ML25141A232

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Fee Exemption Request for NEI 11-02, Resolving Force-on-Force Exercise Scenario Issues, Revision 1
ML25141A232
Person / Time
Site: 99902028, Nuclear Energy Institute
Issue date: 05/21/2025
From: Whitlock M
Nuclear Energy Institute
To: Barwell O
Office of Nuclear Reactor Regulation, NRC/OCFO, Document Control Desk
References
NEI 11-02, Rev 1
Download: ML25141A232 (1)


Text

Michael Whitlock Director, Security & Incident Preparedness Phone: 540.333.5087 Email: mlw@nei.org May 21, 2025 Mr. Owen Barwell Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Fee Exemption Request for NEI 11-02, Resolving Force-on-Force Exercise Scenario Issues, Revision 1 Project Number: 689

Dear Mr. Barwell:

The Nuclear Energy Institute (NEI)1, on behalf of its members, respectfully requests a fee waiver under 10 CFR 170.11(a)(1)(ii) for the U.S. Nuclear Regulatory Commission (NRC) staffs review and endorsement of NEI 11-02, Resolving Force-on-Force Exercise Scenario Issues, Revision 1.

NEI 11-02, Revision 1, provides a standardized process for resolving scenario issues that arise during Force-on-Force (FOF) exercises, as well as for addressing potential issues outside of FOF inspections.

The document has been developed collaboratively with extensive engagement between NEI, industry stakeholders, and the NRC staff. It will enhance regulatory consistency, clarity in inspection practices, and efficiency.

Consistent with 10 CFR 170.11(a)(1)(ii), the endorsement of NEI 11-02 will directly assist the NRC in achieving generic regulatory improvements by:

Providing a uniform framework for resolving FOF scenario issues, Facilitating consistent exercise execution across licensees, Reducing regulatory uncertainty, Enhancing the overall effectiveness and efficiency of the NRC's security inspection program.

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. Owen Barwell May 21, 2025 Page 2 Nuclear Energy Institute These benefits will improve both licensee performance and NRC oversight without requiring case-by-case review, thereby conserving regulatory resources and contributing to the NRC's mission of maintaining public health and safety.

This fee exemption request is being submitted concurrently with NEI's submittal of NEI 11-02, Resolving Force-on-Force Exercise Scenario Issues, Revision 1, for NRC review and endorsement.

If you have any questions or require additional information, please contact me at mlw@nei.org.

Sincerely, Michael Whitlock Director, Security & Incident Preparedness cc:

Ms. Desiree Davis, NSIR/DSO/SOSB Ms. Rebecca Lagios, NSIR/DPCP NRC Document Control Desk