ML11284A006

Staff Responses to Public Comments on DG-1250

ML11284A006
Person / Time
Issue date:	08/28/2012
From:	Office of Nuclear Regulatory Research
To:
Jervey, Richard
Shared Package
ML112580016	List: ML11284A006
References
DG-1250 RG 1.215, Rev 1
Download: ML11284A006 (13)

Text

A notice that Draft Regulatory Guide DG-1250 was available for public comment was published in the Federal Register on May 13, 2011, 76 FR 27924-27925. The comment period ended July 25, 2011. A single comment submission was received from the organization listed below. The comments and the NRC staffs response are set forth in the following table.

Comments were received from:

Russell J. Bell, Director New Plant Licensing, Nuclear Generation Division Nuclear Energy Institute (NEI) 1776 I Street NW, Suite 400 Washington DC 20006-3708 Telephone: 1-202-739-8087 (ADAMS ML11209C487)

Section of Comment or Basis Recommendation NRC Resolution DG1250

1. Clarification Modify this sentence as follows: Staff agrees that a clarification along the lines suggested This supplemental ITAAC closure notification would would be beneficial, but the staff will use language that Page 2, describe the resolution of the circumstances more closely follows the language used in the rule.

paragraph 4 surrounding the identification of new material beginning information, and would need to contain sufficient Sentence will be revised as follows:

The information to demonstrate that, notwithstanding the regulation at new material information, the prescribed inspections, This supplemental ITAAC closure notification would proposed tests, or analyses have been performed as required and describe the resolution of the circumstances surrounding the prescribed acceptance criteria are met. the identification of new material information, and would need to contain sufficient information to demonstrate that, notwithstanding the new information, the prescribed inspections, tests, or analyses have been performed as required and the prescribed acceptance criteria are met.

2. When referring directly to the Modify first sentence as follows: Staff disagrees in that this language is a paraphrase to Commission finding required Operation (which includes loading fuel) cannot make the point that all acceptance criteria need to be met Page 2, by Section 52.103(g), the actual commence until the Commission finds under 10 CFR at that time. To be more clear the following change will paragraph 5 rule language should be used. 52.103(g) that the all acceptance criteria in the be made to the sentence:

beginning combined license ITAAC are met.

ML11284A006

Section of Comment or Basis Recommendation NRC Resolution DG1250 Operation Operation (which includes loading fuel) cannot

. commence until the Commission finds under 10 CFR 52.103(g) that all acceptance criteria in the COL are met.

3. Clarification Modify second sentence to refer to the specific Staff agrees. It would be appropriate to cite Section regulation: Section 52.99(a) 52.99(a) when discussing the ITAAC completion Page 5, schedule submittals required by this section. Sentence Paragraph 1 will be revised to specify Section 52.99(a).

beginning, Section 4

4. The ITAAC completion Modify this paragraph to read as follows: Staff agrees. The requested Level 3 schedules could be schedules referred to in Section In addition to the required schedule submittals If not the same as those schedules submitted to satisfy the Page 5, 4 of NEI 08-01 are expected to already included in the schedule information provided requirements of Section 52.99(a). Section will be Paragraph 2 be one and the same as the in accordance with Section 52.99(a), licensees should revised as follows:

beginning, schedules required by Section provide a Level 3 schedule of ITAAC-related In addition 52.99(a). Clarify guidance so it activities on site and off site (in vendor shops). These If not already included in the schedule information to does not suggest the need for detailed schedules will allow the staff to plan its provided in accordance with Section 52.99(a), licensees two different submittals of oversight activities. should provide a Level 3 schedule of ITAAC-related construction schedule activities on site and off site (in vendor shops). These information. detailed schedules will further allow the staff to plan its oversight activities.

5. The recommendation for Replace this paragraph with the following: Staff agrees with the commenters reasoning, but will applicants to submit and modify the proposed paragraph to reflect that the Page 5, maintain a complete COLs will include an appendix that contains a description of how ITAAC will be included in the Paragraph 3 consolidated listing of ITAAC complete integrated list of ITAAC for each licensed license is a current staff expectation. Referenced beginning, is beyond the scope of this Reg. unit, drawn from the DCD, ESP, LWA and COL, as paragraph will be replaced with the following:

Applicants Guide, and does not have a applicable. The NRC expects that licensees will The NRC expects to issue COLs which include an should regulatory basis. submit ITAAC closure notifications using the appendix that contains a complete, integrated list of nomenclature and numbering scheme of the ITAAC ITAAC for each licensed unit, drawn from the design Applicants provide a complete identified in the COL. This will minimize errors and control document, early site permit (ESP), limited work 2

Section of Comment or Basis Recommendation NRC Resolution DG1250 list of ITAAC when ensure consistent referencing of specific ITAAC by authorization (LWA), and COL application, as incorporating a DCD by the licensee, NRC and the public. applicable. The NRC expects that licensees will submit reference, and adding plant- Applicants should submit and maintain a complete, ITAAC closure notifications using the nomenclature and specific ITAAC in COLA Part consolidated listing of the ITAAC in their COL numbering scheme of the ITAAC identified in the COL.

10. A complete integrated list applications. Providing a complete table that lists all This will minimize errors and ensure consistent of ITAAC will be established ITAAC will ensure that the ITAAC issued with the referencing of specific ITAAC by the licensee, the NRC, as Appendix A of the COL and COL are accurate and will standardize a reference that and the public.

maintained as part of the the staff and licensees can then use. The submission of license (including a complete ITAAC list prior to COL issuance will approved/incorporated reduce errors when referencing or identifying ITAAC amendments). and will provide the basis for the ITAAC list included as an appendix to the COL.

6. Clarification Modify second and third sentences to read as follows: Staff agrees. These clarifications correctly identify the This section also provides guidance for the licensee intended notifications and ITAAC completion packages.

Page 5, oversight of ITAAC closure activities and the Sentence will be revised as follows:

Paragraph 4 maintenance of records referenced by the ITAAC beginning, closure notifications packages. In addition, Section 5 This section also provides guidance for the licensee Section 5 of NEI 08-01 provides an outline of ITAAC oversight of ITAAC closure activities and the completion packages. maintenance of records referenced by the ITAAC closure notifications. In addition, Section 5 of NEI 08-01 provides an outline of ITAAC completion packages.

7. As discussed in NEI 08-01, Add language similar to this from NEI 08-01, Section Staff agrees. By adding the reference to SECY please add language from 4.1: As described in SECY 06-0114, Description of 0114, the reader will understand that the discussion on Page 5, SECY-06-0114 concerning the Construction Inspection Program for Plants the single proprietary determinations has previously Paragraph 1 one-time submittal of a Licensed under Part 52, licensees may submit a been presented to the Commission. Paragraph will be beginning, proprietary affidavit covering single affidavit to request that schedule information be added as follows:

Section 4 the submittal of detailed held as proprietary under 10 CFR 2.390. SECY 06-ITAAC completion schedules 0114 states, [B]ecause the nature of the information As described in SECY 06-0114, Description of the and updates. would not change from initial submittal to update, no Construction Inspection Program for Plants Licensed 3

Section of Comment or Basis Recommendation NRC Resolution DG1250 additional proprietary determinations would be needed under Part 52, licensees may submit a single affidavit and routine schedule updates from the licensee would to request that schedule information be held as be considered proprietary and would be withheld from proprietary under 10 CFR 2.390. SECY 06-0114 states the public without further evaluation. This approach as follows:

would allow for a single proprietary determination, limited to the schedule and its updates, that would Because the nature of the information would not change apply to an entire construction project. from initial submittal to update, no additional proprietary determinations would be needed and routine schedule updates from the licensee would be considered proprietary and would be withheld from the public without further evaluation. This approach would allow for a single proprietary determination, limited to the schedule and its updates, that would apply to an entire construction project.

8. Clarification is needed to assure Modify first sentence as follows: Staff agrees. By adding the recommended phrase, the the reader understands that the The NEI guidance appropriately reflects that the NRC sentence correctly explains that the NEI guidance Page 5, NRC staff has determined that expects the notification of ITAAC completion to provides acceptable guidance on sufficient Paragraph 6 NEI 08-01 provides acceptable contain more information than just a simple statement information for notifications on ITAAC completion.

beginning, guidance on sufficient The sentence will be revised as follows:

The NRC information.

expects The NEI guidance appropriately reflects that the NRC expects the notification of ITAAC completion to contain more information than just a simple statement

9. Consistent, well understood Modify the first 2 sentences as follows: Staff disagrees with the edits proposed for the first 2 language should be used to Each 10 CFR 52.99(c)(1) submittal should include sentences. Staff believes that the language on Page 5, describe the required content of sufficient information on the attributes that validate sufficient information should be retained, and does not Paragraph 7 ITAAC Closure Notifications. that the licensee has satisfied the acceptance criteria. see a problem with the attributes that validate beginning, The regulatory guidance should Licensee ITAAC Closure Notifications under 10 CFR language. Staff agrees to revise the third sentence as Each 10 avoid use of language that is 52.99(c)(1) should include copy the ITAAC copied proposed CFR unlike that used anywhere else directly from the certified design and COL to the 52.99(c)(1) in the DG or NEI 08-01: ITAAC statement. Paragraph will be revised as follows:

4

Section of Comment or Basis Recommendation NRC Resolution DG1250 submittal

1. Sufficient Modify the third sentence as follows: Each 10 CFR 52.99(c)(1) submittal should include information on the The ITAAC determination basis (IDB) should sufficient information on the attributes that validate that attributes that include a clearly written, detailed process on the licensee has satisfied the acceptance criteria. The validate description of how the licensee completed the licensee should copy the ITAAC directly from the COL

[ITAAC] to the ITAAC statement. The ITAAC determination

2. clearly written, basis (IDB) should include a clearly written description detailed process of how the licensee completed the inspections, tests, or analyses and should explain how it met the acceptance criteria. The licensee.

10. Clarification. Revise second sentence as follows: Staff agrees. References to proposed requirements The 225-day notification mandated by proposed 10 should be removed from the final regulatory guide.

Page 6, Also, do not refer to proposed CFR 52.99(c)(3), must include sufficient information Sentence will be revised as follows:

Paragraph 3 requirements in the final so that interested persons will have access to beginning, regulatory guide. information on uncompleted ITAAC The 225-day notification mandated by10 CFR Section 52.99(c)(3), must include sufficient information so that 7 interested persons will have information on uncompleted ITAAC

11. Clarification Revise last sentence as follows: Staff agrees. The clarification improves the readability The uncomplete notification will be a predictive of the sentence. Sentence will be revised as follows:

Page 6, summary for how the licensee plans to complete the Paragraph 3 ITAAC that are if that ITAAC is not completed by The uncomplete notification will be a predictive beginning, 225 days before the scheduled loading of fuel. summary for how the licensee plans to complete the Section ITAAC that are not completed by 225 days before the 7 scheduled loading of fuel.

12. Regulatory guidance The preceding paragraph that begins, The licensee Staff disagrees to deleting the paragraph, but agrees with concerning the 225-day must demonstrate provides apt and sufficient the proposed edits. This position on the content of the Page 6, uncompleted ITAAC letter regulatory guidance for implementing Section uncomplete ITAAC notification is consistent with Paragraph 5 should focus on the information 52.99(c)(3). Thus we recommend deleting this discussions in the public ITAAC workshop series and beginning, required by Section 52.99(c)(3). paragraph (which continues onto page 7) in its agrees with the content of NEI 08-01 Revision 4 Section Each That regulation does not require entirety. 7 and Appendix E.

proposed 10 the uncomplete letter to 5

Section of Comment or Basis Recommendation NRC Resolution DG1250 CFR describe both completed and If the NRC elects to retain this paragraph, Paragraph will be revised as follows:

52.99(c)(3) uncompleted elements of an submittal ITAAC, nor does it require a proposed should be deleted from first sentence (see Each 10 CFR 52.99(c)(3) notification should include schedule for completing comment 15) sufficient information for both the completed and ITAAC. Since developing uncompleted elements of the ITAAC. The licensee guidance to this effect in 2008, Refer to clearly written description instead of should copy the ITAAC directly from the COL to the the industry has determined that detailed process (see comment 9) ITAAC statement. Items that the licensee has parsing completed versus completed toward ITAAC closure should be uncompleted ITAAC elements, accompanied by a clearly written description that and providing a schedule for describes how it completed those portions of the completing ITAAC (beyond inspections, tests, or analyses. Items that remain that required by Section uncomplete for ITAAC closure should be accompanied 52.99(a)), would be by a clearly written description that describes how the problematic and would not add licensee expects to complete those portions of the value in terms of information to inspections, tests, or analyses and that subsequently the public, in part due to the concludes that the acceptance criteria will be met. The rapidly changing status of licensee should include enough detail on each ITAAC closures during the last inspection, test, or analysis for both completed and several months before fuel load. uncompleted portions to clearly indicate how it We plan to propose a revision completed, or will complete, those portions. The to NEI 08-01 guidance on the submittal should also include a schedule for completing 225-day uncompleted ITAAC the ITAAC and a list of references applicable to the letter later this year for ITAAC and available for NRC review. Appendix E to discussion with the NRC staff. NEI 08-01 presents examples of uncomplete Pending consideration of notifications.

revised guidance, NRC regulatory guidance need not and should not go beyond the existing regulations in this area.

13. It is not necessary to give Delete this sentence: Staff agrees. The references to program and system special emphasis to ITAAC Licensees are responsible for ensuring that these continuity during operation is beyond the scope of this Page 7, Maintenance requirements for programs maintain the validity of prior ITAAC regulatory guide. Referenced sentence will be deleted Paragraph 5 security and emergency conclusions on security and emergency preparedness as proposed. The paragraph, as revised after deleting 6

Section of Comment or Basis Recommendation NRC Resolution DG1250 beginning, preparedness programs and to support an affirmative 10 CFR 52.103(g) finding the sentence, continues to correctly identify the areas of The systems. Licensees understand and provide continuity after those programs and emergency preparedness and security to be included as regulation their responsibility to maintain systems are turned over to the operations staff. part of ITAAC maintenance.

the validity of all prior ITAAC conclusions.

Providing continuity after those programs and systems are turned over to the operations staff is beyond the scope of this regulatory guide.

14. Do not refer to required 10 Delete proposed from second sentence. Staff agrees. The entire regulatory guide has been CFR 52.99(c)(3) submittals as edited to remove proposed when referencing the rule.

Page 8, proposed Paragraph 4 beginning, Section 8.1.2

15. DG-1250 presents five None No action.

criteria/thresholds for Page 7, determining when an ITAAC Paragraph 5 post-closure notification is beginning, necessary, including material Section error or omission. The 8.1.2 industry does not object to treating material error or omission as a fifth notification threshold, and will plan to revise NEI 08-01 accordingly.

16. The industry has no objection None No action.

to the suggested clarification to 7

Section of Comment or Basis Recommendation NRC Resolution DG1250 Page 8, the ITAAC Maintenance PWV Paragraph 2, example, and we will revise beginning, NEI 08-01 accordingly.

Example:

17. We understand that the NRC Revise sentence 3 as follows: Staff agrees. The determination process for an ITAAC staff intends no difference with If that is the case, the licensee should make an ITAAC maintenance prompt notification is the same both before Page 8, the industry guidance on the maintenance prompt notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of and after the All ITAAC Complete notification is Paragraph 5, timing of post closure ITAAC determining that the determination of the new submitted, and the only difference is that the expected beginning, notifications after the all information exceeds a notification threshold, and time to submit will be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> instead of the 7 days Section ITAAC complete letter is should follow the format presented in Appendix G of expected for new information arising before an All 8.1.3 submitted. Thus we request NEI 08-01. Section 8.1.3 of NEI 08-01 recommends ITAAC Complete notification submittal. Sentence will that the NRC use identical that the licensee should evaluate new information or be revised as follows:

language to that provided in conditions expeditiously to determine if a notification NEI 08-01, Section 8.1.3. threshold is exceeded during this period before the 10 If that is the case, the licensee should make an ITAAC CFR 52.103(g) finding. maintenance prompt notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of determining that the new information exceeds a notification threshold, and should follow the format presented in Appendix G of NEI 08-01. Section 8.1.3 of NEI 08-01 recommends that the licensee should evaluate new information or conditions expeditiously to determine if a notification threshold is exceeded during this period before the 10 CFR 52.103(g) finding.

18. Replace the word initial with Revise sentence 2 as follows: Staff agrees. It is correct to refer to the notification as a Section 52.99(c)(1) After the licensee submits the initial Section Section 52.99(c)(1) closure notification instead of Page 9, 52.99(c)(1) closure notification on a common issue to initial. Sentence will be revised as follows:

Paragraph 3, the NRC, subsequent licensees could submit beginning, notifications referencing identical information; After the licensee submits the Section 52.99(c)(1)

ITAAC however, closure notification on a common issue to the NRC, closure subsequent licensees could submit notifications referencing identical information; however,

19. Clarify guidance on reference Revise last sentence in paragraph as follows: Staff agrees. The additional information clarifies field by one licensee to common After the licensee submits the initial closure activities, and also properly requests plant-specific 8

Section of Comment or Basis Recommendation NRC Resolution DG1250 Page 9, ITAAC closure information notification on a common issue to the NRC, information for acceptance criteria that are plant-Paragraph 3, submitted by another, including subsequent licensees could submit notifications specific, i.e., acceptance criteria requiring field beginning, what is meant by field referencing identical information; however, licensees activities. Sentence will be revised as follows:

ITAAC activities. must provide plant specific information concerning closure acceptance criteria that require field activities, such as After the licensee submits the Section 52.99(c)(1) inspection of as-built SSCs or testing to verify the closure notification on a common issue to the NRC, ability of installed SSCs to perform required subsequent licensees could submit notifications functions. referencing identical information; however, licensees must provide plant-specific information concerning acceptance criteria that require field activities, such as inspection of as-built SSCs or testing to verify the ability of installed SSCs to perform required functions.

20. Clarify paragraph to focus on The third sentence containing the reference to Staff agrees. Removal of the sentence that references assuring that performing standard industry practice is largely redundant to the standard industry practice does not detract from the P.9, inspections, test, or analyses at second. It may and should be deleted so the paragraph intent of the RG. The previous sentence in the RG Paragraph 6 other than the final installed reads as follows: includes a broader reference to technical justification beginning location is technically and standard industry practice is included under the Section 8.5 justifiable. To avoid confusion, Section 8.5 of NEI 08-01 includes guidance for NEI 08-01 topic of technical justifiability. Paragraph of the regulatory guide need not inspections, tests, or analyses performed at locations will be revised as follows:

mention standard industry other than final installed locations for licensees using practice, which, as discussed the definition of as -built provided in NEI 08-01. Section 8.5 of NEI 08-01 includes guidance for in NEI 08-01, is one aspect in For ITAAC that specify that the inspection, test, or inspections, tests, or analyses performed at locations assuring technical justifiability. analysis is to be performed as-built, licensees may other than the final installed locations for licensees using take credit for inspections, tests, or analyses the definition of as-built provided in NEI 08-01. For performed at locations other than the final installed ITAAC that specify that the inspection, test, or analysis location provided that it is technically justifiable to do is to be performed as built, licensees may take credit for so. In certain cases, and consistent with Section 8.5 of inspections, tests, or analyses performed at locations NEI 08-01, use of other than final in-place, as-built other than the final installed location provided that it is inspections, tests, or analyses to satisfy as-built technically justifiable to do so. NEI 08-01 provides ITAAC may be exercised when performing them guidance on when it is technically justifiable for the earlier is consistent with standard industry practice. licensee to take credit for inspections, tests, and analyses NEI 08-01 provides guidance on when it is technically performed at locations other than the final installed 9

Section of Comment or Basis Recommendation NRC Resolution DG1250 justifiable for the licensee to take credit for location for as-built ITAAC.

inspections, tests, and analyses performed at locations other than the final installed location for as-built ITAAC.

21. The summary description of Revise paragraph as follows: Staff disagrees with the proposed edits, but agrees to NEI 08-01, Appendix C, should Appendix C to NEI 08-01 generally describes revise the section. The proposed edits do not correctly Page 10, be revised to better reflect the common industry processes and practices used in describe NEI 08-01 Appendix C as it appears in Paragraph 3 intent of Appendix C. performing ITAAC-related activities. The purpose is Revision 4.

beginning to describe, in a general way, procedures, training and Appendix C NEI plans to clarify this intent other processes that are used in performing ITAAC to Paragraph will be revised as follows:

of Appendix C in the next aid members of the public in understanding ITAAC revision of NEI 08-01. Closure Notifications. ITAAC categories and Appendix C to NEI 08-01 generally describes common discusses categories such as calculations and analyses, industry processes and practices used in performing test procedures, special processes, inspection ITAAC-related activities of common acceptance criteria programs, code design reports from the American categories. These categories include calculations and Society of Mechanical Engineers, existing reports that analyses, test procedures, special processes, inspection conclude that acceptance criteria are met, programs, code design reports from the American procurement, material control, and training and Society of Mechanical Engineers, reports that exist and qualification. These discussions are intended to assist conclude that acceptance criteria are met, procurement, the licensee in preparing closure notifications or material control, training and qualification, and modular uncomplete notifications for each type of ITAAC construction and testing.

category.

22. Licensees apply a graded QA Revise last sentence in paragraph as follows: Staff disagrees. The proposed changes would limit the approach for SSCs identified as In particular, the licensee should adapt a graded QA scope of the original paragraph, and would incorrectly Page 10, significant contributors to plant approach for the construction and installation of the focus the discussion to SSC, and not performance of the Paragraph 4 safety per NUREG-0800, not ITAAC completion of nonsafety-related ITAAC and ITAAC as originally intended.

beginning In based on whether SSCs are ITAAC associated with the regulatory treatment of addition to ITAAC-related or not. nonsafety-related systems nonsafety-related SSCs that are significant contributors to plant safety to assure satisfactory performance and documentation of any 10

Section of Comment or Basis Recommendation NRC Resolution DG1250 associated ITAAC.

23. Licensees may perform Modify the 4th and 5th sentence as follows: Staff disagrees. The technical justification used to take inspections, tests, or analyses at credit for ITA performed at an other-than-final-installed Page 10, other than the final installed This also applies to the technical justification for location for an as-built ITAAC, including those Paragraph 5 location provided doing so is completing inspections, tests, or analyses if they are covered by the generic technical justifications contained beginning technically justified. NEI 08- performed at locations other than the final installed in NEI 08-01, should appear in the IDB, as this is Appendix D 01 provides generic technical location when those ITA are not covered by the material to sufficiently describe how the ITAAC was justifications for common generic technical justifications contained in NEI 08- completed.

situations where licensees are 01. In cases in where it is acceptable for the licensee expected to do so. Each to perform these inspections, tests, or analyses at ITAAC closure notification will locations other than the final installed location, but the reference NEI 08-01 as a source ITA are not covered by the generic technical of guidance and acceptable justifications contained in NEI 08-01, the licensee technical justifications. The must should document summarize the associated guidance in DG-1250 should be technical justification in the ITAAC Completion clarified to indicate that ITAAC Package and summarize it in the IDB of the closure closure notifications need to notification to establish that it has successfully summarize the technical completed the ITAAC in conformance with the justification for inspections, definition of as-built. This can include appropriately tests, or analyses performed at specific references to the generic technical other than the final installed justifications in Section 8.5 of NEI 08-01.

location only if the ITA are not covered by the generic technical justifications in NEI 08-01.

ITAAC closure notifications D-16 and D-17 in NEI 08-01 are examples that describe generically justified inspections (dimensional checks) performed at a fabrication facility, and reference to NEI 11

Section of Comment or Basis Recommendation NRC Resolution DG1250 08-01 is provided.

24. Appendix H presents examples Revise paragraph as follows: Staff agrees. Appendix H to NEI 08-01 contains to illustrate when a post-closure Appendix H to NEI 08-01 provides examples of examples for when post-closure notifications would be Page 11, ITAAC notification would or ITAAC maintenance. The examples are various required and also when post-closure notifications would Paragraph 5 would not be required. scenarios and events that show whether an ITAAC not be required. Paragraph will be revised as follows:

beginning post-closure notification would or would notlikely be Appendix H required. Appendix H to NEI 08-01 provides examples of ITAAC maintenance. The examples are various scenarios and events that show whether an ITAAC post-closure notification would or would not be required.

25. As discussed in public Revise Item 3 as follows: Staff agrees. The revision below clarifies the use of meetings, the industry plans to Use of Examples in NEI 08-01 templates versus examples in NEI 08-01. The Page 12, Item clarify the intent and use of examples will need to be further completed with details 3 templates versus examples NEI 08-01 includes examples for notifications that are specific to the actual situation encountered presented in NEI 08-01. In the required by 10 CFR 52.99. Although these examples during completion of the ITAAC. The reader should not meantime, the NRC regulatory are intended to templates for illustrate ing and assume that the examples can be used without guidance should avoid reinforce ing the guidance in NEI 08-01, the licensee modifying them for ITAAC completion activities that improperly mixing these terms. should not consider the NRCs endorsement of this are specific to a particular licensee.

industry guideline document a determination that each example applies to all licensees as it is presented and Item #3 will be revised as follows:

written in the guide. A licensee should ensure that an example applies to its particular circumstances before 3. Use of Examples in NEI 08-01 implementing the example guidance or template, as presenteddescribed. NEI 08-01 includes examples for notifications required by 10 CFR 52.99. Although these examples are intended to illustrate and reinforce the guidance in NEI 08-01, the licensee should not consider the NRCs endorsement of this industry guideline document a determination that each example applies to all licensees as it is presented and written in the guide. A licensee should ensure that an example applies to its particular circumstances before implementing it. The sufficient 12

Section of Comment or Basis Recommendation NRC Resolution DG1250 information, required by 10 CFR 52.99(c)(1), for any individual ITAAC closure notification can only be generically guided by the examples presented in NEI 08-01 Revision 4. Ultimately, sufficient information must be determined with respect to the specific facts surrounding each ITAAC performance and closure.

13