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CONSULTING ENGINEER
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5AN P R A N C 15 C 0 TbLEPHONE SUTTER 1 2373 POSTAL CODE 94105 f
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AtomicEnergyCommission Wa.shington 5, D. C.
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Attention:
Mr. Robert Loewenstein, Director-g] 4g 0 ggg g$
.4 of Licensing and Regulation 1
h Gentlemen:
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'O dpgNg\\g This is to request information on the projected L
e Bay Unit No. 1, your Docket No.- 50-205.
The writer is a consulting mechanical engineer experi-enced in the startup and debugging of industrial materials b
handling, control and instrumentation systems.
The Prelim-inary Hazards Analysis Exhibit C of the Bodega Bay applica-k tion; the Comgission's, Questions; Amendments No. 1 and No. 2 to Exhibit C, and TID 7024 have come to my attention.
f My reading of these documents has raised a series of x
questions relative to the reactor safety control systems; the design of underground structures traversing fault lines to resist ground movement; and the presentation of estimater of the benefits'of nuclear power to the public.
Parenthetically, you may share my surprise that private conversalons with eight prominent professional engineers, six of them in responsible charge of design of major projects and l
one a construction manager,by a score of seven to one. indicate opposition to co tion of the Bodega reactor It is hoped that an exchange of correspondence will answer this writer's questions, or encou, rage answers to be developed where none now exist.
The questions which we think need discussion are:
i I.
What is the hazard to be guarded against?
II.
How does the reactor control system protect us from the hazard?
III.
Are we is possession of sufficient information as to long term reliability of the plant?.
- 7 p; r 'p8? P "*PDR-ACHOW!ED8ED FIRESTD85-665 q
MECHANICAL ENGINEERING DEllGN I
INDEPENDENT STUDIES AND REPORTS
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Atomic Energy Comission"
' ' March 17, 1964 Pag,e 2.
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We request discussion of-the;following:'
I.
What.is the hazard to be guarded'against?.
?
a.
E,tructures :
The reactor atIBodegaiis.in a'circu-lar pit.,.In the event of horizontal shear forces across any subfault.within the: pit, the concrete:
lining will either have-to'act.like a round_ key,.
4 preventing relative ground motion, or will yield.-
'Are you. prepared to approve,a structural design which has to be " earthquake resistant" in this sense, rather than in the'more~ familiar: sense of.
f.
above ground structures resisting horizontal-forces due to ground accelerations and building.
r inertia?
We here acknowledge verbal: reports of, r'
design studies for the: Stanford Linear Accelerator p
wherein an underground structure traverses a fault:
line.
Are these design approachesi sufficiently -
well proven-in experience to form the. basis of' AEC approval for a reactor pit lining?
- b.
- Reactor Operation:-
Is there.a'h'azard from muclear
'l explosion here?
What are the consequences of the-
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failure of'the scram' system to operate?.If the r
core starts to melt and the fuel collects in-the-bottom of the core, what would happen?-
II.
How does the reactor. control system protect us from i
the hazard?
L a.
Overcontrol Capability:
Fr'om page IV-5 of Pre-liminary Hazards Analysis:
"The-total control-system is designed with enough shutdown capacity so that the reactor..will always.be suberitical with any one control rod completely withdrawn d.W,p,g !
from the core."
To this. reader the implication-1 is that under some conditions complete insertion-of 144 of. theil45 i:ontrol rods may be necessary
-l for complete shutdown.
Is.this true?-
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b.
. Control-System:
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Refer to Figure III-25 PHA.
How many control-1 3
rods does Reactor Protection Channel #1 acti-vate?
How many control rods does Reactor Pro-tection Channel 12 activate?-
2.
See PHA Figure-III-14.
Are the two control rod drive system solenoid valves functionally r
redundant?
It would appear.that the piping..
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Atomic Energy Commission March 17, 1964 7
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l and porting of the 2 control valve's put them in a logically "OR" relationship so that a loss of voltage in either pilot solenoid circuit will initiate a scram.
3.
What is the function of the 3-way solenoid valve 50/NC35 interposed between the 2 ' instrument air
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supply and the instrument air header?
Is this i
"DC(:fnergized to scram" solenoid powered by the l
& " station battery mentioned on PHA pag"e III-267 i
Is this device considered " fail safe and is its I
wiring loop to be monitored for continuity?
I l
4.
Refer to PG & E's Amendment No. 1, Page 11, answer to question #25, " Failure of power to only one bus will cause de energization of the scram pilot valves connected to the channel served by that bus but will not result in a scram.
This permits re-i i
actor operation to continue, with single channel k
protection provided by the unaffected channel."
e Under this s', heme it would be possible to operate the reactor without any backup for its one func-t tioning control channel.
l How can this description be brought into line with the desire for a high-reliability scram control system?
If this writer under-stands the wiring and piping diagrams mentioned above correctly, an alarm condition from either reactor protection channel will initi-ate a scram.
This writer would object to any unnecessary complications in an automatic control system and also would object to lockouts, by-l passes, or other defeat mechanisms in the safety circuits.
We i
wonder, then how the applicant's description of the operation of l
his " dual channel fail safe" control system can be made into a j
reality.
How is the scram pilot valve to discriminate between cur-i rent interruption due to bus volt; age failure and current interrup-l tion due to alarm action of the autometic controls?
l 1
III.
Are we in possession of sufficient information as to long i
term reliability of the plant?
- a. ' Control Rod Drives:
The control rod drives are, in this writer's opinion, moderately tricky devices, consisting of two concentric piston motions in a common exterior housing.
Is there a five year record i
of successful operation of thi's device at the tempera-tures, pressures, and corrosion and radiation condi-i tions to be found in the Bodega Reactor?
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> )>. n Atomic Energy Commission' March 17,.1964 Page,4.
b.
Instrumentation:-
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- 1..Is there a five year successful. operating record on the instrumentation itemsiproposed for in core maunting, under:the'same conditions to be found in the Bodega Reactor?
_2.
Is it proposed'to use any transistors'or/any.other solid state electronic devices.in surroundings in '
R which these are significant levels.of radiation?
9 For.each type proposed to.be used, is there alsuc cessful?five of radiation? year.. operating record at those levels 1
F 3.
How will individual-solid state devices be selected for reliability?
B c.
Economics:
If full safety is to be achieved through the use of a " dual channel fail safe"~ control system, i
and if any, failure of any component in either. channel is to initiate a' scram, if the entire plant has to go off the line on each scram and if a full inspection 5f the plan.will. be necessa,ry to determine what caused the scram, what does this do to the economics' of plant operation?-
d.
Materials Handling and Maint.g. nance:
1.
Is there a five year recor'dofsuccessful'Aperation of fuel rod control rod, and core. structure com-ponenthandling, maintenance,and' replacement-q i
equipment?
Does this record include the success-i ful handling of worn, bent, or corroded fuel rods and control rods?
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i 2.
Assume a condition of localized high neutron flux L
in the core as mentioned in'the PHA.- Assume 1
localized meltdown of core components.-
Is there a record of successful replacement of damaged core l
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components?
Who is to determine the extent of n.
repairs needed, and what is'the. amount of downtime
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L required'to reinspect and recertify the reactor as L
fit for service?-
1 e.
Desinn Stresses and_ Safety Factors:-
Sources of information.on the design of reactors for earthquake resistance seem to be written mainly by i
geologists or structural-engineers.. Their design l [
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.s Atomic Energy Commission March 17, 1964 i
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criteria appear to be less conservative than those i
used in ordinary industrial equipment.
For instance, i
Housner's " Design of Nuclear Power Reactors against Earthquakes" (Proc. 2d World Conf. on Earthquake Engineering, Tokyo, P. 134) refers to class I parts of reactors -- those essential for safety of operation j
as areas where stresses should " remain within the J
elastic limits".
Neglecting for the moment that moving parts often are limited by considerations of.
i deflection rather than of strength, this writer's l
comment is that a much greater margin of safety appears appropriate to a reactor.
The simple analyses made in the commercial design of F
materials handling equipment, for instance, show a gradation of factors of safety as the amount of hazard changes.
Small commercial hoists may have design t
stresses of one-third of the ultimate; si2nilar equip-ment specifically for repair work around expensive jet I
aircraft will call for design stresses of one-fifth; u
and some parts of ladle cranes carrying molten metal
,in large pouring shops, where not only. initial factors of safety but generous allowances for attrition due to wear are made, the design stresses can be one-tenth of the ultimate.
[
What is to be the factor of safety appropriate to the handling of fuel rods?
It is assumed that your office b
goes through an extensive plan checking procedure in f~
a? proving the design work on reactors; similar plan I
ctecking in the day-to-day routine of a municipal building inspection department is based upon some applicable code.
Do you have a code which governs the design of mechanical parts and reactor internals?
Where did this code originate?
Where it is not based
" upon some earlier code well proven in experience, such as the ASME Code for Pressure Vessels, how has it been experimentally verified?
Your early reply to this inquiry will'be appreciated.
Very trul
- yours, Paul E. Rosenthal 1
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