View source for 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

{{Adams
| number = ML23233A068
| issue date = 08/22/2023
| title = 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
| author name = Marshall M
| author affiliation = NRC/NRR/DORL/LPL1
| addressee name = 
| addressee affiliation = 
| docket = 
| license number = 
| contact person = 
| case reference number = SRM-SECY-22-0076, EPID L-2023-NFG-0004
| document type = Meeting Summary
| page count = 1
| project = EPID:L-2023-NFG-0004
| stage = Meeting
}}

=Text=
{{#Wiki_filter: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}}