ML17013A155

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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ML17013A153	List: ML17013A155 ML17013A156 ML17013A157
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Download: ML17013A155 (2)

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RODNEY MCCULLUMSenior Director,Used Fuel and Decommissioning Programs1201 F Street,NW, Suite 1100Washington, DC 20004 P: 202.739.8082rxm@nei.orgnei.orgJanuary12, 2017Mr. Mark LombardDirector,Division of Spent Fuel Storage and Transportation Office of Nuclear Materials Safety and SafeguardsU.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

DearMr. Lombard:

On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 1is transmitting updated versionsof the draft Regulatory Issue Resolution Protocol (RIRP)Screening and Resolution Planforms for Improving the Efficiency of the Regulatory Framework for Dry Storage of SpentNuclear Fuel(RIRP-I-16-01).These forms have been updated to reflect the discussions inthe recent NRC public meeting held on November 21, 2016along 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.Wethank the NRC for hosting the November 21 meeting. Itwas very helpful in further defining the path forward for the ongoing effort-defined in this RIRP-to 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 framework-consistent with the NRC's Project AIM initiative and complimentary to the industry's Delivering the Nuclear Promise activities.

1The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affectin g 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, majorarchitect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

Mr. Mark LombardJanuary12, 2016Page 2In 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 letterwith the staff's position regarding the sufficiency of this document for initiating the pilotby no later than February 10, 2017.As wediscussed, the approach described in the attached RIRPis founded upon the NRC's 1993 Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors and the Industry's Petition forRulemaking (PRM) 72-7 submitted in October 2012(which itself is based upon the successful power reactor Improved Technical Specification (ITS) effort ofthe late 1980s and early 1990sin accordance with the Commission's policy).It is our expectation that this approachwill 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 formsand proposedLicense and Cask CoC Format, Content, and Selection Criteria document.If you have any questions,please do not hesitate to contact meor Mr. Mark Richter of my staff (mar@nei.org; 202-739-8106).Sincerely, Rodney McCullumAttachmentsc:Mr.John McKirgan,NMSS/DSFM, NRCNRC Document Control Desk