ML22140A377

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)

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 Brief Description Location Page Number SECY-93-087, Policy, Technical, and 3, 7, 23-24, 26, 40, Licensing Issues Pertaining to ADAMS Accession No.

44, 66, 79, 80, 84, Evolutionary and Advanced Light-Water ML003708021 87, 91, 96-97,100 Reactor (ALWR) Designs (Apr. 2, 1993).

3, 21-22, 35, 40-41, Staff RequirementsSECY-93-087 44-45, 59-60, 62, Policy, Technical, and Licensing Issues ADAMS Accession No.

64-65, 67, 73-75, Pertaining to Evolutionary and Advanced ML003708056 82-83, 91-92, 96- Light-Water Reactor (ALWR) Designs 97, 100 (July 21, 1993).

DC/COL-ISG-020, Interim Staff Guidance 3, 22, 35, 41, 45-on Implementation of a Probabilistic Risk ADAMS Accession No.

46, 59-65, 67, 73-Assessment-Based Seismic Margin ML100491233 74, 91, 101 Analysis for New Reactors (May 2010).

NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, 3, 22, 45, 67, 100- ADAMS Accession No.

Section 19.0, Probabilistic Risk 101 ML15089A068 Assessment and Severe Accident Evaluation for New Reactors (Dec. 2015).

https://lbre.stanford.edu/sites/lb 10-12, 14-15, 16, Stanford Seismic Design Guidelines (for re-19-20, 23, 26, 53, Engineers & Architects), by Stanford production/files/publications/sd 56, 67, 80, 82, 87 University, (Jan. 2020).

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. and p-content/uploads/2017/05/F-84, 85, 107, 109- John D. Hooper, P.E., S.E.; Structure Salesforce-Jun17.pdf 110 (June 2017).

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DPO-2020-004 Case File PDF Brief Description Location Page Number https://www.fema.gov/node/neh NEHRP Recommended Seismic 15, 23, 27, 49-50, rp-recommended-seismic-Provisions for New Buildings and Other 66 provisions-new-buildings-and-Structures FEMA P-750 / 2009 Edition.

other-structures ACI Presidents Memorandum Concrete https://www.concrete.org/news/

21, 27, 86 International (Jan. 2020). newsdetail.aspx?f=51723494 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 DPO submitters supervisor, and other 40, 88 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 ult/files/2020-FEMA P-695, Quantification of Building 08/fema earthquakes quantific 46, 49-50, 53, 66 Seismic Performance Factors:, (June ation-of-building-seismic-2009).

performance-factors-fema-p-695.zip EPRI Report NP-6041, Nuclear Plant https://www.epri.com/research/

46, 60, 66 Seismic Margin R-1, (Aug. 1991). products/NP-6041-SLR1 National Institutes of Standards and Technology (NIST), Evaluation 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)

Society of Civil Engineers (ASCE), J.

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

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DPO-2020-004 Case File PDF Brief Description Location Page Number https://www.energy.gov/sites/pr od/files/2019/01/f58/7%20Consi Anderson, Lisa, et al., Consideration of deration%20of%20Component Component Level vs. Element Level

%20Level%20vs.%20Element Stresses in Concrete Nuclear Safety-

%20Level%20Stresses%20in%

58, 59, 66 Related Structures Under High Seismic 20Concrete%20Nuclear%20Saf Loading, Presented at the 2018 DOE-ety-NRC Natural Phenomena Hazards Related%20Structures%20Und Meeting, October 23, 2018.

er%20High%20Seismic%20Loa ding.pdf NuScale Final Safety Analysis Report (Rev. 3) - Part 02 -Tier 2 - Chapter 03 - Design of ADAMS Accession No.

58, 67 Structures, Systems, Components and ML19248B833 (Package)

Equipment - Appendices 3A - 3C -

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

EPRI Report TR-103959, Methodology https://www.epri.com/research/

60, 66 for Developing Seismic Fragilities (June products/1022995 1994).

NUREG/CR-5720, Assessment of ADAMS Accession No.

60, 66 Seismic Margin Calculation Methods ML20248D089 (March 1989).

ASCE 43-19, Seismic Design Criteria for https://ascelibrary.org/doi/epdf/

61 ,66 Structures, Systems, and Components in 10.1061/9780784415405 Nuclear Facilities (2019).

Document from DPO submitter explaining fundamental differences between DPO ADAMS Accession No.

71, 79, 81, 88 and DPO Panels Report (attachment to ML21132A136 email from DPO submitter to NRR Office Director).

Email from DPO submitter to NRR Office 79, 81 Page 14 of this document Director.

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.

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DPO-2020-004 Case File PDF Brief Description Location Page Number Email Attachment to email from DPO submitter to the EDO appeal review team, N/A Pages 19 - 23 of this document EDO question on my DPO and my answer.

Email Attachment to email from DPO submitter to the EDO appeal review team, N/A Pages 24 - 54 of this document Performance-Based Seismic Design of Seismic Category I Structures.

ADAMS Accession No.

N/A Email from EDO to NRR Office Director.

ML22082A178 Staff Response to Taskings in Decision ADAMS Accession No.

N/A on Differing Professional Opinion Appeal ML22062A007 Concerning (DPO2020004) 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.

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A Concrete Containment and Its Internal Structures

A Concrete Shield Building Figure 2 - A concrete shield building encloses a steel containment

Japanese NonLinear Computer Program Predictions VS. Seismic Shake Table Test Data (Crack Patterns)

Figure 9 - finite element mathematical mode Figure 10 similar crack patterns initiated of PCCV from the penetration Excerpt from Figures 9 and 10 of John S. Mas paper, Guidelines for the Performance Based Seismic Design of Seismic Category I Concrete Structures in Nuclear Power Plants

Japanese NonLinear Computer Program Predictions VS. Seismic Shake Table Test Data (Horizon Acceleration Response)

Excerpt from Figure 11 of John S. Mas paper, Guidelines for the PerformanceBased Seismic Design of Seismic Category I Concrete Structures in Nuclear Power Plants

Increase of Reinforcement Increases Shear Strength but Reduces Shear Ductility Excerpt from Figure 12 of John S. Mas paper, Guidelines for the PerformanceBased Seismic Design of Seismic Category I Concrete Structures in Nuclear Power Plants

Two 1/13 Scaled Nuclear Containment Building Specimens Excerpt from Seismic Performance of Nuclear Containments: Simulation and Experiment, by CongHieu Luu, Y.L. Mo, Thomas T.C. Hsu, and ChiunLin Wu (unpublished).

Reinforcement Details of the two Specimens Excerpt from Seismic Performance of Nuclear Containments: Simulation and Experiment, by CongHieu Luu, Y.L. Mo, Thomas T.C. Hsu, and ChiunLin Wu (unpublished).

Finite Element Model Excerpt from Seismic Performance of Nuclear Containments: Simulation and Experiment, by CongHieu Luu, Y.L. Mo, Thomas T.C. Hsu, and ChiunLin Wu (unpublished).

Analytical Predictions VS. Test Data of Containments with 2% Reinforcement Comparison of Analytical Predictions VS. Test Results (Excerpt from Seismic Performance of Nuclear Containments: Simulation and Experiment, by CongHieu Luu, Y.L. Mo, Thomas T.C. Hsu, and ChiunLin Wu (unpublished).

Seismic Margin Assessment (SMA) for Two Seismic Ground Accelerations Excerpt from Figure 13 of John S. Mas paper, Guidelines for the PerformanceBased Seismic Design of Seismic Category I Concrete Structures in Nuclear Power Plants