ML24208A000
| ML24208A000 | |
| Person / Time | |
|---|---|
| Site: | 99902037 |
| Issue date: | 10/30/2024 |
| From: | Leslie Fields Licensing Processes Branch |
| To: | Gerond George Licensing Processes Branch |
| Shared Package | |
| ML24144A022 | List: |
| References | |
| EPID L-2024-LRM-0048 | |
| Download: ML24208A000 (1) | |
Text
Enclosure AUDIT REPORT
SUMMARY
FROM THE JUNE 3, 2024, PREAPPLICATION DISCUSSIONS PERTAINING TO THE PRESSURIZED WATER REACTOR OWNERS GROUP CONCEPTUAL TOPICAL REPORT RELATED TO 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 NRC staff held a closed preapplication meeting (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24093A282) with the PWROG representatives to discuss the proposed TR. On June 3, 2024, the NRC staff held a virtual preapplication audit with PWROG representatives to provide feedback from the May 2, 2024, preapplication meeting.
The NRC staff held the preapplication regulatory audit on June 3, 2024, to enhance the technical understanding of the proposed TR and the conceptual OLM program. This audit allowed the NRC staff the opportunity to provide feedback on the proposed NRC regulatory structure for the conceptual TR, and to specifically state the NRCs expectations for this type of submittal. The audit was 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 OBJECTIVES The objective of the audit was to enhance NRCs understanding of the forthcoming TR submittal and provide additional feedback from preapplication discussions engaged in with PWROGs technical experts during the May 2, 2024, closed meeting. More specifically, the audit allowed the NRC staff to obtain more clarification on the conceptual OLM program, have extended discussions about differences in technical opinion, examine supportive documentation, and identify those areas of the review that need additional focus.
The NRC staff and industry representatives who participated in the audit are listed below:
Name Affiliation Leslie Fields NRC Norbert Carte NRC Matthew Dennis NRC Ismael Garcia NRC John Hughey NRC Alexander Schwab NRC Alex Prada NRC Derek Halverson NRC Timothy Marshall NRC Roy Hardin NRC Trey Hathaway NRC Sergiu Basturescu NRC James Andrachek PWROG - Westinghouse Electric Company (Westinghouse)
Chad Holderbaum PWROG - Westinghouse Jay Boardman Westinghouse Dewey Olinski Westinghouse John Moorehead Westinghouse Thomas Laubham Westinghouse James Lynde Constellation Randy Bickford Expmicrosys Jeff Hudson American Electric Power Dana Schlosser Dominion Energy 3.0 REGULATORY AUDIT BASES The following regulations could be applicable to the conceptual TR:
Title 10 of the Code of Federal Regulations (10 CFR) 50.36, Technical Specifications [(TSs)], 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.
The Surveillance Frequency Control Program (SFCP) is a program in technical specifications (TS), and therefore, implementation of the program in accordance with the TS does not require further evaluation under 10 CFR 50.59.
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.
4.0 AUDIT DISCUSSION Prior to the audit, the NRC staff identified areas needing further clarification based on the discussions that took place during the closed meeting on May 2, 2024.
The audit allowed for significant engagement on topics from the following NRC offices/branches:
Office of Nuclear Reactor Regulation Division of Engineering and External Hazards Instrumentation Controls & Electrical Engineering Branch Office of Nuclear Reactor Regulation Division of Risk Assessment Probabilistic Risk Assessment Oversight Branch Office of Nuclear Regulatory Research Division of Engineering Instrumentation Controls & Electrical Engineering Branch Office of Nuclear Security and Incident Response Division of Physical and Cyber Security Policy Cybersecurity & Digital Instrumentation and Control The discussion during the audit provided several opportunities to explain the details and contents which should be part of the future TR submittal.
4.1 Future Actions The PWROG representatives stated that they plan to submit the TR containing the OLM program in October of 2024.
4.2 Examined Audit Documents All presentations and documents discussed during the audit were shared via a Box.com folder due to the proprietary nature of the documents.
5.0 CONCLUSION
The audit accomplished the objectives and goals listed in Section 3.0 of the audit plan by allowing direct interaction with PWROGs technical experts. The NRC staff provided feedback as part of the preapplication phase which can be incorporated in the future TR submittal. The discussions and technical opinions shared during the audit will allow the NRC staff and PWROG representatives to efficiently complete the goals of the audit and understand the important issues prior to the acceptance review of the future submittal.
Package: ML24144A022 Audit Plan: ML24144A023 Audit Report Summary: ML24208A000 Cover Letter: ML24208A001
- by email OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DEX/EICB/EE NRR/DORL/LLPB/BC NRR/DORL/LLPB/PM NAME LFields DHarrison NCarte GGeorge LFields DATE 07/26/2024 8/2/2024 8/2/2024 8/12/2024 10/30/2024