ML19329F593

Forwards Summary Status of Reg Guides Reviewed 760608 by Structural Engineering Branch & Addl Discussion of Individual Reg Guides

ML19329F593
Person / Time
Site:	Midland
Issue date:	07/19/1977
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Boyd R Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.010, RTR-REGGD-01.012, RTR-REGGD-01.015, RTR-REGGD-01.018, RTR-REGGD-01.019, RTR-REGGD-01.035, RTR-REGGD-01.057, RTR-REGGD-01.060, RTR-REGGD-01.061, RTR-REGGD-01.090, RTR-REGGD-01.092, RTR-REGGD-1.010 3988, NUDOCS 8007020727
Download: ML19329F593 (12)

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Carisumers 907/ST g

Stephen H. Howell Vice President General Of fices: 1945 West Parnell Road, Jackson, Michigan 49201

• Area Code 517 78J.-0453

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July 19, 1977

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Director of Nuclear Reactor Regulation chh.

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1:IDLA;ID PROJECT DN h ij Docic:T Hos 50-329, 50-330

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STRUCTURAL ENGINEERI:iG EVALUATION CF REGULATORY GUIDE POSITIQUS h

FILE: 0505 SERIAL: 3988 Mr Carl I:niel's June 8,1976 letter transmitted the HRC Staff evaluation of the Consumers Power Company position on Regulatory Guides 1.10, 1.12, 1.15, 1.18, 1.19,1.35,1 57,1.60,1.61,1.90, and 1 92 relative to the Midland Plant. Sub-sequent to your review some of our positions have changed, or require additional clarification due to reinterpretation of Regulatory Guide contents. Also, we wish to advise you of our intended action in those areas where the Staff's position is interpreted to be different from the Consumer's position.

Attach =ent 1 is a Senry Status of each Regulatory Guide reviewed in the Struc-tural Engineering category. Attachments 2 thru 6 provide ' additional discussion on individual Regulatory Guides.

The attached material is for infornation only since IIRC evaluation of the final Midland Plant Regulatory Guide positions vill be perforced during review of the Final Safety Analysis Report which is scheduled for subnittal on September 1,1977 Vi& e %.

Sin-:/j g ccMahaney, Lynch 3urg(al THIS DOCUMENT CONTAINS CC:

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POOR QUAllTY PAGES N ysw es--

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.n Sumary Status Regulatory Guide Comment 1.10 See Attachment 2 1.12 See Attachment 3 1.15 See Attachment 4 1.18 NRC agrees with Midland position 1.19 NRC agrees with Midland position 1.35 NRC agrees with Midland position 1.57 NRC agrees with Midland position 1.60 NRC agrees with Midland position 1.61 NRC agrees with Midland position 1.90-NRC agrees with Midland position 1.92 See Attachment 5 and 6 RB/mf D

..etochment 2 Regulatory Guide 1.10

" Mechanical (Cadweld) Splices in Reinforcing Bars of Categorv 1 Concrete Structures" - (Revision 1, January 2,1973)

The NRC objects to the alternate acceptance criteria prepared for C.S.a. in lieu of Regulatory Guide 1.10.

The alternate acceptance criteria have been eliminated from the engineering specifications, and were not utilized previously during construction. Therefore, the Midland plant now fu'11y complies with Regulatory Guide 1.10 as interpreted by the AEC's " Memo to Attendees, Summary of Meeting with ENRICO Products Inc.", May 8, 1973.

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Regulatory Guide 1.12

" Instrumentation for Earthquakes" (Revision 1, April 1974)

The NRC's evaluation deals only with the substitution of a response spectrum analyzer for response spectrum recorders which was found' acceptable. There were no objections to the applicant's position related to the accuracy and range of seismic instrumentation and the substitution of peak strain gages for peak recording accelerographs. We will, therefore, proceed with procure-ment of this instrumentation in the belief that total agreement *has been reached on this guide.

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Regulatory Guide 1.15

" Testing of Reinforcing Bars For Category I 28, 1972)

Concrete Structures" - (Revision 1, December Subsequent review of our position has shown that an additional clarification This clarification to the regulatory guide for prior work is required.

This is related to bend testing for reinforcing bar sized 14 and 18.

clarification, as provided below, will be added to the end of our position in Paragraph C.1.C:

i The requirements of ASTM A-615 Supplemental Requirement S-1 have been satisfied for over one-half of the sizes 14 and 18, and all of the sizes 11 and smaller reinforcing steel shipped before May 15, 1977. A portion of this reinforcing steel was placed prior to issuance of Regulatory Guide 1.15 and'more than one-half the placed reinforcing steel was subjected to bending equivalent to that specified by Supplemental Requirement S-1 since the reinforcing steel was subjected to bending to the testradius during fabrication.

Size 14 and 18 reinforcing steel shipped on or after May 15, 1977 will satisfy the requirements of ASTM-615 Supplemental Requirement S-1 with fu11' sized specimens.

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Regulatory Guide 1.92

" Combinations of Modes and Spatial Comoonents in Seismic Response Analysis" - (February 1976 Revision)

The applicant's position on this guide was submitted to the NRC by our letter of August 19, 1975. At that time, the Regulatory Guide was interpreted to apply only to structures.

3ince the Regulatory Guide also addresses the design of systems and components required for safety, further review of the applicants' Regulatory The results of this review indicated Guide position was found necessary.

that a revision to the Midland Regulatory Guide position is necessary to reflect the design practices which were used for structures, systems and components.

Qur revised position on Regulatory Guide 1.92 which will be submitted in the FSAR is included as Attachment 6.

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r uctachment 6 Page 1 REGULATORY CUIDE 1.92, REVISION 1 (FEB.,1976)

COMBINATION OF MODES AND SPATIAL COMPONENTS IN SEISMIC RESPONSE ANALYSIS The Midland plant design conforms to Regulatory Guide 1.92 requirements i

with the following exceptions:

Reference Section C-1 of the Regulatory Guide.

1)

This section addresses methods employed to combine the responses of individual modes in response spectrum modal analyses.

The Midland plant building and equipment not within the B&W scope of supply designa either conform with, or make use of, more conserva-tive criteria (i.e., the sum of the absolute values of the maximum response of each significant mode) than this section of the Regulatory Guide.

The Midland Plant Piping design combines all individual modes in one spatial coordinate by the square root of the sum of the squares.

The ef fect due to closely spaced modes addressed in Section C-1.2 is not considered because Midland Plant Piping Stress Analysis was initiated prior to the issue of Rev. O of the Regulatory Guide dated 12/74.

The primary system component analysis in the B&W scope of supply use the square-root-of-the-sum-of-the-squares method for combining The summation is based on frequency and seismic modal responses.

The summation extends beyond the 33 modal participation factors.

cps range.

Reference Section C-2 of the Regulatory Guide.

2)

This section addresses the combination of effects due to three spatial components resulting from seismic analyses of structures, systems, or components.

The design and construction of certain buildings, systems and components was initiated prior to the issue of this Regulatory The effects of earthquakes upon these structures, systems Guide.

and components is considered by taking the absolute sum of the effects calculated for one horizontal component and one vertical At the time the construction permit for the Midland component.

The use of plant was issued, this technique was in general use.

thia technique in lieu of the current Regulatory Guide position is consider,ed acceptable for the Midland Plant based upon the letter from J. M. Hendrie of the AEC to R. M. Collins of Bechtel Power Corporation dated December 21, 1973. The safety evaluation for the Midland plant _was issued on November 12, 1970.

Page 2 The combination of effects due to three spatial components con-

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sidered in the design of piping systems conforms with the require-ments of this section of the Regulatory Guide, The design and construction of structures, systems, and components initiated after issue of Revision 1 of the Regulatory Guide con-forms with the requirements of this section of the Regulatory Guide.

The square-root-of-the-sum-of-the-squares technique for combining the response of three mutually perpendicular earthquakes is used for the primary system component analyses in B&W's scope of supply.

This method is consistent with that recommended by this section of the Regulatory Guide.

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Mr.

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Collins, Vice President Engineering Hechtel Power Corporation P.O. Box 3905 San Francisco, California 94119'

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Dear Mr. Collins:

Thank you for your letter of October 31, 1973 Your further comments on the staff reviev of Dechtcl'c Topical Report BC-TOP-4 and.on my prc'vious letter have been carefully,cramined by our Engineering Group.

An is evident from your Topicci Report BC-TOP-4 and as you also indicate, deepl'y embedded structures,can be best analyzed at the present' time by the use of finite clement ~ techniques.

Furthermore, for structures founded on rock and having no significant coil-structu:e

. interaction, we agree with you that a fixed-base analycic is adequate and acceptabic.

For structurca that arc founded on coil and that are either at grade or shallouly embedded, ve feel that the " coil-spring model"

,that your staff has propocca vill be adequate for those cases where the coil medium is ccmi-infinite with relat'ively uniform phycical properties.

For ot.hcr ' soil conditions, with structures at grade or challowly embedded,'ve feel that the " multiple s o i,1-s p r i n g.mo d el",.,,, g..._.

or tho ' finitc; elenent model li:I.more appropriate. ".Tvo

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recent studiccl,2 confirm these conclusions.

I am attaching a table indicating the staf f's current viev as to acceptable methods for soil-structure inter' action analynes.

This table van presented to the ASME Tack Group

'on Dynnmic Analycic at meetings on' Septonber 20-21-and Novembe r 1-2,19'(3 We are currently evaluating your study of thic cubject, and in recognition of our nupual,intercct in the use of 1cnc time-consuming procedurcs, we are prepared to re-examinc our position when the review is completed.

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M.' Collins ',

r Vith respect.to the AEC criteria for structural dccicn of-.

. e" Category I s truct,urce and"for evhluit'ini the~ e'f fects on

. -. structures of hich-cacrcy pipe breaks outcide the containment, your interpretation of the dif ference between Document ( A), " Structural Decicn Criteria for Catocory I Structules Outside the Containment," and Document (B),

" Structural Decicn Criteria for Evaluating the Effects of Hich-Encrcy Pipe

• Breaks on Catecory I Structures outside the Containraent" is correct.

• phonc two documents verc formulated by our Structural EnCincering Branch carli.cr t

this year as o result of the lack of concistent and uniform criteria and of recognized codes for the evaluation' of the. cffects on structures of hich-encrcy pipe breaks outside containment and for the decicu of Catecory I' structures outside co nt ainment.

Since June of this year, vc have been utilizing thecc two documents in our review of case applica,tions, an appropriate.

Sofore June 1973, Catccory I structural decicn critoria and the effects

, of high encrcy pipe breaks vore reviewed on a project 'oy-j project baci-

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1 For your information,' the 'following procedure hac been and i

is beinc followed in the use of thecc two documents:

s (1)

Document (A), covering the effects on structures of hich-encrcy pipe breaks outside containnent' and' structural design criteria for Category I

, structures outcide the containment, applies to projects that had not reached the en'd ofethe "first' round" construction permit review stacc in the l

Structural Encineerinc Branch by July 1, 1973 It has been transmitted to the applicants no later i,

%- - c.-- th an.th e, ef,irst-round construction pernit reviev t

and is beinc cent to applicant: at the acce2 ance

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review stacc for construction permit applications.

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Document (D), coverinc only the effects of hich-encrcy pipe breakc outside the containment, is intended for plante that vere pact the first-round construction permit review stecc by Ju]y 1, 1973 Thuc, it applies to projects in more advanced

.ntaccs of decica or construction..

To date, Document (B) has been sont, in most c accc, to applicant: for construction permitc.

Uc. c ::p e c t to uce Docuacnt (D) in the future for operatinc licence reviews of plante for which meanc of mitigating the effects of hich-encrcy pi pe -breaks outcide containment have not already been proposed by the applicant and reviewed by the staff..

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DEC 21 373

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Collins.

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.Y Should you have any question as to the applicability of these two documents to any of your projects, vc vill,:.-at your

' request, clarify t'hc matter on a project-by-proj ect basis.

To put the matter of impicmentation dates for the nov scismic ana. lysis requirements a bit more precisely, the nov response spectra and damping factor values (now covered in Regulatory Guidos 1.60 and 1.61) arc applicable to plants docketed for construction permit revicus after. April 1, 1973.

The req.~ i re me n t that all three components of carthquake motion g

be combined in the seismic analysis is applicabic to plants for which the Regulatory staff conducted its construction permit reviev after November 1,'1972.

We do not intend to apply the ncy response spectra / damping values,to plants dockcLed prior to April-1,1973, and the combination of three-components carthquakes to plants whose reviev for construction permits.has been completed prior to November 1, 1972 For both sets of nov requirements the staff has recognised, as noted in my letter of September 4, 1973, the impact on designs of plants already under review, and has succcsted spot-checking' methods to estab.lish an acceptable licensing basis for scismic analysis n'nd design for heavily-impacte,d applications.

With recara

..o your comment on staff requirements for analyt'icci results in the PSAR, it is our intent to require such analyses for those cascs where the staff has determined that previously accepted methods and criteria are not adequate, or where the applicant has proposed a new analytical method that may be nonconservative or that has not been previously published and reviewed in the prof essional literature.

The matter does indeei varrant continued attention by Regulatory Managemedt,.to see that req'uests for analytical results meet the concra'l intent noted above, on the one hand, and, on the other hand, to make sure that such results are requested und carefully reviewed when they are necessary to provide an adequate licensing basis.

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Hendric, Deputy Director for Technien1 Review Directorate of Licensing Enclosuren:

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