ML16118A098
| ML16118A098 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/04/2016 |
| From: | Schlueter J Nuclear Energy Institute |
| To: | Booma Venkataraman Nuclear Energy Institute |
| Garmoe A, NRR/DPR, 301-415-3814 | |
| References | |
| Download: ML16118A098 (2) | |
Text
From:
SCHLUETER, Janet To:
Venkataraman, Booma Cc:
Helton, Shana; ASHKEBOUSSI, Nima
Subject:
[External_Sender] Draft RIS on EDD: Industry Suggested Edits Date:
Monday, April 25, 2016 3:47:55 PM Booma - Please acknowledge receipt.
This email provides the fuel cycle industrys suggested revised safety related definition for the Draft RIS on Embedded Digital Devices which was the subject of an April 6, 2016 NRC public meeting. We appreciated the opportunity to discuss this matter, and trust that the revised text below in red will be fully considered by NRC as it proceeds to finalize the RIS. If, for any reason, NRC has concerns, questions or comments on the text below, please contact me at your earliest convenience. General feedback is welcome as well.
As we have stated during NRC public meetings, in NEI letters and in discussions with you and others at NRC since 2014, the fuel cycle industry remains concerned that the Draft RIS contains a definition of safety related even though this term is not currently defined in NRC regulations nor does it need to be. We would also note that, from a risk perspective, the Draft RIS definition of safety related as it applies to a Part 50 power reactor (e.g., core damage) is significantly higher than that being applied to a fuel facility (e.g., performance criteria in 70.61). Further, we are not aware of the regulatory basis for such an inconsistent approach to risk management across NRC licensed facilities.
After careful consideration, we suggest that the two sentences at the top of page 11 of the Draft RIS that currently begin with For the purposes of this RIS and end with chemicals released, are met be deleted and replaced with the following.
While safety-related is not defined in 10 CFR Parts 40 and 70 for FCFs, for the purposes of this RIS, the term safety-related as applicable to FCFs applies to systems, structures, and components or parts thereof in which a defect or failure to comply could create a substantial safety hazard as defined in 10 CFR Part 21.3, i.e., sole IROFS.
Thanks for your time. Again, if you have any concerns, questions or comments on our suggested revised text, please contact me at your earliest convenience.
Janet R. Schlueter Senior Director, Radiation and Materials Safety
1201 F Street NW, Suite 1100 Washington, DC 20004 www.nei.org
P. 202-739-8098 M. 202-468-6673 F. 202-533-0132
E. jrs@nei.org T. @NEI
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