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{{#Wiki_filter:10 CFR 72.48 Implementation | {{#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 | * 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 | * 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 | * 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 | ||
* | * 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 | * 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 | * 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 | |||
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 04:18, 30 October 2019
| 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
- 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