ML091030655
| ML091030655 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/13/2009 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| SHUKLA G , ACRS, 415-6855 | |
| References | |
| NRC-2757 | |
| Download: ML091030655 (480) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
561st Meeting Advisory Committee on Reactor Safeguards Docket Number: (n/a)
Location: Rockville, Maryland Date: Thursday, April 2, 2009 Work Order No.: NRC-2757 Pages 1-275 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
Vogtle Electric Generating Plant License Renewal ACRS Committee Presentation Mark Ajluni April 2, 2009 1
Agenda
Introductions
VEGP Site Description Project Key Points Open Items Subcommittee Follow-Up Items Summation and Questions 2
VEGP Representatives Tom Tynan, Site Vice President Lee Mansfield, Engineering Support Manager Mark Ajluni, Licensing Manager 3
VEGP Site Description Westinghouse (NSSS), Bechtel (AE)
Two 4 Loop PWR Units z 3625 MWt z 1250 MWe Ultimate Heat Sink - NSCW Forced Draft Cooling Towers and Basins Turbine Cycle Cooling Provided By Natural Draft Towers 4
VEGP License Renewal Project Key Points 10 CFR 54.17(c) Exemption z NRC granted VEGP an exemption to 10 CFR 54.17(c) to submit Vogtle Unit 2 License Renewal Application prior to reaching 20 years remaining on the operating license Basis: Unit 2 is the same design and construction as Unit 1 5
VEGP License Renewal Project Key Points As a result of the aging management reviews, VEGP credited the following:
z 38 Aging Management Programs 9 existing programs with no change 15 existing programs with enhancements 14 new programs z 27 of the 38 are GALL Programs Only minor exceptions 11 plant specific programs incorporated GALL attributes where possible 6
Open Item Resolution The VEGP Final SER for License Renewal has no Open or Confirmatory Items 7
Subcommittee Follow-Up Items Containment Residue z Region II Site Inspection performed walkdown of Boric Acid Corrosion Control Program during 1R14 (April 2008) z Inspection concluded BACC Program would adequately manage boric acid corrosion z However inspector noted non-boric acid deposits from NSCW leakage that could mask boric acid corrosion 8
Subcommittee Follow-Up Items Containment Residue 9
Subcommittee Follow-Up Items CNMT Residue Corrective Actions z BACC Program procedure changes, training, and enhanced communication have been implemented to heighten awareness.
z Aggressive inspection, cleaning and repainting program is in progress - at power and during refueling outages.
z Tools developed to promptly identify and address leakage in containment.
10
Subcommittee Follow-Up Items Containment Residue 11
12 Subcommittee Follow-Up Items Containment Residue The valve on the preceding slide was discussed at the Subcommittee meeting The corrosion visible in the picture had been evaluated as minor surface corrosion that did not require remediation VEGP inspected and cleaned the valve.
The initial evaluation was confirmed as correct.
13
14 Subcommittee Follow-Up Items Water in Pullboxes Medium Voltage Cables z In scope medium voltage cables at VEGP are located in tunnels and not subject to submergence, with one exception Non-safety related 4kV feeders to high voltage switchyard switch house z Region Inspection found water in pull box near switch house z Corrective action - accelerated implementation of the license renewal aging management program inspections Quarterly inspection (later increased to monthly based on first two inspections)
Trending of results z Design changes initiated to add sump pumps to two boxes.
Planned for installation in 2010.
15
Subcommittee Follow-Up Items Aging Management of Boral VEGP Unit 1 spent fuel racks contain Boral' neutron-absorbing panels. Unit 2 racks do not use Boral'.
Our strategy monitors spent fuel pool aluminum concentration and monitors industry operating experience.
To date, industry operating experience has not shown evidence of loss of neutron absorption in Boral'.
SNC has committed to perform a baseline and a follow-up inspection to confirm the neutron-absorbing capacity of the Boral' panels.
16
Summary Experienced team created a high quality application Extensive use made of GALL Thorough audits and inspection of the application and programs VEGP responsive to NRC throughout review No Open or Confirmatory Items VEGP is confident that we are prepared to manage aging and continue to operate safely beyond 40 years 17
1 UNITED STATES OF AMERICA 2 + + + + +
3 NUCLEAR REGULATORY COMMISSION 4 + + + + +
5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) 6 + + + + +
7 MEETING 8 + + + + +
9 THURSDAY, 10 APRIL 2, 2009 11 + + + + +
12 ROCKVILLE, MARYLAND 13 + + + + +
14 The Advisory Committee convened in Room T2B3 in 15 the Headquarters of the Nuclear Safety Regulatory 16 Commission, Two White Flint North, 11545 Rockville 17 Pike, Rockville, Maryland, at 8:30 a.m., Dr. Mario 18 Bonaca, Chair, presiding.
19 20 MEMBERS PRESENT:
21 MARIO BONACA Chair NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 SAID ABDEL-KHALIK Vice Chair 2 J. SAM ARMIJO Member-at-Large 3 JOHN D. SIEBER Member 4 MICHAEL T. RYAN Member 5
6 MEMBERS PRESENT (CONTINUED):
7 SANJOY BANERJEE Member 8 DENNIS C. BLEY Member 9 JOHN W. STETKAR Member 10 WILLIAM J. SHACK Member 11 OTTO L. MAYNARD Member 12 CHARLES H. BROWN, JR. Member 13 HAROLD B. RAY Member 14 MICHAEL CORRADINI Member 15 GEORGE E. APOSTOLAKIS Member 16 17 NRC STAFF PRESENT:
18 Brian Holian 19 Donnie Ashley 20 Louis Lake (via telephone) 21 Emma Wong NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 David Pelton 2 Jay Collins 3 Jim Medoff 4 Steven Arndt 5 David DeSaulniers 6 G. Edward Miller 7 Ian Jung 8 Bill Kemper 9 Ted Quay 10 11 NRC STAFF PRESENT (CONTINUED):
12 William Kennedy 13 Tom Koshy 14 Stu Richards 15 George Russell 16 17 ALSO PRESENT:
18 Mark Ajluni 19 Lee Mansfield 20 Tom Tynan 21 Wade Richards NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 Mike Rowe 2 Paul Brand 3 Dave Brown 4 Robert Williams 5 Dan Flynn 6 William Horin 7 Philip Holzman 8
9 10 11 12 13 14 15 16 I N D E X 17 AGENDA ITEMS PAGE 18 Call to Order 5 19 Review of License Renewal of Vogtle (VEGP) 20 Opening Remarks 7 21 VEGP Introduction 11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 SNC License Renewal Application 12 2 Staff Introduction 28 3 NRC Staff Review Summary 29 4 NRC Onsite Inspection Results 31 5 Committee Discussion 36 6 Digital Instrumentation and Control (I&C) 7 Interim Staff Guidances (ISGs) 46 8 Afternoon Session 133 9 Adjourn 275 10 11 12 13 14 15 16 17 18 19 20 21 P R O C E E D I N G S NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 (8:29 a.m.)
2 CHAIRMAN BONACA: Good morning. The 3 meeting will now come to order.
4 This is the first day of the 561st 5 meeting of the Advisory Committee on Reactor 6 Safeguards. During today's meeting, the Committee 7 will pursue the following: license renewal 8 application and final Safety Evaluation Report for 9 the Vogtle Nuclear Plant, digital instrumentation 10 and control Interim Staff Guidances, license renewal 11 application and Final Safety Evaluation Report for 12 the National Institute of Standards and Technology 13 reactor, draft final Regulatory Guide 1.211, 14 Qualification of Safety-Related Cables and Field 15 Splices for Nuclear Power Plants, preparation of 16 ACRS reports.
17 This meeting is being conducted in 18 accordance with the provisions of the Federal 19 Advisory Committee Act. Mr. Sam Duraiswamy is the 20 Designated Federal Official for the initial portion 21 of the meeting.
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1 Mr. Louis Lake of Region II is on the 2 phone bridge line to listen to the discussion 3 regarding the Vogtle license renewal application.
4 We will have some members representing 5 the Nuclear Utility Group on Equipment Qualification 6 which is NUGEQ on the phone bridge line to listen to 7 the discussion regarding draft Final Regulatory 8 Guideline 1.211.
9 To preclude interruption of the meeting, 10 the phone will be placed in a listening mode for the 11 presentation and committee discussion.
12 We have received no written comments 13 from -- no, we have received written comments from 14 NUGEQ regarding new Regulatory Guide 1.211. We have 15 not received any requests for time to make oral 16 statements from members of the public regarding 17 today's sessions.
18 A transcript of portions of the meeting 19 is being kept. And it is requested that speakers 20 use one of the microphones, identify themselves, and 21 speak with sufficient clarity and volume so that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 they can be readily heard.
2 We'll move on to the first item on the 3 agenda, which is the Vogtle License Renewal 4 Application. But before that, I would like to --
5 Dr. Abdel-Khalik would like to make a statement.
6 VICE CHAIR ABDEL-KHALIK: Thank you, Mr.
7 Chairman.
8 I have a conflict. Therefore, I will 9 not participate in the discussions regarding to the 10 Vogtle license renewal application.
11 CHAIR BONACA: Okay.
12 With that, I'll go to Mr. Sieber who 13 will take us through the presentation.
14 MEMBER SIEBER: Okay. Thank you, Mr.
15 Chairman.
16 Our first session this morning is the 17 license renewal for two units at the Vogtle Nuclear 18 Plant. The Vogtle plant consists of two units, 19 four-loop Westinghouse-type PWRs with dry ambient 20 containments. And it is located about 26 miles 21 southeast of Augusta, Georgia, which was my hometown NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 for a while. And Michael lived in Aiken so we're 2 familiar with the territory.
3 We had our subcommittee meeting on 4 November 5th, which was clear there were some issues 5 that came out of that. And I'll just briefly touch 6 on what those issues were.
7 The first was the number of exception to 8 GALL, of which there were 14, which is -- we have 9 spoken to the issues of exceptions to GALL in 10 previous reports on license renewals. I would just 11 point out at this time that when there are a lot of 12 exceptions, it indicates that GALL could possibly be 13 updated to lower the number of exceptions taken.
14 Some applicants have taken an effort an 15 to change their AMPs, Aging Management Programs, to 16 better match GALL. And so that's another approach 17 to that. But since we have discussed it in so many 18 previous letters, I've concluded we need not discuss 19 it again.
20 The second issue that came up during the 21 subcommittee was medium-voltage cables that appeared NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 to be submerged at least part of the time. This is 2 an issue that is generic to many plants in the 3 United States that use medium-voltage cables that 4 are underground or underground duct work.
5 And we consider this a current licensing 6 issue and not a license renewal issue. So there is 7 a generic letter out on that which the licensee must 8 respond and come up with a program to solve that 9 problem.
10 The third issue to come up during the 11 subcommittee was the fatigue analysis. There is no 12 open item here. The licensee has committed but has 13 not yet done, to my knowledge, the fatigue analysis 14 the way that is so suggested by the ASME Code.
15 And lastly there were some material 16 condition issues, for example the boric acid 17 program, there was some evidence of 18 corrosion/deterioration based on photographs and the 19 reports from the region.
20 In addition, there were photographs of 21 anti-corrosive material that apparently came from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the containment air coolers when those coolers were 2 repiped to use to cool containment during outages to 3 provide a better working condition for the workers 4 in containment during outages.
5 That does not appear to be a condition 6 that would effect the safety of the plant. On the 7 other hand, boric acid condition, to the extent they 8 exist, is a current licensing issue. And needs to 9 be remediated and not wait until license renewal 10 occurs.
11 So those are the four issues. I would 12 bring them out here just to put on the record the 13 fact that we looked at these items and made some 14 preliminary determinations about them. And you may 15 not see them in our final letter or perhaps you 16 will, depending on what the issue is.
17 So with that, I would like to introduce 18 Brian Holian, Director of License Renewal, to 19 introduce the staff speakers and the licensee for 20 this session.
21 Thank you.
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1 MR. HOLIAN: Thank you, Dr. Sieber.
2 I'm Brian Holian, Director of License 3 Renewal. In accordance with the agenda, I will just 4 introduce NRC staff and turn it over to Southern 5 Nuclear for their presentation. The NRC 6 presentation will follow the licensee's 7 presentation.
8 One item before introductions, as Dr.
9 Sieber mentioned, on the GALL update, I remind the 10 Committee that the GALL has served, you know, very 11 usefully in license renewal reviews. And we are in 12 the process this year of updating the GALL.
13 The Nuclear Energy Institute, on behalf 14 of a lot of licensees, has already sent us some 15 comments that we get from the public and we'll be 16 working through a GALL update to minimize exemptions 17 and, you know, increase the efficiency of reviews 18 really.
19 For introductions, to my right is Mr.
20 Dave Pelton, the Branch Chief that also has the 21 Vogtle review.
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1 To his right and presenting later will 2 be Donnie Ashley, the Senior Project Manager in 3 License Renewal.
4 Already on the phone, the Chairman 5 introduced Mr. Lou Lake, the reactor inspector from 6 Region II. And he presented at the subcommittee 7 back in November. And he's on the phone.
8 Also on the phone is his Branch Chief 9 from the Division of Reactor Safety, Mr. George 10 Hopper.
11 With that, I'll turn it over to Mark 12 Ajluni, the Licensing Manager for Southern Nuclear 13 Company.
14 MR. AJLUNI: Thank you.
15 Thank you, Mr. Chairman, and 16 distinguished members of the ACRS staff.
17 I'd like to start off today by 18 introducing myself. I'm Mark Ajluni. I'm the 19 Licensing Manager for the Southern Nuclear Fleet.
20 And I'd like to introduce the members of our team.
21 Mr. Todd Youngblood in back. Todd is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 our Engineering Director at the site.
2 Mr. Jack Stringfellow, Jack is Licensing 3 Supervisor for Vogtle.
4 Mr. Cary Martin, Project Engineer, 5 electrical, for the license renewal project.
6 Jon Hornbuckle, Project Engineer, time-7 limited aging analysis -- I'll get that straight.
8 And I'd like to introduce Mr. Lou Bohn.
9 And Lou is Project Engineer, electrical -- no, I'm 10 sorry, mechanical.
11 And also with us today is Tom Tynan, 12 Site Vice President.
13 And Lee Mansfield, Site Engineering 14 Support Manager.
15 Next slide. Okay, I'd like to start off 16 really talking about the site. And then I'll cover 17 some key points, open items, and subcommittee 18 follow-up items.
19 The Vogtle site is a Westinghouse, four-20 loop plant. Bechtel is the architect engineer. It 21 went commercial in the late '80s. The megawatt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 rating is 3625 and producing about 450 megawatts 2 electric. It has been uprated and the latest uprate 3 was a feedwater flow measurement uncertainty uprate.
4 Ultimate heat sink for the plant is the 5 NSCW system forced draft cooling towers and basins, 6 right there. And these are concrete structures, 7 Category One seismic. And then for the power 8 producing segment of the plant, there is a turbine 9 cycle cool provided by natural draft cooling towers, 10 the hyperbolic towers here.
11 And our latest core damage frequency is 12 1.5 E to the minus 5 for those of you that are 13 interested.
14 Some of the key project points, when we 15 applied for license renewal, we applied for Unit One 16 and Unit Two even though Unit Two had not completed 17 its 20-year requirement. And the NRC did review 18 that and grant us an exemption pursuant to 10 CFR 19 54.17(c). Currently, both units are within the 20-20 year cycle.
21 Other key points, I'll talk about the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 aging management reviews in a minute. We credited 2 38 aging management programs. Twenty-four of the 38 3 were existing programs and 15 of those required 4 enhancements, nine there were no changes to the 5 programs.
6 Twenty-seven of the 38 programs are 7 GALL. Only minor exception were taken to GALL. And 8 since we talked about it, some example of the 9 exceptions would be different versions of a code or 10 a standard, perhaps a different surveillance 11 interval, and material environmental issues. And 12 then other differences. Overall though we were 13 greater than 85 percent match to the GALL program.
14 And one thing we are very proud of is 15 the fact that there are no open or confirmatory 16 items for the final SCR for license renewal. So 17 that was -- we were pleased with that.
18 And now I'd like to turn it over to Lee 19 Mansfield and Lee will talk about some of the 20 subcommittee follow-up issues.
21 MR. MANSFIELD: Good morning.
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1 The reason Region II did a site 2 inspection and a walk-down of our Boric Acid 3 Corrosion Control Program in the spring of 2008.
4 They concluded that the program would adequately 5 manage boric acid but pointed out that we had a non-6 boric acid residue in our containment. It is a 7 white residue that could potentially mask boric acid 8 leaks.
9 So we have taken a number of actions 10 there and I'll describe those. Next slide please.
11 I did want to show you an example of what this 12 residue looks like. This is an area looking up 13 under one of our containment coolers that has 14 nuclear service cooling water passing through it.
15 The white residue and the staining is 16 from past leakage out of the cooler that is above 17 this area. And as you can see, it dries white and 18 could potentially mask boric acid.
19 Next slide please. Our corrective 20 actions have included procedure changes. We went 21 and revised every procedure that has anything to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 with a walk-down or inspection or housekeeping at 2 Plant Vogtle to make sure there is no confusion 3 between this material and a boric acid leak.
4 We've actually done training which 5 involves recurring training coming into outages as a 6 reminder. We've done enhanced communication through 7 our electronic means. And in general have made sure 8 that while we're recovering our containments from 9 this issue, that there is no confusion.
10 And we've told our plant staff whenever 11 there is a question about this, you know, default to 12 a condition report in our corrective action program, 13 come ask the boric acid corrosion control engineer, 14 and we'll get to the bottom of it.
15 We have put in place a very, very 16 aggressive inspection, cleaning, and repainting 17 program. We're making at-power entries as we speak.
18 We've been doing that for a couple of months now.
19 Actually for the last month, we've been doing that 20 weekly.
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1 short in duration again because we're at power.
2 They are really valuable because they are helping us 3 plan for our outage cleaning efforts, which is where 4 the bulk of our work is going to be.
5 So we have -- we currently have a 6 significant commitment by Tom of people and budgets 7 going forward to make sure that we come to grips 8 with this residue issue and clean it up. We will be 9 doing, as a minimum, these large clean-up efforts in 10 the next two refueling outages on each unit.
11 We've also developed work controls tools 12 to help us identify -- promptly identify leaks from 13 cooling water systems and containment so that while 14 we're cleaning and recovering, we don't have new 15 leaks that go too long and create more of a problem 16 for us.
17 Next slide please. This is the same 18 photo I showed you before of the underside of one of 19 our containment coolers. I just show this as an 20 example of how we are able to recover these areas, 21 clean and repaint and recoat and get back to our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 original condition.
2 MR. TYNAN: Before we move further, I 3 just want to make sure the Board understands that 4 I've given this, you know, a lot of my personal 5 attention. I've walked down all these areas in both 6 containments. And make sure, as Lee mentioned, that 7 we have resources and whatever we needed to clean up 8 the containment and address these issues.
9 And to make sure that the station, my 10 station has the proper focus on this item, we have 11 made it number five on our major issues list which 12 gets attention from the entire plant staff.
13 So we are going to make sure that, you 14 know, we're not taking this lightly. We've taken 15 this very seriously and intend to have this 16 addressed in short order in the short term as well 17 as making sure we have long-term actions so it 18 doesn't occur again.
19 MR. MANSFIELD: Next slide please. This 20 is a photograph that was shown at the subcommittee 21 meeting on November 5th. And it was shown as an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 example of the white residue. There was some 2 discussion about the material condition of the 3 valve, particularly the carbon steel packing 4 follower and gland studs had minor corrosion on 5 them.
6 We wanted to follow up with that issue 7 and tell the Committee what we've done. Next slide 8 please. We had originally evaluated this as minor 9 corrosion in our corrective action program and had 10 not planned a near-term remediation of that valve.
11 We have since gone back out to that 12 valve -- I've gone personally and looked at it. And 13 we've cleaned the valve and confirmed our initial 14 belief that it was minor corrosion and we didn't 15 have to replace any components.
16 Next slide please, Lou. This is an 17 after photograph of the same value. And this was --
18 we did this without liquid cleaning methods. So 19 this was the after condition. And I really just 20 wanted to show that this was, indeed, what we 21 thought it was.
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1 MEMBER RAY: How do you deal with ALARA 2 considerations when you elect to do something like 3 that? I mean is it worth it?
4 MR. MANSFIELD: At-power cooling?
5 MEMBER RAY: No, just the manner and 6 exposure --
7 MR. MANSFIELD: Okay.
8 MEMBER RAY: -- that's involved in the 9 housekeeping.
10 MR. MANSFIELD: Well, we took that into 11 account in doing this. And actually these are all 12 of the work that we're doing inside containment now 13 is outside the bioshield and in low-dose areas. The 14 dose rates are very low and we're picking up very 15 little dose doing this.
16 We looked at all of the impacts of doing 17 that and see a real benefit in the head start in 18 helping us prepare for the outages to refine our 19 cleaning methods and make sure that when we get into 20 the outages we can do the most, you know, the most 21 cleaning and the best effort we can do.
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1 MEMBER RAY: Well, I guess I conclude 2 from that that if significant exposure would have 3 been incurred, you wouldn't have done it.
4 MR. MANSFIELD: I certainly would say 5 that there would be a point where it wouldn't make 6 sense to go in and do this kind of work at power 7 because of the dose.
8 MEMBER RAY: I'm not talking about at 9 power necessarily.
10 MR. AJLUNI: I would say we always 11 consider radiological consequences and dose when we 12 do work. And that's a factor. For these valves in 13 this area, you know, the Vogtle containment is a 14 very large containment. Things are spread out.
15 There's lots of shielding. And for this work, it is 16 low dose.
17 MEMBER RAY: Well, low but some dose, I 18 would guess. It may be negligible, I don't know 19 what the field is in there. It just -- it didn't 20 sound to me like you were taking that into 21 consideration when you were talking about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 progressing.
2 MR. TYNAN: We are top quartile in the 3 industry for four-loop Westinghouse PWR in terms of 4 overall dose. And looking at both non-outage and 5 outage dose. And this particular project, you know, 6 always gets a lot of attention when we go into 7 containment. And we assess dose relative to our 8 goals. And so --
9 MEMBER RAY: I just wouldn't want you to 10 take away some message here that wasn't intended 11 when it comes to incurring dose for housekeeping 12 purposes.
13 MR. MANSFIELD: And we didn't. To be 14 honest with you, we didn't. We see -- you know 15 taking the dose into account, we really do see a 16 great value in -- for our planning, to be able to 17 get in there in these low-dose areas, do what 18 cleaning we can, scope out what we're going to do 19 during outages to make that the most effective.
20 MEMBER SIEBER: I think that goes two 21 ways. And generally I leave it to the licensee's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 judgment as to whether housekeeping is worth the 2 dose that it takes. But we do have examples in the 3 industry where housekeeping -- poor housekeeping has 4 masked major problems, for example, in Ohio.
5 And so I think that the management of 6 Vogtle and every other plant has to decide the 7 extent to which they will expend dose to find out 8 what the condition of their plant is. And I think 9 in the examples that the applicant has shown here 10 that it is reasonable.
11 And I agree with you --
12 MEMBER RAY: Well, Jack, I would just 13 like to hear it mentioned.
14 MEMBER SIEBER: Right. It's on the 15 record. But it is a judgment call.
16 MR. MANSFIELD: Next slide please. The 17 second follow-up item is water in pullboxes. Now at 18 Vogtle, the end scope medium voltage cables are all 19 located in tunnels and not subjected to submergence 20 with one exception. We have two non (1)(e), 4kV 21 cable cables that run from the turbine building out NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 to our high-voltage switch yard to support switching 2 operations for offsite sources.
3 During a region inspection, water was 4 found in one of the pullboxes, the pullbox nearest 5 the high-voltage switch yard. And our corrective 6 action for that has been to go ahead and accelerate 7 the implementation of the license renewal aging 8 management program inspections.
9 So we were doing quarterly inspections 10 of those boxes, those three boxes. We've now moved 11 those inspections to monthly based on our findings.
12 We'll continue to trend the results.
13 When we inspect and find water, we pump 14 it out. We'll continue to trend those results. In 15 the mean time, we are developing a design change.
16 We have on our work list for 2010 to add automatic 17 sump pumps to two of the three boxes that don't have 18 sump pumps in them now.
19 And I will tell you that, you know, 20 we're -- if we need to change the frequency again, 21 if there are other actions we need to take in an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 interim method before we get the sump pumps in, 2 we'll do that.
3 MEMBER STETKAR: Remind me, I look at 4 too many plants. Are the main safety-related pumps 5 at Vogtle 4kV? Or are the 480 volt?
6 MR. MANSFIELD: The main safety-related 7 pumps are 4kV.
8 MEMBER SIEBER: This issue is also a 9 generic issue. In November of -- excuse me, March 10 21st, 2002, there was an information notice issued 11 by the staff on this matter of submerged safety-12 related electrical cables. There is a Generic 13 Letter issued in 2007, which Vogtle and other 14 licensees are required to respond to that talks 15 about inaccessible or underground power cable 16 failures that disable accident mitigation systems or 17 cause plant transients.
18 These are current licensing issues that 19 would be handled under the reactor oversight 20 process. I presume you have received the Generic 21 Letter and have responded to it.
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1 MR. MANSFIELD: Yes, we have.
2 MEMBER SIEBER: And so that would be the 3 manner of disposition of this item with regard to 4 license renewal is through your Generic Letter 5 response.
6 MR. MANSFIELD: Okay. Next slide 7 please. Mark Ajluni will cover the aging management 8 of Boral.
9 MR. AJLUNI: Thank you.
10 Since the last ACRS meeting related to 11 this issue, we got basically notified by the staff 12 that they had expressed a concern concerning Unit 13 One Boral spent fuel pool racks. And on Unit One, 14 Boral is the material that is used for the spent 15 fuel pool racks.
16 Unit Two uses a different material 17 called Boroflex. And Unit Two does not credit the 18 Boroflex in their licensing basis.
19 And the concern was that the Boral 20 perhaps could experience similar degradation effects 21 as Boroflex related with aging.
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1 And we had proposed -- we currently 2 monitor the spent fuel pool chemistry and one of the 3 elements we look for is aluminum. And the presence 4 of aluminum would indicate that there was some 5 degradation going on potentially with the Boroflex.
6 And we also monitor industry operating which, to 7 date, has not shown any problems with the use of 8 Boral as the material.
9 We had a lot of discussion with the 10 staff about where do we go with this and there's 11 really not any evidence of the degradation. The 12 driving factor for us was, as pointed out the staff, 13 was that the Unit One racks are, they're not 14 original Vogtle racks. They were purchased from 15 Maine Yankee. And so they actually are rather older 16 racks. In fact, they are one of the older set of 17 racks currently in use.
18 So if there was an aging impact or 19 effect due to Boral degradation, one might expect 20 them to show up on the Vogtle racks first. And 21 given that and thinking about what the right thing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 to do was, we made a commitment to go forth and 2 conduct testing on the racks.
3 We'll do a baseline inspection in 2017.
4 And then within ten years after that, we'll do --
5 but prior to the license renewal period starting, 6 we'll do another neutron attenuation test or some 7 other test and measuring absorber effectiveness and 8 we'll look to see if there has been any degradation 9 of that.
10 If we see degradation, we'll report it 11 as OE and we will take appropriate measures to deal 12 with it. And to address that, we made a commitment 13 to do that. It is a one-time commitment.
14 MEMBER SIEBER: Let me ask you a 15 question --
16 MR. AJLUNI: Yes.
17 MEMBER SIEBER: -- about your racks. Do 18 you use flux trap design-type racks? That's the 19 ones where you have the space between them.
20 MR. AJLUNI: Yes, the high density.
21 MEMBER SIEBER: And the idea is to put NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the Boral where the flux peaks so you get the 2 greatest capture?
3 MR. AJLUNI: That's correct.
4 MEMBER SIEBER: Okay. Those racks came 5 out shortly after the Executive Order that banned 6 recycling and a lot of plants backfit with those 7 kind of racks. One of the issues, besides the loss 8 of boron as an absorber material, is the change in 9 geometry that occurs when the Boral blisters.
10 And so when you inspect and you do a 11 determination as to whether the Boral is still 12 there, you have to look at whether the geometry has 13 changed because of blistering or other effects that 14 would change the neutronic characteristics of the 15 rack itself.
16 Are you aware that that could be a 17 factor?
18 MR. AJLUNI: We are aware of the 19 blistering.
20 MEMBER SIEBER: Okay.
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1 industry OE out on it. And our testing would factor 2 that into it.
3 MEMBER SIEBER: Okay. Thank you.
4 MR. AJLUNI: Okay. And that's all I 5 have on that issue if there are no further 6 questions.
7 In summary, we created an experienced, 8 high-quality team and a high-quality application.
9 The team -- the members of the team worked on all 10 three Southern nuclear plants license renewals.
11 This is the last one so they have had a lot of 12 experience.
13 They've made extensive use of GALL.
14 There were thorough audits and inspections of the 15 program. We've been very responsive to the NRC 16 throughout the review. We're proud of the fact that 17 there's no open or confirmatory actions.
18 And finally, we're confident that Vogtle 19 Electric Generating Plant is prepared to manage 20 aging and continue to operate the plant safety 21 beyond its 40-year regular life.
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1 Thank you very much.
2 MEMBER SIEBER: Okay. Thank you.
3 Any questions of the applicant at this 4 time?
5 MEMBER RYAN: Just one. You mentioned 6 the residue several times. And it is interesting to 7 see the change. Did you ever figure out what the 8 residue is?
9 MR. MANSFIELD: Yes. The residue is 10 principally from our nuclear service cooling water 11 system. That system is made up to by well water.
12 And the minerals in the well water, when they come 13 out into the air and dry, they turn white.
14 There is a corrosion inhibitor in that 15 system as well called tolytriazole. That dries 16 white so between the two, when that system has had 17 leakage over the years, it has caused this staining.
18 MEMBER RYAN: Okay. Thank you.
19 MEMBER SIEBER: Any other questions?
20 (No response.)
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1 staff.
2 Thank you very much.
3 MR. HOLIAN: This is Brian Holian. I'm 4 Director of License Renewal. We'll transition to 5 the staff's presentation.
6 Presenting is Donnie Ashley, the Senior 7 Project Manager. Also joining us at the side table 8 is Dr. Sam Lee, Deputy Director of License Renewal.
9 And a reminder, primarily for questions, 10 but the region is on the phone. That's Lou Lake, 11 Reactor Inspector. Go ahead, Donnie.
12 MR. ASHLEY: Thanks, Brian.
13 Good morning to you all. As Brian said, 14 I'm Donnie Ashley. I'm Project Manager for the 15 Vogtle Electric Generating Plant License Renewal 16 Project. I, along with the tech staff members here 17 in the room, are here to provide you with the status 18 of our review of the Vogtle application and to 19 answer questions that you might have.
20 And Mr. Lou Lake, as has been been 21 mentioned several times, is on the phone with us.
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1 I'll begin with a brief overview of the 2 license renewal effort on this particular project.
3 And the audits and inspections, we're going to cover 4 those in a little different path this time. Usually 5 we do those after we do Section 2 but we'll do those 6 first and then we'll talk about the individual 7 sections of the Safety Evaluation Report.
8 The Safety Evaluation Report itself, the 9 staff was aided with the audit reviews. In 10 additional requests for information provided by the 11 applicant, in response to 87 of those RAIs, there 12 were 173 audit questions which appeared and ended up 13 in the Q&A database, which is on the docket.
14 The information collected from the audit 15 and the RAI responses, in addition to the 16 information given to us from the inspection, was 17 used to develop the final Safety Evaluation Report.
18 There are 40 commitments in the Appendix A of the 19 Safety Evaluation Report.
20 The applicant did not use two number so 21 what we did is we went back to the SER Appendix and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 changed that commitment list to show that Commitment 2 No. 10 and Commitment No. 22 were not used at 3 Vogtle. As has been mentioned, the SER contains no 4 open items or confirmatory items. And we have three 5 license conditions that normally -- they are in the 6 back, the last page of your handout -- these are the 7 standardized conditions that appear in all license 8 renewal SERs.
9 And continuing the recap of the November 10 2008 subcommittee meeting, the three major issues 11 that were discussed by the applicant are repeated 12 here. Subsequent to the subcommittee meeting, the 13 staff asked seven additional RAIs based on the 14 discussions with the staff and on your questions 15 from the subcommittee.
16 And this resulted in a revised 17 commitment to provide for the inspection of the 18 panels in addition to the Water Chemistry Program.
19 That raised the total number of RAIs to 94.
20 The applicant also provided an update on 21 the commitments that were in effect at the time the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 subcommittee met. And we added one new commitment, 2 which was involved in -- the emergency diesel 3 generator fuel oil day tank vent line was added to 4 the commitment list.
5 During the review, the NRC teams 6 conducted three onsite audits and one inspection 7 during the periods listed on this slide. The staff 8 started the review with the scoping and screening 9 methodology audits in September of 2007 at the 10 corporate offices of the Southern Company.
11 This was followed with a series of 12 onsite audits and inspections from October 2007 13 through June 2008. Region II conducted that 14 inspection in May and June to review the scoping and 15 screening and aging management programs.
16 CHAIR BONACA: On page three, you 17 mention that additional components are broke into 18 scope. Could you comment on that?
19 MR. ASHLEY: Yes, sir, I have a slide on 20 that later.
21 CHAIR BONACA: All right.
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1 MR. ASHLEY: The specific audit 2 information was combined into the audit summary and 3 used as input into the SER. And it was issued in 4 September 2008.
5 The original inspection was completed 6 during 2008 and the results were published in a July 7 18, 2008 Inspection Report that was provided to the 8 subcommittee and Mr. Lake was the author of that 9 Inspection Report.
10 As has been discussed by the applicant, 11 the inspectors identified enhancements involved in 12 the manhole flooding and the conditions inside the 13 containment. Region II will follow up on these 14 issues during a future 71003 inspections.
15 The inspection team concluded that the 16 scoping and screening of the non-safety-related 17 systems, structures, and components was implemented 18 as required by the rule and the aging management 19 portions of the license renewal activities were 20 conducted as described in the application.
21 Mr. Lake, do you have any comments from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 Region II?
2 MR. LAKE: No, we do not.
3 MR. ASHLEY: Any questions from the 4 Board for Mr. Lake?
5 (No response.)
6 MR. ASHLEY: Section 2 discusses the 7 scoping and screening methodology of those 8 structures and components subject to aging 9 management review. The methodology, plant level 10 scoping reviews of the relevant systems and 11 structures, mechanical systems, structures and 12 electrical I&C systems are in those sections, too.
13 The staff found the results by the 14 applicant also meet the review criteria in the 15 standard review plan and in accordance with the 16 rules.
17 Three components -- and this should 18 answer your question, Dr. Bonaca -- three components 19 were added to the scope of the review. And that was 20 the non-ESF exhaust fan housing and unit heaters 21 were added as a missile barrier function.
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1 The makeup air duct for the electrical 2 ventilation system was added as A2 on the scope.
3 The chiller compressor components, including the 4 housings, filters, and dryers, were added to the 5 scope as a result of the RAIs that were asked.
6 Does that answer your question?
7 CHAIR BONACA: Yes.
8 MR. ASHLEY: Consistent with 10 CFR 9 54.4(a), the staff concludes that there were no 10 omissions of mechanical components and structures 11 within the scope of license renewal. The staff 12 believes that the available guidance in identifying 13 such components by the applicant is adequate.
14 The review of the aging management 15 programs was performed, as I said, by a combination 16 of license renewal audit teams, onsite teams, and 17 headquarter's personnel, as documented in the SER.
18 The summary of those reviews are listed on this 19 slide.
20 Our counting is a little different than 21 the applicant counts. But we did review 38 aging NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 management programs. Fourteen of those were new 2 programs and 24 were existing programs. Twenty of 3 the programs had exceptions and/or enhancements made 4 to them. Eleven of the programs were plant-specific 5 and seven were 100 percent consistent with GALL.
6 When considering the individual elements 7 of the programs and looking at the individual line 8 items that were evaluated, we agree with the 9 applicant that approximately 85 percent of their 10 programs were consistent with GALL.
11 In Section 3, the staff concluded that 12 the aging management effects will be managed so that 13 the intended functions will be maintained and that 14 the activities authorized by the renewed license 15 would continue in accordance with the current 16 licensing basis to comply with the NRC's 17 regulations.
18 Section 4, the time-limited aging 19 analysis, our plant-specific safety analyses that 20 involved time-limited assumptions defined by the 21 current operating term, the staff reviewed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 information in the application to determine whether 2 the applicant has provided sufficient information 3 pursuant to the regulations for the time-limited 4 aging analysis and for the plant-specific TLAAs.
5 The applicant evaluates its calculations 6 and analysis against the six criteria specified in 7 the regulation. And that involves the SSEs within 8 the scope of license renewal to consider its aging 9 effects and are determined to be relevant by the 10 applicant in making its safety determination.
11 The current licensing basis includes the 12 updated UFSAR, engineering calculations, technical 13 reports, engineering work requests, licensing 14 correspondence, and applicable vendor reports. The 15 applicant stated that it did not identify any 16 exemptions granted under 50.12 based on the TLAAs as 17 defined in CFR 54.3.
18 The plant-specific TLAAs are listed on 19 this slide that were reviewed both in audits and in 20 the office.
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1 accordance with Part 54, the applicant has provided 2 an adequate list of TLAAs, that the TLAAs will 3 remain valid for the period of extended operations, 4 and that the TLAAs have been projected to the end of 5 the period of extended operation, and that the aging 6 effects will be managed by those TLAAs.
7 Future commitments have been identified 8 and a schedule is documented in the SER such that 9 there is reasonable assurance that the activities 10 approved by the license renewal will continue to be 11 conducted in accordance with the current licensing 12 basis and the changes associated with the license 13 renewal.
14 In conclusion, the staff found that the 15 requirements of 10 CFR 54.29(a) have been met for 16 the license renewal of the Vogtle Electric 17 Generating Plant. And that's all I have, sir.
18 MEMBER STETKAR: Donnie, regarding the 19 Boral questions, I think we've heard that the staff 20 is planning to issue Interim Staff Guidance 21 regarding Boral inspections. Is that correct?
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1 MR. ASHLEY: I believe Matt Yoder -- is 2 Matt here? Matt or Emma Wong has some recent 3 information on that.
4 MS. WONG: This is Emma Wong of the 5 staff. Yes, that's true. We're working on that 6 right now.
7 MEMBER STETKAR: I just -- so some of 8 the issues I think the applicant mentioned that they 9 have committed to do inspections by -- I wrote down 10 the date -- 2017 or something like that. But with 11 respect to this Interim Staff Guidance, those --
12 there may be requirements to perform inspections as 13 part of the current licensing basis. Is that 14 correct?
15 MS. WONG: Well, we're working on an 16 Interim Staff Guidance for license renewal right 17 now.
18 MEMBER STETKAR: Okay.
19 MS. WONG: So that would cover --
20 MEMBER STETKAR: So that's strictly 21 within the context of license renewal.
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1 MS. WONG: Right.
2 MEMBER STETKAR: Okay. Thank you.
3 That's -- I was just trying to sort this out whether 4 the Boral issue is going to become similar to the 5 non-EQ cables in manholes where it has been brought 6 up in the license renewal but has essentially 7 gravitated into a current licensing basis.
8 MEMBER SIEBER: Well, let's ask that 9 question. Does the staff plan to do anything on 10 Boral with regard to current licensees outside of 11 license renewal?
12 MR. PELTON: Yes, this is Dave Pelton 13 from DOR. As, you know, Emma just introduced 14 herself. And she and her branch are looking at this 15 both, you know, generically for license renewal but 16 also for the current licensing bases.
17 So the answer is yes. What form that 18 takes ultimately, whether it is an ISG or some other 19 generic NRC communication, that hasn't been resolved 20 yet. So it is still under review.
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1 doesn't absolve the licensee from the responsibility 2 of making their criticality calculations, you know, 3 are current and suitable. But nonetheless, we are 4 looking at it for both.
5 And as we do with all of these issues, 6 water in the manholes, et cetera, we work closely 7 with our tech staff to make sure that we understand 8 aging management but also what's the impact on Part 9 50 in the current licensing bases.
10 MEMBER SIEBER: I think that's 11 important. I would not like to see any issue of 12 this type rest solely in the license renewal arena.
13 MR. PELTON: Absolutely agree.
14 MR. ASHLEY: Part of the commitment that 15 the applicant made was to monitor industry operating 16 experience and obviously to comply with any new 17 requirements that would come out of the agency.
18 MEMBER ARMIJO: Now I'm a little 19 confused here. The applicant's slide 16 says there 20 is, to date, no industry operating experience 21 showing evidence of loss of neutron absorption of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 Boral. And if that's correct, why is the staff so 2 concerned about this issue. You know something is 3 inconsistent here.
4 MR. PELTON: Emma, can you address that?
5 I'll give you the -- you know, my perspective is --
6 this is Dave Pelton again. As the Branch Chief and 7 talking closely with Emma and the folks in her 8 branch is that, you know, it's -- you know, there's 9 known physical changes in Boral over time. And it 10 is recognized in EPRI guidelines and a lot of 11 operating experience.
12 And the concern is, we talked about it 13 yesterday that as a blister forms, you know, right 14 now there hasn't been a Boral issue related where 15 the material, the substrate, the boron powder, you 16 know, fall away and changes its configuration, thus 17 maybe changing the criticality assumptions.
18 That doesn't mean it won't happen. So, 19 you know, my impression is that these actions are 20 precautionary to make sure that the licensee doesn't 21 inadvertently -- you know doesn't find themselves NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 down the road in a situation where the criticality 2 assumptions have changed because the configuration 3 with the Boral plates themselves have changed based 4 on these physical changes.
5 So we think it is prudent if nothing 6 else at this point to make sure they are monitoring 7 it.
8 MEMBER ARMIJO: So far, have there been 9 any measurements of neutron absorption in plants 10 that have exhibited this blistering? And have you 11 found that there have been lots of them?
12 MR. PELTON: Emma, I'm going to turn 13 that over to you.
14 MS. WONG: There has been blistering 15 seen. But they all have been water filled. Our 16 concern is if it is going to be gas filled, and then 17 that changes the criticality analysis if they 18 haven't accounted for it in their original 19 criticality analysis.
20 MR. LAKE: But, you know, this is not a 21 Vogtle issue. I'm just saying why is Vogtle being -
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1 - this is not a Vogtle problem. This is a broader 2 issue.
3 MR. PELTON: It is. And, you know, 4 historically, you know I'm not going to pretend to 5 be an absolute expert or all knowing, which -- well, 6 sometimes I am but nonetheless -- you know in the 7 past with Boroflex, you know, we did see changes 8 both in physical properties and in its neutron-9 absorbing capability.
10 And there has been a relatively recent 11 issue at Palisades with a material I've heard -- I 12 believe it is Carborundum -- where, again, they had 13 physical changes and then when the licensee did some 14 neutron-absorbing tests, they found that some 15 assumptions had changed in that regard as well.
16 So, you know, we're trying to stay one 17 step ahead of --
18 MEMBER ARMIJO: I just want to get it 19 straight. Have there been any measured losses in 20 neutron-absorbing capability on Boral in in the 21 industry?
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1 MS. WONG: No.
2 MR. PELTON: I don't believe that there 3 has been. Emma, is that true?
4 MS. WONG: I don't believe there is.
5 MEMBER ARMIJO: Okay. There have been 6 measurements but nobody has found the loss but 7 you've seen the blistering. You are anticipating 8 there could be loss.
9 MR. PELTON: Correct.
10 MEMBER ARMIJO: Okay. I understand it.
11 Thank you.
12 MEMBER BANERJEE: I have a question.
13 What is the status with regard to inspections and so 14 on related to CRDM cracking? Any potential for 15 this?
16 MR. ASHLEY: From regional inspections?
17 MEMBER BANERJEE: Or by the licensee.
18 Are there any issues related to it in the long term?
19 MR. ASHLEY: We're not aware of that for 20 --
21 MR. COLLINS: This is Jay Collins from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the Piping and NDE Branch. We currently have issued 2 a rule in September of 2008 which updated our 3 requirements for a CRDM inspection. And the Vogtle 4 licensee will continue to follow those requirements 5 going forward. We don't anticipate anything that 6 would be in the current licensing.
7 MEMBER BANERJEE: It's not one of the 8 plants which are closer to the limits is it?
9 Pressure, temperature, chemistry?
10 MR. COLLINS: The requirements --
11 MEMBER BANERJEE: I'm not talking about 12 inspection but where is it in the sort of hierarchy 13 of plants which are susceptible to this sort of --
14 MR. COLLINS: I can get back to you with 15 the specifics but --
16 MEMBER BANERJEE: Okay.
17 MR. AJLUNI: Mark Ajluni, Southern 18 Nuclear Licensing.
19 Vogtle is a low-TF plant and ranks low 20 in susceptibility.
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1 answering.
2 CHAIR BONACA: On page 17, you list 3 three ways in which you may deal with TLAA. And the 4 question I have is could you highlight which of the 5 TLAAs as such that the aging effects would be 6 managed for the period of extended operation?
7 MR. ASHLEY: All the plant-specific 8 TLAAs would fall into that category to be managed.
9 Unless I misunderstood your question.
10 CHAIR BONACA: Well, I'm trying to 11 understand, you know, of the -- you are saying the 12 TLAA will remain valid for the period of extended 13 operation or they will be project or they will be 14 managed typically means that that TLAA doesn't reach 15 the 60 years.
16 MR. ASHLEY: They would continue to 17 monitor the TLAAs --
18 CHAIR BONACA: That's right. I would 19 have liked to see a list of those.
20 MR. ASHLEY: -- over the path -- over 21 the entire period of extended operations to make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 sure that they remained valid.
2 CHAIR BONACA: I understand that. I'm 3 trying to understand which ones.
4 MR. ASHLEY: Oh, which ones 5 specifically?
6 CHAIR BONACA: Yes.
7 MR. ASHLEY: Well, the plant specific 8 ones obviously. But any additional that would 9 require updates, I don't know a specific list of 10 those.
11 CHAIR BONACA: Okay.
12 MEMBER SIEBER: Okay. I think the 13 vessel TLAAs require ten-year updates, something 14 like that. That would be an example.
15 MR. ASHLEY: Yes, they would be on the 16 list.
17 Jim Medoff?
18 MR. MEDOFF: This is Jim Medoff with the 19 staff. Typically the ones that you see aging 20 management on, you may see them used on the III 21 criterion for a fatigue TLAA. You may see it on, I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 think it is EQ, but Doug can verify that with me.
2 And you may see it occasionally on some plant-3 specific TLAAs that are in Chapter 47 of the 4 application.
5 CHAIR BONACA: Yes, I mean the reason 6 why I asked that question is that there is a special 7 interest in those where aging effect have not been 8 projected to the end of the license period. And, 9 therefore, they have to be managed.
10 MR. ASHLEY: That is correct.
11 CHAIR BONACA: So that's why I asked 12 that question.
13 MR. ASHLEY: Thank you.
14 MEMBER SIEBER: Is there any other 15 questions from members?
16 (No response.)
17 MEMBER SIEBER: If there are no other 18 questions, I think this concludes this portion.
19 CHAIR BONACA: Okay. Thank you for the 20 presentation.
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1 cannot start the next session until 10:15. So we 2 will recess until 10:15.
3 (Whereupon, the foregoing matter went off the record 4 at 9:23 a.m. and went back on 5 the record at 10:14 a.m.)
6 CHAIR BONACA: This section is on 7 digital instrumentation and control interim staff 8 guidance. Before I turn over the meeting to Mr.
9 Brown, I would like to just announce that myself, 10 Sam Armijo, and Abdel-Khalik will meet with the EDO 11 at noontime, so we will be leaving, and I would like 12 Bill Shack to chair the meeting for the brief time 13 in which we will not be here, until we start the 14 meeting at 1:00, if we are not back by that time.
15 With that, I'll turn over the meeting to 16 Mr. Charlie Brown.
17 MEMBER BROWN: Thank you, Mr. Chairman.
18 Just for a piece of information, this meeting is 19 strictly to cover, and I say that -- try to make 20 sure we focus on these two particular subjects, is 21 Interim Staff Guidance 5. It's a new Section 3, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 which are human factors of the overall ISG, but it's 2 really as a result of some questions from us, or 3 requests from the Committee on crediting manual 4 operator actions for diversity and defense-in-depth 5 as a substitute, as opposed to automated systems. I 6 think I phrased that roughly correctly.
7 And the second one is to try -- ISG-6 is 8 what's referred to as the licensing process for 9 digital I&C. And the purpose of that is to try to 10 put a little meat to go out to the folks submitting 11 these, telling them what types of information they 12 have to submit in order to allow the Staff to do a 13 satisfactory job of evaluating those designs. And, 14 right now, it's just kind of amorphous.
15 So, with that, I will turn it over to 16 David Desaulniers, Steve Arndt, and Ed Miller. I 17 guess Steve is the leader of the pack.
18 MR. ARNDT: I'm the first speaker, 19 anyway.
20 Good morning.
21 (Chorus of good mornings.)
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1 MR. ARNDT: Mr. Brown mentioned what 2 we're going to do today, is give you a highlight of 3 the ISG-5 update, and the status of ISG-6 licensing 4 process update. We reviewed this with the Digital 5 I&C Subcommittee on February 26th and 27th.
6 I will start off with giving you just a 7 real basic background, hopefully skip through the 8 slides fairly quickly, give you a reminder of the 9 ISG process, and how we go to this point; 10 particularly, for those of you who didn't read the 11 article in this month's ANS Nuclear News that goes 12 into this in detail. Then, Dave will give you an 13 overview of what's actually in ISG-5 Rev. 1.
14 MEMBER APOSTOLAKIS: Which month is 15 this, Steve?
16 MR. ARNDT: March. Then Ed will give 17 you an overview of ISG-6. We are requesting a 18 letter on this this week.
19 As a result of the November 2006 20 Commission meeting on Digital Instrumentation and 21 Control, the Commission requested that the Staff put NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 together a project plan for improving the efficiency 2 and effectiveness of digital I&C reviews, and, also, 3 establish a Steering Committee to oversee those 4 activities, and to coordinate interactions with the 5 industry. We've had extensive interactions with the 6 industry, as well as the public. We're up to almost 7 150 public meetings over the last two and a half 8 years on developing and improving the digital I&C 9 guidance.
10 One of the first things we did was 11 establish a set of high-priority, short-term actions 12 that we wanted to look at to improve the efficiency 13 and effectiveness of the process. There is concerns 14 by the industry, and by the Commission, that our 15 process was good, it was adequate, we could get 16 where we needed to be, but we didn't have everything 17 well-established. It wasn't very efficient. We 18 didn't know how to go through it in an effective 19 way. So, what we did, was we established a set of 20 particular issues to improve. Those were assigned 21 to seven task working groups listed there. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 determined that the process by which we would update 2 the guidance would be to develop interim staff 3 guidance through public interactions and 4 discussions.
5 Once those were established, we'd go 6 back and update the regular guidance. We had a Reg 7 Guide SRP Chapter, NUREG, whatever the appropriate 8 guidance would be. During that discussion, the ACRS 9 asked to be briefed on a regular basis on ISGs as 10 they were being developed. Done that, in most cases 11 prior to issuance, in some cases just after 12 issuance, depending upon the schedule. And we're 13 tried to incorporate as many of the inputs and 14 guidance the Committee has provided to us in those 15 guidance. The Committee will get another 16 opportunity when they become part of the update to 17 the regular regulatory guidance.
18 A few basic examples. I'll walk through 19 this fairly quickly, so we can get to the meat.
20 ISG-1, which was in cyber security. The ACRS 21 reviewed it as part of their review, and issued a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 letter in April. This was, basically, to look at 2 the issue associated with the guidance for 3 developing safety systems under Reg Guide 1.152, and 4 the equivalent industry guidance, NEI 04-04. We 5 reviewed those. We provided an ISG for additional 6 information on how to meet those requirements in 7 either 1.152, or the NEI guidance.
8 Diversity and defense-in-depth, which is 9 a particularly challenging area for I&C, we provided 10 a significant amount of additional technical 11 guidance on what we meant, how we meant it, and what 12 would be an acceptable guidance. This is acceptable 13 guidance. Jack Herb likes to call it the fast lane, 14 the HOV lane. If the industry chooses to do this 15 particular methodology, we will have a more 16 expedited review. In that, it includes discussions 17 of how much diversity is sufficient, what kind of 18 diversity, these kinds of issues.
19 One of the issues that was brought up 20 during that review was, if you're going to credit 21 manual operator action as part of your diversity NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 strategy, what would be the criteria associated with 2 that crediting? ISG-2, which, again, is the fast 3 lane, indicated that the criteria would be 30 4 minutes. If you have 30 minutes of time to evaluate 5 and assess, that would be considered an acceptable 6 mechanism. If it was less than that, the default 7 position would be additional diverse actuation would 8 be necessary.
9 Obviously, there are alternatives that 10 have been proposed, and some that have been 11 tentatively approved. The Committee, however, felt, 12 as did the Staff, that a more formalized review 13 process would be appropriate, so ISG-5 now is being 14 updated to include that, and we'll get to that 15 shortly.
16 Risk, of course, was a major issue.
17 We've looked at this extensively. One of the 18 challenges, of course, is that digital systems are 19 incorporated in all the new plants, and Part 52 20 requires a comprehensive PRA to be evaluated, so the 21 first part of that issue was to provide some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 guidance on what would be an acceptable Part 52 PRA.
2 That was issued after ACRS review in August of 3 2008. Other issues were brought up associated with 4 what can we do for relaxing requirements based on 5 risk information? Staff determined that that was not 6 yet a ripe subject. That has been deferred to the 7 Research Program.
8 ISG-4 looks at communications, 9 electronic communications in the control room, 10 issues associated with multi-divisional video 11 display units, inter-channel communications, et 12 cetera.
13 As I mentioned, ISG-5 looks at a number 14 of issues. The first revision, which was issued in 15 September of 2007, included -- help me, Dave.
16 MR. DESAULNIERS: First, included 17 computer-based procedures.
18 MR. ARNDT: Thank you.
19 MR. DESAULNIERS: And minimum inventory.
20 MR. ARNDT: And minimum inventory. This 21 new update goes on to include manual operator NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 action. One of the issues that was raised, the 2 safety parameter display system, wording in the 3 actual rule was going to require rule making, and 4 that's been put on that track, instead of the ISG 5 track.
6 Licensing process you'll hear more 7 about, but this was the whole issue of what level of 8 detail needs to be reviewed, how is it reviewed, 9 when is it reviewed, how do you stage the reviews, 10 how do you provide a level of assurance that the 11 reviews are going well for the industry, so that 12 they can better plan their resources?
13 ISG-7 is the fuel cycle facility.
14 Originally, we were not going to have this, but as 15 we looked more at the fuel cycle facilities, these 16 are enrichment plants, the fuel facilities, and 17 things like that that are being built right now, it 18 looks like a lot of distributed computer-based 19 control, a lot of very similar kinds of issues. So, 20 we are in the process of taking care of the 21 electronic and digital issues associated with that.
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1 Slightly different issues associated with 2 consequence, slightly different issues associated 3 with how distributive the systems are, but we'll 4 have a very similar one. That's currently under 5 development, and we'll talk to the Subcommittee 6 probably in August about that.
7 In addition, there's a lot of other I&C 8 work going on. We talked to the Committee in 9 February a little bit about the Oconee review. Wolf 10 Creek is - I'm looking at Bill Kemper - we've just 11 issued the Wolf Creek safety evaluation report, 12 which is using a newer technology, field-13 programmable gate arrays for some of their safety 14 systems.
15 We're also going back and looking at 16 some of the operational issues associated with what 17 are the challenges associated with digital I&C, when 18 you actually get in the plant. How do you do 50.59 19 determinations? If you have an event, how do you do 20 significant determination process? Are there going 21 to be any challenges?
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1 We believe that most of these will be 2 fairly straightforward analysis. You just have to 3 work them through the process. Since we don't have 4 particularly good risk models, it will be a little 5 bit more difficult. Maybe expert panel, like we do 6 for the maintenance rule for systems, we don't have 7 the model for things like that. We're in the 8 process of working through those right now.
9 So, as the Steering Committee moves 10 forward, we're going to complete the ISGs.
11 Hopefully, we'll get the good alignment with our 12 industry colleagues. We've been using very 13 collaborative interactions with our industry 14 colleagues. We've been using the ISGs in the 15 reviews of Oconee, and Wolf Creek, and a number of 16 other review items. Also, in the advanced reactor 17 area for the review of topical reports in those 18 areas. We've gotten pretty good feedback on it. We 19 will update the regulatory guidance as we get more 20 experience, and get the time to do those. We'll 21 integrate those into our international NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 collaboration. We're getting a lot of input from 2 our international colleagues, and, also, requests 3 for how did we come up with this? How are we 4 implementing it, things like that. We're 5 proactively working in a number of bilateral areas.
6 We're working extensively in the MDEP program. Ian 7 Jung is one of the chairs of the INC part of the 8 MDEP program. The International Database program on 9 digital system failures important to safety, 10 COMPSIS, we're collaborating, so we're continuing to 11 work on this issue.
12 One of the biggest challenges, of 13 course, is digital systems evolve so quickly 14 compared to their analog inputs, we need to stay 15 ahead of the curve, if we can, or, at least, keep up 16 with it.
17 MEMBER APOSTOLAKIS: Steve, in your 18 interactions with international organizations, have 19 you noticed any differences in the emphasis they 20 place, for example, here, we think now we are all on 21 the same wavelength, and we're thinking potential NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 failure modes, and the risk part can wait until we 2 know more. Although, these guys usually are not too 3 hot about risks, is there a difference, you think, 4 in perspectives?
5 MR. ARNDT: There is some difference.
6 And I'll take a first crack at it, and let Ian weigh 7 in if I don't capture everything.
8 Depending upon the regulatory structure, 9 for example, the Brits have a much more heavily 10 structured risk component in their licensing 11 process. So, they're a little more enthusiastic 12 about the risk efforts. The French, as you know, 13 are very adverse to incorporating this, and we're 14 kind of in-between. But, depending upon the 15 licensing process, the structure of their issues, 16 there are some differences. But we are seeing a lot 17 of similarity, as well.
18 Diversity, for example. Most of the 19 companies are coming in fairly close to where we are 20 on diversity, in some cases, actually even more 21 conservative than we are. But we're starting to see NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 a convergence in that area. Ian, would you like to 2 amplify on that at all?
3 MR. JUNG: Yes, Ian Jung with NRO. One 4 of the insights that we are gaining through new 5 reactor reviews, for example, EPR, we've been 6 interacting with the French and Germans extensively 7 last couple of years. I think what we are finding 8 is the design stages for those countries are not --
9 none of the reviews are completed. What we're 10 finding as we go, we are finding that some of the 11 new design details that brings out some of the new 12 concerns. But, in all cases, the way each country 13 is approaching, is based on sort of mostly a 14 deterministic approach, that they are making 15 significant assumptions of common cause failure, for 16 example, and how to deal with that. And their 17 approach has been somewhat different, and they have 18 a hard-wire backup, for example. But, in the French 19 case, they haven't even decided exactly what is 20 acceptable diversity and defense-in-depth at this 21 point. So, as we work together, I think we are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 gaining a lot of insights.
2 MEMBER APOSTOLAKIS: So, is the approach 3 that, if there is a common cause failure, and we 4 don't even know why, are we protected? Which is 5 really what I think one of our old NUREGs is doing.
6 Are they following the same kind of philosophy?
7 You have to speak up.
8 MR. JUNG: Oh, yes. I think we're 9 making the same assumption, that we don't know 10 exactly what failure modes we are talking about yet.
11 We have to deal with it.
12 MEMBER APOSTOLAKIS: Do you think any of 13 those groups are ahead of us, in the sense of 14 they've done more work?
15 MR. ARNDT: I think from the area of 16 operational experience, certainly, some countries 17 have more years of dealing with the systems than we 18 do, so they may have a little bit more insight in 19 that aspect. But, by and large, we're probably as 20 far along, if not ahead, of most countries in terms 21 of actually figuring out what we want, why we want NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 it, and what the technical basis is associated with 2 that.
3 MEMBER APOSTOLAKIS: Final question.
4 MEMBER BROWN: Don't worry. I'll 5 interrupt you in a minute. This is not a common 6 mode failure of this meeting.
7 (Laughter.)
8 MEMBER APOSTOLAKIS: You will address 9 the issue of operator action, and timing, and all 10 that. Are they addressing that, at all?
11 MR. ARNDT: I have not seen a lot of --
12 most of the international interactions I've had, 13 have basically been, we generally agree with your 14 30-minute criteria, and we're either implementing 15 it, or modifying it, but they're taking lead from 16 us. Ian, you may have a different perspective.
17 MR. KEMPER: Yes. This is Bill Kemper.
18 I'll just try to answer -- add some information to 19 your question here, George. In that meeting that we 20 had a couple of years ago with seven different 21 regulators, we asked them specifically what was the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 time response for operator actions, and almost of 2 them had some criteria. It varied from 15 minutes, 3 to 30 minutes, but they almost all were sensitive to 4 that, and they brought that into their regulatory 5 criteria.
6 MEMBER APOSTOLAKIS: Thank you.
7 MR. ARNDT: Okay.
8 MEMBER RAY: Let me make one comment 9 here in the context of your talking about other 10 organizations. Something you might not have 11 noticed, perhaps you did. The March 19th FERC 12 agenda had an interesting comment about that FERC 13 would regulate all critical equipment within nuclear 14 power plants that's not regulated by the NRC. So, 15 it would be interesting to know how the heck we 16 figure out what's regulated by the NRC. But that's 17 not for this meeting. I just want to make sure you 18 knew.
19 MR. ARNDT: We are intimately aware of 20 that issue, both the electrical and the I&C branches 21 both in NRR, NRO, and NSIR are working those issues NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 right now.
2 MEMBER RAY: Okay.
3 MR. ARNDT: With that, I am going to 4 turn it over to my colleague, Dave. And he's going 5 to go through, at some level of detail, ISG-5, 6 Revision 1.
7 MR. DESAULNIERS: Good morning, all. My 8 name is David Desaulniers. I'm Senior Technical 9 Advisor for Human Factors in the Office of New 10 Reactors. I'm also a member of TWG-5, as the human 11 factors lead for that group.
12 Today, I'll be providing an overview of 13 the most recent interim staff guidance developed by 14 TWG-5. And, as Steve has already told you, that 15 guidance concerns the crediting of manual operator 16 actions in diversity and defense-in-depth analyses.
17 We amended ISG-5 in November of '08, to 18 include that manual operator action guidance, and 19 that's why the slide title here Rev. 1. As noted, 20 also, previously, the subject is also an ISG-5, 21 computer-based procedures and minimum inventory.
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1 That guidance was completed in September of '07, and 2 the Committee has been provided a presentation 3 regarding those topics, previously.
4 By way of background to discuss the 5 manual operator action guidance in ISG-5, I'm going 6 to briefly speak to ISG-2, and we have Ian Jung 7 here, so if I misrepresent ISG-2, please correct me 8 here if I go astray. But, ISG-2 was really the 9 genesis for this particular guidance in ISG-5. ISG-10 2 was addressing concern that a software problem, 11 digital protection, reactor protection system could 12 affect multiple channels, and result in a common 13 cause failure of B 14 MEMBER APOSTOLAKIS: So, is the issue of 15 operator action part of ISG-2 or 5, or both? Are 16 they looking at different things?
17 MR. DESAULNIERS: No. They're looking 18 at the same thing. What we're doing here is, is 19 we're simply providing additional clarification and 20 guidance that was in ISG-2, and we're expanding upon 21 that to provide greater detail on how to credit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 manual operator actions they hadn't discussed in 2 ISG-2.
3 MEMBER APOSTOLAKIS: But 2 and 5 will be 4 consistent.
5 MR. DESAULNIERS: Yes.
6 MEMBER APOSTOLAKIS: Okay.
7 MEMBER BROWN: They hope. ISG-2 says 8 greater than 30 minutes.
9 MEMBER APOSTOLAKIS: Right.
10 MEMBER BROWN: The default is greater 11 than 30 minutes.
12 MEMBER APOSTOLAKIS: Right.
13 MEMBER BROWN: If you have less than 14 that, you build hardware, or something. This says 15 B 16 MR. DESAULNIERS: The Staff B 17 MEMBER BROWN: You all asked, and I went 18 back and read the minutes and the letter, and you 19 all asked them to evaluate a process that would 20 allow consideration of operator response in less 21 than 30 seconds.
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1 MR. DESAULNIERS: Thirty minutes.
2 MEMBER BROWN: Thirty. That would be B 3 (Simultaneous speech.)
4 MEMBER BROWN: I don't know. Okay. If 5 we had a PRA, maybe we would. I'm just teasing.
6 Okay. But, yes. Less than 30 minutes, yes. So 7 that's --the thrust here was to lay out a process 8 and methodology to address that, to address the less 9 than 30 minutes issue, fundamentally. Although, to 10 apply to whether it's greater than 30 minutes, is 11 really valid, also.
12 MEMBER APOSTOLAKIS: I understand that, 13 but my question is, why does it appear in two 14 places, 2 and 5?
15 MEMBER CORRADINI: Yes. Why didn't you 16 review 2, I guess is George's question.
17 MEMBER APOSTOLAKIS: What is my 18 question?
19 (Laughter.)
20 MEMBER CORRADINI: Why didn't you just 21 review 2, and put this in.
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1 (Simultaneous speech.)
2 MR. DESAULNIERS: ISG-2 is currently in 3 the process of being revised so that it 4 appropriately points to ISG-5, where the human 5 factors guidance is provided. So, we are working to 6 insure the guidance appropriately point to each 7 other, and we just put the details of the guidance 8 in ISG-5 as human factors guidance.
9 MEMBER CORRADINI: Just so I understand, 10 just for clarity. So, what you're saying is, if you 11 accept 30, plus or minus 30, you'd stick with 2. If 12 you want to get into the realm of less than 30, go 13 see 5.
14 MEMBER APOSTOLAKIS: No, I don't think 15 that's what I said.
16 MEMBER CORRADINI: That's what I heard 17 you say. I apologize.
18 MR. DESAULNIERS: What we're doing is, 19 basically, providing guidance that will -- ISG-2, 20 basically said if you're going to credit manual 21 operator action, you need to do a human factors NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 evaluation in order to credit that action. We're 2 providing the guidance for how to do that human 3 factors evaluation.
4 MEMBER APOSTOLAKIS: Okay.
5 MR. DESAULNIERS: Now, there was an 6 assumption under ISG-2 that you were, basically, 7 crediting action over 30 minutes. This guidance 8 that we are providing, as Charlie mentioned, will 9 provide methodology to credit action, whether it's 10 over 30 minutes, or under 30 minutes.
11 MEMBER CORRADINI: Thank you.
12 MEMBER APOSTOLAKIS: But, I thought your 13 answer would be that this issue of human factors 14 appears naturally both in 2 and 5. In 2, it may be 15 part of defense-in-depth. In 5, we are dealing with 16 an integrated control room, and we want to know, 17 again, how -- what the timing is, and all that. Is 18 that the correct perception, that it's an issue that 19 naturally appears in both? That's why it's in both.
20 MR. DESAULNIERS: I believe that would 21 be a fair characterization.
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1 (Off the record comments.)
2 MR. DESAULNIERS: Under the D3 analysis, 3 going back to vulnerability for common cause 4 failure, such vulnerabilities are identified. As 5 previously stated, there's the option of using an 6 inverse automated backup system to address such 7 vulnerabilities. Alternatively, ISG-2 provides, as 8 we've been discussing, the option to use manual 9 operator action.
10 Specifically, with regard to manual 11 operator action, ISG-2 stated what's on your screen 12 here, and they may be credited for responding to 13 events in which the protective actions subject to 14 the common cause failure is not required for at 15 least 30 minutes, and the plant response is bounded 16 by the Branch Technical Position 7-19, recommended 17 acceptance criteria.
18 This is the guidance that the Committee 19 had heard. There was recommendation that we 20 consider a process that looks at 30 minutes, above 21 and below 30 minutes, and this is where we developed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 guidance in ISG-5.
2 Not only did we hear that message from 3 the Committee, but also industry. They were 4 recommending that we consider guidance for less than 5 30 minutes. ACRS provided us a letter in October of 6 '07 recommending development of such a process. So, 7 the TWG-5 action plan was expanded to incorporate an 8 action item to address this issue. We proceeded 9 with public interactions with our industry 10 counterparts to develop that guidance. Industry 11 developed a White Paper for a methodology which we 12 took into consideration as we were developing the 13 ISG, so we gave that consideration, and we 14 incorporated it into -- much of that into the 15 process that I will go on to describe.
16 The ISG has three major sections to it, 17 scope, Staff position, and methodology. And I'll 18 address each of these in more detail in the 19 subsequent slides. The guidance is review guidance.
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1 licensees and applicants can demonstrate that the 2 proposed manual actions are feasible, can be 3 implemented reliably. You will, ultimately, see a 4 key component of this process is a demonstration in 5 real time of the ability to perform those actions.
6 This slide summarizes material and scope 7 section of the ISG. This is where we, basically, 8 highlight fundamental assumptions and expectations 9 associated with this guidance. The scope covers the 10 credited actions in the D3 analysis, as we've been 11 discussing, talking about instances of abnormal 12 operational occurrences, and postulated accidents 13 concurrent with the software common cause failure, 14 the digital protection system. Again, in the 15 context of ISG-2, the digital protection system 16 here, you're talking about the reactor trip system, 17 and the SFAS system. As a result, you're talking 18 about instances where you're looking at cases of 19 beyond design-basis to consider for those actions, 20 where you're talking about backup actions in this 21 case. The guidance is applicable to both new and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 existing reactors, so that summarizes the scope.
2 The Staff position, again, the general 3 high-level expectations that the actions that are 4 going to be credited would be included in the 5 emergency operating procedures, they would be 6 executed from within the main control room, so we're 7 not, in this case, talking about crediting actions, 8 local actions elsewhere in the plant. These should 9 be demonstrated to be both feasible and reliable.
10 And, ultimately, they can be addressed in the human 11 factors engineering program consistent with Reg 12 Guidance for that program, which is NUREG 0711.
13 MEMBER APOSTOLAKIS: You have an 14 argument why you have excluded outside the control 15 room?
16 MR. DESAULNIERS: Yes. Again, we're 17 talking about actions that -- the emphasis in 18 developing this guidance was clearly on can we 19 credit actions in less than 30 minutes? So, there 20 is a limited time B 21 MEMBER APOSTOLAKIS: This is the B NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 MR. DESAULNIERS: Yes, the guidance can 2 be applied to instances of greater than 30 minutes, 3 but going into development of guidance for actions 4 outside the control room takes into additional 5 considerations of environmental conditions, and 6 transient requirements that we didn't attempt to 7 encompass in this cut of the guidance.
8 MEMBER APOSTOLAKIS: But if somebody --
9 so, it's an application, and they give you a 10 systematic approach to addressing this, you would 11 still look at it. It's not excluded. You would 12 probably question the timing, and the conditions, 13 and so on, but B 14 MR. DESAULNIERS: This is guidance, and 15 it doesn't prohibit the applicant from proposing 16 approaches that would be outside that guidance.
17 MEMBER APOSTOLAKIS: Okay.
18 MEMBER MAYNARD: I guess, I still am not 19 sure that it's a good idea for the Staff's position 20 to exclude it. It may take more work, or it may be 21 more difficult, or whatever. But when you put in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the Staff position that it excludes -- basically, 2 just for actions in the control room, you're kind of 3 into a no-man's land. And I agree that more 4 scrutiny on actions outside the control room, but a 5 lot of plants have unique features, and different 6 things that -- you're probably going to have to 7 address that, anyway. Are you going to address that 8 within guidance, or are you going to do it totally 9 outside of the Staff position?
10 MEMBER APOSTOLAKIS: The word 11 "exclusion" is kind of strong.
12 MEMBER MAYNARD: Right. Yes. David?
13 MR. DESAULNIERS: Ultimately, the 14 interim staff guidance will be developed further to 15 be incorporated into a permanent guidance document.
16 An opportunity will be there to address further 17 issues. But, at this point, the objective was to 18 try to get out something in a timely fashion for 19 industry, so we limited the scope to where the Staff 20 and industry believes it was most likely going to be 21 needed, at this point. So, it was within the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 control room.
2 MEMBER RAY: The bullet there about 3 demonstrated to be feasible and reliable seems -- of 4 course, you want that to be a criterion, but how to 5 accomplish that would be awfully tough. Do you have 6 any thoughts as to what that B 7 MR. DESAULNIERS: As I go into the 8 process, you will see that that's specifically what 9 the process is all about, demonstrating both the 10 feasibility and reliability.
11 MEMBER RAY: Okay. I didn't attend the 12 Subcommittee, so just go right ahead.
13 MR. DESAULNIERS: Okay. So we will go 14 in, and we'll address that more in detail later in 15 this presentation.
16 The methodology section is comprised of 17 four phases; analysis, preliminary validation, 18 integrated system validation, and then long-term 19 monitoring. These phases roughly correspond to the 20 phases you have seen in the industry White Paper.
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1 and emphasis amongst these, but the process, 2 overall, is -- we're fairly close. I'll move on to 3 the analysis section, which is the first slide.
4 The objective of the analysis phase 5 here, and this is the first part of -- again, the 6 first section of the overall process. And the 7 emphasis here is, preliminary assessment of what is 8 the time available to perform the required actions, 9 and that's based on analysis of a plant response.
10 And, then, what is the time required for the 11 operator to actually implement the actions necessary 12 for the mitigation?
13 The objective here, also, is to identify 14 what are the critical assumptions in critical 15 operator errors that would underline this analysis.
16 And, ultimately, establish an adequate margin 17 between your estimate of time available, and your 18 estimate of what the time required is.
19 MEMBER APOSTOLAKIS: Now, estimate, what 20 -- are you going to tell us how people estimate 21 things? Yes.
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1 MR. DESAULNIERS: Yes. More 2 specifically, time available is estimated using 3 methods consistent with those described in ISG-2.
4 We're talking about realistic assumptions regarding 5 the plant response, and the criteria in BTP 7-19.
6 To estimate the time required, it's expected that 7 that time required would be based on an analysis of 8 a documented sequence of actions, such as that you 9 may find in the task analysis, the emergency 10 procedure guidelines, or EOPs. And you would use 11 one of several acceptable methods for developing 12 those estimates. And we'll provide on a subsequent 13 slide some of those methods.
14 The margin calculation, the methodology 15 proposed by the Staff is that that would be --
16 margin would be established based on the time 17 required to recover from credible errors. So what's 18 the longest time that would be required to recover 19 from a credible error? And you would use that as 20 your margin, difference between your time available, 21 and time required.
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1 This slide lists acceptable methods.
2 This is not an all-inclusive list. They're not 3 limited to these, but the guidance provides examples 4 of acceptable methods. And they range from 5 developing your estimate of time required based on 6 operator interviews and surveys, or looking at 7 operating experience, making use of software models 8 that model human behavior and task sequences, using 9 mockups, control room mockups as a tool, expert 10 panel elicitation, and it includes a ANSI Standard, 11 which is ANSI/ANS 58.8, which was developed to 12 provide a basis for estimating time required to 13 perform safety-related operator actions.
14 That methodology, we provide as a means 15 for basically doing the task decomposition, which 16 means breaking down those operator actions into the 17 particular elements so that you have a detailed 18 analysis of that action sequence, provides a good 19 framework for doing that. We're not, necessarily, 20 endorsing that guidance through our risk, as a means 21 of coming up with the specific numbers that are in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 that guidance document, because there are specific 2 numbers associated with action sequences that we 3 don't believe, perhaps, are appropriate to 4 application here in a digital control room.
5 MEMBER BROWN: Relative to this, though, 6 if I go through that list and look at it, it's a 7 pretty soft, very qualitative list, which, when I 8 read the ISG and how that was put together, 9 effectively - now, correct me if I'm wrong - but it, 10 effectively, established a methodology for each 11 licensee can develop his own metrics based on his 12 operator interviews, his analysis, his surveys, his 13 own particular experience. And there's no common 14 metric that then gets carried forth from licensee to 15 licensee. So, every time somebody wants to do it, 16 you're going to have to re-evaluate whether that 17 qualitative approach is satisfactory, how thorough 18 was it, what was the detail of the modeling that 19 they did, what standard, from where did they draw 20 the standard when they did the analysis, if it was a 21 standard?
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1 I mean, it just seemed fairly vague when 2 I went through it relative to a nice -- I didn't 3 expect it to be hammered in concrete, but I would 4 have expected some metrics to be laid out to define 5 how you would do this. I mean, you can talk to 6 people and say oh, yes, it only takes me five 7 minutes to do that. Well, every time I figure it's 8 only going to take me five minutes to do something, 9 it takes me an hour. I'm being a little facetious, 10 but I did it for a purpose. The individual's 11 ability to estimate their time to perform something 12 in a non-stressful situation is, I think, fraught 13 with peril, from that standpoint.
14 MR. DESAULNIERS: I don't disagree with 15 your observations, and I believe that is, in fact, 16 why the subsequent phase, preliminary validation, is 17 intended to be a independent confirmation of the 18 initial analysis. Also, it behooves the applicant 19 to be conservative in their assessments with respect 20 to the time that's required. In other words, not to 21 under-estimate the time required, but to estimate on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the high side, because, ultimately, this action will 2 need to be proven out in a demonstration of 3 integrated system validation. And if, at that 4 point, that time required exceeds what was in their 5 analysis, they're failing one of the criteria of 6 their integrated system validation. So, yes, it's 7 qualitative, and it would have been nice to be able 8 to go to something more like ANSI/ANS 58.8, which 9 provided specific time criteria associated with each 10 of these elements, but we didn't believe we were 11 prepared to do that at this point. And that's 12 something that we have as a plan to develop in the 13 future B 14 MEMBER BROWN: Having endorsed that 15 standard. I think it said that when we go to the 16 presentation somewhere, if I remember correctly.
17 MR. DESAULNIERS: Ultimately, we would 18 like to support further development of ANSI/ANS 19 58.8, so that it could be endorsed as a standard 20 appropriate to the application of digital control.
21 MEMBER BROWN: So, then are you B NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 MR. ARNDT: We have not endorsed the 2 standard.
3 MEMBER BROWN: Yes, okay. I got that.
4 I wasn't going to beat that to death. But here's a 5 circumstance, whether you want to issue this late 6 this year, or later this year, for actual use by the 7 licensees when they're doing analyses. I think you 8 said something about the fall, or whatever, you 9 wanted to issue this.
10 MR. ARNDT: Well, we've already issued 11 the interim guidance. We'd like to issue the long-12 term permanent regulatory guidance later this year, 13 early next year.
14 MEMBER BROWN: Oh, so this -- I didn't 15 understand. Is that actually already out, this 16 Section 3?
17 MR. ARNDT: Yes, sir.
18 MEMBER BROWN: Okay.
19 MR. ARNDT: It can be revised.
20 MEMBER BROWN: I didn't know that.
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1 ask that, and I forgot to, so I appreciate the 2 answer.
3 MR. ARNDT: I'd also like to point out, 4 there are industry standards, at least in the 5 nuclear business, on how to conduct operator 6 interviews, and operator surveys, and task network 7 modeling, and things like that, so it's -- there are 8 standardized methodologies out there, so it's not 9 quite as loosey-goosey as it might seem.
10 MEMBER BROWN: Go ahead.
11 MR. DESAULNIERS: Okay. The -- I won't 12 go into the detailed review criteria, but the 13 general topics that are provided associated with the 14 analysis phase for NRC review are listed here, 15 ranging from time required, and time available, to 16 the staff size, composition, and augmentation of 17 that staff, and identification of credible operator 18 errors.
19 As, for an example, one of the criteria 20 would be that time required estimate to allow 21 sufficient -- should be sufficient to allow for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 implementation of the symptom or function-based EOPs 2 to address the particular event. So, it would not -
3 - it would allow for that type of response.
4 MEMBER APOSTOLAKIS: I have a question.
5 I'm sorry.
6 MR. DESAULNIERS: Oh, I was going to 7 say, a second example with regard, for example, 8 staff size, is the criterion would be that they 9 would be able to implement the actions, assuming the 10 minimum crew size required by the technical 11 specifications.
12 MEMBER APOSTOLAKIS: Something that has 13 been bothering me for a long time, there appears to 14 be a disconnect between this kind of approach, which 15 you're proposing, which also has been proposed in 16 the context of human actions under fire conditions, 17 and the human reliability models that another group 18 has developed. You are placing time available, and 19 time requirement at the center of your evaluation.
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1 that there will be between the two times. That's 2 not exclusive, but you are also considering other 3 things.
4 Every time I propose to the Staff that 5 was working on this time, really has to be central 6 to their thinking, time just as another performance-7 shaping factor, varied in stress and other things.
8 And I'm bothered by that inconsistency. The 9 question is, who's right? I think you B 10 (Laughter.)
11 MEMBER APOSTOLAKIS: But I don't 12 understand that. I don't understand. And then we 13 have the experiments, I don't know if you're 14 familiar with them, of Haldon. But they're really 15 looking at time sequences. They have crews, and did 16 they do it in time, and so on. So, it's not really 17 a question to you, especially after I said that 18 you're right.
19 MR. DESAULNIERS: I'll agree.
20 (Laughter.)
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1 has been bothering me, and the conflict is primarily 2 from my colleagues, so next time we talk about human 3 reliability models, I will raise the issue again. I 4 really don't think that time should be just another 5 common shaping factor. I mean, it's B 6 MEMBER MAYNARD: I think another key 7 element in this probably is training. And, also, 8 recognition of when there is a time limit, not 9 really the right term, but when timing is important, 10 if an operator knows that, and that's part of the 11 training and everything, they will generally meet 12 that. If they're not aware that something needs to 13 be done within 30 minutes, or 20 minutes, or 14 whatever, they may, or may not make that time frame, 15 just depending on what else is going on. So, I 16 think that it needs to be clear if there is a time 17 that something needs to be accomplished. And then, 18 also, training, because -- and ongoing training. We 19 run into this in fire protection and some others of 20 shutdown outside the control room, of where when 21 programs were initially put together, people trained NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 them that they were able to do it within the time 2 frame, several years later go back and ask them to 3 do it, and they couldn't do it within that time 4 frame. So, I think that needs to be factored in, and 5 I think it's implied that it needs to specifically 6 be B 7 MR. DESAULNIERS: It specifically 8 addresses part of the long-term monitoring phase, 9 which is the last part of that. It addresses that 10 point, exactly.
11 MEMBER APOSTOLAKIS: Actually, this 12 raises the issue really of the other performance-13 shaping factors. Training is one, but, I mean, the 14 issue of stress, and so on. Are you considering 15 those at all in your evaluation?
16 MR. DESAULNIERS: Well, some of these 17 other performing-shaping factors is what would be 18 ferreted out in the end in terms of the integrated 19 system validation when operators are expected to 20 perform these activities in real time. That time 21 factor would be a stressor, of sorts, as well as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 some of the other factors.
2 MEMBER APOSTOLAKIS: So, they are part 3 of this evaluation, of your evaluation, or the 4 methodology.
5 MR. DESAULNIERS: Right. It's 6 addressed, ultimately, in part of the integrated 7 system validation.
8 MEMBER APOSTOLAKIS: Okay.
9 MR. DESAULNIERS: It's also, I believe, 10 addressed as part of when we say that the margin 11 should be based on credible operator errors, the 12 expectation is, is that the analyst will be 13 considering what some of those stressors are. And, 14 as a result, what the potential for those errors 15 are.
16 MEMBER STETKAR: Dave, I think all of 17 these discussions are really good, like talking 18 about operator responses, and uncertainty, and 19 variability, and all that kind of stuff. The ISG, 20 and everything you've spoken about so far, 21 inherently presumes that we know the time required NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 absolutely, precisely. And it doesn't seem to 2 provide much guidance, or warning about the fact 3 that there could be just as much uncertainty in our 4 ability to estimate that time required, as our 5 ability to estimate the operator response times. In 6 particular, the time available may be a function of 7 the specific scenarios that you're asking people, 8 the fidelity of the thermal hydraulic models to be 9 able to -- and I don't see any of those kind of 10 warnings in here for the time available part of the 11 big equation. The fact the methodology does have 12 some surrogate ways to account for crew variability, 13 because of the mean value estimates that you use, 14 and some -- your margin to account, essentially, for 15 uncertainties in the time required. How do you 16 answer questions when people say well, there could 17 be just as much uncertainty in the time available, 18 and I don't see those same kind of warnings in the 19 ISG.
20 MR. ARNDT: Right now, the ISG assumes 21 that you take those times as a direct pass-off from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 your BTP-19 analysis, so the conceptual concept was 2 that that would be a given in this analysis, and 3 those issues would be dealt with in ISG-2, and/or 4 BTP-19.
5 MEMBER STETKAR: Okay.
6 MR. ARNDT: We understand that those are 7 issues. We had this discussion associated with it, 8 and there is a criteria associated with how you do 9 the analysis, and what assumptions are made in your 10 thermal hydraulic models in the BTP-19 analysis.
11 It's certainly an area that needs, probably, some 12 additional looking at in that part of it, but for 13 this analysis, it's a boundary condition.
14 MEMBER STETKAR: Along that line B 15 MR. ARNDT: I know that's not a perfect 16 answer, but B 17 MEMBER STETKAR: One of the sources of 18 uncertainty might be similar, but not identical 19 scenarios, so I don't recall how you pick the 20 scenarios that this is based on, and if there's any 21 -- if you consider the range of scenarios, you can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 suffer some of this uncertainty through that kind of 2 an approach.
3 MR. ARNDT: Without going into gory 4 detail, which we really don't have time for at this 5 meeting, but the BTP-19 time required numbers are 6 based on doing a best estimate thermal hydraulic 7 analysis of the Chapter 15 analysis, and the AAOs.
8 Strictly, that's the set.
9 MEMBER STETKAR: That's the set.
10 MR. ARNDT: That's the set. It's a 11 deterministic analysis, assumed to be bounding based 12 on that.
13 MEMBER STETKAR: Okay.
14 MR. DESAULNIERS: I think, with that, 15 unless there's additional questions, I'll move on to 16 the discuss of the preliminary validation phase.
17 Now, this phase, Phase Two, in essence, 18 is intended to be an independent confirmation of the 19 analysis results. And, it's really only applicable 20 to those vendors and applicants under the Part 52 21 process, because it's a means of addressing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 providing reasonable assurance where you have 2 instances where the applicant would not have the 3 benefit of trained crews, and full-scope simulator 4 available to do a full validation, as would be 5 available at an existing reactor.
6 The expectation here is that the methods 7 used would be diverse, and as realistic as the 8 maturity of the design allows consistent with my 9 prior comments here. These analyses for the 10 preliminary validation, this is the part where it 11 would be submitted to the NRC as part of the D3 12 diversity and defense-in-depth submittal.
13 (Off the record comments.)
14 MR. DESAULNIERS: The methods, here, 15 again, these are examples of acceptable methods.
16 Applicants are not limited to these. They range 17 from basic tabletop analysis, in which the applicant 18 would be using people with expertise in the response 19 of the plant and operation of the plant in order to 20 be able to go over drawings and background material, 21 basically just as the methodology implies. Tabletop NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 of a talk-through of what actions would be required, 2 and how the plant would respond. A little bit more 3 developed concept is actually walking through this 4 activity, where you may have mockups associated with 5 it, but you can begin to go into greater detail of 6 the actual actions that would be required to be 7 taken. There are software models, again, that can 8 be used to perform these types of analyses. Man-in-9 the-loop testing, and even going to the extent that 10 you have part task simulators that you could use to 11 simulate some of the activities associated with 12 this.
13 The intent here is that you would be 14 going through these activities with a team of 15 individuals that was independent of those that 16 performed your initial analysis to identify any 17 potential pitfalls, or missing pieces in the 18 assumptions, and to come up with an independent 19 assessment of the time required, and time available 20 to perform the actions, and the margin, and confirm 21 that the initial analysis was on target. That would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 be used as the basis, again, for the D3 submittal.
2 MEMBER BROWN: Again, on something like 3 tabletop walk-throughs, where these people sit down, 4 they develop that methodology on their own. The 5 level of detail, how they do it, the documents they 6 have available, their vision of what the scenario 7 looks like. Are there any established practices 8 which define these things, which tell people how to 9 develop those practices, and utilize them, or is it 10 just going to be up to each licensee to figure out 11 how to do the tabletop, whatever? And, then come --
12 I mean, part of your ability to accept a final 13 decision that they make, to come into acceptance, 14 having some fidelity to the methodology that they 15 use based on some type of an accepted standard by 16 industry, or what have you. And this, like the 17 previous ones, just seems to be come in and tell us 18 how you did it, and we'll evaluate it ad hoc with --
19 I agree, you can't tell them how to do it, unless 20 you want to give them a standard that's an industry 21 standard, based on previous comments. But there are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 -- it sounds to me like, based on your comments, 2 there are no real standards for these within which 3 they would operate.
4 MR. DESAULNIERS: Well, there's various 5 guideline documents and best practices, but there's 6 nothing that's specifically cited in the ISG that 7 says -- points to specific practices.
8 MEMBER BROWN: Well, prototype testing 9 or simulator to you, and it's the level of detail 10 that you're simulating, the level of detail of the 11 prototype man-in-the-loop testing that you do, how 12 far down do you track that relative to information 13 he gets, the processes he has to go through, it just 14 seems a little bit B 15 MR. ARNDT: As Dave has said, there are 16 guidelines out there, 0700, 0711, are two NRC 17 guidelines. There are other ones out there. But, 18 as you'll see later on in the presentation, it 19 behooves the licensee to do this in sufficient 20 detail that they have a very high confidence that 21 when they get to final validation, that they will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 pass. So, why don't we revisit this at the end of 2 the presentation, and see if you're a little more 3 comfortable with it?
4 MEMBER MAYNARD: Well, the process, I 5 take it that it initially would be up to the 6 applicant to pick the method, and defend the method.
7 And the NRC would be reviewing it at some point to 8 determine whether those are appropriate methods for 9 the type of actions that are being required.
10 Because a walk-through may be very appropriate for 11 one thing, but -- our tabletop may be appropriate 12 for one thing, but inappropriate for another. They 13 would propose that you would review the B 14 (Off mic comment.)
15 MEMBER BROWN: Isn't that a little late?
16 By the time it gets in here, to finally say no, you 17 didn't do it the way we like it. What I've heard in 18 previous meetings, you'll have a hard time doing 19 that if you haven't defined a standard or what have 20 you within which they have to operate. If it's ad 21 hoc B NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 MR. DESAULNIERS: Well, we provided the 2 review criteria, again, associated with these 3 activities, so while it doesn't prescribe 4 methodologies, there are criteria with respect to 5 the preliminary validation that they would need to 6 make, need to meet, in addition to the analysis.
7 And as Steve commented, in the end, here they're 8 expected to use multiple methods within these so 9 that they -- again, while there may not be specific 10 standards that they're pointing to, use of multiple 11 methods should insure that they're coming to some 12 convergence on what the appropriate time is. And, 13 in the end, because the times have been developed as 14 part of the analysis and preliminary validation, 15 that time required will be one of the standards 16 they'll be held to in the actual demonstration of 17 the -- in the integrated system validation. There's 18 incentive there to insure that this is a bounding 19 analysis.
20 MEMBER BROWN: Okay. We've got to move 21 on, so I'll wait.
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1 MEMBER APOSTOLAKIS: So what would you 2 do if some licensee came to you and said as part of 3 my preliminary validation, I used a human 4 reliability model, probability that things will go 5 wrong is ten to the minus four.
6 MR. DESAULNIERS: The review criteria 7 that we've just put up on the screen here -- no, you 8 were right. Go back. We were just talking about 9 using validation of two or more methods, the 10 particular -- what I was expecting to see is that 11 there's an expectation that they're going to be 12 evaluating time required and time available. To 13 just give me a probability that there wouldn't be an 14 error in performance is not going to address the 15 minimum criteria of addressing those.
16 MEMBER APOSTOLAKIS: But that's my 17 question, why? I mean, what if they come in as --
18 you guys at the NRC could develop ATHEANA, and we 19 did a great application of ATHEANA, and the numbers 20 turned out to be very low. I mean, why -- how can 21 you turn down something that somebody used, an NRC-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 developed methodology?
2 MR. DESAULNIERS: It goes back to the 3 broader comment of we're providing, as Steve 4 mentioned in the opening remarks, what is attempting 5 to be a fast track of here's a methodology that if 6 you're within these bounds, it will facilitate Staff 7 review. It doesn't preclude an applicant from 8 coming in with an alternative approach. But, yes, 9 we would require additional review time to address 10 that alternative approach. So that flexibility is 11 available, it just wouldn't be considered part of 12 the fast track, as described here.
13 MEMBER STETKAR: Let me see if I can 14 sort that out in my head. Somebody came in with an 15 ATWS situation where they, according to this 16 methodology they demonstrated that the time required 17 is just 15 seconds less than the time available.
18 That would probably bother you a little bit. But, 19 on the other hand, if they did some sort of detailed 20 risk assessment, and could convince the Staff, 21 through whatever means, that the frequency of ATWS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 challenge -- those challenges was ten to the minus, 2 pick a small number, per year, that might be taken 3 into consideration. Is that reading too much into 4 what you're saying, or is it B 5 MR. ARNDT: Let's not mix ATWS with 6 common cause software failure diversity analysis.
7 It's a little bit different beast, but similar 8 requirements. But, the point being, if you come in 9 with a analysis that does not meet this particular 10 criteria, but you would like us to evaluate it 11 irregardless of that, that's fine.
12 MEMBER STETKAR: And that would, I think 13 B 14 MR. ARNDT: And both the criteria and 15 the methodology would be evaluated. I'll use the 16 Oconee trip example. When Oconee submitted their 17 application for their SFAS and RPS upgrade, they 18 provided certain accidents that did not bust the 19 Part 100 requirement, so they didn't have to worry 20 about the diversity requirement for that part of it.
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1 in a diverse actuation automated system, that met 2 that checkbox. And one accident scenario that did 3 neither, and would require manual operator action.
4 So that last one, we evaluated, and although the 5 methodology would have been appropriate to this, the 6 actual criteria was not. It was much shorter.
7 We went in, and we looked at that, we 8 look at what they provided, which was operational 9 history, training, and other things, that gave us 10 sufficient assurance that they could meet that in a 11 reliable fashion. Most of it was done that way, one 12 outside.
13 MEMBER CORRADINI: Just a comment. I 14 can't find the restriction to Part 52 for this 15 anywhere in the document. It's on the slide, but it 16 doesn't say that in the document.
17 MR. DESAULNIERS: This is -- this 18 portion B MEMBER CORRADINI: This 19 portion, right.
20 MR. DESAULNIERS: This portion, 21 preliminary validation. Okay. Well, I can look NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 through it. I can tell you that that's the intent.
2 I'd have to look through the document to point 3 specifically to where B 4 MEMBER CORRADINI: It's very specific -
5 - you won't find it mentioned in that context.
6 MEMBER BROWN: Are you talking about the 7 ISG itself, or Part -- ISG is Section Phase Two.
8 It's on page 16.
9 MEMBER CORRADINI: But it doesn't say 10 that it's restricted to Part 52.
11 MR. DESAULNIERS: The preliminary 12 validation part here B 13 (Simultaneous speech.)
14 MR. DESAULNIERS: The middle of the 15 document on page 16, "Note: Licensees upgrading 16 existing plants should skip this phase, and go 17 directly to Phase Three, Integrated System 18 Validation. The preliminary validation is only 19 required for those vendors or applicants who are 20 using the 10 CFR Part 52 process."
21 MEMBER APOSTOLAKIS: Let me see if I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 understand your response to Mr. Stetkar's question.
2 Phrase it a little differently. This evaluation is 3 done B 4 MEMBER STETKAR: Mine came out of ADAMS.
5 MEMBER APOSTOLAKIS: -- independently of 6 the accident sequence? In other words, we're just 7 looking at the software, and we're postulating 8 common cause failures, and so on, and we want to --
9 and if they want to take credit for manual action, 10 they have to follow this process. Is this done 11 independently of which accident sequences might be 12 needed, and how unlikely that accident sequence 13 might be? Or are you kind of neutral on that?
14 MR. ARNDT: Let me explain it again, and 15 see if I -- because I'm not exactly sure of the 16 question you're asking. The process is, you look at 17 the BTP-19 accident scenarios, which are, basically, 18 you make all your Chapter 15 accidents and you AOOs, 19 you assume a concurrent software common mode 20 failure. You then look at how that scenario plays 21 out in thermal hydraulics, and other things.
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1 MEMBER APOSTOLAKIS: So it's not really 2 embedded in the PRA, which goes beyond those 3 accidents.
4 MR. ARNDT: No. It's a deterministic 5 analysis. Because of the way the Commission policy 6 is, it permits best estimate analysis, but it's not 7 a PRA-based beyond-design-basis type analysis.
8 MEMBER APOSTOLAKIS: Thank you.
9 MR. DESAULNIERS: Okay? Let's go on to 10 the next slide here. I think I've already largely 11 covered this slide here, the results for the 12 preliminary validation documented in the D3 analysis 13 for NRC review. Ultimately, they should support 14 high confidence that the time required for manual 15 operator action will satisfy the success criteria 16 for the integrated system validation, which is the 17 next phase of the analysis.
18 MEMBER APOSTOLAKIS: So this is like 19 beyond a reasonable doubt. It remains undefined, 20 but sort of wait and see, that type, high 21 confidence. I remember in an earlier document NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 within fire protection, they demanded that there was 2 a numerical guidance as to how much shorter the time 3 required should be, time available. Are you giving 4 anything like that here, or is it just judgment?
5 MR. DESAULNIERS: No, it's based on the 6 calculation of a margin, which the guidance in this 7 document, base that margin based on the time 8 necessary to recover from a credible operator error.
9 The error with the longest recovery.
10 MEMBER APOSTOLAKIS: Are you saying that 11 the required language should be based on the 12 available time by at least 10 minutes or something?
13 MR. DESAULNIERS: The time required to 14 recover from -- so, analyze your action sequence, 15 what errors might occur, identify that okay, there 16 may be a mismanipulation of a switch, that the time 17 to recover from that error, how much time is it? If 18 that is your bounding error, that would be the basis 19 for your margin.
20 MEMBER BROWN: Effectively, what it 21 says, there's no addressing how short is too short.
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1 I phrased it slightly different when I looked at 2 it, so if somebody came in and said we only need 3 eight minutes, we require five -- no, we require 4 eight, but we can react in five, that would be --
5 theoretically, for this, that would be okay. If we 6 require five, but we can do it in two, because our 7 analysis -- that could be okay. There is no how 8 short is too short.
9 MEMBER RAY: But George is asking about 10 the use of the words "high confidence." What do you 11 base high confidence on? The answer seems to be 12 well, if it's capable of recovering from an 13 operator error in the time required, then I have 14 high confidence it will be done. That sounds like 15 an answer to me.
16 MR. ARNDT: And it can be demonstrated 17 in the validation.
18 MEMBER BROWN: That's our one -- I can 19 show you that I can do it. Now that I have high 20 confidence that I will do it, leaves me -- I don't 21 know.
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1 MR. DESAULNIERS: Well, they need to 2 demonstrate it in multiple scenarios with multiple 3 crews.
4 MEMBER BROWN: That's what I'm listening 5 for, is how do I arrive at this high confidence.
6 George is saying one way, is they have some 7 arbitrary, admittedly, margin.
8 MEMBER APOSTOLAKIS: Right.
9 VICE CHAIR ABDEL-KHALIK: I understand 10 that this has to be done for the Chapter 15 accident 11 scenarios, and for the anticipated operational 12 occurrences.
13 MR. DESAULNIERS: Correct.
14 VICE CHAIR ABDEL-KHALIK: But doesn't 15 this depend on when this common mode failure occur 16 during a specific scenario? I mean, put yourself in 17 the position of the applicant, who's trying to go 18 through this process. There's just an infinite 19 number of scenarios for a specific accident 20 scenario, depending on when you assume this failure 21 to occur.
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1 MR. DESAULNIERS: That's correct.
2 VICE CHAIR ABDEL-KHALIK: Have you shown 3 this to be at all workable?
4 MR. ARNDT: What we're trying to do is 5 define a set of scenarios that are, in our opinion, 6 will be provide a reasonable assurance that all of 7 this -- billions of possible scenarios would be 8 reasonably recoverable based on these actions.
9 Because of the way the BTP-19's structure is set up, 10 we're looking at those scenarios that would possibly 11 bust the Part 100 acceptance criteria. Admittedly, 12 there is lots of other ways of doing this, but this 13 is, what we hope, is a reasonable set of scenarios 14 that the operator can use to demonstrate that their 15 actions can be accomplished in a reasonable time 16 period.
17 VICE CHAIR ABDEL-KHALIK: My concern is 18 that the scope of the evaluations that the applicant 19 would have to go through, even for a single accident 20 scenario, you have to assume that the common cause 21 failure would occur anytime during that accident, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 and the operator actions required to recover at that 2 time will depend on when that common cause failure 3 occurs. And, therefore, this process is just 4 incredibly open-ended. Demanding, I would say, the 5 least, in terms of what the operator B 6 MEMBER APOSTOLAKIS: What you're saying, 7 Said, is the starting point of the time required and 8 the time available may not be the same.
9 VICE CHAIR ABDEL-KHALIK: Right.
10 MEMBER APOSTOLAKIS: That's what you're 11 saying.
12 VICE CHAIR ABDEL-KHALIK: Well, not 13 just, but the progression of the scenario can B 14 (Simultaneous speech.)
15 VICE CHAIR ABDEL-KHALIK: -- when this 16 common cause failure occurs. I think you're asking 17 something that would be very difficult, if not 18 impossible, to do.
19 MR. ARNDT: It will certainly be 20 challenging. However, you've got to remember, this 21 is only one of several different options that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 licensee has in meeting the diversity requirements.
2 Alternatively, they could install an automated 3 diverse actuation, or they could have the actual 4 system originally designed to be sufficiently 5 diverse, not to be subject to the software common 6 cause failure. So, there are a number of different 7 options B 8 MEMBER RAY: But you said you met with 9 industry, and worked with them on this. What would 10 be their response to Said's comment, which is, 11 basically, that you have to assume the failure could 12 occur at any time. That's not their assumption, is 13 it, or do you assume the failure initiates the B 14 MR. DESAULNIERS: Well, we can say that 15 this phase of the methodology is largely consistent 16 with what industry had proposed in their's, so I 17 don't believe that they had identified that as an 18 insurmountable problem.
19 MEMBER RAY: That's my point, exactly.
20 They're assuming, I would think, that the common 21 mode failure occurs initially, or is pre-existing, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 or something of that kind, rather than that it 2 occurs on demand. That's my -- what I would bet.
3 VICE CHAIR ABDEL-KHALIK: But is that 4 logical?
5 MEMBER RAY: I don't know. I'm just 6 asking them if they talked about this. I don't know 7 the answer to that question.
8 MR. KEMPER: This is Bill Kemper, again.
9 If I can provide some insights on this. The way we 10 have evaluated this phase as, we assume, and 11 licensees do their analysis in this method, that the 12 reactor trip system, or the engineered safety 13 feature system fails, concurrent with the accident.
14 In other words, once you have a large break LOCA, 15 it is assuming that the reactor trip fails. It does 16 not perform its safety function at that point, and 17 then the accident is evaluated from there, from a 18 thermal hydraulic perspective, if you will. So, 19 we've always considered that to be an enveloping 20 scenario, if you will, because if the system 21 partially actuates, then you still have some safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 function, if you will. Like, say one train of SFAS 2 actuates, another train doesn't, that's not 3 perceived as onerous as both trains not operating.
4 So, that's been historically the way that's been 5 treated.
6 MEMBER APOSTOLAKIS: So, what you are 7 saying, Bill, is that the assumptions under which 8 this ISG has been developed are bounded.
9 MR. KEMPER: That's correct.
10 MEMBER RAY: Said's hypothesis would 11 argue with that, I think.
12 VICE CHAIR ABDEL-KHALIK: I guess I will 13 have to think about specific scenarios in which this 14 might not be the case.
15 MR. KEMPER: Well, the scope is limited 16 primarily to the reactor trip system and engineer 17 safety features.
18 (Off mic comments.)
19 MR. KEMPER: Okay. Yes, because, for 20 example, during a LOCA scenario, once SFAS has 21 initiated, of course, the safety function is being NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 enacted now. Obviously, there are other actions 2 that have to be carried out pursuant to the EOPS, 3 but the primarily safety system has performed its 4 safety function.
5 MR. ARNDT: In terms of experience in 6 what scenarios give us the most problem meeting the 7 acceptance criteria, most of those are initial 8 actuation-type issues. SFAS doesn't work, you don't 9 have low pressure injection, you have fuel problems, 10 you bust your Part 100 requirement. So, at least 11 the ones we've looked at so far would argue that you 12 probably wouldn't have too many problems with five 13 minutes down, ten minutes down, things like that.
14 Without having looked at every possible scenario, I 15 can't give you a statement B 16 VICE CHAIR ABDEL-KHALIK: Same here.
17 MR. ARNDT: The things that we've looked 18 at so far, the major issues are those immediate 19 action-type issues.
20 VICE CHAIR ABDEL-KHALIK: Thank you.
21 MR. JUNG: This is Ian Jung. Just to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 provide more perspective on this, none of the plants 2 that have come in have not had the -- follow this 3 particular approach, that to the extent that we have 4 to worry about this time available, and all this 5 elements. In some designs, like Wolf Creek case, 6 for example, we told them we are making a decision 7 for that from NR perspective. They don't even need 8 to get into even diverse actuation scenarios, so we 9 have to consider some scenarios. Some of the 10 scenarios end up being according to the D3 analysis, 11 it could be a very simple one manual action that 12 punching reactor trip system. It could be as simple 13 as that, so we need to think about that, and whether 14 we need automatic actuation for that, versus a 15 simple manual action that's going to do it in a few 16 minutes. Maybe all this analysis might be over-17 killing it.
18 MEMBER RAY: Just take the swamp over 19 water storage tank in the containment sump, for 20 example, that's a pretty critical time critical 21 thing. Let's assume a failure -- I'm taking too NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 much time here. But I think that that's the kind of 2 thing we're talking about, not if a plant tripped or 3 it didn't trip. And that's the end of the 4 discussion.
5 MEMBER BROWN: Can we move on?
6 MR. DESAULNIERS: I think we might be 7 running tight on time.
8 MEMBER BROWN: Poor management of time 9 here.
10 MR. DESAULNIERS: Okay. With regard to 11 integrated system validation, this is the point at 12 which the objective is to confirm that operators are 13 able to perform the credited actions in real time 14 using the as-built design. The method is to use a 15 plant reference simulator capable of realistically 16 representing the abnormal operational occurrences in 17 postulated accidents concurrent with the common 18 cause failure. The intent here is to validate time 19 required using both nominal and tech spec minimum 20 crews to make sure that the actions can be 21 implemented in both those configurations. And, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 again, this is consistent with the overall human 2 factors engineering process, can be implemented 3 consistent with NUREG 0711.
4 The review criteria associated with the 5 integrated system validation address these following 6 areas; integration with the human factors 7 engineering program, that should be done. The 8 criteria for the simulator, the personnel used to 9 run those scenarios, the operational conditions 10 represented in those scenarios, as well as the 11 performance times. And for, I guess, purposes of 12 example, and perhaps the most critical area of 13 criteria, I'll speak about the performance time 14 criteria, just in the next slide 15 These two criteria, again, bring us back 16 to some of the discussions earlier in the 17 presentation that tie us back to looking at what was 18 coming out of the analysis phase, specifically, the 19 first criterion here. Multiple crews will be 20 running for each abnormal operational occurrence, or 21 postulated accident. The mean performance time of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the crew should be less than, or equal to the 2 estimated time required derived from the analysis 3 phase. So, this is where I was saying it behooved 4 the applicant to insure that they provided a time at 5 the analysis phase that was conservative to 6 incorporate the times that they're actually going to 7 see under the -- for the performance of the crew in 8 the simulator, is if they under-estimate at the 9 analysis phase, they will not meet the first 10 criterion. And it brings that -- and, as a result, 11 it brings in the analysis phase -- the analysis into 12 question, because it would show somewhere that your 13 analysis was not incorporating, perhaps, appropriate 14 assumptions with regard to what was required to 15 implement those operator actions. I'm sorry. You 16 had a question?
17 MEMBER APOSTOLAKIS: I'm trying to 18 digest all this. So, the first one refers only to 19 the time required. Right?
20 MR. DESAULNIERS: Yes.
21 MEMBER APOSTOLAKIS: Second one to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 operator.
2 MEMBER RAY: You justify the mean time 3 by what? Mean time less than required.
4 MR. DESAULNIERS: That case, we're 5 looking, again, at verifying that the analysis was a 6 valid analysis, and that it provided an estimate 7 that was going to bound what those operators, on 8 average, were going to be able to do. Ultimately B 9 MEMBER RAY: Bound and on average, those 10 words just don't go together, to me.
11 MR. DESAULNIERS: Because the next 12 criterion deals with the actual performance of each 13 individual crew relative to time available, 14 including margin. So, that addresses the other 15 piece. So, both of those criteria have to be met.
16 MEMBER CORRADINI: So, I've been 17 listening. Can I see the first bullet, again, since 18 you started with the first bullet?
19 MR. DESAULNIERS: Yes.
20 MEMBER CORRADINI: So, you're saying if 21 there's some sort of analysis of how the crews NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 behave, is there a mean performance time compared to 2 a pre-done analysis that says we need to do it by X?
3 If we need to do the action in an hour, and the 4 mean crew performance shows by whatever mechanism is 5 less than an hour, then you set aside bullet one.
6 MR. DESAULNIERS: Yes.
7 MR. ARNDT: Not quite. You didn't say 8 it quite right.
9 MEMBER CORRADINI: Well B 10 MR. ARNDT: It's, if you do an analysis 11 and it says you can do the operation in an hour, and 12 then you later on say we do it, and we only take an 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> or less, it's okay. This is the analyzed 14 amount of time it takes to perform the action.
15 MEMBER CORRADINI: Oh, excuse me.
16 MEMBER MAYNARD: The term "time 17 required" is a little misleading.
18 MR. ARNDT: Yes.
19 MEMBER MAYNARD: You have to read it in 20 a different context.
21 MR. ARNDT: You have to read it in a B NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 MEMBER CORRADINI: Oh, so this is the 2 time to perform the action, not the time available 3 before the action must be performed.
4 MR. ARNDT: Right.
5 MEMBER CORRADINI: Okay. I'm sorry.
6 Excuse me.
7 MR. ARNDT: I know. I do the same 8 thing.
9 MR. DESAULNIERS: Yes. The time 10 required to perform the action based on the 11 analysis.
12 MEMBER APOSTOLAKIS: So, this is based 13 on some sort of crew performance. Right?
14 MR. DESAULNIERS: Exactly.
15 MEMBER APOSTOLAKIS: Why are you 16 allowing the mean in the first bullet, but in the 17 second you want every crew to pass the test?
18 MEMBER CORRADINI: Because it's a 19 different thing.
20 MR. DESAULNIERS: It's a different 21 criteria.
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1 MEMBER APOSTOLAKIS: It is different.
2 MR. DESAULNIERS: It is.
3 MEMBER APOSTOLAKIS: By why is the mean 4 more appropriate in the first, and not the second?
5 MR. ARNDT: The mean is appropriate 6 because it's -- you're going to have an analysis.
7 The analysis is going to say, it's going to take an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, or 30 minutes, or whatever. The first one 9 you're simply saying, our analysis was acceptable, 10 and we're validating our analysis by saying on 11 average, the crews are meeting where we said we were 12 going to. So, that's validating the analysis. The 13 second one is validating B 14 MEMBER ARMIJO: I don't understand that.
15 The analysis should be independent of the crew 16 performance.
17 MEMBER STETKAR: No. This is the 18 analysis of the crew performance. You've got --
19 there's two analyses going on here.
20 (Simultaneous speech.)
21 MR. ARNDT: Sorry. Keep going.
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1 MR. DESAULNIERS: It's also important to 2 take a look at this, because when you get to the --
3 looking at performance time, there you are looking, 4 presumably, at just correct operator performance, 5 and you may not have the benefit of operator error.
6 So, with respect to that margin, you're not -- you 7 don't have a means to validate that your margin is 8 right, necessarily. And by going back and 9 validating that at least your analysis of the time 10 required, your margin is largely based on that.
11 It'll also give you confirmation that you have an 12 appropriate margin.
13 MEMBER CORRADINI: So, can I try one 14 more time now with the two bullets, just for 15 numbers. So, what you're saying, if the required 16 time to perform the action is 30 minutes, the mean 17 time of the crew performance has got to be 30 18 minutes or less. If the time available is an hour, 19 then you're going to look at the crew performance in 20 some methodology to determine not just the mean, but 21 also the wings in the mean to make sure that that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 falls within the hour.
2 MR. DESAULNIERS: Right.
3 MEMBER CORRADINI: Got it.
4 MR. DESAULNIERS: Yes.
5 MEMBER CORRADINI: Thank you.
6 MR. ARNDT: For each crew.
7 MEMBER CORRADINI: Got it.
8 MEMBER BROWN: Estimated time required 9 for what? The first bullet.
10 MR. DESAULNIERS: The time required to 11 perform the mitigation action.
12 (Simultaneous speech.)
13 MR. DESAULNIERS: Not time required to 14 mitigate the accident. Time required to perform the 15 mitigation action, but not, necessarily, to mitigate 16 the accident.
17 MEMBER APOSTOLAKIS: That's time 18 available.
19 MEMBER BROWN: Okay. Let's go on.
20 MR. DESAULNIERS: Okay.
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1 later.
2 MR. DESAULNIERS: The last phase is 3 long-term monitoring, and this addresses, I 4 believe, some of the comments or questions that were 5 raised earlier with regard to training, and insuring 6 that if, I guess, the experience -- someone noted 7 that if you train operators that they need to do it 8 within a specific time available, that they 9 generally will meet that. Part of this is insuring 10 that that message remains clear throughout the life 11 of the plant, or for as long as those actions are 12 credited, and that programs should be to insure that 13 there are no inadvertent changes to the design 14 configuration of a plant, such that it would change 15 the time available to perform the actions. So, in 16 essence, through training, ongoing training process, 17 there would be a continued look at the ability of 18 operators to perform these actions within the 19 credited period of time. And if that were failing 20 to meet those times, to feed back into corrective 21 action process to insure that the training was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 modified, or whatever was necessary, to insure that 2 they can continue to perform those actions within 3 the credited time.
4 I think I largely addressed the points 5 in this slide previously, so long-term, where do we 6 go from here? That describes the process. The 7 Staff's intent is, ultimately, to develop a Branch 8 Technical Position that would incorporate the 9 guidance that we have in this ISG, and to revise the 10 Standard Review Plan in order to reference that 11 Branch Technical Position.
12 Longer term in the future, we would hope 13 to support future development of 58.8 as a 14 methodology that addresses, again, some of the 15 questions that I heard today, to provide a 16 standardized methodology appropriate to the 17 application in digital control rooms.
18 MR. ARNDT: We'll go on right now, 19 because we're a little pressed on time, with ISG-6.
20 This is a review B 21 MEMBER APOSTOLAKIS: Is this the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 estimated time?
2 MEMBER BROWN: The time available.
3 (Laughter.)
4 MR. ARNDT: Our margin has been eaten 5 into quite a bit. ISG-6 is in the process of 6 development, and Ed will go through what it is, 7 where it is, and where we are going in the future.
8 MR. MILLER: Okay. Great. Good 9 afternoon. As Steve said, my name is Ed Miller.
10 I'm a Project Manager in Operating Reactor Licensing 11 in NRR. I've been in this position for about five 12 years. Prior to that, I spent about two years in 13 instrumentation controls, as a member of TWG-6, 14 providing licensing perspective for ISG-6. What I'd 15 like to do real quick, though, is go over B 16 (Off the record comments.)
17 MR. MILLER: Okay. Just real quick, who 18 I was. Then I'd like to go into the purpose of ISG-19 6, initially. The first two purposes on there 20 really get to reduction of regulatory uncertainty.
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1 process that I'll discuss in more detail a bit 2 later. And, clearly, defining our expectations for 3 documentation. We'd like to do this both by laying 4 out clearly the criteria we expect to evaluate these 5 submittals by, and giving just a list of documents, 6 and documentation that we would expect to be 7 submitted, both with the application later on, and 8 kept available for audit throughout the process.
9 Lastly, that we also expect this ISG to 10 serve as a knowledge management tool. This will 11 provide a learning tool for new reviewers as they 12 come in, and as is becoming a very real situation 13 right now, losing our senior review staff to 14 retirement. And it will also promote consistency 15 throughout the review process by serving as that 16 guide. We certainly intend to incorporate lessons 17 learned from recent ISG amendment reviews, such as 18 Wolf Creek and Oconee. Next slide, please.
19 This is a very basic flow chart. It 20 gives an overview of the process. And recognizing 21 that digital instrumentation and controls are a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 significant licensee resource commitment, we 2 developed a phased approach to acknowledge that not 3 all the information needed to make the decision is 4 initially available when they submit a license 5 amendment request. And, additionally, we structured 6 the phases of this to parallel the life cycle of the 7 digital I&C upgrade for a site.
8 Starting off with Phase Zero, which 9 actually begins before they've even submitted a 10 license amendment request. This is when they're 11 engaging the NRC Staff in a discussion of what they 12 plan to do for digital I&C upgrade, if it happens.
13 And, we actually envision this being one of the most 14 important aspects of the licensing process, even 15 though it occurs before the submittal of an 16 amendment request. And this is because we're trying 17 to propose a creative use of our public meetings to 18 discuss what they're intending to do. In these 19 meetings, we're going to over things, such as 20 defense-in-depth and diversity, any other unique or 21 potentially complex topics associated with what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 they're planning on submitting.
2 In addition to that, we're planning on 3 using the meeting summaries that we issue after any 4 public meeting today to document initial Staff 5 assessments of what the licensee has presented to 6 us. Included in those assessment would be 7 identification of what we, as the NRC Staff, really 8 find to be the critical factors in what they 9 presented to us. This will serve a number of uses 10 as we get into later phases by feeding into the 11 acceptance review that we would perform. Again, 12 we've already identified what's important to us in 13 the submittal ahead of time, identifying with the 14 licensee if you change something, do you think it's 15 going to be as big of an impact? Granted, it's not 16 set in stone. If they change something that we 17 didn't identify before, it could come up. But, like 18 I said, it reduces the regulatory uncertainty that 19 changing something that we didn't identify as a 20 critical factor before, is less likely to.
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1 license amendment application. We'll put that 2 through the acceptance review, which, as I said 3 before, will be benefitted by the meeting summaries 4 that have already been conducted, or issued. Moving 5 into the RAI process. This is another point where 6 we're going to try to make some creative use of our 7 existing processes.
8 Typically, right now we ask questions 9 when we need information, and leave it at that. We 10 get responses, and, basically, silence is no more 11 information needed. We'd like to start providing 12 feedback in the RAI process of areas of review that 13 we no longer have any questions on. This provides 14 more of a positive feedback to the licensee that we 15 have come to an understanding on that point. And, 16 again, this doesn't mean that we're done, it's 17 approved, no more questions can come up. But it 18 does provide a reduction of regulatory uncertainty 19 by identifying those areas that we feel are being 20 addressed adequately at this point.
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1 information that would be on a schedule established 2 with the original submittal of the application comes 3 in. There really is no absolute defining line 4 between Phase One and Phase Two. We would certainly 5 still continue to ask RAI questions on information 6 submitted during Phase One, as we go into Phase Two.
7 But, Phase Two is where we would expect to conduct 8 the regulatory audits. Again, we've developed a new 9 Office within NRR to govern those activities.
10 At the conclusion of all that, we would 11 render a regulatory decision. In the case of 12 approving the digital I&C upgrade, we transition 13 into Phase Three. And this really breaks with the 14 licensing, or breaks the end of the licensing 15 process, when we issue that SE. Obviously, we're 16 doing no more licensing reviews of it. It 17 transitions into an inspection process. So, at this 18 point, it goes out, they install the system in the 19 plant, perform site acceptance testing, and all 20 these reviews of those will be conducted by the 21 region under their Inspection Procedure 52003, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 which, again, was updated recently to address these 2 issues. Go to the next slide, please.
3 For the format of ISG-6, we modeled it 4 heavily after RS001, which is the review standard 5 for extended power uprates. Basically, we had a 6 good model that had been proven to be successful 7 there, so we figured, if it's not broke, don't fix 8 it.
9 MEMBER BROWN: Ed, I'm going to 10 interject one point here, that for the table, the 11 flow chart, I just checked the rest of the sheets 12 and didn't really see this point. Once, if I 13 remember from reading through the ISG that you 14 presented, you will effectively step out of this 15 process at the end of the Phase Two process. That 16 means, it goes -- it's now the region. It's now the 17 licensee, applicant, whoever, they install stuff, 18 and everything else happens. NRC, the Staff, nobody 19 looks at this anymore.
20 MR. ARNDT: Headquarters.
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1 sorry. I apologize. I didn't mean to -- I was not 2 excluding the region folks, staff from doing that.
3 That's just a point that was not articulated in the 4 rest of the slide.
5 MR. ARNDT: Headquarters steps out after 6 the SE is issued. Right?
7 MEMBER BROWN: Correct. Yes.
8 MR. ARNDT: Okay.
9 MEMBER ARMIJO: Just before -- what do 10 you actually issue? Is this -- do they get an 11 amendment to the existing plant license?
12 MR. ARNDT: Correct.
13 MEMBER ARMIJO: That's what they get.
14 Okay.
15 MR. MILLER: Yes. The headquarters 16 staff is still available as a consult to the region 17 when they do their inspection. And that has come up 18 before.
19 MEMBER MAYNARD: Typically, what I've 20 seen, they may be out of it from the design review 21 and acceptance, but when it comes to implementation, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 to testing and stuff, typically, somebody from 2 headquarters has been aware of the inspection, and 3 communicated, been a part of it, sometimes.
4 MR. MILLER: Right. So, again, you 5 could see the format here. In the first part of the 6 ISG, we describe that process in significant detail, 7 going over the very smaller points of what we want 8 to make sure it's accomplished. Again, providing an 9 example, meeting summary to be issued that 10 delineates the summary be included, identifying the 11 critical points, things like that.
12 The other part of this is going to 13 contain the review areas. And what we did was we 14 broke down the overall digital I&C upgrade review 15 into a number of conceptual review areas that allow 16 somebody to get their mind around an individual 17 review area first, and then put all those individual 18 review areas together into a digital I&C review.
19 MEMBER APOSTOLAKIS: Is there anything 20 unique to I&C here?
21 MR. ARNDT: In the format slide?
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1 MEMBER APOSTOLAKIS: It seems to me, 2 this is a standard process that one would follow.
3 MR. ARNDT: We actually borrowed from 4 the extended power uprate. The concept was we 5 wanted to have a more formalized, more structured 6 approach. And what we looked at was other 7 complicated reviews.
8 MEMBER APOSTOLAKIS: But, I mean, this 9 is not something we're going to review. This is 10 standard. Unless there is something unique to I&C.
11 MR. MILLER: The review areas, which we 12 get into now. But that's what's the B 13 MEMBER BROWN: Yes. The ISG identifies, 14 8, 9, 10, whatever the number is, specific review 15 areas and provides a definition of what they're 16 looking for within those review areas.
17 MEMBER APOSTOLAKIS: Okay. That is of 18 interest, the overall approach.
19 MR. MILLER: Okay. Moving on real 20 quick. I'll go through this very quickly. This is 21 just the tiers of review. It's another way to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 reduce regulatory uncertainty. We also came up with 2 the concept of defining different tiers for where an 3 application would fall. Tier One is where you need 4 a topical report already pre-approved with no 5 deviations. This review is very confirmatory, 6 making sure that you fit the envelope within which 7 we approved the topical report. Tier Two is where 8 you use a previously approved topical report, no 9 deviations. I'm sorry, with deviations, so in that 10 case, you identify some points that you need to 11 change from the approval had previously. The parts 12 of it that you do within the previous envelope would 13 be confirmatory, the new parts would require more 14 significant review. Finally, Tier Three is where 15 there's a totally new system, and that requires, 16 basically, a thorough review of all the technical 17 areas that we would do if it were coming in under a 18 topical report. Again, that's to reduce regulatory 19 uncertainty. What tier it falls under will be 20 discussed during the Phase Zero meetings, that we 21 have broad feedback, again, in the meeting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 summaries. Move on from that one.
2 So, this is really the part of it that's 3 very, very specific to digital I&C. These are our 4 working list of review areas. And what we're trying 5 to do, as I mentioned before, is break it down into 6 some conceptual areas to help our new reviewers get 7 their minds around what this is, and really define 8 kind of the points of the process that we get into 9 here.
10 As you can see, we start off with 11 defense-in-depth and diversity, move into the 12 hardware architecture, how is the hardware built, 13 the hardware design process. Is the design process 14 such that it produces robust product? Looks at the 15 communications on that hardware both within the 16 system, with other class warning systems, and with 17 non-safety systems. Then we look at the software 18 that runs on the hardware, look at the design 19 process that was used to develop the software. And 20 then system qualifications, bins it up into okay, 21 here's the whole system. What are my acceptance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 criteria for running the system as a whole?
2 System, hardware, software, and 3 methodology modifications really is only applicable 4 to a Tier Two review. That's where they've got a 5 previously approved topical report with deviations.
6 And the idea here is we're going to delineate what 7 really consider a deviation. We'll talk about how 8 to address those. But, obviously, that wouldn't be 9 a problem for a Tier One and for a Tier Three. We'd 10 be reviewing everything, so there really wouldn't be 11 any deviations.
12 Technical specifications, as with any 13 license amendment, we certainly review the technical 14 specifications to make sure that the LCOs and 15 remaining SRs define the minimum level of 16 functionality for the system. One of the things 17 we're trying to include here, and we've been working 18 with stakeholders on this one, is trying to figure 19 out some of the things that might be specific to a 20 digital I&C upgrade that we could prepare reviewers 21 to see as technical specification changes. Are we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 going to be getting rid of checks, because that 2 would be something that's very important to a 3 reviewer from a historical aspect.
4 MEMBER BROWN: Can you say that again?
5 I didn't read that anywhere. You want to get rid of 6 channel checks.
7 MR. MILLER: Just as a possible benefit, 8 yes. The system has a self-checking feature.
9 MEMBER BROWN: Okay. You didn't read it 10 in context.
11 MR. MILLER: I'm sorry. So, kind of a 12 question we asked them was, what would you be 13 anticipating you would like as a technical 14 specification change in some of these to help 15 prepare our reviewers to B 16 MEMBER BROWN: But if you're going to do 17 that, I'm very familiar with it, because I actually 18 did it. But, you have to have -- you just can't do 19 that willy-nilly. You have to have a way how you 20 check the checker.
21 MR. MILLER: Right.
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1 MEMBER BROWN: So there's some process 2 you have to incorporate in running that. And you 3 also have to have some process that utilizes those 4 self-checking type things, such that they provide 5 you information as to what they did and didn't. If 6 you don't have that, then you don't have the ability 7 to know where you are at any one time. So, I just 8 throw that out as a -- and I'm sorry I didn't 9 understand the context. Why don't you tell me what 10 you're thinking of that.
11 MR. MILLER: But, I think your point, 12 though -- I mean, there's a big benefit, that if we 13 bring that up as -- if a licensee proposes to delete 14 a channel check, here's some of the things you 15 really need to be on the watch for, too. I mean, we 16 have a chance to introduce some consistency in how 17 we look at those things, and make sure that we catch 18 everything, too.
19 MEMBER BROWN: Yes. Just bear in mind, 20 the self-checking doesn't necessarily check all 21 aspects from input to output. So, it's a subset of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 things you may or may not be able to do. Okay. Go 2 ahead. I'm sorry.
3 MEMBER ARMIJO: I know at the 4 Subcommittee meeting we talked about the guidance 5 that's being prepared for how to deal with DAC 6 items. An awful lot of the stuff on this list for 7 the new plants is DAC. Can you say anything about 8 how these requirements and how you would normally 9 review them are going to work under DAC?
10 MR. WERMEIL: Do you want me to answer 11 that? This is Jared Wermeil from the Staff. The 12 guidance that we're writing in ISG-6 is not intended 13 to be used in accordance with the DAC process under 14 a Part 52 application.
15 MR. ARMIJO: Okay. I thought this did 16 apply to Part 52.
17 MR. WERMEIL: It does not. This is 18 strictly for operating plant amendments under 50.90.
19 MR. ARMIJO: I misunderstood.
20 MR. WERMEIL: Now, the elements in that 21 working list of review areas are typical of any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 digital system, and they would fit into a DAC 2 process. I believe that was your point. That is 3 absolutely true. However, this document is going to 4 describe for a licensee how they would structure 5 their amendment to address these review areas. It 6 doesn't help a COL applicant, because the timing of 7 the information that's asked for here is very 8 different when you're providing a COL application 9 that's referencing a standard design, as opposed to 10 amending your operating license. And this is not 11 going to help them in that regard. The types of 12 documentation, the kind of information is the same, 13 but it will be coming at very different times, and 14 it may look very different. And this document won't 15 help in that particular aspect.
16 I know that NRO is developing a DAC 17 implementation guidance document. And, eventually, 18 I would expect, because both offices have been 19 talking about this, that there will be some 20 similarities. But, at this particular moment, the 21 structure of this document is not going to assist in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the DAC implementation. It's just for operating 2 plant amendments.
3 MEMBER BROWN: I still want to emphasize 4 one point. If you look at the draft review areas 5 which they're talking about in here, and based on 6 the ESBWR presentations, and the USABWR 7 presentations at this point, these review areas not 8 under this process, but are applicable relative to 9 types of information that people really ought to be 10 getting. It's a matter of how we do it, and how we 11 fit it into this DAC ITAAC process, which would 12 improve that process immensely, in my own personal 13 opinion.
14 MR. WERMEIL: One point I would also 15 make, with the implementation of DAC, there is even 16 a question of who would be responsible for the 17 review of those aspects, because DAC is a subset of 18 ITAAC. And ITAAC is, basically, an inspection 19 function. So it's hard to say at this point, and 20 that's something that is being worked out.
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1 you have now gone into this realm, I really do 2 think, though, this isn't directly applicable, so 3 the timing is different. And the only one part of 4 the thing that you had said at the end that I just 5 want to make sure I understood it properly, was when 6 we asked the question about who would be looking at 7 DACs, we were told the regional office, or Region 8 II, as well as headquarters together. Right?
9 MR. JUNG: Yes. Ian Jung with NRO.
10 Current decision for NRO is the Division of 11 Engineering in headquarters will take the lead on 12 review of the DAC items. And, obviously, we need to 13 coordinate with the program office for ITAAC 14 construction inspection program.
15 MEMBER CORRADINI: Thank you.
16 MEMBER BROWN: I think you are just 17 about done, aren't you?
18 MR. MILLER: Pretty much.
19 MEMBER BROWN: I wanted to introduce one 20 other point, in that when I went through the list of 21 this stuff, it effectively addresses what I would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 call standard -- you get the software design process 2 and stuff in, but it doesn't really -- the software 3 design based systems bring a different perspective 4 to the development of determinacy and independence 5 in terms of how you assess those, and how are they 6 meeting them relative to the rest of the general 7 criteria for a plant. And this list does not really 8 cover those very explicitly, so my thought process 9 is, you need to expand this list by those two items 10 to cover hey, what should we be getting to make sure 11 we have a good assurance of the determinacy and the 12 independence, and how, not telling them how, but how 13 the licensee or the applicant decides they're going 14 to meet those requirements. So, that's my thought 15 process on the thing.
16 MR. KEMPER: Yes. Bill Kemper, again.
17 If you could just go back a slide, and show us the 18 list. Software design process, software 19 architecture, those two items there are intended to 20 address the entire software life cycle development 21 process.
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1 MEMBER BROWN: I understand, but it 2 still doesn't cover explicitly the -- I mean, you 3 bring software into the picture, and you start 4 communicating between channels, there's nuance in 5 how you get determinacy and independence. It's not 6 straightforward, because of how you do it. So, you 7 need to know how the guy is going to do it. You 8 don't have to tell him how, but you need to know 9 how, but you need to have some way of addressing it 10 so that he presents the information in a manner in 11 which you can understand how he's doing it. That's 12 all. That's trying to -- I don't care how you -- if 13 you want to expand the review area, the software, 14 the other thing to do that, because it is 15 intertwined with the hardware part of it, as well.
16 They are not separable.
17 MR. KEMPER: Right. And the 18 communications, the tick mark up there under 19 communications, really that's a broad overarching 20 area B 21 MEMBER BROWN: It's just not clear when NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 you read the document. One other point. You all 2 significantly modified this from the first round.
3 It went from this table, which was somewhat 4 incomprehensible. Was that driven by a previous 5 Committee meeting, or was that your choice?
6 MR. ARNDT: That was driven by a number 7 of inputs.
8 MR. KEMPER: It's still there. The 9 table will not disappear, but it will take on a 10 different form, if you will. So the list of 11 documents B 12 MEMBER BROWN: That will be back in the 13 back as an Appendix.
14 MR. KEMPER: Yes, that's correct. The 15 list of documents that licensees need to submit is 16 extremely important to provide regulatory clarity on 17 what's expected, and when they need to submit that.
18 MEMBER BROWN: Excuse me. Thank you.
19 Are there any other questions? Number one, I wanted 20 to thank everybody for a very interesting session, 21 as I thought it would be. And I -- while we kind of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 ran over five minutes here, I thought the discussion 2 on ISG-5 was far more critical to the overall 3 process here today, than the ISG-6. So, Ed, I 4 apologize for shortchanging you a little bit, but I 5 think a lot of good stuff came out, so I did want to 6 thank you all for the time, and a very good 7 presentation, and a good articulation of the thought 8 process. Back to the chairman.
9 MEMBER SHACK: Okay, gentlemen. We're 10 ready to adjourn for lunch. We will resume at 1:05.
11 (Whereupon, the proceedings went off the 12 record at 12:06:42 p.m., and went back on the record 13 at 1:04:19 p.m.)
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1 2
3 4
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 2 (1:04 p.m.)
3 MEMBER SHACK: Okay. If we can come 4 into session.
5 Our next topic is the license renewal 6 and final safety evaluation report for the National 7 Institutes of Standard and Technology Reactor. And 8 it is Jack Sieber again. It is a big day for Jack.
9 MEMBER SIEBER: Yes. I am earning my 10 money today.
11 Thank you, Mr. Chairman, and thank all 12 of you for attending. I guess as an introduction, 13 when I look at what we have done, and what the staff 14 and the licensee has done here on the NIST project, 15 it is not really a license renewal but a relicensing 16 of the plant. And I will spend a couple of minutes 17 explaining why I used that term as opposed to what 18 we have been used to in the last 52 or 53 license 19 renewals under Part 54.
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1 called the National Bureau of Standards -- and the 2 reactor, which is located at, if you are going 3 northbound, Exit 11, southbound Exit 10, on I-270, 4 is known as NSBR. And that stands for National 5 Bureau of Standards, NBSR, Reactor.
6 This reactor differs from those that we 7 have renewed licenses for over the last 10 years, in 8 that it is a Type 104C reactor, which is a research 9 and test reactor. And because of that it falls 10 under different portions of the rule, the rules 11 which we use for normal power reactor relicensing, 12 and it stems from actually the Atomic Energy Act of 13 1954, as amended.
14 And the Congress at that time had the 15 foresight to recognize what research and test 16 reactors do, along with educational reactors, and 17 noted the fact that the power levels in research and 18 test reactors are a couple of orders of magnitude 19 lower than power reactors, and the source term is 20 several orders of magnitude lower.
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1 conditions -- for example, at full power -- a NIST 2 reactor operates at 7.2 pounds per square inch, 3 which is not a high pressure, and 115 degrees 4 Fahrenheit, which is roughly bath water, if you 5 don't mind tritium. But we wouldn't want you to do 6 it because we don't want you to contaminate the 7 moderator.
8 And so the rules are different. And if 9 you trace through from the broad statement in the 10 Atomic Energy Act to how this is interpreted in 11 Title X, you find that the description of -- and the 12 repeat of the statement in the Atomic Energy Act 13 related to this is in Part 50.41, which basically 14 grants broad leeway to the operator and owner of 15 research and test reactors to modify the reactor, 16 modify its operation, in a way to suit the 17 experiments that it is conducting, keeping in mind 18 the foremost consideration of public health and 19 safety.
20 And because of that, certain of the 21 regulations do not apply, and, of course, others do.
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1 For example, a lot of Part 50 does not apply to 2 research and test reactors -- notably, Appendix A, 3 which is the general design criteria. And, 4 therefore, you can't regulate a reactor like this to 5 meet those criteria.
6 In addition to that, Part 54, which is 7 license renewal, does not apply. On the other hand, 8 there is a whole host of provisions of the Title X 9 that do apply, and, for example, Part 19, which is 10 notices; Part 20, basically health physics 11 requirements; parts of Part 50, security; Part 100, 12 accident doses, and so forth.
13 These reactors are built to national and 14 local codes and standards, including the ASME boiler 15 and pressure vessel code for unfired pressure 16 vessels and NIST reactor vessels built to that 17 standard, and B31.1 piping standard, and commercial 18 codes for the confinement building and auxiliary 19 building supporting the reactor. And that is in 20 keeping with the low source term and mild 21 environment of that reactor.
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1 Now, we had our subcommittee meeting on 2 February 4th of this year, which I thought was well 3 done by both the applicant and the staff, and by our 4 subcommittee members at the time. And we had a 5 number of questions, which we collected during the 6 meeting and after the meeting. And with the use of 7 transcripts, which should make our Court Reporter 8 happy, that we used -- actually used the transcripts 9 to figure out what the questions really were, 10 compiled those, submitted them to the staff, and 11 between the staff and the applicant provided 12 answers.
13 And I have provided all of you copies of 14 this by e-mail, two drafts, one which was 15 preliminary and then a final, and paper form here.
16 And during the meeting today what I would like to do 17 is you can read through the questions, and if your 18 name is listed as the questioner you can read the 19 response to that and determine whether you are 20 satisfied with that response or not.
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1 commitment, and it has to do with the first question 2 on the adequacy of seismic analysis, where we talked 3 about doing a seismic walkdown, and had you done 4 one, and, of course, you aren't required to do one.
5 On the other hand, the applicant took the 6 initiative and performed one, found a block wall 7 that potentially might not meet power reactor 8 seismic qualifications, but if it failed could 9 endanger essentially safety-related equipment.
10 And the licensee has agreed to either 11 analyze that wall or remediate the wall, either by 12 fixing it or removing it or replacing it or 13 something like that. And I presume that the staff 14 is incorporating that response into their SER.
15 And on the other hand, it seemed to me, 16 at least from the questions I was involved in, that 17 the answers were very thorough and satisfactory.
18 I would like to bring up an issue that 19 is late arising, and this is an issue involving the 20 safety analysis, and has to do with loss of flow in 21 the coolant system. And I will just describe it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 enough to let you know that that -- this issue is 2 still out there, but not enough so that you will 3 find fault with my description.
4 If you look at the loss of flow, this is 5 loss of forced flow. There are four coolant pumps 6 of roughly 100 horsepower each, 13-inch impellers.
7 I think the capacity is something like 9,000 gpm or 8 something like that. Three out of four must operate 9 under the technical specifications, and the modes of 10 failure is loss of one pump or rotor seizing of a 11 pump while the other ones continued to run, and loss 12 of all power to all pumps, which by my way of 13 examining the analysis is the most severe case.
14 And the figure of merit is the critical 15 heat flux ratio. The licensee has decided that, if 16 you look at the actual flow coast down curve 17 compared to the curve used in the analysis, which is 18 supposed to fit the actual data, that there is a 19 difference and the difference is probably not 20 conservative. And it would appear to me, based on 21 napkin calculation, that what it does is affect the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 margin and to -- for the critical heat flux ratio 2 roughly 10 to 15 percent.
3 On the other hand -- and I think that 4 this issue needs to be addressed, and I would like 5 the applicant and the staff to address it here, but 6 it also needs to appear in the updated FSAR for this 7 facility in a corrected form, in the SER, that says 8 that the new analysis continues to meet the 9 regulations. And that will be an open item from 10 this meeting.
11 My intention is to cover everything that 12 we can cover that relates to the license renewal for 13 this reactor at this meeting. And when the 14 applicant and the staff are ready to fully address 15 this one outstanding issue, we can have another full 16 committee meeting of short duration where we can 17 hear your official analysis and the staff's review 18 of that, and limit that meeting to that discussion 19 and generate whatever letters or reports that we 20 have to generate at that time.
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1 minimizes the applicant's time. And I would also 2 offer that this is the way the system ought to work, 3 where the applicant finds and evaluates its own 4 errors, reports those. Second best is if the staff 5 finds, and the worst is if we find them. And so you 6 are in the best of all situations at this point, and 7 I think that is a very safety-conscious attitude on 8 everybody's part with this regard.
9 And so with that introduction, what I 10 would like to do is turn it over to Ted Quay, who is 11 Deputy Director of NRR, Division of Policy and 12 Rulemaking. And that is the division, as opposed to 13 our ordinary License Renewal Division, this division 14 is the division that does this type of reactor.
15 Ted?
16 MR. QUAY: Thank you. Good afternoon, 17 Dr. Sieber, and members of the Committee.
18 My name is Ted Quay. I am the Deputy 19 Director of the Division of Policy and Rulemaking in 20 NRR. Our division is responsible for the NIST 21 relicensing application, review of it.
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1 With me, on the far end of this table I 2 have Kathryn Brock, Chief of the Research and Test 3 Reactors Branch A. Ms. Brock's branch has primary 4 responsibility for relicensing reviews. Sitting 5 next to me is Mr. William Kennedy. He is here as a 6 Project Manager for the relicensing review. Mr.
7 Kennedy will lead the staff presentation.
8 This afternoon we will begin with a 9 presentation by the licensee that will include 10 discussions of the concerns voiced by members of the 11 ACRS Committee during last February's meeting.
12 Following the February meeting, the staff issued a 13 request for additional information to collect and 14 document information related to the ACRS members' 15 concerns. Mr. Kennedy reviewed the licensee's 16 information and visited the facility to examine the 17 licensee's seismic walkdown.
18 After the licensee's presentation, Mr.
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1 evaluation report. Mr. Kennedy will also explain 2 the closure of the open item and the staff's draft 3 safety evaluation report.
4 The open item has been successfully 5 resolved, and the staff final safety evaluation 6 report will be in management concurrence in the next 7 few days.
8 As you are aware, this week the licensee 9 identified an error in two of their accident 10 analyses. The staff will review the licensee's 11 effort on this error and present the findings to the 12 Committee later on this year. I expect the final 13 safety evaluation report to be published as a NUREG 14 this summer.
15 With that, I will turn the presentation 16 over to the licensee.
17 MEMBER SIEBER: Thank you.
18 MR. RICHARDS: Thank you, Mr. Chairman, 19 members of the ACRS. Thank you for letting us come 20 and present our responses to your questions. I have 21 a number of people here to assist in the responses.
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1 Dr. Williams is the head of our nuclear analysis 2 section. Dr. Rowe is a special assistant to the 3 NCNR Director.
4 And in the back, from my left to your 5 right, Dave Brown is the head of our health physics 6 section, Dan Flynn is the -- an SRO, Dan Hughes is a 7 trainee right now in the operations section, Dr.
8 Brand is the Chief of Reactor Engineering, and Mr.
9 Copley is the consultant we choose from Envirotech 10 to answer some of the climactic questions.
11 And I am Wade Richards, and I am the 12 Chief of Reactor Operations and Engineering.
13 Dr. Dimeo was unable to be here today.
14 He had a family emergency, so -- he is our Director.
15 So I will be -- I will very briefly go through his 16 description of the NIST Center for Neutron Research 17 at the NCNR, and then we will briefly describe the 18 NBSR. We were asked to summarize our licensing 19 basis accidents. We will be doing that. And then, 20 we will get into the subcommittee followup items, if 21 that is acceptable.
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1 The NIST reactor is a source of the NIST 2 Center for Neutron Research and its neutron-3 scattering user facility, serving over 2,200 4 researchers annually. Our mission is to assure that 5 availability of neutron measurement capabilities to 6 meet the needs of the U.S. researchers from 7 industry, university, and other government agencies.
8 The research done at the NCNR is highly 9 multidisciplinary, spanning basic and applied 10 materials research to investigate into some of 11 nature's most fundamental questions. In most of the 12 research done at the NCNR, neutrons are used to 13 probe matter. In some research, the neutron itself 14 is to be studied.
15 Our scientific productivity is widely 16 regarded as the highest of any neutron facility in 17 the U.S., most recently cited in the 2008 APS 18 report.
19 MEMBER BANERJEE: How many beam lines do 20 you have with that --
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1 actually giving you beam lines. What I am giving 2 you is instrumented positions.
3 MEMBER BANERJEE: Okay. So --
4 MR. ROWE: Sometimes we share beam 5 lines.
6 MEMBER BANERJEE: Yes.
7 MR. ROWE: But it is on the order of 20 8 to 24. A little of it depends on how you count, but 9 it is of that order.
10 MEMBER BANERJEE: Well, the reason I was 11 interested in beam lines was, where do you -- you 12 know, how many penetrations do you get to the core?
13 MR. ROWE: Okay. Penetrations going in 14 are nine beam ports that penetrate into the reactor, 15 plus one cold neutron port, which penetrates into 16 the vessel. Then, there are two tangential tubes 17 which come in underneath the fuel, so they come in 18 low in the vessel and go across, and there are four 19 rabbit tube possibilities.
20 MEMBER SIEBER: Yes. I have nine radial 21 beam tubes, two through-reactor tubes, a cold NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 neutron source, a thermal column, four pneumatic 2 tubes, and seven vertical tubes.
3 MR. ROWE: I guess I left out those 4 other --
5 MEMBER SIEBER: Okay.
6 MR. RICHARDS: Okay. We are one of four 7 major neutron-scattering facilities in the U.S., but 8 the only one not run by the Department of Energy.
9 Reports from the White House and the American 10 Physicists Society emphasize a number of important 11 observations regarding this essential measurement 12 technique.
13 NIST is the only facility providing a 14 broad range of world-class measurements and 15 capabilities. NIST has the largest user program, 16 mainly because of the cold neutron source, and the 17 way to reduce the gap between the U.S. and Europe is 18 through exploiting the best neutron sources and 19 increasing the number of beam lines and instruments.
20 We are way behind the Europeans in neutron sources 21 for the use of neutron-scattering.
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1 Given the success of the NCNR and its 2 national and international reputation for 3 excellence, and its critical role in the NIST 4 mission, it is not surprising that it has received 5 and continues to receive very strong support from 6 senior leadership at NIST and at the Department of 7 Commerce, to operate the NIST reactor costs 8 effectively and while assuring safety of the staff 9 and the general public.
10 An example of the agency's strong 11 commitment to the NIST Center for Neutron Research 12 is that we are in the midst of an initiative to 13 significantly expand our cold neutron measurement 14 capability over the next five years as part of the 15 American Competive -- Competitive -- Competitiveness 16 -- America Competes Act.
17 (Laughter.)
18 NIST and the Department of Commerce will 19 continue to remain committed to the safe, reliable 20 operation of the NIST reactor.
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1 of the NCNR?
2 (No response.)
3 If not, I want to go into a description 4 of the NBSR itself very briefly.
5 I guess before we get into the 6 description of the NBSR, the Chairman indicated 7 there was a question on aging of the NBSR. The NBSR 8 reactor first went critical in 1967, and it has been 9 operating -- started out at 10 megawatts?
10 MEMBER SIEBER: That's right.
11 MR. RICHARDS: I am looking at these 12 gentleman because they have been there the --
13 (Laughter.)
14 -- 10 megawatts, then went to 15, and 15 then went to 20. But in the time that we have been 16 operating, very recently, as recently as about a 17 year and a half ago, we did a vessel investigation 18 with a boroscope. And we looked down at the areas 19 in the reactor tank where the effects of aging would 20 be greatest -- that is, at the tips of our beam 21 tubes.
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1 Let me go back here and point out -- the 2 tips of the beam tubes --
3 MEMBER CORRADINI: You are going to have 4 to, unfortunately, be near a microphone.
5 MR. RICHARDS: Let me go back to the --
6 MEMBER CORRADINI: You have to --
7 MR. RICHARDS: There it is.
8 MR. ROWE: That is the tip of the cold 9 neutron penetration, the way it is pointing at --
10 over on the other side you can see one of the normal 11 radial beam tubes coming in. And then, down low you 12 can see the thermal -- the tangential tubes that run 13 below the actual fuel --
14 MEMBER CORRADINI: So, Mike, just like 15 trigger reactors, which is what I think I know, you 16 guys come in and then you cap off, so it is 17 essentially at the end of this so-called insertion 18 is where you are working by the insert --
19 MR. ROWE: That is right. It is right 20 in -- at the inner end is the highest flux point.
21 MEMBER CORRADINI: Okay.
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1 MR. ROWE: And basically what we have 2 done is to look at aging, look at embrittlement, 3 and, you know, or at least as many of you know, 4 there is an aluminum vessel. This is not a steel 5 vessel. There is no brittle ductile transition per 6 se.
7 And what you have is a continuous 8 degradation of ductility with thermal neutron 9 fluence, not fast neutron fluence. The amount of 10 that reduction in ductibility depends on the ratio 11 of thermal to fast.
12 What we have done to estimate the effect 13 of aging is to look at a program that was undertaken 14 at Brookhaven reactor, the HFBR before it was shut 15 down, and to look at that and to compare the thermal 16 and fast flux in that to ensure that we were 17 comparing the right kind of radiation condition.
18 At the end of the license period that we 19 are asking for at the moment, we will not have 20 reached half of the fluence that they had reached in 21 their testing program. And we are well within any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 reasonable -- ductility is still fine. We still 2 would meet a make-before-break criterion.
3 The last thing I would mention is the --
4 in fact, there is a very low -- as the Chairman 5 said, there is a very low pressure vessel, and the 6 region of highest fluence is a region of 7 compression, not tension. Where there is no tension 8 -- and one of the things we have in our tech spec, 9 we look very carefully at putting anything in there 10 which could create a pressure in there. In fact, we 11 are doing a lot of --
12 MEMBER SIEBER: The phenomena of concern 13 is the aluminum in the structure and the vessel when 14 it captures neutrons it creates silicon. Silicon is 15 an embrittling agent, and the -- this is not pure 16 aluminum. This is already an alloy that has 17 additives to it so that it is not so ductile. And 18 for -- in the short run you may be improving the 19 strength of the vessel back in the neutron 20 embrittlement before it becomes ductile enough to 21 show cracks.
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1 MR. ROWE: Certainly, the ultimate 2 strength is rising capacity.
3 MEMBER SIEBER: That is right.
4 MR. ROWE: At the cost of some 5 ductility. But as I say, we have done the 6 calculations and we satisfied that the ductility 7 will be fine until the end of this license period.
8 MEMBER ARMIJO: Just an order of 9 magnitude, what kind of strain would you expect from 10 -- at end of life for this vessel?
11 MR. ROWE: What kind of strain?
12 MEMBER ARMIJO: Yes. How much strain?
13 Is it like five percent strain capability without --
14 MEMBER SHACK: Ductility at the end of 15 life.
16 MEMBER ARMIJO: Yes, ductility at the 17 end of life, as measured by strain or a reduction in 18 area --
19 MR. ROWE: I guess I can't pull that off 20 the top of my head really quickly.
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1 know, is it the order of -- these are inherently 2 very ductile materials, so big numbers are -- at 3 beginning of life are --
4 MR. ROWE: It is several percent, but I 5 --
6 MEMBER ARMIJO: It is several percent.
7 MR. ROWE: That is the -- I won't try to 8 go any closer, because I don't trust my memory 9 anymore.
10 MEMBER ARMIJO: Okay.
11 MR. ROWE: Maybe 20 years ago I would 12 have remembered that, but --
13 MEMBER ARMIJO: You don't have any 14 materials guys around here that might --
15 MR. ROWE: Paul, do you remember? Paul 16 Brand.
17 MR. BRAND: I am the Chief of Reactor 18 Engineering, and I am trained as a Metallurgist, but 19 it is a long time ago that I have discussed this.
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1 get when you will do a uniaxial tensile experiment 2 would go roughly to 50 percent to one-third. That 3 is what I remember.
4 Before I would go in writing on that, I 5 have to go back to that discussion with Mike.
6 MEMBER ARMIJO: Okay.
7 MR. BRAND: But it definitely doesn't go 8 to a fraction of a percent. It goes to -- and I 9 cannot possibly see a mechanism that would invoke 10 that kind of ductility.
11 MEMBER ARMIJO: Yes. There is no 12 loading mechanism.
13 MR. BRAND: There is no loading 14 mechanism that we can think of that would invoke 15 this. And then, add that to the fact that the thing 16 has become a lot stronger, I don't think that this 17 should be a consideration at this point.
18 MEMBER ARMIJO: Okay. Thank you.
19 MEMBER SHACK: What did we say the end-20 of-life fluence was going to be?
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1 and I will look it up for you at the break. I just 2 don't have it -- again, I am not going to pull 3 things off the top of my head.
4 MEMBER SIEBER: I probably have it here.
5 MR. ROWE: I just don't trust my memory 6 on this.
7 MEMBER SIEBER: You applied for the 8 extension April 9, 2004. And under provisions of 9 timely renewal, the license continues. A renewed 10 license would be a period of 20 years from the 11 2004 --
12 MR. ROWE: I guess the question was, 13 what the fluence rate -- what the total fluence 14 would be. I will look it up. I just -- I just 15 don't want to do it off the top of my head.
16 MEMBER BANERJEE: What is the flux?
17 What is the flux?
18 MR. ROWE: The flux is on the order of 19 two times 1014. Thermals, that is the one that 20 counts. That is the one that matters in this case, 21 as you know. But I will get you that number.
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1 MEMBER SIEBER: Thank you.
2 MR. RICHARDS: Any more questions on the 3 aging?
4 (No response.)
5 If not, we will move ahead on the very 6 brief description of the National Bureau of 7 Standards reactor. It is heavy water moderated and 8 cooled, and it is enriched fuel, tank-type reactor 9 designed to operate at 20 megawatts. It is actually 10 a custom designed variation of the Argonne CP-5 11 reactor.
12 MEMBER BANERJEE: There is actually no 13 pressure in this. It is --
14 MEMBER SIEBER: It is hydrostatic 15 pressure.
16 MEMBER BANERJEE: Hydrostatic.
17 MR. RICHARDS: Hydrostatic.
18 MEMBER BANERJEE: And you have to pump 19 stuff through it, I take it.
20 MR. RICHARDS: It really is hydrostatic.
21 MEMBER SIEBER: It's hydrostatic.
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1 MR. ROWE: There is --
2 MEMBER SIEBER: It's vented.
3 MR. ROWE: -- helium pressure above the 4 vessel, above the motor in it. It sits in a few 5 inches of water. It really is a hydrostatic 6 process.
7 MR. RICHARDS: This picture depicts the 8 four cadmium shim arms, two on this side and two on 9 the other side.
10 MEMBER SIEBER: You have to sit by the 11 mic.
12 MR. RICHARDS: The four cadmium shim 13 arms and the 30 fuel elements, you can see the top 14 of the fuel element heads, and then the one large 15 hydrogen cold source are shown here.
16 The fuel element itself is very unique.
17 It is an MTR-type element of U-308 with an 18 aluminum-dispersion clad. It is 93 percent enriched 19 in U-235, has about 350 grams per element, 17 20 plates. There are 17 plates in the upper section, 21 and there are 17 plates in the lower section, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 you can see that there is a gap in the middle. The 2 plates are about 13 inches long by about 2.7 inches 3 wide, and there should be no clads.
4 (Pause.)
5 MR. ROWE: While we have a break, let me 6 give you the number you asked for -- two times 1023.
7 MEMBER SHACK: And I just -- I looked up 8 -- the elongation of that is somewhere around eight 9 to 10 percent. So it is ductile stuff. We didn't 10 just decide on a number between us, but I just 11 didn't want to give you a number without --
12 MR. RICHARDS: This is the seven-inch 13 gap, which is a rather unique feature of our fuel.
14 It is non-fueled, and this is actually on the center 15 line of the core, so that we are actually increasing 16 the thermalization by not having a fueled area 17 looking right at the center line. And then, of 18 course, there is the lower section. The overall 19 length of the fuel is about 70 inches.
20 MEMBER ARMIJO: Are all of the 21 assemblies the same -- have that gap in --
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1 MR. RICHARDS: Yes, they are.
2 MEMBER ARMIJO: Okay.
3 MEMBER BANERJEE: And what is the --
4 does it have a positive void coefficient or --
5 MR. ROWE: No.
6 MEMBER SIEBER: No.
7 MR. ROWE: So we will get to that, 8 because that was one of the questions asked. We are 9 going to talk about that.
10 MEMBER SIEBER: All of the coefficients 11 are negative.
12 MEMBER BANERJEE: Oh, okay. That is 13 right there.
14 MR. RICHARDS: Yes, we just -- I tried 15 to point it out here.
16 The MBSR includes many inherent capacity 17 systems. The prompt neutron lifetime is long due to 18 the heavy water. These are unique features of this 19 heavy water reactor, makes everything very slow.
20 The reactivity coefficients, void, and temperature 21 are all negative.
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1 As the Chairman said, the reactor 2 operates at a very low temperature compared to what 3 you are used to seeing, and a very low pressure.
4 And it has no large energy content.
5 MEMBER BANERJEE: Does this have a lot 6 of tritium?
7 MR. RICHARDS: Oh, yes.
8 (Laughter.)
9 MEMBER SIEBER: Well, I think you have 10 to --
11 MR. RICHARDS: You probably have to 12 quantify that.
13 MEMBER SIEBER: There are a number of 14 replaceable things in this reactor besides the fuel.
15 One of them is the --
16 MR. RICHARDS: Heavy water.
17 MEMBER SIEBER: -- heavy water, which is 18 replaced basically for ALARA principles, radiation 19 dose.
20 MR. RICHARDS: Operational 21 considerations, yes.
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1 MEMBER SIEBER: But it also aids in 2 coolant purification. There is an online coolant 3 purification system that is replacing the entire 4 heavy water load, guarantees periodic refreshing of 5 that. The same thing with the -- in fact, talking 6 about void coefficient, one of the emergency 7 shutdown mechanisms, the third one, is to dump the 8 moderator out of the reactor and that shuts it down.
9 MR. RICHARDS: One of our passive 10 systems.
11 MEMBER SIEBER: And the control rods are 12 also replaced from time to time, depending on 13 depletion as opposed to mechanical issues that might 14 occur.
15 MEMBER BANERJEE: So is the tritium 16 distilled off? I mean, tritium oxide or dioxide?
17 MR. RICHARDS: We actually have a tech 18 spec limit on the amount of tritium that we will 19 tolerate in the water, and it is -- when the tritium 20 reaches the five curie level --
21 MR. ROWE: Five curies per liter.
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1 MR. RICHARDS: -- we will replace the 2 whole tritium inventory.
3 MEMBER BANERJEE: So you --
4 MR. RICHARDS: I am sorry, the whole 5 P20.
6 (Laughter.)
7 MEMBER BANERJEE: So you don't have an 8 online tritium removal system.
9 MR. ROWE: No, we don't.
10 MEMBER SIEBER: No.
11 MR. ROWE: In fact, we have always 12 replaced the heavy water far ahead of the time that 13 we got to five times -- to five curies per liter.
14 If we never replaced it, five curies per liter would 15 be the limiting concentration at the end of life, 16 but we replace it long before then, as the Chairman 17 said, for ALARA purposes.
18 MEMBER BANERJEE: So how long does it 19 take to reach five curies?
20 MEMBER SIEBER: Several years.
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1 sorry, you said? Typically, we would replace it --
2 I am going to ask Dave Brown, who is the head of 3 Health Physics Branch.
4 MR. BROWN: Dave Brown, Health Physics.
5 I would estimate about 12 years.
6 MEMBER BANERJEE: Okay.
7 MR. BROWN: Twelve full power operating 8 years.
9 MEMBER ARMIJO: What happens with the 10 tritiated water that -- do you send it somewhere 11 else?
12 MEMBER SIEBER: Yes.
13 MR. RICHARDS: We sent it to ACL. Take 14 it and pour it in their reactor.
15 MEMBER ARMIJO: There is nobody else.
16 MEMBER SIEBER: Right.
17 MEMBER BANERJEE: Well, they know how to 18 separate it.
19 MR. RICHARDS: Yes, they do.
20 MEMBER BANERJEE: Okay.
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1 licensing basis accident. We were asked to just 2 very briefly summarize the accidents that we did 3 analyze. The startup accident -- it is an accident 4 that goes from 100 kilowatts to 130 percent of full 5 power, which was 20 megawatts, at a delta rho over 6 delta T over times 10-4 per second.
7 Maximum reactivity insertion accident, 8 experiment removed .5 percent delta rho in half a 9 second. Loss of coolant accident, inlet pipe break 10 in the process room, offsite tritium doses with this 11 accident were found to be well within the 10 CFR 12 Part 20 limits.
13 Misloading of a fuel element, we put a 14 fresh element in all possible locations. The loss 15 of flow -- if you'll notice, loss of flow, we have 16 the loss of offsite power, and there is an asterisk 17 on that one. And there is an asterisk on the single 18 pump seizure. That is because of the --
19 MR. ROWE: No, five.
20 MR. RICHARDS: I'm sorry?
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1 pumps, the other asterisk.
2 MR. RICHARDS: Oh, I'm sorry. It is one 3 missing, you said?
4 MR. ROWE: It is missing, unfortunately, 5 in the viewgraph, but it should have been on number 6 five. It seems to show --
7 MR. RICHARDS: Oh, loss of both shutdown 8 pumps.
9 MEMBER SHACK: So, number two, it 10 disappears and it goes to --
11 MR. RICHARDS: There is no issue with 12 number two. It is just on number five.
13 MR. ROWE: One and five.
14 MR. RICHARDS: One and five. Got my 15 asterisk in the wrong place.
16 MR. ROWE: And one -- five is a 17 modification of one, in which the shutdown pumps 18 don't start up.
19 MR. RICHARDS: And the asterisks are 20 there because of this situation with the coast down 21 curve, which we will talk about.
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1 MEMBER SIEBER: Right.
2 MR. RICHARDS: Throttling of the inlet 3 valves to either plenum, and the spurious signal 4 closing of DWV-19. This is one of the ones that you 5 identified -- you folks asked about, and that we 6 have done the analysis on now. And, of course, the 7 MHA, maximum hypothetical accident, postulates a 8 complete melting of an MTR-type fuel. And even 9 after that melting, complete melting, we still 10 satisfy the 10 CFR 100 limits at our site boundary.
11 Now, the open item that was discussed 12 before is the fact that when we were actually doing 13 the analysis for DWV-19, we decided to start looking 14 at a number of flow situations besides that one, and 15 we found that the 20-second coast down curve that is 16 in the present SAR, and also mentioned in the SER, 17 is incorrect. And we let the non-power branch know 18 that what we wanted to do was do some recalculations 19 on that coast down curve.
20 We are collecting the data tomorrow. We 21 will actually get -- the reactor portion is down NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 right now. We will collect up all of the data 2 tomorrow, and then send the analysis off to BNL to 3 run the RELAP code for us, and we should get some 4 updated coast down curves.
5 We consider this situation analogous to 6 -- analogous, and bounded by the way, by the DWV-19 7 valve situation, which we have analyzed, because 8 that is a complete loss of flow. So we -- as the 9 Chairman stated, we will be coming back to you 10 probably in a month, or whenever we can get back on 11 your calendar, with an analysis of a new coast down 12 curve.
13 VICE CHAIRMAN ABDEL-KHALIK: What is the 14 worth of a control rod in --
15 MR. RICHARDS: The control rods are 16 usually worth eight to sometimes even $10.
17 MR. WILLIAMS: Bob Williams. The group 18 of them together is more than $30. So roughly eight 19 to $10.
20 VICE CHAIRMAN ABDEL-KHALIK: So where 21 did the .5 percent delta rho in half a second come NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 from then?
2 MR. WILLIAMS: That is from the removal 3 of the -- an experiment from the core with the 4 maximum reactivity allowed.
5 VICE CHAIRMAN ABDEL-KHALIK: But it 6 doesn't have anything to do with the --
7 MR. WILLIAMS: No. Actually --
8 VICE CHAIRMAN ABDEL-KHALIK: -- kind of 9 failure?
10 MR. WILLIAMS: -- the startup accident 11 has to do with it. The reactivity insertion rate 12 there is our tech spec limit. So we just assume 13 that that reactivity insertion rate continues 14 unabated from 100 kilowatts to -- is it 100 15 kilowatts? To full power, yes.
16 MR. ROWE: Until it's --
17 MR. WILLIAMS: Without a period scram.
18 VICE CHAIRMAN ABDEL-KHALIK: Thank you.
19 MR. WILLIAMS: That is the maximum 20 reactivity insertion rate, and then the other 21 accident is the experiment, the highest worth NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 experiment.
2 MEMBER SIEBER: I just might add at this 3 time you have the SER -- SAR available to you. It's 4 Figure 4.9 -- 4-9 in the SAR, that compares the 5 curve of flow coast down for -- that was used in 6 RELAP versus plant data that existed at the time.
7 And the issue is not so much the displacement of the 8 curve but the slope, as I see it. And the coast 9 down slope looks to be steeper, a little bit 10 steeper, for the actual plant data than the curve 11 used in RELAP.
12 MEMBER BANERJEE: So I presume that the 13 mode of cooling -- and I think we may have addressed 14 it -- is natural circulation when the pumps --
15 MR. RICHARDS: Yes.
16 MEMBER BANERJEE: Now, you said a way to 17 chop this thing down is to dump the heavy water, 18 right? So what happens when you dump the heavy 19 water?
20 MR. ROWE: It is not dumped all the way.
21 MEMBER BANERJEE: Oh. You just dump --
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1 MR. ROWE: We don't empty the vessel.
2 We drop it down until the top reflector is removed.
3 MEMBER BANERJEE: And that is enough --
4 MR. ROWE: And that is enough -- that is 5 enough to give us a shutdown margin against full 6 removal of all four amounts.
7 MEMBER BANERJEE: So when you drop it to 8 that level you still have sufficient natural 9 circulation to keep it cool?
10 MR. ROWE: No. No, you would want the 11 pump running. And we don't use that -- that's a 12 backup shutdown mechanism.
13 MEMBER BANERJEE: Normal shutdown is 14 with the rods.
15 MR. ROWE: Normal shutdown is with the 16 rods, and then we leave that water there. But where 17 the level drops to the natural circulation would not 18 be as good as we would want to have.
19 MR. WILLIAMS: One more thing. Bob 20 Williams. Our inner reserve tank, then, would empty 21 into the fuel elements in the case that they dropped NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the moderator level. So there would be cool 2 reporting on top of the fuel.
3 MEMBER SIEBER: Yes, cool --
4 MEMBER BANERJEE: From heavy water.
5 MR. WILLIAMS: Yes. Yes.
6 MEMBER BANERJEE: And where is your heat 7 sink in this problem?
8 MR. ROWE: When it's in natural 9 circulation? There is a vessel plus the core 10 support structures plus the biological shield.
11 MEMBER BANERJEE: Thanks.
12 MR. ROWE: Okay.
13 MR. RICHARDS: The next area to cover is 14 the actual response to the items that the Committee 15 came up with from our last meeting. I would like to 16 ask the Chairman -- I am not exactly sure how to 17 proceed here. There are over 19 of these items, and 18 we can either address the ones that you have -- you 19 have all had the writeups. We can either address 20 the questions that you have or I can go through each 21 one and -- with a small summary.
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1 MEMBER SIEBER: I think that would be 2 pretty time-consuming to do it that way, 3 particularly since the answers that you provided us 4 and the staff provided us are so thorough. What I 5 had initially asked members to do is to look at the 6 list that I -- we had handed out to them, to find 7 the questions that they asked, and if they are 8 satisfied with the answers, so be it. If they have 9 further questions based on what they read as 10 responses, then they should feel free to ask those 11 followup questions.
12 MEMBER RAY: Well, Jack, I have done as 13 you asked, and I will start, if it's okay, with the 14 following question.
15 MEMBER SIEBER: Okay.
16 MEMBER RAY: The subject is groundwater 17 monitoring, and I have read the answer, the 18 response. And I know I am not an expert in this.
19 Maybe Mike Ryan --
20 MEMBER RYAN: Could you jump in on what 21 question it is, please, just what page you are on?
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1 MEMBER RAY: I would if they were 2 numbered. It happens to be on page 6 of my -- the 3 copy I have, Mike. It's entitled ground --
4 MEMBER SIEBER: The pages are numbered.
5 MEMBER RAY: -- groundwater monitoring.
6 I don't have a numbering of them. I have it by 7 titles. Anyway, as Jack has said, it is a complete 8 response referring to this having been looked at by 9 URS, and USGS I guess.
10 But the conclusion seems -- can I say 11 sort of hedged? And the rationale provided is -- I 12 would just say reads like it is sort of, well, this 13 is the best we can surmise. It ends by saying there 14 appears to be a technically adequate approach to 15 monitoring potential offsite migration of 16 constituents in groundwater.
17 So, anyway, it just seemed to be like 18 less than the kind of response we would expect 19 normally. And I wondered if there was anything 20 stronger that could be said.
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1 is you always want to dig one more hole.
2 MEMBER RAY: Well, Mike, while I am 3 talking here, read it yourself and see what you 4 conclude.
5 MEMBER RYAN: No. I appreciate your 6 point that it is not as definitive as one might 7 like.
8 MEMBER RAY: You are a better judge of 9 this than I would be.
10 MEMBER RYAN: I guess the proof is in 11 the pudding on the second question. I am interested 12 in -- because the second question informs whether we 13 need to push the first question further. And you 14 told -- let's see, it is the one regarding the 15 tritium. Maybe it is not on that page, it is one 16 later on.
17 MEMBER RAY: Right below it. Member 18 Ryan asked about the applicant's environmental 19 monitoring. You know, you say monitoring for 20 tritium, and you never really said what your finding 21 -- you are saying it is below the drinking water NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 standard, but is it 1,000 or 2,000 or 19,600?
2 MR. RICHARDS: I'd refer to Dave.
3 MR. BROWN: Dave Brown, Health Physics.
4 I guess I am wondering, what is your exact 5 question?
6 MEMBER RYAN: Well, in the groundwater 7 monitoring results you monitored for tritium. Can 8 you give me a range of values that you see in 9 groundwater?
10 MR. BROWN: Zero.
11 MEMBER RYAN: It is not zero. It is 12 background.
13 MR. BROWN: Oh, it is background, excuse 14 me.
15 MEMBER RYAN: Okay. So background in 16 your area is 1,000? 800? What is the background 17 you measured, do you know, have a range of numbers 18 or --
19 MR. BROWN: Background --
20 MEMBER RYAN: For tritium.
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1 MEMBER RYAN: Yes, picocuries per mL.
2 MR. BROWN: Picocuries per mL we are 3 measuring -- our lower level detection is on the 4 order of -- I am trying to convert picocuries per 5 mL. It is like 10 -- a couple dpm per mL, and we 6 don't see anything above that.
7 MEMBER RYAN: Okay. That is really, 8 really low.
9 MR. BROWN: We don't measure any 10 positive results in our environmental samples.
11 MEMBER RYAN: Really? Okay. All right.
12 Thank you. That is fine.
13 So if the numbers are at or near 14 background, and they are not creeping up or you 15 don't see any trends, that is my --
16 MR. BROWN: That's correct.
17 MEMBER RYAN: -- second question, you 18 don't see any trends up or down because you are not 19 measuring anything. I don't mean to be critical, 20 but there is two reasons. You are not looking in 21 the right place, which I am thinking you are looking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 in the right place, or the numbers really confirm 2 that there is no area of concern.
3 So I guess with that, Harold, I am 4 satisfied that if the tritium values are very low 5 compared to the drinking water standard that it is 6 reasonable to conclude that, you know, they are 7 okay.
8 MEMBER RAY: I will accept it on that 9 basis, then, and I really wasn't going to say I 10 wouldn't accept it anyway. I just want to draw 11 attention to the fact that it was a very qualified 12 and hedged answer about why the sampling points were 13 adequate.
14 MEMBER RYAN: The proof is in the 15 numbers in the samples to me. That is where you 16 really gain confidence in statements that are 17 equivocal, you know, about what is actually 18 happening.
19 MEMBER RAY: Yes. Well, I had a leaking 20 spent fuel pool, and we never found anything until 21 we dug it up. But that is okay.
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1 MEMBER BANERJEE: How do you know to dig 2 it up?
3 MEMBER RAY: We decommissioned the 4 plant.
5 MEMBER SIEBER: Don't have to worry 6 about shutting it down then.
7 MEMBER RAY: Okay. Anyway, that is --
8 the other one I had was on this issue of what we 9 would normally refer to as the tech specs on the 10 diesel generators. The answer is we don't need them 11 anyways. They are just there as backup.
12 It is a little confusing, because, you 13 know, these things are always for backup. But I --
14 in this case, I think what Jack said at the outset 15 is probably the right way to look at it, which is at 16 such low power density, and so on, that it is 17 inherently safe without emergency power --
18 electrical power supplies.
19 So the fact that you have them out of 20 service for an extended period of time is not 21 something we would take exception to I guess. So, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 anyway, those are the two questions I had.
2 MEMBER RYAN: I can finish up pretty 3 quick, Jack, if it's all right.
4 MEMBER SIEBER: Okay. Go ahead.
5 MEMBER RYAN: I really appreciate the 6 experimental review flow diagram, and so forth, that 7 you provided. It certainly answered my question 8 there.
9 And then, I guess on the waste question 10 you really have until the end of facility lifetime 11 to store waste, so --
12 MR. ROWE: Yes.
13 MEMBER RYAN: And, again, I am not 14 looking for a further followup question, but you 15 addressed the, you know, access and personnel 16 control, and that kind of thing, I am sure in your 17 in-house procedures for who can get in, when they 18 can get in. Are you going to get to any kind of 19 inventory where you would be, you know, of concern 20 of how much inventory you had? Are we talking 21 curies or thousands of curies?
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1 MR. RICHARDS: I am not aware we are 2 going to get to that level, are we, Dave?
3 MEMBER RYAN: And I would permit it for 4 storage separately from the operation of the reactor 5 I guess.
6 MR. BROWN: Dave Brown, Health Physics.
7 Right now there is reactor-produced material, and 8 it is included within the reactor license.
9 MEMBER RYAN: So they are authorized to 10 store that onsite, right?
11 MR. BROWN: As far as I know, yes.
12 MEMBER RYAN: Well, how many curies of 13 stuff do you have in inventory in waste?
14 MR. BROWN: Right now?
15 MEMBER RYAN: Yes.
16 MR. BROWN: Well, we just did a shipment 17 in June before the site closure, so we are very low.
18 MEMBER RYAN: So very low.
19 MR. BROWN: Millicuries.
20 MEMBER RYAN: Where would you get -- I 21 mean, what do you think -- and, again, I am asking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 for an insight, so please don't take this as a 2 question, but where would you anticipate 3 accumulation might cause you some operational, you 4 know, concerns, where you are going to be more 5 focused on managing the waste in storage than you 6 are now?
7 MR. BROWN: Well, our plans are pretty 8 straightforward. It is passive storage. When we 9 reach a level to where we normally would ship, if 10 there is no site available to ship it to we will put 11 it in the same type of package, transfer it to one 12 of these storage facilities, and put the sealed lead 13 on it and wait for a --
14 MEMBER RYAN: Around the storage areas.
15 MR. BROWN: Yes.
16 MEMBER RYAN: Yes, okay. And how many 17 years in between shipments did you go?
18 MR. BROWN: Four to five.
19 MEMBER RYAN: Four to five.
20 MR. BROWN: That is for the Class C 21 waste.
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1 MEMBER RYAN: Right. Okay. Thank you.
2 That's it. I just -- that is good enough detail.
3 I appreciate the followup. Thanks so much.
4 MEMBER SIEBER: Okay. Does any other 5 member have followup questions to the questions that 6 they posed at the last meeting --
7 MEMBER STETKAR: Yes.
8 MEMBER SIEBER: -- based on the answers?
9 MEMBER STETKAR: A few, and I know we 10 are short on time here, so --
11 MEMBER SIEBER: Go ahead.
12 MEMBER STETKAR: The DWV-19 closure, I 13 really appreciate all of the analysis you did, but a 14 couple of questions. One is the conclusion is that 15 the maximum temperature remains quite low for at 16 least a couple of hours, if not longer than that.
17 And you make the statement that there has been ample 18 opportunity to reopen the valve and provide 19 supplemental cooling.
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1 other -- you mentioned other vent paths and things 2 like that, and I couldn't find -- I didn't have 3 enough wherewithal to go try to search through 4 different drawings, because part of the question was 5 also on venting -- vent capability. Are there 6 enough vent paths available that you could remove 7 heat, you know, in the event that you couldn't get 8 that valve open, if the gate --
9 MR. ROWE: We have enough vent paths 10 that we don't have to worry about pressure, in spite 11 of the fact that DWV-19 remains closed. We are 12 vented as well as -- we have vents equivalent to the 13 one that is beyond the pipe. But heat transfer goes 14 -- we actually have done measurements looking at 15 what happens over -- for a long period of time. We 16 would be fine for a long time.
17 MEMBER STETKAR: Okay. Okay.
18 MR. ROWE: It has been measured. And I 19 can't give you a good calculation.
20 MEMBER STETKAR: Well, that was my 21 sense. I was just curious whether there was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 something magic about this couple of hours, and we 2 would have enough time to --
3 MR. ROWE: The statement about a couple 4 of hours is under normal circumstances what we would 5 do is -- as soon as we had the problem, we would go 6 down, and there is a disconnect for the automatic 7 operator. We would use that disconnect and close 8 them manually.
9 Now, if the valve completely failed, 10 that is not -- that is obviously not what we are 11 going to do. Well, I guess you wait for it to 12 happen, understand the question, and then we would 13 be fine. We would have to --
14 MEMBER STETKAR: I was --
15 MR. ROWE: -- understand how to deal 16 with it over the longer term.
17 MEMBER STETKAR: Occasionally valves 18 fall apart.
19 MR. ROWE: Occasionally valves fall 20 apart.
21 MEMBER STETKAR: Not very frequently.
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1 That is enough, because of the time.
2 Responses on -- we had questions on the 3 general topic of single failure criterion. But you 4 made the statement that says because you only have 5 one DC bus, one DC power supply is adequate because 6 DC power is not necessary to achieve or maintain 7 safe shutdown. That was a simple --
8 MR. ROWE: Right.
9 MEMBER STETKAR: -- sentence. There 10 were a couple of amplifying paragraphs after that 11 sentence, but those paragraphs basically describe 12 redundancy and instrumentation and things like that 13 that -- it is not clear if you had -- if you didn't 14 have any DC power you would have any 15 instrumentation.
16 So I was curious, what is the basis for 17 the statement that said DC power is not necessary to 18 achieve or maintain safe shutdown?
19 MR. ROWE: Let me first try and explain 20 what the supplementary paragraphs were intended for, 21 and then try to answer your actual question. In the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 supplementary paragraphs we are addressing the 2 question which had been asked about diversity of 3 detection capability.
4 And there was some question -- and I 5 don't remember who asked the question anymore, but 6 anyway there was a question about, was it really a 7 single detector in which the failure --
8 MEMBER STETKAR: Okay. Those are not 9 relevant to the --
10 MR. ROWE: But safe shutdown goes -- we 11 can scram, and after rescram that is all we have to 12 do. With DC power you are not required to scram.
13 MEMBER STETKAR: Right.
14 MR. ROWE: And we can scram. And the 15 reactor, when it has scram, it will just sit there.
16 MEMBER STETKAR: Okay. Okay. That's 17 what I thought. I got a bit confused whether the 18 second --
19 MR. ROWE: I'm sorry.
20 MEMBER STETKAR: -- was somehow a 21 qualification of that first statement somehow.
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1 MR. ROWE: And then, the only other ones 2 I had were I understand now -- thank you very much 3 -- I had a question about scaling of the return 4 period or the frequency on high wind speed, the 100 5 mile per hour wind speed. And I understand now how 6 the calculation was performed. It is not -- still 7 not clear to me how data derived from wind speeds in 8 Kingston, Jamaica, are necessarily relevant to 9 scaling of wind speeds in Rockville or Gaithersburg, 10 Maryland.
11 What I -- that is just a whiny statement 12 in a sense. The real question I had was I 13 understand now how the numbers that you used were 14 calculated. My question was: how do you account 15 for the actual historical data that I pointed out in 16 the subcommittee meeting about high wind speeds 17 measured here in the greater metropolitan D.C. area?
18 And there is a paragraph -- and I 19 honestly don't understand -- it is on page 22 for 20 the other Committee members, the middle of the page.
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1 better what that discussion means about -- it starts 2 off, "These data points are relevant only to the 3 extent," and so forth. So if somebody could help me 4 out on that, I would really appreciate it.
5 MR. CROSBY: Good afternoon. My name is 6 John Crosby. I am with Envirotech. I am a 7 consultant to NIST on the project. We did the 8 climate study.
9 It is an interesting question. Let me 10 just read through. Is your question at the end, the 11 last sentence, sir, about the --
12 MEMBER STETKAR: It was actually the 13 whole paragraph.
14 MR. CROSBY: The whole paragraph.
15 MEMBER STETKAR: Well, yes, the whole --
16 I was trying to understand a little bit better what 17 the --
18 MR. CROSBY: There doesn't seem to be a 19 method to incorporate data that happened, and I will 20 say yesterday, not in a sarcastic way, but in the 21 recent future to put those into the tables that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 used in these volumes provided by ASME and others.
2 So, in effect, something that happened in the last 3 few years hasn't been incorporated and would -- but 4 would be incorporated in the next update of the 5 volume.
6 MEMBER STETKAR: Oh. Is that -- oh.
7 MR. CROSBY: That is what we are trying 8 to say.
9 MEMBER STETKAR: Ah. That is --
10 MR. CROSBY: I apologize.
11 MEMBER STETKAR: Okay. Now I understand 12 what you are trying to say.
13 MR. CROSBY: Then, what we tried to do 14 was explain that in the old days -- in recent past 15 they would use the highest wind data per year, the 16 one epochal data point.
17 MEMBER STETKAR: Okay.
18 MR. CROSBY: Currently, they are using 19 what they call peaks over threshold, so they are 20 trying to determine what is this threshold supposed 21 to be, and then any time the wind goes above that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 that data point would count, which makes it a much 2 better data set, much more realistic.
3 So they could -- because there could be 4 many data points above this threshold. And that was 5 the last sentence where apparently there is an 6 ongoing discussion point about what that threshold 7 would be, so --
8 MEMBER STETKAR: Oh, okay. Thank you.
9 I now understand what that paragraph means. I am 10 not sure if it answers my original concern, because 11 I think --
12 MR. CROSBY: Well, the original 13 concern --
14 MEMBER STETKAR: The original concern 15 was basically taking your -- the curve that you show 16 in Figure 1, which is derived from data in Jamaica 17 --
18 MR. CROSBY: Yes, right.
19 MEMBER STETKAR: -- and saying how --
20 how would that curve change if I actually looked at 21 historical wind data for this area?
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1 MR. CROSBY: Right.
2 MEMBER STETKAR: Which in principle you 3 could do.
4 MR. CROSBY: I would refer you then to 5 that Table C6-7 at the top of page 22. The data 6 from Kingston, Jamaica, because of the fact that it 7 is a well-instrumented island, they are able to 8 collect a lot of data there over a number of years, 9 and they developed the numbers in Table 1 on page 21 10 as well as confirmed this reverse Weibull curve, 11 which is the curve on the top of page 21.
12 What they show is that the numbers are 13 actually higher than what the current ASCE shows in 14 that Table C6-7. So --
15 MEMBER STETKAR: But that is an average 16 of the continental United States, and I am talking 17 about --
18 MR. CROSBY: Right.
19 MEMBER STETKAR: -- you know, the D.C.
20 area.
21 MR. CROSBY: But we have --
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1 MEMBER STETKAR: Which might be better 2 or worse, but I don't know.
3 MR. CROSBY: Right. Well, the wind 4 curve data, though, that we -- I hate to keep 5 flipping here. Let me just go back a minute. There 6 are wind speed charts, if you will, like the one we 7 show on page 19. While it is in wind pressures as 8 opposed to velocity, you can basically see that we 9 are in a very, very low wind area compared to, say, 10 the south tip of Florida, which receives hurricanes, 11 or the Outer Banks. Those darker areas have much, 12 much higher potential wind velocities than we do.
13 MEMBER STETKAR: Yes.
14 MR. CROSBY: I think if we were on the 15 coast, we would have a much bigger concern about the 16 winds than we do here from hurricanes.
17 MEMBER STETKAR: Thanks. And because of 18 the time, I -- you have explained -- I understand.
19 Thank you very much.
20 MR. CROSBY: You're welcome.
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1 questions?
2 MEMBER STETKAR: I don't have -- I have 3 some for the staff, but we need to get them --
4 MEMBER BROWN: Just one other one on the 5 radiation monitors. You talk about -- this is on 6 the redundancy. How did you get redundancy? And 7 you mentioned your basic reactor monitoring devices.
8 You are required to have a redundancy by your tech 9 specs, I presume. So you've got two, and I presume 10 one out of two is enough to shut you down on any one 11 of the particular functions, is that correct?
12 MR. ROWE: That's correct.
13 MEMBER BROWN: Okay. And then, you went 14 on to talk about the radiation monitors for airborne 15 radioactive material. You said you had two 16 detectors monitoring the normal air and irradiated 17 air drawn into the building air exhaust system. And 18 I didn't quite catch -- and you had -- your third 19 one was actually monitoring stack exhaust.
20 MR. ROWE: Yes.
21 MEMBER BROWN: So I am not quite -- what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 is this -- you said measure normal air. Is this 2 from outside the building, bringing it in into the 3 intake? Are you talking about normal air into the 4 exhaust or irradiated air into the exhaust?
5 MR. ROWE: Let me try, and if I get in 6 trouble I will bring Dan Flynn in. We have two 7 different air systems within the reactor, two 8 different ventilation systems -- one that we call 9 normal air, which is just taking air out of the 10 normal places, others that we call the active air 11 system, where we -- there are actually places where 12 we expect that we might have a problem, close to the 13 beam port, places where we might generate argon.
14 So those are the two systems, but they 15 are both taking air from inside the reactor and 16 taking it to the outside.
17 MEMBER BROWN: Okay. So there is one 18 detector in each of those, and each one of them is 19 supposed to cause a scram, if it detects radiation 20 according to the statements in here. Okay? Is that 21 correct?
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1 MR. ROWE: I'll let Dan --
2 MR. FLYNN: Dan Flynn, Reactor 3 Operations.
4 MEMBER BROWN: There is three of them.
5 There is normal air, irradiated air expected places, 6 and then there is the stack, stuff going out to the 7 environment.
8 MR. ROWE: Right.
9 MEMBER BROWN: So just two of those 10 three?
11 MR. FLYNN: We need two out of the 12 three. Dan Flynn, Reactor Operations. We need two 13 out of three. Each channel will give you a scram.
14 MEMBER BROWN: But two out of -- oh, you 15 need two out of three to be operational? Is that 16 what you mean?
17 MR. FLYNN: That is correct. Each 18 channel will give you a scram at 50,000 counts.
19 MEMBER BROWN: Okay. All right. Thank 20 you.
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1 questions?
2 MEMBER ARMIJO: Just a couple of things 3 on the spent fuel pool. I asked questions about 4 that.
5 I was looking for any issues related to 6 accidents, and not necessarily criticality, but, you 7 know, things dropping on the fuel, misloading, which 8 actually is a criticality event. So that is what I 9 was looking for, but I -- I think you pretty much 10 answered that question.
11 But in the case of the criticality 12 analysis, you do some very conservative analysis.
13 And do you or don't you take into account the Boral 14 in your racks?
15 MR. WILLIAMS: No, I do not.
16 MEMBER ARMIJO: You do not.
17 MR. WILLIAMS: I did not take into 18 account any poisons when I did those calculations.
19 And I didn't take into account structural material 20 either. I just put the fuel in the geometry that it 21 is with water and concrete. The only exception was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 one rack had stainless steel cans, and I put the 2 stainless steel there. But that doesn't make a huge 3 difference.
4 MEMBER ARMIJO: Which are the racks that 5 have the Boral? Is it most of your racks?
6 MR. WILLIAMS: No. Two of them do, and 7 two of them don't. There is a rack that holds 24 8 elements I think, 22, that -- whether it's Boral 9 separating the pairs of elements, that are just in 10 two rows. And then, the combination rack that has 11 one row of fuel elements and shelves with fuel 12 pieces. The fuel pieces would be one section of our 13 fuel element, just where the plates are.
14 MEMBER ARMIJO: In your operations, do 15 you have to assure yourself that the Boral is still 16 effective? You know, there is a current issue in 17 power reactors that some Boral is losing its neutron 18 capture ability.
19 MR. WILLIAMS: I heard that. I don't --
20 I don't really know. But that is why I didn't 21 include it in the calculations.
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1 MEMBER SIEBER: Right.
2 MEMBER ARMIJO: So it is not in your 3 calculations.
4 MEMBER SIEBER: Not in the --
5 MEMBER ARMIJO: It is in the safety 6 analysis that --
7 MR. WILLIAMS: That is correct.
8 MEMBER ARMIJO: Okay.
9 MR. WILLIAMS: Just in case.
10 MEMBER SIEBER: Okay.
11 MEMBER ARMIJO: All right. Thank you.
12 MEMBER SIEBER: Any further questions?
13 MEMBER BANERJEE: I just have a general 14 question. What is the largest sort of credible 15 penetration that could break, and how long would it 16 take your tank to drain them? Is there a 17 penetration into the tank that could conceivably 18 break? And, if it did, how long would it take the 19 tank to drain through that?
20 MR. ROWE: The answer to the first 21 question is not in any credible way that we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 found. We have calculated the worth of flooding the 2 tanks, and that is all well within the controls 3 of --
4 MEMBER BANERJEE: There are no pipes 5 leading in/out of the tank?
6 MR. ROWE: Well, only the one that we 7 analyzed in the loss of coolant accident. We did an 8 analysis without -- without saying how it happened, 9 and said that we had a rupture in the lower part 10 under the reactor, we had a complete rupture. I 11 don't remember the time it took to drain, but that 12 is one of the accidents that we actually analyzed.
13 MEMBER BANERJEE: And you made up --
14 MR. ROWE: But that would be the fastest 15 way to drain it that I know of. I can't think of a 16 faster way to drain it.
17 MEMBER BANERJEE: Yes. I wasn't at the 18 subcommittee meeting, so I -- so you did analyze 19 that.
20 MR. ROWE: We analyzed the loss of 21 coolant.
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1 MEMBER BANERJEE: Emergency water which 2 is --
3 MR. ROWE: Yes, we do. We have a 4 completely passive emergency tank, which will start 5 to drain. That is adequate for half an hour. With 6 a single reactor operator intervention, we are good 7 for a couple of hours. Following that, we have 8 backup systems to either use potable water or to 9 bring the heavy water back up from where it is 10 collected in the process room and feed it back in.
11 MEMBER SIEBER: We are running a little 12 bit behind time, so if there are additional 13 questions that are important to the process, let me 14 know now. If not, I would like to thank the 15 applicant for being well prepared and responsive to 16 our questions and concerns, and invite the staff to 17 just summarize the preparation of their SER.
18 And while they are getting ready to do 19 that -- and thank you very much -- I will point out 20 that because of the complexity of licensing and 21 relicensing of Type 104 reactors there is a standard NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 review plan which each of you got a copy. It is 2 NUREG-1737, and it was published about 13 years ago.
3 Volume 1 tells applicants how to write 4 their final safety analysis report and tech specs.
5 Volume 2 tells the NRC staff how to review it and 6 what the acceptance criteria are.
7 This process that NIST has gone through 8 now has basically updated the FSAR, since they are 9 not required to annually update the FSAR for this 10 type of reactor, as power reactors are required to 11 do.
12 And so the review job is extensive. The 13 SER has been provided to all of you electronically.
14 At least I got a paper copy of it, which I will 15 give to anybody who wants it. And maybe you can 16 summarize the findings and conclusion from your 17 review.
18 Thank you.
19 MR. KENNEDY: Okay. Thank you. Good 20 afternoon, Mr. Chairman, and distinguished members 21 of the subcommittee. My name is William Kennedy. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 am the NRR Project Manager for this license renewal.
2 I want to thank you all for being here, and also 3 thank the members of the subcommittee for raising 4 some good concerns that really helped us to improve 5 the process overall and the review of the 6 application.
7 And my goal today is just to provide 8 common understanding for everyone regarding our 9 conclusions in the safety evaluation report or 10 resolution of the open items. And also, if there 11 are any additional questions regarding your concerns 12 from the subcommittee meeting, I can try to address 13 those as well.
14 What I am going to cover briefly is the 15 licensing history, the staff review criteria, 16 overview of the safety evaluation report, resolution 17 of the open item, and I can mention again briefly 18 the additional open item if there are more questions 19 on that.
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1 license from the Atomic Energy Commission for short-2 term operation, kind of start up and verify the 3 reactor was operating as designed. That was in 4 1967.
5 They got their 15-year license in 1970.
6 They applied for a license renewal and a power 7 uprate in 1980, and that was -- the license was 8 issued in 1984. And we recently received the 9 application in 2004 for the current licensing 10 action.
11 Some of the requirements have already 12 been covered, so I am going to go through these 13 briefly. Part 54 does not apply to test reactors, 14 and there is a statement in the Atomic Energy Act 15 calling for the minimum amount of regulation 16 necessary for the NRC to complete its obligations 17 under the Atomic Energy Act.
18 MEMBER CORRADINI: Just for background.
19 The Section 104, that was instituted for primarily 20 test reactors or for what was the -- what you know 21 to be the historical intent? I assume --
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1 MR. KENNEDY: Research and test 2 reactors, yes. The test reactor criteria that 3 applies in this case is that the power level is over 4 10 megawatts, not that they do excursion testing or 5 fuel testing. It is just based on power level 6 alone.
7 MEMBER CORRADINI: And then, this goes 8 down to a level of what? The Section 104 goes down 9 to any power you want.
10 MR. KENNEDY: Yes.
11 MEMBER SIEBER: If it's critical, it's 12 in there.
13 MR. KENNEDY: We have five watts and --
14 MEMBER CORRADINI: I just wanted to make 15 sure. Thanks.
16 MR. KENNEDY: This has already been 17 covered. Just to clarify, Part 100 is applicable to 18 test reactors, but it is only -- only the part about 19 accident doses. The seismic appendix is not 20 applicable.
21 This is our standard review plan, NUREG-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1537, and we are doing the application and also 2 associated reg guides, standards, and other NUREGs.
3 These are the areas we reviewed.
4 Seismic and groundwater monitoring fall under the 5 siting criteria; the structures, systems, and 6 components; reactor characteristics like the 7 moderator, void, and temperature coefficients; 8 electrical power systems, including the backup power 9 systems that are provided for defense-in-depth, 10 their experiment program.
11 We spent a lot of work on the accident 12 analyses and also rewrote essentially the technical 13 specifications to conform to the format of the 14 current standard. And we also looked at prior use 15 of reactor components, which you would call aging.
16 These are the principal safety 17 conclusions that we reached as a result of our 18 review. We found that the structures, systems, and 19 components that are important to safety continue to 20 be acceptable, and we can expect them to ensure safe 21 operation of the facility. We also concluded that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the licensee's management organization is acceptable 2 to maintain and operate the reactor safely.
3 The research programs at the reactor, 4 including a failure of those programs, will not pose 5 a significant risk to continued safe operation.
6 They do have limits in their technical 7 specifications that cover the experiment program, 8 and those limits were appropriately analyzed for 9 accidents.
10 We also concluded that routine exposures 11 will be below the limits in Part 20 for members of 12 the public and personnel at the facility, and there 13 won't be any releases to the environment in excess 14 of the concentration limits specified in Appendix B 15 to Part 20. And they also have provisions for 16 maintaining doses as low as reasonably achievable.
17 MEMBER CORRADINI: Just for my own 18 edification -- I should have asked the licensee, but 19 you probably know -- what is the curie content of 20 tritium residing in the reactor on a basis?
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1 total?
2 MEMBER CORRADINI: Yes, approximate.
3 MR. KENNEDY: I don't know that number.
4 We heard that the --
5 MEMBER CORRADINI: Or how about --
6 MR. KENNEDY: -- concentration limit was 7 five curies per liter of primary coolant.
8 MEMBER CORRADINI: Is it significantly 9 below that?
10 MEMBER SIEBER: Yes.
11 MR. KENNEDY: I would ask the licensee 12 to clarify that.
13 MR. BROWN: Dave Brown, Health Physics.
14 We are currently about 1.1 curie per liter.
15 MEMBER CORRADINI: How many liters do 16 you have? How many liters do you have in the 17 vessel?
18 MEMBER SIEBER: It is six feet by 12 19 feet, so --
20 MEMBER CORRADINI: So it is like about 21 100,000 curies.
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1 MEMBER BLEY: What are you just before 2 you discharge and start over again? How high does 3 it get?
4 MR. BROWN: Historically, anywhere 5 between one and a half to two and a half curies per 6 liter. It is about 100,000 pounds of D20 in the 7 system, so convert that, maybe 40,000 liters.
8 MEMBER SIEBER: Right.
9 MEMBER CORRADINI: Thank you.
10 MR. KENNEDY: Okay. And we also 11 concluded based on our review of the accident 12 analyses that the licensee has conservatively 13 considered a range of accidents, including a maximum 14 hypothetical accident that is bounding in its 15 consequences. And the radiological consequences of 16 this maximum hypothetical accident are below the 17 guidelines in Part 100, and actually well below the 18 limit for members of the public in 10 CFR Part 20.
19 I think total dose was around eight millirem, I 20 believe.
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1 of work done to update and get the tech specs into 2 conformance with the standard, and found -- we 3 concluded that those tech specs and the operating 4 license provide reasonable assurance that this 5 facility can be operated as it has been analyzed, 6 and that that won't lead to any adverse consequences 7 to public health and safety or the environment or 8 facility personnel.
9 And we also found that there has not 10 been any significant degradation of structures, 11 systems, or components related to safety, and the 12 surveillance requirements in the technical 13 specifications ensure that any degradation will be 14 caught in a timely manner and remedied.
15 MEMBER STETKAR: Can I ask about the --
16 this came up at a subcommittee meeting. We had a 17 few questions about surveillance requirements. I 18 wanted to ask you because the response that we 19 received from NIST explains a rationale. Is the 20 staff okay with the fact that NIST is essentially 21 taking a number of exceptions to the surveillance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 intervals specified in the ANSI ANS standards?
2 You know, for example, quarterly tests, 3 quarterly functional testing of pumps, they say, 4 well, once a year is good enough because their 5 experience is that they haven't had any pump 6 failures. And the staff is okay with that?
7 MR. KENNEDY: Yes. Not -- we are not 8 okay with it purely based on your statement that 9 they haven't had any pump failures, so let's extend 10 the surveillance requirement.
11 MEMBER STETKAR: But, I mean, you --
12 MR. KENNEDY: Based on other 13 considerations, including ALARA and the number of 14 redundant systems they have, the quarterly testing 15 -- annual testing I believe is what the new 16 requirement is, would be adequate.
17 MEMBER STETKAR: I just wanted to be 18 sure that you thought about that. I mean --
19 MR. KENNEDY: Yes.
20 MEMBER STETKAR: -- you can do --
21 MR. KENNEDY: Yes.
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1 MEMBER STETKAR: Okay.
2 MR. KENNEDY: And I had a discussion 3 while I was at the site for the seismic walkdown 4 about the emergency power surveillance requirements 5 or the backup power surveillance requirements. And 6 the diesel -- the diesel surveillance requirement is 7 in conformance with the standard. It is less 8 restrictive than their old surveillance requirement, 9 but it is in conformance with the standard.
10 And based on their operational 11 experience with the backup battery, the slow decline 12 in performance of that battery would be caught by 13 annual surveillance before it became an actual 14 issue. The battery is double the size it needs to 15 be, and the degradation is not a rapid process that 16 wouldn't be caught.
17 Not discussed here, but also in our 18 review, were the physical security plan and the 19 emergency plan. They were both found to be 20 acceptable. And, finally, we concluded that the 21 continued operation of this facility does not pose a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 significant risk to public health and safety, 2 facility personnel, or the environment.
3 In terms of the open item, it was a 4 timing requirement in their operator training and 5 requalification program. They simply changed that 6 requirement to be -- to meet the regulation. That 7 is all documented.
8 MEMBER SIEBER: Right.
9 MR. KENNEDY: If there are any other 10 questions about this new open item, I can briefly 11 address them. Otherwise, I think everything that we 12 know now has been said.
13 MEMBER STETKAR: I don't have any on the 14 additional ones, but I did have one that I wanted to 15 ask you. And this is -- I -- one of the questions I 16 had on the meteorological stuff was rain-over-snow 17 loading on the roof and how that analysis was done.
18 The response essentially says that the ASCE 19 requirements basically don't require you to add rain 20 loading as long as the expected snow loading is 21 greater than, whatever it is, 20 pounds per square NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 foot or something like that.
2 Now, I know historically the staff has 3 always required a rain-on-snow loading. What is 4 your position on that? Are you willing -- do you 5 accept the fact that -- essentially, what they are 6 saying is it doesn't make any difference how you do 7 the rain-over-snow loading, because basically they 8 are not required to do that according to the ASCE 9 standard, which is true if you read the standard.
10 MEMBER SIEBER: It has to meet the local 11 building code.
12 MEMBER STETKAR: It has got to meet the 13 local building codes, but I --
14 MEMBER BROWN: Right.
15 MEMBER STETKAR: -- know in other types 16 of licensing applications the NRC staff has 17 required, despite that, that you have to put the 18 rain on top of snow. So it is --
19 MEMBER BLEY: Which nature does.
20 MEMBER STETKAR: Which nature does also.
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1 the nature of that. So I was just curious whether 2 the -- if their essential statement that they don't 3 really need to do that, and, therefore, however they 4 add the rain doesn't make any difference is -- is 5 kind of an acceptable position to the staff.
6 MR. KENNEDY: Well, if they hadn't 7 provided that in the application, if they had just 8 provided the standard in the application and we 9 reviewed that, that would have been acceptable.
10 MEMBER STETKAR: That would have?
11 MR. KENNEDY: According to our guidance, 12 yes.
13 MEMBER STETKAR: Okay. Thanks. That is 14 all -- that is basically what I was asking.
15 MEMBER SIEBER: That is the requirement, 16 and you have met the requirement.
17 MR. KENNEDY: Once I saw their -- that 18 statement in their response to our RAIs to address 19 your concerns, I felt that what they had done 20 originally was a conservative analysis and 21 acceptable.
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1 MEMBER STETKAR: That is true. And the 2 reason I didn't ask them about the analysis is I 3 just wanted to make sure the staff was okay with 4 just meeting the standard, because I am familiar 5 with other applications where people have made that 6 argument and the staff has come back and said, 7 "Well, that is not the way we want you to do the 8 analysis." So thanks. That is it. I am happy.
9 MR. KENNEDY: That is all I have, unless 10 there are other questions.
11 MEMBER SIEBER: Okay. We are running a 12 little bit behind. I appreciate the work that the 13 applicant has done, and also the staff. In my 14 tenure with the ACRS, that is one of the nicest jobs 15 I have had dealing with both the applicant and the 16 staff, and very interesting.
17 I think that both have been thorough in 18 the performance of the update of the FSAR, and the 19 rethinking of some of the accident analysis where 20 there was questions, and also in the development of 21 the technical specifications. And so I thank all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 for the effort that has been placed to this project.
2 And with that, Mr. Chairman, I turn it 3 back to you, just a minute or two late.
4 CHAIRMAN BONACA: No, just on time.
5 MEMBER SIEBER: Okay.
6 CHAIRMAN BONACA: We will take a break.
7 Come back at 2:45.
8 (Whereupon, the proceedings in the foregoing matter 9 went off the record at 2:29 p.m. and 10 went back on the record at 2:46 p.m.)
11 CHAIRMAN BONACA: Let's resume the 12 meeting.
13 The next item on the agenda is the draft 14 final Regulatory Guide 1.211, Qualification of 15 Safety-Related Cables and Field Splices for Nuclear 16 Powerplants. And Otto Maynard will take us through 17 the presentation.
18 MEMBER MAYNARD: Thank you, Mr.
19 Chairman.
20 I never thought cable qualification 21 could be so exciting until I got this --
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1 (Laughter.)
2 We previously reviewed this subject last 3 September, and during that meeting some of the 4 members questioned the scope. We had some questions 5 on things, and there was also a little bit of 6 confusion over some of the changes, and that wasn't 7 necessarily all the staff's fault; it was the 8 documents we were looking at. So we thought it best 9 to come back and discuss it at a future meeting, so 10 that is what we are here today for.
11 We will be hearing from the staff, and 12 then we also have comments from NUGEQ. I think all 13 of you got a copy of the letter from NUGEQ on the --
14 some of the issues and concerns that they had, so we 15 will be hearing from them at the end of this 16 meeting, too. So I want to make sure we leave time 17 at the end.
18 A couple of things I will point out that 19 at least from what I read has changed, and the staff 20 and NUGEQ can both correct me if I am wrong. One of 21 the key things on the position of condition NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 monitoring, the scope has changed. That is one of 2 the areas that we -- some of the members have 3 questioned a subset of risk-significant, safety-4 related. And I believe now the scope is for 5 basically what is in the maintenance rule.
6 And I also want to just point out, as we 7 are listening to the staff here, and then get to the 8 NUGEQ, the NUGEQ is challenging the need for the 9 condition monitoring, whether the data really 10 supports the need for that, and also the scope of --
11 we thought the original scope that the staff had was 12 better than what it is now, and then also the 13 special condition monitoring, that it lacks some 14 specificity, it is pretty broad.
15 So we will be hearing more about that, 16 and we will be hearing more from the staff. So 17 right now I will turn it over to the staff to begin 18 their presentation of Reg. Guide 1.211.
19 MR. AGGARWAL: Mr. Chairman, and the 20 members of the Committee, good afternoon. As 21 pointed out to you, the staff is here to make a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 presentation to you on Reg. Guide 1.211, with the 2 expectation the Committee will agree with the 3 position taken by the staff and look forward to 4 receiving a letter.
5 Let me point for a moment -- recap a 6 little background about this reg guide. As you 7 aware, the IEEE Standard 383, first time was issued 8 in 1974, and for 30 years actually nothing was done.
9 IEEE worked on this previously. They issued a 10 standard in 2003, which in my opinion, in the 11 staff's opinion, is a much-improved standard, and it 12 actually meets the NRC requirement.
13 As you know, often these standards being 14 a process of society, they want to write the best 15 standard. Sometimes it happens that we may take an 16 exception if we feel that the information given in a 17 given standard is not enough. This is how we took 18 the exceptions in this particular standard, which I 19 will talk to you very briefly.
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1 have taken 10 exceptions to the IEEE standard. We 2 received five comment letters from five different 3 organizations. And, as you know, we met with you on 4 September 4th and made a presentation.
5 Now, I would also like to point out 6 again that this is Standard 383. To improve the 7 standard, the whole thing is based on testing of 8 non-prototype cable. As you know, in a given week 9 at a powerplant you use thousands and millions of 10 feet of cable, and often a manufacturer will qualify 11 a given cable based on the standard. And then, many 12 times they will allow -- they use the same analogy 13 to qualify by analysis cables of different kinds.
14 The bottom line is there is only one 15 prototype for a given cable, and that is all this 16 standard is limited to. Okay?
17 Next one.
18 Now I would like to address some of the 19 questions which were raised at the meeting in 20 September with the ACRS. The first question was 21 raised that -- provide the definition of "risk-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 significant, safety-related cable." The Committee 2 found that there was no precise information 3 available, and the staff agreed. We went and looked 4 in a number of regulations. The term is not really 5 very precisely defined.
6 Therefore, the staff decided to remove 7 those terms and said, okay, let them use the term 8 which is commonly understood for years, and we ran 9 -- okay, let's go back to the maintenance rule. So 10 what we are saying, only those safety-related cable, 11 cables -- safety-related cable, not non-safety-12 related cable, only the safety-related cable which 13 falls under the maintenance rule should be the scope 14 of the guide.
15 Again, the licensees expect you will --
16 is supposed to know where the hottest spots are in 17 these plants, and he can only know that by knowing 18 the monitoring of radiation and the temperature.
19 Once they know, so they can focus on those safety-20 related cables, which are in those hottest parts.
21 Based on that --
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1 MEMBER APOSTOLAKIS: Do you mean the 2 safety-related -- all the cables that are part of 3 the safety-related system are themselves safety-4 related? Is that what these safety-related cables 5 are?
6 MR. AGGARWAL: After they had determined 7 -- defined that in 50.49, and essentially it tells 8 you that, again, what I am saying it is in the 9 maintenance rule, have safety-related cables plus 10 non-safety-related cables. This guide is going to 11 address only safety-related cable.
12 MEMBER APOSTOLAKIS: The maintenance 13 rule actually identifies safety-related cables?
14 That's -- I don't --
15 MR. KOSHY: Safety-related is those 16 systems that are relied on for accident mitigation 17 and the whole definition of --
18 MEMBER APOSTOLAKIS: I understand that.
19 MR. KOSHY: But the maintenance rule has 20 safety-related and more in it. But what we are 21 saying is the subset of the maintenance rule cable, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 which are also classified as safety-related, are 2 within the scope of this reg guide.
3 MEMBER SHACK: So you really do mean 4 "and." You want safety-related and covered by the 5 maintenance rule.
6 MEMBER APOSTOLAKIS: Yes.
7 MEMBER MAYNARD: So this is really very 8 close to the same scope that you had before. Before 9 you called it risk-significant safety-related. Now 10 you are saying the maintenance rule that are safety-11 related.
12 CHAIRMAN BONACA: And it is important.
13 MEMBER STETKAR: Just to make sure I 14 understand, things that come up in license renewal 15 are underground cables that provide a station 16 blackout recovery function, which are typically non-17 safety-related cables. Those would not be covered 18 by this, is that correct?
19 MR. AGGARWAL: That is correct.
20 MEMBER STETKAR: Okay.
21 MEMBER BROWN: Say that again.
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1 MEMBER MAYNARD: Please.
2 MEMBER STETKAR: You want me to say that 3 again?
4 MEMBER BROWN: Exactly.
5 MEMBER STETKAR: Well, I don't know if I 6 can say it exactly, but in license renewal 7 applications there have been questions regarding the 8 monitoring of cables that are non-safety-related 9 cables, but that are in scope for license renewal 10 because they provide the function of station 11 blackout recovery. In many cases, those cables are 12 routed underground, and we have had those problems 13 in manholes.
14 Those particular types of cables in 15 those functions would not be covered by this 16 regulatory guide.
17 MR. KOSHY: We cannot say all of it, but 18 some of it may fall into this category, because 19 that --
20 MEMBER STETKAR: If they are not safety-21 related cables.
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1 MR. KOSHY: If they are not safety-2 related and not in maintenance rule, then it --
3 MEMBER STETKAR: No. Be careful, 4 because if they are not safety-related as I -- that 5 is why I am trying to understand the logic of this.
6 If they are not safety-related --
7 MR. KOSHY: It is out.
8 MEMBER STETKAR: -- it is out. Even 9 though the maintenance rule would call them risk-10 significant.
11 MR. KOSHY: Yes.
12 MEMBER APOSTOLAKIS: So it may be 13 limited.
14 MR. AGGARWAL: So based on what we just 15 discussed, the position was changed as you see in 16 yellow highlighted, the words were added. The 17 condition monitoring of safety-related cable may be 18 related to this -- covered by --
19 MEMBER SHACK: Why do you leave out the 20 risk-significant cables that aren't safety-related?
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1 had a lot of discussion last time in September, and 2 the issue basically was that -- how do you define 3 "risk-significant"?
4 MEMBER MAYNARD: There is a concern of 5 mixing the two, because typically risk-significant 6 isn't just limited to the safety-related part.
7 MEMBER RAY: Yes, but he is right.
8 There isn't a definition.
9 MEMBER MAYNARD: Right.
10 MEMBER BLEY: But 50.69 sets up the 11 alternative policy to use that definition.
12 MEMBER RAY: It does. That is right, 13 Dennis. But the problem is that stuff that is not 14 safety-related but is within the scope of the 15 maintenance rule is what you are --
16 MEMBER SHACK: 50.69 is a voluntary 17 rule.
18 MEMBER RAY: That is where I was gong.
19 MEMBER SHACK: But the maintenance rule 20 is somewhat similar in scope to 50.69, and is 21 certainly part of the regulations that everybody --
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1 you know, so it -- that certainly seems to me to 2 give you a way to define "risk-significant."
3 MEMBER RAY: But it can't impose 4 requirements for equipment qualification on stuff 5 that is not safety-related merely because it is 6 inside the maintenance rule. I mean, you know, you 7 are talking about a huge issue here that -- you 8 know, where the industry thinks it is well 9 established. The maintenance rule imposes 10 requirements on non-safety-related stuff, but the 11 requirements are limited.
12 What the yellow ones to me do is they 13 say something that is safety-related but not covered 14 by the maintenance rule is excluded. And I was 15 going to ask: well, what is that?
16 Well, wait a minute, what I said was 17 simple.
18 MEMBER SHACK: No, no, I understand what 19 you said.
20 MEMBER RAY: Okay. And I am just 21 saying, well, why would you have something that is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 safety-related and not covered by the maintenance 2 rule that you don't want to include within this reg 3 guide? Because that is what the words said to me 4 when I read them.
5 MEMBER CORRADINI: So you are asking, is 6 that the null set, or is there actually something 7 out there?
8 MEMBER RAY: Yes.
9 MEMBER MAYNARD: Let's let him -- one 10 conversation here at a time. Do you have -- you 11 asked a question.
12 MEMBER RAY: Well, I did ask a question.
13 I made a statement, but there is a question 14 implied. The statement is, the words to me said, if 15 you've got something safety-related not covered by 16 the maintenance rule, then the reg guide doesn't 17 apply to that step. The implicit question is: is 18 that correct? Is that what you intended? Because 19 that is not what I heard him say.
20 What I heard him say was this covers 21 everything that is in the maintenance rule that is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 safety-related.
2 MEMBER ARMIJO: Right. That is what I 3 heard.
4 MEMBER RAY: Well, that is only the 5 other side of the coin, Sam. I mean, if it covers 6 -- if it is safety-related within the maintenance 7 rule, then it doesn't cover stuff that is safety-8 related not within the maintenance rule.
9 MEMBER MAYNARD: As I interpreted what 10 you have written and what you have said is that we 11 are dealing with a subset of safety-related. It is 12 not all the safety-related. It is only the safety-13 related that are within the maintenance rule.
14 MEMBER RAY: Correct. And I would just 15 ask the question, then, what is not in the 16 maintenance rule that is safety-related?
17 MR. KOSHY: Let me give you a quick 18 example. For example, the feedwater system is 19 falling within the maintenance rule, but it is not 20 considered safety-related.
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1 not within the maintenance rule? That is the 2 question.
3 MR. KOSHY: Feedwater system.
4 MEMBER RAY: It is safety-related?
5 MR. KOSHY: No. Feedwater system is 6 non-safety-related but within maintenance rule.
7 MEMBER RAY: My question is: what is 8 safety-related but not within the maintenance rule?
9 MR. AGGARWAL: Nothing.
10 MEMBER RAY: Nothing. And that is what 11 this is saying to me is, if it's safety-related and 12 not in the maintenance rule, then it is not covered.
13 That is what the words say. You are telling me 14 what you intended was if it is within the 15 maintenance rule in safety-related it is covered.
16 Why don't you just say if it's safety-related and in 17 there.
18 MR. AGGARWAL: That's what I --
19 MEMBER RAY: I mean, that eliminates the 20 confusion that we are all having here.
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1 Research. I think -- Mr. Ray, how are you?
2 MEMBER RAY: I'm fine.
3 (Laughter.)
4 MR. RICHARDS: I think the idea here was 5 to go look for a widely used definition, and we 6 looked at the maintenance rule and said, okay, here 7 is a whole scheme of things that is already laid out 8 in the regulations that has been widely addressed by 9 the industry, so the industry will know what is 10 covered by this definition. And I think the 11 challenge was, what does "safety-significant" and 12 "safety-related" mean? That was what we had before.
13 Now we've gone to a definition that the 14 industry I think is comfortable with, and we have 15 excluded the non-safety items that are addressed by 16 the maintenance rule. So, to answer your question, 17 you know, we went looking for a good definition that 18 was pre-existing. We didn't really take it that 19 next step to figure out, well, you know, what is 20 excluded by this.
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1 that. I was only trying to establish that -- didn't 2 you end up with just the safety-related stuff? What 3 does reference to the maintenance rule add to --
4 MR. RICHARDS: It points to a pre-5 existing program for which there is a long history 6 of what is in it and what is not.
7 MEMBER BLEY: Safety-related is even 8 older than that.
9 MEMBER RAY: Okay. I give up. To me, 10 you are talking about what is safety-related, and 11 that is the set that you are referring to. The 12 maintenance rule has us all confused, but it doesn't 13 seem to add anything. But with that I will just 14 quit repeating myself.
15 MEMBER BROWN: No. You shouldn't quit 16 repeating yourself, because --
17 MEMBER MAYNARD: Is it your opinion or 18 position that still all the safety-related cables 19 are covered by this condition monitoring?
20 MR. AGGARWAL: Correct.
21 MEMBER ARMIJO: That is your intention.
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1 MEMBER MAYNARD: So I think what they 2 saying is this applies to safety-related cables.
3 MEMBER BROWN: I do, too. But I am --
4 MEMBER MAYNARD: So I think we are 5 struggling with why do we even bring in the 6 maintenance rule aspect. Why don't we just say 7 "safety-related cable"?
8 MEMBER BLEY: I guess I'm -- I just went 9 back and looked at 50.65, and it says safety-related 10 SSCs, and then it qualifies which ones. So I don't 11 know of any, but maybe there are some that don't 12 meet those qualifications.
13 MEMBER RAY: No, that's right. I am not 14 an expert in plant design, so --
15 MEMBER SHACK: I mean, certainly we know 16 if you look at 50.69 there are safety-related 17 components that are not risk-significant. Whether 18 they are cables or not I -- you know, I would 19 suspect that varies from plant to plant. I don't 20 know. So I think this, in fact, could limit the set 21 somewhat.
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1 MEMBER RAY: In principle.
2 MEMBER SHACK: In principle, it could.
3 MEMBER RAY: Yes.
4 MEMBER SHACK: But if their intent is to 5 cover all safety-related cables, then --
6 MR. KOSHY: Yes. The very title is 7 qualification of safety-related cable, how to 8 qualify if it is doing a safety-related function.
9 MEMBER RAY: But I am with everybody 10 else, why bring in the maintenance rule if that's 11 what you want?
12 MR. AGGARWAL: I will concede if the 13 committee recommends to drop that into maintenance 14 rule, we will do so, and simply say "safety-related 15 cables."
16 MEMBER RAY: That is what you mean. It 17 would be okay to exclude some safety-related stuff 18 that is not covered by the maintenance rule 19 probably. And if that is what you meant, then fine, 20 that is what --
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1 does give a qualification. I don't know what is in 2 the qualification. I mean, I know what --
3 MEMBER MAYNARD: Well, why don't we --
4 this is an area we may want to come back to later.
5 Let's go ahead and move on. And after we get 6 through the rest of it, we will see if we want to 7 come back and talk a little bit more about this. So 8 let's go ahead and move on.
9 MEMBER BROWN: Well, the only question I 10 thought -- there is still disagreement somewhere on 11 whether you should even have condition monitoring at 12 all, isn't there? If you read some of the other 13 paper, there is --
14 MEMBER BLEY: Yes.
15 MEMBER BROWN: Okay. We will get to 16 that later?
17 MEMBER BLEY: The disagreement is not at 18 the staff level. It is --
19 MEMBER BROWN: I understand. I 20 understand that, and I -- I've got some other 21 questions I wanted to address on that. Go ahead.
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1 MR. AGGARWAL: One of the other 2 questions which was raised by ACRS was again on this 3 code, and we just discussed we really meant safety-4 related cables, and this is wrong.
5 Next?
6 One of the questions that was raised, 7 again in the September meeting, are the cables 8 covered under Appendix R? Are they within the scope 9 of this guide? And the answer is no. The 10 requirements for Appendix R are somewhat different 11 as compared to this requirement for qualification of 12 cables for low power environment, to a different 13 issue. And for reference we have pointed out here 14 that -- there the requirements for Appendix R are 15 included.
16 The bottom line is for purposes of this 17 reg guide requirement for Appendix R not covered by 18 this reg guide.
19 MEMBER BROWN: But this reg guide is 20 just not -- "condition monitoring" means go off and 21 monitor this, the environment in which these cables NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 are, for the life of their application. So this is 2 more than just qualification of cables. This is 3 actual plant requirements on the licensees over the 4 40-year or 60-year life of the application.
5 So it is more than just qualification, 6 so I would just take an issue with the point -- the 7 difference between fire -- that fire doesn't cover 8 qualification. Well, this also has non-9 qualification attributes in it also. That is -- I 10 was quibbling a little bit, but it is clarifying.
11 MR. KOSHY: The IEEE Standard 323, even 12 the recent version, includes monitoring the 13 qualification as part of the qualification process.
14 That is how the industry has addressed that issue, 15 in the sense --
16 MEMBER BROWN: For fire.
17 MR. KOSHY: No, for qualification. IEEE 18 323, 2003 version, which we are going to endorse, 19 and we have endorsed the previous version already.
20 That is -- considers maintaining qualification as 21 part of the qualification process itself. And, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 therefore, monitoring falls into the same 2 qualification standard.
3 MEMBER BROWN: To ensure you don't 4 exceed the qualification environment.
5 MR. KOSHY: The assumptions -- you are 6 within the assumptions, and that is what the 7 industry chose to go with. And chances are when we 8 endorse it we will be considering the endorsement in 9 the full scope of the standard itself.
10 MEMBER BROWN: That is in 323?
11 MR. KOSHY: Yes.
12 MR. AGGARWAL: That is the model 13 standard.
14 MR. KOSHY: That is a model document for 15 all standards. And this is -- you can -- this 16 standard you can see it as a daughter standard, 17 focusing just on cables. 323 addresses the 18 qualifications at large for all -- all components.
19 MEMBER MAYNARD: And I do think that is 20 important to note. This isn't the only requirement 21 dealing with condition monitoring and with equipment NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 qualification. This is specific to the cables. It 2 does fall under other standards, and there are other 3 requirements.
4 Okay. Let's move on.
5 MR. AGGARWAL: Okay. The next concern 6 the Committee has, they wanted us to justify the 7 need for protecting specialty cable with connectors 8 for tri-axial and bi-axial. That position has been 9 removed from the reg guide.
10 MEMBER ARMIJO: Why did you remove it?
11 All we needed -- we asked for a justification. We 12 may have agreed with you, but we --
13 MR. AGGARWAL: We conceded the standard 14 adequately covers, so we didn't have to take an 15 exception.
16 MR. KOSHY: But what you will also see 17 is that in the discussion part we have shared the 18 thought that in some specialty cables, some must be 19 tested with this respective connector. It may not 20 work very well, in the sense if you separately 21 qualify the connector and the specialty cable NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 separately, when you put it together you find that 2 functionally it may fail.
3 So that thought is shared in the 4 discussion part, but we did not go to the extent of 5 saying that in every case you shall test it like 6 that. So that is where we backed out and said, 7 okay, we have shared that concern, and now the 8 industry knows it. And the standard also talks 9 about the same discussion, so that should be 10 adequate, rather than addressing another exception.
11 MEMBER ARMIJO: Was that issue of the 12 cables and the connectors addressed? Is it 13 addressed in some other regulation, in some other --
14 MR. KOSHY: No, it is not.
15 MEMBER ARMIJO: So, if it is a real 16 problem, why isn't it?
17 MR. KOSHY: Okay. It is a real problem, 18 but it may not be widespread, in the sense what we 19 know of is certain connectors and certain cables, 20 when separately qualified and put it together, it 21 didn't work right. But that is not a generality, in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the sense all cases are not like that. So we shared 2 that thought in the discussion part, and we left it 3 rather than going for a specific example.
4 MEMBER ARMIJO: And you said that point 5 is also raised in the standard.
6 MR. KOSHY: That point is discussed, and 7 it's in the standard also, yes.
8 MEMBER BLEY: But it is not a 9 requirement to test it.
10 MEMBER ARMIJO: Well, maybe we will ask 11 the industry guys whether they believe it is 12 significant or not.
13 MR. KOSHY: And, you know, as we 14 progress in testing, if we come across cases, we had 15 -- the other method would be to issue an information 16 notice stating, okay, in this particular application 17 we find this to be available, and let the industry 18 know about it.
19 MR. AGGARWAL: So, finally, the issue 20 was raised with regard to that the staff has not 21 specified or offered any specific condition NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 monitoring techniques. And the requirement of 2 condition monitoring is imposed without any 3 condition monitoring techniques.
4 Let me now address that issue. My 5 position is that the staff continues to believe that 6 condition monitoring is required and must be 7 implemented. And the reason is that that is -- as 8 was stated previously, all we do is do one prototype 9 testing, and that test, whether it is in Plant A or 10 Plant B or C, that test is used not only in U.S.A.
11 but all over the world, to focus attention that one 12 prototype, one cable, is tested, and you come back 13 that, hey, I don't want to do anything for 40 years.
14 The staff thinking is not acceptable.
15 And this is also based on our operating 16 experience, particularly includes the power cable.
17 Therefore, the staff is saying that there are 18 probably 14 techniques available for condition 19 monitoring now. We are not in a position at this 20 time to tell you that Technique A, B, or C, you are 21 leaving to licensee that you can put any technique NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 which may fit to the type of the cables you have or 2 the environment you are exposed to, and take a lot 3 of factors.
4 The bottom line is that we require that 5 you do something other than test the cable, and the 6 cable is good for 40 years, 60 years, and some 7 plants are now thinking to go 80 years. So you need 8 to know in your plan really how these are. You 9 should know the temperature, you should know the 10 radiation, and, once you know, then you should have 11 simple walkdowns, or use any appropriate techniques.
12 I may also point out that the staff and 13 the international community at this time is working 14 to focus on different matters of condition 15 monitoring. And we may be back before this 16 Committee some time in the near future when we may 17 specify that this kind of technique for this 18 particular type of cable is appropriate. For the 19 time being, the staff is submitting that, hey, we 20 would like something to be done, and it is up to the 21 licensee to pick any technique. They can pick what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 they think is best justified.
2 With that, I conclude.
3 MEMBER RAY: This is a reg guide. How 4 does it get implemented in the way that you have 5 just now been talking about it?
6 MR. AGGARWAL: Very good question. You 7 are 100 percent. Reg guides are advisory. And not 8 only that, it is voluntary. If you are in an 9 operating plant, you don't have to use this at all.
10 MEMBER RAY: If you are what?
11 MR. KOSHY: If it is an operating plant.
12 MEMBER RAY: Oh, okay.
13 MR. KOSHY: It is voluntary. But for 14 new licensees, they need to address all of the reg 15 guides.
16 MR. AGGARWAL: They are expected to 17 attend.
18 MEMBER RAY: Understood.
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1 condition monitoring will be done.
2 MEMBER RAY: Okay. So this isn't going 3 to have a big impact on the existing operating 4 plants, except those who voluntarily follow the 5 guidance.
6 MR. AGGARWAL: Correct. They don't have 7 to do anything at all.
8 MEMBER RAY: Okay. No, I understand.
9 MEMBER MAYNARD: Well, the existing --
10 they don't have to do anything relative to this.
11 They have to meet whatever their current commitments 12 are.
13 MEMBER RAY: Yes. They --
14 MR. AGGARWAL: However, I must caution 15 you that a nuclear powerplant -- suppose they decide 16 to change the system in entirety on their own, okay?
17 Not that NRC is asking, but they decided to change 18 their whole RPS system, for example, then they must 19 comply with this reg guide, because this is a change 20 in the system.
21 MEMBER RAY: Well, okay.
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1 MEMBER MAYNARD: You said that later you 2 may have -- well, one of the questions relative to 3 this, and I think we will be hearing more from NUGEQ 4 on this, is the broadness of this without much 5 specifics on exactly what to be done. And that is a 6 two-edged sword.
7 You mentioned that you may come back 8 later with more specifics as to what types of 9 monitoring are appropriate in what cases. Would 10 that be like a revision to the reg guide or --
11 MR. AGGARWAL: It could be.
12 MEMBER MAYNARD: -- how would that be 13 done?
14 MR. AGGARWAL: It could be test revision 15 on a new reg guide.
16 MR. KOSHY: There are two things in the 17 works. One is our research is working with one of 18 our national labs to look at the essential elements 19 of the cable test program. That is actually 20 possibly -- the draft reg guide should be coming out 21 by the end of the year. They have just finished NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 their initial work. We saw some initial reports, so 2 that is coming, to essentially explain the essential 3 elements of a test program.
4 The second part which Satish referring 5 to is the -- these techniques are gradually getting 6 refined. We know of one technique developed in the 7 Haldon project which is -- looks very promising. It 8 has been tested in about four nuclear stations 9 overseas, three of the Swedish plants, and I forgot 10 the other name. And they find that to be one test 11 that is suitable for all types of cable. That is 12 the first one of its kind.
13 And so far all of their tests have been 14 very successful, and it is able to measure the 15 insulation all the way to the full run of the cable.
16 And within their country EPRI also has experimented 17 with the same technique, and their report is that it 18 looks very promising.
19 So what I am hoping is in the near 20 future we should be able to -- if this test is one 21 -- one for all, it will be a great success. If not, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 we may have to look at a couple more and present a 2 reg guide explaining why this is the most suitable 3 way to go.
4 In the meantime, there are three IEEE 5 standards which essentially talk about all of the 6 best techniques that are in the market now, and 7 giving level of clarification as to which technique 8 is best suited for which type of cable. So there 9 are three IEEE standards in the works already.
10 We are holding off an endorsement 11 because of the -- see this industry work that is 12 progressing, and we hopefully looking at this one 13 technique that may be applicable to all types of 14 cables.
15 MEMBER BROWN: Okay. I want to -- a 16 little more calibration and then a question.
17 Condition monitoring -- there is two things called 18 out in this, environmental condition monitoring 19 whereas -- and I presume -- and then condition 20 monitoring. These are -- so you've got two --
21 there's two aspects to this.
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1 So as far as the environmental, I am 2 just trying to understand it. Wherever the cables 3 run, if they are in a space, you should have 4 cognizance monitoring of that space -- its 5 temperature, radiation, whatever the appropriate 6 parameters are -- so that you know now the 7 environment in which whatever cables are in there 8 are enduring, and you an evaluate that relative to 9 their qualification status.
10 Second is what I would -- condition 11 monitoring. That is tests of the cable, like megger 12 tests, hi-pots, time domain reflectometer test, you 13 know, impedance measurement, whatever the heck they 14 are for co-ax, etcetera. And I am just reflecting 15 back on some experience.
16 The last thing I ever wanted to do was 17 take cables apart. Every time I took cables apart 18 and put them back together I ended up with loose 19 connections somewhere. Okay? So I've got kind of a 20 very jaded thought process. If you have to do it 21 every now and again, what type of periodicity are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 you talking about relative to making these -- and 2 there is a second piece of this -- this condition 3 monitoring, are you talking about every year, every 4 10 years, every shutdown for refueling? Is there 5 something in your mind relative to that?
6 Second question related to this is, most 7 of the cables that are safety-related are actually 8 energized in performing their function. For 9 example, neutron detectors, pressure detectors, 10 temperature detectors. And you are reading those 11 all the time. Motors are running, all kinds of 12 stuff like that. So you know that they are working.
13 Now, lights, you know, cables that go 14 off to something that is intermittently on, you 15 don't know what their status is at any time, unless 16 the light is on all the time, which is a different 17 circumstance. So do you -- there is no 18 differentiation in here in terms of cables which are 19 continuously energized with a visual evidence of 20 their application in work? Or is it just cables --
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1 that are not in a state where you can know what 2 their operational mode is?
3 MEMBER RAY: That is a harsh environment 4 qualification.
5 MEMBER BROWN: Well, I mean, go through 6 -- you know, the harsh environment is where you have 7 a -- I mean, cables are in radiation environments, 8 and I just didn't -- co-ax cables, and I didn't go 9 take them apart, just --
10 MR. KOSHY: We are trying to gain 11 assurance that these cables can in fact withstand a 12 LOCA environment to the accident, so that we are 13 confident of the information that comes into the 14 control room and the actions that we need to take.
15 So the fact that it is functioning now 16 is not an assurance that it can survive a LOCA 17 environment. And the next part about the 18 environment that -- the question that you addressed, 19 too -- during the qualification process, we make 20 some assumptions on what is the probable environment 21 in its operating life -- for example, a certain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 level of radiation and certain level of temperature 2 condition.
3 And in the test process we tried to 4 integrate it and accelerate its aging, bringing it 5 to its end of life and then expose it to an accident 6 radiation. That is --
7 MEMBER BROWN: I saw that. Yes, I got 8 that part.
9 MR. KOSHY: Okay. Now, so the fact that 10 it is functioning now gives me assurance that under 11 fair conditions it is functional. But if I am to 12 have an accident, and parts of the cable is exposed 13 to this extreme environment, would it still do it 14 with the same level of, you know, conductivity and 15 lack of leakage current through that accident?
16 Because that affects my setpoints and the 17 preciseness of the signal that I am expecting.
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1 assumptions. Speaking from operating experience, 2 these days we come across a problem only if it 3 fails. For example, in some thermal lagging on a 4 steam pipe, it was removed to enter into the update 5 early and so some of the fire work. That heat 6 dissipation was so much on the cable, the MO, it 7 stopped functioning.
8 Then, we noticed -- looked into it 9 earlier and found out that insulation had completely 10 hardened, and it was breaking. So what we noticed 11 in the normal operating experience is only when 12 things are crossed far beyond to the extent they are 13 failing, or we catch it in the next surveillance.
14 So in looking into the safety 15 significance, what we are hoping is this program 16 will give us reasonable assurance that this cable 17 can function through the accident environment and 18 serve its safety function. That is why we are going 19 this far to say that you need to do additional 20 testing to make sure that the insulation is 21 remaining intact to serve its function.
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1 MR. AGGARWAL: Let me also add that it 2 is not the staff's intention that licensees remove 3 all the cable, dismantle, only doing for condition 4 monitoring. We are expecting them to use their 5 judgment, and pick some selective cables, and the 6 given technique that is useful for the plant.
7 We totally agree with you that 8 dismantling cable, connecting them back, will create 9 more problems. But they are techniques available 10 now while the cables are energized and operational 11 you can use relative to the techniques.
12 MR. KOSHY: And you had one more 13 question regarding the frequency. We stated in the 14 reg guide that condition monitoring and its 15 frequency may be adjusted based on the cable 16 performance. For example, if I am buying a cable 17 now, the cable chemistry is so good, if I took a 18 baseline data, in about probably five to seven years 19 I don't have to look at it at all. I take annual 20 reading at, let's say, five years or seven years. I 21 will find that the rate of degradation is very low.
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1 I will endure only for the next 10 years.
2 So, in a sense, you can adjust your 3 frequency based on what you read from this test 4 program. But if you see a serious degradation, we 5 expect the frequency to become closer, by the same 6 token.
7 MEMBER BROWN: Well, the techniques I 8 have experienced that have had wide -- that have 9 wide variability in application. So that your data 10 trending is hard.
11 MR. KOSHY: Well, we are hoping they 12 will dwell on the same techniques, so that you can 13 --
14 MEMBER BROWN: Are you using the same 15 technique, whether it's a megger test or whether 16 it's a time domain reflectometer, to make sure 17 you've got continual continuity, the level of 18 continuity you want on certain types of co-ax 19 cables, things of that nature? Those are -- you 20 don't get the nice, you know 1.0 times 106 every 21 time. They bounce around, so --
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1 MR. KOSHY: We can limit some reasonable 2 radiation, so long as, you know, your outages kind 3 of reflect the same way on cables of comparable, 4 let's say, average and also application. If it is 5 exhibiting certain level of difference, you can 6 eliminate some of those questions.
7 But, you know, if you see a gross 8 difference, that is an early indication that 9 insulation is seriously degraded. And we want 10 licensees to be prepared to attend to it, rather 11 than finding out later that this is not working.
12 MEMBER BROWN: Are megger tests on your 13 list?
14 MR. KOSHY: We were not going to supply 15 a list in --
16 MEMBER BROWN: No. Is that one of the 17 14 techniques?
18 MR. KOSHY: If it -- yes, it is one of 19 them, and they cannot use that -- the lowest one of, 20 you know, unrolled megger for doing that testing.
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1 take a 5,000-volt megger on a 5 kV system, whatever 2 it is, and you will find -- depending on all types 3 of conditions, you will get numbers from one meg-ohm 4 to 100 meg-ohms or 100 gig-ohms over a five-year 5 period. And I don't know what you are going to do 6 with this.
7 MR. RUSSELL: This is George Russell, 8 NRR. I have -- Tom Koshy in Research is writing, as 9 he stated earlier, the effective characteristics of 10 a cable monitoring program. We don't want just one 11 test. You are going to have to evaluate what type 12 of cables do you have in your plant, and do a series 13 or a combination of tests.
14 To answer your other question, there is 15 methods out right now that provide a pretty good 16 trending, such as partial discharge and tan delta, 17 but they are using them for power cables and they 18 are doing correlation curves and deciding when to 19 replace the cables.
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1 will give that, so -- for certain types of cables.
2 So there already is methods out there that I can 3 trend and make a choice through a correlation curve 4 when I am going to replace the cable. So there is 5 methods right now that the utilities are utilizing, 6 and several of them in the southeast part of the 7 United States have -- they are trying to perfect the 8 tan delta, and there are several companies going 9 after partial discharge.
10 I understand with your megger, but we 11 are not talking about just doing a megger, we would 12 like to see a correlation of tests based on the 13 cables that you have. And then, you can get your 14 trend.
15 MEMBER MAYNARD: The way I read the reg 16 guide, at this point you are not specifying a 17 frequency or a test. You basically do something.
18 And as long as it is even close to reasonable at 19 this point you would be accepting that. But at some 20 time in the future you may be coming out with 21 another reg guide or whatever to get some --
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1 MR. KOSHY: And we will build confidence 2 on certain techniques that we can say, okay, this is 3 the way to go.
4 MEMBER MAYNARD: So you are not saying 5 that people have to disassemble cables or whatever.
6 They can take a look on a case-by-case basis and 7 what they --
8 MR. AGGARWAL: Exactly.
9 MR. KOSHY: Some of these techniques --
10 you know, like if you have a break in one and the 11 opening on one side of the cable is sufficient for 12 running the test. And especially the one technique 13 that I was referring to -- is referred to as LIRA, 14 Line Impedance Resonance Assessment.
15 They are also experimenting on doing 16 that on live wire in the sense not at all 17 disconnecting, but just attaching two patches to the 18 end and running the signal.
19 MR. AGGARWAL: And the cables are 20 energized.
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1 energized, yes.
2 MEMBER MAYNARD: And at this point, you 3 are not really -- although some of the plants and 4 some of the utilities may be doing some research and 5 developing new plants, you are not really asking 6 anyone to go beyond the current state of knowledge 7 or capability.
8 MR. AGGARWAL: Correct. Yes.
9 MEMBER MAYNARD: I think we will hear 10 some more from NUGEQ on this.
11 MEMBER BROWN: Yes, I just -- I wanted 12 to get my thoughts out there. That's all.
13 MEMBER MAYNARD: Okay.
14 MR. AGGARWAL: Thank you.
15 MEMBER MAYNARD: All right. Did you 16 have any more? I think that is your last slide, 17 right?
18 MR. AGGARWAL: Yes.
19 MEMBER MAYNARD: I guess I would like --
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1 clear on the scope that they are proposing?
2 CHAIRMAN BONACA: Yes.
3 MEMBER MAYNARD: And does anybody have 4 any more questions on that scope?
5 (No response.)
6 Okay. With that, thank you very much.
7 MEMBER BROWN: Good morning.
8 MEMBER MAYNARD: Oh no, we are not done 9 yet.
10 I believe we have an individual here 11 from NUGEQ.
12 MR. HORIN: I am here.
13 MEMBER MAYNARD: All right. All right.
14 Come to a microphone anyway there. Introduce 15 yourself. Why don't you come on up here, yes.
16 MR. HORIN: Good afternoon, Mr.
17 Chairman, and the rest of the Committee. We come 18 before you again.
19 Thank you very much for allowing us to 20 take some time to discuss this guide and the 21 direction that we are going in some of these areas.
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1 I think that the progress that has been made over 2 the last couple of years in looking at this guide is 3 important. But we still have a couple of issues 4 that we think are very important that we have not 5 fully resolved.
6 My name is Bill Horin. I am with 7 Winston & Strawn. We are the counsel to the Nuclear 8 Utility Group on Equipment Qualification.
9 Phil Holzman, who is our Technical 10 Consultant with Strategic Technology and Resources, 11 is listening in on the phone. We have been in 12 existence since 1981, and the sole purpose of this 13 group is to examine issues related to equipment 14 qualification and primarily the environmental 15 qualification of electric equipment.
16 We represent over 95 of the operating 17 reactors in the United States, and we have been 18 following this issue for many years and continue to 19 follow it. It is an important one.
20 Let me say first that we do not object 21 to condition monitoring. I heard that mentioned on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 a couple of occasions. We believe that it must be 2 clearly laid out that proven and effective means of 3 condition monitoring are the ones that we must focus 4 on.
5 There is a lot of discussion about, you 6 know, 14 methods, but the applicability of any one 7 of those to a broad set of cables that would result 8 in -- provide results and provide any information 9 that is useful for determining the survivability of 10 that cable in a harsh environment is very limited.
11 The slides that we I guess -- next 12 slide. Or do I do this? Okay. Thank you, Tom.
13 One moment.
14 Okay. What I wanted to start with here, 15 because I think it is an important factor, and there 16 were only -- there is only a handful of the 17 Committee members that were here in 2002 when this 18 issue came before you -- is to provide a bit of 19 background related to the substantial research 20 effort that the staff undertook in the 1992 to 2003 21 timeframe to address qualification, the adequacy of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 our qualification standards, to address also 2 specifically the availability of reasonable 3 condition monitoring techniques.
4 We said at the very beginning -- and 5 this was a comment with NUMARC, and we worked 6 closely with them, is that we believe research in 7 the area of condition monitoring may be useful 8 toward developing information for assessing the 9 actual service life of equipment. We didn't object 10 to doing research on condition monitoring, and we 11 don't object again, as I pointed out, more effective 12 and proven methods of condition monitoring to be 13 considered for facilities.
14 MEMBER ARMIJO: Let me ask you, do you 15 consider it -- you know, maybe useful isn't a real 16 big endorsement. Do you think it is important and a 17 high priority to do condition monitoring?
18 MR. HORIN: If we get useful 19 information.
20 MEMBER ARMIJO: Sure, I agree, you know, 21 that is a prerequisite. But do you really think --
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1 so you -- you are not against it, but you are 2 against it if it is -- provides garbage --
3 MR. HORIN: The way this guide is 4 written presents a very broad and undefined 5 expectation with respect to the application of cable 6 condition monitoring. And perhaps we should back up 7 just for a second. We are distinguishing here 8 between cable monitoring, environmental monitoring, 9 walkdowns, corrective action programs, which 10 licensees do already and which future licensees will 11 do.
12 The issue that we are focusing on here 13 is supplementing those efforts with actual cable 14 condition monitoring techniques. And so if we, 15 again, have, you know, proven and effective means, 16 it would be -- to provide the information that we 17 need, you know, it would be an appropriate thing to 18 expect.
19 But we don't have that at this point in 20 time, and the reg guide is written in a way that 21 would expose licensees who either adopt this at new NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 plants, or who are, as Mr. Aggarwal pointed out, 2 conducting a major change to their facility where 3 you are fundamentally changing the licensing basis, 4 and, therefore, you may be expected to utilize the 5 newest guidance available, under those circumstances 6 we don't believe that this is adequately defined.
7 In the 1992 to 2003 timeframe, the NRC 8 undertook a substantial research effort, which was 9 to address the question in the Generic Safety Issue 10 168 and to address several components related to the 11 environmental qualification standards. Now, one of 12 those components was the adequacy of the existing 13 standards, the adequacy of the application of 14 testing techniques.
15 We have heard today that we do a single 16 prototype, and then licensees go off and change, 17 manufacturers go off and change the configuration.
18 Well, that is not 100 percent clear or accurate, 19 because when you do a prototype of a particular type 20 of cable you are required to evaluate and maintain 21 that that qualification applies to cable which is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 similar design and function and materials, and you 2 have to do a detailed analysis of that.
3 And the generic safety issue resolution 4 and the task action plans, a result of the task 5 action plan efforts, concluded that that type of 6 testing was adequate, and that it was appropriate 7 given the standards and conditional measures of 8 conservatism we have in our regulatory system.
9 But most importantly, with respect to 10 this particular issue that we are dealing with right 11 now, and that is -- and I am focusing first on the 12 condition monitoring question -- we identified as 13 part of that task action plan 12 techniques I 14 believe it was, and we have tacked on a couple of 15 others that are out there now, that have -- at least 16 in laboratory applications are in limited 17 applications, potential benefit, or have the 18 possibility of providing some information with 19 respect to the condition of the cable.
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1 that will provide information that tells you, which 2 is what we are most concerned about, how this will 3 perform in the event of an accident as opposed to 4 some particular, you know, gross failure of the --
5 you know, of the insulation or some part of the 6 cable construction -- is -- was the focus of this 7 task action plan, a review of condition monitoring.
8 And we -- the staff spent taxpayer's dollars, 9 millions of dollars on this effort.
10 Let's see. So in October of 2000, this 11 testing was completed, and the staff briefed the 12 ACRS. There were still a number of questions 13 related to the characterization of the results of 14 the testing that were performed under the GSI, and 15 so some additional meetings and interactions were --
16 took place over the next couple of years to focus on 17 in particular, you know, the need for monitoring 18 plant environments and cable condition monitoring.
19 In June of 2002, the staff came before 20 this Committee and described what the results were 21 of that process. What the staff demonstrated or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 stated -- and we provide specific citations to the 2 ACRS transcripts on our web -- that with respect to 3 the methods that no single technique was effective, 4 and a combination of techniques would be needed to 5 provide useful information, and that overall -- and 6 this goes to the question of terminating, 7 determinating, and whether or not there is a higher 8 risk component with respect to equipment performance 9 versus cable performance, but the benefits of 10 conducting condition monitoring were modest at best.
11 And, fundamentally, that was done by a 12 risk analysis that the NRC had conducted that 13 examined the question of, you know, we are going to 14 establish the specific -- assume failure probability 15 for cable. And even if we are able to reduce that 16 down to zero, okay, the change in the risk related 17 to, you know, cable failures was going to be -- that 18 could be prevented by condition monitoring, even if 19 condition monitoring could take the risk to zero, 20 there was not a significant change in the risk 21 involved.
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1 MEMBER STETKAR: Can I ask a question 2 about that? I am not familiar with that study, 3 although I have some background in risk assessment 4 and electrical things. So I -- I am kind of 5 curious. You are characterizing the study. Are you 6 familiar with that study and how it was done?
7 MR. HORIN: Yes. Bill is our technical 8 consultant for it.
9 MEMBER STETKAR: Okay. He is on the 10 line.
11 MR. HORIN: He is listening.
12 MEMBER STETKAR: Okay.
13 MEMBER MAYNARD: We can open it up if 14 you need him to answer a question. We'll see how --
15 MEMBER STETKAR: My experience has been 16 that: a) cables are not modeled in any risk 17 assessment, so determining the net changes of 18 failure rate of something that is not there is --
19 MEMBER APOSTOLAKIS: Problematic.
20 MEMBER STETKAR: -- problematic. Thank 21 you, George.
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1 (Laughter.)
2 And, second of all, that if -- I have 3 seen risk assessments that have included cables, but 4 the presumption is those cables are under good 5 condition. In other words, the presumption is that 6 they are not degraded, and that sufficient 7 monitoring has been done to ensure that they are in 8 condition as -- essentially the same condition that 9 they were installed when the plant was built.
10 So that is why I am curious about the 11 conclusion that making the cables perfect doesn't 12 change things.
13 MR. HORIN: There was a failure rate 14 model, then, for the cable. And I believe it was 15 one percent.
16 MEMBER STETKAR: I am not sure what a 17 one percent failure rate means, but that's okay.
18 MEMBER BLEY: You are saying somebody 19 took a PRA of a whole powerplant, modeled all of the 20 cables, and put in a one percent --
21 MR. HORIN: All of the cabling with a --
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1 an assumed --
2 MEMBER BLEY: Something is real suspect 3 about that.
4 MEMBER STETKAR: I have never heard of 5 anyone ever doing that, so that is curious.
6 MEMBER APOSTOLAKIS: That is something 7 that perhaps --
8 MR. HORIN: Yes, Phil might be able to 9 provide more, so go ahead and open up the line.
10 MEMBER MAYNARD: Go ahead.
11 MR. HORIN: Phil, we're going to try and 12 tap you in here.
13 MR. HOLZMAN: Can you hear me?
14 MR. HORIN: Okay.
15 MR. HOLZMAN: Okay. Good afternoon.
16 MEMBER STETKAR: Good afternoon. Have 17 you been listening?
18 MR. HOLZMAN: Of course.
19 MEMBER STETKAR: Are you familiar with 20 the study that was done that concluded that perfect 21 cables has no effect on -- making cables perfect has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 no effect on risk?
2 MR. HOLZMAN: I am reasonably familiar 3 with it. And, in fact, I think we provided an 4 overview of that -- of that study in Enclosure 2 to 5 the letter we provided to the ACRS. But, in 6 summary, I believe that the PRA evaluation took a 7 look at the most risk-significant accident 8 scenarios, particularly those that were scenarios 9 that produced harsh environments in the plant, and 10 then it looked at the specific ones that were the 11 most significant in terms of risk contributions.
12 And it looked at -- and those scenarios 13 and the equipment necessary to support those 14 scenarios were a substantially smaller subset of the 15 equipment than the whole plant.
16 And then, Arthur Buslick, who I think 17 was the NRC staffer that did work on this, and his 18 contractors -- I don't know really who actually did 19 the work -- took a look at the available research 20 information that the NRC had conducted on cable 21 performance during accidents and other information.
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1 And based on that, they came to the conclusion that 2 for the purposes of modeling cables in the PRA they 3 would assume a failure rate of .01 for the cables, 4 which I think is a number to start with.
5 I think those of us who have experience 6 in qualification would have disagreed with that 7 number and thought it was very low. Oh, excuse me, 8 very high in terms of failure rate.
9 My understanding also is that in the 10 modeling, the PRA modeling they did, they assumed 11 that if there was a cable that failed in one 12 redundant train of a system that the -- that the 13 cable also failed in the other train. So you had a 14 .01 failure rate for actually both cables in both 15 trains.
16 And they modeled that -- those cables in 17 as supporting the equipment, and then they came up 18 with a CDF for that model. And then, they took the 19 same model and they said, okay, let's take in that 20 model the -- and assume now that the failure -- that 21 the cables don't fail, they have a failure rate of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 zero, and see what the change in CDF is.
2 And then, they went through that 3 process, and I think the conclusions that Bill just 4 expressed to you are stated in their study, which 5 was part of the proposed -- was part of the 6 technical assessment for this GSI, which was that 7 the -- that the -- I think they would have called it 8 the monetized benefit in terms of however this goes 9 on for latent cancer fatalities and everything else 10 -- that given other analyses they had done for other 11 reasons that this was a modest -- that there was a 12 modest benefit.
13 And there was a recognition that it was 14 modest even assuming that the cable -- that the 15 cables were perfect now, that the condition 16 monitoring took the failure rate from .01 to zero.
17 And I think the study also went on and said if there 18 were -- if there was credit for other licensee 19 activities, such as environmental monitoring, 20 walkdowns, and things like that, the benefit would 21 be even less. And then, obviously, recognizing that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 you can't make the cables perfect, the benefit would 2 be even less than that.
3 And I think in the enclosure that we 4 provided to you that is -- I think on page 2 of that 5 enclosure there is an interaction between Satish 6 Aggarwal, Arthur Buslick, and one of the members of 7 the ACRS. And they in essence all said that the 8 benefits -- it says the benefit -- I will just get 9 down to -- to the ACRS member's statement at the 10 end. "So the benefits of industry actions are, 11 then, even smaller than modest, because you are 12 getting all the way to zero." And the ACRS said, 13 "That's right."
14 And I think even Satish said at that 15 time, when he was making the presentation, said 16 that, "And we find that any requirements such as 17 condition monitoring, the benefits are zero to 18 modest." And so we are confused. I will let you 19 get back to the discussion. But, I mean, frankly, 20 we are confused because, as you saw today, there has 21 never been a mention of GSI-168 or the significant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 efforts that the staff had in that area.
2 And it seems like the conclusions --
3 they are bringing up the same questions and the same 4 perspectives they had before the GSI was even 5 started. I mean, I can remember back in '93 we were 6 hearing the same thing, that condition monitoring is 7 necessary. And they set about in the GSI-168 8 program in essence to prove it, so that they could 9 make it a regulatory requirement.
10 MEMBER MAYNARD: Okay. John, did you 11 get --
12 MEMBER STETKAR: I did. And thanks for 13 your elaboration. As you were speaking, I kind of 14 reread the Enclosure 2. It is my understanding that 15 the study you are citing looked at Surry and 16 Peachbottom and only the contributions from LOCA 17 events, and made some assumptions about how much 18 cables might contribute to LOCA events. And that is 19 really not a risk assessment. It is --
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1 at --
2 MEMBER MAYNARD: I would like to move 3 along. I think we understand their position.
4 MR. HORIN: Okay. To move on, I think 5 the fundamental point, or actually there is another 6 point to be made on this particular slide -- we have 7 already talked about the conclusions, but also there 8 was an additional contractor report that was issued, 9 and it is NUREG/CR-6704, that was issued at that 10 time, which indicated that you had to look at the 11 condition monitoring methodologies closely because a 12 lot of the information that comes from them were 13 obtained in laboratory settings.
14 And that the conclusion was that 15 additional testing needed to be performed on the 16 effect in actual plant conditions in situ to truly 17 assess the viability, the efficacy, of these 18 condition monitoring techniques.
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1 specific expectations with respect to condition 2 monitoring, and that we needn't change the 3 fundamental qualification criteria that we have used 4 with respect to environmental qualification of 5 electric equipment.
6 To jump ahead, there has been nothing 7 that has been placed before stakeholders -- and I 8 would ask that if there is anything that is in the 9 public document room, give me an ADAMS number. If 10 there is anything that has been fully vented with 11 stakeholders concerning supporting any change to the 12 conclusions of the task action plan, and if they 13 come forward with it, and we will be happy to 14 examine it.
15 But all we have at this point in time 16 is, well, we have some condition monitoring 17 techniques that are promising. There is one in 18 particular that we think may be good. But the tooth 19 fairy -- you know, thinking what the tooth fairy is 20 going to bring you until that quarter is under your 21 pillow doesn't tell you what is happening.
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1 And we haven't had the opportunity, as 2 we mentioned, that -- to examine any change in the 3 basis for the conclusions that were reached in 2002 4 and 2003. I think that it is also important to note 5 that EPRI, with respect to the one methodology that 6 Mr. Koshy mentioned, is planning to do in situ 7 examination of that methodology in 2010, but we are 8 not there yet.
9 I mean, we have some claims of promising 10 results in some plants in Europe, but we don't have 11 anything that tells us, as U.S. regulated and 12 regulatory bodies, that, yes, this is the answer.
13 And yet we are looking to put language into a reg 14 guide that will apply to new plants, can apply under 15 some circumstances to existing plans, that expects 16 condition monitoring with essentially no limitation 17 on that provision.
18 MEMBER MAYNARD: I am going to have to 19 ask you to move it along a little bit. We do have 20 some other questions for the staff, so --
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1 along here. We have heard the suggestion that doing 2 nothing is what licensees are doing, and that is a 3 mischaracterization. We are doing environmental 4 monitoring. We are doing walkdowns and inspections.
5 Anything that we find we put in corrective action 6 programs and follow through with the root cause 7 analyses.
8 Those are not nothing, and those have 9 been shown to be effective in identifying situations 10 where you have cables, other equipment in the plant, 11 that may have been stressed in a manner that is, you 12 know, not expected from the original design.
13 We have already talked about the 14 efficacy of condition monitoring techniques to put 15 it in --
16 MEMBER RAY: Let me interrupt you for 17 just a second, just very briefly. All those things 18 that are being done now would not satisfy this reg 19 guide in your judgment?
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1 monitoring, which we distinguish between monitoring, 2 environmental monitoring. And those elements -- and 3 the new language -- we just saw this new language 4 today, because this wasn't released previously. The 5 new language seems to confuse condition monitoring 6 with the type of environmental monitoring that is 7 being conducted.
8 We would view monitoring, cable 9 monitoring, as involving inspections, walkdowns, 10 environmental monitoring. That would be cable 11 monitoring. Condition monitoring is specific to and 12 would be in addition to those other efforts that are 13 undertaken already. And this reg guide suggests 14 that you should be doing this condition monitoring 15 -- cable condition monitoring in addition to the 16 other methods that you are doing.
17 MEMBER RAY: And that is not being done 18 now.
19 MR. HORIN: And it is not being done, 20 because we don't have any proven ways. There are 21 some cables -- I think we mentioned some power NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 cables. There are some methods that are useful for 2 particular cables. But we are talking about 3 instrumentation and control cables, medium voltage 4 cables, we don't have some method that we can point 5 to that is the silver bullet here.
6 And all we are asking is that there be 7 some recognition in this language that those 8 techniques, to the extent that condition monitoring 9 remains in the guide, that there be some 10 qualification on that language that suggests that it 11 has to be some proven and effective means of 12 condition monitoring, not just, "Well, do something.
13 We want you to do something. We don't know what 14 that is, but do something."
15 And if we don't have any criteria or any 16 standard by which to even approach this, we are 17 running into a situation where licensees will be 18 unable to demonstrate that they reasonably satisfied 19 what the expectation is. So that is our 20 fundamental --
21 MEMBER RAY: Okay. But it would seem --
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1 and I can -- I have been admonished we need to move 2 on here, but it would seem like the guide, were it 3 to exist, would invite licensees to propose what 4 they would intend to do specifically. And it would 5 be whatever was available at the time. And I gather 6 your concern is that that wouldn't be enough.
7 MR. HORIN: No. The guide is not clear 8 on that point.
9 MEMBER RAY: So it is a matter of 10 clarity.
11 MR. HORIN: So it is a matter of 12 clarity. And our suggestion, which we have at the 13 end of our presentation, and we have essentially cut 14 through these -- let's go right to here -- is we use 15 language that says that, where appropriate, these 16 activities should be supplemented with -- "these 17 activities" being conditioned or -- being cable 18 monitoring or environmental monitoring -- should be 19 supplemented with condition monitoring techniques 20 that are proven to be effective for assessing in 21 situ degradation for the cables and conditions of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 concern.
2 And we provide some additional language 3 that we should also be focusing on those that are 4 most at risk. But our question here is, if we are 5 really intending to have licensees that are --
6 become committed to this reg guide only do those 7 things that really work, then what is wrong with 8 putting that language in?
9 I mean, we are looking for clarity here, 10 and all we are saying is that, given the uncertainty 11 -- significant uncertainty that exists with respect 12 to the applicability of particular of any of those 13 14 methods of condition monitoring, and, in 14 particular, the absence of any additional record 15 beyond what was done in the Generic Safety Issue 168 16 resolution, that it is inappropriate to simply say, 17 "Oh, and we expect you to do condition monitoring."
18 I would point out that among the people 19 who commented upon this guide, the draft guide 20 originally -- we mentioned there are five different 21 groups -- IEEE itself commented and opposed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 inclusion of condition monitoring, because the IEEE 2 standard on which this is premised and on which an 3 exception is being taken doesn't address condition 4 monitoring. So that is somewhere else.
5 And we recognize that there are going to 6 be additional efforts, that there is an additional 7 reg guide that is going to be evaluated, and we 8 would suggest that this language, if we are going to 9 come out with this reg guide now, would be 10 appropriate in that to the extent that more detailed 11 guidance with respect to condition monitoring and 12 the status of that within the -- you know, our 13 universe of activities we can employ to provide 14 additional assurance of cable condition, is best 15 addressed in the context of these additional efforts 16 that are ongoing and will result in additional 17 guidance -- sometime by the end of the year that we 18 are looking for another reg guide that would focus 19 -- draft reg guide that would focus on condition 20 monitoring.
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1 program.
2 MR. HORIN: Essential elements. But 3 that type of effort that is focused purely on this 4 issue, which is -- I hope we have gotten across is 5 not clear that we can point to any one of those 14 6 methods and say, "Use it."
7 MEMBER MAYNARD: What I see is a key 8 difference between what you are proposing -- you are 9 limiting -- you are saying "where appropriate,"
10 whereas they are saying "all within the scope." So 11 you are saying -- and that is one key difference.
12 The other is to basically only use it 13 when there is a proven method or technique proven to 14 be effective.
15 MR. HORIN: Right.
16 MEMBER SHACK: Where do you think it is 17 appropriate?
18 MR. HORIN: In what respect?
19 MEMBER SHACK: Well, you say "where 20 appropriate." I want to know what your definition 21 of "appropriate is."
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1 MR. HORIN: We were looking at -- if you 2 look -- on the next line down, or the next sentence, 3 most effective when applied to cables with the least 4 margin due to qualification level, service 5 condition, those cables that are at risk, those 6 cables that we know are right on the border in terms 7 of their, you know, temperature environment, so 8 their radiation environments, to look at those 9 perhaps that have, you know, greater potential risk 10 or significance in the plant, because we know that 11 there are a number of cables that are out there that 12 are subject -- that are safety-related, that are 13 subject to 50.49, and it is only because they just 14 barely exceed a temperature limit that licensees 15 will have in their plants.
16 MEMBER BLEY: How about cables that are 17 in service in environments for which they weren't 18 qualified?
19 MR. HORIN: Well, that is something for 20 corrective action. I mean, if they are not 21 qualified, then they need to be qualified. I mean, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 that is a separate issue. That is a regulatory 2 compliance issue.
3 MEMBER MAYNARD: I would like to bring 4 this to a close. I think we are clear on your 5 position here. And unless there are some other 6 burning questions for him, I think Charlie had a 7 couple of questions for the staff on IEEE itself, I 8 believe.
9 MEMBER BROWN: Yes, these are general.
10 The IEEE standard 383-2003 is relatively general in 11 a couple of places, and so a little bit of this is 12 to make sure I understand how this is supposed to be 13 applied. You describe design basis event 14 simulations, but the design basis event environment 15 will be different for different plants, if I am not 16 mistaken, isn't that correct?
17 MR. AGGARWAL: Correct.
18 MEMBER BROWN: And so for applications 19 in the commercial plants, do licensees qualify 20 explicitly for theirs? Or do the cable 21 manufacturers have an envelope within which they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 operate that they may qualify? I mean, I just don't 2 know the difference. I know what I used to do. I 3 don't know what you all do.
4 MR. AGGARWAL: Take a worst-case 5 scenario. Going back to IEEE Standard 32374, they 6 have provided typical cases of PWR and BWR. And 7 most of the cables in that country have been 8 qualified based on those presumptions.
9 MEMBER BROWN: So that is what the 10 licensees and other folks --
11 MR. AGGARWAL: The obligation for the 12 licensees to show that their plant-specific 13 conditions did not exceed what is --
14 MEMBER BROWN: They try to fit it within 15 a generic qualification. But if a plant has a 16 unique situation, they may have to do a supplemental 17 test or qualification.
18 MEMBER BROWN: And that is in another 19 IEEE standard?
20 MR. KOSHY: That is another document 21 that I referred to, 323-2003.
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1 MR. HORIN: All right. And it is also a 2 compliance issue. I mean, if you are outside --
3 MEMBER BROWN: No, that is fine. I just 4 didn't -- I didn't see it in this one, and I didn't 5 have a reference to the other document.
6 When you do -- again, this is aging.
7 What I am used to seeing is you bend cables, because 8 that is the stress point.
9 MR. AGGARWAL: That is after the LOCA 10 testing.
11 MEMBER BROWN: Yes, I saw that also.
12 But it just -- you are doing it to radii that are 13 somewhere in the neighborhood of 20 to 40 times --
14 MR. AGGARWAL: Yes.
15 MEMBER BROWN: -- the diameter of the 16 cable. And the applications I have used to qualify 17 were like in the eight to 12, whatever the design 18 bend radius was of the cable. That is the way we 19 tested it, because that way we knew that if we ran 20 into a condition during building a plant we could --
21 we would not exceed the qualification capability.
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1 And 40 times a two-inch diameter cable 2 is 80 inches, which is a huge bend radius. So --
3 MR. AGGARWAL: But, remember, these are 4 brand-new cables.
5 MR. KOSHY: The presumption is this is 6 verification after the post-LOCA condition. In a 7 sense, I aged -- radiation aging, thermal aging, 8 exposed LOCA environment. Then, I am making sure it 9 has enough life for a basic flexibility, not the 10 pulling conditions of the cable.
11 MEMBER BROWN: But why aren't you 12 interested in the performance of a cable within 13 where it might be installed? For instance, if it's 14 installed with a 15 bend radius, why wouldn't you 15 test it to that, and then just -- in the LOCA 16 conditions?
17 MR. KOSHY: When the cable is new, you 18 are stressing to a higher surface tension, and you 19 have installed it in place already. So the LOCA is 20 happening much later. So when it is new, it is 21 capable of flexing more, and we believe -- at least NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 the standard community believes that is not 2 seriously affecting enough to reduce its qualified 3 life.
4 MEMBER BROWN: I was talking about after 5 your temperature -- after your aging you would have 6 it bent to --
7 MR. KOSHY: Because the cable is -- we 8 are not going to move in the post-accident 9 environment. It is fixed in place. It is routed, 10 connected --
11 MEMBER BROWN: I understand that.
12 MR. KOSHY: -- stays in place.
13 MEMBER MAYNARD: And just to see if it 14 could withstand some flexibility.
15 MEMBER BROWN: I've got it installed 16 with a 20-inch bend radius. I would do the aging, 17 the thermal -- you know, thermal and radiation, and 18 then I would do the LOCA. And that is just like it 19 is installed. Then, I would go see, does it 20 embrittle? Does it fall apart or not? As opposed 21 to trying to bend it.
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1 MR. KOSHY: Yes. Some rough bending to 2 see if the insulation will fall apart.
3 MEMBER BROWN: Okay. You answered my 4 question. We can get on.
5 VICE CHAIRMAN ABDEL-KHALIK: Let me just 6 ask -- maybe I'm missing something. After a plant 7 is built, how would you test a cable in situ at LOCA 8 conditions?
9 MR. HORIN: That is one of the questions 10 that we have here. In terms of being able to test 11 the cable proven and effective for the purposes for 12 which you are trying to do the testing, if you are 13 able to utilize the condition -- if there is a 14 condition monitoring technique that is ever shown to 15 be able to get down to the level of measurement that 16 would give you some indication of whether this cable 17 is capable of performing in a LOCA, you know, that 18 would be -- you know, somebody ought to go out and 19 patent that right now.
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1 will find more significant degradation of cables.
2 But it is very difficult to even suggest that there 3 is anything that would get you to that point.
4 VICE CHAIRMAN ABDEL-KHALIK: But if the 5 bottom-line purpose of this is to show -- is to 6 monitor the condition of the cable to prove that 7 they will actually perform adequately under LOCA 8 conditions, to limit this to in situ methods, is in 9 my opinion inappropriate.
10 MR. HORIN: Well, that is what we are 11 talking about here.
12 VICE CHAIRMAN ABDEL-KHALIK: But you are 13 saying --
14 MEMBER RAY: I think they are looking 15 for change. I am just offering that in situ can 16 only, obviously, detect change.
17 VICE CHAIRMAN ABDEL-KHALIK: Detect 18 change, but not at LOCA conditions.
19 MEMBER RAY: That's right. But if you 20 find change, then you have to do something to say, 21 "Well, is the change indicative of a loss of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 qualifications."
2 MEMBER MAYNARD: Especially looking 3 for --
4 MEMBER ARMIJO: Well, it's reducing your 5 margin from the original qualification, right?
6 MR. HORIN: Yes.
7 MEMBER ARMIJO: So there must be some 8 margin at which you would say it probably won't --
9 MR. HORIN: And that is the question:
10 do we have any techniques that can get us to that?
11 MEMBER RAY: And then, you look at what 12 is the significance of the change to the 13 qualification? Which means you had to pull some 14 cable in. All right? But the first thing you do is 15 figure out, has there been any change?
16 Now, the argument is that isn't 17 sufficiently dispositive on qualification.
18 MR. AGGARWAL: Just for clarify, 19 condition monitoring is not replacing your regular 20 testing of the cable that you had to have creating 21 the cable -- thermal radiation, and then the LOCA NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 testing, and the tests we talked about. That is 2 what you call testing at Level III. So the staff is 3 not telling that condition monitoring is going to 4 replace LOCA testing. That is given, that you will 5 do that.
6 What the staff is saying, that -- just 7 do the test once, and then don't walk away for 40 8 years, 60 years, 80 years. And Bill described some 9 of those matters with -- they are doing, but that is 10 not in any of the regulatory guides. But that will 11 be one of the acceptable ways to meet the 12 requirement of the guide.
13 VICE CHAIRMAN ABDEL-KHALIK: I guess, 14 you know, I brought up this question reading the 15 suggested alternate wording that you have on this 16 page where you say, "Where appropriate, these 17 activities should be supplemented with condition 18 monitoring techniques that are proven to be 19 effective for assessing in situ degradation for the 20 cables and conditions of concern."
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1 means?
2 VICE CHAIRMAN ABDEL-KHALIK: Please.
3 MR. HORIN: Yes. This guide is focused 4 on providing some guidance, and what we are looking 5 at is whether, for cables that have already been 6 installed -- and Mr. Aggarwal was pointing out --
7 this doesn't address the testing issue -- for cables 8 that have already been installed, do we have a 9 methodology that will provide information that will 10 address the condition of the cable with respect to 11 its ability to perform under the conditions for 12 which it is expected to perform? And that is all 13 that is saying, and that these methods would not be 14 -- we wouldn't be pulling cable. We would have to 15 be determinating, reterminating. We would be --
16 MEMBER RAY: Yes. But you are never 17 going to meet the standard. What you need, as I 18 said to Said, is something that detects a change, 19 and then you pull the cable and see if the change 20 affects --
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1 you know, point, and I think that is the type of 2 thing that would be in the context of what we are 3 talking about coming up later this year.
4 MEMBER RAY: All right. Okay.
5 VICE CHAIRMAN ABDEL-KHALIK: Or perhaps 6 laboratory samples that are appropriately aged.
7 MEMBER RAY: That is another way to do 8 it, pull some samples.
9 VICE CHAIRMAN ABDEL-KHALIK: That would 10 truly represent the conditions in the field and you 11 measure how the degradation is with aging at LOCA 12 conditions. So my objection is to the word "in 13 situ," because that sort of constrains the 14 acceptability of the --
15 MR. HORIN: And we say "in situ" here 16 because that is what this is aimed -- this reg guide 17 is aimed at.
18 MEMBER RAY: Yes. The demonstration of, 19 you know, ability to provide information doesn't 20 necessarily mean that demonstrating the adequacy of 21 that particular technique is limited to in situ. It NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 could be laboratory. But what we are concerned with 2 is we right now have a situation where it is 3 essentially a guidance document that would say do 4 something, we don't care what it is, just do 5 something.
6 VICE CHAIRMAN ABDEL-KHALIK: I'm sorry, 7 but I read your wording differently.
8 MR. HORIN: Okay. And we'll stop.
9 MEMBER MAYNARD: I think we've aired 10 this out enough. I think we understand the 11 positions, and we have tried to solve the problems 12 and everything here. But I think we have enough to 13 lead our discussion when we get to this. So unless 14 there is any other pressing questions for the staff, 15 or for Mr. Horton --
16 MR. HORIN: Horin.
17 MEMBER MAYNARD: -- Horin, I will go 18 back to my original opening statement. I never 19 thought cable qualification could be so exciting.
20 (Laughter.)
21 And with that, I will turn it over --
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1 back to you, Mr. Chairman.
2 CHAIRMAN BONACA: Thank you. And with 3 that, if there are no further questions from the 4 public, we are going to take a break until 4:30, and 5 we will start then.
6 (Whereupon, at 4:13 p.m., the proceedings in the 7 foregoing matter went off the record.)
8 9
10 11 12 13 14 15 16 17 18 19 20 21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 2
3 4
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
Advisory Committee on Reactor Safeguards (ACRS)
License Renewal Full Committee Vogtle Electric Generating Plant (VEGP)
Safety Evaluation Report (SER)
April 2, 2009 Donnie J. Ashley, Project Manager Office of Nuclear Reactor Regulation 1
Introduction
- Overview of VEGP license renewal review
- License Renewal Audit and Inspection
- SER Section 2: Scoping and Screening review results
- SER Section 3: Aging Management review results
Overview
- License Renewal Application (LRA) submitted June 2007 Recap of November 2008 Subcommittee Meeting
- 87 RAI items issued
- 173 Audit Questions
- 40 Commitments
- Additional Components Brought Into Scope
- Draft SER issued November 19, 2008
- Final SER issued March 13, 2009
- No Open Items (OIs)
- No Confirmatory Items
- Three (3) License Conditions (1) 3
Overview Recap of November 2008 Subcommittee Meeting (condt)
- Material Condition in Containment
- Identified during June Regional Inspection
- Region has evaluated past inspections and will continue to monitor
- Boral
- Questions about adequacy of AMP
- Telecon with Applicant and Tech Staff
- Revised AMP commitment
- Water in Cable Pull-Box
- Applicant revised monitoring program
- Region will continue to monitor 4
Overview (condt)
Subsequent to sub-committee meeting
- 7 additional RAIs issued on Boral
- Resulted in a revised commitment to provide for inspection of panels in addition to water chemistry program.
- 94 total RAIs
- Applicant provided update on Commitments
- Added one new commitment on debris screens.
5
Audits and Inspections
- Scoping and Screening Methodology Audit 9/17 - 9/21, 2007
- Aging Management Program (AMP) Audit 10/15 - 10/19, 2007
- Aging Management Review (AMR) Audit 12/9 - 12/14, 2007
- Region II Inspection (Scoping and Screening & AMP) 5/19/ - 06/06, 2008 6
Audit and Review
- Audit Summary (ADAMS Accession No. ML080430373)
- Publicly Available, Issued on September 30, 2008
- Audit Summary Includes :
- Audit and Review Results
- Audit and Review Q&A Database
- List of Documents Reviewed by the Audit and Review Team 7
Regional Inspection
- Two Weeks on Site
- AMP inspection May 19 - June 6, 2008
- License renewal chapter - MC 2516
- License renewal inspection procedure IP 71002 8
Regional Inspection
- Inspectors identified enhancements
- Manhole flooding with Medium Voltage Non-Safety Related Cable
- Condition inside containments
- Region II will follow up on these issues during a future IP 71003 inspection 9
Regional Inspection The inspection team concluded that the scoping and screening of non-safety related systems, structures, and components, was implemented as required by the rule and the aging management portions of the license renewal activities were conducted as described in the application.
10
SER Section 2: Structures and Components Subject to Aging Management Review Section 2.1 Scoping and Screening Methodology Section 2.2 Plant-Level Scoping Results Section 2.3 Mechanical Systems Results Section 2.4 Structures Results Section 2.5 Electrical and I&C Control Systems 11
Section 2 - Conclusion ased on its review of the LRA, the onsite audit results, and dditional information submitted as the result of RAIs, the staff oncluded that:
The applicants scoping and screening methodology meets the requirements of 10 CFR 54.4 and 54.21(a)(1), and That the applicant adequately identified those SSCs within the scope of license renewal in accordance with 10 CFR 54.4(a), and those SCs subject to an AMR in accordance with 10 CFR 54.21(a)(1) 12
Section 3: Aging Management Review Results Aging Management Programs (AMPs)
- 38 AMPs
- 14 are NEW programs
- 24 are EXISTING programs
- 20 programs with exceptions and/or enhancements
- 11 are plant specific
- 7 are consistent with GALL 13
Section 3 - Conclusion Based on its review of the LRA and additional information submitted as the result of RAIs, the staff concluded that:
Aging effects will be managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, per 10 CFR 54.21(a)(3), and That activities authorized by the renewed license would continue to be conducted in accordance with the CLB, and any changes made to the CLB in order to comply with 10 CFR 54.21(a)(3), would be in accordance with the NRCs regulations 14
SER Section 4: Time-Limited Aging Analyses
- 4.1 TLAA Process
- 4.2 Reactor Vessel Neutron Embrittlement
- 4.3 Metal Fatigue
- 4.4 Environmental Qualification of Electrical Equipment
- 4.5 Concrete Containment Tendon Prestress
- 4.6 Containment Liner Plate Metal Containments and Penetration Fatigue
- 4.7 Other Plant Specific TLAA 15
4.7 Other Plant Specific TLAAs
- 4.7.1 Leak Before Break Analysis
- 4.7.2 Fuel Oil Storage Tank Corrosion Allowance
- 4.7.3 Steam Generator Tube, Loss of Material
- 4.7.4 Cold Overpressure Protection System
- 4.7.5 Underclad Cracking of Reactor Pressure Vessel 16
Section 4 - Conclusion Based on its review of the LRA and additional information submitted as the result of RAIs, the staff concluded that the applicant provided an adequate list of TLAAs, per 10 CFR 54.3 and that the:
TLAAs will remain valid for the period of extended operation, per 10 CFR 54.21(c)(1)(i)
TLAAs have been projected to the end of the period of extended operation, per 10 CFR 54.21(c)(1)(ii)
Aging effects will be managed for the period of extended operation, per 10 CFR 54.21(c)(1)(iii) 17
Overall Conclusion The staff has concluded there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the CLB, and that any changes made to the VEGP CLB in order to comply with 10 CFR 54.29(a) are in accordance with the Act and the Commissions regulations.
18
19 License Conditions (1)
- The first license condition requires the applicant to include the UFSAR supplement required by 10 CFR 54.21(d) in the next UFSAR update, as required by 10 CFR 50.71(e), following the issuance of the renewed license.
- The second license condition requires future activities identified in the UFSAR supplement to be completed prior to the period of extended operation.
- The third license condition requires that all capsules in the reactor vessel that are removed and tested meet the requirements of American Society for Testing and Materials (ASTM) E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule insertion and withdrawal schedule, including use of spare capsules, must be approved by the staff prior to implementation. All capsules placed in storage must be maintained for future insertion. Any changes to storage requirements must be approved by the staff, as required by 10 CFR Part 50, Appendix H.
20
Digital Instrumentation Control Interim Staff Guidance on Highly Integrated Control Room -
Human Factors, Licensing Process Issues, and Related Matters April 2, 2009 Steven Arndt Office of Nuclear Reactor Regulation David Desaulniers Office of New Reactors G. Edward Miller Office of Nuclear Reactor Regulation
Agenda
- Background on Steering Committee
- Digital I&C Project Products
- Path Forward
- Overview of ISG-5, Revision 1
- Manual Operator Action Background
- Overview of ISG for crediting manual operator actions
- Overview of ISG-6
- Process Overview
- Format of ISG-6
- Tiers of Complexity
- Phases of Process
- Areas of Review
- Path Forward Slide 2
Committee
- Digital I&C Steering Committee formed January 2007
- 7 Task Working Groups formed to address specific issues
- TWG-1 Cyber Security
- TWG-2 Diversity and Defense in Depth (D3)
- TWG-3 Risk-Informing Digital I&C
- TWG-4 Highly-Integrated Control Room - Communications
- TWG-5 Highly-Integrated Control Room - Human Factors
- TWG-6 Licensing Process
- TWG-7 Fuel Cycle Facilities
- Industry established counterpart groups
- Over 100 public meetings to define, discuss and resolve issues Slide 3
Digital I&C Project Products Status of Digital I&C Products TWG-1: Cyber Security - ISG-1 Issued 12/2007
- ACRS Review: Letter dated April 29, 2008
- Next Steps: Update SRP and RG 1.152 following rulemaking and RG 5.71 TWG-2: Diversity and Defense in Depth (D3) - ISG-2 Issued 9/2007
- Industry Concern: Credit defensive measures and component level actuation
- ACRS Review: Letter dated October 16, 2007
- Recommends Process to Evaluate < 30 Minute Operator Action
- Next Steps: Complete NUREG on diversity attributes, update SRP Slide 4
Digital I&C Project Products Status of Digital I&C Products (contd)
TWG-3: Risk Informing Digital I&C - ISG-3 Issued 8/2008
- Industry Concern: Risk informing guidance on D3 and policy on diverse actuation systems
- ACRS Review: Letter dated April 29, 2008
- Recommends emphasize failure modes vs. sensitivity studies
- ISG-3 was revised to incorporate recommendations
- Next Steps: Methods for obtaining risk insights and risk informing digital I&C to be addressed in 5-year research plan TWG-4: Highly Integrated Control Room Communications ISG-4 Issued 9/2007
- ACRS Review: Letter dated October 16, 2007
- Next Steps: Update SRP, RG 1.152, and IEEE 7.4.3.2 Slide 5
Digital I&C Project Products Status of Digital I&C Products (contd)
- TWG-5: Highly Integrated Control Room Human Factors ISGs issued 9/2007 and 11/2008
- ACRS Review: Letter dated October 16, 2007
- Present ISG on Manual Action today
- Next Steps: Rulemaking on Safety Parameter Display System, and update NUREG, Reg. Guide, and SRP
- TWG-6: Licensing Process - ISG-6 under development, inspection procedure issued 10/2008, audit procedure issued 12/2008
- Industry Concern: Level of staff review and slow progress on ISG
- ACRS Review: Letter Dated April 29, 2008
- Present update today
- Next Steps: Bi-weekly public meetings, workshop on licensing experiences in Spring 2009, add cyber security, issue final ISG Slide 6
Digital I&C Project Products Status of Digital I&C Products (Cont.)
- TWG -7: Fuel Cycle Facilities - ISG-7 under development
- ACRS Review: Request Review End of Summer
- Next Steps: Issue ISG, update and issue appropriate NUREGs
- Ongoing Work
- Updates to Regulatory Documents
- Operational Program Updates Slide 7
Path Forward
- Complete ISG for Licensing and Fuel Cycle Facilities
- Update Regulatory Documents
- Address Operational Issues
- Continue to use ISGs in Ongoing Reviews
- International Cooperation
- MDEP
- Bilateral Work
- COMPSIS
- IAEA and Other Interactions
- Ongoing Research Activities Slide 8
ISG-05, Revision 1
- Computer-based procedures
- Minimum inventory Slide 9
Background
ISG-02, Interim Staff Guidance on Diversity and Defense-in-Depth Issues, September 26, 2007
- Provided acceptable methods for implementing diversity and defense-in-depth (D3) in digital I&C system designs
- Clarified use of operator action as a diverse defensive measure and established corresponding operator action times Slide 10
Background
ISG-02 states:
Manual operator actions may be credited for responding to events in which the protective action subject to a CCF is not required for at least the first 30 minutes and the plant response is bounded by BTP 7-19 recommended acceptance criteria.
Slide 11
Background
- Industry sought flexibility and guidance to credit manual operator actions in less than 30 minutes
- ACRS letter (10/16/07) recommended development of an alternative process to the 30-minute criterion
- Scope of TWG-5 action plan expanded to develop guidance for crediting manual operator actions
- Public interactions between TWG-5 and industry counterparts
- Industry developed white paper methodology for crediting manual operator actions
- Staff considered and incorporated, as appropriate, white paper methods in developing an amendment to ISG-05 Slide 12
ISG-05 (Revision 1)
- Scope
- Staff Position
- 4-Phase Methodology Slide 13
Overview of ISG-5 Scope
- Manual actions credited in D3 analyses for coping with abnormal operational occurrences and postulated accidents (AOO/PAs) concurrent with software CCF of the digital protection system
- New and existing reactors Slide 14
Overview of ISG-5 Staff Position Credited actions should be:
- Included in emergency operating procedures (EOPs)
- Executed from within the main control room
- Demonstrated to be feasible and reliable
- Addressed in the human factors engineering (HFE) program consistent with NUREG-0711 Slide 15
Overview of ISG-5 Method 4-Phases:
- Analysis
- Preliminary Validation
- Integrated System Validation
- Long-term Monitoring Slide 16
Overview of ISG-5 Analysis Objective
- Estimate time available and time required
- Identify critical assumptions and credible operator errors
- Establish adequate margin Slide 17
Overview of ISG-5 Analysis Method Time Available
- Use methods and realistic assumptions consistent with BTP 7-19.
Time Required
- Use one of several acceptable methods for developing estimates of time required to perform action sequence Margin
- Time to recover from credible errors Slide 18
Overview of ISG-5 Analysis Examples of Acceptable Methods
- Operator interviews and surveys
- Operating experience reviews
- Software models of human behavior, such as task network modeling
- Use of control/display mockups
- Expert panel elicitation
- ANSI/ANS 58.8, Time Response Design Criteria for Safety-Related Operator Actions (task decomposition)
Slide 19
Overview of ISG-5 Analysis Review Criteria Topics
- Time required
- Time available
- Use of alarms, controls, and displays
- Use of symptom/function-based EOPs
- Staff size, composition and augmentation
- Level of detail
- Identification of credible operator errors Slide 20
Overview of ISG-5 Preliminary Validation Objective
- Independent confirmation of analysis results Applicability
- Only required for those vendors/applicants who are using the 10 CFR Part 52 process Method
- Use diverse methods that are as realistic as maturity of design allows
- Submit analysis and results for NRC review as part of D3 submittal(s)
Slide 21
Overview of ISG-5 Preliminary Validation Examples of Acceptable Methods
- Tabletop analysis
- Walkthrough/talkthrough analysis
- Software models of human behavior, such as task network modeling
- Use of control/display mockups
- Man-in-the-loop prototype testing
- Real-time validation using part-task simulator Slide 22
Overview of ISG-5 Preliminary Validation Review Criteria Topics
- Independence from Phase 1
- Validation team qualifications
- Use of two or more methods
- Validation of time required Slide 23
Overview of ISG-5 Preliminary Validation Results
- Shall be documented in the D3 analysis for NRC review
- Should support high confidence that the time required for manual operator actions will satisfy the success criteria for the integrated system validation Slide 24
Overview of ISG-5 Integrated System Validation Objective
- Confirm operators are able to perform credited actions in real-time using as-built design Method
- Use plant-referenced simulator capable of realistically representing AOO/PA with CCF
- Validate time required using both nominal and TS minimum crews
- Accomplish as part of HFE program activities per NUREG-0711 Slide 25
Overview of ISG-5 Integrated System Validation Review Criteria Topics
- Integration with HFE program
- Simulator
- Personnel
- Operational Conditions
- Performance Times Slide 26
Overview of ISG-5 Integrated System Validation Performance Time Criteria
- For each AOO/PA, the mean performance times of the crews is less than or equal to the estimated time required derived from the analysis phase.
- For each AOO/PA, the performance time for each crew, including margin determined in the time required analysis, is less than the analyzed time available.
Slide 27
Overview of ISG-5 Long-term Monitoring Objective
- Ensure credited actions remain feasible and reliable Method
- Design and configuration controls ensure discrepancies from D3 assumptions and constraints are identified and corrected
- Training keeps performance within assumptions of the analysis Slide 28
Overview of ISG-5 Long-term Monitoring Review Criteria
- A long-term monitoring strategy is capable of tracking performance of the manual operator actions to demonstrate that performance continues to support the associated D3 analysis
- The program is structured such that corrective actions are formal, effective, and timely Slide 29
ISG-5 Path Forward
- Support future development and revision of ANSI/ANS 58.8, Time Response Design Criteria for Safety-Related Operator Actions Slide 30
Introduction
- Purpose of ISG-6
- Refined licensing process
- Expectations for documentation
- Knowledge management
- Lessons learned from recent I&C amendment reviews Slide 31
Process Overview Slide 32
Format of ISG-6
- Introduction
- Purpose
- Licensing Process
- Process Overview
- Pre-Application Meetings
- Initial Application
- Continued Review and Audit
- Implementation and Inspection
- Review Areas
- Scope of Review
- Information to be Provided
- Regulatory Evaluation
- Technical Evaluation
- Conclusion
- Appendices (Example Formats)
Slide 33
Tiers of Review
- Each Tier corresponds to an expected review complexity:
- Tier 1: Previously approved system, no deviations from topical report, review to focus on plant specific aspects, least review effort expected.
- Tier 2: Previously approved system, with deviations, moderate review effort expected.
- Tier 3: Totally new system, extensive review effort expected. Thorough review of all technical areas.
Slide 34
Draft Review Areas
- Working List of Review Areas
- Defense-in-depth & Diversity
- Hardware Architecture
- Hardware Design Process and Quality Control
- Communications
- Software Architecture
- Software Design Process
- System Qualifications
- System, Hardware, Software, and Methodology Modifications
- Technical Specifications
- IEEE 603 Compliance
- IEEE 7-4.3.2 Compliance
- Cyber Security Slide 35
Path Forward
- Monthly Public Meetings
- Next meeting is April 28, 2009
- Monthly conference calls on status
- Full Draft of ISG for Public Comment
- Summer, 2009
- ISG-6 Issued
- Fall, 2009
- Pilot application encouraged Slide 36
NIST Center for Neutron Research ACRS Meeting April 2, 2009
ACRS Meeting April 2, 2009
- NIST Participants
- Dr. Robert Dimeo, Director NCNR
- Dr. Michael Rowe, Special Advisor to the NCNR Director
- Dr. Wade Richards, Chief Reactor Operations & Eng.
- Dr. Paul Brand, Chief Reactor Engineering
- Dr. Robert Williams, Section Head Nuclear Analysis
- Mr. David Brown, Supervisor Health Physics
- Mr. Daniel Flynn, Senior Reactor Operator
- Mr. John Crosby, Enviro Tech Sensors Inc.
ACRS Meeting April 2, 2009
- Description of NCNR
- Description of the NBSR
- Licensing Basis Accidents
- Subcommittee Follow-up Items
ACRS Meeting April 2, 2009 Description of the NCNR
The NIST Center for Neutron Research A National User Facility The mission of the NIST Center for Neutron Research is to assure the availability of neutron measurement capabilities to meet the needs of U.S.
researchers from industry, university and other Government agencies.
- 23 instruments with access based on technical merit
- Highly interdisciplinary: basic/applied materials science & fundamental physics
- More than 2200 research participants per year
- Over 300 scientific publications per year
- Numerous partnerships with other agencies, industry, and academia (e.g. NSF, ExxonMobil, FDA, Smithsonian, Johns Hopkins, UMD,)
Largest user program and highest productivity of any neutron facility in the US [1]
[1] The American Physical Society: Access to Major International X-Ray and Neutron Facilities, November 2008.
The NIST facility is the only U.S. facility which currently provides a broad range of world-class capability. [1]
the NIST Center for Neutron Research (NCNR) currently has the largest number of users in the United States, largely because of its modern suite of cold neutron instruments. [2]
The highest priority for federal investments in neutron scattering is to fully exploit the best U.S. neutron source capabilities...for the benefit of the broadest scientific community. [1]
To improve access and to enable the user community to grow it is critically important to increase the number of beamlines and instruments at major facilities in the US. [2]
[2] The American Physical Society: Access to Major International X-Ray and Neutron Facilities, November 2008.
[1] The Office of Science and Technology Policy Interagency Working Group on Neutron Science: Report on the Status and Needs of Major Neutron Scattering Facilities and Instruments in the United States, June 2002.
NIST and DoC NIST and DoC leadership have been extremely supportive of and remain committed to the safe, effective, and reliable operation of the NIST Reactor as a critical component of the NIST measurement mission.
Past
- Cold neutron source/guide hall (1994)
- Upgraded cold source installed (2002)
- Cooling tower w/plume abatement installed (2002)
- Initiative to expand access by supporting more instruments and developing new capabilities (2004)
Present/future
- NCNR Expansion and Reliability Enhancements Project (2007-2011)
ACRS Meeting April 2, 2009 Description of the NBSR
ACRS Meeting April 2, 2009
- The National Bureau of Standards Reactor (NBSR) is a heavy water moderated and cooled, enriched fuel, tank type reactor designed to operate at 20Mw.
- It is a custom designed variation of the Argonne CP-5 class reactor.
NIST Center for Neutron Research ACRS Meeting April 2, 2009 ACRS Meeting April 2, 2009
- The NBSR includes many inherent, passive safety features
- The prompt neutron lifetime is long due to the heavy water
- The reactivity coefficients of void and temperature are negative
- Reactor operates in a low temperature, unpressurized condition and has no large stored energy content.
ACRS Meeting April 2, 2009 Licensing Basis Accidents
Accidents Analyzed
- Startup Accident
- 100 kW 130% at /t = 5x10-4 /s
- Maximum Reactivity Insertion
- Experiment removed =.5% in .5 sec
- Loss of Coolant
- Inlet pipe break in process room
- Offsite tritium doses within 10 CFR 20 limits
- Misloading of Fuel
- Fresh element in all locations
Accidents Analyzed II
- Loss of Flow
- 1. Loss of Offsite Power *
- 2. Single Pump (1 of 3) Seizure *
- 3. Throttling of Inlet Valves to either Plenum
- 4. Spurious signal closing DWV-19 (Hot Leg)
- 5. Loss of Both Shutdown Coolant Pumps
- Maximum Hypothetical Accident
- Postulates complete melting of fuel element
- Satisfies 10 CFR 100 limits
- Open Item
Open Item
- Flow coastdown data out-of-date.
- New data will be measured this week.
- BNL will analyze loss of flow accidents again with updated coastdown data.
ACRS April 2, 2009 Subcommittee Follow-up Items
ACRS Meeting April 2, 2009
- Discuss the methodology used to monitor the groundwater at the reactor site for contamination by releases of radioactive material from the facility.
ACRS Meeting April 2, 2009
- Provide a discussion of seismically-induced damage to any structures and components that have been installed since the analysis in 1966 whose failure could impact proper operation of safety-related structures and components.
ACRS Meeting April 2, 2009
- The most recent revision of the proposed Technical Specifications contains some surveillance requirements that are less conservative than those specified in the current TSs. Provide a discussion that explains why the recommended surveillance requirements contained in ANS 15.1-2007 are inappropriate or overly conservative for the NBSR. Provide a discussion that explains how the decrease in conservatism maintains the current level of safety.
ACRS Meeting April 2, 2009
- Provide a detailed step-by-step explanation of the experiment review, approval, and implementation process.
Include discussions of the applicable requirements specified in the proposed Tss and administrative requirements that ensure no experiment will have an adverse impact on reactor safety or the health and safety of the public and staff personnel.
ACRS Meeting April 2, 2009
- Provide a discussion and analysis of the adequacy of natural circulation cooling in the event that DWV-19 is isolated during extended full-power operation. Include a discussion of the heat sinks, flow paths, peak vessel temperature, and ability of the pressure relief valve to perform its intended function. Also discuss any actions or preventative measures to mitigate the consequences of such a occurrence or measures taken to prevent it altogether.
ACRS Meeting April 2, 2009
- The moderator temperature coefficient and moderator void coefficient appeared to be inconsistent with each other. Discuss how these coefficients were determined including methods of calculation. Discuss whether these coefficients necessarily need to be consistent given the methods of calculation. Discuss how these coefficients represent the most limiting conditions in the coolant and/or how the values chosen for these coefficients provide adequate conservatism.
ACRS Meeting April 2, 2009
- Discuss the storage and disposal of Class B and Class C waste that may be generated at the NBSR during the period of the renewed license.
ACRS Meeting April 2, 2009
- Proposed TS 3.9.1,Fuel Storage, specified that all fuel elements shall be stored and handled in a geometry such that the calculated keff shall not exceed 0.90 under optimum conditions of water moderation and reflection. Provide a summary and discussion of this calculation for storage in the spent fuel pool.
ACRS Meeting April 2, 2009
- Clarify whether the confinement building design is based on loading from 100-mph sustained winds or a 100-mph wind gust.
ACRS Meeting April 2, 2009
- Discuss the derivation of the 50-year and 100-year numerical scaling factors for wind speeds. If Caribbean hurricane wind data was used to estimate the 100-year maximum wind gust speed at the NBSR site, provide a discussion of the relevance of that date to winds at the NBSR site. Otherwise, provide a discussion of the wind data used to estimate the 100-year maximum wind gust speed for the NBSR site.
ACRS Meeting April 2, 2009
- In March 2008, storms in the Washington DC metro area generated wind gust speeds of 74 mph and 60 mph measured at Regan National Airport and 66 mph measured at Dulles International Airport.
Discuss how this storm data affects the projection of the 100-year maximum wind gust speed.
ACRS Meeting April 2, 2009
- Discuss the technical basis for the applied additional rain-on-snow loading including historical data to justify the assumed 50%
rain fraction.
ACRS Meeting April 2, 2009 The End
Advisory Committee on Reactor Safeguards (ACRS) License Renewal Full Committee National Institute of Standards and Technology National Bureau of Standards Test Reactor License Renewal April 2, 2009 William B. Kennedy, Project Manager Office of Nuclear Reactor Regulation
Introduction
- National Institute of Standards and Technology (NIST) National Bureau of Standards Reactor (NBSR) License Renewal
- Topics:
- Licensing History
- Staff Review Criteria
- Overview of the Safety Evaluation Report (SER)
- Resolution of Open Items in the draft SER
- Additional Open Item in the final SER 2
Licensing History 1961
- The National Bureau of Standards applied for a construction permit and operating license for a 10 Megawatt thermal (MW(t)) heavy-water-cooled-and-moderated reactor 1963
- The Atomic Energy Commission (AEC) issued a construction permit 1967
- The AEC issued Provisional Operating License No. TR-5 3
Licensing History 1970
- The AEC issued Facility License No. TR-5 with a term of 15 years 1980
- The National Bureau of Standards applied for a 20-year renewal and an increase in the maximum licensed power level to 20 MW(t) 1984
- The NRC issued the renewed license at the increased power level for a period of 20 years NIST filed an application for license renewal 4
April 9, 2004
Regulatory Review Criteria In accordance with Section 104 of the Atomic Energy Act of 1954, as amended (the Act), the NRC must impose the minimum amount of regulation consistent with its obligations under this Act...
10 CFR Part 54 does not apply to license renewal for non-power reactors 5
Regulatory Review Criteria Non-power reactor license renewal is primarily conducted in accordance with 10 CFR Parts 20, 50, 51, and 100 (in part, for test reactors)
- Part 100 guidelines for radiological consequences of accidents apply to test reactors
- Part 100, Appendix A, Seismic and Geologic Siting Criteria for Nuclear Power Plants, does not apply 6
Staff Review Guidance NUREG-1537, Part II, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria, dated February 1996, provides the staff with review criteria, including:
- NUREGs pertinent to special areas of the review, e.g., emergency planning
- Regulatory Guides, division 2
- American National Standards Institute/American Nuclear Society ANSI/ANS-15 series standards 7
Areas of Review
- Facility siting criteria
- Structures, systems, and components
- Reactor characteristics
- Electrical power systems
- Experiment program
- Radiation protection
- Accident analyses
- Technical specifications
- Prior use of components 8
Safety Conclusions Based on its safety evaluation, the staff concludes:
- The design, testing, and performance of SSC important to safety during normal operation are acceptable; safe operation can reasonably be expected to continue
- The licensees management organization is acceptable to maintain and safely operate the reactor 9
Safety Conclusions
- The licensees research activities and programs, including experiment malfunctions, will not pose a significant risk to continued safe operation of the facility
- Exposures from and releases of radioactive effluents and waste from the facility are not expected to result in doses or concentrations in excess of the limits specified in 10 CFR Part 20, and are consistent with as-low-as-reasonably-achievable principles 10
Safety Conclusions
- The licensee has conservatively considered the consequences of a bounding maximum hypothetical accident and shown the radiological consequences to be a small fraction of those specified in 10 CFR Part 100
- The licensee has conservatively considered an appropriate range of postulated credible accidents using appropriate initiating and mitigating assumptions 11
Safety Conclusions
- The renewed Facility Operating License and TSs provide reasonable assurance that the licensee will operate the facility in accordance with the assumptions in the SAR
- No significant degradation of SSC has occurred, and the TSs will continue to provide reasonable assurance that no significant degradation of SSC will occur 12
Safety Conclusions
- The licensees physical security plan continues to be acceptable to protect its special nuclear material
- The licensees emergency plan provides acceptable assurance that the licensee will continue to be prepared to assess and respond to emergency events 13
Safety Conclusions
- Continued operation of the NBSR during the period of the renewed license poses no significant radiological risk to the health and safety of the public, facility personnel, or the environment 14
Resolution of Open Item
- Draft SER contained one open item regarding a timing requirement in the operator training and requalification program
- NRC issued an RAI on February 18, 2009
- The licensee responded March 3, 2009, stating that the requalification program shall be administered over a period not to exceed 24 months, followed by successive 24 month periods.
15
Resolution of Open Item
- The RAI response resolved the open item by changing the timing requirement in the operator training and requalification program to meet the regulatory requirement
- Final SER concludes that the program meets all applicable regulatory requirements and is consistent with standard ANSI/ANS-15.4, Selection and Training of Personnel for Research Reactors, issued 1988 16
Additional Open Item
- In addressing the concerns of the ACRS subcommittee members, the licensee identified an unrelated inaccuracy in the pump coastdown data used in two loss-of-flow accident analyses
- The licensee will perform additional analyses to determine if the inaccuracy is safety-significant
- The staff will review the analyses, verify that the conclusions in the final safety evaluation report remain valid, and present the findings to the ACRS full committee later this year 17
Backup Material
- Responses to ACRS subcommittee member concerns 18
Seismic Hazard Analysis
- NRC staff reviewed the seismic design basis for the facility (0.1 g peak ground acceleration)
- NRC staff reviewed past AEC and NRC approvals of the seismic design for the facility
- The staff concludes that the seismic design is adequate and conservative 19
Seismic Hazard Analysis
- The licensee performed a seismic walk-down that identified a wall that, if it collapsed, could affect emergency core cooling system piping
- NRC staff visited the facility to review the walk-down
- The licensee will perform a seismic analysis for a 0.1 g earthquake and reinforce the wall if necessary
- The staff finds this acceptable 20
Groundwater Monitoring
- The licensee performs groundwater monitoring by sampling surface water fed by groundwater for tritium and other nuclides
- This is consistent with analysis performed by the U.S. Geological Survey during initial licensing
- A 2006 report confirmed the original analysis
- The staff finds the current groundwater monitoring program acceptable 21
Natural Circulation Cooling
- The licensee performed an analysis of natural circulation cooling following full power operation
- The safety margin is greater than 2
- There is adequate time (more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) to manually open a valve to reestablish flow
- Even with no action, the reactor vessel will not over-pressurize
- The staff finds the analysis acceptable and the consequences are bounded by the MHA 22
Single Failure Criterion
- The staff reevaluated redundancy in systems
- Electrical power is not required for maintaining safe shutdown, so redundancy only provides defense-in-depth
- Multiple monitoring devices for a single variable have diverse designs and are electrically and physically separated
- The staff finds the level of redundancy acceptable to prevent a single failure from 23 causing an unanalyzed accident
Surveillance Requirements
- The licensee provided additional justification for relaxing surveillance requirements
- Annual emergency sump pump testing is justified by the redundancy in emergency coolant sources
- Quarterly start tests of the diesel generators is consistent with the approved standard
- Annual surveillance of the station battery is supported by operational data and experience 24
- The staff finds the surveillances acceptable
Experiment Review Process
- The licensee provided additional clarification of the extent of the experiment review and approval process
- The experiment review process meets the guidance found in the accepted standards
- The staff found that the technical specifications ensure that the licensees experiment program will not pose a significant risk to the health and safety of the public 25
Moderator Coefficients
- The licensee provided additional clarification of the consistency of the moderator void and temperature reactivity coefficients
- The coefficients are consistent when calculated for the entire coolant volume
- The coefficients are always negative
- The accident analyses do not take credit for the coefficients and are conservative
- The staff finds the licensees treatment of the 26 moderator coefficients acceptable
Waste Disposal
- The licensee provided additional information on plans for storage and disposal of Class B and Class C wastes
- The NBSR license TR-5 provides possession limits for these wastes and requires appropriate storage and disposal
- The licensee plans to construct an interim storage facility with 40 years of capacity
- The staff finds the licensees storage and 27 disposal of these wastes acceptable
Spent Fuel Pool Safety
- The licensee provided results of calculations of criticality safety for the spent fuel storage pool
- The licensee used conservative assumptions to show that the stored fuel cannot achieve criticality
- The effective multiplication factor remains below the limit of 0.9 in the technical specifications
- The staff finds the spent fuel pool storage facility acceptable for storage of spent fuel in 28 accordance with license TR-5
Site Meteorology - Wind
- The licensee provided additional information on the confinement building design for wind loads
- The building was design and built to the accepted standards at the time of construction
- The licensees derivation of the maximum 100-year return wind speed was conservative
- The American Society of Civil Engineers (ASCE) standard gives a wind speed of 96 mph which is below the design limit of 100 mph 29
Site Meteorology - Snow
- The licensee provided additional information on potential roof snow loading
- The licensees analysis is conservative compared to the ASCE standard
- The licensees calculations and the ASCE standard give maximum snow loads that are below the design load for the confinement building roof 30
Advisory Committee on Reactor Safeguards 561st ACRS Meeting April 2-4, 2009 Draft Final Regulatory Guide 1.211, "Qualification of Safety-Related Cables and Field Splices for Nuclear Power Plants" Comments of the Nuclear Utility Group on Equipment Qualification
Nuclear Utility Group on Equipment Qualification ("NUGEQ")
- Formed in 1981 to address issues related to equipment qualification.
- NUGEQ includes utilities operating nuclear power reactors in the United States and Canada.
- NUGEQ represents over 95 operating nuclear power plants in the United States William A. Horin - Winston & Strawn, Counsel to NUGEQ Philip M. Holzman - Strategic Technologies & Resources, Inc., Consultant to NUGEQ
"Environmental Qualification of Low Voltage Instrumentation and Control Cables"
- NUGEQ actively participated in industry interactions with NRC staff - 1993 to 2003:
- Clear industry support for cable CM research NUMARC comments to NRC, "we believe that research in the area of condition monitoring may be useful toward developing information for assessing the actual service life of equipment." (Reprinted in 1993 workshop proceedings NUREG/CP-0135 (pp. H-3 to H-6))
- Clear NRC staff interest in cable CM 11/15/96 memorandum to the Commission - staff states it would be prudent to have some form of cable CM
- NRC undertook a new cable test program to address six issues.
Two of these issues involved cable condition monitoring (CM):
Issue 5 - whether condition monitoring methods exist that could be used to monitor the condition of cables in situ, and Issue 6 - whether condition monitoring could be used to predict the accident survivability of cables
"Environmental Qualification of Low Voltage Instrumentation and Control Cables" Consideration of Cable Conditioning Monitoring
- October 2000 - testing completed; NRC Staff briefs ACRS on GSI-168 Subsequent public meetings and interactions including input on the need for monitoring plant environments and cable CM
- June 2002 - NRC presents GSI-168 proposed resolution to ACRS, including results of CM research and estimates of CM risk benefits
"Environmental Qualification of Low Voltage Instrumentation and Control Cables"
- NRC Staff Conclusions Regarding Cable Condition Monitoring Methods - No single technique was effective and a combination of techniques would be needed.
Risk Benefits - the benefits of reducing cable failure probability to zero
[an unrealistic but bounding condition that assumed perfect condition monitoring techniques exist] were modest at best.
- ACRS and NRC Conclusion Actual cable condition monitoring benefits, if any, would be even less than modest.
- GSI-168 Contractor Report Condition Monitoring results obtained in laboratory setting Additional testing needed to determine effect of plant conditions on use of techniques in situ
"Qualification of Safety-Related Cables and Field Splices for Nuclear Power Plants"
- Draft Guide DG-1132 NRC concluded some form of cable CM needed to establish reasonable assurance of performance.
NRC asserted CM is needed in lieu of "doing nothing" NUGEQ perspective
- "Doing nothing" is mischaracterization
- Environmental Monitoring
- Walkdowns/Inspections
- Corrective Action Programs
- Efficacy of CM techniques not supported by the record
- GSI-168 or subsequent information
- Risk benefit of CM (even assuming perfect techniques) not supported by the record
"Qualification of Safety-Related Cables and Field Splices for Nuclear Power Plants"
- NUGEQ Conclusions and Recommendations Environmental Monitoring & walkdowns/inspections are proven &
effective (NRC and industry concur).
Condition Monitoring can supplement environmental monitoring and walkdowns/inspections when the method is proven and effective for the cable design and conditions of concern.
Cable aging management activities should be focused on risk significant cables.
Cable aging management activities should be focused on "at risk" cables (those with the least margin).
Regulatory Position 7 in Regulatory Guide should be modified to reflect above perspectives.
"Qualification of Safety-Related Cables and Field Splices for Nuclear Power Plants" NUGEQ Proposed Language (7) Programs for monitoring of environmental conditions (such as temperature, radiation levels) coupled with walkdowns to look for visible signs of anomalies attributable to aging with particular emphasis on the identification of localized adverse environments or hot spots should be implemented for power, instrumentation, and control cables whose failures could disable risk-significant equipment. Where appropriate these activities should be supplemented with condition monitoring techniques that are proven to be effective for assessing in situ degradation for the cables and conditions of concern. Such activities are most effective when applied to cables with the least margin due to qualification levels, service conditions, or other application considerations. For safety-related power cables, which are inaccessible or installed underground and may be exposed to condensation and wetting, appropriate inspection, testing and monitoring programs should be implemented to detect degradation.
Query: Why is this language unreasonable?
Regulatory Guide 1. 211 Qualification of Safety-Related Cables and Field Splices ACRS Meeting: April 2, 2009 Satish Aggarwal Division of Engineering Office of Nuclear Regulatory Research 301-251-7627 1
Regulatory Guide 1. 211 BACKGROUND Standards Activities:
-IEEE Std 383-1974
-IEEE Std 383-2003 published in June 2004 Regulatory Activities:
-DG-1132 was issued for public comment in June 2007 with 10 exceptions to IEEE Std 383-2003.
-Received comment letters from 5 organizations.
-Staff met with the ACRS on September 4, 2008.
2
ACRS Concerns and the Staff Responses ACRS:
- 1) Provide the definition of risk-significant safety-related equipment (e.g. cable).
Staff:
The terminology risk significant safety-related equipment has been removed from the RG. The condition monitoring of the safety-related cables is limited to those covered by the maintenance rule.
3
Regulatory Guide 1.211 (March 2009)
C. Regulatory Position (Revised)
(6) Programs for monitoring of environmental conditions (such as temperature, radiation levels), and condition monitoring should be implemented for power, instrumentation, and control cables (the condition monitoring of safety-related cables may be limited to those cables covered by 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants.). Condition monitoring programs may include any appropriate technique(s), supplemented with walkdowns to look for visible signs of anomalies attributable to aging with particular emphasis on the identification of localized adverse environments or hot spots. For safety-related power cables that are inaccessible or installed underground, appropriate inspection, testing and monitoring programs should be implemented to detect degradation.
The condition monitoring and its frequency may be adjusted based on the cable performance.
4
ACRS Concerns and the Staff Responses ACRS:
- 2) Clarification is needed in the scope of the guide which should be limited to safety-related cables.
Staff:
The scope of the guide is limited to only safety-related cables.
5
ACRS Concerns and the Staff Responses ACRS:
- 3) The cables under Appendix R (Fire Protection) are not within the scope of the RG.
Staff:
The Appendix R requirements are not covered within this RG, however, they are covered by:
- Regulatory Guide 1.189 Fire Protection for Nuclear Power Plants; March 2007; Rev 1.
- NUREG-0800 Standard Review Plan Sec 9.5.1: Fire Protection System; October 2003; Rev 4, (Formerly NUREG-75/087 March 1979).
- Guidelines for Fire Protection for Nuclear Power Plants; Branch Technical Position ASB 9.5-1; May 1976.
- Guidelines for Fire Protection for Nuclear Power Plants; Branch Technical Position ASB 9.5-1; Rev 1; March 1978.
- Recommended Fire Protection Policy and Program Actions (GL 85-01);
October 26, 1984.
ACRS Concerns and the Staff Responses ACRS:
- 4) Justify the need for testing specialty cables with connectors.
Staff:
This regulatory position was removed from the RG.
7
ACRS Concerns and the Staff Responses ACRS:
The RG does not offer any specific condition monitoring techniques to assess physical and operational conditions of the cables. The requirement for condition monitoring is being imposed without any conditions monitoring techniques being endorsed by the staff.
Staff:
The condition monitoring of safety-related cables should be implemented. The licensees need to choose the most applicable technique(s) based on the cable type and environment. There are about 14 condition monitoring techniques available.
8