ML20006C043

Forwards Response to NRC Bulletin 89-003.Util Nuclear Fuels Dept Designs or Reviews & Approves Each Core Reload for Plants & Refueling Operations Recently Reviewed to Ensure Appropriate Procedural Controls in Place

ML20006C043
Person / Time
Site:	Byron, Braidwood, Zion, 05000000
Issue date:	01/29/1990
From:	Richter M COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-89-003, IEB-89-3, LMW:MHR:0603T, LMW:MHR:603T, NUDOCS 9002060230
Download: ML20006C043 (5)

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.~ January 29, 1990 ie U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

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Subject:

Zion Station Units 1 and 2 Byron. Station Units 1 and 2 Braidwood Station Units 1'and 2 Response to NRC Bulletin 89-03 NRC Docket Nos. 50-295/304, 10-45t/455 and 50-456/457 t

Reference:

NRC Bulletin 89-03, dated November 21, 1989.

Dear Sir:

NRC Bulletin 89-03 (Bulletin), addressed to all holders-of operating 3

. licenses or-construction permits for pressurized water reactors', provided information on the potential loss of required shutdown margin-(SDM) during the movement and placement <of highly reactive fuel during refueling operations.

Addressees were requested to take the actions presented in the Bulletin to prevent potential. violations of required-SDM. Additionally, the Bulletin-required a response which would confirm that addressees have taken, or will take, the; requested. actions.

The' Attachment to this letter provides Commonwealth Edison Company's (CECO) response for Zion, Byron and Braidwood Stations to NRC Bulletin 89-03.

Ceco shares the NRC concerns on this subject and is ensuring that..the

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appropriate controls are, or will be, established to prevent the loss of

. required SDM.

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' U.S. zNuclear Regulatory Conunission January-29, 1990

- 6;i Please' direct any questions that you may have concerning this response to this: office.

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Respectfully,

.b M.H. Richter Generic Issues Administrator

-Attachment cc: A.B. Davis - Regional Administrator, Region III Resident Inspector - E, BY, BW

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ATTACHMENT RESPONSE TO NRC BULLETIN 89-03 FOR ZION, BYRON AND BRAIDWOOD STATIONS f

~ Egguested Action Assure that any intermediate fuel assembly configuration (including control

- rods) intended to be used during refueling is identified and evaluated to maintain sufficient refueling boron concentration to result in a minimum shutdown margin of approximately 5%.

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U Commonwealth Edison's Nuclear Fuel Services Department (NFS) designs, or reviews and approves, each core reload for Zion, Byron and Braidwood Stations. For each core reload, NFS provides the stations with the necessary 7

boron concentration required to maintain the refueling shutdown margin for a fully loaded, as-designed core. -In addition, NFS provides'any fuel move

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restrictions which will be necessary to ensure shutdown margin in intermediate configurations. The stations utilize this guidance provided by NFS when generating and reviewing the Nuclear Component Transfer List (NCTL), which controls the movement of fuel, and when establishing the boron concentration for core alterations. Adherence to the NFS guidance ensures that the shutdown

-margin required by the station's Technical Specifications for core alterations will be maintained.

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ATTACHMENT (cont'd) w."

Reguested Action Assure that fuel loading procedures only allow those intermediate fuel assembly configurations that do not violate the allowable shutdown margin and E

that these. procedures are strictly adhered to.

Reapnnst The station procedures which control the Nuclear Component Transfer List (NCTL) and the conduct of refueling operations have recently been reviewed to ensure appropriate procedural controls are in place to ensure shutdown margin li.s maintained during core alterations. Procedure revisions will be implemented at each station to ensure that:

1) the NFS guidance to ensure shutdown margin will be followed during the generation, and review, of the NOTL(s); 2)- any subsequent revisions (i.e., field or "on-shif t" revisions, etc.)_to'an NCTL associated with core related fuel moves will require the approval of a qualified member of the station's, Nuclear Engineering Group; 3)

NFS will be notified prior to.any deviation from their guidance for further evaluation; and 4)'the boron concentration level provided by NFS will be taken into consideration by the station when establishing the boron concentration for' core alterations.

It is expected that all procedure revisions at each station will be' completed by August 1, 1990.

If the procedure revisions are not completed prior to the start of any Spring 1990 refueling outage (March 1990 outages for Zion and Braidwood Stations), interim controls (i.e.,

temporary procedure revisions, operating orders, etc.) will be implemented prior to the start of the refueling outage.

For Byron Station (Unit 1), which is' presently in a refueling outage, the Fuel Handling Foremen,who supervise core alterations are cognizant of the Bulletin concerns and the NFS guidance for the reload. Additionally, a qualified member of Byron's Nuclear Engineering Group will be on-site during the unit's core load.

It should be noted that strict procedural adherence is mandatory.at all Comr.onwealth Edison nuclear stations.

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ATIACHMENT,(cont'd) i Regunted_Aclion Assure that the staff responsible for refueling operations is trained in the' procedures recommended in Item 2 above and understand the potential consequences of violating these procedures. This training should include'the fundamental aspects of criticality control with higher enriched fuel assemblies.

L Responam It has been the practice at the PWR stations to conduct training prior to

' refueling outages for fuel handling personnel responsible for refueling operations.. This training consists of a review of procedures and technical-specifications associated with refueling operations. Future training will re-emphasize the importance of procedural adberence and the potential consequences of violating the procedures, including the loss of required SDM and potential for inadvertent criticality should an improper intermediate fuel-configuration or boron concentration be utilized. Additionally, the training will include any recent industry information associated with refueling j

operations as deemed appropriate.

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