ML17137A183
Jump to navigation
Jump to search
| ML17137A183 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 05/11/2017 |
| From: | Gutherman B Nuclear Energy Institute |
| To: | NRC/NMSS/DSFM/IOB |
| Wharton L | |
| References | |
| NEI 12-04 | |
| Download: ML17137A183 (8) | |
Text
10 CFR 72.48 Implementation Guidance NEI 12-04 Endorsement 1
Brian Gutherman for the Nuclear Energy Institute Meeting with NRC-DSFM May 11, 2017
- Rockville, MD
Latest Developments
- NEI summarized Industrys position on 11 issues requiring alignment with NRC to move forward in August, 2016
- NRC letter of March 2017 provided responses to all 11 issues
- Alignment was reached on 10 of 11 issues with Industry action to revise the 12-04 guidance identified
- Industry understands NRCs position on generic approval of Methods of Evaluation (MOEs) 2
Method of Evaluation (MOE)
- There are two potential departures from an MOE described in the FSAR, either of which would require prior NRC approval:
- 1. Change to an element of a method where the results are not essentially the same or conservative
- 2. Use of another MOE that has not been approved by the NRC for the intended application Industry proposes clarifying the guidance to avoid ambiguity for users and the NRC 3
Fundamentals
- NRC approves cask designs and ISFSI licenses, but does not generically approve the MOEs described in the FSARs
- FSARs are approved documents and MOEs used in the safety analyses are summarized in the FSARs for the ISFSI or cask
- MOEs summarized in the FSAR are used to evaluate other changes, such as modifications and procedure changes
- Computer codes supporting those MOEs evolve over time and cask designers often wish to (or have to) use the latest code versions
- MOE guidance between 50.59 and 72.48 should be consistent
- Some CoC amendments do not involve review or use of MOEs (e.g., administrative changes) 4
Method of Evaluation
- NRCs 3/3/17 letter
- In order for a different MOE than that described in an FSAR to be used, it must be generically approved by the NRC either:
- via topical report, or
- in response to a specific request submitted as part of design approval applications
- NRC does not currently have adequate guidance and practice to review amendment applications requesting generic MOE approval
- There is still some confusion on the details, e.g.,
what does generically approved mean?
5
Generic Approval of MOE 6
Remaining MOE Issues
- FSAR descriptions of analysis methods
- Using FSAR-described MOEs used across amendments within a CoC or across CoCs (by the same CoC holder)
- Evaluating use of later releases or versions of previously used codes that are described in the FSAR 7
Path Forward
- Industry will revise NEI 12-04 to reflect the agreements on the 11 issues and most other editorial or administrative suggestions in the NRC comment letters
- Public meeting to discuss proposed changes to MOE guidance before 12-04 is re-submitted
- Industry would like to reach agreement on the content of 12-04 in 2017 8