ML18346A316

Summary of Public Phone Call with the Nuclear Energy Institute Regarding Planning for the November 2018 Inspection Workshop

ML18346A316
Person / Time
Issue date:	01/07/2019
From:	Joe Golla NRC/NRR/DLP/PLPB
To:	Dennis Morey NRC/NRR/DLP/PLPB
Golla J, NRR/DLP, 415-1002
References
Download: ML18346A316 (5)

Text

January 7, 2019 MEMORANDUM TO: Dennis C. Morey, Chief Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation FROM: Joseph A. Golla, Project Manager /RA/

Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation

SUMMARY

OF PUBLIC PHONE CALL ON NOVEMBER 6, 2018, WITH THE NUCLEAR ENERGY INSTITUTE REGARDING PLANNING FOR THE NOVEMBER 2018 INSPECTION WORKSHOP On November 6, 2018, the U.S. Nuclear Regulatory Commission (NRC) staff held a public phone call with the Nuclear Energy Institute (NEI) and other stakeholders. The purpose of the call was to discuss the November 15, 2018, inspection workshop. The workshop would address the inspection activities related to digital instrumentation and controls (I&C) modifications performed under the Alternate Review Process introduced in digital I&C Interim Staff Guidance (ISG)-06, Licensing Process, Revision 2.

NEI provided an example of a Vendor Oversight Plan (VOP) summary description that would be included as part of a license amendment request (LAR) using the Alternate Review Process.

The staff noted that Section C.2.2.1 of draft ISG-06, Revision 2, only requires a description of the licensees vendor oversight plan to support the license review for a digital I&C system. If the VOP summary is to generically satisfy the guidance in the ISG, then the NRC staff would have very little knowledge of the specific oversight activities to be performed by the licensee. As a result, it will be difficult for the NRC staff to develop meaningful inspection plans for verifying that oversight is correctly performed or that the correct level of oversight is being planned.

The staff noted that, as written, the VOP summary does not include a list of oversight activities to be performed per an established plan. Instead, it provides instructions for creating a plan that is comprised of General Performance Measures and Project Specific Performance Measures.

The VOP summary lists topical areas to be covered by the oversight activities but does not identify the activities such as audits, code reviews, or document reviews that would be performed to verify that vendor performance is acceptable. It is not clear whether an actual summary document would include such a list of activities or if it would just generically describe the types of oversight activities that could be performed later in the process.

Further, the VOP summary provides instructions on how a vendor oversight plan should be created including guidance on what the contents of a VOP would be and guidance on how

D. Morey acceptance criteria should be established. It does not however, provide a summary of an actual VOP though.

The staff asked NEI to address the following questions regarding the VOP summary:

1. Will the actual vendor oversight plan itself be complete and available for the NRC to audit during the license amendment evaluation or will this plan be a downstream activity?

NEI responded that the VOP will be developed as part of the equipment purchase order and that it would be completed before the LAR is submitted. The VOP would be available for the NRC to audit.

2. Will the VOP summary document submitted to the NRC include a summary of specific planned oversight activities to be performed for the subject project or will it just generically describe the types of activities that could be performed later in the process?

NEI responded that the VOP summary would include specific activities, as well as the base level activities.

3. The summary refers to project-specific activities described in the LAR. Are vendor oversight activities included as project specific activities and will they be specifically listed as such somewhere else in the LAR?

NEI stated that the VOP would be a living document that would contain a summary of the project specific activities.

4. ISG-06 states that the description of the licensees vendor oversight plan will ensure that the vendor executes the project consistent with 1) the LAR, 2) the 2015 version of the American Society of Mechanical Engineers Nuclear Quality Assurance (NQA) 1, Part II, Quality Assurance Requirements for Nuclear Facility Applications, Subpart 2.7, Quality Assurance Requirements for Computer Software for Nuclear Facility Applications. It is unclear how a summary of a plan to do vendor oversight activities can accomplish this. In other words; a plan to do something really doesnt ensure that it gets done. The sentence should probably be reworded to something like: The Plan, when executed, can be used to ensure that the vendor . . .

NEI agreed with the proposed wording change.

5. The summary document assumes throughout that a vendor has an NRC-approved 10 CFR 50 Appendix B Quality Assurance (QA) Program. Many of the digital I&C equipment vendors and suppliers do not have such QA programs. Instead, the products are commercially dedicated either by a licensee or by a different vendor that has an Appendix B compliant QA program. It is also the staffs understanding that these QA programs are not always approved by the NRC.

NEI stated that the term NRC-approved would be removed from the VOP when referring to the vendors 10 CFR 50 Appendix B QA Program.

6. On page 5 of the summary, under the title Software Verification, it is stated that application software verification and validation meets the requirements of IEEE 1012, as endorsed by Regulatory Guide 1.168. Since not all vendor processes are in full compliance with the

D. Morey guidance of IEEE 1012, this may be difficult for some platforms / vendors to comply with. Is this statement meant to be an example or is it intended to apply to all digital I&C systems?

NEI clarified that statement of IEEE 1012 conformance is for the workshop example.

NEI informed the staff that it would take the feedback provided during the call and modify the VOP summary in preparation for the workshop. NEI asked the staff to provide examples of the vendor oversight activities the staff would expect to see addressed in the VOP. The staff agreed to provide this material during the workshop.

No comments or questions were received on the call by members of the public.

CONTACT: Joseph A. Golla, NRR/DLP 301-415-1002

Enclosure:

Attendees List

ML18346A316 -Summary; ML18296A130 -Notice; ML18346A298 -Package; *concurred via e-mail NRC-001 OFFICE NRR/DLP/PLPB/PM NRR/DLP/PLPB/BC NRR/DLP/PLPB/PM NAME JGolla DMorey JGolla DATE 1/2/2019 1/3/2019 1/7/2019

NRC Public Phone Call Attendance November 6, 2018 Pareez Golub Excel Services Warren Odess-Gillett NEI Ron Jarrett TVA Ray Herb Southern Nuclear Frank Novak GEH Mark Burzynski Rolls Royce Nuclear John Schrage Entergy Jana Bergman Scientec Mike Waters NRC Rich Stattel NRC Samir Darbali NRC Calvin Cheung NRc Joe Golla NRC Enclosure