ML17276A633

Submittal of NEI 15-03, Revision 2, License Actions to Address Non-conservative Technical Specifications.

ML17276A633
Person / Time
Site:	Nuclear Energy Institute
Issue date:	10/02/2017
From:	Cameron G Nuclear Energy Institute
To:	Jennifer Whitman Office of Nuclear Reactor Regulation
Shared Package
ML17276A630	List: ML17276A633 ML17276A642
References
NEI 15-03, Rev. 2
Download: ML17276A633 (2)

Text

GREGORY R. CAMERON Sr. Project Manager, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8105 grc@nei.org nei.org October 2, 2017 Ms. Jennifer Whitman Chief, Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Submittal of NEI 15-03, Revision 2, Licensee Actions to Address Nonconservative Technical Specifications Project Number: 689

Dear Ms. Whitman:

On behalf of the industry, the Nuclear Energy Institute (NEI)1 submits NEI 15-03, Revision 2, Licensee Actions to Address Nonconservative Technical Specifications for U.S. Nuclear Regulatory Commission (NRC) review and endorsement. This guidance was developed by the industry to provide guidance that may be used by licensees to address an operating license technical specification that is determined to be insufficient to protect the assumptions or conclusions of the safety analysis or technical specification bases (i.e., a Nonconservative Technical Specification or NCTS). In 1998, the NRC issued Administrative Letter 98-10 (AL 98-10),

Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety. Since the issuance of AL 98-10, industry operating and regulatory experience has indicated the need to provide additional guidance to licensees. This was the topic of a technical session at the 2014 NRC Regulatory Information Conference, during which it was suggested that the industry develop this guidance.

NEI 15-03, Revision 2 replaces Revision 1, which was submitted for NRC review and endorsement by NEI letter dated October 31, 2016. Revision 2 addresses NRC comments and suggestions made during a public meeting held on August 8, 2017.

We believe that use of this document by licensees will provide further guidance on actions to be taken upon identification of an NCTS to verify and maintain acceptable plant conditions, comply with license and 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.

Ms. Jennifer Whitman October 2, 2017 Page 2 regulatory requirements, and communicate the details of the condition appropriately. This guidance does not establish any new regulatory requirements, but suggests a process to ensure appropriate steps are taken when an NCTS is identified.

If you have any questions, please contact me.

Sincerely, Gregory R. Cameron Attachment c: Blake Purnell, NRR, NRC