ML26022A023
| ML26022A023 | |
| Person / Time | |
|---|---|
| Site: | 99902041 |
| Issue date: | 02/09/2026 |
| From: | Ngola Otto Licensing Processes Branch |
| To: | Elliott G Framatome |
| Shared Package | |
| ML26022A025 | List: |
| References | |
| EPID L-2025-TOP-0023, ANP-10300, Rev 1 | |
| Download: ML26022A023 (0) | |
Text
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION FEBRUARY 24 - 26, 2026, REGULATORY AUDIT PLAN FOR FRAMATOME TOPICAL REPORT ANP-10300, REVISION 1, SUPPLEMENT 1P, REVISION 0 AURORA-B ADDRESSING L&CS 11, 12, AND 18 DOCKET NO. 99902041 EPID: L-2025-TOP-0023
1.0 BACKGROUND
By letter dated June 16, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25167A304), Framatome Inc. (Framatome), submitted Topical Report (TR) ANP-10300, Revision 1, Supplement 1P, Revision 0, AURORA-B Addressing L&Cs [Limitations and Conditions] 11, 12, and 18, for U. S. Nuclear Regulatory Commission (NRC) staffs review and approval.
The NRC staff has performed a review of ANP-10300, Revision 1, Supplement 1P, Revision 0 (hereafter referred to as the TR), and determined that a regulatory audit of the items in the Information Request and Audit Questions sections of this audit plan would facilitate the timely completion of our reviews. The NRC staff is continuing to review other aspects of the TR and may identify the need to audit additional subjects by separate correspondence or during audit discussions. The NRC staff conducted an initial audit on September 17 - 18, 2025 (ML25234A034).
2.0 REGULATORY AUDIT BASES Applicable regulations are found in the following sections of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities:
10 CFR Part 50, Appendix A, General Design Criteria 10, which require the reactor core, coolant, and protection systems are designed to provide sufficient margin to the specified acceptable fuel design limits during normal operation and including anticipated operational occurrences.
Additional review guidance is provided in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 4.2, Fuel System Design. The regulatory audit will be held in accordance with the NRC Office of Nuclear Reactor Regulation (NRR) procedures as described in LIC-111, Revision 2 Regulatory Audits (ML24309A281).
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The purpose of this audit is to gain a more detailed understanding of the information supporting Framatomes proposed TR methodology. The areas of focus for the regulatory audit are the information contained in the submitted TR, the enclosed audit information needs, and all associated and relevant supporting documentation (e.g., methodology, process information, calculations) identified below. The audit will be performed in accordance with Instruction LIC-111, Revision 2, guidance.
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION An audit was determined to be the most efficient approach toward a timely resolution of questions associated with this TR review. The audit will provide the NRC staff with an opportunity to facilitate efficient interactions and understanding of the TR methodologies. The audit will also provide an opportunity for the NRC staff to clarify potential review questions. As appropriate, 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.
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 information the NRC staff determines to be necessary to support the development of its safety evaluation (SE) will be requested to be submitted on the docket.
4.0 INFORMATION REQUESTS Please make the following information for the NRC staff to audit via an online reference portal by January 26, 2026, in order to support an efficient face-to-face audit:
1.
Regarding L&C 11, the NRC staff would like to verify their understanding of the material presented in the TR during the audit. Therefore, the NRC staff request that Framatome make available subject matter experts knowledgeable on the approach proposed.
2.
Regarding L&C 11, the NRC staff request that Framatome make available, either via on-line portal or physical copies at the audit location, the following information:
a.
documentation outlining the proposed approach and demonstrating its application (e.g., summaries and calculation notes demonstrating application) b.
comparisons of the ((
)) and the data used to derive it 3.
Regarding L&C 18, the NRC staff would like to verify its understanding of the material presented in the TR. Therefore, the NRC staff request that Framatome make available subject matter experts knowledgeable on the approach proposed.
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 questions 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 Office/Division/Branch Role Participation Ngola Otto NRR/DORL/LLPB Project Management In-person Kevin Heller NRR/DSS/SFNB Technical Reviewer In-person Noushin Amini NRR/DSS/SFNB Technical Reviewer In-person John Lehning NRR/DSS/SFNB Technical Reviewer Remote 6.0 LOGISTICS The NRC staff requests a three-day in-person audit to be conducted at Framatomes facilities in Richland, Washington, to support technical discussions associated with the review and supporting audit information. The audit should be conducted from February 24 - 26, 2026.
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 January 26 to March 12, 2026, through an online portal established by Framatome. The NRC staffs access to the online portal should be terminated on March 12, 2026.
7.0 SPECIAL REQUESTS The NRC staff would like access to the documents requested above in Section 4.0 through an online portal that allows the NRC staff to access documents via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the NRC staff have access to the online portal:
The online portal will be password-protected, and separate passwords will be assigned to the NRC staff who are participating in the audit.
The online portal will be sufficiently secure to prevent the NRC staff 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. The NRC project manager will provide the names and contact information of the NRC staff 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. The audit
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION information the NRC staff determines to be necessary to support the development of the NRC staffs SE will be requested to be submitted on the docket.
9.0 AUDIT QUESTIONS Questions Regarding L&C 11
- 1. When developing the proposed approach, was ((
))?
- 2. What is the reasoning for ((
))?
Questions Regarding L&C 12
- 1. In Section 5, L&C 12 ((
)), of the TR, it is stated that ((
)). In Section 5.1, ((
)) Methodology, it is further indicated that
((
)).
Given the limited availability of experimental or plant data to adequately ((
)) presented in the TR, are there alternative analytical, empirical, or simplified modeling approaches that could be employed to estimate ((
))?
- 2. Please be prepared to discuss the ((
)) modeling approaches, supporting evidence, and conclusions in
((
)) particularly the information provided ((
)). These responses describe additional experimental results from ((
)). Points of interest include the following:
- a. ((
))
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION Questions Regarding L&C 18
- 1. Please verify the equation presented in Section 6.1.1, Conservative Measures, of the TR is correct; given the discussion around this equation, the NRC staff believes there may be a typo. From the text, the implication is that the ((
)).
- 2. The final paragraph in Section 6.2, Application of Conservative Measures in Follow-On Cycles, of the TR indicates ((
)). Within this context, what constitutes ((
))? It is unclear if this is a ((
)) or if a broader calculation is being performed.
- 3. With regard to the application of conservative measures in follow-on cycles (Section 6.2 of the TR): assuming the ((
)), what investigative analyses have been performed to assess the likelihood that, should a ((
)). By what magnitude would the ((
))?