ML20055F584
| ML20055F584 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/29/1990 |
| From: | Fieno D Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20055F580 | List: |
| References | |
| GL-88-16, LBP-90-15, OLA, NUDOCS 9007180071 | |
| Download: ML20055F584 (8) | |
Text
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l UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION-I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' In the Matter of THE CLEVELAND ELECTRIC' Docket'No. 50-440-OLA' j
(PerryNuclearPowerPlant, i
Units 1 and 2) i i
]
AFFIDAVIT OF DANIEL FIEN0 t
H My name is Daniel Fieno.
-I am employed' in the Division of Systems L
Technology's Reactor Systems Branch, NRR, of the U.S.. Nuclear - Regulatory Commission.
My professional qualifications are attached.
I helped prepare Generic Letter 88-16.
I hereby depose-and state:
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The Licensing Board questioned, in LBPi90-15, dated June. 11, 1990, whether the methodology by. which cycle-specific parameter limits are determined allow for " excessive. discretion or judgement.on' the part of CEI." The Board stated it was unable to determine from the license amend-ment application or from Generic Letter 88-16 whether such discretion would be permitted so as to constitute unlawful abdication of Commission 1
responsibility to pass on the question of whether the licensee's activi-ties meet the standards of the Atomic Energy Act.
The Board also ques-l tioned whether the cycle-specific parameter limits are conditions. or limitations upon reactor operations deemed necessary to obviate the pos-sibility of an abnormal situation or event giving rise to an.immediate threat to' the public health and safety required by 10 CFR 9 50.36 to be I
in the technical specifications.
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When a reactor core is reloaded for its _ next operating cycle, a number of-changes-are made to the core:
(1) some of the irradiated fuel is: dis-charged from the core; (2) some new, 'unirradiated fuel is loaded in' the core; and (3) the remaining irradiated fuel is relocated to other loca-tions to achieve the desired fuel loading pattern.
The fuel loading pattern is chosen to,: among other things, achieve a certain energy output for. the cycle and' to maintain the design-limitations on normal operation and the-transient and accident analyses. - This process of designing. the '
3 reload core is performed using methodologies (computer codes) and proce-dures that have been reviewed and approved by'the NRC through its licens-ing topical report review procoss.
The' end result of this reload.. design.
a effort is a safety analysis report by the licensee.
This-safety analysis report addresses the fuel design, the nuclear design, the. thermal-hydrau-lic design, and the transient and accident analyses of : the core.
In addition, the safety analysis report addresses changes to the numerical values of cycle specific parameters presently required in' the technical specifications.
Some of the changes to the technical specifications are-made because of the different. characteristics of the reload core-from the previous core.
These varying reload core. characteristics result in changes to the numerical values of cycle-specific parameters.
An example F
of a cycle-specific parameter for a boiling-water reactor. is the minimum critical power ratio (MCPR) that protects the fuel cladding from overheat-ing.
In the design process for a reload core, a number of criteria speci-fied by the regulations must be met.
In the example given, the design of the core must' be such that the MCPR limit meets General Design Criterion 10 of_the regulations.
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Generic Letter 88-16 provides for revision of the technical specifications
~ so that '.the numerical values of cycle-specific parameters, which assure i
that the operating limits are met,'may be located to a licensee document (usually called a Core Operating Limits. Report [COLR]).
This -does not change the operating limit's of the core.
The same safety analysis using NRC approved methodologies must be performed by a licensee for each reload core, and each reload core must meet al.1 applicable' NRC criteria.
The-only difference is that, with relocation of certain. cycle-specific numeri-(
cal information about each reload 'to the COLR, the technical specifica-4 tions do not. require change to -reflect the different characteristics 'of I
each~ reload core.
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GenericLetter88-16doesnot-allowfora'nydiscretionorjudgmentonthe part of licensees in the operation of a reload core that is any different th6n-was previously allowed.
. The only change being made is to allow licensees to relocate the numerical values of cycle-specific parameters of L
a reload core (detennined by using NRC approved computer codes), in the i
COLR, rather than in the plant's technical specifications.
'The reload i
core design must. meet all applicable criteria established by NRC regula-tions.
A reload. core will differ from previous reload cores operated at -
the plant, but these differences can occur within the design and regula-L i
L tory criteria that each reload core must meet.
By deleting the numerical
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i-values of the-MAPLHGR, MCPR, and LHGR limits from the technical specifi-L cations,-licensees of boiling water reactors will be able.to simply record-the numerical values of the cycle-specific. parameters of a reload core (MAPLHGR, MCPR, and LHGR limits for BWRs) in the COLR, rather than to seek
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a technical specification change for these. values for each core reload.
I These cycle-specific numerical values, which vary 'for each core reload, p
are the only information ' being removed from. technical specifications.
'The operating limits remain in the technical--specifications.
No. change-l to core operating limits is proposed by Generic Letter 88-16 and no cal-culations that have not been reviewed and approved by the NRC are being i
. proposed by the' Generic Letter.
No safety. issue is-raised by a simple-relocation of-the numerical values Lof cycle-specific core parameters for each reload core.
Therefore, Generic letter 88-16 does not affect the a
limitations upon reactor core operation deemed necessary to obviate the t
possibility of an abnormal situation.or event giving rise to' an immediate threat to the_public health and safety.
Thus, Generic Letter 88-16 is in full conformance with - the requirements of 10 CFR i 50.36 regarding the technical specifications.
S.'
I attes', the foregoing is true and correct to' the best of-my knowledge and belief.
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l Daniel Fieno Subscribed and Sworn to before me thisJdthday.of U%,p 1990 =
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- Notary public j
g My commission expires:
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CAROL L AUGUSTINO l;
NOTARY FU300 STATE OF MARYLAND My Commissico Evire:Jonvory 17,1994 i
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R PROFESSIONAL QUALIFICATIONS L
Daniel B. Fieno Reactor Systems Branch -
i Division of Systeras Technology U.S. Nuclear Regulatory Commission I' am employed as a Senior -Reactor Engineer (Nuclear) of the Reactor Systems-Branch of the Division of Systems Technology of NRR.
I have held this and similar positions from December 16, 1983 to the present time.
I was employed; as a Section - Leader of - the. Reactor - Physics Section of the Core Performance
. Branch ' of NRR from August '1',
1976 ' to December 15, 1983.
From June 1973:
through July 1976, I. was a Reactor Physicist in the Core Performance Branch and the Reactor Safety Branch of NRR.
I gradua'ted from the University of Cincinnati with a BS Cum Laude Degree in-Physics in:1951.
I received a Graduate Certificate in reacto-technology from the Oak Ridge School of: Reactor Technology (ORSORT) in August 1957.
I have been continuously employed in the nuclear energy profession since June 1951.
In my present position at the NRC.. I serve as a senior reviewer.in the areas of ~ nuclear power plant technology.which includes reactor systems, reactor core design, and operating performance.
I:have extensive experience in the evalua-tions of reactor core designs presented in Preliminary Safety Analysis Reports 1
(PSARs) and Final Safety Analysis Reports -(FSARs), license' amendments including reload core submittals, the methochlogies used in the evaluation.of the static and dynamic reactor physics responses of proposed and operating reactor cores, operating reactor generic problems and issues, new and. spent fuel storage facilities, technical specificatio1s, conducting :and-supervising reactor physics-studies by a contractor (Braokhaven National Laboratory).
In sunenary, I have participated in nearly all aspects related to the reactor ' physics of light water reactor power plantr.
While I. was Section Leader of the Reactor PhysicsSection I had supervisory responsibility for over 7 years for the review of the, reactor core physics design submitted in-all reactor construction pennit and operating -license applications.
The Reactor Physics Section participated in the review of L the analytical models used in perfonning reactor core physics licensingievalua-tions'.
The Reactor Physics Section managed an extensive physics program' at the Brookhaven National Laboratory. in support _ of Section's work.
The Reactor
'r Physics Section was also responsible for the-review of-the physics related aspects of new and spent' fuel storage facilities.
Prior to joining the NRC staff in June 1973, I was employed by NASA (and its predecessor agency NACA) in its nuclear-energy programs -at the Lewis Research Center from June 1951 to June 1973.
While.at NASA, I-was technical supervisor of the Reactor-Mathematics and Computation Section for some 4 years and tech-nical supervisor of the Reactor Analysis Section for some eight years.
Both
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of' these research sections were in the NASA / Lewis Research Center's Nuclear Peactor Division.
During my 22 years of employment in NASA's nuclear energy programs I participated in many reactor physics areas of'research, design, and experimentation.
These areas included reactor physics methods development, cross section evaluations, critical experiment analysis, design of the Plum Brook Research Reactor and. several critical facilities, and design of nuclear reactors. for space power applications.
During tnis period I also taught graduate level reactor physics courses.
This included an extensive course for the research and operating staff of the Plum Brook Research Reactor in 1958.
During my employment at NASA, numerous reports and memoranda were written by myself and the technical staffs of the sections that I supervised.
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C0(,hE TED VNITED ATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION d
BEFORE THE' ATOMIC SAFETY AND LICENSING ~ BOARD
% JL -5 PS :08.
QFFICE OF SECRETARY THE CLEVELAND = ELECTRIC
)
Docket No.- 50-440-0MKillNG & SLAVICE ILLUMINATING COMPANY, ET AL.
)
BRANCH
)-
(Perry Nuclear Power Plant,-
)
' Units 1 and 2)
)
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CERTIFICATE OF SERVICE
'.k I hereby certify that copies.of "NRC STAFF MOTION FOR RECONSIDERATION"
!1 in.the above-_ captioned-proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's l
internal mail system,fthis 3rd day of-July, 1990:
i John H. Fryej-III, Chairman Jerry R. Kline Administrative Judge Administrative Judge l
Atomic Safety and Licensing Atomic.Uafety_and Licensing-Board Panel Board Panel-
=
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission d
Washington, D.C.
20555 Washington, D.C.
20555 Frederick J.
Shon Atomic Safety and Licensing Board Administrative Judge
. Panel (1)*-
Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Board Panel-Washington, D.C.
20555 U.S. Nuclear Regulatory-Commission Washington, D.C. 20555 office of the Secretary (2)'*
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing
' Washington, D.C. 20555 Appeal Board (5)*
Attn: Docketing-and. Service U.S. Nuclear Regulatory Commission Section-Washington, D.C. 20555 Adjudicatory File
- Bruce A. Berson Atomic Safety and Licensing i
Regional Counsel.
Board USNRC, Region III U.S. Nuclear Regulatory Commission -
799 Roosevelt Road Washington, D.C.
20555 Glen Ellyn, IL 60137 Jay Silberg Shaw, Pittman, Potts & Trowbridge 2300 N.-Street, N.W.
Washington, D.C.
20037
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. Susan Hiatt Ohio Citizens for Responsible f
Energy.-
8275 Munson Road-Mentor,-Ohio.44060' J/i Colleen N. Woodhead Counsel-for NRC Staff-i
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