ML23214A253

(Nei), Request for Review and Endorsement of NEI 99-04, Rev. 1, Guideline for Managing NRC Commitment Changes

ML23214A253
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/01/2023
From:	Brett Titus Nuclear Energy Institute
To:	Bo Pham Division of Operating Reactor Licensing
References
Download: ML23214A253 (1)

Text

BRETT TITUS Director Regulatory Affairs

1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8017 bat @nei.org nei.org

August 1, 2023

Bo Pham Director, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 - 0001

Subject:

Request for Review and Endorsement of NEI 99-04, Rev. 1, Guideline for Managing NRC Commitment Changes

Project Number: 689

Dear Mr. Pham:

The Nuclear Energy Institute (NEI) 1, on behalf of its members, is pleased to submit for NRCs review and endorsement NEI 99-04, Rev. 1, Guideline for Managing NRC Commitment Changes. This document was revised by NEI in consort with representatives from our member companies and the Pressurized Water Reactor Owners Group. It contains process enhancements and updated guidance that will assist the industry and the NRC with standardized, clear, and predictable practices for the treatment of regulatory commitments.

NEI believes that there is mutual interest in reviewing and endorsing NEI 99-04, Rev. 1. This Revision is a general update of the document to reflect more than 20 years of licensee and NRC experience with regulatory commitments. It incorporates the evolution of NRC regulations and practices as they impact regulatory commitments since Rev. 0 of this document was last endorsed by the NRC in 1999.

Consistent with the description contained in LIC-101, License Amendment Procedures, Rev. 6, (which cites LIC-100), regulatory commitments are the third tier of the hierarchical structure that forms the licensing bases for nuclear power plants. The LIC states, Control of such commitments in accordance with licensee programs is acceptable provided those programs include controls for evaluating changes and, when appropriate, reporting them to the NRC. Thus, it is in the best interest of both the nuclear industry and the

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.

Bo Pham August 1, 2023 Page 2

NRC to align on this revised guidance for clarity and efficiency as licensees navigate existing and future regulatory commitments.

For your awareness, NEI is submitting a fee exemption request to the NRCs Office of the Chief Financial Officer (CFO) to cover all activities involved in the review and endorsement of NEI 99-04, Rev. 1.

On behalf of NEI and our members, we look forward to future engagements with NRR staff, with the mutual goal of endorsing this proposed guidance, for the benefit of NRC and licensees alike.

If there are any questions on this matter, please contact me at 202-739-8017 or bat@nei.org.

Sincerely,

Brett Titus

Attachments: NEI 99-04, Rev. 1, Guideline for Managing NRC Commitment Changes

c: Jamie Heisserer, NRR, NRC Gregory Suber, NRR, NRC Gerond George, NRR, NRC