ML17137A183

Presentation Slides: 10 CFR 72.48 Implementation Guidance NEI 12-04 Endorsement, Brian Gutherman/Nei - Public Meeting with NEI and Industry, Held on May 11, 2017

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 Brian Gutherman for the Nuclear Energy Institute Meeting with NRC-DSFM May 11, 2017

• Rockville, MD 1

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

• Cask designers have common equipment in different CoCs and in different amendments for the same CoC

• 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