ML23123A025
| ML23123A025 | |
| Person / Time | |
|---|---|
| Issue date: | 04/05/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2344 | |
| Download: ML23123A025 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, April 5, 2023 Work Order No.:
NRC-2344 Pages 1-63 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 704TH MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 WEDNESDAY 8
APRIL 5, 2023 9
+ + + + +
10 The Advisory Committee met via hybrid In-11 Person and Video-Teleconference, at 8:30 a.m. EDT, Joy 12 L. Rempe, Chairman, presiding.
13 14 COMMITTEE MEMBERS:
15 JOY L. REMPE, Chairman 16 WALTER L. KIRCHNER, Vice Chairman 17 DAVID A. PETTI, Member-at-Large 18 RONALD G. BALLINGER, Member 19 CHARLES H. BROWN, JR., Member 20 VICKI M. BIER, Member 21 VESNA B. DIMITRIJEVIC, Member 22 GREGORY H. HALNON, Member 23 JOSE MARCH-LEUBA, Member 24 MATTHEW W. SUNSERI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 ACRS CONSULTANT:
1 DENNIS BLEY 2
4 DESIGNATED FEDERAL OFFICIAL:
7 ALSO PRESENT:
8 JOE ASHCRAFT, NRR 9
ERIC BENNER, NRR 10 GILBERTO BLAS RODRIGUEZ, NRR 11 SAMIR DARBALI, NRR 12 KHOI NGUYEN, NRR 13 JASON PAIGE, NRR 14 RICHARD STATTEL, NRR 15 DINESH TANEJA, NRR 16 BRIAN YIP, NSIR 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 CONTENTS 1
Page 2
Call to Order..................
4 3
ACRS Chairman Opening Statement.........
5 4
Agenda and Items of Current Interest 5
5 International Outreach Activities/ACRS Retreat 6
Follow-up Items: Design Reviews, Topical Report 7
Reviews, Committee Work Methods 8
Committee Discussion and Deliberation....
9 Roadmap of Digital Instrumentation and Controls 10 Regulatory Requirements, Industry and 11 Staff Guidance/Commission Meeting Preparation 12 Remarks from Subcommittee Chairman 6
13 Presentation and Discussion........
7 14 Committee Deliberation
.......... 62 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 P-R-O-C-E-E-D-I-N-G-S 1
8:30 a.m.
2 MEMBER REMPE: So good morning. This 3
meeting will now come to order. This is the first day 4
of the 704th meeting of the Advisory Committee on 5
Reactor Safeguards. I'm Joy Rempe, Chairman of the 6
ACRS.
7 Other members in attendance are Ron 8
Ballinger, Vicki
- Bier, Charles
- Brown, Vesna 9
Dimitrijevic, Greg Halnon, Walt Kirchner, Jose March-10 Leuba, Dave Petti and Matt Sunseri. We do have a 11 quorum today.
12 And today the Committee is meeting in-13 person and virtually.
14 The ACRS was established by the Atomic 15 Energy Act and is governed by the Federal Advisory 16 Committee Act. The ACRS Section of the U.S. NRC 17 public website provides information about the history 18 of this Committee and documents such as our charter, 19 bylaws, Federal Register notices for meetings, letter 20 reports and transcripts of all full and subcommittee 21 meetings, including slides presented at the meetings.
22 The Committee provides its advice on 23 safety matters to the Commission through its publicly 24 available letter reports.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 The Federal Register notice announcing 1
this meeting was published on March 9, 2023. This 2
announcement provided a meeting agenda as well as 3
instructions for interested parties to submit written 4
documents or request opportunities to address the 5
Committee.
6 The Designated Federal Officer at today's 7
meeting is Mr. Larry Burkhart.
8 The communications channel has been opened 9
to allow members of the public to monitor the open 10 portions of the meeting. Members of the public can 11 use the MS Teams link to also view slides and other 12 discussion materials during these open sessions. The 13 MS Teams link information was placed in the Federal 14 Register notice and agenda on the ACRS public website.
15 We've received no written comments or 16 requests to make oral statements from members of the 17 public regarding today's session. Periodically, the 18 meeting will be open to accept comments from 19 participants listening to our meetings.
20 Written comments may be forwarded to Mr.
21 Larry Burkhart, today's Federal Officer.
22 During today's meeting, the committee will 23 consider the following topics, follow-up items from 24 our international outreach activities and our ACRS 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 retreat and then roadmap of instrumentation and 1
controls regulatory requirements, industry and staff 2
guidance and commission meeting preparation.
3 A transcript of the open portions of the 4
discussion for the second topic will be kept, and 5
during that time we do request that speakers identify 6
themselves and speak with sufficient clarity and 7
volume so they can be readily heard. Additionally, 8
participants should mute themselves when not speaking.
9 So if not -- do any other members have any 10 opening comments or remarks? So if not, I'd like to 11 ask the court reporter at this time to let us go off 12 the record and then return at 1:00 p.m. for our 13 discussion on Topic 2. Okay?
14 (Whereupon, the above-entitled matter went 15 off the record at 8:32 a.m. and resumed at 1:00 p.m.)
16 CHAIR REMPE: Okay. It is 1:00 p.m. on 17 the East Coast, and we are going to restart. And we 18 are back on the record. And at this point, I'd like 19 to ask Member Brown to lead us through this topic.
20 Charlie?
21 MEMBER BROWN: Well, you're ahead of me.
22 CHAIR REMPE: Turn your mic on, too, 23 please.
24 MEMBER BROWN: I got to find my slides.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 You will have to hold on a second. There they are.
1 All right. We've got a triumphant trio up here who is 2
going to present. I think, Jason, is going to lead 3
off with a few comments. Samir and Gilberto, I'm 4
trying to get the names correct, and they will go 5
through this roadmap.
6 Just for a little intro, I had forgotten 7
how long ago it was, but it was, I don't know, a few 8
couple months ago when Walt and I think Dennis and 9
Greg in some way, shape or -- I think those were the 10 folks who mentioned that after all the Reg. Guides we 11 went through, how were all these interrelated and what 12 do they do and where are we going?
13 So since I was doing all these Reg. Guides 14 and aggravating people, that's part of my job when 15 you're young like I am. So I will turn it over to you 16 all to provide a coherent discussion of where we are 17 going, what the Reg. Guides are for and their 18 orientation and how do they fit together in the big 19 picture? Okay. Have at it, Jason.
20 MR. PAIGE: All right. Thank you. Good 21 afternoon. My name is Jason Paige. I'm the Branch 22 Chief of the Long-Term Operations and Modernization 23 Branch in the Division of Engineering and External 24 Hazards in NRR.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 Our branch leads the strategic 1
enhancements of the agency's INC infrastructure. As 2
you recall and you alluded to, from the full committee 3
meeting on Reg. Guide 1.152 in November of 2022, it 4
was requested that the staff provide an informational 5
briefing on the regulatory infrastructure showing the 6
relationships between the regulations and INC 7
guidance.
8 To prepare for this meeting, this was a 9
collaborative effort between NRR, NSIR and research.
10 Gilberto Blas Rodriguez, the farthest from me, and 11 Samir Darbali, are the co-leads for this effort and 12 will be presenting today.
13 Samir has extensive experience with 14 completing regulatory reviews utilizing the INC 15 infrastructure. Gilberto started at the agency in 16 January of this year. And he served two purposes for 17 co-leading this effort. One, to provide fresh eyes 18 and perspectives to identify ways to clearly 19 communicate our infrastructure. And two, it was used 20 as a training exercise to help him get up to speed on 21 our infrastructure.
22 Before I turn it over to Gilberto and 23 Samir, I will note that our presentation serves two 24 purposes. One it provides a roadmap of our INC 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 infrastructure to show where we started and where we 1
are going to improve the clarity of our 2
infrastructure. And second, it provides the mapping 3
of our infrastructure to show the relationships 4
between the regulations and INC guidance.
5 So thank you for this opportunity to brief 6
you today on our regulatory infrastructure. And I 7
will turn it over to Gilberto.
8 MR. BLAS RODRIGUEZ: Okay. Thank you, 9
Jason. Good afternoon, everyone. My name is Gilberto 10 Blas --
11 MEMBER BROWN: With one hand, pull the mic 12 over toward you, and the speaker is on. And I'll turn 13 mine on. Normally, nobody has a problem hearing me.
14 But he does. Just so that we get full coverage. If 15 you don't get close, then we get lost, and we don't 16 want to miss any of your tidbits.
17 MR. BLAS RODRIGUEZ: All right. Thank 18 you. All right. Good afternoon, everyone. My name 19 is Gilberto Blas. And I'm an electronics engineer 20 supporting the Long-Term Operations and Modernization 21 Branch under Jason Paige.
22 For today's brief, we're going to be going 23 over the purpose and objectives. We're going to be 24 covering background information to explain 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 developments that have contributed to the 1
instrumentation and control of regulatory 2
infrastructure that is in place, accomplishments that 3
have transpired because of those developments. And 4
then we'll be going into the NRC/INC licensing 5
infrastructure from the top of the Code of Federal 6
Regulations for regulatory and staff guidance, 7
providing an explanation of the documents available to 8
staff and their role.
9 We will be doing a deeper dive into each 10 of the main technical areas in INC, showing the 11 mapping between regulations and guidance documentation 12 and explain the interrelationships between the 13 documents.
14 Last, we will be presenting a look ahead 15 into what efforts are underway associated with INC as 16 it relates to established regulatory guidance.
17 Next slide, please. All right. So as 18 Jason stated, the main purpose of today's meeting is 19 to brief on the INC regulatory infrastructure mapping, 20 connecting the regulatory requirements with our 21 applicable guidance.
22 Objectives include communicating the 23 staff's continued efforts to modernize and improve 24 clarity of the INC regulatory infrastructure and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 interrelationships between INC requirements, guidance 1
and industry standards.
2 Next slide, please. All right. Let's get 3
into it. Let's start with some insight and 4
perspectives to our previous efforts related to the 5
INC regulatory infrastructure that happened to shape 6
it to what it is right now.
7 So back in 2016, the commission issued 8
SRM-SECY-15-016 where it directed the staff to develop 9
an integrated strategy to modernize the NRC INC 10 regulatory infrastructure.
11 The staff responded with SECY-16-0070, 12 where they presented the Integrated Action Plan, the 13 IAP, to modernize the NRC's instrumentation and 14 control regulatory infrastructure.
15 The Commission approved the IAP in SRM-16 SECY-16-0070 and throughout its implementation, the 17 staff engaged with external stakeholders and completed 18 significant improvement to the digital INC regulatory 19 infrastructure.
20 These include revisions to Branch 21 Technical Position 719 and Interim Staff Guidance 06 22 that had enabled the expanded safe use of the INC in 23 commercial nuclear reactors. This is evidenced by 24 licensees and applicants using and planning for more 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 complex digital INC projects that are supported by 1
elements contained in guidance developed under the 2
IAP.
3 So the staff provided annual updates on 4
this effort since its beginning in 2016 until its 5
completion as communicated in SECY-19-0112. The 6
staff's vision from carrying out the IAP was to 7
modernize the INC regulatory infrastructure with 8
reduced uncertainty that enables the safe us of INC.
9 As a result, licensees are implementing 10 digital INC modifications and more given that the 11 staff is realizing on that vision by conducting 12 licensing activities with the use of products that 13 came from the IAP.
14 Next slide, please. Okay. So here are 15 the accomplishments that have been made since the last 16 ACRS briefing on digital INC infrastructure and 17 licensing activities held back in September of 2021.
18 In October of 2022, the NRC staff issued 19 Regulatory Guide 1.250, Dedication of Commercial Grade 20 Digital Instrumentation and Control Items for Use in 21 Nuclear Power Plants. Specifically, the guidance 22 supports digital modernization by enabling licensees 23 to procure and accept commercial grade digital 24 equipment for INC items.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 On August of 2022, NRC staff issued SECY-1 22-0076 recommending to the commission to expand the 2
current common-cause failure policy in data licensing 3
systems that provides for the use of risk-informed 4
approaches.
5 NRC staff has also issued Reg. Guidance 6
1374 that is Reg. Guide 1.152, Rev. 4, that endorses 7
IEEE Standard 7432-2016, which is currently out for 8
public comment.
9 And in the preparation of future advanced 10 reactor INC reviews, the staff has held multiple 11 industry workshops on the INC licensing framework for 12 advanced reactors in February and April of this year.
13 MEMBER BROWN: Before you go on, you all 14 issued that two or three weeks ago. I remember you 15 were going to do it after the meeting after you 16 incorporated our suggestions, some of our suggestions.
17 When did you all actually -- is it actually out now?
18 MR. PAIGE: Is that the draft guide you 19 are talking you?
20 MEMBER BROWN: Yeah, the draft guide.
21 MR. PAIGE: That's still in its public 22 comment period.
23 MEMBER BROWN: Okay.
24 MR. PAIGE: And it should be ending 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 shortly.
1 MEMBER BROWN: How long did you all put it 2
out for, two months?
3 MR. PAIGE: What was it -- from when to 4
when?
5 MR. NGUYEN: This is Khoi Nguyen. Reg.
6 Guide 1374 is under the public comment period for 30 7
days.
8 MEMBER BROWN: Oh, 30 days.
9 MR. NGUYEN: It's supposed to ended April 10
- 10. We're supposed to get all the comments by April 11 10.
12 MEMBER BROWN: Okay. Thank you. I just 13 like to know what's coming next or you were probably 14 going to tell me that later probably. Go ahead.
15 MR. BLAS RODRIGUEZ: Thank you. Next 16 slide, thank you. All right. So overview of NRC INC 17 licensing infrastructure. I'm going to start at the 18 top with an overview of the NRC instrumentation and 19 control infrastructure. It follows and supports the 20 requirements and policies established by Title 10 of 21 the Code of Federal Regulations and staff requirements 22 memoranda as seen in the top of the pyramid.
23 Now these are supported by established 24 Regulatory Guides which provide guidance to licensees 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 and endorse industry standards.
1 Best practices and guides. It is also 2
supported by the staff review guidance which are for 3
NRC staff to conduct the reviews for licensing 4
activities.
5 On the next slide, we will be going into 6
more detail to the staff review guidance. Next slide, 7
please. So we have staff review guidance for the 8
review of light water reactors, which consist of the 9
following Standard Review Plan, Chapter 7, which 10 contains the branch technical positions and is 11 supported by interim staff guidance. These documents 12 are going to be covered in the next slide to more 13 detail.
14 For the review of specific reactor 15 designs, the staff developed design specific review 16 standards. For non-light water reactors, the design 17 review guide was developed. And for non-power 18 reactors, NUREG-1537 for the Non-powered Production 19 and Utilization Facility Review Guide was developed.
20 MR. BLEY: Excuse me. This is Dennis 21 Bley. Up there on your first bullet, Standard Review 22 Plan, did you say that the branch, the BTPs and the 23 ISGs are incorporated in Chapter 7?
24 MR. BLAS RODRIGUEZ: Only the branch 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 technical positions.
1 MEMBER BROWN: They're incorporated by 2
reference. They're not literally --
3 MR. BLEY: They're not part of the SRP.
4 MEMBER BROWN: Let me try to clarify.
5 MR. BLEY: I'd rather hear him, Charlie.
6 MEMBER BROWN: Okay. I'll let him talk.
7 MR. BLAS RODRIGUEZ: So my understanding 8
is that the branch technical positions are part of the 9
SRP. The interim staff guidance accompanies the SRP.
10 It's not part of the SRP.
11 MR. BLEY: Okay, Charlie, maybe you can 12 clarify.
13 MEMBER BROWN: You did not put the BTPs 14 word-for-word into the SRP, did you? I don't remember 15 that they are referenced in the SRP as guidance to be 16 followed.
17 MR. BLEY: That's my memory.
18 MEMBER BROWN: That's my memory of what 19 was done.
20 MR. BLAS RODRIGUEZ: So the next slide 21 will actually go into what the BTPs and this 22 conversation --
23 MEMBER BROWN: This conversation.
24 MR. BLAS RODRIGUEZ: Yes, sir.
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17 MEMBER BROWN: Okay. One other question 1
hopefully you will address. When we started doing the 2
first DSRS was mPower, I think.
3 MR. BLAS RODRIGUEZ: Yes.
4 MEMBER BROWN: It was quite a while ago, 5
which set the standard for developing the expanded 6
DSRS, which is architecture focused for the most part, 7
at least it started setting the architecture focus for 8
these reviews and then it expanded into the NuScale as 9
well as it was used.
10 At one time, you all made the comment, I 11 don't know. This has been so long ago I'm not sure 12 I'm correct on this. That the SRP itself was going to 13 be revised to be more in line with the flow of the 14 DSRS's. Is that still on the table or are you all 15 sticking with the present game plan the way that it is 16 organized?
17 MR. PAIGE: So I think you are referring 18 to ACRS meeting back in September of 2021 where it was 19 briefed on the modernization of Chapter 7.
20 MEMBER BROWN: It would be nice if I 21 remembered that way back then.
22 MR. PAIGE: Yeah. So I think Dinesh was 23 one of the presenters for that meeting. So he's 24 welcome to the mic.
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18 MR. TANEJA: Yeah. This is Dinesh. So, 1
you know, I basically know a little bit of background.
2 So the branch technical position right now are there, 3
you know, as part of the SRP Chapter 7. And they are 4
specific to some technical areas.
5 So what we did with the DSRS is that we 6
took all the BTPs and we incorporated the BTPs within 7
the body of the design specific review standard that 8
we used for the NuScale review. Okay?
9 And then with the BRG also is essentially 10 a, you know, standalone review guidance that includes 11 all the relevant BTPs within the body of it. Okay?
12 Now there is the SRP modernization project 13 that has the intent of consolidating the BTPs within 14 the body, which we haven't done that yet because we 15 are just kind of seeing, you know, I guess cost 16 benefit type of thinking that the SRPs right now serve 17 very well for doing the, you know, license amendment 18 requests that are coming in on a piecemeal basis on 19 operating reactors. All the new reactors, they either 20 want to use the DRG or the DSRS.
21 MR. BLEY: Dinesh?
22 MR. TANEJA: Yes?
23 MR. BLEY: Dennis Bley. I thought you 24 folks told us, and maybe that's where you are headed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 here, is that you envisioned that the DSRS would 1
eventually probably with very little change become the 2
new Chapter 7 in the SRP. Is that still correct?
3 MEMBER BROWN: Well, you know, that's what 4
we were intending to do. But, you know, thinking of 5
redoing the SRP Chapter 7 somehow, you know, it's 6
counter to doing the, you know, work that we need to 7
do for a license amendment request on operating 8
reactors, which are in various different sizes. It 9
could be the, you know, we are seeing in some comment 10 just for a tech spec change. Some comment for a very 11 minor little. The SRP serves very well for that 12 purpose, right?
13 But if I'm getting a
brand new 14 application, then the applicants are telling us that 15 we want to tailor our application to the DSRS or the 16 DRGs so we can use that guidance that's available to 17 us.
18 So do we want to just get rid of Chapter 19 7 SRP and replace it with DSRS? It doesn't really do 20 anything for us because DSRS is there for us to use so 21 we are using it, you know? That's the thought right 22 now.
23 MR. BLEY: Okay.
24 MEMBER BROWN: Does that answer your 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 question, Dennis? Are you there, Dennis?
1 MR. BLEY: As well as will happen.
2 VICE CHAIR KIRCHNER: I have a question.
3 MEMBER BROWN: Go ahead.
4 VICE CHAIR KIRCHNER: Just kind of from a 5
philosophical standpoint, why would you have a DSRS 6
and a DRG, picking on an old topic that we hit before 7
this distinction between non-LWRs and LWRs. I mean, 8
advanced reactors are advanced reactors. They are 9
going to need a reactor protection system.
10 They probably hopefully don't have so many 11 controls and so many bells and whistles and so on and 12 so forth. But from a philosophical standpoint, if the 13 coolant is sodium or the coolant is Flibe or the 14 coolant is helium or the coolant is light water, in 15 terms of designing architectures for reactor 16 protection systems, et cetera, it's all the same.
17 Will this all eventually in your mind come 18 together, or as Dinesh just said, it's just convenient 19 to leave it as it is, SRP Number 7, and go on your way 20 with new reactors? But in particular, the two rows 21 there, why would there be any substantial difference 22 between a design specific review standard and a DRG?
23 MR. TANEJA: Let me try to answer that.
24 So when we had the mPower applicant coming in, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 there was a number of applicants potentially coming 1
with small modular reactors, the commission directed 2
us to come up with the review guidance that was 3
specific to each design at that time. And it was to 4
basically, because these designs are passive, they 5
were small modular, and they were intended to be 6
somewhat different, so the direction that we got from 7
the commission was to come up with the DSRS that is 8
specifically designed.
9 So we started out with the mPower. And 10 then mPower pulled out the application. They decided 11 not to proceed. And then we ended up using that same 12 one for NuScale.
13 And now I think evaluating that, if a 14 future applicant does come in with an ASMR and if they 15 want to really tailor their application using the DSRS 16 format, we have that guidance available to us.
17 So the DRG was really created to be in 18 line with the LMP framework. It's, you know, 19 basically to be, you know, risk informed with a more 20 PRA-initiated type of a risk-informed regulatory 21 framework. So to be in line with that, we created the 22 DRG.
23 So, you know, we are going through that 24 process of trying to figure it out because now we have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 GEH that just told us that even though it's a light 1
water reactor, they want to really tailor their 2
application using the DRG. We are working with them 3
right now to figure out because they said, well, you 4
know, we are risk informing our design so I think it 5
works best for us that we follow it.
6 MEMBER BROWN: When we reviewed the DRG, 7
if I remember correctly --
8 MR. TANEJA: Yes, yes. We --
9 MEMBER BROWN: -- and we commented that 10 once you finish going through that DRG, you might as 11 well take off the non-light water or light water and 12 just say design review standard for digital items.
13 VICE CHAIR KIRCHNER: Yeah, that's what I 14 meant when I just said --
15 (Simultaneous speaking.)
16 MEMBER BROWN: You know, for not digital 17 but for plants, period. It doesn't really make any --
18 the requirements, not requirements, excuse me, the 19 guidance in the architecture in all the common-cause 20 stuff and the BTPs is all kind of blended throughout 21 it so it's vanilla. And we actually suggested taking 22 away the -- I probably didn't do that. It still says 23 non-light water reactors, right, non-LWRs? Is that 24 correct?
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23 MR. TANEJA: Well, based on the feedback 1
that we got from the SERS, we did add a footnote.
2 MEMBER BROWN: Yeah, that's right. I got 3
the footnote. If you want to use it, you can. Okay.
4 I remember that now. Thank you.
5 MEMBER HALNON: So on the slide, the 6
NUREG-1537, I don't know if you've gotten there yet 7
because mine sort of stopped. But that's a 1997 8
document. Doesn't that pre-date some of the good 9
practices we've learned in the 2000s and in the teens?
10 It seems like that is a little old to be relying on 11 for any past review guidance in this area.
12 MR. PAIGE: Yes. That's a good point. So 13 that document is currently being updated to 14 incorporate lessons learned from, you know, previous 15 history so.
16 MEMBER HALNON: Okay. So this is 17 referring to the next rev that we'll see which we will 18 probably be reviewing. Okay.
19 MEMBER PETTI: Because I understood that 20 it was Kairos you guys used being DSRS, the two of 21 you. I thought that is what we were told, right?
22 MEMBER HALNON: Right.
23 MEMBER BROWN: No, that's what they said 24 directly.
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24 MEMBER PETTI: Right. That's what they 1
said.
2 MEMBER BROWN: In their write-up that they 3
used the DSR.
4 MEMBER PETTI: Right.
5 MEMBER BROWN: And the staff used the DSR 6
as guidance and for their review.
7 MEMBER PETTI: Joe has his hand up. Oops.
8 Maybe not.
9 MR. ASHCRAFT: Yeah. This is Joe 10 Ashcraft. What I told you yesterday is we use NUREG-11 1537 for most of the, you know, bullet points to look 12 at. But in addition, I also use the DSRS specifically 13 for the principle design INC criteria and also the 14 appendix and the architecture just to help me go 15 through what I was looking at. But officially, Kairos 16 was reviewed using NUREG-1537.
17 MEMBER PETTI: Thanks.
18 MEMBER BROWN: And I wanted to amplify one 19 other thing just from a historical standpoint. If you 20 go back to roughly 2009 or so, largely, at least the 21 first review I did of an INC system, it was for ESPWR, 22 that was largely a bottom-up review for the staff.
23 They looked at it position by position, IEEE standard 24 position. If you met the positions, you were okay.
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25 The committee did not -- I won't say 1
didn't. We didn't think that was a good way to do it.
2 The fact is there is now way we could ever review 3
anything to go through dozens of documents position by 4
position. So we didn't get a figure that was worth 5
anything, a one line diagram.
6 So after about a year and a half, we 7
finally got everybody convinced to generate that. And 8
we have changed the review process from a bottom-up to 9
a top-down review starting with architecture. And to 10 me that's been a significant change. And hopefully 11 the applicants, it's much easier for them if they 12 present the information in a top-down manner, and you 13 can really see whether it is satisfactory or not and 14 then pick up the loose ends as boilerplate.
15 So this is a significant change in my own 16 opinion in terms of how, based on what we've seen, at 17 least in my time here, is how the staff reviews it 18 overall. And it has certainly eased our ability to 19 review the same in a timely manner and get it back to 20 them. And I think that has proven itself in 21 particularly the APR-1400 and NuScale reviews. Those 22 went very smoothly. That's just a little background 23 for everybody at the same time.
24 All right. Sorry to interrupt. I always 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 have to provide instructional details. Thank you.
1 MR. BLAS RODRIGUEZ: Okay. Next slide, 2
please. All right. So the INC portion of the SRP 3
Chapter 7 provides guidance for review of the INC 4
portions of applications for nuclear reactor license 5
or permits and amendments to assist in licenses.
6 And for branch technical positions, they 7
are contained within Chapter 7. The BTPs represent 8
guidelines intended to supplement the acceptance 9
criteria establishing regulations and the guidelines 10 provided in Reg. Guides and applicable industry 11 standards.
12 The ISGs are supplemental information to 13 Chapter 7. And these are all things used to clarify 14 or expand on guidance found in Standard Review Plans 15 or Regulatory Guides and facilitate the resolution of 16 technical or licensing issues within established 17 regulatory processes.
18 One thing to note is that ISGs are 19 intended to be incorporated into the Standard Review 20 Plan.
21 MEMBER PETTI: So you said intended. So 22 we haven't seen an interim for an awful long time. I 23 mean, is there a schedule for putting that into the 24 SRP?
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27 MR. BLAS RODRIGUEZ: All right. So right 1
now the guidance in ISG-04 is being incorporated in 2
IEEE 7432.16 and then for ISG-06, we are waiting until 3
we gather lessons learned from the Limerick and Turkey 4
Point licensing reviews before incorporating them into 5
the SRP.
6 MEMBER BROWN: ISG-6 was the licensing --
7 MR. BLAS RODRIGUEZ: Licensing process.
8 MEMBER BROWN: ISG-4 was -- I have 9
forgotten the titles.
10 MR. TANEJA: Communications independence.
11 MEMBER BROWN: Oh, yeah, right. Okay.
12 All right. Those I remember doing 6, 12 years ago or 13 something like or 10 years. Go ahead.
14 MR. BLAS RODRIGUEZ: Okay. With that, I 15 will pass it over to my colleague, Samir Darbali.
16 MEMBER BROWN: One other observation.
17 When we did the Diablo Canyon review, Richard, you 18 were on that, right? That was done from an 19 architectural standpoint. That one also went very 20 smoothly in my personal opinion. Am I correct?
21 MR. DARBALI: Yup.
22 MEMBER BROWN: It was one and done. And 23 it really eased and smoothed out the whole process.
24 So this new process I view as wonderful.
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28 MR. DARBALI: Okay. All right. Thank 1
you, Gilberto, and good afternoon everybody.
2 MEMBER BROWN: Get closer.
3 MR. DARBALI: Is that better?
4 CHAIR REMPE: Yes.
5 MR. DARBALI: Okay.
6 MEMBER BROWN: Thank you.
7 MR. DARBALI: Good afternoon, everyone.
8 As Gilberto mentioned, we have several regulatory 9
requirements, items, documents and endorsed industry 10 standards. And this covers a range of INC topics.
11 This is going to make it hard to follow how all these 12 documents fit together or to see how the big picture 13 of a regulatory infrastructure looks like.
14 To address this, the staff came up with an 15 approach through the regulatory and licensing guidance 16 into nine technical areas, which include eight INC 17 technical areas that are focused on safety and tied 18 back to the requirements in 10 CFR Parts 50 and 52 19 and one cybersecurity area that ties back to the 20 requirements of Part 73 for security.
21 We have included cybersecurity because of 22 the nexus between safety and security throughout the 23 design, implementation, operation and modification of 24 the licensing process.
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29 This approach to group the regulatory and 1
staff guidance into technical areas provides clarity 2
and cohesiveness of the INC infrastructure by allowing 3
applicants, licensees, vendors and NRC staff to 4
effectively navigate and use the regulatory guidance.
5 This particular slide is set up in a way 6
that one can click through any of the technical areas, 7
and the presentation will take you to that detailed 8
mapping slide. So in the following slides, what we'll 9
do is we'll look at the mapping between the regulatory 10 requirements and guidance for each of these nine 11 technical areas.
12 When we get to these slides, you will see 13 the applicable regulatory requirements on the left-14 hand side of the slide, the applicable regulatory 15 guides and endorsed industry standards in the middle 16 of the slide and the staff reviewed guidance on the 17 right-hand side of the slide.
18 We also have two backup slides at the end 19 that map the INC technical areas to the IEEE 7432 20 clauses and to the ISG-06 sections. We have included 21 these two slides for additional reference material.
22 If you have any questions, we can go over these slides 23 later as well.
24 So with that, we are going to start with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 the mapping of the criteria for safety systems 1
technical are. Any questions on what we're showing 2
here?
3 So let's start with the criteria for 4
safety systems technical area. So this technical area 5
covers those aspects of the system architecture that 6
includes the fundamental design principles.
7 On the left side of the slide are the 8
applicable regulatory requirements and policy. And 9
these include Part 50 and 52 that contain the 10 requirements for different licensing process.
11 Part 50, being a two-step process with a 12 construction permit and an operating license and Part 13 52 being a one-step process with a combined operating 14 license and as part of that combined operating 15 license, applicants can reference sort of by design.
16 Part 50 also contains technical 17 requirements such as the general design criteria in 18 Appendix A and the quality assurance criteria in 19 Appendix B.
20 We also have IEEE Standard 60 and 279, 21 which are incorporated by reference in 5055(a)(H) and 22 also the common-cause failure policy in SRM-SECY 23 087.
24 One thing to note is that depending on the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 specific application, there might be other applicable 1
regulatory requirements that are not captured in the 2
slide. For example, a particular application may be 3
related to ATWS, in which case 50.62 may also be 4
applicable.
5 In the middle of the slide, we have the 6
applicable Regulatory Guides and endorsed industry 7
standards. In this slide and in the following slides, 8
we will see the latest revision number for these Reg.
9 Guides. However, the applicable revision will be 10 determined by the individual plan's licensing basis.
11 The Reg. Guides for this technical area 12 cover, amongst other things, periodic testing, QA 13 requirements, bypass and inoperable status indication, 14 single failure, manual initiation of protection 15 actions and independence. You can see that some Reg.
16 Guides don't endorse any industry standards and that's 17 because the specific guidance is in the Reg. Guides 18 themselves.
19 And then on the right side of the slide 20 are the applicable staff guidance documents. We note 21 the SRP Chapter 7 sections listed here and also BTP 7-22 8, which provides guidance for applying Reg. Guide 23 1.22, BTP 7-19, that's for diversity and the ISG-06 24 sections for system description.
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32 So we also note the ISG-06 section --
1 MEMBER BROWN: Before you go on, did the 2
reporter get everything?
3 MR. DARBALI: Yeah, where did I leave off?
4 MEMBER BROWN: Joy, can I --
5 CHAIR REMPER: Yes, sir.
6 MEMBER BROWN: Okay. You got everything.
7 Okay. Thank you.
8 MR. DARBALI: Thank you. I apologize.
9 And so we also have the ISG-06 sections for system 10 description, system architecture and compliance with 11 IEEE Standard 603.
12 We have an asterisk here at the bottom 13 where we identified those documents that are specific 14 to Line C. So in this slide, that would be the CCF 15 policy and that's SECY-93-087, BTP 7-19, diversity and 16 defense-in-depth for computer systems, and ISG-O6, the 17 licensing process for digital modifications.
18 MEMBER BROWN: Okay. Question?
19 MR. DARBALI: Yes.
20 MEMBER BROWN: You just finished dealing 21 with 22-0076, SECY. Is there an SRM out on that yet?
22 MR. DARBALI: Not yet.
23 MEMBER BROWN: I didn't think it had been.
24 I had not seen that.
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33 MR. DARBALI: Right, right.
1 MEMBER BROWN: Okay. But we did provide 2
comment, and you all provided whatever machinations 3
you did relative to that. But we actually issued our 4
letter report after SECY was a SECY, right?
5 MR. DARBALI: Right, right.
6 MEMBER BROWN: So you're not getting 7
anything back from the commission at all?
8 MR. DARBALI: Right. We're still waiting 9
for the SR from the commission. And as we receive 10 that and there are other updates made to what you will 11 see in this slide and other slides, we will be making 12 an update for that.
13 MR. BLEY: Hey, this is Dennis Bley. I 14 just wanted to compliment you on this slide. This is 15 the kind of thing I was envisioning when we asked this 16 question. And it looks pretty complete. There might 17 be things that need to be polished up on it.
18 But, you know, by the time the staff gets 19 around to actually incorporating things as we were 20 talking earlier and getting rid of the ISGs and BTPs, 21 you guys will all be retired and gone, and this will 22 help whoever is going to do it. They don't have to 23 build this for themselves. Thanks for it.
24 CHAIR REMPE: You look pretty young, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 Dennis, to be retired. But maybe I'm more optimistic 1
about timing.
2 MR. BLEY: I think you put the senior --
3 you put the junior staff in front of us today.
4 MR. BENNER: Bingo, younger staff. This 5
is Eric Benner. We put the people who are going to 6
have to live with this framework for the next two 7
decades.
8 VICE CHAIR KIRCHNER: And the ACRS.
9 MR. DARBALI: Thank you.
10 VICE CHAIR KIRCHNER: I just want to echo 11 Dennis' compliment. This is very good. So it begs 12 the question, has industry seen this yet or is this 13 the first rollout?
14 MR. DARBALI: Yes. This is the first time 15 we have made this public.
16 VICE CHAIR KIRCHNER: I would think that 17 this would be invaluable to especially the newer 18 applicants who haven't labored through the processes 19 before.
20 MR. DARBALI: Right.
21 VICE CHAIR KIRCHNER: Very well done.
22 Thank you.
23 MR. DARBALI: Right. And, you know, as 24 you have seen, and you will continue to see, we do 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 have some ability that you can click through some of 1
the technical areas. And I will take you to that 2
slide, so.
3 VICE CHAIR KIRCHNER: I see the arrow at 4
the bottom.
5 MEMBER MARCH-LEUBA: Yeah. So following 6
up on the topic, ACRS meetings, this is going to be 7
forever enshrined, you know, what page. I know that 8
we find it.
9 MR. DARBALI: Mm-hmm.
10 MEMBER MARCH-LEUBA: So you need to 11 consider making this part of a document --
12 MR. DARBALI: Right.
13 MEMBER MARCH-LEUBA: -- that's easier to 14 find. I don't think it raises to the level of NUREG-15 KM, knowledge management.
16 MR. DARBALI: Right.
17 MEMBER MARCH-LEUBA: But someplace that it 18 can be found.
19 MR. DARBALI: Yes, yes.
20 MEMBER MARCH-LEUBA: We were talking this 21 morning about searching ADAMS.
22 MR. DARBALI: Mm-hmm.
23 MEMBER MARCH-LEUBA: Make it foundable, 24 easy.
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36 MR. DARBALI: Yes.
1 MEMBER MARCH-LEUBA: Not just in ADAMS.
2 MR. PAIGE: So to that point, we've 3
actually had conversations on how to put this in a 4
more permanent location. We've also talked about 5
putting it on the NRC public website so that it is 6
available to everyone so we are having those 7
conversations.
8 MEMBER MARCH-LEUBA: I wanted --
9 MEMBER BROWN: One other question -- I'm 10 sorry. Go ahead.
11 MEMBER MARCH-LEUBA: I wanted to make a 12 point. I mean, there is something called NUREG-KM.
13 That's knowledge management. That for sure you can 14 always find it. And it doesn't need to be 150 pages.
15 It can be only 10.
16 MEMBER BROWN: On 22076, have you all had 17 any communications back or questions that you all have 18 been asked relative to that or is that just still off 19 in the ether somewhere in the commission space?
20 MR. DARBALI: I was going to say we did do 21 a briefing to the commissioner's assistants back in 22 January.
23 MEMBER BROWN: Okay. So there is some 24 action going on. It's not just dead on arrival.
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37 MR. DARBALI: Right.
1 MEMBER BROWN: Okay.
2 MR. DARBALI: And we did receive two 3
votes.
4 MEMBER BROWN: Oh, yeah. I remember 5
seeing two votes. They weren't real extensive.
6 MR. DARBALI: Right.
7 MEMBER BROWN: Okay. Thank you.
8 MR. DARBALI: Okay. And we appreciate the 9
comments on the slide. The team here and supporting 10 staff put a lot of work into this. And it was 11 gathering a lot of knowledge and digging through 12 documents. So it's going to be a very useful tool 13 also to staff. And we're also seeing how this can 14 help inspectors as well to be more efficient in their 15 inspections.
16 MEMBER BROWN: Well, the presentation --
17 I've been doing this for almost 15 years now come next 18 month in May. And this is the first time I've seen an 19 organized layout. I mean, I've kind of absorbed it by 20 osmosis as we went through all the processes, but 21 never in quite as crisp a manner. So I want to echo 22 Dennis' and Jose's comments.
23 MR. DARBALI: Thank you.
24 MEMBER BROWN: This is a -- I'm really 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
38 glad you guys asked the question that NUREG Guide 1
1.152 needed. Very productive. So go ahead.
2 MR. DARBALI: Billy, do you have the file?
3 If you could click on the back button, and it will 4
take you again to the technical areas. So now we're 5
going to be looking at the criteria for safety system 6
for programmable digital devices technical area.
7 So this technical area covers those 8
digital specific licensing aspects that supplement the 9
criteria for safety systems, technical area. Again, 10 the applicable regulations and policy are on the left.
11 And they are mostly the same as in the previous slide.
12 The applicable Regulatory Guide that 13 covers this technical area is Reg. Guide 1.152, 14 Revision 3, which endorses the 2003 version of IEEE 15 7432. We've also identified here at Draft Guide 1374 16 for Revision 4 of Reg. Guide 1.152 to endorse the 2016 17 version of 7432.
18 As you know, IEEE 7432 supplements the 19 criteria of IEEE 603 with criteria specific to 20 computers or programmable digital devices. Because of 21 this, the clauses in 7432 parallel those clauses of 22 IEEE 603.
23 In the table in this slide, we're showing 24 the clauses within the latest revision of 7432, which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 is the 2016 version, that are applicable to this 1
technical area. This includes applying the single 2
failure criteria to programmable digital devices, 3
system integrity, communication independence, control 4
of access, reliability and common-cause failure.
5 The staff guidance for performing the 6
licensing interviews is found in Chapter 7 of the SRP, 7
most notably in BTP 7-17 for self-test and 8
diagnostics, BTP 7-19 for defense-in-depth and 9
diversity and BTP 7-21 for real-time performance of 10 digital systems.
11 In addition, ISG-04 provides guidance on 12 data communications. And this guidance, as Gilberto 13 mentioned, is now captured in the 2016 version of 14 7432.
15 And finally the ISG-06 sections for system 16 description, system architecture, applying a digital 17 INC topical report in compliance with IEEE 603 in 18 conformance to 7432 and the secure operational 19 environment aspect of STO.
20 MEMBER BROWN: How old is 7-21?
21 MR. DARBALI: I don't know how old 7-21 22 is. I would have to check.
23 MEMBER BROWN: I know there has been no 24 revisions to it since I have been here that I remember 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 unless you all flagged one by me.
1 MR. DARBALI: Right. Okay.
2 MEMBER BROWN: Richard, do you know that?
3 Do you use 7-21?
4 MR. STATTEL: No.
5 MEMBER BROWN: Dinesh?
6 (Simultaneous speaking.)
7 MEMBER BROWN: That one is a golden oldie 8
of some kind because I haven't seen any changes in the 9
last 15 years.
10 MR. DARBALI: Okay.
11 MEMBER BROWN: Of course, I'm tending to 12 forget some of those so.
13 MR. DARBALI: So when you get that, just 14 let me know. Okay? So that's the criteria for safety 15 systems, programmable digital devices. If there are 16 no questions, I can move to the next technical area.
17 MEMBER HALNON: Yeah. I have a general 18 question.
Just it doesn't apply necessarily 19 specifically to this one. But have you had a chance 20 to look at the Part 53? Does that plug in here, I 21 mean, complimentary or is it something you're going to 22 have to do extensive work beyond what you have here?
23 MR. DARBALI: Right. So since we don't 24 have a final Part 53, we did not look at that. But I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 think the regulatory guidance that you see here, a lot 1
of it really just ties back to IEEE 603.
2 MEMBER HALNON: It is required to be a 3
plug-in. It should almost, probably.
4 MR. DARBALI: Right. Licensees and 5
applicants will have an option to follow the 6
regulatory guidance to make their safety case.
7 MEMBER HALNON: But you don't have 8
anything on the docket list, punch list to write 9
something special for Part 53, the proposed language 10 yet?
11 MR. DARBALI: Not at this time.
12 MEMBER HALNON: Okay. Thanks.
13 MR. TANEJA: Well, you know, the DRG is 14 really following the LMP framework. So that is the 15 performance-based, risk-informed, you
- know, 16 architecture that it follows. So when the Part 53 17 rulemaking is finalized and if there are companion 18 guidance, I think DRG would be a good place for us to 19 get started with, you know? So we do have something 20 that's in line.
21 MEMBER HALNON: Thank you.
22 MR. DARBALI: Thank you. Okay. Now we're 23 going to the digital development and reliability 24 technical area.
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42 MR. PAIGE: Just some information, in 2016 1
it was revised, not that long ago.
2 (Simultaneous speaking.)
3 MEMBER BROWN:
That's one of the 4
difficulties. I try to keep track. I would have to 5
go have somebody send that to me so I can -- can you 6
send a copy of that to Christina so she can get to --
7 you know, Christina, right? I'm sure.
8 MR. DARBALI: So going back to the digital 9
development and reliability technical area, so this 10 technical area covers the digital life cycle 11 activities that ensure the quality and reliability of 12 the digital system.
This includes software 13 requirement specifications, verification and 14 validation, configuration management, software and 15 system test documentation and software unit testing.
16 In addition to the Regulatory Guides 1.168 17 through 1.173, we also note Reg. Guide 1.152 that 18 endorses the IEEE Standard 7432 because Clause 5.3 of 19 7432 provides additional guidance on software 20 development, software tool, independent V&V and 21 configuration management. We also note Clause 5.9 for 22 control of access, which is applicable to the 23 development environment.
24 And for the staff guidance, we include BTP 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 7-14 on performing software reviews and ISG-06, 1
Section D.4 for system development under the ultimate 2
review process. Section D.9 for development under the 3
tier review process and Section D.8 for the secure 4
development aspect of STO.
5 We're now going to --
6 VICE CHAIR KIRCHNER: I have a question.
7 It's a cross-cutting question.
8 MR. DARBALI: Yes.
9 VICE CHAIR KIRCHNER: What is your 10 thinking on quality assurance? And specifically, 11 obviously for the existing fleet, Appendix B applies 12 and that essentially is NQA-1, ASME NQA-1.
13 Now a lot of this pre-supposes that in 14 this case that development is done under an NQA-1 like 15 quality program. I'm just looking ahead. 10 CFR 53, 16 the advanced reactors, well, right now, they are under 17 50 and 52 so that's the only licensing option going 18 ahead.
19 But how will you handle quality assurance 20 if an applicant proposes to use something that's not 21 NQA-1, and you basically have an architecture here of 22 regulatory guidance that is very structured to NQA-1 23 and IEEE standards? Any thoughts on that or is it 24 like Dinesh said that you go to your DRG framework for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 the review?
1 MR. DARBALI: The next technical area is 2
commercial dedication. So it just touch-up on that, 3
but I see Dinesh stood up.
4 MR. TANEJA: So far, I think everybody's 5
QA program is pretty much following the NQA-1, right?
6 VICE CHAIR KIRCHNER: Right.
7 MR. TANEJA: And NQA-1 basically has 8
guidance that points out to IEEE 7432, which for --
9 you know, I mean, it gives you the framework for the 10 software QA, but then the specifics get into the IEEE 11 standard, and it points to that. So the NQA-1 does 12 that.
13 And the only other thing that we are 14 seeing right now is that maybe the IEC standards that 15 are being used in lieu of IEEE standards for the 16 specific areas of configuration management, RV&V and 17 the life cycle development activities. So we are kind 18 of working on that to try to work with each applicant 19 as to, you know, what standards that they intend to 20 use.
21 VICE CHAIR KIRCHNER: Thank you.
22 MR. TANEJA: Yeah.
23 VICE CHAIR KIRCHNER: Thank you.
24 MR. DARBALI: Okay. Now we'll move on to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 the commercial grade dedication technical area. And 1
for this technical area, we note 10 CFR Part 21 under 2
the regulatory requirements.
3 So the regulatory guidance includes 4
generic guidance for commercial grade dedication, as 5
found in Reg. Guide 1.164, which points to the staff 6
evaluation of EPRI Reports 106439 and 107330 for the 7
dedication of digital equipment and programmable logic 8
controllers.
9 We also have the recently issued Reg.
10 Guide 1.250 for verifying an item's dependability 11 critical characteristics based on an accredited 12 certification. And finally, we're pointing here to 13 DG-1374 to endorse the 2016 version of IEEE 7432 14 because the 2016 version includes a Clause 5.17 on 15 commercial grade dedication.
16 And then the applicable staff guidance 17 includes, again, BTP 7-14 and ISG-06, Section D.99, 18 for commercial grade dedication under the TR review 19 process.
20 With that, we'll move back to the next 21 technical area, which is equipment qualification. For 22 this technical area, we note under the regulatory 23 requirements 5049. And the regulatory guidance 24 includes generic guidance for equipment qualification 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 as found in Reg. Guide 1.89, which is currently being 1
revised under DG-1361.
2 The digital specific guidance is found in 3
Reg. Guide 1.209, Reg. Guide 1.100, that endorses 4
three standards for seismic qualification, Reg. Guide 5
1.180, that endorses eight standards for 6
electromagnetic interference and radiofrequency 7
interference, and also Reg. Guide 1.152 because IEEE 8
Standard 7432 contains Clause 5.4 on equipment 9
qualifications. And then the applicable staff 10 guidance includes ISG-06, Section D.3, on hardware 11 equipment qualification.
12 If there are no questions, we'll go to the 13 next technical area, which is accident monitoring 14 communication. And for this technical area, we note 15 under the regulatory requirements 50.34(f)-2019, for 16 the TMI related requirements and 51.55(e) for spent 17 fuel pool monitoring.
18 The applicable regulatory guidance is in 19 Reg. Guide 1.97. That endorses IEEE Standard 497.
20 And for the staff review guidance, we note BTP 7-10 21 for guidance on applying Reg. Guide 1.97.
22 MEMBER BROWN: This is largely the PAM, 23 isn't it?
24 MR. DARBALI: Yes, PAMs, correct. And 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 we'll go now to the next technical area, which is set 1
point establishment and maintenance. For this 2
technical
- area, we note under the regulatory 3
requirements of BT-36(c)(1)(ii)(A) and the regulatory 4
guidance is in Reg. Guide 1.105 that endorses ANSI 5
ISA-670401.
6 And the staff review guidance includes BTP 7
7-12 on establishing and maintaining instrument set 8
points and also Section D.7 of ISG.
9 The last INC technical area is instrument 10 sensing lines. And for this technical area we note 11 under regulatory requirements 50.36(c)(2)(ii) because 12 it addresses install instrumentation used to detect 13 and indicating the control room a significant and 14 normal degradation of the reactor coolant pressure 15 boundary.
16 The regulatory guidance for this technical 17 area is in Reg. Guide 1.151, which endorses two 18 standards. And we don't have any specific staff 19 review guidance for this technical area other than the 20 generic Chapter 7 review guides.
21 So that completes the eight INC technical 22 areas. And now we'll move to the cyber security 23 technical area. And we note here under the regulatory 24 requirements, the operating license under Part 50 and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 the combined operating license under Part 52, which 1
require that a cyber security control program be 2
placed at the time the plant begins operations.
3 We also note Part 73, regulatory 4
requirements, 73.1, is the purpose and scope of Part 5
73, 73.54, commonly known as the cyber security rule 6
or the cyber rule, requires operating reactor 7
licensees and applicants to ensure that digital 8
computer and communication systems associated within 9
a power plant
- safety, security and emergency 10 preparedness functions are protected from cyber-11 attacks up to and including the design basis threat.
12 And 73.77 for reporting of cyber security event 13 notifications.
14 The applicable guidance for implementing 15 the requirements of 73.54 is in Reg. Guide 571, and 16 the applicable guidance for implementing the 17 requirements of 73.77 is in Reg. Guide 583. And the 18 staff guidance for evaluating an applicant's cyber 19 security plan to meet the requirements of 73.54 is 20 documented in Section 1366 of the SRP.
21 The scope of the staff's review in this 22 area is programmatic as part of the overall conduct of 23 operations assessment.
24 MEMBER HALNON: Samir, I expected to see 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 the 5.71 or something from the NEI document that most 1
applicants -- or not applicants, but operating 2
reactors are to. And also it seems like the 3
inspection program drove the requirements for a while 4
because they were learning through these steps. Has 5
all that learning been incorporated in the 800 now of 6
the SRP?
7 MR. DARBALI: I don't know about if it's 8
being incorporated into the SRP. I do know 5.71 was 9
recently revised so a lot of lessons learned from the 10 earlier inspections after being there.
11 MEMBER HALNON: Yeah. We reviewed that.
12 We came away a little bit on the empty side from the 13 standpoint that nobody is using it.
14 MR. DARBALI: Okay.
15 MEMBER HALNON: Again, that's the existing 16 ones. The new applicants probably. At least that's 17 out there that they can see it.
18 MR. DARBALI: Right.
19 MEMBER HALNON: But NEI, I think it's 04-20 04 or something like that is --
21 MR. DARBALI: Right. Also NEI 13-10, I 22 think all of those are reviewed by letters rather than 23 endorsed by Reg. Guides. So that's why they are not 24 included here. I believe there is going to be a cyber 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 security meeting on May 17.
1 MEMBER HALNON: Right.
2 MR. DARBALI: So maybe that's --
3 (Simultaneous speaking.)
4 MEMBER HALNON: That's going to be less 5
geared toward what the operating plants are doing and 6
more geared toward the interagency coordination that 7
we're having. But I guess I expected to see almost 8
more of a spaghetti mess on this one than any of the 9
other ones.
10 MR. DARBALI: Okay. Okay.
11 MR. YIP: This is Brian Yip from the cyber 12 security branch. I could jump in and address a little 13 bit of that. So in Reg. Guide 5.71, Revision 1, we 14 did add some language approving NEI 10-04 and NEI 13-15 10 for use.
16 We are undertaking the initial stages of 17 an effort now to revise -- well, the industry is 18 working on revising NEI 8-09 to Revision 7. So we are 19 in the beginning stages of engaging with the industry 20 on that.
21 And we are also in the beginning stages, 22 now that we have 5.71, Revision 1, completed, we are 23 in the initial stages of looking at the standard 24 review plan for cyber security to see whether or not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 it needs to be updated.
1 MEMBER HALNON: Okay. So we're still 2
catching up on all the last decade of learnings in the 3
cyber area. Is that fair?
4 MR. YIP: Yeah, I think --
5 MEMBER HALNON: When I say catching up, I 6
mean, updating the official document. The stuff is 7
out there. It's just not all collated into one area 8
yet.
9 MR. YIP: Yeah. That's correct.
10 MEMBER HALNON: Thanks.
11 MR. DARBALI: Thank you, Brian. So if 12 there aren't any other questions, that concludes our 13 tour of the nine technical areas of the INC regulatory 14 infrastructures. And so I'll turn it over to Jason 15 for the next slide.
16 MR. PAIGE: Thank you. So we also wanted 17 to provide a look ahead to some things that we are 18 prioritizing to continue to implement revision for 19 modernizing the INC infrastructure as communicated in 20 SECY-19-0112.
21 So in general, our vision includes 22 modernizing guidance to enable the expanded safety use 23 of digital INC, strategic updates to Reg. Guides to 24 endorse the latest standard and reducing the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 complexity of our infrastructure by consolidating 1
and/or closing out interim guidance.
2 And so this slide provides the specific 3
activities that we're focusing on. So the first one 4
is the modernization of Chapter 7, which we briefly 5
talked about during today's meeting in reference --
6 you know, we presented our plans for modernizing 7
Chapter 7 during the September 2021 ACRS meeting.
8 Second, update digital development and 9
reliability guidance to endorse the latest IEEE 10 Standard 1012. Third --
11 MEMBER BROWN: Before you go, 1.68, the 12 last we reviewed that a long time ago, 68, 69, 70, 71, 13 72 and 73. They're all kind of tied together. They 14 seem to be kind of tied together in terms of this 15 particular, the whole task that you're looking for 16 software stuff. Is that going to entail then of a 17 trickle down of changes to the rest or is this just 18 isolated to the basic --
19 (Simultaneous speaking.)
20 MR. PAIGE: So we're trying to take a 21 strategic approach. So I think our first step is to 22 update the Reg. Guide 1.68 and then we will look into 23 consolidating those Reg. Guides and taking those 24 steps.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 MEMBER BROWN: So there is a little more 1
in the bag possibly depending on what you see with 2
1.68?
3 MR. PAIGE: Do you want to add anything, 4
Rich?
5 MR. STATTEL: So I would just add --
6 pardon? Oh, this is Richard Stattel. I would just 7
add, so we are prioritizing as far as which Reg.
8 Guides we are going after for revision. And 1.68 is 9
of particular interest to us because there have been 10 like three revisions to the IEEE standard and so there 11 is significant change in the V&V activities that are 12 being used by the industry. And this is not just the 13 nuclear industry. This is all of the computer 14 industry.
15 And what we're looking for in this Reg.
16 Guide in particular is we're revisiting and refocusing 17 on what our position is because the IEEE standard is 18 intended to be a graded approach to V&V. In other 19 words, you do the amount of V&V activities that are 20 appropriate for the type of software that is being 21 developed. And our Reg. Guide kind of goes counter to 22 that by forcing all safety-related software to be a 23 particular grade.
24 So we're kind of refocusing on that and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 revisiting the actual regulatory position on that one.
1 MEMBER BROWN: Does that apply to FPGA 2
type software?
3 MR. STATTEL: Yes.
4 MEMBER BROWN: So it applies, and it's not 5
-- okay.
6 MR. STATTEL: Absolutely.
7 (Simultaneous speaking.)
8 MEMBER BROWN: -- it covers the whole panel 9
of --
10 MR. STATTEL: That's correct. A lot of 11 the early guidance was written with a lot of software 12 verbiage, written for the computer or PLC industry.
13 And what we've learned over the years is these other 14 technologies, like FPGAs and complex logic devices, 15 it's equally applicable, right?
16 So the guidance, the terminology we're 17 trying -- as these IEEE standards are developed, we're 18 trying to go to more generic terminology that can be 19 applied to the different technologies that are being 20 implemented.
21 MEMBER BROWN: Thank you.
22 MR. PAIGE: So continuing on with the 23 third bullet. So with the issuance of Reg. Guide 24 1.52, we will take the necessary steps to sunset ISG-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 04.
1 The fourth bullet, when we receive 2
commission direction, we will follow that direction by 3
regarding SECY-22-0076. And lastly, we are discussing 4
internally a path forward for industry's use for IEEE 5
Standard 603-2018. As you are aware, the 1991 version 6
is IBR'd so we're discussing to determine how --
7 MEMBER BROWN: It's what?
8 MR. PAIGE: IBR'd, oh, incorporation by 9
reference.
10 MEMBER BROWN: Oh, yeah.
11 MR. PAIGE: Sorry. A path for industry to 12 use the latest version. So these are the items --
13 MEMBER BROWN: Does that mean a rule 14 change?
15 MR. PAIGE: So we're still discussing 16 internally. That's one of the options that we are 17 considering.
18 MEMBER BROWN: That's one of the -- that's 19 kind of an anchor. 603-1991 is an anchor, a strong 20 anchor relative to the general framework we've been 21 talking about. It touches all of those even though it 22 only covered physical access on the control of access.
23 All of the rest of the stuff in there meets -- not 24 necessarily the deterministic versus interrupt driven 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
56 software for microprocessors and stuff. But we tried 1
to cover that with time response type looking.
2 But that is one heck of an anchor to keep 3
all this stuff focused so that people don't go flying 4
off the deep end with I'll do what I want to when I 5
want to do it type of approach. So I'm just 6
cautioning some carefulness that we don't throw babies 7
out with the bath water here when we go to 603-2018.
8 The general progression of IEEE standards 9
that I've seen seems to be pablumizing some of the 10 good stuff in 603. You know, they're putting some 11 mush words in. So I just hate to lose that anchor.
12 We still use it thoughtfully. It's not 13 like we're going to go stick a knife in our heart just 14 because the rule says to do that. But it is an anchor 15 for a starting point. So just keep that in mind.
16 MR. PAIGE: Okay. Thank you. And so with 17 that, that concludes our presentation. Any additional 18 questions?
19 CHAIR REMPE: So full of thoughts. I also 20 thought this was a great way to organize things. And 21 actually I'm watching it and knowing your plans for 22 changes, I think your website, again, it's just one 23 member's comment is a good place to do this because it 24 reminds me of some of the guidance for advanced 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
57 reactors where things are changing. And so this will 1
allow you to make changes and people know to go to the 2
latest version. So I think you are taking a wise path 3
but that's my opinion.
4 The other thing I'm thinking about is this 5
was a good way to organize it, and I think maybe it 6
was motivated by our request that you might not have 7
done it without it. And I'm seeing some heads shaking 8
up and down.
9 And I think in light of that, it's an 10 information briefing. But in our monthly meeting 11 summary, I'm not suggesting a letter here, but a 12 couple of paragraphs saying we had this meeting, and 13 the members agreed that it was a great way to organize 14 it.
15 And I think it would be a good idea. And 16 that's one member's suggestion to try and make Member 17 Brown do a little work. And we could even take a soft 18 vote. But it's a couple of paragraphs, Charlie, but 19 I think, it's a good thing to acknowledge it.
20 (Simultaneous speaking.)
21 MEMBER BROWN: -- four or five weeks 22 because I have forgotten enough of it that I can't 23 repeat it very well.
24 CHAIR REMPE: Well, anyway I think we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 ought to acknowledge it.
1 MEMBER MARCH-LEUBA: Charlie, you can 2
delegate it to Christina.
3 CHAIR REMPE: And then have you review it, 4
of course.
5 MEMBER MARCH-LEUBA: Do you want me to ask 6
ChatGPT to write it for you?
7 MEMBER BROWN: I'm glad you all did that.
8 Christina worked with you all, I think, closely. She 9
did an excellent job, I thought, coordinating with the 10 staff. We went through several iterations in terms of 11 developing clarity.
12 I mean, you all had the framework there, 13 but there were a lot of -- I know I got emails, and we 14 had some back and forths. And I said charge. So I 15 really appreciate Christina's efforts on this and your 16 all's non-reluctance to work with, to take some 17 feedback from us as you developed this.
18 I knew it was very important relative to 19 some of the comments from the members to get a good 20 clear view of how all this tangled web of Reg. Guides 21 and everything. This certainly is a real compliment 22 coming from me, and I think you've heard that from 23 other committee members also, that this really 24 untangles that web very, very well.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
59 MEMBER HALNON: Yeah, I would go one step 1
further and say, you know, we've had a couple of 2
presentations of roadmaps. And this one has been the 3
best organized and easiest to get through. So I would 4
suggest holding this up, at least from my opinion, as 5
a model for the future.
6 It seems like hyperlinks are fairly simple 7
technology, and they're just pictures, right, but they 8
really drive you where you need to go.
9 MEMBER BROWN: Any other members have any 10 other comments?
11 CHAIR REMPE: I want to push the issue.
12 I think it ought to be acknowledged in our meeting 13 somehow.
14 MEMBER BROWN: Do any of the members other 15 than Joy have any other comments?
16 MEMBER HALNON: Seconded. I second.
17 VICE CHAIR KIRCHNER: Just well done. It 18 answers --
19 MEMBER HALNON: I third it then.
20 MEMBER BROWN: Third what?
21 MEMBER HALNON: Joy's comment. I second 22 Dave's second.
23 CHAIR REMPE: Again, not a letter. If you 24 wanted more, we could do more. But I think --
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 MEMBER BROWN: No, we couldn't.
1 CHAIR REMPE: -- it's something you could 2
point to also if you need anything to say, hey, you 3
know, the ACRS is pleased we did this and stuff like 4
that.
5 MR. BENNER: This is Eric Benner. Chair 6
Rempe, Member Brown and all members, we do appreciate 7
the prodding. We had pieces of this to close out the 8
creative action plan we did. We did have an action 9
there of a strategic look of sort of how this was put 10 together so we had piece parts.
11 And I really want to thank Gilberto 12 because he's just been with us for months, and Jason 13 said, hey, I'm going to have Gilberto do this because 14 if he can understand it, and he said -- I'm not going 15 to say what he said.
16 And we said that's a great, great idea.
17 And a lot of people got together. But we saw the 18 benefit of -- I just half jokingly said we have people 19 presenting who are going to be the people doing this 20 work for the next couple of decades, but it was just 21 half joking because they need to understand this 22 moving forward. And what the members have pointed out 23 is the applicant, typically new applicants, have to 24 understand it too.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 So we're going to leverage it. We are 1
going to leverage this in multiple workshops with the 2
advanced reactors. There we will make it readily 3
accessible. So we appreciate, you know, the committee 4
prodding us to get this done. Because now that we've 5
got it done, we're seeing all kinds of ways we're 6
going to be able to use it so.
7 MEMBER BROWN: I would also suggest that 8
you -- I know you all -- BDO's overall operation and 9
its presence, it does brief the commission on stuff.
10 This is a complicated area that is controversial and 11 has been in terms of how it's executed.
12 And this would provide, I think, a pretty 13 valuable short briefing in whatever time it is. But 14 I think this didn't take long at all. It took longer 15 because of the Q&A that we had. This was largely 16 about a half an hour presentation if you don't have 17 any questions. And I think it would be useful for the 18 commissioners to know that there has been real 19 progress on doing this.
20 I mean, it's obviously up to your all 21 bosses, but that's another thought process.
22 MR. BENNER: Yeah. One of the uses I was 23 going to do, we occasionally brief our senior 24 management on just interesting topics. And I was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 going to suggest this as a topic. And in that 1
briefing, we can talk about it going further.
2 MEMBER BROWN: That's fine. Did you have 3
something else, Greg? You look like you were about to 4
say something.
5 MEMBER HALNON: I was just going to say 6
you're writing your paragraph.
7 MEMBER BROWN: I will never remember what 8
I just said.
9 CHAIR REMPE: Eric is giving us good input 10 for that paragraph is what I would say.
11 MEMBER BROWN: Do you want to write a 12 paragraph for me?
13 MR. BENNER: I'll happily draft a 14 paragraph for you.
15 (Simultaneous speaking.)
16 MEMBER BROWN: I'll see if I can jumble 17 together a few coherent words. But you know anytime 18 I start doing this, you know how it gets. You have to 19 have background, facts, discussion.
20 CHAIR REMPE: A summary paragraph. We can 21 give you something Ron has done.
22 MEMBER BROWN: It will only be 200 or 300 23 lines long.
24 CHAIR REMPE: Okay. But anyway, I think 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 it ought to be done is all I'm saying. And it might 1
help in the future. Thank you very much though for 2
coming.
3 MEMBER BROWN: Okay. Again, thank you all 4
very much. And with that, any public comment? Can we 5
go out to public comment if there is anybody on the 6
phone lines that would like to provide an observation 7
or comment, this is your opportunity.
8 CHAIR REMPE: I would add, if you're on 9
the phone, sometimes you have to press star 6 to 10 unmute yourself.
11 MEMBER BROWN: Not hearing anything, I 12 will pass it back to the chairman.
13 CHAIR REMPE: Okay. So at this point, 14 we're going to go off the record. And, again, thank 15 you for coming in. And why don't we take a 15 minute 16 break and then let's come back. I'm going to ask 17 Member Ballinger to go first with his presentation 18 because I have not had time to -- against the last two 19 slides of mine. Is that okay? Okay. Go for it.
20 Let's come back then at 2:30.
21 (Whereupon, the above-entitled matter went 22 off the record at 2:16 p.m.)
23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
Advisory Committee on Reactor Safeguards (ACRS)
Full Committee Informational Briefing April 5, 2023 NRC Instrumentation and Controls (I&C)
Regulatory Infrastructure for Reactors
Presentation Outline
- Purpose & Objectives
- Background
- Accomplishments
- Overview: NRC I&C Licensing Infrastructure
- Overview: NRC I&C Staff Review Guidance
- I&C Regulatory Infrastructure Technical Areas
- Mapping between regulations and guidance
- Look Ahead
- Closing Remarks 2
Purpose & Objectives
- Brief the Advisory Committee on Reactor Safeguards (ACRS) on the NRCs I&C regulatory infrastructure mapping connecting the regulatory requirements with applicable guidance oFamiliarize the ACRS with the NRCs I&C regulatory infrastructure oCommunicate the staffs efforts to continue to modernize and improve clarity of the I&C regulatory infrastructure oCommunicate the interrelationships between the I&C requirements, guidance, and industry standards 3
=
Background===
- The Commission issued SRM-SECY-15-0106 (February 25, 2016) oDirected the staff to develop an integrated strategy to modernize the NRC's I&C regulatory infrastructure
- The Commission issued SRM-SECY-16-0070 (October 25, 2016) oApproved the implementation of the staffs Integrated Action Plan (IAP) to modernize the NRCs I&C regulatory infrastructure
- The staff issued SECY-19-0112 (November 2019) oVision for modernized I&C regulatory infrastructure with reduced uncertainty that enables the expanded safe use of digital I&C
- The staff is currently implementing the vision 4
Accomplishments Since Sept. 2021 ACRS Briefing on Digital I&C (DI&C) Infrastructure and Licensing Activities
- Issued guidance for verifying a DI&C items dependability critical characteristics based on an accredited certification during the dedicating process
- Issued RG 1.250, Rev. 0: Endorses NEI 17-06 on Commercial Grade Dedication
- Issued SECY-22-0076 to expand the DI&C common-cause failure policy
- Issued DG-1374 (RG 1.152, Rev. 4) to endorse IEEE Std 7-4.3.2-2016
- Held industry workshops on the I&C licensing framework for advanced reactors 5
See SECY-21-0091 and SECY-22-0095 for staffs annual updates to the Commission
Regulatory Guides (26)
Endorsed Industry Standards, Recommended Practices, and Guides (e.g., IEEE, IEC, EPRI, ISA, NEI)
- Regulations Title 10, Code of Federal Regulations (10 CFR)
- Staff Requirements Memoranda (SRMs)
Overview: NRC I&C Licensing Infrastructure Policy and Requirements 6
- Design Specific Review Standard (DSRS)
- Design Review Guide (DRG)
- NUREG-1537 - Non-power Production and Utilization Facilities (NPUFs)
NRC Staff Review Guidance Regulatory Guidance
Document Description SRP Chapter 7, BTPs, ISGs Licensing review guidance for Light Water Reactors (LWR)
DSRS Chapter 7 Design specific review standard (e.g., NuScale)
DRG Generic licensing review guidance for non-LWR reactors NUREG-1537 Licensing review guidance for NPUFs Overview: NRC I&C Staff Review Guidance 7
- Design Specific Review Standard (DSRS)
- Design Review Guide (DRG)
- NUREG-1537 - Non-power Production and Utilization Facilities (NPUFs)
NRC Staff Review Guidance
Overview: I&C Licensing Review Guidance 8
Staff Review Documents Description Standard Review Plan - Chapter 7 (Instrumentation and Controls)
Chapter 7 of the SRP provides guidance for review of the I&C portions of: (1) applications for nuclear reactor licenses or permits and (2) amendments to existing licenses Branch Technical Positions (contained within Chapter 7)
The BTPs represent guidelines intended to supplement the acceptance criteria established in regulations and the guidelines provided in regulatory guides and applicable industry standards DI&C Interim Staff Guidance (supplemental information to Chapter 7)
ISGs are often used to clarify or expand on guidance found in standard review plans or regulatory guides, and facilitate the resolution of technical or licensing issues within established regulatory processes
I&C Regulatory Infrastructure Technical Areas Criteria for Safety System Programmable Digital Devices Criteria for Safety Systems Digital Development and Reliability Commercial Grade Dedication Equipment Qualification Setpoint Establishment and Maintenance Instrument Sensing Lines Accident Monitoring Instrumentation Cyber Security Security 10 CFR Part 73 9
Safety 10 CFR Parts 50 & 52
RG 1.47, Rev. 1 Bypassed and Inoperable Status Indication for NPP Safety System RG 1.62, Rev. 1 Manual Initiation of Protection Actions RG 1.75, Rev. 3 Independence of Electrical Safety Systems RG 1.53, Rev. 2 Application of the Single-Failure Criterion to Safety Systems RG 1.22, Rev. 0 Periodic Testing of Protection System Actuation Functions RG 1.118, Rev. 3 Periodic Testing of Electric Power and Protection Systems ANSI/IEEE Std 338-1987 Criteria for Periodic Surveillance Testing IEEE Std 379-2000 Application of the Single-Failure Criterion to Nuclear Power Generating Station Safety Systems IEEE Std 384-1992 Standard Criteria for Independence of Class 1E Equipment and Circuits NUREG-0800 Standard Review Plan, Chapter 7 - I&C 7.1 - Introduction, 7.2 - Reactor Trip System, 7.3 - Engineered Safety Features Systems, 7.4 - Safe Shutdown Systems, 7.5 - Information Systems Important to Safety, 7.6 - Interlock Systems Important to Safety, 7.7 - Control Systems, 7.8 - Diverse Instrumentation and Control
- Systems, 7.9 - Data Communication Systems BTP 7-8 Guidance for Application of Regulatory Guide 1.22 BTP 7-19
- Guidance for Evaluation of Diversity and Defense-in-Depth in Digital Computer-Based I&C Systems ISG-06
- Licensing Process (D.1 - System Description, D.2 - System Architecture, D.6 - IEEE Std 603/IEEE Std 7-4.3.2 Compliance/Conformance) 10 CFR Part 50 Construction Permit (CP),
Operating License (OL) 10 CFR Part 52 Design Certification (DC),
Combined Operating License (COL), Standard Design Approval (SDA),
Manufacturing License (ML) 10 CFR Part 50, Appendix A General Design Criteria 1,2,4,13,19, 20,21,22,24,25,29,34 10 CFR Part 50, Appendix B Quality Assurance Criteria 50.55a(h)
IEEE Std 603-1991 IEEE Std 279-1971 SRM-SECY-93-087
- Item 18 Regulatory Requirements & Policy Regulatory Guidance Staff Guidance Criteria for Safety Systems
- Digital-Specific RG 1.30, Rev. 0 QA Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment IEEE Std 336-1971 Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations Criteria for Safety Systems 10 Back RG 1.153, Rev. 1 Criteria for Safety Systems
DG-1374 (RG 1.152, Rev. 4)
Criteria for Use of Computers in Safety Systems of NPPs IEEE Std 7-4.3.2-2016 Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations RG 1.152, Rev. 3
- Criteria for Use of Computers in Safety Systems of NPPs IEEE Std 7-4.3.2-2003 Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations NUREG-0800 Standard Review Plan, Chapter 7 BTP 7-17
- Guidance on Self-Test and Surveillance Test Provisions BTP 7-19
- Guidance for Evaluation of Diversity and Defense-in-Depth in Digital Computer-Based I&C Systems BTP 7-21
- Guidance on Digital Computer Real-Time Performance ISG-04
- Highly-Integrated Control Room Communications ISG-06
- Licensing Process (D.1 - System Description, D.2 - System Architecture, D.5 - Applying a Topical Report, D.6 - IEEE Std 603/IEEE Std 7-4.3.2 Compliance/Conformance, D.8 - SDOE)
Regulatory Guidance Staff Guidance Criteria for Safety System Programmable Digital Devices Criteria for Safety System Programmable Digital Devices 11
- Digital-Specific 10 CFR Part 50 CP, OL 10 CFR Part 52 DC, COL, SDA, ML 10 CFR Part 50, Appendix A General Design Criteria 21 10 CFR Part 50, Appendix B Quality Assurance Criteria 50.55a(h)
IEEE Std 603-1991 IEEE Std 279-1971 SRM-SECY-93-087
- Item 18 Applicable IEEE Std 7-4.3.2-2016 Clauses 5.1 Single-Failure Criterion 5.5 System Integrity 5.5.1 Design for PDD Integrity 5.5.2 Design for Test and Calibration 5.5.3 Fault Detection and Self-Diagnostics 5.5.4 Prioritization of Functions 5.6 Independence 5.7 Capability for Testing and Calibration 5.8 Information Displays 5.9 Control of Access 5.11 Identification 5.15 Reliability 5.16 Common Cause Failure Criteria 5.18 Simplicity Regulatory Requirements & Policy Back
DG-1374 (RG 1.152, Rev. 4)
Criteria for Use of Computers in Safety Systems of NPPs IEEE Std 7-4.3.2-2016 Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations RG 1.152, Rev. 3
- Criteria for Use of Computers in Safety Systems of NPPs IEEE Std 7-4.3.2-2003 Clause 5.3 Quality, Clause 5.9 Control of Access RG 1.173, Rev. 1
- Developing Software Life Cycle Processes for Digital Computer Software Used in Safety Systems of NPPs RG 1. 170, Rev. 1
- Software Test Documentation for Digital Computer Software Used in Safety Systems of NPPs RG 1.169, Rev. 1
- Configuration Management Plans for Digital Computer Software Used in Safety Systems of NPPs RG 1.168, Rev. 2
- Verification, Validation, Reviews and Audits for Digital Computer Software Used in Safety Systems of NPPs IEEE Std 828-2005 Standard for Configuration Management in Systems and Software Engineering NUREG-0800 Standard Review Plan, Chapter 7 BTP 7-14
- Guidance on Software Reviews for Digital Computer-Based I&C Systems ISG-06
- Licensing Process (D.4 - Digital I&C System Development Processes, D.8 - SDOE, D.9 - Other Review Guidance for Tier 1, 2, and 3 Reviews) 10 CFR Part 50 CP, OL 10 CFR Part 52 DC, COL, SDA, ML 10 CFR Part 50, Appendix A General Design Criteria 1, 21 10 CFR Part 50, Appendix B Quality Assurance Criteria 50.55a(h)
IEEE Std 603-1991 IEEE Std 279-1971 Regulatory Requirements Regulatory Guidance Staff Guidance Digital Development and Reliability IEEE Std 829-2008 Standard for Software and System Test Documentation ANSI/IEEE Std 1008-1987 Standard for Software Unit Testing IEEE Std 830-1998 Recommended Practice for Software Requirements Specifications IEEE Std 1074-2006 IEEE Standard for Developing a Software Project Life Cycle Process IEEE Std 1028-2008 Standard for Software Reviews and Audits IEEE Std 1012-2004 Standard for Software Verification and Validation Digital Development and Reliability RG 1.172, Rev. 1
- Software Requirements Specifications for Digital Computer Software Used in Safety Systems of NPPs RG 1.171, Rev. 1
- Software Unit Testing for Digital Computer Software Used in Safety Systems of NPPs 12
- Digital-Specific Back
DG-1374 (RG 1.152, Rev. 4)
- Criteria for Programmable Digital Devices in Safety-Related Systems of NPPs IEEE Std 7-4.3.2-2016 Clause 5.17 Use of Commercial Digital Equipment RG 1.164, Rev. 0 Dedication of Commercial-Grade Items for Use in NPPs RG 1.250, Rev. 0
- Dedication of Commercial-Grade Digital I&C Items for use in NPPs NEI 17-06, Rev. 1 Guidance on Using IEC 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications EPRI 3002002982, Rev. 1 to EPRI NP-5652 and TR-102260 Guideline for the Acceptance of Commercial-Grade Items in Nuclear Safety-Related Applications Regulatory Requirements Regulatory Guidance Staff Guidance NUREG-0800 Standard Review Plan, Chapter 7 BTP 7-14
- Guidance for Software Review for Digital Computer-Based Instrumentation and Control Systems ISG-06
- Licensing Process (D.9.9 - Commercial-Grade Dedication of Digital Equipment)
Commercial Grade Dedication Commercial Grade Dedication 13
- Digital-Specific 10 CFR Part 21 Reporting of Defects and Noncompliance 10 CFR Part 50 CP, OL 10 CFR Part 52 DC, COL, SDA, ML 10 CFR Part 50, Appendix A General Design Criteria 21 10 CFR Part 50, Appendix B Quality Assurance Criteria 50.55a(h)
IEEE Std 603-1991 IEEE Std 279-1971 Back EPRI TR-106439 Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Applications EPRI TR-107330 Generic Requirements Specification for Qualifying a Commercially Available PLC for Safety-Related Applications in NPPs Staff Review of EPRI TR-106439 *
(7/17/1997)
Staff Review of EPRI TR-107330 *
(1/9/1998)
IEEE Std C62.41.2-2002 IEC 61000-6 IEC 61000-4 DG-1374 (RG 1.152, Rev. 4)
Criteria for Use of Computers in Safety Systems of NPPs IEEE Std 7-4.3.2-2016 Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations RG 1.152, Rev. 3
- Criteria for Use of Computers in Safety Systems of NPPs IEEE Std 7-4.3.2-2003, Clause 5.4 Equipment Qualification RG 1.100, Rev. 4 Seismic Qualification of Electric and Mechanical Equipment for NPPs RG 1.209, Rev. 0
- Guidelines for EQ of Safety-Related Computer-Based I&C Systems in NPPs IEEE Std 323-2003 Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations IEEE Std 344-2013 Standard for Seismic Qualification of Equipment Regulatory Requirements Regulatory Guidance Staff Guidance NUREG-0800 Standard Review Plan, Chapter 7 ISG-06
- Licensing Process (D.3 - Hardware Equipment Qualification)
RG 1.180, Rev. 2 Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related I&C Systems 10 CFR Part 50 CP, OL 10 CFR Part 52 DC, COL, SDA, ML 10 CFR Part 50, Appendix A General Design Criteria 1,2,4,13,21,23 50.49 Environmental Qualification of Electric Equipment Important to Safety for NPPs 50.55a(h)
IEEE Std 603-1991 IEEE Std 279-1971 Equipment Qualification DG-1361 (RG 1.89, Rev. 2)
IEC/IEEE Std 60780/323-2016 Standard Criteria for Digital Computers in Safety IEEE Std 323-1974 Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations IEEE Std C37.98-2013 Seismic Qual. Testing of Protective Relays and Auxiliaries ASME QME-1-2017 Qualification of Active Mechanical Equipment IEEE Std 1050-2004 IEEE Std C62.41.1-2002 IEEE Std C62.45-2002 MIL-STD-461G IEC 61000-3 Equipment Qualification RG 1.89, Rev. 1 Environmental Qualification of Certain Electric Equipment Important to Safety for NPPs 14
- Digital-Specific Back
Regulatory Requirements
& Orders Regulatory Guidance Staff Guidance Accident Monitoring Instrumentation RG 1.97, Rev. 5 Criteria for Accident Monitoring Instrumentation for NPPs IEEE Std 497-2016 Standard Criteria for Accident Monitoring Instrumentation for Nuclear Power Generating Stations NUREG-0800 Standard Review Plan, Chapter 7 BTP 7-10 Guidance on Application of Regulatory Guide 1.97 Accident Monitoring Instrumentation 15 10 CFR Part 50 CP, OL 10 CFR Part 52 DC, COL, SDA, ML 10 CFR Part 50, Appendix A General Design Criteria 19 10 CFR 50.34(f)(2)(xix)
Additional TMI-related Requirements 10 CFR 50.155(e)
Spent Fuel Pool Monitoring Back
Regulatory Requirements Regulatory Guidance Staff Guidance 10 CFR Part 50 CP, OL 10 CFR Part 52 DC, COL, SDA, ML 10 CFR Part 50, Appendix A General Design Criteria 13, 20 10 CFR 50.36(c)(1)(ii)(A)
Technical Specifications 50.55a(h)
IEEE Std 603-1991 IEEE Std 279-1971 Setpoints Establishment and Maintenance RG 1. 105, Rev. 4 Setpoints for Safety-Related Instrumentation ANSI/ISA 67.04.01-2018 Setpoints for Nuclear Safety-Related Instrumentation NUREG-0800 Standard Review Plan, Chapter 7 BTP 7-12 Guidance on Establishing and Maintaining Instrument Setpoints ISG-06
- Licensing Process (D.7 - Technical Specifications)
Setpoint Establishment and Maintenance 16
- Digital-Specific Back
Regulatory Requirements Regulatory Guidance Staff Guidance 10 CFR Part 50 CP, OL 10 CFR Part 52 DC, COL, SDA, ML 10 CFR Part 50, Appendix A General Design Criteria 1,2,13,21,22,23,24 10 CFR 50.36(c)(2)(ii)
Technical Specifications RG 1.151, Rev. 2 Instrument Sensing Lines IEEE Std 622-1987 Recommended Practice for the Design and Installation of Electric Heat Tracing Systems for Nuclear Power Generating Systems ANSI/ISA-67.02.01-2014 Nuclear Safety-Related Instrument Sensing Line Piping and Tubing Standard for Use in NPPs NUREG-0800 Standard Review Plan, Chapter 7 Instrument Sensing Lines Instrument Sensing Lines 17 Back
RG 5.71, Rev. 1 Cyber Security Programs for Nuclear Facilities Regulatory Requirements Regulatory Guidance Staff Guidance RG 5.83, Rev. 0 Cyber Security Event Notifications Cyber Security NUREG-0800 Standard Review Plan, Section 13.6.6 Cyber Security 10 CFR 7
3.1 Purpose and Scope
10 CFR 73.54 Protection of Digital Computer and Communication Systems and Networks 10 CFR 73.77 Cyber Security Event Notification 18 SDOE Back 10 CFR Part 50 OL 10 CFR Part 52 COL
Look Ahead
- SRP Modernization of Chapter 7
- Update digital development and reliability guidance
- Take necessary steps to sunset ISG-04
- Follow Commission direction regarding SECY-22-0076
- Path forward for IEEE Std 603-2018 19
Closing Remarks
References
- Commission Papers (SECY) - https://www.nrc.gov/reading-rm/doc-collections/commission/secys/index.html
- Staff Requirements Memoranda - https://www.nrc.gov/reading-rm/doc-collections/commission/srm/index.html
- Regulatory Guides - https://www.nrc.gov/reading-rm/doc-collections/reg-guides/power-reactors/rg/index.html
- Interim Staff Guidance - https://www.nrc.gov/reading-rm/doc-collections/isg/index.html
- Review of EPRI TR-106439, Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety - https://www.nrc.gov/docs/ML0921/ML092190664.pdf
- Safety Evaluation of EPRI TR-107330, Generic Requirements Specification for Qualifying a Commercially Available PLC for Safety-Related Applications in NPPs - https://www.nrc.gov/docs/ML1220/ML12205A265.pdf
- IEEE Standards - https://ieeexplore.ieee.org/Xplore/home.jsp
- ACRS September 2021 DI&C Systems Meeting Transcript (ML21299A197) - https://www.nrc.gov/reading-rm/doc-collections/acrs/agenda/2021/index.html 21
Acronyms 22 Acronym Description Acronym Description ACRS Advisory Committee on Reactor Safeguards ISG Interim Staff Guidance ANSI American National Standards Institute LWR Light-Water Reactor ASME American Society of Mechanical Engineers ML Manufacturing License BTP Branch Technical Position NEI Nuclear Energy Institute CFR Code of Federal Regulations NPP Nuclear Power Plant COL Combined Operating License NPUFs Non-power Production and Utilization Facilities CP Construction Permit NRC Nuclear Regulatory Commission DC Design Certification OL Operating License DI&C Digital Instrumentation and Controls QA Quality Assurance DG Draft Guide PDD Programmable Digital Device DRG Design Review Guide PLC Programmable Logic Controller DSRS Design Specific Review Standard RG Regulatory Guide EPRI Electric Power Research Institute SDA Standard Design Approval IAP Integrated Action Plan SDOE Secure Development and Operational Environment I&C Instrumentation and Controls SIL Safety Integrity Level IEC International Electrotechnical Commission SRM Staff Requirements Memorandum IEEE Institute of Electrical and Electronics Engineers SRP Standard Review Plan ISA International Society of Automation V&V Verification and Validation
Backup Slides
I&C Technical Areas & IEEE Std 7-4.3.2-2016 Clauses 24 5.17 - Use of Commercial Digital Equipment 5.4 - Equipment Qualification 5.1 - Single-Failure Criterion 5.5 - System Integrity 5.5.1 Design for PDD Integrity 5.5.2 Design for Test and Calibration 5.5.3 Fault Detection and Self-Diagnostics 5.5.4 Prioritization of Functions 5.6 - Independence 5.7 - Capability for Testing and Calibration 5.8 - Information Displays 5.9 - Control of Access 5.11 - Identification 5.15 - Reliability 5.16 - Common Cause Failure Criteria 5.18 - Simplicity 5.3 - Quality 5.3.1 Software Development 5.3.2 Software Tools 5.3.3 Verification and Validation 5.3.4 Independent V&V Requirements 5.3.5 Software Configuration Management 5.3.6 Software Project Risk Management 5.9 - Control of Access Digital Development and Reliability Clauses 4, 5.2, 5.10, 5.12, 5.13, 5.14, 6, 7, 8 do not provide criteria beyond IEEE Std 603 Commercial Grade Dedication Equipment Qualification IEEE Std 7-4.3.2-2016 does not provide specific criteria for Back Criteria for Safety Systems Criteria for Safety System Programmable Digital Devices
I&C Technical Areas & ISG-06, Licensing Process 25 Digital Development and Reliability Criteria for Safety System Programmable Digital Devices Commercial Grade Dedication Equipment Qualification ISG-06, Rev. 2 does not provide specific licensing review guidance for D.1 - System Description D.2 - System Architecture D.6 - IEEE Std 603/IEEE Std 7-4.3.2 Compliance/Conformance Criteria for Safety Systems D.1 - System Description D.2 - System Architecture D.5 - Applying a Topical Report D.8 - Secure Development and Operational Environment D.6 - IEEE Std 603/IEEE Std 7-4.3.2 Compliance/Conformance D.4 - Digital I&C System Development Processes D.8 - Secure Development and Operational Environment D.9 - Other Review Guidance for Tier 1, 2, and 3 Reviews D.9.9 - Commercial-Grade Dedication of Digital Equipment D.3 - Hardware Equipment Qualification Setpoint Establishment and Maintenance D.7 - Technical Specifications Back