ML20134D482

Summary of 960820 Meeting W/Nuclear Energy Inst,Epri & Several Licensees in Rockville,Md to Discuss Draft Rev a of NEI96-07, Guidelines for 10CFR50.59 Safety Evaluation, Submitted for Staff Review on 960813

ML20134D482
Person / Time
Issue date:	10/17/1996
From:	Stewart Magruder NRC (Affiliation Not Assigned)
To:	Matthews D NRC (Affiliation Not Assigned)
References
PROJECT-689 NUDOCS 9610220285
Download: ML20134D482 (13)

Text

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UNITED STATES g

j NUCLEAR REGULATORY COMMISSION g

WASHINGTON, D.C. 20666 4 001 October 17, 1996 MEMORANDUM TO:

David B. Matthews, Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FRON:

Stewr.rt L. Magruder, Project Manager M q, d

Generic Issues and Environmental l

Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF AUGUST 20, 1996, MEETING WITH THE NUCLEAR ENERGY INSTITUTE l

On August 20, 1996, representatives of the Nuclear Energy Institute (NEI), the Electric Power Research Institute (EPRI), and several licensees met with representatives of the Nuclear Regulatory Commission (NRC) at the NRC's offices in Rockville, Maryland. Attachment 1 provides a list of meeting i

attendees.

The purpose of the meeting was to discuss Draft Revision A of NEI 96-07, l

" Guidelines for 10 CFR 50.59 Safety Evaluations," which was submitted for staff review by NEI letter dated August 13, 1996. NE! opened the meeting by stating that this document was an update to NSAC-125, and that it was submitted with the intention of stimulating dialogue between the industry and the staff on 50.59 issues. NEI indicated that they were responding to two issues raised within the past year by the staff. The issues are, as follows:

the scope of 50.59 reviews (i.e. Whether changes that are not explicitly described in the FSAR should be included); and the use of compensatory measures that outweigh any potential increase in probability of occurrence or consequences or reduction in margin. The only changes from NSAC-125 are related to the second issue and are highlighted in Sections 3.4, 3.5, 3.6, and 3.8.

NEI stated that they have a working group that meets to discuss 50.59 issues and that the original intent of the group was to combine NEI's commitment management guidance with a major update to NSAC-125. Although the group has not yet completed this task, NEI decided to submit the draft document to try to respond to the issues raised by the staff and to try to get approval of a document so that the industry and the staff can start discussions from common ground. NEI stated that their goal is still to make additional improvements to the document in the future.

NEI next made a pre.,entation on the safety review process and the industry philosophy on the margin of safety issue. They presented several examples of situations in which, they felt, extra margin exists between values listed in i

the FSAR and those found acceptable in an SER and industry standards. NEI J

U a1 Ph03 lo7fl 9610220205 961017 PDR PROJ 689 PDR WW3

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s DISTRIBUTION:

SUMMARY

OF AUGUST 20, 1996 MEETING W/NEI DATED October 17, 1996 Hard Cggy Project:.F.ile PUBLIC i

PGEB r/f ACRS OGC 1

SMagruder E-Mail FMiraglia RZimerman i

AThadani TMartin BSheron FGillespie GHolahan BBoger CGrimes l

WDean FAkstulewxiz MMalloy EMcKenna JWilson GThomas JSchiffgens DWigginton JHoore CMarco JCanady, RII CMiller

D. Matthews

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October 17, 1996 restated the industry position that a nonconservative change in the value of a parameter listed in the FSAR does not constitute an increase in the consequences of an accident or a decrease in the margin of safety provided that the new value is still less than the acceptable value listed in the SER.

The group then discussed the use of new models by licensees to perform safety analyses.

It was agreed that licensees should use new assumptions in the old model for the 50.59 analysis.

The use of compensatory actions was also discussed.

NEI used an example of increasing the test interval for a component but compensating by focusing the tests on parts that have a history of causing failures. The NEI handouts are included as Attachment 2.

The staff next raised the concern that some licensees have good 50.59 processes but don't do a good job of recognizing what changes should be subject to the process.

NEI responded that the industry is aware of the problem and is encouraging licensees to conduct more training for their employees on the subject.

The next major topic of discussion was Enclosure 1 to the August 13, 1996, letter from NEI. The enclosure listed NRC points made at a July 23, 1996, Nuclear Strategic Issues Advisory Committee meeting along with the industry position for each point.

The group had a long discussion of the requirements of 10 CFR 50.71(e). No consensus was reached, however, it was decided that the scope of an FSAR may have to be expanded. The next subject was the definition of licensing basis.

NEI stated that they generally agree with the 10 CFR Part 54 definition. They believe, however, that voluntary commitments from licensees that are not required by regulations should not be part of the licensing basis.

The final subject of the meeting was a brief discussion of non-conforming conditions. The staff emphasized the importance of addressing issues in a timely manner and tracking items effectively. NEI responded that they believe that Section 4.0 " Evaluation Process Guidance," of NEI 96-07 effectively addresses this issue.

The meeting concluded with a commitment from the staff to review NEI 96-07 and agreement by all parties that further discussions are required to resolve these issues.

Project No. 689 Attachments: As stated

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D. Matthews October 17, 1996 4

restated the industry position that a nonconservative change in the value of a parameter listed in the FSAR does not constitute an increase in the consequences of an accident or a decrease in the margin of safety provided that the new value is still less than the acceptable value listed in the SER.

j The group then discussed the use of new models by licensees to perform safety j

analyses.

It was agreed that licensees should use new assumptions in the old model for the 50.59 analysis. The use of compensatory actions was also discussed. NEI used an example of increasing the test interval for a

{

component but compensating by focusing the tests on parts that have a history of causing failures. The NEI handouts are included as Attachment 2.

1 The staff next raised the concern that some licensees have good 50.59 i

processes but don't do a good job of recognizing what changes should be i

subject to the process. NEI responded that the industry is iware of the problem and is encouraging licensees to conduct more training for their employees on the subject.

The next major topic of discussion was Enclosure 1 to the August 13, 1996, letter from NEI. The enclosure listed NRC points made at a July 23, 1996, Nuclear Strategic Issues Advisory Committee meeting along with the industry.

position for each point. The group had a long discussion of the requirements of 10 CFR 50.71(e).

No consensus was reached, however, it was decided that the scope of an FSAR may have to be expanded. The next subject was the definition of licensing basis. NEI stated that they generally agree with the 10 CFR Part 54 definition. They believe, however, that voluntary commitments from licensees that are not required by regulations should not be part of the l

licensing basis. The final subject of the meeting was a brief discussion of non-conforming conditions. The staff emphasized the importance of addressing issues in a timely manner and tracking items effectively. NEI responded that they believe that Section 4.0 " Evaluation Process Guidance," of NEI 96-07 effectively addresses this issue.

The meeting concluded with a commitment from the staff to review NEI 96-07 and agreement by all parties that further discussions are required to resolve these issues.

Project No. 689 Attachments: As stated Document Name: G:\\SLM1\\MSUM820.96 To receive a copy of this document, i icate in the box:

"C" - Copy without attachment / enclosure "E" - Copy wit _ attachment /epc)psure f "N" - No copy 0FFICE PM:PEGB E SC:PGEB Wl BC: pef 4//, lN NAME SMagruder:sw <tm FAkstulbE li DMat%LNd DATE 10/10/96 10/lb /96N 10/M/96 0FFICIAL RECORD COPY

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NRC/NEI MEETING ON 10 CFR 50.59 ISSUES LIST OF ATTENDEES August 20, 1996 N8ME ORGANIZATION Doug Walters NEI Steve Floyd NEI Steven Root Edison International Carter Rogers Arizona Public Service Co.

Roger Walker Texas Utilities Electric Alan Passwater Union Electric Jack Haugh EPRI Margo Barron NUS/LIS Bob Fraser Northern States Power Co.

William Cross Southern Technical Services Ken Wilson Florida Power Corp.

1 Mark Beaumont Westinghouse Mike Schoppaan Florida Power & Light Tricia Heroux EPRI Frank Lentine Commonwealth Edison Joe Hegner Virginia Power Chuck Coker Edison International Bob Newkirk Detroit Edison Jeb Deloach Northeast Utilities Jerry Wilson NRC/NRR/DRPM David Matthews NRC/NRR/DRPM Eileen McKenna NRC/NRR/DRPM George Thomas NRC/NRR/DSSA John Schiffgens NRC/NRR/DSSA David Wigginton NRC/NRR/DRP Janice Moore NRC/0GC Catherine Marco NRC/0GC Chris Grimes' NRC/NRR/DRP Brian Grimes NRC/NRR/DRPM James Canady NRC/ Region II Christopher Miller NRC/0CM Stu Magruder NRC/NRR/DRPM i-

NEI 96-O'1 Rsvision A July 1996 i

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NEI 96-07 Revision A July 1996 Design Failure Point or System Limitetton (Unacceptable condition)

A Mergin of Safety (Regulated by NRC, Requires Rppropel to Change)

V Rcceptance Limits as Defined in the Basis for eng Technical Specification a

Range Allowed for Operation and Analyzed Transients V

• Operating Point. Rnelysis Rssumption or Set Point

• May be reallocated without prior NRC appropel using consistent methods approved by the NRC If all parameters remain within preplously approved ecceptance limits and meet technical specifications.

Figure 3-1.

Relationship of Limits. Operating Points and Margin of Safety 17

Marcin of Safety Examole:

STRESSES IN PIPING, EQUIPMENT AND SUPPORTS FAILURE STRESS A

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I MARGIN OF SAFETY I

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CODE ALLOWABLE STRESS FOR

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v CALCULATED STRESS FOR APPLICABLE LOAD COMBINATION (Not identified in UFSAR or SER)

Example:

ASME III Class I loading combination for seismic + LOCA. SER states acceptibility based on < code allowable; does MQI say acceptibility is based on margin between calculated value and limit.

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Marcin of Safety Examole:

ACCIDENT CONSEQUENCES (Pncs > REGULATORY LIMIT)

SYSTEM FAILURE LIMIT

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CALCULATED Pac 3 FOR LIMITING FAULT EVENT (Stated in UFSAR + SER)

Example:

Feedwater line break event. SER states acceptability based on consequences <

code allowable; does N.QI say acceptibility is based on margin between calculated and code allowable.

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Miggin of Safety Examole:

ACCIDENT CONSEQUENCES (DNBR)

FUEL FAILURE (DNB)

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CALCULATED DNBR FOR APPLICABLE EVENT (Stated in UFSAR + SER)

Example:

Decrease in heat removal event. SER states acceptibility based on DNBR > 1.19; does HQI say acceptibility is based on margin between calculated value and limit.

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Margin of Safety Examole:

ACCIDENT CONSEQUENCES (RCS PRESSURE)

SYSTEM FAILURE LIMIT

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v CALCULATED Pncs FOR APPLICABLE EVENT (Stated in UFSAR + SER)

Example:

Decrease in heat removal event. SER states acceptibility based on consequences

< 110% of design; does MQI say acceptibility is based on margin between calculated value and limit.

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j Marcin of Safety Examole:

ACCIDENT CONSEQUENCES (NON-LOCA DOSE) 4 10 CFR 100

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Example:

Steam Generator Tube Rupture event. SER states acceptibility based on dose meeting "small fraction of 10 CFR 100"; does MQI say acceptibility is based on margin between calculated value and limit.

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NEI Project No. 689 a

cc:

Mr. Thomas Tipton, Vice President Operations and Engineering Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708 Ms. Lynnette Hendricks, Director Emergency Preparedness and Waste Regulation Nuclear Energy Institute

. Suite 400 1776 I Street, NW Washington, DC 20006-3708 Mr. Ronald Simard, Director Advanced Reactors Programs Nuclear Energy Institute Suite 400 1776 I Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation i

P.O. Box 355 i

Pittsburgh, Pennsylvania 15230 d

e