ML24289A230
| ML24289A230 | |
| Person / Time | |
|---|---|
| Issue date: | 10/17/2024 |
| From: | Rodriguez G NRC/NRR/DEX/EICB |
| To: | Jason Paige NRC/NRR/DEX |
| Gilberto Blas | |
| References | |
| Download: ML24289A230 (1) | |
Text
October 17, 2024 MEMORANDUM TO:
Jason C. Paige, Chief Long Term Operations and Modernization Branch Division of External Hazards Office of Nuclear Reactor Regulation FROM:
Gilberto Blas Rodriguez, Electronics Engineer
/RA/
Instrumentation & Controls Branch Division of External Hazards Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF SEPTEMBER 19, 2024, PUBLIC MEETING DISCUSS PROPOSED PATH FORWARD FOR INDUSTRYS USE OF INSTITUTE OF ELECTRICAL AND ELECTRONICS ENGINEERS STANDARD (IEEE) 603-2018, CRITERIA FOR SAFETY SYSTEMS On September 19, 2024, an Information Meeting with a Question and Answer Session was held between the U.S. Nuclear Regulatory Commission (NRC) staff and external stakeholders to discuss the NRC staffs proposed path forward to address the use of the 2018 version of Institute of Electrical and Electronics Engineers (IEEE) Standard (Std) 603, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations, in the development of safety-related instrumentation and control (I&C) systems.
The meeting notice and agenda were noticed on the NRC public website, dated September 5, 2024, and in the NRC Agency Documents Access and Management System (ADAMS) at Accession No. ML24262A149. The meeting was held online via TEAMS.
The NRC staff opened the meeting with introductory remarks, and then gave a presentation (ML24262A141) on the efforts to provide industry the regulatory confidence to use IEEE Std 603-2018 in the development of safety-related I&C systems. The NRC staff discussed the options that were considered for the path forward on the use of the standard, and the results of their evaluation. This work builds on the efforts previously discussed with stakeholders at the public meeting held on September 14, 2023 (ML23242A169). Following this meeting, the staff received feedback from the Nuclear Energy Institute (NEI) in a letter dated November 3, 2023 (ML23307A127). The staff considered this feedback in their evaluation and decided to incorporate IEEE Std 603-2018 by reference (IBR) into Title 10 of the Code of Federal Regulations (CFR) Part 50.55a(h) through rulemaking.
CONTACT: G. BlasRodriguez, NRR/DEX (301) 287-9260
J. Paige 2
The NRC staff elaborated on the evaluation for the path forward to IBR, the standard, and the detailed comparative analysis made to the current standard of IEEE Std. 603-1991 incorporated in Title 10 of the CFR. The presentation detailed the line-by-line comparison that was made between revisions to show that the 2018 standard is routine in nature with the revision being predominantly identical, equivalent, or enhanced language. The NRC staff shared that the IBR of IEEE 603-2018 would treat referenced standards in the same manner as the 1991 version.
The NRC staff presented their evaluation and analysis on Clause 5.16, Common Cause Failure (CCF), highlighting existing CCF policy and shared their recommended path forward consistent with this existing Commission policy.
The NRC staff presented its recommendation to IBR the entirety of IEEE Std 603-2018 with the single exception being that it would incorporate only the first normative sentence of Clause 5.16.
The NRC staff also discussed next steps after rulemaking which may include an evaluation to repurpose Regulatory Guide 1.153, Criteria for Safety Systems, to provide implementation guidance and the estimated schedule associated with the proposed rulemaking.
At the end of the meeting, the NRC staff invited comments or questions from external stakeholders.
The NRC staff was first asked questions related to the Advanced Act and its impact on evaluating the options for the path forward on the use of the standard. The NRC staff shared that there is an internal team in place actively assessing how to address the Advance Acts requirements. Follow up questions were received on future opportunities for public engagement.
The NRC staff relayed the public comment period and Advisory Committee on Reactor Safeguards interactions as additional opportunities for public engagement. Additional questions were asked regarding specific details on the delegated rulemaking process and Clause 5.16 which the NRC staff provided clarification on. The next question was related to the NRCs role and level of involvement in the development of the IEEE standard. The NRC staff communicated that the Nuclear Energy Innovation and Modernization Act explicitly directed the NRC to work with industry to develop standards to streamline the regulatory process and that the staff have been and continues to be actively involved in IEEE standards development.
Another question was raised about the IEEE 603 standard and its transition into a rule to enhance regulatory confidence. In response, the NRC staff reiterated that the rulemaking process is currently underway and confirmed their intention to update the incorporation by reference of the standard into the CFR, thereby ensuring regulatory confidence.
The meeting adjourned at 1:50 pm Eastern Standard Time.
No regulatory decisions were made during the meeting.
Please direct any inquiries to Calvin Cheung at calvin.cheung@nrc.gov or me at gilberto.blasrodriguez@nrc.gov.
Enclosures:
List of Attendees
Package: ML24289A210 Meeting Notice: ML24289A225 Meeting Summary: 24289A230 NRR-106 OFFICE NRR/DEX/EICB NRR/DEX/EICB NRR/DEX/EICB:BC NAME GBlasRodriguez CCheung FSacko DATE 10/11/24 10/16/24 10/17/24 OFFICE NRR/DEX/ELTB:BC NAME JPaige DATE 10/16/24 Enclosure LIST OF ATTENDEES SEPTEMBER 19, 2024, PUBLIC MEETING TO DISCUSS PROPOSED PATH FORWARD FOR INDUSTRYS USE OF INSTITUTE OF IEEE 603-2018, CRITERIA FOR SAFETY SYSTEMS Nuclear Regulatory Commission Aaron Kwok Calvin Cheung David Rahn Denise Edwards Dinesh Taneja Frederick OBrien Gilberto Blas Rodriguez Ilka Berrios Ismael Garcia Jason Paige Kenn Miller Ming Li Norbert Carte Samir Darbali Sergiu Basturescu Sheldon Clark Tania Martinez Navedo Tyler Hammock William Roggenbrodt External Stakeholders Aaron Green Alan, Campbell Alexander Joseph Bowman Alan Smith Andrew Michael Nack Bradley Tyers Congjian Wang Christopher Phillips David R Heinig Denver G. Atwood Geno Keller Larry Erin Marvin Morgan Michael L Elijah Neil Archambo Pareez E Golub Robert J Chenkovich Trevor Taylor