ML25066A041
| ML25066A041 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/27/2025 |
| From: | Couture P Entergy Operations |
| To: | Mirela Gavrilas NRC/SECY, NRC/EDO |
| References | |
| NRC-2019-0062, 89FR86918 00126, 89FR92609 00126, CNRO2025-00006, RIN 3150-AK31 | |
| Download: ML25066A041 (1) | |
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Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102 CNRO2025-00006 February 27, 2025 ATTN: Ms. Mirela Gavrilas Executive Director of Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Entergy Endorsement of NEI Comprehensive Industry Comments on NRCs Rulemaking on the Post-SRM Part 53, Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors (RIN-3150-AK31; NRC-2019-0062)
Project Number:
689
Dear Ms. Gavrilas:
Entergy Operations, Inc. (Entergy) appreciates the Nuclear Regulatory Commissions (NRCs) efforts to develop a technology-inclusive, risk-informed, and performance-based regulatory framework for new reactors, referred to as the Part 53 rulemaking. The NRCs incorporation of the Commission directive in the Proposed Rule language published on October 31, 2024 is a step in the right direction, but issues remain that must be addressed prior to publishing the final Rule.
Entergy supports the Nuclear Energy Institute (NEIs) timely and detailed input on the NRCs Part 53 proposed rule language (Reference 1). NEIs submittal reflects Entergys views and concerns for Part 53. It highlights the beneficial features the staff has incorporated into Part 53 that should be retained, as well as areas where changes are needed to achieve a Part 53 rule that meets the statutory requirements in the Nuclear Energy Innovation and Modernization Act (NEIMA), the Commission directive in the SRM and select items from the ADVANCE Act.
Of particular interest to Entergy is the ability to transition from Parts 50 or 52 to Part 53. As an Early Site Permit holder, transferability has the potential to save licensing time and cost that would be required for Entergy to seek later stage approvals under Part 53. Additionally, Entergy supports the ability to transition between Parts 50 or 52 to Part 53 while maintaining finality approved under Parts 50 or 52. Reopening settled safety issues would increase risk and reduce the probability of Entergy pursuing a Part 53 licensing pathway.
CNRO2025-00006 Page 2 of 2 We are vested in the NRC developing a successful Part 53 that will be used and useful. The industry has invested significant resources in participating in the public meetings the NRC has held, and in reviewing and commenting on the draft rule language, in the hope of having an inclusive and efficient Part 53. We believe the ability of the nation to reduce carbon emissions and have a robust and reliable electric grid depends on a successful Part 53 rulemaking. We also believe it is clear that, with relatively straight forward changes to the NRC staffs Part 53 preliminary rule language, the NRC can establish a Part 53 rule that allows the variety of risk-informed licensing approaches that industry plans to use for new reactors and this can be accomplished on the Commission directed schedule.
Our hope is that the comprehensive comments developed by NEI, in partnership with the industry, will enable the staff to pursue an inclusive and efficient rule. As stated above, the industry stands ready to provide input in the rulemaking process, including the development of necessary guidance.
We appreciate the NRCs consideration of these comments in the formation of Part 53. If you have questions or require additional information, please contact please contact me at 601-368-5102.
Respectfully, Phil Couture PC/dlw Reference
- 1. Letter from D.E. True (NEI) to M. Gavrilas (NRC), "NEI Paper on NRCs Rulemaking on the Post-SRM Part 53, Risk-Informed, Technology-Inclusive Regulatory Framwork for Advanced Reactors (RIN-3150-AK31; NRC-2019-0062)," dated Febraury 14, 2025.
cc:
Mr. Mike Mahoney NRC Entergy Fleet PM Mr. John Lubinski, NMSS, NRC Mr. John Tappert, NMSS, NRC Ms. Andrea Veil, NRR, NRC Mr. Raymund Furstenau, RES, NRC Mr. Robert H. Beall, NMSS/REFS/RRPB, NRC Mr. Greg Bowman, NRR, NRC Mr. Jeremy Bowen, NRR/DANU, NRC Mr. Anders Gilbertson, NRR/DANU/UARP, NRC Rulemaking.Comments@nrc.gov Regulations.gov SIGN