ML25225A244
| ML25225A244 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 08/13/2025 |
| From: | Yuen S Nuclear Energy Institute |
| To: | Carroll C Office of Nuclear Reactor Regulation, NRC/OCFO, Document Control Desk |
| References | |
| NEI 23-01, Rev 2 | |
| Download: ML25225A244 (1) | |
Text
Stewart Yuen Senior Project Manager Phone: 920.396.0521 Email: sjy@nei.org August 13, 2025 Mr. Christopher Carroll Chief Financial Officer (Acting)
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Fee Exemption Request for Endorsement, and Review of NEI 23-01 revision 2, Operator Cold License Training Plan for Advanced Nuclear Reactors Project Number: 689
Dear Mr. Carroll:
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI)1 is writing to request a waiver of fees associated with the NRC staffs review of NEI 23-01 revision 2, Operator Cold License Training Plan for Advanced Nuclear Reactors. NEI 23-01 provides applicants for Advanced Nuclear Reactors with a standard plan to train and license operators before construction of the plant is complete. NRC review and endorsement of NEI 23-01 will allow applicants to reference this plan within their Advanced Reactor Construction Permit (CP) or Combined Operating License (COL) application and reduce the time the staff needs to review the application.
NEI requests that NRCs review of NEI 23-01, including any subsequent submittals necessary to address staff review comments, be granted a fee waiver pursuant to 10 CFR 170.11. NRCs review of the document meets the exemption requirement in 10 CFR 170.11(a)(1)(ii) because the review will assist the NRC in generic regulatory improvements or efforts.
Since existing industry guidance for Operator Cold License Training is not well suited to advanced reactors, including light-water small modular reactors (SMRs), each applicant will need to have a plan in their CP/COL application for how to approach this topic. This could result in many different approaches 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. Christopher Carroll August 13, 2025 Page 2 Nuclear Energy Institute being taken, which would require the NRC staff to review them anew with each application. General guidance, like that provided in NEI 23-01, can be reviewed, and endorsed by the NRC staff once. This guidance can be referenced in the individual applications and would need no additional review by the staff, thereby potentially saving review time.
NEI has discussed NEI 23-01 with the staff in multiple venues already, including public meetings in December 2022, December 2023, December 2024, and March 2025. Revision 2 incorporates changes because of the staffs questions and comments at the March 2025 public meeting. The technical report has been provided to NRC staff for endorsement under separate cover letter.
If there are any questions on this matter, please contact either me at sjy@nei.org or Marcus Nichol at mrn@nei.org.
Sincerely, Stewart J Yuen cc:
Angelica Gheen, Advanced Reactor Policy Branch, NRR, NRC Mike Wentzel, DANU, NRR, NRC Document Control Desk