ML22279B059

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Staff Response to ACRS on RG 1.250
ML22279B059
Person / Time
Issue date: 10/18/2022
From: Raymond Furstenau
Office of Nuclear Regulatory Research
To: Rempe J
Advisory Committee on Reactor Safeguards
References
Download: ML22279B059 (3)


Text

MEMORANDUM TO:

Joy L. Rempe, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 FROM:

Raymond V. Furstenau, Director Office of Nuclear Regulatory Research Coffin, Stephanie signing on behalf of Furstenau, Raymond on 10/18/22

SUBJECT:

STAFF RESPONSE TO ACRS LETTER, DATED SEPTEMBER 27, 2022, IN REGARD TO PROPOSED NEW REGULATORY GUIDE 1.250, DEDICATION OF COMMERCIAL-GRADE DIGITAL I&C ITEMS FOR USE IN NUCLEAR POWER PLANTS The purpose of this memorandum is to provide the U.S. Nuclear Regulatory Commission (NRC) staff's response to the Advisory Committee on Reactor Safeguards (ACRS) letter dated September 27, 2022, (Agencywide Document Access and Management System (ADAMS)

Accession No. ML22264A193) on the proposed new Regulatory Guide (RG) 1.250, Dedication of Commercial-Grade Digital I&C Items for Use in Nuclear Power Plants, (ADAMS Accession No. ML22003A180).

During the 698th meeting of the ACRS, September 7-9, 2022, the Committee reviewed proposed new Regulatory Guide (RG) 1.250. In addition, the ACRS Digital Instrumentation and Control (DI&C) Systems Subcommittee (SC) reviewed this matter on July 21, 2022. In the letter dated, September 27, 2022, the ACRS provided conclusions and recommendations on proposed new RG 1.250.

The staff has carefully considered the Committees feedback to ensure the RG adequately addresses the stated concerns as well as the needs of other internal and external stakeholders.

In response, the staff has updated Section B, Discussion, of RG 1.250 to include the following paragraph:

The application of digital technology to the design and configuration of nuclear power plant safety systems requires careful consideration of NRC guidance pertaining to safety system architecture, failure modes and effects analysis, and the application of defense in depth principles. Prior to the selection of equipment to be used in accomplishing the required safety functions, a proposed digital safety system design should be completed, evaluated, and accepted to the extent that all required characteristics of the proposed digital safety system design have been identified and specified, and the dedication process only begins when the design is complete and accepted. The equipment that is selected to perform the required safety functions must be shown to meet applicable technical and quality requirements.

CONTACTS: Dinesh Taneja, NRR/DEX/ELTB Michael Eudy, RES/DE/RGPMB 301-415-0011 301-415-3104 October 18, 2022

J. Rempe 2

The staff plans to issue RG 1.250 within one week of this memorandum. In addition, upon issuance of the RG, the staff will be updating Inspection Procedure (IP)-71111, Attachment 21N.03, "Commercial Grade Dedication," (ADAMS Accession No. ML22075A251). The updates will include references to RG 1.250 and associated guidance documents for dedication of commercial digital equipment. Accordingly, the training program on this inspection procedure for the NRC inspectors will also be updated.

Memo: ML22279B059

  • via Econcurrence OFFICE RES/DE/RGPMB NRR/DEX/ELTB TL NRR/DRO/IQVB NRR/DEX/ELTB BC NAME M. Eudy D. Taneja G. Galletti J. Paige DATE 10/07/2022 10/07/2022 10/11/2022 10/11/2022 OFFICE RES/DE/RGPMB BC NRR/DEX Dir RES/DE Dir RES Dir NAME M. Rahimi E. Benner L. Lund R. Furstenau S. Coffin for DATE 10/13/2022 10/13/2022 10/17/2022 10/18/2022 All concurrence received via Email or Econcurrence