ML20125A344
| ML20125A344 | |
| Person / Time | |
|---|---|
| Issue date: | 05/07/2020 |
| From: | Paul Kallan NRC/NRR/DNRL/NRLB |
| To: | Michael Waters NRC/NRR/DEX/EICB |
| Kallan P | |
| References | |
| Download: ML20125A344 (7) | |
Text
May 07, 2020 MEMORANDUM TO:
Michael D. Waters, Chief Instrumentation and Controls Branch B Division of Engineering and External Hazards Office of Nuclear Reactor Regulation FROM:
Paul B. Kallan, Project Manager /RA/
Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE APRIL 28th, 2020, CATEGORY 2, PUBLIC MEETING VIA SKYPE TO DISCUSS THE DRAFT APPROACH FOR A NEW REGULATORY GUIDANCE INFRASTRUCTURE FOR DIGITAL INSTRUMENTATION AND CONTROL (I&C)
The U.S. Nuclear Regulatory Commission (NRC) held a Category 2 public meeting via skype on April 28th, 2020, with the Nuclear Energy Institute (NEI) and other industry stackholders, to discuss the NRC staffs draft approach for achieving a simpler and more effective I&C regulatory infrastructure and get feedback from industry. No members of the general public participated via Skype during the meeting.
The public meeting notice dated April 9th, 2020, can be found in the NRCs Agencywide Documents Access and Management Systems (ADAMS) under Accession No. ML20099F336.
This meeting notice was also posted on the NRC public website.
Enclosed is the meeting agenda (Enclosure 1), list of participants (Enclosure 2), and a brief overview of the meeting (Enclosure 3). The staff presentations used during the meeting can be found at the ADAMS Accession Nos. given below:
Draft Approach for a New Regulatory Guidance Infrastructure for Digital Instrumentation and Control (I&C) - ML20113E839 Figure 1 Draft Approach for a New I&C Regulatory Guidance Infrastructure -
Enclosures:
- 1. Meeting Agenda
- 2. List of Attendees
- 3. Meeting Overview CONTACT: Paul Kallan, NRR/DNRL 301-415-2809
- via email NRR-106 OFFICE DNRL/NRLB:PM DEX/EICB:BC DNRL/NRLB:PM NAME PKallan MWaters PKallan (signed)
DATE 05/05/2020 05/06/2020 05/07/2020
U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 2 PUBLIC MEETING VIA SKYPE TO DISCUSS THE DRAFT APPROACH FOR A NEW REGULATORY GUIDANCE INFRASTRUCTURE FOR DIGITAL INSTRUMENTATION AND CONTROL (I&C)
PUBLIC MEETING AGENDA
April 28TH, 2020 Time Topic Speaker 2:00 PM
Introductions
NRC Staff/NEI Staff 2:10 PM Opening Remarks NRC Staff/NEI Staff 2:20 PM Discussion NRC Staff 2:50 PM Industry Input NEI/Industry 3:40 PM Opportunity for Public Comment Members of the Public 3:50 PM Closing Remarks NRC Staff/NEI Staff 4:00 PM Meeting Adjourn
U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 2 PUBLIC MEETING VIA SKYPE TO DISCUSS THE DRAFT APPROACH FOR A NEW REGULATORY GUIDANCE INFRASTRUCTURE FOR DIGITAL INSTRUMENTATION AND CONTROL (I&C)
LIST OF ATTENDEES April 28th, 2020 Name Organization Ismael Garcia U.S. Nuclear Regulatory Commission (NRC)
Eric Benner NRC Louise Lund NRC Michael Waters NRC Ronaldo Jenkins NRC Paul Kallan NRC Paul Rebstock NRC Philip McKenna NRC Booma Venkataraman NRC Michael McCoppin NRC Steven Arndt NRC Tom Bryce NRC David Rahn NRC Shakur Walker NRC Sushil Birla NRC Robert Krsek NRC David Beaulieu NRC Steven Cade NRC Dinesh Taneja NRC Bernie Dittman NRC Robert Roche Rivera NRC Stephen Geier Nuclear Energy Institute (NEI)
Stephen Vaugh NEI Maria Assard NEI Warren Odess-Gillett NEI John Conly Centrec Corporation Larry Nicholson Centrec Corporation Jana Bergman Curtiss Wright Jeff Hudson Digital Design Engineering Neil Archambo Duke Energy Ray Herb Southern Nuclear Operating Company David Herrell MPR Mark Burzynski Rolls Royce Nuclear
U.S. NUCLEAR REGULATORY COMMISSION CATEGORY 2 PUBLIC MEETING VIA SKYPE TO DISCUSS THE DRAFT APPROACH FOR A NEW REGULATORY GUIDANCE INFRASTRUCTURE FOR DIGITAL INSTRUMENTATION AND CONTROL (I&C)
On April 28th, 2020, a public meeting via skype with NEI and other industry stakeholders was held to discuss the NRC staffs draft approach for achieving a simpler and more effective I&C regulatory infrastructure and to get feedback from industry. No member of the general public participated via skype during the meeting.
The staff discussed the background including previous and ongoing actions striving to improve the clarity and cohesiveness of the I&C regulatory infrastructure. While the staffs focus was on tactical improvements, the staff mentioned that they are now transitioning to modernizing and streamlining the overall I&C regulatory infrastructure. Next, the staff discussed Figure 1, Draft Approach for a New I&C Regulatory Guide Infrastructure Framework where an evaluation would be required to assess the technical feasibility of updating or streamlining the regulatory guidance. The staff also mentioned that for the development of new standards, as well as the need to endorse International Electrotechnical Commission (IEC) standards, an evaluation would be required to determine if these can be endorsed via existing regulatory guides thus avoiding the need for developing new standards. Therefore, the intent of the meeting was not to discuss the details associated with each major area shown in the figure, as each one warrants its own separate evaluations and discussions. Instead, such discussions would be held during future public interactions regarding the topic of specific regulatory guidance updates. Finally, the staff discussed the highest NRC priority areas which are updating/streamlining Regulatory Guide (RG) 1.153, Criteria for Safety Systems, RG 1.152, Criteria for Safety System Computers, and, RG 1.168, Verification, Validation, Release & Audit for Digital Systems. At the end of this discussion, the staff asked NEI and industry for their comments and feedback including their highest priority areas. Their feedback included the following:
NEI stated that they supported endorsement of the Institute of Electrical and Electronics Engineers (IEEE) Std 603-2018, Criteria for Safety Systems for Nuclear Power Generating Stations, via the planned RG 1.153 update, and questioned whether an equivalent revision to 10 CFR 50.55a, Codes and Standards, would be pursued as well. The staff stated that the current plan does not involve rulemaking and instead, it would only involve an endorsement review to validate that the 2018 version of the standard would satisfy the current regulatory requirements.
Regarding the discussions associated with RGs 1.152 and 1.168:
o NEI questioned whether the planned RG 1.152 update to endorse the 2016 version of IEEE Std 7-4.3.2, "IEEE Standard Criteria for Programmable Digital Devices in Safety Systems of Nuclear Power Generating Stations," includes deletion of the guidance for Secure Development and Operational Environment (SDOE). The staff stated that the current plan is to delete such guidance from RG 1.152 as it is addressed in the 2016 version of the standard.
o NEI indicated that they supported endorsement of IEEE Std 1012-2016, Standard for System, Software, and Hardware Verification and Validation, via the planned RG 1.168 update for a scope of the endorsement limited to just the software Verification and Validation (V&V) processes specified in the standard.
NEI stated that hardware and system V&V processes, which are included in the standard, are already addressed by Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR 50 and, endorsement of these V&V processes via RG 1.168 update would be unnecessary and result in more onerous processes. The staff stated that limiting the scope of the endorsement to just the software V&V processes would be consistent with the scope of the 2004 version of the standard, which is currently endorsed by RG 1.168. However, such a determination would be performed as part of the evaluations required in support of the RG 1.168 update.
o NEI stated that they supported the planned evaluation to assess graded-approach alternatives for the specified software integrity level guidance. NEI questioned whether the staff could also evaluate graded-approach alternatives to the level of independence of software V&V specified in both RG 1.168 and IEEE Std 1012. Specifically, RG 1.168 endorses the IEEE Std. 1012-2004 guidance for technical independence or separation between the quality and design activities as it satisfies the Appendix B requirements.
o Related to the topic of a graded-approach, NEI stated that it may be worthwhile to consider the NRC endorsement of IEC standards such as 60880, Instrumentation and control systems important to safety - Software aspects for computer-based systems performing category A functions, and 62138, Nuclear power plants - Instrumentation and control systems important to safety -
Software aspects for computer-based systems performing category B or C functions, as such standards include a graded approach to software requirements. Specifically, NEI noted the IEC standards could provide an additional option for meeting the regulatory requirements. Meeting attendees discussed the option of having one RG endorsing the software-related IEEE standards and another endorsing the associated IEC standards. Staff noted this topic can be further discussed during future public meetings associated with specific RG updates.
o NEI suggested that the staff should also consider endorsing ASME NQA-1, Quality Assurance Requirements for Nuclear Facility Applications, which addresses software quality assurance among other topics, as an additional alternative for simplifying the I&C regulatory guidance infrastructure.
o NEI stated that they did not object to the consolidation of the software RGs and questioned whether there are sections/areas of the RGs that are redundant or could be consolidated. The staff stated that such a question would need to be addressed as part of the planned evaluations for consolidating the software RGs.
NEI questioned whether the draft approach for a new I&C regulatory guide infrastructure framework factored in lessons learned from other agencies and regulators. The staff stated that the draft approach did not directly implement any lessons learned from interactions with other agencies and regulators and it is difficult to compare standards for
different technologies. But the staff used and continues to use these lessons to inform the ongoing efforts for modernizing the I&C regulatory infrastructure.
NEI expressed their concerns with the current NRC approach of endorsing a specific version of a standard, which results in several of the key regulatory guides used for digital upgrades reflecting older version of the standards. The staff stated that the Office of Nuclear Regulatory Research is developing a strategy to speed up the standards endorsement process.
NEI staff also briefly discussed the plan and goals of NEI 20-07, which is intended to replace NEI 16-16, Guidance for Addressing Digital Common Cause Failure, (ADAMS Accession No. ML17135A253). NEI plans to have their first draft available by early summer 2020 and have a public meeting by late summer 2020.
At the end of the meeting, the staff opened the meeting to comments or questions from the general public. There were no comments or questions from the public.