ML20141L501

Comment (1) of Mike Tschiltz on DG-1321 FRN

ML20141L501
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/06/2020
From:	Tschiltz M Nuclear Energy Institute
To:	Office of Administration
References
84FR26725 00001, DG-1321
Download: ML20141L501 (2)

Text

Mike just clarifying .. not sure it was clear Is the staff considering whether the current ISG-025 process should still be applicable during the period from the Notice of Intended Operations to 103(g)? Or whether the ISG-025 process should no longer be used after the Notice of Intended Operations?

Thanks SUNI Review Complete Template=ADM-013 Mike Tschiltz E-RIDS=ADM-03 ADD: Marieliz Johnson Nuclear Energy Institute 1201 F Street NW, Suite 1100 Comment (1)

Washington, DC 20004 Publication Date: 5/5/220 www.nei.org CITATION 84 FR 26725 M: 202.471.0277 E: mdt@nei.org From: Dudek, Michael <Michael.Dudek@nrc.gov>

Sent: Wednesday, May 6, 2020 2:31 PM To: TSCHILTZ, Michael <mdt@nei.org>

Subject:

[EXTERNAL] RE: DG-1321 FRN Afternoon Mike - Thanks for the outreach! As to your first question, yes, it was the NRCs intent to mean from the Notice of Intended Operation until 103(g).

For the remainder of your comments, I will have my AA put your email into ADAMS so that the comments may be considered along with the other public comments on the DG.

If you have any other questions, please let me know.

Respectfully, Michael I. Dudek Michael I. Dudek l NRR/DNRL/NRLB Branch Chief l U.S. NRC

Michael.Dudek@nrc.gov l : (301) 415-6500 l : (703) 772-1154 From: TSCHILTZ, Michael <mdt@nei.org>

Sent: Tuesday, May 05, 2020 3:50 PM To: Dudek, Michael <Michael.Dudek@nrc.gov>

Subject:

[External_Sender] DG-1321 FRN Mike hope all is well. Quick question.. the FRN noted that The staff is also seeking input on whether to incorporate guidance on two issues into DG-1321: the continued viability of an existing process for treating changes during construction, i.e., the preliminary amendment request process and the timing and review of license amendment requests submitted after the Commission publishes a Notice of Intended Operations.

I am aware of meetings with the staff has had with Southern concerning a streamlined LAR process during construction, since emergency/exigent LARs are not applicable under construction. But it is unclear exactly what the staff is considering in the FRN. Is the staff considering whether the current ISG-025 process should still be applicable during the period from the Notice of Intended Operations to 103(g)?

Also several other issues. DG-1321 seems to only cover a small subset of what the industry was requesting in its report that shows that there were a number of changes to Tier 1 and Tier 2* that created challenges. Not sure why Tier 2* isnt addressed in the DG. Also it is not clear why minor clerical corrections to Tier 1 information is excluded from the process. Without the additional relief in those 2 areas it seems as if PAR is still needed.

Please see attached report.

Thanks.

Mike Tschiltz Nuclear Energy Institute 1201 F Street NW, Suite 1100 Washington, DC 20004 www.nei.org M: 202.471.0277 E: mdt@nei.org