ML22341A012

December 12, 2022 Nuclear Regulatory Commission and Boiling Water Reactor Owners Group Executive Oversight Committee Meeting - NRC Presentation

ML22341A012
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Issue date:	12/12/2022
From:	Ngola Otto Licensing Processes Branch
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ML22341A010	List: ML22341A011 ML22341A012 ML23038A001
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Download: ML22341A012 (55)

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Nuclear Re gulator y Commission and Boiling Water Reactor Owner s Gr oup Executive Over sight Committee Meeting

December 12, 2022 Agenda

Time Topic Speaker 1:00 PM Public Meeting Start / Introductions Ngola Otto, NRR, DORL BWROG Project Manager 1:05 PM NRC Opening Remarks Mike King, NRR, Deputy Office Director for Reactor Programs 1:10 PM BW ROG Introduction Steve Douglas, BWROG Executive Chairman

• Meeting Objectives & BW ROG Overview

1:20 PM Emergency Procedures Committee and Emergency Procedures and Severe Accident Guidelines (EPG/SAG) Rev. 4 Update Bill Williamson, BWROG

1:30 PM Risk Topics (BW ROG) Robert Rishel, BWROG Integrated Risk Informed

• NRC Endorsement of Institute of Electrical and Electronics Engineers (IEEE) 1819 and endorsed NEI Guidance for Regulation Committee Chairman 50.69

• ASME/IEEE Components Standards that could be developed to replace/supplement NRC endorsed NEI 50.69 Guidance

• NRC endorsement of Low Power/Shutdown PRA standard

1:50 PM TSTF-576, Revise Safety/Relief Valve (SRV) Requirements Ryan Joyce, BWROG 2:10 PM RG 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors Tamara Malaney, RG 1.183 Revision Committee Vice Chair NRC Presentations 2:25 PM Proprietary Information Thomas Wengert, NRR, DORL 2:40 PM Break All 2:55 PM Update on Inspection Plans and Schedule for EPG/SAG Rev. 4 Implementation Aron Lewin, NRR, DRO

3:10 PM Licensing and TSTF -576, SRV Update Michelle Honcharik, NRR, DSS

3:20 PM Engineering Program Inspection Changes Douglas Bollock, NRR, DRO 3:35 PM Subsequent License Renewal Lauren Gibson, NRR, DNRL Ted Smith, NMSS, REFS 3:50 PM Digital Instrumentation & Controls Mike Waters, NRR, DEX 4:10 PM NRC Questions/Comments/Wrap-up NRC/BW ROG 4:20 PM Opportunity Public Questions/Comments Public/NRC 4:30 PM Adjourn Opening Remar ks

Michael King Deputy Of fice Dir ector for Reactor Pr og r ams Of fice of Nuclear Reactor Re gulation

3 NRC Staf f Review of Requests for W ithholding of Pr oprietar y Infor mation

Tom Wenger t Of fice of Nuclear Reactor Re gulation December 12, 2022 Key Messa ges

• Release of public infor mation is an impor tant aspect of NRCs mission and its value of public openness.

• 10 CFR 2.390 contains the r equir ements for submitting and r equesting withholding of pr oprietar y infor mation.

• NRR Of fice Instr uction LIC-204, Rev. 4, pr ovides guidance for the NRC staf f s r eview and disposition of withholding r equests.

• A good under standing of the r equir ements for pr oprietar y submittals and r eviews by the NRC staf f and the industr y will impr ove the ef fectiveness of the pr ocess.

• T he NRC cur r entl y plans to tr ansition to a Contr olled Unclassified Infor mation (CUI) pr og r am on November 1, 2023.

5 Over view of A pplicable Re gulations

• Gover ning re gulation: 10 CFR 2.390, Public inspections, exemptions, and requests for withholding.

• NRC is required by 10 CFR 2.390(a) to make public final NRC recor ds, including cor respondence to and from the N RC.

• For submittals requesting withholding of proprietar y infor mation, the NRC must make a deter mination on the request.

• Basic requirements of 10 CFR 2.390 Types of documents that can be withheld [2.390(a)]

Marking requirements [2.390(b)(1)(i)]

Affidavit requirements [2.390(b)(1)(ii)]

NRC criteria for making a determination [2.390(b)(3) and (4)]

6 Over view of NRC Staf f Review Pr ocess

• NRC Mana gement Dir ective 3.4, Release of Infor mation to the Public, describes the a gencys policy gover ning the public availability of infor mation in NRC's possession, including the r eceipt and handling of sensitive pr oprietar y infor mation.

• NRR Of fice Instr uction LIC-204, Handling Requests to W ithhold Pr oprietar y Infor mation fr om Public Disclosur e, Revision 4, contains guidance for the NRC staf f s r eview and disposition of pr oprietar y withholding r equests.

• Basic Requir ements Affidavit or Unsworn Testimony Marking of Information Sought to be Withheld Proprietary Determination by NRC Staff Issuance, Correspondence, and Documentation of the Proprietary Determination

7 Examples of Recent Issues with Pr oprietar y W ithholding Requests

• Requests to withhold infor mation that is already in the public domain

• Proprietar y infor mation unredacted

• Mar king of documents [10 CFR 2.390(b)(1)(i)]

• Issues with Af fidavits [10 CFR 2.390(b)(1)] :

Statement of clear basis for withholding [b)(1)(ii)(C)]

Specific harm statement [(b)(1)(ii)(D)]

Statement of reason for withholding [(b)(1)(iii)]

Affidavit signer: Owner vs. Submitter of information [(b)(1)(iii)]

• Proprietar y slide presentations - withholding request with af fidavit must be submitted in advance to allow staf f to review and make a withholding deter mination prior to the meeting.

8 Summar y

• Release of public infor mation is an impor tant aspect of NRCs mission and its value of public openness.

• 10 CFR 2.390 contains the r equir ements for submitting and r equesting withholding of pr oprietar y infor mation.

• NRR Of fice Instr uction LIC-204, Rev. 4, pr ovides guidance for the NRC staf f s r eview and disposition of withholding r equests.

• NRC staf f will enga ge licensees/applicants/vendor s if ther e ar e questions or disa g r eements on asser tions of withholding.

• A good under standing of the r equir ements for pr oprietar y submittals and r eviews by the NRC staf f and the industr y will impr ove the ef fectiveness of the pr ocess.

9 Refer ences

• 10 CFR 2.390, Public inspections, exemptions, requests for withholding

• NRC Mana gement Directive 3.4, Release of Infor mation to the Public

• NRR Of fice Instr uction LIC-204, Handling Requests to W ithhold Proprietar y Infor mation from Public Disclosure, Revision 4 (ADAMS Accession No. ML20049A139)

• Controlled Unclassified Infor mation (CUI) Prog ram - NRC public website:

https://www.nrc.gov/reading-r m/cui.html

10 Questions?

11 Update on Inspection Plans and Schedule for EPG/SAG Rev. 4

Ar on Lewin Of fice of Nuclear Reactor Re gulation December 12, 2022 71111.18 SAMG Update Sample

• IP 71111.18, Plant Modifications cur rentl y requires inspection of Severe Accident Mana gement Guidelines (SAMGs) updates as a one-time sample to be completed by the end of CY2022.

• To date, no findings have been identified.

• Following CY2022, IP 71111.18 will indicate that the SAMG update sample be perfor med as required.

(see ADAMS ML22154A389)

13 Tr aveler TSTF-576, Revise Safety/Relief Valve Requir ements

Michelle Honcharik Of fice of Nuclear Reactor Re gulation December 12, 2022 Over view of NRC Staf f Review Pr ocess

• Status:

- The traveler is under review by the NRC staff. A second round of Requests for Additional Information (RAI) questions were drafted, and a clarity call was held in October 2022.

• Technical concer n:

- The NRC staff has not been provided adequate assurance that the methodology that will be used to control the Safety/Relief Valve (SRV) setpoints is acceptable. The SRV setpoints can affect the ability of SSCs to respond to or operate through postulated accidents. The NRC staff has been unable to confirm that the methodology will be consistent with approved methods or that the staff will be able to verify adequate response to postulated accidents.

• Next Steps:

- TSTF will be discussing how to proceed with the BWROG licensing committee in December.

15

• Maintain risk-infor med focus.

• Identify deficient conditions that would not nor mall y be r eadil y identifiable thr ough r outine plant activities or perfor mance indicator s (e.g., monitoring during nor mal oper ation or sur veillance tests).

• Allow inspections that ar e focused on r ecent plant changes and oper ating experience.

• Maintain the NRC's r ole as an independent r e gulator.

17

• On Jul y 21, 2022, the NRC Commission approved SECY 0053, Recommendation for Modifying the Periodicity of Reactor Over sight Process Engineering Inspections

• Approved changing engineering inspections from a 3-yr to a 4-yr cycle.

• 4 Engineering inspections will be conducted at each site in the 4-year cycle.

• Comprehensive Engineering Team Inspection (CETI)

• 3 Focused Engineering Inspections (FEI)s.

18 18

• 4 Engineering inspections will be conducted at each site in during the 4-year cycle.

• Comprehensive Engineering Team Inspection (CETI)

• Combines the current IP 71111.21M Design Bases Assurance Inspection (Team) with the triennial portions of IP 711111.07 Heat Exchanger/Sink Performance, and IP 71111.17T,Evaluations of Changes, Tests and Experiments

• 3 Focused Engineering Inspections (FEI)s.

• IP 71111.21N.05 Fire Protection Team Inspection,

• *IP 71111.21N.03 Commercial Grade Dedication, and

• *IP 71111.21N.04 Age-Related Degradation

• New Inspections 19 19

• CETI

• Team makeup: 7 inspectors, 2 onsite weeks (490 direct inspection hours)

We no longer use contractors as routine support for inspections

• Same preparation for inspections as previous DBAI (team) inspections.

20 20 CGD inspection objectives To review the implementation of the licensees process for dedicating commercial-grade items (CGIs), as required in applicable portions of Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 (Appendix B) to ensure reasonable assurance is provided that CGIs will perform their intended safety function.

To review implementation of the licensees procurement process for safety-related components as required in Appendix B or 10 CFR 50.69.

21 21 Technical/process and inspection implementation tr aining conducted for each re gions engineering inspector s.

Training includes table-top scenarios

NRC Technical and Prog r ammatic leads identified

NRC inter nal cross-re gional panels will be held post inspection (first 6 months of implementation to ensure consistency)

22 22 Inspection Procedure IP71111.21N.04 is in development. Cur rentl y out for 30- day comment period until November 14. To be completed and publicl y available by end of December 2022

Fir st ARD inspections to be gin after Jul y 2023

23 23 DRAFT Objectives To verify that maintenance activities to addr ess a ge-r elated de g r adation for str uctur es and components (SCs) ar e being conducted in a manner that pr ovides r easonable assur ance of the safe oper ation of the plant.

To verify that a ge-r elated de g r adation for plant SCs ar e appr opriatel y identified, addr essed, and cor r ected.

24 24 ARD inspection will sample both active and passive components

T his is NOT an a ging-mana gement prog r am inspection.

Age-related issues, aging components or phenomenon that accelerates the age of components.

Likel y around 12-24 samples.

Sample selection heavily informed by operational experience.

25 25 Technical and inspection implementation tr aining will be developed and conducted for each re gions engineering inspector s.

Training will include table-top scenarios NRC will identify Technical and Prog r ammatic leads

NRC inter nal cross-re gional panels will be held post inspection to ensure consistency

26 26 Questions?

27 Douglas Bollock Senior Reactor Oper ations Engineer Of fice of Nuclear Reactor Re gulation Division of Reactor Over sight Reactor Inspection Br anch Email: douglas.bollock@nrc.gov; Phone: 301-415-6609

28 Subsequent License Renewal License Renewal & Envir onmental Reviews

Lauren Gibson, Br anch Chief, License Renewal Projects

Ted Smith, Br anch Chief, Environmental Review License Renewal Turkey Point Units 3 & 4 (FL) Peach Bottom Units 2 & 3 Surry Units 1 & 2 (VA)

(PA)

NEW expiration 2052 & 2053 NEW expiration 2053 & 2054 NEW expiration 2052 & 2053 COMPLETED 12/2019 COMPLETED 03/2020 COMPLETED 05/2021 (ML19191A057) (ML20052F523)

(ML20044D902)

North Anna Units 1 & 2 (VA) Point Beach Units 1 & 2 (WI) Oconee Units 1, 2 & 3 (SC) St. Lucie Units 1 & 2 (FL)

Accepted for review 10/2020 Accepted for review 01/2021 Accepted for review 07/2021 Accepted for review 09/2021

= Site Specific Environmental Report Submitted

30 Comanche Peak Units 1 & 2 (TX)

Submitted 10/2021 Acceptance Review In Progress

31 Review

ACRS Full Committee SER

Review

Annual Updates PM Holds

Resume Nor mal Process Environmental ACRS Full Committee Seems Close Reviewer s SER, Rev 1 or confir m input Supplement and PM compiles 32 Tur key Point Nor th Anna Oconee T he NRC intends to

• review all applicable Category 1 (generic) issues listed in the applicable SEIS Table 4-1 for site-specific findings (e.g., SMALL, MODERATE, LARGE) using the methodology in the LR GEIS and document staff s analysis

33 T he NRC intends to

• review applicable Category 2 (site-specific) issues listed in the applicable SEIS Table 4-2 for new information since the issuance of the site-specific draft or final SEIS and update site-specific analyses

• issue a notice of availability that begins a limited scoping period (comments invited; no public meeting)

• complete a (virtual) environmental audit, including issuing RAIs and RCIs, as appropriate

34 T he NRC intends to

issue a site-specific draft SEIS or draft SEIS supplement for public comment, and a notice of opportunity for hearing

issue a site-specific final SEIS or final SEIS supplement to provide staff s recommendation on whether to authorize the licensing action

35 Timeline: Planned Path Forwar d

Milestone Approximate Timing Site-specific environmental license renewal application supplement received by NRC 0 NRC publishes availability of supplement Federal Register notice (FRN) 15 days NRC publishes notice of intent to prepare an EIS supplement and start of 30-day scoping period, 30 days as appropriate, FRN Scoping period ends (if one is conducted) 60 days Conduct environmental audit 4 months NRC issues environmental RAIs/RCIs (if needed) 5.5 months NRC receives RAI/RCI responses 6.5 months

36 Timeline: Planned Path Forwar d (continued)

Milestone A ppr oximate Timing

NRC publishes draft SEIS supplement or draft SEIS and FRNs to start 45-day comment period and 60 -day period to 12 months request a hearing Draft SEIS supplement or draft SEIS comment period ends 13.5 months

Publish final SEIS supplement or final SEIS and FRN 14.5 months

EPA Issues FRN - final SEIS supplement, or final SEIS, notice of availability and beginning of 30- day cooling off 15 months period NRC issues FRN - renew ed license/record of decision 16.5 months, unless (assuming no comments during EPA cooling off period or hearing(s) held per Commission direction, as appropriate)

37 Based on Notices of Intent, we are expecting 6 applications by the end of FY24.

Resour ces are projected to be tight.

Please continue to send in Notices of Intent so we can plan.

38 39 Digital Instr umentation and Contr ols

Michael Water s Of fice of Nuclear Reactor Re gulation December 12, 2022 What I ll Be Covering To d a y

• NRC Vision

• Accomplishments

• Ongoing Initiatives Photo: Rendering of Limericks Main Control Room displays for planned Plant Protection System, : ML21063A119

4141 NRC Vision for Digital I&C

A clear regulatory structure with reduced regulatory uncertainty that enables the expanded safe use of digital I&C in commercial nuclear reactors while continuing to ensure safety and security.

From NRC SECY 0112

42 Accomplishments

43 Clear Expectations for Implementing 10 CFR 50.59

Chiller Controls

Diesel Generator Controls

Feedwater/Turbine Control System 44 NRC DI&C Interim Staff Guidance (ISG) 06 Revision 2

Timeline (not to scale)

Traditional Process LA Issued

LA R S ubm i tte d NRC Review and Audits NRC Regional Inspection (Phase 1 Information) Processes

Phase 2Supplemental Information Licensee Activities

Concepts High Level Detailed HW & SW Design Implementation, Installation and and Pre-applicationSystem Design, and Fabrication Software V&V, and Site Acceptance Testing Meetings Planning Factory Testing

Alternate Review Process LA Issued

NRC Vendor NRC Regional Inspection LA R S ubm i tte d NRC Review and Audits Inspection Processes Processes All Information

45 NRC Branch Technical Position 7-19 Defense-in -Depth and Diversity to Address DI&C CCF

Incorporates a Risk-Informed Graded Approach

Incorporates Lessons-Learned from Previous Operating Reactor and New Reactor Reviews

Supports Expanded use of Defensive Measures to Address Software CCF

46 Non-Light-Water Reactor I&C Design Review Guide (DRG)

Supports NRC s Non-LWR Vision and Strategy, Implementation Action Plan Strategy 3, which involves developing:

1) guidance for flexible regulatory review processes for non-LWRs within the bounds of existing regulations

2) non-LWR regulatory framework that is risk-informed, performance-based, and features NRC staff s review efforts commensurate with the demonstrated safety performance of non-LWR technologies.

3) Incorporates principles from RG 1.233 and NRC Vision and Strategy: Safely Achieving Effective and Efficient Non-Light Water Reactor Mission Readiness, which describes the NRC s vision and strategy for preparing for non-LWR reviews.

47 Just Released--Reg Guide 1.250: Dedication of Commercial-Grade Digital I&C Items in Nuclear Plants Endorses NEI 17-06 Rev. 1 and IEC-61508 with clarifications

Provides supplemental guidance for performing commercial grade dedication of digital technology equipment by leveraging 3rd party certifications of digital I&C equipment to determine the acceptability of the dependability critical characteristics of that equipment

Ensures that the 3rd party certification organizations are regularly accredited by signatories to the International Accreditation Forum Multilateral Recognition Arrangement

48 Ongoing Initiatives

49 DI&C Safety System Licensing

• License amendment requests for operating reactor digital I&C modernization Turkey Point RPS/ESFAS replacement (July 2022)

Limerick RPS/ESFAS and other system replacement (Sept 2022)

• Construction Permit Reviews Kairos (Sept 2021)

Abilene Christian University (Aug 2022)

• Pre-submittal interactions, white papers, topical reports, & reviews supporting advanced reactor I&C designs (2023)

NuScale US460 TerraPower ASL2 Holtec SMR-160 X-Energy MELCO GE BWRX-300 Atomic Alchemy MMR WEC eVinci

50 Risk-Informing Digital I&C CCF Policy

• The current policy in SRM-93digital I&C systems in nuclear power plants- 087 has been effectively used to license

A defense-in-depth and diversity (D3) analysis is required to cope with a hypothetical digital CCF that disables a safety function during an accident.

Requires a diverse means of safety actuation if plant consequences could be significant

• Staff proposed expanding the use of risk information in SECY(August 2022) to address potential alternatives for the D3 analysis 0076

• Additional stakeholder interactions clarifying the policy on independence of manual actuation displays/controls credited in the D3 analysis

51 Continue work on Reg Guides Endorsing Updated Standards

• Endorsement of IEEE 7-4.3.2-2016 (RG 1.152)

• Endorsement of IEEE-603-2018 (TBD)

• Endorsement of IEEE-1012-2106 and streamlining of Guides for IEEE computer society standards (RGs 1.168 - 1.173)

52 Summary

• Early engagement and pre-submittal meetings are critical

• NRC will continue to engage stakeholders on regulatory needs and guidance development activities

• Potential Interactions in 2023 RG 1.153 Workshop (~March)

Advanced Reactor Workshop(s) (TBD)

DI&C Licensing Lessons Learned Workshop (April - May)

53 Questions?

Clear 50.59 Efficient Expectations Licensing NEI BT P Endorsement of 96- 07 ISG Updated Standards App. D RIS NRC 2002-22 06 7-19 CCF Sup. 1 NEI 17- 06 IEC IEEE 54 Oppor tunity for Public Questions and/or Comments

55