ML18137A046

NRC NEI Fee Waiver Request NEI 05-05 Force-on-Force Exercise Controller Responsibilities Guideline Revision 6

ML18137A046
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/16/2018
From:	Gross W R Nuclear Energy Institute
To:	Wylie M E NRC/OCFO
Hudson, Sharon
References
Download: ML18137A046 (2)

Text

WILLIAM R. GROSS Director, Incident Preparedness 1201 F Street

, NW, Suite 1100 Washington, DC 20004 P: 202.739.8123 wrg@nei.org nei.org May 1 6, 2018 Ms. Maureen E. Wylie Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Fee Exemption Request for NEI 05-05, Force-on-Force Exercise Controller Responsibilities Guideline, Revision 6 Project Number: 689

Dear Ms. Wylie:

The Nuclear Energy Institute (NEI)1, on behalf of its members, will be submitting NEI 05

-05, Force-on-Force Exercise Controller Responsibilities Guideline, revision 6 for endorsement. The guidance in this document addresses the knowledge and skills necessary to be a controller in both a licensee Force

-on-Force (FOF) exercise, as well as the NRC evaluated FOF as part of the 71130.03 Inspection Procedure, Contingency Response - Force-on-Force Testing. FOF exercises are scripted to maximize realism; however, simulations are employed where necessary to assure the safety of the participants. NEI 05-05 provide s acceptable simulation s and control measures for a broad range of expected tactics. Revision 6 of NEI 05

-05 was created, in part, to incorporate control elements previously included in Addendum 5 to NRC Inspection Procedure (IP) 71130.03, Contingency Response

- Force-on-Force Testing. Addendum 5 was removed from the IP in January, 2017. Elements from Addendum 5 were incorporated into NEI 05

-05 to enhance the control of FOF exercises.

NEI requests that the NRC's review of NEI 05-05 and any future submissions of the guidance document be granted a fee waiver pursuant to the provisions of 10 CFR 170.11. This document meets the exemption 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.

Ms. Maureen E. Wylie May 1 6, 2018 Page 2 requirement in 10 CFR 170.11(a)(1)(ii i)(A) in that it will "-assist the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins)." In this case, NRC review and endorsement of revision 6 of NEI 05

-05 will facilitate in the development of control measures associated with planned FOF scenarios and provide clarity to licensees on control attributes associated with Force

-on-Force. If you have any questions or require additional information, please contact AJ Clore at (202) 739

-8025; ajc@nei.org or me. Sincerely, William R. Gross c: Ms. Marissa Bailey, NSIR/DSO, NRC Mr. Doug Huyck, NSIR/DSO, NRC NRC Document Control Desk