ML25071A003
| ML25071A003 | |
| Person / Time | |
|---|---|
| Site: | 99902041 |
| Issue date: | 03/17/2025 |
| From: | Ngola Otto Licensing Processes Branch |
| To: | Elliott G Framatome |
| Shared Package | |
| ML25071A001 | List: |
| References | |
| EPID L-2044-TOP-0033 | |
| Download: ML25071A003 (1) | |
Text
REGULATORY AUDIT PLAN FOR FRAMATOME TOPICAL REPORT ANP-10358P REVISION 0, INCREASED BURNUP FOR PWRS DOCKET NO. 99902041 EPID: 2024-TOP-0033
1.0 BACKGROUND
By application dated November 26, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24331A085), Framatome Inc. (Framatome), submitted Topical Report (TR) ANP-10358P, Revision 0, Increased Burnup for PWRs [Pressurized Water Reactors], for U.S. Nuclear Regulatory Commission (NRC) review and approval.
The NRC staff has performed an initial review of ANP-10358P, Revision 0 (hereafter referred to as the TR) and determined that a regulatory audit would facilitate its review. Additional audits regarding other topics not covered in this audit plan may be necessary as the NRC staffs review progresses to other areas of the TR.
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-11, Reactor Inherent Protection, and GDC-13, Instrumentation and Control, is provided in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (SRP), Section 4.3, Nuclear Design. In accordance with SRP Section 4.3, the objectives of the nuclear designs safety review is to provide reasonable assurance that: (1) acceptable fuel designs limits are not exceeded, (2) limiting power distributions are not exceeded, and (3) analytical methods should be representative of the state of the art, and the experiments used to validate the analytical methods should be adequate representations of fuel designs in the reactor and encompass a sufficient range of variables and operating conditions.
3.0 REGULATORY AUDIT SCOPE The purpose of this audit is to gain a more detailed understanding of the information supporting Framatomes proposed TR methodology. An audit was determined to be the most efficient approach toward a timely resolution of questions associated with this review. The audit will provide efficiencies for the NRC staff by providing an opportunity for effective in-person discussions on the TR methodology and for clarifications on unresolved questions. Upon completion of this audit, the NRC staff is expected to achieve the following:
- 1.
Confirm internal Framatome information that supports statements made in the TR.
- 2.
Determine whether the information included in the audited documents is necessary to be submitted to support a safety conclusion.
The audit will focus primarily on the TR, the enclosed audit information needs, and all relevant supporting documentation (e.g., methodology, process information, calculations, etc.) identified
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION below. The audit will be performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Revision 2, Regulatory Audits, (ADAMS Accession No. ML24309A281). Non-docketed information reviewed during the audit that the NRC staff deems necessary to support the development of its safety evaluation will be requested to be submitted on the docket.
4.0 INFORMATION REQUESTS To facilitate efficient face-to-face audit interactions, the NRC staff is requesting that Framatome provide access to requested audit documentation through an online reference portal before the face-to-face portion of the audit. Please make the following information for the NRC staff to audit via an online reference portal by March 24, 2025:
Reference 31: Tomani H., Carlsson M., and Malen K., "Final Report of the ROPE II Project," Studsvik-ROPE II-20, September 1995.
Reference 33: STUDSVIK/N-08/037, "PIE of high burnup M5 rodlet after experiment in the IFA-683 rig for AREVA NP," Carolina Losin, February 2008.
Reference 45: Brown, L.D., T. Tony Cai, and Anirban DasGupta. "Interval Estimation for a Binomial Proportion," Statist. Sci. 16(2), 101-133, May 2001.
Reference 46: Wissinger, G.J. Fuel Fragment Jamming Inside Fuel Rods Following a LOCA, NUTHOS-14, August 2024.
Reference 47: S.D. Campos, et.al., Identifying Important Parameters Affecting Fuel Dispersion and Relocation Phenomena Under Loss of Coolant Accident (LOCA)
Conditions, ANS Winter Meeting, November 2023. Transactions, Volume 129, Number 1, pages 112-115.
Reference 54: S.C. Franz, G.J. Wissinger, Flow Dynamics in a Fuel Bundle with a Particle Bed, ICONE31-136239, November 2024.
Reference 55: A. Bouloré, et al., Fission Gas Release and Fuel Fragmentation Modelling in LOCA Conditions in the Pleiades Platform, TopFuel 2024, Grenoble, France.
Reference 56: R. Largenton, et. al, LOCA Transient - Beneficial Effects of the Pressure and Temperature Evolution on Fine Fuel Fragmentation, TopFuel 2024, Grenoble, France.
In addition, to support the NRC staffs understanding of the TR and to help identify any additional information needed to support its review, the NRC staff requests that Framatome be prepared to discuss the audit topics identified in the attachment.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION 5.0 AUDIT TEAM Key Framatome personnel involved in the development of the TR should be made available for interactions on a mutually agreeable schedule to respond to any questions from the NRC staff.
Team Member Division Area of Responsibility Ngola Otto NRR/DORL/LLPB Project Management Ankur Bhattacharya NRR/DORL/LLPB Project Management Patrick Raynaud NRR/DSS/SFNB Technical Lead Joseph Messina NRR/DSS/SFNB Technical Reviewer Kevin Heller NRR/DSS/SFNB Technical Reviewer Richard Fu NRR/DSS/SFNB Technical Reviewer Jack Vande Polder NRR/DSS/SFNB Technical Reviewer 6.0 LOGISTICS The audit will involve both the review of documents on an electronic portal as well as an in-person face-to-face discussion. The online portion of the audit will be conducted from March 2025 to September 2025 through an online portal established by Framatome. The NRC staff and contractors access to the online portal should be terminated on September 30, 2025.
The NRC staff requests a three-day in-person audit to be conducted at Framatomes facilities in Lynchburg, VA, to support technical discussions associated with the review and supporting audit information. The audit should be conducted from March 25-27, 2025.
7.0 SPECIAL REQUESTS The NRC staff would like access to the documents listed above in Section 4.0 through an online portal that allows the NRC staff and contractors to access documents via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the NRC staff and contractors have access to the online portal.
The online portal will be password-protected, and separate passwords will be assigned to the NRC staff and contractors who are participating in the audit.
The online portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information on the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.
Username and password information should be provided directly to the NRC staff and contractors. The NRC project manager will provide the names and contact information of the NRC staff and contractors who will be participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES The NRC team will develop an audit summary report to convey the results. The report will be placed in ADAMS within 90 days of the completion of the final audit session.