ML19283B692
| ML19283B692 | |
| Person / Time | |
|---|---|
| Site: | 05000502 |
| Issue date: | 02/06/1979 |
| From: | Parr O Office of Nuclear Reactor Regulation |
| To: | Burstein S WISCONSIN ELECTRIC POWER CO. |
| References | |
| NUDOCS 7903060613 | |
| Download: ML19283B692 (34) | |
Text
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UNITED STATES 3 Na f' S NUCLEAR REGULATORY CCMf.81sSION NRC PDR W ASHINGTON, D. C. 20555
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Docket flo. STtl 50-502 Mr. Sol Burstein Executive Vice President Wisconsin Electric Power Company 231 West Michigan Street Milwaukee, Wisconsin 53201
Dear Mr. Burstein:
SUBJECT:
REQUEST FOR ADDITI0tlAL IrlFORMATI0tl C0tiCERillflG THE HAVEtt flVCLEAR PLAtlT, UtlIT 1 As a result of our review of the Haven 1 Preliminary Safety Analysis Report, we find that we need additional information to continue our evaluation.
The specific information required is listed in Enclosure 1.
Our review schedule is based on the assumption that the additional information requested will be available for our review by April 2, 1979.
If you cannot meet this date, please inform us within seven days after receipt of this letter so that we may consider the need to revise our review schedule.
Several responses to our first round questions have not been received to date.
Some of these responses are expected to be included in your February amendments to the WUP PSAR and the Haven Site Addendum. lists the first round questions for which responses have not been received.
You can expect further requests for additional information subsequent to the receipt and review of these responses.
Please contact us if you desire any discussion or clarification of the enclosed material.
Sincerely, hk 19. A_
an D. Parr, Chief Light Water Reactors Branch flo. 3 Division of Project Management
Enclosures:
As Stated cc w/ enclosures:
See next page
.i Mr. Sol Burstein FEB 0 61979 cc:
Gerald Charnoff, Esq.
Mr. William Charles Hanley Shaw, Pittman, Potts & Trowbridge President, Safe Haven Ltd.
1800 M Street, N. W.
P. O. Box 40 Washington, D. C.
20036 Kohler, Wisconsin 53044 Robert H. Gorske, Esq.
Mr. Thomas Galazen General Counsel Northern Thunder Wisconsin Electric Power Company Box 334 780 North Water Street Turtle Lake, v.'isconsin 548f Milwaukee, Wisconsin 53202 A. William Finke, Esq.
Senior Attorney Wisconsin Electric Power Company 331 West Michigan Street Milwaukee, Wisconsin 53201 Thomas A. Lockyear, Esq.
Assistant Chief Counsel Public Service Commission of Wisconsin Hill Farms State Office Building 4802 Sheboygan Avenue Madison, Wisconsin 53702 Mr. Richard L. Prosise Bureau of Legal Services Department of Natural Resources Box 7921 Madison, Wisconsin 53707 David Beckwith, Esq.
Foley & Lardner 777 East Wisconsin Avenue Milwaukee, Wisconsin 53202
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i EtlCLOSURE 1 REQUEST FOR ADDITIONAL I!!FORMATI0ti PART I - WISCONSIfl UTILITIES PROJECT PSAR
. i 110.0 MECHAfilCAL EtlGIfiEERIflG BRA!1CH 110.18 The exception taken to position C.2.a.(2) and C.2.a.(4) of (App. B)
Regulatory Guide 1.121 in Appendix B, Section D.6 of the PSAR (RSP) is unacceptable. The requirement for a 300 percent margin against burst failure based on normal operating pressure differential must be satisfied for all types of defects.
This margin of safety may be demonstrated either analytically or experimentally.
Test data submitted by Westinghouse for certain types of through wall defects has indicated that additional margin remained in the tube beyond the point where bulging occurs. A lower margin of safety may be applicable to this test data, provided it is shown that the remaining strength beyond bulging to gross rupture provides an equivalent margin of safety as required in Psegulatory Guide 1.121.
Therefore, provide additional information that substantiates the equivalency of the Westinghouse 200 percent margin, based on Westinghouse performed tests, to the 300 percent margin required by the Regulatory Guide which utilizes a somewhat less conservative definition of tube failure.
This equivalency must be justified for all types of tube defects.
110.19 The information presented in Appendix B, Section D.22 is (App. B) acceptable for ferritic bolts only. However, Section D.22 should address Regulatory Guide 1.124, Revision 1, dated Jan. 1978 rather than the flovember, 1976 issue. Therefore, revise Section D.22 to include an assessment of Revision 1 of Regulatory Guide 1.124.
110.20 Exceptions flo. 1, 2, 8, 9,10,11 and 12 in Appendix B, Section (App. B)
D.23 are not completely acceptable.
Conformance to the rules (RSP) of AStiE Section III only provides assurance of the structural integrity of a component and does not necessarily quarantee the operability of an active component.
Therefore, merely requiring deformation limits of a support structure in the Design Specifications may not assure that the supported active component will remain operable under all loading conditions.
The staff position on deformation is that as a minimum, the support for an active component, i.e., a component required for safe shutdown of the plant or to mitigate the consequences of an accident, should not deform to the extent that the operability of the active component is impaired.
Further, the fact that the words "most adverse" and " normal functior" may not be well defined or may be ambigious is not, in the staff's opinion, acceptable justification for deleting entire sections of Regulatory Guide 1.130.
Revision 1 of Regulatory Guide 1.130 dated October,1978 may satisfy some of the concerns expressed
=-u=--
110-2 in Section D.23 of the PSAR.
Therefore, revise Section 0.23 by either committing to the positions in Regulatory Guide 1.130, Revision I which are associated with the above noted exceptions, or by providing sufficient design criteria to assure the staff that the above staff position on deformation of supports will be satisfied.
110.21 Exceptions No. 5 and 7 in Appendix B, Section D.23 of the PSAR (App. B) are unacceptable.
As implied in Position C.3 of Regulatory (RSP)
Guide 1.130, Revision 1, the s!.aff position is that for normal and upset plant condition loads, the Level A and B service limits are 50% of the critical buckling strength for flat plates and 33% of the critical buckling strength for shells.
For loads associated with the faulted plant condition, the Level D service limits should not exceed the limits specified in ASME Appendix F, of the critical buckling strengths for shells, unless justified by acceptable analysis and/or testing.
Revise Exceptions 5 and 7 to include a commitment to the above position.
121.0 MATERIALS ENGINEERING BRANCH - MATERIALS INTEGRITY SECTION 121.10 Table 5.2-7 of the PSAR lists Reactor Coolant Pressure (5.2)
Boundary Materials for Class 1 Primary Components.
List the specific location (s) for any ferritic material of pressure-retaining components of the reactor coolant pressure boundary, other than:
(1)
Carbon, and low alloy ferritic steel pipe, forgings, castings, and pipe with specified mininum yield strengths not over 50,000 psi; (2) Welds and weld heat affected zones in the materials specified in (1) above; (3) Materials for bolting and other types of fasteners with specified minimum yield strengths not over 130,000 psi.
121.11 The response to Question 121.9 is not adequate.
Your (5.2.4) response stated that "the requirements of Appendices G (5.4.3) and H of 10 CFR Part 50 are met as discussed throughout (RSP)
Sections 5.2.4 and 5.4.3" of the WUP PSAR and that "there are no areas of non-compliance" with these requirements.
The information contained in Sections 5.2.4 and 5.4.3 is not adequate enough to determine if all of the requirements of these appendices will be met.
It is our position that you make a commitment to fully comply with all of the requirements of Appendices G and H of 10 CFR Part 50.
214.0 REACTOR SYSTEMS BRANCH 214.37 The response to question 214.35, concerning equipment to (5.2.2) mitigate low-temperature overpressurization events, indicates (RSP) that exception may be taken to the system design requirements of IEEE 279 which are specified in our psition. The response does not provide information identifying the exception (s), nor does it provide justification for the exception (s). Therefore, we require that any exception to IEEE 279 be identified and justified.
214.38 In the response to question 214.35, you propose a probabilistic (5.2.2) evaluation of equipment to mitigate low-temperature over-(RSP) pressurization events in lieu of meeting OBE criteria.
Such a probabilistic assessment to satisfy our seismic criteria is unacceptable. We require that you comply with the seismic qualification provision of the position.
214.39 The response to question 214.36, concerning the capability (5.5.7) to achieve and maintain cold shutdown, did not address the (RSP) following criteria:
(1) The plant must be capable of achieving RHR operational conditions in about 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (assuming the worst single failure and loss of offsite power).
(2) Test results specifically justifying the adequacy of boron mixing under natural circulation (assuming the worst single failure and loss of offsite power) must be provided.
Discuss how you will satisfy these criteria.
214.40 Inadvertent mispositioning cf some emergency core cooling manual (6.3) valves could compromise system performance. We require control (RSP) room position indication for any manually operated emergency core cooling valve which, if kept in an incorrect position, would compromise system performance.
Discuss your plans to satisfy this requireme'nt.
214.41 Following a steam line break and subsequent safety system (15.1.5) response, reactor cooldown, and pressurizer refill, operator (RSP) action may be necessary to prevent compromising reactor vessel integrity because of potential operation in an unacceptable pressure / temperature regime.
We require that any manual actions (without credit before 10 minutes) be identified, and reflected in analyses predicting acceptable consequences.
Discuss your plans to satisfy this requirement.
214-2 214.42 We require assurance that the emergency core cooling pumps (5.4.6, will perform their safety functions for an extended period 5.4.7, of time following a loss-of-coolant accident under environmental 6.3) conditions that prevail.
Discuss your plans to satisfy this (RSP) requirement.
214.43 Safety related systems should be protected against loss of (3.5.1) function due to internal missile impact.
Pressurized components and rotating machinery are potential internal missile sources.
These include the vessel seal ring and valve stems.
Discuss your plans to consider valve stems, gravity missiles, and seccndary missiles in the Haven design.
222.0 POWER SYSTEMS BRANCH 222.6 Your response to qualification review item D-35, position 3 (8.3) is inadequate in its present form.
Revise your technical (RSP) specification to include requirements for tests as set forth in our position 3, to demonstrate the full functional operability and independence of the onsite power sources once per 18 months during shutdown.
222.7 Your design of penetration overload protection is inadequate (8.3) and therefore your response to qualification review item D-ll (RSP) is incomplete. We require that the following requirements of IEEE-279 should be satisfied with regard to the protection of the electrical penetrations:
(1) All source and feeder breaker overload and short circuit protection systems are qualified for the service environment including seismic.
The seismic qualification for non-Class lE circuit breaker protection systems shiuld as a minimum assure that the protection systems remain operable during an operating basis earthquake.
(2) The circuit breaker protection system trip set points must have the capability for test and calibration.
Provisions for test under simulated fault conditions should be provided.
' (3) No single failure shall cause excessive currents in the penetration conductors which will degrade the penetration seals.
(4)
Signals for tripping source and feeder breakers shall be independent, physically separated and powered from separated sources.
Modify your design to include the above requirements.
222.8 Section 8.2 of the WUP PSAR and the Haven Site Addendum discuss (8.2) the possible use of a combustion turbine generator.
You state that, "The combustion turbine generator is not a safety related source of electric power.
It is considered to be an offsite power source."
You also state that, "this unit would be used as a backup supply to plant auxiliary loads, for black plant startup, system peaking, and standby reserve."
Please respond to the following questions concerning the combustion turbine generator:
F
222-2 (1) Section 16.3.6.5 of the WUP PSAR (Technical Specifications) states that the reactor shall not be made critical unless several conditions are met.
One of these conditions is that two or more 345 kV transmission lines are in service.
Explain how the combustion turbine generator could be utilized for a black plant startup when your proposed technical specifications prohibit this type of startup.
(2)
If the combustion turbine generator is going to be used as an "offsite power source" for the safety related buses, provide the following additional information for the unit:
(a) The intended modes of operation, including the circumstances under which it will provide "offsite power";
(b)
If known, the rating and specifications of the unit; and (c)
If known, the testing which will be performed to assure its reliability.
(3) Discuss the effect or provide assurance that the combustion turbine generator when operating and connected to the 69 kV bus will not effect the stability or reliability of the preferred source of offsite power.
i 241.0 CORE PERFORMANCE BRANCH - REACTOR FUELS SECTION 241.3 In your reply to item A.2.(c) of our Qualification Review letter, your steady-state performance evaluation, (4.2.1.3.1) calculations are performed using the improved Westinghouse (RSP) analytical model, PAD-3.3.
Our approval of this model, which will be the subject of separate correspondence, incorporates some restrictions for its application.
Therefore, provide a commitment that the steady-state performance evaluation for the Haven FSAR will be performed using the approved version of WCAP-8720 that will incorporate these restrictions.
241.4 In your reply to item A.2.(a) and D.31 of our (4.2.1.3.1)
Qualification Review letter, concerning fuel rod (RSP) bowing, WCAP-8346 and WCAP-8692 are listed as references.
In our letter from J. Stolz (NRC) to T. Anderson (W) dated June 19, 1978, we state that WCAP-8692 is no longer adequate for referencing and needs to be revised.
WCAP-8346 had been previously withdrawn.
Two interim procedures are available for treating the effects of rod bow on critical heat flux:
(1) an acceptable model as described in an NRC memo-randum from D. F. Ross and D. G. Eisenhut to D. B. Vassallo and K. R. Goller, dated February 15, 1977, (a copy of which will be forwarded to you under separate cover) and (2) procedures that can be used by an applicant as given in a letter from J. Stolz (NRC) to T. M. Anderson (W)~, dated June 19, 1978.
The effects of rod bow should be evaluated for the Haven FSAR using one of these methods or a method that might be developed by Westinghouse and approved by NRC.
241.5 The analysis of asymmetric LOCA loads has been pre-(4.2) viously discussed in Qualification Review item D.41.
(RSP)
Loads trom seismic and LOCA events are being reviewed by NRC as generic tasks (A-2 and B-6, NUREG-0371).
Since no plant structures would be affected by the outcome of this analysis, the results of an analysis that show that the fuel assemblies can withstand this phenomenon and that coolable geometry is maintained should be provided in the FSAR.
For the CP review, we only require that Wisconsin Electric Power commit to address this issue and provide the analysis in the Haven FSAR.
331.0 RADIOLOGICAL ASSESSMENT BRANCH 331.28 Describe precautions taken to prevent inadvertent personnel (12.1.2) access during fuel transfer to the very high radiation areas in the vicinity of the fuel transfer tube.
If there is sufficient permanent shielding to assure acceptable levels in adjacent, potentially occupied areas, provide diagrams of that shielding.
331.29 Provide information concerning action taken to maintain (12.1.2) occupational radiation exposure as low as is reasonably achievable by minimizing and controlling the buildup, transport and deposition of activated corrosion products in reactor coolant and auxiliary systems.
Include as a minimum,information on the following steps taken to minimize Co-58 and Co-60, including:
(1) The use of reduced nickel in primary coolant system alloys.
(2) Low cobalt impurity specifications in primary coolant system alloys.
(3) The minimization of high cobalt, hard facing wear materials in the primary coolant system.
(4) The use of high flow rate /high temperature filtration.
(5) The selection of valves and packing materials to minimize crud buildup and maintenance.
(6) Provisions of decontamination of reactor coolant components and systems.
411.0 QUALITY ASSURANCE BRANCH - OA SECTION 411.17 The response to question 411.14 is incomplete.
It is the (APPA) staff's position that the PSAR for the Haven Nuclear Plant (17.1) must include a commitment to:
(RSP)
(1)
Comply with the requirements of ANSI N45.2.5 (Draf t 3, Rev.1, January 1974) or meet the regulatory position of Regulatory Guide 1.94 (April 1975 or April 1976);
(2) Comply with the requirements of ANSI N45.2.8 (Draf t 3, Rev. 3, April 1974) or meet the regulatory position of Regulatory Guide 1.116 (June 1976 or May 1977);
(3) Comply with the requirements of ANSI N45.2.12 (Draft 3, Rev. 4, February 1974); and (4) Comply with the requirements of ANSI N45.2.13 (Draft 2, Rev. 4, April 1974) or meet the regulatory position of Regulatory Guide 1.123 (October 1976 or July 1977).
Please provide such commitments or propose alternatives for the staff's evaluation.
We note, too, that page 17.1-12a still refers to ANSI N45.2.13-1974. This reference should be changed to agree with item "4" above.
411.18 The proposed exception / modification relating to position C.l.b (APP A) of Regulatory Guide 1.38 (page A.1-ll of the PSAR) is unacceptable.
(RSP)
It is the staff's position that rerating of hoisting equipment should be done in accordance with the Regulatory Guide unless adequate justification (e.g., an appropriate discussion and analysis of design margin) is provided.
Please delete the proposed exception / modification or provide such justification.
F
4 412.0 QUALITY ASSURAtlCE BRAf1CH - C0t1 DUCT OF OPERATI0ilS 412.5 You indicate in your answer to question 41.1 that the plant (13.1.2.3) staff numbers shown in Figure 13.1-3 are for two unit operation. Therefore, since the Haven site is a single unit, please update Figure 13.1-3, and other areas if needed, to reflect that fact.
432.0 ACCIDENT ANALYSIS BRANC!! - EMERGENCY PLANNING SECTION 432.10 In your discussion of Fire Emergency on page (13.3.4.2) 13.3-4, your plans would appear to exclude offsite fire fighting support from restricted areas.
Please clarify your intent in this regard.
REQUEST FOR ADDITI0ilAL IrlFORMATI0il PART II - HAVEtt SITE ADDEtlDUM
321.0 HYDROLOGY / METEOROLOGY BRANCH - HYDROLOGY SECTION 321.3 Section 2.4.3 - Describe in detail the provisions for flood (2.4.3) protection onsite from water levels greater than 610 feet mean sea level, which you refer to in the first paragraph of page 2.4.12, amendment 16.
321.4 Sections 2.4.13 and 3.8.5.1 - There is an apparent conflict (2.4.13) between statements made in these two sections concerning (3.8.5) design basis groundwater levels.
Section 2.4.13 states that the design basis groundwater level will be taken to be plant grade.
Section 3.8.5.1 however, briefly describes an underdrain system which has as one of its stated purposes the reduction of hydrostatic forces on the containment.
If credit is taken for the underdrain system in any structural calculation, it niust be considered safety-related.
If this is the case, please address the Branch Technical Position on Safety Related Dewatering Systems (attached) which is an appendix to the Standard Review Plan 2.4.13, revision 1 (NUREG-75/087).
321.5 Section 2.4.7 and 9.2.5 - Ice-related effects on the Great (2.4.7)
Lakes are of sufficient concern that any safety-related (9.2.5) water supply must be carefully evaluated.
The hydrologic description of ice effects covered in section 2.4 admits to severe shore icing, but does not account for the possibility of windrowed ice far from shore.
Such deep ice far from shore can and does occur in the Great Lakes, even in depths of 30 feet or more.
Ice piles have been observed in Lake Erie one mile from shore extending to the bottom in 26 feet of water.
We believe that you have not documented the capabii:ty of safety-related intakes in Lake Michigan to withstand the effects of severe icing conditions.
Indicate the provisions to prevent blockages of your intakes by large quantities of frazil or floating ice, and the protection of the intake from forces caused by ice piles.
Alternately, discuss a source of cooling water other than offshore intakes for the ultimate heat sink.
321.6 Sections 2.4.7 and 9.2.5 - Describe the modifications to the (2.4.7) ultimate heat sink under the conversion to a one unit facility.
(9.2.5)
Specifically, will one of the offshore intakes be eliminated?
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BRANCH TECHNICAL POSITIONS HMB/GSB 1 SAFETY-RELATED PERMANENT DEWATERIZ SYSTEMS Suma ry This position has been fomulated to minimize review problens comon to pemanent dewater-ing systems that are depended upon to serve safety-related purposes by describing accept-able geotechnical and hydrologic engineering design bases and criteria. A safety-related designation for pemanent dewatering systems is provided since they protect other safety-related structures, systems and components from the effects of natural and man caused events such as groundwater. In addition, the level of documentation of data and studies which are considered necessary to support safety-related functions is defined. This position applies to both active (e.g., uses pumps) and passive (e.g., uses gravity drains) dewatering systens. This position does not reflect structural, cechanical and electrical criteria.
II. Backorcund The staff has reviewed a ntnber of pemanent dewatering systems, including McGuire 1 & 2 Cherokee 1 & 2, Perkins 1 & 2, Perry 1 & 2. WPPSS 3 & 5. Dcuglas Point 1 & 2 and Catawba 1
& 2.
Perry, beginning in 1975, was the first plant reviewed with such systens, and was reviewed very late in.the f.P process. Only WPPSS 3 & 5 and Douglas Point use a passive systen (no pumps).
Pemanent dewatering systems lower groundwater levels to reduce subsurface water loads on plant structures. In addition, they can increase plant operational dependability and reduce costs. These effects are accomplished by providing added means of keeping seepage water out oi lower building levels during the later stages of plant life when nomal water-
. proofing provisions may have deteriorated, and reducing radwaste systen operating costs by ninimicing.the amcunt of drain water that raust be treated. Benefits are, therefore, of two types, tangible (dollars) and intangible (" insurance"). We understand the construction costs of underdrains can vary widely depending on the design..Ccnstruction costs of between
$125K to $1000K per unit have been suggested. The costs of coping with significant amcunts of groundwater inleskage in safety-related building areas, which underdrains are expected to minimize, is estimated to be in the range of $1CCK to $2CCK per year per reactor. The construction costs of alternatives to underdrains for structural purposes alene (exclusive of inleakage treatment) is estimated to range upward frcm $3CCK per unit and is highly dependent on site conditions. Structural alternatives to perranent underdrains include additional concrete and steel in the ivwer portions of buildings, and the use of anchor systems to resist floatation.
Cewatering systems are generally composed of three components; the collector system, the drain system, and the discharge systen. Water is first collected in collector drains 2.4.13-9 Rev. 1 I
aJJaan to taut idine n esca,ations. Interceptor drains or piping are then used to convey
,[ttiswatertoafinaldischargesystem. The discharge system can te either gravity flow
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' or a ymplng system. Most t.nderdrain structures, systems and components are buried along-side and under structures, although sone systems employ pumping systems within larger structures (such as reactor or auxiliary buildings) to discharge collected water. Finally, permanent dewatering systems are not a required feature at any plant, but may be proposed as a cost effective feature.
Many permanent dewatering systems at nonnuclear facilities, such as dams and large build-ings, have functioned over the years. However, the likelihood of a portion of such a system becoming ineffective and, therefore, not perfoming its intended function may well be considerably greater than the probability of occurrence of a nuclear poner plant design basis event such as a Probable Maximum Hurricane, Probable Maximum Flood, or Safe Shutdown Earthquake. Losses of function in the past have generally been attributable to piping of r
fines, inadequate capacity, or clogging. We have concluded that safety analyses of such systems should consider reliability and failures of features of the system itself, as well as potentially adverse effects of failures of nearby nonsafety-related features.
Such systems need not be designed for design earthquakes if they are not intended to perfom as underdrains fully during or imediately following a severe earthquake, or if the system can be expected to perform an underdrain function in a degraded condition. Certain portions of such systems, however, may be required to regularly perform other safety functions (e.g., porous concrete base mats) and should be designed for severe earthquakes. Failure of a dewatering system could cause groundwater levels to rise above design levels, resulting in overloading concrete walls and mats not designed to withstand the resulting hydrostatic pressures. In addition to causing potential structural and equipment damage, groundwater could enter safety-related buildings and flood components necessary for plant safety.
The basis for staff concerns over the use of such systems is whether they can be expected to perfom their function, and prevent structural failures and interior flooding of safety-related structures. The degree of concern is directly related to the corresponding degree to which the safety of the structures and systems rely on the integrity of the dewatering sy' stem, particularly with a dewatering system in a degraded situation. For example, if structures can accomodate hydrostatic, loads that would result with a total failure of a dewatering system, our concerns have been primarily limited to the capability of such systems to perform their functions under relatively infrequent earthquake situations.
If, however, such systems must retain functional (e.g., keep water levels down), whether in a degraded situation or not to prevent structural failures and internal flooding under potentially frequent conditions, we have been very concerned with system reliability.
Many applicants have indicated that their plants can withstand, or have been designed against, full hydrostatic loadings that would occur in the absence of the underdrain systems, but not if an earthquake were to occur. If the plant can withstar.d full hydrostatic loading, assuming degradation of the underdrain system, many of the staff's concerns may be eliminated from further consideration tecause of the time available for remedial action af ter detection of system degradation.
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2.4.13-10
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!!!. $ltuations Ide tified During Pr vious Rev ews Four gpneral categories of situations have been identified during case reviews as follows:
(a) Estimating and Confirming Permeability Values It is necessary to estimate the amount of water that will be collected so that system components such as strip drains, blanket drains, collector pipes, and pu ps are ade-quately designed and sized. One of the most important and most difficult parameters to evaluate is the permeability of the soil and rock existing at a site. A per.
meability value could be affected significantly by conditions of concentrated flow along joints in fractured and weathered rocks, or within other aquifers affected by foundation excavation. In addition, geological and foundation conditions that were not detected in site explorations may affect flow conditions and cause the estimated perreability values and flow regimes to be substantially different from those assumed at the CP preliminary design stage. These conditions are of ten first detected during construction dewatering. Therefore, we have required a corriitment to consider con-struction excavation and dewatering data in the final design of underdrain systems.
(See situation (d) below.)
(b) Operational Monitoring Requirements To guard against system malfunctions and to assure sufficient time is available for implementation of remedial measures before groundater could rise to an unacceptable level, provisions must be made for early detection of system failures, and contingency rneasures for these failures must be well defined prior to plant operation. Since drain systems are usually buried and concealed and there may be no direct way of inspecting them, reliance must be placed on piezometers, observation wells, manholes, and monitoring of collected water to detect problems or malfunctioning of the system.
The details of an operational monitoring program are necessary prior to construction of the underdrain to assure that each of the following will be provided: (a) an early detection alarm system during nomal operating conditions; (b) regularly scheduled inspection and monitoring; and (c) competent evaluation of observations during both construction and operation. In addition, the bases for acceptable contingency measures suitable for coping with various possible hazards must te established at the Cp stage.
(c) Pipe Brens A dewatering system might be overloaded by such conditions as leaks or breaks in either the circulating or service water systems. A leak through a pipe break may te a very small percentage of the total flow of the cooling water system, but large enough to exceed the hydraulic capacity of drains, pipes and pumps in the dewatering system. For example, a complete failure of circulating water system piping has been required in the design of the dewatering systems reviewed to date. This require'ent was made to assure that such abnormal occurrences do not adversely af fect the integ-rity of safety-related structures, systems, and components.
(d) Seauence of Review Underdrain systems are usually one of the first items constructed and, after back-filling and construction of subsurface facilities, are then no longer visible for 2.4.13-11 Rev. 1 T
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, regula,r inspection. In most cases, these systems are in'itially designed based on rather limited information from preconstruction field activities, and are tailored specifically for the site and facilities. By necessity then, final review and approval by the staff of the design must rely in some part on information gathered during construction. Therefore, the review and approval can be acco:rplished in two ways:
(1) design details of the permanent underdrain syste9, the operational monitoring program and plans for construction dewater,ing can be submitted in the PSAR with only con-firmation of the details required prior to actual construction; or (2) conceptual designs of the permanent underdrain system and the operational monitoring program and details of construction dewatering can be submitted in the PSAR with the more complete review and approval based on construction dewatering requiring. review and approval prior to actual construction. Review and approval of unique designs as post-CP rutters is based upon 10 CFR Part 50, Subsections 35(b) and 55(e)(1)(iii). To prevent extending the review schedule, the first procedure would be the most desirable, but the staf f recognizes that the detail required may not always be avail-able at the time the PSAR is submitted.
5 IV. Proposed Staff Position We have reviewed and approved the design of a limited number of permanent dewatering systems. However, because of the importance of these systems to plant safety, we have always required that they be designed and used in a conservative manner. The following is a list of required design provisions which are consistent with requirements in recent CP reviews:
(a) if the dewatering system is relied upon for any safety-related function, the system snust meet the appropriate criteria of Appendix A and Appendix B to 10 CFR Part 50.
In addition, guidance for structural, mechanical and electrical design criteria is provided in related sections of the Standard Review Plan for Category
- structures, systems and components. However, all portions of the system need not be designed to accomodate all design basis events, such as earthquakes and tornados, provided that
- such events cannot either influence the system, or that the consequences of failure from such events is not important to safety; nevertheless, a clear demonstration of the effectiveness of a backup system and the timeliness of its implerentation must te provided; (b) the potential for localized pressures developing in areas which are not in centact with the drainage system, or in areas where pipes enter or exit the structural walls or mat foundations, must be considered.
(c) uncertainty in detecting operational problems and providing a suitable monitoring system must be considered; (d) the potential for piping fines and clogging of filter and drainage layers must be considered; Rev. 1' 2.4.13 12 k
t
(e) assurance must be provided that the system as proposed can be expected to reliably perform its function during the lifetime of the plant; and (f) where the system is safety-related, is not totally redundant or is not designed for all design basis events, provide the bases for a technical specification to assure that in the event of system failure, necessary rerredial action can be implemented before design basis conditions are exceeded.
V.
SAR's (Std. Format & Content Infomation, Sections 2.4 & 2.b) for each of the plants with pemanent dewatering systems should include the following infomation:
(a) Provide a description of the proposed dewatering system, including drawings showing the proposed locations of affected structures, components and features of the system.
Provide information related to the geotechnical and hydrologic design of all system components such as interceptors, drainage blankets, and pervious fills with descrip-tions of material source, gradation limits, material properties, special construc-tion features, and placement and quality control measures. (Note structural, mechanical and electrical information needs described elsewhere.) Where the dewater-IV.
ing system is important to safety, provide a discussion of its expected functional reliability. The discussion of the bases for reiiability should include comparisons of proposed systems and components with the performance of existing and comparable 3ystems and components for applications under site conditions similar to those proposed.
Where such infomation is unavailable or unfavorable, or the application (design and/or site) is unique, the unusual features of the design should be supported by additional tests and analyses to demenstrate the conservative nature of the design.
In such cases the staff will meet with the applicant, on request, to establish the bases for such additional tests and analyses.
(b) Provide estimates, and their bases, for soil and rock penneabilities, total porosity, effective porosity (specific yield), storage coefficient and other related parameters used in the design of the dewatering system. In general, these site parameters should be detemined utilizing field and, if necessary, laboratory tests of materials representative of the entire area of influence of the expected drawdown of the system.
Unless it can be substantiated that aquifer rioterials are essentially homogeneous, or tnat cbviously conservative estirates nave been used as design bases, provide pre-construction pumping tests and other in-situ tests perfomed to estimate the pertinent hydrologic parameters of the aquifer. Monitoring of purping rates and flow patterns during dewatering for the construction excavation is also necessary to verify assured design bases relating to such factors as permeability and aquifer centinuity. In addition, the final design cf the system should be based on construction dewatering riata and related observations to assure that the values estimated from site exploration data are conservative. Lastly, the final design of the dewatering system and its hydrologic and geotechnical cperational monitoring program should be confirmed by construction excavation and dewatering information.
2.4.13-13 Rev. I F
T
e
- !( sudr infontatforrfa111 to'tuppornhe cons ~erVatisin'of d'est'gn"information previously f
,revi'ewed by the staff, the changed information should be reviewed under 10 CFR
'Part 50, Subsections 35(b) and 55(e)(1)(lii).
(c) Provide analyses and their bases for estimates of groundwater flow rates in the various parts of the permaneat dewatering system, the area of influence of drandown, and the shapes of phreatic surfaces to be expected during cperation of the system. The extent of influence of the drawdown may be especially important if a natural or man-made water body affects, or is affected by, the dewatering systems.
(d) Provide analyses, including their bases, to estaolish conservative estimates of the time available to mitigate the consequences of system degradation
- that could cause groundwater levels to exceed design bases. Document the measures that will be taken to either repair the system, or provide an alternate dewatering system that would
^
become operational before the design basis groundwater level is exceeded.
4 (e) Provide both the design basis and nortnal operation groundwater levels for safety-related structures, systems and components. The design basis ground. vater level is defined as the maximum groundwater level used in the design analysis for dynamic or static loading conditions (whichever is being censidered), and may be in excess of the elevation for which the underdrain system is designed for nor al operation. This level should consider abnormal and rare events (such as an occurrence of the Safe Shutdown Earthquake (SSE), a failure of a circulating water system pipe, or a single failure within the system). which can cause failure or overloading of the permanent dewatering system.
(f) A single failure of a critical active feature or component must be postulated during any design basis event. Unless it can be documented that the potential consequences of the failure will not result in Regulatory Guides 1.26 and 1.29 dose gaidelines being exceeded, either (1) document by pertinent analyses that groundwater level -
recovery times are sufficient to allcw other forms of dewatering to be implemented before the design basis groundwater level is exceeded, discuss the reasures to be implemented and equipment needed, and identify the amount of tire required to accomplish each reasure, or (2) design for all system components for all severe natural phenomena and events. For example, if the design basis groundoater level can be exceeded only as a result of a single nonseismically induced failure of any component or feature of the system, the staf f may allow the design basis level of the dewatering system to te exceeded for a short period of time (say 2 or 3 days), provided that (1) effective alternate denatering reans can be implemented within this time period, or that (2) it can be shown that Regulatory Guides 1.26 and 1.29 guidelines will not be exceeded by groundwater induced impairments of safety-related structures, systems, or components.
- See (f) for considerations of differing system types.
Rev. Is 2.4.13-14 k
F
p1.
l J
(c,) Wherp appropriate, document the bases which assure the ability of the system to with 4tand various natural and accidental phenomena such as earthquakes, tornadoes, surges, floods, and a single failure of a component feature of the system (such as a failure of any cooling water pipes penetrating, or in close proximity to, the outside walls of safety-related buildings where the groundwater level is controlled by the system).
An analysis of the consequences of pipe ruptures on the proposed underdrain system must be provided, and should include considerations of postulated breaks in the circulating systein pipes at, in, or near the dewatering system building either inde-pendently of, or as a result of the SSE. Unless it can be documented that the poten-tial consequences will not be serious enough to affect the safety of the plant to the extent that Regulatory Guides 1.26 and 1.29 guidelines could be exceeded, provide analyses to document that (1) water released from the pipe break cannot physically enter the dewatering system, or (2) if water enters the dewatering system, the system will not be overloaded by the increased flow such that the design basis groundwater level is subsequently exceeded.
(h) State the maximum groundwater level the plant structures can tolerate under various significant loading conditions in the absence of the underdrain system.
(1) Provide a description of the proposed groundwater level monitering programs for dewatering during plant construction and for permanent dewatering during plant opera-tion. lionitoring infomation requested includes (1) the general arrangerent in plan and profile with approximate elevation of piezoreters and observation wells to be installed, (2) intended zone (s) of placement, (3) type (s) of piezoneter (closed or cpen system), (4) screens and filter gradation descriptions, (5) drawings showing typical installations showing limits of filter and seals, (6) observation schedules (initial and time intervals for subsequent readings), (7) plans for evaluation of recorded data, and (8) plans for alam devices to assure sufficient time for initiation of corrective action. Provide a comittent to base the final design of the operational mcnitoring program on data gathered during the construction monitoring program (if construction experience shows the assumed operational program bases to be nonconservative or impractical). Changes to the operational program are-to be documented in the FSAR.
(k) Provide infomation regarding the outlet flow ronitoring pr'ogram. The infomation required includes (1) the general location and ty;:e of flew r:easurerent device (s),
and (2) the cbservation plan and alarn procedure to identify unanticipated high or low flow in the system and the condition of the ef fluent.
(1) For OL reviews, but only if not previously reviewed by the staff, provide (1) sub-stantiation of assumed design bases using infcrmation gathered during dewatering for construction excavation, and (2) all other details of the dewatering system design that ixplement design bases established during the CP review.
(m) For OL reviews, provide a Technical Specification fo periods when the dewatering system ray be exposed to sources of water not considered in the design. An example of such a situation would be the excavation of surface seal material for repair of 2.4.13-15 Rev. 1 Y
pip :ij, usa tr.at tre underdrain would Le empused to Jtrect surface runoff. In addi-tion, where the permanent dewatering system is safety related, is not completely rgdundant, or is not designed for all design basis events, provide the bases for a technical specification with action levels, the rerejlal work required and the esti-I rated time that it will take to accomplish the work, the sources, types of equipment and manpower required and the availability of the above under potentially adverse conditions. [See Section V(f)].
at t
I e u. 5 GOWI AfsacDT PEINTIAG OF RCE : 3973. '20 197/277 Rev. I 2.4.13-16
(
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362.0 GEOSCIEilCES BRA!!CH - GE0 TECHNICAL ENGINEERING SECTIOil 362.1 Piezor.
from piezameters 16 and 18 (Fig. 2.5.4-13)
(2.5.4.5.1) indicate tne water surface would reach levels in the permanently excavated slope.
Discuss measures to control seepage at the toe of slope and address the impact on slope stability.
362.2 Provide the guidelines that will be used by field personnel in (2.5.4.5.1) determining the extent of weak or weathered rock zones to be removed (e.g. based on refusal to yield to construction equipment of a specified weight or capability).
362.3 We require timely adequate notification for inspection by the (2.5.4.5.1)
(RSP) ilRC Geosciences Branch staff of finally prepared rock foundation surfaces beneath Category I structures before treatment with concrete.
Provide a commitment that you will give this notification.
362.4 In view of the anticipated variable foundatien conditions beneath (2.5.4.5.1) the Service Water Piping and the large potential for differential settlement, we request submittal of piping and connection details and estimates of anticipated and tolerable limits of total and differential settlement along the piping length.
o 362-2 36?.5 The specified gradation range (Fig. 2.5.4-33) for the
S P (2.5.4.5.2) structural fill is very wide and could result in poorly graded or segregated soils whose characteristics would be significantly different from tested material.
Provide an additional control specification (e.g. uniformity coefficient) that will assure a reasonably well graded structural fill.
We require that the Sieve analysis testing be conducted on structural fill as placed in the foundation, and not on stockpile material.
Justify your reason for not using the preferred testing standard for sieve analysis (AST"-D-422) of soils for the structural iill.
362.6 We require the compaction criteria for structural fill beneath (RSP)
(2.5.4.5.2)
Category I structures be changed to an average of 85 percent but not less than 80 percent relative density (ASTM D-2049) or not less than 95 percent of ASTM 0-1557 maximum dry density, whichever results in the h.ighest in-place dry density.
This s
dual criteria is necessary in recognition of the submitted widely graded structura? fill which would permit the use of clean soils with no fines to soils containing fines up to 18 percent passing the 200 sieve. Attaining the specified level of compaction should not be difficult with presently available compaction equipment and will assure that backfill will exhibit good static and dynamic properties. Indicate your intentions with respect to this position.
362-3 362.7 Provide and discuss the resuits of pu ping tests that '..cre (2.5.4.6) to be performed ir. 1973.
Provide the ccnceptaal desi n of y
the construction dewatering system.
362.8 Describe the properties and field controls and documentation (2.5.4.7) to be required if soil cenent is to be placed in the foundation of structures.
Indicate the properties and field controls to be required (e.g. strength, etc.) for fill concrete and porous concrete.
362.9 Provide a graph of depth versus maximum acceleration levels (2.5.4.8.1, 2.5.4.12) fron u,e results obtan.cc..ith the : N E pcci ;m for e:a. of the ajopteu five earthquake time histones.
362.10 For the condition of shear stresses in the free field (2.5.4.8.1)
(Fig. 2.5.4-20) only, provide curves of induced cyclic shear stress peaks resulting from each of the individual time histories rather than an average curve.
1 362.11 For each Category I structure founded on soil, provide adepted (2.5.4.10.1) soil parameters (e.g. unit weight, shear strength, etc.), actual bearing f actor s and computed ultimate bearing capacities including the margin of safety against bearing type failure under both static and dynamic loading.
Include in this discussion the foundation design of the pipe tunnel where it is located on in.
situ glacial till.
362-4
=...
362.12 The discussion on lateral earth pressures omits site specific (2.5.4.10.3) information.
Provide specific adopted soil parameters, design values and resulting lateral earth pressure coefficients to be used in design at the Haven site.
362.13 Provide approximate locations and typical installation details (2.5.4.13) of settlement monuments.
Discuss the frequency of monitoring and the method for presenting recorded settlements that will include the settlements that develop as construction loads are appl ied.
362.14 Provide information on the type, properties, method of (2.5.5) installation and service history of the proposed filter cloth, e
372.0 HYDROLOGY / METEOROLOGY BRANCH - METEOROLOGY SECTION 372.6 ANSI A58-1-1972 based its extreme wind distributions on an (2.3.1)
(Q372.1) analysis by Thom for about 140 locations across the U.S. (Thom, H.C.S., 1968: New Distributions of Extreme Winds in the United States. Journal of the Structural Division, ASCE (American Society of Civil Engineers), Vol. 94, No. ST 7, Proceedings Paper 6038,pp.1787-1801.)
In the site region, Thom used data only from Chicago, IL. and Green Bay, WI. for a 21 year period.
i Verify that your design wind speed of 90 mph is appropriate for the Haven site based upon records in the general site vicinity.
Specifically, using the Fisher-Tippett Type II methodology outlined by Thom and at least 30 years of recent data, provide the annual extreme-mile wind speeds 30-feet above the ground for a 100 year recurrence interval for Milwaukee and Green Bay, WI., and for any other locations that may be representative of extreme wind conditions at the site.
List the annual extreme windspeeds by year that you used and provide a plot similar to Figure 6 of Thom (1968) for your analyses.
Discuss what value best represents extreme wind conditions at the site.
432.0 ACCIDENT ANALYSIS BRANCH - EMERGENCY PLANNING SECTION 432.2 Your list of agencies to be contacted, on page 13.3-1, should include 13.3.3 (Addendum) the State Department of Agriculture.
If the county agricultural agencies are autonomous, also include the appropriate agencies in Sheboygan and Manitowic Counties.
432.3 Please scope (e.g., by means of a block diagram) the jurisdic-(13.3.3)
(Addendum) tional relationships of the Town of Mosel and the City of Sheboygan to the Sheboygan Sheriff's Office.
The principal government office or agency in each local political jurisdic-tion, which would have the responsibility for prompt initiation of protective action warnings and instructions to the public, should be clearly identified.
432.4 Please scope the facilities presently in place and used in (13.3.4)
(Addendum)
Sheboygan County for providing early warnings and information to the public in emergencies (e.g., for snow storms, air pollution alerts, floods).
Pertinent experience in the Town of Mosel should be related in somewhat greater depth or detail.
432.5 Your preliminary plans emphasize the protective measure of public (13.3.4)
(Addendum) evacuation virtually to the exclusion of other protective measures and alternatives (e.g., shelter, removing dairy herds from pasture).
Preliminary planning should reflect provisions for initiating protective actions for all exposure pathways, onsite, and offsite, including:
I sr
- a
=
432-2 (1)
Direct radiation exposure from a confined source in-plant, an airborne plume, and ground deposition,
( 2)
Inhalation exposure from an airborne plume,and
( 3)
Ingestion exposure from contaminated water, milk, and other agricultural products.
432.6 Your plans should provide for taking preciptation, water, and
( 13. 3.4 )
(Adcendum) vegetation sInples within the site boundary and outside at least to the low population zone boundary to assess potential ingestion exposure pathways in an emergency.
The expected response and anticipated capabilities of offsite agencies for radiological hazards assessment in the environs should be described, recognizing, however, that for more severe emergencies protective actions offsite would be initiated based solely on in-plant infonnation, but possibly modified thereaf ter as off-site information would become available.
432.7 Your estimates of notification times, on page 13.3-2, are ver.y low.
(13.3.4)
(Addendum)
Such estimates would depend in part upon the availability of resources which were present or could be brought into the locale.
In paragraph 13.3.4.c, please list the number and type (i.e., town, county, state) of police officers, as functions of time, which were assumed for your calculations.
Compare the assumed resources with those which could be immediately available or assigned to the locale within the assumed time.
432-3 432.8 In the last paragraph of Section 13.3.4, on page 13.3-5, please (13.3.4)
(Addendum) describe the basis for the time-dose-distance plots presented in Figures 13.3-2, -3 and -4.
Acceptable bases are described on page 13-9, of Regulatory Guide 1.70, Rev. 2 - Standard Format and Content of Safety Analysis Reports for fluclear Power Plants.
432.9 Please specify a scurce of local weather forecasting which (13.3.3)
(Addendum) could provide information as an aid to consequence assessment.
If special arrangements would be required to obtain such information, please include the source in your list of contacts with agencies.
e,',
ENCLOSURE 2 HAVEN, UNIT 1: ROUND 1 QUESTIONS FOR WHICH RESPONSES HAVE NOT BEEN RECEIVED Review Area Question Number Date Forward to WEPC0 Containment Systems 42.47 07/18/78 flechanical Engineering 110.17 10/24/78 Instrumentation & Control 221.47,.48,.49 10/24/78 Analysis 240.1 08/03/78 Accident Analysis 312.8 08/03/78 Seismology 360.7 through 360.10 10/24/78 360.12 10/24/78 360.14 through 360.18 10/24/78 Geology 361.10,.11 07/18/78 Initial Test & Operations 413.11,.12 11/08/78 Operating License 430.3 12/18/78 P