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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
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JAMES E. SLIDER Technical Advisor, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8015 jes@nei.org nei.org March 18, 2021 Mr. David C. Cullison Office of the Chief Information Officer Mail Stop: T-6 A10M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Information Collection: Voluntary Reporting of Performance Indicators [Docket NRC-2020-0185]
Project Number: 689
Dear Mr. Cullison:
By Federal Register announcement (86 FR 1544), dated January 8, 2021, the U. S. Nuclear Regulatory Commission (NRC) staff published a request for information regarding renewal of the Office of Management and Budget clearance for collection of information associated with the Voluntary Reporting of Performance Indicators. The Nuclear Energy Institute (NEI) 1 appreciates this opportunity to submit comments on behalf of NEI members.
Based on our survey of NEI members 2, it appears that the NRC is underestimating the true burden of performance indicator information collection. In the attachment, we explain that licensees must perform a host of activities beyond submitting the finished data to the NRC. These supporting activities apparently are not included in the NRCs estimate for submitting the data.
We welcome the opportunity to discuss this further with the NRC. We would suggest utilizing a future meeting of the ROP Working Group 3 for that purpose.
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.
2 Survey conducted by Justin Wearne, PSEG loanee to NEI, between January 8 and March 1, 2021.
3 The ROP Working Group, comprised of members of the NRC staff from the Office of Nuclear Reactor Regulation and NEIs Reactor Oversight Process Task Force, meets approximately monthly to discuss current issues and questions arising from implementation of the ROP.
Mr. David C. Cullison March 18, 2021 Page 2 If you have any questions in this matter, please contact me.
Sincerely, James E. Slider
Attachment - NEI Comments on Performance Indicator Data Collection Introduction In the January 8, 2021, Federal Register Notice (86 FR 1544), the NRC staff requested feedback on the following four questions related to the burden of collecting performance indicator information and submitting it to the NRC. The performance indicator information is associated with the NRCs Reactor Oversight Process (ROP). The ROP is the NRC program comprised of performance indicators and NRC inspections which guides the application of NRC resources overseeing U.S. nuclear power reactors. The performance indicator data is submitted to the NRC by U.S. power reactor licensees in accordance with an NEI guidance document, NEI 99-02, Regulatory Assessment Performance Indicator Guideline. The NEI responses to the four questions presented in the FRN follow.
- 1. Is the proposed collection of information necessary for the NRC to properly perform its functions? Does the information have practical utility?
NEI Response: Yes, in our view the proposed collection of information is necessary for the NRC to perform its function as an independent regulator of U.S. nuclear power reactors using the Reactor Oversight Process. Yes, in our view the information has practical utility as an indispensable input to the Reactor Oversight Process.
- 2. Is the estimate of the burden of the information collection accurate?
NEI Response: No. The estimates of burden presented in the FRN appear not to consider the numerous tasks that support the performance indicator program but are not explicitly described in NEI 99-02. Examples of these supporting tasks include the following:
a) Redefining Trains: Redefining trains 4 in the Institute of Nuclear Power Operations (INPO) Industry Reporting and Information System (IRIS) 5 system to support Unavailability Index (UAI) &
Unreliability Index (URI) calculations for submittal to the NRC for the Mitigating System Performance Index (MSPI) performance indicator.
This infrequent activity is generally performed after the plant has completed a modification to improve MSPI margin and baseline core damage frequency (CDF) by installing an additional train.
This needs to be done following installation in the plant and the quarter before the new probabilistic risk assessment (PRA) values are to be used in the MSPI calculation. This laborious exercise requires an individual fluent in IRIS as well as the cognizant engineer fully engaged for several days. This will also result in a change to the PRA values in IRIS. Revising those values is a demanding, non-routine task that requires diligence and attention to detail (i.e., time).
b) Changes to the Security PI: Changes to the closed-circuit television (CCTV) and intrusion detection system (IDS) normalization factors must be made in accordance with a similar, though somewhat less laborious and challenging process. This is not a routine activity.
c) Reportability Evaluations: Several times a year, a station will need to determine if an event or condition is reportable under an NEI 99-02 performance indicator. While these internal evaluations are most often associated with MSPI, several other indicators frequently reach this threshold, as well. Examples include the performance indicators for Unplanned Scrams per 7,000 Critical Hours (identified in NEI 99-02 as IE01); Unplanned Power Changes per 7,000 Critical Hours (IE03); and 4
As used in NEI 99-02, a train is a group of components that together provide the monitored (i.e., relevant) functions of the system that is the subject of the performance indicator.
5 The Industry Reporting and Information System is the data system through which nuclear power plant licensees manually submit raw data that is compiled and checked by INPO and prepared in the format required for submission to the NRC. After the licensee data file is processed by IRIS, the licensee formally submits the data file to the NRC.
1
Attachment - NEI Comments on Performance Indicator Data Collection Unplanned Scrams with Complications (IE04). These internal evaluations may require research into the history of previous discussions with the NRC on related Frequently Asked Questions (FAQs) 6, management presentations, use of consultants, and industry peer reviews.
These could be needed up to a dozen times per station per year. Developing each position paper could take up to twenty hours. Industry experts could be engaged as well. This is generally followed by station, fleet and industry peer reviews and challenge meetings, each taking an hour with up to six reviewers at each challenge meeting.
d) Quarterly Submittals: Performance indicator data is submitted to the NRC on a quarterly basis.
The quarterly submittal requires raw data entry, independent review and approval of the entered data, data locking, and tracking the status of reports. For the current NRC request on the burden of the information collection, NEI surveyed members on the burden associated with this step and found there was a great variance in the burden experienced by NEI members. As best we can tell, the NRC estimate of 72,712 hours0.00824 days <br />0.198 hours <br />0.00118 weeks <br />2.70916e-4 months <br /> of industry burden noted in 86 FRN 2144 appears to reflect only the burden of the quarterly submittals to NRC.
e) PI Challenge Meetings: Because the performance indicator data is subject to NRC requirements for accuracy and completeness (10 CFR 50.9), most stations conduct a performance indicator challenge meeting. These meetings typically involve the participation of multiple Data Stewards, their managers, and the site leadership team. Preparation for these meetings can take several hours to develop the necessary presentation packages and assure the quality of the planned submittal.
f) Data Steward Training: Data Stewards are the individuals assigned responsibility for collecting the plant raw data needed for NEI 99-02 reporting. These individuals need training on NEI 99-02, approved FAQs, and the station process for collecting information and submitting it to the INPO IRIS system. Accuracy of information being submitted is a key part of this training. This training varies and can be as low as a few hours, or up to several days. Because of high turnover in the Data Steward positions in recent years, most stations are spending more resources in Data Steward training than when the NRC last updated its estimate of the information collection burden.
g) FAQ Submittals: In recent years, the number of FAQs submitted by licensees has been small.
Hence, for most licensees submitting an FAQ is an infrequent occurrence. When an FAQ submittal is being considered, the licensee will perform research similar to that described above for Reportability Evaluations. The review and challenge of a FAQ is similar to the Reportability Evaluations listed above. Therefore, the level of effort for an FAQ submittal is also similar to that described above. In addition to the burden that falls on the licensee submitting an FAQ, each FAQ creates a burden on the industrys other licensees who participate in the NEI Reactor Oversight Process Task Force. The ROP Task Force serves as the industrys authority for final review and approval of FAQs submitted to the NRC. The industry representatives who comprise the ROP Task Force typically spend about two days each month reviewing and commenting on materials pertaining to FAQs and monthly interactions with the NRC staff on changes in and issues arising from the ROP.
6 NEI 99-02 prescribes a Frequently Asked Questions or FAQ process through which industry and the NRC document, discuss, and resolve questions about interpretation of guidance in NEI 99-02. The result is preserved as so-called approved FAQs which are considered supplements to NEI 99-02 until they are incorporated into NEI 99-02 at the next periodic revision of the document. The entire body of approved FAQs is maintained in a permanent record of archived FAQs that is a valuable resource for determining the basis for the contents of NEI 99-02 and changes in the contents from its inception in the year 2000.
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Attachment - NEI Comments on Performance Indicator Data Collection h) Approved FAQs: As the performance indicator guidance document evolves through NRC-approved FAQs and revisions to NEI 99-02, licensees need to review those changes and ensure internal procedures are aligned and adequately communicated to internal stakeholders.
- 3. Is there a way to enhance the quality, utility, and clarity of the information to be collected?
NEI Response: There is no need as the NRC-endorsed industry guidance document, NEI 99-02, adequately describes the information to be collected and provides a remedy if additional clarity is needed.
- 4. How can the burden of the information collection on respondents be minimized, including the use of automated collection techniques or other forms of information technology?
NEI Response: NEI encourages the MAP-X team of the NRCs Embark Venture Studio to include NEI 99-02 reporting in the scope of their efforts to develop web-based solutions to streamline industry reporting and to support the NRCs vision of big data being available. Of course, any such developments would have to be coordinated with industry and INPO.
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