NRC-2011-0204, Comment (12) Donald Harrison, on NRC-2011-0204-0001, Proposed Generic Communication; Draft NRC Generic Letter 2011-XX: Seismic Risk Evaluations for Operating Reactors

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Comment (12) Donald Harrison, on NRC-2011-0204-0001, Proposed Generic Communication; Draft NRC Generic Letter 2011-XX: Seismic Risk Evaluations for Operating Reactors
ML11301A103
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 10/24/2011
From: Harrison D
- No Known Affiliation
To:
Rulemaking, Directives, and Editing Branch
References
76FR54507 00012, NRC-2011-0204-0001
Download: ML11301A103 (1)


Text

Page 1 of I As of: October 25, 2011 Received: October 24, 2011 PStatus: PendingPost PUBLIC SUBMISSION Tracking No. 80f5ab53 eComments Due: October 31, 201 1 Submission Type: Web Docket: NRC-2011-0204 Proposed Generic Communication - Draft Generic Letter on Seismic Risk Evaluations for Operating Reactors Comment On: NRC-2011-0204-0001 Proposed Generic Communication; Draft NRC Generic Letter 201 1-XX: Seismic Risk Evaluations for Operating Reactors Document: NRC-2011-0204-DRAFT-0012 Comment on FR Doc # 2011-22422 Submitter Information -

Name: Donald Harrison .

Address: ,] .[-

10423 Church Hill Road .

Myersville, MD, 21773 o, General Comment This may be a repeated comment related to the North Anna observation, as the system crashed twice while trying to input this comment (if so, please use this as the latest complete comment regarding this topic).

The results from the North Anna event primarily appear to resemble the old spectral shape/model, just higher than their SSE. This event, may actually show the new reactor performance-based model is less correct than the old model and thus not appropriate as being required to be addressed by the current plants licensed using the old model.

Also, the new model peaks in the high Hz range where relay chatter is most important, an issue pretty much resolved by the industry since the IPEEE days, but it is lower than the old model in the lower Hz range where component and structure issues are more prevalent. On this basis, if the new model is eventually proven wrong, with the North Anna event evidencing that potential fact, then it may make the use of the new model inappropriate and potentially non-conservative in the critical frequency ranges if imposed on the current operating plants.

The NRC should evaluate the results of the North Anna earthquake closely and determine if the spectral shape more appropriate reflects current guidance versus requiring the use of a new reactor model that is not reflected by most of the data from the current event.

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