ML043140475
| ML043140475 | |
| Person / Time | |
|---|---|
| Site: | Boiling Water Reactor Owners Group |
| Issue date: | 11/09/2004 |
| From: | Gramm R NRC/NRR/DLPM/LPD4 |
| To: | Putnam K BWR Owners Group, Nuclear Management Co |
| Pham B, NRR/DLPM, 415-8450 | |
| References | |
| Download: ML043140475 (4) | |
Text
November 9, 2004 Mr. Kenneth Putnam, Chairman BWR Owners Group Nuclear Management Company Duane Arnold Energy Center 3277 DAEC Rd.
Palo, IA 52324
SUBJECT:
TECHNICAL SPECIFICATION TASK FORCE TRAVELER 357 (TSTF-357),
REVISION 1, "MINIMUM CRITICAL POWER RATIO SAFETY LIMIT"
Dear Mr. Putnam:
By letter dated April 4, 2003, the Nuclear Energy Institute (NEI) submitted a proposal to move the numerical value of the cycle-specific safety limit minimum critical power ratio (SLMCPR) currently in Technical Specification 2.1.1.2 to the Core Operating Limits Report (COLR). TS 5.6.5, COLR, would be modified to specifically require that the numerical value of the SLMCPR be included in the COLR, and that the numerical value be determined in accordance with NRC-approved methodology.
TSTF-357, Revision 1 proposes to replace the SLMCPR with a requirement to maintain the 99.9% departure from nucleate boiling ratio (DNBR) avoidance criterion that bounds the boiling avoidance limit such that 99.9% of the fuel rods in the core would not be expected to experience the onset of transition boiling for two-recirculation-loop and single-recirculation-loop operation. Currently, STS 2.1.1.2 states:
"With reactor steam dome pressure 785 psig and core flow 10% rated core flow:
MCPR shall be [1.07] for two recirculation loop operation or [1.08] for single recirculation loop operation."
On July 20, 2004, the Boiling Water Reactors Owners Group (BWROG) met with the NRC staff to discuss the staffs objection to the approval of TSTF-357. During this meeting, the BWROG requested that the staff formally document its concerns, as well as maintain TSTF-357 in an open status for future resolution. This letter documents the staffs concern regarding approval of TSTF-357.
The discussion in Generic Letter (GL) 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications," provides the background and basis for determining the acceptability of relocating numerical limits for cycle-specific parameters from the TS to the COLR.
Specifically, to be acceptable, the proposed change must be consistent with the guidance provided in GL 88-16, which consists of three separate actions to modify the plant's TS: (1) the addition of the definition of a named formal report that includes the values of cycle-specific parameter limits that have been established using an NRC-approved methodology and consistent with all applicable limits of the safety analysis, (2) the addition of an administrative reporting requirement to submit the formal report on cycle-specific parameter limits to the
K. Putnam Commission for information, and (3) the modification of individual TS to note that cycle-specific parameters shall be maintained within the limits provided in the defined formal report.
To date, the first of the three criteria described above has not been satisfied by the BWROG.
The current vendor methodologies for the proposed TSTF are not sufficiently rigorous enough, with well-documented limitations on such methodologies, for the staff to permit licensees to use them without review. As an example, the staff recently identified two instances, involving two different licensees and vendors, where the vendors inappropriately applied methodologies beyond the NRC-approved ranges or used analytical methods not previously approved as part of the NRC-approved methodology. The staff also noted another mistake in the application of a vendors methodology during a license amendment request for additional margin. In this particular example, the staff<s questions led the licensee to determine that mistakes were made in the analysis and a complete recalculation of the SLMCPR was required. These examples have all occurred within the past seven months, and does not provide the staff confidence in the BWR vendors< methodology.
Based on the reasoning above, the staff will continue to evaluate the BWR plants< safety limits on a cycle-specific basis, and TSTF-357 will not be approved until the staff has greater confidence in the application of vendors< approved methodologies.
If you have further questions on this matter, please contact me at (301) 415-1010.
Sincerely,
/RA/
Robert A. Gramm, Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Project No. 691 cc: See next page
ML043140475 NRC-001 OFFICE PDIV-2/PM PDIV-2/LA SRXB/SC IROB/SC PDIV-2/SC NAME BPham:mp EPeyton FAkstulewicz TBoyce RGramm DATE 11/4/04 11/4/04 11/04/04 11/03/04 11/9/04
BWR Owners Group Project No. 691 cc:
Mr. Joseph E. Conen Vice Chairman, BWR Owners Group DTE Energy - Fermi 2 200 TAC 6400 N. Dixie Highway Newport, MI 48166 Mr. J. A. Gray, Jr.
Regulatory Response Group Chairman BWR Owners Group Entergy Nuclear Northeast 440 Hamilton Avenue Mail Stop 12C White Plains, NY 10601-5029 Mr. H. Lewis Sumner Executive Chairman, BWROG Southern Nuclear Company 40 Inverness Center Parkway P.O. Box 1295 Birmingham, AL 35242 Mr. William Holston Manager, Engineering Services Nine Mile Point - Station OPS Building/2nd Floor P.O. Box 63 Lycoming, NY 13093 Mr. Thomas G. Hurst GE Nuclear Energy M/C 782 3901 Castle Hayne Road Wilmington, NC 28402 Mr. Thomas A. Green GE Nuclear Energy M/C 782 175 Curtner Avenue San Jose, CA 95125 Mr. James Meister Executive Vice Chairman, BWROG Exelon Cornerstone II at Cantera 4300 Winfield Road Warrenville, IL 60555 Mr. William A. Eaton ENTERGY P.O. Box 31995 Jackson, MS 39286 Mr. Aloysius Wrape General Manager, Perform Mail Code GENPL4 Two North Ninth Street Allentown, PA 18101 Mr. Richard Libra DTE Energy Fermi 2 M/C 280 OBA 6400 North Dixie Highway Newport, MI 48166 Mr. James F. Klapproth GE Nuclear Energy M/C A-16 3901 Castle Hayne Road Wilmington, NC 28402