ML21083A162

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Summary of Digital Instrumentation and Controls Workshop Related to Lessons Learned and Insights Gained from the Use of the Alternate Review Process in Di&C ISG-06, Licensing Process, Revision 2
ML21083A162
Person / Time
Issue date: 03/19/2021
From: William Roggenbrodt
NRC/NRR/DEX/EICB
To: Jeanne Johnston
NRC/NRR/DEX/ELTB
Roggenbrodt, William A 301-415-0678
References
Download: ML21083A162 (9)
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March 19, 2021 MEMORANDUM TO: Jeanne Johnston, Chief Long Term Operations and Modernization Branch Division of Engineering and External Hazards Office of Nuclear Reactor Regulation FROM: William Roggenbrodt, Electronics Engineer - Digital I&C /RA/

Instrumentation and Controls Branch Division of Engineering and External Hazards Office of Nuclear Reactor Regulation

SUBJECT:

MEETING

SUMMARY

OF FEBRUARY 10, 2021, DIGITAL INSTRUMENTATION AND CONTROLS WORKSHOP RELATED TO LESSONS LEARNED AND INSIGHTS GAINED FROM THE USE OF THE ALTERNATE REVIEW PROCESS IN DIGITAL INSTRUMENATION AND CONTROLS INTERIM STAFF GUIDANCE 06, LICENSING PROCESS, REVISION 2 On February 10, 2021, the U.S. Nuclear Regulatory Commission (NRC) staff held a virtual Category 2 public meeting with various industry stakeholders. The purpose of the meeting was to share insights and discuss the lessons learned related to the use of the Alternate Review Process (ARP) described in Digital Instrumentation and Controls (DI&C) Interim Staff Guidance (ISG)-06, Licensing Process, Revision 2, dated December 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18269A259). The meeting notice and agenda were posted to the NRCs public website prior to the meeting (ADAMS Accession No. ML21028A747).

The ARP is one of two licensing review processes in DI&C-ISG-06 and allows the NRC staff to reach a licensing decision for DI&C upgrades earlier in the product development lifecycle than under the traditional licensing process. The ARP includes an added focus on the software development plans and vendor oversight plan (VOP), rather than the software outputs and the results of integration testing during the latter stages of system development provided in the traditional license amendment process in Revision 2 and in earlier revisions of DI&C-ISG-06.

The workshop began with a presentation by the NRC staff related to activities associated with guidance development and inspections for DI&C system upgrades performed under Title 10 of the Code of Federal Regulations (10 CFR) 50.59, Changes, tests and experiments, process.

The remainder of the workshop addressed licensing activities and insights related to the DI&C-ISG-06 ARP. Both NRC staff and industry stakeholders provided presentations dealing with improvements to the DI&C regulatory infrastructure, specifically, DI&C-ISG-06, Revision 2, which supports modernization efforts for instrumentation and controls (I&C) systems.

J. Johnston Staff from the NRCs Office of Nuclear Reactor Regulations Division of Engineering and External Hazards and the Division of Reactor Oversight presented topics related to the DI&C upgrades under the 10 CFR 50.59 process, the status of infrastructure development activities, information regarding historical and current licensing activities related to DI&C ISG-06, and insights and lessons learned based on recent licensing activities associated with the ARP.

Representatives from Idaho National Laboratory, Dominion Energy, Exelon Generation, Entergy, Southern Nuclear, and the Nuclear Energy Institute (NEI) provided presentations related to their experience with or intent to use the DI&C-ISG-06 ARP.

A period for open discussion was held along with a period for public comments following the presentations made by both the staff and industry representatives during the morning and afternoon sessions.

A written transcript of the workshop has been made publicly available (ADAMS Accession No. ML21060B547).

The following material was presented during the workshop:

  • Exelon Generation - Leveraging Regulatory and Technical Initiatives for Digital Transformation of Limerick Station (ADAMS Accession No. ML21034A603)
  • Idaho National Laboratory - Light Water Reactor Sustainability Program - Program Overview (ADAMS Accession No. ML21034A609)
  • The staff presented information related to 10 CFR 50.59 inspection activities, background on the optional DI&C-ISG-06 ARP development, and its current licensing activities.
  • Stakeholders had specific questions about guidance documents such as Branch Technical Position (BTP) 7-19, Revision 8, Guidance for Evaluation of Defense in Depth and Diversity to Address Common-Cause Failure Due to Latent Design Defects in Digital Safety Systems, and the plans for revising regulatory guides noted in NRC Slides. NRC staff noted the completion of BTP 7-19, and indicated that RG 1.153 should be the first RG that could be published for comment in the fall of 2021.

J. Johnston Industry Modernization and Licensing Plans

  • Industry and U.S. Department of Energy representatives presented their modernization efforts with a common theme of reducing operations and maintenance costs and maintaining long-term plant sustainability:

o Exelon Generation - Limerick: An Exelon representative presented its general plans for plant control room modernization at Limerick, which include the reactor protective system, the redundant reactivity control system, the nuclear steam supply shutoff system, and the emergency core cooling system. The representative displayed a graphic that showed a significant portion of the main control room that would become digital in display, control logic, and alarm functionality. The representative noted Exelon is targeting installation of the equipment by 2024 in a single outage.

o Dominion - North Anna and Surry: A Dominion representative stated it is in the planning and vendor selection phases for modification of a significant number of I&C systems, both safety-related and non-safety-related, in order to standardize the systems at each of the plants in five phases. Each main control room will be upgraded during this project, and at least one new simulator will be added. The first system would be installed in 2022 (under 10 CFR 50.59) with a goal of completing Surry and North Anna upgrades in 2028 and 2031, respectively. Dominion intends on sending a letter of intent to NRC for a DI&C upgrade license amendment request in 2023.

o Southern Nuclear: A Southern Nuclear representative discussed its Modernization Implementation Plan related to their digital strategy and the use of a centralized design organization. The representative indicated that digital upgrades for Southern Nuclear plants are current planned in the 2030s timeframe.

o U.S. Department of Energy/Idaho National Laboratory: An INL representative presented key activities supporting industry through their Light Water Reactor Sustainability Program. The focus of the work related to their public/private partnership with Exelon Generation and their study on cost analysis and justification, as well as human factors engineering. The results of the report were made public in their Phase Implementation Report (https://www.osti.gov/biblio/1662013).

o There was significant dialogue among industry stakeholders on several implementation aspects for these specific plant upgrades and DOE activities.

  • The staff communicated the following aspects related to the ARP:

o The ARP is one of two processes within DI&C-ISG-06 and is not a replacement for the traditional Tier 1, 2, and 3 licensing process within DI&C-ISG-06.

o The ARP in DI&C-ISG-06 is intended for projects that are in the earlier phases/stages of lifecycle development (e.g., planning or the beginning of the requirements stages).

J. Johnston o The ARP focuses more on the submitted design, lifecycle development, and procurement processes, whereas the traditional method within DI&C-ISG-06 focuses more on adequate design outputs for each stage of development up to factory acceptance testing.

o The minimization or elimination of surveillance requirements for upgraded DI&C functions and/or systems in NRC technical specifications is based upon a number of factors and will be a plant-specific determination. A licensee needs to demonstrate that self-diagnostics can be credited to reduce surveillance requirements with a failure modes and effects analysis, and still perform functional tests of the self-diagnostic tests during operation.

o Audits or inspections may occur both for the ARP and the traditional process, dependent upon where the licensee or its vendor is in the lifecycle development process.

  • Under the ARP, licensing commitments may be used as a mechanism to ensure the as-built system complies with the design attributes and acceptance criteria upon which the NRC safety evaluation is based.
  • The staff also presented lessons learned and perspectives in implementing the DI&C-ISG-06 ARP in three focus areas:

o Pre-application interactions and licensing tools (e.g. biweekly public meetings, open item lists, and electronic portals).

o The VOP and role of vendor inspections, regional inspectors, and relevant inspection procedures.

o Other technical areas such as crediting self-diagnostics, response times assumed in accident analyses, and diversity and defense in depth analyses.

  • Many questions were asked by industry, primarily on the VOP and the relationship of vendor inspection activities to license amendment request review activities.
  • The NRC staff acknowledged issues and some challenges associated with implementing the VOP guidance within the ARP and provided additional insights from an on-going licensing review of a lead plant employing the process. The NRC staff clarified that the software development plans, in combination with the VOP, provide confidence that (1) the vendor will follow appropriate development and verification and validation processes, and (2) that the licensee will independently confirm key attributes of the lifecycle development process, tailored to its specific digital design, are followed and achieved by the vendor to meet the requirements of Institute of Electrical and Electronics Engineers Standards 279-1971 and 603-1991 and applicable criteria within Appendix B to 10 CFR Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
  • The NRC staff also reaffirmed the role of inspection oversight as part of the ARP paradigm. The NRC staff described the specific inspection procedures that will be used

J. Johnston and how they interface with licensing activities. The NRC staff also discussed the relevance of licensee commitments as a key element of the ARP basis.

NEI Insights on the ARP

  • NEI presented a similar presentation on their insights with a focus on vendor oversight and inspection questions/comments.

o NEI noted the benefit of pre-application meetings and licensing tools (NRCs first bullet).

o Based on lessons learned, NEI noted in part that industry needs to understand the regulatory basis for the VOP, and also that the process presented challenges in resources needed to support NRC licensing and inspection activities during the same time frame for an on-going licensing review.

o NEI summarized that lessons learned can assist future DI&C LAR planning and submittals, and industry still values the ARP to reduce licensing risk.

Next Steps

  • There were no specific follow-up actions.
  • There was a strong consensus for NRC to have a follow-up meeting next year on digital licensing and these topics after both NRC and industry exercise the DI&C-ISG-06 ARP further.
  • An industry stakeholder contacted the NRC shortly after the workshop and requested that NRC hold the next meeting in a separate forum, rather than as part of a future NRC Regulatory Information Conference session, to facilitate the meeting in a more interactive fashion.

The NRC staff did not make any regulatory decisions or commitments at the meeting. No members of the public identified themselves on the teleconference.

Please direct any inquiries to 301-415-0678 or by e-mail to William.Roggenbrodt@nrc.gov.

Enclosure:

List of Attendees

ML21083A162 *via email NRR-106 OFFICE NRR/DEX/ELTB NRR/DRO/IQVB NRR/DEX/EICB NRR/DEX/EICB/BC NRR/DEX/ELTB/BC WMorton for NAME SDarbali* DZhang* RStattel* MWaters* JJohnston*

DATE 3/4/2021 3/4/2021 3/4/2021 3/19/2021 3/19/2021 LIST OF ATTENDEES FEBRUARY 10, 2021, DIGITAL INSTRUMENTATION AND CONTROLS WORKSHOP RELATED TO LESSONS LEARNED AND INSIGHTS GAINED FROM THE USE OF THE ALTERNATE REVIEW PROCESS IN DI&C-ISG-06 Name Organization NRC Attendees Alvarado, Rossnyev NRC Arndt, Steven NRC Ashcraft, Joseph NRC Ayegbusi, Odunayo NRC Beaulieu, David NRC Benner, Eric NRC Bollock, Douglas NRC Cheung, Calvin NRC Chung, Pong NRC Clark, Sheldon NRC Darbali, Samir NRC Dittman, Bernie NRC Dixon-Herrity, Jennifer NRC Frumkin, Daniel NRC Galletti, Greg NRC Garcia, Ismael NRC Gutierrez, Mauricio NRC Hardin, Roy NRC Johnston, Jeanne NRC Keefe, Maxine NRC Keim, Andrea NRC Ki, DaBin NRC Kim, Anya NRC Klett, Audrey NRC Li, Ming NRC Lund, Louise NRC Makor, Shiattin NRC Marshall, Michael NRC Martinez Rodriguez, Erick NRC McKenna, Philip NRC Morton, Wendell NRC Ortega-Luciano, Jonathan NRC Rahn, David NRC Rebstock, Paul NRC Enclosure

2 Name Organization NRC Attendees Roche-Rivera, Robert NRC Roggenbrodt, William NRC Sanders, Serita NRC Seymour, Jesse NRC Shah, Nirodh NRC Stattel, Richard NRC Taneja, Dinesh NRC Vasavada, Shilp NRC Vazquez, Justin NRC Waters, Michael NRC Weerakkody, Sunil NRC Zhang, Deanna NRC Zhao, Jack NRC Name Organization Attendees from Other Organizations Archambo, Neil Duke Energy Armistead, Robert B. "Robin" Naval Nuclear Laboratory (NNL)

Bailey, Michael Bailey Engineering Services, LLC Bajumpaa, Dave Dominion Energy Bergman, Jana Curtiss Wright Burzynski, Mark NewClear Day, Inc.

Busch, Warren NextEra (FPL)

Carmin, Cory Enercon Services Chenkovich, Robert J. Dominion Energy Connelly, John R. Exelon Copeland, Randolph TVA Couture, Phil Entergy DePodesta, Karen Enercon Services Dolfi, James Mitsubishi Electric Power Products, Inc.

Flowers, James Southern Nuclear Flynn, Marty Entergy Freebairn, William S&P Global Platts Frewin, Wesley NextEra (FPL)

Gasque, Jason L TVA Gaston, Ron Entergy Geier, Stephen NEI Golub, Pareez E Sargent and Lundy Grove, John Christian Southern Nuclear Hannaman, William Member of Public Haynes, Brian Framatome Herb, Raymond L. Southern Nuclear

3 Name Organization Attendees from Other Organizations Jarrett, Ron TVA Jentzsch, Kris PG&E Keller, Eugene Talen Energy Mack, Jarrett NextEra (FPL)

Madden, Fred Certrec Mascitelli, Francis Exelon Mauck, Jerry JLM Engineering and Technology Resources Morrison, Charles NRC Contractor Odess-Gillett, Warren R NEI Primer, Craig Idaho National Laboratory Quinn, Ted Technology Resources Remer, Sherman J. Idaho National Laboratory (BEA)

Rosko, Bill Rolls Royce Schrage, John Entergy Shaffer, R Framatone Consultant Supler, Richard Enercon Services Vaughn, Steve NEI Vere, Joseph Zachry Nuclear Engineering Wallen, Cliff Dominion Energy Watkins, James Enercon Services Whittle, C. D. "Whit" Southern Nuclear Wiwel, Mike PSEG Nuclear Zach, Andrew U.S. Senate, Environmental and Public Works Committee

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