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Category:Letter
MONTHYEARML24023A0392024-01-22022 January 2024
NEI Comments on the Information Collection Renewal for Domestic Licensing of Special Nuclear Material, Docket Id NRC-2023-0118
ML23355A1972023-12-14014 December 2023
NEI, Comments on NRC Draft Resolution of SFAQ 2022-02, SAE Program Requirements
ML23219A1672023-10-25025 October 2023
Response Letter to Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07
ML23270B9002023-09-27027 September 2023
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
ML23268A0102023-09-22022 September 2023
NEI, Fee Exemption Request for Endorsement, Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors
ML23241A8612023-08-25025 August 2023
Consolidated Industry Comments to NRC Regulatory Issue Summary 2023-02, Scheduling Information for the Licensing of Accident Tolerant, Increased Enrichment, and Higher Burnup Fuels
ML23236A4992023-08-24024 August 2023
Industry Feedback on Region II Fuel Cycle Facility Construction Oversight Workshop Held August 15, 2023, and Suggested Topics for Additional Public Meetings in Fall 2023
ML23256A1622023-08-0101 August 2023
Incoming NEI Letter Dated August 1, 2023 Regarding Increase in Fees 2023-2025
ML23206A0292023-07-24024 July 2023
Incoming Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07
ML23143A1232023-06-22022 June 2023
NRC Fee Waiver Request for Draft NEI 23-01
ML23200A1662023-05-30030 May 2023
NEI Proposed Metrics for a Performance-Based Emergency Preparedness Program
ML23116A0732023-05-25025 May 2023
Letter to Hillary Lane in Response to a Request for a Fee Exemption for NEI 23-03
ML23135A7332023-05-0909 May 2023
NEI Comments on NRC Safety Culture Program Effectiveness Review
ML23110A6752023-04-18018 April 2023
04-18-23_NRC_Fee Waiver for NEI 23-03
ML23110A6782023-04-18018 April 2023
Request for Review and Endorsement of NEI 23-03, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications at Non-Power Production or Utilization Facilities
ML23110A6762023-04-18018 April 2023
04-18-23_NRC_NEI 23-03 Review + Endorse
ML23107A2302023-03-31031 March 2023
NEI Letter, to Andrea Veil, NRC, Regarding Industry Recommendations for a 10 CFR 50.46a/c Combined Rulemaking
ML23138A1662023-03-24024 March 2023
Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07
ML23083B4622023-03-24024 March 2023
Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07
ML23060A3272023-03-0101 March 2023
NEI, Wireless Cyber Security Guidance
ML23060A2142023-03-0101 March 2023
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
ML22348A1122023-01-17017 January 2023
Letter to Richard Mogavero Response to Fee Exemption NEI 08-09 Revision 7
ML22353A6082023-01-11011 January 2023
U.S. Nuclear Regulatory Commission Report of the Regulatory Audit of the NEI-Proposed Aging Management Program Revision to Selective Leaching Program (XI.M33)
ML22349A1012022-12-12012 December 2022
LTR-22-0343 Ellen Ginsberg, Sr. Vice President, General Counsel and Secretary, Nuclear Energy Institute, Expresses Concerns Related to Issuance of Regulatory Issue Summary 2022-02; Operational Leakage
ML22336A0372022-11-16016 November 2022
Fee Exemption Request for NEI 08-09 Revision 7 - Changes to NEI 08-09 Cyber Security Plan for Nuclear Power Reactors
ML22321A3152022-11-16016 November 2022
NEI Letter with Comments on Significance Determination Process Timeliness Review
ML22298A2262022-10-25025 October 2022
Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated October 2022
ML22298A2302022-10-17017 October 2022
Submittal of NEI 22-03, Draft Revision 0, Nuclear Generation Quality Assurance Program Description
ML22207B6512022-07-26026 July 2022
NEI, Full Fee Exemption Request for Industry Guidance Proposal - Weather Related Administrative Controls During Transient Outdoor Dry Cask Operations
ML22195A1662022-07-14014 July 2022
NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7
ML22195A0202022-07-13013 July 2022
07-13-22 NRC Fee Exemption Request for NEI 21-05 Review
ML22195A0672022-07-13013 July 2022
Fee Exemption Request for Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 21-05, Reporting Guidance for Licensees with Risk-Informed Licensing Bases
ML22159A2772022-06-28028 June 2022
Response Letter to Richard Mogavero for Fee Exemption for the Nuclear Regulatory Commission Review Ad Endorsement of NEI 15-09, Revision 1
ML22153A2782022-06-0202 June 2022
Nie, Fee Exemption Request for Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated May 2022
ML22154A2962022-06-0202 June 2022
LTR from R. Mogavero to M. Sampson Dated Jun 2 2022 Endorsement of NEI 15-09 Cyber Security Event Notifications Rev 1 Dated May 2022
ML22152A2712022-06-0101 June 2022
Digital Instrumentation and Control Common Cause Failure Policy Considerations, Revision 1
ML22143A9362022-05-20020 May 2022
May 13, 2022, Public Meeting on Draft Regulatory Issue Summary Operational Leakage, 87 Fed. Reg. 2361 (Jan. 14, 2022) (Docket Id NRC-2021-0173)
ML22110A1752022-05-0303 May 2022
NRC Response to the Nuclear Energy Institute April 1, 2022, Letter, Regarding the Nrc'S CUI Implementation Plan
ML22109A2082022-04-0808 April 2022
April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0
ML22110A1782022-04-0101 April 2022
April 1, 2022, Letter from NEI Regarding Nrc'S Controlled Unclassified Information Program Implementation
ML22048A5812022-02-16016 February 2022
NEI 22-02: Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations
ML22019A2922022-01-12012 January 2022
NEI, Submittal of Proposed Revisions to Aging Management Programs XI.M33, Selective Leaching and XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements
ML21343A2922021-12-0808 December 2021
NEI, Transmittal of NEI 21-07 Revision 0-B, Technology Inclusive Guidance for Non-Light Water Reactor Safety Analysis Report: for Applicants Utilizing NEI 18-04 Methodology
ML21337A3802021-12-0303 December 2021
NEI Technical Report NEI 17-06 - Guidance on Using Iec 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications, Revision 1
ML21319A3522021-11-10010 November 2021
NRC NEI Fee Waiver Request Changes to NEI 10-04 and NEI 13-10, Dated November 10, 2021
ML21306A3652021-10-29029 October 2021
NEI Letter from D. Young to NRC S. Atack to Cease Work on Draft D of NEI 20-05, Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Eligibility Criteria of 10 CFR 73.55(a)(7)
ML21342A1682021-10-29029 October 2021
Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 10-04, Identifying Systems and Assets Subject to the Cyber Security Rule, Revision 3, Dated October 29, 2021
ML21342A2032021-10-29029 October 2021
Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 13-10, Cyber Security Control Assessments, Revision 7, Dated October 29, 2021
ML22081A2002021-10-29029 October 2021
NEI Backfitting Concerns with NRCs Developing Position on Protection of Dry Storage Systems from Natural Phenomena During Short Term Operations
2024-01-22
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Text
MICHAEL D. TSCHILTZ Senior Director, New Plant, SMR &
Advanced Reactors 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8083 mdt@nei.org nei.org June 14, 2017 Mr. Michael E. Mayfield Deputy Director (Acting)
Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
NEI White Paper, First Principles for Use in Developing Design Certification Tier 1 and Information and Inspections, Tests, Analyses and Acceptance Criteria, dated June 2017 Project Number: 689
Dear Mr. Mayfield:
On behalf of the nuclear industry, the Nuclear Energy Institute (NEI) 1 is pleased to submit for NRC review and feedback the attached NEI white paper, First Principles for Design Certification Tier 1 Information and Inspections, Tests, Analyses and Acceptance Criteria, dated June 2017. This paper contains guidance to assist in developing design certification applications.
From 2013 to 2016, the NRC held numerous public meetings with the industry to discuss the standardization of inspections, tests, analyses and acceptance criteria (ITAAC) with the objective to clarify the scope of ITAAC required for design certification applications. This process has been guided by the application of First Principles that have been expressed in several NRC policy papers from the early 1990s concerning the scope of Tier 1 and ITAAC. Lessons learned from the development and implementation of ITAAC for the lead new plant projects have also been incorporated to improve clarity. Our interactions with the NRC have underscored the importance of First Principles as a basis for assuring that applications contain the appropriate scope of Tier 1 and ITAAC.
1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.
Mr. Michael E. Mayfield June 14, 2017 Page 2 Over the same period, the industry has engaged NRC in several public meetings on the use of Tier 2*
information - information that resides in Tier 2 of a design certification but requires prior NRC approval to change, similar to Tier 1. The industry has argued that the use of Tier 2* has proven problematic and burdensome and should be ended in favor of designating design information as either Tier 1 or Tier 2. The NRC staff has agreed that use of Tier 2* should minimized and more tightly controlled. Whether the goal is to eliminate or minimize Tier 2*, we and the staff have discussed that clear guidance is needed to determine the proper scope of Tier 1 versus Tier 2.
Thus, we are providing this white paper as a basis further discussion leading to a common understanding on Tier 1/ITAAC First Principles. Establishing a clear set of First Principles will support determinations on the scope of Tier 1 and Tier 2 information in ongoing and future design certifications. With the benefit of First Principles, the ongoing reviews are expected to indicate whether future design control documents can contain only Tier 1 and Tier 2 information, or that a limited scope of Tier 2* information is necessary.
The First Principles in the attached white paper are taken from a draft revision of NEI 15-02, Industry Guideline for the Development of Tier 1 and ITAAC Under 10 CFR Part 52, which contains guidance to applicants to standardize Tier 1 and ITAAC. We plan to submit for NRC review and endorsement the revision to NEI 15-02 that incorporates feedback on the standardized ITAAC provided in connection with the ongoing NuScale design certification review. In addition, the revision of NEI 15-02 will include Tier 1/ITAAC First Principles updated based on the outcome of discussions with the NRC staff on the attached white paper.
We will be in contact with you to request a public meeting to discuss Tier 1/ITAAC First Principles. In the meantime, if you have any questions or require additional information, please contact Russ Bell (rjb@nei.org; 202.739.8087) or me.
Sincerely, Michael D. Tschiltz Attachment c: Mr. Timothy J. McGinty, NRO/DCIP, NRC Mr. Joseph Colaccino, NRO/DARR/NRCB, NRC NRC Document Control Desk