ML24269A149
| ML24269A149 | |
| Person / Time | |
|---|---|
| Site: | 99902041 |
| Issue date: | 10/01/2024 |
| From: | Ngola Otto Licensing Processes Branch |
| To: | Elliott G Framatome |
| References | |
| EPID L-2024-TOP-0026, ANP-10356, Rev 0 | |
| Download: ML24269A149 (1) | |
Text
October 1, 2024 Gayle Elliott, Director Licensing and Regulatory Affairs Framatome Inc.
3315 Old Forest Road Lynchburg, VA 24501
SUBJECT:
FRAMATOME INC. - WITHDRAWAL OF REQUESTED REVIEW REGARDING TOPICAL REPORT ANP-10356, REVISION 0, LICENSING GUIDANCE FOR LEAD TEST ASSEMBLIES (EPID L-2024-TOP-0026)
Dear Gayle Elliott:
By letter dated July 2, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24185A036), Framatome Inc. (Framatome) submitted Topical Report (TR) ANP-10356, Revision 0, Licensing Guidance for Lead Test Assemblies, to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. In the July 2, 2024, letter, Framatome stated that the purpose of the TR is to provide guidance on the interpretation and implementation of the Technical Specification (TS) Lead Test Assembly (LTA) provision within the construct of the plants existing licensing bases. The NRC staff understood that the submittal sought to provide clarity on (1) the LTA provision in the standard technical specifications (STS),
(2) the application of Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests, and experiments, and (3) exemptions to 10 CFR 50.46, Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors.
By letter dated September 12, 2024 (ADAMS Accession No. ML24257A147), you requested to withdraw the TR and fee waiver request from NRC review. The NRC acknowledges your request to withdraw the TR. The NRC staff activities on the review have ceased and the associated Cost Activity Code number has been closed.
The NRC staff in its review prior to the withdrawal identified that your application did not provide the following technical information in sufficient detail to enable the NRC staff to complete its detailed review. Therefore, should you decide to re-submit the request, it must include the following information:
Technical justification to support the numbers proposed for limited numbers of LTAs for the various types of LTAs, especially with respect to combinations, thereof.
Information and justification on what constitute limiting fuel assemblies and LTAs, particularly with respect to the current interpretation that the non-limiting locations terminology of the STS LTA provision generally means the existing co-resident/reload fuel assemblies in the core are the most limiting.
Provide approaches to demonstrate when and how to perform thermal margin setback for LTAs. Adequate justification that foregoing thermal margin setback continues to ensure LTAs are non-limiting with respect to co-resident/reload fuel.
Technical justification for an open-ended higher burnup target limit or, conversely, justification for a defined fixed or scalable higher burnup target limit.
Language in the TR should address its inconsistencies with the requirements in 10 CFR 50.59(c)(1), which requires that a licensee must assess both TS and specific criteria in 10 CFR 50.59(c)(2) before proceeding without NRC approval. Also, meeting the TS LTA provision alone does not equate to a negative 10 CFR 50.59 evaluation and is not sufficient to avoid a license amendment.
If you have any questions, please contact me via email at Ngola.Otto@nrc.gov or by telephone at 301-415-6695.
Sincerely,
/RA/
Ngola Otto, Project Manager Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 99902041
SUBJECT:
FRAMATOME INC. - WITHDRAWAL OF REQUESTED REVIEW REGARDING TOPICAL REPORT, ANP-10356, REVISION 0, LICENSING GUIDANCE FOR LEAD TEST ASSEMBLIES (EPID L-2024-TOP-0026)
DATED OCTOBER 1, 2024 DISTRIBUTION:
PUBLIC RidsNrrOd Resource RidsNrrDssSfnb Resource RidsNrrDss ResourceRidsNrrLADHarrison RidsNrrDorl Resource RidsNrrDorlLlpb Resource RidsNrrDro Resource TClark, NRR VCusumano, NRR BPham, NRR ARivera-Varona, NRR JPelton, NRR PMcKenna, NRR GGeorge, NRR SKrepel, NRR KHeller, NRR DBeaulieu, NRR THipschman, NRR EXTERNAL DISTRIBUTION:
Gayle.Elliott@Framatome.gov Jerald.Holm.ext@Framatome.com ADAMS Accession No.: ML24269A149 NRR-004 OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DSS/SNFB/BC NRR/DSS/DD NAME NOtto DHarrison SKrepel VCusumano DATE 9/24/2024 9/25/2024 9/25/2024 9/25/2024 OFFICE NRR/DRO/DD NRR/DORL/LLPB/BC NRR/DORL/DD NRR/DORL/LLPB/PM NAME PMcKenna GGeorge ARivera-Varona NOtto DATE 9/25/2024 10/01/2024 10/01/2024 10/01/2024