ML24219A256
| ML24219A256 | |
| Person / Time | |
|---|---|
| Issue date: | 07/15/2024 |
| From: | O'Driscoll J NRC/NRR/DANU |
| To: | Nesbit S LMNT Consulting |
| References | |
| Download: ML24219A256 (1) | |
Text
From:
James O"Driscoll To:
"steve.nesbit@lmnt-consulting.com"; Ossy Font Cc:
"Brandon Chisholm"; "FACEMIRE, Jon"; Steven Lynch (They/Them/Theirs); Anders Gilbertson (He/Him/His);
Nanette Valliere (She/Her)
Subject:
RE: RE: Regulatory Guide 1.253 Clarification C.5.d Date:
Monday, July 15, 2024 3:37:00 PM Hi Steve, Thanks for your response. We will track this issue as well for consideration of a clarification in the next revision to the RG.
Here is some more detail on C.5.d-
NEI 18-04, Rev 1, section 5.9.7 addresses the evaluation of changes to defense-in depth as part of the Risk-Informed and Performance-Based Decision-Making Process. It states For each iteration of the design evaluation lifecycle in Figure 5-4, the DID evaluation from the baseline will be re-evaluatedbased on a review to determine which programmatic or plant capability attributes have been affected for each layer of defense. Changes that impact the definition and evaluation of LBEs, safety classification of SSCs, or risk significance of LBEs or SSCs will need to have the DID adequacy re-evaluated and the baseline updated as appropriate.
RG 1.253, clarification C.5.d states in part Guidance for the change control process for the SAR, including ensuring the design and construction of defense-in-depth features remains adequate (i.e., up to issuance of an operating license), is addressed in NEI 18-04, Revision 1 as endorsed by RG 1.233. This clarification is referring to section 5.9.7 of NEI 18-04, Revision 1.
Theremainder of this clarification is simply stating the fact that additional guidance regarding an FSAR change control process is a work in progress. This is referring to TIRICE.
The phrase in the first sentence Guidance for the change control process for the SAR may be a little misleading in that the sentence is only referring to maintaining the adequacy of DID and updating it as necessary as the design progressesthrough subsequent iterations of the overall design evaluation lifecycle. If such a change during the CP stage was determined topotentially impact the DID baseline,it may need to be incorporated as a change to the original PSAR text as part of the process to develop the OL application FSAR. Is not meant to imply that the SAR requires ongoing updatingduring the CP stage.
The clarification was intended to address NEI 21-07, theTwo-Step Licensing (CP Content) in Chapter 4 which states that "It will not be practical to address programmatic DID (Section 4.2.2) and the integrated evaluation of DID adequacy (Section 4.2.3) in the PSAR, and those areas should be reserved for the FSAR developed as part of the OL application unless fundamental to the CP LMP-based affirmative safety case envelope." The clarification C.5.d (first sentence) was added to support this NEI 21-07 statement.
From: steve.nesbit@lmnt-consulting.com <steve.nesbit@lmnt-consulting.com>
Sent: Friday, June 14, 2024 2:06 PM To: James O'Driscoll <James.O'Driscoll@nrc.gov>; Ossy Font <Ossy.Font@nrc.gov>
Cc: 'Brandon Chisholm' <bmchisho@southernco.com>; 'FACEMIRE, Jon' <jwf@nei.org>; Steven Lynch (They/Them/Theirs) <Steven.Lynch@nrc.gov>
Subject:
[External_Sender] RE: Regulatory Guide 1.253 Clarification C.5.d
Jim, thanks for getting back to us about this.
I want to be clear that we do not agree with your assessment of the Clarification C.5.d issue.
Clarification C.5.d is incorrect because it states that change control guidance for the SAR is provided in NEI 18-04 Rev. 1. As we noted, NEI 18-04 provides no such guidance. Moreover, the specific guidance in NEI 21-07 that is being "clarified" by Clarification C.5.d is never identified. The net result of these two facts is Clarification C.5.d will likely confuse users of the guidance.
Fortunately, this is not a fundamental flaw, because Clarification C.5.d does not require specific actions on the part of the applicant. Based on prior conversations with NRC management, we understand the NRC intends to revise and update Reg Guide 1.253 and the ARCAP ISGs in the future. If that is the case, we plan to bring this topic up again within the context of the revision to RG 1.253; however, at this time we are suggesting that the staff should take note of this Clarification C.5.d concern and address it in those future conversations.
Steve Nesbit LMNT Consulting (704) 578-5817 steve.nesbit@lmnt-consulting.com
From: James O'Driscoll <James.O'Driscoll@nrc.gov>
Sent: Friday, June 7, 2024 7:15 PM To: steve.nesbit@lmnt-consulting.com; Ossy Font <Ossy.Font@nrc.gov>
Cc: 'Brandon Chisholm' <bmchisho@southernco.com>; 'FACEMIRE, Jon' <jwf@nei.org>; Steven Lynch (They/Them/Theirs) <Steven.Lynch@nrc.gov>
Subject:
RE: Regulatory Guide 1.253 Clarification C.5.d
Hi Steve, Thanks for reaching out.
As you know, we are working with you and others on TIRICE and TIMaSC the result of these efforts would provide comprehensive guidance on the change processes associated with the licensing basis and the supporting integrated risk evaluation.
The purpose of the clarification was to make clear that the change processes themselves is not the subject of the RG 1.253.
The language in C.5.d also communicates that the subject for the need for change and a change process is inherent in the LMP based approach. These are discussed relative to role of the IDPP to evaluate both the design and the underlying risk evaluation to identify needed changes.
We look forward to continuing to work with you and others to develop actionable change processes to support the LMP.
- Thanks,
Jim ODriscoll Project Manager Advanced Reactor Policy Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission James.ODriscoll@nrc.gov l (301) 415-1325 Mail Stop O-6A51M In-Office: Tuesdays, Wednesdays Remote: Mondays, Thursdays, Fridays
From: steve.nesbit@lmnt-consulting.com <steve.nesbit@lmnt-consulting.com>
Sent: Wednesday, May 29, 2024 2:14 PM To: James O'Driscoll <James.O'Driscoll@nrc.gov>; Ossy Font <Ossy.Font@nrc.gov>
Cc: 'Brandon Chisholm' <bmchisho@southernco.com>; 'FACEMIRE, Jon' <jwf@nei.org>
Subject:
[External_Sender] Regulatory Guide 1.253 Clarification C.5.d
Good afternoon, Im sending this note on behalf of Southern Company and in coordination with the Nuclear Energy Institute. I work as a contractor to Southern Company on projects related to the regulatory framework for advanced reactors, including the Technology Inclusive Content of Application Project (TICAP) which produced NEI 21-07.
This note follows up on a discussion at the May 23, 2024 Advanced Reactor Stakeholder meeting concerning Regulatory Guide 1.253. Specifically, the TICAP team is seeking a better understanding of the NRC intent and basis for Regulatory Guide 1.253 Clarification C.5.d.
Clarification C.5.d is repeated in its entirety below.
Clarification: Guidance for the change control process for the SAR, including ensuring the design and construction of defense-in-depth features remains adequate (i.e., up to issuance of an operating license), is addressed in NEI 18-04, Revision 1 as endorsed by RG 1.233.
Additional guidance related to change control for the FSAR following issuance of the operating license is under development and the NRC is not taking a position on this topic at this time. The staff may address such change control processes in future regulatory actions, including possible rulemakings, license conditions, and development of guidance documents.
The clarification states the change control process for the SAR is addressed in NEI 18-04, Revision
- 1. However, the words change control are in NEI 18-04 in only two places. The first, Table 4-1, is associated with SSC categorization. The second, Section 5.9.6 (p. 79), relates to the DID baseline and refers to 10 CFR 50.59, which is for facility modifications, not the SAR. To the best of our knowledge, there is no guidance for the change control process for the SAR in NEI 18-04. Can you reference a specific section and page of NEI 18-04 where the information addressing SAR change control resides?
Also, Clarification C.5.d relates to NEI 21-07 Chapter 4, Integrated Evaluations. Chapter 4 makes no mention of change control of anything. To what specific part of NEI 21-07 is Clarification C.5.d intended to apply?
As it currently stands, we do not believe Clarification C.5.d is either understandable or actionable for applicants.
We note that NEI commented on an earlier version of Clarification C.5.d as was provided in the draft version of Reg Guide 1.253 (see NEI Comment 36 on page 53 of the ARCAP/TICAP comment table attached to the August 10, 2023 NEI comment letter). One of the points made in that August 10, 2023 comment is that we do not believe NEI 21-07 (or the associated reg guide) is the appropriate place for guidance on the change control process for the SAR.
We feel that an interactive discussion with the NRC would be the appropriate next step.
Thank you for your consideration of this request.
Steve Nesbit LMNT Consulting steve.nesbit@lmnt-consulting.com 704-578-5817