ML24144A023
| ML24144A023 | |
| Person / Time | |
|---|---|
| Site: | 99902037 |
| Issue date: | 05/29/2024 |
| From: | Leslie Fields Licensing Processes Branch |
| To: | Olinski D Licensing Processes Branch |
| Shared Package | |
| ML24144A022 | List: |
| References | |
| EPID L-2024-LRM-0048 | |
| Download: ML24144A023 (1) | |
Text
May 29, 2024 Mr. Dewey Olinski Executive Director, PWR Owners Group, Program Management Office Westinghouse Electric Company 1000 Westinghouse Drive, Suite 172 Cranberry Township, PA 16066
SUBJECT:
REGULATORY AUDIT PLAN TO PROVIDE FEEDBACK FROM THE MAY 2, 2024, PRE-APLICATION MEETING PERTAINING TO A CONCEPTUAL TOPICAL REPORT REGARDING ON-LINE MONITORING PROGRAM FOR TECHNICAL SPECIFICATION INSTRUMENTATION (EPID L-2024-LRM-0048)
Dear Dewey Olinski:
On May 2, 2024, the U.S. Nuclear Regulatory Commission (NRC) held a closed preapplication meeting (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24093A282) with the Pressurized Water Reactor Owners Group (PWROG) regarding a proposed topical report (TR) to include an on-line monitoring program for Technical Specification instrumentation. Based on the meeting discussion, the NRC plans to conduct a half-day virtual audit to share and discuss NRC feedback on the key considerations.
The proposed conceptual TR will contain the justification for the monitoring of the Technical Specification instrumentation to determine if a channel calibration must be performed. To provide additional clarification and NRC feedback, the details of the NRC regulatory audit plan are provided in the enclosure to this letter.
If you have any questions, please contact me at 301-415-1186 or via e-mail at Leslie.Fields@nrc.gov.
Sincerely,
/RA/
Leslie Fields, Senior Project Manager Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 99902037
Enclosure:
Regulatory Audit Plan
Enclosure REGULATORY AUDIT PLAN TO PROVIDE FEEDBACK FROM THE MAY 2, 2024, PRE-APLICATION MEETING PERTAINING TO A CONCEPTUAL TOPICAL REPORT REGARDING AN ON-LINE MONITORING PROGRAM FOR TECHNICAL SPECIFICATION INSTRUMENTATION (EPID L-2024-LRM-0048)
1.0 BACKGROUND
The U.S. Nuclear Regulatory Commission (NRC) staff is currently engaged in preapplication discussions with the Pressurized Water Reactor Owners Group (PWROG) regarding a conceptual topical report (TR) which could include adoption of on-line monitoring (OLM) software with machine learning for Technical Specification (TS) instrumentation. On May 2, 2024, the U.S. Nuclear Regulatory Commission (NRC) held a closed preapplication meeting (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24093A282) with the Pressurized Water Reactor Owners Group (PWROG) to discuss the proposed TR.
The NRC staff plans to conduct a regulatory audit on June 3, 2024, to enhance the technical understanding of the proposed TR and the OLM program. This audit will allow the NRC staff to provide feedback on the proposed NRC regulatory structure for the conceptual TR, and specifically, what are the NRCs expectations for this type of submittal. The proposed audit will be held in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Regulatory Audits, dated October 31, 2019 (ADAMS Accession No. ML19226A274).
2.0 REGULATORY AUDIT BASES The following regulations could be applicable to the conceptual TR:
Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36 (10 CFR 50.36),
Technical Specifications, requires that TS include items in the following categories:
(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notification; and (8) written reports.
10 CFR 50.59, Changes, test, and experiments is an NRC-approved process to determine if an activity must be preapproved by the NRC.
Surveillance Frequency Program (SFCP) is an NRC-approved process to evaluate the activity of changing a SF. The SFCP would meet the 10 CFR 50.59(c)(4) "more specific criteria" guidance for the SR frequency change activity and would not require further 50.59 evaluation.
10 CFR 73.54, Protection of digital computer and communication systems and networks, are the cybersecurity requirements for commercial nuclear power reactors.
The requirements establish a comprehensive cybersecurity program for the protection of
digital computer and communications systems and equipment against cyberattacks that would adversely affect operational safety, security, or emergency preparedness.
3.0 REGULATORY AUDIT SCOPE The NRC staff would like the PWROG to make available the appropriate personnel with detailed knowledge of the proposed conceptual TR, supporting methodology, and supporting documents to be used in the development of the TR.
Based on the May 2, 2024, preapplication meeting discussions, the NRC staff will focus on NRC staff feedback provided in response to OLM preapplication topics. In Section 3.1 of this audit plan, the planned areas of focus for detailed discussion and document review are provided.
Specific details on the all the items needed in the TR submittal process should be identified and communicated during the audit.
3.1 List of Items for Audit Discussion Box.com portal uploaded with the following list of discussion items: (1) NRC feedback via email communication (2) Executive Summary of the conceptual TR for the PWROG OLM program, (3) Attachment 2, Key Considerations for an On-Line Monitoring Program for Technical Specification Instrumentation (ADAMS Accession No. 24095A259), (4) May 2 Preapplication Closed Meeting Slides, April 18, 2024, PWROG-NRC Meeting on OLM Attachments.
3.2 Supporting Information from PWROG The PWROG is requested to make the appropriate personnel or contractors who are familiar with the proposed TR available for the audit (in person, through Microsoft Teams, or on the phone).
The NRC staff also requests that PWROG be prepared to discuss the items listed in Section 3.1 of this audit plan and, if applicable, have the related supporting documents available for review, which could be provided electronically. The NRC staff may require the PWROG to provide appropriate documents to the NRC docket that would enable an accelerated and effective review of the TR.
4.0 TEAM AND REVIEW ASSIGNMENTS Reviewer Expertise Assigned Auditor Technical Reviewer Norbert Carte (NRC/NRR)
Technical Reviewer John Hughey (NRC/NRR)
Technical Reviewer Ismael Garcia (NRC/NSIR)
Technical Reviewer(s)
Other NRC staff as needed Project Manager Leslie Fields (NRC/NRR) 5.0 LOGISTICS The audit will be 100 percent virtual on June 3, 2024, starting at 10:00 a.m. EST, and concluding at approximately 3:00 p.m.
The PWROG should provide the documentation that may aid discussion on the specific topics of interest.
Please note that the following proposed schedule is subject to change:
10:00 a.m.
Start Virtual Meeting - Introductions, Audit Activities, Goals, and Logistics 10:15 a.m.
PWROG and NRC Staff Meeting Feedback 11:30 a.m.
Break 12:30 p.m.
NRC Expectations of Sections Needed in the TR Application Submittal 2:30 p.m.
NRC/PWROG Wrap Up and Conclusions 4:00 p.m.
Exit the Audit 6.0 DELIVERABLES At the conclusion of the audit, the NRC staff will provide a summary report of the audit discussions listed in the audit scope. The NRC regulatory audit report will be issued within 90 days of the completion of the audit.
Package: ML24144A022 Cover Letter w/encl: ML24144A023
- by email OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DORL/LLPB/BC NAME LFields DHarrison GGeorge DATE 05/29/2024 05/29/2024 05/29/2024