Regulatory Guide 1.187
| ML19204A176 | |
| Person / Time | |
|---|---|
| Issue date: | 07/23/2019 |
| From: | Tekia Govan NRC/NRR/DIRS/IRGB |
| To: | Philip Mckenna NRC/NRR/DIRS/IRGB |
| Govan T, 415-6197, NRR/DIRS | |
| References | |
| NEI 96-07, RG-1.187, Rev 2 | |
| Download: ML19204A176 (6) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555-0001
July 23, 2019
MEMORANDUM TO:
Philip J. McKenna, Chief
ROP Support and Generic Communication Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation
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 DRAFT
REGULATORY GUIDE 1.187, REVISION 2, THAT ENDORSES
NUCLEAR ENERGY INSTITUTE 96-07, APPENDIX D, HELD ON
JUNE 25, 2019
On June 25, 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 Requirements SECY-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 representatives to improve the guidance for applying 10 CFR 50.59 to digital I&C-related
CONTACT: Tekia V. Govan, NRR/DIRS
(301) 415-6197
P. McKenna
2 design modifications as part of a broader effort to modernize the regulatory infrastructure for digital I&C. This meeting, on June 25, 2019, serves as an additional opportunity to engage the public and the nuclear industry prior to the close of the public comment period on the draft RG
1.187, Revision 2, on July 15, 2019.
Meeting Summary
The NRC and industry management made brief opening remarks, and introductions were made by all in attendance. The NRC staff stated the objective of the meeting which was to conduct table-top exercises of digital I&C upgrades in which applying NEI 96-07, Appendix D, Criterion 6 guidance was met. During this meeting, NEI presented four examples and NRC presented three examples (ADAMS Accession Nos. ML19176A070 and ML19170A329), respectively related to NEI 96-07, Appendix D, Criterion 6 guidance. All the examples were presented with a starting point where it could not be demonstrated that a common cause failure across multiple trains was sufficiently low through a qualitative assessment as described in regulatory issue summary 2002-22, Supplement 1. The examples were only discussed against 10 CFR 50.59, Criterion 6, which is applicable to modifications that create a possibility for a malfunction of an
[structure, system, and component (SSC)] important to safety with a different result than any previously evaluated in the final safety analysis report (as updated). The NRC staff has taken an exception in draft RG 1.187, Revision 2, against the documentation of NEI 96-07, Appendix D, Criterion 6, Section 4.3.6.
During the table-top exercises the NRC staff and NEI generally came to the same conclusion as to whether the digital I&C modification in the exercise could be performed under 10 CFR 50.59 or if a license amendment request (LAR) would be required.
The major take ways from the meeting were:
NEI clarified that the safety analysis in NEI 96-07, Appendix D is not exclusive to updated final safety analysis report (UFSAR), Chapter 15, Accident Analysi
s. NEI
stated that the term safety analysis applies to any portion of the UFSAR where a safety analysis is performed.
Some of the digital modification examples provided by NEI demonstrated that a different interpretation of the current wording in the draft RG 1.187, Revision 2, could result in a licensee submitting a LAR when it is not required.
NEI and NRC staff agreed that working through the examples using NEI 96-07, Appendix D guidance should produce the same result as using the current guidance in NEI 96-07 base document.
NEI and NRC staff agreed with the definition of Malfunction of an SSC Important to Safety in NEI 96-07. There was discussion on what a different result meant in the regulation under 10 CFR 50.59, Criterion 6. Specifically, it was discussed where a modification should be evaluated by the malfunction different result or the safety analysis different result. The NEI 96-07 base document discusses malfunction different result, but NEI 96-07, Appendix D now discusses the safety analysis different result. There was action taken by NEI to evaluate the difference in terminology between the NEI 96-07 base document and NEI 96-07, Appendix D.
NEI agreed that they needed to revise the wording in NEI 96-07, Appendix D,
Section 4.3.6, steps 1 through 4 and to clarify the step 6 wording as it relates to safety analysis have become invalid due to their basic assumptions no longer being
P. McKenna
3 valid. Based on the current reading of Section 4.3.6, step 6, the NRC staff concluded that modifications could result in the need for a LAR.
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 will be able to meet the deadline for public comment period on draft RG 1.187, Revision 2, that closed on July 15, 2019. NEI stated that they will have recommended changes to NEI 96-07, Appendix D that will be included as a part their comment response including additional examples that clarify the discussion held during this meeting. The NRC staff stated that with the additional guidance and examples that are expected to be submitted as a part of NEIs public comment, there will be a need for another public comment period and potentially another public meeting to discuss these latest revisions to the NEI guidance.
Enclosure:
As stated
ML19204A176 concurred via e-mail*
OFFICE NRR/DIRS/IRGB* NRR/DIRS/IRGB* NRR/DIRS/IRGB* NRR/DIRS/IRGB*
NAME
TGovan IBetts PMcKenna TGovan DATE
07/23/2019
07/23/2019
07/23/2019
07/23/2019
Enclosure 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, HELD
ON JUNE 25, 2019
June 25, 2019, 1:00 PM to 4:30 PM
NRC One White Flint North
11555 Rockville Pike O-11B04 Rockville, MD
ATTENDEE
ORGANIZATION
1. Rossnyev Alvarado
NRC
2. Pete LeBlond
LeBlond and Associates
3. Kate Austgen
NEI
4. Phil Couture
Entergy
5. Thomas Thornton
Entergy
6. Steve Burd
Entergy
7. Ron Jarrett
8. Raymond Herb
Southern Nuclear
9. Steven Arndt
NRC
1
0. Tim Reed
NRC
1
1. Maxine Segarnick
NRC
1
2. Kayla Gamin
NRC
1
3. Paul Kallan
NRC
1
4. Jana Bergman
Curtiss-Wright
1
5. Steve Geier
NEI
1
6. Steve Vaughn
NEI
1
7. Shakur Walker
NRC
1
8. Bob Weisman
NRC
1
9. Phil McKenna
NRC
2
0. Tara Inverso
NRC
2
1. Greg Bowman
NRC
2
2. Mirela Gavrilas
NRC
2
3. Deanna Zhang
NRC
2
4. Neil Archambo
Duke Energy
2
5. Norbert Carte
NRC
2
6. Eric Benner
NRC
2
7. Michael Waters
NRC
2
8. Dave Beaulieu
NRC
2
9. Wendell Morton
NRC
3
0. Tekia Govan
NRC
P. McKenna
- 2 -
Participated via conference line
3
1. Matthew Shakur
3
2. Joe Holonich
NRC
3
3. Donald Chase
Curtiss Wright
3
4. Ken Lowery
Southern Nuclear
3
5. Gordon Clefton
Idaho National Lab
3
6. Bob Neuendorf
3
7. Megan Nydegger
3
8. David Madsen
Pacific Gas and Electric
3
9. Larry Nicholson
Certrec
4
0. Rob Burg
4
1. Charles Brown
NRC
4
2. Randy Strader
4
3. Michael Sortwell