ML21266A065

NEI Presentation - ROP Public Meeting 09232021 (002)

ML21266A065
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/23/2021
From:	Nuclear Energy Institute
To:	NRC/SECY
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Download: ML21266A065 (8)

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©2021 Nuclear Energy Institute September 23, 2021 Feedback on proposed ROP changes

©2021 Nuclear Energy Institute

NEI understands the direction that NRC is headed with current strategy but we have questions on actions & engagement

We agree that there are improvements that could be gained through incorporation of operating experience including more recent experience

We agree that there are areas that were included in the SECYs that are no longer being recommended or were already completed We appreciate the opportunity to provide any new insights and provide perspectives on relative importance

SUMMARY

©2021 Nuclear Energy Institute

We do not see any new information that would change our position on the original recommendations

We acknowledge that use of licensee self-assessments are no longer being pursued

As a result of the NRC request during the last public meeting, NEI has identified an area that warrants additional consideration for the scope of the triennial fire protection inspection (TFPI)

The NEI fire protection task force will reach out to the applicable technical staff to discuss SECY-18-0113

©2021 Nuclear Energy Institute 4 NEI Fire Protection Task Force re-evaluated Fire Protection recommendations in SECY-18-0113 and SECY-19-0067 Attributes of the TFPI are redundant to attributes of other NRC inspections IP 71111.05, Fire Protection IP 71111.18, Plant Modifications IP 71111.21M, Design Basis Assurance Inspection (Team)

Continuing to see low numbers of Fire Protection findings based on industry performance Ready to engage NRC staff with the following recommendation:

Reallocate unique TFPI inspection criteria to CETI and IP 71111.05, Fire Protection TRIENNIAL FIRE PROTECTION INSPECTION (TFPI)

©2021 Nuclear Energy Institute

We do not see any new information that would change our position on the original recommendations

We do have some questions on actions and engagement SECY-19-0067

©2021 Nuclear Energy Institute September 23, 2021 Status of Plans for Reporting Guidance Applicable to Plants with Risk-Informed Licensing Bases

©2021 Nuclear Energy Institute

NEI task force is developing guidance on how to apply reporting requirements for licensees with risk-informed licensing bases

For example,

50.69(b)(1)(vii) and (viii) provide an explicit exemption to 10 CFR 50.72 and 50.73 respectively for RISC-3 and RISC-4 components

50.69(g) requires LER under 50.73(b) for any event or condition that prevented, or would have prevented, a RISC-1 or RISC-2 SSC from performing a safety significant function.

Other risk informed initiatives would also benefit from additional reporting guidance REPORTING GUIDANCE

©2021 Nuclear Energy Institute Actions complete/in-progress

Draft guidance developed

Initial regulatory affairs review completed

Industry operations tabletop performed

Incorporate feedback from tabletop -in progress Next Steps

NEI regulatory and legal review of updated draft guidance - Oct, 2021

NEI/NRC workshop - Late Fall

We are interested in engaging the NRC staff for feedback STATUS