ML19199A581

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Forwards L Bykoski Draft Testimony on Contention 2,re Cooling Tower Design Adequacy of Earthquakes & Tornadoes
ML19199A581
Person / Time
Site: Crane Constellation icon.png
Issue date: 01/26/1977
From: Cleary D
Office of Nuclear Reactor Regulation
To: Regan W
Office of Nuclear Reactor Regulation
References
NUDOCS 7905040215
Download: ML19199A581 (4)


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-77

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  • Form AIC.518 ( Rev. 7 3)) AEQd 0240 TT w as eovsneemmere pansreise orrieus t eva.eae.see

Q Uf!ITED STATES CF AME?,ICA tiUCLEAR REGULATCRY CCMMISSIC:i BEFORE THE ATCi1IC SAFETY AtlD LICE!iSI:'G ECARD In the i'atter of

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liUCLEAR REGULATORY CC 7tISSIO 1 STAFF'S TESTIMCriY C 1 CCliTEllTIC:1 ~

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9 This testimcny addresses Centention 3 hich states:

"The design for the ccoling to..ers is inadequate to withstand the earthcuake or tornado that the rest of the plant is built to withstand. As a result, if this earthquake or tornado does occur ar.d tne main plant does withstand it, it is highly prctable that the cooling towers will not. Then, either the plant will shut down for two or three years v.hile the towers are rebuilt cr repaired, or the plant..ill centinue to operate without cooling tcwers using cnce-tarcugh cooling.

In this latter event, it is highly likely that state water quality criteria would be violated a.~.d severe envircntental impacts would ensue.

There-fore, no operating license should be granted until the entire plant is rendered capable of withstanding the maximum anticipated earthcuake or tornado cr until an adequate cost-benefit analysis ;.rsuant to NEPA is conducted taking into account the impact of possible loss of the ccoling tov.ers."

The plant, as it is designed, is physically incapable of operating a once-through ccoling system. Therefore, the plant will not operate in violation of state water quality criteria as a result of cnce-through cccling.

The contenticn assumes that all plant systems and structures other than the cooling towers cre designed to withstand earthcuakes and tornadoes.

In fact, only those plant systems and structures '<.hich are necessary to shut the plant dcwn safely and maintain it in a safe shutdo.;n ccndition are designed to withsta-d tornadces and a level of seismic shaking called the Safe S'rutdcwn Earthquake.

These strigent design requirements against the effects of natural phencrena are required by NRC to cratect the health and safety of the public. The remaining systems and structures, including the cooling tcwers, are not specified by MRC regulations with regard to effects of natural phencmena. Plant features not included in the health ar.d ll 1

safety category are designed by the applicant to be cost effective and to meet any building ccdes as may be required by state and local regul a tions.

The same conditicns would exist for any alternative energy scurce plant at the same site.

If one were to consider the loss of cooling towers at the site same-time during the lifetime of the plant, this would only change the lifetime capacity factor of the plant frcm an assumed 70% to about 65%. However, it is important to reali:e that this same reduction in capacity factor would cccur if a fossil plant were located at that site.

It should be further realized that the probability of occurrence of natural phenomera sufficient to cause such damage is lcwer than the assumed 100 percent probability, thus, the actual prcbalistic reduction in capacity factor due to the effects of natural phencmena en the cooling tcwers would be even icwer than the five percentage points calculated.

In addition to the above points, it must be remembered that there are portions of the plant other than cooling towers that also are not designed to MRC seismic and wind leading safety criteria, such as the turbine, main condenscr, turbine building, switch-yard, ar.d transmission lines. Thus, the design of cooling towers to more stringent requirements would not substantially improve the ability of the entire plant and transmission system to withstand severe natural phenomena. Also, since statistical information on capacity factcrs inherently includes the impacts of such natural phencmena, it is clear that to reduce the value of the anticipated capacity factor further because of this postulated impact would be improper.

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