ML24249A199

Summary of the NEI 99-02 Rev. 8 and IE01 Whitepaper Public Meeting Held on August 28, 2024

ML24249A199
Person / Time
Issue date:	09/19/2024
From:	Ronald Cureton NRC/NRR/DRO/IRAB
To:	David Aird Office of Nuclear Reactor Regulation
References
Download: ML24249A199 (1)

Text

MEMORANDUM TO:

David M. Aird, Chief Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM:

Ron Cureton, Reactor Operations Engineer Reactor Assessment Branch Division of Reactor Oversight Office of Nuclear Reactor Regulation

SUMMARY

OF THE NEI 99-02 REV. 8 AND IE01 WHITEPAPER PUBLIC MEETING HELD ON AUGUST 28, 2024 On August 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff hosted a public meeting with the Nuclear Energy Institute (NEI), other senior industry executives, and various external stakeholders to discuss proposed changes contained in draft Revision 8 to NEI 99-02, Regulatory Assessment Performance Indicator Guideline, and a supporting whitepaper, NEI Reactor Oversight Process Task Force Whitepaper - Clarifications to the Unplanned Scrams per 7000 Critical Hours Performance Indicator. The topics discussed during this meeting are described below.

IE01 Whitepaper The NRC staff provided the NRC position on the Unplanned Scrams Performance Indicator (IE01) whitepaper (ML24185A209) that the staff did not concur with the proposed additions to definitions of unplanned scrams. The staff did not believe that the proposed changes were consistent with the definition of reactor scrams from SECY 99-007, Recommendations for Reactor Oversight Process Improvements. The NRC staff also did not concur with the addition of the example of a scram for turbine post-maintenance considerations as a scram that would not be counted toward the PI. The NRC staff did not believe that a reactor scram would be a certainty after major turbine maintenance but may be a high probability. Per SECY 99-007, a high probability scram would still meet the definition of a countable scram for the Performance Indicator (PI). The staff expressed concern that the additional text added to the definitions and examples could imply that early initiation of a manual scram prior to reaching an automatic scram setpoint would not result in the scram counting toward PI data.

CONTACT:

Ron Cureton, NRR/DRO (404) 997-5173 September 19, 2024 Signed by Cureton, Ronal on 09/19/24

D. Aird NEI clarified that white paper attempted to distinguish between use of manual scram for low-power shutdown versus meeting conditions requiring manual scram (e.g., during transients) and that initiation of a manual scram for transients prior to reaching required criteria was not intended to be excluded from PI counting.

NEI and NRC agreed to revisit the clarifications provided in the white paper after NEI 99-02 Revision 8 issuance, and Revision 8 will be issued unchanged from Revision 7 in these areas.

NEI 99-02 Revision 8 NRC staff presented open comments on NEI 99-02 Revision 8 (ML23290A125 &

ML23290A147) for discussion:

Unplanned downpowers PI - NEI presented examples related to proposed clarifying language for unplanned downpowers.

Unplanned Scrams with Complications (USwC) PI - NEI clarified that the proposed language is more technically accurate than the Frequently Asked Question (FAQ) 18-01 approved response.

USwC Main Feedwater - NEI provided background discussion and clarified that while no formal FAQ required the proposed changes, previous FAQ resolutions drove this change to clarify NEI 99-02.

Occupational Radiation Safety - NEI agreed with adding the text recommended by NRC staff to NEI 99-02 Revision 8.

Occupational Radiation Safety - NEI agreed to use language from IMC 0308 for the definition of the occupational radiation safety cornerstone.

Emergency Preparedness - NEI will update the section and has proposed revisions.

NSIR has not provided final agreement on the proposed revisions.

NEI agreed to provide clean and mark-up versions of NEI 99-02 Revision 8 which reflected the discussions above to NRC for review prior to the September 25 Reactor Oversight Process (ROP) working group meeting.

FAQ 24-01 NEI introduced an FAQ (ML24226B216) for review and more detailed discussion at a subsequent public meeting. The FAQ focuses on the question of if receipt of a safety injection signal alone without an associated safety injection counts toward PI considerations. NRC acknowledged receipt of the FAQ.

Conclusion At the end of the meeting, NRC and industry management gave closing remarks. The industry representatives expressed appreciation for the open dialogue and time spent by NRC staff to

D. Aird review the NEI 99-02 revision. The NRC management shared appreciation for the open and constructive dialogue during the meeting.

The following link contains the meeting agenda and other information: ML24228A183 The enclosure provides the attendance list for this meeting.

Enclosure:

As stated

ML24249A199 OFFICE NRR/DRO/IRAB NRR/DRO/IRAB/BC NRR/DRO/IRAB NAME RCureton DAird RCureton DATE 9/9/2024 9/10/2024 9/19/2024

Enclosure LIST OF ATTENDEES NEI 99-02 REV. 8 AND IE01 WHITEPAPER PUBLIC MEETING August 28, 2024 - 1:00 PM to 2:30 PM Name Organization1 Name Organization Tim Riti NEI David Aird NRC Tony Brown NEI Russell Felts NRC Amy Chamberlain Southern Nuclear Phil McKenna NRC Jack Hicks Luminant Dan Geary NRC Nicole Good STARS Alliance Alex Garmoe NRC John Giddens Entergy Ronald Cureton NRC Larry Nicholson Certrec Daniel Merzke NRC Marty Murphy Curtiss-Wright Charles Murray NRC Enrique Meléndez-Asensio CSN David Garmon NRC William Garrett Southern Nuclear Caty Nolan NRC Roy Linthicum Constellation Rich Smith NRC Brett Titus NEI Denny Smith NextEra Carrie Seipp Xcel Energy Tony Zimmerman Duke Energy Brian Stander Nebraska Public Power District Timothy Hammons South Texas Project Richard Mothena APS Michael Wetteland South Texas Project David Young NEI Christian Williams Constellation Robert Rishel Duke Energy Stephenie Pyle Entergy Fred Madden Certrec Matthew Hoholek AEP Anntwinette Ragland Southern Nuclear Russell Thompson TVA Shawn Wagner Unidentified Andrew Radosevic Unidentified Helen Levendosky Unidentified James Pak Unidentified Jana Bergman Unidentified Isaac Mulhern Unidentified Michael Williams Unidentified Joshua Haggard Unidentified Adam Abrams Unidentified John Egdorf Unidentified Steven Kadatz Unidentified Phil Lashley Unidentified Karle Cooper Unidentified Matthew Heckard Unidentified Michael Scarpello Unidentified Anthony Daniels Unidentified Amanda Britton Unidentified Marcus Hofmann Unidentified Cynthia Cashwell Unidentified 1 Unidentified organization indicates that the participants affiliation was not provided by the issuance of this meeting summary.