ML17090A137

NEI Revised Fee Exemption Request for NUMARC 93-01 Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants

ML17090A137
Person / Time
Site:	Nuclear Energy Institute
Issue date:	03/30/2017
From:	Zachariah T Nuclear Energy Institute
To:	Wylie M E NRC/OCFO
Hudson, Sharon
References
NUMARC 93-01
Download: ML17090A137 (2)

Text

THOMAS ZACHARIAH Senior Project Manager 1201 F Street

, NW, Suite 1100 Washington, DC 20004 P: 202.739.8058 txz@nei.org nei.org March 3 0, 2017 Ms. Maureen Wylie Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555

-0001

Subject:

Revised Fee Exemption Request for Revision 4e of NUMARC 93

-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants"

Project Number: 689

Dear M s. Wylie:

On January 30, 2017

, NEI submitted revision 4e of guidance document NUMARC 93

-01 , "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants

," for NRC re view and endorsement. NUMARC 93-01 is the existing guidance that established an acceptable approach for licensees to meet 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," also known as the Maintenance Rule. NUMARC 93-01 was previously endorsed by the NRC under Regulatory Guide (RG) 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. NEI understands that the NRC endorsement of this revision to NUMARC 93

-01 would be through an issuance of interim staff guidance (ISG) and subsequently incorporated into a revision to RG 1.160.

NEI requests that the NRC's review of NUMARC 93

-01, Revision 4e

, and any future submissions of the guidance document be granted a fee waiver pursuant to the provisions of 10 CFR 170.11.

The report meets the exemption requirement in 10 CFR 170.11(a)(1)(ii) in that it is "to assist the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins).

" In this case, the revision of this guidance supports increased regulatory efficiency of agency efforts as it provides a consistent industry approach for the treatment of SSCs when EOPs direct to functions in FLEX Support Guidelines (FSGs) in meeting the requirements of the Maintenance Rule

. The NRC is the primary beneficiary of this guidance as the NRC has and will continue to use this document to support the inspection efforts associated with 10 CFR 50.65.

NEI had previously submitted a fee waiver request for this revision of NUMARC 93

-01 on March 22, 2017. However, that letter did not reference the most current fee exemption requirements in 10 CFR 170.11(a)(1).

M s. Maureen Wylie March 30 , 2017 Page 2 NEI requests that the NRC consider this request in lieu of the request made on March 22, 2017

. Please contact me should you have any questions at 202

-739-8058 or txz@nei.org

. Sincerely, Thomas Zachariah

c: Mr. Christopher Miller, Director, NRR/DIRS, NRC Ms. Ami Patel, NRR/DIRS, NRC Ms. Jane Marshall, JLD, NRC Mr. Mohamed Shams, JLD, NRC Mr. Michael King, NRR/DIRS, NRC