ML19297G592

Rev 2 Public Meeting Summary, September 18, 2019

ML19297G592
Person / Time
Issue date:	10/28/2019
From:	Tekia Govan NRC/NRR/DRO/IRSB
To:	Philip Mckenna NRC/NRR/DRO/IRSB
Govan T, 415-6197, NRR/DRO
References
Download: ML19297G592 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 28, 2019 MEMORANDUM TO: Philip J. McKenna, Chief Oversight and Support Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM: Tekia V. Govan, Project Manager /RA/

Oversight and Support Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUMMARY

OF THE PUBLIC MEETING ON THE DRAFT REGULATORY GUIDE 1.187, REVISION 2, THAT ENDORSES NUCLEAR ENERGY INSTITUTE 96-07, APPENDIX D, HELD ON SEPTEMBER 18, 2019 On September 18, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 public meeting with the Nuclear Energy Institute (NEI) to discuss the usability of NEI 96-07, Appendix D, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18338A389), as endorsed by draft Regulatory Guide (RG) 1.187, Revision 2, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments (ADAMS Accession No. ML19045A435).

Background

The NRC staff issued for public comment draft RG 1.187, Revision 2, that will provide guidance on complying with the requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.59 when performing a digital instrumentation and controls (digital I&C) modification.

Specifically, NEI 96-07, Appendix D, Revision 0, was submitted to the NRC on November 30, 2018. As discussed in Section C of RG 1.187, the staff endorses NEI 96-07 and finds that it provides an acceptable approach for the application of 10 CFR 50.59 guidance when conducting digital I&C modifications, with certain exceptions and clarifications.

Draft RG 1.187, Revision 2, was issued for public comment to facilitate the Commissions direction in the Staff Requirements Memorandum (SRM)SECY-16-0070, Staff RequirementsSECY-16-0070 Integrated Strategy to Modernize the Nuclear Regulatory Commissions Digital Instrumentation and Control Regulatory Infrastructure (ADAMS Accession No. ML16299A157). The NRC staff has engaged the public, NEI, and industry CONTACT: Tekia V. Govan, NRR/DRO (301) 415-6197

P. McKenna 2 representatives to improve the guidance for applying 10 CFR 50.59 to digital I&C-related design modifications as part of a broader effort to modernize the regulatory infrastructure for digital I&C.

This meeting, on September 18, 2019, served as an additional opportunity to engage the public and the nuclear industry prior to the final evaluation of the public comments received and issuance of RG 1.187, Revision 2.

Meeting Summary The NRC and industry management made brief opening remarks, and introductions were made by all in attendance. The NRC staff presented the background for the submittal of NEI 96-07, Appendix D and its documented draft endorsement in RG 1.187, Revision 2 (ADAMS Accession No. ML19260F165). The presentation continued with a discussion on a list of topics, developed by the NRC staff, where additional clarification was needed to address NEIs comments on draft RG 1.187, Revision 2 (ADAMS Accession No. ML19198A323). The NRC staff developed a tracked change version of NEI 96-07, Appendix D, to assist in demonstrating how the guidance could be revised to address the staffs proposed exception in draft RG 1.187, Revision 2 and to meet the intent of supplemental guidance for digital I&C modifications (ML19260E543).

During this meeting the NRC staff also discussed the proposed exemption in RG 1.187, Revision 2, in that NEI 96-07, Appendix D, Section 4.3.6 (ADAMS Accession No. ML19254E467) should determine whether the impact of the SSC malfunction has a different result than any previously evaluated in the final safety analysis report, as updated, instead of a different result than previously evaluated in the safety analysis.

The NRC staff did not make any decisions or took any agency positions during this meeting.

The enclosure provides the attendance list for this meeting.

Conclusion The meeting concluded with NEI stating that they would take into consideration the discussion with the NRC staff and review the staffs tracked change version of NEI 96-07, Appendix D. NEI will then inform the NRC of its next steps that may include, but are not limited to, providing a revision 1 to NEI 96-07, Appendix D.

Enclosure:

As stated

ML19297G592 *= via email OFFICE NRR/DRO/IRSB/PM* NRR/DRO/IRSB* NRR/DRO/IRSB/BC*

NAME TGovan BCurran PMcKenna DATE 10/24/2019 10/28/2019 10/28/2019 LIST OF ATTENDEES

SUMMARY

OF THE PUBLIC MEETING ON THE DRAFT REGULATORY GUIDE 1.187, REVISION 2 THAT ENDORSES NUCLEAR ENERGY INSTITUTE 96-07, APPENDIX D September 18, 2019, 1:00 PM to 4:00 PM NRC One White Flint North 11555 Rockville Pike O-9B04 Rockville, MD ATTENDEE ORGANIZATION

1. Rossnyev Alvarado NRC

2. Pete LeBlond LeBlond and Associates

3. Kate Austgen NEI

4. Phil Couture Entergy

5. Steven Arndt NRC

6. Maxine Segarnick NRC

7. Ray Herb Southern Nuclear

8. Paul Kallan NRC

9. Jana Bergman Curtiss-Wright

10. Steve Geier NEI

11. Bob Weisman NRC

12. Phil McKenna NRC

13. Neil Archambo Duke Energy

14. Norbert Carte NRC

15. Eric Benner NRC

16. Dave Beaulieu NRC

17. Manuel Crespo NRC

18. Nancy Salgado NRC Enclosure

P. McKenna 19. Robert Roche-Rivera NRC

20. Jon Rund NEI

21. Richard Stattel NRC

22. Wendell Morton NRC

23. Sheldon Clark NRC

24. Ismael Garcia NRC

25. Christina Antonescu NRC

26. John Hernandez Palo Verde

27. Tekia Govan NRC