ML20210G072
| ML20210G072 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 07/29/1999 |
| From: | Emeigh C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9908020288 | |
| Download: ML20210G072 (4) | |
Text
.
uq i, [ par 4 UNITED STATES l
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j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666 0001 l
..... July 29, 1999 l
MEETING REPORT Licensee: Westinghouse Electric Company, LLC (WELCO)
Docket: 70-1151 Date and Time: June 17,1999, at 1:00 p.m.
Location: U.S. Nuclear Regulatory Commission (NRC) 1 Two White Flint North 11545 Rockville Pike Room T-8-A-1 Rockville, MD 20850 i Purpose of Meeting: To discuss licensing requirements on k-eff (Revision 10) !
I Attendees:
4 Name Organization Telephone E-mail l Mary T. Adams NRC/NMSS/FCSS 301-415-7249 mta @nrc. gov Michael Lamastra NRC/NMSS/FCSS 301-415-8139 mxl2@ nrc. gov Charles E. Gaskin NRC/NMSS/FCSS 301-415-8116 ceg1 @ nrc. gov Dennis R. Damon NRC/NMSS/FCSS 301-415-8093 drd1 @ nrc. gov Harry D. Felsher NRC/NMSS/FCSS 301-415-5521 hdf@nrc. gov Wilbur L. Goodwin WELCO (Columbia) 803-647-3282 goodwiwl@ westinghouse.com William D. Newmyer WELCO (Columbia) 803-647 3650 newmyewd@ westinghouse.com NRC met with WELCO on June 17,1999, to discuss concerns relative to WELCO's interpretation that the current license implicitly authorizes them to use "k-eff less than 1.0" when calculating k-eff and that part of Revision 10 was to make that authorization explicit. NRC does not agree with WELCO's interpretation and the purpose of the meeting w:.s for WELCO to clarify their position on the issue.
NRC staff discussed why WELCO's description in their license is not clearly defined and is b different from both other fuel fabricator licensees' description in their licenses and industry /
standards. The following topics were discussed: additive margins, administrative margins, /
" margin of safety" (i.e., confidence of suberiticality), and accuracy of codes (i.e., fundamental knowledge), graphs of acceptable areas of operation, different methods of determining Q{
l subcriticality.
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, 4 WELCO provided information that was not included in their license application, but some of which is included in their " Criticality Safety Handbook", which is still under development at the site. WELCO is not required to submit the handbook for NRC review and NRC has not reviewed the handbook at the site. The following topics were discussed: use of 95/95 confidence level, k-eff of 1.0 condition is placed in fault-trees, and use of the k-eff < 1.0 limit to benchmark early handbook data for simple geometry, graphs of acceptable areas of operation.
WELCO stated that making a change in the k-eff limit would effect only a change in the paperwork (e.g., removal of conservativisms in the modeling, devoting resources to perform
. additional calculations) rather than a change in the physical layout and control of operations at the site. In addition, WELCO stated that new analyses are already being performed at a k-eff value of 0.98 rather than 1.0. WELCO requested time to study the methods used by the other fuel fabrication facility licensees and industry standards before making a commitment to either change their methodology or explain in more detail in their license application their current methodology.
Based on discussions at the meeting, WELCO will (1) under the next revision number, request some minor license changes not related to criticality safety; (2) under the following revision number, request criticality safety license changes as discussed during the Revision 10 review that do not affect the "k-eff less than 1.0" issue, accept a license condition regarding the "k-eff less than 1.0" issue, and withdraw Revision 10; (3) under the following revision number, reprint the approved license so that all the pages have the same date and revision number; and
. (4) study the "k-eff less than 1.0" issue and submit a future amendment request that resolves the issue (i.e., license condition described above),
in addition, the WELCO requested that the table in Chapter 6 of the license that provides a summary of criticality safety controls and assumptions for the systems at the site be removed.
. WELCO and NRC agreed that the table would be kept in the license until the information is provided in a future document submitted to NRC (e.g., Integrated Safety Analysis Summary that is proposed to be required by the draft 10 CFR Part 70 rule).'
During the discussions, it became apparent that (1) both NRC and WELCO are in a close agreement in their understanding of each other's methodologies, (2) both agree that " margin of
- safety" is what is important, (3) both agree that the description in the license is not sufficient, o (4) WELCO believes that a change in the k-eff limit is not necessary, however they recognize the concem that NRC has with a "less than 1.0" description in the license; and (5) NRC does not believe that WELCO is currently operating in an unsafe manner or is in potential violation of their license with respect to the above issues.
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r 3 .
-i WELCO provided information that was not included in their license application, but some of which is included in their " Criticality Safety Handbook", which is still under development at the site. WELCO is not required to submit the handbook for NRC review and NRC has not reviewed the handbook at the site. The following topics were discussed: use of 95/95 confidence level, k-eff of 1.0 condition is placed in fault-trees, and use of the k-eff < 1.0 limit to benchmark early handbook data for simple geometry, graphs of acceptable areas of operation.
WELCO stated that making a change in the k-eff limit would effect only a change in the paperwork (e.g., removal of conservativisms in the modeling, devoting resources to perform additional calculations) rather than a change in the physical layout and control of operations at the site. In addition, WELCO stated that new analyses are already being performed at a k-eff value of 0.98 rather than 1.0. WELCO requested time to study the methods used by the other fuel fabrication facility licensees and industry standards before making a commitment to either change their methodology or explain in more detail in their license application their current methodology.
Based on discussions at the meeting, WELCO will (1) under the next revision number, request some minor license changee not related to criticality safety; (2) under the following revision number, request criticality safety license changes as discussed during the Revision 10 review that do not affect the "k-eff less than 1.0" issue, accept a license condition regarding the "k-eff less than 1.0" issue, and withdraw Revision 10; (3) under the following revision number, reprint the approved license so that all the pages have the same date and revision number; and (4) study the "k-eff less than 1.0" issue and submit a future amendment request that resolves the issue (i.e., license condition described above).
In addition, the WELCO requested that the table in Chapter 6 of the license that provides a summary of criticality safety controls and assumptions for the systems at the site be removed.
WELCO and NRC agreed that the table would be kept in the license until the information is provided in a future document submitted to NRC (e.g., Integrated Safety Analysis Summary that is proposed to be required by the draft 10 CFR Part 70 rule).
During the discussions, it became apparent that (1) both NRC and WELCO are in a close agreement in their understanding of each other's methodologies, (2) both agree that " margin of safety" is what is important, (3) both agree that the description in the license is not sufficient, (4) WELCO believes that a change in the k-eff limit is not necessary, however they recognize the concem that NRC has with a "less than 1.0" description in the license; and (5) NRC does not believe that WELCO is currently operating in an unsafe manner or is in potential violation of their license with respect to the above issues.
cc: Licensee (WGoodwin, RWilliams, and WNewmyer) l Distribution:
Docket 70-1151 PUBLIC NMSS r/f FCSS r/f LIB r/f MLamastra CGaskin i NRC File Center Region il DAyers, Rll Madams DMartin DDamon TPham J
[g:\LIBiwmt-0617.wpd] ~7Shstm i
- See previous concurrence _
OFFICE LIB lC LIB lC Lig//f l(! l NAME HFelsher PShea C8didfQn DATE 07/ 7 /99 07/12/99 07/N)/99 "C" = Copy w/o attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy j Official Record Copy 1
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WELCO provided information that was not included in their license application, but some of which is included in their " Criticality Safety Handbook", which is still under development at the site.' W CO is not required to submit the handbook for NRC review and NRC has not reviewed handbook at the site. The following topics were discussed: use of 95/95 confidence i el, k-eff of 1.0 condition is placed in fault-trees, and use of the k-eff < 1.0 limit to I benchmark ea handbook data for simple geometry, graphs of acceptable areas of operation. j l
WELCO stated th malti ng a change in the k-eff limit would effect only a change in the l
- paoerworK (e.g., re val of conservativisms in the modeling, devoting resources to perform additional calculation rather than a change in the physical layout and control of operations at the site. In addition, W LCO stated that new analyses are already being performed at a k-eff value of 0.98 rather than .0. WELCO rquested time to study the methods used by the other fuel fabrication facility lice ees and industry standards before making a commitment to either change their methodology o explain in more detail in their license application their current methodology.
Based on discussions at the me ting, WELCO will (1) under the next revision number, request some minor license changes not re{ated to criticality safety; (2) under the following revision number, request criticality safety license changes as discussed during the Revision 10 review that do not affect the "k-eff less than 10" 1 issue, accept a license condition regarding the "k-eff less than 1.0" issue, and withdraw Revisjon 10; (3) under the following revision number, reprint the approved license so that all the pages have the same date and revision number; and (4) study the "k-eff less than 1.0" issue and submit a future amendment request that resolves the issue (i.e., license condition described above).
N la addition, the WELCO requested that the table in Chapter 6 of the license that provides a summary of criticality safety controls and assumptions for the systems at the site be removed.
WELCO and NRC agreed that the table would be k'ept in the license until the information is provided in a future document submitted to NRC (e.g), Integrated Safety Analysis Summary that is proposed to be required by the draft 10 CFR Part 70 rule).
\
During the discussions, it became apparent that (1) both NRC and WELCO are in a close agreement in their understanding of each other's methodologies, (2) both agree that " margin of safety" is what is important, (3) both agree that the description,in the license is not sufficient, (4) WELCO believes that a change in the k-eff limit is not necessary, however they recognize the concern that NRC has with a "less than 1.0" description in the license; and (5) NRC does not believe that WELCO is currently operating in an unsafe manner or is in potential violation of their license.
cc: Licensee (WGoodwin, RWilliams, and WNewmyer)
Distribution:
Docket 70-1151 PUBLIC NMSS r/f FCSS r/l LIB r/f MLamastra CGaskin NRC File Center Region il DAyers, Ril Madam. DMartin DDamon TPham
[g:\ LIB \wmt-0617.wpd] _
/7%h9Y OFFICE - LIB lC LIB lO/ ' LIB l NAME HFelsher % PShea /Uh CEmeigh DATE 07/ ~7/99 07/0// 9 4 ' 07/ /99 "C" = Copy w/o attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy Official Record Copy t