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| How would NRC treat Unplanned Scrams per 7,000 Critical Hours and Unplanned Power Changes per 7,000 Critical Hours for a unit in this situation? | | How would NRC treat Unplanned Scrams per 7,000 Critical Hours and Unplanned Power Changes per 7,000 Critical Hours for a unit in this situation? |
| On page 12, the NRC states, "To establish the necessary baseline of critical hours to prevent falsely inflating the data , these indicators will become valid after four full calendar quarters have passed once critical hours have occurred." | | On page 12, the NRC states, "To establish the necessary baseline of critical hours to prevent falsely inflating the data , these indicators will become valid after four full calendar quarters have passed once critical hours have occurred." |
| [emphasis added.
| | [emphasis added. |
| ] We suggest replacing the word "data" with the word "indicator value". 8. Figure 1, page 16 Note 2 says, "Significance determination for findings associated with operational program development inspections and ITAAC subject to a hearing in accordance with IMC 2519." | | ] We suggest replacing the word "data" with the word "indicator value". 8. Figure 1, page 16 Note 2 says, "Significance determination for findings associated with operational program development inspections and ITAAC subject to a hearing in accordance with IMC 2519." |
| IMC 2519, "Construction Significance Determination Process", does not mention the word "hearing". Please explain what hearing is referred to in Note 2 or revise Note 2 to clarify that hearing is being referred to. | | IMC 2519, "Construction Significance Determination Process", does not mention the word "hearing". Please explain what hearing is referred to in Note 2 or revise Note 2 to clarify that hearing is being referred to. |
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Category:Graphics incl Charts and Tables
MONTHYEARML24023A0392024-01-22022 January 2024 NEI Comments on the Information Collection Renewal for Domestic Licensing of Special Nuclear Material, Docket Id NRC-2023-0118 ML21130A5982021-05-0707 May 2021 NEI Responses to NRC Staff Comments on NEI 20-07 Draft B ML21175A0362021-04-21021 April 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security Email from D. Young, NEI to N. Valliere, D Andrukat, S. Helton, P. Lee, NRC Summary Table Showing Key Attributes for Eligibility Criteria ML21097A2452021-04-13013 April 2021 Nrc/Nei Workshop Master Slides April 13, 2021 ML21013A5522021-01-13013 January 2021 ROP Task Force FAQ Log - January 2021 ML20205L3952020-07-28028 July 2020 July 28, 2020, NEI Presentation on Risk Tool on Spent Fuel Dry Storage ML20205L3962020-07-28028 July 2020 July 28, 2020, NEI Presentation on Industry Understanding of Proposal on Shielding ML20038A1952020-02-0606 February 2020 NEI Dic Comments on BTP 7-19 Revision 8 to Support Feb 11 2020 Public Meeting ML20037B0892020-02-0404 February 2020 FAQ Log January 2020 ML19226A3342019-08-14014 August 2019 (NEI) - Comments on Draft Interim Staff Guidance on the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept ML19176A5342018-06-12012 June 2018 Appendix to IMC 2600 - New Core to IMC 2600 NRC Core Inspection Requirements Tables 1 and 2 ML18163A3502018-06-0606 June 2018 ISG-06 NRC Tabletop Prep Agenda 2018-06-13/14 ML18053A0052018-02-20020 February 2018 3 Chart of RISC Milestones ML18018A8652018-01-0909 January 2018 01-09-17 - NRC NEI Supplementary Response to NRC RAIs on EPRI Report 10229... (2) ML17304B3082017-10-27027 October 2017 10-27-17 - NEI Industry Comments on the Information Collection for Domestic Licensing of Special Nuclear Material + Attachment ML17121A4302017-05-0101 May 2017 Industry Comments on the Draft Implementation Plan ML17229B5602017-01-27027 January 2017 New Plant Licensing Lessons Learned and Recommended Actions ML16061A1712016-02-22022 February 2016 02-22-16 - NRC - Industry Comments on DG-1324 (Docket Id NRC-2015-0278) - Attachment RIS 2011-12, Response to Public Comments on Docket Id NRC-2011-0013-NRC Regulatory Issue Summary 2011-12, Revision 1, Adequacy of Station Electric Distribution System Voltages2011-12-29029 December 2011, 28 February 2012 Response to Public Comments on Docket Id NRC-2011-0013-NRC Regulatory Issue Summary 2011-12, Revision 1, Adequacy of Station Electric Distribution System Voltages, Rev. 1 - Adequacy of Station Electric Distribution System Voltages (Track Changes), NRC Concerns Associated with NRC Release of RIS 2011-12, Revision 1, Attachment ML0726306712007-09-20020 September 2007 9/24/2007 Public Meeting Handout: Draft Interim Staff Guidance for Digital I&C Licensing Process Task Working Group ML0513900842005-06-15015 June 2005 Enclosure - Emergency Planning - Inspections, Tests, Analyses, & Acceptance Criteria (EP ITAAC) Combined License (COL) Application - Subpart C to 10 CFR Part 52 ML0509701402005-04-0404 April 2005 Attachment 5 - April 4, 2005, E-Mail from NEI on Draft Operation Program Implementation Matrix 2024-01-22
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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
[Table view] |
Text
Attachment 1 Comments on Draft Implementation Plan to Ensure NRC Staff Readiness for AP1000 Operations, Revision 0 No. Section, Page, Text Comment 1. III.E, page 9 (see also III.F)
This section states:
"If there is a greater
-than-green finding identified before the 10 CFR 52.103(g) finding, the staff is required to conduct the required supplemental inspection specified in the cROP Action Matrix. If the supplemental inspection is successfully completed prior to the 10 CFR 52.103(g) finding, the staff will close the greater-than-green finding, and the finding will also be considered closed for future assessment purposes under the ROP Action Matrix. However, if the required supplemental inspection is not completed before the 10 CFR 52.103(g) finding, the greater
-than-green finding will remain open and will be assigned to the ROP cornerstone that is most closely related to the finding and the finding will be considered as an input to the ROP Action Matrix upon initial implementation of the ROP.
" While we would not want to see the 103(g) finding delayed to resolve a construction greater
-than-green finding, the NRC's proposal seems contradictory. The 103(g) finding means that the commission has conclude d that the ITAAC have been completed, the plant is completed in accordance with design, and is ready for fuel load.
How, then, would a construction inspection finding apply to evaluating performance of the operating plant?
In addition, it is not clear how the NRC would judge the resolution of a greater-than-green construction
-related finding held open past the 103(g) finding. The significance of the construction
-related finding would be evaluated using the construction SDP (IMC 2519). The NRC proposes to map the open finding to a corresponding cornerstone of the ROP, where the basis for significance determination (IMC 0609) is completely different.
Adding to this complexity, different inspection procedures would apply (IP 9500X vice IP 9000X) to the supplemental inspection needed to resolve the greater
-than-green finding. We would suggest that the NRC choose a different path for closing a greater
-than-green construction finding that remains open at the time of the 103(g) finding. We suggest the following: (a) treat the construction
-related finding outside of the operational ROP; (b) conduct the supplemental inspection using the applicable construction inspection procedure; (c) close the construction
-related finding in accordance with the criteria of the construction inspection procedure. If NRC remains on its proposed path of rolling over construction
-related findings past Attachment 2 No. Section, Page, Text Comment the 103(g) finding and re
-mapping them to the operational ROP, the NRC should invoke the Action Matrix deviation process to recognize that construction
-related findings are not additive to operations-related findings.
- 2. III.F, page 9 As in the comment above, the NRC states
- "If the supplemental inspection is successfully completed prior to the 10 CFR 52.103(g) finding, the staff will close the greater
-than-green finding, and the finding will also be considered closed for future assessment purposes under the ROP Action Matrix. However, if the required supplemental inspection is not completed before the 10 CFR 52.103(g) finding, the greater
-than-green finding will remain open and will be assigned to the ROP cornerstone that is most closely related to the finding and the finding will be considered as an input to the ROP Action Matrix upon initial implementation of the ROP.
" The industry comment on section III.E applies to section III.F as well. 3. III.G, page 9, fourth sentence This section makes the following statement:
"Inspections of the development of operational programs after the 10 CFR 52.103(g) finding will be conducted using applicable inspection procedures specified by IMC 2504.
" [emphasis added] It is unclear what inspections are referred to, as IMC 2504, states: "To specify the inspection policies for reviewing, prior to the Commission's 10 CFR 52.103(g) finding, the operational programs described in the FSAR, for a plant licensed in accordance with 10 CFR Part 52.
" [emphasis added] And "The purpose of these inspections is determine the status of the operational programs prior to the Commission's 10 CFR 52.103(g) finding and to determine the adequacy of the preoperational testing portion of the initial test program conducted by the licensee." [emphasis added] 4. III.G, page 9, last two sentences This section states:
"The significance of operational program development findings identified after the 10 CFR 52.103(g) finding will be determined using the guidance in IMC 2519. The operational program development findings identified after the 10 CFR 52.103(g) finding will be assigned to the ROP cornerstone most closely related to the finding, and significance of the finding will be Attachment 3 No. Section, Page, Text Comment considered for determining the appropriate ROP Action Matrix column in accordance with IMC 0305."
As noted in the previous comments on Section III.F, resolving a greater-than-green finding that was evaluated using the construction SDP (IMC 2519) and was re
-mapped into the operational ROP, where a different SDP (IMC 0609) is applicable, is problematic
. 5. III.L, page 10 III.M, page 10 As noted in previous comments, resolving a greater
-than-green finding that was evaluated using the construction SDP (IMC 2519) and has been re
-mapped into the ROP where a different SDP (IMC 0609) applies, is problematic
. 6. III.O, page 11 and Table 1, page E1-2, entry for MSPI This paragraph does not reflect previous discussions on applicability of MSPI to AP1000 that occurred at several ROP public meetings in 2015
-2016. From those ROP public meetings, we understood that the staff had concluded that further pursuit of PI modifications for the AP1000, particularly an MSPI modification, would not likely bear fruit. Therefore, the staff concluded that it should pursue inspection modifications to cover the areas in which performance indicators would not be practical.
- 7. III.P, pages 11
-12 This section proposes to treat certain performance indicators as invalid until "-sufficient time has passed to accumulate enough representative data to provide a valid assessment result."
What would happen if a unit has not reached 7,000 critical hours in the first four calendar quarters (first year) after initial criticality?
How would NRC treat Unplanned Scrams per 7,000 Critical Hours and Unplanned Power Changes per 7,000 Critical Hours for a unit in this situation?
On page 12, the NRC states, "To establish the necessary baseline of critical hours to prevent falsely inflating the data , these indicators will become valid after four full calendar quarters have passed once critical hours have occurred."
[emphasis added.
] We suggest replacing the word "data" with the word "indicator value". 8. Figure 1, page 16 Note 2 says, "Significance determination for findings associated with operational program development inspections and ITAAC subject to a hearing in accordance with IMC 2519."
IMC 2519, "Construction Significance Determination Process", does not mention the word "hearing". Please explain what hearing is referred to in Note 2 or revise Note 2 to clarify that hearing is being referred to.
Interestingly, Figure 1 does not depict what Section III labors to Attachment 4 No. Section, Page, Text Comment describe, i.e., the closure of greater
-than-green construction findings that may not be closed prior to the 103(g) finding.
- 9. Table 1, page E1
-2, entry for Safety System Functional Failures The entry under "When PI becomes Valid" states, "This PI becomes valid when the mitigating systems cornerstone becomes valid."
The entry under "Comments" states, "-the PI should become valid the first quarter in which 10 CFR 50.73, 'Licensee event report system,' becomes applicable after the MS cornerstone has been transitioned to the ROP."
If the above entries are equivalent, why are they written differently? If the above entries are not equivalent, why is conflicting direction presented in this table?
- 10. Enclosure 2 Several items in this table state "None specified" under Implementation Milestone when there is a milestone.
For example the milestone for Item 5, Reactor Vessel Material Surveillance Program is "before initial criticality" (VCS COL).