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| {{#Wiki_filter:}} | | {{#Wiki_filter: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}} |
Latest revision as of 16:29, 29 October 2019
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Category:Letter
MONTHYEARML24023A0392024-01-22022 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 ML23110A6752023-04-18018 April 2023 04-18-23_NRC_Fee Waiver for NEI 23-03 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 ML23107A2302023-03-31031 March 2023 NEI Letter, to Andrea Veil, NRC, Regarding Industry Recommendations for a 10 CFR 50.46a/c Combined Rulemaking 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 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 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; 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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