ML25248A053
"Draft Meeting" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.
| ML25248A053 | |
| Person / Time | |
|---|---|
| Site: | 99902028 |
| Issue date: | 09/08/2025 |
| From: | Marshall M Licensing Processes Branch |
| To: | Jennivine Rankin Licensing Processes Branch |
| Shared Package | |
| ML25248A054 | List: |
| References | |
| EPID L-2025-NFN-0001 | |
| Download: ML25248A053 (5) | |
Text
September 8, 2025 MEMORANDUM TO:
Jennivine K. Rankin, Acting Branch Chief Licensing Projects Branch Division of Operating Reactors Licensing Office of Nuclear Reactor Regulation FROM:
Michael L. Marshall, Jr., Senior Project Manager /RA/
Plant Licensing Branch 1 Division of Operating Reactors Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JULY 23 AND 24, 2025, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE CONCERNING REVISION 1 TO NEI 20-07, DRAFT REVISION E2 (EPID L-2025-NFN-0001)
On July 23 and 24, 2025, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Nuclear Energy Institute (NEI) at NRC headquarters in Rockville, Maryland. The purpose of the meeting was for the NRC staff and NEI representatives to discuss the use of Draft Revision E2 of NEI 20-07, Guidance for Addressing Common Cause Failure in High Safety-Significant Safety-Related Digital I&C Systems. The meeting notice and agenda, dated July 7, 2025, are available in the NRCs Agencywide Documents Access and Management System at Accession No. ML25188A180. The meeting materials used by the NEI representatives during the meeting were NEI 20-07 (ML25198A311) and a NEI 20-07 tabletop example (ML25198A316). A list of meeting attendees is enclosed.
The NEI representatives described the substantive differences between Draft Revisions E1 and E2, which included:
Incorporation of Electric Power Research Institutes digital engineering guideline, hazards and consequence analysis in digital systems, and digital reliability analysis methodology changes.
Incorporation of NRC feedback from October 2024 public meeting (ML24303A040).
Additionally, using Figure 3 in Draft Revision E2, the NEI representatives described what information that an applicant or licensee using NEI 20-07 methodologies would be included in an application (e.g., license amendment request).
CONTACT: Michael Marshall, NRR/DORL/LPL1 301-415-2871
J. Rankin Using the NEI 20-07 tabletop example, the NEI representatives described how an applicant or licensee would:
Describe control structure hierarchy.
Identify stakeholder losses.
Identify system hazards.
Identify unsafe control actions.
Identify probabilistic risk assessment model characteristics for risk-informed decision making.
Evaluate risk-significance of postulated common cause failure.
Use sensitivity study demonstrating the impact of basic events.
Identify systematic loss scenarios associated with postulated common cause failures.
During the two-day meeting, the NRC staff made the following comments or suggestions to NEI:
It should be clear in NEI 20-07 which parts of the methodology must be followed versus which parts of the methodology are optional.
The level of detail addressing the risk-informed principles included in a requested licensing actions using the NEI 20-07 methodology should be comparable to the level of detail in a risk-informed completion time submittal.
Consideration should be given to include a sample calculation of core damage frequency and large early release frequency in NEI 20-07.
It should be clear in NEI 20-07 if applicants and licensees have the flexibility to change the scoring method described in NEI 20-07.
NEI 20-07 should be agnostic with regards to the licensing process (e.g., new, advance, operating) being used by an applicant or licensee.
In response to NRC staff questions, NEI stated:
The methodology in NEI 20-07 is intended to be a replacement for a defense-in-depth and diversity analysis.
Attachments 1 and 2 of the tabletop example would be included in an applicants or licensees requested licensing action using the methodology described in NEI 20-07.
No regulatory decisions were made during the meeting. No public meeting feedback forms were received. Please direct any inquiries to me at 301-415-2871 or michael.marshall@nrc.gov.
Project No: 99902028
Enclosure:
List of Attendees
Enclosure LIST OF ATTENDEES July 23 AND 24, 2025, MEETING WITH NUCLEAR ENERGY INSTITUTE CONCERNING REVISION 2 TO NEI 20-07, DRAFT REVISION E Name Organization July 23, 2025 Steven Alferink U.S. Nuclear Regulatory Commission (NRC)
Christina Antonescu NRC Sushil Birla NRC Norbert Carte NRC Jobin Binu Daniel NRC Samir Darbali NRC Louis Dumont NRC Ismael Garcia NRC Mauricio Gutierrez NRC Derek Halverson NRC Ian Jung NRC John Lane NRC Michael Marshall NRC Gerardo Martinez-Guridi NRC Sunwoo Park NRC Grace Pennington NRC David Rahn NRC Fanta Sacko NRC Dinesh Taneja NRC Larry Aaron Nuclear Energy Institute (NEI)
Alan Campbell NEI Marvin Morgan NEI Andrew Nack NEI Warren Odess-Gillett NEI KelIi Voelsing NEI Jana Bergman Curtiss Wright Alfred Hyde Dominion Energy Mary Miller Dominion Energy Sofia Bouhrizi EDF Simon Diemert Brad Dolan Jeff Joyce Andrew Nack Will Star Yi Yu Name Organization July 24, 2025 Steven Alferink NRC Christina Antonescu NRC Sushil Birla NRC Norbert Carte NRC Jobin Binu Daniel NRC Louis Dumont NRC Ismael Garcia NRC Mauricio Gutierrez NRC Derek Halverson NRC Ian Jung NRC Michael Marshall NRC Gerardo Martinez-Guridi NRC David Rahn NRC Dinesh Taneja NRC Larry Aaron NEI Alan Campbell NEI Marvin Morgan NEI Andrew Nack NEI Warren Odess-Gillett NEI Jana Bergman Curtiss Wright Alfred Hyde Dominion Energy Mary Miller Dominion Energy Sofia Bouhrizi EDF Andrew Nack Yi Yu
Package: ML25248A054 Meeting Notice: ML25188A180 Meeting Summary: ML25248A053 Meeting Materials: ML25198A311 and ML25198A316 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LLPB/LA NRR/DORL/LLPB/BC NRR/DORL/LPL1/PM NAME MMarshall DHarrison JRankin MMarshall DATE 09/05/2025 09/05/2025 09/08/2025 09/08/2025