ML19209C500
| ML19209C500 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/04/1979 |
| From: | Mcgurren H, Swanson D NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7910150721 | |
| Download: ML19209C500 (11) | |
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9/4/79 NRC PUBLIC DOCUMEYf ROOM
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A UNI!ED STMES OF :0 ?CA r
NUCLEAR REGULATCRY CC. 'ISSION
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3EFORE THE ATr^!IC SAFETY /JiD LIC)_.'.S iN'; A??? -gnARD s'-
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VIRt; INIA ELECTRIC AND PO'4ER CCMPANY
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Doch t No s. 5 0-3 3 3 OL -
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50-339 OL'.
(North.bna Nuclear Pcwer Station,
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NRC STAFF 'EPLY TO INTZ7XENOR ARNOLD AND CG'T.'CSWEALTH OF VI 41NI A ':d"CR.;'.DA CF PROPOSED FINDINGS R.ECARDING_SEFQICE WATER FUMPHOUSE SETTLEMEL' Pursuant to the Atomic Safety and Licensing Appeal Board's Menorandum and Order dated June 21, 1979, the Cot =onwealth of Virginia and the Intervenor Geraldine Arnold submitted on August 20,1979, =emoranda of proposed find-ings reg.irding service water pumphouse (SWPH) settlement (hereinafter Cc mon-wealth anu Arnold memoranda, respectively).
The NRC Staff rsply to these ce=oraada is set forth below.
Cc=onwealth of Virginia Mc orandum The thruat of the Cocoonwealth's position is that since adverse ef fects of SWPH settic=ent may require appropriate action by the reactor operators such indi-viduals shculd be suitably trained in accordance with training progrr.s xhich have been revieu2d and approved by the GC Staf f (Cc monwealth's '!enorandum at 3-4).
The short answer to this is that in fact the operators are trained to respond to a leak in the service water system.
As reflected in the record, the licensee's personaci receive training in loss of service eater '..hich encompasses, c en; etter things, a rupture in the service ' eater system (fr.
136, 137).
The Comenwalth has not established that either the predran is la aay way deficient or that any idditional mem ures such as it ecu?d have the.i. pre 11 Bo ird d irect, are neccssary.
This is especially tr,e in l i:;ht of
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- the extensive record developed hich decenstrates the very unlikely occut ronce of any significant malfunction at the pumphouse and the ease in detecting and correcting a leak which could affect the requirements of that system in the
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unlikely event a leak should occur (Staff Menorandum at 19-30).
Accordingly, the Centen calth's requested actica is urc arranted.
Intervenor Arnold Menorandum Intervenor Arnold raises three aspects of SWPH settlement, and concludes that certain requirements must be imposed on the Staf f by the Appeal 2 card. As the Staff discusses belcw, the concerns raised by Mrs. Arnold do not support the relief requested.
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'!ETiiCD FOR MEASURING EX?3' SION JOINT INTEGRITY Under this heading the Intervenor raises three concerns (at 4 and 5):
(1) That monitoring of settlement, to insure that 6'4PR settle-ment does not exceed specified limits based on manufacturer stress limits of the expansion joints, is inadequate; (2) That the failure of the expansion joint failure mechanism is not understood; and (3) That detection of expansion joint leakage is inadequate.
Nothing in the record suppot s Intervenor's concera that the tonitoring of settle.mnt at the SWPH to insure that the stress limits of the expansion joints are not exceeded is inadequate to assure that North Anna Nuclear Power Station, Units 1 and 2 will operate without undue risk ta the public health and aafety. Rather, the record shows that the Tachaical Specification wend-ment "o.
12 dif ferential limit of 0.22 foot of wttlerent for the expansion joint isnros that the exp.insten joints in tha,ervice cater li.:es will not fasi n values f:r the expansion joints (ltaff '.!anorr !un at 2 's ).
xccol the 3
w :>ll as the t'vrting rn qu i r e r.. it at 75% of this The -ni: 2cing prc;rin
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6 300RORSNil allowable settlement linit pcovides caple time to bring the plant to a safe ccaditico before the design value of the e.:pansion joints is reached (Staf f Memorandum at.27).
In Intervenor Arnold's conclusion (at 17) it is recct= ended that the SEC Staff be required to:
Direct the Applicant to develop end impi,e ent a method for neasur-ing expansion joint integrity thrcush dicact maasurcment of the expansion joint, rather than through.aterpretation of settlement data.
For the reasons stated above and the added reason that there is no evidence in the record indicating a need for providing a systen for "scisuring expansion joint integrity through direct reasurecent of the 2xpansion joint" the NRC Staff believes that the above request is wholly unrupported by the record.
Interv:ncrs second concern, failure to understand the failure rechanisa of the a:'pansien joint, is without support.
The canuf acturer conducted a testing pro-gram and found that the failure mechanisa for metal expansion joints with convoluticas such as those used in the North Anna service water systta is development of fatigue cracking at more than ten times the design nutber of cycles (a cycle is a complete cycling of the bellows assembly, Tr. 239) beyond its elastic limit (Tr. 240).
The record indicates that these tests show that fatigue cracks, referred to es pinhole Icaks, develop arcund tae circumference of the expansien joint convolutions which in tire and under additicnal cycles, will propegate into centinuous circumferential cracks (Tr. 200).
Further, the racerd indicates that the manufacturer hvi run tests en pansien joints si:,ilar to those at North Anna (Tr. 241), that the North anna cxpansion joints ire a standard design ( H.), that the cencept of usiny, such e:m :stan joints in a 1.irge diameter piping system, such as the servi.e.ater
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,p t e m it %rth y
Mna, is not unco::ren ( H.), and t'.wt the exp insion joint 4 :ere manufactured
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300R ORGINAL in accordance with an acceptable quality a.=ur nee program and were inspected for damage before their installation (Tr. 313, 314, and 241; see Staf f ?!cmo-randua at 25.27).
Fiaally, a large leak from the Wrth Anna expcasien joints is unlikely since there are four large tie rods that hold each joint together (Tr. 223, 293; see VEPCO's Memorandum at 20).
The third concern, inadequacy of detection of an expansion joint leak, is also lacking in support. The Intervenor's interpretation of the record is 21slead-Ing (Tr. 224).
Although an expansion joint leak up to the rate of 3,000 gallons per minute weuld not be detected in the Control Room; it would be detected v'isually by an operator, making his rounds every four hours. What is not indicated by the Intervenor is that the reason such a leak does not register in the Centrol Roca is that it would take a leak in excess of 3,CC0
- illons per minute to appreciably af fes the service water systes operation and, thus, shew up on the Control Room instrumentation (Tr. 224).
Accerdingly, even through a leak at a rate of up to 3,000 gallons per minute from an expansion joint may go unnoticed for up to four hours, such leak wculd not affect the public health and safety. A leak rate of 3000 gallens per minute for four hours (720,000 gallons) is well within the Service Water Reservoir capaci:y of 22,500,000 gallons (h rth Anna, Units 1 and 2, SER at 2-11).
VEPCO's Past Mon ito ri_n3 Performance The second aspect raised ay !!rs. Arnold involtes VEPC0's past history of s;rvey-ing.
Her first cencern is based on VEPCO's cc petence and cerr.itrent to operate North inna 1&2 in a safe manner. However, this matter is not relevant to the instant preceeding.
As Mrs. Arnold points cut, that issue was before the Atomic Safety and Licensing Board prerbesly, and was resolved by a finding of t'ut 2 card that Vd2C0 did poczcss the requisite cov 2tence and cc.rnitment (.t r.o ld
/ofrr/n
- Memorandum at 6).
Moreover, that find ing was a f fi.;ced by this Vpeal Euard (ALAB-491, 8 7C 245 (1978)).
Further, the iss :e of VEFCO's commitrent and ccepetende to. safely operate a reactor was not included in the list of issues
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to be considered in this preceeding before the Appeal 2eard (AL\\3'-529, 9 ?:RC 153 (1979)). Accordingly, it is not proper to reconsider that issue at this
- time, Mrs. Arnold then shifts her emphasis frca a concern over VEPCO's ccupetence and commitment to operate a reactor safely to VdCO's perfut ; nee a
>aito t L'a the settlement of the S'.iFH.
Mrs. Arnold first raises a concern over VEPCO's performa. :c during the period of July 1977 to March 1978 (Arnold "emorandum at 7).
However, as the Staf f indicated in "NRC Staf f Testimony Regarding Purp-Scuse Settlement" dated April 27, 1979, following Tr. 338 (hereinafter Staff Testiecny), a special inspection and inquiry was conducted to deter.. tine whether VEFC0 had inproperly withheld information f rom the NRC reg 3rding settlereat of the SWPH in excess of the Technical Specificatica limits (Staff Testineny at 13, 14).
The Office of Inspection and Enforcement concluded that allegations of srongdoing en the part of VEPC0 were not substantiated (Id_.; see also, Staff Testimony, Appendices 3 and C).
Moreover, the Staff considers that this
- atter also relates to an enforcement natter that is outside the scope of the issues raised by the.\\ppeal Ecard.
'*rs.
Arnold further argues that the failure to. ore preaptly report survey result - to VEPCO management during the July 1977 to 'farch 1978 tine peried reflects badly on VEFCO's conpetence (Arnold "emerandum at 3, 9).
She also ar3'res that delays in getting survey results to '!E7CO centinued to '! arch 1979 (Id. at 10).
7E?CO witnesses conceded that there were delays in the past in reporting n iey data to apprcpriate VE?CO perscnnel (Tr. 12 3 -2 '+, L29).
'c a-ever, in early 1979, VE?CO Mtablided a new. 2po rtin3 p reca. ore '-hich requirea WWJ
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-s-the survey results to be transmitted to VE.;C0
_ _'. i i n : e v e.' ':erking days (VErC0 Menorandum at 24).
Moreover, Staff witness Mr. Lcnahan testified t' it VEPCO has been complying with this new procedure, and that the Office of Inspection and Enforcement would be enforcing VEPCO's compliance with this procedure (Staf f Me,orandum at 36).
Mrs. Arnold's last point in regard to ;;cnitorin3 is that VEPCO 'ms careless in f ailing to install a survey marker on the service water lines near the expansion joint until July 1977 (Arnold Me=orandum at 11).
again,.:rs..*_..c'.d da s c.u t argue that this event constituted a violation of any con'struction permit eun-dition or regulation, but merely that' VEPCO's failure to install a marker at the indicated point created a need to estimate a portion of the dif ferential settle cnt that had occurred up to the time that the markers were installed (Id.).
Hewever desirable it wculd have been to have had a marker en the line near the expansion joint prior to July 1977, this omission did not result in any significant problems in determining the - aximum allowable settlenent li.ai t s for the expansion joint, since the Staff was able to conservatively estimate that the top of the dike near the currently existing pipe markers settled at the same count as the exposed ends of the pipes which are embedded in the dike (Staff
- Lucrandum at 2 '+ ).
L' sing this conservative assumption, the Staff was able to
.irrive at a conservative settle:r. eat limit.
Ac co rd ingly, the Staff submits that Mrs. Arnold's concerns reprding VEPCO's past reporting history of survey results is everstated, and does not aupport the claint that additienal regulatory centrols at be frpcsed cn VIPC0 to ascure its prompt receipt of informat ion f rca its surv eyor.
To the extent that Mrs. Arnold concludes that the North Anna technical Specificaticos shculd can-tain strict, exacting, and frequent.nenitori.ng and reporting requh acents, the Staf f submits that the proposed tech: cal specification submitted 'oy.22CO, loff/36
. and as codified by the Staf f, accomplishes these goals.
In the Scaff'2 view, such specifications should not include a requirement that VEFC0 receive the
'results of its. surveys within a specified period of ti=c.
The St'af f submits
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that VEPCO's internal reporting procedures referred to above, uhich are enforced by the Office of Inspection and Enforcement, are suffielent to ensure that prompt reporting of survey results will occur (Staf f Memorandua at 36).
Rnrir n Sottl eant Renntro9.M i 4 t# mal canrion j
The last aspect asserted by Mrs. Arnold involves her perception of the need for added conservatism in setting the settlement linits in light of the continuing settlement of the SWPH (Arnold Memorandum at 12, 13).
Her concern stems in part from the fact that the cause of the continued settlement is not fully understeed (Id. at 13), and her belief that the proposed technical specifi-cation shculd ensure that the joints are kept vell short of design limits (Id.
at 15).
In addition, Mrs. Arnold suggests that an absolute settleacnt limit for the northwest corners of the SWPH be included in the technical specifi-cations (LI. at 16).
In respense, the Staff again notes the conservatisms built into the derivation of the technical specification limits for the facility.
Such conservatisms include:
the assumption that the pipes were rigidly anchored in the soil at a point 60 feet from the exposed ends (Staf f Mencrr.ndum at 20), the assumption that the pipes were rigidly connected at the pumpheuse with the top of the pipes at an elevation of 322.36 feet, assuming no SWPH settlement prior to the time that the pipes were connected (Id. at 21), that the pipes were e-belJcd in the fill in August 1973, instead of the assumed date, thus providing an additional r.argin of safety bet..cea the settlur.ent l i.a i t und the actual stras
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- limit of the joint of.15 foot (Id. at 21), the ascumed settlec. cat of the western-aost line since that line would experience the cost settle.- it of all four lines (ld.,at 23), and the assunption that the joints were installed in December 1975, instead of August and October 1976, the actual dates of instal-lation (Id. at 24, 25).
These conservatisns contribute to the Staff's con-clusion that the 0.22 feet limitation on differential settlement provides the requisite assurance that the facility can operate without undue risk to the pWilic health and safety.
As stated above, the record of this proceeding indicates that a separation of the expansion joints at the SWPH is highly unlikely (supra).
Further, even if there is leakage fron an expansion joint, it can be detected and corrected in a nanner which assures that the public health and safety is protected. Accord-ingly, the conservatists built into the proposed technical specification limits are sufficient to protect the facility from unacceptable conscquences frca settlement, and need not be made even acre conservative as Mrs. Arnold would suggest.
Finally, Mrs. Arnold suggests that an absolute settlement limit should be put on the northwest corners of the SWPH since, as she argues, differential settle-ent by itself wculd not detect a ccmmon settle ent of the SWFH and the piping all the way to China (Arnold "a.crandum at 16, and fcotnote "*").
Mc;2ver, as Mrs. Arnold indic.ites In fcotnote "+" on page 16 of her "ecerandum, the techni-cal specification does in fact place an abselute settle cat limit on the piping.
'ccardingly, the scenario that she describes above would not go unchecked by the settlement limits.
Similarly, settlemen t by either the SWPH or the piping alone :eculd be restricted by the dif ferential aettlement linitati:n ie:cecen them.
Thus, in additimal absolute settlement limit en the northwest corner of the J PH is unnecessary.
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e 300R ORWl COSCLUSION In conclusion, the direction which the Commonwealth would have the Appeal Be.ird impose respecting training-and the modifications to the Staff's technical speci-
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fication as requested by Mrs. Arnold are unnecessary in that the limits set forth in the technical specificatica adequately protect the public health and safety. ' lith respect to Mrs. Arnold's requested monitoring frequency of once every 30 days, the Staff submits that this fiequcacy is proper, but, at precent, c'^nli --ly 5 2 1nposed for a limited durntion.
- s t5.e St :f f '- !i: ted
.t the hearing, the potential for rapid settlement of the SWPH cannot be determined until five years of' monitoring from the date of issuance of the North Anna Unit I license has been completed and assessed (Staf f Memorandum at 35).
Accordin;1y, the Staf f reaf firms its previously stated conclusion (Staf f Semo-randus at 37) that the record supports the conclusica that the North Anna Units 1&2 service water system as well as the requirements of Technical Specificat leas 3/4.7.12 and 3/4.7.13, and Tables 3.7-5 and 3.7-6 assure that North Anna Units 1 and 2 will operate without undue risk to the public health and safety.
Respectfully submitted,
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Ecary J. McGurren Ccunsel for SRC Staff l
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~.e Daniel T.
Swanson
'SU Coun'se1 foe ':RC Staff f
Cated at 2ethesda, Maryla'nd this 4th day of September, 1979 108f 5$
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UNFIED STATES OF A.'c7tCA ly NUCLEAR REGULATORY CO?2:IS '
SEFORE THE ATOMIC SAFETY AND LICENSING APPEAL EO.RD
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In the Matter of
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VIRGINTA ELECTRIC AND POWER COMPANY
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Decket Nos. 50-338 OL
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50-339 OL (North Anna "uclear Pcwer Station,
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Units 1 and 2)
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CERTIFICATE OF SERVICE I* ' i. c:c!?fy "at '7f's af ""RC STAR? 7: LY TO IrTc""r"0R *9'!OLD ":D COM'!0NWEALTH OF VIRGINIA MEMORANDA 0F PROPOSED FINDINGS REGARDING SERVICE WATER PU: r3GCSE SETTLEMENT" in the above-captiened proceeding have been served on the following by deposit la the United States mail, first class, or, as indicated by an astecisk, through deposit in the '!uclear Regulatory Commission's internal mail system, this 4th day of September, 1979:
Alan S. Resenthal, Esq., Chairman
- Dr. Paul W.
Purdom, Director Atomic Safety and Licensing Appeal Environmental Studies Institute Board Drexel University U.S. Nuclear Regulatory Cctaission 32nd & Chestnut Streets w'ashingten, DC 20555 Philadelphia, PA 19104 Dr. John Buck
- Mr.
R.
- 3. Briggs Atonic Safety and Licensing Appeal 110 Evans Lane Board Oak Ridge, TN 37330 U.S. Nuc1 car Regulatory Commission Wa sh in g ten, DC 20555 Michael W. 'faupin, Esq.
Hunton & Williams Michael C.
Farrar, Esq.*
P. O.
Box 1535 Atcmic Safety and Licensing Appeal Richrond, VA 23212 Scard U.S. Nuclear Regulatory Cermission Richard Foster, Esq.
Washinatun, DC 20555 1230 A Pearl Street Denver, CO 80203 Ellyn R.
We is s, Esq.
Sheldon, Harmon, Roisman Mr. James M. Torson
& Weiss 501 Leroy 1725 I Street, N.W.
Socorro, NM 37301 Suite 506 Washingten, DC 20006 Mrs. Jaras C. Arnold Box 3951 Charlottesville, VA 22903
,4 f o8s /37
<, Ro3 ers, Jr., Esq.
'T r. D m P. A;ee William H.
3 Georgetown University Law Center Executive Secretary 600 ::ew Jersey Avenue, N.W.
3 card of Supervisors Louisa Ccurthouac
~ 'iaahin;.; ton, DC. 20001 Louisa, VA 23090 Dr. Kenneth A. McCollem Assistant Dean Atomic Safe'y and Licensing Board College of Engineering Panel
- Oklahcma State University U.S. Nuclear P.cgulatory Ca..:aission Stillwater, OK 74074 Washington, DC 20555
'athony Cc bacdella, Esq.
Atenic Safety and Licensing Appeal Office of the Attorney General Pa.s e ] (5)*
11 South 12th Street Room 308 U.S. Nuclear Regulatory Cc unission Tie:. und, VA 23219
' b u h l.y, ; c a, CC 0D5 Mrs. June Allen Docketing and Service Sect.ica ( '+ )
- 412 Owens Drive Office of the Secretary i!ua t sv ill e, AL 35801 U.S. Nuclear Regulatory Commiscion Washington, DC 20555
' irs. Margaret Dictrich 3 cute 2, Box 568 Gordonsville, VA 22042 300R OR E L L ;':.' ~i ;, j j..,.'!-
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McCurren licary Jf Counsel lor SRC Staff 14 0 g g.7.. -
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