ML19256B082
| ML19256B082 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/05/1979 |
| From: | Christman J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | |
| References | |
| NUDOCS 7901230301 | |
| Download: ML19256B082 (23) | |
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UNITED STATES OF AMERICA c. , , , , , , , , , -p NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFLTY AND LICENSING APPEAL BOAR S/
07 P In the Matter of )
)
VIRGINIA ELECTRIC AND POWER )
COMPANY ) Docket Nos. 50-338 OL
) 50-339 OL (North Anna Fower Station, )
Units 1 and 2) )
VEPCO'S RESPONSE TO UCS REPLY BRIEF This Appeal Board, in its order of December 7, 1978, permitted the Union of Concerned Scientists (UCS) to file a second brief amicus cur iae. UCS filed its brief December 14, and the other parties were given until January 5 to respond
("NRC Staf f Request for Extension of Time to File Response to UCS Supplemental Br ief," Dec. 20, 1978, stamped " Granted" Dec.
21, 1978). Th is is Vepco's response.
The only question the UCS was allowed to address is "why it believes that the turbine missile question cannot be resolved for the North Anna facility independently of the outcome of the generic inqui.," (Appeal Board order of December 7, 1978, at 2; UCS brief 6). Ultimately, of course, UCS has to convince the Appeal Board that the turbine missile issue has not been "taken into account in a manner that is at least plausible and that, if proven to be of substance, would be 301 790123os6/
adequate to justify operation" (ALAB-491, slip op. 6 n.7). The UCS brief is inadequate to do this.
The UCS brief is not really a brief at all -- it is t e s t im ony . Sponsored by Robert Pollard, it takes issue with the substance of the NRC Staff's technical analysis of the turbine missile risk. And it comes at an odd time -- about a year after the initial decision and over a year and a half after Mr. Pollard made his limited appearance in the proceeding.
The UCS argument ~has two components, which are, roug hly in order of their importance, (1) that the Staff's technical judgments are wrong and (2) that there will not be adequate information on which to grant an operating license until after the generic studies are finished. Vepco will address each of these arguments in turn.
I. Technical argument: the three probabilities The first UCS argument, which runs through pages 7-13 of its brief, is simply that the Staf f's estimates for the probability of unacceptable turbine missile damage are not conservative at all, despite the Staff's reasoned opinion to the contrary. There are three probabilities that, mul t ipl ied together, give the odds of unacceptable turbine missile damage:
(1) the probability that a turbine missile will be ejected, (2)
9 the probability that it will strike a safety-related structure, and (3) the probability that the structure will sustain unacceptable damage (UCS br ief 5) . The NRC Staff believes it has estimated these probabilities conservatively ( that is, larger than they are in real life). UCS d isputes that belief for each of the three. Although Vepco believes that most of the UCS claims can be disposed of on the existing record, it nevertheless offers the attached af fidavit of Gregory L.
Strickler as additional information.
Turbine f ailure probabilit_v. First UCS takes issue with the Staff's opinion that modern turbines are less likely to generate missiles than older ones because the new turbines are impt yed in materials and overspeed protection. UCS argues that the improvements "may well be offset by f actors such as the larger size of modern turbines and the increased number of turbine blade wheels" (UCS brief 8), that improvements in overspeed protection will reduce the probability of destructive overspeed but not of design overspeed f ailures (id. ), and that even the risk of destructive overspeed f ailures is not much bettered, because those failures tend to be caused by failure of steam supply valves rather than of overspeed protection devices ( id . ) .
This is simply a disagreement over the facts, with Mr.
Pollard on one side and the rest of the evidence on the other.
Vepco's experts, for example, believe that modern improvements in turbines have reduced the probability of failure.
Westinghouse's analysis indicates that the probability of
-6 turbine failure is on the order of only 10 per turbine per year ("Vepco's response to the Limited Appearances of Mrs.
Allen and Mr. Pollard," July 5, 1977, at 55). The NRC Staff's plant-specific review of North Anna 1 and 2 agrees that modern turbines are less likely to fail (Staff response of September 15, 1978, at 5) , and this opinion is consistent with the Staf f's gener ic judgment in Regulatory Guide 1.115:
There is reason to believe that improvements in turbine design, particularly in materials selection, will reduce the design overspeed f ailure rate.
...The staff's view is ... that significant reduction in the rate of destructive overspeed failures may be obtained by the application of improved overspeed protection systems, redundant turbine steam valving, improved valve design, and frequent valve testing.
(Regulatory Gu ide 1.115, Rev. 1, July 1977, at 2.) See also the attached Af fidavit of Gregory L. Strickler. The fact that Mr. Pollard disagrees with Regulatory Guide 1.115 and the other expert opinions about modern turbines is no basis for deciding that those opinions are wrcng.
In short, the record shows that modern turbines are less susceptible to failure and supports the Staff's and
~
Vepco's position, and there is no doubt that the Staff's analysis is "at least plausible" and "if proven to be of substance, would be adequate to justify operation."
The four-missile assumption. UCS next takes issue with the following of the Staff's opinions:
In calculating a turbine missile strike probability it is assumed that the turbine wheel breaks lito 4 equally-sized quadrants, whereas records of actual turbine failures indicate that other modes of failure
( involving f ewer large-sized f ragments) have occurred.
This has a tendency to maximize the estimate for turbine missile strike probability.
(Staf f response of September 15, 1978, at 5.) UCS's point is that there have been past instances of turbines' ejecting more than four missiles at a time, and that the probability of strike naturally rises with the number of missiles.
What UCS would have the Staff do, apparently, is assume the number of missiles that would produce the greatest chance of unacceptable damage, considering both the probability of strike and the amount of kinetic energy necessary to do serious damage. UCS points out that increasing the number of missiles both increases and decreases the r isk of damage, because a larger number of less massive missiles have a better chance of striking something but a poorer chance of doing serious damage when they do.
It would probably not be possible to carry off the
max imization-of-r isk exercise that UCS envisions, because it would require a good deal of quantitative information about the risks involved, and Vepco understands quantification to be the object of the ongoing generic studies. Instead, what the Staff has done is to pick a conservative probability, based on technical judgment and histor ical data, for both the probability of strike (P2) and the probability of unacceptable damage (P3). As we shall see below, UCS concedes the Staff's choice of P 3 is conservative. And as for P 2, f ur missiles is the assumption used in Regulatory Guide 1.115, according to UCS (UCS brief 10), and so the North Anna review is on that count consistent with the Staff's official position. It is not clear whether UCS is challenging Reg Guide 1.115 as well as the North Anna safety analysis. If so, it is on weak ground: Mr.
Pollard himself provided some of the basis of the reg guide (Pollard af fidavit 3), and the ACRS has concurred in the regulatory position the guide represents (Regulatory Guide 1.115, Rev. 1, July 1977, at 1). The Staff in the exercise of its technical judgment has concluded that four missiles is an adequately bad-case assumption for North Anna, and on the record as it stands that decision is plausible.
Probability of damage. The third conservatism, the assumption that the probability of strike and the probability
of unacceptable damage are the same, is not seriously in issue, because UCS agrees that there is "some conservatism" in this assumption. It s techn. cal argument on this point is only that the Staff is not able to quantify the degree of conservatism.
The Staff has conceded, of course, that the purpose of the gener ic stud ies is to quantify the turbine missile risks, and so UCS's argument is beside the point.
Additional conservatisms. As with the P3 assumption, UCS does not deal with the substance of the additional conservatisms imposed by the Stat f , the inspection and maintenance and testing program, except to argue (UCS brief 12) that there is no way to quantify them. Nor does UCS deal with the plant-specific conservatisms mentioned in the discussion of
" missile effects" (Task A-32). For example, the analysis for North Anna 1 and 2 assumed weaker concrete than is actually in place, which according to theory makes the concrete more d if f icul t to penetrate, and the Staff required an extra-thick barrier to prevent spalling (Staff response of September 15, 1978, at 3). These additional conservatisms are evidence that the North Anna units are appropriately protected in accordance with NRC requirements.
Lob shots. UCS raises one additional point in its technical argument. It argues that all of the discussion in
the record is about low-trajectory turbine missiles and not high-traj ectory ones (" lob shots") . This argument is nothing more nor less than an effort (by a nonparty at that) to introduce a new technical issue a year and a half after the close of the principal hearings. The " lob shot" issue is thus one that should be left to the Staf f's review. Even so, the record in this proceeding does contain some relevant evidence, because the Staff's discussion of missile ef fects (Task A-32, Staff response of September 15, 1978, at 2-3) discusses certain conservatisms that are relevant to all kinds of missiles.
Moreover, the attached af fidavit of Gregory L. Strickler shows that the hazard rate from high-trajectory missiles is very small.
It should be evident by now that the record in this proceeding supports the Staff's conclusion that, because of multiple conservatisms, North Anna is " appropriately protected" against missile defects and that the Staff's resolution of this issue is "at least plausible" and "if proven to be of substance would be adequate to justify operation." And with that UCS's case evaporates. Because UCS has made an additional argument, however, we will go on to address the other points in the UCS brief.
II. Generic versus specific Stripped of its technical argument, discussed above, UCS's case boile down to the shopworn argument that North Anna may not be licensed until the generic studies are finished, because until then there is too little information to justify a license. UCS claims that to license the plant at all the Staff has had to presume the outcome of the generic studies.
Sometimes this argument takes the form that the Staff has f ailed to quantify the conservatisms and sometimes that there has really been no plant-specific analysis at all. But the basic claim is a f amiliar one: "you can't possibly know enough, because you' re trying to learn more."
As Vepco pointed out in its response to the first UCS br ief amicus cur iae, this generic versus specific argument has been rej ected many times ("Vepco's Response to UCS Br ief Amicus Cu r iae ," November 16, 1978, at 7 ) . An individual plant may be licensed while a relevant generic proceeding is ongoing, provided there is sufficient evidence on which to base a decision for the individual plant. As we have shown, there is such evidence in this case.
Nevertheless UCS presses on. It begins with the argument that merely by classifying the turbine missile issue as " Category A" the Staff has acknowledged that completing the
generic studies is crucial to the licensing of nuclear plants (UCS brief 2-3). But as UCS recognizes, Category A issues include those that could " provide a significant increase in assurance of the health and safety of the public" or "have a s ign if icant impact upon the reactor licensing process" (UCS brief 2 n.1). There is nothing in the definition of Category A indicating that such an issue has to be resolved before licensing can continue. ( Fo r example, Task A-38, " Tornado Missiles," is Category A even though it represents an effort to consider the relaxation of Staf f requirements that may be overly conservative; presumably this could "have a significant impact upon the licensing process") .
UCS then raises the argument, reductio ad absurdum, that the conservatisms at North Anna, particularly the inservice inspection and maintenance program, cannot really be e f f ec t ive , because if they were the Staff could simply impose similar measures on all plants and cancel the generic studies.
UCS goes on to demonstrate that most of the conservatisms are being studied as parts of the generic Task Action Plans. With respect to P y, the probability of turbine failure, page 8 of the UCS brief (paragraph 3 at the bottom) points out that one of the generic problems is to provide " formal NRC guidance" on how to evaluate the ef fect of the toughness of turbine disk
.aaterials and of testing and inspection of disks, overspeed control systems, and steam valves (A-37/1). On page 10 (second paragraph) of the UCS brief, UCS points out that another gener ic problem is to identify and document the acceptable methods for estimating the missile strike probability P 2 (A-37/1). As for P 3 (the probability of unacceptable damage in the event of a strike), pages 11-12 of the UCS brief point out that generic Task A-32 aims to develop " quantitative acceptance criteria for judging the acceptability of barrier failure probability" (A-32/2). And with respect to the testing and inspection programs, UCS brief page 12 mentions that Task Action Plan A-37 acknowledges that there is, once again, no
" formal NRC gu idance" on how to evaluate testing and inspection of disks (A-37/l). Finally, on the subject of high-traj ectory missiles, the UCS brief at page 13 points out that Task Action Plan A-37 proposes to "re-examine the methods of analysis used by applicants for estimating strike probability for . . .
high-traj ectory missiles" (A-37/5).
It is perfectly evident, however, that nothing in the generic Task Action Plans cited by UCS shows that the NRC's experts are incapable of making technical judgments on individual power plants. A mere glance at the Task Action Plans reveals that they have been undertaken not to determine
whether the Staff is correct in judging that multiple conservatisms exist, but rather to quantify those conservatisms and provide generic guidance so that less ef fort need be put into plant-specific analyses in the future. Thus, A-32 is essentially a " confirmatory task":
As noted in S3 of Task A-32 the conservative approach used in the current NRC criteria on missile effects assures that nuclear power plants meeting the criteria have substantial safety margins for a broad spectrum of missile hazards. In that regard Task A-32 is essentially a confirmatory task, that is, the Staf f's current design criteria for protection against missile effects are judged to be adequate because of ample compensation for gaps in directly applicable test data and lack of detailed confirmation of analytical methods achieved by the series of conservative assumptions noted below. However, further study is believed to be prudent to place this confirmation on a quantitative basis.
(Staff response of September 15, 1978, at 2.) Similarly, Task A-37 is designed more to measure the degree of conservatism than to confirm that it exists:
Presently, the methods and criteria used to evaluate these probabilities [P P and P,] are believed to have relatively large ka,rg n,s i of conservatism in order to compensate for the uncertainties in the available empir ical data and state-of-the-ar t analytical methods.
The purpose of the generic studies described in Task A-37 is to provide a quantitative measure of the conservatisms built into the current NRC missile protection criteria.
(Id. 4.) The Task Action Plan for tornado missiles, A-38, even goes so far as to say that the present safety analyses are too conservative, and that the purpose of the Task Action Plan is
to prevent unnecessary design requirements "due to over.'y large margins of conservatism" (id. 6-7). Thus UCS's attempt to turn these generic goals into critical-path items for the North Anna Station is unavailing.1 UCS concludes its argument by alleging (UCS brief 16) that the Staff hasn't really done a site-specific review at all. UCS emphasizes the Staff's change in position --
representing to the ASLB that North Anna 1 and 2 were adequately protected only until the outcome of the generic stud ies, and then representing to the Appeal Board that the gener ic stud ies are expected to make no dif ference -- and says that there is no basis for it, since "no additional substantive review is claimed by the Staff to have been performed since the SER."
UCS is mistaken. The Staff response of September 15 noted that most of Task A-37 was in the final stages of 1/ At times UCS seems to be saying either that the technical judgment of experts is not an adequate basis for licensing decision, or perhaps only that qualitative judgments are not adequate. For example, the repeated demands that the conservatisms be quantified suggest that UCSwouldbesatisfiedwitgaStaffjudgment that a probability is, for example, 10- but not with a judgment that the probability is so low that safety-related systems are " appropriately protected." Ne ithe r c la im , if claims they are, has any merit; the very nature of the general design criteria demands judgments, some t ime s imprecise but always conservative, about how much protection is enough.
completion and that a final report was expected Apr il 15, 1979 (Staff response of September 15, 1978, at 4). In its response to UCS's request to file its second amicus brief the Staff said that it had drawn on information developed through Task A-37:
The Staff currently believes that, based on information developed th: lug h Ta s k A-3 7, no additional requirements will have to be imposed on facilities such as North Anna.
("NRC Staf f Response to UCS Request for Leave to File Reply Br ief," December 5, 1978, at 5.)
Given the purpose of the generic task action plans --
to develop formal guidance, to quantify risks, to remove unnecessary conservatisms -- UCS's suggestion that they demonstrate by their very existence the inadequacy of the North Anna plant-specific analysis is off the mark. UCS's reductio ad absurdum argument that, if the conservatisms at North Anna were so good, the Staf f could simply impose them everywhere, is unpersuasive because the Staff could do something of the kind, at least for f acilities "such as North Anna" for which Task A-37 is expected to impose no additional requirements ( see "NRC Staf f Response to UCS Request for Leave to File Reply Br ief ,"
December 5, 1978, at 5), but has chosen not to.
The Staff has chosen to proceed with the generic Task Action Plans, presumably because the result will decrease the amount of manpower needed for site-specific reviews, make more
uniform the requirements imposed on dif ferent facilities, and remove conservatisms that are unnecessary. There is nothing in that decision that is inconsistent with the ability to do plant-specific safety reviews.
III. Conclusion Vepco concludes that UCS, despite its eleventh-hour testimony questioning the NRC Staff's technical judgment, has utterly failed to cast any doubt on the adequacy or correctness of the Staf f's plant-specific safety analysis. The Appeal Board should so find and affirm the granting of operating licenses insofar as the turbine missile issue is concerned, and the UCS request that the operating licenses be suspended should be denied.
Respectfully submitted, VIRGINIA ELECTRIC AND POWER COMPANY By /s/ James N. Christman James N. Christman Of Counsel Michael W. Maupin James N. Ch r istman James M. Rinaca Hunton & Williams P. O. Box 1535 Richmond, Virg inia 23212 DATED: January 5, 1979
January 5, 1979 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
) Docket Nos. 50-338 OL VIRGINIA ELECTRIC AND POWER COMPANY ) 50-339 OL
)
(North Anna Power Station, )
Units 1 and 2) )
AFFIDAVIT OF GREGORY L. STRICKLER, VEPCO ENGINEER My name is Gregory L. Strickler. I have been employed as an engineer by Virginia Electric and Power Company since August 5, 1977. Before that I was a consulting engineer in structural design for Gilbert Associates. I hold B.S.
and M.S. degrees in civil engineering from The Pennsylvania State University.
I have been asked to coordinate the response to cer-tain technical arguments made in the " Union of Concerned Scientists Reply Brief, Amicus Curiae," dated December 14, 1978. In preparing this response I have consulted knowl-edgeable engineers at Westinghouse, which manufactured the North Anna turbines, and at Stone & Webster, which designed and constructed the power station. Their opinions form
the basis of this affidavit. I am confident that the Westinghouse and Stone & Webster experts I consulted are both truthful and technically qualified.
I should point out that a thorough analysis of the probability of a turbine missile's damaging an essential system at North Anna 1 and 2 has been performed. This analysis, which is set out in the Final Safety Analysis Report S 10.2.1, demonstrates that the probability of a turbine missile's damaging an essential system is negligible.
Low-traj ectory missiles. UCS argues (UCS brief page 8, single-spaced paragraph "1") that improvements in overspeed protection have no effect on the probability of design overspeed, as opposed to destructive overspeed, failures. This is incorrect, because design overspeed results from a failure of the overspeed protection system that closes governor and interceptor valves at 103% (or less) of operating speed. (Design overspeed is defined in Regulatory Guide 1.115, page 1.115-2, as 120-130% of turbine operating speed.) Therefore, improvements that reduce the likelihood of failure of the overspeed protec-tion system will decrease the probability of generating missiles at design overspeed.
The UCS brief (page 8, single-spaced paragraph "2")
argues that improvements in overspeed protection may not reduce P y because destructive overspeed failures in the
~
past have been caused by failure of the steam supply valves rather than by failure of the devices used to sense overspeed and initiate closure of the valves. UCS suggests that redundant system supply valves may be the answer:
The Staff has not required the inrtallation of redundant steam supply valves which could ameliorate the cause of the historically-observed rate of destructive overspeed failures.
(UCS brief 8, single-spaced paragraph "2").
It may be true that the Staff does not require redundant valves, but it is standard Westinghouse practice to use redundant steam supply valves, and such valves are installed at North Anna 1 and 2.*
The UCS brief (page 9, last sentence) says that the rotational kinetic energy of the turbine wheel will be divided between the translational and rotational kinetic energy of each fragment. It fails to note, however, that
- I should like to correct a misimpression that may have been created by "Vepco's Response to the Limited Appearances of Mrs. Allen and Mr. Pollard," July 5, 1977.
At page 5 of that document the following statement is made:
Westinghouse has performed fault-tree analysis of the turbine overspeed pro-tection system, giving due consideration to improvements in turbine materials, valving, and controls, and estimates a probabilit order of 10 0y per of turbine turbine failure on the per year.
Actually, improvements in valving and materials were not considered in the fault-tree analysis. I learned of this error in the course of preparing this affidavit.
6
the rotational energy does not contribute substantially to missile penetration, because it is dissipated in heating and smearing of metal. This point was made at pages 56-57 of "Vepco's Response to the Limited Appearances of Mrs. Allen and Mr. Pollard," July 5, 1977.
UCS finds fault with the four-missile assumption (UCS brief pages 9-10), urging that the number of assumed missiles be picked so as to produce the highest possible chance of unacceptable damage. The choice of four missiles was not arbitrary, but rather was based on max-imizing the energy per missile as it exits the turbine housing.
The UCS brief (page 8, lines 6-8) claims that the larger size of modern turbines increases the risk. In fact, the larger size will not increase the probability of failure because the same margins of safety are used in the design of the new turbines as were used for the old ones.
Hich- traj ec tory missiles . The UCS brief (pages 12-
- 14) makes much of the risk from high-trajectory missiles, but UCS's concern is unwarranted. As Table 10.2-3 from the FSAR shows (see copy attached to this affidavit),
the overall probability P 4 (= P y xP xP)3 r hazard 2
rate for high-traj ectory missiles , according to the Stone &
Webster analysis, is very low, the largest probability O
being 6.7563 x 10-10 (for the auxiliary building and cable tunnels). This analysis relies on Westinghouse's conclusion, based on its fault-tree analysis, that P y is only 10-6 per turbine per year.
This affidavit is based solely on the opinions of the Stone & Webster and Westinghouse experts I con-sulted.
e Greg6ry 4. Strickler Subscribed and sworn to before me this 5th day of January, 1979. In testimony whereof, I have hereunto set my hand this day, month and year aforesaid.
My commission expires: (f //// 79 lblUlkL E8 '
4 Nbchry Public G
) ) )
SN1LE 10.2-3 (NERAIL PIOBABILI'IY (P4)
Vo = 300 1TS Vo = 600 FPS Im iligh Im liigh Critical Plant Pcgion Traiectorv Trajectory Trajectorv Trajectory Control luxm 6 Drcr b\gr/lblay Poom 1.2223t.-12 3.0169E-13 1.9671E-0S 3.0275E-10 Daergency Diesel Generator Ibcm 0.0 1.3314E-13 0.0 1.3417E-10 Ecactor Contairraent Unit 1 1.0447E-11 1.8320E-13 1.7029E-07 1.7940E-10 Scactor Contaiment Unit 2 1.0447E-11 1.8311E-13 1.7029E-07 1.7941E-10 Fuel Building 0.0 1.3139E-13 0.0 1.3235E-10 Lecmtamination Building 0.0 3.9760E-14 0.0 3.9961E-11 Gascous klaste Decay Tanks 0.0 1.4794E-14 0.0 1.4955E-11 36 Auxiliary reediater Punp ifouse Unit 1 1.21051:-12 6.1831E-14 1.9547r-08 6.2075E-11 Auxiliary reedater Punp llouse Unit 2 1.2858C-12 6.1590E-14 2.0763E-08 6.1881E-11 Fuel Oil Pump Ilouse & Storage Tan};s 0.0 7.9273E-14 0.0 7.9139E-11
=
Auxiliary Building & Cable Tunnels 0.0 6.7398E-13 0.0 6.7563E-10 !;l Auxiliary Serv klater Pump Ilouse E Pipes 7.8800E-13 5.7969E-14 1.26761>08 5.8980E-11 Tus
$h Servi Water Pump liouse & Pipes 3.9767E-13 5.3740E-13 6.3590E-09 5.16961>10 14 uu i-
CERTIFICATE OF SERVICE I certify that I have served a copy of Vepco's Response to UCS Reply Brief on each of the persons named below by first-class mail:
Secretary U.S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION: Chief, Docketing & Service Section Daniel T. Swanson, Esquire U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Richard M. Foster, Esquire 1908-A Lewis Mountain Road Charlottesville, Virginia 22903 Anthony J. Gambardella, Esquire Office of the Attorney General Suite 308 11 South 12th Street Richmond, Virginia 23219 Alan S. Rosenthal, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Michael C. Farrar, Esquire Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, C C. 20555 Ellyn R. Weiss, Esquire Sheldon, Harmon & Roisman 1025 25th Street, N.W.
Suite 500 Washington, D. C. 20005
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D. C. 20555 By /s/ James N. Christman James N. Christman, Counsel for Virginia Electric and Power Company DATED: January 5, 1979
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- A
, UNITED STATES OF AMERICA NUCLEAR REGULA1 DRY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD c
In the matter of blC D(XJTggy PORTLAND GENERAL ELCTRIC
) Docket No. 50-344 0 Y COMPANY, ot al.
)
4 eg (Tmjan Nuclear Plant) )
( " " "U
/
I M J0 INT EXCEPTIONS TO PARTIAL INITIAL DECISION OF DECEMBER 21, 1978, OF THE ATOMIC S AFETY AND LICENSING BOARD The Coalition for Safe Power and the Consolidated Intervenors take exception to the Licensing Board's Partial Initial Decision of December 21, 1978 and state that the Board erred in finding or ruling thats (1) The matter of fire protection for interim operation was satis-factorily established. (Paragraphs 59, 60).
(2) The seismic qualification of safety-related equipment was satis-factorily established. (Paragraphs 55, 58, 60, 61, 79).
(3) An EIS is not required for interim operation. (Paragraphs 75, 77, 78).
(4) All safety problems concerning interim operation before the Board have been satisfactorily resolved. (Paragraph 60).
(5) Limited authority on design defiency issues is supported by Public Service Co. of Indiana, Inc. (Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-316, ' e 2 167,170-1 (19 76). (Paragraph 76).
(6) F; , , protection equipment wot.ld survive the SSE and remain functional in the event of a fire. (Paragraph 60).
(7) Allegations concerning the seismic qualification of equipnent in -
the Contml Building Complex were without merit. (Paragraph 60).
(8) The Licensee provided an additional panel whose testimony included a comprehensive review of safety-related equipment in the Control Building Complex. (Paragraph 57).
EXCEPTIONS - PAGE 1 7901230181
(9) The Staff's panel of witnesses all testified categorically that they know of no unresolved safetyissues, whether generic or plant-specific which have any bearing on the safety of interim operation of the Trojan facility and we find such testimony to be worthy of belief. (Paragraphs 60, 79).
(10) Need for Power has not only been disposed of in prior proceed-ings, but it has no place in this proceeding because of our determination that interim operation will not have any environmental effects that differ from those previously evaluated. (Paragraph 77).
(11) They did permit all intervenors to cross-examine fully on the nature, effect and ramifications of the identified design deficiencies, and no safity questions were left unexplored. (Paragraphs 57, 76, 79).
(12) The contributions of the building response mides were combined by the Square Root of the Sum of the Squares method rather than the Absolute Sum Value technique. (Paragraph 13(5)).
(13) The conservatives of the code interpretation were considered appropriate for comparison with Stick Model results but unnecessary for use with the accurate Stardyne analysis. (Paragraph 16).
(14) Bechtel engineers develo*p*ed a se't of criteria to evaluate the capacities of the shear walls in a more realistic manner. (Paragraph 17).
(15) Confidence in the structural integrity of the Control Building and the ability of the Building Structure to with stand safely the SSE is supported by consideration of a number of factors of conservatism inherent in the evaluations and analyses. (Paragraph 34).
(16) Higher damping would lead to smaller predicted forces, represent-ing a unaccounted for conservatism in all the analyses. (Paragraph 35).
(17) That substantial and convincing evidence was presented supporting the credible testimony of the Bechtel engineers and the PGE expert witnesses.
(Paragraphs'39, 40).
EXCEPTIONS - PAGE 2
. s. . . .
(18) Professor Laursen was a knowledgeable and convincing expert witness. (Paragraph 40) .
(19) The Control Building in its as-built condition and the Control Building, Auxiliary Building and Fuel Building Comples have adequate structural capacity and strength to withstand safely the licensed SSE of 0 25g during a period of interim operation. (Paragraph 41).
(20) Additions and modifications of a limited number of pipe supports or pipe restraints are required and the Licensee is performing the required modifications. (Paragraphs 55 and IV, 3).
(21) Other concerns of Intervenors and those raised in the Limited Appearance of Robert Pollard have already been considered, considered without merit, or satisfactorily resolved. (Paragraphs 78, 79).
(22) The Licensee's procedures for actions to be taken subsequent to a seismic event requiring shutdown are appropriate and adequete to provide for prompt notification. (Paragraph 71).
(23) The NRC Staff procedures for inspection of the f acility following shutdown after an earthquake are adequate to maintain safe conditions at the Facility. (Paragraph 71).
(24) The Facility can safely be brought to the cold shutdown condition after the occurence of any earthquake up to and including the SSE.
(Paragraphs 65, 67, 75).
(25) Modifications done during the period of interim operation and their effects on interim operation will be fully assessed. (Paragraph 74).
(26) Reduced capacity of the Control Building walls not adversely affect safety-related equipment within the Building Complex. (Paragraph 65).
Respectfully submitted, Dated this day, the 5th of January,1979. 7 '
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Eugene Rosolie Nina Bell Coalition for Safe Consolidated Intervenors
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Power EXCEPTIONS - PACE 3