Text

June 26, 2019 Public Meeting Summary Re BTP 7-19
	ML19277H160
Person / Time
Issue date:	10/11/2019
From:	Tekia Govan; NRC/NRR/DIRS/IRGB
To:	Ronaldo Jenkins, Wendell Morton, Nancy Salgado; Division of Engineering, NRC/NRR/DE/EICA
	Govan T, 415-6197, NRR/DIRS
References
	Download: ML19277H160 (5)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 11, 2019 MEMORANDUM TO:

Nancy L. Salgado, Chief Instrumentation and Controls Branch (A)

Division of Engineering Office of Nuclear Reactor Regulation Wendell Morton, Acting Chief Instrumentation and Controls Branch (B)

Division of Engineering Office of Nuclear Reactor Regulation Ronaldo V. Jenkins, Chief Instrumentation, Controls and Electrical Engineering Branch Division of Engineering Office of Nuclear Regulatory Research FROM:

Tekia V. Govan, Project Manager /RA/

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

SUBJECT:

SUMMARY

OF THE PUBLIC MEETING ON THE INTEGRATED ACTION PLAN TO MODERNIZE INSTRUMENTATION AND CONTROLS REGULATORY INFRASTRUCTURE: MODERNIZATION PLAN #1D, REVISION TO BRANCH TECHNICAL POSITION 7-19 HELD ON JUNE 26, 2019 On June 26, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 public meeting with the Nuclear Energy Institute (NEI) and the nuclear industry to discuss Modernization Plan #1D, to revise Branch Technical Position (BTP) 7-19, Guidance for Evaluation of Diversity and Defense-In-Depth in Digital Computer-Based Instrumentation and Control Systems, Revision 7 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16019A344). This topic was discussed in the NRCs Integrated Action Plan to Modernize Digital Instrumentation and Controls Regulatory Infrastructure, Revision 3, updated January 2019 (ADAMS Accession No. ML19025A312).

CONTACT: Tekia V. Govan, NRR/DIRS (301) 415-6197

N. Salgado, et al.

Prior to this meeting, NEI provided the NRC staff with comments on the draft BTP 7-19, Revision 7 (ADAMS Accession Nos. ML19135A401 and ML19171A021). The staff reviewed this information and developed questions regarding the document to be discussed during the meeting.

Meeting Summary NRC and industry management made brief opening remarks, and all attendees introduced themselves.

The NRC staff presented their approach to address the areas of concern identified by NEI (references provided above) as well as focus areas where the staff has identified the need for improvement in the current version on BTP 7-19 (ADAMS Accession No. ML19171A023). The staff discussed the path forward regarding general topic areas such as clarifying the applicability of BTP 7-19 to Title 10 of the Code of Federal Regulation (10 CFR) 50.59 and the proposed new risk-informed graded approach and the resolving comments with the definitions of A1 systems in the proposed graded approach.

Industry stakeholders expressed concerns about the NRC staffs approach regarding potential spurious actuation evaluation criteria. Industry stated that there is a potential for this analysis to become unbounded due to the possible combinations of failures that could occur. The NRC staff provided additional discussion on its intention to simplify and clarify what is necessary for an adequate determination of safety. This was also discussed by way of a proposed acceptance criteria to address industrys concerns. However, the discussion on this topic ended with the NRCs documenting industrys concern and a recommendation for further public interactions on this topic at the next BTP 7-19 public meeting.

The NRC staff provided some general insights into the comments provided by NEI and provided status to each comment to inform the industry which comments required further clarification from industry. During this discussion, the following clarifications were made:

Industry clarified that they were looking for additional flexibilities to address Point 3 of Item II.Q of Staff Requirements Memorandum to SECY 93-087.

Industry stated that they were looking for language that could serve as a placeholder for future methodologies that could be submitted to the NRC staff for endorsement in addressing digital common-cause failure and that the potential methodologies would be targeted to A1 systems associated with a graded approach.

In terms of strategies such as FLEX, industry clarified that it was only seeking additional flexibilities as part of an overall strategy as described in potential D3 assessment.

The NRC staff engaged in discussion to understand the comments provided for each of the above topics. However, the NRC staff made no decisions or took no agency positions during this meeting.

This meeting was transcribed. The official meeting transcript can be found under ADAMS Accession No. ML19275E802.

N. Salgado, et al.

Conclusion At the end of the meeting, NRC and industry management gave closing remarks. NEI expressed appreciation for the open dialogue and willingness of the NRC staff to hear industry views.

The enclosure provides the attendance list for this meeting.

Enclosure:

As stated

ML19277H160 *via e-mail OFFICE NRR/DIRS/IRGB/PM NRR/DIRS/IRGB/OLA* NRR/DE/EICB/TR*

NAME TGovan IBetts WMorton DATE 10/04/2019 10/10/2019 10/11/2019

Enclosure LIST OF ATTENDEES INTEGRATED ACTION PLAN TO MODERNIZE INSTRUMENTATION AND CONTROLS REGULATORY INFRASTRUCTURE: MODERNIZATION PLAN #1D, REVISION TO BRANCH TECHNICAL POSITION 7-19 June 26, 2019, 9:00 AM to 12:30 PM Teleconference ATTENDEE ORGANIZATION

1. Paul Rebstock NRC

2. Deanna Zhang NRC

3. Paul Kallan NRC

4. Steven Arndt NRC

5. David Desaulniers NRC

6. Robert Beaton NRC

7. Eric Benner NRC

8. Wendell Morton NRC

9. Tekia Govan NRC

10. Maxine Segarnick NRC

11. Rossnyev Alvarado NRC

12. Steve Vaughn NEI