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=Text=
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{{#Wiki_filter:Summary of Comments  
{{#Wiki_filter:Summary of Comments on 2018-01-23  
on 2018-01-23  
Draft RIS_KS.pdf
Draft RIS_KS.pdf
This page contains  
This page contains no comments  
no comments  
   
   
This page contains  
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no comments  
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Page: 3 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Page: 3Number: 1 Author: KenSc Subject:  
12:06:34 PM In the sentence directly before this one, the limitation  
Sticky Note Date: 01/24/2018  
12:06:34  
PM In the sentence  
directly  
before this one, the limitation  
regarding  
regarding  
not providing  
not providing  
new guidance  
new guidance is restricted  
is restricted  
to RPS and ESF. But in this sentence that limitation  
to RPS and ESF. But in this sentence  
is extended to all SSCs. This contradicts  
that limitation  
is extended  
to all SSCs. This contradicts  
subsequent  
subsequent  
sections  
sections of this RIS which provide new CCF guidance for other non-RPS/ESF  
of this RIS which provide new CCF guidance  
SSCs. Number: 2 Author: KenSc Subject: Highlight Date: 01/23/2018  
for other non-RPS/ESF  
10:39:52 PM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
SSCs. Number: 2 Author: KenSc Subject:  
Highlight
Date: 01/23/2018  
10:39:52  
PM  Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
9:03:14 AM ATWS is considered  
9:03:14 AM ATWS is considered  
in most FSARs, maybe all. So CCF due to a design flaw is  considered  
in most FSARs, maybe all. So CCF due to a design flaw is  considered  
in most, maybe all, FSARs. Number: 4 Author: KenSc Subject:  
in most, maybe all, FSARs. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
Date: 01/24/2018  
9:02:09 AM     
9:02:09 AM     
12
1 2
  Page: 4Number: 1 Author: KenSc Subject:  
  Page: 4 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Sticky Note Date: 01/24/2018  
12:07:45 PM The first paragraph  
12:07:45  
PM The first paragraph  
on Page 3 says this RIS is not applicable  
on Page 3 says this RIS is not applicable  
to RPS/ESF.  
to RPS/ESF. But this paragraph  
But this paragraph  
implies it would not be applicable  
implies it would not be applicable  
to any equipment  
to any equipment  
of equal or greater importance  
of equal or greater importance  
to RPS/ESF.  
to RPS/ESF. Importance  
Importance  
can be determined  
can be determined  
by the PRA. Equipment  
by the PRA. Equipment  
of equal or greater importance  
of equal or greater importance  
would typically  
would typically  
include load sequencers,  
include load sequencers, and accident monitoring  
and accident  
monitoring  
instrumentation  
instrumentation  
and controls  
and controls for manual actions credited in the TAA. So the original statement  
for manual actions credited  
in the TAA. So the original  
statement  
that says this RIS is not applicable  
that says this RIS is not applicable  
to RPS and ESFAS should be expanded  
to RPS and ESFAS should be expanded to encompass  
to encompass  
these additional  
these additional  
systems. Number: 2 Author: KenSc Subject:  
systems. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
Date: 01/24/2018  
9:06:19 AM     
9:06:19 AM     
1234
1 2 3 4
  Page: 5Number: 1 Author: KenSc Subject:  
  Page: 5 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Sticky Note Date: 01/24/2018  
12:08:20 PM We typically  
12:08:20  
view "failure to perform" as "no function at all". But equally important  
PM We typically  
view "failure  
to perform"  
as "no function  
at all". But equally important  
is performing  
is performing  
a design function  
a design function erroneously.  
erroneously.  
This is too often forgotten  
This is too often forgotten  
by digital designers.  
by digital designers.  
It should be clearly stated. Number: 2 Author: KenSc Subject:  
It should be clearly stated. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
9:15:39 AM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Date: 01/24/2018  
9:15:39 AM  Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
9:17:29 AM A failure of shared resources  
9:17:29 AM A failure of shared resources  
among safety control functions  
among safety control functions  
Line 113: Line 74:
unanalyzed  
unanalyzed  
malfunctions.
malfunctions.
  Number: 4 Author: KenSc Subject:  
  Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
Date: 01/24/2018  
9:13:15 AM     
9:13:15 AM     
12
1 2
  Page: 6Number: 1 Author: KenSc Subject:  
  Page: 6 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Sticky Note Date: 01/24/2018  
10:01:37 AM SECY 93-087 and BTP 7-19 constitute  
10:01:37  
AM SECY 93-087 and BTP 7-19 constitute  
current NRC policy on digital CCF. The current policy does not allow a conclusion  
current NRC policy on digital CCF. The current policy does not allow a conclusion  
that the likelihood  
that the likelihood  
Line 130: Line 87:
factors facilitate  
factors facilitate  
a conclusion  
a conclusion  
that the CCF is beyond design basis, but not that it requires  
that the CCF is beyond design basis, but not that it requires no further consideration.  
no further consideration.  
Another way of looking at this is that the current policy is that qualitative  
Another way of looking at this is that the current policy is that qualitative  
factors do not allow a conclusion  
factors do not allow a conclusion  
Line 137: Line 93:
is comparable  
is comparable  
to other sources of CCF that are not considered  
to other sources of CCF that are not considered  
in the FSAR. How can a RIS be used to change previous  
in the FSAR. How can a RIS be used to change previous NRC policy. I have heard some people say that the current NRC policy is only applicable  
NRC policy. I have heard some people say that the current NRC policy is only applicable  
to new plants. If that is true, which I don't believe it is, then how can the NRC create a new policy for operating  
to new plants. If that is true, which I don't believe it is, then how can the NRC createa new policy for operating  
plants that is different  
plants that is different  
than for new plants. This directly  
than for new plants. This directly contradicts  
contradicts  
the commissioners  
the commissioners  
direction  
direction  
in (SRM)-SECY-16-0070
in (SRM)-SECY-16-0070
  that the guidance  
  that the guidance for new plants and operating  
for new plants and operating  
plants should be the same. Number: 2 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
plants should be the same. Number: 2 Author: KenSc Subject:  
12:10:01 PM Dave, You told me that "sufficiently  
Sticky Note Date: 01/24/2018  
low" could only be reached with 4 factors, the fourth being an evaluation  
12:10:01  
PM Dave, You told me that "sufficiently  
low" could only be reached with 4 factors,  
the fourth being an evaluation  
of the "what if" malfunction  
of the "what if" malfunction  
results.  
results. This contradicts  
This contradicts  
your explanation  
your explanation  
of this RIS. If your interpretation  
of this RIS. If your interpretation  
is confused,  
is confused, the industry's  
the industry's  
interpretation  
interpretation  
is also going to be confused.
is also going to be confused.
 
   
   
This page contains  
This page contains no comments  
no comments  
   
   
This page contains  
This page contains no comments  
no comments  
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  Page: 9 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
  Page: 9Number: 1 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
9:38:55 AM Licensees  
9:38:55 AM Licensees  
will often conduct these evaluations  
will often conduct these evaluations  
Line 178: Line 122:
in revised design/analysis  
in revised design/analysis  
documentation.
documentation.
  Number: 2 Author: KenSc Subject:  
  Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
9:37:49 AM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Date: 01/24/2018  
9:37:49 AM  Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
9:40:45 AM Dave, This does not say that a failure must be postulated.
9:40:45 AM Dave, This does not say that a failure must be postulated.
  Number: 4 Author: KenSc Subject:  
  Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
Date: 01/24/2018  
9:40:15 AM     
9:40:15 AM     
12
1 2
  Page: 10Number: 1 Author: KenSc Subject:  
  Page: 10 Number: 1 Author: KenSc Subject: Highlight Date: 01/23/2018  
Highlight
10:53:30 PM  Number: 2 Author: KenSc Subject: Sticky Note Date: 01/23/2018  
Date: 01/23/2018  
10:53:57 PM No postulation  
10:53:30  
PM  Number: 2 Author: KenSc Subject:  
Sticky Note Date: 01/23/2018  
10:53:57  
PM No postulation  
of CCF.   
of CCF.   
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1 2 3 4 5 6
  Page: 11Number: 1 Author: KenSc Subject:  
  Page: 11 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Sticky Note Date: 01/24/2018  
9:47:22 AM This is technically  
9:47:22 AM This is technically  
incorrect.  
incorrect.  
Single failures,  
Single failures, by definition  
by definition  
are random, non-systematic  
are random, non-systematic  
failures.  
failures.  
An increase  
An increase in the likelihood  
in the likelihood  
of a single failure, does lower system availability, but it does not increase the likelihood  
of a single failure,  
of a CCF.  Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
does lower system availability,  
9:44:37 AM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
but it does not increase  
10:18:38 AM Should be NEI 01-01 Section 4.4.6. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
the likelihood  
10:18:44 AM  Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
of a CCF.  Number: 2 Author: KenSc Subject:  
10:04:39 AM This note just adds confusion  
Highlight
because it says that if a failure is not credible but not sufficiently  
Date: 01/24/2018  
9:44:37 AM  Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:18:38  
AM Should be NEI 01-01 Section 4.4.6. Number: 4 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
10:18:44  
AM  Number: 5 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:04:39  
AM This note just adds confusion  
because it says that if a failure is not credible  
but not sufficiently  
low likelihood  
low likelihood  
it must be considered.
it must be considered.
  Number: 6 Author: KenSc Subject:  
  Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
10:03:46 AM     
Date: 01/24/2018  
1 2 3 4 5 6
10:03:46  
  Page: 12 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
AM     
10:12:33 AM This contradicts  
123456
previous statements  
  Page: 12Number: 1 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:12:33  
AM This contradicts  
previous  
statements  
in this RIS and in NEI 01-01 which state to require no further consideration  
in this RIS and in NEI 01-01 which state to require no further consideration  
in 50.59, the failure likelihood  
in 50.59, the failure likelihood  
must be "comparable  
must be " comparable  
to other common cause failures  
to other common cause failures that are not considered  
that are not considered  
in the UFSAR".  Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
in the UFSAR".  Number: 2 Author: KenSc Subject:  
10:12:30 AM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Highlight
10:07:57 AM Yes, but the sentence above says that even if you have not reached the "sufficiently  
Date: 01/24/2018  
low" threshold, there are no new accidents  
10:12:30  
AM  Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:07:57  
AM Yes, but the sentence  
above says that even if you have not reached the "sufficiently  
low" threshold,  
there are no new accidents  
introduced  
introduced  
unless the failure is "as likely" as other failures  
unless the failure is "as likely" as other failures assumed in the FSAR. This is quite confusing.
assumed in the FSAR. This is quite confusing.
  Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
  Number: 4 Author: KenSc Subject:  
10:05:54 AM  Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Highlight
10:11:38 AM This contradicts  
Date: 01/24/2018  
previous statements  
10:05:54  
AM  Number: 5 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:11:38  
AM This contradicts  
previous  
statements  
in this RIS and in NEI 01-01 which state to require no further consideration  
in this RIS and in NEI 01-01 which state to require no further consideration  
in 50.59, the failure likelihood  
in 50.59, the failure likelihood  
must be "comparable  
must be " comparable  
to other common cause failures  
to other common cause failures that are not considered  
that are not considered  
in the UFSAR". Number: 6 Author: KenSc Subject: Highlight Date: 01/23/2018  
in the UFSAR". Number: 6 Author: KenSc Subject:  
10:57:32 PM     
Highlight
1 2 3 4 5 6 7 8 9 10
Date: 01/23/2018  
  Page: 13 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
10:57:32  
10:20:03 AM This contradicts  
PM     
12345678910
  Page: 13Number: 1 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:20:03  
AM This contradicts  
NEI 01-01 which says to require no further consideration  
NEI 01-01 which says to require no further consideration  
the failure likelihood  
the failure likelihood  
must be "comparable  
must be " comparable  
to other common cause failures  
to other common cause failures that are not considered  
that are not considered  
in the UFSAR", not as likely as those that are considered.
in the UFSAR", not as likely as those that are considered.
   Number: 2 Author: KenSc Subject:  
   Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
10:13:32 AM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Date: 01/24/2018  
10:21:57 AM Needs to also include ways of erroneous  
10:13:32  
AM  Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:21:57  
AM Needs to also include ways of erroneous  
performance.  
performance.  
You can argue that "failure"  
You can argue that "failure" encompasses "erroneous" but erroneous  
encompasses  
"erroneous"  
but erroneous  
is too often overlooked  
is too often overlooked  
by digital designers.
by digital designers.
  Number: 4 Author: KenSc Subject:  
  Number: 4 Author: KenSc Subject: Highlight Date: 01/23/2018  
Highlight
10:58:55 PM  Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Date: 01/23/2018  
10:27:10 AM This should say "which ones that are not as unlikely as failures not considered  
10:58:55  
PM  Number: 5 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:27:10  
AM This should say "which ones that are not as unlikely  
as failures  
not considered  
in the FSAR" or "which one whose likelihood  
in the FSAR" or "which one whose likelihood  
is not comparable
is not c omparable
to other common cause failures  
to other common cause failures that are not considered  
that are not considered  
in the UFSAR." Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018  
in the UFSAR." Number: 6 Author: KenSc Subject:  
10:22:20 AM  Number: 7 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Highlight
10:53:43 AM "as likely as those described  
Date: 01/24/2018  
10:22:20  
AM  Number: 7 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:53:43  
AM "as likely as those described  
in the FSAR" contradicts  
in the FSAR" contradicts  
"comparable  
" comparable  
to other common cause failures  
to other common cause failures that are not considered  
that are not considered  
in the UFSAR", which is your definition  
in the UFSAR", which is your definition  
of "sufficiently  
of "sufficiently  
low". These are two different  
low". These are two different  
thresholds.  
thresholds.  
So it is not clear when Steps 3-5 are needed. This RIS is supposed  
So it is not clear when Steps 3-5 are needed. This RIS is supposed to bring clarity to the 50.59 issue, not more ambiguity.
to bring clarity to the 50.59 issue, not more ambiguity.
  Number: 8 Author: KenSc Subject: Highlight Date: 01/23/2018  
  Number: 8 Author: KenSc Subject:  
11:00:26 PM  Number: 9 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Highlight
10:33:03 AM Clarify that "end result" means "plant level". Number: 10 Author: KenSc Subject: Highlight Date: 01/24/2018  
Date: 01/23/2018  
10:28:29 AM     
11:00:26  
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
PM  Number: 9 Author: KenSc Subject:  
  Page: 14 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Sticky Note Date: 01/24/2018  
10:49:34 AM This is new NRC policy that clearly contradicts  
10:33:03  
AM Clarify that "end result" means "plant level". Number: 10 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
10:28:29  
AM     
12345678910111213141516171819
  Page: 14Number: 1 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:49:34  
AM This is new NRC policy that clearly contradicts  
the quote in this paragraph  
the quote in this paragraph  
from NEI 01-01, which is previously  
from NEI 01-01, which is previously  
endorsed  
endorsed by NRC. It is not clarification  
by NRC. It is not clarification  
of previous policy. It also contradicts  
of previous  
SECY 93-087 and BTP 7-19. A RIS cannot change previous NRC policy. Regardless, "best estimate" methods are used in most, maybe all, FSARs for ATWS, SBO and fire. So they are used in the FSAR, therefore  
policy. It also contradicts  
even with this new policy they can be used to evaluate CCFs when the CCF is considered  
SECY 93-087 and BTP 7-19. A RIS cannot change previous  
NRC policy. Regardless,  
"best estimate"  
methods are used in most, maybe all, FSARs for ATWS, SBO and fire. So they are used in the FSAR, therefore  
even with this new policy they can be used to evaluate  
CCFs when the CCF is considered  
beyond design basis (i.e., significantly  
beyond design basis (i.e., significantly  
less likely than other malfunctions  
less likely than other malfunctions  
considered  
considered  
in design basis events). Number: 2 Author: KenSc Subject:  
in design basis events). Number: 2 Author: KenSc Subject: Highlight Date: 01/23/2018  
Highlight
11:02:45 PM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Date: 01/23/2018  
10:33:15 AM Clarify that "end result" means "plant level". Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
11:02:45  
10:31:39 AM  Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
PM  Number: 3 Author: KenSc Subject:  
10:34:04 AM These are failure modes or component  
Sticky Note Date: 01/24/2018  
level effects. They are not the "end result" Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018  
10:33:15  
10:34:02 AM  Number: 7 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
AM Clarify that "end result" means "plant level". Number: 4 Author: KenSc Subject:  
10:44:51 AM What does it mean to be "bounded".  
Highlight
This RIS needs to provide guidance, because this is a particular  
Date: 01/24/2018  
area for frequent industry inconsistency.
10:31:39  
  Number: 8 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
AM  Number: 5 Author: KenSc Subject:  
10:34:56 AM Clarify that "end result" means "plant level". Number: 9 Author: KenSc Subject: Highlight Date: 01/24/2018  
Sticky Note Date: 01/24/2018  
10:34:29 AM  Number: 10 Author: KenSc Subject: Highlight Date: 01/24/2018  
10:34:04  
10:44:57 AM  Number: 11 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
AM These are failure modes or component  
10:47:18 AM This is not clear. All design functions  
level effects.  
are assigned at the system level. But the effects of system level failures are determined  
They are not the "end result" Number: 6 Author: KenSc Subject:  
at the plant level. Clarity is needed here because this is another area of frequent industry inconsistency.
Highlight
  Number: 12 Author: KenSc Subject: Highlight Date: 01/24/2018  
Date: 01/24/2018  
10:46:06 AM  Number: 13 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
10:34:02  
10:47:45 AM define "bounded" Number: 14 Author: KenSc Subject: Highlight Date: 01/24/2018  
AM  Number: 7 Author: KenSc Subject:  
10:47:34 AM  Number: 15 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Sticky Note Date: 01/24/2018  
10:48:50 AM "results" appears to have two different  
10:44:51  
AM What does it mean to be "bounded".  
This RIS needs to provide guidance,  
because this is a particular  
area for frequent  
industry  
inconsistency.
  Number: 8 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:34:56  
AM Clarify that "end result" means "plant level". Number: 9 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
10:34:29  
AM  Number: 10 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
10:44:57  
AM  Number: 11 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:47:18  
AM This is not clear. All design functions  
are assigned  
at the system level. But the effects of system level failures  
are determined  
at the plant level. Clarity is needed here because this is another area of frequent  
industry  
inconsistency.
  Number: 12 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
10:46:06  
AM  Number: 13 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:47:45  
AM define "bounded"
Number: 14 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
10:47:34  
AM  Number: 15 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:48:50  
AM "results"  
appears to have two different  
meanings.  
meanings.  
This needs clarification.
This needs clarification.
  Number: 16 Author: KenSc Subject:  
  Number: 16 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
10:48:19 AM  Number: 17 Author: KenSc Subject: Highlight Date: 01/24/2018  
Date: 01/24/2018  
10:48:24 AM  Number: 18 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
10:48:19  
10:52:10 AM "bounded" is used in three quotes on this page. But it is never defined here or in NEI 01-01. A definition  
AM  Number: 17 Author: KenSc Subject:  
is clearly needed. Number: 19 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
10:51:10 AM     
Date: 01/24/2018  
1 2
10:48:24  
  Page: 15 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
AM  Number: 18 Author: KenSc Subject:  
10:58:08 AM The same software in different  
Sticky Note Date: 01/24/2018  
10:52:10  
AM "bounded"  
is used in three quotes on this page. But it is never defined here or in NEI 01-01. A definition  
is clearly needed. Number: 19 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
10:51:10  
AM     
12
  Page: 15Number: 1 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
10:58:08  
AM The same software  
in different  
systems could be considered  
systems could be considered  
a "shared resource".  
a "shared resource".  
So change to "shared hardware  
So change to "shared hardware resource".
resource".
  Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
  Number: 2 Author: KenSc Subject:  
10:56:17 AM     
Highlight
1 2 3 4 5 6 7 8
Date: 01/24/2018  
  Page: 16 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
10:56:17  
11:00:58 AM This contradicts  
AM     
previous sections which say that the malfunction  
12345678
must be analyzed only if the likelihood  
  Page: 16Number: 1 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
11:00:58  
AM This contradicts  
previous  
sections  
which say that the malfunction  
must be analyzed  
only if the likelihood  
is not "sufficiently  
is not "sufficiently  
low" based on a qualitative  
low" based on a qualitative  
assessment.  
assessment.  
Here you say that analysis  
Here you say that analysis is needed to reach the "sufficiently  
is needed to reach the "sufficiently  
low" threshold.  
low" threshold.  
This is quite confusing.
This is quite confusing.
  Number: 2 Author: KenSc Subject:  
  Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
10:59:25 AM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Date: 01/24/2018  
11:01:26 AM Very unclear. See previous comments. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
10:59:25  
11:01:11 AM Very  Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
AM  Number: 3 Author: KenSc Subject:  
11:04:42 AM Even if you hardwire a signal from a digital device, the digital device itself can create an erroneous  
Sticky Note Date: 01/24/2018  
11:01:26  
AM Very unclear.  
See previous  
comments.
Number: 4 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
11:01:11  
AM Very  Number: 5 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
11:04:42  
AM Even if you hardwire  
a signal from a digital device, the digital device itself can create an erroneous  
signal that could adversely  
signal that could adversely  
affect RPS/ESF.  
affect RPS/ESF. Digital data communication  
Digital data communication  
creates an additional  
creates an additional  
communication  
communication  
Line 521: Line 287:
on functional  
on functional  
independence.
independence.
  Number: 6 Author: KenSc Subject:  
  Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
11:02:46 AM  Number: 7 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Date: 01/24/2018  
11:07:50 AM Per previous NRC policy, all of these attributes  
11:02:46  
AM  Number: 7 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
11:07:50  
AM Per previous  
NRC policy, all of these attributes  
facilitate  
facilitate  
a conclusion  
a conclusion  
of sufficiently  
of sufficiently  
low likelihood  
low likelihood  
to be analyzed  
to be analyzed using "best estimate" methods. Not sufficiently
using "best estimate"  
methods.  
Not sufficiently
low to require no further consideration.  
low to require no further consideration.  
This RIS is changing  
This RIS is changing NRC policy. Number: 8 Author: KenSc Subject: Highlight Date: 01/24/2018  
NRC policy. Number: 8 Author: KenSc Subject:  
11:07:41 AM     
Highlight
Date: 01/24/2018  
11:07:41  
AM     
   
   
This page contains  
This page contains no comments  
no comments  
1 2 3
123
  Page: 18 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
  Page: 18Number: 1 Author: KenSc Subject:  
11:10:25 AM Limiting and mitigating  
Sticky Note Date: 01/24/2018  
11:10:25  
AM Limiting  
and mitigating  
do not reduce the likelihood  
do not reduce the likelihood  
of the failure. Number: 2 Author: KenSc Subject:  
of the failure. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
11:09:58 AM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Date: 01/24/2018  
11:12:29 AM This paragraph  
11:09:58  
AM  Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
11:12:29  
AM This paragraph  
is not related to design attributes  
is not related to design attributes  
that reduce the likelihood  
that reduce the likelihood  
of failure.  
of failure. It is about tolerating  
It is about tolerating  
the failure. This paragraph  
the failure.  
This paragraph  
should be deleted or moved.   
should be deleted or moved.   
   
   
This page contains  
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no comments  
   
   
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no comments  
1 2
12
  Page: 21 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
  Page: 21Number: 1 Author: KenSc Subject:  
11:18:10 AM Clarify that this refers to functional  
Sticky Note Date: 01/24/2018  
11:18:10  
AM Clarify that this refers to functional  
diversity.  
diversity.  
Implementation  
Implementation  
diversity  
diversity  
is not required  
is not required in the protection  
in the protection  
system by 10CFR Part 50 Appendix A. Implementation  
system by 10CFR Part 50 Appendix  
A. Implementation  
diversity  
diversity  
is only required  
is only required by 50.62 for ATWS, which is a beyond design basis event for which "best estimate" methods are permitted.
by 50.62 for ATWS, which is a beyond design basis event for which "best estimate"  
  Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
methods are permitted.
11:16:14 AM     
  Number: 2 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
11:16:14  
AM     
   
   
This page contains  
This page contains no comments  
no comments  
   
   
This page contains  
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no comments  
   
   
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no comments  
1 2 3 4
1234
  Page: 25 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
  Page: 25Number: 1 Author: KenSc Subject:  
11:27:04 AM This contradicts  
Sticky Note Date: 01/24/2018  
11:27:04  
AM This contradicts  
your definition  
your definition  
of "sufficiently  
of "sufficiently  
low" which requires  
low" which requires the failure likelihood  
the failure likelihood  
to be comparable  
to be comparable  
to failures  
to failures not considered  
not considered  
in the FSAR". Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
in the FSAR". Number: 2 Author: KenSc Subject:  
11:26:09 AM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Highlight
11:29:00 AM The ability to mitigate the malfunction  
Date: 01/24/2018  
11:26:09  
AM  Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
11:29:00  
AM The ability to mitigate  
the malfunction  
is completely  
is completely  
different  
different  
than the determination  
than the determination  
of likelihood.
of likelihood.
  Number: 4 Author: KenSc Subject:  
  Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
11:27:52 AM     
Date: 01/24/2018  
1 2
11:27:52  
  Page: 26 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
AM     
11:31:46 AM Clarify that this means risk comparable  
12
to other failures that are not considered  
  Page: 26Number: 1 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
11:31:46  
AM Clarify that this means risk comparable  
to other failures  
that are not considered  
in the FSAR and distinguish  
in the FSAR and distinguish  
this from risks that do not reach this level and therefore  
this from risks that do not reach this level and therefore  
require further analysis  
require further analysis of the plant level effects. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
of the plant level effects. Number: 2 Author: KenSc Subject:  
11:30:54 AM     
Highlight
Date: 01/24/2018  
11:30:54  
AM     
   
   
This page contains  
This page contains no comments  
no comments  
1 2
12
  Page: 28 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
  Page: 28Number: 1 Author: KenSc Subject:  
11:36:46 AM BTP 7-19 says a D3 analysis is required for "safety systems" not just protection  
Sticky Note Date: 01/24/2018  
systems. A RIS cannot change current Staff policy. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
11:36:46  
11:36:08 AM     
AM BTP 7-19 says a D3 analysis  
is required  
for "safety systems"  
not just protection  
systems.  
A RIS cannot change current Staff policy. Number: 2 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
11:36:08  
AM     
   
   
This page contains  
This page contains no comments  
no comments  
1 2 3 4 5 6
123456
  Page: 30 Number: 1 Author: KenSc Subject: Highlight Date: 01/24/2018  
  Page: 30Number: 1 Author: KenSc Subject:  
11:39:34 AM  Number: 2 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Highlight
11:39:13 AM These other attributes  
Date: 01/24/2018  
11:39:34  
AM  Number: 2 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
11:39:13  
AM These other attributes  
can be used when accompanied  
can be used when accompanied  
by Staff review. Now you are changing  
by Staff review. Now you are changing the Staff policy to allow these other attributes  
the Staff policy to allow these other attributes  
to be used without Staff review and without additional  
to be used withoutStaff review and without additional  
endorsed Staff guidance. Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
endorsed  
11:42:46 AM You are making a statement  
Staff guidance.
Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
11:42:46  
AM You are making a statement  
with inadequate  
with inadequate  
justification.  
justification. "Best estimate" methods are used in most, maybe all, FSARs for all beyond design basis events. SECY 93-087 and BTP 7-19 define CCF with concurrent  
"Best estimate"  
methods are used in most, maybe all, FSARs for all beyond design basis events. SECY 93-087 and BTP 7-19 define CCF with concurrent  
accidents  
accidents  
as a beyond design basis event. Now, you are using this RIS to change NRC policy. Number: 4 Author: KenSc Subject:  
as a beyond design basis event. Now, you are using this RIS to change NRC policy. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
11:40:21 AM  Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
Date: 01/24/2018  
11:44:21 AM This is not an alternate  
11:40:21  
AM  Number: 5 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
11:44:21  
AM This is not an alternate  
approach.  
approach.  
It is your definition  
It is your definition  
of "sufficiently  
of "sufficiently  
low" Number: 6 Author: KenSc Subject:  
low" Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018  
Highlight
11:43:50 AM     
Date: 01/24/2018  
1 2 3 4
11:43:50  
  Page: 31 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
AM     
12:01:52 PM "Best estimate" methods facilitate  
1234
  Page: 31Number: 1 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
12:01:52  
PM "Best estimate"  
methods facilitate  
crediting  
crediting  
backups.  
backups. Without "best estimate" methods backups cannot be credited because they will never achieve the same performance (e.g. response time, design basis margin to critical safety function limits) as the original system. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018  
Without "best estimate"  
11:59:40 AM  Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018  
methods backups cannot be credited  
12:03:16 PM This is not an economical  
because they will never achieve the same performance  
(e.g. response  
time, design basis margin to critical  
safety function  
limits) as the original  
system. Number: 2 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
11:59:40  
AM  Number: 3 Author: KenSc Subject:  
Sticky Note Date: 01/24/2018  
12:03:16  
PM This is not an economical  
means nor is it likely to show equivalent  
means nor is it likely to show equivalent  
design basis results.  
design basis results. This is why "best estimate" methods are needed. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018  
This is why "best estimate"  
12:02:23 PM     
methods are needed. Number: 4 Author: KenSc Subject:  
Highlight
Date: 01/24/2018  
12:02:23  
PM     
   
   
This page contains  
This page contains no comments  
no comments  
   
   
This page contains  
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no comments  
   
   
This page contains  
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no comments  
   
   
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no comments  
   
   
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no comments
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Revision as of 04:49, 6 July 2018

Summary of Comments on 2018-01-24 by Ken Scarola_Nuclear Automation Engineering
ML18025B924
Person / Time
Issue date: 01/24/2018
From:
Office of Nuclear Reactor Regulation
To:
References
RIS-02-022, S01 DRF
Download: ML18025B924 (72)
v • d • e


See also: RIS 2002-22

Text

Summary of Comments on 2018-01-23

Draft RIS_KS.pdf

This page contains no comments

This page contains no comments

1 2 3 4

Page: 3 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

12:06:34 PM In the sentence directly before this one, the limitation

regarding

not providing

new guidance is restricted

to RPS and ESF. But in this sentence that limitation

is extended to all SSCs. This contradicts

subsequent

sections of this RIS which provide new CCF guidance for other non-RPS/ESF

SSCs. Number: 2 Author: KenSc Subject: Highlight Date: 01/23/2018

10:39:52 PM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

9:03:14 AM ATWS is considered

in most FSARs, maybe all. So CCF due to a design flaw is considered

in most, maybe all, FSARs. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

9:02:09 AM

1 2

Page: 4 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

12:07:45 PM The first paragraph

on Page 3 says this RIS is not applicable

to RPS/ESF. But this paragraph

implies it would not be applicable

to any equipment

of equal or greater importance

to RPS/ESF. Importance

can be determined

by the PRA. Equipment

of equal or greater importance

would typically

include load sequencers, and accident monitoring

instrumentation

and controls for manual actions credited in the TAA. So the original statement

that says this RIS is not applicable

to RPS and ESFAS should be expanded to encompass

these additional

systems. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

9:06:19 AM

1 2 3 4

Page: 5 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

12:08:20 PM We typically

view "failure to perform" as "no function at all". But equally important

is performing

a design function erroneously.

This is too often forgotten

by digital designers.

It should be clearly stated. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

9:15:39 AM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

9:17:29 AM A failure of shared resources

among safety control functions

can also introduce

unanalyzed

malfunctions.

Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

9:13:15 AM

1 2

Page: 6 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:01:37 AM SECY 93-087 and BTP 7-19 constitute

current NRC policy on digital CCF. The current policy does not allow a conclusion

that the likelihood

of a CCF is sufficiently

low to require no further consideration

based on these qualitative

factors alone. The current policy is clear that these qualitative

factors facilitate

a conclusion

that the CCF is beyond design basis, but not that it requires no further consideration.

Another way of looking at this is that the current policy is that qualitative

factors do not allow a conclusion

that the likelihood

is comparable

to other sources of CCF that are not considered

in the FSAR. How can a RIS be used to change previous NRC policy. I have heard some people say that the current NRC policy is only applicable

to new plants. If that is true, which I don't believe it is, then how can the NRC create a new policy for operating

plants that is different

than for new plants. This directly contradicts

the commissioners

direction

in (SRM)-SECY-16-0070

that the guidance for new plants and operating

plants should be the same. Number: 2 Author: KenSc Subject: Sticky Note Date: 01/24/2018

12:10:01 PM Dave, You told me that "sufficiently

low" could only be reached with 4 factors, the fourth being an evaluation

of the "what if" malfunction

results. This contradicts

your explanation

of this RIS. If your interpretation

is confused, the industry's

interpretation

is also going to be confused.

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1 2 3 4

Page: 9 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

9:38:55 AM Licensees

will often conduct these evaluations

prior to investing

in revised design/analysis

documentation.

Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

9:37:49 AM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

9:40:45 AM Dave, This does not say that a failure must be postulated.

Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

9:40:15 AM

1 2

Page: 10 Number: 1 Author: KenSc Subject: Highlight Date: 01/23/2018

10:53:30 PM Number: 2 Author: KenSc Subject: Sticky Note Date: 01/23/2018

10:53:57 PM No postulation

of CCF.

1 2 3 4 5 6

Page: 11 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

9:47:22 AM This is technically

incorrect.

Single failures, by definition

are random, non-systematic

failures.

An increase in the likelihood

of a single failure, does lower system availability, but it does not increase the likelihood

of a CCF. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

9:44:37 AM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:18:38 AM Should be NEI 01-01 Section 4.4.6. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

10:18:44 AM Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:04:39 AM This note just adds confusion

because it says that if a failure is not credible but not sufficiently

low likelihood

it must be considered.

Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018

10:03:46 AM

1 2 3 4 5 6

Page: 12 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:12:33 AM This contradicts

previous statements

in this RIS and in NEI 01-01 which state to require no further consideration

in 50.59, the failure likelihood

must be " comparable

to other common cause failures that are not considered

in the UFSAR". Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

10:12:30 AM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:07:57 AM Yes, but the sentence above says that even if you have not reached the "sufficiently

low" threshold, there are no new accidents

introduced

unless the failure is "as likely" as other failures assumed in the FSAR. This is quite confusing.

Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

10:05:54 AM Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:11:38 AM This contradicts

previous statements

in this RIS and in NEI 01-01 which state to require no further consideration

in 50.59, the failure likelihood

must be " comparable

to other common cause failures that are not considered

in the UFSAR". Number: 6 Author: KenSc Subject: Highlight Date: 01/23/2018

10:57:32 PM

1 2 3 4 5 6 7 8 9 10

Page: 13 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:20:03 AM This contradicts

NEI 01-01 which says to require no further consideration

the failure likelihood

must be " comparable

to other common cause failures that are not considered

in the UFSAR", not as likely as those that are considered.

Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

10:13:32 AM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:21:57 AM Needs to also include ways of erroneous

performance.

You can argue that "failure" encompasses "erroneous" but erroneous

is too often overlooked

by digital designers.

Number: 4 Author: KenSc Subject: Highlight Date: 01/23/2018

10:58:55 PM Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:27:10 AM This should say "which ones that are not as unlikely as failures not considered

in the FSAR" or "which one whose likelihood

is not c omparable

to other common cause failures that are not considered

in the UFSAR." Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018

10:22:20 AM Number: 7 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:53:43 AM "as likely as those described

in the FSAR" contradicts

" comparable

to other common cause failures that are not considered

in the UFSAR", which is your definition

of "sufficiently

low". These are two different

thresholds.

So it is not clear when Steps 3-5 are needed. This RIS is supposed to bring clarity to the 50.59 issue, not more ambiguity.

Number: 8 Author: KenSc Subject: Highlight Date: 01/23/2018

11:00:26 PM Number: 9 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:33:03 AM Clarify that "end result" means "plant level". Number: 10 Author: KenSc Subject: Highlight Date: 01/24/2018

10:28:29 AM

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19

Page: 14 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:49:34 AM This is new NRC policy that clearly contradicts

the quote in this paragraph

from NEI 01-01, which is previously

endorsed by NRC. It is not clarification

of previous policy. It also contradicts

SECY 93-087 and BTP 7-19. A RIS cannot change previous NRC policy. Regardless, "best estimate" methods are used in most, maybe all, FSARs for ATWS, SBO and fire. So they are used in the FSAR, therefore

even with this new policy they can be used to evaluate CCFs when the CCF is considered

beyond design basis (i.e., significantly

less likely than other malfunctions

considered

in design basis events). Number: 2 Author: KenSc Subject: Highlight Date: 01/23/2018

11:02:45 PM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:33:15 AM Clarify that "end result" means "plant level". Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

10:31:39 AM Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:34:04 AM These are failure modes or component

level effects. They are not the "end result" Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018

10:34:02 AM Number: 7 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:44:51 AM What does it mean to be "bounded".

This RIS needs to provide guidance, because this is a particular

area for frequent industry inconsistency.

Number: 8 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:34:56 AM Clarify that "end result" means "plant level". Number: 9 Author: KenSc Subject: Highlight Date: 01/24/2018

10:34:29 AM Number: 10 Author: KenSc Subject: Highlight Date: 01/24/2018

10:44:57 AM Number: 11 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:47:18 AM This is not clear. All design functions

are assigned at the system level. But the effects of system level failures are determined

at the plant level. Clarity is needed here because this is another area of frequent industry inconsistency.

Number: 12 Author: KenSc Subject: Highlight Date: 01/24/2018

10:46:06 AM Number: 13 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:47:45 AM define "bounded" Number: 14 Author: KenSc Subject: Highlight Date: 01/24/2018

10:47:34 AM Number: 15 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:48:50 AM "results" appears to have two different

meanings.

This needs clarification.

Number: 16 Author: KenSc Subject: Highlight Date: 01/24/2018

10:48:19 AM Number: 17 Author: KenSc Subject: Highlight Date: 01/24/2018

10:48:24 AM Number: 18 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:52:10 AM "bounded" is used in three quotes on this page. But it is never defined here or in NEI 01-01. A definition

is clearly needed. Number: 19 Author: KenSc Subject: Highlight Date: 01/24/2018

10:51:10 AM

1 2

Page: 15 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

10:58:08 AM The same software in different

systems could be considered

a "shared resource".

So change to "shared hardware resource".

Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

10:56:17 AM

1 2 3 4 5 6 7 8

Page: 16 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:00:58 AM This contradicts

previous sections which say that the malfunction

must be analyzed only if the likelihood

is not "sufficiently

low" based on a qualitative

assessment.

Here you say that analysis is needed to reach the "sufficiently

low" threshold.

This is quite confusing.

Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

10:59:25 AM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:01:26 AM Very unclear. See previous comments. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

11:01:11 AM Very Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:04:42 AM Even if you hardwire a signal from a digital device, the digital device itself can create an erroneous

signal that could adversely

affect RPS/ESF. Digital data communication

creates an additional

communication

independence

vulnerability.

But it has no effect (positive

or negative)

on functional

independence.

Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018

11:02:46 AM Number: 7 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:07:50 AM Per previous NRC policy, all of these attributes

facilitate

a conclusion

of sufficiently

low likelihood

to be analyzed using "best estimate" methods. Not sufficiently

low to require no further consideration.

This RIS is changing NRC policy. Number: 8 Author: KenSc Subject: Highlight Date: 01/24/2018

11:07:41 AM

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Page: 18 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:10:25 AM Limiting and mitigating

do not reduce the likelihood

of the failure. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

11:09:58 AM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:12:29 AM This paragraph

is not related to design attributes

that reduce the likelihood

of failure. It is about tolerating

the failure. This paragraph

should be deleted or moved.

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Page: 21 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:18:10 AM Clarify that this refers to functional

diversity.

Implementation

diversity

is not required in the protection

system by 10CFR Part 50 Appendix A. Implementation

diversity

is only required by 50.62 for ATWS, which is a beyond design basis event for which "best estimate" methods are permitted.

Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

11:16:14 AM

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Page: 25 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:27:04 AM This contradicts

your definition

of "sufficiently

low" which requires the failure likelihood

to be comparable

to failures not considered

in the FSAR". Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

11:26:09 AM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:29:00 AM The ability to mitigate the malfunction

is completely

different

than the determination

of likelihood.

Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

11:27:52 AM

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Page: 26 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:31:46 AM Clarify that this means risk comparable

to other failures that are not considered

in the FSAR and distinguish

this from risks that do not reach this level and therefore

require further analysis of the plant level effects. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

11:30:54 AM

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Page: 28 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:36:46 AM BTP 7-19 says a D3 analysis is required for "safety systems" not just protection

systems. A RIS cannot change current Staff policy. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

11:36:08 AM

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Page: 30 Number: 1 Author: KenSc Subject: Highlight Date: 01/24/2018

11:39:34 AM Number: 2 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:39:13 AM These other attributes

can be used when accompanied

by Staff review. Now you are changing the Staff policy to allow these other attributes

to be used without Staff review and without additional

endorsed Staff guidance. Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:42:46 AM You are making a statement

with inadequate

justification. "Best estimate" methods are used in most, maybe all, FSARs for all beyond design basis events. SECY 93-087 and BTP 7-19 define CCF with concurrent

accidents

as a beyond design basis event. Now, you are using this RIS to change NRC policy. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

11:40:21 AM Number: 5 Author: KenSc Subject: Sticky Note Date: 01/24/2018

11:44:21 AM This is not an alternate

approach.

It is your definition

of "sufficiently

low" Number: 6 Author: KenSc Subject: Highlight Date: 01/24/2018

11:43:50 AM

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Page: 31 Number: 1 Author: KenSc Subject: Sticky Note Date: 01/24/2018

12:01:52 PM "Best estimate" methods facilitate

crediting

backups. Without "best estimate" methods backups cannot be credited because they will never achieve the same performance (e.g. response time, design basis margin to critical safety function limits) as the original system. Number: 2 Author: KenSc Subject: Highlight Date: 01/24/2018

11:59:40 AM Number: 3 Author: KenSc Subject: Sticky Note Date: 01/24/2018

12:03:16 PM This is not an economical

means nor is it likely to show equivalent

design basis results. This is why "best estimate" methods are needed. Number: 4 Author: KenSc Subject: Highlight Date: 01/24/2018

12:02:23 PM

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