ML20155E134
| ML20155E134 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 10/29/1998 |
| From: | Miraglia F NRC (Affiliation Not Assigned) |
| To: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| Shared Package | |
| ML20155E139 | List: |
| References | |
| 2.206, NUDOCS 9811040212 | |
| Download: ML20155E134 (6) | |
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' UNITED STATES g
g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. seest,.J001 4,*****
October 29, 1998 J
s Mr. David A. Lochbaum j
Union of Concemed Scientists 1616 P Street NW, Suite 310 i
' Washington, DC 20036-1495 l
I
Dear M'r. Lochbaum:
I have received your Petition that you submitted on behalf of the Union of Concemed Scientists (UCS), dated September 25,1998, addressed to L. Joseph Callan, Executive Director for Operations, U.S. Nuclear Regulatory Commission (NRC). The Petition requests enforcement action to require an immediate shutdown of the River Bend Station (RBS) and that the facility remain shut down until all. failed fuel assemblies are removed from the reactor core. The RBS j
licensee, Entergy Operations, Inc., had recently filed NRC Daily Event Report No. 34815, in which it reported "a possible defect in fuel cladding." As an alternate action, you also stated that RBS could be restarted following the proposed shutdown after its design and licensing bases were updated to permit operation with failed fuel assemblies. Additionally, the Petition requested a public hearing to present new plant-specific information regarding the operation of RBS, as well as to discuss a UCS report dated April 2,1998, entitled " Potential Nuclear Safety Hazard / Reactor Operation With Failed Fuel Cladding."
)
As the basis for your request, examples were cited in the Petition (summarized below) where, in your opinion, the RBS Updated Safety Analysis Report (USAR) does not allow for operation with pre-existing fuel failures:
(1)
Integrity of the fuel barrier is an explicit criterion in addition to radiation l[
requirements, and RBS is violating "the spirit, if not the letter, of [USAR Section 15A, Table 15A.2-4] Criterion 4 2 since the fuel barrier has already failed, albeit to a limited extent."
(2)
The USAR description for six design-bases events includes either the statement 9{0\\
that the fuel barrier maintains its " integrity and functions as designed," or that "no radioactive material is released from the fuel," as a consequence of the event.
lt is your view that the analyses associated with these events " appear (s) valid 3
only when the River Bend Station is operated with no failed fuel assemblies."
i Your Petition further reasserted the UCS position that nuclear power plants operating with fuel cladding failures were potentially unsafe and were in violation of Fenderal regulations. In its April 1998 report, the UCS stated that it has not been demonstrated that the effects from design-bases transients and accidents (i.e., hydrodynamic loads, fuel enthalpy changes, etc.)
j prevent pre-existing fuel failures from propagating. Therefore, you concluded that it was possible that "significantly more radioactive material will be released to the reactor coolant system during a transient or accident than that experienced during steady state operation." In 9811040212 981029 PDR ADOCK 05000458 0
s l
David A. Lochbaum l l
l addition, you also stated that, by operating with possible failed fuel cladding, RBS is violating its I
licensing basis for the radiation worker protection (as low as reasonably achievable (ALARA])
program as it is described in USAR Sections 12.1.1, " Policy Considerations," and 12.1.2.1,
" General Design Considerations for ALARA Exposures."
When the staff received your Petition, it conducted a preliminary evaluation to determine if an urgent safety issue was involved that warranted the requested action. Although you raised important concerns in your Petition, the staff has concluded that the Petition uncovered no urgent safety problems that warranted immediate action by the NRC. Technical Specifications (TS) limits on reactor coolant system (RCS) activity typically account for a small fraction of l
failed fuel, which can be expected during normal operations. These limits are set to values of RCS specific activity, which assure that the radiological consequences of postulated design-basis accidents are within the appropriate dose acceptance criteria. At RBS, operation with a minimal amount of fuel cladding damage is allowed, provided the licensee continues to meet RCS chemistry requirements of TS Section 3.4.8. Furthermore, the Petition did not include any information indicating that RBS has operated outside its TS limits. Consequently, your request for enforcement action to require the immediate shutdown of RBS is denied.
The licensee has taken actions to address the suspected condition of the fuel assembly, including the insertion of control rods to " isolate" the fuel assembly in order to minimize reactor coolant activity levels. The NRC has been closely monitoring events at RBS and will continue to ensure that there is no undue risk to public health and safety.
In your Petition, you also requested that the NRC conduct an informal public hearing in order to "present new information on reactor operation with failed fuel assemblies" as a follow up to the April 1998 UCS report, as well as to provide plant-specific information regarding the operation of RBS. In order to ensure that potentialissues relating to this material are appropriately
' addressed, the NRC is hereby offering you an opportunity to present the new information referred to in your Petition at an informal public hearing. The public hearing will also allow the licensee and public to present other pertinent information, as well as provide a means to solicit questions from all participants. The information gained from the hearing will subsequently be used by the NRC in evaluating the issues raised in your Petition and the eventual rendering of a Director's Decision pursuant to 10 CFR 2.206.
In order to assist in facilitating discussion on the relevant issues during the proposed informal public hearing, the NRC is requesting that you provide, in advance of the hearing, the new information on reactor operation with failed fuel assemblies you intend to present. This will allow meeting participants to review the material and better prepare for the hearing.
If you wish to accept this offer, please contact Mr. Robert J. Fretz, the NRC Petition Manager, at (301) 415-1324 in order to establish a mutually agreeable date, time and location for the informal public hearing. Mr. Fretz will also serve as our point of contact for the information we have requested in advance of the hearing.
l t
David A. Lochbaum !
Your Petition has been referred to me pursuant to 10 CFR 2.206 of the Commission's regulations. As provided by Section 2.206, action will be taken on your request within a l
reasonable time. I have enclosed for your information a copy of the notice that is being filed l
with the Office of the deral Register for publication. I have also enclosed for your information a pamphlet on the pt.uac petition process.
Sincerely, k)*
l Frank J. Mirahia, et ctor Office of Nuclear Reactor Regulation
Enclosures:
- 1. Federa/RegisterNotice
- 2. Pamphlet on the Petition Process cc w/ encl: See next page i
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David A. Lochbaum Your Petition has been referred to me pursuant to 10 CFR 2.206 of the Commission's regulations. As provided by Section 2.206, action will be taken on your request within a reasonable time. I have enclosed for your information a copy of the notice that is being filed with the Office of the Federal Register for publication. I have also enclosed for your information a pamphlet on the public petition process.
i Sincerely, ORIGINAL SIGNED BY:
Frank J. Miraglia, Acting Director Office of Nuclear Reactor Regulation
Enclosures:
- 1. Federa/RegisterNotice
- 2. Pamphlet on the Petition Process cc w/ encl: See next page DISTRIBUTION: See next page "See Previous Concurrence Document Name:
RB980592.GRN
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Q@RF/O NAME EAdensam BBoger chok b f/ W/98 DATE 10/22/98 10/27/98 I
COPY YES/NO YES/NO YES/NO OFFICIAL RECORD COPY l
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EDO #G980592 Acknowledgment Letter daied: October 29.1998 DISTRIBUTION: wo/att 2 Docket File'(50-458)'
. PUBLIC (w/ incoming letter)
EDO#G980592 EDO Reading PD4-1 R/F (w/ incoming)
S. Collins /F, Miraglia.
' B. Boger E. Adensam (EGA1)
J.Hannon
'C.Hawes R. Fretz M.- Boyle (MLB4)
R. Sabbaratham (RXS2)
OPA OCA-I NRR Mail Room (EDO#G980592 w/ incoming) (05/E/7)
T. Harris (TLH3)
- J. Goldberg T. Gwynn, RIV
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i Entergy Operations, Inc.
River Bend Station ec:
i Winston & Strawn Executive Vice President and 1400 L Street, N.W.
Chief Operating Officer l
Washington, DC 20005-3502 Entergy Operations, Inc.
l P. O. Box 31995 Manager-Licensing
- Jackson, MS 39286 Entergy Operations, Inc.
River Bend Station General Manager - Plant Operations P. O. Box 220 Entergy Operations, Inc.
St. Francisville, LA 70775 River Bend Station P. O. Box 220 Senior Resident inspector St. Francisville, LA 70775 P. O. Box 1050
. St. Francisville, LA 70775 Director-Nuclear Safety Entergy Operations, Inc.
President of West Feliciana River Bend Station Police Jury P. O. Box 220 P. O. Box 1921 -
St. Francisville, LA 70775 St. Francisville, LA 70775 Vice President - Operations Support Regional Administrator, Region IV Entergy Operations, Inc.
U.S. Nuclear Regulatory Commission P. O. Box 31995 611 Ryan Plaza Drive, Suite 1000 Jackson, MS 39286-1995 Arlington,TX 76011 Attomey General Ms. H. Anne Plettinger State of Louisiana 3456 Villa Rose Drive P. O. Box 94095 q
Baton Rouge, LA 70806 Baton Rouge, LA 70804-9095 l
Administrator Wise, Carter, Child & Caraway Loulslana Radiation Protection Division P. O. Box 651 P. O. Box 82135 Jackson, MS 39205 Baton Rouge, LA 70884-2135 Mr. Randall K. Edington i
- Vice President - Operations Entergy Operations, Inc.
River Bend Station P.O. Box 220 St. Francisville, LA 70775 1
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