ML20035H111
| ML20035H111 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/27/1993 |
| From: | Murley T Office of Nuclear Reactor Regulation |
| To: | Hink A AECL TECHNOLOGIES |
| References | |
| NUDOCS 9305030146 | |
| Download: ML20035H111 (4) | |
Text
{{#Wiki_filter:-t C$la- ,o cacyq UNITED STATES -t NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20656 ,o April 27, 1993 Mr. A.D. Hink Vice President / General Manager AECL Technologies 9210 Corporate Boulevard, Suite 410 Rockville, Maryland 20850
Dear Mr. Hink:
I am pleased to respond, at Chairman Selin's request, to your letter of March 31, 1993. As you know, the Nuclear Regulatory Commission (NRC) is reconsidering its effort on all of its work, includir.g preapplication reviews, to be responsive to guidelines established by President Clinton and.the Office of Management and Budget. Accordingly, the Comission is studying options and recommen-dations regarding the process inherent ultimate safety (PIUS), Canadian Deuterium Uranium 3 (CANDU 3), modular high-temperature gas-cooled reactor (MFITGR), and power reactor inherently safe module (PRISM) preapplication review projects. I feel certain that matters discussed in your letter and in your recent conversations with individual Commissioners will'be considered in the deliberations. A recurrent theme in your March 31 letter was that the NRC'is continuing to review light-water reactor applications for design certification, and that equal treatment should be given the CANDU.3 program. - At this time, we are-reviewing four light-water standard designs for standard design certification (SDC) under 10 CFR Part 52. The applicant for each of the designs has. submitted a formal application for an SDC in accordance with the regulation. You have not submitted an application for' standard design certification under Part 52. Our effort to review material you have submitted is a preapplication review conducted pursuant to the Commission's Advanced Reactor _ Policy State-ment of 1986. My point is that the CANDU 3 design review is not a standard design certification application review, and for that reason alone, does not warrant as high a staff review priority as an SDC application. The same is true of the other three preapplication review projects now at the NRC. The CANDU 3 preapplication review has had exactly the same review priority as would be given a preapplication review submittal from any U.S. vendor. n f 29 % & E -u W2Y [
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.j -{ Mr. A. D. Hink, Your letter made several other points with which we are familiar based on our l past conversations and correspondence. I feel certain that all factors will i be considered ir. Commission deliberations to decide on an appropriate NRC course of action regarding our preapplication reviews, including the CANDU 3 preapplication review. Sincerely, t Original sicn06t'l / i Trank J. Kir.:3110 / Thomas E. Murley, Direct r 'l Office of Nuclear Reactor Regulation Distribution: 1 Central File NRC & Local PDRs i EDO 8746 JMTaylor, EDO JHSniezek, EDO JLBlaha, EDO HLThompson, ED0 ESBeckjord, RES l TEMurley/FJMiraglia, NRR JGPartlow, NRR WTRussell, NRR ATGody, NRR-L DMCrutchfield, NRR WDTravers, NRR RCPierson, NRR THCox, NRR i JNDonohew, NRR PWShea, NRR 0GC OPA l OCA NRR Mailroom - EDO GT8746 l BJToms, NRR - ED0 GT8746 PMMagnanelli, NRR - EDO GT8746 PDAR R/F l i f
- see previous concurrence PDAR:ADhk LA:PDST SC:PDAR TECH ED*
PD: PIAR 0FC NAME JDono k PSh'ea)M TCox Y C-RSanders RPih, son s t DATE 04/h93 04/\\h3 04//5 /93 04/15/93 04/h/93 0FC ADAR:NRR n. D:M l ( M Mid\\M.el i NAME DATE 04/lc//93 N04fd93 I 0FFICIAL RECORD COPY ~ <- l GT87467/.Ab/fn 2 l DOCUMENT NAME: 9 h i
~ r. p es 'o, UNITED STATES fs $36 $ pg [l[ld W lI ]i [; f/h; [h)T l 8 't NUCLEAR REGULATORY COMMISSION .f N t WASHING 1ON D. C. 20555 %.....,/ EDO Principal Correspondence Control ._l / I 9 b FROM: DUE: EDO CONTROL: 0008746 DOC DT: 03/31/93 FINAL REPLY: A. D. HINK, AECL TECHNOLOGIES TO: CHAIRMAN SELIN FOR SIGNATURE OF:
- GRN CRC NO: 93-0278 DESC:
ROUTING: REQUEST NRC CONTINUE REVIEW OF THE CANDU 3 DESIGN TAYLOR SNIEZEK DATE: 04/06/93 THOMPSON BLAHA ASSIGNED TO: CONTACT: BECKJ0RD NRR MURLEY SPECIAL INSTRUCTIONS OR REMARKS: FOR APPROPRIATE ACTION.
f 't t OFFICE OF THE SECRETARY [ CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-93-0278 LOGGING DATE: Apr 5 93 i ACTION OFFICE: EDO AUTHOR:' A.D. HINK AFFILIATION: MD (MARYLAND) ADDRESSEE: CHAIRMAN SELIN LETTER DATE: Mar 31-93 FILE CODE: IDR-6 STAND I
SUBJECT:
LTR OF APPRECIATION FOR THE VISIT TO DISCUSS THE DESIGN CERTIFICATION PROGRAM FOR CANDU'3 ACTION: Appropriate DISTRIBUTION: CHAIRMAN, COMRS, OGC, RF SPECIAL HANDLING: NONE CONSTITUENT: NOTES: DATE DUE: SIGNATURE: DATE SIGNED: i AFFILIATION: 1 i h i i l i I e i EDO -- 003746 93-t 9/6 3 - A -C/ i
S,. /\\. gn u W J ECL Technologies A.D. Hink Vu e-Presalent end 9210CorporateBoulevard Genea: Manager Swte410 Rockvine, Maryland 20650 USA 1KO USA AECL (301}417-0047 March 31,1993 Fa-(301 > 417-074e Tele x 403-442 Dr. Ivan Selin Chairman U. S. Nuclear Regulatory Commission Washington D.C 20555
Dear Chairman Selin:
We would like to thank you for the time you gave us last week, and the frank discussion we had regarding our design certification program for CANDU 3. We have now had an opportunity to visit with all five Commissioners, with Dr. Murley and several members of his staff, and with the Office of General Counsel. We also have received a response to our original letter of March 3,1993, from Dennis Crutchfield of NRR. For the past three years, it has been our understanding that AECL Technologies (AECLT) and the NRC were working towards a decision on the issuance of a design certification for the CANDU 3 reactor under the provisions included in NRC Regulation 10 CFR Part 52. It now appears that in order to comply with a 5% reduction in the overall manpower requirements mandated for the agency, the NRC is considering discontinuing, or reducing to a token level, their efforts on our program, including the technical review under way by Research. We believe that such action not only would be a financial and programmatic hardship to AECLT, but also would not be in the best interests of the Nuclear Regulatory Commission and the U. S. nuclear.ommunity in general. It was suggested to us that the NRC may continue to review certain light water reactor designs but will not review other designs including the CANDU 3. In attempting to understand the rationale for this decision, we heard a number of different explanations which we feel do not give adequate consideration to the circumstances related to our program and do not give completely fair treatment to our submission for design certificatice as compared to other vendors. At the risk of repeating things which we may have previously said we would like to review those points in this letter and reaffirm our position regarding continuance of the CANDU 3 program with the NRC. o AECLT is fully committed to complete the design certification process in accordance mth NRC requirements. A Dwe. ion of AEct, Inc. ~
-o i i Dr. Ivan Selin USNRC Page 2 March 31,1993 AECLT has made a major commitment to produce a nuclear system which will o be ofinterest to U.S. utilities. Over $100 million has been spent on the design { j~ of this system and $40 million more is committed and in place, assuring its t completion. We have established a U.S. company and staffed it with qualified - nuclear personnel who are proceeding to transfer the technology from Canada to the U.S. to be put in the form required for sale to U.S. utilities. The receipt of an NRC design certification is necessary in order to fulfill the objectives of our plan and we would not have proceeded to this point were we not assured that the NRC was ready and willing to review our design up to the completion of design certification. AECLT has worked to comply with all NRC requirements and procedures. We l o have agreed to the conditions of 100% cost recovery that were initiated well i after our program started and, in fact, have paid several invoices in excess of S300,000 for senices received from the NRC for the review of our design. As recently as December we agreed on a schedule established by the NRC staff and have increased our staffing in Toronto and in the United States in order to comply with the requirements that we knew would be forthcoming from the NRC based on that schedule. I o in the March 24, 1993, letter from Mr. Crutchfield, the CANDU 3 is still discussed in the context of the advanced reactors group, which includes a number of reactor designs based on technology not yet proven even though it has been clearly stated and understood that CANDU is an evolutionary design based on over 200 reactor years of operating experience and more than 30 plants l throughout the world. Through all the organizational changes and project management changes instituted by the NRC during our program, it was always made clear that we were in the " advanced" reactor group for administrative -l purposes only and that we were considered to be an evolutionary design. We do not feel the CANDU design review should be discontinued because it has i been improperly designated. If the NRC continues to review the designs of i i evolutionary and passive light water plants, we believe AECLT's CANDU 4 program must be reviewed in the same context. o The licensing process established by the NRC has become the benchmark for i world-wide acceptability of nuclear plants. The CANDU is a competitive i j nuclear system which has competed successfully with light water reactors all over the world. If the NRC contmues to license these light water reactors and i does not review CANDU, not only will we be precluded from selling in the United States but it will impact on our ability to market world-wide. It is our 9
j i Dr. Ivan Selin f USNRC Page 3 March 31,1993 understanding that the U.S.-Canada Trade Agreement provides that we receive the same response from the U.S. regulating agencies as if we were a domestic l Vendor. [ CANDU technology is recognized as being among the most reliable and safe o nuclear technologies in the world. We have been told and we believe that the I NRC is genuinely interested in understanding our technology and it would certainly be to the Commission's advantage to remain aware of the technical advances contained ~ in the CANDU system. In order for the nuclear industry to develop in the future, we will need to use the best featt'res of all available technologies and should not preclude any out of hand, especially one which has demonstrated its capability for so many years. In addition to the electric power l generating use, CANDU has other interesting features such as the potential for the burning of plutonium, the reuse of spent LWR fuel, and desalination applications. The NRC, as part of it's mandate, has maintained cognizance of all viable nuclear technologies employed all over the world. A certified design i review of the CANDU will enable the Commission to become involved in such design features as digital computer control systems, on line refueling, automatic activation of safety systems, group separation for common mode failure considerations, on-line testing for reliability assurance, performance-based j regulation, new hydraulic codes and other features not normally reviewed by the Commission. o The long-term plan calls for all U.S. owned CANDUs to be built in the United States by U.S. industry. Toward that end we have already entered into agreements with several U.S. companies who are exploring the possibility of becoming part of a business entity with the capability' of delivering a total system in the future. The interest shown by these companies is based in part on-our commitment to obtain a full NRC design certification. o The CANDU reactor will offer an important and attractive alternative to U.S. ) utilities. If the nuclear market returns, as we believe it will, there will be a need j for more than one nuclear concept and CANDU 3, because of it's size and j reliability, will be an attractive option. AECLT is exploring agreements with EPRI to prepare an Advanced Heavy Water Reactor requirements document l applicable to CANDU that would be analogous to the light water requirements l established by U.S. utilities. In a recent review of. our design at EPRI i headquarters, it was obvious that the advantages of our system are ofinterest to i ( i 5
t Dr. Ivan Selin USNRC l Page 4 March 31,1993 the U.S. utilities and for that reason we are proceeding with them to be certain f that we will eventually comply with all requirements and therefore be in a strong competitive situation. l In summary therefore, we request that the NRC continue the review of the CANDU 3 design on the same basis and schedule as originally agreed. We have now established the working team and the momentum, along with committed financial resources, for this program. Any reduction in effort or stretchout of the schedule would be detrimental to the CANDU program in the United States. As we indicated in our meetings with you, we are prepared to consider innovative approaches which would assist you in compensating for your lack of resources available to apply to this program. It is our strong belief, however, that if you are to continue with the standard design certification program the CANDU 3 must be part of that program. Very truly yours, )' J' 4-A. D. Hink Vice President / General Manager AECL Technologies f:idata'c31icens\\09000inrc-2
e ] Dr. Ivan Selin ~USNRC I Page 5 - 1 March 31,' 1993 i i 1 1 cc: Kenneth C. Rogers, Commissioner j James R. Curtiss, Commissioner Forrest J. Remick, Commissioner E. Gail de Planque, Commissioner i Dennis M. Crutchfield, NRR/DAR Mr. James M. Taylor, NRC/EDO Dr. Thomas E. Murley, NRR/ Director Mr. Thomas II. Cox, NRR Mr. John N. Donohew l -i i P l l l
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