ML19105B177
| ML19105B177 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/2019 |
| From: | Lawrence Burkhart Advisory Committee on Reactor Safeguards |
| To: | |
| Burkhart L | |
| References | |
| NRC-0127 | |
| Download: ML19105B177 (294) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
660th Meeting, Advisory Committee on Reactor Safeguards (ACRS),
Open Session Docket Number: N/A Location: Rockville, Maryland Date: February 6, 2019 Work Order No.: NRC-0127 Pages 1-294 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 660TH MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +
8 WEDNESDAY 9 FEBRUARY 6, 2019 10 + + + + +
11 ROCKVILLE, MARYLAND 12 + + + + +
13 The Advisory Committee met at the Nuclear 14 Regulatory Commission, Two White Flint North, T3D50, 15 11545 Rockville Pike, at 8:30 a.m., Peter Riccardella, 16 Chairman, presiding.
17 18 COMMITTEE MEMBERS:
19 PETER RICCARDELLA, Chairman 20 MATTHEW W. SUNSERI, Vice Chairman 21 JOY L. REMPE, Member-at-Large 22 RONALD G. BALLINGER, Member 23 DENNIS C. BLEY, Member 24 CHARLES H. BROWN, JR. Member 25 MICHAEL L. CORRADINI, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 VESNA B. DIMITRIJEVIC, Member 2 WALTER L. KIRCHNER, Member 3 JOSE MARCH-LEUBA, Member 4 HAROLD B. RAY, Member 5 GORDON R. SKILLMAN, Member 6
7 DESIGNATED FEDERAL OFFICIALS:
8 DEREK WIDMAYER 9 QUYNH NGUYEN 10 MIKE SNODDERLY 11 ZENA ABDULLAHI 12 13 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 T-A-B-L-E O-F C-O-N-T-E-N-T-S 2 Page 3 Opening Remarks by the ACRS Chairman . . . . . . 4 4 Technology-Inclusive, Risk-Informed, Performance-Based 5 Approach for Approving Non-Light-Water Reactors 6 Remarks by the Subcommittee Chairman . . . . . . 7 7 Discussion . . . . . . . . . . . . . . . . . . . 13 8 Non-Production & Utilization Facilities 9 Rulemaking . . . . . . . . . . . . . . . . 95 10 Interim Letter: Chapters 2 and 17 of the NRC Staffs 11 Safety Evaluation Reports With Open Items 12 Related to the Certification of the NuScale 13 Small Modular Reactor . . . . . . . . . . 131 14 Adjourned . . . . . . . . . . . . . . . . . . . 217 15 16 17 18 19 20 21 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 (8:31 a.m.)
3 CHAIRMAN RICCARDELLA: Good morning. The 4 meeting will come to order. This is the first day of 5 the 660th meeting of the Advisory Committee on Reactor 6 Safeguards.
7 During today's meeting the Committee will 8 consider the following. Technology-inclusive, risk-9 informed, performance-based approach for approving 10 non-light water reactors, non-power production and 11 utilization facilities rulemaking, Interim Letter 12 Chapters 2 and 17 of the NRC Staff's safety evaluation 13 reports, with open items related to the certification 14 of the NuScale small module reactor.
15 Number 4, review of AURORA-B for LOCA 16 scenarios and preparation of ACRS reports. The ACRS 17 was established by statute and is governed by the 18 Federal Advisory Committee Act, FACA.
19 As such, this meeting is being conducted 20 in accordance with the provisions of FACA. That means 21 that the Committee can only speak through its 22 published letter reports.
23 We hold meetings to gather information, to 24 support our deliberations. Interested parties who 25 wish to provide comments can contact our office NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 requesting time after the federal register notice 2 describing a meeting is published.
3 With that said, we also set aside ten 4 minutes for spur of the moment comments for members of 5 the public attending or listening to our meetings.
6 Written comments are also welcome.
7 Mr. Derek Widmayer is the designated 8 federal officer for the initial portion of this 9 meeting.
10 Portions of the sessions, on Interim 11 Letter Chapters 2 and 17 of the NRC Staff safety 12 evaluation reports with open items may be closed in 13 order to discuss and protect information designated as 14 proprietary.
15 The AURORA-B for LOCA scenario meeting 16 will be closed in its entirety in order to discuss 17 protected proprietary information.
18 The ACRS section of the U.S. NRC public 19 website provides our charter, bylaws, letter of 20 reports and full transcripts of all full and 21 subcommittee meetings. Including all slides presented 22 at the meetings.
23 We have received no written comments or 24 requests to make oral statements from members of the 25 public regarding today's sessions.
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6 1 There will be a phone bridge line, but to 2 preclude interruption of the meeting, the phone will 3 be placed in a listen only mode during the 4 presentations and Committee discussion.
5 A transcript of portions of this meeting 6 is being kept. And it is requested that speakers use 7 one of the microphones, identify themselves and speak 8 with sufficient clarity and volume so that they can be 9 readily heard.
10 As an item of current interests, I would 11 like to welcome to new management and analysts to our 12 support staff, Paula Dorm and Makeeka Compton.
13 MEMBER CORRADINI: They should stand.
14 Stand up.
15 MS. DORM: Hi, I'm Paula.
16 CHAIRMAN RICCARDELLA: That's Makeeka.
17 Hi. With that said, I'll turn the meeting over to 18 Derek Widmayer.
19 MEMBER BLEY: Well, speaking on Derek's 20 behalf, this is --
21 (Laughter.)
22 MEMBER BLEY: I'd like to welcome 23 everybody to our December meeting to look at the 24 Staff's proposed SECY and guidance documents on the, 25 what we were calling the licensee modernization NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 project and is now called the Technology-Inclusive, 2 Risk-Informed and Performance-Based Approach, to 3 inform the content of applications for licensees' 4 licenses.
5 At this point, Bill, am I going to turn it 6 over to you or John?
7 MR. SEGALA: Yes.
8 MEMBER BLEY: John Segala, please 9 introduce this for us.
10 MR. SEGALA: Thank you, Dr. Bley. I'm 11 John Segala, I'm the Chief of the Advance Reactor and 12 Policy Branch in the Office of New Reactors, and I'm 13 appreciative of the ACRS inviting us here today.
14 We had previously briefed the Subcommittee 15 back in October and we were scheduled to brief the 16 Full Committee in early December, but due to President 17 Bush's funeral and the Government closure at that 18 time, we got rescheduled. So I appreciate you 19 accommodating us today.
20 We have, as you said, we're moving forward 21 with commission paper. We're also developing an 22 associated draft regulatory guide.
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8 1 also ran into some internal concurrence issues.
2 So we're still working to get that draft 3 guide out as soon as possible, but I just wanted to 4 update you on where we were with that.
5 MEMBER BLEY: Thank you. We look forward 6 to seeing that.
7 MR. SEGALA: Okay. So I also wanted to 8 sort of step back based on some things that have 9 happened since we last met.
10 First of all, as you know, when you look 11 at some of the designers out there that might be 12 considered early movers, ones that would be coming in 13 with an application using the current regulations.
14 We see the licensee modernization project 15 in our draft guide as very important for helping to 16 establish, as you said, a technology-inclusive, risk-17 informed, performance-based approach for establishing 18 the licensing basis and the content of the 19 application.
20 In addition, recently, the Nuclear Energy 21 Innovation and Modernization Act was signed into law.
22 That's requiring the NRC to develop a technology-23 inclusive, risk-informed, performance-based regulation 24 for advance reactors. We call this Part 53, although 25 it's not officially a Part 53.
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9 1 But we see, we don't know the exact scope 2 of what this is going to be, but we see the licensing 3 modernization project as forming the foundation for 4 this future rulemaking that we have to do by 2027.
5 So I just wanted to sort of set the stage 6 for that. We're looking for the ACRS today to provide 7 feedback on our commission paper and to provide us a 8 letter on the commission paper.
9 So that's our goal for today. And we're 10 looking forward to having discussions.
11 MEMBER BLEY: Thanks for that. What's the 12 status of the paper now, I thought you were, you were 13 hoping to get it out already?
14 MR. SEGALA: Yes. And we're still working 15 on getting that out as well.
16 MEMBER BLEY: Okay.
17 MR. SEGALA: It's in final concurrences 18 now.
19 MEMBER CORRADINI: So, just to clarify one 20 thing. So, the intent is the technical basis we're 21 going to be talking about today would probably be what 22 you would point to in satisfaction of this new 23 congressional action?
24 MR. SEGALA: It will help form the base 25 foundation for that new rule.
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10 1 MEMBER CORRADINI: Okay, thank you.
2 MR. SEGALA: So I just wanted to put that 3 in perspective for you that this is where, we had 4 always, when we had developed our vision and strategy 5 document and our implementation action plans, we had 6 always included in the mid-term and the long-term 7 implementation action plans, a plan to look at whether 8 or not we should be doing a new rule for advance 9 reactors.
10 Now, with this law, we were being told to 11 just do it. So, we had always thought that LMP would 12 eventually help form the basis if we end up, in the 13 future, ever did a new rule. But now that that's 14 become a reality, we're moving forward with that in 15 mind.
16 MEMBER BLEY: Well, it's nice to be a 17 little ahead.
18 MR. SEGALA: Yes. For once.
19 MEMBER REMPE: John? You mentioned that 20 you were hearing some of the design developers 21 expressing interest in using what is in the NEI 22 document and this approach, can you characterize a 23 little bit more about how strong that interest is and 24 the schedule when you'd anticipate them to actually 25 trying to apply it?
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11 1 MR. SEGALA: Well, I guess it depends on 2 who you talk to. There has been, we've generally 3 heard favorable responses from designers on using it.
4 We're not quite sure if everybody is going to use it.
5 There have been, as we mentioned in a 6 Subcommittee meeting, there's been a number of 7 tabletops or --
8 MEMBER REMPE: Right.
9 MR. SEGALA: -- pilots of LMP. X-energy 10 has done it, Oklo has done it.
11 We're looking to, I believe Kairos is 12 planning to do it. Westinghouse, for the eVinci, is 13 planning to do a tabletop.
14 And so, we're hearing a lot of interests 15 in using it. I think the one area that we're not 16 quite sure, that we haven't heard as much, has maybe 17 been in more the molten salt reactors.
18 MEMBER REMPE: So, okay, let's pick on X-19 energy. Have they said, hey, we're going to use it, 20 we're going to be here within the next year to come, 21 or how strong is that is interest?
22 Or is there anyone who said, I'm going to 23 be here in the next year?
24 MR. SEGALA: I can't really talk about 25 that because that information is proprietary.
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12 1 MEMBER REMPE: Okay. But without 2 characterizing anyone, you can't tell me if anyone has 3 said they're going to be here in the next year, the 4 next two years, next five years?
5 MR. SEGALA: We are currently expecting an 6 application within the next year or so.
7 MEMBER REMPE: Okay.
8 CHAIRMAN RICCARDELLA: Excuse me, we need 9 to pause the meeting for a second so that we can open 10 the phone for outside. And it's going to be a little 11 noisy.
12 (Off record comments.)
13 CHAIRMAN RICCARDELLA: Okay, you can 14 continue.
15 MR. SEGALA: So that's all I had in terms 16 of --
17 CHAIRMAN RICCARDELLA: Thanks.
18 (Laughter.)
19 MEMBER CORRADINI: I'm sure the people on 20 the line enjoyed that conversation. But that was the 21 introduction, that's all you had.
22 MR. SEGALA: We're done.
23 (Laughter.)
24 MR. SEGALA: You can write the letter 25 right now.
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13 1 CHAIRMAN RICCARDELLA: Correctly.
2 MR. SEGALA: Do you want Bill to swear on 3 a Bible since he's in the court of law here?
4 MR. RECKLEY: No, thank you. Okay, so, 5 again, I'm Bill Reckley and I'm going to walk through 6 some of the background, the guidance.
7 We still call it licensing modernization 8 project as well, but the official document is a draft 9 of NEI 18-04 and a draft regulatory guide which 10 provides the background into elements of how we would 11 approach licensing of non-light water reactors. It's 12 not the total story but it's been, these areas are the 13 cornerstones, if you will, of a licensing approaches.
14 And then that feeds into the draft commission papers.
15 As John said, when we came in October, we 16 were really kind of looking for a letter on both the 17 guidance, so, down in the details, as well we the 18 higher level, that would be addressed in the 19 commission paper. Although things haven't really 20 panned out as we thought.
21 We thought the draft guide would be out by 22 now and so, but we're going to stick to the plan that 23 the draft guide will be going out for comment and 24 we'll return to the ACRS for the final guide. And 25 that's the details, both in the NEI guidance document NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 and the draft guide.
2 MEMBER BLEY: Bill?
3 MR. RECKLEY: Yes.
4 MEMBER BLEY: At that time, will there be 5 any additional tabletop work completed? And if so, 6 can we include some of that in the --
7 MR. RECKLEY: Yes. Yes. Anything that is 8 done and any actual insights, even from the two 9 tabletops that have been done.
10 At the Subcommittee meeting we talked 11 about the PRISM tabletop, but the report wasn't out.
12 MEMBER BLEY: We did get it, yesterday, I 13 think.
14 (Laughter.)
15 MR. RECKLEY: Yes. We've provided it. I 16 know. We'll, we only got it Friday, so it wasn't as 17 --
18 MEMBER BLEY: Okay, fair enough.
19 MR. RECKLEY: -- if we were holding it.
20 But now that the report is out that would be perhaps 21 another topic, as well as any other tabletops that are 22 done, as John mentioned, on any of the other 23 technologies.
24 And any insights that we get from the 25 commission, from the paper, ACRS, discussions at this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 and any additional meetings that we have, and then the 2 public comment itself. And then at the same time, the 3 industry, all of the developers, or many of the 4 developers, are looking at it in real time.
5 And they might provide comments, both to 6 us and to the, to NEI, for incorporation into the 7 final NEI document. So it's still a little bit of a 8 fluid process, but nothing to date has been identified 9 that really changes things dramatically.
10 MEMBER BLEY: If I can --
11 MR. RECKLEY: Sure.
12 MEMBER BLEY: -- with one. I'd like to 13 hear from, at that time, from both you and folks from 14 the industry, in the tabletops that will have been 15 done by that point.
16 I'm interested in, are there any aspects 17 of the NEI document and your guide that have not been 18 tested.
19 MR. RECKLEY: Okay.
20 MEMBER REMPE: While we're talking about 21 those tabletops, this is the first time I heard that 22 something like an Oklo's reactor that is more of, 23 really a departure from the established PRISM and the 24 pebble bed that we've heard about for a long time.
25 Are you familiar with what occurred in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 that tabletop? Is there a document, were you there?
2 Something that doesn't maybe have a PRA 3 for example, how did that work?
4 MR. RECKLEY: We'll provide the report, 5 the public version of the report today's ACRS.
6 Actually, we --
7 MEMBER REMPE: Is it done?
8 MR. RECKLEY: There is a public version 9 available now.
10 MR. SEGALA: There is one, I'm not sure 11 it's been made public yet.
12 MR. RECKLEY: Okay.
13 MR. SEGALA: We went through the process 14 --
15 MR. RECKLEY: All right.
16 MR. SEGALA: -- of getting a redacted 17 version of that.
18 MR. RECKLEY: So, when it is public, we 19 will provide it.
20 MEMBER REMPE: Can you give us a heads up, 21 how did it go or anything, or you just got to wait 22 till it becomes public to talk in a public meeting 23 about it?
24 MR. RECKLEY: It would be better if we 25 waited.
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17 1 One of the lessons that we really look to 2 get out of, not only Oklo but then probably some of 3 the other micro-reactors, is, within this methodology, 4 which has its roots going all the back into the '80's 5 for a different technology, whether the micros do fit, 6 whether the guidance needs to be tweaked because the 7 micros are different enough from the MHTGRs and the 8 PRISMs, that size, that medium size, whether the 9 guidance needs to be tweaked, whether additional 10 guidance might be developed for micros.
11 So that is one of the things we're looking 12 to get out of some of the recent and planned 13 tabletops.
14 MEMBER REMPE: And did you see that the 15 guidance needs to be tweaked or you can't, you're 16 still trying to decide?
17 MR. RECKLEY: I'm not sure that we saw 18 that. It may be that the language here or there needs 19 to be clarified.
20 But, again, I think because we're 21 addressing these key elements, the identification of 22 events, the classification of the SSCs and an 23 assessment of defense-in-depth, those are things that 24 any size reactor, even non-reactors, need to address 25 that.
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18 1 And so, I don't think there will be any 2 fundamental shifts, but there may be areas where 3 they're different enough, the behaviors and their 4 reliance on inherent features for intrinsic 5 characteristics, whatever the key phrase is there, 6 might need to get reflected a little more in the 7 guidance.
8 MEMBER REMPE: Okay, thank you.
9 MR. RECKLEY: So, as John mentioned, 10 although it didn't pan out, we still expect to issue 11 the draft guide and wouldn't really be able at this 12 point, hopefully. It's near enough in the future that 13 we wouldn't be able to take into account ACRS comments 14 on the draft, but we'll come back for the final.
15 On the commission paper, it's changed in 16 that we would now expect to wait for your letter 17 before sending up the commission paper. So, as 18 opposed to telling the commission in the paper, the 19 little couple of sentences, you'll get a letter from 20 ACRS, it will be, you've gotten a letter from ACRS.
21 MEMBER BLEY: We're hopeful in that.
22 (Laughter.)
23 MR. RECKLEY: Well, again, yes. We can 24 always change it back.
25 So, just, in terms of the background and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 kind of higher-level activity, I won't spend a lot of 2 time because we have gone over this numerous times 3 between Subcommittees and Full Committees, the non-4 light water reactor program, or advance reactor 5 program, we've defined through a number of strategies 6 and then activities within strategies.
7 Trying to increase the skills and 8 capability of the staff is Strategy 1. That's 9 training and so forth.
10 Strategy 2 is trying to make sure we have 11 the analytical tools, the computer codes, simulation 12 models.
13 Strategy 3 is licensing processes. And 14 that's largely what we're going to be talking about 15 today, the licensing modernization project or NEI 18-16 04.
17 Strategy 4 is consensus codes and 18 standards. The major activity there is ASME Section 19 3, Division 5 for high temperature materials.
20 Strategy 5 is policy issues. And I will 21 make a mention that the checkmark on functional 22 containment, we not only sent the paper up last year, 23 SECY-18-96, but we got the commission decision and the 24 Staff's requirements memorandum dated December 4th, 25 saying that we could proceed with that approach, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 functional containment.
2 MEMBER BLEY: Bill, I don't think we've 3 seen the SRM.
4 MR. RECKLEY: Okay. It will be --
5 MEMBER BLEY: I guess it's public?
6 MR. RECKLEY: Yes.
7 MEMBER BLEY: Yes, we can get it.
8 MR. RECKLEY: Okay. It was --
9 MEMBER BLEY: Didn't know it was out. And 10 while I say that --
11 MR. RECKLEY: Sure.
12 MEMBER BLEY: -- are you going to talk 13 about EP for us in a moment? What's the status there?
14 MR. RECKLEY: That's currently before the 15 commission and we're still waiting for a commission 16 decision on that proposed rulemaking. So the next 17 step is expected to be the issuance of a proposed rule 18 for public comment on how to consider potential 19 reductions in emergency planning zones for advance 20 reactors and other new technologies, which includes 21 not only non-light water reactors but small light 22 water reactors, such as the NuScale SRM. And then 23 also, medical isotope production facilities.
24 And, yes, we can get you that but it's 25 available on the commission's site.
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21 1 MEMBER BLEY: Yes.
2 MR. RECKLEY: It's a clean SRM, so --
3 MEMBER BLEY: Oh.
4 MR. RECKLEY: -- I mean, it basically said 5 what we addressed in the SECY paper and what the ACRS 6 recommended in the letter, we could proceed with that 7 approach.
8 MR. SEGALA: I'd just like to also add on 9 EP, that based on your letter and our response to your 10 letter, we have added, we're in the process of adding 11 some wording to the draft guide for that on source 12 term and PRA. There's a little bit that we've added.
13 And we're going to share that with you when we send 14 that out.
15 MEMBER BLEY: Okay, thanks.
16 MR. RECKLEY: The two boxes at the bottom 17 here are just, as we're doing this infrastructure 18 work, if you will, we're trying to keep an eye on 19 potential first movers and then things like micro-20 reactors and the request for information that's been 21 issued, both by the Department of Energy and the 22 Department of Defense.
23 And so we're trying to keep an eye on 24 those activities, to Dr. Rempe's point, just to try to 25 make sure that we're not caught by surprise by an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 applicant coming in sooner than what we're prepared 2 for.
3 So, as things firm up, again, keeping an 4 eye on largely the DOE and DoD activities, if we see 5 something starting to move, we would shift and try to 6 make sure that we have preparations underway for that 7 application, should it come in.
8 Okay. I'm going to go through a couple 9 nightmare figures here for the next couple slides.
10 So the first is, I've used this in 11 previous presentations to the ACRS, it's a kind of a 12 generic risk assessment, risk communication tool 13 called a bowtie diagram. And it goes through a 14 process of looking at barriers and measures to prevent 15 a top-level event and measures that one might take to 16 mitigate or recover from a top-level event.
17 So, in light water space the top-level 18 event is usually discussed as being core damage 19 accidents in our space since we're trying to make this 20 technology-inclusive. We just kind of use the 21 unplanned movement of radioactive materials from one 22 place, where they're supposed to be, to another place 23 where they're not supposed to be.
24 And that way we can address molten salts 25 or whatever technology might be presented to us.
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23 1 So, within those barriers you can see some 2 of the activities that we have already underway. For 3 example, we're looking at emergency planning and 4 whether emergency planning zones might be revised as 5 a result of the technology.
6 That's usually the last line of defense to 7 protect public health and safety. So that's that last 8 box there in the figure.
9 We are looking at citing. Whether the 10 same citing guidance and regulations, established for 11 large light water reactors dating back from the, 12 largely from the '50s and '60s, would still be 13 necessary or appropriate for advance reactor designs.
14 I mentioned the functional containment in 15 that box on that safety arm.
16 In the socioeconomic arm we're looking at 17 Price-Anderson and we owe a report to Congress in 2021 18 that will say, is Price-Anderson good enough as it 19 stands, is it too restrictive, is it not restrictive 20 enough. Whatever the conclusion would be by that time 21 frame.
22 We have to look at environment, and that 23 is another activity we have underway to say, is the 24 way we approach environmental reviews for large light 25 water reactors, can it be right sized or revised to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 address the smaller non-light water reactor designs.
2 So the box in the yellow there is, what is 3 the LMP or what is in NEI 18-04 and the draft guide.
4 It covers how we're going to identify and address 5 both, from the plant standpoint, the prevention and 6 mitigation of the identified events. Both internal 7 and external.
8 MEMBER CORRADINI: So, I have a question 9 about the one thing you didn't talk about, SECY 10 0076.
11 MR. RECKLEY: Okay.
12 MEMBER CORRADINI: So, how does one map 13 that onto a frequency consequence analysis to make 14 sure that you're not bound, well, to at least 15 understand where it sits relative to consequences 16 versus consequences from --
17 MR. RECKLEY: The way --
18 MEMBER CORRADINI: -- other initiating 19 events?
20 MR. RECKLEY: Right. It may not get 21 plotted on a frequency consequence because the 22 frequency part is sometimes hard to get people to 23 estimate for security events.
24 But what we're talking about under SECY-25 18-0076 is more of a consequence-based approach. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 the arrow there is pointing to that part of the 2 security program that goes to intervening if there is 3 an assault on the facility.
4 So, current requirements are that 5 operating plants have ten, minimum of ten armed 6 responders standing by waiting to respond to an 7 assault.
8 MEMBER CORRADINI: So, it's taking the 9 current approach and applying it to --
10 MR. RECKLEY: Right. The notion is, 11 looking at that particular thing, the number of armed 12 responders.
13 If one can address through the consequence 14 assessment that even if the armed responders, even if 15 the armed assault was successful, in terms of what 16 they were able to damage under the design basis 17 threat, that the consequences, in terms of public 18 health and safety are below a threshold, then you can 19 say, you can potentially relax that requirement for 20 ten armed responders.
21 And in terms of the operating reactors, 22 ten armed responders is $5 million a year. So that is 23 the reason that the industry picked that particular 24 activity out.
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26 1 areas for advance reactors, it may be possible that 2 additional security requirements get looked at.
3 MEMBER CORRADINI: Okay.
4 MR. RECKLEY: But for right now, we've 5 narrowed it down to just a couple things that we're 6 going to look at to say, could relief be justified 7 through a consequence assessment.
8 MEMBER CORRADINI: I got it. Thank you 9 very much.
10 MR. RECKLEY: Okay. So this is the second 11 nightmare figure. As John mentioned, one of the 12 things that we're trying to do is to kind of go back 13 to basics because we're starting from a technology-14 inclusive. All sizes, all reactor types.
15 So, how can we kind of develop an approach 16 that is so generic that it can address that wide 17 range. So, part of the reason, or part of the way 18 we'll do that, and this goes to, I think the ACRS 19 comments when we were talking to you about emergency 20 planning, is to focus on the source terms.
21 So, at the top of this figure is a generic 22 mechanistic source term representation. Inventory 23 times a series of release fractions. And then you 24 enter that into a computer code, like MACCS, for how 25 it gets distributed once it goes off site. And you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 can do a consequence assessment.
2 And so, by and large, what we're looking 3 at for each technology, and each design ultimately is, 4 how are you controlling the release fractions across 5 the series of barriers. And from a design standpoint 6 you have flexibility.
7 For gas cooled reactors, the thrust of the 8 argument to date has been, we want to control the 9 first one, and maybe the first two. We want to try to 10 keep the radionuclides within the TRISO particle. If 11 it manages to get out of the TRISO particle we want to 12 try to keep it in the matrix, to some degree, for 13 other particular transients.
14 You also go as far as the reactor, the 15 primary system, the helium circuit and a reactor 16 building. But by and large, the thrust has been 17 trying to keep it within the TRISO particle.
18 Another molten salt reactor design may 19 have a different strategy altogether. And they may 20 emphasize trying to keep certain radionuclide groups 21 within the salt, but for other radionuclides a 22 physical barrier. The last leap path factor.
23 So they might put the emphasis on salts, 24 chemistry and then physical structures, like a 25 building. Something closer to maybe a containment.
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28 1 Although the lower energy may not be a challenge in 2 terms of needing to survive 60 pounds per square inch, 3 or something like that.
4 So, each design, each technology will look 5 and they'll come up with a strategy for, in the end, 6 trying to keep the radioactive material from escaping 7 from the facility. So --
8 MEMBER CORRADINI: So, can I take, I like 9 the diagram. Has Staff thought it through for these 10 generic concepts and kind of estimated the hours for 11 the decontamination as I move from left to right and 12 the methods used for heat removal from going from left 13 to right?
14 In other words, I'm sure that the 15 particular industry or vendor will come up with 16 calculations, et cetera, et cetera, but it seems to me 17 one can rough out how this might look for the various 18 three types.
19 MR. RECKLEY: We have. And I'm hoping 20 that we'll have a report within a few months. We 21 asked Sandia to look, and to use this model, and to go 22 back historically. So they're not doing analysis --
23 MEMBER CORRADINI: Sure.
24 MR. RECKLEY: -- they're doing historical 25 looks at PRAs and consequence assessments from each NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 technology.
2 MEMBER BLEY: And experiments?
3 MR. RECKLEY: Wherever they can get data.
4 MEMBER BLEY: Wherever they can get 5 information.
6 MR. RECKLEY: Wherever they can get data.
7 And where they don't have data they're going to use 8 their best guess.
9 Just to give us this idea, and in part, 10 the reason we ask them to do that is, as we look for 11 the technologies as to where we should be putting our 12 planning and resources, it should match up to where 13 they, that technology is going to be trying to credit 14 which release fraction they're going to put the 15 emphasis on.
16 MEMBER BLEY: Okay.
17 MR. RECKLEY: And so, to date, nothing 18 really all that surprising has come out of it. But 19 we'll have a little better tool and we'll have the 20 calculations. And as soon as they report is issued, 21 we'll make it available to you.
22 MEMBER BLEY: We look forward to that.
23 Are they looking at different reactor types as well?
24 MR. RECKLEY: Because of the constraints 25 --
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30 1 MEMBER BLEY: Yes.
2 MR. RECKLEY: -- in terms of how much 3 money we gave them, they picked three designs, one for 4 each technology group. Then they picked several event 5 sequences.
6 Because each, the release fractions is a 7 function of the transient. Each specific transient.
8 MEMBER BLEY: Of course.
9 (Off microphone comment.)
10 MR. RECKLEY: What?
11 MEMBER KIRCHNER: And the design. They're 12 separating fuel and fission products. You're in a 13 different place on this diagram to start the incident.
14 MR. RECKLEY: Right. So they're looking, 15 again, they've picked a couple models.
16 MEMBER KIRCHNER: Yes.
17 MR. RECKLEY: Specific transients, 18 specific reactor designs. And then they're going to 19 scale things like power level and so forth.
20 So, as soon as that report is available, 21 we'll make it available to you.
22 MEMBER BLEY: Because, as part of their 23 assignment, given the three generic reactor types 24 they're looking at, is part of their assignment to 25 identify the areas or additional research or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 experimentation would be useful for each type?
2 MR. RECKLEY: In part, that is what will 3 come out. That wasn't the primary mission but when we 4 get the report and they say, we had to make major 5 assumptions here, here and here, but over here the 6 data was pretty good, we'll be able to get that out of 7 the report.
8 MEMBER BLEY: Okay.
9 MR. RECKLEY: So, what can affect the 10 release fractions? I mean, this is what the designers 11 are going to have to identify.
12 So, things like in the first case, how 13 does the radionuclides go from the fuel to the matrix, 14 that's going to be functions of a radiation or burn 15 off, it's going to be functions of temperature.
16 Temperature is expected to remain a major 17 driver for the release fractions for all the 18 technologies. And so, the bottom part of the figure 19 is just a simple representation of the other two 20 fundamental safety functions of heat generation and 21 heat removal and how that might look and how that 22 might get assessed.
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32 1 through a series of passive mechanisms.
2 So, the reason to put this up here is, 3 again, sort of like the bowtie. That we're trying to 4 look at this from the simple, and then it gets more 5 complex.
6 One of the things that the Sandia report 7 does, for example, is they have a matrix. So it 8 starts off really simple but then you say, what is the 9 variables that go into making that release fraction, 10 how you can estimate it. And it just multiples very 11 quickly until it becomes a huge matrix.
12 And so, as we go into the next discussion 13 on the events and so forth, we're just, from the 14 Staff's point of view, tying all of this, trying to 15 tie it together. The mechanistic source term, the 16 event selection.
17 And then ultimately, even classification, 18 SSCs, they come back. Where are you putting your 19 emphasis. And so that will come back into the, which 20 ones are safety related, which ones may be warranting 21 special treatment and which ones might be backup that 22 you're satisfied with the commercial, commercial grade 23 equipment.
24 MEMBER CORRADINI: Just one thing, just to 25 understand, Bill. The analysis that Sandia is doing, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 that is all for non-light water --
2 MR. RECKLEY: Yes.
3 MEMBER CORRADINI: -- options?
4 MR. RECKLEY: Yes.
5 MEMBER CORRADINI: Okay, thank you.
6 MR. RECKLEY: So, all of that is kind of 7 background. Getting into the specifics of what is in 8 the guidance document, what's in, at a higher level, 9 what's in the commission paper.
10 Again, the elements that we're looking at 11 is, how do you use the behavior of the non-light water 12 reactors, considering all of those things I just 13 talked about, and come in and do things like, identify 14 and assess licensing basis events using both 15 probabilistic approaches, risk-informed approaches and 16 using deterministic approaches and engineering 17 judgment.
18 How do you classify the equipment, how do 19 you define performance requirements?
20 One question that often comes up is, for 21 non-light water reactors, the operating history is not 22 as populated as light water reactors, how do you make 23 up for those uncertainties in having less operational 24 data?
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34 1 do the PRA and make your best assumptions on 2 frequencies of the availability or the failure of 3 equipment, along with that, you're going to define the 4 performance requirements in order to make sure that 5 down the road the assumptions you made are reasonable.
6 And that the events that you analyzed and the 7 acceptance criteria that you used are still valid.
8 And then lastly, the defense-in-depth 9 assessment that's including in the methodology, to 10 make sure that, again, largely to make sure that 11 uncertainties are addressed, that you don't overly 12 rely on one element, one barrier, and to bring in that 13 engineering judgment through the integrated decision-14 making process to make sure that you're making 15 conscious choices on how to address the safety for 16 that particular design.
17 MEMBER REMPE: Bill? If I were thinking 18 back on what I thought was important in 18-04, I would 19 have identified those three bullets, but I also would 20 have identified identifying key safety functions for 21 that particular design.
22 MR. RECKLEY: Right.
23 MEMBER REMPE: Did you think about 24 highlighting that as a bullet, and why did you not?
25 MR. RECKLEY: I guess the sub-bullet under NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 SSC classification function and risk considerations, 2 that was my attempt. But I agree with you that the 3 way the methodology lays out that in order to identify 4 the equipment, you first identify the functions.
5 MEMBER REMPE: Key safety functions.
6 MR. RECKLEY: And then from the functions 7 comes the performance requirements for individual 8 SSCs.
9 MEMBER REMPE: And for defense-in-depth, 10 I think you need to know that too.
11 MR. RECKLEY: Right.
12 MEMBER REMPE: And I just was thinking 13 about it, if I were doing it.
14 MR. RECKLEY: And I don't disagree with 15 you.
16 MEMBER REMPE: Okay.
17 MR. RECKLEY: One item that we like to 18 address, and this was highlighted in, not the October 19 meeting, but the subcommittee meeting we had before 20 then. Although the topics that are addressed in NEI 21 18-04 and the draft guide are important, they're not 22 100 percent of the requirements that will be imposed 23 on these reactors.
24 And so, it is necessary to keep in mind, 25 the regulatory context is broad. This is a very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 important part but it's not 100 percent.
2 And so I broke it down at the subcommittee 3 meeting into those requirements that are associated 4 with LMP. And for example, the maintenance rule and 5 quality assurance programs, they're built in to how 6 programmatic controls are used within the LMP process 7 to provide the reliability and ensure equipment has 8 the capabilities to do the functions of, that they're 9 assigned to do.
10 The LMP then also interfaces with other 11 requirements. And this was back on the bowtie 12 diagram. The LMP itself doesn't get into citing, 13 doesn't get into emergency planning or environment 14 reviews.
15 But as shown on the diagram, you're doing 16 events assessments ultimately to determine things like 17 emergency planning and whether they can be relaxed.
18 And so, it's a natural outgrowth of the guidance in 19 NEI 18-04 and the draft guide that, as you're 20 analyzing events, you're going to use those 21 consequence assessments as part of the rational for 22 whether you can reduce emergency planning zones.
23 MEMBER CORRADINI: So, maybe you, I think 24 I can guess the answer but, so if I, you said they're 25 disconnected, but in some sense the source term used NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 to construct the FC curve so that you can do an 2 analysis, has got to decide where you stop on 3 frequency, below what you don't consider on frequency, 4 to understand the consequences that you apply to 5 emergency planning --
6 MR. RECKLEY: Right.
7 MEMBER CORRADINI: -- at the site?
8 MR. RECKLEY: Yes. And that's why said --
9 MEMBER CORRADINI: Is there guidance in 10 the considered version of 1353 that verbalizes that or 11 is it just implied?
12 In other words, how do I know when I stop 13 the AP and citing?
14 MR. RECKLEY: Yes, we'll get into that.
15 MEMBER CORRADINI: Okay, fine. Sorry.
16 MR. RECKLEY: No, that's fine. But, 17 that's why it's called an interface. It's really a 18 hand off. It is part of the same decision-making 19 process --
20 MEMBER CORRADINI: Okay.
21 MR. RECKLEY: -- it's just that you don't 22 see in NEI 18-04, here's the additional work that you 23 need to do in order to do the emergency planning. But 24 1353 references 1350 and 1350, the reg guide for the 25 EPC, references back to 1353. So, it's recognized NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 that the two things work together.
2 MEMBER CORRADINI: Okay. I'm smiling 3 because I just don't want to create an infinite loop 4 that doesn't --
5 (Laughter.)
6 MEMBER CORRADINI: The way you said it, it 7 sounds like I'm --
8 MR. RECKLEY: Hopefully not.
9 MEMBER CORRADINI: Okay.
10 MR. SEGALA: There are some things that 11 would need to be considered, in LMP it's like a 30 day 12 dose and EP they're looking at a 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> dose.
13 MEMBER CORRADINI: Right.
14 MR. SEGALA: So, if you're less than one 15 rem for 30 days, they're going to be less than one rem 16 for the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
17 MR. RECKLEY: And then lastly on the 18 slide, there are requirements, such as routine 19 effluents, worker protections and elements of security 20 that aren't addressed within LMP.
21 So, getting to the event selection and 22 much of the focus of the discussions often comes down 23 to looking at the frequency target. Frequency 24 consequence target figure.
25 So, at the highest level for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 commission paper, we're basically just saying what the 2 categories are and how we're using the figure and the 3 emphasis, as its stated at the top, that the targets 4 are not intended to be interpreted as being actual 5 acceptance criteria.
6 One of the things I did to this figure was 7 went ahead and added the two orders of magnitude zone 8 that's used in the defense-in-depth assessment as risk 9 significant licensing basis events.
10 Just to be clear that you're not looking 11 at the solid bright blue line but you're looking at, 12 where does the event map onto the frequency 13 consequence, what's keeping it from going up or down 14 and the general message of, the closer you are to the 15 line the more attention you should pay as to what's 16 limiting the consequences.
17 So, I think that was basically all for the 18 SECY paper, was the level of detail we were providing 19 to the commission. The note off to the side, there 20 is, and maintains, a deterministic approach. The 21 traditional Chapter 15 approach.
22 That is the design basis accident category 23 that are events that are taken from the mid-range, the 24 design basis event category, and then analyzed with 25 more traditional approaches of using only safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 related equipment in the assumptions.
2 And then what's not shown on the figure, 3 but one also needs to keep in mind, is in addition to 4 the plotting of the event sequences and looking at 5 each sequence in terms of what is keeping it at an 6 appropriate place on the frequency consequence.
7 Target, in terms of the availability and 8 reliability of equipment and the capability of that 9 equipment to prevent a release.
10 You're also looking holistically at the 11 design and comparing it to aggregate goals, like the 12 commission's safety goals.
13 MEMBER MARCH-LEUBA: Okay, before you 14 move. All of these results are based on you knowing 15 the frequency. The y-axis in this figure.
16 So what degree of certainty do you require 17 from an applicant, to believe the frequencies he tells 18 you?
19 MR. RECKLEY: Well, yes. One of the 20 things that the methodology includes is you're not 21 only plotting the mean frequency as your best guess of 22 what the frequency is, but you're plotting the 23 uncertainty bands.
24 And so, as you look at the uncertainties, 25 it might be very possible that those uncertainty bands NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 will be much wider than people are accustom to seeing 2 on, maybe for light water PRAs.
3 MEMBER MARCH-LEUBA: But those are --
4 MR. RECKLEY: But --
5 MEMBER MARCH-LEUBA: Those are the 6 estimates from the applicant, which has a bias 7 towards, per this position, where he decides his PRA.
8 Where I would like to see some emphasis is 9 on requiring from the Staff, when they review those 10 PRA, that there be an aggressive, thorough and 11 complete review. Not just, let's review what the 12 applicant said and check their math.
13 If you're going to build a reactor like 14 this, Five Mile is upwind from my house, I want you to 15 raise your right hand and tell me, I know these 16 frequencies, I dually agree with them, not just a 17 cursory review of the math of the applicant. Because 18 the applicant has a bias when they develop their PRA.
19 And we have some examples when some people 20 go and tells us the probability of failure of this 21 system is ten to the minus 11. That does nothing.
22 MR. RECKLEY: I guess all I can say is I 23 think the staff always does that.
24 MEMBER MARCH-LEUBA: Well, they're not 25 doing it in this case.
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42 1 MR. RECKLEY: Okay. That you might want 2 to take up --
3 MEMBER MARCH-LEUBA: I would like to see, 4 on the guidance and on the --
5 MR. RECKLEY: Right.
6 MEMBER MARCH-LEUBA: -- procedures, some 7 emphasis that the Staff will do an aggressive review 8 of what's missing on the PRA and what's bias.
9 MR. RECKLEY: Okay. Again, I won't attest 10 to any particular ongoing or past review, but I would 11 say that's the goal of the NRC Staff for any review.
12 And certainly we'll be coming before the 13 ACRS and you can challenge not only the applicant but 14 the Staff on the thoroughness.
15 MEMBER MARCH-LEUBA: I've done a lot of 16 reviews for the Staff and we tend to check the math of 17 the applicant more than looking --
18 MR. RECKLEY: Okay.
19 MEMBER MARCH-LEUBA: When the consequences 20 of you being wrong are so large, I mean, when we're 21 talking about, are you violating CHF or not in a small 22 reactor that has no consequence for safety, I mean, 23 you can be a little more forgiving. But when the 24 consequence of you being wrong are so large --
25 MR. RECKLEY: No. And that, to me, that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 1 one of the nice features of the frequency consequence 2 target figure is, you're not only looking at the 3 uncertainties associated with the frequencies, which 4 move you up and down, but your uncertainties in terms 5 of the consequences.
6 And there may be events in which the 7 uncertainties and frequencies are very large, but the 8 consequence uncertainties remain very close to the 9 area where you would have no concern.
10 The closer you are in either, to the 11 target area, the risk significant LBE region, the more 12 attention you're going to pay to the uncertainties 13 associated with, not only the consequences, but also 14 the availability of the equipment.
15 MEMBER MARCH-LEUBA: Yes, I just wanted to 16 put you on the record.
17 MR. RECKLEY: Yes. Nope.
18 MEMBER MARCH-LEUBA: There's an issue of 19 availability of resources at the time to review. We 20 have to do it in 18 months or we have to do it in 12 21 months now. We don't have time to do a thorough 22 check. And that should be emphasized.
23 MR. RECKLEY: Okay.
24 MEMBER MARCH-LEUBA: That everything is 25 based on, we know the y-axis.
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44 1 MR. RECKLEY: Okay.
2 MEMBER REMPE: So, with this figure, if 3 you have a micro-reactor that doesn't have a PRA, do 4 you just assume that the accident happens or do they 5 have some sort of hazard assessment where they had 6 higher frequency hazards and lower frequency hazards?
7 I mean, how far did this tabletop go? I 8 mean, they don't have a detail PRA, they don't have 9 data for qualifying a lot of their new designs.
10 MR. RECKLEY: Well, again, to me that just 11 is reflected in the uncertainty events. When you say 12 they don't have a PRA you --
13 MEMBER REMPE: Do they have some sort of 14 hazard assessments, so there was some sort of --
15 MR. RECKLEY: Yes.
16 MEMBER REMPE: -- simplified PRA?
17 MR. RECKLEY: Right.
18 MEMBER REMPE: So no one came in without 19 a PRA is what you're telling me in the tabletops?
20 MR. RECKLEY: Right.
21 MEMBER REMPE: Okay. I don't know whether 22 these designs are.
23 MR. RECKLEY: Right.
24 MEMBER REMPE: So they do need to have a 25 PRA of some sort --
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45 1 MR. RECKLEY: Right. And NEI 18-04 2 discusses that since this is related to the design 3 process, and ultimately to the licensing process, it's 4 an iterative process.
5 And so you start off with maybe more 6 traditional hazards. Maybe failure modes and effects 7 analysis or process hazards with less focus on the 8 frequencies but just identifying what can go wrong.
9 Then as you progress through the design 10 process you start to ask the question, not only what 11 can go wrong but how likely is it, such that you can 12 put it on the frequency consequence curve.
13 But, by the time the design is submitted 14 for a licensing application, the expectation is that 15 they will have, not only what can go wrong but how 16 likely it is.
17 I'll say, one potential caveat is, if 18 there is a reactor design, and I'll stress the if, 19 that you could model maybe as, on the non-reactor side 20 there's processes to assess unmitigated releases, 21 right? Just, you've got a source term, just let it 22 go, what happens?
23 Well, if it ever was that the design, the 24 inventory was small enough or the design so straight 25 forward that you could kind of do an unmitigated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 release and show that it was a minimal consequence, 2 then maybe you wouldn't bother with doing this more --
3 MEMBER REMPE: In our discussions over the 4 last, I don't know how many months, you mentioned that 5 earlier and I wasn't sure where these tabletops were 6 going, and I wondered if they did come in with --
7 MR. RECKLEY: We haven't seen one go that 8 route yet.
9 MEMBER REMPE: Okay.
10 MR. SEGALA: Yes, all of them so far have 11 used a PRA.
12 MEMBER MARCH-LEUBA: Let me reemphasize my 13 point. Can you go back a couple slides before on the 14 specification of SSCs. I think it's like --
15 MR. RECKLEY: The next slide.
16 MEMBER MARCH-LEUBA: -- 6 or 5. Go 17 backward. There. Okay.
18 Those SSCs classified as a non-safety 19 related with a special treatment. The example we saw 20 during the Subcommittee was, the way I read it, and 21 I'm oversimplifying, is an SSC that the PRA said you 22 didn't have to worry about. And then the committee 23 said, you're crazy, you have to worry about it.
24 Isn't that what that classification is?
25 Non-safety related with a special treatment. Why did NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 1 you add it?
2 MR. RECKLEY: The non-safety related with 3 special treatment is a category of equipment that does 4 have some risk importance. Some safety functions.
5 It's not needed necessarily for the design 6 basis accident, but it's needed to control where you 7 are on the frequency consequence target.
8 MEMBER MARCH-LEUBA: And it's decided by 9 this committee that reviews at the end? The defense-10 in-depth committee I believe it's called.
11 MR. RECKLEY: The integrative decision-12 making panel will play a role in that, yes.
13 MEMBER MARCH-LEUBA: All right. So, isn't 14 that an example where the PRAs have told you, you 15 needed to make it safety related, and you didn't?
16 MEMBER BLEY: No.
17 MR. RECKLEY: No.
18 MEMBER BLEY: No. They set out, you might 19 want to talk about this, specific definitions of what 20 is safety related in the future --
21 MR. RECKLEY: Right.
22 MEMBER BLEY: -- under this program.
23 These would be cases that don't meet those rules but 24 need a risk criteria.
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48 1 can talk about the particular example we talked during 2 the subcommittee, it's an open session. But it 3 involved some sodium water reactor.
4 And in my opinion, it nearly pointed to 5 the fact that the PRA was deficient, and they decided 6 to go this route instead of --
7 MR. RECKLEY: Okay.
8 MEMBER MARCH-LEUBA: But that's my 9 opinion.
10 MR. RECKLEY: All right. So, as Dennis 11 said, the second element within the methodology is 12 really the establishment of safety classes and 13 performance criteria for the equipment.
14 For safety related equipment it's defined 15 there in the bullet. For non-safety related, as we 16 were just mentioning, it is those SSCs that are 17 playing a role. And then non-safety related with no 18 special treatment are all other SSCs.
19 I would go as far as to say you got to be 20 careful because even equipment that's not safety 21 related with no special treatment does not mean that 22 it serves no purposes in controlling, in contributing 23 to either a risk or lack thereof within a facility, 24 it's just an SSC that you don't need to put particular 25 performance measures or address through other than NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 commercial procurement.
2 CHAIRMAN RICCARDELLA: Bill, go on back to 3 that frequency consequence curve. Could you briefly 4 describe the rationale for why there is that step 5 change at one rem?
6 MR. RECKLEY: Theres a number of ways to 7 construct a frequency consequence target. And the 8 closer you try to get to marrying it to a regulatory 9 limit, the actual more steps you have. If you go 10 back, for example, and look at NUREG-1860, it had like 11 ten steps, because as you go through the various 12 regulations.
13 So, the reason for the step in this 14 particular figure that we accepted from the industry 15 is, the top line for the higher frequency events, 16 youre really trying to derive the dose considerations 17 from Part 20, something close to normal effluence.
18 The bottom point, in terms of the dose and 19 frequency, is largely derived from the safety goal, at 20 the lower end. And the LMP decided to connect a value 21 at E-2 and one rem, based on traditional event 22 assessment criteria, with the safety goal kind of 23 number down at E-7.
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50 1 could have drawn a straight line.
2 In general, theres a preference in risk 3 evaluations to have a slope greater than one, kind of 4 to make it a little more risk-adverse, so that youre 5 addressing the bottom end a little more conservatively 6 than you would, thats largely because of 7 uncertainties and so forth.
8 So, all of that is in there.
9 MEMBER CORRADINI: But, I mean, I think 10 Petes asking the question is, or my way of thinking 11 about it is, once you get close to this knuckle, you 12 start looking closely. Whether I look -- right?
13 MR. RECKLEY: Yes.
14 MEMBER CORRADINI: Thats how I view it --
15 MR. RECKLEY: Right.
16 MEMBER CORRADINI: -- is that, when I get 17 to this little stair-step, if Im starting to get near 18 it, I have to ask, in terms of uncertainty and 19 frequency and uncertainty and consequence --
20 MR. RECKLEY: Right.
21 MEMBER CORRADINI: -- to make sure Im 22 below your buffer, whatever, your dark yellow versus 23 your light yellow or whatever it is.
24 MR. RECKLEY: Right.
25 MEMBER CORRADINI: Okay.
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51 1 MEMBER MARCH-LEUBA: Short question on this 2 topic. In previous presentations, youve been very 3 careful to tell us that NRC was not sponsoring these 4 numbers, not even accepting them. Are we now to a 5 point in which NRC approves them or accepts them? Or 6 where are we?
7 MR. RECKLEY: Were going to accept, or 8 propose to accept, that this frequency consequence 9 target for the identification of events, for defense-10 in-depth assessments, and everything thats within the 11 methodology that we talk about.
12 The caution has always been, we just dont 13 want the line to be interpreted as acceptance 14 criteria. That will remain, to include the possible 15 use of engineering judgment --
16 MEMBER KIRCHNER: Well, 10 CFR 50.34 is 17 very explicit that this is not a goal, 25 rem.
18 MR. RECKLEY: Right.
19 MEMBER KIRCHNER: Its expected that the 20 applicant will demonstrate well margin below that.
21 MR. RECKLEY: And even the 25 rem number, 22 weve historically had troubling saying what frequency 23 is it associated with? And so, thats why, although 24 this is plotted at 25 and E-4, were saying, dont 25 interpret our regulations to be E-14 and 25 rem.
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52 1 MEMBER BLEY: To Joses point, I think back 2 in October, when you were with us, you had told us 3 that you guys were still considering whether this is 4 the right target or you ought to have something 5 different.
6 MR. RECKLEY: Well, definitely during the 7 briefings on the functional containment paper, we 8 said, dont focus on the numbers, were --
9 MEMBER BLEY: Oh, yes.
10 MR. RECKLEY: -- just trying to get the 11 concept. But at the Subcommittee meeting, what we 12 intended to say was, this is the figure --
13 MEMBER BLEY: Okay.
14 MR. RECKLEY: -- that were saying is 15 acceptable for use, within the limitations we talk 16 about.
17 MEMBER BLEY: I have my meetings mixed up, 18 perhaps.
19 MEMBER MARCH-LEUBA: Then, would it be 20 appropriate to -- are you expecting an evaluation of 21 that from ACRS in our letter, I mean, in our 22 recommendation, of that line? The wisdom of using 23 such a line?
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53 1 categorized, and analyzed, and the way SSCs will be 2 classified and performance measures established, and 3 the way defense-in-depth assessments will be done, 4 will use this figure.
5 MEMBER MARCH-LEUBA: Okay.
6 MR. RECKLEY: And so, yes.
7 MEMBER MARCH-LEUBA: So, the answer is yes?
8 You --
9 MR. RECKLEY: Yes.
10 MEMBER MARCH-LEUBA: -- would expect us to, 11 at least in the discussion, mention it?
12 MR. RECKLEY: Right. And Ill get into 13 that in a second, when we get into the paper.
14 MEMBER KIRCHNER: Bill, may I just throw 15 out a caution? This figure is really derivative from 16 the LWR experience. And implied in this is an 17 unfolding of an accident scenario and time. And 18 without making a pejorative statement, let me see how 19 I can explain my point.
20 There can be events in other non-LWR 21 designs that could lead to large, instantaneous large 22 inventory release, which is different than how we 23 anticipate, shall I say, an LWR event proceeding.
24 And where Im going with this is, for 25 example, time becomes of essence, because the PAG of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 one rem could be exceeded before you could even sound 2 a general alert or respond, depending on where the 3 location is of the EAB and the local workforce and 4 population.
5 So, I just throw that at that, as I think 6 about this, the implicit here is, we have an unfolding 7 over time, which allows ample time to make decisions 8 about protective action, et cetera, that may not be 9 the case for alternate designs, that might have --
10 MEMBER BLEY: Lets have a little --
11 MEMBER KIRCHNER: -- a large inventory.
12 MEMBER BLEY: -- among the many discussions 13 on this one. I dont quite see that, Walt.
14 MEMBER KIRCHNER: Okay.
15 MEMBER BLEY: Because the one youre 16 suggesting, although it happens fast, theres no time 17 on here, but it would fall outside of this curve on 18 consequences. At least, thats what I think youre 19 getting at.
20 So, when its all done, you plot the point 21 on here where you end up and if its outside of that 22 line, its unacceptable, whether it happens very 23 quickly --
24 MEMBER KIRCHNER: No.
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55 1 --
2 MEMBER KIRCHNER: No, I agree with you.
3 MEMBER BLEY: -- includes modeling carrying 4 out protective actions as well.
5 MEMBER KIRCHNER: Okay.
6 MEMBER BLEY: So, you just couldnt do it 7 --
8 MEMBER KIRCHNER: Or the EAB may be --
9 MEMBER BLEY: -- in that case, yes.
10 MEMBER KIRCHNER: -- a significant 11 distance.
12 MEMBER CORRADINI: Right.
13 MEMBER BLEY: Yes.
14 MEMBER CORRADINI: You would have to change 15 the distance --
16 MEMBER KIRCHNER: Youd go back to the --
17 MEMBER CORRADINI: -- you evaluate.
18 MEMBER KIRCHNER: -- design and change the 19 EAB. Anyway, thats -- thank you.
20 MR. RECKLEY: The -- yes, I would go as far 21 as to say, I agree with you that time is a key 22 variable and its a key variable in a number of ways.
23 In some reactor designs, you might have a puff and 24 youd have to control that --
25 MEMBER KIRCHNER: Right.
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56 1 MR. RECKLEY: -- and that will be a quicker 2 release than maybe large light-water reactors.
3 The other way it comes into play in this 4 mechanistic source term assessment is, there may be 5 designs in which particular radionuclide groups 6 migrate through, and that time needs to be assessed, 7 such that, by the time that you get to the leak path 8 factor for the building, it might be the release, and 9 some of the stuff that were seeing is, sometimes the 10 releases from non-light-water reactors can be many 11 days. So, the releases can be longer.
12 MEMBER KIRCHNER: Yes.
13 MR. RECKLEY: So, both of those will have 14 to get looked at and assessed within, as Dennis 15 mentioned, a 30-day dose on the figure.
16 So, lastly, within the methodology, or 17 next to last, I guess, is the assessment within the 18 process for defense-in-depth, which looks at, again, 19 the risk-informed assessment techniques, PRAs, and 20 before PRAs in the design process. Again, maybe 21 youre using failure modes and effects, a process 22 hazard kind of assessment tools.
23 But ultimately, by the time its licensed, 24 you would be looking also at the question of how 25 likely are failures and what reliability requirements NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 would be needed for SSCs, down under the programmatic 2 controls? So, all of those things to support the PRA.
3 Youre also looking at deterministic 4 criteria, through both the Chapter 15 analysis and 5 also, the defense-in-depth assessment being done 6 through the Integrated Decision-Making Panel is 7 looking at deterministic or engineering judgment kind 8 of criteria.
9 So, again, for the purpose of the SECY 10 paper, the notion that the defense-in-depth 11 assessments are being done is about the level that 12 were talking about and that it includes both plant-13 level hardware-oriented measures, as well as 14 programmatic measures.
15 MEMBER BLEY: Bill, a couple things about 16 this. One, its in the flavor of the Integrated 17 Decision-Making Process thats in 1174.
18 MR. RECKLEY: Yes.
19 MEMBER BLEY: But now, weve tagged a panel 20 with carrying that out, which you always needed in 21 some form.
22 The only way well really see if that 23 panel is doing a good job is careful dissection of the 24 tabletop exercise reports, I think. And I wonder how 25 much you guys have thought about that.
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58 1 The other is, the panel is described under 2 the defense-in-depth section, but it seems they have 3 a role in the SSCs and in the selection of licensing 4 basis events, which is kind of saying did the PRA 5 leave anything out that we ought to be looking for?
6 MR. RECKLEY: Yes, I --
7 MEMBER BLEY: Will you talk about that 8 ensemble of things Ive put together?
9 MR. RECKLEY: Yes. I think what you just 10 said is true, its an Integrated Decision-Making Panel 11 and the integrated includes how all of those pieces 12 fit together.
13 And so, thinking of it from a design 14 perspective, the designer, and in this particular 15 case, the process or the panel, has all those things 16 in play, because theyre trying to make design 17 decisions.
18 What equipment do I want to make safety-19 related? What equipment might warrant being 20 additional special treatment requirements?
21 Going back, that panel will contribute to 22 -- maybe going back and saying, maybe we should make 23 a design change to actually affect the event 24 selection. So, yes, it only works if all of those 25 things are in play.
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59 1 MEMBER BLEY: Now, somewhere in the things 2 Ive read for this meeting, you talk about how, or 3 someone talks about how the panel is originally set up 4 by the designer and eventually, this role moves over 5 to the licensee, as the design comes to completion and 6 the machine moves over to an owner.
7 Can you say anything about the 8 requirements of what kinds of people need to be on 9 this panel? Including if you need a facilitator of 10 some sort who really understand the whole process?
11 MR. RECKLEY: Yes. The panel, as its 12 discussed within the guidance, points over to the 13 50.69-related guidance, in terms of how to set up a 14 multi-disciplinary or Integrated Decision-Making 15 Panel.
16 Those models are basically the same, 17 whether we look at what we did for the Maintenance 18 Rule or what the industry did for the Maintenance 19 Rule, what its done for 50.69, what its done for 20 risk-informed tech spec initiatives.
21 The notion of an Integrated Decision-22 Making Panel or multi-disciplinary panel is basically 23 the same, or at least very similar, between all of 24 those and its going to require people from the risk 25 arena, the PRA arena, operations, design, some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 mechanical, civil, structural, depending on the 2 elements.
3 So, Im not personally an expert in that, 4 other than to just say, its really borrowing from the 5 use of that particular tool, multi-disciplinary or 6 Integrated Decision-Making Panels, from all of that 7 experience. Again, the tech specs, the Maintenance 8 Rule, and more lately, the 50.69.
9 On the next slide, I do address --
10 MEMBER CORRADINI: But just to make sure I 11 understand your answer to Dennis, youre looking at 12 this decision-making panel, is not the final judgment, 13 but Ill call it the final decision-making 14 recommendation to this is safety-related or not 15 safety-related? This is an appropriate defense-in-16 depth or not? This is essentially the LBEs that ought 17 to be the DBAs? Is that my understanding?
18 MR. RECKLEY: Well, I can say, from the 19 staffs point of view, we have the luxury of only 20 looking at the outcomes of all those decisions that 21 have been made.
22 MEMBER CORRADINI: But if we went to the 23 example, tabletops, thats what you would be expecting 24 this to be the answer, is that decision-making panel 25 examined each of these features and said, yes, well, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 1 we understand the PRA, but we were concerned, 2 therefore, just to be sure, this will become safety-3 related, or this will be an additional defense-in-4 depth necessary?
5 MR. RECKLEY: Right. And the rationale 6 that they laid out for why that was added and why it 7 was enough. Again, from our standpoint, were 8 focusing on what the outcome of that process is, more 9 so than actually the mechanics --
10 MEMBER CORRADINI: Understood.
11 MR. RECKLEY: -- of it. Which goes to the 12 first bullet here, and again, I think --
13 MEMBER RAY: Bill, can I interrupt you for 14 a second?
15 MR. RECKLEY: Sure.
16 MEMBER RAY: Dennis, you referred to the 17 licensee. And of course, now, our thinking is in 18 terms of certification applicant, for example, which 19 may or may not be what you meant by licensee, because 20 theres another step, its a process that involves 21 both a licensee of a plant that they own, as well as 22 potentially in this process, a certification applicant 23 that doesnt own a plant, is only producing something 24 that theyre marketing.
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62 1 I read, and I dont remember exactly where it was, but 2 it, at least to me, it implied that this process ought 3 to continue from early in the design into operations 4 of a facility.
5 MEMBER RAY: Well, and I guess --
6 MEMBER BLEY: Which would be a real 7 licensee.
8 MEMBER RAY: I just want to make a note 9 that the step between somebody who may be seeking a 10 certification that they then want to market, to 11 somebody who ultimately, maybe a long time down the 12 road --
13 MEMBER REMPE: So, Harold?
14 MEMBER RAY: -- is a purchaser of that 15 certification, I dont imagine it as a continuity that 16 seems to be implicit in the question.
17 MEMBER REMPE: Harold?
18 MEMBER RAY: Yes?
19 MEMBER REMPE: Id argue that it has to be, 20 because they have to have site characteristics to 21 fully apply this.
22 Once they finally have a licensee that 23 owns it, they will have to go through the process 24 again and assume, in order to get the dose and the 25 consequences, the actual characteristics of the site, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 they may make some tweaks in the design-basis events 2 and the classification of the equipment, right?
3 MEMBER RAY: Well, Im just asking to 4 clarify. Youre talking about, basically, some 5 assumptions that may be made in certification that 6 then have to be --
7 MEMBER REMPE: Right.
8 MEMBER RAY: -- reassessed by a COL 9 applicant --
10 MEMBER REMPE: Right.
11 MEMBER RAY: -- if its a Part 52. And I 12 dont know whether it is or not. But the point is, I 13 was just trying to understand what Dennis was 14 referring to.
15 MR. SEGALA: I think you should keep in 16 mind, too, that -- this is John Segala from the staff 17 -- that for non-light-water reactors, were looking at 18 all possible licensing process.
19 They could come in under Part 50 with a 20 construction permit operating license. They can come 21 in under 52 with a design cert, and then, switch over 22 to a COL. They could come right into a COL, with a 23 full design siting review all at once.
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64 1 this will be an iterative process.
2 MEMBER RAY: I understand that to be the 3 case, what you just said, which is maybe why I asked 4 the question to begin with.
5 I think we need to keep that in mind as 6 were going through and talking about this and asking 7 questions and so on, are the answers different 8 depending on which process somebody comes in with?
9 Joy just explained that, well, presumably, 10 if one does seek a certification, you make assumptions 11 about the site conditions, those then have to be 12 validated by the COL holder and modified as necessary 13 later on.
14 But that process may affect what were 15 talking about here. Its not as easy as just saying, 16 well, if Im just a certification applicant, Ill make 17 some assumptions and then, anybody who purchases that 18 certified design has to validate those assumptions 19 that Ive made or change them, whatever the case may 20 be. Thats enough, then, thank you.
21 MR. RECKLEY: Okay.
22 MR. SEGALA: And we do that under the 23 current reviews, the design certs have a bounds for 24 the site characteristics and then, we have to validate 25 to make sure that theres no exceedances at the site NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 1 when its selected.
2 MEMBER RAY: Thats what were striving to 3 do, Im not sure weve done it yet. But thats part 4 of the dialogue thats going on, is assumptions made 5 in a certification, how do you know what they were and 6 how do you validate them when you go to use the 7 certified design? So, okay.
8 MR. RECKLEY: So, related to the same 9 topic, out of the Subcommittee meeting, Dr. Rempe had 10 asked what our experience was with Integrated 11 Decision-Making Panels or the process.
12 And so, we did go back and look. And I 13 took the question, do we have something that actually 14 watched and then, said, we like the way its working, 15 how the interchange between the experts or the panel 16 members works, is there best practices in maybe how to 17 set that up?
18 And unfortunately, I guess, my reply is, 19 no. To the degree weve watched, weve not 20 documented. Again, all those processes I mentioned 21 that have included these, weve looked at outcomes, 22 but weve not really documented, per se, how the panel 23 worked within that process and maybe what best 24 practices was.
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66 1 talked about, that that will be a key focus area for 2 us as we go forward, and also for the developers, that 3 theyll have to look during the process, because the 4 importance of the Integrated Decision-Making Panel 5 members is to address the uncertainties.
6 And we will be looking and asking the same 7 questions that they should be asking of themselves.
8 But the short answer is, no, we couldnt find a 9 document that actually looked at the performance of a 10 panel.
11 Another question -- I guess I can go back 12 to -- I was hoping we would find something, but we 13 didnt.
14 MEMBER REMPE: Thank you for looking into 15 it.
16 MR. RECKLEY: Okay. The second question, 17 or another question to come out of the Subcommittee 18 was on the reliability of passive heat removal and the 19 need to look, not only at the design, but then, also 20 degradation mechanisms and challenges to those.
21 And we acknowledge that. I passed along 22 some references from Argonne in regards to the reactor 23 cavity cooling system, but thats an example, thats 24 not an exhaustive set of references.
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67 1 this is maybe one level of detail down. As we go back 2 and look at the draft Guide and the NEI document, 3 well revisit whether we need to include some 4 discussion of making sure the degradation mechanisms 5 and so forth.
6 That was the intent, well just go back 7 and make sure it clearly states that that needs to get 8 looked at.
9 MEMBER BLEY: In the Reg Guide or --
10 MR. RECKLEY: Both NEI 18-04 and the draft 11 Guide.
12 MEMBER BLEY: Okay, I think that would be 13 great.
14 MR. RECKLEY: Okay. Then, we talked about 15 tabletop exercises, the ADAMS accession numbers for 16 the two that we have. Then, additional ones are 17 planned or underway, and weve talked about that.
18 And then, John also mentioned the Nuclear 19 Energy Innovation and Modernization Act. Ill just 20 mention that the Act includes a couple of requirements 21 for the NRC.
22 One is, within the current construct, to 23 come up with a technology-inclusive, risk-informed, 24 thats this activity. So, when we report back to 25 Congress and say, what are we doing under the current NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 1 requirements?, thats this.
2 As John mentioned, the Act also says, do 3 the Part 53 or do a rulemaking to develop a framework.
4 Were hopeful that this is also establishing the 5 groundwork for doing that. But were just at the 6 beginning stages of talking about that rulemaking.
7 MEMBER REMPE: Bill, just for the record, 8 the PRISM application does not go into an Integrated 9 Decision-Making Panel for defense-in-depth assessment, 10 is that true?
11 MR. RECKLEY: Theyre on --
12 MEMBER BLEY: I did a quick look and saw 13 that they do talk about the Integrated Decision-Making 14 Panel, but I didnt get a chance to read it --
15 MEMBER REMPE: I dont think --
16 MEMBER BLEY: -- in detail. Maybe --
17 MEMBER REMPE: -- they did. From my quick 18 look, they didnt go into defense-in-depth evaluations 19 yet. So, that part of the process hasnt been 20 evaluated in a tabletop, unless this new one for Oklo 21 did, I dont know. But I just wanted -- can you 22 clarify that part --
23 MR. RECKLEY: Do you recall?
24 MR. SEGALA: Yes, I think they were limited 25 in what they did in that.
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69 1 MEMBER CORRADINI: Yes, I think they -- I 2 seem to remember you asked that question of the PRISM 3 people at the Subcommittee and I thought, at that 4 point, they had not.
5 MEMBER REMPE: Thats what the report also 6 indicated, and I just wanted to make sure. And then, 7 Im just trying to understand how far the process has 8 been explored in tabletops, is why Im asking the 9 question on the record.
10 MR. RECKLEY: Okay.
11 MEMBER BLEY: Bill, just a comment. Im 12 surprised you couldnt find anything. The -- this is 13 really like an expert elicitation process --
14 MR. RECKLEY: Yes.
15 MEMBER BLEY: -- like you do in PIRT, like 16 you do in technical expert elicitations, a whole 17 variety of areas. Theres a vast literature about how 18 that works and how it fails.
19 And a key piece in the places where its 20 worked well is defining the role of the facilitator 21 very well and how to protect against biases. Thats 22 missing in most of our guidance documents for this 23 sort of panel. But its available.
24 MR. RECKLEY: And maybe I just need to be 25 clear, I didnt find it an NRC assessment and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 1 definition.
2 MEMBER BLEY: I agree with you.
3 MR. RECKLEY: Okay.
4 (Laughter.)
5 MR. RECKLEY: There are -- yes, if you 6 Google multi-disciplinary or expert panels --
7 MEMBER BLEY: Youre buried for months.
8 MR. RECKLEY: -- yes, you can find a lot of 9 references on how to do it. But I just didnt find an 10 NRC assessment of one of those.
11 MEMBER REMPE: I didnt have a lot of time 12 to look at the PRISM report, but I liked that, just 13 because Im not so familiar with the design, there 14 were a lot of differences in the selection of the 15 licensing basis events. It provided a more documented 16 approach on why they selected it, so if they changed, 17 I think thats nice.
18 There were a lot of recommendations on how 19 to improve the process on educating the members and 20 things like that. So, I really wanted to emphasize 21 that I think these tabletops are very useful.
22 MR. RECKLEY: And it helped having the 23 PRISM design, which has a well basis, it had people 24 available at GEH that were familiar with the design, 25 familiar with licensing, who became familiar with this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 process. And so, yes, we agree, it was --
2 MEMBER REMPE: And DOE had funded a new 3 PRA, so a lot of other people had gotten involved.
4 So, it was a nice time to do that work.
5 MEMBER BLEY: Just another comment, since 6 were on this train. Often, when looking at Reg 7 Guides and this sort of thing, weve pushed the staff 8 to include examples.
9 But it seems to me, because this is such 10 a large integrated process, that having a series of 11 tabletop reports will look less like a cookbook and 12 more like the kind of thing that will be helpful in 13 the future, showing people various ways to go at this 14 problem.
15 MR. RECKLEY: Thank you. Well, and I 16 really should thank the industry, the industry is 17 doing the tabletops and coordinating those.
18 So, Ill spend the next few minutes going 19 through the paper, because, again, it is the paper 20 that were expecting to be addressed in the letter and 21 well come back for a letter on the draft Guide.
22 Anyway, thats the way we had kind of left 23 it, its obviously up to the Committee to decide how 24 to do this. But we are asking the Commission to make 25 some decisions and Im sure that they would value the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 1 ACRS input on the proposal.
2 So, the paper is just organized -- and by 3 the way, it hasnt changed. Neither has the draft 4 Guide changed as weve really gone through the 5 process, more than some clarifications and editorial 6 changes.
7 So, its organized by the paper itself.
8 An enclosure with background that goes into the 9 previous activities, going back into the 1990s and 10 then, up to current day.
11 And then, Enclosure 2, which talks about 12 the process, which is a higher level summary of the 13 discussions in NEI 18-04 and DG-1353.
14 So, in terms of background, Im not going 15 to go into a lot. There were a couple key papers 16 brought before the Commission.
17 One, SECY-93-092, back in the early 1990s.
18 This was coming out of the initial PRISM review, 19 considerations of the modular high-temperature gas 20 reactor, and some other designs.
21 There was a lapse for a while, in terms of 22 the scale of our activities, we came back in the early 23 2000s. And a key paper for this current discussion is 24 SECY-03-0047, Policy Issues Related to Licensing Non-25 Light-Water Reactor Designs. And Ill come to that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 one in particular.
2 And then, also, building off of all the 3 other risk-informed activities. The time frame for a 4 lot of the non-light-water reactor work was 5 overlapping with other risk-informed, performance-6 based activities, leading to things like NUREG-1860 7 proposals and advanced notice of proposed rulemaking 8 and some of those things that, as projects kind of 9 lost their momentum, got set aside.
10 But there was progress made. And as I 11 mentioned, one of the key ones was putting before the 12 Commission proposals and having them make actual 13 decisions on a couple key policy issues.
14 And so, in SECY-003-0047, the staff asked 15 the Commission to approve the use of a probabilistic 16 approach for the identification of events, a 17 probabilistic approach to safety classification of 18 SSCs, and a relaxation or a change to the design 19 process to move from single failure criteria over to 20 a broad assessment of events across a wider range of 21 frequencies and to replace the single failure 22 criterion with a probabilistic or reliability-based 23 approach. So, the Commission approved those in an SRM 24 related to that SECY paper.
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74 1 through the major elements that are addressed in the 2 draft Guide, again, at a higher level, and we try to 3 point out the key areas where we think they are 4 consistent with the previous Commission decisions, 5 where it might be a new decision or a logical 6 extension of past decisions.
7 And then, also, to ask the Commission, 8 finally, youre going to get to see a picture of how 9 the pieces fit together. We want to make sure that 10 this is in line with what you think is appropriate.
11 So, the biggest decision out of the paper 12 is how the pieces fit together and then, there are a 13 couple areas where the Commission has not made a 14 specific decision and we are going to ask them to make 15 sure that theyre okay with the direction were going.
16 MEMBER MARCH-LEUBA: Very quickly, because 17 the time is getting there, have you given any thought 18 of how this will be implemented? Say, for example, 19 NuScale, NuScale could have used this, they didnt, 20 but they could have, for the design certification.
21 MEMBER CORRADINI: I dont think they 22 could, theyre not a non-light-water reactor. Theyd 23 have to --
24 MEMBER MARCH-LEUBA: Its a small -- its 25 an SMR, right? Well, what -- okay. Somebody that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 wants to do a design certification, and they choose 2 the events early in the process.
3 Is there a way, whether you tie it -- when 4 youre finally done and you have a COL and all those 5 150 ITAACs get resolved, that this gets reanalyzed and 6 verified that all the events -- that you didnt miss 7 one?
8 Because I can guarantee you whats going 9 to happen, theyre going to choose some events out of 10 whatever draft PRA they got, and then, they are going 11 to change them.
12 MR. RECKLEY: The gist of the process is 13 that you dont really get to choose your events. You 14 have a design and youre going to assume failures of 15 all of the various combinations of SSCs that you have.
16 What you get to estimate, perhaps, and what will get 17 a lot of attention --
18 MEMBER MARCH-LEUBA: They do it based on a 19 draft conceptual PRA, incomplete always.
20 MR. RECKLEY: Yes. Yes, as they go 21 through, again, its iterative. And so, what they 22 start out estimating through the process hazard or the 23 failure modes and effects, and then, ultimately, 24 through the PRA. By the time its submitted to us, it 25 will be complete and it will be supported by the PRA NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 theyre providing to us.
2 MEMBER MARCH-LEUBA: Yes, but then, 3 eventually, theres going to be -- theres a lot of 4 ITAACs and COL items that get pushed back. Is there 5 a thought that, whenever you want to build a plant, 6 you have to redo this -- the final PRA is not done 7 until two days before you load fuel, right?
8 MR. RECKLEY: Right.
9 MEMBER MARCH-LEUBA: And that --
10 MR. RECKLEY: Well, its some period --
11 MEMBER MARCH-LEUBA: Okay. A --
12 MR. RECKLEY: -- six months or --
13 MEMBER MARCH-LEUBA: -- couple of weeks.
14 MR. RECKLEY: Yes.
15 MEMBER MARCH-LEUBA: But --
16 (Laughter.)
17 MEMBER CORRADINI: I was going to say, I 18 think theres a definable time period.
19 MR. RECKLEY: Right.
20 MEMBER CORRADINI: I cant remember if its 21 a year --
22 MEMBER MARCH-LEUBA: Im exaggerating with 23 a couple of weeks, but very late in the process. Is 24 there a thought that the events have to be rethought, 25 verified that you didnt miss something, when you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 actually have the real PRA?
2 MR. RECKLEY: Or that the PRA has to verify 3 --
4 MEMBER MARCH-LEUBA: Yes.
5 MR. RECKLEY: -- what youve modeled and 6 how youve laid it out, yes.
7 MEMBER MARCH-LEUBA: But that should be, I 8 wouldnt call it codified, but it should be understood 9 that thats -- there is a process that would have to 10 be followed.
11 Because were pushing a lot of things to 12 the construction side and something will be forgotten.
13 And not just forgotten, once you have your design-14 basis events specified, its going to be very hard to 15 change them, even if the PRA changes.
16 MR. RECKLEY: Okay. So, just going through 17 the highlighted area of what were asking the 18 Commission, we just basically describe what weve 19 already described here, in terms of the event 20 selection.
21 From the Commissions point of view, or 22 the staffs point of view, were saying the use of the 23 probabilistic approach to the identification of events 24 is consistent with our previous SECY paper and 25 Commission decision in 2003.
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78 1 The use of frequency consequence targets 2 to support the capabilities and reliabilities is 3 consistent. And the replacement of the -- or not 4 including the assumption of single failure within the 5 design process, based on a probabilistic and 6 establishing performance criteria for SSCs is 7 consistent.
8 The one thing the Commission didnt 9 specifically address in those previous decisions, and 10 I think its something Dr. Corradini brought up 11 earlier, was the notion of having a cutoff below which 12 youre saying there is some residual risk of this 13 facility, and its not address specifically within the 14 LBEs and the measures taken to prevent or mitigate 15 those LBEs.
16 And so, we want to point out to the 17 Commission that we think that that is a logical 18 outgrowth of using the probabilistic approach. There 19 has to be, at some point, where you say, were not 20 going to address that. Thats within the current 21 processes, itll be within the process going forward.
22 We think its just -- the process going 23 forward actually has more thought given to what youre 24 not going to address than what the current one does.
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79 1 that this isnt, or shouldnt be viewed as a hard 2 line, such that 5E-7 is some magic number and if Im 3 able to show that Im at 4E-7, Im just free to just 4 dismiss that.
5 You have to address the uncertainties, 6 where the defense-in-depth assessment, the 7 consideration of cliff edge effects, all of those 8 things that weve learned that we need to do is built 9 into the process, such that youre making a logical 10 decision for what you do not need to address within 11 the licensing basis events.
12 The safety classification and performance 13 criteria element within the paper is, again, generally 14 consistent with the discussions that were going on in 15 the 2003 time frame, and so, consistent with the 16 Commission decision in 2003, to use a probabilistic 17 approach for safety classification.
18 Assessing defense-in-depth, again, the 19 paper just outlines, and weve gone through this, so 20 I wont repeat.
21 It includes things like the Integrated 22 Decision-Making Panel that weve incorporated into 23 50.69 and 50.65, the Maintenance Rule, our 24 consideration of risk-informed tech specs. So, this 25 is, again, generally consistent with other actions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 that the Agency has taken.
2 One thing we point out in the paper is 3 that there was a time frame and a decision made 4 related to SECY-15-0168, was the risk management 5 regulatory framework proposal.
6 And in that paper, the question was posed 7 to the Commission, should the Agency define defense-8 in-depth? Should we define a specific policy 9 statement, where were very clear on what it means?
10 And the Commission said, no.
11 And so, what we point out in the 12 Commission paper is, this process does include a 13 defense-in-depth assessment as part of the process.
14 We are not planning to impose this on anybody else, 15 but if youre using this process, an assessment of 16 defense-in-depth is an integral part of the process.
17 So, we just want to make sure that the 18 Commissions comfortable, for this particular case, 19 for non-light-water reactors using this methodology, 20 that it does include an assessment of adequacy of 21 defense-in-depth.
22 MEMBER MARCH-LEUBA: Yes. Bullet 3 there, 23 it kind of -- its very interesting. It kind of 24 provides how you do the defense-in-depth, right? You 25 make sure that if one fails, the other one works. Is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 1 this a fancy way of saying, single failure criteria?
2 MR. RECKLEY: I wouldnt say -- it has some 3 similarities to it, but in large degree, the single 4 failure criterion, Ill simplify, led to two trains.
5 Often, two redundant trains, not necessarily two 6 diverse trains.
7 This will say, Im not putting all my eggs 8 in one basket, but it probably would lead to more 9 diversity versus --
10 MEMBER MARCH-LEUBA: But you --
11 MR. RECKLEY: -- simple redundancy.
12 MEMBER MARCH-LEUBA: But you did use 13 independent, you didnt use diversity.
14 MR. RECKLEY: Right.
15 MEMBER MARCH-LEUBA: On purpose, I assume.
16 MR. RECKLEY: But that would come, really, 17 out of the risk assessments. And its an expected 18 outcome, but not necessarily a required outcome.
19 MEMBER MARCH-LEUBA: So, when theyre doing 20 this verification in Bullet 3, they should at least 21 consider diversity or common-cause failures of the two 22 systems?
23 MR. RECKLEY: Yes.
24 MEMBER MARCH-LEUBA: Because if you put two 25 check valves next to each other, they get broken by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 1 the same seismic event?
2 MR. RECKLEY: Thats right.
3 MEMBER MARCH-LEUBA: Okay, thank you.
4 MR. RECKLEY: Then, lastly, within the 5 paper, we bring up that were really looking to take 6 this as a stepping stone to providing additional 7 guidance on the content to applications.
8 To try to make sure that the developers, 9 ultimately the applicants, are able to provide us the 10 most directed, concise application that they can bring 11 us, addressing the measures that assure the safety of 12 that particular design.
13 We think this approach feeds that 14 capability pretty well, because the design process, 15 the licensing process, as its defined here, is all 16 trying to focus in on whats the most important, and 17 from our point of view, therefore, what should be the 18 focus of the application?
19 What areas do you need to provide the most 20 information? What areas might you be able to provide 21 less information? And possibly, what areas dont you 22 need to include any information?
23 And so, although the Commission has 24 previously told us many times, in different papers and 25 different initiatives, to include risk-informed, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 performance-based approaches in our reviews, its not 2 quite been as emphasized that it should also be used 3 in actually deciding whats put in an application.
4 So, we want to put before the Commission, 5 we want to take this, expand upon it, and actually use 6 this approach to define what needs to be in an 7 application.
8 MEMBER REMPE: So, Bill, now, the NEI 9 document acknowledges that not all the regulations 10 will be met.
11 MR. RECKLEY: Right.
12 MEMBER REMPE: Are you saying, then, in 13 light of the fact that not all regulations will be met 14 using this approach, its just for selecting licensing 15 basis events and --
16 MR. RECKLEY: Right.
17 MEMBER REMPE: -- et cetera, classifying 18 equipment, are you saying the applications dont have 19 to include anything else about the design to meet the 20 other regulations?
21 MR. RECKLEY: No. No, but if you look at 22 an application -- they will still have to address all 23 the other regulatory criteria and how they are meeting 24 that and what aspects of the design.
25 But to be fair, when you look at what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 1 drives the level of information on particular systems, 2 structures, and components, and the bulk of an FSAR, 3 that is this big, it really is the events and the 4 safety classification, and to some degree, the 5 defense-in-depth assessments, not so much for current 6 applications.
7 But what you need to do for those other 8 rules tends to be much more direct. Heres the rule, 9 heres what were doing to address it. That will 10 still need to be there.
11 MEMBER REMPE: Okay, thank you.
12 MEMBER CORRADINI: So, this is an optional 13 path for non-light-water reactors. So, if they choose 14 not to go this path, they must meet current 15 regulations and take exemptions to the general design 16 criteria, et cetera, et cetera?
17 In other words, Im trying to understand 18 -- and the reason Im asking the question like this 19 is, although defined, and I typically think its quite 20 a good approach, it could create a conversation for 21 the first few of these that could be viewed as 22 interminable.
23 So, the other option path is to 24 essentially follow the current regulations and then, 25 take exemptions? I mean, thats how --
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85 1 MR. RECKLEY: Yes.
2 MEMBER CORRADINI: -- the gas-cooled 3 reactor did it, thats how --
4 MR. RECKLEY: You could do that approach.
5 You can come forward with principal design criteria, 6 your barriers.
7 You could take the standard ANS 51.1, 8 52.1, for light-water reactors and try to say, heres 9 our events, based on functions like decreases in heat 10 removal, decreases in inventory, reactivity 11 transients, and heres how were going to address 12 those within our designs. One could construct that --
13 MEMBER CORRADINI: I understand.
14 MR. RECKLEY: Yes, you could take a shot.
15 Were going to end up asking you many of the questions 16 that would have been answered through this process.
17 MEMBER CORRADINI: I figured that.
18 MR. RECKLEY: I mean, so --
19 MS. CUBBAGE: This is Amy Cubbage. I just 20 wanted to clarify something. Under both approaches, 21 they both have to propose PDCs. And in either case, 22 would they need an exemption to do so, because the 23 GDCs dont apply.
24 So, in both cases, if you use LMP or an 25 alternative approach, you have to propose PDCs. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 both approaches would be under the current regulations 2 and both approaches would likely have some level of 3 exemptions. The use of LMP wouldnt necessarily 4 obviate the need for exemptions or otherwise.
5 MEMBER CORRADINI: Okay. So, your point, 6 though, is that it would, in theory, streamline the 7 choosing of what LBEs go into DBAs, et cetera, et 8 cetera --
9 MS. CUBBAGE: Which is one way of 10 fulfilling the current regulations. Another way of 11 fulfilling the current regulations is to use, as Bill 12 said, more of the standards and traditional 13 engineering judgment and deterministic thoughts to 14 determine what the events are.
15 MEMBER CORRADINI: Okay.
16 MR. RECKLEY: Right.
17 MEMBER CORRADINI: Thank you.
18 MR. RECKLEY: But then we would go from, 19 for example, in the area of non-safety-related with 20 special treatment, you would go, and if youre going 21 to say, well, well going to try to use something much 22 closer to what we do now, then you would go over to 23 regulatory treatment of non-safety systems or RTNSS.
24 And the criteria that are defined are 25 sometimes hard to follow and sometimes, theyre light-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 1 water reactor specific, as to how they were derived.
2 You would have to propose something in that arena to 3 say, heres how were going to go.
4 My personal opinion is, its going to come 5 out looking a lot like, well, were going to have an 6 Integrated Decision-Making Process to try to help us 7 assess what needs additional regulatory treatment.
8 MEMBER CORRADINI: So, okay. I want to 9 just test the other pathway. The other part of this, 10 though, that I wanted to make sure I understood is, 11 youre not necessarily looking for a detailed PRA, but 12 youre looking for a comprehensive look at the system, 13 so that I might be able to make, Ill use the word 14 conservative or bounding estimates on frequency or 15 consequence.
16 As long as its complete, as complete as 17 you can get it, it doesnt have to be highly detailed.
18 Because some of these systems are such that, to get a 19 highly detailed one would be a challenge.
20 MR. RECKLEY: I think thats true.
21 MEMBER MARCH-LEUBA: How can it be complete 22 and not detailed?
23 MEMBER CORRADINI: Because you can make 24 bounding assumptions. In some --
25 MEMBER MARCH-LEUBA: Okay.
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88 1 MEMBER CORRADINI: -- other applications, 2 that we shouldnt --
3 MEMBER MARCH-LEUBA: You mean conservative?
4 MEMBER CORRADINI: -- talk about in public, 5 theyve had relatively conservative assumptions on 6 what the accidents are and what the responses to those 7 accidents are. And that made it complete, but it was 8 not very detailed.
9 MR. RECKLEY: Time will tell. The thought 10 is, many of these designs would have more 11 straightforward or simpler PRAs, just reflecting the 12 simpler designs, right?
13 If I have an active component that then 14 relies on active cooling and AC power and all of those 15 dependencies, that is what drives the complexity. And 16 sometimes, as you mentioned, I make assumptions on 17 those supporting things or how far down I go.
18 In the passive arena, hopefully, theyre 19 less complex simply because theyre less complex.
20 MEMBER CORRADINI: Right. But I --
21 MEMBER BLEY: Often, this -- not going at 22 the detail, making what appear to be conservative 23 assumptions, are conservative for what youre thinking 24 about, but may be optimistic for other scenarios.
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89 1 be pretty thorough, to make sure if you do make 2 bounding assumptions, that theyre really bounding for 3 everything.
4 MR. RECKLEY: Or you make different 5 assumptions for different scenarios.
6 MEMBER BLEY: Which is the right way to do 7 it.
8 MR. RECKLEY: Yes.
9 MEMBER CORRADINI: Okay. All right, 10 thanks.
11 MEMBER MARCH-LEUBA: As we are getting to 12 the closing arguments, I wanted to reemphasize what I 13 said before, that the staff is always going to be 14 reinventing, retransforming, reengineering, pick the 15 name, which means, have less money available to the 16 reviews.
17 This type of PRA is not the place to save 18 money, doing the review. Because the consequences of 19 being wrong on those frequencies, having missed a 20 sequence, are very large. So, whenever we retransform 21 again, dont save money on this PRA review.
22 MR. RECKLEY: Okay. And we hope, I didnt 23 mention it here, we mention it within the draft Guide 24 and its mentioned in NEI 18-04, we look, hopefully to 25 help in that arena, the ASME/ANS non-light-water NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 reactor PRA standard, that will call -- provide 2 guidance for how to do that or include peer reviews 3 and so forth, to help make sure that the PRA is good 4 enough to support this activity.
5 MEMBER BLEY: Youre all done? I think 6 its time to see if any of the members have further 7 questions. And then, well go for public comment.
8 MEMBER KIRCHNER: May I ask?
9 MEMBER BLEY: Sure.
10 MEMBER KIRCHNER: Bill, I just want to test 11 the last lines of 19. So, do you see -- this 12 approach, I think should inform where the NRC puts a 13 great deal of its attention, but how substantively is 14 that going to change the scope and level of detail in 15 the application?
16 MR. RECKLEY: That will be design-specific.
17 As an example that Ive used in the past is, the 18 current requirements to describe within the 19 essentially complete design is to describe the power 20 conversion systems in some detail.
21 And for light-water reactors, that makes 22 sense, because power conversion, upsets on the 23 secondary translate very quickly to upsets on the 24 primary, and youre dependent on heat removal and so 25 forth. And so, secondary plant systems are described NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 in some detail for light-water reactors.
2 If a design can show that their heat 3 removal is not through the secondary, and a secondary 4 plant upset doesnt cause a transient, a fast-acting 5 transient on the primary, because the heats being 6 absorbed by the graphite or the heat capacity of the 7 sodium or whatever the argument would be, then that 8 argument would be, they dont need to describe the 9 secondary plant as much as the light-water reactor has 10 done.
11 That would be an example. But they would 12 have to show that an upset on the secondary doesnt --
13 MEMBER KIRCHNER: They would have to show 14 enough to demonstrate to you that it doesnt have an 15 impact?
16 MR. RECKLEY: Right. But having shown 17 that, they then wouldnt need to describe the 18 secondary as much.
19 MEMBER BLEY: Anything else from the 20 members? Charlie?
21 MEMBER BROWN: Yes, a little bit on, since 22 I havent said anything about the I&C world. But when 23 you -- level of detail of information to be included, 24 following up on Walts comment, where when I first got 25 here, ten years ago plus change, ESBWR was coming NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 through for an application.
2 And the level of detail provided for the 3 I&C systems were sparse, to say the least. Little 4 information on how they achieved independence and just 5 words that says, in the application, well follow the 6 rules and the rule for IEEE 603, et cetera, and the 7 various Reg Guides.
8 It was -- you just had no idea how they 9 were going to accomplish this with the software-based 10 systems. Has -- now, I understand that for event 11 selection, thats a different issue.
12 But here, are reactor protection and 13 reactor trip or safeguards actuation type functions, 14 where theres a fairly standardized approach, and have 15 there been any discussion on whether those would be, 16 quote, under the risk assessments, say, we dont need 17 them at all?
18 MR. RECKLEY: I havent seen --
19 MEMBER BROWN: Because these plants are so 20 safe?
21 MR. RECKLEY: I havent seen any go as far 22 as, we dont need them at all. The -- you do have, in 23 the non-light-waters, again, the additional thermal 24 capacities or the longer time constants can reduce the 25 importance of how fast your reactivity control systems NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 1 work.
2 Which then can show up in simpler 3 reactivity control systems and simpler instrumentation 4 to drive it, because I dont need the instrumentation 5 and the control rods to respond in two seconds, I 6 might have a much longer time period.
7 And so, those physical things can get 8 reflected in the descriptions and in the application, 9 but its because youve shown that theyre less 10 important, not a priori, Im not going to describe 11 them.
12 Once you show theyre less important, then 13 you might be able to describe them in less detail or 14 have less complex systems.
15 MEMBER BROWN: Thats fairly mushy.
16 MR. RECKLEY: Yes.
17 MEMBER BROWN: Okay.
18 MR. RECKLEY: Because we wont know until 19 we see a design and how they craft the safety 20 arguments that theyre trying to craft.
21 MEMBER BROWN: Well, time response is one 22 issue. I mean, a few seconds versus 250 milliseconds 23 or 500 milliseconds.
24 Theres -- I mean, weve got some 25 scenarios that are seconds in response today, yet our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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94 1 systems fundamentally reflect fairly responsive and 2 parallel independent systems, to make sure something 3 happens --
4 MR. RECKLEY: Right.
5 MEMBER BROWN: -- regardless of whether you 6 have ten or 15 minutes to do something.
7 MR. RECKLEY: Right. But again, one of the 8 fundamental or primary safety functions, the 9 generation of heat or reactivity control, will 10 continue, I think, personal opinion, to always require 11 you have those protection systems, and theyll have to 12 be described as to how they work.
13 There will just be a little more 14 discussion for the non-lights, I think, as to how that 15 also pairs with intrinsic reactivity feedback 16 mechanisms and other things that come into play, maybe 17 more than light-water reactors have. But well see.
18 I dont --
19 MEMBER BROWN: Thank you.
20 MEMBER BLEY: Okay. And I think at this 21 point, well go to public comments. If we can get the 22 phone line open?
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95 1 your name and your organization, and give us your 2 comment.
3 Is there anyone on the phone line who 4 would make a comment? Who would like to make a 5 comment? Its really open? Okay. I dont hear 6 anything.
7 Okay. I think were finished. Mr.
8 Chairman, back to you.
9 CHAIRMAN RICCARDELLA: Thank you.
10 MEMBER BLEY: Exactly on time.
11 CHAIRMAN RICCARDELLA: Very well done, 12 were exactly on time at 10:30. And it shows that we 13 have a 15-minute break. We will reconvene at 10:45 to 14 discuss Non-Production and Utilization Facilities 15 Rulemaking. Thank you.
16 (Whereupon, the above-entitled matter went 17 off the record at 10:30 a.m. and resumed at 10:47 18 a.m.)
19 CHAIRMAN RICCARDELLA: Okay. I think we 20 have a quorum.
21 We will now move to NPUF, non-production 22 and utilization facilities rulemaking. And I will 23 turn the meeting over to Subcommittee Chairman, Matt 24 Sunseri.
25 MEMBER SUNSERI: Thank you, Mr. Chairman.
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96 1 This discussion on the non-production and utilization 2 facilities rulemaking is a continuation of a process 3 that we've been going through for a couple of years 4 now.
5 There was a previous subcommittee and a 6 letter written in 2016. And we recently had a 7 subcommittee meeting in January. And this will be the 8 briefing from that meeting. And we intend to roll 9 into letter preparation, letter report preparation 10 following this presentation today.
11 So, with no further ado, I'd like to turn 12 it over to Ms. Lund for introductions here.
13 MS. LUND: Thank you very much. Good 14 morning. I'm Louise Lund. And I'm the Director of 15 the Division of Licensing Projects --
16 MEMBER SUNSERI: Can I just -- hold on for 17 a second. So the acoustics in this room are pretty 18 challenged here. So what I ask you to do is just to 19 make sure that the microphone is clearly aligned with 20 your voice, because I couldn't hear what you were 21 saying.
22 MS. LUND: Okay. Does this work?
23 MEMBER SUNSERI: That --
24 MS. LUND: Okay. Great. Thank you. Good 25 morning. I'm Louise Lund. And I'm the Director of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 1 the Division of Licensing Projects in the Office of 2 Nuclear Reactor Regulation.
3 The NRC is here today to provide an 4 overview of the draft final non-power production or 5 utilization facility rulemaking, which we call the 6 NPUF rulemaking.
7 Seated at the table over there to the side 8 are Bob Beall, the Rulemaking Project Manager from the 9 Office of Nuclear Material Safety and Safeguards, and 10 I am sure that you're aware that rulemaking moved over 11 as a group to NMSS, and Duane Hardesty, Senior Project 12 Manager, and Al Adams, Senior Project Manager. And 13 they're both from the Research and Test Reactor 14 Licensing Branch in the Office of Nuclear Reactor 15 Regulation.
16 And I think we mentioned probably at the 17 subcommittee meeting that Al Adams is now in phased 18 retirement. But he's still in the group helping us 19 out with a number of projects. So that's really good 20 for us.
21 So we also have working group members and 22 management from the offices of NRR, Office of General 23 Counsel, Office of Research, NMSS, and the Office of 24 New Reactors.
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98 1 who is the Acting Branch Chief in the RTR Licensing 2 Branch, Rich Clement, Michael Smith, Kevin Folk, and 3 Kos Lois from NRR, Tony Gomez from NMSS, Howard 4 Benowitz from OGC, and Michael Eudy from research to 5 assist in answering any questions that come from the 6 committee.
7 And to support this rulemaking, the staff 8 has developed a draft final rulemaking package which 9 consists of a Commission Paper, Federal Register 10 Notice and a new regulatory guide, Reg Guide 2.7, 11 preparation of updated final safety analysis reports 12 for non-power production or utilization facilities, 13 and I'll tell you a little bit more how that factors 14 in, and other supporting documents that provide the 15 details of the proposed regulatory changes and the 16 benefits to the licensees and NRC staff.
17 There are nine regulatory actions which 18 are changes included in the draft final rule. Okay.
19 The most transformative action is 20 elimination of fixed license terms for research 21 reactors, which is consistent with the requirement of 22 the Atomic Energy Act to impose minimum regulation on 23 these licensees and reduces the burden on licensees 24 and the NRC staff, and most importantly, maintains 25 adequate protection of public health and safety of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 1 environment. And there'll be more discussion as to 2 how that works.
3 We look forward to an informative 4 interaction with the ACRS today. And I want to thank 5 the ACRS for its review, its comments, and feedback to 6 the staff on this very important rulemaking.
7 To start today's presentation, Bob Beall 8 will provide an overview of the NPUF rulemaking. And 9 Duane and Al will then provide a detailed discussion 10 of the nine recommended regulatory changes. Thank you 11 very much.
12 MR. BEALL: Okay. Thank you, Louise. So 13 the draft final rule here that's before you and I'm 14 here to discuss implements the direction the staff got 15 from the Commission to streamline the license renewal 16 process for non-power reactors in NPUF type 17 facilities.
18 And they wanted us to create a more 19 efficient and effective regulatory framework for these 20 facilities.
21 And during the process over the past 22 couple years the staff has used their own knowledge 23 and also comments from the public to come up with 24 innovative and transformative approaches, which you'll 25 see in a few minutes that we've come up with some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 1 interesting ideas on how to accomplish this for these 2 non-power licensees.
3 And those ideas are all contained in the 4 nine rulemaking objectives that Al and Duane will be 5 going over in a few minutes.
6 For the proposed rule, we issued a 7 proposed rule on March of 2017 that was out for a 75-8 day comment period. And we also held a public meeting 9 on May of that year to assist the public in 10 formulating their questions. They came in and we were 11 available, the staff was available to answer any 12 questions or comments they may have about the proposed 13 rule.
14 And at the end of the comment period, we 15 received 16 comment submissions. And in general, all 16 the comments were supportive of the rulemaking process 17 that we were proposing.
18 As Matt mentioned, we were here just a 19 couple weeks ago in January to present to the 20 subcommittee. And during that meeting, the TRTR 21 chairman stated that he felt that the draft final NPUF 22 rule was a win/win for both the NRC and the NPR 23 community. So that was a very nice endorsement he 24 gave us.
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101 1 Duane and Al. And they will go through the nine 2 regulatory changes that the staff is proposing to 3 make.
4 MR. HARDESTY: Good morning. I would like 5 to start by showing this slide, this graphic here, 6 which is a generalization of the types of facilities 7 that are affected by this rulemaking.
8 Section 101 of the Atomic Energy Act 9 provides the authority to license production and 10 utilization facilities. And the types of non-power 11 production or utilization facilities or NPUFs are 12 given in both Section 103 and 104 of the Act.
13 Currently, the NRC regulate 36 NPUFs, 14 which includes 30 research reactors, 1 testing 15 facility, 1 of which is dual licensed as a medical 16 therapy facility under 104(a), and then the 5 17 remaining facilities are 2 medical isotope production 18 facilities which have construction permits, and 3 19 class 103, I'm sorry, 3 104(c) facilities that are in 20 decommissioning.
21 As we go through the slides, you're going 22 to see this graphic each time. And it will be grayed 23 in and out to show the effectivity of the particular 24 objective that I'm talking about.
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102 1 those slides. And that denotes changes between what 2 was in the proposed rule and what's in the draft final 3 rule.
4 So the first objective of the rule is to 5 address inconsistencies in definitions and terminology 6 that were in our regulations. The draft final rule 7 creates a definition for non-power production and 8 utilization facilities which is flexible enough to 9 capture all of the non-power facilities licensed under 10 Part 50, including the medical isotope facilities.
11 The NPUF definition was modified in the 12 draft final rule because the staff realized that the 13 definition was too broad.
14 The definition in the proposed rule 15 excluded fuel cycle facilities, or I'm sorry, fuel 16 reprocessing facilities. But we determined we also 17 needed to exclude production facilities that were 18 designed for the formation of plutonium or uranium-233 19 or designed for the separation of plutonium, both 20 which are captured in Part 1 and 2 of the definition 21 of production facility in 50.2.
22 The staff also received a public comment 23 on the definition of testing facility and research 24 reactor, which I will talk about next.
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103 1 Technology submitted a comment recommending a more 2 risk-informed definition for testing facility and for 3 research reactor and recommended the use of the one 4 rem accident dose criteria that we established for 5 research reactors as being the demarcation threshold 6 between them. Next slide. Okay.
7 The NRC agreed that use of the postulated 8 accident dose is a more risk-informed, performance-9 based approach to distinguish between NPUF facility 10 types and modified the definitions of testing facility 11 and research reactor to be based on that accident dose 12 criteria.
13 The staff also made conforming changes to 14 the definition of non-power reactor and standardized 15 the use of terminology throughout the NRC regulations.
16 Next slide.
17 MR. ADAMS: Good morning. I'd like to 18 talk about the second objective, which entails 19 eliminating license terms for certain NPUFs.
20 The Atomic Energy Act does not establish 21 a license term for class 104(a) or 104(c) facilities.
22 The term is limited only by 10 CFR 50.51(a) to 40 23 years or less. The staff currently licenses NPUFs for 24 20-year terms for both renewals and initial licenses.
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104 1 consider terms that were longer than 20 years other 2 than indefinite, but determined that with the addition 3 of regular FSAR updates there's no significant nexus 4 between safety and the license renewal process.
5 The regulations allow 40-year licenses.
6 And several licenses with 40-year terms were issued in 7 the late 1950s and early 1960s.
8 The staff determined that 40 years was too 9 long of a time to go without an SAR update and adopted 10 the practice of 20-year terms after a decision was 11 made in the 1970s that license renewal was no longer 12 a simple administrative action.
13 The staff's experience with renewals show 14 that even going 20 years without a formal process to 15 update the licensee basis documentation contributed to 16 a loss of licensing basis and contributed to the last 17 backlog of license renewals. Thus, the staff 18 concluded that longer license terms would further 19 aggravate the difficulties that were experienced.
20 During the proposed rule phase, it was 21 suggested that we both extend the terms of licenses 22 and require FSAR updates. However, feedback from 23 public meetings showed that the RTR license community 24 would not support a proposal that included both FSAR 25 updates and license renewal for research reactors.
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105 1 The staff agreed that both were not needed 2 to protect public health and safety. The staff's view 3 is that the non-expiring license is consistent with 4 the Atomic Energy Act Section 104(a)(2), quote, impose 5 only such minimum amount of regulation under this Act 6 to promote the common defense and security and to 7 protect public health and safety.
8 The next two slides discuss how health and 9 safety of the public is maintained with a non-expiring 10 license. Next slide.
11 This slide provides technical reasons 12 based on design and operational characteristics of 13 class 104 NPUFs for discontinuing license renewal for 14 NPUF licensees due to their low risk.
15 This discussion is applicable to the 16 medical therapy and research reactors. It is not 17 related to testing facilities or commercial and 18 medical ISO facilities who will still be subject to 19 license renewal.
20 While commercial facilities may have some 21 of the attributes of non-commercial facilities, 22 potential pace and scope of commercial activities 23 justifies the additional scrutiny of class 103 24 licensing process.
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106 1 than testing facilities will have a maximum accident 2 dose criteria of one rem TEDE. These facilities 3 operate at low power levels, have a small inventory of 4 fission products, and operate at low temperatures and 5 pressures preventing a low potential radiological risk 6 to the environment and the public.
7 These facilities are also simple in their 8 design and operation. And, therefore, the scope of 9 aging-related concerns is limited. The staff has 10 found no significant aging issues because NRC 11 currently imposes aging-related surveillance 12 requirements on NPUFs via their technical 13 specifications.
14 In addition, the design basis of these 15 facilities evolves slowly over time. The NRC receives 16 approximately five license amendment requests each 17 year from all the licensees combined. Further, on 18 average, each of these facilities reports only five 10 19 CFR 50.59 evaluations per year. Next slide, please.
20 MEMBER KIRCHNER: Al, before you go on, 21 just as a footnote, could you just specify where that 22 dose is measured?
23 MR. ADAMS: So the dose is to the 24 maximally exposed person, wherever that person might 25 happen to be.
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107 1 MEMBER KIRCHNER: So there's no distance 2 implied, just the maximally --
3 MR. ADAMS: Right.
4 MEMBER KIRCHNER: -- exposed person?
5 MR. ADAMS: Right.
6 MEMBER KIRCHNER: Okay.
7 MR. ADAMS: Sometimes the distance is to 8 the fence or to the -- you know, the boundary of the 9 restricted area of research reactors is very small.
10 It could sometimes be the, you know, the room in the 11 engineering building.
12 MEMBER KIRCHNER: Yes. All right.
13 MR. ADAMS: So we considered the nexus 14 between license renewal and safety. When the first 15 power reactors are facing license renewal, research 16 reactor license renewal is already an established 17 process.
18 We looked at the framework that was being 19 developed for power reactor license renewal and 20 focused on aging of structures, systems, and 21 components important to continued safety.
22 We did not include research reactors in 23 the power reactor framework for Part 54 because we 24 already had an established license renewal process.
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108 1 encompass if limited to aging issues for research 2 reactors.
3 So the question is, without notable aging 4 issues, what does taking a snapshot of a research 5 reactor only once every 20 or 40 years contribute to 6 safety. We came to the conclusion that there was 7 nothing of safety importance.
8 There are other processes in place that 9 ensure safety on a continuing basis. And the actions 10 we have taken or are proposing to take contribute more 11 than continuing safety than performing a license 12 renewal every 20 years.
13 NUREG 1537 is our format and content 14 guidance for licensees and the standard review plan 15 for the staff for NPUF licensing actions. It was 16 issued in 1996 with two interim staff guidance 17 documents issued later. There was no comprehensive 18 guidance for research and test reactors before 1996.
19 As an entrance criteria to being ordered 20 into a non-expiring license, all of the facilities 21 will undergo a license renewal review using the 22 guidance of NUREG 1537. This ensures a comprehensive 23 and consistent licensing basis using established 24 guidance for the licensees.
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109 1 that was reviewed and documented in the safety 2 evaluation report using the standard review plan. So 3 we will have the solid, documented basis of the safety 4 of the facilities entering into the non-expiring 5 license process.
6 The oversight and inspection program is a 7 comprehensive look at all aspects of facility 8 operation. Inspectors are on site up to several times 9 a year. Any deterioration in licensing performance 10 will be discovered, documented, and corrected.
11 Inspection results are reviewed for 12 adverse trends that could indicate new aging issues.
13 Licensees also report maintenance, which includes 14 component issues, in their annual reports, which would 15 allow the NRC to identify new aging issues if they 16 were to occur.
17 As such, the staff believes that the 18 regulatory oversight and requirement for FSAR updates 19 by the final rule will provide the safety benefits 20 currently afforded by the license renewal process.
21 I'll turn it back over to Duane at this 22 point.
23 MR. HARDESTY: All right. So, moving on 24 to the third objective under the draft final rule, the 25 staff wished to consolidate the license renewal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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110 1 requirements for current and future NPUF licensees 2 licensed under 10 CFR 50.22 and all testing 3 facilities.
4 There are no new requirements under 51.35.
5 However, we did make minor modifications to the draft 6 final rule to make the renewed license effective 7 immediately. It used to be effective in 30 days.
8 That was to add flexibility for implementation of the 9 staff and the licensee working together to give 10 flexibility.
11 Then we also removed some text which 12 unnecessarily limited a renewed NPUF license to less 13 than 40 years. A 40-year term is allowed by the 14 Atomic Energy Act. And so that was an error that we 15 corrected. Next slide, please.
16 For the fourth objective, the staff has 17 extended the requirements for updates of final safety 18 analysis reports under 50.71(e) of the Code of Federal 19 Regulations to be applicable to all NPUFs.
20 This is kind of the key part of our entire 21 package in that we are relying on the FSAR updates to 22 be the basis, to maintain the licensing basis for our 23 licensing, or licensees.
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111 1 having difficulty providing documentation to fully 2 describe the details of their licensing basis.
3 Under the draft final rule, NPUFs will be 4 required to provide five-year updates to the FSAR 5 ensuring more timely documentation of changes to the 6 facility. The updated FSAR is important for the NRC's 7 inspection program and for effective license operator 8 training at the facility.
9 The five-year periodicity that we chose 10 reflects the more slowly evolving basis that Al just 11 mentioned for NPUFs. But it's also frequent enough to 12 maintain the licensing basis given the staff's 13 findings for typical number of facility changes and 14 the staff turnover at the facilities.
15 We also generated a Reg Guide, Reg Guide 16 2.7, which provides guidance to the licensees on 17 preparing and submitting FSAR updates.
18 MEMBER SKILLMAN: Duane, what inspection 19 requirements changed when the five-year updates became 20 required? Did --
21 MR. HARDESTY: When will they be required?
22 MEMBER SKILLMAN: No. You have a licensee 23 who has now agreed to have an unexpired, an unexpiring 24 license. And for that privilege, you require a five-25 year update on the FSAR, right?
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112 1 MR. HARDESTY: Actually, all NPUFs, even 2 the ones that undergo license renewal, have to do the 3 updates.
4 MEMBER SKILLMAN: Okay. So what 5 inspection requirements did you change? Did you 6 institute a thicker magnifying glass for that FSAR 7 update so that you really, really know those licensees 8 are toeing the line?
9 MR. HARDESTY: Not per se. There is part 10 of the inspection program where they look at the 11 facility as changed, whether it be via amendment, 12 which the licensing branch would look at, as well as 13 whether it would be under 50.59 without prior 14 notification to the NRC or prior approval of the NRC.
15 And that is documented by the licensee in 16 an annual report to us. So we see those changes much 17 more frequently. And additionally, our project 18 managers interface with the facilities to understand 19 the changes to the facility.
20 So we see that, any changes that come in 21 both from the inspections program where they go out 22 and look at the facilities from these annual reports.
23 And then we'll see a consolidation of that into the 24 five-year updates, which the staff will review as part 25 of the new licensing or the regulatory requirement.
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113 1 MR. ADAMS: Can I just add something? So, 2 when these updates come in to NRC, they're not 3 licensing actions. But the project managers will sit 4 down, review the FSARs. And, you know, they already 5 know what they expect to see in it because they've 6 been involved in issuing the license amendments.
7 They've been involved in looking at 50.59 reviews.
8 So, if they don't see what they expect to 9 see, then they can, then through the inspectors they 10 can feed back through the inspection program a process 11 where the inspectors would discuss this with the 12 licensees when they're on site.
13 MR. HARDESTY: Right. And even now 14 without this, when the project manager and the 15 inspector want to discuss the facility, they'll 16 schedule something prior to the inspector going out 17 for a routine inspection. And the project manager has 18 the opportunity to have the inspector ask any 19 additional questions or look at any additional records 20 that might be reasonable for understanding what is 21 under, what changes are being made at the facility.
22 MEMBER SKILLMAN: Thank you.
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114 1 facilities, which are the two types of facilities that 2 will continue to undergo license renewal.
3 The change is to make the requirement such 4 that they have to submit an application two years 5 prior to the expiration of the license. Current 6 regulations allow that NPUF licensees can submit as 7 soon as 30 days or as late as 30 days prior to the 8 expiration of the license.
9 Again, historically that 30 days has 10 proven to be insufficient time for the NRC staff to 11 make a determination of the acceptability of the 12 application and to adequately assess, I mean, to ask 13 for the licensee to supplement the application.
14 So what we've done in the past is we've 15 basically accepted the application as is, which is, 16 which increased the burden to both the NRC staff and 17 the licensees because all of those deficiencies had to 18 then be addressed through other means such as the 19 request for additional information process.
20 The proposed rule also would have 21 eliminated the requirement for also class, all class 22 104 NPUFs because they didn't have license renewal 23 anymore, so we didn't need them to be in 2.109.
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115 1 situation in which at least one facility will be 2 subject and getting ready to go through license 3 renewal, which is one of our entrance criteria under 4 NUREG 1537, after the final rule goes into effect.
5 So we basically would have put them into 6 a box where they didn't have a timely renewal 7 provision because they couldn't meet the two-year 8 window because they were less than that.
9 So we modified the language slightly so 10 that it didn't go away for anybody that might be doing 11 license renewal that's an NPUF. But it also changed 12 it to two years for those that we intend to have 13 future license renewal, which would be the class 104 14 test, 4(c) testing facilities and all 50.22 15 facilities. Next slide, please.
16 So this is the objective for the accident 17 dose criterion that we alluded to a couple of times 18 already. So we created a new accident dose criterion 19 for all NPUFs other than testing facilities in 10 CFR 20 50.34.
21 So, prior to this, the staff didn't have 22 an accident dose criteria in the regulations. So the 23 licensees were asked to meet the Part 20, 10 CFR Part 24 20 requirements for accident dose criteria.
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116 1 Licensing Appeals Board suggested that the standards 2 in Part 20 were unduly restricted as accident dose 3 criteria for research reactors.
4 In 1991, the NRC amended Part 20 and 5 lowered that public dose from .5 down to .rem. Still 6 at that time the staff was using the Part 20 7 requirements for NPUFs other than testing facilities 8 as the accident dose criteria for demonstrating worst-9 case accidents to a member of the public for the 10 maximum hypothetical accident.
11 MEMBER REMPE: So --
12 MR. HARDESTY: However, in 1992, the 13 Environmental Protection Agency published protective 14 action guidelines. And in January 2017, the EPA 15 published an update to the PAGs and the PAG manual 16 that had dose guidelines that supported their decision 17 to protective actions such as staying indoors, 18 evacuation or evacuation to protect the public during 19 a radiological incident.
20 In the early phase of radiological 21 incidents, the trigger for the protective action of 22 sheltering in place or evacuation of the public range 23 is from one to five rem. So the EPA PAG manual does 24 not provide a protective action recommendation for the 25 public when the projected dose to an individual from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 1 an incident is less than one rem.
2 So, putting that all together, the staff 3 realized that we were unnecessarily limiting the 4 accident dose criteria or we were severely limiting 5 the accident dose criteria for our research reactors 6 and, indeed, also our testing facility. And they were 7 able to meet that.
8 However, not having that accident dose 9 criteria and the fact that the trend is that Part 20 10 continues to go down in dose limits, we wanted to 11 provide an accident dose criteria that was 12 specifically applicable to those non-power production 13 and utilization facilities other than testing 14 facilities, which were governed under Part 100.
15 The staff believes that that one rem 16 criteria aligns well with the PAG guidelines, being as 17 if there is no protective action guidelines 18 recommendations under one rem. And the staff has 19 determined that there is a benefit to the licensees 20 without undue risk to the public by establishing this 21 actual accident dose criteria.
22 The staff did make a small change in the 23 final rule. It was an administrative change of where 24 it was located in 50.34. Where we had put it 25 inadvertently placed it under power reactor criterion.
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118 1 And we moved it out there to be where all of the other 2 facilities would be other than power reactors. Next 3 --
4 MEMBER SUNSERI: Duane, let me ask you a 5 question. Joy, did you have a question? Did you want 6 to ask him?
7 MEMBER REMPE: It's not on this point. It 8 was actually an earlier one. But --
9 (Simultaneous speaking.)
10 MEMBER SUNSERI: Okay.
11 MEMBER REMPE: Well, I'll ask it later 12 when --
13 MEMBER SUNSERI: Okay. Go ahead.
14 MEMBER REMPE: Oh, okay. Well, since 15 we've interrupted and you're not -- I thought you had 16 a question on item 6.
17 MEMBER SUNSERI: No, no, I was --
18 MEMBER REMPE: Okay.
19 MEMBER SUNSERI: I was stopping him so, 20 because I thought you had a question.
21 MEMBER REMPE: I did. It was on 5 I 22 believe where you talked about there are a couple of 23 facilities that you left the 30-day timely renewal 24 provision in there. I've forgotten now if this was in 25 the original review when we did the letter a while NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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119 1 ago.
2 But if it's only a couple of facilities 3 and in light that it's hard for the staff to turn 4 things around in 30 days, is it wise to leave that as 5 a, to leave it in? I mean, it was a couple of 6 exceptions is what I think I heard you say. And 7 should -- the two years is really where you want to 8 go, right?
9 MR. HARDESTY: So the specific issue is 10 that the new regulation would, as it was written in 11 the proposed rule would have established a two-year 12 timeframe.
13 MEMBER REMPE: Right.
14 MR. HARDESTY: The one particular facility 15 will be within about a year of timely, needing to 16 submit their application. They won't be eligible for 17 timely renewal because it's less than two years the 18 way it was written.
19 So, basically the flow of 2.109 the way 20 it's written is, unless you're this or this or this, 21 it falls out to 30 days.
22 So we left that waterfall in so that when 23 this particular facility looks at that regulation for 24 applicability it automatically goes down to 30 days.
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120 1 regulations when they do come for license renewal.
2 MEMBER REMPE: And no other facility will 3 ever fall into that category in the future is what I'm 4 trying to get to. It was just this one.
5 MR. HARDESTY: Correct.
6 MEMBER REMPE: And I just wanted to make 7 sure I understood that.
8 MR. HARDESTY: Yeah.
9 MEMBER REMPE: Thank you. Sorry --
10 MEMBER SUNSERI: No, no, it was a good 11 question. So they built in the transition period into 12 the regulation so that you didn't have to deal with an 13 exception afterwards or something, right?
14 MR. ADAMS: That's correct, because right 15 now, you know, when the rule would become effective 16 they would already be within two years of submitting 17 an application.
18 MEMBER SUNSERI: Right.
19 MR. ADAMS: So --
20 MEMBER SUNSERI: Thank you.
21 MR. HARDESTY: Okay. The seventh 22 objective is to extend the applicability of 10 CFR 23 50.59 to NPUFs that have had their fuel removed from 24 their site in preparation for decommissioning.
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121 1 whose license were amended to reflect permanent 2 cessation of operations and that no longer had fuel on 3 site because these facilities have returned their fuel 4 to the Department of Energy.
5 The former language stated that 50.59 6 applied to licensees whose license has been amended to 7 allow possession of nuclear fuel but not operation of 8 the facility.
9 So what the staff had to do when we 10 reached that situation was we would essentially write 11 a license condition to give them the same 50.59 12 allowance that the regulations would normally do. So 13 this is just simply an administrative change to the 14 wording to prevent that and make 50.59 applicable to 15 all facilities regardless of their status for the 16 fuel. Next slide.
17 Objective 8 clarifies the existing 18 environmental reporting requirements. The NRC is 19 required to prepare either an environmental impact 20 statement or an environmental assessment as 21 appropriate for all licensing actions pursuant to 10 22 CFR Part 51 unless a categorical exclusion applies.
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122 1 or a supplement to a previously provided environmental 2 report to assist the NRC in preparing the National 3 Environmental Policy Act documentation.
4 A new section was added to 10 CFR Part 51 5 to clarify the NPUF environmental reporting 6 requirements. 51.56 clarifies that an applicant's 7 existing requirement for meeting the provisions of 8 51.45.
9 Again, the change is not a new 10 requirement. It's just for regulatory certainty we 11 wanted to provide clarity such that it was clear in 12 the new requirements that environmental report 13 submissions were required from the applicants for 14 licensing actions. Next slide.
15 And finally, the ninth objective is to 16 eliminate NPUF financial qualification information 17 requirements. Before this final rule, 50.33(f) of the 18 Code of Federal Regulations required NPUF licensees 19 that requested license renewal to submit the same 20 financial information that was required in an 21 application for an initial license.
22 In 2004, there was rulemaking where the 23 NRC discontinued financial qualification reviews for 24 power reactors at the license renewal stage except in 25 very limited circumstances. The Commission at that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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123 1 time stated that the NRC had not found a consistent 2 correlation between licensees' poor financial health 3 and poor safety performance.
4 So, if the licensee postpones inspection 5 repairs that are subject to NRC oversight, the NRC has 6 the authority to shut down the reactor and take 7 appropriate action if there is a safety issue. So 8 that's independent of any financial information or 9 qualifications.
10 So, on a similar reasoning, we determined 11 that it was valid for NPUF licensees seeking license 12 renewal to also be excluded from this NPUF, or rather 13 this financial qualification requirement.
14 At the NPUF sites, the NRC's inspection 15 enforcement programs serve as an important tool for 16 evaluating licensee performance and assuring the safe 17 operation. And the inspection program examines all 18 aspects of facility operation to ensure they're safe.
19 The NRC is similarly not aware of any 20 connection between an NPUF's financial qualifications 21 at license renewal and the safe operation of the 22 facility.
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124 1 renewal application.
2 And so the elimination of NPUF license 3 renewal financial qualification requirements is 4 recommended for, or is listed as part of the draft 5 final rule to reduce the burden associated with 6 license renewal applications while still enabling the 7 NRC to obtain the information necessary to conduct its 8 review for license renewal. Next slide.
9 MR. ADAMS: Next slide. So the staff made 10 changes in the draft rule to arrive at the final rule.
11 And that was as a result of public comments and work 12 group considerations. So this slide summarizes the 13 more significant changes.
14 So we revised the proposed definition of 15 non-power production and utilization facility to 16 exclude a production facility designed or used 17 primarily for the formation of plutonium or uranium-18 233 or designed or used for the separation of the 19 isotopes of plutonium.
20 Based on a comment from this, we revised 21 the existing definition of non-power reactor, research 22 reactor, and testing facility to base the definitions 23 on radiological risk rather than reactor power level.
24 This is the most significant change made from the 25 proposed rule.
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125 1 Where appropriate, we made conforming 2 changes to the terms and definitions throughout 10 CFR 3 Chapter 1 to add, correct, or standardize the 4 terminology and definitions.
5 The proposed 10 CFR 50.135 was revised so 6 that renewed licenses will be effective immediately.
7 Time for the licensee to implement the renewed license 8 would be determined on a case-by-case basis instead of 9 by rule to allow more licensee flexibility in 10 operation.
11 We also clarified the proposed 10 CFR 135 12 to maintain up to a 40-year term for renewed licenses.
13 The wording of the draft regulation inadvertently 14 could limit license terms to 30 years.
15 We also maintained the 30-day timely 16 renewal provision for facilities licensed under 17 Section 104(a) and (c) of the Atomic Energy Act that 18 still needed to undergo license renewal to be subject 19 to a non-expiring license.
20 Finally, we revised the location within 10 21 CFR 50.34 of the accident dose criterion. We realized 22 that we could place the criterion in the section of 23 50.34 that would allow greater clarity for the 24 application. Next slide.
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126 1 summarizes the nine final --
2 MEMBER KIRCHNER: Al, just a minor point, 3 why did you stick with testing facility? Testing 4 facility to me is rather vague. Why didn't you call 5 it reactor testing facility or test reactor or 6 something?
7 Is there some historical legal basis for 8 that or -- I mean, testing facility, there are a lot 9 of reactor-related testing facilities that don't have 10 radioactive sources or don't use a test reactor.
11 MR. ADAMS: Yeah, no, we didn't. And, 12 indeed, you know, I completely understand what you're 13 saying, because in the past we did look at a petition 14 for rulemaking to change the terminology.
15 All I can tell you is that in the 16 regulations there was testing facility, testing 17 reactor. They call themselves test reactor. For no 18 good reason, we left it alone.
19 MEMBER KIRCHNER: Okay. That's it. Thank 20 you.
21 MEMBER REMPE: So, while you're, again, 22 interrupted. Let's talk about what you did in the 23 past when they had to submit their financial 24 qualification updates.
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127 1 facility. Did they used to say, yeah, we had this 2 money when we got it licensed and we know that prices 3 have increased, so they included the increase in 4 price?
5 MR. ADAMS: So the financial requirements 6 for decommissioning are in 50.75 and decommissioning 7 is in 50.82. Those aren't changing. Those 8 requirements aren't changing. The financial --
9 MEMBER REMPE: Oh, okay.
10 MR. ADAMS: The financial requirements 11 we're talking about is that as part of the license 12 application you would have to tell us normally for the 13 first five years of the renewed license where you were 14 getting your money from, how you were spending your 15 money.
16 MEMBER REMPE: Okay.
17 MR. ADAMS: So it was basically a pro 18 forma financial statement.
19 MEMBER REMPE: Okay. So they still have 20 to show they can --
21 MR. ADAMS: They still have to show 22 capability to fund decommissioning in accordance with 23 the regulations. And there's a requirement to keep 24 that cost estimate up-to-date.
25 MEMBER REMPE: Good. Thank you.
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128 1 MR. ADAMS: That's not changing.
2 So this is our final slide. It summarizes 3 the nine final rule change areas of the NPUF rule 4 showing the facilities each of the changes are 5 applicable to.
6 Along with Louise, I'd like to recognize 7 the work of the working group. They put in many long 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, lots of discussion and very thoughtful 9 discussion to address the comments that were made from 10 the public and also to go through the proposed rule 11 and make sure it was the best rule we can create.
12 With that, I'll turn the presentation back 13 to Bob to discuss moving forward.
14 MR. BEALL: Okay. Thank you, Al. So 15 where are we with the final rule? Currently, the 16 draft final rule is in formal concurrence. At the, 17 towards the end of February, the staff will get 18 comments from the division level and NRC management.
19 We also plan on having another public 20 meeting towards the end of February. And this public 21 meeting is to get last minute feedback on the proposed 22 implementation schedule of the draft final rule from 23 the public.
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129 1 goes towards the Commission. And speaking of the 2 Commission, the package is due by June of this year to 3 them. And right now we're on schedule to meet that 4 date.
5 With that, the three of us will be happy 6 to take any further questions from the Committee.
7 MEMBER SUNSERI: Members, any additional 8 questions for the group? None? All right.
9 So let's open the phone lines. And while 10 we're doing that, we'll call for any comments from the 11 audience. Members of the public in the audience, 12 please come to the podium and state your name.
13 Nobody? Oh, here comes one.
14 MR. NEWTON: I'm Tom Newton from the 15 Center for Neutron Research. I just kind of wanted to 16 reiterate my comments that I did with the subcommittee 17 a couple weeks ago, is if this rule is properly 18 implemented, the TRTR community, both the research 19 reactor community and others, feel like this is a 20 win/win. It will reduce burden for both of us without 21 having any really safety consequence.
22 MEMBER SUNSERI: Thank you. Any other 23 comments from the audience?
24 Okay. We'll turn to the phone line now.
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130 1 make public comments? Please state your name and make 2 your comment.
3 Is anybody on the phone line that can hear 4 this, please just speak up because it was my 5 understanding that there was somebody that wanted to 6 make a public comment.
7 Thank you. All right. One last chance.
8 Any member of the public on the phone line that would 9 like to make a comment, please do so at this time.
10 All right. Well, that's it. We'll close the phone 11 line.
12 With no further questions, we'll turn it 13 back to you, Mr. Chairman.
14 CHAIRMAN RICCARDELLA: Okay. Thank you, 15 Matt. We have about a half an hour. And I understand 16 that we have a letter ready to meet on this topic.
17 MEMBER SUNSERI: That's correct. We have 18 a draft letter. We can --
19 CHAIRMAN RICCARDELLA: Okay. We're no 20 longer on the record.
21 (Whereupon, the above-entitled matter went 22 off the record at 11:28 a.m. and resumed at 1:02 p.m.)
23 CHAIRMAN RICCARDELLA: Okay, the meeting 24 will convene. The topic is --
25 MEMBER CORRADINI: Okay, shall we get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 started?
2 CHAIRMAN RICCARDELLA: Yes, Mike.
3 MEMBER CORRADINI: Okay, were in a 4 session that is going to be talking about NuScale 5 Chapter 2 and 17. This is our containing Phase 3 6 review of NuScale With Open Items.
7 And, what Ill do is Ill turn it over to 8 NRO, Dr. Chowdhury will lead us through at least the 9 first part of it.
10 And then, we have staff to support him if 11 we have detailed questions.
12 Dr. Chowdhury?
13 DR. CHOWDHURY: Yes, good afternoon. My 14 name is Prosanta Chowdhury. Im the Project Manager 15 for Chapter 2 of the NuScale Design Certification 16 Application review.
17 I have been with the NRC about 14 years 18 and my background is, Im in -- I have a nuclear 19 engineering degree, Masters degree, and also on -- in 20 electrical engineering.
21 Prior to joining the NRC, I worked for the 22 State of Louisiana in the radiation protection area 23 for 18 and a half years.
24 At the NRC, I joined the Project 25 Management Group in 2008, so I have been there for ten NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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132 1 years now.
2 What I plan to do today is to go over the 3 high level of findings that the staff presented at the 4 ACRS Subcommittee meeting on Chapter 2 on December 18, 5 2018.
6 And so, and then, if there are any 7 specific questions the members may have, then we have 8 the staff present in the audience to answer those 9 questions.
10 Okay, this is slide number two. On 11 December 18, 2018, the staff presented to the ACRS 12 Subcommittee Chapter 2, the following topics.
13 The topics are geography and demography, 14 which is Section 2.1 of the Standard Review Plan; 15 Nearby Industrial, Transportation and Military 16 Facilities, Section 2.2; Meteorology Section 2.3; 17 Hydrology Engineering is Section 2.4; and Geology, 18 Seismology and Geotechnical Engineering is Section 2.5 19 of the SRP.
20 I want to make a note here that the staff 21 review that was presented on December 18, 2018 was 22 based on Design Certification Application Revision 1 23 submitted by NuScale on March 15, 2018.
24 We also received later Revision 2 of the 25 Design Certification Application, but the staff, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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133 1 because of the scheduling and timing, the staff did 2 not review that part to influence the SE. So, that 3 will come later. At this point, our focus is on 4 Revision 1.
5 Topics and conclusions for SRP Section 2.1 6 at Geography and Demography and also SRP Section 2.2, 7 Nearby Industrial, Transportation and Military 8 Facilities, COL items provided in the Design 9 Certification Application have been found to be 10 acceptable.
11 The COL Applicant referencing the NuScale 12 power plant design clarification should describe and 13 address site specific geographic and demographic 14 statistics as part of COL item 2.1-1.
15 Nearby Industrial, Transportation and 16 Military Facilities to demonstrate that the design is 17 acceptable for each potential accident or provide site 18 specific design alternatives as part of COL item 2.2-19 1.
20 Site specific information in a COL 21 application should be bounded by the design 22 parameters.
23 MEMBER REMPE: Excuse me for a minute, I 24 missed the Subcommittee meeting. But I was curious 25 from the transcript which I read after the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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134 1 Subcommittee meeting where the staff said they 2 evaluated six sites and only one of the six sites were 3 bounded by the site parameters that are based on the 4 EPRI users or utility requirements document.
5 Correct, thats what --
6 DR. CHOWDHURY: Thats in Section 2.3 I 7 believe. And Mike Mazaika is present in the audience.
8 MEMBER CORRADINI: I think that was 9 strictly for the LPZ and EAB calculations. The staff 10 did an audit on six.
11 DR. CHOWDHURY: Yes, thats in Section 12 2.3.
13 MEMBER REMPE: Right. Okay, so Id note 14 that in --
15 MEMBER CORRADINI: But not on these.
16 MEMBER REMPE: Okay. So, I should wait 17 until -- okay. Heads up, go ahead.
18 DR. CHOWDHURY: Okay.
19 So, now we are talking about 2.3, 20 Meteorology. And, for -- there are five subsections 21 there, 2.3.1, 2.3.2., 2.3.3, 2.3.4 and 2.3.5.
22 So, each of them climatology, 2.3.1; 23 precipitation, winds, rain, snow and ambient dry and 24 wet-bulb temperatures are generally representative of 25 a reasonable number of potential plant site locations.
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135 1 However, because design may be deployed in 2 remote locations or at sites subject to harsh weather 3 conditions, some postulative parameter values may be 4 challenged.
5 And, these were discussed in detail at the 6 Subcommittee meetings.
7 Local meteorology and onsite 8 meteorological measurements are the COL Applicants 9 responsibility and theyll be responded or provided by 10 the COL Applicant.
11 So, would you like to bring up your 12 question at this point?
13 MEMBER REMPE: Okay, so, again, the staff 14 did an audit and only one out of six sites were found 15 to be bounded by what was in the EPRI utility 16 requirements document.
17 DR. CHOWDHURY: The staff did a 18 calculation by themselves. So, I would request Mike 19 Mazaika to come forward please to the microphone or 20 Jason White, one of them.
21 MEMBER REMPE: So, just to give the whole 22 extent of my question, Chapter 19 did their analysis 23 for the risk assessment using Surry parameters.
24 So, Im just curious in the one out of six 25 or the six ones you did with the audit, did you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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136 1 include Surry?
2 MR. WHITE: One moment.
3 MEMBER CORRADINI: If I just want to 4 clarify to get precisely to -- so, what the staff did 5 was on the accident releases. They chose the 6 specified NuScale short distance and then chose six 7 sites and one of the six passed at that short 8 distance.
9 MEMBER REMPE: Right. But didnt they 10 assume -- did they look -- Im not sure what they did 11 in the audit. But did they look at the X/Qs for all 12 six sites and said, hey, only one out of six sites are 13 bounded by whats in the EPRI document?
14 MR. WHITE: Yes, thats correct.
15 MEMBER REMPE: Okay, of the six sites, did 16 you include Surry?
17 MR. WHITE: Thats what Im checking, one 18 moment, please.
19 MEMBER REMPE: And then, at some point, 20 Id like to hear from NuScale, are there any -- weve 21 only looked at a few of the chapters and were going 22 to see a third set of site parameters in the DCD or 23 was it just limited to Surry and the EPRI recommended 24 values?
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137 1 NuScale Power.
2 MEMBER CORRADINI: Youre going to have 3 speak up, please, Mark.
4 MR. SHAVER: Sorry, is this better?
5 MEMBER CORRADINI: Yes.
6 MR. SHAVER: All right. So, what NuScale 7 did was took meteorological data from airports all 8 over the U.S. and picked the value between the 80th 9 and 90th percentile, the meteorological data was the 10 80th to 90th percentile and did --
11 MEMBER REMPE: Im having trouble hearing 12 you.
13 MEMBER CORRADINI: Youre going to have to 14 speak a little more clearly and a little slower or 15 else, we cant understand you.
16 MR. SHAVER: All right. So, what NuScale 17 did to develop the X/Qs for accident doses is looked 18 at meteorological data all over the United States from 19 airports.
20 And, we took the 80th to 90th percentile 21 site which ended up being Sacramento.
22 And then, we took that meteorological data 23 to develop X/Qs for the accident scenarios.
24 MEMBER REMPE: So, is this for Chapter 2 25 what you did? Because in Chapter 2, I thought you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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138 1 attributed it to the EPRI URD.
2 But now, youre telling me you 3 independently looked at all of these sites?
4 MR. SHAVER: Yes, we independently looked 5 at sites. And this was at Chapter 2 X/Qs that were 6 used in Chapter 15 analysis.
7 And we did that because of our shorter 8 site boundary distance. We used the ARCON96 code 9 modified to do the X/Qs.
10 MEMBER REMPE: So, Im having a little 11 trouble still hearing you, so youre tell me on 12 Chapter 2 and Chapter 15, you did your own assessment 13 and picked the 85th or something percentile values of 14 the existing sites in the U.S. today, is that what you 15 said?
16 MR. SHAVER: The meteorological data, that 17 is correct. And then, we used that meteorological 18 data in the ARCON code to develop X/Qs for our shorter 19 site boundary.
20 MEMBER REMPE: Okay. So, then, again, Im 21 just repeating what I read in Chapter 19 in the open 22 version, it says you used Surry.
23 So, how does this 85th percentile compare 24 with Surry?
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139 1 that comparison.
2 MEMBER DIMITRIJEVIC: Joy, as I pointed in 3 the email, the Surry data was for some of the 4 population by 2060 and also economical effects.
5 I didnt find reference to Surry data in 6 anything else in Chapter 19.
7 MEMBER REMPE: I thought they did it when 8 they actually evaluated the does to get the 9 consequences.
10 MEMBER CORRADINI: I dont -- so, two 11 things. One, NuScale, if we start getting into areas 12 that are in proprietary, you have to stop us and well 13 save for closed session. Thats point one.
14 Point two is, I think what Vesna says is 15 correct to the extent that its open information.
16 MEMBER REMPE: Okay, so, one --
17 MEMBER CORRADINI: What they did by the 18 number of sites, the number of sites as Matt said, 19 80th to 90th percentile and then staff came back with 20 an audit at six reactor sites and found at a short 21 distance only one out of six passed using that tool 22 and that meteorological data from those six sites.
23 So, two different totally different 24 analyses approaches.
25 MEMBER REMPE: So, I guess Id like --
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140 1 MEMBER DIMITRIJEVIC: But also Chapter 19 2 has the meteorological data for the tornados, you 3 know, for external events. And theyre not for 4 meters, you know, theyre not -- the ones I tracked 5 are not are equivalent to Chapter 2.
6 So, Im not -- and plus, I dont remember, 7 did you look in the separate document to see does EPRI 8 document gives the all the data that they provide in 9 Chapter 2 table?
10 MEMBER REMPE: Okay, so again, Im really 11 getting confused because they did their own 12 assessment. I did see attributes in the staff 13 documents to what NuScale did saying that it was the 14 EPRI.
15 I thought it was actually in the NuScale 16 document, too, theyd used the EPRI UFRDX. But, they 17 did not, is -- I was confused on that totally. They 18 did not ever use the EPRI document?
19 MR. WHITE: So, from the staffs 20 perspective, Im not sure what NuScale used for their 21 calculations.
22 We did not do a direct comparison to the 23 Surry data set. We used six data sets that we had in 24 house and we did an independent calculation using the 25 ARCON96 methodology with those six meteorological data NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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141 1 sets and we compared our numbers to the numbers that 2 they provided as their site parameters.
3 MEMBER REMPE: So, I guess where Im 4 coming from and Im not quite sure I fully understand 5 what youre saying, Vesna. But, to me, at some point, 6 the COL Applicant has to come in and compare their 7 particular site with all the assumptions that were 8 made by NuScale.
9 And, where Im trying to go with this is, 10 are there two sets of assumptions for -- or two 11 different type of site evaluations for parameters?
12 Or, is that list going to be very 13 convoluted to compare with for different analyses they 14 need to compare different things?
15 MR. WHITE: Well, Im not quite sure for 16 the Chapter 19 analysis that you mentioned. But, for 17 Chapter 2, were only comparing their results to the 18 site parameters that they provided for Chapter 2.
19 MEMBER REMPE: Okay. So, Im not quite --
20 I had trouble hearing what youre saying. Yes, could 21 you --
22 MEMBER CORRADINI: You have to speak 23 closer to the mic.
24 MEMBER REMPE: Yes, its --
25 MEMBER CORRADINI: Its mushy in here.
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142 1 MR. WHITE: Okay. Sorry about that.
2 Were only looking at the site parameters 3 that they provided for Chapter 2. So, when we did our 4 independent verification, we were looking at our 5 results versus the values that they provided for 6 Chapter 2.
7 Im not quite sure what they provided for 8 Chapter 19.
9 MEMBER REMPE: Okay. So, thats the point 10 Im going to is that I want to know what exactly was 11 used in Chapter 19 so its clear to everybody that the 12 -- what needs to be considered for the different 13 analyses.
14 And I guess I -- maybe this has happened 15 in other GCs where they used two different site 16 parameters type things?
17 MEMBER CORRADINI: So, if I might try, I 18 mean, I dont want to read from the SER because it is 19 a proprietary SER, but I think as the staff member 20 noted, it was essentially, and as NuScale noted, they 21 essentially used the 80th, 90th percentile from a 22 number of sites.
23 They did not consider Surry. They did not 24 consider anything in Chapter 19.
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143 1 calculations at a short distance. The distance 2 matters because you change the methodology relative 3 close to buildings versus far away as the diffusion 4 and the spread of the thing.
5 So, I think thats the open item thats 6 left out there to be considered.
7 MEMBER REMPE: It is, but then, whats 8 considered for Chapter 2 may be different than Chapter 9 19 is the point Im trying to emphasize.
10 CHAIRMAN RICCARDELLA: But in Chapter 19, 11 wouldnt the COL Applicant have to do his own PRA and 12 consider the specific --
13 MEMBER CORRADINI: Yes.
14 MEMBER REMPE: Right.
15 CHAIRMAN RICCARDELLA: -- parameters --
16 site parameters that are applicable to their site?
17 MEMBER DIMITRIJEVIC: Right, because --
18 MEMBER REMPE: But they wont ever --
19 CHAIRMAN RICCARDELLA: They just used 20 Surry as an example.
21 MEMBER REMPE: They wont ever say, well, 22 its bounded because -- and theyll -- by whats in 23 Surry here versus whats in the 80th percentile?
24 MEMBER CORRADINI: I guess my -- again, I 25 dont want to speak for the staff, but my sense is, in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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144 1 a sense, this is a red herring.
2 They have a calculation. The calculation 3 is an open item because, at these close distances, it 4 does not meet the EAB and the LPZ proposed.
5 So, they either have to go back and --
6 NuScales got to go back and redo the analysis and to 7 staffs approval or change the distance and show that 8 at some distance you then meet the site parameters.
9 But, I think thats it. I dont think 10 looking at Chapter 19 at this point is going to 11 benefit us at all.
12 MEMBER REMPE: I just, again, Ill 13 probably bring it up again in Chapter 19 space, but it 14 seems like theres different assumptions used for 15 different places. And I just am wondering about that.
16 Okay?
17 CHAIRMAN RICCARDELLA: But we reviewed the 18 PRA a few months ago.
19 MEMBER REMPE: Preliminary review, yes.
20 CHAIRMAN RICCARDELLA: Preliminary review.
21 It was the preliminary PRA but it was just an example 22 of -- it wasnt in the PRA.
23 MEMBER DIMITRIJEVIC: Well, the PRA, like 24 everything else, has to be conforming the qualified, 25 you know, phase and all the assumptions on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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145 1 locations and the thing will have to be confirmed.
2 I dont see any contradiction actually, at 3 least what I checked with what youre saying. Because 4 the only problem will be if you have a contradictory 5 assumption which are important from my point.
6 But since they all were used in -- and I 7 didnt see this other Surry application. So, the 8 Surry data, it was used in some but is not used in 9 Chapter 2.
10 Well, my point is, I dont think we need 11 to be concerned because all of those assumptions still 12 have to be confirmed in the qualified.
13 MEMBER REMPE: I agree with you that 14 theyll have to be confirmed, but I dont -- Im 15 trying to emphasize the point, theres two different 16 sets of assumptions is all Im trying to emphasize.
17 MEMBER DIMITRIJEVIC: But they --
18 MEMBER REMPE: And I was curious, are 19 there going to be a third set? I mean, how many 20 different site parameters -- or do they pick for 21 different chapters is where Im kind of going.
22 MEMBER CORRADINI: Again, Ill just 23 repeat, I think, to focus just on Chapter 2, staff has 24 left it an open item in terms of the source term 25 itself and the methodology used for short distances.
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146 1 And, until NuScale comes back and confirms 2 that theyve sorted out the methodology or show that 3 they meet the method -- they use the methodology as 4 stated at a longer distance, it remains an open item.
5 MEMBER REMPE: Okay.
6 MEMBER CORRADINI: I think -- Im looking 7 at you -- I think Ive said it --
8 MR. WHITE: Yes, thats accurate.
9 MEMBER REMPE: Okay.
10 MEMBER CORRADINI: Okay.
11 MEMBER REMPE: Thank you.
12 DR. CHOWDHURY: So, the open item, Im on 13 slide number five.
14 On slide five, we mention just talked 15 about the open item, its Open Item 02.03.04-1. And, 16 again, we are currently evaluating X/Qs in meteorology 17 to determine if the methodology is acceptable for 18 calculating design assess and offsite X/Q values in 19 parameters at EAB and LPZ in relation to NuScale 20 design or a COL Applicant reference in the NuScale 21 design.
22 The staff found that the Applicant 23 provided onsite X/Qs site parameters values at the 24 main control room and technical support center doors 25 and heating, ventilation, air conditioning intake that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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147 1 were representative of a reasonable number of sites 2 that may be considered for a COL Application.
3 As for the long-term accident dispersion 4 estimates for routine releases that found that the 5 long-term routine release site parameter values 6 selected by that Applicant are representative of a 7 number of -- a reasonable number of sites that have 8 been already considered for a COL Application.
9 MEMBER KIRCHNER: So, I was asking my 10 colleagues, maybe it was before my time on the 11 Committee, are you going to then come before us with 12 this accident source term methodology review?
13 DR. CHOWDHURY: Will that be presented?
14 MEMBER KIRCHNER: Yes.
15 DR. CHOWDHURY: Yes, it will be.
16 MEMBER KIRCHNER: Okay, thank you.
17 MEMBER CORRADINI: So, and again, just so 18 I have it clear, theres two things that sit in the 19 open item. One is the methodology for EAB and LPZ and 20 the source term that is yet to be --
21 DR. CHOWDHURY: Right.
22 MEMBER CORRADINI: -- the final? Okay.
23 DR. CHOWDHURY: Thats correct.
24 MEMBER CORRADINI: All right.
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148 1 report.
2 MEMBER CORRADINI: Thank you.
3 DR. CHOWDHURY: Hydrology Section 2.4 in 4 all areas of hydrology, the Applicant provided 5 adequate site parameters as well as COL items 2.0-1 6 and 2.4-1.
7 So, essentially, a COL Applicant 8 referencing the NuScale Power Plant Design 9 Certification should provide information sufficient to 10 demonstrate that the actual site characteristics 11 described in this application falls within the range 12 of site parameter values consistent with the 13 stipulation in COL items 2.0-1 and 2.4-1.
14 And the staff finds this, including the 15 stipulations in COL items acceptable for 2.4.
16 Section 2.5, Geology, Seismology, 17 Geotechnical Engineering, again, in all areas of this 18 topic, the Applicant provided adequate information 19 including COL item 2.5-1 that specifically belongs to 20 that section.
21 And also referenced COL items for Section 22 3.7 and 3.8. So, those COL items, 3.7-3, 3.7-5 and 23 3.8-6, 3.7-8 that -- and specified that a COL 24 Applicant referencing the NuScale Design Certification 25 should provide the information sufficient to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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149 1 demonstrate that the actual site characteristics falls 2 within the range of site parameter values.
3 The staff finds the Applicants 4 information, including stipulations in all those COL 5 items acceptable.
6 And, I think staff made some -- Weijun, 7 you are here, right, in the audience?
8 Okay. So, the -- since we presented at 9 the Subcommittee meeting some change -- some 10 corrections are made in this -- on those drafts or 11 some consistency, right?
12 Okay, would you please come forward and 13 explain what the changes were?
14 MEMBER CORRADINI: Your comments only get 15 on the record if you come forward.
16 MR. WANG: Okay, Weijun Wang.
17 MEMBER CORRADINI: And you have to speak 18 right in to that mic, otherwise, we cant hear you, 19 Im sorry.
20 MR. WANG: Okay. Im Weijun Wang, 21 Geotechnical Engineer in the NRO. I am the reviewer 22 of the NuScale Section 2.5 with other of my 23 colleagues.
24 Okay, this chart here, its a little bit 25 different from what we presented at the Subcommittee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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150 1 because the figure on the left, that one, because here 2 we said we present the chart for the -- so far the 3 design seismic response spectrum for the horizontal 4 plot.
5 And in Subcommittee presentation, 6 actually, we presented on the left one, it was 7 vertical components.
8 So, now the -- on the left one, its 9 correct. Its horizontal components certified the 10 design seismic response spectrum. Thats the only 11 difference.
12 CHAIRMAN RICCARDELLA: Its horizontal in 13 both the right -- in the left and the right now?
14 MR. WANG: Right. The -- in the design, 15 it had provided both horizontal and vertical, the 16 components.
17 And, as an example, we only provide 18 horizontal. The only different is the anchor, the 19 acceleration, its like in the horizontal one, it was 20 .4g and the vertical was .5g. Thats the major 21 difference here.
22 CHAIRMAN RICCARDELLA: Okay, thank you.
23 DR. CHOWDHURY: Okay, thats all the --
24 MEMBER CORRADINI: Do you want to move on 25 now to NuScale?
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151 1 So, for the Committee, there were 2 questions in the Subcommittee about ODI, so I think 3 NuScales presentation is going to try to specifically 4 address some of our questions.
5 MR. INFANGER: Good afternoon, Im Paul 6 Infanger. Im Regulatory Affairs at NuScale.
7 My background is a Masters degree in 8 nuclear engineering and Ive been in licensing for 35 9 years, 25 years at the operating fleet, about 10 years 10 in new reactors and the last 4 years, Ive been at 11 NuScale.
12 Next to me is the lead presenter is Neil 13 Olivier, hell give a little background.
14 MR. OLIVIER: Yes, my name is Neil 15 Olivier. Im the Corporate Services Director at 16 NuScale.
17 My background is mainly in operations 18 previous to NuScale. Ive got licenses on Limerick 19 Generating Station in Columbia and I worked at San 20 Onofre before that. And I was in the Navy before 21 that.
22 And, if you want me to go ahead, I can 23 start presenting.
24 So, I was asked to come today to give a 25 background and an overview of NuScales ODI program.
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152 1 So, our ODI program is mandated from the quality 2 assurance -- NuScales quality assurance program is 3 based on NQA-1.
4 Specifically, Requirement 3, Section 500, 5 it allows for the deferral of design verification 6 activities provided that we identify and control those 7 items.
8 Those ODIs are a form of engineering 9 assumptions that are controlled --
10 MEMBER RAY: Wait, lets stop here --
11 MR. OLIVIER: Okay.
12 MEMBER RAY: -- for a bit.
13 What its based on, of course, this is the 14 boiler and pressure vessel code and there are a lot of 15 things not covered by the boiler and pressure vessel 16 code. But thats a minor point.
17 The inspection report which is a public 18 document, so I wont refer to the SER, is, as you 19 know, uses Appendix B as its criterion. It 20 acknowledges the source of requirements.
21 But criterion 3 and 16 are basically the 22 same as in boiler and pressure vessel code as it is in 23 Appendix B. And Appendix B is, I think, the thing we 24 should use as our reference here, particularly when 25 were talking about design certification.
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153 1 Now, the inspection report says that 2 theres a NuScale -- they refer to a memo, but lets 3 just call it a procedure and policy that identified 4 ODIs necessary for closure prior to support the DCA 5 submittal.
6 And there were ODIs not necessary to be 7 closed prior to the DCA submittal.
8 So, theres a distinction that I believe 9 NuScale has between the things that are required to 10 support DCA submittal and those that can be deferred.
11 And, the issue that we want to, I think, 12 get clarity around is the NRC inspection report also 13 refers to sufficient closure of ODIs to allow a 52.50 14 -- a reasonableness finding to be made.
15 And its in that domain that we want to 16 get clarity.
17 So, the issue of deferral isnt a 18 question, the question is, what do we do -- what do we 19 need in order to support the design certification and 20 what do we do to identify those things which we dont 21 need for design certification but which are needed to 22 support operability perhaps well down the road. How 23 is that distinction made from NuScales point of view?
24 MR. OLIVIER: So, the memo you speak of, 25 the ODIs that we classified as not -- we had to close NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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154 1 them for DCA which are all closed. Those address 2 content analysis or results of conclusions or an 3 engineering deliverable is needed for DCA.
4 So, the ones that are open are categorized 5 in the latter category that dont need to be closed 6 for DCA.
7 So, I dont know how to word it any other 8 way than that.
9 MEMBER RAY: Well, at the time of the 10 inspection, there were 173 closed that were considered 11 necessary to close and 1,500 that were open.
12 MR. OLIVIER: There were 1,500 open, they 13 looked at 173 in detail and did not find any 14 conclusion or nonconformances in the inspection.
15 MEMBER RAY: I think were mixing up two 16 things here. Let me just read from the inspection 17 report.
18 NuScale identified 173 ODIs that required 19 closure, blah, blah, blah. The NRC inspection team 20 reviewed 170 from the list of 1,563.
21 But, at the time, they recorded, they can 22 be wrong, of course, but that there were 173 that were 23 identified as needing to be closed and they were 24 closed, as you said.
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155 1 happened before the --
2 MEMBER RAY: So, hows the distinction 3 made because we have to make a similar distinction.
4 We have to come to some conclusion.
5 MR. OLIVIER: Right, and I was going to go 6 into that as far as the interactions between the NRC 7 and NuScale and theyve done various chapter audits.
8 They did the QA inspection. I believe theres another 9 Q&A inspection scheduled.
10 Theyve reviewed them in RAIs. Theyve 11 reviewed thousands of documents and yet to tell us 12 that theres an ODI that needed to be closed prior for 13 DCA. Its just we have closed the ones necessary for 14 the DCA.
15 The ones open, and I can provide examples 16 and give you some statistics on whats open now. I 17 dont think anybodys --
18 MEMBER RAY: Well, I think were trying to 19 get what the criteria are both you guys and, of 20 course, well talk to the staff as well, for what it 21 is that needs to be closed.
22 Now, to an extent, what needs to be closed 23 is a function of how visible the ODIs are. So, for 24 example, if you have ITAAC that covers, and Im not 25 suggesting thats the right solution, but if you have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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156 1 ITAAC that cover ODIs then thats a very visible 2 mechanism for handling those things that are not 3 closed, but what you relied upon in the design 4 certification.
5 MR. OLIVIER: I agree.
6 MEMBER RAY: Thats the way we look at it 7 anyway.
8 And were trying to understand that.
9 There isnt any explanation that we can find. ITAAC, 10 of course, are a perfectly logical and ordinary way to 11 cover things that are not capable of being resolved at 12 the time of certification.
13 And, how many of these 1,500 ODIs, if any, 14 would be subject to having ITAAC established?
15 Well, that depends, in my personal 16 individual judgment, on how visible the tracking of 17 the ODIs is.
18 Theres references here to the ODIs 19 existing at different levels in the design 20 documentation.
21 Now, I think youre going to be able to 22 tell us that you have very solid tracking system for 23 the ODIs that exist and its that that is going to be 24 important in what you say here, so please, emphasize 25 it.
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157 1 MEMBER BLEY: Id like to add something to 2 Harolds question. One thing to know what the ODIs 3 are and track them as they close, its another if they 4 affect other aspects of the design or anything in the 5 DCD such as the PRA. And how are you tracking that as 6 well?
7 You know, if you change one of these 8 assumptions you havent yet settled on, it could 9 affect many other things.
10 MR. OLIVIER: Agreed. The configuration 11 management system is what were relying to make sure 12 that the impact analysis is accurate when we change 13 something. Theres no -- I couldnt tell you that a 14 specific item does or does not affect something 15 without doing an impact analysis which is part of the 16 design verification and design control.
17 The design control system is set up as 18 required by NQA-1 to do that impact analysis to ensure 19 that all changes are -- all impacts are assessed.
20 MEMBER CORRADINI: So, can I take an 21 example? So, lets say, for example, Ill pick this 22 as an example, that you want to have a CVCS pump of 23 some output and you assume so many GPM under normal 24 operation and under accident for injection purposes.
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158 1 by the manufacturer that you eventually have it 2 procured from that its 10 percent less.
3 Explain to me how that then is promulgated 4 through the whatever you call the checking program to 5 make sure that doesnt have an impact either in a 6 Chapter 15 analysis or in a PRA analysis? Can you 7 help me there?
8 MR. OLIVIER: Yes, so the --
9 MEMBER CORRADINI: Is that a good example?
10 MR. OLIVIER: It is. It is and I have a 11 few examples with me, but we can use your example.
12 MEMBER CORRADINI: Okay, thats fine. If 13 youve got an example --
14 MR. OLIVIER: Well, its the same -- those 15 are -- its very similar to what I have --
16 MEMBER CORRADINI: Oh, okay.
17 MR. OLIVIER: -- in that its weight 18 versus a flow.
19 Its that our design control program is 20 managed in a way, whether its in ODI or its a 21 change, say we wanted to change the flow, we would 22 then do an impact analysis against all documents that 23 are related to that function.
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159 1 -- I will call it a reference, but a link inside CMIA, 2 our system, configuration management information 3 system, it will tell me what other impacts there are.
4 The engineer then does the impact analysis 5 and it should inform upon every other document that 6 needs to be changed and every impact from there, it 7 would chain tell us whether the DCA is affected in any 8 fashion.
9 And then, that would drive a change, if 10 needed, we would inform the NRC.
11 MEMBER CORRADINI: Okay. So now, Im 12 going to pick up to be another member who doesnt 13 trust computers.
14 Have you done a check so that you actually 15 invent an ODI that had a significant change and wanted 16 to look for and you expect to an effect over there and 17 you double check that you do see those effects?
18 That the configuration control management 19 system actually says when I change the pump flow or 20 the weight or something, I expect to see a big effect 21 over here and, ergo, I do see the effect? Do you know 22 what Im asking?
23 MR. OLIVIER: Yes, and I dont think weve 24 done --
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160 1 software program actually captures --
2 MR. OLIVIER: So, the software program 3 only lists the impacted documents, the engineer --
4 MEMBER CORRADINI: And the engineer will 5 check it?
6 MR. OLIVIER: -- is required to check 7 every single line item.
8 MEMBER CORRADINI: Okay, okay.
9 MEMBER RAY: Yes, they say very clearly 10 that the design control process, and its a design 11 change --
12 MEMBER CORRADINI: Okay.
13 MEMBER RAY: -- would be or choose --
14 MR. OLIVIER: Yes, we can -- we use the 15 same exact process for an ODI. If an ODI changes, 16 its entered and the change control process is treated 17 like any other change.
18 MEMBER CORRADINI: Okay, thank you, I got 19 it.
20 MEMBER RAY: But, again, whats -- what 21 were struggling with is the idea that certain things 22 are needed to get the design certification and other 23 things are not and how is that distinction made, 24 particularly given that the -- everything you read 25 here is very explicit. Id give you citations, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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161 1 some of them are not where I want to go in terms of 2 documentation.
3 But, in any event, this only applies to 4 the certification process, this, by that I mean, the 5 QA program or the -- its emphasized that were only 6 looking at a program and youre, I know, describing 7 program controls of open design items.
8 The program only applies through design 9 certification. How, unless we are sure, and this is 10 the bottom line for me, that weve listed and 11 identified the ODIs that need to be controlled, how do 12 we know that, yes, theyre going to get handled after 13 design certification?
14 MR. OLIVIER: So, in our database and I 15 reviewed it and Ive reread it multiple times, theres 16 a 1,098 that are explicitly listed. Every one of 17 thems been reviewed and the justification has been 18 reviewed by engineering and another engineer to verify 19 that the justification is sound. Thats for the open 20 design item.
21 Theyve also been reviewed to make sure 22 that we didnt need to have them closed before we 23 submitted the DCA.
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162 1 give you some statistics if youd like them.
2 MEMBER RAY: But, would you accept the 3 idea that the design certification itself needs to say 4 that these items need to be closed in accordance with 5 a program that complies with Appendix B or that your 6 topical report, whatever you want?
7 I mean, does that make sense? I think 8 thats your intent, isnt it?
9 MR. OLIVIER: Its in our -- I cant speak 10 to that whats in -- Tom, maybe you can speak to it, 11 but --
12 MEMBER RAY: Yes, were just looking for 13 some way to make sure that four years down the road, 14 in a situation in which the program youre talking 15 about now may not apply. Theres no obligation to use 16 it, these things are going to get closed.
17 MR. BERGMAN: So, Tom Bergman, Vice 18 President, Regulatory Affairs, NuScale.
19 It isnt necessary to put things that will 20 be required later in the DCA. So, the -- what were 21 seeking approval of is the design thats in the DCA, 22 not a perspective design down the road.
23 So, its strange, but by rule, we can 24 terminate our QA program the day were certified. And 25 then, when COL comes in that uses our information, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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163 1 everything has to be back under Appendix B the day the 2 application is submitted.
3 And then, once that COL is issued, it 4 stops again for us, not for the licensee at that 5 point.
6 As a practical matter, you dont do that, 7 right? Because, especially in our case where youve 8 got a COL coming in right on our heels.
9 But, by rule, were not seeking approval 10 of what the COL will submit, its have we made the 11 case that weve, with reasonable assurance, met the 12 NRCs regulations with the application as its 13 submitted.
14 I get the interest in control --
15 MEMBER RAY: Well, let me stop you right 16 there, because respond to this. The Agency certifies 17 a design and information has been relied upon which 18 includes, I wont say a lot, but includes a fair 19 number of unverified design assumptions.
20 Shouldnt those be part of the 21 certification? I mean, you, yourself, dont want at 22 least some of the ODIs to remain open at the time of 23 certification. Theres a bunch that youve said, 24 these need to be closed. What about the others?
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164 1 exactly our assurance that, although we relied on 2 them, we relied on those assumptions and you cant 3 say, well, no, no, you didnt because of whatever 4 reason. I dont know what it would be.
5 But, lets just say we rely on all of 6 those assumptions and unverified design inputs, how do 7 we then gain the confidence necessary that, in fact, 8 theyre going to be resolved and if there are any 9 changes, I dont have any doubt that itll be -- the 10 changes will be processed under your change procedure.
11 But, its the idea and I could cite to you 12 here comments about how the ODIs exist at various 13 levels in documents and so on. You cant go look at 14 the documents. Youve got to work off of some set of 15 identified ODIs to ever find them later when 16 operability of the systems required.
17 Help us understand which ones you think 18 need to be closed? Which ones can remain open? And 19 how we can be certain that they will be closed?
20 Because we rely on all of them, not just 21 the ones you think need to be closed.
22 MR. BERGMAN: And Ill need Neil to 23 correct me if I misstate, but most of the ones are 24 left open because the information simply doesnt 25 exist. Right?
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165 1 So --
2 MEMBER RAY: Thats what ITAAC do very 3 explicitly.
4 MR. BERGMAN: No, ITAAC -- well, most of 5 these ODIs are not touched by ITAAC.
6 MEMBER RAY: I know that, Im not 7 proposing ITAAC, Im just telling you that thats what 8 ITAAC were established to do in a design certification 9 was to make sure, and I can read the definition to you 10 here if youd like me to, to make sure that the things 11 that could not be verified at the time of 12 certification would be verified before operability.
13 Thats what it is. The inspection test, 14 analysis and, you know --
15 MR. BERGMAN: I have a different view of 16 ITAAC.
17 MEMBER RAY: Acceptance criteria.
18 MR. BERGMAN: Which are to confirm that 19 the design that is built conforms to the design that 20 was proposed, both in the DC and as modified in the 21 COL and is ultimately modified during construction.
22 So, I think the CVCS example is very 23 clear, but that, as you said, would be visible in the 24 DCA.
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166 1 look to Neil for the details, but a component weight 2 is going to be an assumption today because we dont 3 have procured component.
4 That component weight is going to still be 5 an open item at the COL because they still havent 6 procured a component.
7 During construction, theyll procure the 8 component. If the weight, depending on how you 9 characterize the open item, sometimes it can be above 10 than or less than or you just said, you know, 6,000 11 pounds.
12 If it comes in, whether its 5,500 pounds 13 or its 6,500 pounds, thats a change that goes 14 through the change control process.
15 If that change doesnt affect the FSAR, 16 the NRC would only verify it through inspection. They 17 rely on the design control process to make sure the 18 design changes, if weve changed an assumption, the 19 design changes have been properly controlled.
20 If it does affect the FSAR, of course, you 21 know, it goes 50.59 and then you have to evaluate, is 22 it a departure and during licensing or after 23 licensing? Is it a 50.59 licensing change?
24 MEMBER RAY: Truly, we do know. We --
25 MR. BERGMAN: Right.
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167 1 MEMBER RAY: -- weve done all of this 2 ourselves. The problem -- some of us, many times --
3 but the issue thats still unanswered here is, weve 4 got this large number of items, some of them may be --
5 MR. BERGMAN: I disagree its large.
6 MEMBER RAY: -- the table of the weight of 7 a pump thats assumed to be something and it turns out 8 to be something greater, for example. Yes, I totally 9 understand that.
10 But it could be something much different 11 from that as well. There are, I mean, again, I can go 12 through and give examples here, but I dont want to 13 take the time to do it, you know them better than I 14 do, of things that are assumptions relative to system 15 performance.
16 Theyre identified -- we just want to be 17 sure that they are tracked to closure whenever that 18 happens.
19 One way to do it, and the way thats 20 established and accepted so far and one of the 21 certifications that weve done and plants that are 22 under construction today, are ITAAC.
23 But Im not suggesting that here, I just 24 want to get to the point where we say were confident 25 that the ODI are identified, they will be attached in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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168 1 some way to the design certification and they will be 2 tracked to closure whenever that happens.
3 MR. BERGMAN: I do not believe thats ever 4 been done for any certified design by the Agency.
5 MEMBER CORRADINI: So, whats been done?
6 MEMBER RAY: No, I agree with you because 7 people would go back and look at the weight of a pump 8 and say, this is more than was assumed in the design 9 and they would go through 50.59. Absolutely right.
10 The point is, you identify that as an open 11 design item. There are others as well that may be 12 much more significant and subtle than the weight of a 13 pump.
14 MEMBER CORRADINI: But thats --
15 MR. BERGMAN: But thats what --
16 MEMBER CORRADINI: Can I -- hold --
17 because were running out of -- I hate to be the time 18 watcher, but Im watching the time. I want to make 19 sure I get the staff up here on Chapter 17.
20 What I think the back and forth is, is 21 that were trying to find a way that we get confidence 22 in what appears to be a much more sophisticated way of 23 tracking things than weve seen before in other 24 certified designs. Thats my impression.
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169 1 I dont suspect that these things were watched as 2 these are being watched.
3 MR. BERGMAN: I actually agree. I think 4 the only reason this became an issue was because we 5 were the first Applicant to actually compile the list.
6 MEMBER CORRADINI: I didnt say that, but 7 thats the sense that I get, too.
8 MR. BERGMAN: Yes, but the rest of them 9 simply relied on their NQA-1 compliant program to 10 bring it to closure.
11 MEMBER RAY: I dont want to be -- suggest 12 any criticism here of the process.
13 MR. BERGMAN: Sure.
14 MEMBER RAY: Were just trying to marry it 15 up with design certification. So, understand that.
16 But let me tell you, as somebody whos 17 been through this, like I said, for a long, long time, 18 if you come in with a component that differs from what 19 was in the design that was presented and approved, 20 whether its the CP or OL or whatever, by the NRC, you 21 identified that.
22 You dont need an ODI to say check the 23 weight versus what was assumed in the design. What 24 was assumed in the design is in the design and you can 25 compare it and check it yourself. You dont go and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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170 1 have to, I think, but your system is great.
2 But were trying to identify, like I said, 3 where ODIs get -- have the potential to get buried and 4 make sure that they arent.
5 First of all, that all the ones that 6 should be dealt with in order to certify the design 7 have been closed. Thats number one.
8 And, number two, that given that there are 9 many assumptions and they arent just the weight of a 10 pump out there, that years down the road, they get 11 picked up and closed. They may be esoteric 12 assumptions that were made.
13 And thats the whole point.
14 MEMBER CORRADINI: You get the last word 15 because I think weve got to get back to the 16 presentation.
17 MR. BERGMAN: I will. And so, thats what 18 Neil tried to explain is for items that, quote, are 19 significant enough to be in the DCA thats been part 20 of the NRCs review. It was part of the inspection.
21 The licensing audits which have been at least several 22 thousand documents now, all of those contain 23 assumptions, not all, many of those contain 24 assumptions.
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171 1 they believed an assumption needed to be in the FSAR, 2 they would raise it at that time either through an RAI 3 or just a question in the assumption, not every 4 question in the audit, excuse me, gets an RAI.
5 So, that process is very thorough. And 6 so, that screenings been done. There are, and again, 7 Ive let Neil give you the stats, most of these are 8 minor in the nonsafety related areas or theyre things 9 you simply cant validate like component weights.
10 MEMBER CORRADINI: So, at this point, Im 11 going to say, Neil, youre back up.
12 MR. OLIVIER: All right, thank you.
13 I will move expeditiously. Most of this 14 stuff, weve already covered.
15 So, ODIs are resolved and verified via the 16 design verification process. Weve already gone over 17 this. Theyre ideally per NQA-1, theyre to be closed 18 out prior to procurement manufacture, construction or 19 by use for another design organization with a 20 different QA program.
21 But, in all cases, that design 22 verification is required to be done prior to relying 23 on the component to perform its function.
24 Moving on to slide four, the interactions 25 that weve had with the NRC regarding ODIs, weve NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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172 1 already talked about the 2017 inspection. Weve had 2 numerous communications with the staff, numerous 3 chapter audits where thousands of documents were 4 reviewed and ODI questions were asked and subsequently 5 answered along with RAIs. And I couldnt give you a 6 solid number, but its -- theres thousands of 7 documents that were reviewed.
8 The highlights from the inspection, they 9 reviewed 170 specific ODIs. So, we gave them the list 10 and at the time, it was 1,500. Its currently 1,098 11 -- correction, 93, excuse me, 1,093 that are open.
12 They had no concerns about no 13 nonconformances or violations. They did note we had 14 a conservatively low threshold for opening ODIs. And 15 I bring that up as part of what Tom said.
16 Some examples, we talked about weight, but 17 300 I classify and have binned them, my staff did, 317 18 of those 1,093 that are open are specific to mass to 19 a cabinet.
20 MEMBER CORRADINI: Can you repeat that 21 again?
22 MR. OLIVIER: So, 317 of those ODIs that 23 are currently open are due to mass of a component.
24 Thats a third of them, basically.
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173 1 secondary plant. One of them that Ive used an empale 2 before is tower selection, what type of tower are you 3 going to use.
4 And different -- Ive worked at three 5 plants, one didnt have a tower, San Onofre was a 6 single passthrough.
7 Depending on the site location, depending 8 on the environment, you have a different tower, things 9 like that.
10 The size of the containment or the -- not 11 the containment, the tower intake, depending on what 12 type of tower you pick, what have different sites, 13 those are the many assumptions, 115 of those that are 14 around the secondary plant. They are open items that 15 need to be confirmed later on down when we have that 16 information.
17 And then, theres 45 that are specific to 18 the layout and theyre basically open items to ensure 19 that we get proper isometric drawings done in the 20 detailed design, nothing more than that.
21 MEMBER RAY: Okay, let me add to your 22 highlights some highlights that Ill provide from the 23 same report.
24 MR. OLIVIER: Okay.
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174 1 reviewed a small section -- a small sample of design 2 supporting documentation for the DCA.
3 The inspection team identified an example 4 where inaccurate information was present in a topical 5 report at the time of submittal, specifically, the 6 cover page to the calculation made a statement that a 7 value was obtained by analysis when it was an assumed 8 value identified as an ODI.
9 Now thats not a problem in that it was 10 identified as an ODI, just not in the report that was 11 being submitted. Which, again, were looking at this 12 from the standpoint of what our role is here.
13 NuScale documented the issue in correction 14 action report.
15 The NRC inspection team identified an 16 example where an assumption was not identified as an 17 ODI by NuScale, specifically, the fuel pool heat load.
18 Specifically, NuScale made the assumption 19 to neglect the main reactor coolant pump pool heat 20 input, excuse me, into the spent fuel pool heat load.
21 The DCA supporting documentation, NuScale 22 identified that this is an assumption that should be 23 verified which is an ODI by NuScale definition.
24 Now, this was two years ago. Nobody 25 expects perfection, thats not the point. But these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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175 1 are two specific examples of where the system went 2 awry.
3 Elsewhere, there was a reference, and I 4 guess this gets to the bottom line for me again is, 5 are these things being captured in a way thats 6 visible at a high level? All of them, regardless of 7 where they may be buried on the back page of some 8 report or otherwise.
9 Or do you have to go looking for them with 10 an audit?
11 MR. OLIVIER: No, sir. And, I can answer 12 that.
13 MEMBER RAY: And youre going to, I know, 14 but --
15 MR. OLIVIER: Well, theres not much. And 16 to your specific question, they are in a specific ODI 17 database. I can search for them, I can look at them 18 and I can tabulate them and you can search for data by 19 ODI number, by their type, by their parameter, whether 20 system.
21 MEMBER RAY: As you and I both know, 22 having done it, the verification of the fact that ODIs 23 are getting associated with other things, again, never 24 going to be perfect but it is a key part of it as well 25 as the visibility which, as they say in this topical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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176 1 report, the visibility didnt exist in the front of a 2 report -- a topical report thats being issued.
3 So, having an inventory that enables and 4 facilitates going back and saying, wait a minute, 5 heres one that we didnt capture because it wasnt 6 obvious or whatever to the verifying responsible 7 engineer is a part of what were looking at.
8 Again, the main thing for us is the 9 certification process, whats in, whats out and the 10 things that dont get closed at certification. Are we 11 sure theyre going to be? Thats the issue.
12 MR. OLIVIER: Yes, and theyre visible and 13 tied to the source document that they came from.
14 MEMBER CORRADINI: Please go ahead.
15 MR. OLIVIER: And, theres not much more.
16 The conclusion is that, in the concluding 17 slide that NuScales ODI process properly controls 18 unverified engineering assumptions in accordance with 19 NQA-1 and that the NRC has reviewed the ODI process in 20 various ways including the inspection, detailed 21 inspection, chapter audits and RAIs.
22 Thats the end of the presentation.
23 MEMBER CORRADINI: So, let me ask a 24 question as an observer of the conversation.
25 So, once the DCA is, assuming, becomes the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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177 1 DCD and were all squared away, these pass on to the 2 owner/operator and will have this list to check as 3 construction is going on?
4 MR. OLIVIER: Absolutely, its part of the 5 design.
6 MEMBER CORRADINI: And they have to 7 develop their own program of -- or do they follow this 8 NQA procedure in the COL phase?
9 MR. OLIVIER: Hypothetically, that group, 10 whoever does the COL --
11 MEMBER CORRADINI: They have to decide?
12 MR. OLIVIER: -- they have to, using NQA-13 1, their engineering assumptions by different whatever 14 name, they need to be verified so they will be 15 transferred with the design to that group.
16 MEMBER CORRADINI: And theres no other 17 instrument from your perspective thats necessary 18 other than that?
19 MR. OLIVIER: Absolutely.
20 MEMBER CORRADINI: Okay.
21 And, let me ask another way, let me try a 22 different approach.
23 I cant -- for want of a better term, I 24 cant come up with a -- is -- are there levels of 25 importance of these ODIs so that you actually have 10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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178 1 or 20 that you watch because theyre such large 2 sections that have such a large impact?
3 How do you know which are more or less 4 important than others? We used weight and pump 5 capacity, but I could come up with some past 6 certifications that didnt turn out to be so mundane.
7 MR. OLIVIER: The ODIs are owned by the 8 document and the engineer who authored the document.
9 They keep track of what they -- as an overall process, 10 theyre responsible for closing out those ODIs. They 11 know which ones are important, which ones need to be 12 closed out.
13 Other than that, I dont keep a top 10 14 list, if thats what youre asking.
15 MEMBER CORRADINI: Thats kind of what I 16 was asking.
17 MR. OLIVIER: I dont personally because 18 I run the program, but they do, the engineers know 19 which ones -- they own them, thats the program puts 20 the ownership on the engineer.
21 MEMBER CORRADINI: Okay, so any more 22 questions for NuScale before we drag the staff up here 23 and get after them?
24 Okay, thank you.
25 Omid, are you the lead here?
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179 1 MR. TABATABAI: Yes, I am.
2 MEMBER CORRADINI: You have so many, Im 3 not sure.
4 MR. TABATABAI: Good to see you, too.
5 MEMBER CORRADINI: Youre on.
6 MR. TABATABAI: All right, good afternoon, 7 everyone. Thank you very much for giving us this 8 opportunity to present to you the staffs review of 9 Chapter 17 of NuScale Design Certification 10 Application.
11 My name is Omid Tabatabai, Im the Senior 12 Project Manager in the Office of New Reactors and I 13 have the responsibility for Chapter 17.
14 With me today, we have Alissa Neuhausen 15 and Andrea Keim. They will be presenting reliability 16 assurance portion and also QA portion.
17 And also, Ian Jung is here and he will be 18 supporting us with reliability assurance portion of 19 the meeting.
20 Just on the agenda for the staff today, I 21 just wanted to go over the staffs review. Under 22 quality assurance, Member Ray, you had some questions 23 for the staff during the Subcommittee. And, although 24 NuScale went through the ODI process extensively, but 25 we wanted to be responsive to those questions. And we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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180 1 will touch on the questions that you asked during the 2 Subcommittee presentation.
3 MEMBER RAY: Thank you.
4 MR. TABATABAI: Just to mention the names 5 of the staff who reviewed this Chapter 17, these are 6 our key reviewers for Chapter 17.
7 Quickly, I will give you a high level 8 overview of Chapter 17 SER that the staff has 9 prepared. Our SER is based on Revision 1 to the DCA.
10 The latest revision that we have in house 11 is Revision 2. But, by the time that we were going 12 through the process of concurring or and approving the 13 SER, we had Revision 1.
14 The SER has two open items and no 15 confirmatory item. One open item is related to 16 quality assurance and one open is related to 17 reliability assurance section.
18 During the review, the staff performed two 19 audits and one inspection that we have already touched 20 on.
21 Again, during the December 18 22 Subcommittee, we provided some information on the SER.
23 It has not changed, we dont have any update except to 24 touch on ODI process from the staffs perspective 25 again.
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181 1 This concludes my introduction and, with 2 that, I will turn the presentation to Andrea.
3 MS. KEIM: Hi, Im Andrea Keim, I work in 4 the Vendor Inspection Quality Assurance Branch of NRO, 5 which is New Reactors.
6 I have a Bachelors degree in material 7 science and engineering and I also have a Masters 8 degree.
9 The Quality Assurance Branch, we currently 10 have two branches and these branches perform routine 11 and reactive vendor inspections.
12 We also conduct QA implementation 13 inspections for the new operating reactors -- for the 14 new reactors, sorry.
15 We also perform QA licensing reviews for 16 Part 50 and 52, where we review the QA programs and we 17 also do the initial test program.
18 So, with that, Im going to discuss 19 Section 17.5 of the NuScale Design Certification 20 Application.
21 So, the first thing were going to talk 22 about is the regulatory basis which the first one is 23 Appendix A, GDC 1 which requires quality standards be 24 applied to the structure systems and components 25 important to safety, that these shall be designed, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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182 1 fabricated, directed and tested to quality standards 2 commensurate with the importance of the safety 3 function to be performed.
4 The next requirement is that they -- is 5 Appendix B which is 10 CFR Part 50 which is our 6 quality assurance requirements and it addresses the 18 7 criteria.
8 52.47 address the contents of an 9 application which includes that they -- that the 10 application must include the quality assurance 11 program.
12 And, the description of the quality 13 assurance program for the nuclear power plant shall 14 include a discussion of how they meet the requirements 15 of Appendix B.
16 MEMBER RAY: Okay, lets stop there then.
17 What were talking about is issuing a certification 18 for a design that has what were now calling open 19 design items.
20 How do you reconcile that with whats on 21 the screen here? And, also that the quality assurance 22 program that is approved, excuse me, the quality 23 assurance programs thats applicable ends as NuScale 24 just reaffirmed at the time of design certification?
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183 1 be made for things that are not yet done but are 2 assumed in the certification? Because thats what 3 were talking about.
4 MS. KEIM: But thats going to be like a 5 hold point until you get your COL Applicant in.
6 MEMBER RAY: No, Im asking about the --
7 just read the words. It doesnt talk about a hold 8 point. A certification is issued and the provisions 9 for certification require, as you have pointed out, 10 that you have a QA program that applies to everything 11 thats in the certification.
12 Youve got assumptions here. The 13 assumptions are unverified. How should they be 14 identified at the time of certification consistent 15 with this requirement up here?
16 The way that weve done before, I wont 17 name names, but plants that include those being built 18 are you have design acceptance criteria. You have 19 ITAAC that are associated with things that cant yet 20 be done to use the heavy pump example, you dont 21 identify those because thats a deviation from the 22 approved design that you then have to process when it 23 occurs.
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184 1 have assumed that arent verified, how are they 2 supposed to be identified?
3 Youve taken credit for something thats 4 an only a design assumption that doesnt comply with 5 Criterion 3 of Appendix B or the equivalent in NQA-1 6 or the topical report or where ever.
7 But the point is, youve taken credit for 8 it, it isnt yet verified and nobodys trying to say 9 it has to be. Although, strangely, there are some 10 that have to be, as pointed out in the inspection 11 report in order to reach a reasonable assurance 12 determination.
13 Were trying to figure out how these 14 things are identified that remain at the time of 15 certification. And I dont think we should call 16 certification a hold point.
17 MS. KEIM: Technical reviewers have gone 18 through their process of reviewing their chapters and 19 they do audits and do RAIs and they come to a 20 conclusion of reasonable assurance.
21 MEMBER RAY: Well, NuScale has a system in 22 which theyve at least identified which ODIs need to 23 be closed. Do we concur in that determination or is 24 it only a result of the inspections that are -- the 25 reviewers work thats -- that you referred to?
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185 1 Have we looked at the ODIs to say, gee, 2 this one should be closed? NuScale fell short here or 3 made a mistake or something. This is a verification 4 that should occur.
5 Im going to ask you -- well get to her 6 in a minute.
7 MS. KEIM: Thats my boss.
8 MEMBER RAY: Okay, go ahead.
9 MS. KAVANAGH: Hi, my names Kerri --
10 MEMBER RAY: Sorry.
11 MS. KAVANAGH: Thats okay. Im Kerri 12 Kavanagh, Im the Chief of the Quality Assurance 13 Vendor Inspection Branch.
14 Quality assurance does not require a 100 15 percent inspection and verification. The goal of a 16 design cert is reasonable assurance.
17 We assure that theyre implementing their 18 QA program at specific times when the tech staff goes 19 out and they do audits, if there are already concerns, 20 they report back and we will continue evaluating 21 whether or not we need to perform more quality 22 assurance inspections to verify that the QA program is 23 implemented while the design is under certification 24 review.
25 MS. KEIM: So, let me --
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186 1 MEMBER RAY: You know, but wait a minute.
2 Im sorry, Joy, were not -- Im trying not to talk 3 about what you do. Im trying -- which is very fun --
4 good job, I like the inspection report. It was very 5 helpful.
6 What Im trying to do is understand the 7 certification process which you provide input to, I 8 know.
9 MS. KAVANAGH: Yes.
10 MEMBER RAY: But we are trying to look at 11 this from the standpoint of the things that have been 12 taken credit for that are important to certification 13 but which have not been verified.
14 How is that done? You make an important 15 contribution to that. But another way of saying it 16 is, well, weve looked at the open design items and 17 were good with those that remain to be closed later.
18 MS. KARAS: This is Becky Karas. Im the 19 Branch Chief for the Reactor Systems Branch. I was 20 also supporting the 2017 inspection thats been 21 referred to.
22 And my staff does look at some of the ODIs 23 when there are calculations that theyre looking at 24 for the audits.
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187 1 been looking at a calculation through an audit process 2 that is something thats supporting the conclusions 3 and the results that are in the DCD.
4 And, in those cases, my staff engages in 5 a discussion with NuScale. They also sort of 6 independently look at that. And these are usually 7 things that are like engineering assumptions and 8 thats how weve seen it for other designers that 9 therell be things that are listed as, you know, 10 assumptions or conservative assumptions in the 11 calculations.
12 If we look at that and it makes sense to 13 us that thats a conservative assumption thats very 14 clear, then that may end it. Also, if its something 15 that doesnt matter, theres no sensitivity and we 16 know that, that may end it.
17 But in some cases, we have gone back to 18 the Applicant and weve said, you know, youve got an 19 open design issue, youve got an assumption for this 20 certain parameter. And its not apparent to us that 21 that would be obviously conservative. We need the 22 calculations supporting that that shows that thats, 23 you know, the right value.
24 And then, you know, either they have it 25 because, in some cases, they have that later NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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188 1 calculation thats already been done but the paperwork 2 for closing the ODI or the updated Rev to that first 3 calculation might not be completed.
4 But we engage in those discussions with 5 them. We may submit an RAI if we need to to make sure 6 that that value is calculated.
7 Ive got some specific examples where 8 weve done that.
9 MEMBER RAY: Well, let me interrupt you 10 before you get too far. And I think you should please 11 continue.
12 But the -- in the very beginning of what 13 you said, you said in our audit process. And, Ive 14 done a lot of audits and I do understand auditing. It 15 is not review, its not what we do.
16 If -- whats different between an audit 17 where you do what youve just described, and please 18 continue when Im done with my spiel.
19 Whats different between an audit which 20 surfaces something and you send an RAI and you ask for 21 more information and youre not satisfied with it or 22 whatever, and what were talking about or what were 23 trying to talk about is, you should have or the 24 certification should contain an identification of all 25 the ODIs so you dont pick it up in an audit.
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189 1 MS. KARAS: So, let me explain how were 2 conducting the review then maybe from a basic 3 perspective.
4 So, lets say theres a calculation in 5 Chapter 15, right, the key assumptions will be listed.
6 The output results will be listed. It wont 7 necessarily -- it wont indicate there that theres an 8 ODI or anything. Right?
9 MEMBER RAY: Exactly.
10 MS. KARAS: But we dont, you know, look 11 solely at whats written in the DCD, right? Theres 12 always a calculation supporting that, so we open 13 audits for the chapters.
14 And, you know, those key calculations we 15 then audit in that supporting documentation, it will 16 indicate if theres an ODI or not.
17 And sometimes that could be with a value 18 or an assumption that isnt important enough to rise 19 to the list thats listed in the DCD. We can then 20 either, you know, request that they place that in the 21 DCD, we can -- we will ask for the basis behind that.
22 So, there have been instances where weve 23 done that.
24 MEMBER RAY: Okay, but again, were 25 talking about an audit process and Im trying to -- if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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190 1 I could, because of time, I just want to ask staff to 2 please stick with the idea that were trying to 3 distinguish between discovering something in an audit 4 that isnt satisfying and getting it corrected as 5 opposed to having an identified list of assumptions 6 that we rely upon implicitly whether we happen to pick 7 it up in an audit or dont in the design 8 certification.
9 Thats what were trying to talk about.
10 So, terrific auditing job, you know, I dont have any 11 criticism or question about it. I know that that goes 12 very well.
13 But still, when youve got over a 1,000 14 currently of open ODIs, the changes of picking up 15 something and take the difference between the weight 16 of a pump and the heat input to the spent fuel pool 17 from the -- those are two quite different issues.
18 And one can be identified when the plant 19 is being built that the plant -- the pump weight is 20 different than what was in the design. The absence of 21 consideration of the heat input to the overall 22 performance in an accident is not going to be picked 23 up during construction. Its not a 50.59 item.
24 And so, help us get to the point where we 25 can understand, you know, were just relying upon the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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191 1 down stream post certification QA programs, whoevers 2 implementing them, to pick these things up and deal 3 with them because theres a list kept somewhere that 4 isnt part of the certification.
5 It sounds to me like thats the case.
6 MEMBER BLEY: Harold, let me try 7 something.
8 MEMBER RAY: Okay, Im sorry to go on and 9 on.
10 MEMBER BLEY: I know and I think I 11 understand where youre coming from.
12 We have, in other cases, other plants, 13 other design certs, but actually in operating plants, 14 too, found situations where the design assumptions 15 were wrong and it was never checked.
16 Now, I kind of think, listening to all 17 Ive heard today, that what NuScale has done is the 18 first step in what were looking for.
19 These ODIs, everybody has them, but they 20 dont make a list of them. Theyve tried to make a 21 list, we havent seen -- at least I havent seen the 22 list, I dont know how thorough it is.
23 MEMBER RAY: Its a big list.
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192 1 the plant.
2 But what they havent done, they told us, 3 is set priorities on that. Some of these design 4 assumptions have a very minor effect on overall 5 safety. Some go right to the heart of being able to 6 remove heat, being able to contain fission products, 7 whatever.
8 If there were some structure to look for 9 which of these have the greatest impact, could have 10 the greatest impact on safety, youd want to have a 11 top ten list. You want to look at these more 12 thoroughly and try to make sure you met all of those 13 estimations.
14 MEMBER RAY: Well, NuScale --
15 MEMBER BLEY: Now, NuScale --
16 MEMBER RAY: NuScale did do that for the 17 -- in their judgment for the design --
18 MEMBER BLEY: Well, no, theyve got a big 19 list and they said they havent put any priorities on 20 them.
21 MEMBER RAY: But they did close 173.
22 MEMBER BLEY: They did, for design cert.
23 MEMBER RAY: Thats right.
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193 1 ones to close for design cert and we dont know how 2 you -- yes, what all the others are on the list.
3 But there are, certainly, are ways to put 4 them in priority that would help us avoid the problem 5 weve seen in the past. And I think thats what --
6 were started on the road that way with just having 7 this, which is --
8 MEMBER RAY: And I dont want to diminish 9 the auditing process or the inspection process.
10 MEMBER BLEY: Oh no.
11 MEMBER RAY: I mean, theyre very good, 12 very good processes, but thats not what we deal with 13 in certification. We need to know what the 14 assumptions are.
15 Okay, enough. Thank you.
16 MEMBER CORRADINI: Please continue.
17 MR. TABATABAI: Were on slide seven now.
18 MS. KEIM: So, slide seven talks about our 19 topical report review. The NuScale Quality Assurance 20 Topical Report Review was completed separate from the 21 design application process. It followed a topical 22 report process.
23 The topical report was reviewed to ensure 24 that the preliminary work on the application was done 25 in accordance with Appendix B to 10 CFR Part 50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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194 1 requirements.
2 The staff used the standard review plan, 3 NUREG-0800, Section 17.5 which is for safety analysis 4 reports as the guidance.
5 And the Applicant QA topical report 6 submittal was in accordance with our Reg Guides and 7 with the standard review plan and it met the 8 requirements of NQA-1 2008 and 2009 addenda.
9 So, we found the topical report acceptable 10 and it met the requirements of Appendix B.
11 Slide eight?
12 MEMBER RAY: The only thing Id say there 13 is, Appendix B doesnt say anything about, and I dont 14 think the topical report does, either, about things 15 that are covered by ITAAC, for example.
16 So, theres no issue over unresolved or 17 unresolvable items. Weve to a system to deal with 18 that.
19 What were talking about here is a system 20 that isnt included within those things that are 21 covered by ITAAC. Theres a really nice explanation 22 of why they -- why ITAAC exists, what its supposed to 23 do and so on and so forth.
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195 1 you take credit for the ITAAC, the QA program is 2 satisfied.
3 The issue is, were taking credit for ODI 4 that we dont know what they are. And does that 5 satisfy the QA Appendix B requirements for design 6 certification?
7 Its, you know, Im trying to use 8 something that illustrates what it is were talking 9 about. Its well-establish that you can satisfy 10 Appendix B and have unresolved design items that are 11 reflected in ITAAC.
12 The question is, can you satisfy Appendix 13 B and have unresolved items that are in the hands of 14 the responsible design engineers.
15 MEMBER BLEY: Mike had to step away for a 16 minute.
17 MEMBER RAY: Yes, I --
18 MEMBER BLEY: But were within just a few 19 minutes of our ending time and you arent quite there 20 yet. So, I think if you can go ahead, it would be a 21 good thing.
22 MS. KEIM: Yes.
23 MEMBER RAY: Ive created too much 24 turmoil, Im sorry.
25 MS. KEIM: So, the staffs review of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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196 1 design certification application Section 17.5 was done 2 to -- it references the appropriate quality assurance 3 topical report and the staff has assigned an open item 4 to address the quality assurance implementation 5 inspection.
6 Weve done a preliminary one or an initial 7 one and we plan to go out and do a second inspection.
8 The next slide talks about our completed inspection.
9 We went out in June 5th through the 9th of 10 2017. We were in the Corvallis, Oregon location. The 11 staff used Inspection Procedure 35017 which is the 12 quality assurance implementation inspection procedure.
13 There were no findings of significance 14 were identified, yet, there were some issues to look 15 into.
16 The QA inspection report is available on 17 our public site. And, as noted in the SER for the 18 Design Certification Application, we will have an open 19 item to perform a follow up inspection which has been 20 scheduled for the end of February.
21 The announcement letter went out and it 22 was dated January 27th, so we are planning to be there 23 on February 25th through March 1st.
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197 1 meeting.
2 So, how does the NEC staff ensure all open 3 design items are sufficiently closed by the time of 4 the Design Certification Application as approved?
5 So, I dont know if youre still going to 6 -- how these answers are going to meet your needs, but 7 the technical reviewers use audits and the RAIs during 8 the review process to obtain sufficient information to 9 make a reasonable assurance determination for the 10 assigned review areas.
11 Any ODI that prevents the reviewer from 12 making a reasonable assurance determination will need 13 to be closed prior to the approval of the Design 14 Certification Application. So, they would have been 15 assigned an open item.
16 The NRC performed an initial quality 17 assurance inspection that reviewed the ODI tracking 18 and closure process and there were no findings of 19 significance identified.
20 So, the second question, what does 21 sufficiently closed mean?
22 The response that we came up with it, 23 sufficiently closed means the technical staff are able 24 to make a reasonable assurance determination.
25 So, for the third question, what --
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198 1 MEMBER RAY: And, in doing that, are they 2 aware of the open ODIs that they may be relying upon?
3 MS. KEIM: Yes.
4 MEMBER RAY: They are?
5 MS. KEIM: Yes.
6 MEMBER CORRADINI: So, can I say it 7 another way, just so were on the same page?
8 MS. KEIM: Okay.
9 MEMBER CORRADINI: Theres an engineering 10 calc. In the engineering calc, you guys are reviewing 11 or auditing. Its listed that I have assumed A, B, C, 12 D, and E in this. And then, staff is deciding, well, 13 A, C, C, D, and E dont matter or its conservative or 14 something.
15 Its listed in the engineering calc?
16 MR. TABATABAI: That was actually the 17 specific example --
18 MEMBER CORRADINI: Thats why -- I just 19 wanted to make sure Im on the same page.
20 MR. TABATABAI: Yes.
21 MEMBER CORRADINI: Okay.
22 MS. KEIM: So now, were on question 23 three.
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199 1 assumptions that are used in the PRA model?
2 So, the response here, I didnt address 3 the specific PRA model question, but for the main 4 question, NRCs Regulatory Information Summary 2010-05 5 discusses the applicability of 10 CFR Part 21.
6 And these requirements are applicable for 7 standard design certifications. And the RIS clarifies 8 that the regulatory requirements of Section 206 of the 9 Energy Reorganization Act are applicable through the 10 entire regulatory life of a standard design 11 certification.
12 So, the NRC considers the regulatory life 13 as the period of time which the standard design 14 certification needs to meet the regulations in effect.
15 And this period is when an application is docketed, 16 and ends when the termination or expiration date of 17 the standard design certification or the termination 18 or expiration of the last license directly or 19 indirectly referencing the standard.
20 Therefore, the vendor in this case, 21 NuScale, would evaluate the defect or failure to 22 comply in accordance with their procedures.
23 The NuScale procedure addresses discovery 24 of the issue, the evaluation, and notification.
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200 1 reviewed during the NRC staff inspections as in the 2 one in June and it will -- the one in February of 3 2018.
4 And, for the final question, it wasnt 5 really a question, it was making a statement that we 6 need to clarify with NuScale that theyve run a RIS 7 with these open items.
8 MEMBER BALLINGER: So, let me try to 9 simplify what Im hearing. Item number one, an 10 engineer or somebody goes and looks at an ODI and 11 lists the assumptions. And, if theyre satisfied with 12 the assumptions or theyre conservative or something, 13 they say, okay, were fine.
14 If they dont, then it becomes an open 15 item.
16 MS. KEIM: Yes.
17 MEMBER BALLINGER: Right? Right? It 18 becomes and open item.
19 MEMBER RAY: No, actually, you have to be 20 more than satisfied.
21 MEMBER BALLINGER: Okay, well, let --
22 MEMBER RAY: You have to meet Criterion 3 23 of Appendix B, period.
24 MEMBER BALLINGER: Right, okay. So, lets 25 -- youre more exact than I am, right?
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201 1 So, what if unverified assumptions change 2 after the DCA is approved? If the DCA is approved, 3 theres no open items. Or can there be open items?
4 MEMBER RAY: Thats what were talking 5 about is, how do we know what the open items are that 6 we relied upon in the design certification and which 7 continue to exist?
8 MEMBER CORRADINI: Dont get confused with 9 the open items and ODIs. Are you -- I assume youre 10 not confused.
11 MEMBER BALLINGER: An open item is 12 generated if they cant verify the assumptions or the 13 staff is not satisfied.
14 MEMBER CORRADINI: Or theyll ask an RAI 15 or require --
16 MEMBER BALLINGER: Or yes, something like 17 that.
18 MEMBER RAY: An open design item, just as 19 a --
20 MEMBER BALLINGER: Right, but all the open 21 items have to be cleared.
22 MEMBER RAY: Open design items.
23 MEMBER CORRADINI: There is a difference, 24 theres a difference.
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202 1 difference, but Im saying open items.
2 MEMBER RAY: Well, open items are a 3 different subject.
4 MEMBER BLEY: Open items in the SER 5 supporting the design cert.
6 MEMBER BALLINGER: yes.
7 MEMBER BLEY: All those open items must be 8 closed.
9 MEMBER BALLINGER: Right.
10 MEMBER BLEY: The open ODIs dont all have 11 to be closed, thats what --
12 MEMBER BALLINGER: Okay, thats what 13 youre saying, because Im reading that, if theres an 14 ODI that generates an open item --
15 MEMBER BLEY: It has to be closed.
16 MEMBER BALLINGER: -- it has to be closed.
17 MEMBER BLEY: Yes. Thats -- sure.
18 MEMBER BALLINGER: So, thats what Im 19 understanding.
20 MEMBER RAY: But thats --
21 MEMBER BALLINGER: No, where Im going is, 22 when you get through this, youre finished. If the 23 DCA is issued, all open items, open items, have been 24 closed. And, those open items may have been generated 25 by ODIs --
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203 1 MEMBER BLEY: Or other --
2 MEMBER BALLINGER: -- or other.
3 MEMBER RAY: Mostly other things.
4 MEMBER CORRADINI: But, I think staffs 5 point is, as I understand it, to summarize because, a, 6 have run out of time; and, b, they still have another 7 part of the presentation to talk about, is that they, 8 by accommodation of their review, inspections, and 9 audits, have satisfied themselves that they have 10 captured the important ones that they require to be 11 closed ODIs.
12 They require to be closed so the design 13 certification can go forward. Thats my impression of 14 their statement.
15 MR. TABATABAI: Thats correct. I mean, 16 they have 15 -- I mean, last -- two years ago, when 17 the staff did an inspection, there were about 1,500 18 ODIs, but that doesnt mean the staffs SER would 19 include 1,500 open items.
20 No, open items are a very, very, very 21 small subset of ODIs. Not all ODIs are required to be 22 -- theres no regulation -- the NRC staff has no 23 regulatory requirements to demand all of the ODIs be 24 closed by the time of DCA approval. Theres no 25 regulations in place.
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204 1 The staff reviews what comes in the 2 application, which is defined by the Code of Federal 3 -- what the Applicant needs to provide and thats what 4 the staff reviews based on all of the guidance 5 documents, DRP or DSRs and things like that.
6 And so, for -- and if they are not happy 7 with the level of information or clarity of the 8 information in the application, the staff uses RAIs, 9 audits, and confirmatory analysis to make sure that 10 those open items or ODIs that have an impact of the 11 finding, reasonable assurance finding, those are 12 closed. So, that item is closed.
13 MEMBER RAY: Wait a minute, I got to jump 14 in here and say, they dont -- the staff doesnt 15 review all ODIs.
16 MR. TABATABAI: Thats what I was --
17 MEMBER RAY: As you just --
18 MR. TABATABAI: -- about to say.
19 MEMBER RAY: -- heard explained.
20 MR. TABATABAI: Okay.
21 MEMBER RAY: They review what theyre 22 reviewing when they have issues that come up that are 23 associated with ODIs, its conceivable itll generate 24 and open item. But, itd be very rare.
25 The issue is, the two things are just --
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205 1 the words sound similar, but theyre very, very 2 different. And you shouldnt assume that all ODIs get 3 reviewed as part of the design certification.
4 MEMBER BALLINGER: That was the point I 5 was missing.
6 MEMBER CORRADINI: Sam?
7 MR. LEE: Yes, this is Sam Lee from NRO 8 Licensing Branch 1.
9 I think the last exchanges there, I think 10 those reflect a clearer understanding. If I could 11 just step back a little bit to provide a perspective.
12 And, Im going to say something that might 13 actually raise your eyebrows, but Im going to qualify 14 it, so allow me to expand on what Im about to say.
15 Open design item is not within the scope 16 of the staffs review of the DCA application package.
17 Again, Ill say, its not within the scope 18 of the design review of the staffs review of the 19 design application package.
20 The way we came across ODI, as you know, 21 we -- as part of the design application package, we 22 have the FSAR, the topical reports thats a report 23 that come to you for review, as well as supporting 24 technical reports.
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206 1 reports to review as part of the DCA.
2 And, one of those is a topical report on 3 quality assurance program development, QAPD. And, as 4 Kerri was saying earlier, in the midst of performing 5 a review of QAPD, and as part of a follow up action to 6 do a QA inspection, we came across NuScales program 7 called open design item program.
8 And when we came across it, the name 9 itself is kind of altering enough, right, the open 10 design items. And it is associated with our notion of 11 open items.
12 So, obviously, we were very curious and we 13 made a separate inspection effort to look into that.
14 And what we found was that the level of 15 detail of whats covered in the ODI really is below 16 the scope of the staffs review. Right? Its not 17 even in our radar.
18 As I said, Im going to qualify what Im 19 about to say or what I just did say.
20 And so, the more we looked into that, the 21 more we realized that these dont rise to the level of 22 the open items that you and I -- that weve been 23 talking about.
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207 1 responses, at times, the staff has had to conduct 2 audits, regulatory audits.
3 And we look at the information in more 4 detail, information thats, in the cases, its not 5 docketed. And sometimes, we would come across 6 questions that would be directly at the related --
7 particular related ODI.
8 And if that ODI needs to be addressed and 9 closed in order to satisfy, as the staffs need to 10 make a disposition, a regulatory disposition, we would 11 pursue that and make sure that that is closed.
12 Whether thats pursued as an RAI or an 13 open item, it remains to be seen. And Im not sure if 14 theres any open item that we have in any of our 15 chapters today that was born out of an ODI, per se.
16 But, it could be, it could be.
17 And so, I just wanted to state up front 18 that we dont approach ODI as a program to reviewed.
19 We encounter them on a case by case basis as our 20 review directed to ODI, if needed.
21 MEMBER RAY: Well, let me say that, from 22 just reading the introduction to Part 50, every 23 Applicant for a design certification under Part 52 is 24 required to include the description of the quality 25 assurance program applied to the design and blah, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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208 1 blah, blah.
2 The point is, this is something, here in 3 this case, you said these are trivial items. An 4 assumption was made according to the inspection report 5 to neglect main reactor coolant pool heat input to the 6 spent fuel pool heat load.
7 Thats the kind of thing that we do look 8 at and its not necessarily trivial. It wasnt even 9 identified with an ODI until the inspection occurred.
10 So, good things come out of inspections, dont get me 11 wrong.
12 And, NuScale does track these ODIs. The 13 issue before us is, should they be identified as 14 existing at the time of design certification? Whether 15 its itsy-bitsy things, and were only talking about 16 stuff thats covered by Chapter 15, by the way, not 17 things that are in the balance of plant or whatever, 18 thats not anything that were concerned about in the 19 certification.
20 Its only those things that pertain to the 21 certification.
22 If you were able to tell us that ODIs that 23 are identified and not resolved and that are 24 important, any of them would be identified as open 25 item, like Ron had assumed, great. That basically NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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209 1 would answer our question.
2 But were looking for something less than 3 that, which is just that, in the process, we are 4 assured the ODIs that exist at the time of 5 certification are identified, thats all were looking 6 for.
7 And, you know, I would Chair the AP1000 8 Subcommittee, we went through and identified things 9 that couldnt or hadnt been resolved and we made up 10 ITAAC.
11 And, sometimes, theyd fail the damn thing 12 and we had to go through a pretty difficult process 13 after the Amendment 6 was issued.
14 So, it isnt something that is just a lot 15 of trivia, necessarily.
16 MR. LEE: This is Sam Lee, again.
17 For the record, I didnt refer to ODI as 18 being trivial. So, but, I understand what youre 19 saying.
20 I think, as I hear you, Im thinking about 21 the process that we have in place. And I have to 22 trust the process. And the process allows for the 23 staff to be able to conduct its review in the manner 24 that the Part 52 requires.
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210 1 design, not complete design. It talks about 2 reasonable assurance finding, not complete assurance 3 finding.
4 And, I think the, again, if we are 5 trusting the process and conducting the review per our 6 process, I dont know that we are doing this review in 7 any less rigorous way than what we did for AP1000, per 8 se.
9 And so, we have to trust the process to be 10 able to arrive at a regulatory finding that we must 11 make. And, in the course of doing so, if we run into 12 an ODI that speaks to a particular question that the 13 staff has, we would pursue that. And I think we have.
14 MEMBER RAY: Is there any reason why --
15 MR. LEE: And, I think we have several 16 examples that we have and Ill turn the mic over to 17 Becky.
18 MS. KARAS: I can -- this is Becky Karas, 19 again. I can give you a couple of examples of -- or 20 if you ask a lot of questions about them, Ill have to 21 get Tim to come up here.
22 And these are only a few examples of 23 places where we have pursued issues.
24 There was one case in the return to power 25 recriticality calculation where they had an assumed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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211 1 power peaking factor. And it was stated that it was, 2 you know, that was an assumed value based on 3 engineering judgment.
4 When we audited that, we couldnt 5 immediately come to the conclusion that that was 6 clearly conservative. So, we raised that with 7 NuScale.
8 They performed the calculation that would 9 determine that peaking factor and it did confirm that 10 it was conservative.
11 We audited that calculation as well and 12 they closed the ODI.
13 We also had a case where the subchannel 14 analysis, they had a value listed for the input P-rise 15 engineering uncertainty factor that was incorporated 16 into that analysis in the topical report.
17 And, later, they did verify that analysis 18 to be conservative and closed the ODI.
19 So, those are a couple of examples. You 20 know, there are certainly, I think, some, you know, 21 isolated circumstances like by the inspection that we 22 noted like with the pool heat load, I think, you know, 23 any inspection can uncover those things.
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212 1 when the ODI process was more in its infancy within 2 NuScale. And, they have since that time, put in more 3 controls to capture things like that. So --
4 MEMBER CORRADINI: Im sorry, Becky.
5 MS. KARAS: Yes.
6 MEMBER CORRADINI: Were you finished?
7 MS. KARAS: Yes, sorry.
8 MEMBER CORRADINI: Okay, so, Im going to 9 do a time check. Were about 15 minutes over. I 10 think weve had enough interchange for the moment.
11 I think you have more to talk about 12 relative to the second part, which is the RAP or the 13 D-RAP.
14 MR. TABATABAI: Thats correct.
15 MEMBER CORRADINI: So, can we get to that?
16 MR. TABATABAI: Sure.
17 CHAIRMAN RICCARDELLA: Are we still going 18 to have a closed portion of the meeting?
19 MEMBER CORRADINI: I dont think were 20 going to have a closed portion unless we need to in 21 the D-RAP.
22 CHAIRMAN RICCARDELLA: In the what?
23 MEMBER CORRADINI: Unless we need to in 24 the D-RAP portion, were not going to have a closed 25 portion.
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213 1 CHAIRMAN RICCARDELLA: All right.
2 MEMBER CORRADINI: So, why dont you keep 3 on going?
4 MS. NEUHAUSEN: Okay, good afternoon. My 5 name is Alissa Neuhausen. Im covering Section 17.4 6 on the reliability assurance program.
7 MEMBER CORRADINI: Closer to your mic.
8 MS. NEUHAUSEN: Closer -- move it closer 9 to me.
10 So, for the reliability assurance program, 11 staffs review was performed in accordance with SRP 12 Section 17.4, Revision 1.
13 The Applicants -- sorry, the staff 14 reviewed the program description and implementation 15 programmatic controls SEC selection methodology expert 16 panel member requirements and the determination of 17 risk significant SSEs.
18 The first stage of the RAP is the design 19 reliability assurance program which encompasses the 20 reliability assurance activities that occur before 21 initial fuel load which includes the DC and COL 22 phases.
23 The second stage comprises the reliability 24 assurance activities conducted during the operations 25 phase.
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214 1 The DC review is the subject of todays 2 presentation.
3 Specifically, staff found that the D-RAP 4 list was developed in accordance with its RAP 5 methodology.
6 NuScale adequately implemented the expert 7 panel in developing the D-RAP list and the D-RAP list 8 is comprehensive.
9 The three COL items, respectively, for 10 integrating RAP into operational programs, QA controls 11 during site specific design, procurement, fabrication, 12 construction, and pre-operational testing activities, 13 and the identification of site specific SSEs provide 14 an appropriate level of assurance that a COL Applicant 15 referencing the NuScale design will implement an 16 adequate reliability assurance program.
17 And then, the last item, the inclusion of 18 the D-RAP ITAAC is currently the only open item in 19 Section 17.4.
20 I do want to correct this slide, it should 21 be open item 17.4-1 to be consistent with the SER.
22 And then, SECY -- theres been no change 23 since the Subcommittee meeting SECY-18-0093 is still 24 with the Commission.
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215 1 discontinue the use of the D-RAP ITAAC and the staff 2 is waiting -- still waiting for the response.
3 MEMBER CORRADINI: Question by the 4 Members?
5 Okay, so, with that, I think we asked you 6 enough questions for the moment.
7 Ill turn it back to -- oh, Im sorry, 8 excuse me, we have to get public comments. My 9 apologies.
10 So, are there people in the audience, if 11 we can open the outside line, please?
12 Anybody that has a comment may come to the 13 podium. Hearing none, can we go to the outside line?
14 Can somebody on the phone at least verify 15 that you can -- we can hear you?
16 Anybody on the outside line?
17 PARTICIPANT: We can hear you.
18 MEMBER CORRADINI: Okay. So, anybody that 19 wants to make a comment, please go ahead. Hearing 20 nothing, we will close the outside line and Ill turn 21 it back -- well, before I do that, let me see, do I 22 have any more members that want to make comments?
23 MEMBER RAY: I interrupted Joy at one 24 point.
25 MEMBER REMPE: I was -- Dennis made my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
216 1 comment about prioritization and thats what I was 2 trying to get in.
3 At some point, I interrupted the gentleman 4 who was trying to ask -- answer my question, was Surry 5 one of the six that he evaluated? And Id like to 6 know that before we get to Chapter 19, just for my own 7 future perspective.
8 MEMBER CORRADINI: Okay.
9 MEMBER REMPE: And I -- it doesnt have to 10 be today.
11 MEMBER CORRADINI: Can we take it as an 12 action item?
13 MEMBER REMPE: Yes, please.
14 MEMBER CORRADINI: Okay, good.
15 So, Ill turn it back to the Chairman.
16 Mr. Chairman, its all yours.
17 CHAIRMAN RICCARDELLA: Okay, so, were 18 about 15 minutes over, so were going to delay the 19 start of the next session by 15 minutes. So, well be 20 back here at 3:00 p.m.
21 MEMBER MARCH-LEUBA: Yes, the next session 22 is going to be closed, so well need to start doing 23 the set up during the break.
24 CHAIRMAN RICCARDELLA: Oh.
25 MEMBER MARCH-LEUBA: And, do the --
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
217 1 CHAIRMAN RICCARDELLA: Okay.
2 MEMBER MARCH-LEUBA: Only the NuScale 3 people are not invited for the next session.
4 (Whereupon, the above-entitled matter went 5 off the record at 2:47 p.m.)
6 7
8 9
10 11 12 13 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.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
ACRS Full Committee Draft Commission Paper (and related draft regulatory guide)
Technology-Inclusive, Risk-Informed, Performance-Based Approach to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors, February 6, 2019 1
Outline
- Background
- NEI 18-04 & Draft Regulatory Guide DG-1353
- Licensing Basis Events
- Safety Classification and Performance Measures
- Assessing Defense in Depth
- Content of Applications
- Draft Commission Paper 2
Strategies & Contributing Activities Strategy 1 Strategy 2 Strategy 3 Strategy 4 Strategy 5 Knowledge, Skills Strategy 6 Computer Codes Flexible Review Consensus Codes Policy and Key and Capability Communication
& Review Tools Processes and Standards Technical Issues ONRL Molten Salt Reactor Training Identification &
Assessment of Regulatory Roadmap ASME BPVC Section III Siting near densely populated NRC DOE Workshops Available Codes Division 5 areas Knowledge Management Prototype Guidance ANS Standards 20.1, 20.2 Insurance and Liability Periodic Stakeholder 30.2, 54.1 Meetings Competency Modeling Non-LWR Design Criteria Non-LWR PRA Standard Consequence Based Security NRC-DOE MOUs (SECY-18-0076)
Updated HTGR Environmental EP for SMRs International and Fast Reactor Reviews and ONTs Coordination Training (SECY-18-0103)
Licensing Modernization Functional Containment Project (SECY-18-0096)
Potential First Micro-Reactors Movers 3
Integrated Design/Review Siting near Functional densely populated Containment areas EP for SMRs (SECY-18-0096) and ONTs Licensing Modernization (SECY-18-0103)
Project Insurance and Liability Environmental Reviews Consequence Based Security (SECY-18-0076) 4
Fundamental Safety Functions and Mechanistic Source Term 5
NEI 18-04, General Approach
- Licensing Basis Events
- Probabilistic Risk Assessment
- Deterministic
- SSC Classification
- Function and Risk Considerations
- Safety Related
- Non-Safety Related with Special Treatment
- Defense-in-Depth Assessment
- Structures, Systems and Components
- Programmatic
- Integrated Decision-making Process 6
Other Requirements
- Associated requirements include:
- Quality Assurance
- Maintenance Rule
- Interfaces with requirements for:
- Siting
- Environmental Reviews
- Additional requirements for design/operation include:
- Routine Effluents
- Worker Protections
- Security
- Aircraft Impact Assessments 7
Event Selection & Analysis The F-C Target values shown in the figure should not be considered as a demarcation of acceptable and unacceptable results. The F-C Target provides a general reference to assess events, SSCs, and programmatic controls in terms of sensitivities and available margins.
AOOs Note that DBAs DBEs (Chapter 15) derived from DBEs BDBEs RISK SIGNIFICANT LBEs
- F-C Target considered along with cumulative risk metrics, safety classification, and assessment of defense in depth 8
Safety Classification and Performance Criteria
- Safety-Related (SR):
o SSCs selected by the designer from the SSCs that are available to perform the required safety functions to mitigate the consequences of DBEs to within the LBE F-C Target, and to mitigate DBAs that only rely on the SR SSCs to meet the dose limits of 10 CFR 50.34 using conservative assumptions o SSCs selected by the designer and relied on to perform required safety functions to prevent the frequency of BDBE with consequences greater than the 10 CFR 50.34 dose limits from increasing into the DBE region and beyond the F-C Target
- Non-Safety-Related with Special Treatment (NSRST):
o Non-safety-related SSCs relied on to perform risk significant functions. Risk significant SSCs are those that perform functions that prevent or mitigate any LBE from exceeding the F-C Target, or make significant contributions to the cumulative risk metrics selected for evaluating the total risk from all analyzed LBEs.
o Non-safety-related SSCs relied on to perform functions requiring special treatment for DID adequacy
- Non-Safety-Related with No Special Treatment (NST):
o All other SSCs (with no special treatment required) 9
Assessing Defense in Depth 10
Additional Discussion Topics
- Integrated Decisionmaking Process
- Multi-Disciplinary assessments
- General guidance from RG 1.201 & NEI-00-04 (10 CFR 50.69)
- No specific NRC documentation on assessment of similar panels
- Key focus area for implementation by developers
- Reliability of Passive Heat Removal Systems
- Table Top Exercises
- X-energy (ADAMS Accession No. ML18228A779)
- PRISM (ADAMS Accession No. ML19036A584)
- Additional Planned
Draft SECY Paper
- Paper
- The purpose of this paper is to seek Commission approval of the U.S.
Nuclear Regulatory Commission (NRC) staffs recommendation to adopt a technology-inclusive, risk-informed, and performance-based methodology for informing the licensing basis and content of applications for licenses, certifications, and approvals for non-light-water-reactors (non-LWRs).
- Enclosure 1, Background
- Enclosure 2, Technology-Inclusive, Risk-Informed, Performance-Based Approach 12
Policy Background
- Advanced Reactor Policy Statement
- Pre-application evaluations (e.g., PRISM, MHTGR)
- SECY-93-092, Issues Pertaining to the Advanced Reactor (PRISM, MHTGR, and PIUS) and CANDU 3 Designs and Their Relationship to Current Regulatory Requirements
- SECY-03-0047, Policy Issues Related to Licensing Non-Light Water Reactor Designs
- Related initiatives to develop and implement risk-informed, performance-based regulation 13
Policy Background SECY-03-0047, Policy Issues Related to Licensing Non-Light Water Reactor Designs, and the related staff requirements memorandum (SRM) dated June 26, 2003.
- Greater emphasis can be placed on the use of risk information by allowing the use of a probabilistic approach in the identification of events to be considered in the design, provided there is sufficient understanding of plant and fuel performance and deterministic engineering judgment is used to bound uncertainties;
- A probabilistic approach for the safety classification of structures, systems, and components is allowed; and
- The single-failure criterion can be replaced with a probabilistic (reliability) criterion.
14
Event Selection
- Consistent with SRM approving the use of a probabilistic approach to identify events provided there is sufficient understanding of plant and fuel performance and engineering judgment is used to address uncertainties Including a lower frequency range for licensing basis events, when combined with other considerations and engineering judgment, is an inherent part of a risk-informed approach and is consistent with the Commissions SRM
- The F-C targets support defining needed SSC capabilities and reliabilities to support the design process and to inform the content of applications, considering uncertainties and multi-module issues
- Consistent with the Commissions SRM approving replacement of the single-failure criterion with a probabilistic (reliability) criterion 15
Safety Classification &
Performance Criteria
- The safety classification of SSCs and determination of performance criteria are directly related to and performed in an iterative process along with the identification and assessment of LBEs and the assessment of defense in depth
- Systematic approach to assessing and determining appropriate relationships between the needed capabilities and reliabilities for SSCs and the role of those SSCs in mitigating and preventing LBEs 16
Assessing Defense in Depth
- Framework that includes probabilistic and deterministic assessment techniques to establish defense in depth using a combination of plant capabilities and programmatic controls
- Assessments performed using several approaches to assess a reactor design and determine if additional measures are appropriate to address an over-reliance on specific features or to address uncertainties
- Includes verification that two or more independent plant design or operational features are provided to meet the guidelines for each licensing basis event
- Methodology includes use of an Integrated Decision-Making Process Staff is not proposing to more universally define or impose DID criteria and seeks Commission acceptance of the NEI 18-04 approach for this specific case (see SECY-15-0168).
17
Informing Content of Applications
- NEI 18-04 provides useful guidance for reactor designers and the NRC staff for selecting and evaluating licensing basis events, identifying safety functions and classifying SSCs, selecting special treatment requirements, identifying appropriate programmatic controls, and assessing defense in depth Taken together, these activities support documenting the safety arguments and determining the appropriate scope and level of detail in applications for licenses, certifications, or approvals for non-LWRs 18
Recommendation The staff recommends that the Commission approve the use of the technology-inclusive, risk-informed, and performance-based approach described in the paper (consistent with NEI 18-04 and DG-1353) for identifying LBEs, classifying SSCs, and assessing the adequacy of defense in depth. These key aspects of the proposed approach will also be used to inform the appropriate scope and level of detail for information to be included in applications to the NRC for licenses, certifications, and approvals for non-LWRs.
19
ACRS Full Committee Meeting:
Non-power Production or Utilization Facility (NPUF)
License Renewal Rulemaking February 6, 2019 1
NRC Staff Presenters
- Robert Beall, NMSS: Rulemaking PM
- William Duke Kennedy, NRR: Acting Branch Chief
- Al Adams, NRR: Senior Project Manager 2
Purpose of the NPUF Final Rule
- Implement Commission direction to streamline the license renewal process by establishing a more efficient, effective and focused regulatory framework
- Use innovative and transformative approaches to address existing shortcomings in the current regulations for non-power licensees 9 rulemaking objectives 3
Public Comments on the NPUF Proposed Rule
- Proposed rule was published for comment on March 30, 2017 day public comment period
- Public meeting was held on May 24, 2017
- Received 16 comment submissions
- Public comments generally supported the proposed rulemaking and recommended alternative approaches to certain aspects of the rule
- The draft final rule was presented to the ACRS Subcommittee on January 23, 2019
- The TRTR Chairman stated at the meeting that the draft final NPUF rule was a win-win for the NRC and NPR community.
4
Relationship of NPUF Entities (Post-Final Rule)
Research Reactors Testing Facilities**
Class 104 licensed under § 50.21(c) or Research licensed under § 50.21(c) or
§ 50.22 for R&D; a or c
§ 50.22 for R&D; accident radiation doses accident radiation doses mission > 1 rem TEDE;
< 1 rem TEDE associated risk warrants classification as testing facility Commercial **Deletes previous power levels and notable safety considerations:
Class Medical
- Circulating loop through the 103 Radioisotope core used for fuel experiments
- Liquid fuel loading Irradiation and
- Large experimental facility in Processing the core (> 16 in2 in cross-section)
Facilities 5
- 1. Update Terms and Definitions
- Establish a single term (non-power production or utilization facility) to capture all non-power facilities Class 104 Research Reactors licensed under part 50 Testing Facilities a or c
- Revise definitions for non-power reactor, research reactor, and testing facility in response to public Medical Class 103 comment and make Radioisotope Irradiation and conforming changes* Production
- Ensure clarity and Facilities consistency for the applicability of NPUF regulations
- Text in red are changes from the proposed rule. 6
- 1. Update Terms and Definitions
- National Institute of Standards and Technology public comment
- Revise definitions of testing facility and research reactor to remove the arbitrary 10MW(t) threshold, and apply, instead, a risk-based approach to its regulation of a testing facility.
- risk is best quantified by accident analyses performed under a licensing safety analysis
- Recommended definitions refer to the proposed accident dose criterion of 1 rem (0.01 Sv) 7
- 1. Update Terms and Definitions
- NRC staff determination
- 10 MW(t) threshold, while generally based on safety significance, is not documented.
- Prescriptive power thresholds do not account for the safety features that are engineered into the facility design and those barriers that must be breached during an accident before a release of radioactive material to the environment can occur.
- Power thresholds do not accurately represent the risk associated with a particular facility.
- Use of a postulated accident dose is a more risk-informed, performance-based approach.
8
- 2. Eliminate License Terms
- Exempt Class 104a and 104c NPUFs, other than testing facilities, from 40-year fixed term in 10 CFR 50.51 Class 104 Research Reactors Testing Facilities
- No license term a or c specified in AEA for Class 104 NPUFs
- Consistent with AEAs Medical Class 103 minimum regulation Radioisotope standard Irradiation and Production
- Reduce burden for Facilities licensees and NRC, but maintains public health and safety 9
No Notable Safety Considerations
- small fission product inventory
- small radiological consequence for maximum hypothetical accident
- Low energy systems
- low operating power and temperatures
- minimal decay heat
- No significant aging considerations
- simple designs
- proactive aging management / aging-related surveillance requirements
- loss of coolant is an analyzed condition
- Slowly evolving licensing basis
- Very low number of design changes each year
- Few rulemakings apply 10
Maintaining Safety without License Renewal Class 104a or c, except testing facilities
- License renewal under NUREG-1537
- Inspection program
- Technical specifications
- Existing reporting requirements
- Safety issues with SSCs
- Maintenance activities
- FSAR Update rule requirement 11
- 3. Define the License Renewal Process
- Consolidate license renewal requirements under 10 CFR 50.135 for testing facilities and NPUFs licensed Class 104 under 10 CFR 50.22 Research Reactors Testing Facilities a or c
- Clarify license renewal process
- Licenses will be effective immediately Medical Class 103 Radioisotope
- Maintains 40-year Irradiation and term for licenses Production Facilities
- Enhance regulatory efficiency 12
- 4. Require Updated FSAR Submittals
- Extend applicability of 10 CFR 50.71(e) to NPUFs
- Ensure timely documentation of Class 104 Research Reactors Testing Facilities changes to licensing a or c basis
- Benefit knowledge management, NRCs Medical Class 103 inspection program, and Radioisotope licensee operator training Irradiation and Production and exams Facilities
- Reg Guide 2.7 provides guidance on the FSAR updates.
13
- 5. Amend Timely Renewal Provision
- Create two-year timely renewal for Class 103 and testing facilities and exempt Class 104a and 104c NPUFs, other than Class 104 Research Reactors testing facilities Testing Facilities a or c
- 30 days in 10 CFR 2.109 is not a sufficient period of time for adequate assessment of license Medical Class 103 renewal application Radioisotope Irradiation and
- Two years provides Production sufficient time Facilities
- Maintain 30-day timely renewal provision for certain facilities 14
- 6. Provide an Accident Dose Criterion
- Create new accident dose criterion for NPUFs, other than testing facilities, in 10 CFR 50.34
- Part 20 public dose limits Class 104 Research Reactors Testing Facilities are unnecessarily restrictive a or c as accident dose criteria
- Criterion would align with early phase EPA PAG and provide adequate protection Medical Class 103 from unnecessary exposure Radioisotope to radiation Irradiation and Production
- Revised the location within Facilities 10 CFR 50.34 of the accident dose criterion 15
- 7. Extend Applicability of 10 CFR 50.59
- Extend applicability to NPUFs regardless of decommissioning status Class 104 Research Reactors Testing Facilities
- 10 CFR 50.59 a or c currently is not applicable to NPUFs once fuel is Medical Class 103 moved offsite Radioisotope Irradiation and
- Avoid burden of Production issuing license Facilities amendments 16
- 8. Clarify Existing Environmental Reporting Requirements
- Add requirement in 10 CFR 51.56 for NPUFs to provide an environmental report per 10 CFR 51.45 Class 104 Research Reactors Testing Facilities
- Historically, NRC has a or c relied on 10 CFR 51.41 to collect environmental Medical information Class 103 Radioisotope
- Improve consistency Irradiation and and clarify Part 51 Production Facilities requirements for licensing actions 17
- 9. Eliminate NPUF Financial Qualification Information Requirement
- Eliminate 10 CFR 50.33(f)(2) financial qualification requirement at license renewal Class 104 Research Reactors Testing Facilities
- Primary means to a or c ensure safety is through NRCs oversight and Medical Class 103 Radioisotope enforcement programs Irradiation and
- Reduce licensee Production Facilities burden without compromise to public health and safety 18
Significant Changes from the NPUF Proposed Rule
- Revised the proposed definition of non-power production or utilization facility
- Revised the existing definitions of non-power reactor, research reactor, and testing facility
- Made conforming changes to terms and definitions throughout 10 CFR Chapter I
- Revised proposed 10 CFR 50.135 so that renewed licenses will be effective immediately
- Clarified proposed 10 CFR 50.135 to maintain 40-year terms for renewed licenses
- Maintained timely renewal provision for certain facilities
- Revised the location within 10 CFR 50.34 of the accident dose criterion 19
NPUF Final Rule Summary NPUF Final Rule Change Class 103 Class 104a Class 104c Facilities Facilities Facilities Commercial Medical R&D Testing Therapy
- 1. Update terms and definitions
- 2. Eliminate license terms N/A N/A
- 3. Define the license renewal process N/A N/A
- 4. Require updated FSAR submittals
- 5. Amend timely renewal provision
- 6. Provide an accident dose criterion
- N/A
- 7. Extend applicability of 10 CFR 50.59
- 8. Clarify existing environmental reporting requirements
- 9. Eliminate NPUF financial qualification N/A N/A information for license renewal
- Not applicable for Class 103 testing facilities 20
NPUF Rulemaking Schedule
- Final NPUF rule milestones:
- Currently in concurrence
- Public meeting on the draft final rule implementation scheduled for late February
- Due to Commission in June 2019 21
QUESTIONS?
22
BACK UP SLIDES 23
Regulatory Policy - Class 104 The policy for regulation of Class 104 NPUFs is described in the Atomic Energy Act of 1954, as amended, Section 104a. and c.
Sec. 104. Medical Therapy and Research and Development
- a. the Commission is directed to permit the widest amount of effective medical therapy possible with the amount of special nuclear material available for such purposes and to impose the minimum amount of regulation consistent with its obligations under this Act to promote the common defense and security and to protect the health and safety of the public.
- c. The Commission is directed to impose only such minimum amount of regulation of the licensee as the Commission finds will permit the Commission to fulfill its obligations under this Act to promote the common defense and security and to protect the health and safety of the public and will permit the conduct of widespread and diverse research and development.
24
Regulatory Policy - Class 103 The policy for regulation of Class 103 NPUFs is described in the Atomic Energy Act of 1954, as amended, Section 103.
Sec. 103. Commercial Licenses
- a. The Commission is authorized to issue licenses to persons applying therefor to transfer or receive in interstate commerce, manufacture, produce, transfer, acquire, possess, use, import, or export under the terms of an agreement for cooperation arranged pursuant to section 123, utilization or production facilities for industrial or commercial purposes. Such licenses shall be issued in accordance with the provisions of chapter 16 and subject to such conditions as the Commission may by rule or regulation establish to effectuate the purpose and provisions of this Act.
- c. Each such license shall be issued for a specified period, as determined by the Commission, depending on the type of activity to be licensed, but not exceeding forty years from the authorization to commence operations and may be renewed upon the expiration of such period.
25
Regulatory Definitions
- Non-power reactor means a research or test reactor licensed under §§50.21(c) or 50.22 of this part for research and development [10 CFR 50.2 Definitions].
- Research reactor means a nuclear reactor licensed by the Commission under the authority of subsection 104c of the Act and pursuant to the provisions of § 50.21(c) of this chapter for operation at a thermal power level of 10 megawatts or less, and which is not a testing facility as defined by paragraph (m) of this section [§170.3 Definitions].
26
Regulatory Definitions (cont.)
- Testing facility means a nuclear reactor which is of a type described in §50.21(c) of this part and for which an application has been filed for a license authorizing operation at:
(1) A thermal power level in excess of 10 megawatts; or (2) A thermal power level in excess of 1 megawatt, if the reactor is to contain:
(i) A circulating loop through the core in which the applicant proposes to conduct fuel experiments; or (ii) A liquid fuel loading; or (iii) An experimental facility in the core in excess of 16 square inches in cross-section. [§ 170.3 Definitions]
27
Characteristics of Current NPUF Entities Research Reactors Testing Facilities Class 104 10 MWt > 10 MWt or Research or a or c 1 MWt if mission > 1 MWt if notable safety notable safety considerations considerations Commercial Class 103 Medical Notable safety considerations:
Radioisotope
- Circulating loop through the core used for fuel Irradiation and experiments Production
- Liquid fuel loading
- Large experimental facility in Facilities the core (> 16 in2 in cross-section) 28
Presentation to the ACRS Full Committee NuScale Design Certification Application Review Safety Evaluation Report Chapter 2: SITE CHARACTERISTICS Project Manager: Prosanta Chowdhury February 6, 2019
ACRS subcommittee meeting on December 18, 2018 Topics covered:
- Geography and Demography (SRP Section 2.1)
- Nearby Industrial, Transportation, and Military Facilities (SRP Section 2.2)
- Meteorology (SRP Section 2.3)
- Hydrologic Engineering (SRP Section 2.4)
- Geology, Seismology, Geotechnical Engineering (SRP Section 2.5)
Note: Staff review is based on DCA, revision 1 (March 15, 2018)
February 6, 2019 NuScale DCA FSAR Chapter 2 - Presentation to ACRS 2
Topics and Conclusions Geography and Demography (SRP 2.1), and Nearby Industrial, Transportation, and Military Facilities (SRP 2.2)
Conclusion COL Items provided in the DCA are acceptable. The COL applicant referencing the NuScale Power Plant DC should describe and address -
site specific geographic and demographic characteristics as part of COL Item 2.1-1; nearby industrial, transportation, and military facilities to demonstrate that the design is acceptable for each potential accident or provide site-specific design alternatives - as part of COL Item 2.2-1; site specific information in a COL application should be bounded by the design parameters.
February 6, 2019 NuScale DCA FSAR Chapter 2 - Presentation to ACRS 3
Topics and Conclusions Meteorology (SRP 2.3)
Conclusion Site parameters related to FSAR Section 2.3 were postulated in accordance with 10 CFR 52.47(a)(1).
- Regional Climatology (SRP 2.3.1): Precipitation (rain/snow), winds (i.e., straight-line, tornado, hurricane), ambient dry- and wet-bulb temperatures are generally representative of a reasonable number of potential plant site locations; However, because design may be deployed in remote locations or at sites subject to harsh weather conditions, some postulated site parameter values may be challenged.
- Local Meteorology and the Onsite Meteorological Measurements (SRP 2.3.2 and 2.3.3): Local Meteorology and the Onsite Meteorological Measurements Program are site-specific and addressed by the COL applicant.
February 6, 2019 NuScale DCA FSAR Chapter 2 - Presentation to ACRS 4
Topics and Conclusions Meteorology (SRP 2.3) (contd)
Conclusion Short-Term Atmospheric Dispersion Estimates for Accident Releases (SRP 2.3.4): Open Item 02.03.04 Staff currently evaluating TR-0915-17565 (Accident Source Term Methodology) to determine if NuScale methodology is acceptable for calculating DBA offsite /Q values at EAB and LPZ in relation to NuScale design or a COL applicant referencing NuScale design.
Staff found that Applicant provided onsite /Q site parameter values at the MCR and TSC doors and HVAC intake that are representative of a reasonable number of sites that may be considered for a COL application.
Long-term Atmospheric Dispersion Estimates for Routine Releases (SRP 2.3.5): Staff found that the long-term (routine release) site parameter values selected by the Applicant are representative of a reasonable number of sites that have been or may be considered for a COL application.
February 6, 2019 NuScale DCA FSAR Chapter 2 - Presentation to ACRS 5
Topics and Conclusions Hydrology (SRP 2.4)
Conclusion In all areas of hydrology, the applicant provided adequate site parameters as well as COL Items 2.0-1 and 2.4-1. A COL applicant referencing the NuScale Power Plant DC should provide information sufficient to demonstrate that the actual site characteristics described in its application falls within the range of site parameter values consistent with COL Items 2.0-1, and 2.4-1. The staff finds the applicants information, including stipulations in the COL Items, acceptable.
February 6, 2019 NuScale DCA FSAR Chapter 2 - Presentation to ACRS 6
Topics and Conclusions Geology, Seismology, Geotechnical Engineering (SRP 2.5)
Conclusion In all areas of Geology, Seismology, Geotechnical Engineering, the applicant provided adequate information, including COL Item 2.5-1, and referenced COL Items 3.7-3, 3.7-5, 3.8-6, and 3.7-8, and specified that a COL applicant referencing the NuScale Power Plant DC should provide information sufficient to demonstrate that the actual site characteristics fall within the range of site parameter values specified in the NuScale Power Plant DC. The staff finds the applicants information, including stipulations in the COL Items, acceptable.
February 6, 2019 NuScale DCA FSAR Chapter 2 - Presentation to ACRS 7
NuScale Horizontal Certified Seismic Design Response Spectra at 5% Damping 10.00 10.00 CSDRS CSDRS RG 1.60 @ 0.3g RG 1.60 @ 0.1g CSDRS-HF 1.00 1.00 0.10 0.10 0.01 0.01 0.1 1.0 10.0 100.0 0.1 1.0 10.0 100.0 Frequency (Hz) Frequency (Hz)
CSDRS vs RG 1.60 CSDRS and CSDRS-HF February 6, 2019 NuScale DCA FSAR Chapter 2 - Presentation to ACRS 8
NuScale Nonproprietary Chapters 2 and 17 ACRS Full Committee Neil Olivier Corporate Services, Director Paul Infanger Regulatory Affairs, Supervisor 1
PM-0219-64333 Revision: 0 Copyright 2019 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
Background:
NuScale ODI Program
- NuScales Quality Assurance program is based on ASME NQA-1-2008.
- ASME NQA-1-2008 Part I, Requirement 3, Section 500, Part (b) allows the deferral of design verification activities provided the unverified portions of the design are identified and controlled.
- Open Design Items (ODIs) are a form of engineering assumption controlled under the NuScale Design Control Process. Assumptions are information or data that is selected for a design activity, other than previously validated design criteria, which are taken to be true for the sake of analysis.
- Assumptions, along with verified design inputs, describe the conditions under which design activity results are considered valid.
- Assumptions are documented and tracked
- Basis statements provide engineering justification that the assumption is reasonable
- Verifier assures assumptions are reasonable 2
PM-0219-64333 Revision: 0 Copyright 2019 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
Background:
NuScale ODI Program (cont.)
- ODIs are resolved/verified via the design verification process.
- Design Verification is required:
- Ideally before releasing the design for procurement, manufacture, or construction, or for use by another design organization (with a different QA program)
- In all cases, the design verification is required prior to relying on that SSC to perform its function 3
PM-0219-64333 Revision: 0 Copyright 2019 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
NuScale NRC Interactions on ODIs
- 2017 QA Inspection
- Training/Communication of Staff
- DCA Chapter Audits - Review of NuScale ODIs present in source documentation reviewed.
- RAIs 4
PM-0219-64333 Revision: 0 Copyright 2019 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
2017 QA Inspection Highlights
- Included review of NuScales ODI Process
- The NRC report (ML17201J382) cited:
- Review of 170 specific ODIs
- NuScale had a conservatively low threshold for opening ODIs
- No violations or nonconformances were identified
- NuScale ODI process adequately manages unverified assumptions 5
PM-0219-64333 Revision: 0 Copyright 2019 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
Conclusion
- The NuScale ODI process properly controls unverified engineering assumptions in accordance with NQA-1.
- NRC has reviewed ODI process thru various interactions:
- RAIs
- DCA Chapter Audits
- QA Inspection 6
PM-0219-64333 Revision: 0 Copyright 2019 by NuScale Power, LLC.
Template #: 0000-21727-F01 R4
Safety Evaluation with Open Items:
Chapter 17, Quality Assurance and Reliability Assurance NuScale Design Certification Application ACRS Full Committee Meeting February 6, 2019
Agenda
- NRC Staff Review Team
- Summary of the NRC Staffs Review
- Quality Assurance
- ACRS Subcommittee Questions on the Applicants ODI Process
- Reliability Assurance
- Abbreviations February 6, 2019 2
NRC Staff Review Team
- NRC Technical Reviewers
- Andrea Keim, NRO
- Mark Caruso, NRO (Retired)
- Project Management
- Omid Tabatabai, Senior Project Manager
- Greg Cranston, Lead Project Manager February 6, 2019 3
Overview of the Staff Review
- SER contains two Open Items and no Confirmatory Items,
- NRC Staff conducted two regulatory audits concerning reliability assurance program and one quality assurance implementation inspection,
- NRC Staff briefed the ACRS subcommittee on 12/18/18,
- The staff will discuss ACRS Subcommittee members questions regarding the applicants ODI process.
February 6, 2019 4
DCA, Part 2, Tier 2 Section 17.5 Quality Assurance February 6, 2019 5
Regulatory Basis
- 10 CFR Part 50, Appendix A, GDC 1 requires that QA program be established and implemented
- 10 CFR Part 50, Appendix B specifies 18 quality criteria that the QA program description must address
- 10 CFR 52.47(a)(19) requires that a standard DC applicant include a QAPD that satisfies applicable portions of Appendix B to 10 CFR Part 50 February 6, 2019 6
Topical Report Review
- NuScale submitted Topical Report NP-TR-1010-859-NP, Quality Assurance Program Description for the NuScale Power Plant, Revision 3 on March 24, 2016
- NuScale commits to NQA-1-2008 and NQA-1a-2009 addenda as endorsed by RG 1.28, Revision 4
- The NRC staff reviewed the QAPD using NUREG-0800 Section 17.5
- The NRC staff SER dated September 22, 2016 February 6, 2019 7
Staffs Review of DCA, Section 17.5
- References Quality Assurance Program Description for the NuScale Power Plant, NP-TR-1010-859-NP-A, Revision 3
- COL Item 17.5-1: A COL applicant that references the NuScale Power Plant design certification will describe the quality assurance program applicable to the site-specific design activities and to the construction and operations phases.
- Open Item 17.5-1: Additional QA implementation inspection February 6, 2019 8
QA Implementation Inspection
- June 5 - 9th, 2017
- NuScale Office Facility in Corvallis, Oregon
- Inspection Procedure 35017, Quality Assurance Implementation Inspection
- No findings of significance were identified
- QA Inspection Report is publicly available at (ML17201J382).
- Additional QA inspection is being scheduled and is listed in SER Open Item 17.5-1 February 6, 2019 9
ACRS Subcommittee Comments/Questions
- How does the staff ensure all ODIs are closed by the time DCA is approved?
- What does sufficiently closed mean?
- What if unverified assumptions change after the DCA is approved?
- ACRS Subcommittee Comment: The NRC staff should convey to NuScale that they are taking a risk by not closing all ODIs before the DCA is approved, particularly, those unverified assumptions that could trigger a Tier 1 change.
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DCA Part 2, Tier 2, Section 17.4 Reliability Assurance Program February 6, 2019 11
Reliability Assurance Program
- Staff evaluated NuScales reliability assurance program, including the design RAP (D-RAP) list in accordance with SRP Section 17.4, Rev. 1
- Staff found the RAP program sufficient in:
- Program description and implementation
- Programmatic controls
- SSC selection methodology
- Expert panel member requirements
- Determination of risk significant SSCs February 6, 2019 12
Reliability Assurance Program
- Staff found:
- the D-RAP list was developed in accordance with its RAP methodology and the D-RAP list is comprehensive.
- NuScale adequately implemented the expert panel in developing the D-RAP list.
- COL items provide reasonable assurance that the RAP for a COL applicant which references the NuScale design will be adequate.
- Open Item 17.5-2: D-RAP ITAAC (SECY-18-0093)
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Abbreviations ACRS Advisory Committee on Reactor Safeguards CFR Code of Federal Regulation COL Combined License DC Design Certification DCA Design Certification Application D-RAP Design Reliability Assurance Program GDC General Design Criteria ITAAC Inspections, Tests, Analyses, and Acceptance Criteria NRO NRC Office of New Reactors ODI Open Design Item QA Quality Assurance QAPD Quality Assurance Program Plan RAP Reliability Assurance Program SER Safety Evaluation Report SSC Structures, Systems, and Components SRP Standard Review Plan (NUREG-0800)
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