ML18107A049

Summary of March 29, 2018, Teleconference on Digital Instrumentation and Control Integrated Action Plan Modernization Plan 4

ML18107A049
Person / Time
Issue date:	05/03/2018
From:	Joe Golla NRC/NRR/DLP/PLPB
To:	Dennis Morey NRC/NRR/DLP/PLPB
Golla J
References
Download: ML18107A049 (4)

Text

May 3, 2018 MEMORANDUM TO: Dennis C. Morey, Chief Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation FROM:

Joseph A. Golla, Project Manager /RA/

Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation

SUMMARY

OF MARCH 29, 2018, TELECONFERENCE ON DIGITAL INSTRUMENTATION AND CONTROL INTEGRATED ACTION PLAN MODERNIZATION PLAN #4 On March 29, 2018, U.S. Nuclear Regulatory Commission (NRC) staff held a public teleconference with representatives from the Nuclear Energy Institute (NEI) to continue discussions of short-term aspects of Modernization Plan #4 (MP #4a) of the Integrated Action Plan to Modernize Digital Instrumentation and Controls (DI&C) Regulatory Infrastructure (Agencywide Documents Access and Management System (ADAMS) Package Accession Number ML17277B643). The purpose of the meeting was to discuss a revision to the current interim staff guidance (ISG) for license amendment requests (LARs) that include DI&C safety equipment (DI&C-ISG-06). The discussions focused on the following:

1. Quality assurance (QA) language in the draft DI&C-ISG-06

2. Status of the DI&C-ISG-06 draft (ADAMS Accession No. ML18088A013)

3. Clarification of DI&C-ISG-06 language changes

4. Planning for the June 13-14, 2018, table top exercise

5. Identification of activities for the next public teleconference NRC and NEI discussed the language in Section C.2.2 referencing the 2015 version of the American Society of Mechanical Engineers standard Nuclear Quality Assurance (NQA) 1, Part II, Quality Assurance Requirements for Nuclear Facility Applications, Subpart 2.7, Quality Assurance Requirements for Computer Software for Nuclear Facility Applications. A representative of Entergy further asked for clarification of this language and how it would apply CONTACT: Joseph A. Golla, NRR/DLP 301-415-1002

to licensees whose QA program is not based on NQA-1. NRC and NEI agreed that the intent of the language is not to require a licensee to update its QA program to meet NQA-1, 2015, but for the licensee to ensure that the vendor executes the DI&C modification project consistent with NQA-1, 2015, Part II, Subpart 2.7. NEI volunteered to discuss this approach with Entergy after the teleconference. NRC and NEI agreed that the language is clear and does not require further revision. NRC staff noted that regulatory guide (RG) 1.28, Quality Assurance Program Criteria (Design and Construction), Revision 5, endorses the 2015 version of NQA-1.

The NRC staff informed NEI that the DI&C-ISG-06 revision project is on track to send a draft to the Advisory Committee on Reactor Safeguards (ACRS) I&C Subcommittee by April17, 2018, in preparation for the May 17, 2018, ACRS Subcommittee meeting.

The NRC informed NEI that several changes had been made to the ISG. Although most changes were editorial in nature, some changes were the result of internal comments received.

NEI asked for clarification on some of the changes made to the draft ISG, in particular:

1. In Section D.2.6.2.4 - NEI asked the staff to consider revising the definition of Defense in Depth and Diversity, in order to avoid a misinterpretation. The staff proposed to modify the definition to read [d]efense in depth and diversity are methods that can be used to protect against common cause failures.

2. In Section B.1.3 - NEI asked the staff to consider adding back a sentence that was removed regarding the scope of the LAR. The staff made note of this comment.

3. In section B.1.3 - NEI asked for clarification on the addition of a paragraph which describes other review areas that may be applicable to the LAR review (e.g., human factors engineering). NEI had no concerns with the language added after the clarification.

4. In Section B.1.3 - NEI asked for clarification on the removal of a sentence that referenced IEEE standards and their respective RGs. NEI had no concerns with the removed sentence after the clarification.

5. In Section B.1.1 - NEI asked for clarification of a sentence that addresses the information necessary to support the staff review. The words information necessary had replaced the words types of documentation or level of detail. The staff explained that the new language was cleaner, however, NEI asked to staff to consider revising the language in order to convey the scalability of the review process. The staff made note of this comment.

6. In Section D.2.2.2 - NEI asked for clarification on the use of conform vs comply. The staff explained that conformance is used when referring to guidance, while compliance is used when referring to regulations. NEI had no further comments.

7. In Section C.1, Tier 3 description - NEI asked the staff to consider the language used to identify the ISG sections that apply to Tiers 1, 2 and 3. The staff made note of this comment.

8. In Section D.8.2 - NEI asked the staff to consider if the editorial changes made to the last paragraph maintain the intent of the original language. The staff made note of this comment.

9. NEI asked the staff to consider removing the use of pronouns (e.g., they) which could reduce the clarity of the language in the ISG. The staff made note of this comment.

In preparation for a planned table top exercise on June 13-14, 2018, NEI provided a proposed table of activities (ADAMS Accession No. ML18095A694). The table identifies certain DI&C-ISG-06 sections, content and the individual(s) that will be leading that portion of the table top exercise. Due to time constraints, NRC and NEI were not able to discuss the contents of

the table during the teleconference. NRC and NEI made note to discuss the table during the next public teleconference.

At the end of the meeting, NRC and NEI identified the following agenda topics for the April 12, 2018 public teleconference:

1. Discussion and clarification of further changes to the ISG draft

2. Discussion of table top exercise activities No member of the public provided a comment.

No actions were identified during the meeting.

Meeting Participants Rich Stattel, NRC Samir Darbali, NRC Deanna Zhang, NRC Joseph Golla, NRC Michael Waters, NRC Brian Thomas, NRC Ronaldo Jenkins, NRC Aaron Armstrong, NRC Warren Odess-Gillett, NEI Pareez Golub, Excel Services Dave Herrell, MPR Rob Burg, Engineering Planning and Management, Inc.

Jana Bergman, Scientech Mark Burzynski, Rolls Royce Nuclear Don Chase, Scientech Gordon Clefton, DOE/INL John Conly, Certrec Corporation Jana Bergman, Curtiss Wright

ML18107A049

• via e-mail OFFICE DLP/PLPB/PM DE/EICB/BC*

RES/DE/ICEEB*

NAME JGolla MWaters RJenkins DATE 5/2/2018 4/27/2018 4/20/2018 OFFICE NRO/DEI/ICE*

DLP/PLPB/BC DLP/PLPB/PM NAME IJung DMorey JGolla DATE 4/24/2018 5/2/2018 5/3/2018