ML23325A063
| ML23325A063 | |
| Person / Time | |
|---|---|
| Issue date: | 12/21/2023 |
| From: | Marshall M NRC/NRR/DORL/LPL1 |
| To: | |
| Shared Package | |
| ML23325A066 | List: |
| References | |
| EPID L-2023-NNR-0007 | |
| Download: ML23325A063 (1) | |
Text
December 21, 2023 LICENSEE: n/a FACILITY: n/a
SUBJECT:
SUMMARY
OF NOVEMBER 14, 2023, INFORMATION PUBLIC MEETING ON DRAFT REVISION 9 TO BRANCH TECHNICAL POSITION 7-19 (EPID L-2023-NNR-0007)
On November 14, 2023, an information meeting with a question-and-answer session was held between the U.S. Nuclear Regulatory Commission (NRC) and external stakeholders through video conference. The purpose of the meeting was to provide external stakeholders an opportunity to ask NRC staff questions about the draft revision to Branch Technical Position (BTP) 7-19, Guidance for Evaluation of Defense in Depth and Diversity to Address Common-Cause Failure Due to Latent Design Defects in Digital Safety Systems. The draft revision was published and made available for public comment on October 24, 2023. The meeting notice and agenda, dated October 24, 2023, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML23296A080. A list of attendees is provided as Enclosure 1. Copies of the draft revisions were made available to external stakeholders prior to the meeting at ADAMS Accession Nos. ML23222A237 and ML23222A219. A copy of the presentation used by the NRC staff during the meeting is available at ADAMS Accession No. ML23305A167.
The NRC staff informed the meeting participants that public comments on the draft revision would not be collected during the public meeting. The NRC staff informed the meeting participants that public comments should be provided through regulations.gov using the Docket ID NRC-2023-0181. The NRC staff informed the meeting participants that the public comment period on the draft revision ends on November 24, 2023.
The NRC staff provided a high-level overview of the direction to the NRC staff in SRM-SECY-22-0076, Expansion of Current Policy on Potential Common-Cause Failures in Digital Instrumentation and Control Systems (ML23145A176). The NRC staff informed external stakeholders that the revisions to the BTP 7-19 were limited to the changes needed to implement the direction in SRM-SECY-22-0076. The NRC staff described the substantive changes in the draft Revision 9 to BTP 7-19. The substantive changes included:
Revisions to Section B.1.1 to reflect the updated four points in SRM-SECY-22-0076 Revisions to Section B.1.2 for clarification of critical safety functions Revisions to Section B.3.1.3 for evaluation of alternative approaches Addition of Section B.3.4 for evaluation of risk-informed D3 assessment
Revisions to Section B.4 for evaluation of different approaches for meeting Point 4 Addition, at the end, of four flowcharts to facilitate NRC staff review Members of the public were in attendance. During the question-and-answer portion of the meeting, the following statements1 were made to and questions were asked of the NRC staff:
BTP 7-19 is complex and challenging to navigate.
Multiple terms are used interchangeably, which can create confusion.
What is the intended scope of BTP 7-19? Is it intended to cover non-safety systems?
The title of BTP 7-19 does not indicate that non-safety systems can fall within the scope of the document.
The acceptance criteria in Section B.3.1.3 does not appear to be consistent. The words correct and complete should be replaced with credible and bounding.
Guidance for advanced reactors and operating reactors seem to be mixed in BTP 7-19.
Is the review guidance in BTP 7-19 applicable to advanced reactors?
Can the NRC staff explain the use of probabilistic risk assessment (PRA) model, PRA maintenance, and PRA upgrade in Section B.3.4.2? Should definitions of those terms be included in BTP 7-19?
The review of intersystem common cause failure modelling would go beyond the requirements in the American Nuclear Society standards for PRA.
Assuming an intersystem common cause failure would lead to over conservatism in the analysis.
There appears to be three different approaches in BTP 7 not one graded approach.
The graded approach discussed seems to be limited to the new risk-informed approach.
1 Statements and questions are paraphrased.
Public meeting feedback forms were not received. No regulatory decisions were made during the meeting. Please direct any inquiries to me at 301-415-2871, or michael.marshall@nrc.gov.
/RA/
Michael L. Marshall, Jr, Senior Project Manager Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosure:
List of Attendees
LIST OF ATTENDEES NOVEMBER 14, 2023, INFORMATION PUBLIC MEETING ON DRAFT REVISION 9 TO BRANCH TECHNICAL POSITION 7-19 (EPID L-2023-NNR-0007)
Name Organization Samir Darbali U.S. Nuclear Regulatory Commission (NRC)
Michael Marshall NRC Carla Roque-Cruz NRC Kate Lenning NRC Mary Presley Electric Power Research Institute James Chamberlain Southern Nuclear Company Shilp Vasavada NRC David Herrell MPR Associates Frank Hope Jensen Hughes Jana Bergman Curtiss Wright Christina Antonescu NRC Steven Alferink NRC Joseph Ashcraft NRC Christopher Phillips Paragon Philip Tarpinian Constellation Nuclear Eric Bowman NRC David Desaulniers NRC Steven Pope -----
David Heinig Sargent & Lundy Geno Keller Talen Energy Undine Shoop NRC Mike Wiwel -----
Ismael Garcia NRC Paul Hunton Idaho National Laboratory Tony Nakanishi NRC Michael Swim NRC Daniel Silverstein NRC Brayden Gordy -----
Sergiu Basturescu NRC Robert Chenkovich Dominion Energy Steve Wyman NRC Alexander Bowman Tennessee Valley Authority Alan Campbell Nuclear Energy Institute Jason Paige NRC Brian Mount Dominion Energy Sunil Weerakkody NRC Francis Mascitelli Constellation Nuclear Ming Li NRC Doug Eskins NRC Ho Thu Dominion Energy Enclosure
Name Organization Warren Odess-Gillett Westinghouse Dinesh Taneja NRC Gerond George NRC Calvin Cheung NRC Jack Zhao NRC Sunwoo Park NRC Christopher Cook NRC Bradley Dolan Tennessee Valley Authority Richard Supler ENERCON Ron Jarrett Paragon Golub, Pareez Sargent & Lundy Derek Halverson NRC Sheldon Clark NRC Han Bao Idaho National Laboratory John Lane NRC Andrea Kock NRC Mary Miller Dominion Energy Norbert Carte NRC William Catullo Paragon Mauricio Gutierrez NRC Ian Jung NRC Eric Benner NRC Khoi Nguyen NRC
Package, ML23325A066 Meeting Notice, ML23296A080 Handouts, ML23305A167 Meeting Summary, ML23325A063 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DEX/ELTB/BC NRR/DORL/LPMB/BC NAME MMarshall KZeleznock JPaige (DTaneja for) UShoop DATE 11/20/2023 12/04/2023 12/13/2023 12/20/2023 OFFICE NRR/DORL/LPL1/PM NAME MMarshall DATE 12/21/2023