ML20044C033
| ML20044C033 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/10/1993 |
| From: | Bergman T Office of Nuclear Reactor Regulation |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| TAC-M80517, NUDOCS 9303170016 | |
| Download: ML20044C033 (2) | |
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March 10,1993 1
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- Docket Nos. 50-445 l
and 50-446 DISTRIBUTION:
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.Mr. William J.'Cahill Local /NRC. PDR EJordan.
Group Vice President, Nuclear PDIV-2 Reading
.RJones d.j TU Electric Company JRoe.
LACRS(10)..
400 North.0 live Street, L.B. 81 MVirgilio Plant File L Dallas, Texas 75201 BHolian.-
LYandell,RIV EPeyton.
.TBergman.
Dear Mr. Cahill:
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2, TOPICAL REPORT-RXE-91-002, " REACTIVITY ANOMALY EVENTS METHODOLOGY",(TAC N0. M80517)
By letter dated January 19, 1993, the staff. issued.a ~ safety evaluation (SE) o'f topical report RXE-91-002, " Reactivity Anomaly Events Methodology." - The'SE concluded that the methodology described in the report -'is acceptable ~ for. use
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by TU Electric for Comanche Peak Steam Electric Station Units land=2.
3 As a result of additional information obtained following issuance of the SE, the staff is supplying the following' clarification. Section 3.3 of the:
staff's SE discusses additional conservatisms that the licensee had: included in the hot-zero-power control-bank withdrawal analysisk The SE states that the licensee had neglected the effects of the' Doppler; reactivity feedback 1
resulting from the power increase. Subsequent discussions with the licensee-revealed that, while the core physics calculations.do not take creditt for the-4 Doppler feedback, the transient analysis does include Doppler feedback'.
effects. The method used.in each case is conservative for its. particular -
application. This issue had been partially addressed by letter dated February 14, 1992, in response to a _ request for. additional information.
Because the application of the Doppler feedback effects in the hot-zero-power.
control bank ~ withdrawal analysis is-conservative, the staff's conclusions. are unchanged and the analysis is acceptable.
i Sincerely, Original Signed By:
Thomas A. Bergmar,. Project Manager Project Directorate IV-2 Division of Reactor Projects.III/IV/V Office of Nuclear Reactor. Regulation cc: See next page
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. Senior Resident Insp'ector
.JabkR.Newman,Esq.:
e U.S. Nuclear Regulatory Commission -
Newman & Holtzinger-P.? O.: Box 1029 1615 L Street, N.W.
- Granbury, Texas' 76048 Suite =1000)
Washington, D. C. 120036-a Regional Administrator, Region IV U.S. Nuclear' Regulatory Commission Chief, Texa's Bureau of. Radiation Control 611 Ryan Plaza Drive, Suite 1000 Texas Department of Health:
Arlington, Texas 76011 1100 West;49th Street'-
Austin, Texas-'78756 Mrs. Juanita Ellis, President Citizens Association for Sound Energy Honorable Dale McPherson 1426 South Polk County' Judge Dallas,' Texas 75224 P. O. Box 851 Glen Rose, Texas 76043-1 Owen L. Thero, President Quality Technology Company-Lakeview Mobile Home Park, tot 35
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4793 East Loop 820 South Fort Worth,. Texas 76119 Mr. Roger. D. Walker,. Manager -
Regulatory Affairs for Nuclear
- Engineering Organization _
Texas Utilities Electric-Company
'400-North Olive: Street, L.B. 81
' Dallas, Texas! 75201 Texas Utilities, Electric Company c/o Bethesda 1.icensing.
J3 Metro Center, Suite 610
- Bethesda,. Maryl and 20814
~ William A. Burchette, Esq.
Counsel for Tex-La Electric
-Cooperative of Texas Jorden,=Schulte, & Burchette 1025 Thomas Jefferson Street, N.W.
Washington, D.C.
20007 l
GDS Associates,_Inc.
. Suite 720-1850_ Parkway Place
-Marietta, Georgia. 30067-8237
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A AECL AECLTechnologies g
A.D. Hink
. Vice-Presidem and 9210CDrporateBoulevard GmralMapr -
Suite 410 -
l Rockville, Mar /and -
March 10,1993 (Project No. 679) 208s0 USA 1-800-USA-AE CL (301)417 0047 Fax (301)417-0746 mex403a2 Dr. Ivan Selin Chairman -
U. S. Nuclear Regulatory Commission Washington D.C.
Dear Dr. Selin:
I have been advised by your staff that a reassessment of the schedules and manpower allocations related to the review of the Advanced Reactor designs is underway and that such a reassessment could affect the overall schedule for the review of our CANDU 3 design. As you know, we have been working with the NRC since May of 1989 when'we first indicated our intention to apply for design certification under 10 CFR Part 52 as one of the first applicants to respond to that regulation. Since that time there have been a number of schedule
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modifications and changes but we have continued to work closely with the NRC staff, providing technical information which would assist in the evaluation of the CANDU' design.
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~In the December 16,1992 letter (containing SECY-92-393) from the commission, a~ schedule was established based upon NRC's estimate of resources available to apply; to our preapplications activities. Using this schedule as a basis, we hase accelerated the mobilization of our staffin Toronto, Saskatchewan and Rockville so as to be certain we would provide you with all the infonnation you needed in a timely manner. We have also committed to a meeting next week with EPRI to begin activities on a joint program with them for a heavy water requirements document prepared in the same fashion as the documents used for the' advanced light water reactors. In addition, we have increased activities related to the generic design of CANDU 3 currently underway in Canada.'
In fact, we have recently concluded: an agreement with the province of Saskatchewan whereupon'they would contribute $20 million to be matched by an additional $20 million supplied by AECL to complete this design. Hence the funding to complete the design of the CANDU 3 is in place.
As you can see, our program has reached a high level of activity and any change in the NRC's intentions to review our design for design certification would have a serious programmatic and financial impact on AECL. We are certainly aware of the restraints that have been placed on the NRC and other U.S. government agencies with regard to budgets and manpower-
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availability.
However, we believe that there are mitigating circumstances involving the CANDU program which should be considered in making your decision. We respectfully suggest that you consider the following:
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. Dr. Ivan Selin
.USNRC i
Page 2
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' March 11 1993.
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The CANDI-3 program is unique in that it is an evolutionary plant based on proven teclu > logy and over 200 reactor years of operating experience. It has j
been placed in the advanced reactors group primarily ' for - administrative '
convenience of NRC in their organizational structure...We have been advised by I
NRC and ACRS staff that no prototype would be necessary since CANDU 3 is-t based on proven technology and, therefore, meets a major criteria set for evolutionary design. We have been assured by your staff that the CANDU 3 design is recognized to be further advanced than the other reactor designs which are being funded primarily by the DOE. It has always been our contention that the CANDU 3 design was in the same situation as other ALWR designs and if you plan to proceed with the review of the ALWR reactors, 'you should also" consider CANDU on the same footing. In fact, to do otherwise could be considered a violation of the U.S. Canadian Trade Agreement and your own-regulations which provide for a review of designs.
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o The CANDU program with NRC is unique as compared to the other advanced -
reactors and several of the light water reactors in that we are paying for the.
I NRC evaluation. To date, AECL has been billed for'$320,000 and several more l
invoices are on the way which will be significantly larger due to an increase in activity by the NRC over the past few months. We were told at the beginning' l
of the program that under the NRC cost recovery we.would haveL to pay our own way and we agreed to that. AECL has invested in preparation of the CANDU 3 design and we are not now receiving nor have we in the past l
received any money from the DOE or any other U.S. government agency to develop this nuclear reactor system. Since the CANDU 3 program represents income to the NRC, it appears reasonable that you would want to continue this program rather than terminate.
CANDU reactor technology has proven itself 'to be extremely reliable and o
effective in operations throughout the entire world.
In order to' offer this 1
technology in the United States it will b.: necessary to receive a license from the NRC. If we are denied the opportunity to be licensed in the U.S., it'would be' eliminating one possible future option for U.S. utilities to select fori heir i
t applications. In the time period since we'have established AECL Technologies.
j in the U.S., we have discussed our overall plans with utilities and other interested _
parties and there has always been encouragement on their part to proceed with this program. We are now planning to work with' EPRI and U.S. utilities-to~
establish a set of advanced heavy water reactor requirements compatible with those already available for the light water reactors. Furthermore, AECL, through ~
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Dr. Ivan Selin USNRC Page 3 March II,1993 its activities in Canada, will complete the total design of the CANDU 3 much in the same manner as planned for the light water reactors under the first-of-a-kind engineering program. All of this will be done at no cost to the U.S. taxpayer but l
the results will be made available to U.S. utilities through EPRI and the NRC.
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AECL has formed a U.S. company headquartered in Rockville and we have i
o entered into agreements with U.S. companies to explore the possibility of establishing an entity in the U.S. that would have the capability of delivering a full system. Therefore, if we are mecessful in this venture we will be creatmg jobs and providing new, proven, successful technology to the United States.
i It is for these reasons that we oppose any action that would terminate or delay the preapplication -
activities that have been planned for the CANDU 3 design. We would like the opportunity to meet with you and ' discuss this subject more thoroughly and we will be contacting your office to arrange for such a meeting. Thank you for your consideration.
Very truly yours, i
N A.D. Hink Vice President / General Manager i
AECL Technologies ADH/dw cc:
Kenneth C. Rogers, Commissioner James R. Curtis, Commissioner i
Forrest J. Femick, Commissioner E. Gail de Planque, Commissioner 1
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Dr. Ivan Selin i
.USNRC Page 4 -
March 11,1993 -
cc:
Mr. James M. Taylor, NRC/EDO O
Dr. Thomas E. Murley, NRR/ Director Mr. Robert C. Pierson, NRR.
l Mr. Thomas H. Cox, NRR Mr. John N. Donohew p_
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