ML19294A908
| ML19294A908 | |
| Person / Time | |
|---|---|
| Issue date: | 02/08/1978 |
| From: | Rosenthal A NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| To: | Gilinsky V, Hendrie J, Kennedy R NRC COMMISSION (OCM) |
| Shared Package | |
| ML19294A895 | List: |
| References | |
| TASK-TF, TASK-TMR SECY-79-88, NUDOCS 7905080163 | |
| Download: ML19294A908 (2) | |
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%....[.J ENCLOSURE 3 February 8, 1978 MEMORANDUM FOR:
Chairman Hendrie Commissioner Gilincky Commissioner Kennedv i
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Commissioner Bradford r
FROM:
/' Alan S.
Rosenthal, Chairman i
Atomic Safety and Licensing Appeal Panel i.
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SUBJECT:
STAFF NOTIFICATION TO BOARDS OF RELEVANT h.~
AND MATERIAL NEW INFORMATION i
e I endorse the recommendation contained
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February 1,
in Mr. Yore's 1978 memorandum as constituting a sufficiently F t-reasonable accommodation of the interests of all concerr.ed to warrant beina out into effect on a six-month trial basis.
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In this connection, it seems to me to make especially good t
sense not to burden the adjudicatory boards with copies of correspondence and other material generated orior to the 1
submission of the I,'
ability report and suoplementfinal environmental statement, site suit-i No. 1 to the safety evaluation report.
A board should be able to assume -- at I
least in
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the absence of a soccific claim to the contrary -- that those documents missions such as the SER(taken together with the other formal sub-i' itself) all pertinent disclosures during the course ofhave come to grips with i
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the staff reviaw.
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Should Mr.
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Yore's recommendation be accepted,
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Panel will use the Appeal i
the trial period to monitor closely the i'
volume and content of the correspondence and other docu-j l'
mentation supplied to the adjudicatory boards during what i
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Mr. Yore has referred to as the "second period".
Our pur-pose will be to ascertain, inter alia, the extent to which in practice the new reporting procedures actually j
(1) serve to provide the boards with information having a discernible bearing uoon questions appropriately subject to adjudication in a licensina proceeding; and (2) tax the no.* available resources of the Appeal F*t f.
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. trial period, the ccmmission will be fornished with the t-Appeal Panel's judnment respecting bcth the efficacy of those procedures and our need, if any, for further technical
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personnel or docket room space
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additional material.
to scrutinize and house the 6
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Commission.
February 8, 1978 I would ad1 only my hope and expectation that the staff will exercise some restraint in its imolementation of the new reporting procedures.
Beyond doubt, there will be correspondence or other documents passino between the staff and applicant with resnect to a particular permit or license application in adjudication which cuite obviously could have no possible relevance to any issue which had been or might be raised in the course of the proceeding.
The like-lihood that the new procedures will accomplish their intended objective -- and that time and resources will not be wasted --
will be substantially enhanced if material in that category is not forwarded to the boards.
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cc:
James R.
Yore Lee V.
Gossick Edson G.
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ENCLOSURE 2 CONTAINMENT BUCKLING CONCERN - EXAMINATION The records in NRR indicate that the January 11, 1978, contractor's progress report on " Buckling Criteria and Application of Criteria to Steel Containment Shell," was received by the staff of the Division of Systems Safety (DSS) on or about that date.
The DSS staff signed a memorandum to the NRR Division of Project Management on January 30, 1978, with a recommendation that appropriate Licensing Boards and the ACRS should be notified. A copy of that transmittal memorandum is provided in Enclosure A.
It did not enter the NRR tracking system for potential Board notification matters until March 7,1978, because of a clerical o
error in DSS. Our files indicate that there was a series of memoranda back and forth among the two NRR Divisions and the staff of the Office i
I of the Executive Legal Director questioning whether the information was
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appropriate for Board notification. These internal memoranda are pro-vided in Enclosures B through G for your information. The questions
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were resolved by the October 31, 1978, memorandum provided in Enclosure G.
Accordingly, ten Licensing Boards were provided with the new infor-
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mation between December 20, 1978, and January 3,1979, along with a brief description of what the information meant, in the staff's opinion, Ii for each particular case.
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The uncertainty in buckling criteria raised by the contractor's report has been included as a topic of concern in ongoing licensing reviews.
For example, see Enclosure H, which is an excerpt from the Allens Creek
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', Cont'd. PSAR that responds to a staff question dated March 24, 1978.
You will also note from Enclosure H, that the January 11, 1978, progress report is not the only source of information indicating uncertainty in what constitutes an appropriate factor of safety against buckling for various load combinations and service limits. The ASME Code,1977 summer addendum, also changed the previous code requirements on the factor of safety for buckling and provided three acceptable methods of analysis for predicting buckling loads.
The question of what constitutes acceptable conservatism to assure f
that buckling won't occur for a particular design is not easily determined from existing standards (e.g., Regulatory Guide 1.57 and the ASME Code). Many factors contribute to the overall assessment
{,j of the conservatism of a design, such as the method of analysis
)i (linear or non-linear), the method of modeling, the " knockdown" factors that reflect the difference between the calculated buckling loads and I j, the actual buckling loads, the character of the loads (static or dynamic),
and the distribution and magnitude of imperfections in the structure. A jn
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factor of safety by itself is meaningless unless it is associated with a t.
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particular method of analysis and associated knockdown factors. Specifying L)I the relationship between the factor of safety and other parameters was one r..
of the reasons for initiating the technical assistance contract awarded
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to International Structural Engineers. The lack of clear criteria for 1
specifying the relationship was also the source of the questions among i.
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i Cont'd. the staff offices between January and October,1978, that delayed the board notification. To put it in different words, it was not clear to the staff whether the first report on progress in clarifying existing requirements was an indication that the requirements were inadequate, and it was not clear that the new information put a new or different light upon an issue before the boards.
To further explain this technical point, we have provided a recent staff memorandum in Enclosure I.
It contains a recommendation that i.
a subsequent draft report from the same contractors should not be forwarded to the Boards at this time pending receipt of the final report due on March 1, 1979. More important, the contractors now recommend a factor of safety of two instead of their previous re-commendation of three.
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((.1 This is not considered by us to be a change of mind, but to reflect u.
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an understanding that the factor of safety by itself is meanirgless J
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unless it is associated with a particular method of analysis. The 4a-management of NRR concurs in the recommendation of Enclosure I for
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4 the reasons stated there. The technical point that the memorandum it-serves to describe is that overall conservatism (margin) against buckling is a complex function of several plant dependent variables i
including the factor of safety multiplied by the knockdown facter.
For the case of pure axial loads, this knockdown f actor could be as 9
. Cont'd.,
large as ten, while the proposed factor in the first draft report was three. As you see, in this case the most important contribution to conservatism would not be the factor of safety, but rather, the knockdown factor which depends, among other things, on the particular method of analysis.
Enclosure J summarizes this point for one of the ten plants for which the Boards were notified of new information on buckling. For that plant, the minimum factor of safety on buckling was calculated to be 3.27, when other sources of conservatism in the model were accounted for.
This value is, of course, in excess of the ASME code requirement or the recommended interim, conservative factor
' b of safety of three in the contractor's progress report of January 11, 1978.
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We believe that this lengthy summary of the containment buckling concern illustrates that decisions as to whether a particular piece of new information puts new or different light on a licensing requirement are
- y not always straightforward. They sometimas require complex engineering evaluations that take time.
3 F.
Enclosures E.*.
TJ A.
Memo for D. B. Vassallo from I. Sihweil dated 1/30/78
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B.
Memo for M. J. Grossman from D. B. Vassallo dated 3/29/78 C.
Note to D. B. Vassallo from M. J. Grossman dated 4/10/78 s-4,.
D.
Memo for M. J. Grossman from D. B. Vassallo dated 4/18/78 t,1; ' '
E.
Memo for M. J. Grossman and R. J. Mattson from D. B. Yassallo r.1 dated 9/28/78.
F.
Note to D. B. Vassallo from J. Scinto dated 10/11/78 I
G.
Memo for T. F. Englehardt from D. B. Vassallo dated 10/31/78
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H.
Allens Creek PSAR, pages K130.21; 3.8-81, a, b, c.
I.
Memo for R. J. Mattson from F. Schauer dated 1/11/79 J.
Ltr to Messrs. Lazo, Hand, & Luebke from E. G. Ketchen dated i_
1/3/79.
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ENCLOSURE A to Coni.ainment Buckling e
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/5N lot UNITED STATES
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NUCLEAR REGULATORY COMMISSION f
k Veslolh W ASHINGTON, D. C. 20555
%, v JAN 3 01973 MEMORANDUM FOR:
D. B. Vassallo, Assistant Director for Light Water Reactors Division of Project Management M ;,\\
J. P. Knight, Assistant Director THRU:
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for Engineering p
Division of Systems Safety FROM:
I. Sihveil, Chief Structural Engineering Branch Division of Systems Safety
SUBJECT:
INTORMATION TO BE PROVIDED TO ACRS AND LICENSING BOARDS (SEB: 001, 002)
I We just received the attached progress report from our consultant that b
questions the current criteria for buckling of steel containment shells.
g We believe that the appropriate licensing boards and the ACRS should be notified.
It should be realized that this report is preliminary in nature and has not been fully evaluated by our branch. We believe it may have an impact on the design of steel contain=ents such as those used for the BWR Mark III and PWR Ice-Condensers.
l h+ G wenL I. Sihveil, Chief Structural Engineering Branch j
Division of Systems Safety
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Attachments: As stated cc w/ encl:
R. Mattson K. Wichman D. Eisenhut SEB Me=hers L. Shao 4 gVLdo 8
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