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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
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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
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ML23236A4992023-08-24024 August 2023
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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
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Letter to Richard Mogavero Response to Fee Exemption NEI 08-09 Revision 7
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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
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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
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ML22195A0202022-07-13013 July 2022
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ML22195A0672022-07-13013 July 2022
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April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0
ML22110A1782022-04-0101 April 2022
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ML22019A2922022-01-12012 January 2022
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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
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ML21342A2032021-10-29029 October 2021
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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
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JERRY W. HIATT, CHP Senior Project Manager, Radiation Safety and Environmental Protection 1201 F Street
, NW, Suite 1100 Washington, DC 20004 P: 202.739.8171 jwh@nei.org nei.org September 20, 2018 Mr. Dave Garmon, Health Physicist Radiation Protection and Consequence Branch U.S. Nuclear Regulatory Commission Washington, DC 20555
-0001
Subject:
Industry Comments on NRC Draft Revision to the Public Radiation Safety Significant Determination Process Project Number: 689 Dear Mr. Garmon
- On behalf of the Nuclear Energy Institute's (NEI)1 members, we provide the attached comments on the NRC Draft Revision to the Public Radiation Safety Significant Determination Process provided to external stakeholders.
We thank you for the opportunity to provide the nuclear energy industry's comments on the Draft Revision. If you have any questions or require additional information, please contact me
. Sincerely, Jerry W. Hiatt, CHP Attachment c: Dr. Kevin Hsueh, NRR/NRC 1The 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 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.
Page l 1 of 3 Summary of Industry Comments 09.20.2018 USNRC PUBLIC RADIATION SAFETY SIGNIFICANCE DETERMINATION PROCESS DRAFT REVISION FOR EXTERNAL STAKEHOLDERS
, Page-Location - NRC Draft Proposed Text in NRC Draft Industry Comment p.3, 1 st full paragraph If the licensee has a substantial failure to implement the radioactive effluent release program, then the finding would be WHITE - Comment: Regarding the WHITE designation
- Is there no consideration of the actual public dose resulting from the failure? Should not a minimal dose consequence be considered GREEN?
p.3, 2 nd paragraph If the licensee has a substantial failure to implement the radioactive effluent release program, then the finding would be WHITE. Failure to identify a release event, or assess the dose consequences and the impact to the environment in a timely manner, consistent with ODCM requirements, could be considered a substantial failure to implement the radioactive effluent release program.
Recommendation:
Insert the word "radiological" as shown below "Failure to identify a radiological release event -" Page 3, 3 rd Paragraph Examples of a substantial failure to implement the radioactive effluent release program are:
- Significant deficiency in implementing the effluent release program as defined in the plant's Technical Specifications, resulting in the gross inability or gross inaccuracy in characterizing an effluent release.
- Significant deficiency in evaluating an effluent release (either planned or unplanned) where the resulting dose has been grossly underestimated.
- Significant deficiency in calibrating effluent monitors used to assess effluent The uses of the words "significant" and "gross inability" are subjective and subject to inspector interpretation.
Recommendation
- Significant deficiency in implementing the effluent release program as defined in the plant's Technical Specifications, resulting in the inability or inaccuracy greater than a factor of 100 in characterizing an effluent release vs. an equivalent NRC. Calculation Significant deficiency in evaluating a radiological effluent release (either planned or unplanned) where the calculated dose has been underestimated by a factor of 100 vs. an equivalent NRC calculation Significant deficiency in calibrating instrumentation or monitors used to Page l 2 of 3 releases, resulting in a gross inability or gross inaccuracy in characterizing an effluent release.
- Failure to have any data by which to assess the dose to a member of the public from an effluent release (i.e., no monitor data, no independent sample data, no actual release sample data, etc.) assess radiological effluent releases, resulting in an inability or inaccuracy greater than a factor of 100 vs. equivalent NRC calculation in characterizing an effluent release.
Failure to collect and assemble data by which to assess the dose to a member of the public from a radiological effluent release (e.g., no monitor data, no independent sample data, no actual release sample data, etc.) Overall Section - General Industry Comment RADIOACTIVE EFFLUENT RELEASE PROGRAM Comment: The Effluent Release Program section is silent on Solid Radwaste Effluent Reporting. It must be assumed that all findings on Solid Radwaste Effluent reporting would be Green.
Since the last NRC Rad Effluent Report (2010, which is 7 years late) also excluded any Solid Radwaste Effluent information, this reporting must not be of safety significance.
Commercial Solid Low Level Waste disposal data is obtained and stored in the National DOE Manifest Information Management System (MIMS).Therefore, NRR should follow up on its written promise dated June 18, 2015 to revise RG 1.21 with regard to solid radioactive waste shipped. That revision should eliminate the requirement to submit Solid Radwaste shipment quantities as part of the Annual Radiological Effluent Release Report (ARERR). In addition, review of the ARERR for types and amounts of radioactive waste disposed should be deleted from Inspection Manual 71124.08-03 b. pp. 6 & 7 General Industry Comment C. SDP Determination Process
- a. Packaging Comment: Industry suggests that the definition of what constitutes 1 R/hr at 3 meters be added asSection V C. b. Radiation Limits Exceeded.
The draft revision to this section already added clarification regarding averaging radiation levels over the area of a probe. Additional text should be added on averaging 3 meter dose rates from packages.
Page l 3 of 3 Such guidance is needed in this document at this time because NUREG 1608 is not slated for revision for at least 2 years.
p.9 ,footnote2 The loss of package contents means that radioactive material has been released and can be detected and distinguished in a low background area
at a distance of 30 cm from the item with a micro
-rem per hour
-type instrument, which typically uses a 1 inch by 1 inch scintillation detector. Comment/Question: what constitutes a "low background area
?" Is it intended to be near the location of the potential release or could the package be taken to another location where the "background" could be lower? e.g., inside a separate building p.12, 2 nd paragraphIt is also expected that the inspector follows previous guidance concerning multiple findings on a single incident.
That is, a finding with a package breach which resulted in a YELLOW determination and a CoC deficiency which resulted in a GREEN determination would be considered to be a YELLOW finding. This is because the YELLOW signifies a more serious problem with the package breach aspect of the finding, than the CoC deficiency aspect of the finding.
Comment/Question
- This statement indicates that only a single finding would be issued. In other words only a "Yellow" and not a "Yellow" for the breach and a "Green" for the documentation associated with the CoC.
Is this correct?