ML22290A127

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Regulatory Audit Plan for Electric Power Research Institute Report 3002018337, Use of Data Validation and Reconciliation Methods for Measurement Uncertainty Recaptutopical Report
ML22290A127
Person / Time
Site: Electric Power Research Institute
Issue date: 11/02/2022
From: Lois James
Licensing Processes Branch
To: Greene J
Electric Power Research Institute
James L, NRR/DORL/LLPB, 301-415-3306
References
3002018337, EPID L-2021-TOP-0006
Download: ML22290A127 (5)


Text

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November 2, 2022 Mr. Jeffrey D. Greene Program Manager Electric Power Research Institute 1300 West W.T. Harris Boulevard Charlotte, NC 28262

SUBJECT:

REGULATORY AUDIT PLAN FOR ELECTRIC POWER RESEARCH INSTITUTE REPORT 3002018337, "USE OF DATA VALIDATION AND RECONCILIATION METHODS FOR MEASUREMENT UNCERTAINTY RECAPTURE: TOPICAL REPORT" (EPID L-2021-TOP-0006)

Dear Mr. Greene:

By letter dated January 27, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21053A027), Electric Power Research Institute (EPRI) submitted Report 3002018337, "Use of Data Validation and Reconciliation Methods for Measurement Uncertainty Recapture: Topical Report [(TR)], to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. EPRI Report 3002018337 dated November 2020 presents a process for using a mathematical Data Validation and Reconciliation method for monitoring core thermal power and use of the methods for Measurement Uncertainty Recapture Uprates.

The NRC staff technical review of this TR, which is ongoing, has determined that a regulatory audit is needed to facilitate the review. The NRC staff will perform an extended regulatory audit beginning the week of October 24, 2022, and ending the week of November 7, 2022. The audit will consist of an onsite week, an in-office week, and a virtual week. The enclosure is a copy of the audit plan that the NRC staff will follow.

Please contact Lois M. James at 301-415-3306 or via e-mail at Lois.James@nrc.gov with any questions you may have regarding this letter.

Sincerely, Lois M. James, Senior Project Manager Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 99902021

Enclosure:

Audit Plan Lois M. James Digitally signed by Lois M. James Date: 2022.11.02 09:38:49 -04'00'

ML22290A127 OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DSS/SFNB/BC NRR/DORL/LLPB/BC(A)

NAME LJames DHarrison SKrepel NOtto DATE 10/17/2022 10/17/2022 10/17/2022 10/18/2022 OFFICE NRR/DORL/LLPB/PM NAME LJames DATE 11/02/2022

Enclosure REGULATORY AUDIT PLAN FOR ELECTRIC POWER RESEARCH INSTITUTE EPRI REPORT 3002018337, NOVEMBER 2020 "USE OF DATA VALIDATION AND RECONCILIATION METHODS FOR MEASUREMENT UNCERTAINTY RECAPTURE: TOPICAL REPORT" EPID L-2021-TOP-0006

1.0 BACKGROUND

By letter dated January 27, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21053A027), Electric Power Research Institute (EPRI) submitted EPRI Report 3002018337, "Use of Data Validation and Reconciliation Methods for Measurement Uncertainty Recapture: Topical Report [(TR)], to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. EPRI Report 3002018337 dated November 2020 presents a process for using a mathematical Data Validation and Reconciliation (DVR) method for monitoring core thermal power and use of the methods for Measurement Uncertainty Recapture Uprates. In March 2021, the NRC staff completed an acceptance review of the TR and found it acceptable for docketing (ADAMS Accession No. ML21048A004).

2.0 REGULATORY AUDIT BASES To establish a licensing basis, licensees must analyze transients and accidents in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) 50.34, 10 CFR 50.46, and where applicable, per NUREG-0737, Clarification of TMI [Three Mile Island]

Action Plan Requirements. These accidents and transients are described in the Standard Review Plan (SRP) (NUREG-0800). Section 15.0.2 of the SRP, Review of Transient and Accident Analysis Methods (ADAMS Accession No. ML070820123), provides guidance to NRC reviewers of transient and accident analysis methods and Regulatory Guide (RG) 1.203, Transient and Accident Analysis Methods (ADAMS Accession No. ML070820123), is intended to provide guidance for use in developing and assessing evaluation models for accident and transient analyses. RG 1.203 and SRP Section 15.0.2 cover the same subject material and are intended to be complementary, with Section 15.0.2 providing guidance to reviewers and the RG providing practices and principles for the benefit of method developers.

3.0 REGULATORY AUDIT SCOPE The NRC staff will conduct an extended audit between October 24, 2022, and November 10, 2022. This audit is expected to include discussion between the NRC staff and EPRI staff regarding the topical report.

4.0 INFORMATION NEEDS The NRC staff requests that EPRI make available the appropriate engineer(s) with knowledge of the DVR methods and any appropriate references, to address questions by the NRC staff. The NRC staff will focus on the responses to the requests for additional information, the staffs understanding of the DVR methodology (as described in the staffs derivations), and other issues identified in the most recent meeting.

Documents referenced in the TR should also be made available.

5.0 TEAM ASSIGNMENTS Joshua Kaizer, Technical Reviewer (NRR/DSS/SFNB)

David Rahn, Technical Reviewer (NRR/DSS/SFNB)

Lois M. James, Senior Project Manager (NRR/DORL/LLPB)

Resources Available, if needed Dusty Brooks Nathan Porter 6.0 LOGISTICS Audit Dates: Onsite - October 24-27, 2022 October 24 - Audit will begin 2:00 pm local time in Montrose, CO October 25 - All day discussions October 26 - All day discussions October 27 - All day discussions with onsite exit at 5pm In-office - October 31, 2022 Virtual - November 5, 2022 Breakout schedule - to be determined Entrance:

Monday, October 24, 2022, 2:00 pm Exit:

Thursday, November 10, 2022, 3:00 pm The NRC staff will work with EPRI to establish times for breakout sessions based on NRC staff and EPRI staff availabilities.

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