ML25006A202
| ML25006A202 | |
| Person / Time | |
|---|---|
| Site: | 99902028, Nuclear Energy Institute |
| Issue date: | 01/06/2025 |
| From: | Montgomery B Nuclear Energy Institute |
| To: | John Marshall Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| Shared Package | |
| ML25006A201 | List: |
| References | |
| Download: ML25006A202 (1) | |
Text
Bruce Montgomery Director, Decommissioning &
Used Fuel Phone: 202.739.8128 Email: bsm@nei.org January 6, 2025 Ms. Jane Marshall Director, Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Materials Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Request for Review and Endorsement of NEI 22-01, Revision 1, License Termination Process Project Number: 689
Dear Ms. Marshall:
The Nuclear Energy Institute (NEI)1, on behalf of its members, submits the attached Revision 1 to technical report NEI 22-01, License Termination Process, for review and endorsement by the U.S.
Nuclear Regulatory Commission (NRC) as a non-proprietary document. This report will assist decommissioning reactor licensees in the development and implementation of license termination plans (LTP) that satisfy NRCs requirements in 10 CFR 20, Subpart E, Radiological Criteria for License Termination. The information contained in this report is derived from exisiting NRC regulations and guidance, the decommissioning experiences of commercial nuclear reactor licensees over the past twenty years, and from the extensive library of decommissioning work compiled by the Electric Power Research Institute.
NEI 22-01 was submitted to NRC for review on February 13, 2023,2 as supplemented by letters dated April 11, 2023,3 and December 12, 2023.4 By email dated September 13, 2023, 5 NRC acknowledged receipt of NEI 22-01 and indicated that while NRC did not intend to endorse the document at the time, the NRC staff recognized the potential benefits of NEI 22-01 for establishing consistency across the industry 1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.
2 ADAMS Accession No. ML23045A322 3 ADAMS Accession No. ML23102A030 4 ADAMS Accession No. ML23347A211 5 ADAMS Accession No. ML23257A053
Ms. Jane Marshall January 6, 2025 Page 2 Nuclear Energy Institute and improving the quality of future LTP submittals and helping increase the efficiency and effectiveness of NRCs licensing reviews and inspection activities associated with the license termination process. On June 21, 2023,6 NRC approved NEIs request for a fee exemption for its review of NEI 22-01.
By letter dated April 30, 2024, NRC issued the results of its technical review, providing comprehensive insights and observations on NEI 22-01.7 NEI appreciates the level of detail and comprehensiveness of the NRC staff review and the beneficial impact they will have on the quality and completeness of the industry guidance on license termination processes and activities. These insights and observations have been incorporated into Revision 1. Because of the extensive nature of the resultant changes and additions, NEI suggests that a public meeting to provide an overview of these changes may be beneficial.
NEI continues to believe that NRC endorsement of this report will benefit both the NRC and the commercial reactor fleet by enhancing the safe, environmentally responsible, and timely completion of license termination-related activities, thus providing broad public benefit. NRC endorsement of NEI 22-01, Revision 1 will provide licensees with confidence that the approach provided in the guidance is consistent with the NRCs expectations. Additionally, as the industry continues to gain experience and develop improved technical capabilities and methodologies, NEI plans to continue updating NEI 22-01 in future revisions and to submit these revisions for NRC review, thereby ensuring continued improvement in license termination practices in alignment with NRC requirements.
If you have any questions on this matter, please contact me at bsm@nei.org.
Sincerely, Bruce Montgomery, Director, Decommissioning & Used Fuel Attachments:
NEI 22-01, Revision 1 Cc:
Ms. Jennifer Whitman, NMSS/DUWP Mr. Bruce Watson, NMSS/DUWP Mr. Cynthia Barr, NMSS/RTAB Mr. Shaun Anderson, NMSS/DUWP/RDB NRC Document Control Desk 6 ADAMS Accession No. ML23103A329 7 Jennifer Whitman (NRC) to Bruce Montgomery, U.S. Nuclear Regulatory Commission Observations and Insights of Nuclear Energy Institute (NEI) Technical Report NEI 22-01, License Termination Process (EPID L-2023-NFO-0010) dated April 30, 2024 (ML24039A183)