ML18220A899
| ML18220A899 | |
| Person / Time | |
|---|---|
| Issue date: | 07/11/2018 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-3805 | |
| Download: ML18220A899 (335) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactors Safeguards Open Session Docket Number: (n/a)
Location: Rockville, Maryland Date: Wednesday, July 11, 2018 Work Order No.: NRC-3805 Pages 1-335 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 655th MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +
8 OPEN SESSION 9 + + + + +
10 WEDNESDAY 11 JULY 11, 2018 12 + + + + +
13 ROCKVILLE, MARYLAND 14 + + + + +
15 The Advisory Committee met at the Nuclear 16 Regulatory Commission, Two White Flint North, Room 17 T2B1, 11545 Rockville Pike, at 8:30 a.m., Michael L.
18 Corradini, Chairman, presiding.
19 COMMITTEE MEMBERS:
20 MICHAEL L. CORRADINI, Chairman 21 RONALD G. BALLINGER, Member 22 DENNIS C. BLEY, Member 23 CHARLES H. BROWN, JR. Member 24 MARGARET SZE-TAI Y. CHU, Member 25 VESNA B. DIMITRIJEVIC, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 WALTER L. KIRCHNER, Member 2 JOSE MARCH-LEUBA, Member 3 HAROLD B. RAY, Member 4 JOY L. REMPE, Member 5 PETER RICCARDELLA, Member 6 GORDON R. SKILLMAN, Member 7 MATTHEW SUNSERI, Member 8
9 DESIGNATED FEDERAL OFFICIALS:
10 CHRISTOPHER BROWN 11 WEIDONG WANG 12 KATHY WEAVER 13 ALSO PRESENT:
14 HUDA AKHAVANNIK, NRR 15 ROSSNYEV ALVARADO, NRR 16 STEVEN ARNDT, NRR 17 SURINDER ARORA, NRO 18 AYO AYEGBUSI, NRO 19 ANTONIO BARRETT, NRO 20 LUIS BETANCOURT, NRO 21 SUSHIL BIRLA, RES 22 JOSH BORROMEO, NRR 23 ERIC BOWMAN, OCM 24 ANNA BRADFORD, NRO 25 MIKE BREACH, NRR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 ALEXANDRA BURJA, NRO 2 LUISSETTE CANDELARIO QUINTANA, NRO 3 HAROLD CHERNOFF, NRR 4 NAN CHIEN, NRO 5 JEFF CIOCCO 6 MICHAEL COOK, GE Hitachi 7 SAMIR DARBALI, NRR 8 MARK DeWIRE, BSEP 9 THINH DINH, NRO 10 BERNARD DITTMAN, RES 11 TIM DRZEWIECKI, NRO 12 ISMAEL GARCIA, NRO 13 JAMES GILMER, NRO 14 RAJ GOEL, NRO 15 BRIAN GREEN, NRO 16 DAN GREEN, TVA 17 RALPH GRUMMER, Farawila, et al.
18 MAURICIO GUTIERREZ, RES 19 SYED HAIDER, NRO 20 NICHOLAS HANSING, NRO 21 MICHELLE HAYES, NRO 22 RAUL HERNANDEZ, NRO 23 SEUNGJU HAN, KHNP 24 ANDY HON, NRR 25 JOHN HONCHARIK, NRO NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 BRIAN HUGHES, NRO 2 SEOKHWAN HUR, KEPCO E&C 3 ATA ISTAR, NRO 4 DIANE JACKSON, NRO/SCVB 5 JAE HOON JEONG, KEPCO 6 SUNGHUAN JUN, KEPCO E&C 7 REBECCA KARAS, NRO 8 MARYAM KHAN, NRO 9 JUNGHO KIM, KHNP 10 TAEHAN KIM, KHNP/KEPCO E&C 11 YUNHO KIM, KHNP 12 RONALD KING, TVA 13 TATSURO KOBAYASHI, TEPCO 14 ROBERT KRSEK, OCM 15 HIEN LE, NRO 16 TUAN LE, NRO 17 KIWON LEE, Doosan 18 YUEH-LI LI, NRO 19 KWANGIL LIM, KEPCO E&C 20 MARK LINTZ, NRO 21 WILL LONG, Duke Energy 22 TIM LUPOLD, NRO 23 GREGORY MAKAR, NRO 24 MICHAEL D. MAZAIKA, NRO 25 MICHAEL McCOPPIN, NRO NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 ALAN MEGINNIS, Framatome 2 JILL MONAHAN, Westinghouse 3 WENDELL MORTON, NRR 4 JEFF NOLIN, BSEP 5 CHANG-SOK OH, KNF 6 JONATHAN ORTEGA-LUCIANO, NRO 7 SUNWOO PARK, NRO 8 PRAVIN PATEL, NRO 9 HANH PHAN, NRO 10 DAVID RAHN, NRR 11 SHEILA RAY, NRR 12 FARIDEH SABA, NRR 13 AHSAN SALLMAN, NRR 14 CAYETANO SANTOS, NRO 15 THOMAS SCARBROUGH, NRO 16 MOHAMED SHAMS, Office of Commissioner Wright 17 JOHN SIPHERS, Duke Energy 18 ROB SISK, Westinghouse 19 MATT SMITH, Westinghouse 20 MICHAEL SMITH, NRR 21 RICHARD STATTEL, NRR 22 ED STUTZCAGE, NRO 23 DINESH TANEJA, NRO 24 BRIAN THOMAS, RES 25 ROGER L. THOMAS, JR., Duke Energy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 VAUGHN THOMAS, NRO 2 BOYCE TRAVIS, NRO 3 NANETTE VALLIERE, COMM/OCMSB 4 ANDREA D. VEIL, ACRS Executive Director 5 BOOMA VENKATARAMAN, NRR 6 HANRY WAGAGE, NRO 7 WILLIAM WARD, NRO 8 MIKE WATERS, NRR 9 JENNIFER WHITMAN, NRR 10 STEVE WILLIAMS, NRO 11 TOM WILLIAMSON, Duke Energy 12 GEORGE WUNDER, NRO 13 ANDREW YESHNIK, NRO 14 STEPHEN YODERSMITH, BSEP 15 DEANNA ZHANG, NRR 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 C O N T E N T S 2 Call to Order and Opening . . . . . . . . . . . . 8 3 Brunswick Steam Electric Plant, Units 1 and . . . 9 4 2, MELLLA+ Application 5 Licensee Presentation . . . . . . . . . . . . . . 10 6 Staff Presentation . . . . . . . . . . . . . . . 30 7 Opportunity for Public Comment . . . . . . . . . 39 8 Digital Instrumentation and Controls . . . . . . 39 9 Interim Staff Guidance-06, "Licensing 10 Process" Draft Revision 2, and 11 Integrated Action Plan for Modernization 12 of the NRC's Digital I&C Regulatory Structure 13 Staff Presentation . . . . . . . . . . . . . . . 41 14 Opportunity for Public Comment . . . . . . . . 117 15 APR 1400: Selected Safety Evaluations Associated 16 with Reactor Design Application . . . . . . . . 118 17 Public Comment . . . . . . . . . . . . . . . . 184 18 Adjourn . . . . . . . . . . . . . . . . . . . . 187 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 P R O C E E D I N G S 2 8:29 a.m.
3 CHAIR CORRADINI: Okay, the meeting will 4 now come to order. This is the first day of the 655th 5 meeting of the Advisory Committee on Reactor 6 Safeguards. During today's meeting, the Committee 7 will consider the following: Brunswick Steam Electric 8 Plant, Units 1 and 2, MELLLA+ application; Digital 9 Instrumentation and Controls Interim Staff 10 Guidance 06; APR1400 Safety Evaluations associated 11 with the reactor design application, and preparations 12 of ACRS reports.
13 The ACRS was established by statute and is 14 governed by the Federal Advisory Committee Act, or 15 FACA. As such, this meeting is being conducted in 16 accordance with the provisions of FACA. That means 17 that the Committee can only speak through its 18 published letter reports. We hold meetings to gather 19 information to support our deliberations.
20 Interested parties who wish to provide 21 comments can contact our offices requesting time after 22 The Federal Register notice describing a meeting is 23 published. That said, we have set aside 10 minutes 24 for extemporaneous comments from members of the public 25 attending or listening to our meetings. Written NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 comments are also welcome.
2 Mr. Weidong Wang is the Designated Federal 3 Official for the initial portion of this meeting.
4 Portions of the sessions of the Brunswick 5 MELLLA+ and APR1400 Safety Evaluations associated with 6 reactor design application may be closed in order to 7 discuss and protect designated information that is 8 proprietary.
9 The ACRS section of the U.S. NRC public 10 website provides our charter, bylaws, letter reports, 11 and full transcripts of all full and subcommittee 12 meetings, including all slides presented to the 13 meeting.
14 We've received no written comments or 15 requests to make oral statements from members of the 16 public regarding today's session.
17 There will be a phone bridgeline open. To 18 preclude interruption, the phone will in a listen-in-19 only mode during the presentations and Committee 20 discussions.
21 A transcript of a portion of the meeting 22 is being kept, and it is requested that speakers use 23 the microphones, identify themselves, and speak with 24 sufficient clarity and volume, so they may be readily 25 heard.
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10 1 Also, just to remind everybody, could you 2 please silence your cell phones or turn off your 3 devices, so we don't get interrupted by any sort of 4 noises?
5 So, I'll turn this over to Dr. Rempe to 6 lead us through the first portion of the meeting.
7 MEMBER REMPE: Thanks, Mike.
8 So, May 16th, the Power Uprates 9 Subcommittee reviewed the license amendment request 10 and the associated NRC Draft Safety Evaluation for the 11 Brunswick Steam Electric Plant to operate in the 12 expanded Maximum Extended Load Line Limit Analysis 13 plus domain. This is the fifth plant to submit an LAR 14 for operation in the MELLLA+ domain, but the first to 15 rely on GEH methods with Framatome, formerly AREVA, 16 ATRIUM 10XM fuel.
17 On May 15th, the Thermal-Hydraulic 18 Subcommittee reviewed results from confirmatory plant-19 specific TRACE/PARCS calculations that the staff 20 completed to assist them in their evaluation of this 21 application. At the end of our May 16th meeting, the 22 Subcommittee concluded that this request was ready for 23 consider by the full Committee.
24 And at this point, I would like to ask, 25 Andy, are you the one who is going to start or is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 there someone else?
2 MR. HON: No, the licensee is going to 3 start.
4 MEMBER REMPE: Oh, okay. I would like to 5 licensee to please come forward and start our 6 discussion.
7 MR. NOLIN: Good morning. I'm Jeff Nolin.
8 I'm the General Manager of Engineering at Brunswick 9 Nuclear Plant.
10 I would like to thank you for providing us 11 the opportunity to come and discuss the license 12 amendment for Brunswick's implementation of MELLLA+,
13 to answer questions, and talk about our readiness for 14 implementation of the project.
15 The objectives of what we would like to 16 talk about today include why we're pursuing the 17 implementation of MELLLA+; describe some of the key 18 aspects of it; discuss readiness and talk about our 19 intentions for implementation timing.
20 Relative to the timing, Brunswick is 21 looking to implement the MELLLA+ on both Unit 1 and 22 Unit 2 in the fall of 2018. Some of the operating 23 parameters that we're working with: Unit 2 has a 24 planned refueling outage in the spring of 2019.
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12 1 will be entering a number of deep downpowers for end 2 of cycle and final feedwater temperature reduction in 3 the fall. So, we're looking to implement in the third 4 quarter of 2018 just from an operating preference for 5 the units. We would like to implement both units at 6 the same time to make sure that the operators are 7 working off of a common platform for each unit.
8 A little bit of an overview of Brunswick.
9 Brunswick is a two-unit BWR-4 with a Mark I 10 containment. We are operating, in our license renewal 11 period of extended operation, Brunswick has been 12 operating for 43 and 42 units, respectively. Unit 2 13 is the lead unit.
14 We have been operating with the extended 15 power uprate, 120-percent uprate, since 2004, so 14 16 and 13 years on each unit, which is a little bit 17 different with the MELLLA+ application in that we've 18 been operating with an extended power uprate for more 19 than 13-14 years. And so, this is really an 20 application for MELLLA+ as opposed to a power uprate 21 with MELLLA+. So, it's a little bit different than 22 some of the other license amendments that have been 23 submitted previously.
24 We operate with a 24-month operating 25 cycle. We've transitioned to Framatome fuel in 2008-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 2009. So, again, about a decade of operation with 2 Framatome fuel, and we have full-core ATRIUM 10XM fuel 3 right now. We've been on ATRIUM 10XM fuel since the 4 2011-2012 transition.
5 The Brunswick plant, the background of the 6 plant, with the extended power uprate, we dramatically 7 reduced the flow window that the plant operates on 8 from approximately 24 percent to a 6-percent flow 9 window. So, MELLLA+ restores the operating margin for 10 the plant. The primary drivers for that are fuel 11 reactivity manipulations for the operators associated 12 with those downpowers. There are some side benefits 13 relative to recirc pump operation, that the extended 14 operation of that we believe will help recirc pump 15 reliability as well.
16 Finally, relative a project of 17 implementation readiness, we've completed the plant 18 modifications to increase our standby liquid control 19 tanks from enrichment of 47-percent to 92-percent B-10 20 enrichment. Those were completed in 2016 and 2017.
21 We've also implemented the modifications to the e-22 prompts for the power range monitors. Those were 23 completed in 2016 as well. The operators have 24 performed introduction training and, then, more 25 detailed training on MELLLA+, including simulator NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 sessions with the MELLLA+ operating domain, and we'll 2 have more discussion on that in subsequent slides.
3 Our phase 2 implementation of the project 4 will include update of procedures and tech specs, the 5 engineering changes. We'll transition our stability 6 solution to the DSS-CD option with the implementation.
7 The implementation will also include a 8 period of special testing to verify thermal-hydraulic 9 stability. That's a series of five points on each 10 unit that we will run through and collect data, 11 including level and pressure perturbations to verify 12 stability. And that will be part of the tech spec 13 implementation.
14 With that, I'll turn it over to Mr.
15 Siphers for the design discussion.
16 MR. SIPHERS: Okay. Good morning. My 17 name is John Siphers. I'm General Manager of Nuclear 18 Fuel Design for Duke Energy, and I would like to 19 describe some of the analyses that went into the LAR 20 that we submitted for MELLLA+.
21 As was previously stated, we have a little 22 bit of a different structure than is typically seen 23 for MELLLA+ applications. We are using the GEH 24 Topical Report for MELLLA+, but we have Framatome 25 fuel.
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15 1 In doing the analysis required by the LAR, 2 we have done all of those analyses, but they required 3 different vendors to do the different piece parts of 4 that analysis to complete the full set. GE provided 5 the overall plant response, specifically ATWS and 6 ATWSI and stability solution work, and Framatome 7 performed the remainder of the analyses, the kind of 8 typical analyses that are done on a reload-by-reload 9 basis to quantify the fuel design attributes each 10 cycle.
11 And as Jeff mentioned earlier, both 12 vendors have had a long history of support for the 13 Brunswick plant. We used GE fuel from initial startup 14 up to and through our power uprate, and we 15 transitioned to Framatome fuel in 2008 and have been 16 using Framatome fuel ever since. So, we've been in a 17 position where both vendors are very familiar with the 18 Brunswick plant.
19 One last note here was on the no impact 20 that was noted in the MELLLA+ Topical Report from ECCS 21 net positive suction head from the implementation of 22 MELLLA+. And therefore, there was no change to the 23 containment accident pressure credit that we 24 originally received in the extended power uprate 25 application.
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16 1 Because of the structure of the project, 2 both vendors doing parts of the analysis, during our 3 pre-submittal meetings there were questions asked 4 about the applicability of GEH methods to Framatome 5 fuel and the applicability of Framatome methods to the 6 MELLLA+ region. Framatome methods have been 7 benchmarked at core conditions at other plants that 8 are equivalent to what we're going to see at Brunswick 9 from a power and flow standpoint. And therefore, the 10 information that we've included in the LAR should 11 allow this SER for Brunswick to be issued without 12 restrictions in those areas. And similarly, the LAR 13 information we presented shows the GEH models were 14 able to accurately represent the Framatome fuel 15 design.
16 One of the ways we did that was that we 17 transferred information directly from Framatome to GE 18 as part of that development. So, GE was allowed to 19 explicitly model the fuel. We also participated in 20 that at Duke Energy by working on the thermal-21 hydraulic data that went from Framatome to GE, and we 22 had had a history of doing that for many years prior 23 to the MELLLA+ LAR.
24 Following the LAR, during one of the 25 audits, there were some additional questions raised.
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17 1 And in one of the RAIs, we provided some significant 2 comparisons to MELLLA+ predicted core operation and 3 showing the results from GE models and the results 4 from Framatome models, and those were included in one 5 of the RAIs and show excellent agreement between the 6 two models for what would be predicted at Brunswick.
7 One of the more significant areas of focus 8 when operating the MELLLA+ regime, obviously, is the 9 response of the plant when you're on a high power rod 10 line or the high power low-flow conditions. Both the 11 ATWS condition and the potential for ATWS for 12 instability were modeled by GE. And because the 13 analysis, again, was a GE model of a Framatome fuel 14 bundle, GE did a lot of sensitivity cases on fuel 15 parameters that would be important to the outcome of 16 those results. And GE will present a lot more of the 17 information regarding those sensitivity cases later in 18 the GE proprietary session.
19 Also during the MELLLA+ audit, there was 20 a significant amount of discussion with the NRC 21 reviewers on the Tmin model that's used for the 22 results of the ATWSI analysis. And as a result of 23 that discussion, we ran several cases, and had GE run 24 several cases, that compared the results of that 25 model. And that's also going to be presented later in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 the proprietary session as well. We believe that 2 those sensitivity cases show that the model 3 effectively analyzes the MELLLA+ operating regime from 4 the standpoint of completely protecting the fuel 5 parameters of concern.
6 A couple of decisions that we made in our 7 implementation of MELLLA+. One decision that we made 8 was that we would transition to the DSS-CD system for 9 thermal-hydraulic instability monitoring during the 10 development. The additional protection that that 11 system offers is the confirmation density algorithm 12 for detection of thermal-hydraulic instability. And 13 in this new software/hardware configuration, that 14 algorithm is really layered on top of all the 15 algorithms that were previously present in the option 16 3 system. So, we believe that that offers us 17 additional confirmation or additional protection 18 against thermal-hydraulic instability. And that will 19 be the licensing basis method that we use going 20 forward.
21 The second decision that we made early on 22 in the project was to ensure the MELLLA+ operating 23 region would not adversely impact the ATWS analysis 24 and to ensure that we elected to significantly 25 increase our Boron-10 enrichment in our standby liquid NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 control system from 47 to 92 percent out of the 2 Boron-10. The outcome of that is it accelerates the 3 shutdown of the core during an ATWS condition and, 4 effectively, by doing that, limits the heat transfer 5 to the suppression pool that occurs during that 6 situation. And if you look at the information in the 7 box there, one of the interesting outcomes of that is 8 that the amount of additional shutdown that we've 9 gotten from the increased Boron is that the peak pool 10 temperature from our EPU MELLLA+ plus conditions is 11 actually less than the peak pool temperature was when 12 we originally licensed the core under the lowest core 13 flow we could get under the original power. So, we 14 believe this is actually a quantifiable increase in 15 safety that we've made as part of the project.
16 MEMBER SKILLMAN: John, how much is the 17 delta, please? Approximately, what is the delta 18 between what the original was and what the negative 19 effect of the Boron --
20 MR. SIPHERS: In terms of?
21 MEMBER SKILLMAN: Delta degrees 22 Fahrenheit.
23 MR. SIPHERS: Yes, it's the 189 to 174.
24 MEMBER SKILLMAN: Okay.
25 MR. SIPHERS: So, you're looking at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 degrees.
2 MEMBER SKILLMAN: Oh, thank you. Thank 3 you.
4 MR. SIPHERS: Yes, sir.
5 MEMBER MARCH-LEUBA: John, out of 6 curiosity, how much money has this Boron modification 7 cost? Because it is a really good modification. It 8 improves the safety of the reactor significantly.
9 MR. SIPHERS: I have to ask Stephen to 10 comment on that.
11 MR. YODERSMITH: This is Stephen 12 Yodersmith from the Brunswick plant.
13 It was about a million dollars for each 14 unit. So, it was a significant investment in --
15 MEMBER MARCH-LEUBA: It's not 16 insignificant.
17 MR. YODERSMITH: The Boron, the enriched 18 B-10 powder itself is very expensive. So, just the 19 powder itself was, say, 750 grand, and then, the labor 20 and the time to do the modification and the 21 engineering work.
22 MEMBER MARCH-LEUBA: I can just say from 23 other licensees that the most expensive part, the most 24 difficult part was to get rid of the old Boron.
25 Nobody wanted it.
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21 1 (Laughter.)
2 MR. YODERSMITH: Yes, nobody did want it.
3 Yes, we tried to stash in the FLEX dome, thinking that 4 might be a good option, and the feedback was it's not 5 enough water. Even though it's got Boron in it, it's 6 just not enough water. So, yes. No, we couldn't sell 7 it to anybody. Nobody wanted it.
8 MEMBER MARCH-LEUBA: So, just keeping it 9 in a 50-gallon tank somewhere?
10 MR. YODERSMITH: There's a stability pond 11 that we have onsite. And so, it was analyzed by our 12 Chemistry Department and by our RP Department.
13 There's no radioactivity in it. And since it is just 14 Boron, we were able to put it in the stability pond.
15 So, it was properly evaluated for the environmental 16 impacts, which were none, and we are able to store it 17 there.
18 MEMBER MARCH-LEUBA: Thank you.
19 MR. YODERSMITH: Yes, sir.
20 MEMBER BALLINGER: You could start up your 21 own shielding company?
22 (Laughter.)
23 MR. YODERSMITH: Something, yes.
24 MEMBER BALLINGER: Make concrete.
25 MR. YODERSMITH: Yes, no kidding. Yes.
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22 1 Yes. Yes, the 47 percent was still very enriched, and 2 we were surprised nobody wanted it.
3 MR. SIPHERS: All right. If there are no 4 further questions, I'll turn it over to Mark DeWire, 5 who will describe the validity of the operator actions 6 required under MELLLA+ and the training that Brunswick 7 operators received.
8 MR. DeWIRE: Hi. Good morning. I am Mark 9 DeWire. I'm Assistant Ops Manager Shift at the 10 Brunswick station.
11 As has been mentioned by Mr. Siphers and 12 Mr. Nolin, we did conduct operator training. We 13 started off in the year 2017, in the spring, with a 14 high-level classroom overview of MELLLA+ and what was 15 going to be coming forward with that.
16 We came back, followed back around in the 17 fall, October-November timeframe, with some more 18 classrooms and tech spec workbook exercises; going in 19 the simulator, doing some demonstrations and looking 20 at some equipment changes that had happened in there.
21 A lot of the operator training happened 22 around the time-critical operator action of 120 23 seconds for initiating reactor water level reduction.
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23 1 that we did.
2 With regards to the time-critical operator 3 action, we did receive training on that. We are 4 trained from ATWS conditions, from initial training, 5 and then, through continuing training. So, this is 6 really just kind of a refresher on the time-critical 7 operator action that would be established.
8 We ran three high power ATWS simulator 9 scenarios per crew. And then, in February of this 10 year, the NRC came down and did an audit of the time-11 critical operator actions associated with those ATWS 12 actions.
13 As stated, we did three simulator 14 scenarios per crew. With 12 crews, that gave us 36 15 scenarios. We did do timing on the time-critical 16 operator action. That was the average time was 85 17 seconds with a deviation of 16 seconds. And then, 18 that proved that the operating crews were able to 19 effectively get the time-critical operator action 20 within the required timeframe with margin.
21 MEMBER MARCH-LEUBA: Hey, just out of 22 curiosity, how many time-critical operator actions do 23 you have in the plant? Is it two or is it 200?
24 MR. DeWIRE: It's not 200.
25 MEMBER MARCH-LEUBA: A dozen?
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24 1 MR. DeWIRE: It may be 25 to 30, somewhere 2 in that area. We have them broken down into an hour 3 or less, you know, and then, you've got specific ones, 4 like 120 seconds associated with reactor water level.
5 You get 20 minutes with control building HVAC. So, 6 there's various actions that are out there. This is 7 one of the more limiting ones by far.
8 MEMBER MARCH-LEUBA: And how often do they 9 get tested? Will you repeat this test every five 10 years or every --
11 MR. DeWIRE: It becomes part of the LOCT 12 scenarios and initial scenarios to have that time-13 critical operator action to meet that, whenever you do 14 that evaluated scenario.
15 MEMBER MARCH-LEUBA: Was the example 16 operators that we didn't have to re-license?
17 MR. DeWIRE: That's correct. And then, 18 the actual time-critical operator actions are 19 contained with their own procedures against their own 20 validations on a periodic basis. And if you don't 21 meet those bases, you start off with putting in the 22 corrective action process and figure out what happened 23 via that way.
24 MEMBER MARCH-LEUBA: Thank you.
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25 1 little behind schedule, or ahead of schedule, we've 2 got time. Talk about time-sensitive actions. The 3 operator action to inject the SLC is a time-sensitive 4 action. How many of those do you have and what type 5 of validation is done with that?
6 MR. DeWIRE: It's in the same program as 7 the time-critical operator action. Containment is in 8 the same procedures, so they would be validated the 9 same way --
10 MEMBER REMPE: Oh, really?
11 MR. DeWIRE: -- on a periodic basis.
12 MEMBER REMPE: Okay. And is there about 13 30 of them also?
14 MR. DeWIRE: Somewhere around that area, 15 yes. I don't have the exact number in my head. It's 16 been a while since I did that audit.
17 MEMBER REMPE: Okay. Thank you.
18 MR. DeWIRE: Yes.
19 MEMBER SKILLMAN: Mark, may I ask this, 20 please?
21 MR. DeWIRE: Yes, sir.
22 MEMBER SKILLMAN: Of your 12 operating 23 crews, can you speak to how many did not know an ATWS 24 scenario was going to be presented to them? And 25 hence, they were not prepared and waiting for ATWS.
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26 1 They were actually focused on something else when the 2 ATWS event was introduced.
3 MR. DeWIRE: You're talking about for 4 the --
5 MEMBER SKILLMAN: Crew training.
6 MR. DeWIRE: For the quarterly, for the 7 training?
8 MEMBER SKILLMAN: Yes.
9 MR. DeWIRE: They knew they were getting 10 trained on ATWS. Now the scenarios, you don't walk in 11 and put a countdown time and say, okay, now the ATWS 12 is going to begin. You start them off with some 13 event, and then, it progresses into an ATWS. So, they 14 know they're in there for ATWS training certainly, but 15 they're not on station ready to go with prescripted 16 actions or anything like that.
17 MEMBER SKILLMAN: Are there any scenarios 18 where they're not aware there's going to be an ATWS, 19 but you know that is what you're going to subject them 20 to, so it truly is a surprise?
21 MR. DeWIRE: Absolutely. When we do 22 quarterly -- or testing, cyclical training testing in 23 the simulator, one of the scenarios that we can give 24 them is an ATWS, and that will be in there. So, they 25 have no idea it's coming then.
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27 1 MEMBER SKILLMAN: Okay. Thank you.
2 MR. DeWIRE: Yes, sir. Any other 3 questions on that?
4 (No response.)
5 MR. DeWIRE: All right. In conclusion, 6 then, I would just like to wrap it up with the 7 implementation of the MELLLA+ significant benefits 8 that we talked about. One of the ones near and dear 9 to my heart is the greater flexibility in using core 10 flow to control reactivity. It's a lot less shots on 11 goal for the number of downpowers and reactivity 12 manipulations that the station and the operators have 13 to perform, and it increases the station's capacity 14 factor during the operating cycle.
15 We'll be ready to implement the MELLLA+
16 license amendment, the DSS-CD firmware, and SLC.
17 We've already completed those, as we've discussed.
18 The training, we've completed the training on the 19 MELLLA+ equipment, procedures, and the required 20 actions. The final power and future minor setpoint 21 engineering change is approved, and implementation and 22 a test plan has been established. And as Mr. Nolin 23 alluded to, we're requesting approval to support the 24 third quarter of 2018 implementation.
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28 1 DSS-CD has already been implemented and is running?
2 You just have jumped it out today, correct?
3 MR. DeWIRE: That's correct.
4 MEMBER MARCH-LEUBA: So, does it look good 5 with respect to noise?
6 MR. DeWIRE: Yes, I haven't seen any 7 issues with it.
8 MEMBER MARCH-LEUBA: How long has it been 9 running? A year?
10 MR. SIPHERS: Since 2016.
11 MR. DeWIRE: 2016, is that right?
12 MEMBER MARCH-LEUBA: A couple of years?
13 MEMBER RICCARDELLA: Why does it increase 14 capacity factor? What's the mechanism for that?
15 MR. SIPHERS: Less downpowers.
16 MEMBER MARCH-LEUBA: Control those --
17 MR. DeWIRE: So, we're coming into the 18 fall where I start to die off pretty rapidly with my 19 k-effectives. So, I'm having to do a lot more 20 downpowers and a lot more watt adjustments in order to 21 maintain 100 percent. If I can extend this flow 22 window out, I can just run the flow up and maintain 23 the power on that rod line. So, there's less 24 downpowers, less time down, and increased production 25 factor.
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29 1 MR. SIPHERS: One of the things in a BWR, 2 when we adjust control rods, we typically like to do 3 that at a lower core power.
4 MEMBER RICCARDELLA: Oh, I see.
5 MR. SIPHERS: So, any type of rod 6 adjustment that we do involves reducing flow to a very 7 low power, adjusting the rods, and then, kind of 8 ramping back up to higher power.
9 MEMBER RICCARDELLA: I got you. Okay. I 10 understand. Thank you.
11 MR. NOLIN: So, from an operator burden 12 standpoint, you have less downpowers. But, from a 13 safety standpoint, you have less rod manipulations as 14 well.
15 MEMBER MARCH-LEUBA: I have one more 16 question.
17 MEMBER REMPE: One more question? Okay.
18 MEMBER MARCH-LEUBA: Can you skip up to 19 slide 21? That serves you well for having backup 20 slides.
21 (Laughter.)
22 MEMBER MARCH-LEUBA: So, those are the 23 test points, A, B, C, D, and E, right where you are 24 going to do the stability tests?
25 MR. YODERSMITH: Yes.
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30 1 MEMBER MARCH-LEUBA: Are those results 2 going to be -- I assume they are not going to be 3 public, but are they going to be shared with Framatome 4 and/or GE? Or are you going to keep them by 5 yourselves or? What type of benchmark do you plan to 6 do, especially analytical analysis?
7 MR. YODERSMITH: Yes, we plan on sharing 8 the results with GE and Framatome, absolutely, and 9 then, sharing, one, our stability results are in line 10 with what GE would expect and what we would expect, as 11 the site, and from the TIP standpoint, that are 12 uncertainties are in line with --
13 MEMBER MARCH-LEUBA: You collect TIPs now?
14 MR. YODERSMITH: Yes, sir, we'll collect 15 TIP data at test condition alpha and at test condition 16 echo for the point of verifying that our belief that 17 there is no problem with uncertainty in this region --
18 we verify that and validate that.
19 MEMBER MARCH-LEUBA: Can you do me a 20 favor, as a personal favor, and ask GE and Framatome 21 to analyze the points ahead of time, to calculate what 22 the decay ratio is before you run the tests?
23 MR. YODERSMITH: Oh, yes.
24 MEMBER MARCH-LEUBA: Before and after?
25 MR. YODERSMITH: Yes, yes, right, right.
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31 1 MEMBER MARCH-LEUBA: Do a blind test.
2 MR. YODERSMITH: Right. That is in the GE 3 task report for our testing. And so, it kind of 4 outlines what sort of tests we should do and that it's 5 okay to do them.
6 MEMBER MARCH-LEUBA: Similar to what Dave 7 was commenting on the simulator testing, if you know 8 what the answer is, it's very easy to reproduce. It's 9 best to do a blind test ahead of time.
10 MR. YODERSMITH: Right, right. Yes, we'll 11 have acceptance criteria all laid out in the special 12 procedures. So, we'll know what good looks like.
13 Thank you.
14 MEMBER REMPE: Okay. So, if there aren't 15 any more questions, let's have the staff come forward.
16 Unlike at the Subcommittee meeting, we are going to 17 let the staff have more time. We ran over with the 18 licensee last Subcommittee meeting.
19 MR. HON: Good morning, Chairman Corradini 20 and Chairman Rempe. I'm Andy Hon. I'm the Project 21 Manager at NRR for this project.
22 Our team is going to share with you the 23 results of our review and the SE. Our SE, the draft 24 has been provided to you. It's very similar to other 25 plants' SE. It addresses each section of the M+ that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 the licensee shared earlier, the SAR, and then, all 2 the applicable Ls and Cs, I should say limitations and 3 conditions, from the Topical Report referenced.
4 Our team conducted two audits on five 5 focus areas that we will be sharing with you. The 6 first audit is the detailed Safety Analyses that was 7 done in July last year here in Rockville. And then, 8 we actually went to the site in February this year to 9 audit the simulator of their operator actions.
10 Our SE also included a summary of our 11 colleagues at Research using the TRACE computer 12 modeling to model the application. And that's also 13 included in our SE for Brunswick plant-specific 14 modeling.
15 Our plan is to finalize our SE next month, 16 make a final decision after today's briefing, and 17 incorporate any comments the Committee wishes to 18 incorporate.
19 I would like to recognize that a number of 20 people contributed to this project from both NRR, 21 different branches, and also our colleagues at 22 Research, as well as our consultants from Oak Ridge.
23 In today's presentation, we have two parts 24 because of the proprietary information. We have the 25 open session that we'll be sharing with you in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 next 10 minutes. And then, after that, we would like 2 to close the session to share more proprietary 3 information.
4 The plan right now is only including GEH 5 information sharing. If there are any questions 6 related to the AREVA or Framatome, we may have to 7 excuse people who do not have access to that 8 information in a later part of the meeting. And at 9 the end, our management would like to share some 10 closing remarks.
11 With that, I'll turn it over to our lead, 12 Josh.
13 MR. BORROMEO: Good morning. My name is 14 Josh Borromeo. I'm in the Reactor Systems Branch in 15 NRR. And I'll be discussing the NRC focus areas of 16 the application, why we focused on them, and provide 17 an overview of the review of each of these areas.
18 So, as the licensee mentioned, the LAR 19 will allow Brunswick to operate at flows as low as 85-20 percent core flow and at 100-percent power. And they 21 followed the GE MELLLA+ Licensing Topical Report, 22 which is essentially the MELLLA+ roadmap for licensing 23 MELLLA+.
24 Now this isn't the first time that the 25 staff has seen a MELLLA+ application. It's not the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 first time that we've seen MELLLA+ with GE methods or 2 the first time we've seen MELLLA+ with Framatome 3 methods. However, it's the first time that we've seen 4 a combination of GE methods and Framatome fuel, and 5 that's really in the stability and the ATWS analyses 6 that the licensee provided. Now I'm going to touch on 7 them in my presentation, but Aaron is going to go into 8 much more detail in the closed session.
9 So, the areas -- next slide.
10 CHAIR CORRADINI: Just a clarification, 11 because you nicely went through all that, have you 12 guys reviewed the reverse, which is GE fuel with 13 Framatome analysis methodology, the extent of flow in 14 there? I don't remember that.
15 MR. BORROMEO: I don't think we did for --
16 CHAIR CORRADINI: I didn't think so.
17 Okay.
18 MR. BORROMEO: I don't think there was a 19 transition for there, was there?
20 CHAIR CORRADINI: Okay. Thank you. Thank 21 you.
22 MR. BORROMEO: Okay. So, the areas where 23 the staff reviewed are areas that have been 24 historically challenging or have been new to the 25 staff. The first is the applicability of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 Framatome methods to MELLLA+. It's important to note 2 that, like the licensee said, they already have 3 Framatome fuel and the methods are already approved 4 for EPU. What the licensee is really requesting is 5 just approval for the Framatome methods and the 6 MELLLA+ operating domain.
7 The next focus area is a safety limit MCPR 8 penalty removal. Historically, a safety limit MCPR 9 penalty has been applied to all the MELLLA+
10 applications. This time the licensee was able to 11 gather more data and justify the removal of this 12 penalty.
13 The next focus area was DSS-CD. The 14 application of DSS-CD isn't new. However, the 15 licensee is requesting a change to the methodology and 16 it will reduce the range that the algorithm searches 17 for thermal-hydraulic instabilities. And they changed 18 that due to plant-specific noise that they had to 19 avoid spurious scrams.
20 And finally, ATWSI and ATWS, like I said, 21 the combination of the GE methods and the AREVA fuel 22 was a challenge for us. Tmin has been historically 23 challenging. So, we focused on that, as we have done 24 for previous reviews. And the licensee was able to 25 gain margin in the ATWSI analyses by fine-tuning their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 feedwater temperature reduction rate.
2 So, for the Framatome methods, we recently 3 approved methods for MELLLA+ for Monticello. So, we 4 have a very recent precedent that we were able to 5 start from. What the staff did was take a look to 6 make sure that there wasn't anything new or different 7 between the plants and the reviews that would cause us 8 to have to question or dig in any further to what the 9 licensee provided.
10 And the staff determined that we could 11 apply similar SE justifications and conclusions as we 12 did for Monticello, except for the MICROBURN-B2, which 13 is the core simulator, which is related to the safety 14 limit .03 penalty.
15 Now the safety limit MCPR penalty, like I 16 said, this is a penalty that has been applied to other 17 MELLLA+ applications, and it's a limitation and 18 condition in the GE MELLLA+ roadmap methodology. Now, 19 for Monticello, we continued to apply this .03 safety 20 limit MCPR penalty at high-power-to-flow ratios 21 because the staff didn't think there was enough data 22 to justify the removal of this penal.
23 So, since the Monticello application, the 24 staff has reviewed an AURORA-B Topical Report that 25 requested MICROBURN-B2 be approved in the MELLLA+
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37 1 operating domain without a penalty. In that review, 2 the staff determined that there was no adverse 3 uncertainty trend at high-power-to-flow ratios. So, 4 what the licensee did for Brunswick was follow a 5 similar approach to AURORA-B. So, the licensee was 6 able to provide additional data and justification.
7 The staff reviewed that and took a similar review 8 approach to AURORA-B and determined that we were able 9 to remove the penalty for this review.
10 For DSS-CD, the staff has reviewed the 11 DSS-CD implementation several times, including fuel 12 type changes and setpoint changes. These are allowed 13 within the DSS-CD methodology. The big change for us, 14 though, was that the licensee is shrinking the 15 oscillation period range that the algorithm searches 16 for to determine if these are truly thermal-hydraulic 17 instabilities of the plant or if they aren't. And the 18 licensee, like I mentioned, is doing this because of 19 plant-specific noise that they have to avoid spurious 20 scrams.
21 CHAIR CORRADINI: When you say "reduce in 22 time"?
23 MR. BORROMEO: Reduce in period. So, they 24 take a look at the oscillating period, and that period 25 that they search for is slightly reduced.
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38 1 MEMBER REMPE: During the Subcommittee 2 meeting -- I'm not sure whether it was the closed or 3 open part -- but you just said, "Oh, the licensee is 4 doing this because of their particular situation."
5 MR. BORROMEO: Correct.
6 MEMBER REMPE: I thought it was presented 7 to us that this may not be the only one to expect to 8 occur.
9 MR. BORROMEO: It might not be the only 10 one to expect, but this is the first time the staff 11 has seen it.
12 MEMBER REMPE: Right. Okay. Thank you.
13 MR. BORROMEO: Aaron is going to get into 14 more detail on this, but the licensee provided us 15 TRACG sensitivity studies to demonstrate that the 16 spirit of the DSS-CD methodology was still maintained, 17 and the staff found that this was acceptable.
18 And then, for ATWSI, the licensee 19 mentioned the challenges with Tmin. Aaron is going to 20 discuss that, the Tmin sensitivity studies that we 21 requested from the licensee, which is similar to what 22 we've done before for Peach Bottom and several other 23 plants.
24 However, the big, new item that has been 25 mentioned over and over again the GE methods and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 Framatome fuel, the combination there. So, the 2 licensee did a series of sensitivity studies to bound 3 the ATRIUM 10XM fuel, and the staff reviewed this and 4 determined that what the licensee did was 5 conservative.
6 In order to also support this, the NRR 7 staff requested Research perform TRACE confirmatory 8 studies, and PERC is going to give a presentation on 9 that later. Those results supported the NRR's 10 conclusion that the ATRIUM 10XM fuel was 11 conservatively modeled and that the ATWS results meet 12 the ATWS acceptance criteria. And Aaron is going to 13 get into more details in this in the closed session.
14 So, in conclusion, for these focus areas, 15 the Framatome methods we found were valid for the 16 conditions of the Brunswick MELLLA+ operating domain.
17 The .03 safety limit MCPR penalty is not necessary for 18 this Brunswick MELLLA+ application. The change in the 19 DSS-CD methodology was acceptable, and the ATWSI 20 analysis bounded the ATRIUM 10XM fuel and continues to 21 meet the ATWS acceptance criteria. And ultimately, 22 the staff found that the proposed Brunswick MELLLA+
23 operating domain license amendment request was 24 acceptable.
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40 1 have any comments or questions?
2 (No response.)
3 MEMBER REMPE: We are going to go to a 4 closed session. But, before we do that, we need to 5 allow for public comments and open up the lines.
6 I guess, Weidong, you'll take care of 7 getting the lines open. While we're waiting, does 8 anyone in the room want to make a comment?
9 (No response.)
10 MEMBER REMPE: Okay. So, the lines are 11 open. Does anyone on the line wish to make a comment 12 today?
13 (No response.)
14 MEMBER REMPE: Hearing no one, I guess 15 we'll close the line, and we'll switch to the closed 16 session.
17 (Whereupon, the above-entitled matter went 18 off the record at 9:09 a.m. and resumed at 10:15 a.m.)
19 CHAIR CORRADINI: Okay. Let's come back 20 into session. So, our next topic will be talking 21 about the Digital I&C Interim Staff Guidance-06, and 22 I'll turn it over to Member Brown.
23 MEMBER MARCH-LEUBA: And this is open 24 session?
25 CHAIR CORRADINI: Open?
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41 1 MEMBER BROWN: The whole session is open.
2 This morning the staff will be presenting 3 to us the Draft of Revision 2 to the Digital I&C 4 ISG-06, the licensing process, outlining what needs to 5 be done in order to get through the licensing process 6 for operating plants upgrading their analog 7 instrumentation to digital instrumentation and control 8 systems.
9 Our full Committee reviewed Revision 1 of 10 ISG-06 in October of 2010, and the initial Revision 1 11 of this ISG was issued later in 2011, if I believe 12 correctly. Our Subcommittee reviewed this latest 13 draft of Revision 2 on May 17th and June 20th.
14 We will also hear an overview and updated 15 progress of the Staff's Integrated Action Plan for the 16 modernization of the NRC's digital I&C regulatory 17 infrastructure.
18 Before I turn it over to the presenters, 19 Brian, would you like to say a few words?
20 MR. B. THOMAS: Sure. Good morning.
21 Brian Thomas with the Office of Research and, also, a 22 member of the Steering Committee, on behalf of the 23 Steering Committee, and there are a few members who 24 are not there, Bob Caldwell, we're expecting him to 25 join us; also, Eric Benner, who is the Chair of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 Steering Committee who is out on leave at this time.
2 But, on behalf of the members of the 3 Steering Committee and on behalf of the staff, I want 4 to express our appreciation and our thanks for having 5 us here. We look forward to the exchange with you.
6 As Member Brown said, our exchanges with the 7 Subcommittee back on the 17th of May as well as June 8 20th were very informative. The staff will address 9 some of those comments that we received then and go 10 through the ISG-06 as well as the IAP as a whole.
11 So, thank you.
12 MEMBER BROWN: Okay. Thank you.
13 Mike, would you like to take over and get 14 us moving?
15 MR. WATERS: Yes. Good morning, Chairman 16 and fellow members of the ACRS. My name is Mike 17 Waters. I'm currently serving as the Acting Deputy 18 Director, Division of Engineering in NRR. Our 19 Division Director Eric Benner is also out this week.
20 So, I'm acting for him as well.
21 I want to re-echo Brian's opening remarks 22 on behalf of the Steering Committee. Thank you for 23 taking the time to meet with us.
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43 1 from multiple Divisions who share responsibility for 2 digital I&C who are here in the audience, who will 3 participate and help us on this.
4 As noted by Charlie, this follows two 5 Subcommittee meetings this May and June on both Draft 6 ISG-06 and the Integrated Action Plan. These were 7 very viable interactions already, and we've already 8 updated the ISG to reflect some of the comments we 9 heard from the Subcommittee in both of those 10 Subcommittee meetings. We appreciate that.
11 We look forward to productive dialog this 12 morning, and we're specifically seeking feedback and 13 endorsement on our Draft ISG-06, which we intend to 14 publish for formal public comment later this month.
15 And before going on, I would like to 16 acknowledge the people at the table. We have Mr. Dave 17 Rahn, a Senior Electrical Engineer who will talk about 18 the Integrated Action Plan; Samir Darbali; Richard 19 Stattel from NRR, and Deanna Zhang from NRO, who will 20 discuss the scope and content of ISG-06.
21 Next slide, please.
22 And as Charlie noted, this is the agenda.
23 We're first going to talk about the Draft ISG-06, 24 which will be a substantial portion of the meeting 25 today, followed by Dave's discussion on the other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 1 activities that are ongoing, the Integrated Action 2 Plan.
3 With that, we're ready to start. If 4 there's any questions? Otherwise, I'll turn it over 5 to Samir.
6 MR. DARBALI: Thank you, Mike. Next 7 slide, please. So, I would like to mention --
8 MEMBER BLEY: Is your mic on?
9 MR. DARBALI: Thank you. Thank you. As 10 has been said, we briefed the ACRS Digital I&C 11 Subcommittee back on May 17th and June 20th on 12 Revision 2 of ISG-06. We received some verbal 13 comments from the ACRS Subcommittee which mainly 14 focused on how the system architecture and fundamental 15 design principles are addressed in what we call a Tier 16 1, 2, and 3 review process.
17 The next slide. And later on, we'll talk 18 about how we addressed those comments.
19 So, the purpose and scope of ISG-06 has 20 remained the same from Revision 1 to Revision 2. the 21 ISG-06 defines the licensing process used to support 22 the review of license amendment request associated 23 with safety-related digital I&C equipment 24 modifications in operating plants and in new plants 25 once they become operational. This guidance is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 consistent with the NRC's policy on digital I&C 2 equipment and is not intended to substitute NRC 3 regulations.
4 This ISG provides guidance for activities 5 performed before license amendment requests and during 6 license amendment requests review. The staff uses the 7 process described in the ISG to evaluate compliance 8 with NRC regulations, and the ISG makes reference to 9 SRP Chapter 7. It's not meant to replace Chapter 7.
10 Next slide.
11 So, the Revision 1 of ISG-06 introduces 12 the concept of tiers, and we're keeping that concept 13 in Revision 2. And it provides a graded approach for 14 how we perform our digital I&C modification reviews.
15 In a Tier 1 review, a licensee is proposing to use a 16 NRC preapproved digital platform Topical Report. In 17 a Tier 2, the licensee is referencing a Topical Report 18 that has been preapproved, but with some 19 modifications. And on a Tier 3 type of review, the 20 licensee is using a new platform that has not been 21 previously reviewed.
22 MEMBER MARCH-LEUBA: I see you're focusing 23 on hardware. How about software? If I have a 24 platform that has been approved with some software, 25 and I make any change to the software, does it become NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 a Tier 2?
2 MR. DARBALI: When we talk about the 3 tiers, we're talking about both hardware and software.
4 So, when we perform our Topical Report evaluations of 5 the platform we're looking at, we're looking at the 6 RACs, we're looking at the modules, we're looking at 7 different components and the software that performs 8 the function.
9 MEMBER MARCH-LEUBA: My specific question 10 is, at which point -- obviously, you are allowed to 11 change the setpoints, right?
12 MR. DARBALI: Right, right.
13 MEMBER MARCH-LEUBA: There's not a change.
14 At which point does it become a Tier 2 for a change?
15 MR. DARBALI: And Rich can talk more about 16 this.
17 There isn't really one Tier 1 specific or 18 one Tier 2 type. There's always something in the 19 middle. I think Diablo Canyon is a good example where 20 the licensee used the latest Topical Report that was 21 approved months before the license amendment request.
22 And yet, there were some changes in between.
23 So, the staff uses the tiers as guidance 24 on how to review it, but there's some flexibility 25 allowed to the staff on how we evaluate it. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 1 licensee will identify the changes, and we'll decide 2 which aspects need to be reviewed.
3 MR. STATTEL: This is Rich Stattel.
4 With regard to software, your specific 5 question, there are many platforms. So, there's a lot 6 of things that are unique to each platform. However, 7 a typical platform involves two types of software.
8 So, it's very easy to partition this. There is 9 platform-level software. Think of that as operating 10 system software. And then, there's application-11 specific software, which, basically, that's the 12 software that's written to perform certain safety 13 functions. So, to perform the reactor scram function, 14 to perform ESF functions.
15 When we're talking about application 16 software, plant-specific software, there is no change 17 involved with that because that will not be developed 18 until the application is -- until that effort is 19 underway.
20 MEMBER MARCH-LEUBA: So, that is the Tier 21 1?
22 MR. STATTEL: When you go over to the 23 other side, when you talk about the operating system, 24 the platform-level software, really, that does not 25 change very frequently.
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48 1 MEMBER MARCH-LEUBA: Yes.
2 MR. STATTEL: And any changes to that, 3 even if they're minor changes, change -- now we're 4 talking, also, a lot about PLCs, programmable logic 5 controllers. In those applications, we're talking 6 about function block diagrams which use a preapproved 7 library. So, essentially, there's a library of 8 functions, and a developer can choose from that 9 library implementation of those functions. That 10 library itself is considered platform software or 11 operating-system-type software. It can change, but it 12 doesn't change very often. Basically, that's the 13 library from which the developer chooses and builds 14 his application. But changes to those software 15 basically place that into a Tier 2 review. Okay?
16 MEMBER MARCH-LEUBA: Okay. Thank you.
17 MR. DARBALI: Okay. Next slide.
18 The ISG, Revision 1, also introduces the 19 concept of phases. And this allows the staff and the 20 licensee to understand the different stages of license 21 amendment review. So, we call the pre-application 22 meeting or before a license amendment is issued a 23 Phase 0. So, that's when we have discussions with the 24 licensee on what they propose to provide in the 25 license amendment request.
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49 1 Phase 1 is the license amendment request 2 submittal or initial application, and that covers 3 system description, compliance with IEEE standards, 4 design requirements, design specification, and 5 planning and processing information. Then, a Phase 2 6 is a continued review, an audit process where the 7 licensee provides supplemental information.
8 So, you can think of Phase 1 and Phase 2 9 as the licensee has a design, but it's not complete.
10 So, they are allowed, under what we call the Tier 1, 11 2, and 3 review process, to provide that Phase 1 12 information first. The staff starts their review.
13 And as the licensee completes their implementation and 14 testing activities, they provide that Phase 2 15 information, and the staff can go and review and audit 16 that information.
17 MEMBER MARCH-LEUBA: So, in the example 18 that Rich was giving us, say PLCs, they would provide 19 a PLC hardware or we will use this type of machine?
20 MR. DARBALI: Right.
21 MEMBER MARCH-LEUBA: We will provide the 22 library functions --
23 MR. DARBALI: Right.
24 MEMBER MARCH-LEUBA: -- under Phase 1, 25 correct, likely?
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50 1 MR. DARBALI: Right. Yes.
2 MEMBER MARCH-LEUBA: And then, as you are 3 reviewing that, they will do the application software 4 on top of it?
5 MR. DARBALI: Right. Yes. So, you'll see 6 we'll see design requirements, design specifications, 7 but how that gets implemented, we won't see that until 8 Phase 2.
9 MR. STATTEL: One of the challenges I'll 10 just mention, one of the challenges we faced with 11 digital I&C equipment that's kind of unique to this 12 technology is that the development processes span 13 years. So, a lot of times the development of these 14 types of systems can three, four years to occur. So, 15 when we originally developed the ISG in 2010, we 16 recognized this and we wanted to provide a way of 17 essentially performing our evaluation in parallel with 18 that development process. Because when you put our 19 two-year evaluation in series with it, it makes it 20 very difficult for plants to implement these types of 21 modifications.
22 MEMBER MARCH-LEUBA: And what makes it so 23 long, testing? Because, obviously, it's not a 24 problem. I mean, the problems are not that 25 complicated.
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51 1 MR. STATTEL: I guess there are many 2 reasons for that. Because they go through the process 3 of selecting a platform. The designs are typically 4 not identical to the systems they are replacing 5 oftentimes. So, for instance, with Diablo Canyon, 6 they're trying to eliminate manual operator actions.
7 So, there's changes associated with that. And there 8 are also challenges that relate to diversity, defense 9 in depth.
10 The other hazard that these digital 11 systems have a potential for is common-cause failures.
12 So, there's not a one-for-one easy replacement 13 digital-to-analog for that without having to 14 additionally address diversity. So, oftentimes, these 15 systems involve installation of automatic diverse 16 actuation systems or in certain technologies they are 17 able to implement diverse measures within the system 18 in order to address the potential for common-cause 19 failures.
20 Those are just a couple of examples of why 21 the development processes span this. There are other 22 factors that we've seen in evaluations. The Diablo 23 Canyon development process took about four years to 24 complete. That had more to do with vendor performance 25 issues and contract administration. It was things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 that were not really associated with the regulatory or 2 licensing process. But it basically extended the 3 development time for that.
4 Previous to that the Oconee application, 5 there was an original submittal, and the staff had 6 deemed that they had not adequately addressed 7 diversity and defense in depth. It was withdrawn and, 8 then, resubmitted, and a redesign was performed.
9 So, it's really just been our experience 10 that these projects tend to take an extensive period 11 of time for development.
12 MR. DARBALI: And then, we have what we 13 call a Phase 3, which is really, once the license 14 amendment has been issued, then the licensee installs 15 it. And then, we have regional and site inspections.
16 Next slide.
17 So, we have used Revision 1 of ISG-06 for 18 several license amendment requests, most notably, 19 Diablo Canyon Plant Protection System and the Hope 20 Creek Power Range Neutron Monitoring System. We've 21 also used it for various digital I&C Topical Report 22 reviews. That really allows us to, since the Topical 23 Report has been reviewed using the ISG, the licensee 24 wants to use that platform. Most of the criteria in 25 the ISG has been covered. So, it facilitates the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 1 staff's review.
2 We've found that the concept of the Tiers 3 1, 2, and 3 and the Phase 1 and 2 review process have 4 been useful. One thing to note is that, originally, 5 the ISG was meant to be a one-stop shop that included 6 all of the digital NRC guidance, and this became 7 problematic because we ended up duplicating a lot of 8 the Chapter 7 guidance as well as IEEE Standards 603 9 and 7-4.3.2. Because the ISG originally issued in 10 2011, we've revised several Regulatory Guides since 11 then. So, those became outdated.
12 And Revision 1 of the ISG focused more on 13 specific documents by title instead of the information 14 needed to make the review. So, we saw an opportunity 15 to improve on those.
16 Next slide.
17 Right, so we found that we could improve 18 on streamlining the ISG and the Tier 1, 2, and 3 19 review process. Also, we've been having several 20 public meetings with industry, and they've expressed 21 concerns that they need to expand significant 22 resources for procuring, developing, and testing the 23 system before they get the license amendment. So, 24 right now, under the Tier 1, 2, and 3 review process, 25 the licensee has to procure the system, design it, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 develop the modification, implement it, and do 2 testing, and finally, factory acceptance tests before 3 we issue the license amendment. And they've expressed 4 concerns with that saying they would like to see that 5 license amendment issued earlier. So, the staff took 6 our internal lessons learned and comments from 7 industry, and we tried to improve on Draft Revision 2 8 of the ISG.
9 Next slide.
10 So, here's a comparison of both Revision 11 1 and Draft Revision 2. Both Revision 1 and 2 include 12 the Tier 1, 2, and 3 review process which uses a 13 preapproved platform Topical Report. Again, this is 14 for Tiers 1 and 2. For Tier 3, the platform review 15 would be part of a license amendment review.
16 The system description and system 17 architecture are included as part of this review. We 18 understand that, when we first presented the ISG 19 Revision 2 to the ACRS Subcommittee, they pointed out 20 it wasn't clear that we did that system architectural 21 review for the tier process. So, we improved the 22 language on that.
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55 1 information. So, we've maintained that tiered process 2 in Revision 2.
3 We've also added a new review process that 4 we call the alternate review process. It also uses a 5 preapproved Topical Report platform. It covers system 6 description and system architecture, and the review 7 covers the software design, implementation, test plans 8 and processes.
9 However, the main difference between the 10 alternate process and the tier process is that 11 implementation of the design and the test results will 12 be subject to inspection because those will occur 13 after the license amendment has been issued.
14 MEMBER MARCH-LEUBA: What's the likelihood 15 that the inspection will remove a license? Once 16 somebody has a license, it's very difficult to get rid 17 of it.
18 MR. DARBALI: Well, right. The process is 19 not intended to remove the license, but a violation 20 might be issued if it's found that the licensee has 21 made -- either they did not comply with any of the 22 conditions in the license amendment or they've made 23 some sort of design that required a new license 24 amendment request.
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56 1 there's nothing wrong. I mean, I see a lot of balance 2 here with Part 52 --
3 MR. DARBALI: Right.
4 MEMBER MARCH-LEUBA: -- where you approve 5 a paper design --
6 MR. DARBALI: Right.
7 MEMBER MARCH-LEUBA: -- and then, you 8 build it.
9 MR. DARBALI: Right.
10 MR. WATERS: Yes, this is something 11 similar, but it's very different. We will issue the 12 license and they have the authority to build, 13 instruct, and operate the system. As you said, any 14 issues of implementation and testing will be in 15 oversight space. And if our inspection records find 16 an issue in the oversight process, as Samir has noted, 17 like anything else, there's remedies to any adverse 18 things. We hope we don't have any. But that is the 19 difference. Both on the vendor side and site 20 inspections, we will look at the development and the 21 testing.
22 MEMBER MARCH-LEUBA: I see this very 23 positive. Yes, the staff needs to keep the stick.
24 So, you should be able to enforce decisions 25 afterwards.
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57 1 MR. WATERS: Yes, and part of the fabric 2 of this is we are actively working with what the 3 inspection programmatically, little "p,"
4 programmatically, will look like with this new process 5 both in vendor inspection, what we believe will 6 involve vendor inspections more so than the changes to 7 the site inspection.
8 MEMBER MARCH-LEUBA: Okay. Thank you.
9 CHAIR CORRADINI: I'm not an expert in any 10 of this. So, let me ask a broader question. How many 11 have used the top approach and successfully installed 12 a digital I&C system? Not Revision 2, which has the 13 alternate approach, but the --
14 MR. DARBALI: Right. So, for Revision 1, 15 the tier process, we've successfully used it for 16 Diablo Canyon. They have not installed the system 17 because they're going to be shutting down. So, they 18 decided not to install it. But it was a successful 19 review. And it was the pilot for the ISG. We've 20 successfully used it for Hope Creek, for the Neutron 21 Monitoring System --
22 CHAIR CORRADINI: Okay.
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58 1 reviews. And industry has had positive feedback on 2 the tier process.
3 MR. STATTEL: I think the answer is about 4 a half dozen.
5 (Laughter.)
6 CHAIR CORRADINI: Okay. And then, with 7 this alternate review process, my sense is industry 8 will probably use it more -- feel that that could be 9 more effective?
10 MR. DARBALI: Yes. So, during our public 11 interactions with the industry, they do prefer 12 alternate review process. They understand they are 13 taking a risk post-license amendment and subject to 14 inspections and any violations. Whereas, now, during 15 the Phase 2, if they want to do a change to the 16 design, then we're still reviewing it. So, the tier 17 process allows that flexibility.
18 CHAIR CORRADINI: Okay. Thank you.
19 MEMBER BROWN: Correct me if I'm wrong, 20 but the alternate review process that you've 21 incorporated -- let me back up just a minute. If you 22 go back eight years, when we first did the first 23 version of this, the way I've viewed this was taking 24 all of the various documents, the Reg Guides and 25 everything else that are applicable to the I&C world NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 1 which somebody would try to design to, and it kind of 2 coalesced them in and said, "Here's the things you 3 have to look at and the stuff we expect you to present 4 to us, so we can perform our review."
5 So, it took some of the surprise of, all 6 of a sudden, "Hey, you didn't give us this and we 7 really want that." It's now kind of put together in 8 terms of this ISG.
9 The alternate review process, in my mind 10 -- that's why I asked them to correct me if I'm wrong 11 -- is similar to what we do on the design 12 certification side. We approve a Chapter 7 based on 13 an I&C Safety System Technical Report or Topical 14 Report, which are more than platforms. They might 15 identify a platform, but they identify a system 16 architecture. The license is issued and they build, 17 and it gets inspected and tested subsequent to that 18 license. That's the way I view the alternate review 19 process now being applied to the individual 20 replacement of systems. That's just a calibration.
21 If you can fix that a little bit --
22 MR. STATTEL: I would also mention, the 23 next slide will show a timeline, right, that explains 24 that.
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60 1 that.
2 MR. STATTEL: And before Samir leads into 3 this, our experience, essentially, we're issuing the 4 license amendment at an earlier stage, at completion 5 of design, before the design is implemented or tested, 6 right? So, that's the point in time that we're now 7 issuing the license amendment.
8 Our experience, that window of time can 9 typically take from a year to two years or even 10 longer, right? And in our experience, design changes 11 do occur during implementation and during testing. We 12 expect that those design changes would now occur, if 13 the alternate review process is used, those design 14 changes are occurring after we issue the license 15 amendment. Therefore, they would be using either 16 their 50.59 process or they would submit additional 17 license amendments to accomplish those changes.
18 MR. DARBALI: Thank you, Rich. So, the 19 top portion of this slide describes the staff 20 activities related to Tier 1, 2, and 3 review, and 21 this is for Revision 1 and Revision 2 of the ISG.
22 Whereas, the bottom portion describes the NRC staff 23 activities related to the alternate review process.
24 The middle portion describes the licensee activities 25 in procuring and developing testing, the modification.
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61 1 So, you can see that, for the tier 2 process, the license amendment request gets submitted 3 earlier because they are allowed that Phase 2 4 information supplemental submittal later on. So, they 5 can start their license amendment request submittal 6 earlier. For the alternate review process, they need 7 to get more design information because they only get 8 one submittal. This is one of the main differences.
9 For the alternate review process, you don't have a 10 Phase 2 submittal. So, all of the information 11 necessary for the staff to make a safety determination 12 has to be provided in the license amendment request.
13 So, it will take longer for the licensee to submit 14 that. We'll perform our review and audits, and you 15 can see at the bottom the license amendment gets 16 issued earlier.
17 MEMBER KIRCHNER: But, yes, Samir, let me 18 ask a question. One of your earlier slides expressed 19 the industry concern about the resources that are 20 required before the amendment is issued. So, when I 21 look at your diagram, it strikes me that there's still 22 significant resources invested before you get the LA 23 issued.
24 MR. DARBALI: Under the alternate review 25 process.
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62 1 MEMBER KIRCHNER: Under both.
2 MR. DARBALI: Well, yes. Yes.
3 MEMBER KIRCHNER: So, what substantially 4 is different, then, in the alternate process in terms 5 of saving resources?
6 MR. DARBALI: Well, what we've received, 7 the feedback we've received from industry regarding 8 the tiered process is plant management doesn't want to 9 commit a large budget for a digital modification 10 without seeing that license amendment. So, the 11 alternate review process would allow them to say, 12 well, plant management is going to commit not the 13 whole cost of developing, implementing, and testing a 14 system, but enough to get that design information and 15 get a license amendment. It gives licensees that 16 flexibility. They can get that funding for the design 17 to be approved. After that, they can go back to their 18 management and say, "We have our license amendment,"
19 and request funding to complete the design. Industry 20 feels that would enable them to perform more 21 modifications.
22 MEMBER MARCH-LEUBA: I know you don't know 23 the answer to this, but it would be helpful if you 24 could give us a ballpark one-year money for each of 25 those blue boxes in the middle.
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63 1 MR. DARBALI: Yes, it would be helpful.
2 (Laughter.)
3 MEMBER MARCH-LEUBA: I know you don't know 4 it.
5 MR. STATTEL: In a later slide, I will 6 talk a little bit about the efficiency, because we do 7 aim to improve the efficiency of our evaluation 8 activities, and I will speak to that separately.
9 MEMBER KIRCHNER: But that's a different 10 matter than investment by the Applicant to actually 11 get a design mature enough that you can issue the LA 12 under the alternate review process. It strikes me the 13 bulk of the investment has been struck roughly where 14 the red line is on the bottom.
15 MEMBER BROWN: No, no, that's not the 16 case.
17 MEMBER KIRCHNER: So, the testing has --
18 MEMBER BROWN: I've built so much of this 19 stuff.
20 MEMBER KIRCHNER: Yes.
21 MEMBER BROWN: And if you get a system 22 design and an architecture, and it's laid out and you 23 understand it, you haven't committed to a vendor to 24 design, build, manufacture, test. All that money has 25 not been spent. In the tiered process, that money has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 been spent while you're getting the license amendment.
2 MEMBER KIRCHNER: Right.
3 MEMBER BROWN: That is a huge investment 4 in cost. The earlier part is cheaper.
5 MR. STATTEL: Yes, that's what the 6 licensees are telling us.
7 MEMBER KIRCHNER: Okay.
8 MR. STATTEL: We're the lower --
9 MEMBER BROWN: I did that for 22 years.
10 MR. STATTEL: Think about it this way:
11 where the lower red line on this chart here, they 12 haven't bought any equipment; they haven't built 13 anything; they haven't wired up anything; they haven't 14 built anything. Everything is on paper at that point.
15 MEMBER KIRCHNER: Oh, I was going from 16 your review above in the blue; it says "fabrication".
17 MEMBER BLEY: That's the top.
18 MR. DARBALI: Well, you know, the line is 19 flexible.
20 (Laughter.)
21 MEMBER KIRCHNER: Okay. I'm with Charlie.
22 I kind of said, well, if you are designing and 23 fabricating, that means you're procuring, then your 24 investment is huge.
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65 1 there's a figure for the alternate review process.
2 I'm forgetting what the figure number is. And it is 3 more clear than this particular diagram --
4 MEMBER KIRCHNER: Okay. Thank you.
5 MEMBER BROWN: -- because all this other 6 dollars are not expended before that license amendment 7 is requested. Yes, that adds a little bit of 8 confusion, I agree with you on that.
9 MEMBER KIRCHNER: Yes.
10 MEMBER BROWN: I see your blue line in 11 there.
12 MEMBER MARCH-LEUBA: But is it true that, 13 if you're using an approved Topical, basically, you're 14 copying what some other plant did before, you get to 15 red real fast, the bottom red?
16 MR. DARBALI: Right.
17 MEMBER MARCH-LEUBA: I mean, if you just 18 copy what somebody else did, you just have to change 19 the name of the plant and you submit it?
20 MR. DARBALI: Right. Unfortunately, we 21 haven't seen so many digital modifications --
22 MEMBER MARCH-LEUBA: But, hopefully, we 23 will.
24 MR. DARBALI: Hopefully, yes.
25 So, that's one of the differences.
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66 1 Another major --
2 MEMBER BROWN: Well, let me --
3 MR. DARBALI: Go ahead.
4 MEMBER BROWN: Let me comment on the 5 Topical Report. We've had three, I think it's two or 6 three design certifications where a particular 7 platform has been utilized, and that eliminated a 8 whole pile of work that the Applicant had to do. He 9 was just using that and using that as the main 10 framework for developing each of his designs. So, 11 that is a powerful incentive to not reinvent something 12 new, but to use something somebody's already got in 13 place and has applied before. That significantly 14 reduces the staff's needs, if there are minimal, if 15 any, changes to the platform software, the operating 16 system, and all you have to deal with is application 17 software and how it interfaces.
18 So, I think the use of existing components 19 that have been approved is a big incentive. That's 20 personal opinion. But, anyway, you can go on now.
21 MR. WATERS: I think staff agrees. We 22 have really positive experience with the new digital 23 neutron monitoring system. They've installed many 24 plants using them over Topical. And as we get more 25 and more a little more frequently, we've become more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 1 efficient and they use the same thing. Obviously, if 2 the fleet operators want to do things for major 3 upgrades, we would hope to have the same efficiencies 4 after we get a standardized process going, and if they 5 use the same Topical, the same configuration, we hope 6 to have the same savings.
7 MR. DARBALI: So, the other change between 8 the two processes is that orange box at the bottom, 9 which identifies that, for those activities that the 10 staff would not be performing a review on, mainly 11 implementation and testing, including factory 12 acceptance testing, results, those would be covered by 13 optional vendor inspections. And the staff would be 14 engaging the vendor inspection and site inspection 15 team from the very beginning. Actually, the staff 16 expects to be part of those inspection activities.
17 So, those would be covered.
18 Next slide.
19 This slide summarizes some of the 20 characteristics of a license amendment request that 21 uses this new alternate review process. As we said, 22 the LAR has to provide the necessary and sufficient 23 design information to demonstrate regulatory 24 compliance. They don't have that Phase 2 option.
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68 1 described, and this plan ensures that the vendor 2 executes the project consistently with the license 3 amendment request and consistent with requirements of 4 the 2015 version of ASME NQA 1.
5 Appropriate commitments to complete 6 Topical Report plant-specific action items will be 7 included. So, every Topical Report, because it's 8 generic, includes specific action items that need to 9 be performed that are plant-specific. So, the 10 licensee needs to provide that information.
11 For those activities that would occur 12 after the license amendment is issued, the LAR should 13 include commitments to complete those activities. And 14 some of those, as we'll talk later, may be converted 15 to conditions. The license amendment request also 16 should include commitments to complete those life-17 cycle activities under the licensee's QA program.
18 Next.
19 As I said, the alternate review process 20 relies on those additional regulatory commitments, and 21 the staff may translate some of those regulatory 22 significant commitments into license conditions; for 23 example, factory acceptance test results.
24 Next.
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69 1 the staff would be performing with the licensee during 2 the Phase 0 pre-application coordination meetings.
3 So, one of the topics that we would be discussing with 4 the licensee is which review process should be used 5 for the LAR. We expect the licensee to come in and 6 say, "I want to use the tiered process" or "I want to 7 use the alternate review process." And so, we'll have 8 a discussion with the licensee, and the staff will, 9 then, internally make a determination whether they can 10 actually do that. So, the staff has the final say as 11 to what review process will be used.
12 We will also discuss the use of a 13 preapproved Topical Report and any significant 14 changes. So, that would help us determine if it's a 15 Tier 1/Tier 2 review.
16 We'll talk about the portion of the plant 17 system to be replaced; key design concepts, including 18 the four fundamental design principles; any variances 19 from the current I&C guidance, and we'll also cover 20 the applicability of Enclosure B, and we'll show you 21 that Enclosure B soon.
22 Next slide.
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70 1 as part of its review. The staff took that comment 2 and went back and looked at the ISG, and realized 3 that, yes, for the alternate review process, we do 4 emphasize a lot of that system architecture review.
5 We didn't do that, even though it is our intention to 6 review it for the tiered process. So, we went back 7 and we decided to make Section D.2, which would only 8 apply to the alternate review process, it will now 9 apply to both processes. So, it will be clear now 10 that system architecture is covered, regardless of the 11 review process used.
12 Another comment was regarding the four 13 fundamental --
14 MEMBER BLEY: And you've built that into 15 the Draft now?
16 MR. DARBALI: Yes, yes.
17 MEMBER BLEY: So, the one that says "Out 18 for comment" would include that?
19 MR. DARBALI: Yes. That change has been 20 made, and we'll show you that in the Enclosure B 21 table.
22 Another comment was the four fundamental 23 design principles are emphasized for the alternate 24 review process and not the tier process. Because that 25 section is still part of Section D.2., by making NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 Section D.2 applicable to the tier process, we solve 2 that issue as well. So now, the four fundamental 3 design principles are covered in both processes.
4 And then, hardware configuration control.
5 This slide, it's not up-to-date as to how the ISG 6 looks right now. So, the comment on hardware 7 configuration control was that the ISG was silent. We 8 keep emphasizing software configuration management, 9 software configuration control, but we make no mention 10 of hardware.
11 So, what we've done since that meeting, 12 and since we submitted this slide, is we scrubbed the 13 ISG. We looked when we talk about configuration 14 management, and we had a section D.4.2.5. It used to 15 be titled, "Software Configuration Management 16 Process". We looked at it. We realized we don't need 17 to exclude hardware. So, right now, it's just 18 "Configuration Management Process". Whenever we've 19 talked about configuration management, and we've 20 focused on software, we realized that there's no need 21 to just exclude it. So, one of the fixes was to 22 remove the word "software"; just make it generic.
23 One of the things to understand is, the 24 reason we tend to focus on software configuration 25 management is because hardware configuration NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 1 management has always existed. And licensees, under 2 their QA programs, and vendors under the QA program, 3 typically handle that.
4 When the digital I&C software 5 configuration management guidance has been put out, 6 it's to kind of explain or re-emphasize to licensees, 7 hey, software is different; you should be doing 8 configuration management of software. It may have 9 given the impression that we don't care about 10 hardware, which is not true. A lot of times, when we 11 look at our configuration management reviews, vendors 12 use what they call a configuration status accounting-13 type document, and that includes not only the software 14 version and software changes, but also hardware 15 versions. And so, they identify the modules. They 16 identify the components. So, it is covered.
17 We tried to change the language in the ISG 18 so hardware wasn't excluded. We did not create or add 19 or reference any other hardware-specific configuration 20 management documents because I don't think we use any.
21 So, that's how we tried to address that particular 22 comment.
23 MEMBER SKILLMAN: Samir, I understand, I 24 think I understand what you're trying to communicate.
25 The basis of my comment is that, at least in my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 experience, where plants have really gotten into 2 trouble, they've been so eager to implement a change, 3 a license amendment, a hardware change, a widget 4 change, they get so caught in the ether of what 5 they're going to get when they have this new thing, 6 that they are often not as rigorous and disciplined as 7 they need to be to make sure that the "i's" are dotted 8 and the "t's" are crossed in the documentation and 9 that they've gone back into the bowels of their plant 10 and made certain that the whatever it is they're 11 changing has not created an unintended consequence.
12 MR. DARBALI: Right.
13 MEMBER SKILLMAN: That was what I was 14 thinking when I made the comment.
15 MR. DARBALI: Okay.
16 MEMBER SKILLMAN: I think you've said, by 17 extracting the word "hardware," you're using 18 "Configuration Management," capital "C", capital "M",
19 and that ought to take care of it. With all due 20 respect, I'm not sure you've gone far enough.
21 It seems to me that there should be a 22 bunch of exclamation points where your document says, 23 "We've been through this a couple of times, and those 24 who have succeeded have succeeded because they've 25 really paid a lot of attention to these fine details.
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74 1 And where we've found problems is where the integrity 2 of the configuration management/configuration control 3 program has not been as rigorous as it needs to be.
4 And there's one more piece. The 5 configuration management discussion needs to be hooked 6 to a rigorous Appendix 16, xvi, of your Appendix B 7 program for reporting issues, whether you call it 8 "condition reports," or whatever the utility uses.
9 But there needs to be a way to make sure that what you 10 find in the exploring of the configuration control 11 issues gets caught by your corrective action program 12 and it gets vetted by the station staff, so that they 13 understand what the extended condition might be.
14 MR. DARBALI: Right.
15 MEMBER SKILLMAN: Because in so many 16 cases, an I&C change really has extended condition 17 issues that are not obvious.
18 MR. DARBALI: Right.
19 MEMBER SKILLMAN: That's a long sermon.
20 I apologize, but that was the heart of what I was 21 trying to communicate.
22 MR. DARBALI: Okay.
23 MEMBER SKILLMAN: And I know from 24 experience, if you look at the 95-003 plants, the 25 95-002 plants, the 0350 plants, the fingerprint on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 each of those plants is a breakdown in configuration 2 control, a breakdown in corrective action. And the 3 price is so high for those people who have fallen 4 under that situation.
5 Here you might be doing a frontal lobotomy 6 on a plant. This is the place to catch it right on 7 the front end where your ISG says, "Caution, caution, 8 caution"; when you're getting into this, understand 9 what you're dealing with.
10 MR. DARBALI: Okay.
11 MEMBER SKILLMAN: So, I thank you.
12 MR. DARBALI: No, I appreciate that 13 feedback.
14 MEMBER BROWN: I'm going to amplify Dick's 15 comment a little bit. In thinking about how we 16 address this, it was, as he phrased it in the 17 Subcommittee meeting on the 17th, it was relative to 18 the licensee having ownership of what the design looks 19 like when they get it, so that they can ensure that 20 their procedures, practices, and actual management 21 configuration, management systems that are in place, 22 are now consistent with the new technology and don't 23 still rely on the practices that existed for the old 24 technology. I'm squishing his comments from the May 25 17th thing down.
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76 1 (Laughter.)
2 MR. STATTEL: I would just say that the 3 staff agrees. The staff agrees that configuration 4 management is an important characteristic for 5 hardware, software, anything involved with these plant 6 modifications.
7 We're just really trying to explain that 8 the emphasis was placed on software because this is 9 guidance that's basically above and beyond, unique to 10 digital systems. So, what's unique about digital 11 systems? Primarily, it's the software, the HDL 12 implementation. That's why it was that way.
13 When we received your comment, we do agree 14 that, when you emphasize software, you're 15 inadvertently also de-emphasizing the hardware aspects 16 of it, and we didn't intend to do that. So, we're 17 willing to make changes to basically put it on equal 18 footing. We're kind of struggling with exactly where 19 to do that.
20 MEMBER MARCH-LEUBA: But I'm thinking on 21 hardware configuration control, the fact that there's 22 a very limited number of vendors that can supply the 23 system -- it's not you can, almost like at home, buy 24 a power range monitor. You're already from GE. You 25 install it from GE, and if you need a spare part, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 you're going to buy it from GE.
2 MR. STATTEL: Correct.
3 MEMBER MARCH-LEUBA: There is no way you 4 are going to put something else. So, maybe if that is 5 the issue, say that the vendor must keep how the 6 configuration control is. Probably the plant doesn't 7 have any option to change it.
8 MR. STATTEL: Right.
9 MR. DARBALI: Okay. Appreciate that.
10 Thank you.
11 MR. WATERS: So, we'll be happy to take a 12 look at the ISG again to see if there's any clarifying 13 language to add the emphasis there before we issue for 14 public comments. And it sounds like some of this 15 conversation also helps us when we converse with the 16 Inspection Program because this is also an issue we 17 want to ensure is appropriately inspected with the 18 right rigor as well. So, we'll see what we can do in 19 the Draft ISG before we feed it back to you and before 20 we issue for public comment.
21 MR. DARBALI: So, this slide covers some 22 of the changes we've made to the ISG since we last 23 presented it.
24 Like we said, Section D.2, System 25 Architectures, now applies to the Tier 1, 2, and 3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 review process.
2 Also, Section D.3, Hardware Equipment 3 Qualification, now also applies to Tier 1, 2, and 3.
4 What happened was we had that Section D.9.9, which 5 basically covered that same information specifically 6 to the Tier 1, 2, and 3 review process. We realized 7 there was no need to have that guidance separate. So, 8 we eliminated D.9.9 and we made sure that guidance is 9 covered by D.3.
10 We've made general editorial changes for 11 clarification. So, we made the changes regarding 12 configuration management, and we'll go back and look 13 at those.
14 We had language for pre-application 15 coordination meetings and post-license-amendment 16 activities, and we had that separate for each process.
17 We realized those activities are actually common. So, 18 we kind of changed how Section C looks. So now, that 19 information is more consolidated.
20 Next slide.
21 And now, I'll turn it over to Rich to talk 22 about the structure of the ISG.
23 MR. STATTEL: The diagram you see here is 24 illustrating the new structure of ISG-06. It 25 basically is a chapter breakdown of the new document, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 and we did restructure it significantly from the 2 original version.
3 The ISG will now provide guidance for two 4 different regulatory evaluation processes. So, it 5 contains sections that are common to both processes as 6 well as sections that are unique to each.
7 As an example, Section D.1 provides 8 guidance for evaluating and describing the system 9 that's being modified. Since the evaluation is the 10 same for this area, regardless of the type of review 11 being performed, the team saw no need to duplicate 12 this guidance. So, therefore, D.1 is now applicable 13 to both the Tier 1, 2, 3 process and for the alternate 14 review process. Section D.4, on the other hand, 15 provides guidance for development planning processes 16 that is unique to the alternate review process. And 17 thus, it is only referenced in the alternate review 18 process tables of the enclosure.
19 Conversely, Section D.9 provides guidance 20 for evaluating design products that would not be 21 available for an alternate review prior to issuance of 22 the license amendment. Therefore, D.9 is only 23 referenced in the Tier 1, 2, 3 sections/tables of the 24 enclosure.
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80 1 itself, which I kind of prefer to do. This is 2 actually right out of the ISG. Here are two tables 3 that are provided in Enclosure B of the new Revision 4 2. The first table identifies the information to be 5 provided with the license amendment request. This 6 table is applicable to both the alternate review 7 process, as you can see by the columns, and the Tier 8 1, 2, 3 review processes. The second table 9 corresponds to the Phase 2 supplemental information.
10 Now that table is unique to the Tier 1, 2, and 3 11 review processes.
12 So now, also note that the X's in this 13 table, their guidance and assessment will still need 14 to be done for each application to determine the 15 appropriate information that would be needed for a 16 particular license amendment request.
17 Revision 1 of the ISG also included a 18 Phase 3 table which identified documents that would be 19 made available for inspection after the issuance of 20 the license amendment. This table was removed because 21 we did not intend to provide inspection guidance in 22 this ISG.
23 I mentioned before I was going to talk a 24 little bit about efficiency. So, this is where this 25 comes in. One of the things you will notice is that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 1 the planning and process review guidance is now only 2 applicable to the alternate review process. The 3 reason for that is because, without having final 4 design products in hand or being able to look at 5 those, you kind of put more emphasis on the planning 6 and the quality processes that go into building that 7 system. So, there is more of an emphasis placed on 8 the processes.
9 Whereas, with a Tier 1 review, we have 10 final design products in hand, so we're able to de-11 emphasize the process. So, it's not as important that 12 you had good planning. I mean, it's important. We're 13 not trying to say it's not important. But, if you 14 have the final product and you have test results and 15 you have evidence that it meets the regulatory 16 requirements, the planning processes aren't quite as 17 important.
18 So, we're able to gain some efficiencies 19 here by spending more of our time on reviewing those 20 design outputs as opposed to spending time reviewing 21 planning processes, which, even if you find problems 22 with the planning, they are not going to affect the 23 design outputs when they're already in --
24 MEMBER MARCH-LEUBA: Yes, I understand 25 what you're saying.
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82 1 MR. STATTEL: Yes.
2 MEMBER MARCH-LEUBA: You need to educate 3 me a little bit, and I apologize, I was not here for 4 the May Subcommittee meeting, and that's why I need to 5 ask, for personal reasons.
6 1.15 triggered just a thought here. I 7 mean, if you are designing and replacing a flood 8 protection system, you don't have enough boxes here.
9 You have to go through all this. But now, if I'm 10 replacing a relay, an analog relay, with one that has 11 some better digital components, does it trigger 12 everything, or can I get out of it before I start? I 13 mean, I'm just replacing a one-to-one relay, but this 14 one has some microprocessor inside. At what point do 15 I go to jail? You know what I mean, get out of jail 16 on the Monopoly.
17 MR. STATTEL: Well, I would say that the 18 ISG is really developed with -- we're replacing a 19 reactor protection system.
20 MEMBER MARCH-LEUBA: But help me 21 personally relate.
22 MR. STATTEL: That's really the scope of 23 this. And it gets a little awkward when you try to 24 apply it to Topical Reports when you don't even know 25 what they're going to build with it.
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83 1 And also, like your example, if we're just 2 doing a relay-type replacement, it's really hard to 3 fit it into this mold.
4 MEMBER MARCH-LEUBA: But is it clear that 5 it doesn't apply?
6 MR. STATTEL: Correct, yes.
7 MEMBER MARCH-LEUBA: It is clear? I'm not 8 sure. I'm asking you.
9 MEMBER BLEY: You could turn it around and 10 say, is it clear what applies, what are the 11 requirements if you do a simple thing like that?
12 MR. STATTEL: And it's a challenge for us 13 because, when we have our Phase 0 meetings, these 14 types of aspects come up during those meetings and we 15 have these discussions, right? And where there is no 16 clear guidance, essentially, at that stage we're 17 developing a review plan, a unique, specific review 18 plan for that type of operation.
19 MEMBER MARCH-LEUBA: But a relay would 20 probably come into --
21 MR. STATTEL: In your example, relay 22 replacements, actually, I've never seen one actually 23 come in as a license amendment, because, typically, 24 those would be brought --
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84 1 because that's the one that caused a problem in the 2 past --
3 MR. STATTEL: Right.
4 MEMBER MARCH-LEUBA: -- where you guys 5 know the example.
6 MR. WATERS: Right, and we would expect 7 these to be done in 50.59, so that inspection -- but, 8 if for some reason, someone had to come and get a 9 license amendment to approve this, we do have the 10 broader Chapter 7. And the key there is having a 11 complication meeting and having the discussion of what 12 would we look at and what not. We may not even go 13 into ISG-06. We'll just say, you know, Section 1.-
14 whatever of the SRP covers it. The key is to have 15 that conversation.
16 MS. ZHANG: This is Deanna.
17 That was actually discussed, about 18 replacement of certain components instead of replacing 19 a whole system, whether we should revise this ISG to 20 include guidance for that. We had to prioritize what 21 guidance we want to focus on for this revision, and we 22 decided to defer that to later.
23 MEMBER MARCH-LEUBA: I'm not complaining.
24 I'm just asking you, the guys that wrote it, are we 25 falling into a trap that, if I want to change a relay, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 I have to go through all of this?
2 MEMBER BLEY: Or do we confuse the 3 licensee who doesn't know what the heck to do with 4 replacing a component? Does this apply to me? Does 5 it not apply? Can I just do it under 50.59? What do 6 I do?
7 MR. WATERS: My belief is, no, just given 8 the amount of dialog we've had in the last several 9 years, both on this and the 50.59 process. You're 10 probably going to understand what they plan to do 11 under 50.59, what they have to do to address those 12 questions. This is for major upgrades. As Deanna 13 said, we deferred having it for every type of possible 14 upgrade. If we get one for a LAR, we'll just have to 15 make a game-day adjustment and tell them what we need 16 to --
17 MEMBER BLEY: I assumed that was what it 18 was, but, until Jose brought it up, I never really 19 thought about what do I do if I a small change.
20 MR. STATTEL: We do get questioned about 21 this often. What I tell licensees is, don't assume 22 that it does not apply. If you have a question, have 23 a Phase 0 meeting.
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86 1 here, we all agree that a license amendment is not 2 required and they don't have to apply all of this 3 guidance to those types of modifications.
4 MEMBER MARCH-LEUBA: I know it's a little 5 late, but --
6 MR. STATTEL: So, we have had several.
7 And I encourage licensees to come in and have those 8 meetings, even if they don't necessarily lead to an 9 actual license amendment.
10 MEMBER MARCH-LEUBA: I know it's a little 11 late, but I would have put a 1.01 step. Let's say 12 it's applicability.
13 MR. STATTEL: Right.
14 MEMBER MARCH-LEUBA: Very simple. Put it 15 in the guidance that this doesn't necessarily apply to 16 everything or something. I mean, review 17 applicability, or something like that.
18 MR. STATTEL: There has been a lot of 19 criticism in recent months over the onerous criteria 20 that exists around digital I&C equipment. And it is 21 onerous, and part of the reason for that, Chapter 7 is 22 a pretty encompassing review guidance and it covers 23 everything from planning aspects to design, to 24 implementation, to testing. So, it covers all 25 aspects. It is basically an all-things-to-all-people, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 1 everything soup to nuts involved with the development 2 process of digital I&C systems.
3 What we're trying to do is, we can't just 4 remove that because it is, actually, very good 5 guidance, depending on what aspect of the development 6 process you're looking at, you're evaluating. But 7 what we can do is we can emphasize and de-emphasize 8 certain things, depending on exactly what it is you're 9 looking at.
10 So, in a Phase 1 -- or I'm sorry -- in a 11 Tier 1 review where we're looking at design outputs 12 and we see test results, we can de-emphasize those 13 planning parts. In an alternate tier where all we see 14 is the planning and development activities, we can put 15 additional emphasis on that and, of course, we can de-16 emphasize the test results in those cases.
17 MEMBER BROWN: We need to keep moving.
18 So, I want to just make the Committee aware there are 19 other thrusts of their evaluations. RIS 2002-22 has 20 to deal with these types, the 50.59 type, what falls 21 under that to some extent, as well as another set of 22 documents relative to embedded digital devices, which 23 inflames other emotions when you get involved with 24 them.
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88 1 comment relative to Phase 2, and there is no Phase 3.
2 Yet, there is a post, in your figure C.1, there is 3 what you call a post-license-amendment issuance, which 4 is, in my view, kind of a Phase 3, but it's not part 5 of the actual -- it's after license amendment has been 6 applied. So, I agree, you've deleted the old Phase 3, 7 but there's still, in a tiered system, there is still 8 a post-license. I don't think it's --
9 MR. STATTEL: That's true. The process is 10 still there.
11 MEMBER BROWN: And it's in both. It's in 12 both, as the alternate review process and the other 13 one.
14 MR. STATTEL: But we removed the table 15 from the enclosure.
16 MEMBER BROWN: Yes, I got that part, but 17 it doesn't need it. It's just that it's not like 18 everything stops --
19 MR. STATTEL: Right.
20 MEMBER BROWN: -- after Phase 2. That's 21 the point.
22 MR. STATTEL: That's true. Right.
23 MEMBER BROWN: Okay?
24 MR. STATTEL: Yes.
25 MEMBER BROWN: All right. Go ahead.
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89 1 MR. DARBALI: One more point I would like 2 to bring on the relay. The industry members --
3 MEMBER BROWN: You don't know when to 4 stop, do you?
5 (Laughter.)
6 MR. DARBALI: The industry members that 7 have participated in the public meetings regarding 8 ISG-06 are also involved in an industry effort to 9 create a digital design or engineering design guide 10 document. So, it's meant to be an industry guide 11 document, and we'll tell them how to apply the ISG.
12 We haven't seen the document, but we would expect that 13 that guidance document would tell licensees for what 14 type of notifications they should use the ISG.
15 MEMBER BROWN: Okay. Keep rolling. Next 16 slide.
17 MS. ZHANG: I might --
18 MEMBER BROWN: Oh, you're on it?
19 MS. ZHANG: Again, my name is Deanna. I'm 20 here to discuss the system architecture section, and 21 specifically on the four fundamental design 22 principles.
23 As Samir and Rich both stated, this 24 section has now been expanded to apply to both the 25 Tier 1, 2, and 3 process as well as the alternate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 review process. So, this fundamental design 2 principles and the system architecture was in that 3 system architecture section, has been emphasized in 4 this Revision 2, ISG-06.
5 Just to reiterate, the four fundamental 6 design principles include redundancy, independence, 7 deterministic behavior, diversity, and defense in 8 depth. And these are the same fundamental I&C design 9 principles used in support of the staff's ongoing 10 NuScale Chapter 7 review, which the staff uses, the 11 Design Review Standard, DSRS.
12 So, it is expected that the licensee 13 provides the information that supports the Safety 14 Evaluation, including demonstrating how the proposed 15 design and architecture meet the four fundamental I&C 16 design principles and how applicable regulations are 17 met.
18 For the fundamental design principle of 19 redundancy, the system architecture section specifies 20 that the NRC staff should verify that the licensee has 21 demonstrated there is sufficient redundancy in the new 22 architecture. This includes verifying that the single 23 failure criterion reliability and requirements for 24 maintenance bypass have been addressed by the design.
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91 1 independence, the system architecture section 2 specifies that the NRC staff should verify that the 3 licensee has demonstrated that the design applies 4 physical, electrical, data communications independence 5 as well as functional independence in the new 6 architecture. The staff should review whether 7 connections internal to the safety system, including 8 cross-divisional interfaces, connections to human 9 systems interfaces, connections between safety-related 10 and non-safety systems have been adequately 11 identified.
12 For the fundamental design principle of 13 determinism, the system architecture section specifies 14 that the NRC staff should verify that the licensee has 15 demonstrated that the design exhibits deterministic 16 behavior. So, the reviewers should evaluate whether 17 deterministic behavior of the new architecture ensures 18 input signals and system characteristics result in 19 output signals through known relationships among the 20 different system states and responses to those states, 21 and the system produces the same outputs for a given 22 set of input signals within a well-defined response 23 time limit. In other words, the design exhibits 24 predictable and repeatable behavior.
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92 1 design to demonstrate that software failures, whether 2 they affect the watchdog timer functions, including 3 when the watchdog timer times out. This information 4 should address hardware and software malfunction 5 coverages for the watchdog timer, including a 6 description of the enunciation and the effects on the 7 plant during and after any reset of the functions 8 initiated by an expiring watchdog timer.
9 For the fundamental design principle of 10 diversity and defense in depth, the system 11 architecture section specifies that the NRC staff 12 should verify that the licensee has demonstrated, via 13 diversity and defense-in-depth evaluation, that the 14 use and application of D.3 in the new architecture 15 ensures that safety is maintained in the event of a 16 postulated software common-cause failure.
17 Next, I'll pass it on to Samir for the 18 license and oversight --
19 MEMBER BROWN: But, before you do that, 20 I'll just bring up, as we discuss in all the new 21 certifications and other aspects, even when we did 22 Diablo Canyon, there was an emphasis, also, on --
23 although nobody likes to admit it -- control of 24 access. And that is not directly addressed in the ISG 25 as a principle, although you probably recognize that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 1 as long as I'm on the Committee will be resolving 2 control of access, and not relative to a cybersecurity 3 issue, but relative to just blocking off access from 4 external to the plant. I mean, it's literally 5 applying the same thing to the new architectures that 6 we apply to how you manage access to the hardware and 7 the cabinets inside the plant that we've always done.
8 So, I haven't figured out how to get you guys to admit 9 to that yet.
10 CHAIR CORRADINI: If you hadn't said this, 11 I would have been shocked.
12 (Laughter.)
13 MEMBER BROWN: Yes, I just wanted to get 14 it on the record that that is an aspect that is 15 missing from the ISG.
16 MR. DARBALI: Okay. So, I think I'll --
17 CHAIR CORRADINI: Just let it go.
18 (Laughter.)
19 MEMBER BROWN: I don't want you to take 20 any issue with my comments. They're simply meant to 21 be put on the record and to put everybody on notice 22 that --
23 MS. ZHANG: We understand.
24 MEMBER BROWN: It's a very important 25 issue.
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94 1 MR. DARBALI: I will only say secure 2 development and operational environment is covered --
3 MEMBER BROWN: That has nothing to do with 4 control of access.
5 Okay. Have at it now.
6 MR. DARBALI: All right.
7 MEMBER BROWN: You can work on your little 8 chart here.
9 MR. DARBALI: This is just a summary of 10 the two different processes. The Tier 1, 2, and 3 11 review process has two submittals, one with the LAR 12 and, then, the supplemental Phase 2. Whereas, the 13 alternate review process just has one submittal, which 14 is the LAR.
15 If there are design changes made after the 16 license amendment request has been submitted, under 17 the tier review process, those can be incorporated as 18 part of the Phase 2 review. Whereas, if those occur 19 during the use of the alternate review process, it may 20 not be possible to review those. So, those would have 21 to be performed with a new license amendment request, 22 if needed, or through the 50.59 process.
23 We typically don't have license conditions 24 for the Tier 1, 2, and 3 review process. And when I 25 say "license conditions," I mean specific to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 1 digital I&C platform design. Whereas, with the 2 alternate review process, we envision we will have 3 license conditions regarding those implementation and 4 testing activities.
5 And then, the inspection scope, both the 6 tier process and the alternate review process will 7 make use of our regional and site inspection process, 8 but the alternate review process will make use of the 9 vendor inspection process to look at those 10 implementation and testing activities.
11 Next slide.
12 So, the next steps in the ISG-06 revision 13 project is to issue Revision 2, Draft Revision 2, for 14 public comments at the end of July; if not, early 15 August. We are going to be conducting an inspection 16 workshop with industry in September to go over these 17 additional inspection activities related to the 18 alternate review process. We expect to issue the 19 final ISG at the end of the year, and then, engage 20 utilities in the use of the ISG Revision 2 through 21 pre-application meetings. And eventually, we do know 22 this is an Interim Staff Guidance, so we do know that 23 we will be incorporating this into the standard review 24 plan or our Reg Guide.
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96 1 envision any additional ACRS involvement after the 2 public comments are addressed?
3 MEMBER BROWN: Our letter will address 4 that.
5 MR. DARBALI: Okay.
6 MEMBER MARCH-LEUBA: Well, I'm asking 7 them.
8 (Laughter.)
9 MR. DARBALI: We will be happy to 10 accommodate that, if the Committee feels they would 11 like to be briefed again. We're trying to follow an 12 NRR Office instruction. I forgot -- like 508, I think 13 it is. It's the ISG development process. It only 14 calls for one briefing to the ACRS, but I'm sure we --
15 MR. WATERS: Yes, let us circle back to 16 that. We want to make this summer date, and we're 17 happy to engage the ACRS. I don't think we had 18 planned to resubmit the final version review or 19 meetings. But we do plan for, when we get an 20 application in, to engage on an actual application 21 that would be used in this Draft ISG, whenever that 22 comes in.
23 MEMBER BROWN: But we will address that in 24 our letter. I can only comment that we've done a 25 complete review of the ISG as it presently stands.
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97 1 Depending on the nature of public comments and how 2 they're incorporated, if they do something -- so, we 3 will have to evaluate what we do with that subsequent 4 to this particular letter. So, I'm not counting it 5 out, but I'm not saying you'll have to.
6 Is that an appropriate -- I think that's 7 an appropriate way of phrasing it.
8 MR. DARBALI: Yes. Appreciate it.
9 MEMBER BROWN: I'm done. Yes, I would 10 just emphasize we've got a hard stop at 12:15. We've 11 got about nine slides left for the IAP discussion.
12 CHAIR CORRADINI: And then, we still have 13 to reserve time for public comment.
14 MEMBER BROWN: Public comments. So, if 15 you could finish in about 30 minutes or so, that would 16 be useful. Or earlier. That's fine, also.
17 CHAIR CORRADINI: I can't control the 18 members in terms of their interactions. I can't even 19 control myself. That's also the truth.
20 So, have at it.
21 MR. RAHN: Yes, sir. So, thank you. I 22 will lead you through this discussion on the 23 Integrated Action Plan.
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98 1 document. We briefed the Digital I&C Subcommittee.
2 And then, last year, we also briefed them on the 3 status of the Integrated Action Plan in May of last 4 year, also, the Digital I&C Subcommittee. I think 5 this might be the first time we're presenting it to 6 the full Committee.
7 What we would like to talk about today is 8 just an overview, and then, perhaps be ready to answer 9 questions that you may have.
10 The key items that we would like to 11 emphasize are that, once we've embarked upon the 12 Integrated Action Plan, we work closely with 13 stakeholders, typically through a series of public 14 meetings, to identify what kinds of regulatory 15 products would be most beneficial for them. And then, 16 we work to develop those products, have some kind of 17 comment process on those products, especially if it's 18 the regulatory process, it requires it. And then, in 19 addition, we have now started to release the first of 20 our products.
21 We have been focusing on those products 22 that only answer the near-term needs. So, we've 23 essentially prioritized everything into what we call 24 tactical and strategic planning efforts. We have been 25 focusing on the products that are part of our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 1 technical effort right now.
2 And so, recently, we released a document 3 that Charlie recently just mentioned. We issued a RIS 4 supplement to RIS 2002-22. That document endorses an 5 NEI implementing guide which is called NEI-0101. In 6 that document, there has been maybe some uncertainty 7 regarding the appropriate use of that. We have some 8 inspection items where it appeared that the licensees 9 didn't all fully understand what the guide was telling 10 them to do.
11 But, most importantly, they were having 12 difficulty implementing the upgrades under a 10 CFR 13 505.59 process. So, RIS 2002-22, Supplement 1, 14 provided a more clarified way of approaching how to 15 prepare for doing 50.59 evaluations using what we call 16 a qualitative assessment process. We had, actually, 17 a briefing of the Subcommittee on that specific topic 18 last month.
19 Also, we are planning on considering the 20 long-term needs yet for what should our digital I&C 21 infrastructure look like. And so, we've started the 22 ball rolling as far as identifying topics to be worked 23 on. But, most importantly, we're at the point now 24 where we've overcome the hurdle of what we need for 25 the short term. We would like to now have a better NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 1 informing of what our long-term process should look 2 like. So, at the end of this month, we've scheduled 3 a public meeting to help that process.
4 Yes?
5 MEMBER BLEY: Can I interrupt?
6 MR. RAHN: Yes.
7 MEMBER BLEY: And this is more a 8 Committee/Subcommittee question, a Committee question, 9 Charlie. But my impression was in our letter we're 10 only addressing the ISG.
11 MEMBER BROWN: Just the ISG-06.
12 MEMBER BLEY: Were we intending to ever 13 address the RIS or is that on our calendar or not?
14 MEMBER BROWN: Right now, it's been 15 issued.
16 MEMBER BLEY: Oh, it's just out there?
17 Okay.
18 MEMBER BROWN: Yes. There was an earlier 19 version that was issued, I've forgotten when.
20 MR. RAHN: Yes, there was a version issued 21 in July for public comments, last July.
22 MEMBER BLEY: Right.
23 MR. RAHN: And then, we issued it again 24 for public comments in March of this year.
25 MEMBER BROWN: Is that Supplement 1?
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101 1 MR. RAHN: Yes, it's still Supplement 1.
2 And then, we've incorporated public 3 comments received during that March time period.
4 MEMBER BLEY: Okay.
5 MR. RAHN: And now, it's been formally 6 issued.
7 MEMBER BLEY: Okay. Thank you.
8 MR. RAHN: So, what we're embarking on is, 9 there are directions we got from the Commission that 10 were identified in two SRM documents, 15-0106 and 11 16-0070. Those documents were initiated because we 12 were attempting to perform an incorporation by 13 reference of the 2009 version of IEEE 603. And when 14 the proposed language for rulemaking went up with that 15 info paper -- I'm sorry, it was a SECY paper -- it was 16 also submitted with not only incorporating by 17 reference IEEE 603, but also includes some additional 18 requirements regarding things like digital 19 communications and independence, and there was some 20 additional phrases that were being proposed.
21 And the Commission decided that, rather 22 than to take it upon ourselves to change the rule by 23 inserting these additional clauses -- and some of 24 these clauses were not -- they would be good for new 25 reactor applications, but not ideal for operating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 1 reactors because their design basis and their 2 licensing basis was based on the previous versions of 3 IEEE 603. So, they were suggesting that, rather than 4 propose new rules, a better approach would be to 5 identify what should be the really important 6 requirements, and put those in the rule, and then, 7 identify other enhancements of that as guidance, and 8 keep that in the guidance level.
9 So, they provided us an SRM that basically 10 had these bullets included in there, which was let's 11 not only address this rulemaking for 603, but look at 12 the whole broad picture of how do we do digital I&C 13 regulatory reviews, and provide some kind of a 14 strategy that has some kind of a cohesive effort that 15 addresses all the needs for the agency as well as 16 stakeholders, but primarily making sure that we have 17 good representation of the NRR, NRO, and Research 18 needs in mind.
19 And then, along the way, in doing that, we 20 were to identify the best ways of engaging all our 21 stakeholders to provide input for our consideration 22 and help to identify regulatory problems and solutions 23 for them. Basically, all new requirements should be 24 performance-based. We had a little discussion last 25 month of what does performance-based mean. But we are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 1 aiming towards keeping that in mind. And so far, we 2 haven't identified new requirements at this point, 3 but, if we do, that's the approach we're going to 4 take.
5 We're going to focus on what kinds of 6 approaches would be acceptable and to comply with the 7 current requirements. And if we come up with new 8 requirements, it's the same thing; come up with 9 guidance for that.
10 Any new requirements should be technology-11 neutral. And I think we talked about technology-12 inclusive. I think that was something another 13 licensee brought to our attention. And then, in 14 addition, a guidance for any specific technology types 15 could be tailored, if necessary.
16 The same requirements should apply to new 17 reactors and operating reactors. And we also need to 18 evaluate any policy issues that could arise while 19 we're going to through this process and bring it to 20 the attention of the Commission as early as possible.
21 So, the approach we have taken, as I 22 described a little earlier, is that we looked to see 23 what all inputs we had from stakeholders, and we tried 24 to work with them to prioritize what are their needs 25 and what's their relative priority. And so, we broke NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 1 our approach into two pieces, a tactical, for address 2 all our short-term needs, and a strategic, which will 3 identify where should we go with this regulatory 4 infrastructure for the long term.
5 The long-term need is to also identify not 6 only the types of lightwater reactors that we're 7 currently licensing, but also any new small modular 8 reactors or advanced reactors that could be proposed.
9 So, the regulatory infrastructure needs to be 10 accommodating to all those different types of 11 technologies.
12 The plans that we have --
13 MEMBER BROWN: Let me make an 14 observation --
15 MR. RAHN: Yes, sir. Yes.
16 MEMBER BROWN: -- if I could. Going back 17 to the comment about the same requirements for 18 operating versus new reactors --
19 MR. RAHN: Yes.
20 MEMBER BROWN: -- which I totally agree 21 with, just for the Committee members who have not been 22 on the Committee for a long time -- Dennis will 23 remember this, and so will Mike, probably Dick to some 24 extent. I think that might be about it. Since we 25 started dealing with the digital stuff back in 2008 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 1 and '09 on -- I've forgotten what the plant was, ESBWR 2 -- the Committee, us, our viewpoint has been applied 3 in exactly the same way, whether it has been a new 4 design reactor or upgrades for the operating reactors.
5 And I've always wondered how in the world can we get 6 that thought process applied relative to how you all 7 do your infrastructure. I haven't come up with a good 8 way to do that yet. But the fundamental principles 9 approach to evaluating it, and then, having everything 10 else waterfall under that, is a very consistent way of 11 applying it to both new and operating reactors in 12 terms of new reactor protection and safeguard systems, 13 whole system replacements. I'm not talking about a 14 relay here or a relay there, or what have you. So, 15 that's an important point. I just wanted to emphasize 16 that; having both march to the same drummer is a very 17 valid point to deal with it.
18 The other discussion we had in the 19 Subcommittee meeting -- and it was very, very, very 20 animated for a couple of us with this what do we mean 21 by performance-based, which is about as ambiguous as 22 you can get, in my own mind. But, I mean, we can 23 continue to struggle with that. But using the 24 fundamentals is a performance-based approach to doing 25 things.
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106 1 And so, if a regulatory framework, 2 overarching one, is structured around that framework, 3 let everything else waterfall out from under it, that 4 establishes a performance-based, rather than 5 prescriptive, general way of approaching things. So, 6 anyway, I just had to throw that one in for the 7 record.
8 MR. RAHN: Currently, in our plan, we're 9 on what we call Revision 2 of our plan. Some of you 10 may have already seen this version which we published 11 in January. But it covers the topics I have on this 12 slide.
13 The first one is what we call our 14 protection against common-cause failure. We refer to 15 these as MPs, for modernization plans. MP 1 has three 16 aspects to it. The first one has to do with 17 development of this RIS 2002-2022, Supplement 1, which 18 I mentioned earlier.
19 A second part of it is a document that we 20 were planning to review, and potentially endorse, 21 having to do with identifying design attributes that 22 could be used for supporting a qualitative assessment 23 that you could refer to when you're performing digital 24 upgrades under 10 CFR 50.59.
25 It's a document that's being prepared by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 1 NEI called 16-16. That document got started, and 2 then, it got placed on hold pending an update of a 3 portion of it that is being prepared by EPRI. So, 4 it's going to refer to, it's going to have an appendix 5 at the end of it which talks about different types of 6 digital hazards such as software hazards or 7 communications or intercommunication links, and then, 8 what potential design attributes could you include in 9 a design to address those hazards. That document is 10 still being prepared, and it's not expected to be 11 completed until later this year. Mid-November I think 12 is the timeframe they were giving us. So, we'll 13 resume work on that review after NEI provides us the 14 next version.
15 MEMBER SKILLMAN: David --
16 MR. RAHN: Yes?
17 MEMBER SKILLMAN: -- before you change 18 this slide, let me ask this question. And it's 19 relating to the second bullet. The words that you 20 used were "upgrades under 50.59".
21 MR. RAHN: Yes.
22 MEMBER SKILLMAN: And I would ask you to 23 clarify what you mean by that. I ask the question 24 because there was at one time in the industry the 25 notion 50.59 is a change process. It's not.
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108 1 MR. RAHN: Yes.
2 MEMBER SKILLMAN: It's a screening process 3 to determine whether or not the change rises to the 4 level of requiring a license amendment. So, let me 5 ask you, please, to clarify what you meant.
6 MR. RAHN: Yes, that's exactly what we 7 mean. Before making a determination that a 8 modification to the plant could be made, the important 9 first step is to verify that that particular 10 modification is consistent with the current licensing 11 basis for a plant. Typically, that's as documented in 12 the Safety Analysis of record. So, typically, the 13 first step is to see, are they introducing some new 14 mode of failure or some type of error that could 15 introduce or increase the frequency of accidents. And 16 so, they have to embark on a process that says, if 17 they trigger one of these eight criteria, such as 18 accident frequency or new malfunction types, then they 19 wouldn't be consistent with their current licensing 20 basis, and a prior staff review would be needed. And 21 that's what it is aimed at, is helping licensees 22 response to the eight criteria that are in the 23 10 CFR 50.59 process.
24 MEMBER SKILLMAN: Thank you, David.
25 MR. RAHN: Yes. The Part 1.C is an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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109 1 evaluation of where are we with regard to the existing 2 policy for addressing CCF. So, we've embarked upon a 3 review of where are we currently with regard to our 4 guidance that responds to SRM SECY-93-087, which 5 currently describes what would be a suitable approach 6 for addressing potential for common-cause failure, 7 primarily aimed at software introducing.
8 So, that evaluation was done, and we're 9 preparing an info SECY paper that would outline what 10 we consider to be our recommendations for maintaining 11 status quo with that and perhaps enhancing the way we 12 adopt that policy in our existing guidance documents.
13 So, that paper is a draft right now. We've gone up 14 through our channels, but we haven't submitted it.
15 We're planning to submit that thing next month.
16 Yes?
17 MEMBER BROWN: When you say "submit," you 18 mean submit --
19 MR. RAHN: To the Commission.
20 MEMBER BROWN: No, I'm just thinking about 21 we get a copy of it; that's all.
22 MR. RAHN: Oh, okay. Yes.
23 MEMBER BROWN: An outrageous thought 24 process.
25 (Laughter.)
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110 1 MR. RAHN: Yes, right. Well, I would 2 think the one we've done already, I don't see a 3 problem with that, sharing it. But what do you think?
4 MEMBER BROWN: It's an open document. It 5 will be publicly accessible, correct?
6 MR. WATERS: Yes, actually, it's an 7 information paper to the Commission explaining how we 8 are moving forward in applying common-cause failure.
9 At our briefing two months, what you saw 10 was essentially a comment in the paper. It will be a 11 more narrative format, but applying the guiding 12 principles and, again, addressing scope, as well as we 13 believe our next step will be updating Branch 14 Technical Position BTP 7-19 to the Staff Guidance for 15 addressing D.3 for an entire scope of systems. And 16 we'll be happy to engage the ACRS on that document as 17 we begin updates. But, yes, we'll make the 18 information paper available to the ACRS when it's 19 complete.
20 MEMBER BROWN: Yes, that would be useful.
21 We had an interesting discussion on this during the 22 6/20 Subcommittee meeting, where I guess the Committee 23 expressed that BTP 7-19 and the addition of diverse 24 actuating systems, or whatever you want to call them, 25 diverse systems based on an analysis of where you need NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 1 them, if operators can't take care of stuff -- we've 2 got plants operating under those right now, and it 3 seems to work.
4 And how complicated do we need to make 5 this? That's my only big concern, is you're never 6 going to be able to test software; you're never going 7 to be able to find software errors. You don't have 8 the resources, and the vendors don't have the 9 resources, to test it and a manner to do that, either.
10 Software errors are largely designed items. So, I 11 mean, the software does what it's going to do.
12 The diverse approach to doing business 13 looks like we're not going to tell plants to stop 14 operating because of some new metrics that you come up 15 with. So, I just wanted to get that back out, that we 16 had that discussion in the last meeting, and quite 17 frankly, we've done a lot of design certifications 18 where we've accepted the BTP 7-19 approach was the 19 diverse protection systems being the solution to the 20 common-cause failures in the I&C systems.
21 MR. WATERS: I think staff agrees with 22 that, and that was one of the four fundamental 23 principles we talk about in ISG-06.
24 MEMBER BROWN: Exactly.
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112 1 at an appropriate level of defense in depth and 2 diversity to the extent practical commensurate with 3 the risk associated with the system. One of the 4 questions we faced is the "What if?" What if we get 5 a smaller upgrade that's not a full-blown RPS or SFAS 6 or for a LAR review? What's the scoop with that?
7 What flexibilities do we have in using best estimates 8 and operator diversity, to create operator 9 intervention? And this is some of the things we 10 wanted to clarify in the BTP.
11 MEMBER BROWN: Okay. I just wanted to get 12 it that it's been discussed.
13 MR. WATERS: Sure.
14 MEMBER BROWN: And I certainly am looking 15 that we do what we need to do, but don't do stuff that 16 prevents moving forward with these systems which are 17 vast improvements on the reliability and the operation 18 of the plants. Those are real concerns.
19 We've got about 10 minutes here for you to 20 finish up four slides.
21 MR. RAHN: Yes. So, I'll get through the 22 rest of this slide, and then, I can zip through the 23 remainder. The next item on here is what we call our 24 Modernization Plan No. 2. In this plan, we are more 25 formally developing a product which will become NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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113 1 probably an endorsable guide.
2 Currently, the guidance for addressing the 3 10 CFR 50.59 process is covered in a Reg Guide, 1.187.
4 That Reg Guide endorses NEI document 96-07. 96-07 5 goes into great detail about how do you do this 6 evaluation to determine whether prior staff approval 7 is needed before you can make a change. But that 8 guidance, even though it's very detailed, it didn't 9 address some of the criteria that a mod engineer at a 10 plan would need to consider when he does digital 11 upgrades.
12 So, it was decided that a new appendix be 13 developed. So, we refer to it as 96-07, Appendix D.
14 It's going to have some specific criteria in it that 15 would aid a modification engineer at the plant to 16 perform the evaluations that are needed to ensure that 17 he doesn't have to have prior staff approval.
18 We would plan to have that endorsable.
19 That particular product is still in development.
20 We've had many months of dealings with the developers, 21 and we think we see light at the end of the tunnel.
22 MR. WATERS: Let me just clarify --
23 MEMBER BROWN: That's an NEI?
24 MR. WATERS: Yes. This is a document that 25 they are revising, a lot based on the lessons from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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114 1 RIS we talked about. And we're expecting to submit 2 that for endorsement and review.
3 MEMBER BROWN: Thank you.
4 MR. RAHN: The next Modernization Plan is 5 one that we have that is called "Acceptance of Digital 6 Equipment". What it's really about is, is there a way 7 that we could enhance the process by which we address 8 the critical characteristic of dependability for a 9 particular new digital platform or a component that 10 would be used in a safety-related application that's 11 been procured under a commercial grade dedication 12 process?
13 That is also being started, and it's being 14 done with the assistance of work by EPRI. What we're 15 looking at is the possibility of leveraging some of 16 the work that's already been done for the oil and gas 17 industry through their use of ISA Standard 84 and IEC 18 Standards 61508 and 61511.
19 In those processes, they determine what 20 they call a safety integrity level, and then, a third-21 party certifier does some evaluations and testing to 22 determine whether or not a particular vendor's product 23 could meet a certain certification level.
24 And so, what we're considering is coming 25 up with a process by which we could also recognize NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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115 1 that certification level. In order to do that, we 2 would have to certify the certifiers first. And then, 3 we would have some kind of avenue by which a licensee 4 may be able to procure a device that's been certified 5 under that process as part of the input to our 6 commercial grade dedication process. Basically, that 7 would help leverage the issue about dependability of 8 a hardware/software platform for safely performing it 9 safety integrity actions.
10 The last item we have is our long-term 11 regulatory approach. Samir talked to us today about 12 the first item, which we call Modernization Plan 4A, 13 which is a better description of a more efficient 14 licensing process. But, beyond that, we're just now 15 coming to terms with what else are we going to include 16 in this modernization effort. We have a number of 17 suggestions that have been given to us through 18 stakeholders and NEI and other organizations, but they 19 haven't been revisited in a couple of years. So, what 20 we're next going to do is evaluate that current list 21 and, also, listen to stakeholders for any new items 22 that might arise because of the fact that we're now 23 including advanced reactors in our upfront potential 24 for new license applications.
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116 1 this month to gather more information and to help 2 prioritize the needs for that. Mostly important to us 3 is helping us organize for what kind of regulatory 4 research activities need to go on before we can do 5 that modernization.
6 Okay. So, here's where we are at with the 7 IAP. We've originally sent a draft of this to the 8 Commission, and they responded in October of 2016. We 9 have already issued Revisions 0 and 1, and Revision 2 10 is now on the street. Revision 2 came out in January.
11 Right now, we're identifying all the things that need 12 to be changed for Revision 3. We plan to issue 13 Revision 3 in September of this year.
14 Along with that, in October, we provide an 15 annual report to the Commission telling them where we 16 are on the IAP performance, the status of where we are 17 at.
18 So, Rev. 2 identified some of these 19 changes that we've covered actually today. And Rev.
20 3, we're going to talk further about work that's 21 already been completed, but, also, we're going to try 22 to inform where we're going with the MPs that we've 23 already embarked upon and, hopefully, also identify 24 what should the longer-term activities include.
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117 1 meeting at the end of this month. We actually have, 2 with the various MPs, we have a meeting tomorrow, for 3 example, on the commercial grade dedication issue. We 4 will have continued meetings throughout this year. We 5 are also planning on preparing a Commission meeting in 6 October of this year. So, that is something that is 7 on our table along with everything else that we are 8 doing.
9 So, that's what we have for today, but I'm 10 happy to entertain any further questions.
11 MEMBER BROWN: Are you happy now, Mike?
12 Okay. You're complete.
13 If there's no more questions from the 14 table right now, should I go to the audience first?
15 Is there anybody in the audience for the 16 meeting today that would like to make any comments, 17 public comments? I don't see anybody standing up to 18 be recognized.
19 Kathy, is the phone line open?
20 MR. T. BROWN: The phone line is open.
21 MEMBER BROWN: Okay. Is there anybody out 22 there that would like to make a comment?
23 Thank you for telling me it's open. I 24 appreciate that.
25 (No response.)
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118 1 MEMBER BROWN: Hearing none, Mike, I will 2 turn it back over to you.
3 CHAIR CORRADINI: Okay. I wanted to thank 4 the staff. I know we kind of constrained you into 5 this, unfortunately, but I appreciate both the 6 discussion for the ISG as well as your plans for the 7 IAP. I'll get it wrong if I try to say the words. I 8 remember the IAP.
9 So, at this point, we're going to take a 10 break. We have to be back here, the Committee members 11 have to be back here at 15 after precisely because 12 we're going to have a security discussion in closed 13 session. So, I'll let you go, as long as you come 14 back in 17 minutes.
15 MEMBER BROWN: When do we eat lunch?
16 After the security session?
17 CHAIR CORRADINI: At 12:15, be back here.
18 What you choose to do with your 17 minutes is your 19 choice. Okay. See you back here shortly.
20 (Whereupon, the above-entitled matter went 21 off the record at 11:57 a.m. and resumed at 1:45 p.m.)
22 CHAIR CORRADINI: Okay, we'll come back 23 into the session. Our topic for this afternoon is the 24 APR1400 design evaluation review and I'll turn it over 25 Professor Ballinger.
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119 1 MEMBER BALLINGER: Thank you, Mr.
2 Chairman. This meeting represents, I hope, and I hope 3 they hope as well, the last meeting on the APR1400.
4 I could list the meetings that we had over 5 the past year and a half or more but it would take too 6 much time. I could list the people that have 7 contributed to all of this, staff and members of the 8 Committee, and that would also take too much time.
9 So, I'll just thank everybody ahead of 10 time that we got this far and hopefully, we'll have a 11 great conclusion today and going forward. And is 12 Bill...Yes, he's not in the next room.
13 MR. WARD: Thank you.
14 MEMBER BALLINGER: Do you want to say a 15 few words?
16 MR. WARD: Yes, this is the last meeting, 17 we hope, I definitely agree with that and we, too, 18 would like to thank all the people that have been 19 involved, those currently involved, those in the room, 20 and all the prior Members of the Committee, at least 21 one of whom I've seen walking around the floor 22 already, and even prior Members of our staff who are 23 also attending as members of the public.
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120 1 with hopefully the outcome we need.
2 Thank you.
3 MR. SISK: This is Rob Sisk, Westinghouse.
4 I'll just very briefly echo the comments already made.
5 I'm very appreciative of everybody that 6 got us to the point where we are now, coming to the 7 end of Phase 5 as we get to this milestone for 8 APR1400. And it's been quite a journey.
9 So without further ado, I would like to 10 introduce Mr. Yunho Kim, the APR1400 Project Manager.
11 MR. KIM: I am Yunho Kim from KHNP, I am 12 actually APR 1400 Project Manager. I'm very honored 13 to have the scheduled time at the ACRS Committee 14 meeting.
15 So looking back at our bigger process, at 16 Page 3 we have more than 300 open items. So we needed 17 closer communication with the staff. We resolved all 18 the open items, and based on that, we have ACRS 19 meeting October 2017 to last month, June 2018. We 20 presented how we resolved those open items.
21 It was a very tremendous work but there 22 was a very good benefit for APR1400 application. So 23 from now on, I want to have a good productive meeting 24 today and I wanted to just thank you for APR1400.
25 Thank you.
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121 1 MR. KIM: Good afternoon, ladies and 2 gentlemen. My name is Taehan Kim from KEPCO E&C. I'm 3 honored to be here today to present this material, 4 this section 5 on APR1400 design future and design comparison and 6 summary of review at this final ACRS meeting for 7 APR1400 review.
8 This slide shows the contents of my 9 presentation. First, the lead design feature of the 10 APR1400, design comparison of APR1400 and the System 11 80+, and enhancements addressed during the review 12 process, and ITAAC items addressed during the review 13 and summary of topical report and RAIs. Then I will 14 summarize this presentation.
15 Let me start by presentation by 16 introducing the design feature of APR1400. As you 17 know, APR1400 is an evolutionary pressurized water 18 reactor which I improved from the operating stage of 19 APR1000 and conventional shipment and System 80+.
20 Major improvements include 4-train safety 21 injection system, I mean mechanically and 22 electrically, and in-containment refueling water 23 storage tank, a full digital instrument and control 24 system, and also severe accident mitigation system 25 with the incorporation of new requirements for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 hydrogen, gas control, and containment of over-2 pressure protection.
3 This slide shows the different design 4 features of APR1400 from System 80+. The first item 5 is pre-stressed concrete cylindrical containment 6 compared with spherical steel containment of System 7 80+.
8 The second and distinctive new design 9 feature is fluidic device in safety injection tank to 10 enhance safety injection system performance. The next 11 item is fully digitalized, improved I&C system and the 12 computer-based main control room design.
13 And the rest, PLUS 7 fuel with enhanced 14 thermal margins, high burnup, and improved fuel 15 economy. And APR1400 incorporates the passive 16 autocatalytic recombiner and igniter for hydrogen 17 mitigation.
18 Also design enhancement to better execute 19 severe accident mitigation strategies such as 20 emergency containment spray backup system with the 21 external water tank and mobile generator to control 22 long-term containment pressure.
23 This slide shows the major parameters of 24 APR 1400, design lifetime of 60 years for Class 1 25 major equipment, 4000 megawatt thermal and a 1400 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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123 1 megawatt electrical power.
2 Operation condition of primary and 3 secondary site is listed as follows. This slide shows 4 the safety injection system configuration and brief 5 description.
6 As shown in the left figure, it is a very 7 simply design with four independent trains. Each of 8 them have one safety injection pump, one safety 9 injection tank, and related affairs.
10 Each pump takes borated water from the 11 IRWST and the IRWST is located at the lower level of 12 containment. By reducing the IRWST, the operational 13 reliability is enhanced due to no operator action for 14 continued long-term cooling.
15 The right-side figure shows the full-scale 16 test facility for fluid device development. A number 17 of full-scale tests for performance verification and 18 sensitivity of manufacturing tolerance of fluid device 19 were performed with this full-scale test facility.
20 This slide shows the internal 21 configuration of the vortex chamber in the fluid 22 device. The idea of passive flow control comes from 23 the application of vortex flow. Vortex flow is formed 24 in the vortex chamber and provides high-flow 25 resistance.
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124 1 The entire configuration of the Vortex 2 chamber is precisely designed to make strong flow when 3 water is supplied from the control nozzle only, as is 4 shown in the right figure. Because of high resistance 5 due to vortex, low inside flow is damaged.
6 However, if the water is supplied from the 7 both the supply port and supply nozzle and control 8 nozzle, as shown in left-side figure, low-flow vortex 9 is formed and high inside flow is damaged.
10 So when the water level in the tank is 11 high, we get high flow rate and when the water level 12 is low in the top of standpipe, we have low flow rate.
13 This slide shows the design feature of 14 instrumentation and control system with diverse 15 platforms. Safety system is implemented by 16 programmable logic controllers. Non-safety system is 17 implemented by distributed control system.
18 However, diverse protection system is 19 implemented by FPGA-based logic controller. Data 20 communication system maintains independence between 21 safety system and non-safety system. Remote shutdown 22 is also available when MCR is uninhabitable.
23 APR1400 has performed probabilistic risk 24 assessment evaluation for the following area based on 25 the basic element and approach given in ASME/ANS code.
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125 1 At power operation mode, Level 1 and 2 2 internal events include fire, internal flooding, 3 seismic risk evaluation based on the seismic margin 4 methodology and other external events performed.
5 For the low-power and shutdown operation 6 mode, APR1400 has also performed evaluation for Level 7 1 and 2 internal events, fire, flooding, and seismic 8 risk evaluation.
9 With this PRA, KHNP investigated design 10 improvements to reduce or eliminate weakness in 11 APR1400 design and as a consequence, increase the 12 number of emergency diesel generators from 224 and the 13 extended 125 volt DC battery life from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 16 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.
15 This following slide shows other design 16 features like GSI-191, Reg-Guide-4.21-related, AIA, 17 and more.
18 Regarding the GSI-191 issue, APR1400 19 design does not use fibrous insulation in the zone of 20 influence. And I&C sump strainer performance tests 21 were performed in accordance with the Reg Guide 1.83, 22 82, and ANS47.
23 Also, in-vessel downstream effects tests 24 were performed in accordance with document 16793.
25 APR1400 design includes features to conform with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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126 1 10 CFR 20.1406 and Reg Guide 4.21 to minimize 2 contamination of the facility and embodiment 3 throughout the life cycle.
4 APR1400 has minimized embedded and/or 5 buried piping, prepared a provision for early leak 6 detection and introduced trench and double-walled 7 piping. Aircraft impact assessment of APR1400 was 8 performed in accordance with 10 CFR 50.158 and Reg 9 Guide 1.217 and ANS7-13.
10 The structural analysis demonstrates that 11 the integrity of the containment is maintained as part 12 of meeting the sufficiency criteria for maintaining 13 core cooling and the integrity of the spent fuel pool 14 is maintained for all strikes to meet the AIA 15 requirement.
16 The heat removal assessment demonstrates 17 at least one division of core cooling is available for 18 all strikes. For the provision of loss of power 19 event, APR1400 has four EDGs, emergency diesel 20 generators, for emergency power and AAC gas turbine 21 generator for SBO.
22 And for FLEX design for the extended loss 23 of AC power, we provide with a FLEX pump RCS makeup, 24 spent fuel makeup, and spray mobile generator, and 25 also spent fuel level instrumentation.
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127 1 This following slide shows the summarized 2 design difference with the System 80+. Firstly, the 3 containment shape is much different. System 80+ has 4 a spherical steel containment but the APR1400 has a 5 cylindrical-shaped, pre-stressed concrete containment.
6 The thermal power of the core is slightly 7 different, the hot leg temperature is down from 621 to 8 615 to minimize deviation in the steam generator too.
9 The RCS overpressure protection system of the APR1400 10 consists of four high-level operated spring release 11 valves.
12 CHAIR CORRADINI: Can I ask a question 13 about those? What is the experience in Shin Kori 14 about the pilot operated safety relief valves. It's 15 my understanding there was some leakage there.
16 MR. KIM: We do have a POSRV in Shin Kori 17 3 and 4. we have some leaking problem.
18 CHAIR CORRADINI: Is it the same design as 19 what we're looking at here or has there been 20 modifications?
21 MR. KIM: In the design but to my 22 knowledge, as I heard, they manage to handle their 23 problem.
24 CHAIR CORRADINI: Say that again, please?
25 MR. KIM: They managed their problem.
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128 1 CHAIR CORRADINI: How did they manage the 2 problem?
3 MR. KIM: I don't really exactly know how 4 they did but it's what I've heard is the latest news.
5 CHAIR CORRADINI: When you started showing 6 these comparisons, I was looking for lessons learned 7 from either prior System 80 operation or current close 8 enough design.
9 So that's why I asked the question.
10 MR. KIM: This is a big difference and we 11 have the kind of things because I know they managed it 12 is the latest news.
13 CHAIR CORRADINI: So let me ask my 14 question a little bit differently. Has this, what 15 I'll call, leak issue in the pilot system been solved 16 for Shin Kori?
17 MR. KIM: That's what I heard.
18 MR. KIM: Actually, let me add some 19 explanation. actually, we had the same issue in the 20 Shin Kori 3 and the PNPP. So the HMPs are approaching 21 Kori 3, we are looking for what is the root cause and 22 that's still going on.
23 But we have found a way to solve the 24 leakage problems so Shin Kori 3 is now working on the 25 power operation. For the root cause of the leakage, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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129 1 we are still working on. So, probably within a year 2 we will find what is the main cause of leakage.
3 But I think the vendor --
4 CHAIR CORRADINI: Say that again, please?
5 MR. KIM: The vendor, vendor of POSRV, 6 says that usually, the minor leakage is acceptable but 7 the regular leakage I do not think is different today 8 so we tried to meet the core body, no leakage.
9 So we are trying to solve that issue.
10 Currently, we are working on it so probably it will be 11 somewhere within a year.
12 MEMBER KIRCHNER: A related question, 13 you're contrasting the design features that are 14 different from the CE System 80.
15 Of those major items you listed, how many 16 of them have been demonstrated in your modern plant 17 section in Kori? Have you pretty much done all these 18 similar improvements with your newer plants?
19 MR. KIM: In Kori 3 and 4, we applied all 20 these things, cylindrical concrete containment, the 21 power's the same, the holding temporary's the same.
22 And four-train safety injection system with the DBR 23 fluid device.
24 MEMBER KIRCHNER: POSRV? Is the Shin Kori 25 plant digital, I&C?
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130 1 MR. KIM: Yes.
2 MEMBER KIRCHNER: Thank you.
3 MR. KIM: Let me continue. APR1400 4 adopted the interior head assembly for the reactor 5 vessel head and its upper structure, and 6 considerations for strategy cabinet flooding system 7 and pile ignite and fluid device in safety injection 8 tank.
9 This slide shows the summarized table of 10 design differences with System 80+, almost the same 11 items. 4000 megawatt thermal and 1400 megawatt 12 electric and 1400 megawatt electric and 4PS POSRV and 13 IHA, and fluid device in safety injection tank.
14 And we applied the large display panel 15 with a compared work station with a computerized 16 procedure system for maintaining control of APR1400 17 network and data link for data communications for 18 APR1400.
19 This section in the required containment 20 and pile ignite apply for hydrogen gas mitigation and 21 a gas turbine generator and an additional backup 22 supply of spray water.
23 From this slide, the major enhancement 24 addressed during the required process will be 25 presented. Unlike the other Applicant, APR1400 has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 adopted graded approach on the piping design area, I 2 meant design acceptance criteria, through 3 communication with the NRC staff by utilizing detailed 4 reference design information.
5 And for the structure of the design, the 6 effects of the construction sequence and the post-7 construction analyses of the NI building have been 8 considered in the structure of the design based on the 9 construction practice of APR1400, I mean Shin Kori 3 10 and 4.
11 This slide shows the major design 12 enhancement items in instrument and control systems.
13 For plant protection system, switch panel is added for 14 trip channel bypass, setpoint reset, and operating 15 bypass. And cross-channel communications are deleted 16 except 14 signals for reactor trip.
17 For diverse protection system, we adopted 18 FPGA-based logic controller instead of PLC.
19 And TPS channel, TPS2 channel is increased 20 to four channels to be two out of four trip and motor-21 generator set breaker trip is changed to reactor trip, 22 switchgear breaker trip and also reactor trip.
23 Switchgear is changed once they go from one set of 24 four break to two diverse sets of eight breaks.
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132 1 of ITAAC items. We have a total 1202 ITAAC items and 2 key changed items are summarized in the next slide.
3 This slide shows the list of key change 4 items in ITAAC during the review process.
5 ITAAC wording change based on NRC 6 guidelines and incorporation of standardized ITAAC 7 guidelines and technical-related item like CPU load 8 restrictions prior to logic within the SF, 9 structure-related ITAAC items, and things like that is 10 incorporated, I mean addressed during the review 11 process.
12 KHNP provided five topical reports to 13 support the APR1400 application, such as KHNP-QAPD for 14 the APR1400 DC, KCE-1 critical heat flux correlation 15 for PLUS7 thermal design. The third one is the fluid 16 device design for APR1400.
17 The first one is realistic evaluation 18 methodology for large break LOCA of the APR1400 based 19 on PLUS7 fuel design for the APR1400. All five 20 topical reports have been reviewed and approved by the 21 NRC staff.
22 KCE-1 CHF correlation topical report 23 described a CHF test of PLUS7 fuel, correlation 24 development, verification and validation, and each 25 application to the APR1400.
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133 1 KCE-1 CHF correlation topical report 2 supports DCD Chapter 4 and 15 by issuing the design 3 acceptance criteria under full compliance with 4 conditions and limitation of FSER.
5 Fluid device topical reports contain the 6 design requirements, detailed design of the SIT-FD and 7 the result of full-scale performance verification 8 tests, fluidic device topical reports about DCD 9 Chapter 6 and Chapter 15 by issuing the design and the 10 performance of SIT-FD.
11 479 topical report contains evaluation 12 result for fuel assembly and rod supporting, DCD 13 Chapter 4. Main contents of 479 topical reports are 14 fuel rod design, fuel assembly design, and the 15 evaluation results of poolside examination, hot cells 16 examination, and the commercial operating experience.
17 Consideration of the thermal conductivity 18 degradation is included, and evaluation results show 19 the performance integrity of PLUS7.
20 Large break LOCA coolant extends to 21 topical report to describe a realistic evaluation 22 methodology, CAREM for the analysis of LBO APR1400.
23 CAREM follows NUREG/CR-5249, CSAU, in the Reg Guide 24 1.20703.
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134 1 result of CAREM for APR1400 shows sufficient safety 2 margin of ECCS performance.
3 This table summarizes the RAI issue and 4 resolve for each chapter. More than 2000 RAIs were 5 issued and resolved.
6 CHAIR CORRADINI: You're way ahead of me, 7 but I wanted to ask, the RAI issues will be resolved 8 by revisions to DCD Rev. 3, is that correct?
9 MR. KIM: All confirmatory items we've 10 included in Rev. 3.
11 CHAIR CORRADINI: Okay, thank you.
12 MR. KIM: Finally, I will summarize this 13 presentation. APR1400 DCD is completed, all AIAs have 14 been resolved with adequate and sufficient discretion.
15 Confirmatory items have been incorporated into DCD 16 Rev. 3.
17 And with this opportunity, I would like to 18 express out team's deep gratitude to all of NRC staff 19 and ACRS Members for the excellent review, discussion, 20 and feedback for APR1400 DCD.
21 All those efforts result in the enhanced 22 design and made it possible to complete the review 23 process with in the schedule of 42 months.
24 Thank you again.
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135 1 of being in denial, we're ahead of schedule. We 2 probably should just pick it up with the staff now.
3 So, are you guys ready to roll?
4 MR. WARD: Yes, we are. Good afternoon, 5 my name is Bill Ward, I'm the Lead Project Manager for 6 the APR1400 review for NRC and I'm going to start our 7 presentation today with an overview. You can go to 8 the next slide.
9 First of all, I want to say again thank 10 you for all the meetings and all the help and the 11 logistics and everything that we've had to organize 12 over the last 27 months.
13 As you know, there have been two rounds of 14 ACRS meetings, Phase 3 and then Phase 5, and of 15 course, EFROWN had Subcommittee and then full 16 Committee. The Subcommittees were monthly and then we 17 grouped them in the full Committee meetings.
18 We've maintained an aggressive schedule 19 over the last four years at this point, almost four 20 years, three and a half, in order to meet the 21 milestones we have for our review.
22 Part of that was because of the effort 23 required to issue revisions and DCDs, we were trying 24 to avoid having multiple rounds of DCD revisions.
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136 1 was going to issue Rev. 2 at the end of year last 2 year, we were talking about how we were going to 3 organize the last revision and make sure we presented 4 everything to ACRS, and then in terms of being able to 5 do the review and then finish the final SER and still 6 meet our schedule.
7 So, we let the deadline for Rev. 2 slide 8 a little bit to get everything we could into Rev. 2.
9 Rev. 2 was issued in March and now Rev. 3 is the one 10 coming up.
11 So, since we issued Rev. 2, we've been 12 focusing on controlling any changes and making sure we 13 know exactly what changes there are coming and that we 14 document on them.
15 So, we've been trying to make sure we are 16 aware of that and we provided feedback to the 17 Committee so you knew what changes were coming in for 18 any RAI responses that came in after the 19 representative Subcommittee.
20 So, going to my slide on ACRS review, 21 we've had 31 meetings in 27 months.
22 CHAIR CORRADINI: I thought you were going 23 to hand off with something.
24 MR. WARD: I'm going to lead onto it in a 25 second, I'm sorry.
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137 1 CHAIR CORRADINI: You're way ahead of me.
2 MR. WARD: I'm leading into it.
3 CHAIR CORRADINI: Okay, fine. Sorry, 4 excuse me.
5 MR. WARD: So we've had 31 meetings and I 6 just wanted to say the RAI count in our case would be 7 at 2201 for the DCD and the 24 for the environmental 8 report.
9 We also had 69 RAI questions on topical 10 report and way back in pre-application space, we had 11 21 RAI questions on the quality assurance program.
12 So, as I was saying, we began providing 13 information on changes that were coming ever since we 14 started planning Phase 5 Subcommittee meetings. So 15 the first Subcommittee meeting was in October so we 16 submitted are ASER in September.
17 So ever since September, we've had to make 18 sure that we kept you up to date on anything that came 19 through.
20 So we went through and we verified any of 21 the RAI responses that came through, and most of the 22 responses are just corrections of typographic errors 23 and things like that. But we wanted to make sure we 24 kept you informed so we've been providing you that 25 update.
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138 1 We reviewed all the responses since then 2 and made sure that there was nothing significant in 3 them. We kept you up to date, as I said, and there's 4 a total of 52 revised responses that have been 5 received since the Subcommittee for each chapter. So, 6 for example, the last Subcommittee we had was for 7 Chapters 6, 13, and 14.3.
8 And actually, there were some responses 9 that came in after the SC but before we presented them 10 in the Subcommittee meetings so we were able to 11 address them directly in the meeting.
12 So, in general, we've tried to make sure 13 that everything is out there that's coming. And now 14 that we've reached this point, there are no more 15 changes that are going to occur. I'm tracking 16 everything.
17 Of those revised responses and some 18 earlier revised responses that came in, we have a 19 total of 50 questions that are confirmatory actions.
20 And we're waiting for Rev. 3 of the DCD to come in to 21 make sure they're in there.
22 We've seen the revised response, we know 23 exactly what is coming in, and when it comes in, we're 24 going to verify that it's what we thought was going to 25 be there. If it's different then that's an issue.
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139 1 And we'll be able to finalize the FSER.
2 We're already writing the FSER under the 3 assumption that we will have exactly what is promised 4 in the responses.
5 At the same time, we've also been talking 6 with KHMP and they have an electronic reading room so 7 as they put their Rev. 3 version together, they're 8 going to make it available for us to see that so we 9 can have confidence in it. And then when they issue 10 Rev. 3, we'll verify that it's exactly what we 11 thought.
12 So, we're taking all the steps we can to 13 make sure that there are no more changes at this point 14 and anything else that really needed to be considered 15 would have to be postponed until after we get through 16 this process and through the final safety evaluation.
17 And there is a process for that, NRC has 18 something called interim staff guidance, Number 11, 19 which is where you get to a certain point where you 20 have to cut off any changes and they get postponed and 21 put off to a parking lot until later when they deal 22 with them.
23 So, we're at the point now where this is 24 the design that's being approved and what we are 25 seeing as we're going to Rev. 3 is what will be the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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140 1 record design for your approval.
2 MEMBER SUNSERI: Hey, Bill, just a quick 3 question. I understand what you're doing with the 50 4 or so confirmatory items. Do you do any checking of 5 the rest of the Rev. 3 to make sure nothing else 6 changed besides those 50?
7 MR. WARD: We spot check it. We're going 8 to do a sensory review and we're going to spot check 9 it. But because the total DCD is between 11,000 and 10 12,000 pages, it's really hard for us to check every 11 single thing.
12 MEMBER SUNSERI: I just wondering how the 13 configuration, if you will, is maintained at the base 14 document.
15 MR. WARD: One of the things I think, I 16 can't necessarily speak for everybody but I tell 17 people what you do is you pull up the previous Rev.
18 and you pull up the current Rev..
19 Where there's a change bar, you can look 20 and see if the pages are looking the same. And if 21 there's a radical difference, there should be a change 22 bar and then we can go in and figure out what the 23 change is about.
24 And one of the things KHNP has done is 25 provide tables that show us why the changes occurred.
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141 1 They aren't necessarily marked in the DCD, it's just 2 a change bar, but there are RAI tracking reports and 3 there's a change list that if you know how to go 4 through and read them, you can figure out why each 5 change was made and trace it back to the individual 6 RAIs.
7 So even if you weren't involved in the 8 review, eventually, you could figure out exactly why 9 that change was made in each revision.
10 MEMBER BALLINGER: But just for the 11 record, any letter that we would write would be on 12 Revision 2 with confirmatory items. We have not seen 13 Revision 3 so we can't write a letter on Revision 3.
14 CHAIR CORRADINI: That's where I thought 15 you were going.
16 MR. WARD: That's what I wanted to verify 17 because what appears in Rev. 3 should be just Rev. 2 18 with the confirmatory items.
19 MEMBER BALLINGER: The operative word is 20 should be.
21 MEMBER REMPE: Before you go on, today we 22 got an email about Subpart E versus Subpart B. So 23 we're doing a standard design approval here, not a 24 standard design certification, correct?
25 MR. WARD: It's both. I have that in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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142 1 final slide but, yes, initially when KHNP applied, the 2 initial application, Rev. 0 of the DCD, they asked for 3 a standard design certification in Subpart B.
4 A few months ago, they began discussing 5 coming in for a standard design approval and when they 6 submitted Revision 2 in March, they included in the 7 submission the request for what they call the final 8 design approval.
9 And it's a little bit of I don't want to 10 say semantics, but we originally had regulations that 11 called it a final design approval. And that was 12 changed in 2007 and so now it's called a standard 13 design approval, so that's what they want.
14 The idea is that when we issue the FSER, 15 we'll be able to issue a standard design approval.
16 But when you look through Subpart E and I get a 17 comparison of what's required for the technical 18 information between Subpart D and Subpart E, they're 19 essentially the same.
20 There's a couple minor differences but we 21 felt like they provided everything you're supposed to 22 provide for either subpart. And both subparts have a 23 statement regulation in there that there needs to be 24 review for safety issues by the ACRS.
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143 1 state it in the last slide, is that we're asking for 2 the letter to state that's been performed for both 3 Subpart B and Subpart E.
4 MEMBER REMPE: So for my education and on 5 the record, has anyone ever done this standard design 6 approval?
7 MR. WARD: Yes.
8 MEMBER REMPE: I know you changed the word 9 and maybe it was a final design approval. Who else --
10 MR. WARD: Most recently, the ESBWR design 11 did it. When they applied, they asked for final 12 design approval, but by the time it was issued it was 13 after 2007.
14 But the letter that went out did call it 15 a final design approval.
16 MEMBER REMPE: Not in the standard design 17 certification. So is the AP1000 the only --
18 MR. WARD: No, ESBWR, the General 19 Electric.
20 MEMBER REMPE: How many certified designs 21 do we have in the U.S. if the ESBWR is only a standard 22 design?
23 MR. WARD: It's also certified.
24 MEMBER REMPE: It's both, okay.
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144 1 designs, three of which expired.
2 MEMBER BLEY: And a rule is issued whether 3 it's design approval or design certification.
4 MR. WARD: The design certification goes 5 to rule-making so that doesn't happen until we go 6 through the rule-making process.
7 And we're going through a direct final 8 rule because we feel like this is based on existing 9 plants and it's been operating in Korea so we're 10 thinking it's going to be few, if any, adverse 11 comments.
12 MEMBER BLEY: But the appendix to the rule 13 will be for the design certification?
14 MR. WARD: That's correct.
15 This is just an approval which a COL 16 Applicant could reference but then it puts a lot of 17 the burden on the COL Applicant to follow through on 18 certain things, which if they reference the design 19 cert, certain steps are taken.
20 MEMBER REMPE: Say that more clearly. I 21 thought you were not going to go through a rule but 22 you said, oh, we're going to go through a rule on this 23 too?
24 MR. WARD: We're going through a rule, 25 yes.
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145 1 MEMBER REMPE: Okay, I guess I 2 misunderstood the formal discussion.
3 MR. WARD: We're asking for both, both for 4 the Subpart B, which eventually will go to rule-making 5 and the rule-making process officially for us began at 6 the beginning July and we're asking for a direct final 7 rule where we don't go through two steps.
8 We think we can do it in one step, and 9 we're hoping to complete the rule in May.
10 MEMBER BALLINGER: May?
11 MR. WARD: 2019. The standard design 12 approval, once we issue the final safety evaluation, 13 we would be able to send the letter saying that they 14 had the standard design approval.
15 But like I said, the difference between 16 the two, we tend to issue both, the difference between 17 the two is the amount of work that the COL would have 18 to do with referencing it.
19 MEMBER REMPE: A little off topic, has 20 anyone just done a standard design approval and not 21 gone for the certified design?
22 MR. WARD: Not that I'm aware of.
23 MEMBER REMPE: Thank you.
24 MR. WARD: So, we are going to present 25 each chapter, we have a slide per chapter. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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146 1 chapter PMs are going to present each slide as their 2 chapter. We have one chapter PM who's not here today 3 and Mark is going to cover her slide.
4 But we have a roomful of experts from the 5 tech staff here to help answer any questions or come 6 up. So, I'm going to turn it over now. Well, Chapter 7 1 is mine.
8 Chapter 1, it's the design, the APR1400 9 design, the objectives, the information regarding how 10 the DCD was developed and structured in comparison 11 with other facilities.
12 There's some charts in there similar to 13 what KHNP just provided. Later sections provide lists 14 and tables of reference material and other items.
15 All of these are for the purpose of being 16 referenced by the other 18 chapters. There are no 17 specific design commitments in Chapter 1, everything 18 is referenced from other chapters.
19 So there was no specific review done, 20 safety review done, on Chapter 1 and there are no 21 confirmatory items, we didn't ask any RAIs.
22 There are a couple of COL items but 23 they're very high-level. They state for example that 24 a COL would have to name who their architect and 25 engineering firm is that's going to build it and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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147 1 things like that.
2 And that's not really design-related so 3 there's nothing there to review.
4 So the conclusion, the Applicant provided 5 adequate general description of the design objectives 6 in DCD construction and they provided accurate 7 information in the list and tables as confirmed by the 8 evaluations of the individual chapters.
9 So any questions on Chapter 1? Chapter 2 10 is going to be Mark presenting for Carolyn.
11 MR. LINTZ: Chapter 2 covers site 12 characteristics. The scope of review included site-13 related design characteristics for the APR1400 design, 14 including geography, demography, nearby facilities, 15 meteorology, hydraulic engineering, geology, 16 seismology, and geotechnical engineering.
17 The postulated site parameters related to 18 climatology, atmospheric dispersion, ground and 19 surface water, precipitation, geology, seismology, and 20 geotechnical engineering. There are two minor 21 confirmatory items that remain pending submission of 22 DCD Rev. 3.
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148 1 referencing the APR1400 design can meet the relevant 2 requirements.
3 And Applicants seeking a combined license 4 must address the site-specific information.
5 MR. WARD: Any questions on Chapter 2?
6 MR. LINTZ: Chapter 3, design of 7 structures, systems, components, and equipment.
8 The scope includes classification of 9 structures, systems, and components, wind and tornado 10 loadings, water level design, missile protection, 11 protection against dynamic effects associated with 12 postulated rupture of piping, seismic design, design 13 of Category 1 structures, mechanical systems and 14 components, seismic, dynamic, and environmental 15 qualification of mechanical and electrical equipment, 16 piping design review, and threaded fasteners.
17 The Applicant applied a new approach to 18 defying the ITAAC for the critical sections. That 19 would be the steel and reinforced concrete for the 20 design of the safety-related structures, the reactor 21 building and auxiliary building, and the EDG building.
22 There are nine confirmatory items that 23 remain pending submission of the DCD Rev. 3. In 24 conclusion, the Applicant has demonstrated that 25 structures, systems, and components and equipment NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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149 1 comply with NRC regulations and conform to NRC 2 guidance.
3 MEMBER BLEY: Mark, I have a question. We 4 had some internal conversations about it. We have a 5 large set of ITAAC and we have a fairly large set of 6 confirmatory items.
7 I'm pretty familiar with the requirements 8 on the licensee to clear the ITAAC items. How does 9 that compare with what they have to do to clear a 10 confirmatory item?
11 MR. LINTZ: Will you clarify that?
12 MEMBER BLEY: No, I'm expecting somebody 13 over here to clarify that for me.
14 MR. HUGHES: Is the question not for the 15 Applicant but for KHNP for the confirmatory --
16 MEMBER BLEY: No, KHNP has to clear the 17 confirmatory items. At what point in time does that 18 happen?
19 MR. LINTZ: It can happen today, there 20 could be an email in my --
21 MEMBER BLEY: But when does it have to 22 happen?
23 MR. LINTZ: It has to happen by the time 24 we get Rev. 3.
25 MEMBER BLEY: So before the rule, before NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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150 1 we get to the rule?
2 MR. WARD: Yes.
3 MEMBER BLEY: So all the confirmatory 4 items have to be met by the Applicant before you can 5 complete the rule?
6 MR. WARD: A confirmatory item, when we 7 ask an RAI and they provide a response, we always ask 8 for projects to provide a markup of the DCD or the 9 technical report showing where they're going to make 10 the changes so we know exactly what changes. Because 11 sometimes the wording is very critical.
12 MEMBER BLEY: So all of these should be 13 answered in Rev. 3?
14 MR. WARD: They're already in the revised 15 response or RAI response, or sometimes they revise it 16 if we find an error in the response. But we've 17 already gotten a response that says this is what the 18 revised document is going to look like.
19 So all we're waiting for to close the 20 confirmatory item is to see that revised document 21 actually issued. So it's really up to the staff to 22 close a confirmatory item.
23 The Applicant has already provided us the 24 proposed change, now we just need to see the revised 25 document and we close the confirmatory item.
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151 1 MEMBER BLEY: I haven't followed 2 everything during this process, I wasn't really on the 3 Subcommittee. But most of the ITAAC are aimed at 4 things that you clear towards the end of construction.
5 MR. WARD: Correct.
6 MEMBER BLEY: That's generally right.
7 MR. LINTZ: Or doing construction.
8 MEMBER BLEY: Along the way, they can't 9 really be clear until they start building the plant.
10 That's what I thought.
11 MR. LINTZ: You said there's a large 12 number of ITAACs and that might look like it, but as 13 Bill intimated, most of these, in fact, all of these, 14 have been agreed upon and the only thing we're waiting 15 for is to see Rev. 3 with all these in it.
16 MEMBER BLEY: I've been thinking about 17 those a little and thinking back to Part 50, where you 18 had startup requirements which are kind of like ITAAC.
19 And I don't really have a feel or a memory 20 that helps me -- for the most part, there ought to be 21 a wash between what you'd have for startup items under 22 Part 50 and what you have as ITAAC here, I would 23 think, but I don't know that.
24 MR. HUGHES: The difference with the ITAAC 25 is the paperwork has to be submitted as a package and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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152 1 it gets reviewed by the staff.
2 MEMBER BLEY: For the startup tests and 3 that sort of thing, they just do them?
4 (Simultaneous speaking.)
5 MR. HUGHES: -- basically did, and then 6 they had an internal Test Review Board that would 7 review it.
8 MEMBER BLEY: And staff could audit it?
9 MR. HUGHES: And staff would audit it.
10 MEMBER BLEY: Okay.
11 MR. WARD: And the timing is very 12 different. All the ITAAC are going to be done before 13 we approve fuel loading, and some of the startup 14 tests, a lot of those are in 14.2.
15 MEMBER BLEY: Those we still have?
16 MR. WARD: Yes, and we still have 14.2.
17 MEMBER REMPE: So in this application, 18 though, there's something, at least the moment --
19 because I was more focused on Chapter 19, it's a bit 20 different in that the COL Applicant will select an 21 option whether they go for in-vessel retention to 22 external reactor vessel cooling or not, which is a 23 little bit different than just an ITAAC that you put 24 a valve in at a certain place or whatever. And that's 25 a bit different.
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153 1 And are there other things that maybe I 2 missed because I wasn't so focused on the COL items, 3 which are a bit different with this application at a 4 high level?
5 MR. HUGHES: Are you talking about the 6 ITAAC itself?
7 MEMBER REMPE: No, this is not an ITAAC, 8 it's a COL item, which is a little different than an 9 ITAAC, right?
10 MR. WARD: Correct.
11 MEMBER REMPE: And I was just wondering 12 are there other COL items that are a little different 13 with this application?
14 MR. WARD: Offhand I don't know of any.
15 MEMBER MARCH-LEUBA: Going back to the 16 ITAAC issue, I'm just talking off the top of my head, 17 but there were 2000, roughly, RAIs and now that you 18 just finished with them, you know how much work it 19 took to resolve all those.
20 There are 1200 items. I'm wondering if 21 it's too many. The amount of paperwork that the COL 22 would have to produce and the amount of work on this 23 building to get them reviewed, it's not insignificant.
24 MR. HUGHES: We would not do 100 percent 25 review, we would do a sampling review.
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154 1 MEMBER MARCH-LEUBA: The number I've seen 2 in my reviews previously is roughly 40 percent of 3 them, about half. It's still a large number.
4 MEMBER BLEY: We haven't been through the 5 process yet at any plant and Region II runs that kind 6 of inspection.
7 MR. HUGHES: They would be assisted by --
8 MEMBER MARCH-LEUBA: We did this at Vogtle 9 and I remember the licensing manager complaining, 10 saying, I still have 200 ITAACs to go through. They 11 take a week a piece, we'll never get this plan 12 constructed. That's what he said.
13 MS. BRADFORD: Can I make one comment? My 14 name is Anna Bradford, I'm the Deputy Division 15 Director in the Division of Licensing, Site Safety and 16 Environmental Analysis, and the Office of New 17 Reactors.
18 I just want to make clear that the COL 19 items, the ITAAC, the confirmatory items, this is all 20 the same process and approach we've used for previous 21 design certifications and review. So I just don't 22 want to get too off track.
23 I'm hoping that no one thinks that this is 24 something new and unusual or this is just for KHNP.
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155 1 to the way that we've done that. I just want to make 2 that clear.
3 Thank you.
4 CHAIR CORRADINI: I just think some of the 5 Members weren't around when we had the joy of AP1000 6 and ESBWR. So that's part of it but I also think the 7 sheer number sometimes gives people surprise.
8 MEMBER MARCH-LEUBA: As a lesson learned, 9 I would hate if we pushed something to an ITAAC 10 because we don't want to make a decision now. It's 11 not something you can make a decision now what the 12 limit is. You say, well, we'll look at it later.
13 I have one practical example which is the 14 main steam isolation valves, the last one we saw.
15 MR. HUGHES: This is Brian Hughes.
16 If I may, the ITAAC is very similar to the 17 startup tests so you would not do an ITAAC until the 18 equipment is installed, it's ready to go, and you have 19 to test that equipment or that structural member.
20 So, the only thing is the paperwork, which 21 they choose to do on Part 52, seems to be a little 22 more than actual startup but that is the process on 23 Part 52, the rule. So that's what we're required to 24 do if they do a Part 52 application.
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156 1 anything about the APR1400 for KHNP. If this is the 2 way they decide to do it, good for them.
3 MR. WARD: I'd like to add that we are 4 applying lessons learned. It may be somewhat 5 transparent in the way we present it to ACRS but there 6 are steps we've taken as we've gone through. There 7 were several rounds of the ITAAC review, including one 8 that took about a year.
9 We went through with the Division of 10 Construction and Instruction Programs and with the 11 Office of the General Counsel to make sure the wording 12 was clear legally, et cetera, and also for inspectors 13 to be able to make sure that they could actually 14 inspect what was being written.
15 There was a lot of times where an ITAAC 16 might make a statement that an inspector looks at and 17 says, well, how am I supposed to verify that? So, 18 there have been several rounds in the process to make 19 sure those were corrected to the best that we could.
20 And then most recently, right in the last 21 few months, we had one in particular in Chapter 3 22 which we're talking about now. So, in terms of 23 construction dimensions and things like that, which 24 was a big problem for the Vogtle construction, there 25 was a lot of back and forth and discussing how to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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157 1 that.
2 And eventually, the staff came up with a 3 new approach versus using actual physical dimensions 4 like length, and came up with ratios for load versus 5 load capacity.
6 And that was all applied in the ITAAC and 7 that was a new approach. The Applicant liked it and 8 I think the industry is pleased that we took that 9 approach, and we're looking to see how it works out.
10 MEMBER MARCH-LEUBA: I'm glad you thought 11 of that. I'm just concerned that we are building this 12 plant and this building will be overwhelmed with 13 paperwork.
14 MR. WARD: So, there's an interest on both 15 sides, the industry and the NRC, to improve as we go 16 along.
17 MEMBER MARCH-LEUBA: I would like to 18 minimize the number.
19 MEMBER REMPE: I had the same thought 20 originally and so I asked how many were there for 21 AP1000 and ESBWR? And AP1000 had like 800.
22 You can correct me because I just looked 23 on the Internet, and I had 815 and this says 1202.
24 But ESBWR had 1614 so they actually doubled what 25 AP1000 had.
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158 1 CHAIR CORRADINI: Not all ITAACs are 2 equal.
3 MEMBER REMPE: I guess, I don't know. You 4 can say this one's kind of --
5 MR. WARD: And a final statement, NEI and 6 the industry have come up with some standard ITAACs, 7 but they came out kind of late for this review.
8 And we presented them to KHNP and we 9 discussed it, but it looked like it might cause a 10 delay in the schedule and we wanted to maintain that.
11 So, KHNP made the decision to stay with the ITAACs 12 that were proposed and we worked with those.
13 MEMBER REMPE: But there was a schedule 14 pressure that offset that you might have been able to 15 --
16 MR. WARD: Shifting over to a whole new 17 approach on the ITAAC and not knowing exactly where 18 that would lead, they made the decision to stick with 19 what they had.
20 MEMBER REMPE: That's a good decision, 21 thank you.
22 MR. WARD: So, Chapter 4?
23 MR. WUNDER: Thank you. Good afternoon, 24 Mr. Chairman, ladies and gentlemen of the Committee.
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159 1 Chapter 4, Reactor, as well as a few other chapters of 2 the APR1400 DCD review.
3 The staff review of the application 4 covered the areas of fuel system design, nuclear 5 design, thermal and hydraulic design, reactor 6 materials, and the functional design of the reactivity 7 control system.
8 As of today, there is a confirmatory item 9 to be resolved when we receive Revision 3 to the DCD.
10 We have received all necessary markups to give us 11 confidence that this item will be resolved on receipt 12 of the next revision.
13 The Applicant has provided sufficient 14 information to allow the staff to conclude the proper 15 methodologies were used, proper codes and standards 16 apply, and applicable design and other regulatory 17 criteria were met.
18 The staff has concluded that the Applicant 19 has allowed for proper testing and inspection. The 20 staff has also performed its own confirmatory analysis 21 with its first cycle core design. Any questions?
22 Thank you.
23 MEMBER BALLINGER: I probably should 24 interject here. Each one of these chapters, there's 25 a statement about Revision 2 to Revision 3 and what's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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160 1 happening. The rest of the Committee should know that 2 Matt and I, and other Members of the Subcommittee, 3 didn't trust but verify.
4 The staff constructed an Excel spreadsheet 5 with every item on it with a ranking of whether it was 6 minor, less than minor, important and everything, and 7 we went through that and we have been going through 8 that so that we made sure that there were no real 9 showstoppers between Revision 2 and Revision 3 that we 10 would be tripped up on.
11 MR. HUGHES: Chairman, Members, my name is 12 Brian Hughes, I'm going to present Chapter 5, Reactor 13 Coolant System and Connecting Systems. The scope of 14 the review included thermal and hydraulic design 15 review, reactor materials review, code requirements.
16 We have two minor confirmatory items that 17 remain, pending submission of DCD Rev. 3. The 18 conclusions were that the Applicant provided an 19 adequate description of all aspects of the reactor 20 cooling system, its connecting systems, thereby 21 allowing the staff to conclude that proper 22 methodologies were used, the proper codes were 23 applied, all appropriate design criteria and other 24 applicable regulatory criteria were met, and the staff 25 concluded that the Applicant has allowed for proper NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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161 1 testing and inspection.
2 Let's move on to Chapter 6. Chapter 6 is 3 Engineered Safety Features. In Chapter 6 the scope of 4 design was thermal and hydraulic design, material 5 qualifications, heat removal adequacy, code and QA 6 requirements, and containment functional design.
7 For confirmatory items, we have seven 8 confirmatory items that remain pending submission of 9 the DCD Revision 3.
10 The conclusion of the staff is that the 11 Applicant provided an adequate description of all 12 aspects of the engineered safety features, thereby 13 allowing the staff to conclude that proper 14 methodologies were used, that proper codes were 15 applied, and that all appropriate design criteria and 16 other applicable regulatory criteria were met. The 17 staff concluded that the Applicant has allowed for 18 proper testing and inspection. Questions?
19 MR. LINTZ: Mark Lintz, Chapter 7, 20 Instrumentation and Controls.
21 The scope includes safety-related and non-22 safety-related I&C systems, data communication 23 systems, quality and qualification, integrity, 24 reliability, diversity, defense and depth and single 25 failure criteria.
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162 1 There are four confirmatory items that 2 remain pending submission of the DCD Rev. 3.
3 Conclusion, the Applicant has demonstrated that the 4 I&C systems and the overall I&C architecture meet the 5 fundamental safety design principles of independence, 6 diversity, defense and depth, determinism, and 7 redundancy.
8 The Applicant has provided sufficient 9 information to demonstrate isolation of I&C systems 10 from external interfaces. The staff concludes that 11 the I&C design complies with NRC regulations and 12 conforms to NRC guidance.
13 Any questions?
14 MR. HUGHES: Okay, Chapter 8. Chapter 8 15 discusses the electric power system. The staff's 16 review covered the offsite power system, onsite AC and 17 DC power systems, and station blackout.
18 There are, I believe, three open items 19 that need to be resolved with the next revision of the 20 DCD. The staff has markups of the relevant material 21 and is confident that these items will be resolved 22 upon receipt of the revision.
23 MEMBER BLEY: Can you add a little detail 24 to that? From what you've seen, I take it you would 25 consider them resolved, you just need to see them NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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163 1 documented?
2 MR. HUGHES: Right, actually what we've 3 got is a markup of the DCD page and they say this is 4 what the DCD page will look like --
5 MEMBER BLEY: That you find acceptable if, 6 in fact, acceptable --
7 MR. HUGHES: Find acceptable and all we 8 have to do is sign.
9 MEMBER BLEY: That's what I said. But it 10 didn't sound that way.
11 MR. HUGHES: Sorry if I wasn't clear. The 12 staff has concluded that the offsite and onsite 13 electrical systems comply with all applicable design 14 criteria and standards and that the Applicant provided 15 sufficient information and identified necessary 16 analysis to support a future COL application.
17 The staff further concluded that the 18 APR1400 design is capable with standing and recovering 19 from a station blackout of the stated coping period.
20 Okay, Chapter 9 covers the auxiliary 21 systems. We reviewed the fuel handling and storage 22 system, water systems, process of auxiliaries, HVAC, 23 and other systems.
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164 1 concluded that all auxiliary systems comply with the 2 applicable design and other regulatory criteria, and 3 that the Applicant has allowed for adequate pre-4 operational testing.
5 The staff has concluded that the Applicant 6 has provided sufficient information and identified 7 necessary analysis to support a future COL 8 application.
9 And as long as I'm on a roll, I'll do 10 Chapter 10, Steam and Power Conversion System. The 11 staff has reviewed the turbine generator, main steam 12 system, condensate and feed and associated systems, 13 and the auxiliary feed and steam systems.
14 All confirmatory actions were addressed in 15 the second revision to the DCD. The staff has 16 concluded that the steam and power conversion systems 17 comply with the applicable design and other regulatory 18 criteria.
19 The staff has concluded that the Applicant 20 has provided sufficient information to support a 21 future COL application.
22 MR. WARD: And for Chapter 11, I'll turn 23 it over to whoever's doing it.
24 MR. LINTZ: Mark Lintz again, Chapter 11, 25 Radioactive Waste Management.
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165 1 The scope includes liquid waste management 2 systems, the gaseous waste management system, solid 3 waste management system, and the process in the 4 effluent radiological monitoring and sampling system, 5 including the instrumentation used to monitor and 6 control releases of radioactive effluents and waste.
7 All confirmatory items were closed with DCD Revision 8 2.
9 In conclusion, the Applicant has 10 demonstrated that the systems comply with NRC 11 regulations and conform with NRC guidance to avoid 12 unmonitored and uncontrolled radioactive releases to 13 the environment. Are there any questions on Chapter 14 11?
15 Chapter 12, Radioactive Protection. The 16 scope includes information on facility and equipment 17 design and programs used to meet the radiation 18 protection standards in 10 CFR Parts 20, 50, 70.
19 There's one confirmatory item that remains pending 20 submission of the DCD Revision 3.
21 In conclusion, the Applicant has 22 demonstrated that the APR1400 design includes adequate 23 design features to maintain the radiation does 24 resulting from exposure to radioactive sources to 25 within the limits required by 10 CFR 120 and as low as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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166 1 is reasonably achievable if operated with an 2 appropriate radiation protection program.
3 An Applicant seeking a combined license 4 must address the radiation protection program as well 5 as other identified radiation protection information 6 items.
7 Are there any questions on Chapter 12?
8 Chapter 13 is Conduct of Operations, 9 Chapter 13 describes a required organizational 10 structure, programs, and procedures required of a COL 11 to safely operate the plant.
12 There were 33 COL information items in the 13 five areas of concern for ACRS safety review, 14 including organizational structure training, emergency 15 planning, operational programs, and plant procedures.
16 Six areas of physical security had no 17 COLs, seventh area, fitness for duty, had one but we 18 do not present those to ACRS. There are two minor 19 confirmatory items remaining pending submission of DCD 20 Revision 3.
21 We concluded that the Applicant provided 22 adequate guidance and information including 23 establishing the training programs in accordance with 24 NEI0613A, emergency planning facility design 25 requirements, operational programs developed in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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167 1 accordance with SECY-05-0197.
2 The GTGs and EDGs, there is an acronym 3 list at the back, those are guidelines used to develop 4 site-specific procedures that are prepared by KHNP, 5 which, when implemented by a COL, provides adequate 6 assurance the COL will operate the plant safely.
7 Any questions on Chapter 13?
8 MR. SANTOS: Good afternoon, my name is 9 Cayetano Santos, I'm the Chapter 14 Project Manager.
10 Chapter 14 is verification programs and there's two 11 major parts of it in the scope.
12 One is the initial test program which 13 includes pre-operational tests, initial fuel loading, 14 initial criticality tests, low-power tests and power 15 ascension tests. These are sections 14.1 and 14.2 of 16 the SER.
17 There are currently no confirmatory items 18 pending for these two sections so DCD Rev. 2 should be 19 the latest and greatest. Regarding the ITP, the 20 staff's conclusion is that the Applicant has fully 21 addressed all the information related to this and has 22 demonstrated compliance with the applicable 23 regulations.
24 The second aspect of the verification 25 programs, as was described earlier, ITAAC and other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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168 1 Tier 1 information including definition of terms, 2 general provisions for the design descriptions. This 3 is discussed in Section 14.3 or the SER.
4 There are two confirmatory items in this 5 section that are pending DCD Rev. 3 and the staff's 6 conclusions regarding ITAAC are that it basically 7 meets the 5247B1 finding, that the ITAAC are necessary 8 and sufficient to provide reasonable assurance that if 9 the ITAAC are met, the facility that incorporates the 10 design has been designed and will be operated in 11 conformity with the NRC's regulations.
12 Any discussion, more about ITAAC?
13 MR. LINTZ: Chapter 15, Transient and 14 Accident Analyses.
15 The scope includes analyses of the APR1400 16 responses to postulated equipment failures or 17 malfunctions to determine the limiting conditions for 18 operation, limiting safety system settings, and design 19 specifications for safety-related structures, systems, 20 and components, the design basis accident 21 radiological consequence analysis.
22 All confirmatory items were closed with 23 DCDRevision2.
24 In conclusion, the Applicant has 25 demonstrated in its analysis of the APR1400 nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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169 1 steam supply system to anticipated operational 2 occurrences and postulated accidents and in its 3 analyses of the radiological consequences of design 4 besides accidents, that the APR1400 design complies 5 with NRC regulations and conforms with NRC guidance.
6 MR. HUGHES: Questions? We'll move on to 7 Chapter 16.
8 The scope of review -- the analysis of the 9 APR1400 defined terms limiting conditions for 10 operations, limiting safety system settings, and 11 design specifications for safety-related structures, 12 systems, and components, a review of the reactor trip 13 and the Engineering Safety Features Actuation System 14 known as ESFAS, setpoint, and service methodologies.
15 The status of the confirmatory items, all 16 confirmatory items are closed with DCD Revision 2.
17 The conclusion of the staff is that Applicant has 18 provided the APR1400 technical specifications that 19 comply with applicable regulations and conform with 20 the NRC guidance.
21 Questions?
22 Chapter 17, Quality Assurance and 23 Reliability Assurance. The scope included quality 24 assurance, including a quality assurance program 25 inspection, the maintenance rule, and a reliability NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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170 1 assurance program, including the reliability assurance 2 program list of structures, systems, and components.
3 There is one confirmatory item that remains pending 4 submission of DCD Revision 3.
5 To conclude, the Applicant added 3 COL 6 information items, making the reliability assurance 7 program acceptable to use for use to identify risk-8 significant SSCs.
9 The Applicant has demonstrated that the 10 quality assurance maintenance rule and reliability 11 assurance programs comply with NRC regulations and 12 conform to NRC guidance.
13 Questions?
14 MR. SANTOS: Chapter 18, the scope of this 15 chapter's review was the Human Factors Engineering 16 portion of the APR1400 DCD. This also included 12 17 implementation plans that are documented in technical 18 reports that are incorporated by reference into the 19 DCD as Tier II information.
20 These technical reports described the 21 proposed methods that a COL Applicant would use to 22 develop the APR1400 control room design.
23 There are currently six minor confirmatory 24 items that remain pending submission of DCD Revision 25 3 and Revision 3 of some of these technical reports, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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171 1 these implementation plan technical reports.
2 And the staff's conclusion is that the 3 Applicant's HFE design conforms with the guidance 4 described in NUREG 0711 and therefore provides 5 reasonable assurance that the HFE-related requirements 6 are satisfied.
7 Any questions?
8 MR. LINTZ: Chapter 19, Probabilistic Risk 9 Assessment and Severe Accident Evaluation. The scope 10 includes the probabilistic risk assessment and its 11 uses and the severe accident evaluation.
12 There remains seven confirmatory items 13 pending submission of DCD Revision 3.
14 The Applicant provided PRA revisions to 15 the at-power internal events Level 1 and 2 PRA, the 16 at-power internal fire Level 1 and 2 PRA, the at-power 17 internal flooding Level 1 and 2 PRA, the low-power 18 shutdown internal events, Level 2 PRA, the low-power 19 shutdown internal fire Level 1 and 2 PRA, and the low-20 power shutdown internal flooding Level 1 and 2 PRA.
21 These updates were in response to an RAI 22 and represent significant improvements. The Applicant 23 has demonstrated that the probabilistic risk 24 assessment and severe accident programs comply with 25 NRC regulations and conform to NRC guidance.
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172 1 19.3, Design Basis, Beyond Design Basis 2 External Event. The scope includes conformance of the 3 APR1400 design with SECY 1225, NRC orders EA-12-049 4 and EA-12-51 and the details addressing the 5 recommendations of the Near-Term Taskforce with 6 respect to managing and mitigating external events 7 that are beyond the design basis of the plant.
8 Two confirmatory items remain pending 9 submission of DCD Revision 3. The Applicant has 10 addressed in the APR1400 application the Commission-11 approved Fukushima actions described in SECY 1225 and 12 in NRC orders EA-12-049 and EA-12-51 to the fullest 13 extent practicable.
14 19.4, Loss of Large Area. The scope 15 includes guidance and strategies provided to a COL to 16 address the loss of large areas of the APR1400 plant 17 due to explosions or fires from a beyond design basis 18 event, using readily available resources and 19 identifying potential practicable areas for the use of 20 beyond readily available resources.
21 This is provided to aid the COL in meeting 22 the requirements of 10 CFR 50.54(hh)(2). One 23 confirmatory item remains pending submission of DCD 24 Revision 3.
25 CHAIR CORRADINI: Can you tell me what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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173 1 that one was? Some of these I remember, some I don't.
2 This one, I have no...I know you have a master list.
3 MR. WARD: Did one of the reviews speak to 4 this item?
5 CHAIR CORRADINI: Also, since we have all 6 these people in the audience dying to talk to us, I 7 wanted to go back to the two confirmatory in 19.3 but 8 let's do 19.4 first.
9 MR. WARD: Actually, they're all three 10 related. There was a realization, I guess, on the part 11 of KHNP that there was references to available mobile 12 generators.
13 And KHNP on site will provide a 480 volt 14 generator and it's a gas turbine generator, a GTG.
15 The remote or offsite mobile generators that would be 16 available to support in both of the situations in 19.3 17 and 19.4, KHNP cannot necessarily define what type 18 they're going to be.
19 They had said they were GTGs, now they're 20 just saying the 4.16 kV is a mobile generator, not 21 defining what type it is.
22 So, they've had to make that change in a 23 number of different places so both the confirmatory 24 items in 19.3 and 19.4 are trying to fix that.
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174 1 the wording, but a bit more vague as to what it is 2 that will provide the necessary --
3 MR. WARD: It's going to 4.16 kV mobile 4 generator. I'm not necessarily exactly sure if 5 they're going to be diesel or something else.
6 So there's a number of places, in Chapter 7 8, 19.3 and 19.4, where they're trying to make the 8 same fix.
9 CHAIR CORRADINI: Thank you. I couldn't 10 remember.
11 MR. LINTZ: I think I've concluded 19.4.
12 19.5, Aircraft Impact Assessment. The scope includes 13 features considered in the APR1400 design to minimize 14 or mitigate the impact of a large, commercial 15 aircraft.
16 The APR1400 is designed to maintain the 17 reactor core cooled and the integrity of the spent 18 fuel pool. This section is provided to demonstrate 19 compliance with 10 CFR 50.150(a). All confirmatory 20 items were closed with DCD Revision 2.
21 The application performed a design-22 specific assessment of the effects of the impact of a 23 large commercial aircraft on the APR1400 design.
24 The Applicant used the assessment to 25 identify and to incorporate into the design those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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175 1 design features and functional capabilities to show 2 that with the reduced use of operator actions, the 3 reactor core remains cooled or the containment remains 4 intact, and the spent fuel cooling or spent fuel 5 integrity is maintained.
6 Any questions on Chapter 19?
7 MEMBER DIMITRIJEVIC: Yes, I have a quick 8 question.
9 I'm sort of curious, in some chapters you 10 opted to talk about future COLA application but in the 11 Chapter 19, you didn't mention anything about what are 12 the expectation of the Chapter 19 for the future COLA 13 applications?
14 You know, maybe this application would be 15 reviewed, be required, for example, to complete it, 16 human factors, what update needs to be done and things 17 like that.
18 MR. WARD: Well, there are site-specific 19 aspects to all the chapters that need to be done, 20 including COL Applicant would have to do a site-21 specific PRA addendum to add on to what was provided 22 for the design of the plant.
23 MEMBER BLEY: Especially for the cooling 24 systems and maybe seismic.
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176 1 about I believe ITAAC or something, about decisions 2 that have to be made. And obviously, one of the 3 bigger ones is the ultimate heat sink for a COL.
4 There's no decision made at all.
5 There's interface requirements that are 6 provided by the design, and it's up to the COL to 7 define and design how they're going to provide an 8 ultimate heat sink. And of course, that's going to be 9 a major factor.
10 MEMBER DIMITRIJEVIC: And how about the 11 peer review requirements for the risk-informed 12 applications? You didn't really measure anything on 13 COLA in this summary, COL applications, so I'm sort of 14 curious why did you decide not to?
15 MR. WARD: Hanh or Michelle, you want to 16 add anything?
17 MR. PHAN: Good afternoon, this is Hanh 18 Phan and I'm the Lead Reviewer for APR1400 PRA and 19 Severe Accident Evaluation. When the Applicant 20 submits their PRA, they inform the staff that they 21 have the peer reviews affirmed for their PRA.
22 There are COL information items asking the 23 COLs Applicants to conduct another peer review if they 24 plan to use their PRA for any risk-informed decision 25 method.
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177 1 MEMBER DIMITRIJEVIC: Thank you.
2 MR. PHAN: Thank you.
3 MR. WARD: Any other questions related to 4 19 or any of the chapters at this point? Onto the 5 conclusions and next steps. I went through some of 6 this at the beginning.
7 In the original application, KHNP 8 requested the certification of the APR1400 design 9 under 10 CFR Part 52, Subpart B, which is the design 10 certification, which will include a rulemaking, which 11 has started and we hope to conclude by May of 2019.
12 Earlier this year on March 8th, the 13 Applicant submitted Revision 2 of the DCD and 14 requested a final design approval.
15 As I said, the FTA was superseded by the 16 standard design approval under Subpart E, and that is 17 what the Applicant would like to request, a standard 18 design approval.
19 In both cases, there are requirement for 20 ACRS to do a review of the safety of the design and we 21 are asking that ACRS provide that report to the 22 Commission to meet the requirements there.
23 MEMBER BLEY: Bill? This application came 24 to you in a different way than usual and we don't know 25 if there will ever be a COL here. The SER, or at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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178 1 least the drafts we looked at, are proprietary.
2 Will that be true with the final SER?
3 MR. WARD: No, there are parts of the SER 4 that might be redacted. We've tried to --
5 MEMBER BLEY: Pick out the limited?
6 MR. WARD: It's very limited. That's not 7 necessarily the case sometimes with the topical 8 reports because they tend to provide more information.
9 MEMBER BLEY: So if somebody decides to 10 build one of these not in the United States, it would 11 be a COL, they would still have access to most of the 12 review information as public information here?
13 MR. WARD: If it's publicly available it 14 will be on the website and they would have access to 15 that. But we wouldn't have any oversight on that, we 16 wouldn't be --
17 MEMBER BLEY: I think the drafts we had, 18 everything was marked which I understand.
19 MR. WARD: Our process, actually, when we 20 issue the SEs, when we finish an SE we issue it as 21 proprietary and we ask that the Applicant do a 22 proprietary review and a technical check to make sure 23 we didn't misstate something.
24 And they respond about ten days later and 25 that's the request, and I can send you examples of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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179 1 that.
2 MEMBER BLEY: You don't have to, I was 3 just curious because I've never gone back after the 4 fact to see how that looks. It's never been on my 5 plate.
6 MR. WARD: Many of the SEs come back and 7 they say there's nothing proprietary in them, in which 8 case we go back, we remove the proprietary headings.
9 And some of them come back and there's 10 areas that there's a number that's marked or a 11 sentence that's marked, and we'll either redact that 12 or attempt to rewrite it without providing the 13 proprietary information.
14 MEMBER BLEY: So it's reasonably limited 15 in the final draft?
16 MR. WARD: Yes.
17 MEMBER BLEY: I was curious, it's never 18 come up before but I've never been thinking about 19 building these elsewhere before.
20 MR. WARD: Yes, it's a precautionary step 21 that we take where we provide them initially as 22 proprietary.
23 MEMBER BLEY: Thanks.
24 MEMBER BALLINGER: Yes, I wanted to make 25 sure I'm very clear, the original submittal was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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180 1 Subpart B and then the letter that I thought I saw 2 said that they wanted to shift to Subpart E.
3 MR. WARD: They don't want to shift.
4 MEMBER BALLINGER: So now you're saying 5 they want both?
6 MR. WARD: They want both. So we're 7 asking for the report to confirm that required was 8 done for both, which is Section 52.53 and 52.141.
9 MEMBER BALLINGER: Which are identical 10 statements.
11 MR. WARD: Right, and pretty much most of 12 the requirements in those two subparts are identical.
13 CHAIR CORRADINI: Folks, we have a few 14 minutes. So what's the benefit of that? I don't 15 appreciate this.
16 MR. WARD: I can speculate.
17 MEMBER BLEY: Is that something that was 18 not for these people, but when Part 52 was written, 19 was it written with both A and B in it originally?
20 MR. WARD: It was originally written and 21 I couldn't find an old version but I was doing the 22 research on this and I think there was an Appendix O 23 that talked about some details on the final design 24 approval because I've seen that referenced.
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181 1 was a major re-write of Part 52 in 2007 and it's very 2 extensive if you look at the Federal Register. And 3 one of those rewrites was to shift the FTA through 4 this SDA and put it in the subpart.
5 CHAIR CORRADINI: Say that again, please?
6 MR. WARD: It was to shift some of the 7 requirements from the Appendix into Subpart E. Some 8 of it was already in E because I see references to the 9 same items, regulation numbers, but they were 10 rewritten.
11 The revision was pretty extensive, I don't 12 remember the exact reason why they did that but the 13 difference is really on what the COL would want to do.
14 If they want to be able to take the 15 standard design approval and run with it, they have a 16 lot more work they have to do but maybe that allows 17 them more freedom.
18 On the other hand, if they go with the 19 design cert, a lot of things are already decided for 20 them. But you might want to make changes in case they 21 have exemptions to the rule.
22 So providing both gives an option, and I'm 23 still working with the General Counsel's Office to 24 find out.
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182 1 the design cert, if no COL has chosen to ask for the 2 standard design approval, we will withdraw it and they 3 will only have the certification option.
4 MEMBER BLEY: Say that part again?
5 MR. WARD: I'm working with the general 6 Counsel's Office. It's my understanding, what he 7 understands, is that when the certification is 8 complete, if no COL has asked to use the standard 9 design approval we will withdraw it.
10 (Simultaneous speaking.)
11 MR. WARD: For a certain period of time, 12 but if nobody invokes it --
13 MEMBER BLEY: During that period of time?
14 MR. WARD: Between when we issue it and 15 when we certify the design in May next year that we 16 will withdraw it.
17 MEMBER BLEY: So it's that short of time?
18 MR. WARD: It will just be a 19 certification.
20 MEMBER BLEY: I'm not sure I understand 21 the difference much.
22 MEMBER BALLINGER: But then the standard 23 design approval is moot.
24 MR. WARD: Right, at that point, unless 25 somebody invokes it. They can continue with it, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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183 1 that's what I'm being told now.
2 CHAIR CORRADINI: Okay, I got it.
3 MEMBER BALLINGER: But with the design 4 certification, that other is moot.
5 MR. WARD: The design approval is moot at 6 that point, yes.
7 MEMBER BLEY: Everybody responsible for 8 this is probably gone now.
9 MEMBER BALLINGER: Interesting, thank you.
10 MR. WARD: So it just allows you, if 11 somebody's anxious schedule-wise I guess or for other 12 reasons, they have the option. But that's my 13 understanding and I've been waiting for the General 14 Counsel to confirm.
15 MEMBER BALLINGER: Thank you.
16 MR. WARD: So, in conclusion we are asking 17 that the report reflect both the request for Subpart 18 B and Subpart E.
19 And the next step is assuming that the 20 staff has provided sufficient information and you're 21 able to provide the report that supports both 22 subparts, KHNP will issue Rev. 3 of the DCD and any 23 referenced technical quotes that have also been 24 revised.
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184 1 that it'll be the revision of record but you corrected 2 me saying it's really Revision 2 in the confirmatory 3 actions.
4 So we will verify the revisions are in DCD 5 Revision 3 in the technical reports and we will issue 6 our final safety evaluation by the end of September.
7 Lastly, I just wanted to thank again the 8 Committee, Committee members, the support staff for 9 all the help and support, all the logistics, all the 10 scheduling that went into this, the back and forth of 11 providing information.
12 It's been a pleasure working with you and 13 we all are glad that we were able to do this and hope 14 that you didn't have any problem with what we did. We 15 appreciate your help and your findings.
16 MEMBER BALLINGER: Thank you very much.
17 We have enough time for Chapters 25 through 40 but I 18 couldn't find them anywhere.
19 MEMBER BLEY: Excuse me, Ron.
20 MEMBER BALLINGER: So we probably ought to 21 think about asking the public if there are any --
22 MEMBER BLEY: No, before that, I have a 23 process question for you, Mr. Chairman.
24 I'm remembering back and I don't remember 25 if it was the ESBWR or something after that where we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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185 1 wrote our letter on a situation like this, but when 2 the final DCD came out, it had some substantive 3 changes.
4 CHAIR CORRADINI: It wasn't ESBWR.
5 MEMBER BLEY: And the staff gave us a 6 chance to review that. We looked at it, looked 7 through it, and decided that those changes weren't 8 sufficient.
9 We actually wrote a letter saying we don't 10 need to have anymore meetings or something like that.
11 CHAIR CORRADINI: I don't know if we want 12 to -- your answer is correct but it was for a 13 different reason. It was ESBWR because they modified 14 their steam dryer design.
15 MEMBER BLEY: That was it.
16 CHAIR CORRADINI: So this is not relevant.
17 MEMBER BLEY: But it was a change later?
18 CHAIR CORRADINI: It was a change.
19 MEMBER BLEY: We didn't have further 20 meetings but we wrote a letter say it doesn't change 21 our opinion as I recall.
22 CHAIR CORRADINI: And since you're into 23 process land, when they start writing the rule, we are 24 allowed comment on that if we choose.
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186 1 to write any comments or a letter of report on the 2 rule because for all intents and purposes the rule is 3 this.
4 MEMBER BALLINGER: Now, should we go and 5 ask for comment? Or I'll turn it back over to you if 6 you want to do the asking. I'm in the other room.
7 Are there any comments from anybody in the 8 room? And I don't know whether the phone line is 9 open.
10 CHAIR CORRADINI: Just wait until it 11 crackles.
12 MEMBER BALLINGER: I didn't hear it.
13 CHAIR CORRADINI: Chris will check. We're 14 open. Are there any members of the public that would 15 like to make a comment? Please state your name and 16 make your comment. Five-second rule. Hearing none, 17 back to you, Mr. Chairman.
18 MEMBER BALLINGER: Okay, thank you very 19 much. Let me thank KHNP and their associated 20 consultants for all these wonderful months and years 21 of discussion. I thank the staff.
22 At this point, we're going to go off the 23 record, we'll take a break until 3:35 p.m. -- let's be 24 generous, 3:40 p.m. and then we'll come back on the 25 record and start dealing with our draft letters.
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187 1 So, you're welcome to stay, the fun only 2 begins now. 3:40 p.m. We'll discuss that after we're 3 off the record.
4 (Whereupon, the above-entitled matter went 5 off the record at 3:18 p.m.)
6 7
8 9
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Brunswick Steam Electric Plant Units 1 and 2 MELLLA+
(Maximum Extended Load Line Limit Analysis Plus)
Advisory Committee on Reactor Safeguards Meeting
BSEP Station Overview and MELLLA+ Project Overview Jeff Nolin - BSEP GM Nuclear Engineering 2
Objectives Show Need for MELLLA+
Describe Key Aspects and Answer Questions Demonstrate Readiness Requested Approval supporting 3Q 2018 Implementation 3
BSEP Station Overview General Electric BWR-4, Mark I Containment Began commercial operation in 1975 (Unit 2) and 1976 (Unit 1), OLTP 2436 MWt EPU (120% OLTP) 2923 MWt fully implemented in 2004 (Unit 1) and 2005 (Unit 2) 24 month operating cycle Transitioned to Framatome Fuel in 2008 (U1) and 2009 (U2)
Full Core Framatome ATRIUM 10XM Fuel Licensed for Increased Core Flow (ICF) (110% at reduced power, 104.5% at CLTP 2923 MWt) 4
MELLLA+ Project Overview - Background and Benefits
Background
EPU reduced the licensed flow window at rated power from approximately 24% to 6% Total Core Flow. MELLLA+ will expand the licensed flow window at 100% power from 99-104.5% to 85-104.5% Total Core Flow.
Benefits Fewer reactivity manipulations Reduction in down-powers Increase station capacity factor Lower Reactor Recirculation Pump (RRP) speeds:
increase RRP seal lifetime increase net electric generation due to lower pump power usage 5
MELLLA+ Project Overview - Implementation Progress and Plans Phase 1 (Pre-MELLLA+ Approval) - Plant Modifications and Training Standby Liquid Control (SLC) Boron-10 (B10) enrichment upgrade (Completed in 2016 & 2017)
APRM EPROM modifications (Completed Mid 2016 on both Units)
Plant Operators Introduced to MELLLA+ (2017 Cycle 3 Training)
Operators provided with overview of hardware and procedure changes including revised Power/Flow maps along with simulator exercises on new time critical operator action. (2017 Cycle 6 Training)
Phase 2 (Post MELLLA+ Approval) - Online Updates and Testing Implement new Technical Specifications, Engineering Changes (ECs), Procedures Special Testing in MELLLA+ Domain including Level Control, Pressure Control, APRM / LPRM / TIP /
OPRM data evaluations, Fuel Thermal Margins, and Moisture Carryover Transition to Detect & Suppress Solution - Confirmation Density (DSS-CD) Stability Option from Option III 6
MELLLA+ Design and Analyses John Siphers - GM Nuclear Fuel Design 7
MELLLA+ Design and Analyses The M+ SAR follows the guidelines contained in the generic MELLLA+ Licensing Topical Report (M+LTR), NEDC-33006P-A.
Although the M+LTR is a product of GEH, BSEP utilizes Framatome A10XM fuel. As such, the safety evaluations provided in the M+SAR are the results from both GEH and Framatome.
GEH evaluated the overall plant response with M+, ATWS, ATWSI and long term stability solution DSS-CD. GEH has a long experience of modeling BSEP from startup through EPU operation.
Framatome performed the remaining typical reload specific fuels analyses. Framatome has been modeling BSEP at EPU conditions since the original ATRIUM 10 transition in 2008 and ATRIUM 10XM since 2011.
Consistent with the M+LTR, the evaluation of BSEP Emergency Core Cooling System Net Positive Suction Head demonstrated there is no adverse impact and therefore no change to Containment Accident Pressure credit is warranted with MELLLA+.
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MELLLA+ Design and Analysis - Vendor Methodology Applicability ANP-3108P, Applicability of Framatome BWR Methods to Brunswick Extended Power Flow Operating Domain (EPFOD)
No SER restrictions on Framatome methodology that are impacted by EPFOD BSEP core and assembly conditions in MELLLA+ are equivalent to core and assembly conditions of other plants for which the methodology was benchmarked GEH methods are applicable to MELLLA+ and are capable of modeling Framatome fuel Transfer of information from Framatome to GEH allowed explicit modeling of the fuel Duke developed and provided a GEH thermal hydraulic model (ISCOR) for ATRIUM 10XM NRC RAI SRXB-RAI-11 response provided steady-state core simulator comparisons for BSEP MELLLA+ cycle using GEH and Framatome methods Shows GEH methods modeled the A10XM fuel and core characteristics in a satisfactory manner 9
MELLLA+ Design and Analysis - Key GEH Analyses GEH analyzed Anticipated Transient Without Scram (ATWS) and ATWS with Instability (ATWSI) scenarios.
To address the effect of any uncertainty in GEH modeling A10XM, fuel parameter sensitivities were performed.
For ATWSI, additional sensitivities were executed utilizing the homogenous nucleation plus contact temperature model for Tmin and plant data was utilized to determine an appropriate feedwater temperature reduction rate.
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MELLLA+ Design and Analysis - Key MELLLA+ Mitigating Actions BSEP will transition from Option III to Detect and Suppress Solution - Confirmation Density (DSS-CD) for thermal hydraulic stability (THI) protection. To set the DSS-CD amplitude discriminator, GEH analyzed BSEP limiting events to demonstrate adequate margins.
BSEP increased the Standby Liquid Control System (SLCS) B-10 enrichment (47 to 92% B-10) such that the ATWS heat load to the suppression pool was reduced at 2923 MWth/85% flow when compared to original power 2436 MWth/75% flow conditions (19.8% B-10).
2436 MWth/75% Flow peak pool temperature was 189.4 F while EPU/MELLLA+ is 174.0 F.
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Operator Actions and Training Mark DeWire - BSEP Assistant OPS Manager - Shift 12
Operator Actions and Training - Overview Operator Training was Conducted During Two Cycles of 2017
- Cycle 3 (May/June 2017)
- MELLLA+ Introduction (Classroom Only)
- Cycle 6 ( Oct/Nov 2017)
- MELLLA+ Procedure and Equipment Changes (Classroom)
- MELLLA+ Tech Spec Workbook (Classroom)
- Equipment Demonstrations (Simulator)
- ATWS Proficiency Training (Simulator)
- Operator training included training on:
- MELLLA+ Operating Restrictions, Technical Specification changes, and procedure updates
- Time Critical Operator Action (TCOA) to initiate reactor water level reduction during ATWS within 120 seconds 13
Operator Actions and Training - ATWS Time Critical Operator Actions ATWS TCOA Training
- Operating crews were trained on MELLLA+ ATWS time critical actions
- Three high power ATWS simulator scenarios performed per crew
- February 2018 NRC Audit observed performance of high power ATWS time critical actions 14
Operator Actions and Training - ATWS Time Critical Operator Actions ATWS TCOA timing results:
- 12 operating crews were timed initiating ATWS reactor water level reduction (36 scenarios)
- Average time to initiate reactor water level reduction was 85 seconds
- Standard deviation was 16 seconds
- Operating crews have demonstrated ability to perform TCOA within required times with margin 15
Conclusions Implementation of MELLLA+ will provide significant benefits:
- Operators will have greater flexibility in using core flow to control reactivity
- Reduces the number of plant downpowers and reactivity manipulations
- Increases the stations capacity factor during the operating cycle Brunswick will be ready to implement the MELLLA+ License Amendment
- Installation of the DSS-CD firmware and SLC enrichment change complete
- Training on MELLLA+ equipment, procedures and required operator actions is complete
- Final PRNM setpoint Engineering Change is approved
- Implementation test plan established Requested Approval supporting 3Q 2018 Implementation 16
Questions 17
Backup Slides 18
Power Density Comparison for MELLLA+ Submittals Plant GGNS PB BFN BSEP NMP2 MNGP EPU Thermal Power (MWth) 4408 3951 3952 2923 3988 2004 Licensed Core Flow (Mlb/hr) 112.5 102.5 102.5 77 108.5 57.6 MELLLA+ knee % power 80.6 78.8 77.6 77.6 77.6 82.5 MELLLA+ knee % flow 55 55 55 55 55 57.4 power/flow ratio at MELLLA+ knee 57.42 55.23 54.40 53.56 51.86 50.01 power density (kW/ft) 5.5 4.8 4.8 4.9 4.9 4 power density (kW/L) 62.3 58.4 58.4 59 59 48.3 19
BSEP Station Overview Key Milestones Year MWt Full Power Operation 1976 (Unit 1) / 1975 (Unit 2) 2436 (Original Licensed Thermal Power - OLTP)
MELLLA Operating Domain 1990 (Unit 1) / 1989 (Unit 2)
Stretch Power Uprate Operation 1996 (Unit 1) / 1997 (Unit 2) 2558 (105% OLTP)
Option III Stability Solution 2002 (Unit 1) / 2003 (Unit 2)
Extended Power Uprate Operation 2004 (Unit 1) / 2005 (Unit 2) 2923 (120% OLTP)
Renewed Operating License 2006 (Unit 1) / 2006 (Unit 2) 2036 (Unit 1) / 2034 (Unit 2)
Framatome A10 Fuel Introduction 2008 (Unit 1) / 2009 (Unit 2)
Framatome A10XM Fuel Introduction 2012 (Unit 1) / 2011 (Unit 2) 20
Special Testing in MELLLA+ Domain 21
MELLLA+ Design and Analysis - SLMCPR BSEP does not have any SLMCPR penalties for operation in EPU. No additional SLMCPR penalty is warranted for MELLLA+.
The primary concern prompting a penalty is increased void fractions due to operation at higher power/flow ratios and lack of operating data to justify current licensing uncertainties.
Framatome operating experience includes data that validates use of existing uncertainties with Framatome methods at the BSEP MELLLA+ high power/flow ratios.
Therefore, operation in the MELLLA+ region is within the analysis capabilities of Framatome methods and uncertainties and no SLMCPR penalty is warranted.
22
MELLLA+ Design and Analysis - DSS-CD BSEP will transition from Option III to Detect and Suppress Solution - Confirmation Density (DSS-CD) for thermal hydraulic stability (THI) protection.
DSS-CD adds a fourth algorithm (confirmation density) to the three available with Option III (period based, growth based, amplitude based). All four of these algorithms detect instability and protect the reactor from THI. The confirmation density algorithm will become the licensing basis method.
DSS-CD implementation includes Manual Backup Stability Protection (BSP) and Automated Backup Stability Protection (ABSP).
BSP is utilized when OPRM system is inoperable and relies on manual operator action. For BSEP, operation in MELLLA+ regime is not allowed with BSP.
ABSP provides an automatic trip if operating in a region with high potential for thermal hydraulic instability To set the DSS-CD amplitude discriminator BSEP limiting events were performed to demonstrate adequate margins.
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MELLLA+ Design and Analysis - ATWS GEH performed Anticipated Transient Without Scram (ATWS) scenarios.
Parameter Result Design Limit Suppression Pool Temperature (F) 174.0 207.7 Peak Cladding Temperature (F) 1215 2200 Peak Containment Pressure (psig) 8.4 62 To address the effect of any uncertainty in GEH modeling A10XM, fuel parameter sensitivities were performed.
BSEP increased the Standby Liquid Control System (SLCS) B-10 enrichment (47 to 92% B-10) such that the heat load to the suppression pool was reduced at 2923 MWth/85% flow when compared to original power 2436 MWth/75% flow conditions (19.8% B-10).
2436 MWth/75% Flow peak pool temperature was 189.4 F while EPU/MELLLA+ is 174.0 F.
24
MELLLA+ Design and Analysis - ATWSI Limiting ATWSI event is the turbine trip with bypass (TTWBP) initiated from 100%P/85% F.
Key operator action credited: Reactor water level reduction within 120s following indication of no scram.
To address the effect of any uncertainty in GEH modeling A10XM, fuel parameter sensitivities were performed to show the operator actions credited are appropriate.
25
MELLLA+ Design and Analysis - ATWSI Additional sensitivities were executed utilizing the homogenous nucleation plus contact temperature model for Tmin.
More conservative compared to the Modified Shumway Tmin model used in the SAR.
Plant data was utilized to determine an appropriate feedwater temperature reduction rate.
ATWSI results will be presented during proprietary session.
26
MELLLA+ Design and Analysis - RSAR MELLLA+ Impacts MELLLA+ Reload Safety Analysis Report (RSAR) was submitted to NRC as a supplemental information to MELLLA+ LAR Documents Single Loop Operation (SLO) and Feedwater Temperature Reduction are not allowed within the MELLLA+ operating domain Documents additional SLMCPR calculations that are required to encompass MELLLA+ domain New MELLLA+ plant specific LOCA analysis No impact to ASME overpressurization. ATWS overpressurization slightly higher when initiated from MELLLA+ conditions No impact on OLMCPR No impact on LHGR limits No impact on MAPLHGR Limits Documents cycle specific DSS-CD Stability acceptability 27
Operator Actions and Training - License Restrictions Operation in the MELLLA+ domain is prohibited when operating with the following plant conditions:
- Reactor Recirculation System Single Loop Operation (SLO)
- Feedwater Temperature Reduction (currently defined as more than 10°F below design)
- Guidance on restrictions will be incorporated into Abnormal Operating Procedures (AOPs),
Annunciator Panel Procedures (APPs), Operating Procedures (GPs and OPs), and engineering procedures (ENPs).
Operator training has been conducted on these restrictions and the corresponding procedure updates.
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Operator Actions and Training - Technical Specification Changes
- New Operating License Condition - Operation in MELLLA+ domain not allowed with Feedwater Temperature Reductions (FWTR)
- TS 3.3.1.1 RPS Instrumentation
- DSS-CD - Confirmation Density Algorithm (CDA) Replaces Period Based Detection Algorithm (PBDA) as the required Thermal Hydraulic Instability (THI) detection algorithm
- OPRM Upscale and Out of Service actions - ABSP (Automatic Backup Stability Protection)
Operator Actions and Training - Technical Specification Changes (Continued)
- TS/TRM bases Operator training has been conducted on the MELLLA+ Technical Specifications 30
Operator Actions and Training - ATWS Time Critical Operator Actions (TCOA)
Time Critical Operator Action (TCOA): Initiate reactor water level reduction during ATWS within 120 seconds
- Terminate/Prevent Injection hard card revised to improve efficiency
- Control Room Supervisor (CRS) retains Command and Control of TCOA Operator training conducted on 120s Terminate and Prevent TCOA 31
655th ACRS Full Committee Meeting July 11, 2018 Josh Borromeo (Lead Reviewer, DSS/SRXB)
Andy Hon (Project Manager, DORL)
Aaron Wysocki (Consultant, ORNL)
Office of Nuclear Reactor Regulation 1
NRC Staff Safety Evaluation
- Similar to other plants MELLLA+ SE
- Conducted two audits on 5 focused areas
- Safety analyses - July 2017 in Rockville
- Simulator - February 2018 on site
- Included a summary of RES confirmatory study using TRACE computer modelling of Brunswick plant specific MELLLA+ conditions.
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NRC Staff Review Team Office of Nuclear Reaction Regulation J. Borromeo (Lead) M. Biro M. Breach M. Chernoff J. Dozier A. Hon J. Hughey D. Ki M. Panicker A. Sallman R. Stattel A. Smith M. Smith A. Wysocki (ORNL)
Office of Nuclear Regulatory Research A. Bielen K. Gibson C. Gingrich N. Hudson J. Staudenmeier P. Yarsky (Lead) 3
Agenda Open Session to the Public Duration Presenter(s) Topic ACRS Opening introduction 25 min Licensee License Amendment Request overview 10 min NRC staff / ORNL Review highlights 5 min ACRS Public comments Closed Sessions Below 15 min Licensee/GEH LAR - ATWSi details (GEH proprietary) 25 min NRC staff / ORNL Review details and TRACE (GEH proprietary) 1 min NRC SES Management closing remark ACRS Discussions and meeting adjourned 4
Brunswick MELLLA+
Application Application Overview
- MELLLA+ expands the operating domain by allowing operation at 85% core flow at 100% power
- Followed the GEH MELLLA+ licensing topical report
- Fifth MELLLA+ review with GEH methods
- Second MELLLA+ review with Framatome methods and fuel
- First analysis with the combination of GE methods, Framatome methods, and Framatome fuel
BSEP MELLLA+ Focus Areas
- Framatome methods not generically approved for MELLLA+
- SLMCPR 0.03 penalty removal
- A SLMCPR penalty has been applied to other MELLLA+
applications
- Application of DSS-CD
- tmin - time period lower limit change (in the DSS-CD LTR, the time period lower limit is identified as Tmin)
- ATWS-I and ATWS
- First time application of GEH methods with Framatome fuel
- Tmin (minimum film boiling temperature) uncertainty (ATWS-I)
- Feedwater temperature reduction rate (ATWS-I)
Review Summary -
Framatome Methods in MELLLA+
- Framatome approved (for EPU) methods have been used by BSEP. In addition, the licensee evaluated GEH topical reports limitations and conditions for generic applicability
- Same conclusion as Monticello (except for MICROBURN-B2 for SLMCPR 0.03 penalty)
Review Summary - SLMCPR 0.03 Penalty
- The 0.03 SLMCPR penalty was applied for Monticello MELLLA+ (EFW) above a power-to-flow ratio of 42 MWt/Mlbm/hr
- AURORA-B AOO topical report review identified no adverse uncertainty trend in MELLLA+ at high power-to-flow ratios
- AURORA-B and Brunswick both use MICROBURN-B2
- Licensee took a similar approach as AURORA-B
- Staff determined that licensee provided sufficient data and justification such that this penalty was not necessary for Brunswick MELLLA+
Review Summary - DSS-CD
- DSS-CD implemented in other MELLLA+ applications which included adjustments to amplitude discriminator and extension of DSS-CD applicability for the fuel type
- Brunswick is adjusting amplitude discriminator and extended DSS-CD applicability for ATRIUM-10XM fuel which is similar to other applications
- The new item is tmin, time period lower limit to 1.0s
- Staff requested sensitivity studies to justify this change and determined that the change would maintain the as-approved performance of DSS-CD
Review Summary - ATWS-I
- Staff requested ATWS-I calculations using homogenous nucleation temperature for minimum film boiling temperature (Tmin) following a similar approach as Peach Bottom
- Both Brunswick and Peach Bottom gained margin in ATWS-I by reducing the feedwater temperature reduction rate
- The new item is the use of TRACG for ATWS-I with ATRIUM 10XM fuel
- Staff reviewed the approach to bound the ATRIUM 10XM fuel and determined that it was conservative and the results met the ATWS acceptance criteria
- For ATWS-I, staff used a TRACE confirmatory study to support conclusions
Conclusions
- The BSEP safety analysis report discusses the acceptability of the focus areas of the review
- Framatome methods were valid for the conditions for BSEP MELLLA+
- The 0.03 SLMCPR penalty is not necessary for BSEP
- DSS-CD tmin increased to 1.0 sec would maintain the as-approved performance of DSS-CD
- The ATWS-I analysis of ATRIUM 10XM was conservative and the ATWS-I results meet the ATWS acceptance criteria
- The staff concludes that the nuclear design of the fuel assemblies, control systems, and reactor core will continue to meet the GDC regulatory requirements
- The staff finds the proposed BSEP MELLLA+ operating domain extension acceptable
Additional Backup Slides Containment Accident Pressure (CAP)
Credit for NPSH Currently Licensed CAP Credit - EPU LAR Approved in 2002
- No Additional CAP Credit Requested - SECY-11-0014 is not Applicable
- ATWS NPSH Margin Increased Due to Increased Boron Concentration from 47-Atom Percent to 92-Atom percent
CAP Credit Commission Documents
- SECY 11-0014, USE OF CONTAINMENT ACCIDENT PRESSURE IN ANALYZING EMERGENCY CORE COOLING SYSTEM AND CONTAINMENT HEAT REMOVAL SYSTEM PUMP PERFORMANCE IN POSTULATED ACCIDENTS (ML102590196)
- SRM 11-0014, STAFF REQUIREMENTS - SECY-11-0014
- USE OF CONTAINMENT ACCIDENT PRESSURE IN ANALYZING EMERGENCY CORE COOLING SYSTEM AND CONTAINMENT HEAT REMOVAL SYSTEM PUMP PERFORMANCE IN POSTULATED ACCIDENTS (ML110740254)
SRM-SECY-11-0014 -
Commission Direction on Use of CAP
- In SECY 11-0014 the staff recommended and in SRM 11-0014 the commission approved Option 1
- The staff should evaluate current extended power uprate (EPU) applications, as well as future applications for new or increased credit for containment accident pressure, consistent with staff practice in implementing the current risk review guidance (Standard Review Plan Section 19.2),
including the review of nonrisk-informed applications such as EPUs and the recently-developed deterministic guidance based on recommendations of the Advisory Committee on Reactor Safeguards (ACRS) to include uncertain and margins in CAP calculations.
Brunswick MELLLA+
Power/Flow Map
P/F Map Plant Comparison 4500 4000 3500 3000 Peach Bottom Thermal Power (MWt) 2500 2000 Brunswick 1500 Monticello 1000 500 0
0 20 40 60 80 100 120 Core Flow (Mlbm/hr)
Conclusions - Operational
- The BSEP safety analysis report proposes solutions to maintain margins under MELLLA+ that are acceptable to satisfy the regulatory criteria
- FWHOOS not allowed in MELLLA+
- SLO not allowed in MELLLA+
- DSS-CD Tmin increased from to 1.0 sec
- SLC boron enrichment increased
- 120 sec operation action time for reactor level reduction
- The staff concludes that the nuclear design of the fuel assemblies, control systems, and reactor core will continue to meet the GDC regulatory requirements
- The staff finds the proposed BSEP MELLLA+ operating domain extension acceptable
Proposed Revision 2 of DI&C-ISG-06 Licensing Process Status Update: Integrated Action Plan for Modernizing the NRC Digital I&C Regulatory Infrastructure USNRC Staff Briefing to the ACRS Full Committee Digital Instrumentation and Controls July 11, 2018
Discussion Topics I. Draft Revision 2 to DI&C-ISG-06, Licensing Process II. Integrated Action Plan (IAP) Strategy for Digital I&C ModernizationUpdate on Status of Activities 2
I. Draft Rev. 2 to DI&C-ISG-06 Licensing Process Samir Darbali, NRR/DE/EICB Richard Stattel, NRR/DE/EICB Deanna Zhang, NRO/DEI/ICE Advisory Committee on Reactor Safeguards Full Committee Briefing July 11, 2018
ACRS Subcommittee Briefing (May 17, 2018 )
- The staff briefed the ACRS DI&C Subcommittee on the proposed changes to be made to DI&C interim staff guidance (ISG) 06, draft Revision 2.
- The ACRS Subcommittee provided verbal comments to the staff. The main comments focused on how the System Architecture and Fundamental Design Principles are addressed within the Tier 1, 2, 3 Review Process.
4
DI&C-ISG-06 Purpose and Scope
- Defines the licensing process used to support license amendment request (LAR) reviews associated with safety-related DI&C equipment modifications in operating plants and in new plants once they become operational
- Provides guidance for activities performed before LAR submittal and during LAR review. The NRC staff uses the process described in ISG-06 to evaluate compliance with NRC regulations
- ISG-06 makes reference to, and is to be used in conjunction with SRP Chapter 7 (NUREG-0800) 5
ISG-06 Rev. 1 - Key Concepts: Tiers Tiers - a general guide for defining the scope or complexity of a review:
- Tier 1 - license amendments proposing to reference a previously approved topical report.
- Tier 2 - license amendments proposing to reference a previously approved topical report with deviations tailored to the plant specific application.
- Tier 3 - license amendments proposing to use a new DI&C platform or component(s) not previously approved by an NRC topical report review.
6
ISG-06 Rev. 1 - Key Concepts: Phases Phases - a general guide for defining the NRC staff activities to be performed during the review.
- Phase 0 - Pre-Application Meetings with the NRC Staff
- Phase 1 - Initial Application (LAR)
System Description, Compliance with IEEE Stds, Design Requirements, Design Specifications, Planning and Process Information
- Phase 2 - Continued Review and Audit (Supplemental Information)
System Architecture, Software/Hardware Design Specifications, Test Results
- Phase 3 - Implementation and Inspection 7
ISG-06 Rev. 1 - Lessons Learned and Industry Feedback
- ISG-06, Rev. 1 was used to review the Diablo Canyon Plant Protection System DI&C LAR (ADAMS Accession No. ML16139A008), the Hope Creek Power Range Neutron Monitoring System LAR (ADAMS Accession No. ML17216A022), and DI&C topical report reviews
- The concepts of tier labels and review phases are useful
- The one-stop shop approach of Revision 1 created challenges:
o Duplication of SRP Chapter 7, IEEE Std 603 and IEEE Std 7-4.3.2 guidance o References to Regulatory Guides and other documents became outdated o Revision 1 focused more on specific documents, instead of the information needed to make the required regulatory findings 8
ISG-06 Rev. 1 - Lessons Learned and Industry Feedback (cont.)
- The Tier 1, 2, and 3 Review Process could be further improved/streamlined
- Industry has expressed concerns with ISG-06, Rev. 1:
o Significant resources are required for procuring, developing, and testing a full DI&C design before the license amendment is issued o Several review criteria topical areas were repetitive
- Staffs lessons learned and industry feedback on Rev. 1 informed the development of ISG-06, Rev. 2 9
ISG-06 Revision 1 vs. Draft Revision 2
- Both ISG-06 Revision 1 and Revision 2 include a Tier 1, 2, 3 Review Process:
- Use of a Pre-Approved Platform Topical Report
- System Description and System Architecture
- Review of Software Design, Implementation & Test Plans and Processes
- Review of Implementation and Test Results Information
- ISG-06 Revision 2 also introduces an Alternate Review Process:
- Use of a Pre-Approved Platform Topical Report
- System Description and System Architecture
- Review of Software Design, Implementation, & Test Plans and Processes
- The Implementation and Test Results Information will be subject to inspection 10
Comparison of Licensing and Oversight Activities Timeline Tier 1, 2, and 3 Review LA Issued Process (Rev. 1 and 2)
LAR Submitted NRC: LAR (Phase 1) and Phase 2 Review, and Regulatory Audit(s) NRC: Optional Regional Phase 1 Information Inspections of Site Activities Available Tier 1, 2, and 3 Licensee Activity:
Licensee Activities Producing and Submitting Phase 2 Supplement Info (Not applicable to the Alternate Review Process)
Modification Concept High Level Implementation and Detailed HW & SW Design and Phase 0 System Design, Test Activities, Post FAT Licensee Activities, SAT and Fabrication Meeting(s) Planning including FAT Report Alternate Review Process LA Issued (Rev. 2)
LAR Submitted NRC: LAR Review and NRC: Optional Vendor NRC: Optional Regional All Information to meet Regulatory Audit(s) Inspections of Inspections of Site Activities Regulatory Requirements Implementation & Test Activities per License Available Conditions Timeline 11
Characteristics of a License Amendment Request (LAR) using the Alternate Review Process
- The LAR provides the necessary and sufficient design information to demonstrate regulatory compliance
- The LAR describes the licensees Vendor Oversight Plan that ensures the vendor executes the project consistent with the LAR and the requirements of the 2015 version of ASME NQA 1, Part II Subpart 2.7 on Quality Assurance Requirements for Computer Software for Nuclear Facility Applications
- The LAR includes appropriate commitments to complete plant-specific actions that are included in the referenced topical report
- The LAR includes appropriate commitments to complete lifecycle activities under the licensees QA program 12
Alternate Review Process: Licensee Committments and License Conditions
- The Alternate Review Process relies on the LAR containing licensing information and additional regulatory commitments to implement remaining development phases by the licensees QA program, after the license amendment is issued
- The NRC staff may likely translate some of the regulatory-significant commitments into license conditions, as part of the approval (e.g., factory acceptance testing) 13
Phase 0 Activities and Review Process Selection
- Phase 0, Pre-Application meeting(s) will be used to discuss with licensees how the proposed DI&C modification LAR will address:
- Licensee-identified Review Process for the LAR
- Use of a pre-approved topical report, and any significant variances
- Portion of the plant system to be replaced and its impact on the plant, calibration, surveillance testing (and associated impacts on plant staff), and FSAR impacts
- Key design concepts, including the four fundamental design principles
- Significant variances from current guidance
- Enclosure B table applicability
- The Pre-Application meeting summary will include a preliminary assessment that the licensee-identified Review Process is applicable for the proposed modification 14
ACRS Subcommittee Comments (May 17, 2018 Briefing)
- System Architecture - the ISG doesnt show how System Architecture is covered/reviewed under the Tier 1, 2 and 3 Review Process.
- Section D.2, System Architecture, will now be applicable to both processes, and Enclosure B, LAR Submittal Information has been updated accordingly.
- Four Fundamental Design Principles - it is not clear how the four fundamental design principles are applied to a Tier 1, 2 and 3 Review
- Section D.2, which contains the sections on the fundamental design principles, is now applicable to both Processes.
15
ACRS Subcommittee Comments (May 17, 2018 Briefing) (continued)
- Hardware Configuration Control - the ISG is silent in regards to configuration control and configuration management of hardware.
- The staff is evaluating how to address this concern in the ISG 16
ISG-06 Changes Made since the May 17, 2018 ACRS DI&C Subcommittee Meeting
- Section D.2, System Architecture is now applicable to the Tier 1, 2, 3 Review Process
- Section D.3, Hardware Equipment Qualification is now applicable to the Tier 1, 2, 3 Review Process
- Section D.9.9, Equipment Environmental Qualification deleted since it is now covered under Section D.3
- General Changes
- Clarification added
- Editorial changes 17
DI&C-ISG-06 Rev. 2 Structure Section A - Introduction Section B - Purpose Section C Digital I&C Review Process Section C.1 Section C.2 Tier 1, 2, and 3 Process Overview Alternate Review Process Overview Section C.1 refers to the review guidance Section C.2 refers to the review guidance described in Sections D.1, and D.5 through D.9 described in Sections D.1 through D.8 Section D.1 Section D.1 Plant System Description Plant System Description Section D.2 Section D.2 System Architecture System Architecture Section D.3 Section D.3 Hardware Equipment Qualification Hardware Equipment Qualification Section D.4 I&C System Development Processes Section D.5 Section D.5 Applying a Referenced TR Safety Evaluation Applying a Referenced TR Safety Evaluation Section D.6 Section D.6 Compliance Matrix for IEEE Stds 603 and 7 4.3.2 Compliance Matrix for IEEE Stds 603 and 7 4.3.2 Section D.7 Section D.7 Technical Specifications Technical Specifications Section D.8 Section D.8 Secure Development and Operational Environment Secure Development and Operational Environment Section D.9 Sections Applicable to Tier 1, 2, and 3 Reviews 18
DI&C-ISG-06, Rev 2, Enclosure B Tables Tier Plant-Specific Information Submitted with License Amendment Request AR 1 2 3 (Phase 1 for Tier 1, Tier 2, Tier 3) 1.1 X (Summary of) Application Software Planning and Processes (D.4) 1.2 X X X Approved Topical Report Safety Evaluation (D.5) 1.3 X X X X System Description (D.1) 1.4 X X X X System Architecture (D.2) 1.5 X X X X (Summary of) Hardware Equipment Qualification (D.3) 1.6 X X X X (Unified Compliance Matrix for) IEEE Stds 603 and 7-4.3.2 (D.6) 1.7 X X X X (Changes to) Technical Specifications (D.7) 1.8 X X X X Setpoint Methodology and Calculations (D.7) 1.9 X X X X Secure Development and Operational Environment (D.8) 1.10 X X X Software Requirements Specification (D.9.1) 1.11 X X X Software Design Specification (D.9.2) 1.12 X X X Design Analysis Reports for Platform Changes (D.9.3) 1.13 X X X System Response Time Analysis Report (D.9.7) 1.14 X X Design Report on Computer Integrity, Test and Calibration, and Fault Detection (D.9.7) 1.15 X Commercial-Grade Dedication Plan (D.9.10) (D.9.9) 1.16 X Quality Assurance Plan for Hardware (D.9.11) (D.9.10) 1.17 X Equipment Qualification Testing Plans (Including EMI, Temp., Humidity, and Seismic) (D.9.9) (D.3) 1.18 X (Summary of) Hardware Development Process (D.9.11) (D.9.10)
Tier Phase 2 - Submitted before Requested Approval (Tier 1, Tier 2, Tier 3 only) 1 2 3 Note: This table does not apply to Alternate Review Process applications.
2.1 X X X Safety Analysis (D.9.4) 2.2 X X X As-Manufactured, System Configuration Documentation (D.9.5) 2.3 X X X Summary Test Reports (Including Test Results up to FAT) (D.9.6) 2.4 X X X System Response Time Confirmation Report (D.9.7) 2.5 X X X Reliability Analysis (D.9.7) 2.6 X X X System-Level Failure Modes and Effects Analysis (D.9.8) 2.7 X X X Qualification Test Methodologies (D.9.9) (D.3) 2.8 X X Platform-Level Failure Modes and Effects Analysis (D.9.8) 2.9 X X (Summary of) EMI, Temp., Humidity, and Seismic Testing Results (D.9.9) (D.3) 2.10 X Commercial-Grade Dedication Report(s) (D.9.10) (D.9.9) 19
System Architecture - Fundamental Design Principles
- Four fundamental design principles are integrated into Alternate Review Process:
- Verify the design applies sufficient redundancy in the new architecture (ISG-06 Rev. 2, Section D.2.6.2.1).
- Verify the design demonstrate physical, electrical, data communications, and functional independence in the new architecture (D.2.2, D.2.5, D.2.6.2.2).
- Verify design exhibits deterministic behavior (D.2.2.1, D.2.6.2.3)
- Verify the design has sufficient diversity and defense-in-depth in the new architecture to ensure safety is maintained in the event of a postulated common cause failure (D.2.6.2.4) 20
Licensing and Oversight Comparison Summary Tier 1, 2, and 3 Review Process Alternate Review Process Document 2 Submittals 1 Submittal Submittals (LAR - Phase 1) (Supplement - Phase 2) (LAR)
Design Changes Design changes submitted during the Design changes during Implementation and After LAR Phase 2 review (before FAT) can be Testing phases will need to be performed under Submittal reviewed as part of the LAR review 10 CFR 50.59, or new LAR approval Potentially:
- Implementation of high quality software development process (e.g., NQA-1-2015)
License None (Typically)
- Vendor oversight Conditions
- Resolution of plant specific action items identified in the topical report
- Implementation and Test activities (e.g., FAT)
- Vendor Inspection of Implementation, Integration, and Test Activities (e.g. FAT)
Inspection Scope
- Regional Inspection of Post FAT Licensee
- Regional Inspection of Post FAT Licensee Activities (e.g., Installation, Maintenance, Activities (e.g., Installation, Maintenance, Training, Operations, Plans, SAT) Training, Operations, Plans, SAT) 21
Next Steps
- Issue draft Rev. 2 of the ISG for formal public comments at the end of July, 2018
- Conduct an ISG-06 Inspection Workshop - Sept., 2018
- Issue the final ISG, addressing public comments by the end of 2018
- Engage utilities in pre-application meetings
- Exercise ISG and incorporate into Standard Review Plan 22
II. Status Update:
Integrated Action Plan to Modernize the DI&C Regulatory Infrastructure Eric Benner, NRR/DE David Rahn, NRR/DE/EICB Advisory Committee on Reactor Safeguards Full Committee Briefing July 11, 2018
Key Messages
- Making progress on Integrated Action Plan (IAP) activities
- Focused on developing regulatory products that support near-term upgrade needs identified by industry stakeholders
- First implementable results target safety-related upgrades under 10 CFR 50.59 (i.e., RIS supplement)
- Next priority - revise licensing process (ISG-06, Rev. 2)
- Staff will continue to pursue broader modernization efforts (initiated in October 2017) 24
Commission Direction on Digital I&C (SRM-SECY-15-0106 & SRM-SECY-16-0070)
- Develop an integrated strategy under the oversight of a senior management steering committee to modernize the DI&C regulatory infrastructure
- Engage stakeholders to identify common priorities, problems, and potential solutions to address them
- New or revised requirements should be performance-based, rather than prescriptive
- Focus on acceptable approaches to comply with the requirements
- Requirements should be technology-neutral; Guidance for specific technologies should be tailored if necessary
- Same requirements should apply for operating and new reactors
- Evaluate potential policy issues; present any issues that are ripe for consideration to Commission prior to any rulemaking 25
IAP Strategy for DI&C Modernization
- Objective: Modernize the digital I&C regulatory infrastructure to enhance the NRCs capability to be more timely, efficient and effective in ensuring safety, and provide a consistent and predictable regulatory process
- Tactical - Continue to prioritize and implement the regulatory activities needed to provide regulatory clarity and support industry confidence to perform digital I&C upgrades (MPs# 1-3 and MP# 4A)---(High-Priority, Shorter-term Regulatory Products)
- Strategic - Assess and implement broader modernization of regulatory infrastructure (MP# 4B) (Long-term horizon activities) 26
Modernization Plans
- Modernization Plan (MP) #1 - Protection against Common Cause Failure
- MP #1A - Regulatory Issue Summary (RIS) 2002-22, Supplement 1
- MP #1B - Review of NEI 16-16
- MP #1C - Implementing Commission Policy on Protection against CCF in DI&C Systems
- MP #2 - Considering Digital Instrumentation & Controls in Accordance with 10 CFR 50.59
- MP #3 - Acceptance of Digital Equipment (Commercial Grade Dedication)
- MP #4 - Assessment for Modernization of the Instrumentation &
Controls Regulatory Infrastructure
- MP #4A - ISG-06 Revision 2
- MP #4B - Broader Modernization Activities 27
IAP Milestones
- SRM Issued October 15, 2016
- Revisions 0 and 1 to IAP prepared Fall of 2016 through Spring 2017
- Annual Update Paper per SRM--October, 2017
- Revision 2 to IAPIssued January 2018
- Revision 3 to IAP - Issuance scheduled for September 2018 28
Revision 2 of IAP (Collective changes since May 2017 ACRS meeting)
- Primarily updated schedules for each of the Modernization Plans
- Adjusted to reflect continued work on RIS 2002-22, Supplement 1
- Adjusted to reflect development of an update to ISG-06 (i.e., Rev. 2)
- Described progress on new Appendix D to NEI 96-07
- Outlined in greater detail the development longer-term activities 29
Plans for IAP Revision 3
- Potential Updates & Changes
- Continue follow-up activities associated with RIS and ISG-06 (training, workshops, public comments)
- Continue work on Appendix D, NEI 16-16 and Commercial Grade Dedication
- Define longer-term activities beyond MPs #1-3
- Transformation Paper initiatives (SECY-18-0060)
- Design Review Standard for non-LWRs
- Outline Proposed Research Activities 30
IAP Schedule
- Stakeholder Meetings: July/August 2018
- Issue Revision 3 to IAP: September 2018
- Annual Commission Paper: October 2018
- Commission Meeting: October 2018 31
Questions?
32
End 33
Backup Slides 34
Key CCF Activities
- MP #1A - RIS 2002-22, Supplement 1, Clarification on Endorsement of Nuclear Energy Institute (NEI)
Guidance in Designing Digital Upgrades in Instrumentation and Controls Systems
RIS 2002-22, Supplement 1 (MP #1A)
Purpose and Scope
- Clarifies NRCs previous endorsement of NEI 01-01 for 10 CFR 50.59 upgrades
- Clarifies the use of qualitative assessments used to determine that CCF is sufficiently low
- Sufficiently low is based on assessing design attributes, quality of the design process, and operating experience
- Not applicable to major Reactor Protection System (RPS) and Engineered Safety Features Actuation System (ESFAS) upgrades 36
NEI 16 Purpose and Scope (MP #1B)
- Originated in support of industry response to NRCs activities on Protection Against Common Cause Failure
- NEI 16-16 provides engineering guidance for industry to address CCF concerns. The guidance includes defensive measures that can be credited to address CCF, in addition to those in the current NRC guidance (i.e., branch technical position (BTP) 7-19) for both operating and new plants
- Based in part on the design measures in EPRI Technical Report (TR)-3002005326, Methods for Assuring Safety and Dependability when Applying DI&C Systems 37
Implementing Commission Policy on CCF in DI&C (MP #1C)
- Staff will update guidance documents to ensure the Commission policy in SRM/SECY-93-087 continues to be consistently applied and addresses evolving DI&C technologies
- Staff is not proposing nor requesting a change to Commission policy
- Staff is developing a Commission Information SECY on future improvement efforts in addressing CCF 38
Proposed Appendix D to NEI 96-07 (MP #2)
Purpose and Scope
- Intended to provide guidance for licensees to perform 10 CFR 50.59 reviews of activities involving digital modifications Status and Next Steps
- Appendix D work had been delayed, by mutual agreement with NEI, until the issuance of RIS 2002-22, Supplement 1
- Category 2 public meeting was held with NEI on June 26, 2018 to resume work/discuss review topics and status
- NRC staff provided NEI with recommended next steps for completing the Appendix D review 39
Acceptance of Digital Equipment Purpose and Scope (MP#3)
- Improved guidance for acceptance of commercial grade digital equipment for safety-related applications
- Evaluate use of Safety Integrity Level (SIL) certification per IEC - 61508 data to supplement commercial grade dedication (CGD) of digital equipment per 10 CFR 50 Part 21
- NEI to submit guidance document for NRC endorsement based on EPRI research on Safety Integrity Level (SIL) certification process to credit identification and validation of dependability characteristics of digital equipment
- NEI has initiated drafting NEI 17-06, a guidance document for acceptance of digital equipment for NRC endorsement 40
Broader Modernization (MP #4B)
(Purpose and Scope)
- Objective - Broadly evaluate the current overall I&C regulatory infrastructure and the supporting technical bases and consider other important areas beyond those identified in the tactical activities (e.g., past review experiences, ongoing licensing review) to identify and prioritize the improvements to modernize the regulatory infrastructure over the longer term in light of evolving approaches to I&C
- Develop a roadmap to modernize the I&C regulatory infrastructure
- The scope of this effort includes four areas:
- Operating reactors
- New and advanced reactors
- Fuel cycle facilities
- Research and test reactors 41
Our Regulatory Framework 42
Scope of MP#4B Assessment
- There are three standards IBR in 10
- NuScale DSRS Chapter 7 CFR 50.55a(h): 19 RGs in DSRS Chapter 7 that IEEE Std 279-1968, IEEE Std 279- endorses 17 standards 1971, and IEEE Std 603-1991 3 Generic Communications referenced in DSRS Chapter 7
- SRP Chapter 7 7 NUREGs referenced in DSRS 27 RGs referenced in SRP Chapter 7 Chapter 7 that endorses 32 standards 17 BTPs referenced in SRP Chapter 7
- Other Relevant Documents 7 ISGs (most of them superseded) 3 Generic Communications 27 NUREGs referenced in SRP Chapter 7 11 SECY Papers 14 NUREGs referenced in SRP 14 Topical Reports Chapter 7 3 RILs 52 other documents referenced in SRP Chapter 7 (e.g., EPRI Reports, IEEE, and ISO stds not endorsed) 43
Acronyms ACRS: Advisory Committee on IAP: integrated action plan Reactor Safeguards I&C: instrumentation and control BTP: branch technical position IBR: incorporated by reference CCF: common cause failure IEEE: Institute of Electrical and DI&C: digital instrumentation and Electronics Engineers control ISG: interim staff guidance DSRS: design-specific review ISO: International Organization For standard Standardization EPRI: Electric Power Research Institute LAR: licensee amendment request ESFAS: engineered safety features MP: modernization plan actuation system NEI: Nuclear Energy Institute FAT: factory acceptance test 44 44
Acronyms NRC: U.S. Nuclear Regulatory SRM: Staff Requirements Commission Memorandum NuScale: NuScale Power, LLC Std: standard (IEEE abbreviation)
QA: quality assurance TR: technical report RIL: research information letter RIS: Regulatory Information Summary RPS: reactor protection system SAT: site acceptance test 45 45
NON-PROPRIETARY APR1400 Design and Safety Enhancement Features ACRS Meeting (July 11, 2018)
Presentation to the ACRS Full Committee July 11, 2018 1 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Contents Design Features of the APR1400 Comparison of APR1400 and System 80+
Enhancements addressed during the Review ITAACs addressed during the Review Topical Reports ACRS Meeting (July 11, 2018)
Request for Additional Information Summary Acronyms 2 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Design Features of the APR1400 APR1400 is an evolutionary PWR Major Improvements 4-train safety injection system In-containment Refueling Water Storage Tank Digital I&C ACRS Meeting (July 11, 2018)
Severe accident mitigation system 3 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Design Features of the APR1400 Design features different from System 80+
Prestressed concrete cylindrical containment Fluidic device in SIT to enhance safety injection system performance Improved digital I&C and advanced control room design ACRS Meeting (July 11, 2018)
PLUS 7 fuel Use of PAR/igniter for hydrogen mitigation Design enhancement to better execute SAM strategies such as ECSBS 4 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Design Features of the APR1400 Design Life Time : 60 Years for Class 1 Major Equipment Power : 4000MWth / 1400MWe Two-Loop : 2 HLs, 2 SGs, 4 RCPs, 4 CLs, 1 Pzr Primary Operating condition:
Pressure : 2250 psia HL/CL Temp. : 615/555 ACRS Meeting (July 11, 2018)
Secondary Operating condition:
Steam Pressure : 1000psia MF/MS Temp. : 450/545 Pzr Free volume : 2400 ft3 SG U-tube : 13102/SG, I690 5 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Design Features of the APR1400 Safety Injection System Four independent trains through Direct Vessel Injection nozzle Safety Injection Tanks(SIT) with Fluidic Device Safety Injection Pumps(SIP) from IRWST SIP SIP SIT SIT ACRS Meeting (July 11, 2018)
RCP RCP IRWST S/G RV S/G CONTAINMENT RCP RCP SIT SIT SIP SIP 6 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Design Features of the APR1400 Safety Injection System Fluidic Device in SIT
- Extend injection duration of SIT
- Based on vortex flow resistance
- Standpipe: low resistance
- Control port: high resistance ACRS Meeting (July 11, 2018)
Large flow rate Small flow rate 7 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Design Features of the APR1400 I&C System Fully digitalized I&C system with diverse platforms
- Safety system : Programmable Logic Controller
- Non-safety system : Distributed Control System
- Diverse protection system : FPGA-based Logic Controller Data communication systems maintain independence between safety system and non-safety system Remote Shutdown Room available when MCR uninhabitable ACRS Meeting (July 11, 2018) 8 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Design Features of the APR1400 Probabilistic Risk Assessment (PRA)
Operation Mode Risk Evaluation At Power Level 1 Internal Event Level 2 Internal Event Internal Fire Internal Flooding Seismic Risk Evaluation ACRS Meeting (July 11, 2018)
Other External Events Low Power and Level 1 Internal Event Shutdown (LPSD) Level 2 Internal Event Internal Fire Internal Flooding Seismic Risk Evaluation 9 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Design Features of the APR1400 Other design features Design feature to address GSI-191 Issue
- No fibrous insulation in the zone of influence (ZOI)
- Sump strainer performance tests were performed.
- In-vessel downstream effects tests were performed.
Design enhancement to implement RG 4.21 Minimization of contamination and radioactive ACRS Meeting (July 11, 2018) waste generation during life cycle requirements.
- Minimization of embedded and/or buried piping
- Provision for early leak detection
- Introduced trench/double-walled piping 10 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Design Features of the APR1400 Other design features Aircraft impact assessment(AIA) to show core cooling capability and spent fuel pool integrity Loss of Power
- Four EDGs for emergency power
- Power supply using mobile generators (onsite and offsite)
- SFP level instrumentations 11 APR1400-K-X-EC-18006-NP
Comparison of APR1400 and System 80+
SIS: safety injection system DVI: direct vessel injection POSRV: pilot operated safety Containment relief valve
- System80+ : Spherical Steel IHA: integrated head assembly
- APR1400 : Cylindrical PS Concrete CFS: core flooding system PAR: passive autocatalytic recombiner Thermal Power
- System80+ : 3,931 MWt
- APR1400 : 4,000 MWt Hot-leg Temp. RCS OPP / RD System
- System80+ : 621 - System80+ : 4 PSV + 2 SDS
- APR1400 : 615 - APR1400 : 4 POSRV ACRS Meeting (July 11, 2018)
RV Upper Structure
- System80+ : Conventional
- APR1400 : IHA Severe Accident
- System80+ : CFS Safety Injection System - APR1400 : CFS + PAR
- System80+ : 4 train SIS + DVI
- APR1400 : 4 train SIS + DVI + Fluidic Device 12 APR1400-K-X-EC-18006-NP
Comparison of APR1400 and System 80+
Design Items APR1400 System80+
NSSS Thermal Power 4,000 MWt (1,400MWe) 3,931MWt (1,400MWe)
Overpressure Protection 4 PSV + 2 train SDS Four(4) POSRVs and Rapid Depressurization valve Reactor Vessel Upper Previous complicated Integrated Head Assembly Head Assembly upper head structures Installation of Fluidic Safety Injection Tank Conventional SIT Device inside the SIT Large Display Panel (LDP)
ACRS Meeting (July 11, 2018) indicating important LDP providing overview parameters + Compact +
Main Control Room Workstation (WS) + Workstations for Computerized Procedure detailed information System Data Communication Network + Data Link Data Link 13 APR1400-K-X-EC-18006-NP
Comparison of APR1400 and System 80+
Design Items APR1400 System80+
Containment Steel-lined post- Steel spherical containment tensioned prestressed shell, surrounded by concrete with a reinforced concrete shield cylindrical wall and a building hemispherical dome Containment H2 PAR/Igniter Igniter Mitigation Alternate AC Power GTG Combustion Turbine Emergency Additional Backup ACRS Meeting (July 11, 2018)
Containment Spray Supply of Spray Water None Backup System 14 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Enhancements addressed during the Review Application of graded approach for the piping design Construction sequence and post-construction analyses for NI building structure based on APR1400 SKN 3&4 ACRS Meeting (July 11, 2018) 15 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Enhancements addressed during the Review Plant Protection System Switch panel added for trip channel bypass, setpoint reset and operating bypass Cross channel communication deleted except voting signals for reactor trip Diverse Protection System (DPS) & Diverse Indication System PLC(Programmable Logic Controller) FLC (FPGA-based ACRS Meeting (July 11, 2018)
Logic Controller)
DPS: 2 channels (2-out-of-2 trip ) 4 channels (2-out-of-4 trip)
DPS: Motor-Generator Set Breaker trip Reactor Trip Switchgear Breaker trip Reactor Trip Switchgear: 4 breakers (1 set) 8 breakers (2 diverse sets) 16 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY ITAACs addressed during the Review Current APR1400 ITAAC 2.0 Design Descriptions and ITAAC # in Rev.2 # in Rev.3 2.1 Site Parameters 0 0 2.2 Structural and Systems Engineering 30 36 2.3 Piping Systems and Component 2 2 2.4 Reactor Systems 213 209 2.5 Instrumentation and Controls 159 159 2.6 Electric Power 187 187 2.7 Plant Systems 484 483 ACRS Meeting (July 11, 2018) 2.8 Radiation Protection 3 3 2.9 Human Factors Engineering 2 2 2.10 Emergency Planning 6 6 2.11 Containment Systems 81 84 2.12 Physical Security Hardware 30 30 2.13 Design Reliability Assurance Program 1 1 Total 1198 1202 17 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY ITAACs addressed during the Review Key Changes in ITAAC ITAAC Wording Changes Communication Independence Incorporation of Standardized ITAAC Guidance Communication Independence of ESF-CCS ITAAC related to Structures Priority Logic within ESF-CCS ACRS Meeting (July 11, 2018)
CPU Load Restrictions Clarification of Diverse Design Group and Diversity between DAS & PPS/ESF-CCS 18 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Topical Reports APR1400 reviewed and approved Topical Reports Supporting Title Document No.
DCD Chapter APR1400-K-Q-1 KHNP QAPD for the APR1400 DC 17 TR-11005-NP-A KCE-1 Critical Heat Flux APR1400-F-C-2 Correlation for PLUS7 Thermal 4, 15 TR-12002-P-A Design Fluidic Device Design for the APR1400-Z-M-ACRS Meeting (July 11, 2018) 3 6, 15 APR1400 TR-12003-P-A Realistic Evaluation Methodology APR1400-F-A-TR-4 for Large-Break LOCA of the 15 12004-P APR1400 PLUS7 Fuel Design for the APR1400-F-M-5 4 APR1400 TR-13001-P 19 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Topical Reports KCE-1 CHF Correlation Topical Report KCE-1 CHF Correlation Topical Report describes CHF tests for PLUS7 fuel, correlation development, verification/validation and its application to the APR1400.
KCE-1 CHF Correlation Topical Report supports DCD Chapters 4 and 15 by assuring the design acceptance criterion under full ACRS Meeting (July 11, 2018) compliance with conditions and limitations on FSER.
20 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Topical Reports Fluidic Device Design Topical Report A passive flow controlling Fluidic Device has been developed and installed inside the SIT in order to improve the effectiveness of SIT water.
Fluidic Device Topical Report contains the design requirements, detailed design of the SIT-FD, and the results of full-scaled performance verification tests.
ACRS Meeting (July 11, 2018)
Fluidic Device Topical Report supports DCD Chapters 6 and 15 by assuring the design and performance of SIT-FD.
21 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Topical Reports PLUS7 Design Topical Report PLUS7 Topical Report contains evaluation results for fuel assembly and rod supporting DCD Chapter 4.
Main contents of PLUS7 Topical Report are:
- Fuel rod design, fuel assembly design, and their evaluation results
- Results of poolside examinations, hot-cell examinations, and commercial operating experiences
- Consideration of Thermal Conductivity Degradation ACRS Meeting (July 11, 2018)
Evaluation results show the performance and integrity of PLUS7.
22 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Topical Reports Large Break Loss-Of-Coolant Accident (LBLOCA) Topical Report LBLOCA topical report describes a realistic evaluation methodology, CAREM*, for the analysis of LBLOCA of the APR1400.
CAREM follows NUREG/CR-5249 (CSAU) and Regulatory Guide 1.203.
CAREM supports DCD Chapter 15.
Evaluation results of CAREM for APR1400 show sufficient safety margin of ECCS performance.
ACRS Meeting (July 11, 2018)
- CAREM: Code-Accuracy-based Realistic Evaluation Methodology 23 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Request for Additional Information 2,225 RAI Questions were issued and resolved DCD No. of RAI No. of P3 Open Contents Chapter Question Items*
1 Introduction & General Description 0 0 2 Site Characteristics 33 0 3 SSC and Equipment 260 47 4 Reactor 62 6 5 RCS and Connection Systems 78 19 6 Engineered Safety Features 151 8 7 I&C 191 40 8 Electric Power 78 5 9 Auxiliary Systems 277 30 10 Steam and Power Conversion System 74 17 38 3 ACRS Meeting (July 11, 2018) 11 Radioactive Waste Management 12 Radiation Protection 84 14 13 Conduct of Operations 52 0 14 Verification Programs 162 21 15 Transient and Accident Analyses 123 3 16 Technical Specifications 223 135 17 QA and Reliability Assurance 5 2 18 Human Factor Engineering 137 0 19 PRA and Severe Accident Evaluation 173 19 ER Environmental Report 24 0 Total 2,225 366
- All open items are now resolved 24 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Summary APR1400 DCD is completed.
All RAIs have been resolved with adequate and sufficient discussion with the staff.
Confirmatory items have been incorporated in DCD Rev.3.
ACRS Meeting (July 11, 2018) 25 APR1400-K-X-EC-18006-NP
NON-PROPRIETARY Acronyms AAC alternate alternating current APR1400 advanced power reactor 1400 CHF critical heat flux DAS diverse actuation system ECSBS emergency containment spray backup system EDG emergency diesel generator ESF-CCS engineered safety features-component control system FPGA field programmable gate array GTG gas turbine generator IRWST in-containment refueling water storage tank ITAAC inspections, tests, analyses, and acceptance criteria LPSD low power and shutdown MCR main control room NI nuclear island ACRS Meeting (July 11, 2018)
PAR passive autocatalytic recombiner PLC programmable logic controller POSRV pilot operated safety relief valve PRA probabilistic risk assessment SAM severe accident mitigation SBO station blackout SDS safety depressurization system SFP spent fuel pool SIP safety injection pump SIT-FD safety injection tank - fluidic device 26 APR1400-K-X-EC-18006-NP
NRC Staff Presentation to the ACRS Full Committee Korea Hydro and Nuclear Power Co., Ltd. (KHNP)
APR1400 Design Certification Application Review Phase 5 Review of Advanced Safety Evaluations JULY 11, 2018
Overview
- ACRS review (31 meetings in 27 months):
Phase 3 FC meeting: 4/20/16 APR1400 DESIGN OVERVIEW Phase 3 SC meetings: 9/21/16 to 8/24/17 (13 meetings, w/Topicals [TOP])
Phase 3 FC meetings: 2/9/17 to 9/7/17 (4 meetings, w/Topicals)
Phase 3 SC meeting: 9/20/17 GSI-191 and Long-Term Core Cooling [LTCC]
PRA Briefing FC meeting: 12/6/17 (1 meeting)
Phase 5 SC meetings: 10/17/17 to 6/19/18 (7 meetings)
Phase 5 FC meetings: 3/8/18 to 7/11/18 (4 meetings, 3 were TOP/LTCC)
- RAI Questions: 2201-DCD, 69-TOP, 21-QA, & 24-ER [2315]
Since the NRC staff first began providing ACRS with the Advanced Safety Evaluations in September 2017, the applicant has continued to submit revised RAI responses.
These RAI response revisions primarily corrected typographical errors or errors in the previous response identified by NRC staff when reviewing the response.
NRC reviewed all RAI responses since 9/2017 and updated ACRS by chapter on any RAI response revision received after the respective Chapter SC.
A total of 52 revised responses received after the last SC meeting for each chapter have been identified to ACRS for review. None were considered significant revisions by NRC staff.
Fifty (50) confirmatory items remain pending submission of DCD Revision 3. All other questions are closed.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 2
Chp 1 - Introduction and General Description of the Plant
- Scope of review:
Provides general descriptions of the APR1400 design, objectives, information regarding how the DCD was developed and is structured, and comparison with other facilities.
Later sections provide lists and tables of referenced material, COL items, conformance with guidance and regulatory documents, and other information referenced by Chapters 2 through 19.
- Status of Confirmatory Items: Since no design commitments are made specifically in Chapter 1, there was no separate review of the chapter and there are no confirmatory items.
Conclusions:
The applicant provided an adequate general description of the APR1400 design, objectives, and DCD construction.
The applicant provided accurate information in the lists and tables as confirmed by evaluations of the individual chapters.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 3
Chp 2 - Site Characteristics
- Scope of review:
Site-related design characteristics for the APR1400 design, including:
geography, demography, nearby facilities, meteorology, hydrologic engineering, geology, seismology, and geotechnical engineering.
Postulated site parameters related to climatology, atmospheric dispersion, ground and surface water, precipitation, geology, seismology, and geotechnical engineering
- Status of Confirmatory Items: Two minor confirmatory items remain pending submission of DCD Revision 3.
Conclusions:
The applicant provided an adequate description of the site-specific information to ensure that potential COL applicants referencing the APR1400 design can meet the relevant requirements.
An applicant seeking a combined license (COL) must address site-specific information.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 4
Chp 3 - Design of Structures, Systems, Components, and Equipment
- Scope of review: Classification of structures, systems, and components, wind and tornado loadings, water level (flood) design, missile protection, protection against dynamic effects associated with postulated rupture of piping, seismic design, design of category I structures, mechanical systems and components, seismic, dynamic, and environmental qualification of mechanical and electrical equipment, piping design review, and threaded fasteners.
The applicant applied a new approach to defining the ITAAC for the critical sections (steel and reinforced concrete) for the design of the safety-related structures (e.g. reactor building, auxiliary building, EDG building).
- Status of Confirmatory Items: Nine confirmatory items remain pending submission of DCD Revision 3.
Conclusions:
The applicant has demonstrated that the structures, system, components, and equipment comply with NRC regulations and conform to NRC guidance.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 5
Chp 4 - Reactor
- Scope of review:
Fuel system design Nuclear design Thermal and Hydraulic design Reactor materials Functional design of reactivity control systems
- Status of Confirmatory Items: All confirmatory items were closed with DCD Revision 2.
Conclusions:
The applicant provided an adequate description of all aspects of the reactor, thereby allowing the staff to conclude that proper methodologies were used, that proper codes were applied, and that all appropriate design criteria and other applicable regulatory criteria were met.
The staff concluded that the applicant has allowed for proper testing and inspection.
The staff performed confirmatory analysis for first-cycle core design.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 6
Chp 5 - Reactor Coolant System and and Connecting Systems
- Scope of review:
Thermal and Hydraulic design Reactor materials Code Requirements
- Status of Confirmatory Items: Two minor confirmatory items remain pending submission of DCD Revision 3.
Conclusions:
The applicant provided an adequate description of all aspects of the reactor coolant system and its connecting systems, thereby allowing the staff to conclude that proper methodologies were used, that proper codes were applied, and that all appropriate design criteria and other applicable regulatory criteria were met.
The staff concluded that the applicant has allowed for proper testing and inspection.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 7
Chp 6 - Engineered Safety Features
- Scope of review:
Thermal and Hydraulic design Material qualifications Heat Removal Adequacy Code and QA Requirements Containment Functional Design
- Status of Confirmatory Items: Seven confirmatory items remain pending submission of DCD Revision 3.
Conclusions:
The applicant provided an adequate description of all aspects of the Engineered Safety Features, thereby allowing the staff to conclude that proper methodologies were used, that proper codes were applied, and that all appropriate design criteria and other applicable regulatory criteria were met.
The staff concluded that the applicant has allowed for proper testing and inspection.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 8
Chp 7 - Instrumentation and Controls
- Scope of review: Safety-related I&C systems, non-safety-related I&C systems, data communication systems, quality, qualification, integrity, reliability, diversity, defense-in-depth, and single failure criterion.
- Status of Confirmatory Items: Four confirmatory items remain pending submission of DCD Revision 3.
Conclusions:
The applicant has demonstrated that the I&C systems and the overall I&C architecture meet the fundamental safety design principles of independence, diversity, defense-in-depth, determinism, and redundancy.
The applicant has provided sufficient information to demonstrate isolation of I&C systems from external interfaces.
The staff concludes that the I&C design complies with NRC regulations and conforms to NRC guidance.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 9
Chp 8 - Electric Power
- Scope of review:
Offsite power systems Onsite AC and DC power systems Station blackout
- Status of Confirmatory Items: Four minor confirmatory items remain pending submission of DCD Revision 3.
Conclusions:
The staff has concluded that offsite and onsite electrical systems comply with all applicable design criteria and standards.
The staff concluded that the applicant has provided sufficient information and identified necessary analysis to support a future COL application.
The staff concluded that the APR1400 design is capable of withstanding and recovering from a station blackout for the stated coping time.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 10
Chp 9 - Auxiliary Systems
- Scope of review:
Fuel handling and storage Water systems Process auxiliaries Heating ventilation and air conditioning Other auxiliary systems
- Status of Confirmatory Items: All confirmatory items were closed with DCD Revision 2.
Conclusions:
The staff has concluded that all auxiliary systems comply with the applicable design and other regulatory criteria and standards.
The staff has concluded that the applicant has allowed for adequate pre-operational testing.
The staff has concluded that the applicant has provided sufficient information and identified necessary analysis to support a future COL application.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 11
Chp 10 - Steam and Power Conversion System
- Scope of review:
Turbine generator Main steam system Condensate and feed and associated systems Auxiliary feed system Auxiliary steam system
- Status of Confirmatory Items: All confirmatory items were closed with DCD Revision 2
Conclusions:
The staff has concluded that the steam and power conversion systems comply with the applicable design and other regulatory criteria and standards.
The staff has concluded that the applicant has provided sufficient information and identified necessary analysis to support a future COL application.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 12
Chp 11 - Radioactive Waste Management
- Scope of review: Liquid waste management system (LWMS), gaseous waste management system (GWMS), solid waste management system (SWMS), and process and effluent radiological monitoring and sampling system (PERMSS) including the instrumentation used to monitor and control releases of radioactive effluents and wastes.
- Status of Confirmatory Items: All confirmatory items were closed with DCD Revision 2.
Conclusion:
The applicant has demonstrated that the systems comply with NRC regulations and conform with NRC guidance to avoid unmonitored and uncontrolled radioactive releases to the environment.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 13
Chp 12 - Radiation Protection
- Scope of review: Information on facility and equipment design and programs used to meet the radiation protection standards in 10 CFR Parts 20, 50, and 70.
- Status of Confirmatory Items: A minor confirmatory item remains pending submission of DCD Revision 3.
Conclusions:
The applicant has demonstrated that the APR1400 design includes adequate design features to maintain the radiation doses resulting from exposure to radioactive sources to within the limits required by 10 CFR Part 20, and as low as is reasonably achievable (ALARA), if operated with an appropriate radiation protection program.
An applicant seeking a combined license (COL) must address the radiation protection program, as well as other identified radiation protection COL information items.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 14
Chp 13 - Conduct of Operations
- Scope of review: Describes the required organizational structure, programs, and procedures required of a COL to safely operate the plant. These are passed on to the COL via 33 COL information items in five areas: organizational structure, training, emergency planning (EP), operational programs, and plant procedures. A sixth area (physical security, no COL items) and seventh area (Fitness for Duty, one COL item) are not presented to the ACRS.
- Status of Confirmatory Items: Two minor confirmatory items remain pending submission of DCD Revision 3.
Conclusion:
The applicant provided adequate guidance and information, including establishing training programs per NEI 06-13A, EP facility design requirements, operational programs developed in accordance with SECY 0197, and GTGs/EOGs used to develop site-specific procedures, which when implemented by a COL provides adequate assurance that the COL will operate the plant safely.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 15
Chp 14 - Verification Programs
- Scope of review:
Major phases of the ITP, including preoperational tests, initial fuel loading and initial criticality, low-power tests, and power ascension tests Tier 1 information including definitions, general provisions, design descriptions, and ITAAC Tables
- Status of Confirmatory Items:
No confirmatory items pending for Sections 14.1 and 14.2 (ITP)
Two confirmatory items remain pending for Section 14.3 (ITAAC)
Conclusions:
The applicant has fully addressed the information related to the ITP and demonstrated compliance with applicable regulations and guidance.
The ITAAC are necessary and sufficient to provide reasonable assurance that, if the Inspections, Tests, and Analyses are performed and the Acceptance Criteria are met, a facility that incorporates the certified APR1400 design has been constructed and will be operated in conformity with the applicable portions of the design certification, the AEA, and the NRCs rules and regulations.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 16
Chp 15 - Transient and Accident Analyses
- Scope of review: Analyses of the APR1400 responses to postulated equipment failures or malfunctions to determine the limiting conditions for operation (LCO), limiting safety system settings (LSSS), and design specifications for safety-related structures, systems, and components (SSCs). Design Basis Accident (DBA) radiological consequence analysis.
- Status of Confirmatory Items: All confirmatory items were closed with DCD Revision 2.
Conclusion:
The applicant has demonstrated in its analysis of the APR1400 nuclear steam supply system (NSSS) to anticipated operational occurrences and postulated accidents, and in its analyses of the radiological consequences of DBAs that the APR1400 design complies with NRC regulations and conforms with NRC guidance.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 17
Chp 16 - Technical Specifications
- Scope of review: Analyses of the APR1400 defined terms, limiting conditions for operation (LCO), limiting safety system settings (LSSS),
and design specifications for safety-related structures, systems, and components (SSCs). Review of reactor trip and ESFAS setpoint and surveillance methodologies.
- Status of Confirmatory Items: All confirmatory items were closed with DCD Revision 2.
Conclusion:
The applicant has provided the APR1400 technical specifications that comply with applicable regulations and conform with NRC guidance.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 18
Chp 17 - Quality Assurance and Reliability Assurance
- Scope of review: Quality assurance, including a quality assurance program inspection, the maintenance rule, and the reliability assurance programs, including the reliability assurance program list of structures, systems, and components.
- Status of Confirmatory Items: One confirmatory item remains pending submission of DCD Revision 3.
Conclusion:
The applicant added three COL information items, making the reliability assurance program acceptable for use to identify risk-significant SSCs.
The applicant has demonstrated that the quality assurance, maintenance rule, and reliability assurance programs comply with NRC regulations and conform to NRC guidance.
July 11, 2018 APR1400 Final ACRS Full Committee Meeting 19
Chp 18 - Human Factors Engineering
- Scope of review:
Human factors engineering (HFE) portion of the APR1400 design certification including the implementation plans (IPs) documented in technical reports incorporated by reference into the DCD that describe the proposed methodology a combined license (COL) applicant or holder will follow to complete the elements in NUREG-0711, Revision 3.
- Status of Confirmatory Items:
Six minor confirmatory items remain pending submission of DCD Revision 3.
Conclusion:
The applicants HFE design process conforms to NRC HFE-related guidance (NUREG-0711) and therefore provides reasonable assurance that HFE-related requirements are satisfied.
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Chp 19 - Probabilistic Risk Assessment and Severe Accident Evaluation
- Scope of review: Probabilistic risk assessment and its uses; severe accident evaluation.
- Status of Confirmatory Items: Seven confirmatory items remain pending submission of DCD Revision 3.
Conclusion:
The applicant provided PRA revisions to the at-power internal events level 1 & 2 PRA, the at-power internal fire level 1 & 2 PRA, the at-power internal flooding level 1 & 2 PRA, the low-power shut-down internal events level 2 PRA, the low-power shut-down internal fire level 1 & 2 PRA, and the low-power shut-down internal flooding level 1 & 2 PRA. These updates represented significant improvements.
The applicant has demonstrated that the probabilistic risk assessment and severe accident programs comply with NRC regulations and conform to NRC guidance.
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Sect. 19.3 - Beyond Design Basis External Event (BDBEE)
- Scope of review: Conformance of the APR1400 design with SECY-12-0025, NRC Orders EA-12-049, and EA-12-051, and the details addressing the recommendations of the Near-Term Task Force with respect to managing and mitigating external events that are beyond the design basis of the plant.
- Status of Confirmatory Items: Two confirmatory items remain pending submission of DCD Revision 3.
Conclusion:
The applicant has addressed in the APR1400 application, the Commission-approved Fukushima actions described in SECY-12-0025 and NRC Orders EA-12-049 and EA-12-051, to the fullest extent practicable.
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Sect. 19.4 - Loss of Large Area (LOLA)
- Scope of review: Guidance and strategies provided to a COL to address the loss of large areas of the APR1400 plant due to explosions or fires from a beyond design basis event using readily available resources and identifying potential practicable areas for the use of beyond-readily available resources. This is provided to aid the COL in meeting the requirements of 10 CFR 50.54(hh)(2).
- Status of Confirmatory Items: One confirmatory item remains pending submission of DCD Revision 3.
Conclusion:
The applicant has provided adequate guidance and strategies, using readily available resources consistent with its design, to address the loss of large areas of the APR1400 plant due to explosions or fires from a beyond design basis event. This information is adequate to enable a licensee who operates an APR1400 plant to meet the requirements of 10 CFR 50.54(hh)(2).
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Sect. 19.5 - Aircraft Impact Assessment (AIA)
- Scope of review: Features considered in the APR1400 design to minimize or mitigate the impact of a large commercial aircraft. The APR1400 is designed to maintain the reactor core cooled and the integrity of the spent fuel pool. This section is provided to demonstrate compliance with 10 CFR 50.150(a).
- Status of Confirmatory Items: All confirmatory items were closed with DCD Revision 2.
Conclusion:
The applicant performed a design-specific assessment of the effects of the impact of a large, commercial aircraft on the APR1400 design. The applicant used the assessment to identify and incorporate into the design those design features and functional capabilities to show that, with reduced use of operator actions:
The reactor core remains cooled, or the containment remains intact; and Spent fuel cooling or spent fuel pool integrity is maintained.
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Conclusion/Next Steps
- Objective: On December 23, 2014, the applicant submitted the application for certification of the APR1400 reactor design under 10 CFR Part 52, Subpart B. On March 8, 2018, the applicant submitted Revision 2 to the DCD and requested a Final Design Approval (FDA). The FDA (previously 10 CFR 52, Appendix O) has been superseded by the Standard Design Approval (SDA, now 10 CFR 52, Subpart E)
[See 72 FR 49352, August 28, 2007].
The requirements for approval of a design under either Subpart are essentially the same (up until the process for certification by the Commission under Subpart B). Both Subparts require a referral to the ACRS (52.53 and 52.141). The applicant and NRC staff believe that the information required (under both Subparts) for the ACRS to report on the portions of the application which concern safety have been provided.
Conclusion:
The APR1400 DC application contains a level of design information sufficient to enable the Commission to judge the applicants proposed means of assuring that construction conforms to the design and the Commission can reach a final conclusion on all safety questions associated with the APR1400 design in order to grant certification under Subpart B. Also, the level of design information is sufficient to issue a Standard Design Approval under Subpart E.
- Next Steps: If ACRS agrees that sufficient information has been provided and is able to report as required by both Subparts, the applicant will issue Revision 3 of the DCD (and referenced technical reports) which will include all corrections identified to staff and ACRS (and no others), closing all remaining confirmatory items. Revision 3 will be the revision of record. NRC staff will verify the changes in DCD Revision 3 and the technical reports and complete the issuance of the APR1400 Final Safety Evaluation Report by September 30, 2018.
- NRC Staff thanks the ACRS members and staff for all their support and assistance with the review and the logistics of holding 31 meetings in the past 27 months!!
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- AC/DC Alternating Current/Direct Current
- AEA Atomic Energy Act (of 1954, as amended)
- ALARA As Low As Reasonably Achievable
- CFR Code of Federal Regulations
- COL Combined License
- DBA Design Basis Accident
- DCD Design Certification Document
- EP Emergency Planning
- EOG Emergency Operating Guidelines
- ESFAS Engineered Safety Features Actuation System
- GTG Generic Technical Guidelines
- GWMS Gaseous Waste Management System
- HFE Human Factors Engineering
- I&C Instrumentation and Controls
- IP Implementation Plan
- ITAAC Inspections, Testing, Analyses and Acceptance Criteria
- ITP Initial Test Program
- LCO Limiting Conditions for Operations
- LSSS Limiting Safety Systems Settings
- LWMS Liquid Waste Management System
- NEI Nuclear Energy Institute
- NSSS Nuclear Steam Supply System
- PERMSS Process and Effluent Radiological Monitoring and Sampling System
- SECY Office of the Secretary of the Nuclear Regulatory Commission
- SSC Structures, Systems, and Components
- SWMS Solid Waste Management System July 11, 2018 APR1400 Final ACRS Full Committee Meeting 26