ML20205Q774
| ML20205Q774 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, 05000000 |
| Issue date: | 09/19/1984 |
| From: | Horin W, Reynolds N BISHOP, COOK, PURCELL & REYNOLDS, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20204J134 | List: |
| References | |
| FOIA-85-59 NUDOCS 8606030298 | |
| Download: ML20205Q774 (24) | |
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... l0 630056 September 19, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-445 and TEXAS UTALITIES ELECTRIC
)
50-446 CCMPANY, et al.
)
)
(Application for (Comanche Peak Steam Electric
)
Operating Licenses)
Station, Units 1 and 2)
)
APPLICANTS' REPLY TO CASE'S ANSWER TO APPLICANTS' MOTION FOR
SUMMARY
DISpOsITIO3 REGARDIN" CONSIDERATION OF FRICTION FORCES I.
INTRODUCTION Utilities Electric Company, g M.
(" Applicants")
Tex 1 hereby suamit their reply to " CASE's Answer to Applicants' Motion for Summary Disposition Regarding Consideration of Friction Forces in the Design of Pipe Supports with Small Thermal Move-ments," ("A.swer") filed Auguct 6, 1984.
The Board authorized Applicants to submit replies to CASE's answers to Applicants' motions for summary dispositien in the August 22, 1984, con-ference all (Tr. 13,995).
As demonstrated below, CASE has failed to demonstrate the existence of a genuine issue regarding the material facts set forth in Applicants' motion.
Accordingly, the Board should render the decision sought by Applicants.
I C-8606030298 860522 h l(Q PDR FOIA l
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GARDE 85-59 PDR g
II.
APPLICANTS' REPLY TO CASE'S MOTION A.
General i
CASE's answer to Applicants' motion fails'to demonstrate the"*~
j existence of a genuine issue regarding any of the material facts set. forth :in Applicants '.. motion.. Thus, under the. usdal ' standard. + *-:.'-
a for granting summ.ary dispositi.on A.pplica.n.ts would.be entitled. to.s judgment as a matter of law (see 10 C.F.R.
$2.749(d)).1 laue Board has, however,' established a more lenient standard j
in this phase of the proceeding for granting summary disposition.
4 2
As the Board noted in its June 29, 1984, Memorandum and Order,
the B_oard intends to ask questions, request briefs or.otherwise l
seek to clarify masters so as'to' determine whether suffic'ient information is available to make a " reasoned decision".
~.
Accordingly, ' we address"belo'w each of CASE's' asserti' ns w'ith o
respect to Applicants' statement of material facts which we perceive to require clarification and/or rebuttal to assist the i
l Board in reaching a sound decision.
We believe there clearly is sufficient information before the Board for it to reach a i
l reasoned decision on this issue.
l 4
i 1
We note that CASE has failed to file a statement of material i
facts as to which it contends there is a genuine issue to be.
j heard, as required by 10 C.F.R. $ 2.749(a).
We do not stand on this technicality, however, but note that this failure makes it all the more difficult to discern precisely what CASE's assertions are.
2 Memorandum and Order (Written-Filing Decisions 4 it Some AWS-ASME Issues) (June 29, 1984) at 2-3 (" Memorandum and order").
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Before responding to CASE's answer, we feel compelled to.
comment on CASE's inability to focus its pleadings on the issues
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- *'ih dispute....'CA'SE'f a'ils',in...' m a n y,i....nstances to adhere'to the Board's admonition in its Memorandum and Order that CASE-
-demoristrate" why
- its#'obfe'etions 'mie' 'rel'e'vant 't'o bie'inhNs'.* * *
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Further,. CASE.also fa'ils3 o, demonstrate.the existence.of.,...*
important issues that affect the public safety.4 CASE pursues
-many argument'swithout re' aching a 'coriclusion it all. In 'sh'o'rt,"' '
CASE's answer makes it extremely difficult to discern what information need be provided to assist the Board in reaching a decision.
Accordingly, we ask the Board to again admonish CASE t
to focus its ansder.ston the genuine ' issues.
Further, the Boa'd r
should caution CASE that failure to address clearly relevant
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' issues works to the,'d'etriment of ration,al decision =aking and will not be viewed with favor by the Board.
B.
Applicants' Reply to CASE's Arguments Applicants focus below only on those arguments of CASE which are at least superficially relevant to the issues at hand.
Mcwever, as already noted, CASE generally does not demonstrate why even those arguments should be considered to raise important safety questions.
Thus, it is difficult to predict whether the Board might consider any of those particular arguments to raise 3
Memorandum and Order at 6.
4 Ld_. at 7.
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important,,, _
Accordingly, we address each even potentially issues.
l relevant issue below regardless of its appare'nt lack of' safety
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.,.-. I a. :, Pipe Support Design.. Organizations ', Practice,,..r,.,,...: p..,. s;,...,.
CASE argues with respect to Applicants' first material fact i
~
that Applicants should have (because Gibbs & Hill designs moment
.. restraints),, b,ut..did.not,. includ,e.Gibbs &, Hill as_ a " pipe. support..., c, 3
design organization" (Affidavit at 1-2).
Applicants will not spend time quibbling with CASE on this matter.
Applicants have never contended that Gibbs & Hill did not design moment restraints ( see CASE Exhibit,669B, ;, Item 90-9S)..
In fact,' we, i
previously provided CASE with information regarding Gibbs &
. Hill's pr' accid with ' respect.'t'o ' the 'consid' era't[on of Ifrietion 'foi' '
these restraints.5 Thus, we fail to see CASE's purpose in addressing this, particularly because CASE does not dispute he technical validity of Gibbs & Hill's practice.
Rather, CASE takes issue with certain tangential matters not directly material to the resolution of this issue..Nevertheless, we address these briefly below to assure a clear record for the Board to reach its s
)
decision.
CASE asserts that because Gibbs & Hill designed the ut ar i
lateral restraint, Applicants' statement that the only supports l
Gibbs & Hill designs are moment restraints is somehow in error.
1 1
5 See June 29, 1984, letter to CASE (illis) from Applicants i
(Horin).
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Hill's supervision," implying that the practice of that group, viz.,-to include friction. effects only when. instructed,.was
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somehow incons'istent with' Applicants p'osition in tiheir motion.'
I
.,In.the fir e. instance..the.. upper. lateral., restraint is not.a. pipe
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support, it is a restraint..for movement of,the steam generator.,.
Further, although the STRUDL group was under Gibbs & Mill super-vi,sion (i.e.., the superviser was a, Gibbs &, Hill,.empleveel. it was.
f not a Gibbs & Hill organization.
The STRUDL group performed analyses for each pipe support design organization and, thus,'
friction was included in those analyses consistent with each organizations' J
- in.struction.s.
Each of' these matters, are fully consistent with Applicants' position throughout the p:.oceeding.
(Finneran Affilavit at' 2.)~. '( Applicants t ve attached the i
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Affidavit of John C. Finneran, Jr. in support of their reply.)
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Accordingly, the Board should find that C; I provides no basis for disputing Applicants' first material fact.
2.
Calculations of Friction Loads CASE does not dispute Applicants' second and third state-ments of material fact (Affidavit at 2-3).
Accordingly, Applicants have no comment on these port.
is of CASE's Answer.
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Application of Procedure for
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CASE states that it disagrees with Applicants' fourth u.1 s" :..:.f.' ' r p.
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......... r statement of material, fact.only "to a certain. extent" (Affidavit at 3).
Mosever, Applicants are unable to discern to what extent
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i CAS E d i s ag r e e s.
..c. t.>.., r......%.v...:., CASE simply restates Applicants' position and
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l draws no conclusion.~ Acco'dingly, CASE has not presented any r
l justification for disputing Applicants' position.
CASE also does
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not dispute Applicants' fi..fth' statement of material' fact (Affidavit at 5).
CASE simply reassorts its basic position, to which Applicants' entire motion is d rected.
Accordin61y, Applicants do.not address these a.spects of CASE's Answer..,
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CASE's Propose ' Guideline
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Applicants address in their sixth statement o" material fact i
u the need to consider a gt delinesuchasMr.Dcy1/'suggestedbe l
l used.
CASE presents several arguments regarding this fact, none of which disprove Applicants' position (Affidavit at 5-10).
CASE d.
first argues Applicants misinterpreted Mr. Doyley. statements.
A review o' Mr. Doyle' testimony will demonstrate that Applicants l
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f have not misinterpretadethat testimony.6 In addition, CASE now 6
Applicants _ trongl.
ject to CASE's characterization of our b
summary of
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testimony as being "very misleading i
and either onstitu ing] or border [it.g] on material false statements" (Answer at 2).
We do not take lightly such charges.
The Board has on many occasions cautioned that j
such unfounded attacP.s will not be countenanced.
- CASE, however, still seems to consider such charges to be the 1
matter of course.
Several of its " Answers" to Applicants' j
motions incorporate the identical attack on Applicants' (footnote continued) i i
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asserts that its. concern en this issue is with the
" survivability" of supports over the period of time the plant
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must operate. '.. CASE does n,ot attem..pt to relate this claim...to or...e.
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otherwise demonstrate a safety concern.
Thus, this assertion
'giv'es no...... basis to questi.....,..o n A p p l i c a n t s,.s....si..y.u.xth statement.'
We note,.
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however,.that this claim appears t'o conflict directly With CASE's position at the hearing.
Asfr.
Doyle testified, CASE was not
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concerned with rep'etitively... applied loads".(Tr.'..6826),'....even wh..e r e ".',.....
the stress ratios for normal allowables approached or slightly i
exceeded one (Tr. 68*6-29).
CASE's present assertion to the j
contrary affords no basis to question Applicants' sixth material
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CASE also conte.mds (Affidavit at.7),,that Applicants have t
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misconstrued Section NF-3231.1 of the ASME Code.
Applicants position s that if the effects of friction were included in the design of these supports, the allowables applicable to such loading combinations could bo increased pursuant to NF-3231.1 t
i (Finneran Affidavit attached to Applicants' Motion for Summary
?
Dispositien, at 4-5).
CASE construes Applicants' position to be j
that friction effects can be included in all analyses in order to i
obtain a general increase in allowables for all leading (footnote continued from previous page) motions.
As we demonstrate here and will demonstrate in ou.
other repli'os, CASE's assertions are unfounded.
Accordingly, the Board should strike each of those charges from CASE's answers and admonish CASE for making such i
i baseless claims.
The Board should also put CASE on notice l
that similar unfounded attacks in the future could result in more severe sanctions, including striking CASE's entire l
pleading.
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combinations.
To the contrary, mechanical loading combinations must satisfy applicable allowables, without any increase.
If
. friction effects are-included, those loading combinations may~~
l utilize the increased allo' wable (F'inneran Affidavit at 3).7 CAS'E apparently misunderstands Applicantsf. position.-
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1 CASE next asserts that when the effects of friction alone t
are considered, the stress ratios are of such magnitude that inclusion of. mechanical loads would create an overstressed con-dition (Affidavit at 7).
To illustrate its point CASE evaluates a calculation Applicants prepared for the NRC Staff which showed that when the effects of friction alone are calculated for a particular support the str_ess ratio w$s.determ.ined 'to be.775'.
CASE erroneously contends that this leaves only.225 of the ratio for mechanicalLloads.. CASE does not ackno'wl' edge that '(~as' ' tated s
l by Mr. Finneran in his statement to the NRC which is referenced i
by CASE') friction forces do not act alone, and that when the normal load (which gives rise to the friction force) is included in the calculation it tends to offset the effect of the friction force.
In this instance, when friction and the normal load are i
combined for the above support, the stress ratio actually drops from that calculated for friction alone to.46.
(Finneran Affidavit at 4.)
Thus, CASE's assertion simply is invalid.
7 t
We note that Applicants' standard practice is not to take I
advantage of this increase in allowables, even when friction is included.
(Finneran Affidavit at 3.)
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CASE's next claim concerns Applicants' use of a 5:1 safety factor for Hilti bolts (Affidavit at 8).
CASE notes that a list of Hilti allowables using a ' factor"of safety' of 4:l"is ine'luded'
s.
..i in the PSE design manual.
CASE says nothing more, but leaves the impression that Applicants incorrectly stated the safety factors ' '-"
they employ for Hilti bolts.
CASE fails to point out that the,
list CASE refers to is simply a letter from Hilti, Inc.,
furnished by NPSI, containing load. capacity data.
(Hilti' 1 -i " '-
recommends therein the use of a 4:1 safety factor.)~
This information is for use by organizations which order Hilti bolts i
from NPSI (which Applicants do not) and is 1,ncluded in Section XII of the manual ' simply for ' general informaElon.
The actual'.
design recuirements for Hilti bolts, using a 5:1 safety factor, are reflected in 'Section V of the PSE' manua'1.
In fact,' CASE itself uses the data from Section V only two pages later (Affidavit at 10) in its own illustration of these effects.
2 (Finneran Affidavit at 5-6.)
CASE next attempts to demonstrate, using a hypothetical support, that the effects of friction are significant and that' failure to consider these effects could result in failure of j
anchor bolts ( Affidavit at 9-10).
CASE's hypothetical is premised on the same fundamental misunderstanding of friction loads discussed above with respect to stress ratios.
CASE either misunderstands, or chooses to ignore, that a friction load does not act alone.
A friction load must act with the normal load from which it results.
In CASE's hypothetical the normal load s.
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has simply been neglected.-
As demonstrated in Mr. Finneran's Affidavit (at 6-7), consideration of the normal load in this
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' example shows "that the' boltt which' 'C'ASE"claimsi would 'pu11' out'
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cannot even be put in tension.
In short, CASE's hypothetical is simp 1y inval16. ' --
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We are deep 1y troubled by. CASE's handling of these last.few assertions.
The fallacy of using data calculated with only friction loads for..the purposes ' CASE" used them "should" be t.*D.~~""
immediately obvious to CASE.
Even if this error was not immediately realized, Mr. Finneran's reply (to which CASE refers) cautioned against such usage and CASE should have so recognized
~
the.er or'of its ' approach'.'- Furthe'r,L Applicants informed ~ CASE of -
Hil'i allowables in Section XII of their the purpose of the t
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m'anual during the tun'e"6, 1994 'confdre'nce cal'1'(Tr. 4'l). "That
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CASE would include in any filing before the Board, let alone sworn affidavit, a statement which, although not false in and af itself, creates an impression in any reader's mind which CASE should know to be false, is disengenuous, at best.
The Board and parties are faced with resolving many issues.
To waste others' time in addressing this type of claim suggests a desire simply to cause delay rather than to reach the truth.
Indeed, Applicants seriously question whether other statements by CASE as to wl ch
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providing a few additional basic facts (which we would expect CASE to know) would clarify the point and demonstrate that no valid concern exists are not also intentional.
Such a practice
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should not be countenanced by the Board.
Accordingly, we urge the Board to caution CASE that such tactics will result in prom'pt Sanctions.O
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. Evaluation of CASE support
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Applicants' seventh material fact addresses the evaluation of the support referenced by CASE in its proposed findings.
CASE disagrees with, App,1,1 cants'.-conclusi,on that even with.
,4 consideration of friction forces the stresses are all-within applicable allowables.
CASE first contends that. Applicants employed an incorrect moment arm.in.the evalua, tion.of this support.,, CASE argues'thatl use of the correct mcment arm would result in "a 37% increase of s.
all tabul'ated values."
(Affidavit at 11.)
CASE is;corre'c't 'in its calculation of the moment arm.
However, CASE incorrectly asserts that the increase would be applied tt "all" valuss.
That increase actually applies only to one moment term (My).
}
Correctly including this revised moment arm in the calculation i
i demonstrates that the stress remains below the applicable i
allowable.
( Finneran Affidavic at 7-8. )
)
CASE also contends that the increased moment arm would cause the stress ratio for the anchor bolts to ex ed one (Affidavit at
(
l 11).
However, as already noted, the increase in mcment arm only l.
a f fects the moment about one axis.
Contrary to CASE's assertion, 8
See note 6, suora.
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a the stress ratio for the anchor bolt only changes from.81 to
.89, which indicates the anchor bolts are not overstressed.
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( Finneran Affidavit at-8.) --
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CASE also questions the dimensions employed in Applicants' calculation (Affidavit.at 11-12).
.Although CASE does not suggest s'
the, discussion is relevant to the issue at hand,.we nonetheless note that the dimensions Applicants employed are correct.
CASE simply misread. the drawing..
(Finneran Affidavit at 8.)'
CASE next contends that Applicants utilized an incorrect allowable in assessing the shear yield Stress (Affidavit at 12).
CASE apparently does not understand the nature of the shear yield stress check.emple'yed in the.s'ubject calculation..'That. check-S*
utilized a formula from the AISC Code and was performed simply to provide added assurance of
.'he adequacy of the seld.9.
~
As'Mr.
Finneran demonstrates in his affidavit, that method yields an allowable which is equivalen to that which CASE argues should be employed.
In any event, CASE's claim is premised on an interpretation of Regulatory Guide 1.124.
Without addressing the validity of CASE's interpretation we note that this Regulatory Guide applies only to class 1 supports.
The subject support is a class 3 support (Finneran Affidavit at 9).
i 1
9 Contrary to CASE's claim (Affidavit at 13), Applicants are not " committed" to any edition of the AISC Code for weld design.
Applicants do not reference the AISC Code in their specifications for the purpose of establishing weld design criteria fnr ASME supports.
(Finneran Affidavit at 9, n.4.)
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In sum, none of CASE's arguments regarding Applicants' seventh material' fact are valid.
Accordingly, the Board should
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accept Applicants' position.
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Evaluation.of sample. supports.
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'l fact in two respects.
First, CASE suggests that Applicants' sample of supports was not." random"... Second, CASE argues that Applicants' calculations of friction ef fects for these supports I
was inadequate.
Both of CASE assertions are unfounded.
i CASE claims that it does not know "how random Applicants' i
]
sample wa.s or the. criteria used. for their selecSion ' ( Affidavit. at' i
14)."
As discussed in Mr. Finneran's affidavit attached to
.., ~..
i Applicants motion for summary disposition (at 5-6),' Applicants' 1
i sample of s"pports was selected by applying two criteria which assured the supports were of the " worst case" type and for which friction would not have been previously considered.
To identify supports which satisfied these criteria, Mr. Finneran simply requested that his engineers review support drawings at randen to identify these supports.
The resulting supports were, therefore, randomly selected in accordance with the established criteria.
(Finneran
!fidavit at 9-10.)
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To discredit Applicants calculations regarding the sample supports CASE selects one such support for examination and contendo that it will illustrate the shortsightedness of -
neglecting assumed minor effects".
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(Affidavit at 14-15).
As demonstrated bef.ow, CASE fails to do so,.
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.4.
m.
CASE first asserts (Affidavit at 15, paragraph (2)) that the stress ratio calculated with the ef fects of friction included was "almact four times as.tigh," as that without friction.- However..-
given the initially low stress ratio for this support, even with the 1.icrease due to friction the stress ratio remains well within the acceptable range.
Thus, there is no significance to the percentage increase in st'ress' ratio.
CASE ~also neglects to po' int out that the allowable when friction was included could have been, but was not;Iihere..ased above the normal. allowable.
i (Finneran Affidavit at 10.).
CASE also claims (Affidavit at 15, paragraph (3)) that inclusion of the effects of friction increases the level A stress l
ratio in the weld from.25 to 96.
CASE believes that this demonstrates the weld would not be able to take much increase in lead before it exceeds allowables.
(CASE asserts that such a load increase "could" be caused by several effects, but does not quantify its argument.)
Contrary to CASE's assertion, the weld stress ratio increases only to.46 when the effects of friction are included.
In addition, the stress ratios are premised on the l
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normal allowable without taking advantage of the permitted increase.
Thus, ample margin to allowable. remains even when
'D friction. effects 'are included.
-( Finneran Affidavit at 10-11.) ~
"5'**'
CASE fails to demonstrate either the relevance or significance of its next two argument's to Applicants' motion-2' (Affidavit at 16,, paragraphs (4) and (5))..Nonetheless, owe make the following points.
First, with respect to paragraph (4),
Applicants note that the.re is alrigid support less than.three' feet from the subject support which prevents additional side load from being imparted to this support.
Thus, CASE's concern regarding the potential effect of additional side load is i
un found ed '..
l(Finneran. affidavit at-11).. Further, with respect to paragraph (5), the note to which CASE refers is only a rough
~
approximation'of th'e frEction load $hich'would be imparted'if'the,'
pipe were to move into at the curvature of the U-bolt.
This calculation was performed merely to confirm that the controlling friction load occurs when the pipe is against the backing plate.
Further, it is not appropriate to characterize this rough approximation as indicating the U-bolt stiffness.
Applicants have utilized actual test data for these values in their motions
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I for summary disposition.
(Finneran Affidavit at 11-12.)
Finally, CASE disputes a statement made in the Cygna Phase III Report, attributed to Mr. Finneran's original affidavit, regarding the consideration of friction in the upset loading condition (Affidavit at 16-17).
The statement in the Cygna Report is not, however, derived frem Mr. Finneran's affidavit.
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In fact, the statement does not relate at all to the issue at s.
- hand, vi=.,
friction effects for small pipe movements for which friction was not. considered under any loading condition.
(Finneran Af fidavit at 12. )' ' Thus, CASE's comments are not
~
relevant to the disposition of' this issue..
III.
CONCLUSION
,.For ti.e foregoing reasons, the Board should find that Chere-is sufficient evidence before it to reach a reasoned decision on CASE's allegations regarding friction effects and that evidence demonstrates that Applicants' practice is appropriate and based on sound engineering principles.
Respectfully submitted,
. 's GO
- 0. s0 Nicholas S.
Reynolds William A. Horin BISHOP, LIBERMAN, CCOK, PURCELL & REYNOLDS 1200 Seventeenth Street, N.W.
Washingten, D.C.
20036 (202) 857-9800 Counsel for. Applicants September 19, 1984 i
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UNITED STATES OF AMERICA NUCLEAR
- REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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Tn the Matter.of
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- Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC
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(Applicatio~n for (Comanche Peak Steam Electric
)
Operating Licenses)
Station, Units 1 and 2)
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AFFIDAVIT OF JOHN C.
FINNERAN, JR. IN SUPPORT OF APPLICANTS' REPLY TO CASE'S ANSWER TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION REGARDING CONSIDERATION OF FRICTION FORCES e
I, John C. Finneran, Jr., being first duly sworn hereby depose and state, as follows:
I am.the-Proje-t Pipe.'Su,pport Engineer for the Comanche Peak Steam Electric Station.
In this position I oversee the design work of all pipe upport design organizations for Comanche Peak.
A statement of my educational and professional qualifications was received into evidence as Applicants' Exhibit 1423.
Q.
What is the purpose of this affidavit?
A.
This affidavit provides information in support of Applicants' Reply to CASE's Answer to Ap icants' Motion for Summary Disposition Regarding Considerati n of Friction Forces.
C.
What is your reply to CASE's assertions with respect to Applicants' first statement of material facts?
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CASE claims in its response to Applicants' first statement
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of material facts that Gibbs & Hill designed the upper
. lateral-restraint. and,. thus, have, designed other."supporta"
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.than. the moment restraints, and that the STRUDL group "was'
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......... n; under Gibbs &. Hill's., supervision," implying that the......
practice of that group, viz., to include friction, effects only when instructed, was somehow inconsistent with
. Applicants,' ; position.in.,their,moti,on, ( Affidavit at. 2 ).
.In.
the first, instance, the upper lateral restraint is not a pipe support, it is a restraint for movement of the steam generator.
Further, although the STRUDL group was under the supervision of.a Gibbs & Hill employee,.it was.not a Gibbs Hill organization.
- dhen the STRUDL group performed analyses f'or each pipe suppost tasign' organization, friction 'was included in those analyses censistent with each organica-tions' instruction.
As e noted in our motion (see my affidavit at 1-2), some design organizations did not consider friction foi pipe movements less than 1/16".
- Thus, the STRUDL group would not always be recuired to include friction.
This is fully consistent with Applicants' position throughout the procee' ding.
O.
What is the next aspec-of CASE's answer to which you wish to provide a reply?
A.
CASE does not specify any particular disagreement with Applicants' second through fifth statements of material fact although claiming that it disagrees to a certain extent with
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the fourth statement, with'out specifying any particular point with which it disagrees.
Thus, the next aspect of
. to"which I 'wish to'.. reply concerns their~
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C A S E '~s 'a n s w e r ".
comments regarding our sixth statement of material fact.
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What'is you'r 'rsply ' tTo" CASE s ' ans'wer 'to" Applicants '
si statement of. material fact?.
A.
CASE presents several arguments regarding this statement of
- ' fact; none'of'which'~dispro've AppiliahtI' posi'ti6nl
' ' ^ " ' ' ' -
~
Specifically, CASE contends (Affidavit at 7), that Applicants have misconstrued Section NF-3231.1 of the ASME Code.
CASE directs its argument to th'e statement in my affidavit accompanying Applicants'" motion (Finneran Affidavit at. 4-5 ):_. "at if the. ef fect.s. of frict. ion are t'.
included in the design of supports, the allowables applicat 's to such loading combinations could be increased pursuant -o NF-3231.1.
CASE incorrectly construes Applicants' position to be that friction effects may be included in all analyses in order to obtain a general increase in allowables for all loading ecmbination::.
To the contrary, mechanical loading combinations (not including frictic-) must satisfy applicable allowables without any increas If friction effects are included, those loading combinations may utilize the increased allowable.1 CASE simply misinterpreted Section NF-3231.1.
1 As I previously noted, Applicants' standard practice is not to take advantage of this increase in allowables, even when friction is included.
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4 CASE next asserts that when the effects of friction s
alone are considered, the stress ~ ratios (load divided by j
allowable)-are of such magnitude that inclusion of. '- ' <. A.H mechan'ica'l' loa'ds we'uld' create ' an overstressed coddition (Affidavit at.7.)....
CASE. illustrates.its. position using-a.,...
calculation Applicants prepared in response to an NRC Staff question which showed that when the effects of friction alone are calculated..for..a.particular. support the.strgss.....
ratio was determined to be.775.
CASE contends that this leaves only.225 of the ratio for mechanical loads.
CASE does not acknowledge, however,.that (as I indicated in my statem'ent to,Mr.. fair. referenced'by CASE). friction _forc'es.do not act alone, and that when the normal load (which gives rise to khe '[riction' force). is ' included in the-calculation,-
it tends to offset the effect of the friction force.
In this instance, when friction and the normal load are combined the stress ratio actually drops from the.775 calculated for friction alone to
.46.
Specifically, as noted in Table 1 of my original affidavit, the loading combination of friction plus Level A loads for this support (SI-1-029-055-S32R) produces a.96 stress ratio (3042 divided by 3181), using a conservative calculation technique (treating the compression force in the support member as a tencien load on the weld (see p.
4 of 7, bottom of calculation)).
To compare accurately the friction plus l
normal lead combination with the friction load alone it is 1
5-e.
s.
> = =..
9 a.
.s necessary to evaluate the weld stresses as'they actually occur.
Doing this for the level' A lbads plus friction lo'da
- R' ~ - 4 t - 6 combination for the weld yields:
... : n....'..
f (weld tension st'ress) = 4972 (15.5) - 16573 = 1439..lb/in 34.47 20.8 b;.-
~,
- r
.q-Then the resultant tension stress on the weld is (1439
+ 2392)l/2 = 1459 lb/in f
=
R The resulting stress ratio is then.46 (allowable stress =
..~.h.,~.-.s.
i:.
~ - i-318'l iS/in).
Performing,a similar evaluation for Level B loads yields a stress ratio of
.42.
In sum, it is simply incorrect to assert, as CASE does, that the stress ratios calcula'ted considering friction alone are at all indicative
~
~
of the stress ratios for cos.bined mechanical and friction leading.,
CASE's next claim concerns Applicants' use of a 5:1 safety facto for Hilti bolts (Affidavit at 8).
CASE notes that a list of Hilti allowables using a factor of safety of 4:1 is included in the PSE design manual.
CASE fails to point out that the list CASE refers to is simply a letter from Hilti, Inc., furnished by NPSI, containing load capacity data for use by organinations which order Hilti bolts from
'SI, which Applicants do not.2 The sheet is included in 'ection XII of the manual with other load 2
Hilti, Inc. recommends a 4:1 safety factor,for Hilti bolts.
Applicants have adopted, however, a 5:1 safety fe.ctor for Hiltis.
This practice is documented in Applicants' design specifications.
A copy of the page from these specifica-tions which calls for the use of the 5:1 safety factor was provided to CASE with Applicants' motion.
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capacity data, for general information.
The actual design requirements for Hilti bolts at Comanche Peak, using a 5:l'
.'sa ety actor, are reflected in Section V of 'the' PSE manca'l.*
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In fact, CASE used data from Section V only two pages later
( Affidavit at' 10) in its cnct illustration of these effects.
?
CASE's final claim wish respect to this portion of Applicants' motion is that failure to consider friction
. effects could result in failure of anchor bolts (Affidavit at 9-10).
To illustrate its point, CASE uses a hypothetical loading condition which is premised on the same fundamental misconception regarding friction loads which I discussed above with respect to stress ratio s.
CASE'apparently'does not understand that a friction load does not act alone.
A fricti'on load must,act with 'the normal loi,d dro which'it' results.
In CASE's hypothetical the normal load has simply been neglected.
Consideration of the normal load for CASE's hypothetical shows that he bolt which CASE claims would pull out cannot even be put in tensien.
Using CASE's assumed friction force (F of 4900 lbs. ),
the normal load' f
(N) producing that friction load is easily calculated as 4900 lbs divided by an assumed coefficient of friction (.3),
which is 16,333 lbs.
Simply summing all moments about 1
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e bolt 3 demonstrates that.. bolt,.A.cannot.even.be put in.
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tension, although CASE represented that there will be a 4900 lb. tension load on the bolt.
CASE's assertion is, therefore, false.
Q.
What is your response to CASE's arguments regarding
^
Applicants' seventh statement of material fact?
A.
CASE contends that Appl'ic. ants employed an incorrect moment arm in the evaluation of this support.
CASE argues tha-use of the correct moment arm would result in "a 37% increase of all tabulated values."
(Affidavit at 11.)
CASE is correct in its calculation of the actual menent arm.
However, CASE incorrectly asserts that the increase would be applied to "all" values.
':'h a t increase actually applies only to one moment term (My).
Correctly including this revised mor 'nt arm in the calculation demonstrates that the stress rer: ins.
1 below the applicable allowable, j
I'have recalculated the stresses in the weld, as i
follows.
First applying the increased moment arm to the My term (multiplied by 1.37) yfelds
8-
.c.
13.835 x 1.37 + 1.010 -~4.7683 = 3.3485 kips /in 5.17 16.88 12.63 The resultant force is then
..<.r...
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F
= [3.34852+.0622 +.167 32 1/2
. ~.
= 3.253 kips /in R
This remains below the 3.431 allowable used in the
......u.
.e original calculation.
Thus, cor.trary to CASE's assertion, the stress' ' ratio for the weld renain's below 1.
CASE also cor tends that the increased moment arm would
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cause the stress ratio for th'e anchor bolts to exceed one (Affidavit at 11).
However, as al: eady noted, the increase in mcment arm only affects the moment about one a-is.
- Thus, the stress ratio for the anchor bolts only changes from.81 to.89, contrary to CASE's claim.
This can be seen by increasing the My moment in the. original Hilti bo] t calculation (Attachment A to my original affidavit, second
- p. 3 of 6) from 15.438 in-kips to 21.2 3 in-kips.
I have attached a new FUB II analysis printout reflecting this change in My (Attachment A).
The Hilti interaction now becomes 3509 + 756
.89
=
4688 5375 CASE also questions other dimensions employed in Applicants' calculation (Affidavit at 1-12).
The l'6"
~
dimension questioned by CASE is from tne center of the pipe
~
to the centerline of the vertical struts and not to the tube 3
This load is evaluated here as a compression load (which it is) rather than the tensile load conservatively assumed in the original calculation.
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l steel as CASE apparently believes.
The tube. steel is
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installed with a 1/16" clearance as indicated on'the drawing.
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CASE next contends that. Applicants utilized an
. incorrect allowable in assessing the shear yield stress.
e 4-(Affidavit at 12).
CASE apparently does not understand the nature of the shear yield stress check employed in the
. subject calculation.. That.. check utilized a. shear yield.
~.
stress value from the AISC Code.4 (See AISC Manual, 7th Edition, p. 5-123 (Attachment B)).
This check was performed simply to provide added assurance of the adequacy of the weld.
That,AISC'for=ula, in fact, yields an allowable
~
(Sy/,I3 =.577 Sy) which is equivalent to that which CASE apparently' argues shot _d be employed (l'.5'r :4 Sy =
.6 Sy; see Affidavit at 12, 13).
It should be noted in any event that CASE's position ir premised on Regulatory Guide 1.124, which applies to class 1 supports.
The subject support is a class 3 support.
O.
What is your response to CASE's argunents with respect to Applicants' eighth statement of material fact?
4 Contrary to CASE's claim (Affidavi at 13) Applicants are not " committed" to any edition of the AISC Ccde for weld design.
Applicants' requirements for weld design are set forth in subsection NF of ASME Code Section III.
Applicants do not reference the AISC Manual for the purpose of establishing weld design criteria for ASME supports.
.._.____[._.
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A.
In challenging Applicants' eighth statement ~of material facts, CASE first claims that it does not know "how random Applicants' sample was or the criteria used for their~
selectiod" (Affidavit at'14).
As I stated in my original affidavit.(at 5-6), Applicants' sample of supports was 0m selected by applying two criteria:
(1) the support is of the type which (as both parties agree) would be most significantly affected by inclusion.of friction effects, viz., short, stiff support members with relatively large pipes, and (2) the pipe thermal movement is less than 1/16" (so friction would likely have been neglected in the original' design). fro identify supports Ohich satisfied
~
these criteria, I recuested that my engineers review support
~
drawings at random to identify these supports.
The resul ing supports were, therefore, randomly selected in accoruance with the established selection criteria.
CASE next attempts to discredit Applicants' calculations regarding the sample supports by examining the calculations for one such support, contending that it "will illustrate the shortsightedness of neglecting assumed ninor,
effe-ts" (Affidavit at 14-15).
In this regard CASE first asse..s (Affidavit at 15, paragraph (2)) that the stress ratio calculated with the effects of friction included was "almost four times as high" as that without friction.
Applicants fail to see the significance of this argument.
In the first instance, the initial stress ratio was so low I
i l
i.
_1 11 that even with the increase due to friction the stress ratio remains well within that which is acceptable.
In addition,
.....,y
.. *: 2 s-e' CASE fails to point out that. the allowable when including friction would be higher than the normal allowable and,
. thus,. he. stress ratio..
1'd'M...e.e even lower.
.,a wou'
~
t CASE further claims (Affidavit at 15, paragraph (3))
that inclusion of the effects of friction in that calcula-tion-would ' increase ' the' ' lev'e'l A' st'res s' lsti~o-in the weld '
~
from.25 to.96.
CASE believes that this demonstrates the v' eld would not be able to take much increase in load before it would exceed allowable.
(CASE asserts that such a load l
increase "could"'be caused'by several effects, but'does not quantify its argument.,)
Contrary to CASE's assertion, as I previously demenstrated (see pp. 4-5) the weld stress ratio is actually.46 when the effects of friction are realisti-cally calculated.
Further, both the.96 and.46 stress ratios are based on the normal allowables and do not take advantage of the increase in allowable that would be permitted.
Thus, ample margin te the allcwable remains even when friction effects are included.
With respect to CASE's next two arguments (Affidavit at 16, paragraphs (4) and (5)) the following points should be noted.
First, with respect to paragraph (4), there is a rigid support less than three feet from the subject support which prevents additional side load from being imparted.
Thus, CASE's concern regarding the potential effect of
,s additional side load is unfounded.
Further, with respect to paragraph (5), the note to which CASE refers is only a rcugh
,,;.n.....?.
' approximation o...f the. friction load which.would be imparted if the pipe were.to move into the curvature of the U-bolt.
r.
.. ;. v.:.-...
This ca.lculation was. per for.ned. merely to confirm....c...that the controlling friction lead cecurs when the pipe is against the backing plate.
Further, it is not appropriatit to l
charact'eriz.e this'ro. ugh approximation as indicating U boJct
~,
stiffness.
Applicants' have utilized actual test data for these values in our other motions for summary dispositier:.
Finally, CASE disputes a statement made in the Cygnai Phase'III' Report, attributed t'~my original affidtvit, o
regarding the consideratien of fricticn in the uptet loac'.ng condition (Affidavit at 16-17).
The statement in the Cyc ma Report is not, however, derived frem my affidavit.
In fact, the statement does not relate at all to the. issue :)f friction effects for smal!. pipe movements.
Thus, the poi at is not relevant to Applicants' motion.
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...19th ~ da of September,1984
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Subscribed and sworn to'before me this c.............
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i While the shear yie!d stress _of structural steel has been variously esti-3 t
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able tensile stress. substantially as it has been since the Sist edition of the R f.P,p.w;x%
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AISC Specifcation. published in 1923. This apparent reduction in factor
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The webs of roIIed shaFes are all of su'ch thfeiness that shear'Is seldom the
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ti criterion for design. However, the web shear stresses are generally high N.
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introducing the =ocent. Deignating as d, the depth of the member entering H
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This c timate assurnes that the upper limit of elastic buckling failure is de-e
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I slenderness ratio C,, ccrresponding to this limit, can be expressed in terms of i +
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p'fTkp Egg the yield stress of a given grade of structural steel as
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tot has been taken as equal to, er only slightly greater han, that required
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$ p :R approaching the Eu!er slenderness range, the factor i.ncreased 15 per-3M y ve.-[-Q. g.}%.
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t UNITED STATES OF AMERICA NUCLEAP REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD N-: L. / -
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In the Matter of
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TEXAS UTILITIES ELECTRIC
)
Docket Nos. 50-445 and i~. -
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50-446-
.CCMPANY, et al...
)
(Comanche Peak Steam Electric
).
(Application for Station, Units 1 and 2)
)
Operating Licenses)
CERTIFICATE OF SERVICE
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I hereby certify that copies of the " Applicants' Reply to CASE's Answer to Applicants' Motion for Summary Disposition Regarding Consideration of Friction Forces," in the above-captioned matter was ser"ed upon the following persons by express delivery (*),
or deposit in the United States mail, first class, postage prepaid, this 19th day of Sept' ember, 1984, or by hand delivery (**)
on the,20th day of, September, 1984.-
- Peter B.
Bloch, Esq.
Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing 'oard
, U.S. Nuclear Regulatory, U.S. Nuclear Regulatory Commission.
Conmission Washington, D.C.
20555 Washington, D.C.
20555
- Dr. Walter E Jordan Docketing & Service Branch 881 West Outer Drive U.S.
Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C.
20555
- Dr. Kenneth A. McCollom
' Dean, Division of Engineering Architecture and Technology
- Stuart A. Treby, Esq.
I 1
Cklahoma State University Office of the Executive Stillwater, Oklahoma 74074-Legal Director i
U.S. Nuclear Regulatory Mr. John Collins Commission Regional Adr'nistrator, Washington, D.C.
20555 Region IV U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Panel 611 Ryan Plaza Drive U.S. Nuclear Regulatory Suite 1000 Commission Arlington, Texas 76011 Washington, D.C.
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f.c Renea Hicks, Esq.
- Mrs. Juanita Ellis Assistant Attorney General President, CASE Environmental Protection '
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' Dallas; Texas 75224 1426 South Folk Street Divisiori '
P.O. Box 12548 Capitol Station Ellen Ginsberg, Esquire Austin, Texas 78711 Atomic Safety and Licensing Board Panel
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Lanny A.
Sinkin U.S.
Nuclear Regulatory 114 W.
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Outline - Staff Response r.
To Applicant's 50.57(6) Motion I.
Introduction II.
Discussion A.
Board is empowered to issue B.
Absence of Adverse Consequences to Public (similar to Catawba II.B.1; from Motion Part C and Affidavit IV) 1.
S/G to prevent criticality.
(from Motion Part B and Affidavit III)
C.
Technical Aspects of Fuel Load and Precritical Testing 1.
Fuel Loading - Motion Affidavit Part I 2.
Proposed Testing - Motion Affidavit Part II R4, TRT (H. L.)
' 3.
QA/QC Oversight - Suppl. #1; Vega Affidavit R4 4.
Completion of QA/QC Procedures - Suppl. #2; a
Deviny Affidavit h]
5.
Cales on keff Suppl. !3 6.
Maintaining Boron Conc. - Suppl. i4 Ko'reig, Calvo, R4 A
7.
Concerns about : artup QA
% ;-7 (5 issues from '../01/84 Board memo)
D.
Issues in Contention Before ASLB 1.
Coatings 2.
Walsh/Doyle 3.
Cygna Report 4.
Staffilalkdown R4, TRT 5.
Diessi Generatt s 1
p4 6.
Miscellaneous Various
+T RT 7.
QA/QC I ~
III.
Conclusion l
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Development of TRT Activities Input D
P. Matthews 1.
Coatings J. Calvo 2.
Electric / Instrumentation Shao 3.
Civil / Structural Shao 4.
Mechanical H. Livermore 5.
QA/QC W. Smith 6.
Test Programs
- II.
Development of Evaluation of Applicant's Reply To CASE's Answer to Applicant's Motion 1.
Pipe Support Design 2.
Calculations o Frict'on Loads 3.
Application of Procedure for Calculation of Friction Friction Loads 4.
CASE's Guideline (relates to W/D) 5.
ivaluation of CASE Support 6.
Evaluation of Sample Supports
- These evaluations should be integrated into the " Issues in Contention Before the ASLB" (Part II.D of Staff Response)
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.;t' CPSES/FSAR 17.1.15 CCRRECTIVE ACTIC?i TUGCO/TUSI requires that measures be established to assure that condi-tiens adverse to quality are prceptly identified, reported, and corrected. Responsibility for perfor:ning corrective action is assigned to contractors, applicable subcentractors, and venders so that each is alert to those conditions adverse to quality within his cwn area of activity.
In the case of significant conditicns adverse, to cuality, which are reportable to tac under the provisions of 10 CFR Part 50.55 (e), measures are taken to assure that the cause of the ccndition is detemined and corrective action is implemented to precluce repetition.
Ccrrective acticn peccedures placed in effect require thorough investi-gation and documentaticn of significant ccnditicas adverse to quality.
The cause and corrective action is reported in briting to the apprcpri-4 ate levels of management and to the purchaser.
This ccrrective acticn applied is subject to review by TUGC0 and the prime contracter i
respcnsible for the criginal purchase specifica icn.
Fcr CPSES, the Quality Assurance Plan requires that prececures and practices be established and dccumented which previde assurance that ccnditicns adverse to quality, such as failures, malfunctions, deficien-cies, deviaticns, defective material and equipment, and a
ncnconfomances, are prceptly identified, dccumented, and corrected as soon as practicable, and that apprcpriate acticn be'taken to ccrrect the cause of the condition.
Corrective acticn cecumentation and recuest fems cr femal letters are used to dccument the ccrrective actien-related requests, rescenses, and folicw up.
Th.e pian requires that measures be established by tne prime contractors to assure that the acceptability of rework cr repairs is verified by reinspecting the item as criginally inspected and that the reinspection is dccumented.
These measures are verified by review and approval of the prime contractors' QA Program and by the subsequent audit for confomance to the approved program.
Significant ccnditicns adverse to quality are identified (such as those which, if they had remained undetected, wculd 17.1-40
)
>h MAY 31, 1979 l
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CPSES/FSAR A ncnconfermance report is utilized for the identification, cocumentation, dispositioning, and verification of deficiencies in characteristics, dccumentation, or precedures which render the quality I of an item unacceptable or indeterminate.
All noncenforming items are tagged and segregated as defined in section 17.1.14, " Inspection and Test Status" and Section 17.1.13, " Handling, Storage, and Shipping."
Folicwing identification and dispositioning of noncenfermances, specified reviews and approvals are precedurally required for 1)
"use as is" and " repair," and 2)
" rework."
Upon ccmpletion of action required fcr disposition, repaired or reworked items are reinspected to verify that specified action and requirements are ccmplied with.
A deficiency repcrt is utilized for the identification, dccumentatien, resolution, and re-evaluation of precedural violatiens/prcgramatic deficiencies which are not directly related to the physical charactristics of an item.
Precedures provide measures which, when initiated, assure that activities adverse to quality are suspended pending identification, documentation, and resolution.
Proposed resolutions are then reviewed and approved, prior to implerentatien, to assure that specified recuirements are ccmplied with.
Implemented resoluticns are re-evaluated to assure that the resolutien has proviced ccmpliance with specified re,uirements.
Precedures require " trending" cf ncnconformance and ceficiency re;crts to identify trencs adverse to quality.
Precedures require the initiation of a corrective action request for significant ncncenformances/ deficiencies and chronically repetitive ncncenfermances/ deficiencies as defined in Secticn 17.1.15.
17.1-39 MAY 31, 1979 L_
s CPSES/FSRR y'
have adversely affected safety-related functions), the cause of the conditicn is detemined, and corrective action is taken to preclude repetition. Such significant conditions, their causes, and the
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corrective action taken are documented and reported to appropriate levels of management through established cccmunication systems.
Corrective action folicwup and clcse-out precedures provide that corrective action commitments are implecented in a systematic and timely manner and are effective.
The occurrence and magnitude of deficiencies and ncnconfermances 'recuir-ing corrective action are evaluated by the purchaser's inspectors during surveillance and at hold peint inspection and witnessing. Addi-tionally, these areas are identified for audit purposes.
The effectiveness of the vendcr's corrective action program is assessed during audits by the vendcr, the ' prime centractor, subcentracter, and by TUGCO.
Stop werk authority is exercised as required.
17.1.17 CUALITY ASSURANCE RECORDS The TUGC0/TUSI Quality Assurance program establishes procedures and practices to assure that TUGC0/TUSI and its centractors have a quality records system wnich provides dccumentary evidence of the performance of activities affecting quality.
Precedures assure er shall require:
1.
That records that are required to be maintained shcw evicence of perfomance of activities affecting quality. Typical records maintained include quality assurance programs and plans, design data and studies, design review reports, specifications, precurement dccuments, precedures, inspection and test reports, material certifications, personnel certification gd test" (eporls'., audit reports, reports cf nonconfomances and ccrrective
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cola-85-59 17.1-41 AUGUST 7, 1981 H,, I s" l
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NUCLEAR REGULATORY COMMISSION ANNOUNCEMENT NO. 6 DATE: January 27, 1982 TO:
ALL NRC EMPLOYEES
SUBJECT:
POLICY AND PLANNING GUIDANCE DOCUMENT In my remarks at the NRC Awards Ceremony on January 18 I stated that the Ocn11ssion's recently-completed Policy and Planning Guidance document would be distributed ta all employees.
It is attached.
The purpose of the PPG is to provide guidance to the staff for-establishing priorities and for improving the regulatory process--
starting -immediately. As the introduction states, this is more than just a dccument to be used in preparing budget requests.
It provides management guidance which focuses on specific areas where the Connission believes additional emphasis is required.
I hope you will read it with that in mind. Your support is.in essential part of carrying out the overall mission and objectives of the NRC.
m N nzio Pa dino Chairma
Enclosure:
As stated
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NUREG-0885 Issue 1 U.S. \\ uclear 9egu atory Commission Poicy and ?anning Guicance 1982 U.S. Nuclear Regulatory Commission
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NUREG-0885 Issue 1 U.S. N uclear Regu atory Commission Policy anc P anning Guidance 1982 Manuscript Completed: January 1982 Date Published: January 1982 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 m,,,,
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FOREWORD The Commissio~n has approved the attached Policy and Planning Guidance document. The purpose of the document is to provide guidance to the staff for establishing priorities and for improving' the regulatory process.. Guidance with respect to each and every activity within NRC is not furnished, since it is not intended that the ' document be all. inclusive.
Program-ming and budgeting within the agency shou.ld be consistent with this guidance unless it is specifically superseded or amended.
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Policy and Planning Guidance TABLE OF CONTENTS Subject Page 1.
Introduction 1
2.
Safe Operation of Licensed Plants 2
3.
Near-Term Licensing Problems and Responses 4
4.
Coordinating Regulatory Requirements 5
5.
Improving the Licensing Process 7
6.
Supporting New Initiatives 7
Waste Management 7
TMI-2 Cleanup 8
7.
Improving Related Regulatory Tools 9
Safety Goal 9
Risk Assessment 10 Siting Policy 10 Quality Assurance 11 Research 11 8.
Safeguards 12 International 12 Domestic 13 4
POLICY AND PLANNING GUIDANCE INTRODUCTION The purpose of this document is to provide guidance to the staff for establishing priorities and for improving the regulatory process --
starting immediately.
It is therefore more than just a document to be used for preparing the FY 84-86 budget request.
It is management guidance intended to focus on specific areas where the Commission believes additional emphasis is required.
Guidance with respect to each and every activity within NRC is not furnished, since it is not intended that the document be all inclusive.
However, this should not be perceived as a Commission belief that other areas are not equally as important to protecting the public health and safety. Many of these other areas have effective ongoing programs where major problems do not exist but adequate management attention and initiative are still important. Although specific colicy and planning guidance is not provided in this document, top management attention is still required for radiation health effects protection, fuel cycle licensing and inspection, materials licensing and inspection, and facets of emergency planning and preparedness not addressed here. These and other support functions are vital to accomplishment of the overall agency mission and objectives.
The document is organized in terms of seven major themes: Safe Operation of Licensed Plants; Near-Term Licens'ing Problems and Responses; Coordinating Regulatory Requirements; Improving the Licensing Process; Supporting New Initiatives in Nuclear Waste and the Cleanup of Three Mile Island; Improving Related Regulatory Tools; and Safeguards..The policy section is intended to establish a general framework for NRC managers to shape their own particular programs.
Planning guidance is furnished in those areas where the Commission believes more detail is warranted to meet specific concerns about schedules and priorities or where major assumptions a"e needed for program development.
Specific guidance involving programs will be provided by the Executive Director for Operations.
The EDO will also develop and provide a management system for the Commission to keep track of the major 1982 program accomplishments and resource expenditures that support this policy and planning guidance.
It is the Commission's intention that nuclear regulation reflect a continuing comnitment to come to grips with the reality of nuclear technology and of its relationship to those who control it, to those who work with it; to those who live near it, and to the general public.
This commitment requires not only an open and effective approach within the agency, but an approach to the public (including the regulated public) that permits more efficient decisionmaking. As part of this process, the Commission must state its basic assumptions and criteria clearly, amend them when the facts so require, and live by them consistently and forthrightly in all activities.
1 I
A
. To carry out the policy of the Commission will require the dedicated effort of all employees as well as the effective and efficient use of all NRC resources.
Innovative, attentive and responsive management effort will be required to accomplish the Commission's goals.
NRC's greatest resource is its employees.
Retention of our most creative and productive talent and the recruitment of new personnel with fresh insights and perspectives should be a management priority. To maintain a highly qualified and informed staff, the Commission's most creative and productive employees should be recognized and provided further opportunity for development.
Increased effort should be expended, in the face of highly competitive conditions, to hire the best qualified individuals essential to the future ability of the NRC to carry out its regulatory responsibilities.
SAFE OPERATION OF LICENSED PLANTS Policy A.
NRC's fundamental task is to make sure that existing plants and those coming on-line operate safely.
To this end, the highest priority will be given to assuring that operating facilities achieve and maintain adequate levels of protection of public health and safety.
Planninc Guidance 1.
NRC on-site inspection of operating reactors will focus directly on the activities and operations of licensees, licensee contractors, and vendors.
NRC will improve its own capabilities for independent and confirmatory measurements. The analysis of operational data and systematic assessment of licensee performance will be used to help focus inspections and to allocate inspection resources.
2.
The NRC and the industry must continue to learn the lessons that l
cnly experience can teach.
Efforts to collect, analyze, disseminate, j
and act upon operational data relevant to the safe operation of major licensed facilitie; must continue to receive priority attentien.
The framing of effective regulations must be based on a close study of operating experience.
3.
NRC will continue to operate and improve, as needed, a Licensee Event Reporting (LER) system. NRC should continue to work with the Institute of Nuclear Power Operations (INPO) in its operation and development of the Nuclear Plant Reliability Data System (NPRDS).
NRC should continue to support INPO in the operation of an industry-wide screening service to identify LERs and other operating experience
- of significance to nuclear power plant licensees.
. 4.
The NRC must develop a long range human factors program plan by mid 1982.
INP0 and the NRC both have programs for developing standards and requirements in the human factors area. These programs should be coordinated.
In some areas it may be sensible to conduct activities in parallel and in others it may be appropriate to drop the NRC program should INP0's efforts be acceptable.
(a) The NRC should make maximum use of available human factors data.
(b) Alternative approaches exist for resolving certain human factors concerns, e.g., in the operator licensing area either the NRC or its contractors could administer examinations or individuals in the industry approved by NRC could undertake this activity. Where fundamentally different approaches are possible, the staff should prepare policy papers as scon as practicable'for Commission consideration which recommend a course of action.
(c) The staff should continue to evaluate and improve the licensing and training requirements for reactor operators.
Resource efficient methods should be pursued which will provide improved initial and requalification testing of operators.
(d) NRC should require key licensee employees including certain management and maintenance personnel to be adequately qualified.
NRC will examine the possible need for qualifying these key employees and working with industry (e.g., INPO) to develop some form of licensing or certification.
5.
Utility management performance needs to be evaluated to assure the quality of operation of nuclear facilities.
Utility managers and supervisors as well as operators should be encouraged to improve their ability to promptly diagnose and deal with off-normal conditions.
6.
As applied to operating reactors, the goal of NRC's enforcement program will be to assure compliance with NRC regulations and license conditions and to use experience gained from application of the enforcement policy to evaluate and revise the policy and make it more effective.
For licensees who do not comply with NRC requirements, prompt and vigorous action will be taken; a licensee must not benefit by violating NRC requirements. Licensees who cannot achieve and maintain an adequate level of _ protection of public health and i
safety will not be permitted to operate.
7.
The Commission supports the systematic evaluation program for operating reactors. The program should continue at its, current pace. The goals and objectives of the program should be met expeditiously.
. 8.
The staff should expedite the assessment of pressurized thermal shock, so that the Commission can consider if actions need to be taken to protect the public health and safety.
NEAR-TERti LICENSING PROBLEMS AND RESPONSES Policy A.
.The NRC intends that its regulatory processes be efficient and cost effective. Unnecessary regulatory burdens are to be avoided, and NRC regulations should allcw licensees to select the most cost effective ways to satisfy NRC safety objectives.
At the same time, pressure to issue new licenses will not be allowed to compromise safety.
Plannino Guidance 1.
Actions should be taken to eliminate all unwarranted delay 'in reaching regulatory decisions.
2.
Consistent with maintaining safety of operating plants, staff reviews and public hearings should be completed on a schedule that assures the licensing process will not unnecessarily be a critical path item which would delay reactor startup.
Recognizing that the length of hearings may depend on the number of contested issues, normally it should take not more than 11 months from issuance of the final supplemental safety evaluation report to an operating license decision by the Commission in contested cases. The staff should make independent estimates of construction completion dates.
3.
Licensing boards should adhere rigorously to established schedules in order to reach timely decisions, while preserving individual rights of the public to pursue valid safety issues. The Commission reaffirms its Statement of Policy on the Conduct of Licensing Proceedings of May,1981, which urged Boards to take firm hold of hearings and keep them moving.
4.
The Congress has directed that the Clinch River Breeder Reactor be built in a timely and expeditious manner as long as the public health and safety is adequately protected.
The NRC will conduct the licensing review consistent with its statutory regulatory resporsibilities and without delay.
5.
NRC will maintain an internal project management structure to oversee project reviews on an integrated plant basis, and ensure that decisions and commitments made early in the project are not
-abrogated or forgotten, thereby requiring the same issue to' be resolved more than once during a project.
1 i
, - -. ~ -.
. 6.
NRC must continue to work with FEtiA to resolve the difficulties in securing the findings for off-site emergency plans for a proposed nuclear plant site in a timely fashion.
7.
The staff is encouraged to urge applicants to conduct independent design reviews prior to selection of major systems.
The purpose should be to get applicants to understand more fully the equipment and systems which are offered by the vendors and architect-engineers.
8.
For the FY 84-86 time period, staffing proposals should decline consistent with the completion of existing reactor casework.
COORDINATING REGULATORY REQUIREMENTS Policy A.
NRC must be sensitive to criticism that there is a large volume of requirements imposed on licensees, that frequently these requirements are not coordinated, and that sufficient' time is not allowed for proper implementation of issued requirements.
Strong measures need to be taken to control the issuance of new requirements.
B.
In cases where there are conflicting priorities in establishing and implementing new requirements, priorities will be based on the expected risk reduction potential associated with the new requirement.
C.
Requirements imposed on the regulated industry by NRC are to have a positive contribution to safety, not only individually, but also when the requirements are taken as a whoia.
Requirements proposed to achieve incremental reductions in residual risk should be evaluated on a cost-benefit basis.
D.
Unresolved Safety Issues should be promptly pursued, and the solutions implemented based on a careful analysis of the costs and benefits of implementation.
Priorities for implementation should be established in light of all other requirements imposed on licensees.
E.
Issues which affect numerous licensees should be addressed in the context of rule-making as opposed to case-by-case review, Plannino Guidance 1.
In order to control and coordinate requirements imposed on licensees, a Committee for Review of Generic Requirements (CRGR) has been 4
established to review proposed requirements and recommend action by the EDO. The CRGR, chaired by the Deputy Executive Director for i
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Regional Operations and Generic Requirements (DEOR0GR), is expected to assume a central role in reviewing and recommending action in the full range of generic requirements considered by the agency, including backfitting. The EDO, assisted by the DEDR0GR, will exert strong management control over operating reactor licensing actions in order to reduce the existing backlog.
Priorities and procedures must be developed for eliminating the backlog expeditiously (i.e., by FY 84). Since the scope of the regional offices has been expanded to create agency wide regional operations that include licensing as well as inspection and enforcement functions, a significant portion of the reactor license amendment reviews should be transferred to the regional offices to assist in cleaning up the large backlog.
2.
All generic issues will be integrated in an agency-wide program.
Emphasis will be placed on implementing approved solutions to generic safety issues which have been resolved.
As a first, step in resolving existing generic issues, the staff will examine these issues and recommend to the Comission a priority list based on the potential significance and cost of implementation of each issue.
Those issues which are of marginal importance to the regulatory program will be dropped. The criteria for setting priorities should be reviewed and possibly revised.
Issues will be added to the program only after careful evaluation to assure that they warrant resource expenditures.
3.
A management system will be developed to account for all new requirements issued, their relationship to the revised Standard Review Plan, and the status of their implementation. The management system to be developed should be coordinated with the systems currently in use and should be capable of incorporating existing, ongoing regulatory requirements.
4.
Implementation schedules for new requirements will be established consistent with the safety importance of the requirement.
Licensees should be allowed sufficient time for in-depth engineering, evaluation and design, procurement of high quality equipment, and its proper installation, to the extent compatible with public health and sa fety.
In setting schedules, industry capability (e.g., engineering resources and manufacturing capacity) to implement the new requirement will be considered.
NRC's ability to review licensees' proposals and to inspect implementation will also be considered. To the extent consistent with safety implications, schedules for requirements will be set so as to avoid downtime on operating plants or delay in startup of new plants. The staff should work through owners groups to establish realistic schedules. The nuclear industry must be responsible for providing realistic estimates of time needed to achieve compliance.
Once compliance dates have been established, the Commission will vigorously enforce :uch dates.
i i
. IMPROVING THE LICENSING PROCESS Policy A.
The Commission intends to make the present licensing process for power plants more efficient.
Consideration is being given to various changes which could affect both new power plant license applications and those already under review.
For new construction permits the main elements of the improved process will be based on concepts already studied such as one-step licensing, standardization, and early site reviews.
For plants currently under review, improvements such as changes in hearing formats and the nature of technical reviews must be studied. The Commission intends to consider a legislative package for submittal to the Congress and also a set of reforms which can be implemented by the Commission without the need for legislation.
Planning Guidance 1.
A special task force will identify the issues which should be addressed in a legislative proposal as well as the specific changes that should be made internally to facilitate streamlining.
A senior Advisory Group will assist the Chairman in making specific, recommencations to :nc Ccmmission as a result of the task force's work. By January,1982 legislative proposals will be prepared.
By April,1982 recommendations for administrative remedies, together with the necessary paper work to implement them, will be ready.
2.
In anticipation that legislation will be enacted which provides for increased use of standardization and early siting in connection with one-step licensing starting in FY-84, the staff should examine its existing authority and regulations, identify resource requirements, and determine what changes are needed to un.dertake such reviews.
SUPPORTING NEW INITIATIVES Waste Management Policy A.
The NRC waste management program is critical to the success of an urgent national task. NRC will organize and plan its waste management program to be consistent with the Executive Branch's program as approved by Congress. NRC's waste management program will be based on the premise that, in the absence of unresolved safety concerns, the NRC regulatory program will not delay implementation of the Executive Branch's program.
NRC high-level waste management efforts will focus on the review of DOE site characterization activities and the development of methods to implement licensing criteria for high-level waste repositories. These criteria will be based on a defense-in-depth strategy that requires thorough consideration of various types of sites, demonstrated capabilities of the waste form selected, and the interaction of the waste form and packaging with the geological, hydrological, and engineerod systems involved.
9.
t Plannino Guidance 1.
The Commission will expeditiously complete the rulemaking on the storage and disposal of nuclear waste (Waste Confidence Proceeding).
2.
The planning basis for waste management activities will be that during FY 82-85, three site characterization reports for a high level waste repository will be submitted to NRC for review.
NRC should publish a final rule before January,1983 covering the technical criteria for high-level waste repositories. The staff should war.k with the technical community and the public to develop methods and tests needed to demonstrate compliance with the regulations.
Af ter site characterization, the staff will be prepared to review a license application to obtain construction authorization for a high-level waste storage facility. The NRC review and hearing process should permit a decision on issuing a construction authorization within three and one half years of receiving the license ap. plication from 00E. Should the Congress pass legislation requiring an earlier decision than presently planned for, the staff should inform the Commission of any obstacles which may exist preventing compliance with the law.
3.
Published projections of spent fuel storage requirements indicate that, using currently approved technology, existing reacter storage basins can be mbdified to accommodate discharged fuel until about the mid 1980s.
Lenger-term storage will involve proposed new storage pools and the development of dry storage technologies. A licensing capability for independent spent fuel storage facilities exists which will permit the NRC to act'promptly on applications for new storage facilities.
The NRC must be prepared to review industry or government proposals for away-from-reactor or at-i reactor independent spent fuel storage facilities.
Because of the lead time for design, licensing and construction, at least one application for a new spent fuel storage facility is expected by 1983. Licensing review will also be required for developmental facilities and work involving the storage of spent fuel in dry storage casks.
TMI-2 Cleanuo Policy A.
The content of the containment at TMI-2 is a potential safety and health hazard to the public.
Expeditious cleanup of the TMI-2 reactor is one of NRC's highest safety priorities. While direct responsibility for cleanup rests with the licensee, NRC will provide oversight and support to ensure decontamination of the facility as well as safe and timely removal of radioactive products from the site.
_g-B.
NRC should work closely with DOE to reach timely decisions on the disposition of reactor fuel.
Planning Guidance 1.
NRC will continue monitoring site cleanup activities through a dedicated TMI program office.
The staff should encourage timely completion of reactor building water processing and timely start of containment decontamination (both by mid FY 82).
NRC should urge the licensee to submit plans and schedules in mid-FY 83 for reactor head removal. The NRC staff will review these plans and make recommendations to the Commission within three months.
Planning for upper internals removal should begin by the end of FY 83, with a goal of having the upper internals removed during FY 84.
Since the pace of cleanup is dependent upon licensee's funding ability, the licensee's financial condition will be monitored closely by NRC.
2.
NRC will closely monitor the agreement with DOE which calls for removal of high specific activity wastes for research and development, including complete removal of the Epicor liners remaining from the processing of auxiliary building water and the submerged demineralizer i
system liners after completion of water processing. The objective of NRC's monitoring is to help assure that the wastes are expedittously removed from the site. NRC should work toward the goal of assuring that DOE will assume responsibility for offsite disposition of the damaged core.
IMPROVING RELATED REGULATORY TOOLS Safety Goal l
Policy A.
The Ccamission has decided to develop a safety goal and related i
safety guidance with initial emphasis on individual and societal risks which might arise from reactor accidents. The purpose of this project is to develop a general approach to risk acceptability and safety-cost tradeoffs, and, to the extent possible, to specify l~
qualitative safety goals and quantitative safety guidance and standards for review of rules and practices.
Planning Guidance 1.
Simultaneously with obtaining public comment on safety goals the staff should prepare for Commission review a step-by-step action plan describing how it intends to use the goals and numerical guidance within the regulatory process.
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2.
Qualitative safety goals and associated quantitative numerical guidance, when approved by the Commission, should be used in the i
evaluation of proposed and existing NRC reactor safety requirements.
Risk Assessment Policy A.
Probabilistic risk assessment is an important tool for weighing risks against one another and for defining achieved safety levels.
i Quantitative risk assessrent techniques will be used to estimate the relative importance of potential nuclear power plant accident sequences.
__ Planning Guidance 1.
Special attention should be given to using probabilistic as,sessment techniques where the data warrants such use and in areas especially amenable to risk assessment, e.g., in licensing reviews as appropriate, dealing with generic safety issues, formulating new regulatory requirements, assessing and revalidating or eliminating existing regulatory requirements, evaluating new designs, and formulating reactor safety research and inspection priorities.
Siting Policy i
Policy A.
Siting criteria for nuclear power plants and other major nuclear facilities need improvement.
The staff has been working to prepare in the very near term modified regulations concerning the siting of nuclear power plants. The Commission has decided to better define its safety objectives and better characterize the radioactive source term before proceeding with new siting regulations.
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Planning Guidance 1.
The radioactive source term should be reassessed by early 1983.
2.
Based on the safety goal and the formulation of a new radioactive source term, a proposed siting rule should be published by late 1983.
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g yuan Ev3 ssdranceiy/
I Policy helNRCiand]ty@Q@thsiNimple, mentation;i.TheiNRC-must encourage ~g ts tpeng thengthe i gQual-i tyy As s ura nce;p ro g rams with spectric attention to' the industry to be more aggressive in assuring the adequacy of design, construction, and operation. Quality Assurance programs for plants under construction and awaiting licensing review must receive priority attention to ensure that the plants can be operated with minimum risk to the public health and safety and that costly licensing delays are' avoided.
Planning Guidance 1.
The fiRC staff will review its Quality Assurance efforts and propose an agency-wide plan by early 1982.
2.
NRC will develop a program for the systematic review of its' Quality Assurance requirements and licensin9 Suidelines.
3.
NRC will coordinate with industry to the maximum extent possible in seeking solutions to the Quality Assurance problems currently being experienced by plants under design and construction.
In the event that these activities prove to be unsatisfactory, consideration should be given to requiring that industry have independent performance audits of their QA activities.
4.
The NRC staff will develop improved inspection and licensing initiatives 4
to ensure the increased effectiveness of utility management control systems. This may include obtaining contracted assistance to evaluate the effectiveness of utility management control systems at selected plants presently under construction.
f Research N
Policy _
A.
The research program will continue to eiphasi:e support of the safety of cperating reactors and other operating facilities.
The 4
j purpose of the research program is to assist in establishing regulations for existing and future facilities.
.I planning Guidance 1.
In view of general budgetary considerations, the agency must be l
prepared to carry out its research mission with fewer resources.
This can be accomplished through more business-like methods, consolidation and coordination of programs with industry and other agencies, and the elimination of marginal programs.
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. 2.
The first priority for NRC research efforts will be light water reactor safety.
3.
Resource requests to support fast breeder reactor application in the FY 84-85 budget should be consistent with Administration plans.
The staff should identify its research and information needs related to: the licensing of breeder reactors, waste, and reprocessing facilities; notify the Department of Energy of these requirements; and to the maximum extent possible, have COE provide the needed research and information.
4 NRC will develop and maintain a long-range research plan to assure that agency resources are being properly directed toward areas of importance to the licensing and inspection processes. The research plan will be revised and updated annually and subjected to agency-wide review and be approved by the Comission.
Research undertaken by the staff will be consistent with the approved long-range research I
plan.
SAFEGUARDS International Folicy A.
With respect to its international responsibilities, the NRC re-cognizes that the proliferation of nuclear explosive devices posas i
a threat to the security interests of the United States. Hence, the NRC will continue to discharge its statutory licensing responsibilities to ensure that effective controls are applied to the import and export of nuclear materials, equipment, and facilities; the NRC will also seek to support the reliability of the U.S. in meeting its supply comitments to nations which adhere to effective non-proliferation policies by implementing procedures that facilitate the timely processing of export licenses. NRC supports the President's commitment to work with other nations to help the IAEA improve the international safeguards regime.
Plannino Guidance 1.
Reviews and assessments relating to the applicable criteria mandated in the Nuclear Non-Proliferation Act of 1978 will be conducted.
i 2.
Staff, in consultation with appropriate Executive Branch agencies, will work to develop NRC recommendations for strengthening IAEA safeguards.
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Domestic Policy A.
The Comission considers e,afeguards an integral and ongoing element of its responsibility for protection of the public.
Safeguards regulation should be conducted with the same philosophy as safety regulation.
Plannino Guidance 1.
Emphasis should be given to performance requirements rather than.
prescriptive requirements to place the responsibility on licensees to select the most cost effective ways to satisfy NRC requirements.
2.
The completion of the remaining elements of the basic safeguards-related regulations -- control of the " insider" and the material control and accounting reform amendments -- should be expedited.
The " insider" rule will be submitted to the Commission by June, 1982. The material control and accounting reform amendT.ents should be submitted to the Comission by March,1983.
3.
Recognizing the n' umber of staff organi:ational elements, federal agencies, state agencies, and local agencies which may become involved in a safeguards event, staff should examine its safeguards emergency planning to assure the establishment of clear lines of responsibility, authority, and communications.
4.
Evaluaticn of safeguards events will serve as a basis for regulatory change and response. This evaluation should include domestic events -- within both the defense and the regulated community --
and foreign events. The staff should not engage in any intelligence activities but rely on the intelligence comunity for appropriate information.
5.
By June 1982, staff should recommend to the Comission its safeguards information needs.
Staff should assure that information needs are coordinated with other responsible agencies and provide a basis for.
agency decisions during safeguards events.
6.
The fundamentals of quality assurance will be used in licensee safeguards programs.
Principal among these fundamentals are emphasis on appropriate licensee management comitment to safeguards and independent safeguard audits by licensees.
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7.
Staff, in addition to assuring that safeguards plans are in place l
at operating facilities and for transportation, will accelerate its independent assessment that these implemented plans meet safeguards
~l objectives and that safeguards regulations adequately support those objectives,
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8.
The effectiveness of the safeguards system, just as the safety i
system, is highly dependent on the performance of the human factor.
Staff should assure that lessons learned from the reac' tor human i
factors program are incorporated as appropriate, in the safeguards l
program.
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'O U.S. NUCLE AR REGUL ATORY COMMISSION i
NUREG-088c~
BIBUOGRAPHIC DATA SHEET Issue 1 l
4 TITLE ANO SU8 TITLE (Aas Vo,i,me Na../ worastaael
- 2. (Leave Dimet i
U. S. Nuclear Regulatory Commission Policy and Planning Guidance 1982 3 RECIPIENT S ACCESSION NO.
7 AUTHORtS)
- 5. DATE REPORT COMPLE TED l v'b The Comission Ynu"ary l
- 9. PERFORMING ORGANt2A DON NAME AND MAILING ADORESS //ncruce 20 Cooes OATE REPORT ISSUED U. S. Nuclear Regulatory Commission 3[nu"arv l'19 2 clashington, D. C. 20555
- 6. ILeave beenkt 8 (Leave Drache 12 SPCNSCRING CRGAN12 ATION NAME AND MA6 LING A00RESS linctuoe I,o Cooel i
4 j
11 CCNTRACT NO i
13 TYPE CF REPCRT Pg asCD Cova st o !sectusere dams!
l Regulatory j
15 SUPPLEVENTARY NOTES 14 /Lesve esmas 16 A 8STR ACT f)Cd evcMs o.,ess)
The purpose of this document is to provide guidance to the staff for establishing i
priorities and for improving the regulatory process.
It is management guidance l
intenced to focus on specific areas where the Commission believes additional emphasis is required. The document is organized in terms of seven major themes: Safe Opera-i tion of Licensed Plants; Near-Term Licensing Problems and Responses; Coordinating l
Regulatory Requirements; Improving the Licensing Process; Supporting New Initiatives in Nuclear Waste and the Cleanup of Three Mile Island; Improving Related Regulatory Tools; and Safeguards. The policy section is intended to establish'a general i
framework for NRC managers to shape their own particular programs. Planning guidance is furnished in those areas where the Commission believes more detail is warrarted to meet specific concerns about schedules and priorities or where major l
assumptions are needed for program development. Guidance with respect to each and every activity within NRC is not furnished, since it is not intended that the docu-ment be all inclusive. However, this should not be perceived as a Commission belief that other areas are not as important to protecting the public health and safety. Many of the other areas have effective ongoing programs where major problens
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do not exist but adecuate management attention and initiative are still important.
f 17 KEY WOROS AND COCUMENT ANALYSIS 17e DESCRiPTORS i
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1 C?SE$/F5AR Procedures define the actions necessary to identify, resolve, and i
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cicsecut deficiencies in characteristics, documentation, or procecures wnich rencer the quality.of an item unacceptable or indeteminate.
When required by specific precedures/ instructions, items, identified as i
unsatisfactory or incccplete and which can be corrected within a reasonable period of time may be icentified on an inspection report s
i and/or deficiency report. A nonconfomance report is used to dccument
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deficiencies unless ancther method is prescribed by a specific
/
procedure / instruction.
it Items identified on a ncnconfomance report are tageed and segrecated
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where practical as defined in section 17.1.14, " Inspection anc Test l
Status" and Section 17.1.13, " Handling, Storage, and Shipping."
Folicwing disposition of ncnconformance reports, specified reviews and appro<als are peccedurally required for 1)
"use as is" and " repair,"
and 2)
" rework."
Ucen ccepletion of acticn required for disposition, recaired er reworked items are reinspected to verify that specified action and requirements are ccmplied with.
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Procedures require " trending" of deficiencies identified on ncnconfomance reports, deficiency reports, and inscection reports to j
identify trends adverse t: quality.
i Precedures recuire the initiation of a ccrrective action recuest for significant or chronically repetitive nonc:nformances as cefined in 3
Section 17.1.16.
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17.1-39 AME?iCMEt4T 41 j
JULY 11, 1983
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