ML21083A121

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Cover Letter with Enclosure April 8-9, 2021, Regulatory Audit Plan for the Westinghouse Electric Company Topical Report WCAP-18446-P/WCAP-18446-NP, Revision 0, Incremental Extension of Burnup Limit for Westinghouse and Combustion Engineerin
ML21083A121
Person / Time
Site: Westinghouse
Issue date: 03/30/2021
From: Dennis Morey
Licensing Processes Branch
To: Zozula C
Westinghouse
Lenning E
Shared Package
ML21083A114 List:
References
EPID L-2020-TOP-0064, WCAP-18446-P
Download: ML21083A121 (4)


Text

March 30, 2021 Ms. Camille Zozula Manager, Infrastructure & Facilities Licensing Westinghouse Electric Company 1000 Westinghouse Drive, Building 1, Suite 165 Cranberry Township PA 16066

SUBJECT:

APRIL 8-9, 2021, REGULATORY AUDIT PLAN FOR THE WESTINGHOUSE ELECTRIC COMPANY TOPICAL REPORT WCAP-18446-P/WCAP-18446-NP, REVISION 0, INCREMENTAL EXTENSION OF BURNUP LIMIT FOR WESTINGHOUSE AND COMBUSTION ENGINEERING FUEL DESIGNS (EPID L-2020-TOP-0064)

Dear Ms. Zozula:

By letter dated December 14, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20350B834), Westinghouse Electric Company (Westinghouse)

(applicant) submitted to U.S. Nuclear Regulatory Commission (NRC) Topical Report (TR)

WCAP-18446-P/WCAP-18446-NP, Revision 0, Incremental Extension of Burnup Limit for Westinghouse and Combustion Engineering Fuel Designs, for review and approval.

The NRC staff technical review of this TR is ongoing. The NRC staff determined that a regulatory audit is needed in order to facilitate the review. The NRC staff will perform a virtual regulatory closed audit on April 8-9, 2021. Enclosed for your information is a copy of the plan the NRC staff will follow during the audit.

If you have any questions, please contact Ekaterina Lenning via phone at 301-415-3151 or via email at Ekaterina.Lenning@nrc.gov.

Sincerely,

/RA/

Dennis C. Morey, Chief Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 99902038

Enclosure:

Audit Plan

Enclosure REGULATORY AUDIT PLAN FOR THE WESTINGHOUSE ELECTRIC COMPANY TOPICAL REPORT WCAP-18446-P/WCAP-18446-NP, REVISION 0, INCREMENTAL EXTENSION OF BURNUP LIMIT FOR WESTINGHOUSE AND COMBUSTION ENGINEERING FUEL DESIGNS (EPID L-2020-TOP-0064)

DOCKET NO. 99902038

1.0 BACKGROUND

By letter dated December 14, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20350B834), Westinghouse Electric Company (Westinghouse) submitted Topical Report (TR) WCAP-18446-P, Revision 0, Incremental Extension of Burnup Limit for Westinghouse and Combustion Engineering Fuel Designs (ADAMS Package No. ML20351A157), to the U.S. Nuclear Regulatory Commission (NRC) for review and approval for licensing applications. WCAP-18446-P, Revision 0, presents a rationale and an application methodology for existing Westinghouse codes for analyses of pressurized water reactor (PWR) non-LOCA events identified in Chapter 15 of NUREG-0800, Standard Review Plan, loss-of-coolant (LOCA) events, and nuclear design to burnups beyond the currently licensed limit of 62 GWd/MTU. The Westinghouse extended burnup (EBU) TR does not discuss increasing fuel enrichment beyond the currently licensed limit of 5 wt%, and therefore the burnup range requested by Westinghouse is limited to an incremental extension.

In January 2021, the NRC staff began an acceptance review of the TR and concluded additional information was necessary before a formal review effort could begin. In a meeting with Westinghouse on February 11, 2021 (ADAMS Package No. ML21042B315), the NRC discussed its acceptance review findings. Westinghouse indicated the necessary additional information identified by the NRC was available and could be readily compiled into a supplement. The NRC subsequently accepted the TR for review (ADAMS Accession No. ML21053A412).

Because the initial submittal of the Westinghouse EBU TR required additional information for the NRC staff to begin its review, the staff has proposed to conduct a regulatory audit in an effort to increase efficiency, facilitate discussion, and clarify issues identified during the staffs initial review. An audit plan has been developed and is enclosed. The NRC staff will conduct this virtual audit under the guidance provided in LIC-500, Revision 8, Topical Report Process, and LIC-111, Regulatory Audits.

2.0 REGULATORY AUDIT BASES Regulatory guidance for the review of fuel system materials and designs and adherence to Title 10 of the Code of Federal Regulations, Appendix A to Part 50, General Design Criteria (GDC)-10, Reactor Design, GDC-27, Combined Reactivity Control Systems Capability, and GDC-35, Emergency Core Cooling, is provided in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (SRP), Section 4.2, Fuel System Design. In accordance with the SRP Section 4.2, the objectives of the fuel system safety review are to provide reasonable assurance that: (1) the fuel system is not damaged as a result of normal operation and anticipated operational occurrences (AOOs), (2) fuel system damage is never so severe as to prevent control rod insertion when it is required, (3) the number of fuel rod failures is not underestimated for postulated accidents, and (4) coolability is always maintained. Regulatory guidance for the review of transient and accident analysis methods is provided in the SRP Section 15.0.2, Review of Transient and Accident Analysis Method.

3.0 REGULATORY AUDIT SCOPE The NRC staff will conduct a two-day audit online. This audit is expected to include one day for discussion between the NRC staff and Westinghouse regarding the content of a planned supplement to the EBU TR, which will contain the necessary additional information identified during the acceptance review, and one day for discussion regarding questions identified during the TR review thus far. Details regarding the discussions and open items are provided below.

4.0 INFORMATION NEEDS The NRC staff requests Westinghouse make available appropriate engineer(s) with knowledge of the EBU TR to address questions by the NRC staff.

Documents referenced in the TR and other key supporting documents should also be made available.

5.0 TEAM ASSIGNMENTS Paul Clifford, Senior Technical Advisor (NRR/DSS)

Kevin Heller, Technical Reviewer (NRR/DSS/SFNB)

John Lehning, Technical Reviewer (NRR/DSS/SFNB)

Ekaterina Lenning, Project Manager (NRR/DORL/LLPB) 6.0 LOGISTICS Audit Dates: Thursday, April 8, 2021 - Friday, April 9, 2021 Time will be allocated for specific topics during each day of the audit as presented below:

Table: Audit Agenda Thursday Friday AM Discussion of content of topical report supplement Discussion of additional concerns identified during the review PM Discussion of content of topical report supplement Revisit topics as needed/TBD 7.0 DELIVERABLES A regulatory audit summary will be provided within 90 days of the completion of the audit.

ML21083A114 (Package)

ML21083A121(Letter with Enclosure)

ML21082A009 (Meeting notice)

OFFICE NRR/DORL/LLPB/PM*

NRR/DORL/LLPB/LA NRR/DSS/SFNB/BC NRR/DORL/LLPB/BC NAME ELenning DHarrison RLukes DMorey DATE 03/24/2021 3/30/2021 3/30/2021 3/30/2021