ML17013A155

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Transmittal of Regulatory Issue Resolution Protocol Screening Form and Resolution Plan for Improving the Part 72 Regulatory Framework (RIRP-I-16-01)
ML17013A155
Person / Time
Site: Nuclear Energy Institute
Issue date: 01/12/2017
From: Mccullum R
Nuclear Energy Institute
To: Mark Lombard
Document Control Desk, Division of Spent Fuel Management
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Download: ML17013A155 (2)


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RODNEY MCCULLUM Senior Director, Used Fuel and Decommissioning Programs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8082 rxm@nei.org nei.org January 12, 2017 Mr. Mark Lombard Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Materials Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Regulatory Issue Resolution Protocol Screening Form and Resolution Plan for Improving the Part 72 Regulatory Framework (RIRP-I-16-01)

Project Number: 689

Dear Mr. Lombard:

On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 1 is transmitting updated versions of the draft Regulatory Issue Resolution Protocol (RIRP) Screening and Resolution Plan forms for Improving the Efficiency of the Regulatory Framework for Dry Storage of Spent Nuclear Fuel (RIRP-I-16-01). These forms have been updated to reflect the discussions in the recent NRC public meeting held on November 21, 2016 along with a draft License and Cask CoC Format Content, and Selection Criteria document, which was developed as a direct result of this meeting. All three of these documents are attached to this letter.

We thank the NRC for hosting the November 21 meeting. It was very helpful in further defining the path forward for the ongoing effortdefined in this RIRPto establish consistent format, content and selection criteria for NRC staff reviewer use in determining what information, related to an approved ISFSI license or cask design CoC, belongs in the ISFSI license or cask CoC (including technical specifications) after the technical review is completed. This effort, going forward, is expected to result in a significantly more efficient used fuel dry storage regulatory frameworkconsistent with the NRCs Project AIM initiative and complimentary to the industrys Delivering the Nuclear Promise activities.

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.

Mr. Mark Lombard January 12, 2016 Page 2 In order for the industry to begin work on the next step, submittal of a pilot CoC application implementing the proposed Format, Content, and Selection Criteria document, we request that the NRC respond to this letter with the staffs position regarding the sufficiency of this document for initiating the pilot by no later than February 10, 2017.

As we discussed, the approach described in the attached RIRP is founded upon the NRCs 1993 Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors and the Industrys Petition for Rulemaking (PRM) 72-7 submitted in October 2012 (which itself is based upon the successful power reactor Improved Technical Specification (ITS) effort of the late 1980s and early 1990s in accordance with the Commissions policy). It is our expectation that this approach will result in the development of a complimentary component of the regulatory framework that, when complete, we envision being incorporated by the NRC via endorsement of NEI guidance.

I would be happy to address any feedback the NRC may have on the updated RIRP forms and proposed License and Cask CoC Format, Content, and Selection Criteria document. If you have any questions, please do not hesitate to contact me or Mr. Mark Richter of my staff (mar@nei.org; 202-739-8106).

Sincerely, Rodney McCullum Attachments c: Mr. John McKirgan, NMSS/DSFM, NRC NRC Document Control Desk