ML19226A110
| ML19226A110 | |
| Person / Time | |
|---|---|
| Site: | 99902028 |
| Issue date: | 09/09/2019 |
| From: | Joseph Holonich NRC/NRR/DLP/PLPB |
| To: | Dennis Morey NRC/NRR/DLP/PLPB |
| Holonich J, NRR/DLP, 415-7297 | |
| References | |
| Download: ML19226A110 (4) | |
Text
September 9, 2019 MEMORANDUM TO: Dennis C. Morey, Chief Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation FROM: Joseph J. Holonich, Senior Project Manager /RA/
Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF AUGUST 21, 2019, MEETING TO DISCUSS THE NUCLEAR PROCUREMENT ISSUES CORPORATION PROCESS AND THE PLANS FOR NUCLEAR ENERGY INSTITUTE 17-06 On August 21, 2019, U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 teleconference with representatives from the Nuclear Energy Institute (NEI). The purpose of the teleconference was to discuss the Nuclear Procurement Issues Corporation (NUPIC) observation process for Safety Integrity Level (SIL) and the plans for NEI 17-06, Guidance on Using IEC 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications. All information related to the meeting and discussed in this summary can be found in the Agencywide Document Access and Management System Package Accession No. ML19184A039.
In opening its discussions, NEI stated that Modernization Plan #3, Acceptance of Digital Equipment, of the Integrated Action Plan to Modernize Digital Instrumentation and Controls Regulatory Infrastructure, Revision 3, supports the use of safety-proven products from qualified industries other than the nuclear industry. NEI continued by stating that now that the Electric Power Research Institute (EPRI) had completed its work on the SIL certification research report, the finalization of NEI 17-06 was the next step.
The first portion of the meeting covered the draft NUPIC document, SIL Certification Accreditation Body Oversight. During these discussions, the NRC staff asked if NUPIC would be observing the accrediting bodies (ABs) in the US and Germany. Industry stated it was working with the US AB and invited the NRC staff to attend the observations. An action from the meeting was for NEI to provide the NRC staff with the dates once the observations were scheduled.
In response to a second NRC staff question, industry clarified that this NUPIC document was a stand-alone document and would not be a part of NEI 17-06. However, the AB oversight process is summarized in Section 5, Suppliers Quality Assurance Program. Industry also stated that this stand-alone document would not have any impact on other NUPIC documents.
CONTACT: Joseph J. Holonich, NRR/DLP 301-415-7297
D. Morey The second part of the meeting covered draft NEI 17-06, Rev. A. In this part, NEI discussed the content of NEI 17-06, Rev. A and the anticipated schedule. An advanced copy of NEI 17-06, Rev. A was provided prior to the meeting. The staff offered several comments on NEI 17-06, Rev. A. These included:
- Section 5.2, first sentence; make clear NUPIC is not the accrediting body;
- Page 10, first paragraph; include testing in the discussion;
- Page 17 discusses what component a certifying body approves or rejects. Because some components may have general certification but not address nuclear plant environments, a third option should be certification for nuclear use of generally certified components.
- Look at the use of approval versus accept; and
- Clarify the flowchart in the NEI meeting presentation when it is included in NEI 17-06.
NEI took an action to consider these comments in the preparation of NEI 17-06.
Another question asked by the NRC staff was the service life of a certified component versus the life of a SIL certificate. The NRC staff offered an example that a component could degrade faster than anticipated and sooner than the life of the certificate. NEI explained that once a SIL certified device is installed in the plant, there is no service life expiration unless specified in the safety manual for the device. The expiration only applies to the certification of the product.
Upon or before expiration the OEM must pursue a certification renewal process for the product to evaluate any changes to the product or processes. NEI took an action to consider including additional information in NEI 17-06.
The NRC staff noted during these discussions that the EPRI report was listed as completed on the NEI 17-06 schedule. However, the copy NRC staff saw via the EPRI reading room did not have any markings indicating it was final. EPRI took an action to look to see why there was a difference between the published and reading room versions of its report. NRC staff took an action on procuring the EPRI report.
At the close of the discussion NEI stated it would like to have a public interaction with the NRC staff towards the end of October 2019. NEI would provide a draft NEI 17-06, Rev. B by the end of September 2019 to support the meeting. An action was for NEI to provide the NRC staff with some viable dates for the meeting.
NEI asked the staff how it plans to endorse NEI 17-06, should the NRC staff decide to endorse NEI 17-06. The NRC staff said it had not yet determined the approach should it decide to endorse NEI 17-06. There was an NRC staff action to inform interested parties the approach it would use to endorse NEI 17-06 should the NRC staff decide to endorse it.
During the stakeholder agendum, a question was asked about the relationship of the SIL to General Electric (GE). The NRC staff explained that the SIL discussed here was Safety Integrity Level. GE SIL is Services Information Letter and is provided to GE reactor owners.
The member of the public was happy with the explanation and thanked the staff.
Following the meeting a stakeholder emailed several questions to the NRC staff. NEI provided responses to those questions. A copy of the email can be found in the meeting package.
In the closing remarks, NEI stated that, as the NRC staff reviews the draft NEI 17-06, Rev. A and needs clarification discussions, industry could support holding one or more publicly-noticed
D. Morey calls before the October meeting. NRC staff agreed a meeting action was to contact NEI if the NRC staff determined such calls were needed.
Actions from the meeting included:
- 2) NEI will consider the clarifying comments from the NRC staff;
- 3) NEI will consider including a discussion of certificate life versus service life;
- 4) EPRI will investigate the difference between the published and reading room version of its report;
- 5) NRC staff will look at procuring the EPRI report;
- 6) NEI will provide the NRC staff with some potential dates for an October 2019 meeting;
- 7) NRC staff will report the endorsement approach should it decide to endorse NEI 17-06; and
- 8) NRC staff will contact NEI if calls are needed before the October 2019 meeting.
Docket No.: 99902028
ML19226A110, Summary ML19184A039, Package *concurrence via e-mail NRC-001 OFFICE DLP/PLPB/PM NRO/DE/EICA/BC* DLP/PLPB/BC DLP/PLPB/PM NAME JHolonich* NSalgado* DMorey JHolonich DATE 09/3/2019 08/30/2019 09/5/2019 09/9/2019