ML20101P597

Discusses Advisability of Frequent Fuel Element Insps.No TS Requirements Exist for Fuel Element Insps.Proposes That 20% Insp of Fuel Elements Take Place Each Yr.Altered Procedure Will Responsibly Address Both Sides of Dialogue

ML20101P597
Person / Time
Site:	Aerotest
Issue date:	06/25/1992
From:	Simens H AEROTEST OPERATIONS, INC.
To:	Mendonca M Office of Nuclear Reactor Regulation
References
NUDOCS 9207130147
Download: ML20101P597 (2)

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AEROTEST OPERATIONS, INC.

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i Marvin M. Mendonca 25 Jely 1992

, U.S. Nuclear Regulatory Commission PDNP

M.S. 11-B-20 Washington, D.C. 20555 Docket 50-228 Dear Marvin.

During this past year, a dialogne has been underway regarding the advisability of frequent fuel element inspections. On the one hand, the original fabricator of the fuel points out that so long as the pool water quality is maintained at a high purity level the fuel need not be inspected except occasionally, and even then only from the hottest region of the core. However, the fabricator is steadfast that even under the best operating conditions, a modest portion (10 to 20%) of the core should be visually examined on a regular basis. The other side of the dialogue relates to the desire to protect ti. integrity of the fuel elements, some of which have been in continuous service for nearly 30 years. The feeling is that unless there is a compelling reason to the contrary, the oldest fuel elements should be subjected to as little stress as practicable.

At the Aerotest Radiography nnd Research Reactor (ARRR) there is no Technical Specification requirement for fuel element inspections. However, over the years, we have practiced a procedure of totally defuelling the core once every two years and visually inspecting each fuel element as it is returned to its original lattice position. This procedure has been described to NRC Region V inspectors, and they have added it to the list of operating activitie,s which they examine during their periodic audits of our operation.

Consistent with the thinking described above, we propose to change the manner in which we examine our fuel elements. Starting this year, we propose to examine 20% of the fuel elements in the core, especially those in the highest flux region. After this year, it is proposed that the 20% inspection will take place every year. We believe chat this altered procedure will responsibly address both sides of the dialogue.

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4 Please consider this proposed change in the ARRR procedures.

}- and adviso us of any difficulty you may foresee in its j- implementation.

2 Sincerely, I/

] 11. G . Simens, President i

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