ML20210H492

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Ack Receipt of in Response to Notice of Nonconformance from Insp Rept 99900003/97-01 Re Steps Taken to Design Organizations to Consider Fuel Cladding Plastic Strain Limits
ML20210H492
Person / Time
Issue date: 08/07/1997
From: Richards S
NRC (Affiliation Not Assigned)
To: Kipp C
GENERAL ELECTRIC CO.
References
REF-QA-99900003 99900003-97-01, 99900003-97-1, NUDOCS 9708140046
Download: ML20210H492 (2)


Text

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Mr. Craig P.-Kipp August 7, 1997 Plant Manager General Electric Nuclear Energy P.O. Box 780, Mail Code A20 Wil;ington, NC 28402-0780

SUBJECT:

GENERAL ELECTRIC NUCLEAR ENERGY JUNE 18, 1997, REPLY TO NRC NOTICE OF NONCONFORMANCE (NRC INSPECTION REPORT NO. 99900003/97-01)

Dear Mr. Kipp:

We have reviewed General Electric's (GE's) June 18, 1997, letter in response to our May 20, 1997, h,tice of Nonconformance.

In the response to nonconformance 99900003/97-01-01, GE addressed steps taken to inform licensee design organizations of the need to consider the fuel cladding plastic strain limits and the associated mechanical over)ower (MOP) limits in addition to the minimum critical power ratio limits when considering rod ) lock inonitor (RBM) operability for potential rod withdrawal error (RWE) events. Specifically, GE has (1) informed its customers by letter about the M0P/RBM issue, (2) performed plant and cycle-specific analysis to assure that strain limits were not exceeded in applicable plants (e.g., Fermi, Hatch, Brunswick, and Duane Arnold) by the MCP/RBM issue, and (3) revised procedures (e.g., RWE technical design procedure for supplemer,tal reload licensing reports) to improve communication with licensees. We consider the response to this nonconformance adequate.

Regarding nonconform'ance 99900003/97-01-02, concerning GE modifying and revising design factors without prescribed instructions and procedures, the letter stated that GE hn revised technical design procedures to include, in part, additional guidance on design changes and documentation. We consider the response to this nonconformance adequate.

Regarding nonconformance 99900003/97-01-03, in the letter of June 18, 1997, to the NRC, GE did not confirm whether GE would conduct followup internal audits to review specific design control deficiencies identified by Detroit Edison Company in its 1992 and 1993 audits of GE.

Subsequently, in a letter of July 31, 1997, and later telephone discussion with the NRC, GE confirmed that it plans to audit its design control process by January 1998. We consider the response to this nonconformance adequate.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter will be placed in the NRC's Public Document Room (PDR).

Sincerely, 1

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Stuart A. Richards, Chief Special Inspection Branch Division of Inspection and Support Programs Mh(L-O FM Docket No. 99900003 Distribution:

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Central Files / Docket File No. 99900003 DOCUMENT NAME: G:\\GAUTAM\\GE.RES

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