ML23276A611
| ML23276A611 | |
| Person / Time | |
|---|---|
| Site: | 99902052 |
| Issue date: | 10/10/2023 |
| From: | Omid Tabatabai NRC/NRR/DNRL/NRLB |
| To: | Jardaneh M NRC/NRR/DSS/STSB |
| References | |
| Download: ML23276A611 (5) | |
Text
October 10, 2023 MEMORANDUM TO:
Mahmoud Jardaneh, 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:
AUDIT PLAN FOR THE NRC STAFF REVIEW OF THE CARBON FREE POWER PROJECT, LLC LIMITED WORK AUTHORIZATION APPLICATION AND NUSCALE POWER, LLC EXEMPTION REQUEST By letter dated July 31, 2023, Carbon Free Power Project (CFPP), LLC submitted an application for a limited work authorization (LWA) to the U.S. Nuclear Regulatory Commission (NRC) for the staffs review and approval1. On July 31, 2023, NuScale Power, LLC (NuScale) also submitted a letter to the NRC requesting for an exemption from the requirements in 10 CFR 50.10(c). CFPP and NuScale seek NRC approval to conduct certain early construction activities at the CFPP site before a combined license (COL) is issued 2. CFPP plans to submit its COL application in January 2024.
The purpose of this audit is to assist and facilitate the NRC staffs review of the LWA and exemption request. The audit will start on October 30, 2023, and is expected to last for eight weeks, ending on December 22, 2023. The audit will be conducted primarily via the NuScale Electronic Reading Room (eRR), however the staff may need to conduct certain aspects of the audit at the CFPP site location and/or NuScales offices in either Rockville, Maryland or Corvallis, Oregon. The contents of the audit plan are provided as an enclosure.
Docket No. 99902052
Enclosure:
Audit Plan cc w/enclosure: CFPP Listserv CONTACT: Omid Tabatabai, NRR/DNRL 301-415-6616 1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML23212A007.
2 ML23212A003.
- via email NRR-106 OFFICE DNRL/NRLB:PM DNRL/NLIB:LA DNRL/NRLB:BC DNRL/NRLB:PM NAME OTabatabai SGreen*
MJardaneh*
OTabatabai DATE 10/10/2023 10/03/2023 10/10/2023 10/10/2023 2
UNITED STATES NUCLEAR REGULATORY COMMISSION AUDIT PLAN FOR THE NRC STAFF REVIEW OF THE CARBON FREE POWER PROJECT, LLC LIMITED WORK AUTHORIZATION APPLICATION AND NUSCALE POWER, LLC EXEMPTON REQUEST DOCKET NO. 99902052 AUDIT PLAN APPLICANT: Carbon Free Power Project (CFPP)
CONTACTS: John Volkoff Kyra Perkins Beth Dalick DURATION: October 30, 2023 - December 22, 2023 LOCATION:
NuScale Electronic Reading Room (eRR)
CFPP Site Idaho National Laboratory, Idaho Falls, Idaho NuScale Offices Corvallis, OR and/or Rockville, MD AUDIT TEAM Mahmoud Jardaneh, Chief, NRR/DNRL/NRLB Omid Tabatabai, Lead Licensing Project Manager Daniel Barnhurst, Environmental Project Manager Gerry Stirewalt, Sr. Environmental Project Manager Ian Tseng, Chief, NRR/DEX/ESEB Barbara Hayes, Chief, NRR/DEX/EXHB Fred Miller, Chief, NMSS/REFS/FAB Shilp Vasavada, Chief, NRR/DRA/PRAC Antohny Bowers, Chief, NSIR/RLB Kerri Kavanagh, Chief, NRR/DRO/IQVB Amitava Ghosh, Physical Scientist Jenise Thompson, Geologist Shawn Harwell, Financial Analyst Stacy Prasad, Sr. Security Risk Analyst Paul Harris, Sr. Program Manager (Fitness for Duty)
Sunwoo Park, Reliability and Risk Analyst Frankie Vega, Reactor Operations Engineer Other NRC subject matter experts, as needed.
3 I.
BACKGROUND AND OBJECTIVES By two letters, dated July 31, 2023, to the U.S. Nuclear Regulatory Commission (NRC), Carbon Free Power Project (CFPP) LLC, and NuScale Power, LLC (NuScale) submitted an application for a limited work authorization (LWA) and a related exemption request for the NRC staffs review and approval. The CFPP and NuScale submittals are available in the NRCs Agencywide Documents Access and Management System (ADAMS) with Accession Nos. ML23212A007 and ML23212A003, respectively. CFPP seeks NRCs authorization to conduct certain early construction activities at the site that would otherwise require a construction permit or a combined license. On September 5, 2023, the NRC staff accepted CFPPs LWA application for docketing and a detailed review3. CFPP plans to build and operate a 6-module NuScale US460 nuclear plant at Idaho National Laboratory, near Idaho Falls, Idaho.
The purpose of this audit is to: (1) assist and facilitate the NRC staffs review of the LWA and exemption request, (2) provide the NRC staff with a regulatory vehicle to conduct a more effective and efficient review of the LWA and the exemption request, and (3) identify any supporting material that the NRC staff may require CFPP and/or NuScale to submit on the docket in order for the staff to make and document a finding whether the LWA and exemption request meet all the applicable regulatory requirements.
II.
REGULATORY AUDIT BASIS This audit will inform the NRC staffs review in making a reasonable assurance finding that the early construction activities under the LWA and exemption request, if approved, would not pose undue risk to public health and safety, or the environment. Therefore, the regulatory bases for conducting the audit include all the applicable NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, and 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.
III.
REGULATORY AUDIT SCOPE The scope of this regulatory audit is consistent with the scope of the activities requested by CFPP and NuScale under the LWA and exemption request submittals. Specifically, the audit covers all parts of the CFPP LWA application and NuScale exemption request, and NuScales Topical Report TR-121172-NP, Carbon Free Power Project Quality Assurance Program Description, Revision 004.4 IV.
INFORMATION AND OTHER MATERIAL NECCSSARY FOR THE REGULATORY AUDIT CFPP and NuScale should be prepared to make available for the NRC staff review documents, reports, calculations, and other material, as applicable, supporting the information and analyses documented in the LWA application and exemption request, as well as CFPPs Quality Assurance Program Description (QAPD) topical report. The NRC staff may request that CFPP and/or NuScale make these additional materials available in the eRR and/or submit on the docket.
3 ML23236A263.
4 ML23212A002.
V SPECIAL REQUESTS NuScale and NRC have discussed and agreed upon the following audit logistics:
NuScale creates Certrec eRR folder(s) for document viewing.
Weekly, or as needed, check-in calls between the NRC staff and NuScale/CFPP to: (1) discuss audit issues, (2) discuss audit issues path to resolution, (3) discuss additional document needs, and (4) determine if a docketed response is required, including whether issuing a formal request for additional information (RAI) is appropriate.
VI DELIVERABLES An audit report will be generated at the completion of the audit. The NRC staff plans to complete its audit report within 45 days after completing the audit. The NRC staff acknowledges the proprietary nature of the information requested and will handle such information appropriately throughout the audit.