ML25066A092
| ML25066A092 | |
| Person / Time | |
|---|---|
| Issue date: | 03/18/2025 |
| From: | Hipolito Gonzalez NRC/NRR/DORL/LPL1 |
| To: | Pelton J Division of Operating Reactor Licensing |
| Kuntz R, NRR/DORL/LPL3 | |
| References | |
| EPID G-2024-AGN-0023 | |
| Download: ML25066A092 (1) | |
Text
March 18, 2025 MEMORANDUM TO:
Jamie Pelton, Acting Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Hipólito González, Chief
/RA/
Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF FEBRUARY 19, 2025, INFORMATION PUBLIC MEETING ABOUT NRCS IMPLEMENTATION OF SECTION 507 OF THE ADVANCE ACT OF 2024 RELATED TO DIGITAL INSTRUMENTATION AND CONTROLS (EPID G-2024-AGN-0023)
On February 19, 2025, the U.S. Nuclear Regulatory Commission (NRC or the Commission) staff from the Office of Nuclear Reactor Regulation (NRR) held a public meeting to discuss Nuclear Energy Institute (NEI) comments related to Section 507 of the Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024 regarding nuclear licensing oversight and inspection programs.
Section 507 of the ADVANCE Act (Section 507) specifically 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 This public meeting focused on NEIs recommendations provided by letter dated October 28, 2024 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML24302A311). Specifically, the meeting addressed NEIs recommendations related to digital instrumentation and controls (DI&C) provided on pages 8 and 9 of Attachment 2 to the October 28, 2024, NEI letter.
The meeting notice and agenda dated January 28, 2025, are located at ML25028A146. The NRC staffs presentation is available at ML25045A054; NEIs presentation is available at ML25052A111. A list of meeting attendees is provided in the enclosure.
CONTACT: Rob Kuntz, NRR/DORL 301-415-3733
The meeting began with introductions then the NRC staff provided a description of ADVANCE Act activities. The NRC staff noted that the public meeting for further information on the NRC staffs activities in response to the ADVANCE Act will be held on March 4, 2025. The NRC staff then presented a background on the ADVANCED Act Section 507 and began discussing responses to NEIs recommendations Recommendation 1 from NEI was to eliminate Title 10 of the Code of Federal Regulations (10 CFR) Part 50.55a(h) (10 CFR 50.55a(h)). The provisions in 10 CFR 50.55a(h) incorporate by reference Institute of Electrical and Electronics Engineers (IEEE) stands IEEE 279-1968, IEEE 279-1971, and IEEE 603-1991. The NEI comment stated that the general design criteria (GDC) in Appendix A to 10 CFR Part 50 could be relied upon to meet the requirements for design. The NRC staff stated that a near-term effort to revise 10 CFR 50.55a(h) through the rulemaking process to incorporate IEEE 603-618 is ongoing. The NRC staff further stated that eliminating 10 CFR 50.55a(h) would be considered but cautions that gaps between the requirements in the GDC and system design requirements would exist for DI&C systems if 10 CFR 50.55a(h) were to be eliminated that could result in other rulemaking. The NRC staff further noted that proposed 10 CFR Part 53, Risk-Informed, Technology-Inclusive Regulatory Framework for Commercial Nuclear Plants, rulemaking does not require any consensus codes and standards.
Subsequent to the NRC staff discussion on NEI Recommendation 1, NEI provided its opening comments. NEI noted that improved regulatory infrastructure is being pursued through the integrated action plan as well as other activities. NEI stated that further opportunities existed such as removing unnecessary duplicate regulatory requirements as well as the use of modern standards and more efficient guidance.
NEI supplemented its recommendations from the letter dated October 28, 2024, on Recommendation 1 to state that eliminating 10 CFR 50.55a(h) and relying on the GDC would eliminate duplicate regulatory requirements and that including by-reference guidance inhibits the use of modern standards. NEI presented a summary of instances where requirements are duplicative in the existing regulations. NEI then presented guidance that could potentially be used by licensees that are not included by reference in the rule and therefore would require an exemption to use and noted that future developed guidance would face the same constraints on adoption. NEI stated that moving the accepted guidance from the regulations to regulatory guides would be consistent with the purpose of regulatory guides and improve the overall efficiency.
The NRC staff next addressed NEI recommendation 2 which recommends Design Review Guide (DRG): Instrumentation and Control for Non-Light Water Reviews in lieu of the guidance in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, (SRP) SRP Chapter 7 for DI&C licensing reviews. The NRC staff commented that it is focusing on lessons learned from Interim Staff Guidance (ISG)
DI&C-ISG-06 Digital Instrumentation and Controls Licensing Process, Revision 2 (ML18269A259) for light water reactors and the DRG for non-light water reactor licensing. The NRC staff also noted that SRP Chapter 7 modernization will occur after the NRC updates its internal guidance for SRP development.
NEI stated in response to recommendation 2 that the review guidance in SRP Chapter 7 could be more efficient which would improve predictability, efficiency, and timeliness of reviews. NEI pointed out that SRP Chapter 7 contains many different Chapters, Appendices, and Branch
Technical Positions and that guidance is repeated in these various components. NEI presented a comparison of the DRG to SRP Chapter 7 and recommended that consolidation of SRP Chapter 7 would improve efficiency.
NEI recommendation 3 recommended creating clear concise review guidance in a single document for human factors engineering (HFE) in lieu of the current guidance which is contained in several NUREGs. The NRC staff responded that combining the guidance into a single document could cause additional confusion and could make updates more challenging.
The NRC staff noted that a table was added to SRP Chapter 18 to improve clarity and that a revision to Chapter 18 is planned. A public meeting to address specific industry concerns is being considered as part of the update. The NRC staff recommended that preapplication meetings are useful for the NRC staff to provide clarity on which guidance document is appropriate for the particular licensing activity being considered.
NEI stated for recommendation 3 that significant revision and consolidation of HFE guidance would improve the overall efficiency with no reduction of reasonable assurance of adequate protection. The NRC staff stated that it would support a future public meeting in which NEI can provide specific feedback about how such an update would be beneficial.
NEI recommendation 4 recommended revising NRC guidance for DI&C using a systems engineering approach in lieu of the prescriptive regulatory guidance associated with each phase of the lifecycle process currently incorporated in the guidance documents. The NRC staff stated it is reviewing guidance using system engineering approaches and would consider revising existing guidance. NEI presented a list of NRC guidance documents that reference superseded or inactive standards and noted that the existing Regulatory Guide structures inhibits the use of modern standards. NEI notes that current standards recognize the importance of systems engineering approaches.
NEI recommendation 5 stated that the Alternate Review Process (ARP) in DI&C-ISG-06 provides streamlined digital specific review criteria, but license amendments often impact other review areas such as HFE, technical specifications, and equipment qualification that do not follow the ARP. NEI suggests that all the potential review areas be addressed in the ARP. NEI also recommended that the guidance should be moved out of an interim staff guidance into a long term, durable, regulatory document. NEI encouraged the NRC staff to incorporate lessons-learned and to incorporate the guidance in the ISG into a durable guidance document.
The NRC staff stated that a collection of lessons-learned are being gathered to be incorporated into the next revision of DI&C-ISG-06 including a public workshop scheduled for March 13 and 14, 2025. The NRC staff plans to transition the guidance in the ISG to a durable guidance upon the next revision.
A member of the public questioned the NRC staff on expanding the Codes and Standards in 10 CFR 50.55a(h) to include the examples provided in NEIs remarks. The NRC staff stated that rulemaking to include additional guidance would be considered as appropriate and noted that expanding the guidance incorporated by reference would not address NEIs underlying recommendation.
At the end of the meeting, the NRC staff and NEI gave closing remarks. NEI requested timelines and public meetings to solicit further input for each of the planned activities discussed in the meeting.
The enclosure provides the attendance list for this meeting.
Enclosure:
List of Attendees
ML25066A092 NRR-106 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NAME RKuntz KEntz HGonzález DATE 3/7/2025 3/10/2025 3/18/2025
Enclosure List of Attendees U.S. Nuclear Regulatory Commission Public Information Meeting Section 507 of the ADVANCE Act Related to Digital Instrumentation and Controls February 19, 2025 Name Affiliation Samuel Akinlolu Sargent and Lundy Shirelle Allen General Electric (GE)
Jim Anderson Nuclear Regulatory Commission (NRC)
Christina Antonescu NRC Neil Archambo Archamboec.com Steven Arndt Marissa Bailey NRC Thomas Basso Nuclear Energy Institute (NEI)
Eric Benner NRC Earl Berry Southern Nuclear Sam Bina NRC Maddie Blalock EPW.senate.gov Gilberto Blas NRC Jay D. Boardman Westinghouse Alexander Joseph Bowman Tennessee Valley Authority Andrew Bowman Westinghouse Lindsay Braithwaite GE Jesse S. Brown Constellation Thomas Buffone NRC Jeffrey Burns Curtiss Wright Alan Campbell NEI Norbert Carte NRC Helen Chang NRC Robert Chenkovich Dominion Energy Yi-Lun Chu NRC Cristina Corrales Electric Power Research Institute (EPRI)
Amy DAgostino NRC Samir Darbali NRC Mari de Jesus NRC Mike Dunevant Denise Edwards NRC Theo Edwards NRC Jason English NRC Larry Erin Framatome Ashley Ferguson INPO Name Affiliation Jasmine Ferguson Nicole Fields NRC Steven Fox Duke Energy Allen Fulmer Dominion Jason Gasque Enercon Matt Gibson EPRI Hipolito Gonzalez NRC Brian Green NRC Pablo J. Guardado Constellation Tyler Hammock NRC David Harrell MPR David R. Heinig Sargent and Lundy Raymond Herb Southern Nuclear David Hooten Sargent and Lundy Ronald Jarrett Enercon Geno Keller Talen Energy Daniel King NRC Mike King NRR Audrey Klett NRC Patrick Koch NRC Rob Kuntz NRC Shao Lai NRC Landau Ming Li NRC Michael Marshall NRC Aaron McCraw NRC Philip McKenna NRC Jaison Monachan NRC Jill Monahan Pennsylvania State University Marvin Morgan Dominion Energy Marty Murphy Curtiss Wright Anrew Nack River Mist Engineering Jared Nadel NRC Caty Nolan NRC Warren Odess-Gillett Westinghouse Trace Orf MRPW Richard Paese Sargent and Lundy Jason Paige NRR Andy Patz NRC Christopher Prescott NRC Steven Pope David Rahn NRC Deann Raleigh Curtiss Wright Name Affiliation Annie Ramirez NRC Jeremiah Rey NRC Tim Riti NEI William Roggenbrodt NRC Fanta Sacko NRC Mark Samselski Constellation Gabrielle Schreier GE Undine Shoop NRC Alan Smith MRPW Dinesh Taneja NRC Spenser Toohill Congjian Wang Idaho National Laboratory Isaac Wang NRC Jack Zhao NRC