ML19308E150
| ML19308E150 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/15/1972 |
| From: | Bloch E US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Muntzing L US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML19308E149 | List: |
| References | |
| NUDOCS 8003240653 | |
| Download: ML19308E150 (9) | |
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ATTACHMENT 2 I
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February 15, 1972
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Attached is a summary of the Crystal River problem and supporting detail.
There are several factors contributing to the extensive list of questions and the dilemma which the applicant apparently faces:
1.
Issuance of the construction permit with many open issues which were to be resolved during the construction period.
(Unfortunately we face this same problem to varying degrees with other cps that have been issued during the past several years atid it will take some time to work out from under it.)
2.
A determination by Florida Power Corporation that the FSAR-would connletelv replace the PSAR and constitute the complete record for the plant.-
I An unusually early submission of the FSAR, some 33 months 3.
before the plant i:. scheduled for fuel loading.
I suspect that many. design d: tails were still unavailable at that time with the result that the FSAR was inadequate.
The only course of action I can suggest at this point is:
1 Where the applicant feels that.the question has been answered in the PSAR, asic hin to identify the specific section.
If we agree that the PSAR cdequately answers the question, it can be incorporated into the FSAR by reference.
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Where the applicant feels that the question has been answered -
in a licensing review of a similar Bud reactor, ask him to identify the reacter and it can be incorporated into the FSAR by reference.
This is a rather common practice.
3'.
With respmt to the remaining questions, meet with the applica-in an effort to reach a clear understanding of what is needed and uhy.
Where appropriate, we could suggest to the applicant hcw best to handle his response.
If you agree with the cbove approach, we will contact the applicant and proceed accordingly.
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IIIGHLIGHTS OF REVIEW CRYSTAL RIVER UNIT 3 The Construction Permit for Crystal River Unit 3 was issued Seotember 25, 1968. The ou)lic hearing was uncontested.
The FSAR was received on January 25, 1971.
Shortly afterwards Florida Power Cororoation was informally notified that our review would not commence before mid-year.
The formal review started August 1,1971. The review schedule including start date was based upon ACRS review desire of 9-12 conths prior to fuel loadinc. The importance of this lead time was deconstrated for Three Mile Island when ACRS refused to review the application because of too much lead tire before fuel loadine.
This reviev, includine a two month de'lav for their response to these cuestiens, is still scheduled to be completed consistant uith proicceed fuel 13ading date of September 1073..
The followine is quoted verbatin from tae Florida Power Corporation actter transmittine the FSAR:
" Amendment No.11 is the Final Safety Analysis Report and is intended to replace in its entirety the Preliminary Safety Analysis Report includine Arc d=c its No. I throuch 10."
At the cine tF2 review plan was beine orepared the subject of aoplicable caterial was discussed.
Based on the above statement it was decided,that our review would be based upon the FSAR and subsecuent amendments.
The above stat teent was broucht to Mr. Joel Rodgers' attention at an informal meetina on Nov:=bec 30. (Roy Snapp accorpenying).
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.2-The FSAR is deficient in the extent of its coverage of many topics.
In todav's atmosphere of anolication quality, this FSAR is marginally acceptable to unacccotable. The anplicant is responsible for being aware of current safety concerns of the staff following issuance of a censtruction acrmit.
If Florida Power Corporation had done so, and had followed the review of recent operatina license applications, they would not have been surprised by the extent and coverage of our question list especially in light of the quality of their FSAR.
It is noted that this question list covers only part of our review of the FSAR. Ouestions on material from five more chapters and the Technical Specifications are still to be forwarded.
Two meetines hava been held with the acclicant since conmencing active review of the application. Meetines were held on Sep,tember 21 and Deconher 17, 1971.
At th2se meetines items of known concern were identified to the applicant.
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Specific Topics Wa.ter Level Durina Hurricane - Staff hydrologists have consistenti/
maintained that the cnalysis reported in the FSAR is inadecuate. We believe that the maximnm level of water should be about 10 feet higher than reported in the FSAR.
Such a difference may_, require some facility modifications.
This concern was discussed in detail with the applicant at the Scotember meeting and iden'tified as the mort important safety problen for their plant. This was reiterated and emohasi:cd wi$th the applicant at the December meeting.
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Grouting - Folicwing CP issuance the groutine program for Crystal River Unit 3 was modified by Amendment No. 7 to the PSAR. Aoparently there was no staff or consultant review of this nodification at that time. Our preliminary assessment indicates that the groutine is adequate, but because of the significance of this item at CP stage we believe the record should be set straicht and completed. Asking for information relating to the grouting procedures at this time is a legitimate request since the FSAF 'is incomplete in this respect.
Repeatinc. 0uestions - As stated earlier our review is based on the FSAR and subsequent amendment:s.
Although the subject raterial ray be the same nnv as questions asked duri:n C? review, the thrust or intent of the questions should be different, i.e. desirn details in. stead of desinn bases.
Additionally, the staf f Safety Evaluation identified a n :nher of areas which would recuire post CP review.
For Crystal River Unit 3 these include 31D nrooress, hurricane I
protection, seismic and blowdown forces on reactor internals, control rod drive rechanisms, separation of control and safety instrumentation, reactor
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building fan coolers, failed fuel element detection, pressure vessel thernal shock, quality, assurance procram, dynamic nnalysis of structures, eculoment, and oiping, sampling of Cadweld Solices and channes to containment design.
Questions on these subjects have been included in our information request.
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More Experienced Ooerating Staff - Recently, the DRL Operational Safety Branch indicated that some additional staffing with reactor oparator experience would Be required of the apolicant for about the first six menths of operation. This staf fing was deemed necessary af ter reviewing ffhe qualifications of the applicant's operating staff as presented in the FSAR.
Although this staff is well educated and trained and deen in exoerience in fossil plant operation, they are deficient in nuclear plant experience.
In a telephone call on February 3,1972 the applicant was informed of this. We further succested that a convenient canner of doing this would be through Babcock and Wilcox, their NSSS vender.
Florida Perer Corporation misunderstood this conversation as they aoparently interpreted our remarks I
to require these personnel to be part of their staff. This infornation was transmitted ints mally to give the applicant as much lead time as oossible since the next written eormunication with Florida Power Corporation is scheduled for early March.
Post CP Safety Conc 2rns - Between issuance of CP and review of the OL application, new safety concerns arise and guidance is croruirated throuch Regulations, p,roposed Reculations, design criteria, sefety guides, information guides, ACRS letters and DRL position papers.
A continuing problem is how to apply these new positions to facilities under construction.
It is our position that questions from the staff and answers from the applicant provide a dialogue which forms the basis for mckinc backfit determinations.
In addition this dialogue provides a means to suggest additional equionent, minor desien changes, or' changes in pronosed opera:ing procedures-within reason with' the apolicant.
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5-General Reasons for Ouestions Questions to determine desin,n details af connonents and systems to meet criteria and' design bases are appropriate at OL review.
Questions associated with new safety concerns - see above.
Some cuestions aimed at oroviding more detailed information of safety related concerns to provide a more coepicte bas Ls for making determination.
Questions and answers orovide documentition on the public record of current staff and general safety concerns of th'.s soecific apoliention!
We try to anticipa'te some potential pitfalls which have arisen in the past at public hearines.
Generally, the, Crystal River 3 cuestic is can be senregated into three categories:
1.
Thirty-three questions that identify t'chnical issues.
Soce of these are oroblets that wereldentified as requiring resolution sub-sequent to issuance of the constructio1 ne rait: others are technical issues relating to new knowledcc or sa ?cty criteria that haVebecome available subsecuent to the filing of.he FSAR.
2.
Seventy-six (76) questions relatine, pr'.narily to documenting information on how desir.ns are being implemented. These are necessary in order
'to have a complete record of this lice ise annlication. Until this documentation is received, we are unabi.e to determine whether the designs develooed are adequate.
3.
Ten questions of a general nature recu : sting clarification of information submitted.
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Florida Power Corporation is actively involved in state licensing of the large Anclote fossil plant.
Within the past feu veeks they have been testifying at public hearings on environmental concerns for the plant. During the past few months they have had to submit reasons why construction should not be suspended on Crystal River Unit 3 for AEC.
Tney were also involved in precaring a three volume Environmental Report for this plant which var submitted to the AEC on January 4,1972. They are presently inv'olved in the PSAR oreparation for Crvstal River Unit 4.
This is scheduled for stb:.ission on May 1,1972.
All of this work is in addition to their effort connected with the Operatinn License revicu of Unit 3.
It is my aninion that Florida Pouer Corporation's licensing staff is extended c(or bevond their present resources and that the Crystal River Unit 3 Ecquest for Additional Information involved demands which may interfere with their other licensine efforts. Their a
complaint is probably a reaction from frustration as much as lecitimate, I
well-founded complaint.
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