ML18333A057

NEI 96-07 Appendix D Meeting Summary 11-14-2018

ML18333A057
Person / Time
Issue date:	12/20/2018
From:	Tekia Govan NRC/NRR/DIRS/IRGB
To:	Bo Pham NRC/NRR/DIRS/IRGB
Govan T
References
Download: ML18333A057 (6)

Text

December 20, 2018 MEMORANDUM TO: Bo M. Pham, Chief ROP Support and Generic Communications Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation FROM: Tekia V. Govan, Project Manager /ra/

ROP Support and Generic Communications Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation

SUMMARY

OF A CATEGORY 2 PUBLIC MEETING HELD WITH THE NUCLEAR ENERGY INSTITUTE TO PROVIDE AN OPPORTUNITY TO DISCUSS THE STATUS OF THE U.S. NUCLEAR REGULATORY COMMISSION STAFFS REVIEW OF THE DRAFT NEI 96-07, APPENDIX D On November 14, 2018, the U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 public meeting with the Nuclear Energy Institute (NEI) in Rockville, Maryland. The purpose of the meeting was to discuss the status of the draft NEI 96-07, Appendix D, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications, which is being developed to assist licensees in the performance of 10 CFR 50.59 reviews for activities involving digital modifications. This meeting provided an opportunity for NRC staff and NEI to discuss the current draft of NEI 96-07, Appendix D.

Background

On July 16, 2018, NEI submitted to the NRC, NEI 96-07, Appendix D, Revision 0f (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18199A647) for comments. To support the discussion of this Category 2 meeting, the NRC staff made its comments on NEI 96-07, Appendix D publically available (ADAMS Accession No. ML18235A165). On August 30, 2018, September 11, 2008, and October 11, 2018, the NRC staff held Category 2 public meetings with NEI to discuss the Appendix D comments. The results of these meeting discussions were documented in meeting summaries that captures CONTACT: Tekia V. Govan, NRR/DIRS 301-415-6197

B. Pham NEIs position, NRC clarifications, and NRC action items for each comment (ADAMS Accession Nos. ML18283A903, ML18282A044, and ML18298A295). On October 26, 2018, NEI submitted to the NRC, NEI 96-07, Appendix D, Revision 0g (ADAMS Accession No. ML18310A433),

which incorporates the NRC staffs comments as documented in the mentioned meeting summaries.

Meeting Summary The NRC made brief opening remarks, and introductions were made by all in attendance. Prior to this public meeting, the NRC staff made publically available a chart that documented the NRC staffs final comments on NEI 96-07, Appendix D, Revision 0g (ADAMS Accession No. ML18311A360). During the meeting, NRC staff discussed with NEI specific comments where it was apparent that there was not alignment between NEIs intent and the NRC staffs read of the NEI 96-07, Appendix D language. Through the discussions, at this and previous meetings, NRC staff and NEI were able to align and resolve approximately 90 percent of the NRC staffs comments. However, the staff and NEI did not reach alignment regarding guidance for evaluating against 10 CFR 50.59(c)(2)(vi). Specifically, Section 4.3.6 of NEI 96-07, Appendix D, generally focuses on the safety analysis result impact rather than the malfunction result impact, which is contrary to the NRC staffs interpretation of the guidance in NEI 96-07 and of 10 CFR 50.59. Whereas, NEI 96-07, Revision 1, defines safety analysis as including supporting USFAR analyses that demonstrate that structure, system, or component (SSC) design functions will be accomplished as credited in the accident analysis. NEI 96-07, Revision 1, also states that malfunctions of SSCs are postulated as potential single failures at the level of the SSC being modified. Therefore, the NRC staffs position is that Section 4.3.6 of NEI 96-07, Appendix D, should determine the SSC malfunction impact instead of the safety analysis result impact on the facility as a whole. This comment carries through much of Section 4.3.6 of NEI 96-07, Appendix D, including the examples.

Documentation of the NRCs final comments on NEI 96-07, Appendix D, which includes those that have not been resolved, can be found under ADAMS Accession No. ML18330A126.

Meeting Conclusion Although not all of the NRC staffs proposed resolutions were readily accepted by NEI, the results of the meeting were documented for NEIs use as they work to finalize NEI 96-07, Appendix D. This meeting was the final public meeting prior to the submission of NEI 96-07, Appendix D for NRC endorsement. NEI submitted the revised NEI 96-07, Appendix D to the NRC on November 30, 2018 (ADAMS Accession No. ML18338A389).

Enclosure:

1. Meeting Agenda

2. List of Attendees

B. Pham

SUMMARY

OF A CATEGORY 2 PUBLIC MEETING HELD WITH THE NUCLEAR ENERGY INSTITUTE TO PROVIDE AN OPPORTUNITY TO DISCUSS THE STATUS OF THE NRC STAFFS REVIEW OF THE DRAFT NEI 96-07, APPENDIX D, Date: December 20, 2018 ADAMS ACCESSION NO.: ML18333A057 * = concurrence via email OFFICE NRR/DIRS/IRGB/PM NRR/DIRS/IRGB/LA NRR/DIRS/IRGB/BC NRR/DIRS/IRGB/PM NAME TGovan ELee* BPham* TGovan DATE 11/28/2018 11/29/2018 12/19/2018 12/20/2018 OFFICIAL RECORD COPY

PUBLIC MEETING AGENDA

NEI 96-07, APPENDIX D, REVISION 0F, SUPPLEMENTAL GUIDANCE FOR APPLICATION OF 10 CFR 50.59 TO DIGITAL MODIFICATIONS November 14, 2018, 9:30 AM to 4:30 PM NRC One White Flint North, O16-D03 11555 Rockville Pike Rockville, MD Time Topic Speakers 9:30 am Meeting Introductions and Opening Remarks NRC Staff Discussion on the NRC staff's comments on the 9:45 am NRC Staff/NEI draft NEI 96-07, Appendix D 10:45 am Break Discussion on the NRC staff's comments on the 10:55 am NRC Staff/NEI draft NEI 96-07, Appendix D 12:30 pm Lunch Discussion on the NRC staff's comments on the 1:30 pm NRC Staff/NEI draft NEI 96-07, Appendix D 2:30 pm Break Discussion on the NRC staff's comments on the 2:45 pm NRC Staff/NEI draft NEI 96-07, Appendix D 4:00 pm NRC Review Schedule NRC Staff/ NEI 4:15 pm Questions/Comments Members of the public 4:30 pm Adjourn Enclosure 1

LIST OF ATTENDEES NEI 96-07, APPENDIX D, REVISION 0F, SUPPLEMENTAL GUIDANCE FOR APPLICATION OF 10 CFR 50.59 TO DIGITAL MODIFICATIONS November 14, 2018, 9:30 AM to 4:30 PM NRC One White Flint North, O16-D03 11555 Rockville Pike Rockville, MD Name Organization

1. Kati Austgen NEI

2. Neil Archambo Duke Energy

3. Mike King NRC

4. David Beaulieu NRC

5. Peter LeBlond LeBlond and Associates

6. Phil McKenna NRC

7. Wendell Morton NRC

8. Tekia Govan NRC

9. Norbert Carte NRC

10. Jeremy Groom NRC

11. Bo Pham NRC

12. Erick Martinez NRC

13. Stephen Geier NEI

14. David Ramendick David Ramendick Consulting Participated via conference line and webinar

15. Jeremy Chenkovich Dominion Energy

16. Gordon Clefton Member of the public

17. Wesley Frewin FPL Enclosure 2

18. Joe Holonich NRC

19. Ronald Jarrett Westinghouse

20. Warren Odess-Gillett Westinghouse

21. Matthew Shakun Westinghouse

22. Jeff Seiter Entergy

23. Mike Waters NRC