ML050680572

Letter to NEI on Submittal and Request for Fee Waiver

ML050680572
Person / Time
Site:	Nuclear Energy Institute, PROJ0669
Issue date:	03/11/2005
From:	Berkow H NRC/NRR/DLPM/LPD4
To:	Pietrangelo A Nuclear Energy Institute
Alexion T W, NRR/DLPM, 415-1326
References
Download: ML050680572 (6)

Text

March 11, 2005 Anthony R. Pietrangelo Senior Director, Risk Regulation Nuclear Generation Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

SUBMITTAL AND REQUEST FOR WAIVER OF NRC REVIEW FEES FOR TOPICAL REPORT, "GUIDELINE FOR PERFORMING DEFENSE-IN-DEPTH AND DIVERSITY ASSESSMENTS FOR DIGITAL UPGRADES: APPLYING RISK-INFORMED AND DETERMINISTIC METHODS"

Dear Mr. Pietrangelo:

By letter dated February 22, 2005, you submitted the subject topical report (TR) for U.S. Nuclear Regulatory Commission (NRC) review and to request a waiver of NRC review fees. The subject TR is Electric Power Research Institute 1002835, dated December 2004.

By letter dated June 15, 2004, from Herbert Berkow (NRC) to Alex Marion (NEI), the NRC provided guidance on the need for pre-submittal meetings. As indicated in that letter, we believe that pre-submittal meetings are an important step in an efficient and effective TR review process. However, we have not had a pre-submittal meeting for this TR.

Therefore, our current plan is that we would treat this submittal as a draft, have the pre-submittal meeting, and give you feedback at the meeting (i.e., to the extent possible, identify any concerns about the viability or completeness of the TR) for you to consider before revising and submitting the TR formally. Once we receive your revised TR, it would be treated as the "initial" submittal and the staff would then perform the fee-waiver review and acceptance review, in accordance with our established process. In accordance with that process, we will not expend any resources on the acceptance review until we make a determination on the fee-waiver request, unless you indicate in your submittal letter that you would be willing to pay for the staff's acceptance review effort in the event that your fee-waiver request is not approved.

Section 170.21 of Title 10 of the Code of Federal Regulations requires that TRs be subject to fees based on the full cost of the review. Therefore, staff time spent on pre-submittal meetings will be billed accordingly.

Sincerely,

/RA/

Herbert N. Berkow, Director Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Project Nos. 669 and 689 cc: See next page

March 11, 2005 Anthony R. Pietrangelo Senior Director, Risk Regulation Nuclear Generation Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

SUBMITTAL AND REQUEST FOR WAIVER OF NRC REVIEW FEES FOR TOPICAL REPORT, "GUIDELINE FOR PERFORMING DEFENSE-IN-DEPTH AND DIVERSITY ASSESSMENTS FOR DIGITAL UPGRADES: APPLYING RISK-INFORMED AND DETERMINISTIC METHODS"

Dear Mr. Pietrangelo:

By letter dated February 22, 2005, you submitted the subject topical report (TR) for U.S. Nuclear Regulatory Commission (NRC) review and to request a waiver of NRC review fees. The subject TR is Electric Power Research Institute 1002835, dated December 2004.

By letter dated June 15, 2004, from Herbert Berkow (NRC) to Alex Marion (NEI), the NRC provided guidance on the need for pre-submittal meetings. As indicated in that letter, we believe that pre-submittal meetings are an important step in an efficient and effective TR review process. However, we have not had a pre-submittal meeting for this TR.

Therefore, our current plan is that we would treat this submittal as a draft, have the pre-submittal meeting, and give you feedback at the meeting (i.e., to the extent possible, identify any concerns about the viability or completeness of the TR) for you to consider before revising and submitting the TR formally. Once we receive your revised TR, it would be treated as the "initial" submittal and the staff would then perform the fee-waiver review and acceptance review, in accordance with our established process. In accordance with that process, we will not expend any resources on the acceptance review until we make a determination on the fee-waiver request, unless you indicate in your submittal letter that you would be willing to pay for the staff's acceptance review effort in the event that your fee-waiver request is not approved.

Section 170.21 of Title 10 of the Code of Federal Regulations requires that TRs be subject to fees based on the full cost of the review. Therefore, staff time spent on pre-submittal meetings will be billed accordingly.

Sincerely,

/RA/

Herbert N. Berkow, Director Project Nos. 669 and 689 Project Directorate IV Division of Licensing Project Management cc: See next page Office of Nuclear Reactor Regulation DISTRIBUTION:

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RidsNrrDlpm (TMarsh) RidsOgcRp RidsNrrDlpmLpdiv (HBerkow) RidsAcrsAcnwMailCenter ACCESSION NO.: ML050680572 NRR-106 OFFICE PDIV-1/PM PDIV-1/LA PDIV-2/SC PDIV/D NAME TAlexion LFeizollahi RGramm HBerkow for DBaxley DATE 3/11/05 3/11/05 3/11/05 3/11/05 OFFICIAL RECORD COPY

Electric Power Research Institute Project No. 669 cc:

Mr. David J. Modeen Vice President and Chief Nuclear Officer EPRI 1300 W. T. Harris Boulevard Charlotte, NC 28262 Mr. James Lang, Director EPRI 1300 W.T. Harris Boulevard Charlotte, NC 28262 Mr. Warren Bilanin, Director EPRI 3412 Hillview Avenue Palo Alto, CA 94304 Mr. Alexander Marion Senior Director, Engineering Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. Gary L. Vine, Executive Director Federal and Industry Activities, Nuclear Sector EPRI 2000 L Street, NW, Suite 805 Washington, DC 20036

Nuclear Energy Institute Project 689 cc:

Ms. Lynette Hendricks, Director Licensing Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. Michael Shoppman Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Mr. Pedro Salas -

Licensing & Industry Affairs Manager Tennessee Valley Authority P.O. Box 2000, OPS 4C-SQN Soddy Daisy, TN 37384 Ms. Barbara Lewis Assistant Editor Platts, Principal Editorial Office 1200 G St., N.W., Suite 1100 Washington, DC 20005 Mr. Gary Welsh Institute of Nuclear Power Operations Suite 100 700 Galleria Parkway, SE Atlanta, GA 30339-5957