ML20209G626

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Forwards Request for Addl Info Re Seismic Interaction Program to Continue Evaluation of Application for Ol. Insufficient Info Provided to Demonstrate Compliance w/10CFR100,App a
ML20209G626
Person / Time
Site: Millstone 
Issue date: 09/17/1985
From: Youngblood B
Office of Nuclear Reactor Regulation
To: Opeka J
NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 8509190601
Download: ML20209G626 (3)


Text

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O e-Docket No. 50-423 SEP 171985 Mr. John F. Opeka Senior Vice President Nuclear Engineering and Operations Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06141-0270

Dear Mr. Opeka:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR MILLSTONE NUCLEAR POWER STATION, UNIT NO. 3 Re:

Letter from J. F. Opeka to B. J. Youngblood dated August 8,1985 Enclosed is a request for additional information which the staff requires to complete its evaluation of your application for an operating license for Millstone 3.

This request is the result of the staffs review of the information submitted in the Reference regarding the Millstone 3 Seismic Interaction Program. The staff review of the Seismic Interaction Program finds that insufficient evidence was presented in support of the program to demonstrate compliance with the applicable requirements of 10 CFR Part 100 Appendix A and the program is not acceptable as currently proposed.

To meet the regulations, you must either conclusively demonstrate similarity to achieve an equivalency to the qualification tests required by the regulations or cond;;ct an analysis using the same criteria applicable to seismic Category I systems.

The staff would like to meet with you as soon as possible to discuss your response to this item.

i For further infortation or clarification Manager, Elizabeth L. Doolittle on (301) please contact the Licensing Project 492-4911.

Sincerely, ORIGINAL SIGIC BY 3 B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing

Enclosure:

As stated DISTRIBUTION:

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SEP 17 ?985 Mr. J. F. Opeka Millstone Nuclear Power Station Northeast Nuclear Energy Company Unit No. 3 cc:

Gerald Garfield, Esq.

Ms. Jane Spector Day, Berry & Howard Federal Energy Regulatory Commission City Place 825 N. Capitol Street, NE Hartford, Connecticut 06103-3499 Room 8608C Washington, D.C.

20426 Mr. Maurice R. Scully, Executive Director Connecticut Municipal Electric Energy Cooperative 268 Thomas Road Groton, Connecticut 06340 Robert W. Bishop, Esq.

Corporate Secretary

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Northeast Utilities Post Office Box 270

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Hartford, Connecticut 06141 Mr. T. Rebelowski Senior Resident Inspector Office U. S. Nuclear Regulatory Commission Millstone III P. O. Box 615 Waterford, Connecticut 06385 Mr. Michael L. Jones, Manager Project Management Department

! e Massachusetts Municipal Wholesale Electric Company

- Post Office Box 426 Ludlow, Massachusetts 01056

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Regional Administrator U. S. NRC, Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. Karl Abraham Public Affairs Office, Region I U. S. Nuclear Regulatory Commission, King of Prussia, Pennsylvania 19406 t

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REQUEST FOR ADDITIONAL INFORTIATION MILLSTONE NUCLEAR POUER STATION, UNIT 3 NORTHEAST NUCLEAR ENERGY COMPANY DOCKET NO. 50-423 In a letter from J.F. Opeka to B.J. Youngblood dated August 8, 1985, the applicant for the Millstone-3 facility has proposed to implement a seismic interaction program to address the potential interactions between Seismic 1

Category I and Non-Seismic Category I structures, systems, and components.

The seismic interaction program proposes to satisfy the seismic /non-seismic interaction guidelines provided in Regulatory Guide 1.29 and Standard Review Plan Section 3.9.2 by relying on acquired knowledge of historical data pertaining to typical failure modes associated with equipnent subjected to

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large : notion earthquakes and by utilizing a set of review criteria to assess

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potentially unacceptable seismic interactions.

V The u'se of the seismic data base as proposed by the applicant to identify

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potentially unacceptable areas of seismic interaction is innovative and useful.' However, the criteria to be used to evaluate the outcome of such an interaction requires much more definition than presented in the proposed program. The staff to date has only accepted the same seismic design methods as those established for Seismic Category I Structures. Systems and Components I

to assess the interaction. To meet the regulations, the applicant e st either conclusively demonstrate component and load similarity to achieve an equivalency to the qualification tests required by the regulations or conduct an analysis using the same criteria applicable to scismic Category I systems.

!.6 Although the staff recognizes that the seismic margin between the analytically-1 predicted loads and the loads which are likely to actually occur during seismic 1

events is large (and current staff efforts as described in NUREG-1061 are reconnending methods to reduce the excess conservatism), the staff at this time lacks a justifiable basis to allow a deviation from the quantitative analyses or tests required by the regulations in favor of the qualitative assessment proposed in the Millstone-3 seismic interaction program.

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O CONCLUSION Based on the above discussion, the staff finds that the seismic interaction l

program proposed by the applicant has not demonstrated conclusively by component and load similarity arguments the ability of structures, systems, L

and components to perfom their safety function during and after a safe shutdown earthquake. Although the use of the applicant's proposed data base provides significant information regardig the potential areas of seismic interaction and seismic damage which might occur in non-nuclear facilities, demonstration that this information is capable of quantitatively evaluating the interaction on a plant specific basis for str1ctures, systems, and components 1siportant to safety in a nuclear facility it incomplete and therefore the methodology is not yet in compliance with 10CFR Pcrt 100 Appendix A.

It is believed that this knowledge when coupled with appropriate analytical methods used in the seismic design of nuclear facilities can provide an effective program to satisfactorily address the seismic interactions between non-Category I and Category I plant features in a quantitstive rather than a qualitative manner.

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