ML22341A012

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December 12, 2022 Nuclear Regulatory Commission and Boiling Water Reactor Owners Group Executive Oversight Committee Meeting - NRC Presentation
ML22341A012
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Issue date: 12/12/2022
From: Ngola Otto
Licensing Processes Branch
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ML22341A010 List:
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Nuclear Regulatory Commission and Boiling Water Reactor Owners Group Executive Oversight Committee Meeting December 12, 2022

Agenda Time Topic Speaker 1:00 PM Public Meeting Start / Introductions Ngola Otto, NRR, DORL BWROG Project Manager 1:05 PM NRC Opening Remarks Mike King, NRR, Deputy Office Director for Reactor Programs 1:10 PM BWROG Introduction Steve Douglas, BWROG Executive Chairman

  • Meeting Objectives & BWROG Overview 1:20 PM Emergency Procedures Committee and Emergency Procedures and Severe Accident Guidelines (EPG/SAG) Rev. 4 Update Bill Williamson, BWROG 1:30 PM Risk Topics (BWROG) Robert Rishel, BWROG Integrated Risk Informed
  • NRC Endorsement of Institute of Electrical and Electronics Engineers (IEEE) 1819 and endorsed NEI Guidance for Regulation Committee Chairman 50.69
  • ASME/IEEE Components Standards that could be developed to replace/supplement NRC endorsed NEI 50.69 Guidance

Opening Remarks Michael King Deputy Office Director for Reactor Programs Office of Nuclear Reactor Regulation 3

NRC Staff Review of Requests for Withholding of Proprietary Information Tom Wengert Office of Nuclear Reactor Regulation December 12, 2022

Key Messages

  • Release of public information is an important aspect of NRCs mission and its value of public openness.
  • 10 CFR 2.390 contains the requirements for submitting and requesting withholding of proprietary information.
  • NRR Office Instruction LIC-204, Rev. 4, provides guidance for the NRC staffs review and disposition of withholding requests.
  • A good understanding of the requirements for proprietary submittals and reviews by the NRC staff and the industry will improve the effectiveness of the process.
  • The NRC currently plans to transition to a Controlled Unclassified Information (CUI) program on November 1, 2023.

5

Overview of Applicable Regulations

  • Governing regulation: 10 CFR 2.390, Public inspections, exemptions, and requests for withholding.
  • NRC is required by 10 CFR 2.390(a) to make public final NRC records, including correspondence to and from the NRC.
  • For submittals requesting withholding of proprietary information, the NRC must make a determination on the request.
  • Basic requirements of 10 CFR 2.390 Types of documents that can be withheld [2.390(a)]

Marking requirements [2.390(b)(1)(i)]

Affidavit requirements [2.390(b)(1)(ii)]

NRC criteria for making a determination [2.390(b)(3) and (4)]

6

Overview of NRC Staff Review Process

  • NRC Management Directive 3.4, Release of Information to the Public, describes the agencys policy governing the public availability of information in NRC's possession, including the receipt and handling of sensitive proprietary information.
  • NRR Office Instruction LIC-204, Handling Requests to Withhold Proprietary Information from Public Disclosure, Revision 4, contains guidance for the NRC staffs review and disposition of proprietary withholding requests.
  • Basic Requirements Affidavit or Unsworn Testimony Marking of Information Sought to be Withheld Proprietary Determination by NRC Staff Issuance, Correspondence, and Documentation of the Proprietary Determination 7

Examples of Recent Issues with Proprietary Withholding Requests

  • Requests to withhold information that is already in the public domain
  • Proprietary information unredacted
  • Marking of documents [10 CFR 2.390(b)(1)(i)]

Statement of clear basis for withholding [b)(1)(ii)(C)]

Specific harm statement [(b)(1)(ii)(D)]

Statement of reason for withholding [(b)(1)(iii)]

Affidavit signer: Owner vs. Submitter of information [(b)(1)(iii)]

  • Proprietary slide presentations - withholding request with affidavit must be submitted in advance to allow staff to review and make a withholding determination prior to the meeting.

8

Summary

  • Release of public information is an important aspect of NRCs mission and its value of public openness.
  • 10 CFR 2.390 contains the requirements for submitting and requesting withholding of proprietary information.
  • NRR Office Instruction LIC-204, Rev. 4, provides guidance for the NRC staffs review and disposition of withholding requests.
  • NRC staff will engage licensees/applicants/vendors if there are questions or disagreements on assertions of withholding.
  • A good understanding of the requirements for proprietary submittals and reviews by the NRC staff and the industry will improve the effectiveness of the process.

9

References

  • 10 CFR 2.390, Public inspections, exemptions, requests for withholding
  • NRR Office Instruction LIC-204, Handling Requests to Withhold Proprietary Information from Public Disclosure, Revision 4 (ADAMS Accession No. ML20049A139)
  • Controlled Unclassified Information (CUI) Program - NRC public website:

https://www.nrc.gov/reading-rm/cui.html 10

Questions?

11

Update on Inspection Plans and Schedule for EPG/SAG Rev. 4 Aron Lewin Office of Nuclear Reactor Regulation December 12, 2022

71111.18 SAMG Update Sample

  • To date, no findings have been identified.
  • Following CY2022, IP 71111.18 will indicate that the SAMG update sample be performed as required.

(see ADAMS ML22154A389) 13

Traveler TSTF-576, Revise Safety/Relief Valve Requirements Michelle Honcharik Office of Nuclear Reactor Regulation December 12, 2022

Overview of NRC Staff Review Process

  • Status:

- The traveler is under review by the NRC staff. A second round of Requests for Additional Information (RAI) questions were drafted, and a clarity call was held in October 2022.

  • Technical concern:

- The NRC staff has not been provided adequate assurance that the methodology that will be used to control the Safety/Relief Valve (SRV) setpoints is acceptable. The SRV setpoints can affect the ability of SSCs to respond to or operate through postulated accidents. The NRC staff has been unable to confirm that the methodology will be consistent with approved methods or that the staff will be able to verify adequate response to postulated accidents.

  • Next Steps:

- TSTF will be discussing how to proceed with the BWROG licensing committee in December.

15

  • Maintain risk-informed focus.
  • Identify deficient conditions that would not normally be readily identifiable through routine plant activities or performance indicators (e.g., monitoring during normal operation or surveillance tests).
  • Allow inspections that are focused on recent plant changes and operating experience.
  • Maintain the NRC's role as an independent regulator.

17

  • On July 21, 2022, the NRC Commission approved SECY 0053, Recommendation for Modifying the Periodicity of Reactor Oversight Process Engineering Inspections
  • Approved changing engineering inspections from a 3-yr to a 4-yr cycle.
  • 4 Engineering inspections will be conducted at each site in the 4-year cycle.
  • Comprehensive Engineering Team Inspection (CETI)
  • 3 Focused Engineering Inspections (FEI)s.

18 18

  • 4 Engineering inspections will be conducted at each site in during the 4-year cycle.
  • Comprehensive Engineering Team Inspection (CETI)
  • Combines the current IP 71111.21M Design Bases Assurance Inspection (Team) with the triennial portions of IP 711111.07 Heat Exchanger/Sink Performance, and IP 71111.17T,Evaluations of Changes, Tests and Experiments
  • 3 Focused Engineering Inspections (FEI)s.
  • *IP 71111.21N.04 Age-Related Degradation
  • New Inspections 19 19
  • Team makeup: 7 inspectors, 2 onsite weeks (490 direct inspection hours)

We no longer use contractors as routine support for inspections

  • Same preparation for inspections as previous DBAI (team) inspections.

20 20

CGD inspection objectives To review the implementation of the licensees process for dedicating commercial-grade items (CGIs), as required in applicable portions of Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 (Appendix B) to ensure reasonable assurance is provided that CGIs will perform their intended safety function.

To review implementation of the licensees procurement process for safety-related components as required in Appendix B or 10 CFR 50.69.

21 21

Technical/process and inspection implementation training conducted for each regions engineering inspectors.

Training includes table-top scenarios NRC Technical and Programmatic leads identified NRC internal cross-regional panels will be held post inspection (first 6 months of implementation to ensure consistency) 22 22

Inspection Procedure IP71111.21N.04 is in development. Currently out for 30-day comment period until November 14. To be completed and publicly available by end of December 2022 First ARD inspections to begin after July 2023 23 23

DRAFT Objectives To verify that maintenance activities to address age-related degradation for structures and components (SCs) are being conducted in a manner that provides reasonable assurance of the safe operation of the plant.

To verify that age-related degradation for plant SCs are appropriately identified, addressed, and corrected.

24 24

ARD inspection will sample both active and passive components This is NOT an aging-management program inspection.

Age-related issues, aging components or phenomenon that accelerates the age of components.

Likely around 12-24 samples.

Sample selection heavily informed by operational experience.

25 25

Technical and inspection implementation training will be developed and conducted for each regions engineering inspectors.

Training will include table-top scenarios NRC will identify Technical and Programmatic leads NRC internal cross-regional panels will be held post inspection to ensure consistency 26 26

Questions?

27

Douglas Bollock Senior Reactor Operations Engineer Office of Nuclear Reactor Regulation Division of Reactor Oversight Reactor Inspection Branch Email: douglas.bollock@nrc.gov; Phone: 301-415-6609 28

Subsequent License Renewal License Renewal & Environmental Reviews Lauren Gibson, Branch Chief, License Renewal Projects Ted Smith, Branch Chief, Environmental Review License Renewal

Peach Bottom Units 2 & 3 Turkey Point Units 3 & 4 (FL) Surry Units 1 & 2 (VA)

(PA)

NEW expiration 2052 & 2053 NEW expiration 2052 & 2053 NEW expiration 2053 & 2054 COMPLETED 12/2019 COMPLETED 05/2021 (ML19191A057) COMPLETED 03/2020 (ML20052F523)

(ML20044D902)

North Anna Units 1 & 2 (VA) Point Beach Units 1 & 2 (WI) Oconee Units 1, 2 & 3 (SC) St. Lucie Units 1 & 2 (FL)

Accepted for review 10/2020 Accepted for review 01/2021 Accepted for review 07/2021 Accepted for review 09/2021

= Site Specific Environmental Report Submitted 30

Comanche Peak Units 1 & 2 (TX)

Submitted 10/2021 Acceptance Review In Progress 31

Review ACRS Full Committee SER Review Annual Updates PM Holds Resume Normal Process Environmental ACRS Full Committee Seems Close Reviewers SER, Rev 1 or confirm input Supplement and PM compiles 32

Turkey Point North Anna Oconee The NRC intends to

  • review all applicable Category 1 (generic) issues listed in the applicable SEIS Table 4-1 for site-specific findings (e.g., SMALL, MODERATE, LARGE) using the methodology in the LR GEIS and document staffs analysis 33

The NRC intends to

  • review applicable Category 2 (site-specific) issues listed in the applicable SEIS Table 4-2 for new information since the issuance of the site-specific draft or final SEIS and update site-specific analyses
  • issue a notice of availability that begins a limited scoping period (comments invited; no public meeting)
  • complete a (virtual) environmental audit, including issuing RAIs and RCIs, as appropriate 34

The NRC intends to issue a site-specific draft SEIS or draft SEIS supplement for public comment, and a notice of opportunity for hearing issue a site-specific final SEIS or final SEIS supplement to provide staffs recommendation on whether to authorize the licensing action 35

Timeline: Planned Path Forward Approximate Milestone Timing Site-specific environmental license renewal 0

application supplement received by NRC NRC publishes availability of supplement 15 days Federal Register notice (FRN)

NRC publishes notice of intent to prepare an EIS supplement and start of 30-day scoping period, 30 days as appropriate, FRN Scoping period ends (if one is conducted) 60 days Conduct environmental audit 4 months NRC issues environmental RAIs/RCIs (if needed) 5.5 months NRC receives RAI/RCI responses 6.5 months 36

Timeline: Planned Path Forward (continued)

Approximate Milestone Timing NRC publishes draft SEIS supplement or draft SEIS and FRNs to start 45-day comment period and 60-day period to 12 months request a hearing Draft SEIS supplement or draft SEIS comment period ends 13.5 months Publish final SEIS supplement or final SEIS and FRN 14.5 months EPA Issues FRN - final SEIS supplement, or final SEIS, notice of availability and beginning of 30-day cooling off 15 months period NRC issues FRN - renewed license/record of decision 16.5 months, unless (assuming no comments during EPA cooling off period or hearing(s) held per Commission direction, as appropriate) 37

Based on Notices of Intent, we are expecting 6 applications by the end of FY24.

Resources are projected to be tight.

Please continue to send in Notices of Intent so we can plan.

38

39 Digital Instrumentation and Controls Michael Waters Office of Nuclear Reactor Regulation December 12, 2022

What Ill Be Covering Today

  • NRC Vision
  • Accomplishments
  • Ongoing Initiatives Photo: Rendering of Limericks Main Control Room displays for planned Plant Protection System, : ML21063A119 41 41

NRC Vision for Digital I&C A clear regulatory structure with reduced regulatory uncertainty that enables the expanded safe use of digital I&C in commercial nuclear reactors while continuing to ensure safety and security.

From NRC SECY-19-0112 42

Accomplishments 43

Clear Expectations for Implementing 10 CFR 50.59 Chiller Controls Diesel Generator Controls Feedwater/Turbine Control System 44

NRC DI&C Interim Staff Guidance (ISG) 06 Revision 2 Timeline (not to scale)

Traditional Process LA Issued LAR Submitted NRC Review and Audits NRC Regional Inspection (Phase 1 Information) Processes Phase 2 Supplemental Information Licensee Activities Concepts High Level Implementation, Detailed HW & SW Design Installation and and Pre-application System Design, Software V&V, and Meetings and Fabrication Site Acceptance Testing Planning Factory Testing Alternate Review Process LA Issued NRC Vendor NRC Regional Inspection LAR Submitted NRC Review and Audits Inspection Processes Processes All Information 45

NRC Branch Technical Position 7-19 Defense-in-Depth and Diversity to Address DI&C CCF Incorporates a Risk-Informed Graded Approach Incorporates Lessons-Learned from Previous Operating Reactor and New Reactor Reviews Supports Expanded use of Defensive Measures to Address Software CCF 46

Non-Light-Water Reactor I&C Design Review Guide (DRG)

Supports NRCs Non-LWR Vision and Strategy, Implementation Action Plan Strategy 3, which involves developing:

1) guidance for flexible regulatory review processes for non-LWRs within the bounds of existing regulations
2) non-LWR regulatory framework that is risk-informed, performance-based, and features NRC staffs review efforts commensurate with the demonstrated safety performance of non-LWR technologies.
3) Incorporates principles from RG 1.233 and NRC Vision and Strategy: Safely Achieving Effective and Efficient Non-Light Water Reactor Mission Readiness, which describes the NRCs vision and strategy for preparing for non-LWR reviews.

47

Just Released--Reg Guide 1.250: Dedication of Commercial-Grade Digital I&C Items in Nuclear Plants Endorses NEI 17-06 Rev. 1 and IEC-61508 with clarifications Provides supplemental guidance for performing commercial grade dedication of digital technology equipment by leveraging 3rd party certifications of digital I&C equipment to determine the acceptability of the dependability critical characteristics of that equipment Ensures that the 3rd party certification organizations are regularly accredited by signatories to the International Accreditation Forum Multilateral Recognition Arrangement 48

Ongoing Initiatives 49

DI&C Safety System Licensing

  • License amendment requests for operating reactor digital I&C modernization Turkey Point RPS/ESFAS replacement (July 2022)

Limerick RPS/ESFAS and other system replacement (Sept 2022)

  • Construction Permit Reviews Kairos (Sept 2021)

Abilene Christian University (Aug 2022)

  • Pre-submittal interactions, white papers, topical reports, & reviews supporting advanced reactor I&C designs (2023)

NuScale US460 TerraPower ASL2 Holtec SMR-160 X-Energy MELCO GE BWRX-300 Atomic Alchemy MMR WEC eVinci 50

Risk-Informing Digital I&C CCF Policy

  • The current policy in SRM-93-087 has been effectively used to license digital I&C systems in nuclear power plants A defense-in-depth and diversity (D3) analysis is required to cope with a hypothetical digital CCF that disables a safety function during an accident.

Requires a diverse means of safety actuation if plant consequences could be significant

  • Staff proposed expanding the use of risk information in SECY-22-0076 (August 2022) to address potential alternatives for the D3 analysis
  • Additional stakeholder interactions clarifying the policy on independence of manual actuation displays/controls credited in the D3 analysis 51

Continue work on Reg Guides Endorsing Updated Standards

  • Endorsement of IEEE 7-4.3.2-2016 (RG 1.152)
  • Endorsement of IEEE-1012-2106 and streamlining of Guides for IEEE computer society standards (RGs 1.168 - 1.173) 52

Summary

  • Early engagement and pre-submittal meetings are critical
  • NRC will continue to engage stakeholders on regulatory needs and guidance development activities
  • Potential Interactions in 2023 RG 1.153 Workshop (~March)

Advanced Reactor Workshop(s) (TBD)

DI&C Licensing Lessons Learned Workshop (April -May) 53

Questions?

Clear 50.59 Efficient Expectations Licensing NEI 96-07 BTP Endorsement of App. D RIS ISG Updated Standards NRC 7-19 2002-22 06 NEI CCF Sup. 1 17-06 IEEE IEC 54

Opportunity for Public Questions and/or Comments 55

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