ML17212B410
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| ML17212B410 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/31/2017 |
| From: | Fregonese V Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| Holonich J, NRR/DPR, 301-415-7297 | |
| References | |
| NEI 01-01, NEI 16-16 | |
| Download: ML17212B410 (14) | |
Text
HOW 12 STAFF CONCERNS WITH Vic Fregonese NEI 01-01 ARE NEI ADDRESSED BY DRAFT APPENDIX D August 1, 2017 AND/OR DRAFT NEI 16-16
TOPICS FOR DISCUSSION
- Walk through the 11 points in the November 5, 2013 letter from NRC to NEI, plus 1 from July 10, 2014 public meeting NRC presentation
- Discuss key issues from these 12 points, dialogue with NRC staff on:
o Industry current position on the issue o Is this being adequately addressed?
o Are the NRC staff and industry aligned on the path forward?
1 - KEY POINTS FROM THE LETTER
- Definitions in need of revision, including hardware, firmware, computer, computer program, diversity, defense-in-depth, software tools
- Interpretation of simple devices
- The above definitions, except for software tools, are covered in other industry documents, such as EPRI 300200526*
- Simple device example is included in NEI 16-16 Appendix A
- Industry has submitted comments to NRC staff regarding the simple device definition, being currently addressed in the clarification to RIS 2002-22.
- Methods for Assuring Safety and Dependability when Applying Digital Instrumentation andControl Systems.
EPRI, Palo Alto, CA: 2016. 3002005326.
2 - KEY POINTS FROM THE LETTER
- Since NEI 01-01 was originally published, there have been significant changes in the regulatory guidance documents
- Guidance for performing modifications could be removed from NEI 01-01 For purposes of discussion, consider:
- Clarification to RIS 2002-22 will provide the latest NRC position for industry to consider when performing digital upgrades
- NEI 96-07 Appendix D is addressing the 50.59 aspects, and is not providing technical guidance for performing digital modifications
- NEI 16-16 is being developed to provide technical methodology for assessing and dispositioning common cause failure susceptibilities in digital systems
- Digital modification technical guidance is being developed by industry as part of the Standard Design Process effort.
3 - KEY POINTS FROM THE LETTER
- Operating experience indicates that NEI 01-01 is not being correctly interpreted
- Regulatory precedence and recent NRC interpretations (such as FPGA devices are digital) should be considered.
For purposes of discussion, consider:
- Industry team assembled to work on NEI 96-07 Appendix D and other IAP activities bring real time experience and lessons learned to the content in the NEI documents being developed.
- Follow on training activities for NEI 96-07 Appendix D will be designed to deliver a consistent message on the content to minimize interpretation issues. This will be coordinated with INPO.
- Industry is pursuing digital specific content as part of the Standard Design Process.
4 - KEY POINTS FROM THE LETTER
- Positions in the Safety Evaluation for RIS 2002-22 should be considered for incorporation into NEI 01-01 For purposes of discussion, consider:
- RIS 2002-22 is being clarified. In particular, the Attachment to the RIS 2017-xx is focused on the framework for adequate documentation of qualitative assessments that support the 50.59 process.
- NEI 96-07 Appendix D addresses adequately documenting the basis for the 10 CFR 50.59 review decision.
5 - KEY POINTS FROM THE LETTER
- Diversity and Common Cause Failure are not adequately addressed in NEI 01-01 For purposes of discussion, consider:
- RIS 2002-22 is being clarified. In particular, the Attachment to the RIS 2017-xx is focused on the framework for adequate documentation of qualitative assessments that support the 50.59 process.
- NEI 16-16 has been developed to specifically address the common cause failure issue.
6 - KEY POINTS FROM THE LETTER
- The examples in the RIS (RIS 2016-05) on Embedded Digital Devices (EDDs) should be addressed in NEI 01-01 For purposes of discussion, consider:
7 - KEY POINTS FROM THE LETTER
- NEI 01-01 does not adequately address the likelihood of failure due to software For purposes of discussion, consider:
- NEI 16-16 was developed to address an approach to analyze and disposition common cause failure concerns for digital upgrades.
- The clarification to RIS 2002-22 addresses likelihood thresholds that are applied as part of the qualitative assessment process.
8 - KEY POINTS FROM THE LETTER
- NEI 01-01 contains both technical and licensing guidance For purposes of discussion, consider:
- The clarification to RIS 2002-22 was developed to provide interim guidance on both technical and licensing areas
- NEI 96-07 Appendix D was developed to address the 50.59 guidance
- NEI 16-16 was developed to address the key technical issues, which are associated with common cause failure
- Industry is pursuing digital specific content as part of the Standard Design Process
9 - KEY POINTS FROM THE LETTER
- NEI 01-01 does not adequately address D3 analysis For purposes of discussion, consider:
- NEI 16-16 was developed to address an approach to analyze and disposition common cause failure concerns for digital upgrades
- The clarification to RIS 2002-22 addresses likelihood thresholds that are applied as part of the qualitative assessment process
- Industry provided comments on BTP 7-19 sections that address this topic
10 - KEY POINTS FROM THE LETTER
- NEI 01-01 does not adequately address coupling and independence For purposes of discussion, consider:
- NEI 16-16 was developed to address an approach to analyze and disposition common cause failure concerns for digital upgrades. This includes addressing non-safety systems which could impact the accident analyses.
- The clarification to RIS 2002-22 addresses this topic.
- Industry provided comments on BTP 7-19 sections that address this topic
11 - KEY POINTS FROM THE LETTER
- NEI 01-01 does not adequately address failure behaviors of digital systems For purposes of discussion, consider:
- NEI 16-16 was developed to address an approach to analyze and disposition common cause failure concerns for digital upgrades. Appendix A specifically addresses this topic.
- The clarification to RIS 2002-22 addresses this topic.
12 - KEY POINTS FROM 7/10/14 PRES
- How does the 50.59 process work for digital upgrades if there is no digital licensing basis described in the UFSAR?
For purposes of discussion, consider:
- The clarification to RIS 2002-22 addresses this topic.
- NEI 96-07, Appendix D emphasizes application of basic 50.59 process guidance from Rev. 1.