ML20056F595
| ML20056F595 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 08/23/1993 |
| From: | Graham P GULF STATES UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RBG-38909, NUDOCS 9308300130 | |
| Download: ML20056F595 (4) | |
Text
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August 23,1993 RBG-38909 File Nos. G9.5, G15.4.1 RBEXEC-93-551 4
3 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 j
Gentlemen:
i River Bend Station - Unit 1 Docket No. 50-458/93-17 Pursuant 10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response to the Notice of Violation for NRC Inspection Report Item No. 50-458/93-17. The inspection was conducted by Messrs. W.M. McNeill and E.T. Baker from June 14, through June 18, 1993, of activities authorized by NRC Operating License NPF-47 for f
River Bend Station - Unit I (RBS). GSU's reply to the violation is provided in the
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attachment.
Should you have any questions, please contact Mr. D.N. Lorfing at (504) 381-4157.
Sincerely,
[
2)Nb P.D. ~'raham Attachment i
930830013o 930823 N
PDR ADDCK 05000458 8
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Page 2 of 2 Ixtter to NRC August 23, 1993 RBG-38909 RBEXEC-93-551 cc:
U.S. Nuclear Regulatory Commission Region IV - Regional Administrator 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 NRC Resident Inspector P.O. Box 1051 St. Francisville, LA 70775 i
l i
s ATTACILTIENT I i
REPLY TO NOTICE OF VIOLATION 50-458/9317-01 LEVEL IV REFERENCE Notice of Violation - Ixtter from S.J. Collins to P.D. Graham dated July 23,1993.
VIOLATION l
Technical Specification 6.9.3.1 requires that core operating limits shall be established prior to stanup from each reload cycle for the minimum critical power ratio and such shall be documented in the core opemting limits report.
Technical Specification 6.9.3.2 states that the analytical methods used to detennine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those in NEDE-24011-P-A, " General Electric Standard Application for Reactor Fuel," (latest approved version).
Contrary to the above, the minimum critical power ratio (MCPR) value of 1.18 documented in the core opemting limits report for Reload 4, Cycle 5, dated August 28,1992, was detennined using analytical methods other than those documented in the latest version of NEDE-24011-P-A as reviewed and approved by the NEC.
REASON FOR TIIE VIOLAT_Ifn General Electric (GE) notified GSU and NRC on June 20, 1992 of a potential reponable condition (PRC), pursuant to 10 CFR Pan 21, regarding a deficiency in GE's generic analysis for the mis-oriented fuel bundle (MOFB) for C-and S-lattice stmetured cores loaded with advanced fuel types (GE8 and above). Condition Report (CR) 92-0524 was written to review l
the PRC and was dispositioned considering the fact that GE had reponed the condition to NRC.
GSU had received the final delivery of GE8 Reload 4 fuel bundles on June 11,1992.
Preliminary cycle specific MOFB analysis for River Bend Station indicated that about 0.04 MCPR margin could be lost in Cycle 5 as the fuel and core design did not take this limitation into account. GSU management was concerned about the safety, openttional and economic impact resulting from the loss in margin. GSU and GE met with NRC on June 26,1992 to discuss our treatment of the MOFB event. Infonnation was presented supponing treatment of the MOFB event as an accident mther than a inmsient, along with information on the expected impact of a loss of MCPR margin on River Bend Cycle 5 operation. GSU did not consider MOFB a safety issue since GE had detennined that only I to 4 fuel pins, much less than the Safety Limit Minimum Critical Power Ratio (SLMCPR) basis, would be in boiling tnmsition in a MOFB. Subsequent discussions were also held with the NRC Project Manager for River Bend Station. GSU believed that the evaluation of GE's PRC (CR 92-0524) and the Reload 50.59 wem both appropriate licensing vehicles to address MOFB-related MCPR operating penalties.
GSU did net initially consider this a Technical Specification issue because the " latest approved version" of NEDE-24011-P-A, "Geneml Electric Standard Application for Reactor Fuel,"
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'(GESTAR-H) had not been revised to require a cycle-specific analysis for S-lattice cores. The PRC was evaluated for applicability to River Bend Station, as would nonnally be done for Part
'21 issues, and detennined not to be applicable to River Bend Cycle 5 based on reasonable assurance that a A10FB was not present in the as-loaded core. GSU detennined that the 10CFR50.59 for Reload 4 would be an acceptable licensing vehicle to address A10FB based on the above.
GSU concurred with GE's request to include h!OFB hiCPR results in River Bend Reload 4 Supplemental Reload Licensing Submittal, pmvided a footnote be added to reference the June 26,1992 meeting with NRC. This footnote was to provide traceability to the fact that cycle specific h10FB analysis, giving a 1.22 Operating Limit hiinimum Critical Power Ratio (OLh!CPR), was the result of a Pan 21 issue rather than a GESTAR-H requirement.
The Core Operating Limits Repon (COLR) for Cycle 5 was written to repon an ODICPR of 1.18, with LFWH (loss Of Feedwater Heating)and RWE (Rod Withdrawal Error) being the limiting transients. h10FB was addressed in the Reload 410CFR50.59 as not being applicable to River Bend Station for Reload 4.
The bases for this were extensive core verification adequately ensuring that no mis-oriented bundle existed following core loading and the consequences of a hiOFB event being less severe than the design basis for SBICPR.
CORRECTIVE STEPS TAKEN AND RESLILTS ACHIEVED CR 93-0319 was written on hiay 26,1993 upon notification by NRC that a potential violation of RBS Technical Specifications existed because the OBiCPR reported in the COLR was not 1.22 as reponed by GE in the Supplemental Reload Licensing Submittal. An OLh1CPR limit of 1.22, including appropriate changes to the process computer software, was administratively imposed on hiay 28, 1993 while funher discussions were being held with NRC personnel.
Additional independent review of the Reload 4 core verfication tapes was perfonned by GE.
As expected, no mis-oriented bundles were found. The tapes were also furnished to the NRC resident inspector. In addition, the circumstances resulting in this violation have been discussed with those RBS personnel responsible for generating the COLR and Reload 10CFR50.59 evaluations.
License Amendment Request 93-07 was generated and submitted to NRC. When approved by NRC, Technical Specification 6.9.3.2 will be revised to allow an OLh1CPR of 1.18 to be used for the remainder of Cycle 5.
GE submitted additional information to NRC on September 30,1992 to support a generic change in the licensing basis for the hiOFB event.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS GSU will establish OLh1CPR in future Core Operating Limits Repons based on the most limiting applicable event unless otherwise approved in writing by NRC.
DATE WHEN FULL CON 1PLIANCE WILL HE ACHIEVED GSU is currently in compliance with an OLh1CPR limit of 1.22.
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