05000259/LER-1981-026, Forwards LER 81-026/03L-0
| ML19257F088 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/25/1981 |
| From: | Green H TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19257F089 | List: |
| References | |
| NUDOCS 8106300188 | |
| Download: ML19257F088 (1) | |
| Event date: | |
|---|---|
| Report date: | |
| 2591981026R00 - NRC Website | |
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TECHNICAL EVALUATION REPORT I
HYDROLOGICAL. CONSIDERATIONS (SEP,C; 111,33}
II-3A 3
B.1, INSERVICE INSPECTION OF WATER CONTROL STRUCTURES CONSUMERS POWER COMPANY BIG ROCK POINT PLANT FRC PROJECT C5257 NRC DOCKET NO. 50-155 FRC ASSIGNMENT 16 NRC TAC NO. 41550 FRC TASK 542 l
NRC CONTRACT NO. NRC-03-79-118 Preparedby Author: J. Scherrer S. Roberts Franklin Research Center FRC Group Leader:
J. Scherrer 20th and Race Street Philadelphia, PA 19103 Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 Lead NRC Engineer: G. Staley June 23,1982 This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government ner any agency thereof, or any of their employees, makes any warranty, ex-pressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, apparatus, product or process disclosed in this report, or represents that its use by such third party would not infringe privately owned rights.
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TECHNICAL EVALUATION REPORT HYDROLOGICAL CONSIDERATIONS (SEP,C; III,3dj INSERVICE INSPECTION OF WATER CONTROL STRUCTURES B.L
- - p II-3A CONSUMERS POWER COMPANY BIG ROCK POINT PLANT FRC PROJECT C5257 NRC DOCKET NO. 50-155 FRC ASSIGNMENT 16 NRC TAC NO. 4t 70 FRC TASK 542 NRC CONTRACT NO. NRC-03-79-118 Prepared by Author: J. Scherrer Franklin Research Center S. Roberts 20th and Race Street FRC Group Leader:
J. Scherrer Philadelphia, PA 19103 Prepared for Nuclear Regulatory Commission Washington, D.C. 20555 Lead NRC Engineer: G. Staley June 23, 1982 This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, ex-pressed or implied, or assumes any legal liability or responsibility for any third party's use, or the results of such use, of any information, apparatus, product or process disclosed in this report, or represents that its use by such third party would not intringe privately owned rights.
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TER-C5257-542 CON"'ENTS Section Title Page 1
INTRODUCTION
1 1.1 Purpose of Review.
1 1.2 Generic Background.
1 1.3 Plant-Specific Background.
1 2
REVIEW CRITERIA.
2 3
TECHNICAL EVALUATION 3
3.1 Safety-Related Water Control Structures 3
3.1.1 Licensee Identification.
3 3.1.2 Conclusion.
3 3.2 Details To Be Inspected 4
3.2.1 Licensee Identification.
4' 3.2.2 Conclusion.
5 3.3 Inspection Program.
6 3.3.1 Inspection Report 7
3.3.2 Frequency of Inspection.
7 3.3.3 Conclusion.
7 4
CONCLUSIONS.
9 5
REFERENCES.
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TER-C5257-542 FOREWORD This Technical Evaluation Report was prepared by Franklin Research Canter under a contract with the U.S. Nucleat Regulatory Commission (Office of Nuclear Reactor Regulation, Division of Operating Reactors) for technical assistance in support of NRC operating reactor licensing actions.
The tecnnical evaluation was conducted in accordance with criteria established by the NRC.
Mr. J. S. Scherrer and Ms. S. L. Roberts contributed to the technical preparation of this report through a subcontract with WESTEC Services, Inc.
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INTRODUCTION
1.1 PURPOSE OF REVIEW The purpose of this review is to evaluate the assumptions, conclusions, and completeness of documentation in responses by Consumers Power Company (CPCo) for Systematic Evaluation Program (SEP) Topic III-3.C (Inservice Inspection of Water Control Structures) for the Big Rock Point Plant.
It includes independent analyses by the Franklin Research Center (FRC) needed to clarify or resolve issues. The Nuclear Regulatory Commission (NRC) is reviewing this ar.d other safety topics within the SEP and intends to coordinate an integrated assessment of plant safety af ter completion of the review of all applicable safety topics and design basis events (DBEs).
1.2 GENERIC BACKGROUND The SEP was established to evaluate the safety of 11 of the older nuclear power plants. An important element of the evaluation is to judge the plants cy current licensing criteria with respect to 137 selected topics, several of which relate to hydrologic assessments of the site.
In a letter dated January 14, 1981 [1], the NRC agreed to the SEP Owners Group's proposed redirecticn of the SEP whereby each licensee would select any 60% of the SEP topics and submit evaluations of these in time for a review by the NRC staf f to be completed by June 1981. Evaluations of topics not selected by a licensee were the NRC's responsibility. The Licensee (CPCo) chose to submit an evaluation for Topic III-3.C in accordance with the SEP guidelines.
1.3 PLANT-SPECIFIC BACKGROUND In a letter to the NRC dated December 21, 1981 (2), CPCo submitted an evaluation of Topic III-3.C comparing the water control structure inspection program for the Big Rock Point Plant with criteria currently used by the NRC staff for licensing new facilities.
In this report, the submitted documenta-tion is reviewed and the adequacy of the Licensee's evaluation is assessed.
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REVIEW CRITERIA The reference criteria used for this topic were based on the Code of Federal Regulations, Title 10, Part 50 (10CFR50), Section 50.36 and Appendix A (General Design Criteria 1, 2, and 44), and 10CFR100, including Appendix A.
Pertinent regulatory positions are identified in the following Regulatory Guides:
1.127 Inspection of Water-Control Structures Associated with Nuclear Power Plants [3]
1.27 Ultimate Heat Sink for Nuclear Power Plants [4]
1.28 Quality Assurance Program Requirements (Design and Construction) [5]
1.132 Site Investigations for Foundations of Nuclear Power Plants [6]
1.59 Design Basis Floods for Nuclear Power Plants [7].
The specific criteria against which the Licensee's submittal was evaluated are given in Regulatory Guide 1.127.
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TECHNICAL EVALUATION In the following evaluation, pertinent elements of the inservice inspec-tion program for water control structures at the Big Rock Point Plant are compared with the positions set forth in Regulatory Guide 1.127.
3.1 SAFETY-RELATED WATER CONTROL STRUCTURES 3.1.1 Licensee Identification The following water control structures and components associated with the Big Rock Point site were identified by the Licensee [2] as requiring surveil-lance in accordance with applicable NRC rules and Regulatory Guide ' 127:
A.
Cooling Water System structures The cooling water system structures identified are those relating to the availability and protection of the ultimate heat sink (UHS). They include the of fshore intake structure, the of fshece intake line, the screenhouse/ diesel generator room / discharge structure, the discharge canal, and the buried fire main piping system.
B.
Flood Protection Structures The Licensee has not identified any flood control structures at the Big Rock Point Plant [2].
3.1.2 Conclusion A.
Cooling Water System Structures Independent review corrborates the Licensee's selection of appropriate cooling system structures, with two exceptions:
o The f ailure of the discharge canal will not 1: event water from passing into the lake, and therefore will have no ef fect on the ability of the plant to shutdown.
Purther, although a riprap breakwater was constructed on the west side of the discharge canal, its failure would result only in gracual siltation of the discharge canal, and therefore it is not safety-related.
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TER-C5257-542 The buried fire main piping system need not be inspected under this o
specific inservice inspection proger.a. Although this system may be safety-related and may provide an overview for transfer of energency cooling water in some emergency situations, it does not f all under the guidelines of Regulatory Guide 1.127.
The intent of Regulatory Guide 1.127 is to include water control structures (d ams, levees, breakwaters, and conveyance facilities), the f ailure of which would
cause
a.
flooding of the site and safety-related equipment, or b.
loss of the ultimate heat sink, such as the emergency service water.
Since failure of the buried fire main piping system would cause neither of the above, it need not be inspected under this program.
B.
Flocad Protection Structures Independ :nt evaluation fcr this report confirms that no structures built for the purpose of flood protection exist at the Big Rock Point plant site.
However, certain site drainage features (the site drainage system) can prevent flooding of the site area.
3.2 DETAILS TO BE INSPECTED 3.2.1 Licensee Identificatig The following elements of the previously identified structures were identified by the Licensee [2] as appropriate inspection items:
A.
Cooling Water System Structures Inspection Element (s)
Frequency Structures to be Observed (proposed)
Offshore Intake Integrity of 5 years Structare wood vanes and steel structure Offshore Intake S11tation or 3 times a day Line blockage checked by water level in forebay 4_
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TER-C5257-542 Inspection Element (s)
Frequency Structures to be Observed (proposed)
Forebay of Integrity of the 5 years Screenhouse concrete structure Opening of Integrity of the Ibne identified offshore Intake opening of the Line offshore intake line Trash Rack Integrity of the Ibne identified Grating grating Accumulation of Ibne identified locse objects Traveling Accumulation Annually Screens of loose objects and Condition of None identified Components concrete Warm Water Integrity None identified Recirculation Line Screenhouse Settlement or None identified Foundation cracks in concrete Discharge Accumulation of None identified Canal sand or silt (Has been done twice in 5 years)-
B.
Flood Pro:ection Structures No flood protection structures exist at the Big Rock Point plant.
3.1.2 Conclusion A.
Inspection of Cooling Water System Structures and Components It is concluded:
1.
The of fshore intake structure should be inspected for settlement and tilt, in addition to integrity of the wooden vanes and steel structure.
2.
The interior of the of fshore intake structure should be inspected for deterioration and damage or structural integrity.
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TER-C5257-54 2 3.
The of fshore intake line should be inspected internally for damage, siltation, and buildup of sand and debris at least once every five years.
4.
The trash rack and traveling screens are features of safety-related water conveyance structures which prevent the buildup of debris which could otherwise preclude the flow of cooling water.
Since failure of the trash racks and traveling screens to perform their protection function could cause a loss of UHS, these features should be inspected.
Tne trash rack grating and the traveling screen should be subject to inspections, in addition to bi-hourly surveillances which are less specific than inspections and may be oriented toward other purposes than condition of cafety-related equipment.
5.
The forebay of the screenhouse should be inspected for siltation.
6.
The discharge canal need not be inspected since its failure will not preclude successful operation of the cooling water system.
7.
For all elements, a formal inspection program should be developed which defines the inspection frequency.
8.
Screenhouse should be inspected for exce.sive settlement, cracks, and structural integrity.
B.
Flood Protection Structures No flood protection structures exist at the Big Rock Point plant [8).
Should construction of any flood control structures be required during the integrated assessment process, those structures must be included in this inspection program.
3.3 INSPECTION PRO 3 RAM The Licensee has stated [2] that there is no formalized inspection program for water control structures incorporating the methods identified in Regulatory Guide 1.127 for the Big Rock Point plant. The Licensee has not stated that the preventive maintenance and periodic inspection programs are conducted or overseen by qualified engineering personnel. s-51. s-Frankhn Research Center A Dus.on W The Frermhn insmute
TER-C5257-542 3.3.1 Inspection Repor t Regulatory Guide 1.127 identifies the need to prepare inspection reporta following the inspection of safety-related water control structures.
These documents should be maintained on the site, for reference purposes.
The Licensee has stated, and the site vicit confirms, that drawings and inspection data or reports are available on the site. The Licensee has further stated that no formal inspection program for water control structures which satisfies Regulatory Guide 1.127 is underway at the Big Rock Point plant.
3.3.2 Frequency of Inspection The Licensee's informal inspections do not meet the intent of the inspection criteria identified in Regulatory Guide 1.127.
The Licensee should develop formal inspections to be conducted at a frequency which takes into consideration the consequences of failure of the structure and the frequency of the initiating event. Special inspections should be performed immediately af ter the occurrence of an event which challenges the integrity of the safety-related water control structure.
For the UHS, this implies that an inspection is necessary following significant buildup of ice or other debris, or an earthquake of specified intensity.
3.3.3 Conclusion Basec on the preceding evaluation, it is concluded that:
1.
The Licensee should formalize an inspection program for water control s tr uctur e s.
2.
The Licensee should develop comprehensive report forms to convey inspection information obtained by the field inspector to the appropriate inspection program manager.
3.
The Licensee should develop criteria by whien "special inspections" are initiated for the purpose of ascertaining the integrity of structures jeopardized by extreme environmental events.
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The Licensee should define the appropriata inspection frequency for all water control st.ructures with consid(er.3 tion given to the consequences of f ailure of those struct',res end the frequency of the events which Jeopardize the integrity of these structures.
5.
Inspections should be conducted under the supervision of a qualified engineer.
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TER-C5257-542 4.
CONCLUSIONS The Licensee has identified pertinent water control structures at the plant but has not developed a formal inspection program that conforms to Regulatory Guide 1.127.
The Licensee should formalize its present informal inspection program and incorporate the comments and criticisms contained in this report. Special consideration should be given to the followings o
The of fshore intake structure should be inspected for settlement or movement.
o The interior of the of fshore intake structure and the intake line should be inspected.
o The screenhouse should be inspected for settlement.
o The Licensee should develop comprehensive report forms to convey information obtained by the field inspector to the appropriate inspection program manager.
o The Licensee should develop criteria to initiate "special inspections" to a scertain the integrity of structures jeopardized by extreme environmental events.
o The License should define inspection frequencies, o
Inspections should be made under the supervision of a qualified engineer.
Following initiation of these recommended changes, the inservice inspection for water control structures underway at the Big Rock Point plant will satisfy the intent of Regulatory Guide 1.127.
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REFERENCES 1.
D. G. Eisenhut (NRC)
Letter to all SEP Licensees January 14, 1981 2.
R. A. Vincent (CPCo)
Letter to D. M. Crutchfield (NRC)
December 21, 1981 3.
" Inspection of Water-Control Structures Associated with Nuclear Power Plants" NRC, March 1978 Regulatory Guide 1.127 4.
" Ultimate Heat Sink for Nuclear Power Plants" NRC, January 1976 Regulatory Guide 1.27 5.
" Quality Assurance Program Requiretoents (Design and Construction)"
NRC, March 1978 Regulatory Guide 1.28 6.
" Site Investigation for Foundations of Nuclear Power Plants" NRC, March 1979 Regulatory Guide 1.132 7.
" Design Basis Floods for Nuclear Power Plants" NRC, August 1977 Regulatory Guide 1.59 8.
Big Rock Point Plant, Final Safety Analysis Report Consumers Power Company Docketed November 14, 1961 9.
Site Visit Report J. Scherrer, W. Erickson Big Rock Point Plant, Charlevoix, MI May 20, 1982 gS a.J Franklin Research Center a won w n r,.n.a.n in.mo.