ML20255A302

From kanterella
Jump to navigation Jump to search
Comment (2) of Timothy Riti on Behalf of Nuclear Energy Institute (NEI) on Licensee Actions to Address Non-conservative Technical Specifications
ML20255A302
Person / Time
Site: Nuclear Energy Institute
Issue date: 09/10/2020
From: Riti T
Nuclear Energy Institute
To:
Office of Administration
References
85FR52643 00002, DG-1351, NRC-2018-0137
Download: ML20255A302 (3)


Text

Page 1 of 1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Meraj Rahimi, Mary Neely As of: 9/11/20 8:47 AM Comment (2) Received: September 10, 2020 Publication Date: Status: Pending_Post PUBLIC SUBMISSION 8/26/2020 CITATION 85 FR 52643 Tracking No. kex-8dsg-gi7k Comments Due: September 25, 2020 Submission Type: Web Docket: NRC-2018-0137 Dispositioning of Technical Specifications that are Insufficient to Ensure Plant Safety Comment On: NRC-2018-0137-0007 Licensee Actions To Address Nonconservative Technical Specifications Document: NRC-2018-0137-DRAFT-0007 Comment on FR Doc # 2020-18797 Submitter Information Name: Timothy Riti Address:

Washington, DC, 20004 Email: txr@nei.org General Comment See attached file(s)

Attachments NEI Letter for Comments on DG 1351 https://www.fdms.gov/fdms/getcontent?objectId=0900006484850aa7&format=xml&showorig=false 09/11/2020

TIMOTHY RITI Senior Project Manager, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8132 txr@nei.org nei.org September 10, 2020 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff Project Number: 689

Subject:

NEI Comments on Draft Regulatory Guide, DG-1351 Revision 1; Licensee Actions to Address Nonconservative Technical Specifications. Docket ID NRC-2018-0137.

Subm itted via regulations.gov

Dear Program Management,

Announcements and Editing Staff, The Nuclear Energy Institute (NEI) 1, on behalf of our members, appreciates the opportunity to provide comments on the subject Draft Regulatory Guide, DG-1351 Revision 1; Licensee Actions to Address Nonconservative Technical Specifications. This proposed regulatory guide describes a method acceptable to the U.S. Nuclear Regulatory Commission (NRC) staff for licensee actions to address nonconservative technical specifications (TS). This RG endorses NEI 15-03, Revision 3, Licensee Actions to Address Nonconservative Technical Specifications.

On April 9, 2020, NEI submitted NEI 15-03, Revision 3, "Licensee Actions to Address Nonconservative Technical Specifications" for NRC review and endorsement. Revision 3 contains changes from discussions that occurred at a public meeting held on Oct 17, 2019 (ML19268A117) to address exceptions from revision 2 contained in Draft Regulatory Guide (DG-1351), Dispositioning of Technical Specifications that are Insufficient to Ensure Plant Safety (ML19268B567). As a result, DG-1351 Revision 1; Licensee Actions to Address Nonconservative Technical Specifications was developed endorsing NEI 15-03, Revision 3 with no exceptions or clarifications. We fully support DG-1351 Revision 1 and appreciate the staffs engagement as we worked to ensure clear guidance was developed to meet industry and NRC needs.

1 The Nuclear Energy Institute (NEI) 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. NEIs 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.

September 10, 2020 Page 2 Please contact me at txr@nei.org or (202) 739-8137 with any questions or comments about the content of this letter.

Sincerely, Timothy Riti c: Mr. Shawn Williams, NRR/DORL/LPL2-1, NRC