ML19240A327
| ML19240A327 | |
| Person / Time | |
|---|---|
| Issue date: | 08/28/2019 |
| From: | Tekia Govan NRC/NRR/DIRS/IRGB |
| To: | |
| Govan T, 415-6197, NRR/DIRS | |
| References | |
| Download: ML19240A327 (10) | |
Text
Modernization Plan #1D BTP 7-19 Update Public Meeting NRC Staff Presentation August 29, 2019
Agenda
- Description of Changes Proposed for BTP 7-19
- Discussion with and feedback from NEI/Stakeholders
- Next Actions
- Schedule 2
Major Changes in Proposed BTP
- Reorganization of BTP to align review guidance with acceptance criteria
- Clarification of applicability
- Incorporation of categorization scheme and graded approach for addressing CCF in DI&C systems
- D3 Assessment
- Qualitative assessment
- Clarification of criteria for addressing spurious operation
- Clarification of criteria for manual system level actuation 3
Process Flow for CCF Assessment
- Determine category of proposed DI&C system (i.e., A1, A2, B1, B2)
- Identify any integration or interconnectivity of the proposed DI&C system with other categories of systems
- If A1 system, perform D3 assessment
- Use of means to eliminate CCF from further consideration
- Use of diverse means
- Use of analysis to demonstrate consequences of CCF is within acceptable limits
- If A2 or B1 system (or integrated B2 system), perform qualitative assessment 4
Spurious Operation
- Evaluate potential for spurious operation due to CCF in DI&C system
- Evaluation should focus on those spurious operations that may induce initiating events that can challenge plant safety
- Design features or defensive measures can be credited to reduce scope of evaluation 5
Manual System Level Actuation and Indications SRM-SECY-93-087 Positions 3 and 4 Clarifications
- Refers to the displays and manual controls described in Position 4 of the SRM on SECY-093-87
- Displays and manual controls necessary to monitor and perform system level actuation of safety critical functions
- Need to be located within the main control room
- Displays and controls provided for Position 4 can be credited as diverse means for addressing Position 3 6
Still Under Consideration Industry Feedback Requested
- How Leak-Before-Break (LBB) criteria can be credited in excluding large break LOCAs and MSLB events from evaluation
- Need feedback from industry regarding crediting LBB
- Applicability to PWRs and BWRs
- What operator or maintenance actions will be taken if a leak is detected to allow LBB to be credited for exclusion of the two events 7
Next Steps and Schedule Milestones Activity Completion Date A.1 Begin revision to draft BTP 7-19 In progress A.2 Category 2 public meeting to discuss the direction of draft BTP 7-19 Completed April 4, 2019 A.3 Category 2 public meeting to discuss topic focused areas of BTP 7-19 Completed June 26, 2019 A.4 Finalize draft BTP 7-19 for staff review Completed August 19, 2019 A.5 Final Category 2 public meeting to discuss BTP 7-19 prior to NRC review and concurrence August 29, 2019 A.6 Agency review and concurrence on draft BTP 7-19 in preparation for public comment October 2019 period A.7 ACRS Subcommittee Meeting November 2019 A.8 Issue Draft BTP 7-19 for public comment period (60 day comment period) December 2019 Public meeting, if needed - January 2020 A.9 Public comment period ends February 2020 A.10 Public Comment/ACRS Comment Resolution Complete March 2020 A.11 ACRS Full Committee Meeting April 2020 A.12 Prepare Final BTP 7-19 Concurrence May 2020 Receive OMB Clearance Approval (non-major rule determination)
A.13 Issuance of Final BTP 7-19 June 2020 8
Questions 9
- BTP: Branch Technical Position
- BWR: Boiling Water Reactor
- CCF: Common Cause Failure
- D3: Defense-in-Depth and Diversity
- DI&C: Digital Instrumentation and Controls
- LBB: Leak-Before-Break
- LOCA: Loss of Coolant Accident
- MSLB: Main Steamline Break
- NEI: Nuclear Energy Institute
- PWR: Pressurized Water Reactor
- SRM: Staff Requirements Memorandum 10