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{{#Wiki_filter:Reference file for DPO-2020- 004 This reference file includes additional information related to the Differing Profession Opinion (DPO) Case File DPO-2020- 004 ( Agencywide Documents Access and Management System (ADAMS) Accession No. ML22056A017). The below table provides a roadmap of publicly available information referenced in the DPO casefile. It includes a brief description of the information, where that information is referenced in the DPO casefile, and where that information can be located. The identified locations of the DPO casefile where particular information is discussed are provided for information only and may not be exhaustive.
{{#Wiki_filter:Reference file for DPO-2020-004 This reference file includes additional information related to the Differing Profession Opinion (DPO) Case File DPO-2020-004 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22056A017). The below table provides a roadmap of publicly available information referenced in the DPO casefile. It includes a brief description of the information, where that information is referenced in the DPO casefile, and where that information can be located. The identified locations of the DPO casefile where particular information is discussed are provided for information only and may not be exhaustive.
DPO-2020-004 Case File PDF Page Number Brief Description Location 3, 7, 23-24, 26, 40, 44, 66, 79, 80, 84, 87, 91, 96-97,100 SECY-93-087, Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water Reactor (ALWR) Designs (Apr. 2, 1993).
ADAMS Accession No. ML003708021 3, 21-22, 35, 40-41, 44-45, 59-60, 62, 64-65, 67, 73-75, 82-83, 91-92, 96-97, 100 Staff RequirementsSECY-93-087 Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water Reactor (ALWR) Designs (July 21, 1993).
ADAMS Accession No. ML003708056 3, 22, 35, 41, 45-46, 59-65, 67, 73-74, 91, 101 DC/COL-ISG-020, Interim Staff Guidance on Implementation of a Probabilistic Risk Assessment-Based Seismic Margin Analysis for New Reactors (May 2010).
ADAMS Accession No. ML100491233 3, 22, 45, 67, 100-101 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 19.0, Probabilistic Risk Assessment and Severe Accident Evaluation for New Reactors (Dec. 2015).
ADAMS Accession No. ML15089A068 10-12, 14-15, 16, 19-20, 23, 26, 53, 56, 67, 80, 82, 87 Stanford Seismic Design Guidelines (for Engineers & Architects), by Stanford University, (Jan. 2020).
https://lbre.stanford.edu/sites/lb re-production/files/publications/sd g january 2020.pdf) 14-16, 19-20, 24, 27, 56, 67, 82, 84-85, 105, 107, 109-110 Vancouver House, by Geoff Poh, P.Eng., Structure (Jan. 2020).
https://www.structuremag.org/w p-content/uploads/2019/12/27200 1-F-Vancouver.pdf 14, 16-17, 19, 20, 27, 51-52, 66, 82, 84, 85, 107, 109-110 Salesforce Tower by Ron Klemencic, P.E., S.E., Michael T. Valley, P.E. and John D. Hooper, P.E., S.E.; Structure (June 2017).
https://www.structuremag.org/w p-content/uploads/2017/05/F-Salesforce-Jun17.pdf 1


DPO-2020-004 Case File PDF Brief Description Location Page Number 3, 7, 23-24, 26, 40, SECY-93- 087, Policy, Technical, and 44, 66, 79, 80, 84, Licensing Issues Pertaining to ADAMS Accession No.
DPO-2020-004 Case File PDF Page Number Brief Description Location 15, 23, 27, 49-50, 66 NEHRP Recommended Seismic Provisions for New Buildings and Other Structures FEMA P-750 / 2009 Edition.
87, 91, 96-97,100 Evolutionary and Advanced Light-Water ML003708021 Reactor (ALWR) Designs (Apr. 2, 1993).
https://www.fema.gov/node/neh rp-recommended-seismic-provisions-new-buildings-and-other-structures 21, 27, 86 ACI Presidents Memorandum Concrete International (Jan. 2020).
3, 21-22, 35, 40-41, Staff Requirements SECY-93-087 44-45, 59-60, 62, Policy, Technical, and Licensing Issues ADAMS Accession No.
https://www.concrete.org/news/
64-65, 67, 73-75, Pertaining to Evolutionary and AdvancedML003708056 82-83, 91-92, 96-Light-Water Reactor (ALWR) Designs 97, 100 (July 21, 1993).
newsdetail.aspx?f=51723494 34, 44-45, 64, 67 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 3.8.4, Other Seismic Category I Structures (Sept. 2013).
3, 22, 35, 41, 45 - DC/COL-ISG-020, Interim Staff Guidance 46, 59-65, 67, 73 -on Implementation of a Probabilistic Risk ADAMS Accession No.
ADAMS Accession No. ML13198A258 40, 88 Emails between the DPO submitter, the DPO submitters supervisor, and other staff during the safety review of the NuScale application in 2017 and 2018.
74, 91, 101 Assessment-Based Seismic Margin ML100491233 Analysis for New Reactors (May 2010).
Pages 5 - 7 of this document 40, 41, 42, 88 Email and email attachment from DPO submitter to the DPO panel members with additional clarifications and information.
NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports 3, 22, 45, 67, 100- for Nuclear Power Plants: LWR Edition, ADAMS Accession No.
Pages 8 - 13 of this document 46, 49-50, 53, 66 FEMA P-695, Quantification of Building Seismic Performance Factors:, (June 2009).
101 Section 19.0, Probabilistic Risk ML15089A068 Assessment and Severe Accident Evaluation for New Reactors (Dec. 2015).
https://www.fema.gov/sites/defa ult/files/2020-08/fema earthquakes quantific ation-of-building-seismic-performance-factors-fema-p-695.zip 46, 60, 66 EPRI Report NP-6041, Nuclear Plant Seismic Margin R-1, (Aug. 1991).
10-12, 14-15, 16, Stanford Seismic Design Guidelines (forhttps://lbre.stanford.edu/sites/lb 19-20, 23, 26, 53, Engineers & Architects), by Stanford re-56, 67, 80, 82, 87 University, ( Jan. 2020). production/files/publications/sd g january 2020.pdf) 14-16, 19-20, 24, https://www.structuremag.org/w 27, 56, 67, 82, 84 -Vancouver House, by Geoff Poh, p-85, 105, 107, 109-P.Eng., Structure (Jan. 2020). content/uploads/2019/12/27200 110 1-F-Vancouver.pdf 14, 16-17, 19, 20, Salesforce Tower by Ron Klemencic, https://www.structuremag.org/w 27, 51-52, 66, 82, P.E., S.E., Michael T. Valley, P.E. andp-content/uploads/2017/05/F-84, 85, 107, 109-John D. Hooper, P.E., S.E.; Structure Salesforce-Jun17.pdf 110 (June 2017).
https://www.epri.com/research/
DPO-2020-004 Case File PDF Brief Description Location Page Number NEHRP Recommended Seismic https://www.fema.gov/node/neh 15, 23, 27, 49-50, Provisions for New Buildings and Other rp-recommended-seismic-66 Structures FEMA P-750 / 2009 Edition. provisions-new-buildings-and-other-structures
products/NP-6041-SLR1 46, 66 National Institutes of Standards and Technology (NIST), Evaluation of the FEMA P-695 Methodology for Quantification of Building Seismic Performance Factors (Nov. 2010).
 
https://www.nehrp.gov/pdf/nistg cr10-917-8.pdf 47-48, 67 Villaverde, Roberto, Methods to Assess the Seismic Collapse Capacity of Building Structures: State of the Art, American Society of Civil Engineers (ASCE), J.
21, 27, 86 ACI Presidents Memorandum Concrete https://www.concrete.org/news/
Struct. Eng., 133(1):57-66.
International (Jan. 2020). newsdetail.aspx?f=51723494
https://doi.org/10.1061/(ASCE) 0733-9445(2007)133:1(57) 2
 
NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports ADAMS Accession No.
34, 44-45, 64, 67 for Nuclear Power Plants: LWR Edition, ML13198A258 Section 3.8.4, Other Seismic Category I Structures (Sept. 2013).
Emails between the DPO submitter, the 40, 88 DPO submitters supervisor, and other Pages 5 - 7 of this document staff during the safety review of the NuScale application in 2017 and 2018.
 
Email and email attachment from DPO 40, 41, 42, 88 submitter to the DPO panel members with Pages 8 - 13 of this document additional clarifications and information.
https://www.fema.gov/sites/defa FEMA P-695, Quantification of Building ult/files/2020-46, 49-50, 53, 66 Seismic Performance Factors:, (June 08/fema earthquakes quantific 2009). ation-of-building-seismic-performance-factors-fema-p-695.zip
 
46, 60, 66 EPRI Report NP-6041, Nuclear Plant https://www.epri.com/research/
Seismic Margin R-1, ( Aug. 1991). products/NP-6041-SLR1
 
National Institutes of Standards and Technology (NIST), E valuation of the https://www.nehrp.gov/pdf/nistg 46, 66 FEMA P-695 Methodology for cr10- 917-8.pdf Quantification of Building Seismic Performance Factors (Nov. 2010).


Villaverde, Roberto, Methods to Assess the Seismic Collapse Capacity of Building https://doi.org/10.1061/(ASCE) 47-48, 67 Structures: State of the Art, American 0733-9445(2007)133:1(57)
DPO-2020-004 Case File PDF Page Number Brief Description Location 58, 59, 66 Anderson, Lisa, et al., Consideration of Component Level vs. Element Level Stresses in Concrete Nuclear Safety-Related Structures Under High Seismic Loading, Presented at the 2018 DOE-NRC Natural Phenomena Hazards Meeting, October 23, 2018.
Society of Civil Engineers (ASCE), J.
https://www.energy.gov/sites/pr od/files/2019/01/f58/7%20Consi deration%20of%20Component
Struct. Eng., 133(1):57-66.
%20Level%20vs.%20Element
DPO-2020-004 Case File PDF Brief Description Location Page Number https://www.energy.gov/sites/pr Anderson, Lisa, et al., Consideration of od/files/2019/01/f58/7%20Consi Component Level vs. Element Level deration%20of%20Component Stresses in Concrete Nuclear Safety- %20Level%20vs.%20Element 58, 59, 66 Related Structures Under High Seismic %20Level%20Stresses%20in%
%20Level%20Stresses%20in%
Loading, Presented at the 2018 DOE-20Concrete%20Nuclear%20Saf NRC Natural Phenomena Hazards ety-Meeting, October 23, 2018. Related%20Structures%20Und er%20High%20Seismic%20Loa ding.pdf NuScale Final Safety Analysis Report (Rev. 3) - Part 02 - Tier 2 - Chapter 03 - Design of ADAMS Accession No.
20Concrete%20Nuclear%20Saf ety-Related%20Structures%20Und er%20High%20Seismic%20Loa ding.pdf 58, 67 NuScale Final Safety Analysis Report (Rev. 3) - Part 02 -Tier 2 - Chapter 03 - Design of Structures, Systems, Components and Equipment - Appendices 3A - 3C -
58, 67 Structures, Systems, Components and ML19248B833 (Package)
Equipment - Appendices 3A - 3C -
Design Reports and Critical Sections Details, (Sept. 30, 2019).
Design Reports and Critical Sections Details, (Sept. 30, 2019).
EPRI Report TR-103959, Methodology https://www.epri.com/research/
ADAMS Accession No. ML19248B833 (Package) 60, 66 EPRI Report TR-103959, Methodology for Developing Seismic Fragilities (June 1994).
60, 66 for Developing Seismic Fragilities ( June products/1022995 1994).
https://www.epri.com/research/
 
products/1022995 60, 66 NUREG/CR-5720, Assessment of Seismic Margin Calculation Methods (March 1989).
NUREG/CR-5720, Assessment of ADAMS Accession No.
ADAMS Accession No. ML20248D089 61,66 ASCE 43-19, Seismic Design Criteria for Structures, Systems, and Components in Nuclear Facilities (2019).
60, 66 Seismic Margin Calculation Methods ML20248D089 (March 1989).
https://ascelibrary.org/doi/epdf/
 
10.1061/9780784415405 71, 79, 81, 88 Document from DPO submitter explaining fundamental differences between DPO and DPO Panels Report (attachment to email from DPO submitter to NRR Office Director).
ASCE 43-19, Seismic Design Criteria for https://ascelibrary.org/doi/epdf/
ADAMS Accession No. ML21132A136 79, 81 Email from DPO submitter to NRR Office Director.
61,66 Structures, Systems, and Components in 10.1061/9780784415405 Nuclear Facilities ( 2019).
Page 14 of this document 88, 108 Email from DPO submitter to staff Page 15 of this document 88, 108 Email from staff to DPO submitter Page 16 of this document N/A Email from DPO submitter to the DPO appeal review team responding to questions on the DPO.
Document from DPO submitter explaining fundamental differences between DPO ADAMS Accession No.
Pages 17 - 18 of this document 3
71, 79, 81, 88 and DPO Panels Report (attachment to ML21132A136 email from DPO submitter to NRR Office Director).
 
79, 81 Email from DPO submitter to NRR Office Director. Page 14 of this document
 
88, 108 Email from DPO submitter to staff Page 15 of this document
 
88, 108 Email from staff to DPO submitter Page 16 of this document Email from DPO submitter to the DPO N/A appeal review team responding to Pages 17 - 18 of this document questions on the DPO.
DPO-2020-004 Case File PDF Brief Description Location Page Number Email Attachment to email from DPO N/A submitter to the EDO appeal review team, Pages 19 - 23 of this document EDO question on my DPO and my answer.


Email Attachment to email from DPO N/A submitter to the EDO appeal review team, Pages 24 - 54 of this document Performance-Based Seismic Design of Seismic Category I Structures.
DPO-2020-004 Case File PDF Page Number Brief Description Location N/A Email Attachment to email from DPO submitter to the EDO appeal review team, EDO question on my DPO and my answer.
Pages 19 - 23 of this document N/A Email Attachment to email from DPO submitter to the EDO appeal review team, Performance-Based Seismic Design of Seismic Category I Structures.
Pages 24 - 54 of this document N/A Email from EDO to NRR Office Director.
ADAMS Accession No. ML22082A178 N/A Staff Response to Taskings in Decision on Differing Professional Opinion Appeal Concerning (DPO2020004)
ADAMS Accession No. ML22062A007 4


N/A Email from EDO to NRR Office Director. ADAMS Accession No. ML22082A178
Disagreement with the Deputy Directors Response and Conclusion I (the NCP submittal) appreciate the response from the Deputy Director. I believe his conclusions are wrong because (1) he neglected the facts that are presented in the NCP submittals, and he did not dispute those facts, and (2) his understanding and interpretation of the NRC policy in SRM SECY 93-087, SRP, structural engineering, PRA, and the GL 88-20 and IPEEE are improper. These will be stated and discussed below.
The Deputy Director stated, I have read through the references in this NCP, as stated on page 12 of 13 in this NON-CONCURRENCE PROCESS. If he did, he should know the following facts as stated and described in those references:
: 1. The fundamental goal of building design is to achieve no collapse.
: 2. The structural engineering analysis/design method is the tool to achieve that goal.
: 3. The PRA method is to evaluate the consequence of a building collapse, such as the probabilistic risks of nuclear core damage resulting from the collapse of the NuScale reactor building, or its structural members such as roofs, floors, and walls, but is not intended to predict and cannot predict the building behaviors (responses) and collapse during earthquakes.
: 4. Important buildings are designed for a maximum considered earthquake (MCR), which equals a minimum magnitude of 1.5 times the acceleration of its design basis earthquake ground motions, as a required seismic margin, using the structural engineering analysis/design method. That magnitude, or seismic margin, is increased proportionally for buildings whose collapse could cause significantly more death.
: 5. The NRC policy specified that magnitude or seismic margin to be 1.67, or (RLE = 1.67 x SSE) in SRM SECY 93-087.
: 6. The shield building of AP1000 and the containment building of KHNP demonstrated that they could sustain RLE with no collapse through structural engineering analysis/design methods.
: 7. The staff of the PRA group stated that the NuScale reactor building should not be allowed to collapse during the RLE.
: 8. The NRO management (SEB Chief and an Acting Director) ordered me not to request the NuScale applicant to demonstrate that the reactor building could sustain RLE with no collapse using the structural engineering analysis/method. Instead they wanted to use a PRA approach.
I believe that the management was wrong because (1) its order is against the safety principle of building design for not using a seismic margin of 1.5 or 1.67, (2) replacing the structural engineering analysis/design method that has been used by the worldwide structural engineering community (practicing licensed professional engineers and building officials) by a PRA method that cannot predict building behaviors (responses) or collapse of a building during earthquakes, and (3) and its order caused no demonstration that the building will not collapse beyond the SSE.
The Deputy Director did not dispute any facts as stated in item 1 through 8 but only tried to justify that the NRO managements order to be proper. He misinterpreted the policy and the SRP and offered his improper understanding and interpretation of how the reactor building should be designed with respect to the RLE. He further tried to use GL-88-20 and IPEEE that 10


Staff Response to Taskings i n Decision ADAMS Accession No.
were issued and practiced more than 30 years ago to resolve the current unanalyzed/undersigned problems of the NuScale reactor building with respect to the RLE. His misinterpretations and improper understandings can be seen from the following excerpts of his statements:
N/A on Differing Professional Opinion Appeal ML22062A007 Concerning (DPO2020004)
: 1) NRO management indicated that the ground motion acceleration screening threshold of 1.67 times design basis SSE is a Commission policy that is implemented using the guidance in SRP Section 19.0, Probabilistic Risk Assessment and Severe Accident Evaluation for New Reactors. (page 12 of 13 in this NON-CONCURRENCE PROCES)
: 2) The agency has implemented the Commission's direction in SRM SECY 93-087 through the Standardized Review Plan (SRP) Chapter 19, dated December 2015..(page 11 of 13 in this NON-CONCURRENCE PROCESS)
: 3) Therefore, there is not a no collapse standard defined by the Commission policy approved in SRM SECY 93-087. (page 12 of 13 in this NON-CONCURRENCE PROCES)
: 4) I have concluded that SRM-SECY-93-087 does not impose a no collapse acceptance criteria for ground motion of one and two-thirds of the Design Basis SSE. (page 12 of 13 in this NON-CONCURRENCE PROCESS)
: 5) Instead, the ground motion level referenced by SRM-SECY-93-087 is intended to be used to identify design specific seismic vulnerabilities. (page 12 of 13 in this NON-CONCURRENCE PROCESS)
The Deputy Directors interpretation in item 1) is to tie the policy and the SRP Chapter 19 together as a unit, and he thus concluded that only PRA can be used related to the RLE because the SRP mentions PRA. His interpretation is incorrect because the NRC policy defines the required magnitude of the seismic margin beyond the SSE to be 1.67 or RLE = 1.67 x SSE, and it stands alone to be a requirement without the need of any SRP. SRP Chapter 19 is a document providing guidance to achieve that policy requirement. Even if the methods stated in the SRP were incorrect, it does not alter the requirement of the policy that is the RLE = 1.67 x SSE. Even if the structural engineering analysis/design method were not mentioned in the SRP, one cannot, based on that omission in the SRP, to conclude that the policy excludes the use of structural engineering analysis/design methods for RLE. The fact that SRP, Chapter 19, does mention the structural engineering analysis/design method for calculating the capacity (collapse) of a building and its structural members and they are to be evaluated by the Structural Engineering Branch further demonstrates that the Deputy Director is not only wrong in his understanding and interpretation between the policy and the SRP but also lacking the knowledge of the SRP on using the structural engineering method for predicting whether a building would collapse or not during the RLE (see proof below).
SRP Chapter 19, dated December 2015, states, The organization responsible for structural engineering supports the review of the PRA and severe accident evaluation in two main area:
the applicants evaluation of seismic contributors (specifically the seismic hazard analysis and estimation of seismic capacities (acceleration at which there is high confidence in low probability of failure [HCLPF] and the applicants analysis of containment performance. The words of structural engineering and seismic capacities are bolded and underlined by me to 11


Disagreement w ith the Deputy Directors Response and Conclusion
emphasize that the value of seismic capacities is developed by structural engineers and reviewed by the structural engineering (Branch), and then provide those capacity values to the PRA analysts (group) for their consequence analysis. The words seismic capacity in structural engineering mean collapse of a beam, a column, or the whole building, such as the NuScale reactor building, during earthquakes.
About ten (10) years ago, the applicant of AP1000 demonstrated that the shield building element could resist three (3) times SSE with no collapse through physical laboratory testing, and the whole shield building could resist three (3) times SSE with no collapse through structural engineering analysis. The KHNP containment building has a margin of strength (overstrength) of 1.44 against SSE through structural engineering analysis. In attachment 1 of reference 2 of this NON-CONCURRENCE PROCESS, a generic concrete containment with 1%
of steel reinforcement possessed a seismic margin of safety 1.54 against a far field earthquake, and 1.43 against a near field earthquake through ductility. The actual margin of safety of a building against earthquakes is the product of both overstrength and ductility. The overstrength of 1.44 times the ductility of 1.43 = 2.06. Recognizing that the KHNP containment has reinforcement more than 1% and that would decrease the ductility value, and the actual ductility value can be obtained for the KHNP containment by using the actual reinforcement in the containment through structural engineering analysis. However, with a seismic margin of 2.06 against SSE, the reduced ductility value in the KHNP containment would be still enough to make the final seismic margin greater than 1.67 times SSE, required by the NRC policy. The major portion of the above statement, with respect to the seismic margin of AP1000 shield building and KHNP containment, were documented in reference 3 of this NON-CONCURRENCE PROCESS.
Since The NRC/NRO/SEB Chief and an Acting Director refused to send the questions to the applicant to obtain seismic capacities of the reactor building and the structural members that form the building, or whether the building could sustain RLE with no collapse, thus It is unknown whether the building could sustain an earthquake beyond the SSE with no collapse.
Therefore, the Deputy Directors conclusion in item 2) above is incorrect.
The Deputy Director concluded in items 3) and 4) above that the NRC policy in SRM-SECY 087 does not require a demonstration of no collapse of the reactor building during the RLE because he did not find a no collapse criterion in it. His conclusion based on the absence of a no collapse criterion in the SRM-SECY-93-087 is just as wrong as he was tying the policy to the SRP in item 1), because the policy is to define RLE = 1.67 SSE, and it does not and should not tell structural engineers how to design buildings with what kind of criteria. The no collapse criterion belongs to the structural engineering because the goal of designing a building is to achieve no collapse. The Deputy Director should remember in the meeting, dated November 29, 2018, with the PRA staff members when they said NO in response to the question whether the NuScale reactor building could be allowed to collapse during the RLE. Therefore, the Deputy Directors conclusion in items 3) and 4) is not only wrong but also dangerous.
In item 5) above the Deputy Director believed that the REL is intended to be used to identify design specific seismic vulnerabilities without specifying the vulnerabilities that he saw. He cited 12


I (the N C P subm ittal) apprec iate the response f rom the D eputy D irec tor. I believ e his c onc lusions are w rong bec ause (1) he neglec ted the f ac ts that are presented in the N C P subm ittals, and he did not dispute those f ac ts, and (2) his understanding and interpretation of the N R C polic y in SRM SECY 93 -087, S R P, str uc tur al engineer ing, P R A, and the G L 88-20 and IPEEE are im proper. These w ill be stated and disc ussed below.
the 1988 NRC Generic Letter (GL 88-20) for performing IPEEE to find vulnerabilities and fix them. This generic letter was issued more than 30 years ago for problems related to plants that had not been designed and built for RLE, and the IPEEE was used to find and fix major seismic problems in the plants. I participated in the IPEEE walkdowns, and I know that it was a band-aid for mistakes that plants had not been designed for the RLE, and is not for the design of new plants, such as the NuScale.
The most vulnerable issue for building design is whether the whole building will collapse or not.
If the whole building will not collapse through the demonstration of the structural engineering analysis/design method, the next vulnerable issue is to check whether there are partial collapses in structural members, such as beams, columns, roofs, walls, slabs, and their connections. These vulnerabilities can be and have been identified through structural engineering analysis, and the design was revised to eliminate all the vulnerabilities until the analysis demonstrates that there is no whole building collapse or partial collapses. This is the normal process structural engineers have been doing for building design in recent decades.
Shall we design the NuScale reactor building without the RLE and then require the plant to go through the IPEEE process as stated in GL 88-20 as the Deputy Director might have suggested, or use the structural engineering analysis/design method with the RLE to ensure that it can sustain the RLE without collapse same as the method used for the design of important buildings worldwide as stated in attachments 1 and 2 in reference 2 of this Non-Concurrence Process?
The answer should be obvious. We found our mistake without designing buildings for the RLE more than 30 years ago and then tried to fix and mitigate the problem through GL 88-20 and IPEEE. Are we going to commit the same mistake for the NuScale?
The fact that no buildings, whether ordinary or important ones, has ever been designed using a PRA method, and all buildings have been designed using the structural engineering analysis/design method as described and documented in the two attachments in reference 2 of this NON-CONCURRENCE PROCESS should serve as a warning to managers who insist to replace the structural engineering analysis/design method by a PRA method for the design of the NuScae reactor building subjected to the RLE.
13


The D eputy D irec tor stated, I hav e read through the ref erenc es in this N C P, as stated on page 12 of 13 in this N O N-C O N CU RR E NC E P R O CE S S. If he did, he should k now the f ollow ing f ac ts as stated and desc ribed in those ref erenc es:
AConcreteContainmentandIts InternalStructures
: 1. The f undam ental goal of building design is to ac hiev e no c ollapse.
: 2. The struc tural engineering analy sis/design m ethod is the tool to ac hiev e that goal.
: 3. The PR A m ethod is to ev aluate the c onsequenc e of a building c ollapse, suc h as the probabilistic risks of nuc lear c ore dam age resulting fr om the c ollapse of the N uS c ale reac tor building, or its struc tural m em bers suc h as roof s, f loors, and w alls, but is not intended to predic t and c annot predic t the building behav iors (responses) and c ollapse during earthquak es.
: 4. Im portant buildings are designed f or a m ax im um c onsider ed ear thquak e ( M C R ), w hic h equals a m inim um m agnitude of 1.5 tim es the ac c eleration of its design basis earthquak e ground m otions, as a required seism ic m argin, using the struc tural engineering analy sis/design m ethod. That m agnitude, or seism ic m argin, is inc reased proportionally f or buildings w hose c ollapse c ould c ause signif ic antly m ore death.
: 5. The N R C polic y spec if ied that m agnitude or seism ic m argin to be 1.67, or (R LE = 1.67 x SSE) in SRM SECY 93-087.
: 6. The shield building of AP 1000 and the c ontainm ent building of KH N P dem onstrated that they c ould sustain R LE w ith no c ollapse through struc tural engineering analy sis/design m ethods.
: 7. The staf f of the PR A group stated that the N uSc ale reac tor building should not be allow ed to c ollapse during the R LE.
: 8. The N R O m anagem ent (SEB C hief and an Ac ting D irec tor) ordered m e not to request the N uSc ale applic ant to dem onstrate that the reac tor building c ould sustain R LE w ith no c ollapse using the struc tural engineering analy sis/m ethod. Instead they w anted to use a P R A appr oac h.
I believ e that the m anagem ent was w rong bec ause (1) its order is against the saf ety princ iple of building design f or not using a seism ic m argin of 1.5 or 1.67, (2) replac ing the struc tural engineering analy sis/design m ethod that has been used by the w orldw ide struc tural engineering c om m unity (prac tic ing lic ensed prof essional engineers and building of f ic ials) by a PR A m ethod that c annot predic t building behav iors (responses) or c ollapse of a building during earthquak es,
and (3) and its order c aused no dem onstration that the building w ill not c ollapse bey ond the SSE.
The D eputy D irec tor did not dispute any f ac ts as stated in item 1 through 8 but only tried to justif y that the N R O m anagem ents order to be proper. He m isinterpreted the polic y and the S R P and of f ered his im proper understanding and interpretation of how the reac tor building should be designed w ith respec t to the R LE. H e f urther tried to use G L-88-20 and IPEEE that were issued and prac tic ed m ore than 30 y ears ago to resolv e the c urrent unanaly zed/undersigned problems of the N uSc ale reac tor building w ith respec t to the R LE. H is m isinterpretations and im proper understandings c an be seen f rom the f ollow ing ex c erpts of his statem ents:
: 1) N R O m anagem ent indic ated that the ground m otion ac c eleration sc reening threshold of 1.67 tim es design basis SSE is a C om m ission polic y that is im plem ented using the guidanc e in SR P Sec tion 19.0, Probabilistic R isk Assessm ent and Sev ere Ac c ident Ev aluation f or N ew R eac tors. (page 12 of 13 in this N O N -CONCURRENCE PROCES)
: 2) The agenc y has im plem ented the C om m ission' s direc tion in SR M SEC Y 93-087 through the Standardized R ev iew Plan (SR P) C hapter 19, dated D ec em ber 2015..(page 11 of 13 in this N O N-CONCURRENCE PROCESS)
: 3) Theref ore, there is not a no c ollapse standard def ined by the C om m ission polic y appr ov ed in S R M S E C Y 93-087. (page 12 of 13 in this N O N -CONCURRENCE PROCES)
: 4) I hav e c onc luded that SR M-SECY-93-087 does not im pose a no c ollapse ac c eptanc e c riteria f or ground m otion of one and tw o-thirds of the D esign Basis SSE. (page 12 of 13 in this N O N-CONCURRENCE PROCESS)
: 5) Instead, the ground m otion lev el ref erenc ed by SR M-SECY-93-087 is intended to be used to identif y design spec if ic seism ic v ulnerabilities. (page 12 of 13 in this N O N-CONCURRENCE PROCESS)


The D eputy D irec tors interpretation in item 1) is to tie the polic y and the SR P C hapter 19 together as a unit, and he thus c onc luded that only PR A c an be us ed related to the R LE bec aus e the SR P mentions PR A. H is interpretation is inc orrec t bec aus e the N R C polic y defines the required magnitude of the s eis mic margin bey ond the SSE to be 1.67 or R LE = 1.67 x SSE, and it s tands alone to be a requirement w ithout the need of any SR P. SR P C hapter 19 is a doc ument prov iding guidance to ac hiev e that polic y requirement. Ev en if the methods s tated in the SR P w ere inc orrec t, it does not alter the requirement of the polic y that is the R LE = 1.67 x SSE. E v en if the s tr uc tur al engineer ing analy s is /des ign method w ere not mentioned in the SRP, one c annot, bas ed on that omis s ion in the S R P, to c onc lude that the polic y ex c ludes the us e of s truc tural engineering analy s is /des ign methods for R LE. The fac t that SR P, C hapter 19, does mention the s truc tural engineering analy s is /des ign method for c alc ulating the c apac ity (c ollaps e) of a building and its s truc tural members and they areto be ev aluated by the Struc tural Engineering Branc h further demons trates that the D eputy D irec tor is not only w rong in his unders tanding and interpretation betw een the polic y and the SR P but als o lac k ing the k now ledge of the SR P on us ing the s truc tural engineering method for predic ting w hether a building w ould c ollaps e or not during the R LE (s ee proof below ).
AConcreteShieldBuilding Figure 2 - A concrete shield building encloses a steel containment


SRP C hapter 19, dated D ec ember 2015, s tates, The organization res pons ible for str uctur al engineering s upports the rev iew of the PR A and s ev ere ac c ident ev aluation in tw o main area:
JapaneseNonLinearComputerProgramPredictions VS.SeismicShakeTableTestData(CrackPatterns)
the applic ants ev aluation of s eis mic c ontributors (s pec ific ally the s eis mic hazar d analy s is and es timation of seismic capacities (ac c eleration at w hic h there is high c onfidenc e in low probability of failure [H C LPF] and the applic ants analy s is of c ontainment performanc e. The w or ds of str uctur al engineer ing and seismic capacities are bolded and underlined by me to emphas ize that the v alue of seismic capacities is dev eloped by s tr uc tur al engineer s and r ev iew ed by the structural engineering ( B r anc h), and then pr ov ide thos e c apac ity v alues to the PR A analy s ts (group) for their c ons equenc e analy s is. The w or ds seismic capacity in s truc tural engineering mean c ollaps e of a beam, a c olumn, or the w hole building, s uc h as the N uSc ale reac tor building, during earthquak es.
Figure9-finiteelementmathematicalmode ofPCCV Figure10 similarcrackpatternsinitiated fromthepenetration ExcerptfromFigures9and10ofJohnS.Maspaper,GuidelinesforthePerformance BasedSeismicDesignofSeismicCategory IConcreteStructuresinNuclearPowerPlants


About ten (10) y ears ago, the applic ant of AP1000 demons trated that the s hield building element c ould res is t three (3) times SSE w ith no c ollaps e through phy s ic al laboratory tes ting, and the w hole s hield building c ould res is t three (3) times SSE w ith no c ollaps e through structural engineering analysis. The K H N P c ontainment building has a margin of s trength (ov ers trength) of 1.44 agains t SSE through s truc tural engineering analy s is. In attac hment 1 of referenc e 2 of this N O N-C O N CU RR E NC E P R O CE S S, a gener ic c onc r ete c ontainment w ith 1%
JapaneseNonLinearComputerProgramPredictions VS.SeismicShakeTableTestData (HorizonAccelerationResponse)
of s teel reinforc ement pos s es s ed a s eismic margin of s afety 1.54 agains t a far field earthquak e, and 1.43 agains t a near field earthquak e through duc tility. The ac tual margin of s afety of a building agains t earthquak es is the produc t of both ov ers trength and duc tility. The ov ers trength of 1.44 times the duc tility of 1.43 = 2.06. R ec ognizing that the KH N P c ontainment has reinforc ement more than 1% and that w ould dec reas e the duc tility v alue, and the ac tual duc tility v alue c an be obtained for the KH N P c ontainment by us ing the ac tual reinforc ement in the c ontainment through structural engineering analysis. H ow ev er, w ith a s eis mic margin of 2.06 agains t SSE, the reduc ed duc tility v alue in the KH N P c ontainment w ould be s till enough to mak e the final s eis mic margin greater than 1.67 times SSE, required by the N R C polic y. The major portion of the abov e s tatement, w ith res pec t to the seismic mar gin of AP1000 s hield building and KH N P c ontainment, w ere doc umented in referenc e 3 of this N O N-CONCURRENCE PROCESS.
ExcerptfromFigure11ofJohnS.Maspaper,GuidelinesforthePerformanceBased SeismicDesignofSeismicCategory IConcreteStructuresinNuclearPowerPlants


Sinc e The N R C /N R O /SEB C hief and an Ac ting D irec tor refus ed to s end the ques tions to the applic ant to obtain seismic capacities of the reac tor building and the s truc tural members that form the building, or w hether the building c ould s us tain R LE w ith no c ollaps e, thus It is unk now n w hether the building c ould s us tain an earthquak e bey ond the SSE w ith no c ollaps e.
IncreaseofReinforcementIncreasesShear StrengthbutReducesShearDuctility ExcerptfromFigure12ofJohnS.Maspaper,GuidelinesforthePerformanceBased SeismicDesignofSeismicCategory IConcreteStructuresinNuclearPowerPlants
Therefore, the D eputy D irec tors c onc lus ion in item 2) abov e is inc orrec t.


The D eputy D irec tor c onc luded in items 3) and 4) abov e that the N R C polic y in SRM-SECY 087 does not require a demons tration of no c ollaps e of the reac tor building during the R LE bec aus e he did not find a no c ollaps e c riterion in it. H is c onc lus ion bas ed on the abs enc e of a no c ollaps e c riterion in the SR M-SECY-93-087 is jus t as w rong as he w as ty ing the polic y to the SR P in item 1), bec aus e the polic y is to define R LE = 1.67 SSE, and it does not and s hould not tell s truc tural engineers how to des ign buildings w ith w hat k ind of c riteria. The no c ollaps e c riterion belongs to the s truc tural engineering bec aus e the goal of des igning a building is to ac hiev e no c ollaps e. The D eputy D irec tor s hould remember in the meeting, dated N ov ember 29, 2018, w ith the PR A s taff members w hen they s aid NO in res pons e to the ques tion w hether the N uSc ale reac tor building c ould be allow ed to c ollaps e during the R LE. Therefore, the D eputy D irec tors c onc lus ion in items 3) and 4) is not only w rong but als o dangerous.
Two1/13ScaledNuclearContainment BuildingSpecimens ExcerptfromSeismicPerformanceofNuclearContainments:SimulationandExperiment,byCongHieu Luu,Y.L. Mo,ThomasT.C.Hsu,andChiunLinWu(unpublished).


In item 5) abov e the D eputy D irec tor believ ed that the R EL is intended to be us ed to identify des ign s pec ific s eis mic v ulnerabilities w ithout s pec ify ing the v ulnerabilities that he s aw. H e c ited the 1988 N R C G eneric Letter (G L 88-20) for performing IPEEE to find v ulnerabilities and fix them. This generic letter w as is s ued more than 30 y ears ago for problems related to plants that had not been des igned and built for R LE, and the IPEEE w as us ed to find and fix major s eis mic problems in the plants. I partic ipated in the IPEEE w alk dow ns, and I k now that it w as a band-aid for mis tak es that plants had not been des igned for the R LE, and is not for the des ign of new plants, s uc h as the N uSc ale.
ReinforcementDetails ofthetwoSpecimens ExcerptfromSeismicPerformanceofNuclearContainments:SimulationandExperiment, byCongHieu Luu,Y.L. Mo,ThomasT.C.Hsu,andChiunLinWu(unpublished).


The mos t v ulnerable is s ue for building des ign is w hether the w hole building w ill c ollaps e or not.
FiniteElementModel ExcerptfromSeismicPerformanceofNuclearContainments:SimulationandExperiment, byCongHieu Luu,Y.L. Mo,ThomasT.C.Hsu,andChiunLinWu(unpublished).
If the w hole building w ill not c ollaps e through the demons tration of the s tr uc tur al engineer ing analy s is /des ign method, the nex t v ulnerable is s ue is to c hec k w hether there are partial c ollaps es in s truc tural members, s uc h as beams, c olumns, roofs, w alls, s labs, and their c onnec tions. Thes e v ulnerabilities c an be and hav e been identified through s truc tural engineering analy s is, and the des ign was rev is ed to eliminate all the v ulnerabilities until the analy s is demons trates that there is no w hole building c ollaps e or partial c ollaps es. This is the nor mal pr oc es s s tr uc tural engineers hav e been doing for building des ign in r ec ent dec ades.


Shall w e des ign the N uSc ale reac tor building w ithout the R LE and then require the plant to go through the IPEEE proc es s as s tated in G L 88-20 as the D eputy D irec tor might hav e s ugges ted, or us e the s truc tural engineering analy s is /des ign method w ith the R LE to ens ure that it c an s us tain the R LE w ithout c ollaps e s ame as the method us ed for the des ign of important buildings w orldw ide as s tated in attac hments 1 and 2 in referenc e 2 of this N on-C onc ur r enc e P r oc es s ?
AnalyticalPredictionsVS.TestDataof Containmentswith2%Reinforcement ComparisonofAnalyticalPredictionsVS.TestResults (ExcerptfromSeismicPerformanceofNuclearContainments:SimulationandExperiment,by CongHieu Luu,Y.L. Mo,ThomasT.C.Hsu,andChiunLinWu(unpublished).
The ans w er s hould be obv ious. We found our mis tak e w ithout des igning buildings for the R LE more than 30 y ears ago and then tried to fix and mitigate the problem through G L 88-20 and IPEEE. Are w e going to c ommit the s ame mis tak e for the N uSc ale?


The fact that no buildings, w hether or dinar y or impor tant ones, has ever been designed using a PRA method, and all buildings have been designed using the structural engineering analysis/design method as described and documented in the tw o attachments in r efer ence 2 of this NO N-CONCURRENCE PROCESS should serve as a w arning to managers w ho insist to replace the structural engineering analysis/design method by a PRA method for the design of the NuScae reactor building subjected to the RLE.}}
SeismicMarginAssessment(SMA)for TwoSeismicGroundAccelerations ExcerptfromFigure13ofJohnS.Maspaper,GuidelinesforthePerformanceBased SeismicDesignofSeismicCategory IConcreteStructuresinNuclearPowerPlants}}

Latest revision as of 17:01, 27 November 2024

Reference File for DPO-2020-004 Appeal Case File - Redacted, Public
ML22140A377
Person / Time
Issue date: 05/20/2022
From: Carolyn Lauron
NRC/NRR/DNRL/NRLB
To:
Carolyn Lauron - 301-415-2736
References
DPO-2020-004
Download: ML22140A377 (54)
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Text

Reference file for DPO-2020-004 This reference file includes additional information related to the Differing Profession Opinion (DPO) Case File DPO-2020-004 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22056A017). The below table provides a roadmap of publicly available information referenced in the DPO casefile. It includes a brief description of the information, where that information is referenced in the DPO casefile, and where that information can be located. The identified locations of the DPO casefile where particular information is discussed are provided for information only and may not be exhaustive.

DPO-2020-004 Case File PDF Page Number Brief Description Location 3, 7, 23-24, 26, 40, 44, 66, 79, 80, 84, 87, 91, 96-97,100 SECY-93-087, Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water Reactor (ALWR) Designs (Apr. 2, 1993).

ADAMS Accession No. ML003708021 3, 21-22, 35, 40-41, 44-45, 59-60, 62, 64-65, 67, 73-75, 82-83, 91-92, 96-97, 100 Staff RequirementsSECY-93-087 Policy, Technical, and Licensing Issues Pertaining to Evolutionary and Advanced Light-Water Reactor (ALWR) Designs (July 21, 1993).

ADAMS Accession No. ML003708056 3, 22, 35, 41, 45-46, 59-65, 67, 73-74, 91, 101 DC/COL-ISG-020, Interim Staff Guidance on Implementation of a Probabilistic Risk Assessment-Based Seismic Margin Analysis for New Reactors (May 2010).

ADAMS Accession No. ML100491233 3, 22, 45, 67, 100-101 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 19.0, Probabilistic Risk Assessment and Severe Accident Evaluation for New Reactors (Dec. 2015).

ADAMS Accession No. ML15089A068 10-12, 14-15, 16, 19-20, 23, 26, 53, 56, 67, 80, 82, 87 Stanford Seismic Design Guidelines (for Engineers & Architects), by Stanford University, (Jan. 2020).

https://lbre.stanford.edu/sites/lb re-production/files/publications/sd g january 2020.pdf) 14-16, 19-20, 24, 27, 56, 67, 82, 84-85, 105, 107, 109-110 Vancouver House, by Geoff Poh, P.Eng., Structure (Jan. 2020).

https://www.structuremag.org/w p-content/uploads/2019/12/27200 1-F-Vancouver.pdf 14, 16-17, 19, 20, 27, 51-52, 66, 82, 84, 85, 107, 109-110 Salesforce Tower by Ron Klemencic, P.E., S.E., Michael T. Valley, P.E. and John D. Hooper, P.E., S.E.; Structure (June 2017).

https://www.structuremag.org/w p-content/uploads/2017/05/F-Salesforce-Jun17.pdf 1

DPO-2020-004 Case File PDF Page Number Brief Description Location 15, 23, 27, 49-50, 66 NEHRP Recommended Seismic Provisions for New Buildings and Other Structures FEMA P-750 / 2009 Edition.

https://www.fema.gov/node/neh rp-recommended-seismic-provisions-new-buildings-and-other-structures 21, 27, 86 ACI Presidents Memorandum Concrete International (Jan. 2020).

https://www.concrete.org/news/

newsdetail.aspx?f=51723494 34, 44-45, 64, 67 NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 3.8.4, Other Seismic Category I Structures (Sept. 2013).

ADAMS Accession No. ML13198A258 40, 88 Emails between the DPO submitter, the DPO submitters supervisor, and other staff during the safety review of the NuScale application in 2017 and 2018.

Pages 5 - 7 of this document 40, 41, 42, 88 Email and email attachment from DPO submitter to the DPO panel members with additional clarifications and information.

Pages 8 - 13 of this document 46, 49-50, 53, 66 FEMA P-695, Quantification of Building Seismic Performance Factors:, (June 2009).

https://www.fema.gov/sites/defa ult/files/2020-08/fema earthquakes quantific ation-of-building-seismic-performance-factors-fema-p-695.zip 46, 60, 66 EPRI Report NP-6041, Nuclear Plant Seismic Margin R-1, (Aug. 1991).

https://www.epri.com/research/

products/NP-6041-SLR1 46, 66 National Institutes of Standards and Technology (NIST), Evaluation of the FEMA P-695 Methodology for Quantification of Building Seismic Performance Factors (Nov. 2010).

https://www.nehrp.gov/pdf/nistg cr10-917-8.pdf 47-48, 67 Villaverde, Roberto, Methods to Assess the Seismic Collapse Capacity of Building Structures: State of the Art, American Society of Civil Engineers (ASCE), J.

Struct. Eng., 133(1):57-66.

https://doi.org/10.1061/(ASCE) 0733-9445(2007)133:1(57) 2

DPO-2020-004 Case File PDF Page Number Brief Description Location 58, 59, 66 Anderson, Lisa, et al., Consideration of Component Level vs. Element Level Stresses in Concrete Nuclear Safety-Related Structures Under High Seismic Loading, Presented at the 2018 DOE-NRC Natural Phenomena Hazards Meeting, October 23, 2018.

https://www.energy.gov/sites/pr od/files/2019/01/f58/7%20Consi deration%20of%20Component

%20Level%20vs.%20Element

%20Level%20Stresses%20in%

20Concrete%20Nuclear%20Saf ety-Related%20Structures%20Und er%20High%20Seismic%20Loa ding.pdf 58, 67 NuScale Final Safety Analysis Report (Rev. 3) - Part 02 -Tier 2 - Chapter 03 - Design of Structures, Systems, Components and Equipment - Appendices 3A - 3C -

Design Reports and Critical Sections Details, (Sept. 30, 2019).

ADAMS Accession No. ML19248B833 (Package) 60, 66 EPRI Report TR-103959, Methodology for Developing Seismic Fragilities (June 1994).

https://www.epri.com/research/

products/1022995 60, 66 NUREG/CR-5720, Assessment of Seismic Margin Calculation Methods (March 1989).

ADAMS Accession No. ML20248D089 61,66 ASCE 43-19, Seismic Design Criteria for Structures, Systems, and Components in Nuclear Facilities (2019).

https://ascelibrary.org/doi/epdf/

10.1061/9780784415405 71, 79, 81, 88 Document from DPO submitter explaining fundamental differences between DPO and DPO Panels Report (attachment to email from DPO submitter to NRR Office Director).

ADAMS Accession No. ML21132A136 79, 81 Email from DPO submitter to NRR Office Director.

Page 14 of this document 88, 108 Email from DPO submitter to staff Page 15 of this document 88, 108 Email from staff to DPO submitter Page 16 of this document N/A Email from DPO submitter to the DPO appeal review team responding to questions on the DPO.

Pages 17 - 18 of this document 3

DPO-2020-004 Case File PDF Page Number Brief Description Location N/A Email Attachment to email from DPO submitter to the EDO appeal review team, EDO question on my DPO and my answer.

Pages 19 - 23 of this document N/A Email Attachment to email from DPO submitter to the EDO appeal review team, Performance-Based Seismic Design of Seismic Category I Structures.

Pages 24 - 54 of this document N/A Email from EDO to NRR Office Director.

ADAMS Accession No. ML22082A178 N/A Staff Response to Taskings in Decision on Differing Professional Opinion Appeal Concerning (DPO2020004)

ADAMS Accession No. ML22062A007 4

Disagreement with the Deputy Directors Response and Conclusion I (the NCP submittal) appreciate the response from the Deputy Director. I believe his conclusions are wrong because (1) he neglected the facts that are presented in the NCP submittals, and he did not dispute those facts, and (2) his understanding and interpretation of the NRC policy in SRM SECY 93-087, SRP, structural engineering, PRA, and the GL 88-20 and IPEEE are improper. These will be stated and discussed below.

The Deputy Director stated, I have read through the references in this NCP, as stated on page 12 of 13 in this NON-CONCURRENCE PROCESS. If he did, he should know the following facts as stated and described in those references:

1. The fundamental goal of building design is to achieve no collapse.
2. The structural engineering analysis/design method is the tool to achieve that goal.
3. The PRA method is to evaluate the consequence of a building collapse, such as the probabilistic risks of nuclear core damage resulting from the collapse of the NuScale reactor building, or its structural members such as roofs, floors, and walls, but is not intended to predict and cannot predict the building behaviors (responses) and collapse during earthquakes.
4. Important buildings are designed for a maximum considered earthquake (MCR), which equals a minimum magnitude of 1.5 times the acceleration of its design basis earthquake ground motions, as a required seismic margin, using the structural engineering analysis/design method. That magnitude, or seismic margin, is increased proportionally for buildings whose collapse could cause significantly more death.
5. The NRC policy specified that magnitude or seismic margin to be 1.67, or (RLE = 1.67 x SSE) in SRM SECY 93-087.
6. The shield building of AP1000 and the containment building of KHNP demonstrated that they could sustain RLE with no collapse through structural engineering analysis/design methods.
7. The staff of the PRA group stated that the NuScale reactor building should not be allowed to collapse during the RLE.
8. The NRO management (SEB Chief and an Acting Director) ordered me not to request the NuScale applicant to demonstrate that the reactor building could sustain RLE with no collapse using the structural engineering analysis/method. Instead they wanted to use a PRA approach.

I believe that the management was wrong because (1) its order is against the safety principle of building design for not using a seismic margin of 1.5 or 1.67, (2) replacing the structural engineering analysis/design method that has been used by the worldwide structural engineering community (practicing licensed professional engineers and building officials) by a PRA method that cannot predict building behaviors (responses) or collapse of a building during earthquakes, and (3) and its order caused no demonstration that the building will not collapse beyond the SSE.

The Deputy Director did not dispute any facts as stated in item 1 through 8 but only tried to justify that the NRO managements order to be proper. He misinterpreted the policy and the SRP and offered his improper understanding and interpretation of how the reactor building should be designed with respect to the RLE. He further tried to use GL-88-20 and IPEEE that 10

were issued and practiced more than 30 years ago to resolve the current unanalyzed/undersigned problems of the NuScale reactor building with respect to the RLE. His misinterpretations and improper understandings can be seen from the following excerpts of his statements:

1) NRO management indicated that the ground motion acceleration screening threshold of 1.67 times design basis SSE is a Commission policy that is implemented using the guidance in SRP Section 19.0, Probabilistic Risk Assessment and Severe Accident Evaluation for New Reactors. (page 12 of 13 in this NON-CONCURRENCE PROCES)
2) The agency has implemented the Commission's direction in SRM SECY 93-087 through the Standardized Review Plan (SRP) Chapter 19, dated December 2015..(page 11 of 13 in this NON-CONCURRENCE PROCESS)
3) Therefore, there is not a no collapse standard defined by the Commission policy approved in SRM SECY 93-087. (page 12 of 13 in this NON-CONCURRENCE PROCES)
4) I have concluded that SRM-SECY-93-087 does not impose a no collapse acceptance criteria for ground motion of one and two-thirds of the Design Basis SSE. (page 12 of 13 in this NON-CONCURRENCE PROCESS)
5) Instead, the ground motion level referenced by SRM-SECY-93-087 is intended to be used to identify design specific seismic vulnerabilities. (page 12 of 13 in this NON-CONCURRENCE PROCESS)

The Deputy Directors interpretation in item 1) is to tie the policy and the SRP Chapter 19 together as a unit, and he thus concluded that only PRA can be used related to the RLE because the SRP mentions PRA. His interpretation is incorrect because the NRC policy defines the required magnitude of the seismic margin beyond the SSE to be 1.67 or RLE = 1.67 x SSE, and it stands alone to be a requirement without the need of any SRP. SRP Chapter 19 is a document providing guidance to achieve that policy requirement. Even if the methods stated in the SRP were incorrect, it does not alter the requirement of the policy that is the RLE = 1.67 x SSE. Even if the structural engineering analysis/design method were not mentioned in the SRP, one cannot, based on that omission in the SRP, to conclude that the policy excludes the use of structural engineering analysis/design methods for RLE. The fact that SRP, Chapter 19, does mention the structural engineering analysis/design method for calculating the capacity (collapse) of a building and its structural members and they are to be evaluated by the Structural Engineering Branch further demonstrates that the Deputy Director is not only wrong in his understanding and interpretation between the policy and the SRP but also lacking the knowledge of the SRP on using the structural engineering method for predicting whether a building would collapse or not during the RLE (see proof below).

SRP Chapter 19, dated December 2015, states, The organization responsible for structural engineering supports the review of the PRA and severe accident evaluation in two main area:

the applicants evaluation of seismic contributors (specifically the seismic hazard analysis and estimation of seismic capacities (acceleration at which there is high confidence in low probability of failure [HCLPF] and the applicants analysis of containment performance. The words of structural engineering and seismic capacities are bolded and underlined by me to 11

emphasize that the value of seismic capacities is developed by structural engineers and reviewed by the structural engineering (Branch), and then provide those capacity values to the PRA analysts (group) for their consequence analysis. The words seismic capacity in structural engineering mean collapse of a beam, a column, or the whole building, such as the NuScale reactor building, during earthquakes.

About ten (10) years ago, the applicant of AP1000 demonstrated that the shield building element could resist three (3) times SSE with no collapse through physical laboratory testing, and the whole shield building could resist three (3) times SSE with no collapse through structural engineering analysis. The KHNP containment building has a margin of strength (overstrength) of 1.44 against SSE through structural engineering analysis. In attachment 1 of reference 2 of this NON-CONCURRENCE PROCESS, a generic concrete containment with 1%

of steel reinforcement possessed a seismic margin of safety 1.54 against a far field earthquake, and 1.43 against a near field earthquake through ductility. The actual margin of safety of a building against earthquakes is the product of both overstrength and ductility. The overstrength of 1.44 times the ductility of 1.43 = 2.06. Recognizing that the KHNP containment has reinforcement more than 1% and that would decrease the ductility value, and the actual ductility value can be obtained for the KHNP containment by using the actual reinforcement in the containment through structural engineering analysis. However, with a seismic margin of 2.06 against SSE, the reduced ductility value in the KHNP containment would be still enough to make the final seismic margin greater than 1.67 times SSE, required by the NRC policy. The major portion of the above statement, with respect to the seismic margin of AP1000 shield building and KHNP containment, were documented in reference 3 of this NON-CONCURRENCE PROCESS.

Since The NRC/NRO/SEB Chief and an Acting Director refused to send the questions to the applicant to obtain seismic capacities of the reactor building and the structural members that form the building, or whether the building could sustain RLE with no collapse, thus It is unknown whether the building could sustain an earthquake beyond the SSE with no collapse.

Therefore, the Deputy Directors conclusion in item 2) above is incorrect.

The Deputy Director concluded in items 3) and 4) above that the NRC policy in SRM-SECY 087 does not require a demonstration of no collapse of the reactor building during the RLE because he did not find a no collapse criterion in it. His conclusion based on the absence of a no collapse criterion in the SRM-SECY-93-087 is just as wrong as he was tying the policy to the SRP in item 1), because the policy is to define RLE = 1.67 SSE, and it does not and should not tell structural engineers how to design buildings with what kind of criteria. The no collapse criterion belongs to the structural engineering because the goal of designing a building is to achieve no collapse. The Deputy Director should remember in the meeting, dated November 29, 2018, with the PRA staff members when they said NO in response to the question whether the NuScale reactor building could be allowed to collapse during the RLE. Therefore, the Deputy Directors conclusion in items 3) and 4) is not only wrong but also dangerous.

In item 5) above the Deputy Director believed that the REL is intended to be used to identify design specific seismic vulnerabilities without specifying the vulnerabilities that he saw. He cited 12

the 1988 NRC Generic Letter (GL 88-20) for performing IPEEE to find vulnerabilities and fix them. This generic letter was issued more than 30 years ago for problems related to plants that had not been designed and built for RLE, and the IPEEE was used to find and fix major seismic problems in the plants. I participated in the IPEEE walkdowns, and I know that it was a band-aid for mistakes that plants had not been designed for the RLE, and is not for the design of new plants, such as the NuScale.

The most vulnerable issue for building design is whether the whole building will collapse or not.

If the whole building will not collapse through the demonstration of the structural engineering analysis/design method, the next vulnerable issue is to check whether there are partial collapses in structural members, such as beams, columns, roofs, walls, slabs, and their connections. These vulnerabilities can be and have been identified through structural engineering analysis, and the design was revised to eliminate all the vulnerabilities until the analysis demonstrates that there is no whole building collapse or partial collapses. This is the normal process structural engineers have been doing for building design in recent decades.

Shall we design the NuScale reactor building without the RLE and then require the plant to go through the IPEEE process as stated in GL 88-20 as the Deputy Director might have suggested, or use the structural engineering analysis/design method with the RLE to ensure that it can sustain the RLE without collapse same as the method used for the design of important buildings worldwide as stated in attachments 1 and 2 in reference 2 of this Non-Concurrence Process?

The answer should be obvious. We found our mistake without designing buildings for the RLE more than 30 years ago and then tried to fix and mitigate the problem through GL 88-20 and IPEEE. Are we going to commit the same mistake for the NuScale?

The fact that no buildings, whether ordinary or important ones, has ever been designed using a PRA method, and all buildings have been designed using the structural engineering analysis/design method as described and documented in the two attachments in reference 2 of this NON-CONCURRENCE PROCESS should serve as a warning to managers who insist to replace the structural engineering analysis/design method by a PRA method for the design of the NuScae reactor building subjected to the RLE.

13

AConcreteContainmentandIts InternalStructures

AConcreteShieldBuilding Figure 2 - A concrete shield building encloses a steel containment

JapaneseNonLinearComputerProgramPredictions VS.SeismicShakeTableTestData(CrackPatterns)

Figure9-finiteelementmathematicalmode ofPCCV Figure10 similarcrackpatternsinitiated fromthepenetration ExcerptfromFigures9and10ofJohnS.Maspaper,GuidelinesforthePerformance BasedSeismicDesignofSeismicCategory IConcreteStructuresinNuclearPowerPlants

JapaneseNonLinearComputerProgramPredictions VS.SeismicShakeTableTestData (HorizonAccelerationResponse)

ExcerptfromFigure11ofJohnS.Maspaper,GuidelinesforthePerformanceBased SeismicDesignofSeismicCategory IConcreteStructuresinNuclearPowerPlants

IncreaseofReinforcementIncreasesShear StrengthbutReducesShearDuctility ExcerptfromFigure12ofJohnS.Maspaper,GuidelinesforthePerformanceBased SeismicDesignofSeismicCategory IConcreteStructuresinNuclearPowerPlants

Two1/13ScaledNuclearContainment BuildingSpecimens ExcerptfromSeismicPerformanceofNuclearContainments:SimulationandExperiment,byCongHieu Luu,Y.L. Mo,ThomasT.C.Hsu,andChiunLinWu(unpublished).

ReinforcementDetails ofthetwoSpecimens ExcerptfromSeismicPerformanceofNuclearContainments:SimulationandExperiment, byCongHieu Luu,Y.L. Mo,ThomasT.C.Hsu,andChiunLinWu(unpublished).

FiniteElementModel ExcerptfromSeismicPerformanceofNuclearContainments:SimulationandExperiment, byCongHieu Luu,Y.L. Mo,ThomasT.C.Hsu,andChiunLinWu(unpublished).

AnalyticalPredictionsVS.TestDataof Containmentswith2%Reinforcement ComparisonofAnalyticalPredictionsVS.TestResults (ExcerptfromSeismicPerformanceofNuclearContainments:SimulationandExperiment,by CongHieu Luu,Y.L. Mo,ThomasT.C.Hsu,andChiunLinWu(unpublished).

SeismicMarginAssessment(SMA)for TwoSeismicGroundAccelerations ExcerptfromFigure13ofJohnS.Maspaper,GuidelinesforthePerformanceBased SeismicDesignofSeismicCategory IConcreteStructuresinNuclearPowerPlants

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