ML20350B606
| ML20350B606 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/2020 |
| From: | Santos N Division of Fuel Management |
| To: | |
| TLiu - NMSS/DFM/STL - 404.997.4730 | |
| References | |
| Download: ML20350B606 (6) | |
Text
Graded Approach to Certificates of Compliance of Storage Systems Division of Fuel Management Norma García Santos Project Manager
Historical Challenges
Proposed Solution: Graded Approach Outreach Work with stakeholders on criteria to organize and retain information on the certificate.
Approach Document each proposed change on an evaluation form.
Submit evaluations as part of the application.
Pilot Test the criteria in a pilot amendment.
Adjust Compile lessons learned.
Adjust criteria, if needed.
Guidance Development of revised guidance.
Revised certificate format and content
Graded Approach Pilot Applicant: TN Americas LLC Model No.: Standardized NUHOMS HSM Application format:
- Evaluation Form for each proposed change. Each evaluation included the following:
- a justification and basis for the change
- proposed disposition of change(s)
- Proposed CoC and Appendices language.
- Page changes for the SAR
- Proposed approach to replace some Fuel Qualification Tables from TSs Fee Exempted (Pilot)
Experienced and knowledgeable staff Institutional and historical knowledge Team:
- Technical reviewers
- Risk expert
- Inspectors
- Attorney Guidance: Proposed graded approach criteria, SRP, and other regulatory guidance.
Review: Public meetings, internal meetings, and individual assignments.
Review Team Applicant
Results Risk-Informing Removal of requirements already specified in the regulations.
Removal of redundant information throughout the CoC and SAR.
A certificate and appendices focused on the safe design and operations of
- systems, structures, and components.
A UFSAR with supporting information.
Next Steps and Questions for Discussion Next Steps:
Develop method of evaluation related to shielding evaluations.
Continue open discussions with the industry about on going activities and discuss timing of guidance development.
Questions for Discussion:
1.
Have vendors expressed interest in future submittals implementing the graded approach methodology?
2.
Does the TN pilot amendment and previously defined submittal worksheets provide enough guidance for future graded approach submittals?
3.
Have vendors expressed interest on using Topical Reports in lieu of the graded approach methodology to simplifying the TS?