ML20040C326

Forwards Tj Rausch Re NRC Review of Potential Effects of Rock Impacts on Spent Fuel Pool Floor During Postulated Seismic Event

ML20040C326
Person / Time
Site:	Dresden
Issue date:	01/22/1982
From:	Steptoe P ISHAM, LINCOLN & BEALE
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8201270532
Download: ML20040C326 (1)

Text

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31 ma ma January 22, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION THE ATOMIC SAFETY AND LICENSING B'OARD In the Matter of

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Docket Nos. 50-237-SP COMMONWEALTH EDISON COMPANY

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50-249-SP

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(Spent Fuel Pool (Dresden Station, Units 2 & 3))

Modification)

Dear Administrative Judges:

Enclosed is recent correspondence between Common-wealth Edison and the NRC Staff concerning the Staff's review of the potential effects of rack impacts on the Dresden spent fuel pool floor during a postulated seismic event.

For the most part the letter contains background information for the NRC Staff's consultant.

It is difficult to predict when the NRC Staff's review will be completed, but I'am sure Mr. Goddard will keep you informed.

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Address Reply to: Post Office Box 767 Chicago. Illinois 60690 January 20, 1982 Mr. Dennis M.

Crutchfield, Chief Operating Reactors Branch 5 U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Dresden Station, Units 2 ano 3 High Density Spent Fuel Storage Racks Seismic Analysis NRC Docket Nos. 50-237/249

Dear Mr. Crutchfield:

On December 1, 1981, Commonwealth Edison (CECO) received a copy of an internal NRC memo (Reference 1)* from Owen Rothberg to Paul O'Connor regaroing the report submitted to the NRC on October 2, 1981 (Ref. 16).

As will be shown herein, this (Ref. 16) report was of limited scope ano not intended to be a complete seismic analysis report.

Following some preliminary discussions, a conference call was held on December 22, 1981, among Paul O'Connor and Owen Rothberg of the NRC, Gunnar Harsted (the NRC consultant), and Tom Rausch and Laird Woldridge of CECO.

During this call, CECO was requested, and agreed, to respono in writing to the comments in the above NRC memo, including giving all background information necessary to understand the reasons for our analysis basis or assumptions.

Please also refer to the Introduction section of the October 2,1981 submittal (Ref. 16).

As described there, it is our understanding that the l

present NGC review is to determine the effects of postulated rocking of the racxs on the pool floor and walls, and that the NRC has no safety concern with respect to the structural adequacy of the racks.

The NRC comments (per Ref.17) and our responses follow:

1. Comment:

Use procedures described in submittal of September 30, 1981 as submittal basis, disregard previous submittals.

Response

It is our understanding from this comment, that the report of September 30, 1981 (submitted October 2, 1981) was the only basis for the review.

However, during the call of Decemoer 23, 1981, it was ascertaineo that the NRC cid consider other material, some dating back to 1979.

6All references in this letter are listed in chronological orcer in k

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. In the remaining responses, we will attempt to tabulate all applicable earlier material.

2. Comment:

Use coefficient of friction values of 0.2 and 0.8 as well as 0.5 for analysis cases.

Response

Values of 0.2 and 0.8 were used in the analyses for the Licensing Report (Ref. 4) as noted in Section 3.4.3.1 o f that report.

The NRC Safety Evaluatica (Ref. 3) stated in Section 3.4.2 that the structural and mechanical analyses were in accordance with accepted criteria.

In Section 3.4.1.1, the seismic analyses, time history analyses, and friction coefficients were specifically addressed.

For the October 2, 1981 report (Ref.16) the concern was not to completely reanaly?.e the racks and pool, but to demonstrate that the origins 1 analyses were suf ficiently conservative, in light of NRC SEP concerns about the seismic analysis methods, and to address rack-to-pool floor impacts. The CECO. approach suggested to the NRC during a conference call on July 23,1981 (Ref.15) included use o f a median value for the coefficient of friction as being most realistic.

The NRC concurred and suggesteu the commonly used MIT study which indicated a mean value of 0.503.

Since the rocking-sliding analysis reported in Reference 16 considered the response of a large number of racks (33 racks) involving even a larger number of leg-floor interfaces, the use of this mean value can be considereo as the "best-estimate" value, and no new analysis is deemed necessary.

3.

Comment:

Use 3 independently generated time histories of pool floor.

It is not necessary to develop a floor response spectrum at the pool floor.

Response

There is no current requirement to use multiple time history analyses.

The Dresden Station and, as f ar as we can determine, all previously licenseo free standing fuel racks have been analysed using only one time history.

This and other recent NRC requests to use multiple time history analyses apparent.ly originate from NUREG/CR-1161 (Ref. 2), which " recommends changes in the

. criteria now used in the seismic design of nuclear plants".

We are not aware of any actual adoption of these recommendations, nor of any other such requirement.

Please refer to the discussion in Page 1-2 of Reference 16, wherein, "the possible sensitivity of the nonlinear response to the change in the input time history and to the change in the friction coef ficient" was considered by way of selecting an input ground response spectrum having 54 percent higher

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. Zero Period Acceleration and much more frequency content than the applicable site-specific response spectrum.

Additionally, the ef fect of peak-broadening of the floor response spectrum, which was used in Reference 16, is similar to the effect of using miltiple time-history and is a commonly used method.

In fact, the use of a time-history compatible with a peak-broadened floor response spectrum can account for time-history sensitivity more completely than the use of three arbitrary time-histories.

Thus, we maintain that we have used recognized and proven methods compatible with published NRC requirements, and that no additional analysis is necessary to establish the conservatism of the. loads for which the rack and the pool structures have been evaluated.

We would also like to point out that the use of multiple time histories for certain analyses is only one of many recommendations in NUREG/CR-1161.

Imposing only one recommendation, without considering all of them, could be either ultra-conservative or non-conservative.

It certainly does not appear that the NUREG suggested such an approach, but rather suggested an overall revision of requirements.

Moreover, the conclusion of NUREG/CR-ll61 seems to be that existing analysis methods are overly conservative, and that adoption of its recommendations would reduce conservatism.

In support of this conclusion we quote:

a.

Section IV. B (page 41) "The use of time histories for which the response spectra envelop the oesign respose spectra.

. tends to artifically introduce an added and unnecessarv conservatism.

This same statement is found in Appendix C, Section 5.1 (page 147).

b.

Appendix D (pages 186 and 187) "This requirement (the present requirement) imposes an additional significant FUC (factor of conservatism)

Appendix D (page 193) "was proposed to... lead c.

to the elimination of conservatism.

d.

Appendix 0 (page 201)

"I do not agree with the recommonaation.

., a single artificial time history with a response spectrum which envelopes a broad base design spectrum is more than sufficient".

The above review of NUREG/CR-ll61 is not intended to evaluate the worth of its recommendations, out only to show that the requested analyses may not provide results which are any more valid than those obtained from the

a

. analysis used in the October 2,1981 submittal (Ref.16).

Thus, it is our position that we have used recognized, long standing, and proven methods, that no other analyses are necessary to demonstrate the suitability of the subject fuel racks, and that the methods we have used are probably more conservative that those recommended in NUREG/CR-ll61 and those suggested in Comment No. 3 above.

4. Comment:

Revise model to include fuel assemblies so that the time history record will include fuel assembly impact.

Therefore a " rattle factor" would be unnecessary.

If a

" rattle factor" is used, justify the apparently low value o f 1. 0 8-1. 4 8.

Response

A " rattle factor" was not used. As is described in Section 3.2 and Figure 3-1 o f the October 2,1981 submittal (Ref. 16), the analysis model included the fuel and the gap between the fuel and the rack.

Therefore, the fuel will impact (rattle) as dictated by the effect of the time history.

As is stated, this analysis " assumed that all of the fuel assemblies in a rack will " rattle" in-phase", which is conservative.

Since the dynamic response resulting from this analysis was less than that obtained in the earlier analysis (Ref. 4), in which " rattle factors" were used to account for the nonlinear behavior resulting from gap, we do not consioer it necessary to justify the value of the " rattle-factors" used, as these no longer formed the design-basis.

5. Comments:

Calculate hydrodynamic ef fects in accordance with classical theory rather than simply by adding mass of external water.

Response

The effect of hydrodynamic mass was considered using the commonly-used virtual or added mass concept as outlined in the report, "Ef fective Mass and Damping of Submerged Structures" (Report No. UCRL-52342).

This is an NRC-sponsored study report, and the OT position paper (Ref.

1) considers its recommendations on the use of added mass as acceptable.

This was earlier discussed with Mr. Herring of the NRC who also concurred with such representation of hydrodynamic mass.

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6.

Comment:

In calculating capacity, do not take credit for shear friction.

Use slab formulas from ACI 349.

Response

The slab capacity baseo on diagonal shear, as noted in Section 4.2 of the September 30, 1981 submittal is based on ACI 349.

The report states " flexure ano shear friction capacities are much higher".

The report does not actually take credit for these higher capacities.

However, since the slab evaluation described in the October 2,

1981,

. submittal is based on higher shear loads, and since the slab capacity was founo to be adequate even without taking credit for shear-friction, no further evaluation is deemed necessary.

The NRC verbally advised CECO that the question on use of shear friction came from a 1979 transmittal, however the NRC has not provided a specific reference and a search of questions and responses has failed to find any reference to use of shear friction.

7.

Comment:

Provide data on dimensions and tolerances of fuel assemblies and tubes as well as fabrication tolerances.

Justify the tube dimensions and center-to-centdr Spacing for all conditions.

Response

The structural calculations were baseo on nominal dimensions.

Because of the requirement to meet the overall rack dimensions, any plus or minus cell dimensions would average to near the nominal dimensions and little change in results would occur.

The gap between the fuel and/or fuel channel and the cell walls is accounted for in the analytical model.

Fuel rack drawings have been provideo to the NRC and it is our understanding from the Decemoer 22, 1981 call (Ref.18) that no additional information is needed.

8. Comment:

Present all pertinent numerical values of results of design analysis with respect to loads, stresses, deformations and movements for both the racks and the SFP walls and floor.

Response

The requested data is presented in the Licensing Report (Ref. 4).

The October 2,1981 submittal was of limited scope and did not concern most of the requested analysis results.

Furthermore, it would be misleading to combine the October 2, 1981 results with earlier results because of the differences in input and type of analysis.

l The intent of the October 2,1981 report was to substanti-ate the earlier analyses and to address rack-to-pool floor impacts, anc was not intended or required to be a complete analysis.

to or leading up to the subject analysis.We have attempted to list all material and.

This list is attached as In response to an additional request from Mr. P.W. O'Connor, ce are attaching a letter and curves from Quadrex Corp. (formally

-Nuclear Services Corp.) as Attacnment 2.

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. One signed original and thirt transmittal are provided for your use. y-nine (39) copies of this If you have any questions on the above, please contact this office.

Very truly yours, f kW Thomas J. Rausch Nuclear Licensing Administrator Attachments cc:

Region III Inspector - Dresden Region III Inspector - Quad Cities mnh/1m 3276N

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Chronological Listing of Relevant Events and Transmittals i '

Ref. No.

Date Item I

1.

4/14/78 "0T Position for Review and Acceptance of Spent Fuel Storage and Handling Applications" issued to all reactor licensees.

Amended 1/18/74.

2.

2.

5/-/80 NUREG/CR-ll61, " Recommended Revisions to Nuclear Regulatory Commission Seismic Design Criteria".

3.

6/6/80

" Safety Evaluation by the Office of Nuclear Reactor Regulation Relating to the Modification of the Spent Fuel Pool, Provisional Operating Licensing i

No. DPR-19 and Facility Operating License No. OPR-25, Commonwealth Edison Company, Dresden Nuclear Power Station Unit Nos. 2 and 3, Docket Nos.

50-237 and 50-249".

f 4.

1/19/81 Date of Rev. No. 5 (Current) of the

" Licensing Report, Dresden Nuclear Power Plant Units 2 and 3, Spent Fuel Rack Modification".

Rev. No; O was dated December 30, 1977.

l 5.

4/29/81 Conference call (NRC/ CECO /NSC).

NRC presented concerns regaroing tilting and sliding analysis.

6.

5/5/81 Date of Af fidavit of Anand K. Singh regaroing seismic issues at Dresden.

(

7.

5/13/81 NRC request for additional information l

(4 questions).

This request expanded l

scope of Ref. 5 above.

l 8.

6/8/81 CECO. response to Ref. 7 submitted to NRC (response dated 6/5/81).

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Con't Chronological Listing ni_ Relevant Events and Transmittals l

Ref. No.

Date Item 9.

6/9/81 Meeting held between~NRC and SEP plant owners group to discuss si,te specific spectra and methods for use.

10.

6/12/81 Letter sent by CECO. to Licensing Board informing Board of NRC concerns and CECO. response.

Included an explanation, a " Rack-to-Hack Impact Evaluation," and Ref. 8 above.

11.

6/19/81 Conference call (NRC/ CECO.).

NRC presented 6 additional concerns.

12.

6/30/81 Meeting in Bethesda (NRC/ CECO./NSC).

Discussed CECO. responses to Ref. 11.

NRC presented 5 additional concerns.

13.

7/17/81 Meeting in Bethesda (NRC/ CECO./NSC).

NRC expressed concerns with original NRC review of Licensing Report (Ref.

4).

The NRC stated that only floor loads were any longer of interest.

The NRC consolidated their concerns as noted in Ref.14 below.

CECO.

presented draf ts of the proposed responses to 7 earlier NRC requests (date not documented).

Based on this meeting, the drafts were never finalized or submitted to the NRC, therefore they should not be considered in any formal evaluation.

k4.

7/20/81 NRC issued notes of meeting of 7/17/81 (Ref.13), including draf t response.

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Con't Attacnment 1 Chronological Listing o f Relevant Events and Transmittals Ref. No.

Date Item 15.

7/23/81 Conference call (NRC/ CECO./NSC).

CECO. presented 2 analysis.' approaches to be used in lieu of the multiple time-history analyses requested by the NRC.

The second approach was based on guidelines set forth in the NRC/SEP owners group meeting of Ref. 9 above.

Mr. Russel agreed that the approach was per that meeting except for use of a single time-history scaled to 0.29 and broaded per Reg. Guide 1.60, as being more conservative than the plant specific 0.12g spectrum.

16.

10/2/81 Report QUAD-1-81-928, " Evaluation o f the Effects of Postulated Rocking of l

Racks on Spent Fuel Pool Structures of l

Dresden Nuclear Station Units 2 and 3", Rev. No. O, cated 9/30/81, submitted by CECO.

17.

11/30/81 NRC internal memo from O. Rothberg to l

P.W. O'Connor, "

Subject:

D.esden SFP-Preliminary Recommendations for Final Submittal from Applicant".

18.

12/22/81 Conference call (NRC/ CECO.).

Discussed memo of Ref.17.

CECO. was requested and agreed to provide a written response, l

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December 24, 1981 caso CCT-81-12

• b?Ebk Mr. J. Loird Woldridge Comonwealth Edison Company Station Nuclear Engineering Room 35 West One First National Plaza Chicago, IL 60690

Subject:

Response Spectra and Time History Plots Dresden Station

Dear Mr. Woldridge:

Enclosed are response spectra and acceleration time-history (in 9 unit) plots for Dresden Station. Plots No. 1 through No. 6 were provided to us by URS/ John A. Blume & Associates, San Francisco.

Plots No. 7 through No.10 were generated using the pool floor time-history data (based on El Centro quake ) supplied to us by Sargent & Lundy Engineers, Chicago.

Plot 1 - N-S broadened pool floor response spectrum developed from NRC Reg. Guide 1.60 response time-history and response spectrum generated from synthetic floor time-history of Plot 2.

l Plot 2 - synthetic floor time-history (NS)

Plot 3 - similar to Plot 1 in E-W l

Plot 4 - synthetic floor time-history (EW)

Plot 5 - broadened pool floor response spectrum developed from site specific response time-history in N-S Plot 6 - similar to Plot 5 in E-W Plot 7 - pool floor response spectrum due to time-history of Plot 8 (N-S)

Plot 8 - acceleration time history in N-S based on El Centro quake Plot 9 - similar to Plot 7 in E-W Plot 10- similar to Plot 8 in E-W Att oc h m e.nt 2.

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c __ _ g4 LEED Mr. J. Laird Woldridge December 24, 1981 Comonwealth Edison Company CCT-81-12

. Time history used in our non-linear analysis (refer to our report No. QUAD-1-81-928 dated 9/30/81) is the one given in Plot 2 above.

If you have any questions, please call me.

Sincerely, C. C. Tang Consultant Engineer CCT/bd Enclosures e

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