ML20203G301

Forwards Rept Which Summarizes Actions Taken to Complete Closeout of Core Performance Action Plan & Provides Recommendations for Further Efforts.Next Director'S Quarterly Status Rept Will Reflect Closure of Plan

ML20203G301
Person / Time
Issue date:	02/16/1999
From:	Wermiel J NRC (Affiliation Not Assigned)
To:	Holahan G NRC (Affiliation Not Assigned)
References
TAC-M91256, TAC-M91620, NUDOCS 9902190260
Download: ML20203G301 (9)

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.  ?' February 16, 1999 MEMORANDUM TO: Gary M. Holahan, Director Division of Systems Safety and Analysis )

Office of Nuclear Reactor Regulation FROM: Jared S. Wermie!, Chief /s/

Reactor Systems Branch Division of Systems Safety and Analysis

SUBJECT:

CLOSEOUT OF CORE PERFORMANCE ACTION PLAN l (TAC NOS. M91256, M91602) l

Reference:

Memorandum from Gary M. Holahan and R. Lee Spessard to Ashok C.

Thadani, " Action Pla' to Monitor, Review, and Improve Fuel and Core Components Operat..:g Performance," dated October 7,1994 The Core Performance Action Plan was formally initiatM in October 1994 to assess fuel and control rod performance and reload core design paality assurance activities that may impact plant safety. This was accomplished through pe.4ormance-based inspections of fuel vendors, evaluations of licensee participation in reload analyses, and independent evaluation of industry core performance information gathered during these inspections. The vendor and licensee inspections were coordinated with the regions and training was provided to regional personnel.

To date all but one of the milestones has been comp!sted. The remaining milestone (Task 6) is  !

to evaluate licensee / vendor lead test programs for identification of core performance problems.

This action has been included in the Agency Program Plan for High Burn-up Fuel that was forwarded to the Commission in a memorandum dated July 6,1998, from L. J. Callan, Executive Director for Operations.

Since the Core Performance Action Plan has met its purpose, including issuance of vendor and licensee inspection reports and the presentation and discussion of issues at the Cora Performance Workshop (TAC No. M95674), the Action Plan is being closed by virtue of this memorandum. The attached report summarizes the actions taken to complete the action plan and provides recommendations for further efforts in this area.

The next Director's Quarterly Status Report will be updated to reflect closure of the Core Performance Action Plan.

Attachments: as indicated CONTACT: E. D. Kendrick, SRXB/DSSA, 415-2891 DISTRIBUTION: File Center GHolahan JWermiel JLyons EKendrick PDR SRXB R/F t

DOCUMENT NAME: G:\ACTNCORE.WPD M" Ob  ; i OFFICE: SRXB:DSSA SR SSA

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SR :DSSA ~O:Dm NAME: EKENDRIC JLY S JWE MIEL d HAN ^ + fb D DATE: 2/(l/9 2/ ll /99 2/ /6 /99 2/ NQQ g Ab T 7

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CORE PERFORMANCE ACTION PLAN CLOSEOUT l 1

1. Background

increasing economic pressures on licensees has led to increased competition among vendors providing fuel and reload analyses, resulting in reload cores with mixed core components and fuel services from multiple vendors. In addition, the NRC has reduced its direct review and oversight of core reload activities by approving generic design criteria for individual reactor fuel

.vendors andmov ng i operating m li ts i rom f t eh tec nhi ca lspec cat ifi ons i to t eh core operating limit report (COLR). Although the staff reserved the right to audit or inspect these activities, there was no increase in NRC audits or inspections.

The applicable regulatory requirements are primarily 10 CFR Part 50, Appendix A, " General Design Criteria for Nuclear Power Plants," and Appendix B," Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." Table 1, " Regulatory Basis for Fuel / Core Design Criteria," gives a summary listing of licensee requirements and guidelines that are used

. by licensees and provide the inspection basis.

At the present time, the following domestic vendors supply nuclear fuel and control rods, core reload analyses, and other fuel-related services and materials to NRC licensees:

ABB Combustion Engineering (ABB/CE):

o Hematite, Missouri- uranium hexafluoride (UF.) conversion facility, PWR fuel manufacturing e Windsor, Connecticut- PWR and SWR neutronics engineering e Vasteras, Sweden - BWR fuel engineering, testing and manufacturing  ;

Framatome Cogoma Fuels (formerly B&W):

• Lynchburg, Virginia - neutronics engineering, PWR fuel manufacturing General Electric Nuclear Energy (GE): ,

I t e San Jose, Califomia - neutronics and transient design I

e Wilmington, North Carolina - neutronics engineering, UF. conversion facility, tubing  ;

L and BWR fuel manufacturing l \

j Siemens Power Corporation - Nuclear Division (SPC-ND): ,

i i l e Richland, Washington - UF conversion facility, neutronics engineering, BWR and PWR fuel manufacturing l e Lingen, Germany - component manufacturing l

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t Westinghouse Electric Corporation (W):

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e Monroeville, Pennsylvania - neutronics engineering e Blairsville, Pennsylvania - tube manufacturing i e Columbia, South Carolina - UF conversion facility, PWR fuel mechanical design and manufacturing

2. Core Performance issues

} Core design is fundamental to maintaining fuel integrity, which is the first principal safety barrier l

(i.e., fuel cladding, reactor coolant system boundary, and the containment) against serious radioactive releases.1.ikewise, safety analyses must be properly performed in order to verify, in conjunction with startup tests and normal plant parameter monitoring, that the reload core design is adequate. Licensees and fuel vendors must have quality assurance programs to l . ensure that the fuel is manufactured properly, the safety analysis is accurate, and that proper

! interfaces between organizations are established.

A primary concem was the issue of increased complexity of reload core designs resulting in j mixed core fuel designs, due to licensee / vendor optimization activities to enhance operating i performance and take advantage of available operating margins, while reducing fuel and j operating costs. A strong economic incentive existed fnr both vendors and licensees to develop methods and reload designs that redues thermal margin and gain operating flexibility. The l' staff's primary concem was that these activities should be conducted with a sound technical j approach that maintains an acceptable level of safety.

t l However, increased fuel failures were being observed in 1993 and several other fuel and j control rod design and fabrication problems at vendor facilities had not been caught by existing j quality assurance procedures. Other observed core performance problems included

! e control rod material failures,

! e degraded scram timing,

! e extended operating fuel cycle effects, e moderator temperature coefficient (MTC) issues, and e high bum-up fuelissues.

3. Preliminary Causal Factors l ]

The initial evaluation of the root causes of the observed core parformance problems had identified inadequate analysis and testing of new fuel and core designs, as well as vendor manufacturing problems. Less-than-adequate licensee oversight of vendor activities and weaknesses in the vendor-licensee interface execution were identified as additional contributing factors. The operating experience of core components (fuel and control rods) was also l approaching the materials' service lifetime and fuel bum-up limits which were supported by the available operational and experimental data. At the same time, foreign data under evaluation, l was indicating that the capability af high bum-up fuel (> 50 gigawatt days per metric ton uranium) to withstand moderate power transients could be significantly less than previously assumed.

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4. Existing Staff ond Inspection Activities Prior to the implemeniction of the action plan, the NRC had reduced its direct review and oversight of core reload activities by approving generic design criteria for individua1 reactor fuel

-vendors and moving operating limits from the technical specifications to the core operating limit report (COLR). Although the staff reserved the right to audit or inspect these activities, there was no increase in NRC audits or inspections. Inspection activities were in reaction to problems as they arose. The staff had also issued generic communications regarding fuel and core operating problems. Scheduled meetings with vendors were used as a technical forum to discuss core component operating performance and surveillance activities. The VIB staff also represented the NRC.at semiannual meetings of the Nuclear Fuel User's Forum. The fuel performance annual reports (NUREG/CR-3950), wtilch were then based on publicly available information such as licensee event reports (LERs) and annual vendor reports, provided descriptions and evaluations of specific fuel operating experience and emerging generic trends.

The VIB staff led periodic reactive inspections of nuclear fuel vendors, and both VIB and SRXB

. staff participated in the 1993 Augmented inspection team (AIT) activities at H. B. Robinson and

, SPC-ND. A follow up vendor inspection, led by VIB and supported by SRXB technical j specialists, at the SPC-ND facility in Richland, Washington, was completed in early 1994. This inspection became the model for the performance-based vendor inspections, and served as the j first scheduled inspection of a nuclear fuel vendor's engineering and manufacturing facilities.

l SRXB technical staff, with contracted technical assistant (TA) support, also performed a i technical audit of a new (GE-11) fuel design licensing qualification and evaluation of compliance

! with Amendment 22 of the approved GESTAR-il topical report on generic design criteria at i GE's engineering facility in San Jose, Califomia. This audit provided the format and procedures L for inspecting vendor compliance with the SER limitations of their approved methods.

l A technical audt of Arizona Public Service's application of approved vendor methods was .

! performed by the licensing project manager, SRXB staff, and a representative from the region. l The audit reviewed the adequacy of the methods and procedures for performing core reload analysis for the Palo Verde plants. This audit provided a basis for the licensee / plant performance-based inspections.

5. Formal Action Plan The Core Performance Action Plan was formally initiated in October 1994 to assess fuel and control rod performance and reload core design QA activities that may impact plant safety. The action plan consisted of a planned, coordinated, and systematic program to monitor, evaluate and improve core performance. The main tasks of the action plan were the performance-based inspections of nuclear fuel vendors and licensee / plant reload analyses. The results of the performance-based inspections of the vendors were used to focus the licensee / plant reload

- analysis reviews and both inspections included review and evaluation of the licensee-vendor interface. The existing inspechon Manual Chapters (IMCs) were used to develop draft inspection plans for each inspection type. Lessons leamed from the inspections have provided insights to be used to evaluate the adequacy of the IMCs for future application. The regions actively participated throughout the process. SRXB staff participated in resident counterparts meetings in several regions to provide information on emerging issues, such as control rod 3

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insertion and reactivity management concems, to facilitate early identification and feedback on

. fuel performance issues.

The results of these inspections were provided to licensees and vendors by way of inspection ,

reports conforming to the IMC 0610, " Inspection Reports," format. Licensee performance was also reflected in the assessment of licensee performance process and provided input to regional enforcement evaluations.

A Core Performance Workshop held in October 1996, a presentation on " Operating Experience identified Core Performance lasues" at the November 1996 CSNI Specialists Meeting on '

Nuclear Fuel and Control Rods, and breakout sessions at the Regulatory information Conferences in April 1996 and 1997 proved to be an effective method of providing information and generating feedback from licensees and vendors.

In addition, generic communications were prepared, including:

e Information Notice 93-82, "Recent Fuel and Core Performance Problems in Operating Reactors," October 12,1993 e Information Notice 94-40, and Supplement 1,

• Failure of a Rod Control Cluster Assembly to Fully insert Following a Reactor Trip at Braidwood Unit 2,*

December 15,1994 e Information Notice 94-72, " Increased Control Rod Drop Time from Crud Buildup,'

October 5,1994 e Bulletin 96-01, " Control Rod Insertion Problems," March 8,1996 i

e Information Notice 98-29, " Predicted increase in Fuel Rod Cladding Oxidation,"

August 3,1998 e Propceed Supplement to Bulletin 96-01, " Control Rod Insertion Problems," issued for comments May 20.1997, withdrawn January 26,1998 The inspections of nuclear fuel vendors consisted of evaluating the performance of the five domestic vendors of nuclear fuel and core components and some of their suppliers. The goal was to conduct an inspection of each fuel vendor in the first 12 to 18 months and to conduct an inspection of at least one licensee's reload analysis per region. In all,10 vendor inspections or follow up inspections were conducted. The results of the fuel vendor inspections provided input for the inspection of licensee / plant reload analyses and generated additional data on core performance.

The scope of the vendor inspections included neutronics engineering, fuel fabrication, fuel bundle assembly, and related fuel-service activities. VIB team leaders planned and led i inspection teams consisting of qualified inspection staff members from VlB, technical specialists l from SRXB, and contracted technical specialists for each engineering and manufacturing facility 1 4 inspected. Each inspection required 2-3 days of inspection preparation at the vendor's facility l'

by the VIB team leader,2-3 days of inspection preparation at headquarters by the full team, at

least one full week of inspection effort per vendor's facility by the full team, and at least one full

{ week to write the report.

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The inspections of licensees' reload analyses consisted of evaluating the performance of licensees that perform core reload analysis functions, either in-house or in active participation with the vendor. The extent and effectiveness of vendor QA oversight by the licensee were also evaluated in these inspections. The results of these inspections in turn provided additional input for the future inspection of nuclear fuel vendors and generated additional data on core performance.

To determine the initial licensee / plant inspection priorities for the inspections in each region, SRXB evaluated the candidate licensees with input provided by the region staff and project managers. The criteria for the preliminary rankings included such factors as e mixed core reload designs, o mixed vendor core components, l e licensee reload design responsibility, i e core component reliability history, and I e plant operational problems.

Documentation of core reload analysis / licensing procedures and approved topical reports for individual licensees also identified candidates for inspection and helped to prioritize the inspection schedule. In several instances generic concems from allegations helped to determine the inspection scope, again with input and coordination from the regions on the l licensee-vendor core design and reload analysis responsibilities and interfaces. The final

selection was made from reload analyses packages that had been reviewed during the vendor

inspections, so that the licensee-vendor core design and reload analysis responsibilities and j interfaces could be evaluated.

l The scope of the licensee / plant inspections typically included the following areas. l

• Organization and interfaces

• Reload analysis capability i e Failed fuel assessment

, e - Self-assessment activities

! e Vendor inspections / oversight functions l

e Transition to mixed core reloads

• Design control procedures l e Staff training and qualification The inspection schedule and resource requirements for these inspections were coordinated I with the region staff for effective implementation. Each inspection was led by a team leader l from the region or the licensee project manager and included SRXB technical specialists, i members from the region, and contractors, as required. Each inspection required 2-3 days of j preparation at headquarters by the full team, one full week of inspection effort at the licensee j facilities by the full team, and at least one full week to write the report.

As part of the action plan, the staff identified, documented, and categorized core performance problems and root cause evaluations that were further evaluated during the inspections. The staff also provided input to vendor and licensee evaluations, regional enforcement evaluations, 1 ano 96r,sric communications, as appropriate. The information gathered was correlated with

! periodic analysis of generic fuel performance problems and further evaluated regarding the j need for information notice updates. The data gathered during this task will provide input for an

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enhanced NUREG/CR-3950," Fuel Performance Annual Report." The reactivation of this report has been proposed to evaluate the generic core performance data and identify emerging trends based on the independent data acquisition and analysis resulting from this action plan. The regional staff was also consulted in the development of the inspection plans and procedures for better tracking and documentation of core performance experience. The inspection plans and ,

procedures used during the inspections supplemented the existing IMCs used for core '

performance related inspections.

This action plan was also intended to enhance staff analyses of extended cycle and fuel bum-up issues by supporting planned research activities in analyzing available experimental data.

However, the emerging high bum-up fuel issues were transferred to the High Burn-up Action l Plan (TAC M91256), and later to the Agency Program Plan for High Bum-up Fuel. .

A closeout plan working meeting was held on September 1-3,1998 with members of the l inspection teams. The purpose of the working sessions was to:

e evaluate generic results from the vendor and licensee inspections, e identify and propose followup of generic issues, e incorporate feedback from Region inspectors, e review existing inspection criteria and guidance for inspectors, o write Action Plan summary and closeout memo.

6. Recommendations In addition to continuing to monitor fuel performance and to support the regions on vendor-related issues, the following activities were proposed by the team members to build upon the lessons leamed during the implementation of the Action Plan.

1. The Nuclear Procurement issues Committee (NUPIC) established the Nuclear Fuel Committee in response to the staff's vendor inspections and in recognition that fuel is  !

the most expensive vendor-supplied product the utilities purchase. NUPlc facilitates the

' sharing of utility resources in the performance of QA program audits of nuclear fuel fabricators. Recently, NUPIC has increased the technical content and focus of the fuel fabrication vendor audits. For example, NUPlC is conducting joint technical assessments of the LOCA analyses of BWR fuel vendors with the BWR Owners Group.

On the basis of this industry initiative, the NRC vendor inspection program envisioned at the onset of the action plan is no longer necessary. Instead, the staff recommends that the NRC actively monitor industry performance of vendor audits and surveillances through continued interaction with NUPIC and the Owners Groups. The need for further NRC vendor inspections will be re-evatusted periodically based on the performance of the industry's audit program.

2. The staff will maintain the capability to support reactive (event-driven or Part 21 follow up) inspections and inspections needed to resolve allegations. The draft inspection guidance that is based on the existing IMCs, as supplemented by the inspection plan formats developed through the action plan, should be finalized. The resulting inspection guidance will be used to perform future performance-based fuel vendor inspections. The revised guidance will be able to be tailored to fit the type of inspection needed.

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3. To keep abreast of fuel performance, the staff will continue to hold technical information .

exchange meetings with the fuel vendors to leam of new reload core designs and to obtain feedback on fuel defects and lead test assembly program results.

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4. As part of the action plan, the staff identified, documented, and categorized core performance problems and root cause evaluations that were further evaluated during the inspections. The information gathered was correlated with periodic analysis of ,

generic fuel performance problems and further evaluated regarding the need for l information notice updates. An enhanced core performance annual report (i.e., the data gathered during this task action will support the development of NUREG/CR-3950, " Fuel Performance Annual Report") is proposed to further evaluate core performance data and identify emerging trends based on the independent data acquisition and analysis  ;

resulting from this action plan. The funding for the report is not currently in the budget. I It will cost approximately $60K to publish the report.

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. r Table 1 Regulatory Basis for Fuel / Core Design Criteria e 10 CFR Part 50, Appendix A, " General Design Cnteria for Nuclear Power Plants," I

. General Design Criterion (GDC) 10. " Reactor Design," and GDC 12, " Suppression of Reactor Power Oscillations"

! e 10 CFR Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and j Fuel Reprocessing Plants"  :

e Licensee / Plant Updated Final Safety Analysis Report (UFSAR), Chapter 4.2, " Fuel  ;

System Design Requirements"

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e Licensee / Plant Technical Specifications, Chapter 3.12, " Core Thermal Limits" '

• Nuclear Fuel Vendor's Quality Assurance and Technical Topical Reports approved by -

the NRC e NUREG-0800, " Standard Review Plan," Section 4.2, " Fuel System Design," and .

Appendix A, " Evaluation of Fuel Assembly Structural Response to Extemally Applied Forces" e NUREG/BR-0058, " Regulatory Analysis Guidelines of the U.S. Nuclear Regulatory Commission" l l

! e. Generic Letter (GL) 83-11, " Licensee Qualification for Performing Safety Analysis in Support of Licensing Actions" e GL 88-16, " Removal of Cycle-Specific Parameter Limits From Technical SpecCications (COLR)"

e GL 90-02, Supplement 1, "Altemative Requirements for Fuel Assemblies in the Design Features Section of Technical Specifications" e SECY-92-263, " Staff Plans for Elimination of Requirements Marginal to Safety" i

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