ML102430521
| ML102430521 | |
| Person / Time | |
|---|---|
| Issue date: | 09/15/2010 |
| From: | Giitter J Division of Operating Reactor Licensing |
| To: | Keys J Nuclear Energy Institute |
| Giitter J G/DORL, 415-1453 | |
| References | |
| Download: ML102430521 (4) | |
Text
September 15, 2010 Ms. Julie Y. Keys, Senior Project Manager Engineering and Operations Support Nuclear Generation Division Nuclear Energy Institute 1776 I Street N. W., Suite 400 Washington D.C. 20006-3708
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION STAFF COMMENTS ON NUCLEAR ENERGY INSTITUTE TECHNICAL REPORT 06-02, REVISION 1, LICENSE AMENDMENT REQUEST (LAR) GUIDELINES
Dear Ms. Keys:
By letter dated August 11, 2010, the Nuclear Energy Institute (NEI) submitted Revision 1 to NEI Technical Report NEI 06-02, License Amendment Request (LAR) Guidelines, for the U.S. Nuclear Regulatory Commission (NRC) staff to endorse. NEI had submitted a draft for NRC staff review on December 8, 2009. NRC staff provided recommendations for revisions in a letter dated June 9, 2010. Some of our recommendations were not adopted. The staff is unable to endorse or recommend the use of this revision pending resolution of the follow-up comments provided in the enclosure. These comments are directly related to our earlier recommendations. The primary focus of these comments is ensuring that LARs are complete and that sufficient detail is provided to the NRC in terms of regulatory requirements and the protection of public health and safety. We would be pleased to meet with you to discuss these comments if you determine such a meeting would be beneficial.
Should you have any questions concerning these comments, please contact Robert Nelson, Deputy Director, Division of Operating Reactor Licensing, at (301) 415-1453.
Sincerely,
/ra/
Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosure:
NRC Comments on NEI 06-02 Rev. 1
September 15, 2010 Ms. Julie Y. Keys, Senior Project Manager Engineering and Operations Support Nuclear Generation Division Nuclear Energy Institute 1776 I Street N. W., Suite 400 Washington D.C. 20006-3708
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION STAFF COMMENTS ON NUCLEAR ENERGY INSTITUTE TECHNICAL REPORT 06-02, REVISION 1, LICENSE AMENDMENT REQUEST (LAR) GUIDELINES
Dear Ms. Keys:
By letter dated August 11, 2010, the Nuclear Energy Institute (NEI) submitted Revision 1 to NEI Technical Report NEI 06-02, License Amendment Request (LAR) Guidelines, for the U.S. Nuclear Regulatory Commission (NRC) staff to endorse. NEI had submitted a draft for NRC staff review on December 8, 2009. NRC staff provided recommendations for revisions in a letter dated June 9, 2010. Some of our recommendations were not adopted. The staff is unable to endorse or recommend the use of this revision pending resolution of the follow-up comments provided in the enclosure. These comments are directly related to our earlier recommendations. The primary focus of these comments is ensuring that LARs are complete and that sufficient detail is provided to the NRC in terms of regulatory requirements and the protection of public health and safety. We would be pleased to meet with you to discuss these comments if you determine such a meeting would be beneficial.
Should you have any questions concerning these comments, please contact Robert Nelson, Deputy Director, Division of Operating Reactor Licensing, at (301) 415-1453.
Sincerely,
/ra/
Joseph G. Giitter, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosure:
NRC Comments on NEI 06-02 Rev. 1 DISTRIBUTION:
PUBLIC Dorl r/f RidsAcrsAcnw_MailCTR RidsNrrOd RidsNrrDorl ADAMS Accession No.: ML102430521 NRR-106 OFFICE DORL/DD DORL/LA DPR DORL/D NAME RNelson:kac1 BClayton SStuchell JGiitter DATE 9/13 /10 8 /31 /10 9/13 /10 9/15/10
OFFICIAL RECORD COPY
[Type text]
U.S. NUCLEAR REGULATORY COMMISSION (NRC) STAFF COMMENTS ON NUCLEAR ENERGY INSTITUTE (NEI) TECHNICAL REPORT 06-02 LICENSE AMENDMENT REQUEST (LAR) GUIDELINES The staffs remaining comment on NEI 06-02 is a follow-up to our earlier comment concerning marked-up technical specification pages. For continuity and ease of reference, the staffs original comment and NEIs resolution are provided below followed by the staffs follow-up comments.
NRC Staff Comment #3 Section 3.0, Page 7 indicates the elements of the standard license amendment request (LAR) format. The last bullet indicates that submission of retyped technical specifications (TS) and/or operating license (OL) pages is optional. However, especially for complex TS change proposals, the retyped (clean) TS pages provide the technical staff with a much clearer understanding of the licensee's proposed changes. Often, the marked up pages can become confusing as the NRC staff attempts to follow the bubbles, arrows, strikeouts, and inserts while fully understanding the changes. In addition, the staff may request retyped pages at any time if it needs this information to support its reasonable assurance finding. It is suggested that the use of optional be replaced with a description for submitting retyped TS/OL pages consistent with the wording in footnote 6 of NEI 06-02. This suggestion should also be reflected in other areas of NEI 06-02, as applicable.
NEI Resolution Retained the term "Optional, because as the NRC states, the retyped pages may not be part of the LAR. Expanded the discussion in Appendix 3 as suggested and referenced it whenever "optional" is stated.
Follow-Up Comments
- 1. The NEI resolution refers to Appendix 3. The staff assumes that NEI is referring to Attachment 4 of Appendix A.
- 2. The term Optional should be removed in all locations that address retyped technical specification pages and retain the words see discussion in Appendix A. As stated in our earlier comment, the staff can request retyped pages at any time if it needs this information to support its reasonable assurance finding. This request could come as early as the acceptance review if the staff determines that this information is needed to initiate the technical review. Licensees should clearly understand this possibility.
- 3. Add the following new paragraph after the existing second paragraph of Attachment 4 of Appendix A.
NRC staff strongly recommends that LARs include retyped technical specification pages. NRC staff can request retyped pages at any time if it needs this information to support its reasonable assurance finding. This request could come as early as the acceptance review if the staff determines that this information is needed to initiate the technical review.
Enclosure