ML20063H518
| ML20063H518 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 07/28/1982 |
| From: | Chipman G ENERGY, DEPT. OF, CLINCH RIVER BREEDER REACTOR PLANT |
| To: | Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8207300297 | |
| Download: ML20063H518 (33) | |
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7 Department of Energy 6
JUL 2 81982 >
T3 Washington, D.C. 20545 OL{ c 9
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The Honorable Nunzio J. Palladino The Honorable James K. Asselstine Chairman Comissioner Nuclear Regulatory Comission Nuclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
20555 s
The Honorable Victor Gilinsky The Honorable John F. Ahearne Comissioner Comissioner Nuclear Regulatory Comission Wclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
20555 The Honorable Thomas F. Roberts Comissioner Nuclear Regulatory Comission Washington, D.C.
20555 Re:
CRBRP Project - Docket 50-537 (Section 50.12 Request)
Gentlemen:
This is in response to the Cownission's Order dated July 21, 1982, regarding Intervenors, Natural Resources Defense Council, Inc. (NRDC) and the Sierra Club, Petition for Investigation, dated July 14, 1982.
In what follows tha Applicants show that:
(1) NRDC's charges are groundless; (2) the Department's actions were proper; and (3) in light of this, the Comission should deny the request. The Department of Energy's (DOE) responses to the Comission's specific questions in the aforementioned order are:
Ql[ESTION1: Are any of the individuals referred to in the petition a part of the Applicants' organization at the present time? If not, when did they depart? If yes, what are their present duties?
RISPONSE-Three individuals were referred to in the petition:
Dr. Anthony R.
Buhl, Dr. William E. Rhyne, and Mr. Donald R. Riley. None of these individuals are part of the Clinch River Breeder Reactor Plant (CRBRP) Project organization at the present time. Their departure dates were December 2,1977, September 29, 1977, and December 11, 1981, respectively.
It should also be noted that one of the two documents relied upon by the petition--a May 27, 1977, memorandum from Donald R. Riley to Anthony R. Buhl--was signed by Mr. E. A. Wright for Mr. ' Ril ey. Mr. Wright's present position is Chief, Reactor and Plant Components Branch, CRBRP Project Office.
In that capacity his duties consist of managing the design and procurement of most of the plant components that are in contact with sodium.
8207300297 820729 PDR ADOCK 05000537 G
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2 QUESTION 2: How were the specific recommendations by the individuals in the two memoranda attached to the petition finally disposed of by the Applicants?
If not finally disposed of, what is their current status?
RESPONSE: The final disposition of the specific recomendations by the individuals referred to in the two memoranda attached to the petition is described in the following discussion. NRDC's petition charges that ty internal documents obtained from Applicants in the course of discovery p in the CRBRP proceedings indicate "a concerted effort to conceal crucial safety
.information{pamannerthatcalls into question the character of the CRBR Applicants."-
NRDC has requested that the Nuclear Regulatory Comission by the Staff into the implications of these documents."3} mediate investigation (NRC) Comissioners themselves "initiste and oversee an Our response to these chargos is as follows:
NRDC's Charges There are two documents which form the basis for NRDC's charges:
(1) a memorandum, dated April 6,1977, from W. R. Rhyne, Chief of the Licensing Branch, to Anthony R. Buhl, Assistant Director for Public Safety, CRBRP Project Office; and (2) a memorandum, dated May 27, 1977, from Donald R.
Riley, Assistant Director for Engineering, to Anthony R. Buhl. The NRDC charges and the salient facts pertinent to each charge are as follows:
Memorandum Rhyne to Buhl, April 6, 1977 NRDC alleges that this memorandum not only indicates "a concerted effort to conceal crucial safety information," but also " displays.a proposal by CRBR personnel to cover up damaging weaknesses in the Applicants safety analysis."4/
In its haste to impugn the Applicants' integrity, NRDC has not described the context in which the document was written; namely, a) the NRC Staff document to which it was addressed, b) the actual Applicants' document which responded to the NRC Staff, and c) the ultimate resolution of the matter between the Applicants and NRC Staff.
In this context, it is clear that the Applicants did not conceal anything, but instead merely expressed their fundamental disagreement with the NRC Staff.
1/ The two documents in question were produced by the Applicants for inspection by NRDC pursuant to NRDC's 18th Set of Interrogatories to Applicants, Nos. I-19 and I-20. As a result of discussions between the Applicants and NRDC, the request was narrowed to encompass only those documents related to the request and covering the time period between January 1,1976, and June 1,1977. See Applicants' Motion for a Protective Order, and Memorandum of Points and Authorities in Support of the Motion for a Protection Order, dated May 4,1982, at page 4.
2/ NRDC Petition at pages 1 and 2.
3/ NRDC Petition at page 2.
4/ NRDC Petition at pages 1 and 2.
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NRDC attempts to support its charge of concealment with the following quotation from the memorandum:
'2.
That we not answer a single question explicitly! Rather, we update the scenario in the TLTM report where we agree that there are inconsistencies, inadequacies, etc., i.e., document unreal scenarios in the report only. However, we should not report sensitivity studies or other information just because NRC asked for it. Planned R&D should be adequately described in the report."
A brief chronology of the pertinent events shows that NRDC's charges are groundless and that the recomendations were properly disposed of, as follows:
a.
On March 30, 1977, the NRC Staff forwarded a set of detailed technical questions to the CRBRP Project Office concerning the Applicants' analyses (Enclosure A). Upon review, Mr. Rhyne concluded that responses in the format sought by the NRC Staff would be, in his opinion, ill advised and unnecessary (Enclosure B).
registering their objection to the questions 5p letter to the NRC Staff ~
b.
On May 9,1977, the Applicants submitted (Enclosure C). On May 27, 1977, the NRC Staff submitted a letter to the Applicants reiterating the Staff's request for answers to the questions (Enclosure D).
In November of 1977, the NRC Staff suspended its review of the CRBRP application.
c.
On February 13, 1981, the Applicants fomarded to the NRC Staff Amendment 60 to the PSAR phat provided the answers to the same NRC Staff questions (Enclosure E).6 The foregoing sequence of events shows that the Applicants concealed nothing.
On the contrary, all of the discourse between the Applicants and NRC Staff was conducted with candor. The Applicants simply disagreed with the NRC Staff, voiced that disagreement and ultimately acceded to the Staff's position.
Accordingly, the Comission should dismiss this charge as groundless and deny the petition.
Memorandum Riley/Buhl, May 27, 1977 NRDC attempts to extend its first groundless charge to embrace the second memorandum, by alleging that the seg" 'nd " proposes that the same policy of distortion and omission be applied. -
5/ Enclosure C was identified and made available for inspection and copying by Applicants' Updated Responses to NRDC's First Set of Interrogatories to Applicants Enclosure A, page 6, dated April 30, 1982.
- 6) The foregoing correspondence between the Applicants and the NRC Staff (Enclosures A, C, D, and E), indicates service upon NRDC at the time of submission.
7/ NRDC Petition at page 4.
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Again, NRDC's charges are made without regard for the context in which the memorandum was written. On its face, the memorandum does not reflect action which is inappropriate. The Director of the Engineering Division was expressing his view to the Director of Public Safety Division concerning the information in a draft of a report being prepared by Argonne National Laboratory as part of their Liquid Metal Fast Breeder Reactor Safety Base Program activities. The work had been performed and the report written at the request of the Director of the Public Safety Division.
The report addresses a specialized area of Hypothetical Core Disruptive Accident (HCDA) analysis for which the Public Safety Division has lead manage-i ment responsibility within the Project. This area of analysis has been considered by the Project to be beyond the design basis. The subject report i
provided supporting analyses for the Applicants report on HCDA energetic analysis; CRBRP-3, " Hypothetical Core Disruptive Accident Considerations in CRBRP; Vol.1, Energetics and Structural Margin Beyond the Design Base."
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Deriving requirements for the design from beyond design basis accident analysis and developing research specifications for this area were the responsibility of the. Director of the Public Safety Division. The input he received from the Engineering Division to help him perform and interface this task with the design was subject to the Public Safety Director's final decision. This is not surprising since the area of analysis is both complex and embodies uncertainties considerably larger than those associated with the elements of design that are within the design basis. These differences in understanding and objectives were resolved within the Project Office prior to comenting to the external organiza-tion, in this case Argonne National Laboratory. Within this context the letter does not represent the concern portrayed by the intervenors.
In particular, NRDC quotes the following passages from the memorandum:
General Comments "1.
The subject report is not acceptable because the information is presented in a very negative manner, particularly Chapter 2. The overall conclusion derived from Chapter 2 is that significant uncertainty exists in the Project's knowledge of all the major phenomenon which contribute to the initiation phase of a loss-of-flow (LOF) accident for an end-of-equilibrium cycle (E0C) core. The report should not only present to NRC our current understanding of the LOF/E0C accident and the basis for this knowledge, but also the results and descriptions of the SAS-3D analysis.
This report should be written in a straightforward, positive manner.
"2.
Any reference in this report to the need for additional work either experimental or analytical should be deleted. This type of information is not appropriate for transmittal to NRC."
5 Specific Comments
" Chapter 9 - This chapter which presents the conclusions should be completely rewritten. Not only does this chapter support Chapter 2, i.e., the Project does not understand the LOF/E0C event, but it also presents to NRC a list of additional experiments which should be performed, see comments G1 and G."
Recommendation "The critical chapters 1, 2, 7, 8 and 9 should be rewritten to a) present a positive, real assessment of the LOF HCDA, b) delete any reference to l
additional analytically [ sic] or experimental work and c) incorporate the preceding comments. Until this is accomplished, Engineering does not recommend transmittal of this report to NRC."
As reflected in the Commission's questions, the more significant inquiry concerns the ultimate disposition of the comments in regard to the final work product--the Argonne Report RAS 77-15.
Although the events in questio~n occurred more than five years ago, the Applicants have been able to reconstruct the following actions which took place relative to the memorandum:
The memorandum in question was used by the Public Safety Division in a.
developing the Project Office comments to Argonne.
b.
A meeting was held with Argonne, CRBRP Project Office personnel, and representatives from General Electric and Westinghouse who were also involved in the Project's HCDA analysis. The Project's comments were transmitted to Argonne at that time.
Neither the author of the memorandum nor any member of the Engineering Division was present. The meeting was conducted under the auspices of the Public Safety Division, the responsible Division within the CRBRP Project Office.
The Report was finalized in July of 1977 with essentially no substantive c.change. A comparison of the draft to the final issued report shows the level of response to the comments in the referenced memorandum (Enclosura F).
d.
The final report includes recommendations for future research. The recommendations in ANL/ RAS 77-15 relative to additional rest 3rch were con-sistent with and confirmatory to the research areas the project had initiated in 1976 and has continued to revise and upate as recently as January 1982.
Enclosure G contains development requirement specifications which describe these areas of ongoing research implemented by the project.
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e.
The. enclosed letter from the individual at Argonne (Enclosure H) under whose supervision and direction the report was prepared shess that:
(1) The report reflects, in all respects, the best technical product and judgment of Argonne.
(2) The report includes recommendations for future work deemed appropriate by Argonne.
(3) The report says precisely what Argonne wished to say.
The Applicants believe that th'e information prepared by Argonne is technically correct. The Applicants also believe that there is no evidence of concealment l
as alleged by NRDC. As with the first charge, the second merely reflects an initial difference in view which was resolved by the Applicants and their contractor without any compromise in technical substance. The Applicants believe that they are entitled to a presumption-of good faith, and absent any tangible evidence to the contrary, the charges must be dismissed.
QUESTION 3: Have any of the individuals referred to in the petition been involved in any respect in the preparation of the Applicants' exemption request and its supporting information? If so, provide the details of any such involvement.
l RESPONSE: Neither Dr. Buhl nor Dr. Rhyne nor Mr. Wright were involved in any way. Mr. Riley was not involved in any way in preparation of the Applicants' July 1,1982, request. Mr. Riley did, however, review a draft of the Site Preparation Activities Report (SPAR) submitted in support of the Applicants' November 30, 1981, request. Mr. Riley's review, which involved about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of effort, consisted of reading the draft and providing connents to the Public Safety Division of the CRBRP Project Office. The comments were l
primarily related to material quantities and costs.
The Petition Must Be Denied On factual grounds, the petition is entirely lacking in substance. This petition is the second recent attempt hy NRDC to embroil the Commissioners l
prematurely in a controversy which is best resolved by other elements of the Commission's organization. Applicants' recent response to NRDC's direct and improper petition for review of the Licensing Board's evidentiary ruling on contentions 1, 2, and 3 clearly demonstrates that, on policy and legal grounds, there is no basis for interlocutory review in that case. For similar reasons, which we will not reiterate here, this NRDC petition should be denied.
7 In closing, we should emphasize that, even though the charges are groundless and the petition should be promptly denied, the petition has exacted its toll.
The charges were first aired on the wire services without any prior notice to the Applicants. The charges were lodged directly with the Commissioners without any prior notice to or consultation with the NRC Staff. While the underlying CRBRP licensing proceedings are adversary in nature, we believe that the adversary process must include limits and bounds to control the unnecessary expediture of time and effort by the Applicants, and in this case, the Commission. The value of those policies which militate against direct Commission review of matters arising out of licensing proceedings is dramatically evident here. NRDC's hasty, ill-conceived and groundless charges have unnecessarily expended the resources of the Applicants and the Commission, and have left neither with sufficient recourse. We trust that, in the future, NRDC will be held to a standard of care and objectivity which is commensurate with the gravity and consequences of its charges.
Respectfully submitted, l
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Gordon L. Chipman, Jr., Acfing Deputy Assistant Secretary for Breeder Reactor Programs Office of Nuc'9ar Energy 8 Enclosures
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UNITED STATES NUCLEAR REGULATORY COMMISSION j.
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MAR 3 01977
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Docket No'. 50-537 U. S. Energy Research and Development Administration ATIll: Iochlin W. Caffey, Director Clinch River Breeder Reactor Plant Project sP. O. Box U Oak Ridge, Tennessee 37830 Gentlemen:
SUa7ECT: REGJEST FOR ADDITIONAL INFORMATIO(1 (Clinch River Breeder Reactor Plant)
As we indicated in our letter od Decerber 1,1976, we find that additional.
information 'is recuired in order that we may continue our review of the Clinch River Breeder Reactor Plant Preliminary Safety Analysis Report.
ne enclosure to this letter supplements the list of the recuired additional ihformation which was transmitted by our letter of August 17, 1976.
s.
Thc-ajority of items in the Enclosure arise from our evaluation of your Third Level 'Ihermal Margin (TLTM) Report dated April 22, 1976, and the TLTH Update Report., dated November 5,1976. In addition, some of the enclosed items deal with your responses to our previous requests for additional information. This request for information does not include all of the items which may arise from the staff's detz.iled review of the references requested in our letter of December 2,1976. Asi a result of our continuing review of your recent subnittals, including the TLTM I
Update Repbrt refer-ences provided in your letters of January 3 and 25, 1977, we expect to forward additional requests in the future.
The proposed approach for protection against core meltdown phenomena and consequences relies heavily on the inherent behavior and capabilities of the reactor containment system and associated structures, with a relatively modest degree of redesign to comply with the NRC requirements for containment integrity. 'Ite evaluations to determine the adequacy of the proposed approach involve' consideration of complex material inter-actions and accident scenarios. As indicated by the enclosed questions, 8
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l there are many uncertainties associatied with these evaluations; in l
particular, the staff finds that you have not provided an adequate basis to substantiate your claim that the core debris will fragment, e
l self-level, and attain a coolable configuration on the cavity floor.
l In addition, we are concerned that your report lacks sensitivity analyses in those areas where very limited information exists. These i
sensitivity studies are necessary to assess the magnitude of your design margins, and to determine where experimental validation is essential. Our review of the published Project and/or ERDA R&D efforts in the area of IXBR core meltdown indicates that the work has been largely preliminary in nature, small-scale, and confined to establishing phenomenological aspects in the areas of material interactions and heat transfer. This preliminary R&D does not satisfy our information l
needs for CRBRP licensing decisions. As indicated in our October 8,1976 letter, the staff would like to meet with the Project to discuss its R&D plans in detail. Without R&D program comitrents with a hign likelihood l
of success to substantiate your TLTM concept or the incorporation of additional measures to protect against containment failure in the event of a core meltdown, the staff may not be able to make a Construction Permit 1
finding of acceptability in this area.
Our letter of May 6,1976 specified that engineering conservatisms should be incorporated in the design and evaluation of the contain-ment system so that there is an extremely low likelihood that potential accidents could ' result in early containment system failure. According to information provided by the project, twenty-four (24) hours after a meltdown accident, the reactor containment pressure is calculated to be almost twice. the design value of 10 psig and rising at about 1 psig per hour, and the containment hydrogen concentration is over 2 percent and rising at about 1 percent per hour. The hydrogen concentration was held to a low level for the first twenty-three (23) hours of analysis by taking credit for hydrogen auto-ignition based on preliminary small-scale
" experiments, h1 hen viewed against the uncertainties associated with melt-thfough time, cavity liner behavior, materials interaction rates and extent, core debris behavior, the performance of incorporated features, combustible gas formation, and gas evolution rates we are not satisfied e
that your intended handling of this matter is consistent with our guidance.
In general, the basic Project approach of not dealing with a core post accident heat removal problem near the source 'in the reactor cavity, but allowing this problem to grow into problems of basic structural integrity, e
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U. S. Energy Research and Develo.=ent Ahinistration IdAR 3 01977 high containment system pressure and temperatbre, large scale genera-tion of hydrogen, and the consequential propagating uncertainties and required R&D efforts, does not appear sound. An evaluation of this type is, however, useful in providing some understanding of the potential consequences of meltdown scenarios where incorporated mitigating measures fail to perform as intended.
Our evaluations of core meltdown accidents in the CRBRP indic, ate substantial benefits in removing heat from the reactor cavity rather than allowing the sodium to boil away, and in protecting the cavity liner and structural concrete from attack by sodium and core debris through the use of refractory materials which are compatible with sodium and core debris. These evaluations have been discussed with the Project personnel and the ACRS, and NRC research reports which relate to this topic are routinely made available to the Project. In view of this, we are concerned about the Project approach, stated in the December 1,1976 letter from A. Buhl to R. Boyd, of undertaking no further activity on the materials compatibility between core debris and refractory materials. We believe that you should more fully consider the benefits of an approach which confines the major impact of the meltdown to the reactor cavity.
We note that the Project letter of November 5,1976, A. Buhl to R. Boyd, states disagreement with the staff's 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> containment integrity criterion, but that the Project co:miits to the incorporation of certain modifications to satisfy the criterion. The Project interprets this action to remove the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> non-venting criterion as an issue at this stage of licensing evaluation.
In order that there b'e no misunderstanding, please advise us that the Project accepts the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> non-venting criterion as a requirement, is proceeding with design on that basis, and that acceptance of the criterion is not conditional on NRC, acceptance of the approach or. features of the TLTM report or its update.
As we noted in our letter of August 17, 1976, we are proceeding with decisions and choices on the basis of the currently documented data from the Project in order to avoid delays; in some cases this course
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could lead to the selection of restrictive design requirements, unless the Project requests additional time for further submittals. We have not received any indication that the Project wishes to alter the CRBRP licensing review schedule for this purpose. Unless the Project responds to the enclosed items in a complete and timely manner coupled with commit-ments to the required R&D, or changes its design approach, the staff 1
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1 U. S. Energy Research and Develo, ment Administration 4-
!.lAR 3 01977 will be recuired to specify restrictive requirements for protection against core meltdown phenomena and consequences where information to support removing these conservatisms is neither available now raor expected to be available consistent with the CRBRP Construction Permit review schedule. We request that the Project indicate its plans in this regard.
Please advise us within two weeks of the receipt of this letter of the dates you will provide complete and adequate responses to all the enclosed items. In order to avoid the difficulties of piecemeal review,
' we request that your responses be as integrated and complete as pos'sible, at least on each major topic. We would be pleased to discuss our response to your basic approach as a separate matter.
Sincerely, I
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- s Thebs'.S, s, Ch f Liquid Metal Fast Breeder Faactors Branch Division of Project Management
Enclosure:
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Request for Additional Information i
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U. S. Energy Research MAR 3 0 N//
and Development Administration cc:
George L. Edgar Peter S. Van Nort Morgan, Lewis & Bockius General Manager, Project 1140 Connecticut Avenue, N.W.
Management Corporation Suite 1100 P. O. Box U Washington, D. C.
20036 Oak Ridge, Tennessee 37830 W. M. Jacobi, Plant Manager William F. Hubbard LMFER Demonstration Plant Assistant Attorney General Westinghouse Electric Corp.
State of Tennessee.
CRER Project Office Supreme Court Building, Room 421 s
P. O. Box U Nashville, Tennessee 37219 Oak Ridge, Tennessee 37830 S. Wallace Brewer Luther M. Reed County Judge and Attorney Attorney for the City Roane County Courthouse of Oak Ridge Kingston, Tennessee 37902 253 Main Street, East Oak Ridge, Tennessee 37830 R. M. Little ERDA/EPRI LMFBR Design Project Godwin Williams, Jr.
3172 Porter Drive
}bnager of Power Palo Alto, California 94304' Tennessee Valley Authority 819 Power Building Guy H. Cunningham, III g
Chattanooga, Tennessee 37401 Assistant General Counsel for Litigation s
E. C. Brolin ERDA.
Project Man'ager, CRBRP 20 Massachusetts Avenue Burns & Roe, Inc.
Washington, D. C.
20545 700 Kinderkamack Road Oradell, New Jersey 07649 William M. Barrick Suite' 250 Anthony Roisman Capitol Hill Building Roisman', Kessler & Cashdan Nashville, Tennessee 37219 1712 N Street, N.W.
Washington, D. C.
20036 Joe H. Walker 401 Roane Street T. Cochran Harriman, Tennessee 37748 Natural Resources Defense Council, Inc.
Herbert S. Sanger, Jr.
917 - 15th Street, N.W.
General Counsel 8th Floor Tennessee Valley Authority Washington, D. C.
20005 Knoxville, Tennessee 37902 r - :..._. _ _
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and Development Administration cc:
J. Griffith Mail Stop F-309 U. S. Energy Research and Development Administration Washington, D. C.
20545 H. Alter Mail Stop F-309 U. S. Energy Research and Development Administration Washington, D. C.
20545
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C. Newton Mail Stop F-309 U. S. Energy Research and Development Administration Washington, D. C.
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Anthony R. Buhl, Assistant Director for Public Safety HRC TLTM LETTER I believe that we should take a firm stand now to prevent or at least minimize turning TLTH eviluations into a class 8 event.
I recocrnand:
1.
That we re-emphasize that TLTH features are in the design base and give their description, design criteria, initiation secuences, etc.. in the PSAR, i.e., document real hardware in the PSAR.
2.
That we not answer a single. question expligitty!
Rather, we update the scenario in the TLTH report where we agree that there are inconsistencies, inadequacies, etc., i.e., document unreal scenarios in the report only.
However, we should not report sensitivity: studies or other information just because l-HRC asked for it.
Planned R&D should be adequately described 1.
in the report.
3.
We should object officially to the NRC class 8 approach and the biachnati implied.
4.
We should not unconditionally comit to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> criteria.
There is some legal precedent in that the DC Cocrt of Appeals refused to review a petition that the AEC consideration of cilss 9 accidents was inadequate at the Shoreham Plant.
l Whatever approach is decided, I believe that it should be decided quickly at the Riley/Buhl/ Caffey level.
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W. R. Rhyne, Chief PS:L:77:426 Licensing Branch cc:
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Dear Mr. Boyd:
.% m:c. c OBJECTIONS TO QUESTIONS RECEIVED DATED l' ARCH.30,1977-9 2-
'1...Lettsr. R. P. Denise.to L H. Caffey, dated May 6, #
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References:
1976.
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2.
Transcript of the September 29, 1976, ACRS Subcommittee Meeting on the CRBRP.
3.
Lette'r, T. P. Speis to L..H. Caffey,. dated.Harch 30. -.i --
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The CRBRP' Project believes that agreement. exists between the Project
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'and'NRC on the following fundamintal points related to treatment cf r.
pstulhtid' cor'e disrup'tive svents (References 1. and 2):
The probability of a core inelt and disruptive accident can and'-
1 must be reduced to a suf#iciently low level to justify theii '.
1.4 exclusion from the des,ign basis spectrum.
-2. Materials and structures may be allowed to exceed th assured.
The treatment is to be realistic and rational.
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The Project believes that many of the questions transmitted by Refer-ence 3 contradict our basic agreements on the treatment of postu-
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lated core disruptive eventi as events beyond the plant design basis
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Level Margin".s s 1.ntended to describe the features and margins in i
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.m
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....n s.?.T Taargins in the third level of safety. Although this nomenclatufe M M:.v ;.
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Wy. -
N.
%.W.f(C.I.9.~ land 'ma,rgins described in the report are fully in consonance w W#. ';
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! lh.F,' <! -" ' fundamental agreements outlined above. 1~. :.. V....
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- Project has committed to. comply with th' r$quirement' to ensure
.u..
s jg2. ..4,;, containment integrity for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> folloWing a postulated:CDAiwitho 3.ggi.Q QC Av'enting"and ~isEproi:eeding' to des,ign on'.tha't basis." WeKontiriue(to. ' ;.'.5,'iK
... find'that a systems solution to the, problem cf reducing the conse.-
"%. e.;9 3/;AC ;.,
@p.y:.,'."n, j).. quences of ' postulated core melt is supeiior T
4%. S
. f
,J;?.'.?.in.' regions.of..h.igh'.t. emperatures.a.nd relati.'vely uncertaih..bou..nding-G- : 4S...,h,t.:h
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~ correlations. 4,e believe this is consistent with the May:6,.1976, " W@: "d.
w...p.. r.. '.
,ilC.
..,g.e.,.:: N. :.;'s...
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- Many of!the technical concerns addreised Y i;he Referehee'-3. quest' ion's
- F, T S 24,1977.!i@n.
M$c.,*
',.were raised in previous conversations with your staff on~ February, A of that meeting, the Project is updating.the report on' thermal ;
5:1. L.. :.
~
Sj?4;
, margin for postulated core disruptive e' vents. Th,e Project apprecictes
~-
.the. technical concerns raised by NRC and. intends -to respond-to"these by i:e@.<e u
.d A-a... -.
e.
$$:':'.' ?.~,appropr.iately updating the : report rather' than' supplying a one'.to-one.c.d k:4 W 9 ?
D. ry.d.;..
question response. - He. believe that.in this c 9
./il.p;:.ll~.3:,'T;@.-l.~.js.,.jh,Q.p,,
.i by al :. parties..
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-Ve' bblieve that' this updated. report will be fully responsive.to NRC J @n.
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- R^
concerns as raised in our discussions on February'24 and in your -
f,.d ej S '
.. ' subsequent letter (Reference 3).
Upon receipt and revies of.our n / 4,.Q-Updated report, the Project wants to sit down with your staff.so,we O.
can agree that the report. addresses.your concerns.~ You may wish to consider withdrawi.ng Reference 3 a. fter reachi.ng.. agreement. that our. p..
,~
~
l W,Y
+
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7, j.:
updated report alleviates your concerns..
.,.;)g,,.
-@:M.G5~
7 Sincerely, s
' *yb
%m 6,..'r.TL*.?:.i:. i:W..V :
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ly$h:.:.::. l.y. 5,.j 0...
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.., n Anthony. R. Buhl.
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PS:L:77:528 b#
Assistant Director f r Public Safety m
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L 9
Enclosure D Np,'a UNITED STATES e
NUCLEAR RIGULATORY COMMISSION f"y O I o
WASHINGTON. D. C. 20$56 56 E
k3/
lAAY 271977
_y I
5 Docket No. 50-537 u
i j
s l
y c
U.S. Energy Research and
- f. _
. ~ '
Developnent Administration 9
ATIN: Mr. Lochlin W. Caffey, Director
~
' Clinch River Breeder Reactor
,0.2 ProjectOffice P. O. Box U j
i l'
Dak Ridge, Tennessee 37830
~"
Gentlemen:
l
SUBJECT:
LICENSING REWrW
'(Clinch River Breeder Reactor Plant)
,, e In a letter dated May 9,1977, Mr. A. R. Buhl objected to requests for additiondl information related to protection against core meltdown phenomena and consequences (TLTM report) transmitted by the NRC staff on March 30, 1977, p
f.~..' and suggested that the staff may wish to withdraw these requests following the review of information which the Project plans to sutrait. Based on the views expressed in the letter of May 9,1977, we believe there continues to exist soce confusion and misunderstanding by the Project of the staff's intentions and responsibilities in its technical review of the CRBRP Preliminary Safety Analysis Report (PSAR).
To carryout its statutory responsibilities, the NRC staff conducts a detailed technical review. In the course of this review, design methods and calculational procedures are examined to establi.sh their validity, and check calculations are made by the staff. The analyses and evaluations presented by the applicant must be reviewed and understood by the staff for us to make the requirep findings with respect to safety adequacy.
r l
. As indicated in the staff's letter of March 30, 1977 we are unable to d
I agree with yoer analyses, evaluations and conclusions for CRSRP on the 5
accudation of a core meltdown. The principal reason for this position h
is that there is an insufficient technical basis to substantiate many of d
your claims. The phenomena and scenarios associated with the accident
'T E
'are complex,.and uncertdinties in.these are.neither addressed by technical r 4
information nor enveloped by conservative assu :ptions. We continue to'5 k
d.
believe that satisfactory resolution of this problem can be" achieved
L through a combination of prudent design based on meaningful. data, con-1 l
servative engineering assumptions where uncertainties are large, and
.Y research and developnent. We encourage the Project to develop the technical I
basis to substantiate the adequacy of the CRBRP design. We do not agree
'(
that any of our questions are contrary to the guidance we have provided in the treatment of the events.
-.r-g
l\\
U. S. Energy Research and
,f Develognent Administration NAY 2 71977 e-We are particularly concerned wi,th Mr. Buhl's suggestion that we consider withdrawing the March 30, 1977 request for additional information, and
. the underlying basis for this suggestion. First, we believe that the conversations of February 24, 1977 have not been properly characterized. On that day, several representatives of the Project requested that the staff provide a sumary outline and preview of the then-forthcoming TLTM questions.
The staff summarized its concerns, which were later documented in the specific A
questions of March 30, 1977. The February 24, 1977 discussions were not I
intended by the staff as a subs ~titute for our documenting technical concerns.
We believed that the preview of the concerns regarding your TLTM approach, with subsequent documentation of the specific points, would focus the. Project's understanding of the issue, and permit more knowledgeable management of this issue. Secondly, we disagree with A. R. Buhl's proposal not to supply'a one-to-one question response. It would be unacceptable to us for the Project' to sirply subnit an updated report. If an updated report is to be used as the vehicle for providing answers to our requests for information, we expect the Project to point out precisely where each request (data, design information, analyses, etc.) is satisfied, or why the question is no longer relevant because cf a changed design. Otherwise, it will be unnecessarily burdensome for the l
..ctaff to review your intended response to requests for additional infomation.
We do not intend to withdraw the requests for information, but are hopeful that l
your Answers to our concerns will be. fully responsive, as you intend. After we have received the information, further technical discussions will probably be
)
appropriate.
e If you have any questions in this matter, please cMitact me.
Sincerely, I
\\
Richard P. Denise, Assistant Director for Special Projects j
Division of Project Management
[g i
ec;.See rage 3
- j a
a l
w 7
A 4
., _. ~
ENCLOSURE E
<. Ah 00004 Departmentof Energy Clinch River BreederReactor Plant Project Office P.O. Box U OakRidge, Tennessee 37830 Docket No. 50-537 February 13, 1981 Mr. Darrell G. Eisenhut, Director Division of Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Eisenhut:
AMENDMENT NO. 60 TO THE PRELIMINARY SAFETY ANALYSIS REPORT FOR CLINCH RIVER BREEDER REACTOR PLANT
References:
(1)
Letter, PS:79:041, R. L. Copeland to R. S. Boyd,
" Topical Report [CRBRP-3, Volume 1] on Structural Margin Beyond the Design Base (SMBDB)," dated February 9, 1979.
(2)
Letter, PS:80:092, R. L. Copeland to D. B. Vassallo,
" Topical Report [CRBRP-3, Volume 2] on Thermal Margin Beyond the Design Base (TMBDB)," dated March 25~, 1980.
(3) Letter, PS:78:317, R. L. Copeland to R. S. Boyd,
" Topical Reports ' Structural Response to CRBRP Scale Models to a Simulated Hypothetical Core Disruptive Accident' (WARD-D-0218) and ' Closure Head Capability for Structural Margin Beyond Design Base Loading' (WARD-D-0178)," dated December 13, 1978.
(4)
Letter, PS:79:047 R. L. Copeland to R. S. Boyd,
" Topical Report on HCDA's," dated February 16, 1979.
The application for a Co'nstruction Permit and Class 104(b) Operating License for the Clinch River Breeder Reactor Plant, docketsd April 10, 1975, in NRC Docket No. 50-537, is hereby amended by the submission of Amendment No. 60 to the Preliminary Safety Analysis Report pursuant to-50.34(a) of 10 CFR Part 50.
1 e
Mr. Darrell G'. Eisenhut February 13, 1981 The CRBRP Project has done extensive work in the area of Hypothetical Core Disruptive Accidents (HCDA) and has documented this effort in a single comprehensive report, CRBRP-3, Volumes 1 and 2, which was pro-vided to the NRC in References (1) and (2).
Additional documents that serve as significant references for this work were also provided to the.
NRC by References (3) and (4).
It is now appropriate to withdraw Appen-dix F. " Core Disruptive Accident Accomodation," from the PSAR, since all of the relevant material relating to HCDA's is provided in CRBRP-3 and its associated references.
Accordingly, this Amendment No. 60 withdraws Appendix F from the PSAR and includes:
responses to NRC's requests for additional information contained in a letter dated March 30, 1977, and revised responses to previously answered NRC questions concerning structural margins asso-ciated with an HCDA.
The CRBRP Project is confident that the above documentation is respon-i sive to NRC Requests for Additional Information regarding HCDA energetics, associated structural margins, and degraded core considerations, and that this information will lead to' resolution of outstanding questions l
regarding these subjects.
A Certificate of Service, confinning service of Amendment No. 60 to the PSAR upon designated local public officials and representatives of the EPA, will be filed with your office after service has been made. Three signed originals of this letter and 97 copies of this amendment, each with a copy of the submittal letter, are hereby submitted.
Sincerely, Op 4
mA R mond
. Co el ed PS:81:056 ting ssist Directo for Public Safety Enclosure cc: Service List SUBSCRIBED end SWORN to before me Standard Distribution this 4 Zfv day of February, 1981.
Licensing Distribution l
Notary Wblic l'
My Commission Exntres April 28. FJ' i
4
,a-n--
n
f..
I_
Enclosure F l
ACTION TAKEM BASED 05 MATURE CF CONMEarr COIMtsarf ID MAY 27, LETTER COMPARISON OF DRAFT AMD FINAL REBORT I
ceneral ca== ants 1.
The subject report is not acceptable 1.
The commenter apparently wanted to 1.
No apparent changes have uncertainties placed in proper from this comment.
because the information is presented perspective rather than just stating There have bec.n some In a very negative manner, particularly Chapter 2.
The overall conclusion de-that they exist. The last two senten-changes resulting from other reviewer rived f rom Chapter 2 is that signifi-ces give sound advice for preparing a a technical report. The cor.nenter comments but the dis-I cant uncertainty exists in the Project's cussion of uncertain-wanted the readers of the report to knowledge of all the major phenomenon understand clearly what the writers ties is still included and not given altered l
which contribute to the initiation position on the subject is, phase of a loss-of-flow (LOP) accident perspective.
f or an end-of-equilibrium cycle (EOC)
The report should not only core.
present to NRC our current understand-ing of the LOP /EOC accident and the basis for this knowledge, but also the results and descriptions of the SAS-3D analysis. This report should l
be written in a straightforward, positive manner.
2.
Any reference in this report to the 2.
The commenter appeared to desire to 2.
No changes.
have the report f ocus on the analysis.
The report still need for additional work either identifies R&D work, experimental or analytical should He apparently felt this was not the be deleted. This type of informa-appropriate document for conveying tion is bat appropriate for trans-
.R&D programs to NRC.
The project normally used Section 1.5 of the PSAR i
mittal to NRC.
and now CRBRP-3.
3.
All acronyms should be defined the 3.
Good comment for clarity.
3.
Last question was clarified.
first time they are used.
4.
The Project Office should only 4.
Procedural comment.
4.
Not applicable.
receive those documents for review which contain the appropriate tables and figures, and numbered pages.
O Soecific commenta 1.
Chapter 1 - The beginning of this 1.
Comment would help clarify purpose of 1.
No changes, chapter should include a dis-report and place it in perspective relative to other analyses already cussion of the basis for analyz-ing only the LOP /EOC accident performed and submitted to NRC.
versus the other accidents des-cribed in Reference (4), e.
g.,
transient-over-power (TOP) acci-dents and the LOP beginning-of-cycle (BOC) accident.
O e
ACTION TAKEE BASED ON Coestaar ID NAY 27, LETTER NATU22 OF CORRENT CORPARISON OF DRAFT AND FINAL R3 PORT l
I l
2.
Chapter 2.1 - Delete the second 2.
Commenter apparently had difficulty 2.
The second paragraph paragraph, it det:. acts f rom the understanding the information in was replaced with two the second paragraph.
paragraphs which dis-chapter.
cussed recent experi-ments. It is not likely that the change was in response to this comment because it in-troduces specific de-tail on the same subject.
3.
Figure 2.2 - The last question 3.
Intended to clarify and improve 3.
No changee.
l on the logic flow is vague. This comr.unication.
should be replaced with specifics or deleted.
]
4.
Chapter 2.1 - On the second page, 4.
Requested additional supporting 4.
No changes.
1 the report states, "The question material intended to clarify and Quote still included.
of initial fuel dispersal still has improve communication.
i significant uncertainties associat-l ed with it and must be left as a major branch point in the analysis".
A brief description of the experi-mental results which show fuel dispersion should De provided at this point.
5.
Chapter 2.1 - On the fifth page, 5.
Commenter apparently did not under-5.
No changes based i
the concept of " sodium removal stand terminology and requested on this comment.
rate" frem positive-void-worth clarification.
region is presented. This con-cept is not discussed in this report, therefore, this reference to the rate should be deleted or the appropriate discussion included.
6.
Chapter 2.3 - On the second 6.
Discussion of experiment results 6.
Changes were made page, Henry's experiment using requested apparently to clarify to define Henry's argon has been used as justifi-and improve communication.
experiment.
cation for the Fauske slosh scenario. A brief description of the results of Henry's experi-ment should be provided.
7.
Chapter 2.4.1.4 - The conclusions 7.
Commenter appears to be concerned 7.
No changes.
drawn from the TREAT tests de-with the fact that the discussion scribed in this section were does not help understanding the based on engineering speculation, uncertainity in the role of fission e.g. the phenomenon of fuel gas.
He believes that test results are dispersal by fission gas is either positive or negative. That highly uncertain. This report is not the case and it is important a.hould not speculate on the that expert judgements be made con-results - either the test infor-cerning implications of results.
mation is useful or it is unac-ceptable.
i N; TION TAKEE BASED 05 CosetEIrr ID RAY 27, LETTER NATURE OF C0fEEENT C00tPARISO5 OF DRAFT AND FINAL REPORT 8.
Chapter 2.4.1 - In the second 8.
Commenter apparently did not understand 8.
No changes.
the relevance of the later discus-paragraph of the first page, a sion to the "four relevant technical set of four " relevant technical issues" are defined. These issues." These items were not and issues were not addressed, in are still not specifically identified the report and, therefore, should in following discussion.
be deleted from the report.
9.
Figure 2.10 - There is no 9.
It appears that the commenter wanted 9.
No changes, obvious trend on this figure, discussion covering the relevance of the figure when the figure was pro-the only obvious fact is the vided as a somewhat general informa-material becomes brittle at high temperatures. The text tion base.
should be more specific.
10.
Comment apparertly was intended to 10.
No changes.
10.
Table 7.4 - the energy egpan-clarify by indicating that volume sion volume of 2.1 X 10 cc should be related to a CRBRP correspnnded to reactor cover gas volume.
design feature.
11.
Chapter 8 - This chapter does 11.
The comment appears to be based on 11.
No changes.
not contribute anything to the desire to relate. uncertainty the report, therefore, it to other specific parts of the docu-should be combined with Chap '
ment and relating it to Project needs.
ter 2, as appropriate, or May have thought ir. formation base was deleted.
adequate.
12.
Chapter 8.1 item (a) - The 12.
Commenter's judgement apparently was 12.
No changes last two sentences of this that enough information existed in based on this item which refer to the need this area, comment.
for additional experimental work would be deleted, see General Comment 94.
- 13. Chapter 8.2 item (c) - Delete, 13.
Commenter apparently wants to extrapo-13.
No change.
or reword on a positive note.
late the analysis further than may It appears certain that this have been appropriate. The comment effect must tend to mitigate may have some validity for reasons different than comment indicates.
consequences rather than exa-cerbate them. The 33 channel vs 10 channel results prove this case.
14.
Chapter 8.2 item (e) - Delete 14.
Commenter apparently judged there was 14.
No change.
no need to do further work to " remove the last sentence.
low level uncertainties".
15.
Chapter 8.2 item (f) - Delete 15.
Commenter apparently wanted to restrict 15.
No changes.
this section. The report is the scope of the report to the based on the reference core analysis performed on the homogeneous design and should not speculate
- core, on any other designs i.e.,
AFMS.
ColeIIIrF 13 NAY 27, LETTER RATURE OF COIEEENT ACTION TAEEE BAEED DE C005PARISOE OF. DRAFT AWD FIBAL REBORT
- i i
16.
Chapter 9 - This chapter which 16.
Commenter apparently thought the 16.
Revisions were presents the conclusions should conclusion section was not well made to combine be completely rewritten. Not written. The commenter's reference the last two para-only does this chapter support to a list of experiments is not graphs in the draft Chapter 2, i.e.,
the Project does clear since the draft has no such into one paragraph not understand the LOF/EOC event, list.
but no substantive but it also presents to NRC a changes in content were made based on i
list of additional experiments this comment.
which should be performed, see comments G1 and G2.
i i
e l
e 8
4 4
f.'
1.
DEVELOPMENT REOUIREMENT SPECIFICATION 02.23.04 HYPOTHETICAL CORE DISRUPTIVE ACCIDENT (HCDA) TRANSITION PHASE OBJECTIVE Provide support for the project position that damaging energetic recriticalities are not physically realizable following an HCDA, either while the core is melting down or if it achieves a grossly molten state.
Since this position is based on the application of general behavior principles, it will be necessary to verify the applicability of these principles with experiments, and to develop a modeling capability in which the principles are applied to analyze transition-phase events.
ORIGINAL ISSUE LATEST ISSUE DATE
- - - STATUS DATE 6/16/76 3/13/81 Completed in 8/79 2.
DEVELOPMENT REOUIREMENT SPECIFICATION 02.23.05 INVESTIGATION OF FISSION GAS & MOLTEN FUEL BEHAVIOR OBJECTIVE Provide out-of-pile experimental data necessary to support the energetics mitigating behavior of retained fuel fission gas during HCDA's.
Determine the role of fission gas and molten fuel relocation upon cladding loading and their impact upon cladding failure under loss-of-flow driven transient overpower conditions.
ORIGINAL-ISSUE LATEST ISSUE-DATE
- -- STATUS DATE 6/16/76 3/13/81 Final Report due in November 1982 G
0
3.
DEVELOPMENT REOUIREMENT SPECIFICATION 02.23.06 INVESTIGATION OF FISSION GAS & MOLTEN FUEL BEHAVIOR OBJECTIVE Objectives are to provide out-of-pile experimental data necessary to support the development of mechanistic models of retained fuel fission gases during hypothetical core disruptive events.
Determine the role of fission gas upon fuel swelling or mechanical breakup response to thermal transients.
ORIGINAL ISSUE ORIGINAL ISSUE-DATE
- - - STATUS DATE 9/20/76 3/13/81 Final Report-due 7/82 4.
DEVELOPMENT REOUIREMENT SPECIFICATION 02.23.07 CLADDING FAILURE CHARACTERIZATION DURING A LOSS-OF-FLOW OBJECTIVE s
Experimentally support the determination of the mode &
location of cladding failure, and the extent of cladding failure and continued extension, if any, under loss-of-flow / transient overpower conditions.
ORIGINAL-ISSUE LATEST ISSUE DATE
- STATUS DATE 9/7/76 3/13/81 Final Report due 3/84 5.
DEVELOPMENT REOUIREMENT SPECIFICATION 02.23.08 ANALYTICAL DEVELOPMENT FOR IMPROVING MODELING OF HCDA BEHAVIOR OBJECTIVE Provide improved analytical code capability for modeling hypothetical core disrupt!.ve accidents, i.e., models which represent (1) experimentally demonstrated fission gas behavior with SAS, (2) gross cladding motion including 2-D inception criteria, fuel & plenum fission gas effects, and cladding partial feedback on fuel motion for the analysis of the behavior of a growing molten fuel region.
ORIGINAL ISSUE LATEST ISSUE-DATE
- STATUS DATE 9/20/76 3/13/81 Final Report due 9/82 D
6.
DEVELOPMENT REOUIREMENT SPECIFICATION 02.23.09 IMPROVED PHENOMENOLOGICAL MODELS OF TRANSIENT FUEL PIN BEHAVIOR OBJECTIVE Develop mathematical models and computational methods to analyze transient behavior of oxide fuel during transient overpower and loss-of-flow HCDA's.
Integrate these models and methods into a SAS 4A computer code system.
ORIGINAL ISSUE LATEST ISSUE DATE STATUS DATE 9/20/76 3/13/81 Final Report due 10/82 7.
DEVELOPMENT REOUIREMENT SPECIFICATION 02.23.11 EXPERIMENTAL INVESTIGATION OF EARLY FUEL ESCAPE DURING MELTOUT PHASE OBJECTIVE demonstrate that during an HCDA a large amount of molten fuel can be dispersed beyond the core into the gaps between ass'embly hexcans and/or through the control assemblies into the lower plenum.
ORIGINAL ISSUE LATEST ISSUE-DATE' STATUS DATE 5/27/81 1/28/82 Task 1 tests due to be completed 10/82
t!Hclosure W ARGONNE NATIONAL LABORATORY 9700 Souik CAss AstNuc, ARCpM,lliNois 60439 hph0NE B2/972-8338 July 20, 1982 Mr. Raymond L. Copeland Assistant Director for Public Safety CRBRP Project US Department of Energy _.
Oak Ridge Operations P.O. Box U Oak Ridge, TN 37830
Dear Mr. Copeland:
Subject:
Recent NRCD Filing against CRBRP Project 1Ath Regard to ANL/ RAS 77-15
Reference:
Memo, D. R. Riley, CRBRP-P0 to A..R. Buhl,-CRBRP-P0,
" Review of ANL/ RAS 77-15, SAS3D Report," May 27, 1977 i
As Section Manager of the Accident Analysis Section of the Reactor Analysis and Safety Division of Argonne National Laboratory. in 1977, I was responsible for the technical management of the efforts which resulted in the publication of the subject document. All of the work described in the report and the preparation of the report itself were perfcrmed under my personal supervision.
I recall that a draft was provided to the CRBRP Project in April 1977 and that certain coments were subsequently generated l
within the Project on the draft.
I do not specifically recall receiving a copy of the. referenced memorandum; however, I do' recall infomally receiving comments from CRBRP Project staff.
I did not find these comments to be unreasonable.
However, they did not alter my technical judgement with regard to the content and intent of the report.
This is to note that it is reasonable that the sponsoring organization provide coments, but this does not alter the fact that ANL has ultimate responsibility for the material published in ANL reports.
1 In June 1977 a meeting among the interested participants was held in which the various coments were discussed.
Publication of the report followed in July 1977, with no significant changes having been made in its context compared to the earlier draft.
With regard to the conduct of the work described in ANL/ RAS 77-15 and the subsequent preparation of the draft and final copies of the report, I offer the following points in summary:
l US DEpics1d W' Tkt NTRsITyODiCAgo ARQONNE U\\i\\ERsifics AssociA1ios
~
July 20, 1982 2
Mr. Raymond L. Copeland (1)
I believe that the subject report objectively presents the relevant material, including the discussion of uncertainties, and represents an honest and forthright presentation of the technical issues under consideration.
(2) The report objectively discusses areas for which Argonne felt in 1977 that further analytical or experimental work needed to be perfomed.
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(3)
I do not recall any substantive changes being made between the draft and the final form of the report.
(4)
I believe that this report reflected ANL's best technical judgement in the areas of LMFBR safety technology discussed in the report.
(5)
I further believe that the report clearly states what the authors intended it to state.
(6)
I reiterate that the comments in the referenced memorandum in question are not improper, but they did not in any way influence the technical judgement of the authors in what was ultimately presented in ANL/ RAS 77-15.
. Sincerely,
&S4 Donald R. Ferguson, Director Fast Reactor Safety Technology Management Center DRF:bak:534
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cc:
G. Edgar, Morgan Lewis Bokius e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3EFORE THE COMMISSIONERS L.
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In the Matter of
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UNITED STATES DEPARTMENT OF ENERGY
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FROJECT MANAGEMENT CORPORATION
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Docket No. 50-537
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(Section 50.12 Request)
TENNESSEE VALLEY AUTHORITY
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(Clinch River Breeder Reactor Plant)
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