ML21309A105

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November 8, 2021 Audit Plan for Framatome Topical Report ANP-10339P, Revision 0, Arita - Artemis/Relap Integrated Transient Analysis Methodology
ML21309A105
Person / Time
Site: 99902041
Issue date: 11/08/2021
From: Dennis Morey
Licensing Processes Branch
To: Peters G
Framatome ANP
Otto N, NRR/DORL/LLPB, 415-6695
References
ANP-10339P, Rev. 0, EPID L-2018-TOP-0034
Download: ML21309A105 (6)


Text

November 16, 2021 Mr. Gary Peters, Director Licensing and Regulatory Affairs Framatome Inc.

3315 Old Forest Road Lynchburg, VA 24501

SUBJECT:

NOVEMBER 8, 2021, REGULATORY AUDIT PLAN FOR FRAMATOME INC.

TOPICAL REPORT, ANP-10339P, REVISION 0, ARITA - ARTEMIS/RELAP INTEGRATED TRANSIENT ANALYSIS METHODOLOGY (EPID L-2018-TOP-0034)

Dear Mr. Peters:

By letter dated August 28, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18242A443), Framatome, Inc. (Framatome) submitted Topical Report (TR) ANP-10339P, Revision 0, ARITA - ARTEMIS/RELAP Integrated Transient Analysis Methodology (ADAMS Package No. ML18242A480), to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. ANP-10339P, Revision 0 (ARITA) presents a coupled code system and evaluation models for the analysis of pressurized water reactor non-loss-of-coolant accident events identified in NUREG-0800, Chapter 15, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition -

Transient and Accident Analysis.

The NRC staff technical review of this TR is ongoing. The NRC staff will perform a virtual regulatory audit on November 3, 2021. The NRC staff determined that this regulatory audit is needed to facilitate the review. Previous audits were held on December 7-11, 2020 (ADAMS Package Accession No. ML21026A007), March 3-4 and 25-26, 2021 (ADAMS Package Accession No. ML21055A702), April 22, 2021 (ADAMS Package Accession No. ML21110A149), June 15, 2021 (ADAMS Accession No. ML21159A143), July 9, 2021 (ADAMS Accession No. ML21187A126), and August 11-12, 2021 (ADAMS Accession No. ML21204A101). Enclosed for your information is a copy of the audit plan the NRC staff will follow.

Please contact Ngola Otto at 301-415-6695 or via e-mail at Ngola.Otto@nrc.gov with any questions you may have regarding this letter.

Sincerely,

/RA/

Dennis C. Morey, Chief Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 99902041

Enclosure:

Audit Plan (Non-Proprietary)

Enclosure REGULATORY AUDIT PLAN FOR FRAMATOME TOPICAL REPORT ANP-10339P, REVISION 0, ARITA - ARTEMIS/RELAP INTEGRATED TRANSIENT ANALYSIS METHODOLOGY PROJECT NO. 728 EPID L-2018-TOP-0034

1.0 BACKGROUND

By letter dated August 28, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18242A443), Framatome, Inc. (Framatome) submitted Topical Report (TR) ANP-10339P, Revision 0, ARITA - ARTEMIS/RELAP Integrated Transient Analysis Methodology (ADAMS Package No. ML18242A480) to the U.S. Nuclear Regulatory Commission (NRC) for review and approval for licensing applications. ANP-10339P, Revision 0 (ARITA) presents a coupled code system and evaluation models for the analysis of pressurized water reactor non-loss-of-coolant accident (non-LOCA) events identified in Chapter 15 of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (SRP). In December 2018, the NRC staff completed an acceptance review of the TR and found additional information was necessary (ADAMS Accession No. ML18345A159) before a formal review effort could begin. The necessary supplemental information was submitted by Framatome in March 2019 (ADAMS Accession No. ML19078A253). The NRC staffs review also relies upon information submitted by Framatome in March 2020, July 2020, November 2020, and June 2021 (ADAMS Accession Nos. ML20097E381, ML20237F458, ML20335A218, and ML21162A080, respectively) in response to request for additional information (RAI) questions from the NRC staff.

The NRC staff has identified that many of Framatomes RAI responses do not fully address the staffs concerns. Therefore, the NRC staff conducted regulatory audits in December 2020 (ADAMS Package Accession No. ML21026A007), March 2021 (ADAMS Package Accession No. ML21055A702), April 22, 2021 (ADAMS Package Accession No. ML21110A149), June 15, 2021 (ADAMS Accession No. ML21159A143), and July 9, 2021 (ADAMS Accession No. ML21187A126), and August 11-12, 2021 (ADAMS Accession No. ML21204A101) to increase efficiency in the review, facilitate discussion, and close the open items. At the close of each of these audits, both the NRC staff and Framatome staff concluded that additional regulatory audits of this nature would further enhance the efficiency of the review.

The NRC staff will conduct this virtual audit under the guidance provided in LIC-500 (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, Section 4.2, Fuel System Design. In accordance with 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, (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.

3.0 REGULATORY AUDIT SCOPE The NRC staff will conduct a one-day audit online. This audit is expected to include discussion between the NRC staff and Framatome staff regarding areas of technical disagreement identified, and open items from the RAI responses. Details regarding the discussions and open items are provided below.

4.0 INFORMATION NEEDS The NRC staff requests that Framatome make available appropriate engineer(s) with knowledge of ARITA and any appropriate references, to address questions by the NRC staff.

Documents referenced in the TR should also be made available.

Discussion Topics This audit will focus on the following RAI responses, which were submitted June 2, 2021 (ADAMS Package Accession No. ML21162A080):

RAIs - 33, 35, 39, 40, 41, 42, 43, 44, 45, 46, 48, 49, 61, 68, 69, 70, 74, 75, 77, 78, 81, 82, 88, 89, 90, and 91 5.0 TEAM ASSIGNMENTS Kevin Heller, Technical Reviewer (NRR/DSS/SFNB)

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

Joshua Kaizer, Technical Reviewer (NRR/DSS/SFNB)

Ngola Otto, Project Manager (NRR/DORL/LLPB)

Ken Geelhood, Pacific Northwest National Laboratory (PNNL)

Bruce Schmitt, PNNL Dave Engel, PNNL David Richmond, PNNL 6.0 LOGISTICS Audit Date: Wednesday, November 8, 2021.

The audit is scheduled to begin at 9:00 a.m. Eastern Standard Time. Time will be allocated for specific topics during the day of the audit as presented below:

Audit Agenda Wednesday AM Major Discussion Topics PM Major Discussion Topics

/ Next Steps The audit will be performed using the WebEx online platform and log-in information provided by Framatome.

7.0 DELIVERABLES A regulatory audit summary will be provided within 90 days of the completion of the audit.

ML21309A105 (Audit Plan)

OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DSS/SFNB/BC NRR/DORL/LLPB/BC NAME NOtto DHarrison RLukes DMorey DATE 11/5/2021 11/15/2021 11/16 /2021 11/16 /2021