ML23010A142
| ML23010A142 | |
| Person / Time | |
|---|---|
| Issue date: | 02/01/2023 |
| From: | Yamir Diaz-Castillo NRC/NRR/DRO/IQVB |
| To: | |
| References | |
| Download: ML23010A142 (16) | |
Text
NRC Regulatory Update Nuclear Oversight Conference February 1-2, 2023 Miami, FL Yamir Diaz-Castillo Quality Assurance & Vendor Inspection Branch / Office of Nuclear Reactor Regulation
Topics 2
Proposed Update to Regulatory Guide 1.28 Commercial-Grade Dedication Inspections at Licensees Status of Counterfeit, Fraudulent, and Suspect Action Items Potential Regulatory Issue Summary on Department of Energy Laboratories NEI 22-03 Quality Assurance Program Description Template IQVB Involvement in Digital I&C Reviews &
Inspections 2nd Town Hall Meeting on Vendor Oversight
Proposed Update to Regulatory Guide (RG) 1.28 3
Proposed Revision 6 to RG 1.28 is currently known as Draft RG DG-1403.
Revision 6 to RG 1.28 will have 3 new conditions Use of Revision 1 to NEI 14-05A for the use of the ILAC alternative.
Subpart 2.2 - Etching not allowed on Ni alloys, weld areas, or sensitized areas of stainless steel.
Subpart 2.5 - NRC approval needed for superseded or canceled Codes & standards referenced.
DG-1403 is presently out for internal concurrence.
After concurrence is complete, DG-1403 will be issued for public comment.
Once public comments are reconciled, DG-1403 will go out for internal re-concurrence and eventually issued as Revision 6 to RG 1.28.
Commercial-Grade Dedication Inspections at Licensees 4
First 2 inspections started this week: Grand Gulf and Cooper (January 30).
Every site will have an inspection at some point during the next 4 years.
NRC resources will include 3 NRC inspectors, 2 weeks on-site (210 hours0.00243 days <br />0.0583 hours <br />3.472222e-4 weeks <br />7.9905e-5 months <br /> of direct inspection).
3rd public meeting took place last week, NRC staff is open having another public meeting and will consider any input received.
Status of Counterfeit, Fraudulent, and Suspect (CFSI) Action Items 5
NRCs Office of Inspector General (OIG) conducted an audit of NRCs oversight of CFSI.
Report issued in February 2022 documented audit findings and recommendations.
Audit results found that NRC should improve its oversight of CFSI by: (1) clarifying and communicating how the NRC collects, assesses, and disseminates information regarding CFSI, and (2) improving staff awareness of CFSI.
Audit report identified 8 recommendations to address the OIGs audit findings.
Status of Counterfeit, Fraudulent, and Suspect (CFSI) Action Items 6
OIGs Audit Recommendations:
Develop processes and guidance to collect, process and disseminate CFSI information Communicate those processes Develop and agencywide approach for CFSI and identify the agencys primary objective regarding CFSI mitigation Define CFSI Include a CFSI category in the Allegation Management System Develop inspection guidance in inspection procedures Develop CFSI training Develop a knowledge management and succession plan.
Status of Counterfeit, Fraudulent, and Suspect (CFSI) Action Items 7
NRCs Actions to Address OIGs Audit Recommendations:
Develop an agency charter that documents objectives, approach and strategy for CFSI-related oversight of NRC regulated facilities and activities.
Incorporate definition of CFSI in formal NRC guidance documents.
Enhance current Technical Review Groups processes and documentation for collecting, evaluating, and disseminating CFSI events and communicating this process with applicable internal stakeholders.
Develop additional inspection guidance for CFSI-related oversight activities.
Engage internal stakeholders to raise awareness of CFSI risks and incorporate CFSI in applicable inspector qualification activities.
Include a category for CFSI in the Agencys Allegation Management System.
Potential Regulatory Issue Summary (RIS) on Department of Energy (DOE) Laboratories 8
DOE maintains the National laboratories as GOCOs
- Government Owned and Contractor Operated.
Contractors may be individual universities, university consortia, private companies, or nonprofits.
As such, DOE National laboratories are commercial entities for which an assessment must be performed.
Potential RIS on DOE Laboratories 9
When procuring an items or services for use in a safety-related application, licensees, applicants, and suppliers are responsible for:
verifying the effective implementation of the laboratories programmatic quality controls maintaining 10 CFR Part 21 responsibility.
Potential RIS on DOE Laboratories 10 NRC staff working on a RIS to document the staffs regulatory position.
RIS expected to go out for public comment in the Spring 2023.
Final RIS expected to be issued in the Fall 2023.
Quality Assurance Program Description (QAPD) Template - NEI 22-03 11 Nuclear Energy Institute (NEI) submitted NEI 22-03, Nuclear Generation Quality Assurance Program Description, to the NRC for review and approval.
NEI 22-03 intended to be a template for applicants to use NQA-1-2015 for QAPDs.
NEI withdraw the submittal during the NRCs acceptance review due to issues associated with implementing the last NEI 11-04 QAPD template.
IQVB Involvement in D&IC Reviews &
Inspections 12 Modernization of the NRCs Digital I&C infrastructure Obsolescence leading to increased desire to install modern DI&C systems DI&C Interim Staff Guidance (ISG)-06, Licensing Process, Revision 2 Alternate Review Process (ARP) - Early approval of License Amendment Requests with subsequent inspection of lifecycle activities such as design and testing (inspection at both vendor and licensee)
Completed first use of ARP process (Waterford 3 Core Protection Calculator System upgrade) 2022 Currently reviewing two additional LAR requests (Turkey Point and Limerick related to Reactor Protection System upgrades)
IQVB Involvement in D&IC Reviews &
Inspections 13 Recently completed development of RG 1.250 - Dedication of Commercial Grade Digital Instrumentation and Control Items for Use in Nuclear Power Plants Endorses NEI 17-06 guideline, Guidance on Using IEC 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications, Revision 1, issued December 2021 Credits Safety Integrity Level (SIL) certification process to satisfy survey activities specific to dependability characteristics for digital components/systems Relies on industry oversight of the SIL accreditation and certification bodies by NRC licensees Currently limited to certifications conducted by American National Standards Institute National Accrediting Board (ANAB)
IQVB Involvement in D&IC Reviews &
Inspections 14 NRC staff working on the development of revision to RG 1.152, Criteria for Programmable Digital Devices in Safety-related Systems of Nuclear Power Plants. (DG-1374)
Endorses Institute of Electrical and Electronics Engineers (IEEE) Standard 7-4.3.2-2016, IEEE Standard Criteria for Programmable Digital Devices in Safety Systems of Nuclear Power Generating Stations.
Major upgrade includes addition of guidance associated with Commercial-Grade Dedication of digital equipment.
Currently going through NRC internal concurrence process prior to public comment period.
2nd Town Hall Meeting on Vendor Oversight 15 Allows IQVB staff to engage in an open dialogue with external stakeholders to discuss issues of importance and provide guidance and clarification on these issues.
Virtual town hall, free to register, and will consist of a few presentations by the NRC staff followed by one or two Q&A sessions focused on QA topics Tentatively scheduled for the Summer 2023 (every 2 years)
Questions 16