ML21299A197
| ML21299A197 | |
| Person / Time | |
|---|---|
| Issue date: | 09/22/2021 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Antonescu, C, ACRS | |
| References | |
| NRC-1676 | |
| Download: ML21299A197 (165) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Digital Instrumentation and Control Systems Docket Number: (n/a)
Location: teleconference Date: Wednesday, September 22, 2021 Work Order No.: NRC-1676 Pages 1-138 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W., Suite 200 Washington, D.C. 20009 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 DIGITAL INSTRUMENTATION AND CONTROL SYSTEMS 8 SUBCOMMITTEE 9 + + + + +
10 WEDNESDAY 11 SEPTEMBER 22, 2021 12 + + + + +
13 The Subcommittee met via Teleconference, 14 at 9:30 a.m. EDT, Charles Brown, Chair, presiding.
15 16 COMMITTEE MEMBERS:
17 CHARLES H. BROWN, JR., Chair 18 RONALD G. BALLINGER, Member 19 VICKI M. BIER, Member 20 VESNA B. DIMITRIJEVIC, Member 21 GREGORY H. HALNON, Member 22 JOSE MARCH-LEUBA, Member 23 DAVID A. PETTI, Member 24 JOY L. REMPE, Member 25 MATTHEW W. SUNSERI, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1 DESIGNATED FEDERAL OFFICIAL:
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 1 CONTENTS 2 Opening Remarks . . . . . . . . . . . . . . . . . 4 3 Status of Infrastructure Activities . . . . . . . 14 4 Recent Guidance Updates 5 Guidance Under Review 6 Regulatory Guide Updates 7 SRP Modernization 8 Status of Licensing Activities . . . . . . . . . 72 9 Digital I&C Licensing Status 10 Updates 11 Digital I&C Licensing Status 12 Topic Reports 13 Closing Comments . . . . . . . . . . . . . . . 134 14 Public Comments . . . . . . . . . . . . . . . . 135 15 Closing Remarks . . . . . . . . . . . . . . . . 135 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 1 P R O C E E D I N G S 2 9:33 a.m.
3 CHAIR BROWN: The meeting will now come to 4 order.
5 This is a meeting of the Digital 6 Instrumentation and Control Systems Subcommittee. I 7 am Charles Brown, Chairman of this Subcommittee 8 meeting.
9 ACRS members in attendance are Matt 10 Sunseri, Jose March-Leuba, Vesna Dimitrijevic, Joy 11 Rempe, Ron Ballinger, Dave Petti, Vicki Bier, and Greg 12 Halnon.
13 Christina Antonescu of the ACRS staff is 14 the Designated Federal Official for this meeting.
15 I presume the court reporter is available.
16 MS. ANTONESCU: Yes, the court reporter is 17 available.
18 CHAIR BROWN: Okay. Thank you.
19 The purpose of this meeting is for the 20 staff to brief the Subcommittee on the status of NRC 21 Digital I&C activities.
22 The ACRS was established by statute and is 23 governed by the Federal Advisory Committee Act, FACA.
24 That means that the Committee can only speak through 25 its published letter reports. We hold meetings to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 1 gather information to support our deliberations.
2 Interested parties who wish to provide 3 comments can contact our office requesting time. That 4 said, we set aside 10 minutes for comments from 5 members of the public who are listening into our 6 meetings. Written comments are also welcome.
7 The meeting agenda for today's meeting was 8 published on the NRC's public meeting notice website, 9 as well as the ACRS meeting website. On the agenda 10 for this meeting and on the ACRS website are 11 instructions as to how the public may participate. No 12 requests for making a statement to the Subcommittee 13 has been received from the public.
14 Due to COVID-19, we are conducting today's 15 meeting virtually.
16 A transcript of the meeting is being kept 17 and will be made available on our website. Therefore, 18 we request that participants in this meeting should, 19 first, identify themselves and speak with sufficient 20 clarity and volume, so that they can be readily heard.
21 All presenters, please pause from time to 22 time to allow members to ask questions. Please also 23 indicate the slide number you are on when moving to 24 the next slide.
25 We have the MS Teams phone line only-audio NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 1 established for the public to listen to the meeting.
2 Based on our experience from previous 3 virtual meetings, I would like to remind the speakers 4 and presenters to speak slowly.
5 We will take a short break after each 6 presentation to allow time for screen-sharing as well 7 as at the Chairman's discretion during longer 8 presentations.
9 Lastly, please do not use any virtual 10 meeting feature to conduct sidebar conversations or 11 discussions. Rather, contact the DFO if you have 12 technical questions, so we can bring those to the 13 fore.
14 We will now proceed with the meeting, and 15 I will, I guess, Mr. Marshall, Michael Marshall, to 16 share his screen with us, which I see it. Does 17 everybody else see the screen?
18 (No response.)
19 Hearing no negatives, I will ask Mr. Eric 20 Benner, the Director of the Division of Engineering 21 and External Hazards in the Office of Nuclear Reactor 22 Regulation, for any introductory remarks to make 23 before we begin today's presentations.
24 Eric?
25 MR. BENNER: Okay. Thank you, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 1 Brown.
2 Mike Marshall, can you go to the second 3 slide?
4 So, as was alluded to, our purpose today 5 is to brief this Subcommittee on the status of key 6 digital I&C regulatory activities. I would say it 7 even goes beyond key. I think we're covering most of 8 the universe of what we're working on right now.
9 And part of the reason we are doing it 10 this way is a lot of these different pieces of the 11 regulatory infrastructure build upon one another. So, 12 for the things that are more past tense, we're going 13 to cover them pretty quickly, but they are some of the 14 building blocks for things that have come after.
15 So, we have kept the presentation 16 intentionally short. We think there will be plenty of 17 time for questions and answers for the Committee.
18 We will, also, be covering the schedules 19 for any of the ongoing and future activities. And we 20 did not put detail in the slides on those, both from 21 the standpoint of some of the things are longer-term 22 and, thus, the schedules are more fluid. Some of the 23 things are predicated on things outside of our 24 control. For instance, for our licensing action 25 discussion, we expect to get an application from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 1 Turkey Point by the end of this month. So, the 2 discussion we'll have on the schedule, that review 3 will be predicated on that assumption, but, obviously, 4 we'll need to validate that assumption. And the hope 5 with this discussion is both to give the ACRS an 6 understanding of the entire landscape of work going 7 on, and to help in the initial planning stages of when 8 and where we'll be seeking ACRS involvement.
9 Next slide, please.
10 So, this is the agenda. Joining me today 11 will be two of my direct-report Branch Chiefs, Jeanne 12 Johnston and Mike Waters. Jeanne will be generally 13 covering all of the guidance document updates. Mike 14 Waters will be covering the licensing activities. And 15 we also have a Senior Electronics Engineer, Rich 16 Stattel, who I believe many of you are familiar with 17 -- he's briefed the Committee a number of times before 18 -- who will discuss Topical Reports, and then, 19 obviously, closing comments. And like I said, I 20 believe we have plenty of time to be able to dive into 21 any questions or concerns the members have.
22 I'm pleased to know -- and this is an 23 interesting outcome -- that we don't have a lot going 24 on right now that would warrant ACRS review. And you 25 might say, why am I pleased about that? Well, part of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 1 it is, by definition, the changes we've made under 2 10 CFR 50.59 broaden what licensees can do without any 3 NRC licensing involvement.
4 So, we're starting to collect data on how 5 many 50.59s are being done for digital information.
6 That data is still rough. So, I'm not going to bring 7 it up here. But, as we collect that data, we'll share 8 it with the Committee.
9 So, there are upgrades being done that we 10 have no licensing involvement on. Now we do perform 11 oversight of licensing 50.59s on a sample basis, and 12 we also will start collecting feedback on any 13 oversight performed of digital mods.
14 We have some limited data that shows that 15 licensees have been using the guidance that's out 16 there appropriately. So, we've had no concern. So, 17 that's broadening the aperture for licensees to adopt 18 new digital equipment. So, that's one of the reasons 19 why I'm pleased.
20 Regarding infrastructure, this was a high 21 focus of the Commission, as indicated in 2016, where 22 we got guidance from the Commission to really come up 23 with what was called the Integrated Action Plan. I 24 will say that all of the activities on the Integrated 25 Action Plan are now complete, except for NEI 17-06, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 1 which deals with commercial grade dedication, which we 2 will be discussing today.
3 And in our interactions with the 4 Commission, we all aligned that we are no longer 5 updating the Integrated Action Plan, and any ongoing 6 infrastructure upgrades are being managed through our 7 routine processes. So, like the Reg Guide processes 8 is what we're following now. There isn't a dedicated 9 focus on digital I&C infrastructure.
10 Now, from an Integrated Action Plan 11 standpoint, myself and Louise Lund, who is my 12 counterpart in the Office of Research, we consider 13 ourselves the accountable SES managers for all things 14 digital I&C. So, we still maintain a focus, but, 15 basically, the presentation you're going to get today 16 really aligns with both the information that Louise 17 and I get updated on on a fairly regular basis, and 18 which we'll go into we still do an annual paper to the 19 Commission. And that paper is due next month. And 20 really, what you're getting today will be a preview of 21 what's going to be in that paper next month.
22 So, really, our focus now is somewhat 23 shifting to licensing actions, and I'm happy to report 24 that we completed -- I'm taking a little of Mike's 25 thunder -- that we've completed our first licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 1 action, Waterford, under the revised guidance. But 2 we're starting to get plans for more.
3 I alluded to Turkey Point is supposed to 4 be coming in at the end of the month. That's a large-5 scale upgrade to RPS and SFAS and some other systems.
6 We are planning for, our schedule is planning for ACRS 7 review for that. So, we'll be talking about that.
8 Limerick is supposed to be coming in next 9 fall, and we're starting to get feedback from other 10 licensees -- Dominion, in particular -- that they're 11 starting to do the planning.
12 So, for this large-scale licensing 13 actions, that will have a touch point with the 14 Committee, and I think that will be where the rubber 15 hits the road. So that, all this infrastructure has 16 been great, but, as we get into the actual licensing 17 reviews, that's where the staff has to make a 18 regulatory decision that comports with the regulations 19 and provides reasonable assurance of adequate 20 protection. And we look forward to having the 21 discussions with the Committees on those actual cases, 22 to both demonstrate these upgrades are happening and 23 they're going to be done in a manner that's safe.
24 So, I appreciate the opportunity to make 25 these opening remarks. And with that, I will turn it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 1 over to Jeanne Johnston.
2 MS. JOHNSTON: Thank you, Eric.
3 CHAIR BROWN: Jeanne, can you excuse me 4 for a second?
5 MS. JOHNSTON: Sure.
6 CHAIR BROWN: So that I can ask Eric a 7 question.
8 MS. JOHNSTON: Okay.
9 CHAIR BROWN: Relative to you addressed 10 Limerick and Turkey Point as being major upgrades, 11 which we would, obviously, be involved in. But you, 12 then, said that other stuff changes under 50.59, which 13 I remember they had a lot of work on 50.59 --
14 MR. BENNER: Right.
15 CHAIR BROWN: -- and the appendix, and how 16 they would be apprised. So, we're not disagreeing or 17 arguing with that.
18 The one area I guess I'd like to have some 19 clarification is there's a number of Reg Guides that 20 apply to digital I&C, and things of that nature, that 21 aren't plant upgrades, but are changes in terms of the 22 regulatory guidance that's put out.
23 MR. BENNER: Yes, uh-hum.
24 CHAIR BROWN: We would expect to continue 25 to see those that we desire to see --
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13 1 MR. BENNER: Yes.
2 CHAIR BROWN: -- under this, under your 3 discussion. So, nothing's changed relative to that?
4 MR. BENNER: No, no. And I think, from a 5 process standpoint, the Reg Guide process offers the 6 opportunity for you to review all of them. I think 7 Christine and I have talked a little about, you know, 8 where we're getting the overt feedback from you that 9 these in this technical arena are ones you're going to 10 want to see. So, we have that information. I will 11 work with my counterpart, Louise, who is the process 12 owner for the Reg Guide process, to make sure that 13 that interest by the Committee is locked in.
14 So, as we get down the path of entering 15 the process for those documents, that your interest in 16 reviewing them is noted, so it doesn't just get lost 17 in the routine process where they're all offered to 18 the Committee to see if the Committee has interest in 19 reviewing.
20 CHAIR BROWN: You are aware that we do 21 have a Commission briefing in October?
22 MR. BENNER: Uh-hum.
23 CHAIR BROWN: And the discussion of some 24 of these, that type of an issue, is part of that 25 discussion with the Commission. Just I presume you're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 1 aware of that?
2 MR. BENNER: Yes, we are. Thank you.
3 CHAIR BROWN: Okay.
4 MR. BENNER: Okay.
5 CHAIR BROWN: All right. I'll let you go 6 on.
7 Any other comments from any other vendors 8 before I mean, excuse me, members -- my old career is 9 coming to the fore here -- before we proceed on with 10 Jeanne?
11 (No response.)
12 Okay. Go ahead, Jeanne. Thank you very 13 much for your patience.
14 MS. JOHNSTON: Okay. Thank you, Member 15 Brown.
16 Good morning. My name is Jeanne Johnston, 17 and I'm the Chief of the Long Term Operations and 18 Modernization Branch.
19 For those of you who don't know, we 20 reorganized last year into a three-Branch team 21 covering electrical engineering and I&C licensing and 22 guidance activities. So, my group has the 23 programmatic responsibility to lead guidance 24 development in I&C and special projects that support 25 I&C modernization initiatives, which are necessary for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 1 the long-term operations of --
2 CHAIR BROWN: Jeanne?
3 MS. JOHNSTON: Yes?
4 CHAIR BROWN: You said, "electrical and 5 I&C."
6 MS. JOHNSTON: That's correct.
7 CHAIR BROWN: So, you're tasked with the 8 electrical as well?
9 MS. JOHNSTON: Yes, I have electrical 10 engineers and I&C in my Branch, yes.
11 CHAIR BROWN: Okay. So, you cover that 12 general category of stuff, such as Reg Guide 1.9 is a 13 diesel generator, applications and stuff.
14 MS. JOHNSTON: Yes.
15 CHAIR BROWN: So, I would expect 16 electrical stuff that's associated with a plant would 17 come under your purview then?
18 MS. JOHNSTON: Yes, it does. We also have 19 a separate Electrical Engineering Branch, which is not 20 present today. Today's focus is on I&C.
21 CHAIR BROWN: Okay. That's fine.
22 MS. JOHNSTON: Okay. Yes, but we are, I 23 was separating the Reg Guide 1.9, which you got a 24 briefing on earlier this year, but we aren't going to 25 be providing an update at this meeting --
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16 1 CHAIR BROWN: Okay.
2 MS. JOHNSTON: -- on that particular Reg 3 Guide.
4 CHAIR BROWN: Okay. Thank you.
5 MS. JOHNSTON: Okay. So, today, first, 6 I'm going to cover some major accomplishments that 7 really lay the foundation and prepare the agency to be 8 better able to support to increased licensing 9 activities for the digital modernization.
10 Next slide.
11 As was mentioned previously in Eric's 12 opening remarks, over recent years we have produced a 13 number of key infrastructure updates to support and 14 remove barriers for performing digital modifications 15 under the 50.59 process. Most notably is the 16 Supplement to a Regulatory Information Summary, the 17 RIS, and the revised Reg Guide 1.187. Both of these 18 products provide enhanced guidance for addressing 19 software common cause failures when performing 50.59 20 digital mods. And we believe that these products 21 represent a big accomplishment, in that the staff has 22 clarified how licensees can perform digital I&C 23 modifications without NRC approval under the 50.59 24 process.
25 CHAIR BROWN: Can I ask you a question?
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17 1 MS. JOHNSTON: Sure.
2 CHAIR BROWN: Back when we did the 50.59 3 and the NEI 96-07, Reg Guide 1.187 was part of that 4 process. My memory is that was Rev. 2.
5 MS. JOHNSTON: Yes.
6 CHAIR BROWN: And this slide indicates a 7 Rev. 3. Has that been issued already?
8 MS. JOHNSTON: Yes. So, as you correctly 9 recall, Revision 2 was issued in 2020, and we did 10 issue it with an opportunity for post-promulgation 11 comments. And due to the comments received, we made 12 some minor changes and issued Revision 3 this year, in 13 2021. So, Revision 3 is very similar to Revision 2.
14 It just adds a few clarifications in response to post-15 promulgation comments. And they're very similar, but 16 that's the difference between the revisions.
17 CHAIR BROWN: Got it. The reason I ask is 18 I don't remember any inquiries as to whether we wanted 19 to see Rev. 3 on that. So, I take it you never asked, 20 is that correct?
21 MR. BENNER: No, my understanding is that 22 Research's Reg Guide Branch did communicate that 23 opportunity.
24 CHAIR BROWN: Okay. I'm saying my memory 25 could be faulty.
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18 1 MR. BENNER: Yes.
2 CHAIR BROWN: Stuffing a lot of stuff in 3 it.
4 MR. BENNER: But, like Jeanne said, it's 5 a clarification, right. It really came up somewhat as 6 a training issue, that there was a piece of the 7 guidance that needed clarification. So, then, 8 internally, we had a lot of discussion of, does there 9 need to be an update at all? We felt it was prudent 10 to provide the clarification. Basically, NEI revised 11 their training materials to clarify the issue. We, 12 essentially, took the language in their training 13 materials and added that to the clarification. So, I 14 would say it's not a substantive change. It was pure 15 clarification.
16 CHAIR BROWN: Okay. Thank you.
17 MS. JOHNSTON: Okay. So, moving on, the 18 guidance, key guidance documents have been updated, 19 but we're ongoing in our efforts here to make sure 20 that the agency implements the new guidance in a 21 consistent fashion. So, we have supported regional 22 inspector training on both of these documents over 23 recent years.
24 And we are coordinating with our 25 colleagues in the Regions who are performing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 1 inspections for digital modifications. And we were 2 made aware of a desire for a tool that inspectors 3 could use to help them when inspecting new digital 4 systems. And so, we are in the process of putting 5 together a proposed Digital Operating Experience Smart 6 Sample document, which is an optional, voluntary tool 7 to aid inspectors as they are reviewing new digital 8 installations.
9 So, an OpE Smart Sample is a document that 10 provides the inspection staff with a synopsis of 11 relevant operating experience. And in this case, it 12 would be related to digital I&C systems, and they 13 could use this document as an additional tool to help 14 them complete ROP baseline inspections. So, we are in 15 the process of developing this, and we don't have too 16 much further to share on that. But I'll pause here in 17 case there are any questions on that.
18 CHAIR BROWN: Yes. It's me again, not on 19 that.
20 While you were going through the RIS, I 21 went back -- and to make sure you all understand, it 22 was not impugning anybody's integrity, because I 23 didn't intend that -- yes, I did review what you all 24 proposed for Rev. 3 and agreed that we did not need to 25 review it. So, the process is working fine from that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 1 standpoint.
2 MS. JOHNSTON: Okay. Fantastic.
3 CHAIR BROWN: I appreciate that. I didn't 4 want you to think that I was walking away with the 5 wrong impression, because I literally forgot it. So, 6 I went and looked it up.
7 MS. JOHNSTON: Thank you. I think it just 8 confirms that the changes between Rev. 2 and Rev. 3 9 were relatively minor.
10 CHAIR BROWN: Yes, very much so. Very 11 much so. Thank you.
12 MS. JOHNSTON: Okay. If there are no 13 further questions on this, we can move to the next 14 slide.
15 All right. For licensing process for 16 digital modification, many of you know we've issued, 17 in 2018, a revision to our ISG-06. And this defines 18 what we call an alternate review process for digital 19 I&C modifications that require NRC approval through 20 the license amendment process.
21 And this ARP allows for an initial single 22 phase of document submittals for review shortly after 23 the high-level design has been firmed up and the 24 detailed design is underway. And this is opposed to 25 the previous version, which was Rev. 1, which defined NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 1 a tiered approach, tiered submittals.
2 So, under the ARP, the staff can 3 potentially make its licensing findings after detailed 4 functional design had been completed, but before 5 software validation and factory acceptance testing has 6 been completed.
7 The ideal application of this process 8 would somewhat abbreviate the licensing review for 9 making a reasonable assurance finding, but would 10 increase the emphasis on the oversight activities.
11 So, such activities such as NRC inspections for 12 ensuring that licensee has adequately adhered to its 13 proposed design, and that the licensee's vendors and 14 systems integration contractors have correctly 15 implemented appropriate software and hardware 16 integration validation and verification processes.
17 So, Rev. 2 was issued, like I said, in 18 2018. And since then, we've had a number of 19 stakeholder outreach activities, including a workshop 20 earlier this year to discuss the application of ARP 21 and clarify any questions from stakeholders.
22 And Mike Waters is going to cover this 23 later in the presentation today, when he talks about 24 the licensing activities in Waterford. But we first 25 used this ARP process for the Waterford core NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 1 protection calculator system replacement, and we're 2 continuing to engage stakeholders on feedback and 3 questions regarding the process. And we are planning 4 to have another workshop this winter and continue to 5 talk about lessons learned and collect some 6 opportunities to potentially revise it in the future.
7 But there are no current plans for Rev. 3 right now.
8 We're still trying to get runtime with Rev. 2, and we 9 expect to exercise the ARP with our future anticipated 10 digital modification LARS that are coming in over the 11 next year or so.
12 CHAIR BROWN: Okay. Can I clarify? I 13 just want to make sure I understand that, with Rev. 2, 14 with these two upcoming, the Turkey Point and 15 Limerick, I would presume, based on your comments, 16 that you all intend to use ISG-06 in what I call the 17 free application part? Or that was where it was 18 proposed initially to be used, if my memory serves me 19 right.
20 MS. JOHNSTON: Yes. So, we are in pre-21 submittal engagements with Turkey Point and Limerick.
22 And part of those discussions is clarifying 23 application of this alternate review process. And 24 there's the ideal process, and then, there's in 25 practice, you know, applying it for a real-life, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 1 complex upgrade. And so, we are learning some things, 2 and I think we're having really productive 3 conversations in the pre-submittal engagements on 4 applying this for a bigger-scale, more complex 5 upgrade.
6 CHAIR BROWN: Okay. The reason I ask is 7 that one of the critical parts of ISG-06 was the 8 emphasis on the overall system architecture, which we 9 have used extensively in the last three or four new 10 design plant applications, DCDs and licensing actions.
11 So, it's good to get that out on the table in front to 12 make sure that, when they finally do come in, we are 13 involved in, subsequently, in the review of a well-14 defined system architecture, similar to that we saw in 15 NuScale and, say, the APR1400, is provided as part of 16 that overall review process.
17 And that was to get that out on the table 18 before. That's why we started that back in 2008 or 19 2009, when we had difficulty with an earlier 20 process/program at that time. So, I just wanted to 21 make sure we hadn't lost the bubble.
22 MS. JOHNSTON: Okay. Certainly. And Mike 23 Waters will definitely cover the anticipated Limerick 24 and Turkey Point LARS later today.
25 CHAIR BROWN: Okay. Thank you very much, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 1 Jeanne.
2 MS. JOHNSTON: No problem.
3 We can go on to the next slide, if there 4 are no further questions.
5 CHAIR BROWN: No, I'm done with that.
6 MS. JOHNSTON: Okay. Okay. So, this 7 year, we updated an Inspection Procedure 52003 for 8 digital I&C mods. And this Inspection Procedure 9 supports all digital modification inspections, 10 including those that are made under the ARP. This 11 document was enhanced to include oversight of 12 licensees' processes for conducting systems 13 integration and their oversight throughout the 14 hardware and software development life cycle. And 15 additionally, our inspection criteria was enhanced to 16 more clearly specify the goals of the inspection and 17 to verify licensees' modification documentation and 18 other relevant documentation, such as test results 19 evaluation.
20 We're using this IP for the first time to 21 support the Waterford core protection calculator 22 system replacement inspections, and site acceptance 23 tests for Waterford are anticipated to be conducted 24 next month.
25 And we have received some preliminary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 1 feedback from industry on this IP, and we're working 2 with our external stakeholders to address this 3 feedback, which will be done at a future public 4 meeting. We don't currently have that scheduled yet, 5 but we can keep you informed, if you are interested in 6 those types of interactions.
7 Any questions on the Inspection Procedure?
8 (No response.)
9 Okay. Hearing none, I'll move on to the 10 BTP. BTP-719, Revision 8, I'm sure the members are 11 well aware that we issued this revision earlier this 12 year. Overall, we believe that the new revision 13 provides flexibility for new and innovative approaches 14 to address common cause failure and using approaches 15 such as defensive measures, but it also allows for 16 flexibility for newer approaches to be considered by 17 the staff on a case-by-case basis.
18 And the ACRS, when we previously came to 19 ACRS for review of this product, we were made aware of 20 some concerns regarding the need to enforce the use of 21 unidirectional, hardware-based data communications, 22 when those communications occur from high safety 23 significant systems to a system of lower safety 24 significance.
25 And the Chairman tasked the EDO to set up NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 1 an independent staff team. And that independent staff 2 review team, at the direction of the EDO, performed a 3 review. Ultimately, the outcome was a recommendation 4 to update certain key guidance documents, including 5 the BTP, to raise awareness that unidirectional 6 communications is one available option for system 7 designers. And we are planning on revising the BTP to 8 address that direction from the EDO to include that 9 enhanced clarification and to add in our lessons 10 learned from applying the BTP for upcoming licensing 11 actions.
12 So, we are planning to update the BTP.
13 However, the timeline for doing that is kind off to 14 the future. So, we are not going to be coming back to 15 ACRS on the BTP anytime soon. We are going to be 16 applying the BTP for the Turkey Point and Limerick 17 applications and collecting lessons learned. And 18 Revision 9 will be a wholesale revision to incorporate 19 the current feedback that we have and new feedback 20 that we're going to collect.
21 CHAIR BROWN: You're aware that's an 22 issue?
23 MS. JOHNSTON: Yes.
24 CHAIR BROWN: And you're aware that 25 earlier comments were, it sounds like you won't even NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 1 be addressing the unidirectional issue on these 2 because it's not in the BTP? So, it just hangs out 3 there waiting to be; sooner or later, we're going to 4 look at these things. I'm just making sure it's clear 5 that, when these projects come forth, I can virtually 6 guarantee there will be significant discussion as to 7 how the communications are done, just as occurred on 8 APR1400 and NuScale.
9 MR. BENNER: And I would say there's two 10 points to that, Member Brown. The first point is for 11 the operating reactors. As part of the implementation 12 of the cyber security requirements, they all 13 implemented the data diode so it exists.
14 So, certainly for any operating reactor 15 LARS that come forth, the fact that they've 16 implemented that is something we're aware of, and, you 17 know, we'll factor into the review as appropriate.
18 The letter, the recommendations from the 19 independent review team and the EDO's memo to the 20 Chairman drew a conclusion that there was no safety 21 issue identified and no regulatory gap in that this is 22 still seen as a cyber issue, and it's addressed as 23 part of the cyber program requirements.
24 Now, for the operating reactors, like I 25 said, they all have their existing cyber program, so, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 1 which includes the data diodes. So that information 2 exists. So, for these reviews, I think we're all 3 going to end up in a, in exactly the same place.
4 I think where you've rightly pointed out 5 is there may still be some disconnect on what will 6 happen in design certification space. So the 7 recommendations have us revise the BTP, Reg Guide 8 1.53, and NSIR Revised Reg Guide 5.71 to raise 9 awareness of this for design cert applicants.
10 But there still will not be any sort of 11 regulatory finding in this regard at the design cert 12 stage because that continues to be addressed in the 13 operational cyber security program review that happens 14 at the COL or operating license stage under Part 50.
15 So I understand that there still may be 16 some concern in that regard. But that's what the team 17 found and that's what the EDO -- the EDO tasked us to 18 make revisions that are in alignment with what the 19 team found.
20 CHAIR BROWN: Well, one of the aspects of 21 that is you're doing a reactor protection system and 22 safeguards upgrades, whatever they consist of, which 23 involves a whole new architecture of replacement of 24 analog equipment with digital equipment. So the 25 digital, the data diodes that had been implemented had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 1 been implemented in the framework of an architecture 2 that is analog, not digital.
3 So there are other aspects of applying a 4 digital architecture other than and over and above 5 what has already been accomplished in the past. I 6 recognize what operating plants have done up to this 7 point via the previous orders and the Reg Guide 5.71 8 implementation in operating plants.
9 So there's a difference right now if you 10 don't -- you've got to look at the new architecture 11 and say does it still, is the existing design and 12 setup satisfactory for what we're receiving or has it 13 --
14 MR. BENNER: Yes.
15 CHAIR BROWN: -- been compromised in some 16 other way. For example --
17 MR. BENNER: Yes, yes.
18 CHAIR BROWN: -- the new systems in the 19 operating plant, the fundamental point of cyber 20 doesn't even deal with the protection systems per se.
21 You can't change those functions.
22 It's for the overall plant. Any 23 information going out goes through a data diode. And 24 it's protected from external connection for other 25 aspects of the plant, not the protection system.
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30 1 So I guess I would disagree that there's 2 not a safety issue, because right now the application 3 of the digital systems is not addressed at all.
4 MR. BENNER: And I will say that our 5 review will continue to look at all hazards of what is 6 inside the data diode to look at where there are 7 potentially bidirectional communications.
8 I will say even on the, you know, the 9 APR1400 there, you know, within that boundary, there 10 are some bidirectional communications. And we 11 understand there are potential hazards associated with 12 that.
13 And ultimately, we had what we felt were 14 the right constraints in place to manage the hazards 15 of those bidirectional communications and made the 16 licensing decision on, or the certification decision 17 on that.
18 CHAIR BROWN: If you note from my review, 19 we did not -- the reason we were not dealing with a 20 rule change per se, a rule change is like taking a 21 hammer, you know, to swat a gnat in some -- that's not 22 a good analogy.
23 But there is no argument that there are 24 some areas, but not in the protection safeguards or 25 what I call safety-related control systems, where you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 1 do not want to have bidirectional communications into 2 those systems. And now they're internal.
3 So you have to look at those individually 4 within the plant, not just -- which is what we did on 5 the design certifications. The data going out of the 6 critical safety systems was unidirectional. It was a 7 hardware data diode, as well as the communication from 8 a network out to the rest of the world. And those 9 were data diodes.
10 So I'm saying right now you've got data 11 diodes going out to the rest of the world. But the 12 internal plant stuff, when you do a new digital 13 systems for protection and safeguards, or any other 14 system, even a reactor, you know, reactivity control 15 system upgrade, you certainly do not want that. And 16 it will be digital. If they upgrade it, it's just the 17 way it's going to happen.
18 MR. BENNER: Yes.
19 CHAIR BROWN: You don't want that 20 communicating bidirectionally with the outside world 21 or even an internal network that's connected to the 22 outside world.
23 MR. BENNER: Yes. And I --
24 CHAIR BROWN: That --
25 MR. BENNER: -- I think in a number of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 1 those cases we have had other mechanisms that have --
2 if there is an area where bidirectional communication 3 that we feel the hazards are not able to be managed, 4 we have limited it to unidirectional communication --
5 CHAIR BROWN: Okay --
6 MR. BENNER: -- but not necessarily a data 7 diode.
8 CHAIR BROWN: Well, if it's a software-9 based unidirectional, then it's just as susceptible as 10 a bidirectional.
11 MR. BENNER: Okay. I will have to get 12 into those on the individual reviews.
13 CHAIR BROWN: No, exactly. That's my 14 point. With the argument --
15 MR. BENNER: Yeah.
16 CHAIR BROWN: -- that there's not a safety 17 gap, oddly there still is. If I was asked in a public 18 session, I would say that.
19 So I don't tend to not agree. I don't 20 totally disagree, because there obviously have been 21 some corrective actions or there is things done to 22 address that. But it's not -- our approach has been 23 more all-encompassing as opposed to applying it to 24 just new design certifications.
25 So I've got a little bit of concern with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 1 the delay. The defense-in-depth is a very, very 2 critical section of this. And the application of any 3 digital systems are -- the architectures, the main 4 thing, the problem is when you do introduce 5 vulnerabilities both in, you know, the how do you make 6 sure you've got good high-quality software.
7 And the second is how do you make sure 8 nobody can access it and change it in a detrimental 9 manner. That control of access is a major 10 vulnerability that we have grave concerns on as we 11 stated.
12 So I guess this is going to be subject for 13 more discussion. But I just wanted to make sure I 14 made those points. And I understand yours. And --
15 MR. BENNER: We do understand your views.
16 And I think at, you know, at bottom, we're aligned on 17 the underlying concerns and try to manage those 18 concerns. And I think it will need to -- we'll, you 19 know, we'll hopefully, as we work through this, you 20 know, case by case, we'll refine them.
21 Those are some of the lessons learned 22 we've talked about that, you know, ultimately would be 23 factored into both our guidance and our engagement 24 with any of the standards organizations.
25 CHAIR BROWN: But right now it's not in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 1 BTP 7-19, because it is a defense-in-depth issue. And 2 it's not covered in 1.152, which is the application of 3 computers and I think, and safety systems. I've 4 forgotten the whole title.
5 But, anyway, that is a -- I learned a 6 lesson back in my old naval nuclear days is -- and 7 Rickover used to rip your head off. Don't tell me how 8 you're doing everything just right. Where is it 9 documented? And where do you have the guidance for 10 people to know what they should be looking at?
11 And if you didn't, couldn't come back and 12 say we're fixing that spec or that regulation or that 13 design document, you didn't get very far without 14 having your tail on fire. So, and the other four-15 stars were no more happy than he was.
16 So the point here is to make sure those 17 things are on the table and that they are considered 18 as part of the defense-in-depth. And it's not there 19 right now. And waiting five years to put it in seems 20 to me, in my own mind, with other potential upgrades 21 coming in, that's where it's critical now.
22 It's the internal application from high 23 safety to low safety or non-safety systems that you 24 have to be careful internal of the plant, even though 25 you've take care of the data diode on the internal to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 1 external in the operating plants, depending on where 2 the data goes.
3 MR. BENNER: And understood. And I will 4 say from, you know, the tasking we had focused on 5 raising awareness for applicants. So I'm going to 6 steal a little of Jeanne's thunder, that we are 7 intending to have a subsequent workshop on licensing 8 lessons learned. And so we're going to commit to 9 overtly discuss that independent review team and the 10 tasking.
11 So, even in advance of us making the 12 changes to the guidance, we're going to discuss that 13 topic with the stakeholders who would be coming in, 14 both new reactor and operating reactor, to make them 15 aware, and again, you know, make them aware of the 16 concern and how it, you know, needs to be addressed.
17 So, again, you know, some of this is just 18 going to play out in the individual reviews as we do 19 them.
20 MEMBER MARCH-LEUBA: Charlie, can I add 21 something to your position?
22 CHAIR BROWN: Sure, yeah, sure thing, 23 Jose. Go on.
24 MEMBER MARCH-LEUBA: This is Jose.
25 CHAIR BROWN: Yeah, go on.
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36 1 MEMBER MARCH-LEUBA: Yeah, let me get at 2 it from a different point of view. Almost a couple 3 weeks ago reviewing a bulletin issued by NIST. NIST 4 keeps a database of vulnerabilities. The number was 5 2021-14444.
6 A couple weeks ago, NIST identified 40,000 7 vulnerabilities this year. That's 200 vulnerabilities 8 a day. Of course, this is for everything in the 9 world, Windows, Mac, embedded system, microwaves, but 10 still 200 vulnerabilities a day.
11 And these aren't the ones from the good 12 hackers. Those are the ones that get reported, 13 correct? There are innumerable number of 14 vulnerabilities that are kept secret, especially by 15 state actors.
16 If you do a search on NIST on VPN 17 vulnerabilities, which is how all these communications 18 are established, on average you get a vulnerability on 19 a VPN system discovered once every three days. Okay.
20 Any licensee that comes and tells you we 21 have a software driven firewall that cannot be 22 penetrated, you should just laugh in their face.
23 That's insane. And it's completely indefensible in 24 view of these statistics.
25 So, whenever you review these things and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 1 you say that it's not a safety system, they're going 2 to tell you how a VPN is a very strong connection, 3 everything is encrypted. And you say, yeah, how long 4 is it going to be until a North Korean hacker breaks 5 into it. I guess --
6 MR. BENNER: But this is --
7 MEMBER MARCH-LEUBA: I want to thoroughly 8 support Charlie's position. And my statement is 9 anybody that tells you that you can protect an 10 internet connected software device, you should laugh 11 in their face. It's indefensible. Okay. That's it.
12 MR. BENNER: Yeah, but I think we keep 13 crossing these issues of the barrier to the outside 14 world and then communications within different 15 echelons within that barrier.
16 So I don't want to say anything more about 17 that, because I don't think any of us saying that a 18 VPN is the right barrier from a cyber protection 19 standpoint. So --
20 CHAIR BROWN: Let me make one observation 21 to you, Eric, relative to Jose's comment. I 22 understand the connection to the outside world, as 23 Jose was addressing.
24 But when you get down to it, say you've 25 got an internal reactor protection system. It's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
38 1 software based. But you need to make software 2 upgrades.
3 And sometimes you will find errors, not 4 common cause failure, nothing like that, just in the 5 process of operating -- that doesn't look right. Why 6 did that happen? And the vendor goes back and says, 7 oh, we've got a little software glitch. We can fix 8 that with a software modification.
9 Now the question comes up is, how do you 10 do that. Well, people have commented, oh, that's 11 easy. We'll transmit it to you, to your facility via 12 the internet. And you can then download it. Okay.
13 Or we can send it directly via a one-time 14 only connection as being implemented or espoused 15 potentially in the Rev. 5.71, a one-time only 16 permission granted to let the internet connect to the 17 internal plant and download that software into your, 18 whatever the system is, reactivity control, reactor 19 protection, safe -- whatever it is. That is the type 20 of thought process that can kill you -- you just don't 21 want to have that.
22 The other way is to put it, fine, now I'm 23 not going to do that. I'm going to bring it in on a 24 CD, which I will put onto a laptop. And I can plug it 25 into, you know, the equipment and download it.
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39 1 Well, what's the vulnerability there? Now 2 your laptop should not have anything else on it ever, 3 because it may have been connected to the internet at 4 some point. You have -- it becomes a piece of 5 critical test equipment like your high calibration 6 voltmeters, ammeters, frequency generators, 7 oscilloscope, whatever it is you use to calibrate 8 analog stuff with.
9 It is now your prime instrumentation. And 10 you can't have any other application code. And you 11 can't ever let it be downloaded. The only way you can 12 protect yourself somewhat is a DVD with no other 13 information. Okay.
14 So there's a lot of things to think about 15 in this, in that once you bring something into the 16 plant, it's not just that.
17 And we noted that in the letter. It was 18 high to low safety significance. The lower safety 19 significance would be the laptop, or it could be a 20 maintenance cabinet that's built in the designs, which 21 some of the new design applications have. How do you 22 get the upgrade into that before you put your cable in 23 to connect it to the system?
24 That's why this unidirectional thought 25 process cannot be just covered, quote, because there NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 1 is no cyber security system within the systems in the 2 plant. You can't have them.
3 Nobody in their right mind would put a 4 cyber security virus protection software into a 5 reactivity control or a reaction protection system.
6 You can't predict its performance under those 7 circumstance.
8 So you're vulnerable because it is 9 literally sterile equipment relative to cyber. You 10 can only protect it by not allowing access or very, 11 very strongly controlled access.
12 We need to move on. I just -- but it's 13 been a good discussion --
14 MR. BENNER: And it is. And I think 15 because it is, it treads both on cyber, which, you 16 know, there are programmatic requirements there. But, 17 Member Brown, as you point out, there's stuff inside 18 that really isn't cyber. And that is more the purview 19 of the secured development operating environment.
20 And, you know, I will say these concerns 21 about, yes, someone brings a laptop in, someone brings 22 a thumb drive in, you know, that there are controls 23 that licensees have to put in place to control how 24 that happens.
25 And like you've alluded to, you know, some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 1 of this is dedicated maintenance workstations where we 2 have the controls there for that piece of it. So, 3 again, you're right. I don't want to belabor the 4 point. I think we share some, you know, similar 5 beliefs as to how, that this does need to be 6 controlled.
7 And, you know, like I said, where it will 8 play out is in the individual licensing reviews. And, 9 you know, ultimately we will update the guidance to 10 reflect that.
11 MEMBER REMPE: So this is Joy. And I 12 appreciate what you're saying about the need to move 13 on.
14 But, Eric, wouldn't it, in light of the 15 spirit of trying to be an effective, Be RiskSMART 16 regulator, wouldn't it be more effective to just 17 update it sooner than later considering what the 18 process is you're envisioning versus what it could be?
19 MR. BENNER: If I had infinite resources, 20 I would love to.
21 MEMBER REMPE: Okay.
22 MR. BENNER: I don't. And I now have 23 licensing work that is essentially going to consume 24 many of my resources.
25 Now, the update to Reg -- I'm getting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
42 1 ahead of myself, and Jeanne was going to get here.
2 The update to Reg Guide 1.153 was already scheduled.
3 That's a fairly heavy lift because of the detail, or 4 I should say Reg Guide 1.152 for IEEE 7432.
5 That's a pretty detailed standard. The 6 standard is out there. And the NRC participated in 7 the working group that developed that standard.
8 So, you know, the fact that licensees are 9 likely going to use that standard, even in advance of 10 us doing the formal endorsement of that standard, that 11 information is out there.
12 So infrastructure ends up taking a 13 backseat to actual licensing and oversight work. And 14 the IAP was focused on the near-term, key 15 infrastructure updates that needed to be done.
16 And as I alluded to, most of those are 17 done. And the remaining infrastructure updates are on 18 a schedule that aligns with the fact that they are 19 more routine updates and that the priority of those is 20 lower than the incoming licensing work.
21 And that's just my reality of I have a 22 limited number of resources to do all these things 23 people would like me to do. And I do want to make 24 sure that I have the right people and the right number 25 of people on something like Turkey Point so we do a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 1 robust technical review.
2 I will reiterate that, in advance of us 3 doing guidance documents, we continue to have 4 workshops to communicate with licensees who are 5 considering doing these upgrades so they're aware of 6 lessons learned both from previous reviews and the 7 reviews we're going to do now.
8 And that, I mean, that's where we're at 9 from a balancing, you know, workload with priorities 10 standpoint.
11 MEMBER REMPE: Okay. Thank you.
12 CHAIR BROWN: We will go ahead. And I 13 agree with Joy by the way. We had the opportunity to 14 get it into 7-19, and it didn't get in. That's 15 fundamentally why we ended up where we are today as 16 you're aware. Can anybody hear me, or am I dead?
17 MS. JOHNSTON: No, we can hear you --
18 CHAIR BROWN: Oh, okay. I thought --
19 everything, nothing was moving on my screen, which is 20 very unusual. Okay. Jeanne, this will be open for 21 more discussion or more opportunities for discussion, 22 let's put it that way.
23 MS. JOHNSTON: Okay.
24 CHAIR BROWN: We do have 5.71 coming up, 25 Eric. So you can imagine that's going to be a robust NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 1 meeting to say the least.
2 MS. JOHNSTON: Understood. If there are 3 no further questions on this slide, I think we can 4 move on.
5 CHAIR BROWN: Oh, absolutely. Get moving.
6 MS. JOHNSTON: Okay. All right.
7 CHAIR BROWN: Sorry about that.
8 MS. JOHNSTON: Okay. So we're not done 9 with common cause failure yet. We are still 10 continuing our work to address common cause failure.
11 Over the past year, we have been engaging 12 with NEI and presubmittal activities to discuss 13 proposed guidance and what they call NEI 20-07 for 14 addressing software common cause failure in high 15 safety-significant safety-related digital I&C systems.
16 We are expecting a new draft version of 17 this guidance to be submitted at the end of this 18 month, so at the end of September. And the new 19 version is going to supersede previous drafts that 20 we've been reviewing. And it's going to, it's 21 expected to adopt a risk-informed approach.
22 And we have not received the new draft D 23 yet. But we are anticipating a need to evaluate if 24 our current common cause failure policy, which is in 25 the SRM to SECY 93-087, if that needs to be updated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 1 before a potential endorsement of 20-07 could occur.
2 So we don't have the official submittal in 3 house yet. So we don't have a lot of the details.
4 But we have been having pre-submittal discussions.
5 And the last public meeting was July 1 of this year.
6 CHAIR BROWN: We will be interested in 7 seeing this obviously.
8 MS. JOHNSTON: Okay. Any other questions 9 on 20-07?
10 CHAIR BROWN: Was I clear? You said --
11 MS. JOHNSTON: Yes, yeah, yeah, we got the 12 message. You want to see this. And we are still, you 13 know, doing the, you know, the review. We haven't 14 even started the real technical review yet. We're 15 still in pre-submittal space right now.
16 But when we do get to the point of 17 potentially endorsing it, if it is acceptable, a 18 regulatory guide might be the vehicle that we choose.
19 And you will absolutely be made aware of opportunities 20 to review that later down the road.
21 CHAIR BROWN: Is this the first, is this 22 Rev. 0 of 07 by the way?
23 MS. JOHNSTON: So we're in draft. We're 24 in draft space.
25 CHAIR BROWN: But this is new.
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46 1 MS. JOHNSTON: Yeah, this is new.
2 CHAIR BROWN: The RIS, didn't RISs cover 3 this before? Didn't we have some RIS that covered 4 common cause failure clarifications on how to -- blah, 5 blah. I can't remember --
6 MS. JOHNSTON: Yeah.
7 CHAIR BROWN: -- all the RISs that I've 8 seen.
9 MS. JOHNSTON: Yes, we did supplement.
10 One was a RIS for focusing on 50.59 modifications. So 11 --
12 MR. BENNER: And that was for low safety 13 significance issues.
14 CHAIR BROWN: Yeah, that's right. I 15 remember now. Thank you for helping me with that.
16 It's been a while. Okay. Go on, Jeanne. I'm, 17 Jeanne, I'm --
18 MS. JOHNSTON: Yeah, so these would be the 19 high safety-significant systems that would go hand in 20 hand with a license amendment.
21 CHAIR BROWN: Okay. Thank you.
22 MS. JOHNSTON: So the new approach would 23 be an alternate method, which is currently allowed by 24 BTP 7-19. So we are just standing by to evaluate any 25 potential policy changes that may be necessary to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 1 support a formal endorsement of this guidance.
2 CHAIR BROWN: Okay.
3 MS. JOHNSTON: Okay?
4 CHAIR BROWN: Yep.
5 MS. JOHNSTON: If no further questions, we 6 can move on.
7 CHAIR BROWN: Yes, go ahead.
8 MS. JOHNSTON: Okay. We are also 9 continuing work on NEI 17-06, which would be a 10 potential reg guide if we find this guidance from NEI 11 acceptable for a commercial grade dedication of 12 digital equipment.
13 And NEI 17-06 provides guidance on 14 procuring and accepting commercial grade digital 15 equipment for nuclear safety-related applications when 16 that equipment has received a Safety Integrity Level, 17 or SIL, certification in compliance with an IEC 18 Standard 61508, functional safety for 19 electrical/electronic safety-related systems.
20 So, according to this guidance, the 21 dedicating entities could rely on the SIL 22 certification process in lieu of conducting a 23 commercial grade survey to provide reasonable 24 assurance that dependability, critical characteristics 25 are adequately controlled.
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48 1 And we are in the process of reviewing 2 this new guidance. It was submitted in February. And 3 if we find it acceptable, we will start the regulatory 4 guide process at the end of this year.
5 So, according to the reg guide process, 6 the ACRS would be notified of an opportunity to 7 review. And I think the soonest would be middle of 8 next year, maybe in April or May, depending on when we 9 can start the comments, the public comment process.
10 CHAIR BROWN: We would probably pretty 11 much want to see this as a first of a kind. It also 12 addresses a critical issue for the -- typically, this 13 commercial grade dedication means the computer 14 function like the platform, like Common Q for instance 15 I guess.
16 And when your commercial systems, they try 17 to sell those to a lot of different people. And they 18 have lots of functions in them. So there's lots of 19 opportunities for vulnerabilities to exist in the 20 hacker world. So that really needs to be thoughtfully 21 done.
22 I'm just bringing that up because it's 23 something you all need to do, because the vendors, you 24 don't have custom software. It's, they're using other 25 people's operating systems. Understand that, that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 1 that makes it even more important to pay attention.
2 So you can go on.
3 MEMBER HALNON: Hey, Charlie, this is 4 Greg, real quick. Did you say this is just software, 5 or is it hardware as well --
6 CHAIR BROWN: No, it's hardware as well.
7 It's a combination. They build a platform. It's got 8 all the computing capability.
9 But they've got an operating system embedded in it.
10 MEMBER HALNON: Okay. Is counterfeit 11 issue involved with this at all?
12 CHAIR BROWN: Yes and no. I mean, 13 somebody could -- once something's out and they know 14 it's good, it could be counterfeited I guess. I mean 15 --
16 MEMBER HALNON: So I guess back to Jeanne.
17 Is that part of this, is to protect us against 18 counterfeit, the counterfeit issue that we had a 19 couple, three years ago?
20 MS. JOHNSTON: I'm going to call on my 21 staff lead, Dinesh Taneja. If he could -- if he's on 22 the line, if he could step in to address that 23 question.
24 MR. TANEJA: Yes, hello. This is Dinesh 25 Taneja. The SIL certification process -- so right NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 1 now, the way we do commercial rededication of digital 2 equipment is the dedicating entities use the EPRI 3 TR-106439 guidance, which we endorsed back in 1990.
4 So part of that review -- the supply chain is looked 5 at by the dedicating entities of a manufacturer's 6 product. And IEC 61-508 also goes and does a deep 7 dive into looking at what the supply chain was and how 8 that was controlled in the equipment development.
9 So the difference is that the IEC 61-508 10 certification is done to equipment that is uniquely 11 designed for safety-critical applications -- not just 12 for -- it's not specific to nuclear industry. It is 13 designed for pharmaceuticals, petrochemicals, and 14 everywhere else. So it is -- cyber is a big concern 15 and I believe that is evaluated as part of that SIL 16 certification process.
17 MEMBER HALNON: Okay. So there is -- I'm 18 sorry, what you're saying -- it's already in the 19 process. It's nothing new in the 1706, then?
20 MR. TANEJA: No -- no, nothing new.
21 MEMBER HALNON: Okay, thank you. You can 22 go ahead, Charlie. Appreciate it.
23 CHAIR BROWN: Okay, thank you Greg. Go 24 ahead Jeanne.
25 MS. JOHNSTON: Okay, we can go to the next NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 1 slide. Okay, so -- so the NRC did endorse an EPRI 2 technical report guideline on evaluating -- evaluation 3 acceptance of commercial-graded digital equipment in 4 1997. And the proposed Reg Guide -- if any I-1706 is 5 found acceptable -- would really complete the story 6 and provide durable guidance.
7 (Simultaneous speaking.)
8 MS. JOHNSTON: Somebody is not on mute. So 9 we are continuing to engage with NEI to validate the 10 process by which the third-party certification becomes 11 accredited. And there is also an existing reg guide 12 -- Reg Guide 1.164 -- that's also going to be 13 referenced in the new reg guide. And it's where --
14 we're hoping that the -- the new reg guide would, you 15 know, provide a wholesome landscape that kind of ties 16 the whole story together. And the -- like, I think I 17 mentioned it previously -- we're expecting, if it 18 stays on track, the public comment period to occur in 19 May of next year. And if ACRS would like a briefing 20 for that before the public comment period, that would 21 be April time frame. And so we can certainly work 22 with your staff to arrange for that.
23 CHAIR BROWN: Okay, thank you.
24 MS. JOHNSTON: Okay. We can go on to slide 25 11. We -- now I am going to talk about reg guides.
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52 1 So we do -- we are continuing to strategically update 2 other infrastructure, mainly key regulatory guides, to 3 improve the clarity and cohesiveness of the guidance.
4 And we plan on doing this by endorsing more recent, 5 more relevant, code and consensus standards. And --
6 and by updating certain reg guides and consolidating 7 them to allow for more effective navigation and use of 8 the available guidance.
9 So the -- the two reg guide activities 10 that are currently on the horizon are Reg Guide 1.152 11 -- this is the guide that endorses IEEE 7432. And the 12 proposed revision would endorse the latest revision --
13 or the 2016 version of that standard. And it would --
14 we're also planning to incorporate new guidance to 15 address some of the things we were talking about 16 previously with the Secure Development and Operational 17 Environment, SDOE. And --
18 (Simultaneous speaking.)
19 CHAIR BROWN: My suggestion -- real quick.
20 The SDOE -- people keep talking -- but that's largely 21 a vendor. Secure Development Operation Environment --
22 that's not an in-plant type thing, from all the 23 previous discussions I remember from years ago. Am I 24 out to lunch on that? Or what? That's when vendors 25 are buying something that you guys certify that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 1 applicant has selected a vendor that has a secure 2 development operating environment for developing of 3 software. Carefully crafted comments are made. It's 4 logged in and all that kind of stuff. Am I correct in 5 that?
6 MS. JOHNSTON: I think -- I think -- I 7 think it's -- it covers both of those aspects.
8 CHAIR BROWN: How does -- how does the 9 applicant -- how does the plant itself get involved in 10 that? I -- I'm a little surprised at the -- you --
11 the applicants would have a large software development 12 staff for most of these systems. Greg, am I out to 13 lunch on that? Can --
14 MEMBER HALNON: It's growing, Charlie. You 15 know, the more -- we get more digital in the industry, 16 I think the -- the staff is growing and -- and -- as 17 the -- the politically incorrect way is the older guys 18 are -- older and more experienced people are moving 19 on. The younger folks coming in have a different 20 skill set. And I think that -- I think it's growing.
21 So I -- I'm not sure if it's to the extent of what 22 you're saying, but there is quite a bit of -- for 23 instance, it used to be that PRA staff was one or two 24 people. Now there's whole departments. So it's --
25 it's growing.
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54 1 CHAIR BROWN: Yes, I could see that idea.
2 So I'm -- I'm just remembering back about -- I don't 3 know, eight or nine -- ten years ago when we were 4 doing this we talked about the Secure Development 5 Operating Environment. It was largely vendor for NRC 6 to -- to make sure that the applicant had selected --
7 but I understand your point about, as the world 8 changes, I -- obviously the licensees are going to 9 have to change also for certain types of things.
10 MEMBER HALNON: Right, the cyber ruling 11 itself put full departments in play at many utilities.
12 CHAIR BROWN: Yes, okay.
13 MS. JOHNSTON: So -- but reg guide 1.152 14 covers both the vendor development and the licensee's 15 operational environment -- when it's installed and how 16 it's connected at the site.
17 (Simultaneous speaking.)
18 CHAIR BROWN: Okay.
19 MS. JOHNSTON: And going back -- you know, 20 there are safety and security interface issues that we 21 are aware of. We're continuing to collaborate and 22 team up with our colleagues in NSIR. My understanding 23 is that the counterfeit issues of -- those are part of 24 a supply chain, risk management -- that's addressed as 25 part of the cyber security aspect. And our safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 1 review would focus on the secure development and --
2 operational environment. And we are going to address 3 the feedback that was given as part of BTP 7-19 and 4 the inter-directional communication in this next 5 revision. So we will address the clarification. It 6 will -- you know, it is guidance. It falls short of 7 being a requirement. But it is -- the clarification 8 is intended to raise awareness of one approach that is 9 available to an --
10 (Simultaneous speaking.)
11 CHAIR BROWN: In your process of doing 12 that, it ought to -- it -- while it -- a reg guide 13 never makes anything a requirement. It's always 14 guidance.
15 MS. JOHNSTON: Yes.
16 CHAIR BROWN: We understand that. But the 17 words make a difference -- in the reg guides, and-or 18 the BTP, as they -- as we used in the design review 19 guide, the -- the non-light water reactor. Which is 20 really applicable to everybody. Words not as an 21 option, it should be the words like, preferred. It --
22 the -- the NRC ought to make it clear that the 23 preferred way is -- as stated in part -- in parts of 24 5.71, high safety to low safety should be uni-25 directional. It should be hardware. It's right in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
56 1 7.5 -- 5.71. So it just needs to be emphasized 2 because people lose sight of that. They don't look at 3 5.71 until, you know, equipment is delivered five, ten 4 years later. So it's part of the -- part of the 5 design ought to be, you know -- that's where you 6 should be using that thought process as well. That's 7 what we're trying to get to.
8 (Simultaneous speaking.)
9 MS. JOHNSTON: Okay --
10 CHAIR BROWN: The words make -- the words 11 make a difference.
12 MS. JOHNSTON: Understood. And we -- we 13 will take that into consideration. Also, we'll 14 continue to work with our colleagues in NSIR. As you 15 know, reg guide 571 is also -- it's in the process of 16 being updated. And the -- the workshops that we're 17 planning on having with our stakeholders is another 18 opportunity to raise awareness that system designers 19 and vendors should be thinking about cyber security.
20 And they should be thinking about these things --
21 (Simultaneous speaking.)
22 CHAIR BROWN: It's not -- let me -- let me 23 help you. It's not cyber security. It's control of 24 access.
25 MS. JOHNSTON: Control of access.
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57 1 CHAIR BROWN: It's control of access. Of 2 course, there is no cyber security functions inside of 3 all of these systems. The protection systems 4 safeguards one control -- or reactivity control.
5 Starting -- even the controllers -- computer-based 6 controllers starting in the operating plants, starting 7 safeguards pumps through operating valves if they 8 change those out. I don't know why they would, but 9 maybe they -- maybe they do. That is -- that's the 10 point of the whole thing -- is control of access. In 11 the analogue world there was no access. Digital world 12 -- there's infinite access if you're not careful. So 13 it's control of access because there -- you can't put 14 cyber security software into a -- a safeguards pump 15 control unit and all of the sudden have it not open 16 when you're supposed to.
17 MS. JOHNSTON: Understood.
18 CHAIR BROWN: Or you can't update it all 19 the time. You can't have access coming from the 20 outside world, or even from the inside world. You 21 never know how malware is going to get in there.
22 Anyway, okay -- I've preached enough on that. You --
23 it's control of access. That's the point.
24 (Simultaneous speaking.)
25 MS. JOHNSTON: Okay -- message -- message NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 1 received.
2 CHAIR BROWN: It's not cyber security.
3 We've tried to say that over and over again. People 4 keep --
5 MS. JOHNSTON: Okay.
6 CHAIR BROWN: -- they haven't been 7 listening. No, I take that back. They've been 8 listening. We're not communicating.
9 (Laughter.)
10 MS. JOHNSTON: Okay, so I think we -- we 11 covered that topic sufficiently. So -- so the --
12 going to status for this reg guide update, as you can 13 see there's a lot of technical objectives that we wish 14 to accomplish in the next revision. And we -- we 15 don't have infinite staff resources here. So the --
16 the current plan is to work on this draft guide and 17 provide a -- you know, really initiate the reg guide 18 process next year, in 2022. And then that would put 19 the comment period and potential ACRS review in the 20 2023 time frame. And we will certainly keep you 21 engaged of what the schedule turns out to be and --
22 and provide it for opportunity for review.
23 CHAIR BROWN: Yes, I'd like to do this 24 before I die.
25 MS. JOHNSTON: Well --
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59 1 (Laughter.)
2 CHAIR BROWN: That's just a little humor.
3 (Laughter.)
4 CHAIR BROWN: -- humor, okay.
5 (Simultaneous speaking.)
6 MS. JOHNSTON: Stay healthy.
7 CHAIR BROWN: I'm working on that. Go 8 ahead.
9 MS. JOHNSTON: Flu season is coming up.
10 CHAIR BROWN: Yes.
11 MS. JOHNSTON: Okay, so the other reg 12 guide, which is I would say behind Reg Guide 1.152 as 13 far as schedule goes, is Reg Guide 1.168 for software 14 verification validation. So we are considering 15 adopting a graded approach alternatives towards 16 specified software integrity level guidance. This is 17 different than the previous SIL which is safety 18 integrity level for 1706. This is different -- same 19 acronym, different meaning. Not to confuse anybody.
20 But this reg guide endorses an IEEE 21 standard 10-12. And we would be potentially endorsing 22 the 2016 version of this standard. And it's a -- it 23 would also be a change in how we're endorsing this 24 standard. Because currently we -- we have everything 25 -- sorry, I'm just gathering my notes. Current -- the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 1 current guidance endorses and approach to assign all 2 safety systems the highest SIL level, which is SIL 4, 3 and the proposed -- what we're proposing is to see if 4 we could assess -- if we could apply a graded approach 5 for the software integrity levels. So -- so not 6 everything would necessarily be a software SIL 4 and 7 that we could -- licensees could take advantage of the 8 different gradation of V&V activities. We are also --
9 (Simultaneous speaking.)
10 CHAIR BROWN: Let me -- go ahead.
11 MS. JOHNSTON: Okay.
12 CHAIR BROWN: No, go ahead. No, let's --
13 MS. JOHNSTON: Okay, we're also considering 14 the feasibility of consolidating other software 15 criteria that reside in other reg guides. And I have 16 those listed here. And that's really in an effort to 17 simplify what can be perceived as a really complicated 18 and, you know, not clear regulatory guide structure if 19 applicants and vendors have to go to several different 20 places to get the guidance that they need. So we're 21 -- we're considering in this next revision to also 22 consolidate the guidance that exists in other 23 software-related reg guides.
24 CHAIR BROWN: Observation is that I guess 25 the graded approach would then be available for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 1 software development for safety systems, like reactor 2 protection, reactor trip safeguard systems?
3 MS. JOHNSTON: Yes.
4 CHAIR BROWN: The -- I'll just give you an 5 observation. One -- in the -- we still had a 6 requirement or problem even with the safety -- the 7 high safety level. I mean, the possibility of data 8 corruption -- getting out and then locking up 9 processors -- is lowered if you have a much higher 10 level integrity software system -- evaluation system, 11 or integrity level. But once you start reducing it 12 to, well, we won't be quite as rigorous. That just 13 increases the chance that the programmers who love to 14 program, or you'll have more potential for corruption 15 of data. And corrupt data has the strong potential 16 for locking up processors, which increases the 17 importance of the watchdog timers that are put on the 18 processors in these systems. So it's -- if they lock 19 up, they trip, particularly in the safety -- in the 20 reactor protection system you trip, and in the 21 safeguards you provide an alarm. Because a single 22 channel within a redundant system can then lock up 23 every voting unit. I'm just saying that there's a 24 combination of things here. We had arguments about --
25 if I go back ten years, one of the hard -- one of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 1 watch dog timers was actually a software-based timer 2 on the platform itself. And that was ridiculous. It 3 had to be an independent hardware base with its own 4 power supply -- watchdog timer. So I'm -- I'm just --
5 something you need to consider when you go to a graded 6 approach -- how does that affect the basic design?
7 The architecture of the systems? And that ought to be 8 talked about if you're going to go to this graded 9 approach.
10 It increases the level of attention over 11 and above what -- even I would think, okay, in terms 12 of the basic architecture. Because that's where your 13 basic safety is and the redundancy and independence --
14 deterministic in the defense and depth and diversity 15 aspects. And control of access. Just makes that more 16 important. That's just a thought -- something you got 17 to keep in mind because, when we see this, we will be 18 -- at least if I'm still here -- or, still alive -- we 19 will be addressing that thought when we go through 20 this as to how you address that in this -- in this 21 update.
22 MS. JOHNSTON: Okay, understood. Thank you 23 for that feedback.
24 CHAIR BROWN: Just a comment, okay? All 25 right, go on to the next slide.
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63 1 MS. JOHNSTON: Okay, so -- I just wanted to 2 quickly cover here before we move on --
3 CHAIR BROWN: Okay.
4 MS. JOHNSTON: Previously we did have Reg 5 Guide 1.153 on the schedule. We were on the 6 subcommittee's calendar for October. But we've since 7 then had to withdraw from that meeting because we are 8 reevaluating whether or not the -- a regulatory guide 9 is the best vehicle or approach that -- just wanted to 10 address that in case there are any questions for why 11 that kind of dropped off of the -- the horizon as far 12 as reg guide updates goes. So the Reg Guide 1.153 13 endorses IEEE 603, which is -- the 1991 version is 14 incorporated by reference in our requirements and we 15 had intended on updating that to endorse the 2018 16 version of 603. But right now we -- we're heading 17 back to the drawing board on that and we're evaluating 18 the path forward for that so we don't have very much 19 at this meeting to share with you.
20 CHAIR BROWN: Okay, let me ask a question.
21 Back several years ago there was a proposed rule 22 change to 10 CFR 50.55-A-H.
23 MS. JOHNSTON: Yes.
24 CHAIR BROWN: I think if 603-1991 is 25 invoked in the rule --
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64 1 MS. JOHNSTON: Yes.
2 CHAIR BROWN: -- if my -- if my memory is 3 correct. And so changing 1.15 -- 1.53 -- I -- one 4 time I looked at one of the -- a variation between 5 1991 whenever we tried to do a -- and the commission 6 rejected the change to the rule to update 1 -- the --
7 to provide clarifications for 1991 version of 603 in 8 the rule. And now 1.153 -- if you go to a 2018 9 version, I remember looking at an earlier revision of 10 that and there were -- we lost something. 1991 was 11 actually better than the more current revision.
12 MS. JOHNSTON: Right. I think what you 13 were maybe referring to is the 2009 version of IEEE 14 603?
15 CHAIR BROWN: Yes.
16 MS. JOHNSTON: Okay, so there were a number 17 of conditions and issues that came up with that 18 previous rulemaking, as you recall correctly, and the 19 staff -- we worked with the industry to resolve those 20 issues, both -- and the resolution resides in the 2018 21 version of 603 and 7432, which is in a different reg 22 guide -- is Reg Guide --
23 (Simultaneous speaking.)
24 CHAIR BROWN: But 7432 does not really say 25 the same things that 603 does. It covers the areas --
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65 1 MS. JOHNSTON: Yes.
2 CHAIR BROWN: They're complimentary in some 3 respects.
4 MS. JOHNSTON: Right.
5 CHAIR BROWN: The point is because 2008 --
6 we -- it was so -- there was enough problems and 7 differences between the 1991 version that we had a 8 whole bunch of clarifications and exceptions that we 9 were going to invoke to part of the rule. And I guess 10 the commission decided, no, we're not going to do 11 that.
12 MS. JOHNSTON: Right.
13 CHAIR BROWN: And you all took that on 14 board and you're saying all the issues to try to 15 resolve that -- those problems hopefully are now in 16 the IEEE 2018 version of 603?
17 MS. JOHNSTON: Yes, that's -- that's 18 correct.
19 CHAIR BROWN: Okay.
20 MS. JOHNSTON: I believe the -- the outcome 21 of that -- of those differences that came to light 22 during the previous rulemaking we -- were addressed 23 during the subsequent IEEE Consensus Standard. And 24 there -- an update of that standard. And that's in 25 the 2018 version. So the -- we want to -- you know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
66 1 that's the -- that's the version that -- that we 2 participated in and that -- you know, resolves many of 3 the -- the past issues that you're alluding to in the 4 previous rulemaking.
5 CHAIR BROWN: Okay.
6 MS. JOHNSTON: So -- I have to provide some 7 clarification.
8 (Simultaneous speaking.)
9 CHAIR BROWN: No, no -- that's -- that was 10 actually -- I'm glad you did that, thank you.
11 MS. JOHNSTON: Okay. All right, and just 12 wanted to clarify, it's -- the 2018 version doesn't 13 fully -- doesn't address everything. Some of the 14 other resolutions reside in -- elsewhere. Like the --
15 the other IEEE standard, 7432. So it's a combination 16 of those two standards where the -- the whole picture 17 resolves, is --
18 (Simultaneous speaking.)
19 CHAIR BROWN: Okay. Obviously we will want 20 to be involved in that.
21 MS. JOHNSTON: Yes, understood. Yes. And 22 like I said, we are kind of back to the drawing board 23 is where we're -- we are reevaluating if our reg guide 24 is really the -- the right vehicle to do what we want 25 to do as far as encouraging --
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67 1 (Simultaneous speaking.)
2 CHAIR BROWN: As opposed to -- as opposed 3 to a rule change?
4 MS. JOHNSTON: Right.
5 CHAIR BROWN: Rule changes are tough.
6 (Simultaneous speaking.)
7 MS. JOHNSTON: Yes, I know. Yes, I may not 8 be alive for a -- for a rule change. But it -- we are 9 -- you know, we are reevaluating what options we have 10 available and what -- also considering the resources 11 and competing priorities that -- that are in front of 12 us -- what we want to focus on over the next few 13 years, so --
14 CHAIR BROWN: Okay. Well the -- that's a 15 key -- key point because 603-1991, the control of 16 access is -- back in those days, was analogue -- it 17 was largely physical control. Who you let in and who 18 you didn't let in. Who you allowed to touch it, who 19 you didn't. Now that's a different world with the 20 digital stuff. So -- all right, I'll let you go on to 21 your next slide. I appreciate your -- going through 22 that.
23 MS. JOHNSTON: No problem, thank you. Next 24 slide, please. Okay, and finally we are participating 25 in a -- a wholesale modernization effort of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 1 standard review plan. The -- it's not just Chapter 7 2 that's being modernized. The -- the Agency is 3 modernizing every chapter of the Standard Review Plan.
4 But we -- we really took this opportunity to look at 5 the current Chapter 7 and how it's organized and came 6 up with a plan to -- to consolidate some of the -- the 7 guidance and move from a system-specific structure, 8 which is the current state, to potentially a safety-9 focus and requirement-centered review guidance. And 10 so what the current guidance looks like if you -- if 11 you look at the -- the different subchapters, or 12 subsections of -- in Chapter 7 is -- there's a lot of 13 system-specific sections and the -- explain to a 14 reviewer the regulatory requirements and -- and set 15 them through on a system-specific basis. And what 16 we're proposing in the new structure is to change it 17 up to be more focused on safety and the regulatory 18 requirements. So we would be going from eight 19 sections to five sections. Also consolidating 20 information -- extraneous information that's in the 21 appendices right now. We would be relocating those to 22 the section -- the regulatory requirement sections and 23 identifying -- right now we have 17 separate BTPs. We 24 would be eliminating 13 of those BTPs. But not -- not 25 completely the information in them. We would just be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 1 moving some of the system-specific content and 2 transfer those to a different document such as an I&C 3 system review guide. Because it is -- it is good 4 information to retain and to keep available, but the 5 -- the idea here is to kind of cut out the extraneous 6 -- nice to have information and -- and to have the 7 other good information that is currently there 8 relocated there into another location.
9 So we would be going from four BTPs to --
10 seven BTPs, excuse me, to four BTPs -- including our 11 favorite BTP, 719. That would be one of the ones that 12 would potentially be kept. And we -- we think that 13 this -- the plan for the new SRP -- the modernized 14 SRP, it really takes into consideration the lessons 15 learned when we developed the NuScale design-specific 16 review standard, the DSRS, and the Design Review Guide 17 for Advanced Non-light Water Reactors.
18 And we are in -- we're still in the 19 initial planning phases for completing this work. So 20 we don't have a concrete schedule. But we will be 21 developing an action plan and prioritizing certain 22 sections. We're not going to do this all at once.
23 It's going to be coming in sections and chunks. And 24 we will definitely keep you informed of what that 25 schedule ends up looking like. And this is part of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
70 1 the SRP review schedule. So part of the process is 2 public comment and ACRS review, if desired.
3 CHAIR BROWN: It's -- it would be desired.
4 And I can save you all a lot of time. Just take the 5 existing new DRG and take away the non-light water --
6 or advanced reactor part and you've got your new 7 Chapter 7. We made that comment in our letter -- or 8 equivalent comment.
9 MS. JOHNSTON: Yes. Thank you for that 10 input.
11 CHAIR BROWN: And it's -- the DRG was a 12 development over all the DSRSs we did, which were 13 significant improvements and focused -- it's an 14 architecture-focused approach as opposed to a 15 piecemeal -- you know, look at the tires and then look 16 at the brake linings and then look at the fuel line 17 and then look at the fuel pump and then try to figure 18 out whether you've got a car or not. It's an 19 architecture-based approach to the -- Chapter 7 20 instrumentation, standard review plan approach. As 21 opposed to piecemeal.
22 MS. JOHNSTON: Yes.
23 CHAIR BROWN: And I think we made that 24 observation in our letter. I don't remember that.
25 I'd have to go back and look.
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71 1 MS. JOHNSTON: Yes. Yes -- the DRG that 2 you're referring to was issued in March of this year 3 and --
4 CHAIR BROWN: Yes.
5 MS. JOHNSTON: And we -- we did note that 6 positive feedback during that guidance development.
7 CHAIR BROWN: Okay. All right. Any other 8 questions from any other members? I think, Jeanne, 9 are you finished?
10 MS. JOHNSTON: I think I am.
11 CHAIR BROWN: Okay. Next slide is --
12 waters. However, it is now 11:00. Actually, it is a 13 little after. We'd have a scheduled break. I have a 14 dog.
15 (Laughter.)
16 CHAIR BROWN: Therefore we're going to take 17 a break for 15 minutes until 11:20. So we'll resume 18 again at 11:20 if that's acceptable to everybody?
19 (No audible response.)
20 CHAIR BROWN: No arguments? We are --
21 what's the proper -- we're in recess.
22 (Whereupon, the above-entitled matter went 23 off the record at 11:05 a.m. and resumed at 11:21 24 a.m.)
25 CHAIR BROWN: Okay. I see it's 11:21.
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72 1 And, Mike, are you ready?
2 MR. WATERS: I'm ready. Can you hear me?
3 CHAIR BROWN: Yeah, I can hear you.
4 Can everybody else hear Mike Waters?
5 MEMBER SUNSERI: Yes. This is Matt.
6 CHAIR BROWN: Okay. I'll take one 7 response as being we can all hear okay.
8 Mike, why don't you go ahead? We'll start 9 the remaining part of the presentation.
10 MR. WATERS: All right. So good morning.
11 Thank you, Charlie and the members, for being here 12 today.
13 So the ACRS, as part of this briefing, 14 asked to hear about specific license activities, some 15 that have been completed in the past and some that are 16 ongoing or will happen in the future, as well as 17 topical report reviews. So I'll jump in and go 18 through some of the key licensing activities, and then 19 Rich will finish on the topical report reviews.
20 So first, Michael, jump to the next slide.
21 Recently completed. We recently approved 22 an amended request for the Waterford Core Protection 23 Calculator System upgrade. Entergy is replacing its 24 existing Core Protection Calculator with the Common Q 25 CPC technology. The CPC, of course, calculates heat NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 1 generation and DNDR. The lights trip functions to the 2 system if necessary to protect safety limits.
3 I want to note -- you already know -- this 4 Common Q CPC technology has improved, is approved, and 5 is currently in use at Palo Verde. This indeed was 6 our first successful test run of Revision 2 of ISG-06, 7 including alternate review process.
8 As Jeanne noted earlier, alternate review 9 process still focuses on system architecture, 10 fundamental design principles, and functional design 11 requirements, as the traditional process, but also has 12 a heavier focus on software development plans and 13 vendor oversight plans as what I call a new feature of 14 the licensing basis. This allowed for an earlier NRC 15 approval of the system during Entergy's design 16 development timeline.
17 I also want to note effort not only 18 involved our I&C team but also include a range of HFE 19 reactor systems, technical specification, risk analyst 20 experts, expert project managers, our vendor 21 inspectors, in collaboration with regional inspectors.
22 They did a great job working together to integrate a 23 team to bring this review to completion within one 24 year.
25 CHAIR BROWN: Mike, could I ask you a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
74 1 question?
2 MR. WATERS: Please.
3 CHAIR BROWN: I don't remember us looking 4 at this. We did the Diablo Canyon one. I know Rich 5 presented that several years ago, which has a very 6 good architecture approach and diagrams and stuff to 7 do that. Did you all end up getting the ISG-06, an 8 equivalent good architecture, when you talk about the 9 fundamental design with the independence and 10 everything shown?
11 MR. WATERS: Yes. We really focused on 12 that. I will note, of course -- and I'll -- I&C 13 experts will slight the terminology I use, but this is 14 a piece component of the overall reactor protection 15 system. So we looked at that within that context.
16 And I'll be happy to have --
17 (Simultaneous speaking.)
18 CHAIR BROWN: -- analog? I mean, 19 previously --
20 MR. WATERS: No, it was a digital to 21 digital replacement.
22 CHAIR BROWN: Okay. All right. Now I'm 23 remembering. I'm remembering seeing some of the 24 correspondence on it, then.
25 MR. WATERS: So, in my viewpoint, other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 1 than the changes within the CPC architecture, per se, 2 there was not a change to overall protection scheme 3 and architecture.
4 CHAIR BROWN: So this was largely a 5 platform replacement, then, a computing platform 6 replacement.
7 MR. WATERS: I would say a new technology, 8 but of course, the platform had application-specific 9 programming and configuration, of course. But yes --
10 CHAIR BROWN: Yeah --
11 (Simultaneous speaking.)
12 MR. WATERS: -- CPCS.
13 CHAIR BROWN: I'm talking about the 14 hardware itself and the operating system and stuff 15 like that, the Common Q operating system --
16 MR. WATERS: Right, right. That's what 17 was --
18 (Simultaneous speaking.)
19 CHAIR BROWN: -- many, many -- several 20 different places. I think APR1400 used it --
21 (Simultaneous speaking.)
22 MR. WATERS: Right. Right.
23 CHAIR BROWN: So did somebody else before 24 that. Was it AP1000?
25 MR. WATERS: Well, for CPC, I can't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 1 distinguish between the CPC versus the other pieces of 2 the reactor protection system. I don't know if -- is 3 that your question? I --
4 CHAIR BROWN: No, the Common Q platform 5 was used in at least two different --
6 MR. WATERS: Yes.
7 (Simultaneous speaking.)
8 CHAIR BROWN: -- certifications that I 9 remember.
10 MR. WATERS: I believe --
11 (Simultaneous speaking.)
12 CHAIR BROWN: -- with FPGA's and --
13 (Simultaneous speaking.)
14 MR. WATERS: -- and AP1000 is Common Q.
15 CHAIR BROWN: That's what I thought, and 16 AP1400 used Common Q also, if I remember correctly.
17 MR. WATERS: I believe --
18 CHAIR BROWN: Okay.
19 MR. WATERS: I'll ask my staff to cut me 20 off of a --
21 (Simultaneous speaking.)
22 CHAIR BROWN: I just threw that out, just 23 -- it's irrelevant. Don't worry about it.
24 MR. WATERS: Okay.
25 CHAIR BROWN: Okay. I just -- I thought NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
77 1 I remembered hearing this, and I thought this was just 2 a piece within the digital design that they already 3 had --
4 MR. WATERS: Right.
5 CHAIR BROWN: -- is what you just said.
6 Okay.
7 MR. WATERS: Exactly.
8 CHAIR BROWN: Thank you.
9 MR. WATERS: To finish this one up -- and 10 it kind of dovetails ISG-06. What was interesting 11 about this review was the requested review timeline 12 and Entergy's development timeline really did not 13 follow the ideal timeline that we assumed back in 2018 14 for ARP, as we briefed you.
15 This is because Entergy proceeded with 16 full development and the build-out of the system in 17 parallel with our licensing review. Entergy in 18 Westinghouse, for example, completed factory 19 acceptance testing in early August, which overlapped 20 with the tail end of our license review.
21 Therefore, it was important to note we 22 simply conducted inspections at the vendor site in 23 parallel with the licensing review. The inspections 24 were not used as part of the staff basis for approval.
25 Rather, it was conducted in parallel because of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 1 time Entergy's developing the process and heavy focus 2 on their development of the system at the vendor under 3 Appendix B.
4 CHAIR BROWN: So Waterford kind of was 5 betting that everything would come all right, come out 6 okay, and they went ahead and started.
7 MR. WATERS: Well, betting -- yes. I 8 mean, they took that business risk, I guess I would 9 say. And a note I'll say in the next slide, that 10 seems to be an Entergy trend, which we'll probably see 11 for Turkey Point and Limerick, the fact that they'll 12 be developing and building the system significantly 13 during our license review.
14 CHAIR BROWN: Okay. Go on. Thank you.
15 MR. WATERS: So, as a note here, we're 16 going to apply the alternate review plan process 17 lessons learned to upcoming Turkey Point/Limerick 18 LARs. And let me go to next slide to talk about it a 19 little bit more specifically.
20 So these are some of the key lessons we 21 derived from our exercise of ISG-06, including not 22 only Waterford, but we've had significant ratification 23 meetings with Turkey Point and Limerick. As Jeanne 24 noted earlier, we have both an alternate review 25 process and traditional tier review process defined in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 1 ISG-06, which really focuses on the types of design 2 information submitted to NRC and the timing.
3 I would say in reality we used maybe a 4 blended approach in some limited areas for Waterford 5 because, a fact of life, design approaches and timing 6 by industry during development of our system, as I 7 mentioned, as well as regulatory insights and needs we 8 identified during our review to make sure we get the 9 complete safety evaluation as efficient as possible.
10 First one, the scope of the vendor 11 oversight plan, that was a key challenge area, I would 12 say, both for Entergy and NRC. As I noted, the vendor 13 oversight plan formed a significant basis of our 14 licensing approval under normal review process. ISG-15 06 did not have specific guidance on the details 16 expected in the vendor oversight plan.
17 But the goal of the vendor oversight plan 18 is to ensure the licensee has a heightened focus on 19 development plans and vendor's product and analysis.
20 I would say, in a similar manner, the NRC had 21 traditionally evaluated and passed license decisions.
22 So Entergy forged new ground in developing 23 the oversight plan for their upgrade. I think from 24 our perspective, there were a couple challenges early 25 on. I think, one, we were challenged to understand NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 1 how the execution of their vendor oversight plan 2 interfaced with our specific Appendix B QA processes.
3 And we had a lot of back and forth to line 4 and level of detail required in their oversight plan 5 and the vendor oversight plan summary on the docket.
6 This involved significant discussions and requests by 7 staff to ensure that critical attributes and features 8 of the implementation testing phase were appropriately 9 captured in the vendor's oversight plan.
10 Let me touch upon a few more. Crediting 11 self-diagnostics, that's not new, per se. We've 12 approved that in past applications. But eliminating 13 the surveillance requests, such as channel operability 14 tests, represented a significant technical 15 specification change pursued by Entergy. And it's a 16 big driver for whatever upgrades that we'll see come 17 down the road.
18 However, there's not detailed guidance in 19 ISG-06 on what is needed to do that, so given the 20 pursuit of self-diagnostics, we had a heavy focus on 21 engaging Entergy on ensuring that the self-diagnostic 22 functions accomplished the same intent of the 23 traditional tech spec surveillances to verify 24 operability. And this required greater design 25 description of the self-diagnostic features and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
81 1 effects and diagnostic analysis to address subsystem 2 failures and diagnostic coverage.
3 And, on that note, staff has continued to 4 communicate to future licensees on the needs to take 5 credit for self-diagnostics in their platforms to 6 eliminate surveillance testing.
7 CHAIR BROWN: If I remember correctly --
8 and I just looked it up in ISG -- there were -- the 9 ultimate review process is it was intended to be a 10 simplified and more streamlined approach, but it still 11 emphasized the design approach of looking at the 12 system architecture, if you look at the text of the 13 ISG.
14 So I'm not so sure it was as applicable to 15 Waterford as it would be for Turkey Point and 16 Limerick. But --
17 MR. WATERS: That's correct. I mean, the 18 system architecture fundamental design principles, 19 including diversity and defense in depth, are 20 fundamental looks here that we've not changed or 21 altered. So you're correct about the Waterford. And, 22 as I'll note when we get to Turkey Point and Limerick, 23 we've started to have application discussions on 24 system architecture already to talk about those 25 things.
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82 1 So that's not changing. That's a 2 foundation of our review is making sure the system 3 architecture is safe and compliant with applicable 4 regulations, of course, and IEEE standards.
5 CHAIR BROWN: This also parallels the DRG 6 --
7 MR. WATERS: Right.
8 CHAIR BROWN: -- that you all developed, 9 staff developed, from all the DSRS work.
10 MR. WATERS: Right. And if you look --
11 you know, it's been a while since we briefed on ISG-12 06, so if you look at section D.2 of ISG, it provides 13 a specific guidance for system architecture 14 evaluations.
15 CHAIR BROWN: Yeah. Okay. We don't want 16 to lose that. That's the most critical part of all of 17 this, is the architecture approach, which we have been 18 doing and proceeding through now for the last ten 19 years. So all right. Good. Thank you.
20 MR. WATERS: All right. Just a couple 21 more here. I'm not going to cover them all.
22 Use of risk insights. Now, this was not 23 a risk-informed review, as you may be familiar with.
24 But we did have an innovative review team, and we took 25 an innovative approach to more purposely consider up NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 1 front those risk-informed principles to help guide us 2 on some of the finer technical issues during the 3 Waterford review.
4 The team still followed ISG-06, but we did 5 consider some risk insights in the safety evaluation 6 on some issues. And we documented that at a high 7 level in that safety evaluation, and we hope to 8 continue that for future reviews.
9 And finally, on this slide -- I did allude 10 to it earlier -- the alternate review process was 11 originally conceived really to give Entergy a 12 licensing decision before they spent significant 13 resources on procuring and fabricating digital 14 systems. However, as I noted, Entergy elected, again, 15 to develop the system in parallel to license review.
16 This does seem to be the current Entergy 17 trend. Therefore, we had to continue our license 18 review but also plan and implement inspections in 19 parallel. That may have caught the licensee off guard 20 to some degree. We had to explain the wall between 21 licensing review and audits and inspection. We did 22 that, and we had to really record our resources. And 23 that's a learn we're going to continue to communicate 24 for future reviews given the current trend here.
25 Any questions before I move on to Turkey NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
84 1 Point?
2 CHAIR BROWN: You're on to 06 lessons 3 right now, so --
4 MR. WATERS: Right. Right.
5 CHAIR BROWN: Go ahead.
6 MR. WATERS: So, next slide, Turkey Point.
7 CHAIR BROWN: Okay.
8 MR. WATERS: So we expect to receive this, 9 I guess, next week. This indeed is a more substantive 10 upgrade to reactor protection system, engineered 11 safety features, and nuclear instrumentation systems.
12 Florida Power & Light has requested us to use all the 13 review process in ISG-06.
14 This system incorporates the Tricon 15 digital platform. As you may know, the NRC has 16 previously approved the Tricon topical report, I 17 believe in the 2012 time frame, so sort of a 18 referenced and approved tropical. And as you may 19 recall, I believe Tricon technology was used in part 20 in Diablo Canyon in the digital upgrade, as well, 21 approved back in the 2015/2016 time frame.
22 The upgrade will employ a diverse 23 actuation system for a limited number of I&C systems.
24 And also, as noted here, the licensee intends to 25 credit leak before break detection as diverse means NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 1 within the D3 assessment. And staff will use the 2 guidance in BTP 7-19 Revision 8 to address and review 3 the D3 approach.
4 So far, we've had approximately eight 5 ratification meetings to methodically step through the 6 key elements of a LAR. Again, as discussed, the plan 7 system architecture fundamental design principles were 8 discussed under oversight plans, EQ, human factor, 9 technical specifications, and I'm sure other important 10 safety issues as well.
11 As far as status, FPL has requested --
12 well, will request review and approval schedule 13 supports a spring 2023 outage, installation for 2023 14 outage. We have to communicate that this is an 15 aggressive schedule given the complex scope of the 16 upgrade and the additional technical issues associated 17 with a review.
18 We expect as a next step, once we receive 19 it next week, to complete an acceptance review, 20 development of a detailed schedule if we accept it for 21 review, and we'll circle back with the ACRS on the 22 appropriate briefing time on the system.
23 CHAIR BROWN: Is there going to be a 24 separate -- I mean, this is I&C. This is not a whole 25 plan. So I presume part of their design or their LAR, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 1 whatever the documents are, there will be a complete 2 architecture diagram similar to what we've seen on the 3 last two design certifications, something that 4 demonstrates the architecture and the meeting the 5 fundamental principles.
6 And even though nobody wants to cover 7 unidirectional communications, that will be an issue 8 when we talk about it when we review it. And we will 9 need that good architecture diagram. That made the 10 NuScale and the APR1400 reviews extremely easy from 11 the Advisory Committee standpoint.
12 MR. WATERS: Yes. Yes -- yes, we --
13 (Simultaneous speaking.)
14 MR. WATERS: The short answer is yes. We 15 have seen their preliminary diagrams or architecture.
16 I can't discuss it here because some of that 17 information is proprietary.
18 CHAIR BROWN: That's fine.
19 MR. WATERS: But to the extent you have 20 access to it, we'll share as part of that briefing.
21 CHAIR BROWN: Well, we will have to have 22 the architecture configuration in order to do our 23 review.
24 MR. WATERS: Sure.
25 CHAIR BROWN: Bottom line. Just like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
87 1 Diablo Canyon.
2 MR. WATERS: Sure. I would expect the 3 same level of information to be provided at the time 4 we brief you.
5 CHAIR BROWN: That also made our review of 6 the Diablo Canyon when it was obvious that they met 7 all the touch points. So --
8 MR. WATERS: And I'll say if we don't have 9 the architecture up front, it's highly unlikely we 10 would accept it for review to begin with. So we'll 11 have access to that information up front.
12 CHAIR BROWN: Okay. Thank you.
13 MR. WATERS: Okay. Next, Limerick.
14 That's a year from now. Limerick represents another 15 substantial upgrade. They intend to integrate the 16 protection and safety systems into a plant protection 17 system using the Westinghouse Common Q technology.
18 And, as you've just noted, Common Q has been used 19 elsewhere, and we have an approved topical report for 20 that as well as revisions to that topical report.
21 What's a little unique here is Exelon has 22 a public-private partnership with DOE's Light Water 23 Sustainability Program for implementing this upgrade.
24 As we understand it, Exelon, in part, has worked with 25 DOE on cost analyses and development aspects of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 1 planned upgrade.
2 Exelon also intends to use new industry 3 guidance that they developed themselves for digital 4 implementation. Exelon has noted they will share 5 those experimental utilities as part of the 6 partnership with DOE.
7 And, again, one key feature proposed by 8 Exelon is elimination surveillance tests to really 9 reduce their long-term cost burden to maintain I&C 10 system. Again, we have engaged with Exelon in 11 multiple pre-application meetings -- at three, I 12 believe. And, again, we've begun to discuss system 13 architectures and the fundamental design principles.
14 But they are continuing to develop their 15 systems, and we expect to have additional pre-16 application meetings as they ramp up to submittal, 17 currently scheduled for September of 2022.
18 CHAIR BROWN: Is theirs an existing 19 analog?
20 MR. WATERS: Yes, I believe it's analog --
21 (Simultaneous speaking.)
22 CHAIR BROWN: It says upgrade, so I'm 23 presuming it was analog before.
24 MR. WATERS: Yes --
25 (Simultaneous speaking.)
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89 1 CHAIR BROWN The word integration is what 2 is curious, the way it's used for RPS, NSSS, and ECCS.
3 I don't know how integrated integrated is.
4 MR. WATERS: Well, right. That's good and 5 -- that's correct, and that's a focal area, as well, 6 in the application space: what is that integration?
7 And again, obviously, as you know, the first question 8 of fundamental design principles, of independence, 9 redundancy, and defense in depth and diversity are 10 questions we'll continue to ask. And that will be a 11 focus of our discussions.
12 CHAIR BROWN: Okay. We'll be looking 13 forward to that. Hopefully I'm still alive then, too, 14 so -- it's only a year away, maybe.
15 MR. WATERS: Well, Charlie, I hope NRC 16 will be briefing in the next ten years, up here in the 17 next ten years. Myself, I hope to win the lottery or 18 retire, but at least someone will be here to brief 19 you.
20 CHAIR BROWN: Okay.
21 MR. WATERS: All right. Let's shift gears 22 slightly to non-power production utilization 23 facilities, the SHINE. I know you've requested to 24 hear about SHINE and AFRRI, and I know you've 25 coordinated separately with our colleagues and DANU on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
90 1 the overall SHINE --
2 (Simultaneous speaking.)
3 CHAIR BROWN: I want to be a little 4 careful on SHINE because, yeah, we're obviously going 5 to be looking at that, but there's -- I don't know 6 where they stand right now. So there's a lot of stuff 7 going on relative to scheduling for that.
8 MR. WATERS: Yeah, I -- right. And so 9 this is going to be very high level, just keep it as 10 a status and what we're looking at for I&C and leave 11 it at that.
12 So, as you know, the SHINE has two primary 13 facilities, their radiation facility and radioisotope 14 production facility. All these facilities would be 15 licensed under 10 CFR Part 50 if approved. On the 16 slide are some of the key I&C systems we are currently 17 in the process of reviewing right now.
18 One is a highly integrated process control 19 system, PICS. And, as the name implies, it's 20 integrated and controls both irradiation processes at 21 the target solution and extraction operations in the 22 radioisotope production facility.
23 The reaction protection system protects 24 safety limits within the target solution vessel during 25 irradiation, and it monitors things such as neutron NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 1 flux, temperatures, and other flow parameters, and 2 obviously actuates shutdown of the process and can 3 move the solution to a safe configuration if limits 4 are approached.
5 In a similar manner, the integrated safety 6 features protects against potential accidents and 7 events or inadvertent releases in both the irradiation 8 facility and the radioisotope production facility, 9 again, primarily by actuating shutdown, confinement, 10 or hydrogen mitigation actions upon radiation levels 11 and pressure levels that approach predefined limits.
12 Just one note that the TRPS and ESFAS are 13 actually based on the variation of the HIPS FPGA 14 platform technology, which has been previously 15 certified for use in the NuScale reactor design. It's 16 not the same design configuration you may be familiar 17 with, but SHINE does reference the HIPS topical 18 platform, and again, we're in the middle of reviewing 19 that. And I believe ACRS was briefed on the HIPS 20 platform earlier, in April 2017.
21 CHAIR BROWN: That's correct.
22 MR. WATERS: Number 2 says --
23 (Simultaneous speaking.)
24 MR. WATERS: Yeah.
25 CHAIR BROWN: Go ahead. Go ahead. Go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
92 1 ahead.
2 MR. WATERS: The radiation monitoring 3 system and neutron flux systems are systems, again, as 4 it suggests, monitor radiological and nuclear 5 parameters in both facilities and provides inputs to 6 both the process control system and those two safety 7 systems.
8 One important thing to note here is staff 9 is not applying specific review guidance ISG-06 or 10 BTP 7-19 as we would for operating reactors. We are 11 using applicable portions of NUREG-1537 standard 12 review plan and criteria for non-power reactors.
13 Again, this SRP has fundamental guidance 14 criteria that covers a large variety of research and 15 non-production designs. Nonetheless, the fundamental 16 design principles and performance-based approach 17 criteria are the same here as it would be for 18 something like ISG-06, just a different process and a 19 different level of scope of review.
20 CHAIR BROWN: Okay.
21 MR. WATERS: I can't discuss schedule too 22 much here.
23 CHAIR BROWN: No, you ought to stay away 24 from that.
25 MR. WATERS: Okay.
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93 1 CHAIR BROWN: Ron, I don't want to step on 2 any -- are you still there?
3 MEMBER BALLINGER: Yeah, I'm here.
4 (Simultaneous speaking.)
5 MEMBER BALLINGER: Schedule is, shall we 6 say, fluid.
7 CHAIR BROWN: Okay. I didn't want to get 8 involved in getting into any areas that we're not 9 engaged with or know what the results are. So we'll 10 stay away from scheduler stuff right now. All I know 11 is we haven't seen any of this yet, so --
12 MR. WATERS: Right. And my final note is 13 our Advanced New Reactor Division will obviously 14 coordinate with ACRS with our engagement plans for all 15 the areas that are needed to be briefed on.
16 CHAIR BROWN: Okay.
17 That's consistent, Ron?
18 MEMBER BALLINGER: Yeah. Yeah.
19 CHAIR BROWN: Okay. Just wanted to make 20 sure I didn't step out of the box, as I am somewhat 21 bent on doing every now and then.
22 Okay. Go on, Michael.
23 MR. WATERS: All right. Next one, the 24 staff is also reviewing the Armed Forces Radiobiology 25 Research Institute request to upgrade and replace NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
94 1 their instrumentation control systems in its TRIGA 2 reactor. It's replacing the system with a hybrid 3 approach of new analog and digital systems.
4 As you know, AFRRI is located down the 5 street from NRC headquarters at Walter Reed Hospital 6 and uses a reactor to research the effects original 7 gamma neutron radiations in support of U.S. Department 8 of Defense protection of armed service members.
9 The upgrade uses General Atomics analog-10 based nuclear instrumentation technology along with 11 digital controls and monitoring systems. And, of 12 course, the system primarily protects the fundamental 13 fuel temperature safety limits by measuring and 14 tripping against power levels and fuel temperatures.
15 And, again, the staff is using the NUREG-16 1537 to conduct our review. We hope to wrap up the 17 primary safety review for I&C this year, and we're on 18 target to issue a license decision in 2022.
19 CHAIR BROWN: And you plan on involving 20 the Advisory Committee?
21 MR. WATERS: No, we don't plan on engaging 22 the Advisory Committee on this upgrade.
23 CHAIR BROWN: Is there a reason?
24 MR. WATERS: Well, we typically engage you 25 all on very significant operating reactor design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
95 1 certifications and have not done so for the more 2 modest RTR upgrades here.
3 CHAIR BROWN: I don't know what the 4 history is on these, so I'm totally blank when it 5 comes to that.
6 Scott, are you on the line?
7 (Pause.)
8 CHAIR BROWN: Larry?
9 MR. BURKHART: I'm here, Charlie, yes.
10 Please express the question again.
11 CHAIR BROWN: Well, I was curious that 12 this is a fairly -- overall upgrade. I don't know 13 what the Committee's involvement has been with these 14 types of installations in the past. I haven't faced 15 one of these.
16 But right now, we're not on their list to 17 review or evaluate the replacement of the old stuff 18 with the new stuff, and I'm not even -- whatever the 19 standards are. So I'm kind of at a loss to know 20 whether we ought to request a meeting on this subject.
21 MR. BURKHART: Yeah, I mean, the guidance 22 is -- as always, right? If we think there's a safety-23 significant issue and it's agreed upon by the 24 Subcommittee, that we would schedule Subcommittee 25 meetings.
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96 1 So what I would recommend is that you have 2 a discussion with your Subcommittee folks, and we 3 engage in a discussion with the staff. And Christina 4 can help on that.
5 MEMBER REMPE: So this is Joy. Maybe 6 another question to Mike could clarify the situation.
7 I know the MIT reactor -- which it wasn't a -- or is 8 not a TRIGA -- did some sort of upgrade, I thought, to 9 their control room. How many other university 10 reactors, which are often TRIGAs, do such upgrades or 11 have done them?
12 MR. WATERS: Well, just to step back, 13 you're correct that MIT upgraded with analog and 14 digital technology. Purdue did as well; went to all 15 digital. We approve additional licensing actions.
16 Again we have not by practice engaged ACRS on those 17 reviews or RTR upgrades. They are indeed less safety-18 significant than the operating reactors we've talked 19 about before.
20 The other question, other digital upgrades 21 do happen RTRs under the 50.59 process. I can't -- I 22 don't have the information on the extent to which that 23 has been done. We can sure go back on that.
24 I would note for an AFRRI system upgrade, 25 like you said, you can fall under the traditional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
97 1 licensing practice which has involved ACRS engagement.
2 CHAIR BROWN: I'm not criticizing --
3 MR. WATERS: Yes.
4 CHAIR BROWN: -- Mike. I'm just --
5 MR. WATERS: No. Yes.
6 CHAIR BROWN: -- not familiar with it.
7 I'm not trying to invent something new. We've got 8 plenty on our plate right now and I'm not quite sure 9 of where this falls.
10 MEMBER PETTI: So this is Dave. As I 11 understand it the requirements are different than what 12 we have for power reactors because of the lower hazard 13 of these types of systems, but it might be interesting 14 because of the microreactor angle where some would 15 argue that the hazards of microreactors are more like 16 some of these systems. It might be useful just to 17 have a briefing of how they're different in terms of 18 their requirements to help us understand some of that.
19 20 CHAIR BROWN: You mean between power 21 reactors and the micro type or the --
22 MEMBER PETTI: No, between power reactors 23 and these, the --
24 CHAIR BROWN: Yes.
25 MEMBER PETTI: -- test reactors so that --
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98 1 because it wouldn't surprise me if a microreactor 2 would try to make the argument that they were similar 3 in hazard to these guys here.
4 CHAIR BROWN: What's the power rating for 5 these types of -- this system? Are they less than 20 6 megawatts or 10 megawatts, or what?
7 MEMBER REMPE: That's a hard question to 8 answer. They pulse up, right, Charlie?
9 MR. WATERS: Yes, how many kilowatt? I 10 think 20 megawatt maybe or higher level I'm familiar 11 with. So that's what I would offer is that the risk 12 significance of these are much less. The systems are 13 obviously less complex in an operating reactor. We're 14 talking about measuring a small number of parameters 15 primarily to protect fuel temperature. So it's an 16 important safety review, but it is definitely less 17 complex than you would expect for an operating reactor 18 digital upgrade. And AFRRI is one megawatt.
19 MEMBER REMPE: So this is Joy and I'm kind 20 of along with what Dave had said that I wouldn't want 21 to focus on a particular reactor, but an overview of 22 what is typically done and how the staff does the 23 review might be of interest.
24 As I recall there was a lot of -- wasn't 25 it Department of Energy funding that helped with like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
99 1 the MIT upgrade or something? They got one of these 2 larger infrastructure awards? And so it was something 3 that -- my perception was they were doing it at a 4 university reactor so they could get some insights on 5 some of the benefits of doing -- for the other types 6 of reactors even. So am I right in that perception?
7 MEMBER PETTI: I think you're right, Joy.
8 I recall. I think they got one of those 9 infrastructure awards.
10 MR. WATERS: Yes, so DOE does fund some 11 improvements. I honestly can't tell you which ones 12 are digital, which ones are not digital because other 13 things go on of course in terms of improvements at 14 RTRs.
15 I'll be happy to circle back with you to 16 provide an overview of the differences if that's 17 what's required for I&C, but I will offer it's for --
18 it's not going to be as complex as it is for what 19 you've heard about for ISG-06 and BTP 7-19 and all the 20 Reg Guides.
21 MEMBER REMPE: How much is the --
22 (Simultaneous speaking.)
23 MEMBER REMPE: -- to do it? I mean are we 24 asking you to do something that's a pain to and you --
25 I've heard earlier several times today that we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 1 limited resources. Are we making you do something 2 that's going to take a lot of effort or is it 3 something that you've got -- it would be pretty easy 4 to put together, I don't know, 10 or 15 slides or 5 something like that to get what we're asking for?
6 MR. WATERS: Well, I&C will be happy to do 7 it. Maybe not immediately, but happy to do it down 8 the road to explain that aspect. And we can 9 coordinate for our colleagues in DANU you to address 10 any needs. I'll be honest, my broader concern is for 11 example we want to make a decision as soon as possible 12 in AFRRI given the amount of security interest on 13 that, so --
14 MEMBER REMPE: That's why I wouldn't focus 15 you on a --
16 MR. WATERS: Right, right.
17 MEMBER REMPE: -- particular one. I'd go 18 at a higher level that might be of interest. And I 19 don't think it's urgent, but again maybe a discussion 20 off line would convince that there's not much here 21 that's going to be of interest to ACRS because we have 22 limitations too (audio interference).
23 MR. WATERS: Yes, I think we can do so.
24 Time is (audio interference), but we have engaged the 25 (audio interference) reactor community. They ask the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
101 1 same questions: What are NRC expectations for a 2 digital license for example? And so we've prepared 3 for those type of discussions, and we can discuss off 4 line or at a future update briefing on that aspect.
5 CHAIR BROWN: Just to springboard off of 6 Dave and Joy, the microreactor thought process, they 7 keep being thrown around. They are small, but they're 8 more for delivering power as opposed to research. And 9 it might be useful to see what these systems look like 10 for us -- not have to do anything with it, but for an 11 information standpoint so we can see how those are 12 handled relative to any other discussions that may 13 come up later.
14 Dave and Joy, is that consistent with --
15 MEMBER PETTI: Yes. So I mean to me my 16 understanding is defense-in-depth is implemented 17 somewhat differently in these systems, that control 18 and protection are not separate necessarily (audio 19 interference).
20 (Simultaneous speaking.)
21 CHAIR BROWN: Yes.
22 MEMBER PETTI: So it's these subtle 23 differences that I think it would just be educational 24 for us to understand because it's sort of an 25 application of how you can change some of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
102 1 requirements as the hazard changes.
2 CHAIR BROWN: Yes.
3 MEMBER PETTI: And that's really what 4 we're struggling with. Part 53 is not going to 5 consider certain aspects of microreactors, but they're 6 going to consider others. So I think it just would 7 help inform us in that.
8 CHAIR BROWN: One of your staff Norbert 9 Carte -- are you there, Norbert? Your hand is up.
10 MR. CARTE: Yes, it was sort of in case 11 Mike wanted my quick summary of some of the 12 differences between NPUFs and power reactors.
13 CHAIR BROWN: Okay. Let's not -- I want 14 to try to leave this at -- why don't -- Christina, can 15 you work with Larry or do whatever we need to do to 16 figure out just maybe an information briefing on what 17 these look like?
18 MS. ANTONESCU: Yes, I will work with the 19 staff, Member Brown.
20 CHAIR BROWN: Okay. And set up an 21 Information Subcommittee meeting at some point, a 22 half-day-type thing?
23 MS. ANTONESCU: Sure. I will do that.
24 CHAIR BROWN: Is that out of purview, 25 Mike, Eric?
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103 1 MR. WATERS: Well, we can circle back to 2 Christina. I know you're focused on microreactors.
3 I'll be honest, that's outside of my knowledge, but I 4 suspect that we're not going to have much yet on the 5 I&C designs or those futures things.
6 CHAIR BROWN: No, no, no. We're not 7 looking for that. We just want to --
8 MR. WATERS: Okay.
9 CHAIR BROWN: -- see what these look like 10 so we'll have some idea of what we're --
11 MR. WATERS: Okay.
12 CHAIR BROWN: -- looking at when we get 13 there.
14 MR. WATERS: Okay.
15 CHAIR BROWN: Those are in the future, but 16 these are -- I think Dave and Joy are correct in that 17 these provide a window into what we may be looking at 18 in the future for some of these advanced reactor 19 applications.
20 MR. WATERS: Yes, we'll circle back with 21 Christina. I would suggest that our new reactor 22 divisions would have the lead on this type of 23 discussion with the ACRS, so --
24 CHAIR BROWN: That's fine. However you 25 all --
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104 1 MR. WATERS: -- we'll circle back.
2 CHAIR BROWN: -- want to arrange it is 3 fine. It doesn't make any different from that 4 standpoint. We'll accept --
5 (Simultaneous speaking.)
6 MEMBER REMPE: Charlie?
7 CHAIR BROWN: Yes?
8 MEMBER REMPE: One other thing that has 9 come up, I was involved in an instrumentation OECD-10 sponsored meeting last January -- oh, in December I 11 guess and one of the points that was heavily 12 emphasized is that these new advanced technologies do 13 a lot of design development and instrumentation comes 14 in at the last minute. And sometimes it's hard to 15 backfit it in and you end up with a fully developed 16 design and you can't get any instrumentation that will 17 accomplish the objective.
18 And so I think it would be a worthwhile 19 information meeting. And I would suggest that there 20 be some discussions between you and Christina and the 21 staff before we actually have the meeting to make sure 22 some different aspects are included in that discussion 23 because it's a good topic to think about.
24 CHAIR BROWN: Yes. No, we could get 25 together informally as long as we don't violate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
105 1 anybody's rules.
2 MEMBER REMPE: Yes, absolutely. There's 3 a lot of good things to think about on this topic and 4 I would be interested in helping if you are trying to 5 put together --
6 (Simultaneous speaking.)
7 CHAIR BROWN: No, no, that's -- we can do 8 that. I'll let Christina work with the staff and 9 we'll figure out what we got and then I'll -- we'll 10 feedback what we find out with you and Dave and 11 anybody else who wants to see it. And then we can see 12 where we want to go forward.
13 MR. BENNER: Yes, Member Rempe raised a 14 good point because I know there are activities out 15 there of saying hey, for these advanced reactor 16 technologies what are the needs for sensors going to 17 be and how do they get there? So I mean we -- but 18 again, we will -- the staff likely will have limited 19 information on that. I mean ultimately our review is 20 hey, if you need to sense a parameter, you better have 21 a sensor that does it and can be environmentally 22 qualified for the situation the sensor is going to be 23 in. But regarding the actual development of advanced 24 sensors, that clearly could be a challenge for some of 25 these designs.
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106 1 CHAIR BROWN: Oh, yes, but my interest 2 right now is to also -- I agree with that totally.
3 Joy would agree with that also because we've faced 4 that before. But here is a class or reactors that 5 kind of mirrors in a way what these other ones -- the 6 sizes that you might be dealing with and how do we --
7 how does the instrumentation and protection systems 8 align for those? Would it be appropriate for the 9 other, what I call vision reactors -- aside from 10 whether they can actually detect anything, what may --
11 just from a scaling standpoint. So I think it would 12 be interesting to see what these look like so that we 13 can have some concept of what we may look like when we 14 go to these advanced reactors.
15 So I agree there might be a technology for 16 measuring something that may not exist. It's always 17 -- people that have these great ideas always do that, 18 but -- and then you're right, they can't produce a 19 piece of stuff that allows you to monitor it. So that 20 doesn't work very well.
21 But let's go ahead and stop this here, but 22 let Christina work with the staff and just develop a 23 half-day information brief that shows what these look 24 like so that we can see physically what they look like 25 as opposed to just viewgraph words, their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
107 1 extensiveness and such. And then we'll just have an 2 idea of what may be proposed in the future.
3 Is that okay, Christina? Larry?
4 MS. ANTONESCU: Yes, member. We'll follow 5 up with the staff and --
6 CHAIR BROWN: Okay.
7 MS. ANTONESCU: -- come up with a plan.
8 CHAIR BROWN: Okay. And if they tell you 9 who to -- just make sure you get with the right --
10 whoever -- Mike and Eric ought to be able to tell you 11 who the right people are to get with.
12 MS. ANTONESCU: Sure. We'll include 13 everybody.
14 MR. WATERS: We'll forward this to the 15 right people actually right now. So we'll do that.
16 CHAIR BROWN: Okay. Any more on this from 17 the members?
18 (No audible response.)
19 CHAIR BROWN: Okay. Let's move on then.
20 MR. WATERS: All right. Rich, it's your 21 show.
22 MR. STATTEL: Good afternoon, everyone.
23 I'm going to discuss several topical reports that we 24 have recently evaluated. I want to point out up front 25 that the -- several of these technical reports not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
108 1 only affect what the system designs will be, but also 2 how the systems will be used in the future when the 3 plants start taking advantage of some of the benefits 4 that these new technologies offer. I'll be discussing 5 the technologies involved. I'll also be discussing 6 some technology developments that we are now seeing in 7 these submittals.
8 So the first one is the HFC platform 9 topical report. The HFC is an FPGA-based platform and 10 it is an enhancement to a previous HFC-6000 I&C 11 platform. The microprocessor technology-based 6000 12 safety platform was evaluated back in 2011 and it was 13 approved the NRC at that time for use in nuclear power 14 plant safety-related I&C applications.
15 The scope of the staff's evaluation of the 16 FPGA platform is it included the development and test 17 plans, specifications, procedures used to perform the 18 design and to perform V&V of standardized FPGA circuit 19 boards that are part of that platform.
20 The SE scope also included the safety life 21 cycle processes that are used for the development of 22 the plant-specific logic in that platform. Many of 23 the system development processes and design concepts 24 are used for both the HFC-6000 and the FPGA platforms.
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109 1 to this particular platform compared to others like 2 Common Q. HFC intends to provide the FPGA and 3 microprocess solutions as separate solutions for 4 nuclear power plants to allow enhanced diversity for 5 the protection systems.
6 Now we were not really -- we did not do an 7 assessment of diversity between the two platforms. We 8 basically -- one was evaluated in '11 and the other 9 was evaluated here, but we do recognize they 10 fundamentally use different technologies. So there is 11 a certain amount of diversity between those two 12 platforms. And we also have plant-specific action 13 items in place to address the diversity at the plant-14 specific level, so those requirements would have to be 15 followed up for anyone who references one or both of 16 these platforms.
17 So that's the HFC platform. It's a pretty 18 typical platform evaluation. Are there any questions 19 before I move to the next technical report?
20 CHAIR BROWN: Yes, just maybe one, maybe 21 two; I'm not sure.
22 MR. STATTEL: Yes.
23 CHAIR BROWN: The only FPGA platform I'm 24 familiar with right now is the NuScale platform. This 25 is -- I mean FPGAs are FPGAs. So we actually looked NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
110 1 at the HIPS platform as part of the NuScale and we 2 evaluated that independently from the overall system 3 architecture.
4 MR. STATTEL: Yes.
5 CHAIR BROWN: We haven't seen either one 6 of these that I'm aware of, the Committee hasn't, as 7 a platform qualification. We did look at the Common 8 Q I think years ago.
9 MR. STATTEL: Right. Well, actually 10 Common Q does use FPGAs as well, so --
11 CHAIR BROWN: Yes, it's a mix. Yes, okay.
12 MR. STATTEL: Right. That's correct.
13 Most platforms actually have some FPGA element to 14 them, usually in the IO board, for example. It's very 15 common for them to use FPGA technology there.
16 CHAIR BROWN: But not in the voting end or 17 the --
18 MR. STATTEL: Right, which this is a bit 19 unique because essentially they basically took their 20 old microprocessor-based design and they built it --
21 they basically transferred it into an FPGA logic, 22 which is kind of interesting.
23 This isn't the first FPGA-based platform 24 we've evaluated. Of course we evaluated the HIPS 25 platform. We also evaluated a RATI platform which is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
111 1 all FPGAs. And there's a couple of others as well.
2 So I would say this is like about our fourth FPGA-3 based platform that we've reviewed.
4 CHAIR BROWN: All I want to put on the 5 table is that if we end up with a backfit, an LAR in 6 an operating plant or a new plant, a new applicant 7 design application, design certification that utilizes 8 something like this where the Committee actually has 9 not looked at the actual topical report, we would 10 probably want to do that in parallel like we did with 11 the NuScale setup. We did the HIPS first and then we 12 looked -- then we did the Chapter 7 equivalent review, 13 how it was applied.
14 So just keep that in mind; that's all I'm 15 saying, as we go forward.
16 MR. STATTEL: Well, in light of that would 17 you expect us to send you the Tricon platform in 18 advance of or in parallel with the Turkey Point 19 application?
20 CHAIR BROWN: Where else was that used?
21 MR. STATTEL: Tricon? That was the 22 platform that was the primary platform for the Diablo 23 Canyon application.
24 CHAIR BROWN: Okay. We did not look at 25 that separately --
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112 1 MR. STATTEL: Correct.
2 CHAIR BROWN: -- for that. Actually I 3 didn't know we hadn't, so that's probably why we 4 didn't. I'm just thinking about that as we go, that's 5 all. We did the HIPS thing in parallel, so --
6 MR. STATTEL: Yes.
7 CHAIR BROWN: -- I'm not sure I want to 8 get out ahead of that before we go there. Let you all 9 do your thing, but then it ought to be addressed as to 10 why it's satisfactory when we get to an application.
11 That's all.
12 MR. STATTEL: Okay. Well, I guess the 13 same would be true for the Common Q platform because 14 that platform was issued and it was evaluated and it 15 has been updated several times.
16 CHAIR BROWN: Yes, and we --
17 MR. STATTEL: Recently. This year.
18 Right, so --
19 CHAIR BROWN: Yes, we accepted that. I 20 don't want to start something new here.
21 MR. STATTEL: Okay.
22 CHAIR BROWN: That's all.
23 MR. STATTEL: All right.
24 (Simultaneous speaking.)
25 CHAIR BROWN: -- questions. This is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
113 1 good calibration, that's all.
2 MR. STATTEL: Yes. I'll just note that 3 one of the things that's kind of unique to each 4 platform we evaluate is the diversity aspect, and of 5 course the licensee who is referencing the platform 6 would have to address that in some way. In some 7 platforms -- there's a couple platforms where it's 8 actually addressed in the topical report. This is not 9 one of them. And like the ALS platform for example 10 has some diversity features built into that.
11 This one is different and unique in that 12 basically they have two different platforms, one 13 that's computer-based and one that's FPGA-based. And 14 so basically they have that diversity because of the 15 two different platforms that they have. Okay.
16 All right. I guess I can move to the next 17 slide. So the next topical report I'm going to talk 18 about is -- it's from Westinghouse and it has to do 19 with self-diagnostic functions, right? The actual 20 title of the topical report is a bit complicated, so 21 I didn't include in this slide. It's actually Common 22 Q Platform and Component Interface Module System 23 Elimination of Technical Specification Surveillance 24 Requirements.
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114 1 for determining if the technical specification 2 surveillance requirements can be eliminated for plant 3 safety systems that are based on the Common Q 4 platform. So essentially they want to take credit for 5 the diagnostic functions that the common platform 6 performs, right?
7 So I'll point out here that we evaluated 8 the self-diagnostic functions so they are described in 9 the platform evaluation, but we never gave any credit 10 for them as far as eliminating surveillance tests. So 11 this topical report attempts to bridge that gap.
12 The method that's provided in the topical 13 report involves a four-step process that establishes 14 whether the Common Q platform self-diagnostic 15 functions are capable of identifying and responding to 16 system failures that would have otherwise in a more 17 traditional manner been identified through manual 18 surveillance tests.
19 The four steps; I'll just briefly describe 20 them, they're identifying the system components that 21 are tested in those manual tests. This is primarily 22 directed at operating plants that have manual 23 surveillance tests in place. The second step is 24 identifying the failure modes of those components, and 25 normally that's done through an FMEA-type analysis.
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115 1 The third step is mapping diagnostic functions to 2 those failure modes. And the fourth step is 3 evaluating if those self-diagnostic functions provide 4 an adequate or equivalent means of identifying and 5 responding to postulated component failures.
6 So I also want to point out that once the 7 surveillances are eliminated from the tech specs the 8 licensee still has an obligation to confirm the 9 functionality of those self-diagnostic functions on a 10 regular basis. This is typically accomplished through 11 system walkdowns, operator rounds, or other 12 administrative processes.
13 These methods have been used to eliminate 14 several surveillance requirements for the recent 15 license amendment for Waterford Core Protection 16 Calculator System. And also similar methods were used 17 by Vogtle. Now you know Vogtle's not operating of 18 course, but in their original license they had planned 19 to perform several manual surveillance requirements, 20 surveillance tests. And they basically modified their 21 license to eliminate those, the requirement to do 22 those.
23 So I'm open to any questions on this 24 topical report.
25 CHAIR BROWN: Yes, I have a question.
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116 1 MR. STATTEL: Yes?
2 CHAIR BROWN: Not a negative question 3 except I did the same thing back in my programs 20 4 years ago when we started the microprocessor stuff 5 with all the self-diagnostics. So we -- all 6 throughout the -- that was part of the exact -- the 7 whole sample period was the self-diagnostics. Part of 8 the program sample time was devoted to that.
9 But we backed off on -- we used to do 10 weekly trip point and calibrations. We actually then 11 backed down to once every month and then we backed 12 down to even less. But what we did is we checked the 13 checker.
14 MR. STATTEL: Yes.
15 CHAIR BROWN: In other words, we had the 16 self-diagnostics built in, but we had a manual means 17 of checking the self-checkers. So periodically 18 whether it's every six months or something like that 19 you go in with the built-in self-checking function and 20 you check that the self-diagnostics is actually doing 21 what it's supposed to be doing.
22 I guess I would be uncomfortable with 23 something that doesn't check that the checkers are --
24 self-checkers are really working right. So I can see 25 most of the major surveillance being eliminated, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
117 1 if I was NRC I would be very hesitant to not have some 2 way of checking periodically, and I don't know what 3 the periodicity would be, to make sure that that self-4 checking function is actually doing what it's supposed 5 to be doing by a human being.
6 MR. STATTEL: Right.
7 CHAIR BROWN: So that's just an 8 observation.
9 MR. STATTEL: That's a very good 10 observation, and we have similar reservations. So 11 I'll mention that when this topical report first came 12 in there was no provisions for checking the checker, 13 as you mention. None at all. So essentially I'm 14 relying on the system to tell me that it has a 15 problem. And we definitely had concerns about that, 16 right? So the system that has a problem, I don't 17 really trust that system to tell me that it has that 18 problem. So that's where these additional provisions 19 came in.
20 Now I'll also mention that this has been 21 a trend that's been going on ever since the digital 22 technology started rolling out, but this is a new way 23 of addressing it. So I'll mention the Oconee system 24 that was installed about like 15 years ago. So in the 25 Oconee system they essentially did the same thing.
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118 1 They didn't eliminate the surveillance tests; they 2 basically rewrote the surveillance tests so that they 3 were only checking the checker, like you mentioned.
4 But they were still surveillance tests. That's how 5 that plant had addressed that.
6 Here they're actually eliminating the 7 surveillance tests, but they do still have that 8 obligation to confirm the functionality of the self-9 diagnostic functions.
10 So we've pretty much held that line. We 11 do have review guidance that tells us to verify that, 12 that they're doing those things. And we have had this 13 discussion with Turkey Point during our pre-14 application meetings so we expect that they will have 15 those provisions in place as well.
16 MEMBER HALNON: This is Greg. I got a 17 real quick question. Maybe it's more of a soap box, 18 but as we get more and more self-diagnostics and doing 19 things from computer screens I fear that there's an 20 unintended consequence of getting people out of the 21 plant. As an old operator I found many problems 22 walking systems down and finding the right 23 transmitters and thermocouples and whatever and 24 putting my hands on them, making sure that we 25 understand what's going on, especially in containment NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
119 1 where you don't get to very often.
2 So I would just ask you to watch for the 3 unintended consequences of becoming more and more 4 detached from the physical plant and more and more 5 attached to just software.
6 MR. STATTEL: Yes, I'm certainly in 7 agreement with you on that point. One of the 8 discussions we had with Westinghouse was I don't --
9 I'm not really comfortable with operators just looking 10 at the absence of an alarm and making an operability 11 determination just based on that. And therefore when 12 we review these, when we evaluate these, we try to 13 understand what the operators have available to them 14 as far as their assessments of operability.
15 And so for example, for Common Q the 16 system creates logs as it operates. So even if 17 there's no problem it basically puts status checks and 18 puts those into logs. And those are things that the 19 operator can look at periodically. They don't cause 20 alarms, but the operator can look at it and verify 21 that the system is in fact functioning. And those are 22 the types of things that we would expect them to do on 23 their operator rounds. Or system engineers do health 24 reports and they'll do rounds and they'll check 25 systems.
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120 1 So there are certain things that each 2 platform -- it's unique to each platform, but there 3 are certain things that the platform can provide to 4 the operators and engineers and technicians to help 5 them confirm that the -- not only that the system is 6 operable, but that the self-diagnostics are in fact 7 functioning correctly.
8 MEMBER HALNON: Yes, I think you got the 9 right mind set. And as we move forward into more 10 digital systems we tend to, what I would say, detach 11 ourselves from the physical touch of the plant and I'm 12 concerned about the absence of operators and 13 technicians walking through the plants and actually 14 doing work. And I say work as in physical touching 15 and monitoring and finding things that even aren't 16 associated with the system that they're going to, but 17 because they're in the area they see it. So I 18 appreciate that. Thanks.
19 MR. STATTEL: Thank you.
20 CHAIR BROWN: Greg, that's similar to --
21 aside from the self-diagnostics that we did, we had 22 the data loggers. You got to be careful on data 23 loggers. If somebody's logging data every five 24 seconds, then that becomes a blur of numbers.
25 MEMBER HALNON: Yes.
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121 1 CHAIR BROWN: So it has to be done on a 2 reasonable basis. But then what we had is the 3 operators -- instead of manually taking their logs 4 every hour they could go look at the data logger. And 5 then they looked at the data coming out of the data 6 logger. Then it was then printed I guess in some --
7 I've forgotten this; it's been 22 years -- where they 8 could have a separate record of it. So it wasn't 9 subject to computer crash or data loss.
10 MEMBER HALNON: Yes.
11 CHAIR BROWN: The Navy loves paper, so the 12 engineer could come back and look at the hourly logs 13 and see hey, look everything looks okay for the last 14 four years. So we didn't eliminate the ability to do 15 it; we just eliminated the need for the operator to 16 manually transcribe it onto pieces of paper. It was 17 more compact.
18 MEMBER HALNON: Yes.
19 CHAIR BROWN: But your point is exactly 20 right. You do not want the operators to lose touch of 21 how the equipment is operating.
22 MR. BENNER: Just to inject, that is a 23 broader issue and I will say that in our interactions 24 with DOE I think they are working with industry as to 25 how do you replicate that through wide-ranging sensors NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
122 1 that are monitoring equipment and things like video 2 cameras or audio? I mean, so there clearly isn't 3 clarity on what they answer is.
4 But I think, Member Halnon, the idea that 5 eyes and ears in the plant provides a value is 6 acknowledged and it's -- even if you're removing some 7 human beings from the plant, are you replicating those 8 eyes and ears in other acceptable ways.
9 MEMBER HALNON: Yes, that's exactly it, 10 Eric. Thanks.
11 MR. STATTEL: There's two additional 12 points I'd like to make: One is the self-diagnostics 13 are far better at identifying problems from what we've 14 seen than human beings as far as just relying on 15 periodic surveillance tests. So a typical analog 16 system sometimes -- it's not uncommon for a 17 surveillance test to be performed once a quarter. So 18 literally the plant could be operating for three 19 months and not know that there's a degraded component 20 or something in place until that surveillance interval 21 comes up, whereas by and large the vast majority of 22 self-diagnostic tests are continuously performed.
23 Typically within a second of a component 24 failing or reaching a limit there's an alarm, the 25 operator questions the operability. It basically NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
123 1 prompts to go look at the system and do a verification 2 of operability. So there's a lot of benefits that are 3 provided by self-diagnostics. I don't want to 4 underestimate that.
5 The second thing I'd like to point out is 6 that from our experience with Vogtle and with 7 Waterford not all surveillance tests are being 8 eliminated, right? There are portions of the system 9 that are not reachable, that can't be verified by 10 self-diagnostics, and this process we found to be a 11 good way to identify those. So those come out in the 12 failure modes and effect analysis. And if there's no 13 way for the self-diagnostics to detect those failures, 14 then the plant has to go in and manually do those 15 either during refueling outages or on a periodic 16 basis. So in both cases, in both Vogtle and Waterford 17 there were certain surveillance tests that were 18 retained. They determined that they needed to be 19 performed anyway. Okay?
20 MEMBER MARCH-LEUBA: Yes, this is Jose.
21 With respect to your first point it's always very 22 common in human-machine interfaces that machine 23 typically does much better.
24 MR. STATTEL: Yes.
25 MEMBER MARCH-LEUBA: The problem is that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
124 1 when the machines fail they fail catastrophically.
2 They fail with a bang. So I agree that the self-3 testing is really good, but if you have a logic 4 problem, you can produce a very large error, whereas 5 humans are more unreliable, but they don't tend to 6 fail that bad. That's something to consider.
7 MR. STATTEL: Thank you.
8 CHAIR BROWN: I agree with Jose and I 9 agree with Rich. I agree with Greg. The things on 10 three months, maybe operators were taking logs roughly 11 hourly, so now that burden has been relieved, but they 12 still have to look at it hourly and they see the 13 differences. The machine can tell you hey, you've got 14 differences between channels and all other kind of 15 stuff. They exceed certain parameters and give you a 16 heads up that maybe something is drifting.
17 But self-diagnostics is just supremely 18 better overall, but you still have to have people 19 evaluate to make sure it's really working the way it's 20 supposed to. And that's where the operators come in.
21 So as long as that's still being emphasized I think 22 that's the right way. You got to check the checkers 23 no matter what regime it's in.
24 So you can go on, Rich, unless there's 25 some other -- anybody else have a comment?
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125 1 (No audible response.)
2 CHAIR BROWN: Rich, you want to go on?
3 MR. STATTEL: Certainly. So the next 4 topical report; a little bit of shift of gears. This 5 is another type of use of technology.
6 So this is an AMS. That's a company down 7 in Tennessee. They provided us with an online 8 monitoring topical report. The online monitoring --
9 so this topical report provides condition-based 10 methods for performing online monitoring to be used as 11 a means to identify whether in-service pressure 12 transmitters need to be calibrated or repaired. Okay?
13 This methodology was developed to be used 14 in nuclear power plants as an analytical tool to 15 measure sensor calibration performance during plant 16 operation between scheduled refueling outages which 17 are typically the times when plant surveillance 18 requirements for transmitters are fulfilled. That's 19 when they do the manual calibrations.
20 The use of online monitoring technology 21 enables licensees to identify pressure transmitters 22 that have potential calibration performance issues 23 during plant operation rather than relying on 24 information gained during those periodic calibration 25 tests that are performed pretty infrequently.
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126 1 The online monitoring methods that are 2 presented in the topical report include the monitoring 3 of calibration performance and the monitoring of time 4 response performance to some degree. The method 5 involves collection of transmitter signal data during 6 plant startup, shutdown, transient and steady-state 7 conditions. These methods are similar to methods that 8 are widely used by plants today for monitoring 9 performance of resistance temperature detectors, but 10 in this topical report the methods are designed to 11 address the unique characteristics of pressure and 12 differential pressure transmitters. So it's kind of 13 a limited scope topical.
14 When a licensee applies the methods that 15 are outlined in this topical report, they can adjust 16 surveillance calibration frequencies based on the 17 analysis of the data they collect. They can also 18 credit the methods as a means of verifying transmitter 19 response time performance and to avoid certain 20 periodic time response testing for some pressure 21 transmitters, not all of them.
22 The topical report also provides a method 23 for determining the maximum calibration interval which 24 is also based on the data, the online monitoring data 25 that is collected.
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127 1 So that's pretty much a synopsis of what 2 this topical report is. It's recently approved so we 3 haven't had any applicants reference it, but we do 4 expect some in the near future.
5 MEMBER REMPE: So what was the basis for 6 their assessment of extending the calibration 7 interval, because with some sensors they just fail for 8 other reasons or they degrade for other reasons that 9 are hard to detect. So did they just do like 1,000 10 and say -- and did they use different vendors, or how 11 did they decide what the basis for extending the 12 calibration interval was?
13 MR. STATTEL: That's a very good question.
14 So within this topical report they did provide a 15 significant amount of data that had been collected 16 over the course of 15-20 years at various plants. The 17 Sizewell plant in U.K. was one primary contributor to 18 this because they had implemented an online monitoring 19 program there. And so we looked at that data. And 20 essentially they had applied these methods. Also some 21 U.S. plants. I believe Vogtle 1 and 2 had applied 22 these methods as well.
23 So the data shows -- so they had performed 24 periodic calibrations and they found transmitters that 25 were out of cal over the course of those years. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
128 1 they basically went back in time and applied the 2 online monitoring methods because they had the data.
3 And so the question came would the online monitoring 4 have identified that same transmitter as being out of 5 calibration? And for the most part they did, right?
6 So essentially the plants had been performing the 7 periodic calibration of all their transmitters when 8 they really -- if they had been applying online 9 monitoring technologies they would have really only 10 had to do a fraction of those calibrations.
11 So it's a very large amount of savings to 12 the plants as far as sending technicians out to verify 13 calibrations when that can be done by doing the 14 comparisons of the signals from various transmitters.
15 Now catastrophic failures -- this topical 16 report also -- it used several different types of 17 transmitters, right? Barton, Rosemount were just two 18 of those. But again it's limited scope, so we're only 19 talking about differential pressure and pressure 20 transmitters. And the topical report includes a 21 failure modes and analysis of those types of 22 transmitters, right?
23 And so, now catastrophic failures, 24 typically those are easily identified even today 25 either through surveillance checks, channel checks NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
129 1 that operators perform once a day, for example, or in 2 a lot of cases when a transmitter fails it's just 3 immediately obvious.
4 Now the gradual failures, those are the 5 ones -- you're correct, those are more difficult to 6 detect and that's where we have a larger reliance on 7 those manual surveillances. And by performing this 8 online monitoring it's more of a continual comparison 9 that happens on a far more regular basis. And what we 10 found was that there were very few cases where 11 calibrations were needed of transmitters that would 12 not have been detected by this online monitoring.
13 MEMBER REMPE: So again from my background 14 I'm sure what you did -- I'm guessing what you did is 15 fine because I haven't looked at it, but if you really 16 wanted more perfection would there have been any 17 benefit if they'd done some cross-calibration with 18 other parameters like, okay, this particular sensor 19 was exposed to higher temperatures or seismic 20 accelerations or higher fluxes of something like that?
21 But basically your evaluated indicated they got most 22 of them. Was it 90 percent of the ones that needed to 23 be de-calibrated -- or re-calibrated but you guys --
24 they caught with this method is basically what 25 happened?
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130 1 MR. STATTEL: Well, I will mention the 2 methods are kind of limited. When we say cross-3 calibration, basically we're comparing signals from 4 multiple sensors that are measuring the same process.
5 Okay? So that's a limitation of this method, right?
6 MEMBER REMPE: Okay.
7 MR. STATTEL: Now I mentioned that we had 8 applied this for RTDs in the past.
9 MEMBER REMPE: Yes.
10 MR. STATTEL: That's commonly used. Now 11 in a typical plant there is like 22 RTDs all measuring 12 all the same temperatures, right? So it's not a big 13 stretch to say that if -- it's very unlikely that all 14 22 of those RTDs would drift in the same direction, 15 right?
16 For pressure transmitters what we find is 17 that typically there are four pressure transmitters or 18 eight transmitters that are measuring the same process 19 so you have a lot less comparison data to use. So 20 it's a little bit more difficult to apply those same 21 principles.
22 MEMBER REMPE: Okay. I'm just curious 23 about it, but thank you. I'll take a look at -- I 24 think that Christina sent us something and I'll go 25 through it in more detail. I just didn't have time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
131 1 before this meeting, but I am interested in what 2 they've been doing. Thank you.
3 MR. STATTEL: Yes.
4 CHAIR BROWN: Okay, Rich. Thank you. Go 5 ahead.
6 MR. STATTEL: All right. So the next 7 topical report I'll talk about is also a platform 8 report. Now Holtec is -- they're doing a design for 9 SMR-160. And they recently announced that they will 10 be using the MELTAC I&C platform for their safety-11 related systems. So I'm here to talk about the MELTAC 12 platform.
13 So MELTAC stands for Mitsubishi Electric 14 Total Advanced Controller. This is a computer-based 15 programmable logic controller that consists of a pre-16 defined set of hardware and software components that 17 can be assembled to produce a safety system 18 application such as reactor protection systems or 19 ESFAS systems. So it's not unlike the other platforms 20 that we've been discussing.
21 The MELTAC system processors are designed 22 to be loaded with plant-specific application software 23 to implement various nuclear plant safety system 24 functions. The scope of the staff's evaluation of the 25 MELTAC platform was very similar to what I discussed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
132 1 in the HFC platforms. The SE scope also included the 2 safety life cycle processes which are unique to the 3 MELTAC development for plant-specific applications.
4 I'll just mention there is one unique 5 feature of the MELTAC platform as opposed to the other 6 platforms we've evaluated, and that is that it 7 includes two different software program manuals, one 8 for platform software development and another software 9 program manual for plant application software 10 development.
11 So I know Member Brown had mentioned 12 before that these systems use common like operating 13 systems. And so this vendor -- and in our evaluation 14 we acknowledged that. So there's basically two 15 different development processes that we're looking at 16 here, one for the operating system, kind of the high-17 level functional characteristics of the platform, and 18 the other is for the plant-specific application 19 developments.
20 So that's the MELTAC platform in a 21 nutshell. Any questions on that topical report?
22 CHAIR BROWN: Kind of like your computer.
23 You got an operating system and then you have all 24 these other application softwares applied.
25 MR. STATTEL: That run underneath that.
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133 1 That's correct.
2 CHAIR BROWN: That run underneath that 3 operating system. So that's very similar. I don't 4 have any more questions on that.
5 Anybody else?
6 MEMBER HALNON: Yes, has that topical --
7 are you guys actively reviewing that right now?
8 MR. STATTEL: We have completed the 9 evaluation. We completed that in 2019.
10 MEMBER HALNON: For the MELTAC. But for 11 the Holtec SMR?
12 MR. STATTEL: Oh. Oh, the Holtec topical 13 report? No, I have not seen that. I don't know what 14 the status of that is.
15 MEMBER HALNON: Okay.
16 CHAIR BROWN: All right. Is that the last 17 slide? I think the last slide says goodbye or 18 something like that. Closing remarks. Is that where 19 we are, Eric?
20 MR. BENNER: That seems to be where we 21 are. So I don't want to belabor the discussion. I 22 think it's been a good discussion. I think going into 23 this my -- where I was at was that we wanted to make 24 sure the Committee was fully aware of all the things 25 we were doing. I think the Committee is now fully NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
134 1 aware. I think there were some moments here where now 2 you're aware of some work in the -- particularly in 3 non-power reactors and topicals that haven't -- you 4 haven't typically seen before, so that spurred some 5 dialogue.
6 I also acknowledge that there are some 7 areas where there may continue to be some different 8 views between the Committee and the staff, and we are 9 committed to continuing to have open dialogue on all 10 those in forums such as this as well as the individual 11 forums to look at individual guidance documents and 12 individual licensing reviews.
13 So from my perspective anyway I believe 14 our objective for the meeting was accomplished, but I 15 certainly defer to the Committee to say if their 16 objectives for the meeting were accomplished. So I'll 17 end it with that.
18 CHAIR BROWN: Okay. Well, I'll save my 19 comments for later, for the end, but are there any 20 comments, go around the table, before I go to public 21 comments? Are there any comments from the members or 22 any closing remarks that they would like to make?
23 MEMBER REMPE: Charlie, this is Joy. I 24 thought this was a very good meeting to provide some 25 great perspective for us. And maybe I've missed it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
135 1 before, but I don't recall you doing something like 2 this before, so I appreciate your efforts to have this 3 as well as the staff efforts to participate.
4 CHAIR BROWN: Thank you.
5 Any other members?
6 (No audible response.)
7 CHAIR BROWN: Let me -- Christina, can we 8 get -- I'll go to the -- before I make my closing 9 comments I will go to public comments. Is the public 10 line open?
11 MS. ANTONESCU: Yes, not yet. If anybody 12 from the public would like to make comments, please 13 un-mute yourself.
14 CHAIR BROWN: But the line is open itself?
15 All they have to do is un-mute themselves, right?
16 MS. ANTONESCU: Yes, the line is --
17 (Simultaneous speaking.)
18 CHAIR BROWN: Okay.
19 MR. MOORE: This is Scott Moore, the 20 executive director. If any members of the public want 21 to make comments, you need to press *6 to un-mute 22 yourselves.
23 CHAIR BROWN: Oh, thank you, Scott.
24 MS. ANTONESCU: Yes, thank you.
25 CHAIR BROWN: Okay. Hearing none, I guess NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
136 1 we just go on into -- let me finish my closing remarks 2 just to amplify my fundamental reason for wanting to 3 schedule a meeting like this was that we needed to get 4 a better handle on what you all had on your plate that 5 we wanted to review and not -- and so that we could 6 get our toe in the water as a Subcommittee meeting on 7 those issues before it got too late, so that we didn't 8 hold up you all processing the Reg Guides and/or ISGs 9 and/or whatever other documents we need that you've 10 got on your table. I was a little surprised on 5.71, 11 but we've got that at least on the table now to 12 proceed with that review.
13 I was very, very pleased with the 14 substance of the meeting. There was excellent I think 15 interchange between the staff and us and our 16 questions. And I really do appreciate the work that 17 Jeanne and Mike and Rich put in to provide the 18 information they did. It was very extensive and I 19 think they did a very good job of getting the 20 positions; as well as you did, Eric, on where we 21 stand.
22 So I was pleased with the meeting. I do 23 want to close with just the last thought that we need 24 to be kept up to date in some way, shape, or form of 25 upcoming documents: Reg Guides, ISGs, BTPs, whatever NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
137 1 they are, because we do have a lot of stuff on our 2 plate and we do like to see those particularly 3 relative to safety -- reactor trip safeguards and/or 4 other process things that we need to take -- we need 5 to have a heads up so that we can schedule them and 6 not -- and get comments into you before you finalize.
7 And in my area I typically like to have at 8 least a choice of do we do it in public or not before 9 public -- I tend to like before public comments for 10 some like 5.71 and/or BTP 7-19, et cetera, as we went 11 through that process, which we did, at least in my 12 view, correctly.
13 So with that I just want to thank you all 14 for a very, very good presentation. Love interchanges 15 that get all the various viewpoints on the table and 16 I think it's particularly important for the members of 17 the Committee to hear the diverse views and thought 18 processes that the I&C folks have on how they're doing 19 their business. And I really do appreciate the input 20 that you gave us on that.
21 So with that if there are any other 22 comments from the Committee?
23 (No audible response.)
24 CHAIR BROWN: Hearing none, I will 25 consider this meeting over, complete, whatever the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
138 1 process is, and thank you very much.
2 (Whereupon, the above-entitled matter went 3 off the record at 12:48 p.m.)
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Periodic Update of Digital Instrumentation and Controls (DI&C)
Infrastructure and Licensing Activities Digital I&C ACRS Subcommittee Meeting September 22, 2021 Eric Benner, Director, Division of Engineering and External Hazards Jeanne Johnston, Chief, Long-Term Operations and Modernization Branch Michael Waters, Chief Instrumentation and Controls Branch Richard Stattel, Sr. Electronics Engineer - Instrumentation and Controls Branch
Purpose
Purpose:
Brief Digital Instrumentation and Controls (DI&C) ACRS Subcommittee on the status of key Digital I&C Regulatory Activities Outcome: ACRS Gains Better Understanding of Infrastructure and Licensing Activities Related to Digital I&C Topics I&C = Instrumentation and Controls ACRS = Advisory Committee on Reactor Safeguards 2
Agenda
- Opening Remarks
- Recent Guidance Updates
- Current Guidance Activities
- DI&C Licensing Activities
- Topical Reports
- Closing Comments 3
Digital I&C Infrastructure Activities Jeanne Johnston
Removing Barriers for Digital Modifications under 50.59
- RIS 2002-22, Supplement 1, Clarification on Endorsement of Nuclear Energy Institute Guidance in designing Digital Upgrades in Instrumentation and Controls Systems
- RG 1.187 Revision 3, added clarifications in response to post-promulgation comments
- Regional Inspector Training
- Proposed Digital OpE Smart Sample for Inspectors RG 1.187 - Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments RIS = Regulatory Issue Summary RG = Regulatory Guide 5 OpE = Operational Experience
Licensing Process for Digital Modifications
- Alternate Review Process in DI&C ISG-06 Rev.
2, Licensing Process (2018) - Defines the review licensing process associated with DI&C modifications requiring a license amendment
- February 2021 workshop conducted to discuss use of ISG 06, Revision 2 ISG = Interim Staff Guidance 6
Recent Guidance Updates Support Digital Upgrades
- Inspection Procedure (IP) 52003 - Digital I&C Modification Inspection
- Supports Digital Modifications, including those made under the Alternate Review Process (ARP) in DI&C ISG-06 Revision 2
- BTP 7-19 Revision 8 issued January 2021
- Staff will update this BTP to address lessons from upcoming licensing actions and attributes as recently directed by EDO BTP 7 Guidance for Evaluation of Diversity and Defense-in-Depth in Digital Computer-Based Instrumentation and Control Systems 7
Work Continues to Address Common Cause Failure
- NEI 20 Guidance for Addressing Software Common Cause Failure (CCF) in high safety-significant safety-related DI&C Systems
- Staff will need to evaluate if current CCF policy in SRM to SECY 93-087 needs to be updated before a potential endorsement
- Next version of NEI 20-07 to be provided end of September 2021 to adopt a risk-informed approach NEI = Nuclear Energy Institute SRM to SECY = Staff Requirements Memorandum to Commission Paper 8
Expanding Access to Digital Equipment through Commercial Grade Dedication (NEI 17-06)
- Provides guidance on using 3rd party certifications to support the evaluation of platform reliability aspects for commercial grade dedication (CGD) of digital equipment
- Version requesting endorsement submitted to NRC in February 2021
- Staff is within the process to endorse via a new regulatory guide 9
Expanding Access to Digital Equipment through Commercial Grade Dedication (NEI 17-06)
- NRC endorsed EPRI TR 106439, Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Applications, in 1997
- Staff engaged with NEI to validate the process by which a 3rd-party certification organization becomes accredited IEC = International Electrotechnical Commission Standard 61508-2010 (IEC 61508), Functional safety of electrical / electronic / programmable electronic safety-related systems.
EPRI = Electric Power Research Institute / TR - Topical Report 10
Strategic Updates to Regulatory Guides Continue RG 1.152 - (IEEE 7-4.3.2 from 2003 to 2016 Version)
- Incorporate new guidance for Secure Development and Operational Environment (SDOE) and include clarification to address ACRS feedback on BTP 7-19 Rev 8
- Retire ISG 04 Highly Integrated Control Rooms and Digital Communication Systems
- Include reference to RG 5.71 for cyber security and clarify uni-directional communication guidance RG 1.168 - (IEEE 1012 2004 to 2016 Version)
- Considering adopting the graded approach alternatives for the specified software integrity level (SIL) guidance
- Assessing feasibility of consolidating software criteria in RG 1.168, RG 1.169, 1.170, RG 1.171, RG 1.172, RG 1.173 RG = Regulatory Guides BTP = Branch Technical Position 11
Modernizing the Standard Review Plan Current State of Chapter 7, Desired State of Chapter 7, "Instrumentation and Controls" "Instrumentation and Controls" Standard Review Plan Standard Review Plan Safety focused and requirement specific System specific review guidance review guidance Repetitive - Several topics are covered in Streamlined approach - Topics covered in multiple areas of the SRP one area of the SRP 5 Sections - focused on safety and 8 System specific sections regulatory requirements for I&C systems Appendices content transferred to 4 Appendices regulatory requirement sections 4 BTPs - 13 BTPs deleted, system specific 17 BTPs content transferred to I&C system review guide Takes into consideration prior work of No consideration of the DSRS or DRG DSRS & DRG SRP = Standard Review plan DSRS = Design Specific Review Standard BTP = Branch Technical Position DRG = Design Review Guide 12
DI&C Licensing Activities Michael Waters
Waterford Core Protection Calculator System (CPCS) LAR
- Upgrade the existing digital CPCS to a Westinghouse Common Q based CPCS
- LA approval issued on August 24, 2021
- First use of ISG-06 "Alternate Review Process"
- Design Requirements and Architecture
- Fundamental Design Principles (e.g., Diversity and Defense in Depth)
- Vendor Oversight Plan and Software Development Plans
- Staff applying ARP Lessons to upcoming Turkey Point and Limerick LARs LAR = License Amendment Request Common Q = Common Qualified Platform TS = Technical Specifications ARP = Alternate Review Process 14
DI&C ISG-06 Lessons
- Highlights -
- Scope of Vendor Oversight Plan
- Crediting Self-Diagnostics
- Supplemental Basis EQ Test Results
- Integrated Review Team & Use of Risk Insights
- Use of Open Item Process
- Implementation of Licensing Review & Audits, Vendor Inspections, and Regional Inspections DI&C ISG Licensing Process EQ = Equipment Qualification 15
Turkey Point Digital Upgrade
- Credit for self-diagnostics to eliminate channel surveillance tests
- Diverse actuation system for certain functions
- Credit leak before break detection in diversity and defense-in-depth assessment
- Plant Installation in Spring 2023 for Unit 3 and Fall 2023 for Unit 4
- FPL intends to submit application in September 2021
- Staff will use ISG-06 Rev. 2 and BTP 7-19 Rev. 8 RPS = Reactor Protection System ESFAS = Engineered Safety Features Actuation System NIS = Nuclear Instrumentation System FPL = Florida Power and Light - A division of NextEra Energy 16
Limerick Digital Upgrade
- Exelon partnership with DOE Light Water Reactor Sustainability Program
- Installation in 2024 for Unit 1 and 2025 for Unit 2
- Exelon intends to submit application by September 2022
- Staff will use ISG-06 Rev. 2 and BTP 7-19 Rev. 8 DOE = Department of Energy ECCS = Emergency Core Cooling System RPS = Reactor Protection System PPS = Plant Protection System NSSSS = Nuclear Steam Supply Shutoff System 17
SHINE Operating License
- Integrated digital instrumentation and control systems
- Highly Integrated Process Instrumentation Controls System (PICS)
- Target Solution Vessel Reactivity Protection System (TRPS)
- Engineered Safety Features Actuation System (ESFAS)
- Radiation Monitoring System (RMS)
- Neutron Flux Detection System (NFDS)
- Staff using review guidance in NUREG-1537 NUREG 1537 - Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors 18
AFRRI System Upgrade
- Replacement of TRIGA reactor control system, reactor protection system, nuclear instrumentation, and control console
- Hybrid analog and digital system to control and protect the reactor
- Staff using review guidance in NUREG-1537
- Staff intends to issue license decision in 2022 AFRRI = Armed Forces Radiobiology Research Institute TRIGA = Training, Research, Isotopes, General Atomics 19
DI&C Topical Reports Richard Stattel
HFC
- Generic FPGA based Digital System Platform
- Topical Report Approved in June 2021
- Platform Features
- FPGA Based
- Builds upon previously approved HFC-6000 HFC = HF Controls, subsidiary of Doosan FPGA =Field Programmable Gate Array 21
Westinghouse Self Diagnostic Topical
- Common Q Platform and Component Interface Module (CIM) System Elimination of Technical Specification Surveillance Requirements
- Topical Report approved December 2020
- Topical Report Features
- Applies to Westinghouse Common Q platform-based systems
- Approves a process that can be used to credit Common Q self-diagnostics features as a basis for eliminating SRs for Common Q based safety systems
- Process was applied and has been approved for the Waterford Core Protection Calculator License Amendment CIM System = System providing the interface between the safety system and the plant components it controls Common Q = Common Qualified Platform SR = Surveillance Requirements 22
AMS Online Monitoring
- Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters
- Safety Evaluation completed in August 2021
- Topical Report Features
- Provides method that licensees can use to perform on-line monitoring of pressure transmitters to extend or defer calibrations
- Method includes processes for monitoring transmitter time response characteristics AMS = Analysis and Measurement Services Corporation 23
Holtec SMR-160 I&C Topical
- Topical Report Employing the Mitsubishi Electric MELTAC Technology for the SMR-160 Instrumentation and Controls
- MELTAC Topical Report approved in May 2019
- Uses computer microprocessor and FPGA based programmable logic controller (PLC) technology
- Consists of pre-defined set of hardware and software components developed specifically for nuclear applications.
MELTAC= Mitsubishi Electric Total Advanced Controller SMR = Small Modular Reactor FPGA =Field Programmable Gate Array 24
Closing Remarks