ML19085A483

Tabletop Exercise of Interim Staff Guidance (ISG)-06, Draft Rev. 2, Licensing Processtabletop (Transcript Day 1)

ML19085A483
Person / Time
Issue date:	06/13/2018
From:	Joe Golla NRC/NRR/DLP/PLPB
To:
Golla J, NRR/DLP, 415-1002
References
NRC-3769
Download: ML19085A483 (267)

Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Tabletop Exercise of Interim Staff Guidance (ISG)-06, Draft Rev. 2, "Licensing Process" Docket Number: (n/a)

Location: Rockville, Maryland Date: Wednesday, June 13, 2018 Work Order No.: NRC-3769 Pages 1-266 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 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +

4 TABLETOP EXERCISE OF INTERIM STAFF GUIDANCE (ISG)-

5 06, DRAFT REV. 2, "LICENSING PROCESS" 6 + + + + +

7 WEDNESDAY, JUNE 13, 2018 8 + + + + +

9 The meeting convened in Room 1C03/1C05 10 of Three White Flint North, 11601 Landsdown Street, 11 Rockville, Maryland, at 8:30 a.m., Joe Golla 12 presiding.

13 INDUSTRY MEMBERS PRESENT 14 NEIL ARCHAMBO, Duke Energy 15 JANA BERGMAN, Curtis-Wright 16 MARK BURZYNSKI, NewClear Day, Inc.

17 STEVE DRAGOVICH, Exelon 18 PAREEZ GOLUB, Excel 19 JERUD HANSON, NEI 20 DAVE HARRELL, MPR Associates 21 RAYMOND HERB, Southern Nuclear 22 DAVID HOOTEN, Imperia Engineering Partners 23 FRANK NOVAK, GE Hitachi 24 WARREN ODESS-GILLETT, NEI 25 JOHN SCHRAGE, Entergy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 NRC STAFF PRESENT 2 JOSEPH GOLLA, NRR 3 ROSSNYEV ALVARADO, NRR*

4 STEVEN ARNDT, NRR 5 ERIC BENNER, NRR 6 PONG CHUNG, RES*

7 KELLEY CLARK, NRC*

8 SAMIR DARBALI, NRR 9 RICHARD STATTEL, NRR 10 BRIAN THOMAS, RES*

11 MICHAEL WATERS, NRR 12 DEANNA ZHANG, NRO*

13 *Present via telephone 14 15 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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3 1 CONTENTS 2 Meeting Opens . . . . . . . . . . . . . . . . . . 4 3 Introductions . . . . . . . . . . . . . . . . . . 5 4 Opening Remarks . . . . . . . . . . . . . . . . . 7 5 Overall Industry Tabletop . . . . . . . . . . . . 10 6 Lessons Learned from Oconee/Diablo Canyon . . . . 21 7 New System Architecture . . . . . . . . . . . . . 40 8 Secure Development and Operational 9 Environment . . . . . . . . . . . . . . . 106 10 Pre-application Coordination Meetings . . . . . 142 11 Human Factors Engineering . . . . . . . . . . . 146 12 Resolution of Topical Report Plant-13 Specific Action Items . . . . . . . . . . 154 14 Secure Development and Operational 15 Environment . . . . . . . . . . . . . . . 232 16 Adjourn . . . . . . . . . . . . . . . . . . . . 266 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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4 1 P-R-O-C-E-E-D-I-N-G-S 2 (8:36 a.m.)

3 MR. GOLLA: We can go ahead and get 4 started now. I'm Joe Golla. I'm the Project Manager 5 for ISG-06. The purpose of the meeting today is to 6 exercise and discuss how different sections of Draft 7 Revision 2 of ISG-06 related to the alternate review 8 process would be applied to example modifications 9 based on past applications. This is a Category 2 10 public meeting. All portions are open, and comments 11 from the public will be taken before today's lunch and 12 before adjournment both today and tomorrow.

13 We do have an attendance list over here.

14 We invite you to enter your information on that.

15 That'll become part of the public record, along with 16 the meeting summary. For folks on the phone, if you 17 would like your participation in the meeting reflected 18 in the attendance list, please send me an email. My 19 address is joe.Golla@nrc.gov.

20 And for folks in the room, in the event of 21 a fire alarm actuation, listen for the announcement 22 please. And if instructed to do so, make an orderly 23 exit out of the building the same way you came, turn 24 left out of the building, turn left on the first road 25 there, which is Marinelli, the road that this building NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 it on, and proceed down the hill. Go about one block, 2 just past the parking garage that's down here. And 3 the mustering point is on Citadel Avenue which is 4 right there.

5 Lunchtime, for the visitors, you can 6 retain your badge, retain your visitor's badge, exit 7 the building, go to lunch either across the street, 8 across Rockville Pike, or you can go to One White 9 Flint North if you want to go to the cafeteria there.

10 You will have to be screened again doing that. Also 11 on the way back, you'll have to be screened back in 12 again.

13 And with that, let's introduce ourselves.

14 Name and organization, starting to my left here.

15 MR. WATERS: Mike Waters, NRC.

16 MR. RAHN: David Rahn, NRC.

17 MR. STATTEL: Richard Stattel, NRC.

18 MR. DARBALI: Samir Darbali, NRC.

19 MR. HERB: Ray Herb, Southern Nuclear.

20 MR. NOVAK: Frank Novak, GE Hitachi.

21 MR. HARRELL: Dave Harrell, MPR Associates.

22 MS. GOLUB: Pareez Golub, Excel Services.

23 MR. ODESS-GILLET: Warren Odess-Gillett, 24 NEI.

25 MR. BURZYNSKI: Mark Burzynski, Rolls-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 Royce.

2 MR. DRAGOVICH: Steve Dragovich, Exelon.

3 MR. HOOTEN: Dave Hooten, Imperia 4 Engineering Partners.

5 MR. HANSON: Jerud Hanson, NEI.

6 MR. ARCHAMBO: Neil Archambo, Duke Energy.

7 MR. SCHRAGE: John Schrage, Entergy.

8 MR. ARNDT: Steven Arndt, NRC.

9 MS. BERGMAN: Jana Bergman, Curtis-Wright.

10 MR. GOLLA: Okay. Folks on the phone --

11 oh, folks on the phone, would you care to introduce 12 yourself? Do we have anyone on the phone that would 13 like to introduce themselves?

14 MR. CHUNG: Pong Chung from Research.

15 MR. GOLLA: Okay.

16 MR. CLARK: Kelley Clark, NRC.

17 MR. GOLLA: Okay.

18 MR. THOMAS: Brian Thomas from Research.

19 MR. GOLLA: Okay, quiet bunch on the 20 phone. All right. So Mike, as the ranking NRC 21 official here, would you like to make some opening 22 remarks?

23 MR. WATERS: Ranking sounds important.

24 Welcome on behalf of the Digital I&C NRC Steering 25 Committee. Welcome to this day-and-a-half tabletop.

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7 1 We will look forward to it. I'll let Samir highlight 2 some of the more specific goals, but of course, as Joe 3 mentioned, the goal of this meeting is to kind of test 4 out how an alternate review process would play out 5 with a hypothetical information.

6 I really appreciate all the information 7 the NEI industry working team put together and sent to 8 us ahead of time to look at, as well as to staff for 9 looking at it and additional information provided back 10 to them. I think it's the best we could have without 11 an actual pre-application, an actual design to test 12 the ISG-06 out.

13 I think Samir will note, again, the goal 14 is to see how it will play out. You know, any lessons 15 learned or insights may be incorporate into the 16 drafted ISG-06 before it is issued in July for a 17 formal public comment and of course, stakeholders an 18 issue of opportunity to comment on that version as 19 well. And again, our goal is to get it issued for 20 public comment the end of July. So this is really 21 important, an important step to go, and we know we 22 have more work even after this.

23 With that said, I'll turn over to Samir 24 for anything else, and then Pareez may have opening 25 remarks as well.

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8 1 MR. DARBALI: Thank you, Mike. I want to 2 thank the industry for being here, and for all the 3 work they've done to support these tabletop exercises.

4 I know this is a very high visibility activity, both 5 at the NRC and the industry side. We're trying to --

6 I think we've done a very good job in drafting the 7 ISG.

8 We are in the process of making some more 9 improvements to it, and hopefully this tabletop 10 exercise allows us to identify any other improvements 11 that we could make, and maybe identify some areas 12 outside of the ISG that we'd like to focus on. So we 13 look forward to the discussions today.

14 Some of the goals for today are just 15 basically to try to be on the same page and -- both 16 industry and NRC as far as how we interpret the ISG 17 information, and that it identifies and be submitted 18 as established for the evaluation, and then kind of 19 test out some of those types of scenarios.

20 MR. HANSON: This is Jerud Hanson with 21 NEI. I just want to make a couple of remarks before 22 I turn it over to Pareez for some additional comments 23 and recognition. First of all, I'd like to thank the 24 NRC staff, members of this team, as well as Pareez and 25 her entire MP4 team for the work that's been done on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 1 this.

2 This is something that's consistently 3 communicated to my management at NEI, that the MP4 and 4 ISG-6 effort continues to be a model for success for 5 the Digital I&C effort. We have continued to have 6 challenges with Digital I&C, but throughout some of 7 those other challenges, this one has continued to move 8 very smoothly. The objectives are continuing to be 9 met.

10 So I just want to recognize that. I want 11 to recognize the NRC team, and I want to recognize the 12 industry team and Pareez for all the good work that 13 has been done on this. We've been looking forward to 14 these tabletop meetings for quite some time. I'm 15 hoping and expecting, based on past performance, that 16 this is going to be a very productive and informative, 17 positive meeting today.

18 Looking forward to the public comment 19 meeting that's coming following this meeting, and 20 looking forward to our 2018 end objective is to get 21 this ISG published for us. So with that, I'm going to 22 turn it over to Pareez and say thank you.

23 MS. GOLUB: Thank you, Jerud. I 24 appreciate that. Thank you on behalf of the whole 25 team. Appreciate that. I'll just -- I guess, again, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 thank you very much to the NRC for hosting this 2 meeting and for agreeing to participate in this. We 3 really appreciate it. I think it's going to be 4 incredibly helpful to us.

5 I have a brief presentation that I think 6 is our first topic, which I can go through. And I 7 think that'll cover -- that'll mostly cover the 8 opening remarks. So again, thank you very much, and 9 thank you to the industry team as well for all the 10 work in putting together the tabletop material. This 11 was a several-month effort.

12 MR. GOLLA: Pareez, could I just interject 13 something? Folks on the phone, if you would please 14 mute your phone until you have a comment. Star-six 15 should mute it. Thank you.

16 MS. GOLUB: If I don't lean forward, can 17 you still hear me over this mic? Okay. So should I 18 start?

19 MR. GOLLA: Sure.

20 MS. GOLUB: So, we put together this 21 presentation just to provide an overview of the 22 tabletop purpose, the outcomes we're hoping to get.

23 I know we've shared this with the staff before, so I'm 24 not going to spend a lot of time going through it, and 25 we don't have a lot of additional folks in the room.

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11 1 So I think most people here probably know this.

2 But as Joe said, the purpose of the 3 tabletop is to pilot certain aspects of the alternate 4 review process, items that were unique or items that 5 during the drafting of ISG-06 Rev 2 were stickier 6 items for us to discuss. We want to make sure we have 7 a common understanding between the industry and the 8 NRC. It's one thing to see something written on 9 paper. It's another thing to actually try to use it.

10 Specifically, for the portions of the 11 alternate review process that we chose and have 12 prepared material for and submitted to you, we're 13 really looking for feedback on is this the right 14 information, the right scope, the right level of 15 detail.

16 Obviously we didn't provide enough 17 technical information to do a technical review, and 18 that was never the intent. Most of the technical 19 material is proprietary. So this is really about 20 scope, level of detail, and does it meet the intent of 21 the ISG-06 alternate review process how it is?

22 Next page. And then this is a big one for 23 the industry. So the ISG-06 obviously is not an 24 industry document, that's an NRC document, and what we 25 have -- what we are going to do throughout the rest of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 this year is to put together a companion document, an 2 industry-guidance document, for the alternate review 3 process. And our hope is that the tabletop material 4 will form the bulk of that guidance document.

5 So it's not really about how to do digital 6 engineering. There's other guidance documents for 7 that or how to do the LAR, again, there's other 8 guidance documents. But really, the intent is to 9 provide an example for the early adopters of the 10 alternate review process so they know what they're 11 shooting at, how to use the process. So that's one of 12 our big goals from this tabletop material, is to 13 review it and use it in that guidance document.

14 And I know we've talked about this before.

15 That guidance document, we're happy to share it with 16 the staff, not for formal review, but you know, we of 17 course welcome your feedback to see if we're hitting 18 the mark. Next page?

19 Okay. So this is a little bit different, 20 Samir, I think than what you said. And I'm actually 21 heartened by what you said. So our original intent 22 when we were talking about the tabletop was not that 23 we intended to change Rev 2 during the tabletop, but 24 you know, just that there may be some opportunities 25 for clarifications which could be part of the public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 comment period or for your consideration.

2 MR. DARBALI: Right, so let me just 3 clarify. So as I mentioned, right, we'll take notes 4 during the meeting, and I imagine the staff would take 5 any, as we are taking both -- making changes both 6 based on the ACRS comments and concurrence comments.

7 We can take some of the feedback that we 8 get, and we can make changes to the ISG. And I would 9 imagine the public comment period is where industry 10 would take feedback from the tabletop and provide 11 those comments.

12 MS. GOLUB: Yeah. That sounds great.

13 MR. DARBALI: But right. It's not a 14 drafting or writing session.

15 MS. GOLUB: Right. Right. But I 16 appreciate that, because if there are -- I mean, 17 especially fundamental misconceptions about what was 18 intended, it would be a great time to clarify it.

19 MS. ALVARADO: Sorry to interrupt, guys.

20 This is Rossnyev. Samir, you need to get closer to 21 the microphone. I couldn't hear anything you said.

22 MS. GOLUB: Samir or me?

23 MR. RAHN: Who were you --

24 MS. ALVARADO: Samir.

25 MR. RAHN: Ros, who couldn't you hear?

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14 1 MS. ALVARADO: You. They said that they 2 were going to put together the documents and guidance 3 for the new process, and then Samir responded, and 4 just try to get closer to the microphone.

5 MR. DARBALI: Okay. So Ros, I'll just 6 repeat what I was just saying. That we'll take any --

7 that the staff will take any feedback from this 8 tabletop meeting and incorporate any changes you feel 9 necessary in the version that's going to go out for 10 public comment, and any comments that industry might 11 have based on these tabletop exercises, and provide 12 those during the public comment period. But this 13 meeting itself is not a writing session itself.

14 MS. GOLUB: Okay. And the next bullet is 15 -- and we've talked about this already. The tabletop 16 material may be included in the industry guidance 17 document as examples. Next slide?

18 So the basis for the tabletop material, we 19 took the nonproprietary, publically-available material 20 from the Diablo Canyon LAR, SER, the Hope Creek PRNMS 21 LAR and SER, Oconee LAR and SER, and then for some of 22 the material that was presented, it did, of course, 23 touch on the Tricon, NUMAC, ALS, and Spinline topical 24 reports and SERs to greater or lesser extents. All of 25 the material, of course, is nonproprietary. Next NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 slide.

2 Yeah, okay. And so this is now the 3 tabletop content. Samir, were you going to go through 4 the agenda, or shall I just cover the tabletop content 5 here? It's not in order, but I could certainly just 6 cover the material.

7 MR. DARBALI: You can go through it.

8 MS. GOLUB: Go through it? Okay. So for 9 the tabletop content, we have a presentation that's 10 the lessons learned from Oconee and this is something 11 that industry is proposing. It's a table called the 12 Safety Function Summary Table. And Mark's actually 13 going to talk about that right after this 14 presentation. Next slide.

15 We have a vendor oversight plan draft LAR 16 description, or LAR description, and this is from 17 Section C221 of ISG-06 Rev 2. And again, this is 18 specific to the alternate review process. We have the 19 alternate review process sample SER inspection items.

20 So this is the -- in particular, the group of 21 inspection items that would be new for the alternate 22 review process.

23 The sample licensee commitments in 24 consideration of the early license amendment issuance, 25 again, unique to the alternate review process. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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16 1 those last two items were prepared by the NRC for the 2 tabletop.

3 We have resolution of topical report 4 PSAIs, plant-specific action items. A presentation 5 and LAR statements. Did we submit the LAR statements, 6 too? I can't remember. But we can go through those.

7 Next slide?

8 We have new system architecture. And this 9 is the D.2.2, again, a new section which may end up 10 being applicable to more than alternate review, 11 depending on how NRC reviews comments from ACRS. We 12 have a human factors engineering section. A small 13 portion for D.4, I&C system development processes, and 14 for D.8, the SDOE LAR submittal material. Next slide?

15 And then the last item is the pre-16 application coordination meeting presentation. So 17 this presentation is like the phase zero presentation 18 of the Rev 1 ISG-06 guidance, but both those sections 19 for Tier 1, 2, 3, and for the AR process were enhanced 20 to add additional material, so that's the intent of 21 this presentation. Next slide?

22 Okay. So these are the outcomes that 23 we're hoping come from this tabletop discussion. That 24 the level of detail that was provided in the material 25 is sufficient for NRC to reach a safety conclusion.

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17 1 In particular, if there is information missing or 2 unnecessary information, we would love to know what 3 that is so we can amend that material before it goes 4 into the guidance document.

5 Vendor technical oversight, this is kind 6 of a big change, one that I know we've discussed at 7 length and ties into the inspection process. So this 8 is -- vendor technical oversight, what we mean is 9 licensee oversight of the vendor and how the licensees 10 are going to handle that scope and intent.

11 So as you guys know, the next item on our 12 sort of bigger-picture MP4A agenda is this NRC 13 industry workshop on inspection. We're talking about 14 doing it in mid-September. And so we're hoping from 15 this tabletop that we -- this helps to maybe highlight 16 what the issues are, industry's concerns, so we can 17 capture some of that so that when we get to that 18 workshop, we already know what we're going to be 19 talking about.

20 So we've got a lot of discussions on our 21 side, and it's going to come up when we get to the 22 sample inspection items and some of the other areas.

23 So we're hoping this helps to clarify what the 24 concerns are that we can discuss them.

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18 1 commitments and licensing conditions. Again, right 2 now, we have commitments that we're making per ISG-06 3 Rev 2, and we're hoping to get some feedback from the 4 staff on which of those commitments may become 5 conditions or what are the criteria that would lead to 6 them being conditions, that type of thing.

7 And then of course, we want to inform 8 industry guidance. So this -- you know, this would be 9 not just feedback on the actual tabletop material, but 10 even feedback on the ISG interpretations, any kind of 11 clarifying guidance. We want to try to capture that 12 and put that into the industry guidance document.

13 MR. DARBALI: Thank you, Pareez. So, to 14 touch on some of the outcomes that you highlighted, we 15 have a very full agenda, so we'll try to keep on track 16 as far as the time, which means we may not be able to 17 complete each of the activities.

18 But I would imagine that at least it 19 allows us to identify -- we already talked about a 20 September workshop on inspection activities, and 21 looking at the material that was provided in 22 preparation for the tabletop, I believe we could have 23 a separate meeting or workshop or even tie it to that 24 September workshop, a discussion on the conditions 25 recommended.

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19 1 I think we could further elaborate on 2 that. I know the focus today is the conditions, so we 3 may not -- we'll touch on some conditions, but I think 4 to have a really in-depth discussion on conditions, we 5 should have a future meeting on that. And as we go 6 along, we can identify new topics.

7 MS. GOLUB: Okay, yeah, that sounds good, 8 Samir. And I guess you know, just along the lines of 9 in the interest of time and efficiency, the only full-10 on presentation we intend to make, aside from the one 11 I just did, would be Mark on the lessons learned, and 12 how the lessons learned, at least from industry's 13 perspective, the ISG-06 alternate review process 14 really addresses. So that's going to be a 15 presentation, and then the Safety Function Summary 16 Table.

17 But outside of that, we're hoping that as 18 we go through the remaining material, even material 19 that appears to be a presentation, that we're not 20 going to present it as such. That our intent is that 21 based on NRC feedback, we'll just cover those items 22 and make the assumption that the rest of it you guys 23 concur, it hits the target.

24 MR. DARBALI: Right. And I do want to 25 make it clear in my correcting. So this is a -- it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 a tabletop exercise, but it's not a precedent-setting 2 decision-making meeting.

3 MS. GOLUB: That's right. Yeah, 4 understood.

5 MR. DARBALI: So, I think we are a little 6 bit ahead of time.

7 MS. GOLUB: Yay.

8 MR. DARBALI: So we can move on to the 9 next item in the agenda, which is the lessons learned, 10 and we'll turn that over to Mark.

11 MR. BURZYNSKI: Thank you. The purpose of 12 this presentation is to just summarize the work we did 13 in validating that ISG-06 solves some of the problems 14 that we saw with various pilot experiences where the 15 reviews -- the review process or review schedule was 16 not as efficient as it could be.

17 It's not the suggested. It's the 18 technical aspect. It's just knowing what information 19 is needed and making sure it's given in the right 20 times to support the decision-making process. So we 21 took the opportunity to go look at what were those 22 experiences? And so if you'll go to the next slide 23 for me.

24 We wanted to capture the pilot 25 experiences. And we looked at Diablo Canyon, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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21 1 looked at Oconee. We also looked at Wolf Creek, 2 although we found not much there. We looked at Hope 3 Creek. So we tried to capture the things that were 4 relevant to this exercise.

5 We'll show you how the key lessons learned 6 were incorporated into the new ISG-06 guidance. And 7 we'll also identify additional lessons learned that 8 we'll be elaborating on in the industry guidance 9 document, the companion how-to guide for utilities 10 that Pareez mentioned. So that's the goal for my 11 presentation, is to give you this information. Next 12 slide.

13 So the first pilot experience we looked at 14 was Diablo Canyon. And what I did there was I went to 15 some public meeting information where this information 16 was presented and captured it and said, what was 17 related to information transfer and completeness and 18 timing that we could make sure if we identified a new 19 guidance that said, here's the information that's 20 needed, that we captured the right set.

21 And one of the examples of the lessons 22 learned was the role of the architecture, and in 23 particular, how it affected the test requirements.

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22 1 requirements weren't as elaborated as well as they 2 could be.

3 And as a result, that led to changes in 4 the test program and the test process, and actually 5 some architecture changes later in the process. So 6 our goal would be, get that information in earlier so 7 that you can uncover those kind of issues sooner in 8 the process rather than later.

9 There was also some lessons learned 10 regarding allocation of system functions. In the case 11 of Diablo Canyon, they allocated protection functions 12 to two subsystems, and that wasn't always clear in 13 their documents and in their license amendment and led 14 to some problems where not all those requirements were 15 properly allocated and accounted for, and that was 16 caught late in an audit. So we'd like to do better 17 with that up front.

18 There were some lessons learned regarding 19 the importance of capturing the maintenance 20 requirements, even though they don't really connect 21 to, let's say, safety decisions. How you go about the 22 maintenance may influence some of the decisions that 23 you're making about the design. And so we thought it 24 was important to capture that earlier in the process 25 as part of the submittal to avoid changes later in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 process when those requirements get introduced.

2 And then there's the lessons learned with 3 how do you communicate information to various parties 4 that have different language meaning, understanding of 5 things. And in this case, there was some system 6 functional requirements that were not commonly 7 understood between the utility, the designers, and the 8 V&V personnel.

9 Everybody was competent, everybody works 10 within their own paradigms, but what the utility was 11 thinking something meant and what the V&V person 12 interpreted to mean weren't always the same. So we 13 thought, we could do better and making some of those 14 kinds of things clearer and provide some tools. So 15 I'll show you how we'll capture this. Next slide.

16 In looking that Oconee project, even 17 though it wasn't a formal pilot project for ISG-06, it 18 was kind of the genesis for ISG-06. But there, there 19 were lessons learned regarding the architecture again.

20 Architecture decisions that were related to function 21 allocation and the design of the echelons.

22 There was the use of the inner-channel 23 communication and the service-unit connections. So 24 the things that you see here, those all affected the 25 review, but the model for submitting an LAR didn't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 really elaborate on these points. It jumped right 2 into the software process without understanding the 3 system requirements for it.

4 And there were some lessons learned about 5 vendor oversight. I think the simplest way to 6 describe that is the difference between vendor 7 oversight for non-digital projects performed by 8 utilities and the expectations for vendor oversight 9 for digital projects.

10 Some of that's captured with what does BTP 11 7-14 thinking mean to vendor oversight that's not 12 present in other projects? And so we've got -- we had 13 some early indications there that that's not well 14 understood, and we're continuing to refine those, that 15 thinking today. So that's what we've learned from 16 Oconee and when after showing your address now.

17 And then there were some insights from the 18 NRC presentation.

19 MS. ALVARADO: Can people on the phone 20 please mute?

21 MR. THOMAS: Yeah, there's a major problem 22 with cutting out. Some interference. Perhaps the mic 23 is being moved around or something. It keeps being 24 interrupted.

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25 1 Brian. It's somebody on the phone that's causing the 2 noise.

3 MR. GOLLA: So, folks on the phone, star-4 six please to mute if you would. Thank you.

5 MR. BURZYNSKI: Okay. And the key insight 6 that we took away from the NRC presentation at the 7 Diablo Canyon lesson learned meeting was that there 8 wasn't a clear correlation between the information 9 licensees were required to provide in ISG-06 at the 10 time, and the evaluations NRC performs. So we took 11 that on to say have we sharpened that up as well? So 12 these were the opportunities, and now I'd like to go 13 to the next slide and tell you how I think we've 14 captured that in the revised guidance.

15 So, first, there's an expanded discussion 16 on licensee oversight of vendors. It's located in 17 three sections. It goes from high-level expectation 18 that you should include this in the LAR to a 19 refinement of what you should be doing as far as that 20 vendor oversight in looking at vendors' processes, 21 vendors' technical products, and how you treat later-22 stage activities that occur after the approval of the 23 LAR.

24 And so it outlines that. And we think 25 that that's moving us in the right direction of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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26 1 getting on the same page. We'll have some more 2 discussion today on it to make sure we're there and we 3 can meet those expectations and then also communicate 4 them to the utility audience that we'll need to know 5 what's different here than what they normally do for 6 vendor oversight.

7 But this gets at the lessons learned from 8 the Oconee project in particular.

9 MR. ODESS-GILLETT: We're still hearing 10 some noise from somebody on the phone shuffling 11 something. If everyone could please put their phones 12 on mute.

13 MR. BURZYNSKI: Okay. The next important 14 change that we've made is there's an expanded 15 discussion on the expectations for technical 16 information to be provided related to system 17 architecture features, system interfaces, and then the 18 fundamental design principles. And this is covered in 19 sections on architecture, sections on new features, 20 sections on interfaces, and on the fundamental design 21 principles.

22 This gets at, I think, a number of the key 23 lessons learned. And first, if we describe an 24 architecture sufficiently well, we identify the 25 interfaces. We identify why the interfaces exist, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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27 1 what's the purpose. And then discuss how those 2 interfaces are safe. We think we'll have a better 3 flow than jumping into the discussion of how they're 4 safe without understanding whether they're -- whether 5 we know all of them or why they're there.

6 We also think that this organization helps 7 us get at the lesson learned of submitting information 8 without clearly linking it to the regulatory 9 expectations. So by taking the architecture features 10 and then tying them to the fundamental safety 11 principals, we think we make that connection very 12 clear.

13 This information is used for this purpose.

14 And so we'll have a better narrative describing what 15 we're doing and why it's safe and how it connects to 16 the regulatory requirements associated with it. We 17 think this is a very important improvement in the new 18 guidance. Okay, next slide, please.

19 There's also an expanded discussion on the 20 expectations for technical information related to 21 system requirements associated with function 22 allocation. As I mentioned in two of the examples, 23 allocations of functions were really something that 24 wasn't well-described but became an issue that needed 25 to be addressed.

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28 1 But we went through a process of discovery 2 of, oh, that's an issue to be addressed, and then 3 another process of discovery of what information do 4 you need. And we think it covers both a macro level.

5 In the case of Oconee, it was function allocation at 6 the echelon level. And in the case of Diablo Canyon, 7 it was function allocation within subsystems within a 8 system.

9 So we have clear guidance now to talk 10 about function allocation. This was something we 11 learned from looking at the IEC 61513 standard for 12 nuclear category A system designs where they have a 13 very clear step in their process to perform this 14 function allocation, hardware and software, and 15 document it. So we kind of learned from that and 16 built that into what we put for the guidance here.

17 There's also expanded discussion on the 18 expectations to provide technical information related 19 to maintenance activities so that we are working to 20 identify those requirements, those interfaces, and 21 those system uses in there. In the case where there's 22 architecture features, you may have maintenance 23 workstation connections. There may be requirements 24 for the tasks to be performed or the functionality 25 that's needed, both from a safety standpoint or from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 1 a user standpoint. And you can capture that.

2 And then finally, we touch on in the last 3 section listed up there, we talk about the user 4 interface and whether there's any HSI involved or that 5 sort of thing so that we build in a complete picture.

6 Think about the maintenance from a hardware interface 7 functionality requirement, and then the operator or 8 technician interfaces.

9 Next slide, please. I'm going to shift 10 gears now and talk about what additional guidance 11 we're going to be putting in the industry companion 12 guidance document. So this is a case where the ISG-06 13 information is useful the way it is right now, but 14 there may be some variations on how a utility might 15 apply it. And the first one to talk about there is 16 how to address application software development. And 17 our industry guidance will look at three different 18 cases.

19 The ISG-06 talks about the information 20 that is needed in a general sense, but from a user 21 standpoint, in preparing a LAR, you may have a 22 preapproved software program manual, and that would be 23 represented in the LAR one way. You may have an 24 application development process that's embedded in a 25 platform topical, and you may need to address it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 through the application-specific action items.

2 Or you may have a case where it wasn't 3 addressed and you need to describe the development 4 process in summary into your LAR. So we thought that 5 that would be useful guidance to the users to know how 6 to address these three different cases.

7 So that will help us. And you'll be 8 seeing those documents as we work through those. We 9 appreciate, Samir, your interest in understanding this 10 part of the project and making sure it meets your 11 expectations and needs.

12 We also talked about the vendor oversight.

13 There will be some expanded guidance there on how to 14 do this vendor oversight. What's the expectation?

15 What might be some tools, techniques, methodologies, 16 and what's the purpose?

17 What are you trying to accomplish with it, 18 so that we can develop vendor oversight plans that 19 capture the lessons learned and meet the expectations 20 that we identified through the Oconee effort 21 initially, but also now with the new look, with the 22 alternate review process, the new piece which is we're 23 moving the timeline forward as to when the LAR 24 approves, to there's more activities that are post-LAR 25 that need to be addressed under this program.

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31 1 So we want to be sure we're clear on all 2 of that and that we can do it well. So that'll be an 3 element of the industry guidance.

4 And then the next slide, we talked about 5 the document, the Safety Function Summary Table. I 6 still don't have that one down, because they've always 7 referred to it as the Mark table, and I haven't yet 8 copyrighted that, so we're going to use the formal 9 name, Safety Function Summary Table. But this is a 10 case where in IEEE 603, Clause 4, there's some 11 discussion about the design basis.

12 And we've struggled on LARs as to what do 13 you have to address there? Is it everything? Is it 14 just what's changed? Is it just new functions? And 15 what we finally decided is that there's something 16 there for everybody. I say it that way because if you 17 organize this information well, you can understand the 18 whole design basis in a snapshot, which will help 19 utilities with their internal interface reviews 20 between, let's say, safety analysis, operations, I&C, 21 to say what's going on.

22 It will facilitate communication with the 23 vendors as far as the functional requirements for the 24 system, and where changes are occurring. It will 25 support V&V because they now have a nice, clear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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32 1 picture of requirements that are interconnected that 2 trace through the system. It will help with 3 oversight, because you can then, if your oversight 4 activities is looking to follow that something's done 5 or done completely, this table can help you organize 6 that thinking.

7 And it will help the regulatory reviews, 8 because it will tell you what are the key licensing 9 basis for the system and identify what's changing with 10 this LAR so that you can then focus on, oh, that's one 11 I just need to see as implemented. This is another 12 one I need to understand the change as well as how 13 it's implemented.

14 And we've suggested a number of parameters 15 that are there that I listed. You could add maybe a 16 few more. One I didn't include was a function 17 allocation column. So in the case of the Diablo, you 18 could have added a column that says this is 19 implemented in subsystem A and this one is implemented 20 subsystem B. But for the generic case, I didn't show 21 that example.

22 And you've seen on the separate worksheet 23 that we put together some examples where we put 24 together for examples, one where there's a requirement 25 or a safety function requirement where there's no NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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33 1 changes by the LAR.

2 It's just being implemented new 3 technology, and it's a Chapter 15 protection event, so 4 it has everything from what event all the way to a 5 response time, and then we contrasted that with a 6 second example of a protection feature that has 7 everything put a Chapter 15 event.

8 That's usually for the lower-power cases 9 where there's not necessarily an explicit requirement 10 for the response time. So we showed those examples on 11 the handout table as case where there's no change, and 12 then we showed two examples, examples three and four, 13 where there's some changes.

14 In the case, the first one, it was the 15 Oconee example, and the only change is the 16 architecture for the SFAS went from two out of three 17 logic to a redundant two out of three logic, and we 18 showed that with bold italics. And then the fourth 19 example is one we extracted from Hope Creek where it 20 was a new function that was added. And you could see 21 all the new items there are added in there.

22 And we think if we can organize 23 information in the LAR like that, it helps you know 24 what's changed, what's not changed, and one-stop 25 shopping as to what are all the requirements from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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34 1 safety analysis Chapter 15 and how they're implemented 2 in the I&C. They'll facilitate the same kind of 3 activities on the utility side and on the vendor side.

4 So we think that that will just help 5 people work through that and get at maybe the question 6 of what does software safety look like? It might look 7 like this table. These are all the safety 8 requirements that need to be captured and maintained.

9 So those were the thoughts that we had for both how we 10 captured lessons learned on ISG-06 and the development 11 of some companion industry guidance.

12 And I'll go to the summary slide. So I 13 think what I've shown you is that we did a pretty good 14 job at addressing the lessons learned that were out 15 there, and so that means not only have we made the 16 document better, but we made it better by correcting 17 some known weaknesses. So, that's good.

18 The new guidance now has direct 19 correlation between the information the utility should 20 provide and the NRC regulatory evaluations. We think 21 that promotes efficiency and helps us on our end of 22 having the right kind of laser focus on the critical 23 issues instead of the hunt and peck process that we 24 used sometimes in the past.

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35 1 underway will help utilities in areas where they have 2 some choices or some options to produce the right 3 variation in the LAR and give you the information to 4 support your regulatory reviews. Thank you.

5 MR. DARBALI: Thank you, Mark. A quick 6 question on the industry guidance. Are you creating 7 that to be applicable to both the alternate review 8 process and the Tier process? Because I see a lot of 9 good ideas that you're implementing, and a lot of that 10 information organization would be useful still for a 11 Tier LAR.

12 MS. GOLUB: Yes. Sorry. The intent was 13 really for the alternate review process, but we 14 recognize that a lot of the information is applicable 15 to both. So even things like the pre-application 16 coordination meeting presentation, it's essentially 17 the same guidance for a phase zero meeting 18 presentation. So yes, I think a lot of it is 19 applicable to both the -- anything related to 20 architecture, any of that stuff.

21 And then Mark's -- of course, the Mark 22 table -- or, I'm sorry, the Safety Function Summary 23 Table -- I'm struggling with that myself -- the Safety 24 Function Summary Table we believe will be helpful in 25 any of the processes in ISG-06 Rev 2.

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36 1 And you know, I just want to -- since I 2 have the mic, I just want to reinforce what Mark said.

3 That the reason we wanted to present this to you at 4 the beginning at this tabletop is to -- really to 5 thank you for your consideration of industry input in 6 these different areas and the lessons learned that 7 came out of some of those early experiences. As you 8 know, industry wants to do a lot more of this work, 9 needs to do this, needs to modernize their protection 10 systems.

11 And so we really want to thank the NRC, 12 especially the team that worked on this with us to 13 thank you for listening to our input, for considering 14 it. And we would love feedback, especially on the 15 safety function summary table, or any part of Mark's 16 presentation.

17 We'd really love some feedback on that, 18 because we're hoping that you also recognize that this 19 may help to alleviate some of those questions that 20 came up on those submittals, you know? Negate some of 21 the confusion that arose because there was not clear 22 understanding of the design basis going in.

23 MR. DARBALI: Right. I was just going to 24 say that we are ahead of time, so we could kind of go 25 through those examples really quick.

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37 1 MR. BURZYNSKI: Okay, so the challenge we 2 have is it's a long piece of paper. And of course, 3 you can organize this table in different ways. I know 4 at one project I worked on, we broke it into three 5 tables. You know, the first four columns were in one 6 table, then to fit formatting of page size.

7 But the idea was to take an FSAR event, 8 because when you work with your safety analysis people 9 and we work with ours, it's what event drives this, 10 where do the fundamental requirements come from? So 11 we wanted to capture that. What is the trip that's 12 credited for it? In this case, it was picked a 13 nuclear over power. What are the variables, the 14 ranges, the nominal, the analytical set point, the 15 number of channels, the type of logic?

16 In this case, it was two out of four 17 increasing. What does it do? In this case, it leads 18 to a reactor trip. Are there any interlocks or 19 operating bypasses? And if there is, what's the 20 nature of their logic? So in this case, it's 21 something that de-energizes on decreasing power, so 22 when you go below the low range of it, it takes itself 23 out of service.

24 And a little description of what that 25 functionality is for, the bypass functionality. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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38 1 then the response time that's assumed in the event.

2 So you can quickly look at a function and go, I know 3 what event it is, all the way through.

4 And if you were looking at it and needed 5 to talk to people, you could know where the 6 information is, who to talk to. If you're just trying 7 to make sure this information flows and is all 8 captured, it's a nice guide for you there.

9 As I mentioned, the second example is a 10 case where they have a low-power feature. It's not 11 really tied to a Chapter 15 in their safety analysis.

12 So it has everything except a response time, because 13 the response times are always linked to the safety 14 analysis. So in some cases, you have information that 15 way, but you might find that the factor acceptance 16 test or validation test is not checking response time 17 for that one.

18 And if you wanted to know why, it's, well, 19 there's no initiating event that it's associated with.

20 So we think this would help kind of just communicate 21 in the case where there's no changes to the plant 22 design basis, just how it's implemented and how it 23 would be elaborated in the logic and that sort of 24 thing.

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39 1 examples three and four, we can start to show how you 2 could show something different. So the example three 3 is a case where we're looking at protection for loss 4 of coolant accident. It's the RCS low pressure. Same 5 kind of information shown.

6 What's different in this is under the 7 actuation logic, you can find some bold italics where 8 the word redundant is captured that way. It's a 9 little shorthand for the Oconee project. They changed 10 our architecture and made the SFAS two out of three 11 taken twice. And that's what changed in there. The 12 other aspects stayed the same.

13 It has a little more elaborate interlocks 14 and permissives because it does things going down and 15 it reinstates things going up. So that's kind of 16 captured there. And it's got a response time for the 17 total channel. So that's one where you could 18 illustrate a small change. If a set point was 19 changed, then you could show that, or something else.

20 And then the fourth example was where 21 there would be a more elaborate one. And this was 22 kind of drawn from Hope Creek. And we picked one of 23 the functionalities, the OPRM upscale, and just showed 24 that there's new functionality being added, and it's 25 -- so they're using existing instrumentation, so the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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40 1 variables and the ranges aren't changing, because 2 they're using existing instrumentation, but they're 3 adding new functionality.

4 The analytical limit is something that's 5 more complicated than the single set point, so you 6 have to go to the core operating limit report to find 7 it. The new functionality was four channel with two 8 out of four logic increasing. It leads to a reactor 9 trip. It has an arm permissive. And it has a 10 response time.

11 So this is one where there's new 12 functionality. You can clearly identify it and see 13 what's changing so you can focus your review, we could 14 focus our preparation of supporting justification for 15 all the changes, not spend time on looking at the 16 original instruments that were just using the signals 17 in a new way, for instance.

18 So that was the idea behind it to capture 19 this. The artwork, you know, could be represented 20 different ways. But we thought there was real value 21 in having a complete picture across disciplines and 22 highlighting what's changed and what hasn't changed in 23 a way that will let us make the right kind of 24 judgements of where to spend time and why we're 25 spending time on things. Yes, Dave?

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41 1 MR. RAHN: Mark, earlier we talked about 2 the need for understanding interfaces.

3 MR. BURZYNSKI: Yes.

4 MR. RAHN: And so would you anticipate in 5 this table, a table like this, you would insert where 6 there might be digital communications to other 7 channels or to other systems?

8 MR. BURZYNSKI: Not on this. Because this 9 is really just trying to get at the functionality 10 design basis for the algorithms. In the architecture 11 system that we'll be talking about later today, we 12 identify in there the architecture and all the 13 interfaces in it. What they're for, what type of 14 interface, what requirements apply, and ultimately how 15 those requirements are satisfied.

16 MR. RAHN: Okay.

17 MR. BURZYNSKI: So it's a similar idea of 18 making it very clear. It's just -- it's part of the 19 architecture discussion.

20 MR. RAHN: Okay. Thanks, Mark.

21 MR. STATTEL: Hey, Mark. Couple comments 22 on this. This looks very similar to the tables that 23 we've received from several applications, including 24 Oconee and Diablo Canyon, for the D.3 analysis because 25 you have, obviously, the ties back to your safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 1 evaluation and required functions.

2 I mean, honestly, if you add a couple more 3 columns like a backup or alternate means of providing 4 safety, this essentially becomes a basis for a D.3 5 analysis, right?

6 MR. BURZYNSKI: I agree that you could add 7 that part in. One thing that I noticed that was 8 different with the D.3 was this one captures some of 9 the electronic or the circuitry for the permissives 10 and interlocks.

11 MR. STATTEL: Right. Right, exactly.

12 MR. BURZYNSKI: But --

13 MR. STATTEL: There's a lot of overlap 14 there, but I think it's a very useful way to lay out 15 the data. This is typically the data that we somehow, 16 in the past, have derived from the documents provided.

17 But just my observation is that it looks very similar 18 to those tables that we've seen in D.3 analysis.

19 MR. BURZYNSKI: Yeah, because we're trying 20 to solve the same basic issue of communicating a big-21 picture in a nice, concise way. And you make a good 22 point of how to capture any of the D.3 insights that 23 are associated with it. Okay. Good. I will be going 24 to 11x17 paper though.

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43 1 know, that's the format for allowing that.

2 MR. BURZYNSKI: Well, thank you. That's 3 good feedback, Rich. Appreciate it.

4 MR. DARBALI: And I do want to say that 5 the guidance for creating that sort of thing would be 6 an industry guidance, not in the ISG.

7 MR. BURZYNSKI: Yes.

8 MR. DARBALI: It's tailored to meet the 9 ISG questions.

10 MR. BURZYNSKI: Yeah, the ISG speaks in a 11 general sense about clause four and identifying the 12 safety basis, and we take it as, you know, how would 13 you do that? And how could you also make it useful by 14 showing what's changed or what's not changed? If you 15 want, if you thought there was any benefit to 16 expanding the discussion ISG-06, that might be 17 helpful. But we didn't want to start reworking it.

18 MR. STATTEL: I'm also glad you included 19 the APRM example, because that was a new function that 20 was being added. The one thing with regard to the 21 others, you know, when I try to project this onto what 22 I anticipate for system upgrades at the operating 23 plants, typically, there wouldn't be any change in any 24 of these columns or any of this data.

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44 1 replacing analog instruments with digital instruments, 2 and they're really not looking to add new functions or 3 change their logic. I guess Oconee is an exception to 4 that to an extent. With this, I mean, would there be 5 some -- I'm just trying to think off the top of my 6 head here. Would there be some way to identify 7 changes to the data? I mean, is there a before and 8 after table, or --

9 MR. BURZYNSKI: Well, yeah, I guess you 10 could come up with that. What I simply tried to do 11 here was use the bold italics.

12 MR. STATTEL: Okay, so that's what 13 changed?

14 MR. BURZYNSKI: That's what changed.

15 MR. STATTEL: Okay. I understand what 16 you're saying then. Okay.

17 MR. BURZYNSKI: And if the whole line is 18 bold italics, it would be there. I didn't show where 19 we were deleting any functions. I didn't envision it, 20 but I guess that's a possibility that you could just 21 --

22 MS. GOLUB: Strike through.

23 MR. BURZYNSKI: Strike through that.

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45 1 about Section 4 of IEEE 603.

2 MR. BURZYNSKI: Yes.

3 MR. STATTEL: So, really, the way that 4 section is written, it's intended to be minimum design 5 requirements for a safety system. So we -- that's 6 kind of how we treat it. So when we perform our 7 evaluation, that's typically why you see a clause-by-8 clause comparison. Not necessarily a four, but we do 9 look at that. I'm not sure what you're suggesting.

10 Are you suggesting that we would only touch on areas 11 that are affected by the modification and not evaluate 12 other sections, or --

13 MR. BURZYNSKI: That's what I would think.

14 MR. STATTEL: Okay. Okay.

15 MR. BURZYNSKI: Because either -- there's 16 many aspects to that. You know, mock spatial 17 representation and that thing, but if it's -- that's 18 already there, we're not identifying any changes. We 19 wouldn't be preparing any justifications for that 20 information. But for any place where there is 21 something new, like a new function, you summarize it 22 in a table like this, but you have to go through all 23 the aspects of clause four in your analysis.

24 MR. STATTEL: Right.

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46 1 all those points in the table.

2 MR. STATTEL: So having done many of these 3 evaluations, I can tell you we really do go through 4 100 percent of those requirements, right? We don't 5 omit any of them. And if it's -- and in a lot of 6 cases, it's obvious that the modified system continues 7 to meet that design requirement and there's no need to 8 change that design requirement.

9 And a lot of times, that's what our 10 evaluation is, and we just pretty much confirm that, 11 okay? So yeah, I don't know how much room there is 12 for streamlining that process, because the evaluation 13 is still going to take place. I don't see any way 14 around that.

15 MS. GOLUB: Right. I don't think -- Mark, 16 you are not --

17 MR. BURZYNSKI: I'm suggesting, Rich, that 18 the information that you would get is this table.

19 MR. STATTEL: Okay.

20 MR. BURZYNSKI: And not something more.

21 So if you're going to do your look for the things that 22 haven't changed, to say does it still meet 603, this 23 would be the information you'd be getting and not some 24 other set.

25 MR. STATTEL: I see.

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47 1 MR. BURZYNSKI: If you think there's 2 another set that is needed, then that's something that 3 should be clearer.

4 MR. STATTEL: I'll have to give that some 5 thought probably later in the day, and we'll have some 6 discussion about that. Because oftentimes, you know, 7 I think the licensees don't recognize that the 8 evaluator doesn't have all of the knowledge of what 9 went into the original basis for the original system.

10 So all we're seeing -- we're -- our 11 blinders are on, so all we're seeing is the modified 12 system. So we don't have any real basis for 13 comparison other than what's written in the FSAR, the 14 plant's FSAR.

15 So oftentimes, we find ourselves digging 16 into the plant's FSAR or the tech specs or the tech 17 spec basis in order to kind of educate ourselves on 18 what the system design is and what the design basis 19 is, and then looking at what's in the proposed 20 modification and kind of evaluating, okay, nothing 21 here has changed what the original design requirement 22 is.

23 And you know, when I look at this table, 24 it's good. It's good information, it's laid out well, 25 it can become very obvious that, okay, there's no NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 1 change in the scaling, there's no change in the logic, 2 there's no change in this. But at the same time, we 3 would also look at your architecture documents or the 4 requirements, system requirements documents, which are 5 still part of ISG-06 to basically confirm that that 6 design basis is still valid, right?

7 MR. BURZYNSKI: Yes.

8 MR. STATTEL: It's a little bit 9 complicated. But yeah, the -- knowing what the change 10 is, is kind of key, and it's not always obvious to us, 11 because a lot of times, we'll just see this new system 12 being projected at us, and we don't -- we don't have 13 that, you know, old knowledge of the old system and 14 all the ins and outs of the old system all the time.

15 So we have to kind of figure that out.

16 MR. BURZYNSKI: Yeah, we agree with you.

17 And that was why I was trying to find a way to 18 illustrate.

19 MR. STATTEL: No, I think it's good. I'm 20 not really challenging what you're presenting here.

21 I think it's very good information, but I just wanted 22 to point out that.

23 MR. BURZYNSKI: Yes. Okay.

24 (Whereupon, the above-entitled matter went 25 off the record at 9:40 a.m.)

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49 1 MR. DARBALI: Anyone on the phone have a 2 question for Mark? Okay. If not -- Was there a 3 question?

4 MR. THOMAS: No questions.

5 MR. DARBALI: Thank you, Brian.

6 MR. THOMAS: This is Brian. No questions.

7 MR. DARBALI: Thank you, Brian. Okay, so 8 we are --

9 MR. WATERS: Samir, I have a question.

10 MR. DARBALI: Go ahead.

11 MR. WATERS: This is Mike Waters. Not so 12 much on the serving table, I think this is all great 13 information, I think it's very viable to help us to be 14 able provide insights for alternative applications we 15 get as well.

16 I really appreciate the key insights from 17 pilot experiences --

18 MS. GOLUB: Mike, can they hear you?

19 MR. DARBALI: I'm not sure that the phone 20 people can hear you.

21 MS. GOLUB: I don't know if you need that 22 spider mic to get --

23 MR. WATERS: Oh, this is not connected to 24 the phone?

25 MR. DARBALI: No.

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50 1 MR. WATERS: My question is, are these key 2 insights going to be tracked in your guidance document 3 or some sort of INPO guidance document like we've seen 4 in the past?

5 And, I guess a little bit programmatically 6 as we get to the lead plant and is there going to be 7 some sort of industry program to help track these 8 types of insights more specifically?

9 MS. GOLUB: So, let me just make sure I 10 understand what you're asking. So, I know a couple of 11 Mark's slides were insights for the -- Oh, thank you.

12 A couple of Mark's slides were insights for the 13 industry guidance document. So those will be included 14 in the industry guidance document.

15 And now, are you saying, as we move 16 forward, we go through a couple of plants, if there 17 are additional lessons learned --

18 MR. WATERS: Right, need of examples.

19 Right.

20 MS. GOLUB: -- maybe incorporated into, 21 that is the intent.

22 MR. WATERS: Okay.

23 MS. GOLUB: And frankly, our hope is that 24 once we get a couple of successful LARs through, those 25 LARs themselves will be the precedence that --

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51 1 MR. WATERS: Yes.

2 MS. GOLUB: -- subsequent licenses, these 3 are going to use versus going back to the tabletop 4 materials.

5 This is really just for the early 6 adopters. And then hopefully we've have the 7 precedence and those can serve for future licensees.

8 MR. WATERS: Okay, thanks.

9 MR. STATTEL: So, this is Rick Stattel 10 again. I do have a suggestion, and I hope to talk 11 about this later in the day as well.

12 When Industry creates this guidance 13 document, I would strongly suggest that it be tier-14 neutral, right?

15 And the reason I say that is, because a 16 lot of the lessons learned that you pointed out really 17 come down to misunderstandings and different 18 interpretations of what a Tier 1 means and what a Tier 19 2 means.

20 So, going back to the original Oconee 21 application, essentially, and obviously I wasn't at 22 the NRC when this first came through, but I did have 23 a lot of discussion with Paul Lozier about this and 24 the people who were involved then.

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52 1 this understanding, or this interpretation, that 2 because they were using an approved platform that 3 somehow they didn't need to provide a lot of oversight 4 on the vendor's processes because the NRC had already 5 reviewed those, and they simply could just use that 6 and it would be an easy evaluation, they could get an 7 easy approval. And obviously that turn out not to be 8 the case.

9 And I think, I almost regret that the 10 tiers are still there, because in all honesty, the 11 alternate review process can be any of the Tier 1, 12 Tier 2, Tier 3. In reality when you really think 13 about what those tiers mean.

14 And ultimately, we want to perform a 15 regulatory review and verify regulatory compliance.

16 And there is so much difference between the types of 17 platforms and the different types of LTR evaluations, 18 that you can't really put them all in the same bin.

19 And that's what we have kind of done here 20 with this ISG. I'm not suggesting we change the ISG 21 at this point in time, but I would like to see in the 22 future just dispel with this, you know, bidding things 23 and putting them in the tiers.

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53 1 what I'm saying?

2 MS. GOLUB: Yes, I think so. I mean, from 3 a, there is no difference between the tiers with the 4 alternate review process.

5 The only thing this Tier 3 assumes that 6 you don't have an approved topical report. The 7 alternate review process assumes you do have one. So 8 I think that would be the only difference.

9 But, I mean, I agree with you. I think a 10 lot of the material that would be in this guidance 11 document is tier-neutral.

12 And I'll just speak to the vendor 13 oversight. We had our team meeting yesterday, our 14 industry team meeting, and we probably spent three 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> talking about vendor oversight.

16 And when I say vendor oversight, I really 17 want to clarify. It's really licensee oversight of 18 the vendors.

19 MR. STATTEL: Of the vendors.

20 MS. GOLUB: And a lot of that was based on 21 the lessons learned from Oconee. We have a, Neil is 22 here from Duke and has some recollections of how that 23 went down.

24 And I think, you know, there is licensees 25 here. I know Steve, Ray, have put a lot of time into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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54 1 talking to their own vendor oversight organizations 2 and discussing on the licensee side, the industry 3 side, how to prepare licensees for doing much better 4 vendor oversight.

5 In making sure we have the right tools, 6 the right guidance. Is that speaking to your --

7 MR. STATTEL: Yes, I think that's a key 8 point. Another comment I noted here is that, the 9 vendor oversight plans, there is no one-size fits all.

10 So if you're preparing a vendor oversight 11 plan for a system that's using a Tricon system, that 12 would be very different than a vendor oversight plan 13 for, say an ALS system.

14 And they really need to be informed by the 15 LTR, by the topical report. And they need to be 16 definitely informed by the application specific items 17 list, which are unique for each topical report.

18 MS. GOLUB: Yes.

19 MR. STATTEL: So, there is just such a 20 wide variety of topical reports and the platforms 21 differ so much that I hate putting them all in the 22 bins, Tier 1, Tier 2, Tier 3, because it's really not 23 practical.

24 And the tier notion, in truth, in 25 practice, what we have learned is there is no such NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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55 1 thing as a true, pure Tier 1.

2 MS. GOLUB: Yes.

3 MR. STATTEL: Okay, it doesn't exist.

4 Even with Diablo Canyon, the Tricon tropical report 5 was approved within the first few months of the 6 application from Diablo Canyon coming in, and yet, by 7 the time we issued the license amendment there were 8 changes to that.

9 So, even that safety evaluation included 10 a delta review of the changes made to that platform.

11 And there's, it's just a reality, there are going to 12 be changes.

13 MS. GOLUB: Yes.

14 MR. STATTEL: Now, once you're in the Tier 15 2 category, you can be anything from very minor 16 changes to major changes. So that category covers 17 such a broad range its almost, it doesn't really make 18 any difference whether you put it in that category or 19 not.

20 And that's one of the reasons why in the 21 ISG-06 we removed the times out of that. Because, we 22 had put in there like a 12 month --

23 MS. GOLUB: Right.

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56 1 because of the wide range.

2 So, it gives the impression, from an 3 applicant, that, oh, because I'm a Tier 2 review I 4 will get my license amendment, an 18 month guarantee.

5 But that's not true at all, okay. Okay.

6 MS. GOLUB: Yes. And I think when we, I 7 know that that lesson learn about the fact that there 8 are changes that occurred to approval topical reports 9 all the time.

10 MR. STATTEL: Right.

11 MS. GOLUB: Especially, we have vendors 12 who are a part of the team. That's always been 13 acknowledge.

14 The alternate review process I thought 15 recognized that well. In the pre-application 16 coordination meeting, we need to show up with your 17 vendor and present those changes that have been made 18 since the approved topical report.

19 That when you address the PSAIs, when you 20 address differences between what's approved in the 21 current, in the alternate review process submittal, 22 that you're recognizing those changes.

23 MR. STATTEL: Yes.

24 MS. GOLUB: But I like what you said 25 about, I like what you said about emphasizing that in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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57 1 the industry guidance though about the fact that the, 2 you know, not all LTRs are, not all topical report 3 LTRs are created equal and that you really need to 4 look at those SERs to help inform the vendor 5 oversight.

6 I really like that. And I know Warren has 7 captured that so we'll include that.

8 MR. STATTEL: Okay, thank you.

9 MR. GOLLA: Okay, that discussion almost 10 put us right back on schedule, but we'll take the 11 opportunity, since we do have a few extra minutes, to 12 see if there are any members of the public on the 13 phone and whether or not they would ask a question or 14 make a comment?

15 Any members of the public? Okay, hearing 16 none, we've got a break scheduled. Folks, I presume 17 you would like to take a break at this time?

18 MS. GOLUB: Yes.

19 MR. GOLLA: Okay. So, 15 minutes. About 20 five after 10:00 come on back.

21 (Whereupon, the above-entitled matter went 22 off the record at 9:50 a.m. and resumed at 10:09 a.m.)

23 MR. GOLLA: Okay, so we're going to skip 24 ahead. One, we're going to look at tabletop examples.

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58 1 our transcriber that, folks, when you're speaking, if 2 you could identify yourself to make it easier for her.

3 With her job.

4 Okay, so who is speaking to this?

5 MS. GOLUB: Well, Joe, we're actually 6 going to go through the example here page-by-page.

7 MR. GOLLA: Okay.

8 MS. GOLUB: It's going to be by exception.

9 But Warren, Warren was kind enough to prepare this 10 section so he'll be speaking for industry.

11 MR. GOLLA: Oh, okay.

12 MR. ODESS-GILLERT: Well, I'd like to 13 start with, you know, these materials, this particular 14 example had been provided to this staff per their 15 review. And I guess I first would like, before going 16 -- Folks on the phone, can you please mute your phone?

17 Folks on the phone, can you please mute your phone?

18 Yes. All right. So, what I'd like to do 19 is to, first, before I go into any presentation or 20 talk on myself, is to get any NRC Staff feedback on 21 the material on this architecture example.

22 MR. DARBALI: Well, this is Samir. I 23 appreciate you highlighting the portions of the ISG 24 that each section addresses. So that's good, a good 25 discussion. I didn't have any comments on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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59 1 contents of it.

2 MR. ODESS-GILLERT: Rich, how about you?

3 No?

4 MR. DARBALI: Deanna, are you on the 5 phone?

6 MR. ODESS-GILLERT: All right, just one 7 more reminder folks. People on the phone, please 8 mute, we can hear you.

9 MS. ZHANG: Hello?

10 MR. DARBALI: Hi, Deanna?

11 MS. ZHANG: Yes, Deanna. Yes, I don't 12 have anything, what's ready.

13 I guess my only recommendation is that 14 this data communication is very much focused on Diablo 15 Canyon. And I know that the communication for Diablo 16 Canyon is relatively straightforward.

17 However, this isn't the case for Oconee.

18 So for the Oconee case, function is like secondary to 19 none, won't be the level of information that will need 20 to be provided in those cases. Which is different for 21 what was provided for Diablo Canyon.

22 MR. ODESS-GILLERT: Very good. Yes, good 23 feedback.

24 MR. DARBALI: And, again, that's an 25 overall comment that we'll see recurring when we talk NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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60 1 about human factors, engineering and other topics 2 where the examples are very straightforward.

3 Are not, you know, simple in a way that 4 the changes are not major. That leads the Staff, of 5 advantage, which you may not say it, but that leads 6 the Staff to think that Industry's intent is to use 7 the alternate review process for those straightforward 8 type mods.

9 The Industry guidance document would be 10 the place where you channel and seize. But if you're 11 thinking of making major fee changes or communication, 12 interface changes, the alternate review process may 13 not be the way that you can get all that information 14 to the Staff.

15 So, I'm just saying that, looking at the 16 examples, that's kind of the impression that I'm 17 seeing.

18 MR. ODESS-GILLERT: Probably we'd like to 19 dispel that impression.

20 MR. DARBALI: Okay.

21 MR. ODESS-GILLERT: Because, from our 22 point of view, we feel that the way the ISG-06 is 23 written for the architecture, that it directs the 24 licensee in developing into LAR, provide the necessary 25 details. Especially in the area of data NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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61 1 communications and compliance to ISG-04.

2 So, that was not our intent. And so --

3 MR. DARBALI: Understood. And I 4 understand that if you had to take a very complex 5 example we would be here all day, so I understand.

6 MR. ODESS-GILLERT: Okay.

7 MS. GOLUB: I have a, I guess I have a 8 quick question. So, you don't have any, you don't 9 have any questions on the architecture section, which 10 is fine.

11 But I guess I want to make sure I 12 understand what that means. So for us, again, looking 13 to the intent of the tabletop, we want to make sure 14 that we provided the right scope, level of detail.

15 Again, understanding this is just a 16 tabletop exercise without all of the intendant 17 technical detail behind it.

18 So, not having comments means that we 19 essentially hit the mark? Is that how we interpret 20 that? I'm Pareez, sorry.

21 MR. STATTEL: Well, from my perspective, 22 yes. Obviously I'm pretty familiar with the Diablo 23 Canyon application, so, all I would say is, like Samir 24 mentioned, Diablo Canyon really did go out of their 25 way not to insert cross-channel communications.

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62 1 They basically put walls between divisions 2 and they limited the connectivity to non-safety 3 systems. And they don't, for example, they have a 4 separate maintenance workstation for each division.

5 Right.

6 So these were all areas of contention for 7 Oconee, right. And Diablo Canyon basically choose not 8 to challenge those areas.

9 So, those parts of that evaluation, and 10 they're reflected in this table top exercise, they 11 were never contentious, right, so there was nothing 12 really, when you pick those up and apply them to the 13 alternate review process, you can see at the 14 architecture level that there is no cross-15 communications between divisions.

16 MS. GOLUB: Yes.

17 MR. STATTEL: Okay. And when we presented 18 this to ACRS, we had a similar response from them.

19 They essentially had, okay, no comments.

20 MS. GOLUB: Right.

21 MR. STATTEL: There's nothing there to 22 discuss that. I mean, we can talk a little bit about 23 how an application that does use cross-channel 24 communication, because we're certainly not prohibiting 25 that and we're not making that a condition of using NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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63 1 the alternate process. The review process.

2 So, we can talk about what that would 3 entail.

4 MS. GOLUB: So, before we do that, I guess 5 I just want to make sure that, I know when Warren went 6 through this he highlighted the sections.

7 You know, you cut and paste essentially on 8 your Diablo Canyon application, which was very big.

9 Cut and paste different sections to try to align them 10 to the different sections of the alternate review 11 process guidance of Section D.2.

12 So, again, just to be clear, it sounds 13 like what was put together hit the mark of, in your 14 mind, what was the requirement for that section of 15 D.2. And the information presented essentially hit 16 the mark, that's what I'm trying to get at.

17 MR. STATTEL: Yes.

18 MS. GOLUB: And it sounds like this was a 19 simple example so maybe it was a little bit easier to 20 hit it, but --

21 MR. STATTEL: When we performed the Diablo 22 Canyon application we didn't have an architecture 23 document, but we had a completed design. So, we had 24 the high-level block diagram, they were included in 25 the application.

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64 1 And we had detailed design, so we had the 2 detailed design description. So we were able to piece 3 together what we needed architecture wise.

4 And I think that shows, like, we use 5 several diagrams that the NRC created, they were 6 essentially architecture diagram and we used those to 7 present to the ACRS in order to project those concepts 8 for their understanding.

9 They don't show up, those particular 10 diagrams, I don't think they showed up in the safety 11 evaluation and they were not in the license amendment.

12 But we used those for presentation purposes.

13 So, I think that's the type of information 14 that that Section D.2 would provide. And obviously 15 that worked, you know. It kind of helped people to 16 understand what the architectures were.

17 And I think that's good. I think going 18 forward with that, those concepts, it would help us to 19 understand the system. And particularly for a simple 20 system like this where you're not, you don't have the 21 communications that would be challenging.

22 And for an alternate review process, I 23 don't think that would be difficult to reach the 24 safety, reach the license amendment issuance with 25 that.

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65 1 I think tomorrow's discussion, when we 2 talk about the conditions and commitments, I think 3 that's a little bit different. I think that's going 4 to be a little bit more challenging.

5 And we can talk a little bit more about 6 what we perform during the audits. What activities we 7 performed during the audit and what our expectations 8 for vendor oversight, by the licensee, would be.

9 MS. GOLUB: Oh, good.

10 MR. STATTEL: But I think that's more of 11 a discussion topic for tomorrow.

12 MS. GOLUB: Good. Yes, I look forward to 13 that.

14 MR. ODESS-GILLERT: So, the goal was to 15 get NRC feedback on the level of detail. So, I don't 16 know, Pareez, if you think it's appropriate to maybe 17 hear from the Staff on if there was inter-channel 18 communication, what additional detail --

19 MS. GOLUB: We have the time so we might 20 as well.

21 MR. ODESS-GILLERT: Yes.

22 MS. GOLUB: Yes.

23 MR. STATTEL: Yes, I think it's a good 24 discussion. I've been thinking a little bit about 25 that.

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66 1 So, in a typical topical report, when we 2 evaluate a topical report, we will do a ISG-04 3 evaluation. And again, there is no two are alike, but 4 they are similar evaluations. And we evaluate.

5 What we try to do is identify any 6 communication pathways that could be used by the 7 platform when implementing a system design. And so, 8 typical questions we'll ask to the vendors are, well, 9 if a plant wants to send data to a plant computer, how 10 would they do that, what interface would they do.

11 And sometimes the answer could be, there 12 could be three different answers, right. Or other 13 times it might be, this is the way it would be done.

14 And we try to identify that, and to the 15 best of our ability, evaluate that against the ISG-04 16 criteria, right?

17 I, I'll just say this, I keep track of all 18 of the topical reports that we have approved and I 19 know what each of the topical report position is or 20 what the decision was, for each point within ISG-04.

21 And I keep them side-by-side for comparison.

22 So, I have that information, I keep that 23 because it's been useful to me. It's not public or 24 anything like that, but it's useful to me because it 25 helps us to be consistent with our treatment of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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67 1 platforms, okay.

2 Some platforms essentially, maybe 90 3 percent of the ISG-04 points are ASAIs, right? Now, 4 even though these are application specific action 5 items, I want to mention that it doesn't mean we don't 6 evaluate them.

7 We're, essentially at the license topical 8 review stage, we're evaluating the systems capability 9 of meeting the criteria in the ISG-04. We can't make 10 a safety conclusion because it's going to be 11 application dependent, but in all those write-ups 12 you'll see, typically our conclusion is that it can be 13 configured, this communication link can be configured 14 to enforce one-way communications, for example, to be 15 used as a plant computer interface link. Or cross-16 channel communication link.

17 So, what I would expect, in the 18 architecture document, number one, identify what links 19 are being used for cross-channel communication, what 20 links are being used to communicate established 21 communication between non-safety systems and the 22 safety system, identify what interfaces, specific 23 interfaces that are discussed in the licensed topical, 24 the referenced topical report, the referenced 25 platform.

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68 1 So for example, I've reviewed so many of 2 these that they all have different names for different 3 links, right. So, ALS had the certain links for 4 configuration.

5 MR. ODESS-GILLERT: Tab. The tab?

6 MR. STATTEL: Right. And those are 7 described in pretty good detail in the topical report.

8 And we evaluated those.

9 So, what I would be looking for in the 10 application is, oh, are those the interfaces that they 11 use and was it used in a way that we had anticipated 12 when we performed topical report evaluation.

13 And then I read the topical report 14 evaluation and it will typically say, here is how we 15 would expect that interface to be used for configuring 16 the FBJ or whatever it is. And I would basically make 17 an assessment, are they in fact doing that.

18 If they're doing that, they've enforced 19 that. Essentially, I can create an actual safety 20 conclusion, base it in part on what was evaluated in 21 the topical report and in part on what the, how the 22 application applied that. Okay.

23 MR. ODESS-GILLERT: Right.

24 MR. STATTEL: So, that's what my 25 expectations would be.

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69 1 MR. ODESS-GILLERT: Right. So, I think, 2 in this example, other than the cross-channel 3 comparison, I think you will see those interfaces like 4 between safety and non-safety. Like, especially to 5 the maintenance workstation --

6 MR. STATTEL: Right.

7 MR. ODESS-GILLERT: -- were addressed.

8 References to ISG-04 compliance, I think, 9 is in the example, as well as references to the 10 topical reports on further description of the type of 11 data link they were using to implement that.

12 MR. STATTEL: Right. Now, I realize to a 13 licensee this may look duplicative, okay, like we're 14 reevaluating the same thing twice. I realize that's 15 the appearance that this gives.

16 But in reality, we don't have a, we're 17 trying to do as much as we can up front with a topical 18 report. I guess the example that comes to my mind is, 19 on Tricon, there is a capability, an interface 20 capability, to connect a main cabinet with a remote 21 cabinet. And RXM chassis.

22 And when we discuss that with the vendor 23 they said, well, you can use that to expand I/O to a 24 remote location, or, you can use that as a safety to 25 non-safety interface and use the remote chassis as an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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70 1 input for non-safety sensors. And it basically 2 provides a qualified boundary, safety to non-safety 3 boundary.

4 Now, obviously that is dependent on the 5 application, right? So it can be used. And when you 6 think about it, it can be used in a lot of different 7 ways.

8 So, in the Diablo Canyon application, they 9 did use an RXM chassis and they used it as a safety to 10 non-safety boundary, right. So that basically 11 formulated the criteria for our application for 12 review.

13 But it was perfectly consistent with what 14 was in the topical report. And that's what we would 15 look for as well.

16 MR. DARBALI: And so far, you had asked a 17 question of anyone in the conference which was, if 18 there was something previously approved in the topical 19 do you need to include it in the LARs.

20 MR. STATTEL: Right.

21 MR. DARBALI: We are always, we always 22 prefer to avoid duplication but if it helps to make 23 the argument we would think, because you already have 24 the information and you base your design on the 25 architecture based on that information.

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71 1 So, I don't see a problem in including a 2 few paragraphs, now yes, if you want to reference five 3 pages, then you can just make that reference, Pages 1 4 through 5 of the topical explain the basis for this, 5 for this topic. And that's generic, it's not 6 dependent on the application.

7 But if it's a few paragraphs you can't 8 say, you know, you can provide information that says, 9 and this was reviewed and approved in the topical 10 safety evaluation.

11 So, I think the preference would be to 12 keep the information. Because it doesn't seem like 13 you have to dig for it, you already have it and you 14 base your information on it.

15 MR. ODESS-GILLERT: Okay. And I guess 16 it's somewhat of a judgment call.

17 MR. DARBALI: Right.

18 MR. ODESS-GILLERT: That you're referring 19 to.

20 MR. DARBALI: I think what we don't want 21 is to, again, the person who reviewed the platform may 22 not be the person who reviews the license amendment 23 request.

24 MR. ODESS-GILLERT: Right.

25 MR. DARBALI: Because, again, so many NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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72 1 years happen in between. So, what you don't want is 2 a new reviewer looking at that and saying, I don't 3 know where that comes from, I don't understand it, and 4 then going and digging into the topical, to find that 5 information.

6 So, avoid duplication if it doesn't add 7 value, but, if it does help the argument, will you 8 please keep it.

9 MS. GOLUB: Were there any other questions 10 on this?

11 MR. ODESS-GILLERT: I don't think so.

12 MR. DARBALI: And I appreciate that, 13 again, we're not looking at the technical details of 14 the information, but I appreciate that your comments 15 that you highlighted, this is the item in Guidance G, 16 this is where the information is provided.

17 I understand that, when the listing ISG 18 was put together, it wasn't like I'll provide it in 19 this order. So we don't expect that.

20 I would imagine that the licensee would 21 look at the ISG and kind of do their internal 22 checkmark, okay, we're covering everything.

23 I wouldn't expect a reviewer to say, oh, 24 you didn't cover this item. Because I think I looked 25 at what you marked and there was one item in the list NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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73 1 that I didn't catch.

2 I don't have it here in my notes, but 3 having the pointer, it's helpful. Without having the 4 pointer, the reviewer's kind of have to do their own 5 mapping and it might take longer.

6 MR. ODESS-GILLERT: Well I think, yes, the 7 idea was, certainly if you're starting a clean sheet 8 of paper with a LAR and using ISG-06 alternate view 9 process D.2.2, or D.2, certainly you would align up 10 your description with the ISG to facilitate that 11 review versus taking something that's already been 12 written and then trying to see to what degree does it 13 meet the --

14 MR. DARBALI: Right. Yes.

15 MR. ODESS-GILLERT: -- criteria and the 16 alternate review process, right?

17 MR. DARBALI: Right.

18 MR. ODESS-GILLERT: So, yes.

19 MR. DARBALI: Right. That's why one or 20 two items in the list were not covered. That's fine, 21 because then the purpose of the tabletop is to show, 22 you provided a list, we tried to identify that 23 information.

24 MR. ODESS-GILLERT: Right. If there is no 25 other feedback, I'd like to sort of highlight what I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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74 1 saw were things that weren't expected in the old ISG, 2 the LAR submittal, that would probably be included in 3 the LAR submittal. And that would be in my 4 presentation that --

5 MR. DARBALI: Right. So, we used 6 PowerPoint. And that ties, if you add it in the text, 7 you did kind of highlight --

8 MR. ODESS-GILLERT: Yes, I did.

9 MR. DARBALI: -- oh, this is the --

10 MR. ODESS-GILLERT: I did.

11 MR. DARBALI: -- so I'm going to go back 12 to that.

13 MR. ODESS-GILLERT: Yes. But for those 14 who may not, have not dug into the details, I thought 15 this might be helpful.

16 So, Joe, you can go on to the next page.

17 So, when reviewing the Diablo Canyon LAR for 18 architecture content, we sort of thought, identified 19 the following gaps that the ISG clearly identified as 20 expectations of what would be included in the LAR.

21 The first one was to demonstrate, the ISG 22 says to demonstrate how the design detects 23 malfunctions. That's in the ISG.

24 And the ISG says, how the application 25 interfaces and uses the self-test and self-diagnostic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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75 1 features defined in the approved topical report and 2 evaluated in the SE.

3 So, when I was reviewing the Diablo Canyon 4 LAR, they don't explicitly describe how the 5 application will take advantage of the diagnostics.

6 They're sort of identified in a general way.

7 But, the ISG is clearly pointing out that 8 the expectation is that the LAR would describe if 9 you've got these internal diagnostics, how would they 10 be employed in the application.

11 MR. STATTEL: Okay, just a little 12 background on that. So, when we had our pre-13 application meeting and the first submittal, Diablo 14 Canyon essentially was not crediting any self-15 diagnostic features and they were going to perform 16 surveillance testing just like they had done on the 17 previous system.

18 After our discussions, right, and we also 19 pointed them to the Oconee application, they decided 20 that they could take advantage of some self-diagnostic 21 functions and redefine, what I believe a channel, 22 Oconee did some redefinition in the tech spec of 23 channel functional paths and what was required for 24 their online surveillance testing.

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76 1 suit and did some similar changes to their tech spec.

2 And in that they credited self-diagnostic features of 3 the system.

4 We didn't reevaluate them, those self-5 diagnostic features, but we did point to them, my 6 recollection is, in the safety evaluation. So 7 essentially, we gave credit for having evaluated those 8 in the topical report and we used that as a basis for 9 approving those tech spec changes. Okay.

10 MS. GOLUB: But I think more on your point 11 is that, is that we're making clear to the Applicant 12 that they need to define that in the LAR.

13 MR. ODESS-GILLERT: Right. Right. Yes.

14 Jay, you want to go to the next page?

15 So, the ISG says that treatment and 16 detection of malfunctions in the system inputs, 17 including sensors and transmitters in the system 18 logic, including internal voters within the safety 19 system or voter's external to the safety system and 20 malfunctions in the system outputs, including discrete 21 output switches, blah, blah, blah.

22 This should include the expected failure 23 states of each input and respond to the system to each 24 failure in the expected failure state. So basically, 25 this would be an FMEA. All right.

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77 1 So the, although I'm just saying here the 2 level of detail and how diagnostics affect the result 3 was not discussed, actually, the FMEAs were really 4 considered Phase 2 documents in the Tier 2.

5 MR. STATTEL: Yes.

6 MR. ODESS-GILLERT: Or the tiered ISG 7 approach. So, it's expected that the Applicant would 8 include the FMEA in the LAR. And that's why these 9 failure modes and any credit to diagnostics in 10 detecting those failure modes would be described as 11 part of the LAR submittal.

12 MR. STATTEL: I'm sorry, I don't 13 understand what the gap is.

14 MR. ODESS-GILLERT: The gap is, is that 15 when Diablo Canyon submitted their LAR --

16 MR. STATTEL: Yes.

17 MR. ODESS-GILLERT: -- the FMEA was not 18 included because it was a Phase 2 document.

19 MR. STATTEL: Correct.

20 MR. ODESS-GILLERT: So, we're doing it 21 earlier. So, you'll have the FMEA --

22 MR. STATTEL: Right.

23 MR. ODESS-GILLERT: -- when you receive 24 the LAR.

25 MR. STATTEL: Okay.

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78 1 MR. ODESS-GILLERT: That's the difference.

2 MR. STATTEL: That's true. I acknowledge 3 that.

4 MR. ODESS-GILLERT: Yes.

5 MR. STATTEL: Actually, they could have 6 submitted the FMEA at the time of the application.

7 Because, I mean, they really did have all the 8 information they needed for that. But, they choose to 9 defer that to Phase 2.

10 But I guess it does take some time and 11 resources for them to create that document and get it 12 ready for submittal. So they took advantage of being 13 able to vet in the Phase 2.

14 MR. DARBALI: You know what, I like this 15 exercise because not only is it information that ISG 16 asked you to provide, but also what, you know, LARs in 17 the past, like Diablo, did provide. So, I think it's 18 very helpful to identify, we'll do the same end phase.

19 So, I like this exercise.

20 MR. ODESS-GILLERT: All right, Joe, to the 21 next slide. So, this is very similar. So, these are 22 ISG criteria.

23 This is a separate I/O power supplies, oh, 24 I guess these are quotes from the LAR.

25 MS. GOLUB: No, these are Phase 2.

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79 1 MR. ODESS-GILLERT: Oh, these are Phase 2 2 items. The following items are indicated as Phase 2, 3 however, we would be including them as part of the 4 LAR.

5 MS. GOLUB: Right.

6 MR. ODESS-GILLERT: All right.

7 MS. GOLUB: And --

8 MR. ODESS-GILLERT: Just to be clear.

9 MS. GOLUB: -- I guess, more on it, I 10 think in a way this kind of speaks to an ongoing 11 conversation we've been having that it's clear to us 12 that it's, when we submit the LAR, we can't really 13 say, well, it's going to be submitted right after 14 conceptual design is done or it's just a little bit 15 into detail size.

16 It really depends on making sure you have 17 the information that you need to submit in the LAR.

18 So that's a kind of a little bit of a learning on our 19 side that you need the information you need to meet 20 the requirements of the ISG.

21 And so this, you know, this is just more 22 of those items that in the past, even though that 23 Phase 1 submittal, the alternate review process LAR, 24 they're not equivalent submittals. I mean, clearly 25 you need more in the alternate review process LAR.

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80 1 MR. WATERS: Yes, please, this is Mike 2 Waters. This is an accomplishment as well. This is 3 where it is different.

4 We'll do an acceptance review, we'll 5 submit it and determine if there is sufficient 6 information where in the past we have a little luxury 7 saying where we can get this into Phase 2, that 8 concept no longer applies to this process. It's very 9 important to get it correct up front.

10 MS. GOLUB: Yes, good point.

11 MR. DARBALI: And I know you know that our 12 May 17 ACRS Subcommittee, the timeline slide that 13 compares the tier and the alternate review process, 14 the LAR submittal, and how it attracts the lifecycle 15 phases.

16 I don't know if you noticed, but for the 17 alternate review process, it shifts a little to the 18 right when compared to the tier process because, and 19 I think at the beginning they were both at the same 20 time frame, but I think we expect that there's a 21 little more information gathering on the part of the 22 licensee and the vendor before that LAR is submitted.

23 Does that translate to a significant 24 change in time, is it going to vary by the mod. But, 25 right, it's good that, and I don't know if that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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81 1 something that the industry guidance is going to 2 highlight.

3 Even though we're having these discussions 4 and creating these new processes to help industry, 5 it's up to the individual licensee to determine, well, 6 you know, based on when my outage is going to be, when 7 I expect fact to be performed, maybe the tier process 8 is more convenient for me. So, it's something to 9 consider.

10 MR. STATTEL: Just a note on power 11 supplies, this was a little awkward with Diablo 12 Canyon. So, let me explain. So, neither one of the 13 platforms that they had used had essentially any 14 discussion about powering, about supplying power to 15 it.

16 Now, like Oconee, they simply powered the 17 divisions with the same power that was powering the 18 old system, the old Bailey system, in the case of 19 Oconee, and the Eagle-21. So, we knew that.

20 But in Diablo's case, we didn't really 21 understand how that power distribution worked, other 22 than what was in the FSAR. So, we had some 23 discussion, we had open item discussion, we had some 24 RAIs, I believe, and we got a diagram of how the power 25 distribution worked.

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82 1 Now, it wasn't changed, right? It was not 2 part of the mod. But when I'm evaluating, when I'm 3 following our SRP, it's telling me, verify that you 4 have independence of power sources and things like 5 that.

6 Now, do I just take their word for it, 7 that because they're using the same power source as 8 before, that they meet all of those requirements? Or 9 do I go back and look at that design?

10 And it became kind of a conundrum for us, 11 because we weren't sure how far to go with that. So, 12 what -- we got enough of an understanding based on the 13 RAI responses to be able to base our safety 14 conclusion.

15 But it also came down to, even the 16 individual power distribution within the cabinets, 17 that, actually at the Phase 2, late in the game, we 18 were on an audit and the designer showed us diagrams 19 and they had draft written all over them and they 20 said, we're still working on this and we're still 21 working on how to connect these power supplies and how 22 to set auctioneering up and things like that, but this 23 is what we're working on.

24 So, it was kind of a work-in-progress.

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83 1 the EQ, which we had contracted out, the EQ engineers 2 were asking, well, what's the qualification, what's 3 the seismic qualification, what's the temperature 4 qualifications of all of these components, which are 5 part of the system, but they're not designed yet. I 6 don't even think they had selected the source of these 7 yet.

8 So, even though it may seem clear in the 9 onset what your boundaries are for what's being 10 amended, license-wise, in the power supply and power 11 distribution area, it was not clear at all. Those 12 were very fuzzy lines.

13 And I think that's going to happen over 14 and over again, because not all the platforms have 15 qualified power supplies that are part of the 16 platform. Some of them do, not all of them.

17 MR. DARBALI: So, Rich, would you think 18 that if a licensee tries to provide that -- kind of 19 rush to provide that information in the LAR, that it's 20 likely that that would change, that the design of the 21 power supplies would change throughout the full 22 design?

23 MR. STATTEL: Well, if -- I think the point 24 is, we're willing to basically limit the scope of our 25 review, if we can be convinced that you're basically NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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84 1 using the same sources as before, we presume that they 2 met the design basis before.

3 We like to confirm that, but we will 4 presume that. I think we're willing to do that. But 5 we do need to consider it, in our evaluation, right?

6 I think in more cases than not, we're going to see --

7 nobody wants to change the power supply.

8 The only reason I think a plant would want 9 to do that is if, let's say for instance, they wanted 10 to go to a qualified power distribution system, like 11 Westinghouse has, and the power requirements are 12 different. Or if the new system, for some reason, 13 uses more power or affects the load distribution 14 center and there might be new calculations associated 15 with that.

16 I don't think anybody is going to be 17 redesigning their power systems based on replacing an 18 I&C system.

19 MR. ODESS-GILLETT: Thank you. Joe, is 20 there another slide after this? This is the last one?

21 MR. GOLLA: This is the last one.

22 MR. ODESS-GILLETT: So, I guess, that's all 23 I wanted to sort of accentuate is regarding the 24 additional items, we envision in the LAR having to 25 include that in the past, would not have been included NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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85 1 as part of this.

2 MR. STATTEL: Yes, I noticed in the markup 3 here, you've deleted a lot of evaluation that 4 basically was taken from the LTR evaluation. And yes, 5 I understand, there's no reason to duplicate that, but 6 a lot of times, it's easier to duplicate it than to 7 provide a reference and have to answer a lot of 8 questions from peer reviewers.

9 So, but, yes, I do recognize that. I 10 think there is some room for improvement there. We 11 can try to do better at that.

12 I also note that you pointed to a diagram 13 that came from Diablo -- I'm actually more interested 14 in your impression of it, than providing additional 15 comments of my own. But there was a diagram that you 16 pointed out on Page 4, right?

17 That actually was something we had -- they 18 did not have that in the initial -- well, in our 19 initial discussions, in our Phase 0 meetings, they 20 hadn't prepared anything like this. They had prepared 21 some of the other drawings that you showed here, but 22 this was kind of what showed the architecture, right?

23 And we pointed them at a similar drawing 24 that Oconee had done, but Oconee's was horizontal 25 instead of vertical like this one. But we pointed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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86 1 them at that and we said, look, we really need to 2 understand the architecture and where the 3 communication links are. And this is what they came 4 up with.

5 MS. GOLUB: Page 4.

6 MR. STATTEL: Not this one, not this one.

7 This is what they started with.

8 (Laughter.)

9 MR. STATTEL: That wasn't good enough.

10 (Simultaneous speaking.)

11 MS. GOLUB: Figure 6.

12 MR. STATTEL: Now, that one, they had. But 13 this one didn't really provide enough information 14 architectural wise.

15 MS. GOLUB: I think it's the next one.

16 MR. STATTEL: No, we had those. That one, 17 with all the colors.

18 MS. GOLUB: Oh, that one, there you go.

19 MR. STATTEL: Because this one shows all 20 four divisions and it shows all the connectivity. It 21 shows where the maintenance work stations, how the 22 maintenance work stations connect in.

23 This is truly an architectural diagram 24 that was useful in supporting our assessments of 25 independence. And we used this pretty extensively NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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87 1 when we presented at ACRS. They had a lot of 2 questions on this.

3 I actually had to zoom in on part of this 4 diagram in order to really draw the lines of where the 5 separations occurred. But this is the architecture 6 diagram, I think, that really sold the system, I 7 think, when we were trying to get people to understand 8 where the communications independence was established.

9 And we had a similar diagram to this in 10 Oconee. And we had pointed Diablo Canyon at that and 11 this is what they created in response. So, I think 12 this diagram is a really good example of what I would 13 want to see in every application.

14 We did not see that in Hope Creek. There 15 are several other applications that we did not receive 16 this type of diagram. But those were less extensive 17 systems, so we were able to work around that.

18 MR. ODESS-GILLETT: Well, what's 19 interesting is that, sort of the pre-application 20 meeting helped inform the licensee on what kind of 21 information would help facilitate the review. So, I 22 --

23 MR. STATTEL: Right.

24 MR. ODESS-GILLETT: -- think it's --

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88 1 the pre-application meeting, having that pre-2 application meeting.

3 MR. ODESS-GILLETT: Yes.

4 MR. STATTEL: They didn't have that up 5 until that point.

6 MR. ODESS-GILLETT: Yes, so that's a good 7 data point in regards to pre-application meetings.

8 MS. GOLUB: So, can I ask a follow-up 9 question? Because I know Warren -- I mean, Warren 10 very carefully -- this took a while to put together, 11 pulling out which diagrams you thought would be the 12 best representations for architecture and whatnot.

13 Are these, in general, this application 14 that submitted these types of diagrams, I mean, this 15 is what you're looking for as part of an architecture 16 description? I just want to make sure that we're 17 clear on that, because there's tons of diagrams.

18 MR. STATTEL: Yes.

19 MS. GOLUB: Just want to make sure that 20 that is in fact what you would anticipate would 21 describe the architecture of these types.

22 MR. STATTEL: And you can see, by the 23 different diagrams that they presented, there are 24 different levels of detail.

25 I think the first one is more the high NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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89 1 level, it made sure it showed all four divisions, and 2 it also has the interface to the non-safety system and 3 it has any cross-channel. If there was cross-channel 4 communications, you would see it on this diagram.

5 The other ones were helpful -- I guess, 6 architecture is such a wide term --

7 MS. GOLUB: It is.

8 MR. STATTEL: -- broad term. But the other 9 ones were helpful in understanding the technical 10 description of how the interfaces were configured.

11 So, yes, it's architectural, but it's more 12 understanding the details.

13 MS. GOLUB: Yes.

14 MR. STATTEL: So, I don't know where you 15 draw the line of what goes into an architectural 16 document --

17 MS. GOLUB: Yes, true, versus --

18 MR. STATTEL: -- and what goes into design 19 detail description.

20 MS. GOLUB: I just, I guess, because this 21 is going to be part of the industry guidance document, 22 this is what licensees are going to look at and say, 23 okay, these are the kind of diagrams we need to 24 provide.

25 So, I just want to make sure when we stick NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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90 1 it in that guidance document and people look at it, 2 that they have the sense that they're hitting the 3 mark. This is the expectation.

4 MR. STATTEL: Right. So, for example, this 5 diagram that we have up here now, that showed 6 connectivity to both the ALS chassis and to the Tricon 7 chassis.

8 And it shows that there are two different 9 work stations, right? One for ALS and one for Tricon, 10 and they share a common monitor. If I had a pointer, 11 I'd point to this. They share a common keyboard and 12 a common monitor.

13 Again, they were putting this all in the 14 same cabinet, but they kept separation between the 15 subsystems. And this diagram was very helpful in 16 supporting that discussion, that description, because 17 it's not really a traditional design that you would 18 see.

19 MR. ODESS-GILLETT: So, this particular 20 diagram --

21 MR. STATTEL: Right. Now --

22 MR. ODESS-GILLETT: -- was more applicable 23 to having two different subsystems versus --

24 MR. STATTEL: That's exactly --

25 MR. ODESS-GILLETT: -- it may not be so --

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91 1 MR. STATTEL: That's exactly right. That's 2 exactly right. And that may not be apparent if you're 3 just looking at it from the outside.

4 MR. ODESS-GILLETT: Right.

5 MR. STATTEL: But when you read the 6 discussion, the description of how the maintenance 7 work stations are configured, this diagram is very key 8 to understanding that.

9 MR. HERB: This is Ray Herb. I don't think 10 it was our intention to only have one diagram, you all 11 pick one you like the best.

12 MR. STATTEL: Right.

13 MR. HERB: I think we would --

14 MR. STATTEL: Right.

15 MR. HERB: -- we would envision, I think, 16 that most submittals would have to have the high level 17 and then, succeeding levels of detail, as far as you 18 could go, to support that. And it wouldn't 19 necessarily have to be one diagram.

20 That's not what we're looking for, I 21 think. And so, I think you're happy with all those 22 diagrams, since we would probably submit several of 23 those with our submittal, enough to actually show the 24 details of the design mix we were at.

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92 1 had another diagram up there, I don't know if you can 2 pull that one up?

3 MR. DARBALI: Before or after?

4 MR. STATTEL: It was the really high level 5 one that showed the reactor plant.

6 MR. ODESS-GILLETT: Oh, yes, that was the 7 first one. It's the Figure 1.

8 MR. STATTEL: So, that diagram, it shows 9 the containment building and the plant.

10 MR. ODESS-GILLETT: Right there.

11 MR. STATTEL: Right. So, that was 12 something where the applicant here wanted to 13 illustrate what the scope of the modification was.

14 So, you can see, the red box is what's being changed 15 and everything outside of that box is, we're not 16 changing that, right?

17 So, it's not really an -- this, I don't 18 consider to be an architectural diagram. This is 19 something -- Oconee did not provide anything similar 20 to this that I'm aware of, right?

21 MR. ODESS-GILLETT: Right.

22 MR. STATTEL: Correct me if I'm wrong, 23 Mark. But big picture wise, yes, it does help, 24 because in the case -- in this case, with this 25 Westinghouse design, we have these systems that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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93 1 very specific to that design, the solid state 2 protection system.

3 And it's very clear from this diagram that 4 we're not touching the solid state protection system, 5 right? So, I think this was something the applicant 6 chose to include as part of their amendment, just to 7 help us to understand what was in scope and what was 8 out of scope.

9 I think it's useful, but not 10 architectural, right?

11 MR. ODESS-GILLETT: No.

12 MR. STATTEL: And we told them that at the 13 pre-app meeting. I said, this is really not adequate 14 for the architecture. And that's where we went to 15 that other, the rainbow diagram, what they call it.

16 MR. ODESS-GILLETT: So, Rich, I think the 17 ISG does talk about what's changed. And so --

18 MR. STATTEL: Yes.

19 MR. ODESS-GILLETT: -- this was --

20 MR. STATTEL: That's right. I think we do 21 have this covered in the ISG, we did establish the 22 scope of the modification.

23 MR. ODESS-GILLETT: You could use that for 24 that purpose.

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94 1 purpose.

2 MR. ODESS-GILLETT: Now, let's go to the 3 next figure, Samir, and I'd like to get -- so, with 4 this figure, but I guess, to some degree, you felt 5 that this was -- what was inadequate about this figure 6 from your point of view, Rich?

7 MR. STATTEL: Okay. So, there were 8 actually two versions of this figure. There was one 9 -- so, it says, you look at that, it says, existing 10 Eagle-21 protection set.

11 MR. ODESS-GILLETT: Right. So, why don't 12 we --

13 MR. STATTEL: And then, there was another 14 version that basically showed -- right.

15 MR. ODESS-GILLETT: Yes, I think to the 16 next --

17 MR. STATTEL: So, basically, they -- so, 18 the first one was a figure, I think it was right out 19 of their FSAR.

20 MR. ODESS-GILLETT: Oh, was it?

21 MR. STATTEL: And then, they essentially 22 just marked it up and said, well, here's what we're 23 going to change it to. And this shows the two 24 subsystems in there.

25 MR. ODESS-GILLETT: Right.

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95 1 MR. STATTEL: But what it didn't show, it 2 did not show -- I don't --

3 MR. ODESS-GILLETT: It's hard to read.

4 MR. STATTEL: I don't want to misspeak 5 here. But to me, this didn't show -- it does show 6 connectivity to the SSPS, it's helpful in establishing 7 the scope of the modification, because it's everything 8 in the box on top.

9 But it didn't show the communications 10 connectivity and it didn't really, at an architectural 11 level, show where the independence was being 12 established. And that's -- and we gave that feedback 13 during the Phase 0 meeting.

14 MR. ODESS-GILLETT: Which is interesting.

15 So, they presented --

16 MR. STATTEL: And they could have expanded 17 this diagram --

18 MR. ODESS-GILLETT: Right.

19 MR. STATTEL: -- and added more detail to 20 it, but I think it would have become really busy.

21 MR. ODESS-GILLETT: Right. So, that's 22 interesting. So, they actually -- this was probably 23 the architecture diagram that they presented at the 24 pre-app meeting?

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96 1 correct.

2 MR. ODESS-GILLETT: Okay. That's good --

3 MR. STATTEL: So, in our minds, we had the 4 Oconee architecture diagrams and then, we're looking 5 at this and we're like, I'm not getting the same 6 information from this.

7 MR. ODESS-GILLETT: All right. That's all 8 I had.

9 MR. STATTEL: Then, the other diagram, 10 there's another set of diagrams --

11 MR. ODESS-GILLETT: Well, this one is 12 showing the allocation of functions --

13 MR. STATTEL: Right.

14 MR. ODESS-GILLETT: -- to the different 15 subsystems.

16 MR. STATTEL: True, and there's a more 17 detailed version of this, I saw it -- yes, that one 18 right there. We had one of those for each protection 19 set.

20 Again, these are more design details and 21 it shows you what the connectivity is. This was 22 useful, because it showed, for instance, the RTD 23 signals. They actually -- the RTDs are wired up to 24 the ALS system and then, there's a 4-20 loop that goes 25 over to the Tricon system. And this shows what the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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97 1 connectivity is.

2 So, you can see every signal in this 3 diagram. But again, even though the communication 4 links are shown here, it really doesn't give that big 5 picture architecture, where the independence is 6 established.

7 It does show division -- if you look at 8 those arrows there, it shows you Class 1 and Class 2 9 separation. That's what that's intended to do.

10 MR. ODESS-GILLETT: And then, the next 11 figure was the one that you were talking about before, 12 about the figure that you suggested from --

13 MR. STATTEL: Right.

14 MR. ODESS-GILLETT: Okay.

15 MR. STATTEL: And I don't have an example 16 of it, but we've seen figures that, like in design 17 certifications and things, that they basically have a 18 really good layout of the system and they show all the 19 components of the system, and it's really hard to tell 20 where the communications interfaces are.

21 And that's what we -- we want to 22 concentrate on that. We want to be able to rapidly 23 identify, well, what are our communication interfaces 24 between Division 1 and Division 2? What are our 25 communication interfaces between safety and non-safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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98 1 systems?

2 MR. ODESS-GILLETT: Yes.

3 MR. STATTEL: I mean, that's really the 4 crux of what ISG-04 is about --

5 MR. ODESS-GILLETT: Right.

6 MR. STATTEL: -- establishing independence.

7 Now, in Topical Reports, typically, these digital 8 systems have lots and lots of interfaces. The one I'm 9 reviewing now has like eight different types of 10 interfaces.

11 Many of them are just internal, like most 12 systems have a back plane communications interface, 13 that uses certain protocols. Some systems have 14 interfaces, communication interfaces that are local to 15 the circuit board, just between components of the 16 circuit board, have communication interfaces.

17 I don't want to say we're not interested 18 in those, right?, but those don't -- they're all 19 within the same division, so any intra-division 20 communications, it's not really an independent -- we 21 don't apply independence criteria to those.

22 But they -- we do consider them in the 23 case that's made for deterministic performance. So, 24 we do want to understand what they're used for, so we 25 do typically describe them, but we don't have a lot of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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99 1 criteria for those types of interfaces.

2 MR. ODESS-GILLETT: So, just for three-way 3 communication, what I'm hearing is that the 4 architecture, diagram of the architecture is good, but 5 probably what would be also good is almost a 6 communication architecture drawing --

7 MR. STATTEL: Yes.

8 MR. ODESS-GILLETT: -- so that you can 9 focus on the communication architecture of where your 10 boundaries are and where you need independence and 11 that kind of thing.

12 MR. STATTEL: Right.

13 MR. ODESS-GILLETT: Okay.

14 MR. STATTEL: Well, it's really 15 independence, it's the independence criteria that 16 we're going after here. And we want to be able to see 17 that at the architectural level. So, communications 18 is key to that.

19 Another aspect of that, though, is 20 basically, if you have non-safety -- let's say you 21 have non-safety related meters that you're driving 22 from your system. How are those connected to the 23 system? Do they go through isolators? So, you'll see 24 on the architecture drawings, those isolators are 25 shown.

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100 1 And in some cases, the platform provides 2 a feature, an isolation feature, a safety to non-3 safety barrier, a qualified barrier, and the 4 architecture diagram would show that all the non-5 safety equipment is wired to the non-safety side of 6 that barrier and the safety on the other side.

7 I wanted to discuss maintenance work 8 stations a little bit, too, because that was a point 9 of contention with the Oconee design. So, in their 10 case, they had one maintenance work station for each 11 Unit and that maintenance work station could be 12 connected to any one of the four protections or 13 division, safety divisions.

14 And how they established independence 15 using one station that could connect to four 16 divisions, that was challenging, right? Since then --

17 now, we did approve that, right? But since then, 18 that's one of the reasons Diablo Canyon chose to have 19 separate work stations.

20 Their initial design had four separate 21 work stations and those work stations, the PCs in them 22 had software for ALS and had software for Tricon, all 23 on the same work station. And that was challenging, 24 as far as crossing.

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101 1 point between the subsystems. Now, the subsystems are 2 all on the same division. So, I don't think it -- I 3 think it could have been approved that way, I really 4 do, and we had initial discussions about that.

5 It could have been approved that way, but 6 they basically made a design decision to make them 7 into separate work stations. And their reasoning for 8 that had nothing to do with regulations, it was just 9 easier to get -- it had to do with the vendors, 10 installing two different vendors' software on the same 11 PC was problematic, because the vendors had issue with 12 that.

13 MR. ODESS-GILLETT: So, it was a design 14 decision?

15 MR. STATTEL: It was a design decision.

16 But I want to point out today that that had nothing to 17 do with regulation, we were not opposed to approving 18 that, reviewing and approving that, because we 19 understood that, even though it was a single 20 maintenance work station, it was all in the same 21 division.

22 And I think there was a path to approval 23 on that particular case. In the end, they did -- they 24 had the same monitor, right, so they just moved it up 25 a level.

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102 1 MR. ODESS-GILLETT: Okay, thank you very 2 much.

3 MR. DARBALI: So, I'm looking at the --

4 kind of jumping ahead. The slide presentation on, 5 we'll talk about it in the afternoon, about pre-6 application meetings, covers a lot of topics.

7 And I'm kind of shifting through the 8 slides. Are there any slides on system architecture, 9 on the pre-application meeting slides, that would kind 10 of apply?

11 MS. GOLUB: Yes, that's a great question.

12 So, in the pre-application review, what we did was we 13 started with the Hope Creek Phase 0 presentation, 14 because it was the most recent, I suppose.

15 And so, the example we provided, it's a 16 mix of Hope Creek material, but then we, essentially 17 we crossed out, like the architecture section, we 18 said, insert here.

19 MR. DARBALI: Right, okay.

20 MS. GOLUB: So, you're not going to see 21 example diagrams from it. But the idea, I guess, was 22 that some of the diagrams that are in Warren's 23 presentation would be presented, some of the higher 24 level ones would be presented.

25 And now, hearing what Rich said about the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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103 1 communications interface, that's clearly an important 2 topic that, when we do the industry guidance, we would 3 recommend that licensees create something for the pre-4 application review meeting to address it, to give them 5 a chance to get some good feedback on what should be 6 included in the LAR.

7 But you're not going to see much in that 8 --

9 MR. DARBALI: Okay.

10 MS. GOLUB: -- tabletop example.

11 MR. DARBALI: So, we are ahead of schedule 12 by about 55 minutes. We can do a few things. We can 13 jump ahead to the Secure Development and Operational 14 Environment discussion. And I picked that one, 15 because that's the one we don't need people from --

16 right. They'll come back sometime in the afternoon.

17 We could try to have also a caucus 18 session, so we could have an industry separate caucus 19 session and a separate NRC session. And then, break 20 for lunch. Or we could --

21 MS. GOLUB: I think we'd rather -- yes, 22 because I don't think the industry needs to -- we 23 don't need to caucus right now. I think --

24 MR. DARBALI: Okay.

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104 1 feedback so far has been really helpful --

2 MR. DARBALI: Okay.

3 MS. GOLUB: -- and responsive and we 4 appreciate that. We could jump into SDOE, that's a 5 nice topic to cover.

6 MR. WATERS: Do you guys want to continue 7 or take a five minute break to get the AV folks down 8 here to --

9 MR. DARBALI: We can do that.

10 MS. GOLUB: You want to take a five minute 11 break?

12 MR. DARBALI: I think yes. I mean --

13 MS. GOLUB: Up to you.

14 MR. DARBALI: I think we are going to end 15 early today. Again, we can't -- I don't think there 16 are many sessions from tomorrow that we can --

17 MS. GOLUB: I guess if there was something, 18 that would be good, because I think tomorrow's topics, 19 we have a lot of questions on.

20 MR. DARBALI: Yes.

21 MS. GOLUB: And so, they're more meaty 22 topics that I think we're really looking forward to 23 getting some good dialogue going, to make sure that 24 we're remotely on the same page on some of these 25 topics.

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105 1 MR. DARBALI: Right.

2 MS. GOLUB: If there is anything from 3 tomorrow, we could -- oh, D.4 maybe we could pull up 4 to today, because that's -- is that one that just 5 involves this crowd?

6 MR. DARBALI: Okay. And we have 50 minutes 7 for that, so --

8 MS. GOLUB: So, we could do SDOE now and 9 then, maybe a little bit later in the day --

10 MR. DARBALI: Are we planning -- or would 11 you like to keep SDOE for later and then -- so we 12 don't have to switch two sessions, we just switch one?

13 MR. STATTEL: Well, no, let's do SDOE --

14 MS. GOLUB: Yes.

15 MR. STATTEL: -- because we only have the 16 material for today. So, we'll work on --

17 MR. DARBALI: Okay, we can do SDOE.

18 MR. WATERS: Let's take a five minute break 19 and see if we can fix this.

20 MR. DARBALI: Okay. We'll take a five 21 minute break.

22 (Whereupon, the above-entitled matter went 23 off the record at 11:08 a.m. and resumed at 11:19 24 a.m.)

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106 1 starting again. It's 11:20. We did some slight 2 changes to the agenda, since we finished early with 3 architecture, we're going to move the SDOE discussion 4 from the afternoon to now. And in the afternoon, 5 we'll cover tomorrow's section on D.4 on system 6 development process.

7 So, we handed out the SDOE section that 8 you see on the screen. Turn it over to Warren -- you 9 prepared this?

10 MR. ODESS-GILLETT: Dave.

11 MR. DARBALI: Oh, Dave Harrell? Go ahead.

12 MR. HARRELL: Okay. So, there are a couple 13 of things about the way the document is written. I 14 did use the phrase the licensee and I did use the 15 phrase vendor.

16 I think it's important to say who's 17 actually doing the work and identify who's doing the 18 work. And of course, those two would be replaced by 19 the licensee's actual name and the vendor's actual 20 name.

21 MR. DARBALI: Right.

22 MR. HARRELL: If I tried to write it 23 without those, it became inobvious who was actually 24 doing the work.

25 MR. DARBALI: Right.

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107 1 MR. HARRELL: I did loosely base it on 2 Diablo Canyon, but I considered replacing more than 3 Diablo Canyon replaced. I also eliminated solid state 4 protection system.

5 I didn't include any discussion on the 6 DAS. I didn't include the FPJ-based system. The FPJ-7 based system was enough different that trying to 8 describe it once became confusing to me, the author.

9 So, here's one, it would confuse every --

10 if the person writing it can't understand it, how 11 could it -- it doesn't communicate, doesn't serve its 12 purpose. So, in my mind, those two are significantly 13 different enough that they would get their own SDOE 14 sections.

15 MR. DARBALI: And you kind of did that?

16 MR. HARRELL: Yes. So, are there questions 17 or comments? What do we need to discuss on this, 18 guys?

19 MR. DARBALI: Right. So, and this is just 20 a very, very minor nit-picky comment. Second 21 sentence, right under D.8, the second sentence, I 22 think it starts: the review is based on the regulatory 23 requirements of the Reg Guide.

24 MR. HARRELL: Yes.

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108 1 have any regulatory requirements?

2 MR. HARRELL: It has regulatory guidance.

3 MR. DARBALI: Right. As a regulatory 4 criteria or regulatory position, but that's just nit-5 picky.

6 MR. HARRELL: But that's an important nit 7 to pick though, thank you.

8 MR. DARBALI: Right. So, the overall 9 structure of how you crafted this section is, the 10 vulnerability assessment, which covers, I think, 11 regulatory precision, C.2.2, then secure development 12 and secure operation of environmental controls.

13 Those cover the vast majority of the 14 regulatory positions. So, you don't specifically 15 point to a regulatory position, doesn't mean it's 16 wrong. We typically see from some vendors a matrix 17 that just addresses the regulatory position from the 18 Reg Guide and how it's met, so it's more of a summary.

19 We find that helpful in our evaluations.

20 I think, for Diablo, I don't think -- Diablo Canyon 21 didn't provide one. I think the vendors provided one 22 specific of how the platform addresses the Diablo 23 design.

24 MR. HARRELL: Okay.

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109 1 from Tricon. And I don't remember how ALS covered it.

2 So, it's not a must, but it helps to speed the 3 process, if you tell them, this is how we need it.

4 This is concise enough that we can draw from that.

5 MS. GOLUB: But that's good feedback, 6 Samir. I mean, if there's a -- presentation helps 7 licensees. If people are preparing this work, it's 8 great to know --

9 MR. DARBALI: Right.

10 MS. GOLUB: -- there's something that 11 presents it better, more easily -- makes your job 12 easier, then that's an advantage to the licensee.

13 MR. DARBALI: Right. And I don't know if 14 you create this based on your internal matrix or you 15 just do it from memory, but it's also helpful to the 16 licensee to have that figured out.

17 MS. GOLUB: Okay.

18 MR. HARRELL: And I can see putting a 19 matrix together that would explain how this goes.

20 MS. GOLUB: And you said, the example is in 21 Diablo Canyon's submittal, the vendors did one?

22 MR. HARRELL: It's probably buried under 23 Triconex proprietary documents.

24 MR. DARBALI: Exactly --

25 MS. GOLUB: Okay.

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110 1 MR. DARBALI: -- it's proprietary. Some of 2 it, because it's SDOE, it's security-related.

3 MR. HARRELL: Yes.

4 MR. DARBALI: So, right.

5 MR. STATTEL: But the Reg Guide is 6 formatted by phase, development phase. And so, you're 7 crossing all the phases and just dividing it into 8 sections, development environment and operating 9 environment?

10 MR. HARRELL: Yes. I'm actually -- what I 11 was actually trying to do was describe the process, 12 the process and the results of the process, more than 13 the individual little pieces of process.

14 Because the -- everything for me, the 15 phase development approach really doesn't work. We 16 end up doing something that's more like an iterative 17 approach.

18 MR. STATTEL: Right. Or we do some kind of 19 mapping. So --

20 MR. HARRELL: Yes.

21 MR. STATTEL: -- typically, the phases that 22 are in the Reg Guide aren't the same as the phases 23 that are used for the particular development. So, we 24 have some kind of mapping equivalency, figure that 25 out. And then, we look at each requirement and where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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111 1 it maps in that.

2 So, I guess, I like this in that, you can 3 avoid doing that, the mapping. But at the same time, 4 you want to make sure all the criteria are okay.

5 MR. DARBALI: And you covered the big ones, 6 you cover remote access, you cover the vulnerability 7 assessment.

8 MR. HARRELL: Portable media is in there.

9 MR. DARBALI: And that's -- right. And 10 that's both in development and some of it's secure 11 operational environment. The other ones are 12 identification and evaluation of unneeded code, you 13 covered that in your V&V.

14 The other one is really -- and this is 15 very tricky, because a lot of vendors and some 16 licensees, they focus on the architecture design 17 requirements and sometimes, SDOE requirements are, oh, 18 we do that in security space.

19 And sometimes, it's not so easy to see an 20 SDOE requirement traced all the way to --

21 MR. HARRELL: Right.

22 MR. DARBALI: -- design implementation and 23 testing. So, I don't know if you actually talked 24 about that, because that's really the repetition that 25 you see, oh, make sure that the requirements are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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112 1 translated into design configuration items, make sure 2 the configuration items are implemented, make sure 3 there is a test to both.

4 All of that could be described in one 5 section, how you go from requirement to the testing, 6 those functions.

7 MR. HARRELL: Right.

8 MR. DARBALI: And one thing is that -- and 9 you credit a lot of what was evaluated for the 10 platform. And you say, what I -- looking at the 11 plant-specific action item to evaluate the secure 12 development, is saying that you did that or that you 13 will do that.

14 And I think, for all of the -- you did 15 that or the licensee did that, that would be some of 16 the vendor oversight inspection activity, where --

17 maybe this is something to be covered in another 18 section and the workshop in September, but I would 19 imagine an inspection at the site saying, show me how 20 you did oversight of the vulnerability assessment.

21 Licensee should have a record of that.

22 But for the activities that it says, we 23 will do that, I would imagine there would be a 24 recommended inspection item for vendor inspection, 25 just a, well -- and again, it wouldn't be just SDOE NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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113 1 inspection, it would be an overall inspection, but if 2 we want to see an inspection of the implementation 3 activities, then there could be an item on it.

4 And I think we'll cover those some more, 5 I think there's a couple of recommended inspection 6 items based on the language of the SDOE section.

7 So, I guess what I'm trying to say is, 8 because we don't get to evaluate the full 9 implementation of secure operational environment 10 features, some of those might get pushed to an 11 inspection space.

12 SDOE is -- there is no right way to write 13 it, as long as you meet the regulatory positions. So, 14 I'm fine with this language, it's just that, whatever 15 is in here that we don't typically -- that we would 16 get in a tier review, would be pushed to maybe a 17 condition or an inspection.

18 MR. HARRELL: It may not be as obvious as 19 one would think. If you look at the first paragraph 20 in D.8.c --

21 MR. DARBALI: Right.

22 MR. HARRELL: -- there's an attempt to say 23 that the features that would be implemented in 24 software are incorporated into the SRD and then, that 25 the SRD then goes to the V&V process, which ensures NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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114 1 that the things are met.

2 So, I know I wrote it somewhere --

3 MR. DARBALI: Right.

4 MR. HARRELL: -- I just didn't remember 5 where.

6 MS. GOLUB: Yes, and --

7 MR. HARRELL: Because one -- my approach to 8 writing this was to sit down with the Reg Guide beside 9 me and this and just try to figure out how this would 10 follow from place to place --

11 MR. DARBALI: Right.

12 MR. HARRELL: -- from point to point 13 through the Reg Guide. And demonstrate that, as the 14 licensee, I understand what I'm doing.

15 MS. GOLUB: And I guess, just to kind of 16 reinforce what Dave's saying, so, this is a section 17 that -- this particular part of the tabletop material 18 went through a lot of revisions.

19 And mostly because Dave was trying to kind 20 of narrow down on, what's the right level of detail?

21 We had a lot of discussion within our team.

22 And so, it's -- from what I'm taking, 23 Samir, from your feedback, I mean, it sounds like for 24 the D.8 section, this is the right level of detail, 25 the right scope, to address D.8. Because that was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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115 1 really -- right, Dave?

2 MR. HARRELL: Yes. It may be --

3 MS. GOLUB: I mean, we went through a lot 4 to put this together.

5 MR. HARRELL: Well, yes, it got rewritten 6 several times, which is why I don't remember where 7 anything is.

8 MS. GOLUB: I know.

9 MR. HARRELL: I do think it's important 10 that we --

11 MS. GOLUB: Find that table.

12 MR. HARRELL: -- in this industry guidance 13 document --

14 MS. GOLUB: The table, I got that.

15 MR. HARRELL: -- we need to make sure we 16 put a table in that's going to summarize, here is 17 where each of the regulatory positions are met, by a 18 reference to a paragraph, which may mean we need to do 19 something towards identifying paragraphs.

20 MS. GOLUB: But it's sound to me like, in 21 general, this is kind of the level of detail, the 22 scope that you were anticipating.

23 MR. DARBALI: Right. And again, this is a 24 summary --

25 MS. GOLUB: Yes.

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116 1 MR. DARBALI: -- of the SDOE activities.

2 MS. GOLUB: But this is what would be 3 included in the LAR.

4 MR. DARBALI: In the LAR, correct. So, I 5 wouldn't take out of the question having a portal-type 6 audit --

7 MS. GOLUB: Sure, absolutely.

8 MR. DARBALI: -- where we would, as an open 9 item, could you place the full vulnerability 10 assessment, and it gets revised, but the latest 11 version --

12 MS. GOLUB: Yes.

13 MR. DARBALI: -- into the portal and we can 14 take a look, confirm kind of what you've done. There 15 may be other security or procedures related to that.

16 So, whatever is current at the time of doing the LAR 17 review, that's some of the things we could audit, 18 whatever has to be performed, we can always inspect 19 to.

20 MR. STATTEL: I'm wondering if there isn't 21 too much information on development environment, since 22 we've already evaluated that as part of the Topical 23 Report.

24 MS. GOLUB: Right, good question.

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117 1 information on development? Can't we reference that?

2 MR. HARRELL: And we do. Some of -- one of 3 the things -- one of my expectations, as someone who 4 assists licensees with the evaluation of vendors, is 5 the SDE program that the vendor had when you did your 6 evaluation, is several years old.

7 I expect to see them having improved and 8 enhanced their program in some manner. What's here is 9 the enhancement of their program, and does it still 10 meet the regulatory expectations, the regulatory 11 criteria?

12 MR. STATTEL: I saw your reference to 13 vendor oversight, too. So --

14 MR. HERB: Yes, we actually include that.

15 In the vendor oversight section, we actually cover SDE 16 and not only the vendor when they're doing the 17 application, but those same controls when it gets to 18 our side as well.

19 MR. STATTEL: Okay.

20 MR. HERB: So, we would fully -- because it 21 moves hand and fist with cyber requirements. A lot of 22 them are duplicated and we're committed to doing the 23 cyber pieces.

24 And a lot of the cyber pieces extend out 25 to the vendor in a secure environment as well, because NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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118 1 we have to develop a trust, a trusted relationship 2 with that vendor. We can't trust that vendor unless 3 they have a secure development environment. So, they 4 kind of go together.

5 MR. STATTEL: And one other thing it's 6 saying now is that different vendors -- the level of 7 evaluation we can perform at the Topical Report level 8 varies a lot from one vendor to another. So, there's 9 going -- it's going to be very specific to the 10 particular platform that you choose.

11 MS. GOLUB: Yes.

12 MR. HERB: And it's specific to the 13 architecture that we're going to choose as well, I 14 think.

15 MR. STATTEL: Yes.

16 MR. HERB: And the level of customization 17 you might have to do in your application. So, we 18 tried to do a high level. I was one of Dave's big --

19 MR. HARRELL: Harshest.

20 MR. HERB: -- editors, harshest editor on 21 this. And so, I'm very familiar with it. And so, we 22 didn't want to -- this is a high level description of 23 the analysis and the vulnerability analysis and the 24 actual program.

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119 1 participate with the vendor to do that, redo that 2 analysis for our project and make sure that the 3 controls are there. And then, inspect them to make 4 sure they're actually doing what they said they were 5 going to do.

6 And how does that compare to what was 7 proposed in the Topical Report? Because you guys may 8 have already looked at that and approved that and so, 9 we want to make sure that we don't invalidate any of 10 those assumptions and if there are changes, they're 11 actual improvements, to improve security.

12 MR. DARBALI: Right. So, I think, to your 13 question, Rich, I think what Dave was stating is, this 14 is mostly addressing that plant-specific action item 15 to the licensee, as to evaluate the vendors as secure 16 development environment, make sure it's the same level 17 or whatever change from the platform.

18 Definitely, if there are no changes, then 19 it's a short description and you explain how or why 20 there are no changes. I think, what we don't or 21 wouldn't like to see is just one sentence, the 22 licensee evaluated the vendor's secure development 23 environment and there are no changes, that's it.

24 (Laughter.)

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120 1 to have, what did you do for that? We've had, even 2 with the Diablo review, we looked at the secured 3 development environment for both subsystems.

4 And from the time the review on the design 5 started, well, both, they were both in separate 6 locations, separate states. So, it's different 7 buildings, it's different control, sometimes different 8 organization, different companies.

9 So, that's where you would expect more of 10 a bigger description of what completely changed.

11 MR. HARRELL: And to some --

12 MR. STATTEL: And they reference updated 13 SDOE?

14 MR. DARBALI: Right.

15 MS. GOLUB: Yes.

16 MR. HARRELL: From personal opinion, if the 17 vendor hasn't changed their program, hasn't changed 18 anything, hasn't followed current vulnerabilities and 19 threats, I'm not completely sure I want to use them as 20 a vendor.

21 MR. DARBALI: Correct, yes, good point.

22 Yes, well, one of the things that we see, and this 23 varies by vendors is, yes, we performed a 24 vulnerability assessment when the project began, and 25 it's like, okay, you're -- and sometimes they do have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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121 1 a procedure or a program that says, you're going to do 2 it every year, and they don't do it.

3 So, that's something that you shouldn't be 4 referencing, yes, they did it ten years ago. But I'm 5 confident with the level of detail in this section.

6 MR. HARRELL: The industry guidance will 7 probably have a table in it that's going to give you 8 the reference from the Reg Guide to the --

9 MR. DARBALI: Right.

10 MR. HARRELL: -- description. That will 11 make life easier for me too, it's also a V&V review 12 type activity. But I'm sure that if I handed this to 13 a reviewer without that table, it's going to be 14 difficult for my internal reviewer --

15 MR. DARBALI: Right. Well, and --

16 MR. HARRELL: -- to demonstrate compliance.

17 MR. DARBALI: Also, if you get a reviewer 18 who's never done a Reg Guide 1152 evaluation --

19 MR. HARRELL: Yes.

20 MR. DARBALI: -- then, it's going to take 21 a little bit longer while they learn what the Reg 22 Guide says and map it.

23 MR. STATTEL: This is one of those areas 24 where it's very subjective. So, quite literally, our 25 regulatory requirements or regulatory criteria is that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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122 1 you do a vulnerability assessment and you address the 2 vulnerabilities. Well, how well you do that 3 vulnerability assessment is a very subjective matter.

4 So, I mean, I don't know how comprehensive 5 it is, I don't know how good it is, I don't know if 6 you've identified all the vulnerabilities out there.

7 There's really kind of an expectation that you've put 8 a good level of effort into that, because that's meant 9 -- and that you've put a good level of effort into 10 addressing the vulnerabilities appropriately.

11 Now, when we read them, it's pretty 12 apparent that -- when someone does a really good job 13 of it and they identify real vulnerabilities and they 14 take meaningful actions to address them, when you read 15 a report like that, it's pretty obvious that it's done 16 well. Or if it's not done well, it's kind of obvious.

17 But it's hard to write that down, because 18 if you take a literal application of this, the 19 vulnerability -- yes, we did a vulnerability 20 assessment and it's not vulnerable to anything, they 21 meet the requirement, right? So, it is a very 22 subjective matter.

23 MR. DARBALI: Yes. The Reg Guide is silent 24 on criteria as far as what a good vulnerability 25 assessment is.

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123 1 MR. STATTEL: Right. You just have to have 2 one.

3 (Laughter.)

4 MR. DARBALI: What's good is -- I think, 5 for the most part, vendors and licensees are, because 6 of the Reg Guide 5.71, the cyber-security guidance, I 7 think pretty much all of the SDOE evaluations I've 8 seen reference that.

9 So, there's another mechanism that calls 10 for them to perform that vulnerability assessment.

11 So, the work is already done.

12 MR. HERB: And I want to stress that, a lot 13 of times when these Topical Reports were done -- and 14 there's been a lot of change in cyber over the years 15 and we've learned a lot in the industry, we're not new 16 at this anymore.

17 And I think the vendors as well, because 18 we lived in an era where we didn't consider it. And 19 some of the Topical Reports are quite old. And so, 20 there should be a -- I think that the expectation is, 21 we have SDOE and we have cyber, these are two barriers 22 to these things happening.

23 And so, we don't necessarily want to 24 duplicate a lot of stuff, so we will borrow back and 25 forth. And I think we have a better understanding of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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124 1 what that's required, now that we're actually past 2 Milestone 8, in the industry, how to do those things, 3 how difficult it is, and it's not a paperwork deal, it 4 is actual real technical controls you have to take.

5 MS. GOLUB: Yes.

6 MR. DARBALI: Yes. So far, we haven't 7 encountered a vendor that has their development 8 computers tied to the internet. So, yes, you do see 9 some platforms that, this was developed before the Reg 10 Guide, this was developed before the cyber-security 11 controls. But they still use common sense secure 12 development controls and they credit that.

13 MR. HARRELL: Even before SDOE and the Reg 14 Guide, vendors who were interested in protecting their 15 intellectual property were protecting their source --

16 MR. DARBALI: Right.

17 MR. HARRELL: -- and their requirements 18 documents, because they didn't want them lifted and 19 copied elsewhere.

20 MR. DARBALI: So, I don't have any other 21 comments on this section. I think, I don't know what 22 our modern or future regulatory infrastructure is 23 going to look like, but if we can get shorter safety 24 evaluations and still maintain the same level of 25 regulatory certainty and reasonable assurance, then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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125 1 that's good.

2 MS. GOLUB: Agreed.

3 MR. STATTEL: Yes. So, this gets to the 4 point of issuing the license amendment, we still have 5 inspection activities --

6 MS. GOLUB: Yes.

7 MR. STATTEL: -- to discuss. So, there's 8 quite a few that were cyber-security related or SDOE-9 related. So, I don't know if you want to broach that 10 now or defer that.

11 MR. DARBALI: Well, we can. We have, I 12 think, some SDOE recommended inspection items. So, 13 we're going to have more time tomorrow, so we could 14 address those. I would like to jump to the pre-15 application meeting --

16 MS. GOLUB: Sure.

17 MR. DARBALI: -- slide, because there is a 18 slide in SDOE, so we might as well talk about it now.

19 And I think that's Slide 20. Okay.

20 MS. GOLUB: All right. So, this is the 21 type of information that we thought would be 22 sufficient to provide at the --

23 MR. DARBALI: Right.

24 MS. GOLUB: -- pre-application review 25 meeting and we're looking for your feedback to say, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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126 1 yes, this is the right stuff, or maybe, there's more.

2 MR. DARBALI: And I forget, what was CGS?

3 MS. GOLUB: Columbia Generating Station.

4 MR. DARBALI: Okay.

5 MR. HARRELL: We're acronym-mad in nuclear, 6 sometimes the acronyms aren't obvious.

7 MS. GOLUB: Well, and you know what? As I 8 said, I had pulled material from the Hope Creek Phase 9 0 meeting. And there was an acronym list at the end 10 of it, which I didn't include just because --

11 MR. DARBALI: Right 12 MS. GOLUB: -- I was trying to keep this a 13 little bit shorter, so I deleted a lot of stuff.

14 MR. STATTEL: Yes. So, I mean, it's a good 15 example. In the NUMAC, in the case of the NUMAC, 16 there's two things that are very different from what 17 we are trying to accomplish here with the alternate 18 review process. One, we're using a system that's been 19 installed in dozens of plants.

20 MS. GOLUB: Yes.

21 MR. STATTEL: So, there's tons of 22 precedence out there. We also have a platform that's 23 very specific to a particular function --

24 MS. GOLUB: That's right.

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127 1 function and we know how it's going to be. There are 2 actually, in the NUMAC Topical Report, there are 3 different configurations depending on the type of BWR 4 plant you're installing.

5 So, in this pre-app meeting, of course, 6 they referenced Columbia, because there were a lot of 7 similarities, and they -- we already knew what the 8 architecture was, because it was right in the Topical 9 Report. So, they didn't even have to provide that.

10 Something else to think about, because 11 there are -- we don't normally deal with this. But in 12 this case, most of the discussion was talking about 13 similarities and slight differences from what was 14 previously approved. And it would be nice to get to 15 that point with these other types of applications, but 16 we're not there.

17 MS. GOLUB: No, that's right.

18 MR. STATTEL: So, that made it a lot easier 19 to do the Phase 0 meeting. And --

20 MS. GOLUB: And that's why we didn't really 21 include the architecture drawings and whatnot from the 22 Hope Creek presentation, because it's such a specific 23 item. The idea behind this --

24 MR. STATTEL: Well, I mentioned earlier 25 that they didn't submit an architectural diagram for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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128 1 Hope Creek. But the reason was because those are 2 already included right in the Topical Report.

3 MS. GOLUB: In the Topical Report, yes.

4 So, there was --

5 MR. STATTEL: Which very few Topical 6 Reports have that.

7 MS. GOLUB: There were a couple 8 architectural drawings in this presentation, the 9 original presentation, which --

10 MR. NOVAK: It's like a block diagram.

11 MS. GOLUB: Yes, like a block diagram, so 12 pretty high level stuff. But I --

13 MR. STATTEL: But I think --

14 MS. GOLUB: -- can't speak to it.

15 MR. STATTEL: -- they're exactly the same 16 as what's in the Topical Report.

17 MR. NOVAK: They're very similar and it was 18 really basically a copy of what we showed you when we 19 came up and talked about Columbia anyway.

20 MR. STATTEL: Yes. And we recognize that, 21 so we didn't have a lot of questions about that.

22 MS. GOLUB: One of the reasons we had 23 looked at Hope Creek was, one, it was very recent, so 24 there was some good lessons learned, we could talk to 25 the folks involved very easily.

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129 1 But also, because we wanted to make sure 2 that the alternate review process could scale to 3 something simpler, like the Hope Creek application, up 4 to an Oconee or a larger, Diablo Canyon, something 5 more complicated.

6 MR. STATTEL: Now, there was a pretty 7 significant challenge with Hope Creek. And it didn't 8 come out in the Phase 0 meeting, but it came out when 9 we started doing the evaluation and doing our 10 regulatory evaluation to the plan.

11 Because as it turned out, that particular 12 Topical Report had been approved in 1993 --

13 MS. GOLUB: Yes.

14 MR. STATTEL: -- which predated IEEE 603, 15 because IEEE 603, at that time, had not been 16 incorporated by reference. And it was evaluated 17 against IEEE 279, right? And we also looked at the 18 plant's licensing basis, which wasn't even 279, I 19 don't think.

20 And so, we're trying to reconcile that.

21 And we had no current evaluation against IEEE 603 22 criteria. So, that was challenging. So, we had to 23 perform -- actually, this predated BTP 14.

24 It predated a lot of the guidance that we 25 would normally apply to digital systems. So, we had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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130 1 to basically perform an evaluation to current-day 2 standards in order to basically get it up to speed.

3 Now, we could not do that with Columbia, 4 because General Electric had not updated their 5 procedures. So, they had nothing for us to evaluate.

6 But with Hope Creek, there was a new -- they docketed 7 a new set of development procedures.

8 MR. NOVAK: Yes, that's right. During 9 Grand Gulf, we got a number of RAIs that led to a bit 10 of an adjustment to our process. During Grand Gulf 11 and then, also during Columbia, we referred to it.

12 In Grand Gulf, we referred to as a 13 compensatory measure that we took in response to some 14 RAIs. And then, in Columbia, we described it in the 15 LAR, we said, we'll take the same compensatory 16 measure.

17 So, then, a little bit -- fast forward to 18 Hope Creek, then we created new plans so that we would 19 not have to continue to report that we're taking 20 compensatory measures. So, we did get a full BTP 7-14 21 evaluation against those new plans.

22 MR. STATTEL: It's worth mention here, 23 because it talks to how Topical Reports become 24 obsolete over time. Not obsolete, they become out-of-25 date, right? So, when we're trying to fit-up an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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131 1 evaluation that was done in 1993 to regulatory 2 requirements of today, there's gaps. There's not a 3 lot of gaps, but there are gaps.

4 And that's what we -- we filled those gaps 5 for Columbia and for Grant Gulf, we filled those gaps 6 by writing RAIs and having responses. And that was a 7 fairly painful process, right?

8 And the idea of Hope Creek was, we could 9 fill them and keep them full and not have to deal with 10 that again. So, essentially, we, as part of that 11 evaluation, we evaluated the updated processes and we 12 referenced that in the safety evaluation. So, the 13 idea is that now, we won't have to reperform that 14 activity.

15 But all Topical Reports are subject to 16 this kind of issue. This one was particularly painful 17 because it was so old and it predated so much of the 18 guidance that we're looking at today.

19 MR. DARBALI: So, some feedback I would 20 provide on a slide for the pre-application meeting on 21 SDOE would be a bullet that says, a matrix will be 22 provided tying to the Reg Guide 1152 criteria. The 23 plant-specific action item from the Topical Report 24 will be addressed.

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132 1 performed after the LAR is expected, if the licensee 2 thinks they want to have a commitment regarding SDOE, 3 it would be good to point that out, the LAR will 4 contain commitments for some SDOE activities.

5 It doesn't have to be very specific, but 6 something to give the staff a heads up, something to 7 expect when the LAR arrives.

8 MR. STATTEL: So, I have a question, I 9 guess, for the licensees. So, you all have cyber-10 security programs, right?, required by Part 72, right?

11 And those were evaluated by the NRC?

12 MR. NOVAK: Yes, they were.

13 MR. STATTEL: Right. So, when you're 14 putting a new critical digital asset in, like an RPS 15 system or whatever, you have a process for --

16 MR. NOVAK: Yes.

17 MR. STATTEL: -- basically including that 18 in your list? You perform your vulnerability 19 assessments, you -- so, is that described? I mean, I 20 -- do you point to that? Is it something the NRC 21 already has in-house?

22 Because I know we've written in our 23 evaluations that we have that expectation that this 24 will be incorporated into your ongoing cyber-security 25 program, but I'm not sure how the logistics of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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133 1 work.

2 MR. HERB: Okay.

3 MR. STATTEL: It's a different group that 4 evaluates those, it's not --

5 MR. HERB: Actually, this -- it's not OPS, 6 okay. And that program is under NSIR.

7 MR. STATTEL: Right.

8 MR. HERB: But we have -- we're required to 9 have a program in place where when we introduce a new 10 critical digital asset, it has to be classified, it 11 has to be -- there has to be an assessment done on the 12 vulnerabilities for that.

13 And then, the technical and programmatic 14 controls required by our cyber-security plan have to 15 be applied. And so, there is -- everybody design 16 change process, and I think I'm speaking for 17 everybody, handles that aspect. So, it's handled on 18 a component by component basis.

19 But there are two aspects to everybody's 20 cyber-security plan. There are the technical controls 21 that are specific to the devices and components that 22 you add and there are the programmatic controls that 23 apply to everything.

24 So, you have -- essentially, there's 25 secure development environment controls and secure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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134 1 operating environment controls are defined in our 2 cyber-security plan. We have to provide isolation, we 3 have to determine what level it's going to be.

4 In this case, these safety-related systems 5 will all be on Level 4, what we call Level 4 at our 6 plant, and I think they're probably the same 7 everywhere. And so, you're -- enforces communications 8 protocols on them, you can't have two-way 9 communications, it has to be one-way out only.

10 MR. STATTEL: So, that's this --

11 MR. HERB: So, there's a lot of chances --

12 MR. STATTEL: This reference you have to 13 Cyber-Security Level 4, you're referring to how it's 14 classified in your cyber-security program?

15 MR. HERB: Yes.

16 MR. STATTEL: Okay.

17 MR. HERB: Yes, Level 4 is the highest 18 level of security, it's a central piece. Most cyber-19 security plans have, I guess, lines of defense, that 20 go all the way up to Level 0. Level 0 is the scary 21 worldwide web. And Level 1.

22 And then, Level 2 is typically our 23 business LANs are behind firewalls and access -- and 24 we typically have very little access back into our 25 plants from Level 2. It's all -- and then, you have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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135 1 Level 3, which is generally our information sharing 2 systems and emergency response.

3 And then, you have Level 4, which is our 4 controls. And we have to segment our safety-related 5 controls from our non-safety controls. And then, you 6 have some functional segmentation as well, to prevent 7 propagation of different cyber threats throughout the 8 thing.

9 So, a lot of these things, they're very 10 complimentary with the SDOE controls. And so, we 11 would do those together at that same time. This 12 hazards analysis would help the whole system-level 13 assessment.

14 And then, there's lots of different 15 methodologies that people use. We did a brute force 16 methodology when we initially did our cyber-security 17 program, but there's -- EPRI has the technical 18 assessment methodology, which is the TAM, they call 19 that, and I think you guys were familiar with that as 20 well.

21 So, we use any number of those things to 22 do those assessments and apply those controls. Those 23 controls would -- if you do it early enough, then 24 those become requirements, and that's where we track 25 those into the system-level requirements, especially NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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136 1 for the system-level controls, technical controls.

2 But the programmatic controls, control of 3 access, separation of functions, and those things, 4 those happen -- portable media and mobile device 5 controls, we're not allowed to plug anything in. So, 6 those controls, they come with the cyber-security 7 program, so we would just leverage those in SDOE.

8 MR. ODESS-GILLETT: So, Samir and Rich, I 9 think what we would anticipate is that the LAR would 10 describe how the cyber-security controls of the plant 11 would encompass the requirements. And that those 12 could then, if you want, become inspection items that 13 you would want to verify that indeed those security 14 controls really do encompass the --

15 MR. DARBALI: For the secure operational 16 controls, yes. Those, I'm not really worried about, 17 because those are standard, again, we issue safety 18 evaluation after the fact, so all of that falls into 19 inspection anyway.

20 It's more of, on the vendor side, that we 21 would be focusing more on those final implementation 22 and testing.

23 MR. ODESS-GILLETT: Okay.

24 MR. DARBALI: And to your discussion, Ray, 25 yes, a lot of what's SDOE -- I think SDOE and cyber NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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137 1 are the same thing, but talking different languages.

2 And the staff has to do a little bit of translating, 3 because nothing in the Reg Guide or in our operating 4 reactors talks about Level 4.

5 And we try not to do an NSIR-type 7354 6 evaluation in our safety evaluation. So, we're very 7 careful in that language. So, if you're saying, oh, 8 it's Level 4, we would probably call it, it's one-way 9 communication --

10 MR. HERB: Right.

11 MR. DARBALI: -- or make sure that there's 12 no remote access translated to that.

13 MR. HERB: And I think that's maybe the 14 value -- and I really wasn't buying into the value of 15 a matrix, but maybe the matrix would help a lot here.

16 Because the matrix could tie some of these 17 requirements to our cyber program as well.

18 MR. DARBALI: Right. From a common sense 19 point of view, if you're doing cyber-security, you're 20 pretty much covering everything --

21 MR. HERB: Yes.

22 MR. DARBALI: -- in the Reg Guide, but 23 there's some translating to that, so a matrix would be 24 helpful.

25 MR. ODESS-GILLETT: Right. And we have to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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138 1 remember that Level 4 includes both safety and non-2 safety --

3 MR. HERB: That's exactly correct, yes.

4 MR. ODESS-GILLETT: -- so, you still have 5 to show your isolation between the two --

6 MR. HERB: Right.

7 MR. ODESS-GILLETT: -- within Level 4.

8 MR. HARRELL: One of the things that I 9 tried to do in writing this section was avoid using 10 Reg Guide 5.71 type terms in this section, because I 11 did not want to invoke an NSIR review.

12 MR. HERB: Right.

13 MR. HARRELL: So, I was very careful in 14 what I chose to include and not include.

15 MR. HERB: But every example you see, they 16 reference their cyber plan. And even here --

17 MR. HARRELL: Yes.

18 MR. HERB: -- they reference cyber plan.

19 And we probably would still, too, but maybe not in the 20 LAR. We would talk to it in --

21 MR. STATTEL: And that's my next question.

22 So, would it be useful to describe how the system will 23 be incorporated into your cyber-security plan or 24 provide a reference to that process? Or are we 25 purposefully avoiding that?

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139 1 MR. HERB: I think we're purposefully 2 avoiding it, on our end, mainly because it's this, we 3 haven't really done it. Now that we have a cyber 4 program in place that's fully inspected and accepted 5 by the NRC, we might be a little more amenable to 6 combining those a little bit.

7 I think we've always had the question of, 8 where do you really address cyber in the LAR? Because 9 it's silent, ISG-06 is silent on that piece. And so, 10 you almost -- you have to address it, it has to be 11 addressed.

12 And it will be addressed in the design, 13 because we address it in the design, period. And so, 14 it seems natural that we would also address it in the 15 LAR, but there's just no guidance currently on it in 16 the ISG-06. And so, maybe that's an area that we need 17 to discuss further.

18 MR. ODESS-GILLETT: Well, Ray, I would 19 expect that the licensee would want to leverage their 20 existing procedures --

21 MR. HERB: Oh, you're absolutely right. We 22 would not have separate SDOE procedures or --

23 MR. ODESS-GILLETT: Right.

24 MR. HERB: -- even SDOE processes, we would 25 use our own cyber processes to do that.

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140 1 MR. DARBALI: And you can reference those.

2 MR. HERB: Yes.

3 MR. DARBALI: Just say, reference those 4 cyber-security procedures as meeting the Reg Guide 5 secure operation requirement criteria.

6 MR. HERB: But because of that firewall 7 between NSIR and --

8 MR. DARBALI: Right.

9 MR. HERB: -- NRR, we try to respect that.

10 But we -- it's kind of like the channel versus 11 divisional, eventually those things fall away when you 12 get out in the field. Well, we're out in the field, 13 so we have to deal with both of them.

14 MR. DARBALI: Right.

15 MR. HERB: And so, we're just a little bit 16 reluctant to reference that in the material. But when 17 we actually get into it, we're going to use as much of 18 the cyber stuff as possible, we're not going to redo 19 anything separate.

20 MR. HARRELL: And I can see adding a 21 statement to this that says something along the lines 22 of, we will -- the licensee has evaluated the SDOE 23 aspects and will integrate them into the cyber-24 security plan. But not much further than that.

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141 1 a security evaluation, a cyber-security evaluation, 2 but we would be coordinating with NSIR. So, this 3 licensee is doing this type of mod and --

4 MR. STATTEL: Why would we do that?

5 MR. DARBALI: Just for awareness, 6 information. Again --

7 MR. STATTEL: I don't think -- I don't 8 envision NSIR being part of our --

9 MR. DARBALI: They would not be.

10 MR. STATTEL: -- license amendment process.

11 MR. DARBALI: No. No, but just so they 12 know, if they're developing inspection plans or 13 priorities or identifying which plants -- and again, 14 more now that some of these mods are going to be new, 15 in the future, I would expect they're all common, so 16 it doesn't affect NSIR performs their plan. But for 17 awareness, here's a plant that's doing something.

18 MR. HARRELL: Maybe coordinate is too 19 strong a word, inform --

20 MR. DARBALI: Okay.

21 MR. HARRELL: -- might be a better word.

22 MR. DARBALI: Right, correct. I know in 23 the past, I was looking at some of the recommended 24 inspection items, some of them were cyber-security 25 related.

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142 1 Whether we do that or not, again, it's 2 going to depend on that relationship between us and 3 NSIR. Do they want -- because some of those predated 4 the full implementation with the cyber-security 5 program. And I think we're past our time.

6 MR. GOLLA: All right. We've arrived at 7 lunchtime. Let me just adhere to the protocol and ask 8 if there are any members of the public on the phone, 9 I don't think there are, but if there are and someone 10 would like to ask a question, a member of the public, 11 or make a comment, please do so now.

12 All right. There's no member of the 13 public, unless they're just listening. Okay. So, 14 lunchtime, come back at about 1:10. Okay. That'll 15 give a little bit more than an hour.

16 (Whereupon, the above-entitled matter went 17 off the record at 12:06 p.m. and resumed at 1:13 p.m.)

18 MR. DARBALI: Okay, we are back from 19 lunch. We are going to go into the pre-application 20 coordination meeting discussion.

21 We are trying to get the projector working 22 in the room but everyone has the slides. So I will --

23 MS. GOLUB: I'll go grab slides. I'm 24 sorry. I didn't realize that --

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143 1 pre-application coordination meeting or were we just 2 going to jump in? You tell me what you would like.

3 MR. DARBALI: Yes, I was going to hand it 4 over to you.

5 MS. GOLUB: Okay.

6 So the next item is the pre-application 7 coordination meeting. So this part of the tabletop 8 material was prepared by, and I think I mentioned this 9 earlier, we started with the Hope Creek Power Range 10 Neutron Monitor, Phase 0 meeting presentation. And 11 then we looked at the guidance that was in ISG-06 Rev.

12 2 for the pre-application coordination meeting, which 13 is essentially the same as the Phase 0 meeting. We 14 updated both of those, that part of the ISG was 15 updated for both review processes.

16 And so this is an attempt to see if what 17 we think meets the intent of that portion of the 18 guidance, if we're all on the same page. And so the 19 one thing that we didn't do is that there was -- and 20 you'll kind of see this in here -- there was some 21 architecture information that was there. There's a 22 needs and benefits. Some of that material -- I left 23 the slide in there just to indicate that that would be 24 provided as part of the presentation but because this 25 is just -- you know the intent of this was not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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144 1 technical, it was strictly, the intent of this piece 2 of the tabletop is really around are we meeting the 3 intent of the guidance.

4 And so what you're going to see is you're 5 going to see a mix of Hope Creek material and then 6 some made up material. And so you know there was a 7 section in the Hope Creek presentation which they had 8 selected some NRC guidance documents and chosen to 9 explain how their application would meet them. And we 10 changed that a little bit to say additional NRC topics 11 of interest. And we added to those topics based on 12 feedback we had gotten during our development process 13 for the alternate review process.

14 And like for example, we added human 15 factors just because that was a topic that had come up 16 on the Hope Creek review. We added the PSAIs because 17 we know that's a big topic, vendor oversight class.

18 We added some additional topics there.

19 So outside of that you know we're 20 certainly open to your feedback and questions.

21 MR. DARBALI: Great. So I think the 22 advantage of the pre-application meetings is the 23 earlier you can come and approach the NRC staff, the 24 better. And I don't think there is any standard 25 guidance as to what should be covered in a pre-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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145 1 application meeting presentation.

2 So the advantage of you coming in earlier 3 is you can follow-up on Phase 0 meetings and focus on 4 different topics. So for example, this morning we are 5 talking about SDOE. If we look at the slide and say 6 oh, you know if you come for a second Phase 0 meeting, 7 could you point -- identify these areas, something 8 like that.

9 I think you covered a lot of material in 10 it. The key is to having the right people in the room 11 both from industry and the NRC. So I would imagine 12 through the project manager we would try to send the 13 slides ahead of time so we can identify which staff 14 should be in the room for that.

15 MS. GOLUB: Oh, yes, that's a good point, 16 Samir. You're right. So we added, for example, we 17 did add a slide on human factors considerations based 18 on some of the topics that Hope Creek had answered.

19 So you're right, we'd have to make sure we had 20 somebody potentially from that branch in the room.

21 MR. DARBALI: Right.

22 MS. GOLUB: The other part is, I guess, 23 you said licensee and NRC but I was thinking the 24 vendor, too. Obviously, the vendor would need to be 25 represented, especially on that following up of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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146 1 topical report discussion. There may be -- there 2 probably will be changes that were made to the 3 application where something would be diverting from 4 what previously approved and the vendor could 5 certainly speak to that.

6 MR. STATTEL: So I mean we do have some 7 guidance on pre-application meetings in ISG-06.

8 MS. GOLUB: That's what this -- that's 9 what this was based on. I went down the line through 10 that guidance.

11 MR. STATTEL: Did you think that there 12 were any gaps or differences between what was done for 13 Hope Creek during that meeting and what we have now 14 put into the ISG-06?

15 MS. GOLUB: Well so human factors is one 16 but I don't think -- I actually can't even remember.

17 Is it in the ISG? We'll have to open up -- if we ever 18 get this thing back, we can take a look at Section 19 C.2.2.1 but I can't remember off the top of my head.

20 But the new guidance, the new ISG, it did 21 have additional areas that were not in the Hope Creek 22 Phase 0 meeting.

23 MR. STATTEL: Right. Right.

24 MS. GOLUB: Well some of these were in 25 Hope Creek. But you know like PSAIs I don't think was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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147 1 in Hope. Vendor oversight plan certainly was not.

2 MR. HERB: Oh, in the existing one or the 3 old one?

4 MS. GOLUB: So I think the question I'm 5 trying to answer is were there gaps between what was 6 in the Hope Creek Phase 0 meeting presentation and 7 what's in the current IS -- the current draft ISG for 8 Phase 0 or pre-application coordination meeting.

9 And the answer is yes, there were gaps.

10 And those are the holes that I tried to fill in this 11 presentation.

12 MR. DARBALI: Okay.

13 MS. GOLUB: So that's why you're going to 14 see there's a bunch of extra slides with some slightly 15 made up stuff on there. And that's just me trying to 16 show you that -- this was actually another one, the 17 SharePoint site for model sharing. I mean that's 18 something that we have in the current guidance but 19 that should be addressed in the pre-application review 20 meeting -- the pre-application coordination meeting.

21 And so, essentially, we kind of went down 22 the line there.

23 MR. DARBALI: So I guess the question we 24 were addressing is was human factors in the list on 25 the topics. They're looking.

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148 1 MS. GOLUB: Oh, no, it is not. But you 2 know where we stuck this? It was there's --

3 MR. HARRELL: Other unique and complex 4 topics.

5 MS. GOLUB: Yes, other unique and complex 6 topics. And so because we knew about the -- and 7 remember, this is something we hoped to put into our 8 industry guidance document. Because we knew it was an 9 issue that had come up during the acceptance review 10 for Hope Creek, we thought if we put it in here that 11 is a good sign to the licensee that you should think 12 about it up front, address it, you know find out when 13 you go to the pre-application coordination meeting if 14 there is something the staff is looking for. You know 15 it's a good time to get that information.

16 MR. HARRELL: We could have listed just 17 about every branch you've got and it would be a 18 useless waste of NRC time. So we tried to focus on 19 the people we knew needed to be in that list. And if 20 we give you the slides in advance, then you should be 21 able to see what we're doing and decide, oh, I need 22 HFE, I need, I need, I need, I need.

23 MS. GOLUB: Yes, and see even like this 24 application development process business you know, 25 kind of addressing Section D.4. That's a newer item NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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149 1 based on the new process. And so there's a slide in 2 here that talks about that.

3 But did you guys, did you have any -- see 4 anything, missing anything that you thought -- okay, 5 so that's good. That's good.

6 MS. VENKATARAMAN: So when do you need it, 7 right? The schedule is usually a discussion.

8 Schedule is usually a discussion item in this. So 9 that is something that you would include.

10 MS. GOLUB: The schedule? Yes, so we have 11 the schedule on slide 26.

12 I'm not sure, am I answering you?

13 MS. VENKATARAMAN: Yes.

14 MS. GOLUB: Okay.

15 MS. VENKATARAMAN: I think that's right.

16 MS. GOLUB: Yes, it's kind of a -- I mean 17 this is the Milestone Schedule and I think one of the 18 items -- oh, it's 27. Okay, thank you. Thank you.

19 MR. BURZYNSKI: The very last page in the 20 back.

21 MS. GOLUB: Yes.

22 MS. VENKATARAMAN: And sometimes in 23 preliminary slides are not getting like initially --

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150 1 given, sometimes there's an email with the scope. And 2 that establishes who all would participate in the 3 public meeting that is done so, for the planning for 4 the meeting.

5 But definitely, when the meeting notice 6 goes out, the slides go to the public, who also gets 7 to know what this is about. So one or two days before 8 so that everyone has this information.

9 MS. GOLUB: Yes, good point.

10 I don't think -- did you introduce 11 yourself? I'm not sure that everybody -- I introduced 12 myself to you but I don't know if everybody here knows 13 who you are.

14 MS. VENKATARAMAN: So me? I'm the 15 culprit?

16 MR. DARBALI: Yes.

17 MS. VENKATARAMAN: Yes, my name is Booma 18 Venkataraman. I am a project manager from the 19 Division of Operator Reactor Licensing currently 20 serving as an Acting Branch Chief. So thank you.

21 MR. DARBALI: Yes. Sorry for not 22 introducing you before. So Booma is here to provide 23 the licensee project management side of the equation.

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151 1 only looking at the technical stuff. They're focusing 2 more of getting that.

3 MS. VENKATARAMAN: Big picture, yes.

4 MR. DARBALI: Yes, so thank you, Booma.

5 So a question Booma. Is that slide 6 sufficient as far as schedule or would you prefer a 7 more detailed list of dates? Because we kind of have 8 to abstract information from this.

9 MR. ODESS-GILLERT: So there's a slide 10 previous to this that's got some milestone dates on 11 it.

12 MR. DARBALI: Oh, okay.

13 MR. ODESS-GILLERT: There you go.

14 MS. VENKATARAMAN: Yes, I think that this 15 something where it's when are you going to submit and 16 basically when do you need it. So --

17 MS. GOLUB: This is something that -- yes.

18 MR. DARBALI: Thank you.

19 MR. HOOTEN: And the more detailed chart 20 would be something to discuss and shift dates 21 appropriately.

22 MS. GOLUB: Yes, so I mean I think Dave's 23 raising a good point, just that there is a more 24 detailed schedule but this is a pre-application 25 coordination meeting. And so the licensee knows what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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152 1 the bigger milestones they were shooting for but there 2 may be dates on this smaller schedule, which may shift 3 as the project moves.

4 And I know there is something in the ISG 5 and I don't know if it's in this section or in a 6 different one where there is a line about the NRC and 7 the licensee understanding that it's a living schedule 8 and that the NRC will be kept informed of that 9 schedule.

10 MS. VENKATARAMAN: Although there is one 11 thing about once they -- in the pre-submittal meeting, 12 we discuss about the coordination and the scope. And 13 then you submit your application. And then if you do 14 get application acceptance review, then an acceptance 15 review letter or an email goes out. There, we commit 16 to this. So that's based on you know an 17 understanding.

18 And I don't know if that kind of shifts 19 unless -- and so maybe you might speak to it, 20 especially with the alternate review process.

21 Typically, that's what we work to.

22 MS. GOLUB: Yes.

23 MS. VENKATARAMAN: Yes.

24 MS. GOLUB: Yes, I guess I think what Dave 25 was pointing out was there are some individual dates NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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153 1 potentially on here. So not these bigger milestones 2 but some of the individual dates.

3 MR. HOOTEN: Right, like insulation prep, 4 all of that.

5 MR. HARRELL: And some of the dates may 6 shift based on discussions in the coordination 7 meeting. I wish we'd come up with an acronym that is 8 pronounceable.

9 MR. DARBALI: Yes, and you know we are 10 talking about to utilize EMOD. So it's not uncommon 11 for it to be planned for one outage and it gets 12 pushed. I don't think it's necessary to provide 13 backup installation dates at this point and you shoot 14 for what you can, would be comfortable with at this 15 stage.

16 MR. ODESS-GILLERT: Right and to think 17 about it from the alternate review process, the 18 installation dates really don't have much of an impact 19 on the review.

20 MS. GOLUB: I think that -- I mean unless 21 the staff has more feedback, I think that's all we 22 have for this section of the agenda.

23 MR. DARBALI: Yes, and that puts us right 24 on time for the next topic. So we will go into the 25 resolution of topical report plant-specific action NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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154 1 items.

2 MR. ODESS-GILLERT: Dave, why don't you 3 sit where I am? And we'll get the -- so you can be 4 near the phone so that the others can here.

5 MS. GOLUB: Do you guys have one of these, 6 too?

7 MR. ODESS-GILLERT: You need this, Dave.

8 MS. GOLUB: Oh, yes, that's a good point.

9 That's a good point. So this presentation, again, 10 we're not going to go through this slide by slide.

11 But we would certainly, the presentation, so how we 12 did the PSAIs was Dave Harrell put together a 13 presentation that philosophically laid out how we 14 wanted to approach the different types of PSAIs, 15 understanding that the SERs that were written for 16 these licensing topical reports were under ISG-06 Rev.

17 1. And so the PSAIs that were included, some of them 18 say NRC will review or you know it has that kind of 19 language in it.

20 So Dave Harrell kind of put together a 21 presentation philosophically that talked about our 22 approach to answering those. And then Dave Hooten put 23 together specific LAR language addressing specific 24 PSAIs that would be examples of each of these cases 25 that Dave Harrell is talking about.

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155 1 So I guess, Dave, you know I think maybe 2 it would be good to not present-present it but to go 3 through each of the cases. And we would love your 4 feedback to hear if we're kind of along the same --

5 you guys were thinking along the same lines that we 6 are or figure out where we're at.

7 MR. STATTEL: Before you launch into that, 8 I just want to mention in the first few top four 9 bullets, the Tricon, the Common Q, the staff was 10 writing these with -- basically with the assumption 11 that this would be used for a major system upgrade 12 that would require a license amendment. They were not 13 thinking about 50.59 upgrades.

14 So the plant-specific action items are 15 written -- when the subsequent license review takes 16 place, the NRC staff will perform this type of review.

17 And we recognized a little while back that 18 we also expect licensees who are doing 50.59s to 19 address those same actions on their own. So you'll 20 see in the newer version, the newer topicals the 21 wording is a little bit different. And so we expect 22 the actions to be addressed, not necessarily by the 23 NRC.

24 So I think it's more of a problem for the 25 older topical reports.

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156 1 MS. GOLUB: Yes, and we did it -- I think 2 it was the Steve list, actually. I think Steve had 3 gone through and put together a list of all of the 4 PSAIs from all of the approved.

5 MR. STATTEL: Right.

6 MS. GOLUB: And we could see that 7 evolution as the topical reports were newer.

8 MR. HARRELL: Basically, our approach has 9 been the same as yours. Either the NRC or the 10 licensee needs to look at the things that are listed 11 as either plant-specific or application-specific 12 action items.

13 Next slide.

14 Being a good engineer, I ended up, we 15 really just want to look and see, we want to talk 16 about is this approach the right kind of approach.

17 Next slide.

18 So I came up with four cases. There is a 19 case that I can see where the PSAI can be incorporated 20 in system-level requirements with the appropriate 21 review analysis test V&V type activities and be 22 covered, done.

23 There's another case where something that 24 the vendor may have done in their software process, 25 hardware process, systems integration process will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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157 1 resolved within two of the PSAIs. It gets evaluated 2 in the LAR as this has been done, this has been fixed, 3 and it gets closed actually by the NRC.

4 There's a case where the licensee 5 committed to new and revised procedures to resolve the 6 PSAI or there is also sort of a secondary case where 7 the NRC reviews the tech spec changes. And that's 8 going to get handled not like one, maybe not quite 9 like two, but it's a little bit different.

10 And then there's the case four where the 11 regulatory guidance has changed since the topical 12 report was issued.

13 And next slide. We'll just walk through 14 them fast.

15 If I can resolve the ASAI through system 16 requirements documents, the implementation is part of 17 the LAR addresses the ISG-04 aspects. Implementation 18 is part of the licensee's responsibility to track to 19 completion. And vendor oversight and the vendors V&V 20 process would track that to a field implementation.

21 And I gave an example of one out of -- I like Tricon.

22 I worked on the LAR or not the LAR but the topical 23 report so I know what's embedded in it.

24 Questions/comments?

25 Next slide.

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158 1 MR. STATTEL: Did you think the way those 2 were evaluated on Diablo Canyon, do you think that was 3 adequate?

4 MR. HARRELL: It worked.

5 MR. STATTEL: I think for the most part, 6 they responded and resolved all the PSAIs. And we 7 reevaluated it and there was a section in the SE that 8 has our evaluation of that but I don't remember there 9 being any issues with that.

10 MR. HARRELL: The only issue with this one 11 is for the Tricon, in particular, it says the NRC 12 will.

13 MR. STATTEL: Okay. Right, that's 14 probably true, yes.

15 MR. HARRELL: So the vendor's V&V process, 16 the licensee's vendor oversight will make sure that it 17 did, indeed, get done.

18 MR. STATTEL: Okay.

19 MR. HARRELL: Slight subtle difference.

20 Taste 2.

21 There some things that I can evaluate the 22 change, write it up, put it in the LAR. It's been 23 done or it's been done previously by the vendor or in 24 the subsequent years after the SE was issued.

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159 1 in the LAR. Yes, we can do that no problem. At least 2 we can address the SDE program when we write the LAR.

3 It may change as time progresses and we will track 4 that change to completion.

5 Case three, admin procedures and tech spec 6 changes are an interesting problem. The tech spec 7 changes, obviously you guys are going to get to 8 evaluate and that's got to be in the LAR.

9 And the plant procedure modifications, I 10 suspect, will end up being a commitment on the 11 licensee's part, too. We will generate the 12 appropriate procedures because, quite frankly, 13 procedures are one of the last things that we all too 14 often do.

15 MR. STATTEL: I was thinking the same 16 thing.

17 MR. HARRELL: Well, the design changes 18 that I used to write, the procedure -- the suggested 19 procedure mods were in the design change and I would 20 end up having to wait for the OPS procedure writers to 21 actually implement what they chose to do instead.

22 Again, no big deal.

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160 1 we're going to address how the licensee's programs and 2 procedures, and standard practice will ensure that the 3 licensee staff is appropriately trained to do whatever 4 needs to be done, however much of the maintenance 5 activity they take on.

6 And we'll make sure that there are 7 appropriate procedures in place to deal with training 8 of OPS, maintenance, engineering as appropriate.

9 MR. STATTEL: Okay. Essentially, that 10 comes from BTP 14, right?

11 MR. HARRELL: Yes, except we probably 12 won't write a training plan for you, as required by 13 BTP 7-14 or as indicated by BTP 7-14 because there are 14 existing plans, procedures --

15 MS. GOLUB: Programs.

16 MR. HARRELL: -- programs in place at the 17 licensee to make sure that the training needs are met 18 through I want to say IMPO processes but I probably 19 shouldn't say that in public.

20 MR. BURZYNSKI: No, it's the training rule 21 --

22 MR. HARRELL: The training rule.

23 MR. BURZYNSKI: -- that is administered or 24 the certification of it is administered by IMPO but 25 it's --

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161 1 MR. HARRELL: Yes, there we go.

2 MR. BURZYNSKI: -- the training rule.

3 MR. STATTEL: So you would still respond.

4 In the license application, you would respond to the 5 ASAI.

6 MS. GOLUB: Yes.

7 MR. STATTEL: And you would basically 8 point to your existing training program --

9 MR. HARRELL: Yes.

10 MR. STATTEL: -- and processes.

11 MS. GOLUB: Yes, and you're going to see 12 that example in the specific PSAIs that we do next.

13 MR. STATTEL: But you close out the PSAI, 14 essentially.

15 MR. HARRELL: Yes and the closure action 16 in the Path 2 closure is addressed in the LAR.

17 MS. GOLUB: In the LAR, right.

18 MR. DARBALI: So I think the comment is 19 that there is a PSAI that comes from the topic report 20 after evaluation but the ISG-06 no longer asks you to 21 provide that information.

22 MR. HARRELL: Yes.

23 MR. DARBALI: Okay but it's still --

24 MR. HARRELL: It's listed before.

25 MR. DARBALI: -- covered.

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162 1 MR. HARRELL: It's still covered. We'll 2 still make sure that the staff, the licensee staff is 3 trained to use the equipment appropriately. And 4 appropriate procedures are written to do maintenance 5 activities.

6 MS. GOLUB: And the PSAI will still be 7 addressing it.

8 MR. HARRELL: Uh-huh.

9 MR. STATTEL: Now the previous you were 10 talking about procedures that aren't going to be 11 developed yet.

12 MR. HARRELL: Yes.

13 MR. STATTEL: So you said they would be 14 commitments. So you're not really closing out that 15 PSAI.

16 MR. HARRELL: We're providing a promise to 17 close.

18 MR. STATTEL: Right and that would be an 19 area where we could talk about it but that might need 20 to be more than a commitment.

21 MR. HARRELL: That's tomorrow's 22 discussion.

23 MR. STATTEL: Right.

24 MR. HARRELL: So we're foreshadowing the 25 interesting discussions for tomorrow morning.

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163 1 MR. STATTEL: Because up until now, we 2 have the approach when we evaluate the PSAIs, our 3 intention is to have every one of those completely 4 closed out, done, approved, before we issue the 5 license amendment.

6 So what we're talking about now is there's 7 going to be a subset of those that would be deferred.

8 MR. HARRELL: Complete closure would be 9 deferred, yes.

10 MR. STATTEL: Right. Okay.

11 MR. HARRELL: The reality is on a lot of 12 plant installation actions, my OPS procedure writers 13 have been finishing the procedures as we install the 14 equipment or as we did pre-op testing. So that's not 15 at all uncommon.

16 MR. STATTEL: That's my experience, too, 17 yes.

18 MS. GOLUB: So Dave, I mean when I hear 19 you say that, what that makes me think is that even 20 under the current ISG-06, the requirements for doing 21 certain -- this is not a good example.

22 MR. HARRELL: Let's go back to case three.

23 Actually --

24 MS. GOLUB: But there are certain 25 procedures that I mean they're not written even now at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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164 1 the time of LAR issuance. I mean even now they --

2 MR. STATTEL: You're right. And actually 3 I was looking -- in preparing for this meeting, I was 4 looking through some ASAIs. I don't even remember 5 which vendor it was but the training plans was one of 6 them. And when you follow that thread through, even 7 in those cases, we didn't really close out that PSAI.

8 We accepted the response but we ended up putting a 9 recommended inspection item --

10 MS. GOLUB: Inspection items, exactly.

11 MR. HARRELL: Yes.

12 MR. STATTEL: -- for closure. That's 13 where they ended up.

14 MS. GOLUB: And even for procedure 15 changes, you know certain nuances within these 16 platforms, there is something that you required. I 17 can't remember. One of them was a key lock. I 18 thought we looked at a couple of things.

19 MR. STATTEL: Right. There are several 20 references to procedures in the inspection items.

21 MS. GOLUB: Right and those became 22 inspection items. So they didn't necessarily become 23 license conditions or anything along those lines.

24 They became inspection items. You had to go back and 25 make sure the licensees actually modified the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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165 1 procedures appropriately.

2 MR. STATTEL: Right, okay. So none of 3 this is unprecedented.

4 MS. GOLUB: No, it's not.

5 MR. DARBALI: Right. We'll talk about 6 this more tomorrow but the recommended inspection item 7 is a confirmatory activity that has -- it's unrelated 8 to the staff's safety determination.

9 MS. GOLUB: Yes.

10 MR. DARBALI: If you provide that type of 11 commitment, the staff should determine if we need that 12 commitment or we rely on that commitment to make our 13 safety determination. If that's the case, then it's 14 probably going to be elevated to a condition.

15 If we say oh, well that's a nice thing to 16 have but I don't need it to make my safety evaluation, 17 then we'll probably leave it at commitment but it can 18 still be an inspection item.

19 MS. GOLUB: That's right. That's right, 20 one doesn't preclude the other.

21 The only point I was making is that 22 especially for procedures and that type of thing, it's 23 really no different under the alternate review process 24 as it was from the previous tier processes.

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166 1 didn't necessarily require -- they were not 2 necessarily commitments in the past.

3 MS. GOLUB: Right. That's right.

4 MR. STATTEL: They were made into 5 recommended inspection items.

6 MS. GOLUB: Right.

7 MR. STATTEL: So our approach to creating 8 the recommended inspection item list was if the SRP is 9 telling me to do something that I can't do, you don't 10 have a training plan, you don't have procedures, then 11 automatically, I'm going to put that into a 12 recommended inspection item. And that's how those 13 lists got started. Okay?

14 We don't ask the licensee to make 15 commitments. Right?

16 MS. GOLUB: Right.

17 MR. STATTEL: And they've never 18 voluntarily made commitments to that effect.

19 MS. GOLUB: Right.

20 MR. STATTEL: So if we want to change the 21 guidance on that, the policy on that, I mean we can 22 talk about that.

23 MS. GOLUB: I don't think -- I mean I 24 don't think so.

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167 1 commitment but in the past we have not done that.

2 MS. GOLUB: Yes. I mean, again, this 3 portion is no different under the alternate review 4 process to the tier process. So licensees do not make 5 commitments in the past -- formal regulatory 6 commitments in the past to do this. So I can't think 7 of a compelling reason why they would in the future.

8 You always have those inspection items.

9 MR. STATTEL: Well, the reason I mentioned 10 it is because you say you're going to make a 11 commitment out of it.

12 MR. HARRELL: I used the word may.

13 MR. STATTEL: Okay. Okay.

14 MS. GOLUB: Good comment, Rich.

15 MR. DARBALI: I like that comment.

16 MS. GOLUB: I like Rich's comment, yes.

17 Strike that from the -- strike that. Let 18 the record reflect that the licensee takes it back.

19 MR. DARBALI: I underlined it because it's 20 not in the list of tomorrow's commitments. We could 21 discuss it then.

22 MR. STATTEL: And that's why. That's why 23 it sticks out.

24 MR. DARBALI: So I think we can go now to 25 the examples.

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168 1 MR. HOOTEN: All right. Can everyone hear 2 me?

3 Okay, so just a little context setting 4 before we look at the specific examples. And I'll 5 read a couple snippets from ISG-06 Rev. 2 Draft, 6 Section D.5.1.2.

7 In the case of the alternate review 8 process, the licensee should describe the process for 9 addressing those plant-specific items related to 10 detailed design, implementation, testing, et cetera, 11 et cetera. Some topical reports include plant-12 specific items stating that the NRC staff should 13 review detailed design, implementation, testing, et 14 cetera, et cetera, activities. For the alternate 15 review process, this is to be interpreted as the role 16 of the licensee in accordance with the licensee's QA 17 program and vendor oversight plan.

18 So that was the context in which I 19 constructed these examples. So just to be clear on 20 that.

21 All right, so the idea of how this was 22 constructed is it was adapted from the Diablo Canyon 23 LAR. And the perspective that was taken was we'll 24 look at each of the items in the Diablo Canyon LAR and 25 if the item looked like it was completed fully prior NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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169 1 to when the LAR would have been submitted under the 2 alternate review process, it wasn't included on the 3 list. But if it was either in part or in its entirety 4 completed after LAR submittal, it is addressed in this 5 document. Does that make sense?

6 MR. DARBALI: Sorry to interrupt. When 7 you say on this document --

8 MR. HOOTEN: The one up on the screen.

9 MR. STATTEL: Right but in a LAR you would 10 still be saying these activities?

11 MR. HARRELL: In an actual LAR, you would 12 address all of them.

13 MR. STATTEL: Right. Okay.

14 MR. HARRELL: But we figured there wasn't 15 a lot of value for this exercise to cover the ones 16 that would be completed by that point in time.

17 So this was just to give you all a flavor 18 of our thinking on how we would go about responding to 19 those ones that wouldn't be completed until later.

20 Is that reasonable?

21 MR. STATTEL: Yes.

22 MR. HARRELL: Okay. All right.

23 So there were like -- I forget -- 19, I 24 guess, total items in the Tricon topical. And I 25 identified numbers 1, 2, 4, 7, 9, 17, and 18 as being NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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170 1 partially or fully implemented after the fact or after 2 the LAR submittal.

3 So I don't know if you want to go through 4 each individual one or are there specific ones that 5 you want to talk about?

6 MR. STATTEL: Let's talk about number one.

7 MR. HOOTEN: Okay. All right so the first 8 one deals with the program manual and the ASAI 9 specifically points out that the staff did not include 10 any sort of endorsement or approval of that document 11 when the platform topical report was approved. So 12 this ASAI is for the NRC staff to perform a review, 13 and, as I read earlier, that's interpreted now as the 14 licensee, of any application-specific development 15 activities governed by that document when you're doing 16 a LAR using this platform.

17 So our proposed response was that the 18 activities governed by that program manual are 19 included as part of the system development process 20 descriptions that are addressed elsewhere in this LAR, 21 and you would list whatever those section numbers are, 22 and are evaluated in accordance with Section D.4 of 23 ISG-06. That's the part that addresses all those 24 development activities.

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171 1 the licensee is going to use the NRC's standard review 2 plan to evaluate a vendor's document -- documentation?

3 MR. HOOTEN: Well, the intention was we 4 were going to use Section D.4 of the ISG. And there 5 are places in there that then point to certain parts 6 of BTP 7-14, if you recall how D.4 is constructed. So 7 that was what I was thinking.

8 MR. STATTEL: Okay. Well, I guess where 9 this all ends up when all the dust settles, wouldn't 10 it be more appropriate for the licensee to be using 11 industry guidance to perform that evaluation?

12 MR. ODESS-GILLERT: Can I speak to that?

13 So I think that we would be informed by the regulatory 14 guidance that endorses that industry guidance if the 15 licensee is doing a vendor oversight because we do 16 want the vendor to be -- you know whatever the 17 commitments are in the LAR for those regulatory 18 guides, that those are actually met.

19 MS. GOLUB: I'm not sure we're hitting --

20 we're addressing Rich's concern.

21 MR. STATTEL: I mean do you see how it's 22 a little awkward the way it is?

23 MR. HOOTEN: Can I attempt to answer the 24 question here? If you look -- no? Okay, go for it.

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172 1 in accordance with ISG-06 D.4. And what I mean there 2 was evaluated by you all in the LAR. Because part of 3 D.4 is there is information to be provided by the 4 licensee and then there's what you're going to review.

5 MR. STATTEL: Oh, okay.

6 MR. HOOTEN: So the LAR, itself, is going 7 to have a description that you all will evaluate using 8 D.4. So that description, which in cases where the 9 program manual was approved, I would just probably 10 point to that, but in this particular case with 11 Tricon, it wasn't. There would have to be a 12 description in the LAR that you would evaluate under 13 D.4 criteria and points to BTP 7-14 and all that jazz.

14 So what the licensee would do isn't 15 evaluate it to D.4. They would evaluate it to make 16 sure that what was written in the LAR about it is 17 being done, in fact, as described.

18 That's what I had in mind.

19 MS. GOLUB: I think this might just be a 20 miscommunication.

21 MR. STATTEL: Okay so actually --

22 MR. HARRELL: Does that make sense?

23 MS. GOLUB: Uh-huh.

24 MR. STATTEL: So essentially, you're doing 25 what it was written to do. So the NRC is actually NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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173 1 perform -- is actually closing this PSAI using the ISG 2 -- using the guidance that is in the ISG.

3 So the NRC is using the guidance that is 4 in the ISG to evaluate.

5 MR. HARRELL: Right. And remember, too, 6 that the D.4 has some sections in it that will have 7 already been executed by the time the LAR is submitted 8 and others will not have but they're still described 9 in the LAR.

10 MR. STATTEL: Okay. I'm okay with that.

11 MR. HARRELL: So you will be able to 12 review the part that's been done. The part that 13 hasn't been done, it's described and then that will be 14 addressed under the vendor oversight activities to 15 make sure that what was described actually gets done.

16 That's how I was piecing it together. Is 17 that reasonable?

18 MR. STATTEL: Yes, I'm okay with that.

19 MR. HOOTEN: All right, number two also 20 relates to software development process. This gets to 21 the plans. There are four plans listed that aren't 22 executed in accordance with what's been submitted in 23 the LAR. And those are installation, maintenance 24 operations, and software safety. And the ASAI says 25 that the staff will evaluate these plans and so forth.

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174 1 Now, if you look in the Rev. 2 of ISG-06, 2 these plants are no longer listed in Appendix B.

3 Appendix B is just silent on them. So this kind of 4 ties back to what was just discussed earlier. In the 5 case of OPS, maintenance, training, and so forth, what 6 Dave Harrell described applies.

7 In addition, I did mention that in the 8 Diablo case, there was a software safety plan or at 9 least a document that contained the content that would 10 be expected at one that the vendor had already 11 produced. And so I just pointed to that for that one 12 because, obviously, utility is not going to create 13 that.

14 Any feedback on that one?

15 MR. STATTEL: I mean where does it leave 16 it? You're not able to close the PSAI the way it's 17 written, though. So these evaluations are not being 18 performed, right?

19 MR. HARRELL: The evaluations of a 20 specific plan are not being performed. But if you 21 roll back up so I can see the list of items again, 22 there's certainly licensee plans, procedures, 23 programs, et cetera, to operate the system in the 24 plant but there's no specifically -- there's no 25 specific licensee or vendor plan to do that operation.

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175 1 So this would be one of the places where 2 we would point you back to the procedures, the 3 processes at the licensee's site. Maintenance, same 4 rough idea, and software installation.

5 MR. STATTEL: Okay but this is really 6 talking about plans, though.

7 MR. HARRELL: Uh-huh.

8 MR. STATTEL: So there's no plans to 9 evaluate. That's the whole point of this.

10 MR. HARRELL: There's no plans to evaluate 11 but there is an alternative that provides the process 12 that is being used to implement those.

13 MR. HOOTEN: The idea would be -- remember 14 when Dave mentioned earlier about evaluating the 15 existing programs and processes that exist? You would 16 need to evaluate those programs and processes to 17 ensure that the content that is talked about, that is 18 being looked for in these plans is, in fact, covered.

19 It's really no different in my mind than 20 having a document that's called something different.

21 Who cares what it's called, right? It's the content 22 that matters. So the idea is whether it's being 23 implemented through a formal plan or through a process 24 or program, you verify that the content is acceptable.

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176 1 doesn't say all that. So --

2 MS. GOLUB: We're going to add that.

3 MR. HOOTEN: -- we would add that. We 4 need to add that.

5 MS. GOLUB: Right.

6 MR. DARBALI: Because I'm looking at the 7 response to the ASAI and, apart from the software 8 safety plan, the way I read it is the ISG and 9 enclosure B don't point to it.

10 MR. HOOTEN: Right.

11 MR. DARBALI: Therefore, we don't need to 12 provide it.

13 MR. HOOTEN: You're right. That's what I 14 was just trying to say.

15 MR. DARBALI: Okay.

16 MR. HOOTEN: The written response here 17 falls short and we need to tie the loop up, or 18 whatever, connect the dots back to what Dave mentioned 19 about the programs and say that the existing programs 20 and processes for training, and maintenance, and OPS, 21 and so on, and operating and maintaining the plant 22 cover the content that would be expected in these 23 plans.

24 That's not in the response.

25 MR. DARBALI: Right.

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177 1 MR. HOOTEN: That's deficient and needs to 2 be fixed.

3 MR. DARBALI: And I would imagine in a 4 response like that, where you're saying we already 5 covered it somewhere else, that could be audited in 6 the case where you say we haven't developed it yet but 7 we will and we address later as a commitment or an 8 inspection activity.

9 MR. HARRELL: Yes.

10 MR. STATTEL: And a lot of these feed 11 through inspection items, too.

12 MS. GOLUB: That's right. I mean there 13 are inspection items that have been in previous LARs.

14 MR. HOOTEN: And we looked at that 15 yesterday and kind of tried to correlate. And there 16 are number of those inspection items that are 17 directly from the ASAIs.

18 MR. STATTEL: Right.

19 MR. DARBALI: Okay.

20 MR. HOOTEN: Okay, ready for number four?

21 MR. STATTEL: So these responses, this is 22 what Diablo Canyon had written or --

23 MR. HOOTEN: No, no, no. No, the ASAIs, 24 themselves, are word-for-word what's written on the 25 topical but the responses are ones that we crafted.

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178 1 MR. STATTEL: So you just crafted those?

2 MR. HOOTEN: Yes.

3 MR. STATTEL: Okay, I see.

4 MR. HOOTEN: Now, in some cases, we 5 utilized information that was in the Diablo one. Like 6 one of these talks about there's a feature that they 7 didn't use. So you know I just basically replicated 8 that. But for the most part, these are newly crafted 9 responses.

10 MR. STATTEL: Okay.

11 MR. HOOTEN: Okay so number four has to do 12 with connecting the TriStation during operation and it 13 deals with the procedures, which was Case 3 of Dave's 14 presentation. And then it also deals with testing the 15 operational software that's produced by the TriStation 16 1131.

17 So the response here, basically, is the 18 development of those plant-specific procedures that 19 deal with connecting or disconnecting the TriStation 20 haven't been created and -- okay, wait a minute. Is 21 that what I said? I'm going off memory. I want to 22 make sure it matches what I'm really saying here.

23 Oh, okay, no. What we said that the 24 development of those procedures such that the tool 25 cannot affect the safety function is what I said is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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179 1 licensing condition and that probably needs to be 2 reconsidered.

3 The reason I had written that, and this 4 might be something you want to look at in the actual 5 ISG-06, but it says at the top of page 52, for PSAIs 6 that are addressed in the LAR are implemented by the 7 licensee subsequent to issuance of the license 8 amendment, a license condition should be established 9 to resolve these PSAIs before system operation or as 10 established in the license condition.

11 So that's the reason I put those words in 12 there. If that's going farther than what you guys 13 really want to go, we've got no problem with that.

14 MS. GOLUB: That's where we need --

15 MR. HOOTEN: But you might want to soften 16 the language here in the ISG-06, if that's really the 17 direction you want to go.

18 MR. STATTEL: Did you make a note of that?

19 MR. DARBALI: Yes.

20 MR. HOOTEN: Do you see what I'm saying?

21 MR. DARBALI: I --

22 MR. HOOTEN: In other words, I was just 23 parroting the language in the ISG.

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180 1 condition.

2 MS. GOLUB: Well, licensees would propose 3 a regulatory commitment. The NRC would then say this 4 has to be a condition to their license.

5 MS. VENKATARAMAN: If it is required, it 6 will be raised to something that is high in the 7 safety. Then it becomes a condition.

8 MS. GOLUB: But we're not going to propose 9 a condition. I mean would try to propose it as a 10 commitment.

11 MR. DARBALI: Okay but if we agree or 12 determine that it has to be a condition, that has to 13 come from the licensee.

14 MS. VENKATARAMAN: When you agree, yes.

15 I mean that's correct. So perhaps it will be an RAI 16 and then you would supplement the application. And so 17 that will become -- and so the commitment is now we 18 comment, then you make the regulatory finding. So the 19 commitment is no longer a commitment.

20 MS. GOLUB: But the only point I was 21 trying to make is I thought, Samir, what you were 22 saying is in the LAR the licensee will propose it as 23 a condition. And I'm saying in the LAR, in the 24 original submittal of the LAR, I see licensees, if 25 anything, would propose it as a commitment, especially NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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181 1 because this a procedure issue.

2 MR. DARBALI: But it would be -- okay, 3 right.

4 MR. WATERS: I think there's a point that 5 if we decide it's a condition, we give the licensee 6 opportunity to propose what that condition exactly 7 looks like. And that's part of the process because 8 we're not going to put the condition in -- we want to 9 get the wording right. I think that's what --

10 MS. GOLUB: Yes, I mean that's --

11 MR. WATERS: -- or just pre-determine if 12 the pre-application really need to be a condition --

13 MS. GOLUB: That's right.

14 MR. WATERS: -- then maybe, come the first 15 submittal is here's what the condition language we 16 would like to have. If not, then yes, so it would be 17 commitments and if we decide it needs to be a 18 condition --

19 MS. GOLUB: That's right.

20 MR. WATERS: -- we'll probably give an 21 opportunity to let's get the wording in the condition 22 exactly right.

23 MS. GOLUB: Right. I mean the licensee 24 would certainly welcome the opportunity to contribute 25 to the language of the condition.

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182 1 MR. WATERS: Is that right, Booma?

2 MS. VENKATARAMAN: Yes.

3 MS. GOLUB: But I just want make sure we 4 understand what Dave is saying, though, because Dave 5 -- Dave, the reason that we put those words in here 6 was based on the language of the ISG and how it's 7 written.

8 And so I think we just want to highlight 9 that that is how the ISG is written. Is that really 10 our intent?

11 MR. STATTEL: Which specific words are we 12 talking about?

13 MR. HOOTEN: So at the top of page 52, at 14 least of the version I was looking at.

15 MR. DARBALI: Well, I mean if it's the 16 version that we shared with the ACRS, then yes, the 17 page number should work.

18 MS. VENKATARAMAN: Yes, I'm not sure I 19 have it.

20 MS. GOLUB: So I would love it if everyone 21 could see it.

22 MR. HARRELL: You had better give a 23 section number.

24 MR. HOOTEN: It's in D.5.1.2, the second 25 to last paragraph.

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183 1 MR. HARRELL: Section D.2 is long.

2 MR. DARBALI: I think what's important to 3 remember is the ISG is guidance to the staff. And I 4 understand industry is trying to use the ISG as a way 5 of crafting the LAR.

6 MS. GOLUB: Oh, yes, that's a good point, 7 Samir.

8 MR. HOOTEN: Right, however, D.5.1 is 9 information to be provided. It's not under D.5.2, 10 which is the evaluation part. So that kind of implied 11 --

12 MR. DARBALI: I see.

13 MR. HOOTEN: You see what I'm saying?

14 MS. VENKATARAMAN: Right. Take this as an 15 action item.

16 I think there is another part where we 17 say, and I don't know which version is this I have, 18 where we evaluate like the commitment-type language as 19 if it is. But it is not a condition so I'm not -- I 20 think I understand there may be a situation here.

21 MR. STATTEL: Okay.

22 MS. VENKATARAMAN: And it is true. Like 23 if you have a commitment, if you mutually agree, it 24 becomes a license condition and then it no longer is 25 a commitment. And we have actually used a commitment NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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184 1 to make a safety finding.

2 All other commitments would just be 3 listed.

4 MR. STATTEL: One correction.

5 MS. VENKATARAMAN: Yes.

6 MR. STATTEL: So this is our procedure for 7 -- this is LIC-101.

8 MS. VENKATARAMAN: Okay.

9 MR. STATTEL: Okay? License Conditions --

10 The NRC may impose license conditions without 11 agreement from the licensee.

12 So essentially, we write, we determine 13 what the conditions are and we don't need agreement 14 from the licensee on those. Whereas, commitments are 15 agreed to or volunteered by the licensee and submitted 16 on the docket to the NRC.

17 So that's really the difference. We can 18 convert commitments into conditions and there's a 19 process for doing that but they start with us. They 20 start with the NRC.

21 So all conditions -- to say you're going 22 to recommend a condition --

23 MS. GOLUB: Right. That's what I'm 24 saying. We're saying that we're not.

25 MR. STATTEL: And there's no agreement.

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185 1 MR. HOOTEN: So with what you're saying 2 there, Rich, it seems to me that the paragraph that I 3 just read really is misplaced in being in D.5.1.

4 MR. STATTEL: I agree.

5 MR. HOOTEN: It should be in D.5.2.

6 MR. STATTEL: I think that's right.

7 MR. HOOTEN: Because it's for you, you're 8 saying, right?

9 MR. STATTEL: I'd ask Samir to make a note 10 of that because I think we need to fix that.

11 MS. GOLUB: Yes. Okay, and then I guess 12 we'll revise our -- this response as well.

13 MR. HOOTEN: Take that.

14 MS. GOLUB: Yes.

15 MR. STATTEL: Now there's a little back 16 door in here. When it talks about commitments, and 17 this is --

18 MR. HOOTEN: Are you still reading from 19 LIC-0101?

20 MR. STATTEL: Yes. For those regulatory 21 commitments that don't warrant escalation into 22 obligation but are relied upon by the staff as an 23 element of staff's approval of the proposed amendment, 24 the staff's SE can rely on the commitment if the 25 commitment is subsequently incorporated into a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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186 1 mandated licensing basis document, for example, the 2 UFSAR.

3 So that's a little back door thing because 4 that way you can essentially base your license 5 amendment approval on a commitment, as long as it's 6 tied to an UFSAR without having a condition. So 7 that's a way to basically base your conclusion on a 8 commitment without having to create a condition.

9 That's a little --

10 MS. VENKATARAMAN: Yes, I think that 11 language is --

12 MR. STATTEL: I've seen that used before.

13 MS. VENKATARAMAN: No, we added that 14 language. Yes, I think the language is in there.

15 MR. DARBALI: So Booma provided some 16 comments on the ISG. So some of that, the nuances 17 will be covered in the version that goes out for 18 public comment.

19 MS. VENKATARAMAN: Okay, great.

20 MR. HOOTEN: All right. So, I think we've 21 covered the first half of the ASAI, which is the one 22 that deals with the procedure for connection, and 23 disconnection, and so forth.

24 The second part of it deals with test 25 plans, procedures, et cetera. And the response to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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187 1 that one is kind of a two-part thing. Again, it goes 2 back to D.4, like we talked about for the other item, 3 where some of that has already been done and is 4 described in the LAR. You've got it for review but 5 some of the later stages of that haven't been done yet 6 and will be subject to the vendor oversight plan, as 7 discussed earlier.

8 All right, Item 7 deals with response 9 time. It talks about the Tricon platform. It didn't 10 meet the response time criteria that is in EPRI TR-11 107330 but it's still probably suitable in a lot of 12 cases. So the commitment -- or excuse me. So the 13 ASAI here is for the licensee to make an evaluation of 14 that.

15 And our response is that bounding 16 calculations would have been performed prior to the 17 LAR submittal that demonstrate that those Tricon 18 response times, when incorporated into a full response 19 time analysis for the entire channel, meet the 20 requirements to support the safety analysis and so 21 forth.

22 And then in addition to that, the actual 23 performance of the equipment would be verified during 24 acceptance testing and documented appropriately.

25 Feedback on that one?

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188 1 MR. STATTEL: So just this is an 2 interesting area because this is an area where it 3 could lead to changes, design changes. Okay?

4 So for example, with Tricon, they perform 5 a calculation based on input they received from the 6 application, after the application is developed. At 7 the time you're submitting your application, the 8 application is not developed. So there's no way to 9 complete that calculation and come up with an accurate 10 response time.

11 MR. HOOTEN: Which is why, again, the 12 wording was chosen was very carefully for that reason.

13 That's why I say bounding calculations.

14 So the idea there is you're going to take 15 worst-case conditions, you're going to throw in some 16 margin, and come up with a number that you're highly 17 confident is going to bound whatever the reality turns 18 out to be.

19 MR. STATTEL: And this discussion is going 20 be different for each platform.

21 MR. HOOTEN: I understand that. This is 22 just an example for this one.

23 MR. STATTEL: But for Tricon --

24 MR. HOOTEN: But that's the approach, 25 right?

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189 1 MR. STATTEL: Right.

2 MR. HOOTEN: Because we want to make sure.

3 You know we don't want to submit an LAR that says we 4 have no flipping idea whether this is going to be 5 acceptable or not.

6 MR. STATTEL: Right.

7 MR. HOOTEN: So we want to make enough 8 conservative bounding assumptions that we can get a 9 pretty confident conclusion that it's going to be 10 okay. The actual final number, we don't know what it 11 is yet but we can be pretty confident it's within the 12 bounds that we calculated and have submitted.

13 MR. STATTEL: So with Diablo Canyon, they 14 ran this calculation. They actually had an 15 application written. They ran this calculation and 16 the number they came up with was very close to what 17 their limit was. And because of that, they didn't 18 want to have no margin. So they actually changed the 19 design and bumped up the limit in order to be able to 20 accommodate that.

21 So, again, that led to a design change 22 after the fact. So this has a lot of potential for 23 that.

24 MR. HOOTEN: And as we talked about months 25 ago, there is some risk licensees are assuming here.

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190 1 MR. STATTEL: Sure. That's right.

2 MR. HOOTEN: If something changes that 3 takes you outside the bounds of the LAR, you're going 4 to have to deal with it.

5 MR. STATTEL: So in this case, in an 6 alternate review process, we would have approved the 7 license amendment. And then the decision would be 8 made to bump up the response time or change the 9 response time you know based on conservative decision-10 making and everything.

11 MR. HOOTEN: For good reasons, right.

12 MR. STATTEL: And that's okay but you 13 would have to process that as a 50.59, right?

14 MS. GOLUB: Right.

15 MR. STATTEL: Okay.

16 MR. HERB: Yes, it is our intention to 17 process all and any of those changes as they go 18 through a like process or a 50.59 process, we would 19 compare that to our submitted material, just like if 20 you write it part of our license and while you're 21 still reviewing it.

22 And then after it's approved, we would 23 have the same thing for any changes.

24 MR. STATTEL: Now another thing I will 25 mention here, while we're on the topic of time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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191 1 response, oftentimes the requirement for time response 2 for a safety system, a protection system is what the 3 old system was. Right? So it had to scram the 4 reactor in X amount of time --

5 MR. HERB: Right, it's based on the risk 6 analysis.

7 MR. STATTEL: -- in so many milliseconds.

8 And if you can say oh, the new system does it within 9 200 milliseconds and the requirement is 300 10 milliseconds, it's a no-brainer. It's a very easy 11 evaluation.

12 But the question is do you just accept 13 what that response requirement was on the old system 14 or do you pull that string further back to the actual 15 safety analysis? Right? You see? Because they are 16 not always right. You know what I mean?

17 Do you just assume that the original 18 number was correct, the original design was correct?

19 Because if you do that, it's a very easy 20 determination.

21 MR. HERB: I think that gets back to the 22 Mark table.

23 MS. GOLUB: Mark, wouldn't that be in your 24 table?

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192 1 whatever Mark table.

2 MR. STATTEL: Because we've done it both 3 ways. And I think you have to go back to your 4 licensing. You have to go to your actual bases, 5 rather than the design basis. I mean that has to go 6 back to your accident analyses bases.

7 MR. HERB: I agree. And so we would pull 8 those numbers, those responses for that table. That's 9 why I love that table because that table forces you to 10 go back and look at the accident analysis, rather than 11 like say I just want to cookie cutter what I have.

12 Because you're right, I have seen systems 13 where you're given two seconds. And so some of that 14 comes out of the cabinet. Some of that comes out of 15 the sensor. As long as you're less than two seconds, 16 you're okay. And so we wouldn't necessarily go to 17 what we have installed. We would go all the way back 18 to the analyses and figure out exactly what our time 19 is and put it in the system as-built would have to 20 meet those requirements.

21 MR. STATTEL: Okay.

22 MR. HARRELL: And the worst thing that 23 could happen is that you're forced to go back and redo 24 some accident analyses with a higher number.

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193 1 part of the initial --

2 MR. HARRELL: That's got to be.

3 MR. HERB: -- the conceptual design piece.

4 And again, that is, you know if something falls 5 through the crack, that's on us. We're going to have 6 to resubmit in some cases. In some cases, it may be 7 bounded to 50.59. We still have to certainly explain 8 that to you at some time.

9 MR. STATTEL: Okay, this makes sense. If 10 you do a bounding calculation, odds are you're not 11 going to have to modify, right?

12 MR. HERB: Right.

13 MR. STATTEL: That's what you're putting 14 down here, right?

15 MS. GOLUB: That's right.

16 MR. STATTEL: Okay.

17 MR. HERB: And I would think that those 18 issues would show up early enough and you would say, 19 oh. Because oftentimes, some of the misconceptions 20 are that analog systems are slower, digital systems 21 are faster but there is a lot of latency sometimes 22 when things happen. So sometimes digital systems can 23 actually be longer response times for those cabinet 24 components than they were previously.

25 So you would definitely go back to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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194 1 accident analysis to see what was there.

2 MR. STATTEL: That's particularly true for 3 control systems.

4 MR. HERB: Yes.

5 MR. HARRELL: It can also be true -- we 6 dealt with that at Lungmen in a protection system, 7 where the design basis was the bistable response and 8 a relay response. And the digital system couldn't 9 keep up with that.

10 MR. STATTEL: Right. Okay.

11 MR. HOOTEN: All right so I'm going to do 12 these a little bit out of order because of 13 similarities. I'm going to do 17 next because that's 14 almost identical to the one we just talked about in 15 approach.

16 Seventeen, rather than dealing with 17 response time, deals with set points. So once again, 18 in this case, we would do bounding calculations at the 19 stage of prior to LAR submittal to either verify that 20 the trip set points don't need to be modified or to at 21 least identify that there's some reasonable 22 probability that they may need to be.

23 In any event, the results of the bounding 24 calculations would be described, summarized, what have 25 you, in the LAR.

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195 1 And the one assumption here is I assumed 2 that these calculations were done using an approved 3 set point methodology. I just threw that in there 4 because that's another whole rabbit trail if it's not 5 the case.

6 And then once again, just like with the 7 response time, proving that the actual system will 8 trip at the set points that you've determined will be 9 a part of the acceptance testing and documented in 10 that context.

11 So you'll get the analysis part of the 12 other bounding calculation and then the proof in the 13 pudding later, when the actual test is performed under 14 the oversight plan.

15 MR. STATTEL: So set points have typically 16 not been contentious in these things. Most plants 17 don't want to change their set points. They just want 18 to transfer them over to the new system.

19 But set points are always effective and 20 the reason is because this new system doesn't have the 21 same accuracy or same uncertainties that the analog 22 system had. So they're different. They may be 23 faster. They may be slower. They may be more 24 accurate, less accurate, whatever. They're different.

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196 1 re-performed, the uncertainty calculations.

2 MR. HERB: We would certainly do those, 3 yes.

4 MR. STATTEL: Right. Right. Now usually, 5 like in the case of Diablo and Oconee, we did not 6 change any numbers in the tech specs. Okay?

7 With that being said, we don't necessarily 8 need to review the uncertainty calculations and 9 evaluate them because the numbers aren't changing in 10 the tech spec. That's your base. That's your 11 licensing basis. If they do change, it would be a 12 more involved review.

13 In this case, what basically our policy 14 is, we will expect to see some kind of summary, a 15 summary description of what changed in those 16 calculations, what the differences are. Right?

17 If it's referencing approved methodology, 18 if it used that same methodology, we would just 19 confirm that and move on. Okay?

20 MR. HOOTEN: Now you wouldn't necessarily 21 be needing a detailed cataloging of every single 22 uncertainty variable that's different between the old 23 and the new. You're not saying that, are you?

24 MR. STATTEL: No. No, not necessarily, 25 no.

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197 1 MR. HOOTEN: More of a summary 2 description.

3 MR. STATTEL: Exactly.

4 MR. HOOTEN: Okay. Yes, and that's 5 consistent with what we had in mind.

6 MR. STATTEL: Yes. So we're not doing a 7 full-blown set point review. We're not going to 8 verify 95.95 or hold you to the ASAI standards because 9 we know the methodology already captures that. And 10 particularly, if you're not changing a number in the 11 tech specs, really, and you're using an approved 12 methodology, we know you're managing your margins to 13 the point where you won't exceed those, the analytical 14 limits.

15 So, okay.

16 MR. HOOTEN: All right. And then the only 17 two that are left here are numbers 9 and 18; 9 dealing 18 with communication interconnections, and 18 dealing 19 with the video display unit. And in those two 20 particular cases, the Diablo Mod, as this was based 21 on, said that these items weren't applicable because 22 those features weren't being used.

23 So that's pretty much all this says.

24 And that was it.

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198 1 applicable because the design does not implement that, 2 perfect.

3 MR. HOOTEN: That's right.

4 MR. DARBALI: But not applicable because 5 the ISG is silent, like the first example.

6 MR. HOOTEN: Right. So basically, in 7 summary from all this, what we would need to do, we 8 would need to change two things here to make this 9 accurate.

10 MR. DARBALI: Right.

11 MR. HOOTEN: Number one is to purge the 12 license condition wording out of this. And then the 13 other one is to add additional discussion to item 14 number 2 o talk about evaluating the licensee's 15 programs and whatnot to demonstrate that the content 16 of what's being looked for in those plans is in fact 17 taken care of.

18 MS. GOLUB: Right.

19 MR. HOOTEN: Are we on the same page?

20 MR. DARBALI: Yes.

21 MR. HOOTEN: Okay, thank you.

22 MR. DARBALI: And we took back the comment 23 on looking at that, moving that paragraph from the 24 ISG.

25 MS. GOLUB: Yes.

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199 1 MR. DARBALI: So like it's about to be 2 2:30.

3 MR. GOLLA: Break time until 2:35 or you 4 want 2:30?

5 MR. DARBALI: Well, I mean the HFE folks 6 are scheduled to be here at 2:45. So, we have to wait 7 until 2:45 to start our session.

8 MR. GOLLA: Oh, okay. So break until 9 2:45.

10 (Whereupon, the above-entitled matter went 11 off the record at 2:20 p.m. and resumed at 2:44 p.m.)

12 MR. GOLLA: And we're back fully. Okay.

13 So human factors engineering is up next. And we have 14 Mr. John Hughey here from the staff. John, are you 15 going to lead off with this?

16 MR. DARBALI: So I'll start. I just want 17 to check is, Brian, are you on the phone?

18 MR. GREEN: I am. This is Brian. I'm on 19 the phone. I'm having a hard time hearing everybody 20 in the room, though.

21 MR. DARBALI: Okay. We'll try to keep the 22 microphones close to us.

23 MR. GREEN: Great. Thank you.

24 MR. DARBALI: Thank you for calling, 25 Brian. So we've got Brian Green on the phone and John NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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200 1 Hughey here, so there are HFE experts. So the section 2 we're going to talk about now, it's a little different 3 from what we've been talking about because we've been 4 covering different aspects of an I&C review. Now 5 we're talking about what the licensee would provide in 6 a LAR. It wouldn't be reviewed by a DIAC staff, it 7 would be reviewed by our HFE folks.

8 So you provided a sample of what would be 9 covered in a LAR. You have your -- what's in the box 10 is basically the background and scope of the change.

11 And then I read that, somewhere in there it says this 12 information is going to be kind of spread out in the 13 LAR and then you say this is the section is one 14 sentence saying it's a minor change and, therefore, 15 this is it, and then another sentence is more of an if 16 it would be a major change, then it would be 17 evaluated.

18 So I guess my first comment would be kind 19 of, like, that information in the background is very 20 helpful. So even if it's spread out, because we 21 don't, I mean, our HFE folks are very basic with other 22 views. They're making a great effort for just being 23 able to participate and put into the ISG-06. So if we 24 just give them a 300-page LAR and say, hey, here, find 25 the HFE, that's kind of a waste of their time.

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201 1 So even if you have to copy the 2 information from different sections in the LAW, it 3 would be very valuable and helpful to have it just in 4 one section show that when you say it's a minor change 5 they can read the reasons behind that and make that 6 determination. And on that, I guess, John, would you 7 like to say something?

8 MR. HUGHEY: Oh, sure. So just to make 9 sure that I understand. So in reading the 10 introductory paragraph, what I'm expecting is that if 11 an LAR, this LAR came in, that the human factors 12 engineering portion of the LAR would consist of the 13 couple of sentences that are on page two of two; is 14 that correct?

15 MR. HARRELL: That was kind of where we 16 were headed.

17 MR. HUGHEY: Sure.

18 MR. HARRELL: Although from talking, from 19 some discussion, we might want to bring all the HFE 20 stuff into one slot. So just to talk a little bit 21 about what this really is.

22 MR. HUGHEY: Sure.

23 MR. HARRELL: I started with Diablo Canyon 24 and then realized they're making changes in the 25 control room, so Ray doesn't like it when I use the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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202 1 word interesting, but it wasn't very interesting in 2 terms of --

3 MR. HUGHEY: Sure.

4 MR. HARRELL: So this is more based on 5 some work I had been doing with another fleet operator 6 that's looking at what does it really mean to replace 7 the protection channels and the solid state protection 8 system. And I want to do some additional things that 9 the existing equipment doesn't do and doesn't do 10 effectively. So there are a few simple switches and 11 maybe some indicators for some additional bypass 12 indication, that does the bypass indication. On the 13 system we're looking at it's primitive. It needs to 14 be enhanced.

15 So a few switches. We're not going to 16 take any manual functions and make them automatic.

17 We're not going to take any automatic functions and 18 make them manual. They'll still be the same 19 capabilities for the operator to flip operating bypass 20 switches. Although there is one place where we 21 probably will add some manual bypass capabilities, but 22 that's not a big function. That's the kind of 23 function that the operator wants rid of anyway. It's 24 not a key to his operating the plant. It's a nuisance 25 that he has to remember to do at the right times or he NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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203 1 trips the plant.

2 So the data for this would be described in 3 the architecture section, so we would describe -- and 4 it's not clear to me whether duplicating information 5 or referring to information is the appropriate thing 6 to do. So that's something that we're going to have 7 to continue to discuss.

8 MR. HUGHEY: Sure.

9 MR. HARRELL: But, certainly, here's what 10 the existing control room looks like, here's the 11 existing interface with the plant and the operator.

12 Here's what I'm going to change, here are the effects 13 of the change, here are the procedures where the 14 changes are going to appear, here's what I'm going to 15 do to the existing bypass and status of the lamps and 16 here are the new lamps that we need to put in. Here 17 are the new switches. We're going to put them in, 18 roughly, the same places as the old switches. And 19 that would the extent of the mod until the utilities 20 get really brave and say let's go glass control room.

21 MS. GOLUB: Yes, so I think I just want to 22 jump in there really quickly. So the reason that we 23 selected this example is based on the utility folks on 24 the team, based on their feedback on what was likely 25 to be sort of the first phase, and maybe you're better NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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204 1 to speak to this, the first phrase of the protection 2 system upgrade.

3 MR. HERB: Right. I think in the industry 4 we're just getting our feet wet with protection system 5 upgrades. Oftentimes, the decision to upgrade from an 6 analog to a digital protection system is a strategic 7 decision, rather than a monetary decision. There's 8 kind of rules of thumb in the industry that whenever 9 we touch the main control room with a design it adds 10 $10 million. And so a $10 million adder would be 11 prohibitive to the plant to actually upgrade their 12 system to digital.

13 So, typically, at Southern, we have put a 14 box around our upgrades so that we get the digital 15 system, but we don't change, we don't impact the 16 operators at all, we don't pull in the cable. So it's 17 within the confines of a cabinet. So those are 18 basically our requirements.

19 Now, we do intend to eventually upgrade 20 the control room, but the benefit from that is not 21 just from the protection system, that's from the 22 operating environment, its benefit from the controls 23 aspects, and LAR management and a lot of other stuff 24 that go into it. And in that time, we would roll 25 protection system changes in at the same time. And so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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205 1 it just made the scope smaller and simpler, and so I 2 said, you know, we eventually would go there, but that 3 would probably be a separate LAR. There would be a 4 LAR for changing the control room, and it wouldn't be 5 really related to the protection system. It would be 6 more the human factors and operating experience would 7 change.

8 So what you guys are normally doing with 9 Vogtle 3 and 4, that's a massive undertaking and 10 there's a lot of human factors pieces that go through 11 all that stuff. We wouldn't have to do that piece at 12 that time, I'm assuming, or at least within our 13 licensing basis.

14 MS. GOLUB: But that's what this example 15 is?

16 MR. HERB: Yes, we didn't want to go into 17 the details because we didn't think it was really 18 valuable to this initial cut on this.

19 MR. HARRELL: But if there is, if we can 20 make the HFE evaluation simpler by putting everything 21 in a section, perhaps we should because it would 22 certainly simplify life for us, as well.

23 MR. HUGHEY: So I think that a lot of 24 Samir's comments there may stem from the fact that, as 25 the human factors guys, we first looked at this, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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206 1 were kind of confused as to exactly what's going to be 2 in the LAR as we read through. We didn't really 3 understand and I'm still not sure, and that's okay.

4 So I see the background on page one. Those are kind 5 of summary points. And what you've just described 6 about, so you've just described much more detail that 7 would be in the LAR.

8 And so the key is is that, you know, our 9 first impression in looking at this, our first 10 thinking was we need a lot more detail than what's on 11 this page because -- and if it's in one place, of 12 course that's fantastic. As long as it's, as we have 13 a clear roadmap where to go or even our thinking was 14 just that it is in there, clearly in there and we can 15 see that this section clearly relates to the human 16 factors review because, you know, if you see the, so 17 if I read the, you know, just the two sentences for 18 what would be the major section which says there's no 19 changes to any important human actions, you know, 20 credited in the analysis, therefore no human factors 21 evaluations are required, so if that's a true 22 statement this is what we would call a Level 3 review.

23 So I'll go to 17, NUREG-1764. I'll bounce this past 24 that, look at this, and this tells me for a Level 3 25 review, I mean, all I have to do is just really make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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207 1 sure that the human actions are properly, have been 2 properly characterized. However, there's this word 3 "important." What do you mean by important? What's 4 your license criteria for saying whether that's 5 important or not? But what I'm hearing from you is 6 that -- go ahead.

7 MR. HERB: It's in the parens right there, 8 operator actions credited in the D3 analysis are 9 credited in the base analysis described in FSAR 10 Chapter 15. That's what we mean by important.

11 MR. HUGHEY: Well, but that's still, but 12 there still may be actions in that scope that you 13 don't think important but we might.

14 MS. GOLUB: Wait. Hold on a second. And 15 I'm not a human factors expert, so please forgive me 16 if this is a foolish question. But I thought that 17 that term, important human actions, I thought that 18 came out of an NRC HFE criteria somewhere because I 19 remember reading it in the SER for Hope Creek that 20 that was a defined term somewhere.

21 MR. BURZYNSKI: I thought it was in the 22 SRP 18 under --

23 MR. GREEN: Yes, it is defined in 1792, 24 Chapter 18 will have it in there, as well. I notice 25 in here -- this is Brian Green, by the way. Pointing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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208 1 to Chapter 15, we also would consider it if you're 2 using it in a risk-informed sense, you're crediting it 3 in a Chapter 19 analysis, although I'm not sure how 4 often the operating plants use that so I'm not sure if 5 it's relevant here. But that may also be important to 6 include in there.

7 MS. GOLUB: Okay. So, John, I guess the 8 only point I wanted to make is that when we say 9 important human actions here, we're not talking about 10 sort of, like, what arbitrarily to the licensee would 11 be important. We're trying to use it in the HFE 12 context.

13 MR. HUGHEY: I understand. I'm not saying 14 that you're --

15 MR. DARBALI: Sorry. I was going to say, 16 to avoid that confusion, maybe you say important human 17 actions and you put a note saying as defined in 18 Chapter 18 or something like that. I don't know that 19 that would clear up the issue, but perhaps it would 20 be. If you look, for example, so this is the kind of 21 thing, if you look on page one, so in the first set of 22 numbers, item three says no existing manual function 23 controls are moved or eliminated. But then I look at 24 number five, and it says there are new processes in 25 implementing procedures that replace the existing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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209 1 procedures. Oh, I'm sorry, number six. There are 2 new, as well as revised, alarm response procedures to 3 deal with changes in the system's architecture.

4 Number one down at the bottom says existing bypass 5 switches remain, additional switches will be added to 6 reflect the architecture and capability changes 7 provided, which may result in switch layout changes.

8 The next one says some new discreet indicators will be 9 installed.

10 So now I look at number three up above, 11 and it's a very absolute statement that says no 12 existing manual function controls are moved or 13 eliminated. Now I look down and I see your specific 14 details, and they do not match that absolute state.

15 So, now, I'm not saying, though, man, this 16 is horrible. I'm only raising this to illustrate that 17 we need those details, and since you're able to make 18 the very clear, definitive, unambiguous statement, 19 there's no changes to important human action, there's 20 no changes, here it's even there's no existing manual 21 function controls are moved or eliminated. Since you 22 know enough, this is an alternative process but you 23 know enough of the design details to make those very 24 strong, unambiguous statements, that means you have 25 the details. And so for us, even though, in all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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210 1 likelihood, we would be able to review something like 2 this with a Level 3 human factors review, you know, 3 the minimum level of review is still confirming that 4 the human actions are properly classified, properly 5 classified as important.

6 Now, a big difference here, for example, 7 I pulled the Diablo Canyon review. So, for example, 8 you look in number four and the first set of numbers 9 says there are no changes to the system safety 10 functions or to the safety-related operator 11 task/function assignments, including changing 12 functions from manual to automatic or task function 13 assignments, including changing functions automatic to 14 manual, which is a difference from Diablo Canyon.

15 That difference, because of that characteristic of 16 Diablo Canyon, that is specifically listed in the 17 safety evaluation of why it was only a Level 3 human 18 factors evaluation.

19 So depending upon the details of what's 20 actually happening here, I suspect that this review 21 would actually go to a Level 2 for NUREG-1764, a Level 22 2 human factors. So you can look in the appendix and 23 you can see what a Level 2, all the issues that a 24 Level 2 evaluation involves, and so the human factors 25 reviewers will be looking for information for those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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211 1 particular items.

2 And, again, though -- I'm sorry. Go 3 ahead.

4 MR. BURZYNSKI: I was going to say would 5 it help in this write-up to clarify which actions are 6 related to, let's say, protecting the plant versus 7 which actions and alarms and things are associated 8 with diagnostics of equipment failures.

9 MR. HUGHEY: Right. So exactly. So now 10 you're providing some of exactly what is that 11 particular detail. So I think you really, you're 12 making the point, you're right that just a generic 13 statement that says nothing important is involved 14 here, we didn't do any of this, we still need to see 15 if you did make changes, what did you change? Not 16 just what you didn't do, what did you change? Because 17 we just have to have some basis to develop our 18 reasonable assurance, not independent verification, 19 you know. I'm just saying we just need to have some 20 detail.

21 MR. BURZYNSKI: So in this particular 22 case, if we said that the new LED indicator lights or 23 the alarms or the bypass switches are all associated 24 with maintenance and equipment troubleshooting, as 25 opposed to system operation or performing safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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212 1 functions --

2 MR. HUGHEY: Yes, exactly.

3 MR. BURZYNSKI: -- that would help you --

4 MR. HUGHEY: Yes, exactly. So it's really 5 just that kind -- so I'm not trying to say, hey, that 6 you can't, there's no way. I'm just saying it's the 7 kind of information that you need because, even though 8 it's -- I think what's a little misleading perhaps is 9 that, even though it's very basic and even though 10 it's, as far as impact to the plant and even if 11 there's a change in an operator manual action, that 12 change itself, even though they may be very 13 inconsequential, we still have to be able to 14 understand exactly what they are so we know exactly 15 why and we can evaluate for ourselves why it's 16 inconsequential.

17 So even though we're in this alternative 18 process, we're still going to do the same review.

19 We're going to use the same review guidance. The 20 questions downstream will just be, you know, more of 21 a licensing mechanism, how do we maintain these . . .

22 MR. STATTEL: Well, I have a question, 23 though, because, thinking back on Diablo, it pretty 24 closely resembles what's described in the tabletop 25 here. Now, Victoria had the information about the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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213 1 specifics of what was being changed. That information 2 was available to us, but it was available in detailed 3 design documents. So I just want to make sure we're 4 clear on what we're proposing here. So instead of 5 having those design detail documents, we would have 6 basically a description, a discussion of specifically 7 what would be changing without having the detailed 8 design. So would that be, I guess the question is do 9 we all, are we all in agreement that would be adequate 10 for the content of the application? Because it is, 11 that's a lot different than what was, what we did for 12 Diablo Canyon, even though it was a Level 3 review.

13 MR. BURZYNSKI: Well, the key insight for 14 me in listening to the discussion is you want to give 15 the information that supports the decision making that 16 has to occur. So I think we need to look at that 17 screen, your screening criteria to get a sense of what 18 is that information to help us better look at that 19 because that was, that's news to me. I'm not aware of 20 that stuff. But I think that would be the kind of 21 guide that would help us give you the information 22 because we now know how you're going to use it.

23 MR. HUGHEY: So there was an intent and a 24 belief on my part that sections, other sections in the 25 document would define what existed in the plant, would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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214 1 define both before and after, including, I would hope, 2 of the changes to the control panels would include a 3 description of functionality as required in the system 4 requirements spec. So there's other places, there's 5 other sources of information available to you, but 6 it's probably not the sort of thing, there was never 7 any thought, and there should have been, of putting it 8 all in one place. If we can bring it all into one 9 place, it will make more sense. Plus, we can target 10 it more towards the kinds of information that you need 11 versus Rich and Samir who need more what is the switch 12 actually doing behind the panel.

13 MR. HUGHEY: So if I can express it like 14 this: it at least needs to be brought in one place in 15 several places. What I mean by that is that you, the 16 licensee, have performed, you will have performed a 17 human factors review, a human factors evaluation of 18 this change. So you need to give us the narrative.

19 You need to describe to us your evaluation and what 20 the basis of your evaluation was, what the source 21 documents for your evaluation was. You need to give 22 us a summary rationale for how you came to your 23 conclusion, something that's just at the level that we 24 can make reasonable assurance. So that means that 25 those different pieces of information that you had to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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215 1 have reviewed and, you know, you need to have some 2 description that kind of explains that for us so we 3 can understand the basis upon which you came to that 4 conclusion from your evaluation. And that may be, so 5 there may be several discreet human factors 6 evaluations in different places, but in each of those 7 places you have to bring some information together.

8 And then if you can at least, in the human factors 9 specific section, at least point us to where that is 10 in your LAR, then that helps us to make sure we find 11 it and we don't, you know, we don't have to ask you 12 questions and --

13 MS. GOLUB: Yes, that makes perfect sense.

14 I think it would be great if we could revise it and 15 then, Samir, maybe follow up and if we could just 16 maybe have a phone call or something to maybe take 17 another look at it.

18 MR. HOOTEN: I have a question. You know, 19 the projects like we're imagining for purposes of the 20 tabletop, it clearly needs to be a LAR for a variety 21 of reasons, mostly having to do with the replacement 22 of the equipment if it's in the protection system 23 cabinets. But a project like that have some, I'll say 24 ancillary changes in the control room that are all 25 relatively minor. If you consider those control room NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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216 1 changes all by themselves, let's say there was just a 2 separate to just do those things, if that would have 3 easily been handled under the 50.59 process, why then, 4 when it's part of a larger project, it has to be a LAR 5 for other reasons, why does that part of it need to be 6 under the same level of scrutiny as the rest of it, 7 the LAR? Does my question make sense?

8 MR. HUGHEY: Yes, I do, but I don't agree 9 with your premise. It's not under the same scrutiny 10 as the rest of the LAR. It is exactly as you 11 describe, then we would apply a Level 3 review, which 12 means basically we're just confirming that those human 13 actions have been appropriately classified. We're not 14 going in and doing a functional analysis, a human task 15 analysis. We're not necessarily going in and doing 16 all those that we can and often, for a Level 3 review, 17 if cause information is provided, they'll look at the 18 different sections and just explain this is how the 19 licensee came to the point, to the conclusion that 20 these are not important, that this is not something 21 that's significant.

22 But we're not at all performing the same 23 level of scrutiny that we would if those actions where 24 change is significant, important changes in operator 25 manual actions and that sort of thing.

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217 1 MS. GOLUB: Did that answer your question, 2 Dave?

3 MR. HOOTEN: Well, maybe I'll rephrase the 4 question. What if the licensee in a 50.59 on the 5 impact of the RPS upgrade on the HFE, on the HF, your 6 human factors, and that 50.59 was done and then the 7 licensee submitted the LAR for the RPS upgrade, would 8 there still be an HFE review of the LAR?

9 MR. HUGHEY: Well, if you, I think that 10 would depend on how you structured the LAR because 11 when you send us a change and you say we are making a 12 design change and you define the scope as everything, 13 well, we look at everything. Some things we look at 14 less degree, some at more degree, but it all comes 15 under the review scope.

16 MR. HOOTEN: What if the licensee created 17 two different modifications, made one of them a LAR 18 and another one they did it under 50.59 --

19 MR. HUGHEY: So we can only --

20 MR. HOOTEN: -- handle the control room 21 stuff, would you still need to look at it?

22 MR. HUGHEY: No. If your LAR includes no 23 human factors information whatsoever and you even make 24 the statement we've already evaluated, you're not 25 putting before us human factors engineering review of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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218 1 that information, then we wouldn't be looking at it.

2 So what would happen is then the inspector, well, your 3 resident inspector would pull your 50.59 and take a 4 look at it and make sure, but, from a different part 5 of the NRC, they agree with the conclusions you came 6 to.

7 Now, it's possible that NRC staff may look 8 at what you do submit and they may say I wonder if 9 that was really, I wonder if we really do need to look 10 at this, and we can ask you a question and if your 11 response to the question is, no, that doesn't need to 12 be in here, it's covered under a 50.59, well, then the 13 NRC as a whole would look at that from a different 14 direction, through the oversight arm, not from the 15 licensing arm.

16 MR. HOOTEN: Okay. Thank you.

17 MS. GOLUB: Good question.

18 MR. HUGHEY: Brian Green, do you have 19 anything to add or . . .

20 MR. GREEN: No, I've got nothing to add.

21 I think that's right.

22 MR. STATTEL: I'm curious. This is Rich 23 Stattel. I'm curious as to the choice of the scope 24 for this particular tabletop because a lot of the mods 25 that we have done, the license amendments that we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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219 1 reviewed and approved do involve installation of touch 2 screens and significant human factors. So why do we 3 limit the tabletop to just this type of --

4 MS. GOLUB: I mean, that's what Ray was 5 describing, that why we, why we --

6 MR. STATTEL: I mean, I can understand, 7 for certain types of upgrades I understand you can 8 kind of keep the human factors out of it. But for 9 example, there's a lot of plants out there that are 10 performing post-accident monitoring system upgrades 11 and such and some of them are under 50.59. I 12 understand that, but, you know, there are clearly 13 human factors engineering aspects.

14 MR. HERB: I would agree with that. And 15 our mods are option limited, you know. They're going 16 to have screens and they're going to have 17 interactions. But when you do a 50.59, those things 18 screen out, and so we're not required to submit a LAR 19 on things that screen out --

20 MS. ZHANG: If whoever is talking can get 21 closer to the microphone. We can't hear anything.

22 MR. HERB: I was going to say we would 23 perform a 50.59 as part of this whole project. And 24 the aspects that screen out would not be part of the 25 LAR, would not be subject to review. Now, that 50.59, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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220 1 of course, is subject to inspection and I would think 2 that, you know, these things like that were described 3 here, which were replacement of incandescent bulbs 4 with LED bulbs and maybe movement of some switches 5 that were on back panels for maintenance bypass, I 6 don't know that those break the plane of required 7 prior NRC approval. That doesn't mean that we can't 8 describe them in here, in the LAR. In that case you 9 would want to look at that screen criteria to make 10 sure that we properly characterize that stuff. But we 11 could actually just not do it all. I think what Dave 12 was saying is maybe we do that underneath a separate 13 DCP.

14 MS. GOLUB: But I think that's what I 15 heard Dave saying, that there's be two different 16 design changes.

17 MR. HERB: But that doesn't mean we're not 18 adding --

19 MS. GOLUB: But they agreed with it.

20 MR. HERB: -- maintenance test panels.

21 But those, again, those, you know, typically, those 22 are already been reviewed and approved underneath your 23 topical report, but those are not, we don't consider 24 those important human actions. They're just 25 maintenance functions. And so we don't have to go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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221 1 through task analysis and all that other stuff.

2 That's part of our procedure change process and our 3 training and maybe the operations of the plant and 4 test plans and all those things we were talking about 5 before.

6 MR. STATTEL: What about OM? OMs are 7 used, and they're part of the design.

8 MR. ODESS-GILLERT: Those are in the 9 control, the operators modules. Those are in the 10 control room, and so they would be impacted, yes. So 11 the operators modules --

12 MR. STATTEL: I mean, would you separate 13 the OMs from the rest of a common --

14 MR. ODESS-GILLERT: We'd have to take it 15 from a case by case.

16 MR. HERB: A case-by-case basis. And my 17 case, Rich --

18 MR. STATTEL: I can't see separating that.

19 MR. ODESS-GILLERT: And they may not.

20 They may not be separated, and they may require an HFE 21 review as part of the LAR. It all depends on the 22 level of changes in the control room from putting in 23 an operators module versus just interfacing to 24 existing controls.

25 MR. HERB: That's it, yes.

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222 1 MS. GOLUB: We selected this example 2 because this was, from the licensees that were part of 3 our team, this was, that they viewed as sort of the 4 most expected first step of a protection system 5 upgrade. That was the idea.

6 MR. HARRELL: The whole flat panel thing, 7 you go to a lot of the control rooms around the 8 country and you're not going to even find flat panels 9 for unimportant non-safety equipment. The first place 10 that I can see putting a flat panel in a control room 11 is not going to be the protection system. It's going 12 to be --

13 MR. HERB: Turbine controls.

14 MR. HARRELL: -- turbine controls. And I 15 was just in a plant two weeks ago that that is the 16 only flat panel in the control room, and they're very 17 proud of the new turbine control system and the 18 operators love it. So that we would move forward 19 with.

20 MR. HERB: Mark 6E turbine speed control 21 for my feed pump, I have exactly one switch that says 22 on and off in the control room.

23 MR. STATTEL: I hear what you're saying, 24 but Calvert Cliffs, the first flat panels in that 25 control room were OMs for the post-accident --

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223 1 MR. ODESS-GILLERT: Post-accident 2 monitoring system. Right.

3 MR. STATTEL: And we put eight of them in.

4 MR. ODESS-GILLERT: Right. But, again, 5 that was under 50.59.

6 MR. STATTEL: And there were task analysis 7 and we performed human factors.

8 MR. HERB: My initials that go for my 9 protection circuit does not include a post-accident 10 monitoring system because that was too expensive.

11 MS. GOLUB: Warren, can you address the 12 OMs under Calvert Cliffs again?

13 MR. ODESS-GILLERT: Okay. So as Rich 14 knows because he was there and involved in the 15 project, that was done under 50.59. So whatever the 16 licensee had decided they needed to do for an HFE 17 evaluation in order to support their 50.59, that's 18 what they did. There was no LAR with that particular 19 mod.

20 MR. STATTEL: But essentially the same mod 21 was done at Watts Bar 2.

22 MR. ODESS-GILLERT: Right, right. And it 23 had to be reviewed because of --

24 MR. STATTEL: And that was not 50.59.

25 MR. ODESS-GILLERT: No, it was not.

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224 1 You're right. That had to be --

2 MR. STATTEL: Well, the plant was under 3 Part 50.

4 MR. ODESS-GILLERT: It was Part 50. Yes, 5 a Part 50 review.

6 MR. STATTEL: All the plants we're talking 7 about are Part 50.

8 MR. ODESS-GILLERT: But it was an NRC 9 review. It was NRC reviewed. You're right, Rich. It 10 was NRC reviewed. CPCs is another one. The core 11 protection calculators at Palo Verde, okay, they had 12 an operators module. We replaced the operators 13 module, so there had to be some kind of review of, 14 okay, like-for-like replacement of the operators 15 module on the control board.

16 MR. STATTEL: I only bring it up because 17 I'm seeing a trend in the topical reports that we 18 receive, and more and more they're trending towards 19 including flat panel displays and features that do 20 involve changing a design.

21 MR. HARRELL: And I think you will see 22 that eventually, but I don't think you're going to see 23 that in the first wave of --

24 MR. STATTEL: Well, I see it today so . .

25 .

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225 1 MR. HERB: Again, you have to get to 2 what's classified as important human action because 3 those flat panel displays, you don't use those to 4 initiate the system. If you have to manually initiate 5 the system, there will be switches that are currently 6 in our control rooms that they would probably still 7 use. And so the system has automatic completion of 8 function, so it just does what it does. They may have 9 to go look for different places for information, but 10 I can also send to the same place they already 11 currently look at. And so even if you have a flat 12 panel this way you may add in the control room, I 13 think that we can characterize those HFE as still your 14 Level 3 review just to confirm that we have not 15 impacted any important human actions and the way you 16 operate the system, primarily because it is a 17 protection system.

18 Now, it gets outside of Vogtle 3 and 4, 19 Part 52, Watts Bar 2 under Part 50. You guys look at 20 everything, and I understand that. But this is a 21 different thing. We already have a license, and we 22 try to stay within.

23 MS. GOLUB: Yes. I think that's an 24 important distinction.

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226 1 the pre-application meeting slides because there's a 2 couple of slides there that talk about human factors, 3 and, Brian, I just sent those to you. Hopefully, you 4 have access to that.

5 So I wanted to turn it over to --

6 MR. GREEN: I see them now.

7 MR. DARBALI: Okay, good. I want to turn 8 it over to John and Brian and see if, you know, this 9 type of information during a Phase 0 meeting is 10 sufficient or any reactions you have to that.

11 MR. HUGHEY: Are you prepared to talk 12 about that, Brian, or do you want me to start?

13 MR. GREEN: Why don't you start because 14 I'm just seeing these slides for the first time.

15 MR. HUGHEY: Okay, very good. Well, I can 16 definitively say it depends. So it's really just the 17 same discussion we just had. These are summary 18 statements, and it depends on the details. So when 19 you say, you know, PRNM back panel equipment and NUMAC 20 ODA has been designed to meet NUREG-0700 to the extent 21 practical, I mean, that's probably a very accurate 22 statement but we have to be able to understand what 23 that means and you have a basis for that because you 24 made that statement. So we would need those details if 25 we receive that in a review, even if we're doing a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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227 1 Level 3 review, just to make sure that's a proper 2 classification.

3 MS. GOLUB: Yes. So, John, the idea here 4 is that not so much asking you to sort of validate 5 those statements in the pre-application review meeting 6 but more these are the kinds of, this is the kind of 7 information we're going to share in the pre-8 application review meeting.

9 MR. HUGHEY: Okay.

10 MS. GOLUB: And so the idea is we're going 11 to share that with you and say, based on the design, 12 you know, all of these statements are true, and we're 13 looking for is this enough information where you could 14 give the licensee some good information on, well, you 15 know, if you're going to make a statement like that in 16 the LAR, you know, you better address X, Y, Z. That's 17 really the idea.

18 MR. ODESS-GILLERT: Well, actually, he's 19 demonstrating NRC feedback to a pre-application 20 meeting bullet point.

21 MR. HUGHEY: That's what I would say if I 22 was in there.

23 MR. ODESS-GILLERT: If he was at the pre-24 application meeting.

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228 1 sure that this is all the topics that you think would 2 be --

3 MR. ODESS-GILLERT: Oh, the topics.

4 MS. GOLUB: Yes, are these the right 5 topics? I mean, I appreciate the feedback on this 6 particular bullet, but the idea is are there other 7 topics, are there other items that --

8 MR. ODESS-GILLERT: Aspects of human 9 factors?

10 MS. GOLUB: Yes, aspects of human factors 11 that, you know, that would be helpful in a pre-12 application review meeting so that you could give 13 feedback to the licensee that would be helpful for 14 them when they prepare the LAR. That's kind of the 15 feedback we're looking for.

16 MR. HUGHEY: Right. So, of course, a pre-17 application meeting has as much detail as the LAR, but 18 for pre-application meeting and for your subsequent 19 license amendment request, I really suggest that you 20 get NUREG-1764 and I can give you the ADAMS number for 21 that, too.

22 MR. HARRELL: It's actually easier to find 23 with 1764.

24 MR. HUGHEY: Okay.

25 MR. WATERS: And Google.

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229 1 MR. HUGHEY: Because this is what we're 2 using, and we're going in and it gives us the criteria 3 to decide if we're going to do a Level 1, a Level 2, 4 or Level 3 review. And depending upon which review we 5 perform, we have specific topic areas that we're 6 looking for. So when we come and do an HFE review, 7 for example the Diablo Canyon -- were you going to say 8 something, Brian? Okay.

9 MR. GREEN: Yes, I'll say something when 10 you're done.

11 MR. HUGHEY: Okay. So for even the Diablo 12 Canyon review, I noticed, you know, this was a Level 13 3 review and there was enough information in the LAR 14 itself, except you just needed something about 15 emergency procedures. It was silent on the EOPs. But 16 that information was provided, it was straightforward, 17 and it was included then, but the reviewer was going 18 through the topics in 1764 and developing a reasonable 19 assurance argument of why each of those elements was 20 satisfied.

21 So that's where I would recommend that you 22 focus: what should you put into an LAR or a pre-23 submittal meeting for a human factors review?

24 MR. GREEN: Yes, I agree with that, John.

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230 1 if you look at that document, if you're not already 2 familiar with it, is that there is a screening 3 process. It's a risk-informed process, and when we 4 get an LAR sometimes the risk information is not 5 there. So this becomes, this can become a challenging 6 task for the NRC reviewer to figure out should we be 7 doing a Level 1, 2, or 3 review because we may not 8 have the complete amount of information to screen 9 that.

10 So, you know, if as you're preparing to 11 put the LAR together and you very clearly, you know, 12 come to the conclusion that NRC should be doing a 13 Level 3 review, you know, you might put that on the 14 application and say, you know, we believe this is a 15 Level 3 review because and put those points in because 16 the reviewer does not know everything that you know.

17 We only know what we see in the documents and what we 18 can put together, and sometimes it's not immediately 19 clear.

20 So if John gets an LAR in and he sees a 21 little bit of information and he calls it a Level 2 22 review, you think it's a Level 3 review, he's going to 23 be wanting a lot more information from you, which that 24 often causes us some friction between us and the plant 25 and we don't want that. So to clearly say why it's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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231 1 Level 3 is helpful. That's not required as part of the 2 application to say what you think it is, but if you 3 have that position and can support it that makes it 4 easier for the NRC reviewer to come to the same 5 conclusion.

6 MR. WATERS: This is Mike. That should 7 hopefully happen at the pre-application meeting, I 8 would hope. My one question, the examples, the 9 decisions, would you guys know that at the time of 10 pre-application, all these points?

11 MR. HARRELL: The system requirements spec 12 should be written by that point, so, yes, we should 13 know exactly what the plant -- we may not know exactly 14 what the alarm windows will say, but we know what 15 their intent was, what they're trying to communicate.

16 MR. WATERS: These provide the basis of 17 why it's a Level 3, right?

18 MR. HARRELL: Yes, we can do that.

19 MR. WATERS: At the time of pre-20 application, right?

21 MR. HARRELL: Yes. If there's significant 22 changes that we're going to have to do to human 23 factors, then we may not know all the details. But we 24 can certainly box in where we're at and what those 25 changes should be. That would really be part of, that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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232 1 would be part of our purchase order when we select our 2 vendor, it would be part of our initial requirements, 3 and we would certainly be able to define that.

4 MR. HERB: Yes, or if we don't have it 5 we've not finished our job.

6 MR. HARRELL: That's right. We wouldn't 7 be submitting a LAR without that information.

8 MR. DARBALI: Okay. Does anybody have any 9 questions, further questions for John or Brian?

10 MS. GOLUB: No, thank you. That was very 11 helpful.

12 MR. GREEN: Thank you.

13 MR. DARBALI: Thank you, Brian. So that 14 pushes us to the final exercise of the day. We have 15 moved this secure development to the morning, we 16 covered that, and we are doing the section D.4, I&C 17 system development processes. That was scheduled for 18 tomorrow between 11 and 11:50. We're going to cover 19 it now from 3:30 until 4:20 or 4:15.

20 MS. GOLUB: 4:15, yes.

21 MR. DARBALI: So does everybody have a 22 copy of it?

23 MS. GOLUB: There's two parts. There's a 24 presentation and then a Word document.

25 MR. DARBALI: Does everybody have a copy?

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233 1 Okay, all right. So go ahead.

2 MS. GOLUB: Okay. So D.4. So we have two 3 parts to this. We have a brief presentation and then 4 the software configuration management process write-5 up. Again, like with all the presentations, I'm not 6 going to go through this in any detail because I 7 suspect you guys have already taken a look at it.

8 Next slide, please. So for the purpose of 9 the tabletop, we, of course, would want your feedback 10 on two cases. The first case is where the platform 11 vendor has an NRC-approved software program manual for 12 application software that's approved as part of their 13 LCR/SER, and then case two where the platform vendor 14 does not have an NRC-approved SPM for application 15 software. And, again, the purpose of these two cases 16 is how would the licensee address each of these cases 17 in the LAR? Make sure that we're all on the same page 18 with that.

19 Next slide, please. Okay. I'm not going 20 to read this, but this is from the Teleperm SPM SER.

21 The Teleperm does have an application SPM approved.

22 Next slide, please.

23 MR. STATTEL: They did not have that 24 approved when we performed the Oconee review, just so 25 everyone is aware.

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234 1 MS. GOLUB: Okay. So for case one, and, 2 again, kind of understanding now, you know, for the 3 case that there is an approved application SPM, this 4 is what the LAR would describe, that second bullet.

5 The LAR would describe how the licensee proposed to 6 use the platform, of course. It would reference the 7 SPM and address the ASAIs, and it would address any 8 exceptions to the SPM, if any were taken.

9 You know, I should cover that top bullet 10 actually. So we had talked about the pre-application 11 review meeting and who would need to be at that 12 meeting. So in the case of D.4, you, of course, have 13 your vendor there to talk through any changes that 14 were made to the platform, to the processes, since the 15 NRC did their generic approval.

16 But these are -- I want to make sure that, 17 I guess that we're clear on this. So for us there 18 really would not be, if there is an approved 19 application SPM, there would be very little in the LAR 20 to address D.4. It would rely heavily on that 21 previous approval. Okay. Very good.

22 MR. STATTEL: And, actually, that's 23 untested because for Diablo Canyon both of the 24 platforms that were used did not have approved SPMs.

25 Oconee, as I mentioned, did not have an approved SPM.

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235 1 That was only developed and approved afterwards, so we 2 really haven't tested that. To date, you know, with 3 Hope Creek and all of these applications today, we 4 haven't really been able to point back to an approved 5 SPM.

6 MS. GOLUB: And so that's, I mean, that's 7 why we're presenting this in the tabletop because --

8 MR. STATTEL: But I agree with what you 9 said. It should minimize what's required in the 10 license amendment.

11 MS. GOLUB: Okay. Very good. Next slide, 12 please. Okay. So case two. Case two is how would we 13 address Section D.4 content if there was not an 14 approved application SPM? During the pre-application 15 meeting, the licensee and the vendor would identify 16 the development documents that would be expected to be 17 available during the LAR review. And then the LAR 18 itself would describe the vendor's application 19 development framework for Section D.4.1.

20 And then let's go to the next slide.

21 Okay. This is an example, but, again, for D.4, one 22 change perhaps between D.4 and what was in the 23 previous ISG, ISG-06 rev 1 is that for D.4 the 24 licensee would be providing a summary of all of these 25 different processes, so they'd be providing the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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236 1 framework, the overall framework, the vendors 2 framework, and a summary of these different processes.

3 And there's criteria for each of these processes in 4 D.4 that the licensee would need to address.

5 So just as an example, we selected 6 D.4.2.5, software configuration management process.

7 And from the ISG, these are the four criteria that 8 were identified.

9 Let's go to the next slide. Yes, okay.

10 So this is the example that we provided. So this 11 would be the summary that would be provided in the LAR 12 for the software configuration management plan, and 13 what we're looking for from you guys, of course, is 14 this the type of information, the level of detail that 15 you feel would be sufficient to address the D.4.2.5 16 criteria, understanding, of course, that the actual 17 documents that were summarized would be available for 18 audit or inspection?

19 MR. DARBALI: Now, this is for case one or 20 --

21 MS. GOLUB: Case two. So case one we 22 would provide only if there were exceptions taken or 23 how we were applying it, that type of thing. But case 24 two where it was not approved, that's where we would 25 be summarizing all of the different elements of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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237 1 process and providing it. So what we tried to do was 2 give you, okay, so if we were to summarize, what would 3 that look like? How much information would we 4 actually need to present? And that's what this is an 5 attempt to address.

6 MR. DARBALI: Yes, so I didn't have any 7 comments.

8 MR. STATTEL: I think it's reasonable.

9 What I would, I would refer to BTP 14, the section on 10 configuration management plan, and there's, like, four 11 paragraphs in there that talks about basically what 12 guidance we're reviewing those. And I think this 13 level of detail could address that, yes.

14 MS. GOLUB: Okay. So I definitely 15 appreciate what you said, Rich, but I guess I want to 16 make sure we're clear. So I guess, in my mind, we 17 would be addressing for the alternate review process 18 the criteria that's in D.4.2.5. We'd be making sure 19 we met that criteria, which is very similar to what's 20 in BTP 7-14, but specifically we're --

21 MR. STATTEL: That doesn't supersede our 22 standard review plan which will still be operative and 23 we will still use it.

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238 1 at this example, it would meet the BTP 7-14 2 description on that section --

3 MR. STATTEL: The review guidance.

4 MR. ODESS-GILLERT: The review guidance, 5 which is what the ISGD-4 actually points to.

6 MR. STATTEL: That's correct. It was 7 derived from that, yes.

8 MS. GOLUB: Right. But I don't know if --

9 so not every section of D.4 points to the review 10 guidance sections of BTP 7-14. Some do, some do not.

11 And I think this one, because I thought I copied the 12 exact criteria, this one --

13 MR. ODESS-GILLERT: And it doesn't list 14 it?

15 MS. GOLUB: This one does not. And I'm 16 not trying to split hairs here. I just want to be 17 clear, from an industry perspective, that, for the 18 alternate review process, the criteria that we're 19 going to try to address is in D.4.2.5, which may be 20 similar to what's in BTP 7-14.

21 MR. ODESS-GILLERT: Review guidance.

22 MS. GOLUB: Review guidance. Thank you.

23 MR. STATTEL: Honestly, I think it's part 24 and parcel. We developed that section of the ISG 25 using BTP 14. Now, I'm not referring, if I'm NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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239 1 reviewing this software configuration management plan, 2 I understand that you've submitted under the alternate 3 review process as defined in the ISG, but my review 4 guidance remains BTP 14, Section B.3.1.11.4.

5 MS. GOLUB: Four, right.

6 MR. STATTEL: So I would apply that. I 7 don't think there's disagreement between what's here 8 and what's in the ISG, but this remains operative 9 guidance and this is the guidance I have for 10 performing that review.

11 MR. DARBALI: So since the ISG is guidance 12 for the staff, should it then conform to the BTP which 13 is what's going to be used for the evaluation?

14 MR. STATTEL: Well, I mean, we discussed 15 that and we added references back to the --

16 MS. GOLUB: Yes. For select sections, 17 there are direct references to the BTP because we did 18 have that discussion.

19 MR. STATTEL: So when we develop this, we 20 had discussion about what the place of the ISG would 21 be with respect to the SRP. We're not modifying the 22 SRP. We're creating an ISG. It will basically layer 23 on top of the SRP. They both are operative guidance.

24 In fact, the SRP actually has a little bit higher 25 standing because it's what's referred to in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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240 1 regulation.

2 So if there's something that we disagree 3 or we find that there's a conflict between the 4 guidance we're providing in ISG-06 and what's in the 5 standard review plan, then, okay, that's a different 6 discussion. But when we develop that, we wanted to 7 make them consistent with each other, and I believe 8 they are. And I've read these, and I believe they 9 are.

10 MR. DARBALI: Never mind my comment 11 because the ISG does point to that section.

12 MR. STATTEL: Yes, and we had a discussion 13 of whether it needed to or not.

14 MR. DARBALI: I guess I'm not sure because 15 this particular section does point to that BTP 16 section.

17 MS. GOLUB: Yes, you're right, it does.

18 Okay. So it sounds like, so it sounds good then, 19 right? So it sounds like then this is, I mean, 20 essentially, this level of detail, this type of 21 content, this is what you're looking for if we go down 22 this case two path.

23 MR. STATTEL: Yes. Now, if there is some 24 disagreement with what the guidance, what the review 25 guidance and the review criteria is and in BTP 14, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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241 1 that's a different matter. Then we should be talking 2 about revising the SRP.

3 MS. GOLUB: Yes, okay. From the work that 4 was done for D.4, I don't believe there's any conflict 5 between what's in D.4 --

6 MR. STATTEL: I don't think there is 7 either.

8 MS. GOLUB: -- and the BTP --

9 MR. STATTEL: No, I'm not aware of any.

10 So with that said, I think what you propose here would 11 be acceptable.

12 MS. GOLUB: Okay, good.

13 MR. DARBALI: Well, I think that covers 14 everything in the agenda. Pareez, you wanted to cover 15 another topic?

16 MS. GOLUB: Yes, okay. Thank you for 17 reminding me of that, yes. Yes, we do want to cover 18 another topic, and I guess this is kind of loosely 19 tied to D.4, mostly because it's tied to SERs or LTRs 20 that may be older LTRs, so older approved topical 21 reports.

22 So, Rich, you had given the example of the 23 GE topical, which was a topical pre-dated, I think you 24 said 6/03, 7/14.

25 MR. STATTEL: The oldest of them all.

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242 1 MS. GOLUB: At any rate, so that's sort of 2 one extreme, but maybe there's another topical report 3 which is not quite that old but it's still, let's say, 4 ten years old. And the example I just heard a little 5 bit earlier was Teleperm, that that was an older 6 topical report.

7 So from a LAR perspective, what we end up 8 submitting in the LAR, of course our vendor is going 9 to describe any changes that have been made to the 10 platform, any changes to the processes. But from our 11 perspective, as long as the underlying regulation has 12 not changed and there haven't been massive changes to 13 the regulation, that we are anticipating that that 14 topical report can still be used, but the type of 15 review that was done for GE and the PRNMS would not 16 need to be done for, say, Teleperm and that you would 17 not expect the licensee to, you know, to provide, 18 like, an analysis of, well, these Reg Guides, these 19 IEEE standards, but these are the newer Reg Guides, 20 newer IEEE standards, that you're not looking for some 21 kind of an analysis there.

22 I wanted to bring it up because I know 23 that's a question that comes up a lot on the industry 24 side, and since we have a little bit of time it seemed 25 like a good idea to start that conversation. And, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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243 1 know, I'll look to my colleagues here to jump in.

2 MR. STATTEL: It's a little dance we do 3 every time we get one of these applications.

4 MS. GOLUB: Yes.

5 MR. STATTEL: So we basically have this 6 triangle of requirements that we deal with, so we 7 have, on the one hand, we have at the time the topical 8 report was reviewed, typically they're reviewed to 9 whatever guidance and whatever criteria is applicable 10 at that time. So depending on the time frame, 1993, 11 2004, whatever the time frame is, that's what it's 12 reviewed to. So that's one set of criteria we look 13 at.

14 The second set of criteria we look at is 15 what the licensing basis for the specific plant is, 16 and that's depending on when they receive their 17 construction permit. Typically, it will be based on 18 IEEE 279. More often than not, they're based on 19 plant-specific design criteria, not general design 20 criteria, although they're mostly the same, okay, 21 fortunately I'll say.

22 And then the third set of criteria is 23 today's criteria, right? So we do this, so we have 24 three sets of criteria all based on what was in place 25 at three different periods of time.

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244 1 So we really, we typically would not make 2 a case for a back-fit, so we would not apply today's 3 standards, IEEE 603-1991, to the review. But at the 4 same time, our regulation tells us to use the standard 5 review plan that's in effect six months before the 6 application is received. Now, the standard review 7 plan tells me to use current day standards.

8 MR. BURZYNSKI: But isn't that regulation 9 just for new plant applications?

10 MR. STATTEL: That's 54a(h) I believe it 11 is, something like that.

12 MS. GOLUB: We can look it up.

13 MR. STATTEL: It's basically content of an 14 application, right? But that's what points us to the 15 standard review plan. It doesn't say that. It's 16 content of application. Other than that, there's, you 17 know -- so we have kind of conflicting guidance, so we 18 perform a regulatory analysis.

19 Now, typically, now, we know, we all know 20 in the I&C community that IEEE 603 is not a whole lot 21 different than IEEE 279, and it's not a very difficult 22 assertion that if a system meets IEEE 603 criteria it 23 also meets IEEE 279 criteria. I've never seen a case 24 where it wouldn't. The other way around might be more 25 difficult.

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245 1 So most topical reports are reviewed to 2 IEEE 603, right? And because of that, it's a lot, 3 once I see the application, it's a lot easier for me 4 to follow the standard review plan that tells me use 5 603, evaluate 603 criteria. And then when I apply it 6 to the plant, I don't apply it as a back-fit, I 7 basically draw the conclusion because this system 8 meets IEEE 603 criteria I deduce that it also meets 9 the plant basis criteria, which is either IEEE 279 or 10 whatever the plant licensing basis is, and that's what 11 50.55a(h) says, and that's how Oconee was done.

12 So Oconee was a little bit unique because, 13 in their case, the platform was reviewed against 1998, 14 603-1998 standard. Their licensing basis was 279, and 15 1991 is the current, okay? So, again, three different 16 sets of criteria. But, fortunately, these criteria 17 aren't that much different, and, even if there are 18 differences, we're able to evaluate the differences.

19 So when you look at the Oconee 20 application, we evaluated against plant design 21 criteria, not general design criteria. For the most 22 part, they were one for one, but in each section 23 you'll see a discussion and a conclusion talking about 24 the differences. So we looked at the differences. We 25 concluded that that system met essentially both sets NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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246 1 of criteria.

2 So we do the same thing with the IEEE 3 standard, right? It's a little awkward the path that 4 we get to that, but we do this little triangle 5 regulatory evaluation and we do it every time.

6 Now, we have had a lot of pushback and we 7 did get some pushback from licensees basically saying, 8 oh, it's inappropriate for you to use 603 criteria 9 because we're a 279 plant. That's a common discussion 10 we have during pre-app meeting. But the reality of it 11 is we've already evaluated the platform under 603. We 12 know what the differences between 279 and 603 are, and 13 they're not that great. So, you know, we're not 14 talking about spending 10,000 more hours in order to 15 do a 603 evaluation versus a 279 evaluation.

16 But there are gaps. They're small. The 17 gaps are small. The gaps between design criteria are 18 small, and we're able to fill those gaps by writing 19 those evaluations and specifically to do that. And 20 that's one of the reasons they're written that way.

21 So if you have questions for me, I mean, 22 I'll try to answer them.

23 MS. GOLUB: So I guess I was thinking more 24 about the licensing topical report.

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247 1 the software program manuals.

2 MS. GOLUB: Okay. Let's go with yours 3 then.

4 MR. STATTEL: So with, I guess, Hope 5 Creek, with Hope Creek, the awkwardness there was that 6 the original safety evaluation that was done by Mike 7 Waterman, it was done in 1993, and it did not consider 8 any of the criteria of BTP 14 or any of the Reg Guides 9 or IEEE 603 at all. It did not consider any of that, 10 right? It was only based on 279.

11 Now, and, actually before me, before I got 12 involved, before Hope Creek, the first application 13 that came in that was questioned was Grand Gulf, and 14 Grand Gulf, Bernie was the reviewer. He basically saw 15 this gap, right? And he wanted to fill that gap, and 16 he wrote RAIs. So he wanted to know how that system 17 met the criteria, the licensing basis criteria. And 18 they worked through several RAIs. They went back and 19 forth. They wanted to evaluate processes, they wanted 20 to evaluate, you know, aspects that were not in 21 existence in 1993.

22 Now, they completed that evaluation, and 23 the subsequent evaluation was Columbia. And when 24 Columbia came in, essentially they looked at the 25 president of Grand Gulf and they said, well, we're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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248 1 going to do the same thing. And they wrote a whole 2 bunch of RAIs, a whole bunch of documents went back 3 and forth to the NRC. We drew the same conclusions 4 based on essentially the same material, right?

5 So now when Hope Creek came in, the 6 difference, the delta was that General Electric had 7 now updated their processes. So rather than, so we 8 had a discussion and the licensee agreed that rather 9 than go through that whole effort again of going back 10 and forth with RAIs and exchange of information, we 11 would simply evaluate those processes.

12 Now, the licensee chose, on their initial 13 application, they submitted those General Electric 14 procedures to the NRC. They were on the docket. They 15 asked us to review them, okay? So we evaluated them.

16 We essentially did a BTP 14 review of those, and, in 17 the process, we actually performed a regulatory audit 18 in Wilmington and essentially we approved it based on 19 current-day processes, and we applied that and that 20 application went out.

21 So there's really no standard for how to 22 do that. I guess if a vendor decides to send an 23 updated topical report and reference new standards, 24 which actually Common Q is doing that right now, 25 that's one way. Another way would be basically deal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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249 1 with it on a plant-by-plant basis here. But it's 2 awkward. I acknowledge it's very awkward, but, again, 3 we're trying to address directives that we have coming 4 from different places.

5 MS. GOLUB: I appreciate that, but I 6 guess, you know --

7 MR. STATTEL: And it's always unique 8 because every plant has a different basis.

9 MS. GOLUB: So letting sort of the GE 10 example go for a minute, and let's let Common Q go 11 because apparently you are also re-submitting. So 12 let's choose platform X that is subsequent to the 1993 13 SER for GE, so they did address the Reg Guides, they 14 did address earlier versions of the Reg Guides, 603 --

15 MR. DRAGOVICH: A good one would be 16 Teleperm.

17 MS. GOLUB: Right. So Teleperm. That was 18 the one that I addressed to begin with. So Teleperm, 19 okay? And let's say, you know, Ray or somebody 20 decides to put in that system, help me understand, in 21 the LAR or in the pre-application review meeting, we 22 come in, we bring the vendor, we present the 23 differences. There have been no regulation changes, 24 so they continue to meet the underlying regulations 25 that were there. What else would be expected for that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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250 1 vendor? What else would be expected of the licensee 2 to present in either the LAR or in the pre-application 3 review meeting outside of those, a presentation of 4 those differences with a statement that, you know, 5 they continue to meet the underlying regulations?

6 That's really what I'm trying to ask.

7 MR. STATTEL: Fundamentally, the license 8 amendment will be reviewed for compliance basically 9 with the licensing basis for that plant. So if it's 10 a 279 plant, that's what we're going to use.

11 Now, we're referencing an SE that was 12 evaluated against 603, so we've got to bridge that 13 gap. So that's what we're doing.

14 MS. GOLUB: I'm not sure I'm asking the 15 right question then because you -- am I asking the 16 right question?

17 MR. ODESS-GILLERT: Go ahead, Samir. What 18 were you going to --

19 MR. DARBALI: What you're saying, Pareez, 20 is if the topical report was evaluated to an older Reg 21 Guide --

22 MS. GOLUB: Yes, that's the question I'm 23 asking.

24 MR. DARBALI: -- which Reg Guide would be 25 used to evaluate the LAR?

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251 1 MS. GOLUB: That's the question, yes. I 2 just want to make sure that, because we've heard 3 different, you know, we've heard different things on 4 the industry side, and I'm thinking about, you know, 5 this industry guidance document and how to address 6 this issue, which it does come up.

7 MR. BURZYNSKI: Because all of the Reg 8 Guides have been re-issued and they've all endorsed 9 later versions of the standards than are in the 10 Teleperm software program manual.

11 MR. STATTEL: True. That's true.

12 MR. HERB: And let me add a clarification 13 to that because, from my aspect of that, from the 14 licensee's point of view on that is what we would 15 write in the LAR, and it's really back to case one 16 where there's maybe a software program manual that's 17 already been approved, when we would do our vendor 18 oversight of that development process for our 19 application, we would inspect the vendor to their 20 software program manual. We wouldn't necessarily 21 inspect them to BTP 7-14 or to the guidance. We would 22 assume, since it was already approved, if it was a 23 pre-approved software program manual, that it still 24 met the same underlying guidance. And so we wouldn't 25 pull the string all the way back to the current NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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252 1 regulatory guidance or the criteria. We would assume 2 that when you accepted our LAR and you would say, 3 okay, it's approved, we're good, and you do your 4 triangular stuff that you keep talking about, which 5 I'm not sure how that goes to a software program 6 manual, but, again, we would not do our vendor 7 oversight against your criteria. We would do it 8 against their program that they described, we 9 described in the LAR.

10 MR. ODESS-GILLERT: So, Ray, we're focused 11 back --

12 MS. GOLUB: Yes, that's a different 13 question.

14 MR. ODESS-GILLERT: We're focused back at 15 the LAR.

16 MS. GOLUB: Yes, we can talk about that 17 question, too, but this is a different one.

18 MR. ODESS-GILLERT: What we're focusing on 19 is, okay, so, Ray, so what we're talking about is the 20 LAR says, for D.4, we are referencing the Teleperm XS 21 software program manual that's been previously 22 approved. Therefore, there's no more we need to 23 discuss about in D.4 because it's been approved and 24 we're going to go forward with that.

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253 1 that's, that's, that the NRC doesn't have any issue 2 with the fact that the SPM is ten years old because, 3 unless the regulations changed since that time, it 4 should still be supporting the regulation.

5 MR. STATTEL: That's true. I agree with 6 you. I guess I'm looking over to Steven there to help 7 me out on this one because I would think that, yes, 8 that's acceptable. I would not -- there are newer 9 versions of BTP 14, right? I know what the changes 10 are. I would not have any qualms about approving, if 11 someone came in with a TXS application, I know what 12 that software program manual was evaluated against and 13 I would have no qualms about approving an application 14 that referenced that. I wouldn't basically try to 15 apply more up-to-date criteria on that. That's just 16 me, though.

17 MR. DARBALI: If there are any 18 application-specific review, it would be done based on 19 the current.

20 MR. ODESS-GILLERT: No, the application 21 activities would be based on conformance to the 22 approved SPM.

23 MR. STATTEL: The SPM, yes. Now, there 24 may be overriding factors. So as you know in new 25 reactor space, there might be a design certification NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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254 1 and there might be a commitment in that design 2 certification to conform to a particular standard, and 3 that may be a different standard than what the SPM is 4 evaluated to. So there are circumstances where that 5 --

6 MR. ARNDT: I think, going back to the 7 statement we made earlier, the key is what exactly are 8 we trying to accomplish? And what we're trying to 9 accomplish is reviewing something against a set of 10 regulatory infrastructure that points back to a 11 particular regulation. So if the regulation hasn't 12 changed, which it very seldom does, and there's no 13 other extenuating circumstances, like, for example, 14 the design cert which is a regulatory change or there 15 is some specific new regulatory information or 16 document that tells us that whatever was reviewed in 17 the past is no longer the agency position on that 18 regulation, again, it happens very rarely, like, for 19 example, if we had withdrawn a topical report or 20 approval of a topical, cross flow being an example, or 21 had some other proactive decision to say that that was 22 not, was no longer an acceptable regulatory action.

23 It would be equivalent of basically going in and 24 saying we've done this, you plant or you vendor either 25 now or in the past have misinterpreted the regulatory NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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255 1 guidance that we approved you under, some criteria 2 either in the guidance or the regulation. Those 3 happen. They happen very rarely. There's one right 4 now, if you follow Duke plants, it's not an IZ issue.

5 But unless something like that has 6 happened, and you should know about that, our 7 interpretation of the compliance of that document to 8 the underlying regulation has not changed. So it goes 9 back to this party kind of thing. We haven't changed 10 our underlying understanding of the licensing basis 11 for the guidance by which the topical was approved.

12 MR. STATTEL: But let me say something, 13 and this might sound a little profound to some of you.

14 Let's say I have an application and my standard review 15 plan says use a current version of standard X, and 16 that current version is the 2008 version, but I know 17 the licensing basis goes back to an older version, 18 right? I know the licensing basis is 1974, okay? If 19 it were to happen that I found it to be not compliant 20 with the new version of the standard but compliant 21 with the old version, I will say right now I would 22 approve that application, even though it doesn't 23 comply with the new version of that standard.

24 This has never happened. I've been here 25 for ten years. I have never seen this happen. And I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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256 1 say this often: it's fortunate that these standards 2 haven't changed that drastically because, in reality, 3 you know, when you look at the fundamental principles 4 that are put out in these standards, they're core 5 principles and they really haven't changed over the 6 years. The methods have changed. Some of these 7 standards have changed significantly, and some of them 8 create problems when you try to implement them or 9 convert from an old standard to a new standard. But, 10 fundamentally, they're trying to accomplish this, they 11 have similar objectives and they haven't changed over 12 the years.

13 So even though our review plan and our 14 decisions when we perform our regulatory analysis have 15 us using newer standards, I know there's a perception 16 out there that, oh, that's inappropriate for the NRC 17 to use that standard that's different from what the 18 licensing basis is, but the reality of it is it 19 doesn't take a lot more effort to do that, right? As 20 a matter of fact, we're a lot more familiar with the 21 new standards than we are with the older ones, right?

22 Not that we're not looking at them, okay? And the 23 truth is if we can show that it's compliant with the 24 newer standard, it's a very easy case to say, well, in 25 that case, we can also agree that we haven't violated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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257 1 the original licensing basis for that particular 2 plant.

3 But, fundamentally, if it were to come to 4 pass that I found something not compliant with 5 something in IEEE 603-91 but compliant with 279 and 6 it's a 279 plant, I would have to approve that license 7 amendment because, fundamentally, of the three points 8 of the triangle, the one that matters is what the 9 licensing basis is, unless, of course, I'm applying a 10 back fit, which we've never done that either in these 11 cases.

12 So it may seem odd to use different 13 standards or newer standards to apply to a safety 14 evaluation to determine compliance with a licensing 15 basis, but it's actually a more efficient method than 16 a different way, particularly when we're referring to 17 license topical reports.

18 Now, we've had discussions in the past 19 about updates of topical reports. Some vendors have 20 provided updates to topical reports, and it certainly 21 benefits them to do that because the newer topical 22 reports that reference newer standards, it's a lot 23 easier to draw the line and basically that would 24 overcome, it would basically cover every licensing 25 basis for every plant that would reference that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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258 1 platform. It's a lot easier to get there. The older 2 ones are challenging, and Hope Creek was a good 3 example of that.

4 MR. ARNDT: Rich, and one of the other 5 issues is usually, not always but usually the newer 6 standards are a better fit for the new technology 7 because they were developed assuming those kinds of 8 issues. So it's easier to interpret, for an FPGA for 9 example, the updated Reg Guide than it is to go all 10 the way back to the stuff that was done in the 70s.

11 It's just very difficult to make that interpretation.

12 So it's usually an easier process both in 13 terms of the kind of questions we ask and the kind of 14 documentation provided. In most cases, the vast 15 majority of cases, it's much more efficient.

16 MR. STATTEL: Now, recently we've gotten 17 a lot of applications that the licensee references 18 general design criteria. They essentially, they point 19 that out, the general design criteria, even though 20 their licensing basis has plant-specific design 21 criteria, right? And we've also had licensees, quite 22 a few licensees call foul when we try to apply general 23 design criteria, but we've been using general design 24 criteria for many years and we've had a whole lot of 25 applicants or a whole lot of license amendments that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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259 1 we've done where that's okay, nobody has an issue with 2 that.

3 So there's all kinds of cases of this, but 4 we certainly acknowledge we're not trying to apply 5 back fits here. More recently, we based our safety 6 conclusions, our license amendment approval on plant 7 design criteria. We've gotten recent direction to do 8 that.

9 Now, again, fortunately, every one, I've 10 looked at a dozen of these things, every one of the 11 plant design criteria, it can be mapped. A lot of 12 times the FSARs have mappings within them that map to 13 the general design criteria, and those criteria have 14 been around since the 60s. They have not really 15 changed since the 60s.

16 MR. SCHLAGE: I just want to ask a 17 question. I'm from Entergy, and I'm part of the team 18 here. My question kind of comes from my experience at 19 a lot of plants, a lot of older plants. So you write 20 an SE, and you're referencing a later standard for 21 this new equipment. Then is the licensing basis for 22 this new equipment the newer standard or is it still 23 the original licensing design criteria?

24 MR. STATTEL: It's still the original 25 licensing design criteria.

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260 1 MR. SCHLAGE: Just a little bit of 2 experience is sometimes that's very confusing for 3 regional inspectors to understand.

4 MR. WATERS: I know Rich is talking more 5 about the IEEE basis and the regulation. I think you 6 are talking more the computer standards, for example, 7 and all the versions of Reg Guides, which is hard to 8 translate. I don't know if we answered your question.

9 I think the computer standard is more the input 10 standards. Is there any clarity that's needed in the 11 ISG-06 to --

12 MR. ODESS-GILLERT: Yes, you hit it right 13 on the nail that that was our concern was the software 14 standards. But I think I heard from the staff that 15 they would accept an approved SPM that was reviewed to 16 earlier Reg Guides and IEEE standards as long as the 17 underlying regulation hadn't changed and the caveats 18 that Dr. Arndt had mentioned.

19 MR. STATTEL: Now, of course, of course 20 our standard review plan is going to give us direction 21 to look at the current standards. I mean, it would be 22 a little complicated if it said, if it pointed us to 23 -- what would it point us to, you know, because it's 24 going to vary by plant.

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261 1 what?

2 MR. STATTEL: No, if the standard review 3 plan, of course, when we update the standard review 4 plan, of course it's going to point us to current-day 5 standards, right?

6 MR. BURZYNSKI: I think the operational 7 thing, though, is if you use a later one because you 8 liked it, that's fine. But if you use it then to say 9 here's your RAI, explain the differences between the 10 two standards and justify them, then that would be the 11 problem on our side.

12 MR. STATTEL: We shouldn't do that. I 13 agree. If we write an RAI, typically I would want it 14 to refer back to a licensing basis for that plant, 15 right? Now, you know what 279 says and you know what 16 603 says. If I referenced a clause in IEEE 603, you 17 know there's an equivalent clause in 279, right? So 18 that's really not, it's not as big of an issue as it 19 seems to be because the criteria, the four criteria 20 are not different. And if you think it takes a 21 thousand hours to do a 603 review and only a hundred 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> to do a 279 review, then you don't understand 23 what those standards are.

24 MS. GOLUB: You know, and, again, our 25 concern was more for the software standards and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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262 1 LTR. We're thinking about D.4, what do we need to 2 include, what do we need to address in the application 3 --

4 MR. BURZYNSKI: If somebody said to me 5 today compare and justify the differences between IEEE 6 829, whatever and whatever, in order to support your 7 review, that is a lot of work.

8 MS. GOLUB: Yes.

9 MR. STATTEL: I agree that can be a lot of 10 work but that's actually work that gets done when we 11 update our Reg Guide. We do that. We evaluate what's 12 changed in those standards, so that's part of the Reg 13 Guide. We do that. I wouldn't ask a licensee to do 14 that. That seems awkward.

15 MR. HOOTEN: So if that was done, if work 16 was done in accordance with a standard that was 17 approved or was endorsed under a prior revision of a 18 Reg Guide, then my understanding is that that prior 19 revision of the Reg Guide was making the assertion 20 that work to that standard meets the underlying 21 regulation.

22 MR. STATTEL: But it was an acceptable way 23 of meeting the underlying regulations. And that 24 doesn't change even if a newer version is endorsed.

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263 1 gets endorsed by a revision to that same Reg Guide, it 2 would still seem to me to be perfectly acceptable to 3 use the older standard as long as the underlying 4 regulation hasn't changed, right? If it was judged at 5 one time that that older standard still supported the 6 underlying regulation which still exists, then I don't 7 see why there would be any reason why you would have 8 to use the newer version just because it came out and 9 was endorsed. Is my thinking off track there?

10 MR. STATTEL: No, you're absolutely 11 correct. And, actually, we do get references to older 12 versions of Reg Guides and older IEEE standards.

13 That's not uncommon at all, particularly it goes back 14 to the monitoring systems. Very few plants are based 15 on the current version of the PAMS Reg Guide.

16 MR. DARBALI: So, Rich, have you seen Reg 17 Guides being created that are not because of a new 18 standard that they were to endorse?

19 MR. STATTEL: No, it's always because IEEE 20 changes, updates the standard.

21 MR. ARNDT: Well, it's not always. It's 22 99 --

23 MR. STATTEL: If you stop changing the 24 standard, we'll stop updating the Reg Guides.

25 MR. ARNDT: But the point, I think, is if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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264 1 there's no reason to believe that the older version no 2 longer meets the underlying regulation that has to 3 change, then there's no reason to believe that there 4 needs to be a reference to something that's different.

5 If you choose to reference something different, and 6 this really gets to the vendor side of the business, 7 if you choose, say, for example, let's say 8 hypothetically two years from now we end up endorsing 9 a parallel standard, we change our endorsement of 10 something to now reference both the IEEE standard and 11 I&C standard, and you choose to use that, that's fine.

12 You're choosing to update your regulatory basis in 13 that fashion. It is something we'll have to evaluate.

14 But if you choose not to do that, and I think most of 15 that would be driven by the vendor design process if 16 they chose to use, the classic example that gets 17 thrown around here, one of the FAA standards and, for 18 some reason, we end up endorsing an FAA standard, that 19 obviously would have a very different perspective in 20 terms of regulatory efficiency and actual design 21 basis.

22 MS. GOLUB: Thank you. That was a very 23 helpful discussion. I appreciate you guys taking that 24 question. It was very helpful.

25 MR. STATTEL: I don't have the ultimate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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265 1 answer, but, you know, again, there's also technical 2 correctness. When you think about it, most vendors 3 would agree that it's more appropriate to use IEEE 603 4 and 7432 as evaluation criteria than it is to use a 5 1971 version of 279 because, obviously, there weren't 6 a whole lot of computer systems present in 1971. So 7 the guidance, even though the underlying principles of 8 the guidance haven't really changed and the 9 performance requirements are the same because these 10 are performance-based guides, the newer standards are 11 more informed about digital technology. So of course 12 you would want, you would want to develop your system 13 to 7432, to the 7432 criteria because it's a better 14 fit.

15 We're really not talking about back-16 fitting. We're just talking about applying the right 17 standard to the right technology. I'm not going to 18 say digital technology is new or unique or anything 19 like that. It's been around a long time. But it 20 wasn't there in 1971. It wasn't there when these 21 plants were first licensed.

22 Now, it doesn't warrant a back-fit. We're 23 not saying this is significant enough of an issue, a 24 safety issue to warrant a back-fit. But at the same 25 time, it makes perfect sense to apply standards that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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266 1 are informed by the existence of that technology.

2 MS. GOLUB: Okay. I think that was very 3 helpful. Thank you.

4 MR. WATERS: I just want to say for the 5 record if you have questions about the rivets or the 6 durability of a topical report, specifically software 7 standard, we understand it, but there's a broader 8 issue for all topicals. So I don't think this is 9 industry guidance for all topicals. I think you know 10 that. It was a good discussion.

11 MS. GOLUB: Yes, thank you.

12 MR. DARBALI: So I'll hand it over to Joe.

13 MR. GOLLA: Okay. So we've reached the 14 end of day one. Great. So are there any questions on 15 the phone, particularly from the public? Any members 16 of the public on the phone that would like to ask a 17 question or make a comment? Hearing none, I think 18 we've made our final comments for the day, and so 19 we'll adjourn now. Okay. Thank you.

20 (Whereupon, the above-entitled matter went 21 off the record at 4:22 p.m.)

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