ML20046C866
| ML20046C866 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point, Palisades File:Consumers Energy icon.png |
| Issue date: | 05/07/1993 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Selin, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20046C856 | List: |
| References | |
| NUDOCS 9308120337 | |
| Download: ML20046C866 (3) | |
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. fr Vke President POWERING suciaar operarians i MKHIGAN'5 PROGRESS En&onmental& MmcalSer&es General othces 1945 West Parnall Road. Jackson. MI 49201 (517) 788-0453 May 7,1993 Honorable Ivan Selin, Chairman U. S. Nuclear Regulatory Commission Mail Stop 16G15 Wohington, DC 20555
Dear Chairman Selin and Fellow Commissioners,
During the past four years, Consumers Power has been active in the support of the Modular High Temperature Gas-Cooled Reactor (MHTGR) Program through Gas-Cooled Reactor Associates (GCRA).
While confirming development and a demonstration plant are required, the MHTGR offers the potential of a far superior nuclear option projected for commercial deployment early in the next century. A copy of our recent testimony to the House Subcommittee on Energy is enclosed that includes the bases for our support plus the status of and recommendations for the Program.
The Administration is proposing to terminate the U.S. MHTGR Program due to "no near-term commercial application." In our view, this is both unfounded and illogical. For the near-term, obvious emphasis within the electric utility industry is on demand-side management with generation expansion being predominantly with natural gas fired, combined cycle plants. Further, with the commensurate projections for solving radioactive wastes disposal problems, the commercial deployment of the MHTGR is responsive to when most users project the revival of the nuclear option.
More recently, the NRC staff has proposed to stop all work on the preapplication review of the MHTGR design. In our view, this action is considered premature until Congressional action on the MHTGR budget for FY '94 is completed. Accordingly, we urge the NRC to maintain a steady level of effort for this activity. Timely and satisfactory closure of the PSER is crucial to the Program.
If there are any questions or a need for additional information, we would be pleased to respond.
Sincerely,
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David P. Hoffman e
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V STATEMENT SUBMITTED FOR THE RECORD APPROPRIATIONS SUBCOMMITTEE ON ENERGY AND WATER DEVELOPMENT UNITED STATES HOUSE OF REPRESENTATIVES FY 1994 DOE APPROPRIATIONS FOR MODULAR HIGH TEMPERATURE GAS-COOLED REACTOR PROGRAM FREDERICK W. BUCKMAN, PRESIDENT AND CEO CONSUMERS POWER COMPANY AND DIRECTOR OF GAS-COOLED REACTOR ASSOCIATES Mr. Chairman and Members of the Subcommittee, my name is Fred Buckman and I am President and CEO of Consumers Power Company. We are the fourth largest electric and gas utility company in the United States, serving approximately six million people in the state of Michigan.
Our company operates nuclear, coal, gas and oil fueled power plants as well as hydroelectric plants.
In addition, we are the principal owner and operator of a natural gas fueled, cogeneration plant that was converted from the unfinished Midland nuclear plant.
Consumers Power Company takes pride in its history of innovations. With regard to nuclear power, our Big Rock Point Plant was one of the first boiling water reactors (BWRs) and is now the oldest operating BWR in the country. We are also the owner / operator of the Palisades Plant, the first Combustion Engineering pressurized water reactor (PWR) Our Midland Plant was to be the first nuclear cogeneration plant supplying steam to the DOW Chemical Company and electricity to both DOW and Consumers Power. It is now the Midland Cogeneration Venture, the first conversion of a nuclear plant and a worthy model within the power industry for future joint ventures to finance, build and operate advanced nuclear plants.
My statement is based on the views of Consumers Power Company, b'it it is also presented on behalf of Gas-Cooled Reactor Associates (GCRA) for which I serve on the Board of Directors.
GCRA is a utility / user organization that supports the development and commercialization of the Modular High Temperature Gas-Cooled Reactor (MHTGR). Our goal is to secure the MHTGR as an attractive nuclear option which is responsive to the needs and interests of a broad base of owner / operators and the Nation as a whole. Within the industry, the MHTGR is viewed as a competitive, follow-on option to the Advanced Light Water Reactors as well as a complementary option that is ideally suited for constrained sites, smaller increments of capacity expansion and cogeneration applications.m As the Nation prepares to enter the 21" century, we are confronting environmental, social and economic concerns with all energy options. These concerns catalyzed the development of our National Energy Strategy which culminated with the enactment of the National Energy Policy Act W
in June 1991, 22 utility executives submitted a joint letter to the government reiterating broad utility support for the MHTGR as an attractive follow-on option to the ALWR. At that time, the MlffGR was a candidate for the Nation's New Praluction Reactor (NPR) which was seen as a unique opportunity to advance commercial MHTGR deployment.
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of 1992. While most elements of the Energy Policy Act have been supported by the new AJm:ninratica, there are several disappointing exceptions. In particular, Subtitle C, Advanced nuclear Reactors, has been largely precluded by the Administration's proposed funding for the Advanced Reactor R&D Program, particularly the MHTGR Program. This Subtitle provides a framework for developing the MHTGR and the Liquid Metal Reactor technologies to the point whereby informed decisions can be made on whether to demonstrate one or both of these technologies through cost shared prototype plants. It was our hope that this legislation would provide the long sought stability to focus and complete these programs.
Subtitle C also provides specific qualifying criteria that address the issues confronting nuclear These include enhanced safety, cost-effectiveness, standardization and non-proliferation.
power.
In our view, the advanced nuclear system that has the highest overall potential for fulfilling these criteria is the MHTGR. During 1989 and 1990, we applied our nuclear and corporate resources at Consumers Power in a Feasibility Study of deploying a MHTGR Lead Project. Based on that effort and our continued assessments, we are convinced that the MHTGR offers the highest potential of any nuclear option for our generation system and for achieving corporate and public acceptance.
The corr.erstone of MHTGR technology is a fundamentally simple reactor safety concept that precludes severe core damage and core disarray accidents, an important consideration in gaining enhanced public acceptance of nuclear power. The MHTGR employs passive design features and inherent characteristics to retain fission products at the source of their generation - within the ceramic coated fuel particles. This design approach assures public safety without reliance on safety systems that require operator action or rely on AC-powered equipment. Resultant safety margins provide the technical basis to eliminate offsite evacuation and sheltering plans. Further, key safety attributes can be demonstrated to the public in full scale testing of the reactor module.
One of the significant commercial benefits of the MHTGR's simple safety concept is the potential for much easier compliance with regulatory requirements and thereby reduce the business risks associated with nuclear power. The ability to produce economic power while maintaining compliance with safety regulations is a primary source of business risks to the owners and operators of nuclear plants in the U.S. and many other countries and a key issue relative to investor acceptance of nuclear power. In addition, owner / operator acceptance is enhanced by the M.HTGR's radiation cleanliness which results in low personnel exposures, low radwaste volumes and relative ease of decommissioning, all of which have been demonstrated at the Fort St. Vrain HTGR plant. Further, the relatively small power rating of individual modules permits incremental capacity additions and adaptation to changing market circumstances plus improved overall generation system reliability.
Accordingly, the MHTGR should suit a broad range of prospective owner / operators seeking a competitive, low-risk nuclear option. In our view, it is the only nuclear option well suited for the evolving Independent Power Producer (IPP) market. Further, the MHTGR is ideally suited for the export market, particularly the rapidly growing developing countries. Commitment to reduce our foreign trade deficit must include commitment to advanced technologies that have high export potential, such as the MHTGR.
The MHTGR has unique high temperature capabilities within the family of nuclear options.
With state-of-the-art technology, the MHTGR can be applied to modern steam power conversion equipment, closed-cycle gas turbine power conversion equipment, and a wide range of industrial 2
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v process heat / cogeneration applications, including hydrogen and methanol production. Until recently, emphasis has centered upon steam power conversion, building upon the base provided by the New Production Reactor (NPR) Project. However, a joint DOE / private-sector sponsored evaluation of the closed cycle gas turbine concept has proceeded in parallel since 1989. Given the deferral and uncertainty of the NPR Project, the general stretch-out of the expected nuclear market and the singular opportunity for a cost shared demonstration project framed within the Energy Policy Act, the MHTGR Program has undertaken a priority evaluation of which MHTGR application is best suited for initial deployment. While there is further work to be done in FY 1993 to complete this evaluation, results to date provide confidence that the Program should focus on the Gas Turbine (GT) as the concept for initial deployment. Key factors are:
The GT concept exploits defense and aerospace derived technologies (e.g., gas turbines, magnetic bearings and compact heat exchangers) - a worthy example of commercial spinoff potential from government funded programs wherein the U.S.
enjoys a current technological advantage. With related state-of-the-art technologies, the GT offers net efficiencies in the range of 48%.
Evaluated power costs are much improved due to the higher efficiencies, plus the net equipment reductions and improved reliability potential associated with the gas turbine power cycle. Further efficiency and economic improvements are achievable with the development of even higher temperature fuels and/or combined cycle designs.
The higher efficiency reduces waste heat rejection to the environment and, combined with the high temperature of the reject heat, the GT concept accommodates dry cooling and is therefore siteable on water constrained sites.
The passive safety features of the reactor system are retained plus the class of accidents associated with potential steam / water ingress to the reactor is essentially eliminated.
The potential for international cooperation to share the development and demonstration costs of MHTGR-GT deployment is enhanced. This is particularly relevant with the current constrained budget realities.
While there are additional development costs, the power cost savings that would be realized in any significant population of plants will provide substantial benefits relative to the incremental j
costs. Environmental advantages would provide additional, but more difficult to quantify, benefits.
Altogether, the potential to compete with natural gas fired turbine / combined cycle plants, the potential for low ownership risks and the potential for broad international energy market applications justify priority for MHTGR-GT development.
In the near-term, the focus of ongoing development should be directed toward issues / activities that are critical for the prototype plant deployment decision.
In our view, the key high priority issues / activities a e:
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Fuel Development and Qualification - The MHTGR safety concept is bas 6d on the fuel particle coatings providing the primary fission product containment function.
While there are numerous technical advantages to this approach, it has yet to be fully demonstrated.
In particular, confirmatory capsule irradiation tests must be successfully completed, and the process for assuring the required fuel manufacturing quality must be demonstrated to the satisfaction of regulatory authorities and the prospective users.
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Licensing Policy and Criteria Acceptance - The key to realizing the commercial potential of the MHTGR concept is to capitalize on its inherent and passive safety features to ease the licensing compliance process. A safety and licensability review by the NRC was initiated in the fall of 1986 and led to their Draft Pre-application Safety Evaluation Report (PSER) in March,1989. While this report served as a substantial confirmation of the MHTGR's enhanced safety concept, key policy / criteria related issues were identified. Timely closure on these issues is urged since it potentially impacts the ongoing design development effort.
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Design and Licensing Development - Sufficient design and licensing development of the GT concept must be advanced to achieve a satisfactory Preliminary Design Approval from the NRC plus provide a sound basis for evaluating its economic potential.
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Program Strategy and Plan - The overall Plan to complete the design, technology and licensing development, to deploy a demonstration project and define the roles of the participants, including any international cooperation, must be established and agreed upon. During the past year, the prospects of compliance with the Energy Policy Act (Subtitle C) plus the related direction from last year's Appropriation Bill revived such efforts within the Commercial MHTGR Program. For a U.S. based project, it is posed to build the prototype plant at a remote government site, in order to accommodate demonstration testing in support of early design certification, plus support other potential Government missions.
However, in light of DOE's proposed budget, the advancement of any MHTGR Program is dependent on Congressional support.
Whereas a DOE budget level in excess of $65 million is required to meet the Energy Policy Act (Subtitle C) timetable, we acknowledge that this timetable must be delayed, as practically all government funded programs are budget constrained. However, we urge the preservation of the Subtitle C logic for determining whether the MHTGR is worthy of a cost-shared demonstration project. Accordingly, we respectfully recommend a minimum DOE funding level of $25 million for FY 1994 with programmatic emphasis as discussed above.
Mr. Chairman, you and this Subcommittee deserve much credit for sustaining a viable MHTGR Program to date. Your continued support is crucial.
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