ML19290D206

Fee Exemption Request for NEI 11-08, Guidance on Evaluating and Submitting Security Plan Changes, Revision 2, Dated October 2019

ML19290D206
Person / Time
Site:	Nuclear Energy Institute
Issue date:	10/16/2019
From:	Gross W Nuclear Energy Institute
To:	Maureen Wylie NRC/OCFO
Hudson, Sharon
References
Download: ML19290D206 (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 October 16, 2019 Ms. Maureen E. Wylie Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Fee Exemption Request for NEI 11-08, Guidance on Evaluating and Submitting Security Plan Changes, Revision 2, Dated October 2019 Project Number: 689

Dear Ms. Wylie:

The Nuclear Energy Institute (NEI), 1 on behalf of its members, plans to submit NEI 11-08, Guidance on Evaluating and Submitting Security Plan Changes, Revision 2 for the U.S. Nuclear Regulatory Commissions (NRC) review and endorsement. Revision 2 of NEI 11-08 updates the previously endorsed Revision 0 and provides guidance for licensees to consider when making a determination relative to the appropriate licensing action under which change(s) to the security plans required under the provisions of 10 CFR Part 50, sections 50.34(c) and 50.34(d) can be made. This guidance is intended to assist the licensee in determining the appropriate licensing action for a specific security plan change and the types of information that should be identified, reviewed and analyzed to support the determination or conclusion that the security plan change meets the provisions of 10 CFR 50.90 or 50.54(p) prior to submitting the security plan to the NRC. NEI and its members are revising NEI 11-08 to include a step-by-step process for licensee use when evaluating and submitting all types of security plan changes and includes guidance on evaluating cyber security plan changes.

NEI requests that the NRC's review of NEI 11-08 and any future submissions of the guidance document be granted a fee waiver pursuant to the 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 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 E. Wylie October 16, 2019 Page 2 or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins). In this case, the revision of this guidance supports increased regulatory efficiency of agency efforts as it provides a consistent industry approach for the treatment of security plan changes that may also affect aspects of other regulatory processes. The NRC is the primary beneficiary of this guidance as the NRC has and will continue to use this document to support review of security plan revisions and the inspection efforts associated with 10 CFR 73.55.

If you have any questions or require additional information, please contact Lisa Hogg at (202) 739-8121 or lbh@nei.org.

Sincerely, William R. Gross c: Mr. Shana Helton, NSIR/DPCP