Overview of a Training Program Produced by LeBlond & Associates, LLC

1. Overview of a Training Program Produced by LeBlond & Associates, LLC • Thanks for taking the time to view this presentation • It’s about ten minutes long • This presentation will advance automatically • until you see this symbol • which means “click to advance” Click on this when you are ready to proceed

2. The Use and Control of Analytical Methodsin accordance with10 CFR 50.59 Developed and Presented by LeBlond and Associates, LLC

3. Contents of This Presentation(color coded by topic) • What is the intended student population? • How is the course structured? • What is the current delivery schedule?

4. What is the intended student population? • This course is intended for personnel who: • Perform Safety Analyses • Review or control the vendor who performs the Safety Analyses • Perform or review any portion of the core reload process • Licensing personnel who are charged with identifying the need for NRC submittals and preparing them, if necessary and • the supervision of the personnel above. • This is intended to be a “Master-Level” class • Potential student population is typically limited to 20 to 25 personnel per site

5. Overall Course Goal • The use of analytical methods in the design and licensing of Nuclear Power Plants is a specialized skill • The application of 10 CFR 50.59, and specifically “criterion eight”, to these methods is a source of confusion This course is intended to eliminate this confusion. • The actual course slides introducing the Course Objectives follow.

6. Course Objectives 1. Overview the major segments of 10 CFR 50.59 Sorted by: • Applicability • Screening • Evaluation 2. Describe the screening process 3. Define and Identify a Design Function 4. Define and Identify the term “Affects” 5. Define the use of PRA techniques to support 10 CFR 50.59 Evaluations 6. Define “Minimal” for dose consequences

7. Course Objectives(cont.) 7. Define and Identify when a Design Basis Limit for a Fission Product Barrier (DBLFPB) has been “exceeded or altered” 8. Define a “Method of Evaluation” and “Input Parameter” 9. Define and Identify when a “Departure from a methodology…” has occurred 10. Identify techniques for the “creation of operating margin” 11. Identify the restrictions on the “creation of operating margin” 12. Identify the conditions when a non-NRC approved method may be implemented. Click to Advance to “How is this course structured?”

8. How is this course structured? • The course is one and a-half days in length • The course briefly overviews the entire 10 CFR 50.59 process to establish and ensure a frame of reference • Typically less than one hour • The guidance provided in NEI 96-07, or the USA Resource Manual, is used to develop key points • The fundamentals of the “Screening Process” are systematically developed in detail … • Design Function • Facility as described in the FSAR • “Adverse affects” with emphasis on the application to analytical methods

9. How is this course structured?(Cont.) • The details of 10 CFR 50.59 c(2) vii and viii are covered • The information above is used to develop Summary Flowcharts for: • “Input Parameters” versus “Method of Evaluation” and • The Screening Process and • The Evaluation Process in accordance with Criterion eight

10. How are the Summary Flowcharts used? • Three detailed examples have been developed. These examples • illustrate the learning objectives • provide a forum for answering student questions • require about four to five hours on the first day • The Summary Flowcharts illustrate the three examples • The course teaches the students to use the Summary Flowcharts on their own • The second day is dedicated solely to review pre-prepared exercises and any situations the students wish to resolve • Students typically can answer their own questions on day #2 Click here to view a few simple, selected course slides

11. Examples to Illustrate “Departure From a Method of Evaluation?” • Changes to Structural Heat Sink Model - Example #2 • Illustration of the “creation of operating margin” • Restrictions • Flexibility/techniques • Use of Non-NRC Approved Codes - Example #3 • Codes/methods • Not described in the UFSAR • Solely used for design analysis • Described in the UFSAR • No “creation of margin” • Not part of the “facility as described …” These are two of the illustrative examples.

12. Example #2Change to Structural Heat Sink Model Comanche Peak has recovered their containment liner with the coating described in Example #1. This was inadvertently treated as a simple maintenance activity. Now the liner recoating is complete and the calculations described in Example #2 have subsequently shown that the maximum, post-accident containment pressure is over the containment design limit by 0.3 psig. Their current outage is scheduled to be complete in three weeks, making any extensive licensing action problematic. As a result, Westinghouse Electric Company, LLC has been contacted for their assistance. The examples consist of a series of questions and answers that illustrate the learning objectives. The answers are presented separately from the questions in blue font.

13. Step #3 Under what conditions, if any, can “margin be created” to resolve Comanche Peak’s concerns? The flowchart on the next slide summarizes the overall process. This example will explore both the flexibility and the restrictions associated with the new 10 CFR 50.59 process. A summary of these features and where they will be illustrated follows the flowchart. This refers to one of the Summary Flowcharts previously described.

14. Each of these steps/questions is intended to promote extensive discussion of the application of the learning objectives. • The flexibility/techniques for “creating margin” that will be explored here are: • Step #4 • Altering the value of an Input Parameter to produce more conservative results. • Step #7 • Altering an element of a method of evaluation, but not “adversely”. • Steps #9 and #10 • Implementing an entirely new method that has been “approved by the NRC for the intended application”.

15. The restrictions on the ”creation of margin” that will be explored are: • Step #5 • Conditions when the selection of an “Input Parameter” is part of the “Method of Evaluation”. • Step #6 • Changing any of the elements of a method unless the results are conservative or essentially the same. • Step #8 • Identification of an “adverse” alteration to a “Method of Evaluation”. • Steps #9 and #10 • Conditions that constitute “approved by the NRC…”.

16. The next two slides are one of the question/answer combinations from Example #2.

17. Step #4 A review of the the major containment structures and components has identified that the concrete missile blocks that sit on top of the CRD booster fans, pressurizer coffin, and the Reactor Coolant Pumps have not been included in the structural heat loss calculations. Specifically, a comparison of the actual analysis inputs, Table 6.2.1-6, and a field walk-down has identified these blocks. Can they be included in the structural heat loss calculation to reduce the peak pressure? Should they be evaluated as “Input Parameters” or as a “Method of Evaluation”? This refers to another of the Summary Flowcharts. To “Input Parameters vs Method of Evaluation”flowchart

18. Yes. They can be included. The modeling of the concrete blocks would qualify as altering an “Input Parameter”. There is no discussion in UFSAR Section 6.2.1.1.3.7(page 6.2.5) regarding the extent, or absence, of modeling these blocks. Contrast that wording with the language of Section 6.2.1.5.6 (page 6.2-26). In that section, the assertion is made that the selection of “surface areas and thicknesses were … conservatively high.” The calculation being described in 6.2.1.5.6 is intended to result in the smallest peak pressure. Note that in all cases, 10 CFR 50, Appendix B, Criterion 3 would apply. That is, these are all “Quality”, Design Bases calculations that require the use of accurate information. This includes use of calculations to develop the value of the “Input Parameter”. (Calculations may be used to determine the value of an “Input Parameter”.) Note that the thermal properties of the coating itself may also hold some potential for refinement here.

19. The preceding slides are indicative of the course’s level of detail. The examples are used to promote detailed discussion on the learning objectives. The second day is used to continue that process, with a combination of pre-prepared classroom exercises and student concerns/questions. Click here to advance to “What is the current delivery schedule?”

20. What is the current delivery schedule? • This class typically can be delivered at your site within four weeks.

21. Closure • Thanks again for your interest and time • For any questions or further details, contact Peter LeBlond at: • 847-549-8775 or • LeBlond@Prodigy.net Just click anywhere to end the show