ML17249A098

NEI - Response to NRC Preliminary Comments on NEI 98-03, Guidelines for Updating Final Safety Analysis Reports, Draft Revision 2

ML17249A098
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/05/2017
From:	Tschiltz M Nuclear Energy Institute
To:	Document Control Desk, Office of New Reactors
Shared Package
ML17249A097	List: ML17249A098 ML17249A099 ML17249A100
References
NEI 98-03, Rev. 2
Download: ML17249A098 (2)

Text

MICHAEL D. TSCHILTZ Senior Director, New Plant, SMRs and Advanced Reactors 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8083 mdt@nei.org nei.org September 5, 2017 Mr. Robert K. Caldwell, Jr.

Acting Director, Division of Engineering, Infrastructure and Advanced Reactors Office of New Reactors U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Response to NRC Preliminary Comments on NEI 98-03, Guidelines for Updating Final Safety Analysis Reports, Draft Revision 2 Project Number: 689

Dear Mr. Caldwell:

Attached for NRC review is an updated draft Revision 2 of NEI 98-03, Guidelines for Updating Final Safety Analysis Reports. This revision responds to preliminary comments provided by your staff in a letter dated February 28, 2017. A comment response table is also provided for convenience.

When the industry initially submitted draft Revision 2 in March of 2015, our intent was only to update guidance that the NRC has endorsed in Regulatory Guide 1.181 for 10 CFR Part 50 power reactor licensees to add guidance for 10 CFR Part 52 licensees. Specifically, a narrow scope of changes was proposed to address the applicability of this guidance to UFSARs that may reference a design certification rule and considerations for associated NRC reporting requirements.

Our intent to focus on this narrow scope of changes remains, as lead Part 52 licensees would like to begin using this guidance as soon as possible and Part 50 licensees have other regulatory priorities that require their continued focused attention. If the NRC would like to address the expanded scope of recommendations, comments, and questions related to previously endorsed, or new, guidance for Part 50 (and Part 52) licensees, we propose to defer those activities to the next periodic review for RG 1.181, i.e.,

following its issuance to endorse the narrow scope guidance update in Revision 2 of NEI 98-03.

We look forward to a public meeting to align on resolution of the NRC staff comments related to the applicability of this guidance to Part 52 licensees. We request that a public meeting be scheduled at the earliest possible convenience. Upon resolution of staff comments on draft NEI 98-03, Revision 2, we plan to submit the final guidance for NRC endorsement in a regulatory guide.

Mr. Robert K. Caldwell September 5, 2017 Page 2 If there are any questions on this matter, please contact me or Kati Austgen (202.739.8068; kra@nei.org).

Sincerely, Michael D. Tschiltz Attachments c: Mr. Frank Akstulewicz, Jr, NRO/DRNL, NRC Mr. Joseph Colaccino, NRO/ DNRL/LB3, NRC Dr. Barbara Hayes, NRO/DNRL/LB3, NRC NRC Document Control Desk