ML20136E812
| ML20136E812 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Vogtle |
| Issue date: | 02/29/1984 |
| From: | Srinivasan M Office of Nuclear Reactor Regulation |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082840446 | List:
|
| References | |
| FOIA-84-663 NUDOCS 8403140164 | |
| Download: ML20136E812 (24) | |
Text
f l'
of' %h UNITED STATES 44
,1 NUCLEAR REGULATORY cOMMISslON f.
- l, WASHINGTON. D. C. 20555
,/
February 29,'1984 MEMORANDUM FOR: Elinor Adensam, Chief Licensing Branch No. 4, DL FROM:
M. Srinivasan, Chief Power Systems Branch, DSI SUBJEJT:
REQUEST FOR INFORMATION - V0GTLE UNITS 1 AND 2 Plant Name: Vogtle Electric Generating Plant, Units 1 and 2 Applicant: -Georgia Power Company Docket Nos: 50-424/425
-Licensing Stage:.OL Project Manager:
M. Miller Systems Integration Branch: Power Syste,ms PSB Reviewers:
J. Lazevnick/E. Tomlinson' Review Status: Awaiting.Information As requested by the Vogtle project manager (M. Miller) en. closed is a partial list of questions from J. Lazevnick who is the PSB electrical reviewer for Chapter 8 of the Vogtle FSAR. The remaining electrical questions will be completed and forwarded to LB 4 by the scheduled date of April 15, 1984.
Also enclosed is the complete list of questions from Mr. E. Tomlinson who is the PSB mechanical reviewer for Vogtle. These ouestions cover portions.of Chapters 8, 9 and 10 of the Vogtle FSAR.
t @h M. Srinivasan, Chief Power Systems Branch Division of Systems Integration j
Enclosure:
As stated cc:
L. Rubenstein i
M. Miller J. f. Knight A. lingara J. Lazevnick
-E. Tr' son 50bl90/(/f11 ConIact:'JmR1MB i:
430-1 V0GTLE ELECTRIC GENERATING PLANT UNITS 1 AND 2 Power Systems Branch (iiechanical Questions) 430.1 Provide a detailed description (or plan) of the level of
~(8.3) training proposed for your operators, maintenance crew, quality assurance, and supervisory personnel responsible for the operation and maintenance of the emergency diesel genera-tors.
Identify the number and. type of personnel that will be dedicated to the operations and maintenance of the emergency diesel generators and the number and type that will be assigned from your general plant operations and maintenance groups to assist when needed.
In your discussion identify the amount and kind of training that will be received by each of the above categories and the-type of ongoing training program planned to assure optinun availability of the emergency generators.
Also discuss the level of education and minimum experience requirements for the various categories of operations and maintenance nersonnel associated with the emergency diesel generators.
(SRP 8.3.1, Parts II and III) 430.2 Operatir.g experience at two nuclear power plants has shown (8.3) that during periodic surveillance testing of a standby diesel generator, initiation of an emergency start signal (LOCA or LOOP) resulted in the diesel failing to start and perfom its function due to depletion of the starting air supply from repeated activation of the starting relay. This event occurred as the result of inadequate procedures and from a hang-up in engine starting and control circuit logic failing to address a built-in time delay relay to assure the engine comes to a complete stop before attempting a restart. During the period that the relay was timing out fuel to the engine was blocked while the starting air was uninhibited. This condition with repeated start attempts depleted starting air and rendered the diesel generator unavailable until the air system could be repressurized.
Review procedures and control system logic to assure this event will not occur at your plant. Provide a detailed discussion of how your system design, supplemented by
- . procedures, precludes the occurrence of this event. Should
- the diesel generator starting and control circuit logic, and procedures require changes, provide a description of the proposed modifications.
(SRP 8.3.1, Parts II and III)
430-2 430.3 Periodic testing and test loading of an emergency diesel (8.3) generator in a nuclear power plant is a necessary function to RSP demonstrate the operability, capability and availability of the unit on demand.
Periodic testing coupled with good preventive maintenance practices will assure optimum equipment readiness and availability on demand. This is the desired goal.
To achieve this optimum equipment readiness status the following requirements should be met:
1.
The equipment should be tested with a mininum loading of 25 percent of rated load. No load or light load operation will cause incomplete combustion of fuel resulting in the fomation of gum and varnish deposits on the cylinder walls, intake and exhaust valves, pistons and piston rings, etc., and accumulation of unburned fuel in the turbocharger and exhaust system. The consequences of no load or light load operation are potential equipment failures due to the gum and varnish deposits and fire in the engine exhaust system.
1 2.
-Periodic surveillance testing should be performed in accordance with the applicable NRC guidelines (R.G.
l.108), and with the recommendations of the engine manufacturer. Conflicts between any such recommendations and the NRC guidelines, particularly with respect to test frequency, loading and duration, should be identified and justified.
3.
Preventive maintenance should go beyond the normal routine adjustments, servicing and repair of components when a malfunction occurs. Preventive maintenance should enconpass investigative testing of components which have a history of repeated malfunctioning and require constant attention and repair.
In such cases consideration should be given to replacement of those components with other
' products which have a record of demonstrated reliability, rather than repetitive repair and maintenance of the existing components. Testing of the unit after adjustments or repairs have been made only confirms that the equipment is operable and does not necessarily mean that the root cause of the problem has been elininated or alleviated.
4.
.Upon completion of repairs or maintenance and prior to an actual start, run, and load test a final equipment check should be made to assure that all electrical circuits are functional, f.e.,' fuses are in place, switches and
~-
- circuit breakers are in their proper positions, no loose wires, all test leads have been removed, and all valves are in the proper positions to permit a manual start of the equipment. After the unit has been satisfactorily
- started and load tested, return the unit to ready
430-3 1
automatic. standby service and under the control of the control room operator.
Provide a discussion of how the above requirements have been implemented in the emergency diesel generator system design and how they will be considered when the plant is in comercial operation, i.e., by what means will the above requirements be enforced.
(SRP8.3.1,PartsIIandIII) 430.4 The availability on demand of an emergency diesel generator is i
(8.3) dependent upon, among other things, the proper functioning of RSP its controls and monitoring instrumentation. This equipment is generally panel mounted and in some instances the panels are mounted directly on the diesel generator skid. Major 1
diesel engine damage-has occurred at some operating plants from vibration induced wear on skid mounted control and
{
monitoring instrumentation. This sensitive instrumentation is 1
not made to withstar.d and functicr. accurately for prolonged i
i periods under continuous vibrational stresses normally encoun-l tered with internal combustion engines. Operation of sensitive instrumentation under this environment rapidly deteriorates calibration, accuracy and control signal output.
(
l 7herefore, except for sensors and other equipment that must be j
directly mounted on the engine or associated piping, the controls and monitoring instrumentation should be installed on a free standing floor-mounted panel separate from the engine t
4 skids, and located on a vibration-free floor area.
If the floor is not vibration-free, the panel shall be equipped with
~
vibration mounts.
Confirn your ccepliance with the above requirement or provide justification for noncompliance.
(SRP 8.3.1, Parts II and III) 430.5 Expand FSAR Section 9.5.3.2.3 to provide the following addi-l (9.5.3) tional information regarding energency lighting for the main control board and remote shutdown panels. Your discussion should also include access routes to the control room.
4 l
a)
List the illumination levels provided by each of the emergency lighting systems, and demonstrate that these illumination levels. conform to the minimum recommendations of NUREG-0700.
In your discussion of illumination levels, consider a single active failure of an amergency diesel generator.
?-
b)- Consider the design basis seismic event coincident with the loss of all non-seismic equipment, components, and
~-
{
systems (including offsite power). Show that adequate l
illumination will be provided in the control room to i
effect safe, cold shutdown of the reactor and to maintain 3
cold shutdown for an extended period of time, or provide 4
i E
f
430-4 justification for not requiring control room lighting under these conditions.-
430.6 The FSAR text and ~ Table 3.2-1 states that the components and (9.5.4) piping systems for the diesel generator auxiliaries (fuel oil (9.5.5) system cooling water, lubrication, air starting, and intake (9.5.6) and combustion system) that are mounted on the auxiliary (9.5.7) skids are designed seismic Category I and are ASME Section III
'(9.5.8)
Class 3 quality. 'The diesel engine, and piping and valves within the engine boundary, are seismic Category I and are constructed to DEMA and manufacturer's standards, respectively. This is not in accordance with Regulatory Guide 1.26 which requires the entire diesel generator auxiliary systems be designed to Ast1E Section III Class 3 or Quality Group C.
Therefore, provide the following:
a)
The industry standards which were used by the diesel generator vendor in the design, manufacture, and inspec-tion of the piping and components within the diesel engine boundary, b)
A revised P&ID (FSAR Fig. 9.5.4-1) which shows all piping and components which are within the engine boundary and which are engine-mounted.
Identify the diesel engine interface, and all locations where there is a change in piping classification.
(The diesel engine interface is defined as the first connection off the engine block, either flanged, screwed, or welded.)
(SRP 9.5.4 through 9.5.8,PartIII) 430.7 Identify all high and moderate energy lines and systems that (9.5.4) will be installed in the diesel generator room. Discuss the (9.5.5) measures that will be taken in the design of the diesel (9.5.6) generator facility to protect the safety-related systems, (9.5.7) piping and components from the effects of high and moderate (9.5.8). energy line failure to assure availability of the diesel generators when needed.
(SRP 9.5.4 through 9.5.8, Parts II and:III) 430.8 De;cribe the instruments, controls, sensors and alarms pro-9.5.4) vided for monitoring the diesel engine fuel oil storage and 9.5.5 transfer, cooling water, lubrication, air starting, and 9.5.6
. combustion air intake and exhaust systens and describe their (9.5.7 function. Discuss the testing and calibration necessary to (9.5.8
. maintain and assure a highly reliable instrumentation,
- controls, sensors and alarm system, and the frequency of such
- testing, and where the alarms are annunciated.
Identify the
. temperature, pressure and level sensors which alert the pperator when these parameters exceed the ranges recommended
,by the engine manufacturer and describe what operator actions
~
are required during alarm conditions to prevent harmful effects to the diesel engine. Discuss the systen interlocks provided. If this information is provided in another section
430-5 of the FSAR, provide a specific reference to that FSAR section.
(SRP 9.5.4 through 9.5.8, Part III) 430.9 In FSAR Section 1.9, you state that the ' design of the fuel oil (9.5.4) storage and transfer system conforms to the requirements of R.G. 1.137, which endorses ANSI Standard N-195. However, there is no reference to testing of fuel oil as discussed in Appendix B of ANSI N-195 and Position C2 of Regulatory Guide 1.137. Revise your FSAR to include a discussion of your conformance to these requirements.
430.10 The diesel generator structures are designed to seismic and (9.5.4) tornado criteria and are isolated from one another by a reinforced concrete wall barrier. Describe the barrier (including openings) in more detail and its capability to withstand the effects of internally generated missiles resulting from a crankcase explosion, failure of one or all of the starting air receivers, or failure of any high or moderate enregy line and initial flooding from the cooling systen so that the assumed effects will not result in loss of an addi-tional generator.
(SRP 9.5.4, Parts II and III) 430.11 Describe your design provisions made to protect the fuel oil (9.5.4) storage tank fill line from damage by tornado missiles.
(SRP 9.5.4, Part II).
430.12 In the FSAR, you state ~that the fuel oil storage tanks are (9.5.4) vented to the " valve house" located between the storage tanks.
Expand your FSAR to provide additional information on the design features of this " valve house" which ensure adequate ventilation of the structure so as to preclude a buildup of combustible gasses, and the provisions to prevent the ventilation capability being blocked as a consequence of any weather condition.
430.13 Expand the FSAR to include a discussion of where the fuel oil (9.5.4) day tank is vented, and what provisions are made to prevent a buildup of combustible gasses.
430.14 The FSAR text (Section 9.5.4) and Table 3.2.2-1 do not address (9.5.4) seismic and quality group classification for the f ael ofi valve house and transfer pump houses.
Tornado missile protec-tion for these structures also is not addressed.
Revise your FSAR to include a discussion of the seismic and inissile protection design of these structures, or provide a specific reference to an FSAR section where the infonnation may be found.
(SRP9.5.4,PartII) 430.15
. Expand your FSAR to show that a spurious actuation of the fire (9.5.4)
- protection system as a consequence of a seismic event will not affect transfer pump operation, and consequently, diesel generator availability.
(SRP 9.5.4,'Part III) 430.16 Regulatory Guide 1.,137 (and ANSI N-195) require fuel oil
430-6 (9.5.4) storage capacity which is adequate for seven days of diesel generator operation at post-LOCA loads, with a 10% margin for diesel ganerator testing and maintenance. Provide a discussion of the' post-LOCA diesel generator Joading and fuel consumption which demonstrates that the 80,G00~ gallon storage capacity is adequate for seven days of operation for either diesel generator without refueling, assumir.gtonly 90% of the storage capacity is available at the starts '(SRP 9.5.4,-Parts I and II) 430.17 Assume an unlikely event has occurred requiring operatinn of a l
(9.5.4) diesel generator for a prolonged period that would require replenishirent of fuel oil without interrupting operation of the diesel generator. What provision will be made in the design of the fuel oil storage fill system to minimize the creation of turbulence of the sediment in the bottom of the i
storage tank. Stirring of this sediment during addition of new fuel has the potential of causing the overall quality of the fuel to become unacceptable and could potentially lead to the degradation or failure of the diesel generator.
In the response, refer to FSAR Section 9.5.4.2.1.1 and describe how a
" full" tank, free of disturbed sediment, is obtained initially, and how fuel oil is transferred from it to the day tanks.
(SRP9.5.4,PartsI,11andIII) 430.18 Expand your FSAR discussion on fuel oil resupply to include (9.5.4) the method employed to deliver fuel oil to the site, how fuel oil can be transferred from the adjacent fuel oil fired steam turbine plant to the site, and how either can be acconplished under extremely unfavorable environmental conditions.
(SRP 9.5.4 Parti) 430.19 Expand your FSAR discussion on biocides and "other additives."
(9.5.4)
State what biocides and "other additives" will be utilized, and show that these materials comply with the diesel engine vendor's recomendation and are compatible with the fuel to be used at Vogtle. Also, state how fuel oil temperature will be maintained above the cloud point, i.e, by locating below the frost line, by heat tracing, or both. Provide details, and state the minimum fuel oil cloud point allowable.
(SRP9.5.4, Parts I and II)
I 430.20 Provide justification for not providing cathodic protection (9.5.4) for the fuel oil storage tanks and the underground portion of the fuel oil transfer system.
(SRP.9.5.4,PartsI.andII) 430.21 In FSAR Table 9.5.4-1, you include a heading of "Nonsafety-(9.5.4)
Related Portion" under the title of Standby Diesel Generator
- . Fuel Oil Storage and Transfer System. Describe what portions
.' of this system are nonsafety-related, show these portions on the P&ID, and describe their isolation from safety-related portions.
i 430.22 The FSAR text (Section 9.5.4) and Figure 9.5.4-1 do not agree
430-7 (9.5.4) with regard to fuel oil transfer system alarms and indica-tions.
(Ex:
(1) Figure 9.5.4-1 shows high and low level alarms and (2) The FSAR text refers to pressure differential alarms on strainers and filters - Figure 9.5.4-1 shows indication, only). Revise the FSAR text and Figure 9.5.4-1 to agree. Coordinate this response with the response to staff questions on overall system descriptions.
430.23 In Section 9.5.5 of the FSAR, you indicate that the function (9.5.5) of the diesel generator cooling water system is to dissipate the heat transferred through 1) engine jacket water, 2) lube oil cooler, and 3) combustion air aftercoolers.
In Table 9.5.5-1, you ghow the jacket water heat exchanger design duty as 21.02 x 10 BTU /hr. Tabulate the maximum heat rejection to the cooling water systen and show that the jacket water heat exchanger is adequate for the intended service plus a design margin (excess capability), assuming the most severe design conditions for the plant.
430.24 You state in Section 9.5.5.2.2 the diesel engine cooling water (9.5.5) is treated as appropriate to minimize corrosion.
Provide additional details of your proposed diesel engine cooling water system chenical treatment, ard discuss how your proposed treatment complies with the engine manufacturer's recorrenda-tions.
(SRP9.5.5,PartsIandIII) 430.25 Describe the provisions made in the design of the diesel (9.5.5) engine cooling water system to assure that all corponents and piping are filled with water.
(SRP 9.5.5, Part III) 430.25 The diesel generators are required to start automatically on (9.5.5) loss of all offsite power and in the event of a LOCA. The diesel generator sets should be capable of operation at less than full load for extended periods without degradation of performance or reliability.
Should a LOCA occur with avail-ability of offsite power, discuss the design provisions and other paraneters that have been considered in the selection of the diesel generators to enable them to run unloaded (on standby) for extended periods without degradation of engine performance or reliability.
Expand your FSAR to include and explicitly define the capability of your design with regard to this requirement.
(SRP 8.3.1, Parts II and.III and SRP 9.5.5, PartIII) 430.27 - You state in section 9.5.5.2 each diesel engine cooling water (9.5.5) systen is provided with a standpipe to provide for system expansion to absorb pump pressure variations, and to provide makeup water. Demonstrate by analysfs that the standpipe size
.will be adequate to provide for minor system leaks at pump
, shaf ts seals, valve stems and other components, and to maintain required NPSH on the system circulating pump and makeup water for seven days continuous operation of the diesel engine at full rated load without makeup, or provide a. seismic
430-8 class 3 makeup water supply to the Category I, safety (SRP 9.5.5, Parts I, II and III) expansion tank.
430.28 Recent licensee event reports have shown that tube leaks are being experienced in the heat exchangers of diesel engine (9.5.5) jacket cooling water systems with resultant engine failure to start on demand. Provide a discussion of the means used to detect tube leakage and the corrective measures that will be taken.
Include jacket water leakage into the lube oil system (standby mode), lube oil leakage into the jacket water (operating mode). jacket water leakage into the engine air intake and governor systems (operating or standby mode).
Provide the permissable inleakage or outleakage in each of the above conditions which can be tolerated without degrading engine performance or causing engine failure. The discussion should also include the effects of jacket water / service water systems leakage.
(SRP 9.5.5, Parts II and III) 430.29 Operating experience indicates that diesel engines have failed (9.5.5) to start on denand due to water spraying on locally mounted electronic / electrical components in the diesel engine starting Describe what measures have been incorporated in the syt. tem.
diesel engine electrical starting system to protect such electronic / electrical components from such potential environment.
(SRP9.5.5,PartsIIandIII) 430.30 In FSAR Section 9.5.6.3, you state that each air start system (9.5.6) contains sufficient air for five consecutive starts of its assnciated diesel engine, enmmencing with the air receiver pressure at the low-pressure alam point and without recharging fom the air compressor.
Expand Section 9.5.6 of the FSAR to clarify your position regarding air start system capability and provide the following:
a)
Define a diesel engine start cycle; i.e., engine cranking for a predetermined time, engine cranking until a prede-temined RPM is reached, engine cranking for a prede-temined number of engine revolutions, etc.
b)
Describe the sequence of events when an emergency start signal exists. State whether the diesel engine cranks until all compressed air is exhausted, or cranking stops after a preset time to conserve the diesel starting air supply.
c)
Provide a tabulation of receiver pressure at the beginning and end of each of the 5 diesel engine starts, starting at the receiver pressure at the low pressure alam point and without recharging.
(SRP9.5.6,PartII) 430.31
- In FSAR Section 9.5.6.1, you state that filters are included (9.5.6) as part of the air start system. There are no air start systems filters shown on Figure 9.5.4-I.
Revise your FSAR text and Figure 9.5.4-1 to include a discussion of the filters
~
1 430-9 provided and where they are located, or justify not having filters.
(SRP 9.5.6, Part III) 430.32 A recommendation in NUREG/CR-0660 states that the dewpoint in (9.5.6) a compressed air starting system for diesel generators should be maintained at a minimum of 10*F below the lowest ambient temperature in the space housing the system (diesel generator room).
In FSAR Section 9.5.6, you state the design dewpoint for the starting air system is 50*F, while in FSAR Section 9.5.7, you state that the minimum diesel generator room temperature will be 50*F, also.
Your design does not conform to the recommendations of NUREG/CR-0660. Therefore, revise your design accordingly, and expand the FSAR to provide a detailed discussion of the air dryer design and operation, including provisions to ensure that the compressed air dewpoint is being maintained at or below the 50*F design.
(SRP 9.5.6, Parts I and II) 430.33 In FSAR Section 9.5.7.5 you briefly discuss the low lube oil (9.5.7) pressure trip.
Expand your FSAR to provide additiona.1 infomation on this trip function, including more details on the pressure switches (nfgr., model, etc.), the location of these switches on the diesel generator, and identifying these switches on the P&ID (Figure 9.5.4-1).
430.34 In FSAR Section 9.5.7.3, you discuss the lube oil keep wam (9.5.7) system, which is shown in part on Figure 9.5.4-1.
In the FSAR, you state that the keep wam lube oil pump circulates heated lube oil throughout the diesel engine during standby.
Continual prelubrication to certain parts of a diesel engine, such as the valve train and the turbochargers, may have a harmful effect, i.e., it may cause a hydraulic cylinder lock due to lube oil leaking through valve guides, or it could cause turbocharger fires due to oil leaking past seals and into the diesel engine exhaust.
Confim that these problems do not exist for your diesel generator design. Also, revise the FSAR to explicitly define the design provisions which preclude the above conditions from occurring.
(SRP9.5.7, Parts II and III) 430.35 Assume an. unlikely event has occurred requiring operation of (9.5.7) the diesel generators for a prolonged period of time.
Demonstrate that there is adequate lube oil in each of the diesel generator sumps for a minimum of seven days of operation at post-LOCA loads without the necessity of repienishing and without encountering abnomal lube oil temperatures, assuming the lube oil level is at the lowest pemissible point of the start of_ operation.
In the event the
- . sump c'apacity is not adequate for 7 days operation and lube
, oil must be added, provide the following:
a)
What provisions have been made in the design of the lube oil system to add lube oil to the sump. These provisions shall include procedures or instructions available to the
430-10 operator on the proper addition of lube oil to the diesel
~ generator as follows:
1.
How and where lube oil can be added while the equipment is on standby service, 2.
How and where lube oil can be added while the equipment is in operation, 3.
Particular assurance that the wrong kind of oil is not inadvertently added to the lubricating oil systems, and 4
That the expected rise in level occurs and is verified for each unit of lube oil added.
b)
Verification that these operating procedures or instructions will be posted locally in the diesel generator rooms.
c)
Verification that personnel responsible for the operation and maintenance of the diesel are trained in the use of these procedures. Verification of the ability of the personnel on the use of the procedures shall be demonstrated during preoperation tests and during operator requalification.
d)
Verification that the color coded, or otherwise marked, lines associated with the diesel generator are correctly identified and that the line or point for adding lube oil (when the engine is on standby or in operation) has been clearly identified.
e)
Where and how lube oil is stored on site (SRP 9.5.7 Parts I and II) and quantity stored for each diesel generator.
430.36 What measures have been taken to prevent entry of deleterious (9.5.7) materials into the engine lubrication oil system due to operator error during recharging of lubricating oil or normal operation.
(SRP9.5.7,PartsIIandIII) 430.37 In Section 9.5.7.4 of the FSAR you state that to ensure (9.5.7) quality lube oil is present in the lube oil system and that it is within manufacturer's specifications, the lube oil will be
. " checked routinely." Define routinely.
(SRP9.5.7,Part.II) 430.38 In Section 9.5.7.2 of the FSAR a brief description of the (9.5.7) crankcase vacuum system is given.
Provide a more detailed description of the system including operating modes, and power
' sources.
If this system is necessary during nomal operation bf the diesel engine (prevention of crankcase explosion) we require that the mechanical portions of this system be designed to Seismic Category I ASME Section III Class 3 (Quality Group C) requirements and the electrical systems (if
430-11 any) to Class 1E requirements. The portion of the system extending outside the diesel generator building shall be tornado missile protected.
(SRP 9.5.7, Part II) 430.39 In accordance with 10 CFR Part 21 requirements Transanerica (9.5.7)
Delaval, Inc. has reported potential problems in the governor lube oil cooler assembly and turbocharger lubrication circuits which could result in diesel generator nonavailability or degraded perfomance. Transanerica Delaval has recommended modifications be made to the DSRV diesel engines to preclude occurrence of these prcblems. State whether these modifications have been made to the diesel generators at Vogtle and, if not, when will the modifications be made.
(SRP 9.5.7, Parts II and III) 430.40 Provide a discussion of the design margin (excess heat (9.5.7) removal capability) included in the design of the lube oil coolers for the diesel generators.
430.41 In Table 9.5.8-1 of the FSAR, you list the combustion air (9.5.8) intake filter, silencer, and flexible connections as being designed to " manufacturer's standard."
In addition, the diesel engine exhaust silencer, exhaust piping, and f,lexible connections are listed as being designed to " manufacturer's standard" or an ASTM standard. This is not acceptable. We require the entire diesel engine combustion air intake and exhaust system to be designed, fabricated, and installed in accordance with ASME Section III Class 3 requirements.
Revise your design accordingly, or provide justification for noncompliance.
(SRP9.5.8,PartII) 430.42 TheFSARText(Section9.5.8)andFigureI.2.2-28donot (9.5.8) provide adequate information or details, respectively, to deternine how tornado missile protection is provided for the combustion air intake.
Provide additional infomation, including drawings, as required, which will clearly show how tornado missile protection is designed.
(SRP9.5.8, Parti) 430.43 Provide a discussion in the FSAR on how tornado missile (9.5.8) protection is provided for the diesel eng(ine exhausts.SRP9.5.8, Parti)
Include such drawings as may be required 430.44 Discuss the provisies made in your design of the diesel (9.5.8) engine combustion air intake and exhaust systen to prevent possible clogging, during standby and in operation, from abnomal climatic conditions (heavy rain, freezing rain, dust stoms, ice and snow) that could prevent operation of the diesel generator on demand.
(SRP9.5.8,PartsIIandIII) 43'0.45 IExperienceatsomeoperatingplantshasshownthatdiesel (9.5.8) engines have failed to start due to accumulation of dust and other deleterious material on electrical equipment associated with starting of the diesel generators (e.g., auxiliary relay contacts, control switch - etc.). Describe the provisions
430-12 that have been made in your diesel generator building design, electrical starting) system, and combustion air and ventilation air intake design (s to preclude this condition to assure availability of the diesel generator on demand.
Also describe under normal plant operation what procedure (s) will be used to mininize accumulation of dust in the diesel generator room; specifically address concrete dust control.
l In your response also consider the condition when Unit 1 is in operation and Unit 2 is under construction (abnormal generationofdust).
(SRP 9.5.8, Parts II and III) i 430.46 Diesel generators for nuclear power plants should be capable (8.3.1) of operating at maximum rated output under various service (9.5.6) conditions. Under no load and light load operations, the (9.5.7) diesel generator may not be cap,ble of operating for (9.5.8) extended periods of time under extreme service conditions or weather disturbances.without serious degradation of the engine performance. This could results in the inability of the diesel engine to accept full load or fail to perform on l
demand. Provide the following:
a)
The environmental service conditions for which your diesel generator is designed to deliver rated load including the following:
Service Conditions a.
ambient air intake tenperature range
'F b.
humidity, max - %
b)
Assurance that the diesel generator can provide full rated load under the following weather disturbances:
l 1.
A tornado pressure transient causing an atmospheric pressure reduction of 3 psi in 1.5 seconds followed by a rise to normal pressure in 1.5 seconds.
2.
A low pressure storm such as a hurricane resulting in ambient pressure of not less that 26 inches Hg for a minimum duration of two (2) hours followed by a pressure of no less than 26 to 27 inches Hg for an extended period of time (approximately 12 hcurs).
c)
Discuss the effects low ambient temperature will have on engine standby and operation and effect on its output particularly at no load and light load operation, niill air preheating be required to reintain engine performance? Provide curve or table which shows i
performance versus ambient temperature for your diesel l
generator at nomal rated load, light load, and no load conditions. Also provide assurance that the engine jacket water and lube oil preheat systems have the l
l
430-13 capacity to maintain the diesel engine at manufacturer's recommended standby temperatures with minimum expected ambient conditions.
If the engine jacket water and lube oil preheat systems' capacity is not sufficient to do the above, discuss how this equipment will be maintained at ready standby status with minimum ambient temperature.
d)
Provide the manufacturer's design data for ambient pressure vs engine derating.
1 e)
Discuss the effects any other service and weather conditions will have on engine operation and output, i
i.e., dust storm, air restrictions. etc.
(SRP 8.3.1, Parts II and III; SRP 9.5.5, Part III; SRP 9.5.7, Parts II and III; and SRP 9.5.8, Parts II and III).
430.47 In Section 9.5.4 of the FSAR you state that in the event of a loss of offsite power (LOOP), the diesel generator ESF room (8.3))
ventilation system must be manually connected to the bus. The (9.5.4 (9.5.8) diesel generator room ventilation system provides cooling to the diesel generator and its auxiliary equipment during diesel generator operation.
Failure to start the ESF ventilation systen to dperating condition within a reasonable amount of time will result in diesel generator room temperatures exceed-ing the 120*F design ambient temperature specified in Section 9.5.4 of the FSAR. Provide the following:
a.
The means that are provided to the control room operator that tells him the ESF ventilation systen needs to be manually connected to the bus in the event of a LOOP.
b.
How and from where will manual connection be perforned?
c.
The time period that will be required to manually connect the ventilation system to the bus. This should include all startup and operator recognition that diesel rocm ventilation system has to be turned-on as a result of room temperature alam, procedures, or other indication and other contingencies or actions that the operator must take as a result of the accident.
d.
A room temperature verses time profile for the worst case outside ambient air temperature conditions for the following events:
1.
diesel generator started, ventilation system auto-matica11y reenergized 2.
diesel generator started, ventilation systen manuallyreenergizedinthetimespecifiedin(c) above 4
h
430-14 1
3.
diesel generator started, ventilation system not energized Assuming that the diesel room ESF ventilation system is e.
not energized for whatever reason, verify that the diesel generator and its associated equipment (electrical and mechanical) is qualified to operate in the maximum room temperature environnent specified in d(3) above and will be able to operate in this environment for a minimum of seven days of diesel generator operation.
f.
If the diesel generator and its associated equipment (electrical and mechanical) cannot operate in the maximum room temperature environment of d(3) above. State the maximum allowable room temperature in which the diesel generator and its associated equipment can operate, and i
provide a list of diesel generator components whose environmental operating temperatu.es are less than the maximum room temperature specified in d(3) above and their operating temperatures. Discuss how the listed diesel generator components will be upgraded to qualify and operate in the maximum environmental room tenperature or will be protected during these conditions, so that the diesel generator can perform its design safety function, or provide assurance to the staff that the ventilation system will be reenergized prior to reaching the maximum environrental room temperature so that the diesel generator and the above listed equipment can perform its design safety function.
(SRP 8.3.1, Parts II and III; SRP 9.4.5, Part III and SRP 9.5.8, Part II and III) 430.48 Expand your discussion of the turbine speed control and (10.2) overspeed protection systems.
Provide a schematic drawing for the Electro Hydraulic Control (EHC) system which shows all systen components and circuits in sufficient detail to permit following any speed control and/or turbine trip action from initiation to completion of the action. De cribe the sequence of events associated with all turbine speed control and/or turbine trip actions. Show all test components and describe i
their functicr. during turbine operation. Provide identifica-tion for all system components and refer to this identifica-tion in your description of system operation. Coordinate the
.(ystem sc emaSRP10.2.PartsIIandIII)gures10.2.2-2and10.2.2-3 s
h tic with FSAR Fi l
430.49 Provide the results of an analysis which demonstrates that any (10.2) failure of a turbine speed control and overspeed protection l
system ccmponents and/or power supply will disable the turbine
- i. speed control and overspeed protection from functioning in a
. safe manner.
(SRP 10.2, Parts ! and II) 430.50 Describe your program for periodic testing and inservice (10.2) inspection of the main steam stop and governor control valves, i
i l
430-15 l
the combined reheat stop and intercept valves, and the steam t
l extraction, non-return valves.
(SRP 10.2, Parts II and III) 430.51 Describe with the aid of drawings, the bulk hydrogen storage (10.2) facility including its location and distribution system.
Include the protective measures considered in the design to prevent fires and explosions during operations such as filling and purging the generator, as well as during normal l
operations.
(SRP 10.2, Part III) l 430.52 Provide additional description (with the aid of drawings) of (10.4.4) the turbine bypass valves and associated controls.
In your discussion include the number, size, principle of operation, construction, setpoints, and capacity of each valve ard the malfunctions and/or modes of failure considered in the design of the turbine bypass systen.
(SRP10.4.4,PartIII) 430.53 Provide a P&ID for the turbine bypass system showing system (10.4.4) components and all instrumentation.
(SRP10.4.4,PartIII) l i
1 l
l i
t-l l
l
430-16 (Electrical Questions) 430.54 Regarding the transmission lines connected to the Vogtle 230 (8.2) and 500 kV switchyards:
a.
FSAR Section 8.2.1.1 states that the lines approach the plant site on at least two rights-of-way, from the northwest and south.
Figures 1.2.2-1 and 8.1-1 seen to indicate there are more than two rights-of-way, and the figures are not consistent with each other. Clarify
- these discrepancies and provide a drawing in FSAR Chapter 8 similar to Figure 8.1-1 which identifies the right-of-way approaches to the plant and the lines which exist on those rights-of-way.
b.
Table 8.2.1-1 indicates that the Wilson Combustion Turbine line is not finalized but Figure 8.1-1 indicates that the Vogtle to Plant Wilson line is existing.
Clarify this discrepancy.
430.55 FSAR Section 8.2.2.1 states that the loss of either VEGP Unit (8.2)
I cr 2 during a 1989 peak condition will not result in a loss of offsite power to the safety related loads at the plant site.
Provide the results of a study for the simultaneous loss of both VEGP Units 1 and 2 during the same type of 1989 peak condTtTon.
430.56 On FSAR Figure 8.2.1-2 or another FSAR figure identify the (8.2) location of the main stepup transformers, the unit auxiliary transformers and the reserve auxiliary transformers.
430.57 FSAR Section 8.2.1.2 and Table 8.2.1-2 indicate that the two (8.2) switchyard battery circuits are divided between the prinary secondary relaying, trip coils, and closing coils of the various 230 kV switchyard circuit breakers; however, FSAR Section 8.3.2.1.3 indicates that one battery circuit serves one switchyard (Unit 1) and the other battery circuit serves the other switchyard (Unit 2). Clarify this apparent discrep-ancy, and describe the de power supply to the 500 kV switchyard and the periodic maintenance which will be performed on all switchyard batteries. Also describe the physical separation between the switchyard circuit breaker control circuits of the two offsite sources.
If they are not separated show compliance with GDC 17 by verifying the plant can remain in a safe condition until at least one offsite circuit can be returned to service given a failure at the point where the circuits are not separated.
430.58
. Describe the instrumentation provided in the control room to (8.2) monitor the status of the offsite power circuits including the switchyard. Also describe the controls provided in the main control room to operate the switchyard circuit breakers.
430-17 430.59 FSAR Section 8.3.1.1.2 states that each reserve auxiliary (8.2) transformer has the capacity to supply all connected non-Class IE running loads and to start and run the loads of one Class IE train. Justify the capability to start and run only one Class IE train from each offsite source.
Is this capability limited by the capacity of the "Y" transformer winding or by the total transformer capacity? Following a loss of one preferred power supply to a Class 1E bus, do you intend that the diesel generator will supply the bus for the entire length of time allowed under this LCO?
Identify the loading on the diesel for this condition and justify its operation at that light load for that extended period.
430.60 FSAR Sections 8.3.1.1.2.0 and 8.3.1.1.3.D indicate that only (8.2) one circuit breaker is provided for the two cubicles available at each Class 1E 4.16 kV bus for connection to the normal or alternate offsite power source.
FSAR Section 1.9.6.2 seems to indicate that the arrangement may also be used to interconnect the redundant 4.16 kV safety buses when operating from the standbysource(dieselgenerators). This is unacceptable.
Interlocks should exist which preclude the manual closing of both interconnecting circuit breakers. This will prevent overloading of a preferred power source and interconnection of the redundant safety buses. Discuss your compliance.
430.61 Regarding the Class 1E and non Class IE 120 VAC power (8.3.1) supplies shown in Figure 8.3.1-4 and 8.3.1-6:
a)
Some of the inverter systems shown in these figures have one 125 VDC input while others have the DC input plus an additional 480 VAC input, although in very other respect they appear identical. Describe the function of the second input and give the design criteria used in specifying one type of system over the other.- Also, provide a one-line diagram showing the interconnections between the inputs and outputs within the inverter system
- block, b)
The General Electric UPS in Figure 8.3.1-6 shows only one input from a 480V/120V regulated transformer. This is a little unusual since the AC regulated input associated with an UPS is nonna11y a backup or maintenance supply to the loads. Describe and provide a functional one-line block diagram showing the major components of the UPS and identify any power inputs from other supplies. Also identify the loads this UPS feeds, c)
Figure 8.3.1-6 shows several manual 120 VAC load transfers between non Class 1E power supplies which are ultimately fed from redundant 4160 VAC Class 1E buses.
The config'. ration of the transfer circuits is such that a single failure of an open circuit breaker or transfer switch could potentially affect the redundant Class IE buses.
In light of the fact SRP Section 8.3.1.!!!.2.b
430-18 does not allow this configuration for connection of Class 1E loads to ' redundant Class 1E supplies, justify the acceptability of this configuration for non Class IE loads which are not vital to plant safety. The transfers in question are those shown in Figure 8.3.1-6 between the regulated transfomer and the inverter system to the Westinghouse computer, between regulated instrument buses INYS and 1NYR, and between the two regulated transfomers to regulated instrument bus INYRS.
Also identify all other non Class 1E transfers or interconnections which are connected to redundant Class IE power supplies.
430.62 FSAR Section 8.3.1.1.2.E and Figure 8.3.1-1 identifies (8.3.1) switchgear INB01, INB10, 2NB01, and 2NB10 as non Class 1E loads fed from Class IE supplies.. Identify any other AC or DC non Class IE loads fed from Class 1E supplies.
Also identify the isolation device which is used between the IE and non IE systems in accordance with Regulatory Guide 1.75.
430.63 Identify all the comon Class IE electrical loads shared (8.3.1) between Units 1 and 2.
Also identify their power sources, and if any of the loads have the capability of being supplied from either unit describe these connections and the interlocks which exist to preclude paralleling the Unit I and Unit 2 Class IE supplies.
430.64 FSAR Section 8.3.1.1.2.K.S states that nolded case circuit (8.3.1) breakers for motor circuits are equipped with instantaneous trip only, and motor overload protection is provided by themal trip units in the motor controller.
It also states that during startup and periodic testing all starters for MOVs are equipped with themal overloads (TOL), but prior to core loading and during plant operation the thermal overload contacts for all Class IE valves are permanently bypassed with jumpers.
In this regard the staff would like to point out that it is not the intent of RG 1.106 to totally eliminate the use of TOLs on MOVs.
It is intended to assure that under accident conditions the valve will not be hindered from performing its safety function by a spurious overload trip condition.
For the majority of valve operations such as during valve test or operation during non accident conditions, the use of TOLs in MOV circuits is a prudent operational practice to minimize motor damage due to overload conditions.
Though the proposed approach resolves concern relating to inadvertent operations of TOL under accident conditions, the staff does not recommend the virtual elimination of TOLs from MOV circuits by pemanent bypass. Address the following coments relative to the above:
.' a.
For the Class 1E MOV circuits that have the overloads jumpered out describe how your design protects the cables to the valve motors against sustained locked rotor i
currents or high impedance faults such that the cable will not fail and affect other Class 1E loads.
2
430-19 e
b.
Describe how the settings of the circuit breaker instan-taneous trips for the Class 1E MOVs satisfy the above concern as well as providing coordination while avoiding
~
spurious operation during normal motor starting tran-sients.
t c.
Continuous bypassing of Class 1E MOV overloads (except during periodic or maintenance testing) is not the only 4
option offered by RG 1.106. However, if it is used it must comply with the sections of IEEE 279 which are designated as requirements in RG 1.106. The use of jumpers to bypass the thermal overloads to Class IE MOVs.
does not comply with Section 4.13 of IEEE 279. ~The requirement is that the bypass (or in this case lack of a bypass) be continuously indicated in the control roon.
Please address this issue.
430.65 FSAR Section 8.3.1.1.2.L states that all Class IE circuit (8.3.1) breakers and motor controllers are testable during reactor operation, except for the electric equipment associated with those Class IE loads identified in Chapter ~7.
Identify the loads referred to in Chapter 7 and provide the justification for not testing, or reference the specific sections in Chapter 7 where the justification is provided.
430.66 FSAR Sections 8.1.4.2.C and 8.3.1.1.3.C state that under-(8.3.1) frequency protection is provided to safely separate the diesel generators from the preferred source during an underfrequency condition.
It is not clear that this feature can also be relied upon to open the diesel generator breaker when parallel with the preferred power supply and preferred power is subse-quently lost. Will the underfrequency or overcurrent pro-tection operate to open the diesel generator breaker first?
430.67 In your discussion of conformance with R.G. 1.9 in f. ?
b l
(8.3.1)
Section 1.9 you state that the diesels are qualifieo in accordance with IEEE Std. 344-1971.
FSAR Section 3.10.P however, states that electrical equipment is qualified it accordance with IEEE Std. 344-1975.
Correct this discrepancy..
and if the diesels are qualified in accordance with the 1971 versien of IEEE 344 state that fact in FSAR.Section.3.10.B.
430.68 Regarding your compliance with Branch Technical Position (8.3.1)
PSB-1 in Appendix 8A of the Standard Review Plant:
a)
Verify that the degraded voltage protection equipment is Class IE qualified and is physically located at and electrically connected to the Class 1E switchgear.
b)
FSAR Section 8.3.1.1.3.H states that studies have been performed which indicate that at the degraded voltage setpoint of 86.5 percent the permanently connected Class IE motor loads will not be damaged, and there is adequate voltage to start the Class 1E loads. Verify that, at the
___.________.________________-__._m,m_
1
~
430-20
-~
setpoint of 86.5 percent, no Class 1E loads will be damaged including all motor and nonmotor loads down to the 120 volt level. Verify that all these loads will start and operate satisfactorily, and no overcurrent devices (overloads, fuses, circuit breakers, etc.) will be tripped as a result of that degrade voltage. Provide the results of your studies which show the worst case transient and steadystate terminal voltage at each voltage level relative to the 86.5 percent relay setpoint.
c)~
Provide the results of your analysis used to select the voltage tap settings of the offsite power transformers in accordance with position B.3 of the Branch Technical
- Position, d)
Discuss your compliance with position B.4 of the Branch Technical Popition.
430.69 Regarding the load shedding and load sequencing:
(8.3.1) a)
Describe what provisions are taken to allow decay of motor residual voltage when a loss of offsite power occurs following a LOCA and the diesel generators are running in standby.
b)
FSAR Section 8.3.1.1.3.F states that logic has been provided that prevents more than three undervoltage conditions from being recognized within a two hour period in order to prevent automatically exceeding the manufac-turer's recomnendations concerning motor start capability of two successive starts within a two hour period. Does the manufacturer's limitation on motor starting apply to both MOV motors and pump motors? Does the logic count the number of undervoltage conditions when operating on offsite and onsite power? What is the purpose of requiring manual opening of the diesel generators breaker to reinstate sequencing following the block? Provide a more detailed discussion of the logic associated with this system, and discuss the safety benefit, if any, derived from it.
c)
Describe the load sequencer logic, circuitry, and components. Because the emergency loads are sequenced on both offsite and onsite power sources, we require that you either provide a separate sequencer for offsite and onsite power (per electrical division) or a detailed analysis to demonstrate that there are no credible sneak circuits or coer,on failure modes in the sequencer design P
that could render both onsite and offsite power sources unavailable.
In addition provide information concerning the reliability of your sequencer and reference design detailed drawings.
430-21 e
r 430.70 FSAR Section 8.3.1.1.3.H states that the diesel generators are (8.3.1) of the type and size that have been previously used as a standby emergency power sources in other nuclear power plants.
Identify the other nuclear power plants referred to and provide a comparison of the two machines which address the requirements given in Sections 5.4.2, 5.4.3, and 5.4.4 of IEEE Standard 387-1977.
If there are any differences between the two machines provide the additional tests and/or analysis required by these sections of the IEEE standard.
430.71 In FSAR Section 8.3.1.1.8.B you reference calculations that (8.3.1) have been made which indicate that motors rated to start at 80% of their nameplate voltages will not be provided pcwer at less than their capabilities. Provide the results of those calculations when the 80% motors are started on the diesel generators and when they are started on the offsite sources.
For the offsite power calculations assume the 4.16 kV bus voltage is at the setpoint of the degraded voltage relays prior to motor starting.
430.72 For the centrifugal charging pumps you state that the pump (8.3.1) brake horsepower exceeds the nameplate rating of the motor (670 hp and 600 hp respectively) but is within the capability of the motors which have a service factor of 1.15. The service factor applied to a motor allows it to deliver greater than rated horsepower without damaging its insulation system when operating at its nameplate voltage.
It is not, however, capable of delivering this same horsepower at reduced voltages. Therefore, justify operation of this motor at reduced voltages down to the settings of the degraded voltage relays.
430.73 Regarding motor-operated valves with power lockout:
(8.3.1) a)
Provide or reference motor control schematic drawings for the valves listed in FSAR Section 8.3.1.1.11.A which shcw the power lockout capability at the main control board.
Describe the technique used to lock the power out, and describe the redundant valve position indication and their power supplies provided for each valve.
b)
Clarify that the power is locked out to the accumulator isolation valves identified in FSAR Section 8.3.1.1.11.B by drawing the circuit breaker from the snotor control center during startup and maintaining it in the racked out position during reactor power operation.
c)
Identify how the accumulator isolation valve circuits
.complywitheachpositiongiveninBTPICSB-4(PSB)and provide or reference motor control schematic drawings for the valves.
Identify the redundant power supplies provided to the position indicators of each valve.
~
430-22 430.74 Regarding the containment building electrical per.etrations:
(8.3.1) a)
In FSAR Section 1.9.63.2 you state that the fault current in low-energy level control circuits and instrument circuits is limited and does not need backup overload protection. The fault currents in question should be limited to a value which is less than the continuous rating of the penetration (to maintain nechanical integ-rity).
If the currents are limited by transformer impedances the transformers should be capable of carrying that value of fault current indefinitely. Verify that the above is the case.
b)
Frovide a single line diagram of the penetration pro-tection protection circuits associated with the pro-tection curves given in sheets 1, 2, and 3 of Figure 8.3.1-7.
Show the primary and backup penetratior,over-current protection devices in these diagrams.
2 c)
The 1 t curves shown in Figure 8.3.1-7 are identified as penetration conductors.
The curves used should be the actual thermal capability curves of the penetration itself (to maintain mechanical integrity). Verify that this is the case or else provide these curves. Also identify how the curves were derived.
d)
The table given on sheet 1 of Figure 8.3.1-7 lists a 10 amp circuit breaker but the protection curves show a 15 amp circuit breaker.
Clarify this discrepancy, e)
Sheet 5 of Figure 8.3.1-7 shows fuses used as backup overcurrent protection for the load center motor feeders.
Assuming a circuit breaker failure and a single line-to-ground fault, one fuse will open and clear the fault leaving the motor operating in a single phase cordition.
It is not clear from the curves shown on this figure that the remaining fuses will open before penetration integrity is lost. Address this concern. Also clarify what the maximum available fault current is for these circuits.
j f)
The single-line diagram on sheet 6 of Figure 8.3.1-7 shows a No. 3/0 AWG penetration, but the thennal capabil-ity curve is labeled as No. 2/0 AWG.
Clarify this discrepancy.
g)
For sheet 8 of Figure 8.3.1-7 clarify what the maximum
,available fault current is at the penetration.
h)
The 25 amp magnetic-only circuit breaker shown on sheet 12 of Figure 8.3.1-7 does not provide redundant pro-tection over the entire range of the thermal capability curves for the no. 8 and no. 6 penetration conductors.
430-23 Correct this deficiency. Also identify the maximum available fault currents at the penetrations for the circuits shown in this drawing.
69 f*
e 7
.ki-
~
_:a v :
mL w,.,,a.,
s
___w.
3 f'#.
(
UNITED STATES
[
't, NUCLEAR REGULATORY COMMISSION' b
i-WAsHINGTC N, D. C. 20555 e
DCT 0 61984 t
k
- . = -
MEMORANDUM FOR:
Thomas M. Novak,'A'ssistant Director for Licensing, DL
.i
-j FROM:
James P. Knight, Assistant Director for Components & Structures Engineering, DE l
i
SUBJECT:
DRAFT SAFETY EVALUATION REPORT - GEOLOGY AND SEISMOLOGY -
- }
V0GTLE, UNITS 1 AND 2 q,
i PLANT NAME:
Vogtle Electric Generating Plant, Units 1 and 2
'{
DOCKET NUMBERS:
50-424/425 LICENSING STAGE:
OL Review
{
PROJECT MANAGER:
Melanie Miller, LB4 Enclosed are the geology and seismology sections for the Vogtle Draft SER, SRP Sections 2.5.1, 2.5.2 and 2.5.3.
The report was prepared by Ina 8. Alterman, Geologist and A. Ibrahim, Seismologist.
As stated in the SER, the staff concludes that there are no capable faults at the site or in the region around the site and that the SSE and OBE are adequate.
A six-month geological and geophysical fault investigation, undertaken to address a possible nearby fault, the Millet Fault, postulated in the USGS Open-File Report 82-156, failed to produce any evidence for the existence of the fault.
i
(
The GSB staff reviewed the study and concurred with the applicant's. conclusions.
A recent clarification of the USGS position with respect to the 1886 Charleston, S.C. earthquake has resulted in NRC-sponsored probabilistic and deterministic.
studies concerning seismicity in the eastern U.S.
At the conclusion of these studies we will be assessing the need for modified positions with respect to eastern U.S. sites.
At this time we see no need to modify the position taken for Vogtle during the CP review and the staff does not consider the issue an.
open item.
~
\\.
' Q, 3
=
.\\
s f-:
J. P. Knight,', Assist'nt Director a
~!
for Components & Structures Engineering, DE Enclosure k'
cc:
R. Vollmer S. Brocoun J. Knight I. B. Alterman E. Adensam A. Ibrahim a
M. Miller D. Eisenhut
]
L; Reiter
~
i d
^?v^- c^^^U /y' l;
c} s' '~ }e
/
h vi y
7,,.
..,,7,,...
3
--J' T W- --
s
-l v:
-(:.
~
(_
(
- =
V0GTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DRAFT SAFETY EVALUATION REPORT 2.5 Geology and Seismology a
Far this SER, the staff has reviewed all available relevant geologic and seis-cologic information obtained since the issuance of the CP-SER and supplements to the CP-SER in 1974 (USNRC, 1974) in accordance with.the SRP.
In the CP-SER the staff and their consultants, the U.S. Geological Survey, conc 1uded that:
(1)
Geologic and seismologic investigations and information provided by the applicant provide an adequate basis for determining that no faults exist at, or in the immediate vicinity of, the plant site that could localize seismicity.
(2)
Ground motion values of 0.20g and 0.12g for the Safe Shutdown Earthquake (SSE) and the operating basis earthquake (05E), respectively, are ade '
quately conservative.
Since the issuance of the CP-SER, the applicant has performed further detailed geologic and geophysi~ cal investigations of-the site and site _ region.
This includes geologic mapping of the excavation for the main power block area, and a fault investigation prompted by a United States Geological Survey open-file report postulating the existence of the Millet Fault seven miles south of the plant site. A staff review of this investigation is discussed in Section 2.5.3 of this SER.
During the current review, the NRC staff identified the following issues for evaluation:
k 09/26/84 2.5-1 V0GTLE SER INPUT SEC 2.5
C L
(1) new geological and seismological information discovered since the CP review l
i
(
(2) the postulated Millet Fault south of the Vogtle site (3) significance of clastic dikes and associated structures at the site and in the site region (4) the adequacy of the seismic design response spectrum Much of the new geologic and-seismic data has been developed from research in the southeastern United States, particularly in the Charleston, South Carolina area.
During past licensing decisions the NRC and AEC have held to the posi-tion that the relatively high seismic activity within the Coastal Plain Pro-vince in the vicinity of Charleston, S.C., including the 1886 Modified Mer-calli Intensity (MMI) X earthquake, was, for licensing decisions, related to a unique tectonic structure there.
Therefore, in the context of the tectonic province approach, an MMI X earthquake should not be assumed to occur anywhere else.
This conclusion was based primarily on the persistent historical seis-micity that has characterized the meizoseismal zone of the 1886 Charleston, S.C.
It was also based on evidence, though not strong, of unique geologic structure.
Lacking definitive information, the NRC-AEC based its conclusions in part on advice from the U.S. Geological Survey.
In 19.73, with AEC funding, the USGS began extensive geologic and seismic investigations in the Charleston, S.C. region.
These studies are still under-way.
As a result of these investigations, a great deal of information has b;.en obtained, but the source mechanism of the seismicity still is not known.
Many working hypotheses have been developed based on the research data.
These hypotheses are described in the Virgil C. Summer Safety Evaluation Report (USNRC,1981), and will not be discussed here, except to say that some of these theories postulate that an earthquake th's size of the Charleston,. S.C.
carthquake of 1886 could recur in other areas of the Piedmont, Atlantic
~ _
Coastal Plain, and continental shelf in addi. tion to the epicentral area.
.~
~.
-~
09/26/84 2.5-2 V0GTLE SER INPUT SEC 2 5
}
{
(
E' Because o,f the wide range o,f opinions within the scientific community con-cerning the tectonic mechanism for the Charleston, S.C. seismicity, the USGS
\\
clarified its position regarding the 1ocil'ization of the seismicity in the
~
vicinity of Charleston, S.C., including the 1886 MMI X earthquake (Novem-ber 18, 1982 letter from James F. Devine, USGS, to Robert E. Jackson, NRC).
The NRC staff has formulated an interim position concerning eastern seismicity in general and Charleston, S.C. seismicity in particular (see Appendix A to
~
this SER and March 2, 1983 memorandum from R. Vollmer to H. Denton). As part of future research efforts described in that position, the NRC staff is
. addressing the uncertainties about eastern seismicity by probabilistic studies funded by NRC and conducted by Lawrence Livermore National Laboratory (LLNL).
At the conclusion of these studies, the NRC staff will. assess the need for a modified position with respect to specific sites.
In the interim, considering the ' speculative nature of most of the eastern seismicity hypotheses, the low probability of large earthquakes in the eastern U.S. and present knowledge of the geology and seismology of the region, the NRC staff considers the Vogtle design basis appropriate.
The staff does not consider this issue an open item.
After careful review of the new information as provided and evaluated by the applicant, the staff concludes that there is no basis for altering its con-clusions stated in the CP-SER concerning the safety of the Vogtle site.
The staff has evaluated the FSAR and subsequent documents and information including excavation and trench mapping, and the fault. investigation report,
" Studies of postulated Millet Fault" (Georgia Power Co., 1983).
The staff has concluded that the applicant has (1) performed satisfactory site and regional geologic and geophysical investigations, (2) reviewed all available pertinent literature, and (3) provided the staff with all information necessary to evalu-ate, assess, and support the applicant's c.onclusions concerning the safety of the Vogtle site from the geologic and seismologic standpoint.
In addition, the staff finds the app.licant has satisfied the requirements of and is in compliance with applicable' portions of the following:
09/26/84-2.5-3 V0GTLE SER INPUT SEC 2.5
p, 1
(
(.
_(1) Appendix A to 10 CFR 50
\\
(2) Appendix A to 10 CFR 100 (3)
SRP Sections 2.5.1, 2.5.2, and 2.5.3 i
(4)
RG 1.70." Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants," Rev. 2 (5) those portions of RG 1.132, " Site Investigations for Foundations of Nuclear Power Plants," applicable to the development of geologic and seismologic information relevant.to the stratigraphy, lithology, geologic history, and structural geology of the sitt.
(6)
RG 4.7, " General Site Suitability Criteria for Nuclear Power Stations" i
(7)
RG 1.60, " Design Response Spectra for Seismic Design of Nuclear Power Plants" In the following sections, the staff reviews the geologic and seismologic information and bases for its conclusions.
2.5.1 Basic-Geology The three fundamental geologic concerns add'ressed in this OL-review, in order to confirm the geologic safety of the site, were:
(1) the large body of new information rapidly accumulating in the south-eastern U.S., in the Piedmont and Coastal Plain, partly because of NRC-funded research, that has resulted in greater knowledge of the sub-i surface and modifications of interpretations of the tectonic history of l
eastern North America; (2) the problem'atic, and almost ubiquicous,,, occurrence of clastic dikes in the upper Eocene and lower Miocene strata of Georgia, South Carolina and North Carolina, the origin of"which had not been investigated in depth; and
,09/26/84, 2.5-4 V0GTLE SER INPUT SEC 2 5
-:: := =. = =
= = =
(
(
's (3) the possibility.of a fault of unknown age postulated by Open-File Report 82-156 of the U.S. Geological Survey to occur seven miles south of the Vogtle site.
~ '
~
ThecInclusionsreachedforwhichthefollowingsectionsprovidestheback-ground and justification are:
(1)
No new information detrimental to the safety of the.Vogtle si.te has been uncovered.
(2) Although the origin of the clastic dikes is still not demonstrated with certainty, their apparent great age, in the hundreds of thousands to millions of years, assdres that they are not a safety concern to the
- ' plant site.
(3) Geological and geophysical investigations confirm that no fault is present at or near the site that has offset any strata younger than 40 million year 3 old.
\\.
~2.5.1.1 Regional Geology The Vogtle Plant is located within the Atlantic Coastal Plain province about 25 miles southeast of Augusta, Ga., and on an upland surface about 100 feet above and adjacent to the Savannah River..At the plant site Coastal Plain sediments range in thickness from 800 to 1,000 feet, consist predominantly of sandstone, shale, limestone, claystone, and marl, and range in age from Upper Cretaceous (138 to 63 million years before the present (mybp)) to Holocene (10,000 yBP to the present).
2.5.1.1.1 Stratigraphy Except for river al.luvium and gravels of Quaternary age (2 mybp-Present), the ytungest, most extensively exposed formation.in the region is the Hawthorn (or Altamaha)' Formation, a red and yellow, thic.k.-bedded sandy clay, of Miocene age
~(25-5 mybp).
e 09/26/84 2.5-5 V0GTLE SER INPUT SEC 2.5 s.
i
(
b Underlying the Hawthorn Formation is the Upper Eocene (55 to 38' mybp) Barnwell Group, with a basal soluble limestone, and, a variety of rapidly changing '
assorted sandy and sandy limestone forma'tions and facies that change capidly both laterally and vertically.
The oldest exposed rock unit, the Blue Buff marl of the Lisbon Formation, is i
a calcareous, silty, grayish fossilifero^us unit, distinctive in lithology and fauna, and of middle Eocene age (50-40 mybp).
The marl is limited in exposure in the banks of the Savannah River which has begun to cut down through it.
Because of its clay content, its density and compaction, the marl is the bearing stratum upon which the applicant chose to build the main power block.
The Eocene formations rest unconformably on Paleocene (63-55 mybp) clays and black lignitic sands which are also distinctive.
These overlie the late Cretaceous (96-63 mybp) Tuscaloosa Formation unconformably.
The Cretaceous sediments are the oldest of the late Mesozoic (240-60 mybp) marine trans-gression deposits that constitute the Coastal Plain covermass.
Adjacent to and northwest of the Atlantic Coasta3 Plain Piovince is the Pied-mont Province.
The boundary between the two provinces is known as the Fall Line which is approximately 25 miles northwest,of the site.
Rocks that char-acterize the Piedmont disappear beneath the Coastal Plain sediments at the Fall Line, but no structurally significant boundary exists.
2.5.1.1.2 Structure and Tectonics In several places in the Piedmont, west and north of the Coastal Plain, Tri-assic down-faulted basins filled with distinctive Triassic sedimentary rocks and some Triassic-Jurassic basaltic igneous rocks are exposed.
Similar basins have been recognized beneath the Coastal Plain.
One such basin, the Dunbarton Basin, trending northeastward, has been identified on the basis of aeromagnetic anomalies and drilling for the Savannah River' Plant (Marine and Siple, 1974).
The Vogtle plant overlies the basin, close to the northern boundary. As this basin'is dowrifaulted, presumably into Piedmont rocks, it is assumed that the rocks below and surrounding.the basis are Precambrian (older than 570 mybp) i and early Pale'ozoic (570-240~ mybp) metamorphics'. ~
~~
. 10/02/84 2.5-6 V0GTLE SER INPUT SEC 2.5
i'
{.
At the surface, the' Coastal Plain strata overlying the Piedmont and Triassic btsins, is gently-dipping towards'the southeast, and, on the large scale,-
relatively undeformed, reflecting the reia5ive tectonic quiescence of a passive continental margin at great distances from a lithospheric plate boundary, where'most seismic, volcanic, and tectonic activity occur, according to the plate tectonics pa,radigm.
^
Recent deep seismic reflection profiling (Cook, et al,1979) has identified a large scale detachment surface under the Applalachians, from the Allegheny Plateau to at'least the central part of the Southern Piedmont, indicating a large allochthonous mass above the continental basement.
There is, however, no certainty that the detachment continues under the Coastal Plain (Iverson and Smithson, 1983).
Although it has been suggested that this detachment surface may be localizing seismicity (Seeber and Armbruster,1982), this has not been demonstrated.
As this is also one of the hypotheses regarding the source of the Charleston 1886 earthquake, it is being addressed in,the Interim Charleston Position of the NRC.(see Appendix A of the SER).
GeophysicIl evidence has suggested the possibility that the P.iedmont~ and its
~
extension under the Coastal Plain is constructed of several discrete, litho-logically and geophysically distinct masses (or terrains).
These are postulated to have coalesced by accretion during middle and late Paleozoic tectonic events as the pre-Atlantic Iapetus Ocean closed, resulting in the continental collision of-North America with Africa (Williams and Hatcher, 1982).
Although attempts to correlate modern seismicity with these terrain boundaries have been made (Wheeler and Bollinger, 1984) the correlation is not convincing and, therefore, this hypothesis has not gained much favor.
Moreover, the Vogtle site is not near the postulated terrain boundaries and thus'is not affected by this information.
A recent U.S. Geological Survey report (Prowell,1983) catalogues faults of Cretaceous and Cenozoic age (63 to 2 myEP), primarily in the Coastal Plain and the Piedmont.
The faults of those ages closest to the Vogtle site are the Belair en echelon faults at least 25 miles _ north of the site, and an unnamed pair.
'of small faults forming a ten-foot wide graben in a kaolin mine about 27 miles e
10/02/84 2.5-7 V0GTLE SER INPUT SEC 2.5 j
y..
t
(..
~
north of,the site, in South Carolina.
These faults offset upper Cretaceous stdiments.
No seismicity has every been associated with these faults. There
=-
\\
are no other faults listed that are' riear the site, or within 50 miles.
l It is significant to note that the Millet Fault, postulated by the same author in an earlier report (Faye and Prowell,1982), is not included in the more i
recent catalogue of documented Cretaceou's and younger faults.
2.5.1.1.3 Clastic Dikes Dike-like structures are common and widespread in the younger Tertiary sedi-mentary strata of the Miocene (24-5 million years before the present-(mybp)).
They are found in the upper Coastal. Plain from Georgia to North Carolina in two upper Miocene formations, the Barnwell Formation and the overlying Haw-thorn Formation.
The conclusions drawn by the applicant from a limited reference and full investigation required by the staff is that the dikes do not represent a safety issue because they appear to be very old, between 10,000 to 100,000 yrs.
The staff concurs.with this assessment and suggests the possibility of the dikes having formed close to 20 mybp.
The following provides scme of the background and information that we're the bases for the above stated conclusions.
The origin of the structures, primarily "c astic" dikes, some with associated faults and folds, is still not understood.
Because of the lack of detailed information, they have been proposed, among other possible causes, to have had i
a seismic origin, possibly related to the Charleston 1886 earthquake (Seeber and Armbruster 1983), the result of subsidence, differential compaction, weathering and sofi formation, or infilled extension cracks in soil.
The dikes have been studied by several authors (Heron, et al, 197'1; Zupan and Abbott, 1975; Secor, 1979; M.cDowell and Houser, 1983).
None of these, however, was a long-term systematic st'udy to attempt to relate all the. features, nor to determine the age, extent, and geometry.
i
- .10/02/84.
2.5-8 V0GTLE SER INPUT SEC 2.'5
(.
C
~
At the re, quest of the staff, the applicant did more reference work and recon-naissance field observations to provide further information, in an effort'to determineifthedikesrepresenta'sa'feth-ielatedconcern.
~
During the course of their study, a large waste disposal trench was dug within the Vogtle exclusion area, two miles south of the plant, for burying i
construction-related wastes.
The trench, about 900 ft. long, 75 ft wide and 35 ft. high, exposed several interesting features, including subsidence sags, faults, dikes and small diapiric structures.
e Along with other features seen in the vicinity and within 30 miles of the plant, the trench exposure provided more information on some aspects of dike genesis in the area.
The a;iplicant logged the trench and submitted a detailed repo'rt and analysis.
A staff geoscientist toured the area with the applicant's consultants and examined the trench prior to the mapping.
Thereportdescribesseverallithicunitsexposedinthetrench, interpreted to be the, upper sands of the Barnwell, the lower massive sandy clay of the Haw-thorn which is truncated by erosion and ove'rlain unconformably by a layer of fine gray aeolian sands.
The strata are warped into several folds, with the downwarps accompanied commonly by normal faults and graben-like structures, indicative of differential subsidance of the strata into voids below.
Narrow, relatively planar dikes of clay emerge from the Barnwell sands, commonly along the faults and, often, unrelated to faults.
The dikes appear to flare out upward in the dense, compact sandy clay, into a myriad of branches or distributaries, irregular and non planar in shape, sometimes somewhat vertical but curving to an arch.over downwarps.
The gray clay dikes are" distinguished only by their light color that stands out against the red or yellow host strata.
In some areas along the trench, blobs and clumps of the same material as the dikes can be seen near the contact with the overyling sands.
The applicant reports channeling and weathering of the middle thick sandy clay dike-bear'ing unit to a soil below the overlying gray sand.
The dikes appear
'to be truncated at the contact with the aeolian sands.
l 09/26/84 2.5-9 V0GTLE SER INPUT SEC 2.5 L
kl b.
Elsewhere,in the site area, dikes often are fairly planar, much' thick'er than in the trench, to about.3-4 in. as opposed,to 1-3 in. in the trench.
The'most striking feature of the thicker ~ dikes' ouEside the trench is the grading from a thin clay center outward to a yellow sandy border and a deep red rind or crust bounding the dike. The red crust is resistant to the characteristic weather-ing of the host strata, and thus stands out in relief within the sandy units i
in which they are found.
A few exposures along the local roads show narrow dike-lilie projections in coarse sand units in which there appears to be no distinction except in color between the dikes and host stratum.
The applicant reports distinctions in the clay content of the " dikes" and the host stratum.
These cbservations have led the applicant to conclude in the report that the dikes are primarily a weathering phencmenon in which groundwater has made its way along pre-existing fractures, bearing and depositing transported clays or leaching out chemicals to alter the character of the fracture zones.
The altered fractures then appear to have been intruded by clastic or clay material.
In addition, the surface weathering, soil development, channeling, and trunca-tion of dikes at the aeolean sand-dike bed contact suggest to the applicant a great length of time from the formation of the dikes and the weathering and erosion of the upper part of the unit.
The estimate based on weathering alone is 10,000 to 100,000 yBP.
Although the staff,does not agree with all-' aspects of the applicant's report, particularly the mode of formation of the dikes, it concurs that they are very old, probably having formed early in the development of the strata in which they are found, which are between 24-20 mybp.
As the dikes intrude sandy strata in narrow channels and flare outward into very dense clay layers, which is the reverse of what would be expected if they were liquefaction structures, it is suggested'that the strata must have been very loosely consolidated or still saturated in order for the dike material to penetratewha'tisnowalmostimpermeablecl.ay. layers.
Such a condition would exist in the early.;tages of sedimentation almost 20,25 mybp.
09/26/84 2.5-10 V0GTLE SER INPUT SEC 2.5
~
G
-C Based therefore on current knowlidge, and considering the likely great age of
~
the dikes, there is no evidence th'at these features represent a safety issue
~
for the plant, whatever their origin.'-
/
- 2. 5.1.'2 Site Geology It is the applicant's view that extensive core drilling and mapping of the main i
power block excavation has provided evidence that the bearing stratum is sound,
~
-lacking faults, solutioning, or any othei geologic feature that may represent a safety concern'.-
Although small depressions are observable in several localities in and around
, the plant site, drilling has shown they are the result of solutioning of the Utley Limestone, a thin, fossiliferous, basal unit of the Barnwell Group.
Overlying strata, such as that seen in the trench, have subsided into solution cavities.
The applicant reports that no evidence for solutioning in the Lisbon clay-marl bearing stratum below the Utley Limestone has been found in drilling or in the excavations.
.s Some reservations that the staff has regarding characteristics of the bearing stratum are addressed in Section 2.5.4 of-this SER.
,,.e-*-
e o
e e p
e
5.
. k.
b
.. =
2.5.2 Vibratory Ground Motion
~
The conclusion reached during the construction permit (CP) review by the staff, the staff's consultant, the U. S. Geological Survey and the U. S.
ArmyCorpsofEngineers,wasthat0.20g(SSE)and0.12g(OBE) i accelerations were adequate.
During the Operating License (OL) review, the NRC staff seismological review was based on geologic and seismologic information in the Vogtle PSAR and FSAR and other available literature.
The review concentrated on the following:
1)~
A review of the seismicity of the region and examination of the association of earthquakes with geologic and tectonic features.
2)
A determinatisn of the vibratory ground motion at the site from the maximum historical earthquake within the tectonic province, an' from d
recurrence of the 1886 Charleston, S. C. earthquake.
3)'
A comparison' of the ground motion ehtimated in (2) above with the SSE proposed for the site.
Our review indicates that those conclusions reached during the CP review regarding the adequacy of the SSE and OBE at Vogtle are still appropriate.
2.5.2.1 Seismicity
..._1___..
~
.7
' 'J ". '.
"~
~
('
(
l l
Bulletins of the southeastern U. $.' Seis~mic Network describe the seismicity since 1977 in the vicinity of the Vogtle Electric Generating Plant (VEGP). Before that, most of what is known about the site region seismicity was based mainly on intensity data.
In general, the seismicity within 50 miles of the site is very low. The maximum historical event within that radius is intensity IV.
Within 200 miles of the site the only earthquake of epicentral intensity greater than or equal to VII was the Union County, South Carolina earthquake of January 1,1913. This earthquake, which occurred in the southern Piedmont had an epicentral intensity of VII (Stover, et al 1984) and was not felt at the site of the VEGP.
In addition to this earthquake, larger earthquakes at distances greater than 200 miles were examined.
The New Madrid, M0 earthquake sequence of 1811-1812 occurrad in the New Madrid Seismic Zone about 530 miles NW of the VEGP and included a maximum epicentral intensity of XI (Stover et al,1984).
Nutt11 (1973) indicated that this earthquake was felt in Georgia 'with a maximum intensity of VI.
The Giles County, VA earthquake of May 31, 1897 occurred about 280 miles north of the site in the Valley and Ridge province and had an epicentral intensity VIII (Bollinger,1973).
Bollinger indicated.that intensity III may have been felt at the site. Another earthquake was the New Brunswick earthquake of January 9,1982, which was about 1250 miles from the Vogtle site and had a ma'gnitude of 5.75 and an epicentral intensity of VI.
This earthquake occurred in the Piedmont-New E.ngland Tectonic province.
e e
h l
%?
Q 1
- =
An earthquake of significance to the VEGP is the Modified Mercalli intensity (MMI) X (Stover et al 1984) at Charleston-Summerville South Carolina. This is the largest historic _ event along the eastern seaboard of the U. S. and occurred in a concentration of seismic activity in the Atlantic Coastal Plain province about 78 miles from the. site.
The E
intensity of this earthquake at the site was VI.
Other earthquakes in the Atlantic Coastal Plain are discussed in Section 2.5.2.2 2.5.2.2 Tectonic Provinces and Maximum Historical Earthquakes The Vogtle site is located in the Atlantic Coastal Plain province.
This province extends from the Fall Line (the southern boundary of the Piedmont Province) 25 miles to the northwest, to the edge of the continental shelf to the east and southeast.
Other tectonic provinces within 200 miles of the site include, the Valley and Ridge province, the Blue Ridge and the Piedmont. Other than the Coastal Plain province, the above provinces and all other provinces outside the 200 miles radius are at sufficient distance so as not to have any impact on the Vogtle seismic design.
In the Southern Appalachian area, the staff has for the purpose of licensing treated the southern Piedmont as a separate area within the assumed Piedmont-NewEnglandtectonicprovince(i.e.McGuire,s'ummer, Catawba SER's).Basedontheavailableinformationitwasnotpossibletorelate past earthquakes to geological structures in the southern Piedmont or the Coastal Plain province.
Except for the Charleston, South Carolina area where the high' seismicity cannot be considered typical of the rest of the
f.
(-
_4
[
. = '
Atlantic Coastal Plain, this province is characterized by low to moderate seismicity. The largest reported earthquakes in the At1 antic Coastal Plain ~
province are the Asbury Park, N.J. earthquake of 1927 with MMI VII, and the Wilmington, Delaware earthquake of 1871 with MMI VII. Therefore, an event similar to the MMI VII mentioned above should be~ considered as the i
maximum historical earthquake likely to effect the site.
Based on the es'timated felt area, the Asbury Park earthquake and the Wilmington earthquake (Kafka, 1980) had an estimated magnitude less than 5.0.
Nuttli and Herrmann (1978) indicated that an appropriate equivalent magnitude to an epicentral intensity of VII is a magnitude 5.3.
It is the staff's conclusion that the maximum randcm earthquake in the Coastal Plain
~
province can conservatively be defined or having an estimated magnitude of 5.3.
The August 31, 1886 Charleston, South Carolina-earthquake is listed with epicentral intensity X.
The center of the area of maximum intensity was located near Middleton, S.C.
The Charleston-Summerville, South Carolina region is presently under investigation.
Interpretations that have been published so far regarding the cause of the Charleton earthquake differ considerably as far as the possible mechanisms are concerned.
The staff current position, as in the past (V. Sumer Nuclear Station, SER)thatinaccordancewiththetectonicprovinceapproach(AppendixAto 10 CFR 100), the effects of a recurrence,of an event the size of the O
e g.
~
g.
j Charleston earthquake in the Charleston-Summerville area shall be postulated to assess its influence on the VEGP.
Additional discussion of the Charleston earthquake is found in Section 2.5.1 and Appendix (A) of 6
this report.
2.5.2.3 Safe Shutdown Earthquake At the CP stage (SER-CP Suppl. 1) the staff concluded that the maximum site intensity will be no greater than VII and the SSE acceleration of 0.2g used for the Vogtle units to be adequately conservative.
The staff position regarding the VEGP site is that the following seismic issues should be considered for the SSE design.
1.
The maximum random event in the Coastal Plain tectonic province, an event of MMI VII equivalent to mb=5.3(Nutt11andHerrmann,1978) in the vicinity of the site.
2.
An event of the size of the 1886 Charleston earthquake MMI X occurring in the vicinity of the Charleston Summerville area about 78 miles from the site.
Based on the tectonic province approach the staff finds that the maximum random event in the Coastal Plain was of MMI VII.
The resulting mean value of peak horizontal acceleration at the site was estimated to be 0.13g (Trifunac and Brady, (1975).
In recent Safety Evaluation Reports (for'examp1','HopeCreek, Millstone, Limerick)thestaffhasindicated e
V' 6-thatsitespecificspectraobtaine'dfroEiapprorriatesuitesofearthquake
~
strong motion records are more in accord with the controlling earthquake a-size, frequency content of response spectrum an local site conditions a
than are standard Reg. Guide 1.60 spectra.
In this method the use of the peak acceleration and Reg. Guide 1.60 spectrum shapes are replaced by spectra obtained from earthquakes within half a magnitude of the safe shutdown earthquake recorded at a distance less than 25 km with geologic conditions similar to those at the site.
It is the staff position that sp.ectra obtained by this method is a more realistic estimate of the seismic ground motion f6r Vogtle. The spectra should be based on an appropriate ensemble of records with mbig = 5.3 :.5 obtained at a soil site within 25 km of the source. The staff position has been that the 84th percentTlespectrumisappropriatefordescribinggroundmetiontobeused
~
in evaluating the design ~ spectra of nuclear power plants.
Previous staff reviews of site specific spectra for s il sites (Hope Creek, NUREG, Wolf Creek, NUREG-0881, and Palo Verde, NUREG-0857) indicate that the Reg. Guide 1.60 spectrum anchored at 0.2g is adequate for describing ground motion for a magnitude 5.3 event.
With respect to the Charleston earthquake of 1886 Nuttli et al (1979) estimatedthemagnitude(m)tobe6.6.'ThedistancebetweentheVogtle b
site and the meisoseismal area of the 1886 earthquake is 78 miles.
Using theeq'uationsderivedbyNuttli(1983)andCampbell(1981)thestaff
X
(
(.
(
, estimated the 84th percentile accelerations at VEGP due to the reoccurrence of such an event to be less than 0.2g.
Based on consideration of both the local magnitude 5.3 and the reoccurrence at an earthquake the size fo the 1886 earthquake in'the~
i Charleston area, the staff considers the Reg. Guide 1.60 response spectrum anchored at 0.2g used for the design of Vogtle to be acceptable.
2.5.2.4 Operating Basis Earthquake The applicant has proposed 0.12g for the acceleration level corresponding to the operating basis earthquake. This represents more than half of the SSE acceleration 0.20g, consistent with Appendix A to 10 CFR 100 which
~
indicate that the OBE to be at least half of the SSE.
2.5.3 Surface Faulting 2.5.3.1 Postulated, Millet Fault For the construction permit, the applicant's geological investigations concluded that there was no surface faulting in the vicinity of the Vogtle site.
Prior to submission of the FSAR for the OL. review, a document released by the U.S. Geological Survey, Open-File Report (OFR)82-156, (Faye and Prowell, 1982) postulated the existence of a fault, thi Millet Fault, seven miles south 10/02/84 2.5-11 V0GTLE SER INPUT SEC 2.5 2
- ~~
.T.~~.
~
c
7
(
Altho'gh the report was a water resources study of the hydrology of the site.
u.
and gcciogy of the Coastal Plain in the vicinity of the Savannah River, indirect
(
eviden, e from secondary sources suggested'to the authors the possibility of a fault across the Savannah River.
The report further postulated a second fault, the Statesboro Fault, 32 miles i
s uth of the plant.
As interpreted by Faye and Prowell, the Millett Fault trends northeastward across the Savannah River, is approximately 40 miles long, and has vertically offset the buried Triassic / Cretaceous contact +600 ft. on the southeast side of the fault.
The. main evidence for the inferred fault came from a comparison of well cut-tings taken several years before the OFR study from two water wells, P5R and AL66.
Interpretation of the lithic fragments suggested that Triassic rocks were present belcw -1100 ft in PSR, but above 600 ft in AL 66 four Eil'es to the south.
Further, an examination of surface and groundwater flow records over a period of forty years, indicated some. anomalous characteristics which Faye and Prowell interpreted as resulting from a subsurface barrier.
By extrapolation from the Belair Fault 35 miles to the north, the OFR inferred that an impermeable gouge zone above the postulated Millett Fault forced the south flowing groundwater from a lower aquifer to a higher one on the south side of the fault.
As the trace of the postulated fault traverses a segment of the Savannah River where a straight stretch of the river changes to a more characteristic meandering flow pattern, the OFR considered this observation further support for the inferred fault.
Evidence for the trend and length of the postulated faults was by extrapola-tion from other post-Cretaceous Coastal Plain faults in the southeastern United States.
While no age of faulting was suggested, the OFR indicated that rocks at least through the Eocene epoch (55-38 mybp) were, involved.
es 09/26/84 2.5-12 V0GTLE SER INPUT SEC 2.5
C' C
2.5.3.2 Fault Investigation
- ~
~
2.5.3.2.1 Introduction At the request of the NRC staff, the applicant undertook a detailed investi-gative program, as the age and therefore capability of the inferred faults were undetermined.
In October,1982, Georgia Power Company submitted to the NRC a report of a fault specific investigation entitled, " Studies of Postulated Millett Fault" (GeorgiaPowerCompany,1983). The post'ulated faults, the Millett and States-boro Faults, were the subjects of the utility's fault investigation, with the primary focus on the former which was closer to the plant.
Technicues'Used in the Investigation:
SCS utilized a wide range of techniques to' exp1 ore the surface and subsurface for both geologic and hydrologic information in order to locate and date the fault.
Included in the study was (1) field geologic mapping, (2) aerial and Landsat imagery for remote sensing analysis, (3) core drilling on both sides of the Savannah River and straddling the interval of the two wells described in the open file. report, (4) petrographic, x-ray and heavy mineral analyses of core samples, (5) downhole geophysical studies including gamma, neutron and electric logging, (6) seismic reflection profiling, (7) regional geophysical and seismicity studies, (7) well water level monitoring, (8) groundwater modelling, and (9) analysis of surface water flow.
Staff Review:
Because of the wide range of techniques used, several NRC staff reviewers have contributed to this evaluation of the utility's report; a geologist covering
~
the varied geologic investigations, a seismologist for the historic and pre-sent day seismicity of the area, a geophysicist for the seismic reflection profiling, and a hydrologist reviewing the_, surface and groundwater study.
In addition, the geologist and one of the geophysicists have visited the site
~
region with the NRC project manag'er and'SCS staff to n amine i.he cores drilled 09/26/84 2.5-13 V0GTLE SER INPUT SEC 2.5
(..
~
w yv I
b.'
(.
for this study, t,he stratigraphy, and various aspects of the surface features I
j-in order to have first hand experience in evaluating the fault investigation r: port.
Conc 1bsions:
The conclusion arrived at by the applicant, based upon the results of the study, is that there is no evidence for a capable fault; and that.if there is a fault, which could not be detected by any of the techniques used by the applicant, it is older than 40 mySp'.
The staff agrees that this conclusion is censistent with the reported information and results of the various investi-gative techniques.
2.5.'3.2.2 Summary of Fault Investigation and Results A brief summary of these results, the applicant's views, and the bases for the applicant's and staff's conclusions follow.
2.5.3.2.2 1 Geol'ocic Investication:
The geologic investigation included (1) field mapping and remote sensing to identify evidence for surface faulting; (2) core drilling with petrographic, x-ray and heavy mineral analysis of the strata in the cores in order to correlate layers frem core to core to determine any offset of the strata; (3) downhole geophysic:1 logging, which identifies individual strata by characteristic signa-tures that are dependent upon the physical properties of the rock units, also with a view te correlating the strata from core to core; and (4) review of other g:ophysical studies.
1.
Field mapping and remote sensing techniques failed to uncover any evidence of surface faulting, or linear features indicative of surface or near surface rupture.
Staff review of some of the original imagery used for the study and. field checks in the site area verified this conclusion.
'2.
Twelve drill cores were taken along two parallel north-south lines, cross-ing the inferred trace of the Millett Fault, one in South Carolina close
\\
09/26/84 2.5-14 V0GTLE SER INPUT SEC 2.5
)
~~
E'
{.
{
i to the two wells studied by Faye and Prowell, and one in Georgic. Along both iines, one core was taken from the location closest to the trace of the fault and the others equally'spaiied north and south of the fault.
Eight holes were cored in Georgia, about one mile apart north-south, and four in S.C.
Visual examination, petrographic and mineralogic analyses identified distinctive marker beds.
One of these, the Blue Bluff mari, i
appeared consistently between 100'ft above sea level to 100 ft below, showing no change in elevation (other than that due to the gentle regional dip to the south) on either side of the postulated fa' ult in Georgia and South Carolina.
This indicates that no vertical offset and therefore no f
fault of the type postulated in the USGS open file report is present down to strata at least 40 my old at the inferred location of the postulated fault.
Furthermore, Core VSC-4, on strike with, and 200 ft. from, well AL66 in which the USGS interpreted Triassic rocks at an elevation of -600 ft, was the deepest hole in the study.
The core at -1000' was still in distinctive Cretaceous Tuscaloos'a sands.' The staff examined this core and agrees that it has none of the characteristics of Triassic rocks and looks much like other Cretaceous samples.
This result is in direct l
disagreement with the open-file report interpretation upon which the fault is postulated.
3.
Downhole geophysical logs, especially the gamma log, provided distinctive signatures that verified the petrographic identification of the ' strata, and in particular the Blue Bluff marl,. confirming the continuity of the unit across th,e inferred location of the Millett Fault.
l t
2.5.3.2.2.2 Seismic Reflection Study:
A nineteen mile acoustical seismic reflection survey was conducted in the Savannah River in the vicinity of the postulated Mille.tt Fault.
The survey used three different energy sources, Uniboom, 10 cubic inch air gun and 20 cubin inch air gun, to obtstn high resolution'and deep penetration of the sub-surface. formations.
The water depth in which the survey was carried out ranges'between l'0-25 feet.
.1 -.....
t 09/26/84, 2.5-15 V0GTLE SER INPUT SEC 2 5 r
m,.~
,cx._..,_-,
,,_wrmm
,,_,,mm-.__.-
~__-.w..
e
(
G The reflection survey identified several key horizons, A through I, at differ-ent depths ranging between +70 to -1150 f,eet.
Some of the horizons, such'as reflector E, which correlates with the' t'op of the limestone that is the lowest
~
unit in the Barnwell group, of late Eocene age (40 MPBP), and reflector G, which' represents the unconformable contact between the unnamed sands of the Middle Eocene Lisbon Formation and the top of the Paleocene kaolinitic clay (60 mybp) are well correlated with adjac'ent core holes.
Some of the reflectors are well defined while others are weakly defined.
Some of the horizons showed small features which may be indicetive of past channelization or buried karstic surfaces.
Th'e continuity of the reflectors above the Triassic / Cretaceous contact and the absence of noticeable displacement in the higher horizons above -500 feet elevation indicate the absence of faulting within the last 60 million years in the vicinity of the postulated Millett Fault.
This con-clusion is in agreement with that of the applicant's report, that no capable fault has been identified by the seismic reflection data obtained for this study.
In additien, seismic reflection data obtained by the applicant from the Savannah River Plant investigation of the deeper horizons in the vicinity of both plants suggest the possibility of a small normal offset of the Triassic / Cretaceous contact of 50-100 ft in the vicinity of the postulated fault.
No evidence, however, for offset in younger horizons can be detected.
2.5.3.2.2.3 Seismolocy Study:
The available seismicity information includes (1) felt earthquakes, (2) recent instrumentally located events, and (3) data from the Savannah River Plant array, just across the Savannah River from the Vogtle site.
The applicant concludes that histcric seismicity reveals no evidence of active faulting in the area.
JA.rW.d This conclusion is consistent with the data.
The seismicity ~ ~ the site has been scattered and low level (maximum MM i.ntensityT7 No Ilustering of earth-quakes is occurring near the postuli Millett or Statesboro Faults.
2.5.3.2.2.4 Hydrology Study:
' Faye and Prowell used, as part of their case, several hydrologic arguments to support the existence of the postulated fault.
These ' arguments were thoroughly 09/26/84 2.5-16 V0GTLE SER INPUT SEC 2.5 m
(
(
investigated in this study by the applicant.
The issues of different unit base flows in river reaches (generally above and below the postulated fault), water
(
well levels across the' postulated fault,'E d groundwater piezemetric surface contours were addressed by their study.
After carefully reviewing all the contractor's hydrologic evaluations, the staff concurs in their conclusion that the hydrologic data provide "no basis to support or preclude the existence of a i
fault."
2.5.3.2.2.5
==
Conclusions:==
On the basis of (1) the continuity of strata across the inferred location of the postulated Millett Fault as determined by (a) drill cores, (b) downhole geophysical logging and (c) seismic reflection profiles, (2) the absence of Triassic rocks at levels above -1000 ft, as shown by drill care VSC-4 on the south side of the postulated fault, (3) the' scattered and low level seismicity and (4) the hydrologic information which neither indicates nor disproves the presence of a fault, the applicant's report concludes that there is no evi-dance for the existence of a capable fault in the vicinity of the Vogtle plant.
The staff has carefully reviewed the report, has visited the site and examined the cores, the legs, and remote sensing imagery, and field checked the surface features.
The reviewers consider the applicant's conclusion to be consistent ~
with the data as reported, and conclude, therefore, that no capable fault as defined in Appendix A to 10 CFR Part 100 is present in the vicinity of the Vogtle plant, based on all presently available data.
Further support for this conclusion comes from Prowell's later (1983) report on Cretaceous and yoenger faults of eastern North America.
The Millett and Statesboro Faults are not included as documented faults.
It is concluded, therefore, that no surface faulting capable of localizing earthquakes is present at the plant site or iri the site vicinity.
~
M 4 4W g
l T.
- T
~~
09/26/84, 2.5-17 V0GTLE SER INPUT SEC 2 5 4
h (r
W 1
,+
l l
' (..
="
~
}
REFERENCES 4
Bolli'nger, % A., "Seismietty of the Southeastern United States," Bull. Seism.
4.
i Soc. Amer., v. 63, Oct.1973.
^
i
. Campbell, K. W. "A Ground Motion Model for the Central U.S. Based on Near-Source Acceleration Data," Prof. Conf. On Earthquakes and Earthquake Engineering, The l
Eastern U.S., v. 1, pp. 365-376, 1981.
Cook, F. A. et al.,1979, Thin-skinned tectonics in the crystalline Southern Appalachians, C0 CORP Seismic Profiling of the Blue Ridge and Piedmont, Geology, e
- v. 7, pp. 563-567.
~
i e
Faye, R. E. and Prowell, D. C.,19.82, Effects of Late Cretaceous and Cenozoic faulting _on the geology and' hydrology of the Coastal Plain near the Savannah River, Georgia and South Carolina:
U.S. Geological Survey Open-File Report 82-156, p. 73.
Georgia Power Company, Studies of Postulated Millett Fault, Vogtle Electric i
Generating Plant, October,1982.
i Heron, S. D., Jr., Judd, J. B., and Johns.on, H. S., Jr., Clastic Dikes Associated with. Soil Horizons in the North and South Carolina Coastal Plain," Geological l
Societ) of America Bulletin, v. 82. pp. 1801-1810, 1971.
L Iverson, W. P. and Smithso'n, S., 1983, Reprocessed C0 CORP Southern Appalachian i
reflection data:
Root zone to Coastal Plain, Geology, v. 11, p. 422-425.
Kafka, A. L., " Earthquake Hazard Studies in New York State and Adjacent Areas,"
Lamont-Doherty Geological Observatory of Columbia University, Palisades, t
N.Y., 1980.
I Marine, I. W. and Siple, G. E.,1974, Buried Triassic basin in the central L
Savannah River area, South Carolina and Georgia:
Geological Society of America l
Bulletin, v. 85, no. 2, pp. 311-320.-
l t
McDowell, R. C., and Houser, B.B., Map Showing Distribution of Small-Scale Deformation Structures in a part of the Upper Coastal Plain of South Carolina 1
and Adjacent Georgia," U.S. Geological Survey Miscellaneous Field Studies Map
[
MF-1538, 1983.
t i
Nuttli, 0. W., "The Mississippi Valley Earthquakes of 1811 and 1812.
-Intensities, Ground Motion and Magnitude," Bull.. Seism. Soc. Amer., v. 63, pp. 227-248," February 1973.
t i
.Nutt11, 0. W., R. Rodriguez, and R. B. Herrmann, " Strong Ground Motion Studies for South Carolina Earthquakes, NUREG/CR-3755, November 1983.
10/02/84 1
V0GTLE SER INPUT REFERENCES
c.
c-Nutt11, O. W., G. A. Bollin'ger, and D. W. Griffith,'"On the Relation Between Modified Mercalli Intensity and Body Wave Magnitude," Bull. Seism. Soc. Amer.,
{
- v. 69, 1979.
,,e Nutt11, O. W., R. Herrmann, " State of the Art for Assessing Earthquake Hazards-in the United States," U,.S. Army Corp of Engineers, WES Report #12, 1978.
Prowell, D. C.,1983, Index of faults of Cretaceous and Cenozoic age in the eastern United States,,U.S. Geological Survey Map MF-1269.
Secor, D. T.", " Geological Investigation a~t the Chem-Nuclear Waste Storage Site, Barnwell, South Carolina, February 24, 1980." Allied-General Nuclear Services.
Seeber, L. and Armburster, J. G.,1981, The 1886 Charleston, South Carolina carthquake and the Appalchian detachment, Journal of Geophysical Research,
- v. 86, no. 39, pp. 7874-7894.
Siple, G. E., " Geology and ground water of the Savannah River Plant and Vicinity, South Carolina," U.S. Geological Survey Water Supply Paper 1841, -
P. 57-60, 1967.
Stover, C. W., B. G. Reagor, and S. T. Algermissen, United States Earthquake Data File, U.S.G.S. Open-File Report 84-225, 1984.
Trifunac, M. D. and A. G. Brady, On the Correlation of Seismic Intensity Scales with the Peaks of Recorded Strong Ground Motion," Bull. Seism. Soc. Amer.,
- v. 65, 1975.
U.S. Nuclear Regulatory Comm.ission, Safety Evaluation Report, Alvin W. Vogtle Nuclear Plant Units 1, 2, 3, and 4, March 8, 1974; Supplement No. 1, May 1 1974.
USNRC, "Safeity Evaluation Report Virgil C. Summer Nuclear Plants," Docket No. 50-395, NUREG-0717, 1981.
USNRC, " Safety Evaluation Report Related to the Operation of Palo Verde Nuclear Generating Station, Unit No.
1," NUREG-0857, 1982.
USNRC, " Safety Evaluattor. Report,' Hope Creek Generating Station, Units 1 and 2," Docket Mcs. 50-354/355, NUREG-
, 1984.
USNRC, " Safety Evaluation Report Related to the Operation of Wolf Creek Generating Station, Unit No.
1," NUREG-0881, 1982.
Wheeler, R. L. and Bollinger, G. A., 1984, Seismicity and suspect'terranes in the southeastern United States Geology, v. 12, p. 323-326.
Williams, H. and Hatcher, R. D., Jr.,1982 Suspect terranes and accretionary history,of the Appalachian Orogen, Geology, v. 10, p. 530-536.
Zupan, A. J. W., and Abbott, W. H., " Clastic Dikes" Evidence fe-Post-Eocene
(?) Tectonics in the Upper Coastal Plain of South Carolina," South Carolina State Development Board, Divisjon of. Geology,~' vi 19,~pp. 14-23, 1975. ~ ~
,10/02/84, 2
V0GTLE SER INPUT REFER.ENCES
- - - - - - - - - - - - - - - - = = =
-l
}
~
~
l
('-
c.
APPENDIX A t
- Interim Position on Charleston Earthquake for Licensing proceedings The NRR Staff position with respect-to' the Intensity X 1886 Charleston earth-l quake has been that, in the context of the tectonic province approach used for licensing nuclear power plants, this, earthquake should bi restricted to th'e Charleston vicinity'. This position was based, in part, on information provided by the United States Geologic,al Survey (USGS) in a letter dated December 30, 1980 from J. E. Devine to R. E. Jackson (see, Summer Safety Evaluation Report).
The. USGS has been reassess %g its position'a'nd issued a clarification on s
November 18, 1982 in a letter from J. E. Devine to R. E. Jackson.
As a result of this letter, a p'reliminary evaluation and outline for NRC action was forwarded to the Commission in a memorandum from W. J. Dircks'en November 19, 1982.
The USGS letter states that:
.e "Because the geologi.e.and tectonic fe'atures of the Charleston region are similar to those in other regions of the eastern seaboard, we conclude that although there is no recent or historical evidence that other regions have uperienced strong earthquakes, the histor-ical record is not, of itself, sufficient _ grounds for ruling out the occurrence irqth'ese other iegions of strong seismic ground motions similar to thise experienced near Charleston in 1886.
Although the
', probability of. strong ground motion due tio an earthquake in any given year at a particular location in the usteen seaboard may be x
very low, deterministic and probabilistic evaluations of the seismic hazard should be made for individual sites in the eastern seaboard
~
to establish the seismic engineering' parameters for critical facilities."
.+
l
-The USGS. clarification represents not so much a new understanding but rather a
.more explicit recognition of existing unce'rtainties with respect to the causative structure and mechanism of the 1886 Charleston earthquake.
Many hypotheses have 09/26/84:
1 V0GTLE SER INPUT APP A 3.c.
y
(;
(.
been prop.osed as to the locale in the eastern seaboa'rd of future Charleston-size earthquake's.
Some of these could be very restrictive in location while others
-~
would allow this earthquake to recur"over very large areas.
Presently none' of
- these hypotheses are definitive and all contain a strong element of speculation.
We are addressing this uncertainty in both longer-term deterministic and shorter-i term probabilistic programs.
The deterministic studies, funded primarily by the Office of Research of the NRC should reduce 'the uncertainty by better identifying (1) the causal mechanism of the Charleston earthquake and'(2) the potential for the occurrence of large earthquakes throughout the eastern seaboard.
The probabi-listic studies, primarily that being conducted for NRC by Lawrence Livermore National Laboratory (LLNL) will take into account existing uncertainties.
They will have as their aim to determine differences, if any, between the probabi-lities of seismic ground motion exceeding design levels in the eastern seaboard (i.e. as affected by the USGS clarified position on the Charleston earthquake) and the probabilities of seismic ground motion exceeding design levels elsewhere in the' central and eastern U.S.
Any plants where the probabilities of exceeding design level ground motions are significantly higher than those calculated for other plants.in the Central and Eastern U.S. will be identified and evaluated for possible further engineering analysis.
Given the speculative nature of the hypotheses with respect to the recurrence of large Charleston-type earthcuakes as a result of our limited scien'tific knowledgeandthegeneralizedfewprobabilityassociatedwithsuchevents,we do not see a need for any action for specific sites at this time.
It is our position, -as it has been in the past, that facilities should be designed to withstand the recurrence of an earthquake the size of the 1886 earthquake in the vicinity of Charleston. At the conclusion of'the shorter-term probabi-listic program and during the longer-term deterministic studies, we will be assessing the need for a modified position,with respect to specific sites.
o O
me s er.
_...-~T.'_~
T _7 ' :. --.~ k. ' - ~ --
~ ~ - "-' ~
S M-
,,,09/26/84 i
2 V0GTLE SER INPUT APP A.
.