ML18002A496

NEI Fee Exemption Request for NEI 03-12 Template for the Security Plan Training and Qualification Plan Safeguards Contingency Plan and Independent Spent Fuel Storage Installation Security Plan, Section 21, Compensatory Measures

ML18002A496
Person / Time
Site:	Nuclear Energy Institute
Issue date:	01/02/2018
From:	Gross W Nuclear Energy Institute
To:	Maureen Wylie NRC/OCFO
Hudson, Sharon
References
NEI 03-12
Download: ML18002A496 (2)

Text

WILLIAM R. GROSS Director, Incident Preparedness 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8123 wrg@nei.org nei.org January 2, 2018 Ms. Maureen E. Wylie Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Fee Exemption Request for NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, [and Independent Spent Fuel Storage Installation Security Plan], Section 21, Compensatory Measures Project Number: 689

Dear Ms. Wylie:

The Nuclear Energy Institute (NEI) 1, on behalf of the nuclear energy industry, will be submitting a revised Section 21, titled Compensatory Measures for NRC review and endorsement. The revision of Section 21, Compensatory Measures of NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, [and Independent Spent Fuel Storage Installation Security Plan], will allow licensee implementation changes that will improve the overall effectiveness and efficiency of using compensatory measures when required. NEI 03-12 is the current NRC staff-endorsed guidance that establishes a generic Security Plan template and acts as the licensing basis for licensees to meet the requirements set forth in 10 CFR 73.55. Where necessary, conforming changes of the editorial nature were made throughout NEI 03-12 to reflect updates in Section 21 (e.g., page numbering).

NEI requests that the NRC's review of the revised Section 21, including any subsequent submittals necessary to address NRC review comments, as well as supporting document, NEI White Paper; Conducting a Risk Assessment to Support Selection of Compensatory Measures be granted a fee waiver pursuant to the 1

The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

Ms. Maureen Wylie January 2, 2018 Page 2 provisions of 10 CFR 170.11. This document meets the exemption requirement in 10 CFR 170.11(a) (1) (ii) in that it will assist the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins). In this case, NRC review and endorsement of the revised Section 21 will facilitate a consistent industry approach to the assessment and implementation of compensatory measures, and thereby increase the efficiency of related regulatory activities such as the review of Security Plan revisions and inspections associated with 10 CFR 73.55.

If you have any questions or require additional information, please contact AJ Clore at (202) 739-8025; ajc@nei.org or me.

Sincerely, William R. Gross c: Mr. James W. Andersen, NSIR/DSP, NRC Mr. David Curtis, NSIR/DSP, NRC Ms. Alison L. Rivera, NSIR/DSP, NRC NRC Document Control Desk