ML24187A094
| ML24187A094 | |
| Person / Time | |
|---|---|
| Site: | 99902028, Nuclear Energy Institute |
| Issue date: | 07/03/2024 |
| From: | Austgen K Nuclear Energy Institute |
| To: | Jennifer Golder Office of Nuclear Reactor Regulation, NRC/OCFO, Document Control Desk |
| Shared Package | |
| ML24187A093 | List: |
| References | |
| Download: ML24187A094 (1) | |
Text
Kati R. Austgen Sr. Project Manager, New Nuclear Phone: 202.340.1224 Email: kra@nei.org July 03, 2024 Ms. Jennifer M. Golder Chief Financial Officer (Acting)
Office of the Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Fee Exemption Request for Endorsement of NEI White Paper, Selection of a Seismic Scenario for an EPZ Boundary Determination Project Number: 689
Dear Ms. Golder:
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI)1 requests a waiver of fees associated with the U.S. Nuclear Regulatory Commission (NRC) staffs review and endorsement of NEI White Paper, Selection of a Seismic Scenario for an EPZ Boundary Determination. This document reflects the work of NEIs Advanced Reactor Regulatory Task Force to develop a technology-inclusive methodology for the selection of a seismic scenario to use in an analysis for determining the boundary of a plume exposure pathway Emergency Planning Zone (EPZ). An EPZ sizing analysis is required by applicants choosing to comply with 10 CFR 50.160, Emergency preparedness for small modular reactors, non-light-water reactors, and non-power production or utilization facilities, and the white paper guidance is intended to supplement that found in Regulatory Guide 1.242, Performance-Based Emergency Preparedness for Small Modular Reactors, Non-Light-Water Reactors, and Non-Power Production or Utilization Facilities.
We believe a fee waiver is warranted pursuant to 10 CFR 170.11(a)(1)(ii) because the white paper guidance will assist the NRC in generic regulatory improvements or efforts. Specifically, rather than each applicant proposing their own seismic scenario development method, applicants can follow an NRC-endorsed method. The availability of an acceptable standardized method will lower staff time spent on application reviews, and improve regulatory efficiency, predictability, and clarity. To ensure industry 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.
Ms. Jennifer M. Golder July 03, 2024 Page 2 Nuclear Energy Institute access, NEI will make the document available to all NEI members and to non-NEI members for a reasonable fee. Thus, access to the white paper would not be limited to any arbitrary class of licensees.
If you have any questions or require additional information, please contact me, or David Young at dly@nei.org.
Sincerely, Kati R. Austgen Sr. Project Manager, New Nuclear Attachment C:
Ms. Andrea Veil, NRR, NRC Mr. Robert Taylor, NRR, NRC Mr. Mohammed Shams, NRR/DANU, NRC Mr. Brian Smith, NRR/DNRL, NRC Mr. John Segala, NRR/DANU, NRC Ms. Kathryn Brock, NSIR/DPR, NRC Mr. Todd Smith, NSIR/DPR, NRC NRC Document Control Desk