ML25101A297

Westinghouse Electric Company Llc. - Audit Plan for Topical Report Advanced Logic System V2

ML25101A297
Person / Time
Site:	99902079
Issue date:	05/28/2025
From:	Vechioli-Feliciano L NRC/NRR/DANU/UAL2
To:	Westinghouse
Vechioli-Feliciano L
Shared Package
ML25101A303	List: ML25101A297 ML25101A298
References
EPID L-2023-TOP-0056
Download: ML25101A297 (1)

Text

WESTINGHOUSE ELECTRIC COMPANY, LLC. - AUDIT PLAN FOR THE TOPICAL REPORT PERTAINING TO THE ADVANCED LOGIC SYSTEM V2 PLATFORM ELIMINATION OF TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS (EPID: L-2023-TOP-0056)

APPLICANT INFORMATION Applicant:

Westinghouse Electric Company, LLC.

Applicant Address:

1000 Westinghouse Drive Cranberry Township, PA 16066 Project No.:

99902079

Background:

By letter EVR_LTR_230330 dated December 20, 2023, (Agencywide Documents Access and Management System Accession No. ML23354A139) Westinghouse Electric Company, LLC.,

(Westinghouse) submitted Revision 0 of the topical report (TR), Advanced Logic System (ALS) v2 Platform Elimination of Technical Specifications Surveillance Requirements. This TR provides a methodology to eliminate certain Technical Specification Surveillance Requirements from the ALS v2 platform.

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the TR and determined that a regulatory audit would assist in the completion of the review. The NRC staff will conduct a regulatory audit to support its review in accordance with this audit plan. A regulatory audit is a planned activity that includes the examination and evaluation of primarily non-docketed information.

Purpose:

The purpose of the audit is for the NRC staff to gain an understanding and to verify, via an independent evaluation, that the ALS v2 Platform conforms to applicable regulations, standards, guidelines, plans, and procedures by assessing Westinghouses approach of eliminating technical specifications for surveillance requirements (SR). Performing a regulatory audit is necessary to assist the NRC staff in efficiently conducting its review and gaining insight into Westinghouses design information.

The NRC staff will also review Westinghouses supporting documents to determine if additional information will require docketing to develop and support conclusions for the NRC staffs safety evaluation of the TR.

The NRC staff plan to conduct the audit virtually via Westinghouses established electronic reading room (eRR). However, should the NRC staff determine that an in-person audit would be a more efficient method to conduct the audit and gather needed information, the NRC staff may use that approach in addition to the virtual audit.

This audit will be conducted in accordance with the guidance provided in the Office Instruction LIC 111, Regulatory Audits, (ML19226A274).

May 28, 2025 Regulatory Audit Basis:

This regulatory audit is conducted in accordance with the following:

1.

Regulation 10 CFR 50.36(c)(3) for SRs states, in part, that SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

2.

General Design Criterion (GDC) 21, Protection System Reliability and Testability, requires, in part, that the protection system be designed to permit its periodic testing during reactor operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.

3.

GDC 22, Protection system independence, requires in part, that the protection system shall be designed to assure that the effects of natural phenomena, and of normal operating, maintenance, testing, and postulated accident conditions on redundant channels do not result in a loss of the protection function.

4.

Institute of Electrical and Electronics Engineers (IEEE) Standard 603-1991, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations, Clause 5.7, states that the safety system shall have the capability for test and calibration while retaining the capability to accomplish its safety functions. It further states that this capability shall be provided during a power operation, and shall duplicate, as closely as practicable, the performance of the safety function. Exceptions to the testing and calibration during power operation are allowed where this capability cannot be provided without adversely affecting the safety or operability of the generating station. However, appropriate justification must be provided, acceptable reliability of the equipment operation must be demonstrated, and the capability shall be provided while the generating station is shut down.

5.

Title 10 of the Code Federal Regulations (10 CFR) Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, Appendix D, Design Certification Rule for the AP1000 Design,Section VIII.C.6 states that after issuance of a license, Changes to the plant-specific TS will be treated as license amendments under 10 CFR 50.90.

Information and Other Material Necessary for the Regulatory Audit:

The primary topics of discussion that the NRC staff will use to determine what potential information gaps may exist, and to identify the information to be audited, will be shared as preliminary questions. The preliminary questions will be shared with Westinghouse via the NRCs eRR in advance of each audit meeting that will be scheduled.

Audit meetings will be scheduled as needed after the entrance meeting.

As previously noted, any information necessary to support the NRC staffs findings and conclusions will be requested to be submitted on the docket.

Team Assignments & Logistics:

The audit team will consist of the following NRC staff from the Office of Nuclear Reactor Regulation. Additional audit team members may be added by the PM, as needed.

NAME DIVISION BRANCH Lucieann Vechioli Feliciano Patrick Boyle Division of Advanced Reactors and Non-Power Production and Utilization Facilities Advanced Reactor Licensing Branch 2 William Roggenbrodt Division of Engineering and External Hazards Instrumentation and Controls Branch Tarico Sweat Division of Safety Systems Technical Specifications Branch Date: March 3, 2025 - April 11, 2025 (may be extended if mutually agreed upon).

Audit meetings will be scheduled as needed after the entrance meeting.

The NRC staff will discuss the purpose of the audit requests and information needs. The NRC staff will confirm with Westinghouse the sensitivity of any information discussed or presented on the eRR.

Audit meetings will take place in a virtual format, using Microsoft Teams or another similar platform. However, should the need arise, the audit may also be conducted in-person at a site chosen and agreed upon by both Westinghouse representatives and the NRC staff. The NRC staff requests that Westinghouse have the information readily available and accessible for the NRC staffs review via the eRR. During predetermined periods where the NRC staff needs to confer with technical experts representing Westinghouse, the NRC staff requests Westinghouse to have its staff available at mutually agreeable business daytimes (e.g.,

Monday - Friday, 9:00 a.m. to 4:00 p.m., EST) via Microsoft Teams, if the NRC staff has any questions during the audit related to any information on the eRR.

When the NRC staff determines that any information on the eRR is relevant to the safety determination, the NRC staff will request Westinghouse to make the draft information available in the eRR for discussion with the NRC staff before the information is formally placed on the docket.

Additionally, the NRCs licensing project manager will inform Westinghouse via routine communications, when the NRC staff no longer need access to the eRR.

Deliverables:

The NRC staff will develop any requests for additional information or requests for confirmatory information, as needed, which will be provided to Westinghouse via separate docketed correspondence. At the completion of the audit, the audit team will issue an audit report. The audit report will be issued within 90 days following the exit meeting but will strive for a shorter duration. The audit report will be declared and entered as an official record in ADAMS.

References:

LIC-111, Revision 2, Regulatory Audits, issued December 19, 2024, (ML24309A281).

WCAP-18810-P/NP, Westinghouse, Submittal of the Advanced Logic System (ALS) v2 Platform Elimination of Technical Specification Surveillance Requirements Topical Report, (ML23354A138).

If you have any questions regarding this audit, please contact me at (301) 415-6035 or via email at Lucieann.VechioliFeliciano@nrc.gov.

Date: MAY 28, 2025 Sincerely, Lucieann Vechioli Feliciano, Project Manager Advanced Reactors Licensing Branch 2 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No.: 99902079

Enclosure:

As stated cc: Westinghouse eVinci via GovDelivery Signed by Vechioli, Lucieann on 05/28/25

Package: ML25101A303 Letter: ML25101A297 Email: ML25101A298

Enclosure:

ML25101A299 NRR-106 OFFICE NRR/DANU/UAL2:PM NRR/DANU/UAL2:LA NRR/DEX/Tech BC: BC NAME LVechioli CSmith FSacko DATE 4/21/2025 04/23/2025 4/29//2025 OFFICE NRR/DANU/UAL2: BC NRR/DANU/UAL2:PM NAME JSegala LVechioli DATE 5/28/2025 5/28/2025