ML25045A054
| ML25045A054 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/2025 |
| From: | Robert Kuntz, Jason Paige, Dinesh Taneja NRC/NRR/DORL/LPL3 |
| To: | |
| References | |
| Download: ML25045A054 (1) | |
Text
ADVANCE Act Sec. 507 Acceptance of Digital Technology Jaison Monachan, NRR Dinesh Taneja, NRR Jason Paige, NRR February 19, 2025
Purpose and Agenda Purpose
- To discuss NRCs approach for addressing NEIs recommendations for ADVANCE Act, Section 507(d)(4) related to timely acceptance of digital technologies
- NEIs recommendations are in NEI letter dated October 28, 2024 (ADAMS Accession No. ML24302A311)
Agenda
- Overview of ADVANCE Act Section 507 & 505 provisions
- Relevance of NEI recommendations on Section 507 to Section 505 provisions
- NRC staff insights & ongoing actions related to NEI recommendations
- Key messages & path forward 2
Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024 (ADVANCE Act) 3
- ADVANCE Act was signed into law in July 2024
- The Act builds on prior initiatives to modernize and streamline the regulatory environment for advanced nuclear technologies, including 1) facilitate American nuclear energy leadership 2) support development and deployment of new nuclear energy technologies 3) preserve existing nuclear energy 4) strengthen Americas nuclear energy fuel cycle and supply chain infrastructure 5) improve the NRCs resources and efficiency
- The Act increases emphasis on efficiency
ADVANCE Act: Section 505 Provisions ADVANCE Act, Section 505 amended the ERA, Section 203 to state:
(c) Licensing process.In carrying out the principal licensing and regulation functions under subsection (b)(1), the Director of Nuclear Reactor Regulation shall (1) establish techniques and guidance for evaluating applications for licenses for nuclear reactors to support efficient, timely, and predictable reviews of applications for those licenses to enable the safe and secure use of nuclear reactors; (2) maintain the techniques and guidance established under paragraph (1) by periodically assessing and, if necessary, modifying those techniques and guidance; and (3) obtain approval from the Commission if establishment or modification of the techniques and guidance under paragraph (1) or (2) involves policy formulation.
4
ADVANCE Act: Section 507 Provisions ADVANCE Act, Section 507, Improving Oversight and Inspection Programs, in part, states:
(d)(4) assess the ability of the Commission, consistent with the mission of the Commission, to enable licensee innovations that may advance nuclear reactor operational efficiency and safety, including the criteria of the Commission for timely acceptance of licensee adoption of advanced technologies, including digital technologies; 5
NEI Suggestions NEIs Section 507 recommendations related to digital technologies:
- 1. Elimination of 10CFR50.55(a)(h)
- 2. NUREG-0800, Chapter 7 Modernization
- 3. Consolidation of HFE review guidance
- 4. Systems engineering approach for digital technologies
- 5. Update DI&C-ISG-06 & Convert to Durable Document NRC is assessing NEIs Section 507 recommendations related to digital technologies under Section 505 provisions
NEI Recommendation 1:
Elimination of 10 CFR 50.55a(h) 10 CFR 50.55a(h) incorporates by reference IEEE 279-1968, IEEE 279-1971, and IEEE 603-1991 providing prescriptive design criteria for protection and safety systems. 10 CFR 50, Appendix A provides General Design Criteria (GDCs) related to I&C, protection systems, and reactivity control systems that address similar design criteria. To enhance the flexibility of the regulations, we believe 10 CFR 50.55a(h) should be eliminated and the GDCs could be relied upon.
NRC staff insights & ongoing actions:
- To address near-term industry needs based on stakeholders feedback, the staff is working on rulemaking to incorporate by reference IEEE Std 603-2018 in 10 CFR 50.55a(h) that is scheduled to be issued in June 2025 for public comments.
- For longer-term, the staff is willing to consider elimination of 50.55a(h) rule; however, the gaps between electrical and I&C systems regulatory requirements contained in IEEE Std 279/603 and the GDC regulatory requirements, which are written at the plant SSC level, would need to be addressed by future rulemaking activities.
- Proposed Part 53 rule, which is risk-informed and performance-based, does not incorporate by reference any consensus codes and standards, including IEEE Std 603.
NEI Recommendation 2:
SRP Chapter 7 Modernization NUREG-0800, Chapter 7 provides 537 pages of staff review guidance for I&C systems, structures, and components for LWRs. Advanced Reactors use the Design Review Guide (DRG): Instrumentation and Control for Non-Light Water (Non-LWR) Reviews, which provides 45 pages of staff review guidance. The DRG should be used in developing streamlined guidance for operating plants.
NRC staff insights & ongoing actions:
- The NRC is focusing on lessons learned from using DI&C-ISG-06 for operating reactor LARs and the DRG for non-LWR licensing. Based on these lessons learned, proposed changes to the NUREG-0800 Standard Review Plan (SRP), Chapter 7 are being considered.
- DI&C-ISG-06 lessons learned workshop is scheduled on March 13-14, 2025.
- SRP Chapter 7 modernization will occur after the staff updates its internal guidance for SRP development.
NEI Recommendation 3:
Consolidation of HFE review guidance NUREG-0800, Chapter 18 provides staff review guidance for Human Factors Engineering (HFE) for LWRs. Chapter 18 provides directions for the staff to also use acceptance criteria in NUREG-0700, NUREG-0711, NUREG-1220, NUREG-1764, and NUREG-1852. The staff should consider incorporating clear, concise review guidance in a single document to facilitate understanding.
NRC staff insights & ongoing actions:
- The referenced NUREGs have specific purposes. Combining the documents is likely to cause additional confusion and make updates more challenging, but staff agree that additional clarity is needed.
- Table 1 was added to Chapter 18 Rev 3 (2016) to help improve clarity, but challenges persist.
- Staff are planning an update to Chapter 18 which includes improving the clarity about how to use the acceptance criteria.
- Staff can plan future public engagements for more specific feedback if desired.
- In the meantime, pre-application meetings can be used to identify the appropriate acceptance criteria.
NEI Recommendation 4:
Systems engineering approach for digital technologies Regulatory Guides 1.152, 1.168, 1.169, 1.170, 1.171, 1.172, and 1.173 provide guidance to licensees related to digital technology design and development activities. These Regulatory Guides focus on distinct elements of the lifecycle. The NRC should consider a systems engineering approach towards digital technology in lieu of prescriptive regulatory guidance associated with each phase of the lifecycle process.
NRC staff insights & ongoing actions:
- The NRC is reviewing NEI 20-07 that uses a systems engineering approach.
- The NRC is researching system engineering methods including STPA (Systems-Theoretic Process Analysis) for advanced non-LWRs, new LWRs, and operating reactors.
NEI Recommendation 5:
Update DI&C-ISG-06 & Convert to Durable Document DI&C-ISG-06 provides the review process for operating LWRs. Revision 3 introduced an Alternate Review Process (ARP) that streamlines digital specific review criteria. Digital LARs often impact other review areas such as HFE, Technical Specifications, Equipment Qualification, etc., that do not follow the ARP. These areas should be included in the scope of the ARP to allow for a single streamlined LAR review process.
Additionally, this guidance should be moved out of Interim Staff Guidance and into a long-term, durable regulatory document.
NRC staff insights & ongoing actions:
- The NRC is gathering lessons-learned (including HFE issues) to incorporate into the next revision of ISG-06. The staff is planning to host a workshop to discuss the lessons-learned in the 1Q2025 (CY). Upon revision, this ISG will transition to a durable guidance (e.g., SRP).
Whats Next?
- Coordinate work on ADVANCE Act, Sections 505 and 507 for addressing digital technologies regulatory infrastructure
- Evaluate NEI 20-07 guidance document
- Modernize SRP Chapter 7 to include ADVANCE Act provisions with due considerations to NEI recommendations
- Update DSRS Chapter 7 and DRG staff review guidance documents to address ADVANCE Act provisions and lessons learned
ACRONYMS ADAMS Agencywide Documents Access and Management System ADVANCE Act Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024 DI&C-ISG-06 Digital Instrumentation & Controls Licensing Process Interim Staff Guidance DSRS Design Specific Review Standard DRG Design Review Guide: I&C for Non-LWR Reviews ERA Energy Reorganization Act GDC General Design Criteria HFE Human Factors Engineering I&C Instrumentation and Controls LWR Light Water Reactor NEI Nuclear Energy Institute STPA Systems-Theoretic Process Analysis
Be Engaged!
27 Stay informed of progress and follow NRCs ADVANCE Act implementation For upcoming and past public meeting information on ADVANCE Act Contact us with ADVANCE Act questions, comments and ideas