ML20113A607
| ML20113A607 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/08/1985 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#285-470 OL, NUDOCS 8504100643 | |
| Download: ML20113A607 (16) | |
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f M METET UNITED STATES OF AMERICA 4/8fdh NUCLEAR REGULATORY COMMISSION EEEQEE INE @IQdlQ g6EEIY ONQ LICENglNG gg@B 0FFICE OF SEC,itiTAnv In the Matter of ( 00CXETING & SERvnT' 9 RANCH
)
HOUSTON LIGHTING AND ( Docket Nos. 50-498 OL POWER COMPANY, ET AL. ) 50-499 OL (South Texas Project, ( ,
Units 1 and 2) ( - ---. . . . .
CCANP RESPONSE TO APPLICANTS' MOTION FOR
-guudegy DIgeggIIlgN QE CC8NE ggUIEUIIQN EQUB I. Introduction CCANP Contention 4, currently pending in this proceeding, states:
"The South Texas Project (STP) Category I structures and equipment are inadequately designed and constructed with respect to wind loadings as demonstrated by the fact that actual wind velocities associated with hurricanes which occurred along the Texas Gulf Coast have exceeded wind loadings f or which STP structures have been designed and evaluated. Further, there are non-Category I structures containing equipment which if destroyed or damaged would jeopardize the safe operation of STP. These non-Category I buildings are not designed to withstand winds generated by hurricanes and if damaged would provide missile type projectiles which could penetrate Category I structures which sre inadequately protected." Memorandum and Order (August 3, 1979), Attachment at 3.
L On March 12, 1985, Applicants filed their Motion for Summary Disposition on CCANP Contention Four [ Hereinafter " Motion"3. In this motion, Applicants contend that the CCANP contention raises no genuine issues of fact but is " based upon ECCANP's]
mininterpretation and misuse of historical wind speed data" and
[CCANP's] failure to understand the methods approved by the NRC and utilized in the industry to ensure that nuclear power plants are properly designed to withstand loads resulting from high winds." Motion at 13. h 8504100643 e5040s PDR ADOCK 05000498 1 My I?
G PDR L
CCANP herein responds to Applicants' Motion and sets forth facts CCANP believes to be contested and the reasons for CCANP's position. This reponse is accompanied by a statement of material facts as to which there is a genuine issue to be heard. (Exhibit 1).
II. .The Adequacy of STNP Category I Structures and Equipment to Withstand the Conditions Potentially Created by a Hurricane is Questionable.
A. Galculatign gi the Qgerating Eggig Wind igr SpjP The design of Category I structures at STNP is based in part on an operating basi s wind (OBW) of 125 mph. Applicants admit that= there have been estimated or recorded wind speeds fer in excess of the 125 OBW on at least 19 different occasions. Motion at 4; Wolfe at ## 16, 17, 18. But Applicants claim that these estimates and recordings can be excluded from the data base used to calculate the OBW. Motion at 8; Wolfe at ## 14-22.
The Applicants support their exclusion of this data with the following reasons:
- the data records gusts or instantaneous wind speeds, not fastest-mile wind speed values
-- the data records estimated wind speeds; cr
-- the data is otherwise not reliable.
Addressing gusts and instantaneous wind speeds first, there are three problems with Applicants' approach.
First, Applicants dismiss a Board concern over whether hurricane and tornado winds are directly comparable given their Motion at 11, n.*; Linderman at 7, n.*. The different durations.
basis for dismissing this Board concern is that the critical 2
9 factor to be measured is the " elastic" range of STNP Category I structures. Linderman at 7, n.*. The elastic range is calculated based on a given wind load measured in pounds per square foot with the length of time that load is applied irrelevant to the ability _of the structure to withstand the load. Id.
Applying this same reasoning to gusts and Instantaneous wind speeds, these two measures should be. incorporated directly into the calculations of the operating basis wind load rather than treated as a coeeficient multiplier, Linderman at 9, n.*, #12.
Second, a " gust" speed at which point the wind monitor blew away cannot be ruled out as a possible f astest-mile wind speed.
At least one reading provided by CEU took place at the point the monitor blew away.
Third, and more generally, Applicants reject some readings as not being the f astest-mile wind speed. Wolfe, #16, item 1 (155 mph), item 3 (153 mph), item 6 (150-175 mph), item 7 (161 mph and 160-180 mph), item 9; #18, item 1. At the same time, Applicants reject the readings themselves as not necessarily reliable for other reasons. If Applicants cannot be sure c; the accuracy of the readings, they cannot be sure the readings were nok fastest-mile wind speeds incorrectly treated as gusts or instantaneous wind speeds.
A similar reliability question is raised by other reasons Applicants gi ve f or ei:cluding readings. These reasons include:
-- observation height uni.nown,
-- quality of observer training indeterminate,
-- quclity of equipment indeterminate, and
-- estimated value. Wolfe, ## 16-18.
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E These reasons both individually and as a group are not an adequate basis for excluding readings.
A statement that the observation height for a reading is unknown does not affirmatively establish that the height was not 30 feet ~ (or ten meters).
A statement that the quality of the observer training is indeterminate does not affirmatively establish that the observer was inadequately trained.
A statement that the quality of the equipment is indeterminate does not affirmatively establish that the equipment was inadequate in any way.
'A statement that the reading was estimated does not affirmatively establish that the reading was inaccurate or unreasonable.
Overall, the Applicants appear to be attempting to shift the burden of proof to the intervenors or the NRC Staff; if the Applicants cannot affirmatively prove the unreliability of a particular reading, then they fail to meet their burden of croof that their calculations need not include the data.
TPe root of the Applicants' approach seems to be a confusicn about what would constitute a conservative approach in this context. The National Weather Service may choose not to rols on data such as that excluded by Applicants when writing their official reports on a hurricane because they seek to maintain a high level of scientific credibility.
But that form of conservatism is not what is sought in the nuclear context. For example, as Applicants note, "uncertai nti es in data" lead to providing "an additignal margin gf safety."
e Linderman #6 (emphasis added); See alsg Motion at .6. A conservative approach in the nuclear context means including any data which might be reliable rather than excluding data not clearly reliable.
The Applicants seek to justify their approach by citing the guidance provided by the NRC Standard Review Plan, Wolfe, #14; Linderman, #7, which states that "Ed]ata on severe weather phenomena should be based on standard meteorological records from nearby representative National Weather Service (NWS), military er other stations recognized as standard installations which have long periods on record." SRP Section 2.3.1 as gugted in Wolfe.
- 14.
CCANP contends that the SRP guidance is not meant to be the exclusive basis for selecting data on severe weather phenomena but only to direct Applicants to one reliable source.
Alternatively, the numerous available recordings above the current OBW and excluded by the Applicants (20 readings), call L
for a more comprehensive approach in this case than the approach contained in the SRP.
Furthermore, the Applicants' approach repeatedly narroweJ the data base, both in terms of the number ot sources and t h :-
duration of measurement history. Wolfe, #11 cod at 5, n.+
(Sources reduced to four, only one with a h; story longer than 41 years; then reduced again to those four only during the lact 29 years). such limited sources as a basis for calculation, With events outside the boundaries calculated from such sources cannot
.be ruled out with any reasonable degree of certainty.
Applicants agree that at least one reliable measurer.ent of 5
fastest-mile wind speed did exceed 125 mph but someho.4 manipulated the data to avoid having to use this higher speed as the OBW. Wolfe, #19.
Finally, when numerous recorded wind speeds in excess of the OBW in fact e::i st , the possibility of a higher 06W than calculated is made much less remote. Such readings should be considered as parameters for the highest possible OBW. In this case, a conser vati ve approach would bb to select the highest recoiding as the OBW. That reading would be 190 mph. Wolfe, #16, item 6.
E. 1GC9CE9CetL90 gf tbg Degign Bagig Igtngdg Winds knig Ibe Design gf thg SINE I r3 their calculations, the Applicants treat the wind load generated by the design basis tornado (DBT) as a separate event whose inclusion in the design calculations obviates the need to l -be. concerned if the OBW is calculated too low. Linderman. #H 17,
. combination with other design basis conditions (but not the OBW, Linderman, #16), to " envelope loads generated by the OPLJ and other severe conditions." Linderman, ## 17, 26.
But hurricanes on the Texas coast are frecuently accompanied by tornadoes. The design calculations for STNP should, therefore, assume the manimum wind load would be the OBW (whether calculated as the Applicants do or as CCANP contends it should be) glus the DBT. These wind loads would then be augmented by the load
-combinations referred to by Applicants.
The results of such a combined OBW/DBT event are in part illustrated by Applicants' affidavit. See Linderman, #17. The DET 6
n-alone would generate a wind load of 332 pounds per square foot.
Id. A 200 mph OBW (close to the 190 mph urged by CCANP), with a gust factor aaplied using th9 Applicants' methodology, would generate a wind load of 133 pounds per square foot at 30 feet.
While a design compensating for a load of 332 pounds ~per square foot would be able to handle a load of 133 pounds per square foot
- the ' Applicants' basic argument - such a design might well fail at a load of 465 pounds per square foot (332 + 133), i.e. should a tornado occur during a peak wind hurricane. The Applicants' calculations fail to include this possible combination of events and are, therefore, inadequate to provide a reasonable assurance that Category I structures can withstand the highest probable wind loads.
C. Inggtagcatign gi gthet Leeds intg tug Destge et the EINE As noted by Applicants, after the highest probable wind load is calculated, additional loads are assumed to provide a margin of safety. Motion at 7; Linderman, ## 12, 13, 16. These same e::tra loads would be applied to both the higher OBW argued for by CCANP and the OBW/DBT combination which CCANP contende must be incorporated into the design.
D. Imaggt 91 Egilute of Nge:Categgty 1 @ttuctuteg gg Categgty 1 sttuctutes
- 1. Turbine Generator Buildina Applicants' position that the DBT loads on the Turbine Generator Building will not cause any failure of that building damaging to the attached Category I structures relies on the current calculation of DBT loads, Linderman, #20, a calculation 7
shown- above to be an inadequate basis for design. The Turbine Generator Building analysis is, therefore, also inadequate.
- 2. Missiles
- a. Applicants' position that all Category I structures at STNP, except f or the Isolation Valve Cubicle (IVC) roof, are designed to withstand a spectrum of missiles which might be generated by the DBT, Linderman, ## 22, 23, is deficient in depending on an inadequate calculation of maximum wind speeds which could occur, i.e. is not based on the probable DBT + OBW value.
- b. The Isolation Valve Cubicle (IVC) roof is not protected against hurricane generated missiles because the Applicants convinced the NRC to accept a probability risk assessment analysis regarding the likelihoco of a missile striking an IVC roof. But the accident at the Salem reactor in New Jersey demonstrated the severe inadequacy of the PRA method and the danger of relying on such a calculation. The FRA analysis at Salem calculated the probability that both the primary and backup scram =ystems for the reactor would fa:1 once in 20,0uO years of reactor operation. In fact, such an event occured at the Salem reactor after less than 500 years of reactor operation.
Given the large margin of error in the FRA method, the NRC cannot rel y on Applicants' application of that method to the questions of a missile striking an IVC roof. Egg Linderman, # 24.
E. Impact gi Stgtm Sytgg gn Catgggty 1 Euildings The Applicants appear to take the position that the existence of roads surrounding the power block at a height 3.26 8
m
feet above the level of the probable maximum hurricane storm surge and the placement of the power block itself 1.26 feet above the same storm surge level assures such a storm surge will not jeapar di z e Category I structures. The power of a storm surge is so immense, however, that the roads could well be overtopped as the water piles up against them, could fail or be breached under the pressure of_the storm surge, or could otherwise be severely damaged by the combination of the storm surge, backwash, and Colorado River overflow. The base of the power block is similarly at -isk should the road barrier fail or be breached.
III. Conclusion Contrary to Applicants position, STNP is not adequatel y designed- to withstand the most severe conditions which could be created by a hurricane at the STNP site.
The Applicants took a non-conservative approach to calculating the OBN. The Applicants erroneously treated the OBW and DET as independently occuring phenomena and, therefore.
er roneousl y assumed calculations based on the DBT would envelope created by the OBW. In general, the Applicants conditions underestimated the potential power of a hurricane.
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Given the unpredictability of hurricanes, both as to their direction of travel and their potential severity, and given the limited data available for predictive purposes, the ASLB should enter an order requiring that the STNP be placed in a safe shut down condition whenever a hurricane enters the Gulf of Me::ico and until'such time as the hurricane is dissipated, i Respectfully submitted, dam ,
b 5 .
Lanny Sinkin Representative for Intervenor, Citizens Concerned About Nuclear Power, Inc.
' 3022 Porter St., N.W. M304 Washington, D.C. 20008 (202) 966-2141 Dated: April 4, 1985 Washington, D.C.
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UNITED STATES OF AMERICA EX h k;Y NUCLEAR REGULATORY COMMISSION . .
- 15. AMt 10 NO :32 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0FFICE Ce fiCEETARV 00CKEONG A SERVici In the Matter of ( 3,yascg
)
HOUSTON LIGHTING AND ( Docket Nos. 50-498 OL POWER COMPANY, ET AL. ) 5G'-499 OL
.(South Texas Project, (
Units 1 and 2) (
MATERIAL FACTS AS TO WHICH THERE IS A GEUglGE ISSUE IQ BE HEARQ Pursuant to 10 C.F.R. Section 2.749(a), CCANP hereby submits, in conjunc ion with its Response to Applicants' Motion for Summary Disposition of CCANP Contention Four, a statement of material facts as to which there is a genuine issue to be heard.
(1) The design of Category I structures at the South Texas Nuclear Project (STNP) uses an operating basis wind (OBW) of 125 mph at a standard reference height of 30 feet, despite the Applicants' admission that data exists indicating the OBW should in #act be much higher than 125 mph.
(2) There is a question whether the readings treated and excluded as gusts or instantaneous wind speeds are in fact fastest-mile wind speeds since the reliability of the
't measurements is not affirmatively established.
(3) There is a question whether the OBW should in fact include gusts and instantaneous wind speeds for purposeu of designing Category I structures to withstand the possible wind loads since the length of time a load is applied to STNP Category I structures is irrelevant.
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(4) A conservative approach to calculating the OBW would inglgde rather- than exclude readings of wind speeds whose reliability might be questionable but whose inaccuracy is not affirmatively demonstrated. The calculated OBW for STNP is, therefore, not conservative in that it does not include numerous readings whose inaccuracy was not affirmatively proven and which are in excess of the OBW. This non-conservative characteristic is especially apparent given that many of the higher readings excluded came from the immediate vicinity of the plant, the site of the plant (Matagorda County) is the most common point in Texas for hurricanes to male landf all , and the readings used by the Applicants are from more remote areas.
(5) Applicants treatment of NRC guida.'ce on how the OBW should be calculated as requiring the exclusion of data from all but a few sources is an overly narrow interpretation of the intent of the NRC Standard Review Plan. Alternatively, the NRC guidance is too confining in a case where so many other readings exist which are in excess of those from NRC identified scurces.
either case, the calculation of the OBW should take ;nto In account the numerous readings excluded by the Applicants.
I (6) Applicants excluded meaured wind speeds which exceed their own 1000-year recurrence interval values. See Applicants' se Motion at 7, n.*. If the excluded values are included, the true 1000 year recurrence value would also be much higher. This would produce a higher OBW should the 1000-year value be used in place of the 100-year value as suggested by the Board.
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(7) The limited number of data sources and the short time period _ over which Applicants' OBW values were measured do not provide an adequate- basis for accepting the Applicants' calculations. on hurricane generated pressures on Category I structures.
(8) The design of Category I structures at the STNP does not tal:e in consideration the possible simultaneous occurence of an OBW (whether at the 125 mph used by Applicants or the 190 nph value _ urged by CCANP) and a design basis tornado (DBT) with a maximum wind speed of 360 mph. The frequent occurence of hurricane generated tornadoes require the design of Category I structures at STNP to be adequate to withstand the pressures generated by a DBT and OBW occuring simultaneously.
(9) The additional margin of safety provided by Applicants' application of load factors does not compensate for excluding the higher wind speed data from the OBW calculation because these additional factors would also be applied to a higher OBW resulting from inclusion of the data excluded.
(10) While Category I structures, except for the Isolation Valve Cubicle (IVC) roof, may be adequately designed to withstand a missile generated by the DBT, these structures are not designed to withstand a missile propelled by a simultaneously occuring DBT and OBW. Since hurricanes on the Texas coast frequently generate tornadoes, the missile protection design should encompass a response to such a simultaneous occurence.
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(11) Given the large error in NRC accepted probability risk assessment values for the simultaneous failure of both the primary and back up scram mechanisms at the Salem reactor, a PRA analysis cannot be relied upon as a basis f or failing to protect the IVC roof from tornado or hurricane-generated missiles.
(12) While stating that there are barriers (roads) surrounding .the power block which are higher than the probable maximum hurricane storm surge and that the power block itself is above the level of such a surge, Linderman, #25, there is no evidence to support that these barriers can withstand the power of a storm surge or that the power block can withstand the e::pected impact if the roads fail or are breached by the hurricane-generated forces.
(13) STNP Category I structures and equipment have not been designed to withstand hurricane-generated wind loads (including concurrent tornado loads).
(14) STNP Category I structures and equipment have not been designed to withstand missles generated by hurricane and/or tornado activity and propelled by a combination of hurricane and tornadic winds.
(15) STNP is not designed adequately to prevent damage by the probable maxiumu storm surge, combined with the 100-year flood in the Colorado River.
(16) Since tornadoes frequently occur with Gulf Coast hurricanes and since a DBT is considered an " extreme" condition 4
a e
requiring the STNP to cease operations, the Applicants should be required to put STNP in a safe shut down condition anytime a hurricane is within the Gulf of Mexico and'to remain in that condition until the hurricane dissipates.
(17)- Given the limited data available for STNP, the unpredictability of hurricanes, both as to their direction and severity (including possible concurrent tornado activity), the-most prudent policy f or protection of public health and safety is to require the STNP to be placed in a safe shut down condition whenever a hurricane enters the Gulf of Mexico and to remain in that condition until the hurricane dissipates.
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f NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD CC in L LSMC In the Matter of (
)
HOUSTON LIGHTING AND ( Docket Nos. 50-498 OL15 NH 10 40:32 POWER COMPANY, ET AL. ) 50-499 OL (South Texas Project, (
()FFICE 07 5 CntIAd Units 1 and 2) <
00CMEitNG 4 SERVICL BRANCH CEBIIEIC81E GE SEBy1CE I hereby certify that copies of CCANP RESPONSE TO -
APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF CCANP_ CONTENTION FOUR were served by hand delivery (*) or deposit in the U.S.
Mail, first class postage paid to the following individuals and entities on the 8th day of April 1985.
Charles Bechhoefer, Esquire Brian Berwick, Esquire Chairman Asst. Atty. Gen.
Atomic Safety and Licensing Board State of Texas U.S. Nuclear Regulatory Commission Environmtl. Protection Washington, D.C. 20555 P. O. Box 12548, Capitol Sta.
Austin, Texas 78711
. Dr. James C. Lamb, III Administrative Judge
- Oreste Russ Pirfo, Esquire 313 Woodhaven Road Office of the Exec. Leg. Dir.
Chapel Hill, North Carolina 27514 U.S. Nuclear Regulatory Comm.
Washington, D.C. 20555 Ernest E. Hill Administrative Judge Jack R. Newman, Ecquire Hill Associates 1615 L Street, NW, Suite 1000 210 Montego Drive Washington, D.C. 20036 Danville, California 94526 Melbert Schwarz, Esquire Baker and Botts Mrs. Peggy Buchorn 300 One Shell Plaza Executive Director, C.E.U. Houston, Texas 77002 Route 1, Box 1684 Brazoria, Texas 77422 Atomic Safety and Licensing Bd.
U.S. Nuclear Regulatory Comm.
William S. Jordan, III, Esq. Washington, D.C. 20555 Harmon, Weiss & Jordan 2001 S Street, N.W., Suite 430 Atomic Safety and Licensing Washington, D.C. 20009 Appeal Board U.S. Nuclear Regulatory Comm.
Pat Coy Washington, D.C. 20555 5106 Casa Oro San Antonio, Texas 78233 Docketing and Service Section Office of the Secretary Ray Goldstein U.S. Nuclear Regulatory Comm.
1001 Vaughn Bldg. Washington, D.C. 20555 807 Brazos Austin, Texas 78701
_ _ _ _ . w___ ______________
Lannyj(Sinkin