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Category:Letter
MONTHYEARML24023A0392024-01-22022 January 2024 NEI Comments on the Information Collection Renewal for Domestic Licensing of Special Nuclear Material, Docket Id NRC-2023-0118 ML23355A1972023-12-14014 December 2023 NEI, Comments on NRC Draft Resolution of SFAQ 2022-02, SAE Program Requirements ML23219A1672023-10-25025 October 2023 Response Letter to Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07 ML23270B9002023-09-27027 September 2023 NEI Letter Request for an Extension of Comment Period on Proposed Revision to Standard Review Plan Section 15.0, Introduction - Transient and Accident Analyses, Docket Id NRC 2023 0079 ML23268A0102023-09-22022 September 2023 NEI, Fee Exemption Request for Endorsement, Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors ML23241A8612023-08-25025 August 2023 Consolidated Industry Comments to NRC Regulatory Issue Summary 2023-02, Scheduling Information for the Licensing of Accident Tolerant, Increased Enrichment, and Higher Burnup Fuels ML23236A4992023-08-24024 August 2023 Industry Feedback on Region II Fuel Cycle Facility Construction Oversight Workshop Held August 15, 2023, and Suggested Topics for Additional Public Meetings in Fall 2023 ML23256A1622023-08-0101 August 2023 Incoming NEI Letter Dated August 1, 2023 Regarding Increase in Fees 2023-2025 ML23206A0292023-07-24024 July 2023 Incoming Fee Exemption Request for Pre-Submittal Activities, Review, and Endorsement of NEI 20-07 ML23143A1232023-06-22022 June 2023 NRC Fee Waiver Request for Draft NEI 23-01 ML23200A1662023-05-30030 May 2023 NEI Proposed Metrics for a Performance-Based Emergency Preparedness Program ML23116A0732023-05-25025 May 2023 Letter to Hillary Lane in Response to a Request for a Fee Exemption for NEI 23-03 ML23135A7332023-05-0909 May 2023 NEI Comments on NRC Safety Culture Program Effectiveness Review ML23110A6752023-04-18018 April 2023 04-18-23_NRC_Fee Waiver for NEI 23-03 ML23110A6782023-04-18018 April 2023 Request for Review and Endorsement of NEI 23-03, Supplemental Guidance for Application of 10 CFR 50.59 to Digital Modifications at Non-Power Production or Utilization Facilities ML23110A6762023-04-18018 April 2023 04-18-23_NRC_NEI 23-03 Review + Endorse ML23107A2302023-03-31031 March 2023 NEI Letter, to Andrea Veil, NRC, Regarding Industry Recommendations for a 10 CFR 50.46a/c Combined Rulemaking ML23138A1662023-03-24024 March 2023 Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 ML23083B4622023-03-24024 March 2023 Transmittal of NEI 22-05 Revision a, Technology Inclusive Risk Informed Change Evaluation (Tirice) Guidance for the Evaluation of Changes to Facilities Utilizing NEI 18-04 and NEI 21-07 ML23060A3272023-03-0101 March 2023 NEI, Wireless Cyber Security Guidance ML23060A2142023-03-0101 March 2023 NEI, Request for NRC Endorsement of NEI White Paper, Enabling a Remote Response by Members of an Emergency Response Organization, Revision 0 ML23023A2752023-01-23023 January 2023 Request for Extension of Comment Period from the Nuclear Energy Institute on PRM-50-124 - Licensing Safety Analysis for Loss-of-Coolant Accidents ML22348A1122023-01-17017 January 2023 Letter to Richard Mogavero Response to Fee Exemption NEI 08-09 Revision 7 ML22353A6082023-01-11011 January 2023 U.S. Nuclear Regulatory Commission Report of the Regulatory Audit of the NEI-Proposed Aging Management Program Revision to Selective Leaching Program (XI.M33) ML22349A1012022-12-12012 December 2022 LTR-22-0343 Ellen Ginsberg, Sr. Vice President, General Counsel and Secretary, Nuclear Energy Institute, Expresses Concerns Related to Issuance of Regulatory Issue Summary 2022-02; Operational Leakage ML22336A0372022-11-16016 November 2022 Fee Exemption Request for NEI 08-09 Revision 7 - Changes to NEI 08-09 Cyber Security Plan for Nuclear Power Reactors ML22321A3152022-11-16016 November 2022 NEI Letter with Comments on Significance Determination Process Timeliness Review ML22298A2262022-10-25025 October 2022 Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated October 2022 ML22298A2302022-10-17017 October 2022 Submittal of NEI 22-03, Draft Revision 0, Nuclear Generation Quality Assurance Program Description ML22207B6512022-07-26026 July 2022 NEI, Full Fee Exemption Request for Industry Guidance Proposal - Weather Related Administrative Controls During Transient Outdoor Dry Cask Operations ML22195A1662022-07-14014 July 2022 NEI, Draft G of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 ML22195A0202022-07-13013 July 2022 07-13-22 NRC Fee Exemption Request for NEI 21-05 Review ML22195A0672022-07-13013 July 2022 Fee Exemption Request for Review and Meeting to Discuss Draft Nuclear Energy Institute Technical Report NEI 21-05, Reporting Guidance for Licensees with Risk-Informed Licensing Bases ML22159A2772022-06-28028 June 2022 Response Letter to Richard Mogavero for Fee Exemption for the Nuclear Regulatory Commission Review Ad Endorsement of NEI 15-09, Revision 1 ML22153A2782022-06-0202 June 2022 Nie, Fee Exemption Request for Endorsement of NEI 15-09, Cyber Security Event Notifications, Revision 1, Dated May 2022 ML22154A2962022-06-0202 June 2022 LTR from R. Mogavero to M. Sampson Dated Jun 2 2022 Endorsement of NEI 15-09 Cyber Security Event Notifications Rev 1 Dated May 2022 ML22152A2712022-06-0101 June 2022 Digital Instrumentation and Control Common Cause Failure Policy Considerations, Revision 1 ML22143A9362022-05-20020 May 2022 May 13, 2022, Public Meeting on Draft Regulatory Issue Summary Operational Leakage, 87 Fed. Reg. 2361 (Jan. 14, 2022) (Docket Id NRC-2021-0173) ML22110A1752022-05-0303 May 2022 NRC Response to the Nuclear Energy Institute April 1, 2022, Letter, Regarding the Nrc'S CUI Implementation Plan ML22109A2082022-04-0808 April 2022 April 8, 2022, NEI White Paper on Digital Instrumentation and Control Common Cause Policy Considerations Version 2.0 ML22110A1782022-04-0101 April 2022 April 1, 2022, Letter from NEI Regarding Nrc'S Controlled Unclassified Information Program Implementation ML22048A5812022-02-16016 February 2022 NEI 22-02: Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations ML22019A2922022-01-12012 January 2022 NEI, Submittal of Proposed Revisions to Aging Management Programs XI.M33, Selective Leaching and XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements ML21343A2922021-12-0808 December 2021 NEI, Transmittal of NEI 21-07 Revision 0-B, Technology Inclusive Guidance for Non-Light Water Reactor Safety Analysis Report: for Applicants Utilizing NEI 18-04 Methodology ML21337A3802021-12-0303 December 2021 NEI Technical Report NEI 17-06 - Guidance on Using Iec 61508 SIL Certification to Support the Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Related Applications, Revision 1 ML21319A3522021-11-10010 November 2021 NRC NEI Fee Waiver Request Changes to NEI 10-04 and NEI 13-10, Dated November 10, 2021 ML21306A3652021-10-29029 October 2021 NEI Letter from D. Young to NRC S. Atack to Cease Work on Draft D of NEI 20-05, Methodological Approach and Considerations for a Technical Analysis to Demonstrate Compliance with the Eligibility Criteria of 10 CFR 73.55(a)(7) ML21342A1682021-10-29029 October 2021 Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 10-04, Identifying Systems and Assets Subject to the Cyber Security Rule, Revision 3, Dated October 29, 2021 ML21342A2032021-10-29029 October 2021 Letter from W. Gross to S. Atack, Endorsement of Nuclear Energy Institute 13-10, Cyber Security Control Assessments, Revision 7, Dated October 29, 2021 ML22081A2002021-10-29029 October 2021 NEI Backfitting Concerns with NRCs Developing Position on Protection of Dry Storage Systems from Natural Phenomena During Short Term Operations 2024-01-22
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MARIA KORSNICK President and Chief Executive Officer 1201 F Street NW, Suite 1100 Washington, DC 20004 P: 202.739.8187 mgk@nei.org nei.org March 19, 2020 The Honorable Steven T. Mnuchin The Honorable Lawrence A. Kudlow Secretary of the Treasury Assistant to the President for Economic Policy U.S. Department of the Treasury and Director of the National Economic Council 1500 Pennsylvania Avenue, N.W. The White House Washington, D.C. 20220 Washington, D.C. 20500
Subject:
Nuclear Industry Recommendations for Economic Recovery
Dear Secretary Mnuchin and Director Kudlow:
The U.S. nuclear energy industry is committed to working with the administration to provide clean, reliable and affordable electricity as the nation addresses the COVID-19 crisis.
On behalf of the NEI member companies 1 who operate, service and supply reactors across the country, let me express our deepest appreciation for the commitment that the President, the Vice President, and you have demonstrated to ensuring that our nations workers and businesses have the support they need during this difficult time. Our member companies are anticipating - or are already experiencing - severe financial strain as product orders are delayed or canceled, as industrial electricity demand falls, and as workforce availability becomes increasingly constrained. To help in addressing these near-term challenges, we have identified specific policy and legislative proposals that would be of immediate benefit in helping the people and the companies of our nations nuclear energy sector to withstand the ongoing operational and economic disruption:
Enabling essential support for nuclear infrastructure - As advocated by the Edison Electric Institute, lifeline sectors including the nuclear power industry may need to share 1
NEI is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants on the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
The Secretary of the Treasury and the Director of the National Economic Council March 19, 2020 Page 2 essential personnel, including line and field workers, control room operators, and anyone else deemed essential, to address workforce shortages. Advanced-approved travel and regulatory waivers will be essential to the timely movement and sharing of personnel, especially when crossing state or local county lines. Any federal, state, or local travel restriction declarations must accommodate the timely and secure movement of lifeline sector assets and essential personnel. Additionally, critical employees - employees with day-to-day responsibility to maintain the operation and reliability of critical infrastructure including ongoing and planned refueling of reactors - should have prioritized access to (1) testing; (2) anti-viral and other treatments for sick individuals; (3) vaccines, when vaccines are tested and proven safe for the public; and (4) personal protective equipment such as N95 respirator masks, Tyvek suits, and nitrile gloves.
Provide grants for COVID-19-related paid leave - Authorize the Secretary of Energy to provide grant assistance to project owners of large critical infrastructure projects utilizing Department of Energy loan guarantees to defray the costs of paid leave granted to employees to address work interruptions related to COVID-19. This is necessary to ensure workforce and project continuity at the Plant Vogtle 3 and 4 nuclear construction site in Waynesboro, Georgia.
Incentivize investments in resilient nuclear generation - Supporting near-term investments in the operation and maintenance of nuclear power reactors will ensure their availability to provide around-the-clock electricity for up to 24 months at a time. The bipartisan Nuclear Powers America Act (H.R. 2314/S.1134) would provide a 30 percent investment tax credit for certain expenditures, helping to ensure the financial viability of the nations nuclear fleet which provides nearly 20% of Americas electricity. As was done under Section 1603 of the American Recovery and Reinvestment Tax Act of 2009, these credits should be convertible to payments in lieu of tax credits.
Provide temporary regulatory fee relief - Various agencies, including the U.S. Nuclear Regulatory Commission, the Federal Emergency Management Agency, the Federal Energy Regulatory Commission, and the U.S. Army Corps of Engineers, collect fees from licensees to offset their operating budgets. These fees amount to approximately $15 million annually for a typical two-unit nuclear power station. Temporarily waiving these fees will result in expeditious savings for consumers as well as increased revenues that can be invested by industry for various capital needs. 2 2
As a general matter, regulatory enforcement-related fees should not be waived.
The Secretary of the Treasury and the Director of the National Economic Council March 19, 2020 Page 3 As the longer-term ramifications of the COVID-19 crisis become more clear, we expect to identify additional nuclear energy sector needs. We will also work with our members to identify opportunities for the nuclear energy sector to contribute to our nations economic recovery. But recognizing the need for a prompt response, the four proposals identified above, if enacted, would have an immediate and extremely beneficial effect on the workers and the companies across the nations nuclear energy sector. We urge your support for these proposals, and we stand ready to work with you to ensure our nations energy needs are met safely, reliably and affordably - today, tomorrow, and for the long-term.
Sincerely yours, Maria Korsnick c: The Honorable Mitch McConnell, Majority Leader, U.S. Senate The Honorable Charles Schumer, Democratic Leader, U.S. Senate The Honorable Nancy Pelosi, Speaker, U.S. House of Representatives The Honorable Kevin McCarthy, Republican Leader, U.S. House of Representatives The Honorable Dan Brouillette, Secretary of Energy