ML22194A892
| ML22194A892 | |
| Person / Time | |
|---|---|
| Site: | 99902028, Nuclear Energy Institute |
| Issue date: | 07/13/2022 |
| From: | Tony Brown Nuclear Energy Institute |
| To: | Bo Pham Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML22194A891 | List: |
| References | |
| NEI 21-05 | |
| Download: ML22194A892 (2) | |
Text
TONY BROWN Technical Advisor, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8087 mab@nei.org nei.org July 13, 2022 Bo Pham Director, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11545 Rockville Pike Rockville, MD 20852-2746
Subject:
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 Project Number: 689
Dear Mr. Pham:
The Nuclear Energy Institute (NEI) 0F1, on behalf of its members, is submitting Draft NEI 21-05, "Reporting Guidance for Licensees with Risk-Informed Licensing Bases," for NRC review. NEI developed NEI 21-05 to provide guidance to licensees with risk-informed licensing bases for complying with the reporting requirements of 10 CFR 50.72, 10 CFR 50.73, and 10 CFR 21. NEI 21-05 achieves this goal by providing specific guidance for each risk-informed program that can be applied to NRC reporting requirements. The following risk-informed initiatives are addressed in this guidance:
10 CFR 50.69, "Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors" Risk-Managed Technical Specifications, also known as Risk Informed Completion Times (RICT) or TSTF-505 10 CFR 50.48(c), "National Fire Protection Association Standard NFPA 805" Technical Specification (TS) 3.0.4.b, "Performance of a Risk Assessment Addressing Inoperable Systems and Components" 1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.
Mr. Bo Pham July 13, 2022 Page 2 NEI 17-02, "Tornado Missile Risk Evaluator (TMRE) Industry Guidance Document" NEI 21-05 provides additional guidance that licensees may use in conjunction with existing guidance, including NUREG-1022, "Event Report Guidelines 10 CFR 50.72 and 50.73," Revision 3.
We request that the NRC review and conduct a meeting to discuss the draft technical report by September 14, 2022. The purpose of the meeting would be to solicit comments and observations from NRC staff on the content of the draft technical report and to respond to any questions from the staff. At this time, we do not plan to seek NRC endorsement, but would consider any feedback from the staff prior to finalizing the document and issuing it for use. NEI will submit a fee exemption request to support the NRCs review and meeting. In addition, we have submitted a request that Draft NEI 21-05 be withheld from public disclosure in its entirety, pursuant to 10 CFR 2.390.
If you have questions on this matter, please contact me (mab@nei.org).
Sincerely, Tony Brown
Enclosure:
NEI 21-05, Reporting Guidance for Licensees with Risk-Informed Licensing Bases, Draft cc:
Chris Miller, DRO, NRC Mike Franovich, DRA, NRC NRC Document Control Desk