SECY-22-0076, SRM-SECY-22-0076 - Summary of July 11, 2023, Information Public Meeting on Proposed Plans to Develop Implementation Guidance Concerning Potential Common Cause Failures in Digital Instrumentation and Controls Systems
| ML23233A068 | |
| Person / Time | |
|---|---|
| Issue date: | 08/22/2023 |
| From: | Marshall M NRC/NRR/DORL/LPL1 |
| To: | |
| References | |
| SRM-SECY-22-0076, EPID L-2023-NFG-0004 | |
| Download: ML23233A068 (1) | |
Text
August 22, 2023 LICENSEE: n/a FACILITY: n/a
SUBJECT:
SRM-SECY-22-0076 -
SUMMARY
OF JULY 11, 2023, INFORMATION PUBLIC MEETING ON PROPOSED PLANS TO DEVELOP IMPLEMENTATION GUIDANCE CONCERNING POTENTIAL COMMON CAUSE FAILURES IN DIGITAL INSTRUMENTATION AND CONTROLS SYSTEMS (EPID L-2023-NFG-0004)
On July 11, 2023, an information meeting with a question-and-answer session was held between the U.S. Nuclear Regulatory Commission (NRC) and external stakeholders at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss the NRC staffs initial plan for developing the implementation guidance mentioned in SRM-SECY-22-0076, Expansion of Current Policy on Potential Common-Cause Failures in Digital Instrumentation and Control Systems. The meeting notice and agenda, dated June 30, 2023, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML23181A068. A list of attendees is provided as Enclosure 1.
The NRC staff provided an overview and a point-by-point discussion on the content of SRM-SECY-22-0076. The Commission direction included developing or updating implementing guidance to be consistent with the revised policy discussed in the staff requirement memorandum (SRM), ensuring the policy is applicable to all licensing pathways, and issuing the implementing guidance within 12 months of the date of the SRM. To meet the Commissions direction to issue final implementing guidance, the NRC staff mentioned that we are considering updating Branch Technical Position (BTP) 7-19 in the Standard Review Plan for light water reactors and considering updating design review guidance for nonlight water reactors. The NRC staff noted that BTP 7-19 contains criteria for (1) precluding common cause failure and (2) acceptance for analyses. In addition, the NRC staff talked about other options, such as updating or creating a new regulatory guide or possible endorsement of guidance developed by industry.
The NRC staff mentioned that the only options that would be considered viable are options that can be completed within 12 months. At the time of the meeting, no decision had been made which guidance documents, if any, would be updated.
Members of the public were in attendance. During the question-and-answer portion of the meeting, the following comments were provided to the NRC staff:
Guidance should be useful out of the gate.
Urge caution with use of the term safety functions because it does not appear to have a regulatory definition.
Provide more detail with regards to the statement in Point 4 that applicant may propose a different approach.
In addition to the comments, the public had the following questions:
What circumstances put possible endorsement of NEI 20-07 outside of the 12-month timeframe?
Does the NRC plan to update Regulatory Guide 1.233?
What is meant by independence of licensing pathways?
What are the performance objectives for critical safety functions?
Would the NRC staff be open to realistic time response to accidents and consideration of manual actions?
Would the NRC staff be open to other changes to BTP 7-19?
What does the NRC staff mean by keeping the instrumentation and control guidance separate from probabilistic risk assessment guidance?
Proposed guidance seems to be high level; do we know what the Commission meant by final implementation guidance?
Public Meeting Feedback forms were not received. No regulatory decisions were made during the meeting. Please direct any inquiries to me at 301-415-2871, or michael.marshall@nrc.gov.
/RA/
Michael L. Marshall, Jr, Senior Project Manager Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosure:
List of Attendees
LIST OF ATTENDEES JULY 11, 2023, INFORMATION PUBLIC MEETING WITH EXTERNAL STAKEHOLDERS ON PROPOSED PLANS TO DEVELOP IMPLEMENTATION GUIDANCE CONCERNING POTENTIAL COMMON CAUSE FAILURES IN DIGITAL INSTRUMENTATION AND CONTROLS SYSTEMS Name Organization Samir Darbali U.S. Nuclear Regulatory Commission (NRC)
Michael Marshall NRC Jim Shea NRC Jana Bergman Curtiss Wright Christina Antonescu NRC Steven Alferink NRC Joseph Ashcraft NRC Bill Hannaman -----
Sergiu Basturescu NRC Robert Chenkovich Dominion Energy Ted Quinn -----
Steve Wyman NRC Raymond Herb Southern Nuclear Company Brian McMahon Framatome Alan Campbell Nuclear Energy Institute Arthur Holtz Jensen Hughes Jason Paige NRC Thomas Basso Nuclear Energy Institute Brian Mount Dominion Energy Alan Smith -----
Wes Brinsfield Jensen Hughes Marcia Carpentier NRC Erin Wisler -----
Collin Parry -----
Mike Dunevant TerraPower Neil Archambo -----
Raymond Schneider Westinghouse Sunil Weerakkody NRC De Wu NRC Francis Mascitelli Constellation Nuclear Mohammad Alavi -----
Charley Peabody NRC Jerry Mauck -----
Ming Li NRC David Rahn NRC Richard Rolland Westinghouse Doug Eskins NRC Enclosure
Name Organization Ho Thu Dominion Energy Warren Odess-Gillett -----
Suzanne Loyd Constellation Nuclear Caroline Larsen NRC Wesley Steh -----
Dinesh Taneja NRC Sushil Birla NRC Calvin Cheung NRC Jack Zhao NRC Christopher Cook NRC Stew Yuen Nuclear Energy Institute Dolan, Bradley Wicker Tennessee Valley Authority Richard Supler ENERCON Ron Jarrett Paragon Golub, Pareez Sargent & Lundy Richard Stattel NRC Derek Halverson NRC Anya Kim NRC Gilberto Blas Rodriguez NRC Robert Williams NRC Sheldon Clark NRC Han Bao Idaho National Laboratory John Lane NRC Johnston, Jeanne Southern Nuclear Company Andrea Kock NRC Wendell Morton NRC Baofu Lu -----
Thomas Jaeger Dominion Energy Stephen Middlekauff -----
Mary Miller Dominion Energy Phil Couture -----
Brian Haynes Framatome Jacob Davis NRC Norbert Carte NRC Aaron Green Framatome Svetlana Lawrence Idaho National Laboratory William Catullo Paragon Mauricio Gutierrez NRC Step Wesley -----
Ian Jung NRC Eric Benner NRC Khoi Nguyen NRC Nick Smith NRC
Meeting Notice, ML23181A068 Meeting Summary, ML23233A068 Handouts, ML23191A065 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DEX/ELTB/BC NRR/DORL/LPL1/PM NAME MMarshall KZeleznock JPaige (LRamadan for) MMarshall DATE 08/21/2023 08/21/2023 08/22/2023 08/22/2023