ML24256A201

NRC Slides Dic - 2024 NEI NEA - September 12 2024

ML24256A201
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Issue date:	09/12/2024
From:	Samir Darbali, Jason Paige, Rodriguez G NRC/NRR/DEX/EICB
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Regulatory Improvements to Support Digital Modernization Jason Paige, Samir Darbali, Gilberto Blas Rodriguez Division of Engineering and External Hazards Office of Nuclear Reactor Regulation Nuclear Regulatory Commission NEI Nuclear Energy Assembly September 12, 2024

Vogtle Unit 3 Control Room Photo Credit: Southern Nuclear Co./Georgia Power Co.

OUTLINE

• NRC Vision for Digital I&C

• I&C Regulatory Infrastructure Organization

• Accomplishments

• Ongoing Activities

• Licensing Activities 2

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

From NRC SECY-19-0112 3

The Road Were On Clear 50.59 Expectations Efficient Licensing Endorsement of Updated Standards 4

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Background===

5

• SRM-SECY-15-0106 (February 2016) o Directed the staff to develop an integrated strategy to modernize the NRCs I&C regulatory infrastructure.

• SRM-SECY-16-0070 (October 2016) o Approved the implementation of the staffs Integrated Action Plan to modernize the NRCs I&C regulatory infrastructure.

• SECY-19-0112 (November 2019) o Lays out the NRCs vision for a modernized I&C regulatory infrastructure.

• The staff continues to make improvements under our normal processes.

6 I&C REGULATORY INFRASTRUCTURE ORGANIZATION

Regulatory Guides (RGs)

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)

Policy and Requirements

• Standard Review Plan (SRP) o Branch Technical Positions (BTPs) o Interim Staff Guidance (ISGs)

• Design Specific Review Standard (DSRS)

• Design Review Guide (DRG)

• NUREG-1537 - Non-power Production and Utilization Facilities (NPUFs)

NRC Staff Review Guidance Regulatory Guidance I&C Regulatory Infrastructure Organization 7

I&C Regulatory Infrastructure Organization

• Nine technical areas related to I&C safety and security.

• Each technical area contains a detailed mapping of applicable regulatory requirements, guidance, and endorsed industry standards (https://www.nrc.gov/reactors/digital/modernize.html).

8

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 Defense-in-Depth and Diversity to Address CCF due to Latent Design Defects in Digital 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-22-0076, SRM-SECY-93-087

• Item 18 Regulatory Requirements & Policy Regulatory Guidance Staff Guidance Criteria for Safety Systems

• Digital-Specific RG 1.30, Rev. 1 Installation, Inspection, and Testing for Class 1E Power, Instrumentation, and Control Equipment at Production and Utilization Facilities IEEE Std 336-2020 Recommended Practice for Installation, Inspection, and Testing for Class 1E Power, Instrumentation, and Control Equipment at Nuclear Facilities Criteria for Safety Systems RG 1.153, Rev. 1 Criteria for Safety Systems RG 1.28, Rev. 5 Quality Assurance Program Criteria (Design and Construction)

ASME NQA-1b-2011 Addenda to NQA-1-2008, NQA-1-2012, and NQA-1-2015 9

IEEE Std 7-4.3.2-2016 Standard Criteria for PDDs 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

• 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-22-0076, 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 RG 1.152, Rev. 4 Criteria for Programmable Digital Devices in Safety-Related Systems of NPPs 10

11 ACCOMPLISHMENTS

Licensing Guidance - LWRs DI&C-ISG-06, Licensing Process o

For licensing reviews of license amendment requests (LARs) associated with safety-related DI&C modifications.

o For the review of the new architecture and design (e.g.,

system, hardware, software and human-system interfaces) to ensure regulatory requirements are met.

Revision 2 of ISG-06 o

Issued in December 2018.

o Incorporated lessons learned to make improvements to the existing Traditional (or Tiered) Review Process.

o Introduced a new streamlined Alternate Review Process to improve the timeliness of licensing reviews.

ISG-06, REVISION 2 LWR DI&C MODERNIZATION 12

Licensing Guidance - LWRs ISG-06, REVISION 2 TRADITIONAL REVIEW PROCESS 13

Licensing Guidance - LWRs ISG-06, REVISION 2 ALTERNATE REVIEW PROCESS 14

Licensing Guidance - Non-LWRs Design Review Guide (DRG) o Issued in February 2021.

o Licensing framework based on RG 1.233, Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors.

The DRG provides guidance for the NRC staff to assess whether:

o The specified I&C systems support the overall nuclear power plant performance objectives.

o That there is reasonable assurance that the plant is designed to adequately protect public health and safety.

o That the design complies with the applicable regulatory requirements.

The staff is currently holding periodic public workshops with the applicants and industry stakeholders on use of the DRG and RG 1.233.

DESIGN REVIEW GUIDE NON-LWR DI&C LICENSING 15

Common-Cause Failure SECY-22-0076 o

In August 2022, the NRC staff submitted to the Commission SECY-22-0076, Expansion of Current Policy on Potential Common-Cause Failures [CCFs] in Digital Instrumentation and Control Systems.

o Requests expansion of the CCF policy to allow the use of risk-informed approaches as a means to justify an appropriate level of defense-in-depth and diversity (D3) for high safety significance DI&C systems.

SRM-SECY-22-0076 o

In May 2023, the Commission approved the staffs recommendation with edits and provided staff direction for developing implementing guidance.

SRM-SECY 0076 CCF EXPANDED POLICY 16

Common-Cause Failure SRM-SECY 0076 CCF EXPANDED POLICY 17 Point 2 Risk-Informed Approach Point 3 Design Techniques or Mitigation Measures Point 2 Best-Estimate Methods Point 3 Diverse Means Deterministic Path Risk-Informed Path Point 4 Independent and Diverse Displays and Manual Controls Point 1 Perform D3 Assessment

Common-Cause Failure BTP 7-19, Revision 9 o

Guidance for Evaluation of Defense in Depth and Diversity to Address Common-Cause Failure Due to Latent Design Defects in Digital Instrumentation and Control Systems.

o Issued in May 2024.

o Incorporates the expanded policy and provides review guidance for risk-informed D3 assessments, and the use of design techniques or mitigation measures other than diversity.

GUIDANCE LWR I&C LICENSING REVIEWS 18

The staff relies on the DRG and RG 1.233 to evaluate whether an application demonstrates adequate defense-in-depth for mitigation of licensing basis events.

The potential DI&C CCF for a reactor design is assessed in a holistic, integrated, risk-informed, and performance-based manner.

GUIDANCE NON-LWR I&C LICENSING REVIEWS Common-Cause Failure 19

RG 1.152, Revision 4 o

Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants o

Issued in July 2023.

o Endorses, with some exceptions and clarifications, IEEE Std 7-4.3.2-2016, IEEE Standard Criteria for Programmable Digital Devices in Safety Systems of Nuclear Power Generating Stations.

RG 1.152, REVISION 4 PROGRAMMABLE DIGITAL DEVICES Regulatory Guides 20

RG 1.250, Revision 0 o

Dedication of Commercial-Grade Digital Instrumentation and Control Items for Use in Nuclear Power Plants o

Issued in October 2022.

o Endorses, with clarifications, NEI 17-06, Guidance on Using IEC [International Electrotechnical Commission]

61508 Safety Integrity Level (SIL) Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications, Revision 1.

o Describes an approach that is acceptable to the staff for dedication of commercial-grade digital equipment for use in nuclear power plant safety applications.

RG 1.250, REVISION 0 COMMERCIAL GRADE DEDICATION Regulatory Guides 21

RG 5.71, Revision 1 o

Cybersecurity Programs for Nuclear Power Reactors o

Issued in February 2023.

o Provides NRC licensees and applicants with guidance on meeting the cybersecurity requirements described in 10 CFR 73.54, Protection of digital computer and communication systems and networks.

RG 5.71, REVISION 1 CYBERSECURITY Regulatory Guides 22

RIS 2002-22, Supplement 1 o

Clarification on Endorsement of Nuclear Energy Institute Guidance in Designing Digital Upgrades in Instrumentation and Control Systems o

Issued in May 2018.

o Clarifies NRCs previous endorsement of NEI 01-01 for 10 CFR 50.59 upgrades.

o Clarifies the use of qualitative assessments used to determine that CCF is sufficiently low.

RG 1.187, Revision 3 o

Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments o

Issued in June 2021.

o Endorses with clarifications NEI 96-07, Guidelines for 10 CFR 50.59 Evaluations, Appendix D, Revision 1, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications.

IMPLEMENTING GUIDANCE 10 CFR 50.59 DI&C Modifications 23

Inspection Procedure (IP) 52003 o

Digital Instrumentation and Control Modification Inspection o

Revised in July 2021.

o Supports regional inspections of DI&C modifications.

o Identifies the inspection requirements to verify that the licensee has developed, implemented, tested, installed, operated, and maintained the design according to the license amendment, safety evaluation, and in accordance with the manufacturers recommendations, and licensee commitments, including the commitments provided in the licensees cybersecurity plan.

IP 52003, Revision 1 DI&C MODIFICATION LARs Inspection Guidance 24

DI&C Operating Experience Smart Sample (OpESS) 2023/01 o

Digital Instrumentation and Controls o

Issued in February 2024.

o Provides support to baseline inspection activities in the area of DI&C modifications.

o Provides examples where deficiencies may be present in DI&C equipment in order to inform the inspection of design, modification, and maintenance activities.

DI&C OpESS 2023/01 DI&C 50.59 MODIFICATIONS Inspection Guidance 25

26 ONGOING ACTIVITIES

IEEE Std. 603-2018 27 Incorporation by Reference of IEEE Std 603-2018, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations

• Currently, 10 CFR 50.55a(h) incorporates by reference (IBR) IEEE Std 603-19911.

o This standard is over 30 years old and has undergone multiple revisions (1998, 2009 and 2018).

o Many applicants and vendors use more recent versions than IEEE Std 603-1991.

• The effort to IBR IEEE Std 603-2018 has two objectives:

o Provide industry with the regulatory confidence to use the 2018 version of the standard in the development of safety related I&C systems; and o Streamline NRCs ability to endorse new and improved standards that are developed to address digital technology advancements.

• A public meeting is planned for 3rd quarter 2024.

110 CFR 50.55a(h) also IBRs IEEE 279-1968 and/or IEEE 279-1971 for protection and safety systems for power plants licensed before May 13, 1999.

Software Regulatory Guides 28 RGs 1.168 - 1.173

• Revise RGs to endorse the latest industry guidance:

o Update RG 1.168, Verification, Validation, Reviews, and Audits for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, to endorse IEEE Std 1012-2016, IEEE Standard for System, Software, and Hardware Verification and Validation o Explore the organization of the software development RG suite (1.168 - 1.173) to determine improvements, level of effort and maintenance involved.

NEI 20-07, Revision E 29 NEI 20-07, Guidance for Addressing Common Cause Failure in High Safety-Significant Safety-Related Digital I&C Systems

• Draft Revision E submitted in July 2023.

• Provides industry guidance for a risk-informed graded approach and an iterative systems engineering process for addressing DI&C CCFs in alignment with the revised CCF policy (SRM-SECY-22-0076).

• NRC staff provided comments which were discussed during four public meetings (March-July 2024).

Draft Regulatory Issue Summary 30 Draft Regulatory Issue Summary (RIS), Pre-Application Communication and Scheduling for Licensing Actions Related to Digital Instrumentation and Controls

• Issued for public comments in December 2023.

• NRC seeks scheduling information for preapplication activities and submittal of applications (e.g., LARs) related to DI&C from all addressees to help inform the NRCs budget and resource planning.

• Voluntary information requested includes: estimated LAR submittal and pre-application timeframe, plant systems to be upgraded, I&C platforms to be used, and intended licensing process.

31 LICENSING ACTIVITIES

Operating Reactor Licensing 32 Limerick Units 1 & 2

• Constellation submitted a LAR in 2022 for an analog-to-digital replacement of the reactor protection system, nuclear steam supply shutoff system, and emergency core cooling system.

• LAR review is ongoing.

Peach Bottom Units 1 & 2

• Pre-application meetings held in 2024.

• Constellation is planning to submit in April 2025 a LAR for a digital-to-digital replacement of the emergency core cooling system and post accident monitoring system compensated level.

New and Advanced Reactor Licensing 33 Small Modular Reactors NuScale US460 SDA Application Clinch River CP Application (BWRX-300)

Holtec SMR-300 Non-LWRs Kemmerer CP Application (Natrium)

Kairos Hermes 2 CP Application Long Mott CP Application (X-Energy XE-100)

Westinghouse eVinci Micro Reactor Terrestrial Energy USA Research & Test Reactors and Fuel Cycle Facilities SHINE OL Application (Medical Isotopes)

Kairos Hermes 1 OL Application (RTR)

Abilene Christian University CP Application (RTR)

X-Energy (Fuel Cycle Facility)

SUMMARY

34

Clear 50.59 Expectations 06 ISG RIS 2002-22 Sup. 1 BTP 7-19 NEI 96-07 App. D Efficient Licensing NEI 20-07 NEI 17-06 Endorsement of Updated Standards IEEE IEC 35

How Can You Help?

36

• Communicate industry needs for endorsing standards and updating regulatory guides.

• Communicate projected schedules for upcoming digital modification submittals.

• Continue supporting pre-submittal meetings and stakeholder engagements.

37 CLOSING REMARKS

38 Thank You!

ARP - Alternate Review Process BTP - Branch Technical Position CCF - Common Cause Failure CFR - Code of Federal Regulations CP - Construction Permit DI&C - Digital Instrumentation and Controls D3 - Defense in Depth and Diversity DRG - Design Review Guide DSRS - Design Specific Review Standard EPRI - Electric Power Research Institute FAT - Factory Acceptance Test IBR - Incorporation by Reference IEC - International Electrotechnical Commission IEEE - Institute of Electrical and Electronics Engineers I&C - Instrumentation and Controls IP - Inspection Procedure ISG - Interim Staff Guidance LA - License Amendment LAR - License Amendment Request LWR - Light Water Reactors NEI - Nuclear Energy Institute Non-LWR - Non-Light Water Reactor NPUF - Non-power Production or Utilization Facility NRC - Nuclear Regulatory Commission OL - Operating License OpESS - Operating Experience Smart Sample RG - Regulatory Guide RIS - Regulatory Issue Summary RTR - Research and Test Reactor SAT - Site Acceptance Test SDA - Standard Design Approval SE - Safety Evaluation SECY - Official Communication with the Commission SIL - Safety Integrity Level SMRs - Small Modular Reactors SRM - Staff Requirements Memorandum Issued by the Commission SRP - Standard Review Plan TR - Topical Report Acronyms