|
|
(2 intermediate revisions by the same user not shown) |
Line 5: |
Line 5: |
| | author name = Perkins S | | | author name = Perkins S |
| | author affiliation = Nuclear Energy Institute (NEI) | | | author affiliation = Nuclear Energy Institute (NEI) |
| | addressee name = Holahan P K | | | addressee name = Holahan P |
| | addressee affiliation = NRC/NMSS | | | addressee affiliation = NRC/NMSS |
| | docket = PROJ0689 | | | docket = PROJ0689 |
Line 15: |
Line 15: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:SUSAN H. PERKINS Senior Director, Nuclear Security & Incident Preparedness 1201 F Street | | {{#Wiki_filter:SUSAN H. PERKINS Senior Director, Nuclear Security & Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8016 shp@nei.org nei.org February 28, 2019 Ms. Patricia Holahan Director, Division of Rulemaking Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 |
| , NW, Suite 1100 Washington, DC 20004 P: 202.739.8016 shp@nei.org nei.org February 28, 2019 Ms. Patricia Holahan Director, Division of Rulemaking Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 | |
|
| |
|
| ==Subject:== | | ==Subject:== |
| Recommended Changes to NRC Regulatory Guides for the Final Mitigation of Beyond Design Basis Events Rule Project Number: 689 Dear Ms. Holahan | | Recommended Changes to NRC Regulatory Guides for the Final Mitigation of Beyond Design Basis Events Rule Project Number: 689 |
| : On January 24, 2019, the U.S. Nuclear Regulatory Commission (NRC) issued the Staff Requirements Memorandum (SRM) for SECY-16-0142 , "Draft Final Rule
| |
| - Mitigation of Beyond
| |
| -Design-Basis Events (RIN 3150-AJ49)." With this SRM, the Commission approved a final rule that amends Parts 50 and 52 of Title 10 of the Code of Federal Regulations (10 CFR) with certain changes provided in the memorandum enclosures
| |
| . The Commission also directed the staff to "make any necessary conforming changes in other rulemaking documents, including the 'NRC Response to Public Comments' and 'Regulatory Analysis,'
| |
| to reflect the changes identified in the FRN and in the Backfitting and Issue Finality Assessment." To assist the NRC staff with the identification of necessary conforming changes, the Nuclear Energy Institute (NEI)1 and its members have prepared a summary of recommended changes to Regulatory Guides 1.226, "Flexible Mitigation Strategies for Beyond-Design-Basis Events," and 1.228, "
| |
| Integrated Response Capabilities for Beyond
| |
| -Design-Basis Events."
| |
| 2 These changes, presented in the attachment to this letter, are intended to promote alignment between the NRC
| |
| -endorsed content of NEI guidance documents and the requirements in the final rule, as modified by the Commission.
| |
| Incorporation of these changes may also obviate the need to develop and submit revised NEI guidance documents, actions which would challenge timely rule issuance.
| |
| 1 NEI is the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy industry. 2 Or the regulatory guide that subsumes the content of Regulatory Guide 1.228.
| |
|
| |
|
| Ms. Patricia Holahan February 28, 2019 Page 2 In addition to the conforming changes identified in the attachment, we also suggest that Regulatory Guide 1.226 contain an endorsement of NEI 06-12, "B.5.b Phase 2 & 3 Submittal Guideline | | ==Dear Ms. Holahan:== |
| ," as an acceptable method to meet the requirements of 10 CFR 50.155(b)(2).3 This addition would address the relocation of the requirements in 10 CFR 50.54(hh)(2) to 10 CFR 50.155(b)(2) and reflect the following paragraph in the final rule statements of consideration: | | |
| "This rulemaking does not revise the regulatory treatment of equipment relied upon for the EDMG s now relocated to § 50.155(b)(2). The regulatory treatment of that equipment remains as it is described in NEI 06
| | On January 24, 2019, the U.S. Nuclear Regulatory Commission (NRC) issued the Staff Requirements Memorandum (SRM) for SECY-16-0142, Draft Final Rule Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49). With this SRM, the Commission approved a final rule that amends Parts 50 and 52 of Title 10 of the Code of Federal Regulations (10 CFR) with certain changes provided in the memorandum enclosures. The Commission also directed the staff to make any necessary conforming changes in other rulemaking documents, including the NRC Response to Public Comments and Regulatory Analysis, to reflect the changes identified in the FRN and in the Backfitting and Issue Finality Assessment. |
| -12, the endorsed guidance document for those strategies and guidelines. | | To assist the NRC staff with the identification of necessary conforming changes, the Nuclear Energy Institute (NEI)1 and its members have prepared a summary of recommended changes to Regulatory Guides 1.226, Flexible Mitigation Strategies for Beyond-Design-Basis Events, and 1.228, Integrated Response Capabilities for Beyond-Design-Basis Events. 2 These changes, presented in the attachment to this letter, are intended to promote alignment between the NRC-endorsed content of NEI guidance documents and the requirements in the final rule, as modified by the Commission. Incorporation of these changes may also obviate the need to develop and submit revised NEI guidance documents, actions which would challenge timely rule issuance. |
| " If you have questions or require additional information, please contact David Young at (202) 739
| | 1 NEI is the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy industry. |
| -8127 or dly@nei.org, or me. Sincerely, Susan H. Perkins Attachment c: Ms. Theresa Clark, NMSS/DRM, NRC Mr. Tim Reed, NRR/DORL/LSPP, NRC Mr. Brett Titus, NRR/DLP/PBMB , NRC 3 Or alternatively, add a statement referencing the December 22, 2006, NRC letter that endorsed NEI 06 | | 2 Or the regulatory guide that subsumes the content of Regulatory Guide 1.228. |
| -12; refer to ADAMS Accession No. ML063560235.}} | | |
| | Ms. Patricia Holahan February 28, 2019 Page 2 In addition to the conforming changes identified in the attachment, we also suggest that Regulatory Guide 1.226 contain an endorsement of NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, as an acceptable method to meet the requirements of 10 CFR 50.155(b)(2).3 This addition would address the relocation of the requirements in 10 CFR 50.54(hh)(2) to 10 CFR 50.155(b)(2) and reflect the following paragraph in the final rule statements of consideration: |
| | This rulemaking does not revise the regulatory treatment of equipment relied upon for the EDMGs now relocated to § 50.155(b)(2). The regulatory treatment of that equipment remains as it is described in NEI 06-12, the endorsed guidance document for those strategies and guidelines. |
| | If you have questions or require additional information, please contact David Young at (202) 739-8127 or dly@nei.org, or me. |
| | Sincerely, Susan H. Perkins Attachment c: Ms. Theresa Clark, NMSS/DRM, NRC Mr. Tim Reed, NRR/DORL/LSPP, NRC Mr. Brett Titus, NRR/DLP/PBMB, NRC 3 |
| | Or alternatively, add a statement referencing the December 22, 2006, NRC letter that endorsed NEI 06-12; refer to ADAMS Accession No. ML063560235.}} |
|
---|
Category:Letter
MONTHYEARML24204A2162024-07-22022 July 2024 Withdrawal of Fee Exemption Request for Endorsement of NEI White Paper, “Selection of a Seismic Scenario for an EPZ Boundary Determination” ML24204A2082024-07-22022 July 2024 07-22-24_NRC_NEI Withdrawal of Fee Exemption Request for Wp Selection of Seismic Scenario for EPZ Determination ML24187A0552024-07-0303 July 2024 Fee Exemption Request for NEI White Paper Selection of Seismic Scenario for EPZ Determination ML24173A2712024-06-14014 June 2024 NEI - Proposed Changes to Inspection Procedure (IP) 71130.10, Cybersecurity ML24165A0852024-06-13013 June 2024 NEI White Paper - Impact of Higher Source Term Fractions on EQ Doses ML24165A0862024-06-13013 June 2024 NEI White Paper - Proposed Control Room Dose Acceptance Criteria Supporting RG 1.183 R2 ML24165A0872024-06-12012 June 2024 NEI White Papers Supporting NRC Workshop Discussions Regarding Nuclear Regulatory Commissions (NRC) Potential Changes to Regulatory Guide 1.183 ML24152A3242024-05-31031 May 2024 NEI Concept Paper: Regulation of Rapid High-Volume Deployable Reactors in Remote Locations ML24159A7312024-05-23023 May 2024 05-23-24 Nuclear Energy Institute Letter to the U.S. Nuclear Regulatory Commission Re Industry Comments on Buildings as Items Relied on for Safety ML24135A1982024-04-23023 April 2024 SFAQ No 2022-02, SAE Program Requirements - NEI Withdrawal Letter ML24078A2212024-03-15015 March 2024 3-15-24 NEI Letter Aveil from Juhle on Pur ML24061A0572024-02-29029 February 2024 Endorsement of NEI 08-09, Revision 7, Changes to NEI 08-09 Cyber Security Plan for Nuclear Power Reactors ML24023A0392024-01-22022 January 2024 NEI Comments on the Information Collection Renewal for Domestic Licensing of Special Nuclear Material, Docket Id NRC-2023-0118 ML23355A1972023-12-14014 December 2023 NEI, Comments on NRC Draft Resolution of SFAQ 2022-02, SAE Program Requirements ML23219A1672023-10-25025 October 2023 Response Letter to Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07 ML23270B9002023-09-27027 September 2023 NEI Letter Request for an Extension of Comment Period on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses, Docket Id NRC 2023 0079 ML23268A0102023-09-22022 September 2023 NEI, Fee Exemption Request for Endorsement, Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors ML23241A8612023-08-25025 August 2023 Consolidated Industry Comments to NRC Regulatory Issue Summary 2023-02, Scheduling Information for the Licensing of Accident Tolerant, Increased Enrichment, and Higher Burnup Fuels ML23236A4992023-08-24024 August 2023 Industry Feedback on Region II Fuel Cycle Facility Construction Oversight Workshop Held August 15, 2023, and Suggested Topics for Additional Public Meetings in Fall 2023 ML23256A1622023-08-0101 August 2023 Incoming NEI Letter Dated August 1, 2023 Regarding Increase in Fees 2023-2025 ML23206A0292023-07-24024 July 2023 Incoming Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07 ML23143A1232023-06-22022 June 2023 NRC Fee Waiver Request for Draft NEI 23-01 ML23200A1662023-05-30030 May 2023 NEI Proposed Metrics for a Performance-Based Emergency Preparedness Program ML23116A0732023-05-25025 May 2023 Letter to Hillary Lane in Response to a Request for a Fee Exemption for NEI 23-03 ML23135A7332023-05-0909 May 2023 NEI Comments on NRC Safety Culture Program Effectiveness Review ML23110A6782023-04-18018 April 2023 Request for Review and Endorsement of NEI 23-03, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications at Non-Power Production or Utilization Facilities ML23110A6762023-04-18018 April 2023 04-18-23_NRC_NEI 23-03 Review + Endorse ML23110A6752023-04-18018 April 2023 04-18-23_NRC_Fee Waiver for NEI 23-03 ML24120A2702023-04-0404 April 2023 Melody Rodridguez NEI Comment on Controlled Unclassified Information ML23107A2302023-03-31031 March 2023 NEI Letter, to Andrea Veil, NRC, Regarding Industry Recommendations for a 10 CFR 50.46a/c Combined Rulemaking ML23083B4622023-03-24024 March 2023 Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 ML23138A1662023-03-24024 March 2023 Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 ML23060A3272023-03-0101 March 2023 NEI, Wireless Cyber Security Guidance ML23060A2142023-03-0101 March 2023 NEI, Request for NRC Endorsement of NEI White Paper, Enabling a Remote Response by Members of an Emergency Response Organization, Revision 0 ML23023A2752023-01-23023 January 2023 Request for Extension of Comment Period from the Nuclear Energy Institute on PRM-50-124 - Licensing Safety Analysis for Loss-of-Coolant Accidents ML22348A1122023-01-17017 January 2023 Letter to Richard Mogavero Response to Fee Exemption NEI 08-09 Revision 7 ML22353A6082023-01-11011 January 2023 U.S. Nuclear Regulatory Commission Report of the Regulatory Audit of the NEI-Proposed Aging Management Program Revision to Selective Leaching Program (XI.M33) ML22349A1012022-12-12012 December 2022 LTR-22-0343 Ellen Ginsberg, Sr. Vice President, General Counsel and Secretary, Nuclear Energy Institute, Expresses Concerns Related to Issuance of Regulatory Issue Summary 2022-02; Operational Leakage ML22336A0372022-11-16016 November 2022 Fee Exemption Request for NEI 08-09 Revision 7 - Changes to NEI 08-09 Cyber Security Plan for Nuclear Power Reactors ML22321A3152022-11-16016 November 2022 NEI Letter with Comments on Significance Determination Process Timeliness Review ML22298A2262022-10-25025 October 2022 Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated October 2022 ML22298A2302022-10-17017 October 2022 Submittal of NEI 22-03, Draft Revision 0, Nuclear Generation Quality Assurance Program Description ML22207B6512022-07-26026 July 2022 NEI, Full Fee Exemption Request for Industry Guidance Proposal - Weather Related Administrative Controls During Transient Outdoor Dry Cask Operations ML22195A1662022-07-14014 July 2022 NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 ML22195A0202022-07-13013 July 2022 07-13-22 NRC Fee Exemption Request for NEI 21-05 Review ML22195A0672022-07-13013 July 2022 Fee Exemption 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 ML22159A2772022-06-28028 June 2022 Response Letter to Richard Mogavero for Fee Exemption for the Nuclear Regulatory Commission Review Ad Endorsement of NEI 15-09, Revision 1 ML22154A2962022-06-0202 June 2022 LTR from R. Mogavero to M. Sampson Dated Jun 2 2022 Endorsement of NEI 15-09 Cyber Security Event Notifications Rev 1 Dated May 2022 ML22153A2782022-06-0202 June 2022 Nie, Fee Exemption Request for Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated May 2022 ML22152A2712022-06-0101 June 2022 Digital Instrumentation and Control Common Cause Failure Policy Considerations, Revision 1 2024-07-03
[Table view] |
Text
SUSAN H. PERKINS Senior Director, Nuclear Security & Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8016 shp@nei.org nei.org February 28, 2019 Ms. Patricia Holahan Director, Division of Rulemaking Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Recommended Changes to NRC Regulatory Guides for the Final Mitigation of Beyond Design Basis Events Rule Project Number: 689
Dear Ms. Holahan:
On January 24, 2019, the U.S. Nuclear Regulatory Commission (NRC) issued the Staff Requirements Memorandum (SRM) for SECY-16-0142, Draft Final Rule Mitigation of Beyond-Design-Basis Events (RIN 3150-AJ49). With this SRM, the Commission approved a final rule that amends Parts 50 and 52 of Title 10 of the Code of Federal Regulations (10 CFR) with certain changes provided in the memorandum enclosures. The Commission also directed the staff to make any necessary conforming changes in other rulemaking documents, including the NRC Response to Public Comments and Regulatory Analysis, to reflect the changes identified in the FRN and in the Backfitting and Issue Finality Assessment.
To assist the NRC staff with the identification of necessary conforming changes, the Nuclear Energy Institute (NEI)1 and its members have prepared a summary of recommended changes to Regulatory Guides 1.226, Flexible Mitigation Strategies for Beyond-Design-Basis Events, and 1.228, Integrated Response Capabilities for Beyond-Design-Basis Events. 2 These changes, presented in the attachment to this letter, are intended to promote alignment between the NRC-endorsed content of NEI guidance documents and the requirements in the final rule, as modified by the Commission. Incorporation of these changes may also obviate the need to develop and submit revised NEI guidance documents, actions which would challenge timely rule issuance.
1 NEI is the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy industry.
2 Or the regulatory guide that subsumes the content of Regulatory Guide 1.228.
Ms. Patricia Holahan February 28, 2019 Page 2 In addition to the conforming changes identified in the attachment, we also suggest that Regulatory Guide 1.226 contain an endorsement of NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, as an acceptable method to meet the requirements of 10 CFR 50.155(b)(2).3 This addition would address the relocation of the requirements in 10 CFR 50.54(hh)(2) to 10 CFR 50.155(b)(2) and reflect the following paragraph in the final rule statements of consideration:
This rulemaking does not revise the regulatory treatment of equipment relied upon for the EDMGs now relocated to § 50.155(b)(2). The regulatory treatment of that equipment remains as it is described in NEI 06-12, the endorsed guidance document for those strategies and guidelines.
If you have questions or require additional information, please contact David Young at (202) 739-8127 or dly@nei.org, or me.
Sincerely, Susan H. Perkins Attachment c: Ms. Theresa Clark, NMSS/DRM, NRC Mr. Tim Reed, NRR/DORL/LSPP, NRC Mr. Brett Titus, NRR/DLP/PBMB, NRC 3
Or alternatively, add a statement referencing the December 22, 2006, NRC letter that endorsed NEI 06-12; refer to ADAMS Accession No. ML063560235.