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MONTHYEARML20244A5561979-03-31031 March 1979 Answer to NRC 790313 Order to Show Cause.Will Reanalyze Seismic Loads on Piping Sys & Will Modify Sys Where Necessary.Expects to Submit Documented Results by 790424. Believes NRC Should Examine S&W Analyses Project stage: Other ML20244A5501979-03-31031 March 1979 Forwards Formal Util Response to NRC 790313 Order to Show Cause Re Potentially Unsafe Piping Sys Project stage: Other ML20244A6471979-04-17017 April 1979 Licensees' Response to 790402 Request of PA Public Util Commission for Hearing & Petition to Intervene Re 790313 Show Cause Order.Urges NRC to Hold Ruling in Abeyance. Certificate of Svc Encl Project stage: Other 1979-03-31
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212M2711999-09-30030 September 1999 Order Approving Transfer of Licenses DPR-66 & NPF-73 from Dlc to Pennsylvania Power Co & Approving Conforming Amends ML20212E5361999-09-24024 September 1999 Memorandum & Order.* Grants Local 29 Waiver of Time Limits for Filing Comments,In View of Claim of Newly Available Info & Refers Comments Re Firstenergy Ability to Run Beaver Valley NPP Safely.With Certificate of Svc.Served on 990924 ML20212G0661999-09-23023 September 1999 Answer of Duquesne Light Co Opposing Petition to Waive Time Limits & Suppl Comments of Local 29 Intl Brotherhood of Electrical Workers.* Request That Commission Deny Request for Leave to File Untimely Comments.With Certificate of Svc ML20212C5611999-09-21021 September 1999 Answer of Firstenergy Nuclear Operating Co & PPC in Opposition to Petition to Waive Time Limits & Suppl Comments of Local 29 Intl Brotherhood of Electrical Workers.* with Certificate of Svc ML20212C5751999-09-20020 September 1999 Affidavit of Td Martin on Beaver Valley Staffing.* Affidavit of Td Martin Re Nuclear Staffing Analysis Update of Staffing Benchmarking Analysis Completed on 980227 for Beaver Valley Power Station ML20212B3361999-09-16016 September 1999 Petition to Waive Time Limits in 10CFR2.1305 & Supplemental Comments on Local 29,Intl Brotherhood of Electrical Workers.* Local 29 Does Not Believe FENOC Can Safely Operate Facility If Positions Eliminated.With Certificate of Svc L-99-122, Comment Supporting Draft RG DG-10736, Svc Level I,Ii & III Protective Coatings Applied to Npps1999-07-28028 July 1999 Comment Supporting Draft RG DG-10736, Svc Level I,Ii & III Protective Coatings Applied to Npps ML20210C6511999-07-23023 July 1999 Memorandum & Order.* Orders That Petition to Intervene Filed by Local 29,IBEW Denied.With Certificate of Svc.Served on 990723 L-99-106, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Standards1999-06-29029 June 1999 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Standards ML20196F1911999-06-23023 June 1999 Reply of Local 29,Intl Brotherhood of Electrical Workers.* Requests That Commission Deny Answers of Dl & Firstenergy Nuclear Operating Co & Grant Local 29 Petition to Intervene as of Right.With Certificate of Svc ML20195H5141999-06-16016 June 1999 Answer of Firstenergy Nuclear Operating Co & Pennsylvania Power Co in Opposition to Petition for Leave to Intervene of Local 29,Intl Brotherhood of Electrical Workers.* Requests That Commission Deny Petition.With Certificate of Svc ML20195J5581999-06-16016 June 1999 Answer of Duquesne Light Co to Petition to Intervene of Local 29,International Brotherhood of Electrical Workers. Commission Requested to Deny Local 29 Petition to Intervene. with Certificate of Svc ML20195H3881999-06-0303 June 1999 Petition to Intervene of Local 29,Intl Brotherhood of Electrical Workers in Matter of Firstenergy Nuclear Operating Co,Pennsylvania Power Co & Duquense Light Co.With Certificate of Svc L-98-067, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds1998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds ML20198P9311997-11-0707 November 1997 Comments of American Municipal Power-Ohio,Inc.NRC Should Require Allegheny Power Sys,Inc to Affirm That Capco Antitrust License Conditions Will Be Followed ML20149E3241997-07-0808 July 1997 Comment on Proposed Regulatory Guidance Re Implementation of 10CFR50.59.Efforts of Nuclear Energy Inst Supported by Util ML20141A7171997-06-18018 June 1997 Comment Opposing Proposed NRC Bulletin 96-001,suppl 1, Control Rod Insertion Problems, Published in Fr on 970520. Insufficient Justification Exists to Warrant Requested Actions ML20138E0341997-04-23023 April 1997 Comment Supporting Revs to General Statement of Policy & Procedure for Enforcement Actions.Util Does Not Understand How Investigation Rept Is to Be Edited in Order to Protect Privacy of Individual ML20136E7311997-03-0303 March 1997 Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs ML20134L3401997-01-22022 January 1997 Resolution 96-R-85, Resolution Supporting Merger of Centerior Energy Corp & Ohio Edison Under New Holding Co Called Firstenergy ML20134N2011996-11-11011 November 1996 Comment Supporting Proposed Rev 2 to Regulatory Guide 1.160 Monitoring the Effectiveness of Maint at Npps ML20134N2811996-11-11011 November 1996 Comment Supporting Draft Supplement 3 to NUREG 0654/FEMA REP 1 ML20128M5851996-10-0404 October 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116G9151996-08-0202 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mods to Fitness-For-Duty Program Requirements ML20112H9241996-06-10010 June 1996 Suppl to Comment 4 Opposing Proposed Rule 10CFR50, Reporting Reliability & Availability Info for Risk- Significant Sys & Equipment ML20097G8991996-02-12012 February 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Which Would Amend Emergency Planning Std in 10CFR50.47 ML20095D9351995-12-0707 December 1995 Comment on Proposed GL, Boraflex Degradation in SFP Storage Racks. Util Suggests That Words as Well as Future Projected Be Deleted from Stated Sentence ML20086M8391995-07-11011 July 1995 Comment Supporting Proposed Generic Ltr Re Process for Changes to Security Plans W/O Prior NRC Approval ML20086L0661995-07-11011 July 1995 Comment Supporting Pr 10CFR50 Re Changes in Frequency Requirements for Emergency Planning & Preparedness Exercises from Annual to Biennial ML20085M0171995-06-13013 June 1995 Comment Supporting Proposed Rule 10CFR2, Petition for RM; Procedure for Submission ML20081G9151995-03-15015 March 1995 Comments on Draft Reg Guide DG-8012, Instruction Concerning Risks from Occupational Radiation Exposure ML20078A0491995-01-12012 January 1995 Comment on NUREG-1122,rev 1 Re Technical Catalog for Nuclear Power Plant Operators Who Operate PWR Reactors ML20078R3371994-12-0909 December 1994 Comment Supporting Proposed GL Re Reconsideration of NPP Security Requirements for Internal Threat ML20077F7341994-11-10010 November 1994 Comment Supporting Proposed Rule 10CFR20 Re Frequency of Medical Exams for Use of Respiratory Equipment.Medical Determination Prior to Initial Fitting of Respirators Needed for New Workers Due to Unfamiliar Medical Histories ML20072K3681994-08-0909 August 1994 Comment Opposing Proposed Rule Change for 10CFR26 Re Consideration of Changes to fitness-for-duty Requirements. Util Suggests NRC Retain Current Scope of 10CFR26 as Is ML20070H6791994-07-13013 July 1994 Comment Supporting Proposed Rulemaking 50-59 Re Virginia Power;Filing of Petition for Rulemaking ML20071N4751993-11-29029 November 1993 Comments on Proposed Rule Re Commission Trial Program to Allow Public Observation of NRC Enforcement Conferences ML20044E2781993-05-13013 May 1993 Comment Supporting Petition for Rulemaking PRM-50-58 Re VEPCO Petition to Change Frequency of Emergency Planning Exercise from Annual to Biennial ML20105C9481992-09-15015 September 1992 Comment Supporting Proposed Rev to 1983 Staff Technical Position on Radwaste Classification, Technical Position on Concentration Averaging & Encapsulation ML20099E1871992-07-24024 July 1992 Comment Supporting Proposed Rules 10CFR20 & 61 Re LLW Shipment Manifest Info & Reporting ML20101T6101992-07-10010 July 1992 Comment Supporting Proposed Rule 10CFR50 Re Receipt of Byproduct & SNM ML20055F4251990-07-0202 July 1990 Comment Opposing Petition for Rulemaking PRM-50-55 Re Petitioner Request That NRC Change Requirement That Nuclear Power Plant Licensees File Revs to Final FSAR No Less Frequently than Annually ML20206M8071988-11-28028 November 1988 Comment Opposing Proposed Rule 10CFR26 Re Random Drug Testing Provision in Fitness for Duty Program.Local 142 Members Can Accept & Work Under Fitness for Duty Program That Contains Only Just Cause Drug Testing Provision ML20195J3381988-11-28028 November 1988 Comment Opposing Proposed Rule 10CFR26 Re Random Testing Provision of Fitness for Duty Program.Members of Local 142 at Plant Can Accept & Work Under Fitness for Duty Program That Contains Only Just Cause Drug Testing Provision ML20195J3521988-11-28028 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Local 142 Members Opposed to Proposed Random Drug Testing.Supports Just Cause Drug Testing Provision ML20206F9951988-11-16016 November 1988 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Program.Opposed to Random Drug Testing Provision to Be Included in Program ML20206G0021988-11-16016 November 1988 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Program.Opposed to Random Drug Testing Provision to Be Included in Program ML20206F9761988-11-16016 November 1988 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Program.Opposed to Random Testing Provision to Be Included in Program ML20206F9501988-11-16016 November 1988 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Program.Opposed to Random Drug Testing to Be Included in Program ML20206F7121988-11-16016 November 1988 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Program.Opposed to Random Drug Testing Provision in Program 1999-09-30
[Table view] Category:PLEADINGS
MONTHYEARML20212G0661999-09-23023 September 1999 Answer of Duquesne Light Co Opposing Petition to Waive Time Limits & Suppl Comments of Local 29 Intl Brotherhood of Electrical Workers.* Request That Commission Deny Request for Leave to File Untimely Comments.With Certificate of Svc ML20212C5611999-09-21021 September 1999 Answer of Firstenergy Nuclear Operating Co & PPC in Opposition to Petition to Waive Time Limits & Suppl Comments of Local 29 Intl Brotherhood of Electrical Workers.* with Certificate of Svc ML20212B3361999-09-16016 September 1999 Petition to Waive Time Limits in 10CFR2.1305 & Supplemental Comments on Local 29,Intl Brotherhood of Electrical Workers.* Local 29 Does Not Believe FENOC Can Safely Operate Facility If Positions Eliminated.With Certificate of Svc ML20196F1911999-06-23023 June 1999 Reply of Local 29,Intl Brotherhood of Electrical Workers.* Requests That Commission Deny Answers of Dl & Firstenergy Nuclear Operating Co & Grant Local 29 Petition to Intervene as of Right.With Certificate of Svc ML20078R8721983-11-0909 November 1983 Response Opposing Rf Walker Re NRC 830720 Response to Initial Pleading in Proceeding.Ltr Does Not Supply Good Cause for Untimeliness or Acceptable Contentions.Certificate of Svc Encl ML20080D2071983-08-26026 August 1983 Request for 15-day Extension to Respond to Amends &/Or Suppls to Petitions.Time Needed Due to Jewish Holidays. Certificate of Svc Encl ML19210E1331979-09-29029 September 1979 Petition to Intervene in Licensing Proceeding.Objects to NRC Policy of Charging Nonprofit Groups for Matls Provided by NRC ML19289F4041979-04-10010 April 1979 Amend to PA Public Utils Commission 790402 Petition to Intervene & Request for Hearing.Certificate of Svc Encl ML20244A5561979-03-31031 March 1979 Answer to NRC 790313 Order to Show Cause.Will Reanalyze Seismic Loads on Piping Sys & Will Modify Sys Where Necessary.Expects to Submit Documented Results by 790424. Believes NRC Should Examine S&W Analyses ML19329D0201974-08-0505 August 1974 Responds to Aslb'S Request for Clarification of Contentions in ASLB Prehearing Conference Order 2. Certificate of Svc & Ltr to Counsel from O'Brien & Gere Engineers Encl ML19329C6461974-03-29029 March 1974 Motion of City of Cleveland to Quash Subpoenas & Application for Subpoena in Event Motion Denied 1999-09-23
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Text
g UNITED STATES OF AMERICA gg ::::
NUCLEAR REGULATORY COMMISSION q, In the Matter of ) g2
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) Docket No. 50-334 a -
DUQUESNE LIGHT COMPANY OHIO EDISON COMPANY PENNSYLVANIA POWER COMPANY
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9 Unit No. 1)
LICENSEE'S ANSWER TO ORDER TO SHOW CAUSE 1
On March 13, 1979, the Director of the Office of Nuclear Reactor Regulation issued an Order to Show Cause to Duquesne Light Company, Ohio Edison Company and Pennsylvania Power Company (Licensee) relating to the seismic '
design of certain piping systems at Beaver Valley Power Station, Unit No. 1.
The order requires Licensee to show cause:
(1) why Licensee should not reanaly'ze those facility piping systems which were analyzed by a computer code using an algebraic summation of the loads predicted separately for the horizontal and vertical ,
components of seismic events, such reanalysis to be performed using an appropriate piping analysis computer code which does not combine loads algebraically, (2) why Licensee should not make any modifications to the facility piping systems indicated by such reanalysis to be necessary, and (3) why facility operation should not be suspended pending such rea+41ysis and completion of any required modifications. The order furthec.
required that Unit No. 1 be placed in cold shutdown condition within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of receipt of the order by Licensee and that the facility remain in such mode until further order of the Commission.
In response to the three issues on which Licensee is ordered to show cause, Licensee answers as follows:
- 1. Why the Licensee should not reanalyze the facility piping systems for seismic loads on all potentially affected safety systems using an appropriate piping analysis computer code which does not combine leads algebraically.
The Licensee will reanalyze the seismic load for affected facility piping systems using an appropriate piping analysis computer code which does not combine loads algebraically.
- 2. Why the Licensee should not make any modifications to the facility piping systems indicated by such reanalysis to be necessarv.
Licensee will make any modifications to the affected facility' piping systems which it determines to be necessary based on the analysis.
- 3. Why facility operation should not be suspended pending such reanalysis and completion of any required modifications.
Licensee-has undertaken the program discussed below for reanalysis of the affected piping systems. Upon completion of the reanalysis of, and Y
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(2) any necessary modifications to the affected piping systems required to assure safe shutdown capability and the capability of affected piping systems associated with the Engineered Safety Features'and the Emergency Core Cooling System, we request that the facility be permitted to resume operation pending completion of reanalysis of the balance of the affected piping systems and any necessary modifications of the remaining affected piping systems.
Reanalysis of piping stress (with a code which does not use an algebraic summation technique) and evaluation of supports in those piping runs, which were originally analyzed using an algebraic summation technique and which are part of systems necessary to assure safe shutdown, and the operability of engineered safety features, or emergency core cooling, are being conducted on a 2 shift per day (10 hrs / shift) basis.
As of March 30, 1979, 66% of the pipe stress computer runs were completed.
The remaining runs should be completed by April 3, 1979. Of the completed runs, 90% are acceptable and 10% are presently undergoing reanalysis.
As of March 30, 26% of the pipe support design reviews were completed.
Of the completed pipe support design reviews, 63% are acceptable, 28%
are presently undergoing further evaluation and 9% are undergoing detailed analysis, as applicable. Completion is scheduled for April 20, 1979.
Related design reviews of equipment associated with these piping systems should also be completed by April 20, 1979.
Assuming the same rate of progress as recently experienced, we expect to submit documentation of the results to the NRC starting on April 10 and continuing to completion on April 24, 1979.
In accordance with the requirements of 10 CFR 2.202(b), Attachment A hereto sets forth Licensee's admission or denial of the allegations and charges made in the order.
The NRC order temporarily suspending operations was issued in the absence of sufficient information to assess the seismic design capabilities of the affected piping systems. We believe it is incumbent upon the NRC, however, to consider and evaluate the engineering analyses and data being developed by Stone and Webster. NRC should determine on the basis of that information whether there is a sufficient threat to the public health and safety to warrant the drastic step of a further order continuing the shutdown of Unit 1 pending the reanalysis and possible modification of all affected piping systems regardless of their importance to the public health and safety.
DUQUESNE LIGHT COMPANY
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By tw ; // . 4 6 2 ~
/ Stanley p. Schaf fer,/
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? . ,J Specific Answer to Each Allegation # ,,3 L or Charge in the Show Cause Order S[SC g h
Paragraph I is admitted.
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,M*, T", n Paragraph II, first sentence is admitted to the extent that ensee" i filed a Licensee Event Report, LER 78-53, indicating that the. -
' re two /
piping systems for which stress computations had M t been comp *>
go a piping analysis computer code.
With respect to Paragraph II, third sentence, it is admitted that, in.the course of reanalysis, discrepancies were observed between the original computer code used to analyze earthquake loading for certain facility ;
piping systems and a currently acceptable code (P Stress and the related algebraic summation subroutine, and NuPipe. respectively).
Paragraph II, fourth sentence is admitted.
Paragraph II, fifth sentence, the Licensee is without sufficient knowledge to admit or deny.
Paragraph II, sixth sentence, is admitted to the extent that ,
algebraic summation without time history analyses can, in certain cases, yield lower calculated stresses than those calculated using techniques such as the square root of the sum of the squares. !
Paragraph II, seventh and eight sentences are admitted to the extent that current industry practice accounts for the effects of earthquakes by combining intramodal forces absolutely, or using techniques such as the square root of the sum of the squares, but it is denied that General Design Criterion 2 specifically requires these load combination techniques.
Paragraph II, ninth and tenth sentences, are admitted to the extent that the algebraic summation technique can become significant for piping runs for which the horizontal seismic component can have both horizontal ,
and vertical components on piping systems and the vertical seismic component also has both horizontal and vertical components, and that in i such runs, the calculated earthquake loads may differ from those calculated using techniques such as absolute combination or the square root of the sum of the squares.
Paragraph II, eleventh sentence, is admitted to the extent that '
although the greatest differences in predicted loads would tend to be limited to localized stresses in pipe supports and restraints or in weld attachments to pipes, there could be areas of higher than originally calculated stress in piping as well as areas in which there is potential for damage to adjacent restraints or supports, which could affect the ,
ability of the piping system to withstand seismic events. !
I Paragraph II, twelfth sentence is admitted to the extent that members of the NRC staff on March 10, 11 and 12 accompanied the Licensee's representatives to the offices of Stone & Webster, the architect-engineer of the facility, to review detailed designs and computations for some of the piping systems of principal potential concern to the staff.
Paragraph II, thirteenth sentence is admitted.
Paragraph II, fourteenth and fifteenth sentences are conclusions drawn by the NRC staff, and therefore do not require an answer.
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COMMONWEALTH OF PENNSYLVANIA) 1
) SS: .
COUNTY OF ALLEGHENY- ) .
On this 31st day of March, 1979, before me, Donald W. Shannon, {
a Notary Public in and for said Commonwealth and County, personally appeared S. G. Schaffer, who being duly sworn, deposed, and said that (1) he is President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, { '
and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge, information and belief.
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1 DONALD W. SHANNON Notary Public Pittsburgh, Allegheny Co.. Pa.
)!y Commission Empires June 7,1979 l
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