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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
[Table view] Category:Report
MONTHYEARML23290A1252023-10-17017 October 2023 NEI - NEI 99-02, Rev. 8, Draft Regulatory Assessment Performance Indicator Guideline ML23290A1472023-10-17017 October 2023 NEI 99-02 Rev 8 Draft 9 29 2023 Redline Version ML23157A1062023-06-0606 June 2023 NEI 19-01, Rev 1, Safety and Economic Benefits of Accident Tolerant Fuel ML23129A0282023-05-0202 May 2023 20230502, NEI Issues for Event Notification Implementation Workshops ML23110A6762023-04-18018 April 2023 04-18-23_NRC_NEI 23-03 Review + Endorse 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 ML23125A3202023-03-0101 March 2023 Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 Revision a 5-4-23 Tirice Response to NRC Comments ML22298A2282022-10-25025 October 2022 NEI 15-09, Rev. 1, Cybersecurity Event Notifications ML22297A2482022-10-20020 October 2022 NEI Comments on 10-20-2022 CCF Meeting Feedback and Comments ML23072A0632022-09-30030 September 2022 (Draft) NEI White Paper Remediation of Vulnerabilities Identified in CDAs - 08302022R0 ML22195A1692022-07-31031 July 2022 NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 - Change Summary ML22195A1672022-07-14014 July 2022 NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 ML22195A1682022-07-14014 July 2022 NEI, Marked-Up to Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 ML22109A2082022-04-0808 April 2022 April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0 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 ML21343A2822021-12-31031 December 2021 Redline/Strikeout Version of NEI 21-07 Rev 0-B, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Using the NEI 18-04 Methodology 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 ML21305A0012021-11-30030 November 2021 NEI 17-06 Rev 0 Draft B, Guidance on Using Iec 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications (Staff Comments Incorporated 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 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 ML21274A0312021-10-0101 October 2021 NRC Draft Detailed Comments Related to NEI 21-07, Revision 0, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Using the NEI 18-04 Methodology ML21278A4722021-09-30030 September 2021 NEI 20-07, Rev. Draft, Guidance for Addressing Common Cause Failure in High Safety-Significant Safety-Related Digital I&C Systems ML21257A2352021-08-19019 August 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security, Email Exchange Between Nrc and NEI Draft Pages from NEI-20-05 Rev. E ML21250A3782021-08-0202 August 2021 NEI 21-07, Revision 0, Technology Inclusive Guidance for Non-Light Water Reactors SAR Content for Applicants Using the NEI 18-04 Methodology ML21130A5962021-05-31031 May 2021 NEI, Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems - Draft C ML21130A5972021-05-31031 May 2021 NEI 20-07, Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems - Draft C ML21130A5982021-05-0707 May 2021 NEI Responses to NRC Staff Comments on NEI 20-07 Draft B ML21125A2842021-05-0505 May 2021 Transmittal of NEI 20-09: Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-Light Water Reactor Standard ML21110A0662021-04-20020 April 2021 Nei'S Comparison Table Between NEI 20-07 Sdos and NRC RGs and Endorsed IEEE Stds R2 ML21085A5552021-03-25025 March 2021 NEI 20-09 -Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-LWR PRA Standard, March 2021 ML21089A0902021-03-18018 March 2021 NEI Comments on Renewal of Performance Indicators Information Collection, March 18, 2021 ML21049A0572021-03-0202 March 2021 Rulemaking: Proposed Rule: NRC Markup of NEI-20-05 Draft B Comments on Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Performance Criteria of 10 CFR 73.55(a)(7) ML20339A4852020-11-23023 November 2020 NEI 20-09 - NRC Comments Resolved November 2020 ML20322A3392020-11-17017 November 2020 NEI ROP White Paper Modification of the Description of Unplanned Scrams with Complications for Nov 18 2020 ROP Public Meeting ML21050A0902020-08-31031 August 2020 Staff Detailed Comments - NEI 20_07 Draft Revision B -February 2021 ML20245E1472020-08-31031 August 2020 Attachment 1 - NEI Guidelines for the Implementation of the Risk-Informed Process for Evaluations Integrated Decision-Making Panel ML20245E5612020-08-31031 August 2020 Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems ML20302A1152020-08-24024 August 2020 NEI 20-09 - Nlwr PRA Peer Review Rev1 August 2020 ML20211L7142020-07-24024 July 2020 Industry Position Regarding Safety Margin: Dispositioning Degraded or Failed Management Measures Above and Beyond Regulatory Requirements, and Meeting Performance Criteria; Follow Up to May 6, 2020 Letter on Smarter Program Inspection Prior ML20155K6852020-06-0101 June 2020 Availability of NEI 20-09, Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-LWR Standard, for NRC Review and Endorsement ML20154K5662020-06-0101 June 2020 Availability of NEI 20-09, Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-LWR Standard, for NRC Review and Endorsement ML20129J8592020-05-31031 May 2020 NEI 96-07, Appendix D Revision 1, Draft M, May 2020 ML20129J8582020-05-30030 May 2020 NEI 96-07, Appendix D, Revision 1, Draft M, May 2020 with Redline Strike ML20141L7882020-05-20020 May 2020 NEI - Comments on Draft Micro-Reactor Applications COL-ISG-029, Environmental Considerations Associated with Micro-Reactors ML20139A1902020-05-14014 May 2020 05-14-20 Changes to NEI 10-04 and NEI 13-10 Guidance for Identifying and Protecting Digital Assets Associated with Safety-Related and Important-to-Safety Functions ML20134J0332020-05-13013 May 2020 Submittal of Response to Request for Additional Information (RAI) for NEI 14-05A, Revision 1, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services ML20135H1682020-05-13013 May 2020 Request for NRC Endorsement of NEI 96-07, Appendix D, Rev 1 2023-06-06
[Table view] Category:Miscellaneous
MONTHYEARML23129A0282023-05-0202 May 2023 20230502, NEI Issues for Event Notification Implementation Workshops ML22297A2482022-10-20020 October 2022 NEI Comments on 10-20-2022 CCF Meeting Feedback and Comments ML23072A0632022-09-30030 September 2022 (Draft) NEI White Paper Remediation of Vulnerabilities Identified in CDAs - 08302022R0 ML22109A2082022-04-0808 April 2022 April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0 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 ML21130A5982021-05-0707 May 2021 NEI Responses to NRC Staff Comments on NEI 20-07 Draft B ML21089A0902021-03-18018 March 2021 NEI Comments on Renewal of Performance Indicators Information Collection, March 18, 2021 ML20141L7882020-05-20020 May 2020 NEI - Comments on Draft Micro-Reactor Applications COL-ISG-029, Environmental Considerations Associated with Micro-Reactors ML20100G9032020-03-31031 March 2020 NEI 15-03, Rev. 3, Licensee Actions to Address Nonconservative Technical Specifications ML20038A1952020-02-0606 February 2020 NEI Dic Comments on BTP 7-19 Revision 8 to Support Feb 11 2020 Public Meeting ML19312B1022019-10-15015 October 2019 NEI Letter to A. Kock Industry Proposal 2 - Smarter Program for Fuel Cycle Facilities; Follow Up to September 25, 2019 Public Meeting in Preparation for Subsequent Fall 2019 Meetings ML19239A0162019-08-27027 August 2019 NEI Comments on IMC 0609, Appendix a and Attachment 1 August 2019 ML19226A3342019-08-14014 August 2019 (NEI) - Comments on Draft Interim Staff Guidance on the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept ML19261B9552019-08-0101 August 2019 Miscellaneous Material Related to DG-1353 on Licensing Basis for Non-LWRs ML19142A0712019-05-20020 May 2019 NEI 07-07 Rev 1, Industry Groundwater Protection Initiative - Final Guidance. ML18324A7772018-11-0909 November 2018 (NEI)- Summary of Information Provided at the October 17, 2018 Public Meeting Association with Implementation of Open Phase Isolation Systems - ML18271A111 ML18275A1212018-10-0101 October 2018 Letter from Nuclear Energy Institute Endorsement of Iso/Iec 17025: 2017, General Requirements for the Competence of Testing and Calibration Laboratories. ML18268A1142018-09-20020 September 2018 Industry Initiative on Open Phase Condition, Revision 2 ML18260A0012018-09-14014 September 2018 September 14, 2018, Update to NEI 17-06 ML18180A3132018-03-16016 March 2018 NEI Recommendations for NRC Regulatory Tranformation Initiative ML17268A0362017-09-30030 September 2017 NEI 17-02, Revision 1, Tornado Missile Risk Evaluator (TMRE) Industry Guidance Document ML17249A0952017-09-30030 September 2017 NEI 12-04, Revision 1, Draft a, Guidelines for 10 CFR 72.48 Implementation. ML17234A6152017-08-31031 August 2017 NEI 13-10, Revision 6, Cyber Security Assessment. ML17230A3532017-08-0404 August 2017 Anchor Darling Double Disc Gate Valve Industry Resolution Plan 8-4-2017 Update ML17212A6352017-07-31031 July 2017 07-20-17 NEI 0809 Addendum 4 Attachment 2 ML17209A7352017-07-14014 July 2017 Anchor Darling Double Disc Gate Valve Industry Resolution Plan ML17137A0192017-05-17017 May 2017 NEI 96-07 Appendix D Draft Revision 0 - Proposed Revisions - May 16, 2017 Redline ML17137A0202017-05-17017 May 2017 NEI 96-07 Appendix D Draft Revision 0 - Proposed Revisions - May 16, 2017 ML17136A1522017-05-16016 May 2017 Draft of NEI 06-11 Revision 2, Managing Personnel Fatigue at Nuclear Power Reactor Sites) for Discussion at NRC Public Meeting on 2017-June-15 ML17269A0012017-05-16016 May 2017 NEI 96-07, Appendix_D with Hsi Edits from 9/19/2017 - 9/21/2017 Meeting ML17121A4302017-05-0101 May 2017 Industry Comments on the Draft Implementation Plan ML17044A0272017-02-0101 February 2017 February 1, 2017, NEI / Industry Input to Modernization Plan No. 3 - Scope of 3rd Party Certification for Commercial Grade Digital Equipment ML12200A3752012-08-31031 August 2012 Comments on Nuclear Energy Institute 96-07, Appendix C: Guideline for Implementation of Change Control Processes for New Nuclear Power Plants Licensed Under Title 10 of the Code of Federal Regulations, Part 52, Revision 0C ML1208000722012-03-20020 March 2012 Letter NEI 96-07 App C Rev. 0C NRC Comments ML0928904002009-09-30030 September 2009 NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, Revision 3 ML0724204472007-08-0606 August 2007 White Paper Testing of Dynamic Soil Properties for Nuclear Power Plant COL Applications ML0520900382005-07-20020 July 2005 Attachment for the Summary of July 20, 2005 Meeting Between NRC and NEI, Cipims/Itaac Verification Demonstration Program, Phase I Report, Revision 0 ML15084A2091998-01-28028 January 1998 Letter to Mr. Modeen, NEI NRC Staff Views on Clarifications Contain in Nei'S July 22, 1997 on Severe Accident Management ML18263A0401996-01-0101 January 1996 One Year Without a Disposal Site for Low-Level Radioactive Waste - Lessons Learned from the Barnwell Closure to 31 States 7/1/94 - 6/30/95 (Enclosure to Comments Submitted on DSI-4, DSI-5, DSI-7, DSI-9, DSI-12, DSI-13, DSI-14, DSI-21, DSI-G 2023-05-02
[Table view] |
Text
STEPHEN E. GEIER Director, Risk and Technical Support 1201 F Street, NW, Suite 1100 Washington, DC 20004
~I NUCLEAR ENERGY INSTITUTE P: 202.739.8111 seg@nei.org
_nei.org November 19, 2018 Mr. Eric Benner Director, Division of Engineering U.S. Nuclear Regulatory Commission
- Washington, DC 20555-0001
Subject:
Summary of Information Provided at the October 17, 2018 Public Meeting Associated with Implementation of Open Phase Isolation Systems (OPIS) - ML18271A111 Project Number: 689
Dear Mr. Benner:
The Nuclear Energy Institute (NEI), 1 on behalf of its industry members, appreciates the opportunity to provide input to the staff's technical evaluation of the Open Phase Isolation System (OPIS} modifications, including the discussion at the public meeting on October 17, 2018. The meeting was an important forum -
for the industry to .discuss with NRC staff their observations and questions concerning the implementation of the open phase isolation systems. The information presented during the public meeting was intended to support the staff's evaluation of licensee implementation of the NEI Open Phase Condition Initiative, or Voluntary Industry Initiative (VII).
The staff's observations and questions were categorized in four topics of interest: (1) Open Phase Condition (OPC) detection and alarm, (2)-0PC protective action, (3) updated final safety analysis report update, and (4) surveillance and limiting condition for operation requirements. NEI, along with industry members, presented responses to each of.these questions during the public meeting. As a follow-up to the industry presentation and discussions at the meeting, this letter and attachment are provided to document the information provided to the staff.
1 The Nuclear Energy Institute (NE!) is responsible for establishing unified policy on behalf of its members relating to 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 and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
NUCLEAR. CLEAN AIR ENERGY
Mr. Eric Benner November 19, 2018 Page 2 If you have questions or need additional information, please contact Frances Pimentel (202-739-8132; fap@nei.org) or me (202-739-8111; seg@nei.org).
Sincerely, Stephen Geier Attachment cc: Mr. Ho Nieh, NRR, NRC Mr. Brian J. McDermott, NRR, NRC Mr. Jessie F. Quichocho, NRR/DE/EEOB, NRC Ms. Leslie Perkins, NRR, NRC
Attachment 1
- Summary of Answers Provided During Public Meeting on October 17. 2018 The questions cited below were those provided by the NRC prior to the meeting (ML18271A111) to help focus the discussion ~md interaction. The responses provided reflect the information included on the industry slid~s (ML18289A992) provided at the 10/17/18 public meeting (ML18277A137) supplemented with some additional information provided during the discussions.
1 - Open Phase Condition(OPC) Detection and Alarm
None.
The proposed OPC detection and alarm design schemes appeared technically adequate to detect and alarm in the main control room in the event of an unbalanced voltage from an OPC.
2 - OPC Protective Actions Questions:
- a. What actions are beihg taken to mitigate the potential consequences resulting from a potential OPIS failure? How do these actions meet the OPCVII criteria?
- b. If there was a failure of the OPIS, how would the pl_ant meet the provisions for single failure of the onsite power system to mitigate against Design Basis Accidents (DBAs)? If so, describe how.
Response
The potential failure of the OPIS is mitigated by both design features and response actions. From a design perspective the OPIS typically fails in a non-trip state in that it will not result in the loss of the offsite power circuit or affect the functionaiity of connected equipment. If the.OPIS spuriously actuates, the consequences are bounded by the response of the existing protective relaying system associated with the offsite power system. The affected source would be isolated, and the plant response would respond as designed-i.e., the load would be transferred to standby .sources. Further, existing relaying, e.g., ground fault protection, neutral overcurrent protection and degraded voltage protection, will be able to detect certain open phase conditions. Therefore, even with the OPiS not functional and without operator actions, certain open phase conditions can still be detected.
From a mitigation perspective the operators are alerted to an. OPIS failure or malfunction via the Main Control Room (MCR) alarm(s). The typical OPIS is self-checking and capable of indication ,upon failure or malfunction. Given the indication of a failure or malfunction, the operators would impleme.nt corresponding mitigative measure per alarm response and/or other procedures. For example, the 1
interim measures, including operator training, similar to those implemented prior to installation of OPIS (e.g., operator rounds, monitoring bus voltages, etc.) would be implemented.
From a repair perspective, each station's Corrective Action Program would minimize the time that OPIS is non-functional. Failures are screened and assigned a significance level based on specific site criteria and procedures to ensure issues are resolved within days to weeks depending on the type of failure, plant risk and electric power system configuration requirements. Additionally, a non-functional relay would be identified as an "Unresolved Maintenance Issue" per North American Electric Reliability Corporation (NERC) Standard PRC-005-6, if applicable, that would require the site to take action to correct the issue further ensuring a timely repair. Operating experience from our industry members
- indicates that these relays are highly reliable.
These actions meet the OPC VII criteria since the OPIS failures described previously either do not affect offsite power availability or are bounded by the response of the existing protective relaying system to malfunctions. Per the VII, *OPIS is designed to minimize misoperation that could cause spurious separation from an operable off-site General Design Criteria (GDC) 17 source. An OPIS failure, which could cause spurious actuation, results in actions that are bounded by current design and licensing basis-e.g., LOOP. Also, interim measures are implemented until OPIS is restored.
(
An OPC, OPIS failure and a DBA are independent events arid the simultaneous occurrence of three independent events is not considered credible. Therefore, an OPIS failure does not affect the plant's ability to mitigate a DBA given-a single failure in the onsite power system, since OPIS failures either do not affect offsite power availability or are bounded by the response of the existing protective relaying system to malfunctions-spurious actuation. As such, OPIS is an enhancement to the electric power system design on the offsite power circuit and the single failure criterion, as defined in IEEE 279 and IEEE 603, is not applicable to OPIS since these systems do not scram or trip the reactor or actuate any engineered safety features ..
Table 1 in the NEI Regulatory Summary Document dated March 2016 (ML16091A100) identifies applicable failure scenarios including single failure criteria in the onsite power system. A summary for each scenario in the table is provided below:
- Scenario #1: An OPC occurs on an offsite power circuit and is isolated by the OPIS which is functional. Loads are transferred to a healthy source and the onsite power system remains operable.
- Scenario #2: A single train of the onsite power system is inoperable with the other remaining operable. OPI_S and the offsite power system are both functional.
- Scenario #3: OPIS is non-functional and unable to isolate an OPC - notification is provided in
- the MCR of the failure. The affected offsite power circuit is operable but temporary interim measures are implemented' until OPIS is restored. The onsite power system remains operable.
I 2
- Scenario #4: OPIS malfunctions and spuriously isolates one offsite power circuit. Loads are .
transferred to a healthy source and the onsite power system remains operable.
Additionally, the loss-of-single-phase event is not explicitly modeled in the current Probable Risk Analysis (PRA) model of record. Adding it to the PRA would be expected to have the effect described in.
the table below. The data table was 'developed by a study preformed from the Byron event. N9te that without any of the current tools for manual open phase detection and without operator awareness at Byron, the event lasted eight minutes but did not result in any equipment damage.
Table i: A Comparison of CDF Impact as a Function of OPC Configurations Condition Failures Modeled Increase in CDF c;
Pre-Event Operator action 3E-6 "'7.5%
Current Alarm or operator action . 6E-7 tvl.5%
Configuration Planned Automatic actuation and operator backup lE-8 "'0.03%
Configuration I 3 - Updates to the Updated Final Safety Analysis Report (UFSAR)
Questions:
What is NEI's expectations for updates to UFSAR with regard to the level of technical content detail and schedule for implementation? What is sufficient detail to reflect the licensing basis for protection against OPCs? Could you provide examples? *
Response
It is expected that licensees update their UFSAR by following NRC-endorsed guidance for adding new 2
informationto the UFSAR and complying with 10 CFR 50.71(e). Specifically, NEI 98-03 , "Guidelines for Updating Final Safety Analysis Reports," Revision 1, Section 6.2, "Level of Detail for FSAR Updates;"
states:
" ... The description shall be sufficient to permit understanding of the system designs and their relationship to safety evaluations." As described in 1980 FSAR update rule, "The level of detail to be maintained in the UFSAR should be at least the same as originally provided. Thus, existing UFSAR information of a similar nature may provide a guide for determining the level of detail for_ new information to be included in UFSAR Updates. However, the primary consideration in determining the level of detail for new information is whether updated _information is sufficient to permit understanding of new or modified safety analyses, design bases and facility operation."
A visual representation of the relationship of Design Bases and Supporting Design Information to the UFSAR and Licensing Basis was provided in industry slides at the 10/17/18 public meeting that depicted 2
NEI 98-03, "Guidelines for Updating Final Safety Analysis Reports," Revision 1 (ML15089A319); endorsed by Regulatory Guide 1.181, "CONTENT OF THE UPDATED FINAL SAFETY ANALYSIS REPORT IN ACCORDANCE WITH 10 CFR 50.71(e)"
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how the licensing basis is made up of a_ combination of sources including commitments and supporting design information such as design calculations and engineering change packages.
The schedule for updating the UFSAR is guided by 10 CFR S0.71(e)(4) which specifies, "Subsequent revisions must be filed annually or 6 months after each refueling outage provided the in~erval between. successive updates does not exceed 24 months. The revisions must reflect all changes up to a maximum of 6 months prior to the date of filling ... "
Also, per the VII, licensees are expected to perfc:>rm UFSAR updates in conjunction with their
- installation timelines and as required per the station's modification process. Further, NEI 98-03, Section 6.1/'What the Regulations Require," states, "Per 10 CFR 50.71(e)(4), the UFSAR is required to reflect changes up to a maximum of six months prior to the date that the last update was submitted to the NRC."
Therefore, unless otherwise approved by the NRC, a revision to a UFSAR shall be submitted within six months after each refueling outage provided the interval between successive updates does not exceed 24 months from the date of the previous submittal. This schedule works well for single-unit sites on a 24-month refueling interval. However, for dual-unit sites on a 24-month refueling interval, in which there would be a refueling outage each year, licensees may request an exemption to avoid submitting updates an annual basis; i.e., six months after each refueling outage. Some licensees have obtained exemptions for their operating units, and esti;lblished a 24-month update frequency based on a lead unit. Single-unit plants that utilize an 18-month refueling interval are required by regulation to submit their updates six months after their outages unless otherwise exempted.
4 - Surveillance & LC~ Requirements:
Questions:
What types of periodic tests, calibrations, setpoint ve.rifications or inspections are anticipated to be established, consistent with the VII? What are NEI's expectations for having licensee's update their TSs in order to meet the VII criteria? Could you provide examples?
Response
Consistent with the VII, it is anticipated that stations will review Maintenance Rule & NERC applicability
- and the associated maintenance requirements and frequencies for their individual OPIS design solutions. For example, at Byron Station, the SEL-451 relays have been classified as monitored microprocessor protective relays that, according to NERC PRC-005-02 criteria, have a maximum maintenance interval of 12 years. If a station's review determines their OPIS solutions are not within NERC scope, maintenance activities will be developed utilizing vendor guidance and preventative maintenance practices (PMs) currently utilized for similar plant equipment. For example, PSStech recommends that the Active Neutral Injection System be tested on an annual basis utilizing the Active Test Function. PMs would then be created to ensure this maintenance is performed as described on an annual basis within the controlled PM program.
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To address the potential need for changes to station Technical Specifications, NEI OPC Working Group requested that the Technical Specification Task Force (TSTF) eval~ate whether the planned OPC detection and mitigation equipment satisfied any of the regulatory criteria for inclusion in the Technical Specifications (TS). The TSTF developed a position paper that was reviewed and commented on by- the Pressurized Water Reactor Owner's Group (PWROG) and Boiling Water Reactor Owner's Group (BWROG) Licensing Committees, the AP1000 Owner's Group (APOG), and the NEI OPC Working Group.
The position paper was published on October 8, 2015, and distributed to the Owners Group members and NEI and provides the basis for evaluations by utilities on whether TS changes are needed when 3
installing OPC equipment. Additionally, the evaluation was also recently provided to the NRC.
The evaluation concluded that the regulations and regulatory guidance do not require additional TS requirements on the OPC detection and mitigation equipment unless the OPC equipment interfaces directly with the engineered safety features actuation logic, bypassing the existing undervoltage
- function. The offsite AC power sources meet Criterion 3 in 10 CFR 50.36(c)(2)(ii) and require a specific limiting condition for operation (LCO) per the regulations. LCO 3.8.1, "AC Sources - Operating," and LCO 3.8.2, ."AC Sources~ Shutdown," are the only LCOs which discuss offsite power and require one (LCO 3.8.2) or two (LCO 3.8.1) qualified circuits between the offsite transmission network and the onsite electrical power distribution system to be operable. The OPC equipment functions as a support system to the offsite power sources, similar to other support systems not addressed in the TS. There are many non-TS support systems that support TS functions, such as room and pump coolers, overcurrent protection, transformer protective functions, barriers, doors and circulating water screens, among others.
Surveillance Requirement 3.8.1.1 requires verification of correct breaker alignment and indicated power availability for each offsite circuit. An ope is created when there is not proper circuit continuity or breaker alignment for one or more phases of an offsite source. Therefore, the OPC function is verified by the existing Surveillance Requirement 3.8.1.1.
3 ADAMS accession number ML18262A377, "Evaluatio.n of Inclusion of Open Phase Condition Equipment Requirements in the Technical Specifications" 5