ML20247R481

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Petition for Rulemaking PRM-50-53 Providing Comments on Ocre Petition Requesting NRC to Reopen ATWS Rulemaking Proceeding.No Basis Found for Ocre Petition Since Stability Considered During ATWS Rulemaking
ML20247R481
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 09/22/1989
From: Marriott P
GENERAL ELECTRIC CO.
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-54FR30905, RULE-PRM-50-53 MFN-069-91, MFN-69-91, PRM-50-53, NUDOCS 8909290263
Download: ML20247R481 (2)


Text

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Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch Subj ect: Comments on OCRE Petition Regarding ATWS Rulemaking (Federal Register Vol. 54, No. 141, July 25,1989)

Reference:

NEDO-24222, " Assessment of BWR Mitigation of ATWS, Volume II (NUREG 0460 Alternate No. 3)", February 1981 The purpose of this letter is to provide General Electric's comments on the Ohio Citizens for Responsible Energy (OCRE) Petitica requesting NRC to reopen the ATWS rulemaking proceeding.

It is General Electrf.c's view that there is no basis for the OCRE Petition.

The possibility of power / flow oscillations associated with a postulated ATUS event were fully recognized by NRC and the indt.stry prior to (and during) the ATUS rulemaking. Prior to the rulemaking, GE performed exten-sive analyses of BWR performance under ATUS conditions (Reference) and these analyses predicted the pon ntial for power / flow oscillations under certain ATWS conditions. The results of these analyses were clearly part of the NRC deliberations associated with the ATWS rulemaking and the March 9,1988 LaSalle Unic 2 event does not introduce any new information which bears on the ATWS rule.

Beyond this, it is important to maintain the proper perspective relative to this situation. First of all, ATUS is an exceedingly low probability event which encompasses a spectrum of postulated failures leading to the inabili-ty to insert some or all of the control rods. With the successful inser-tion of only a few control rods (or a small amount of liquid boron) stabil-ity should not be an issue because of the stabilizing effect of the power reduction. For the reasons stated above, the probability of unacceptable power-flow esci11ations associated with an ATWS event is extremely low.

In summary, it is GE's opinion that the OCRE petition is without merit since stability was considered during the ATWS rulemaking and the LaSalle .

event adds no new information. Furthermore, BWR system designs and inher-ent features are effective in preventing significant oscillations. Based on GE's assessment it is concluded that with existing plant features and l 8909290263 890922 PDR 50-53 PRM PDR kh l

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' t' . . Secretary of the Commission--

September 22,'1989 Page 2 specified operator actions there is a high probability that oscillations, in combination with ATWS, can be avoided entirely or short lived and of relatively low amplitude should they occur. Because of this, ' we do not believe the potential for power oscillations justifies reconsidering the '

ATWS closure.

-I Regards, P. V. Marriott,. Manager.

Licensing and Consulting Services (408) 925-6948 M/C 682-0829891/HCP5 cc: L. Phillips (NRC).

W. Hodges (NRC)

A. Ihadani (NRC)

L. Gifford (GE-Rockville) l l

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