COMMISSION BRIEFING SLIDES/EXHIBITS

BRIEFING ON DIGITAL

INSTRUMENTATION AND CONTROL

APRIL 7, 2008
Digital

Instrument & Controls

Industr Vmiew

April 7, 2008

Amir Shahkarami

Exelon, Senior Vice President

H U CL E A Engineering and Technical Services

I N E R G Y

IN S T I T U T E
Topics

" Objective

" Goals

" Status

*Conclusions

2
Objective

* Safety-focused application of digital technology

- Current operating plants

- Design certification

- New plants

- New fuel facilities

* Stable, predictable, and timely licensing process with

realistic guidance

* Enhance plant safety, availability, and reliability

N•'E I

3
Goals (l of 2)

* Short term - Interim Staff Guidance (ISG)

- Technically sound

- Practical to apply

- Appropriate detail of regulatory evaluations/reviews

* Long term - Final staff guidance

- Incorporate ISG content into final regulatory guidance

- Assure consistency with applicable industry codes and

standards

- Endorse related, detailed industry guidance

IIIE I4
Goals (2 of 2)

* Overall

Assure continued safe operations through each

nuclear facility's digital application

Change regulatory guidance to keep pace with

technology developments

Ensure changes to current positions are made in

accordance with appropriate regulatory process

and well communicated to stakeholders

tIE
Overview

* Project Management

- Project Plan (responsibilities, deliverables, due

dates)

- Pilot Project (validating ISGs, resolving issues,

sharing lessons learned, revising guidance)

NRC - Industry collaboration

* Steering Committee oversight

- On-going

- Industry involvement and support

6
Status (l of 4)

* Continued Attention

Manual Operator Actions

Fixed (30-minute) time period

versus

Method for determining acceptable time period

Documents requested

* What should be submitted and when

* Available vs. Reviewed vs. Docketed

7
Status (2 of 4)

* Continued Attention (cont)

- Review level-of-detail

Independent design review/re-verification

versus

Reasonable assurance determination

Diverse Actuation System

* Avoid expanding the scope to situations that do

not result in a significant safety benefit

•'%EI 8
Status (3 of 4)

Project Schedule

- NRC & Industry actively supporting into

2009

e Oversight I Steering Committee

e Resources / accountability / Task Working Groups

- Project deliverables in use now

* ISG-04 "Communications" used in staff review

e ISG-06-draft "Licensing Process" used in listing

documents for LAR

Rollover to permanent guidance stared

* ISG-01 "Cyber Security" is-being used in draft

rulemaking and Regulatory Guide

9
Status (4 of 4)

Project Progress

-Topical areas (TWGs) 7

- Problem Statements 25

-Acceptably completed 3

%,IE I 10
Conclusions

Project Plan

*Continue management oversightI

coordination

Pilot Project

* Validate Licensing Process. lSGs

-Highest importance and significance

e Demonstrate effective and timely regulator

process for licensing digital upgrades

Guidance

*Continue to refine and enhance regulatory

guidance, as necessary

*Develop a stable, predictable, and timely

licensing process with realistic guidance 11
Acronyms

" ATWS

" BTP

" D-3

" DAS

* DI&C

" ESPS

* ISG

* ITAAC

* LAR

* NEI

" RPS

" TWG

Anticipated Transient Without Scram

Branch Technical Position

Diversity & Defense-in-Depth

Diverse Actuation System

Digital Instrumentation and Control

Engineered Safeguards Protective System

Interim Staff Guidance

Inspections, Test, Analyses, and Acceptance Criteria

License Amendment Request

Nuclear Energy Institute

Reactor Protective System

Task Working Group

NE I 12
Duke Energy

Oconee RPS/ESPS Submittal

ApriI7 2008

Ron Jones

Senior Vice President

Nuclear Operations

Duke

Energy@
RPS/ESPS Upgrade

* Replaces existing analog Reactor

Protective System (RPS) and Engineered

Safeguards Protective System (ESPS).

" New system is AREVA TELEPERM XS

(TXS) digital protection system

• Currently installed in European nuclear

plants

" Involves changes to the Oconee licensing

basis and Technical Specifications

bDuke W•£nergy.
Implementation

e Target implementation dates are:

- Fall 2009

- Fall 2010

- Fall 2011

Oconee Unit 1

Oconee

Oconee

Unit 3

Unit 2

* Unit 1 TXS System is designed and

fabricated

* Factory Acceptance Testing will occur in

4 th Qtr 2008 with site delivery in early 2009

W•£nergy. Duke 3
Rationale for I&C Upgrade

* Duke is improving. key i&C systems by

adopting digital technology

• Duke faced with decisions to either reengineer existing systems or move to

modern digital technology

* Duke decided to upgrade RPS/ESPS in

order to enhance nuclear safety and

operational reliability

Duke 4

Energye
Digital Licensing Submittal

* Duke developing programs to address the

technical, quality, and regulatory

requirements of digital technology

* Duke and AREVA worked diligently to

prepare a licensing submittal responsive to

the NRC guidance

* Advanced system features have been a

challenge to existing regulatory guidance

Duke 5
Licensing Process

* Duke appreciates the efforts by the NRC

and NEI to address technology issues in

licensing digital upgrades

* Duke submittal should- benefit from the

Communications and Cyber Security ISGs

and hopefully the Licensing Process ISG

• A stable, timely and predictable digital

licensing process is essential to industry

confidence in upgrading I&C systems

Ov~nrg¥@
,,.tt .,--'na~nt-,• ,•

Digital I & C

New Plant Perspective

April 7, 2008

Mitch Lucas

Vice President- Luminant Power

Nuclear Engineering & Support

"k> ~
New Plant Feedback

*Improved reg ulatory guidance should

-Result in stal)le, predictable and timely licensing

;e~5

process

-Provide clarity in areas such as Human Factors,

D3, Cyber Security, Communications

-Provide clarity when using Standard

Plan - for both, NRC and Industry

-Help ensure consistencies in interpr

timely reviews

Review

etations and

1
• L•d?•

New Plant Feedback (cont.)

Clear understanding of NRC expectations will

help new plant designs & licensing efforts

In general, to-date, new plants have not. identified

conflicts with issued guidance

" Manual -Operator Actions Methodology

endorsement by US NRC staff (alternative to the

30 minute criterion) (on-going)

" Need 'clarity on DI&C submittals vs. audits for

ITAAC closure

. .~

~, 2
New Plant Feedback (cont.)

* For the next 2+ years, Industry feedback

mechanism to the DI&C Steering Committee is

recommended

-Where issued guidance appears to require

additional clarifications regarding consistency in

interpretation

-When new issues are identified

clarifications

needing

Pilot projects to validate

guidance and help build

effectiveness of issued

confidence in the process

N ~ ~.

4 
Summary

S Digital I&C will enhance safety, reliability

and human performance in new plants

E Joint NRC/Industry efforts will result in a

stable, predictable and timely licensing

process for new plants

*improved guidance with consistent

interpretation will result in efficiencies in

terms of resources and time for both, new

plants and NRC

:,:ii'f.:,,,d
US NRCLE •-"- "" UNITED STATEs -NULEAR REGULATORY COMMISSION

x Protecting People and the Environment

Briefing on Digital

Instrumentation anu

Controls

April 07, 2008
Agenda

Introduction

Review of Issued

Interim Staff Guidance

Use of Interim Staff Guidance

and Operating Experience

Review of Ongoing Efforts

Path Forward

J. Grobe

R. Croteau

P. Hiland

M. Mayfield

J. Grobe

2
Digital Instrumentation ana

Controls Steering Committee

*Task Working Groups - Group

- Group

- Group

1:

2:

3:

- Group 4:

- Group 5:

Cyber Security

Diversity and Defense in Depth

Risk-Informed Digital

Instrumentation and Control

Highly-Integrated Control Room

Communications

Highly-Integrated Control Room

Human Factors

Licensing Process

Fuel Cycle Facilities

- Group

- Group

6:

7:

3
Digital Instru entation and

Controls Steering Committee

* Activities Since July 2007

- Human Capital Investment

" Hring.

" Training

" Graduate Fellowship Program

4
Digital Instru entation and

Controls Steering Committee

Activities Since July 2007 (cont.)

- Task Working Group Accomplishments

* 32 Public Meetings

* 4 Interim Staff Guidance Documents issued

* Fuel Cycle Task Working Group Established

- Project Plan Revised

- 4 Industry White Papers Received

5
Digital Instrumentation and

Controls Steering Committee

Issued Interim Staff Guidance Documents

- September 2007: Diversity & Defense In

Depth

- September 2007: Highly Integrated

Control Room - Communications

- September 2007: Highly Integrated

Control Room - Human Factors

- December 2007: Cyber Security

6
Digital Instrumentation and

Controls Steering Co ittee

Remaining Interim Staff Guidance Documents

- 2008: Probabilistic Risk Assessments

Licensing Process

Manual Operator Actions

Fuel Cycle Facilities

2009: Licensing Process With Cyber

Security

7
Digital Instrumentation and

Controls Steering Commi

* Interfaces

-ACRS

- Other Agencies and Industries

- International Organizations

8
Issued Interi Staff Guidance.

Diversity and Defense-in-Depth

P rotection Against Common-Cause

Failures

* Software Error may Affect all

Divisions

9
Issued Interim Staff Guidance:

Diversity and Defense-in-Depth

* Applicant Should Perform Analysis

" Backup Capability SDiverse Actuation System

SManual Actions

10
Issued Interim Staff Guidance.

Highly-Integrated Control

Room Communications

Describes Acceptable Approach:

- Interdivisional Communications

Multidivisional Control and Display

Stations

- Command Prioritization for Safety

-over Non-Safety Functions

11
Issued Interim Staff Guidance.

Highly-integrated Control

Room Human Factors

* Com uter-Based Procedures

Backup Procedure

Operator Should Always be in Control

" Minimum Inventory

12
issue Staff

Guidance:w Cyber Security

SRegulatory Guide

.NEI Guidance -Al

* Table Correlating

the RG

eEither Acceptable

- Safety Systems

I Plant Systems

NEI Guidance witch

13
use Ciomaterim Staff tGuiance

ISG-04: 'Comunications

* Using for Prioritization and

Control Module Topical Report Review

* Interim Staff Guidance is

Providing a Clear Roadmap

14
use of Interim Staff Guidance

Oconee Application

" Digital ReactorTrip System and

Engineered Safety Feature

Actuation System Modification

" Review Design Features Using

ISGs

" Pilot Draft iSG-06: Licensing

Process

" Developing Inspection Procedure

15
Operating Experience

* National and International Data

Bases

" CCFs are a Valid Concern

" Limited Level of Detail

SContinuing Review of Nuclear and

Non-Nuclear Data

16
operating Experience DI&C Events

* Domestic Power Reactor- Failed

Feedwater Control 'System

Complications During Recovery

* Domestic Fuel Cycle Facility- Digital

Control System Re-|nitialization of

System Configuration

* Foreign Power Reactor -- Digital

Relays Delay in Disconnecting Main

Generator

17
Ongoing Efforts

* Risk Informing Digital I&C

New Reactor Digital I&C PRA ISG is

Near Completion

PIan for Risk Insights

Active Interactions with Industry

18
Ongoing Efforts

Alternative Process to 30 Minute

Criteria

Operator Action to Cope with

Common Cause Failures

-Human Factors TWG

-Issue ISG 'in 2008

19
Ongoing Efforts

SFuel Cycle Facilities

-Project Plan has been Developed

- Interacting.with the Industry to

Develop Guidance

20
Path Forward

" Issue Interim Staff Guidance

Documents

" Revise Interim Staff Guidance as

Neededl

" Address Long Term Actions to

Update Regulatory Infrastructure

21
Acronyms

ACRS

CCF

DI&C

ISG

NEI

PRA

QA

RG

TWG

Advisory Committee- on Reactor Safeguards

Common Cause Failure

Digital Instrumentation and Control

Interim Staff Guidance

Nuclear Energy Institute

Probabilistic Risk Assessment

Quality Assurance

Regulatory Guide

Task Working Group

22