Scheduling Guidance for Licensee Submittals of Reloads That Involve Unreviewed Safety Questions (Generic Letter No. 84-20)
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D.C. 20555
August 20, 1984
TO ALL LICENSEES OF OPERATING REACTORS AND APPLICANTS FOR OPERATING LICENSE
SUBJECT: SCHEDULING GUIDANCE FOR LICENSEE SUBMITTALS OF RELOADS THAT
INVOLVE UNREVIEWED SAFETY QUESTIONS (Generic Letter 84-20)
The purpose of this letter is to provide guidance on the scheduling of
licensee submittals on any reload analyses that contain an unreviewed safety
question or require a revision to the Technical Specifications (TS), and
which therefore require approval and/or a license amendment from NRC prior
to restart. When the submittals involve the reanalysis of FSAR Accident
Analysis Chapter transients and accidents, and these analyses are not based
on NRC-approved analysis models and methods, they should be submitted at
least six months prior to the date of issuance (restart date) of the needed
license amendment or design approval.
In many cases, the analyses of transients and postulated accidents submitted
in support of the reloads have been performed using analysis models and
methods that have not yet been approved by NRC. Full confirmation of the
acceptability of such models and methods frequently has required more review
time than available prior to the needed date and has resulted in interim
findings subject to later confirmation.
In order to avoid possible delays in restart, sufficient time should be
allowed in the reload review process for the staff to make a finding of
acceptability on previously unapproved analysis models and methods. We
therefore provide the following for your guidance:
1. Any licensee planning to submit reload analyses based on analysis
models and methods that are not yet approved by the NRC staff should
submit the models and methods at least six months prior to the date
that a license amendment is needed to authorize restart.
2. For a licensee that submits reload analyses less than six months prior
to the date that a reload license amendment is needed based on models
and methods that are not approved by the staff, the staff cannot assure
an approval can be given within the six month period, and we strongly
suggest that justification for restart should be primarily based on
previously approved analyses or analysis models and methods.
As this letter does not contain any requests for information, an Office of
Management and Budget clearance number is not required.
Darrell G. Eisenhut, Director
Division of Licensing
Page Last Reviewed/Updated Friday, May 22, 2015