ML23031A302
| ML23031A302 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 01/30/2023 |
| From: | Tony Brown Nuclear Energy Institute |
| To: | NRC/SECY |
| References | |
| NRC-2020-0036, PR-50 | |
| Download: ML23031A302 (1) | |
Text
1/31/23, 1:10 PM blob:https://www.fdms.gov/6e069701-54af-438a-96a5-60dcc99c4d1f blob:https://www.fdms.gov/6e069701-54af-438a-96a5-60dcc99c4d1f 1/1 PUBLIC SUBMISSION As of: 1/31/23, 1:10 PM Received: January 30, 2023 Status: Pending_Post Tracking No. ldj-2hdd-q86x Comments Due: January 31, 2023 Submission Type: Web Docket: NRC-2020-0036 Reporting Requirements for Non-Emergency Events Comment On: NRC-2020-0036-0008 Reporting Requirements for Nonemergency Events at Nuclear Power Plants Document: NRC-2020-0036-DRAFT-0015 Comment on FR Doc # 2022-27979 Submitter Information Email:atb@nei.org Organization:Nuclear Energy Institute General Comment See attached file(s)
Attachments 01-30-23_NRC_NEI Comments on Regulatory Basis_Reporting Requirements for Nonemergency Events
TONY BROWN Technical Advisor, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8087 mab@nei.org nei.org January 30, 2023 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff Submitted via Regulations.gov
Subject:
Industry Comments on the Regulatory Basis for Reporting Requirements for Nonemergency Events at Nuclear Power Plants (Docket ID: NRC-2020-0036)
Project Number: 689
Dear Rulemakings and Adjudications Staff:
The Nuclear Energy Institute (NEI),1 on behalf of its members, appreciates the opportunity to comment on the Nuclear Regulatory Commissions (NRC) regulatory basis for reporting requirements for nonemergency events at nuclear power plants (ML22108A004). In general, we support the NRC staffs regulatory basis, which in our view, considers the impact of nonemergency notifications on plant operators and would limit notifications to safety significant events. This would enhance the safety focus of NRCs reporting requirements, consistent with the NRCs Principles of Good Regulation.
In the development of the regulatory basis, the NRC staff placed a priority on retaining requirements that involve potentially significant events or conditions that would require staff evaluation for prompt response. The NRC staff has also addressed openness and transparency by identifying other regulations and processes that exist to ensure all of its stakeholders can maintain awareness and access details associated with conditions of interest.
That said, we encourage the NRC staff to reconsider the overall rulemaking schedule and identify efficiencies in the process that could be leveraged to accelerate the schedule. As noted in the regulatory basis and on the NRCs web page, the target completion date to publish the proposed rule and final rule are November 15, 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.
Rulemakings and Adjudications Staff January 30, 2022 Page 2 2024, and August 12, 2026, respectively. Considering the Petition for Rulemaking was submitted to the NRC on August 2, 2018 (ML18247A204), the current estimate would result in an eight-year schedule to address the petition and almost four years between publishing of the Regulatory Basis and the final rule. This timeline seems prolonged.
Finally, regarding the NRC staffs recommendation to update existing guidance for reporting degraded or unanalyzed conditions under 10 CFR 50.72(b)(3)(ii), we recommend the staff begin the process to revise NUREG-1022, Event Report Guidelines 10 CFR 50.72 and 50.73, as soon as practical. We agree that clarifications of the document would be beneficial and recommend they be made independent of the rulemaking process, allowing for earlier implementation.
We commend the NRC staffs efforts in publishing a thorough, well-prepared regulatory basis and are encouraged by the proposed changes that would enhance the safety focus of NRCs reporting requirements.
We request that the NRC staff pursue efficiencies in the rulemaking schedule and will do what we can to enable such an accelerated schedule.
If you have any questions or require additional information, please contact me at 202.739.8087 or mab@nei.org.
Sincerely, Tony Brown cc:
George Tartal, NMSS, NRC Brian Benney, NRR, NRC