ML24304B046
| ML24304B046 | |
| Person / Time | |
|---|---|
| Site: | 05200050 |
| Issue date: | 10/30/2024 |
| From: | Fosaaen C NuScale |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| LO-175505, IR 2024201 | |
| Download: ML24304B046 (1) | |
Text
LO-175505 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com October 30, 2024 Docket No. 052-050 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
SUBJECT:
NuScale Power, LLC Reply to a Notice of Violation, EA-24-057
REFERENCES:
- 1. NRC Letter to NuScale, NUCLEAR REGULATORY COMMISSION INSPECTION REPORT OF NUSCALE POWER LLC., NO.
05200050/2024-201, AND NOTICE OF VIOLATION dated April 12, 2024 (ML24099A129)
- 2. NuScale Letter to NRC, NuScale Power, LLC Reply to a Notice of Violation, dated May 10, 2024 (ML24131A153)
- 3. NRC Letter to NuScale, NUSCALE POWER LLC - DISPUTED CITED VIOLATION REVISED 05200050/2024-201-01 dated Sept.
30, 2024 (ML24214A127)
In a letter dated April 12, 2024, the U.S. Nuclear Regulatory Commission (NRC) issued Inspection Report 05200050/2024-201 and Notice of Violation (NOV) 05200050/2024/201 (Reference 1), which was identified during a U.S. Nuclear Regulatory Commission (NRC) hybrid inspection conducted at the NuScale Power, LLC (NuScale) facility in Corvallis, Oregon and the NRC headquarters in Rockville, Maryland on February 26, 2024 through March 1, 2024. In a letter dated May 10, 2024, NuScale responded contesting the Notice of Violation (NOV) and providing additional information for the NRC to consider (Reference 2).
In a letter dated September 30, 2024, NRC responded with a conclusion that the original violation remained valid but one finding was determined to be minor and removed from the NOV.
Reference 3 requires that NuScale submit a written response following the instructions specified, and that NuScale should document the results of the extent of condition review for the finding and determine if there are any effects on design activities associated with the Standard Design Approval Application.
NuScales reply to the NOV is provided in Attachment 1. NuScale does not further contest the NOV. The second finding in Reference 1, concerning a failure to adhere to a procedure on 10 CFR 50.46 reporting, was removed from the revised NOV due to a determination of minor severity level and is thus not addressed in Attachment 1. However, NuScale maintains and notes for the record our view that the second finding did not concern a process affecting quality and therefore did not violate 10 CFR 50 Appendix B Criterion V as alleged. That position was advanced in our basis for dispute in Reference 2 and was unaddressed in NRCs evaluation thereof.
This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.
LO-175505 Page 2 of 2 10/30/2024 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com If you have any questions, please contact Mark W Shaver at 541-360-0630 or at mshaver@nuscalepower.com.
Sincerely, Carrie Fosaaen Vice President, Regulatory Affairs NuScale Power, LLC Distribution:
Russell Felts, Director, Division of Reactor Oversight, NRC Kerri Kavanagh, Chief, Quality Assurance and Vendor Inspection Branch, NRC Mahmoud Jardaneh, Chief, New Reactor Licensing Branch, NRC Getachew Tesfaye, Senior Project Manager, NRC : Reply to Notice of Violation, EA-24-057: Failure to Appropriately Classify Decay Heat Removal System Engineering Calculation
LO-175505 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360.0500 Fax 541.207.3928 www.nuscalepower.com Reply to Notice of Violation, EA-24-057: Failure to Appropriately Classify Decay Heat Removal System Engineering Calculation
LO-175505 Page 1 of 3
NuScale Nonproprietary
© Copyright 2024 by NuScale Power, LLC
Reply to Notice of Violation, EA-24-057: Failure to Appropriately Classify Decay Heat Removal System Engineering Calculation 1.0 Introduction and Background
1.1 Background
Background is provided in NuScales response to the initial NOV (Reference 4.6). The revised notice of violation (NOV, Reference 4.7) has been posted for employees.
1.2 NRC Finding The NRC finding is identified in Reference 4.6. The revised NOV (Reference 4.7) maintains the finding that:
NuScale failed to appropriately classify engineering calculation (EC) 101197, DHRS Thermal Hydraulic Calculation for the NPM-20, in accordance with EP-0303-2109. EP-0303-2109 defines safety-related SSCs as those structures, systems and components that are relied upon to remain functional during and following design-basis events to assurethe capability to shut down the reactor and maintain it in a safe shutdown condition. EC-101197 was classified as Non-Safety Related when its stated scope is, in part, to assess the decay heat removal systems ability to perform its safety-related function to achieve and maintain safe shutdown.
The NRCs evaluation of NuScales position (Reference 4.7) further notes:
It was noted that without the DHRS calculations being considered safety-related, NuScale has no safety-related calculations in the DHRS to show the ability to shut down the reactor and maintain it in a safe shutdown condition. Though NuScale argued that the error is in EP-0303-303, that can be a contributing cause for its failure to adhere to EC-101197, and NuScale does not properly classify the DHRS calculations as a safety-related calculation, even if only in part.
2.0 Requested Information 2.1 Summary Reference 4.6 discusses the creation of condition report (CR) 164140 to evaluate the classification of safety-related functions of the DHRS involving EC-101197 (Reference 4.3). As discussed there, the noncompliance was determined to be in implementation of Design Control Process, QP-0303-10267 (Reference 4.4) rather than with Classification of Structures, Systems, and Components, EP-0303-2109 (Reference 4.5) as identified in the inspection report and NOV.
LO-175505 Page 2 of 3
NuScale Nonproprietary
© Copyright 2024 by NuScale Power, LLC
NuScale has since completed the corrective actions identified in Reference 4.6.
2.2 Reason for the Violation The reason for the violation is addressed in Reference 4.6.
2.3 Corrective Steps Taken and Results Achieved Three corrective actions (CAs) were assigned to resolve the condition, as identified in Reference 4.6. The three CAs were misidentified in Reference 4.6 and are thus restated here for clarity:
NuScale ID #
Action Description CR 164140-CA-1 Move the safety classification statement in EC-101197 from the purpose to the scope section, to align with guidance in EP-0303-303 and EP-0303-303-F01. Ensure the safety classification relates to a categorized system function from the DHRS system function report.
CR 164140-CA-2 Review the purpose and scope of EC-101197 to identify the functionality the calculation is analyzing, and determine if this functionality is identified in the DHRS system function report. Create follow-on actions as necessary to revise the system function report and/or EC-101197, and other impacted documents (if any)
CR 164140-CA-3 Communicate and reinforce the process requirements related to safety classification of engineering documents to the engineering organization The CAs are complete and closure verification for CR 164140 was completed on September 12, 2024.
The result of CA-2 is that EC-101197 addresses a function identified in the DHRS system function report, and that the calculation establishes the engineering design basis for a safety-related SSC function as categorized through EP-0303-2109. Therefore, EC-101197 needs to be revised to a safety-related classification.
Following the completion of CA-2, engineering change request (ECR) 173775 was created against EC-101197 to specify: (1) moving the safety classification from the purpose to the scope section, pursuant to current QP-0303-10267, and (2) modifying the safety classification to safety-related in accordance with the result of CA-2. Engineering change request 173775 is required to be addressed in Revision 3 of EC-101197.
Closure of a CA via ECR is an approved process in NuScales corrective action program (CAP), and thus completed CA-1.
Corrective action 3 was completed via communication during an engineering all-hands meeting. Engineering management emphasized procedure use and adherence and specifically discussed the process for safety classification of design documents.
2.4 Corrective Steps Taken to Avoid Further Violations See discussion in Reference 4.6. Additionally, CA-3 was completed to avoid further violations.
LO-175505 Page 3 of 3
NuScale Nonproprietary
© Copyright 2024 by NuScale Power, LLC
2.5 Date When Full Compliance Will Be Achieved Condition report 164140 is closed and compliance has been achieved.
2.6 Results of The Extent of Condition Review and Effects on Design Activities Associated with the Standard Design Approval Application (SDAA)
Under NuScales CAP, an extent of condition review was not required.
The results of EC-101197 were not found to be in error, only the safety classification. No effect on SDAA design activities was identified.
3.0 Conclusion On the basis of the information presented, NuScale requests the NRC to conclude that further enforcement action is unnecessary to ensure compliance with regulatory requirements.
4.0 References 4.1 NRC Letter to NuScale, Nuclear Regulatory Commission Inspection Report of NuScale Power LLC., No. 05200050/2024-201, and Notice of Violation, April 12, 2024 (ML24099A129).
4.2 NuScale Power, LLC, NuScale Power, LLC Quality Assurance Program Description, MN-122626-A, Revision 1.
4.3 NuScale Power, LLC DHRS Thermal Hydraulic Calculation for the NPM-20, EC-101197, Revision 2.
4.4 NuScale Power, LLC Design Control Process, QP-0303-10267, Revision 20.
4.5 NuScale Power, LLC Classification of Structures, Systems, and Components, EP-0303-2109, Revision 11.
4.6 NuScale Letter to NRC, NuScale Power, LLC Reply to a Notice of Violation, dated May 10, 2024 (ML24131A153), Attachment 2, Additional Information Regarding finding One, Failure to Appropriately Classify Engineering Calculation (EC) EC-101197 4.7 NRC Letter to NuScale, NUSCALE POWER LLC - DISPUTED CITED VIOLATION REVISED 05200050/2024-201-01 dated Sept. 30, 2024 (ML24214A127)