ML19218A197
| ML19218A197 | |
| Person / Time | |
|---|---|
| Issue date: | 06/05/2019 |
| From: | Derek Widmayer Advisory Committee on Reactor Safeguards |
| To: | |
| Burkhart L, ACRS | |
| References | |
| NRC-0355 | |
| Download: ML19218A197 (364) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Open Session Docket Number: (n/a)
Location: Rockville, Maryland Date: Wednesday, June 5, 2019 Work Order No.: NRC-0355 Pages 1-342 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 664th MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +
8 OPEN SESSION 9 + + + + +
10 WEDNESDAY 11 JUNE 5, 2019 12 + + + + +
13 ROCKVILLE, MARYLAND 14 + + + + +
15 The Advisory Committee met at the Nuclear 16 Regulatory Commission, Two White Flint North, 17 Room T2D10, 11545 Rockville Pike, at 8:30 a.m., Peter 18 Riccardella, Chairman, presiding.
19 20 COMMITTEE MEMBERS:
21 PETER RICCARDELLA, Chairman 22 MATTHEW W. SUNSERI, Vice Chairman 23 JOY L. REMPE, Member-at-Large 24 RONALD G. BALLINGER, Member 25 DENNIS C. BLEY, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 CHARLES H. BROWN, JR., Member 2 MICHAEL L. CORRADINI, Member 3 MARGARET SZE-TAI Y. CHU, Member 4 VESNA B. DIMITRIJEVIC, Member 5 WALTER L. KIRCHNER, Member 6 JOSE MARCH-LEUBA, Member 7 DAVID PETTI, Member 8 HAROLD B. RAY, Member 9 GORDON R. SKILLMAN, Member 10 11 DESIGNATED FEDERAL OFFICIAL:
12 DEREK WIDMAYER 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 CONTENTS 2 Opening Remarks by the ACRS Chairman . . . . . . 4 3 Reactor Oversight Program (ROP) 4 Enhancements Project . . . . . . . . . . . 7 5 Appendix D to NEI 96-07 and Associated 6 Draft Regulatory Guide for Digital 7 Upgrades under 10 CFR 50.59 . . . . . . . . 94 8 NuScale Design Certification Application 9 Chapters 3.9.2, 14, 19, and 21 . . . . . 209 10 Adjourn . . . . . . . . . . . . . . . . . . . . 342 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.
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4 1 P-R-O-C-E-E-D-I-N-G-S 2 (8:30 a.m.)
3 CHAIRMAN RICCARDELLA: The meeting will 4 come to order. This is the first day of the 664th 5 meeting of the Advisory Committee on Reactor 6 Safeguards.
7 I am Pete Riccardella, Chairman of the 8 ACRS.
9 ACRS was established by the Atomic Energy 10 Act and is governed by the Federal Advisory Committee 11 Act, FACA.
12 The ACRS Section of the U.S. NRC public 13 website provides information about the history of the 14 ACRS and provides FACA-related documents, such as our 15 charter, bylaws, Federal Register Notices for 16 meetings, letter reports, and transcripts of all full 17 and subcommittee meetings, including all slides 18 presented at the meetings.
19 The committee provides its advice on 20 safety matters to the Commission through its publicly 21 available letter reports.
22 The Federal Register Notice announcing 23 this meeting was published on April 29, 2019, revised 24 on May 24th, and provides an agenda and instructions 25 for interested parties to provide written documents or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 request opportunities to address the committee as 2 required by FACA.
3 In accordance with FACA, there is a 4 Designated Federal Official for today's meeting. The 5 DFO for this meeting is Mr. Derek Widmayer.
6 Today's meeting -- at today's meeting, the 7 committee will consider the following: Reactor 8 Oversight Program Enhancement Project and Appendix D 9 to NEI 96-07 and Associated Draft Regulatory Guide for 10 Digital Upgrades under 10 CFR 50.59, NuScale Design 11 Certification Application Chapters 3.9.2, 14, 19, and 12 21, and Preparation of ACRS Reports.
13 As reflected in the agenda, portions of 14 the sessions on NuScale Safety Evaluation Report may 15 be closed in order to discuss and protect the 16 information designated as sensitive or proprietary.
17 Additionally, in tomorrow's session, we 18 will be looking at the issue of open design items that 19 are identified as part of the design certification 20 application with a focus on unverified design 21 assumptions.
22 There is a phone bridge line. To preclude 23 interruption at the meeting, the phone will be placed 24 in the listen-only mode during presentations and 25 committee discussions.
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6 1 We have received no written comments or 2 requests to make oral statements from members of the 3 public regarding today's presentations.
4 There will be an opportunity for public 5 comment, as we have set aside 10 minutes in the agenda 6 for comments from members of the public attending and 7 listening to our meetings. Written comments may be 8 forwarded to Mr. Widmayer, the Designated Federal 9 Official.
10 A transcript of the open portions of the 11 meeting is being kept, and it is requested that the 12 speakers use one of the microphones, identify 13 themselves, and speak with sufficient clarity and 14 volume that they can be readily heard.
15 As an item of interest, I would like to 16 introduce Dr. David Petti as a new member of the 17 committee. Among the many achievements, Dr. Petti is 18 an expert in coated particle field technology.
19 Welcome, Dave.
20 (Applause.)
21 CHAIRMAN RICCARDELLA: It's not on my 22 script, but would everybody please silence their cell 23 phones so we don't have interruptions at the meeting?
24 I would like to ask Mr. Dick Skillman, 25 Chairman of the ACRS Subcommittee on Plant Operations NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 and Fire Protection, to provide any desired opening 2 remarks.
3 Dick?
4 MEMBER SKILLMAN: Mr. Chairman, thank you.
5 For those of you who may remember, there was once a 6 process called SALP, the Systematic Assessment of 7 Licensee Performance. And, fortunately, that system 8 has been displaced by the Reactor Oversight Process, 9 and over the course of years the staff has refined and 10 refined and refined the ROP. And I think it's fair to 11 say with the transformation initiatives that are 12 underway, NRR is still transforming and improving the 13 ROP.
14 So today I thank the members from NRR to 15 come and brief us. I've got to say up front, I must 16 say up front that credit goes to Derek for driving 17 this. I've been a passenger on this effort. So, 18 Derek, thank you.
19 And I'm going to turn the presentation 20 over to Mr. Russell Gibbs. Sir, please proceed.
21 MR. GIBBS: Thank you very much. Before 22 I begin, Billy Dickson, the Deputy Director of 23 Division of Inspection and Regional Support, will 24 provide some remarks.
25 MR. DICKSON: Good morning. My name is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 Billy Dickson. I am the Acting Deputy Director for 2 the Division of Inspection and Regional Support in the 3 Office of Nuclear Reactor Regulations, NRR.
4 So the purpose of today's briefing is to 5 provide an overview of the Reactor Oversight Process, 6 the ROP Enhancement Initiative.
7 Today's staff presentation represents 8 NRR's effort to -- in addressing a number of 9 recommendations received from the NRC transformation 10 team in May of 2018 for enhancement of ROP.
11 The team also addressed a number of 12 recommendations for enhancement of ROP from NEI, the 13 Nuclear Energy Institute, in a letter to the NRC dated 14 September 2018.
15 The ROP Enhancement Initiative started in 16 October of 2018, and from the start of this effort we 17 have continuously received feedback from both our 18 internal and external stakeholders that the element --
19 the key elements of the ROP are sound.
20 The Baseline Inspection Program is a 21 mature program that has had a demonstrated period of 22 success over the past 19 years or so. The 23 infrastructure is good. The focus of this initiative 24 is continuous improvement.
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9 1 worked extensively with the regional offices during 2 the disposition of all the recommendations, especially 3 those dealing with the Inspection Baseline Program.
4 In fact, under the advisement of the project's 5 executive sponsor, Ho Nieh, the Director of NRR, a 6 regional advisory panel was established. And Ho Nieh 7 is in the -- in the audience here. So we have also 8 conducted monthly public meetings with NEI since 9 October 2018 to discuss the outcomes of a staff 10 evaluation for each these recommendations.
11 Before I introduce the staff that will be 12 giving the presentation, which is Russell Gibbs, who 13 has already been introduced, I would like to say that 14 most of these initiatives, this is not a one-and-done 15 effort. And we -- there is an expectation for SECY 16 paper to be delivered to the Commission at the end of 17 this month, with the EDO's approval.
18 With that said, again, I wanted to 19 introduce Russell Gibbs. He is the project manager 20 for the ROP Enhancement Initiative, and also Ami 21 Agrawal, who is the acting branch chief in the 22 Division of Inspection and Regional Support.
23 Thank you. Russell?
24 MR. GIBBS: Okay. Good morning, everyone.
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10 1 mentioned the SECY that will be going out. Are the 2 presentations today pretty much in line with what you 3 expect to have in the SECY?
4 MR. GIBBS: That's correct. Yes, sir.
5 MEMBER BLEY: Okay.
6 MR. GIBBS: Okay. Good morning, everyone.
7 It's a pleasure to be here to talk to you about ROP 8 enhancement. Thank you, Billy, for those -- for those 9 opening remarks.
10 This first slide here on the background, 11 let me just say a couple of things about these 12 recommendations. The 72 we received from the --
13 mainly from the staff were very good. Some of them 14 were, frankly, really transformative in nature. At 15 this time, we don't believe the ROP is in need of a 16 transformation.
17 Now, back in 1998 and 1999, as Mr.
18 Skillman said, indeed, we did need to transform our 19 oversight program. At this time, indications are, 20 based on feedback from our internal stakeholders and 21 our external stakeholders, that the ROP is a sound 22 program. We believe it is doing what it should be 23 doing in providing effective oversight of nuclear 24 reactors in the United States.
25 Having said that, we can always improve.
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11 1 So, really, what we're going to be talking today about 2 are some of the -- we'll call it the first phase of 3 ROP enhancement, some of the improvements that we 4 believe are necessary to continue this journey of 5 maintaining and growing our oversight program for 6 nuclear reactors.
7 The Commission has been very interested in 8 this. In fact, in the fall of last year at an 9 operating reactor business line meeting, of course, a 10 budget meeting, and the staff's presentation on 11 transformation, ROP enhancement was discussed.
12 So I think the Commission is very much 13 looking forward to receiving our paper with the 14 recommendations that we have to further improve this 15 project. As we indicated -- as Billy indicated, the 16 program -- this project began in October of last year.
17 A lot of work has been done in the last several 18 months. And so it has been a very busy time, but we 19 believe we have gotten much accomplished.
20 So let's reflect back on the goals of what 21 we're doing here. One is to make this ROP even more 22 risk-informed and performance-based than it already 23 is. You know, over the years, our understanding of 24 risk has improved. Our tools have improved. Our 25 knowledge of risk information has improved, both with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 industry and with staff.
2 So we see a few opportunities to make it 3 even better. With respect to being performance-based, 4 again, a fundamental shift in what we did from the old 5 SALP program.
6 We believe there has been enough 7 experience over the last 19 or 20 years to indicate 8 that, for example, the TR inspection program could be 9 revisited to determine if there are some efficiencies 10 in that program taking into account the performance of 11 the nuclear industry over the last 20 years.
12 Secondly, and really importantly, as we go 13 through this project, the first phase of ROP 14 enhancement, and whatever we do in the future, we need 15 to keep our principles of good regulation at the 16 forefront of what we do. And we have a number of 17 examples I think that will indicate that we are, in 18 fact, doing that.
19 We have examples of showing that we 20 continue to need to be an independent regulator. We 21 have examples of improving the clarity of the 22 oversight program.
23 With respect to openness, as Billy 24 indicated, there is many, many exchanges between 25 ourselves and industry about what we're doing. And so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 we continue to be open about that.
2 I don't know if you know, but we meet with 3 the industry every month to talk about the reactor 4 oversight process. Reliability, of course, is very 5 important. It's an interesting situation between 6 reliability and efficiency. It's very important that 7 we balance those two -- those two principles within 8 our oversight program.
9 We need to get it right. We need to come 10 to the right answer, but we need to do it in an 11 efficient manner as well.
12 Yes, sir.
13 MEMBER BLEY: What's ICORE?
14 MR. GIBBS: Okay. ICORE, independence --
15 it's our acronym for the principles of good 16 regulation, which are independence, clarity, openness, 17 reliability, and efficiency.
18 MEMBER BLEY: You started by saying you 19 had 99 recommendations from inside and outside. Were 20 they all substantive?
21 MR. GIBBS: Indeed. Some of them were 22 quite transformative in nature. For example, our 23 nuclear industry suggested, for example, that we 24 eliminate the problem and identification/resolution 25 biennial team inspection. We don't agree with that.
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14 1 That's would be a substantive change to the program.
2 However, because, as you know, the PI&R 3 program, problem identification and resolution, is 4 fundamental to an effective oversight program. But 5 could we make improvements? Indeed, we can.
6 And so what we plan to do, as I'll mention 7 later, is to do a more in-depth, comprehensive review 8 of the problem identification and regulation --
9 resolution inspection program to see if we can make it 10 even better.
11 That's more about efficiency and 12 reliability with respect to our principles. Does that 13 answer your question?
14 MEMBER BLEY: Look forward to hearing what 15 you have to say.
16 MR. GIBBS: Oh, good. Anyone else?
17 MEMBER REMPE: Well, when you're talking 18 about some of these transformative, out-of-the-box 19 thinking recommendations, a couple of them caught my 20 eye in the table. There was the one about eliminate 21 the regional offices and bring it all back to the 22 headquarters.
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15 1 promote some consistency. Obviously, the downside 2 would be less familiarity with plants and a lot of 3 travel costs that -- are those going to receive the 4 same type of scrutiny in the future?
5 Or another one was to get rid of the SPAR 6 models and use industry models. And so some of those 7 have some -- you know, they're pretty significant, and 8 I'm just curious on how they will be addressed.
9 MEMBER BLEY: So, and they don't seem part 10 of this program to me.
11 MEMBER REMPE: Well, I think it's the 12 longer term is what I'm hoping to hear.
13 MR. GIBBS: Well, a couple of things.
14 SPAR models, let me -- let me comment on that with 15 respect to our principles of good regulation and 16 independence. We believe our SPAR models are 17 necessary for us to do our job.
18 They are very helpful for us in 19 understanding, for example, the risk significance of 20 a licensee performance deficiency; us performing our 21 own evaluation, using our own tools, to come to a 22 regulatory decision. Not to say that we don't engage 23 with industry -- we do -- as part of that solution.
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16 1 of the models, they know and you know, a few inputs 2 are what drive the results.
3 MR. GIBBS: Of course.
4 MEMBER REMPE: And coming to consistent 5 inputs to me before you waste time to do the analysis 6 seems like a common sense resolution. And I, again, 7 don't see that addressed yet, and it seems like that 8 one would have been a quick fix.
9 MR. GIBBS: We will talk about that.
10 MEMBER REMPE: Okay. But you hit the nail 11 on the head. The influential assumptions that go into 12 a risk calculation are paramount. And, you know, we 13 may agree or we may disagree with industry about what 14 those influential assumptions are.
15 They would typically be, for example, how 16 long the performance deficiency has been in effect 17 with respect to the degraded condition. It could be 18 a modeling of common cause failures, which is a really 19 important aspect of a probabilistic risk assessment.
20 Or it could be human error probability, 21 for example, how much time does the operator have to 22 perform the recovery of the degraded condition. The 23 more time, the less likely of failure. Sometimes we 24 do not agree with the -- with the industry in these 25 areas.
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17 1 But you're exactly right. With respect to 2 the regional offices, where are we going in the 3 future, number of inspectors, et cetera, combining 4 offices, whatever that might be, that is out of scope 5 of ROP enhancement. We are not evaluating that. That 6 is for a future NRC initiative to address that.
7 MEMBER REMPE: Okay.
8 MR. GIBBS: So we will be --
9 MEMBER REMPE: It will be thought about in 10 the future.
11 MR. GIBBS: Absolutely. We will be 12 essentially taking those recommendations and 13 transferring them to the -- to the executive director 14 of operations for operation there, so an assessment 15 that they may doing in the future.
16 MEMBER REMPE: Thank you.
17 MR. GIBBS: Yep. you're welcome.
18 MEMBER SKILLMAN: I'd like to make a 19 comment about the SPAR models. I spent over 10 years 20 as a director in engineering at TMI-1, and there were 21 a number of times we had an exigent issue. We were in 22 communication with the region and our PRA specialist 23 in GPU, were communicating directly to the region PRA 24 specialist.
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18 1 contrast and sometimes support between our PRA 2 specialist and the NRC staff at King of Prussia, they 3 are having the SPAR models at their instant access, 4 allow them to give a very good first cut understanding 5 of significance to the regional administrator, because 6 we knew that the next action would be our leadership 7 with regional leadership.
8 And so I would be one who would say don't 9 get rid of the SPAR models because that independence 10 sometimes challenged us to be better at what we were 11 doing at the site. But I would say the flip side was 12 also true. We might have had risk insights that the 13 region did not appreciate that allowed them to adjust 14 their SPAR model.
15 So this was not inside trading. This was 16 not collusion. This was two independent groups of 17 individuals who really knew their -- knew their tools 18 and their technology, and we were able to avoid, in 19 some cases, a violation. In other cases, it became 20 abundantly clear that we were out of the box, and 21 there would be no surprise for what was going to be 22 occurring.
23 But that relationship I thought was one of 24 the strongest and most beneficial ones that I 25 experienced up in Region I. The relationship between NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 the corporate risk specialists and the NRC staff 2 region PRA -- there's a special name for those 3 individuals, but --
4 MR. GIBBS: Yes. Senior reactor analyst.
5 MEMBER SKILLMAN: The analysts, the 6 analysts in region. That was really invaluable.
7 MR. GIBBS: Yes, sir. In fact, our SRAs 8 or senior reactor analysts are fundamental to the 9 significance determination process, a process we used 10 to determine the significance of licensee performance 11 deficiencies.
12 But let me add to the SPAR model just one 13 thing. Sometimes people forget that SPAR models are 14 also very useful in event response, which is, by the 15 way, one of the primary responsibilities of NRC. If 16 something happened at a plant, we need to know if we 17 need to respond to that plant or not.
18 So we use those models to help us in a 19 very timely manner, as Mr. Skillman indicated, to 20 respond to the plant.
21 MEMBER BLEY: Just a note for the 22 committee. I don't know if everybody got wind of it, 23 but last week there was a Commission meeting with the 24 research staff. And there was fairly extensive 25 interaction between the Commission and RES and with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 the industry on the SPAR model issue.
2 And some of the others I included that --
3 high-energy arc faults, which don't seem to have 4 disappeared, but I think that webcast is probably 5 available, archived, if we need to take a look at it.
6 MEMBER SUNSERI: Russell, I just have one 7 question. I want to make sure I'm on the same page as 8 you. When you talk about efficiency, does that 9 include timeliness of the identification of issues?
10 MR. GIBBS: Yes, sir.
11 MEMBER SUNSERI: Because it seems like we 12 would lose focus if we're working on things too far in 13 the past versus -- I mean, so timeliness is part of 14 your model?
15 MR. GIBBS: Indeed it does. That's 16 important for us as regulators, to be timely, such 17 that we know the problem -- about the problem and what 18 the licensee is going to do about it. Otherwise, we 19 don't know exactly what's going on, and has the issue 20 really been addressed.
21 So it's important to return that facility 22 back to its, if you will, normal or nominal plant 23 risk. And so timeliness is indeed an important 24 feature of efficiency; of course, resources as well.
25 MEMBER SUNSERI: Thank you.
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21 1 MR. GIBBS: I will mention one other 2 thing. We'll maybe get to it. I'm just -- you know, 3 this communication between licensees and NRC in the 4 midst of determining significance of inspection 5 finding or the significance of a plan event, but 6 primarily with respect to inspection, we have taken 7 some action to improve those communications early on.
8 It's called inspection finding resolution 9 management. It's a relatively new process change we 10 made where the NRC engages with industry very early --
11 very early in the process to make sure we have some 12 alignment on those influential assumptions that we --
13 that we talked about earlier, because like you said, 14 if you go down that path of doing all of the analysis 15 and you're not -- you're totally misaligned on those 16 inputs, then that's, of course, going to create some 17 disagreement, frankly, about the solution that you 18 might reach some weeks later.
19 MEMBER REMPE: Clearly, you can't always 20 come to agreement. But if you understand that, you'll 21 understand the output you get and what's causing it, 22 and so I hope that is done.
23 MR. GIBBS: Exactly. Yep. Okay. A few 24 of the --
25 MEMBER RAY: Wait. I was waiting for a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 pause, but it wasn't working. I, too, have been a 2 licensee, and I guess there is one thing that I'd like 3 to ask, which is, if you have a lot of very low 4 significance issues, as determined by the significance 5 determination process, does the fact that they're 6 repetitive make a difference?
7 MR. GIBBS: Indeed.
8 MEMBER RAY: And how do you incorporate 9 that into the process?
10 MR. GIBBS: So that question is part of 11 the problem identification resolution program. So if 12 -- even if a problem is of very low safety 13 significance, and it keeps repeating, that's a 14 problem. And so we need to identify that as part of 15 our PI&R program, but we also have another program.
16 It's called the cross-cutting issues program.
17 The cross-cutting issues program that we 18 will speak about in a moment is one of the areas that 19 we are going to be doing some work on to see if we can 20 -- we are going to do an effectiveness review to make 21 sure it's doing what we want it to do, to capture 22 those issues of very low safety significance.
23 MEMBER RAY: Well, yeah. And that's fine.
24 You're going to get to it, and I will probably keep 25 quiet then. But I just want to say that, to me, is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 the most important thing is whether you recognize the 2 symptoms of an underlying problem.
3 MR. GIBBS: Right. Absolutely.
4 MEMBER RAY: Okay.
5 MR. GIBBS: By the way, about 95 percent 6 of all of the inspection findings in the United States 7 are very low safety significance. That's -- it sounds 8 like a very good thing to me. But those items that 9 are not of very low safety significance, we need to 10 make sure we get those right, and as they will become 11 more and more significant, even righter, so we --
12 because we need to make sure that those are corrected.
13 MEMBER SKILLMAN: Russ, is that 95 percent 14 a gratuitous 95 percent, or are you -- are you 15 repeating fairly close to dead-on accurate 95 percent?
16 MR. GIBBS: It moves anywhere probably 17 from -- over the years, it has actually become more --
18 less significant. So I think more recently it has 19 moved possibly even higher than 95 percent, because 20 we're receiving -- we're seeing less risk significant 21 inspection findings over the last several years.
22 MEMBER SKILLMAN: So the 95 might really 23 be 97 or 96 or --
24 MR. GIBBS: Could be.
25 MEMBER SKILLMAN: -- 98.
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24 1 MR. GIBBS: It's a very high number.
2 That's the point.
3 MEMBER SKILLMAN: Thank you.
4 MEMBER BLEY: That number doesn't give me 5 as much confidence as it sounds it gives you. Maybe 6 even talk about this a little bit.
7 MR. GIBBS: Sure.
8 MEMBER BLEY: I have a valve that an 9 inspection finds is in a condition so it's likely it 10 wouldn't operate properly. I look at my PRA model, 11 and this particular valve and this particular system 12 is backed up with lots of redundancy and diversity, 13 and, therefore, it has no real impact on risk.
14 But if the same problem that affected this 15 valve affected this valve over here, it would have 16 very high --
17 MR. GIBBS: Sure.
18 MEMBER BLEY: -- risk significance. Do 19 you look for that?
20 MR. GIBBS: Yes.
21 MEMBER BLEY: Do you look for that 22 connection, and how do you do that?
23 MR. GIBBS: We look -- it's called extent 24 of condition, and the more significant an item is, the 25 more we look to see if there are other problems. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 look -- by the way, this is the responsibility of the 2 licensee. They are responsible for this -- for this 3 search, and, of course, we're going to be making sure 4 that they -- that they do that. That's part of our 5 problem identification and resolution inspection 6 program.
7 MEMBER BLEY: You kind of answered me in 8 the same words you started with.
9 MR. GIBBS: Okay.
10 MEMBER BLEY: If it's a significant one, 11 then we get deeper. It's this idea of potential 12 significance that I was hanging on there, and, you 13 know, maybe it's due to a maintenance problem. And, 14 really, the issue is it's a maintenance problem, and 15 that could have high risk significance, even though 16 this particular event does not.
17 MEMBER BLEY: Yes. Indeed.
18 MR. GIBBS: So --
19 MEMBER BLEY: Okay.
20 MR. GIBBS: -- the inspections try to 21 expand on it.
22 MEMBER RAY: Well, Dennis, you're right.
23 But even more subtle common cause or extent of 24 condition is lack of effective oversight in general.
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26 1 lack of oversight of things that are taking place.
2 And I just want to feel confident that you 3 would recognize that in assessing extent of condition 4 of a small minor issue like Dennis mentioned.
5 MR. GIBBS: Right. The reactor oversight 6 process is risk-informed and performance-based. And 7 that is a very powerful goal of what we're trying to 8 accomplish. Let's, again, reflect upon the licensee's 9 responsibility. It's their responsibility to maintain 10 these plants, meet the regulations, and maintain these 11 plants in a safe manner. We're there to make sure 12 they do, right?
13 And for more -- as an issue becomes more 14 and more significant, we engage more and more. This 15 is a graded approach to regulatory oversight. But you 16 make good point. If -- and, by the way, it's a 17 current issue that we're thinking about.
18 Suppose a plant is in column 1 of the 19 action matrix. They're not -- they're not proceeding 20 down the path of reduced performance with respect to 21 our system process. But what if there are a number of 22 low, very low, safety significant issues? What should 23 that -- what does that mean to us? And how should we 24 respond to that?
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27 1 at this time.
2 MEMBER RAY: Well, I'm glad to hear that.
3 We don't need to dwell on it anymore, in my 4 standpoint. But I'll just tell you, again, from an 5 experience standpoint, it often reflects a lack of 6 I'll call it management oversight or licensee --
7 whatever you want to call it. But it produces these 8 symptoms for a long time, and then all of a sudden the 9 same problem results in something much more 10 significant that could have been avoided.
11 So I think you should keep a focus on that 12 in my comment.
13 MR. GIBBS: We agree. Thank you.
14 MEMBER SUNSERI: Well, that would be -- my 15 experience is that would be reflected in the trending 16 program, which is a subcomponent of the PI&R, right?
17 So Dennis' issue, while that behavior that caused that 18 value failure on an insignificant valve might be 19 considered lucky, the plant probably wouldn't take any 20 action unless there was a trend of those kind of 21 failures, right?
22 MR. GIBBS: And, by the way, they are 23 supposed to be looking at other plants as well, as 24 part of operating experience.
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28 1 a lot. If you look at really severe events that have 2 happened that have generated higher levels of 3 inspection following the event, they almost always 4 have a link to a corrective action program that isn't 5 working well. Is that part of the inspection process, 6 looking at their corrective action program?
7 MR. GIBBS: Indeed. It's one of the most 8 fundamental parts of our inspection program. Every 9 inspection procedure that we perform, there is about 10 a 10 percent effort on problem identification 11 resolution. That's one aspect, and we perform a great 12 deal of inspection.
13 We also look at the problem identification 14 resolution program every six months, sort of 15 collectively, and every year. And then we go back as 16 a team and we go look at it currently every two years.
17 And so one of the questions that we are 18 asking ourselves now, can that entire process be 19 optimized?
20 MEMBER BLEY: Okay. And I'm just thinking 21 about finding the problem and problem resolution in 22 the corrective action program. That's a little tricky 23 to reflect into the risk measures that we usually use 24 for this program. So how do you do that? Is it just 25 more a judgment process looking at those things?
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29 1 MR. GIBBS: Okay. So a risk-informed 2 program doesn't mean that we are overrelying on PRA 3 calculations. It also has other aspects of how we 4 assess performance. And one of those critical areas 5 is the health of the PI&R program. We have to have 6 confidence that the PI&R program at a licensee is 7 robust and healthy. If we don't, then we can -- we 8 can take action.
9 We can go as far as a deviation from our 10 program. In the current program, we can deviate from 11 the program if we believe there is sufficient evidence 12 to show that we should. So we have flexibility in our 13 process to deal with these situations. Okay?
14 MEMBER BLEY: And if we bring up anything 15 that you've got slides on later, just tell us.
16 MR. GIBBS: Glad to have this discussion 17 with you.
18 Objectives of the ROP enhancement project, 19 as we have been talking about quite a bit, we try to 20 focus on issues of higher safety significance. When 21 I say "focus," I mean we spend more time and energy on 22 those areas.
23 We want -- however, we want our program 24 itself to be able to deal with those issues of lower 25 safety significance as well, particularly in a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 collective manner with respect to PI&R and human 2 performance, which is also very, very important in the 3 risk profile of a facility.
4 In terms of enhancing the significance 5 determination process, we have made great strides over 6 the years, but we believe we can do better. In fact, 7 currently, there are a number of issues --
8 infrastructure issues that we're looking at to further 9 improve the program, and so we're looking at treatment 10 of human error probability.
11 Common cause failure modeling is another 12 area. We're looking at our tools, particularly the 13 phase 1 screening tools and the significance 14 determination process, to make sure they're doing what 15 we want them to do, that they're not overly 16 conservative or vice versa.
17 We do not want something to screen as very 18 low safety significance if, in fact, it's of higher 19 significance.
20 MEMBER CORRADINI: Does research help you 21 with that? Does RES help with you with that sort of 22 improvements of the tools?
23 MR. GIBBS: Our main source of that is our 24 Division of Risk Assessment in NRR, which has a very 25 close relationship to research. Research is our --
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31 1 MEMBER CORRADINI: So you go through --
2 you go through that division if you need help.
3 MR. GIBBS: Yes, we do.
4 MEMBER CORRADINI: Okay. Fine.
5 MR. GIBBS: Yep. Of course, we talked 6 about improving the inspection program. We believe 7 it's a robust program, but we do believe that there 8 can be some efficiencies gained in the program, 9 particularly in light of what we've seen with respect 10 to industry performance over last -- over the last 20 11 years, and, frankly, what we have learned implementing 12 this program over these -- over these years.
13 We talked earlier about improving 14 communications with industry. We just want to make 15 sure in the final determination that at least we have 16 an understanding of their position and that we 17 document that as needed.
18 A few guiding principles. You know, we do 19 a reactor oversight process self-assessment every 20 year, and it's a very robust program. So ROP 21 enhancement is in addition to what we're already 22 doing. I think there are some -- I see Bob Kahler in 23 the room here for emergency preparedness. Thank you, 24 Bob, for coming.
25 Our Emergency Preparedness Division, they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 have -- they have been performing a great deal of work 2 with respect to a focused self-assessment of emergency 3 preparedness. So what we did -- what we have done is 4 we try to leverage what Bob is doing in emergency 5 preparedness as part of ROP enhancement.
6 Security -- same thing. The security area 7 has spent a lot of time improving their program.
8 So we're trying to take advantage of some 9 things that we're already doing.
10 By the way, we want to maintain the 11 strengths of the reactor oversight process. The 12 inspection program is a strong program. We believe 13 the significance determination process is strong. Our 14 assessment process is strong, and we continue to get 15 feedback in that regard.
16 But as I said, can we improve? Of course 17 we can. And so what we're trying to do is make some 18 of these -- some of these improvements to the program 19 and maintain the strengths of what we do, because we 20 do believe, not just us by the way, again, industry 21 believes it's a strong program.
22 In fact, our program has been -- has been 23 a model for several countries around the world. In 24 fact, Japan is the most recent member or regulator who 25 is adopting some of the ROP principles, because of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 this robustness.
2 But anytime we make a change to the 3 program, we need to understand the basis of what we're 4 doing, the basis of what we do now, and how we're 5 impacting that basis. It's very important that we do 6 that. We need to articulate that to help all of our 7 stakeholders understand why we're making the change.
8 The question is: what's the problem?
9 What are we trying to correct? And then why is that 10 different than what we had originally assumed?
11 We have a couple of examples in ROP 12 enhancement in that regard. As Billy indicated, many, 13 many meetings that we've had with industry, I think 14 we've had over 10 public meetings since ROP 15 enhancement began. Again, we meet with industry every 16 month, and we've had other meetings as well, to try to 17 gain some understanding about their views, tell them 18 what we're thinking, we get feedback from them.
19 And one of the things that we're doing 20 very carefully as part of this project is taking into 21 account these alternative views, and we're actually 22 documenting those in the commission paper that we will 23 present to the Commission at the end of this month.
24 On project infrastructure, I just wanted 25 to give you a sense of some of the things that we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 been doing. Ho Nieh, our director, is our executive 2 sponsor, and, Ho, it has been -- it has been fabulous 3 that you have been working with us.
4 I think the notion of the development of 5 a regional advisory panel -- Ho's idea -- was great, 6 because as we reach out to the regions, the regions 7 need to understand what we're doing, and we need their 8 input, and we've been using the regional advisory 9 panel, which are SES executives, to help us in that 10 regard.
11 With respect to the recommendations 12 received, the 99, the ones that were in scope, we put 13 them in various -- into various themes, such as 14 inspection, SDP, significance determination process, 15 performance indicator program, emergency preparedness, 16 security.
17 Also, sort of an add to the program that 18 we somewhat did not expect was the -- our inspection 19 programs for independent spent fuel storage 20 installations. So that's a part of the program. We 21 are working with our office of NMSS to help us in that 22 regard.
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35 1 leader for ROP inspection, for example. I was -- I am 2 the overall team leader for this effort. It has 3 involved a lot of people, a lot of staff, a lot of 4 interactions with industry.
5 We are taking this very seriously. It's 6 one of the most, if not the most, important 7 initiatives within the office of NRR.
8 There's a public website, lots of 9 management tools, because what we find in this 10 project, it has been moving fairly quickly. We need 11 to have very good tools to help us manage this 12 program, and we believe we do.
13 As Billy indicated, we are -- we are close 14 to getting this commission paper ready for the 15 Commission. I believe we are going to -- Dan Merzke 16 is here, our primary author of this paper. Thank you, 17 Dan. It is with our OGC, Office of General Counsel, 18 now, and we expect an NLO, no legal objection, from 19 them tomorrow.
20 And then Ho Nieh will take a look at the 21 paper, and then -- and then we're going to submit it 22 to our EDO we hope on the 17th of June. If that goes 23 well, we'll meet this end-of-June deadline.
24 MEMBER BLEY: I don't mean to be 25 insulting. All you're saying sounds good, but it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 very high level and it could mean almost anything.
2 The SECY paper, does that get very specific about the 3 changes you are proposing to make?
4 MR. GIBBS: Absolutely.
5 MEMBER BLEY: Okay.
6 MR. GIBBS: Let me -- I mean, let me tell 7 you something about that. We will get to it in a 8 minute, but I'll just -- I'll say it now.
9 The Commission has on multiple occasions 10 commented in public meetings that they believe the ROP 11 is a strong program. In fact, they believe it's 12 sufficiently robust that if we elect -- if we're going 13 to change the program, they issued a staff 14 requirements memorandum that they need to be either --
15 they need to either approve certain changes or they 16 need to be notified of certain changes prior to the 17 change.
18 There are some changes we are making that 19 fit that -- that fit that. So, yes, and we're going 20 to get into some of those details in just a moment 21 about some of the things that we're going to be 22 changing. Yeah, we'll get to it.
23 All right. So here are some completed 24 actions already. Now, these items did not require 25 Commission approval, nor notification, but just to let NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 you get a sense for some things we've already done.
2 Industry believes -- has provided comments 3 to us that they do not believe we should issue a press 4 release for a white inspection finding. A white is a 5 finding in the -- and it's currently of low to 6 moderate safety significance. We're going to suggest 7 that it be changed to a finding -- inspection finding 8 of low safety significance, and we'll talk about that 9 in just a moment.
10 MEMBER BLEY: Okay. Because I'm not sure 11 what the distinction was you just made.
12 MR. GIBBS: The distinction is is that we 13 have guidance about when to issue a press release for 14 a white finding. We have, on very rare occasion, not 15 adhered to that guidance.
16 One or two examples. Okay? Now, what 17 we're doing is we want to -- we have reinforced that 18 guidance with our Office of Public Affairs, because 19 they own this guidance. It's really their program.
20 Okay?
21 Appendix M, Appendix Mike, this is a 22 procedure we use in the SDP process. We use it when 23 we don't have a tool to determine significance of an 24 inspection finding or we use it when we're finding 25 that the tool we have is not working very well. It's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 not used that often.
2 We were earlier trying to revise this 3 procedure to make it more robust with respect to entry 4 conditions, with respect to, you know, what are the 5 decision-making criteria which are, by the way, Reg 6 Guide 1.174, which is a risk-informed approach to 7 regulatory decision-making.
8 But also, to integrate the results of 9 those decisions we make about the individual elements 10 of Appendix M into a more holistic, comprehensive 11 decision. We went down that path and decided that we 12 needed to pause and really focus on the entry 13 conditions and give guidance to the analysts and to 14 the decisionmaker about how to assess each of the 15 decision attributes. And that's where we landed with 16 this revision to Appendix M, and the industry agrees 17 that that is a good revision to this procedure.
18 Initially, you know, one of the 19 recommendations was to just stop work on Appendix M.
20 Well --
21 MEMBER BLEY: Well, there was -- we saw a 22 little bit of this a few years ago. And I know from 23 industry, and maybe from Congress and a few other 24 places, there was some real concern about moving away 25 from quantitative and back to qualitative criteria.
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39 1 So you're actually changing the guidance 2 to people for when they -- when it's appropriate to go 3 to qualitative criteria.
4 MR. GIBBS: Yes. And giving them guidance 5 on how to assess those attributes, to make it as 6 objective and predictable as much as possible. Okay?
7 Improving communications with licensee 8 about inspection results. I had mentioned that 9 earlier. This is the inspection finding resolution 10 management program. We believe -- it is already -- we 11 have already seen some improvements in this program.
12 A few years ago, we were seeing inspection 13 findings that were greater than green. That would be 14 white, yellow, or red. They were taking us a really 15 long time to come to resolution, and we were trying to 16 understand why. Some of it was about our 17 communications with the licensee, not really getting 18 alignment about what's going on, an understanding at 19 least. And so we have made some changes in that 20 regard. That procedure I think was issued in 2016.
21 Here are some early opportunities. Some 22 feedback we got from industry, in terms of right 23 sizing inspection follow up specifically for white 24 inspection findings. This is a supplemental 25 inspection, inspection procedure 95001. Two things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 that we're focusing on right now.
2 One, do we need to spend the level of 3 resources on that supplemental inspection as we have 4 over the last few years? We believe that we can, but 5 more importantly, I believe, is that this procedure 6 has spelled out -- has indicated that licensees 7 perform a root cause evaluation for a white inspection 8 finding when, indeed, in a risk-informed program, a 9 causal analysis is sufficient.
10 And so if a licensee is performing a root 11 cause for every inspection finding that is of white 12 significance, this takes a lot of time. The question 13 is -- and takes a lot of resources. The question is, 14 in a risk-informed program, is this necessary?
15 So we're going to -- we are right now in 16 the process of revising inspection procedure 95001 to 17 address this item.
18 Another thing with respect to clarity, 19 right now, a green inspection finding is a very low 20 significance. We are not changing that. It makes 21 good sense. A white inspection finding right now says 22 from low to moderate. It's the only one that has a 23 range, if you will. We don't believe that's good in 24 the spirit of clarity. We want to change that to low 25 safety significance.
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41 1 A yellow inspection finding in this 2 program is right now considered substantial. And a 3 high -- or a red is considered high. I don't know 4 about you, but "substantial" sounds more important 5 than "high." We're actually changing the substantial 6 characterization of a yellow to moderate, and then we 7 will not do anything with red.
8 So we will end up with very low for green, 9 low for white, moderate for yellow, and high for red.
10 We believe that's more understandable.
11 MEMBER BLEY: Makes sense to me. Dick, 12 two things. Didn't we write a letter on this issue of 13 not attacking every white finding on --
14 MEMBER SKILLMAN: Yeah. About two years 15 ago we did.
16 MEMBER BLEY: That's what I thought. And 17 I think the concern we were left with was it seemed 18 reasonable, as long as if that same white finding 19 crops up multiple times, then we ought to be elevating 20 it.
21 MR. GIBBS: Then that will fit into our 22 assessment process. Multiple times would indicate 23 that that licensee will shift to the right on the 24 action matrix, and we will be doing a more in-depth 25 inspection.
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42 1 MEMBER BLEY: Is it possible for you to do 2 like a two-minute summary of the action matrix?
3 Because I'm not sure all of the members are familiar 4 with that.
5 MR. GIBBS: Sure.
6 MEMBER BLEY: Some are, some are --
7 haven't gotten into that in great detail.
8 MR. GIBBS: So we consider the action 9 matrix a strength of the ROP. One of the big 10 differences between SALP and the ROP, one of the big 11 ones, is the action matrix. It's a very predictable 12 regulatory oversight tool.
13 There is no question where a licensee is 14 going to be with respect to performance, our 15 assessment of their performance using this action 16 matrix. It has several columns.
17 When a licensee is taking care of business 18 and there is no, if you will, greater-than-green 19 inspection finding or performance indicator, they are 20 in column 1 -- column 1 of the action matrix.
21 Column 2 happens when a greater-than-green 22 inspection finding is identified. White, for example.
23 If a white inspection finding is identified, we will 24 move into a column 2, which requires a regulatory 25 response, which is a supplemental inspection.
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43 1 And then as it goes to the right, you get 2 into what is called the degraded cornerstone column.
3 And I think what you're mentioning, there is about, 4 you know, with repetitive failures, then the licensee 5 might move into column 3 of the action matrix, which 6 could be from three white inspection findings or 7 performance indicators, or it could be from a yellow 8 inspection finding.
9 And then the column 4 is for one single 10 red or when multiple cornerstones are degraded. So 11 it's a very graded approach to our oversight.
12 MEMBER BLEY: And it defines what NRC's 13 response will be once you're in one of those columns.
14 MR. GIBBS: It defines our communications 15 with a licensee; it defines our public involvement; it 16 defines, most importantly, our response with respect 17 to supplemental inspection.
18 As you can imagine, a licensee that is in 19 column 4 of the action matrix is a significant -- a 20 significant inspection activity.
21 MEMBER SKILLMAN: And then there's one 22 more column.
23 MR. GIBBS: It's 0350.
24 MEMBER SKILLMAN: 0350.
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44 1 keys, and that's on the far far right.
2 MEMBER SKILLMAN: Yeah.
3 MR. GIBBS: We don't see that. Thank 4 goodness. I mean, overall, you know, nuclear power in 5 the United States is very safe.
6 MEMBER KIRCHNER: But could you give us an 7 update on the current fleet versus your action matrix?
8 Is there anyone on the right-hand side of the matrix?
9 MR. GIBBS: Is anyone in column 4? No.
10 That's done. Column 3, Dan Merzke, I don't think --
11 zero. Over 90-plus percent are in column 1. Five 12 units in column 2. That licensee response column 13 where we will go do a supplemental inspection to make 14 sure that they're addressing the issue, including 15 extent of condition, which is very, very important.
16 Again, as regulators, I was an inspector.
17 I think we've had some inspectors in the room here.
18 You know, what is near and dear to us as regulators is 19 that licensees identify and correct problems. If 20 they're doing that, then we have reasonable degree of 21 assurance that the facility is being operated in a 22 safe manner. Okay?
23 Okay. Commission approval. With respect 24 to SRM COMSECY-16-022, these are the items that we are 25 requesting the Commission to approve. One of those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 items is optimizing the baseline inspection program.
2 Ami here led this group, did an extensive 3 assessment of all of the baseline inspection programs 4 for the reactor safety cornerstones, minus emergency 5 preparedness, and we found some opportunities to 6 optimize the program.
7 Now, individually -- individually, if we 8 wanted to change an individual inspection procedure, 9 we would not need to ask permission for that, unless 10 it was a really substantial change, like eliminating 11 the procedure, but collectively, because of the work 12 we've done and where we -- where we recommend that we 13 land, which is a reduced inspection program from what 14 it is today.
15 It's comparable to about where it was when 16 this program began in 2000. Comparable. So, you 17 know, we're trying to eliminate unnecessary overlap 18 and redundancy. Really, what we're doing is we're not 19 -- we're not removing inspectable areas. What we're 20 doing is looking at the number of samples, inspection 21 samples we take, and also the number of hours we 22 spend.
23 If you're going to reduce samples in an 24 area, you're going to spend less hours on that 25 procedure. So what that's going to do is have an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 overall impact. The baseline inspection program will 2 decrease. That needs Commission approval.
3 The next item, I will say -- so let me 4 back up. Optimizing the baseline inspection program, 5 what problem are we -- what is the problem? We're 6 trying to address efficiency. So getting back to 7 those principles of good regulation, the elimination 8 of the four-quarter requirement for closure of green 9 inspection findings and the option, which we 10 recommend, to establish a requirement that PIs remain 11 inputs until the supplemental inspection is complete.
12 We believe this is an important change, 13 primarily to encourage licensees to correct problems 14 in a timely manner. Our data that we -- Dan actually 15 did the work on this, in the room. The data suggest 16 that we believe licensees could take more timely 17 corrective action for these greater-than-green 18 inspection findings and also for these performance 19 indicators.
20 So we want to change the program as much 21 as we can to encourage licensees to take these more 22 timely action. That's -- from a very high level, 23 that's what we're doing.
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47 1 the program, it's unclear, it's complicated, and we 2 want to -- we want to make that simple. So it's 3 really helping us with respect to clarity of the 4 program, really a basic understanding of how this 5 works. That's the second item requiring Commission 6 approval.
7 MEMBER SKILLMAN: Russell, what allowance 8 is given for the fuel cycling? For instance, let's 9 presume for a minute that there is a finding, it's 10 greater than green, it's in the primary shield, the 11 plant is on a 24-month fuel cycle, and you're two 12 months in. So you're not going to get into that 13 primary shield area for the next 22 months unless you 14 take a shutdown.
15 So what allowance is given for the 16 licensees to address a greater than green? They are 17 certainly not going to get it in the next four 18 quarters if they're on 24-month fuel cycle. It's 19 probably not raging safety significance, but it is 20 important.
21 So what is the -- what is the allowance 22 that is given for the -- if you will, the structure of 23 the plant, its fuel cycle, and, quite candidly, 24 radiological exposure?
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48 1 a problem that is affecting the reactor shield wall --
2 shield wall? Is that --
3 MEMBER SKILLMAN: So let's say I've got --
4 I can't reliably understand my lubricating oil levels 5 in my reactor coolant pump motors. It's really not a 6 safety component, but it certainly is a reliability 7 component and maybe a fire issue.
8 But I really am not going to go anywhere 9 near those reactor coolant pump motors if I'm on a 24-10 month fuel cycle. If I'm two months in, I'm not going 11 to get into that area for the next 22 months. But 12 it's a greater than green, for whatever reason.
13 So what allowance does the inspection 14 protocol allow for that licensee to say, "I'm 15 confident I'm not going to have a fire problem. I've 16 dealt with this problem in the past. But if you force 17 me to go to closure, I'm going to have to shut the 18 plant down, and that brings risks that I really prefer 19 to not take."
20 MR. GIBBS: Right. Well, the first thing 21 is, licensees have to meet their technical 22 specifications. So if this problem is affecting 23 operability, they would indeed need to take action to 24 address the problem.
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49 1 here is one that is kind of goofy. It really isn't 2 covered by tech specs. It raises the question of 3 operability, but the plants definitely say, "We've 4 dealt with this before. Even though we can't see 5 those levels, we're comfortable that the oil is there, 6 the lubricant is there."
7 MR. GIBBS: So if a licensee -- of course, 8 they've identified this problem. They've entered it 9 into their corrective action program, and they will 10 establish a plan to correct that. And we look at that 11 plan and we're satisfied with it. That's how this 12 program would work.
13 MEMBER SKILLMAN: So that might be the 14 allowance that the licensee is granting, even though 15 there is a greater than green that might last for more 16 than four quarters.
17 MR. GIBBS: Well, you know, interestingly, 18 as -- depending on -- when you say "greater than 19 green," there is a difference between red and white, 20 right?
21 MEMBER SKILLMAN: You betcha.
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50 1 of high safety significance.
2 MEMBER SKILLMAN: I understand.
3 MR. GIBBS: I suspect that they would do 4 the right thing.
5 MEMBER SKILLMAN: Yeah. I do, too. I was 6 just wondering, are there -- are there areas where the 7 inspection team, the NRC inspection team, would say, 8 "We understand what you're dealing with, and we will 9 flirt with you for a certain time period until this is 10 taken care of."
11 MR. GIBBS: We actually have an office 12 instruction in NRR. It's -- I think we call it 13 license -- it's LIC-503 or 504 -- 504. We actually 14 created this document after Davis-Besse. Similar 15 situation where, what is our decision as a regulator 16 for these -- for these situations that could involve 17 some degree of risk, some degree of high risk.
18 This procedure is very helpful for us to 19 inform us about what our regulatory action should be.
20 MEMBER SKILLMAN: Fair enough. Thank you.
21 MR. GIBBS: Okay? All right.
22 Significance determination process for emergency 23 preparedness. There are 16 planning standards in the 24 regulations. Some are more important than others.
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51 1 standards, like licensee making the emergency 2 declaration, very, very important.
3 The licensee notifying the local officials 4 about what that emergency classification is. Very 5 important that the licensee makes a protective action 6 recommendation in a timely manner. That's a third 7 one. And the fourth one is dose assessment, 8 performing dose assessments of the situation. Really 9 important.
10 No change is being proposed to the 11 treatment of those four planning statements. So, of 12 the 16, right, 12 remain. Of those 12, three are --
13 actually could impact the licensee's ability to meet 14 those four risk significant planning standards, such 15 as staffing of the emergency response organization, 16 equipment used in the emergency response facility to 17 help the licensee, you know, do what they need to do 18 in an emergency.
19 Those items could become greater than 20 green or white is if -- if you have a cap on those.
21 The remaining nine -- and this is where I think, Bob, 22 you may want to comment further. Those will be 23 considered not to be of greater-than-green 24 significance. They are more compliance-based, and so 25 this is a big change in the program.
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52 1 So it gets back to risk-informing the 2 program. Better risk-informing the program, using 3 risk information to make the program even better than 4 it is.
5 These three items require Commission 6 approval. Does that help you all understand some of 7 the -- we are at 9:30 right now, so I'm trying to --
8 MEMBER RAY: Well, we're going to have to 9 pause for just a second still, notwithstanding that.
10 Okay. Risk-informed. But, again, I find 11 myself wondering, what is the basis of risk? Is it 12 the event itself or the condition itself, or is it the 13 extent of condition? Is it a result of something that 14 could, if it happened in another location, have very 15 significant consequences? But because it happened in 16 this location -- to use Dennis' example -- it had very 17 low significance. Well, then, it has low significance 18 and we will treat it as such.
19 I'm not clear on how you factor in the 20 risk significance of something that is systemic or it 21 has an extent of condition that could affect other 22 things in what you're describing.
23 MR. GIBBS: Again, and maybe I was not 24 clear enough, but, again, our program -- risk-informed 25 and performance-based -- using a graded approach, if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 1 a more risk-significant or greater-than-green 2 inspection finding occurs, we perform a supplemental 3 inspection.
4 In that supplemental inspection, we 5 perform an extent of condition. Actually, what we're 6 doing is looking to see what the licensee did in their 7 own extent of condition review. Of course, as it 8 becomes more and more important, we may do our own 9 inspection, you see, so we're treating -- we're 10 treating the program in a manner that's graded 11 approach with respect to risk.
12 Now, when you talk about risk in -- you 13 know, in very simple terms, and try to keep it really 14 simple, it's what can go wrong at a facility. We call 15 those initiating events. What can go wrong?
16 The second part to the risk triplet is, 17 you know, how likely is it? I mean, we have an 18 understanding of these initiating events.
19 And then the third item is, what is the 20 consequence? Your question is about consequence with 21 respect to possibility of other areas. The answer 22 lies in the supplemental inspection.
23 MEMBER BLEY: Let me turn it around just 24 a little bit --
25 MR. GIBBS: Okay.
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54 1 MEMBER BLEY: -- if I could. I'll get 2 back to -- you said something earlier that I think is 3 the key. one thing one might do is rely on Appendix 4 M and some qualitative approach to address this kind 5 of issue. Another is I thought you said you had 6 guidance that actually deals with these extent of 7 conditions.
8 MR. GIBBS: It's in the supplemental 9 inspection procedure.
10 MEMBER BLEY: It is in the --
11 MR. GIBBS: Yes.
12 MEMBER BLEY: -- inspection process.
13 MR. GIBBS: Yes, it is.
14 MEMBER BLEY: I don't know if that helps.
15 MEMBER RAY: Well, it has to be greater 16 than green. I was really triggered off what he said 17 was the change was just describing -- maybe just if 18 you'll repeat that again, it will answer my --
19 MR. GIBBS: Which one?
20 MEMBER RAY: Well, just before I 21 interrupted you, you had talked about a change 22 occurring. Actually, I think Dennis spoke, and then 23 I did. And in thinking about it, maybe I 24 misunderstand what you were saying is change 25 effective. I can't repeat it back to you now at this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 1 point.
2 MR. GIBBS: Right. The one that comes to 3 mind is our work we are doing with respect to the 4 treatment of white inspection findings in our 5 supplemental response. That's what comes to mind, I 6 believe, with respect to your question.
7 We believe we can spend a bit less 8 resources on uncomplicated, for example, degraded 9 conditions, those that are uncomplicated, a single 10 white issue, for example, and that we do not believe 11 -- and regulations, by the way, do not require that a 12 licensee perform a root cause evaluation for those 13 situations.
14 MEMBER RAY: Well, you won't find anybody 15 who wasn't more glad to see SALP go to me. But it did 16 include the assessment of what are the implications of 17 this minor event that happened. And I guess I'm still 18 trying to gain confidence that there is some aspect of 19 that that is preserved here in the changes that you're 20 making.
21 MR. GIBBS: Yeah. Let me reach -- let me 22 throw out a lifeline here. I want to make sure that 23 -- and Billy or Ami or anyone here with NRC, I want to 24 make sure we capture that question and we give a 25 satisfactory answer to help you understand that.
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56 1 Really, but the short answer is problem 2 identification and resolution, and our inspection of 3 that -- of the licensee's identification and 4 correction of the problem, including extent of 5 condition, which could involve multiple issues of 6 various safety significance, is really -- is really 7 the program response.
8 I don't know if anyone -- Billy, did you 9 want to add to that?
10 MR. DICKSON: No.
11 MS. AGRAWAL: I guess your point is that, 12 how are we capturing the low safety significant 13 issues? Is that the gist of the question?
14 MEMBER RAY: What are the implications of 15 a low safety significant event? I had to go to so 16 damn many regional meetings to talk about things that 17 were insignificant because the implication of it was 18 that, well, if this had happened elsewhere, it would 19 have been significant.
20 So I understand not wanting to overdo 21 that. That's really what caused SALP to be so 22 strongly criticized. But it's -- there is a degree to 23 which I am concerned about going too far in the other 24 direction, which is, yeah, these are little minor 25 things that are happening. It doesn't rise to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 level where we look at what the extent of condition 2 is.
3 And so we don't see that until something 4 significant does happen. And that's all I'm trying to 5 say, and I've taken too much time, so --
6 MR. MURPHY: I'm Marty Murphy. I'm the 7 Director of Regulatory Affairs at Xcel Energy, and 8 I'll presenting here shortly.
9 So maybe I can help with that. So I think 10 -- you know, Russell, I'll try to throw you a lifeline 11 here. So there is a number of things that licensees 12 do within the corrective action process where we'll 13 assign a causal evaluation for something, and in some 14 cases it may be a fix.
15 But if there are generic implications 16 where that component is used in other places of the 17 plant, you know, we will look at it for, you know, 18 those aspects of common cause or other -- you know, if 19 that degradation could be impacting more safety-20 significant areas.
21 So that certainly happens, and that 22 happens through the cap screening process where there 23 is a collection of, you know, subject matter experts 24 that review all of the caps and then screen them for 25 the various actions that are required to assess those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 1 corrective actions.
2 I think the other thing that you've got to 3 consider, too, is the residents every day look at all 4 of the caps. And if they see a component or something 5 that has a generic application in the plant, they 6 would likely be asking those same questions about what 7 we were going to do relative to its use in other 8 areas.
9 And if you get into operability, and you 10 start to question operability in those other areas, 11 then you may have tech spec issues which would then 12 rise to the level of trying to understand the safety 13 significance.
14 So there is a number of things that happen 15 on a daily basis through screenings and assessments to 16 look for those very issues, the trending that gets 17 done by the PI&R program, the trending that happens by 18 the residents themselves, so, again, there is a 19 multitude of layers of defense there to look for those 20 variables.
21 Does that help?
22 MEMBER RAY: I think we should go on.
23 MR. GIBBS: Fair enough. As Billy 24 indicated at the beginning, the ROP enhancement 25 project is not a one and done. Essentially, we just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 1 are towards the end of phase 1 of ROP enhancement.
2 ROP enhancement will continue. We're not real sure 3 exactly how long, but there are a few next steps for 4 us, some longer term actions.
5 We are going to be looking at some 6 possible revisions to performance indicators, 7 specifically, the mitigating systems performance index 8 PI. Industry believes it has basically kind of run 9 its course. It is actually a fairly complicated PI.
10 It involves a lot of resources, and they are wondering 11 if they could change that, the MSPI performance 12 indicator. More work to do in that regard.
13 Remember that the performance indicator 14 program and the inspection program work hand in hand 15 to assure that licensees are operating their plants 16 safely.
17 I mentioned to you before we're going to 18 be performing a comprehensive review of the problem 19 identification and resolution program to make sure 20 that it's accomplishing what we want. It's early to 21 know exactly what that is going to look like, but we 22 intend to kick that off in the July timeframe. We're 23 making preparations for that.
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60 1 program. And, Mr. Ray, this may actually address some 2 of your questions. The cross-cutting issues program 3 is a program that focuses on three areas -- human 4 performance, problem identification and resolution, 5 and safety conscious work environment -- to see if --
6 if things are happening at a lower level of 7 significance, it actually has some -- collectively a 8 more risk-significant potential. Okay?
9 MEMBER RAY: Yes.
10 MEMBER KIRCHNER: Before you go on, if we 11 could go back to 10, since you put it up. It's so 12 blurry, I can't --
13 MR. GIBBS: Oh, I'm sorry.
14 MEMBER KIRCHNER: Can you explain what 15 you're illustrating there?
16 MR. GIBBS: This is just an example of a 17 performance indicator -- oh, I see that, it is blurry 18 -- unplanned scrams per 7,000 critical hours. You can 19 see -- well, I don't think you can see, but there are 20 thresholds. This is, by the way, one of the -- one of 21 the areas that is a really good indicator of plant 22 safety, if there are unplanned scrams.
23 This typically means that there are 24 problems. And so this indicator across the industry, 25 I think right now they are all green. Dan, I don't --
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61 1 I don't know -- Brunswick has one. Okay. But, yeah, 2 that's right. That's right. But most of the 3 performance indicators are in the green range.
4 So, again, you kind of get back -- are the 5 performance indicators telling us what they need to 6 tell us with respect to oversight? Could they be 7 enhanced? Could they be improved? These are some of 8 the questions we're going to be asking.
9 Apologies on the slide there.
10 MEMBER KIRCHNER: Well, clearly, that was 11 an important one for the industry from an 12 operability/reliability standpoint. How many of your 13 performance indicators run green all the time?
14 MR. GIBBS: Ninety-nine percent.
15 MEMBER KIRCHNER: So then do you have the 16 right performance indicators?
17 MR. GIBBS: That's the question.
18 MEMBER KIRCHNER: All right.
19 MR. GIBBS: That's the question.
20 MEMBER KIRCHNER: Because if you're just 21 checking the box, after a while it's --
22 MR. GIBBS: We understand that comment.
23 Absolutely. And so we intend to look at the 24 performance indicators. And I can assure you industry 25 will be very interested to be involved in this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 1 dialogue, because, you know, the whole performance 2 indicator program was the notion of industry back 3 many, many years ago. And so we -- but we believe 4 it's a good program. But could it be improved?
5 Possibly. Okay?
6 A few next steps. I mentioned to you 7 earlier optimizing the spent fuel storage installation 8 inspections that we do. We do those a bit differently 9 across the regions. The question is: are we spending 10 too much time on these inspections that some believe 11 are not that risk significant? That's a question 12 we're asking.
13 We're also looking at radiation protection 14 inspections to see if we can do some further 15 optimization in that particular cornerstone.
16 The significance determination process is 17 an ongoing evolution. Of course, we talked about the 18 emergency preparedness SDP, some of the changes that 19 we're going to be making there. But the SDP is one of 20 those area, very important part of our program to help 21 us understand the significance of licensee performance 22 deficiencies. And as we get more experienced, we go 23 back to the SDP to make sure it's giving us the right 24 answers for these degraded conditions caused by a 25 licensee performance deficiency.
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63 1 Indicated earlier Bob's group is going to 2 be assessing additional actions identified in the 3 emergency preparedness focused self-assessment. I 4 think that, Bob, there are over 20 -- over 20 5 different activities in that area. Some are, frankly, 6 more important than others, but there is a lot of work 7 to do in that area.
8 These are some out-of-scope items we 9 mentioned of ROP enhancement. Those regional 10 structure and organizational issues, we're not --
11 we're not addressing that as part of ROP enhancement.
12 Early on, we got some feedback from 13 industry about low-risk compliance issues and backfit.
14 That is no longer part -- it was early, but that is no 15 longer part of ROP enhancement. NRR has formed a 16 separate group to address that, and the fundamental 17 question is, if there is a compliance issue and it's 18 of low risk with respect to the licensing basis, how 19 do we -- how do we treat that as a regulator? We're 20 trying to answer some of those questions.
21 Inspection reports streamlining is another 22 area. We're calling it ISTR -- inspection, 23 scheduling, and tracking, reporting. Dan is -- Dan, 24 you're doing a lot of work here for us. He has been 25 involved with ISTR. It's one of those areas that, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 know, if you spend a lot of time documenting, you're 2 not inspecting. So we want to make sure that we have 3 the right mix with respect to inspection and 4 documentation, and ISTR is one of those items to help 5 us there.
6 MEMBER RAY: Well, but, of course, 7 compliance issue is an example. There are compliance 8 issues, but we disregard them because they're not 9 significant. I mean, the consequences are not 10 significant as we observe them. That's a question 11 that takes a long time to discuss. And we don't have 12 that time here, but it's an example of what I was 13 referring to.
14 MR. GIBBS: Well, I'll say that if there 15 is a non-compliance, we don't disregard them.
16 Licensees must enter those into the corrective action 17 program. And we, on a selective sampling basis, will 18 make sure that they correct the problem, even if it's 19 of very low safety significance and they're 20 documented. Not much, but they're documented in a 21 lighter -- lighter way.
22 MEMBER RAY: But that point needs to be 23 made along with the "we don't want to waste time on 24 this stuff" comment also, which is what I heard you 25 say before.
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65 1 MR. GIBBS: Okay. The last thing I'll say 2 is all of these 99 recommendations, 72 we received as 3 part of transformation initiatives, 27 from the 4 Nuclear Energy Institute provided those by letter.
5 All of those we're going to be putting together in a 6 memo from Ho Nieh to Dan Dorman, the Deputy Executive 7 Director for operations, here in the very near term.
8 And you will be able to see how we actually 9 dispositioned every one of them. Many of them are out 10 of scope, and they were transitioned to other areas 11 for resolution. Some of them are open. Some of them 12 are closed with no action. Just to have you aware 13 that that is also something to do.
14 MEMBER BLEY: That won't be in time as --
15 to be an attachment to the SECY.
16 MR. GIBBS: It will not be attached to the 17 SECY, but certainly the office of the EDO and the 18 Commission will be aware that it exists. And it is 19 publically available.
20 Apologies for going over. Appreciate all 21 of your questions. I think I'm a little late.
22 MEMBER KIRCHNER: I have a question. Is 23 this ICORE logo, is that adopted now by the 24 Commission?
25 MR. GIBBS: Yes, sir.
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66 1 MEMBER KIRCHNER: And the E stands for 2 what?
3 MR. GIBBS: Efficiency.
4 MEMBER KIRCHNER: Not effectiveness.
5 MR. GIBBS: No, sir. Reliability -- you 6 know, efficiency and effectiveness.
7 MEMBER KIRCHNER: Two different words.
8 I've been in the government 40 years. Efficiency in 9 the government is usually measured by taking people 10 out of the loop. I'll be blunt. That's what 11 transformation usually is in the government.
12 MR. GIBBS: That's not our goal.
13 MEMBER KIRCHNER: Well, then, pick your 14 words carefully. Your job is to be effective, not 15 efficient. Efficient is expected to carry out the 16 job, but effectiveness is the measure.
17 MR. GIBBS: Well, it is one of our 18 principles of good regulation. It's hard for me to 19 argue that. Reliability, I think, and efficiency, you 20 know, when we -- when we are both reliable and 21 efficient, that we are, therefore, effective. Not 22 real sure about the -- why we landed there, but that 23 is -- that is where we are. Yeah. Thank you, though, 24 for the comment.
25 Anything else? No?
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67 1 MEMBER SKILLMAN: Billy, Russell, Ami, 2 thank you.
3 Let's change out to Marty. Marty, we're 4 going to ask you to go quickly, please.
5 MR. MURPHY: Hi. I'm Marty Murphy. I am 6 the Director of Regulatory Affairs for Xcel Energy, 7 and I am here representing both NEI and Xcel Energy.
8 And we're going to touch base and talk about 9 industry's understanding of the changes that we have 10 a current understanding right now of what will be 11 included in the staff SECY paper for ROP enhancement.
12 We'll touch base on that.
13 First, I think I'd like to echo some of 14 the information that Russell identified. We, as an 15 industry, do feel that the ROP works well. That what 16 we're looking for is some enhancements, and that it 17 has served industry well to date. But we do believe 18 that there is areas for improvement and continuous 19 learning. So from that standpoint, I'll try to move 20 through quickly.
21 I think one of the things we really want 22 to focus on is there's a lot of alignment. We have 23 had great dialogue with the agency and the staff with 24 regard to the changes that they are proposing and how 25 quickly and timely they worked through the proposals NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 1 that they had relative to enhancing the ROP.
2 So with that being said, we're going to 3 talk a little bit about just the very high level --
4 Russell touched on this -- that the industry 5 performance to date right now is supporting some of 6 these changes in -- to the ROP to enhance it and 7 optimize it. We're going to talk a little bit about 8 our understanding of what will be included in the 9 staff SECY paper. We do not have a lot of details.
10 We've had a lot of dialogue, but the details we are 11 waiting to see and eagerly anticipating.
12 We are very happy to hear, and we agree 13 that this should not be a one-and-done effort. The 14 staff has repeatedly stressed that, and we are 15 completely aligned that there is more to do after this 16 SECY paper.
17 But this is an excellent start, and the 18 timeliness with which the staff -- I really can't 19 stress that enough -- the timeliness with which the 20 staff has worked through this has just been, you know, 21 excellent from the standpoint of the amount of 22 information they took to prioritize it, and then roll 23 it into potential recommendations to the Commission 24 for changing and enhancing, optimizing the ROP.
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69 1 that is what you really want to hear about from me is 2 where we're not aligned with the staff on their 3 proposal or where we're waiting for additional 4 information to truly understand what their proposal 5 will contain. And then some future opportunities that 6 we see with regard to the next steps for the ROP 7 enhancement effort.
8 So, next slide, please.
9 So at this point -- and Russell touched on 10 this -- industry is performing at an extremely high 11 level, on the highest levels that it has ever had. If 12 you look across multiple metrics on performance, 13 reliability, safety, the industry currently is at its 14 highest.
15 I think one of the key points -- and you 16 talked about it a lot -- that underlying that and 17 underpinning that performance and safety is a very 18 exceptionally strong safety culture and performance 19 improvement culture that the industry has where we 20 find, identify, and fix issues to enhance and improve 21 safety and performance.
22 So that really sets up the underpinning 23 for why we believe we can continue to enhance and 24 optimize the ROP at this point.
25 Next slide.
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70 1 This is just simply a trend graph of the 2 change in CEF since the start of the ROP. You'll 3 notice this says a five times reduction. The previous 4 slide said a 10 times reduction. It's just simply 5 different time periods. The previous slide took a 6 much longer look at the change in CDF over that time.
7 Next slide, please.
8 MEMBER KIRCHNER: I can't let that go by.
9 So would you explain how that happened? Did the 10 people sharpen their pencils and get better at doing 11 the PRAs or --
12 MR. MURPHY: So, no. What happened is 13 that the --
14 MEMBER KIRCHNER: What substantively 15 changed?
16 MR. MURPHY: Well, it's the use of the PRA 17 tools to then understand the design and then go make 18 either design or modification changes, procedural 19 changes, and continuously look for those changes where 20 we can improve our risk profile.
21 MEMBER KIRCHNER: So that's a steep drop 22 in the curve there. And so what substantively changed 23 in the industry to achieve that?
24 MEMBER CORRADINI: I guess Walt is asking, 25 is it a lot of little things? Is there a couple of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 big things, as you point out, around the 2000 2 timeframe?
3 MR. MURPHY: Yeah. And I am not a PRA 4 expert, but I can tell you from my personal experience 5 it's many little things and where we went and looked 6 at making modifications in those changes to improve 7 our risk profile.
8 For instance, at Prairie Island, one of my 9 plants, we installed low leakage reactor coolant pump 10 seals. That had an impact.
11 At Monticello, we had some condensate 12 demineralizer valves that had an impact on flooding.
13 We pinned those valves closed, and that had an impact 14 on the risk profile. We made different -- go ahead.
15 CHAIRMAN RICCARDELLA: No. You go ahead.
16 MR. MURPHY: Okay. We have made different 17 procedural changes where we've staged equipment and 18 written procedures to allow a thorough understanding 19 of some actions that would be taken in the event of a 20 loss of power and needing to supply alternate power to 21 our batteries.
22 CHAIRMAN RICCARDELLA: And how are those 23 changes related to the ROP program?
24 MR. MURPHY: Well, so this is setting up 25 our underpinning, and the performance change in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 1 industry, which then we believe supports an 2 understanding of how to optimize the ROP and look for 3 that change in the risk-informed nature of the ROP.
4 MEMBER SKILLMAN: I'd like to offer a 5 contrary view. I believe that what you see there is 6 accurate. I believe this is the tail-end effect of 7 50.56, the maintenance rule, coupled with an almost-8 militant view by industry to make sure their 9 corrective action programs are extraordinarily 10 thorough, coupled with what has been a recognition 11 that the work management program is the glue that 12 makes it all work. And those three components --
13 50.65, people -- system health reports, material 14 condition of the plant, coupled with a very, very 15 strong and disciplined corrective action program, 16 coupled to a no-nonsense "we're going to get this work 17 done" work management program, is what has driven 18 that.
19 I think some of the modification issues 20 that you point to assist to some degree, but I think 21 it's really problem identification and work execution 22 that has driven that down, and it's through the lens 23 of what has come out of the maintenance program --
24 maintenance rule.
25 MR. MURPHY: I won't disagree with that.
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73 1 And I think if you looked at the -- another slide, it 2 would identify the maintenance rule as driving that 3 and just have it partitioned slightly earlier. So at 4 the tail end, as you say, I would agree with you.
5 MEMBER SKILLMAN: Thank you.
6 MR. MURPHY: As well as those other 7 additional items.
8 MEMBER SUNSERI: Marty, I think maybe I 9 can share some industry experience because I was in 10 the industry at the time of the implementation of ROP, 11 and I know at the time there were several plants that 12 when we implemented particularly the performance 13 indicator part of the program. There were some 14 performance issues identified in the systems where 15 they performed that there was very little margin to 16 changing thresholds, going from green to white or 17 yellow.
18 And so at the time -- and this is relevant 19 to the ROP -- so risk capture was put in place to help 20 those plants stay within the green while they worked 21 out adding additional margin.
22 So Marty pointed out when I was -- you 23 know, I'm familiar with one where reactor coolant seal 24 modifications were made, enhancements to the auxiliary 25 feed water system were made, enhancements to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 electrical power supply system were made, and all of 2 that was done in an effort to reduce the importance, 3 if you will, of the central service water system, 4 which gained margin there, which reduced the overall 5 core damage frequency. So it kind of worked hand in 6 hand.
7 Now, what was the driver for that? The 8 driver wasn't necessarily a recognition that we need 9 to improve core damage frequency. The driver was we 10 got low margin on this ROP, so -- which resulted in 11 improved safety overall. So I think that's the tie 12 that at least I saw to -- between the curve Marty 13 pointed out and the ROP program.
14 MR. MURPHY: Thank you. I appreciate 15 that.
16 So we'll touch base on the -- what our 17 understanding of the proposal is, and as Russell 18 pointed out, there is really three key areas in the 19 staff SECY paper and that is the response to white 20 findings, baseline inspection program changes, and the 21 efforts that the staff has been working on, the 22 significance determination process.
23 With regard to the response to white 24 findings, we are aligned with where the agency is, 25 with the need to align that response or rebase that --
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75 1 align that response to the safety significance of a 2 white finding. Over the years, the expectations and 3 the level of response necessary to address a white 4 finding has gone up and is not necessarily 5 commensurate with the safety significance of the 6 findings.
7 There is a broad range of findings, as 8 Russell pointed out, some relatively straightforward 9 and simple, some more complex. Adjusting the 95001 10 procedure to incorporate that understanding is vitally 11 important to us as it will help enhance our use of 12 resources to align them in the most safety-significant 13 area.
14 We are aligned with the changes that the 15 staff is going to make in the action matrix to help 16 better convey that a white finding is of low 17 significance, and that a yellow finding is of moderate 18 significance. We did provide a much more detailed 19 look and integrated change to the action matrix, and 20 the staff has looked at that.
21 We believe we -- you know, more dialogue 22 should be had on that, but we are aligned with the 23 changes that the staff is making right now, because we 24 do believe that will help rebaseline that 25 understanding of a white finding as a low safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 significance issue.
2 Russell touched on the flexibility in the 3 95001. We are aligned with that, that there needs to 4 be greater flexibility, and we -- I say I would 5 applaud the staff's desire to go and look more 6 holistically at lessons learned on 95001 as a next 7 phase to have a true understanding of what that 95001 8 procedure should look like, so that we can assess the 9 white findings properly.
10 And then we'll talk about the change in 11 the closure of the white performance indicators in a 12 little bit more detail in the challenges section 13 because we are not aligned with the changes that the 14 staff are proposing with the white performance 15 indicators.
16 Overall, with the baseline inspection, we 17 are aligned with what the staff is proposing. The 18 change to the PI&R team inspection from two years to 19 three years we believe is being done in the right 20 direction. There is much duplication in the PI&R 21 inspection. The entire process of PI&R is inspected 22 as Russell laid out, and we can certainly attest to, 23 at multiple points and by multiple groups within the 24 agency to ensure licensees have a strong PI&R.
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77 1 a thorough understanding of the need for that strong 2 PI&R, because it ensures that we remain reliable and 3 predictable and that we are operating at these high 4 levels of safety and reliability.
5 MEMBER BLEY: You went a little fast for 6 me. It sounds like the place so far that you have --
7 you're not aligned with the staff is on the white 8 findings. Can you expand on that just a little?
9 MR. MURPHY: Yeah. I will in the next 10 slide.
11 MEMBER BLEY: Okay.
12 MR. MURPHY: Okay? And I think we would 13 also -- and I'll touch base in the next slide on some 14 of the challenges that we think exist. The staff has 15 done a lot of work -- as Russell pointed out and we 16 agree with -- in looking at the SDP, the security SDP, 17 and the EP SDP. That work started before the ROP 18 enhancement effort, and we applaud that effort. The 19 staff is doing a, you know, really solid job of 20 looking at that holistically.
21 One of the SDP changes that the staff is 22 looking at is merging the mitigating strategies SDP 23 with the at-power SDP. We had suggested in industry 24 that you would merge the mitigating strategies SDP 25 with the B.5.b SDP, because they are both design basis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 events.
2 We'll touch base on that. We just truly 3 don't understand the basis for merging the mitigating 4 strategies SDP with the at-power SDP, because we think 5 it blurs the lines between beyond design basis and 6 design basis issues as well as how you would make that 7 gradation in a greater-than-green finding.
8 MEMBER BLEY: Over the last several years, 9 we had interactions with NEI and others before the 10 final rule was put out on making a strategy on beyond 11 design basis events. And a number of plants with 12 gradual staff agreement started moving toward 13 incorporating the use of flex equipment into before 14 core melt kind of events.
15 For me, that kind of hints at maybe a 16 reason why staff is talking about merging those. We 17 can talk about that with staff. Any thoughts on that?
18 MR. MURPHY: Well, I think we understand 19 that, and the staff has made that same point, that 20 that's -- you know, from a certain standpoint, that is 21 part of it. But we really believe that there is --
22 there is just a better fit between the mitigating 23 strategies and the B.5.b SDP. If you're going to --
24 if you're going to merge them and make a single SDP, 25 it makes sense to us that those two would be merged, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 rather than the mitigating strategies and the at-2 power.
3 MEMBER BLEY: No matter how one merges, is 4 there any real impact to such a process?
5 MR. MURPHY: Again, we don't have the 6 specific details, and I think, you know, we'll be 7 waiting to see what that looks like.
8 MEMBER BLEY: Okay. Fair enough.
9 MR. MURPHY: I would imagine that if it's, 10 you know, transposing what is in one and putting it 11 there, likely not, but, again, it's just the potential 12 to blur the distinction between design basis and 13 beyond design basis.
14 And then, lastly, improving the 15 interactions with licensees during the SDPs. This is 16 the inspection finding management process, and this 17 has been a very important and good change from the 18 licensee's perspective. The improved communication 19 that we have with the region, when we are trying to 20 understand what the performance deficiency is in order 21 to understand what the SDP outcomes are, is vitally 22 important.
23 And as Russell identified, and I think 24 somebody else touched base -- I think it was you, 25 Mr. Skillman -- with regard to the interactions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 between the PRA group and the SRAs in the region, that 2 does happen. And it continues to happen, and there 3 continues to be very strong relationships there.
4 But the clarity of communication with 5 station management from regional management on what 6 the performance deficiency is is one of the 7 enhancements of that inspection finding process, as 8 well as making it clear when the clock starts, very 9 clear to both the licensees and the NRC with the 10 tracking of that process as the NRC staff evaluates it 11 from a significance standpoint. So it's a positive 12 change.
13 Okay. Some of the challenges that we see 14 -- and the first one is with the performance 15 indicators. Fundamentally, there's a difference 16 between a performance indicator and a finding. You 17 could consider the performance indicator sometimes may 18 be a trend. There may be a number of discrete 19 happenings that cause you to go from green to white.
20 For instance, you could have a number of scrams that 21 would transition you from a green performance 22 indicator to a white indicator.
23 You understand immediately through the 24 performance indicator when you've gone back through to 25 baseline risk through the -- through the objective NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 1 evidence that is revealed by the performance 2 indicator, whereas with a finding, you don't actually 3 understand that until you've worked through your 4 corrective action process, you've done your causal 5 evaluation, and then they've been assessed and 6 reviewed by the NRC.
7 So there's a fundamental difference there.
8 MEMBER BLEY: Do you or does NEI or the 9 industry have a sense of whether or not the current 10 performance indicators are really predictors of future 11 performance, which was the hope for them to be?
12 MR. MURPHY: Well, I guess I'd point to 13 Dan, because Dan did a look at that, I think it was, 14 right? Well, with the background information -- I'm 15 sorry, I'm confusing it. But I think with -- with an 16 understanding of what those performance indicators 17 are, and that those performance indicators were tied 18 to an understanding of what was adequate protection, 19 and a lot of work was done to baseline them to either 20 safety, risk significance, or an understanding of 21 adequate protection.
22 You know, they are somewhat different 23 maybe necessarily, and it gets to the question you 24 asked about, are they the right performance 25 indicators? And are they driving continuous NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 1 improvement? That's not their intent. That's INPO's 2 function, to drive us to excellence and continuous 3 improvement. The performance indicators are there to 4 assess us and look at us relative to safety and 5 adequate protection.
6 MEMBER BLEY: Okay. Ten years ago, 7 someone from INPO implied that they have actually come 8 up with some performance indicators that really work 9 with it. I don't know if that's something that's open 10 to talk about or if it's going on or if you can say 11 anything about it. But if you can, I'd be very 12 interested.
13 MR. MURPHY: Well, INPO, I mean, you know, 14 all the stations are assessed by INPO, and INPO does 15 have its set of indicators that they use to drive us 16 to excellence. But excellence is different than 17 safety, so, you know, obviously, what they -- what 18 they ask us to do also feeds back into our ability to 19 always be safe from that standpoint. Is that a --
20 MEMBER BLEY: Okay.
21 MR. MURPHY: Okay? So the staff has done 22 some work and an analysis to support this change to 23 the white performance indicators. We believe that 24 additional work needs to be done on that analysis.
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83 1 from about 2006 'til present, there has been a 2 dramatic decrease in the number of white performance 3 indicators. From 2006 to 2010, there were 33. From 4 2011 to 2015, there were 23. And from 2016 to 5 present, there's currently five.
6 There has been a change in what those --
7 what is causing the white performance indicators to 8 really transition, and right now it's primarily based 9 on unplanned scrams. And so when you look at 10 analyzing what is driving unplanned scrams and those 11 changes, you can have a number of discrete events.
12 The staff has indicated that the 13 timeliness to complete the analysis and the 95001 14 associated with those indicators is trending upward, 15 and we believe additional analysis needs to be done to 16 thoroughly understand what is going on with that 17 trend.
18 When you couple that with the changes to 19 the expectations and white findings, you look at the 20 difficulty that you can sometimes have with trying to 21 look for causes and common causes between discrete 22 events. You can get to very challenging causal 23 evaluations, and they're difficult to finalize and 24 then support through the 95001 inspection with the 25 changing and growing expectations that have occurred NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 1 over the years with those 95001 inspections.
2 So our position is that additional work 3 needs to be done on this proposed change. Additional 4 dialogue with industry and a more thorough 5 understanding of the analysis of the trend data that 6 exists that the staff finds compelling in order to 7 make this change to the white performance indicator 8 from that standpoint.
9 With the baseline inspection program 10 changes, we are aligned with that. We believe the 11 staff can do more to look for efficiencies. What they 12 have done is a very good start, but we believe that 13 there is more efficiencies and duplication that can be 14 rung out to help with the baseline inspection and 15 allow us to be focused on the most safety-significant 16 and important areas from that standpoint.
17 And then with the significance 18 determination process, as we talked about already, the 19 mitigating strategies and the B.5.b SDP, again, it's 20 not clear to us why that change is really being made 21 and what the benefit is.
22 And then, as we talked about earlier with 23 Russell, EP has done a self-assessment. There is a 24 number of recommendations in that self-assessment.
25 And we believe some of the proposed changes -- and, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 again, we haven't seen, you know, exactly what will be 2 proposed -- that there is more room to go potentially 3 in the EP area as well in enhancing the SDP. And that 4 there has been some tempering of some of those ideas 5 in the self-assessment from proposed changes that 6 could be made to the EP SDP.
7 So moving on to opportunities, again, the 8 staff has been very clear, and we are completely 9 aligned that this is not a single effort, what will be 10 contained in the SECY paper. There has been -- as 11 Russell said, we have met monthly with the staff. We 12 have had great dialogue.
13 We need to maintain the momentum and 14 continue looking for additional efficiencies and 15 optimization of the ROP.
16 We believe there are some areas in the 17 second phase of ROP enhancement. The first item here 18 is making the 95001 a smarter inspection, and that 19 will be through leveraging the lessons learned that 20 the staff identifies through its more comprehensive 21 look at the 95001 inspection, as well as creating 22 increased flexibility such that simple, 23 straightforward problems can be addressed and 24 corrected and assessed by perhaps the resident 25 inspector with a limited amount of effort commensurate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 with the safety significance.
2 We understand that there will be cases 3 where there's more complexity, and the staff will have 4 to rely on subject matter experts to support that 5 95001 inspection. So, again, it's the broadening and 6 the flexibility that we see that needs to be in that 7 95001 inspection.
8 Streamlining the ISFSI inspections is 9 another area. That is yet to start. We have had some 10 initial discussions with NMSS, but that's an area 11 where there is certainly efficiencies to be gained 12 based upon the risk.
13 We believe that the staff has proposed 14 some changes to the radiation protection program, but 15 in that sense we believe a holistic, more aggregate 16 look at the entire program needs to occur, much like 17 has been done with security and EP from that 18 standpoint. And we're eager to see the staff embark 19 on that -- that more holistic look to look for 20 efficiencies in the radiation protection area.
21 We touched base a little bit on improving 22 the alignment on common cause failure and human error 23 probability. That's the next bullet here is improving 24 the realism in the RASP handbook. Getting that 25 alignment around common cause and human error NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 1 probability is important for getting alignment in what 2 the outcomes are on the SDP, and that effort is 3 underway and continues.
4 Completing the holistic look, the PI&R 5 program is very important to us. There is a lot of 6 duplication in PI&R. I think Russell said that we 7 have made -- the industry had made the proposal to do 8 away with the PI&R. I will kind of couch that a 9 little differently. Our recommendation was to 10 eliminate the periodic team inspection, but keep it as 11 a supplemental inspection, so that if you saw 12 challenges within PI&R that the staff could invoke a 13 supplemental inspection to be a team inspection on 14 PI&R and address issues from that standpoint.
15 The staff has identified that they are 16 looking for additional performance indicators or new 17 performance indicators, and we believe those need to 18 be looked at, not just from adding additional 19 performance indicators but performance indicators that 20 could be used in place of inspection to, again, 21 increase our overall effectiveness and efficiency from 22 the staff's perspective and the licensee's 23 perspective.
24 MEMBER BLEY: It seems like that would 25 take some real proving --
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88 1 MR. MURPHY: I think --
2 MEMBER BLEY: -- some research to convince 3 folks that the indicators were indicating the right 4 things.
5 MR. MURPHY: Yes. I think you're spot on.
6 I think that will become the most crucial part is 7 making sure that, if you have an indicator, that it's 8 giving you insights into the adequate protection of 9 safety and that we're not using an indicator to drive 10 excellence or some other driver.
11 MEMBER BLEY: Thanks. I have a question.
12 Both the staff and you have referred to the tools for 13 looking at security as well. We had a session here a 14 while back on safety and the security interface where 15 some of the same tools that are used in risk 16 assessment are being used or disbanded and 17 vulnerability assessment that would let you go beyond 18 the kind of simple-minded response to results of, say, 19 drills, exercises, to really understand what the 20 problems are and probably saving a great deal of 21 effort in responding to those kinds of issues.
22 Has that made it into this program at all?
23 And is the industry pushing that?
24 MR. MURPHY: I don't know -- well, I don't 25 believe it has made it into this program. Industry is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 continuing to expand its use.
2 MEMBER BLEY: Okay. So it's going to more 3 and more licensees.
4 MR. MURPHY: Correct. And at both of my 5 plants we use the tools and we use them to help 6 develop our strategies and help look at the 7 effectiveness of those strategies. So --
8 MEMBER BLEY: And they also seem to be 9 extremely useful for evaluating the effects of 10 deficiencies that show up in the force-on-force 11 exercise.
12 MR. MURPHY: Right.
13 MEMBER BLEY: So instead of layer and 14 layer of less effective responses, you could save a 15 lot of money and effort and improve your performance.
16 And you're trying that.
17 MR. MURPHY: That's correct. And, yes, we 18 are -- we are using it actually at both of my plants 19 right now.
20 MEMBER BLEY: Does it -- but it doesn't 21 really help you respond to issues that come up.
22 MR. MURPHY: Not at this point.
23 MEMBER BLEY: Okay. Too bad.
24 MR. MURPHY: And then the last opportunity 25 that we see is the staff has identified that they want NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 to spend time going back and looking at the cross-2 cutting program. And we believe that as the staff 3 goes back and looks at the cross-cutting program, they 4 need to look at it from all aspects.
5 We are aligned that the changes the staff 6 made to the current -- to get us to the current cross-7 cutting program, that it works well, but we could see 8 that, you know, because of our improved performance 9 and the strong safety culture and performance 10 improvement cultures that we have at stations, that 11 the staff has the opportunity to continuously look at 12 our PI&R programs; that you could perhaps do away with 13 the cross-cutting process.
14 So as the staff does that assessment, we 15 would ask that they make sure that they include all 16 possibilities, not just increasing the application of 17 the cross-cutting program, but if there is a way to do 18 away with it.
19 MEMBER BLEY: I don't quite under that 20 that, Marty, because the cross-cutting programs seem 21 to get at those hard cases that could have very broad 22 impacts that you don't see from just focusing in on a 23 specific event, one at a time.
24 MR. MURPHY: They could. But I think when 25 you actually try to work through a series of discrete NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 events and look for common causes, you can -- you can 2 quickly become distracted if you have, you know -- I 3 think six is the area, in this specific area, but it 4 had been four. Licensees will typically at, say, the 5 50 percent point, start doing their causal evaluations 6 at three.
7 So you may have three in an area and start 8 doing your causal evaluation. They may be completely 9 discrete and not necessarily independent. You can --
10 well, we can expend a significant amount of effort and 11 become distracted trying to force-fit a common cause 12 on those issues. So --
13 MEMBER BLEY: I could see that. But if 14 you miss one, that's a pretty significant omission.
15 MR. MURPHY: Well, I don't know that I 16 would agree that it is a significant omission from the 17 standpoint you also have to consider what's the risk 18 of that specific cross-cutting issue.
19 MEMBER BLEY: Yeah. No. I'm saying --
20 MR. MURPHY: And the underlying --
21 MEMBER BLEY: -- but if you're not 22 looking, you're not going to see them --
23 MR. MURPHY: Well, so --
24 MEMBER BLEY: -- when they are 25 significant.
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92 1 MR. MURPHY: -- so the program doesn't 2 make us look and trend. We trend as a function of our 3 PI and our program. So we look and trend no matter 4 what.
5 MEMBER BLEY: I'm not following you 6 completely, but that's okay for now.
7 MR. MURPHY: Okay. And that is the extent 8 of my presentation.
9 MEMBER SKILLMAN: Marty, thank you very 10 much.
11 MR. MURPHY: Thank you.
12 MEMBER SKILLMAN: Colleagues, before we 13 wrap up here, any other questions or comments?
14 MEMBER BLEY: I have kind of two related 15 points.
16 MEMBER SKILLMAN: Please.
17 MEMBER BLEY: I take it since this was an 18 information brief today, our -- have we been asked to 19 do a letter on this?
20 MEMBER SKILLMAN: No.
21 MEMBER BLEY: I'm kind of uncomfortable 22 with us not responding, at least once the SECY comes 23 out, because this could be significant material in 24 order, you know, we might be able to help in this 25 area. But right now they're not looking for a letter, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 1 and we're not looking to write one.
2 MEMBER SKILLMAN: Yes, sir.
3 MEMBER BLEY: I think we ought to look at 4 that SECY paper.
5 MEMBER SKILLMAN: Okay. Anybody else? So 6 I would like to thank Russell and the NRR team and 7 Marty for your participation.
8 And with that, Mr. Chairman, back to you.
9 CHAIRMAN RICCARDELLA: Okay. Comments?
10 We're a little behind.
11 MEMBER SKILLMAN: Do we want to go to 12 public line? Is the -- Derek, is the public line 13 open?
14 Good morning. Is anybody on the line? If 15 so, would you simply say hello? Thank you.
16 Now, from anybody who might be on the 17 public line, if you would to make a comment, please do 18 so and state your name. Thank you. Hearing none, 19 we'll close the public line.
20 Is there anybody in the room that would 21 like to make a comment? Hearing none, Pete, thank 22 you.
23 CHAIRMAN RICCARDELLA: Yes. So we're 24 about 10 minutes behind schedule. I propose we take 25 a 15-minute break and reconvene at -- huh?
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94 1 MEMBER REMPE: We're 25 minutes late.
2 CHAIRMAN RICCARDELLA: Reconvene at 20 3 minutes to 12:00 -- 20 to 11:00.
4 (Whereupon, the above-entitled matter went 5 off the record at 10:25 a.m. and resumed at 10:42 6 a.m.)
7 CHAIRMAN RICCARDELLA: We're getting 8 further behind schedule on the break, so I'd like to 9 ask Charlie to take over and initiate the meeting on 10 digital I&C and 10 CFR 50.59.
11 MEMBER BROWN: Okay, this second part of 12 our full committee meeting is going to be a briefing 13 by the NRC staff on NEI 96-07 Appendix D, which is a 14 supplemental guidance for the application of 10 CFR 15 50.59, changes to the plant for digital modifications, 16 and the associated draft revision 2 to Reg Guide 17 1.187, which is the endorsing document for the 18 Appendix D.
19 Obviously, NEI has requested that 20 endorsement and today's briefing will not only be just 21 from the staff, but we will also have NEI's 22 participation and they will be able to provide their 23 perspective as part of this overall presentation.
24 We did have a subcommittee meeting on 25 April 16 where I think a large number of the members NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 1 were here. It was like eight or nine members out of 2 the total number.
3 But we have asked the staff to address 4 primarily a little bit of the history about why we're 5 here, but primarily we want to deal with the issues 6 and the differences between the NEI desires and the 7 staff's clarifications and exceptions within Reg Guide 8 1.187.
9 So with that, I think, Bill, you were 10 going to make some opening remarks?
11 MR. DICKSON: Yes, I was.
12 MEMBER BROWN: Okay.
13 MR. DICKSON: And again, I just want to 14 again talk about the purpose of today's briefing, and 15 you pretty much covered the purpose of today's 16 briefing.
17 But the staff presentation represents NRC 18 and the industry progress over a two-year period to 19 provide clarity as industry performs 10 CFR 50.59 20 screening and evaluation for potential digital I&C 21 plant modifications.
22 This work supports actions described in 23 the integrated action plan for modernized digital 24 instrumentation and controls, I&C regulatory 25 infrastructure.
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96 1 From April 2016 through 2017, the NRC 2 staff and industry participated in monthly public 3 meetings to resolve NRC's comment on the draft NEI 96-4 07 Appendix D.
5 In January of 2017, NEI and NRC staff 6 mutually agreed to place the review of NEI 96-07 7 Appendix D on hold to dedicate resources to the 8 issuance of a RIS 2002-22 Supplement 1. That's the 9 clarification on endorsement of NEI guidance and 10 design and digital upgrades for digital I&C.
11 The RIS was actually issued on May 31, 12 2018, and licensees are currently using the RIS to 13 plan and perform digital I&C modifications in their 14 plants.
15 So in July 2018, the NEI provided an 16 update to NEI 96-07 Appendix D, and in August 2018, 17 NRC provided a set of comprehensive comments, about 85 18 or so, to NEI, and again, to just begin the 19 disciplined process of cataloging and tracking the 20 comments.
21 There were five public meetings held with 22 industry to resolve these comments. Over 90 percent 23 of the comments were resolved using this process.
24 NEI submitted a final revision of NEI 96-25 07 Appendix D to the NRC in November of 2018 and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 1 requested endorsement by January of 2019. The draft 2 Reg Guide endorsing Appendix D was issued for a 45-day 3 comment period on May 30 of 2019.
4 The ACRS subcommittee on digital I&C was 5 briefed on Appendix D and Reg Guide 1.187 Revision 2 6 in April 2019 by NRC staff and NEI.
7 Members here today to discuss, to give 8 this presentation are Michael Waters from the Office 9 of NRR, the Division of Engineering, he is branch 10 chief, Philip McKenna who is with NRR and the Division 11 of Inspection and Regional Support, and Wendell 12 Morton, who is also in the Division of Engineering and 13 NRR.
14 We're ready to answer any questions you 15 may have and look forward to the discussion. Phil?
16 MR. McKENNA: Okay, so I'll take over for 17 the remainder of the brief. Good morning. Again, the 18 purpose today is to discuss 96-07 Appendix D and our 19 endorsed Reg Guide 1.197 Revision 2, and also to 20 discuss the current process for documenting digital 21 instrumentation and control modifications using the 22 50.59 rule. I do have --
23 MEMBER BLEY: Before you start, have there 24 been any changes since the subcommittee?
25 MR. McKENNA: So the only changes were in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 1 the wording, some revised wording in the Reg Guide, 2 but nothing of substance, so all of the same, the one 3 major exception, and all of the five other 4 clarifications remain.
5 MEMBER BLEY: Okay, thank you.
6 MEMBER BROWN: Just to make sure, were you 7 referring to changes, Dennis, after the 4/16 meeting?
8 MEMBER BLEY: Yes, I was.
9 MEMBER BROWN: Because the document we 10 reviewed for the 4/16 of 1.187, it did change. You 11 had input from --
12 MR. McKENNA: Yes, so we had input from 13 other staff and we --
14 MEMBER BROWN: And they are not trivial.
15 I mean, it was fairly -- I read the comparison of the 16 two and they were not -- there were some very pointed 17 differences.
18 MR. McKENNA: That's correct, but the 19 major, the five major, the five clarifications and the 20 one major exception remain the same.
21 MEMBER BROWN: Yeah, they remain.
22 MR. McKENNA: It's just the wording was 23 changed.
24 MEMBER BROWN: It was just the discussion 25 and the lead in had some more detail put into it --
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99 1 MR. McKENNA: Yes, sir.
2 MEMBER BROWN: -- and some deleted.
3 MR. McKENNA: Okay.
4 MEMBER BROWN: Okay.
5 MR. McKENNA: So Billy already covered 6 this. This is how we got to where we are today. I 7 will just go to the next slide. I wanted to, as a 8 refresher, give the 50.59 evaluation criteria because 9 this is one of our major exceptions. It's one of the 10 criterion in 50.59 for evaluation.
11 So again, a licensee can make a change to 12 its facility based on the 50.59 rule. There's a 13 screening part and then there's an evaluation part, 14 and they can do that change without coming to the NRC 15 if the change is not to a tech spec and they do not 16 meet any of the following eight criteria, and I will 17 not read all of the criteria. I'm just listing them 18 here. I'll go onto the next page.
19 I have highlighted criterion six, which is 20 what we are taking exception to in Appendix D, create 21 the possibility for a malfunction of an SSC with a 22 different result from any previously evaluated in the 23 FSAR as updated.
24 MEMBER BROWN: Can I correct that? You're 25 not arguing with the 50.59 rule words. What your NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 1 exception is to is to the interpretation by NEI to how 2 you apply that?
3 MR. McKENNA: That's correct.
4 MEMBER BROWN: Is that correct?
5 MR. McKENNA: That's correct, how they're 6 interpreting what's in Appendix D.
7 CHAIRMAN RICCARDELLA: I have just a 8 clarification on what you said. You said they can 9 make this change without coming to the NRC. It's 10 without a license amendment?
11 MR. McKENNA: Without a license amendment, 12 yes.
13 CHAIRMAN RICCARDELLA: It's not as if the 14 NRC is not aware that the plant is making a change, 15 right?
16 MR. McKENNA: That's correct. The rule 17 also requires at a certain periodicity that they 18 report all of the changes that they made under a 50.59 19 rule, so.
20 CHAIRMAN RICCARDELLA: But they don't have 21 to report plans to make a significant change?
22 MR. McKENNA: They do not need to. If 23 they're using the 50.59 rule to make the change, they 24 do not need to report that they're going to do that.
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101 1 that actually the case or --
2 (Simultaneous speaking.)
3 MR. McKENNA: We have inspect --
4 CHAIRMAN RICCARDELLA: We generally know.
5 I mean, don't your inspectors know that --
6 MR. McKENNA: Yes, so we have resident 7 inspectors at the site who are aware of the changes 8 taking place. They inspect the 50.59 process and the 9 modification process. They sit in on the planning 10 meetings. They'll sit in on the final approval 11 meeting if it's a major change, so the NRC inspectors 12 are aware.
13 MEMBER BROWN: When you said approval 14 meeting, you mean the licensee's approval meeting --
15 MR. McKENNA: The licensee's approval 16 meeting.
17 MEMBER BROWN: -- not the NRC's --
18 MR. McKENNA: That's correct.
19 MEMBER BROWN: -- approval?
20 MR. McKENNA: Yes, so there are certain 21 criteria that a licensee will have where a major 22 modification will have to go in front of their PORC 23 and, you know, resident inspectors will sit in on that 24 meeting.
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102 1 clear, there's a screening process, and the 2 documentation of that screening process is also 3 available if the resident inspector wanted to review 4 it?
5 MR. McKENNA: That's correct, yes. Okay, 6 so just to hop right in here to NEI 96-07 Revision 1, 7 so this is the base document that NEI and the NRC has 8 endorsed on how to do a 50.59 rule, a modification 9 using the 50.59 rule, and there is five different 10 sections in 96-07.
11 The first one is the applicability 12 section. Next is screening where you're screening if 13 the modification is adverse or not adverse. If it is 14 not adverse, the licensee stops there and they can go 15 ahead and implement the modification.
16 If it's adverse, they go on to the 17 evaluation process where they evaluate the 18 modification against those eight criteria I showed and 19 I'll stop there. And then it's applying 50.59, the 20 comp actions and dispositioning, the record retention 21 of the 50.59 evaluations.
22 CHAIRMAN RICCARDELLA: Could you help me 23 a little bit with the meaning of adverse and non-24 adverse?
25 MR. McKENNA: Yes, so it's basically a go, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 1 no-go, so you can go onto the next step in the 50.59 2 process. So if the modification is, you know, fairly 3 minor and straightforward, so risk-wise, it can be 4 screened as non-adverse.
5 CHAIRMAN RICCARDELLA: Without even 6 answering those --
7 MR. McKENNA: Without even evaluating it 8 against the evaluation criteria in 50.59, yes, sir.
9 MEMBER BROWN: Who develops the criteria 10 for determining adverse or non-adverse? Is that the 11 licensee that figures that out?
12 MR. McKENNA: So that's in the guidance of 13 NEI 96-07. It gives you the criteria for, which we 14 have endorsed, for how to do a screening.
15 Okay, so what makes digital I&C 16 modifications different in this process? Why are we 17 endorsing Appendix D?
18 MEMBER BROWN: Before you go on, when you 19 say they screen the quality, it's against the 20 information in 96-07 Rev 1? You're not talking about 21 Appendix D yet?
22 MR. McKENNA: I'm not talking about 23 Appendix D yet. We're just talking about Rev 1, yes, 24 sir.
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104 1 we understood that.
2 MR. McKENNA: Yes, we're building up to 3 Appendix D. So common cause failure is the main 4 reason why we need some more guidance for digital 5 modifications. When we had, you know, the nuclear 6 power plant built with hardware, it's easy to test 7 hardware and have standards in there. We have -- we 8 can tell if its degradation is slowly.
9 In this case, when you have software 10 involved in a modification, you can have a single 11 failure vulnerability or a common cause failure, so we 12 needed some way to address that when you're evaluating 13 a modification in 50.59.
14 So we issued the RIS 2002-22 Supplement 1 15 back in May to give some technical guidance on how to 16 address if a modification has a low likelihood of 17 failure or not. And the highlighted in yellow, the 18 RIS 2002-22 is not for replacement. Yes, sir?
19 MEMBER BROWN: You've already -- I'm 20 trying to get back to what I was asking you earlier.
21 MR. McKENNA: Yes.
22 MEMBER BROWN: You've gone through the 23 adverse and non-adverse already now.
24 MR. McKENNA: That's correct.
25 MEMBER BROWN: Now they're evaluating, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 1 the RIS 2002-22 Supplemental 1 would be used for the 2 evaluation?
3 MR. McKENNA: So, yes.
4 MEMBER BROWN: Now we're not in Section 5 4.3 in my terms --
6 MR. McKENNA: Okay.
7 MEMBER BROWN: -- my understanding.
8 MR. McKENNA: So you would not need to use 9 the qualitative assessment, which I'm discussing right 10 here, unless you screened the modification as adverse.
11 So you screened the modification as adverse. Now 12 you're into the evaluation section. We needed more 13 supplemental guidance on how to answer those 14 evaluation criteria for digital modification because 15 of the common cause failure issue for digital.
16 MEMBER BROWN: Okay, so if I put a little 17 line up at the top, I would say now screened as 18 adverse. Then you go on and use --
19 MR. McKENNA: And do a qualitative 20 assessment, yes, sir. So a qualitative assessment, 21 which I have in a couple more slides, allows you to 22 answer the evaluation criteria in the 50.59 rule.
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106 1 features, actuation system, or the internal logic 2 portions of the --
3 MEMBER BLEY: We talked about that. Does 4 it say that anywhere?
5 MR. McKENNA: It does say it right in the 6 RIS.
7 MEMBER BLEY: It's in the RIS?
8 MR. McKENNA: Yes.
9 MEMBER BLEY: It's not in the Reg Guide?
10 MEMBER BROWN: Could you say that again, 11 what it does? Repeat that because I want to make sure 12 we understand what Dennis just asked.
13 MR. McKENNA: So right in the RIS, those 14 words in yellow are right in the RIS. So it's not for 15 the wholesale replacement of the reactor protection 16 system or the engineering safety features, actuation 17 system, or internal logic system.
18 MEMBER BLEY: But are those words in the 19 NEI guide?
20 MR. McKENNA: No, no.
21 MEMBER REMPE: Or the Reg Guide?
22 MEMBER BLEY: Or in the Reg Guide? No?
23 MR. McKENNA: No. Well, we're -- so the 24 RIS is still in place, so nothing cancels the RIS.
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107 1 to do a qualitative assessment.
2 MEMBER REMPE: And if we go to the Reg 3 Guide, will the RIS still be in place or will --
4 MR. McKENNA: Yes.
5 MEMBER REMPE: So there is no need to have 6 such a statement in the Reg Guide?
7 MR. McKENNA: That's correct.
8 MR. MORTON: The Reg Guide is the general 9 overall 50.59 guidance for all different discipline 10 applications, mechanical, electrical, digital I&C too 11 included. The RIS is specific to digital I&C 12 applications.
13 MEMBER BLEY: So this is like NRC's 14 Appendix D if one were to make that comparison?
15 MEMBER BROWN: This is all without 16 Appendix D up until to this point?
17 MR. MORTON: Yes.
18 MR. WATERS: No, no.
19 MEMBER BROWN: We have not even started --
20 MR. WATERS: This is confusing. Let me 21 tell you how we got here.
22 We've had Appendix D for endorsement 23 review for quite a time, and we decided strategically 24 to do the RIS in parallel to that given some of the 25 issues we had with Appendix D to address the near term NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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108 1 obsolescent needs of industry for what we called 2 ocular support systems where they had systems ready to 3 go to install.
4 So we strategically developed this RIS to 5 provide a roadmap of how to do it for that, and we 6 noted not for RPS and things like that because we 7 realized there are broader questions. This was done 8 in parallel to the Appendix D. Appendix D was put on 9 hold.
10 What we're doing now with the Appendix D 11 endorsement review is applying some of the principles 12 of the RIS, the qualitative assessment, into our 13 Appendix D review so we have two products in parallel.
14 So I appreciate the questions, but that's part of the 15 confusion.
16 CHAIRMAN RICCARDELLA: In an ideal world, 17 wouldn't Appendix D have these yellow words in it? I 18 mean --
19 MEMBER BLEY: The NEI document is not 20 controlling.
21 CHAIRMAN RICCARDELLA: Yeah.
22 MR. WATERS: Part of the challenge, let's 23 be honest, is 50.59 does not distinguish between 24 digital systems, non-safety systems, or safety-related 25 systems. It applies to any plant change and we're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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109 1 hesitant to put in a primary guidance document to 2 limitation.
3 But we do talk about things like the 4 qualitative assessment and what it would apply to and 5 what it would not, and we want to look at endorsed 6 technical guidance that would be applicable to 7 different types of systems, so that's part of it.
8 But fundamentally, I don't think we can 9 absolutely preclude the use of 50.59 for any type of 10 system whether it be a nut or bolt or a major reactor 11 protection system, so that's part of the issue here.
12 MR. MORTON: Excuse me, one of the 13 clarifications we made with the Reg Guide endorsement 14 for Appendix D is to specifically acknowledge RIS 15 Supplement 1 as the staff's primary guidance when 16 performing a qualitative assessment, so it's embedded 17 within the Reg Guide endorsement.
18 CHAIRMAN RICCARDELLA: But you have to 19 look at so many different documents it seems like, 20 just to have it all in place.
21 MEMBER SUNSERI: But wouldn't anyone 22 anticipate though that if you went through the 23 qualitative criteria, that these wouldn't get through 24 anyway?
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110 1 it would not pass a 50.59, right. Any licensee can 2 use the 50.59 rule for any modification they'd want, 3 and it would anticipate that they would get -- it 4 would not pass the evaluation section. That's 5 correct.
6 MEMBER BROWN: One of the points in 7 Appendix D, the very last, this is what got me 8 confused when we were talking about this earlier.
9 Appendix D, example 22, I believe it is, talks about 10 an upgrade to a reactor protection system, and then 11 they go through their whole Section 4.3 analysis and 12 they end up that it doesn't pass. Therefore, you need 13 to get NRC approval of it.
14 MR. McKENNA: Right.
15 MEMBER BROWN: And I guess my confusion 16 was, well, gee, supposedly they're not allowed to do 17 that, but number two, they include it in an example in 18 the Appendix D which says, "We're going to do an 19 evaluation," which leads or implies that Appendix D 20 could be used as a vehicle for replacing the entire 21 RPS and SFAS system by doing a 50.59 evaluation and 22 running through the entire process.
23 So that's kind of a confusion example to 24 have as an example in Appendix D and still know that 25 by Supplement 1, you can't do this for RPS or --
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111 1 MEMBER SUNSERI: I guess my point only is 2 that these words are unnecessary if you truly believe 3 if you apply the criteria correctly, they would screen 4 out --
5 MEMBER BROWN: No, that's true.
6 MEMBER SUNSERI: -- of needed approval 7 anyhow.
8 MEMBER BROWN: That's -
9 CHAIRMAN RICCARDELLA: And is that what 10 happens with that example?
11 MEMBER BROWN: It was evaluated as the 12 licensee cannot do it.
13 MEMBER BLEY: But not on this basis.
14 CHAIRMAN RICCARDELLA: Pardon me?
15 MEMBER BROWN: Not on this basis, but 16 based on an Appendix B basis --
17 CHAIRMAN RICCARDELLA: Yeah.
18 MEMBER BROWN: -- which sounds like 19 Appendix D can be used for evaluation purposes for a 20 complete replacement, yet the supplement says not for 21 any of these, so, to me, there's a little bit of a 22 dichotomy there. That's all. That was confusing to 23 me.
24 MEMBER BLEY: But just for us, the 25 statement they've been talking about is on page two of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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112 1 the RIS right up at the top full paragraph.
2 MR. McKENNA: Okay, I'll move on. So now 3 I'm going to talk about the qualitative assessment, 4 which we've already broached that subject.
5 So originally, there was guidance in NEI 6 01-01 on the qualitative assessment, but not enough, 7 especially on how to do it, so that's what the RIS 8 does. It talks about how to do a qualitative 9 assessment, which I have in some more slides which 10 shows the criteria.
11 And mainly you do a qualitative assessment 12 so you can support the conclusion that there is not a 13 minimal increase in four. It applies to basically 14 four of the eight criteria in the 50.59 rule. And 15 again, I highlighted the one which we are talking 16 about in Appendix D as the exception.
17 So there's three things to consider in a 18 qualitative assessment. The first one is the design 19 attributes. How is the equipment built? What built-20 in features does it have, the fault detection, 21 diagnostics, et cetera, and there can be some external 22 features built in.
23 So the first one is the design attributes, 24 and there are some typical design attributes that you 25 would use in a system. The second one is the quality NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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113 1 of the design process, so the manufacturer, the 2 software development, if it's safety related, what 3 documentation is available for that component.
4 If it's commercial grade, you may not have 5 as much documentation, so you rely more on the design 6 attributes and any operating experience of that piece 7 of equipment.
8 And then the last one is operating 9 experience. I'll apologize for the typo in here.
10 That's not medification. That should be modification, 11 so any OE from the nuclear industry about the 12 equipment in use.
13 So that's how it inputs into a qualitative 14 assessment, and again, this happens after it's 15 screened as not adverse, and now you're going to use 16 the evaluation criteria.
17 So you do the qualitative assessment 18 first, and if it has, this piece of equipment has a 19 low likelihood of a failure, the licensee can stop 20 there and implement the modification.
21 If it has a high likelihood of a failure, 22 now they have to do the eval -- screen it again, so 23 all of the evaluation criteria, and they won't be able 24 to answer the evaluation criteria.
25 MEMBER CORRADINI: And how and low is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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114 1 quantitative? That binary decision is quantitative as 2 to what you pass or --
3 MR. McKENNA: So there is a definition of 4 the low in 96-07.
5 MEMBER BROWN: Okay, so if I go back a 6 slide, where would I say okay, now I've gotten through 7 all of this Supplement 1 qualitative --
8 MR. McKENNA: So the --
9 MEMBER BROWN: -- your evaluation process, 10 and you've determined that it's, what's the term?
11 MR. McKENNA: Low likelihood of failure.
12 MEMBER BROWN: Which slide would that --
13 where is the termination here? You don't have a 14 termination.
15 MR. McKENNA: So the termination is --
16 well, these slides don't run through the entire --
17 MEMBER BROWN: I know, but it should be 18 before you get into the Appendix D thing, right?
19 MR. McKENNA: Well, it's part of Appendix 20 D, right? So Appendix D takes you through the 21 screening.
22 MEMBER BROWN: Okay, so now we're 23 including Appendix D in this process, not in the 24 previous?
25 MR. McKENNA: Right, I'm about to go into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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115 1 the Appendix D portion, so maybe that will answer your 2 question.
3 MEMBER BROWN: Okay.
4 MR. McKENNA: Can we go back one slide?
5 So now we're going to start talking about Appendix D.
6 So a little bit of highlights about Appendix D, again, 7 the RIS 2002-22 gives the technical guidance for doing 8 a digital modification.
9 Appendix D gives the screening and 10 evaluation guidance for the 50.59 process for digital 11 modification. So nothing before talked about the 12 screening process for digital modifications. Appendix 13 D does.
14 The format of Appendix D, the paragraphs 15 align with the base document of 96-07 Rev 1 for ease 16 of use.
17 Some of the guidance in Appendix D is not 18 digital specific, so it expands upon more than just 19 digital, and Appendix D does incorporate the RIS 2002-20 22 supplement guidance on qualitative assessments, so 21 it mentions in Appendix D that you do a qualitative 22 assessment for the technical side of it.
23 MEMBER BROWN: Okay, why was the Section 24 3.15 --
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116 1 section, so it was just giving the definition of a 2 qualitative assessment.
3 MEMBER BROWN: So that's just a 4 definition. It was added to the NEI supplement.
5 MR. McKENNA: That's correct.
6 MEMBER BROWN: A new paragraph for 96-07 7 --
8 MR. McKENNA: That's correct.
9 MEMBER BROWN: -- without a rev.
10 MR. McKENNA: Right, exactly.
11 MEMBER BROWN: Appendix D kind of adds to 12 that without --
13 (Simultaneous speaking.)
14 MR. McKENNA: Right, right, because that 15 was not in the base document.
16 MEMBER BROWN: Yes.
17 MR. McKENNA: That's correct.
18 MEMBER BROWN: Okay, thank you.
19 MR. McKENNA: So I'm going to skip this 20 slide. This is what was our introduction of how we 21 got to where we are today in the development process.
22 So now I'm going to talk about our 23 exceptions in Appendix D, and the one major exception 24 again is the Criterion 6, and our exception talks 25 about how NEI is interpreting safety analysis.
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117 1 So they interpret it as to mean the 2 Chapter 15 accident analysis of the FSAR. We 3 interpret Criterion 6 as you have to evaluate is 4 against the entire FSAR.
5 So Appendix D deviates from the base 6 document and the guidance in that area, and again, we 7 have made it an exception in our endorsement of 8 Appendix D.
9 MEMBER CORRADINI: Since this is the crux, 10 can you say that --
11 MEMBER BROWN: Go back again.
12 MEMBER CORRADINI: Can you say it again, 13 please? I'm just trying to understand the difference 14 between how you interpret it versus --
15 MR. McKENNA: Yes, I'll rephrase 16 everything. So again, we start the process screening.
17 It screens as adverse. You have to do a qualitative 18 assessment to determine the likelihood of failure.
19 MEMBER CORRADINI: It's not low.
20 MR. McKENNA: It's not low, and you have 21 to use the evaluation criteria in 50.59. There's 22 eight criteria. In this case, this is talking about 23 the sixth one.
24 MEMBER CORRADINI: Which was highlighted 25 a few slides ago.
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118 1 MR. McKENNA: That's correct. So NEI's 2 interpretation of that, and I won't go back, is that 3 that criteria says against the FSAR.
4 MEMBER CORRADINI: Well --
5 MR. McKENNA: NEI evaluate -- their 6 interpretation is against the accident analysis 7 portion of the FSAR. Our interpretation is the entire 8 FSAR.
9 CHAIRMAN RICCARDELLA: But if you go back 10 to that slide nine that had that highlighted, I think 11 that it might -- the key discussion is the word on the 12 very last line, the word result. It's not a 13 difference in the FSAR. It was a difference in the 14 result, and NEI argues that result means a significant 15 effect on the probability of an accident.
16 MR. McKENNA: That's correct.
17 MEMBER BLEY: And the staff argues that if 18 there's any change in the SSC being evaluated --
19 MR. McKENNA: You have to evaluate it 20 against the entire FSAR, not just the accident 21 analysis.
22 MEMBER BLEY: Well, when you say against 23 the whole FSAR, the way you've said it before at the 24 subcommittee, you said that, but you also said the 25 malfunction of an SSC with a different result means at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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119 1 the SSC level, something is different in the failure 2 mode or how it responds --
3 MR. McKENNA: That's correct.
4 MEMBER BLEY: -- regardless of what that 5 impact is on the overall safety or risk.
6 MEMBER BROWN: An LAR is required under 7 those circumstances. A license amendment is required.
8 MEMBER CORRADINI: I don't want to 9 complicate matters, but I think Dennis said it in a 10 way I think I understand it, which is your 11 interpretation is if there's a change in the failure 12 modes, even if the failure modes aren't significant in 13 terms of how it affects accident analysis, it's a 14 problem.
15 MEMBER BROWN: It requires a license 16 amendment.
17 MEMBER CORRADINI: It requires a license 18 amendment. I'm sorry. It doesn't pass --
19 MR. McKENNA: Unless there's a low 20 likelihood of failure, right, in the qualitative 21 assessment portion. So you could do the qualitative 22 assessment and not have to answer this question.
23 MEMBER BLEY: But it's decoupled from the 24 impact of --
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120 1 trying to get at.
2 MEMBER RAY: Yeah, it's decoupled though 3 because you can't know what was credited to the thing 4 that's being changed in terms of its consequences. It 5 can have consequences on other things that are 6 described in the FSAR, not just on the event 7 consequence of interest. That's why this difference 8 exists.
9 It's very significant. It's not just some 10 legalistic semantic difference. It's a fundamental 11 difference in understanding what the FSAR is about.
12 MEMBER BROWN: The staff fundamentally 13 says the whole FSAR needs to be the result of that.
14 MEMBER RAY: Well, you don't have to work 15 on the whole FSAR, but you've got to consider --
16 MEMBER BROWN: Well, that's what they say 17 in the Reg Guide, the whole FSAR.
18 MR. MORTON: Based upon the actual full 19 quoted rule language. The rest of that actually says, 20 "Create the possibility of a malfunction of an SSC 21 with a different result than previously analyzed in 22 the FSAR as updated." So our position is the rule 23 language holds. It's the FSAR is updated, not --
24 MEMBER RAY: Yeah, but it holds for a 25 reason. I've read all of this stuff so far, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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121 1 nobody has ever explained the reason as I see it, 2 which is the FSAR is read and a reasonableness finding 3 is reached, a reasonable assurance of adequate 4 protection is reached on the totality of the FSAR.
5 You changed something that may affect 6 other things due to the change. You can't simply look 7 at the consequences of that change for a particular 8 action if it's analyzed because it may induce an 9 accident sequence on other stuff that's described in 10 the FSAR.
11 CHAIRMAN RICCARDELLA: But there's a 12 different question that asked that, isn't there?
13 Isn't it question five --
14 PARTICIPANT: Yes.
15 CHAIRMAN RICCARDELLA: -- that asked that?
16 Do you have those answers?
17 MEMBER CORRADINI: That's back a few 18 slides.
19 PARTICIPANT: But I don't think --
20 MEMBER RAY: Yeah, but that doesn't change 21 what I'm saying, Pete.
22 CHAIRMAN RICCARDELLA: The one that has 23 all six questions.
24 MEMBER CORRADINI: Slide five. My 25 interpretation of what Harold is worried about is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 encompassed in the one above the other one.
2 MEMBER RAY: Well, yes, I've read that, 3 but, the create a possibility of an accident of a 4 different type. I guess I'm looking at it from the 5 standpoint of the agency having reviewed the FSAR.
6 How do you -- I don't know how to identify that 7 there's an accident of a different type unless you do 8 an amendment.
9 In other words, you come back to the 10 agency having reviewed the FSAR and say, "This is not 11 going to affect anything else or the effect it's going 12 to have will be minimal." You have to postulate.
13 You would have to -- and listen, I've done 14 many, many 50.59, you're not going to have somebody 15 doing that who is capable, in my judgment, of 16 assessing what the implications are for the entire 17 FSAR. That's why you process an amendment.
18 MEMBER BLEY: Well, you do --
19 MEMBER RAY: I've done zillions of them.
20 MEMBER BLEY: Yeah, but why do you do the 21 amendment? One, because you have to, and two, they're 22 going to look at it, but if you put the right people 23 on it in the plant to examine the impacts of it --
24 MEMBER RAY: Well, you're sure to --
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123 1 responsibility.
2 MEMBER RAY: Absolutely, if you do the 3 amendment, I think you will have done what the agency 4 would do, and they say, "We confirm that you've done 5 an adequate job," but you have to do the amendment.
6 The problem that that represents is it's a heck of a 7 lot more work than processing a 50.59 change, which --
8 MEMBER CORRADINI: But I guess what I 9 thought Dennis was asking Harold is if you're going to 10 do the due diligence anyway, whether you do it before 11 or after NRC approval, it's got to be the same due 12 diligence. That's what I --
13 MEMBER RAY: If you can pass the test, I'm 14 telling you, Mike, that you apply in making 50.59 15 changes, if you pass it and you don't need the 16 amendment, you are not going to do the due diligence 17 that you will do if you have to do an amendment. That 18 is for sure. Dick will confirm it and I'm sure Matt 19 will as well.
20 MEMBER BROWN: So fundamentally, I'm 21 trying to -- I understand, I think I understand what 22 you're saying. Let me phrase it slightly different.
23 The process of getting to the point of low 24 likelihood such that you decide you don't have to do 25 one doesn't involve the same level of due diligence as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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124 1 if you had to submit an LAR, an amendment. Did I say 2 that right?
3 MEMBER RAY: You said it right, but I'd 4 also say the determination of whether there's a 5 possibility of an accident of a different type is not 6 something that will typically be addressed in a 50.59 7 evaluation that you pass and implement.
8 PARTICIPANT: It's one of the questions 9 that you have to ask.
10 MR. BEAULIEU: Can I clarify that?
11 MEMBER RAY: Yeah.
12 MR. BEAULIEU: I'm the agency's 50.59 guy.
13 I've been involved with this. I'm Dave Beaulieu. The 14 accident of a different type is a different explicit 15 definition and is being clarified by Rev 1 of this Reg 16 Guide, so that's really a different issue.
17 What this does is -- let's say that the 18 issue here is a software common cause failure, and 19 this is why the issue arises with digital, just 20 because software can introduce a common cause failure.
21 So now that we have a plant that was 22 designed for a single failure, which is typically the 23 loss of a single train, now you have a common cause.
24 You can lose all of the trains simultaneously.
25 So what is a different result is in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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125 1 chapter for every safety system, like in the 2 description of the chapter for like high pressure 3 safety injection, aux feed, or whatever it is, there 4 is typically an evaluation of common, of failure modes 5 and effects.
6 So a different failure mode is not a 7 different result alone. It's only if the effect is 8 different. The result is different. So now if you 9 have a single failure, the FSAR will say we have 10 redundant trains.
11 They're 100 percent capacity and we're 12 good to go, but if you have a common cause failure, 13 you lose both trains, and so you're not bounded by the 14 single failure because you've lost an entire safety 15 system. The safety system in nonfunctional. It goes 16 away, and it might not be explicitly described in the 17 accident analysis. It won't cover that level of 18 detail. That's in the chapter.
19 If the commission meant safety analysis, 20 accident analysis, they would have used that word.
21 They use the words in the safety -- in criterion 22 eight, they use the words in the safety analysis. In 23 other places, they specifically mention accidents 24 previously evaluated.
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126 1 or safety analysis for criterion six, they would have 2 said so. They didn't. They said previously -- it 3 says any previously evaluated in the FSAR. That's 4 what it says and --
5 MEMBER RAY: My comments were just not 6 limited to digital I&C. I was talking about --
7 MR. BEAULIEU: Yes, right.
8 MEMBER RAY: -- how it applies more 9 generally.
10 CHAIRMAN RICCARDELLA: But wouldn't this 11 common cause failure that results in the result of an 12 entire system and not just one train, wouldn't that 13 trip the question before the one? Wouldn't that say 14 that's an accident of a different type? It wouldn't 15 say it was just losing one train. I'm losing an 16 entire safety system.
17 MR. BEAULIEU: That's a different type and 18 the definition of that is not a simple answer. It's 19 being clarified in Rev 1. Does it create confusion?
20 It means an entirely different -- a different type 21 means it's an entirely different scenario that was a 22 different sequence such that if the plant was being 23 designed today, that scenario would have been included 24 in the FSAR.
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127 1 fall into that category, but it's really, criterion 2 five is not the primary challenge for common cause 3 failures of software or anything. It's criterion six 4 that's really the challenge, the different result, not 5 necessarily a different type.
6 MR. MORTON: But I want to clarify also 7 another piece to this because I'm hearing the 8 discussion.
9 One of the primary drivers for why we 10 wrote the RIS Supplement 1 in the first place is 11 because staff understood, especially working with 12 industry and hearing their feedback, that there were 13 four of those eight criteria that were very hard to 14 resolve when it comes to software common cause 15 failure.
16 So without the RIS and providing the 17 qualitative assessment, which is really taking an 18 engineering judgment on the design work that was 19 already done as part of the engineering change package 20 for the proposed mod, you're collecting that 21 information together and making an engineering 22 judgment on the likelihood of failure of the proposed 23 modification.
24 And if you determine it's low per the 25 definition within the RIS and NEI 101, then you can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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128 1 answer those evaluation questions as no, it's not 2 going to create an accident of a new type.
3 The likelihood of failure is low based 4 upon the collection of information on the engineering 5 judgment of the design features, quality design, and 6 operating experience you may have on that, and that's 7 what we've done for --
8 And that applies to most digital 9 modifications you can have except for those wholesale 10 RPS replacements so that you can answer the question 11 about whether it's an accident of a new type.
12 Well, if the likelihood of failure is 13 sufficiently low, it's not going to, similar to 14 criterion six. Is it going to be a different result 15 than previously analyzed?
16 If the likelihood of failure is 17 sufficiently low for the qualitative assessment, you 18 can answer that question no. That's what the RIS was 19 intended to do for many of those types of general 20 modifications that we're talking about.
21 MEMBER SUNSERI: So I just want to -- I 22 know -- I'm sorry, but I've got to -- I think we're 23 all still talking past each other because we're 24 getting so involved in the details of how to address 25 the questions.
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129 1 My understanding, which I think is similar 2 to Harold's, is that the fundamental difference is the 3 scope of how you apply these questions, right?
4 So industry is saying the scope of how we 5 apply these questions is Chapter 15, maybe 3 and 6 6 that they consider part of the safety analysis. The 7 regulation specifically says the final safety analysis 8 update, which encompasses all of that.
9 Harold's point is what does the regulator 10 use for the overall conclusion of adequate protection?
11 It's the whole final safety analysis report, just not 12 Chapters 3, 6, and 15. That's what we're 13 fundamentally talking about.
14 MR. McKENNA: That's correct. So I'm 15 going to move on. We've talked about a lot of these 16 slides that are at the end of the package. I will 17 probably go fairly quickly. Stop me if you need me 18 to.
19 I'm going to start talking about Appendix 20 D. The first part is the screening section. We have 21 no -- this is all fully endorsed in the Reg Guide.
22 This is how you do a screening for digital 23 modification.
24 Still in the screening section, this slide 25 just talks, highlights some of the portions of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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130 1 Appendix D that's new for digital.
2 MEMBER BLEY: Can I ask you a question?
3 MR. McKENNA: Yes.
4 MEMBER BLEY: Because early on, somebody 5 said, you know, why didn't you just spin the RIS into 6 the Reg Guide? And the answer was because the Reg 7 Guide covers all of 50.59.
8 But when you read the revised Reg Guide, 9 the revision was done for performing digital 10 modifications, and it has sections on digital 11 modifications background and it talks a lot about 12 Appendix D, so I don't quite get why you didn't weave 13 them all together.
14 I don't think the answer that the Reg 15 Guide applies to all of 50.59 answers that question, 16 going back to a question that somebody asked right at 17 the beginning.
18 MR. McKENNA: I'll answer it.
19 MEMBER BLEY: Okay.
20 MR. McKENNA: So in the development of the 21 Reg Guide, it was just to endorse Appendix D, right?
22 Appendix D, realistically if it were to expand it more 23 upon the Reg Guide, we could have weaved it all 24 together, but it didn't, so we had to include the 25 words of the RIS in total so we have the technical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 guidance available, and we considered that too 2 difficult to weave into the Reg Guide.
3 MEMBER BLEY: Okay, and a real easy 4 question if you got the answer, I've been spitting 5 through the Reg Guide here trying to find the call out 6 to the RIS, and I see that the RIS is one of the 7 documents in the reference list, but I haven't seen 8 the arrow pointing the person using the Reg Guide to 9 the RIS.
10 MR. McKENNA: So it would be in Appendix 11 D, right? So Appendix D --
12 MEMBER BLEY: Appendix D?
13 MR. McKENNA: No, Appendix D of 96-07, 14 right?
15 MEMBER BLEY: So the Reg Guide doesn't 16 point to the RIS?
17 MR. McKENNA: No, because we're using --
18 we're endorsing Appendix D, so we're endorsing the 19 50.59 process that the industry --
20 MEMBER BLEY: With exceptions.
21 MR. McKENNA: With one exception, right.
22 MEMBER BLEY: And the exceptions are in 23 the RIS.
24 MR. McKENNA: The exceptions are in the 25 Reg Guide.
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132 1 MEMBER BLEY: In the Reg Guide, okay. Oh, 2 that's that section in the Reg Guide that I had 3 trouble reading. Okay, go ahead.
4 MEMBER BROWN: So if this is at the point 5 where if it screens adverse, you go to the next page, 6 the evaluation section?
7 MR. McKENNA: Right, or you would do a 8 qualitative assessment before. Before trying to 9 answer the evaluation questions, you would do a 10 qualitative assessment.
11 MEMBER BROWN: And the way you do the 12 screening is per the guidance in Appendix D?
13 MR. McKENNA: Appendix D, that's correct.
14 MEMBER BROWN: That whole section on 4.2.
15 That's the screening section.
16 MR. McKENNA: That's correct.
17 MEMBER BROWN: Okay, so this is the 18 logical point where you would say all right, if we 19 want to make a change, we go do an initial assessment, 20 then we go do, oh, it's we got to go -- if it's 21 adverse.
22 MR. McKENNA: It screens as adverse.
23 MEMBER BROWN: Okay, and then you go to 24 the next page and you go into the full-blown 25 evaluation.
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133 1 MR. McKENNA: The evaluation section.
2 (Simultaneous speaking.)
3 MEMBER BROWN: -- about five or six --
4 MR. McKENNA: Right, and then in order to 5 answer those evaluation questions, you would do the 6 qualitative assessment first.
7 MEMBER BROWN: Per 2002-22.
8 MR. McKENNA: Per the RIS, that's correct.
9 MEMBER BROWN: Supplement 1.
10 MR. McKENNA: Right. Okay, this just 11 talks about how the Appendix D is aligned with 96-07.
12 It again highlights our major exception that we're 13 discussing in the Reg Guide.
14 In Section 4.3.6 of Appendix D, there is 15 a discussion on design basis functions. It connects 16 the design basis functions and the safety analysis 17 results, and I put in quotes there, "Unless the 18 equipment would fail in a way not already evaluated in 19 the safety analysis, there could be no malfunction of 20 an SSC important to safety with a different result."
21 And again, the industry, NEI has interpreted safety 22 analysis as the accident analysis.
23 These are the six steps in Section 4.3.6, 24 and steps five and six is what our exception covers 25 where they discuss identifying all of the safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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134 1 analysis involved, and then for each safety analysis 2 involved, compare the results with the previously 3 evaluated results for the modification.
4 Again, from step five, I just put some 5 quotes out of Appendix D. If there is no safety 6 analysis involved again, then you can't have a 7 different result with the malfunction.
8 MEMBER MARCH-LEUBA: So could you give us 9 a concrete example where this would work --
10 PARTICIPANT: Fail or succeed.
11 MEMBER MARCH-LEUBA: -- where this would 12 work, but the RIS would fail or -- you know what I 13 mean.
14 MR. McKENNA: All right, I will, but it's 15 at the end of the presentation and at the backup 16 slides. These are all backup slides. Oh, back one, 17 sorry, back two. There we go.
18 So here is our first example of how we say 19 this will fail. The component is a power operated 20 relief valve used to control RCS pressure during low 21 temperature operations.
22 The component malfunction would be a 23 failure to control pressure. So that is evaluated in 24 the FSAR in Chapter 5 and in Chapter 15, but not --
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135 1 analysis.
2 So they implement the mod and there is a 3 malfunction which causes the valve a failure to open.
4 So this results in a new failure mode where they have 5 a pressure excursion where they violate a brittle 6 fracture limit of the pressure vessel. So -- yeah, 7 isn't that question five? Doesn't that trip question 8 five? Doesn't that trigger a response to question 9 five?
10 MEMBER CORRADINI: I think where I'm 11 listening to Pete's question and your answer is it's 12 a matter of how much is done, how much analysis is 13 done within the context of 50.59 versus how much is 14 done in the context of a license amendment.
15 What I'm hearing is the level of due 16 diligence is different. Therefore, because it's 17 different, it's almost as if you don't believe that 18 criterion five is actually evaluated appropriately in 19 a 50.59. That's my interpretation of this whole 20 discussion.
21 MR. McKENNA: I won't argue with that and 22 if -- go ahead, Dave.
23 MR. BEAULIEU: This is Dave Beaulieu.
24 There is overlap in the questions, and so it's not 25 necessarily one covers it, so you get, you know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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136 1 credit. There is overlap in the question.
2 And in terms of due diligence, the purpose 3 of 50.59 is not directly tied to safety. It's tied to 4 what was the basis for us issuing them their license?
5 And if it caused them to question the basis for 6 issuing it, then we have these criteria, and those 7 things would require prior NRC approval.
8 Most of the things that are submitted are 9 safe. Well, virtually everything submitted to us is 10 safe. That's not the question. 50.59 has a different 11 purpose. It's a threshold for what needs NRC 12 approval. Is it outside of the envelope of what we 13 licensed the plant to do?
14 MEMBER RAY: Well, to answer Pete as 15 directly as I think I can, yeah, all right, but then 16 you need an amendment in order to make sure that 17 question is asked and answered.
18 You can't rely on the 50.59 process to 19 recognize, "Oh, there's another accident that has been 20 created by this thing." That's just the reality of 21 how 50.59s get processed. Any of us are going to tell 22 you that, Pete.
23 Sure, legally you should have recognized, 24 "I have now created the potential for another 25 accident," and that should trigger an amendment as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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137 1 needed, but you don't necessarily -- are going to 2 realize that.
3 So 50.59 processing doesn't encompass the 4 entire FSAR typically in reality. That's what an 5 amendment is for. I mean, you could make everything 6 an amendment if you wanted to from the standpoint of 7 being legalistic.
8 MEMBER BLEY: It almost sounds like that's 9 what you're arguing. That's why I'm a little --
10 MEMBER RAY: No, it's not. It's only --
11 MEMBER BLEY: -- tied up here.
12 MEMBER RAY: It's only in the 13 circumstances in which we're talking about a different 14 type of consequence occurring.
15 MEMBER CORRADINI: So let me ask that 16 question.
17 MEMBER RAY: And then you've got to have 18 some amendment process, I would say, to evaluate, 19 well, what's the potential effects of that?
20 MEMBER CORRADINI: But, I mean, let me ask 21 the question and then I'll stop because we're running 22 out of time. If I had a common cause -- the whole 23 point of this is the attribute of common cause failure 24 for the digital I&C system. At least that's what 25 staff is saying.
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138 1 If that's the case, then in a PRA 2 standpoint, I could essentially propose a common cause 3 failure of a particular controller that would take out 4 both trains. That's within the safety analysis, which 5 is part of the tangent on that, which is part of the 6 accident analysis.
7 So I would then consider creating a 8 different quality of accident because of a common 9 cause failure of a digital I&C part. I mean, isn't 10 that doing criteria five? I mean --
11 MEMBER RAY: Well, you know, I don't know 12 how to answer, Mike. I'm only saying that from my 13 standpoint anyway, when this possibility exists as the 14 staff reads the requirements of 50.59, it's 15 appropriate to process an amendment so you make darn 16 sure you've evaluated all of the consequences.
17 MEMBER CORRADINI: I get your point.
18 MEMBER RAY: All right.
19 MEMBER SKILLMAN: I did an awful lot of 20 these, and if I were doing a 50.59, everybody 21 understands 50.59 is a screening tool. It's a 22 screening tool.
23 Now, if I take the example that you've 24 identified that I'm changing the PORV, I would have 25 checked yes and yes on five and six. I would have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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139 1 checked them both and I would have --
2 Now, here is the deal and Harold pointed 3 it out very clearly. If you check no and no and 4 you're solid on your nos, you could be -- you stop and 5 you go ahead. When you check just one yes or more 6 than one yes, you are now into an analytical exercise 7 that could take six or 12 person months.
8 It is a huge investment, and so what 9 you're really doing is saying in the totality of my 10 FSAR and for common cause for digital I&C, I have a 11 new failure mode. I probably created a new accident 12 and that requires a huge amount of effort.
13 MEMBER BLEY: You know, at the place --
14 that all makes sense, and what Harold said makes 15 sense, but where I'm hanging up is the discussion we 16 had at the subcommittee meeting where it was argued 17 that this distinction in criteria six of what's the 18 different result is only relevant for digital I&C 19 systems and it shouldn't be reflected back to all of 20 the others, and you just shook your head.
21 If that's right, that makes a big 22 difference, but I thought it was argued we don't want 23 to be applying this to PORVs and other things. We 24 want to be applying it to just digital I&C systems.
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140 1 interpretation of the rule goes into effect, it would 2 be able to be applied to everything.
3 MEMBER BLEY: Well, that would make sense 4 to me, but I heard just the opposite at the 5 subcommittee meeting. That's why I'm confused here 6 because I heard it argued that it would not get 7 reflected back to --
8 MR. McKENNA: I think what we said in the 9 subcommittee meeting is that Appendix D is only for 10 digital, but once you apply the logic of what the 11 industry is trying to do, they could use it for 12 everything.
13 MEMBER SKILLMAN: That's what I remember.
14 MEMBER BROWN: That was an example that 15 they gave.
16 MEMBER BLEY: Could use, but doesn't have 17 to use, and that's the -- if this is the way it ought 18 to be, why shouldn't you have to do it for hardware or 19 whatever else comes along?
20 MEMBER BROWN: Didn't they use that as an 21 example that NEI did, the discussion where they talked 22 about that would start precluding certain failures, 23 replacements of a valve --
24 CHAIRMAN RICCARDELLA: A valve that opens 25 or is closed versus open.
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141 1 MEMBER BROWN: Ones that normally failed, 2 I can't remember which way, failed open, but now the 3 new replacement valve fails closed in some 4 circumstances.
5 CHAIRMAN RICCARDELLA: It has no effect.
6 MEMBER BROWN: It has no effect on the 7 analysis, and therefore, but we'd be precluded. We'd 8 have to come in and do an LAR for that, okay, which 9 that would, based on the process that we've just been 10 discussing here, and that seems to make some sense if 11 it didn't have any effect.
12 MEMBER MARCH-LEUBA: Well, if it didn't 13 have an effect, you never got to the question.
14 MEMBER BROWN: Well, it was evaluated in 15 the sense, in their terminology against the safety 16 analysis, not the whole FSAR, I mean update for the 17 FSAR as updated.
18 I'm remembering vaguely that discussion 19 and the argument would be that now this -- the logic 20 followed based on what you all are using as the 21 exception, if that was translated back into the other 22 realm, that would preclude a whole, you know, a whole 23 ramp of changes that had been made or we possibly 24 would --
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142 1 the rule.
2 MEMBER BROWN: Yes, which creates a 3 conundrum.
4 MEMBER BLEY: And their argument was it 5 would preclude new changes --
6 MEMBER BROWN: Yeah, exactly.
7 MEMBER BLEY: -- because they just wouldn't 8 pay for the LARs. They'd leave it like it is.
9 MEMBER BROWN: I understand the thought 10 process --
11 MR. McKENNA: Right, so --
12 MEMBER BROWN: -- but the concern is real.
13 MR. McKENNA: So this slide, I kind of 14 wanted to summarize what our exception really means, 15 so I put it in kind of basic guidance.
16 So a licensee is going to plan a digital 17 modification. They have selected a digital widget 18 from a first of a kind vendor that has not produced 19 nuclear components in the past.
20 So it doesn't pass the qualitative 21 assessment of a low likelihood of failure and it 22 creates a malfunction with a different result, so what 23 can the licensee do?
24 They can select a new vendor or they can 25 put the rigor in and submit the license amendment.
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143 1 That's the whole bottom line.
2 MEMBER RAY: Or they can qualify the 3 component.
4 MEMBER MARCH-LEUBA: Or the easy thing is 5 to use some diversity.
6 MR. BEAULIEU: Can I clarify? This is 7 Dave Beaulieu. The point was made about what the 8 industry said. The industry was talking about a new 9 failure mode would be a different result, meaning 10 they're saying that if the component was a failure to 11 open, the failure mode was failure to open, and now 12 after the mod, it could fail open or it could fail 13 closed.
14 They're saying, well, that's a different 15 result. That is incorrect. The guidance does not say 16 that. The regulation does not say that. It's the 17 effect. It has to do with the effect of the change.
18 So if now you have a common cause failure, 19 the failure mode is now two valves fail closed and 20 were done in trains, it's the effect of that. Those 21 two valves failing closed is what this criterion deals 22 with.
23 So for like a non-safety like main 24 feedwater, for example, 96-07 already gives that as an 25 example. Main feedwater is not credited anywhere. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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144 1 the chapter on main feedwater, it assumes a loss of 2 all main feed, so it's not a different result for main 3 feed or a lot of non-safety systems, but for safety 4 systems, the safety system is always credited in one 5 way or another in the safety analysis. It's credited.
6 And it might not be explicitly described 7 in the accident analysis, but it's always credited in 8 one way or another, and a loss of both trains of 9 safety system, that's what the concern is. That is a 10 different result.
11 MEMBER BLEY: Yeah, and the way you just 12 phrased it in terms of the effect seems to me it would 13 have, well, certainly at the subcommittee meeting it 14 would have eliminated a lot of the misunderstanding or 15 discussion.
16 If that's what's really intended, I don't 17 think it uses that, you use those words in the RIS.
18 Maybe you do. I got to go back and look. But I think 19 that would have helped a lot. And I suspect, although 20 we'll hear from the industry, from NEI in a bit, that 21 would kind of resolve the big concern in this issue.
22 It's clear to you right now. Is it clear 23 in the documentation that that's what you intended, 24 because I didn't think it was?
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145 1 your examples the more I'm with Pete in that when you 2 fail two systems because of CCF, you're creating a 3 failure of question five more than a, yeah, we don't 4 really need to modify six. But we need to emphasize 5 that when we mean a new accident we mean you're 6 failing everything. Whereas, in your old FSAR in 7 chapter 15, you only assume one failure.
8 I mean, you have two check valves, an 9 analytical check valve and mechanical check valves, 10 and you only assume one failed. And now you replace 11 it by a digital check valve. Both of them can fail.
12 And you never analyze that.
13 So I think the complaints you're hearing 14 is that our brain thinks more of question five. We 15 understand your problem. We agree with the problem.
16 And I am starting with a solution. But I think better 17 more five than six.
18 MEMBER RAY: Jose, the problem, that may 19 be. But the issue is how are you sure that you will 20 adequately answer question 5 when you do a 50.59 21 evaluation. I mean, an amendment isn't the end of the 22 world, my god. I've processed lots of amendments.
23 Yes, it takes more time and effort. But that's the 24 whole point of it.
25 CHAIRMAN RICCARDELLA: Yeah, but the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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146 1 frame, the bigger question I think, it's how much due 2 diligence do you do. You've clearly, you guys that 3 have operated plants clearly say you do a lot more due 4 diligence if you need to prepare an LAR than if you 5 don't, right? That's agreed.
6 But, you know, when you prepare an LAR, 7 there's a lot of additional cost and time. And all of 8 that cost and time isn't strictly related to the due 9 diligence. It's a whole bunch of other things. You 10 open it up to public challenge. You have --
11 MEMBER RAY: But there's one other --
12 CHAIRMAN RICCARDELLA: -- all kinds of 13 things. But, you know, so I think the question is how 14 do we limit the LARs to, the need for LARs to mods 15 that are truly safety significant and not have to be 16 doing LARs for everything --
17 MR. McKENNA: By using the qualitative 18 assessment.
19 MEMBER RAY: Wait a minute. I want to say 20 one thing before we go too far, what Pete said.
21 There's one other things you do in addition to more 22 due diligence. You also engage the staff.
23 CHAIRMAN RICCARDELLA: Yeah.
24 MEMBER RAY: And I don't think that is as 25 bad a thing to happen, or I guess I'll say it the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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147 1 other way. I think it's a necessary thing to happen 2 because not everything is described in the FSAR that 3 the Agency took credit for or considered or would 4 consider relative to reasonable assurance. It's not.
5 You can't say I know everything. I don't need anybody 6 else to look at what I've done. Okay. I'm sorry.
7 CHAIRMAN RICCARDELLA: Yeah, and when I 8 say due diligence, I'm saying the more due diligence 9 also includes the diligence provided by the staff.
10 MEMBER RAY: Doggone right.
11 CHAIRMAN RICCARDELLA: No question about 12 that. But I think the question is how do we limit 13 that to mods, things that are truly safety 14 significant. That's my perspective on it, so that 15 we're not doing, you know, unlimited LARs.
16 (Simultaneous speaking.)
17 MR. WATERS: That's the purpose of the 18 rule. I'm sorry. Do you want to --
19 PARTICIPANT: No, no.
20 MR. WATERS: That's the purpose of the 21 rule, that licensees must be safe. And all changes 22 you make, whether it's a law or 50.59, safe and 23 compliant, the purpose of the rule says does it pose 24 a safety question that NRC should independently audit 25 and confirm.
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148 1 They may well analyze two trains failing.
2 And they can mitigate it or already bound it. But the 3 purpose of the rule is is that type of analysis 4 something that NRC should independently audit and 5 confirm as part of the LAR process, which is our 6 ability to do so.
7 And these eight criteria are the 8 thresholds independently of when it crosses that 9 threshold and we need to review it. I just want to 10 emphasize time and criteria and six is about when you 11 cannot demonstrate common cause failures are 12 sufficiently low, what does it mean to have a 13 different result, a malfunction different result and 14 how are we interpreting that.
15 Staff believes that the base document, NEI 16 96-07, there's guidance for that right now for all 17 types of mods is adequate. And if you read it, it's 18 a pretty common understanding. We have a concern that 19 there's a different interpretation and different 20 criteria being introduced in Appendix D which it 21 deviates from. And that's the issue today.
22 MEMBER MARCH-LEUBA: Yeah, and is there 23 any digital modification that you can make that would 24 pass question 6? I mean, all of them have common 25 cause failure, and all of them are a new result.
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149 1 MR. McKENNA: So I have the list of 2 proposed mods that are happening right now out in the 3 industry.
4 MEMBER MARCH-LEUBA: Okay --
5 MR. McKENNA: So all these are being done 6 using the 50.59 process using a qualitative 7 assessment. So it's expected that none of these will 8 come into the NRC with a license amendment request.
9 So these are the types of mods that are happening 10 using the guidance and the RIS.
11 MEMBER MARCH-LEUBA: So how did they pass 12 the RIS generators?
13 MR. McKENNA: Because there is a low 14 likelihood of failure outcome in their qualitative 15 assessment. So the equipment's not going to fail. So 16 you won't have the common cause failure.
17 MEMBER MARCH-LEUBA: The digital controls 18 are really good.
19 MR. McKENNA: Yep.
20 MEMBER BROWN: And per the RIS.
21 MR. McKENNA: And per the RIS.
22 CHAIRMAN RICCARDELLA: You're saying it's 23 done before you get to the six, to the eight questions 24 --
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150 1 don't have to --
2 CHAIRMAN RICCARDELLA: -- screen, it's 3 screened.
4 MR. McKENNA: It is screened in. So it's 5 screened as adverse. You do the qualitative 6 assessment, the low likelihood of failure, so you can 7 answer no to the evaluation question.
8 MR. MORTON: So, if you look at the fourth 9 bullet in the second half, the digital inverter, so 10 PSEG and Hope Creek came in to visit the staff to talk 11 about their qualitative assessment for their digital 12 inverter replacement where they actually went through 13 the process, described some of the things they did, 14 some of the challenges they had.
15 And we thought that they generally did a 16 pretty good job of implementing it per what we wrote 17 and the expectations and the intentions that we had 18 with that.
19 And we've had other licensees come in and 20 do the same thing with the RIS using the qualitative 21 assessment for safety significant mods up into and not 22 including the RPS logic, trip logic, for example.
23 So what you're seeing here is an example 24 of a lot of mods that can be done and should be done 25 without license amendments. And that was the staff's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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151 1 intent with the RIS is to allow you to do a 2 significant number of safety-related modifications 3 without needing a license amendment request, because 4 we thought that they should be able to up into and 5 including wholesale replacement of RPS and SFAS.
6 MEMBER REMPE: So --
7 MEMBER BROWN: Hold it. You just said 8 wholesale replacement of the RPS and SFAS. They came 9 into you? You just lost with me with that. Is that 10 --
11 MR. McKENNA: He said up into, not 12 including.
13 (Simultaneous speaking.)
14 MEMBER BROWN: Oh, up, okay, that's what 15 you meant not including --
16 MR. MORTON: Yes, yes.
17 MEMBER BROWN: -- for changes not 18 including. I mean, I can envision like the digital 19 inverters, they will have microprocessors in them.
20 You can't find one to take with that.
21 MR. McKENNA: And they did --
22 MEMBER BROWN: And if you've got two 23 trains and you've got an inverter that's feeding the 24 motors that you need to drive, they're going to have 25 common processors that's not going to be different.
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152 1 More than likely it's a standard motor controller.
2 And now, you're in a condition where they could both 3 fail.
4 It's not like the RPS systems where we 5 have watchdog timers, et cetera, et cetera. So 6 tripping it or non-tripping doesn't make any 7 difference.
8 There four trains, you lock up, issue a 9 trip, you're still clean. That's why you have the 10 watchdog timers. Can't do that for the motor 11 controllers.
12 MEMBER REMPE: So --
13 MEMBER BROWN: They either start or they 14 stop.
15 MEMBER REMPE: So I was listening to your 16 recent meeting with the Commissioners. And industry 17 elaborated on I guess some example where they were 18 concerned on how they would demonstrate the 19 probability of a failure if you had digital I&C 20 components was sufficiently low without a lot of 21 testing.
22 And I think that that is their concern, 23 that, yeah, there's some examples you could get 24 through, but there will be some, unless you went to an 25 analog backup, it would be difficult to preclude a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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153 1 common cause failure.
2 And one of, the Chairman actually 3 suggested maybe some pilots are needed to try and work 4 through some of these examples. What is your plan on 5 responding to such a comment like that?
6 MR. WATERS: Yes, the context, or I think 7 the context of that conversation was primarily where 8 license amendment comes in or would not be 50.59. And 9 I just want to clarify that. So we're talking about 10 a license amendment.
11 MEMBER REMPE: And so this would not be 12 something they would try to -- you're right. It was 13 a bit off topic. But if they tried to do something 14 like this and they would have trouble doing a 50.59 15 without a lot of testing, would a pilot help?
16 MR. WATERS: Well, I don't think we do a 17 pilot 50.59, because the NRC doesn't review, does not 18 approve or deny.
19 MEMBER REMPE: Right.
20 MR. WATERS: That's a separate inspection.
21 That conversation was primarily based on a major 22 license amendment, which would be a SFAS and RPS.
23 MEMBER REMPE: Right.
24 MR. WATERS: And the question is how do 25 you address common cause failure and do a defense in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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154 1 depth analysis. And we're working that separate BPT-2 719. We're actually going to reface her later this 3 year on that.
4 We are open to using the guidance we have 5 for major applications coming in to test it out. We 6 call it e-plant pilot. We call it a pilot e-plant.
7 So we're eager to have those applications and work 8 through that to see if the lower alternatives, what 9 design majors and features analysis can be done to 10 demonstrate defense in depth against a common cause 11 failure.
12 But again, that, you know, the industry 13 has said that they don't plan to make these major 14 modifications under 50.59. They've said that. So 15 we're talking about a license amendment process --
16 MEMBER REMPE: Right.
17 MR. WATERS: -- where we look at the 18 design architecture and then defense in depth if it's 19 a common cause failure. And we're talking about a 20 purchase for that type of licensing analysis. And 21 we're willing to reorder license applications and test 22 that out. And we're going actually go back to 23 designs.
24 MEMBER REMPE: Okay. So, basically, I 25 mean, there's been real back and forth with this and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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155 1 disagreement with industry. And I assume that some of 2 it is because of trying to demonstrate a common cause 3 failure is fairly low as the issue here, at what 4 they're going, on how they're going to demonstrate 5 that.
6 MR. WATERS: Yes, for license amendments 7 I think the industry -- I don't want to speak for 8 industry. But I think they've asked for additional 9 ways to not do the defense in depth analysis that we 10 typically ask them to do to demonstrate there's no 11 significant vulnerability. It's a common cause 12 failure. But this is licensing since, and the 13 licensing since.
14 Here we're talking about, again, non-RPS, 15 non-SFAS systems where we're comfortable with them 16 saying common cause failure is sufficiently low enough 17 to answer these questions.
18 MEMBER REMPE: And they can demonstrate 19 that with --
20 MR. WATERS: Demonstrate that.
21 MEMBER REMPE: -- available without having 22 to have some examples to resolve --
23 MR. WATERS: And the conundrum of part 24 train 6 is whether they're able to demonstrate lags 25 and how do you analyze failure of multiple trains and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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156 1 what is, is it a different malfunction with a 2 different result. And that's the conundrum right now 3 for those type of systems.
4 MEMBER REMPE: Thank you.
5 MR. McKENNA: I've skipped ahead to the 6 last slide just to summarize after the list of mods I 7 put up there that the industry is currently doing 8 those modifications without the endorsement of 9 Appendix D right now. It would have had no effect on 10 those modifications.
11 And to have an effect, again, the 12 qualitative assessment would have to be more than a 13 minimal increase in likelihood of failure, and it 14 would have to meet the criterion 6. And I'll end 15 right there for any final questions.
16 MEMBER BLEY: Yeah, I've got two. One is 17 for David behind me. I'm going to see if I got your 18 clarification right. On number 6, where we talk about 19 a different result, my understanding of what you said 20 is that means some new effect on the description or 21 analysis somewhere in the FSAR on which the general 22 conclusions on safety are based. Is that a fair 23 paraphrase of what you said?
24 MR. BEAULIEU: It has to be any place in 25 the FSAR that describes the malfunction of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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157 1 affected system and the results of that malfunction.
2 And it's typically, it says a single failure. That's 3 the typical description.
4 And so, in the results of that, they 5 always say the result of that malfunction is we're 6 good. We have 100 percent predominant train, and the 7 plant is safe.
8 So, if you picked out both trains of a 9 safety system, in general the plant is not, there is 10 no, that's beyond what's evaluated.
11 MEMBER BLEY: I understand. But the first 12 part of that is that the way you just described it is 13 essentially what I said. But you've narrowed it to, 14 that describes the specific malfunction and its 15 results.
16 MR. BEAULIEU: Yes.
17 MEMBER BLEY: Those results as described 18 in the FSAR have changed. That's the key.
19 MR. BEAULIEU: Yes, that's --
20 MEMBER BLEY: -- the way you've 21 interpreted it.
22 MR. BEAULIEU: It has to be explicitly 23 prescribed, yes.
24 MEMBER BLEY: I don't think, I think if 25 the RIS had those words and if that's what everybody NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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158 1 else intends, it would be a lot more clear and some of 2 the confusion that we saw at the subcommittee meeting 3 wouldn't have occurred. And that still seems to be up 4 there. So I'll ask NEI about that when they come.
5 But I think that's a clarification that, 6 at least it helps me. And it kind of, it does make 7 sense for me here.
8 Now, the other question is I go ahead and 9 I do a 50.59 and I evaluate these and I say there's no 10 effect. And I do it. And you do an audit. The 11 inspectors do an audit. And they say we don't agree 12 with this. Then they send it back and have you guys 13 look at it. And you say, oh, man, that's a 14 tremendously big, new effect.
15 What happens to me as the guy who's 16 sending this thing that oversimplified the result --
17 MR. McKENNA: Right. So the licensee 18 would put that in their corrective action program.
19 And we would issue a violation. They would have to 20 correct that violation, which may mean that it would 21 now get submitted for a license amendment request. I 22 mean, that's simplified.
23 CHAIRMAN RICCARDELLA: But in the interim, 24 the change has already been done --
25 MR. McKENNA: Right.
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159 1 CHAIRMAN RICCARDELLA: -- and the plant is 2 operating in that --
3 MR. McKENNA: That's correct. So we would 4 have to evaluate for operability. I mean, they would 5 have to go through all the standard processes in place 6 to say they're operable. But, yes, they would have to 7 correct that deficiency.
8 MEMBER SKILLMAN: Well, and there's more 9 to that. You know, in our previous session from 8:30 10 to 10:00, this issue would go into the significant 11 determination process. There would be determination 12 of extent of condition. And I don't --
13 MR. McKENNA: Right, we would evaluate it 14 --
15 MEMBER SKILLMAN: -- be an alarmist, but 16 under the right conditions this could be a very 17 serious violation.
18 MR. McKENNA: Yeah.
19 MEMBER SKILLMAN: It could be. On the 20 other hand, it might be just minor.
21 MR. McKENNA: It could be. And --
22 MEMBER SKILLMAN: But the SDP would --
23 MR. McKENNA: 50.59 violations are 24 processed under traditional enforcement typically.
25 But, yes, it could go under the ROP also.
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160 1 MEMBER BLEY: Are they fairly common?
2 MR. McKENNA: No, there's probably I would 3 say maybe five violations per year on average --
4 MEMBER BLEY: Across the whole --
5 MR. McKENNA: -- of 50.59, across the --
6 MEMBER BLEY: Thank you.
7 CHAIRMAN RICCARDELLA: So I want to be 8 clear, because I got the impression at the 9 subcommittee from NEI that if we, if this difference 10 isn't resolved, that a whole bunch of digital mods 11 aren't going to be done because the operators will 12 decide we need it. What I hear you saying is that 13 most of these mods are going through with a 50.59 14 anyway.
15 MR. McKENNA: There's mods being plans and 16 accomplished today using the RIS.
17 CHAIRMAN RICCARDELLA: And the majority of 18 them won't require an LAR?
19 MR. McKENNA: Right, if they use the RIS 20 through the qualitative assessments and the 21 qualitative assessment says it a low likelihood of 22 failure, they won't, they'll do it through the 50.59 23 process.
24 MEMBER BALLINGER: Has there been an 25 example of one where it didn't or has failed the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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161 1 criteria? In other words, you've listed --
2 MR. WATERS: So we wouldn't know --
3 MEMBER BALLINGER: -- that went through.
4 But has there been an example of one that didn't?
5 MR. WATERS: Right, we wouldn't know 6 unless they came in with a license amendment request.
7 (Simultaneous speaking.)
8 MR. McKENNA: And nobody has.
9 CHAIRMAN RICCARDELLA: Have you had many 10 license amendment requests for digital I&C changes?
11 MR. WATERS: No, typically we get 12 amendment requests for reactor protection systems or 13 SFAS systems or components of it.
14 CHAIRMAN RICCARDELLA: Okay. The big 15 things.
16 MR. WATERS: We don't get those for the 17 auxiliary and support systems.
18 I want to answer one of the questions. We 19 are meeting with industry end of this month. And one 20 thing we want to talk about are what are specific 21 digital examples where they cannot address the common 22 cause failure sufficiently low question where 23 criterion 6 is important and interpretation of it 24 becomes important, because we want to hear about those 25 specific examples so we understand what the practical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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162 1 implications are.
2 And we'll have a few examples of where we 3 think it's unclear. We want absolutely clear 4 guidance. We don't want to have any adverse 5 inspection findings. We don't want to, on both sides.
6 So this is why it's important to get this guidance 7 correct.
8 MEMBER BLEY: I think those kind of 9 examples would be really helpful, because I have a 10 little trouble dealing with David said here. You 11 know, you go to the part of the FSAR that describes 12 this specific malfunction. Things are a little 13 different. So it's not exactly the same malfunction 14 that was in there. Is that a result or is that a, or 15 don't you have to look at it because it's a different 16 malfunction?
17 MR. WATERS: And all FSARs are different 18 and they have different little detail and they have 19 different scenarios to look at. So it's hard to have 20 a generic, it's hard without having actual examples.
21 That's what we're looking forward towards.
22 MEMBER BLEY: Okay. I think that would 23 help. And the one you had isn't really a digital one.
24 So I haven't seen a really good one yet. Go ahead.
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163 1 will that not affect perhaps what you have in the Reg 2 Guide, or, I mean, will you have to update it? I 3 mean, that's why --
4 MR. McKENNA: So the Reg Guide is out for 5 public comment right now. So we'll update the Reg 6 Guide based on public comments.
7 MEMBER REMPE: And you'll have those 8 examples to consider to see if some changes are needed 9 and you'll incorporate it at that time.
10 MR. WATERS: And that is our hope. But I 11 want to sort of go back to your pilot question.
12 MEMBER REMPE: Yeah, that's what I was 13 trying to get to. As we were talking about, you know, 14 what would make you guys come to consensus, and when 15 I heard that statement, I was like, well, I thought 16 examples or pilots would help --
17 MR. WATERS: People like to have practical 18 examples, really step through the practical examples.
19 When we did the RIS on the CCF, we had workshops where 20 we talked about actual upgrades and how to address 21 this. So, having actual examples and tabletop, that's 22 what, tabletop --
23 MEMBER REMPE: Right.
24 MR. WATERS: -- how would you apply the 25 guidance and whatever issues. We look forward to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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164 1 that. And hopefully we'll have that part of that 2 conversation at the end of the month.
3 MEMBER REMPE: Because it seemed like you 4 guys just couldn't work through the differences when 5 we had the subcommittee meeting.
6 MEMBER BLEY: Well, that seemed true. But 7 also I think I'm the last comment. In Section C2 in 8 the Reg Guide, that's the section that goes through 9 the exceptions and additions.
10 MR. McKENNA: Yes.
11 MEMBER BLEY: When I read through that, 12 and it isn't crystal clear, it seems like everybody 13 has thrown in a little piece that they were concerned 14 about. And it seems just a hodgepodge. So I think 15 you could really make that a lot more clear. And that 16 might help everybody.
17 MR. McKENNA: Thank you for your comment.
18 CHAIRMAN RICCARDELLA: Yeah, I think we 19 better get on with hearing from NEI if we could.
20 Thank you. Very interesting topic.
21 (Pause.)
22 CHAIRMAN RICCARDELLA: Ready? Okay. Good 23 afternoon, now. We're past morning. So, you know, we 24 postponed our next meeting. So we have until about 25 12:30 here --
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165 1 MR. GEIER: Okay.
2 CHAIRMAN RICCARDELLA: -- to cover this, 3 plus comment.
4 MR. GEIER: We'll walk through. And if we 5 want to have more discussion, you know, we're open to 6 --
7 CHAIRMAN RICCARDELLA: Okay.
8 MR. GEIER: -- supporting the Committee.
9 So my name is Steve Geier. I'm Senior Director of 10 Engineering Risk for NEI. And we're going to be 11 talking primarily focused on this one area of 12 contention. With me, primarily going to be doing the 13 technical discussion, will be Kati Austgen, my 14 colleague at NEI.
15 Just a couple comments to start out is, 16 you know, the main driver for this, for the whole 17 integrated action plan and these initiatives that 18 we've been working with the staff on is that there's 19 a real need for the plants out there to upgrade 20 obsolete and really antiquated analog systems.
21 And many of these upgrades are shown and 22 have been demonstrated through OE to improve plant 23 safety and to certainly improve, significantly improve 24 station reliability.
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166 1 which is for LARs, it really improved and streamlined 2 some of these. And as the staff talked about, we've 3 got about 60 mods that we've polled our members that 4 are moving forward primarily because of the RIS. And 5 these are all, these 60 are all under 50.59.
6 As of yet, we don't have anybody signed up 7 yet or kind of saying that they're going to move 8 forward with a SFAS or RPS. But there are some 9 considering it.
10 And I think one of the committee members 11 mentioned about a possibility of a pilot. We're 12 working with members on what that might mean and if 13 there's incentive there to kind of test this. And 14 it's primarily for the ISG-6, Rev. 1 process that was 15 just approved at the end of last year.
16 MEMBER BROWN: You said SFAS and RPS. I 17 mean, supplement 1 said don't use this for, you 18 wouldn't do a 50.29 --
19 MR. GEIER: Right, that would be done 20 under the ISG-6, the LAR process.
21 MEMBER BROWN: Yeah, okay. That's -- I 22 just wanted to make sure we were in the LAR process --
23 MR. GEIER: Because of the cost and 24 timeframe, that's where this pilot, where there might 25 be some additional funding or fee waivers.
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167 1 MEMBER BROWN: Well, there have been RPSs 2 done. Diablo Canyon did an RPS, which was approved by 3 the NRC. And Oconee I think did one which was 4 approved by the NRC.
5 MR. GEIER: That's correct.
6 MEMBER BROWN: So --
7 MR. GEIER: Those are two projects why 8 plants are very uncertain about moving forward and the 9 future just because of the cost --
10 MEMBER BROWN: Well, they sped through 11 fairly niftily. I didn't do the Oconee one, but I did 12 do the Diablo Canyon one, which was pretty 13 straightforward and not overwhelmingly complicated.
14 So those are the only two I'm aware of. Maybe --
15 MR. GEIER: -- for our members is that 16 those are reasons why they're very cautious about 17 moving forward because of the extreme cost, as well as 18 the additional schedule required because of the LAR 19 process.
20 MEMBER BROWN: Well, they were also 21 working out how you handle the common cause failure 22 issue relative to the use of watchdog timers and 23 control of access so that people can't come in 24 software-wise via the internet and change part of the 25 software. So they had to demonstrate --
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168 1 MR. GEIER: And our hopes are, as Mike 2 Waters and staff talked about, is the revisions that 3 BPT-719 might improve the, or would approve the way we 4 treat common cause failure for those significant 5 upgrades.
6 MEMBER BROWN: Okay.
7 MR. GEIER: And it might help streamline 8 those going forward.
9 MEMBER BROWN: All right. I just didn't 10 want to muddy the waters with RPS and SFAS stuff from 11 this particular conversation. That's all.
12 MR. GEIER: Right. And so all I want, 13 just to kind of introduce Kati, is Appendix D has been 14 a significant improvement document that we've been 15 working on. It has been going on for about five 16 years, which has been a very good interaction with the 17 staff. And we've resolved virtually all the questions 18 with the exception of this one.
19 And I think it's an important issue. Our 20 members feel like that's, for those, again, don't want 21 to kind of add on too much to what was already 22 discussed, but this question comes into play when it 23 cannot pass the RIS supplement 1 kind of screen, the 24 qualitative assessment.
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169 1 that are not going to be able to pass that. And so 2 the desire is to have this clean endorsement so that 3 those mods can also go forward under 50.59. That's 4 our overall desire.
5 So, with that, I'm going to turn it over 6 to Kati to talk about some of our issues.
7 CHAIRMAN RICCARDELLA: Excuse me just for 8 a second, Kati. I need to make an administrative 9 announcement that we have to get on the record.
10 We have a P&P meeting scheduled for 12:15.
11 And we've decided to postpone that till 12:30. So 12 that needs to be on the record. And we'll start our 13 P&P next door at 12:30. So we have until then to 14 continue and hopefully wrap up this meeting.
15 MS. AUSTGEN: I'm Kati Austgen from the 16 Nuclear Energy Institute. I might as well go ahead 17 and get into Appendix D. You heard a lot from the 18 staff about the purpose. I just wanted to reiterate 19 that 96-07 Appendix D is supplemental guidance for 20 digital modifications. It is intended to be used with 21 NEI 96-07, Rev. 1, which is the currently endorsed 22 guidance for all 50.59 activities.
23 I'll reinforce that Appendix D helps 24 licensees with the identification of UFSAR described 25 design functions relative to digital activities, how NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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170 1 and where to address common cause failure aspect in 2 the 50.59 process, and how to apply the qualitative 3 assessments to justify those conclusions.
4 And it also helps with detailed guidance 5 and examples on the combination of design functions, 6 which is back-to-back common cause failure piece.
7 That's a unique twist for digital activities that 8 probably would not see with the other activities that 9 plants have ongoing.
10 And as you know, criterion 6 then is the 11 most difficult one to address. And that's what we're 12 here to address today.
13 I also want to reiterate that the 14 engineering and technical work is complete to support 15 a 50.59 review conclusion. So that's the going in 16 premise for NEI 96-07, Rev. 1. It is equally the 17 premise for Appendix D.
18 These are nuclear professionals. These 19 are engineering professionals. They do their 20 engineering and technical work to determine if the 21 activity is a good idea. They ensure that safety 22 design and operational requirements will be met. And 23 so that has to be there for a 50.59 conclusion to be 24 reached.
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171 1 would be relied upon for a license amendment request 2 if it were determined that a license amendment request 3 is required.
4 And then, finally, on this slide as the 5 staff noted, 50.59 is a licensing or right-of-approval 6 review. So it is simply can the licensee do the 7 change on their own given all of the engineering and 8 technical work they have and applying the 50.59 9 regulation.
10 If they can do it on their own, then the 11 NRC would inspect those 50.59 evaluations following 12 the licensee's approval and implementation. If the 13 licensee cannot do it on their own, then the NRC would 14 approve it in advance with a license amendment should 15 the licensee choose to go forward with it.
16 MEMBER BLEY: If, in fact, the level of 17 technical review and work is the same as would be 18 required for an LAR, then your claim would be I guess 19 that the added cost with an LAR is the time it takes 20 to interact with the staff here and get the approval, 21 because you wouldn't need to do any further technical 22 work to support it.
23 MS. AUSTGEN: That's right. The added 24 cost and schedule uncertainty of a license amendment 25 request, interacting with the staff.
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172 1 MEMBER BLEY: But has it -- have you been 2 to the plant --
3 MS. AUSTGEN: I have.
4 MEMBER BLEY: -- of these?
5 MS. AUSTGEN: I have.
6 MEMBER BLEY: So you would claim that the 7 ones you gave to approve as 50.59 you had as much 8 detail as you would have had if you had the single 9 LAR.
10 MS. AUSTGEN: Yes, sir.
11 MR. GEIER: Yeah, if I can add, too, I've 12 been design manager at two different stations. And, 13 you know, I can also say that there is a separation of 14 processes. There's the engineering process. And 15 there's the licensing process.
16 The engineering process, that's all 17 completed regardless of the outcome, you know, of the 18 50.59 evaluation. You have your procedures and your 19 calculations and your analyses that are required.
20 What goes, the difference is once you've 21 decided that something goes into an LAR is you need to 22 write the LAR, submit the LAR, and then answer any 23 RAIs, interact.
24 And that typically, you know, for an 25 average one could add up to a year. And when you're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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173 1 looking at scheduling mods, typically these mods would 2 go in during an outage. That could mean you could 3 postpone it, you know, a year and a half to two years 4 because you would have to skip that cycle.
5 So that's where the timeframe comes in, 6 and then all the added cost of that delay. The 7 engineering work, that cost is the cost. It's not 8 going to change whether you're doing it under 50.59 or 9 you do it under LAR. It's that LAR, the licensing 10 cost.
11 CHAIRMAN RICCARDELLA: But some of my 12 colleagues who've been in operating plants implied 13 that a licensee does a lot more due diligence if an 14 LAR is required than if not.
15 MR. GEIER: My experience, I would contest 16 that. Now, there may be more work that has to be done 17 in answering RAIs. But the engineering work that 18 comes into and then writing the initial LAR, that's 19 the same. There's no difference.
20 CHAIRMAN RICCARDELLA: Just educate me.
21 Is there also a concern about once you have a license 22 amendment request, you're opening up to a public 23 challenge and could be delayed --
24 MR. GEIER: No, no. I would say public 25 challenge, that has no bearing on it. It's really the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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174 1 uncertainty and the, from a schedule and what changes 2 that might be imposed on by the staff to start getting 3 into the RAI and the challenge process.
4 CHAIRMAN RICCARDELLA: Okay. Thank you.
5 MR. GEIER: You're welcome.
6 MS. AUSTGEN: Okay. So then, we will 7 recap for you the major points of how we look at 8 addressing criterion 6.
9 And I do want to make clear that we view 10 this as being the same as NEI 96-07, Rev. 1. This 11 process may not be spelled out as explicitly. But the 12 process that we propose to follow is the same that is 13 followed in 96-07, Rev. 1. So, if the staff believes 14 that it is inconsistent with Rev. 1, then that is a 15 kick-out to something beyond digital.
16 But the way we've been implementing 96-07, 17 Rev. 1 for the past 20 years, the way we propose to 18 address criterion 6 in Appendix D, it is pulling out 19 those digital nuances so that you can still apply the 20 same approach as in 96-07, Rev. 1.
21 MEMBER MARCH-LEUBA: So what would you 22 have to do different if the Reg Guide is published?
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175 1 that would be different in criterion 6.
2 MEMBER MARCH-LEUBA: Can you provide us 3 with an example?
4 MS. AUSTGEN: I would rather defer based 5 on time and do the example in our public meeting later 6 this month. Happy to share those with the Committee.
7 MEMBER MARCH-LEUBA: I know we're -- I'm 8 looking at my watch. You're saying that Appendix D is 9 consistent with the regulation. The same law, the 10 regulation says Reg Guide, which is different. So we 11 do have a discrepancy. And an example would really 12 help a lot.
13 MS. AUSTGEN: Yes, yes.
14 MEMBER REMPE: Several examples that can't 15 pass would help a lot to work through this I think.
16 It sounds like the staff is interested in that. It 17 sounds like you are willing to provide some examples, 18 right?
19 MS. AUSTGEN: Yes.
20 CHAIRMAN RICCARDELLA: Is this public 21 meeting you referred to?
22 MS. AUSTGEN: So we're going to have a 23 public meeting with the staff. I believe it's going 24 to be June 25th.
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176 1 examples and illustrate the difference, how those 2 examples would go through Appendix D as written as the 3 industry says it ought to versus how it would go 4 through criterion 6 as the staff says it should based 5 upon their exception.
6 (Simultaneous speaking.)
7 MEMBER CORRADINI: Digital I&C examples.
8 MS. AUSTGEN: We intend to do both.
9 MEMBER CORRADINI: Okay. Thanks.
10 MR. GEIER: I should mention that there is 11 several examples already in Appendix D. But those are 12 examples using the industry's approach.
13 I think what we want to bring in is what 14 the impact would be, come up with some examples if we 15 use the staff's approach, how that would impact 16 several mods that otherwise would pass that particular 17 question.
18 MEMBER BROWN: So you're going to provide 19 examples in this public meeting of, to be explicit of 20 things that won't pass the exceptions. Now, with the 21 exception in there, you would not pass. And that's, 22 I think that's what Joy and Jose are emphasizing.
23 MEMBER REMPE: And it would be helpful if 24 the staff and industry could find a way through to 25 modify the Reg Guide in a way without just saying we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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177 1 fully endorse. Maybe it's also the NEI document needs 2 to have some changes. But there should be a way to 3 come to some sort of compromise I hope.
4 MEMBER BLEY: I'm thinking back to the 5 subcommittee meeting. You brought some examples at 6 that time. And the way this was stated toward the end 7 of our session with the staff, that a new result means 8 that somewhere in the FSAR it describes a specific 9 malfunction.
10 And the results of that malfunction and 11 the new result would mean that the results are 12 actually, you know, that has a new effect on the 13 results in that part of the FSAR, rather than simply 14 a different failure mode or something like that, which 15 is where a lot of the examples we talked about before 16 focused on.
17 Now, you may not agree with what was said 18 here. And that isn't, those words aren't in the 19 documents that I can find. If you have any comment on 20 that, I'd appreciate it.
21 MS. AUSTGEN: I think in going through our 22 four points, I think we can address that and help with 23 that. Okay.
24 So let's go ahead and go to our next 25 slide. So our first point was that a malfunction is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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178 1 defined. And it's not just a malfunction, but the 2 phrase in the regulation is a malfunction of an SSC 3 important to safety.
4 And that is defined in NEI 96-07, Rev. 1.
5 Of course, it is defined as a failure to perform a 6 design function. So it's not just any failure. It's 7 a failure to perform a design function.
8 Then, design function is also defined in 9 NEI 96-07, Rev. 1. And you can see on this slide 10 there's three different flavors of a design function.
11 We start in applying the 50.59 process by 12 looking as broadly as you can. Look at all the 13 failures that might be related to this activity. Now 14 figure out if it's a malfunction. Is it a failure to 15 perform a design function? If it is a failure to 16 perform a design function, figure out which kind of 17 design function it is.
18 Recall in criterion 6 that you're looking 19 at malfunction of an SSC important to safety with a 20 different result. So this slide is all about 21 answering that first question, what's a malfunction of 22 an SSC important to safety.
23 In order to get to that different result 24 piece, that's where we go further and we say, okay, we 25 know from definition of design function and definition NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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179 1 of design basis function that those are credited in 2 the safety analysis.
3 And we know from endorsed Reg Guides and 4 industry guidance that design basis functions are 5 described in safety analyses, not just accident 6 analysis, but safety analyses. But that also doesn't 7 mean the entire updated FSAR. And, again, there's a 8 definition for safety analysis. It's definition 3.12 9 in NEI 96-07, Rev. 1.
10 So, given that, I hope to clarify a little 11 bit of how the staff has characterized our position.
12 We do not say that safety analyses is strictly 13 accident analysis. It is bigger than that. But it is 14 not the entire updated FSAR, descriptive information, 15 text, tables, diagram.
16 You have to link it back to safety 17 analysis, what was actually performed to show that you 18 maintain the reactor pressure boundary, the integrity 19 of the systems, et cetera.
20 MEMBER BLEY: The way the staff phrased it 21 toward the end of that session isn't this way. It's 22 if somewhere in the FSAR a malfunction is described 23 along with the results of that malfunction, and that's 24 where they're saying they'd use the whole FSAR. Why 25 do you disagree with them?
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180 1 MS. AUSTGEN: So, again, getting back to 2 the failure modes piece of it, you might have a 3 failure modes and effects analysis. That might be 4 descriptive material in the FSAR.
5 In fact, Appendix B, bravo, to NEI 97-04 6 endorsed by Reg Guide 1.186, specifically says that 7 failure modes and effects analyses are descriptive 8 material. They are not the safety analyses, which is 9 what's being referenced as where you would find credit 10 for design basis functions and by extension design 11 functions because --
12 MEMBER BLEY: You kind of answered me by 13 pointing with your own definitions. But that's all 14 right.
15 MS. AUSTGEN: Yes. So let's keep moving.
16 MEMBER RAY: Of course, the S in FSAR 17 stands for safety.
18 MS. AUSTGEN: Yes, it does. Yes, it does.
19 So, and so we see Final Safety Analysis Report is a 20 big thing. It's defined by regulations. It has all 21 these constituent pieces and parts.
22 One sliver of that is safety analyses, 23 those things that demonstrate that the plant will be 24 able to cope with accidents and the things that are 25 presented to it.
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181 1 MEMBER MARCH-LEUBA: So, if the plant, the 2 FSAR assume a single failure of that one train on 3 chapter 15, now you have failure of two trains. Is 4 that a new accident?
5 MS. AUSTGEN: So --
6 MEMBER MARCH-LEUBA: What will happen? I 7 mean, I've been mixing.
8 MS. AUSTGEN: Yeah, yeah, so, again, we're 9 falling into the earlier discussion where we're mixing 10 and matching the different criteria. So I'll say it's 11 not a new accident, because if you already describe 12 one train failing and you could run that analysis and 13 say, well, now both trains failed --
14 MEMBER MARCH-LEUBA: My reactor brain says 15 you're in an analyzed condition. And therefore, you 16 should never satisfy the condition.
17 MS. AUSTGEN: So you will certainly 18 analyze it. Now the question is, from our perspective 19 if the safety analysis that demonstrated that you 20 would be able to make it through the loss of one 21 train, did it say you have to have the entire other 22 train, or did it say, you know what, I could have 23 neither train and I would still survive.
24 MEMBER MARCH-LEUBA: It's still an 25 analyzed condition. You have to analyze with failure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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182 1 of two. You either did or you didn't. And if you 2 didn't, then you have to do it again.
3 MS. AUSTGEN: But that's not --
4 MEMBER MARCH-LEUBA: And we have one and 5 a half minutes --
6 MS. AUSTGEN: That's what the criterion is 7 asking.
8 MEMBER MARCH-LEUBA: -- one and a half 9 minutes to go.
10 MS. AUSTGEN: Yeah.
11 MEMBER MARCH-LEUBA: So let's be done.
12 MS. AUSTGEN: Okay.
13 CHAIRMAN RICCARDELLA: Excuse me just for 14 a second. We've reached the witching hour of 12:30.
15 And so what's going to happen is we're going to keep 16 going with this meeting. But my two colleagues have 17 left to conduct the other meeting. And I'll keep 18 going. Thank you.
19 MS. AUSTGEN: Thank you. So, again, we 20 point back to a notice of proposed rulemaking. When 21 the current 50.59 rule was being promulgated, this 22 notice of proposed rulemaking explained the transition 23 from saying malfunction of a different type to 24 malfunction of a different result. And they explained 25 what result means.
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183 1 They say unless the equipment would fail 2 in a way not already evaluated in the safety analysis.
3 They do not say already described in the FSAR. They 4 say evaluated in the safety analysis.
5 MEMBER BROWN: Is this the version of 6 50.59 that was issued back in 1999 and early 2000?
7 MS. AUSTGEN: Yes, that's right.
8 MEMBER BROWN: I couldn't find this change 9 from type to result.
10 (Off-microphone comments.)
11 MS. AUSTGEN: Yeah.
12 MEMBER BROWN: I couldn't see, I couldn't 13 find a precursor. All I'm saying is I couldn't find 14 something before. All I saw was the end result. I 15 could not see what came before.
16 CHAIRMAN RICCARDELLA: You're saying it 17 was in the NPRM --
18 MEMBER BROWN: Yeah, I couldn't --
19 CHAIRMAN RICCARDELLA: -- notice of 20 proposed rulemaking.
21 MEMBER BROWN: Yeah, I couldn't find that.
22 So I was struggling.
23 MS. AUSTGEN: Right. Yes, it was in the 24 notice of proposed rulemaking. And I will go ahead 25 and give you the citation for the page of the Federal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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184 1 Register Notice.
2 MEMBER BROWN: Is there an ML number for 3 that?
4 (Off-microphone comments.)
5 MS. AUSTGEN: Okay. We'll give it to 6 Kathy.
7 MR. GEIER: Yes, we have a copy of the 8 page from that.
9 MEMBER BROWN: No, that's fine --
10 MR. GEIER: And we can provide a copy that 11 we've got. It's got the number on the top.
12 MEMBER BROWN: The history was tough to 13 find. That's all.
14 MS. AUSTGEN: Yep. Okay. Short answer, 15 it would not have an ML number, but it is in the 16 Federal Register. So --
17 MEMBER BROWN: That's fine.
18 MS. AUSTGEN: Okay. Let's go to the next 19 slide.
20 MEMBER KIRCHNER: Since we have more time, 21 maybe we can go back to what you were saying.
22 MS. AUSTGEN: Yeah.
23 CHAIRMAN RICCARDELLA: I'll point out to 24 my colleagues that the next meeting starts at 1:15.
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185 1 closed anyway.
2 MEMBER KIRCHNER: When you say you're 3 focusing on result, let's just take a broad category 4 of accidents like LOCAs. Now, if you have a digital 5 control system for the ECCS systems and you have a 6 common cause failure, typically when you do your LOCA 7 analysis, you assume a single failure somewhere in the 8 system, but you don't take out two divisions or four 9 divisions on an advanced plant.
10 But the potential could be there with a 11 digital control system for those different divisions 12 having a common cause failure. And then you would 13 take them all out. Are you saying that's not a --
14 that would result in quite a difference in the 15 outcome. So --
16 MEMBER CORRADINI: Can I ask your question 17 differently, because I think you're getting to the 18 crux of it? If I have a common cause failure, it 19 could be an electrical or mechanical component.
20 MEMBER KIRCHNER: Anywhere, yes.
21 MEMBER CORRADINI: And it doesn't have to 22 be a digital component.
23 MEMBER KIRCHNER: Yeah, it could be things 24 like --
25 MEMBER CORRADINI: But the assumption --
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186 1 MEMBER KIRCHNER: -- a safety --
2 MEMBER CORRADINI: -- in a single failure 3 criterion is that that probability is low.
4 PARTICIPANT: That's right.
5 MEMBER CORRADINI: And given that it's 6 low, still I will assume a single failure. So the 7 same logic would have to go with the digital 8 component, which is they'd have to show that the 9 digital common cause failure is low, but nonetheless 10 I'd have a single failure.
11 MEMBER KIRCHNER: Yeah.
12 MEMBER CORRADINI: That's what I think has 13 got to be -- I'm looking for -- Dennis said it early 14 in this discussion and I haven't left it, which is 15 what's good for the goose is good for the gander.
16 MEMBER KIRCHNER: Yeah, that's where I'm 17 going.
18 MEMBER CORRADINI: If we're talking 19 digital I&C, we're talking mechanical, electrical, 20 it's got to all be consistent.
21 MEMBER MARCH-LEUBA: Well, the staff told 22 us it's, all the examples that are going through the 23 system now are because they're not even doing 50.59.
24 They screen out at the beginning. The probability of 25 failure is so low that they don't have to evaluate.
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187 1 CHAIRMAN RICCARDELLA: They're not doing 2 the assessment. They're doing the screening.
3 MEMBER MARCH-LEUBA: Right. The screening 4 gets you out of the --
5 MR. GEIER: So, just to clarify if I can, 6 is the RIS, the qualitative analysis being done by the 7 RIS, that becomes an input. It's done under, it's not 8 necessarily part. It's not a question of 50.59. It's 9 not a part of that. It becomes input into the 50.59.
10 So, if you perform that and the results of 11 your qualitative assessment is that it's a low 12 likelihood of CCF, what that means for that question 13 is you don't need to consider that a malfunction will 14 occur as a result of a software CCF. That is what is 15 resulting in that question as being no.
16 Now, you still may not pass your screen.
17 You may still be doing an evaluation. And you still 18 have to look at those other questions. But the whole 19 idea of the qualitative analysis is to be able to 20 conclude that you don't need to consider software 21 common cause failure as a malfunction from the 22 component --
23 MEMBER BROWN: -- sufficiently low.
24 MR. GEIER: You've concluded sufficiently 25 low.
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188 1 MEMBER BROWN: That's what Mike said.
2 It's sufficiently low.
3 MR. GEIER: Therefore, you don't need to 4 consider that it's going to happen that that 5 malfunction is going to occur.
6 MEMBER MARCH-LEUBA: Now, the problem with 7 that approach, which I like, is that there are PhDs 8 being done about how to evaluate that probability to 9 failure. And you get three different digital I&C 10 experts, and you'll get five different answers.
11 MR. GEIER: And because you do the 12 qualitative assessment, that doesn't necessarily mean 13 that you're not going to do a 50.59 evaluation. You 14 still may be doing that evaluation. You just use the 15 results of that evaluation to help you answer your 16 questions. Hopefully, that helps on that.
17 CHAIRMAN RICCARDELLA: Is that what you 18 were referring to as the qualitative?
19 PARTICIPANT: That's the fourth.
20 CHAIRMAN RICCARDELLA: Yeah.
21 PARTICIPANT: That's on top of that --
22 CHAIRMAN RICCARDELLA: But that's what 23 you're referring to as the qualitative assessment?
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189 1 specific to CCF. There's other aspects of the 2 modification that you're also evaluating.
3 Because don't forget, I mean, you're 4 looking at the whole modification. You're looking at 5 everything from environmental qualification, from 6 structural, from, you know, because there's more 7 things that occur.
8 It's just that RIS gave us a way to 9 evaluate a digital mod for the potential of a software 10 CCF causing that to malfunction.
11 MEMBER BROWN: These are in kind of the 12 same ballpark. The initial screening -- oh, I'm 13 sorry. Thank you very much. I wish you all would 14 help me, okay, instead of having to have the briefers 15 do it. The screening is at the very -- it's adverse 16 or non-adverse.
17 CHAIRMAN RICCARDELLA: Yeah.
18 MEMBER BROWN: You haven't even gotten 19 down into the qualitative assessment. That's a higher 20 level worth of back of the envelope, whatever it is.
21 You'll look at it. I've got some new stuff in there.
22 And it performs differently than the old stuff. Could 23 there be a problem?
24 And if the answer to that comes out yes, 25 that's adverse. And you need to move into the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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190 1 evaluation period. And then you do the, you go 2 through the qualitative assessment with the RIS 3 approaches.
4 And if that's now low likelihood, in other 5 words, it's sufficiently low of a CCF, then you just 6 go ahead and do the change on your own. If it's not, 7 then you're in the LAR realm.
8 Did I phrase that properly? I'm trying to 9 get this down to -- I am too old to be convoluted 10 around. I just --
11 (Simultaneous speaking.)
12 CHAIRMAN RICCARDELLA: But some of it is 13 that second thing you said involves these eight 14 questions.
15 MEMBER BROWN: Yeah, the evaluation 16 involves the eight questions. The one on 6 is, is the 17 CCF consideration sufficiently low, and therefore I 18 meet that one and I don't have to anything more. You 19 may have to deal with one of the other ones I guess in 20 some circumstance. That's a different issue.
21 MR. GEIER: And if you look at the 22 engineering process, that qualitative assessment is 23 likely to be done as part of the -- it's new. So I'm 24 not sure how utilities are doing this. But it's 25 likely to be done as part of the engineering design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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191 1 package.
2 And so once that's complete and you have 3 this, so if you got a digital component, a digital 4 upgrade and there's a potential for software CCF, 5 you're likely going to do this analysis. And then you 6 take that whole package and then you apply 50.59 to 7 that, to the change in parallel, you know. Actually, 8 it comes after you complete --
9 MEMBER BROWN: -- you determine there's 10 something, a different common cause failure is a 11 possibility. And, therefore, you have to then move 12 into the evaluation --
13 MR. GEIER: And actually, I mean, 14 everything you do in the engineering world becomes 15 fodder for input for, in a 50.59 evaluation because 16 you look at, because it's all part of that change.
17 And I think in terms of flowcharts, you 18 know, how things -- and again, I come out of the 19 engineering world. And this is all being, it's an 20 engineering process. And then you take the results of 21 that and you apply the licensing piece, which is where 22 Kati comes from, and applies 50.59 rule to it.
23 MS. AUSTGEN: Okay. So we will provide 24 additional references for the staff to get to you on 25 changing from type to result and what that means.
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192 1 I'd like to move on to our third point 2 because that will I think help also. So one of the 3 issues going on at the time of the promulgation of 4 that 1999, 2000 rulemaking on 50.59 was that FSARs 5 varied in their depth.
6 And so how could we make sure that every 7 licensee, no matter how thick or thin their FSAR, was 8 being treated on a level playing field when it came to 9 whether or not they could make changes on their own 10 under 50.59?
11 And so the solution to that was to focus 12 on design function, because no matter how thick or 13 thin your FSAR was, it described if something had a 14 design function. That is, if it had to do something 15 in order to meet your safety analyses, that was 16 included in UFSAR.
17 So this is where looking at, hey, just 18 because I have a new widget and it wasn't described in 19 the FSAR, that doesn't give you a free pass. If your 20 new widget has some bearing on a design function, you 21 will find that design function in your FSAR. You'll 22 pull it into 50.59.
23 That's where you'll make your is it 24 adverse to the design function or not adverse to the 25 design function determination based on your technical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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193 1 work. And if it is adverse to the design function, 2 you will go on to the 50.59 evaluation and answer the 3 eight criteria.
4 MEMBER BLEY: Okay. So I like that. And 5 it's a little different than I think we heard back at 6 the subcommittee meeting. But if you got something 7 new and it's not in your FSAR, that doesn't get you 8 out of looking at it. You have to look for its design 9 function and that should be there.
10 I think that's a crucial point. This is 11 the first time I've heard it mentioned.
12 MEMBER BROWN: Yeah, and I'm hoping I can 13 get the transcript, because I couldn't write fast 14 enough.
15 MEMBER BLEY: Tonight.
16 MEMBER BROWN: It was very clear, very 17 crisp, and very linear. So --
18 MS. AUSTGEN: All right. We'll aim to 19 keep that up.
20 MEMBER BROWN: Give you credit for that.
21 MS. AUSTGEN: Okay. So then, if we take 22 that approach then, what we're saying is you look for 23 design function. That's not any and all descriptive 24 material in the FSAR.
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194 1 we're hearing from the staff when they say they want 2 to take exception to how we provide guidance on 3 criterion 6. They would say look at all the 4 descriptive material in the FSAR. Well, now you're 5 back to do I have a thick FSAR or a thin FSAR. And it 6 might make a difference.
7 And they're saying we're still sticking 8 with the design function. Identify the design 9 function, and then you can work through the steps of 10 the process. And thank you to the staff for putting 11 up the steps of the process in their slides.
12 MEMBER KIRCHNER: Isn't there some place 13 for common ground here with the staff and, because it 14 would seem to me, I'm kind of in Harold's camp, I 15 would go into the FSAR and look at the impact of the 16 change accordingly. For example, if we're changing 17 something like a valve on the primary coolant system, 18 I'm not going to be looking at the siting part of the 19 FSAR.
20 So, I mean, some sense and sensibility has 21 to apply here as well. I'm going to go and look at 22 chapter 3. I'm going to look at chapter 5. I'm going 23 to look at chapter 15. I'm not going to be off in 24 chapter 1 or 2 or however many volumes are on the 25 bookshelf.
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195 1 So it seems to me there's a way to find 2 some common ground with the staff in this particular 3 application of criterion 6.
4 MEMBER BLEY: I agree. And the way this 5 was presented, my memory of the Subcommittee was, gee, 6 if my FSAR was real thick and I've got one of these 7 widgets then I have to evaluate it, but if it's real 8 thin and I don't have one of these widgets, I don't 9 have to evaluate it. And that just didn't smell 10 right.
11 But if you can tie it to the design 12 function and evaluate against the design function, 13 that gives you a way not to let them fall through the 14 cracks.
15 MEMBER RAY: Dennis.
16 MEMBER BLEY: Yes, sir.
17 MEMBER RAY: If there's a failure, a 18 malfunction, that doesn't affect the design function 19 but it effects something else, I'm trying to think of 20 something really, because of the time, the malfunction 21 of the new device impacts other things in a way that 22 the, say it's, uses compressed gas to activate instead 23 of an electrical motor. Out of the air.
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196 1 malfunctioning could affect something else because 2 it's no longer using the same activation method. It's 3 using a compressed gas instead of an electric motor, 4 let's say. Or vice-a-versa.
5 I find it hard to narrow the circumstances 6 in which I'm only looking at whether there's a 7 different outcome for the design function as opposed 8 to a different impact because I've replaced one 9 component with another one that's perhaps very 10 different.
11 MEMBER CORRADINI: But wouldn't --
12 MEMBER RAY: And that's what causes me to 13 say, I don't care whether it's three volumes or 17, 14 the license is based upon the description of the 15 plant, and if the change affects that description, it 16 seems to me like a license amendment is required. I'm 17 done.
18 MEMBER CORRADINI: But I thought where we 19 were going, when you were saying looking for common 20 ground is, if you have identified the design function 21 and the modification effects that design function, 22 then you have to consider the results of a 23 malfunction.
24 Whether that malfunction, and I'm looking 25 at you guys, whether that malfunction is designated in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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197 1 Chapter 3, Chapter 6 or Chapter 15.
2 MEMBER BLEY: Or 9.
3 MEMBER CORRADINI: Or whatever. That's 4 what I --
5 MEMBER RAY: But you're limiting just to 6 design function now.
7 MEMBER CORRADINI: Well, I'm saying --
8 MEMBER RAY: Not to the kind of 9 hypothetical I was trying to come up with.
10 MEMBER CORRADINI: Yes, I can't deal in 11 hypotheticals.
12 MEMBER BLEY: The trouble with a 13 hypothetical is --
14 MEMBER CORRADINI: I'm dying for a 15 practical example.
16 MEMBER RAY: Well no, you just look at it 17 as if it were described that way in the original 18 submittal and say, well, that's all right.
19 MEMBER BLEY: Or it could be, with your 20 example, it could be that introduces, where the 21 original thing met one design function, the new thing 22 might affect some other design functions as well.
23 MEMBER RAY: It might affect something 24 else. I'm just saying, limiting the change to what 25 impact it has on the design function seems to me to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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198 1 too narrow. That's all I'm trying to say.
2 And I interrupted Mike, I'm sorry.
3 MEMBER CORRADINI: That's all right.
4 MEMBER BROWN: Well, the way she said it, 5 the design function just, you still have to, if it's 6 not, you still have to assess it if it effects a 7 design function. Even if it's not stated in FSAR or 8 the old FSAR. The thinner volume.
9 MEMBER CORRADINI: But the design function 10 has to be stable.
11 MEMBER BROWN: Yes. Yes.
12 MEMBER BLEY: But now you got to go back 13 and define --
14 MEMBER BROWN: I got to go back and read 15 the words from the transcript --
16 MEMBER BLEY: -- what design function 17 means.
18 MEMBER BROWN: -- because I've lost it 19 already.
20 MEMBER BLEY: That's where she started.
21 MEMBER RAY: Well, what I meant was, it 22 doesn't create a hazard that didn't exist before, for 23 example. But that's what I'm saying.
24 MR. GEIER: The one thing I'd say is that 25 we describe, is you take something that maybe was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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199 1 designed a certain way and you change that design.
2 But the whole idea of it, it would still be performing 3 the same design function but the engineering analysis 4 looks at those things.
5 If you change something from say mod 6 powered by power and you put in a air operator valve 7 and you're running air, you know, you look at all 8 those impacts of those design, not just the function 9 of that. You look at everything that's brought into 10 that --
11 MEMBER RAY: Yes.
12 MR. GEIER: -- the entire mod, that's done 13 in the engineering space.
14 And then you take the results of that 15 engineering analysis, and how that effects the design 16 function and you evaluate under 50.59.
17 MEMBER RAY: But you have to understand 18 how to define, how to limit the boundaries of the 19 design function. Is the design function not to create 20 a hazard of an electrical explosion, for example.
21 You know, I think we're trying to squeeze 22 into a few seconds, a discussion that's a longer 23 discussion inevitable, that we'll probably have after 24 this is over.
25 MS. AUSTGEN: So, to keep --
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200 1 MEMBER BLEY: Keep rolling.
2 MS. AUSTGEN: Yes. To leave this point, 3 I will leave you with NEI 96-07 Rev 1, Definition 3.3 4 of change. In the discussion provides what a design 5 function is. And so that is --
6 MEMBER BROWN: Where did you say that was, 7 96?
8 MS. AUSTGEN: 96-07 --
9 MEMBER BROWN: Where?
10 MS. AUSTGEN: -- Rev 1.
11 MEMBER BROWN: Where?
12 MS. AUSTGEN: 3.3.
13 MEMBER BROWN: 3.3, okay, I got that now.
14 MS. AUSTGEN: The definition of change.
15 MEMBER BROWN: Okay.
16 MS. AUSTGEN: And in the discussion for 17 that definition provides what a design function is.
18 Okay, so let's keep going. Additional, so 19 I've tried to clarify that the way we have described 20 implementing criterion 6, the guidance for Section 21 4.3.6 in Appendix D, we see that as consistent with 22 NEI 96-07 Rev 1, Section 4.3.6.
23 We also see that as consistent with some 24 other 50-59 criteria. And this was to get to the 25 Staff's point about going back to the text of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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201 1 regulation versus what we have in guidance 96-07 Rev 2 1.
3 Well, if you go back to the text of the 4 regulation, on some additional criteria it also says, 5 previously evaluated in the final safety analysis 6 report as updated. I will grant you that says, final 7 safety analysis report as updated.
8 But, based on existing guidance, we have 9 understood that to mean, for the last 20 years, that 10 evaluated in the final safety analysis report means in 11 safety analyses. Those are specific calculations 12 underlying your conclusion --
13 MEMBER MARCH-LEUBA: I still don't 14 understand what chapters you will be worried about?
15 MS. AUSTGEN: We don't --
16 MEMBER MARCH-LEUBA: Give me example.
17 MS. AUSTGEN: We don't narrow it down to 18 chapters.
19 MEMBER MARCH-LEUBA: Yes, well give me 20 one.
21 MS. AUSTGEN: I'm not going to give you a 22 chapter. I'll give you the definition of safety 23 analysis.
24 MEMBER MARCH-LEUBA: You always forget 25 about this.
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202 1 MS. AUSTGEN: I know.
2 MEMBER MARCH-LEUBA: So there is an 3 example that you can give us and are willing to, and 4 therefore I'm suspecting you're modest.
5 (Laughter.)
6 MEMBER MARCH-LEUBA: And you got ten 7 minutes to close this up.
8 MS. AUSTGEN: I'm an open book but I can't 9 go into examples because, as we said, they're open 10 ended and they go forever so we'd rather hold that for 11 the public meeting.
12 What I will tell you is, what we believe 13 safety analyses are, are as defined in 3.12 of NEI 96-14 07 Rev 1.
15 Safety analyses are analyses performed 16 pursuant to NRC requirements to demonstrate the 17 integrity of the reactor coolant pressure boundary, 18 the capability to shut down the reactor and maintain 19 it in a safe shutdown condition, or the capability to 20 prevent or mitigate the consequences of accidents that 21 could result in potential offsite exposures comparable 22 to the guidelines in 10 CFR 50.34(a)(1) or 10 CFR 23 100.11.
24 MEMBER MARCH-LEUBA: So --
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203 1 completeness.
2 Safety analyses are required to be 3 presenting in the UFSAR per 10 CFR 50.34(b) and 10 CFR 4 50.71(e) and include, but are not limited to, the 5 accident analyses typically presented in Chapter 15 of 6 the UFSAR.
7 MEMBER CORRADINI: But to use your three 8 or four, I can't remember, criteria attributes, I'd 9 find those in Chapter 3 if I was talking about 10 structural components, or SSCs. I find them in 11 Chapter 5 relative to reactor pressure vessel 12 integrity.
13 MS. AUSTGEN: Yes.
14 MEMBER CORRADINI: So, my interpretation 15 is, it's got to be throughout the FSAR as applicable.
16 MS. AUSTGEN: Yes.
17 MEMBER CORRADINI: Okay. Not just Chapter 18 15.
19 MS. AUSTGEN: Correct.
20 MEMBER BROWN: Okay. She's almost done 21 now, right?
22 MS. AUSTGEN: I am.
23 MEMBER BROWN: Okay.
24 MS. AUSTGEN: I am. One more slide.
25 Let's get us to our summary slide. There we go.
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204 1 Okay. So, we follow previously approved 2 definitions, we look at the rulemaking record, and our 3 two decades of experience with implementing 50.59 to 4 understand that when you look for a malfunction, 5 you're looking at failure to perform a design 6 function.
7 When you look for a different result, 8 you're looking at the safety analysis level. And 9 again, that was definition 3.12, safety analyses.
10 We've talked a little bit about, unless it 11 would fail in a way not already evaluated, there is no 12 need for the NRC to review the change. That's part of 13 the rulemaking record. And the logic, we believe, is 14 consistent with the application of the other 15 evaluation criteria.
16 MEMBER BROWN: Can I just make one 17 observation. And this kind of supports a little bit 18 of the Industry's position.
19 NEI 96-07 goes through and uses, as a 20 basis for their whole approach on the item, Criteria 21 6, about a page and a half where they go through 3.3, 22 3.12, 3 point, the NRC endorsed those almost 19 years 23 ago. So NEI 96-07 was endorsed without exception, 24 without clarification in 2000. In the initial Reg 25 Guide 1.187.
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205 1 So there is a past, a history, that's all 2 I'm saying, of the utilization of these thoughts.
3 These engineering thoughts, design basis thoughts, 4 what are malfunctions, what are design functions, et 5 cetera, as well as the safety analysis for the last 19 6 years.
7 So, we have accepted, at least NRC has 8 accepted that at some point, as some of the criteria 9 used for evaluation. So it's all in there, it's just 10 a matter of how you tweak the nuances of how you use 11 it.
12 Are there any more questions? You're 13 complete, Kati? I'm sorry, I interrupted you.
14 MS. AUSTGEN: Yes, we're done. Thank you.
15 MEMBER MARCH-LEUBA: I'm confused.
16 CHAIRMAN RICCARDELLA: I'm more confused 17 now because I don't think I understand what the 18 disagreement was.
19 MEMBER BROWN: I'm like, it seems to me I 20 agree with you, Dennis. I think there's some realm 21 that seems to me that the Staff and NEI can come up 22 with a way of phrasing that exception in a manner that 23 would end up being acceptable to both parties. And 24 allow it to be, to move on.
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206 1 how to do that.
2 MR. GEIER: We're very hopeful that by 3 using some examples in this meeting on June 25th, it 4 will help bring some --
5 MEMBER BROWN: Examples of how it doesn't 6 work, one way or the other would be 7 MEMBER BLEY: Both ways.
8 MEMBER BROWN: -- both ways, would be 9 very, very helpful. In other words, examples that 10 won't work relative to their thought process and 11 therefore they're concerned and thought process for 12 yours relative to your concern.
13 CHAIRMAN RICCARDELLA: Or an example that 14 would pass on the Industry's interpretation but not 15 pass on their --
16 MEMBER BROWN: And be a problem under 17 theirs.
18 CHAIRMAN RICCARDELLA: Yes. Yes.
19 MEMBER BROWN: Okay. That's the crux of 20 the thing.
21 MEMBER MARCH-LEUBA: And that would be a 22 public meeting so the slides will be available?
23 MR. GEIER: That's correct.
24 MEMBER RAY: By not pass, Pete, you mean 25 would not require an amendment?
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207 1 MEMBER BROWN: Yes.
2 CHAIRMAN RICCARDELLA: That in accordance 3 with the Industry interpretation wouldn't require an 4 amendment, but in accordance with the Staff's 5 interpretation would.
6 MEMBER RAY: Right. I should have said --
7 CHAIRMAN RICCARDELLA: I'd like to see an 8 example of it.
9 MEMBER RAY: -- to pass means not 10 requiring an amendment.
11 CHAIRMAN RICCARDELLA: Yes.
12 MEMBER BROWN: I'm done. Should we go on 13 to go to public comments?
14 CHAIRMAN RICCARDELLA: Yes.
15 MEMBER BROWN: Is the line open, Kathy?
16 (Off microphone comment.)
17 MEMBER BROWN: Okay. I guess I can do 18 that simultaneously. Is there anybody in the audience 19 that would like to make a comment? Based on --
20 MR. LEWIS: My name is Marvin Lewis.
21 MEMBER BROWN: Hold on just a minute. I 22 don't see anybody from the room that wants to make a 23 comment.
24 Public line is open. Can you, I think I 25 heard somebody, could you say something again to make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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208 1 sure it's open?
2 MR. LEWIS: My name is Marvin Lewis. Can 3 you hear me?
4 MEMBER BROWN: Yes, thank you very much.
5 Okay, if there is anybody on it we can go ahead and 6 start and make some comments from the public. Marvin, 7 since you answered you're first.
8 MR. LEWIS: Yes, I've been listening as 9 best as I can, and I was listening when you were 10 talking about backups and separation of trains and 11 stuff like that. And it seems to me that you're 12 ignoring the problem and asking for a verbal solution.
13 Just solving the problem by words.
14 That might be a real, real problem. And 15 that's, you know, software, hardware, computer 16 digitalization is one thing, but having two trains of 17 tables going across the floor separated by a certain 18 amount or a two sets of valves and two sets bypasses, 19 or whatever, it's real.
20 And I don't hear anybody saying, let's go 21 out and take a look at the SSC. The actual item we're 22 talking about. Thank you.
23 MEMBER BROWN: Okay, thank you very much, 24 Marvin. Thank you, Marvin. Is there anybody else on 25 the public line that would like to make a comment?
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209 1 Hearing none I will pass this back to you, Pete.
2 CHAIRMAN RICCARDELLA: Okay, thank you.
3 We'll recess the meeting until 1:15. Not much time 4 for lunch, but the cafeteria is closed so it doesn't 5 matter.
6 MEMBER REMPE: Again.
7 (Laughter.)
8 MEMBER BROWN: Exactly. Kati, thank you.
9 Oh, I didn't thank you all. You all did 10 a nice job of providing your side of the story and I 11 wanted to thank the Staff for their observations and 12 stuff today. I think a lot of information came out, 13 so very good.
14 (Whereupon, the above-entitled matter went 15 off the record at 12:59 p.m. and resumed at 1:16 p.m.)
16 CHAIRMAN RICCARDELLA: The meeting will 17 now come to order. We're going to review several 18 chapters of the NuScale DCA, and I'll turn the meeting 19 over to Subcommittee Chairman Mike Corradini.
20 MEMBER CORRADINI: Okay, thank you very 21 much for turning it over. We're going to start our 22 afternoon session, which will go for four plus hours, 23 if we can hold it to that. Which is my plan.
24 We've arranged this in a manner where 25 NuScale will start us off with a few items. But then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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210 1 move of their presentation will be in closed session 2 at the end, since we had asked them for certain things 3 from the Subcommittee.
4 I think most of the Committee was at the 5 Subcommittee meetings in mid-May. I think two or 6 three members weren't, so they'll kind of go along for 7 the ride.
8 So, Rebecca, are you going to lead us off?
9 MEMBER REMPE: Before you do that, Dr.
10 Corradini, I think you and I need to acknowledge that 11 because of some prior work we did that we have to 12 limit our participation regarding Section 19.2 in the 13 deliberations for this meeting, right?
14 MEMBER CORRADINI: Right. Rebecca, are 15 you going to start us off?
16 MS. NORRIS: Yes. I will be doing this 17 entire presentation.
18 MEMBER CORRADINI: Okay. Oh, I'm sorry.
19 And I was supposed to check to make sure your 20 colleagues at NuScale are on the line and the phone 21 line. So, is NuScale subject matter experts back in 22 Corvallis on the line?
23 PARTICIPANT: Yes, we are.
24 MEMBER CORRADINI: Okay, thank you very 25 much. I should have checked on that at the very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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211 1 beginning. Rebecca.
2 MS. NORRIS: Thank you. Good afternoon, 3 everyone, I am Rebecca Norris. I am a licensing 4 supervisor for this chapter, Chapter 19, Probabilistic 5 Risk Assessment and Severe Accident Evaluation.
6 So, the objective for this open 7 presentation, specifically, is not to be a technical 8 presentation. Hence why I do not have any of my 9 subject matter experts up here with me.
10 This is just a schedule of the technical 11 responses we have planned for all of the questions we 12 have collected from ACRS so far. That have been 13 submitted through the Staff or directly in the 14 meetings.
15 So, the three venues that we have to 16 answer questions are this afternoon in the closed 17 session, the June 18th through 20th Subcommittee, 18 which is Chapters 6 and 15 specifically, to answer 19 some of the questions that have come up.
20 MEMBER CORRADINI: 3, 6 and 15.
21 MS. NORRIS: 3, 6 and 15, yes. And then 22 the July 23rd through 25th visit to Corvallis for 23 some, I believe most of the ACRS members will be 24 going.
25 So, the topics we plan on covering, with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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212 1 regard to Chapter 19 and these venues are in the 2 afternoon. We're going to be covering the passive 3 safety system reliability evaluation.
4 And then June 18th through 20th we'll have 5 ECCS, valve operation internals. We have a specific 6 slide animation that was requested that we apparently 7 showed at a much earlier ACRS meeting. And we have 8 all that lined up.
9 Also, the Target Rock inspection of the 10 ECCS valves is going on this week. So hopefully that 11 week we'll have some insights from there. Just early 12 insights.
13 MEMBER CORRADINI: Remind me, Target Rock 14 is the location where the ECCS valves are being 15 manufactured?
16 MS. NORRIS: Yes. Yes, that's correct.
17 MEMBER CORRADINI: Or tested. Tested.
18 MS. NORRIS: Tested.
19 MEMBER CORRADINI: Okay, thank you.
20 MS. NORRIS: So, for the Corvallis visit 21 is actually when we have most of our PRA items lined 22 up to be spoken about.
23 So, first on the list we have the ECCS 24 valve design. Specifically, basically all the 25 proprietary material that we can easily show you in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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213 1 Corvallis. Detailed drawings, electrical drawings, 2 things like that.
3 We also, for PRA analysis, we have the 4 list of questions that are on the slide. We have a 5 more detailed list that was sent out through emails 6 with the ACRS staff members, Mike Snodderly and Steve 7 Pope on our end.
8 And so, if anybody has any more questions 9 or additions or clarifications to that, please let us 10 know either during the meeting today or you can email 11 through the normal channels with Mike Snodderly.
12 In addition to this, we got a couple of 13 days ago Member Rempe's questions. I think we had two 14 specifically.
15 They were with regard to multi-module 16 response with shared systems, faults basically. We 17 did send a response email with very, a very short 18 answer to that. I'm sure we'll be in some more 19 communications regarding that question.
20 If we don't, if we need to further answer 21 the question, we plan on doing it during the 23rd 22 through 25th site visit.
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214 1 answering that during the July site visit as well.
2 Oh, I think I actually got that backwards.
3 We sent an email regarding the sensor diversity 4 question, we haven't sent any information on the 5 multi-module response yet.
6 And that is actually all I have for this.
7 For this presentation. So, request if there are any 8 clarifications, questions, anything like that on the 9 schedule.
10 MEMBER CORRADINI: Members, any questions?
11 Hearing none, let's move on.
12 CHAIRMAN RICCARDELLA: But you'll be here 13 during all of the Staff discussions of the chapters 14 we're reviewing --
15 MS. NORRIS: Yes.
16 CHAIRMAN RICCARDELLA: -- at this meeting 17 and if some questions come up you can --
18 MS. NORRIS: Yes. So both everyone in 19 person and also on the phone. We'll have --
20 MEMBER CORRADINI: Yes, there's other in 21 the room --
22 CHAIRMAN RICCARDELLA: Good.
23 MEMBER CORRADINI: -- backing her up.
24 CHAIRMAN RICCARDELLA: Okay, very good.
25 MS. NORRIS: That is true.
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215 1 MEMBER CORRADINI: Okay, thank you, 2 Rebecca.
3 So, we'll begin first with Chapter 3.9.2 4 from the Staff. Members should have those handouts in 5 front of them.
6 I recognize some of the parties moving to 7 the front of the table.
8 MS. VERA: Okay, good afternoon everyone.
9 My name is Marieliz Vera and --
10 MEMBER CORRADINI: Do you have a green 11 light on? Nope.
12 MS. VERA: Good afternoon, everyone, I'm 13 Marieliz Vera. I'm the project manager for Chapter 3 14 of the NuScale DC application. Today we're going to 15 present the Section 3.9.2 dynamic testing and analysis 16 of system, structure and components.
17 The review team is Yuken Wong, Dr. Steve 18 Hambric and Dr. David Ma, that is in the audience, and 19 the project manager, Greg Cranston is the lead project 20 manager.
21 And I'm going to turn the presentation to 22 Yuken.
23 MR. WONG: The Staff reviewed Section 24 3.9.2 in accordance with the standard review plan and 25 Reg Guide 1.20. Which is the comprehensive vibration NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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216 1 assessment program for reactor internals.
2 We sent the review of two areas. The 3 first one is the dynamic system analysis of reactor 4 internals and the Service Level D conditions. Level 5 D is the fault condition involving the simultaneous 6 safe shut down earthquake and hybrid events.
7 The second area is the reactor internals 8 comprehensive vibration assessment program, or CVAP.
9 Next slide please. I will present the 10 four open items related to the NuScale power module 11 dynamic analysis under Service Level D conditions.
12 The NuScale power module, or NPM, was 13 analyzed for six months initially. However, these 14 ones did not consider the case of 130 percent nominal 15 NPM stiffness.
16 The Staff raised the concern that in 17 addition to shifting the NPM stiffness down 30 18 percent, the analysis should also consider shifting 19 the NPM stiffness up 30 percent in order to account 20 for the uncertainty in the NPM input and assumptions.
21 In response to the NRC concern, NuScale 22 performed 12 seismic runs, including a test with 130 23 percent nominal NPM stiffness. The results are 24 documented in Revision 2 of the seismic report and it 25 is currently under review.
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217 1 This figure shows the reflector blocks.
2 They are stacked and restrained horizontally, but not 3 vertically.
4 The lower core plate vertical in-structure 5 response spectra acceleration at the high frequency 6 end exceeds the gravity acceleration. As a result, 7 the reflector blocks may uplift during a seismic 8 event.
9 However, this uplift was not considered in 10 the original analysis. In response to NRC concern, 11 NuScale relies the ANSYS model to simulate the uplift 12 of the reflector blocks from the lower core plate.
13 The Staff reviewed the modeling methods 14 and results and found them acceptable. And this open 15 item is now resolved.
16 The next slide.
17 CHAIRMAN RICCARDELLA: When they did that 18 analysis, did it show any uplift? Did any of those 19 ANSYS elements open up?
20 MR. WONG: Yes. There is small uplift of 21 the reflector blocks. And then there are not enough 22 to close the gap between the reflectors and the upper 23 core plate.
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218 1 assembly analysis.
2 CHAIRMAN RICCARDELLA: Thank you.
3 MR. WONG: During refueling, NPM will be 4 placed in the reactor flange tube for disassembly.
5 NuScale updated the ANSYS model to simulate the uplift 6 of the NPM from the reactor flange tube during a 7 seismic event. The results are documented in Revision 8 2 of the NPM seismic report and it is currently in the 9 review.
10 Next one please. The last open item. The 11 Applicant provided the level D stress evaluation 12 results of reactor vessel internals and steam 13 generator components in a RAI response, however, there 14 is, the results are based on the original six seismic 15 runs.
16 NuScale will update our results based on 17 the new in-structure response spectras from the 12 18 seismic runs. The Staff will review the supplemental 19 response when it is available.
20 And now I'm going to turn over to Dr.
21 Hambric to discuss the CVAP.
22 DR. HAMBRIC: Hi, I'm Steve Hambric from 23 Penn State and we reviewed the usual flow induced 24 vibration phenomena that you would for a design 25 application.
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219 1 The good news is, there's a couple of 2 phenomena that traditionally have been issues for 3 reactors, are not for NuScale. And the first is 4 turbulence buffeting.
5 The reason that's not a big concern is 6 that flow rates are much, much lower than what you 7 would expect. Or what you would get in a typical 8 reactor due to the natural recirculation, the small 9 size. So there's not of focus been put on that.
10 Flutter and galloping, they just use good 11 design practices to make sure that any structure and 12 cross flow has plenty of margin against that sort of 13 thing.
14 There are some mechanisms that we found 15 low margins of safety. And that's what we're going to 16 focus our time on today.
17 The first is vortex shedding. So there's 18 cross flow again but over a body where vortices form.
19 And the frequency of those vortices could line up with 20 a structural resonance. They lock into each other and 21 bad things happen. A strong vibration, impact, high 22 stresses, things like that.
23 An even worse phenomena is fluid-elastic 24 instability. In this case it would be associated with 25 the steam generator, a raise of tubes where the lock-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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220 1 in continues into the different tubes, all combining 2 with each other and causing an even higher vibration 3 and contact. Again, things you don't want to happen 4 in a reactor.
5 CHAIRMAN RICCARDELLA: I would expect 6 those would be mitigated somewhat by the lower flower 7 as well, would they not?
8 DR. HAMBRIC: We'll talk about that.
9 CHAIRMAN RICCARDELLA: Okay.
10 DR. HAMBRIC: But the margin that they 11 currently have is on the low side.
12 CHAIRMAN RICCARDELLA: I apologize, I'm 13 the lead in this section but I was not able to be here 14 during Subcommittee meetings, so I might be asking 15 some questions that you have already asked.
16 DR. HAMBRIC: That's fine.
17 MEMBER CORRADINI: But he has all your 18 slides and he's studied them --
19 CHAIRMAN RICCARDELLA: Yes, I did.
20 MEMBER CORRADINI: -- extensively.
21 DR. HAMBRIC: So this is a test. That's 22 good. I think we've kept some of them as backups so 23 we should be able to --
24 CHAIRMAN RICCARDELLA: Yes, understand.
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221 1 significant resources in trying to retire this risk 2 that's associated with some testing. And we'll talk 3 about it in a few slides. But we will be going over 4 to witness part of it.
5 CHAIRMAN RICCARDELLA: The TR-3 testing.
6 MEMBER KIRCHNER: And, Mike, just a 7 procedural question. Can we get into detail on any of 8 these or is this being saved for the closed session?
9 MEMBER CORRADINI: They'll tell us when we 10 get into closed territory, but my answer is, most of 11 this I think is open. The slides that were discussed 12 in the main meeting were all open.
13 DR. HAMBRIC: Yes, I think, correct me if 14 I'm wrong, as long as we don't get into specific 15 numbers or design parameters or things like that, then 16 we should be okay. But I'm sure NuScale will chime in 17 if we're --
18 MEMBER CORRADINI: Yes, they'll stop us 19 when we stray.
20 DR. HAMBRIC: Yes.
21 MEMBER CORRADINI: Okay.
22 DR. HAMBRIC: NuScale also did a pretty 23 thorough assessment of the possibility of acoustic 24 resonance. This is flow instability over openings and 25 pipes locking into acoustic resonance.
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222 1 This is what caused all the trouble in the 2 Quad Cities plant and the steam dryer issues. So 3 there are a few locations that they want to keep an 4 eye on that they'll be doing some initial startup 5 testing addressed.
6 CHAIRMAN RICCARDELLA: And that's driven 7 by secondary flow which isn't that low, right?
8 DR. HAMBRIC: Right.
9 CHAIRMAN RICCARDELLA: Those concerns, 10 yes.
11 DR. HAMBRIC: Mainly the steam. And the 12 final mechanism is the leakage flow and stability.
13 Those are usually in trained objects inside passages.
14 We've had very narrow flow passages and so instability 15 is performed.
16 And with all of these, you have an 17 instability vibrating at a certain frequency coupling 18 to some sort of resonance, either acoustic or 19 structural. And if the frequencies align and the 20 stars align, then we can lock-in and bad things can 21 happen. So we'll go through each of those.
22 The open items that are in the SER are 23 associated with some concern that we have with the 24 analysis procedures NuScale has used and the 25 particular non-conservatism. And also, the testing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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223 1 for the plant. Or non-plant.
2 So, we got a slide here on analysis 3 concerns and another one on testing.
4 The analysis concerns we've kind of boiled 5 down into two main ones and then a secondary one. The 6 main one is, where they're coming up with their flow 7 velocity estimates. And they're structural resonance 8 questions.
9 So, to assess any lock-in problem we need 10 to know both how fast the flow is moving, and that 11 tells you what frequencies the flow instabilities are 12 oscillating at. And then how the structures are 13 vibrating, what frequencies they're resonating. And 14 we'll looking for alignment and some other things.
15 So, the flow modeling non-conservatisms we 16 found were associated with a rough CFV assessment that 17 they did. It does not include all the details of all 18 the components.
19 So for example, the steam generator's 20 model is sort of a big heat sink. There's really no 21 localized philosophies computed through the individual 22 tubes. And their assumption of some uniformed 23 velocity could very well be violated in certain 24 locations.
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224 1 tubing arrays will show you that the velocity is not 2 uniformed. There's some parts for the flow that was 3 faster. Those are the parts we care about. And some 4 are slower. That has not been assessed so far.
5 Structural modeling, they use finite 6 element analysis, which is fine, but a couple of 7 things that we're waiting for answers on is a mesh 8 resolution study to make sure that the meshes are 9 refined enough to give us accurate resonance 10 frequencies. Of course, meshes tend to give you high 11 frequencies, which was not conservative.
12 And then we've had a lot of discussion 13 about some of the boundary conditions that they've 14 assumed on some of their structures. And in 15 particular, some components we'll get into in a moment 16 where they assume they had pin supports.
17 Any time a tube goes through a hole, for 18 example, and there's actually a gap between the tube 19 and the hole. And so we're discussing that in some of 20 our open items.
21 Now, the final secondary comment was, so 22 far they have only assessed margin against these sorts 23 of lock-in phenomena. How much percent margin do they 24 have between, for example, a resonance frequency and 25 a full ex-citation frequency.
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225 1 But what you'll see in a minute, the 2 margins are actually kind of small. And when they get 3 small, we need to do more than that. We need to 4 actually do a force response analysis.
5 If those frequencies are close, you're 6 going to have a higher amplitude vibrant than you will 7 if there's just turbulent buffeting, for example.
8 MEMBER CORRADINI: So, I'm sorry. No, go 9 ahead.
10 MEMBER MARCH-LEUBA: No, I'm talking about 11 something else.
12 MEMBER CORRADINI: Oh. Your point is, is 13 if they start overlapping, you got to do more of a 14 non-linear analysis. If they're far apart you can get 15 away with --
16 DR. HAMBRIC: It's probably even linear.
17 But still, it's not doing anything right now.
18 MEMBER CORRADINI: Okay.
19 CHAIRMAN RICCARDELLA: -- response peak, 20 you're saying if they're not right on, if they're 21 just, if they're a little bit off that peak, you still 22 get some --
23 MEMBER CORRADINI: Right.
24 DR. HAMBRIC: Yes. It wouldn't 25 necessarily be a lock-in, but you're going to get a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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226 1 higher vibration than you would with just turbulent 2 buffeting. That has not been assessed so far.
3 MEMBER MARCH-LEUBA: And then the non-4 linear effects will align them.
5 DR. HAMBRIC: Yes. So I think the idea 6 is, they want to make sure there's margin so there are 7 no non-linear effects --
8 MEMBER MARCH-LEUBA: Yes.
9 DR. HAMBRIC: -- but even so, the linear 10 effects must be accounted for. And that's an open 11 item that we have.
12 CHAIRMAN RICCARDELLA: But the margins are 13 just based on frequency rations?
14 DR. HAMBRIC: Yes.
15 CHAIRMAN RICCARDELLA: Okay.
16 DR. HAMBRIC: Critical velocities, 17 critical frequencies, factors like that.
18 MEMBER MARCH-LEUBA: Because, NuScale, and 19 you haven't done the slides, NuScale has a specific 20 characteristic that you can only have flow if you have 21 nuclear power.
22 DR. HAMBRIC: Right.
23 MEMBER MARCH-LEUBA: So you can only test 24 if you get 100 percent power.
25 DR. HAMBRIC: Yes, exactly.
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227 1 MEMBER MARCH-LEUBA: How would they 2 identify that it's one of these things?
3 Because you cannot put sacrificial 4 instrumentation, like you do on other things because 5 it will stay in the primary --
6 DR. HAMBRIC: Right.
7 MEMBER MARCH-LEUBA: -- for a couple of 8 years. So, have they considered anything to detect in 9 case you were wrong?
10 DR. HAMBRIC: Yes. So we'll have some of 11 that.
12 MEMBER MARCH-LEUBA: Okay.
13 DR. HAMBRIC: You're exactly right.
14 MEMBER MARCH-LEUBA: Good to know.
15 DR. HAMBRIC: So in fact, the next slide 16 is testing concerns. One of the things that stuck us 17 when we first got the application is there is very 18 little benchmarking in testing.
19 Now, the reason for the reduced 20 benchmarking is, if you look at past applications, 21 applicants have spent a lot of time and money on 22 trying to sort out the strength of turbulent buffeting 23 flows, because the flows are so fast. The flows do 24 become important.
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228 1 really isn't necessary.
2 So now we're looking at just essentially 3 testing for these possible lock-in problems, which is 4 much trickier and they're really hard to benchmark.
5 The other thing, as you just mentioned, 6 Jose, is that it's a natural circulation plant and 7 there's really no way, before they load fuel, to get 8 hot flow going in prototypic flow conditions over 9 these components in a real reactor.
10 CHAIRMAN RICCARDELLA: You can do stuff 11 with electrical heating, can't you?
12 DR. HAMBRIC: They could but it would be 13 --
14 CHAIRMAN RICCARDELLA: Very expensive.
15 DR. HAMBRIC: -- expensive, difficult, 16 maybe not good enough.
17 CHAIRMAN RICCARDELLA: Yes.
18 MEMBER MARCH-LEUBA: 300 megawatt is a lot 19 of power.
20 MEMBER CORRADINI: I guess I want to make 21 sure I understand. You want to be at full power or 22 you can be at partial power and see some of these 23 things?
24 DR. HAMBRIC: No, no, you need to be, in 25 fact, probably beyond the full power.
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229 1 MEMBER CORRADINI: Okay. So you can't do 2 it at part --
3 CHAIRMAN RICCARDELLA: You can't get the 4 flow without the --
5 MEMBER CORRADINI: I understand that. I 6 understand that, but I'm asking --
7 CHAIRMAN RICCARDELLA: I'm sure you knew 8 it.
9 MEMBER CORRADINI: But I can't approach 10 any of these phenomena with what they're normal heat 11 up system is, which is the aux boiler coming up to 12 like 20 percent or something.
13 DR. HAMBRIC: Not in a test.
14 MEMBER CORRADINI: Okay, thank you.
15 DR. HAMBRIC: So, after a lot of 16 discussions, very helpfully discussions, we came up 17 with, NuScale came up with an approach that we think 18 we're happy with, but we still have some boxes to 19 check to make sure of that.
20 The initial startup test, let's do these 21 bullets in reverse order, is more focused on, what if 22 they're wrong. So, it's not trying to benchmark any 23 particular mechanism or measure anything in 24 particular, it's to see if something bad is happening 25 in spite of all of their best efforts, in spite of all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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230 1 our best efforts to ensure that nothing will.
2 So, we are still waiting to see their 3 instrumentation plan, but the idea is to put enough 4 instrumentation in the initial reactor, the prototype 5 reactor, so that if something happens they can 6 identify it, number one, and number two, localize it.
7 And then number three, presumably mitigate it.
8 So that is the goal. This is going to 9 require --
10 MEMBER MARCH-LEUBA: No, that 11 instrumentation is going to end up in the core as a 12 loose part.
13 DR. HAMBRIC: Well, that's if something 14 horrible happens, yes.
15 MEMBER MARCH-LEUBA: No, no. With all the 16 tubes failing, the instrumentation fails all the time.
17 DR. HAMBRIC: Oh sure.
18 MEMBER MARCH-LEUBA: And becomes a loose 19 part. Oops.
20 DR. HAMBRIC: Because that actually 21 probably should be something that we ask them in their 22 test plan is, what is your plan for making sure there 23 are no loose parts in your reactor in case something 24 does come loose.
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231 1 flow is so low that most of those parts will end up in 2 the bottom of the lower plenum.
3 DR. HAMBRIC: Okay. Well, that's --
4 MEMBER MARCH-LEUBA: And they won't be 5 carried.
6 DR. HAMBRIC: But still, that's a good 7 point. We should ask them.
8 MEMBER MARCH-LEUBA: Yes, we definitely 9 have to have a plan for when it breaks, what do you 10 do.
11 DR. HAMBRIC: Okay. Okay.
12 MEMBER MARCH-LEUBA: Not if it breaks but 13 when it breaks.
14 DR. HAMBRIC: So, that is still something 15 we have not reviewed yet. They have agreed to do this 16 instrumentation plan, they've agreed to do the initial 17 startup test, and we have not sign the final plan yet.
18 So that is pending review.
19 Accompanying that initial startup testing 20 are some focused tests, which we'll get into in a 21 moment, to really go after a couple of the key 22 mechanisms. One with the steam generator, and two 23 with the steam generator inlet flow restrictors. And 24 I'll talk about both of those.
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232 1 are the components with low margins of safety. These 2 are imagines drawn from NuScale documents.
3 The top one is obviously the helical coil 4 steam generator. A couple open items on that. And 5 they were concerned about both vortex shedding as well 6 as fluid-elastic instability.
7 So, the vortex shedding is restricted to 8 the very bottom tubes. And those are the tubes where 9 vortices can actually form. Anything upstream of 10 those tubes the vortices can't form because there's 11 another tube in the line. So you really have to have 12 an open space --
13 MEMBER MARCH-LEUBA: And this vortex is 14 performed on the primary, outside the tubes?
15 DR. HAMBRIC: Yes.
16 MEMBER MARCH-LEUBA: Or inside the tubes?
17 DR. HAMBRIC: Outside the tubes.
18 MEMBER MARCH-LEUBA: Okay.
19 DR. HAMBRIC: Yes. We do have some 20 questions about the insides of the tubes, but they're 21 not as important as these. But they are in the safety 22 evaluation report.
23 CHAIRMAN RICCARDELLA: So that's what's 24 separated by your red arrow?
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233 1 blue?
2 DR. HAMBRIC: No. That's, again, a 3 picture from the NuScale document. I just put the red 4 arrow in there to say that's the direction of flow.
5 CHAIRMAN RICCARDELLA: Oh.
6 DR. HAMBRIC: So the blue are actually 7 their supports. So they've got these long --
8 CHAIRMAN RICCARDELLA: Yes.
9 DR. HAMBRIC: -- pretty complicated 10 support structures with little clips that all of the 11 tubes kind of pop into.
12 CHAIRMAN RICCARDELLA: But you said that 13 the vortex shedding was restricted to certain areas, 14 could you kind of point to that on the --
15 DR. HAMBRIC: Actually, right where that 16 red arrow is. It's the very bottom two.
17 CHAIRMAN RICCARDELLA: All right.
18 DR. HAMBRIC: So if there's open water 19 downstream of the flow, then you can have vortex 20 shedding. So we compute --
21 MEMBER KIRCHNER: These margins are based 22 on your calculations or their calculations?
23 DR. HAMBRIC: These are NuScale reported 24 margins.
25 MEMBER KIRCHNER: Okay.
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234 1 DR. HAMBRIC: Our assessments of possible 2 non-conservatisms of flow velocities and boundary 3 conditions and damping take away those margins. And 4 that's what we're concerned about.
5 Now, NuScale will argue that they have put 6 lots of extra conservatism in their other parameters, 7 so that these margins, in their eyes, are 8 conservative.
9 MEMBER KIRCHNER: Thank you.
10 DR. HAMBRIC: But that's still a point of 11 debate between us. That's why we have open items and 12 we continue --
13 MEMBER KIRCHNER: And, again, be a little 14 precise here. When you say takes away the margin, 15 your calculations would indicate they have FEI or 16 vortex shedding?
17 DR. HAMBRIC: If we work with the numbers 18 they're giving us --
19 MEMBER KIRCHNER: Yes.
20 DR. HAMBRIC: -- and then go to the open 21 literature and check other people's thoughts about 22 what critical velocities are, what the velocity 23 distribution in the steam generator might be. Yes, 24 margin as well.
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235 1 on flow velocity or on frequency or --
2 DR. HAMBRIC: Margins against lock-in 3 between the flow phenomenon and the structural 4 resonance.
5 CHAIRMAN RICCARDELLA: Which, yes, which 6 means frequency differences?
7 DR. HAMBRIC: Yes. Essentially, yes.
8 MEMBER BALLINGER: If I look at ten 9 percent margin, I ask myself, what's the uncertainty 10 on the analysis.
11 DR. HAMBRIC: Yes, they in fact have been 12 working on deriving uncertainties in their measurement 13 inspection plan. But they would argue that the 14 uncertainty is being moved artificially close to the 15 margin because they've put so much conservatism in.
16 MEMBER BALLINGER: Okay.
17 DR. HAMBRIC: Yes.
18 MEMBER BALLINGER: So conservatism --
19 MR. GEIER: So you got bias and 20 conservatism and you've got uncertainty.
21 MEMBER BALLINGER: Okay. So it's really 22 not margin, you need to put more words in there that 23 it's estimated margin given uncertainty or something 24 like that.
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236 1 margins. One, which is based on their best 2 engineering estimate, and one which they say is worst 3 case.
4 MEMBER CORRADINI: Which is this, maybe 5 that's --
6 DR. HAMBRIC: This is their worst case.
7 MEMBER CORRADINI: Okay. That's what I 8 thought.
9 MEMBER BALLINGER: Is the best estimate 10 more proprietary?
11 DR. HAMBRIC: I'm not sure and I honestly 12 don't remember what the best estimate results are.
13 MR. WONG: I recall NuScale mentioning in 14 a subcommittee meeting here, that the latest update, 15 that has not been provided to the NRC shows, around 60 16 or 80 percent.
17 MEMBER BALLINGER: I think I remember --
18 DR. HAMBRIC: But we have no seen those 19 yet.
20 MEMBER MARCH-LEUBA: Didn't NuScale, I 21 know they have measured the pressure drops across the 22 simulator, and heat temperature coefficient, so they 23 have a vape. I mean, don't you have a actual heat 24 exchanger with pump somewhere?
25 DR. HAMBRIC: Sorry?
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237 1 MEMBER MARCH-LEUBA: Yes. Didn't you guys 2 test the heat exchangers on an outside loop to measure 3 pressure drops and heat temperature coefficients?
4 (Off microphone comments.)
5 MEMBER MARCH-LEUBA: Yes, but did you look 6 for --
7 DR. HAMBRIC: Yes.
8 MEMBER KIRCHNER: -- that loop is still 9 available?
10 MEMBER CORRADINI: Yes, you got to come to 11 the mic if you're going to answer him, otherwise we'll 12 just wait to hear from --
13 DR. HAMBRIC: Right. So, they've done 14 initial tests for those sorts of things, but the test 15 that they're going to do will address these concerns.
16 And that's what we've talked about.
17 MEMBER MARCH-LEUBA: What I don't 18 understand is they have a loop, a dedicated loop with 19 other reactor where they can pump flow through the 20 simulator.
21 DR. HAMBRIC: Oh, right. That gives them 22 their heat exchange coefficients and loss and --
23 MEMBER MARCH-LEUBA: But yes, it will also 24 give you all this vibration.
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238 1 it to do so. And if the supports --
2 MEMBER MARCH-LEUBA: That's what I was 3 asking, if it's still available.
4 DR. HAMBRIC: And if the supports are 5 prototypic --
6 MEMBER CORRADINI: I think you want to 7 hold off where he's going with this because I think 8 there's going --
9 DR. HAMBRIC: All right.
10 MEMBER CORRADINI: -- we're going to talk 11 about.
12 CHAIRMAN RICCARDELLA: At this relatively 13 early stage of design, aren't there things that could 14 be done to change natural frequencies if it turns out 15 to be a problem?
16 DR. HAMBRIC: Yes. And that's one of the 17 things that we're hopefully that the new test will 18 show us. That maybe those natural frequencies are 19 higher than are currently estimated.
20 CHAIRMAN RICCARDELLA: Yes. Yes. But I 21 mean, you could put in another support or something to 22 --
23 DR. HAMBRIC: And we'll talk about the 24 supports.
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239 1 right, good.
2 DR. HAMBRIC: Okay. So these margins are 3 older. We know that NuScale is working to improve 4 them but we don't have the final, latest numbers to 5 talk about.
6 But again, we'll talk about the testing 7 that they're going to do to hopefully retire these 8 risks to our satisfaction.
9 CHAIRMAN RICCARDELLA: Okay.
10 DR. HAMBRIC: In a couple slides. The 11 other components that are in cross flow are the 12 control rod drive shafts. There's two pictures that 13 were in the right there at the bottom. The CRDS's are 14 on the right.
15 And then the in-core instrument guide 16 tubes are on the left. And both of these are tube 17 arrays with pretty wide separation. There's no chance 18 of fluid-elastic instability of these.
19 But they all get threaded through these 20 holes and there's a support grids that you can see in 21 the pictures.
22 And the concern here is vortex shedding.
23 And the flow comes upward through the core. And then 24 at the very top it has to move radially outward and 25 then work its way down through the heat exchanger. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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240 1 it's up at that top part that the rods are in 2 crossflow.
3 And current analyses show a less than 25 4 percent margin, for both components, against vortex 5 shedding. And that is something we have open items 6 for.
7 MEMBER MARCH-LEUBA: Will this be worse, 8 sorry, go ahead.
9 MEMBER BLEY: No, go ahead.
10 MEMBER MARCH-LEUBA: Will this be worse 11 with liquid water or with the steam?
12 Because under so much conditions should 13 you uncover part of the steam generator or --
14 DR. HAMBRIC: It would be with the water.
15 MEMBER MARCH-LEUBA: Water makes it worse?
16 DR. HAMBRIC: Yes.
17 MEMBER MARCH-LEUBA: I would assume so but 18 --
19 DR. HAMBRIC: Yes, definitely water.
20 MEMBER BLEY: Now you said, if I 21 understood right, the vortex shedding is an issue at 22 the reactor coolant system outlet coming down?
23 DR. HAMBRIC: Well, it's right where those 24 red arrows are.
25 MEMBER BLEY: Oh, up at the top.
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241 1 DR. HAMBRIC: Yes. It's on the way to --
2 MEMBER BLEY: Where you have the 3 crossflow?
4 DR. HAMBRIC: Yes.
5 MEMBER BLEY: Okay. So up there you get 6 some real vibration problems if you have the --
7 DR. HAMBRIC: Flow comes up, it goes our 8 radially and then it goes back down again.
9 MEMBER BLEY: Okay. I was looking at the 10 wrong one. That makes sense.
11 DR. HAMBRIC: Yes, I think there's a black 12 arrow that they're, I pulled these from NuScale 13 drawings. That's probably calling something.
14 MEMBER MARCH-LEUBA: And while we're 15 bothering you, I mean, the inside of the tube you have 16 the boiling. When I boil water in my kitchen it goes 17 the whole thing, the whole pot moves.
18 (Laughter.)
19 DR. HAMBRIC: In the helical coil steam 20 generator tubing yes. Yes. That's actually another 21 open issue we have didn't make the cut for this 22 presentation. But they've done internal flow 23 measurements where we have seen some strong pulsations 24 that are --
25 MEMBER MARCH-LEUBA: But does that --
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242 1 CHAIRMAN RICCARDELLA: With boiling inside 2 the tubes.
3 MEMBER MARCH-LEUBA: -- give you the 4 proper frequencies?
5 DR. HAMBRIC: I have no idea. They're 6 getting back to us on that. There is a characteristic 7 frequency that shows up in the internal flow 8 pressures, and the question is out to them, what does 9 that mean in a structural response and is it 10 important.
11 Okay, next slide. All right, the last 12 component of a significant interest are the steam 13 generator flow restrictors. The bottom there's one of 14 them. And up on the top you can see the full array.
15 And that big structure, very carefully, 16 gets feed into all of the steam generator inlet tubes.
17 And what these restrictors are meant to do is prevent 18 something called a density wave oscillation mechanism 19 from occurring in the entire steam generator.
20 And this is a pretty unpleasant 21 instability. It happens at extremely low frequencies 22 but it's not something you want in the plant.
23 But putting these restrictors in 24 eliminates that problem. However, NuScale spent a 25 fair bit of effort making sure to introduce another NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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243 1 problem that's a leakage flow instability.
2 So if you look at that picture at the 3 bottom, imagine the flow migrating from the small 4 cross-sectional area part to the fatter cross-5 sectional area part.
6 MEMBER MARCH-LEUBA: And you can use the 7 mouse to point, it will help a lot.
8 DR. HAMBRIC: Oh, I'm sorry. Okay, so 9 imagine the flow getting squeezed through that 10 annulus. So there's a tube that goes, the steam 11 generator tube surrounds this.
12 And as it expands beyond it, you get 13 pulsations in the loading. And we need to make sure 14 that those pulsations, the frequencies of those 15 pulsations, don't correspond to the cantilever beam 16 mode of this entire structure. And lock-in and 17 amplify the pulsations and amplify the vibration and 18 cause problems.
19 MEMBER BLEY: And these are in every tube?
20 DR. HAMBRIC: Every tube.
21 MEMBER KIRCHNER: Every tube.
22 DR. HAMBRIC: Every single one.
23 MEMBER BLEY: Is this done elsewhere?
24 I've never seen anything --
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244 1 as prototypical conditions.
2 DR. HAMBRIC: The design that is, was 3 chosen, was selected from several that were tested in 4 somewhat prototypic conditions. So they built a 5 fixture and then stuck a whole bunch of design concept 6 into the fixture, ran extremely high flow through 7 them, much higher than they'd expect to see in real 8 operations, and picked the one that showed almost no 9 vibration whatsoever.
10 Tweaked the design a little bit, and 11 because of that tweak they're going to go and do a 12 final test of just this design. In the same sort of 13 a fixture but with a lot more instrumentation, a lot 14 more care.
15 And the test plan and the procedures and 16 instrumentation have all been submitted as part of 17 their measurement inspection program. We've evaluated 18 it. It seems sounds to us. We're doing our final 19 checks now but this looks to us like they're on a 20 pretty good path to success.
21 MEMBER BLEY: So, when you have one of 22 these in a tube, how is the widest diameter of this 23 restrictor compare with the inside diameter of the 24 tube? How much space was the clearance?
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245 1 forgotten that. It's tight. Can someone from NuScale 2 address that?
3 MEMBER CORRADINI: Look, before we start 4 banting numbers --
5 DR. HAMBRIC: Oh, that's true, thank you.
6 Thank you.
7 MEMBER KIRCHNER: It's very tight.
8 DR. HAMBRIC: But in their suite of 9 components that they've evaluated, they evaluated a 10 parametric study like that. They vary gap width, they 11 vary number restrictors, light between restrictors.
12 They did a pretty thorough job assessing those issues.
13 And I'm sure that flow throughput was 14 important to them. They didn't want to over restrict 15 the flow otherwise they wouldn't get the power out of 16 the reactor.
17 MEMBER BLEY: You said these kind of 18 restrictors are used in other steam generators?
19 DR. HAMBRIC: Well in other, yes, sure.
20 MEMBER BLEY: Like conventional steam 21 plants?
22 DR. HAMBRIC: Yes, flow restrictors are a 23 common device to --
24 MEMBER BLEY: I think an orifice --
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246 1 about density, the other ones we don't, but density we 2 do. And they typically use orifice in the reactors.
3 DR. HAMBRIC: Yes, the orifices were, 4 anything at all to add resistance.
5 Okay, so the next test is the more 6 involved one. And this is what is still under Staff 7 review and will be for a while.
8 MEMBER CORRADINI: This test, just for 9 clarification, this test program you're going to be 10 speaking about is, from a planning standpoint is, 11 after the DCA will be evaluated and passed, this will 12 be a construction item?
13 DR. HAMBRIC: Well, part of it.
14 MEMBER CORRADINI: How does this fit in, 15 in terms of where it is in time lines?
16 DR. HAMBRIC: So, half of it we will have 17 in time, we hope, for the final SER. The other half 18 we won't. So I'll get to it on the next slide.
19 MEMBER CORRADINI: Okay, sorry. Thank 20 you.
21 DR. HAMBRIC: So, earlier tests of steam 22 generator mockups have been mainly thermal hydraulic 23 oriented with minimal instrumentation. And also the 24 supports of the tubes were not prototypical.
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247 1 vibration specific test. Where they've spent a lot of 2 effort to making sure that the supports, these clips 3 that you can see in their designs are prototypic, that 4 the clearances are prototypic.
5 They're putting in five rows of tubes, 6 which should be enough to assess fluid-elastic 7 instability. And the instrumentation is significant.
8 With the steam gauges accelerometers, they will be 9 driving these structures in multiple ways.
10 And Part A of the test is structural 11 dynamic. Where are the resonance frequencies, what 12 are the clip boundary conditions revealing because 13 they're current assessments assume that the clip 14 boundary conditions are quite conservative, pinned 15 almost.
16 There is some sliding allowed but they're 17 essentially viewing them as a point connection that 18 restricts lateral motion.
19 In reality, each tube goes to a clip on 20 the bottom and two clips on the top. So it's more 21 like, almost clamped. If it's clamped, all those 22 resonance frequencies go up and all of a sudden, we've 23 got a lot more margin than we thought we did.
24 So that's a big output from this test.
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248 1 clearances, right?
2 DR. HAMBRIC: There is clearances. So one 3 of the big outstanding items we have with them is 4 they're relying on thermal expansion to take away 5 those clearances.
6 And we're waiting for calculations from 7 them to prove to us that that is true. There is 8 enough thermal expansion to really lock those tubes 9 into those clips and make that boundary condition 10 whole.
11 Now, they can't do that in this test. So 12 they've come up with sort of a pre-loading gadget, 13 which we haven't seen yet, we're hopeful we will in a 14 couple of weeks, where they will press the tubes 15 against the supports where they force the similar two 16 that they expect to get out of thermal expansion.
17 It sounds great, but we're waiting for the 18 calculations to prove that that is in fact real.
19 Because that's pending.
20 That's number one. What are the resonant 21 frequencies and are they higher than expected and can 22 they then take credit for that in their analysis of a 23 real steam generator.
24 CHAIRMAN RICCARDELLA: What about fretting 25 and wear at those contact points?
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249 1 DR. HAMBRIC: That's part of the 2 expansion.
3 CHAIRMAN RICCARDELLA: Yes, I know.
4 DR. HAMBRIC: Is it tight or not?
5 CHAIRMAN RICCARDELLA: Well -- you're 6 saying if they get it tight enough that there won't be 7 any fretting?
8 DR. HAMBRIC: Couldn't be. And if force 9 response is low should we see any vibration. There's 10 a lot of open questions to make us believe that that's 11 going to be the case. If it's tight enough there 12 should not be any motion in the frame.
13 MEMBER CORRADINI: But this test is 14 crucial to prove out things empirically. That's the 15 way I hear it.
16 DR. HAMBRIC: Yes. Now, the other key 17 mechanism is damping. So if you look in the backup 18 slides, they're assuming one and a half percent 19 damping for the helical coil steam generator.
20 In Reg Guide 1.20 we allow one percent.
21 If you go above that, you need proof. And we have not 22 had that yet. They're hoping to prove that here.
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250 1 then we've got low margin and we need to make sure 2 that works.
3 CHAIRMAN RICCARDELLA: Will this test 4 address both vortex shedding and fluid-elastic 5 instability?
6 DR. HAMBRIC: Soon. So, the structure 7 test gets us part way there.
8 So the next test, which will not be done 9 any time soon, and NuScale has not told us when it's 10 going to happen, will be to turn the flow on and 11 assess whether vortex shedding is happening or fluid-12 elastic instability is happening.
13 Now, the great thing about this --
14 CHAIRMAN RICCARDELLA: What are they going 15 to test without turning the flow on?
16 DR. HAMBRIC: This is all just structural 17 dynamic tests. Where are the resonance frequencies --
18 CHAIRMAN RICCARDELLA: Ah.
19 DR. HAMBRIC: -- what are the boundary 20 conditions.
21 CHAIRMAN RICCARDELLA: Okay. Okay.
22 DR. HAMBRIC: Are the boundary conditions 23 stiffer than they are currently assumed.
24 CHAIRMAN RICCARDELLA: Yes. Yes.
25 DR. HAMBRIC: If so, that's a good thing.
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251 1 CHAIRMAN RICCARDELLA: So they're just 2 going to shake it on a shaker table?
3 DR. HAMBRIC: Or with hammers.
4 (Laughter.)
5 DR. HAMBRIC: Well, that's a common 6 dynamic testing method.
7 CHAIRMAN RICCARDELLA: An instrumented 8 hammer.
9 MEMBER CORRADINI: Doctor, if they can do 10 it to you, they can do it to the steam generator.
11 DR. HAMBRIC: They can. That's about, 12 yes, it's pretty analogous. I mean, trying to get a 13 dynamic response out of a hammer.
14 MEMBER SKILLMAN: Steve, for the situation 15 where they are counting on expansion of the tube, to 16 back the tube into the clip, can the aggregate force 17 of all of the tubes backing into the clip deform the 18 support?
19 DR. HAMBRIC: I don't know.
20 MEMBER SKILLMAN: Will they be looking at 21 that?
22 DR. HAMBRIC: We can ask.
23 MEMBER SKILLMAN: Well, find out.
24 DR. HAMBRIC: Okay.
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252 1 thermal expansion you're talking about just expansion 2 of the dilation of the tube or is it the whole helix 3 expanding?
4 DR. HAMBRIC: Well the tube will expand, 5 the supports will expand too.
6 CHAIRMAN RICCARDELLA: Yes.
7 DR. HAMBRIC: The metal, the clips. And 8 then you got the aggregate. And we haven't seen a 9 calculation so we don't know how much detail to put 10 into it. We've done a localized calculation of the 11 entire array. It's TBD. We're waiting to hear back.
12 MEMBER MARCH-LEUBA: The one normal 13 operating conditions, there's a density of 63 percent 14 of normal water. For dampening, that would make a big 15 difference, won't it?
16 DR. HAMBRIC: Very big difference, yes.
17 MEMBER MARCH-LEUBA: So, do you have any 18 plans, they have any plans for this testing, are they 19 going to use a surrogate fluid or --
20 DR. HAMBRIC: Oh, the fluid dampening.
21 Yes.
22 MEMBER MARCH-LEUBA: The dampening will be 23 caused by motion in the water. And if your water 24 weighs 60 percent of normal, it will be different.
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253 1 dampening you get, but at they are, at the moment, not 2 counting on that. They're assuming that the supports 3 --
4 MEMBER MARCH-LEUBA: I guess you could 5 scale it.
6 DR. HAMBRIC: The frictional motion 7 between the supports and the tubing, they are similar 8 to this dampening. But if it's locked in because of 9 thermal expansion, maybe that goes away.
10 MEMBER MARCH-LEUBA: Yes.
11 DR. HAMBRIC: These are all questions that 12 we're trying to answer.
13 CHAIRMAN RICCARDELLA: Yes.
14 DR. HAMBRIC: And important ones too. So 15 that's boundary conditions and dampening that we'll be 16 able to assess for the final safety evaluation report.
17 CHAIRMAN RICCARDELLA: Will there be water 18 inside the tubes when you do this?
19 DR. HAMBRIC: No. The reason for that is 20 because they're instrumenting them and they can't get 21 the wires out unless they got the hollow tubes --
22 MEMBER MARCH-LEUBA: Will that not affect 23 your frequency? The mass of the tube?
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254 1 mass of the fluid isn't enough if it's post --
2 CHAIRMAN RICCARDELLA: Square root of K 3 over M, something like that, right?
4 (Laughter.)
5 DR. HAMBRIC: So, I think we understand 6 how to estimate the effects of internal water and 7 external water. Strong certainty.
8 So, getting back to the flow tests. The 9 nice thing about this facility that makes it actually 10 better than the real thing, is that they can run the 11 flow much, much higher than prototypic.
12 And the reason that's a good thing, is 13 that they can tell you, here is the threshold, here is 14 when vortex shedding will happen, here is when fluid-15 elastic instability happen. That means we have X 16 percent margin.
17 Now, there is some extra steps they have 18 to take to account for uncertainties and any biases 19 between these tests and the real thing, but still, 20 that would be a huge number to know.
21 The sad thing is, that is not going to 22 happen before the final SER. So really all we can do 23 at this point is to ensure those flow test procedures 24 are rigorous, that they've got contingency planning in 25 case something happens they can identify it, hope to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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255 1 resolve it by some sort of design.
2 MEMBER CORRADINI: Does that become a COL 3 item though for the first plant?
4 That's what I want to understand. Can the 5 Staff help me there?
6 MR. WONG: We are concerting the options.
7 One of the options is to have an ITAAC for the 8 completion of the steam generator flow test. Same for 9 the steam generator in that final design.
10 MEMBER CORRADINI: The restrictors.
11 CHAIRMAN RICCARDELLA: Yes.
12 MEMBER CORRADINI: Okay, thank you.
13 CHAIRMAN RICCARDELLA: An ITAAC is better 14 than a COL.
15 MEMBER KIRCHNER: Is it possible that, I'm 16 just looking at this nice picture you have here, that 17 the coldest point in the system is going to be the 18 feedwater coming in there right at the tube sheets.
19 Could a cold spot like that cause striking?
20 Now, granted coming out of the core you've 21 got crossflow and steam generator, so they should have 22 a fairly uniform distribution coming up the riser and 23 turning over and then coming back down. But could 24 that induce a effect of stripping?
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256 1 problem number is big enough. Or small enough. But 2 it's a really, really, really, water is a terrible 3 thermal conducting fluid compared to what you think 4 of, of stripping, so I can't imagine it would be a big 5 deal.
6 DR. HAMBRIC: Yes, I don't understand the 7 term.
8 MEMBER CORRADINI: Stripping means that 9 you're going to get a fluctuation in flow with an 10 appropriate flux --
11 MEMBER KIRCHNER: And hot and cold spots.
12 MEMBER CORRADINI: -- a corresponding 13 fluctuation in temperature and you get a hold and cold 14 flipping across the structural middle of that.
15 MEMBER KIRCHNER: Or just preferential 16 higher velocity right there at the tube sheet.
17 CHAIRMAN RICCARDELLA: Are you talking 18 stripping inside the tubes or outside?
19 MEMBER KIRCHNER: Well, outside --
20 CHAIRMAN RICCARDELLA: In the primary 21 flow.
22 MEMBER KIRCHNER: -- and the primary flow 23 being impacted. Changing the buoyancy. Being colder 24 at the tube sheet there, dropping the water down 25 preferentially and picking up the --
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257 1 MEMBER MARCH-LEUBA: The coldest tube 2 where we feed water, the water is getting out. So if 3 you get any value it would be getting out of the 4 tubes, not into the tubes.
5 MEMBER KIRCHNER: No, no, I'm talking 6 about the primary flow over the tube bank.
7 MEMBER CORRADINI: I think that's what 8 Jose is saying.
9 MEMBER MARCH-LEUBA: Yes, but seawater 10 goes on the bottom.
11 MEMBER KIRCHNER: I know.
12 MEMBER MARCH-LEUBA: So when it gets there 13 it's getting out.
14 MEMBER KIRCHNER: Right.
15 MEMBER MARCH-LEUBA: I don't know anything 16 about it.
17 MEMBER KIRCHNER: But then they pick up 18 the velocity there. Preferentially.
19 DR. HAMBRIC: Yes, that's probably a 20 question for a different group.
21 MEMBER CORRADINI: We'll ask NuScale in 22 the closed session.
23 DR. HAMBRIC: Okay.
24 MEMBER CORRADINI: I know what we want.
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258 1 flow induced vibration questions?
2 Okay, there's a lot riding on this test, 3 it's quite important. Okay.
4 Here again are the steam generator and the 5 flow restrictors. And I've already discussed this.
6 The procedures that they have presented to us so far.
7 So reasonable.
8 And we have pretty high confidence that 9 they'll be able to confirm that their design is not a 10 flow induced vibration issue. But as Yuken said, 11 those results will be available after design 12 certification. Okay.
13 Initial startup testing will focus on two 14 things. One, in the decay heat removal system there 15 is some steam flow that is passing over openings. And 16 you can see them in the picture there on the right.
17 And it's possible that there could be some 18 lock-in between the flow and the open. But then 19 NuScale has done things to try to minimize the 20 strength of any sort of lock-in, that would curve the 21 opening, that's the design practice.
22 But during initial startup testing there 23 will be instrumentation and they will carefully 24 increase the flow and look for possible lock-in 25 points. And if they occur, report them and presumably NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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259 1 come up with a mitigation strategy. There are ways to 2 take care of it if it doesn't work.
3 MEMBER MARCH-LEUBA: When you say startup 4 testing, you say nuclear in the real reactor?
5 DR. HAMBRIC: Real reactor. This is all 6 initial startup, yes.
7 MEMBER MARCH-LEUBA: Because when you were 8 talking before it was a pump.
9 DR. HAMBRIC: The previous slide is all 10 preliminary, yes.
11 MEMBER MARCH-LEUBA: But this, now, 12 fortunately all this is in, when the pool is outside 13 the vessel. So, if something breaks --
14 DR. HAMBRIC: That is, yes.
15 MEMBER MARCH-LEUBA: -- not a bad problem.
16 DR. HAMBRIC: Yes. The next bullet is 17 internal.
18 CHAIRMAN RICCARDELLA: There's a lot of 19 tests, there's a lot of test data available on that.
20 I mean, design the size of a cavity, right?
21 DR. HAMBRIC: Oh, yes.
22 CHAIRMAN RICCARDELLA: It's like blowing 23 across the top of a bottle basically.
24 DR. HAMBRIC: That's correct. So what 25 they have is margin against the primary flow and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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260 1 stability blocking into an acoustic resonance.
2 Where they don't have margin is at some 3 speeds, the secondary flow and stability. It's a full 4 wave length the opening it could lock-in.
5 CHAIRMAN RICCARDELLA: Yes.
6 DR. HAMBRIC: It's not as strong, but it 7 can be stronger than you think. And we've got plenty 8 of evidence to stabilize.
9 CHAIRMAN RICCARDELLA: But that's under 10 normal operation, not under DHRS operation, right?
11 DR. HAMBRIC: Yes.
12 CHAIRMAN RICCARDELLA: The concern --
13 DR. HAMBRIC: Well, we're looking at all 14 industry --
15 MEMBER CORRADINI: I think the way 16 Professor Hambric is asking this is, these are closed 17 ends that they've got to survive with as it's 18 whistling by --
19 CHAIRMAN RICCARDELLA: Yes.
20 MEMBER CORRADINI: -- under full power 21 conditions, right? Because --
22 DR. HAMBRIC: Well, they're going to check 23 all power conditions.
24 MEMBER CORRADINI: But you would expect it 25 at full power conditions, will you?
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261 1 CHAIRMAN RICCARDELLA: You wouldn't expect 2 it when you opened the DHRS valves and you run on 3 that.
4 DR. HAMBRIC: Yes.
5 CHAIRMAN RICCARDELLA: Run in that mode, 6 right?
7 DR. HAMBRIC: Maybe.
8 MEMBER MARCH-LEUBA: But the flow would be 9 going in --
10 DR. HAMBRIC: Oh, I'm sorry, yes. Yes.
11 CHAIRMAN RICCARDELLA: Yes. I mean --
12 DR. HAMBRIC: But, I mean, these are 13 variable power reactors, right --
14 CHAIRMAN RICCARDELLA: Yes.
15 DR. HAMBRIC: -- so they're not always 16 going to be sitting there at full power.
17 CHAIRMAN RICCARDELLA: Yes.
18 DR. HAMBRIC: So, I imagine the reason 19 they've got a whole bunch of these modules, and 20 NuScale, jump in if I'm wrong, is so they can deliver 21 a certain amount of power when it's asked for. To do 22 so efficiently.
23 So they are going to be operating at 24 different speeds, and they have to make sure that 25 there aren't certain speeds where acoustic resonance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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262 1 occurs. If it does, they'll probably try to avoid 2 them. That might be a simple mitigation strategy is, 3 don't operate at that speed.
4 MEMBER MARCH-LEUBA: Going back to the 5 testing, you can do this out of pile? I mean, this is 6 a cheap test compared to the other one.
7 DR. HAMBRIC: They could. But this is the 8 route they've elected to go and as long as we can 9 assure that their procedure and their contingency 10 planning is solid and they want to operate like that, 11 then --
12 MEMBER MARCH-LEUBA: They have confidence 13 in their design, this is perfectly acceptable.
14 DR. HAMBRIC: And then finally, we 15 mentioned this before, but instrumentation, accept for 16 acoustic resonance, is intended primarily just to find 17 the unexpected. If something bad is happening, in 18 spite of their best planning is happening, the 19 instrumentation should be sufficient to identify it 20 and hopefully localize it.
21 So they know a component is having 22 problems, then they can go in and mitigate it. And 23 this is obviously in their best interest too. They're 24 going to want this happening in their plant.
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263 1 instrumentation, they're claimed test procedures, 2 they're mitigation strategies and make sure it's as 3 solid as possible before they get approved. Okay.
4 And I think that's it. Just a summary of 5 open items.
6 MEMBER CORRADINI: Questions from the 7 Committee before we move on to Chapter 14? Okay, 8 we're moving on.
9 Tanny, are you the next victim?
10 MR. SANTOS: Yes. This is the Staff's 11 presentation on SER Chapter 14, the initial test 12 program ITAAC.
13 Next slide please. So my name is Tanny 14 Santos, I am the Chapter 14 project manager. Listed 15 on this slide are all of the technical reviewers that 16 participated in review of Chapter 14.
17 Fortunately, there is quite a lot of 18 people involved because of the scope of the review, 19 the information in this chapter. It includes staff 20 from both NRR, NRO and NSIR.
21 Next slide please. The outline of the 22 Staff's presentation for 14 is in two parts. The 23 first part is on the initial test program, SER Section 24 14.2, and that would be presented by Taylor Lamb.
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264 1 on Section 14.3 on the ITAAC meeting. So with that, 2 I'll just turn it over to Taylor for this portion.
3 MS. LAMB: Hello, my name is Taylor Lamb.
4 I'm with the quality vendor inspector branch. I am 5 the lead technical reviewer for the initial test 6 program, Section 14.2.
7 But I'll reiterate what Tanny said in that 8 several other system specific reviewers were involved 9 with this review.
10 So, our review objective was to look at 11 Section 14.2 for completeness and suitability for 12 development of an ITP by a COL applicant. We utilized 13 DSRS Section 14.2 in Reg Guide 1.68.
14 So, 5279A28 regarding COL applications, 15 specifically requires plants for pre-operational and 16 startup testing. However, there is no requirement for 17 a DC applicant to provide an ITP submitted under 10 18 CFR Part 52 Subpart b.
19 But as stated, we review them for 20 completeness and suitability for a COL applicant to be 21 able to develop an ITP. We reviewed this against DSRS 22 Section 14.2, which was guidance that was developed in 23 accordance with SECY-11-0024.
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265 1 certification stage where our ITP review focused on 2 providing assurance that the risk significant SEC 3 functions are tested and the test abstract adequately 4 addresses design functionality, rather than a detailed 5 review including the acceptance criteria for instance.
6 Next slide please. The Staff, to perform 7 its review, the Staff utilized table 17.4-1, the 8 design reliability assurance program, SSC functions, 9 categorizations and categorization basis in the DCA to 10 determine the set of test abstracts that we would 11 review using a risk-informed approach and for 12 efficiency.
13 We sent those items to NuScale, NuScale 14 came back and requested a larger scope of review. So 15 with that, NRC approved only those test abstracts 16 listed in Table 14.2-1 of the SER. And then Table 17 14.2-2 of the SER contains a list of test abstracts 18 that are not, will not be approved in the design 19 certification stage.
20 Those test abstracts specifically must be 21 addressed by a COL applicant. And if the design 22 certification is approved, the Staff would recommend 23 that the certification will include clarifying 24 language that these abstracts are outside the scope of 25 the certified design.
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266 1 Next slide please.
2 CHAIRMAN RICCARDELLA: Does that mean 3 they'll all have ITAACs?
4 Does that mean they'll have ITAACs on each 5 one of those items?
6 MS. LAMB: No, not necessarily. And Kerri 7 Kavanagh, who is in the corner, she might want to 8 speak up on some of these items as well.
9 MS. KAVANAGH: Hi, this is Kerri Kavanagh, 10 the chief of quality assurance vendor inspection 11 branch.
12 As Taylor mentioned, ITP is not required 13 to be reviewed under a design certification, however, 14 NuScale did ask for us to review a certain portion, 15 which we did. For those portions of test abstracts 16 that we did not review, the COL applicant will have to 17 have them review as part of that review. It's not an 18 ITAAC.
19 MEMBER CORRADINI: But it will be part of 20 their COL.
21 MS. KAVANAGH: Application, absolutely.
22 MEMBER CORRADINI: Application, excuse me.
23 MS. KAVANAGH: Yes.
24 CHAIRMAN RICCARDELLA: And identified in 25 the DCA as a COL item?
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267 1 MS. KAVANAGH: Not necessarily. It's 2 going to be, it's a requirement in 52.79 for the COL 3 applicant to provide an ITP. So for those items that 4 are not covered in the certified design, COL applicant 5 will be responsible for providing it.
6 MS. LAMB: There is one test abstract that 7 will remain open, 14.2-47, the emergency core cooling 8 system test Number 47, in accordance with open item 9 3.9.6-1. So, until that is resolved, test number 47 10 will remain open.
11 We have one confirmatory item, 14.2-1.
12 Until we receive a response from, to the Staff's 13 review of the test abstracts in Table 14.2-1 of the 14 SER, when we performed our review, we looked at the 15 proposed markups. So once NuScale submits their 16 future revision of the DCA, we anticipate that we 17 would be able to close out the confirmatory item.
18 With this said, the Staff concludes using 19 the information presented in the DCA. And pending the 20 confirmation of the confirmatory item and closure of 21 the open item, that the Applicant has demonstrated 22 compliance with the NRC regulations and guidance.
23 MR. SANTOS: Anything else on 14.2? Next 24 slide please.
25 Okay. So moving on to 14.3, ITAAC. So in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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268 1 this section of the SER the Staff reviewed all the 2 Tier 1 information in NuScale's application. This 3 includes site parameters, interface requirements and 4 of course of the ITAAC tables.
5 So the regulatory finding that the Staff 6 in making in 14.3 is with regard to 52.47(b)(1). That 7 is the requirement that a design certification 8 contained the ITAAC that are necessary and sufficient 9 to provide reasonable assurance that a plant that 10 incorporates the design certification has been 11 constructed and will operate in accordance with the 12 certification of the NRC's regulations.
13 Now, to make this finding, Staff had 14 several guidance documents. One of course is the 15 standard review plan.
16 Another is a set of draft standardized 17 ITAAC that the Staff provided NuScale for use in 18 design certification application back in 2016. And 19 many of the ITAAC NuScale submitted thus conformed 20 with the standardized ITAAC.
21 The third item I'd like to list here is 22 new, so I'd like to spend some time on it and discuss 23 it. It's SECY-19-0034.
24 And this SECY describes some revised 25 principles for reviewing Tier 1 information. So many NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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269 1 of the principles described in this SECY is similar to 2 what's in the SRP right now, but it does highlight 3 three new principles which I've listed here in the 4 slide.
5 The first is that Tier 1 information 6 should be at a qualitative and functional level of 7 detail. Tier 1 information should also not include 8 the level of detail that would require NRC approval 9 for a departure that is of minimal safety 10 significance. And lastly, then use a numerical values 11 in Tier 1 should be minimized.
12 So these three new principles are trying 13 to emphasize the importance of avoiding any 14 unnecessary detail in Tier 1 information or 15 unnecessary means requiring NRC approval for a 16 departure that is of minimal safety significance.
17 Now, as I said, this SECY was recently 18 issued. It was issued back in April. So the Staff 19 has not had an opportunity to apply all of these new 20 principles to all of the application for NuScale.
21 But there is an attachment to the SECY 22 that provides as an example how these new principles 23 could be applied to the structural review of the 24 NuScale Tier 1 application. So in that area, these 25 principles have been applied in the SECY.
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270 1 And next slide please. So the bulk of 2 14.3 just documents the Staff's review of the ITAAC or 3 points to another SER section or chapter that contains 4 the evaluation of the ITAAC.
5 Several of these sections do not contain 6 any open items, so I was not going to focus any of the 7 presentation on these sections. The remainder of the 8 Staff's presentation will focus on the open items and 9 other sections.
10 Next slide please. Okay, so 14.3.1, 11 selection criteria. Tier 2, Section 14.3.2 of 12 NuScale's application describes their approach for 13 identifying what information in Tier 2 rises to the 14 level of being included for Tier 1 information.
15 They call this the first principles 16 approach. And it's similar to NEI 15-02 and a NEI 17 White Paper that the Staff has reviewed and provided 18 comments on.
19 But since the Staff has not endorsed 20 either of these NEI documents, the Staff has excluded 21 from its review this first principles approach for 22 identifying what should be in Tier 1.
23 So, in the SER, the Staff is not taking a 24 position on the first principles approach. And the 25 implication for that is, if and when this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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271 1 certification were to go to rulemaking, Tier 2 Section 2 14.3.2 would not be incorporated by reference into the 3 design certification rule.
4 MEMBER CORRADINI: I remember we discussed 5 this, but I'm still struggling to understand by not 6 taking a position, does that mean any other than 7 you're tacit approving?
8 MR. SANTOS: No. I think if we were to 9 say nothing, I think it could be interpreted as tacit 10 approval. By Staff explicitly saying in the SER we 11 are not taking the position and we will exclude it 12 from the incorporation by reference to the rule, I 13 think it does not need to word not approving the 14 approach.
15 But I think the implications --
16 MEMBER CORRADINI: But you're not 17 disapproving it either.
18 MR. SANTOS: Right. Right, we're not 19 approving or disapproving.
20 MEMBER CORRADINI: So it could be good, 21 but other good ways, is that what you're trying to say 22 to me?
23 MR. SANTOS: Say that again?
24 MEMBER CORRADINI: That it's okay but 25 there might be other okay ways?
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272 1 MR. SANTOS: I think we're saying we agree 2 with the conclusions of this approach to identify.
3 Because basically what you have is a body of 4 information that's Tier 2 that the Staff is reviewing 5 and approving --
6 MEMBER CORRADINI: Right.
7 MR. SANTOS: -- and a body of information 8 is Tier 1, that's reviewed, approved and will be 9 certified. It's just the approach on how to identify 10 what from Tier 2 goes to Tier 1 that the Staff is not 11 taking a position on.
12 MEMBER CORRADINI: So you're okay with the 13 result, you're not okay with the process?
14 MR. SANTOS: Yes. We're reviewing the 15 results but we're not taking position on the process.
16 MEMBER BLEY: As a process for other 17 people to use.
18 MR. SANTOS: Right. For example, if NEI 19 were to come in later with a proposal to, for NRC 20 endorsement, we would engage with them and maybe 21 endorse it that way. But as of this point, since the 22 NRC has not endorsed the NEI approach generically, 23 we're not taking the position on the NuScale --
24 MEMBER CORRADINI: Okay, okay. Okay, got 25 it.
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273 1 MR. SANTOS: Next slide. Okay, so in 2 14.3.1 there are a couple of open items. One is 3 actually an item from Chapter 17. It has to do with 4 the design reliability assurance program. NuScale did 5 not provide an ITAAC for the D-RAP.
6 And in SECY-18-0093, the Staff is 7 recommending to the Commission that the use of ITAAC 8 to verify D-RAP no longer be used. But we are still 9 waiting a Commission decision on this SECY, so once we 10 hear from that we'll be able to close this open item.
11 If the Commission agrees with the Staff 12 recommendation it's closed, but if the Commission 13 disagrees, then we would need to request that NuScale 14 provide an ITAAC for the D-RAP.
15 The second open item has to do with a 16 Staff review of the Tier 1 information, specifically 17 the ITAAC. The Staff reviewed the information here 18 for consistency and clarity.
19 And based on that review, in an RAI we 20 suggested some wording changes to Tier 1 to make sure 21 that there was consistency in the ITAAC design 22 commitment, the ITA and acceptance criteria. And to 23 make sure that their acceptance criteria, there's no 24 ambiguity in the acceptance criteria, it's perfectly 25 clear.
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274 1 So this is an open item because it was an 2 RAI that was just recently issued to NuScale. And a 3 similar approach and review was done for the APR1400.
4 MEMBER BLEY: Tanny?
5 MR. SANTOS: Yes.
6 MEMBER BLEY: I know we've talked in some 7 length about that, the first open item up there --
8 MR. SANTOS: Yes.
9 MEMBER BLEY: -- on the Subcommittee. I 10 don't quite remember the rationale for not meeting an 11 ITAAC for the D-RAP.
12 MR. SANTOS: My read of the SECY paper is 13 it basically boiled down to, an ITAAC for a D-RAP is 14 not necessary because it poses an unnecessary 15 regulatory burden without a commensurate safety 16 benefit. That's what I took out of my read of the 17 SECY.
18 MEMBER CORRADINI: That's essentially all 19 it said. It's a very short SECY.
20 MEMBER BLEY: Yes, I know we looked at it.
21 MEMBER CORRADINI: Yes, we did. We didn't 22 comment on it, we just, we were informed of it when we 23 were going through chapter --
24 MR. SANTOS: 17.
25 MEMBER CORRADINI: Thank you.
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275 1 MEMBER BLEY: Somehow it feels a little 2 uncomfortable to me, but there's not --
3 MEMBER KIRCHNER: Does it all get rolled 4 up at the end with the final PRA, though?
5 MEMBER BLEY: That would be the rational 6 I was hoping to hear.
7 MEMBER CORRADINI: Somebody is coming to 8 the microphone to solve this.
9 (Off microphone comments.)
10 MS. HAYES: This is Michelle Hayes.
11 (Laughter.)
12 MS. HAYES: And we wrote that SECY. And 13 our argument was that it was more of a programmatic 14 program. The RAP is programmatic and they're 15 committing to the program in Chapter 17.
16 We review it, we say we agree with your 17 program as described. We don't need an ITAAC, just 18 like we don't need an ITAAC for other programmatic 19 issues.
20 MEMBER BLEY: Thanks.
21 MR. SANTOS: Okay, Section 14.3.2 reviews 22 the structural and systems engineering. ITAAC, there 23 are two open items here.
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276 1 building, radioactive waste building and control 2 building.
3 The Staff has concluded that the 4 acceptance criteria for these ITAAC is incomplete 5 because it did not address deviations between the 6 assumed design loads and the as constructed loads.
7 And so it did not address changes in demand that 8 result from these deviations.
9 The Staff also thinks that the acceptance 10 criteria should also state that the reconciliation 11 analysis account for changes between design and 12 construction should use the same methods and codes as 13 that used in the design certification.
14 The second open item has to do with ITAAC 15 for the control building. Staff finds that it's 16 insufficient to verify that as the as-built seismic 17 Category 1 structure is protected from adverse seismic 18 interaction from a non-seismic Category 1 SEC.
19 The acceptance criteria is not consistent 20 with the standardized ITAAC the Staff provided and is 21 not consistent with a similar ITAAC for the reactor 22 building because, to verify a similar, a similar form.
23 The next slide please. 14.3.3 is on 24 piping systems and components. There is one open item 25 here.
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277 1 And this open item has to do with a Staff 2 determination that an ITAAC is needed to verify the 3 installation of the ECCS valves, the containment 4 isolation valves, decay heat removal system actuation 5 valves and the hydraulic lines, to make sure that each 6 valve can perform its safety function.
7 The ITAAC that the Staff is looking for 8 would involve a walkdown inspection to verify that the 9 valves and lines are installed consistent with their, 10 the specifications for geometric configuration, 11 orientation, accessibility and line route, line 12 routing.
13 So, with this ITAAC, with this additional 14 ITAAC in conjunction with the other ITAAC provided by 15 NuScale, the Staff will be able to reach a reasonable 16 assurance determination that these valves will be able 17 to operate under their design basis conditions.
18 And we had a public meeting with NuScale 19 a few weeks ago to discuss this. We are just now 20 working on the language for the ITAAC.
21 Next slide. 14.3.6 is on the electrical 22 systems. There are two open items here. Again, the 23 first open item is from Chapter 8.
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278 1 under Staff review. There are no ITAAC to verify the 2 equipment used to meet these GDC 17 and 18 3 requirements.
4 So if the GDC exemptions are approved, 5 then this open item can be closed. But if the GDC 6 exemptions are not approved, any equipment used to 7 meet these GDC would need ITAAC verification.
8 And the second open item in this chapter 9 is just to correct an editorial error in one of the 10 Tier 2 tables that provides some additional 11 information about the ITAAC would be to perform.
12 Next slide. And 14.3.8 is on radiation 13 protection. There are two open items here but it's 14 really the same issue, it's just two different RAIs 15 that are trying to address this issue. It has to do 16 with the borated polyethylene shielding and a Tier 1 17 table, 311-1.
18 Now, this table is not an ITAAC table, 19 this table is the reactor building shield wall 20 geometry. And one of the ITAAC acceptance criteria 21 references this table by stating that the thickness of 22 the radiation shielding barriers should be equal to or 23 greater than any values in this table.
24 So, what's happened is, over the bioshield 25 design has evolved over time. Originally there was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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279 1 borated polyethylene shielding. So there was a 2 corresponding line item in this table for it.
3 When that borated polyethylene was 4 removed, the line item was removed from the table.
5 But then subsequently it was re-added back into the 6 bioshield design but was not added back into the tank.
7 So the Staff would be looking for NuScale to add the 8 corresponding line item back into the table so that 9 the acceptance criteria would be appropriate.
10 Next slide. 14.3.9 is human factors 11 engineering. Again, two open items. The first open 12 item here has to do with a Staff concern from Chapter 13 18, to try to ensure that the insights from the entire 14 human factors engineering design process are applied 15 to the as-built main control room.
16 The ITAAC provided by NuScale had a design 17 commitment for the MCR that did not include changes to 18 the design that could occur after the integrated 19 system validation test of the HFE process. We have 20 recently received an updated revision from NuScale to 21 propose a vision to this ITAAC, and the Staff is 22 currently evaluating that right now.
23 The second open item has to do with the 24 ITAAC verifying the displays, controls and alarms.
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280 1 room but not for the remote shutdown station.
2 NuScale has asked, requested an exemption 3 from GCD 19, which requires equipment outside the 4 control room have the capability to shut down the 5 reactor in the event that the main control room is 6 evacuated. So, again, if this exemption is approved, 7 no ITAAC would be required to this verification.
8 Next slide. 14.3.11 is on containment 9 systems. There's one open item here. This one is 10 related to another exemption request from an 11 integrated leak-rate test, 10 CFR 50 Appendix J, for 12 the Type A test.
13 No ITAAC was provided for the Type A test.
14 The Staff's evaluation of this exemption is in Chapter 15 6. But since Chapter 14 was being issued to process 16 before Chapter 6, an open item was created in Chapter 17 14 regarding the acceptability of not having such an 18 ITAAC.
19 Chapter 6 has now, I think, been issued.
20 And it's concluding that this exemption request can be 21 approved so therefore this actually closes out this 22 open item in Chapter 14.
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281 1 Chapter 6.
2 Finally, the conclusions. As I said, 3 there are some sections with open items and for those 4 sections we're not able to finalize any conclusions at 5 this time.
6 But for those sections that do not have 7 any open items, conclusion is basically that pending 8 the resolution of any confirmatory items in those 9 sections, the 10 CFR 52.47(b)(1) requirement has been 10 met.
11 Any questions?
12 MEMBER CORRADINI: Members, questions?
13 Okay, I think there are no questions.
14 MR. SANTOS: Great.
15 MEMBER CORRADINI: So, what I proposed to 16 do, Mr. Chairman, is we take our break now and we come 17 back at a quarter to 3:00. And then we attack Chapter 18 19 and all its derivatives.
19 CHAIRMAN RICCARDELLA: I accept --
20 MEMBER CORRADINI: Chapter 21.
21 CHAIRMAN RICCARDELLA: I accept your 22 suggestion and I will be on recess until quarter to 23 3:00.
24 (Whereupon, the above-entitled matter went 25 off the record at 2:29 p.m. and resumed at 2:44 p.m.)
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282 1 CHAIRMAN RICCARDELLA: Okay. The meeting 2 will come to order. Dr. Corradini?
3 MEMBER CORRADINI: Okay, we're back in 4 session. We have another group in front of us, all 5 smiles. That will change.
6 (Laughter.)
7 MEMBER CORRADINI: Okay. Who is going?
8 Dr. Chowdhury, you're going to lead us? You're going 9 to start us off?
10 Oh, thank you very much. There was a 11 question to the members. Thank you very much.
12 Do we require of the people, of the staff, 13 that we had questions about 392 that require a closed 14 session discussion? I thought not, but I wanted to 15 check. We'll probably have a closed session 16 discussion about some things in Chapter 19. There's 17 a burning desire here, but nothing in 392? No? Okay.
18 CHAIRMAN RICCARDELLA: There was that one 19 question about the clearances, but I don't know --
20 MEMBER CORRADINI: I don't think that's 21 something that's a burning desire at this point.
22 MEMBER MARCH-LEUBA: I don't think they 23 know the answer.
24 MEMBER CORRADINI: Okay.
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283 1 ask NuScale to call somebody.
2 MEMBER CORRADINI: Right. So, that 3 answers that question. So, I'm sorry. Go ahead.
4 DR. CHOWDHURY: That's all right.
5 Good afternoon. My name is Prosanta 6 Chowdhury. I am one of the project managers at NRO.
7 So, this is Chapter 19, full Committee 8 meeting. The staff is presenting. And Greg Cranston 9 was the one who introduced Chapter 19 at the 10 Subcommittee meeting on May 15th, who was covering for 11 Rani Franovich, who is the Chapter PM. So, today I'm 12 covering for Rani for Greg.
13 (Laughter.)
14 MEMBER CORRADINI: So, you're the second 15 cover?
16 DR. CHOWDHURY: I'm the second cover, 17 well, backup. In any case, Greg couldn't be here.
18 But, on behalf of Greg, Rani, and the rest of the 19 staff, I thank you for the opportunity to present the 20 staff's evaluation of the NuScale PRA and severe 21 accident analysis. As I mentioned, the Subcommittee 22 meeting on this chapter, specific sections, was held 23 on May 15th, 2019.
24 This full Committee presentation will 25 provide an overview of the staff's review of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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284 1 topics listed -- and I will show you the topics --
2 except for -- well, let me go there. These are the 3 topics, so except for 19.3 related to RTNSS and 19.5 4 related to aircraft impact. However, the staff is 5 available to answer any questions members may have in 6 those areas that are not being presented.
7 It should also be noted here that Section 8 19.4, related to loss of large areas of the plant due 9 to explosions and fires, is part of staff's Chapter 20 10 evaluation. The staff plans to present this topic to 11 the ACRS at a meeting tentatively scheduled for July 12 2019.
13 So, with this introduction, I turn it over 14 to Alissa Neuhausen.
15 MS. NEUHAUSEN: Good afternoon. My name 16 is Alissa Neuhausen, and I'm a risk and liability 17 analyst in the Office of New Reactors.
18 I'm going to start with a description of 19 the staff's review, and then, I'm going to turn it 20 over to the topics from the Subcommittee meeting that 21 were requested. So, that's the ECCS valves, passive 22 safety system reliability, and then, open items for 23 19.1 and 19.2 24 Staff reviewed the quality, completeness, 25 and consistency of the information in the DCA Rev 2, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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285 1 in accordance with the SRP Section 19.0 and ISG-28.
2 Staff created ISG-28, recognizing limitations of the 3 DCA stage, such as no plant operating experience and 4 a lack of maintenance practices and procedures to 5 support the review of a DCA PRA performed in 6 accordance with the PRA ASME/ANS PRA standard for 7 acceptability. And NuScale committed to using the PRA 8 standard as endorsed by Reg Guide 1.200 and modified 9 by ISG-28.
10 At the DCA stage, the staff reviews the 11 PRA description and results to identify the risks, 12 insights, and vulnerabilities. These include ensuring 13 that the dominant severe accident sequences risk, 14 significant SSCs, and key operator actions are 15 identified. Insights from currently-operating plants 16 are evaluated for significance to the NuScale design.
17 So, in its review of vulnerabilities, staff noted 18 specifically some of the contributors to CDF that were 19 eliminated for the NuScale design. So, some of these 20 are: the primary system has fewer components, 21 reducing challenges associated with external piping, 22 and the elimination of reactor coolant pump seal 23 failure events and sump blockage concerns.
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286 1 frequency and large release frequency and conditional 2 containment failure probability, and evaluated how the 3 PRA results are used as inputs to other programs and 4 processes, such as RTNSS, D-RAP, and ITAAC.
5 Another focus of the review was ensuring 6 that the appropriate key assumptions are included in 7 the DCA. These are related to sources and model 8 uncertainty, scope or level of detail, and are 9 important because the results depend on these 10 assumptions.
11 The staff applied the enhanced safety-12 focused review approach during its PRA review to 13 support integrated decisionmaking and increased focus 14 on safety. Sharing information related to the risk 15 significance of systems and components among technical 16 staff helps align staff on the most risk significant 17 areas of the review.
18 A couple of examples of where this was 19 applied. One example is the reactor building crane.
20 It was applied due to its novel uses, new consequence, 21 frequency of lifting, and because it is shared across 22 multiple modules. Staff expended additional effort 23 compared to other reviews and alerted crane reviewers 24 to the importance of the module drop.
25 Another example is on the key assumptions.
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287 1 Staff focused on ensuring that the COLA item for these 2 key assumptions as described in the SER and RAI 3 response was adequate. And staff's review resulted in 4 multiple additions to some of these key assumption 5 tables in the DCA.
6 Staff also considered ESFRA when issuing 7 RAIs. So, if it was determined that a safety finding 8 could be made based on available information, then we 9 would not issue RAIs if we could make the safety 10 finding.
11 And I will turn it over to Ayo to talk 12 about the ECCS valves failure rates.
13 MR. AYEGBUSI: All right. Good afternoon.
14 My name is Ayo Ayegbusi. I'm a risk and a liability 15 analyst in the Office of New Reactors.
16 So, I'm going to talk about two items.
17 One has to do with the ECCS valves and the design, and 18 the second has to do with RAI 8840, as requested by 19 the Subcommittee.
20 The staff ordered the documents detailing 21 NuScale's ECCS valves failure rates and the 22 sensitivity studies that they performed for those 23 valves. Specifically, the staff looked at the ECCS 24 PRA notebook and the probabilistic analysis of the 25 ECCS valve reliability.
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288 1 For the ECCS valves failure rates, NuScale 2 based those failure rates on operating experience data 3 which comes from the licensee valve reports. And 4 then, also, generic data, which comes from the 6928 5 NUREG, and some NuScale-specific design assumptions.
6 As far as the operating experience data 7 that comes from the LERs, the staff reviewed that and 8 found that acceptable, based on the fact that the 9 approach that was taken is similar to the approach 10 that the agency takes when developing NUREG-6928. And 11 that approach includes using Bayesian update -- well, 12 looking at the demands in the industry, looking at the 13 failures that have occurred, and using the Bayesian 14 update to develop the failure rates.
15 Okay. And then, lastly, from our review, 16 we identified the Applicant performed a number of 17 sensitivity studies, one of which was basically saying 18 why they developed their failure rate for the valves, 19 the ECCS system valves; what if they used the generic 20 industry failure rates, what would the results look 21 like? And so, the staff reviewed this particular 22 sensitivity study and found it reasonable. And the 23 reason why the staff found it reasonable is because, 24 when they did the study, there wasn't a significant 25 impact on the ECCS system failure vulnerability, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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289 1 subsequently would not have a significant impact on 2 the CDF.
3 MEMBER MARCH-LEUBA: Was that because of 4 the IAB, you know, the inadvertent actuation block 5 valve?
6 MR. AYEGBUSI: Was it?
7 MEMBER MARCH-LEUBA: The valve failure 8 probability --
9 MS. NEUHAUSEN: The failure to actuate 10 mode doesn't actually model the IAB. So, it 11 contributes to the way they model various operations, 12 but not for the failure to actuate.
13 MEMBER MARCH-LEUBA: I think it would if 14 the IAB fails --
15 MS. NEUHAUSEN: Well, it's not modeled in 16 the fault tree for failure to actuate.
17 MEMBER BLEY: So, you did review the fault 18 tree?
19 MR. AYEGBUSI: Yes, yes. To be clear, 20 right, NuScale's current PRA models NuScale's current 21 design, as they understand it, right? And so, the 22 IAB, it's not included because it is not deemed to 23 impact the functionality of the ECCS in this case.
24 MEMBER MARCH-LEUBA: The ECCS is what the 25 agency is about. I mean, it doubles the -- the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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290 1 probability of failure multiplies. I mean, something 2 doubles it.
3 MR. AYEGBUSI: So, that's not our current 4 understanding, but we'll have to rely on NuScale or 5 the ECCS valve people to answer that question.
6 MEMBER MARCH-LEUBA: The ECCS valve, the 7 RRV can only open if the IAB allows it to. So, if the 8 IAB has failed, the RRV will never open.
9 MR. AYEGBUSI: That's not our current 10 understanding, but I would rather we --
11 MEMBER MARCH-LEUBA: But it is reality.
12 MR. AYEGBUSI: I would rather we defer to 13 NuScale or our ECCS valve folks.
14 MEMBER MARCH-LEUBA: So, the IAB is not 15 modeled in this PRA analysis?
16 MR. AYEGBUSI: Correct.
17 MEMBER BLEY: We're going to see the 18 details when we go visit the site.
19 MEMBER DIMITRIJEVIC: Or maybe in the 20 closed session today.
21 MEMBER BLEY: No, they're going to show it 22 to us when we go out there.
23 MEMBER CORRADINI: Does staff have a --
24 MR. LUPOLD: This is Tim Lupold from the 25 Mechanical Engineering Branch.
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291 1 It's my Branch that looks at the ECCS 2 valve and the operation of the valve. You're correct, 3 the IAB does have to function in order for the valve 4 to function properly. The IAB has to close in order 5 to prevent the valve from opening, and then, it has to 6 move again and open to allow the valve to open up.
7 That's physically how it works.
8 Now I believe what happened is that 9 NuScale considers this valve IAB to be extremely 10 reliable, and therefore, does not assume a single 11 failure. And that was the subject of a SECY -- what 12 was it? -- 19036, that we sent and it's with the 13 Commission right now.
14 MEMBER BLEY: Well, yes, but that SECY and 15 that argument about single failure has to do with 16 normal regulation. When you're doing a PRA, you model 17 how it works. You don't use those kind of arguments 18 to design your PRA model.
19 MR. LUPOLD: I am not making any arguments 20 on that. I'm just --
21 MEMBER MARCH-LEUBA: You are not a PRA 22 guy.
23 MR. LUPOLD: I really wanted to state how 24 the valve works. That was my objective.
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292 1 modeled with seeing the probability to failure under 2 the PRA.
3 MS. NEUHAUSEN: Well, there's still the 4 probability that the ECCS valve doesn't open, but the 5 IAB is not included the failure to actuate.
6 MEMBER CORRADINI: I think we have another 7 person at the mic --
8 MEMBER DIMITRIJEVIC: But there is a model 9 for the ECCS valve itself. And that is what Dennis 10 asked you. Did you see the fault tree which included, 11 you know, SOV for opening the small -- that should 12 probably be relevant?
13 MS. NEUHAUSEN: Yes. Yes, we saw the --
14 MEMBER DIMITRIJEVIC: But was the IAB part 15 of that fault tree?
16 MS. NEUHAUSEN: The IAB is not a part of 17 the failure to actuate fault tree. It is a part of 18 the spurious actuation fault tree.
19 MEMBER BLEY: Only part of spurious?
20 MEMBER MARCH-LEUBA: Let's get it from the 21 horse's mouth.
22 (Laughter.)
23 MS. NORRIS: This is Rebecca Norris with 24 NuScale.
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293 1 failure tree because, if the IAB fails, it can 2 contribute to spurious opening, but does not affect a 3 failure to open. So, it will still open, even if the 4 IAB does -- and we can discuss this more in the closed 5 session.
6 MEMBER CORRADINI: Let's do that.
7 MEMBER BLEY: We're supposed to see the 8 fault trees when we go out there.
9 MEMBER CORRADINI: Right.
10 MEMBER BLEY: Personally, I would rather 11 wait until we actually have them in front of us and we 12 can talk to them, and how all these pilot valves, 13 including that one, interact and how that's modeled, 14 and what data they're using as to whether it's moving 15 in one direction under hydraulic force or moving in 16 the other direction under spring actuation. And all 17 of those affect how this ought to be done, and I'd 18 rather wait until we see all of that together. So, 19 they could do it in the closed session, but we're 20 going to do it again when we get out there.
21 MEMBER CORRADINI: Proceed.
22 MR. AYEGBUSI: Okay. So, the last thing 23 I wanted to mention on this slide is that there's a 24 lot of tension on the ECCS valves and the potential 25 concern on the failure was of these valves, right?
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294 1 And so, one of the things that the staff looks at is 2 that, when you have items like this, that they're 3 included on the key assumptions list, which requires 4 the COL applicants to review and verify or establish 5 that there's still confidence in the values that were 6 used.
7 MEMBER KIRCHNER: Wait a minute. Wait a 8 minute. The COL applicant? We're certifying the 9 design here and this is fundamental to this design, 10 absolutely critical and fundamental. So, how can you 11 punt this to the COL?
12 MR. AYEGBUSI: So, we're not punting to 13 the COL. What we're saying is the -- well, if I can 14 start with where Alissa started, right, what we look 15 at, at the DCA stage, we look for the risk and size 16 for those that have been identified, and we look to 17 make some reasonable judgment on how the CDF and LRF 18 compares to the Commission safety goals, right?
19 So, in order to do that in this case with 20 a design that doesn't have operating experience, 21 right, our approach was to look at how they determined 22 the failure rates for each of the different valves 23 that make up the ECCS system, right? And when we 24 looked at that, we looked at their methodology, and 25 their methodology is similar to how we develop the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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295 1 generic data we provide in our NUREG.
2 And all we're saying is, because there is 3 no operating experience that supports the data that 4 they've used, right -- well, I have to be careful 5 there. Because there's no operating experience with 6 this particular valve, I should say, right, typically, 7 our process is to have the DCA Applicant included as 8 one of the key assumptions, which, then, the COL 9 applicant is required to review and verify if they 10 have additional information.
11 MEMBER KIRCHNER: That's just 12 unacceptable.
13 MR. AYEGBUSI: Okay.
14 MEMBER KIRCHNER: Now that's one person's 15 opinion, but this design is based on this. So, 16 putting this off or putting off resolution of -- you 17 already said several things that suggest you need a 18 test program to demonstrate --
19 MS. NEUHAUSEN: Yes, yes. Could we also 20 add that in the design space there is a test program 21 going on, and they're working on that now. It's just 22 the specific PRA numbers are to be validated at the 23 COL stage, not like the whole design of the system.
24 MEMBER KIRCHNER: So, what assumptions are 25 you using in generating your PRA numbers? Because you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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296 1 had no operating data --
2 MS. NEUHAUSEN: Well, the assumptions that 3 we are using now are that, like the numbers that they 4 have based on licensee event reports, the number of 5 demands that they took out of the generic data and 6 NUREG-6928, and then, some specific assumptions are 7 reasonable for us at this stage. And then, there's 8 the whole design assurance testing program that's 9 going on right now. And then, those numbers need to 10 be validated at the COL phase as well.
11 CHAIRMAN RICCARDELLA: But are you saying 12 there's a test program to evaluate these, but it won't 13 be completed --
14 MS. NEUHAUSEN: Not the reliability, not 15 the reliability numbers, but the design.
16 MEMBER MARCH-LEUBA: Okay. So, what 17 you're saying, you need this program to see if they 18 work when they're supposed to?
19 MS. NEUHAUSEN: Right, the test program is 20 not running a thousand runs are anything.
21 MEMBER MARCH-LEUBA: But the relative 22 values that you're assuming of 10 to the minus 5, 10 23 to the minus 15, or whatever they are, how are they 24 going to validate it?
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297 1 typical process.
2 MEMBER MARCH-LEUBA: Okay. You gave us a 3 NUREG which IT confiscated our computers, so I cannot 4 get it out yet.
5 (Laughter.)
6 CHAIRMAN RICCARDELLA: They're replacing 7 them.
8 MEMBER MARCH-LEUBA: Well, they're giving 9 us new computers and they want access.
10 Some failure rates for power-operated 11 valves is 15 percent on that PNNL. I'll give you a 12 reference tomorrow when I get my hard drive back.
13 (Laughter.)
14 MR. AYEGBUSI: So, in this case, we can 15 specifically about these valves, right. So, there are 16 a couple of ECCS valves, right? There is one that is 17 hydraulically-operated, and there's another -- I'm 18 trying to remember --
19 MS. NEUHAUSEN: Solenoid.
20 MR. AYEGBUSI: -- solenoid-operated, 21 right. So, if you look at the generic data for 22 current industry operation, right, they're on the 23 order of, I think one is like 10 to the minus 3; one 24 is on the order of 10 to the minus 4, if I remember 25 correctly.
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298 1 MEMBER DIMITRIJEVIC: Forty to the minus 2 4 for solenoid and 60 minus 5 for the hydraulic.
3 MR. AYEGBUSI: Industry generic data?
4 MEMBER DIMITRIJEVIC: No, that's NuScale.
5 MR. AYEGBUSI: Yes, that's --
6 MEMBER DIMITRIJEVIC: Industry data, they 7 don't tell you.
8 MR. AYEGBUSI: Well, we're referring to 9 the NUREG-6928. So --
10 MEMBER MARCH-LEUBA: There is a NUREG that 11 compiles LER data. It was done by PNNL. And some 12 type of data -- it happened to be pilot operators --
13 had a 14.3 percent failure rate.
14 MR. AYEGBUSI: Understood. And again, I 15 guess the other aspect here is looking at the current 16 design of NuScale, the current NuScale design of the 17 valve, and comparing to the valves that are in that 18 report, right, so these valves are --
19 MEMBER MARCH-LEUBA: Hopefully, they 20 design it better, but --
21 MR. AYEGBUSI: Well, these valves don't 22 include some of the -- these valves are simpler. The 23 current design is simpler than some of the valves that 24 are captured in NUREG-6928.
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299 1 they not include generic data in the table 19.41-9?
2 I wanted to ask them that question because they 3 include generic data, but for not for these two 4 specific valves. They say, "Not applicable."
5 MEMBER PETTI: Just as a question, how 6 much different is the generic data from the values 7 that NuScale used? You talked about these being 8 updated. Did it change the value at 25 percent? Did 9 it change it by a factor of 3? I can't tell --
10 MR. AYEGBUSI: So, I think, well --
11 MEMBER DIMITRIJEVIC: They said they don't 12 -- well, it would be interesting to, I mean --
13 MEMBER CORRADINI: Let him answer him 14 before you ask him another question.
15 MR. AYEGBUSI: So, we don't require them 16 to put the data in the table, right?
17 MEMBER DIMITRIJEVIC: Right.
18 MR. AYEGBUSI: They've already told us in 19 the description that in some areas they utilized 20 NUREG-6928. For those specific valves, we have to 21 order the documentation, right? And as I said 22 earlier, there was methodology in developing the data 23 they used, right, which is similar to how we developed 24 the data in coming up with the NUREG-6928. So, we 25 don't require them to put the generic data in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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300 1 table. So, that question I would have to defer to 2 NuScale.
3 MEMBER RAY: What's the design 4 certification based on?
5 MR. AYEGBUSI: The design certification?
6 MEMBER RAY: The reasonable assurance of 7 adequate protection that's the basis of design 8 certification, what's it based on in this regard?
9 MR. AYEGBUSI: So, in this regard, as 10 Alissa commented earlier, right, a couple of things.
11 One is identifying vulnerabilities. The other is 12 identifying risk in sites --
13 MEMBER RAY: No, no, no. No, what's it 14 based on? What does the licensee have to comply with?
15 MR. AYEGBUSI: So, I mean, the regulation 16 is that the licensee has to provide a description and 17 results of the PRA.
18 MEMBER RAY: That's the basis of the 19 design certification, is that the licensee provides a 20 description of the PRA?
21 MS. NEUHAUSEN: That's the only regulation 22 that the PRA has to --
23 MEMBER RAY: So, there's no required 24 reliability of these components?
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301 1 help at the back table.
2 MR. AYEGBUSI: So, I mean, there's no 3 regulation on each component like --
4 MEMBER RAY: I'm not talking about 5 regulation. The certification describes a plant 6 that's a certified design. It's not something 7 revisited later on. What does it require in terms of 8 their performance?
9 MR. AYEGBUSI: So, Commission policy is 10 that for conditional -- core damage frequency, right, 11 it's that core damage frequency is lower than 10 to 12 the minus 4, and large release frequency is lower than 13 10 E minus 6.
14 MEMBER RAY: So, the certification is 15 based on demonstrating that the actual components will 16 comply with that?
17 MR. AYEGBUSI: The plant CDF and the plant 18 LRF, not just individual specific components.
19 MEMBER RAY: Yes.
20 MR. AYEGBUSI: So, when you monitor an 21 entire system, you comply with that.
22 MEMBER RAY: Okay. And that's a required 23 for the license for the plant to operate, to be 24 operable?
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302 1 those goals, if you conform with those goals, then we 2 find it acceptable; we find it reasonable.
3 MEMBER RAY: I think we're mixing up two 4 things here. I'm mixing them up for you. You're 5 saying the certification requires that some 6 combination of component reliabilities exist, such 7 that the overall core damage frequency is met by the 8 license holder?
9 MR. AYEGBUSI: Correct.
10 MEMBER RAY: And that's as far as it goes?
11 MR. AYEGBUSI: Correct.
12 MEMBER CORRADINI: And then, for the level 13 2 part of it, there is a requirement to show that you 14 meet the estimated failure of probability of 15 containment.
16 MEMBER RAY: Okay. Another way to do it 17 would be to specify minimum reliabilities of the 18 individual components, but they're not doing that in 19 this case here.
20 MEMBER CORRADINI: No.
21 MEMBER DIMITRIJEVIC: That cannot be done 22 because the model is too complex.
23 MEMBER RAY: Okay.
24 MEMBER DIMITRIJEVIC: However, what I 25 wanted to say, and it's in your sensitivity analysis, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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303 1 when you have a percent of common cause, which I 2 remember this discussion because they use a very 3 conservative number, and we can even take 14 percent 4 and it will not reach that number. However, that 5 common cause should show that they are very sensitive 6 to that because it came with results 40 to the minus 7 6. So, you have a 10 to the minus 9 and 40 to the 8 minus 6; they both satisfy the safety goal, but this 9 is a completely different plan. This is not any more 10 negligible risk and all your risk insights are not 11 valid anymore.
12 So, the question is, because you said 13 first you want to see these insights. And these 14 insights are different when you are 10 to the minus 5 15 and when you are 10 to the minus 9. So, therefore, if 16 the sensitivity shows that there will increase a 17 thousand times, even if they still meet the safety 18 goal, you don't have good risk insights. So, it shows 19 sensitivity and something you should look into.
20 That's what's my opinion.
21 MS. NEUHAUSEN: Right. So, that common 22 cause was for like all the common cause --
23 MEMBER DIMITRIJEVIC: And I know, and I 24 think it was completely unnecessary sensitivity. That 25 didn't tell us anything and it showed that they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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304 1 very sensitive, and nobody is surprised.
2 The thing is they should run the different 3 sensitivity on the factors, those rates and the ECCS, 4 but they ran it on this delta P failure rate --
5 MS. NEUHAUSEN: And they did run some.
6 They did one on the delta P. They did one on the 7 passive system reliability --
8 MEMBER DIMITRIJEVIC: Right.
9 MS. NEUHAUSEN: -- which is in the model.
10 MEMBER DIMITRIJEVIC: Yes, I know.
11 MS. NEUHAUSEN: And then, the generic --
12 MR. AYEGBUSI: So, I think one of the 13 things there is you're seeing the system, you're 14 seeing the PRA sensitivity studies that were done.
15 MEMBER DIMITRIJEVIC: Right.
16 MS. NEUHAUSEN: In individual notebooks 17 they have some sensitivity studies that were done.
18 So, your concerns are addressed in individual PRA 19 notebooks for a system, right? That's one aspect.
20 But the other aspect is, when we say "risk 21 insights," right, we don't specify how the sensitivity 22 study should be done. We look at the reasonability of 23 it, right, and we look to see if, for example, a 24 component has a low failure rate. If you increase the 25 failure rate, right, this will come out as being NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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305 1 sensitive. But also --
2 MEMBER DIMITRIJEVIC: Your risk insights 3 is everything but the important components or the 4 important systems, the important human actions. That 5 completely changes when your risk goes to 10 to the 6 minus 6 or 10 to the minus 4. It's not just 7 sensitivity studies, your risk insights; everything 8 that you get from PRAs, these insights.
9 MR. AYEGBUSI: Okay.
10 MEMBER CORRADINI: You get her point, 11 right?
12 MR. AYEGBUSI: I have to think through it.
13 MEMBER CORRADINI: I'm not a PRA person, 14 but I think what she's saying, when something is a 15 thousand times smaller, and then, I do just enough 16 sensitivity to show that I have a big margin, the 17 margin is a factor of a thousand, that's good, but it 18 tells me nothing about what's driving that factor of 19 a thousand. Is it the valves? Is it the DHRS? Is 20 there any dominant aspect of the design that takes me 21 from here to there when I do a broad, sweeping 22 sensitivity? Am I getting it approximately correct?
23 MEMBER DIMITRIJEVIC: No.
24 MEMBER CORRADINI: No?
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306 1 once when you get this thousand increase, it's a 2 completely different story. It's not the same PRA.
3 The conclusions are not the same anymore.
4 Let's say that this is right and that 5 those valves are a thousand times higher failure rate.
6 That invalidates all of the conclusions from this PRA.
7 That's my point. You still meet the sensitive goal, 8 but conclusions are invalidated.
9 So, I'd just like to say, in that case, we 10 should say we are very sensitive to that. We 11 shouldn't say, oh, we meet safety goals, so we don't 12 care. We should say we are sensitive to this and it's 13 something we should keep track of.
14 MS. NEUHAUSEN: Well, I think we know that 15 were sensitive to the ECCS valves. I mean, that's in 16 there, right, and --
17 MEMBER DIMITRIJEVIC: Well, that's what I 18 just want to say. We cannot say, yes, we meet the 19 safety goal. Okay. That's --
20 MR. AYEGBUSI: Yes, I think we understand 21 that. I think we try to capture that in our Safety 22 Evaluation Report. We're not looking to say, you 23 know, 10 to the minus 4, are you lower than that, 24 right? We're kind of looking to say all the Applicant 25 has done, do we have a sense that they're not higher NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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307 1 than 10 to the minus 4? So, it's more of a sense than 2 saying you meet a specific number.
3 MEMBER DIMITRIJEVIC: And one of the 4 things which I also object to on the sensitivity, I 5 want to tell you that they didn't run any combination.
6 And sometimes there could be some things in 7 combination together, you know, like, say, increase 8 the valve failure probability and that the delta P, 9 opening of the low delta P. The things are virtually 10 the same cut-sets. If you run a combination, you can 11 get some proof of finding that something increases CDF 12 significantly. I did not see any combination in the 13 sensitivity studies.
14 MR. AYEGBUSI: Yes, I think, in general, 15 we would agree with that, but there are a couple of 16 things there. If you look at the top, the significant 17 cut-sets, right --
18 MEMBER DIMITRIJEVIC: Yes.
19 MR. AYEGBUSI: -- a lot of these are 20 driven by common-cause failure.
21 MEMBER DIMITRIJEVIC: That's true.
22 MR. AYEGBUSI: Right, which is --
23 MEMBER DIMITRIJEVIC: CVCS, DHRS, yes.
24 MR. AYEGBUSI: Correct. Which they did do 25 some level of sensitivity study on, right? Now, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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308 1 again, we agree with your point that it was a --
2 MEMBER DIMITRIJEVIC: I know, but you're 3 going to say, okay, they put in the two, and now they 4 still have the 10 to the minus 4, so we are fine.
5 That's all --
6 MR. AYEGBUSI: Well, no, actually, that's 7 not how we would look at it. How we look at it is 8 they've increased the common-cause failure. And I 9 would agree with you that maybe they should run it, 10 they could run it only for two systems or the 11 combinations, right, and not all the common-cause 12 failures. But the reality is those systems are 13 already risk-significant, right?
14 So, at some point we have to make, going 15 back to the enhanced safety-focused review, we have to 16 make a judgment and say -- because you're asking 17 questions -- are these questions going to be required 18 for us to make a safety finding, right? And what we 19 did was we said we don't believe we need to ask these 20 questions for us to be able to make a safety finding 21 based on the information we have now.
22 MEMBER DIMITRIJEVIC: Okay. Well, I can 23 see your point. At the same time, when you have a 24 small number, the sensitivity and uncertainty are the 25 most important.
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309 1 MR. AYEGBUSI: Understood.
2 MEMBER DIMITRIJEVIC: They have to show 3 you what are some things that you really need to 4 consider. For example, you can notice that this 5 opening on low the delta pressure doesn't have a 6 common cause even in the assumption. You know, .1, it 7 still is independent, which is really I won't put 8 common-cause events since this assumption just 9 reflects our knowledge, I mean using your judgment.
10 So, you know, the thing is that, if you 11 miss those little things there, the whole picture on 12 sensitivity and uncertainty can be askew. It's 13 something worth looking, in my opinion --
14 MR. AYEGBUSI: Okay.
15 MEMBER DIMITRIJEVIC: -- to get a little 16 more information, a little better understanding what 17 does that mean "no risk".
18 MEMBER PETTI: To me, given the uniqueness 19 of the design and how different it is, it's almost 20 like the risk insights are more important. I know 21 there's this legal thing about you've got to be below 22 CDF and LRF. But we don't have a lot of 23 understanding. Ask yourself if we've done a PRA on 24 Shippingport. You know, it's great. You just don't 25 know the uncertainty that's there. The risk insight NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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310 1 piece, even though the numbers are low, are really 2 important, I would think. That we don't lose track of 3 that, that's all I'm --
4 MR. AYEGBUSI: Yes, I guess what I would 5 say to that is that's why it's important -- and I 6 think Alissa covered this earlier -- that's why it's 7 important to us that the uncertainties, the potential 8 concern around uncertainties are captured under the 9 key assumptions, right, and that's tracked to the COL 10 and it continues to be a focus item, right? So, it's 11 not lost, right? I mean, that's why it was 12 significant for us to specifically focus on that.
13 So, I would say we definitely did not 14 spend all our time focusing on if they met the 15 Commission safety goals. That was probably, I would 16 say, the least of our insights.
17 MS. NEUHAUSEN: Yes, but I think the slide 18 that I would keep referring back to is the slide 5.
19 I mean, we have Commission safety goals on here, but 20 it's not the only thing that we look at, right? You 21 mentioned the risk insights, the vulnerabilities.
22 Really important are really the programs and 23 processes, too, and it's, I think, what you keep 24 alluding back to.
25 MEMBER CORRADINI: Okay.
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311 1 MR. AYEGBUSI: All right. All right.
2 MEMBER KIRCHNER: Let me ask you a 3 question. Is failure of one of these valves a design-4 basis event?
5 MS. HAYES: Maybe we need someone from 6 Chapter 2 to help us out there.
7 MR. AYEGBUSI: Right.
8 MEMBER CORRADINI: I think the answer to 9 that is yes, because they've got three RVVs and two 10 RRVs. And the assumption is a single failure --
11 MEMBER KIRCHNER: A single failure would 12 have one of these --
13 MEMBER DIMITRIJEVIC: A LOCA.
14 MEMBER KIRCHNER: -- a LOCA situation.
15 MEMBER CORRADINI: Right.
16 MEMBER MARCH-LEUBA: Let's wait for 17 Chapter 15. I think that's the basis of safety, that 18 the RRVs cannot fail because of the IAB. The IAB, you 19 know, the actuation block.
20 MEMBER CORRADINI: I think we have a 21 member of the staff that is going to help us.
22 MR. NOLAN: This is Ryan Nolan from 23 Reactor Systems.
24 It is addressed in Chapter 15, both an 25 inadvertent opening as well as the single failure of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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312 1 the main valve from opening. Certainly the IAB is 2 being looked at as well. At a high level, the failure 3 of an ECCS valve is addressed in Chapter 15.
4 MR. AYEGBUSI: All right. I'm being told 5 to speed along.
6 So, we're talking about the ECCS system as 7 a whole. The sensitivity studies that were performed 8 -- we talked about using generic data to evaluate if 9 the NuScale specific data, how they compared to each 10 other, right? But, then, NuScale also did other 11 sensitivity studies and these are in the PRA 12 notebooks, not in the FSAR, right? So, I wanted to 13 point that out.
14 But they did sensitivity studies by 15 looking at increased failure probabilities of the 16 passive heat removal function of the system, right?
17 And then, the ECCS would go to differential pressure 18 of the valve actually on that condition. And then, 19 the common-cause failure using a significantly higher 20 failure probability for common-cause failure of all 21 components.
22 And so, based on our review, what we found 23 was, basically, the insights that come out from just 24 the PRA by itself have captured what came out during 25 the sensitivity studies, and that these sensitivity NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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313 1 studies were not significant, did not change the CDF 2 or LRF significantly.
3 And I think you already mentioned the one 4 in the common-cause failure where that was probably 5 the most significant one, where our CDF came down to 6 10 to the minus 6, on the order of that.
7 So, the results of the studies demonstrate 8 that, again, the CDF and LRF Commission safety goals 9 are met, but, more importantly, that the risk insights 10 have adequately been captured in the FSAR, right, and 11 risk-significant SSCs, key assumptions table, key 12 insights table, and for all the different hazards and 13 modes.
14 All right. So, that's all I had on ECCS 15 valves, unless there are additional questions 16 Okay. So, moving on to RAI 8840, this RAI 17 was actually a pretty detailed RAI. I'm going to 18 cover one question out of multiple questions in that 19 RAI. And this is probably the one that took a while 20 to complete.
21 But, basically, this particular question 22 had to do with the fact that the normal-type design 23 is, if you had a LOCA inside containment, the 24 containment actuation valves would go closed. What we 25 saw in the PRA modeling was that the PRA didn't model NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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314 1 the containment actuation valves going closed. And 2 based on that, I guess NuScale, they provided their 3 supporting documents for us to audit. And then, we 4 also internally performed our independent analysis to 5 evaluate how they came to their conclusions. And 6 eventually, we were satisfied with not modeling the 7 containment isolation for a LOCA inside containment, 8 given the fact that, even in that condition, you would 9 still have core cooling and heat transfer to the pool.
10 This RAI is now in confirmatory space.
11 And basically, how we resolved this concern that we 12 had was NuScale included in the FSAR, the DCA, a 13 discussion about why this was not necessary, why 14 containment isolation is not necessary in LOCAs inside 15 containment. And that satisfied our concerns that it 16 was not captured somewhere in the DCD.
17 MEMBER CORRADINI: So, I want to make sure 18 I understand this.
19 MR. AYEGBUSI: Yes, sir.
20 MEMBER CORRADINI: Okay? So, it's now 21 turned to a confirmatory item? That last thing I 22 don't understand.
23 MR. AYEGBUSI: Yes, it's now a 24 confirmatory item.
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315 1 would be what?
2 MR. AYEGBUSI: So, the confirmation is 3 NuScale submitted to us a supplemental RAI response, 4 which includes a markup of the text, the DCD text.
5 And we found that acceptable. And so, during the next 6 go-round, when the next revision of the DCD is sent 7 in, we'll verify that.
8 MEMBER CORRADINI: Okay. Thank you.
9 Okay.
10 MEMBER MARCH-LEUBA: Sorry, but you have 11 seen the calculation with LOCA inside containment when 12 isolation doesn't happen?
13 MR. AYEGBUSI: Yes, sir.
14 MEMBER MARCH-LEUBA: Because after LOCA, 15 you rely on the steam that leaves the vessel 16 condensing into the containment. And if you are not 17 isolated, the steam leaks out and you never have the 18 heat conduction to the vessel.
19 MR. AYEGBUSI: So, I don't know -- you 20 know, I can speak to all the details you want. I just 21 don't know if some of it crosses into closed space.
22 But what I would say is you're not losing 23 enough to impact heat transfer.
24 MEMBER MARCH-LEUBA: And you have seen a 25 simulated calculation, a real calculation?
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316 1 MR. AYEGBUSI: Yes, we have seen their 2 calculation and we have done our own calculation.
3 MEMBER MARCH-LEUBA: Okay.
4 MR. AYEGBUSI: Yes.
5 MEMBER KIRCHNER: Which LOCAs did you 6 consider?
7 MR. AYEGBUSI: Which LOCAs? I think, so 8 the LOCAs are on the valves. I'm pretty sure there's 9 a LOCA on the valve.
10 MEMBER KIRCHNER: You have several things 11 that could do that, the valves, the piping --
12 MR. AYEGBUSI: I'm sorry. The ECCS valves 13 and the CVCS line.
14 MEMBER KIRCHNER: CVCS line is one that 15 could do it.
16 MR. AYEGBUSI: Yes. CVCS line, the charge 17 and the discharge line --
18 MEMBER KIRCHNER: And that's a smaller 19 one. CVCS is probably more --
20 MEMBER CORRADINI: I think the RVVs might 21 be the largest piping system. I think CVCS is smaller 22 than that.
23 MEMBER KIRCHNER: Yes, the RVV is the 24 biggest LOCA probably. So, as Jose said, you lose all 25 your inventory.
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317 1 MEMBER MARCH-LEUBA: What he's saying is 2 that you do condense some of the steam. Not all of it 3 leaves the steam line. But you have to run a 4 calculation to see how much is left.
5 MR. AYEGBUSI: Well, so, I mean, 6 obviously, it's directly there's the steam coming out, 7 steam going to containment and cooling it, right? But 8 the reality is you don't have a lot of penetrations 9 that will be where steam can escape from containment, 10 right? Some penetrations are in closed state --
11 MEMBER MARCH-LEUBA: The steam line -- oh.
12 MR. AYEGBUSI: Some penetration is in 13 closed state. There are very few penetrations that 14 you have to be concerned with. I think there's only 15 actually one penetration you would be concerned with, 16 and the size of that penetration, it's not big, right?
17 So, it's not top numbers, I guess.
18 All right. And that's all I have.
19 MS. POHIDA: Hi. I'm Marie Pohida. I'm 20 going to be discussing the staff's review of the 21 passive system for liability evaluation. This is 22 going to be high-level. So, I don't go into 23 proprietary territory. And I understand that the 24 Applicant will be discussing their analysis this 25 afternoon in the closed session.
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318 1 Okay. I audited documents related to the 2 passive system reliability analysis, and my review 3 focused on the general approach to the screening and 4 binning of accident sequences that were modeled; the 5 identification of key phenomena for the NRELAP 6 evaluation. These sequences that were binned were 7 those that include contribute at least 1 percent of 8 the CDF. They assume a successful scram due to low 9 frequence of ATWS, and sequences that required 10 inventory addition to prevent core damage, like a CVCS 11 LOCA outside containment that's not isolated, that was 12 not in scope.
13 So, these scenarios that were considered 14 for the pass of a liability evaluation for ECCS was a 15 spurious opening of the reactor recirculation valve 16 with a single reactor vent valve available. The 17 second scenario is a CVCS LOCA outside containment 18 that is successfully isolated with DHRS not available, 19 and the RPV pressure increases until a reactor safety 20 valve cycles and sticks open, where, then, ECCS 21 actuates on high level.
22 For evaluating the passive reliability of 23 the decay heat removal system, the Applicant 24 considered a general transient with just one train of 25 the DHRS available, and no other system was credited.
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319 1 I looked at the NRELAP inputs and the ranges, such as 2 assumptions of non-condensable gases in the CNV and 3 the decay heat removal system. And I looked at the 4 general approach to the quantification of the passive 5 system reliability. I also looked at the 6 distributions of the inputs, were they assumed to be 7 uniform or normal. I did need additional information 8 to understand how several of the inputs affected the 9 passive system reliability results, including the 10 assumptions on non-condensable gas volumes, the non-11 condensable gas distributions, and the assumed initial 12 CNV pressures.
13 Following that RAI response, the Applicant 14 then updated the tables of key ECCS and decay heat 15 removal system phenomenon in Chapter 19.
16 Next slide.
17 All right. There was a sensitivity 18 analysis that was performed of ECCS and DHRS 19 reliability where all the parameter distributions for 20 the NRELAP inputs were assumed to be uniform. The 21 results, I don't want to get into details because this 22 is an open session, but the results of that 23 sensitivity analysis for ECCS reliability and DHRS did 24 meet the Commission goals for CDF and LRF.
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320 1 key ECCS and DHRS phenomena in the DCA in Chapter 19, 2 and their analysis was consistent with the goals of 3 our SRP in Chapter 19.
4 So, that concludes my discussion. Are 5 there any questions?
6 MEMBER DIMITRIJEVIC: I was surprised when 7 I saw distribution of those numbers because it was 8 very narrow. Did you check that uncertainty analyses 9 that did -- I'm trying to find where I saw this. You 10 can enter a factor of 2 or something, which is really 11 strange, I mean.
12 MS. POHIDA: I'm slow here because I don't 13 want to go into proprietary territory.
14 I reviewed the sensitivity analysis, and 15 that analysis was where they assumed that all those 16 distributions assumed -- all those distributions --
17 MEMBER DIMITRIJEVIC: Correct.
18 MS. POHIDA: -- were assumed to be 19 uniform.
20 MEMBER DIMITRIJEVIC: Yes, so there's some 21 uniform and some -- yes.
22 MS. POHIDA: Yes, and those results I 23 think need, if I need to go into detail, they need to 24 be reserved for the closed session.
25 MEMBER DIMITRIJEVIC: Okay. All right.
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321 1 MS. POHIDA: Thank you very much.
2 Oh, this is me. Okay.
3 I do have an open item. It's RAI 9659.
4 And it's looking at the consequences of a module 5 that's being moved for refueling. As it's being moved 6 in the operating bay, if it's dropped, it can impact 7 up to two operating modules.
8 And I'm going back to Revision 1 of the 9 DCA. There's a statement that says, if a module is 10 dropped on an operating module near the top, it could 11 impact DHRS piping or the heat exchangers.
12 Revision 2 that we received last October 13 of the DCA was augmented to state that, "Additional 14 pipe breaks may occur, leading to a CVCS line break 15 outside containment."
16 So, we issued an RAI. We've received it 17 and we're evaluating it for the completion of risk 18 insights. And it's basically what pipes are assumed 19 to fail? CVCS, decay heat removal system, and the 20 containment flood and drain system, what pipes are 21 assumed to fail? And more importantly is the 22 capability of the containment isolation valves to 23 close compromised, given that you have a strike from 24 an operating module, I mean given a strike from a 25 dropped module that hits an operating module that has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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322 1 sufficient force to cause pipe breaks? So, that's 2 being reviewed as we speak.
3 And that's all I have on this slide.
4 MEMBER DIMITRIJEVIC: But they make the 5 case, it seems, that this module drop frequency is 6 very small compared without the initiating event 7 frequency. So, for operating module drop was never 8 considered initiating. So, okay, you are concerned 9 about containment isolation and the operating module, 10 right?
11 MS. POHIDA: I'm concerned about the 12 consequences if a dropped module that's being removed 13 for refueling hits an operating module.
14 MEMBER DIMITRIJEVIC: Right, but that 15 operating module doesn't have an initiating event 16 module drop.
17 MS. POHIDA: No, but what's being 18 postulated in Revision 2 of the DCA is that that 19 dropped module hits an operating module near the top 20 and causes pipe breaks --
21 MEMBER DIMITRIJEVIC: Right.
22 MS. POHIDA: -- of the CVCS system outside 23 containment.
24 MEMBER DIMITRIJEVIC: Right.
25 MS. POHIDA: Which would, then, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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323 1 necessitate containment isolation.
2 MEMBER DIMITRIJEVIC: Right.
3 MS. POHIDA: And the question is, is the 4 capability of the containment isolation valves to 5 function compromised if, you know, if an operating 6 module is struck with sufficient force to cause pipe 7 breaks?
8 MEMBER DIMITRIJEVIC: Okay. I'm only 9 pointing to you that that event is not part of PRA at 10 all. It's only part of a PRA for a shutdown module.
11 It's not a part of the PRA for an operating module.
12 So, there is not any place in PRA where they consider 13 containment isolation.
14 MS. POHIDA: It's considered qualitatively 15 in the multi-module risk section of the DCA. And the 16 reason why I'm asking these questions is to make sure 17 that our understanding of the consequences of this 18 event are complete and that the risk insights are 19 complete.
20 MEMBER DIMITRIJEVIC: All right. I just 21 want to say that they don't have really good place to 22 consider this because they made the case of the 23 initial infrequency to do the module drop. Anything 24 else is small compared by the frequency rates.
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324 1 that? Are you referring to the analysis of single 2 module drop, where a module is being dropped --
3 MEMBER DIMITRIJEVIC: No, but that --
4 MS. POHIDA: -- but the addition of 5 striking an operating module is not being postulated?
6 MEMBER DIMITRIJEVIC: No, there is a 7 story, a qualitative story, about that. I'm just 8 pointing there is no quantitative -- there is no 9 initiating event on the operating module which comes 10 around that drop.
11 MS. POHIDA: Yes, it's being evaluated 12 qualitatively --
13 MEMBER DIMITRIJEVIC: Right.
14 MS. POHIDA: -- in the multi-module 15 section of DCA.
16 MEMBER DIMITRIJEVIC: Right.
17 MS. POHIDA: Yes. And according to our 18 SRP, there's no requirement that they quantify, but we 19 need to make sure that our understanding of the risk 20 insights is complete.
21 CHAIRMAN RICCARDELLA: I would assume 22 that, if the probability was high enough, it would be 23 part of the CDF for an operating module.
24 MEMBER DIMITRIJEVIC: Yes, that's why I 25 say maybe after they complete that, they will have to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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325 1 add the new initiating event. I mean, I don't know.
2 I'm just saying that's not in the PRA.
3 CHAIRMAN RICCARDELLA: You know, it's, do 4 they have a reasonable basis for their assumption on 5 the probability of dropping the module?
6 MS. POHIDA: For single module drop?
7 CHAIRMAN RICCARDELLA: Yes.
8 MS. POHIDA: That doesn't impact another 9 module?
10 CHAIRMAN RICCARDELLA: Regardless, what's 11 the probability of dropping a module, whether it 12 impacts it or not?
13 MS. POHIDA: Okay. I just discussed this 14 in a prior meeting. It's about an order of magnitude 15 lower than an EPRI report where they assessed the 16 probability of a dropped spent fuel cask. Okay? And 17 it's about, roughly, two orders of magnitude lower 18 than what was estimated in a NUREG -- I can't remember 19 the number now -- for heavy load drops greater than 30 20 tons.
21 What we did is we used the --
22 CHAIRMAN RICCARDELLA: So there's not 23 justification for those orders of -- is there some 24 justification why those are so much lower?
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326 1 Applicant has further information -- it is, in the 2 NUREG most of those failures were due to rigging 3 failures. Okay? Whereas, in this design they have a 4 designated module lift adapter with designated 5 attachment points to the containment to move the 6 nuclear power module. Does that help?
7 CHAIRMAN RICCARDELLA: Yes, that helps for 8 the second one, but what about the --
9 MS. POHIDA: But this information is being 10 reevaluated in context of this multi-module drop 11 event.
12 MEMBER DIMITRIJEVIC: Well, in that case, 13 I have an additional question.
14 MS. POHIDA: Thank you.
15 MEMBER DIMITRIJEVIC: You asked them to 16 put the insights for a module drop in Chapter 19, 17 but --
18 MS. POHIDA: Yes.
19 MEMBER DIMITRIJEVIC: -- that wasn't done?
20 And so, I can understand some and understand that is -
21 -
22 MS. POHIDA: For a single module drop, 23 yes.
24 MEMBER DIMITRIJEVIC: Yes. Okay. All 25 right. For me, all right, there is some percentages NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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327 1 the single module becomes multiple, but that's all 2 right, a single module.
3 And that's all right because some of these 4 things are in different tables, as I saw in your ICI.
5 However, I would object to you not ask them in design 6 -- you know, this is not final design and, you know, 7 the claim is not safety system.
8 So, my question is for human action, which 9 you notify there is action of commission, which is the 10 most important contributor to module drop. I think 11 that these actions should be in Chapter 19 and it 12 should be in the -- I think it is Table 7, teaching 13 why it is important --
14 MS. POHIDA: Human actions?
15 MEMBER DIMITRIJEVIC: Yes, human actions, 16 yes, for the shutdown.
17 MS. POHIDA: That is being reevaluated in 18 context of this RAI.
19 MEMBER DIMITRIJEVIC: Oh, excellent. All 20 right.
21 MS. POHIDA: Okey-dokey. Are there any 22 more questions?
23 Thank you.
24 MS. NEUHAUSEN: So, due to the open item 25 on multi-modal risk that Marie just discussed, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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328 1 staff can't make a finding on the description in DCA 2 Part 2, Tier 2, Section 19.0 and 19.1.
3 And then, the only other comment I have to 4 make is that we were provided some SER comments during 5 the previous meeting, and we agree with them. And so, 6 phase 4, there will be changes associated with those 7 comments.
8 And 19.2.
9 MS. GRADY: Okay. And for the severe 10 accident portion of Chapter 19, there are two open 11 items. And I can describe them briefly because 12 they're both still in evaluation.
13 One of them is the equipment survivability 14 evaluation, and that is being impacted by the fact 15 that the Applicant has proposed a new method of 16 determining an accident source term. And whatever 17 source term finally gets agreed upon is going to 18 impact the equipment survivability program and what 19 components are involved and what conditions they're 20 going to be evaluated under.
21 And that's it for equipment survivability.
22 MEMBER CORRADINI: And just to be clear, 23 so staff now has a Revision 3 of the source term --
24 MS. GRADY: Yes.
25 MEMBER CORRADINI: -- and it is under NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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329 1 review?
2 MS. GRADY: Absolutely.
3 MEMBER CORRADINI: Okay.
4 MS. GRADY: And I should also mention 5 that, coincident with that and coincident with the 6 equipment survivability evaluation, the Applicant has 7 also submitted an Exemption Request No. 16, which is 8 the post-accident sample system exemption request, 9 which is significantly related to this accident source 10 term. And all three of those are being evaluated 11 simultaneously.
12 MEMBER CORRADINI: Okay.
13 MS. GRADY: And that's the open item.
14 And I was here on the Subcommittee meeting 15 and described the other open item, which is under 16 hydrogen generation and control. And this is also 17 still under evaluation. There has been identified an 18 accident by NuScale where there could be a CVCS line 19 break underneath the bioshield. And that could, in 20 fact, produce detonatable or combustible conditions.
21 And if it did, it would lead, then, to multi-module 22 risk; that the bioshield wasn't designed. So, we are 23 reviewing our analysis of that, and that is still 24 ongoing. I'm expecting a confirmatory calculation on 25 what conditions will be for these under the bioshield NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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330 1 later on this week. So, by phase 4, I should have an 2 answer as to whether or not this leads to that.
3 And because there are two open items in 4 Chapter 19.2, we can't say that it's final yet. And 5 the two open items are the equipment survivability and 6 hydrogen generation and control.
7 MEMBER CORRADINI: Questions by the 8 Committee?
9 If not, we're going to go on to Chapter 10 21, I have a kind of feeling.
11 Who's handling 21? I had that feeling.
12 You're back.
13 DR. CHOWDHURY: Me, too. So, should I 14 proceed?
15 MEMBER CORRADINI: Yes, please do.
16 MEMBER DIMITRIJEVIC: I have an objection.
17 I have an objection on the title of this chapter 18 because the chapter definitely is not multi-module 19 design consideration because the only thing which is 20 here is the systems and common systems. So, I don't 21 call it "multi-module design system consideration".
22 The risk does not consider the accident drops the --
23 the hydrogen explosion. Human action is different 24 from the very important things moving the module 25 around, and all I see for this section. So, don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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331 1 call it "the consideration".
2 DR. CHOWDHURY: Okay. I'll answer to that 3 question in just a second.
4 So, once again, Prosanta Chowdhury. I'm 5 the project manager. And this is Chapter 21.
6 MEMBER REMPE: Is your microphone on?
7 DR. CHOWDHURY: Yes.
8 MEMBER CORRADINI: He's just a very quiet 9 person.
10 DR. CHOWDHURY: Once again, this is a full 11 Committee meeting on Chapter 21, "Multi-Module Design 12 Considerations". And I will answer your question, or 13 try to. I'll try to.
14 What happened is that this is a new and 15 unique chapter in design certification application.
16 So, we never had Chapter 21. We do not even have an 17 SRP standard section on Chapter 21. This is the title 18 that the Applicant used to summarize the multi-module 19 shared systems' interactions and their effects, and 20 compiled and consolidated everything under this 21 chapter.
22 So, we utilized the same, so that we --
23 the chapter titled "consideration". In this chapter, 24 we never documented any staff's findings. We simply 25 pointed to where those multi-module consideration and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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332 1 assertions and shared systems' interactions have been 2 evaluated and documented.
3 So, could we name it differently?
4 Probably.
5 MEMBER DIMITRIJEVIC: Well, the only thing 6 which I want to say, it's not module consideration.
7 It's the system consideration. Because all new and 8 unique things were not considered. The unique thing 9 is that you move the modules; you can drop them.
10 That's unique. The unique thing is that you can have 11 a hydrogen explosion affecting multi-modules. That's 12 unique. Unique thing is that you have an operator 13 responding to that, multiple events, which is also not 14 considered here. The only thing considered is the 15 systems. So, it should be "multi-module design system 16 consideration". I disagree that new and unique things 17 are covered.
18 DR. CHOWDHURY: I understand.
19 MEMBER DIMITRIJEVIC: More than half of 20 them are not covered.
21 DR. CHOWDHURY: I understand, but here, 22 also, multi-module includes systems that support the 23 multi-modules. But if NuScale chooses to provide any 24 insights into the nomenclature, please do so.
25 Okay. So, I'm going to move on. Thank NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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333 1 you for the comment. I appreciate it.
2 So, this is the same list of technical 3 staff, and some of the staff are here today to answer 4 any questions, including Mary Pohida. Thank you for 5 joining me here.
6 And then, this is what is presented. On 7 May 15th, we presented to the Subcommittee this 8 Chapter 21, where we said that Chapter 21 didn't have 9 any open items or confirmatory items. And staff 10 looked at number of shared systems that used the 11 standard review plan, and, also, design-specific 12 review standards were applicable.
13 And staff documented that evaluation in 14 multiple sections of different chapters which are 15 listed here. I had a table there that listed which 16 systems are evaluated where.
17 And then, there was, I understand, a 18 question from the Subcommittee whether loss of any 19 shared system would result in any module shutdown.
20 And I want to point to two areas of the Applicant's 21 Design Certification Application, Part 2, Tier 2, 22 Section 21.2.2 that states, "A total functional 23 failure of certain shared systems may lead to an 24 automatic or a manual trip of up to 12 NPMs." Now 25 NPMs stands for NuScale Power Modules. "But these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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334 1 failures do not present safety-related NPM functions."
2 MEMBER REMPE: So, that I don't think is 3 quite the question that this member of the ACRS 4 Subcommittee asked. I asked, is there guidance?
5 Because you had manual trip there. And I think during 6 the Subcommittee meeting we were told that, yes, there 7 are some shared systems, there are certain shared 8 systems where we were told, yes, the operators are 9 going to have to shut down and they will be guidance 10 provided. And we have been told regularly, oh, the 11 guidance comes at the COL applicant stage. And where 12 I asked, is there enough guidance in what will be 13 certified by the staff that they understand, yes, if 14 you lose whatever system, you've got to shut this 15 thing down? So that whoever is around when they 16 actually have a COL applicant, because we know a 17 certified design can be picked up by somebody else, 18 will know what they're supposed to do, and the staff 19 will be able to monitor what is being done by the COL 20 applicant that they know, yes, if you lose "X" system, 21 you've got down four, five, six, whatever number of 22 modules.
23 DR. CHOWDHURY: Correct.
24 MEMBER REMPE: Is that guidance somewhere 25 once they're certified?
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335 1 DR. CHOWDHURY: Yes. Thank you for 2 clarifying your question.
3 If you remember, when we presented Chapter 4 13, part of Chapter 13, 13.1 and 13.5, NuScale 5 submitted what is called genetic technical guidance.
6 And the staff has been reviewing it, has reviewed the 7 initial, the first edition of it, asked multiple 8 questions. The questions were responded to. A new 9 revision just came in, generic technical guidance, 10 just the end of last month, May 31st.
11 So, the generic technical guidance 12 provides the guidance to develop procedures. So, 13 those will be the plant-specific, operator-specific 14 procedures. So, there is a process in place to 15 develop specific procedures for operators to follow.
16 And my assumption here is that the shared 17 systems' failures and their impact, how the operator 18 will react to it, will be included in those 19 procedures. So, that's my understanding.
20 MEMBER REMPE: So, my question now, 21 knowing that this document has come into the NRC --
22 DR. CHOWDHURY: Uh-hum.
23 MEMBER REMPE: -- on May 31st, is for you 24 to provide that formally, someone from your staff 25 provide that to ACRS, the answer to the question. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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336 1 looked at this revised guidance, and they clearly 2 said, given enough information, that we know, if 3 system "X", shared system "X" goes down, that this 4 number of modules must be shut down. And there is 5 enough information in what the staff's going to be 6 certifying that it's not a question that you're 7 assuming it's there; it's actually there? That's what 8 I'm trying to get to.
9 DR. CHOWDHURY: Okay. What the staff, at 10 this point, what I assume the staff will do is inform 11 the Committee and document in the SER what they have 12 reviewed and whether this guidance is adequate for the 13 COL applicants or license holders and operators to 14 develop their detailed operating procedures based on 15 this guidance. Because those will be the plant-16 specific, and they should cover the aspects of 17 operation under the guidance of those GTGs.
18 So, I think --
19 MEMBER REMPE: Am I clear enough on what 20 I would like to see?
21 DR. CHOWDHURY: Yes.
22 MEMBER REMPE: And we'll hear back?
23 DR. CHOWDHURY: Yes. But what I want to 24 mention here is that I am not in a position at this 25 time to tell you exactly whether your exact question NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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337 1 will be answered. However, the staff will provide 2 their findings based on the Revision 1. That had led 3 to some open items also.
4 MEMBER REMPE: That's fine, if you even 5 say, hey, it's not totally adequate; there are some 6 open items. I just want to make sure you understand 7 the question and --
8 DR. CHOWDHURY: It may be at a higher 9 level.
10 MEMBER REMPE: -- that I will get an 11 answer.
12 DR. CHOWDHURY: Right, right. It may not 13 be very specific; it may be at a higher level, but 14 yes.
15 MEMBER REMPE: Okay. And let me know if 16 it's such a high level. I'm a little dumb sometimes 17 and I might not catch it if it's too high.
18 (Laughter.)
19 MEMBER REMPE: But it has to answer my 20 question because I'll be asking it again later.
21 DR. CHOWDHURY: Sure.
22 MEMBER REMPE: Thank you.
23 DR. CHOWDHURY: Okay. That's it. That's 24 all I have.
25 MEMBER CORRADINI: Okay. Questions by the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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338 1 members for Chapter 21?
2 MEMBER KIRCHNER: It seems like your 3 answer for that leads one to believe that the only 4 thing being certified here is the module itself as a 5 standalone entity, or at least that's my 6 interpretation. Because we know several systems that 7 are shared, it seems to me one can be a lot more 8 explicit about what their impact is. And, again, to 9 leave it to COL applicant -- I'm thinking of the CVCS 10 system, in particular. It's not risk-important, and 11 yet, it's an actor in so many different scenarios that 12 I don't know how that determination was made. I'm 13 still puzzled by that.
14 But that's a good example where generic --
15 you need to go further in suggesting generic tech 16 specs or something to develop those procedures.
17 MEMBER MARCH-LEUBA: They are reluctant to 18 put it in tech specs because it implies safety-19 related. In a perfect world, CVCS will be in the 20 technical specification, because anymore you cannot 21 operate without it.
22 MEMBER KIRCHNER: Well, they even go as 23 far as to rely on it operating all the time because 24 they want a constant sparging effect and to pressurize 25 it. So, I'm --
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339 1 MEMBER REMPE: My take on his response was 2 we've got some additional information. And he is 3 assuming that that information will be sufficient that 4 it will say, if "X" system goes down, four, five, six, 5 however many it's supporting, modules must be shut 6 down. And he hasn't looked at it yet. He thinks 7 that's what it's going to have, but I think we have to 8 have a clear answer. Is that not what I -- I got that 9 he is going to make sure that information exists, even 10 if he has to have a COL item or something. It will be 11 identified that we need more information --
12 MEMBER DIMITRIJEVIC: And maybe we tell 13 them that they need to be shut down. That's 14 interesting, how long it will take them to shut down 15 the --
16 MEMBER REMPE: All of those things, I want 17 to see the additional information, but this is the 18 first I heard that another document is coming in, 19 because before there wasn't.
20 DR. CHOWDHURY: No, this document came in 21 already. We are just looking at the Revision 1 of it, 22 and we had questions on Revision 0 that we asked lots 23 of questions and we got answers. And there was an 24 open item. We need to verify the GTGs against the ISP 25 testing that they have done. So, that is going on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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340 1 right now or will be going on.
2 I also want to point out, on my slide No.
3 4, that NuScale has two tables in Tier 2, Table 21-2 4 and 21-3. And that's where NuScale shared systems 5 have the potential of an adverse system interaction or 6 an undesirable multi-module interaction, are 7 summarized in those two tables.
8 MEMBER CORRADINI: I think Chapter 21 is 9 strictly for shared systems, Walt, and CVCS is not a 10 shared.
11 MEMBER DIMITRIJEVIC: No, but CFDS is.
12 MEMBER CORRADINI: CVCS is not shared 13 between modules.
14 MEMBER DIMITRIJEVIC: CFDS is.
15 MEMBER KIRCHNER: For boron injection --
16 MEMBER CORRADINI: Well, boron injection 17 is one thing, but I thought you were talking about the 18 CVCS system. Each module has its own CVCS system.
19 MEMBER MARCH-LEUBA: Am I wrong? Am I 20 mistaken? Are there only two CVCSs for the --
21 MEMBER CORRADINI: No. You're thinking of 22 maybe component cooling.
23 MEMBER MARCH-LEUBA: No. There's only one 24 BIS.
25 MEMBER DIMITRIJEVIC: CFDS.
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341 1 MEMBER CORRADINI: Correct. Other 2 questions for Mr. Chowdhury?
3 (No response.)
4 MEMBER CORRADINI: Okay. At this point, 5 what I want to do is I want to get public comments 6 before we go into closed session.
7 So, I am told both lines are open.
8 Is there anyone in the room that wants to 9 make a public comment?
10 No. So, please on the phone lines, could 11 someone please at least acknowledge that the phone 12 lines are open, please?
13 PARTICIPANT: The phone lines are open, 14 and I don't have a question.
15 MEMBER CORRADINI: Okay. Go ahead with 16 your comment, please.
17 MEMBER BLEY: She doesn't have one.
18 MEMBER CORRADINI: Oh, I thought she said 19 she did. No comment?
20 Does anybody else have a comment on the 21 line?
22 Okay. Hearing none, why don't we close 23 the lines? And let's verify that, and then, we can go 24 into closed session to discuss some of the other 25 questions we had about Chapter 19.
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342 1 Is NuScale coming up for this?
2 CHAIRMAN RICCARDELLA: Let's take a 10-3 minute break, so 10 minutes after 4:00.
4 (Whereupon, the above-entitled matter went 5 off the record at 3:58 p.m.)
6 7
8 9
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Reactor Oversight Process Enhancement Initiative ACRS Briefing June 5, 2019
Background
- 99 recommendations received for enhancing the ROP
- Discussions at Operating Reactor Business Line and Transformation Commission meetings (fall 2018)
- ROP enhancement project initiated (October 2018) 2
ROP Enhancement Goals
- Make the ROP more risk-informed and performance-based
- Further improve consistency with the NRCs Principles of Good Regulation 3
Objectives
- Focus on issues of higher safety significance
- Enhance Significance Determination Process (SDP)
- Improve inspection program
- Improve communications with industry 4
Guiding Principles
- Leverage ROP self-assessment process
- Maintain ROP strengths
- Develop a strong basis for important changes
- Obtain extensive stakeholder feedback
- Take into account alternate views 5
Project Infrastructure
- NRR Director is the Executive Sponsor
- Recommendations binned into eight themes
- Each theme assigned a team leader and SME(s)
- Held internal alignment meetings/seminars, numerous public meetings with industry/NGOs and RIC session
- Created a public ROP enhancement website
- Established project management tools, including an internal SharePoint site
- SECY paper to the Commission by end of June 2019 6
Completed Actions
- Reinforce press release guidance for White findings
- Revise approach to IMC 0609, Appendix M
- SDP using qualitative criteria
- Improve communication with licensees about inspection results 7
Early Opportunities
- Right-size inspection follow-up for White findings
- Modify White and Yellow finding descriptors
- Refrain from expanding baseline inspection program in the future 8
Commission Approval
- Optimize Baseline Inspection Program
- Review IPs to verify optimal efficiency and effectiveness
- Eliminate unnecessary overlap and redundancy
- Eliminate the four quarter requirement for closure of greater-than-Green inspection findings
- Option to establish requirement that PIs remain inputs until supplemental inspection complete (consistent treatment)
- Specific changes to the SDP for Emergency Preparedness (EP)
- Distinguish significance of certain EP planning standards 9
Next Steps
- Evaluate revisions to performance indicators
- Perform comprehensive review of Problem Identification &
Resolution Inspection Program
- Perform effectiveness review of the Cross-Cutting Issues Program 10
Next Steps
- Optimize Independent Spent Fuel Storage Installation and radiation protection inspections
- Evaluate SDP infrastructure improvements
- Assess additional actions identified in EP focused self-assessment 11
Out-of-Scope Recommendations
- Regional structure and organization
- Low risk compliance issues and backfit and licensing basis recommendations
- Inspection report streamlining Publicly available memo to disposition all 99 recommendations 12
Discussion 13
NEI Perspectives on the NRCs ROP Enhancement Project Martin Murphy, Xcel Energy &
NEI Regulatory Issues Working Group June 5, 2019
Overview Basis for Our Recommendations Our Understanding of the Staffs Proposal Challenges Opportunities
©2019 Nuclear Energy Institute 2
Unprecedented Industry Performance
>90% 10x Top Performing Best Ever 100x Reliability Safety Excellence Oversight Margin
>90% 10-Fold Highest Fewest Fleet Capacity Reduction in Performance NRC ~100 Times Factor Average CDF Record Ever Performance Safer Than Sustained Issues Ever NRC Goals Exceptional Safety Culture The Combination of Performance and Margin Should Enable Transformation
©2019 Nuclear Energy Institute 3
Basis for Our Recommendations CDF Trend Since ROP Implementation 100%
90%
Industry Average CDF Relative to 80%
70% Factor of 60% ~5 Reduction ROP Baseline Year (1999) 50%
40%
30%
20%
10%
0%
1999 2000 2005 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
©2019 Nuclear Energy Institute 4
Our Understanding of the Proposal Based on public briefings only Three key areas:
- Response to White Findings Prompt closure after successful IP 95001 inspection Change in labeling More flexible IP 95001 effort Change in closure of White performance indicator
- Baseline Inspection Program Changes Optimize inspection hours and samples based on experience Review and revise PI&R inspection
- Significance Determination Process Changes Better risk-inform the EP SDP Merge Mitigating Strategies SDP into At-Power SDP Improve interactions with licensee during SDPs
©2019 Nuclear Energy Institute 5
Challenges Response to White Performance Indicators
- Staff proposes to change the means to close a White PI, likely making this White input to the Action Matrix endure longer
- In our view, staff has not provided an adequate basis for the Commission to make an informed decision on the proposal Baseline Inspection Program Changes
- Staff proposes some modest changes in eight inspection procedures
- In our view, staff could go farther in reducing the burden and improving effectiveness of the BIP Significance Determination Process Changes
- The basis for combining the Mitigating Strategies SDP with the At-Power SDP, but not the B.5.b SDP, is not clear to us
©2019 Nuclear Energy Institute 6
Opportunities The June SECY on ROP Enhancement should be seen as a first phase of a multi-phase effort The second phase should address other areas for improvement, including:
- Making IP95001 a smarter inspection
- Streamlining ISFSI inspections
- Optimizing Radiation Protection program inspections
- Completing the holistic review of PI&R inspections
- Looking for performance indicators that would allow further focusing of inspections on risk-significant areas unsuitable to oversight by performance indicators The proposed review of the cross-cutting aspects program should include all possible outcomes
©2019 Nuclear Energy Institute 7