|
---|
Category:Letter
MONTHYEARIR 05000346/20243012024-02-0202 February 2024 NRC Initial License Examination Report 05000346/2024301 IR 05000346/20230042024-01-31031 January 2024 Integrated Inspection Report 05000346/2023004 ML23313A1352024-01-17017 January 2024 Authorization and Safety Evaluation for Alternative Request RP 5 for the Fifth 10 Year Interval Inservice Testing Program ML23353A1192023-12-19019 December 2023 Operator Licensing Examination Approval Davis Besse Nuclear Power Station, January 2024 L-23-260, Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station2023-12-0707 December 2023 Corrections to the 2022 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station L-23-243, Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0606 December 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23338A3172023-12-0606 December 2023 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000346/2024001 IR 05000346/20234032023-11-0202 November 2023 Security Baseline Inspection Report 05000346/2023403 ML23293A0612023-11-0101 November 2023 Letter to the Honorable Marcy Kaptur, from Chair Hanson Responds to Letter Regarding Follow Up on Concerns Raised by Union Representatives During the June Visit to the Davis-Besse Nuclear Power Plant L-23-215, Changes to Emergency Plan2023-10-19019 October 2023 Changes to Emergency Plan ML23237B4222023-09-28028 September 2023 Energy Harbor Nuclear Corp. - Vistra Operations Company LLC - Letter Regarding Order Approving Transfer of Licenses and Draft Conforming License Amendments ML23269A1242023-09-27027 September 2023 Request for Withholding Information from Public Disclosure IR 05000346/20234012023-09-13013 September 2023 Security Baseline Inspection Report 05000346/2023401 (Public) L-23-205, Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-09-12012 September 2023 Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments L-23-172, Quality Assurance Program Manual2023-08-31031 August 2023 Quality Assurance Program Manual IR 05000346/20230112023-08-30030 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000346/2023011 ML23129A1722023-08-25025 August 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2; Davis Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1 IR 05000346/20230052023-08-24024 August 2023 Updated Inspection Plan for Davis-Besse Nuclear Power Station (Report 05000346/2023005) L-23-188, Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-08-0707 August 2023 Energy Harbor Nuclear Corp., Supplement to Application for Order Consenting to Transfer of Licenses and Conforming License Amendments IR 05000346/20230502023-08-0303 August 2023 Special Inspection Report 05000346/2023050 IR 05000346/20230902023-08-0101 August 2023 EA-23-002 Davis-Besse Nuclear Power Station - NRC Inspection Report No. 05000346/2023090 (Public) ML23178A2742023-08-0101 August 2023 Letter to the Honorable Marcy Kaptur from Chair Hanson Responds to Letter Regarding the License Transfer Application for the Davis-Besse Nuclear Power Station L-23-175, Submittal of Fifth Ten Year Inservice Testing Program2023-08-0101 August 2023 Submittal of Fifth Ten Year Inservice Testing Program IR 05000346/20230022023-07-27027 July 2023 Integrated Inspection Report 05000346/2023002 ML23193A7842023-07-13013 July 2023 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000346/2023402 ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III ML23160A2342023-06-13013 June 2023 Confirmation of Initial License Examination L-23-034, 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models2023-06-13013 June 2023 2022 Annual 10 CFR 50.46 Report of Changes to or Errors in Emergency Core Cooling System Evaluation Models IR 05000346/20235012023-06-13013 June 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000346/2023501 L-23-135, Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-05-31031 May 2023 Response to Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations L-23-065, Annual Financial Report2023-05-22022 May 2023 Annual Financial Report ML23124A1742023-05-17017 May 2023 Energy Harbor Fleet Vistra License Transfer - Request for Withholding Information from Public Disclosure for Commance Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 ML23129A0112023-05-16016 May 2023 Notice of Consideration of Approval of Indirect and Direct License Transfer for Comanche Peak Plant, Units 1 & 2, Beaver Valley Station, Units 1 & 2, Davis Besse Station, Unit 1 and Perry Plant, Unit 1 (EPID L-2023-LLM-0000) (Letter) ML23131A2732023-05-15015 May 2023 Notification of NRC Supplemental Inspection 95001 and Request for Information L-23-101, Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 20222023-05-12012 May 2023 Combined Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report for the Davis-Besse Nuclear Power Station - 2022 L-23-131, Readiness for Resumption of NRC Supplemental Inspection2023-05-12012 May 2023 Readiness for Resumption of NRC Supplemental Inspection IR 05000346/20230102023-05-0909 May 2023 Commercial Grade Dedication Inspection Report 05000346/2023010 ML23123A1272023-05-0303 May 2023 Information Request to Support Upcoming Problem Identification and Resolution Inspection at Davis-Besse Nuclear Power Station IR 05000346/20230012023-05-0101 May 2023 Integrated Inspection Report 05000346/2023001 and 07200014/2022001 L-23-092, Occupational Radiation Exposure Report for Year 20222023-04-27027 April 2023 Occupational Radiation Exposure Report for Year 2022 ML23111A1972023-04-26026 April 2023 Information Meeting with Question and Answer Session to Discuss NRC 2022 End-of-Cycle Plant Performance Assessment of Davis-Besse Nuclear Power Plant Station ML23114A1062023-04-25025 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection CP-202300181, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-20020 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, ISFSI, Corrected Affidavit for Application for Order Consenting to Transfer of Licenses and Conforming License Amendments CP-202300157, ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments2023-04-14014 April 2023 ISFSI, Beaver Valley, Units 1 and 2, ISFSI, Davis-Besse, Unit 1, ISFSI, Perry, Unit 1, and ISFSI, Application for Order Consenting to Transfer of Licenses and Conforming License Amendments ML23096A1382023-04-11011 April 2023 Review of the Spring 2022 Steam Generator Tube Inspection Report L-23-061, Submittal of the Decommissioning Funding Status Reports2023-03-31031 March 2023 Submittal of the Decommissioning Funding Status Reports L-23-037, and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments2023-03-29029 March 2023 and Perry Nuclear Power Plant - Independent Spent Fuel Storage Installation Changes, Tests, and Experiments L-23-066, Annual Notification of Property Insurance Coverage2023-03-21021 March 2023 Annual Notification of Property Insurance Coverage ML23066A2892023-03-14014 March 2023 Request for Threshold Determination Under 10 CFR 50.80 and 10 CFR 72.50 for an Amendment to the Voting Agreement ML23066A2592023-03-14014 March 2023 Request for Withholding Information from Public Disclosure for Beaver Valley Power Station, Units 1 and 2, Davis Besse Nuclear Power Station, Unit 1, and Perry Nuclear Power Plant, Unit 1 2024-02-02
[Table view] |
Text
November 4, 2011 Cynthia Pederson, Regional Administrator (Acting)
U.S. Nuclear Regulatory Commission Region III 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Via email to Cynthia.Pederson@nrc.gov
SUBJECT:
Conditional Allegation - Shield Building Design at Davis-Besse
Dear Ms Pederson:
The purpose of this letter is to ask questions concerning the design evaluation and analysis of the shield building at the Davis-Besse nuclear plant. However, if the NRCs processes cannot support answering these questions before the plant restarts, please treat them as allegations.
BACKGROUND Updated Final Safety Analysis Report (UFSAR) section 3.8.2.2 summarizes the design and associated analyses for the shield building. UFSAR section 3.8.2.2.2 states that dead loads were considered in the shield building design. UFSAR section 3.8.2.2.4 states that the dead loads included concrete (143 pounds per square foot) and steel reinforcing (489 pounds per square foot).UFSAR section 3.8.2.3.7 states that Cement for all concrete except the Shield Building is Type II low alkali cement The Shield Building has Type I cement above grade.UFSAR Figure 3.8-3 (left) illustrates a typical section of the containment vessel and shield building.
The NRCs PNO-III-11-014 (ML11293A092) dated October 20, 2011 stated:
The reactor vessel closure head is bolted on top of the reactor vessel which is located inside a 1.5 inch thick steel containment vessel surrounded by a 2.5 foot thick free-standing, reinforced concrete, shield building. The majority of the shield building vertical exterior has additional non-structural, architectural concrete up to 1.5 foot thick separated by grooves.
November 4, 2011 Page 2 of 3 This plan diagram (overhead view) of a section of the shield building wall shows the non-structural, architectural concrete referred to in the NRCs PNO. As indicated by the two fish-hook shaped devices in the drawing, the attachments are anchored to the shield building wall.
The media has reported that numerous cracks in the non-structural, architectural concrete have been identified. The NRC PNO stated If there are any challenges identified to the design function of the shield building they will have to be resolved before the plant restarts.
QUESTIONS
- 1. The non-structural, architectural concrete elements do not appear in UFSAR Figure 3.8-3. The plan diagram indicates these elements are connected to the shield building wall. Are the dead loads from these concrete elements properly considered in the design analyses of the shield building?
- 2. The UFSAR does not explicitly describe these non-structural, architectural concrete elements. Thus, it is not clear if these elements have Type II concrete or Type I cement as explained in UFSAR section 3.8.2.3.7. What type of cement was used in the non-structural, architectural concrete?
- 3. If the concrete/cement in the shield building is the same as that in the non-structural, architectural concrete elements and all have the same age and environmental exposure history, would numerous cracks identified in one suggest comparable conditions in the other? If not, why not?
UCS realizes that UFSAR Figure 3.8-3 is a simplified drawing and the design analysts hopefully used the more detailed civil/structural arrangement drawings, but it is prudent to check to verify
November 4, 2011 Page 3 of 3 it. Recall that the NRC team conducting the design inspection at the DC Cook nuclear plant in summer 1997 found that design analysts had failed to consider a wall inside containment that caused their calculations of water inventory available during the recirculation phase of an accident to be significantly non-conservative. Holes had to be cut through that wall to assure that adequate water inventory would be available.
UCS also understands that the numerous cracks, even if also within the shield buildings walls, do not in themselves demonstrate that the design function has been compromised. But theres little reason that numerous cracking found in the non-structural, architectural concrete would not also be found in the shield building concrete unless (a) a different type of concrete was used, or (b) no one looked at the shield building concrete.
CONDITIONAL ALLEGATIONS UCS would prefer that the NRC answer the questions above before Davis-Besse restarts. But we realize that the NRC may lack the process and means to do so. If that is the case, please consider the following two items with the agencys allegations program:
- 1. The design evaluation and analysis for the shield building did not properly consider the dead load from the non-structural, architectural concrete attached to it.
- 2. The shield building wall was not sufficiently examined for indication of cracking.
Sincerely, David Lochbaum Director, Nuclear Safety Project PO Box 15316 Chattanooga, TN 37415 (423) 468-9272, office (423) 488-8318, cell