ML20053B340

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Requests Addl Info Re Spent Fuel Pool Structural Adequacy Analysis,Within 14 Days.Addl Errors & Deficiencies Identified by NUS-3567,Revision 1 Audit Review Encl
ML20053B340
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 05/21/1982
From: Lainas G
Office of Nuclear Reactor Regulation
To: Vandewalle D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
LSO5-82-05-048, LSO5-82-5-48, NUDOCS 8205280311
Download: ML20053B340 (9)


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May 21,1982 i

Docket No. 50-155 LS05-82-05-048 Mr. David J. VandeWalle Nuclear Licensing Administrator Consumers Power Company 1945 W. Parnall Road Jackson, Michigan 49201

Dear Mr. VandeWalle:

SUBJECT:

SPENT FUEL P00L STRUCTURAL ADEQUACY - BIG ROCK POINT During the review of a question regarding the adequacy of the spent fuel pool to retain its integrity upon the loss of spent fuel pool cooling, errors were found by the staff in the analysis of record performed by NUS Corporation and submitted by Consumers Power Company in their letter dated June 20, 1980. Consumers Power Company was requested to re-review the entire analysis and correct it as needed.

In response to this request, Revision I to the above mentioned NUS report (NUS-3567; Revision 1, dated April 27,1982) was prepared and submitted. The staff has determined from an audit review that several basic errors and deficiencies exist in the revised analysis (Enclosure 1). The errors and deficiencies are such that the analysis is not sufficient to assure the structural integrity of the pool would be maintained if pool cooling is lost.

While we are looking at these issues in connection with developing staff testimony for the ongoing proceeding relating to your proposed expansion of the spent fuel pool, these errors and deficiencies are such as to raise questions concerning the adequacy of the spent fuel pool to retain its integrity upon the loss of spent fuel pool cooling under existing pool loading conditions.

For this reason, under the provisions of 10 CFR 50.54(f),

the licensee is directed to provide within 14 days of the date of this letter the following information signed under oath and affirmation, to enable the Commission to determine whether or not the Big Rock Point license should be modified, suspended, or revoked:

1.

A justification of why continued operation of the facility should be permitted considering safety grade equipment is not available to cool the pool and access could be limited by a LOCA.

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2.

A corrected revision of the current analysis of record for the spent fuel pool structure.

3.

A schedule for either (a) a comprehensive analysis of the spent fuel pool structure that shows the pool would retain its integrity when toraconsideration is given to appropriate analytical techniques and reductions of concrete strength to levels commensurate with those appropriate for the type of concrete andeconditions of exposure (greater than those proposed by the licensee in their analysis of record), or (b) provision of safety grade design features to assure that the spent fuel pool cooling can be maintained without access to the containment.

Sincerely.

Gus C. Lainas, Assistant Director for Safety Assessment Division of Licensing

Enclosure:

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Sincerely, Darrell G. Eisenhut, Director Division of Licensing

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h Docket No. 50-155 LS05-82 Mr. David J. VandeWalle Nuclear Licensing Administrator Consumers Power Company 1945 W Parnall Road Jackson, Michigan 49201

Dear Mr. VandeWalle:

SUBJEET:

SPENT FUEL P00L STRUCTURAL ADEQUACY - BIG ROCK POINT During the review of a question regarding the adequacy of the spent fuel pool to retain its integrity upon the loss of spent fuel pool cooling, errors were found by the staff in the analysis of record performed by NUS Corporation and submitted by Consumers Power Company in their letter dated June 20, 1980. Consumers Power Company was requested to re-review the entire analysis and correct it as needed.

In response to this request, Revision 1 to the above mentioned NUS report (NUS-3567, Revision 1, dated April 27,1982) was prepared and submitted. The staff has determined from an audit review that several basic errors and deficiencies exist in the revised analysis (Enclosure 1). The errors and deficiencies are such that the analysis is not sufficient to assure the structural integrity of the pool would be maintained if pool cooling is lost.

Under the provisions of 10 CFR 50.54(f), the licensee is directed to provide within 14 days of the date of this letter the following:

1.

A justification of why continued operation of the facility should be permitted considering safety grade equipment is not available to cool the pool and access could be limited by a LOCA.

2.

A corrected revision of the current analysis of record for the spent fuel pool structure.

3.

A schedule for either (a) a comprehensive analysis of the spent fuel pool structure that shows the pool would retain its integrity when consideration is given to appropriate analytical techniques and reductions of concrete strength to levels comensurate with those appropriate for the type of concrete and conditions of exposure (greater than those proposed by the licensee in their analysis of record), or (b) provision of safety grade design features to assure that the spent fuel pool cooling can be maintained without access to the containment.

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Docket No. 50-155 L505-82 Mr. David J. VandeHalle Nuclear Licensing Administrator Consumers Power Company 1945 W Parnall Road Jackson, Michigan 49201

Dear Mr. VandeWalle:

SUBJECT:

SPENT FUEL P0OL STRUCTURAL ADEQUACY - BIG ROCK POINT During the review of a question regarding the adequacy of the spent fuel pool to retain its integrity upon the loss ofsspent fuel pool cooling, errors were found by the staff in the analysis of record performed by NUS Corporation and submitted by Consumers Power Company in their letter dated June 20, 1980. Consumers Power Company was requested to re-review the entire analysis and correct it as needed.

In response to this request, Revision 1 to the above mentioned NUS report (NUS-3567, Revision 1, dated April 27,1982) was prepared and submitted. The staff has determined from an audit review that several basic errors and deficiencies are such that the analysis is not sufficient to assure the structural integrity of the pool would be maintained if pool cooling is lost.

Under the provisions of 10 CFR 50.54(f), the licensee is directed to provide within 14 days of the date of this letter the following:

1.

A justification of why continued operation of the facility should be permitted considering safety grade equipment is not available to cool the pool and access could be limited by a LOCA.

2.

A corrected revision of the current analysis of record for the spent fuel pool structure.

3.

A schedule for either (a) a comprehensive analys.is of the spent fuel pool structure that shows the pool would retain its integrity when consideration is given to appropriate analytical techniques and reductions of concrete strength to levels comensurate with those appropriate for the type of concrete and conditions of exposum (greater than those proposed by the licensee in their analysis of record), or (b) provisionsof safety grade design features to assure that the spent fuel pool cooling can be maintained without access to the containment.

Sincerely, AD:SA:DL D:DL 0 ELD OELD Glainas DEisenhut RGoddard JScinto 5/ /82 5/ /82 5/ /82 />O g / /82

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Mr. Paul A. Perry, Secretary U. S. Environmental Protection Consumers Power Company Agency 212 West Michigan Avenue Federal Activities Branch Jackson, Michigan 49201 Region V Office ATTN:

Regional Radiation Representative Judd L. Bacon, Esquire 230 South Dearborn Street

' Consumers Power Company Chicago, Illinois 60604 212 West Michigan Avenue Jackson, Michigan 49201 Peter B. Bloch, Chairman Atomic Safety and Licensing Board Joseph Gallo, Esquire U. S. Nuclear Regulatory Commission Isham, Lincoln & Beale Washington, D. C.

20555 1120 Connecticut Avenue Room 325 Dr. Oscar H. Paris Washington, D. C.

20036 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Peter W. Steketee, Esquire Washington, D. C.

20555 505 Peoples Building Grand Rapids, Michigan 49503 Mr. Frederick J. Shon Atomic Safety end Licensing Board Alan S. Rosenthal, Esq., Chairman U. S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Board Washington, D. C.

20555 U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Big Rock Point Nuclear Power Plant ATTN: Mr. C. J. Hartman Mr. John O'Neill, II Plant Superintendent Route 2, Box 44' Charlevoix, Michigan 49720 Maple City, Michigan 49664 Christa-Maria Mr. Jim E. Mills Route 2, Box 108C Route 2, Box 108C Charlevoix, Michigan 49720 Charlevoix, Michigan 49720 William J. Scanlon, Esquire Chairman 2034 Pauline Boulevard County Board of Supervisors Ann Arbor, Michigan 4B103 Charlevoix County Charlevoix, Michigan 49720 Resident Inspector Big Rock Point Plant Office of the Governor (2) c/o U.S. NRC Room 1 - Capitol Building RR #3, Box 600 Lansing, Michigan 48913 Charlevoix, Michigan 49720 Herbert Semmel Counsel for Christa Maria, et al.

Urban Law Institute Antioch School of Law 263316th Street, NW Washington, D. C.

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Mr. David J. VandeWalle CC Dr. John H. Buck Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Ms. JoAnn Bier 204 Clinton Street Charlevoix, Michigan 49720 Thomas S. Moore Atomic Safety and Licensing Appeal Board

. U. S. Nuclear Regulatory Commission Washington, D. C.

20555 James G. Keppler, Regional Administrator Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 4

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I ENCLOSURE ADDITIONAL ERRORS AND DEFICIENCIES IDENTIFIED BY AUDIT REVIEW 0F NUS-3567, REV. I 1.

Pages 12-41 and 12-42 indicate that the walls are assumed (with no backup calculations) to be simply supported at their tops.

Drawings indicate that the steel framing and steel plate flooring supported from the top of the walls are not adequate to support this assumption.

2.

The thermal loading analysis contained in Section 12.1.3.4 of the NUS calculations is generally inadequate and contains numerous errors.

Cracked section thennal loads in Section 12.1.3.4 of the NUS calculations have been evaluated using erroneous assumptions and misapplications of the referenced methodology. The neutral axis for the cracked condition is assumed (without basis) to be located at 1/3, the thickness from the compression surface and the resultant rebar force is determined from equilibrium.

Basic concrete design theory indicates that both strain compatibility and equilibrium must be enforced simultaneously to calculate the neutral axis location and resultant forces and stresses. The un-cracked section resultant force profiles are erroneously determined and do not satisfy equilibrium as they should.

Also, erroneous force resultants are used in the NUS cracked equilibrium calculations.

3.

The licensee's reference to ACI Standard 349-69, in the NUS cal-culations, Section 12.1.3.4, is not valid. The first public appearance of ACI 349 was in the February 1975 ACI Journal.

It was accepted as a standard by Committee ballot in June 1976 and published first as ACI Standard 349-76.

The licensee's reference was actually a January 1972 ACI Journal article. A more appropriate reference on the subject of thennal stress analyses for concrete is AC1 Report 349.lR-80, " Reinforced Concrete Design for Thermal Effects on Nuclear Power Plant Structures," 1980.

4.

The steel area associated with #9 rebars at 10 inches on center is erroneouspassumedinNUSca}culation,Section12.1.3.4,tobe 0.8836 in rather than 1.2 in.

5.

In-plane seismic loads from gross structural response on pool structure elements are not considered.

6.

Bond reduction considerations on rebar lap slices were not addressed.

7.

The validity of the assumption of fixed boundaries for the pool walls and floors was not checked considering the in-situ structural configurations, and the construction joints shown on drawings at the wall / floor intersections.

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I 8.

Specification of the wall section depth as "0.8h" for shear capacity calculation is only valid, per ACI 318-77, for evaluating prestressed l

concrete members and walls for in-plane behavior, not for the out-of-l plane strength of the walls and floors they are evaluating.

i 9.

Vertical hydrodynamic forces induced by horizontal accelerations i

during a seismic event are not considered.

Similarly, horizontal hydrodynamic forces induced by vertical motions are not considered.

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