ML19350C807
| ML19350C807 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/06/1981 |
| From: | Thiruvengadam CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML19350C792 | List: |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8104060729 | |
| Download: ML19350C807 (10) | |
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- UNITED STATES OF AMERICA [
NUCLEAR REGULATORY COMMISSION ed . . - 2 4 %N # 'T2,
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d StcM ATOMIC SAFETY AND LICENSING BOARD 'I' . '
Charles Bechhoefer, Chairman D ,,. J "f.go$ senk3 d Dr. Frederick P. Cowan # \
Gustave A. Linenberger k[ e, P
In The Mutter Of ) Docket Nos. 50-239 OM
) 50-330 OM CONSUMER POWER COMPANY )
) Docket Nos. 50-239 OL (Midland Plant, Units 1 and 2)) 50-330 OL STATE OF MICHIGAN )
) SS.
COUNTY OF JACKSON )
AFFIDAVIT OF THIRU THIRUVENGADAM I, Thiru Thiruvengadam, being first duly sworn, do state that I am of lawful age and that the statements in the attached affidavit are true and correct to the best of my knowledge and belief.
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Thiru Thiruvengadam SUBSCRIBED AND SWORN TO before me this 6th day of March , 1981.
AA MAYA k-NotargPublic'F 810 40 607J4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Charles Bechhoefer, Chairman Dr. Frederick P. Cowan
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Gustave A. Linenberger .
In The Matter Of ) Docket Nos. 50-239 OM
) 50-330 OM CONSUMERS POWER COMPANY )
) Docket Nos. 50-239 OL (Midland Plant, Units 1 and 2)) 50-330 OL AFFIDAVIT OF THIRU THIRUVENGADAM My name is Thiru Thiruvengadam. I am employed by Consumers Power Company as Section Head, Civil Engineering, Midland Design-Production Department. In this job I am responsible for reviewing, as necessary, the civil / structural aspects of the soils remedial work at Midland, including overseeing the development of the site specific response spectra (SSRS) and-seismic review of the Midland plant described in this affidavit.
I have held my present position since May 1980.
From November 1978 until May 1980 I was a staff engineer in Consumers Power Company's Project Engineering, Services Department.. Prior to. November 1978 I was employed as a structural engineer by Bechtel Corporation, and' prior to that as a senior structural analyst at Sergeant & Lundy. I
!have a B.E. in' Civil' Engineering from the UniversityLof
, Madras, India, an M.E. in Power Engineering from the Indian L __
Insitute of Science at Bangalore, India, and a Ph.D. in i Civil Engineering (Major: Structures and Minors: Soil Mechanics and Foundation Engineering and Theoretical and Applied Mechanics) from the University of Illinois in Champaign-Urbana, Illinois.
As a result of this work experience and education, I am familiar with the facts concerning the review of seismic issues of the Midland plant, and I believe I am qualified to express the professional opinions set forth in this affidavit.
The construction permits for the Midland plant were issued in 1972, prior to the effective date of 10 CFR Part 100, Appendix A. The maximum or design basis earth-quake for the site approved at that time was represented by modified Housner spectra anchored at 0.12g.1/ Since then the analysis of structures, piping, and safety-related
-equipment at Midland has proceeded on the basis of that approved seismic input.
f 1/ A response spectrum is a plot of the maximum response (acceleration, velocity or displacement) of a family of idealized single-degree-of-freedom damped oscillators as a function of natural frequency (or period) of the oscillators to a specified vibratory motion, such as an earthquake record. A design response spectrum is obtained by analyzing, evaluating and statistically combining a number of individual response spectra derived from the records of significant past earthquakes. One L
of the important paramters in describing an earthquake is the maximum . (peak) ground acceleration (PGA) specified for a given site. In design response spectra, the PGA o
is the acceleration at zero period. For Midland construction permits the approved PGA at zero period'was 0.12g, where "g"~is the acceleration due to gravity. The shape of response spectra approved at the time the Midland construction permit was a modified version of one published by Dr. G.~W. Housner. Subsequently, in 1973, Regulatory Guide 1.60 was issued which specified a different shape which is acceptable to the NRC for the design response. spectra.
In the Final Safety Analysis Report submitted in 1977 to the NRC in connection with the operating license proceedings, the Midland site was identified as being located in Michigan basin, a separate tectonic province with low
. seismicity. Beginning in 1978, a series of NRC Staff FSAR technical review questions indicated that the Staff was reluctant to accept Applicant's subdivision of the larger Central Stable Region into smaller tectonic provinces, such as the Michigan basin. Identification of the appropriate tectonic province for the Midland site is important because under 10 CFR Part 100, Appendix A, this choice leads to the identification of a design basis earthquake (10 CFR Part 100, Appendix A terminology, a Safe Shutdown Earthquake, or SSE).
In particular, selection of Central Stable Region as the appropriate tectonic province could lead to a different SSE than the 0.12g design basis earthquake approved at the construction permit stage.
Applicant provided' responses to the NRC Staff's questions; however, in a meeting in July 1979, the NRC indi-
.cated-that Applicant's justification of the Michigan basin as a separate tectonic province. remained unpersuasive to them. At that time, the NRC Staff orally suggested that Applicant follow a site-specific response spectra approach to ' the methodology for determinir.g an appropriate seismic input for the plant, similar to that TVA used for the Sequoyah nuclear plant. The first NRC written communication on that subject was through a letter dated October 14, 1980.
In a letter of that date, Robert L. Tedesco of the NRC offered Consumers Power Company two alternatives for establishing
" acceptable seismological input parameters." (Att chment A).
The first alternative was to define the acceptable response spectra as the standardized response spectra of Regulatory Guide 1.60 anchored at 0.19g.
The second alternative in the October 14, 1980 Tedesco letter was to construct a site specific response spectra for the Midland Plant. Consumers Power Company has been pursuing that option, although we have not conceded that the desigt. basis of the Midland plant approved at the construction permit stage is inappropriate, or that the Michigan basin is not a separate tectonic province.
Carrying out a seismic review of the Midland plant with site specific response spectra as the input is a time-consuming process which may take up to two years to complete.
The first step is assembling a data set of representative real time histories of earthquakes at various locations
.around the world. The October 14, 1980 Tedesco letter specifies'that these real time hist'ories should be for earthquakes whose magnitudes fall within the' range of
!- 5.31.5MbLg recorded at epicentral distances of less than l~ 25 kilometers at' sites with local site. conditions similar to Using.those real time histories one can
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Midland plant site.
ge$eratesitespecificresponsespectrafortheMidlandsite by dynamic analysis and appropriate statistical processing.
Following the identification of the appropriate SSRS, carrying out a seismic review requires the construction of a dynamic structural model of the plant structure and foundations, which among other things, will reflect the proposed remedial work, including for example the caissons to be placed under the auxiliary building. The dynamic model and the SSRS are used to carry out structural response analyses which will provide information to determine the ability of plant structures to withstand the seismic loads obtained using the SSRS as the input. In a parallel analysis, a synthetic time history (acceleration as a function of time) is derived to match the SSRS. This synthetic time history and the dynamic model are used to generate floor response spectra at several floor levels, which will provide information to check the ability of equipment, piping and electrical systems to withstand the seismic forces so produced.
On March 2, 1981, Consumers Power Company sub-
.mitted to the NRC E SSRS applicable at the original ground surface of the Midland' site, developed by its consultant, Weston Geophysical Corporation. In April, 1981, Applicant will submit Part II of the Weston Geophysical report, con-taining SSRS applicable at the top of the fill. The NRC Staff have stated that it would be appropriate to have a-meeting with the. Staff one month after the submittal of the L1. -
b report to discuss the contents. A similar NRC Staff response time is expected for Part II of the raport. While I believe that the NRC Staff has diligently pursued the review of Applicant's seismic submittals since the October 14, 1980 letter, I do not believe that the staff will have the time to finish its review and approval of all three parts of the Weston report before June 1981. Moreover, review and approval of the SSRS is only the starting point. Seismic review of the structures, equipment, piping and electrical systems affected by the remedial measures using the SSRS input will take months. In my opinion, this review cannot be completed 'in time for the soils settlement heari ys this year.
It is important for the Licensing Board to recog-nize that the changes in foundations involved in the proposed remedial work will influence the seismic review of the supported plant structures, equipment, piping and electrical
! systems.- A separate review of the remedial fixes for a l
revised seismic input _ would at best provide limited informa- -
tion. -Such separate treatment would result in an inappro-priate use of design ~and analytical resources, both on the
- part of Applicant and the NRC Staff, and would thus be inefficient.
Because of the present unavailability of'an approved seismic. review criteria for Midland, Consumers Power. Company is incorporating a margin into the designs
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I of caissons and other proposed soils remedial work. This margin is obtained by designing the proposed remedial fixes with a reasonable margin over FSAR seismic criteria (i.e. modified Housner spectra anchored at .12g). This design margin applies only to remed i al work and not to all plant. structures, equipment, piping, and electrical systems which may be supported by the remedial work.
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&[kl 1945 iles: Parnell Roac Jacksca, Michigan U2:1
Dear Mr. Cost:
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Cnc Of the open itas asso:iated witn car radicic;tcal safe:y review cf g.r application for operating licenses for Midlar.d Plan:, Units 1 an: 2, ar.:
identified in car letter of Mar:h 23,1979, is :ne establish en: ef aca:ut;e seisrclogical input parareters. Resolution of tms open itec is aitc r.e essarf for approval of tne re edial actions ass:ciated with tne scils sct:le in:
r4 ur wnich was the subject of the Dece:ber 6,1979 Or.ser cr. P.::ifica:ir,n of -
Constrx:icn Perntts.
As n::e: in y03r response to cur previous re:#2::s 51.2, 'sil.c, >51..; :.r.:
261.7, you consicer the Hi:higan Basin to be a cistin:: uctor.ic pr:.in:e for the purpose of evaluating si:e seistic design input, wnereas during tr.e Midia,:
C'. revie,e, the staff has fcanc insufficient support tr,a t*e Centra! Sta:ie Regicn . an be suodivice: into separate te::enic crovir.:es. Tcur apr;.htn .isir.;
hist:ric seisticity in the Michigan Basin resul:cd in a Safe Sna:d:r.n Earth-quate (SSE) characterized by Modifiac Her:alli Intenst:y (.mi) of U, and a M::ifiec :Wsner respcnse spectra anchored at 3.12g. Discussed te'c.t u :ne staff's curr:nt view as to two acceptable asproactes, eitner of which su:ifies the con: rolling earthquake from the Central Stable Repos a. f .Mch aisc re-quires consideration of soil arplifica:icn.
The controlling earth:uake w would currently re:uire to be use: in dater =n-ing the SSE for the Kiciand site is sirilar to t>.at which c:: gree: it. Tem, O'.io in !;&rcn 1937, and has a body wave ragnitude of 5.3 M,. ,. at: a mi of Vli-M:2.
ht:li, (State-of-tne-Art for iissessing Eartn:uaic HaD?:s in nc Unia: 53%
P.esor: 12, Credible Earth:uakes for the Central fJ. S.: Misc. ? w S- E -1 U. L Arry ingineering k'sterways Experirent Sta: ion,1975) using an al.ec.anve rc hc: has also suggested this magnitude as the 'raxic.u ' wnen ts:n; rast:2!
events (th:se rer.aining after seiscic zones su:h as I na, t: ash ta;iey, an.
are recoved) for the Central United States. It is iccorur.: to note it.at t'.e July 29, 1950 Kentucky earthquake had a magnitude of 5.1-5.4 P g'.7 an:
occurred in a " residual area". -
The following alternatives of characterizing the SSE waald de acr.epu::e a the staff and are consistent with the staff's Stancars Review Pian fi:.?)
Se: tion 2.5.2:
ATTACHMENT A 96 0 g Solo 2&OM 1 fog / ppg)
,r.r. J. 'n'. Cook ,
ine Ar.na Ch:o e6rth:;une of Mar:h 9.1937 is the largest historic eartt.- '
quake in tne Centrai Stable Fagion tectonic province. Inis earthnate nad a W.I Of vil-YI!! ant sno.ild be assuae: to o: ur near the site (Appendu A to 10 CFR Part 100, SV Section 2.5.2}. Usin; tais inten-sity one acceptabic ap;rs:en w:uld be based upon the stancarcize res:cr.se spectra of Regulate y Guice 1.60 anchored at 0.193 as deter:inec n the trena of tne reans of tne intensity acceleratica values in irifuna: anc Brady (Seis:ulogical Se:iety of Aaerica Sull., Y. 65,1975).
An alternative retho hf describing the SSE.ar.d response spectra result-ing fr;: an A".na" type earth uate assmed to oc:or near tne site ir.volves using the nagnitude. As was ir.dicated during the recent M rev;e> c Sequoyar., n;nitsee may be a ecre realistic estizcte of earthqwite si:e than intensi ty. T:>arefers a des:ription of the SSE can also de o:taine: W cellecting re;reser.tative real time nistsries for a magnitude of
, ep):entrai distantes less than 25 kilometers at scii si*.es.
5.3 + .5 Fydtion Su:n a col' nas been r:ade by Lawrence livemore Laboratory (tit.
Draft. Seisri: Hazard Analysis: Site Specific Paspo .se Spectra Results.
/.aust 23,1979) but it would be beneficial if you update this cita set as appropria te. It is the staff's position that the representati:n appropri-ate for use in establishing the SSE is the 84th percentile of the response spectra as derived directly froc the real time histories.
Ibe input for the to.sarative analysis cf ycur present response ste:tra (Mcdtfiec Housner) and Regulatcry Guide 1.60 both anchored at 3.129 was at the foundatien level. It-is our conclusion that the appropriate locatica fcr
' vibratory ground r.stior. inpo: for year Midland site be at tr.e top of the A3xe natural glacial till (essentially the criginal regional grec.d surface).
l this till is a thin sans layer @.ich is highly variante in density t.t tne co -
pacted fill that was placed to raise plant grade. Therefore either cf car above acceptable apptcaches will also require an assessment of soil a:;1ifica .
tion fro: the till surface.
i We are available to reet with you at your earliest otr;:rtunity to discuss the above apprca n in orcer that acceptable data and ruthocs of teseribin.: vitre-tcry ground cotien can be utilized for the Midland site.
Contact our proje:t rana;er. Darl H od, if you wish to arrange such a aee:ing l
or desire clarification of this letter.
Sincerely, h kW R:ter: L. Tedes:o
- Assistant Director for Liceraing Division of Licensing i- cc: See.next page
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t UNITED STATES OF AMERICA H y E
NUCLEAR REGULATORY COMMISSION j7 2d "
2,'
Before the Atomic Safety and Licensing M
Board Q 0,,
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In the Matter of ) Docket Nos. 50-329-OL
) 50-330-OL CONSUMERS POWER COMPANY ) 50-329-OM
) 50-330-OM (Midland Plant, Units 1 and 2) )
)
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance on behalf of Consumers Power Company in the captioned matter. In accordance with S2.713 of the Commission's Rules of Practice, the following information is provided:
Name: Philip P. Steptoe Address: 'Isham, Lincoln & Beale One First National Plaza Suite 4200 Chicago, Illinois 60603 Telephone: 312/558-7500 Admission: Supreme Court of Illinois Supreme Court of Virginia United States District Court for the Nrrthern District of Illinois
(* e DATED: March 18, 1981 *
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Philip P. Steptoe One of the Attorneys for-Applicant
I 3/18/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSICN ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket Nos. 50-329 OM
) 50-330 OM CONSUMERS POWER COMPANY )
) Docket Nos. 50-329 OL (Midland Plant, Units 1 and 2)) 50-330 OL CERTIFICATE OF SERVICE I, Philip.P. Steptce, one of the attorneys for Consumers Power Company, certify that ccpies of " Applicant's Motion to Defer Consideration of Seismic Issues Until the Operating Licensing Proceeding," with attached affidavits of Thiru Thiruvengadam and James W. Cook, have been served in the above-captioned matter on the following by depositing the same in the United States mail, first class postage prepaid, this 18th day of March, 1991:
Frank J. Kelley, Esq. Charles Bechhoefer, Esq.
Attorney General of the Atomic Safety & Licensing Bd. Pnl.
State of Michigan U.S. Nuclear. Regulatory Comm.
Stewart H. Freeman, Esq. Washington, D.C. 20555
--Assistant Attorney General Gregory T. Taylor, Esq. Dr. Frederick P. Cowan Assistant Attorney General -6152 N.. Verde Trail Environmental Protection Div. Apt. B-125 720 Law Building Boca Raton, Florida 33433
- Lansing, Michigan 48913 L Admin. Judge Ralph S. Decker Myron M. Cherry, Esq. . Route No. 4, Box 190D One IBM Plaza. Cambridge, Maryland 21613 Suite 4501 Chicago, Illinois 60611 Carroll E. Mahaney.
Babcock.& Wilcox Mr. Wendell H. Marshall P. O. Box 1260
- RFD 10 Lynchburg, Virginia 24505 Midland, Michigan 48640 James E. Brunner, Esq.
Steve.Galdler, Esq. . Consumers Power Company
- 2120 Carter Avenue 212 West Michigan Avenue St. Paul,~ Minnesota- 55108 Jackson, Michigan 49201~
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Atomic Safety & Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
. Mr. C. R. Stephens Chief, Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commissioit Washington, D.C. 20555 Ms. Mary Sinclair 5711 Summerset Street .
Midland, Michigan 48640 William D. Paton, Esq.
Counsel for the NRC Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Barbara Stamiris 5795 North River Road Route 3 Freeland, Michigan 4862?
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Philip P./Steptoe 4
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