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Category:Letter
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June 1, 2020 Mr. Rodney McCullum, Sr. Director Decommissioning and Used Fuel Program Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, DC 20004
SUBJECT:
RESPONSE TO NUCLEAR ENERGY INSTITUTE LETTER - DEFINING SPENT FUEL PERFORMANCE MARGINS: AN EXPERIENCE-BASED APPROACH TO PROTECTING AGAINST GROSS RUPTURE OF CLADDING IN DRY STORAGE, DATED MAY 13, 2020
Dear Mr. McCullum,
Thank you for your letter dated May 13, 2020 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML20148M158), in which the Nuclear Energy Institute (NEI) provided its perspectives on future work related to gross rupture of cladding in dry storage. In your letter, you provide the industrys perspectives on the risk insights and safety margins regarding meeting existing criteria pertaining to cladding integrity that could be used to improve industry submittals and regulatory reviews. Additionally, you provided insights for the U.S. Nuclear Regulatory Commission (NRC) and Electric Power Research Institute to consider as part of its plan to establish a Phenomena Identification and Ranking Table (PIRT) team to evaluate the need for changes to the definition of gross rupture.
I appreciate the early perspectives you provided for the PIRT team to consider and agree that timely consideration of any potential need for change to the definition of gross rupture is an important step towards transforming spent fuel licensing, as it is a subject that is integral to several technical aspects of the NRC review. I have found that the public workshops to discuss the NEI white paper recommendations on spent fuel performance margins have resulted in meaningful exchanges including the most recent April 15-16, 2020 workshop. As agreed during the workshop, my staff is working to develop a draft safety goal associated with more clearly defining gross rupture to serve as a starting point for a future PIRT and is planning to hold a focused discussion on the draft safety goal at the next public workshop. I believe a clearer safety objective that forms the basis of the definition of gross rupture can help improve focus on what is most important to assure safety without unnecessary conservatisms.
Thank you for your continued interest in the NRCs spent fuel regulatory approaches. We look forward to working with NEI and other stakeholders to continue the dialog on defining gross rupture and the various other recommendations provided in your November 8, 2019 letter.
R. McCullum 2 Additional details on the meeting logistics for the June 2020 workshop will be provided in the coming weeks. Please contact me, Christopher Regan, or Christian Araguas of my staff if you need additional information.
Sincerely, Andrea L. Digitally signed by Andrea L. Kock Kock Date: 2020.06.01 13:55:32 -04'00' Andrea L. Kock, Director Division of Fuel Management Office of Nuclear Materials Safety and Safeguards
R. McCullum 2 RESPONSE TO NUCLEAR ENERGY INSTITUTE LETTER - DEFINING SPENT FUEL PERFORMANCE MARGINS: AN EXPERIENCE-BASED APPROACH TO PROTECTING AGAINST GROSS RUPTURE OF CLADDING IN DRY STORAGE, DATED MAY 13, 2020 DATED: June 1, 2020 DISTRIBUTION:
JLubinski, NMSS RLewis, NMSS CRegan, NMSS/DFM CAraguas, NMSS/DFM JMcKirgan, NMSS/STL YDiaz-Sanabria, NMSS/CTCF MRahimi, NMSS/MSB RChang, NMSS/NARA Project Manager ADAMS Accession Number: ML20148M157 *via e-mail OFC NMSS/DFM NMSS/DFM NMSS/DFM NAME CAraguas CRegan* AKock DATE 5/29/2020 5/29/2020 06/01/2020 OFFICIAL RECORD COPY