ML25063A290
| ML25063A290 | |
| Person / Time | |
|---|---|
| Issue date: | 03/05/2025 |
| From: | Duane Hardesty NRC/NRR/DANU/UNPL |
| To: | Holly Cruz NRC/NRR/DANU/UNPL |
| Hardesty D | |
| References | |
| EPID L-2023-NFG-0002 NEI 23-03 | |
| Download: ML25063A290 (3) | |
Text
MEMORANDUM TO:
Holly D. Cruz, Branch Chief Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Duane A. Hardesty, Senior Project Manager Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MARCH 4, 2025, PUBLIC MEETING TO DISCUSS SECTIONS OF THE NATIONAL ORGANIZATION OF TEST, RESEARCH AND TRAINING REACTORS, INC. PROPOSED NEI 23-03 GUIDANCE ON THE 50.59 PROCESS FOR DIGITAL APPLICATIONS (EPID: L-2023-NFG-0002)
On March 4, 2025, (Agencywide Documents Access and Management System Accession No. ML25041A221), the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting with the National Organization of Test, Research, and Training Reactors (TRTR) staff to continue to discuss endorsement of Nuclear Energy Institute (NEI) 23-03, Guidance on the 50.59 Process for Digital Applications. A list of attendees is provided as an enclosure to this memorandum.
The TRTR representatives provided edited responses to the NRCs previous comments for Section 4.3.1 and 4.3.2. The NRC staff and TRTR representatives discussed the NRC staff comments in Section 4.3.1 related to consistency of phrasing of software failure vs. failures or malfunction due to software and single failure vs. single point vulnerability. Additionally, the NRC staff asked that TRTR further explain how, when identifying the accidents affected by the proposed activity, introducing a new malfunction increases the overall likelihood of malfunctions.
In Section 4.3.2, the NRC staff had proposed significant additions for applying the guidance for criterion vi of 10 CFR 50.59, Changes, tests and experiments. TRTR disagreed with the additions and proposed that the revision would be better suited for NEI 21-06, Guidelines for 10 CFR 50.59 Implementation at Non-Power Production or Utilization Facilities. The NRC staff took an action to identify the distinct elements of the proposed edits and recommend a more targeted revision for NEI 23-03. The NRC commented that testing as a cause for change in the likelihood of a malfunction, as a result of a digital modification, was inconsistent. TRTR took an action to rephrase the bullet under identifying the effect of testing on the likelihood of any malfunctions.
CONTACT: Duane A. Hardesty NRR/DANU 301-415-3724 March 5, 2025 Signed by Hardesty, Duane on 03/05/25
H. Cruz TRTR accepted the edits proposed in Example 4-15 through Example 4-18. However, the NRC staff took an action to propose further edits in Example 4-15 to add clarification on applying the guidance on how to identify the accidents that have been evaluated in the updated final safety analysis report (UFSAR).
Representatives scheduled the next meeting for March 25, 2025, to continue review of NRC comments. There were no members of the public present in the meeting.
Enclosure:
As stated
ML25063A290 NRC-001 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME DHardesty HCruz DHardesty DATE 3/4/2025 3/5/2025 3/5/2025
Enclosure MEETING WITH NATIONAL ORGANIZATION FOR TEST, RESEARCH, AND TRAINING REACTORS March 4, 2025, 10:00 A.M. - 12:00 P.M.
LIST OF ATTENDEES NAME ORGANIZATION David Beaulieu U.S. Nuclear Regulatory Commission Norbert Carte U.S. Nuclear Regulatory Commission Duane Hardesty U.S. Nuclear Regulatory Commission Andrew Miller U.S. Nuclear Regulatory Commission Kamal Manoly U.S. Nuclear Regulatory Commission Brooke Gallagher U.S. Nuclear Regulatory Commission Christina Antonescu Advisory Committee on Reactor Safeguards Jill S. Monahan Pennsylvania State University Frances Pimentel Nuclear Energy Institute Jeffrey Geuther Pennsylvania State University Steven Richard Reese Oregon State University Andrew Smolinski Armed Forces Radiobiology Research Institute Ryan Marcum I&C Operative Randolph Strader National Institute of Standards and Technology Mary Miller Dominion Energy