ML19318D161

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NRC Review and Endorsement of NEI 17-04, Model SLR New and Significant Assessment Approach for SAMA, Revision 1
ML19318D161
Person / Time
Site: Nuclear Energy Institute
Issue date: 11/12/2019
From: Earls C
Nuclear Energy Institute
To: Maureen Wylie
NRC/OCFO
smh
References
Download: ML19318D161 (2)


Text

CHRIS EARLS Senior Director Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202-739-8078 cee@nei.org www.nei.org November 12, 2019 Ms. Maureen E. Wylie Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Fee Exemption Request for Activities Performed for NRC Review and Endorsement of NEI 17-04, Model SLR New and Significant Assessment Approach for SAMA, Revision 1 Project Number: 689

Dear Ms. Wylie:

In a letter dated August 4, 2017, the U.S. Nuclear Regulatory Commission (NRC) staff approved a fee waiver request for NRC activities performed for the review and endorsement of NEI 17-04 Model SLR New and Significant Assessment Approach for SAMA, Revision 0. NEI 17-04 is a model approach for assessing the significance of new information that an applicant for renewal of a nuclear power reactor operating license or extension of a combined license is aware of and that may relate to either (1) the severe accident mitigation design alternatives (SAMDA) analysis or severe accident mitigation alternatives (SAMA) analysis documented in the NRCs final environmental statement (FES, FSEIS, or EA) that supported issuance pursuant to 10 CFR Part 50 (or Part 54) of the reactors initial (or renewed) operating license or (2) the SAMDA analysis documented in the NRCs final environmental statement (FES, FSEIS, or EA) that supported issuance pursuant to 10 CFR Part 52 of the reactors combined license and the design certification incorporated therein by reference, if any. Subsequent license renewal (SLR) applicants are required to perform this type of assessment and include the results in the applicants environmental report.

In a letter dated November 12, 2019, NEI is now asking for the NRC staffs endorsement of NEI 17-04, Revision 1 dated August 2019. NEI 17-04, Revision 1 reflects changes to address challenges that applicants and the NRC staff identified during preparation and processing of the evaluations in three lead plant SLR applications for significance of new information related to SAMA analyses. These changes clarify the definition of SAMAs to be analyzed in the first stage of the model approach (Stage 1) and clarify the processes that may be used in Stage 1 to estimate risk reduction.

The purpose of this letter is to request that the NRC's review of this guidance document and any subsequent revision of it be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. Like Revision 0, Revision 1 of this document meets the exemption requirement in 10 CFR 170.11(a)(1)(ii) in that it will

Ms. Wylie November 12, 2019 Page 2 assist the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins). The NRC is the primary beneficiary of this guidance as the NRC will use this document to support evaluation of environmental reports in SLR application submittals. In this case, the use of the guidance supports increased regulatory efficiency of agency efforts as it provides a consistent approach for implementing the requirements of 10 CFR Part 51, as it applies to license renewal.

Once endorsed by NRC, the use of this guidance supports increased regulatory efficiency of agency efforts as the methods evaluated under this process will be used by many licensees in completing and submitting SLR applications.

If you have any questions or require additional information, please contact me.

Sincerely, Chris Earls Cc: Robert Elliott, NMSS/REFS Jeffrey J. Rikhoff, NMSS/REFS Kevin Folk, NMSS/REFS Jerry Dozier, NMSS/REFS

` Document Control Desk, NRC