ML18311A360

NRC Comments on Appendix D Revision 0g Rev. 1

ML18311A360
Person / Time
Issue date:	11/07/2018
From:	Office of Nuclear Reactor Regulation
To:
Govan T V
References
Download: ML18311A360 (42)

Text

removedmoved

qualitative assessment

failuresfunction

failuresfunction

adversenot adverse

response time response time

response time

response time response time response time

technical

Generally, only malfunctions are identified in the UFSAR, not

the initiators of the malfunctions

safety analyses

compensatory actions

A 10 CFR 50.59 Evaluation is required for digital modifica tions that adversely affect design functions, or the methods used to perform or control design functions. There is no regulatory requirement for a proposed activity involving a digital modification to default (i.e., be mandatorily "forced") to an adverse conclusion. If all design basis functions continue to be performed/satisfied, and there are no other design functions involved, then the proposed activity does NOT create the possibility for a malfunction of an SSC important to safety with a different result because no malfunction occurs. With no malfunction occurring, there cannot be a different result.