ML18254A362

NEI Reactor Oversight Process Whitepaper, Change to the NEI 99-02 Text for the Drill/Exercise Performance Indicator - Initial Notification Form Accuracy.

ML18254A362
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/07/2018
From:	Young D Nuclear Energy Institute
To:	Robert Kahler Policy and Oversight Branch
Quinones J, NRR/DIRS, 404-997-4469
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ML18254A348	List: ML18254A362 ML18254A366 ML18256A295
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Download: ML18254A362 (2)

Text

DAVID YOUNG Technical Advisor, Nuclear Security and Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8127 dly@nei.org nei.org September 7, 2018 Mr. Robert Kahler Chief, Regulatory Policy and Oversight Branch Division of Preparedness and Response Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

NEI Reactor Oversight Process Whitepaper, Change to the NEI 99-02 Text for the Drill/Exercise Performance Indicator - Initial Notification Form Accuracy

Dear Mr. Kahler:

During a Reactor Oversight Process (ROP) public meeting on April 5, 2018,1 the Nuclear Energy Institute 2 (NEI) introduced three white papers associated with emergency preparedness performance indicators to the NRC for review. One of the white papers proposed a change to the criteria for assessing the accuracy of an initial notification form used to provide information to an Offsite Response Organization (ORO); the criteria are presented in the Drill/Exercise Performance section of NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The change would eliminate the current guidance to report a Drill/Exercise Performance (DEP) opportunity failure for an incorrect form entry that would not impact the ability of an ORO to make a Protective Action Decision (PAD).

NEI and industry representatives met with the NRC on August 28, 2018, to discuss staff comments on the proposed change.3 The white paper has been revised to address the comments provided in the meeting and the revised paper is attached to this letter.

We request a review of the attached white paper and a response indicating NRC approval for implementation.

1 Refer to ADAMS Accession No. ML18109A397 2

The Nuclear Energy Institute is the organization responsible for establishing unified industry policy on matters affecting its members, 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, suppliers and nuclear materials licensees, nuclear medicine and radiopharmaceutical companies, companies using nuclear technologies in the agricultural, food, and industrial sectors, universities and research laboratories, law firms, labor unions, and international electric utilities.

3 Refer to ADAMS Accession No. ML18205A361

Mr. Robert Kahler September 6, 2018 Page 2 If you have questions or require additional information, please contact me at (202) 739-8127 or dly@nei.org.

Sincerely, David L. Young Attachment c: Mr. Greg Bowman, NRR/DIRS/IRAB, NRC