ML20153G805
| ML20153G805 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/13/1986 |
| From: | Stevenson J CLEVELAND ELECTRIC ILLUMINATING CO., STEVENSON & ASSOCIATES |
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Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of
)
)
THE CLEVELAND ELECTRIC
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Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.
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50-441
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(Perry Nuclear Power Plant,
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Units 1 and 2)
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J AFFIDAVIT OF DR. JOHN D.
STEVENSON City of Washington
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as:
I, District of Columbia
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Dr. John D.
Stevenson, being duly sworn, deposes and says as follows:
1.
I, John D. Stevenson, am President of Stevenson & As-sociates (" SEA").
My business address is 9217 Midwest Avenue, Cleveland, Ohio 44125.
S&A, which I founded in 1981, special-izes in design analysis for extreme loads associated with earthquakes, tornados, and other phenomena resulting in high stress.
SEA has performed extreme load analysis for over 20 domestic and foreign nuclear power plants.
i 2.
A copy of my professional qualifications is attached hereto as Exhibit
'h."
As indicated therein, I hold a B.S. de-gree in Civil Engineering from Virginia Military Institute 8602280436 860225
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PDR ADOCK 05000440 i.
. Q PDR
(1954), and M.S.
(1962) and Ph.D (1968) Civil Engineering de-grees from Case Institute of Technology in Cleveland, Ohio.
I 4
am a member of numerous professional societies.
Among these, I am currently Chairman of the Executive Committee of the Techni-cal Council on Codes and Standards of the American Society of Civil Engineers ("ASCE"), which has over 5000 members.
In this position, I have the overall management responsibility for the development-of all ASCE codes and standards.
In addition, I cerve as Chairman of the ASCE Nuclear Standards Committee, which develops all ASCE nuclear standards.
In this position, I had overall responsibility for the development of American Na-tional Standards Institute Standard N-725 (Design and Analysis of Earth Structures In Nuclear Service).
The Committee is cur-rently developing a standard for seismic design and analysis of nuclear safety class structures.
3.
In addition to these affiliations, I am currently U.S. representative to International Atomic Energy Agency and International Standards Committee working groups, which have developed international seismic design standards for nuclear power plant facilities.
4.
As indicated in Exhibit A hereto, I have authored nu-merous publications on the subject of seismic design and analy-sis.
These include a number of recent papers discussing geismic design and analysis of nuclear power plant structures and equipment.
I have recently served as a consultant to the U.S. Nuclear Regulatory Commission, in development of a.
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comprehensive report on seismic design of nuclear power plant piping.
5.
Following the January 31, 1986 earthquake that oc-curred in the vicinity of the Perry Nuclear Power Plant, I was esked by the Cleveland Electric Illuminating Company ("CEI") to analyze the data provided by seismic recorders installed at various locations in the Perry plant, and to determine:
(1) how the earthquake parameters,.as recorded by the instrumen-tation at the site, compare to those for the Safe Shutdown Earthquake (SSE) and Operating Basis Earthquake (OBE) postu-lated in the design of the Perry plant's buildings, systems and components; (2) the structural significance of the readings by the seismic recorders at the Perry site during the January 31, 1986 earthquake; and (3) the anticipated impact of the earth-quake on the plant's buildings, systems and components.
i 6.
After a physical walkdown of the site, analysis of data recorded by the seismic instrumentation, and discussions with plant technical and operating personnel, I prepared a re-port of my conclusions regarding the earthquake and its signif-icance for the Perry Plant.
A copy of my report ("A Prelimi-nary Evaluation of the Significance of the Seismic Event on January 31, 1986," dated February 10, 1986), is attached hereto as Exhibit "B."
7.
As set forth in Exhibit B, the zero period accelera-tions (ZPA's) recorded during the earthquake in some cases ex-ceeded the design basis ZPA's.
However, if the appropriate
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i cdjustment is made to take into account the short duration and, low energy of the seismic event, the average elastic response ZPA's are less than SSE ZPA's in all cases, and with one excep-tion equal to or less than one-third of OBE design values (and approximately equal to OBE values in the remaining case).
The exceedences are therefore not significant from an engineering
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standpoint.
No damage to safety-related structures, systems and equipment would have been expected from the 1986 earthquake and none has been found.
I conclude, therefore, that the 1986 carthquake does not call into question the adequacy of the ceismic design of the Perry plant.
8.
The information and conclusions set forth in this Af-fidavit'and in the accompanying Exhibits is true and correct to the best of my knowledge and belief.
5n D.
Stevenson Subscribed and sworn to before me this 18D day of February, 1986.
W tr)
G Notarf Public My Commission Expires:
4 c ommmassa mage s aneg 4,, o w
EXHIBIT "A"
JOHN 0. STEVENSON 4
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EXPERIENCE:
PRES!0ENT. MANAGING Since November 1981. Dr. Stevenson has managed and Ig PARTNER has served as Pr%sident and Senior Consultant to l
Stevenson & Associates. The firm specializes in high technology consulting and forensic engineering associated with failure analysis of structural and I
r.achanical systems; extreme loads; and nonlinear, dynamic, and probabilistic high temperature analyses, VICE-PRESIDENT -
As Vice-President. Dr. Stevenson managed and served
'i GENERAt. MANAGER as Senior Engineering Consultant to the Cleveland 1976 - 1981 Offices of Woodward-Clyde Consultants and Structural Mechanics Associates specializing in areas of high l
technology applicable to the structural-mechanical design and analysis of systems and components. Prior to'this time, the consulting group he headed provided similar services as a 01 vision of Davy-McKee Co.
Dr. Stevenson also served as Corporate Manager of Engineering Quality Assurance for Davy-McKee Co.
ASSOCIATE PROFESSOR Case Western Reserve University. CWRU, and EDAC. Inc..
ANO. PRINCIPAt.
Cleveland. Ohio.
MANAGER OF EASTERN I
As an Associate Professor at CWRU, Dr. Stevenson served OPERATIONS 1974 - 1976 as 01 rector of a program in Design for the Extreme t.oad Environment and held a joint appointment in the i
Departments of Civil Engineering and Mechanical Design. He also conducted a number of seminars on Seismic Quality Assurance Scheduling and Manpower 1
Requirements and Mechcnical and Electrical Equipment Pipe and Duct Design of Industrial Factitties.
Dr. Stevenson was a Principal and managed one of three consulting offices for Engineering Dectston Analysis Corp., Palo Alto California. He was active in marketing and providing consulting services in the area of extreme load, seismic, tornado, high energy systems rupture. and component failure analysis.
CONSUt. TANT Westinghouse Nuclear Energy Systems.
1973 - 1974 Pittsburgh, Pennsylvania.
As a Consulting Engineer for Westinghouse Nuclear Energy Systems. Dr. Stevenson acted as an advisor to I
the Technical Otrector on the Executive Vice-President for Nuclear Power Staff. He performed evaluations of balance of plant requirements associated with nuclear power plant design and constructed and represented 1
Westinghouse on a number of Industry Comittees associated with nuclear power.
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CONSULTANT Westinghouse Water Reactor Divisions.
1972 1973 Pittsburgh. Pennsylvania.
As an Advisory Engineer for the Westinghouse Standard Plant Project. Dr. Stevenson acted as a consultant to the Manager of the Westinghouse Standard Plant Project. In 'this capacity he had responsibility for determining interface requirements with site-related design parameters and set envelope requirements for the standard plant design. He was responsible for I
nuclear island PSAE text developments and AEC licensing requirements associated with the standard plant layout development.
ADJUNCT PROFESSOR University of Pittsburgh and NSSA Inc.,
AND PRESIDENT Pittsburgh, Pennsylvania.
1970 - 1972 As a member of the Civil Engineering Facility of the University of Pittsburgh. Dr. Stevenson.was particularly active in the areas of structural dynamic response to earthquake, tornado, missile and fluid jet effects as well as reliability and risk analysis and optimum design of structural systems.
Dr. Stevenson I
was responsible for the development of a graduate study program for the study of structural design and analysis for the extreme load environment.
Dr. Stevenson founded and served as President and Managing 01 rector of Nuclear Structural Systems Associates. Inc. During this period, the firm served as consultants to the nuclear power industry, particularly in the areas of structural and mechanical design and licensing of nuclear plant fac1111 ties.
1 Dr. Stevenson was active in developing 512.idard Plant design concepts and also conducted engineering design seminars for the nuclear industry throughout the U.S.,
lI Europe and Japan for over 500 representatives of over 150 compantes.
MANAGER STRUCTURAL Westinghouse PWR Systems Otvision, SYSTEM ENGINEERING Pittsburgh, Pennsylvania.
1968 - 1970 Or. Stevenson had overall responsibility within E
kastinghouse for the development and approval of structural design criteria and layout used in the design of the six nuclear power stations for which Westinghouse had prime design and construction responsibility for product line management of design l
and development of support structures for major I
nuclear components.
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er LEAD ENGINEER Westinghouse PWR Systems Division, 1966 1968 Pittsburgh, Pennsylvania.
As Lead Engineer, Dr. Stevenson was responsible for liaison with the various architect-engineer-constructor firms whicti performed the detailed structural design and construction of turnkey plants, and as such he was responsible for design review and approval.
Dr. Stevenson was active in representing Westinghouse structu'ral design policy before the Atomic Energy Commission and Advisory Connittee.on Reactor Safeguards.
GRA00 ATE STUDENT Case Institute of Technology, Cleveland, Ohio.
1963 - 1966 Work toward a Ph.D. in Structures with emphasis on computer applications and risk analysis applied to structural design.
RESEARCH ENGINEER I.I.T. Research Institute, Chicago, Illinois.
1962 - 1963 Responsibilities included integrated radiation.
structural and operational analysis and minimum cost design of nuclear blast resistant underground structures.
ASSISTANT PROFESSOR virginia Military Institute,t.exington, Virginia.
1957 - 1962 Courses in structural design of concrete and steel structitres were taught to Civil Engineering
, undergraduates.
John Hopkins University, Baltimore, Maryland (Part-Time) Research Assistant.
Responsibilities included report editing and research in the location, type quantity and packaging of low level solid atomic wastes.
l 73 FIELO ENGINEER McDowell Construction Co., Cleveland, Ohio Q
1956 - 1957 Field Engineer responsible for Technical Supervision and engineering field modifications to construction of a Sintering Plant for U.S. Steel Corp. Youngstown Works.
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I Dr. Stevenson has been particularly active in the review and evaluation of d; sign adequacy of structures and equipment in nuclear power plan industrial facilities.
evaluations include the following:
y Muclear Power. Plants:
I Indian Point Units 2 & 3 H.B. Robinson R.E. Ginna I
Point Beach Dresden 2 Monticello I
- 0. C. Cook Palisades Oyster Creek Millstone I
South Texas Project Fessenheim - France Cordoba Argentina I
Mihama - Japan Conn. Yankee Maine Yankee I
Midland s
Other Industrial Facilities:
Tokamac Fusion Test Facility a
Purex Facility Hanford i
Rocky Flats Processing Facility Centrifuge Plant Granger Soda Ash Plant y
LMFBR l
Hercules Polypropalene Plant Shuichang Steel Complex Touss 0.11 Fired Power Station I
Hanford Coal Fired Power Station Addy Ferro Silicate Plant Killen Coal Fired Power Station LNG Storage Facilities - U.S.
B.S. - Civil Engineering -
EDUCATION:
Virginia Military Institute, 1954 AEC Institute on Nuclear Engineering -
f Purdue University, Summer 1960 M.S. - Civil Engineering -
Case Institute of Technology, 1962 1
Ph.D. - Civil Engineering -
Case Institute of Technology, 1968 l
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PROFESS 10hAL:
1.
Member:
American Society of Civil Engineers Chairman:
Executive Comittee Technical Council Codes And Standards Chairman:
Nuclear Standards Comittee Member:
Structural Division Comittee on Nuclear
. Safety Structural Division Comittee on Nuclear Member:
Structures and Materials 2.
Member:
American Concrete Institute E
Joint ACI-ASME Subgroup on Design.of Member:
Concrete Components in Nuclear Service, ASME 8PVC-Section III-Oiv. 2, Corresponding Consultant ACI 349 Safety Class Concrete Structures 3.
Member:
American Society of Mechanical Engineers Member:
Subgroup on Design of ASME 8PVC-Section III-Div. 1 Nuclear Conconente Subcomittee on Qualification of Mechanical Member:
Components in Nuclear Service Nuclear Standards Management Board of ANSI 4.
Member:
5 representing ASCE U.S. Respresentative International Standards 5.
Member:
Comittee SC 85/3/7 on Seismic Criteria for Nuclear Plants 6.
Member:
U.S. Representative International Atomic 5
Energy Agency Working Group on the Development of Seismic Design Standards
- 7. Vice Chairman: ANS-2, American Nuclear Society Comittee on Site Evaluation NUPPSCO, American Nuclear Society Comittee Member:
on Nuclear Power Plant Codes and Standards 8.
Member:
AISC, American Institute of Steel Construction Comittee on Specifications for j
Structural Steel in Safety Class Nuclear 4
Structures Earthquake Engineering Research Institute 9.
Member:
- 10. Register Professional Engineer: Virginia, Pennsylvania, and Ohio
- 11. Winner:
Moiselff Award - ASCE, 1971 1
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PU8(ICATIONS:
Stevenson, J.D., and Haga. P.G.,
- Pressurized Water Reactor Containment 1.
Structures Design Experience." Journal of the Power Division. ASCE.
Vol. 96. No. P01. Proc. Paper.,7037. January 1970, Moses. F.. and Stevenson J.D. " Reliability Based Structural Design."
2.
Journal of the Structural Division. ASCE. Vol. 96. No. ST 2. Proc.
Paper 7072. February 1970.
Stevenson, J.D., and Moses. F. " Reliability Analysis of Frame 3.
Structures." Journal of the structural Oivision. ASCE. Vol. 96 No. ST 11. Proc. Paper 7692. November 1970.
Stevenson J.0.. ' Criteria and Design of Pressurtred Water Reactor 4.
Coolant System Support Structures - State-of-the-Art " First E
International Conference on Structural Mechantes in Reactor Technology.
Berlin Germany. September 1971.
Stevenson. J.0.. and Abrams. J.I.. (Editors) ' Proceedings of Sympostum 5.
on Structural Design of Nuclear Power Plant Fact 11ttes." University of g
P1ttsburgh, 1972.
Stevenson. J.0.. " Seismic Design of Small Otameter Pipe,and Tubing for
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6.
Nuclear Power Plants." Proc. 5th World Conference on Earthquake Engineering. Rome, June 1973.
Stevenson J.0.. ' Containment Structures for Pressurized Water Reactor 7.
Past. Present, and Future State-of-the Art." Proc. 2nd Systems:
International-Conference on Structural Mechanics in Reactor Technology.
I North Holland Publishing Company, 1973..
Stevenson, J.O. (Edttor). ' Proceedings of Symposium on Structural 8.
1 Design of Nuclear Power Plant Fact 11ttes." ASCE Speciality Conference.
Chicago. December 1973.
Stevenson, J.D. and 1.aPay." W.S. "Ampitftcation Factors to be used in 9.
Simpitfted Seismic Oynamic Analysts of Piping Systems.' Proc. Pressure Vessel ar.d Piping Conference. ASME. Jbne 1974.
Stevenson, J.0. (Editor). " Proceedings of Second ASCE Speciality 10.
Conference on Structural Design of Nuclear Power Plant Facilities."
New Orleans. December 1975.
Stevenson. J.O.. " Rational Determination of Operational Basis 11.
Earthquake and its Impact on Overall Safety and Cost of Nuclear I
Facilities.' Nuclear Enoineering and Oesign_ Vol.135. North Holland Publishing Company. 1975.
Stevenson, J.O. Survey of Extreme t.oad Design Regulatory Agency 12.
1.tcensing Requirements for Nuclear Power Plants." Nuclear Eng1n_ee_f.ln.g ajld_0esign. Vol. 36. North Holland Pub 11shing Company. 1976.
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Stevenson. J.D., " External Hazards in Reliability and Risk Assessment 13.
of Nuclear Power Plants." Proceeding 2nd International Conferen~ce on Structural Safety and Reliability. Munich. Sept. 1977.
14.
Stevenson, J.D., " Preliminary Design of a Containment to Withstand Core Melt for a 1300 MWe t.WR System." Nuclear Engineerine and Oestan.
Vol. 48. North Holland Publishing Company, June 1978.
15.
Stevenson, J.O., "The Economic Ef fect of Increased Seismic Load on Nuclear Power Plant Design and Construction Costs." Nuclear Engineering and Oesign, Vol. 48, North Holland Publishing Company, June 1978.
16.
Stevenson, J.D., "Research Needs Associated with Seismic Load on Nuclear Power Plants,' Nuclear Engineerino and Design, Vol. 50. North Holland Publishing Co., October 1978.
17.
Stevenson, J.D. (Editor), " International Seminar on Probabilistic and Extreme Load Design of Nuclear Plant Facilities,' Presented August 22-24. 1977 by SM)RT 4 and ASCE. March 1979.
18.
Stevenson. J.D., ' Standards - Status and Development in the Nuclear Industry." Proceedings of ASCE Speciality Conference on Design of Nuclear Plant Facilities, Boston, April 1979.
19.
Stevenson. J.D., "Probab1115 tic Analysis of Nuclear Containment Structures to Resist Seismic Loads," Proceedings of ASCE Speciality E'
Conference on Design of Nuclear Plant Factitties. Boston, April 1979. -
20.
Bergman. L.A. and Stevenson, J.D., "The Ef fects of Support Stif fness Upon the Response of Piping Systems," Presented at ASME National Congress on Pressure Vessels.and Piping. June 1979.
I 21.
Gorman, M. and Stevenson. J.D., " Probability of Failure of Piping W
Oesigned to Seismically Induced Emergency and Faulted Condition Limits,' to be Presented 5th SM1RT Conference, Berlin, Germany.
August 1979.
22.
Stevenson, J.D. Chairman, Editing Board, Bructural Analysis and Desion of Nuclear Plant Facilities, ASCE Manuals and Reports on Engineering Practice - No. 58. American Society of Civil Engineers, August 1980.
23.
Stevenson, J.0.. ' Structural Camping Values as a Function of Dynamic Response Stress and Oeformation t.evels," Nuclear Engineerino and Desien. Vol. 60 No. 2, September 1980.
24.
Stevenson, J.G. " Nuclear Standards Applicable to the Civil-Structural Design of Nuclear Power Plants." Proceedings of Speciality Conference on Experience with the implementation of Construction Practices. Codes Standards, and Regulations in Construction of Power Generating Facilities, Pennsylvanta State University. September 1981.
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25.
Stevenson, J.D. and Thomas, F.A., " Selected Review of Foreign t.icensing Practices for Nuclear Power Plants," NUREG/CR-2664, U.S. Nuclear Regulatory Comission, April 1982.
26.
Stevenson, J.D. and Thomas, F.A., " Selected Review of Regulatory Standards and Licensing Issu,es for Nuclear Power Plants "
NUREG/CR-3020. U.S. Nuclear Regulatory Commission, November 1982.
21.
Stevenson, J.D. and Thomas, F.A., " Selected Review of Foreign Safety Research for Nuclear Power Plants," NUREG/CR-3040, U.S. Nuclear I
Regulatory Consission, November 1982.
28.
Stevenson, J.D., "Use of the Delphi Approach in Seismic Qualification of Existing Electrical and Mechanical Equipment and Distribution Systems in Industrial Facilities," Proceedings of the 6th Japan Earthquake Engineering Symposium - 1982. Tokyo, Japan, December 1982.
29.
Stevenson, J.D. and Thomas, F.A., " Selected Review and Evaluation of U.S. Safety Research Vis-a-Vis Foreign Safety Research for Nuclear Power Plants," NUREG/CR-3212, U.S. Nuclear Regulatory Comission, I
March 1983.
30.
Stevenson, J.D., " Seismic Design of Nuclear Plant Facilities at Low Seismicity Sites " Lawrence Livermore Laboratories Sponsored Conference on Seismic Design of Industrial Facilities, San Franchco, May 1983.
31.
Hall, W.J., Kennedy, R.P. and Stevenson, J.D., " Nuclear Power Plant E
Seismic Design - A Review of Selected Topics,' Paper K 14/1 Presented at the 7th International Conference on Structural Mechanics in Reactor Technology, Chicago, Ill., August 1983.
(Submitted for Publication in E
Nuclear Engineering and Design) 32.
Stevenson, J.D., ' Designing for Extreme loads - The Impact on Cost and Schedule', Nuclear Engineering International, July 1984 33.
Stevenson, J.D., "A Review of Procedures Available to Seismically Requalify Operating Nuclear Plant Structures. Equipment and I
Distribution Systems", Paper K 936 To be Presented at 8th SMIRT, August 1985 34 Stevenson, J.D. "A Sumary of Snubber Failure Experience in Nuclear Power Plant Facilities", Paper F1 935. To be Presented at 8th SMIRT, August, 1985 6
35.
Stevenson, J.D., " Rational Seismic Design of Nuclear Power Plant Piping at low and Moderate Seismicity Sites", Paper K937, To Be Presented at 8th SMIRT, August 1985 l.3 3
s EXHIBIT "B"
STEVENSON & ASSOCIATES a structural-mechanical consulting engineering firm 9217 Midwest Avenue. Cleveland, Ohio 44125. (216) 587-3805. Telex: 980101 Document Number 861401-1 Revision 0 -- 2/10/86 A PRELIMINARY EVALUATION OF THE SIGNIFICANCE OF THE SEISMIC EVENT ON JANUARY 31, 1986 ON
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THE PERRY NUCLEAR POWER PLANT February 10, 1986 Perry Nuclear Power Plant Cleveland Electric Illuminating Co.
10 Center Road Perry, Ohio 44080 PREPARED BY:
Stevenson and Associates 9217 Midwest Avenue Cleveland, Ohio 44125 (216) 587-3805
l i
l Document Number 861401-1 Revision 0 -- 2/10/86 A PRELIMINARY EVALUATION OF THE SIGNIFICANCE OF THE SEISMIC EVENT ON JANUARY 31, 1986 ON THE PERRY NUCLEAR POWER PLANT k
February 10, 1986 Perry Nuclear Power Plant Cleveland Electric Illuminating Co.
10 Center Road Perry, Ohio 44080 PREPARED BY:
Stevenson and Associates 9217 Midwest Avenue Cleveland, Ohio 44125 (216) 587-3805 t
1.0 INTRODUCTION
On January 31, 1986, at 11:47 a.m. EST, a brief (approximately 0.75 second strong motion duration) and shallow (10 km focal depth) earthquake with a 4.9 mb magnitude occurred.
Its epi-center was south of Lake Erie, at a distance of approximately eleven (11) miles from the Perry Nuclear Power Plant site at Perry, Ohio.
Stevenson and Associates was retained to analyze the data pro-vided by seismic recorders installed at various locations in the Perry plant, and determine:
(1) how the earthquake para-meters, as recorded by the instrumentation at the site, compare to those for the Safe Shutdown Earthquake (SSE) and Operating Basis Earthquake (OBE) postulated in the design of the Perry plant's buildings, systems and components; (2) the structural' significance of the readings by the seismic recorders at the Perry site during the January 31, 1986 earthquake; and (3) the anticipated impact of the earthquake on the plant's buildings, systems and components.
This report contains Stevenson and Associates' preliminary evaluation of the above-described matters.
It is based on a physical walkdown of.the site, analysis of data recorded by the seismic instrumentation, and discussions with plant technical and operating personnel.
Since some of the evaluations of the earthquake are still underway, this report may be supplemented and/or revised at a later date if new information developed during these ongoing activities so warrants.
4 m
A resume of the qualifications and experience of Stevenson and Associates is included as Attachment 1 to this report.
2.0 SEISMIC INSTRUMENTATION AT THE PERRY PLANT The earthquake motion at the Perry site was recorded by three different types of instrumentation.
One type of recorder is the Kinemetrics Model SMA-3 strong motion time history record-ing accelerograph; this system detects and records the three orthogonal components of acceleration signals over the duration of an earthquake.
Another type of instrumentation is the Engdahl PSR 1200-H/V response spectrum recorder, which provides the respons. at selected frequencies in three orthogonal direc-tions.
The third type of instrumentation is the Engdahl PAR 400 peak accelerograph, which records the three orthogonal com-ponents of peak local accelerations produced by the earthquake.
The locations and readings taken by these systems vill be dis-cussed ~ separately below.
2.1 Locations and Readinos by the Kinemetrics SMA-3 Accelerocraphs Two Kinemetrics SMA-3 strong motion time history recording accelerographs installed at the Perry plant provided time his-tory data on the earthquake.
One system is located on the Unit I reactor containment concrete vall at the basemat at Elevation 575', as shown in Figure 1.
The second system is attached to the steel containment vessel vall at Elevation 686', 111 feet above the first system and offset by less than one degree in Azimuth.
The longitudinal axes of both instruments are in the N-S direction.
The time history motions recorded by these two systems are shown in Figures 2 through 8.
A detailed interpretation of the
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readings from these recorders is contained in Reference 1.1/
The lower instrument (Elevation 575') gave a peak acceleration of 0.18g in the N-S direction, 0.10g in the E-W direction, and 0.llg in the vertical direction.
The upper instrument (Elevation 686') gave a peak acceleration of 0.55g in the N-S direction, 0.18g in the E-W direction, and 0.30g in the verti-cal direction.
It should be noted that both instruments are installed on cantilever brackets off the wall.
While the brackets are quite heavy and relatively rigid, they are attached by four 3/8" diameter bolts, approximately 5 inches on center vertically and 8 inches horizontally.
This arrangement nay result in amplified bracket motion.
2.2 Locations and Readinos of the Enodahl Response Spectra Recorders There are four Engdahl PSR 1200-H/V triaxial response spectra recorders at the Perry plant.
This type of recorder includes twelve reeds of different lengths and weights, one for each 1/
References are listed at the end of this report.
frequency, fabricated from spring steel.
A diamond-tipped sty-lus is attached to the free end of each reed to inscribe a per-manent record of its deflection on one of twelve record plates.
The record plates are aluminum, plated with successive layers of nickel, tin, and lead-tin.
The four PSR 1200-H/V recorders at the Perry plant are located as follows (all locations are for Unit 1):
1.
Reactor Buildino Foundation:
Elevation 574', Reactor Building foundation mat, Azimuth 210*.
This recorder was most recently calibrated on January 14, 1985.
2.
Reactor Buildino Drywell Platform:
Inside the drywell platform at Elevation 630', Azimuth 240*, mounte'd as shown in Figure 9. "This recorder was most recently calibrated on January 30, 1986.
3.
HPCS Pump Base Mat:
In the HPCS Pump Room, in the Aux-iliary Building foundation mat, Elevation 574'.
The equipment was being calibrated at the time of the earthquake.
Previous calibration occurred on January 14, 1985.
4.
RCIC Pump Base Mat:
In the RCIC Pump Room in the Auxil-iary Building foundation mat at Elevation 574'.
The equipment was being calibrated at the time of the earthquake.
Previous calibration was on January 14, 1985.
The readings taken by these four instruments are discussed in detail in Reference 2.
Briefly stated, three of the four in-struments provided response spectra which were consistent with each other and which were reasonable in light of the time his-tory readings of the Kinemetrics instruments.
The fourth spectra recorder, mounted inside the drywell on the Elevation 630' platform (see Figure 9), indicated vertical acceleration response components of.973g and 1.54g at frequencies of 20.2 and 25.4 Hz, respectively.
These readings were 8 to 10 times higher than the corresponding horizontal accelerations at the same frequencies measured by the instrument.
See Table 1.2_/
2.3 Location and Readinos of the Enodahl Peak Acceleration Recorde.rs The Engdahl Model PAR 400 peak acceleration recorder senses and records peak accelerations triaxially.
A diamond tipped scriber at the end of an amplifier arm traces a very fine visi-ble permanent record on an aluminum record plate with succes-sive layers of nickel, gold, and burnt gold.
2/
Figure 9 shows the mounting of the Engdahl PSR 1200-H/V instrument on the Elevation 630' platform.
The instrument is located approximately 6 feet from the face of the reactor ves-sel shield wall on an outer beam which provides supports for the platform, recirculation and safety injection piping, and a monorail.
Given the highly complex nature of the steel plat-form and support structure on which the instrument is mounted, it is quite possible the instrument may have measured the ac-celeration caused by a secondary impact resulting from the earthquake..
The two peak acceleration recorders are located as follows:
1.
Reactor Recirculation Pump:
Inside the drywell at Elevation 574', on recirculation pump B33-C001A.
This instru-ment was most recently calibrated on December 4, 1985.
2.
HPCS Pump Base Mat:
In the HPCS Pump Room, in the Aux-iliary Building foundation mat at Elevation 574', mounted as shown in Figure 10.
This instrument was most recently cali-brated on January 30, 1986.
The readings by the Engdahl PAR 400 recorders are dis-cussed in detail in Reference 2.
3.0 COMPARISON AND EVALUATION OF RECORDED ACQELERATIONS AGAINST THOSE ASSUMED FOR THE PERRY SSE AND OBE Table 2 shows a comparison of the zero period acelerations
("ZPAs"), as recorded by the various instruments, with the cor-responding SSE and OBE design accelerations.
According to the recorded accelerations, the design basis values of ZPA for the l
OBE, and in a few ' instances the SSE, were exceeded during the l
l January 31, 1986 earthquake.
As will be discussed below, given the short duration and low energy of the earthquake, the ex-ceedences were not significant from an engineering point of view.
This is supported by the apparent lack of damage to plant structures and mechanical and electrical components de-tected as a result of the earthquake.
Moreover, inspection of.
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engineered facilities located near the epicenter and not de-signed to withstand any earthquake force did not reveal any damage from the earthquake (Reference 3).
In order to corre-late the short duration, high frequency acceleration thac was recorded with the lack of impact on structures and equipnent, it is necessary to understand how measured ground acceleration can and should be correlated with design basis accelerations.
In postulating the limiting earthquake conditions for designing nuclear power plant facilities, a key parameter has been the zero period acceleration or Instrumental Peak Acceleration (Arp), which represents the peak acceleiation recorded during the entire. earthquake motion.
As concluded in many studies
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(References 4 through 11), Arp is a poor indicator of the dam-age potential of earthquake ground motions.
It has been ob-served that structures performed much better than would have been predicted based on the measured Arp to which the struc-tures were subjected; this phenomenon has been particularly no-ticeable in connection with short duration, high energy ground motions due to low to moderate magnitude earthquakes, such as the January 31, 1986 earthquake near Perry.1/
The differer;ces 1/
Examples of this behavior may be found in the records of the 1966 Parkfield earthquake, the 1971 Pacoima Dam earthquake, the 1972 Ancona earthquake, and the 1972 Melendy Ranch Barn earthquake.
These earthquakes showed recorded instrumental peak ground accelerations of between 0.5g and 1.2g, yet only minor damage occurred in the vicinity of the recording sites.
vr between measured ground motion, assumed design levels, and ob-served physical behavior is so significant that it cannot be attributed to.the safety factors which are utilized in the de-sign and in elastic seismic analyses.
Kennedy (Reference 12), based on the work of others (References 13 through 16) has suggested that it is not appropriate to use just measured A p to define the characteristics of the SSE and I
OBE.
It is necessary to take also into account, in addition to Arp, the dominant frequency of the strong motion excitation and the duration of the strong motion.1/
He has proposed the fol-loving relationship to develop an equivalent design accelera-tion for the anchoring elastic spectra:
AD" (K ) (rms),
p where AD is the equivalent design acceleration and the other parameters are defined as follows:
p
=J2in(2To/To) 42.0 K
Duration of strong motion (sec.)
To
=
1/
Thus, for a high dominant frequency and/or short duration earthquake, the equivalent peak acceleration would be signifi-cantly less than that predicted on the basis of Arp measure-ments alone..
Predominant period of cotion (sec.)
To
=
dP rms
=
E(T)/TD = earthquake power (average P
=
rate of energy input)
N t To 2
a (t)dt = total energy ET
=
I/ t.
fed into the structure between times to and to + To, and iristrument acceleration at time t.
a(t)
=
Efforts are underway to compute Ao for the January 31, 1986 earthquake.
In the meantime and by way of comparison, four earthquakes similar in magnitude and duration to the Perry earthquake have been selected from Tables 1 and 2 of Reference 12.
The characteristics of those e~arthquakes, and those of the one at Perry, are summarized in Table 3.
For the four earth-quakes listed, an average ZPA of 0.434g is required to cause the same level of response for elastic structures as that pos-tulated by the NRC Reg. Guide 1.60 (Reference 17) spectra for a
.20g ground acceleration.
This result suggests that a correc-tion factor of 0.20/0.434 = 0.46 should be applied to the ac-celerations measured during low to moderate magnitude earth-quakes (such as the one near Perry) to obtain elastic responses r,-
that can be compared to those from the limiting Reg. Guide 1.60 earthquake.
If, in fact, a 0.46 correction factor is applied to the accel-erations recorded at Perry and shown in Table 2, accelerations well below the SSE and OBE levels are obtained for all loca-tions except for the readings at the Reactor Building Contain-ment Vessel (Elevation 686'), where the corrected N-S and ver-tical ZPA are approximately equal to the OBE design value.
This is shown in Table 4, where the recorded values of Table 2 have been adjusted by a.46 factor.
4.
STRUCTURAL SIGNIFICANCE OF THE PERRY EARTHQUAKE AND ANTICIPATED IMPACT OF EVENT ON THE ADEQUACY OF THE PLANT STRUCTURES, SYSTEMS AND COMPONENTS, Table 4. indicates that if the recorded accelerations from the Perry earthquake are corrected to take into account the short duration and lov energy of the event, the average elastic re-sponse ZPAs are in all but one instance equal to or less than one-third of the OBE design values, and are approximately equal to the OBE values in the remaining case.
In light of these re-sults and the design limits placed on the strength of materials for safety applications (i.e., not to exceed a 0.6 to 0.8 fac-tor of yield during an OBE), all safety-related plant struc-tures, systems and equipment should have remained essentially elastic during an earthquake such as the one experienced on l 0
January 31, 1986, and thus should have emerged undamaged from it.
This expectation has been corroborated by physical obser-vation of plant conditions following the earthquake.
Some auxiliary or secondary structural systems, such as sus-pended ceilings and plaster ceilings and walls, might be ex-pected to sustain some displacement or cracking.
One might also expect actuation of instrumentation measuring or sensing changes in liquid levels or the presence of vibration.
In ad-dition, one might expect some activation of inertia-sensing re-lays or switches (fluid or spring loaded), if such controls or l'nstrumentation have not been qualified for seismic op-erability.
If any of these circumstances are determined to have taken place at Perry, their occurrence voul'd only be in-dicative of the anticipated response of non-seismically quali-fled structures to moderate earthquake conditions.
4 e
n-TABLE 1 (From Reference 2)
READINGS FROM RESPONSE SPECTRA RECORDER MPL NUMBER:
D51-R170 LOCATION:
REACTOR RECIRCULATION PIPING SUPPORT - DW 630', 240*
NOMINAL ACCELERATION (c)
REED FREQUENCY NUMBER (HERTZ)
North / South East / West Vertical 1-31-86 2-2-86 1-31-86 2-2-86 1-31-86 2-2-86 1
2.00
.047
.048
.049
.051
.007
.007 2
2.52
.082
.082
.086
.084
(*)
.013 3
3.17
.184
.184
.144
.140
.015
.014 4
4.00
.226
.223
.128
.127
.023
.023 5
5.04
.132
.134
.158
.158
.035
.033 6
6.35
.131
.134
.058
.055
.033
.030 7
8.00
.104
.104
.109
.090
(*)
.019 8
10.1
.093
.093
(*)
.052
.093
.085 9
12.7
.188
.182
.166
.080
.198
.199 10 16.0
.194
.204/.167
.348
.312
.490
.500 11 20.2
.152
.152
.191
.175
.973
.973
^
12 25.4
.114
.091
.155
.'158 1.7 1.54
(*)
Unreadable TABLE 2 COMPARISON OF DESIGN ZPAs (1)
VS RECORDED ZPAs (Expressed in g values)
Reactor Reactor Reactor Reactor Building Building Auxiliary Building Building Con-Platform Building Founda-Recircu-tainment Ele-Founda-tion Mat lation Vessel vation tion Mat Elevation Pump Elevation 630'-1" Eleva-574'-10" Eleva-tion 686' Inside tion 568' SMA -3 tion 605' SMA-3 Drywell PAR 400 (Kine-PAR 400 (Kine-PSR 1200 (Engdahl) metrics)
(Engdahl) metrics) (Engdahl)
D51-R140 D51-N101 D51-R120 D51-Nill D51-R170 Recorded
.17
.18
.32
.55
.09 NS SSE
.17
.18 1.06
.40
.48 OBE
.10
.10
.86
.24
.40 Recorded
.06
.10
,11
.18
.16 EW SSE
.20
.18 1.06
.40
.48 OBE
.10
.10
.86
.24
.40 Recorded
.03
.11
.05
.30 Note 2 VERT SSE
.20
.18
.47
.24
.28 OBE
.10
.10
.38
.15
.16 Recorded.
.18
.23
.34
.65 Note 2 SRSS(3) SSE
.33
.31 1.57
.62
.73 OBE
.17
.17 1.27
.37
.59 (1)
Zero period acceleration (2)
ZPA indeterminable from available data (3)
Square-root-of-the-sum of the squares n-TABLE 3 CHARACTERISTICS AND GROUND ACCELERATION LEVELS REQUIRED TO ACHIEVE EQUAL STRUCTURAL ELASTIC RESPONSE BETWEEN R.G.
1.60 AND SELECTED EARTHQUAKES Recording Peak Equiv.
Station Inst.
Strong ZPGA to Magni-Epicen-Ground Motion the 0.20g tude tral Dis-Accelera-Dura-R.G. 1.60 Earthouake My tance(km) tion, a tion, sec.
Spectra Parkfield - 1966 5.6 1
0.49 1.4
.3275 Hollister - 1974 5.2 13 0.138 1.1
.4825 Santa
- 1978 5.1 4
0.347 3.0
.2825 Barbara Bear Valley-1972 4.7 6
0.520 0.8
.6450
.434(Average)
- 1986 4.9 17
(*)
0.75
(*)
0.18g in N-S direction, 0.10g in E-W direction, measured at the foundations.
6
- TABLE 4 COMPARISON OF DESIGN ZPAs (1)
VS CORRECTED RECORDED ZPAs (Expressed in g values)
Reactor Reactor Reactor Reactor Building Building Auxiliary Building Building Con-Platform Building Founda-Recircu-tainment Ele-Founda-tion Mat lation Vessel vation tion Mat Elevation Pump Elevation 630'-1" Eleva-574'-10" Eleva-tion 686' Inside tion 568' SMA -3 tion 605' SMA-3 Dryvell PAR 400 (Kine-PAR 400 (Kine-PSR 1200 (Engdahl) metrics)
(Engdahl) metrics) (Engdahl)
D51-R140 D51-N101 D51-R120 D51-Nill D51-R170 Recorded
.08
.08
.15
.25
.04 NS SSE
.17
.18 1.06
.40
.48 OBE
.10
.10
.86
.24
.40 Recorded
.03
.05
.06
.08
.07 EW SSE
.20
.18 1.06
.40
.48 OBE
.10
.10
.86
.24
.40 Recorded
.02
.06
.02
.14 Note 2 VERT SSE
.20
.18
.47
.24
.28 OBE
.10
.10
.38
.15
.16 Recorded
.08
.11
.16
.30 Note 2 SRSS(3) SSE
.33
.31 1.57
.62
.73 OBE
.17
.17 1.27
.37
.59 (1)
Zero period acceleration (2)
ZPA indeterminable from available data (3)
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REFERENCES (1)
Kinemetrics/ Systems "3trong-Motion Data report for the ML 5.0 Earthqua' x ai.147 EST, January 31, 1986 Perry,-
Ohio", 4 Februa.* le,6.
(2)
ENGDAHL Enterprises, " Report on the Peak Shock Recorder and Peak Acceleration Recorder Installed at the Perry Nuclear Power Plant During the Seismic Event on January 31, 1986," Document No. 120910, 7 February 1986.
(3)
Stevenson and Associates,," Reconnaissance Report Pre-pared for EERI for the Ohio-1986 Earthquake" (In Prepa-ration).
(4)
Blume, J. A., "On Instrume'ntal versus Effective Accelera-tion and Design Coefficients", Proceedings of the 2d U.S. National Conference on Earthquake Engineering, Stanford University, California, August 1979.
(5)
- Schnabel, P.B.,
and Seed, H.B., " Accelerations in Rock for Ea.thquakes'in the Western United States",.Seismol.
r Soc. America Bull., Vol. 62, April 1973.
(6)
- Ploessel, M.R.,
and Slosson, J.E., "Repedtable High Ground Accelerations from Earthquakes", California Geol,-
ogy, Vol. 27, No. 9, pp.'195-199, September 1974.
(7)
- Newmark, N.M., "A Rationale for Development of Design Spectra for Diablo Canyon Reactor Facility", N.M.
Newmark Consulting Engineering Services, Urbana, Illionis, September 1976.
(8)
- Nuttli, O.W.,
" State-of-the-Art for Assessing Earthquake
' Hazards in the United States; The Relation of Sustained Maximum Ground Acceleration and Velocity to Earthquake Intensity and Magnitude", Miscellaneous Paper S-73-1, Report 16, November 1979, U.S. Army Engineers Waterways Experiment Station, Vicksburg, Miss.
(9)
- Whitman, R.V.,
" Effective Peak Acceleration", Proceed-ings of the Second International Conference on Microzonation, San Francisco, California, November 26 -
December 1, 1978, Vol. III, pp. 1247-1255.
(10)
- Page, R.A.,
- Boore, D.M.,
- Joyner, W.B.,
and Coulter, H.W., " Ground Motion Values for Use in the Seismic De-sign of the Trans-Alaska Pipeline System", USGS Circular No. 672, Washington (1972).
- rr (11)
- Kennedy, R.P.,
- Tong, W.H.,
and Short, S.A.,
" Earthquake Design Ground Acceleration Versus Instrumental Peak Ground Acceleration", SMA 12501.01, Structural Mechanics Associates, Newport Beach, California, October 1980.
(12)
- Kennedy, R.P., " Peak Acceleration as a Measure of Dam-age", Presented at 4th International Seminar on Ext'reme-Load Design of Nuclear Power Plants", Paris, France, August 1981, 1
(13)
- Arias, A., "A Measure of Earthquake Intensity", Seismic Design for Nuclear Power Plants, MIT Press, Cambridge, Mass. (1970).
(14)
Housner,'G.W., " Measures of Severity of Earthquake Ground Shaking", Proceedings of the U.S. National Con-ference on Earthquake Engineering, EERI, Ann Arbor, Michigan, June 1975, pp. 25-33.
(15)
- Mortgat, C.P., "A Probabilistic Definition of Effective Acceleration", Proceedings of the 2nd U.S. National Con-ference on Earthquake Engineering, Stanford University, August 22-24, 1979, pp. 743-752.
(16)
- McCann, M.W., Jr. and Shah, H.C., "RMS Acceleration for Seismic Risk Analysis:
An Overview", Prdceedings of the 2nd U.S. National Conference on Earthquake Engineering, Stanford University, August 22-24, 1979, pp. 883-897.
(17)
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.60, " Design Response Spectra for Seismic Design of Nu-clear Power Plants" (Rev. 1, December 1973).
l W G
O
l ATTACHMENT 7
o UNITED STATES OF AMERICA NUCLEAR REGULATORY CONNISSION
-w Before the Director. Office of Nuclear Reactor Regulation
)
In the Matter or
~
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 OL ILLUMINATING CO. ET AL.
)
50-441 OL
)
(Perry'Nuclece Power Plant,
)
Units 1 and 2)
)
~
PETITION FOR ACTION UtIDER 10 CFR 0.006 I.
INTRODUCTION At 11:47 AM on Fetday. January 31, 1986 on earthquake with a
scale struck Northeast Ohio.
magnitude or 5.0 on the Rtchter is estimated to be near The epicenter or the earthquake Thompson, Ohio, less than 10 miles from the Perry Nuclear Power Plant.
While only preliminary information is ovoilable on the earthquake at this time, this information strongly indicates the FSAR onalysis or site creo seismicity that, at o minimum, needs to be redone.
The January 31 earthquake clearly shows the conclusions in the FSAR and SER (NUREG-0887) to be erroneous.
For example, it is concluded that no capable routes exist in the vicinity or the plant.
FSAR Section 2.5.3.4s SER ot p.
2-21.
The plant site 15 also sotd to be on oreo of low seismicity.
FSAP Section 2.
Appendix 0, p.
0-94.
Even more disturbing ore news accounts stating that accelerottons from the earthquoke were estimated to range from 0.19 9 to 0.25 g.
Perry as aesigned to wathstand 0.15 g (sore shutdown earthquake).
F5AR 5ection 0.5.0.6.
This, along with the definitton of the operating costs earthquoke in 10 CFR 100
~ - - - - _ _ _ _ - _ _ - _ _ _ _ _
o.
t could reasonobly be expected to Appendix A-(on earthquake ubich ofrect the plant Site during the operating life of the plan t),
indicates that the SSE ond OBE should be more severe than presently postulated, and the seismic capability of safety-related structures, systems, and components at Perry should be upgraded accordingly.
In light of this information, Chio Citi: ens for Responsible Energy (*0CRE') hos moved to reopen the hearing record in the Perry operating license proceeding, for the purposes or admitting and litigating the following neu contention:
Appliconts have not demonstrated that the seismic design of the Perry Nuclear Pcuer Plant :- odequate in light of observed local Seismicity.
Secouse fuel loading of Perry Unit 1 is scheduled for sometime this month (perhaps os soon as mid-February). OCRE 0150 finds it necessary
.t o file this action pursuont to 10 CFR 2.206 in order to ensure thoe licensing does not proceed before this.
matter has been thoroughly investigated.
II. RELIEF REQUESTED OCRE requests that fuel loading noe be permitted, and that no operottng Itcense for any pouer level be tssued, until the follouang actions have ceen accompisshed:
1.
The Perry Nuclear Power Plant hos been thoroughly snspecteo for domoge resuictag from the January 31 earthquake.
This should include the use of nondestructive evoluotion techniques as well om tsual inspection, v
T testing or all plant systems is 2.
Post-earthquake functional cCapleted.
These, tests should include, but not be limited to, containment integrated look rate testing and hydrostatic testing Cr the reactor. coolant pressure boundary.
corrective actions or repairs round 3.
Full completion or any to be necessary as o result or the testing and inspection delineated above.
4.
A comprehensive investagotion or the January 31 earthquake and a reevaluation or local seismicity by the Cleveland Electric Illuminating Co., the NRC, the Advisory Committee on Reactor Soreguards, the U.S. Geologic survey, and all other scientific ontities studying the earthquake.
S.
Completion or the hearing and assuance or o decision'on (noted above) in the reopened OCRE's seismic design contention operating license proceeding, should the Appeal Board grant CCRE's motion, Completed installation or any seismic upgrading of Perry c.
that may be required either by the NRC Starr or by the Appeal in its decision on OCRE's seismic design contention.
Board III. CONCLUSION The January 31 earthquake rosses ssgnificant questions ocout the sorety or the Perry Nuclear Pouer Plant.
Completion or the ocove activities is o necessory prerequisste to the resolution of these questions.
Because it is imperative that the sorety or Perry be firmly resolved carore the plant is permitted to
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I operate, the granting or this Petition is manifestly in the public interest, Respectru11y submitted.
esI suson L, Hiatt OCRE Representative 3275 Munson Rd.
Mentor. OH 44060 (214) 255-3158 5 - 8 _ 3_ w. 1.9.3_6_ _ _ _ _ _ _ _ _ _
OATED S
I e
4 4
y February 25, 1986 00CKETED USNHC UNITED STATES OF AMERICA
'86 Qg 2/ #0 W NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal [ M N,h'
)u_-' u. r, In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing "Appli-cants' Answer to OCRE Motion to Reopen the Record and to Submit a New Contention" were served by deposit in the United States Mail, First Class, postage prepaid, this 25th day of February, 1986, to all those on the attached Service List.
Q f Yf f
HARRY H.
GLASSPIEGEL' DATED:
February 25, 1986 h
\\
UNITED STATES OF AMERICA NUCLEAR REGULATCRY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
)
)
THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL.
)
50-441
)
(Perry Nuclear Power Plant,
)
Units 1 and 2)
)
SERVICE LIST Alan S. Rosenthal, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel i
l Appeal Board U.
S. Nuclear Regulatory Commission U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 i
Washington, D.
C.
20555 Dr. W. Reed Johnson ~
Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Appeal Board U.
S. Nuclear Regulatory Commission U.
S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Mr. Howard A. Wilber Colleen Woodhead, Esquire Atomic Safety and Licensing Office of the Executive Legal Appeal Board Director U. S. Nuclear Regulatory Commission U.
S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 James P..Gleason, Chairman Terry Lodge, Esquire 513 Gilmoure Drive Suite 105 Silver Spring, Maryland 20901 618 N. Mici.igan Street Toledo, Ohio 43624 Jerry R. Kline Ms. Susan L.
Hiatt Atomic Safety and Licensing Board 8275 Munson Avenue U.S. Nuclear Regulatory Commission Mentor, Ohio 44060 Washington, D.C.
20555 Glenn O. Bright Donald T.
Ezzone, Esquire Atomic Safety and Licensing Board Assistant Prosecuting Attorney U.S. Nuclear Regulatory Commission Lake County Administration Center Washington, D.C.
20555 105 Center Street Painesville, Ohio 44077 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 John G. Cardinal, Esquire Prosecuting Attorney Ashtabula County Courthouse Jefferson, Ohio 44047
..