ML19246A028
| ML19246A028 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 09/19/2019 |
| From: | Dennis Morey Division of Licensing Projects |
| To: | Zozula C Westinghouse |
| Lenning E, 415-3151 | |
| Shared Package | |
| ML19246A008 | List: |
| References | |
| EPID L-2019-TOP-0014 | |
| Download: ML19246A028 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 19, 2019 Ms. Camille Zozula, Manager Infrastructure & Facilities Licensing Westinghouse Electric Company 1000 Westinghouse Drive Building 1, Suite 165 Cranberry Township PA 16066
SUBJECT:
FINAL SAFETY EVALUATION FOR WESTINGHOUSE ELECTRIC COMPANY LTR-NRC-19-15, "NOTIFICATION OF CHANGES TO WESTINGHOUSE QMS" (EPID: L-2019-TOP-0014)
Dear Ms. Zozula:
By letter dated April 8, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19098A193), Westinghouse Electric Company (Westinghouse) submitted to the U.S. Nuclear Regulatory Commission (NRC) letter LTR-NRC-19-15, Notification of Changes to Westinghouse QMS [quality management system]. While Westinghouse did not seek NRC review and approval of the changes at the time of submittal, the NRC interprets Title 10 of the Code of Federal Regulations (10 CFR) 50.4 as requiring NRC review and approval of all submittals. Westinghouse, as a non-licensee/nuclear steam supply system (NSSS) supplier, stated changes were submitted in accordance with 10 CFR 50.4(b)(7)(ii). Westinghouses justification for the proposed changes referenced the regulatory requirements of 10 CFR 50.54(a)(3). However, the regulatory requirements of 10 CFR 50.4(b)(7)(ii) require NSSS suppliers to submit quality assurance (QA) program changes prior to implementation. The regulatory methodology in 10 CFR 50.54 is only applicable to licensees making a QA program description (QAPD) change if there is no reduction in commitment to a previously accepted QAPD or topical report (TR).
The NRC staff reviewed the letter and requested a teleconference with Westinghouse to discuss this letter. As discussed on the call held between the NRC staff and Westinghouse on May 14, 2019, the NRC staff believes an innovative approach (that will be documented in the NRC staffs safety evaluation) can be used within the bounds of 10 CFR 50.4 which would allow similar flexibility to a licensees flexibility to make changes to a previously accepted QAPD, provided the change does not reduce the commitments. In the email dated May 18, 2019, Westinghouse confirmed the acceptability of NRC approach (without this revised approach documented in an NRC SE, the NRC staff would need to provide SE for each change that Westinghouse submits).
By letter dated June 13, 2019 (ADAMS Accession No. ML19154A062), the NRC issued the acceptance letter of the LTR-NRC-19-15, Notification of Changes to Westinghouse QMS, to be reviewed as TR on a generic basis. By letter dated July 30, 2019 (ADAMS Accession No. ML19190A025), the NRC issued the draft safety evaluation for LTR-NRC-19-15, Notification of Changes to Westinghouse QMS.
The enclosed final SE addresses the applicability of the LTR-NRC-19-15, Notification of Changes to Westinghouse QMS.
C. Zozula The NRC staff has found that LTR-NRC-19-15, Notification of Changes to Westinghouse QMS, is acceptable for referencing in licensing applications provided that the conclusions and applicability defined in the enclosed NRC final SE are met.
Our acceptance applies only to material provided in the subject TR. In accordance with the guidance provided on the NRC website, we request that Westinghouse publish the accepted version of this TR within three months of receipt of this letter. The accepted version shall incorporate this letter and the enclosed final SE after the title page. Also, they must contain historical review information, including NRC requests for additional information (RAIs) and your responses. The accepted version shall include an "-A" (designating accepted) following the TR identification symbol.
As an alternative to including the RAIs and RAI responses behind the title page, if changes to the TR were provided to the NRC staff to support the resolution of RAI responses, and the NRC staff reviewed and approved those changes as described in the RAI responses, there are two ways that the accepted version can capture the RAIs:
- 2. The RAIs and RAI responses can be captured in the form of a table (inserted after the final SE) which summarizes the changes as shown in the approved version of the TRs. The table should reference the specific RAIs and RAI responses which resulted in any changes, as shown in the accepted version of the TRs.
If future changes to the NRCs regulatory requirements affect the acceptability of this TR, Westinghouse will be expected to revise the TR appropriately or justify its continued applicability for subsequent referencing. Licensees referencing this TR would be expected to justify its continued applicability or evaluate their plant using the revised TR.
Sincerely,
/RA/
Dennis C. Morey, Chief Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 99902038
Enclosures:
As stated
ML19246A008 (Package)
ML19246A028 (Letter)
ML19246A022 (SE Encl.)
ML19246A024 (Comment Resolution Att.) *concurrence via e-mail NRR-106 OFFICE NRR/DLP/PLPB NRR/DLP/PLPB/LA* NRR/ DIRS/IQVB/BC NRR/DLP/PLPB/BC NAME ELenning DHarrison KKavanagh DMorey DATE 09/03/19 09/16/19 09/17/19 09/19/2019