View source for RIS 2025-01, Pre-Application Communication and Scheduling for Licensing Actions Related to Digital Instrumentation and Controls

{{Adams
| number = ML25007A014
| issue date = 01/14/2025
| title = Pre-Application Communication and Scheduling for Licensing Actions Related to Digital Instrumentation and Controls
| author name = Felts R, Pelton J
| author affiliation = NRC/NRR/DORL, NRC/NRR/DRO
| addressee name = 
| addressee affiliation = 
| docket = 
| license number = 
| contact person = 
| case reference number = OMB 3150-0269
| document report number = RIS 2025-01
| document type = NRC Regulatory Issue Summary
| page count = 5
}}
{{#Wiki_filter:OMB Control No.:  3150-0269 Expiration Date: 12/31/2027 

ML25007A014 UNITED STATES 
NUCLEAR REGULATORY COMMISSION 
OFFICE OF NUCLEAR REACTOR REGULATION 
WASHINGTON, DC 20555-0001 

January 14, 2025 

NRC REGULATORY ISSUE SUMMARY 2025-01 PRE-APPLICATION COMMUNICATION AND SCHEDULING FOR LICENSING ACTIONS 
RELATED TO DIGITAL INSTRUMENTATION AND CONTROLS 

==ADDRESSEES==
All holders of Part 50 operating licenses or Part 52 combined licensees for nuclear power reactors, except those that have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel or combined license holders that have not received authorization to load nuclear fuel and begin operation.

==INTENT==
The primary purpose of this regulatory issue summary (RIS) is to help inform the U.S. Nuclear Regulatory Commissions (NRCs) budget and resource planning for the eventual review of applications related to analog-to-digital or digital-to-digital instrumentation and controls upgrades (e.g., license amendment requests). Specifically, the NRC seeks scheduling information for preapplication activities and submittal of applications (e.g., license amendment requests) related to digital instrumentation and controls (DI&C) from all addressees.

Additionally, this RIS seeks to promote early and frequent communication between the NRC 
and addressees for any DI&C upgrade application that a licensee intends to submit within the next 2 years. Frequent communication between the NRC and addressees promotes the submission of high-quality and complete applications.

Providing current scheduling information in response to this RIS is strictly voluntary. Although the agency requires neither specific action nor written response, this information will allow the NRC to better allocate its resources to support the activities leading up to and including the review of an analog-to-digital or digital-to-digital instrumentation and controls upgrade submittal.

The proper allocation of resources promotes the efficient completion of the NRCs review responsibilities.

==BACKGROUND INFORMATION==
The NRC formulates its budget by projecting 2 years beyond the current fiscal year in which it is operating. To help the NRC plan its resources appropriately, information from the licensees regarding their intentions to submit a licensing action will assist the NRC in planning for the necessary resources during the budget process and for any schedule needs in preparation for the review before the submittal of the licensing action. Moreover, early notification of future applicant intent will allow the NRC staff to engage in preapplication activities with the future applicant. These preapplication interactions permit the NRC staff to become familiar with the proposed design and approaches to be used by the potential applicant and enable it to identify and resolve potential policy issues before an application is submitted. Some reviews of DI&C upgrade submittals require specialized skills and significant resources to complete. The NRC will use the information obtained as a result of this RIS for scheduling and resource allocation.

==SUMMARY OF ISSUE==
The NRC encourages potential applicants to provide the agency with DI&C-related scheduling information for preapplication activities and licensing submittals. This information will allow the NRC to better allocate its resources, both financial and technical, to perform timely and effective reviews of DI&C upgrade applications.

==VOLUNTARY RESPONSE==
The NRC staff has developed several questions on the scheduling of DI&C activities. The NRC 
will use addressees responses to help determine resource allocation and prioritization for DI&C 
applications that will be submitted in upcoming fiscal years.

The NRC may share the application schedules with other Federal agencies to support its planning for the DI&C modernization effort. If a prospective applicant deems this information proprietary, it should include with the information a request to withhold the information from public disclosure in accordance with Title 10 of the Code of Federal Regulations 
(10 CFR) 2.390, Public inspections, exemptions, requests for withholding. RIS 2004-11, Supporting Information Associated with Requests for Withholding Proprietary Information, dated June 29, 2004 (Agencywide Documents Access and Management System Accession (ADAMS) Accession No. ML041180231), provides additional information about requests for withholding proprietary information from public disclosure. The NRC asks potential applicants to request withholding only for information that is currently treated as proprietary and to provide, where necessary, the proprietary information in designated attachments to their response to this RIS.

If an addressee chooses to provide a voluntary response, the NRC would like to obtain the information within 60 days of the date of this RIS. Respondents should answer the questions below to the best of their ability, providing as much detail as possible.

The NRC staff recognizes that the addressees ability to respond to these questions depends, in part, on the stage of submittal preparation. In some cases, addressees may not be able to respond to all questions at this time. With this in mind, the staff also encourages voluntary updates to initial responses to this RIS as significant scheduling changes occur.

The NRC seeks voluntary responses to the following questions: 

(1) 
Do you plan to submit a DI&C upgrade-related license application (e.g., license amendment)? If so, what is the estimated timeframe for such a submittal? 

(2) 
Do you plan to hold preapplication meetings with the NRC staff? If so, what is the estimated timeframe for the initial preapplication meeting? 

(3) 
Which systems do you plan to upgrade? 

(4) 
What platform(s) will be used for the upgrade? (5) 
Do you plan to use DI&C-Interim Staff Guidance (ISG)-06, Revision 2, Licensing Process, issued December 2018 (ADAMS Accession No. ML18269A259), to prepare your application? If yes, which of the four processes (e.g., Tier 1) described in the ISG 
do you believe the NRC will use in its evaluation of the application based on the criteria provided in Section C of ISG-06? 

==Addressees==
that choose to respond to these questions may mail the responses to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 
20555-0001. Additionally, addressees may submit responses electronically in accordance with 
10 CFR 50.4, Written communications; 10 CFR 70.5, Communications; 10 CFR 71.1, Communications and records; and 10 CFR 72.4, Communications, as appropriate for the submission. Detailed guidance can be found on the NRCs website at https://www.nrc.gov/site- help/e-submittals.html.

==BACKFITTING AND ISSUE FINALITY DISCUSSION==
This RIS requests the addressees to inform the NRC of scheduling information for any planned DI&C-related application submittals. The RIS requires no action or written response. Any action on the part of addressees to submit information in accordance with the request contained in this RIS is strictly voluntary. Therefore, this RIS does not constitute backfitting as defined in 
10 CFR 50.109(a)(1).  

===FEDERAL REGISTER NOTIFICATION===
The NRC published a notice of opportunity for public comment on this RIS in the Federal Register on April 17, 2024 (89 FR 27461). No comments were received.

===CONGRESSIONAL REVIEW ACT===
This RIS is not a rule as defined in the Congressional Review Act (5 U.S.C. 801-808) and, therefore, is not subject to the Act.

===PAPERWORK REDUCTION ACT STATEMENT===
This RIS contains voluntary information collections that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB) approved these information collections (approval number 3150-0269, expiration 12/31/2027). The burden to the public for these information collections is estimated to average 200 hours per response.

Send comments regarding this information collection to the FOIA, Library, and Information Collections Branch, Office of the Chief Information Officer, Mail Stop: T6-A10M, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, or by e-mail to Infocollects.Resource@nrc.gov, and to the OMB reviewer at: OMB Office of Information and Regulatory Affairs (3150-0269), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 
17th Street NW, Washington, DC 20503.

Public Protection Notification 

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid OMB control number.

==CONTACT==
Please direct any questions about this matter to the technical contacts listed below.

/RA/ 

/RA/ 

Russell Felts, Director 

Jaime Pelton, Deputy Division Director Division of Reactor Oversight 

Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 

Office of Nuclear Reactor Regulation 

Eric Benner, Director Division of Engineering and External Hazards Office of Nuclear Reactor Regulation 

Technical Contacts:  Carla Roque-Cruz, Senior Manager Michael Marshall, Senior Project Manager 

Manager 

NRR/DORL/LPMB 

NRR/DORL/LPL-1 

301-415-1455  

301-415-2871 

E-mail: Carla.Roque-Cruz@nrc.gov  E-mail: Michael.Marshall@nrc.gov 

Note: NRC generic communications may be found on the NRC public website, http://www.nrc.gov, under NRC Library/Document Collections. NRC DRAFT REGULATORY ISSUE SUMMARY 2025-01, PRE-APPLICATION 
COMMUNICATION AND SCHEDULING FOR LICENSING ACTIONS RELATED TO DIGITAL 
INSTRUMENTATION AND CONTROLS, DATE: January 14, 2025 

ADAMS Accession Number: ML25007A014 

*via e-mail 

EPID: L-2023-GEN-0008 OFFICE 
NRR/DORL/LLPB 
NRR/DORL/LPL-1 QTE* 
NRR/DORL/LPL-1/BC 
NAME 
CRoqueCruz MMarshall JDougherty HGonzalez DATE 
07/31/2023 
07/31/2023 
07/   /2023 
07/31/2023 OFFICE 
NRR/DEX/EEOB/BC(A) 
OGC (NLO) 
OCIO/GEMS/ICT 
NRR/DRO/IOEB 
NAME 
RStattel BVaisey DCullison PClark DATE 
07/27/2023 
08/03/2023 
07/31/2023 
08/24/2023 OFFICE 
NRR/DRO/IOEB/BC 
NRR/DEX/D 
NRR/DORL/D 
NRR/DRO/D 
NAME 
LRegner EBenner BPham RFelts DATE 
09/06/2023 
01/13/2025 
01/13/2025 
01/14/25 OFFICIAL RECORD COPY
}}

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