ML20083F149
| ML20083F149 | |
| Person / Time | |
|---|---|
| Site: | 99902028 |
| Issue date: | 07/06/2020 |
| From: | Joseph Holonich Licensing Processes Branch |
| To: | Dennis Morey Licensing Processes Branch |
| Holonich J | |
| References | |
| EPID L-2017-PMP-0009 | |
| Download: ML20083F149 (4) | |
Text
July 6, 2020 MEMORANDUM TO: Dennis C. Morey, Chief Licensing Processes Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Joseph J. Holonich, Senior Project Manager /RA/
Licensing Processes Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF APRIL 1, 2020, MEETING TO DISCUSS DIGITAL INSTRUMENTATION AND CONTROL, INTEGRATED ACTION PLAN, MODERNIZATION PLAN #3, ACCEPTANCE OF DIGITAL EQUIPMENT, NUCLEAR ENERGY INSTITUTE 17-06 (EPID L-2017-PMP-0009)
On April 1, 2020, U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 meeting with representatives from the Nuclear Energy Institute (NEI). The purpose of the meeting was to discuss the Digital Instrumentation and Control (I&C), Integrated Action Plan (IAP),
Modernization Plan #3 (MP #3), Acceptance of Digital Equipment, and discuss resolution of staff comments provided on NEI 17-06, Revision B, Guidance on Using IEC [International Electrotechnical Commission]-61508 SIL [Safety Integrity Level] Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications.
The agenda and all information related to the meeting and discussed in this summary can be found in the Agencywide Documents Access and Management System Package Accession No. ML20076A584.
In its opening remarks, NEI representatives stated that it was planning to respond to the NRC staff comments on draft NEI 17-06, Revision B, and was looking to discuss the plans for endorsement of NEI 17-06.
The NRC staff opened the meeting by explaining that previous discussions with NEI were related to a proposal for the nuclear industry to use the dependability and reliability information that can be derived by third-party certifiers in a commercial grade dedication process. The NRC staff also understood that an industry-led organization like the Nuclear Utility Procurement Issues Committee would be performing periodic oversight of the certifying body using IEC-61508, Functional Safety of Electrical/Electronic/Programmable Electronic Safety-related Systems (E/E/PE, or E/E/PES), evaluation process. However, it appears now that this CONTACT: Joseph J. Holonich, NRR/DORL (301) 415-7297
D. Morey proposed process had changed, such that the periodic oversight would be covering the certifiers conformance to IEC-17065, Conformity Assessment Requirements for Bodies Certifying Products, Processes and Services, only.
Also, the NRC staff said that its previous comments were related to the plan described in NEI 17-06 as discussed in earlier public meetings. However, since the plan now appears to have changed, the staff did not have a basis for preparing formal written comments.
NEI representatives made a presentation on the quality assurance (QA) aspects of SIL certifications. Throughout the presentation, the NRC staff asked numerous questions. One concern raised by the NRC staff was that until recently the focus was on QA but now there was also a question about the technical aspects. The NRC staff requested a clear understanding of the relationship of these two aspects, in order to endorse NEI 17-06.
Another concern raised by the NRC staff about the SIL certification process was access to information used in the certification. The NRC staff noted that original equipment manufacturers (OEMs) may not share internal information. For an industry oversight observation of a SIL certifier, it would be necessary to have that information available.
The discussion continued by the NRC staff noting that NEI 17-06 needed to ensure the process to be followed was clear when a SIL certified product was purchased by the licensee. Also, the NRC staff explained that NEI 17-06 needed to make clear it was relying solely on the SIL certification for Electric Power Research Institute (EPRI) 106439 dependability characteristics, and that other OEM information may be needed for other critical characteristics in the commercial dedication process. This was considered a gap that needed to be closed in NEI 17-06. The NEI representatives explained where this is described in NEI 17-06. As a result of these discussions an action for both the NRC staff and NEI representatives was to independently caucus internally and consider what would be the best way to move forward.
It was also noted that these discussions were expected to develop material that would be sufficient to submit a next draft of NEI 17-06. The NEI representatives expressed a desire that the NRC staff provide its IEC-17065 observation notes to aid in NEI addressing the remaining NRC staff issues.
The NEI representatives expressed a desire for the NRC to share, in writing, the concerns about their accrediting body observations and to obtain specific comments on the draft NUPIC checklist to assist the industry in addressing the NRC questions. The NRC staff responded that nothing had been formally provided for endorsement. Hence, this effort was not in a formal endorsement process, so it was not possible to provide detailed comments on a changing draft document. In addition, the NRC staff explained that in its review of NEI 17-06, it was not clear how commercial grade dedication and SIL certification would be used.
The NEI representatives explained that the intent of NEI 17-06 was for it to be used by a licensee personnel not familiar with IEC-61508 SIL certification process. The NEI representatives pointed out where this process is explained in NEI 17-06. The NEI representatives agreed to take an action to make sure it was clear how the processes would be used.
Another action taken by the NEI representatives was to consider augmenting the NEI 17-06 observation checklist which is currently based on IEC-17065.
D. Morey At the end of the discussions, stakeholder input was solicited. A representative of the United Kingdom (UK) regulatory body Office for Nuclear Regulation stated that the meeting was very relevant to the UK.
In closing, the NRC staff noted that there was a lot of information presented in the meeting that was not included in the drafts of NEI 17-06. The NEI representatives stated that based on the meeting it needed to adjust the schedule provided in the meeting briefing slides. It was agreed that another meeting was needed before the formal submittal would be made. June 2020 was identified as a potential time frame for the next meeting.
Actions from the meeting were:
- 1) The NRC staff and NEI representatives to independently caucus internally and consider what would be the best way to move forward;
- 2) The NEI representatives agreed to make sure it was clear how the NEI 17-06 processes would be used;
- 3) The NEI representatives will consider augmenting the NEI 17-06 observation checklist to address NRC observation concerns; and
- 4) Another meeting will be scheduled when NEI submits a subsequent draft revision of NEI 17-06 in June 2020.
Docket No. 99902028
Package: ML20076A584 Summary: ML20083F149 *concurrence via e-mail OFFICE NRR/DORL/LLPB/PM* NRR/DORL/LLPB/LA* NRO/DE/EICA/BC*
NAME JHolonich DHarrison BVenkataraman DATE 04/02/2020 07/01/2020 04/29/2020 OFFICE NRR/DORL/LLPB/BC* NRR/DORL/LLPB/PM*
NAME DMorey JHolonich DATE 04/28/2020 07/06/2020