ML13267A382

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Endorsement Letter: Mitigation Strategies Order EA-12-049, NEI Position Paper: Shutdown/ Refueling Modes
ML13267A382
Person / Time
Issue date: 09/30/2013
From: Jennifer Davis
NRC/NRR/MSD
To: Joseph E Pollock
Nuclear Energy Institute
Kratchman J, NRR/MSD, 415-5112
References
EA-12-049
Download: ML13267A382 (2)


Text

September 30, 2013 Mr. Joseph E. Pollock, Vice President Nuclear Operations Nuclear Energy Institute 1201 F Street NW, Suite 1100 Washington, DC 20004

Dear Mr. Pollock:

The U.S. Nuclear Regulatory Commission (NRC) staff has considered your request to endorse the Nuclear Energy Institute (NEI) position paper dated September 18, 2013, entitled Position Paper: Shutdown/ Refueling Modes (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML13273A514).

The purpose of the position paper is to further develop and clarify the guidance provided in NEI 12-06 (ADAMS Accession No. ML12221A205) related to industrys ability to meet the intent of Order EA-12-049, Order Modifying Licenses With Regard To Requirements for Mitigation Strategies for beyond Design Basis External Events, during shutdown and refueling modes of operation (ADAMS Accession No. ML12054A735). The NRC staff has interacted with your staff and external stakeholders during the development of this position paper.

The NRC staff agrees that the position paper provides an acceptable approach for demonstrating that the licensees are capable of implementing mitigating strategies in all modes of operation, including shutdown and refueling modes. The NRC staff will evaluate a licensees application of the guidance in its development of the final safety evaluation documenting compliance with NRC Order EA-12-049.

Individual licensees should inform the NRC of their plans to abide by this generic resolution and their plans to address potential plant specific issues associated with implementing this resolution that are identified during the audit process. Licensees are strongly encouraged to follow the guidance in the NEI position paper, Position Paper: Shutdown/ Refueling Modes, in order to improve efficiency of the NRCs review and to avoid further requests for information.

If a licensee deviates from the guidance, the licensee should justify the deviations and provide information that demonstrates that mitigating strategies can be performed in all modes of operations, including shutdown and refueling modes.

Sincerely,

/RA/

Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation

ML12221A205) related to industrys ability to meet the intent of Order EA-12-049, Order Modifying Licenses With Regard To Requirements for Mitigation Strategies for beyond Design Basis External Events, during shutdown and refueling modes of operation (ADAMS Accession No. ML12054A735). The NRC staff has interacted with your staff and external stakeholders during the development of this position paper.

The NRC staff agrees that the position paper provides an acceptable approach for demonstrating that the licensees are capable of implementing mitigating strategies in all modes of operation, including shutdown and refueling modes. The NRC staff will evaluate a licensees application of the guidance in its development of the final safety evaluation documenting compliance with NRC Order EA-12-049.

Individual licensees should inform the NRC of their plans to abide by this generic resolution and their plans to address potential plant specific issues associated with implementing this resolution that are identified during the audit process. Licensees are strongly encouraged to follow the guidance in the NEI position paper, Position Paper: Shutdown/ Refueling Modes, in order to improve efficiency of the NRCs review and to avoid further requests for information.

If a licensee deviates from the guidance, the licensee should justify the deviations and provide information that demonstrates that mitigating strategies can be performed in all modes of operations, including shutdown and refueling modes.

Sincerely,

/RA/

Jack R. Davis, Director Mitigating Strategies Directorate Office of Nuclear Reactor Regulation DISTRIBUTION:

PUBLIC SBailey SWhaley MSDP R/F EBowman JBowen RidsNRRLASLent Resource JDavis JKratchman ADAMS Accession No.: ML13267A382 OFFICE NRR/MSPB/PM NRR/MSPB/LA NRR/MSD NRR/MESB/BC NRR/MSD/D NAME JKratchman SLent EBowman SBailey JDavis DATE 9/25/13 9/25/13 9/26/13 9/26/13 9/30/13