Scheduling Guidance for Licensee Submittals of Reloads That Involve Unreviewed Safety Questions (Generic Letter No. 84-20)

                               UNITED STATES 
                        NUCLEAR REGULATORY COMMISSION
                           WASHINGTON, D.C. 20555

                              August 20, 1984 

TO ALL LICENSEES OF OPERATING REACTORS AND APPLICANTS FOR OPERATING LICENSE 

Gentlemen: 

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


8408200275 
.