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{{#Wiki_filter:}} | {{#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 | ||
*NEI summarized Industry's 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 NRC's 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 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 | |||
*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 | |||
*NRC's 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}} |
Revision as of 21:14, 18 October 2018
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 R | |
References | |
NEI 12-04 | |
Download: ML17137A183 (8) | |
Text
10 CFR 72.48 Implementation GuidanceNEI 12-04 Endorsement 1 Brian Guthermanfor theNuclear Energy InstituteMeeting with NRC-DSFMMay 11, 2017 *Rockville, MD Latest Developments
- NEI summarized Industry's 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 NRC's 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 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
- 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
- NRC's 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
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