ML23293A264
| ML23293A264 | |
| Person / Time | |
|---|---|
| Site: | Electric Power Research Institute |
| Issue date: | 11/16/2023 |
| From: | Lois James Licensing Processes Branch |
| To: | Camilli N Electric Power Research Institute |
| References | |
| TR 3002023774, TR 3002023774, Revision 4.1, L-2023-TOP-0038 prior to fee exemp, TR 3002023774, Rev 4.1, L-2023-NTR-0006 after fee exemp, EPID L-2023-NTR-0006 | |
| Download: ML23293A264 (1) | |
Text
November 16, 2023 Nicholas Camilli, Principal Project Manager Nuclear Maintenance Applications Center Program Electric Power Research Institute 1300 West W.T. Harris Boulevard Charlotte, NC 28262-8550
SUBJECT:
REPORT REGARDING OCTOBER 10 - 13, 2023, REGULATORY AUDIT FOR ELECTRIC POWER RESEARCH INSTITUTE TECHNICAL REPORT 3002023774, MOTOR-OPERATED VALVE PERFORMANCE PREDICTION METHODOLOGY, VERSION 4.1 (EPID L-2023-NTR-0006)
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, 3002023774, to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. The EPRI MOV PPM software was developed to enhance industrys ability to size MOVs and predict their performance. The NRC staff reviewed and accepted the technical report on August 16, 2023 (ADAMS Accession No. ML23179A263).
On October 10 through 13, 2023, the NRC staff conducted a virtual regulatory audit with EPRI technical staff to discuss supporting documentation and to ask questions about the review of the changes implemented in Version 4.1 of the MOV PPM. The results of the audit provided additional information to support the NRC staff safety evaluation. The audit report is enclosed.
Please contact me via e-mail at Lois.James@nrc.gov with any questions you may have regarding this letter or audit report.
Sincerely,
/RA/
Lois M. James, Project Manager Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 99902021
Enclosure:
Audit Report
Enclosure REGULATORY AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION IN SUPPORT OF THE REVIEW OF TECHNICAL REPORT 3002023774, ELECTRIC POWER RESEARCH INSTITUTE MOTOR-OPERATED VALVE PERFORMANCE PREDICTION METHODOLOGY, VERSION 4.1 ELECTRIC POWER RESEARCH INSTITUTE DOCKET NO. 99902021 EPID L-2023-NTR-0006
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, Report 3002023774, to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. The EPRI MOV PPM software was developed to enhance the industrys 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 in the Office of Nuclear Reactor Regulation (NRR) accepted the EPRI MOV PPM, Version 4.1, for review.
During its initial review of the EPRI MOV PPM, Version 4.1, the NRC staff identified the need to conduct a regulatory audit to better understand the EPRI MOV PPM, Version 4.1, by reviewing the supporting documentation for the PPM software changes and discussing this documentation with EPRI staff.
In this report, the NRC staff summarizes the results of its audit of Version 4.1 of the EPRI MOV PPM conducted virtually.
2.0 REGULATORY AUDIT BASIS The NRC staff performed the regulatory audit of Version 4.1 of the EPRI MOV PPM as a planned regulation-related activity for the examination and evaluation of primarily non-docketed information related to the EPRI MOV PPM, Version 4.1. The NRC staff conducted the audit to gain an understanding of the EPRI MOV PPM, Version 4.1; to verify information described in Addendum 11 to EPRI MOV PPM TR-103237-R2; and to identify any information that would require docketing needed to support the basis for the regulatory decision by the NRC staff in its evaluation of the EPRI MOV PPM, Version 4.1. The NRC staff performed the audit in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 2019 (ADAMS Accession No. ML19226A274).
3.0 NRC AUDIT TEAM The audit team consisted of the following NRC staff:
NAME E-MAIL NRR DIVISION BRANCH Lois James Lois.James@nrc.gov Division of Operating Reactor Licensing Licensing Projects Branch Thomas Scarbrough Thomas.Scarbrough@nrc.gov Division of Engineering and External Hazards Mechanical Engineering and Inservice Testing Branch Nicholas Hansing Nicholas.Hansing@nrc.gov Division of Engineering and External Hazards Mechanical Engineering and Inservice Testing Branch 4.0 AUDIT PREPARATION In a letter dated September 26, 2023 (ADAMS Accession No. ML23258A217), the NRC staff provided the audit plan to EPRI describing the scope of the audit and information requested to be made available in an EPRI-established electronic portal. EPRI made available that information, and additional information identified during the audit, in the EPRI-established electronic portal.
5.0 DOCUMENTS AND INFORMATION MADE AVAILABLE BY EPRI EPRI made the following documents and information available in the electronic portal for audit review:
- 1. EPRI Motor-Operated Valve Performance Prediction Program, Addendum 11 to TR-103237-R2 - Changes to Performance Prediction Methodology Software, Version 4.1, 2023 Technical Report 3002026131 (March 2023)
- 2. EPRI MOV Performance Prediction Program: Performance Prediction Methodology (PPM) Version 4.1 User Manual and Implementation Guide, EPRI 3002023774 (Final Report, July 2022)
- 3. MPR Letter dated January 6, 2023, EPRI PPM Software Error Status File, from Timothy H. Shaw, MPR, to Ms. Valerie Vaughn, EPRI, which forwards Revision 15 of MPR Document 0140-0271-01, EPRI PPM Software Report Status File
- 4. MPR Document 0140-0415-SPEC-002 (Revision 0, June 11, 2022), Software Verification and Validation Plan for EPRI MOV PPM v4.1
- 5. MPR Document 0140-0415-RPT-001 (Revision 0, August 22, 2022), PPM Version 4.1: Verification and Validation Report
Thrust Uncertainty Method, Revision 1, Report 1003279 (Final Report, November 2002)
- 7. Examples demonstrating the incorporation and performance of the Thrust Uncertainty Method (TUM) as part of the EPRI MOV PPM
- 8. Examples demonstrating the incorporation and performance of the refined gate valve unwedging equation as part of the EPRI MOV PPM
- 9. Examples demonstrating the incorporation and performance of the Borg-Warner gate valve multiplier as part of the EPRI MOV PPM
- 10. Guidance provided for addressing potential unwedging effects of globe valves as part of the EPRI MOV PPM documentation
- 11. Examples describing the changes to the PPM parametric reports to allow parametric evaluations to be used as a design standard for packing loads and demonstrating the incorporation and performance of the method using packing parametric runs
- 12. A description of EPRI MOV PPM problem reports or other issues that resulted in significant upgrades or corrections to the EPRI MOV PPM
- 13. A description of the process for installation and operation of the EPRI MOV PPM on an NRC laptop 6.0 AUDIT PERFORMANCE The objective of this audit by the NRC staff was to verify that the EPRI MOV PPM, Version 4.1, conforms to applicable regulations, standards, guidelines, plans, and procedures. The NRC staff relied on the review described in previously issued NRC safety evaluations (SEs) for the acceptability of earlier versions of the EPRI MOV PPM.
On October 10, 2023, the NRC staff held an audit entrance meeting using Teams to discuss the scope and plan for the audit of the EPRI MOV PPM, Version 4.1. Following the entrance meeting, EPRI and supporting personnel described each of the changes provided in Version 4.1 to the EPRI MOV PPM for the NRC staff audit team.
During the audit, the NRC staff identified additional information that was needed to complete the review of the EPRI MOV PPM, Version 4.1, beyond that requested in the audit plan. EPRI provided the additional requested information in the electronic portal during the audit. For example, EPRI made available MPR Document 0140-0415-SPEC-002 (Revision 0, June 11, 2022), which describes activities to perform software verification and validation (V&V) for modifications to the software to create Version 4.1 of the EPRI MOV PPM. EPRI also made available MPR Document 0140-0415-RPT-001 (Revision 0, August 22, 2022), which provides the results of the V&V evaluation for each change in the EPRI MOV PPM, Version 4.1. The NRC staff verified that these reports indicate that the V&V activities were implemented in accordance with the quality assurance (QA) requirements of Title 10 of Code of Federal Regulation Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, including independent verification of the evaluation results.
In Supplement 3 to the NRC SE dated September 30, 2002 (ADAMS Accession No. ML022410364) of Addendum 2 to EPRI TR-103237-R2, the NRC staff accepted the hand-calculation method for the TUM that allows the user of the EPRI MOV PPM to calculate a less conservative prediction of the thrust required to operate gate valves under dynamic flow from the standard EPRI MOV PPM calculation, with specific conditions. EPRI has incorporated the hand calculation method for applying TUM into the Version 4.1 software. During the audit, the NRC staff reviewed examples of EPRI MOV PPM prediction output reports that demonstrated the incorporation and performance of the TUM as part of the EPRI MOV PPM, Version 4.1. The NRC staff reviewed the changes from PPM prediction output reports provided from Version 4.0 to Version 4.1 related to the calculations of the predicted MOV thrust requirements using the TUM. With assistance from EPRI personnel operating the software, the NRC staff reviewed the automatic software notifications where parameters were input that exceeded the limitations for application of the TUM. The NRC staff found that the EPRI MOV PPM, Version 4.1, referred users to the applicable EPRI document for guidance to incorporate the TUM results (including the TUM uncertainty values) into the MOV thrust prediction calculation. At the request of the NRC staff, EPRI made available the updated Addendum 2 to EPRI TR-103237-R2, which incorporated the NRC SE at the beginning of the report. The NRC staff verified that the TUM incorporation into the EPRI MOV PPM, Version 4.1, included V&V activities described in the applicable EPRI reports.
The NRC staff reviewed examples of the EPRI MOV PPM prediction output reports that demonstrated the incorporation and performance of the refined gate valve unwedging equation as part of the EPRI MOV PPM, Version 4.1. The modification to the EPRI MOV PPM in Version 4.1 included the ability to use the refined unwedging equation in reverse to calculate the highest allowed measured static unwedging load. The NRC staff verified that the incorporation of the refined gate valve unwedging equation into the EPRI MOV PPM, Version 4.1, included V&V activities described in the applicable EPRI reports.
The NRC staff reviewed examples of the EPRI MOV PPM prediction output reports and parametric reports that demonstrated the incorporation and performance of the multiplier for the thrust prediction for Borg-Warner gate valves as part of the EPRI MOV PPM, Version 4.1. The automatic application of the multiplier for Borg-Warner gate valves is consistent with the initial NRC SE dated March 15, 1996 (ADAMS Accession No. ML15142A761) on the EPRI MOV PPM. The NRC staff checked a sample of the EPRI MOV PPM prediction output reports and parametric reports for accurate thrust predictions with the Borg-Warner gate valve multiplier, with minor deviations from rounding numbers. The NRC staff verified that the incorporation of the automatic application of the Borg-Warner gate valve multiplier into the EPRI MOV PPM, Version 4.1, included V&V activities described in the applicable EPRI reports.
The NRC staff reviewed the new guidance prepared by EPRI for addressing potential unwedging effects of globe valves as part of the EPRI MOV PPM. This new guidance reflects operating and test experience that globe valves might experience unwedging effects as a result of the disk angle for some globe valves that allows the disk to enter the seat more fully than typically assumed for globe valves. The new guidance specifies that globe valve unwedging effects are not modeled by the EPRI MOV PPM and are the responsibility of the user to address when identified. The new guidance indicates how to use the PPM results with the identified globe valve unwedging effect, and how an unwedging effect can be conservatively applied to PPM inputs. EPRI indicated that the PPM software and engineering methods were not adjusted for the globe valve unwedging effect. The NRC staff verified that this new guidance is included in the user manual for the EPRI MOV PPM, Version 4.1.
The NRC staff reviewed examples of the PPM parametric reports for the EPRI MOV PPM, Version 4.1, based on the changes to the software that allow parametric evaluations to be used as a design standard for packing loads, and demonstrating the incorporation and performance of the method using packing parametric runs. In the EPRI MOV PPM, Version 4.1, EPRI made the PPM prediction output reports more complete to allow parametric predictions of packing load to be used as design basis outputs. The updated parametric reports indicate that the parametric results for gate valves, butterfly valves, and globe valves cannot be used as design basis output, except for packing evaluations.
The NRC staff reviewed the description of each EPRI MOV PPM problem report or other notification that resulted in changes to the EPRI MOV PPM in Version 4.1. For example, the NRC staff reviewed Addendum 11 to TR-103237-R2, which describes the changes in the EPRI MOV PPM, Version 4.1, and the basis for each change. The NRC staff also reviewed MPR Document 0140-0415-RPT-001, which discussed the changes in the EPRI MOV PPM, Version 4.1, and the results of the V&V activities for each change.
On October 13, 2023, the NRC staff held an audit exit meeting using Teams to summarize the results of the audit, and to discuss the next steps for the NRC review of Version 4.1 of the EPRI MOV PPM. During the meeting, the NRC staff stated that it had not identified any additional information at that time that is needed to be submitted on the docket for the NRC staff to complete the review of the EPRI MOV PPM, Version 4.1. When preparing its SE, the staff will determine whether any requests for additional information (RAIs) are needed to complete its review of the EPRI MOV PPM, Version 4.1.
7.0 CONCLUSION
The NRC staff has completed its audit of the information made available by EPRI in the electronic portal to support the NRC review of Version 4.1 of the EPRI MOV PPM. The regulatory audit of Version 4.1 of the EPRI MOV PPM allowed the NRC staff to gain an understanding of the EPRI MOV PPM, Version 4.1; to verify information described in Addendum 11 to EPRI MOV PPM TR-103237-R2; and to identify any information that would require docketing to support the basis for the regulatory decision by the NRC staff in its evaluation of the EPRI MOV PPM, Version 4.1.
8.0 EPRI AUDIT PARTICIPANTS NAME BRANCH Nick Camilli EPRI Tim Shaw MPR Associates
- via eConcurrence NRR-106 OFFICE NRR/DORL/LLPB*
NRR/DORL/LLPB*
NRR/DEX/EMIB/BC*
NRR/DORL/LLPB/BC*
NAME LJames DHarrison SBailey GGeorge DATE 10/20/2023 10/26/2023 11/6/2023 11/8/2023 OFFICE NRR/DORL/LLPB*
NAME LJames DATE 11/16/2023