ML101890078
| ML101890078 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 08/03/2010 |
| From: | Leeds E Office of Nuclear Reactor Regulation |
| To: | Pietrangelo A Nuclear Energy Institute |
| Stuchell S, NRR/DPR,301-415-1847 | |
| References | |
| NEI 10-06, Rev 0, TAC ME4210, Y020100117 | |
| Download: ML101890078 (3) | |
Text
August 3, 2010 Anthony Pietrangelo Senior Vice President and Chief Nuclear Officer Nuclear Energy Institute 1776 I Street, N.W., Suite 400 Washington, D.C. 20006-3708
Dear Mr. Pietrangelo:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your June 30, 2010, letter and e-mail, Submittal of NEI 10-06, Revision 0, Regulatory Issue Resolution Protocol: A Method for Resolving Regulatory Issues with Generic Implications (Agencywide Documents Access and Management System, Accession Number ML101900464).
Both the Nuclear Energy Institute (NEI) and NRC Regulatory Issue Resolution Protocol (RIRP) teams should be commended for their efforts over the last eighteen months, including, the open and public communication that was maintained in the development of the industry guidance document and for endeavoring to achieve a mutual understanding of how to enhance this protocol. The NRC agrees that this protocol could aid in more efficiently evaluating, resolving and closing out selected regulatory issues with generic implications, resulting in a more timely and effective resolution of those issues. Implementing NEIs 10-06 guidance document to facilitate issue closure can promote consistency in the industrys interface with existing NRC processes.
Although NEI did not request the NRC to formally review and comment on NEI 10-06, NRC staff intends to review the document and separately provide comments back to NEI. During our preliminary review, the staff found a substantial improvement from the draft document.
However, staff believes there should be a stronger emphasis on developing and implementing plans for specific actions, schedules, and milestones during each project. In addition, to expedite the resolution of any issue managed under the RIRP, there should be an industry emphasis on implementing both short and long-term actions as determined by the RIRP team.
There must be a clear connection between the action plan, the implementation, and the closure criteria. The NRC has not identified the need for any changes to existing NRC processes.
In addition to substantial process improvement resulting from implementation of the pilot on electrical cable degradation, the NRC and industry staff has made progress on developing durable guidance for monitoring cable performance. The NRC staff looks forward to reviewing the proposed industry cable monitoring program and pilot implementation plan detailing the short-term actions taken and the long-term actions planned by all commercial nuclear power plants to address the cable design and environment issues. This will be necessary to resolve the cables pilot.
We believe that an additional pilot is needed to continue to refine and validate the effectiveness of the guidance document. Continuous improvement and timely issue resolution will facilitate our shared goal of a safety-focused, effective and efficient process.
The NRCs Generic Issues Program seeks to utilize existing NRC processes and industry initiatives to address Generic Issues across the spectrum of NRC licensees. The RIRP aids this objective by providing a framework with the potential to improve collaboration and timely resolution of Generic Issues. I believe that NEIs and industrys dedication to the timely resolution of generic issues is crucial to the protocols prospects for long-term success.
I support an additional pilot as the mutual method to further enhance and refine NEI 10-06. I appreciate your commitment to work with me as Co-Executive sponsor and look forward to continued improvement in this area.
Sincerely,
/RA/
Eric J. Leeds, Director Office of Nuclear Reactor Regulation cc:
Gordon Clefton, NEI Jeannie Rinckel, NEI Martin Virgilio, NRC
- concurrence via e-mail OFFICE PM: NRR/DPR/PGCB LA: DPR/PGCB*
BC:NRR/DPR/PLPB DD:NRR/DE NAME SStuchell CHawes JJolicoeur (BMiller for)
PHiland (GWilson for)
DATE 07/15/10 07/16/10 07/23/10 07/20/10 OFFICE DD:NRR/DORL DD: NRR/DPR OD: NRR NAME JGiitter TMcGinty (TQuay for)
ELeeds DATE 07/21/10 07/22 /10 8/3/10