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NEI Presentation - ROP Public Meeting 09232021 (002)
	ML21266A065
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/23/2021
From:	; Nuclear Energy Institute
To:	; NRC/SECY
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Feedback on proposed ROP changes

September 23, 2021

SUMMARY

NEI understands the direction that NRC is headed with current strategy but we have questions on actions & engagement We agree that there are improvements that could be gained through incorporation of operating experience including more recent experience We agree that there are areas that were included in the SECYs that are no longer being recommended or were already completed

We appreciate the opportunity to provide any new insights and provide perspectives on relative importance

We do not see any new information that would change our position on the original recommendations We acknowledge that use of licensee self-assessments are no longer being pursued As a result of the NRC request during the last public meeting, NEI has identified an area that warrants additional consideration for the scope of the triennial fire protection inspection (TFPI)

The NEI fire protection task force will reach out to the applicable technical staff to discuss

NEI Fire Protection Task Force re-evaluated Fire Protection recommendations in SECY-18 -0113 and SECY -19 -0067 Attributes of the TFPI are redundant to attributes of other NRC inspections

IP 71111.05, Fire Protection

IP 71111.18, Plant Modifications

IP 71111.21M, Design Basis Assurance Inspection (Team)

Continuing to see low numbers of Fire Protection findings based on industry performance Ready to engage NRC staff with the following recommendation:

Reallocate unique TFPI inspection criteria to CETI and IP 71111.05, Fire Protection ©2021 Nuclear Energy Institute 4 SECY 0067

We do not see any new information that would change our position on the original recommendations We do have some questions on actions and engagement

September 23, 2021

NEI task force is developing guidance on how to apply reporting requirements for licensees with risk-informed licensing bases For example, 50.69(b)(1)(vii) and (viii) provide an explicit exemption to 10 CFR 50.72 and 50.73 respectively for RISC-3 and RISC-4 components 50.69(g) requires LER under 50.73(b) for any event or condition that prevented, or would have prevented, a RISC-1 or RISC-2 SSC from performing a safety significant function.

Other risk informed initiatives would also benefit from additional reporting guidance

Actions complete/in-progress Draft guidance developed Initial regulatory affairs review completed Industry operations tabletop performed Incorporate feedback from tabletop -in progress Next Steps NEI regulatory and legal review of updated draft guidance - Oct, 2021 NEI/NRC workshop - Late Fall We are interested in engaging the NRC staff for feedback

ML21266A065

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SUMMARY

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