ML25352A091

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Westinghouse Electric Company, Nuclear Regulatory Commission Inspection Report 99900404/2025201
ML25352A091
Person / Time
Site: 99900404
Issue date: 01/13/2026
From: Douglas Bollock
NRC/NRR/DRO/IQVB
To: Bowman A
Westinghouse
References
EPID I-2025-201-0001 IR 2025201
Download: ML25352A091 (0)


Text

Mr. Andrew Bowman Manager, Global Nuclear Regulatory Affairs Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, PA 16066

SUBJECT:

NUCLEAR REGULATORY COMMISSION INSPECTION REPORT OF WESTINGHOUSE ELECTRIC COMPANY NO. 99900404/2025-201

Dear Mr. Bowman:

On May 12 - 15, July 7 - 10, August 25 - 28, and December 1 - 5, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an inspection at the Westinghouse Electric Company (hereafter referred to as WEC) facility in Warrendale, PA. The purpose of this limited-scope routine inspection was to assess WECs compliance with provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance, and selected portions of Appendix B, Quality Assurance Program Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.

This technically-focused inspection specifically evaluated WECs implementation of quality activities associated with the Limerick Generating Station Units 1 and 2 plant protection system digital modernization project design, implementation, and system validation test activities. The enclosed report presents the results of the inspection. In addition, the NRC inspection team evaluated WECs closure of the inspection findings documented in the inspection report No.

99900404/2024-201, dated June 18, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24169A203). This NRC inspection report does not constitute NRCs endorsement of WECs overall quality assurance (QA) or 10 CFR Part 21 programs.

Within the scope of this inspection, no violations or nonconformances were identified.

In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding, and the NRCs Rule of Practice, a copy of this letter, its enclosure(s), and your response will be made available electronically for public inspection in the NRCs Public Document Room or from the NRCs document system (ADAMS), accessible at http://www.nrc.gov/reading-rm/adams.html.

Enclosure:

Inspection Report No. 99900404/2025-201 and Attachment January 13, 2026

A. Bowman 2

Sincerely, Douglas Bollock, Branch Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation Docket No.: 99900404 EPID No.: I-2025-201-0001 Signed by Bollock, Douglas on 01/13/26

ML25352A091 NRR-106 OFFICE NRR/DRO/IQVB NRR/DRO/IQVB NRR/DEX/EICB NAME DZhang ENour SDarbali DATE 1/6/2026 12/18/2025 12/18/2025 OFFICE NRR/DEX/EICB R-I/DORS/EB2 NRR/DRO/IQVB NAME GBlas LDumont DBollock DATE 12/18/2025 1/12/2026 1/13/2026

Enclosure U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF REACTOR OVERSIGHT VENDOR INSPECTION REPORT Docket No.:

99900404 Report No.:

99900404/2025-201 Vendor:

Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, PA 16066 Vendor

Contact:

Mr. Andrew Bowman Manager, Global Nuclear Regulatory Affairs Email: bowmanab@westinghouse.com Nuclear Industry Activity:

Westinghouse Electric Company (hereafter referred to as WEC) supplies and supports development of the digital Plant Protection System for Limerick Generating Station Units 1 and 2.

Inspection Dates:

May 12 - 15, July 7 - 10, August 25 - 28, and December 1 - 5, 2025 Inspectors:

Deanna Zhang NRR/DRO/IQVB, Team Leader Aaron Armstrong NRR/DRO/IQVB, Team Leader Eric Nour NRR/DRO/IQVB, Trainee Charlotte Ruley NRR/DRO/IQVB, Trainee Louis Dumont R-I/DORS/EB2 Samir Darbali NRR/DEX/EICB, Technical Specialist Gilberto Blas NRR/DEX/EICB, Technical Specialist Approved by:

Douglas Bollock, Chief Quality Assurance and Vendor Inspection Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

2 EXECUTIVE

SUMMARY

Westinghouse Electric Company 99900404/2025-201 The U.S. Nuclear Regulatory Commission (NRC) staff conducted a limited-scope routine vendor inspection at the Westinghouse Electric Company (hereafter referred to as WEC) facility in Warrendale, PA, to verify it had implemented an adequate quality assurance (QA) program that complies with the requirements of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR)

Part 50, Domestic Licensing of Production and Utilization Facilities, and 10 CFR Part 21, Reporting of Defects and Noncompliance. The NRC inspection team conducted this inspection on-site and virtually during the weeks of May 12 - 15, July 7 - 10, August 25 - 28, and December 1 - 5, 2025.

This technically-focused inspection specifically evaluated WECs implementation of its QA and 10 CFR Part 21 programs as applied to WECs activities to support the development of the digital Plant Protection System (PPS) for Limerick Generating Station (LGS) Units 1 and 2. This inspection specifically focused on the development activities and design outputs related to the design phase, implementation phase, and completed portions of the system validation test phase of the digital PPS development lifecycle for LGS Units 1 and 2. In addition, the NRC inspection team evaluated WECs closure of the inspection findings documented in the inspection report No. 99900404/2024-201, dated June 18, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24169A203).

The following regulations served as the bases for the NRC inspection:

Appendix B to 10 CFR Part 50 10 CFR Part 21 During this inspection, the NRC inspection team implemented Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023; IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023; IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting of Defects and Noncompliance, dated February 10, 2023; and IP 35710, Quality Assurance Inspection of Software Used in Digital Instrumentation and Control Nuclear Applications, dated April 18, 2024.

The NRC inspection team observed the following specific activities:

System validation test activities for PPS Integrated Logic Processor (ILP) for software baseline (BL) 6.3 and BL 6.4 System validation test activities for PPS - Distributed Control System interface for software BL 6.4 System validation test activities for PPS response time validation for software BL 6.4 System validation test activities for PPS abnormal conditions for software BL 7.0 Demonstration of central processing unit max load indications and maintenance and test cabinet alarms

3 The results of the inspection are summarized below.

Inspection Areas The NRC inspection team reviewed a sample in the areas of design control, commercial grade dedication, procurement document control, control of purchased material, equipment, and services, test control, control of nonconforming material, parts or components, and corrective action program. The NRC inspection team concluded that the policies and procedures are implemented consistent with the requirements of Appendix B to 10 CFR Part 50, as imposed in procurements documents by licensees. No findings of significance were identified.

10 CFR Part 21 Program The NRC inspection team reviewed a sample in the area of 10 CFR Part 21. The NRC inspection team concluded that the policies and procedures are implemented consistent with the requirements of 10 CFR Part 21. No findings of significance were identified.

Corrective Action The NRC inspection team reviewed the corrective actions that WEC took to address Nonconformance Nos. 99900404-2024-201-01 and 99900404-2024-201-02, documented in inspection report No. 99900404/2024-201, dated June 18, 2025 (ADAMS Accession No. ML24169A203). The NRC inspection team reviewed the documentation that provided the objective evidence that all the corrective actions were completed and adequately implemented.

Based on this review, the NRC inspection team closed Nonconformance Nos. 99900404-2024-201-01 and 99900404-2024-201-02.

4 REPORT DETAILS 1.

10 CFR Part 21 Program a.

Inspection Scope The U.S. Nuclear Regulatory Commission (NRC) inspection team reviewed WECs policies and implementing procedures that govern the implementation of its Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance, program to verify compliance with the regulatory requirements. The NRC inspection team also evaluated the 10 CFR Part 21 postings and verified that these postings are in compliance with the 10 CFR 21.6, Posting Requirements. The NRC inspection team verified that WECs corrective action procedures provide a link to the 10 CFR Part 21 program. The NRC staff also reviewed a sample of Part 21 evaluations that are applicable to the Limerick Generating Station (LGS) Units 1 and 2 Plant Protection System (PPS) digital modernization project and verified that these evaluations were performed documented in accordance with WECs 10 CFR Part 21 program procedures.

The NRC inspection team also discussed WECs 10 CFR Part 21 program with WECs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.

b.

Observations and Findings No findings of significance were identified.

c.

Conclusion The NRC inspection team concluded that WEC has established its 10 CFR Part 21 program in accordance with the requirements of 10 CFR Part 21. Based on the limited sample of documents reviewed, the NRC inspection team determined that WEC is implementing its policies and procedures consistent with the requirements of 10 CFR Part 21. No findings of significance were identified.

2.

Design Control a.

Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its design control program to verify compliance with the regulatory requirements of Criterion III, Design Control, of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. The NRC inspection team reviewed a sample of design output documents for the design phase, implementation phase, and test phase for the Limerick PPS digital modernization project and verified these documents have been adequately completed in accordance with WECs policies and procedures. Specifically, the NRC inspection team traced system attributes for Central Processing Unit (CPU) load limits, response times, secure operational environment, the component interface module (CIM), and communication independence from the license amendment request documents of the Limerick digital PPS to system requirements, the

5 system requirements to software requirements and hardware design descriptions, to software design descriptions and hardware drawings, and to the system validation test procedures and data sheets. The NRC inspection team also reviewed completed independent verification and validation (IV&V) tasks, including a regression analysis report for these lifecycle phases.

The NRC staff observed how the health of the Advant Controller (AC) 160 components is monitored via the Node Heartbeats screen on the Safety Display and the maintenance and test panel (MTP). For the CIM, the NRC inspection team also observed how the operability of the CIMs is monitored via the Safety Display and the MTP; for example, when toggling a CIM switch to Local mode or when physically removing a CIM from its baseplate, various messages are provided to in the Safety Display and MTP. The NRC inspection team confirmed that these features were consistent with the LGS PPS LAR documents, and system requirements and design specifications.

The NRC inspection team also discussed WECs design control program with WECs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.

b.

Observations and Findings No findings of significance were identified.

c.

Conclusion The NRC inspection team concluded that WEC has established its design control program in accordance with the requirements of Criterion III of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that WEC is implementing its policies and procedures consistent with the requirements of Criterion III of Appendix B to 10 CFR Part 50. No findings of significance were identified.

3.

Commercial Grade Dedication, Procurement Document Control, and Control of Purchased Material, Equipment and Services a.

Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its commercial grade dedication program, procurement document control program, and control of purchased material, equipment, and services program to verify compliance with the requirements of Criterion III, Criterion IV, Procurement Document Control, and Criterion VII, Control of Purchased Material, Equipment and Services, of Appendix B to 10 CFR Part 50.

The NRC inspection team reviewed a sample of purchase orders (POs) and verified that applicable regulatory requirements, design bases, and other requirements necessary to assure adequate quality are included or referenced in these sample set of POs. The NRC inspection team also reviewed a sample of supplier audit reports and commercial grade surveys (CGS) performed associated with components used in the Limerick PPS project and verified that the scope of the audits and CGS, audit and CGS results, and any findings were properly documented. The NRC inspection team reviewed a sample of commercial grade

6 dedication packages and witnessed a receipt inspection for one of the components undergoing the dedication process. The NEC inspection team verified that the receipt inspection was performed in accordance with written procedures and checklists.

The NRC inspection team also discussed WECs commercial grade dedication program, procurement document control program, and control of purchased material, equipment, and services program with WECs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.

b.

Observations and Findings No findings of significance were identified.

c.

Conclusion The NRC inspection team concluded that WEC has established its commercial grade dedication program, procurement document control program, and control of purchased material, equipment, and services program in accordance with the requirements of Criterion III, Criterion IV, and Criterion VII of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that WEC is implementing its policies and procedures consistent with the requirements of Criterion III, Criterion IV, and Criterion VII of Appendix B to 10 CFR Part 50. No findings of significance were identified.

4.

Nonconforming Parts, Materials, or Components, and Corrective Action Program a.

Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its control of nonconforming parts, materials, or components and corrective action programs to verify compliance with the requirements of Criterion XV, Nonconforming Materials, Parts, or Components, and Criterion XVI, Corrective Action, of Appendix B to 10 CFR Part 50, respectively.

The NRC inspection team verified that WECs processes and procedures provide for the identification, documentation, segregation, evaluation, and disposition of nonconforming items. These processes also apply the principles of rework, repair, reject, use-as-is.

The NRC inspection team reviewed a sample of automation issues tracking system (RITS) associated with the production of the Limerick digital modernization project to confirm that WEC dispositioned the nonconforming materials in accordance with the applicable procedures, documented an appropriate technical justification for various dispositions and took adequate corrective action regarding the nonconforming items to prevent recurrence as appropriate.

The NRC inspection team also reviewed a sample of Corrective Action Program (CAP)-

Incident Reports (CAP-IRs) and Problem Identification and Resolution Reports (PIRs) to verify: (1) adequate documentation and description of conditions adverse to quality; (2) appropriate identification of corrective actions taken to correct the condition; (3) direction for review and approval by the responsible authority; (4) a description of the current status of

7 the corrective actions; and (5) actions taken to verify timely and effective implementation of the corrective actions. In addition, the NRC inspection team confirmed that the corrective action and nonconformance process provides a link to the 10 CFR Part 21 Program.

The NRC inspection team discussed WECs controls for nonconforming parts, materials, or equipment and its corrective action programs with WECs management and technical staff.

The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.

b.

Observations and Findings b.1 Corrective Actions Associated with Nonconformance 99900404/2024-201-01.

Following the 2024 NRC inspection of WEC, the NRC issued Nonconformance 99900404/2024-201-01 for WECs failure to ensure that purchased material, equipment and services from Liberty Electronics conform to the PO requirements. Specifically, WEC did not provide sufficient objective evidence to demonstrate that Liberty had included in its quality program requirements to (1) use International Organization for Standardization (ISO)/International Electrotechnical Commission (IEC) 17025, General requirements for the competence of testing and calibration laboratories accredited laboratories for procured calibration services, and (2) record inspection, measurement, and test equipment used for all inspection and tests for WEC products. In addition, WEC did not provide sufficient objective evidence that documents the basis to allow certain procurement restrictions imposed on procurements from Liberty as documented in CAP-IR-2020-4474 to be removed.

In its response to the NRC dated June 18, 2024 (ADAMS Accession No. ML24199A220)

WEC stated that the steps that they would take to avoid further noncompliance would be the creation of CAP-IR-2024-6678. The NRC inspection team reviewed the corrective actions identified in CAP-IR-2024-6678, including objective evidence of the adequate implementation of these corrective actions. Specifically, the NRC inspection verified that:

Training was conducted with WEC supplier quality auditors to ensure consistency (1) when processing deficiencies identified during the CGS process, and (2) the level of specificity required when documenting the objective evidence documentation for deficiencies identified.

Completion of an extent of condition evaluation of the Westinghouse QSL and identification and completion of additional corrective actions to address the results of the evaluation.

Revision of WECs procedure, QA-7.22, Commercial Grade Survey Process, to clarify the requirements for maintaining compensatory measure on the QSL until WEC Engineering has fully resolved any of the discrepancies within the commercial grade item or the supplier.

Performance of limited scope CGS of Liberty Electronics to reconcile the lack of objective evidence documented within WECs CGS report, WES-2023-102.

8 Based on its review, the NRC inspection team closed Nonconformance 99900404/2024-201-01.

b.2 Corrective Actions Associated with Nonconformance 99900404/2024-201-02.

Following the 2024 NRC inspection of WEC, the NRC issued Nonconformance 99900404/2024-201-02, for WECs failure to promptly correct conditions adverse to quality. Specifically, WEC closed CAP-IR-2023-3864 and CAP-IR-2023-11754 without including sufficient details in the closure statement about resolution and did not include objective evidence of all performed activities within the corrective action reports.

In its response to the NRC dated June 18, 2024 (ADAMS Accession No. ML24199A220),

WEC stated that the steps that they would take to avoid further noncompliance would be the creation of CAP-IR 2024-5058, CAP-IR 2024-5561, CAP-IR-2024-6149, and CAP-IR-2024-6685 to address the lack of procedural compliance by conducting causal analysis, extent of condition, extent of cause, and refresher training. In addition, WEC introduced an additional final QA approval of all CAP-IRs in the closure workflow to control CAP closure which includes a checklist to aid issue owners in ensuring compliance for CAP closure.

The NRC inspection team reviewed the documentation that provided the objective evidence for the completion of the corrective actions, including a review of CAP-IR 2024-5058, CAP-IR 2024-5561, CAP-IR-2024-6149, and CAP-IR-2024-6685. Specifically, the NRC inspection team verified that the CAP-IR's provided objective evidence that the causal analysis, extent of cause, extent of condition, and refresher training actions had been completed and that a checklist and final quality assurance check of each report was implemented within WECs updated corrective action program process.

The NRC inspection team determined that WECs corrective actions were adequately implemented to address Nonconformance 99900404/2024-201-02. Based on its review, the NRC inspection team closed Nonconformance 99900404/2024-201-02.

c.

Conclusion The NRC inspection team concluded that WEC has established controls for nonconforming materials, parts, or components, and corrective actions program in accordance with the requirements of Criterion XV and Criterion XVI of Appendix B to 10 CFR Part 50. Based on the limited samples reviewed, the NRC inspection team also determined that WEC is implementing its policies and procedures consistent with the requirements of Criterion XV and Criterion XVI of Appendix B to 10 CFR Part 50.

5.

Test Control a.

Inspection Scope The NRC inspection team reviewed WECs policies and implementing procedures that govern the implementation of its test control program to verify compliance with the requirements of Criterion XI, Test Control, of Appendix B to 10 CFR Part 50.

The NRC inspection team reviewed a sample of test procedures and test datasheets that cover portions of the Limerick PPS system validation tests and verified that these procedures adequately identify the objective of the tests covered by the procedure, and the

9 test data sheets included: appropriate test cases to verify that the test objectives were accomplished, and the expected results of each test case were properly identified. The NRC inspection team witnessed the performance of a sample of test cases in the areas of integrated logic processor tests, PPS abnormal conditions tests, PPS-Distributed Control System interface tests, and time response tests for various software baselines of the PPS and verified that these tests were performed in accordance with test procedures and test data sheets.

The NRC inspection team also discussed WECs test control program with WECs management and technical staff. The attachment to this inspection report lists the documents reviewed and personnel interviewed by the NRC inspection team.

b.

Observations and Findings No findings of significance were identified.

c.

Conclusion The NRC inspection team concluded that WEC has established its test control program in accordance with the requirements of Criterion XI of Appendix B to 10 CFR Part 50. Based on the limited sample of documents reviewed, the NRC inspection team also determined that WEC is implementing its policies and procedures consistent with the requirements of Criterion XI of Appendix B to 10 CFR Part 50. No findings of significance were identified.

6.

Entrance and Exit Meetings On May 12, 2025, the NRC inspection team discussed the scope of the inspection during the entrance meeting with Christopher Crefeld, WECs Vice President, Global Instrumentation and Controls, and other members of WECs management and technical staff. On December 5, 2025, the NRC inspection team presented the inspection results during an exit meeting with Chris Srock, WECs Senior Director, Global Instrumentation and Controls, and other members of WECs management and technical staff. The attachment to this report lists the attendees of the entrance and exit meetings, as well as those individuals whom the NRC inspection team interviewed.

Att1-1 ATTACHMENT 1.

ENTRANCE/EXIT MEETING ATTENDEES Name Position Affiliation Entrance Exit Interviewed Chris Meier Consulting Engineer WEC X

X*

X Dominic Mocello System Test Manager WEC X

X Steven Merkiel Integrated System Engineer Lead WEC X

X Matthew Shakun Licensing Engineer WEC X

X John Semonos WEC Licensing WEC X

Garret Takei Engineer WEC X

X Lauren Furguiele Project Manager WEC X

X*

X Angela Zubroski Quality and Ops Planning Manager WEC X

X Parastoo Muse Limerick DMP Program Manager WEC X

X*

X Warren Odess-Gillet Licensing I&C Engineer WEC X*

X*

X*

Christopher Srock Senior Director Global Instrumentation and Control WEC X

X*

Att1-2 Steven Billman Director, Control and Information System WEC X*

Andrew Barth Senior Specialist Contract Management WEC X

X*

X Jerrod Ewing Operating Plants Licensing Manager WEC X

X X

Andrew Lutz Principal Project Manager WEC X

Dante Mincin Manager, Qualification Operation WEC X

Miguel Vallarta Manager, Safety Hardware Engineering and Drafting WEC X*

X*

Daniel Zenger Principal Product Engineer WEC X*

Quang Nguyen Director, Safety and Reactor Systems Engineering WEC X*

Bryan Jaskiewicz Functional and System Engineering Manager WEC X*

Mikhail Lemkov I&C Safety Software Manager WEC X*

Johnathan Semanco Principal Engineer WEC X*

Chris Crefeld Vice President, Global Instrumentation and Controls WEC X*

X Murat Uzman Fellow Engineer, IV&V WEC X

X Srinivasan Suresh Principal Engineer WEC/Cyient X

Kenneth Pryke Test Lead WEC X

Brandon Neff Test Lead WEC X

David Bash Technician WEC X

Att1-3 Michael Pezek Test Lead WEC X

Bailey OMalley Tester WEC X

Jeff Mascitelli Senior Engineer WEC X

Anandi Balakumar IV&V Team Leader WEC X

Mark Samselski Engineering Manager Constellation X

Scott Schumacher Senior Engineer Constellation X*

Michael Foote Senior Staff Engineer Constellation X

Gerald Segner Senior Project Manager Constellation X*

Ashley Rickey Project Manager Constellation X*

X*

Steven Hesse Manager, Reactor Engineering Constellation X

Kevin Cawley Electrical Engineer Constellation X

Brian Devine Operations Senior Manager Constellation X

Kayla Marriner Project Manager Constellation X*

Deanna Zhang Inspection Team Leader Nuclear Regulatory Commission (NRC)

X X

Aaron Armstrong Inspector NRC Eric Nour Inspector NRC X

X

Att1-4 Charlotte Ruley Inspector NRC Louis Dumont Inspector NRC X*

Samir Darbali Inspector NRC X*

X Gilberto Blas Inspector NRC X*

Kerri Kavanagh Branch Chief NRC X*

X*

  • Remote 2.

INSPECTION PROCEDURES USED:

Inspection Procedure (IP) 43002, Routine Inspections of Nuclear Vendors, dated February 10, 2023 IP 43004, Inspection of Commercial-Grade Dedication Programs, dated February 10, 2023 IP 36100, Inspection of 10 CFR Part 21 and Programs for Reporting of Defects and Noncompliance, dated February 10, 2023 3.

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Type Description 99900404/2024-201-01 Closed Notice of Nonconformance (NON)

Criterion VII of Appendix B to 10 CFR 50 99900404/2024-201-02 Closed NON Criteria XVI of Appendix B to 10 CFR 50 4.

DOCUMENTS REVIEWED Quality Assurance Procedures (QAP)

W2-5.1-101, Westinghouse Corrective Action Program Procedure Revision 11.0, dated June 16, 2025 W2-5.1-101.W01, Corrective Action Program Issue Identification, Screening, and Classification Revision 5.0, dated June 16, 2025 W2-5.1-101.W11, Corrective Action Program Issue Evaluation, Analysis, Resolution, and Trending Revision 4.0, dated June 16, 2025 NA 15.1, Control of Nonconformances, Revision 22.0, dated September 12, 2024 W2-5.1-201, Identification and Reporting of Conditions Adverse to Nuclear Safety Revision 3.0, dated March 27, 2024

Att1-5 W2-5.1-201.W01, Nuclear Safety Review Staff Work Instruction Revision 3.0, dated March 27, 2024 W2-5.1-201.W02, 10 CFR Part 21 Posting Revision 1.0, dated March 27, 2024 W2.9.4-101, Control of Purchased Items and Services Revision 9.0, dated July 2, 2025 W2-9.5-101, Supplier QA Program Qualification and assessment, Revision 4.1, dated September 30, 2024 W2-9.5-102, Commercial Grade Dedication process, Revision 2 W2-9.5-104, Supplier Oversight, Revision 2.0, dated June 5, 2018 W2-9.5-105, Control of Suppliers and the ASL and QSL, Revision 3.0, dated October 10, 2018 W2-9.5-106, Supplier Corrective Action Request Process, Revision 4.1, dated April 11, 2025 W2-9.14-200, Counterfeit, Fraudulent, and Suspect Items, Revision 0.2, dated July 5, 2022 NA 6.1.2, Quality Specification for Procurement, Revision 8.2, dated November 15, 2023 QCI-308, Work Instruction for Receiving Inspection of Item(s) Controlled on a Westinghouse Commercial Dedication Instruction, Revision 8, November 2024 QCI-415, Work Instruction for Sampling, Revision 1 QA-2.8, Qualification of Audit Personnel, Revision 2.2, dated December 14, 2022 Design Control WNA-VR-00580-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project, Plant Protection System IV&V Summary Report, Revision 1, dated August 2024 WNA-VR-00580-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project, Plant Protection System IV&V Summary Report, Revision 2, dated January 2025 WNA-ECN-00133-GLIM, Limerick DMP Baseline 6.2r1 Updates, Revision 0 WNA-ECN-00134-GLIM, Limerick DMP Baseline 6.3 Updates, Revision 0 WNA-ECN-00135-GLIM, Limerick DMP Baseline 6.4 Updates, Revision WNA-LD-01578-GLIM, Limerick DMP Architecture & Layout Index Sheet, Revision 4 WNA-CN-00603-GLIM, Limerick Generating Station, Units 1 & 2, Digital Modernization Project Plant Protection System Time Response Calculations, Revision 3 WNA-DS-05075-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Requirement Specification, Revision 0

Att1-6 WNA-DS-05101-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Component Functional Logic Specification, Revision 1, dated August 2023 WNA-DS-05129-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Functional Logic Specification, Revision 1, dated August 2023 WNA-SD-00746-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Bistable Processor Logic and Regulatory Guide 1.97 Processor, Revision B, dated February 2024 WNA-SD-00747-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Local Coincidence Logic Processor, Revision B, dated February 2024 WNA-SD-00748-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Integrated Logic Processor, Revision B, dated February 2024 WNA-SD-00749-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Software Design Description for the Interface and Test Processor, Revision B, dated February 2024 WNA-SD-00750-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Maintenance and Test Panel, Revision B, dated February 2024 WNA-SD-00751-GLIM, Limerick Generating Station Units 1&2 Plant Protection System Digital Modernization Project Software Design Description for the Safety Display, Revision 5, dated November 2025 WNA-RL-07536-GLIM1, AC160 Software Release Record for BPL, Revision 3 WNA-RL-07538-GLIM1, AC160 Software Release Record for RG1.97-Div2, Revision 2 WNA-RL-07541-GLIM1, AC160 Software Release Record for LCL-ECCS/NSSSS, Revision 2 WNA-RL-07542-GLIM1, AC160 Software Release Record for LCL-RPS, Revision 4 WNA-RL-07543-GLIM1, AC160 Software Release Record for ILP with Voting, Revision 4 WNA-RL-07544-GLIM1, AC160 Software Release Record for ILP without Voting, Revision 4 WNA-RL-07547-GLIM1, Software Release Record for Unit 1 FPDS Maintenance and Test Panel, Revision 4 WNA-RL-07548-GLIM1, Software Release Record for FPDS Safety Display, Revision 4 Commercial Grade Dedication Package

Att1-7 CDI-4057, Services Associated with Built to Print Electro-mechanical Parts &

Assemblies, Revision 14, dated August 2024 CDI-2794, Pluggable Relay with Terminal Block Base, Revision 22, dated February 19, 2020 CDI-3497, Solid-state Relays for Use in Production, Revision 8, dated February 2, 2023 CDI-2687, Standard Safety Isolation Amplifier or Signal Conditioner, Revision 22, dated September 11, 2024 CDI-2660, Ovation Modules, Revision 24, dated March 5, 2024 Audit/Survey WES-2023-300, Revision 0 WES-2025-050, Revision 0 WES-2024-106, Revision 0, dated August 12, 2024 WES-2024-266, Revision 0, dated August 23, 2024 WES-2023-102, dated March 21,2023 WES-2024-267, dated August 16, 2024 WES-2024-152/NIAC 31474, dated January 12, 2024 Purchase Orders (PO) 4500931943, STND SFTY IR Preamp Chassis Bottom FAB, dated February 21, 2025 4500931545, Flow Control Service Screw, HEX CAP 1/4IN-28X1-1/2IN GRADE 5, dated February 18, 2025 4500935224, Module Input Isolator E/I 0-1 Vrms, dated March 28, 2025 Contract ID 00800304, Limerick Plan Protection System Digital Upgrade Project, dated November 18, 2020 Test Control Documents WNA-TP-01109-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project, Plant Protection System Integrated Logic Processor Test Specification/Procedure, Revision 1, dated April 2025 WNA-TD-01109-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project, Plant Protection System Integrated Logic Processor Test Data Sheets, Revision 0, dated May 2025 WNA-TD-01109-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project, Plant Protection System Integrated Logic Processor Test Data Sheets, Revision 1, dated August 2025

Att1-8 WNA-TD-01117-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project, Plant Protection System Distributed Control System Interface Test Data Sheets, Revision 1, dated July 2025 WNA-TD-01142-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Abnormal Conditions Integrated Logic Processor Test Data Sheets, Revision 0, dated June 2025 WNA-TP-01117-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project, Plant Protection System Distributed Control System Interface Test Specification/Procedure, Revision 1, dated June 2025 WNA-TP-01142-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Abnormal Conditions Integrated Logic Processor Test Specification/Procedure, Revision 1, dated June 2025 WNA-TP-01112-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Time Response Test Specification/Procedure, Revision 1, dated August 2025 WNA-TD-01112-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Time Response Test Data Sheets, Revision 0, dated August 2025 WNA-TP-01144-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Abnormal Conditions Nuclear Steam Supply Shutoff System Test Specification/Procedure, Revision 1, dated August 2025 WNA-TD-01144-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Abnormal Conditions Nuclear Steam Supply Shutoff System Test Data Sheets, Revision 1, dated November 2025 WNA-TP-01112-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Time Response Test Specification/Procedure, Revision 2, dated November 2025 WNA-TS-00216-GEN, Plant Protection System Upgrade Equipment Qualification Unit Configuration and Test Specification, Revision 3, dated July 2024 WNA-TP-08031-GLIM, Limerick Plant Protection System Upgrade Components Reconciliation Equipment Qualification Test Monitoring Procedure, Revision 3, dated February 2025 WNA-AR-01150-GLIM, Limerick Generating Station Unit 1 Digital Modernization Project Plant Protection System Factory Acceptance Testing Regression Analysis Report, Revision 0, dated May 2025 WNA-TD-01134-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project, Plant Protection System Maintenance and Test Panel Miscellaneous Test Data Sheets, Revision 0, dated August 2025 WNA-TD-01119-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Cabinet Indication and Status Test Data Sheets, Revision 2, dated November 2025

Att1-9 WNA-TD-01146-GLIM, Limerick Generating Station Units 1&2 Digital Modernization Project Plant Protection System Abnormal Conditions-Miscellaneous Test Data Sheets, Revision 1, dated November 2025 10 CFR Part 21 Evaluations LTR-SRC-24-39, Nuclear Safety Evaluation for IR-2024-10627 Common Q System Time Response Calculation Methodology, dated December 18, 2024 Automation Issues Tracking System (RITS)

RITS 78714, dated July 20, 2023 RITS 78715, dated July 20, 2023 RITS 79463, dated January 5, 2024 RITS 79538, dated January 23, 2024 RITS 79541, dated January 23, 2024 RITS 80438, dated June 20, 2024 RITS 81834, dated November 18, 2024 RITS 82086, dated December 17, 2024 RITS 82152, dated December 19, 2024 RITS 82212, dated January 8, 2025 RITS 82221, dated January 9, 2025 RITS 82448, dated February 7, 2025 RITS 82643, dated February 28, 2025 RITS 82652, dated February 28, 2025 RITS 82752, dated March 13, 2025 RITS 82767, dated March 13, 2025 RITS 83081, dated April 25, 2025 RITS 83233, dated May 9, 2025 RITS 83236, dated May 11, 2025 RITS 83248, dated May 12, 2025 RITS 83284, dated May 14, 2025 RITS 83286, dated May 14, 2025 RITS 83287, dated May 14, 2025 RITS 84481, dated September 1, 2025 RITS 84497, dated September 3, 2025 RITS 84506, dated September 3, 2025 RITS 84511, dated September 4, 2025 RITS 84512, dated September 4, 2025 RITS 84520, dated September 5, 2025 RITS 84527, dated September 6, 2025 RITS 84619, dated September 12, 2025 RITS 84657, dated September 16, 2025 RITS 84675, dated September 16, 2025 RITS 84733, dated September 25, 2025 RITS 84744, dated September 26, 2025

Att1-10 RITS 84758, dated September 27, 2025 RITS 84922, dated October 14, 2025 RITS 84935, dated October 17, 2025 RITS 84946, dated October 17, 2025 RITS 85099, dated November 5, 2025 RITS 85169, dated November 11, 2025 RITS 85192, dated November 14, 2025 RITS 85193, dated November 14, 2025 RITS 85194, dated November 14, 2025 Corrective Action Program Issue Reports (CAP-IRs)

CAP-IR-2023-3185, dated March 28, 2023 CAP-IR-2023-3864, dated April 18, 2023 CAP-IR-2023-4482, dated May 5, 2023 CAP-IR-2023-4866, dated May 16, 2023 CAP-IR-2023-5195, dated May 29, 2023 CAP-IR-2023-6856, dated July 14, 2023 CAP-IR-2023-8261, dated August 23, 2023 CAP-IR-2023-11611, dated November 21, 2023 CAP-IR-2023-12158, dated December 6, 2023 CAP-IR-2023-12161, dated December 6, 2023 CAP-IR-2024-2567, dated March 12, 2024 CAP-IR-2024-5058, dated May 8, 2024 CAP-IR-2024-5561, dated May 20, 2024 CAP-IR-2024-6048, dated June 3, 2024 CAP-IR-2024-6149, dated June 5, 2024 CAP-IR-2024-6678, dated July 20, 2024 CAP-IR-2024-6685, dated July 20, 2024 CAP-IR-2024-8514, dated August 14, 2024 CAP-IR-2024-8935, dated August 26, 2024 CAP-IR-2024-8984, dated August 27, 2024 CAP-IR-2024-8997, dated August 28, 2024 CAP-IR-2024-9039, dated August 28, 2024 CAP-IR-2024-9085, dated August 29, 2024 CAP-IR-2024-9493, dated September 10, 2024 CAP-IR-2024-9494, dated September 10, 2024 CAP-IR-2024-9495, dated September 10, 2024 CAP-IR-2024-10152, dated September 26, 2024 CAP-IR-2024-10389, dated October 3, 2024 CAP-IR-2024-10627, dated October 9, 2024 CAP-IR-2024-11882, dated November 9, 2024 CAP-IR-2024-12131, dated November 15, 2024 CAP-IR-2024-12132, dated November 15, 2024 CAP-IR-2024-12134, dated November 15, 2024 CAP-IR-2024-12135, dated November 15, 2024 CAP-IR-2024-13293, dated December 18, 2024

Att1-11 CAP-IR-2025-2246, dated March 6, 2025 CAP-IR-2025-2249, dated March 6, 2025 CAP-IR-2025-2250, dated March 6, 2025 CAP-IR-2025-2251, dated March 6, 2025 CAP-IR-2025-2252, dated March 6, 2025 CAP-IR-2025-2255, dated March 6, 2025 CAP-IR-2025-2258, dated March 6, 2025 CAP-IR-2025-2887, dated March 21, 2025 CAP-IR-2025-5261, dated May 22, 2025 CAP-IR-2025-5264, dated May 22, 2025 CAP-IR-2025-5265, dated May 22, 2025 CAP-IR-2025-5266, dated May 22, 2025 CAP-IR-2025-5268, dated May 22, 2025 Problem Identification and Resolution Reports (PIRs)

PIR-2025-2814, dated September 9, 2025 PIR-2025-4000, dated September 30, 2025 PIR-2025-4011, dated October 1, 2025 PIR-2025-4012, dated October 1, 2025 PIR-2025-4025, dated October 12, 2025 PIR-2025-4128, dated October 12, 2025 Corrective Action Reports Opened During the Inspection PIR-2025-2663, dated August 26, 2025 PIR-2025-6845, dated December 2, 2025 Training Records Douglas Burget, Lead Auditor Qualification package, dated February 17, 2025 Steven Vandevort, Lead Auditor Qualification package, dated March 24, 2025 Training records for Janakirman Murugesan Training records for Srinivasan Suresh Miscellaneous/Other LTR-IVV-22-013, Resource Allocation Agreement for Cyient Engineers to Perform IV&V Activities on Limerick PPS Project, dated October 20, 2022 LIM-25-010-P, Update to WCAP-18598, Revision 2, Licensing Technical Report for the Limerick Generating Stations Units 1&2 Digital Modernization Project, Revision 3, dated September 30, 2025