ML23143A003
| ML23143A003 | |
| Person / Time | |
|---|---|
| Site: | 99902052 |
| Issue date: | 05/26/2023 |
| From: | Tabatabai-Yazdi O NRC/NRR/DNRL/NRLB |
| To: | Michael Dudek NRC/NRR/DNRL/NRLB |
| References | |
| Download: ML23143A003 (7) | |
Text
May 26, 2023 MEMORANDUM TO:
Michael I. Dudek, Chief New Reactor Licensing Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation FROM:
Omid Tabatabai, Senior Project Manager
/RA/
New Reactor Licensing Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation
SUBJECT:
PRESUBMITTAL AUDIT
SUMMARY
REPORT FOR THE REGULATORY AUDIT OF NUSCALE POWER, ON BEHALF OF CARBON FREE POWER PROJECT, TOPICAL REPORTS ENTITLED, ON-SHIFT AND EMERGENCY RESPONSE ORGANIZATION (ERO) STAFFING, AND EMERGENCY ACTION LEVELS (EALs) SCHEME By email correspondence dated March 28, 20231, NuScale Power, LLC (NuScale), on behalf of Carbon Free Power Project (CFPP), LLC requested the U.S. Nuclear Regulatory Commission (NRC) staff to conduct a presubmittal audit of the topical reports (TRs) entitled On-Shift and Emergency Response Organization (ERO) Staffing, and Emergency Action Levels (EALs)
Scheme.
On May 1, 2023, the NRC staff issued an audit plan2 and held the audit entrance teleconference with NuScale and CFPP, LLC on May 2, 2023. The objective of this audit was for the staff to become familiar with the contents of the TRs and to identify any policy issues and/or significant missing information that would challenge and/or impede the staffs acceptance review of the TRs.
The NRC staffs observations from the presubmittal audit of the TRs are enclosed.
CONTACTS: Omid Tabatabai, NRR/DNRL 301-415-6616 Michael Norris, NSIR/DPR 301-287-3754 Don Johnson, NSIR/DRP 301-287-9230 1 ADAMS Accession No. ML23121A110.
2 ADAMS Accession No. ML23121A068.
The audit was conducted remotely via NuScales Electronic Reading Room and teleconferences on Microsoft Teams. No pre-decisional documents were provided directly to the staff or docketed.
Docket No. 99902052
Enclosure:
As stated cc w/encl.: CFPP Listserv
SGreen*
MDudek OTabatabai DATE 05/23/2023 05/23/2023 05/26/2023 05/26/2023
Enclosure PRESUBMITTAL AUDIT
SUMMARY
REPORT FOR THE REGULATORY AUDIT OF NUSCALE POWER, ON BEHALF OF CARBON FREE POWER PROJECT, TOPICAL REPORTS ENTITLED, ON-SHIFT AND EMERGENCY RESPONSE ORGANIZATION (ERO) STAFFING, AND EMERGENCY ACTION LEVELS (EALs) SCHEME
1.0 BACKGROUND
AND PURPOSE By email correspondence dated March 28, 2023, from NuScale LLC (NuScale) to NRC, NuScale requested an NRC presubmittal engagement for the topical reports (TRs) entitled On-Shift and Emergency Response Organization (ERO) Staffing, and Emergency Action Levels (EALs)
Scheme. As a result of NuScales request, the staff proposed to initiate an audit of the ERO and EAL TRs to assess the needed information. The audit took place at NRC headquarters via use of the NuScale Electronic Reading Room (eRR). The audit entrance was held on May 2, 2023, as mutually agreed.
2.0 REGULATORY AUDIT BASIS This regulatory audit is solely based on NuScales request to the NRC staff to perform a presubmittal assessment of the TRs before NuScale submits the TRs for the NRC review. This presubmittal assessment intended to help the staff determine whether there are any regulatory impediments or significant information gaps in the TRs that would impede a timely and/or efficient acceptance review.
3.0 AUDIT DATES AND LOCATION The audit was conducted remotely. The audit entrance and exit meetings were conducted via Microsoft Teams.
Dates:
May 2, 2023 - May 9, 2023 Location:
NRC Headquarters via NuScale eRR 4.0 AUDIT TEAM MEMBERS Don Johnson, Senior Emergency Preparedness Specialist, NSIR/DRP/POB Michael Norris, Senior Emergency Preparedness Specialist, NSIR/DRP/RLB Omid Tabatabai, Senior Project Manager, NRR/DNRL/NRLB Thomas Hayden, Project Manager, NRR/DNRL/NRLB 5.0 APPLICANT PARTICIPANTS Beth Dalick Kyra Perkins Lindsey Vance Kevin Deyette Robert Sanford John Volkoff
2 6.0 AUDIT DOCUMENTS The staff audited the following documents provided by NuScale in the eRR:
- 1. On-Shift and Emergency Response Organization (ERO) Staffing
- 2. Emergency Action Levels (EALs) Scheme
7.0 DESCRIPTION
OF AUDIT ACTIVITIES AND
SUMMARY
OF OBSERVATIONS This regulatory audit focused on identifying any significant issues that would potentially challenge or impede an efficient and timely NRC review of the TRs when submitted. The NRC staff did not request any additional information or documents to be provided. A summary of staffs observations for each TR is provided below:
7.1.
NRC STAFFS OBSERVATIONS ON EAL SCHEME TOPICAL REPORT
- 1. The EAL scheme, once approved, will need to be considered a public document as well as needing to be available to offsite response organizations.
- 2. For the Fission Barrier (FB) Matrix:
- a. EAL FA1 should be limited to a loss, or potential loss, of either the reactor coolant system or Fuel Clad barriers, and not the Containment Barrier.
- b. Given that there are no logic-based considerations for the FB Matrix, there is no need for a FB Matrix for this design and the relevant criterion can be made into EALs directly.
- 3. Several parts of the document state, or imply, that Notice of Unusual Events (NOUEs) are only applicable when exceeding Technical Specifications (Tech Specs), which is not entirely true. Most NOUEs occur when licensees are still within Tech Specs but are experiencing situations that could escalate to events warranting escalated EAL declarations, i.e., the NOUE is a precursor to an alert or higher emergency classification level (ECL).
- 4. 10 CR 50.72 reporting requirements (non-emergency) are not relevant to the EAL Scheme Development guidance. The EAL Scheme Development guidance should be limited to what is needed to support the development of a design-specific EAL scheme.
- 5. Many NEI 99-01/07-01 EALs, particularly at the Alert level, are considered precursors to escalated classifications and may not be necessary for the NuScale/CFPP EAL scheme (anticipated transient without a scram), toxic gas, natural hazards with safety system concerns, remote shutdown, etc.) Without an understanding of the design, primarily through a review of design-specific Tech Specs, determining if these EALs are necessary would be challenging.
- 6. The NRC staff would need to determine the maximum radiological risk to the public to independently conclude the appropriate, maximum, ECL needed in order to determine the appropriate, scalable, emergency plan requirements, i.e., if the radiological risk is commensurate with the Alert ECL or higher
3 (site area emergency or general emergency). And then a careful review of design-specific Tech Specs, and associated accident analysis, is needed to develop the actual EALs. See Defense-In-Depth discussion below for further clarification.
Defense-in-depth Considerations
- 1. The planning basis for emergency preparedness is in alignment with the Commissions Defense-in-Depth policy. In order to develop the emergency plan, and emergency action levels in particular, we need to understand the public impact when the radionuclide barriers fail (i.e., source term) as well as the design elements, and event sequences of concern (i.e.,
Tech Specs).
- a. Defense-in-depth is an element of NRCs safety philosophy that is used to address uncertainty by employing successive measures including safety margins to prevent and mitigate damage if a malfunction, accident or naturally caused event occurs at a nuclear facility. The ultimate purpose of defense-in-depth is to compensate for uncertainty (e.g.,
uncertainty due to lack of operational experience with new technologies and new design features, uncertainty in the type and magnitude of challenges to safety). The NRCs regulatory framework has four objectives for defense-in-depth:
- i.
Compensate for uncertainties, including events and event sequences which are unexpected because their existence remained unknown during the design phase.
1 Emphasizes the importance of providing some means to counterbalance unexpected challenges.
ii.
Compensate for potential adverse equipment performance, as well as human actions of commission (intentional adverse acts are part of this) as well as omission.
- 1. Addresses uncertainty in equipment and human actions.
- 2. It encompasses equipment design and fabrication errors, as well as both deliberate acts meant to compromise safety, and errors or inadequacy in carrying out procedures meant to ensure safety.
iii.
Maintain the effectiveness of barriers and protective systems by ensuring multiple, generally independent and separate, means of accomplishing their functions.
- 1. Addresses the uncertainty in the performance of the structure, system, and components (SSCs) that constitute the barriers to radionuclide release, as well as in the SSCs whose function is to protect those barriers.
iv.
Protect the public and environment if these barriers are not fully effective (Emergency Planning).
- 1. Emphasizes the concept of layers of protection, in that it addresses the need for additional measures should the barriers to radionuclide release fail after all.
4 7.2 NRC STAFFS OBSERVATIONS ON ERO TOPICAL REPORT
- 1. The TR only evaluates the capabilities of the on-shift staffing to perform their operational and emergency plan functions. It does not evaluate the capabilities offered by the augmenting ERO staff to relieve and support on-shift staffing nor does it evaluate the performance of the repair and mitigation functions.
- 2. The TR does not evaluate the capability of the on-shift staffing, as well as the augmenting ERO, to perform notification of any recommended protective actions to offsite authorities for any type of releases off-site. Nor does it evaluate the capability to assess the extent and magnitude of releases.
- 3. The TR does not provide a basis for the 240-minute augmentation time that addresses the support and relief functions of the augmenting ERO.
- 4. The TR does not address the impacts to the on-shift for delaying the performance of these functions using personnel with a 240-minute augmentation time.
8.0 EXIT BRIEFING The NRC staff conducted an audit exit meeting via a teleconference on May 12, 2023. The NRC staff summarized their observations and described information that would need to be submitted to enable the staff perform an acceptance review of the TRs.
9.0 OPEN ITEMS AND PROPOSED CLOSURE PATHS Not applicable.
10.0 DEVIATIONS FROM THE AUDIT PLAN None.