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34/O.22I UNITED STATES NUCLEAR REGULATORY COMMISSION 033 SEP 2 3 375 W ASHINGToN, D.
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20555 Os DD Docket No. 50-358 l
William Kerr, Chairman Advisory Committee on Reactor Safeguards REGULATORY STAFF SUPPORT OF ACRS ACTIVITIES
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Reference is made to our agreement of August 21, 1974, whereby the Regulatory staff is to assist the ACRS in an early identification of
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potential problem areas for each application.
We docketed the Cincinnati Gas and Electric Company's application for an operating license for the Wm. H. Zimmer Nuclear Power Station, Unit 1, on September, 10, 1975. At this time we do not feel that the application involves new or unique potential safety problem areas either related to the site or plant facilities. We will keep you advised if such areas arise during our detailed round-one review of the FSAR.
You should note that the Zimmer facility incorporates the Mark II con-tainment concept and the applicant and staff are actively reassessing dynamic loads on the containment resulting from the LOCA and relief valve action. The facility is presently about 35% complete and construction has progressed well above the drywell-wetwell interface.
We do not anticipate construction or licensing delays pending resolution of this matter since we feel at this time that major design changes will not be required.
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Jo4In F. Stolz, Chief L ght Water Reactor Project ranch No. 2-1 Division of Reactor Licensing a
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Dr'. O. R. Oma6*F Atcaic Power Equipment Department Qeneral Electric Company q
175 Curtner Avenue San Jose, California 95125 j
Dear Dr. Greaser:
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On November 30, 1965, Mr. Robert Brugge of General Electric presented the second seminar in the program for ABC revitw of GE BWR subsystems. This seminar was devoted to consideration of Core Startun Test Programs. 7his f
letter contains our comments on this saminar as they relate to the pre-Mll paration of a document suitable for fornal review. However, I believe it would be worthwhile to provide scene general comunents on the program y%u as we see it developing now that we have had the benefit of two seminars and have cr==wmted on the first by our letter November 17, 1965 W}
It appears to us that, while the reports thus far provided are suitable f
ll for'use prior to the scheduled seminan, they are not really suitable for the kind of safety evaluation that would be zwquired for an " advance I
approval". As was indicated in our November 17 letter, the documentation necessary for such an approval should contain a comprehensive analysis of the use of the system (or techniques) and its attendant safety con-siderstions, as well as the bases for utilizing the system. In addition,
!I any interactica of the system with the rest of the facility must be r
considered to the extent necessary and as dictated by individual circum-
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stances. The description of the system or component would, of course, be repeated ~ as we understand that the original document provided in advance cf the===1 - would not be used for the formal review.
l Ancther worthwhile ecesideration is whether the " advance approval" is to apply to the construction pezmit review or to the provisional operating license review, or both. The startup test pregram, in the detail presented at the seminar, reasonably applies only to the operating stage. However, where components or' systems are to be reviewed they would normally be considered at both stages of review. We believe it important that you j
specify the kind of approval requested. In addition, it vould be useful to specify the type and amount of informative that would be expected to be left for inclusica in the Pr=14=4aa v or Final ysis Report.
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- c. seneems Mr. Brugge inquired as to the requimd number of ccpies of heI$EntStr A ple.
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reports. In view of the considerable interest generated by thFyWM144s MPIB l
seminars, we would appreciate receiving 50 cepies for distribution to N
representatives of the Office of the Dinctor of Regulation, the Divisions of Reactor Licensing, Safety Standazwis and Ccmpliance, and to the ACBS.
The following is a listing of our ccaments as they apply specifically to the second seminart (1) As a general comment we believe some thou6ht;corld profitably be given.to the possibility of brcadening the topic to be reviewed so as to include p operational and operational testing of the nuclear ' steam supply system, rather than confining the review to only the core startup program. It would seem that such a myiew would focus on " advance approval" cf a ccuplete facet of the overall operating state cf review.
(2) 'Jbe material presented in AFED 4851 was oriented tcwards plant operating personnel and as such contained information that was di aquim d to conduct the tests described rather than a safety evaluation of the tests. We believe that much of the detailed procedural inforinatica could be deleted, and that the report should include consideratice of items 3 and 4 telow.
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(3) An identificatice of the analvtical methods and parameters involving the core nuclear, hydraulic and thermal characteristics which are used in the safety assessment of the reactor end a discussion of how those methods and parameters will be confir:aed in the initial testing program and how each method and parameter is related to each specific test.
(4) In the cases referred to in item 3 above, a statement of the criteria governing the experimental accuracy of measurements to be made in initial testing, sad a statement of the criteria for acceptance of deviations of measured values frca cor-msponding values assumed or implied in the safety assessment.
Sincerely yours, Odginal Signed BY R.L Oc:n R. L. Doen, Director Division of Beactor Licensing
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