ML24054A400
| ML24054A400 | |
| Person / Time | |
|---|---|
| Site: | 99902041 |
| Issue date: | 03/01/2024 |
| From: | Ngola Otto Licensing Processes Branch |
| To: | Joseph Donoghue, Bo Pham Division of Operating Reactor Licensing, NRC/NRR/DSS |
| References | |
| EPID L-2023-PPM-0003 | |
| Download: ML24054A400 (1) | |
Text
March 1, 2024 MEMORANDUM TO: Bo M. Pham, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Joseph E. Donoghue, Director Division of Safety Systems Office of Nuclear Reactor Regulation FROM:
Ngola A. Otto, Project Manager /RA/
Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION STAFFS RESPONSE TO FRAMATOME RECOMMENDATIONS FOR TOPICAL REPORT ANP-10339P, REVISION 0, ARITA - ARTEMIS/RELAP INTEGRATED TRANSIENT ANALYSIS METHODOLOGY LESSONS LEARNED (EPID L-2023-PPM-0003)
On December 14, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff held a meeting with representatives from Framatome Inc. (Framatome) to discuss the lessons learned pertaining to the ANP-10339P, Revision 0, ARITA - ARTEMIS/RELAP Integrated Transient Analysis Methodology (ARITA) topical report review. The meeting information can be found in ADAMS at Package Accession No. ML23353A207. Framatome later provided a list of lessons learned recommendations (ADAMS Accession No. ML24012A184), for the consideration of the NRC staff. The NRC staffs responses to Framatomes recommendations are provided in the enclosure.
Docket No. 99902041
Enclosure:
Responses to Framatome Lessons Learned Recommendations on the ARITA Topical Report Review
Enclosure U.S. NUCLEAR REGULATORY COMMISSION STAFFS RESPONSE TO FRAMATOME RECOMMENDATIONS FOR TOPICAL REPORT ANP-10339P, REVISION 0, ARITA - ARTEMIS/RELAP INTEGRATED TRANSIENT ANALYSIS METHODOLOGY LESSONS LEARNED (EPID L-2023-PPM-0003)
Requested Future Improvements - Revise LIC-109/LIC-500 to address the following:
Recommendation (1) - Use of a preliminary safety evaluation (SE) with open items prior to issuance of requests for additional information (RAIs) will aid in determining what information is needed to make a safety and regulatory finding on the report.
Response
o The NRC staff plans to adhere closely to the LIC-500, Rev. 9 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20247G279) process regarding preparing draft SE with holes per Section 2.4, Draft Safety Evaluation with Holes and Requests for Additional Information.
o No updates to the LIC-500 process is needed.
Recommendation (2) - Management oversight, early escalation, and the escalation process need to be defined within LIC-500.
Response
o The NRC staff plans to use regular public, status, and management meetings for discussion of issues to determine when escalation is necessary.
o The NRC staff recommends the establishment of schedules for resolving technical issues with agreement with all stakeholders. For complex reviews, Project Managers should consider documenting and entering these schedules in ADAMS or Reactor Program System for record keeping.
Recommendation (3) - Publish detailed meeting and audit summaries to assure agreements are addressed and retained.
Response
o The NRC normally publishes meeting summaries with meeting-related documents, discussion of next steps, and follow-up items. In addition, regulatory audits are conducted per LIC-111 (ADAMS Accession No. ML19226A274). Per LIC-111, audit content, activities, and information are communicated at the exit briefing. The NRC staff normally shares the audit summary report with applicant/licensee for identification of any factual errors, sensitive and/or proprietary information. No final licensing conclusions or findings are made in the audit summary report because licensing and regulatory decisions cannot be made solely based on an audit.
o No updates to the LIC-500 process are needed because the regulatory audit process is described in LIC-111.
Recommendation (4) - Ensure traditional audits are utilized where underlying calculations are reviewed and interactions with technical experts are performed to resolve concerns.
Response
o The NRC will consider additional audits as necessary to resolve technical concerns associated with calculations, data, or documentation to support regulatory findings.
o The NRC staff performed several traditional audits for the ARITA review where supporting calculations were reviewed in detail.
o The issue-resolution audits were integral to the staffs ability to make a safety finding on a number of challenging technical issues.
Recommendation (5) - Allow audit reports with RAI responses to be used in final -A version without the need for a formal RAI and RAI response.
Response
o The NRC staff will follow the LIC-500 and RAI process per LIC-115 (ADAMS Accession No. ML21141A238) for processing RAIs, because no final licensing conclusions or findings are made in the audit summary report.
Recommendation (6) - Provide instructions on revising acceptance review milestones in the event original milestones are exceeded.
Response
o The NRC staff will continue to follow the LIC-500 guidance regarding notification and communication with TR sponsor for significant changes (e.g., 25 percent or greater) in schedule and resource estimates. The NRC staff will track timeliness and adherence to RAI response schedules and will revise the associated schedule and resources with resolving RAIs.
o The NRC staff plans to use a formal letter to communicate schedule and resource changes for complex reviews.
Recommendation (7) - Provide the Technical Evaluation Report (TER) with the draft SE when subcontractors are used to assure transparency and completion.
Response
o The NRC staff considers the TER to be a consultant report, which is considered an input to the staffs SE. The NRC does not normally share internal input documents with external stakeholders.
Recommendation (8) - Reference topical report information in lieu of repeating in the final SE.
Response
o The NRC staff considers the length of the SE to be commensurate with the length and complexity of the ARITA TR and supporting RAI responses.
The ARITA TR and supporting RAI responses were ~1600 pages.
o The NRC staff intends to continue referencing or summarizing TR information in lieu of directly copying from the TR.
Recommendation (9) - Allow vendors to create non-proprietary version of final SE to reduce time and expense.
Response
o The NRC staff is responsible for generating the proprietary and non-proprietary versions of the final SE. The NRC staff will consider the request in the next revision to TR process (LIC-500).
Recommendation (10) - Develop an appeal process to address significant and unresolved disagreements between the NRC staff and Framatome technical staff positions as well as between NRC staff and contractor positions.
Response
o The NRC will continue to use its organizational values and regulatory requirements in decision-making for resolving technical issues.
Recommendation (11) - A written Issue Resolution Map with NRC tracking to adequate resolution should be kept and distributed to Framatome and NRC staff so that all are aware of the resolution status of each item.
Response
o For the ARITA TR review, the NRC staff utilized a detailed status list for the RAIs.
The status list was used for meeting and audit discussions and were updated after each meeting. The NRC staff plans to use similar tracking list for future reviews if deemed necessary.
o However, the resolution of issues in these documents does not constitute a final staff position, but a tentative staff position before the SE is issued.
Requested Future Improvements - Develop guidance on what constitutes reasonable assurance for use by NRC staff and share with industry.
Recommendation (12) - Develop guidance on what constitutes reasonable assurance for use by NRC staff and share with industry.
Response
o The NRC staff does not agree further guidance is necessary.
Reasonable assurance is a legal standard that predates the nuclear industry and is incorporated into the Atomic Energy Act of 1954.
The NRC office directors have issued guidance to perform reviews to a reasonable assurance standard.
Detailed technical guidance provided in existing documents (e.g., Standard Review Plan, Regulatory Guides) informs regulatory judgments.
- via email NRR-106 OFFICE NRR/DORL/LLPB/PM*
NRR/DORL/LLPB/LA*
NRR/DSS/SFNB/BC NRR/DORL/LLPB/BC*
NAME NOtto DHarrison SKrepel GGeorge DATE 2/26/2024 2/26/2024 2/26/2024 3/1/2024 OFFICE NRR/DORL/LLPB/PM*
NAME NOtto DATE 3/1/2024