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Category:General FR Notice Comment Letter
MONTHYEARML24200A1852024-07-17017 July 2024 Comment (1) of Frances A. Pimentel on Draft Regulatory Guides: Design-Basis Floods for Nuclear Power Plants and Guidance for Assessment of Flooding Hazards Due to Water Control Structure Failures and Incidents ML24173A0042024-06-14014 June 2024 Comment (1) of Individual on Draft NUREG: Event Report Guidelines ML24173A0052024-06-14014 June 2024 Comment (2) of Tony Brown on Behalf of Nuclear Energy Institute (NEI) on Draft NUREG: Event Report Guidelines ML24114A0252024-04-0808 April 2024 Comment (4) of Charlotte Shields on DG-5080 Uas Question ML24009A0372023-12-13013 December 2023 Comment (2) of Bruce Montgomery on Draft DUWP-ISG-02, Radiological Survey and Dose Modeling of the Subsurface to Support License Termination ML23353A2442023-12-13013 December 2023 Comment (2) of Bruce Montgomery on Interim Staff Guidance on Subsurface Investigations, Radiological Survey and Dose Modeling of the Subsurface to Support License Termination ML23348A0732023-12-11011 December 2023 Comment (2) of Charlotte Shields on Behalf of Nuclear Energy Institute on Draft Regulatory Guide: Physical Security Event Notifications, Reports, and Records ML23348A0772023-12-11011 December 2023 Comment (1) of Charlotte Shields on Behalf of Nuclear Energy Institute on Draft Regulatory Guide: Preemption Authority, Enhanced Weapons Authority, and Firearms Background Checks ML23349A0442023-12-11011 December 2023 Comment (1) of Charlotte Shields on Draft Regulatory Guide: Suspicious Activity Reports ML23326A1172023-11-21021 November 2023 Comment (1) of Alan Campbell on Proposed Revision to Standard Review Plan Branch Technical Position 7-19, Guidance for Evaluation of Defense-In-Depth and Diversity to Address Common-Cause Failure Due to Latent Design Defects in Digital Safe ML23326A0312023-11-17017 November 2023 Comment (2) of Kati R. Austgen on Draft Regulatory Guide: General Site Suitability Criteria for Nuclear Power Stations ML23284A3892023-10-10010 October 2023 Comment (8) of Ben Holtzman on Guidance for a Technology-Inclusive Content of Application Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Advanced Reactors ML23270B9552023-09-27027 September 2023 Comment (2) of Stewart Yuen on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses ML23242A0412023-08-25025 August 2023 Comment (2) of Brett Titus on Behalf of NEI on Draft NUREG: Revision to Subsequent License Renewal Guidance Documents, and Supplement to Associated Technical Bases Document ML23236A5292023-08-21021 August 2023 Comment (6) of Bruce S. Montgomery on Draft Interim Staff Guidance: Use of the Decommissioning Trust Fund During Operations for Major Radioactive Component Disposal ML23256A1122023-08-10010 August 2023 Comment (3) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1132023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1152023-08-10010 August 2023 Comment (2) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1162023-08-10010 August 2023 Comment (1) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1192023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1202023-08-10010 August 2023 Comment (2) of Ben Holtzman on Behalf of Nuclear Energy Institute on Draft Interim Staff Guidance: Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications-Roadmap ML23256A1222023-08-10010 August 2023 Comment (5) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1232023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23256A1252023-08-10010 August 2023 Comment (4) of Ben Holtzman on Behalf of Nuclear Energy Institute on Draft Interim Staff Guidance: Review of Risk-Informed, Technology Inclusive Advanced Reactor Applicationsroadmap ML23234A0392023-08-10010 August 2023 Comment (4) of Ben Holtzman on Review of Risk-Informed, Technology Inclusive Advanced Reactor Applications - Roadmap ML23181A0292023-06-29029 June 2023 Comment (2) of Rod Mccullum on Draft Regulatory Guide: Weather-Related Administrative Controls at Independent Spent Fuel Storage Installations ML23174A0492023-06-16016 June 2023 Comment (2) of Ben Holtzman on Behalf of Nuclear Energy Institute on Draft Interim Staff Guidance: Review of Risk-Informed, Technology Inclusive Advanced Reactor Applicationsroadmap ML23158A2162023-06-0202 June 2023 Comment (2) of Alan Campbell on Draft Regulatory Guide: Guidelines for Lightning Protection for Production and Utilization Facilities ML23159A2472023-05-22022 May 2023 Comment (4) of William Gross on Perimeter Intrusion Alarm Systems ML23143A1982023-05-18018 May 2023 Comment (1) of Richard Mogavero on Behalf of Nuclear Energy Institute on Draft Regulatory Guide: Cybersecurity Event Notifications ML23130A2082023-05-0808 May 2023 Comment (9) of Mark A. Richter on Behalf of Nuclear Energy Institute on Material Compatibility for Non-Light Water Reactors ML23115A0152023-04-0707 April 2023 Comment (1) of Alan Campbell on Draft Regulatory Guide: Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants ML24120A2702023-04-0404 April 2023 Melody Rodridguez NEI Comment on Controlled Unclassified Information ML23089A0012023-03-28028 March 2023 OMB 3150-0035, NEI Comment on 10 CFR Part 21 Information Collection Renewal 2023 ML23094A0632023-03-28028 March 2023 NRC-2022-0145- NEI Official Comment Attachment on 10 CFR Part 21 Information Collection Renewal ML23115A0172023-03-23023 March 2023 Comment (3) of Alan Campbell on Draft Regulatory Guide: Criteria for Programmable Digital Devices in Safety-Related Systems of Nuclear Power Plants ML23074A0472023-03-14014 March 2023 Comment (2) of A. J. Clore on Perimeter Intrusion Alarm Systems ML22354A2422022-12-19019 December 2022 Comment (4) of Thomas Basso on Behalf of Nuclear Energy Institute on Performance-Based Containment Leak Test Program ML23005A2412022-12-16016 December 2022 Comment (1) of Janet R. Schlueter on Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities ML22244A1732022-08-31031 August 2022 Comment (1) of Tony Brown on Behalf of Nuclear Energy Institute on Industry Comments on Draft Appendices to NUREG/BR-0058, Revision 5, Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission ML22242A0302022-08-29029 August 2022 Comment (1) of Victoria K. Anderson on High Energy Arcing Fault Hazard Frequency and Consequence Modeling ML22231B0532022-08-19019 August 2022 Comment (6) of James E. Slider on Nrc'S Fiscal Years 2023-2027 Artificial Intelligence Strategic Plan ML22230A0402022-08-15015 August 2022 Comment (4) of William R. Gross on Behalf of NEI on Update of Facility Security Clearance ML22224A1942022-08-12012 August 2022 Comment (1) of William R. Gross on Behalf of Nuclear Energy Institute on Personnel Access Authorization Requirements for Non-Immigrant Foreign Nationals Working at Nuclear Power Plants ML22174A0722022-06-21021 June 2022 Comment (11) of Frances A. Pimentel on Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Plants ML22174A3422022-06-21021 June 2022 Comment (2) of Victoria K. Anderson on Level 3 PRA Project Documentation (Volume 3x) ML22165A2082022-06-13013 June 2022 Comment (2) of Victoria K. Anderson on Draft Research Information Letter Reports Determining the Zone of Influence for High Energy Arcing Faults Using Fire Dynamics Simulator, and Predicting High Energy Arcing Fault Zones of Influence for ML22145A2992022-05-23023 May 2022 Comment (2) of Victoria K. Anderson on Acceptability of Probabilistic Risk Assessment Results for Advanced Non-Light Water Reactor Risk-Informed Activities ML22152A0632022-05-23023 May 2022 Comment (1) of Kati R. Austgen on Safety Review of Light-Water Reactor Construction Permit Applications ML22124A0812022-05-0202 May 2022 Comment (3) of Richard Mogavero on Cyber Security Programs for Nuclear Power Reactors 2024-07-17
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Page 1 of 1 As of: 2/15/18 2:44 PM Received: February 12, 2018 Status: Pending_Post PUBLIC SUBMISSION Tracking No. lk2-91gm-le2s Comments Due: February 12, 2018 Submission Type: Web Docket: NRC-2017-0185 Unified Agenda of Federal Regulatory and Deregulatory Actions Comment On: NRC-2017-0185-0001 Unified Agenda of Federal Regulatory and Deregulatory Actions; Semiannual Regulatory Agenda Document: NRC-2017-0185-DRAFT-0002 Comment on FR Doc# 2017-28246 Submitter Information j;~J~1R Name: John Butler Submitter's Representative: Anya Barry f"-3 r IL cJ-c) If' Organization: Nuclear Energy Institute
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General Comment l.}__J See attached file(s)
Attachments 02-12-18_NRC _NEI Comments on Unified Agenda SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 */A \
Add= (!. 8/-r!cl':Y~ l /J {p) https://www.fdms.gov/fdms/getcontent?object1d=0900006482fld6f8&format=xml&showorig=false 02/15/2018
JOHN C. BUTLER Senior Technical Advisor 1201 F Street, NW, Suite 1100 Washington, DC 20004
~I NUCLEAR ENERGY INSTITUTE P: 202.739.8108 jcb@nei.org nei.org February 12, 2018 Ms. Cindy K. Bladey Office of Nuclear Materials Safety and Safeguards US Nuclear Regulatory Commission Washington, DC 20555-0001 Submitted via Regulations.gov
Subject:
Comments on Unified Agenda of Federal Regulatory and Deregulatory Actions (Federal Register Vol 83, 2018, dated January 12, 2018; Docket ID NRC-2017-0185)
Project Number: 689
Dear Ms. Bladey:
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 1 appreciates the opportunity to provide comments on the Unified Agenda of Federal Regulatory and Deregulatory Actions published in the subject Federal Register notice. Our review of the NRC regulatory agenda and underlying regulatory processes has focused on identifying measures necessary to ensure that the NRC conducts the rulemaking process in an efficient and transparent manner, accounts for the cumulative effects of regulation, and appropriately incorporates stakeholder input throughout the process.
The Unified Agenda of Federal Regulatory and Deregulatory Action identifies 53 active and long-term 2
rulemaking activities. A more recent listing of rulemakings, provided on the NRC public website , identifies 57 rulemakings. The average age of these rulemaking activities is 4.4 years. In the previous 12 months, as reflected in the Spring 2017 and Fall 2017 Agenda, twenty rulemaking activities were completed.
Discontinued rulemakings constituted 30o/o of the completed activities and 40% were amendments to the list of approved spent fuel storage casks. A significant portion of the remaining 30% was a combination of administrative and non-discretionary activities. The total rulemaking budget for fiscal year 2018 is $2.431 million and 87 full-time equivalents (FTE) 3 *
- 1 NEI is the organization responsible for establishing unified nuclear industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include utilities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel fabrication facilities, materials licensees, and other organizations and individuals involved in the nuclear energy industry.
2 https://www.nrc.gov/reading-rm/doc-collections/rulemaking-ruleforum/active/Rulelndex.html 3
NUREG-1100, Volume 33, "Congressional Budget Justification, Fiscal Year 2018" NUCLEAR. CLEAN AIR ENERGY
Ms. Cindy Bladey February 12, 2018 Page 2 The high percentage of discontinued rulemakings, while welcomed, calls into question the efficacy of the current proces? for initiating rulemaking activities. The high average age and significant staff hours expended on rulemakings both point to a need to improve prioritization and oversight efforts. The changes in the rulemaking process resulting from SECY-15-0129, Commission Involvement in Early Stages of Rulemaking, are expected to provide greater oversight on rulemaking efforts; however, additional changes may be warranted.
As noted in the Federal Register notice, the NRC has a process for developing rulemaking budget estimates and determining the relative priorities of rulemaking projects during budget formulation. The "Common Prioritization of Rulemaking" (CPR) process considers four factors and assigns a score to each factor. Those factors include:
Factor A. Support for the NRC's strategic plan goals Factor B. Support for cross-cutting strategies that cross cut and support safety and security objectives Factor C. A governmental factor representing interest to the NRC, Congress or other governmental bodies Factor D. An external factor representing interest to the public, non-governmental organizations, and the nuclear industry.
The CPR factors are determined in a qualitative manner through committee discussion. For Factor A, as an example, the process assesses whether a rulemaking activity supports either the NRC strategic plan goal for safety and/or the strategic plan goal for security with little discrimination among issues as to the level of support offered. A review of CPR scores for Factor A shows that 50% of current regulatory actions received a High score (value between 14 and 20).
The industry believes that there would be benefit in having review criteria for each of the prioritization factors and that these review criteria should be focused on the benefit provided by the proposed chahge (i.e., ti benefit) vs. the benefit of regulation. In addition, the review criteria should take'into account the cost and burden imposed by the proposed regulation. This refinement of the prioritization process would assist the review process by encouraging greater discrimination among assigned scores and would assure that the focus of NRC and industry attention and resources are on those issues that provide the greatest safety and security benefit. There is an opportunity to update the CPR review criteria as part of the effort to reflect recent changes to the NRC Strategic Plan: Fiscal Years 2018-2022.
Please contact me if you have any questions regarding these comments.
Sincerely;
~~
John C. Butler