Letter Sequence Other |
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MONTHYEARML0930200742009-11-0303 November 2009
Acceptance for Review of Nuclear Energy Institute (NEI) Topical Report 94-01, Revision 2-A Supplement 1, Industry Guideline for Implementation the Performance-Based Option of 10 CFR Part 50, Appendix J
Project stage: Acceptance Review
ML0933405412009-12-0303 December 2009
Request for Additional Information Nuclear Energy Institute (NEI) Topical Report 94-01, Revision 2-A Supplement 1, Industry Guideline for Implementing the Performance-Based Option of 10 CFR Part 50, Appendix J.
Project stage: RAI
ML1108903142011-04-21021 April 2011
Letter Revision 3 to Nuclear Energy Institute (NEI) NUMARC 94-01, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J
Project stage: Other
ML12226A5462012-12-0606 December 2012
NEI TR 94-01, Rev 3-A Approval Letter
Project stage: Other
2009-12-03
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Category:Letter
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NEI, Comments on NRC Draft Resolution of SFAQ 2022-02, SAE Program Requirements
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Response Letter to Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07
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NEI Letter Request for an Extension of Comment Period on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses, Docket Id NRC 2023 0079
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ML23135A7332023-05-0909 May 2023
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ML23107A2302023-03-31031 March 2023
NEI Letter, to Andrea Veil, NRC, Regarding Industry Recommendations for a 10 CFR 50.46a/c Combined Rulemaking
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NEI, Request for NRC Endorsement of NEI White Paper, Enabling a Remote Response by Members of an Emergency Response Organization, Revision 0
ML23023A2752023-01-23023 January 2023
Request for Extension of Comment Period from the Nuclear Energy Institute on PRM-50-124 - Licensing Safety Analysis for Loss-of-Coolant Accidents
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Letter to Richard Mogavero Response to Fee Exemption NEI 08-09 Revision 7
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U.S. Nuclear Regulatory Commission Report of the Regulatory Audit of the NEI-Proposed Aging Management Program Revision to Selective Leaching Program (XI.M33)
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Fee Exemption Request for NEI 08-09 Revision 7 - Changes to NEI 08-09 Cyber Security Plan for Nuclear Power Reactors
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[Table view] |
Text
April 21, 2011 Mr. Biff Bradley, Director Risk Assessment Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
REVISION 3 TO NUCLEAR ENERGY INSTITUTE (NEI) NUMARC 94-01, INDUSTRY GUIDELINE FOR IMPLEMENTING PERFORMANCE-BASED OPTION OF 10 CFR PART 50, APPENDIX J (TAC NO. ME2164)
Dear Mr. Bradley:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your March 29, 2011, letter (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML110970445), requesting the NRC review and consider for endorsement Topical Report (TR) NUMARC 94-01, Revision 3. The subject TR was included as an attachment (ADAMS Accession No. ML110970451) to the letter and is dated March 2011. In addition to TR NUMARC 94-01, Revision 3, two other attachments were also included; (1) NEIs Responses to NRC Requests for Information on Type C Containment Isolation Valve Leak-tight Performance, dated March 28, 2011 (ADAMS Accession No. ML110970448), and (2) EPRIs Type C Containment Isolation Valve Performance, Report # 1022599, Technical Update, dated March 2011 (ADAMS Accession No. ML110970450).
Section 170.21 of Title 10 of the Code of Federal Regulations requires that TRs be subject to fees based on the full cost of the review. However, based on the letter dated August 6, 2009 (ADAMS Accession No. ML093060238), the Office of the Chief Financial Officer has waived the 10 CFR 170.21 fees associated with the review of TR NUMARC 94-01. Any reviews of subsequent revisions to this TR will be in accordance with 10 CFR 170.21, and any desired fee waivers must be requested.
Upon receipt of the documents from NEI, the NRCs staff noted an administrative error in the document numbers. Although there are references to NUMARC 91-04, the NRC understands that the guidelines for implementing Appendix J are contained within NUMARC 94-01.
During the initial review of the cover letter and attachments, the NRC staff noted references to the restoration of the 75-month interval for Type C testing and the staff clarifies that 10 CFR Part 50, Appendix J, Option B does not allow a permanent or scheduled extension of the 60-month (five-year) testing interval for Type C components. The final rule did allow a 25 percent (15-month) margin in testing frequency. Therefore, the review and consideration for acceptance and endorsement of TR NUMARC 94-01, Revision 3, will consider the extension of the 60-month interval to 75 months.
B. Bradley In addition, during a very preliminary review of the EPRI Report # 1022599 Technical Update, the NRC staff concluded that the EPRI focus was on local leak rate test (LLRT) individual failures (each plants staff determines what leakage value results in a failure for each of their valves) with little attention to how close units operate to the 0.6 La combined Type B and C Technical Specification leakage criterion. This may incorrectly result in a condition for desired routine scheduling of Type C tests beyond 60-months, and may result in an understatement of the min-pathway total.
The NRC staff will consider the responses to the request for additional information and determine if sufficient data has been provided to satisfy staffs concerns of Type C component performance. The NRC staff expects to complete a review of all submitted information by May 27, 2011. However, the schedule is based on current NRC plans and workload, and may be impacted by other higher priority tasks assigned by management.
As with all TRs, the SE will be reviewed by the NRCs Office of the General Counsel (OGC) for determination of any impact by the Congressional Review Act (CRA). This review by OGC ensures that any endorsement or acceptance of a TR by the NRC is considered with respect to being a rule according to the CRA. If this initial review by OGC determines the SE, with its accompanying TR, may be a rule, the NRC will forward the package to the Office of Management and Budget (OMB) for continued review and consideration. Any review by OMB would impact the schedule for the final issuance of the SE.
If you have any questions regarding this matter, I may be reached at 301-415-1847 or Sheldon.Stuchell@nrc.gov.
Sincerely,
/RA/
Sheldon D. Stuchell, Senior Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 689
The NRC staff will consider the responses to the request for additional information and determine if sufficient data has been provided to satisfy staffs concerns of Type C component performance. The NRC staff expects to complete a review of all submitted information by May 27, 2011. However, the schedule is based on current NRC plans and workload, and may be impacted by other higher priority tasks assigned by management.
As with all TRs, the SE will be reviewed by the NRCs Office of the General Counsel (OGC) for determination of any impact by the Congressional Review Act (CRA). This review by OGC ensures that any endorsement or acceptance of a TR by the NRC is considered with respect to being a rule according to the CRA. If this initial review by OGC determines the SE, with its accompanying TR, may be a rule, the NRC will forward the package to the Office of Management and Budget (OMB) for continued review and consideration. Any review by OMB would impact the schedule for the final issuance of the SE.
If you have any questions regarding this matter, I may be reached at 301-415-1847 or Sheldon.Stuchell@nrc.gov.
Sincerely,
/RA/
Sheldon D. Stuchell, Senior Project Manager Licensing Processes Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Project No. 689 DISTRIBUTION:
PUBLIC PLPB Reading File RidsNrrDssScvb RidsNrrDss RidsNrrDprPlpb RidsNrrDpr RidsNrrPMSStuchell RidsNrrLADBaxley RidsOgcMailCenter RidsAcrsAcnwMailCenter GBettle, NRR/DSS/SCVB BLee, NRR/DSS/SCVB RDennig, NRR/DSS/SCVB RErickson, CFO/DC/ARPB ADAMS ACCESSION NO ML110890314 TAC ME2164 OFFICE PLPB/PM PLPB/LA DSS/SCVB PLPB/BC PLPB/PM NAME SStuchell DBaxley RDennig JJolicoeur SStuchell DATE 4 /11/ 2011 4 / 14/ 2011 4 / 18 / 2011 4/21/11 4/21/11 OFFICIAL RECORD COPY