ML25052A111
| ML25052A111 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/19/2025 |
| From: | Nuclear Energy Institute |
| To: | NRC/NRR/DORL/LPL3 |
| References | |
| Download: ML25052A111 (22) | |
Text
©2025 Nuclear Energy Institute Digital I&C Recommendations ADVANCE Act February 19, 2025
©2025 Nuclear Energy Institute 2 Recognize that NRC staff and industry have improved regulatory infrastructure through the Integrated Action Plan (IAP) and other recent activities Improved clarity implementing digital modifications under 10 CFR 50.59 Improved ability to use qualitative assessment of Common Cause Failure Improved ability to use certified Commercial-Off-The-Shelf components Improved license amendment request process for digital modifications Industry Recommendations
©2025 Nuclear Energy Institute 3 Further opportunities to meet current and future industry needs:
Remove unnecessary duplication of regulatory requirements Allow use of modern standards that reflect state of practice More efficient guidance to improve efficiency, predictability, and timeliness Industry recommendations:
Meet the intent of ADVANCE Act Sections 505 and 507 Do not result in a reduction of reasonable assurance of adequate protection Improves efficiency for licensing and adoption of future standards Industry Recommendations
©2025 Nuclear Energy Institute 4 Recommendation 1: Eliminate 10 CFR 50.55a(h) and rely upon 10 CFR 50, Appendix A, General Design Criteria (GDC)
Unnecessary duplication of regulatory requirements Inhibits the use of modern standards Recommendation 1
©2025 Nuclear Energy Institute 5 Unnecessary duplication of regulatory requirements NUREG-0800 Chapter 7, Appendix 7.1-A provides staff acceptance criteria and guidelines for I&C systems important to safety.
Section 2 addresses GDC
Directs staff to use IBRed standard as acceptance criteria for demonstrating compliance with GDC Requirements in IBRed standards are addressed by GDC Recommendation 1 GDC IEEE 279-1971 Section IEEE 603 Section(s) 1 4.3 5.3 2
3 4
4 4.4 5.4 13 4.9, 4.13, 4.17, 4.19 5.8, 6.2, 6.5, 7.2 20 3, 4.1, 4.5, 4.15 4, 5, 5.5, 6.1, 6.8, 7.1 21 3, 4.1-3, 4.5-19, 4.21, 4.22 4, 5.1-3, 5.5-15, 6.2-8, 7.2-5, 8 22 3, 4.2-7, 4.15, 4.17 4, 5.1, 5.3-6, 6.2, 6.3, 6.8, 7.2, 8 23 4.5 5.5 24 4.2, 4.5-7 5.1, 5.6, 5.12, 6.3, 6.6, 8 25 3
4
©2025 Nuclear Energy Institute 6 Recommendation 1 10 CFR 50.34(f)(2)(v) 10 CFR 50.55a(h) IBRed Standards Provide for automatic indication of the bypassed and operable status of safety systems. (I.D.3)
IEEE 279-1971 4.13 Indication of Bypasses. If the protective action of some part of the system has been bypassed or deliberately rendered inoperative for any purpose, this fact shall be continuously indicated in the control room.
IEEE 603-1991 5.8.3 Indication of Bypasses. If the protective actions of some part of a safety system have been bypassed or deliberately rendered inoperative for any purpose other than an operating bypass, continued indication of this fact for each affected safety group shall be provided in the control room.
5.8.3.1 This display instrumentation need not be part of the safety systems.
5.8.3.2 This indication shall be automatically actuated if the bypass or inoperative condition (a) is expected to occur more frequently than once a year, and (b) is expected to occur when the affected system is required to be operable.
5.8.3.3 The capability shall exist in the control room to manually activate this display indication.
©2025 Nuclear Energy Institute 7 Current structure inhibits the use of modern standards NEI recognizes and appreciated that NRC is pursuing rulemaking to incorporate IEEE 603-2018 consistent with industrys recommendation in November 2023 Even if IEEE 603-2018 is IBRed, other standards (including future revisions of IBRed standards) may be used by applicants:
IEEE updates to IEEE 603 (targeting 2028 issuance)
IEC-61513 considered by Advance Reactor vendors Recommendation 1
©2025 Nuclear Energy Institute 8 Elimination of 10 CFR 50.55a(h) would improve the overall efficiency with no reduction of reasonable assurance of adequate protection Transition updates to standards to the Regulatory Guide process in lieu of rulemaking Aligned with purpose of Regulatory Guides (i.e., demonstrate how to meet requirements)
Recommendation 1
©2025 Nuclear Energy Institute 9 Recommendation 2: Consolidate staff review guidance NUREG-0800 Chapter 7 More efficient guidance to improve efficiency, predictability, and timeliness Current NUREG -0800 Chapter 7 composition:
10 Chapters 7 Appendices 1 Table 17 Branch Technical Positions Recommendation 2
©2025 Nuclear Energy Institute 10 More efficient guidance to improve licensing efficiency, predictability, and timeliness NEI understands and appreciates intended audience for NUREG documents are NRC staff Industry typically uses NUREG documents to ensure appropriate information is provided for staff review References between SRP sections create complex relationships between Sections, BTPs and Appendices inhibiting understanding.
Significant sections of redundant guidance (e.g., SRP Chapters 7.2 and 7.3 significantly overlap)
Recommendation 2
©2025 Nuclear Energy Institute 11 Comparison to Digital I&C Design Review Guide (DRG)
DRG provides clear, concise review guidance addressing key aspects of staff review.
Includes criteria from IEEE 603 Limits external references Reduces repetitive review guidance Recommendation 2
©2025 Nuclear Energy Institute 12 Significant revision and consolidation of NUREG-0800 Chapter 7 would improve the overall efficiency with no reduction of reasonable assurance of adequate protection Improvements to Chapter 7 will provide more clarity on licensing review criteria resulting in more efficient licensing processes Recommendation 2
©2025 Nuclear Energy Institute 13 Recommendation 3: Consolidate staff review guidance related to Human Factors Engineering (HFE)
More efficient guidance to improve efficiency, predictability, and timeliness Current HFE guidance documents:
NUREG-0800 Chapter 18 and Chapter 18 Appendix A NUREG-0700 - HSI NUREG-0711 - HFE Program NUREG-1220 - Training NUREG-1764 - Human Actions NUREG-1852 - Operator Actions Related to Fire Recommendation 3
©2025 Nuclear Energy Institute 14 More efficient guidance to improve efficiency, predictability, and timeliness SRP Chapter 18 Attachment A, SRP Chapter 18 Appendix A, NUREG-1764 and NUREG-1852 each address human/operator action.
Recommend one set of general guidance for human/operator actions with considerations for specific actions highlighted (e.g., fire response)
Chapter 18 description of Graded Approach to Review provides discretionary criteria
Potential to tie to risk-informed approaches
Unclear how the graded approach is performed Recommendation 3
©2025 Nuclear Energy Institute 15 Significant revision and consolidation of HFE guidance would improve the overall efficiency with no reduction of reasonable assurance of adequate protection Improvements to HFE guidance will provide more clarity on licensing review criteria resulting in more efficient licensing processes Recommendation 3
©2025 Nuclear Energy Institute 16 Recommendation 4: Revise Regulatory Guides associated with digital technology design and development activities.
Inhibits the use of modern standards More efficient guidance to improve efficiency, predictability, and timeliness Recommendation 4
©2025 Nuclear Energy Institute 17 Current Regulatory Guide structure inhibits the use of modern standards Recommendation 4 Regulatory Guide Endorsed Standard Status 1.152 IEEE 7-4.3.2-2016 Active 1.168 IEEE 1012-2004 IEEE 1028-2008 Superseded Inactive - Reserved 1.169 IEEE 828-2005 Inactive - Reserved 1.170 IEEE 829-2008 Superseded 1.171 ANSI/IEEE 1008-1987 Superseded 1.172 IEEE 830-1998 Superseded 1.173 IEEE 1074-2006 Superseded
©2025 Nuclear Energy Institute 18 Inhibits the use of modern standards Current standards recognize the importance of systems engineering approaches
Example - IEEE 1012-2016 acknowledges the integrated nature of modern systems and provides comprehensive verification and validation requirements Recommendation 4 IEEE 1012-2004 IEEE 1012-2016 IEEE Standard for Software Verification and Validation IEEE Standard for System, Software, and Hardware Verification and Validation
©2025 Nuclear Energy Institute 19 More efficient guidance to improve efficiency, predictability, and timeliness Periodic Review concluded:
A feasibility study to explore consolidating RGs 1.169 through 1.173 found that the idea may have merit. For example, it could harmonize positions on Institute of Electrical and Electronics Engineers Standards (IEEE Stds.)
discussed in all six regulatory guides (RGs 1.168 through 1.173), reduce duplication of information, and generally aid the public by reducing the number of regulatory guides in this technical area. [emphasis added]
Recommendation 4
©2025 Nuclear Energy Institute 20 Revising these Regulatory Guides provides:
Ability to review/endorse modern, systems engineering approaches to system development (including potential use of international standards)
Easier downstream maintenance of Regulatory Guides (fewer RGs to maintain)
Recommendation 4
©2025 Nuclear Energy Institute 21 Recommendation 5: Revise DI&C-ISG-06 to incorporate lessons learned from initial projects More efficient guidance to improve efficiency, predictability, and timeliness DI&C-ISG-06 Revision 3 Alternate Review Process is a significant step forward in Digital I&C licensing Industry appreciated NRC staff coordinating upcoming workshop (March 13-14) to discuss lessons learned Industry encourages the output of the workshop to include a future revision to DI&C-ISG-06 content and incorporation into durable (i.e.,
non-interim) guidance Recommendation 5
©2025 Nuclear Energy Institute 22 These recommendations support NRCs mission as an efficient and reliable agency Industry appreciates NRCs consideration of the ADVANCE recommendations and planned actions Conclusion Industry requests:
- Timelines for each planned action to be communicated
- Additional public meetings to solicit further input/discussion on each planned action