ML19296D477
| ML19296D477 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/28/1980 |
| From: | Gray J, Mcgurren H NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19296D476 | List: |
| References | |
| NUDOCS 8003040661 | |
| Download: ML19296D477 (15) | |
Text
02/28/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY COM'ilSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PORTLAND GENERAL ELECTRIC COMPANY,
)
)
(Control Building)
(Trojan Nuclear Plant)
NRC STAFF'S RESPONSE TO LICENSEE'S MOTION FOR
SUMMARY
DISPOSITION A.
Introduction By motion dated February 7,1980,M the Licensee in the captioned proceeding requested, pursuant to 10 CFR $ 2.749, that the Licensing Board sumarily dispose of certain contentions of the Coalition for Safe Power (CFSP) which have been admitted as issues in this proceeding. The Licensee's motion for sumnary disposition is specifically directed toward (1) CFSP Contention 3 (2) CFSP Contention 17 (3) CFSP Contention 20 (4) CFSP Contention 22.
The Licensee's motion for summary disposition was accompanied by effidavits which purport to demonstrate that, as to the contentions which ar: the y
On filing its motion of February 7,1980, the Licensee withdrew its previous motion for sumary disposition filed on August 27, 1979.
f 003 0 40 fo (p i
i 2
subject cf the motion, there is no genuine issue of material fact. Accord-ingly, the Licensee argues that the Licensing Board should find in favor of the Licensee with regard to the above contentions and that those contentions should be dismissed as issues in this proceeding. The NRC Staff's response to the Licensee's motion is set forth below.
B.
NRC Staff's Response CFSP Contention 3 CFSP Contention 3 states that:
Plant Staff Review of the proposed modifications is inadequate to assure no violations of Technical Speci-fications will occur.
In support of the motion with regard to CFSP Contention 3, the Licensee sets forth, in the affidavit of Richard C. Anderson, the Bechtel Engineering Manager with supervisory responsibility wer the development of the proposed modifications to the Control Building Complex, a description of the purpose of work plans to be developed for the perfonnance of the modification work and of the procedures for the development, preparation and review of such work plans.
In the affidavit of C. Paul Yundt, General Manager of the Trojan Plant, the Trojan Plant Staff responsible for review of Bechtel work plans is defined and the plant procedures for review of the work plans is described. As set forth in the Yundt affidavit, prior to the commencement of any work under the proposed modifications, the work plans must oe approved by the Licensee's Resident Engineer (Yundt Affidavit on CFSP Contention 3, paragraph 7).
Prior to any such apprwal, the Plant Quality Assurance Staff
-~
s will review the work plans against the Technical Specifications a1d plant adainistrative procedures. Should that review identify any aspect of the work plan which conflicts with Technical Soecification requirements, the work plan will be tr.odified so that the work will not violate Technical Specifications.
(Yundt Affidavit on CFSP Contention 3, paragraphs 8, 9).
As set forth in the attached " Affidavit of M. H. Malmros on PGE Motion for Summary Disposition with Regard to CFSP Contention 3," the NRC Resident Inspector for the Trojan Nuclear Plant has reviewed the Affidavits of Richard C. Anderson and C. Paul Yundt and has examined facility procedures and records for the development and control of construction work plans. Based on the resident inspector's examination of the facility procedures and records, he has detemined that an approved procedure for the development and control of work plans is maintained and that approved procedures for the review of work plans to assure that Technical Specifications are met during modification work are maintained. The description of work plans and the review process as stated in the affidavits of Richard C. Anderson and C. Paul Yundt are consistent with the requirements of these procedures (Malmros Affidavit, paragraph 5). Accordingly, the Staff concurs in the Licensee's statement of " Material Facts as to Which There is No Genuine Issue to Be Heard set forth in Parts II.A through II.F of the Licensee's motion with regard to CFSP Contention 3 and the Staff supports the Licensee's motion for dismissal of CFSP Contention 3.
, 2.
CFSP Contention 17 CFSP Contention 17, which raises concerns with regard to the effects of the proposed modification work on the ability of plant operators and the fire brigade to respond to emergencies and fires, states 17.
Performance of modification work will hamper the ability of plant operators to respond to any emer-gency properly and thus poses an undue risk to the public health and safety.
In support of the motion with regard to this contention, the Licensee sets forth, in the affidavits of Richard C. Anderson and C. Paul Yundt, an identi-fication of the areas of the plant where modification work will take place, an identification of plant areas, within or adjacent to work areas, to which operator access could be necessary during emergencies (Yundt Affidavit on CFSP 17, paragraph 8), and the identification of a single area through which access cay be temporarily impaired, though not blocked, by the modification work (Anderson Affidavit on CFSP Contention 17, paragraph 6).
The Staff has perfomed its own review and evaluation of the effects of the modification work on access for plant operators in the event of a fire or other emergency (Affidavit of James E. Knight on PGE Motion for Summary Dis-position with regard to CFSP Contention 17 (Knight Affidavit), paragraph 4).
Based on that evaluation, the Staff agrees with and concurs in the statements set forth in paragraphs 5 through 10 and 12 of the Richard C. Anderson Affi-davit and paragraphs 4 through 12 of the C. Paul Yundt Affidavit insofar as paragraphs 4 through 12 relate to the effects of modification work on access
, for operators and the fire brigade (Knight Affidavit, paragraph 7).
The Staff also agrees with and concurs in the Licensee's statement of material facts set forth in Parts II. A through II.G of the motion with regard to CFSP Contention 17. Accordingly, the Staff supports the Licensee's motion for dismissal of CFSP Contention 17, insofar as that contention relates to effects of the modification work on operator access, in the event of a fire or other emergency.
The remaining effect of the modification work on operator actions arises from construction-generated noise which could potentially interfere with communications between Control Room operators or with operators' hearing Control Room audible annunciators.
In the Affidavit of Richard C. Anderson (paragraph 11), it is indicated that tools to accomplish the modification work will be selected to minimize noise level. The Staff has performed a review and evaluation of the effects of noise produced during the modification work on operations in the Control Room (Affidavit of Fred Clemenson on PGE Motion for Summary Disposition with Regard to CFSP Contention 17, paragraph 4). Based on that evaluation, the Staff agrees with and concurs in paragraph 11 of the Richard C. Anderson Affidavit and paragraphs 5,11 and 12 of the C. P. Yundt Affidavit insofar as these paragraph: relate to the effect of the modification work on operator actions arising from construction-generated noise which could potentially interfere with communications between Control Room operators or with hearing Control Room audible annunciators (Clemenson Affidavit, paragraph 7).
c, Accordingly, the Staff also agrees with and concurs in the Licensee's state-ment of Material Facts set forth in Part II.H of the motion with regard to CFSP 17 (Clemenson Affidavit, paragraph 8). Therefore, the Staff supports the Licensee's motion for dismissal of CFSP Contention 17, including those aspects of the contention regarding the effect of the modification work on operator actions arising from construction-generated noise.
3.
CFSP Contention 20 CFSP Contention 20 states:
Inadequate assessment of the effects of drilling in the control building walls during modification has been made.
In support of the motion with regard to this contention, the Affidavit of Richard C. Anderson (the Bechtel Engineering Manager who has supervisory responsibility for the development of the proposed modifications) identifies the precautions and procedures that will be taken to avoid damage to the reinforcing steel in the Control Building walls (Affidavit of R. C. Anderson on CFSP Contention 20, at paragraphs 6-8) as well as the procedures that will be taken to preclude damage to equipment either atta:hed to or adjacent to the Control Building walls where drilling will be conducted (Affidavit of R. C. Anderson on CFSP Contention 20, paragraphs 9-11).
The Affidavit of Dr. William H. White, the Bechtel Engineering Specialist who either perfomed or supervised the seismic analyses of the Complex with regard to the proposed modifications, indicates that the drilling to be done will not damage the reinforcing steel in the Control Building walls to reduce their shear capacity
, (Affidavit of Dr. White on CFSP Contention 20, paragraphs 6 and 7).
Dr. White's affidavit further indicates that a reduction in the shear capacity of the Control Building walls will not result from the pattern of the bolt hole drilling (Affidavit of Dr. White on CFSP Contention 20, paragraph 8), drilling on any existing cracks or the filling of abandoned holes with grout (Affidavit of Dr. White on CFSP Contention 20, paragraphs 9,10 and 11).
The Staff has perfonned its own review and evaluation of the effects of drilling in the Control Building wsils during the modification work (Affidavit of James E. Knight on PGE Motion for Summary Disposition With Regard to CFSP Contention 20, Joint Affidavit of Kenneth S. Herring and Drew Persinko on PGE Motion for Summary Disposition With Regard to CFSP Contention 20, and Affidavit of Fred C. Clemenson on PGE Motion for Summary Disposition With Regard to CFSP Contention 20 (all attached)).
Based on that evaluation, the Staff agrees with and concurs in the statements set forth in paragraphs 5 through 11 of the R. C. Anderson Affidavit (Knight Affidavit, paragraph 6, Clemenson Affidavit, paragraph 7, and Joint Affidavit of Herring and Persinko, paragraph 10) except the statement in paragraph 9 that all holes must be located such that there is a gap greater than 2 inches between the wall and an, siece of adjacent equipment (Knight Affidavit, paragaph 6).
To allow installation of the washer, nut and bolt on the Control Building wall, a horizontal distance of at least five inches from the wall to the nearest cable, cable tray or conduit is rcquired (Knight Affidavit, paragraph 6). The safety of equipment adjacent to the wall to be
, drilled is assured even with a two inch gap, however (Knight Affidavit, para-graph 6).
For the reasons set forth in paragraph 7 of the Clemenson Affidavit, the Staff agrees with and concurs in paragraph 12 of the Anderson Affidavit to the extent that paragraph addresses the effects of vibration, dust and debris from drilling on equipment near the drilling site.
The Staff also agrees with and concurs in the statement set forth in para-graphs 9 and 10 of the W. H. White Affidavit which concern the effect of drilling on existing cracks in the Control Building walls (Joint Affidavii; of Herring and Persinko, ;;aragraph 10).
Accordingly, the Staff agrees with and concurs in the Licensee's statement of material facts set forth in II.D. through II.H. of the motion with regard to CFSP Contention 20 (except as noted in the Knight Affidavit, paragraph 6 -
to accomodate the bolt assembly to be installed on the walls where holes are drilled, there must be a gap greater than 5 inches and not 2 inches as stated in paragraph II.F. of the Licensee's Statement of Material Facts).
This demonstrates basic agreement between the Licensee and the Staff regarding precautions and procedures that will be taken to preclude damage to equipment either attached or adjacent to the Control Building walls that may result from drilling necessary during the proposed modification work.
It also shows agreement between the Licensee and the Staff regarding the effect of any drilling on existing cracks. There has, however, been a failure to agree on the effect that this drilling will have on the shear capacity of the Control Building walls, r-.
_9-With regard to the shear capacity of the Control Building walls, the Staff cannot agree and concur with a statement made in paragraph 12 of the Anderson Affidavit on CFSP Contention 20 (Joint Affidavit of Herring and Persinko, para-graphs 10 and 11) and certain statements made in paragraphs 5, 5, 7, 8, 11 and 12 of the White Affidavit on CFSP Contention 20 (Joint Affidavit of Herring and Persinko, paragraphs 10 through 14). The Staff cannot concur in the statement in paragraph 12 of the Anderson Affidavit that drilling necessary for modification will not harm the reinforcing steel in the walls and the statements in paragraphs 5, 6, 7 and 12 of the White Affidavit that near capacity is independent of loss of material due to drilling and shear capacity will not be raduced by such drilling for the basic reason that the effect that the steel removed by the drilling will have on shear capacity has not been fully demonstrated and is not fully understood (Joint Affidavit of Herring and Persinko, paragraphs 10,11 and 12). The Staff is unable to concur and agree with the statement in paragraph 8 of the White Affidavit regarding the tendancy of a crack to develop along a single plane of bolt holes for the reasons the.t the Licensee has not identified the angle of orientation of the planc and defined the stress field in the wall being drilled (Joint Affidavit of Herring and Persinko, paragraph 13).
Until it is shown that the grout in abandoned holes has attained the strength of the material in the walls or there is proper consideration given any reduction in the wall strength due to the grout in abandoned holes, the Staff cannot concur in paragraph 11 of the White Affidavit (Joint Affidavit of Herring and Persinko, paragraph 14). Thus, the Staff cannot agree and concur in the Licensee's statement of material facts set forth in II. A.,
B.,
and C. of
, the motion with regard to CFSP Contention 20 which in essence state that the shear capacity of the Control Building walls will not be affected by the drilling necessary during the proposed modification.
There remain unresolved concerns as to the calculation and analysis of shear capacities of the walls in the modified Complex (Joint Affidavit of Herring and Persinko, paragraphs 11, 12 and 14). Until these concerns are resolved and it is demonstrated that shear capacities are adequately and finally detennined, a conclusion on the effects of drilling on wall capacity and strength cannot be reached in the Staff's view.
Accordingly, the Staff is of the view that a " genuine issue of material fact" (10 CFR 9 2.749(a)) - the level of final, correctly determined shear capacities in the modified Complex and the manner in which those capacities are affected by drilling in walls - remains, and that this remaining issue precludes summary dismissal of CFSP Contention 20. Thus, the Staff opposes the Licensee's motion with regard to CFSP Contention 20.
4.
CFSP Contention 22 CFSP Contention 22 states that:
The effect of the steel plate on displacement in the Complex has not been completely analyzed.
In support of the motion with regard to this contention, the Licensee, in the Affidavit of W. H. White, describes the manner in which structures will undergo displacements during an earthquake and identifies interstructure
, displacement (relative displacement between two adjacent structures) as the displacements of concern raised by this contention. The Licenwe points out that interstructure displacements were analyzed in detail for interim opera-tion of the as-built structures in Phase I of this proceeding and it was shown that existing gaps between structures in the as-built Complex were sufficient to preclude contact of structures during an earthquake (White Affidavit, paragraph 6).
The Licensee asserts that the addition of a 3-inch thick steel plate to the west or R line wall of the Control Building as well the addition of new concrete walls pursuant to the modifications will stiffen the Complex and therafore reduce displacements of the modified Control Building relative to the as-built, unmodified structures that were analyzed for interim operation (White Affidavit, paragraph 7). However, the Licensee points out that the addition of the 3-inch thick steel plate on the west or R line wall of the Control Building between the Control and Turbine Buildings would reduce the existing gap between these buildings if no other actions were taken (White Affidavit, paragraph 8). To increase the size of the gap after installation of the plate, portions of concrete slabs and a steel girder flange will be removed in certain areas (White Affidavit, paragraph 8). The Licensee asserts that its analysis of the modified Control Building Complex demon-strates that, with the steel plate installed and portions of floor slabs and a girder removed to increase the gap between structures at the location of the steel plate, the relative displacements of the Control and Turbine Buildings will be such as to preclude contact between these structures F
, (White Affidavt, paragraph 9).
Accordingly, the Licensee concludes that the effect of the steel plate on displacements of the nodified Control Building Complex has been fully analyzed, that contact between the Control and Turbine Buildings during an earthquake is precluded, (White Affidavit, paragraph 10),
and that CFSP Contention 22 should, therefore, be dismissed.
As set forth in the Joint Affidavit of Kenneth S. Herring and Drew Persinko on PGE Motion for Summary Disposition With Regard to CFSP Contention 22 (attached), the Staff has reviewed the proposed modifications to the Trojan Control Building, the Licensee's analyses thereof, and the Affidavit of W. H. White with regard to the Licensee's Motion on CFSP Contention 22 Based on that reiiew, tne Staff agrees with the statement in paragraph 5 of the White Affidavit as to the manner in which structures will undergo dis-placements during an earthquake (Joint Affidavit of Herring and Persinko, paragraph 10), and with the statement in paragraph 6 c7 the White Affidavit (and, therefore, statement of material fact II. A.) as to interstructure dis-placements for the as-built unmodified Complex (Joint Affidavit of Herring and Persinko, paragraph 11).
The addition of the steel plate and three concrete walls to the Control Building will stiffen the Complex for displacements in the north-south (N-S) direction (Joint Affidavit of Herring and Persinko, paragraph 12) but will not significantly stiffen the Complex, relative to its as-built, unmodified state, for displacements in the east-west (E-W) direction (Joint Affidavit
. of Herring and Persinko, paragraph 13).
Thus, the Staff agrees with and concurs in the statenents in paragraph 7 of the White Affidavit and the Licensee's statement of " Material Facts to to Which There is No Genuine Issue To Be Heard," parts II.B. and C insofar as those statements assert that the modifications will reduce displacements in the N-S direction. The Staff does not agree that E-W displacements will be significantly reduced by the modifications since the modifications will not significantly stiffen the Complex in the E-W direction. Nevertheless, the Staff is in basic agreement with the Licensee that the additional gaps provided by removal of portions of floor slabs and a steel girder flange in the areas where the steel plate will be installed between the Control and Turbine Buildings should be 6dequate to preclude contact between those buildings from displacements caused by an earthquake (Joint Affidavit of Herring and Persinkc, paragraphs 12 and 13).
At the same time, the Staff does not agree that actual displacement in eithe-the N-S or E-W directions for the modified Complex are adequately and finally quantified (Joint Affidavit of Herring and Persinko, paragraphs 12 and 13). The Licensee's treatment, in its structural anlayses, of nomal' forces (as detemined by the effects of gross overturing, shrinkage and temperature), single versus double curvature behavior of structures, rein-forcement ratios and shear stresses has not been shown to be wholly adequate and appropriate (Joint Affidavit of Herring and Persinko, paragraph 14).
These matters can offect the stiffness of the modified Complex and, if appro-priately accounted for, can result in an increase in calculated displace-
. ments of structures beyond those shown in paragraph 9 of the White Affidavit (Joint Affidavit of Herring and Persinko, paragraph 14).
Consequently, the Staff does not agree that the calculated displacements set forth in paragraph 9 of the White Affidavit are the final and necessarily the highest displacements that will occur.
In turn, while the Staff believes that the gaps to be provided between structures where the steel plate is to be installed should be adequate to preclude building contact during an earthquake (Joint Affidavit of Herring and Persinko, paragraphs 12 and 13),
the Staff does not agree with the statement in paragraph 10 of the White Affidavit that the effects of the steel plate on displacements in the modified Complex have been " fully analyzed."
Further, without a final, fully adequate detemination of the displacements in the modified Complex, it is not an established fact that analyses demonstrate the adequacy of the gap between the modified Control and Turbine Buildings to prevent contact between those buildings during an earthquake (statement of " Material Facts As To Which There Is No Genuine Issue To Be Heard," part II.F.).
Accordingly, the Staff is of the view that a " genuine issue of material fact" (10 CFR S 2.749(a)) -
the level of final, correctly-calculated displacements for the modified Control Building Complex -remains with regard to CFSP Contention 22, and, therefore, opposes the Liceneee's motion for sunnary disposition with regard to that contention.
. C.
Conclusion For the reasons set forth above, the Licensee's motion for summary disposition with regard to CFSP Contentions 3 and 17 should be granted but the motion with regard to CFSP Contentions 20 and 22 should be denied.
Respectfully submitted, A
J sep R. Gray oun el for NRC Staff
.jf V
w Henryh McGurren Counsel for fD Staff Dated at Bethesda, Maryland this 28th day of February,1980