ML25037A233
| ML25037A233 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/06/2025 |
| From: | Anderson V Nuclear Energy Institute |
| To: | NRC/SECY/RAS |
| References | |
| NRC-2024-0173, PRM-50-126, 89FR92853 | |
| Download: ML25037A233 (1) | |
Text
From:
ANDERSON, Victoria To:
RulemakingComments Resource
Subject:
[External_Sender] NEI Comments on Petition for Rulemaking Technical Specifications for Nuclear Power Reactors (Docket ID NRC-2024-0173)
Date:
Thursday, February 6, 2025 1:28:41 PM Attachments:
02-06-25_NEI Comments on Petition for Rulemaking Technical Specifications for Nuclear Power Reactors (Docket ID NRC-2024-0173).pdf February 06, 2025 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
Subject:
NEI Comments on Petition for Rulemaking Technical Specifications for Nuclear Power Reactors (Docket ID NRC-2024-0173)
Submitted via Regulations.gov Rulemakings and Adjudications Staff:
By Federal Register (FR) notice (89 FR 92853) dated November 25, 2024, the Nuclear Regulatory Commission (NRC) requested comments on a petition for rulemaking submitted by Brian D. Mann on behalf of the Technical Specifications Task Force, the Pressurized Water Reactor Owners Group, and the Boiling Water Reactor Owners Group. The petition, dated September 13, 2024, requested that the NRC revise its regulations to apply risk insights to the selection of technical specifications (TS) Limiting Conditions for Operation (LCOs) and to update the regulation to be consistent with the guidance in the NRC's Standard Technical Specifications (STS). The petition was assigned Docket No. PRM 126.
The TS are the most visible and pervasive aspect of the NRC's regulatory oversight of nuclear power plants. The NRC and the industry have developed and implemented many risk-informed initiatives to improve the TS over the last 30 years. The Nuclear Energy Institute (NEI)
[1]
agrees with the petitioner that additional improvements to plant safety and operation can be made by the application of risk to the TS LCO selection criteria, which requires a change to the regulation.
NEI endorses the petition and requests that the NRC initiate rulemaking. NEI agrees with the problem statement and the proposed solution described in the petition. Additionally, NEI agrees that the proposed rule change supports congressional direction in the "Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024" (the "ADVANCE
Act of 2024"), and the NRCs Strategic Plan.
NEI also supports the petitioners request to revise 10CFR50.36 to be consistent with the Commissions STS, and to remove information that is no longer applicable. While the petition proposes the changes on a "not-to-interfere" basis with the primary change to risk-inform the TS LCO selection criteria, NEI strongly encourages the NRC to include the changes in the rulemaking.
NEI also supports the proposed changes to the Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors. These changes update the Final Policy Statement to be consistent with the revised regulations and current terminology and facilitate future licensing actions to take full advantage of the rule change.
We appreciate the opportunity to provide our perspective on this important regulatory matter. If you have questions or require additional information, please contact me at vka@nei.org.
Sincerely, Victoria Anderson Techincal Advisor, Engineering & Risk
[1]
The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
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.
Victoria Anderson Technical Advisor, Engineering &
Risk Phone: 202.739.8101 Email: vka@nei.org February 06, 2025 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff
Subject:
Comments on Petition for Rulemaking Technical Specifications for Nuclear Power Reactors (Docket ID NRC-2024-0173)
Submitted via Regulations.gov Rulemakings and Adjudications Staff:
By Federal Register (FR) notice (89 FR 92853) dated November 25, 2024, the Nuclear Regulatory Commission (NRC) requested comments on a petition for rulemaking submitted by Brian D. Mann on behalf of the Technical Specifications Task Force, the Pressurized Water Reactor Owners Group, and the Boiling Water Reactor Owners Group. The petition, dated September 13, 2024, requested that the NRC revise its regulations to apply risk insights to the selection of technical specifications (TS) Limiting Conditions for Operation (LCOs) and to update the regulation to be consistent with the guidance in the NRC's Standard Technical Specifications (STS). The petition was assigned Docket No. PRM-50-126.
The TS are the most visible and pervasive aspect of the NRC's regulatory oversight of nuclear power plants. The NRC and the industry have developed and implemented many risk-informed initiatives to improve the TS over the last 30 years. The Nuclear Energy Institute (NEI)1 agrees with the petitioner that additional improvements to plant safety and operation can be made by the application of risk to the TS LCO selection criteria, which requires a change to the regulation.
NEI endorses the petition and requests that the NRC initiate rulemaking. NEI agrees with the problem statement and the proposed solution described in the petition. Additionally, NEI agrees that the proposed rule change supports congressional direction in the "Accelerating Deployment of Versatile, Advanced 1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
Rulemakings and Adjudications Staff February 06, 2025 Page 2 Nuclear Energy Institute Nuclear for Clean Energy Act of 2024" (the "ADVANCE Act of 2024"), and the NRCs Strategic Plan.
NEI also supports the petitioners request to revise 10 CFR 50.36 to be consistent with the Commissions STS, and to remove information that is no longer applicable. While the petition proposes the changes on a "not-to-interfere" basis with the primary change to risk-inform the TS LCO selection criteria, NEI strongly encourages the NRC to include the changes in the rulemaking.
NEI also supports the proposed changes to the Commissions Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors. These changes update the Final Policy Statement to be consistent with the revised regulations and current terminology and facilitate future licensing actions to take full advantage of the rule change.
We appreciate the opportunity to provide our perspective on this important regulatory matter. If you have questions or require additional information, please contact me at vka@nei.org.
Sincerely, Victoria Anderson Techincal Advisor, Engineering & Risk