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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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NIMA ASHKEBOUSSI Senior Director, Fuel and Radiation Safety 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8022 nxa@nei.org nei.org May 13, 2021 Ms. Cherish K. Johnson Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Fee Exemption Request for Updating Guidance to Address the Industrywide Learning Aging Management Program Project Number: 689
Dear Ms. Johnson:
In 2016, the Nuclear Energy Institute (NEI) 1 submitted NEI 16-03, Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools for the NRCs review and endorsement. NEI 16-03 provides guidance for monitoring programs for fixed neutron absorbers in spent fuel pools to demonstrate compliance with 10 CFR 50.68 with respect to the neutron absorbing materials. On March 3, 2017, 2 the NRC staff endorsed NEI 16-03, Revision 0, for referencing in nuclear power plants licensing applications. NEI believes that there is mutual interest in updating NEI 16-03 and that a fee exemption under 10 CFR 170.11(a) is appropriate. NEI is therefore submitting this letter to request that the NRCs review of NEI 16-03, Revision 1 be granted a fee waiver pursuant to 10 CFR 170.11(a)(1)(ii), consistent with the NRCs waiver granted for NEI 16-03, Revision 0. As demonstrated below, NEI 16-03, Revision 1 meets the exemption requirements in that it will assist the NRC in generic regulatory improvements or efforts (e.g.,
rules, regulatory guides, regulations, policy statements, generic letters, or bulletins.).3 In April 2016, the NRC issued Generic Letter (GL), 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools. 4 In discussions concerning the implementation of GL 2016-01, NRC staff requested that industry issue guidance providing licensees with an acceptable approach to develop neutron absorber programs. NEI 16-03 was developed to provide acceptable methods for monitoring neutron absorbers in 1
The Nuclear Energy Institute (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 in 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.
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10 CFR 170.11(a)(1)(ii).
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Ms. Cherish K. Johnson May 13, 2021 Page 2 spent fuel storage racks at nuclear power plants. Additionally, the industry, through the Electric Power Research Institute (EPRI), voluntarily initiated the industrywide learning aging management program (i-LAMP). In 2018, these efforts resulted in the NRC closing GL 2016-01 with the NRC closure letter 5 specifically recommending to:
continue to engage with industry through the EPRI Neutron Absorber Users Group to stay abreast of industry operating experience and research involving the condition of neutron-absorbing materials installed in spent fuel pools, including the continued development and use of the EPRI program established to monitor industrywide operating experience.
Activities under i-LAMP now need to be incorporated into NEI 16-03 guidance so that all reactors have regulatory certainty and predictability to ensure there is no unidentified or unmitigated degradation of neutron-absorbing materials via an agreed-upon method. By incorporating i-LAMP into NEI 16-03, Revision 1 NRC would set clear and predictable regulatory guidance for utilities to follow, ensuring a consistent approach that will save NRC resources. Further, the update to NEI 16-03 will allow the NRC to resolve an identified safety issue and assist the NRC in generic regulatory improvements that had been identified in GL 2016-01. The effort to improve the safety of spent fuel pools through the implementation of the EPRI i-LAMP into the NEI 16-03 guidance constitutes the exact type of generic regulatory improvement envisioned by 10 CFR 170.11.
As noted above, the NRC previously approved NEIs fee waiver request for the review of NEI 16-03, Revision
- 0. NRCs July 14, 2016 letter 6 to NEI notes that the NRC is the primary beneficiary of NEI 16-03 because, if endorsed, the NRC will utilize NEI 16-03 as a guidance document for developing and monitoring programs for neutron absorbers in spent fuel pools. NEI 16-03 will assist the NRC in completing the process of updating and stabilizing the regulatory framework governing spent fuel pools through publication of the planned regulatory guide.
NEI believes this statement continues to be true. Incorporating i-LAMP into NEI 16-03, Revision 1 continues the work to improve the safety of spent fuel pools and aligns with the NRCs desire, as outlined in the GL 2016-01 closure letter, to continue to engage with industry and develop EPRIs work.
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Ms. Cherish K. Johnson May 13, 2021 Page 3 In summary, the information in this letter demonstrates that the criteria in 170.11 (a)(1)(ii) has been satisfied and a fee exemption is appropriate for the review of NEI 16-03, Revision 1 and the EPRI topical report on i-LAMP.
Please contact me should you have any questions.
Sincerely, Nima Ashkeboussi c: Joe Donoghue, NRR Robert Lukes, NRR NRC Document Control Desk