ML17137A183: Difference between revisions

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| docket = PROJ0689
| docket = PROJ0689
|| license number =  
|| license number =  
| contact person = Wharton L R
| contact person = Wharton L
| case reference number = NEI 12-04
| case reference number = NEI 12-04
| document type = Meeting Briefing Package/Handouts, Slides and Viewgraphs
| document type = Meeting Briefing Package/Handouts, Slides and Viewgraphs
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=Text=
=Text=
{{#Wiki_filter:10 CFR 72.48 Implementation GuidanceNEI 12-04 Endorsement 1 Brian Guthermanfor theNuclear Energy InstituteMeeting with NRC-DSFMMay 11, 2017 *Rockville, MD Latest Developments
{{#Wiki_filter:10 CFR 72.48 Implementation Guidance NEI 12-04 Endorsement Brian Gutherman for the Nuclear Energy Institute Meeting with NRC-DSFM May 11, 2017
*NEI summarized Industry's position on 11 issues requiring alignment with NRC to move forward in August, 2016
* Rockville, MD 1
*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  
Latest Developments
*Industry understands NRC's position on generic approval of Methods of Evaluation (MOEs) 2 Method of Evaluation (MOE)
* NEI summarized Industrys position on 11 issues requiring alignment with NRC to move forward in August, 2016
*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
* NRC letter of March 2017 provided responses to all 11 issues
*Industry proposes clarifying the guidance to avoid ambiguity for users and the NRC 3
* 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
Fundamentals
*NRC approves cask designs and ISFSI licenses, but does not generically approve the MOEs described in the FSARs
* 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
* 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
* 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 wishto (or have to) use the latest code versions*Cask designers have common equipment in different CoCs and in different amendments for the same CoC
* 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
* Cask designers have common equipment in different CoCs and in different amendments for the same CoC
*Some CoC amendments do not involve review or use of MOEs (e.g., administrative changes) 4 Method of Evaluation
* MOE guidance between 50.59 and 72.48 should be consistent
*NRC's 3/3/17 letter
* Some CoC amendments do not involve review or use of MOEs (e.g., administrative changes) 4
-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  
Method of Evaluation
*in response to a specific request "submitted as part of design approval applications"
* NRCs 3/3/17 letter
-NRC does not currently have adequate guidance and practice to review amendment applications requesting generic MOE approval
  - In order for a different MOE than that described in an FSAR to be used, it must be generically approved by the NRC either:
*There is still some confusion on the details, e.g., what does "generically approved" mean?
* via topical report, or
5 Generic Approval of MOE 6
* 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
Remaining MOE Issues
*FSAR descriptions of analysis methods
* FSAR descriptions of analysis methods
*Using FSAR-described MOEs used across amendments within a CoC or across CoCs (by the  
* 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


same CoC holder)
Path Forward
*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
*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
*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}}
*Industry would like to reach agreement on the content of 12-04 in 2017 8}}

Latest revision as of 03:18, 30 October 2019

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