ML20206D893
| ML20206D893 | |
| Person / Time | |
|---|---|
| Issue date: | 04/28/1999 |
| From: | Mckenna E NRC (Affiliation Not Assigned) |
| To: | Carpenter C NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9905040273 | |
| Download: ML20206D893 (6) | |
Text
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UNITED STATES p-s j
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001 April 28, 1999 MEMORANDUM TO: Cynthia A. Carpenter, Chief Generic Issues, Environmental, Financial and Rulemaking Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation FROM:
Eileen M. McKenna, Senior Reactor Engineer k4%
Generic Issues, Environmental, Financial and Rulemaking Branch Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF APRIL 26,1999, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING REVISIONS TO EVALUATION CRITERIA IN 10 CFR 50.59 On April 26,1999, 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 and related issues concerning implementation of the revised final rule. Specifically, as discussed at an earlier meeting on March 31,1999, the staff is considering addition of a criterion concerning control of evaluation methods described in the FSAR. The staff wanted to discuss the language with industry representatives to be sure that the language was clear and would be interpreted as intended.
The staff noted that the proposal is still undergoing internal review and is subject to revision.
Criterion (viii) is intended to control evaluation methods that were presented in the FSAR and used to demonstrate that the facility met its design bases requirements. Since under the other criteria in 10 CFR 50.59, licensees would have greater flexibility to adjust input parameters that are used in analyses, as long as results continue to meet the established limits, the staff concluded that control of the methods was necessary. The staff stated that criterion (viii) applies only to changes to methods themselves; changes to methods 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 (as being revised) would apply.
At the previous meeting, there had been some concern expressed that the definition of
- departure, as meaning if the result of a revised method was "non-conservative," might be too restrictive. The staff had been considering this aspect, and stated during the meeting that the current proposal being circulated included a concept of " essentially the same." The staff is considering this new language to take into account situations where the result is a small change 5
[b{I not in the conservative direction, but where the "nonconservatism" is such that it is within the margin of error for the type of analysis being performed. Using this new conceptual language, very minor variations in results would not result in the need for prior NP.C approval before a For instance, the staff noted that results pPsC3 (th-licensee could use the revised or alternative method.
would be viewed as essentially the same if the variations are explainable as routine analysis g5040273990428 Y'
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= C. Carpenter
-2 April'28, 1999
. sensitivities, and where the differences in the results are not a factor in determining whether any limits or criteria are satisfied.
NEl stated that they still had some concern about the intended scope of the methods criterion.
Specifically, NEl expressed the view that the phrase " methods used in establishing the design bases or safety analyses" was too broad. They thought this could be better defined by itemizing what functions (and thus, the controlling values that would be determined by the analyses with methods in the FSAR), as those: used to demonstrate integrity of fission product
. barriers; for calculating radiological consequences, and a third set of those used to demonstrate
. compliance with regulations (e.g., the General Design Criteria, among others), license conditions, TS and orders. There was also some discussion about how " described in the FSAR" should be interpreted for such statements as " Computer code X was used for this analysis" (where the code is presented in a topical report or other document). The staff's view was that this statement was a description of the method used, and thus, would fall under the scope for evaluation. The staff also noted that when using a different method, albeit one that has been accepted by NRC, it must be clear that the approval was either generic (for certain types of facilities, range of conditions, etc.), or plant-specific. The staff stated that it is not generally sufficient to conclude that because a particular method was approved for a specific application or plant that it is acceptable for use at another. The staff explained that the extert of review conducted on methods, if intended for plant-specific use, may have been more limited than if generic use was intended, and that therefore, use by another plant (with different physical configurations or characteristics) might not have been covered by the staff's review.
The NEl also stated that with respect to guidance, they plan to modify NEl 96-07 to reflect the final rule, which they would hope to have available for NRC review by fall 1999. The staff asked about guidance for Part 72 facilities. NEl stated that they did not want to delay the revision of NEl 96-07 for reactors to include specific guidance, but would be willing to help develop examples or supplemental guidance later. The staff also noted that there may be a need for supplemental guidance on applicability to aging management programs under Part 54.
The staff and NEl also discussed other issues. For instance, the staff asked if there were any further comments on " minimal" increases in frequency or likelihood of accidents or malfunctions. NEl stated that it planned to send NRC a letter around April 30,1999, summarizing their thoughts on this topic, as well as views on other issues such as control of evaluation methods.
Project No. 689
Attachment:
As stateo cc w/att: See next page 4
C. Carp:nter
-2 April 28, 1999 sensitivities, and where the differences in the results are not a factor in determining whether any limits or criteria are satisfied.
I l
NEl stated that they still had some concern about the intended scope of the methods criterion.
Specifically, NEl expressed the view that the phrase " methods used in establishing the design l
bases or safety analyses" was too broad. They thought this could be better defined by l
itemizing what functions (and thus, the controlling values that would be determined by the l
analyses with methods in the FSAR), as those: used to demonstrate integrity of fission product barriers; for calculating radiological consequences, and a third set of those used to demonstrate l
compliance with regulations (e.g., the General Design Criteria, among others), license l
conditions, TS and orders. There was also some discussion about how " described in the FSAR" should be interpreted for such statements as " Computer code X was used for this i
analysis" (where the code is presented in a topical report or other document). The staff's view l
was that this statement was a description of the method used, and thus, would fall under the l
scope for evaluation. The staff also noted that when using a different method, albeit one that l
has been accepted by NRC, it must be clear that the approval was either generic (for certain types of facilities, range of conditions, etc.), or plant-specific. The staff stated that it is not generally sufficient to conclude that because a particular method was approved for a specific application or plant that it is acceptable for use at another. The staff explained that the extent of review conducted on methods, if intended for plant-specific use, may have been more limited I
than if generic use was intended, and that therefore, use by another plant (with different physical configurations or characteristics) might not have been covered by the staff's review.
The NEl also stated that with respect to guidance, they plan to modify NEl 96-07 to reflect the l
final rule, which they would hope to have available for NRC review by fall 1999. The staff asked -
l about guidance for Part 72 facilities. NEl stated that they did not want to delay the revision of l
NEl 96-07 for reactors to include soecific guidance, but would be willing to help develop examples or supplemental guidance later. The staff also noted that there may be a need for i
supplemental guidance on applicability to aging management programs under Part 54.
l The staff and NEl also discussed other issues. For instance, the staff asked if there were any l
further comments on " minimal" increases in frequency or likelihood of accidents or malfunctions. NEl stated that it planned to send NRC a letter around April 30,1999, summarizing their thoughts on this topic, as well as views on other issues such as control of evaluation methods.
Project No. 689 Attachments: As stated cc w/att: See next page l
DISTRIBUTION: See attached page Document Name: g:\\emm\\msum0426 OFFICE PM:RGQgg SC:Rgh NAME EMcKe$na:sw FAblewicz DATE 4/M/99 4/[/99
NRC/NEl MEETING ON 10 CFR 50.59 CRITERIA LIST OF ATTENDEES April 26,1999 NAME ORGANIZATION Tony Pietrangelo NEl Russ Bell NEl David Matthews NRC/NRR Cindi Carpenter NRC/NRR Frank Akstulewicz NRC/NRR Eileen McKenna NRC/NRR Stu Magruder NRC/NRR Chris Jackson NRC/NRR Steve Hoffman NRC/NRR Tom Bergman NRC/NRR Mark Satorius NRC/OEDO Claudia Craig NRC/OCM Nancy Chapman SERCH/Bechtel Kim Green NUS-IS Mike Markley NRC/ACRS Janice Moore NRC/OGC Jenny Weil McGraw-Hill
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 i Street, NW 1776 i 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 i Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708-Mr. David Modeen, Director Engineering Nuclear Energy Institute Suite 400 1776 i Street, NW V{ashington, DC 20006-3708 Mr. Anthony Pietrangelo, Director 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 t
Distribution: Mtg. Summary w/ NEl Re 10 CFR 50.59 Criteria Dated April 28. 1999 Hard Cooy Central FHes PUBLIC RGEB R/F OGC ACRS SMagruder EMcKenna EMail SCollins/RZimmerman BSheron BBoger WKane DMatthews SNewberry GHolahan JStrosnider CCarpenter FAkstulewicz EMcKenna CJackson KManoly MDrouin, RES MMarkley, ACRS JMoore, OGC SShankman, NMSS PEng, NMSS PBrochman, NMSS GTracy, EDO MMiller, OCM JBeali, OCM THsia, OCM CCraig, OCM BMcCabe, OCM
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