ML23067A300

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Audit Plan - NuScale SDA Application Phase a Safety Review
ML23067A300
Person / Time
Site: 05200050
Issue date: 03/22/2023
From: Getachew Tesfaye
NRC/NRR/DNRL/NRLB
To: Michael Dudek
NRC/NRR/DNRL/NRLB
References
Download: ML23067A300 (7)


Text

March 22, 2023 MEMORANDUM TO: Michael I. Dudek, Chief New Reactor Licensing Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation FROM: Getachew Tesfaye, Senior Project Manager /RA/

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

SUBJECT:

AUDIT PLAN FOR THE STAFF REVIEW OF THE NUSCALE POWER, LLC STANDARD DESIGN APPROVAL APPLICATION -

NUSCALE US460 By letter dated December 31, 2022 (electronically submitted on January 1, 2023), NuScale Power, LLC (NuScale) transmitted the last part of the required staged submittal of the Standard Design Approval (SDA) application. The submitted documents can be found at Agencywide Documents Access and Management System (ADAMS) Accession No. ML22339A066. The purpose of this audit is for the U.S. Nuclear Regulatory Commission (NRC) staff to conduct the staffs safety review of the NuScale SDA application in such a manner that identified issues can readily and easily be discussed and closed-out in order to provide a more predictable review schedule. The audit also achieves a more effective and efficient review by allowing the staff to review and discuss supporting material with the objective of improving communication and eliminating unnecessary requests for additional information. The staff plans to audit material which may be needed to make a reasonable assurance finding that the design protects public health and safety. If the NRC staff identifies information that is needed to support a finding, NuScale will need to submit that information on the application docket.

The audit will start on March 20, 2023, with an Entrance meeting. The audit has three different end dates based on staff predetermined level of effort for chapters/sections (low, medium, and high). The audit will be conducted primarily via the established NuScale Electronic Reading Room and/or at NuScales offices in either Rockville, Maryland or Corvallis, Oregon. The contents of the audit plan are provided as an enclosure.

Docket No. 05200050

Enclosure:

Audit Plan cc w/enclosure: NuScale Power, LLC Listserv CONTACT: Getachew Tesfaye, NRR/DNRL 301-415-8013

ML23067A300 *via email NRR-106 OFFICE DNRL/NRLB:PM DNRL/NLIB:LA DNRL/NRLB:PM DNRL/NRLB:BC DNRL/NRLB:PM NAME BBavol SGreen* GTesfaye MDudek* GTesfaye DATE 3/02/2023 03/16/2023 03/16/2023 03/22/2023 03/22/2023 UNITED STATES NUCLEAR REGULATORY COMMISSION AUDIT PLAN FOR THE STAFF REVIEW OF THE NUSCALE POWER, LLC STANDARD DESIGN APPROVAL APPLICATION - NUSCALE US460 DOCKET NO. 05200050 AUDIT PLAN APPLICANT:

NuScale Power, LLC (NuScale)

CONTACTS:

Manager: Thomas Griffith Supervisors: Thomas Griffith, Jim Osborn, Stephanie Terwilliger, Shane Scanlon, Wren Fowler DURATION:

Phase A: High Effort Chapters (1, 3.7, 3.8, 6*, 4*, 5*, 8.3, 15*, 16, 17.4, 19.0*- 19.3*) and applicable Technical and Topical Reports - (7 months)

March 27, 2023, through October 27, 2023 Phase A: Medium Effort Chapters (3 except 3.7 and 3.8, 7, 8 except 8.3, 9, 11,

12) and applicable Technical Reports - (5 months) March 27, 2023, through August 27, 2023 Phase A: Low Effort Chapters (2, 10, 13, 14, 17 except 17.4, 18, 19.4-19.X) and applicable Technical Reports - (3 months) March 27, 2023, through June 27, 2023
  • Parts of these chapters are covered by the audit plan (ML23067A298) for the request for supplemental information (RSI) [ Agencywide Documents Access and Management System (ADAMS) Accession No. ML23058A160]. Phase A duration maybe longer than 7 months for these parts.

LOCATION:

U.S. Nuclear Regulatory Commission (NRC) Headquarters (via NuScale) Electronic Reading Room (eRR))

One White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738 NuScale 11333 Woodglen Drive, Suite 205 Rockville, Maryland 20852 NuScale 1100 NE Circle Blvd Corvallis, OR 97330 Enclosure

AUDIT TEAM (Project Managers):

Getachew Tesfaye (Project Lead) Thomas Hayden David Drucker Taylor Lamb Stacy Joseph Alina Schiller Ricky Vivanco Bruce Bavol AUDIT TEAM (Technical Branch Chiefs):

Branch Chief Branch Branch Chief Branch Wendell Morton DEX/EEEB Scott Krepel DSS/SFNB Stewart Bailey DEX/EMIB Brian Wittick DSS/SCPB Jason Paige DEX/ELTB Vic Cusumano DSS/STSB Michael Waters DEX/EICB Dan Widrevitz (A) DNRL/NVIB Joseph Colaccino DEX/ESEB Matthew Mitchell DNRL/NPHP Ian Tseng DEX/ESEB Steven Bloom DNRL/NCSG Barbara Hayes DEX/EXHB Lauren Nist (She) DRO/IOLB Jay Robinson DRA/APLB Kerri Kavanagh DRO/IQVB Shilp Vasavada DRA/APLC Kenneth Erwin NMSS/REFS/ERNRB Kevin Hsueh DRA/ARCB Jessie Quichocho NSIR/DPR/RLB Rebecca Patton DSS/SNRB Brian Yip NSIR/DPCP/CSB Phillip Sahd DSS/SNSB Amanda Marshall NSIR/DPCP/RSB Diana Woodyatt DSS/SNSB 2

I. BACKGROUND AND OBJECTIVES By letter dated December 31, 2022 (electronically submitted on January 1, 2023), NuScale transmitted the last part of the required staged submittal of the Standard Design Approval (SDA) application. The submitted documents can be found at under ML22339A066. The purpose of this audit is for the NRC staff to conduct the staffs safety review of the NuScale SDA application in such a manner that identified issues can readily and easily be discussed and closed-out in order to provide a more predictable review schedule. The audit also achieves a more effective and efficient review by allowing the staff to review and discuss supporting material with the objective of improving communication and eliminating unnecessary requests for additional information.

The staff plans to audit material which may be needed to make a reasonable assurance finding that the design protects public health and safety. If the NRC staff identifies information that is needed to support a finding, NuScale will need to submit that information on the application docket.

II. REGULATORY AUDIT BASIS This regulatory audit is based on the submittal of the final safety analysis report (FSAR) documents for its SDA application of the NuScale design (ML22339A066). The bases for the submittal follow the regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.

  • 10 CFR Subpart E - Standard Design Approvals o § 52.131 Scope of subpart.

o § 52.133 Relationship to other subparts.

o § 52.135 Filing of applications.

o § 52.136 Contents of applications; general information.

o § 52.137 Contents of applications; technical information.

o § 52.139 Standards for review of applications.

o § 52.141 Referral to the Advisory Committee on Reactor Safeguards (ACRS).

o § 52.143 Staff approval of design.

o § 52.145 Finality of standard design approvals; information requests.

o § 52.147 Duration of design approval.

III. REGULATORY AUDIT SCOPE The audit covers all parts of the NuScale SDA application (ML22339A066), except parts of the FSAR covered by the RSI audit plan (ML23067A298); and All parts of the following four topical reports not covered by RSI audit: (1) TR-0516-49422, Loss-of-Coolant Accident [LOCA]

Evaluation Model, Revision 3 (ML23008A002); (2) TR-0516-49416, Non-Loss-of-Coolant Accident Analysis Methodology, Revision 4 (ML23005A305); (3) TR-124587, Extended Passive Cooling and Reactivity Control Methodology, Revision 0 (ML23005A308); and (4)

TR-131981, Methodology for the Determination of the Onset of Density Wave Oscillations (DWO), Revision 0 (ML22364A332).

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IV. INFORMATION AND OTHER MATERIAL NECCSSARY FOR THE REGULATORY AUDIT NuScale should be prepared to provide documents, reports, calculations, computer code verification, and other material, as applicable, supporting the analyses documented in the respective FSAR chapters and technical and topical reports. The NRC staff may request that NuScale make these additional materials available in the eRR and/or as a computer disc to be submitted on the docket.

V SPECIAL REQUESTS NuScale and NRC have discussed and agreed upon the following audit logistics:

  • NuScale creates Certrec eRR locations for document viewing.

o NuScale to set up access for NRC participants once the staff emails are communicated.

  • Weekly schedule for audit activities o Friday - NRC PMs submits audit issues (via email) o Monday - NuScale addresses issues o Tuesday/Wednesday/Thursday - standing audit meetings o Thursday/Friday - NuScale posts issue responses in eRR
  • During the standing audit meetings NuScale and NRC staff will:

o Clarify audit issues o Discuss audit issue resolutions o Discuss additional document needs o Discuss and decide on timeframe for issue resolution Expectation is < 30 days for response to be posted to eRR.

Other timelines to be developed if necessary for a complete resolution.

o Determine if a docketed response is required.

  • NRC to track status of audit issues (internal spreadsheet).

o NRC to provide NuScale a copy of the current tracker on Fridays.

o Ensure mutual alignment during weekly standing meetings.

  • NuScale to develop issue responses to audit questions.
  • Written responses will be uploaded to Certrec eRR on Thursdays/Fridays.

o NRC PMs will be notified via email when responses are available.

o Associated NuScale documents requested in the audit will be available in eRR for viewing.

  • NRC to review audit issue responses and documentation in eRR.
  • Feedback on audit issue responses and discussion to be held in weekly standing meetings.

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  • NRC approval or rejection of audit issue responses communicated verbally.

o If issue response is approved, the NRC staff determines if the response needs to be submitted on the docket.

o NRC will periodically issue an administrative request for additional information (RAI) for issues resolved in eRR and submittal on the docket is needed.

o If response is rejected, NuScale returns to internal response development steps.

  • Responses will be posted twice before moving questions to formal RAI process.

o This is a guideline that can be adjusted if necessary to cycle minor changes.

o Once original response and one revised response are posted, further cycles will be moved to RAI process.

  • NuScale to request NRC elevation audit issue to RAI process via email.
  • The RAI process will be used when:

o NRC requires formal docketing of a response o completion of the response will extend past the audit close date o requested by NuScale or NRC

  • NRC will send formal RAI to NuScale via email
  • RAI clock starts on the day the question is sent o < 30 days from receipt to response posted in eRR
  • NuScale will respond to RAI questions:

o Does the RAI contain proprietary, ECI, SRI information?

o Is clarification needed?

o Is the 30-day timeline achievable?

NuScale responses to RAIs will be submitted to NRC EIE formally VI DELIVERABLES The NRC audit team is expected to consist of the above listed project managers along with a multi-faceted group of NRC technical reviewers and contractors. 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 audit will start on March 27, 2023, and end based on a chapters/sections level of effort designation of Low, Medium, or High.

The NRC will inform NuScale of emerging information needs as well as documents that can be removed from eRR.

An audit report will be generated at the completion of the audit. If necessary, any circumstances related to the conductance of the audit will be communicated to, Getachew Tesfaye, at 301-415-8013 or Getachew.tesfaye@nrc.gov.

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