ML24304A348
| ML24304A348 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 10/29/2024 |
| From: | Brett Titus Nuclear Energy Institute |
| To: | Bo Pham Licensing Processes Branch |
| References | |
| NEI 99-04 | |
| Download: ML24304A348 (1) | |
Text
Brett Titus Director, Regulatory Affairs Phone: 202.739.8017 Email: bat@nei.org October 29, 2024 Mr. Bo M. Pham Director, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
Subject:
Status and Way Forward on NEI 99-04, Revision 1 Project Number: 689
Dear Mr. Pham:
The Nuclear Energy Institute (NEI)1, on behalf of its members, is writing to update you on the status and planned use of NEI 99-04, Revision 1, Guideline for Managing NRC Commitment Changes.2 This revision provides process enhancements and updated guidance that supports standardized, clear, and predictable practices for the treatment of regulatory commitments. Revision 1 reflects the more than 20 years of industry and U.S. Nuclear Regulatory Commission (NRC) experience with regulatory commitments, as well as the evolution of NRC regulations and practices since Rev. 0 of this document was endorsed by the NRC in 2000.3
Background
NEI 99-04, Rev. 1, was submitted to the NRC on August 1, 2023, with a request for review and endorsement.4 A related letter to the NRCs Chief Financial Officer requested a fee exemption for NRC review and endorsement of NEI 99-04, Revision 1.5 On October 30, 2023, the Chief Financial Officer wrote back to deny the fee exemption.6 In the denial letter, the NRC stated that the NEI fee exemption request letter, did not provide sufficient justification for the NRC to make a determination, at this time, that will support a generic regulatory improvement consistent with 10 CFR 170.11. The NRC endorsed NEI 99-04, Rev. 0, and continues to find the current guidance acceptable for managing NRC commitment changes. [emphasis added].
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.
2 NEI 99-04, Revision 1, Guidelines for Managing NRC Commitment Changes, July 31, 2023, ADAMS ML23214A262.
3 NRC acceptance of NEI 99-04, Revision 0, was documented in SECY-00-045, Acceptance of NEI 99-04, Guidelines for Managing NRC Commitments, February 22, 2000 (ADAMS ML003679799); and NRC letter from Samuel J. Collins to Ralph Beedle (NEI), Staff Acceptance of NEI 99-04, Guidelines for Managing NRC Commitment Changes, March 31, 2000 (ADAMS ML003696998).
4 NEI Letter from Brett Titus to Bo Pham (NRC), Request for Review and Endorsement of NEI 99-04, Rev. 1, Guideline for Managing NRC Commitment Changes, August 1, 2023 (ADAMS ML23214A253).
5 NEI Letter from Brett Titus to Howard K. Osborne (NRC), Fee Exemption Request for Review and Endorsement of NEI 99-04, Rev. 1; Guideline for Managing NRC Commitment Changes, August 1, 2023 (ADAMS ML23213A206).
6 Howard K. Osborne (NRC) to Brett Titus (NEI), Letter to The Nuclear Energy Institute in Response to a Request for a Fee Exemption for NEI99-04, Rev 1, Guideline for Managing NRC Commitment Changes,, October 30, 2023, ADAMS ML23284A15.
Mr. Bo M. Pham October 29, 2024 Page 2 Nuclear Energy Institute Path Forward NEI believes that Revision 1 offers significant value to NEI members and the NRC. As we have previously discussed with the NRC in past public meetings, this update greatly clarifies the process of commitment management, includes a step-by-step process for evaluating commitment changes, and eliminates unnecessary periodic reports on commitment changes. Additionally, Revision 1 does not change compliance with any regulatory requirements.
Based on the foregoing, NEI is no longer seeking NRC review and endorsement of Revision 1, and we have made the update available to NEI members for use.
If you have any questions on this matter, please contact me.
Sincerely, Brett Titus Director, Regulatory Affairs