ML19290C155
| ML19290C155 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/19/1979 |
| From: | Gray J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Mccollom K, Mark Miller, Paxton H Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8001100169 | |
| Download: ML19290C155 (9) | |
Text
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A J. Gray H.McGurren
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S.Treby HKS/TFE/ ESC C
December 19, 1979 p,
A.Schwencer 316-Phillips M.Malmros J. Crews Region V Marshall E. Miller, Esq., Chairman Dr. Kenneth A. McCollom, Dean Atomic Safety and Licensing Board Division of Engineering, U.S. Nuclear Regulatory Commission' Architecture & Technology Washington, D.C.
20555 oklahoma State University i
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Stillwater, Oklahoma 74074 Dr. Hugh C. Paxton 1229 41st Street H. Smith Los Alamos, New Mexico 87544 314-Phillips D.Vassallo 110-Phillips In the Matter of K. Herring Portland General Electric Company, et al.
440-Phillip's
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(Trojan Nuclear Plant)
-D&SS Docket No. 50-344 ELD FF (2)
(Control Building)
Chron.
Gentlemen:
3 By Order dated November 30, 1979, the Licensing Board directed the Staff and the other parties to the referenced proceeding to provide certain information 1
and positions in accordance with paragraphs (4) and (5) on page 4 of that I
Order.
In a letter dated December 7, 1979, the Staff stated that it would si provide its responses to the. Board's directives during the week of Decem-
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ber 17, 1979. This constitutes those responses.
In paragraph (4) on page 4 of its November 30, 1979 Order, the Licensing Board directed that:
4.
The Staff shall furnish a date reasonably anticipated
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for the completion and filing of its SER, and a full justification and explanation for any further slippage in that regard.
By letter dated December 7, 1979 in response to the Licensing Board's directive in its Order of November 30,1979 (Order, p. 4, paragraph 2), the Staff set forth in detail the remaining unresolved problems with regard to the proposed modifications to the Trojan Control Building. Those unresolved problems are addressed in a series of Staff questions submitted to-the Licensee on Septem-ber 14, 20 and 28 and October 2, 1979. It is the Staff's view that full resolution of those problems is necessary before a complete and adequate SER on the proposed modifications can be issued. The questions submitted by the Staff to the Licensee were detailed in nature and were designed to elicit information and commitments from the Licensee such that full, responsive answers would resol te the remainsng unresolved problems.
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By letter dated December 8. 1979 in response to the Licensing Board's directive in its Order of November 30, 1979 that the Licensee report the status of all information requested by the Staff but not yet supplied (Order, p. 4, para-graph 3), the Licensee stated that it plans to file its responses to the remaining Staff questions by December 22, 1979 (Licensee's letter of December 8, 1979, p. 2).
In view of the Licensee's comunitment to supply responses to the remaining Staff questions, the reasonably anticipated date for the completion and filing of the Staff's SER on the proposed modification is February 14, 1980. As previously mentioned, the issuance of a complete SER with no unresolved problems remaining is dependent upon submission by the Licensee of full, complete and responsive answers on December 22.
In the event that some or all of the answers submitted on December 22 are not complete and fully responsive and do not resolve all of the unresolved problems, the SER to be issued on February 14, 1980 will identify the unresolved problems and describe their effects on the Staff's conclusions with regard to the adequacy of the proposed modifications.*/
i In paragraph (5) on page 4 of its November 30, 1979 Order, the Licensing Board directed that:
5.
All parties shall state and document their views as to how long interim operatien of the Trojan facility should be permitted, in the absence of the submission of firm 5
plans for control room modifications, adequate from a safety standpoint to bring the facility into substantial compliance with the license.
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Based on the substantial reco'rd compiled, and the uncontroverted evidence pre-sented, at the Phase I hearings on interim operation, the Licensing Board found that the as-built Control, Auxiliary and Fuel Building Complex at the Trojan facility has adequate capacity, despite the Control Building design deficiencies which are the sole and exclusive subject of the instant proceeding, to safely withstand the licensed Safe Shutdown Earthquake (SSE) of 0.25g.
(Portland General Electric Company, et al. (Trojan Nuclear Plant), LBP-78-40, 8 NRC 717',
735 at paragraph 41 (1978) (hereinafter referred to as Partial Initial Decision or PID), aff'd, ALAB-534, 9 NRC 287 (1979). See also Tr. 661-62, 668, 1035, 1474-76, 2105, 2135; PGE Exh. 12, p. 6; Staff Exh. 5, pp. 27-28; Staff Exh. 6, pp. 11-16; Oregon Exh. 1, pp. 9-12.)
In fact, the Board justifiably found that the as-built Complex can safely withstand earthquakes considerably in excess of the licensed SSE.
(PID, 8 NRC 717, 735 at paragraph 41.
See also Tr. 1474-76, 2096-97, 2105, 2110, 2291; PGE Exh. 10, p. 28.)
- f The Staff is aware of the Licensing Board's previous admonition that the situation encountered in Phase I, where hearings vent forward with un-resolved issues remaining, must be avoided in Phase II.
However, in view of the strong desire of the Licensing Board and all parties to move forward toward complet 'on of Phase I L, the Staff feels. compelled to issue the
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-a-The uncontroverted evidence also shows that the analyses made on the adequacy of the as-built Complex to safely withstand earthquakes during interim opera-tion were deterministic, and had no time dependence (Tr. 2228-29, 801, 864-66).
With the present license condition requiring that_the plant be shutdown at an OBE level of 0.08g, the Control Building is adequate, from a safety standpoint, without explicit regard to time.since, if an earthquake of greater than 0.08g occurs, the plant must be shut down and cannot be restarted without prior NRC authorization, and an earthquake of less than 0.08g should not result in struc-tural degradation that would affect the ability of the plant to withstand subsequent earthquakes up to and including the licensed SSE (Tr. 2255-57).
The fundamental reason to modify the as-built control Building is to restore the safety margins to the extent practical and, if possible, to restore the margins originally intended when the plant was licensed (Tr. 2268. See also Tr. 2137-38).
As set forth in the~ attached joint affidavit of Kenneth S. Herring and Charles M. Tranne11. III, the analyses that demonstrated the adequacy of the as-built Control Building Complex for interim operation was not time dependent.
Accordingly, it is the Staff's view at this time that there is no need for an explicit time limit on the length of interim operation.
Nevertheless, as is'also set forth in the attached joint affidavit, interim v
operation is operation with margins reduced relative to those embodied in the original operating license and approved FSAR criteria. It is the Staff's view that these margins should be restored so as to bring the Control Building into
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substantial compliance with the FSAR criteria and that such restoration should g
be accomplished as quickly as is reasonable. To this end, the Staff will con-tinue to make.its best efforts to pursue resolution of the remaining unresolved
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problems with regard to the proposed modifications so that the adequacy of the proposed modifications may be fully adjudicated and determined. In addition, the Staff is of the view that evidence should'be taken in the Phase II pro-ceeding on the length of time, after authorization of modifications, that would be reasonable for completion of the modifications. Based on such evidence, a reasonable date for the completion of modifications could be set so as to assure
'that such completion would not be unduly delayed.
Sincerley, Joseph R. Gray Counsel for.NRC Staff
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Docket No. 50-344 PORTLAND GENERAL ELECTRIC COMPANY, ET AL. )
(Control Building)
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(Trojan Nuclear Plant)
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JOINT AFFIDAVIT OF CHARLES M. TRAMMELL, III AND KENNETH S. HERRING ON LENGTH OF INTERIM OPERATION FOR THE AS-BUILT CONTROL BUILDING STATE OF MARYLAND
)SS COUNTY OF MONTGOMERY)
I, Charles M. Trammell, III, being duly sworn, depose and state:
1.
I am a Senior Project Manager, Division of Operating Reactors, U.S.
Nuclear Regulatory Commission, Washington, DC 20555.
2.
I have prepared the statement of Professional Qualifications attached hereto, and, if calleo upon, would testify as set forth therein.
3.
I am the NRC Staff Project Manager for the Trojan Nuclear Plant. In this capacity, I have been involved in the NRC Staff's review and evaluation of interim operation of the as-built Control Building since the issuance of the NRC's Order for Modification of License on this matter on May 26, 1978.
I. Kenneth S. Herring, being duly sworn, depose and state:
4.
I am a senior structural engineer, Engineering Branch, Division of Operating Reactors, U.S. Nuclear Regulatory Commission, Washington DC 20555.
5.
I have prepared the statement of Professional Qualifications attached hereto, and if called upon, would testify as set forth therein.
6.
In my capacity as senior structural engineer, I have had primary responsibility for the NRC Staff's evaluation of the structural adequacy of the as-built Control, Auxiliary and Fuel Building Complex for interim operation since the NRC was informed of the Control Building design deficiencies in April, 1979.
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. We the affiants Charles M. Trammell, III and Kenneth S. Herring, being duly sworn, depose and state:
7.
The analyses demonstratir.g the structural adequacy of the as-built Control Building Complex for interim operation were deterministic and had no time dependence. Therefore, no time limit is dictated by the analyses performed.
Accordingly, we see no need at this time for an explicit time limit on the length of interim operation.
8.
At the same time, interim operation of the as-built plant is at reduced margins relative to those provided by the original operating license criteria. These margins should be restored to bring the Control Building into substantial conformance with the FSAR criteria and the restoration should be made with all deliberate speed. As such, we are of the view that evidence should be presented in the hearings on the proposed modi-fications on the length of time that will reasonably be required after authorization of modifications to complete the modifications and the licensee should be required to complete them within that time.
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Charles M. Trammell, III Subscribed and sworn to before me this 19th day of December, 1979
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Notary Public
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My Commission expires:
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CHARLES M. TRAMMELL, III DIVISION OF OPERATING REACTORS U. S. NUCLEAR REGULATORY COMMISSION PROFESSIONAL QUALIFICATIONS I am a senior project manager in the Division of Operating Reactors. Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission. As such, I am responsible for managing and participating in the safety and environmental reviews associated with licensing actions regarding the design and operation of assign'ed operating power and research reactors.
This includes planning and coordinating the efforts of other Commission personnel involved in the reviews.
I have a Bachelor of Arts degree in mathematics from Brown University, and one year of graduate studies in mathematics at Rennselaer Polytechnic Institute where I worked as a graduate assistant.
From November 1962 until February 1964, I attended U. S. Naval Destroyer School at Newport, Rhode Island, and was subsequently assigned as Engineer
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Officer of USS Farragut (DLG-6), where I was responsible for all aspects of propulsion engineering and related auxiliary equipment.
i My experience in the nuclear field began in 1964, when I entered the Navy Nuclear Power Program.
I attended a one-year course in naval nuclear power, and was subsequently selected for a staff position at-the Navy',s prototype nuclear power plant (DlG) at West Milton, New York. There I 1726 272
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Professiona1' Qualifications Charles M. Tramnell, III was in charge of a shift crew which operated the plant for training and engineering testing.
I was responsible for the training and nuclear qualification of assigned officers and enlisted men.
From 1967 until 1974, I was employed by Public Service Electric and Gas Company wnere I was responsible initially for the Preliminary Safety Analysis Report for the Salem Nuclear Generating Station. Later, I attended the Westinghouse Reactor Operator Training Program (10 months) which led to certification of equivalency as Reactor Operator thereby establishing eligibility for a " cold" senior reactor operator license at Salem.
In 1969, I was promoted to Reactor Engineer at the Salem station where I was responsible for developing physics and core performance tests and fuel handling procedures while the plant was under construction.
Training at Westinghouse Nuclear Operations Division and startup testing experience at Indian Point, Ginna, H. B. Robinson and Surry stations led to qualification as nuclear engineer in accordance with ANSI Standard N18.1.
In September 1973, I was promoted to the position of Quality Assurance Engineer at the Salem site, where I was responsible for developing the quality assurance program for the operational phase of the Salem station.
I have held my position with the Commission since September 1974.
I have participated in numerous safety and environmental reviews of all types of connercial nuclear power plants, including testifying as an expert witness in the Trojan Spent Fuel Pool Expansion Hearing.
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PROFESSIONAL QUALIFICATIONS OF KENNETH S. HERRING EXPERIENCE:
Jan. 1977 to' U.S. Nuclear Regulatory Commission Present Engineering Branch, Divicion of Operating Reactors Office of Nuclear Reactor Regulation Washington, D.C.
20555 Applied Mechanics Engineer (1/77 to 1/79)
Structural Dynamicist (1/79 to 10/79)
Senior Structural Engineer (10/79 to Present)
~ Responsible for the review, the analysis, and the evaluation of structural and mechanical aspects related to safety issues for reactor facilities licensed for power operation, and test reactor facilities, including the formulation of regulations and safety criteria. An emphasis is placed on seismic, impact and other dynamic loading considerations, in addition to static loading considerations; and linear and nonlinear, concrete and steel behavior.
Responsible for coordinating various outside technical assistance programs and internal tasks related to structural and mechanical applications to nuclear power G plants.
Aug.1974 to Stone and Webster' Engineering Corporation Dec. 1976 3 Executive Campus Cherry Hill, New Jersey Structural Engineer in the Structural Mechanics Group Responsible for conducting static and dynamic, including seismic, finite elemec;. analysis and design of structures in nuclear power generation facilities.
Responsible for maintaining the Strucural Mechanics computer facilities at CH0C.
Fortran IV programing experience.
Aug.1973 to University of Illinois, Department of Civil Engineering Aug. 1974 Urbana, Illinois 61801 Research Assistant Responsible for conducting an investigation into the material properties of fiber reinforced concrete using quick-setting cements for the Department of Trans-portation, Federal Railroad Administration. A report on the outcome of the study was published.
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. EDUCATION:
State University of New York at Stony Brook - Bachelor of Engineering -
May 1973' I
University of Illinois at Urbana-Champaign - Master of Science in Civil Engineering (Structures) - August 1974 ENGINEER-IN-TRAINING: New Jersey -
TECHNICAL SOCIETIES:
American Society of Civil Engineers - Associate Member - April 1974 to Present.
ASME BOILER AND PRESSURE VESSEL CODE COMMITTEES:
Section XI - Subgroup on Containment - fiember - January 1979 to Present.
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