ML23258A217
| ML23258A217 | |
| Person / Time | |
|---|---|
| Site: | Electric Power Research Institute |
| Issue date: | 09/26/2023 |
| From: | Lois James Licensing Processes Branch |
| To: | Camilli N Electric Power Research Institute |
| References | |
| TR 3002023774, EPID L-2023-TOP-0038 prior to fee exemp | |
| Download: ML23258A217 (1) | |
Text
September 26, 2023 Nicholas Camilli, Principal Project Manager Nuclear Maintenance Applications Center Program (NMAC)
Electric Power Research Institute (EPRI) 1300 West W.T. Harris Boulevard Charlotte, NC 28262-8550
SUBJECT:
ELECTRIC POWER RESEARCH INSTITUTE REGULATORY AUDIT PLAN IN SUPPORT OF THE REVIEW OF TECHNICAL REPORT 3002023774, EPRI MOV PERFORMANCE PREDICTION METHODOLOGY, VERSION 4.1 (EPID L-2023-TOP-0038)
Dear Mr. Camilli:
By letter dated June 14, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23180A012), Electric Power Research Institute (EPRI) submitted the Motor-Operated Valve (MOV) Performance Prediction Methodology (PPM), Version 4.1, Technical Report 3002023774, to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. The EPRI MOV PPM software was developed to enhance industry's ability to size MOVs and predict their performance in meeting the applicable design-basis safety functions.
The NRC staff reviewed EPRIs request and determined that a regulatory audit would assist in the timely completion of the NRC staffs review. The NRC staff will conduct a regulatory audit to support its review of the EPRI MOV PPM, Version 4.1, in accordance with the enclosed audit plan.
The NRC staff will conduct the audit to increase its understanding of the EPRI MOV PPM and identify information that will require docketing to support the NRC staffs regulatory findings. The NRC staff plans to conduct the audit virtually via an EPRI-established electronic portal.
However, should the NRC staff determine that an in-person audit would be a more efficient method to conduct the audit and gather needed information, the staff may use that approach in addition to the virtual audit.
If you have any questions, please contact me by email at lois.james@nrc.gov.
Sincerely,
/RA/
Lois M. James, Senior Project Manager Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 99902021
Enclosure:
Audit Plan
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION IN SUPPORT OF THE REVIEW OF TECHNICAL REPORT 3002023774, EPRI MOV PERFORMANCE PREDICTION METHODOLOGY, VERSION 4.1 ELECTRIC POWER RESEARCH INSTITUTE DOCKET NO. 99902021 EPID L-2023-TOP-0038
1.0 BACKGROUND
By letter dated June 14, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23180A012), Electric Power Research Institute (EPRI) submitted the Motor-Operated Valve (MOV) Performance Prediction Methodology (PPM), Version 4.1, Technical Report 3002023774, to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. The EPRI MOV PPM software was developed to enhance industry's ability to size MOVs and predict their performance in meeting the applicable design-basis safety functions.
By email dated August 16, 2023 (ADAMS Accession No. ML23179A263), the NRC staff accepted the EPRI MOV PPM, Version 4.1, for review.
The NRC staff has identified the need to conduct a regulatory audit to better understand the EPRI MOV PPM, Version 4.1, by reviewing the supporting documentation and discussing this documentation with EPRI staff.
2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The audit is conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the NRC staff in efficiently conducting its review and gaining insights into specific processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.
The NRC staff will perform the audit in accordance with this audit plan and NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 2019 (ADAMS Accession No. ML19226A274).
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The objective of this audit is to verify, via an independent evaluation, that the EPRI MOV PPM, Version 4.1, conforms to applicable regulations, standards, guidelines, plans, and procedures.
The NRC staff will review and discuss the supporting documents, as described in Section 4.0 of this audit plan, with EPRI staff to determine if additional information will require docketing to develop and support conclusions for the NRC staffs safety evaluation of the EPRI MOV PPM, Version 4.1.
4.0 INFORMATION AND OTHER MATERIAL FOR THE REGULATORY AUDIT The NRC staff requests that EPRI have the following information readily available and accessible for the NRC staffs review via an online portal, or as part of the audit discussions:
- 1. An example demonstrating the incorporation and performance of the Thrust Uncertainty Method as part of the EPRI MOV PPM.
- 2. An example demonstrating the incorporation and performance of the refined gate valve unwedging equation as part of the EPRI MOV PPM.
- 3. An example demonstrating the incorporation and performance of the Borg Warner multiplier as part of the EPRI MOV PPM.
- 4. An example demonstrating the incorporation and performance of the new guidance for addressing unwedging effects for globe valves as part of the EPRI MOV PPM.
- 5. An example describing the changes to the PPM parametric output report to allow parametric evaluations to be used as a design standard, and demonstrating the incorporation and performance of the method using packing parametric runs.
- 6. Description of problem reports or other issues that resulted in significant upgrades or corrections to the EPRI MOV PPM.
Additional information may be requested to be added to the portal by the NRC staff based on the NRC staffs continued review of the EPRI MOV PPM, Version 4.1, and supporting documents, and based on audit discussions.
Based on the audit, the NRC staff will determine whether additional information needs to be submitted on the docket for the staff to complete the review of EPRI MOV PPM, Version 4.1, via a request for additional information (RAIs).
5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff:
NAME E-MAIL DIVISION BRANCH Ms. Lois James Lois.james@nrc.gov Division of Operating Reactor Licensing Licensing Projects Branch Mr. Thomas Scarbrough Thomas.Scarbrough@nrc.gov Division of Engineering and External Hazards Mechanical Engineering &
Inservice Testing Branch 6.0 LOGISTICS The audit will be conducted from October 10-13, 2023, through an online portal (also known as electronic portal, ePortal, or electronic reading room) established by EPRI.
The audit team will conduct a TEAMS-based entrance meeting with EPRI on October 10, 2023, for the purposes of introducing the team, discussing the scope of the audit, and describing the information to be made available on the portal. During the week of October 10, 2023, the NRC staff will hold breakout sessions with representatives of EPRI to answer audit team questions.
An exit meeting/call will be held at the conclusion of the audit.
The NRC staff does not foresee the need for an onsite visit or in-person discussions between the NRC and EPRI staff to discuss information to be provided on the portal at this time.
However, if the need for such a meeting is identified in the future, the audit plan will be revised, and the schedule for the audit will be adjusted accordingly. The NRC project manager will coordinate any changes to the audit schedule and location with EPRI.
7.0 SPECIAL REQUESTS The audit team would like access to the documents indicated in Section 4.0 above through an online portal that allows the audit team to access documents via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the audit team has access to the online portal:
The online portal will be password-protected, and separate passwords will be assigned to the NRC staff who are participating in the audit.
The online portal will be sufficiently secure to prevent the NRC staff from printing, saving, downloading, or collecting any information on the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.
Username and password information should be provided directly to the NRC staff. The NRC project manager will provide to EPRI the names and contact information of the NRC staff who will be participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES An audit summary report will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the NRC staff will issue an RAI to EPRI.
- via email NRR-106 OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DEX/EMIB/BC NRR/DORL/LLPB/BC NAME LJames DHarrison SBailey GGeorge DATE 09/18/2023 09/20/2023 09/26/2023 09/26/2023 OFFICE NRR/DORL/LLPB/PM NAME LJames DATE 09/26/2023