ML20236Y192
| ML20236Y192 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/28/1998 |
| From: | Howard D AFFILIATION NOT ASSIGNED |
| To: | Collins T NRC |
| References | |
| NUDOCS 9808110241 | |
| Download: ML20236Y192 (2) | |
Text
582 South Almaden Avenue San Jose, CA 95110
'(408) 286-9405 DoubleDuck@CompuServe.com July 28,1998 L
Timothy E. Collins, Chief Reactor Systems Branch, USNRC g
Mail Stop 8E23
,M Washington, DC 20555 g&
- Re: ITS 3.1.2 Reactivity Anomaly MM
Dear Mr. Collins:
2/4/97 Thank you for you letter of July 22,1998, though I find it somewhat at dis with the information I sent in my previous et mmunication about the mythical Reactivity Anomaly.
The attachment was interesting for several reasons. First, engineeringjudgment was really not involved at all. If it had been, there would be NO Reactivity Anomaly spec to discuss. We would have removed it in 1%3 as our two years of engineering data demanded.
But, if we had, we would NOT nave received our license amendment. So we wrote it for
- strictly Political Reasons, not ' engineering. That has always reminded me of putting a traffic light in the middle of a corn field. You know it's a safety device, and you would hesitate to remove it, but you would te hard pressed to justify it bemg there.
Now, if you had t'., justify that traffic light, your justification would sound like the Bases in the attachment to your letter. I read that information with a sense of deja vu. It is the same argument used to justify the anomaly spec when we were designing reactor cores with not much more than a slide rule. But, in this iteration, there is a valiant attempt to try to give it legitimacy by cross-tying it to Shutdown Margin. There is no connection. Shutdown margin IS a real world w.cessity even if boric acid is needed to get there. I remember Admiral Ricko-ver testifying at the Yankee-Rowe hearings that any plant that had to inject boric acid to shut-down was unnfe.
-I had heard that the entire ITS project was contracted and not written by the staff.
What is obvious is that the author was either an ex-navy nuke or has only PWR experience.
I'd bet on ex-navy nuke as only the navy trains their people to use the pleonasms negative reactivity and positive reactivity. If you go through the bases and remove the words positive and negative it reads exactly the same. And there are other clues. (e.g., the BWR has no Core Monitoring System.)
The wording of the spec hasn't changed in the last 35 years except for the addition of Mode 2. This was never intended, and the BWR's have never attempted to show compliance in Mode 2, and have NEVER been cited for that. They can't. They never bothered to obtain the data required.~ Their startup program consists of running major transients and comparing them witti predicted. If they are compatible, then all the coefficients must be correct, and that coefficient data is GE Proprietary.
Though the proposed ITS spec says APPLICABILITY: MODES 1 and 2, the Bases states, Therefore, the comparison is only done when in MODE 1. The Bases states it as origi-nally intended. The spec is wrong.
Can I assume that the term 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching equilibrium conditions is interpreted L
to mean after equilibrium Samarium is reached at about 210 hours0.00243 days <br />0.0583 hours <br />3.472222e-4 weeks <br />7.9905e-5 months <br /> at high power? I have one antique document showing that CE doesn't provide data before 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> with their reload fuel packages. Then all subsequent follow is normalized to that base point.
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Having held an AEC Operators / Senior Operators for a test reactor, a PWR, and a BWR, taught GE's Station Nuclear Engineering course for two years, was a senior licensed Shift Operations Advisor at the Fermi 11 startup for four years, and worked in ISEG at Grand Gulf for three years where I was primarily concerned with the activities of their reactor engi-neering group, I can assure you that there is no reason for Reactivity Anomaly other than to increase the cost of operation of our nuclear power plants which like Oyster Creek are finding future operations increasingly prohibitive.
I'd hete to see the NRC put itself out of business. Please let Reactivity Anomaly go the way of Fire Protection & Detection and environmental considerations - out of the Tech Specs.
Or, if you can't get rid of it entirely, try to eliminate Mode 2 from the BWR ITS.
Very truly yours, 6%#V' Don Howard ps: This is not a long winded application for a contract as a 'BWR ITS consultant. But, I do suggest that you fied/ develop someone who speaks the language. The BWR IS different from the PWR.
pps: I will say no more on this subject.'
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