ML18221A131
| ML18221A131 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 08/01/2018 |
| From: | Riti T Nuclear Energy Institute |
| To: | May Ma Rules, Announcements, and Directives Branch |
| References | |
| 83FR31429 00001, NRC-2018-0137 | |
| Download: ML18221A131 (3) | |
Text
As of: 8/8/18 1:38 PM Received: August 01, 2018 PUBLIC SUBMISSION Status: Pending_Post Tracking No. lk2-94lv-y011 Comments Due: September 04, 2018 Submission Type: Web Docket: NRC-2018-0137 Dispositioning of Technical Specifications that are Insufficient to Ensure Plant Safety Comment On: NRC-2018-0137-0001 Dispositioning of Technical Specifications That Are Insufficient To Ensure Plant Safety Document: NRC-2018-0137-DRAFT-0001 Comment on FR Doc# 2018-14379 Submitter Information Name: Tim Riti Organization: Nuclear Energy Institute General Comment See attached.
Attachments 08-01-18_NRC_NEI Draft Industry Comments to Draft Regulatory Guide DG-13.. _
SUNSI Review Complete Template =a ADM-013 E-RIDS=aADM-03 ADD"' Blake Purnell Stephen Burton COMMENT (l)PUBLICATION DATE:
7/5/2018 CITATION: 83 FR 31429
TIMOTHY RITI Senior Project Manager, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8137 M: 202.230.4498 txr@nei.org nei.org August 1, 2018 Ms. May Ma Office of Administration Mail Stop: 1WFN-7-A60M*
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 NUCLEAR ENERGY INSTITUTE
Subject:
Industry Comments to Draft Regulatory Guide DG-1351, "Dispositioning of Technical Specifications That Are Insufficient To Ensure Plant Safety" (Federal Register Vol. 83, 31429, dated July 5; 2018 - Docket ID NRC-2018-0137)
Project Number: 689
Dear Ms. Ma:
On behalf of its members, the Nuclear Energy Institute (NEI)1 appreciates the opportunity to provide comments on the proposed Draft Regulatory Guide (DG-1351) which proposes new guidance on methods and procedures that are acceptable to the NRC staff for dispositioning of technical specifications (TS) that are insufficient to ensure power plant safety.
The draft regulatory guide endorses NEI 15-03, Revision 2, "Licensing Actions to Address Nonconservative Technical Specifications," with exceptions.
In 2013, the NRC requested that the industry develop guidance on licensee actio!'}s to address nonconservative Technical Specifications (NCTS) to replace NRC Administrative Letter 98-10,"Dispositioning of Technical Specifications that are Insufficient to Ensure Plant Safety." The industry guidance would be in lieu of new NRC guidance. The industry and NRC held.two meetings in 2014 and NEI 15-032 was submitted 1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing. unified policy on *behalf of its members on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues.
NEI's members include.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 arid entities involved in the nuclear energy industry.
2 NEI 15~03, Rev. 0, "Licensee Actions to Address Nonconservative Technical Specifications", April 2015, transmitted by NEI's Bruce S. Montgomery to NRC's Robert B. Elliott by letter dated May 11, 2015.
Ms. May Ma August 1, 2018 Page 2 in May 2015. In July 2016, a follow up meeting occurred to discuss NRC comments on this document. The industry revised the document to address the staff concerns and submitted Revision 1 in October 2016. The NRC staff requested another meeting in August 2017 to discuss additional comments. The industry revised NEI 15-03 to address the NRC staff concerns and submitted Revision 2 in October 2017. Industry representatives believed the staff's concerns were addressed in Revision 2 to NEI 15-03. The exceptions that the staff describes in DG-1351 for treatment of a lack of technical specifications and expectations for final corrective action timeliness are significant and could be interpreted as imposi_ng new requirements on the industry.
We request that the comment period be extended from September 4th by an additional 30 days. This should provide time for NRC and industry to meet and, hopefully, resolve NEI's concerns.
Please contact me at txr@nei.org if you require information or clarification concerning these comments.
Sincerely,
- ~
?
Timothy Riti c:
- Michele Evans NRC/NRR