ML19106A187
| ML19106A187 | |
| Person / Time | |
|---|---|
| Issue date: | 04/17/2019 |
| From: | Tekia Govan NRC/NRR/DIRS/IRGB |
| To: | Tara Inverso Division of Inspection and Regional Support |
| Govan T | |
| References | |
| Download: ML19106A187 (6) | |
Text
April 17, 2019 MEMORANDUM TO: Tara Inverso, 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
SUBJECT:
SUMMARY
OF A CATEGORY 2 PUBLIC MEETING HELD WITH EXTERNAL STAKEHOLDERS TO DISCUSS LESSONS LEARNED AFTER THE ISSUANCE OF REGULATORY ISSUE
SUMMARY
2002-22, SUPPLEMENT 1, CLARIFICATION ON ENDORSEMENT OF NUCLEAR ENERGY INSTITUTE GUIDANCE IN DESIGNING DIGITAL UPGRADES INSTRUMENTATION AND CONTROL SYSTEMS On February 27, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 public meeting with external stakeholders in Rockville, Maryland. The purpose of the meeting was to discuss lessons learned after the issuance of Regulatory Issue Summary (RIS) 2002-22, Supplement 1, Clarification on Endorsement of Nuclear Energy Institute Guidance in Designing Digital Upgrades in Instrumentation and Control Systems, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18143B633).
Meeting Summary NRC and industry management made brief opening remarks, and introductions were made by all in attendance. The NRC staff presented an overview of RIS 2002-22, Supplement 1 (ADAMS Accession No. ML19056A537). As part of this presentation, the NRC staff provided examples of digital modifications that the industry can conduct without prior NRC approval using a qualitative assessment. Specifically, the NRC staff provided an example of the replacement of an existing emergency diesel generator voltage regulator being replaced with a digital reference adjuster, as a component that could be modified under 10 Code of Federal Regulations (CFR) 50.59 using the guidance provided in RIS 2002-22, Supplement 1.
The Nuclear Energy Institute (NEI) made a presentation that provided an industry perspective on the use of RIS 2002-22, Supplement 1, since its issuance in May 2018 (ADAMS Accession No. ML19056A533). NEI provided some areas that they believed licensees could improve to ensure the success of digital modifications under 10 CFR 50.59, such as:
CONTACT: Tekia V. Govan, NRR/DIRS 301-415-6197
T. Inverso
- 10 CFR 50.59 screening and evaluation questions associated with digital plant changes;
- documentation and explanation of why the design has a low likelihood of failure; and
- industry working together and sharing information regarding digital project designs.
NEI also discussed the expectation of implementing digital modifications, such as diesel generator controls, turbine and feedwater controls, and digital inverters in 2019 through 2020.
Specifically, Dominion Energy plans to use RIS 2002-22, Supplement 1, for a digital modification in the switchyard. Dominion Energy noted that this modification was recently inspected during a NRC Region 1 triennial modifications team inspection.
NextEra Energy provided a presentation on their use of RIS 2002-22, Supplement 1, to develop draft qualitative assessment documentation for the replacement of an analog rod control system with the Westinghouse advanced rod control hybrid digital control system with ovation-based logic and upgrading the existing ovation main turbine control system (ADAMS Accession No. ML19056A528). This draft qualitative assessment followed the RIS to determine that common cause failure is sufficiently low given design features and operating experience with the system.
Through the development of this draft qualitative assessment, NextEra determined that the use of operating experience is essential in the process but has some challenges when attempting to comply with the RIS. NextEra noted that they will be conducting a fleet-wide training on RIS 2002-22, Supplement 1, led by Duke Energy staff. NRC staff has been invited to provide a RIS overview at this meeting via teleconference.
Both NEI and NextEras presentations contained positive comments on the usability of RIS 2002-22, Supplement 1, with the expectation of implementing digital modifications, in 2019 through 2020. Because of this RIS, industry has cited a better understanding of NRCs expectations for qualitative assessment and a significant reduction in the level of details to respond to 10 CFR 50.59 evaluation questions.
The meeting concluded with external stakeholder questions regarding the timing of the next NRC guidance document for digital modifications. The endorsement of NEI 96-07, Appendix D, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications is expected to be issued by the NRC staff in July 2019. The NRC staff is also working with the nuclear industry to develop revised technical guidance for addressing common cause failure as documented in NRC Branch Technical Position 7-19.
The NRC staff made no decisions or took any agency positions during this meeting.
Enclosures:
- 1. Meeting Agenda
- 2. List of Attendees
T. Inverso
SUMMARY
OF A CATEGORY 2 PUBLIC MEETING HELD WITH EXTERNAL STAKEHOLDERS TO DISCUSS LESSONS LEARNED ATFER THE ISSUANCE OF REGULATORY ISSUE
SUMMARY
2002-22, SUPPLEMENT 1, CLARIFICATION ON ENDORSEMENT OF NUCLEAR ENERGY INSTITUTE GUIDANCE IN DESIGNING DIGITAL UPGRADES INSTRUMENTATION AND CONTROL SYSTEMS Date: April 17, 2019 ADAMS ACCESSION Nos.: ML19106A187 OFFICE NRR/DIRS/IRGB/PM NRR/DIRS/IRGB/LA NRR/DIRS/IRGB/TR NRR/DIRS/IRGB/BC NRR/DIRS/IRGB/PM NAME TGovan BCurran *w/edits PMcKenna *w/edits TInverso TGovan DATE 04/16/2019 04/16/2019 04/17/2019 04/17/2019 04/17/2019 OFFICIAL RECORD COPY
PUBLIC MEETING AGENDA
Category 2 meeting to discuss the Regulatory Issue Summary 2002-22, Supplement 1, Lessons Learned February 27, 2019, 09:00 AM to 02:00 PM NRC Three White Flint North, 1-C03 11601 Landsdown Street Rockville, MD Time Topic Lead 9:00 a.m. Meeting Introductions and Opening Remarks NRC/Industry 9:20 a.m. NRC Overview of RIS 2002-22, Supplement 1 P. McKenna, NRC 10:20 a.m. Break 10:30 a.m. NEI Perspective and Examples using N. Archambo, RIS 2002-22, Supplement 1 Duke Energy 12:00 p.m. Lunch 1:00 p.m. Digital Modifications and Preparing for the W. Frewin, NextEra 10 CFR 50.59 Review 1:45 p.m. Public Comments 2:00 p.m. Closing Remarks/Meeting Adjourned Enclosure 1
LIST OF ATTENDEES Category 2 meeting to discuss the Regulatory Issue Summary 2002-22, Supplement 1, Lessons Learned February 27, 2019, 09:00 AM to 02:00 PM NRC Three White Flint North, 1-C03 11601 Landsdown Street Rockville, MD Name Organization
- 1. Jana Bergman Curtiss-Wright
- 2. Matthew Shakur Westinghouse
- 3. Steve Vaughn NEI
- 4. Wesley Frewin NextEra Energy
- 5. Rossnyev Alvarado NRC
- 6. Paul Phelps Dominion Energy
- 7. Phil McKenna NRC
- 8. Chris Miller NRC
- 9. Perry Buckberg NRC
- 10. Eric Bowman NRC
- 11. David Rahn NRC
- 12. Neil Archambo Duke Energy
- 13. Jerud Hanson INL
- 14. Dan Stoodard Dominion Energy
- 15. Steven Arndt NRC
- 16. Eric Benner NRC
- 17. Michael Waters NRC
- 18. Dave Beaulieu NRC
- 19. Wendell Morton NRC Enclosure 2
- 20. Tekia Govan NRC Participated via conference line and webinar
- 21. Dave Heinig Sargent and Lundy
- 22. Daniel Colburns Dominion Energy
- 23. Rob Burg Engineering Planning and Management
- 24. Eric Bernard MPR Associates
- 25. Michael Bailey Bailey Engineering Services
- 26. William Barasa Sargent and Lundy
- 27. William Sotos Certrec
- 28. Michael Sortwell AEP
- 29. John Connelly Exelon
- 30. Daniel Cronin University of Florida - Training Reactors
- 31. Dan Ferman Member of the public
- 32. Warren Garnett Member of the public
- 33. Maria Start Member of the public
- 34. Joseph Holonich NRC
- 35. John Troday Member of the public
- 36. Ismael Garcia NRC
- 37. Ty Rogers GE
- 38. Donald Chase Curtiss Wright
- 39. Frank Mascitelli Exelon
- 40. Mark Burzynski Rolls Royce