ML22299A109
| ML22299A109 | |
| Person / Time | |
|---|---|
| Issue date: | 11/17/2022 |
| From: | Bhagwat Jain NRC/NRR/DORL/LPL4 |
| To: | NRC/NRR/DEX/EXHB |
| Shared Package | |
| ML22299A108 | List: |
| References | |
| Download: ML22299A109 (1) | |
Text
U.S. Nuclear Regulatory Commission Public Meeting Summary November 17, 2022
Title:
Public Meeting on the U. S. Nuclear Regulatory Commission Staffs SECY-22-0076 Regarding Expansion of the Current Common-Cause-Failure Policy for Digital Instrumentation and Controls Systems Meeting Identifier: 20221046 Date of Meeting: October 20, 2022, 02:00 PM to 4:00 PM ET Location: Webinar Type of Meeting: Comment-Gathering Purpose of the Meeting:
The purpose of this meeting with external stakeholders was to inform and solicit their feedback on the U.S. Nuclear Regulatory Commission (NRC) staffs SECY-22-0076 regarding expansion of the current NRC policy for addressing common-cause-failure (CCF) for digital instrumentation and control (DI&C) systems.
General Details:
The meeting was a virtual meeting conducted via Microsoft Teams platform. The meeting started on schedule at 2:00 PM (Eastern Time (ET)) and concluded at 4:00 PM (ET). The webinar was attended by over 80 participants. A list of attendees and the organization they represent is provided in the enclosure. The meeting proceedings were transcribed, and the meeting transcript is available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML22298A012.
Summary of Presentations:
The NRC staff from the Office of Nuclear Reactor Regulation (NRR), Division of Engineering and External Hazards (DEX) presented recent activities (ML22291A015 and ML22297A213) and the status of SECY-22-0076 (ML22193A290). The NRR staff held an open dialogue and engaged the stakeholders in robust discussion and received their differing perspectives on the need for diverse and independent manual controls and displays for critical safety functions which are necessary to maintain plant safety.
The NRC staff provided the summary of the proposed expanded policy, the staffs position on the Advisory Committee on Reactor Safeguards (ACRS) questions from the September 23, 2022, briefing to the DI&C Systems ACRS Subcommittee, the applicability, and clarifications of Point 4 in the proposed expanded policy, and the staffs position on diverse and independent main control room displays and manual controls.
Overall, the NRC staff delivered the following key messages to stakeholders.
The proposed expanded policy in SECY-22-0076 encompasses the current four points of Staff Requirements Memorandum (SRM)-SECY-93-087, SECY-93-087 - Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advance Light-Water Reactor (ALWR) Designs (with clarifications), and expands the use of risk-informed approaches in Points 2 and 3.
Points 1-3 and Point 4 of SECY-22-0076 address two facets needed to ensure safe operation of the plant:
- Points 1-3 ensure DI&C systems are sufficiently robust to adequately cope with CCF
- Point 4 ensures operators can manually control critical safety functions even in the event of a DI&C systems CCF Point 4 incorporates an implicit element of risk-informing as it focuses only on those critical safety functions needed to ensure the safety of the facility.
The expanded policy in SECY-22-0076 is intended to be technology neutral and applies to any reactors (including non-light-water reactors) licensed under Title 10 of the Code of Federal Regulations Parts 50, Domestic Licensing of Production and Utilization Facilities, and 52, Licenses, Certifications, and Approvals for Nuclear Power Plants..
The NRC staff acknowledges that the critical safety functions listed in SRM-SECY-93-087, SECY-22-0076 and Branch Technical Position 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 (i.e., reactivity control, core heat removal, reactor coolant inventory, containment isolation, and containment integrity), dated January 2021 (ML20339A647), may not be the appropriate set for all reactor designs.
SECY-22-0076 provides for existing regulatory tools (exemptions and alternatives), if necessary, to accommodate for reactor designs with different critical safety functions.
If the NRC staff encounters a reactor design where the policy in SECY-22-0076 would not be applicable, the staff will engage the Commission as appropriate.
Public Participation Themes:
A summary of feedback and comments expressed by members of the public are provided below.
Summary of Stakeholders Key Comments on Point 4 of SECY-22-0076 Nuclear Energy Institute (NEI) commented that Point 4 requires a separate analysis which is too onerous. Some stakeholders differed and expressed their opinion that no separate analysis is required and that there is no single way to perform defense-in-depth and diversity analysis.
NEI stated that Point 4 requires additional manual controls and displays which are unnecessary to maintain plant safety. The NRC staff and some stakeholders provided their differing opinion and explained that Point 4 of the proposed policy ensure that operators can take manual actions of critical safety functions even after a DI&C systems CCF.
NEI commented that Point 4 is one additional and unnecessary layer to cope with a CCF.
NEI commented that they want to move towards the use of modern digital control rooms (e.g., glass control rooms).
NEI presented an example of advanced pressurized-water reactor (APWR) design (ML22298A009) to support its view that Point 4 requires an additional layer of diversity.
(The NRC staff noted that the APWR is not a certified and approved design by the NRC.)
After the meeting, the NRC staff received written comments from four stakeholders: Mr. Ken Scarola (ML22297A144), Mr. Thomas Gurdziel (ML22298A038), and NEI (ML22297A248).
The public comment-gathering meeting met its objective of engaging the NEI, nuclear industry representatives, and members of the public in a public discussion on NRC staffs SECY-22-0076 regarding the proposed expansion of the current CCF policy. The stakeholders provided their feedback and comments which are captured and summarized herein. The meeting was attended with over 80 participants. Stakeholders comments were primarily focused on interpretation of Point 4 in the proposed policy related to diverse and independent main control room displays and manual controls.
Action Items/Next Steps:
The stakeholders discussed several technical aspects that were focused on the implementation guidance. After the Commission votes and issues the SRM to SECY 22-0076, the NRC staff will consider stakeholders feedback and comments in the development of the guidance to implement the policy in the SRM to SECY 22-0076, as appropriate.
At the end of the meeting, NRC management gave closing remarks. No regulatory decisions were made. NEI, other nuclear industry representatives, and members of the public provided comments. Public Meeting Feedback forms were not received. Please direct any inquiries to me at 301-415-6303 or via email at Bhagwat.Jain@nrc.gov.
Sincerely,
/RA/
Bhagwat Jain, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosure:
List of attendees
LIST OF ATTENDEES OCTOBER 20, 2022, PUBLIC COMMENT GATHERING MEETING ON SECY 22-0076 REGARDING EXPANSION THE CURRENT COMMON-CAUSE-FAILURE POLICY FOR DIGITAL INSTRUMENTATION AND CONTROL SYSTEMS Microsoft Teams Meeting ATTENDEE ORGANIZATION1 Eric Benner U.S. Nuclear Regulatory Commission (NRC)
Jason Paige NRC Bhagwat Jain NRC Shilp Vasavada NRC Steve Wyman NRC Ming Li NRC Mo Sadollah NRC David Rahn NRC Sergiu Basturescu NRC Sunil Weerakkody NRC Bill Roggenbrodt NRC Dinesh Taneja NRC Norbert Carte NRC Cavin Cheung NRC Steven Alferink NRC Gregg Galletti NRC Christopher Cook NRC Eric Bowman NRC Sheldon Clark NRC Tony Nakanishi NRC Joseph Ashcraft NRC Richard Stattel NRC Samir Darbali NRC Jamie Heisserer NRC Roy Hardin NRC Dante Johnson NRC Hang Vu NRC Ian Jung NRC Jack Zhao NRC Stephen Campbell NRC Michael Marshall NRC Derek Halverson NRC Khoi Nguyen NRC Maxine Keefe NRC Andrea Kock NRC Mauricio Gutierrez NRC Charles Peabody NRC Enclosure
ATTENDEE ORGANIZATION1 Jennifer Dixon-Herrity NRC Francis Novak General Electric Power Robert Chenkovich Dominion Energy Robert Atkinson Dominion Energy Shayan Sinha Dominion Energy Stephen Kenney Dominion Energy Marry Miller Dominion Energy Svetlana Lawrence Idaho National Laboratory Han Bao Idaho National Laboratory Alan Campbell Nuclear Energy Institute Thomas Basso Nuclear Energy Institute Warren Odess-Gillett Westinghouse Electric Company LLC Jeffrey Stone Constellation Energy Generation, LLC (Constellation)
Rick Ashley Constellation Philip Tarpinian Constellation Frank Mascitelli Constellation Warren Busch Florida Power and Light Steve Kincaid Kairos Power Paul Heaney MPR Associates Jana Bergman Curtiss-Wright Mark Burzynski Sunport Brian Haynes Framatome Ron Jarrett Framatome Abdelnaeem Taha Framatome Jacek Nowakowski Framatome Philip Opsal Framatome Ken Scarola Unknown Neil Archambo Unknown Ron Jarrett Unknown Patrick Essner Unknown Rayan Lentz Unknown Dough Eskins Unknown Jerry Mauck Unknown Lou Gaussa Unknown Mike Dunevant Unknown Tom Gurdziel Unknown Luke Karten Unknown Arthur Holtz Unknown Zackery Helgert Unknown Stephen Middlekauff Unknown Steh Wesley Unknown Richard Paese Unknown Alan Smith Unknown De Wu Unknown Mohammad Alavi Unknown Bruce Hallbert Unknown David Beaulieu Unknown
ATTENDEE ORGANIZATION1 William Freebairn Unknown Andrew Zach Unknown
ML22299A109 *by email OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DEX/ELTB/BC*
NAME BJain PBlechman JPaige DATE 10/26/2022 11/17/2022 11/17/2022 OFFICE NRR/DORL/LPL4/PM*
NAME BJain DATE 11/17/2022