ML040290033
| ML040290033 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 01/29/2004 |
| From: | Catherine Haney NRC/NRR/DRIP/RPRP |
| To: | Leyse R - No Known Affiliation |
| Roecklein A, NRR/DRIP/RPRP 415-3883 | |
| References | |
| G20030739 | |
| Download: ML040290033 (2) | |
Text
January 29, 2004 Mr. Robert H. Leyse P.O. Box 2850 Sun Valley, ID 83353
SUBJECT:
DEMAND FOR WITHDRAWAL OF NUCLEAR REGULATORY COMMISSIONS DENIAL OF PETITIONS FOR RULEMAKING Your e-mail sent October 28, 2003, to the Chairman of the Nuclear Regulatory Commission (NRC) was assigned to my office for a response. The e-mail demanded that the Commissions decision to deny PRM-50-73 and PRM-50-73A be withdrawn because of errors in the denial.
Specifically, you contend that the staff was in error when it stated that the occurrence of unusually heavy crud that was seen at River Bend Station in 1998 happened only once. You also stated that ballooning of the fuel cladding will not occur, because overheated cladding will instead be pressed against the fuel pellets. Our technical staff has reviewed the information submitted with your demand for withdrawal and evaluated it against the basis on which the staff had recommended denial of your petitions to the Commission.
In your e-mail you identified several passages in the Federal Register notice (FRN) of denial of your petitions for rulemaking where you assert the staff stated incorrectly that the heavy crud build-up on fuel bundles in the core of the River Bend Station in 1999 only happened once at that plant. The FRN issued on July 16, 2003, regarding PRM-50-73 and PRM-50-73A, stated, As the licensee event report (LER 50-458/99-016-00) indicated, the occurrence of this event was unusual and only happened once during the previous eight cycles for this specific plant.
The NRC staff has not found any other nuclear power plants that experienced this unusually heavy crud formation. Because of this, the NRC staff also indicated that the 1998/1999 event identified by you as evidence of the likelihood of high crud levels had occurred once at River Bend and had not been repeated there, or at any other plant in the United States. You are correct that, subsequent to the NRCs response to PRM-50-73 and 50-73A published in July 2003, River Bend Station documented in October 2003 that some fuel pins had failed in 2002 due to crud build-up. Specifically, the licensee determined that seven (7) fuel pins, out of more than 48,000 that make up the reactor core, had failed and replaced the assemblies containing these seven pins. The licensee performed examinations and analysis of the removed fuel rods and determined in October 2003 that the fuel pins had failed due to accelerated corrosion attributed to crud build-up. However, in your e-mail to the Chairman, you did not provide, nor did the NRC staff find, any information to explain why you believed that the 2002/2003 River Bend crud situation was as severe as in 1998/1999.
At no time during River Bends 2002/2003 operating cycle were any operating limits exceeded and plant conditions did not rise to any threshold that would require a licensee event report (LER) or trigger any other reporting requirement due to crud buildup. The fuel failure was detected by routine coolant activity monitoring currently required by NRC regulations and mitigating actions were implemented by the licensee to prevent any safety significant event from developing. This new evidence further confirms the staffs position in the denial of your petitions that fuel failure caused by crud build-up can be detected and mitigated, that licensees
R. Leyse have procedures in place to do so and are implementing those procedures, and therefore, that no rulemaking is necessary.
In summary, some nuclear power plants continue to experience some crud build-up on fuel pins during operations. The industry is continuing to improve plant operating conditions and attempting to prevent heavy crud build-up from recurring. Neither the heavy crud experienced by River Bend in 1998/1999 nor the crud situation in 2002/2003 involving only seven pins out of 48,000 pins would negate the overall conclusions reached by the NRC staff in its recommendation to deny your petitions. In the staff analysis of your petitions, NRC concluded that there was no evidence provided by you or found by the staff to indicate that this heavy crud build-up had compromised the capability of the Emergency Core Cooling System (ECCS) to mitigate a Loss of Coolant Accident (LOCA).
Your second point questions the staffs statement that [U]nder conditions where heavy crud deposition occurs, fuel damage could eventually lead to cladding cracks or ballooning effects.
The staff continues to believe that this statement is correct in that the ballooning of the fuel pin during a depressurization procedure can result from weakening of the cladding material due to effects such as wear or corrosion.
In conclusion, your demand for withdrawal of the Commissions decision provides no new information that would suggest the staffs technical evaluation of your petitions for rulemaking was in error. Thus, there continues to be no reason to revise the regulations as requested by your petitions.
Thank you for your comments.
/RA/ David L. Skeen for Catherine Haney, Program Director Reactor Policy and Rulemaking Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
ML040290041 (package)
ML033490546 (incoming)
ML040290033 (response)
OFFICE RPRP:PM RPRP:SC DLPM DLPM DSSA NAME ARoecklein DSkeen MWebb WReckley SLu DATE 01/23/04 01/27/04 01/28/04 01/28/04 01/29/04 OFFICE DSSA OGC OGC RPRP:PD NAME JWermeil GMizuno STreby CHaney DATE 01/29/04 01/ /04 01/29/04 01/29/04