ML18274A188
| ML18274A188 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/2018 |
| From: | Aron Lewin NRC/NRR/DIRS/IRIB |
| To: | Thomas Hipschman, Aron Lewin |
| Lewin A, 415-2259, NRR/DIRS | |
| References | |
| Download: ML18274A188 (2) | |
Text
From: SLIDER, James To: Lewin, Aron
- Hipschman, Thomas Cc
- EGDORF, John
Subject:
[External_Sender] FLEX Related Inspection Revisions Date: Thursday, August 23, 2018 7:31:06 AM Attachments:
IP71111-18_FLEX Mod_ML18192A217.pdf Aron/Tom, Below is a comment on the proposed revision of IP 71111, Attachment 18, to which you shared with us in July.
NEI members have a concern that the revision of Inspection Manual 71111, Attachment 18 (attached) could be interpreted to be broader than the current licensees' SAMGs commitments.
The Inspection Manual could imply that all of NEI 14-01 section 3.2 is applicable (prior to 10 CFR 50.155 being approved by the Commission), versus only the applicable SAMGs integration and validation portions. Per the Nuclear Strategic Issues Advisory Committee (NSIAC) initiative, licensees committed to the following:
"Site SAMGs will be updated to future revisions of the BWROG or PWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other emergency response guideline sets and symptom based Emergency Operating Procedures, and validated , using the guidance in NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents .1" Below is a suggested wording change to limit the scope of the inspection criteria to that of the NSIAC commitment.
- e. (If applicable) Verify that site SAMGs are updated when the BWROG or PWROG generic severe accident technical guidelines are revised.
Specific Guidance The PWROG issued new severe accident technical guidelines in February 2016 (Revision 0), while the BWROG issued a Revision 4 to severe accident technical guidelines guidance in June 2018.
Licensees have committed to updating site SAMGs within 2 refueling outages or 3 years (whichever time period is greater) of the publication date of new BWROG or PWROG generic severe accident technical guidelines.
Licensees have also committed to integrating the SAMGs with other emergency response guideline sets and symptom based Emergency Operating Procedures, and validating the site SAMGs in accordance with in NEI 14-01, "Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents."
Section 3.2 of NEI 14-01 contains guidance on SAMG integration and validation for updating site SAMGs when either the BWROG or PWROG revise their generic severe accident technical guidelines..
NEI 14-01, Revision 1 was issued in February 2016 (ML16224A619).
If you have any questions, please let us know.
Best regards, Jim James SLIDER l Senior Project Manager, Regulatory Affairs 1201 F Street, NW, Suite 1100 l Washington, DC 20004 P: 202.739.8015 nei.org This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.Sent through www.intermedia.com