ML052150339
| ML052150339 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/29/2005 |
| From: | Lochbaum D Union of Concerned Scientists |
| To: | Richard Ennis NRC/NRR/DLPM/LPD1 |
| Shared Package | |
| ML052910278 | List: |
| References | |
| TAC MC8035, Y020050167 | |
| Download: ML052150339 (3) | |
Text
Original Due Date: 09/29/2005 Ticket Number: 020050167 Document Date: 07/29/2005 NRR Received Date: 08/03/2005 From:
TACs:
MC8035 David Lochbaum
- YELLOW ***
Richard Ennis For Signature of:
Routing:
Dyer Borchardt Sheron NRR Mailroom
==
Description:==
GE's Nuclear Band-Aids for Vermont Yankee Assigned To:
Contact:
MARSH, LEDYARD (TAD) B Special Instructions:
Union of Concerned Scientists Cltlers and S:Iendsts for EnvIrnrmental Sokons July 29, 2005 Richard B. Ennis, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washginton, DC 20555-0001 Earth
SUBJECT:
GE'S NUCLEAR BAND-AIDS FOR VERIONT YANKEE
Dear Mr. Ennis:
Unable to satisfy the'NRC staffs concerns about the computer methodology p
tfnloyed by thd 'G06-iral Electric Company (GE) in thermal hydraulic analyses of Vermont Yankee at extended power uprate (EPU) conditions in time to meet its own arbitrary schedule pressures, Entergy Nuclear Vermont Yankee, LLC (ENVY) proposed during the June 30, 2005, meeting to apply a "nuclear band-aid" in the form of a temporary license condition increasing the minimum critical power ratio (MCPR) margin by 0.02 (slide 6 from ADAMS Accession Nb. ML051I20135).
- "'44;'
There was no talk during thi s'meeting (or at least'during the limi-ited portion of this meet'ing that members of the public were allowed to observe) and there is no documentation found in ADAMS regarding ENVY's treatment of the other GE "nuclear band-aid" involving MCPR margin. By letter dated July 14, 2005 (ADAMS Accession No. ML052000328), GE informed the NRC staff about its recommended surveillance program to prevent excessive control rod friction caused by inteiference between the fuel channel and the control rod blade. Attachment I to this GE letter clearly indicates that Vermont Yankee is one of the reactors needing to implement this surveillance program.
Reference 1 to the July 140 GE letter is a formal notification to NRC made by GE in accordance with 10 CFR Part 21. That Part 21 notification is dated March 3, 2003 (ADAMS Accession No. ML031420086).
GE reported discovering a phenomenon increasing the potential for fuel channels to bow and interfere with control rod insertions. GE informed NRC that "Absent a detailed plant-specific calculation, a generic interim penalty of 0.02 on the Operating Limit MCPR (OLMCPR) is recommended."
If I understand the GE Part 21 letters properly, the 0.02 MCPR penalty proposed'in March 2003 as an interim measure to be used until a long-term solution svas found and implemented. The'surveillance program transmitted to the NRC in July 2005 is the6xiig-terni so'ution and, once implemented, eliminates the need for that 0.02 MCPR penalty. However, it is not apparent from a review of the publicly available record that ENVY has committed to thL surveillance program recommended by GE.
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July 29, 2005 Page 2 of 2 If the NRC staff feels it is necessary to apply the "nuclear band-aid" sought by ENVY during the June 30, 2005, public meeting, it seems appropriate from both a legal and safety perspective that the license condition either impose a 0.04 MCPR penalty (i.e., 0.02 for the Part 21 safety issue and 0.02 for the EPU analytical methods issue) or impose a 0.02 MCPR penalty along with a requirement that the surveillance program recommended by GE to protect against fuel channel/control rod interference be fully implemented.
Please note that UCS is not petitioning the NRC under 2.206 seeking to compel ENVY to take this action and UCS is not making an allegation to the NRC that ENVY is not implementing the GE recommended surveillance package. Instead, UCS is sharing our insights with the NRC on what should be done. We reserve the right to submit a later 2.206 petition should the final "nuclear band-aids" not fully cover the wound.
Sincerely, David Lochbaum Nuclear Safety Engineer