ML25268A216
| ML25268A216 | |
| Person / Time | |
|---|---|
| Site: | 99902028, Nuclear Energy Institute |
| Issue date: | 09/25/2025 |
| From: | Andy Campbell Nuclear Energy Institute |
| To: | Carroll C NRC/OCFO, Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25268A216 | List: |
| References | |
| NEI 24-11, Rev. 1 | |
| Download: ML25268A216 (1) | |
Text
Alan Campbell Technical Advisor Phone: 202.739.8011 Email: adc@nei.org September 25, 2025 Mr. Christopher Carroll Chief Financial Officer (Acting)
U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Fee Exemption Request for NEI 24-11, Revision 1, Fire Response Evaluation for Advanced Reactor Technology Project Number: 689
Dear Mr. Carroll,
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI)1 requests a waiver of fees associated with the U.S. Nuclear Regulatory Commission (NRC) staff's review and endorsement of NEI 24-11, Revision 1, Fire Response Evaluation for Advanced Reactor Technology. This document presents a regulatory and technical approach to assess appropriate fire response strategies for the advanced reactor fleet, offering a methodology that is technology-inclusive and aligned with modern risk-informed safety practices.
NEI believes this fee waiver is warranted pursuant to 10 CFR 170.11(a)(1)(ii), as the NRCs review of NEI 24-11, Rev 1 will "assist the NRC in generic regulatory improvements or efforts." Specifically, this document:
Establishes a structured process to determine acceptable fire response configurations for advanced reactor designs, including options for incipient response and reliance on offsite fire support.
Responds directly to NRC guidance in DANU-ISG-2022-09 encouraging early dialogue on risk-informed, performance-based fire protection programs.
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 September 25, 2025 Page 2 Nuclear Energy Institute Supports greater regulatory efficiency and consistency by clarifying how alternative fire response approaches can maintain defense-in-depth and meet applicable safety objectives.
The evaluation process outlined in NEI 24-11, Rev. 1 reflects extensive stakeholder input and builds upon insights from current regulatory guidance, operating experience, and advances in fire science. Its industry-wide applicability will contribute meaningfully to the NRCs ongoing efforts to modernize fire protection expectations for non-light water reactors and other innovative reactor designs.
If you have any questions or require additional information, please contact me at adc@nei.org or 202-439-3698.
Sincerely, Alan Campbell Technical Advisor cc:
Evan Davidson (NRR/DRA/APLB)
Michael Wentzel (NRR/DANU)
NRC Document Control Desk