ML20339A484

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Summary of Remaining October 2020 NRC Comments on NEI 20-09
ML20339A484
Person / Time
Site: Nuclear Energy Institute
Issue date: 11/23/2020
From:
Nuclear Energy Institute
To:
Office of Nuclear Reactor Regulation
Williams D
Shared Package
ML20339A483 List:
References
NEI 20-09
Download: ML20339A484 (2)


Text

Summary of Remaining October 2020 NRC Comments on NEI 20-09 Note: Comments not included in this table were fully addressed in the text of the document.

Page Comment/Text Discussion 4 NRC proposed added text: Each PRA at each This is more appropriate for the licensing stage of design, construction, or operation document.

that the user elects to have a peer review done is considered to be a different PRA and a distinct (i.e., separate) peer review.

5 NEI 17-07, Revision 2, includes discussion For ANLWRs, back referenced SRs are not and specific items related to cross- used in the same way. They will be limited reference from internal fire PRA SRs to so the language in NEI 17-07 is not internal events PRA SRs. Those items do appropriate.

not appear in NEI 20-09. Justification for their deletion is not apparent, especially because the discussion in NEI 17-07, Revision 2 is applicable for the ANLWR PRA Standard.

Suggest retaining the discussion from NEI 17-07, Revision 2, (with any changes to SRs cited therein) unless a straightforward justification can be provided for exclusion.

7 Section 3.3 from NEI 17-07 is missing from The way the ANLWR is structured, the full NEI 20-09. The underlying guidance remains section 3.3 is not needed. Will add a valid for ANLWRs. Suggest retaining Section sentence to 3.3 to note how referenced SRs 3.3 from NEI 17-07 unless a justification for are addressed but not the full section 3.3.

its exclusion can be provided.

9-10 Various added NRC text edited for clarity 10 If the host user cannot achieve confidence in Does not belong in a guidance document, the qualification of the peer reviewers for the this is outside the peer review process.

PRA scope determined by the user and/or peer review of newly developed method(s),

NRC review of the PRA scope and/or newly developed method(s) should be considered.

10 PRA standard (section 6.2.3) states a This is being removed. No change made.

minimum of 5 members 11 NRC added text: Section 6.2.3 of the This is being removed from the LWR ASME/ANS Advanced Non-LWR PRA standard and will likely be removed from Standard discusses the team size the ANLWR standard as well.

requirements.

11 Review team member qualifications Edited to address NRC comments 13 SQUG walkdown training should be retained NRC suggested deletion of this previously.

Either is acceptable to industry.

13 NRC added economic impact modeling Not being done in the USA, deleted 15 Various comments on Figure 1-1 Deleted Figure 1-1

24 Suggested language adds applicability from Deleted section RG 1.200 to ANLWRs. Further, it is suggested that this reference is revisited based on whether RG 1.200 is the appropriate reference or the anticipated DG for ANLWRs.