ML20032C709
| ML20032C709 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 07/22/1981 |
| From: | Nelson T LAWRENCE LIVERMORE NATIONAL LABORATORY |
| To: | Chen P Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20032C706 | List: |
| References | |
| SM-81-194, NUDOCS 8111100762 | |
| Download: ML20032C709 (7) | |
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Lawrence Livermore National Laboratory
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July 22, 1981 SM 81-194 Mr. P. Y. Chen Systematic Evaluation Procram Branch r
Division of Licensing Office of Nuclear Reactor Reg.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear P. Y.:
I have enclosed W. J. Hall's final letter,regarding continued operation of.the Big Rock Point Plant and EG&G's review of the Lacrosse program plan. Note that the Lacrosse review should be used in conjunction with the previous submittals and hichlights those items which have still not been adequately addressed in the program plan.
Sincerely, QW h
Thomas A. Nel.on Structural vechanics Group Nuclear Test Engineerino Division TAN /cg 0007m Enclosures l
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J sly 15,1981.
Mr. T. A. Nelson
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L-90 Lawrence Livermore Laboratory P. O. Scx 808 Livennore, CA 94550 Re: Big Rock Point Nuclear Power Plant -- Docket No. 50-155 LLL Agreement 1523501
Dear Mr. Nelson:
' mments arising from my.r'eview of the Big Rock Point Nuclear Power Plant Coand in particular pertaining to its ibility to accommodate seismic effects follow.
Over the past several months.:I have received the following material for re-
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' view pertaining to this case.
Material originating from Consumers Power Company
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1.
Letter of March 31, 1980 (8 pages) -- Re: Anchorage and Support of Safety-Related Electrical Equipment 2.
Letter of Octob:r 10, 1980 (7 pages) -- Re:
Response to Staff Letter dated August 4,1980 - Proposed Seismic Evaluation Program and Basis for Continued Interim Operation 3.
Letter of January 9, 1981 (20 pages) -- Re:
Preliminary Seismic Safety Margin Evaluation f
4.
Letter of March 26, 1981 (4 pages) -- Re: Anchorage and Support of Safety-Related Electrical Equipment l
19, 1981 (3 pages) -- Re:.SEP Topic.III-6, Seismic Letter of June Design - Proposed Progress and, Justification for Continued Operation I
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Excerpt pp. 53-55, copy from BRP risk analysis 7.
Excerpt pr VI-113lto VI-174,. copy from BRP risk analysis G
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4 Material originating from U. S. Nuclear Regulatory Cormnission l.
Letter of August 4,1980(3 pages plus Attachments 1 and 2) 4.
2.
Letter of April 24, 1981 (5 pages) -- SEP Topic III-6, Seismic De-sign Considerations Big Rock Point 3.
Letter of June 8, 1981 (28 pages) -- Site Specific Ground Response Spectra for SEP Plants Located in the Eastern United States
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Letter of June 22, 1981 (11 pages) -- Summary of Meeting Held with Consumers Power Company to Discuss Se'ismic Design Considerations (SEP Topic III-6) for the Big Rock Point Plant 5
5.
Plot (undated) -- 1 page, ijlustrating USNRC Site Specific Spectrum
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and the 0.12 g anchored REG. Guide 1.60 Spectra (84.1 percentile) employed by applicant for analysis 6.
Copy c' Report entitled " Derivation of Floor Responses -- Reactor Buil ag," prepared by D'Appolonia Consulting Engineers, Inc., June 1978, 62 p.
On June 30, 1981, in conjunction with T. Cheng and W. Paulson a*nd W. T.
Russell, I made a site visit to the Big Rock Point site and participated in technical discussions and a plant inspection.
On the basis of my review of the seismic portions of the risk analysis studies made available to me, and reflecting on the brief discussions at the time of the site visit wherein some of.the uncertainties and gaps in.the analysis were identified, I cannot recommend employing such an approach as a sole basis for continued operations. Such studies, when they encompass rig-orous tota.1 system performance and the interactions therein, can be helpful as a basis for forming an opinion as to the adequacy of expected performance under various conditions of system disturbance.
My brief revieN of the seismic portion of the risk analysis studies suggests that such an overall comprehensive treatment does not c:rrently exist in the present case.
As one might s ; mise from my foregcir.g statements, and irrespective of whether or not the level of earthquakt hazard.is perceived to be low based on recent recorded seismic history, I bel kve reasonably demonstrated adequacy of system resistance to earthquakes is necessary.
In view of the recent seismic quiescence of the region in which the plant is located, and on the basis of the recent USNRC/ TERA s,ite specific studies, i
spectra anchored at 0.11 to 0.12 g horizontal ground ac'celeration appear acceptable in this particular~ case. Alth'ough I appreciate the bases upon which the USNRC site specific spectra were generated, I do wish to note that 9
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Dr. Newmark (prior to his ' death) and I expressed concern verbally that in some cases the amplified regions (acceleration and velocity) were low compared to Standard Reg. Guide 1.60 or NUREG CR/0098 spectra which we' In this case it is my understanding that normally would recommend for'use.
the licensee and his consultants have employed Reg. Guide 1.60 spectra (84.1 percentiie) anchored at 0.12 g horizontal ZPA for safety related structures and the reactor coolant loop; such spectra do contain reasonable accelera -
tion and velocity amplifications and I concur with their use.
Even so, when reviewing the pnysical resistance of critical safety systems in such cases as this, namely older plants, I-recommend particular attention be paid to the margins that may be present to resist overloading from seismic However it is only fair to note that in the case of anticipated low effects.
seismic activity, as in this case, the loading contribution from seismic effects is normally only a small fraction of the total stressing at critical locations, especialiy when compared to allowables.
I subscribe fully to tha content of the April 24, 1981 USNRC letter and shall The site visit reveals that not repeat the contents of that letter herein.
much of the equipment has been reviewed for adequacy of anchorage and sup-port, which is comforting, but much remains to be done (as for example, the walk-through alone, which involves limited inspection at test, i, dicated a n
need for anchoring the control room cabinets, anchoring cranes,. anchoring fire extinguishing equipment, and anchoring some batteries); comments made on the tour suggested that some portions of the equipment have not been exam-In any event, it is my recommendation that this program of up-ined as yet.
grading be pursued rigorously, systematically and promptly.
Obviously I believe the total, system integrity at the reactor coolant pressure boundary should be examined carefully as soon as possible on a documented In this connection I am concerned that the fire water system by system basis.
system with its standard threaded pipe which is relied upon to provide post-incidence. emergency water injection from the intake well, may not possess the desired inherent resistance. This system may not possess the resist-ance to seismic excitation that is believed to exist, and I strongly suggest that an upgraded system be developed and installed in the very> near future, with some degree of redundancy as to water sources, water paths and pumping It appears to me that such upgrading can be done at minimal ex-capacity.
pense, but care must be exercised that the system is an Alternatively it may be necessary which could af i 2ct the system performance.
to strengthen some walls.
In conclusion, the system a. it currently exists may not be as inherently If the licensee resistant to seismic excitation as believed by the licensee.
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4 promptly develops a plan'of action to review and upgrade systems as noted in the USNRC latter of 14 April 1981 and takes steps to execute the re-quired upgrading promptly, then in view of the perceived low seismic hazard I recommend continubd operation in the interim (near term).
4 Sincerely yours, (d-IhM W. J. Hall WJH:efh
- cc:
W. T. Russell, USNRC.
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U:;1TLD STAILS UF '
t'A NUCLEAR REGill. A10RY CC' :. -510'1 CEFORE TiiE ATOMIC SAFFTY AE LICFNSING 60ARD In the Matter of
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CONSUMERS PO'.'ER COMPAdY
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Docket No. 50-155
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(Big Rock Point Plant)
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(Spent Fuel Pool Modification)
CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF RESPONSE TO INTERVEN0RS' REPLY TO LICENSEE'S MOTIONS AND STAFF OBJECTIONS in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mai' system, this 6th day of November,1981.
Herbert Grossnan, Esq., Chairmar Joseph Gallo, Esq.
Administrative Judge Isbem, Lincoln & Beale Atomic Safety and Licensing Board 1120 orniecticut Ave, N.W., r325 U.S. Nuclear Regulatory Connission 1ashington, D. C.
2003i; Washingten, D.C.
20555
- John A. Leithauser Dr. Oscar H. Paris Leithauser and Leithauser, P.C.
Administrative Judge Opal Plaza, Suite 212 Atomic Safety and Licensing Board 13301 Eight *1ile Road U.S. Nuclear Regulatory Commission East Detroit, MI 4G021 Washington, D.C.
20555
- John O'Neill, II Mr. Frederick J. Shon Route 2, Box 44 Administrative Judge Maple City, Michigan 49664 Atomic Safety and Licensing Board U.S. ';uclear Regulatory Commiss. ion-Chri sta-itaria Washingten, D.C.
20555
- Route 2, Cox 108c Charlevoix, MI 49/20 Philip P. Steptoe, Esq.
Michael 1. Miller, Esq.
Ms. JoAnne Bier Isham, Lincoln & Ceale 204 Clinton One First National Plaza Charlevoix, MI 49/20 Suite 4J00 i
Chicago, Illinois 60603
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- Atomic Safety and Licensing Mr. Thomas Danmann Tppeal Board Panel Route 3, Box 241 U.S. Nuclear Regulatory Conmission Charlevoix, MI 49720
!!ashington, D. C.
20555 Judd L. Bacon, Esq.
- Atuaic Safety and Licensing Consuaers Power Co.
Coard Panel 212 West Michigan Avenue U.S. "uclear Regulatory Commission Jackon, MI 49201 Uashington, D. C.
20555 fir. Gordon Howie
- Docketing and Service Section 411 Pine U.S. Nuclear Regulatory Couaaission Boyne City, MI 49712 Uashington, D. C.
20555 Mr. Jim Mills lierbert Scr.rel, Esq.
Route 2, Box 108 Urban Law Institute of Cha rlevoix,111 49720 The Antioch School of Law 1624 Crescent P1 t,
N.W.
Mashington, D. C.
20009
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LL Janice E. Moore Counsel for NRC Staff i
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