NRC-2017-0154, Comment (3) of Ralph A. Butler Regarding Clarification on Endorsement of Nuclear Energy Institute Guidance in Designing Digital Upgrades in Instrumentation and Control Systems
| ML17220A060 | |
| Person / Time | |
|---|---|
| Site: | University of Missouri-Columbia |
| Issue date: | 07/31/2017 |
| From: | Rhonda Butler Univ of Missouri - Columbia |
| To: | Cindy Bladey Rules, Announcements, and Directives Branch |
| References | |
| 82FR30913 00003, NRC-2017-0154 | |
| Download: ML17220A060 (2) | |
Text
UNIVERSITY of MISSOURI RESEARCH REACTOR CENTER July 31, 2017 1/0/..JCJ17 :0 ~~ ~
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REFERENCE:
Docket No. 50-186 University of Missouri-Columbia Research Reactor Renewed Facility Operating License No. R-103
SUBJECT:
Request for Public Comment on "Clarification on Endorsement of Nuclear Energy Institute Guidance in Designing Digital Upgrades in Instrumentation and Control Systems," (82 FR 30913); Docket ID NRC-2017-0154 The University of Missouri Research Reactor (MURR) appreciates the opportunity to provide comments on a draft regulatory issue summary (RIS) to supplement the U.S. Nuclear Regulatory Commission (NRC) staffs endorsement of the Electric Power Research Institute (EPRI)/Nuclear Energy Institute (NEI) Joint Task Force report entitled, "Guideline on Licensing Digital Upgrades: EPRI TR-102348, Revision 1, NEI 01-01: A Revision ofEPRI TR-102348 To Reflect Changes to the 10 CFR 50.59 Rule,"
in RIS 2002-22, as published in the Federal Register (Volume 82, No. 126 I July 3, 2017).
The following are MURR's comments on the draft RIS:
- 1. The following bullet at the top of page 3 of the 17-page "Draft Qualitative Assessment Framework" attachment to "NRC Draft Regulatory Issue Summary 2017-XX, Supplement to RIS 2002-22," is very confusing.
"Possible accidents of a different type are limited to those that are as likely to happen as those previously evaluated in the UFSAR; and, based on the likelihood offailure of equipment that can initiate events that lead to accidents that are a different type, the activity does not create an accident of a different type that is as likely to happen as those previously evaluated in the UFSAR" MURR is not sure exactly what this bullet is trying to say. Is it possible to revise to make it unambiguous? If MURR understood, what the bullet was trying to say we could suggest a rewrite.
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w 1513 Research Park Drive Columbia, MO 65211 Phone: 573-882-4211 Fax: 573-882-6360 Web: http://web.missouri.edu/-murrwww Fighting Cancer with Tomorrow's Technology
- 2. The definition of "sufficiently low" at the top of page 5 of the 17-page attachment is extremely vague concerning failure due to software. It states that sufficiently low means much lower than the likelihood of failures that are considered in the UFSAR (e.g., single failures) and comparable to other common cause failures not considered in the UFSAR (e.g., design flaws, maintenance errors, calibration errors)?
- 3. MURR strongly believes that the draft RIS and NEI 01-01 should not apply to Non-power Production or Utilization Facilities (NPUFs) licensed under 10 CFR 50 due to the extreme dependence on risk-based analysis. NPUFs do not have the resources, nor provide a significant risk to the health and safety of the public, to support the risk-based analyses needed to meet these guidelines.
Thank you for the opportunity to comment. Should you have any questions, please feel free to contact me at 573-882-4211 or ButlerRa@missouri.edu.
Sincerely, Ralph A. Butler, P.E.
Director xc: Reactor Advisory Committee Reactor Safety Subcommittee Dr. Mark Mcintosh, Vice Chancellor for Research, Graduate Studies and Economic Development Mr. Geoffrey Wertz, U.S. Nuclear Regulatory Commission Mr. Johnny Eads, U.S. Nuclear Regulatory Commission L
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