ML19308E194
| ML19308E194 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Crystal River, 05000376  |
| Issue date: | 12/15/1972 |
| From: | Deyoung R US ATOMIC ENERGY COMMISSION (AEC) |
| To: | Boyd R US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8003240733 | |
| Download: ML19308E194 (4) | |
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Otc 151M R. S. Boyd, Assistant Director for Boiling Water Reactors, L REACTOR PL/JTI INFORMATION REGARDING COMMISSIONER RAMEY'S MEMO TO L. M. MIT.lTZING Attached is the pertinent information which you requested with
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. respect to Aguirre, Crystal River Unit _3 and Indian Point Unit 2 1
in regard to Commissioner Ramey's memo to L. H. Huntzing regarding
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burden of proof.
Original signed by R. C. DeYoung R. C. DcYoung, Assistant Director for Pressuri:cd 17ater Reactors Directorate of Licensing cet
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. -.. s Aguirre Commissioner Ramey's state =ent that " Regulatory consultants '(U.S.
Geological Survey) interpreted the criteria (seismic) to require the' applicant to prove 'beyond a reasonable doubt' geologic inactivity at the Aguirre site in Puerto Rico" is an accurate quote of a statement l
made, by USGS in their report to the Regulatory staff (submitted by I
letter from H. Coulter to W. Gen =ill, dated July 18, 1972),
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this was not the main thrust of the USGS report. The-principal point-made was that the data and information presented by the applicant could be interpreted to indicate recency of movement of a fault near the site. 'The Regulatory staff did not use the 'beyond a reasonable doubt' wording in its subsequent report to the ACRS.
Commission Ra=ey's statement concerning the commitment in Mr. Muntzing's letter of Septe=ber 11, 1972, that tl.e staff would clarify the intent of the proposed seismic criteria as requiring the applicant to make a i
" reasonable investigation" is an accurate quote.
I discussed the status of the clarification work with W. Morrisca of Regulatory Standards l
who informed =e that RS had planned to do this in November, but that more pressing work had prevented doing so.
RS still intends to j
change thisecriteria to make the clarification.
i See attached letters for background.
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Crystal River Unit 3 In the Crystal River Unit 3 steam system design there are no isolation valves in the main stean piping.between the steam generator
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and the turbine stop' valves.
The turbine stop valves also act as main steam stop and containment isolation valves. Most other pressurized-water reactor plants have isolation valves outside and close to the reactor containment building.
A few plants such as the Oconee Units and Rancho Seco have the same valve arrangecent as Crystal River Unit 3, but their sten = lines-from the reactor building ~to the reactor stop valve are designed to Category I (seismic) requirements.
Such is not the case for Crystal River.
In cocparison to all other recent generation plants, the Crystal River system is unique.
The safety concern is that ground accelerations of the Category I (seismic) magnitude could possibly result in the failure of all four cain steam lines without = cans of isolation resulting in blowdown of the entire secondary steam systen with the consequent release cf secondary radioactivity.
0f even greater concern is that a rapid cooldown of the primary syste= would occur possibly leading to a return to power of the reactor core with the further possibility of substantial fuel damage and direct release of primary radioactivity to the atmosphere.
This concern was further amplified because of recent piping failures in secas systems at Turkey Point and Surry.
The stean systen as described above for. Crystal River Unit 3 was reviewed and accepted during the CP review in 19c8.
Consequently, any design changes required in this system would be backfit itens subject to the requitements of 10 C72 50.109.
Up to now, we have not attempted to process a fornal backfit recor:endation through the Commission.
There is some doubt that the staff can demonstrate that backfitting will provide a substantial, additional protection which is required for the public health and safety.
On September 21, 1972, we forwarded a lettet to the applicant with respect to our position on this catter.
I,'e stated that the applicant "may proceed with the design and procure ent of suitable steanline 1solatien valves for subsequent installation in appropriately designed Class 1 portions of the steam lines during the first refueling outage of Unit 3... Alternatively, you cay atte=pt to deconstrate that such backfit modifications to the steam system are not necessary".
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J Indian Point Unit 2 With respect to Indian Point 2, the Final Environmental statement discusses at length the Staff analysis and conclusions that
- long-tem operations as proposed by the Applicant has a high potential for serious irreversible damage _ to _the aquatic biota of the Hudson River and other areas which depend upon it for recruitment of their biota.
This position is not in accord with e
that of the Applicant, and the Staff has accepted the burden of defending its positica. A hearing is new in progress before an Atomic Safety and Licensing Borad on'these issues, with the Staff giving direct testimony on its analyses and evaluations.
The major staff recomendation on the licensing of this p'lant is that operation with once-through cooling can be authorized for a limited period (5 years) because there is an acute need for the plant's power and the environmenta) damage frca such operation for this limited time is believed to be suseptible to recovery, but :nat long-term operation would be acceptable only with a closed-cycle cocling system.
The Staff discussion notes that these assessments can not be made with complete assurance as to the environmental impacts, 1but that the risks are real and have a high probability.
It is not the Staff position that there be closed-cycle cooling unless the Applicant can show it is net needed; rather, it is tha cperatien of the plant recuires closed-cycle cooling (for the long term),
based on a positive assessment of the situation and not just a pre-sumption :na: cicsad-cycle has no been shown to be unnecessary.
Any Applicant has the right to ask for a new review tased en new information, and it is noted in the Staff summary that it will apprcpriately consider any new data the Applicant has to offer.
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