ML19341C555

Responds to Professor Rea 801226 Ltr Re Facility.Core Meltdown Is Not Possible at Facility.Util Has Provided Justification to NRC Re Relief or 15-minute Time Limit for Public Notification

ML19341C555
Person / Time
Site:	Fort Saint Vrain
Issue date:	02/23/1981
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Kuzmycz G Office of Nuclear Reactor Regulation
References
P-81062, NUDOCS 8103030741
Download: ML19341C555 (5)

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February 23, 1981 F2rt St. Vrain cP 0

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Mr. George Kuzmycz -

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Washington, D. C. 20555 @4 Doc <et No. 50-267 I SUE .ECT: Response to Professor Rea's Letter December 26, 1980

Dear Mr. Kuzmycz:

In response to Professor Rea's letter the following information is offered keyed to the paragraph numbers of the subject letter. Since the letter is written more along the line of making statements rather j than asking questions the following is an attempt to address the

! issues of the statements made:

1. Fort St. Vrain has had some operational problems. It is a j first-of-a-kind plant built under the provisions of the Power Reactor Demonstration program, and not unlike the development of water reactor technology in its beginning the gas cooled technology requires development. The first-of-a-kind equipment at Fort St. Vrain has resulted in some problems along with conventional equipment which has been applied in services for which there is no operating or design history. Although it may appear that the operational problems exper'.enced to date have some implication on safety it should be noted that with the design conservatism, redundant components, etc., the plant and the plant control systems have always responded in a conservative manner with reference to the health and safety of the public.

With refererce to chronology of General Atomic (GA)

! ownership we are not aware of any bankruptcy being

involved. GA was a part of the General Dynamics organization in the early design stages of Fort St. Vrain.

Gulf 011 along with many other oil companies interested in i becoming total energy companies bought into General Atomic which then became Gulf General Atomic. The inference that Gulf 011 purchased the plant is totally false. The plant #7 j was purchased by Public Service Company of Colorado by \

contract agreements in 1965, and has always been Public l Service Company's plant regardless of the cnange in 0 810303074)

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l ownership of General Atomic. Royal Dutch Shell aisc bought into General Atomic as stated, but again Royal Dutch Shell did not purchase the plant.

In 1979 based on contract agreements Public Service Company accepted the plant from General Atomic for commercial operations. Acceptance of the plant for commercial t

operation, however, does not mean Public Service Company purchased the plant in 1979. Public Service Company purchased the plant in 1965, at which time the purchase was reviewed by the Public Utilities Commission ( and therefore the rate payers) as well as the stockholders. Acceptance of the plant in 1979 was based on contract negetiations which s3rved to benefit the rate payers of Coloradt..

Although operation at Fort St. Vrain has been below that expected we have consistently been improving the capacity and availability of the unit. The operation in 1979 might appear to be poor without further analysis. During 1979 the plant was shutdown for two major outages involving required refueling and installation of Region Constraint Devices to fix the temperature fluctuation problems.

Professor Rea tactfully omitted reference to 1978 and 1980 wherein the plant had availability factors of in excess of 60's and capacity factors in excess of 43fs.

2. While the plant was built under the auspices of the reactor power demonstration program it was not designed to be

" experimental" While we have experienced some problems, and in our attempt to resolve these problems certain testing must be performed in order to gain information for corrective action, the program is certainly not conducted on a trial and error basis. Testing is carefully evaluated and controlled with reference to plant safety and the safety of the general public.

We have no idea what Professor Rea's " surprise inspection" is referencing. It should be noted that almost every NRC inspection is unannounced.

Oak Ridge and Los Alamos have both been utilized extensively in the development and continued analyses of Fort St. Vrain. These organizations are utilized by the NRC on a contract basis to independently review Fort St.

Vrain. Within the context of what Oak Ridge and Los Alamos is contracted to d ), botn organizations are highly qualified and nighly resr,ected in the nuclear industry for their expertise in boch water cooled and gas cooled technciogy.

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3. The reactor core and surrounding materials have been designed far full power operation and the attendant temperatures, and most certainly these temperatures are well within the design limits of the materials utilized.

We beg to differ with the statement that radiation increases exponentially with temperature. Radiation levels are directly dependant on fuel performance and because of our fuel design the fuel can and has performed in an excellent manner. Obviously neutron flux levels in the core tend to increase with incretsing power levels, but material selection has conservatively taken such flux levels into account.

While it is true that there are over 200 radio nuclides produced in nuclear fission the statement that only 24 are monitored is misleading. The total circulating activity is monitored and this total activity is then represented in terms of the more predominate nuclides (Kryptons, Xenons and Iodines) for determining dose conversion factors. So that while the primary coolant is not analyzed for each and every nuclide, the total activity is nevertheless accounted for on a conservative basis.

While we have never heard the term " jerk it forward" the rise to power above 70% will be done on a controlled basis governed by carefully developed test procedures which have been reviewed by the NRC.

Under accident conditions any reactor is subject to core overheating. At least at Fort St. Vrain we are not subject to a meltdown. The core is made completely of graphite and ceramic materials. Upon loss of forced coolant the core can increase to a maximum temperature af 5400 degrees within 83 hours9.606481e-4 days <br />0.0231 hours <br />1.372354e-4 weeks <br />3.15815e-5 months <br />. This is far below the design temperatures of the graphite / ceramic core. In short, a core meltdown is not possible at Fort St. Vrain.

4. Public information programs are presently in progress both on the part of Public Service Company and the State. A public information brochure has been prepared by Public Service Company and will be issued to those people living within the emergency planning zone of Fort St. Vrain.

Public Service Company has, in addition, developed a public information program in the form of a video tape. It is our intention to utilize this program to further educate those people living near Fort St. Vrain. The tape has already been utilized to aquaint the media, local response personnel, and state personnel.

l Regarding the use of potassium iodide as a thyroid blocking agent, the Colorado Department of Health is the only agency l

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authorized to administer drugs. Public Service Company as a private utility nas no authority to issue such material.

Within our emergency plans the Colorado Department of Health has the responsibility to determine the necessity for using the blocking agent.

We have no particular need for cloth filters as such and, in fact, have suggested the use of a damp handkerchief in our public information brochure.

5. We beg to differ with your opinion on the inadequacy of emergency plans, and our opinion is shared by the Governor, State and Local officials, as well as the NRC.

The subject of potassium iodide was addressed in item 4 above.

The Public Information Brochure does definitely define evacuation centers. It is impossible to predetermine evacuation routes with reference to wind direction as we have no idea which way the wind will be blowing at any given time. The evacuation routes, however, are defined and various traffic control points are established and manned along these routes. Should other evacuation routes be preferred, such information will be available to the traf fic control points for alternate evacuation routes.

It is true that the emergency planning zone for Fort St.

Vrain is five (5) miles. This zone is defined by accident analysis and is conservative with reference to the protective action guidelines. We have recognized that soma people within the five (5) mile emergency planning zone may have special problems such as lack of transportation, handicapped people, etc. The brochure contains a tear off mailer for those people to identify these types of problems so that local authorities can take necessary steps to plan for such special circumstances.

Based on time that is required for an accident to develop at Fort St. Vrain we have provided justification to the NRC for relaxing the 15 minute time limit for public notification. To quote Joseph Hendrie, former Chairman of the Nuclear Reguitory Commission, "If TMI-2 had been an HTGR you would have time to go home and have a sandwich and then come back :nd decide wnat to do."

6. Comparison of Fort St. Vrain to the Titanic is ridiculous and needs no further comment.

Very truly yours, iLbs 77 M&M Don W. Warembsurg r Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DW/dkm 1

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