ML20212L534
| ML20212L534 | |
| Person / Time | |
|---|---|
| Issue date: | 08/05/2020 |
| From: | Sheila Ray, Robert Roche-Rivera Office of Nuclear Reactor Regulation |
| To: | Eric Benner, Louise Lund Office of Nuclear Reactor Regulation |
| R. Roche-Rivera | |
| References | |
| Download: ML20212L534 (8) | |
Text
August 5, 2020 MEMORANDUM TO:
Eric Benner, Director Division of Engineering and External Hazards Office of Nuclear Reactor Regulation Louise Lund, Director Division of Engineering Office of Nuclear Regulatory Research FROM:
Sheila Ray, Senior Electrical Engineer in the Electrical /RA/
Engineering New Reactors and License Renewal Branch Division of Engineering and External Hazards Office of Nuclear Reactor Regulation Robert Roche-Rivera, Project Manager /RA/
Regulatory Guidance and Generic Issues Branch Division of Engineering Office of Nuclear Regulatory Research
SUBJECT:
SUMMARY
OF THE JULY 20, 2020 PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE AND THE INSTITUTE OF ELECTRICAL AND ELECTRONICS ENGINEERS TO DISCUSS A NEW REGULATORY GUIDANCE FRAMEWORK FOR IEEE ELECTRICAL STANDARDS On July 20, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting via Skype with representatives from the nuclear industry, including the Nuclear Energy Institute (NEI) and the Institute of Electrical and Electronics Engineers (IEEE). The purpose of the meeting was to discuss the NRC staffs draft approach for achieving a simpler and more effective regulatory guidance framework for the endorsement of IEEE Nuclear Power Engineering Committee (NPEC) electrical standards and get feedback. The public meeting notice can be found in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML20190A012. The Meeting Agenda and List of Attendees can be found in Enclosures 1 and 2, respectively.
At the beginning of the meeting Mr. Robert Roche-Rivera, Codes and Standards Program Manager in the Division of Engineering (DE), Office of Nuclear Regulatory Research (RES),
welcomed everyone to the Category 2 public meeting and explained the ground rules for the meeting and logistics regarding using Skype during the meeting. Subsequently, Ms. Louise Lund, NRC Standards Executive and Division Director of RES/DE and Ms. Jane Marshall, Deputy Division Director of the Division of Engineering and External Hazards (DEX) in the Office of Nuclear Reactor Regulation (NRR), provided the NRC opening remarks, highlighting the effectiveness, efficiency, and risk informing objectives with respect to regulatory guidance development, as well as welcoming the continued collaboration in the development and use of
E. Benner and L. Lund IEEE standards. These remarks were followed by opening remarks by Stephen Geier, Senior Director of the Engineering and Risk Division at NEI. Mr. Geier highlighted NEIs interest in efficiencies that may be gained through the regulatory guidance framework and expressed support for a streamlined regulatory guidance process that leverages both industry and NRC participation in standards development committees and results in a quicker endorsement of new and or updated standards.
Following the opening remarks, Ms. Sheila Ray, Senior Electrical Engineer in the Electrical Engineering New Reactors and License Renewal Branch (EENB), NRR/DEX, presented the regulatory guidance framework for IEEE electrical standards including identification of IEEE NPEC, Subcommittee 2, 3, and 4 standards endorsed by existing Regulatory Guides (RGs);
development of new RGs; and plans for endorsement of standards within the existing and new RGs, grouping the endorsement of standards by topic. The presentation also covered the status of significant RGs and discussions of the effectiveness of periodic reviews for communicating status and plans for the update of RGs. The slides for this presentation can be found in ADAMS under Accession number ML20189A599.
Discussions on IEEE NPEC Subcommittee 2:
Mr. Bill Horin, Nuclear Utility Group on Equipment Qualification, thanked the staff for the ongoing coordination of the endorsement of IEEE standards and encouraged the consideration of the licensing basis for the existing plants in the ongoing process.
Mr. James Parello, IEEE, thanked the staff for the current efforts, asked about plans on schedule for starting the work and assigning staff particularly considering the review and licensing of new reactors, and suggested the distribution of draft IEEE standards (i.e. prior to the balloting of the standard) amongst NRC staff for a collective review of such standards. Ms. Ray explained that the NRC has a prioritization process in place for the review and endorsement of standards. The process monitors changes in agency priorities and adjusts the review and endorsement of standards accordingly. With respect to resources, the staff leverages the participation of NRC representatives in the standards development committees as well as the support and collaboration of staff across the agency including staff from NRR, RES, and other offices. Further, regarding the distribution of draft standards, Ms. Ray explained that it is the staffs current practice to do so and to discuss staffs perspectives prior to participation in IEEE committee activities to determine and align on agency views and expressed such views during committee meetings.
Discussions on IEEE NPEC Subcommittee 3:
Ms. Yvonne Williams, Bechtel National, asked why was IEEE Standard 1819, IEEE Standard for Risk-Informed Categorization and Treatment of Electrical and Electronic Equipment at Nuclear Power Generating Stations and Other Nuclear Facilities, included with IEEE Standards 1205, Guide for Assessing, Monitoring, and Mitigating Aging Effects on Class 1E Equipment Used in Nuclear Power Generating Stations and 933, Guide for the Definition of Reliability Program Plans for Nuclear Power Generating Stations. Ms. Ray clarified that the plan is to develop 3 new RGs, one for each of these standards. In terms of priority and schedule, work is projected to start first on IEEE Standard 1819, followed by 1205, and then 933. Ms. Williams also indicated that experts on security systems were needed to support the development of IEEE Std. 692, IEEE Standard for Criteria for Security Systems for Nuclear Power Generating Stations.
E. Benner and L. Lund Mr. Daryl Harmon, IEEE, thanked the staff for hosting this meeting and recognized the staffs responsiveness to an NPEC letter requesting priority endorsement for a number of NPEC related standards and its consideration in the regulatory framework.
Mr. Mostafa Taha, Columbia Generating Station, thanked the staff for the information shared in the slides and indicated that such information provides a helpful roadmap that licensees could refer to with respect to guidance for meeting NRC requirements. Further, Mr. Taha asked about additional sources of information with details or guidance on testing requirements. RG 1.30, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment, and RG 1.118, Periodic Testing of Electric Power and Protection Systems, address testing.
Discussions on IEEE NPEC Subcommittee 4:
Mr. Robert Konnik, IEEE Standard 690 Working Group Chairman, commented on the scope of some of the standards referenced in IEEE Standard 690, for example, some focus on design aspects and other on installations aspects. Further, Mr. Konnik suggested that the framework should also look into IEEE Insulated Conductors Committee (ICC) standards like IEEE Standard 1185, IEEE Recommended Practice for Cable Installation in Generating Stations and Industrial Facilities, and suggested that both design and installation related standards be looked at and considered together.
Mr. Parello commented on the need to consider standards within the scope of other committees, for example IEEE Standard 535, IEEE Standard for Qualification of Class 1E Vented Lead Acid Storage Batteries for Nuclear Power Generating Stations, currently endorsed by RG 1.158. Ms.
Ray mentioned the staffs plans for a future public meeting to discuss the regulatory guidance framework for the endorsement of standards pertaining to the IEEE Energy Storage &
Stationary Battery Committee, such as IEEE Standard 535. Additionally, the staff held a meeting on April 28, 2020 on the draft approach for the regulatory guidance infrastructure for digital instrumentation and control, and the meeting summary can be found at ML20125A344.
Mr. Jim Gleason asked about the staff plans for updating RG 1.89 which currently endorses IEEE Standard 323-1974, IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations and asked whether the staff anticipated changing existing positions. As a background, he referred to the RG 1.100 endorsement of IEEE Standard 344, IEEE Standard for Seismic Qualification of Equipment for Nuclear Power Generating Stations and indicated that the recent revision of RG 1.100 provides more restrictions related to the seismic qualifications than prior revisions, and was wondering if the same was to be expected with respect to the environmental qualifications. Ms. Tania Martinez Navedo, Branch Chief of the Electrical Engineering New Reactors and License Renewal Branch, NRR/DEX, explained that for RG 1.89 the staffs intent is to clarify existing staff positions and that no changes in staff positions were anticipated. Mr. Michael Wiwel suggested the endorsement of IEEE Standard 741, IEEE Standard Criteria for the Protection of Class 1E Power Systems and Equipment in Nuclear Power Generating Stations via RG 1.32, in lieu of developing a new RG.
Discussions on Communications:
Mr. Mike Eudy, Project Manager in the Regulatory Guidance and Generic Issues Branch, RES/DE, welcomed comments and suggestions with respect to external stakeholder
E. Benner and L. Lund involvement in providing feedback on period reviews and RGs updates. Mr. Harmon encouraged continuing the communications during IEEE subcommittee and working group meetings.
Mr. Taha, commented that additional background information with respect to the changes and updates of IEEE standards, would be very helpful. Mr. Harmon, referred to the introductory sections of a standard as providing information on the revisions as well as the rationale for the revisions. Mr. Kenn Miller, Senior Electrical Engineer in the Instrumentation, Controls, and Electrical Engineering Branch, RES/DE, referred to the IEEE NPEC meeting minutes which are captured on IEEE NPECs website. The committee meeting minutes document the committees activities as well as background information on standards revisions.
Additionally, Mr. Miller pointed out the location in the NRC website were periodic reviews are available. Mr. Eudy solicited feedback from the meeting participants on the need for making periodic reviews more visible and welcomed comments on the usefulness of such reviews. Mr.
Geier indicated that the RG development process would benefit from making the periodic reviews more visible, for example a dedicated website for highlighting recent updates related to RGs. Mr. Geier also commented that he found the periodic reviews to provide valuable information. Another idea that came up during the discussion was publishing and Federal Register notice on a periodic basis listing the periodic reviews completed during a given reporting period.
Ms. Williams suggested that standards committee meetings or other standards committee interactions could serve a forum for obtaining external feedback on RG periodic reviews.
Specifically, Ms. Williams suggested that that a list of upcoming periodic reviews be provided to the NPEC chair for NPEC related standards. The NPEC chair would then forward that information to the SC chairs for associated standards. In addition, the NRC representatives supporting each SC could be directly asked to highlight the upcoming periodic reviews to the SC chairs, via email, when the schedule for review is announced. The staff will discuss Ms.
Williams recommendation internally and provide and update during the next NPEC meeting.
Mr. Meraj Rahimi, Chief of the Regulatory Guidance and Generic Issues Branch, RES/DE, indicated that in its development of periodic reviews, the NRC staff considers and leverages the experience gained via the participation in standards committee activities and encouraged the continuation of such collaboration. Ms. Melanie Brown, Southern Nuclear, suggested that the NRC representatives to each working group could provide an update on RGs and periodic reviews to the working group.
The floor was opened to questions from the public, but no additional questions or comments were received.
After the public comment period, the NRC, NEI, and IEEE made closing statements thanking everyone for the information presented and the discussions at the meeting. The meeting was adjourned at 3:23 p.m. Eastern Daylight Time
- via email OFFICE NRR/DEX/EENB RES/DE/RGGIB NRR/DEX/EENB RES/DE/RGGIB NAME S. Ray*
R. Roche-Rivera*
T. Martinez Navedo* M. Rahimi*
DATE 7/30/2020 7/30/2020 8/05/2020 7/30/2020
U.S. NUCLEAR REGULATORY COMMISSION JULY 20, 2020 CATEGORY 2 PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) AND THE INSTITUTE OF ELECTRICAL AND ELECTRONICS ENGINEERS (IEEE) TO DISCUSS A NEW REGULATORY GUIDANCE FRAMEWORK FOR IEEE ELECTRICAL STANDARDS Meeting Agenda July 20, 2020 2:00 PM to 4:00 PM Time Topic Speaker 2:00 PM Welcome and Introductions NRC 2:05 PM Opening Remarks NRC/NEI/IEEE 2:10 PM Discussion NRC/NEI/IEEE 3:40 PM Opportunity for Public Comments Members of the Public 3:55 PM Closing Remarks NRC/NEI/IEEE 4:00 PM Meeting Adjourn
U.S. NUCLEAR REGULATORY COMMISSION JULY 20, 2020 CATEGORY 2 PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) AND THE INSTITUTE OF ELECTRICAL AND ELECTRONICS ENGINEERS (IEEE) TO DISCUSS A NEW REGULATORY GUIDANCE FRAMEWORK FOR IEEE ELECTRICAL STANDARDS List of Attendees July 20, 2020 Name Affiliation Jeremy Bowen U.S. Nuclear Regulatory Commission (NRC)
Michael Eudy NRC Louise Lund NRC Jane Marshall NRC Tania Martinez Navedo NRC Gurcharan Matharu NRC Kenneth Miller NRC Khoi Nguyen NRC Meraj Rahimi NRC Liliana Ramadan NRC Sheila Ray NRC Robert Roche-Rivera NRC Mo Sadollah NRC Brett Titus NRC Khadijah West NRC Neil Archambo Duke Energy Joel Beres Utility Engineering Jana Bergman Curtiss-Wright Corporation Melanie Brown Southern Nuclear Augi Cardillo NuScale Power Suresh Channarasappa Westinghouse Nomso Chukwuka Energy Northwest/Columbia Generating Station John Conly Certrec Corporation Ken Fleischer Fleischer Consultants, LLC/ Institute of Electrical and Electronics Engineers (IEEE)
Jason Gasque Tennessee Valley Authority (TVA)
Stephen Geier Nuclear Energy Institute (NEI)
Jim Gleason GLSEQ, LLC Darryl Harmon Westinghouse/IEEE Brian Haynes Framatome David Herrell MPR William Horin Winston & Strawn, LLP Ron Jarrett TVA
Name Affiliation Wayne Johnson Electric Power Research Institute (EPRI)
Eugene Keller Talen Energy Susquehanna Nuclear LLC Robert Konnik IEEE Cece Lamah Columbia Generating Station Andrew Mantey EPRI John Minley Southern Nuclear Warren Odess-Gillett Westinghouse James Parello IEEE Ted Quinn Technology Resources/ International Electrotechnical Commission (IEC)
David Rickenbach Meeting Attendee Jim Sharkey EPRI Carlos Sisco Winston & Strawn Carol Smidts Ohio State University Donald Spellman Xcel Engineering Mostafa Taha Columbia Generating Station Chew Charn Tan Meeting Attendee Dzung Tonthat Meeting Attendee Steve Vaughn NEI Yvonne Williams Bechtel National Michael Wiwel PSEG Nuclear