ML16293A951
| ML16293A951 | |
| Person / Time | |
|---|---|
| Issue date: | 11/10/2016 |
| From: | Mary Johnson NRC/EDO |
| To: | Pietrangelo A Nuclear Energy Institute |
| Tilton C | |
| Shared Package | |
| ML16274A472 | List: |
| References | |
| OEDO-16-00665 | |
| Download: ML16293A951 (2) | |
Text
November 10, 2016 Mr. Anthony R. Pietrangelo, Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute 1201 F Street, NW, Suite# 1100 Washington, DC 20004
Dear Mr. Pietrangelo:
By letter dated September 29, 2016 (Agencywide Document Access and Management System (ADAMS) Accession No. ML16274A473), the Nuclear Energy Institute (NEI) provided industrys views on the U.S. Nuclear Regulatory Commissions (NRCs) Operability Determination (OD) process as documented in Inspection Manual Chapter 0326, Operability Determinations &
Functionality Assessments for Conditions Adverse to Quality or Safety (ADAMS Accession No. ML15328A099). In this letter, NEI disagreed with recent application of NRCs OD guidance and stated the industrys intention to develop guidance clarifying the conditions and criteria that would lead to entry into the OD process. Specifically, NEI disagreed with two Non-Cited Violations (NCVs) issued by the NRC to Indian Point 3 (NCV 05000286/2016002-02, ADAMS Accession No. ML16243A245) and Salem 2 (NCV 05000311/2016002-02, ADAMS Accession No. ML16266A224). These NCVs document licensees noncompliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for not following station procedures for conducting ODs when new operating experience indicated more extensive degradation of baffle former bolts was likely.
With respect to the specific NCVs referenced in your letter, the NRC staff will continue to follow its process regarding contested NCVs which can be found in Section 2.2.8, Licensee Denial of NCV, of the Enforcement Manual (ADAMS Accession No. ML102630150).
The NRC staff is aware of NEIs ongoing effort to develop industry guidance on the process for performing ODs. The NRC staff looks forward to continued meaningful interactions with industry and the public to help ensure necessary and appropriate clarity in OD guidance.
If you have any further questions, please contact the Chief of the Technical Specifications Branch, Alexander R. Klein by email at Alex.Klein@nrc.gov or by phone at 301-415-2822.
Sincerely,
/RA/
Michael R. Johnson Deputy Executive Director for Reactor and Preparedness Programs Office of the Executive Director for Operations
ML15328A099). In this letter, NEI disagreed with recent application of NRCs OD guidance and stated the industrys intention to develop guidance clarifying the conditions and criteria that would lead to entry into the OD process. Specifically, NEI disagreed with two Non-Cited Violations (NCVs) issued by the NRC to Indian Point 3 (NCV 05000286/2016002-02, ADAMS Accession No. ML16243A245) and Salem 2 (NCV 05000311/2016002-02, ADAMS Accession No. ML16266A224). These NCVs document licensees noncompliance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for not following station procedures for conducting ODs when new operating experience indicated more extensive degradation of baffle former bolts was likely.
With respect to the specific NCVs referenced in your letter, the NRC staff will continue to follow its process regarding contested NCVs which can be found in Section 2.2.8, Licensee Denial of NCV, of the Enforcement Manual (ADAMS Accession No. ML102630150).
The NRC staff is aware of NEIs ongoing effort to develop industry guidance on the process for performing ODs. The NRC staff looks forward to continued meaningful interactions with industry and the public to help ensure necessary and appropriate clarity in OD guidance.
If you have any further questions, please contact the Chief of the Technical Specifications Branch, Alexander R. Klein by email at Alex.Klein@nrc.gov or by phone at 301-415-2822.
Sincerely,
/RA/
Michael R. Johnson Deputy Executive Director for Reactor and Preparedness Programs Office of the Executive Director for Operations DISTRIBUTION: OEDO-16-00665 PUBLIC CTilton AKlein RidsNrrDSS RidsNrrDE RidsNrrDIRS RidsOeMailCenter RidsNrrOd RidsOgcMailCenter RidsEdoMailCenter RidsRgn1MailCenter ADAMS Accession No.: ML16293A951 Incoming No.: ML16274A471 NEI Ltr: ML16274A473 Package No.: ML16274A472
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NAME CTilton AKlein TMcGinty JLubinski CMiller CHsu DATE 10/28/2016 10/28/2016 10/28/2016 10/28/2016 10/28/2016 11/1/2016 OFFICE OE*
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EDO NAME PHolahan BHarris WDean DDorman MJohnson DATE 11/03/2016 11/1/2016 11/04/2016 11/03/2016 11/10/2016