What types of license renewal commitment changes require notification to the agency?
All commitments are subject to the commitment tracking system, as noted in the Nuclear Energy Institute (NEI) guidance document, entitled “Guidelines for Managing NRC Commitment Changes” (NEI 99-04 , Rev. 0), and as endorsed in Regulatory Issue Summary 2000-17, “Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff.” Figure A-1 of NEI 99-04 provides an overview of issues leading to NRC notification. Some notification may be preemptive, in terms of exploring ways to proceed, and other notifications may be necessary because the staff relied on the given commitment in the SER. In addition, if a licensee makes a change to a commitment to the NRC and the affected commitment is not a requirement or part of a codified process (such as the UFSAR), the subject guidance requires an impacts review of intended SSC functions and/or a significant hazards review.
