ML15306A450

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Summary of Public Meeting to Discuss NEI 14-09 Guidelines for Implementation of 10 CFR Part 21 Reporting of Defects and Noncompliance
ML15306A450
Person / Time
Issue date: 11/03/2015
From: Belen-Ojeda A, Kerri Kavanagh
Division of Construction Inspection and Operational Programs, NRC/NRO/DCIP/CMVB
To: Nichol M
Nuclear Energy Institute
Belen-Ojeda A
References
NEI 14-09
Download: ML15306A450 (5)


Text

November 3, 2015 Mr. Marc Nichol Senior Project Manager, Quality Issues and Licensing Action Nuclear Energy Institute 1201 F Street NW, Suite 1100 Washington, DC 20004

SUBJECT:

SUMMARY

OF THE OCTOBER 16, 2015, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE TO DISCUSS THE DISCUSS NEI 14-09, GUIDELINES FOR IMPLEMENTATION OF 10 CFR PART 21 REPORTING OF DEFECTS AND NONCOMPLIANCE.

On October 16, 2015, a Category 3 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and Nuclear Energy Institute (NEI). The NRC staff had previously issued a public meeting notice dated September 28, 2015, as documented in the Agencywide Documents Access and Management System (ADAMS) under accession number ML15268A455. The meeting notice includes the meeting agenda.

The NRC staff conducted this meeting to discuss the results of the initial review of NEI 14-09, Guidelines for Implementation of 10 CFR Part 21 Reporting of Defects and Noncompliance.

The meeting discussion focused on a list of topics where NRC staff and NEI were not aligned so NEI can prepare for a Public Meeting scheduled for November 5, 2015 to present proposals to address NRCs concerns. Enclosure 1 provides a list of attendees. The meeting handout used during the discussion is located in ADAMS under accession number ML15287A350 and is provided as Enclosure 2.

The NRC staff presented different perspectives for consideration on NEI 14-09 and some suggestions to be added to NEI 14-09. The NRC staff noted that the guidance was geared toward a reactor licensee perspective with minimal guidance provided to vendors or third party dedication entities and the guidance did not address the purchaser taking 10 CFR Part 21 responsibility when dealing with overseas suppliers. Also, the NRC staff noted a lack of clarity between the discovery and evaluation phases, and the link between 10 CFR Part 21 and corrective action program.

The NRC staff suggested to include a discussion on entities that provide safety-related software with the message that software can affect safety-related items. The NRC staff informed NEI about certain areas where the vendors would benefit from licensees knowledge of the significance of 10 CFR Part 21 and the benefits of maintaining open dialog between licensee and vendor on a potential Part 21 evaluation.

NEI agreed to present a proposal to address NRCs concerns and to revise the NEI 14-09 guidance to reach consensus between NRC staff and NEI.

M. Nichol In the discussion related to Fuel Cycle Facilities, the NRC staff agree to create guidance for implementation of 10 CFR Part 21 Reporting of Defects and Noncompliance; and incorporate industry comments. The NRC staff is planning to endorse NEI 14-09 and incorporate the materials and fuel cycle guidance in a regulatory guide.

Please direct any inquiries to Aixa Belen at 301-415-6263 or via e-mail aixa.belen@nrc.gov; or Paul Prescott at 301-415-3026 or via e-mail at paul.prescott@nrc.gov.

Sincerely,

/RA Thomas Kendzia acting for/

Kerri Kavanagh, Chief Quality Assurance and Vendor Inspection Branch Division of Construction Inspection and Operations Programs Office of New Reactors

Enclosures:

List of Attendees cc w/encls:

See next page

ML15306A450 *via e-mail NRC-001 OFFICE NRO/DCIP/MVIB NRO/DCIP/QVIB NRO/DCIP/QVIB NAME ABelen PPrescott KKavanagh DATE 11/03/2015 11/03/2015 11/03/2015 List of Attendees Meeting with Nuclear Energy Institute (NEI) to discuss the results of the initial review of NEI 14-09, Guidelines for Implementation of 10 CFR Part 21 Reporting of Defects and Noncompliance, on October 16, 2015.

NAME AGENCY/AFFILIATION Janet Schlueter NEI Marc Nichol NEI Steve Schilthelm BWXT Jim Gresham Westinghouse Robert Theuret Westinghouse Doug Weaver Westinghouse Tom Loomis Exelon Frederick Willis Southern Nuclear Mike Dunkelberger MPR Associates Jay Gardiner* Curtiss-Wright Paul Garcia* AREVA Marc H. Tannenbaum* EPRI Frederick Puleo* South Texas Project Electrical Generating Station William A. Horin* Winston and Strawn LLP Rob Burg* Engineering Planning and Management Justin Wearne* PSEG Mari Jaworsky* Duke Energy Leslie J. Collins* Westinghouse Carlo L. Sisco* Winston and Strawn LLP Marvin Lewis* Public Aixa Belen Nuclear Regulatory Commission Paul Prescott Nuclear Regulatory Commission Kerri Kavanagh Nuclear Regulatory Commission Aaron Armstrong* Nuclear Regulatory Commission Jermaine Heath Nuclear Regulatory Commission Soly Soto Nuclear Regulatory Commission Solomon Sahle Nuclear Regulatory Commission Patrick Castleman Nuclear Regulatory Commission Kimyata Morgan Butler Nuclear Regulatory Commission

  • People participating on the phone Enclosure

Mailing List cc:

Ruth Thomas 354 Woodland Drive Columbus, NC 28722 Email jrs@nei.org mrn@nei.org swschilthelm@bwxt.com greshaja@westinghouse.com theurerc@westinghouse.com weave1dw@westinghouse.com thomas.loomis@exeloncorp.com fhwillis@southernco.com mdunkelberger@mpr.com mtannenbaum@epri.com fjpuleo@stpegs.com WHorin@winston.com rjb@epm-inc.com JGardiner@curtisswright.com Justin.Wearne@pseg.com Paul.Garcia@areva.com Mari.Jaworsky@duke-energy.com collinlj@westinghouse.com CSisco@winston.com