ML19329F229

From kanterella
Jump to navigation Jump to search
Forwards Partial Response to Requests for NRC Review of Util Position Re Structural Engineering Reg Guide Implementation
ML19329F229
Person / Time
Site: Midland
Issue date: 06/08/1976
From: Kniel K
Office of Nuclear Reactor Regulation
To: Howell S
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8006230754
Download: ML19329F229 (14)


Text

.

o a

m.,.(.p w w.w/aw.,,a y e m.wm m ps m,,-.,

-4

.n.

~ :. ll JA.

. Jln g _ gys

.w "W e.r, s

s 4.

E2i{*T7. 'wi.

... sr.

a t

.t.

Distribution:

gat File (2) TPSpeis IE (3) m raina.

E C PDR (2)

RN'Inrk SMacKay TAIppolito r mal PDR JFStolz ICrocPar JPaps, valla

'fIC EKniel Eervice JCBS (16)

PS8 File CDParr JPKnight DGEiserJust ' '

Docket Nos.[50-329 P[I)eYoung WRDutler SSPwlicki Mh i

and w-.00 DTSkovholt D37asualln Mi h il GKnighton.

l

.ppnaniaa P5tainar=n PC21eck

. BJYournh1md P 2 111ns Mt: Donald

'DNovak Waegan N.j, cJaeltenes willi -

RP&wy Dmunch N

l 1

PHHouston CEID VBenaroya <

JTrh114na Consumers Power Ocmpany WEKreger prm11ard 2Spangler JCStepp j

I

'ATIN: Mr. S. H. Ibwall T m n_1 m n BRDenton VAMoore PWollmer Vice Premirkt M[Ernst WFar="411 ERMama7 T Res - ~.y l

l

.212 West Michigan Avenue RLprhm EPn,11ar PAPurple Niemm1 J Jackson, F4'-h4=n 49201 mrmr PHRa.id IGhao Frmar g;{

ASchwencer BJGrimes PMirogue GArndt K;c t

Gentlenen:

RLipinski c,-

rY

.r w

f 1.&}g.

- g..

'lhis letter is in partial response to your request for a review of the inni-tation of zwplatory guidas on the Midland Plant. 'the amlnand

/

i ip f

i tv== ants pertain to your letter of August 19, 1975 ran=vd45 regulatory, Q :W

%t guides <h=11M with ai -

  • 1 = = inaari e.

' f]-j /Qf

..~.

. ~ s.s.

'the am1r=re contains ap iMr-ev==nts en angulatory mildam 1.10,

%^ ~ l 1.12, 1.15, 1.18, 1.19, 1.35, 1.60, 1.61 and 1.92. We did not,wenant

~

s.

at this time regarding Brglatory Giidag 1.27, 1.55 and 1.59. We will i

forward our ocuments cx1 Regulatory O' irk 1.27 and 1.59 with thnaa cm the "immllanar=la grow of gnish. Our evv' writs on Regulatory Glich l.55 will be forwarded with Hma of the Quality Assuranrw gro@.

We agree that Regulatory Otida 1.57, Amlim with untal conhiment systerus, and Begulatory Guido 1.90, daalig with grouted terAana, are not applicable to the Midland Plant.

'!he ae1<=d mmaats result from our review of your letters of July 21, W

i 1975, August 19,-1975, nanaritwr 1, 1975 and Peoruary 3, 1976: review of pertinent parts of your Pr=14minary Safety Analysis Repcrt and lir=nm t

\\

application; <maidaration of the di==aima we have had with you on i this matter; and the apnlina+4m of ana.w iate regulaticms, maaa and r

standards. Based on this review, we have concluded that the 441===aritation i

of regulatory guides and %4.able alwives indir-*.:ed by our encirmi l

mts does not ecostitute a change to the mimina1 architectural

+ an1 aaerinameinrr criteria which fnmad the basis for la=== of the construction Ixurits for the Midland Plant, and that such %1% tion does r"% to the Genes.al Design M+=ria of Ama=div A to 10 GR 50.

~

THIS DOCUMENT CONTAINS POOR QUAL.lTY PAGES RO'06280 7 5J

4

-n.__.

.a m, x o...,psr.w..

wr,.:., w,rnm -.

_=n,n r

e

/ _y.re,

r

./

} '

,{..,

.s, I

gt-

' ~~ 4,

m.,

i. -sM W

._,7

^ 1 1r..

y

r e

'%nsumers Power capany 2-JtR 8 1978 l

It is requested that you r_M=nt the vegree to which yx1 will it:plaunct.

l the rugulatory gnidaa ard acceptabha alternatives, hviir-=ted in the ane.inmart,rmnerats by w-

  • +a memrybnents to the Midland sm14rm&4rm ty{;g s

, fy;j[W,( '

and zurisions to the Pr=14=ichary Safety Analysis Esport.

, u w

..f,-

Sincerely, original Signed HE Karl Kniel s

, :,,jp

~

= Karl Knial, Olief "i-j.c 7Cf 'l

~

s Light Watar Reactors Branch No. 2

~ ' M ? ;,.;

Division of Project remarpunal,t 45 ww1,wnve:

,. ;p.-

Regulatory Guida Baview

~li;n$;.p.q;y nn e*

m..

w,m...

tx:

>-w..

Ln

= Q e 4:

-6

, c. a' v,y.s&. a%gr:

' ' ~..,

Bouard J. Voge', Esq.,.

s n

s ggg

3. 7'"i -

G gap

.f -t'. C.

~ 'f r M..; W e,.,

y s.

814 F1 cue h, h ildi m,

i. '.1. '-

i 310 Pcurth Avenue, South P4nnaa.m14 =, Minnesota 55415 I

Myron M. carry, EM.

Jenner & Block

)

1 IBM Plazt.:

Chicago, I114m4 = 60611 C,

Harold F. Beis, Esq.

Icwenstein, Heuman, amis & Annirad 1025 CL-i.icut Avemus, N. W.

Washington, D. C.

20036 l

Honormhla W4114== H. Nord Assistant Ai.iaEinsy f'm=rn1 1

Topeka, Kanaan 66601 I,

Irving Like, Esq.

I anilly, like a schneider 200 West Nain Street Baby 3ca, New Yack 11702

~/

Jumiss[A. Emndall, Esq.

' 135 JC Saginaw Bond

{

Pi@ a'vi, Midniaan 48640 i

/

M*M~

~Mgm 4.

S*5 5

' 'M S

f " *" " * - h y;g, TQ._L.-

- T444* _ l 7

-gd

..',3
  1. 4]

s1

' * * * "--3/---/7S 3/-Mn

,1 1 in si im

,e i in N

  • ~

d u. s. sovsiennsamt eninveme'orricss sev4.ese-ees

_. j., y,- l

[ FeraufABC.)le (Ren 9-53) AICM 0240

~_..'g_,

_~u.3,.

y y! '. -

D_ :

,..,xtmg Q t

4 MIDLAND PIANP UNITS 1 AND 2 REGUIA'IORY GUIDE REVIDf 1.

Regulatory Guide 1.10

" Mechanical (Cadweld) Splices in Reinforcing Bars of Category I Concrete Structures" - (Rev.1,1/2/73) a) Guide Reconmendation:

Tnis guide describes an acceptable method of inplanenting the criteria of Appendix A to 10 CFR Part 50 with regard to the testing and sanpling of mechanical splices in reinforcing bars used on Category I concrete structures. Paragraph C.5.a stipulates that if two or nere splices fail to meet the tensile test, the balance of the 100 production splices under investigation should be rejected and replaced.

'Ihe applicant proposed that if two or more splices fail to meet ytensile test, the condition would be handled in the following manner. First of all, Bechtel Quality Control would

<*v'==nt the event by issuing a Non-Confonnance Report (NCR) addressing the situation. Quality Control would also physically f

identify the questionable cadwelds and notify Bechtel Quality Assurance that a situation existed which might be reportable in accordance with 10 CFR 50.55(e). Bechtel Quality Assurance would forward this notification to CPCo Quality Assurance for their possible notification to the NRC.

After review in the Field, the NCR would be transmitted to the Design Office for dispositioning along with appropriate data to allow the Design Office to evaluate the condition.

'Ihis evaluation would be performed in accordance with approved procedures 18wHng to an Engineering direction to accept or reject the questionable car * = W. 'Ihis direction would be transmitted back to the Field on the NCR. Should this direction be to accept the cadwelds, Engineering must provide the engineering rationale for their decision.

i

.q

' Upon receipt of the Engineering disposition of the 81CR, its empletion by constnx: tion, and its acceptance by Quality 4

Control, a copy of the emplete NCR is:

i 1

l

1) Transmitted to CPCo Field Quality Assurance, if the Bechtel decision is to accept the caA =1ds.

2) acuted to construction to initiate appropriate action to prevent recurrence.

3) Routed to Bechtel site Quality Assurance for evaluation and use in determining the need for cearrective action to prevent recurrence.

The entire process described above is monitored throughout by Bech 1 Quality Assurance. They review the various steps 1

as nece

, and may request additional actions or clarifications at any step. They also audit the entire ca^=1d%g process at periodic intervals.

Criterion No.1 of Appendix A to 10 GR 50 states: " Structures, systems and my.ue.nts inportant to safety shall be designed fabricated, erected and tested to quality standards ommensurate with the inportance of the safety functions to be performed...".

It is the opinion of the staff that although the proposed procedure may be acceptable for application to areas of little safety significance, it should not be approved beforehand for general use.

Furthernere, the proposed procedure would not provide a level of quality assurance equivalent to that of the regulatory guide.

The staff therefore rs 2------4s that Midland construction practices conform fully to Regulatory Guide No. 1.10.

2.

Regulatory Guide 1.12

" Instrumentation for Earthquakes" - (Rev,1, April 1974)

For the Midland Plant. a response spc, dun analyzer will be included as part of the contro'. rom seismic instruntation in lieu of discrete response spectr e recorders. m is analyzer would <m1 l

& ate the response spectrun, at specific danping valves, for ccmparison to the plant design criteria and evaluation of the earthquake effects.

A response spectrun analyzer, permanently installed in the control rocm will present nere ocmplete infonnation than that presented by response spectrun recorders. Data frm the strong notico accelermeters will be recorded on negnetic tape and then fed into a playback unit that is cable-connected to the response spectrum analyzer to produce earthquake response 5 Wha in==44ately fellowing an earthquake.

Alllocatiohwhereresponsesps,Lamrecordersarerequiredbythe k gulatory Guide will be monitored in 3 directions by strong motion accelermeters. 21s systan will provide all information required by Regulatory Guide 1.12.

We staff has concluded that the information provided by this instrumentation will be at least equivalent to that called for by the regulatory guide and is acceptable to the staff.

1

. 3.

Regulatory Guide 1.15

" Testing of Reinforcing Bars for Caery I Concrete Structures" - (Rev. 1,_12/28/72)

~

'Ihis guide describes an acceptable method for inplementing general design criteria relating to tests and irspection of reinforcing bars for Category I concrete structures.

Piragraph C.1.a requires a testing frequency of one v tman of each bar size for each 50 tons of material produced. Reinforcing steel procured and used in 1969 and 1970 (before Regulatory Guide 1.15 was issued) had a testing frequency of 100 ton. Category I structures constructed in 1969-1970 include the auxiliary bi41aing base mat and sme exterior walls. Upon reactivation of the Midland Project in 1973, project specifications were revised to specify a fr%cy of testing such that one full-diameter specimen is tested frca each bar size for each 50 tons or fraction triereof.

'Ihese requirments have been inplemented since that time..

h staff has concluded that this degree of conformance with this regulatory guide is satisfactory.

Paragraph C l.c of this guide states that the acceptance standards should be in accordance with the A9IM A-615-72, " Standard Specification for Deformed Billet-Steel Bars for Concrete Reinforcement",

American Society for Testing Materials, including supplemental Requirement (S-1) using full sections of the bars as rolled.

h applicant proposed that the acceptance criteria for any failed test (Qualification as well as In-Process) shall be the same as that for tensile tests specified in Subarticle Cr-2331.2 of ASME Section III, Div. 2 Code. Ihis means that if a test specimen fails to meet the specifiM strength requirments, two (2) additional specimens frun the tc'e heat and of the same bar-size shall be tested, and if either of the tw additional specimens fail to meet the specified strength requirements, the material represented by the tests shall be rejected for the specified use.

. The applicant also proposed that alternative use of rejected material under strict control may be ude subject to evaluation by the Project Engineer.

The staff has found that the proposed acceptance criteria are identical with those of the Standard Review Plan and are described in paragraph CC-2331.2 of ACI/ASME (ACI-359) " Standard Code for Concrete Reactor Vessels and Contaiment", April 1973, and are acceptable. However, the staff considers the altemate use of rejected material to be beyord the scope of this regulatory guide.

O s

v

. 4.

Regulatorv Guide 1.18

" Structural Acceptance Test for Casacrete Primary Reactor Contaiments" - (Rev. 1, 12/28/72) a) Guide Remmerziation:

This guide describes an acceptable method of performing the initial structural acceptance test which deonstrates the capability of a concrete primary contalment to withstand postulated pressure loads. Paragraph C.5 refers to the measure-ments which would be rew-craled for a prototype cen%iment, i.e., a containment that incorporates new or unusual design features, mese include strain measuranents in the concrete sufficient to permit a cmplete evaluation of strain distribution in the walls of the contalment knilding.

We applicant subnits that both Turkey Point and Palisades were M ted for strain measurements and data gathered during their Structural Integrity Tests (SIT). Although not empletely identical to Midland, the applicant considers Turkey Point and Palinadaa to adequately represent Midland as its prototype, based on this data. Furthermore, the Midland contaiments are similar to the Bechtel designed contaiments at Arkansas Nuclear One, Units 1 and 2.

The Arkansas' units are a three buttress systen with 1,000 ton capacity tendons, as is Midland. Unit 1 containment has undergone SIT but was not instrunented for strain measuranents. The displacements measured at selected points during this SIT agreed well within acceptable limits with the predicted response. In addition, no unusual response, either in terms of displa<,amants or cracking, was noted.

Based on this satisfactory performance of these similar contaiment buildings, the staff has concluded that the Midland contaiment building need not be subject to prototype testing and strain measurements are not s 'accary.

However, the staff

reccumends full.conformance to the other provisions of this guide including subtittal of a test plan prior to gws of the test and in accordarce with section c.12 of this guide.

i l

O

~ 5.

Regulatory Guide 1.19

" Nondestructive E n mination of Prima.w Containment Liner Welds" - (Rev. 1, 8/11/72)

This guide describes acceptable gvciddres for implementing the criteria for leaktightness of the primary contaiment liner i

and its penetrations. Frequency and methods of testing of welds in a liner are based upon ASME Boiler and Pressure Vessel (bde Sections III and V to assure a uniform quality level consistent with the safety function of contciment liners.

Se Midland requirements for nondestructive e.umination of liner plate welds ccuply with Regulatory Guide 1.19, except for the testing frequencies, which are in accordance with proposed ASME Pressure Vessel Code Section III Div. 2 as issued for trial use and connent in 1973.

In ht No. 23 to the application for construction permits for Units 1 and 2 of Midland Plant the applicant described the proposed requirments for non-destructive examination of seam welds on the reactor building contaiment liner plate and p.atrations.

These requirements have been reviewed by the Regulatory siaff and it has been found that they ccupare favorably with: ASME Pressure Vessel Code, Division 1,Section VIII, the ACI/ASME Section III, Division 2, Sub-sub Article Cr 5520 5520 and Regulatory Guide 1.19.

Based on the considerations:

(a) that all welds will at least satisfy the requirements of the ACI/ASM8 Code and exceed the require-ments of the ASME Pressure Vessel Code, (b) that all seams will be individually tested, and (c) that an integrated leak rate test will be perfonned in the finished contaiment, it has been concluded that satisfactory assurance exists that the welds will be able to carry all postulated loads. Werefore, the requirements for non-destructive examination of the seam welds of the reactor building containment liner plate and penetrations are acceptable as set forth in ATardrent No. 23.

t 9-6.

Pegulatory Guide 1.35

" Inservice Inspection of Ungra*d Tendans i

in Prestressed Ccia. rete Containment Structures" - (Rev. 2, Jan. 1976)

This guide dawiMs a basis for developing an appropriate i

inservice inspection and surveillance program for ungrouted tendons in prestressed concrete containment structures of light-water-cooled

{

reactors.

i l-The applicant stated that the Midland Plant will conform to the r+3--+dations of this guide as daeribed in Bechtel topical report BC-70P-5A, Rev. 3 (2/75). However, that report allows indivirbal i

l plants to take exception to the pv--Mares given therein. Such an i

I exception was presented in the applicant's PSAR with respect. to the ntnber of tendons tested during the 1, 3 and 5 year inspections.

However, the applicant stated that the test schedule in the PSAR will be rev h to agree with the regulatory guide.

}

Bechtel topical report BC-4tP-5A, (February 1975) has been A

reviewed and approved by the angulatory staff for use on a ntaber of other nuclear plants with characteristics similar to those of j

the Midland Plant.

The staff has concluded that the inspection program defined by BC-70P-5A and Regulatory Guide 1.35 is suitable for the Midland Plant.

l'

)

4 4

1 1

-,-,.._,...w e.,e,.,

,-_-,,g,

,r__,..

m,,

w,,

,,-,-w--,..m.,

,.,.,..~,,y

- 8.

Regulatory Guide 1.60

' Design Resoonse Spectra for Seismic Design of Nuclear Power Plants" - (Rev.1, Decerrber 1973) and Regulatory G'4Aa 1.61 "Dancin ilues for Seismic Design of Nuclear Power Plants" -

(October 19..

Wese guides provide response spectra and damping values as given in a paper by Newark, Blume and Kapur entitled " Seismic Spectra for Nuclear Power Plants" published in the Journal of the Power Division, Novrstber,1973.

We Midland design response spectra differs fran that of Regulatory Guide 1.60 and was established and in use on Midland and other nuclear power plants before issuance of this guide.

W e Midland Plant Design Response Spectra are shown in figures 5-A-1 and 5-A-2, Section 5 (Appendix SA) of the PSAR for the design and maximum

, respectively. Rese sps L.a correspond to maximum rizontal ground acceleration of.06g for the design earthquake and 0.129 fur the maximan earthquake.

h e damping factors utilized in the Midland Plant design are those rr,'-- erded by Newmark & Hall as presented at the Fourth World Earthquake (bnference, February,1969 in the paper entitled " Seismic Design Criteria for Nuclear Reactor Facilities".

Furthernere, the applicant has stated that the seismic analysis of buried pipe lines will be based on the principles contained in the Bechtel topical r.eport BC 'IOP-4A Rev. 3, " Seismic Analysis of Structures and Equipnent for Nuclear Power Plants," Bechtel Power Corporation, Noverber 1974.

2G staff has fourd that although the Midland response spectra are less conservative than those of Regulatory Guide 1.60, the damping values are nore conservat.im than those of Regulatory Guide 1.61.

l We cambined effect resu hs in design values for the Midland Plant that are carparable to those that would be obtained fran use of the regulatory guides.

l' 9

. + -, _., -- -

l s

11 -

'Ihe staff has concluded that the seismic design of the Midland Plant is conservative and is acceptable to the staff. Furtisempre, the staff has reviewed the Bechtel topical report BC M -4A and has found the design criteria and procedures acceptable for use on the Midland Plant.

1 i

l 1

l l

i i

1 l

3

-u.

9.

Regulatory Guide 1.92 "Cmbinations of Modes and SpaHa1 %;ts in Seistric Response Analysis" - (December 1974)

This guide indicates that if individual mechanical response nodes are not closely spaced, the square root of the sun of the squares procedure should be used for cmbirdng individual mode respxises but if their individual frequencies differ by less than 10 percent, then they should be ccarbined by their absolute sun.

The applicant has stated that the sum of the absolute values fran the modes.which correspond to natural frequencies below 33 cps was used.

The staff has concluded that the procedure used by the applicant is more conservative than that re ---14ed by this guide and is acceptable to the staff.

4 l

l

-