ML23268A010

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

ML23268A010
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/22/2023
From:	Yuen S Nuclear Energy Institute
To:	Osborne H NRC/OCFO
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ML23293A021	List: ML23268A010 ML23293A025
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Download: ML23268A010 (1)

Text

STEW YUEN Senior Project Manager Engineering and Risk 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 612.518.2850 ras@nei.org nei.org September 22, 2023 Howard Osborne Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

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 Project Number: 689

Dear Mr. Osborne:

The Nuclear Energy Institute (NEI) 1, on behalf of its members, is writing to request a waiver of fees associated with the NRC staffs review of Draft NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors. NEI 23-01 provides applicants for Advanced Nuclear Reactors with a standard plan to train and license operators before construction of the plant is complete. NRC review and endorsement of NEI 23-01 will allow applicants to reference this plan within their Advanced Reactor Construction Permit (CP) or Combined Operating License (COL) application and reduce the time the staff needs to review the application.

NEI requests that NRCs review of NEI 23-01, including any subsequent submittals necessary to address staff review comments, be granted a fee waiver pursuant to 10 CFR 170.11. NRCs review of the document meets the exemption requirement in 10 CFR 170.11(a)(1)(ii) because the review will assist the NRC in generic regulatory improvements or efforts.

Since existing industry guidance for Operator Cold License Training is not well suited to advanced reactors, including light-water small modular reactors (SMRs), each applicant will need to have a plan in their CP/COL application for how to approach this topic. This could result in many different approaches being taken, which would require the NRC staff to review them anew with each application. General guidance, like that provided in NEI 23-01, can be reviewed, and endorsed by the NRC staff once. This guidance can be 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.

Mr. Howard Osborne September 22, 2023 Page 2 referenced in the individual applications and would need no additional review by the staff, thereby potentially saving review time.

NEI has discussed NEI 23-01 with the staff in multiple venues already, including a public meeting in December 2022. The draft technical report will be provided to the staff to collect comments and observations to ensure there are not significant staff concerns with the guidance. It will then be updated as needed and submitted to the NRC for endorsement.

If there are any questions on this matter, please contact either me at sjy@nei.org or Marcus Nichol at mrn@nei.org.

Sincerely, Stewart J Yuen

Attachment:

Draft NEI 23-01, Operator Cold License Training Plan for Advanced Nuclear Reactors, cc: Scott Tonsfeldt, DANU, NRR, NRC Steven Lynch, DANU, NRR, NRC NRC Document Control Desk