ML18054A194

NRR E-mail Capture - (External_Sender) Public Comments Related to Digital I&C RIS 2002-22, Supplement 1 Follow Up Question on RIS

ML18054A194
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/24/2017
From:	Fregonese V Nuclear Energy Institute
To:	David Rahn Division of Engineering
Shared Package
ML18039A804	List: ML18043A006 ML18054A045 ML18054A046 ML18054A047 ML18054A048 ML18054A050 ML18054A190 ML18054A194 ML18054A198 ML18054A220 ML18054A226 ML18054A656 ML18057B126
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Download: ML18054A194 (4)

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NRR-DMPSPEm Resource From: FREGONESE, Victor <vxf@nei.org>

Sent: Monday, April 24, 2017 9:16 AM To: Rahn, David Cc: Drake, Jason; Archambo, Neil G; Morton, Wendell

Subject:

[External_Sender] RE: Re: Follow up Question on RIS We can discuss later this week, after you get our comments. It just needs to be clear, as the SRM/SECY statements had a certain applicability at the time they were written (New Plants, RPS/ESFAS, etc). It would be helpful to finally clarify what the staffs interpretation of what the best estimate statement was intended to apply to, and what it was not.

Vic Fregonese Senior Project Manager Nuclear Generation Division Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004 www.nei.org M: 704-953-4544 E: vxf@nei.org From: Rahn, David [1]

Sent: Monday, April 24, 2017 8:41 AM To: FREGONESE, Victor Cc: Drake, Jason; Archambo, Neil G; Morton, Wendell

Subject:

RE: Re: Follow up Question on RIS Hi Vic:

I agree we need to address this before the public comment version is finalized. If we ended the affected paragraph at the end of the previous sentence, it would be consistent with current policy, and we could tackle the next sentence (regarding how beyond-design-basis analyses could be used and for what purpose) as material for consideration within comments to NEI 16-16.

Dave From: FREGONESE, Victor [2]

Sent: Monday, April 24, 2017 8:36 AM To: Rahn, David <David.Rahn@nrc.gov>

Cc: Drake, Jason <Jason.Drake@nrc.gov>; Archambo, Neil G <Neil.Archambo@duke-energy.com>; Morton, Wendell

<Wendell.Morton@nrc.gov>

Subject:

[External_Sender] Re: Follow up Question on RIS Thanks. I think we should address this issue head-on, and not leave it open to interpretation downstream. So if there is a position it would be better just to state what it is, and what it is not. Thanks!

On Apr 24, 2017, at 8:33 AM, Rahn, David <David.Rahn@nrc.gov> wrote:

1

Hi Vic:

Wendell and I will be discussing this point today, and will get back to you on it as soon as we have reached a conclusion. We received a similar comment from others, regarding whether statements like this in the RIS are going beyond existing policy, and may not be allowed to be clarified in the form of a RIS. The issue isnt so much related to the process of determining whether existing plant level analyses can be shown to be bounding, but rather it is related to how it was determined that the frequency of a potential new CCF was found to be negligible.

We may end up deleting the entire highlighted sentence altogether.

Dave From: FREGONESE, Victor [3]

Sent: Friday, April 21, 2017 8:38 AM To: Morton, Wendell <Wendell.Morton@nrc.gov>; Rahn, David <David.Rahn@nrc.gov>

Cc: Drake, Jason <Jason.Drake@nrc.gov>; 'Archambo, Neil G' <Neil.Archambo@duke-energy.com>

Subject:

[External_Sender] Follow up Question on RIS Wendell and Dave, One point that Dave B of the NRC clarified after the meeting was the intent of his statements about the use of best estimate methods in the previous meeting.

This was very helpful in explaining his thoughts on this topic.

I noted a section of the draft RIS that discusses this point.

I know we are sending comments next week, but I am having a team meeting on Monday to do a de-brief on the 4/20 meeting and the RIS, and want to be clear about this point, as it is an important one to understand.

I dont need a technical answer to this, as we are exchanging via e-mail, but a yes/no answer will be sufficient for my meeting, as there is some question in my mind as to whether this could be done under 50.59.

Question: Is in envisioned that the following section (from page 7) remain as written, considering the recent comments from NRC staff on beyond design basis? Yes or No?

Similarly, the NRC staff expectation regarding the documentation of qualitative assessments is to be able to describe the licensees basis (rationale) for concluding that a particular proposed modification will not:

• create a possibility for an accident of a different type (10 CFR 50.59(c)(2)(v)), and

• create a possibility for a malfunction of an SSC important to safety with a different result (10 CFR 50.59(c)(2)(vi)).

A bounded plant-level end result is not considered a different type of accident or a malfunction with a different result. When evaluating the impact of potential new CCFs that are of sufficient frequency that need to be accounted for within the plant design basis, design basis analysis methods and acceptance criteria should be used. When evaluating the impact of potential new CCFs that are of negligible frequency, beyond design basis analysis methods (best estimate) and acceptance criteria may be used in evaluating whether the plant level effect is bounding Vic Fregonese Senior Project Manager Nuclear Generation Division Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004 www.nei.org M: 704-953-4544 E: vxf@nei.org This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission 2

in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

Sent through www.intermedia.com This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

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This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.

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Hearing Identifier: NRR_DMPS Email Number: 198 Mail Envelope Properties (41207040FCA6A84984074E806C73D73EDD8C80)

Subject:

[External_Sender] RE: Re: Follow up Question on RIS Sent Date: 4/24/2017 9:16:03 AM Received Date: 4/24/2017 9:16:21 AM From: FREGONESE, Victor Created By: vxf@nei.org Recipients:

"Drake, Jason" <Jason.Drake@nrc.gov>

Tracking Status: None "Archambo, Neil G" <Neil.Archambo@duke-energy.com>

Tracking Status: None "Morton, Wendell" <Wendell.Morton@nrc.gov>

Tracking Status: None "Rahn, David" <David.Rahn@nrc.gov>

Tracking Status: None Post Office: mbx023-e1-nj-2.exch023.domain.local Files Size Date & Time MESSAGE 8809 4/24/2017 9:16:21 AM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: