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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. 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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. 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September 11, 2003 Mr. Alex Marion, Director Engineering Department Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
Dear Mr. Marion:
The purpose of this letter is to respond to your letters to me, dated April 9 and May 22, 2003.
Your letter dated April 9, 2003, contained three enclosures entitled Industry Principles for Fire-Induced Circuit Failure Resolution, Recommended Steps for Circuit Failure Issue Resolution, and Comments on Recent NRC Documents. In this letter you asked us to accept NEI 00-01, coordinate all fire protection rulemaking activities, develop appropriate inspection guidance and training, and document regulatory expectations and resolution plans in a Regulatory Information Summary (RIS). Your letter dated May 22, 2003, requested near-term approval of NEI 00-01 for licensee use.
This letter provides you our current high-level view with respect to NEI 00-01. I have directed my staff to discuss details of NEI 00-01 with the NEI staff at a future public meeting on that subject in late October or early November. Please note that we are considering NEI 00-01 in the context of a number of other ongoing and planned rulemakings in the area of fire protection, and the views expressed in this letter have changed from our previous views on this report.
The NRC staff is currently reviewing NEI 00-01 in the context of National Fire Protection Association (NFPA) 805. In your letters, you propose that NEI 00-01 be considered as an acceptable means to achieve resolution of current licensing basis (CLB) issues. We believe that NEI 00-01 would afford an opportunity to resolve CLB issues in a risk-informed context. At the present time the staffs vision for NEI 00-01 is to endorse its circuit analysis methodology in a planned regulatory guide that accompanies the risk-informed performance-based rule that incorporates NFPA 805. Licensees not adopting the NFPA 805 option of the proposed 10 CFR 50.48 rule may apply NEI 00-01 risk-informed methods, but must also request exemptions or deviations, depending on their licensing basis.
NRC staffs current views on the inspection of fire induced circuit failures is reflected in a RIS issued recently for public comment. This RIS is available in draft form (ML032030584). An attachment to this RIS provides technical input used to risk-inform the inspection guidance on associated circuits. Furthermore, the staff is planning to hold a public workshop on this subject before resuming inspection of associated circuits. Please refer to the current Fire Protection Improvement Plan (ML032050010).
2 In your letters and in NEI 00-01, you proposed actions that require multi-discipline staff reviews as well as actions that require Commission approval. To respond to your requests, my staff has requested a cross-functional review to determine the acceptability of the application of NEI 00-01, Revision 0, in a risk-informed performance-based rule application. Based on preliminary feedback we received from the Office of Enforcement as well as the Inspection Program Branch of the Office of Nuclear Reactor Regulation, we have initiated actions to address some policy level decisions. For example, we have started developing a proposal for enforcement discretion for associated circuits findings for Commission approval. If approved by the Commission, this measure would reduce undue burden for the NRC staff and the licensees on the associated circuit analysis issues. We are working with the Inspection Program Branch of the Office of Nuclear Reactor Regulation and the Office of Enforcement on ways to encourage the licensees to self-discover and fix risk-significant issues.
We agree that it is imperative to coordinate fire protection rulemaking activities. My staff is aware of your comments on IP 71111.05 Manual Action Feasibility Criteria. They plan to address your comments and concerns on this subject as the rulemaking activities proceed.
However, I recommend that your staff meet with the NRC staff on this subject to discuss details at a future public meeting in late October or early November.
Mr. Emerson has been in contact with my staff regarding the September 2003, NEI Fire Protection Information Forum. We will further clarify NRC views on NEI 00-01 and other fire protection issues at that meeting.
If you have any questions regarding this letter, please contact Sunil Weerakkody of my staff, 301-415-2870.
Sincerely, John N. Hannon, Chief //RA//
Plant Systems Branch Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation Project No. 689
2 In your letters and in NEI 00-01, you proposed actions that require multi-discipline staff reviews as well as actions that require Commission approval. To respond to your requests, my staff has requested a cross-functional review to determine the acceptability of the application of NEI 00-01, Revision 0, in a risk-informed performance-based rule application. Based on preliminary feedback we received from the Office of Enforcement as well as the Inspection Program Branch of the Office of Nuclear Reactor Regulation, we have initiated actions to address some policy level decisions. For example, we have started developing a proposal for enforcement discretion for associated circuits findings for Commission approval. If approved by the Commission, this measure would reduce undue burden for the NRC staff and the licensees on the associated circuit analysis issues. We are working with the Inspection Program Branch of the Office of Nuclear Reactor Regulation and the Office of Enforcement on ways to encourage the licensees to self-discover and fix risk-significant issues.
We agree that it is imperative to coordinate fire protection rulemaking activities. My staff is aware of your comments on IP 71111.05 Manual Action Feasibility Criteria. They plan to address your comments and concerns on this subject as the rulemaking activities proceed.
However, I recommend that your staff meet with the NRC staff on this subject to discuss details at a future public meeting in late October or early November.
Mr. Emerson has been in contact with my staff regarding the September 2003, NEI Fire Protection Information Forum. We will further clarify NRC views on NEI 00-01 and other fire protection issues at that meeting.
If you have any questions regarding this letter, please contact Sunil Weerakkody of my staff, 301-415-2870.
Sincerely, John N. Hannon, Chief //RA//
Plant Systems Branch Division of Systems Safety and Analysis Office of Nuclear Reactor Regulation Project No. 689 DISTRIBUTION: ADAMS SPLB R/A SBlack MJohnson JHannon JHyslop JBirminghan BSheron MSalley DFrumkin GParry MReinhart MRubin WBorchardt ISchoenfeld SWeerakkody Internet:fae@nei.org Accession Number: ML032541229 Please see previous concurrence DOCUMENT NAME: C:\ORPCheckout\FileNET\ML032541229.wpd OFFICE SPLB:DSSA: SC:SPLB: RPRP BC:SPLB: DSSA D:DSSA NRR DSSA DD:DSSA NAME DFrumkin:tw SWeerakkody EMckenna JHannon SBlack/
MJohnson DATE 8/22/03 8/22/03 9/ 02 /03 9/11/03 9/11/03 OFFICIAL RECORD COPY