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N ,' s t May 20, 1982 MD40RANDlN FOR: D. Okrent, Chairman ACRS Subcor'unittee on Midland Plant Units 1 & 2 FROM: D. Fischer, Reactor Engineer
SUBJECT:
PROJECT STATUS REPORT FOR 'IEE ACRS SUBCmMI'1"rEE MEETING ON MIDLAND PLAMP LNITS 1 & 2 - JJNE 2,1982, WASHINGTON, D.C. Attached is a project status report for the subject meeting. We purpose of the meeting is to review the application of Constsaers Power Company for a license to operate the Midland Plant Units 1 & 2. We meeting will begin at 4:00 p.m. on June 2nd and will be held in Room
's. 1045 (tentative), at 1717 H St., N4., Washington, D.C. Attendance by the following ACRS menbers and consultants is anticipated and hotel reserva-tions have been made as indicated. If anyone is unable to make the meeting, 5 please call us or the hotel and cancel your reservations so that we are not billed.
D. Okrent Innbardy 6/1 W. Mathis Arny-Navy 6/1 D. Moeller Army-Navy 6/1 C. Siess Park Central 6/1 E. Epler Park Central S/2
- v. Lipinski Makes own
Attachment:
Project Status Report cc: ACRS Members R. Fraley M. Libarkin J. McKinley G. Quittschreiber
. E. Epler W. Lipinski
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i l 6 MIDLAND PUGTP LNITS 1 & 2 a OPERATING LICENSE REVIEW JUNE 2, 1982 PROJECT STATUS REPORT I PURPOSE: he purpose of this meeting is to review the application of Consumers Pbwer Company for a license to operate the Midland Plant Units 1 & 2. BACKGROUND: 4 Pertinent facts concerning the Midland Project are included in my May 17, 1982 project status report for the ACRS Subcommittee Meeting on Midland i Plant Units 1 & 2 - May 20-21, 1982. tat project status report contained: 1
. a description of the plant site
. a description of the plant
. comments on plant elevation and design water levels
. a status of the ACRS review
; . a list of open items and licensee conditions Attactrnents to the May 17th status report included:
- . a map of the Midland
- . a diagram at Midland's reactor coolant system
. a table comparing Midland features with those of Rancho Seco, Oconee, and Turkey Point
. past ACRS letters
. Staff response to cocenents made in past ACRS letters l
l . Dr. Siess' report of the Ad Hoc Subcomittee on fomdation i problems and remedial actions at Midland Plant Units 1 & 2
. Consultant reports
- Dr. R. Foster, Comments on Midland's IES and Dnergency Plan
- Mr. P. Davis, Evaluation of Aux. Feedwater Reliability at j
Midland
- Dr. P. Pomeroy, Comments on Midland Seismic Site Specific l
Response Spec +.ra
- Mr. J. Hickman, Coments on Midland's Aux. Feedwater Design Statement of Ms. Mary Sinclair l
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MIDIAND PLANT STATUS REPORT Copies of the status report for the May 20-21 Subcomittee Meeting are available upon request. OPEN ITEMS: We status of open items and licensing conditions has not changed since my last status report. As presented by the NRC Staff during the May 20-21 Subcomittee Meeting, these items are listed on Attachment 1 to this report. , MIDLAND PLANT SUBCOMMITTEE MEETINGS % REVIEW CONSUMERS OL APPLICATION On April 29, 1982 an ACRS Ad Hoc Subcommittee met to discuss the renedial actions for soils-related structural settlement problans at the Midland site. Of particular note in this report is the Ad Hoc Subcomittee's re-comnendation (accepted by the full ACRS during the May Full Comittee meeting) that the Midland Plant Subcommittee review:
- 1. We adequacy of the seismic input criteria and
- 2. We seismic Site Specific Response Spectra and its relation to the proposed permanent site dewatering as a means of re-ducing the probability of liquefaction due to an earthquake.
During the May 20-21 Midland Plant Subcommittee Meeting the following topics were discussed:
. We status of the NRC Staff's OL review
. We quality of design and construction
. Ibman factors review of the control room
. Alternative shutdown panel
. Instrumentation to detect inadequate core cooling
. E/DC system reliability
. Process steam
. Seismic issues (including seismic input criteria, seismic site specific resEense spectra, and liquefaction)
. Probabilistic risk assessment
. Auxiliary feedwater system reliability
. Utility organization, management, and training
. Dnergency operating procedures
. System high point vents
. Dnergency planning
. Radiation protection program
. Dwironmental issues at Midland
. Potential for ground water contamination
MID[AND PUWT STATUS REPORT Several items which were scheduled to be discussed during the May 20-21 I meeting were deferred until the June 2nd Subcommittee Meeting. %ese topics include:
. Items from previous ACRS letters
. Methods to reduce common cause failure
. Integrated control system Seismic and environmental qualification of equipnent important to plant safety
. IER system operation
. Bolting and other high strength material
. Fire protection
. Habitability Industrial Security will be discussed at the June 2nd Subcommittee Meeting since we have the facilities in Washington to hear this propriatary pre-sentation.
We tentative schedule for the June 2nd Subconmittee Meeting was issued on May 25,1982. ADDITIONAL INFORMATION FOR THE JUNE 2 SUBCOPMITTEE EETING he NRC Staff's Midland Plant Project Manager, Mr. Darl Hood, has compiled a list of ACRS concerns from past ACRS letters. his list, Attachnent 2, is complete and should obviate your review of chapte.r 19 in the OL SER. Mr. Hood references the section(s) of the OL SER which addresses each ACRS con-cern. For each concern, he summarizes:
. the ACRS concern
. the CP SER response to the ACRS c6ncern
. the OL SER section that relates to the ACRS concern Familiarity with Attachment 2 should allow us to move more quickly throtzjh ti.o "ITD4S FRO 4 PREVIOUS ACRS IETIERS" section of the June 2nd Subcommittee Meeting. <
ADDITIONAL INFORMATION FOR '1HE JUNE 4 FULL COPNITTEE EETIM Attached to this project status report is a menorandum from Mr. Hood to me dated April 7,1982 (Attachment 3) that discusses the Midland breakdown in quality assurance with respect to soils activities. We testimony filed June 6 1981 referred to in this menorandun is voluninous. If you Rather thantotransnit would like see allitorto you, I would like to tell you Wat is in it. part of this testimony, please let me know. We June 6th,1981 EC Staff testi-mony contains: e e
MID[AND PUMP STARIS REPORT 1. hstimony of Eugene J. Gallagher with respect Quality I Assurance Program Implementation Prior to December 6, 1979; Attached to Mr. Gallagher's testimony are those docments listed on Attachment 4. Se conclusion of his testimony states " h e quality assurance deficiencies related to soil construction activities under and aromd safety relates structures and systems arising from improper impleentation of the quality assurance program provide adequate bases to mdify the construction permits by suspending those soil con-struction activities."
- 2. mc Staff testimony of James G. Keppler with respect to the quality assurance implementation prior to December 6,1979; Significant attachments to this testimony incitzie:
f
- Midland Sumary Report - an overall assessnent of the Midland construction project to Feb. 15, 1979
- Midland Construction Status Report as of Oct.1,1979
- March 15, 1979; Sumary of Feb. 23, 1979 and March 5, 1979 meeting
- March 12, 1979; Midland Diesel Generator Building and Plant Area Fill
- 3. mc staff testimony with respect to quality assurance;
- 4. Testimony of Joseph D. Kane with
- respect to the quality assurance program implementation prior to December 6,1979;
- 5. Testimony of Darl S. Hood with respect to the quality assurance program impl e entation prior to December 6, 1979;
- 6. SC Staff testimony with respect to implenentation of quality assurance for soils work and remedial measures after December 6,1979; te testimony includes as an attachment major simnary findings in the areas of managenent effectiveness, piping and supports, QA/0C program assessment, civil (soils) activities, and electri-cal work.
e 5 .
MIDIAND PEANT STATUS REPORT 7. EC Staff testimony of Darl S. Hood, Jeffrey K. Kimball and I Eugene Gallagher on Stamiris contention 1;
- 8. WC Staff testimony of Darl Hood, Joseph Kane, Frank Rinaldi and Eugene Gallagher on Stamiris contention 2; and
- 9. mc Staff testimony with respect to intervenor Stamiris con-tention number 3.
I have extracted Ms. Stamiris' three contentions from the applicable testi-mony and have included them as Attachment 5. As a result of the above listed testimony the conclusions of Attachment 6 wete reached. Mr. Hood adequately stramarized these conclusions in his April 7th memo to me when he said "%e applicant subsequently agreed, by joint stipulation with the Staff, not to contest the Staff's findings that a OA breakdown in the soils area existed as of December 6,1979. %e stipulation went on to note that changes had been made to the organization and procedures, and that the Staff now finds these areas to be acceptable." I also have a copy of the ASIB's Findings of Fact and Conclusions of Iaw (dated December 30, 1981 and supplanent thereto dated March 26, 1982). %e supplement addresses the same subjects addressed in the original findings - quality assurance and management attitude. Specific subjects addressed in the supplement include (1) SALP (2) he MP(AD reorganization (3) Quality control inspector qualifications and (4) Audit Report F-77-32. %e con-clusions reached in the December 30, 1981 findings were not changed. (Attachment 7).
%e twa Systematic Assessment of Licensee Performance (SALP) reviews Wiich have been completed on Midland are attached (Attachment 8 and 9). Consumers has responded to the latter of these two reviews in a submittals dated May 17th 1982 (Attachment 10) . Attachment 11 is a Midland Project Quality Assurance Program update Executive Summary. If pu are interested in reviewing Midland's Quality Assurance Program in detail, a two voltane description of it is avail-able.
As a result of the most recent SALP report, Mr. Keppler (Region III Admin-istrator) is reevaluating the testimony he made to the ASIB. % is reevalu-ation will be completed in mid June. Selected I&E inspection reports are included as Attachment 12. e
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ACRS Items of November 18, 1976 Supplerental Midland Peport In a letter dated October 14, 1976, the Licensing Board for a Midland hearing which began on August 16, 1976, returned the original ACRS report of June 18, 1970 to the ACRS for clarification. The clarification sought by the Board was with reference to a paragraph on "other problems related to large water reactors" identified by the Regulatory Staff and the ACRS, and which the committee consi-I dered applicable to the Midland Plant. In response to the Board's recuest, the ACRS issued a " Supplemental Report on Midland Flant Units 1 and 2" dated Nevenber 18, 1976. In July 1977, the NRC Staff issaed Supplement 2 to the SER for the CP review (hereaf ter referred to as the CF-SER) to provide an updated status and identify resolutions of the eleven iters identified by the ACES reply. These items have also been addressed in the recent OL-SER as indexed in Chapter 19. A sum. mary of these OL- SER dis-cussions for the eleven items follows. ITEMS FRDM 11/18/76 ACRS SUPPLEMENTAL REPORT SEP REFERENCE 2.1 SEPA % TION OF FFOTECTION A'?D CONTROL EQUIPMENT 7.7.3, APP C (USI A-47) 2.2 VIBRATION A';D LOOSE-PARTS MONITORING 4.4.4.2 2.3 POTENTI AL FOR AXI AL ".ENON OSCILLATIONS 4.3.2.5 2.4 EEHAVIOP OF CORE-BARPIL CHECK VALVES IN NORMAL OFERATION 4.4.2.3, (2.4 of SUPP 2 to CP-SER) 2.5 FUEL-HA' IDLING ACCIDENT 15.5.6, 9.4.2 2.6 EFFECTS OF ELOXD3'/N FORCES ON COPI INTEPJ;ALS 3.9.2.3, 3.9.2.2 2.7 ASSURANCE THAT LOCA PILATED FUEL ROD FAILUPIS WILL NOT 4.2.3.3 INTEPJEPI WITH ECCS 2.8 EFFECT ON PRESSUPI VESSEL INTEGRITY OF ECCS INDUCED 5.3.5, THEPJ'.AL SHOCK APP C (USI A-11 t. 49) 2.9 ENVIRONMENTAL QUALIFICATION OF EQUIPMENT 3.11 2.10 INSTRUMENTATION TO FOLLOW THE COURSE OF AN ACCIDENT TABLE 1.1 6.2.8, 7.5, 11.5, 12.3 2 .1.' IMPROVED QA AND ISI FOR PRIMARY SYSTEM 5.2.4 1 l g g ,( s, ATTActMtNT 2.
2.1 SEF AWIO:. OF PRDTECTION AND CO:' TROL E2t'IPMENT Source: ACRS Feport on 3-Mile Island, January 17, 1968. . Concern centered around the applicant's proposed use of signals from protection instru.ents for control purposes. ACRS recommendd applicant explore poEsibility of naking safety instruments independent of control f unctions. L In Supplement 2 of the CP-SER, we noted that Consumers Power Co.?pany would follow IEEE-279 dated August 1968, and would develop detailed criteria and proced_res for the installation of the protection and emergency power system for 52F & NSSS secpes. These were subr.itted for staf f review and approval prior to installatien. In OL-SEF, Section 7. 7. 3, we note the analyses being performed by the applicant of contrcl systems that share a connen power source or common instrament line (ICS, evaporator steam denand development , NNI) to ass are that f ailure in these power sources or sensors will not result in conse-quences nore severe than those in Chapter 15. This is also associated with our review of RG 1.97. These analyses will be addressed in ar. SER Supplement. In OL-SER, Section 7.7.4, we discuss the applicant's response to IE Infor-nation Notice 79-22 (Sept. 79) which asked whether the harsh envi ronment from a high energy line break night cause control system ralf unctions and consequences more severe than Chapter 15 analyses. Our review of the appli-cant's evaluation accepts the finding that consequences beyond Chapter 15 analyses would not occur. In OL-SEE, Section 7.5.2, we address the applicant's response to IE Bulletin 79-27 which questions the adequacy of plant procedures for accomplishing shutdown upon loss of power to any electrical bus supplying power for instru-ments and controls. We note in Section 7.5.2 our acceptance of the appli-cant's evaluation finding that less of power to riny one of the buses would not prevent readca; and maintaining cold shutdown. Finally, this safety implication of control systems is discussed in Appendix C of OL-SER by USI-A-47. Midland, like other plants, will be subject to the ultimate resolution of this CSI. 3.2. VIERATION AND LOOSE FARTS MONITORING Source: ACRS Report on Palisades (1/27/70) ACRS recommended studies of reans of inservice monitoring for vibration or the presence of loose parts in the pressure vessel and other parts of the pr.~ mary system, and implementation of such means as found practical and appropriate. e(G.
In Section 4.4.4.2 of OL-SER, we note that the applicant has described the LPMS that will be used at Midland. We have evaluated the system to RG 1.133 - Revision 1 and compared it with procedures used on other plants and find it acceptable. Further review matters for this system will involve Tech. Specs. for the LCO and surveillance requirements, alarm settings , baseline data acquisi-tion, and assurance of obtaining quality data. The precritical vibration mcnitoring program for Midland is discussed in Section 3.9.22 of the OL-SFn. We have reviewed and accepted the program to g RG 1.20. The program recognizes Oconee Unit 1 tests as valid prototypes for the internals and recogaires Davis-besse Unit 1 as a limited valid prototype for the surveillance specinen holder tube design. 2.3 FOTENTI AL FOR AXI AL XENON OSCILLATIONS Source: ACRS Report on 3-Mile Island, January 17, 1968. Tnis iter references continuing studies on the possible use of part-length rods for stabilizing potential xenon oscillations. As noted in Section 4. 3. 2.5 of the OL-SER, this issue was resolved by start-up tests for the Oconee Unit I reactor. A diagonal (certination of axial and a:inathal oscillation was induced, and the reactor was monitored for 72 hcurs. The azinuthal corponent of the oscillation was damped, but the axial component was divergent. At Maout 70 hours into the transient, the part-length rods were used to suppress the axial imbalance, which was reduced to near zero where it was kept. 2.4 EEHA'.'IOR OF COFI-E ARFIL CHECK VALVES IN NOM %L OPERATION Source: ACR3 Feport en 3-Mile Island, January 17, 1908. The Committee regausted experimental verification that vibrations would not unseat these valver during normal operation. The concern was t... - there was a potential for these valves to open during normal operation allowir j exces-sive core bypass flow. Core bypass flo=* is discussed in 4.4.2.3 of OL-SER. Resolution of this item by tests on a previous operating plant is discussed in Section 2.4 of S upplement 2 to the CF-SER. 2.5 CONSE2UENCES Or FUEL HANDLIN3 ACCIDENTS Source Hutchinson Island, March 12, 1970 In this item, the Committee referred to the possibic need for a charcoal filtration nystem in the fuel handling building. The Midland spent fuel pool area ventilation system is dis:ussed in OL-SER Section 9.4.2. In the event of a radioactive release audi as f rom a f uel-handling accident, redundant radiation detectors in the exhaust duct isolate the normal ventilation syatem and automatically start the safety-related standby exhaust system. The standby exhaunt system consists of two 1004 l 3et(>
1 I capacity trains, each having an air filtration unit and an exhaust fan. The system rneets RG 1.13 and limits radioactive releases to acceptab?.e levels by air filtration and by maintaining a negative pressure in the area to limit exfiltration. Meets GDC 61. Also meets Position C2 of RG 1.52 and Positions C1 and C2 of RG 1.140. Radiological consequences of a fuel handling accident are discussed in OL-SER Section 15.5.6 and are well within guidelines values of 10 CFR 100. 2.6 EFFECTS OF BLOWDOWN FORCES ON CORE INTERNALS g Source: ACRS Report on 3-Mile Island, January 17, 1968. Comnittee recommended Staf f review the ef fects of blowdown forces on core internals and the development of appropriate load combinations and defoun- . ation limits. Section 3.9.2.3 of OL-SER discusses the applicant's analyses of the reactor internals and unbroken loops of the RCPB, including supports, for the com-bined ef fects of asym:netric loCA loads and the SSE. These analyses are presently underway and the results are to be presented to the Staff by April ! 1983. The applicant's analysis will utilize previous analyses for Davis-Besse 2 and 3 with appropriate adjustments. The Staf f has accepted the appli- l cant's approach and will report on the results in a supplement to the SER. l 2.7 ASSURA' ICE THAT LOCA RELATED FUEL ROD FAILURES WILL NJT INTERFERE WITH ECCS Source: ACRS Peport on 3-Mile Island, January 17, 1968. Tne Comnittee desired to emphasize the importance of work to assure that fuel rod f ailure f rom lOCAs will not af fect significantly the ability of ECCS to prevent clad snelting. This concern was resolved by the generic rulemaking hearing on acceptance crite ria for ECCS, which resulted in 10 CFR 50.46 and Appendix K to 10 CFR Part 10. 7 The n 2dels and evaluation of fuel clad ballooning and flow blockage are diset ssed in OL-SER Sections 4.2. 3. 3 (3) and 6.3.4 which indicates compliance I wich 10 CFR 50.46 and Appendix X, Part 50. 2.8 EFF1 ** ON PRESSUPI VESSEL INTEGRITY OF ECCS INDUCED THER'd>4 SHOCK j Source: Oconee, July 11, 1967 5 The Committee reconnended the Staff review analyses of possible effects upon ! pressare vessel integrity arising from therTnal shock induced by ECCS operation. { The Mae of pressurized thermal shock is discussed in OL-SER Section 5.3.5 I and Appendix C (USI A-49) . The potential for adverse etfacts increase with , time as ~ degradation of material properties accrue due to irradiation. The l US1-49 issue should be resolved for operating PWas within 4 calendar years. L The Staff believes that the Midland vessels will not be jeopardized by thermal shock for at least 4 calendar years. By that time guidelines from resolution of A-49 will be available for Midland. The Staf f's assessment for Midland has been made recognizing that for Midland Unit i the limiting reactor vessel l 6 d d
beltline material is circumferential weld (WF 70) between the upper and lower shell forgings. The rate of increase in RT for Midland was estimated using the methods of RG 1.99 , Fevision S 2.9 ENVIRONMENTAL QUALIFICATION OF EQUIPMENT Source: Palisades , January 27, 1970 The Committee recommended that attention be given to the long term ability of vital components, such as electrical equipment and cables, to withstand I the environnent of the containment a f te r a LOCA. The status of the Staf f's evaluation of the Midland program for environmental qualification of mechanical and electrical equipnent is discussed in OL-SER Section 3.11. As noted therein, the review is being performed using the guidance of NUREG-0588, " Interim Staf f Position on Environmental Qualification of Safety-Related Electrical Equipment". The review is continuing and upon completion will be addressed in a supplerent to the SER. The applicant pro-vided a revised subnittal on April 30, 1982. The Staf f anticipates an audit in mid-J une 1982. The seisric equiprent qualification program is addressed in OL-SER Section 3.10. As noted there, the review is continuing. The applicant's seismic report is to be submitted in July 1982 and an audit by our SQRT is r eheduled for September 1982. 2.10 INSTRUMENTATION TO FOLLOW THE COURSE OF AN ACCIDENT Source: Hutchinson Island, March 12, 1970 This item relates to the developnent of systems to control the buildup of hydrogen in the containnent, and of instrumentation to nor.itor the course of events in the event of a LOCA. Se etion 6.2.5 of the OL-SER discusses the Midland hydrogen recombiners and th? hydrogen monitoring system. The Staf f reviewed the design to GDC 41, 42, an 1 4 3 10 CTE 50.44: and PG 1.7, Revision 2 and found it to be acceptable. Th( design is also discussed in Appendix C (USI
- 18) of the OL-SER.
Sect'on 7.5 of the OL-SER discusses accident mor.itoring instruments. As listed in Table 1.1 of the OL-SER, the post TMI requirements include II.T.1
" Accident Monitoring Instrumentation" (Sections 6.2.8, 7.5, 11.5, and 12.3):
II.T.2 " Instrumentation for Detection of Inadequste Core Cooling"(Section 4.4.4.1); and II.T.3 "Instranentation for Monitoring Accident Conditions (FG 1.97, Rev. 2)" (Section 7.5. 3) . In OL-SER Section 7.5.4 the Staf f finds the information systers important to safety, including accident monitoring instrunentation are consistent with the plant safety analyses and show sub-stantial compliance with RG 1.97, Pev. 2. 2.11 IMPROVED QA_ AND ISI OF PRIMARY SYSTEM Source: Oconee July 11, 1967 The connittee emphasized the importance of QA in f abrication of the primary l system and inspection during service life. Code requiremonts were excoeded during the f abrication of the Mi'." t - d reactor
.9 4.
vessel by the perfornance of ultrasonic examinations of welds in addition to the code required radiography. Also, since originally initiating this concern at Oconee in 1967, compliance with new requirements of codes and Regulatory Guides have provided ir. proved quality assurance for the f abri-cation of the primary system. Since 1SS7, considerable improvements have been made in the preservice and inservice inspectien requirerents for the primary system. Examples include: A. Issuance of the AS!!E Section XI Code. E. Issuance of Apper. dix I to the AEME Section XI Code (this appendix improved and standardized vessel ultrasonic exaninations). C. Issuance of Appendix III to the ASME Section XI Code (this appendix improved and standardized piping ultrasonic exar.inations) . These requirenents have been (and are being) implerented daring the preservice inspection ot the Midland Plant. They also will be inplemented daring inservice inspections if they are not superseded by more effective requircrants. SEP sections which discuss this issue are: 5.2.1.1, 5.2.1.2, 5.2.3, 5.2.4 and 5.4.2.1.
\ . ,. Sandia National Laboratories
""*"""""'"""'c anos
- 4 May 7, 1982 1
i Professor David Okrent i University of California at i Los Angeles
! School of Engineering and I
! Applied Sciences j 5532 Boelter Hall 4 Los Angeles, California 90024
Dear Professor Okrent:
j In response 'to Mr. Fischer's letter (l) dated April 13, 1982, I j have briefly reviewed the studies and correspondence he supplied related to the Midland Plant Auxiliary Feedwater System (AFWS) design. There appears to be surprising similarity between the
- unavailabilitggscalculatedbythePickard,LoweandGarrick (PLEG) StudyL i using both ant-specific data and the NRC generic data (NUREG-0611).I The evaluation done by Roscoe (4 )
found no basis for suggesting different unavailabilities. Thus, there appears to be general agreement on what represents a reasonable estimate of the AFWS unavailability and thus appears j to be no great motivation for the ACRS to delve into this. j However, the NRC-Consumers Power correspondence (5,6,7,8) that '
; follows raises several questions that have broader implications i than just for Midland or just for AFWSs. They, in fact, raise ;
questions that will need to be addressed in a much broader context , as the safety goal is implemented. } Bas: j 10-0cally, to 10~gheAFWS Midland AFWS issue as I understand it, is that a unreliability criterion has been placed into f i the Standard The PL&G Study Review Planat(SRP) arrives subsequent an AFWS to ability unava:,1 the PL&G StudyM of 1.4x10 median (plant-spqcific data) or 2.0x10-0 mean (plant-specific data) or 1.2x10-* (NRC data). All of which slightly miss 'i the 10-9 criterion. From the NRC correspondence, it appears abundantly clear that they conclude that a third AFWS train (Midland has a two-train system) is needed to " bring the system ! 1 into an acceptable unreliability range (10-* to 10-3 per l demand).* ' Consumers Power appears to have several arguments (6) ; j -(1) The basis for the criterian is not provided. - (2) The' methodology for the calculation to determine compliance to the criterian is not provided. i (3) Consumers Power's calculations, because they are con-servative, reflect an adequate system. j (4) Their system is comparable to AFWSs of plants already judged acceptable. l l - . _ - 8'
- Professor David Okrent May 7, 1982 (5) They have alternate decay heat removal methods which, when considered, provide an overall decay heat removal capability that meets the SRP criterion.
(6) They are willing to make electric power and control : l system changes which should make the system acceptable. , (7) A third train requirement at this late date would impose a severe hardship. These appear to te issues that transcend the Midland AFWS question and suggest issues that will arise when implementing the quantita-tive guidelines of the safety goal. Among these are: (1) Do the quantitative guidelines reflect means, medians, percentiles , or what? (2) Does the method for doing the calculations need to be specified by NRC? (3) To what extent should NRC supplied generic data vs. plant-specific datt be used? (4) What does it mean if the quantitative guidelines are only missed by 20% when the uncertainties in the calculation are much larger. (5) Should quantitative guidelines be allocated down to the functional level and/or system level and put in the SRP? (6) When should an ALARA criterion be used? (7) Do the quantitative guidelines have to be met in specified ways (i.e., is a third AFW train the only acceptable way to meet 10-4)? All in all, these seem like important policy issues. Looking at them in some detail in the Midland AFWS context may provide some insights important to the broader question of safety goal implementation. l Sincerely, l Jack W. Hickman, Supervisor Nuclear Fuel Cycle Systems Safety Division 4412 Copy to: USNRC D. F. Fischer 4410 D. J. McCloskey
Attachment:
References
I References , (1) NRC letter from D. F. Fischer to P. R. Davis and J. W. Hickman, dated April 13, 1982, Midland Plant Auxiliary Feedwater System Reliability. , F (2) Midland Plant Auxiliary Feedwater System Reliablility Analysis, prepared for Consumers Power Company by Pickard, Lowe and Garrick, Inc. (PL&G). October 1980. (3) Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in Westinghouse-Designed Operations Plants, NUREG-0611, USNRC, January 1980. (4) Midland Plant Auxiliary Feedwater System Reliablility Analysis Evaluation, NUREG/CR-2368, SAND 81-2164, Sandia National Laboratories, B. J. Roscoe, August 1981. (5) NRC letter from R. Tedesco to J. Cook (CPC), dated October 22, 1981, re transmittal of Preliminary SER draft, Section 10.4.9, ,
" Auxiliary Feedwater System."
(6) CPC letter from J. Cook to R. Tedesco (NRR), dated November 12, 1981, re CPC response to open items of preliminary draft SER, Section 10.4.9. (7) Letter from CPC to H. Denton, dated March 1,1982, forwarding Babcock & Wilcox system analysis of loss of feedwater accident and PL&G auxiliary feedwater reliability. (8) NRC letter from R. Tedesco to J. Cook (CPC), dated March 26, lE82, re Midland Plant Auxilairy Feedwater System Design. I i
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. e Sandia National Lab 0ratories Albu ue. New Mexico 87185 May 7, 1982 g RECE'""'
Professor David Okrent IIG T .[.ad tR C. IU U U-University of California at Los Angeles School of Engineering and !'N " Applied Sciences AM . M! 5532 Boelter Hall 7 iS.9 M IIM.l E l t'i d biW Los Angeles, California 90024 A
Dear Professor Okrent:
In response to Mr. Fischer's letter (l) dated April 13, 1982, I have briefly reviewed the studies and correspondence he supplied related to the Midland Plant Auxiliary Feedwater System ( AFWS) design. There appears to be surprising similarity between the unavailabilitigs calcula ted by the Pickard , Lowe and Garrick (PL&G) Study (2i using both lant-specific data and the NRC generic data (NUREG-0611).( ) The evalua tion done by Roscoe (4 ) found no basis for suggesting different unavailabilities. Thus, there appears to be general agreement on what represents a reasonable estimate of the AFWS unavailability and thus appears to be no great motivation for the ACRS to delve into this. However, the NRC-Consumers Power correspondence (5,6,7,8) that follows raises several questions that have broader implications than just for Midland or just for AFWSs. They, in fact, raise questions that will need to be addressed in a much broader context as the safety goal is implemented. Basically, 10-4 to 10-5the Midland AFWS issue as I understand it, is that a AFWS unreliability criterion has been placed into the Standard Review Plan (SRP) subsequent to the PL&G Study. The PL&G Study arrives at an AFWS unavailability of 1.4x10-4 median (plant-spgcific data) or All2.0x10-4 mean (plant-specific (NRC data). of which slightly miss data)o{l.2x10-the 10- criterion. From the NRC correspondence, it appears abundantly clear that they conclude that a third AFWS train (Midland has a two-train system) in needed to " bring the system into an acceptable unreliability range (10-4 to 10-3 per demand)." Consumers Power appears to have several arguments (6): l (1) The basis for the criterian is not provided. 1 l (2) The methodology for the calculation to determine I compliance to the criterian is not provided, l l (3) Consumers Power's calculations, because they are con-servative, reflect an adequate system. (4) Their system is comparable to AFWSs of plants already hlddbOk , w
( . Professor David Okrent May 7, 1982 (5) They have alternate decay heat removal methods which, when considered, provide an overall decay heat removal capability that meets the SRP criterion. (6) They are willing to make electric power and control system changes which should make the system acceptable. (7) A third train requirement at this late date would impose a severe hardship. These appear to be issues that transcend the Midland AFWS question and suggest issues that will arise when implementing the quantita-tive guidelines of the safety goal. Among these are: (1) Do the quantitative guidelines reflect means, medians, percentiles, or what? (2) Does the method for doing the calculations need to be specified by NRC? (3) To what extent should NRC supplied generic data vs. plant-specific data be used? (4) What does it mean if the quantitative guidelines are only missed by 20% when the uncertainties in the calculation are much larger. (5) Should quantitative guidelines be allocated down to the functional level and/or system level and put in the SRP? ] (6) When should an ALARA criterion be used? (7) Do the quantitative guidelines have to be met in specified ways (i.e., is a third AFW train the only acceptable way to meet 10-4)? All in all, these seem like important policy issues. Looking at them in some detail in the Midland AFWS context may provide some insights important to the broader question of safety goal implementation. Sincerely, Jack W. Hickman, Supervisor Nuclear Fuel Cycle Systems Safety Division 4412 Copy to: USNRC D. F. Fischer 4410 D. J. McCloskey
Attachment:
References
r .
~
( ( t* References (1) NRC letter from D. F. Fischer to P. R. Davis and J. W. Hickman, dated April 13, 1982, Midland Plant Auxiliary Feedwater System Reliability. (2) Midland Plant Auxiliary Feedwater System Reliablility Analysis, prepared for Consumers Power Company by Pickard, Lowe and Garrick, Inc. (PL&G), October 1980. (3) Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in Westinghouse-Designed Operations Plants, NUREG-0611, USNRC, January 1980. (4) Midland Plant Auxiliary Feedwater System Reliablility Analysis Evaluation, NUREG/CR-2368, SAND 81-2164, Sandia National Laboratories , B. J. Roscoe, August 1981. (5) NRC letter from R. Tedesco to J. Cook (CPC), dated October 22, 1981, re transmittal of Preliminary SER draft, Section 10.4.9,
" Auxiliary Feedwater System."
(6) CPC letter from J. Cook to R. Tedesco (NRR), dated November 12, 1981, re CPC response to open items of preliminary draft SER, Section 10.4.9. (7) Letter from CPC to H. Denton, dated March 1, 1982, forwarding Babcock & Wilcox system analysis of loss of feedwater accident and PL&G auxiliary feedwater reliability. (8) NRC letter from R. Tedesco to J. Cook (CPC), dated March 26, 1982, re Midland Plant Auxilairy Feedwater System Design. i l
I h L ~2.b 5711 Summerset Drive Midland, MI 48640 gg December 14, 1982 p g c r- e v ~ n c '.C " nr n 1 prf;M$;,iuub.,lilI RE Dr. David Okrent, Professor Q{C21j982 School of Engineering and Applied Science pu f ., University of California <jgc,;gI;p,1g2g3:4.5,6 Los Angeles, CA g
Dear Dr. David Okrent:
Dave Fisher of the Washington ACHS offlee has told me that you wanted to be kept informed of developments at the Midland nuclear plant site. Since there have been significant developments that have occurred here in the past several months, I believe you should be apprised of them. On October 29, 1982, Mr. James Keppler, NFC director of Begion III, provided his latest testimony with respect to Ouality Assurance nt Midland. Mr. Keppler noted that he had given the \fidland UcensingBoard his assurance for' the licensee's OA program for remedial soils work and the remainder of construction in July,1981 However, in April,1982, he found that the licensee was rated Category III, the lowest acceptable rating given by the SALP review process. As a result of this rating, Mr. Keppler realized he had to alter his testimony of reasonable assurance for the Board. (The Category III rating was not mentioned by Mr. Margullo when he gave a report for Consumers Power Co. to the ACBS Com-mittee in Washington, D.C. on June 2,1982.) Mr. Ker pler's testimony refers to the assessment of several chief directors of inspection at Midland, C.E. Norelius and B. L. Spessard, as well as chief Resident Inspector, P. J. Cook. These attachments contained many negative findings along with specific reasons for them. These findings were covered in the local and area press. (Copies of some of the news stories are enclosed.) The negative SALP review also prompted Mr. Keppler to add more resources to overseeing Midland activities,and he created the Office of Special Cases (OSC) for NRC field activities at Midland (and Zimmer). This inspection team only recently completed a phase of their work. Their findings indicated serious problems over a wide range of activities. As a result, Consumers Power Co has decided to halt work on almost all safety-related wo rk. All the safety equipment will be removed from the two containment build-ings, the diesel generator building and the auxiliary building. Fverything is to be reinspected and reinstalled. (News accounts of this action are enclosed.) S/A-g5-6o2-
/1lN
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( I Page Two (
* . -Dr. David Okrent December 14, 1982 It is expected that this action may significantly delay the plants) completed construction.
This past week, the soil settlement hearings continued. They dealt primarily with the diesel generator building. Among the disclosures that were significant, was the fact that Dr. Peck, a Bechtel soll consultant, admitted under questioning i by Judge Bechhoefer that the surcharge program of the diesel generator building, which was undertaken after the building was under construction and with the lack of adequate soil compaction, was unprecedented at any other building site. Also, a major difference of opinion developed between NRC staff and consultants. Joseph Kane, NRC geotechnical specialist and,II.N. Singh, consultant for the NRC from the Army Corps of Engineers, did not agree with other NRC structural engineers or consultants on the manner in which the geotechnical data that was provided was used in constructing their model as to the structural integrity of the building. Although the soil settlement hearings which are in progress are supposed to be the route for determining the adequacy'of the remedial fixes that have been proposed, the NRC is allowing tunneling under the turbine building to begin December 13, 1982, before the outstanding OA issues have been heard, and before James Keppler has testified on his reasonable assurance to the Board. It appears that the NBC is separating the theoretical adequacy of the technical fixes from the practical adequacy of implementing the quality assurance. This has always been the problem at Tlidland and continues to be the most significant problem. It appears that the whole point of the hearings can, in effect, be overruled by the staff. If that is the case, the efficacy of nuclear licensing as it now is implemented must be questbned and the role of the Licensing Poard reviewed, in related local matters, the City Council of Saginaw (Saginaw is 15 miles downwind and downriver from the TIldland nuclear plants) has passed a resolution opposing the operation of the Midland nuclear plants. Tittabawassee Township has filed an appeal of the nuclear plant water permit because no further develop-ment could take place downriver from the nuclear plant. The Tittabawassee is a small river and The Dow Chemical Co. and the nuclear plants would use all the disposal capacity. Tittabawassee Township has just opened an industrial develop-ment park. Ingersoll Township which is next to the nuclear plbnts has also passed a resolution opposing the nuclear plants. The Midland County Commissioners also have deep concerns about the adequacy of the emergency evacuation procedures. (See news story.) We appreciate the continued interest of the ACBS in the Midland nuclear plant project. Yours sincerely, Mary Sinc . r cc: Senators Levin and Riegle, Congressmen Dona d Albasta and John Dingell, Dr. Henry Meyers, David Fisher
E' aa 9
..NRC gives examp es to back criticism 4 .
Related story, pag. 3
< Ry pat *L rat * ^ ^ the NRC, but on two occasion 3 Bechtel i
Dail) Newn stuff uriter Midiand iad>cated 't d>d a"t " eat to #- ihe ro,m. Cook said. in recently fled testimony, the U S. i Nuclear Regulatory Commisoion gave pgQg "The opimon of the stafTi., that if Cun. sumers generates a form that will and several examples to justify its harsh criticism of the Ahdland nuclear plant < g gg them in not meurrmg regulatory dafli. culty, and w hoch has had NRC mput, the project. For example. the NRC dennbd twa {J b - - - r
; hcensee should demand that the con-tractor comply with these puheies m3tead occurrances to back its claim that ">hp- EE Mumm ==7" smg of the contractor dictating the regulatory j shod workmanship" in toleratd at the environment under which they will g nuclear plant. work," Cook wrote.
i Electrical cables, partscularly m the He said Consumers protested that this Cook noted there u an obhgation to the a controt room.are at times allowed to dan- was not a valid finding of non- NRC to supply a prec 3e number of qual. AN EXA11PLE cited by the NRC of gle on the floor m ualk area- despite the conformance becau* plant quahty con- ified persons for the Ant work, and said Consumna " argumentative nature was fact the ends of the partially installed trol iQCl mspwtors had not yet inspected the information ultimately was obtamed the utihtya response to an NRC report cables are uncovered. wmor NRC redi. the anchors by appealmg to Consumers' upper man- called Systematic Assessment of Licen3ee dent inspector Ronald Cook said m an "The NRC mspectors treat this as in- agement. Performance ISALPs, which grades the attachmen'. to the NRC's untten te.. dicative that shpshod workmanship is *llowever, this indicates an imphed regulatory performance of utshties build-timony. tolerated m the hopes that QC will find unwillingness of the constructor ing nuclear plants. The testimony is to be uwd in an up. the mistaken, Cook wrote. The latest SALP said Consumers wa3 commg portion of the federal hearmg on (khtcl> to share mformation with the NRC and mometimes with the been ee weak in several areas. The utility re-the plant's soil problems. TO SUPPORT its claim that Bechtel (Consumersi." Cook wrote. sp nded with a rebuttal document at "This is also another indicator of shp. Power Corp., the plant's prime con. . "thstorically. one of the NRC questions least as long as the SALP report it. elf. shod workmanship which has been tractor. as uncooperative and seems to be . "The licensee s argumentatise position brought to the constructor's attention at rtinmng ihe project rather than Con- has been. Who is runnmg the y>b - Be- is in the form of'we really are not all that chtel or Consumers?.'" Cook said. addmg various times. but was last noted dunng a sumers, the NRC cited two more exam- that a second example *would allow one bad' when the records, findmgs and ob-recent inspection," Cook wrote. ples- to beheve it is Bahtel., senrations of the NRC inspectors support In the semnd example, Cook said NRC In one, Cook said, an NRC inspector Just the opposite position," Cook said. inspectors found that some drop.m an. askM Con <umers and Bechtel to provide The example involved a form that the chors used to attach components to con. resumes of workers mvolved in work to NRC insisted Consumers generate to ct,. ANOTi!ER PORTIONorthe teet hnony crete wall 3 were improperly m3talled and corrwt soil and foundation problema. The ordmate the mstallation of matruments wntten by two other NRC ofTicials said "obviousiv did not adhere to the m. mapector was told the records would not needW for the soil work. The form was
~ James W. Cook, the Consumers vice stallation procedures." be provided because they were personal. wntten by Consumers and approved by president in charge of the Slidland project, is an " extremely capable and dy-
, namic individual
- but that these attn-
-a .
butes may be causing confusion because Cook is too msolved m details of plant operations. Consumers has decimed comment on the NRC testimony, and said it wd! re-spond with sta own testimony dunng the soil heanng. But at a news conference Tueaday,
. Cook respondM to the testimony that ad-drewed him personally.
"A1y policy is to be mvolved to the ex-tent one person is able to be," Cook said.
He . aid such personal involvement by upper management ts essential to satas-factonly mmplete any nuclear project. Cook abo said there was "some con. fusion in the way that (NRC testimonyl was wntten." and that Consumers will attempt to clanfy the satuation in its tes-
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'. : By.D VID EVERETJ,&,; Cgyg power to the nuclear, reactors.
Consumers' primary construction firm at H ' Free Press stan Writer ..w. . . .
- we realize the layoffs are creating a hard.
' The inspectors' findings include: , j. _ Midland. t;. g n,, , gship for the. people involved,
- rThe'1,040 layoffs announced this week M * 'A larhe' backlog'of juality control aThe'in ."* c re-inspect!onwill mean' clearing a Cnnsumers Power Co.'s Midland Nucle-)t espections materialsja themost from dieselof thegenerator safetythe areas, building g spokesman standpoint of our commitmentMichael to build. K
. "i . . :s Consumers officials said. The re-lovestiga ping a plant that's going to be safely operat-f :-c]az yaerious Power ently by federal safety problems Inspectors, Plant were discovered officials said sparked re-(
- NobleNsby Yit] potential verifying Ehether , ' the' and other re9u e safety a al es areas.
g ad s M, we fed that we have taken the most
,, pr'oli er type'of steel was used in the build-ingJ
# N' * -
d@o M e pro I ms cNit rdin the plants > l_hld-4
, The Midland planIhas suffered major
' liidergency generator system, are serious
- Differences between construction in the TiiE PROBIBtS in the diesel generator - construction problems since work began in enough for Consumers to also order'at; building and construction drawings, building are serious, NRC spokesman Jan ;1969. Federal officials once described the g
! .I. ' reinspection of most nuclear safety work 1
- 1.ack of required separation between Project as one of the most troublesome in L Strasma said from the agency's Chicago l M at. the $3.39 billion project and to re s,, some electrical cables used for safety and office. '
the nation. ",_. 1 I'
, investigate most of its quality control per. other purposes. , ' :; , .
' "If you have problems like this in one ,;
'f ,-
; ; s6nnel, according to the U.S. Nuclear Regu. , Consumers' respons; r. discoveries
- f. The worst problem has b*en improper J e to the l
4(' { , Jalory Commission. y74 .
,g.y;l f.wasthelayof(s,plusplanstore-investigate ;
.; . . w , the quality control personnel and to re , similar area,you become concerned there might be ' soils foundation work. A federal licensing problems in other areas," he added.; : board is examining that prob 1 l '
, The Jackson-based utility, which sup- '
i a,;,,THENRCdiscovered the flawsin quall g nspect most of the safety-related work , p!!es electricity to most of outstate Michi involved
, cred inin 1978 when the sa i
ty control and equipment installation in done in 12 years of construction. L tor building the current contro- y l , October and November during an inspec-f,',,' . . The lald-off workers, including electri- , ' gan, deta!!ed a new team inspection and ^ versy was found to be settling into the i g tion'of the diesel generator building. The ' clans, pipefitters, ironworkers and labor- construction plan Friday as part of'Its. ground more than expected. response to the NRC allegations. - [ i3 generator is designed to supply emergency ers, are employed by Bechtel Power Corp., "Given the state's economic conditions, See A-PLANT, Page 9A I 4 " 7
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A-PL ANT, from Page 1 A The welding done by the worke'rs in P '
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Tile Pl. ANT is supposed to provide question will be checked, Koschik said. An electricity for the Consumers network and unrelated NRC investigation of Zack's j '(f y
- [I '
h}b P, 'M.,* . ', ,o steam for the massive Dow Chemical com- work at Midland is continuing.
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$ =) plex next to the site. Consumers officials This week's layoffs leave about 4,000
{ L 3 ** l 1 acknowledge that the 1983 and 1984 dead- workers at the Midland site. The NRC's L lines for each reactor to be operating may review of Consumers' plans to fix the soils h 8[l Ck l
, ! not be met. The project is 85 percent problems is delaying most work in that
. i ! complete.
I 'r !3 a ;'
- i. 1 I Consumers also announced th.is week it area of the plant, but non nuclear work is l h' '
DI'ODlelllS had to lay off 151 welders at the Midland proceeding. Also, the layoffs and inspec-1
, I tions are not expected to affect work on the plant because'h testing subcontractor had nuclear reactor and its steam system, the l ,n- I *
5 '
, , %. J.
l not properly verified their qualifications' NRC said.
) 1,epOI,ICO The welders, who work on heating, venti-lating and air conditioning for the Chicago- liearings into the soils problems resume
' ir 5 i' . based Zack Co., were not properly certified Monday in Midland. 0ther hearings will be
}
) ! 'I by the testing firm, Photon Testing Inc., the held on Consumers' request for a license to r > p . . .
- f : ga
. utiiitysaid. operate the et>nt-
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36 Pages
. Friday, December 3,1982 P r ~' Vol.125 No.183 l p..-- '
- ii 3B ,/, im +
4 ,,e, i. a;o . . l ; , , , Nucleareplant?,lsafetyl
, q< '-{9,.:- s; ?
3 ,e.,s f1-, , m . .ta n l reins ectioni,ordere.d s g ' g s I '. ! i l
- 7 .
. By PAULRAUk .' _ _ _
already installed, and the foreward look
? Daily News staffwriter is the formation of new construction
' {In a new plan to finish the Midland -
' teams to fimsh the plantswhich is now 85 percent complete.
' nuclear plant. Consumers Power Co. has . ' _
yD i The major objectives of the plan are to
; ordered a reinspection of' virtually all '1 safety-related work atthe plant. .
b G ,; __ 'i] provide more efficient control over the Construction work on most safety..
-- ,, plant's completion. and to irr. prove the
/ -
po.Lc. project's performance in meeting the reg. related aspects of the plant has halted - h ulations and expectations of the NEC, while the reinspection takes place lead. 5 e- according to plant site' manager Donald n
~
ing to the layofT of 1,G40 Bechtel Power Corp. workers this week. The safety- t *- B. Miller. .: i. =. 5 related work will resume when the rems- c c .n, . ,o,, _- i em o".s ,, To implement the plan', Mill'er said in a pection is complete. Consumers said.
- news release that it was necessary to re-
-' The new plan- desenbed to U S. Nuc. .
duce the manual workforce by more than lear Regulatory Commission staff t y Con. \'
' sumers Thursday - stemmed fmm a re- 1 TA 1.000 persons, leaving about 4.000 per.
't ' (
- m '"#
' a,ons at work on the Midland plant. As a cent NRC inspection of the plant's safety.
l related diesel generator buildmg. '"s'r*,Er7 result of the layofTs, the Bechtel work- { force was nearly halved Ir'om 2,200 to NRC Region til spokesman Jan Stras. 'u 1.200 workers. Bechtel is the plant's en-
, ma said the inspaction found that the as- /
built state of the diesel generator build-m sineer-architect and the prime con. A tractor; no. Consumers,.non-manual or
.j ing and its systems do not match con. subcontractor employees were let go, with
,' struction drawings; that questions were COOLING POND
the. exception of 151 Zack Co. welders. raised about the material. traceability of ;4 y i} structural steel used in the generator NUCLE AR l'LANT buildingsb who are expected to return to work.' where reinspection of safety related Both Consumers and the NRC agree
< N' buildtng, which is evidence of a Quality
,, Assurance problem: and that questions work wi!I take place are shaded.The ': ,the recent NRC inspection of the diesel 4
two rounded structures are the con.'l generator buildmg "mdirectly" led" to the N were raised about the separation of elec. tainment buildings. Hetween them is layofTs. tricalcable trays. Shafer said the NRC inspec' tion con.
' the ausiliary building. The diesel tirpaddition, Strasma said the inspec. generator building is the rectangular' > tinues and may not 'be, completed until
+ tion revealed a large hack-log of planti'. .>> year's end.
wide Quality Control (QC) inspections. area. * ' ' t i. - d i's .
' " ' " ' ' Another factor behind the layoffs is J ,
' Strasma said the most significant *
. annect of the inspection'was that we -
Tile--FIRST PHASE.o..f uthe
- ._ new system-_n that
__a athe
.. en,t.
._ u ire Bechtel&workforce was not u,,a,u,,,, _ , , , _ _
l
+few muc19 waming is enough?
EDITOR - wTE: This is the econd Tu o of t he te-t 4 i of three ar tr:ee- on an emergent > plan Ud V C '"I' ' *
- f" '
and warmns. ucm for the .ilidland nuc- A das. and F reer a-lear power mant. The third article will Midland " c=* rn "~ esplain the evocral rosernment's role in m hen diren3 around evaluatinac tne plan and the warning RUCICar plant m \an Bure
' 39 tem. heard properly on a plant , i was sery di,
! 14PAULRAF heard or l >hould o. t)anic Newntaff w riter ,atduf the Pahsade-How m:x : n.- enough when it come, to He raid he was tr warnma : r population around the Shd- the windown up a land nudar mant of an accident inwh. . . enough to we a -t i mg radtaur releax and ponibly esa. hear people.3 rdea . it mas tout h oll .-ome- NORM AN 8AA RI. ConeumerGpok.~ bemg able to hear cuation? thing man at the nuclear plant, said the in-And. at wrux pomt doe > the re>pon-:bi;. tie 3 aid additional u arning 3s3tems home memtors cost $300 each and that itv for bu.Tzm. in3talline and mamtain. might be funded b3 pubhc monev and mexpenoise weather momtor> cannot be in'g warm- n Aems dhitt from Consum. through utihty bill after Coneumer> has rehably adapted to a new function, as ers Powe- i to the communiue, that purchased the equipment. wantextr:urrotection$ Blackhurst envisions. He said Consumers supports the uw of M) Then,e mie6uons are now being grap ANOTHER STAUNCH ADVOCATE in-home momters in some locations, but iled wnfi_ ' Time answers aren t i;ntirely of in-home warmng deuces to comple- not for everyone in the 10 mile radius i deer yee. -tr.zt some firmly entrenched ment the strens is Shdland County com- around the nuclear plant. . l mestionnammis memg taken. missioner Charles E. Blackhurst, chair- "Oue requirement.is to meet the
- man of the county Law Enforcement entena to have a prompt pubhc notifka-AT LEmitf two officials, in addition to Committa. tion synsem. If ear aaren system meets I ltidland ihmty Emegency Services -I'm dead senous about this warning that artena, it's adeguate. There is not a Y i hneemr IK Machael Freer. beheve the system I think we ought to have the best requirement above and beyond that,"' #~
, 308 warmarena Cortsamers is buymg system there is. It botts down to one thmg Sean said. ' '
! yon't be ====y==1* by themselve, - the Madland County Board of Commis- Freer said it isn't clear yet whether m-
"Idamsm'sawmagh
- Freer seid samers is nepmsee foe the safety dthe herse pagers will be neteoury. "But we 1 i' the *1 think we need com- People dMidland Countyc . reserve the prerogative in Madland Coun-ammmmmmg anpability in the *Til fight 'em down to the last man to
- ty to emesed the federal cdesraa af tue} 3-1 e Sansk addttamos might ine14 pet this system. Consumers Power knows t hink it's iin ourestasumm* bent,%starents. . 2
- i pseem, im4mmmme unanitors to warn of ext. how I feel. How would 14mg.like it if we "Jf we feelit's -ry le se beyond a! $;
. r_ _ , as enhie television st, told W N==d County emergency ser- simp rarams p=== thumrwe'seipmagte{
vices director (Freert to stop working on dat,* Freer adM /qs g; ! o,, a ; 4-l as4.= mar M. Chatterton, Midland the plan? ran mas beyond that," Black-f%e sirens themseb4s have been. E
- mapervsmarand chairman of a hurst said, addrag be um't sure how much bought for 32 m21 hon by Consumers, #
. _ amp _to assist Freer, support the board would give such a me- wipchwill be repaid by all of rta electne % -
i da ademamensl1 hat all homes in the 10- 12ca. . , ,. custosners in Micitiman one t.he Midt.ru 1
, sdie h==ipamey Planning Zone iEPZ Blackhurst amid the utility's reaction to plant goes on-hne. "The impact on a bitt !
-. ~ A nih plant be equip- buymg in-home-slanna'.hr everyone in w She less than miniscule," Sean said. I pad with ahkurmimonitors that could be set the 10-mile EPZ Aas been "very mute,- "Peu're not going to notice those sarens on affby a acb signal from the plant. while Chatterton said. Consumers has your bill."
"We humveco fad a way toget maade the been "very cooperatave" and receptise to But the questaen ef awho would pay for ,
' imune an amern yespis." Shas*e.pton said. the iden while 's"achmg it with certain enhancements to the minn warning 333-Tiow'n the ttunnem pt input in.1
- ant to reservations.= tem remainsunanswered Freersaid.
" BARBARA HENTON, site emergency plan corrdmator at the nucinar plant, "rW WW 'em down to the last man to get this said Consumers i. fully committal to an etTective warning system. but indicated (wamimE) system. Consumers Power knows how I that if FEMA and the NRC find that the feel leur would thev like it if we told the Midland miren-PA system alone meeta the entena, -
3 Midland and surroundmg townships will Courity emergency services director to stop work- he on their own as far as buying additions to the o retem. -Anythmg that falls out-ing orr the plan? I,m not beyond that.,,- County -
,,ae w hat is neces,ary, that s optiondi.-
Commissioner Charles E. Blackhurst. M * "ea'* ** 'd She said Chatterton.a call for m home he Cenemmers supports the use of in-home moni- "o *'O,','f","y','t"",%'op ; t 12r0 Irt Some locations, but not for everyone in the how resident. feel about the siren w arn- All resident
, mg capabihtv. For them to go out and I,lanning Zone 10-mileradius around the nuclear plant. - Norman
~
purchase emethmg they don t know they nuclear plant ni Sacri, Consumers' spokesman at the nuclear d "7 ," uldi he le r ations abvut the de pl*gg siren. are based on one of three te.-to he overlapped by I at tended ufidentical % helen >) =tems l l l l l l
--- , --..----ay m-y.-_,.mg . . - - - -
r .. l Gh.? Who should pay?' Tw o of t he testa. iu Jack.-on County an'd Bay Counts, were cn clear. hot, summer others finally heard the 3iren at a di-My Tile 3!!DLAND PL\NT -iren -utem t.snce of 300 yardu the rated dierance is I w ill be improved. 31 lienton said, ba. ed dau and Frwr 3aii he was impre==d mile ' on c.inimenta from the diren testa for ex. I 11 - concern aro3e from the other te-t. In the other testo. Freer > aid he could ample. ,irens here will be rotated at slow-w hen airens atound the Pahsades nuclear hear both strene and voice me33 ages 13 er . peed 3 and w ill be stopped at eight pose-f plant in Van Buran County could not be milewamsy. beard properly on a sold. winter day. tnon-in3tead of four to allow better under-l He said the presence of wind and -ound- ,tandingofor.ilmes ages.
'I was sery diseppomted m what I deadening snow and the fact windows Frankiv. l think the problems encoun.
I heard or i 3hould s.av.didn't hear.~ Frwr were clowd against the cold reduced the tered on the day of the test at Palisades ! 3 aid of the Pah34de3-aren te3t. performance of the Pahsades 3trens "We won't be a problem in Shdland becau-e He.-and he was tr.selhng in a car w ith have just a few days hke that m 3hdland weie learned f rom the experiente." h l the windows up and approached clone County." Freer said facetiou31y. "The Henton said enough to w a seen rotating without problem l have i. what it we need to ac.ts-being able to bear t. Fresr 3 aid he and s ate the system and there is a bhuard." Continued on page J umummer Midlan'd Bay _ county county I p _ s. e A n s , ,3 l .
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- ...A. I Saginaw l county l All residents within this 10 mile Emergency Thomas, Tittabawassee and Kochville townships; Planning Zone Iw ithin circle) around the )!idland and 13ay County has a plan for residents in lleaver, nuclear plant must be notified within 4~2 minutes of Williams, Kawkawlin, Stonitor and Frankentust a plant acciden:. Emergency planning efforts also townships. Letters A through R within the circle are under way in Surinaw County for residents designate areas for planning purposes. (Graphic hy overlapped by the EPZ in Jonesfield, Richland, 311chigan State Police) i h
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8 ing devices. she agreed. 4' ' ' Continued frum ,%
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, mayed by the delay. " County government ,' *
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E. llenton noted there already aret' just moves slowly. It takes more commin-
"'She'said Consumers is counting on i plani to install additional warning re . sions and ' discussions'to' get something' ,
media to educate people how to hsten to j ceivern, which will carry tones and mes,r , accepted. Itlp;not hkera2 business ",she w ' the siren.PA units. > t sagesactivated by a radio signal.incritic ' ; said.
' t n * * '.??* ' t ' 'n - "3t t" .
"You have to wait until it rotates to .' al location 3 such as hoepital~, radio sta s ,, The sirens will be und to warn area-ward you to actually hear the men. age. It t tions, high-noise areas und for school su- .' citizens durmg a variety of emergencies, %'
will be un educational procens to get peo- perintendents. ' notjust during an accident at the nuclear , pie to etand rtill until they hear the mes- ' plant. As such. the emner they are instal. sage,"L. Henton naid. ' CONSUMERS Il0 PES to have the led the better. W. lienton said. - Spoken mer.uges would muy whether a siren 3 in-tailed by late January, when orill or actual emergency w as in progrew NHC officiala will visit, or earher. They I in the ca3e of the latter. rcoidents would ' were to have beer. matalled airlier, but , -;. * , ,g L
;e.
be udsi3ed to tune their radirus or televi . resersations from the Palisaden test , s* !.D f, sions to certa m stations for innt ruct nons. She said Con 3umers is considermg sur- ( cauaed the county to withhold ita approv. ., t al. Freer 3.nd . c'
' Q veying nearby residenta after a test of the 4
Midland sv-tem to see if it was heard. [ , L. lienton said Consumers is not dis- - m . . . '
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. Q Midland Daily News
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?" Tuesdey. November 9.1982.M.dlead. M.:h.g a 25c Per Copy Vet 125. Nos M2 20 yn (- l Tootimony says s ipshod workmanship to erated at n plant _ addataen to a mother prosect unpre- neceussey for Lakang the actaen. NRC'e standpnent. if they cencentrated es gpg g cedseted en tb auclear andustry - the fiams identafied problema rather tham j g,g adAtaen of new foundstaans below sev- OTHER POINT 8 6e the Nereheaf *rguing as to the vehdaty of the cit. l "Spahed workmanskap.a tenented at ,,.,. WlM eral entical buddmss to correct soit preh- Sprenard sneem atsons," they added. the $8Jud aucteer plant m the hopse thet guahty emment mapsetore will And
,, gy g,,e ,
o Censumers roepeness to Regnes III This undergianing project, the two enforcement lettere are " mere lengthy IN HIS MEMO. attachement B the i ^ - - mestabas tater. amedmg to .$.,. M. ' pl35tt NRC emesels wrote. is "probebly the and mere argn==an = rive" tham . . NRC's Ronald Ceek said Censuaners lwrenen testamany 6 lad recently by the ,Y'. egu valent of building a thre resetor frera any other liceense en the regnen. *umans to poemens the emique almidy to U 2L Nuclear Regulesary Comm- ,g, and. mans as fdhreplacing"a lot af whicle essere a desum s urteer umsta under anarch au rartaoms of the Nhc instal they N NRC amcmas ele enad that Cee. ,,,,,,,,,,c _ _
. a en eight biadwomane sesammL have fumand one that se _, ' -" to semere Power Co. te more arge* Nerettee ard Spenserd queettened __e psyneese regnames by C- to their point of view - mT _~ _ ef the emmesape" than any esiner wtsar etaldy do. ampmet es plant taaaynty wheehe, at to pramihen,as . "
m 9 ansm&
= meia =igbeen.g u m , , ,
esee ,,,,,m ,,m , ,a ,a beve the NR, C sever.e ,t, ,,,,,, ,,,,, , gn,e.n ,,,, ,eemmi .tu,e ,d.e, j .De utdaty womed be battay com" recommamend 'hmt Esppear ammmeur re- woman the NBC se he a pen of their eso. "The aheve mdacatans . the reym-respond to the NitC desmengtaw assedneE W emmainnemy itself wee favne- 9"*""EI"""" ** s to heat werb es eum structase pressem seeker than heems em tata-the lammes has hung,erge.
' ri oble as that it emmeluded that work sa ras g,"tammed musemer p6mma rather to en NBC eenersupr. r nuclear unn ohn'e amostratag ee me
- perimrmour urealsguintory W
- her eagerent meMay m C 4 *** 88 EI' *"7 8 '** the plant's sea problemas may ematanus
8"*8 abama spamme by mest Besadas,"but an alaaress t bacesse of issten NRC scrutiny ang other two preres a= the seele e Whee =%guemmapassedesseront accept se NBC pesetsen wetheep &
tho utmy anad e dulay of work and go' ting eee mes r selt smastnartaan = f fttung hematly esordnang to Sud a "amAmmar t'er ,.we,h hwey w.s be es.su ne m2. ether
*'s *ame sugeur sums at samme m=be r== mag C=m the
%' renamitments by Ceneumere -h- .
Thas resumendataan een est adspeed i.w a - umm-1 pastemi jah and amm useng'ay es_ e-ta=r=du quasmand emmeerenssene a =meenhomm heemmen a5 pmm> 88b " *"reben P m and bewevee's.that usaght em to she lesqu esthe af theesteeseen NRC tam > Asked esti be why the N weev Glad by Keppler. in-t othere were, daruaammte taded sandy to auptulp uty shut umm ma'aleed .* "g - d tammesy and mas ses arqaama moeurs. elong with Kapplur's tenaupeup. Pease show iny,e h a samnmuebeamr thmm la a het af *Indicatore af *
""'II"6 by 88 the8,'s'am*e NBC emad '7mit diartseure Thee are the farto Another undepted seemsnmendstaos e mese esepistejean mag m lammmme Parenrmaman,"Sumedshamb amit W ah* =en, , .g B,,ut,g NB,C,,assersey
, ,c,,,,,,,e ,,n Wdham e , ,,,. pesas that need.
e just the way it a Tha== unsee made by Neret un and ( l was that pesumet omrversave arth q weems at sheldtdiend p4mmeleme" hum. , ! Tun ash wnteen by four NRC tamsay was a httle snare adweee thea estet, they were relevant to the pre- C-- ,gare e outped massasemeses Nerebus and flpommesd she emed aged to penetrate" or drill dbmungh embatale, eestana emme of the NRC's they thought at would be It was met a Ing emedang. m they were N* "
- all sier moy9e eDedhertsw easmere is "bverty - -
- and ufety-related and non- " . header f
immmmme critamme of she bladland presort. pluny C _; Power dwhead comument Vice level"- that weiand lash gramasa about whether semushaug as am, ' eiertrualdurtbanha,e and gemende en itemanasses leek at the en the NRC sadamisey because it has m* .alety after th* esels and
. as semas of = . dra.a ham.am ah=h aswer les med a setetasmahip between Comeuniors, Be The NBC testassemy deels wah quahty yet been introduced et the esel hennag . ors =hele age esenting gre.p een- "Thus appmere a part to be due to thmer 72 mrh carnalatang water hae whale pse.
seems and the Esderal reguletary agency. - uGAI Programs at the Madland ,,ntret,d en bialdmg the remeters sementavity of what appears in the pubier formma the entrectave soil wert. . Attachmee t A by Morelles and record asemcnaltnestsef ses -
"All of thus occurrammes have hep-Per-e = Rahert n F Warnark.direc. auclear plant. and was filed in cen. and THE MEMOS BY Nerehus. Stemmerd Cook were sehcated by Keppier am en sp, e,d cells James W. Omsk, the Con- The aseadavity may have resulted freen pened because of a lack of centrol and
' tw af the NRC's Omre of Special Cape - . penstaan was.h the Anasmae Safety end la-s apenal enet set up en fanes em problems ansang Board beenns sate the plant's suempt te edeptify the fundasnental numere m prudent sa charge of Ge tM extended pebhe vis bahty wtush has attentaen te deteit." Ceek wrote.
'at the Cadland and F ramer nuclear soil probleem problems at the Midland con.trwetiae Midland prope= t. an *eataeansey empebas attended consensetaan of the fardsty sussentina ih t reviewo of the . ort pner The mest entacal portaans were sub- sete Keppler has amed he cannot undrr- and dynamic endavidual." But ut asys "The stafra verw as that the Meersed to drdhng were nns performed because pamens had the la eay abent Brehtet site would look bet.or freen the public deang me would ampact the constructaan ;-We are cenemced that Bechsel has cent snitted as awe attachawnia to the tee- stand why QA progrume are emplemen- the.e atenbute. may actually be caumens timony of NRC Region ill Admani.trato' ted poorly here beceu. e the pron;r am. , me et the ~r infu.aod' at the Midland .tandpomt and be snare defendable frera schstule Ceanumera as trymg to meet.
'! and artieduhar en their forems.a can. James keppler The attahrnrata 4.n= eaderstaan. Quality en teksag a buck-aret tarmacives are ahueta pron.ct l =sh - - - '. ;a1* 8. *ere ntien by =e Hegian lit d. rec- The nieme written bv %rchu, A Tbc NRC .n nal. id J.nw. Cook is t tore actively insolved m in3pi<tmg the sp,,,,rd sitates that the E11ered pr vst am muah muhrd" m decade of plant l THE CECENTLY maded te,timnny Midtand plant. C E %rchue and H l e, one of the m.. t coenpirs A ="m opi r ..nm .... . that therv ere teme= =hre ' appears to have .har ksd Con.umers into Spe=ard and hv the plant a sn.it NRL; pl.c,ted ever undertaken" en Hrrwa Ill h.. t.n ,% ,to he read, totake steun j regissutang e deley in .hr teme .stlotted to remedent mapects. Ronald J Cuuk becauer two reattors are bemg built in = hele t ..A see tenues to argue ehmat the I
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*' MmotTo'i UNIVERSITY OF SOUTHERN CALIFORNIA -
- (r % 1 LOs ANGELES, CALIFORNIA 90007 f f UNIVERSITY PARK *
& HEE Psb o M SCHOOL OF ENGINEERING DEPARTMENT OF CIVIL ENGINEERING June 21, 1982 Jeff Kimball Mail Stop P-514 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Jeff,
This is in response to your note of June 8 following our telephone conversation, but also will address the questions of Dave Okvent.
- 1. I should have started with 4 2 log 10U c = 1.1 - 1.0 m /per' year /per 10 km ,
b 3 2 I wanted to convert N to N, change m to MMI and use 10 km not 4 10 km2 ThereasonsforkhisarethatINaveprogramsandrisktables which are calibrated to these inputs for eastern U.S. In going over my notes, written at Midland, I discovered a mistake' Inadvertently, I appear to have started with log 10"c
= .1 - 1.0 m b '
Thus, it is not surprising that you and Dr. Holt could not duplicate my results. Please accept my sincere apologies. In as much as this must have created unnecessary work and problems, I am very sorry indeed. I am the one to blame. Going back to the 3 2 log 10 N c = 1.1 - 1.0 m /per year /per 10 km b With this, the exceedance probabilities for peak accelerations greater than .03 g are smaller than 5% for 50 years of exposure and the return periods are longer than 1000 years. Notice that I am not quoting the " actual" probabilities for this case now because I believe that the estimates derived from the tail ends of the distribution functions involved are not reliable.
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June 21, 1982 Page Two i Regarding Dr. Okvent's question: the return period is the estimate of any average time window during which at least one peak l acceleration will reach a chosen level. i Sincerely,
. 9 k6h
~ M.D. Trifunac
! MDT:mdm P.S. Would you please be so kind to forward a copy of this letter for Dr. Holt. I do not have his address.
I cc: Dr. Holt
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i t 9 i l t i i
fV 5711 St' merset Drive Midlan MI 48640 9(A4l May 28,1982
- ' ~DcP RECEIVED Dr. Paul G. Shewmon ADVISORY COW:i1EE O!!
Dept. of Metallurgical Engineering f.EACIORSAfECUVDS.tLSARC. , v 19th A e u JIJN u 1982 Columbus, Ohio 43210 AM FM gg [f g . 7 38,9,10111.%1 1 2i33 4,566
Dear Dr. Shewman:
1 On June 4, the full Committee of the Advisory Committee on Reactor Safeguards (ACRS) will meet to make its final safety review of the Midland nuclear plants. I would like to ask for time to make a statement at that meeting for Dr. Charles M. Anderson, a soils, foundation and structural engineering consultant and me. I have been involved in the licensing of these nuclear plants from the very beginning in 1968. Dr. Charles M. Anderson is our consultant and an expert on soils, foundation and structural engineering and seismic analysis. It is important for you to understand that at the ACRS subcommittee meeting in Midland, Michigan, May 20-21, our consultant, Dr. Anderson, met with unusual hostility on the part of Consumers Power Co. and was denied the kind of access to the plant that he needed as well as being denied the right to go on tour with the ACES subcommittee. While I realize that the ACRS review is not a part of the hearing process itself, it is nevertheless an integral and required part of the whole licensing process. I consider myself and my representatives a full party to that licens-ing process. I am enclosing a letter about these matters which I wrote to Senator Carl Levin. Senator Levin has become most concerned about Midland nuclear plant problems and has indicated his interest in an independent review of nuclear plants, of the kind that we were trying to arrange at Midland with Dr. Anderson, by drafting a billin the Senate to this effect. I believe you should be aware of these events. Po /A 4sw2. Many thanks for your attention to this matter. Yours sincerely,
- Mary Si lair MS/jt ,
cc: Mr. Ray F. Fraley, Exec. Dir., ACBS Senator C arl Levin j - C f l. M f Go
k ( EXCERPT FROM
, MINUTES OF 266TH ACRS MEETING JUNE 3-5,1982 II. Operating License Review of Midland Plant Units 1 and 2 (0 pen to Public)
[ Note: David C. Fischer was the Designated Federal Employee for this portion of the meeting.] [W. Kerr did not participate in the review of the Midland Plant.] A. Report of the ACRS Subcommittee D. Okrent reviewed tne history of the Midland license for the Committee He mentioned that the ACRS had done a particularly detailed review of Midland in 1969 and 1970 because the site was one that had a higher population density within three miles from the plant tt an did other proposed nuclear power stations. D. Okrent referred to a Comittee 4 letter dated November 18, 1976 which identified issues wnicn should be colsidered in the OL review (see Appendix IV). D. Okrent indicated that there are some special issues applicable to Midland. He called the Committee's attention to a history of quality control deficiencies at Midland during tne construction period, noting some problems with cadwelds, bolts, and soil settling, as well as cracking at the foundation of the diesel generator building. He suggested that the Committee pay special attention to specific issues that dealt witn the quality question. D. Okrent brought op a question concerning the seismic design rereviu, a question of liquefaction problems with soils under many of the safety related structures and a dewatering scheme beirg proposeo by the Applicant. Other topics men- ' tioned for discussion were questions regarding whether a nign point vent on the reactor vessel should be provided, whetner provisions snould be made for instrumentation to detect inadequate core cooling, wnether less than f avorable experience with nign strengtn bolts required an explanation. D. Okrent pointed out that there were no major issues regarding fire protection. He indicated that the Applicant is proposing an extensive program to evaluate systems interactions, similar to that being done at Indian point. Althougn tne integrated control system was modified somewnat to accommodate the process tertiary steam system he ! did not see a need for extensive Committee attention to tnese modifica-tions. D. Okrent did point out that the Committee snould decide whether to pursue tne issue of turbine missiles as a specific or generic issue with regard to Midland. i D. Okrent identified several otner potential issues whicn mignt be discussed as part of tne Comittee's Operating License Review (see Appendix IV): F0 / A - 8 s'-4 cL. B 73
I. k k MINUTES OF THE 266TH ACRS MEETING JUNE 3-5,1982
. High copper content in the welds of the Midland 1 reactor vessel
. The status of the ongoing probabilistic risk assessment at Midland
. Comitment by the Applicant to install a third auxiliary feedwater pump in the nonseismic, Category-1 turoine buildi ng
. B&W emergency operating procedures
. Industrial security
. Steam generator overfill protection.
C. P. Siess summarized the ad hoc Subcommittee meeting on Midland Foundation Problems and Remedial Actions which was held on April 29, 1982. The problem at Midland is inadequately compacted fill that is partly granular and partly - cohesive soils. He indicated that the consequence of this inadequate compaction was the differential settle-ment of certain safety related structures.. This produced some cracking in the walls of sone reinforced concrete structures. He indicated tnat the Subcomittee concluded, af ter presentations by the Staff and eneir consultants, that remedial measures Deing taken seemed appropriate to allay any particular concern about structural adequacy. He noted tnat the Subcomittee was satisfied with the dewatering system proposed by tne Applicant to eliminate the nazard of liquefaction. However, the question of the seismic input to the liquefaction analysis was still open since the Subcomittee nad not reviewed tne seismic design spec-trum during its meeting. B. Statement by Mary Sinclair Mary Sinclair, a citizen of Midland, Michigan, read a statement on the Midland Nuclear Plants (see Appendix V). M. Sinclair described tne environment in the immediate vicinity of tne Midland Plants, including the siting of an elementary school "imediately across the road from the Midland f acility." She explained that ner purpose was to present a public perception of the role of the Advisory Comittee on Reactor Safeguards. The theme of her statement was that the pub 1rc has lost confidence in the nuclear power plant licensing process.
, / j$Y y , . /-
J (. ( l l MINUTES OF THE 266TH ACRS MEETING JUNE 3-5, 1982 C. Status of the NRC Staff Review R. Hernan NRR Project Manager for Midland, reviewed the SER open items individually. (see Appendix VI). A list of special review areas was presented as areas of particular concern to the NRC Staff. J. Ebersole questioned how the Staff was evaluating the soils settlement issue. J. Kane NRC Staff, indicated that the problem had been evaluated by measured building settlement and by making borings in the in- pl ace fill material. R. Hernan indicated that the Staff had looked closely at the unique process steam system at the Midland plant witn regard to radiation mon-itoring in the case of a primary to secondary system leak. J. Ebersole pointed out that there is a vastly increased probability of secondary blowdown with such a system. B&W reactors are extremely sensitive to secondary system blowdown in view of the superheat design of the steam genera tors. He questioned whether the NRC Staff had looked into the combination of this increased probability of secondary blowdown in conjunction with a control system failure on feedwater overfilling the steam generator. This could result in an extremely rapid depressuriza-tion and tnermal shock to the Midland 1 reactor vessel which does have a high copper content. He suggested that there is an unusual potential for very large thermal transients in this system. R. L. Tedesco, NRC Staff, pointed to the safety grade overfill protection system and the fact that only one steam generator would blow down should an accident occur. J. Ebersole expressed concern about the assumptions in the NRC analysis. M. bender expressed concern regarding the NRC's collective judgment as to the quality of the Midland plant. He questioned wnetner there was an integrated, comprehensive report on the problems of quality at Midland plant. R. L. Tedesco indicated tnat the Staff did not plan to produce an integrated report on this subject. D. Okrent and R. Axtmann expressed concern about emergency preparedness and emergency planning at Midland. R. Axtmann inquired whether an emergency plan would be in place before startup. R. L. Tedesco indi-cated that a completed emergency plan might not be in place for low power operations, but that a tested plan must be available before the plant goes into full power operation. R. Mattson, NRC Staff, indicated that steam generators should be pro-tected against overfill from either the main or auxiliary feedwater systems. Equipment to provide this protection should be safety grade. 4 l l
,y)h" '
e ( ( MINUTES OF THE 266TH ACRS MEETING JUNE 3-5, 1982 D. Okrent noted that this issue is particularly important on B&W plants because of their control sensitivity and he questioned the lack of urgency expressed by the NRC Staff at issuing a backfit requirement for ' operating plants. D. Okrent requested a written response within the next month regarding the NRC Staff position with respect to the issue of feedwater overfill protection. J. Ebersole requested that the NRC Staff include in its report an analysis of the consequences of continu-ing to pump cold main feedwater into the steam generator in the event of a main steam line failure. This procedure can lead to a severe secondary transient leading to the pressurized thermal shock problem in the reactor pressure vessel. D. Quality control Issues W. Little, NRC Staf f, Region III, presented a tabulation of NRC criteria for assessing contruction QA/QC at nuclear power plants (see Appendix VIII). As a result of the Staff's Systematic As:essment of Licensee Performance (SALP) review of Midland, the Staff had identified six areas wnich it plans to f ollow in more detail than currently reqaired. M. Bender questioned how the Staff makes a final judgment regarding tne overall plant adequacy. W. Little suggested that the Staff nas to depend on its routine inspection program to assess the
.overall adequacy of plant construction.
J. Ebersole questioned how' extensive the Staff effort would have to be in order to assure against a total failure of flow of service water. J. Kane, NRC Staff, indicated that the Staff .has undertaken QA auait efforts sufficient to confirm loose fili, sof t clays under pipes, the measurement of settlements and stresses on pipes. Based on an evalua-tion of the remedial measures taken by the Applicant, the Staff is convinced that the problems that have been identified are being ade-quately addressed. D. Okrent requested an explanation of the six items that would require special quality assurance monitoring by the Staff. W. Little identi-fied these as follows:
. Remedial actions related to soils problems
. Piping systems and supports
. Electrical power and supply distribution
. Instrumentation and control
. Design control and the control of design changes
. Reporting requirements and corrective action.
s 7 b f
o [ ( ( . MINUTES OF THE 266TH ACRS MEETING JUNE 3-5, 1982 H. Bender suggested that the Staff prepare a comprehensive report identifying quality problems at the Midland site and containing an overall assessment of plant quality. R. Vollmer, NRC Staff, did not think the Staff would have any objection to preparing such a report. He indicated that, before this plant could be licensed, he expected Consumers Power to provide objective evidence that the plant had been designed and constructed in accordance with the application. M. Sender expressed concern that the construction problems found may suggest that greater care should have been taken during the construction phase. R. Vollmer thought that the audits the Staff is conducting regarding mechanical and structural details should provide sufficient assurance of the quality of construction. E. Consumers Power Presentation Regarding Quality Assurance D. W. Marguglio, Construction Quality Assurance Program Manager for Consumers Power Company (CPCo), described three major aspects of the quality assurance effort at the Midland site:
. NRC's increased Inspection Program
. External, independent audits and assessments by CPCo consultants (biennial audits)
. CPCo performed reinspections and rereviews.
The Committee discussed tne apparent buildup in the quality assurance organization and its relationship to the fill material and electrical equipment qualification issues. P. G. Shewmon questioned whether the independent audits being conducted by Consumers Power have uncovered anything in the six areas that the NRC inspection teams have been concentrating their efforts. D. Marguglio indicated that a recent review found the timeliness of quality assurance corrective actions to be quite satisfactory. J. Ebersole pointed out that numerous significant targets are in the direct path of potential turbine missiles. He questioned the position of the NRC Staff regarding the potential problem of both a turbine stop valve and control valve failure which could lead to turbine overspeed and disc failures. He mentioned attegts hv the Applicant to put two trip systems on a single 5et of valves as a solution to the problem. R. Klecker, NRC Division of Engineering, explained the NRC's turbine missile guidelines as shown in Standard Review Plan 111.5.1.3 (see Appendix X). He compared the Applicant's values for missile genera-tion, strike and damage probabilities with NRC's Stcndard Review Plan numbers. 6 , , 0
-- .__.2 - _~: . _ .
( ( l JUNE 3-5, 1982 MINUTES OF THE 266TH ACRS MEETING F. Seismic Review J. Kimball, NRR Staff Seismologist, explained the Staff's position on the Midland Plant. Two alternatives were given to the Applicant after the Applicant's analysis at the construction permit stage had been reviewed and found to require reanalysis. The Applicant decided to use the site specific spectrum to replace the 0.129 modified Housner spectrum which was the original Midland design spectrum. The Staff and Applicant agree that the 84th percentile in the Midland' site speci fic response spectra is a conservatve representation for the ground motion at the Midland site (see Appendix XI). L. Reiter, Section Leader for Seismology in the NRR Division of Engineering, made some general comments regarding probabilistic estimates for the safe shutdown earthquake. He noted that reliance upon probabilistic estimates for very long return period earthquakes is not the way to alleviate concerns regarding earthquakes greater than the sa fe shutdown earthquake. In answer to a ques:1on by D. Okrent, L. Reiter indicated that one possible way to alleviate some of these concerns would be to make a study of events, the probability of which is high enough to be accurately estimated by available proce-dures, in order to develop a base from which to extrapolate less likely events. G. Knighton, NRC Staff, indicated that simply raising the g value for the plant site would not give confidence fro.n the seismic i point of view, as would a closer look at the capacity of the equipment or the design of the equipment to withstand mJre severe shaking. The Committee discussed the design of structures at nuclear plants in general with regard to their ability to withstand a seismic event. R. Kennedy, President of Structural Mechanics Associates, consultant to i Consumers Power, briefly summarized the criteria for the seismic margin review at the Midland plant (see Appendix XI!!). R. Kennedy described i the screening process to select structural elements, components, and distribution systems for seismic safety margin evaluation, and pre-sented an example of analysis results for the borated water storage tank at Midland. There were no questions from the Committee. T. R. Thiruvengadam, Consumers Power Co., reviewed the soils explom-tion program at Midland with regard to liquefaction potenti'al and margins. He identified the diesel generating area, and the railroad bay area of the auxiliary building as the principal structures for which remedial measures against liquefaction were found necessary (see Appendix IX). He indicated that if these areas are dewatered and the ground water level is maintained at or below elevation 610, the struc-tures would be safe against liquefaction for earthquakes with peak ground accelerations of 0.199 He added that during normal operations of the dewatering system, the water level is maintained at elevation 595. l l 7
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~
l
[ ( ( MINUTES OF THE 266TH / ORS MEETING JUNE 3-5, 1982 T. R. Thiruvengadam inoicited that for an earthquake of magnitude 6 or 0.199 acceleration there is a factor of safety of 1.5 against the potential for liquefaction and for a 0.259 accelera, tion there is a factor of safety of 1.1 against the potential for liquefaction. In answer to a question by D. W. Moeller T. R. Thiruvengadam indicated that the safety factor of 1 would imply the onset of liquefaction. - D. Okrent summarized the various views of the ACRS consultants with respect to the seismic area. R. Holt, Western Geophysical Corp., consultant for Consumers Power, attempted to clarify and reconcile Midland numbers with the numbers estimated by Drs. Trifunac and Pomeroy, ACRS consultants. G. Inadequate Core Cooling Instrumentation and Reactor Vessel Head Vent i R. Mattson, NRC Staf f, indicated that a reactor vessel head vent will be requi red of the Applicant before 14 cc. msing. The Staff and the ' Applicant nave continued to discuss the core exit thermocouples as a means of detecting inadequate core croling. R. Mattson indicated that these thermocouples would be upgraced and operational prior to fuel load. He added that the hot-leg nonitoring system proposed by the ! Applicant is inadequate and has to be upgraded to include a vessel head tap. L. Gibson, Section Head for Safety and Analysis Consumers Power ! Co., presented Consumers Power's position with regard to venting their B&W designed reactor coolant system. He indicated that Consumers Power is in agreement with B&W, that the proper way to provide venting t for the B&W design is through the use of vents at the top of the hot t leg and tne top of the pressurizer. L. Gibson expressed Consumers Power's belief that a level indicator in the reactor head does not provide additional margin for the operator to respond to an inadequate core cooling event. He indicated that Midland procedures call for trip of the reactor coolant pumps on a loss of subcocling margin in order to avoid void formation in the pumps. D. Okrent noted that there was definitely a philosophical difference between the Staff and the Appli-cant. R. Mattson indicated that, regardless of the Committee's report. l the Staff was prepared to go to the Hearing Board with its current ; position. R. Mattson mentioned the Semiscale/M00-V whicn will model the B&W reactor system. The discussion involved recent TRAC calculations made by Los Alamos involving the ability to maintain single phase natural circulation cooling in the B&W design for certain small break LOCAs. He referred to a letter from the NRC Staff to H. Meyers of the Udall Comittee which expla*.s the Los Alamos calculations ; 8 I'J f : S , 1
r. ( ( JUNE 3-5, 1982 MINUTES OF THE 266TH ACRS MEETING (see Appendix XIV) and suggested that the TMI-2 Hearing Board might require additional information regarding this matter. In response to an inquiry by D. Okrent, R. Mattson indicated that this matter was an open or outstanding issue which will be addressed in a supplement to ) the SER. I H. Slager, Consumers Power, provided the summary of experience at the Midland plant regarding bolting. During routire testing ofThey reactor were l i vessel anchor bolts, several failed in a ductile manner. i j found to be much softer tnan anticipated because of improper heat treatment. Because of this experience Consumers Power Company initia-ted a hardness testing program for all special purpose bolts. H. Slager I noted that this is a QA problem which involved more than just record keeping. He indicated that the hardness test program was eventually extended to cover other bolts and similar problems were found with steam generator anchor bolts, reactor coolant snubber anchor bolts, and pipewhip restraint bolts (see Appendix I X.) . H. Slager indicated that Paladine Engineerirg Services was hired to perfonn an independent analysis of the Midland Reactor Vessel ancho'r bolts and found that the cracking mechanism was initial stress corrosion cracking followed by , complete failure due to the low fracture toughness. j H. Slager explained that in order to avoid further stress corrosion l cracking, Consumers decided to lower the prestress on the anchor bolts from 92 ksi to 6 ksi and add upper lateral supports to take up some of the potential seismic loads carried by the reactor vessel anchor l bolts in the original design. H. Etherington suggested that it is not good engineering practice to let the design load exceed the prestress load on these bolts. The prestress load should be at least equal to [ the design load. T. R. Thiruvengadam indicated that that was the l s original intent, but the lost stiffness was now being taken up through j the upper lateral supports. Chairman Shewmon inquired whether the Staff had made any progress evaluating the use of this ASTM specification that has resulted ) in the placement of unsatisfactory material at two plants 50 far. ' C. D. Sellers, NRC Staf f, indicated that the Staff does not have anything other than h technical assistance contract at Brookhave's that would address this matter. An NRC position addressing anchor bolt prel oad , material selection, hardness, inspection at receipt, and inspection in service would be formulated from the results of the i' Brookhaven contract. i i g2 : i
( ( MINUTES OF THE 266TH ACRS EETING JUNE 3-5, 1982 j J. J. Ray asked several questions pertaining to a.c./d.c. electrical i system reliability. B. Harshe, Consumers Power, answered these l questions as follows: l . Analysis for stability of the grid assumed a single failure such i as a breaker that did not operate, line problems coincident with the f ault sucn that there was stability long enough for backup , relaying or backup switching to take place. i I . With regard to d.c. supply, batteries are oversized and should i last for approximately 4 1/2 nours under full load conditions. > j . Load shedding analyses to verify extension of the 4 1/2 hour i battery lifetime in the event of a blackout have not been done , i yet. 1 j . All Consumers Power Nuclear Plants have top priority for restora-j tion of power in tne event of a blackout. -
. Consumers Power System has blackstart capability through the use j of the hydro facility at Leadington, diesel generators, and gas j turbines.
l
- C. Mark pointed out the unfavorable orientation of the plant turbines
} and questioned the NRC Staff's procedures for cetermining strike and damage probabilities. P. G. Shewmon asked the NRC Staff to explain their general approach with regard to the turbine missile strike , probability P 2, and the damage probability P3 . ! i
- D. W. Moeller questioned whether the Applicant had considered the Bullock Creek Elementary School in its emergency planning. W. Beckman, Consumers Power, indicated that there were actually two questions 9
involved, the first involving the status of the Emergency Plan and the
! second with respect to the elementary school. He first indicated that ,
the Midland County Emergency Plan has been reviewed by the State of ' Michiga n. He pointed out that the school lies in Midland County and , i has an evacuation plan using buses. Information in answer to addi-t tional questions by D. W. Moeller concerning emergency planning are as j follows: i . Saginaw and Bay County Emergency Plans will be submitted to FEMA . for review. ! f . The Dow Chemical Co. and Consumers Power have reciprocal agree-ments regarding an accident at the nuclear power plant with plans , for protecting the personnel and shutdown of certain facilities I in the 00W Plant. l 1 l @/ l l
( EXCERPT FROM ( MINUTES OF 266TH ACRS MEETING JUNE 3-5,1982 1 2 l
?
Oow Chemical personnel participated in an emergency drill at the nuclear power plant, but Midland plant personnel do not yet participate in drills at the chemical plant. i D. Okrent expressed concern regarding the question of small break LOCAs l and possible difficulties with natural circulation for 88W plants, and tne Midland plant in particular. He explained that fonnation of a l bubble at the top of the reactor coolant system hot leg would most certainly interfere witn natural circulation if the reactor coolant j i l pumps were tripped. He expressed displeasure with tne fact that this j item was not mentioned in the SER and that the Comittee was given He
- insufficient information to make a technical evaluation of it.
j suggested that he would be more comfortable if the Comittee did not go beyond a recommendation for 5% power operation prior to resolution of l this issue. i In answer to a question by C. Mark, T. J. Sullivan, Consumers Power, ; indicated tnat the subject of control room nabitaoility in tne event of In answer to i j i noxious gas release from Dow Chemical nad been addresseo. a question by J. Ebersole concerning tne competency of the diesel generator building to handle a transformer failure and consequent fire, fire i R. Burg, Bechtel Power Cerp. , indicated that they naa looked at the and also explosion with regard to the ciesel generators and tnat 4 diesel generators can be controlled remotely from the main control l panel for an inoefinite period of time. i 1 l
- I e
J i 4
e 4 RECEIVFD ADVISORY COMWTTEE ON M L AO INCOMPLETE TENTATIVE SCHEDum
, REACTOR SAFEGU.%DS, U.SXR.C. MIDLAND PLANT UNITS 1 & 2 i 266TH ACRS MEETING M i4 N JUNE 4, 1982 AM PM (8:30 A.M. - 12:30 P.M.)
7 38,9,101112,1 2 3 4.5,6 APPROXIMATE TIMEt SPEAKER I. INTRODUCTION 8:30 a.m. A. Subcommittee Chairman's Report D. Okrent 4 8:50 a.m. B. Comments by Members of the Public M. Sinclair 9:00 a.m. C. Status of the NRC Staff Review R. Hernan j 1. SER Open Items
- 2. Licensing conditions 9:10 a.m. D. Discussion [ ascertainment of Com-mittee preferences (from the topics listed in Item VI) for topics to be dis-
. cussed]
II. QUALITY CONTROL ISSUES (Does experience in Midland indicate the need for a broader review of the
,- ' Caality Control?)
9:30 a.m. A. Summary of NRC Experience and W. Little j NRC Staff Position
^
9:50 a.m. ,
. B. Applicant Response B. Marguglio 10:00 a.m. .- ', C. Diseussion 10:15 a.m. , ;.
BREAK ********* t _ III. SEISMIC 10:25 a.m. A. Staff Summary of Proposed Re- L Reiter/J. Kimball
} quirements and Probabilistic.
r stimates of Increased Sizes 10:35 a.m. '
- 2. Margin Study Results (including T R. Thiruvengadam
( , , Liquefaction) , 10:50 a.m. lb - - C. Discussion g#' I C'lV. INADEQUATE CORE COOLING INSTRUMENTATION AND HEAD VENT 11:05 a.m. A. Staff Position R. Mattson 11:10 a.m. B. Applicant Response L. Gibson
/
11:15 a.m. C. Discussion
},$c/lf /h h
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MIDLAND 6/4/82 APPROXIMATE TIME SPEAKER V. BOLTING EXPERIENCE H. Slager 11 :20 a.m. A. Summary by Applicant 11 :30 a.m. B. Discussion 11:35 a.m. VI. OTHER POSSIBLE TOPICS FOR DISCUSSION A. Fire Protection B. Systems Interaction C. Integrated Control System D. Turbine Missiles E. High Copper Vessel F. Process Steam G. ATWS H. AC/DC Systems Reliability I. Probabilistic Risk Assessment J. Auxiliary Feedwater System Reliability K. Organization, Kanagement, and Training L. Emergency Operating Procedures M. Industrial Security N. Items from Previous ACRS Letters
- 0. SG Overfill Protection P. Natural Circulation in the Event of a SBLOCA Q. Other i
(' i s MIDLAND PnTJJECT QUALITY ASSURANE PPISBffATION TO ACRS JUiE 4,1982 1 CONSlfES P0iER C0fPANY S W I'hRGUGLIO
.- ( i NRC INSECTIONS: o INCREAS:D IISPECTION PROGRN1 TEA'i IlGPECTION--F%Y,1981 RESIDEhT INS?ECTOR SINCE 1978
I
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l EXTERNAL AUDITS Ato Agggggrggg, t BIBiNIAL DJALITY ASSURANCE AUDIT-1976-NUCLEAR AUDIT & TESTING COPAt# BISNIAL DJALIT/ ASSURANCE AUDITS--1975 & 1980-- PANAGBEE A!!ALYSIS COMPANY SPECIAL DJALITY ASSESSTER--1981-MANAGSEE A!1ALYSIS COPANY PE-PZVIBl 0F SUPPLIER RADIOGRAPHIC FIlf4-- HARTFORD STEAM BOILER PPESERVICE INSPECTION AUDITS FUTUFE BIENNIAL DJALITY ASSURANCE AUDITS FbTUPE IN;0 ASSESSMBRS
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- 3. REINSECTIONS AfD P2-REVIEWS:
E-REVIB! 0F ENVIR0!(SiTAL AND SEISMIC DJALIFICATION TESTS t '. E-REVIEW OF FSAR t j P2-REVIB! 0F DOCLFBHS WHICH UiOFFICIALLY COULD HAVE ALTEED l DESIG!1 E0iJIR98HS i i i SPECIAL E-P2 VIEW FOR DESIGN SPECIFICITY AIO TOLERA!4CING 1 i i SEISMIC IMR31N ANALYSIS i COIRROL ROOM DESIG!1 E-REVIEW FOR HLf%N FACTOPS l ! SPECIAL DESIGN E-REVIEW BY BECHEL CORPORAE I E-EVIEW OF BECHTEL PROCUR&BU PAO'AGES i E-REVIEW 0F SLPPLIER QUALITY ECORDS (NSSS & AE) ! E-ASSESSFBIT OF LOW ALLOY, DJB1CED a TEPEED BOLTS-- l 7/8" & ABOVE I i
e ( ( l EINSPECTIONS AND PE-PEVI&S (corn'D): j SPECIAL OERINSPECTION OF SUPPLIED ELECTRICAL E0JIPENT FOR 1 I LORM1ANSHIP 100% E-EVID! 0F B&W FIELD-ORIGINATED RADIOGRAPHS i i SAPLING E-REVIEW OF BECHTEL FIELD-ORIGINATED RADIOGRAPHS
~
RE-PEVIEW OF CONSTRUCTION PROCEDURES i i ! PE-EVIEW OF OJALITY CONTROL INSTRUCTIONS 4 l 1
- 1 MIDLAND PROJECT DJALIT/ ASSURANCE DEPARTIST REIRSECTIONS l
1 l SECIAL CABLE INSTALLATION PEINSPECTION OVERVIEW OF BEChTEL SU? PLIER AUDITS f i l i I
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