ML20053B834
| ML20053B834 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/25/1982 |
| From: | Gallo J ISHAM, LINCOLN & BEALE |
| To: | Bloch P, Paris O, Shon F Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OLA, NUDOCS 8206010269 | |
| Download: ML20053B834 (2) | |
Text
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s ISHAM, LINCOLN & BEALE COUNSELOR $ AT LAW P20 COMECTICUT AVENUE. N W e SUITE B40 l
WASHINGTON. D C. 20036 T T Lim N
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'THREE 5 N tlONALPLAZA
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May 25, 1982
$EEE TELEX 2-6288 Peter B.
Bloch, Esquire Dr. Oscar H. Paris Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U. S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D.
C.
20555 Washingtun, D. C.
20555 Mr. Frederick J.
Shon Administrative Judge Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C.
20555 RE:
In the Matter of Consumers Power Company (Big Rock Point Nuclear Power Plant), Docket No.
50-155-OLA (Spent Fuel Pool Modification)
Gentlemen:
The enclosed letter was telecopied to my client by the NRC Staff on Friday, May 21, 1982.
I received a copy from my client yesterday afternoon.
The letter apparently has not been served on this docket.
The letter requests information which is the subject of litigation in this case (see the testimony of NRC Staff witness Herring and Consumers Power Company witness Sacramo concerning O'Neill Contention IIC).
The letter also estab-lishes a 14-day deadline to Friday, June 4, for the submission of the information, with the implied threat of adverse licens-ing action if the information is not received by that date.
Consumers Power Company
(" Licensee"), through its counsel, will be filing shortly a motion with this Licensing Board to enjoin the NRC Staff from seeking the information set forth in their letter.
In addition, Consumers Power Company, I> sos azoo 03 o au slql em
Peter B.
Block, Esquire Dr. Oscar H. Paris Mr. Frederick J. Shon February 22, 1982 Page 2
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through its counsel, hereby moves the Licensing Board to enter a t;;porary restraining order that bars the 14-day deadline set f,.
forth in the Staff letter from running until after Licensee's motion for an injunction is finally adjudicated on this docket.
Licensee requests that the matter of the TRO be placed on the agenda for Thursday's 10:00 a.m. on-the-record conference call for oral argument and ruling by the Licensing Board at that time.
Counsel apologizes.for the informal nature of this motion.
It was unavoidable, however, due to the fact that counsel was travelling to Michigan today - for the purpose of attempting to settle certain contentions with the Intervenors.
Counsel vill not return to Washington until 9:00 a.m. Thursday, however, Counsel will be prepared to go forward at the time of the 10:00 a.m. conference call.
Respectfully submitted,
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Nay 21,19tt2 gEctmI Docket no. 50.-155 O
L505-82~05-048 gY217g NQLy ycsusy W. David J. VandeWalle Maclear Licensing Administtetor Constners Power company 1945 W. Parns11 Road Jackson, Michigan 49201 Deer Mr. YandeWalle:
SLEJECT: SPERT F11EL POOL STRUCTURAL ADE@RCT - BIG ROCK POINT During the review of a question regarding the adequacy of the spent fee';
pool to ratain its integrity upon the loss of spent fuel pool cooltag, 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 A ne 20, 1960.
Consumers Power Company nes requested to re-review the entire analysis and correct it as needed.
In response to this request.
Revision 1 to the above mentioned MUS report (huS-3567. Revision 1. dated April 27,1982) was prepared and sutaitted. The staff has determined from an audit review that several basic errors and Offciencies exist in the rt: vised analysis (Enclosure 1). The errors and deficiencias are such that the analysis is not sufficient to assure the structural integrity of the pool mould be maintained if pool coolin2 is lost.
While we are looking at these issues in connection with developing staff testimony for the ongoing proceeding relating to your proposed expension of the spent fuel pool, these errors an'd deficiencies are such as to raise cuestions 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 prayistons of 10 CFR 50.54(f).
the licensee is directed to provide within 14 days of the date of this letter the following infomation signed under oath and affinnation, to anable the Concission to detemine whether or not the Bfg Rock Point license should be modified, suspended, or revoked:
j 1.
A.iustification of why continued operetton of (he Neility should be permitted considering safety grade equipent is ret available to cool the pool and access could be limited by a LOCA.
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D. J. VandeWalle 2 A corrected revision of the current analysis of record for the spent fuel pool structure.
3.
A schedule for either (a) a comprehensive analysts of the spent fuel I
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 cannensurate with those appropriate for the type of concrete and conditions of esposvre (greater than those proposed by the Ifeensee in their analysis of record), or (b) provision of safety grade design features to assure thet the spent fuel pool cooling can be maintained without access to the containment.
Sincerely, O
Gus C. Lainas. Assistant Director for Safety Assessment Division of Licensing
Enclosure:
As stated cc w/ enclosure:
See acxt page O
e 9
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_EELOSURE ADDITIORfd. ER?O*.S AO DEFICIDICIES IDENTIFIED BY AUDIT RElilEW OF Nd5-3567. REY. 1 l
l 1.
Pa9es 12-41 and 12-42 indicate that the walls are assumed (wtth no backup calculstions) to be simply supported at their tops. Drewings j
indicate that the steel framing and steel plate floorfog supported from the top of the malls are not adequata to support this assagtion.
l 2.
The thermal loading analysis contained in Section 12.1.3.4 of the i
105 calculations is generally inadequate and contains numerous l
errors.
Cracted section therzul loads in Section 12.1.3.4 of the l
MJS calculations have been evaluated using erroneous assumptions and misapp11 cations of the referenced methodology.
The neutral -
l axis for the cracked condition is assimed (witkut basis) to be located at 1/3, the thickness from the compression surface and i
the resultant rebar force is determined from equilibria. Basic concreta design theory indicates that both strain cospatibility l
and equilibriunt aust be enforced simultaneously to calculate the netttral axis location and resultant forces and stresses. The un-cracked section resultant force profiles are erroneously deterwined r_nd do not satisfy equilibrium as they should. Also, erroneous force resultants am used in the NJS cracted equilibrium calculations.
3.
The licensee's reference to ACI Standard 349-69, in the NJS cal-culations, Section 12.1.3.4 is not valid. The first public app *arance of ACI 349 as in the February 1975 ACI Journal.
It was accepted as a standard by Costittee ballet in June 1976 and i
published first as ACI Standan:! 349-76.
The licensee's referenca i
was acttelly a Jantary 1972 ACI Journal article.
A more appropriate i
reference on the subject of thermal stress analyses for concrete i
is ACI Report 34g.1R-80. " Reinforced Concrete Design for Thermal Effects on Maclear Power Plant Structures.* 1960.
I 4.
The steel area associated with 19 rebars at 10 inches on center is
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erroneousy assumed in MJS calculation. Section 12.1.3.4. to be rather than 1.2 in3 l
0.8336 in 5.
in-plane seismic loads frocr gmss structural response on pool structure eierents are not considemd.
6.
Bond reduction considerations on rebar lap slices were met addressed.
7.
The validity of the assucption of fixed be:mdaries for the pool r
walls and floors was not checked considering the in-situ. structural configurations, and the construction joints shown on drawings at t
the wall / floor intersections.
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2-8.
Specification of the tell section depth as "0.8h" for shear capacity calculation is only valid, per ACI 318-77. for evaluating prestressed conente members and wils for in-plane behavior, not N-tiie out-of-plane strength of the walls and floors they are evaluating.
9.
Vertical hydrodynamic forces induced by horizontal accelerations during a seisn;1c event are not considered.
Siellarly, horizontal hydrodynamic forces induced by vertical actions are not considered.
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