RBG-30705, Application for Amend to License NPF-47,revising TS 6.9.3.2,part of Colr.Revision Indicates Cycle 5 Impact on Operating Limit Not Due to Core Verifications

Application for Amend to License NPF-47,revising TS 6.9.3.2,part of Colr.Revision Indicates Cycle 5 Impact on Operating Limit Not Due to Core Verifications

ML20045G247
Person / Time
Site:	River Bend
Issue date:	07/02/1993
From:	Booker J GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20045G248	List: ML20045G255 RBG-30705, Application for Amend to License NPF-47,revising TS 6.9.3.2,part of Colr.Revision Indicates Cycle 5 Impact on Operating Limit Not Due to Core Verifications
References
RBG-30705, NUDOCS 9307130091
Download: ML20045G247 (8)

Text

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.' E egl GULF STATES UTILITIES COMPANY R!vtR MND STA flCN POST OFFICE BOX 220

$ f DIANO5VtLLE, LOU)SIANA 70'/7b AM A CrjnF y;d th G v4 346 86$1 July 2, 1993 RBG-30705 File No. G9.5, G9.42 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

River Bend Station - Unit 1 Docket No. 50-458 Gulf States Utilities Company (GSU) hereby files an application to amend the River Bend Station - Unit 1 Technical Specifications, Appendix A to Facility.

Operating License NPF-47, pursuant to 10CFR50.90. This application is filed to revise Technical Specification (TS) 6.9.3.2, pan of the Core Operating Limits Report section of the TS, to indicate that for Cycle 5 the impact on the operating limit minimum critical power ratio from a misoriented fuel bundle need not be considered due to extensive core verifications.

Attachment I to this letter provides the justification for this proposed revision to the Technical Specifications as shown in Attachment 3. Attachment 2 furnishes the no significant hazards consideration discussion.

If you have any questions or comments, please contact Mr. Leif L. Dietrich of my staff at (504) 381-4866.

Sincerely, b

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J.E. Booker i

Manager - Safety Assessment and Quality Verification River Bend. Nuclear Group DN JIR/

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U.S. Nuclear Regulatory Conunission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 l

NRC Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 Department of Environmental Quality

. Radiation Protection Division P.O. Box 82135 Baton Rouge, LA 70884-2135 ATrN: Administrator Mr. E. T. Baker M/S OWFN 13-H-15 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA

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PARISH OF WEST FELICIANA

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Docket No. 50-458 In the Matter of

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GULF STATES UTILITIES COMPANY

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(River Bend Station

- Unit 1)

AFFIDAVIT J.

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Booker, being duly sworn, states that he is a Manager-Safety Assessment and Quality Verification for Gulf States Utilities Company; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.

/ F. Ik-n4

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E. Ifo6ker Subscribed and sworn to before me, a Notary Publig in and for the State and Parish above

named, this J nd day of N t lA_A 1993.

My Commission expires with Life.

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0)auda ), /vlunX Claudia F. Hurst Notary Public in and for West Feliciana Parish, Louisiana

ATTACIIMENT 1 PROPOSED GULF STATES UTILITIES COAIPANY RIVER BEND STATION DOCKET 50-458/ LICENSE NO. NPF-47 CORE OPERATING LIMITS REPORT (93-07)

DOCUMENT INVOLVED:

Technical Specifications ITEM:

Administrative Controls 6.9.3.2 REASON FOR REQUEST:

A proposed change is being requested in accordance with 10CFR50.90 to provide the necessary technical specification changes to allow the exclusion of the minimum critical power ratio (MCPR) result of misoriented bundle analysis identified in the Supplemental Reload Licensing Report for River Bend Station, Reload 4 Cycle 5 (Ref. GE Document 23A7181, Rev.0, August 1992) in the cycle 5 Core Operating Limits Report (COLR). The Cycle 5 core operating limits utilized the analytical methods currently described in Section 6.9.3.2 of the RBS Technical-Specifications (i.e., document NEDE-24011-P-A, " General Electric Standard Application for Reactor Fuel", latest approved version),

a The Supplemental Reload Licensing Report for Cycle.5 shows that the' MCPR for the i

misoriented bundle analysis of 1.22 is.04 higher than the previous technical specification limit j

(i.e.,1.18 for Cycle 1,2,3 and 4) set by Rod Withdrawal Error and Imss of Feed Water Heater Analyses. In the 10CFR50.59 evaluation for Reload 4 Cycle 5, GSU addressed the exclusion of the 1.22 limit from the Cycle 5 COLR. NRC recently stated that such exclusion should have been previously reviewed and approved by NRC. Since there is not a misoriented fuel bundle in the Cycle 5 core because of extensive core verifications including an independent verification by GE, the proposed change allows GSU to maintain an Operating Limit MCPR (OLMCPR) of 1.18 for Cycle 5 operation.

DESCRIlvl' ION:

The cycle-specific core opemting limits (e.g. MCPR) shall be determined such that all applicable limits of the safety analyses are met. Core operating limits are calculated based on the analytical methods which must be previously reviewed and approved by the NRC. This requirement is identified in Section 6.9.3.1,6.9.3.2, and 6.9.3.3 for administrative controls of the COLR. The GESTAR document (NEDE-24011-P-A, " General Electric Standard Application for Reactor Fuel," latest approved version) which is reviewed and approved by the NRC presents generic l

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infonnation relative to the fuel designs and analyses of General Electric BWR plants for which i

GE provides fuel. The generic information contained in the document is supplemented by plant cycle-unique infonnation and analytical results. The Supplemental Reload Licensing Repod includes a listing of the fuel to be loaded in the core and safety analysis results. The infonnation is documented in RBS USAR Chapter 4,5,6 and 15.

For a reload analysis, some anticipated operational occurrences (AOOs) which would be limiting because of MCPR, are reevaluated as follows.

1.

Turbine Trip without Bypass or Generator Load Rejection without Bypass; 2.

Loss of Feedwater Heating; 3.

Feedwater Control Failure; j

4.

Control Rod Withdrawal Error; and 5.

Pressure Regulator Downscale Failure.

The misoriented bundle accident does not strictly qualify as a moderately frequent incident but is evaluated for reload cores to meet the fuel cladding integrity safety limit MCPR.

The operating limit minimum critical power ratio (OLMCPR) for RBS is 1.18 set by Rod Withdrawal Error (RWE) and Loss of Feed Water Heater Analyses (LFWHA) during Cycle j

1,2,3, and 4 operation Plant operational and economical evaluations are based on this MCPR limit. However, du: to a deficiency reponed by GE in a 10CFR Pan 21 on June 19, 1992, Cycle 5 Supplemental Reload Licensing Report shows that misoriented bundle accident analysis becomes more limiting than RWE and LFWHA. The MCPR result for this analysis is 1.22.

River Bend Stelion is currently in compliance with the applicable technical specifications administratively. The OLMCPR in the plant process computer is 1,22. The major basis for this request, allowing use of an OLMCPR of 1.18 instead of a limit of 1.22, is that there is not a i

misoriented fuel bundle in the Cycle 5 core. RBS should not operate with the higher limit of 1.22 which puts additional burden on operations and may limit full power operations.

REVISED TECHNICAL SPECIFICATIONS:

'i GSU proposes that Technical Specification 6.9.3.2 be revised as shown in Attachment 3.

SCHEDULE FOR ATTAINING COMPLIANCE:

Due to possible operational constraints, GSU requests this proposed change be approved as soon as possible. This approval will allow GSU to remove the current administrative OLMCPR of 1.22 and retum to an OLMCPR of 1.18 for the remainder of Cycle 5 operation.

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NOTIFICATION OF STATE PERSONNEL:

A copy of the amendment application and this submittal is being provided to the State of Louisiana, Department of Environmental Quality-Nuclear Energy Division.

ENVIRONh1 ENTAL Ih1 PACT APPRAISAL:

Gulf States Utilities Company (GSU) 'ias reviewed the proposed license amendment against the criteria of 10CFR51.22 for environmc ntal considerations. The proposed changes to the technical specifications do not involve any sig lificant hazards considerations, nor increase the types and amounts of effluents that may be 1: leased offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, GSU concludes that the proposed changes meet the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

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ATTACIIMENT 2 NO SIGNIFICANT IIAZARDS CONSIDERATIONS In accordance with the requirements of 10CFR50.92 the following discussions are provided in support of the detennination that no significant hazards are created or increased by the change proposed in this amendment request.

1.

The proposed change would not involve a significant increase in the probability or consequences of an accident previously evaluated because:

An RBS specific calculation has been perfonned (Reference 1) to estimate the probability of operation with a mis-oriented fuel bundle given the current core verification procedures. This calculation estimated the probability to be 7.36E-07 per cycle. In addition, independent verification has been performed by General Electric to show all fuel bundles are properly oriented in the Cycle 5 core (Rrwnce 2). This additional

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verification reduces the probability lower than 7.36E-07 pu ycle. Therefore, the i

probability of operation with a mis-oriented fuel bundle is insignhicant. The probability i

is well below that for moderate frequency and infrequent events and is even below the probability for limiting faults such as a large LOCA. Therefore, there is no increase in the probability of any previously analyzed accidents. The video tape of Cycle 5 core was j

also made available for review by the RBS NRC Resident Inspector.

The estimated maximum consequences of operation with a mis-oriented fuel bundle are failure of I to 4 fuel pins (Reference 3). It is expected that the coolable geometry will not be impacted and the pin failures will not propagate. The 1 to 4 pin failures are well below the limit for abnonnal operational occurrences of 0.1% (38 pins). Coolable geometry will be maintained and the off-site consequences from failure of 1 to 4 fuel pins are insignificant in comparison to the limits of 10CFR100. Therefore, the consequences of any previously analyzed accident are not increased.

2.

The proposed change would not create the possibility of a new or different kind of accident from any accident previously evaluated because:

All anticipated operational occurrences including a mis-oriented fuel bundle accident performed for reload cores are identified in GESTAR (Reference 4). The events are analyzed and reponed in the Cycle 5 Supplemental Reload Licensing Report (Reference 5); therefore, no possibility of a previously unanalyzed accident is created.

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i 3.

The proposed change would not involve a reduction in the margin of safety because:

It has been shown that with the extensive RBS core verification as mentioned above, the probability of operation with a mis-oriented fuel bundle during any cycle is extremely small Because of the increased awareness and extra care taken during RF4, there is no mis-oriented bundle for operation during cycle 5. Essentially, the extra attention paid to fuel orientation during RF4 has decreased the probability of operating with a mis-oriented fuel bundle during cycle 5 to 7.36E-07, which is so small that it can be considered zero. Since there is no mis-oriented fuel bundle, there is no effect on margin of safety created by this request.

REFERENCES 1.

Salyer, William, " Impact of Secoad Core Pass on Failure Probability of Core Verification," GSU Calculation File G13.18.12.0*32, Revision 0, June,1992.

2.

Letter to K.E. Suhrke (GSU) from C.J. Paone (GE), " Request for Independent Fuel Orientation Verification," RBC-43948, June 7,1993.

3.

Letter to USNRC Document Control Desk from J.F. Klapproth (GE), " Rotated Bundle Event Licensing Basis Change," September 30,1992.

4.

NEDE-24011-P-A-10-US, " General Electric Standard Application for Reactor Fuel,"

March,1991.

5.

GE Document 23A7181, Revision 0, " Supplemental Reload Licensing Report for River Bend Station Reload 4 Cycle 5," August,1992.

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