ML20217K594

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Summary of CRGR Meeting 307 on 970623 Re Review & Endorsement of SRP Chapter 7,update, Instrumentation & Controls. List of Attendees Encl
ML20217K594
Person / Time
Issue date: 08/11/1997
From: Ross D
Committee To Review Generic Requirements
To: Callan L
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
NUDOCS 9708150309
Download: ML20217K594 (35)
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7ay August 11, 1997 MEMORANDUM TO: L. Joseph Callon Executive Director for Operations OriginalSigned by:

FROM: Denwood F. Ross, Jr., Chairman D0nwood F Committee to Review Generic Requirements . Ross

SUBJECT:

MINUTES OF THE CRGR MEETING NUMBER 307 The Committee to Review Generic Requirements (CRGR) met on Monday, June 23,1997 from 1:00 p.m. to 4:30 p.m. Attachment 1 contains a list of attendees.

D. Doger (NRR), J. Wormlel (NRR), and M. Chiramal (NRR) presented for CRGR review and endorsement the Standard Review Plan Chapter 7, " Instrumentation and Controls," Update.

The CRGR had previously reviewed the draf t SRP update at the CRGR Meeting No. 292.

The CRGR endorsed the SRP for issuance. Attachment 2 contains details.

B. Boger (NRR), J. Wermlel (NRR), and J. Stewart (NRR) presented for the CRGR review and endorsement the Staff Evaluation Report on EPRI Topical Report, " Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Applications," EPRI TR 100439. The CRGR endorsed the SER for publication subject to minor comments. Attachment 3 contains details.

T. King (RES) and J. Kramer (RES) presented for the CRGR review and endorsement the six proposed final regulatory guides (RG 1.168 through 1.173) for computer sof tware to be used in safety systems of nuclear power plants. The CRGR endorsed the regulatory guide's for issuance subject to minor comments. Attachment 4 contains details.

Questions concerning these m6eting minutes should be referred to Raji Tripathi (415 7684).

Attachments: As stated O f 'f N M

\ 0 / h Y U M / n Qc f) n,s , y cc: Commission (4) .

SECY J. Lieberman, 08; E. Halman, ADM H. Bell, OlG K. Cyr, OGC J. Larkins, ACRS

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Regional Administrators, RI RIV 0. Sheron, NRR /

CRGR Members G. Holahan, NRR Distribution: / ))

File Center (w/attch) PDR (NRC/CRGR) (w/o attch) CRGR SF

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CRGR CF STreby AThadani JMitchell RTripathi BBoger LSpessard JWormiel MChiramal JJoyce JStewart TKing

! .f hf]f SK/ DOCUMENT NAME: S:\CRGR\ MINUTES.307 OFFICIAL RECORD COPY receive a copy of this document. Indicate in the box: 'C' Copy w/o attachment. *E' = Copy w/ attachment. *N' = No copy OFC CRGR,, , DR(p'D' NAME RTripdI$[c DFI)bss DATE 081//97 Odh/97

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,d CRGR Meeting No. 307 Attendance List June 23,1997 CRGR MEMBERS NRC STAFF

1. D. Ross, AEOD 1. B. Boger, NRR
2. F. Miraglia, NRR 2. J. Wermlel, NRR
3. J. Murphy, RES 4. M. Chiramal, NRR
4. M. Knapp, NMSS 5. J. Joyce, NRR
5. D. Dambly, OGC .
6. J. Stewart, NRR
0. J. Dyer, RIV 7. T. King, RES
8. J. Kramer, RES CRGR STAFF 9. J. Persensky, NRR
10. R. Brill, RES
1. R. Tripathi, AEOD 11. L. Spessard, NRR ACRS STAFF
1. M. Markley, ACRS ATTACHMENT 1 g

, 4 Updated Standard Review Plan (SRP) Chapter 7

" Instrumentation and Controls" (CRGR Meeting No. 307 June 23,1997) topic Staff request for CRGR review and ondorsement of the SRP Chapter 7, Update,

" instrumentation and Controls." On September 29,1990, at the CRGR meeting No. 292, the Committee reviewed and endorsed the draf t version of tho SRP prior to the issuance for public comments, in the revised text, submitted for the CRGR endorsement, most changes were made by the staff as a result of the ACRS comments and public comments.

Significant changes were made in the following parts:

  • Page SRP 7.016: The text on inter disciplinary coordination with the staffs of various NRR branchos has now been moved to tho " Introduction." In the Fall 1996 vorsion, similar text was repeated in each section.
  • Page 7.0 A 6: The footnoto W a edded,in response to the ACRS comments, to clarify the staff's intent of N ORElon of tho acceptance critoria. The last sentence in the footnote my M ctWod as the staff does not wish to precodo Graded QA.
  • BTP HICB 14 9 through HICB 14 31: The text included here in is a completo re-writo because of the ACRS comments.
  • BTP HICB 19 8: Clarification of diversity requirements.

BACKGROUND (i) Memorandum from F. J. Miraglia to D. F. Ross, "Roquest for Review and Endorsement of Updated Standard Review Plan Chapter 7,' Instrumentation and Controls'," dated June 9,1997 (CRGR ltem No.161, received on J n o 9,1997 and distributed to the members on June 11,1997).

The presentation material used by the staff is included as Attachment 2 A.

ISSUES, CONCERNS AND RECOMMENDATIONS Nono. The Committoo endorsed the updated SRP Chapter 7 for issuance.

BACKFIT CONSIDERATIONS No backfit proposed or intended. The review guidance applios only to the futuro plants and to oldor plants retrofitting with now l&C systems.

ATTACHMENT 2 (Minutes of the CRGR Mtg. No. 307)

, 4 04 ATTACHMENT 2 A PRESENTATION MATEFJALS USED BY THE STAFF M

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UPDATE OF 1

STANDARD REVIEW PLAN CHAPTER 7 INSTRUMENTATION AND CONTROLS i i

Presented to:

f Committee to Review Generic Requirements i

j Matthew Chiramal j instrumentation and Controls Branch l Division of Reactor Controls and Human Factors

! Office of Nuclear Reactor Regulation l

Phone No: 301-415-2845; E-mail: mxc@nrc. gov n

i CRGR Meeting No. 307; June 23,1997 gy l rx

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C* 7.0. Instrumentation and Controis - Overview of F.eview Process ' '

Appendix 7.0-A Review Process for Digital 1&C .

/* 7.1 Introduction Appendix 7.1-A Acceptance Criteria and Guidelines  !

Appendix 7.1-B Confonnance to IEEE Std 279 Appendix 7.1-C Conformance to IEEE Std 603

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  • 7.3 Engineered Safety Features Systems 2
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  • 7.5 Information Systems important to Safety l
  • 7.6 Intedock Systems important to Safety l

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-(* 7.7 Control Sys+ ems t

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  • 7.8 Diverse I&C Systems
  • 7.9 Data Communication Systems 2 l

i *- Appendix 7-A Branch Technical Positions

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  • Appendix 7-8 General Agenda, Station Site Veits

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  • Appendix 7-C Acronyms; Abbreviations, and Glossary 4

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SRP Chaotor 7 revised to cddress diaitcl I&C topics -

.j e Revised Section 7.1 on general requirements and guidance ,

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Add references to new regulatory guides (RGs) and branch technical '

positions (BTPs) on special digital system issues i Highlight review areas, acceptance criteria, and review process for u digital systems based on IEEE Std 7-4.3.2 (RG 1.152)

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j e New Section 7.0 ar.d Appendix 7.0-A describe the overall review j

process for digital systems i i

j e New Appendix 7.1-C gives guidance with respect to review according to j IEEE Std. 603 (RG 1.153) i 4

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  • Revised Appendix 7.1-A addresses rule changes (Part 52 and revisions j to Part 50), and new regulatory guides i

! e Revised Sections 7.2 through 7.9, which focus on systems, to add

! reference to digital system guidance in Section 7.1 e Revised Appendix 7-A includes new BTPs I

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Draft SRP Chapter 7 was issued for Public Comments -

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  • Issued for Public Comments on December 5,1996 '
  • Two sets of comments received: i

- Nuclear Energy Institute

- Westinghouse Electric Corporation b

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4 DISPOSITION OF PUBUC COMMENTS ON DRAFT SRP CHAPTER 7 UPDATE i

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2 Public Commsnts and their Disoosition -

NEl Comments:
  • SRP Chapter 7 well organized and clear i

SRP Chapter 7 appropriately relies largely on references to standards j rather than including detailed review guidance SRP Chapter 7 should be publicly available for extended period of trial use and public comment

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! Disposition: s i

  • SRP is maintained as a "living document;" additional public

!, comments, revisions of applicable standards, new standards, and  !'

results of new studies will be regularly incorporated into future l revisions of SRP Chapter 7; final SRP Chapter 7 will be available

! indefinitely on the intemet .

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i l Public Comments and their Disposition fContinued) -

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! Westinghouse Comments / Disposition:

i, Comment - Definitions of terms " Deterministic" and " Deterministic l Timing" in Appendix 7.O-A and BTP HICB-14 contain contradictory l statements.

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! o Disposition - The definitions were revised.

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  • Comment - A sentence in Appendix 7.O-A, Section C.1, seems to t l indicate that the staff is willing to relax the acceptance criteria for safety systems of lesser significance. e pr-d spJr ed v

l o Disposition - The wording of the sentence is "The Staff's review l emphasis should be commensurate with the safety significance of the j given system or aspect of a system's design under review." It is j meant to provide guidance to the staff reviewer for level of review l effort and not an indication of relaxa_ tion of acceptance criteria for the f design. A phrase and footnote wers added to clarify this point.

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t l Westinghouse Csmments/ Disposition (continued): -

.t Comment - In Section 7.1.1, item 7, " Diverse actuation systems"  !

l should read " Diverse Actuation Systems MAY include the Anticipated I i

Transient Without Scram (ATWS) ...." .

o i Disposition: The title of this section (and Section 7.8) was changed to " Diverse instrumentation and control systems" as opposed to l " Diverse actuation systems," since it provides guidance for any j diverse I&C system. ATWS Mitigation System and Diverse Actuation l System are examples of diverse I&C systems.

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  • Comment - The first paragraph of Appendix 7.1-B states that l

although required by NRC regulations only for protection systems, the criteria of ANSI /IEEE Std 279 are applicable to any instrumentation j and control system, and that the reviewer may use the concepts of l the standard in the review of I&C systems that are not part of the

protection system. Examples and clarification should be included in l Appendix 7.1-B. #

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o Disposition: A clarification was provided that IEEE Std 279 is useful l guidance for l&C. systems other than protection systems and noting j that use of this guidance is described in Sections 7.2 through 7.9.

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Westinghouse Comm:nts/ Disposition (continued): -

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! i l Comment - After 10 CFR 50.55a(h) is revised from IEEE 279 to IEEE l 603, Appendix 7.1-B should be eliminated and only Appendix 7.1-C l

be used.  !,

i j o Disposition: SRP Chapter 7 is planned to be used for review of future  !

i plant applications as well as license amendment applications. Thus,  ;

} SRP Chapter 7 retains both Appendix 7.1-B and 7.1-C since current

operating plant licensing bases incorporate IEEE Std 279. i Comment - The statement in Section 7.8 that equipment diversity i

should be provided to the extent reasonable and practicable is vague and subjective - examples of diversity should be included. ,

o Disposition: Additional clarification on equipment diversity is included l in BTP HICB-19 in response to this comment and a similar j

! recommendation by the NAS study. i Several Comments on BTP HICB-12 on Instrument Setpoints and on l BTP HICB-13 on Cross-Calibration of RTDs are addressed in the

! revisions of these BTPs.

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CHANGES BASED ON ACRS COMMENTS AND NAS/NRC STUDY t a

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! _Chanaes based on ACRS Comments and NAS/NRC Study

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Recommendations i

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in using BTP HICB-14 for guidance the reviewer is directed to additional

guidance and acceptance criteria in standards and other references. It would be preferable to include the acceptance criteria and guidance from the standards in the BTP itself.

o Disposition:

In the revised SRP Chapter 7, where possible, particularly in BTP H!CB l 14, the required guidance and acceptance criteria were extracted from l the referenced standards and documents and included directly in the SRP section and associated BTP.

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o ACRS Comm:nt: ' .

5 Balance in review guidance between design process and product assessment in BTP HICB-14 o Disposition:

Section 3.1, Acceptance Criteria for Software Life Cycle Process l Planning, and Sectica 3.2, Acceptance Criteria for Software Life Cycle j Process implementation, have been revised and formatted to be '

! consistent with the product acceptance criteria in Section 3.3, 2

Acceptance Criteria for Software Lifecycle Process Design Outputs.

i Revisions to BTP HICB-14 will focus the reviewer's assessment on the

important aspects of design process and product verification and ,

L validation effort and provides en appropriate balance in the review

between the digital system design devt !opment process and the process l outputs (products) ,

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o ACRS Ccmment: --

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Staff should review the Atomic Energy Control Board (AECB) Draft Reg.

Guide C-138, " Software in Protection and Control Systems," particularly the use of formal notation in the Software Requirements Specificaten i o Such a review was performed by the staff, in 1996, at the request of l

the Director General, AECB. By letter dated June 7,1996, de NRC l Executive Director for Operations stated that the contents of C-138 l were consistent with the staff positions and acceptance criteria on

software related issues incorporated in the update of SRP. Chapter 7 and j the new regulatory guides on software quality.

Appendix 7.O-A has been revised to provide additional guidance on the I

use of formal methods in software development l

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  • NAS Recommendation:
The [US]NRC should revisit its guidelsnes on assessing whether adequate diversity exists. The [US]NRC should not place reliance on different programming languages, different design approaches meeting p the same functional equirements, different design teams, or using  ;

! different vendors' equipment (" nameplate" diversity). Rather, the i

[US]NRC should emphasize potentially more robust techniques such as i the use of functional diversity, different hardware, and different real- i l time operating systems.

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o Disposition:

In the revised BTP HICB-19 additional clarification on acceptable j diversity for digital system has been included. Specifically, BTP HICB-19 t calls for a diversity demonstration based on an appropriate combination j different types of diversity including functional diversity and different hardware.

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, 4 Safety Evaluation Report Approving EPRI Topical Report, TR 106439,

" Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety" (CRGR Meeting No. 307 June 23,1997) topic Staff request for CRGR review and endorsement of the subject proposed Safety Evaluation Report (SER). The staff regards the guidelines contained in the EPRI Topical Report, TR 106439, " Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety," generically acceptable for qualifying commercial grade digital l&C equipment for nuclear safety application in nuclear safety systems. No new staff positions are sold to be established.

BACKGROUND fi) Memorandum dated June 5,1997, from F. J. Miraglia to D. F.,Ross, requesting CRGR review and endorsement of the proposed SER on EPRI Topical Report, TR 100439, " Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety," for issuance. The review packago (CRGR ltem No.

162) was received on June 10 and distributed to the members on June 11,1997.

(ii) E mail, June 20,1997, from R. Tripathi to the CRGR members forwarding the issue Shoot.

No presentation material was distributed by the staff at the meeting.

ISSUES, CONCERNS AND RECOMMENDATIONS .

The Committee made minor comments and endorsed the SER for publication subject to those comments. The CRGR recommended woMng changes to the SER, which the staff agreed to incorporato as follows:

a. Page 7: Replace the word " endorsed" with " formally reviewed" in the last sentence in the middlo two paragraphs. The sentence now reads, "This document has not been formally reviewed by the NRC staff."
b. Pago 10: Add the following sentence to the end of the second paragraph: "The above issues nood to be addressed as part of the licensee's proposed design change and may be addressed in other documents,"

ATTACHMENT 3 (Minutes of the CRGR Meeting No. 307)

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c. Page 16 Replace the word 'this' in the second sentence in the first full paragraph .

with "the lack of documentation for commercial grade items." The sentence  !

, now reads, "To compensate for the lack of documentation for commercial grade items and reach an equivalent level of assurance, the licensees... .' ,

The CRGR endorsement was formally relayed to the staff on July 10,1997.

BACKFIT CONSIDERATIONS ,

No backfit proposed or intended.

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From Rail Tripathi To: WND2.WNP5.RLS '

Date: 7/10/971:59pm S @ ct: CRGR ENDORSEMENT OF SRP CH 7 AND COTS SER Lee, A

Over the telephone and via e mail, Jerry Wermiel and I re capped (and agreed on) three i CRGR comments on the COTS SER, following the CRGR meeting on June 23,1997.

These comments will be reflected in the CRGR mtg. minutes. However, because of competing tasks, the meeting minutes will not be ready to be issued until late July /early

  • August. '

There were no CRGR comments to be resolved on the SRP Chapter 7, Update.

The CRGR endorsement of these two topics was conveyed to the staff at the meeting by Dr. Roas subject to various comments on the COTS SER. This e mail formally documents  ;

that thJ,e are no open issues to be addressed on either of the aforementioned topics.

Rajl cc: , ,

CHGR Members Jerry Wermlel

Matt Chiramal Jim Stewart CC: WND2.WNP5.JSW1, WND2.WNPS.MXC, WND2.WNP4.JMW1, WND...

f-r ATTACHMENT 3 A

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, e' Proposed Final Regulatory Guides For the Use of Computer Software in Nuclear Safety Applications Regulatory Guides 1.168 Through 1.173 (CRGR Meeting No. 307 June 23,1997)

TOPlc Staff request for CRGR review and endorsement of the proposed final regulatory guidos (RG 1.168 through 1.173) for computer sof tware to be used in safety systems of nuclear power plants.

Notes:

1. These Regulatory Guides had not been concurred by OGC However, the staf f informed the CHGR staff that OGC was involved in commenting on the draf t regulatory at the pre publication for comment stago. Thus, tho intent of item (iv) of the CRGR Charter, Rev. 6, was satisfied.
2. The Comtnittee had not reviewed the draf t regulatory puides pior to the issuance for public comments. On behalf of the Committee, the CRGR staff had reviewed these documents (although not in depth) and provided comments to the staff.

BACKGROUND (i) Memorandum dated June 5,1997, from F. J. Miraglia to D. F. Ross. The review package (CRGR ltem No.102) was received on Juno 10 and distributed to the members on June l',1997.

(ii) E mail, date unknown, from R. Tripathi to the CRGR members forwarding the issue Sheet. .

Presentation material used by the staff is included as Attachmont 4 A.

ISSUES, CONCERNS AND RECOMMENDATIONS The Committee made various comments and recommendations. There were one generic change and some specific changes recommended.

ATTACHMENT 4 (Minutes of the CRGR Meeting No. 307)

O The following generic change was recommended for all six regulatory guidos:

Scation D. "lmolomentation" Use tho modified wording used in Rog. Guido 1.52 and 1.53, and included in Attachment 4 A. fdgie this and other conformina chanaos in all sistor reaulatory auides Specific CRGR comments on the individual rogulatory guidos were as follows:

il0LGulda 1.108;

1. Pago 0, item 1: This paragraph to be modified to clearly set that wo are applying the IEEE standard to a narrow set of critical sof tware.
2. Pago 0, item 2: Tho second paragraph is to be modiflod to eliminato the apparent contradiction betwoon the 4th lino of the first paragraph and the last but one lino of the second.
3. Pago 7,ltom,3: Clearly state that the IEEE standard does not require indopondonco, but wo do.

4 Pago 9, item 7: In the last sentonco, change "this regulatory guido" to "Rogulatory Guido 1.08," unless "this* would mean R69. Guido 1.163.

5. Pago 9, item 8: Clari'
  • that this is one acceptablo method.

Bro. Guido 1.109

1. Pago 5: Deloto Footnote 5.
2. Page 10, item 11: Rostato the sentonco, "... Assumptions about cost and scheduto must not diminish safety."

flco, Guido 1.170

1. Pago 7, item 3: Doloto the last sentonco, "...For examplo, test...)

Subject to those recommendations, the CRGR ondorsomont to the staff was sont on July 17,1997.

BACKFIT CONSIDERATIONS No backfit is proposed or intended. The use of the regulatory guidos is voluntary.

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i RECONCILIATION of PUBLIC COM1ENTS  :

! Draft Software Regulatory Guides DG-1054-1059 i

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Presentation to CRGR t

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Joel J. Kramer Control. Instrumentation, and Human Factors Branch Division of Systems Technology Office of Nuclear Regulatory Research b$' P x!

l June 23. 1997 3 r!

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PlRPOSE Discuss Proposed Changes to Draft Software Regulatory Guides These gb9 des endorse. with clarification and exception. IEEE standards More detailed review guidance and acceptance criteria are contained in SRP and BTP-14 t

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DRAFT REGULATORY GUIDES FOR COMPUTEK SOFTWARE USE IN .

SAFETY SYSTEMS OF IRJCLEAR POWER PLANTS

  • DG-1054 (Software Verification and Validation)--Proposed Final i

Regulatory Guide 1.168 .

  • DG-1056 (Software Test Documentation )--Proposed Firal Regulatory i

Guide 1.170

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NATURE OF STANDARDS BEING ENDORSED Consensus Standards on Software Engineering Overall Software Process IEEE 1074-1991 Developing Software Life Cycle Processes Intermediate Software Products IEEE 830-1994 Software Requirements Specifications Evaluation of Interriediate and Final Software Products IEEE 829-1993 Software Test Documentation

IEEE 1028-1988 Software Reviews and Audits Control of Intermediate and Final Software Products IEEE 828-1990 Software Configuration Management Plans

  • These are also products of the software development process 4 .

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PtBLIC COMENT S0lRCES

  • Westinghouse
  • Commonwealth Edison .
  • Nebraska Public Power District (Cooper Nuclear Station)
  • Capri Technology
  • A member of the Atomic Safety and Licensing Board (ASLB) -
  • (Nuclear Utilities ~ Software Management Group) ,

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SUP9%RY OF PUBLIC COP 9ENTS ienerally supported use of Software Regulatory Guides as a first

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  • andards may be too prescriptive ,

4RC mquirement for " independence" Restricting use of Comercial Off-the-Shelf (C0TS) Software

  • Worthwhile. constructive suggestions for improved wording and cl ari fication
  • Need for a software " systems safety model" to provide further assurance of adequacy of software products

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9 PROPOSED CHANGES TO DG-1054 (REGULATORY GJIDE 1.168)

Software Verification and Validation

  • Position 3 Independence of Software V+V Proficiency of independent verifiers Responsibility for the adequacy of'V+V 4

Posi'i on 5 Conformance of Haterials Acceptance of pre-existing software Regulatory Guide 1.152. Rev.1. and EPRI T-106439 Section B Discussion ,

Classification of safety systems software Importance to safety Flexibility in implementation

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"R0 POSED CHANGES TO DG-1055 (REGULATORY GUIDE 1.169)

Software Configuration Management  ;

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i- n 6 Documentation 4

Applicability of guide -

Softwabe requirements. designs and code Support software used in development (exact versions)

Ensuring that all factors cordributing to executable .

software are understood

. Pr > cn 12 Backfit clarification (New Position) .

> w statements on Section 1.1 of IEEE Std 828-1990 should not be interpreted as a requirement for backfit Section D Implementation contains staff's position PROPOSED CHANGES TO DG-1056 (REGULATORY GUIDE 1.170)

Software Test Documentation

  • NONE ,

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PROPOSED CHANGES TO DG-1057 (REGlMATORY GUIDE 1.171)

Software Unit Testing 6

Position 4 Independence in Software Verification '

o Essentially same as with Position 3 for DG-1054 (RG 1.167)

PROPOSED CHANGES TO DG-1058 (REGULATORY GUIDE 1.172 Software Requirements Specification Position 6.3 Robustness o Responding to both hardware and software failures vs.

handling both o Software requirements for fauIt tolerance and failure modes be specified for each actairisc mode o

1 Based on system level hazards analysis or consideration of '

software internals 9

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"R0 POSED CHANGES TO DG-1059 (REGULATORY GUIDE 1.173)

Software Life Cycle Processes Po' ' ion 1.3 Commercial Software Essentially same as Position 5 for DG-1054 (RG 1.168)

Po i t inn 1.4 Definitions Only definitions for accident and hazard t

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\9o Comparison of Wording in the " Implementation" section of the Proposed regulatory guides and Regulatory Guides 1.152 and 1.153 Proposed Final Reg. Guides Revision 1 of 1.168 through 1.73 Reg. Guides 1.152 and 1.153 The second sentence in the first Darnaraoh reads as:

^ ny beckhtning thet mcy scre!! 'com

. No corresponding sentence.

applysg-th!c new guidance 40-ormathWants woe!d be juc4!!!cd H acwdence "W e44eb!iehed NRC bcck(4444ng-gwidance-end psee^derce "

Question: Isn't this always true? Why in this case the backfitjustification any more important, especially, when the Regulatory Guides provide only a cuidance and not.a teautreme_nt? Is this going to be the new

" boiler plate" material?

The second paraaraoh reads as:

"Except in those cases in which an applicant "Except in those cases in which an applicant or hcensee proposes an acceptable alternative or licensee proposes an acceptable alternative method for complying with specified portions method for complying with specified portions of the Commission's regulations, the methods of the Commission's regulations, the methods described in this guide will be used in the described in this guide will be used in the evaluation of submittalin connection with evaluation of submittalin connection with applications for construction permits, standard applications for construction permits and design certifications'and desi0n.approkals, and operating licenses, it will also be used to combined operating licenses. This guide will evaluate submittal from operating reactor also be used to evaluate submittal from licensees that propose system modifications operating reactor licensees who propose voluntarily initiated by the licensee if there is e modifications that go' bey 6 tid thtf"durr'Ent clear nexus between the proposed licensingLbasis if those' modifications are modifications and this guidance" voluntarily initiated by the licensees and there is a clear connection between the proposed modifications and this guidance. This gijlde svill be iised iri conjunction ;with; and will eventually be leflected in 'the Standard _ review Elan,1which is' currently under revision."

ATTACHMENT 4-B (Minutes of the CRGR Meeting No. 307) 3

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