ML20134M213
| ML20134M213 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 08/26/1985 |
| From: | Taylor J DAIRYLAND POWER COOPERATIVE |
| To: | Zwolinski J Office of Nuclear Reactor Regulation |
| References | |
| LAC-11094, NUDOCS 8509040020 | |
| Download: ML20134M213 (2) | |
Text
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D DA/RYLAND h
[k COOPERAT/VE P.O BOX 817 2615 EAST AV SOUTH LA CROSSE. WISCONSIN M601 (6 %)788400)
August 26, 1985 In reply, please refer to LAC-11094 DOCKET No. 50-409 Director of Nuclear Reactor Regulation Attn:
Mr. John Zwolinski, Chief Operating Reactor Branch #5 Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
DAIRYLAND POWER COOPERATIVE LA CROSSE BOILING WATER REACTOR (LACBWR)
PROVISIONAL OPERATING LICENSE DPR-45 CLARIFICATION OF ANTICIPATED TRANSIENT WITHOUT SCRAM (ATWS) RULE 10 CFR 50.62 REFERENCES (1) NRC Letter, Zwolinski to Linder, dated July 26, 1985.
(2) DPC Letter, Linder to Paulson, LAC-10173, dated September 13, 1984.
Dear Mr. Zwolinski:
DPC has reviewed your response, Reference 1, to a request for clarification to the ATWS Rule: 10 CFR 50.62.
There is agreement that paragraphs 50.62 (c)(1) and (2) are not applicable to LACBWR, that paragraph 50.62 (c)(5) is applicable and DPC has installed a Recirculation Pump Trip System and that LACBWR is a " boiling water reactor".
As a result of this review, it is necessary to restate our request for clarification to paragraphs 50.62 (c)(3) and (4).
It is obvious that many years of effort was expended and great care in developing the ATWS Rule 10 CFR 50.62.
The Basis for the Final Rule was published in Vol. 49, No. 124, Tuesday, June 26, 1981 of the Federal Register. On page 26038, the discussion of each of the paragraphs (c)(1) thru (c)(5) is given. Paragraph (c)(1) discusses PWRs.
Specifically, the three major PWR NSSS suppliers are mentioned by name.
Paragraph (c)(2) and (c)(3) specifically states General Electric, Combustion Engineering and Babcock and Wilcox plants.
Paragraph (c)(4) states General Electric plants and specifically mentions three designs; BWR/4, BWR/5, and BWR/6.
Paragraph (c)(5) only mentions BWRs.
Using the Basis for the Final Rule, it would appear the La Crosse Boiling Water Reactor, an Allis-Chalmers design, would r
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f Mr. John Zwolinski, Chief August 26, 1985 Operating Reactor Branch #5 LAC-Il 094 be required to meet only paragraph (c)(5).
However, when the rule was written in final form, (1) paragraph (c)(1) discussed all PWRs generically; (2) paragraph (c)(2) specifically mentioned Combustion Engineering and Babcock and Wilcox; paragraph (c)(3),(4) and (5) generically states each BWR.
Since paragraphs (c)(3) and (4) of the rule did not repeat the name of the major BWR designer, General Electric, which was the basis for this section of the rule, the Allis-Chalmers designed BWR, which is significantly different in design, is enveloped by omission.
DPC requests clarification to paragraphs (c)(3) and (4) of the ATWS Rule 10 CFR 50.62 for the following reasons:
(1) Paragraph (c)(3) and (4) were written with the intent of specific General Electric BWR designs.
(2) The rule failed to specifically state General Electric in paragraphs (c) (3) and (4).
(3) The design difference between the General Electric rod injection system and the Allis-Chalmers individual control rod drive hydraulic system is so extreme it is impossible to add this new "specified" equipment (ARI) paragraph (c)(3).
(4)
LACBWR was granted a construction permit prior to July 26, 1984 and the design did not incorporate the stated design requirements of (c)(4).
(5)
LACBWR is a unique BWR and cannot be generically compared to General Electric plants.
(G) 10 CFR Part 170 provides for a licensee to request clarification of a rule that is not applicable to a particular type facility.
DPC is confident that your staff will consider these reasons for clarification and determine paragraphs (c)(3) and (4) of the ATWS Rule 50.G2 do not apply to LACBWR.
If you have any questions regarding this matter, please contact us.
Sincerely, DAIRYLAND POhTR COOPERATIVE
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James W. Taylor General Manager JWT: RMB: sks cc: James G. Keppler, Region III NRC Resident Inspector Walter Paulson, LACBWR Project Manager PCI-9.a 2