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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; 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 ML22153A2782022-06-0202 June 2022 Nie, Fee Exemption Request for Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated May 2022 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 ML22152A2712022-06-0101 June 2022 Digital Instrumentation and Control Common Cause Failure Policy Considerations, Revision 1 ML22143A9362022-05-20020 May 2022 May 13, 2022, Public Meeting on Draft Regulatory Issue Summary Operational Leakage, 87 Fed. Reg. 2361 (Jan. 14, 2022) (Docket Id NRC-2021-0173) ML22110A1752022-05-0303 May 2022 NRC Response to the Nuclear Energy Institute April 1, 2022, Letter, Regarding the Nrc'S CUI Implementation Plan ML22109A2082022-04-0808 April 2022 April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0 ML22110A1782022-04-0101 April 2022 April 1, 2022, Letter from NEI Regarding Nrc'S Controlled Unclassified Information Program Implementation ML22048A5812022-02-16016 February 2022 NEI 22-02: Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations 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 ML21343A2922021-12-0808 December 2021 NEI, Transmittal of NEI 21-07 Revision 0-B, Technology Inclusive Guidance for Non-Light Water Reactor Safety Analysis Report: for Applicants Utilizing NEI 18-04 Methodology ML21337A3802021-12-0303 December 2021 NEI Technical Report NEI 17-06 - Guidance on Using Iec 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications, Revision 1 ML21319A3522021-11-10010 November 2021 NRC NEI Fee Waiver Request Changes to NEI 10-04 and NEI 13-10, Dated November 10, 2021 ML21306A3652021-10-29029 October 2021 NEI Letter from D. Young to NRC S. Atack to Cease Work on Draft D of NEI 20-05, Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Eligibility Criteria of 10 CFR 73.55(a)(7) ML21342A1682021-10-29029 October 2021 Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 10-04, Identifying Systems and Assets Subject to the Cyber Security Rule, Revision 3, Dated October 29, 2021 ML21342A2032021-10-29029 October 2021 Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 13-10, Cyber Security Control Assessments, Revision 7, Dated October 29, 2021 ML22081A2002021-10-29029 October 2021 NEI Backfitting Concerns with NRCs Developing Position on Protection of Dry Storage Systems from Natural Phenomena During Short Term Operations 2024-01-22
[Table view] Category:Report
MONTHYEARML23290A1252023-10-17017 October 2023 NEI - NEI 99-02, Rev. 8, Draft Regulatory Assessment Performance Indicator Guideline ML23290A1472023-10-17017 October 2023 NEI 99-02 Rev 8 Draft 9 29 2023 Redline Version ML23157A1062023-06-0606 June 2023 NEI 19-01, Rev 1, Safety and Economic Benefits of Accident Tolerant Fuel ML23129A0282023-05-0202 May 2023 20230502, NEI Issues for Event Notification Implementation Workshops ML23110A6762023-04-18018 April 2023 04-18-23_NRC_NEI 23-03 Review + Endorse 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 ML23125A3202023-03-0101 March 2023 Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 Revision a 5-4-23 Tirice Response to NRC Comments ML22298A2282022-10-25025 October 2022 NEI 15-09, Rev. 1, Cybersecurity Event Notifications 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 ML22195A1692022-07-31031 July 2022 NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 - Change Summary ML22195A1672022-07-14014 July 2022 NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 ML22195A1682022-07-14014 July 2022 NEI, Marked-Up to Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 ML22109A2082022-04-0808 April 2022 April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0 ML22048A5812022-02-16016 February 2022 NEI 22-02: Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations 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 ML21343A2822021-12-31031 December 2021 Redline/Strikeout Version of NEI 21-07 Rev 0-B, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Using the NEI 18-04 Methodology ML21343A2922021-12-0808 December 2021 NEI, Transmittal of NEI 21-07 Revision 0-B, Technology Inclusive Guidance for Non-Light Water Reactor Safety Analysis Report: for Applicants Utilizing NEI 18-04 Methodology ML21337A3802021-12-0303 December 2021 NEI Technical Report NEI 17-06 - Guidance on Using Iec 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications, Revision 1 ML21305A0012021-11-30030 November 2021 NEI 17-06 Rev 0 Draft B, Guidance on Using Iec 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications (Staff Comments Incorporated ML21342A2032021-10-29029 October 2021 Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 13-10, Cyber Security Control Assessments, Revision 7, Dated October 29, 2021 ML21342A1682021-10-29029 October 2021 Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 10-04, Identifying Systems and Assets Subject to the Cyber Security Rule, Revision 3, Dated October 29, 2021 ML21274A0312021-10-0101 October 2021 NRC Draft Detailed Comments Related to NEI 21-07, Revision 0, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Using the NEI 18-04 Methodology ML21278A4722021-09-30030 September 2021 NEI 20-07, Rev. Draft, Guidance for Addressing Common Cause Failure in High Safety-Significant Safety-Related Digital I&C Systems ML21257A2352021-08-19019 August 2021 Rulemaking: Proposed Rule: Advanced Reactor Physical Security, Email Exchange Between Nrc and NEI Draft Pages from NEI-20-05 Rev. E ML21250A3782021-08-0202 August 2021 NEI 21-07, Revision 0, Technology Inclusive Guidance for Non-Light Water Reactors SAR Content for Applicants Using the NEI 18-04 Methodology ML21130A5962021-05-31031 May 2021 NEI, Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems - Draft C ML21130A5972021-05-31031 May 2021 NEI 20-07, Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems - Draft C ML21130A5982021-05-0707 May 2021 NEI Responses to NRC Staff Comments on NEI 20-07 Draft B ML21125A2842021-05-0505 May 2021 Transmittal of NEI 20-09: Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-Light Water Reactor Standard ML21110A0662021-04-20020 April 2021 Nei'S Comparison Table Between NEI 20-07 Sdos and NRC RGs and Endorsed IEEE Stds R2 ML21085A5552021-03-25025 March 2021 NEI 20-09 -Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-LWR PRA Standard, March 2021 ML21089A0902021-03-18018 March 2021 NEI Comments on Renewal of Performance Indicators Information Collection, March 18, 2021 ML21049A0572021-03-0202 March 2021 Rulemaking: Proposed Rule: NRC Markup of NEI-20-05 Draft B Comments on Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Performance Criteria of 10 CFR 73.55(a)(7) ML20339A4852020-11-23023 November 2020 NEI 20-09 - NRC Comments Resolved November 2020 ML20322A3392020-11-17017 November 2020 NEI ROP White Paper Modification of the Description of Unplanned Scrams with Complications for Nov 18 2020 ROP Public Meeting ML21050A0902020-08-31031 August 2020 Staff Detailed Comments - NEI 20_07 Draft Revision B -February 2021 ML20245E1472020-08-31031 August 2020 Attachment 1 - NEI Guidelines for the Implementation of the Risk-Informed Process for Evaluations Integrated Decision-Making Panel ML20245E5612020-08-31031 August 2020 Guidance for Addressing Software Common Cause Failure in High Safety-Significant Safety Related Digital I&C Systems ML20302A1152020-08-24024 August 2020 NEI 20-09 - Nlwr PRA Peer Review Rev1 August 2020 ML20211L7142020-07-24024 July 2020 Industry Position Regarding Safety Margin: Dispositioning Degraded or Failed Management Measures Above and Beyond Regulatory Requirements, and Meeting Performance Criteria; Follow Up to May 6, 2020 Letter on Smarter Program Inspection Prior ML20155K6852020-06-0101 June 2020 Availability of NEI 20-09, Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-LWR Standard, for NRC Review and Endorsement ML20154K5662020-06-0101 June 2020 Availability of NEI 20-09, Performance of PRA Peer Reviews Using the Asme/Ans Advanced Non-LWR Standard, for NRC Review and Endorsement ML20129J8592020-05-31031 May 2020 NEI 96-07, Appendix D Revision 1, Draft M, May 2020 ML20129J8582020-05-30030 May 2020 NEI 96-07, Appendix D, Revision 1, Draft M, May 2020 with Redline Strike ML20141L7882020-05-20020 May 2020 NEI - Comments on Draft Micro-Reactor Applications COL-ISG-029, Environmental Considerations Associated with Micro-Reactors ML20139A1902020-05-14014 May 2020 05-14-20 Changes to NEI 10-04 and NEI 13-10 Guidance for Identifying and Protecting Digital Assets Associated with Safety-Related and Important-to-Safety Functions ML20134J0332020-05-13013 May 2020 Submittal of Response to Request for Additional Information (RAI) for NEI 14-05A, Revision 1, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services ML20135H1682020-05-13013 May 2020 Request for NRC Endorsement of NEI 96-07, Appendix D, Rev 1 2023-06-06
[Table view] Category:Miscellaneous
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
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Text
March 20, 2012
Mr. Russell J. Bell Director, New Plant Licensing Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, D.C. 20006-3708
SUBJECT:
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
Dear Mr. Bell:
My staff is continuing its review of Nuclear Energy Institute (NEI) 96-07, Appendix C, Revision 0C, Guideline for Implementation of Change Control Processes for New Nuclear Power Plants Licensed Under 10 CFR 52, which you submitted to the U.S. Nuclear Regulatory Commission (NRC) on October 31, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML113220426), including the two sections amended on November 30, 2011, Section 4.1.1, Construction Change Applicability (ADAMS Accession No. ML113390052) and Section 4.4.2.2, Evaluation of Departures From Tier 2 Information That Do Not Affect Ex-Vessel Severe Accident Criteria (ADAMS Accession No. ML113390051). NEI 96-07, Appendix C, Revision 0C, provides guidance for implementing the license change process requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 52. Overall, Appendix C to NEI 96-07 appears to be comprehensive and to provide an appropriate level of detail for future users. However, we have identified a number of recommendations for changes and some areas that need further clarification to meet the objectives of the change processes of 10 CFR Part 52. These recommendations are set forth in the enclosure.
We will discuss the staff comments on NEI 96-07, Appendix C, Revision 0C at a meeting to be scheduled during 2012. We look forward to receiving stakeholder input on these comments at that meeting. We appreciate your extensive effort in developing this document and anticipate that you will issue it in final form later this year. If you address the staff comments to our satisfaction, we intend to develop and issue an endorsement of NEI 96-07, Appendix C, as revised, as an acceptable method of meeting the change process regulations at 10 CFR Parts 50 and 52.
If you have any questions regarding the staff comments, please contact Mr. Earl R. Libby at (301) 415-0522.
Sincerely, /RA/ Amy E. Cubbage, Chief Policy Branch Division of Advance Reactors and Rulemaking Office of New Reactors Project No.: 689
Enclosure:
NRC Comments on NEI 96-07, Appendix C
ML120800072 *via email NRO-001 OFFICE PM:DARR/APOB LA:DARR/APOB* OGC* BC:DARR/APOB NAME ELibby BAbeywickrama* RWeisman ACubbage DATE 03/20/2012 03/20/2012 03/20/2012 03/20/2012 Enclosure U.S. Nuclear Regulatory Commission Comments on NEI 96-07, Appendix C, Revision 0C Dated October 30, 2011 Section
1.1 Purpose and Scope
Page C-4, last paragraph, third sentence
In general, this appendix has been written for applicants and holders of combined licenses (COLs). Additionally, this guidance is applicable to holders of operating licenses that reference a design certification. Furthermore, much of the information in this guidance is applicable to holders of construction permits that reference a design certification.
NRC Comment: Construction Permits (CPs) are beyond the scope of NEI 96-07, Appendix C. All other similar references to CPs should be deleted.
Section 1.2.1 Relationship to Other Processes That Control Licensing Basis Activities Page C-5, fifth bullet Changes to the fire protection program for Part 52 licensees are governed by 10 CFR 50.59 as discussed in Section 4.1 of this appendix, and licensee changes to the design of fire protection systems as described in the DCD are governed by Section VIII.B.5 of a referenced design certification rule.
NRC Comment: Some fire protection system information may be covered by the other Section VIII processes.
Page C-5, sixth bullet During the construction phase, maintenance activities, including associated temporary changes, are subject to the licensee programs for controlling such changes during construction that will be relied upon to maintain Inspection, Test, Analysis and Acceptance Criteria (ITAAC) closures, and any affected SSCs are ultimately subject to the ITAAC themselves. Accordingly, screening and evaluation under 10 CFR 50.59 and VIII.B.5 are not required.
During the operational phase, maintenance activities, including associated temporary changes, are subject to the technical specifications and are assessed and managed in accordance with the Maintenance Rule, 10 CFR 50.65; screening and evaluation under 10 CFR 50.59 and VIII.B.5 are not required.
NRC Comment: The scope of NEI 96-07 Appendix C includes both construction and operation under a COL. The Maintenance Rule is applicable only during the operational phase, after the § 52.103(g) finding. As stated in § 50.65(a)(1), "-each holder of a combined license under Part 52 of this chapter after the Commission makes the finding under § 52.103(g), shall monitor the Enclosure performance or condition of structures, systems, or components-" The language change recognizes the licensee control of maintenance activities, including associated temporary changes, during the construction phase. (
Reference:
NEI 08-01 "Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52" and RG 1.215 "Guidance for ITAAC Closure Under 10 CFR Part 52")
Section 1.2.3 Relationship to the UFSAR Page C-6 New plant change processes identified in 10 CFR 52.98 are the processes that identify when a license amendment is required prior to implementing departures from the plant specific DCD, other changes to the facility or procedures described in the FSAR (as updated, or UFSAR) or test and experiments not described in the UFSAR. As such, it is important that the FSAR be properly maintained and updated in accordance with 10 CFR 50.71(e) and Section X of the design certification rules.
NRC Comment: This section provides guidance on the requirements of both § 52.98 and § 50.59 when addressing the relationship to the UFSAR. It is important to recognize the unique role the plant specific DCD plays in the safety analysis report and the change control regulations for the plant specific DCD information.
Section 1.3 10 CFR Part 52 Change Process Overview Page C-7 first paragraph After determining that a proposed activity is safe and effective through appropriate engineering and technical evaluations, the 10 CFR Part 52 change processes are applied to determine if a license amendment and/or exemption is required prior to implementation
NRC Comment: Tier 1 changes require both a license amendment and an exemption from the design certification rule.
Page C-7 second bullet EVALUATION: Apply the applicable change process evaluation criteria to determine if a license amendment and/or exemption must be obtained from the NRC.
NRC Comment: Tier 1 changes require both a license amendment and an exemption from the design certification rule.
Page C-9 Figure 1 NRC Comment: Add logic bi-stable diamond for evaluation of aircraft impact features under 10 CFR 50.150. Enclosure
Section 1.4.1 Departures from Design Certification Information Page C-10 add new paragraph between second and third paragraph The NRC has a reasonable expectation that vendors and utilities will cooperate with the NRC in assuring that the level of enhanced safety believed to be achieved with the certified designs will be reasonably maintained for their period of operations including renewal. This expectation that industry will cooperate with NRC in maintaining the safety level of the certified designs applies to design changes under section VIII.B.5. (62 FR 25800; 25810; May 12, 1997)
NRC Comment: Staff believes there is value in restating upfront Commission's high-level expectations regarding the change process for new reactors in general and VIII.B.5 in particular.
Page C-10 last paragraph, first sentence 10 CFR 52.63 also identifies a process for changing a standard design certification by rulemaking, which includes amending the rule amendments to the rule sought by the design certification sponsor.
NRC Comment: Only the NRC can amend a rule.
Section 1.4.3 Early Site Permits
Page C-14 second paragraph Activities on the proposed site that are not construction activities, as defined under 10 CFR 50.10(a)(2), are not restricted by an ESP. Therefore, a COL applicant may make changes to the description of such activities in the SSAR without prior NRC approval, but must identify such changes as part of its FSAR. Additionally, the environmental impact of such activities or site
-related changes will need to be evaluated as potential variances or "new and significant information" in the construction permit or combined license application referencing the ESP.
NRC Comment: Delete paragraph as it is not correct. ESP holders must conduct activities in accordance with the ESP and SSAR, and may not change the ESP or the SSAR without a license amendment. (10 CFR 52.39(e)) If the holder of an ESP believes that the ESP/SSAR governs activities not within the definition of construction, it should seek a license amendment.
Page C-14 last paragraph third sentence In other words For example, after issuance of the construction permit or COL, changes to the information in the SSAR, as incorporated in the FSAR, are evaluated pursuant to the change control processes in 10 CFR 50.59 or 10 CFR 52.98, as applicable, rather than 10 CFR 52.39.
Enclosure NRC Comment: The change control process of 10 CFR 50.59 or 10 CFR 52.98 does not apply to construction permits. Section 3.2 Accident Previously Evaluation in the FSAR Page C-18 discussion second paragraph The term "accident" is distinguished from the term "severe accident". Severe accidents are events beyond the plant's design basis accidents as that term is defined in 10 CFR 50.2 and Section 3.7 of this appendix. NRC Comment: A severe accident is a beyond design basis accident, but severe accident design features are part of a plant's design basis, as defined in 10 CFR 50.2. (72 FR 49,352, 49,380)
Section 3.3 All Matters Described in the Plant-Specific DCD Page C-18 definition The evaluation of a departure must consider more than just the descriptive information contained in the text of the DCD. Thus, "all matters described in the plant-specific DCD" means includes:
NRC Comment: Specification of a list of items does not define or limit the term "all matters" in this context.
Section 3.4 Change/Departure Page C-19 definition The definition in Section 3.3 of the main body of NEI 96-07, Revision 1, also applies to Part 52 licensees for changes under 10 CFR 50.59 as well as but is not the definition of "departure" from a generic the plant specific DCD under Section VIII of the design certification rule(s). with the clarifications in italics below. Change or departure means a modification or addition to, or removal from, the facility or procedures that affects: (1) a design function or ex
-vessel severe accident function; (2) a method of performing or controlling the function; or (3) an evaluation that demonstrates that intended functions will be accomplished.
A departure is a deviation from the DCD. Specifically, a departure refers to a modification or addition to, or removal from, information contained in a referenced standard design certification rule and reflected in a plant specific DCD.
See RG 1.206, C.III.1.6.
NRC Comment: Enclosure Section VIII has its own terms and definitions separate from section 50.59. Departure is defined in the 2007 Part 52 rule to be a "deviation." Also see RG 1.206, C.III.1.6.
Page C-19 discussion The discussion in Section 3.3 of the main body of NEI 96-07, Revision 1, also applies to Part 52 licensees for changes under 10 CFR 50.59. or Section VIII of the design certification rule(s) with one addition to the discussion of design functions:
Ex-vessel severe accident functions are SSC functions or design features for the prevention or mitigation of ex
-vessel severe accidents. As defined in Section 3.8, ex
-vessel severe accident refers to a postulated accident when the reactor core has melted and exited the reactor vessel and the containment is challenged. An ex-vessel severe accident design feature is a feature that has an intended function to resolve ex-vessel severe accidents. (72 FR 49394) Consistent with the treatment of changes to an SSAR by an ESP holder (72 FR at 49360), typographical or administrative corrections that are not substantive deviations from the Tier 2 information are not considered a departure and need not be evaluated through the Section VIII criteria. However, even typographical corrections to Tier 1 and Tier 2* that are sought by a licensee require NRC approval.
NRC Comment: The 2007 Part 52 Rule and RG 1.206, C.III.1.6 defines a departure as a "deviation." The NRC did not adopt section 50.59 definitions and limitations wholesale in the 2007 rule revising Part 52. (2007 Part 52 Rule SOC, 72 FR at 49394, Pages 10-11 of Comment Summary Report for the rule).
Section 3.5 Current Licensing Basis Page C-21 discussion, first paragraph, first full sentence If the COL application references a certified design, the referenced generic DCD, including any documents specifically incorporated by secondary references in the DCD, will also include design basis information.
NRC Comment: "Secondary references in the DCD" is more comprehensive than "documents specifically incorporated by reference." The proper scope of the discussion on external documents assists the accurate retention of important data, upon which the NRC based its licensing decision.
Section 3.9 Facility as Described in the FSAR (as updated)
Page C-23 definition The definition in Section 3.6 of the main body of NEI 96-07, Revision 1, also applies to Part 52 licensees for changes under 10 CFR 50.59 or Section VIII of the design certification rule. Enclosure NRC Comment: "The facility as described in the FSAR (as updated)" is terminology relevant to section 50.59 and does not appear in Section VIII of the appendices to Part 52. Therefore, it is not relevant to whether a departure is evaluated under Section VIII, which applies to plant specific DCDs.
Page C-23 discussion
The discussion in Section 3.6 of the main body of NEI 96-07, Revision 1, also applies to Part 52 licensees for changes under 10 CFR 50.59 or Section VIII of the design certification rule(s) with the clarification that t The focus of Section VIII of the design certification rule(s) is the changes or departures from the information presented in the FSAR to satisfy the requirements of 10 CFR 52.79 47 for Part 52 licensees rather than 10 CFR 50.34(b) for Part 50 licensees. NRC Comment:
Section VIII of the design certification rule(s) addresses changes or departures to the plant-specific DCD. For Part 52, a departure is defined as a "deviation" from the design certification document.
Section 3.10 Final Safety Analysis Report (as updated)
Page C-23 definition, second paragraph Final Safety Analysis Report (as updated) means the Final Safety Analysis Report (including the plant-specific Design Control Document (DCD)) submitted in accordance with 10 CFR 52.79 ,
as amended and supplemented, and as updated per requirements of Section X.B X.A of the applicable Part 52 design certification appendix, 10 CFR 52.3 and 10 CFR 50.71(e).
NRC Comment: Section X.B refers to the reporting requirements, but there may be changes in-between the reporting periods of Section X.B.3 that should be considered.Section X.A requires the plant-specific DCD to be updated as the licensee proceeds.
Section 3.17 Procedures as Described in the FSAR (as updated)
Page C-27 definition The definition in Section 3.11 of the main body of NEI 96-07, Revision 1, also applies to Part 52 licensees for changes under 10 CFR 50.59 or Section VIII of the design certification rule(s). NRC Comment: "Procedures as described in the FSAR (as updated)" is terminology relevant to section 50.59 and does not appear in Section VIII of the appendices to Part 52. Therefore, it is not relevant to whether a departure is evaluated under Section VIII, which applies to plant specific DCDs.
Enclosure
Section 3.19 Screening Page C-28 definition The definition in Section 3.13 of the main body of NEI 96-07, Revision 1, also applies to Part 52 licensees for changes under 10 CFR 50.59 or Section VIII of the design certification rule(s). NRC Comment: This does not apply to Section VIII of the design certification rule(s) because it imports the § 50.59 definitions/limitations that were not carried forward into Section VIII of the design certification rule(s).
Page C-28 discussion The discussion in Section 3.13 of the main body of NEI 96-07, Revision 1, also applies to Part 52 licensees for changes under 10 CFR 50.59 or Section VIII of the design certification rule(s).
Further discussion and guidance on screening are provided in Section 4.2 of the main body of NEI 96-07, Revision 1, (for plant-specific FSAR changes) with any unique aspects of VIII.B.5 screening evaluation described in Section 4.4.2.1 of this appendix (for departures from design certification information).
NRC Comment: Section VIII.B.5.a requires an evaluation. "-When evaluating the proposed departure, an applicant or licensee shall consider all matters described in the plant-specific DCD-"
Section 3.21 Test or Experiments Not Described in the FSAR (as updated)
Page C-29 definition The definition in Section 3.14 of the main body of NEI 96-07, Revision 1, also applies to Part 52 licensees for changes under 10 CFR 50.59 or Section VIII of the design certification rule(s). NRC Comment: "Tests or experiments not described in the FSAR (as updated)" is terminology relevant to section 50.59 and does not appear in Section VIII of the appendices to Part 52. Therefore, it is not relevant to whether a departure is evaluated under Section VIII, which applies to plant specific DCDs.
Page C-29 discussion The discussion in Section 3.14 of the main body of NEI 96-07, Revision 1, also applies to Part 52 licensees for changes under 10 CFR 50.59 or Section VIII of the design certification rule(s). Enclosure
Section 3.22 Tier 1 Information Page C-30 discussion Changes to and departures from Tier 1 information are addressed in Section VIII.A of the design certification rule appendices. Generic changes to Tier 1 information are governed by 10 CFR 52.63(a)(1). Plant-specific departures proposed by an applicant or licensee require exemptions, which are governed by the requirement in 10 CFR 52.63(b)(1) and 52.98(f)
Section VIII.A.4. NRC Comment: The design certification rule(s)Section VIII.A.4 includes 10 CFR 52.63(b)(1) and 52.98(f) and one additional criterion, -" the Commission will deny a request for an exemption from Tier 1 if it finds that the design change will result in a significant decrease in the level of safety otherwise provided by the design." The discussion should include all of the applicable criteria.
Section 4.2.4 Safety Security Interface Page C-35 [Move this section to a more appropriate location.]
NRC Comment: The Safety Security Interface, 10 CFR 73.58, does not cleanly fall under this topic area covering more specific change processes. The SSI is an assessment and management of potential adverse effects on safety and security, including the site emergency plan, before implementing changes to plant configurations, facility conditions or security. It does not replace required change processes.