ML20205G036
| ML20205G036 | |
| Person / Time | |
|---|---|
| Issue date: | 04/01/1999 |
| From: | Mckenna E NRC (Affiliation Not Assigned) |
| To: | Carpenter C NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9904070100 | |
| Download: ML20205G036 (9) | |
Text
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' UNITED STATES 4
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001
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April-1, 1999 1
MEMORANDUM TO: Cynthia A. Carpenter, Chief Generic Issues and Environmental Projects Branch Division of Regulatory improvement Programs -
Office of Nuclear Reactor Regulation '
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j FROMi Eileen M. McKenna, Senior Reactor Engineer NW1 f/Lff(
'j Generic issues and Environmental Projects Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MARCH 31,1999, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING REVISIONS TO EVALUATION CRITERIA IN 10 CFR 50.59 On March 31,1999, representatives of the Nuclear Energy Institute (NEI) met with representatives of the Nuclear Regulatory Commission (NRC) at the NRC's offices in Rockville, Maryland. Attachment 1 provides a list of meeting attendees.
The purpose of the meeting was to discuss staff-proposed evaluation criteria that may be included in the final rule revision to 10 CFR 50.59. Specifically, the staff is concidering the language shown in Attachment 2 as the criteria to be used instead of the existing criterion on
" reduction in margin of safety as defined in the basis for any technical specification." The staff wanted to discuss the language with industry representatives to be sure that the language was 7
clear and would be interpreted as intended. The staff noted that this proposal is still undergoing./
. internal review and is subject to revision. Further, the staff noted that a decision had not been reached as to how much of the language presented (beyond the two criteria themselves) would f
be in the rule itself rather than in the Statement of Considerations and guidance.
g2, For criterion (vii), the industry representatives stated that they thought the criteria was clear and they had no concerns with the language. The staff had also prepared a proposed definition of
" design basis limit." There was some discussion on the specific words as to whether all of the
~ different words (acceptance criterion, limit, controlling value) were necessary to convey the meaning.' The staff will consider this as it completes its recommendations to the Commission.
Criterion (viii) is intended to control evaluation methods that were presented in the FSAR and used to demonstrate that the facility met its requirements. Since under other criteria in 10 CFR 50.59, and in particular in criterion (vii), licensees would have flexiHlity to adjust input parameters that are used in analyses, as long as results continue to meet the established limits, j
_the staff concluded that control of the methods was necessary. The staff stated that criterion (viii) applies only to changes to methods themselves, such changes would not require
' evaluation against the other criteria. For all other changes to the facility or procedures, the first
. seven criteria in 10 CFR 50.59 would apply.
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C. Carpenter
-2 April 1, 1999 The industry representatives stated that they understood the staff's intent in proposing this criterion on methods. There was also general agreernent with distinguishing between input i
l parameters and methods as to how changes to these respective situations should be evaluated.
The industry representatives expressed some concern that the part of the definition of-departure as being "if the results of the evaluation are in the non-conservative direction" may be l
too restrictive, and they thought that this should reflect a concept of "within the margin of error",
such that very minor variations in results would not result in the need for prior approval of use of the method. The staff was sympathetic to the concept, but noted that this was difficult to
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embrace in a rule.
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There was also some concern expressed that " methods used in establishing the design bases or safety analyses" was too broad, and it was suggested that this be limited to " safety analyses". The staff noted that the criterion was intended to include such matters as seismic design or wind loadings that are part of the design bases, for which analyses are described in the FSAR, and for which changes to the methods could impact upon the facility performance.
The staff agreed that not every part of the design bases would have methods of evaluation described in the FSAR.
In summary, the participants noted that the discussion had been helpful in understanding how these criteria might be implemented, and about some areas where further development may be needed.
Project No. 689 Attachments: As stated cc w/att: See next page i
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i C. Carpenter 2-April 1, 1999 The industry representatives stated that they understood the staff's intent in proposing this criterion on methods. There was also general agreement with distinguishing between input
- parameters and methods as to how changes to these respective situations should be evaluated.
The industry representatives expressed some concern that the part of the definition of departure as being "if the results of the evaluation are in the non-conservative direction" may be
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too restrictive, and they thought that this should reflect a concept of "within the margin of error",
such that very minor variations in results would not result in the need for prior approval of use of
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the method. The staff was sympathetic to the concept, but noted that this was difficult to embrace in a rule.
There was also some concern expressed that " methods used in establishing the design bases or safety analyses" was too broad, and it was suggested that this be limited to " safety analyses". The staff noted that the criterion was intended to include such matters as seismic design or wind loadings that are part of the design bases, for which analyses are described in the FSAR, and for which changes to the methods could impact upon the facility performance.
The sta'f agreed that not every part of the design bases would have methods of evaluation described in the FSAR.
In summary, the participants noted that the discussion had been helpful in understanding how these criteria might be implemented, and about some areas where further development may be needed.
Project No. 689 Attachments: As stated cc w/att: See next page DISTRIBUTION: See attached page Document Name: g:\\emm\\msum0331
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NAME EMcKenna:sw FAksfutewicz DATE l
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I NRC/NEl MEETING ON 10 CFR 50.59 CRITERIA LIST OF ATTENDEES March 31,1999 l
NAME ORGANIZATION Tony Pietrangelo NEl Russ Bell NEl Ralph Beedle NEl David Matthews NRC/NRR Frank Akstulewicz NRC/NRR Kamal Manoly NRC/NRR Eileen McKenna NRC/NRR Stu Magruder NRC/NRR Mary Drouin NRC/RES Chris Jackson NRC/NRR Nancy Chapman SERCH/Bechtel Kim Green NUS-IS Kenneth Hutko PSE&G Tony Hsia NRC/OCM Mike Markley NRC/ACRS Janice Moore NRC/OGC Jenny Weil McGraw-Hill Everett Whitaker TVA Lara Helfer Winston and Strawn j
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PROPOSED CRITERIA FOR 10 CFR 50.59 (As presented at 3/31/ meeting)
CRITERION 7 -
Prior NRC approval required if the change, test or experiment would:
(vii) result in a. design basis limit for a fission product barrier being.
exceeded or altered.
Design basis limit for a fission product barrier means an acceptance criterion established during the licensing review as presented in the final safety analysis report for any parameter (s) used to determine the integrity of a barrier. The limit is the controlling value for the parameter at which confidence in the integrity of the barrier begins to decrease.
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CRITERION 8 - METHODS Prior NRC approval required if 'a change, test or experiment would:
(viii) result in.a departure from a method of evaluation used in establishing the design bases or in the safety analyses.
Departure from a method of evaluation means (i) changing any of the elements of the method described in the FSAR (as updated) such that the results of the revised method are in the non-conservative direction, or (ii) changing from a method described in the FSAR (as updated) to another method unless that method has been approved by the NRC for the facility i
and intended application.
Methods of evaluation means the calculational framework for evaluating behavior or response, as for the reactor or any system, structure or component. This includes the following:
-data correlations
- means of data reduction
- physical constants or coefficients
- mathematical models
- assumptions in the computer program
- specified factors to account for uncertainty in measurements or data
- statistical treatment of results
- dose conversion factors
)
How the plant and its response are modeled is part of the method (controlled by above criterion), the charactoristics of the plant are input parameters, changes to which are controlled by the other seven criteria (and in some cases TS) input parameters: values derived directly from the physical characteristics of structures, systems or components, or processos in the plant. These would include such things as:
Flows, temperatures, pressures, dimensions (volume, weight, size),
i response times -
Non-conservative direction: For the same situation being analysis, the "new" method predicts a response further from the limit that must be
O satisfied than did the old. This can be determined by benchmarking (new vs. old code), or may be apparent from the nature of the changes between the methods.
Design bases and safety analyses - As per 50.2, functions and controlling values for SSC; safety analyses are those demonstrations that plant response to postulated events meets the applicable acceptance criteria.
In the soc, we would discuss that the reason we want to maintain control of the methods is that this provides the confidence that demonstrating that the other criteria are met maintains the regulatory envelope that NRC reviewed as part of its licensing decision.
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Nuclear Energy Institute Project No. 689 cc:
Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute Suite 400 Suite 400 1776 l Street, NW 1776 l Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations
- Nuclear Energy Institute ABB-Combustion Engineering, Inc.
Suite 400 12300 Twinbrook Parkway, Suite 330 1776 l Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director -
1 Licensing 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 P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 l'
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Distribution: Mtg. Summary w/ NEl Re'10 CFR 50.59 Criteria Dated April 1,1999 Hard Coov Central Files
' PUBLIC PGEB R/F OGC ACRS SMagruder EMcKenna EMail SCollins/RZimmerman BSheron -
BBoger WKane DMatthews SNewberry GHolahan JStrosnider CCarpenter FAkstulewicz i
EMcKenna CJackson KManoly MDrouin, RES l
MMarkley, ACRS J
l JMoore, OGC j
l SShankman, NMSS PEng, NMSS PBrochman, NMSS GTracy, EDO MMiller, OCM JBeali, OCM THsia, OCM CCraig, OCM BMcCabe, OCM l
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