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'O UNITED STATES NUCLEAR REGULATORY COMMISSIOR g[
3 ADVis0RY COMMITTEs ON RtACTOR SAFIGUA 408 A,
WASHINGTON.D.C.30006 7
June.. i982 Honorable Nunzio J. Palladino Chairman U. 5. Nuclear Regulatory Commission
.!ashington, D.C. 20555
Dear Dr. Palladino:
$UBJECT: ACR$ INTERIM REPORT ON MIDLAND PLANT, UNITS 1 AND 2 3-5, 1982, the Advisory Committee on Reactor During its 266th meeting, June Safeguards reviewed the application of Consumers Power Company for a li-This application was conse to operate the Midland Plant, Units 1 and 2.
29, 1982 in Washing-also considered at Subcommittee meetings held on Aprilin Midland, Michigan and ton, D. C., on May 20-21,1982 members of the Subcomittee toured the On May 20,1982 Washington, D. C.
In the course of these meetings the Committee had the benefit'of plant.
discussions with representatives and consultants of Consumers Power Company, and Wilcox Company, techtel Corporation, the Nuclear Regulatory 8abcock The Comittee also had the Commission Staff, and members of the public.
benefit of the documents listed below.
The ACRS reported on June 18, 1970 regarding the construction pennit ap-p11 cation for the Midland Plant; on September 23, 1970 regarding several amendments to the application; and on November 18, 1976 regarding applica-ble 9eneric matters.
The Midland Plant site is located on the south bank of the T1ttabawassee The main industrial River adjacent to the southern city limits of Midland.
complex of the Dow Chemical Company lies within the city limits directly across the river from the site.
There are about 2000 industrial workers within one mile of the site, and the estimated 1980 population was about This makes the Midland 51.400 residents within five miles of the site.
site one of the more densely populated sites at distances close to the Plant.
Each of the two Midland units employs a Sabcock and Wilcon designed nuclear steam supply system rated at 2468 MWt with a stretch power rating of 2552 The Midland Plant is unique in that the heat generated wl11 be used MWt.
not only to produce electricity but also to produce process steam for the Dow Chemical Company plant via a tertiary system.
The Midland plant has been the subject of several major problems related One of these problems to quality assurance during plant construction. fill under several safety-related The relates to the soll SW
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Honorable Nunzio J. Palladino
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June 8,1982 deficiencies relating to' soil fill have led to excessive settlement and some cracking of these structures, and have also introduced questions concerning the adequacy of protection against liquefaction of the granular portions of the fill in the event of strang vibratory motion accompanying an "
The Applicant has proposed and is implementing, under close surveillance by the NRC Staff, remedial measures with regard to the foundation deficiencies.
We are generally satisfied with the approach being taken, subject to confir.
mation of the overall quality assurance program and the seismic design basis. Both of these items are discussed below.
With regard to quality control of design and construction, the report of the NRC Staff's Systematic Assessment of Licensee Performance (SALP) review for 30, 1981 revealed deficiencies in the instal-the period July 1,1980 to June lation of piping and piping suspension systems, in the pulling of electrical cables, and in the handling of problems relating to soils and foundation.
Deficiencies by the Applicant in the handling of soils-related matters have continued to occur, subsequent to issuance of the SALP report. We believe that the NRC Staff is handling the corrective actions for specifically identified quality assurance deficiencies in an appropriate manner.
In -view of the overall concern about Midland quality assurance the 15tc h
should arrange for a broader assessment of Midland's design adequacy and construction quality with emphasis on installed electrical, control, and mechanical equipment as well as piping and foundations.
We wish to receive a report which discusses design and construction problems, their dispost-tion, and the overall effectiveness of the effort to assure appropriate qual 1ty.
Our reservation concerning seismic design relates to the lack of adequate assurance that the Midland Plant will be capable of accomplishing shutdown heat removal for low probability earthquakes more severe than the safe shutdown earthquake (SSE).
The Midland seismic design basis at the con 7
'struction permit stage corresponded to a teil VI, peak ground acceleration For the operating license of 0.12g, employing a modified Housner spectrum.
review, the NRC Staff has reevaluated the original seismic design basis and l
the Applicant and the NRC Staff have agreed on the use of site-specific l
analyses which have led to increases in the design response spectra for frequencies above about 2 cycles /sec.
Historically, no earthquakes stronger than the newly proposed SSE have However, expert opinion differsy-occurred within 200 miles of the Plant.
widely on the'exceedance frequency of the proposed SSE and on the, severity or 1 in at the site of earthquakes whose likelihood is less than 1 in 10 5
10 per year.
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Honorable Nunzio J. Palladino June 8,1982 The kpplicant is currently reevaluating by selective audit the seismic capability of the plant, as originally designed, to withstand the revised SSE.
Measures taken to assure safe shutdown in the event of an earthquake include the use of dewatering to reduce the potential for soil liquefaction.
We recommend that all systems and components important to decay heat removal be carefully evaluated for their ability to accomplish necessary functions in the unlikely event of lower-probability, more severe earthquakes in order to pn ovide the necessary degree of assurance.
This matter should be re-solved in a manner satisfactory to the NRC Staff.
We wish to be kept informed about the resolution of this matter.
We believe that any recom-mendations for changes in the plant resulting from this evaluation should be implemented by the end of the second refueling outage.
The Applicant has agreed to provide core exit thermocouples, a hot-leg-level measurement system, and subcooled margin monitors as instrumentation to detect inadequate core cooling.
Consumers Power Company also plans to include a remotely operable vent on top of both inlet loops to the steam generators; however, Consumers has not committed to supply a high point vent on the reactor vessel head.
This matter should be resolved in a manner satisfactory to the NRC Staff.
The ACRS recomends that the Applicant review further the potential for providing indications of water content or level within the reactor vessel.
The staff of the Applicant includes many personnel who have had nuclear However, operating experience with this 88W type power plant experience.
%b power reactor-is limited, and the NRC Staff is requiring that at least one person having experience on a large commercial PWR be included on each shift for one year. We support the NRC Staff position.
The Applicant's experience with the operation of nuclear power plants should, in principle, place Consumers in a favorable position to provideIn cuntinuing, careful oversight of the operations at the Midland Plant.
view of some prior adverse operating experience at the Palisades Plant however, we recommend that the NRC Staff institute an augmented audit of operations at Midland, at least during the early years of operation at power.
We 'have reviewed the evaluation made of the tertiary process steam system for use by Jow Chemical Company.
This system appears not to impose any unacceptable impaci.s either on the safe operation of the Midland Plant or on the people working at"the Dow Chemical Company.-
The Applicant, has undertaken an effort to have a probabilistic risk assess.
performed for the Midland Plant and stated that the results will
. ment (PRA)le in the fall of 1982.We believe it desirable to have plant.
be availab Specific PRAs performed for each commercial nuclear power plant and that l
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o Honorable Nunzio J. Palladino June 8,1982
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it is particularly appropriate for the Midland Plant because of its rela-tively high, close-in population density. We wish to have the opportunity to review the Midland FRA with assistance from the NRC Staff, and to offer comments or recommendations as appropriate.
We do not believe that this review need delay licensing of the Midland Plant for operation Recently, questions have come to light in connection with 88W plants con-cerning the availability of natural circulstion in the presence of an We wish interrupted or continuing small break loss-of-coolant accident.
to see a proposed NRC Staff resolution of this issue.
The Applicant described an extensive systems interactions study being undertaken for the Midland Plant.
We wish to be informed of the results of this study.
We believe that, in view of the population density near this plant, addi-tional prudence is appropriate for the Midland plant in the resolution of the ATWS issue and other Unresolved Safety Issues.
We endorse the participation of Dow Chemical Company plant personnel in emergency procedures developed on the basis of an assumed failure at the Similarly, there should be active participation by Midland Midland Plant.
Plant personnel in emergency procedures developed on the basis of an assumed failure at the Dow Chemical plant. The Applicant and the IstC Staff
- s, should promote continued coordination of these types of relationships, as well as those involving appropriate state and local groups to assure that the capability for an offactive emergency response is developed and said-tained.
With regard to the eleven items identified in the ACRS Supplemental Report 18, 1976, we have the follow.
on Midland Plant, Units 1 and 2 dated November The issues related to vibration and loose-parts monitoring, ing comments.
potential for axial menon oscillaticns, behavior of core-barrel check valves during normal operation, fuel handling accidents, effects of blowdown forces on core internals, LOCA-related fuel rod failures, and improved quality assurance and in-service inspection for the primary system have all Separation been resolved or are in a confirmatory stage of being resolved.
of protection and control equipment has been accomplished in an appropriate the safety implications of control systems remains an manner; however, Resolution awaits Unresolved Safety Issue directly applicable to Midland. The effect of ECCS completion of the NRC Staff Task Action plan A-47. induced therma part; however, the Unresolved Safety Issue on pressurized therm 1
will apply.
Environmental
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9 June 8.1982 Honorable Nonzio J. Pa11edino
-5 issue which is under review by the NRC Staff and whose resolution will '
apply to the Midland Plant.
Instrumentation to follow the course of an cccident has been resolved in part by the development of revised Regulatory Guide 1.97.
We do not believe that licensing of the Midland Plant for operat'icn need await further resolution of any of the eleven issues dis-cussed above.
The various other satters identified by the NRC Staff as open or confirma-tory in the Safety Evaluation Report should be resolved in a manner satis-factcry to the NRC Staff. We wish to be kept advised concerning resolution of the turbine missile issue..
The ACRS believes that, subject to satisfactory completion cf construction and staffing and if due regard is given to the comments above. the Midland Plant. Units 1 and 2 can be operated at power levels up to 5 percent of full power with reaso.. cele assurance that there is no undue risk tc the health and safety of the public.
We defer our recommendation regarding operation at full power until we have had the opportunity to review the plan for an audit of plant quality and the proposed resolution of the question regarding natural circulation in the presence of a small break LOCA.
Dr. Kerr did not participate in the Committee's review of this matter.
Sincerely, f
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S.
P. Shewmon Chairman
References:
Consuners Power Company. " Midland Plant Units 1 and 2 - Final Safety l
1.
Analysis Report" including Amendments 1-43 l
U.S. Nuclear Regulatory Commission. " Safety Evaluation Report Related l
2.
to the Operation of Midland Plant. Units 1 and 2." NUREG-0793 dated May 1982 i
3.
U.S. Nuclear Regulatory Commission. "NRC Licensee Assessments."
NUREG-0834 dated August 1981 Letter from J. Cook, Consumers Power Company, to J. Keppler. NRC, i
4.
Subject:
Midland Project Response to Draft SALP Report, dated May 17.1982 Letter from J. Cook. Consumers Power Company, to J. Keppler. NRC, 5.
Midlar.d Project Quality Assurance Program Update, dated
Subject:
l April 30,1981
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6-Honorable Nunzio J. Palladino June 8,1982 6.
Letter from J. Hind NRC, to J. Cook, Cons *umers Power Company,
Subject:
Syster,.atic Assessment of Licensee Performance ($ ALP),
dated April 20, 1982 7.
Letter from J. Cook, Consumers Power Company, to H. Denton, NRC,
Subject:
Summary of Soils-Related Issues at the Midland kclear i
Plant, dated April 19, 1982 8.
Letter from K. Drehobl Consumers Power Company, to D. Fischer. ACRS,
Subject:
Midland Project Soils Information, dated April 12, 1982 9.
Statemsnt of Ms. M. Sinclair to ACRS, dated June 4,1982
- 10. Letter from B. Stamiris to Dr. D. Okrent and ACRS Members,
Subject:
Midland OL Review, dated May 29, 1982
- 11. Letter from M. Sinclair to Dr. P. Shewmon, ACRS,
Subject:
Midland OL Review, dated May 28, 1982
- 12. Statement by Dr. C. Anderson to ACRS Midland Plant Subcommittee dated May 20-21, 1982
- 13. Statement by Ms. M. Sinclair to ACRS Midland Plant Subcommittee dated May 20-21, 1982
- 14. Letter from B. Stamiris to D. Fischer and ACRS Members,
Subject:
Soil Settlement and QA Issues, dated May 20, 1932
- 15. Letter from M. Sinclair to Dr. C. Siess, ACRS,
Subject:
Midland Soil Settlement, dated April 26, 1982 4
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