ML20209D160
| ML20209D160 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1582, NUDOCS 8704290193 | |
| Download: ML20209D160 (160) | |
Text
fCRS7~/S'82 ORGME
~
Uh1TED STATES O
- NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON ADVANCED REACTOR DESIGNS O
~
LOCATION:
WASIIINGTO:3, D. C.
PAGES:
1 - 143 i
DATT:
FRIDAY, APRIL 24, 1987 1
...Jd3 @} M @ Y 30$18M9,ye l;om A1.?SOfice ACE-FEDERAL REPORTEPS, INC.
0 Official rters 444 North Ca tol Street Washington, C. 20]01 s
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(202)347 3700 1
NATIONW10E COVERACE
CR30692.0 BRT/sjg 1
1 UNITED STATES OF AMERICA 7-
~
2 NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
SUBCOMMITTEE ON ADVANCED REACTOR DESIGNS 4
5 Nuclear Regulatory Commission 6
Room 1046 1717 !! Street, N.W.
Washington, D.
C.
7 8
Friday, April 24, 1987 9
The meeting convened at 8:30 a.m.,
Mr. David A. Ward, 10 chairman of the subcommittee, presiding.
11 ACRS MEMBERS PRESENT:
12 13 MR. DAVID A. WARD 14 MR. JESSE C.
EDERSOLE DR. J. CARSON MARK 15 MR. CARLYLE MICllELSON 16 DR. CI! ESTER P.
SIESS 17 MR. Cl!ARLES J. WYLIE 18 19 20 21 22 23
()
24 25 Acti 17 ntinAL Riti>onTitas INC.
ti M.m.nm Nationwide emcuge xm im im,
PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS FRIDAY, APRIL 24, 1987 The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at
(
this mooting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
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1 PROCEEDINGS l
2 MR. WARD:
The mooting will now como to order.
3 This is a mooting of the Advisory Committoo on Reactor p
1 4
Safeguards.
I am David Hard, subcommittoo chairman.
The
)
5 other ACRS members present today aro Mr. Eborsolo, Dr. Mark, s
]
6 Dr. Hylio.
I think Dr. Sioss will bo horo.
I don't know 1
3 7
if Mr. Micholson is hero or not.
j I
8 MR. EDERSOLE:
Ho's here.
9 MR. WARD:
The purposo of this mooting is to 10 review the document NUREG-1226, entitled "Dovolopment and j
11 Utilization of the NRC Policy Statomont on the Regulation j
12 of Advanced Nuclear Power Plants."
()
13 Dr. El-Zoftawy is the cognizant ACRS staff 14 member for this mooting.
}
t l
15 The rules for participation in today's mooting i
j 16 have boon announced as part of the notico of this mooting l
17 previously published in the Fodoral Registor on April 6, i
J 18 1987.
19 A transcript of the open portion of the mooting 20 is being kept and will be mado availablo as stated in tho 21 Federal Registor notico.
I request that each speaker first I
22 identify horself or himac1.f and npoak with sufficient i
23 clarity and volume no that sho or ho can bo.rondily heard, 24 Wo havo rocoived no writton ntatomonto from i
25 members of the public.
l l
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Uo have roccived no roquests for time to make 2
statomonts from members of the public.
i 3
It looks wo really have just enough agenda for
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4 half-day mooting.
I don't know if the members have planned j
5 on that, but at any rato I think we'll just work through i
6 lunch.
That might not be much of a burdon for us, if it 7
goes as quickly as Mod sooms to think it will.
j 8
Doos anyone have anything they would liko to say 1
j 9
before wo start with the agenda?
l 10 MR. EDERSOLE:
I havo road through this and I'm l
11 impressed as always about this limitless flow of words and 12 papers that comos out of a conferenco liko this.
It's liko O
13 e river that witt never run dry and annears to be orowino f
14 all the timo.
1
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15 But out of it, I thought we'd just put in front i
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16 of all this, a plea or philosophy of ovon loss proscriptivo I
17 controls to be put on the industry in tho ovolution of 18 those now machinos.
And out of that I can recall, and I'll 19 just cito a couplo of oxamplos, the uso as industry used it 20 of GDC-19 as a caso in point, whoro it was molusod in the 21 wrong direction, was nonconservativo and brought about j
22 onormous costs for firo protection in the control room 23 dosigns.
24 I can roca11 the dinoutor of the Fort St. Vrain L
25 plant and its prodoconsor because of the uno of water seals, iO l
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which is a proscriptivo detail which is going to have to be
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2 fixed if that over amounts to anything.
And out of it I 3
got -- nuro I agroo to a nonproscriptivo approach to thoso 4
things but only if wo faco the limitless burdon of I
5 regulation in high dotail presented to us at a timo beforo g
i 6
they fix the errors that tho industry may mako -- is too 7
costly which is tho experienco of the past.
I 8
In other words, wo havo lot them proceed with l
9 ambiguous constructions in the past, lot them cast in stool
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l 10 and concreto the mistakes, and then causo them to fix thoso 1
i 11 things backwards.
j 12 As long as they bring the information to the i O 13 reautatory proceee eariv enouoh and in sufficient detait i 1
j 14 don't have any problom with this pilo of paper but if they l
15 wait too lato, then wo'll bo in tho namo troublo wo aro in J
i j
16 today and that's disantor and if wo don't watch it wo 17 will again find oursolves on a son of regulation and detail
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10 that wo can't manago at all and that will cause this i
19 bureaucracy to extend boyond it's prosent point.
Maybo i
\\.
20 that's the purposo.
I don't know.
That's my roaction to j
21 this pile of papor.
Part of the proposed policy in to --
I 23 it sort of insists on early intoractions betwoon --
i 24 MR. EllCR80tts It doosn't say much about detail l
i 25 and the detail is a part of the regulatory procons.
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1 Because our past experionco has boon that's where the 2
troubles havo boon.
They como to us lato with detail and 3
wo havo built our plants which had absolutoly nolid mazo of 4
patchen on them to mako them, presumably, not with a great 5
deal of assuranco, safe in our view.
6 MR. WYLIE:
I've got a little difforont 7
interpretation of that in the fact that it doon requiro 8
adhoronco to the standardization policy statomont which 9
itnolf requiron detail of a comploto donign.
10 MR. EDERSOLE:
If it works out that way.
11 MR. UYLIE:
At least it infora that thoro will 12 bo sufficient detail to bo able to examino, as a cortified O
ta denica-14 MR. EUERSOLE:
The two dotaila I unod was the 15 donign of control rooms against tho background of GDC-19, 16 and than the millotono that dragged it to its donth or in 17 doing that.
10 MR. WYLIE:
Dut if that wan submittod an a 19 cortified donign in detail, why, that should havo boon 20 caught.
21 MR. EDERSOLE:
In the cano of GDC-19 thoro wan 22 toleranco on the part of the regulatory proconn to lot thom 23 got away with woll known offectn of the maldonignn that 24 worn offorud in that particular aron.
25 Thoro'n no quantion that wan a toleranco, and 1 ACi!.Fi:1)tinAi. Riti>onit:ns, INC.
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1 think an unwarranted one on the part of the regulators, to 2
lot tho industry tako a choap, no good approach to a 3
generalized critorion.
I don't know whether that attitudo l
4 is with us as much now as it was.
I'm not at all nure.
It j
5 kind of flows with tho adminiutrations.
6 MR. 11ARD:
I guosa I didn't quito maybo havo the i
7 namo improosion you do -- I just don't understand how the 8
standardization policy will apply horo.
It scomo tough to 9
try to standardizo a now invention.
10 MR. MICIIELSON:
A prototypo.
11 MR. IIARD:
And unwiso.
i 12 MR. liYLIC Ild t in offact it in proposed to O
13 adh-e to the stend-dizaeien ne cy.
n 14 MR. 11ARD:
In one placo I think the Staff i
15 ronponnon in that what wo really mean in that the donign i
16 nhould bo the nort of thing that could bo standardized.
17 MR. IlYLIE:
I've got a little -- maybo wo'll 18 hone about that.
19 MR. MICllELSON:
Thin in the thing that bothers 20 mo.
I had a groat doal of difficulty undoratanding how wo 21 woro going to be ablo to apply the ntandardization policy 22 to thin.
Yot it nooma to bo naying wo will.
23 I havo a groot doni of difficulty noning how you 24 nro ovon going to do o good job opplying the nnfoty gonin, l
25 n1though pronumably wo will.
And, in a littlo moro dotnil, l O 1
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for instanco, in the caso of the Appendix K revision, wo 1
2 don't really deal with gas-cooled roactors, et cotora, et I
3 cotora, in thinking about that.
Yet all that in a blankot l
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4 way, they koop saying is going to apply.
I just don't i
j 5
understand how wo are going to tako regulations that woro l
1 1
6 never writton for thin purposo and say they apply a.
j 7
Appondix K being a good examplo.
l I
0 lihat do you do for gan-cooled peak clad l
9 temperaturo, gan-cooled vornus wator roactor -- you havo to i
)
10 writo a difforont not of rulon.
lihat aro you going to do J
l j
11 about your codos and so forth?
It's an entirely different l
j 12 ball gamo.
You can do it but it hann't boon dono.
It's
!O 12 not et att cieer to me that it' evea inteaded te no done i
l 14 any timo soon.
And yot wo are going to liconno thono 1
15 donigns or cortify thom or comothing?
I think they ovon l
4 16 talked about cortification in horo nomowhoro.
i l
17 MR. IlYLIE:
Part of tho standardization policy.
i i
10 MR. MICilELSON:
llow aro wo going to cortify a l
l l
l 19 donign liko thin without avon having any background 4i 20 developmont work?
I don't know how to cortify a donign i
21 from tho viewpoint of ECCS for, nay, gan-coolod -- uning i
22 Appendix K.
i l
23 HR. Olit:RSOLE:
I have one other ntatomont.
I j
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24 Hn. IIARD:
Yon?
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l 25 MR. CHURSOLE:
I'm junt going to road a couplo l
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1 of nontoncon to quantion the commenta that NRC goon out to 2
got and the quality of the commento and I'm going to road 3
them an at least my view --
4 MR. SIESS:
A little loudor, Joano --
5 MR. EDERSOLE:
In my view an ovidence of the 6
quality they should improvo on "an problema of safety of 7
concern to the NRC havo very little probability of 8
occurrenco.
A prototypical plant demonstration will not bo 9
nuf ficient to provido proof of safoty; thoroforo, only 10 component proof of safoty may bo demonstrated."
If that i
l 11 isn't the craziont picco of advico I over hoard, I don't 6
12 know of ono that would be worno.
()
13 I'm bothorod, in other words, by tho quality of 14 tho advinary information.
15 HR. WARD:
Woll, no, thono aro -- the public in l
16 froo -- how can wo hold the NRC ronponniblo?
17 HR. EDERSOLE:
They haven't nerooned thono la thinga very wall.
19 HR. WARD:
Tom, are you ready to otraighton thin 1
20 out?
21 MR. KING:
I'm roady.
l 22 HR. WARD:
Why don't you go ahond, planno.
l 23 HR. KING:
My namo in Tom King, I'm with tho 24 Offico of Hononrch.
Maybo I ought to ntact off by 25 oxplaining wo aro in a now organization now.
Whoro
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1 advanced reactors fit and who the players aro, in the now i
2 organization.
I'm an acting branch chief for what's called I
i 3
the " Advanced Roactors Engincoring Issuon Branch" in tho
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4 new organization.
That branch in in the Division of i
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Regulatory Applications.
Bill Morris in the division i
j G
director, Zoltan Ronztoczy in his deputy and Dill Morris I
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7 reports to Dockjord.
i l
0 In my branch wo havo two noctions, ono dealing l
9 with gonoric insuon, ono with advanced roactors.
Jorry t
a 10 tilinon in the noction loador on tho advancod roactor 1
l 11 noction.
1 j
12 Thoro are allotted novon FTC -- novon peoplo to f
O i2 ue in that noction.
ilo havo eix on heard and eno vacancy 14 to fill.
f 15 ftR. HICllCLSON:
In that what in referrod to an 10 tho "advancud roactora group," in most of this?
Samo thing i
17 oxactly?
18 f tR. KING:
Yon.
Ilhonover you say " advanced l
1 i
l 19 roactorn group" that function in in that noction.
f 20 MR. EllCRSOLC llow many aro in that?
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21 ftR. KING:
Six on board and ono vacancy to E111.
22 tilt. llA R D :
And you alno havo ronponnibility for 1
23 all thu gonoric innuo work?
i i
24 Mll. KING:
Prioritization of gonoric innuon.
l 25 flit. OllCitHOLC lihat nort of fiold of connultantn
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I do you have, numerically, to help you out?
2 HR. KING:
llo havo two national laba, Oak Ridge 3
and Hrookhaven.
Thin year the funding at Brookhaven in 4
approximatoly $1 million and at Oak Ridge about S450,000.
5 It will got a little lonn for FY '80 becauno things will be j
6 winding down thoro.
7 MR. WARD:
So, I know it's off the subject, but 0
how many poopio are in tho gonoric innuon noction?
9 MR. KING:
In the gonoric innuun, thoro are i
10 novon -- fivo on board and two vacancion.
11 MR. IJARD:
The tank managorn for the action 12 plano, aro they in that group?
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nH. xinci r m na nuro wh a vou - a by m nx 14 managorn."
The peoplo who prioritizo gonoric innuon are in 15 the generic innuon noction.
I 16 MR. lIARD:
Dut whethor nomothing in boing workod 17 an tank A-44 or nomothing --
i 10 ftR. KING:
That in not in that noction.
That'n l
i 19 in one of the engincoring -- another division, an 20 ongincoring division.
3 i
21 MR. lIARD:
Thank you.
22 ftH. KING:
And and for an doing the review wo 23 will alno call on nupport from other divinionn, both within 24 runonrch and a littlo bit from NRR and NMUS in nupport of 25 thu roviow.
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1 The bulk of the roview in going to bo dono in 1
2 renonrch in the advanced roactora noction and with nomo 3
help f rom nomo of the other divinions within Roncarch.
f j
j 4
Mod suggonted wo alt,3 montion, maybe, futuro
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5 mootings.
I don't know if you want to do that now or do f
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6 that at tho ond.
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7 MR. UAllD Go ahoad.
l 0
MR. KING:
I know you are now as the chairman l
1 9
and I don't know whethor you wanted a nonnion to bring you 10 up to opcod on what thono donignn look like or what the L
4 11 review ntatintien or anything like that.
Wo don't havo j
l
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12 nuch a nonnion nchedulod at the prosent timo.
If you would
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O like one, we can -neduto one.
14 Currently what wo had pinnnod on was toward tho i
15 ond of FY '07, coming in and giving you the ntatun of our t
16 review and talking about the major innuon and the proponod 17 ronolutionn wo are coming up with for thono major innuun t
10 and thon, in rY '80, wo'd havo the draft DURN would bo nont I
l 19 to you for review and we'd havo como numbor of mootingn to i
l 20 review thono beforo they are nont to tt.o Comminulon.
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21 HR. Ell 0RUOLI:s 20, 25 yearn ago thoro woro a l
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22 varloty of oddball machinon built, nubnidized in part by
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23 000 o r Al'C.
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j 24 Do you nuo a roturn to that notion of fodoral i
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25 nubsidy to got thingn -- got the nucione option on the path i
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again, ovon to tho extont of building the right kind of LliR j
2 in competition with those now things?
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3 MR. KING:
Not under the curront administration, l
4 I don't.
1 5
MR. EHERSOLC:
Evorything in supponod to como 5
6 out of the profit noctor?
4 l
l 7
flR. KING:
lihat DOC in doing in funding tho l
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0 conceptual donigns.
Thoro'n a ponnibility they will fund l
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some of the conts of going through an application for n
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t 10 ntandard plant review.
They will fund nomo of the R&D but 11 their ponition, an I undoratand it, in the bulk of the r
12 funding to build a prototypo if ono noods to bo built --
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coniis0'c:
Oa a naver banin without the i
1 14 physical building?
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15 Hit. KING:
No.
Phynical building would havo to 16 bo pickod up by industry.
l 17 Mit. Enl:HSOLE:
The only chock they are going to 18 givo induntry in a warranty or guarantoo that they will 19 liconno it?
Or will they?
20 ftR. KING:
DOC 7 dol: can't givo them the l
21 quarantoo they will liconno it.
1 22 ttit. 1:UtitSOLE:
llow are they over going to como l
23 out of tho ground?
l l
24 flit. KING:
You aro anking a quantion but you 25 nhould havu a DOI: pornon to ank it to.
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MR. MICllCLSON:
Porhaps I misunderstood but I 2
thought you said DOE would holp financo the development of 3
dosigns, in other words they would help got it off tho 4
ground in tho nonno of contributing towardn designors and 5
perhaps R&D offorts but not phynical plant building; in l
6 that correct?
t 7
MR. KING:
They are funding the total cost of 0
the conceptual design offort.
9 MR. MICllELSON:
By " conceptual," though, what do 10 you monn?
11 MR. KING:
The work that's going on now, prior 12 to actually filing an application for a standard plan.
L O
nR. eiicRSOLe s
>>ue that' in areat detait o vou 14 could build it# right?
t 15 MR. KING:
Thoro'n quito a bit.
l 16 HR. MICllELSON:
Tank it difforontly.
If a group 17 of utilition got togethor and decidad to dovolop a comploto 10 donign that they could go out and start building, would DOC 19 fund any part of that?
Or in that a quantion that'a unfair, 20 from your viewpoint?
21 MR. KING:
You really should ank it of D00.
22 What DOC han nald their pronent ponition in they will not 23 fund the comploto program.
24 MR. MICllEL!10N Conceptually, you know, donign, 25 I can noo.
That'n hond and thinking but I wondorod if iXE Aci!.1'itoir.nAi. Riti>oit tiins, INC.
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was willing to go in and assist in detail development prior 2
to construction.
4 3
MR. KING:
They have said they will fund somo 4
R&D to support the plants but tho bulk of the funding, to i
5 got ono -- cither a prototype built or got one on line,
)
l 6
will have to bo put up by industry.
i 7
MR. MICl!ELSON:
What kind of monoy aro wo 4
8 talking about for DOE's budgets for the hond and process i
9 whatever it might be.
i l
10 MR. KING:
The funding for the throo plants, the j
11 IITGR fund in approximatoly $20 million a year, that 12 includos dosign and como R&D; the LMRs, I think it's in the j
l ()
13 noighborhood of $14 million a year, for thoso.
But thoro'n 14 a lot of bano technology R&D work, FTF funding --
l 15 MR. MICilELSON:
That won't buy very much of tho l
16 donign effort, by tho timo you havo dono somo phynical --
17 nomo laboratory offort as woll.
Okay.
Thank you.
10 MR. SIESS:
Tom, thoro's a connidorablo utility
[
1 19 intorost in the IITGR; GCRA.
I i
20 In thoro a comparablo intoront in the LMR or in 21 that atrictly DOE pushing that?
j 22 MR. KING:
I noo wo have a DOC repronontativo 1
j 23 horo.
Maybo ho might want to addroon that quantion.
Mark 24 Noran in horo from the DOE.
l 25 MR. NORAN:
I don't know if I can addronn it.
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1 What was the question?
2 MR. SIESS:
Thoro's a great deal of intorost or i
3 considerable interest by the utilities in the HTGR as 4
ovidenced by the GCRA group.
5 Is thoro anything liko that for the LMR?
Ilavo l
6 any of the utilities shown any intorost in building an LMR?
7 MR. NORAN:
I'm not aware of a similar intorost 1
l 0
but I'm really not the right person.
9 MR. SIESS:
DOE, then, is pushing the LMR7 10 MR. NORAN:
I really couldn't answer.
Wo don't i
11 have any -- any program DOE person here.
12 MR. WARD:
To respond to your earlier question,
()
13 I guess I'm a little familiar to the prosentations to the 14 full committoo with the concepts that are boing developod.
I 15 It sooms to mo that what you proposo for a mooting to givo a
]
16 us an update whoro things are going lator this year is 4
17 adequato.
18 MR. KING:
All right.
We'll plan on that.
19 MR. WARD:
Any other committoo members havo 20 anything?
All right.
21 Mod mentioned thoro's a workshop or somothing 22 next wook?
23 DR. EL-ZEFTAWY:
April 29th.
I 24 MR. KING:
Mr. Dockjord, sinco ho's now in tho j
25 organization han asked for a workshop with DOE and its
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1 contractors scheduled for Wednesday of next week to bring 2
him up to speed on what the designs look like and what-the-3 review efforts are that are under way.
4 MR. WARD:
Okay.
5 MR. KING:
Anyone is invited to attend that.
i 6
MR. WARD:
I won't be able to make.it.
That's 7
the reason -- maybe someone else from the subcommittee 4
8 would like to attend the meeting?
9 MR. WYLIE:
Next Wednesday.
10 MR. WARD:
Yes.
11 MR. WYLIE:
I'd like to.
12 MR. WARD:
Will you be out in Idaho?
()
13 MR. WYLIE:
No.
14 MR. WARD:
Okay.
I thought you were.
15 MR. WYLIE:
No.
I've got a problem.
16 MR. KING:
The location is at-the Marriott Hotel 17 in Gaithersburg, starting at 9:00 a.m.
if you want to 18 attend.
It's scheduled to last all day, to 4:00 or 5:00; 19 something like that.
20 The only other thing I want to mention before I' 21 start is the draft NUREG that we are going to talk about 1
4 22 today, the draft NUREG itself is not ready for public 23 release.
It's considered predecisional.
Certainly my 24 Vugraphs are releasable.
There's an appendix to the NUREG 25 which is just a copy of the advanced reactor policy
(
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1 statement which has already been issued to the public so 2
the appendix, there's no problem if the appendix is
+e j
3 released but the draft NUREG itself we ask that it not be 4
released to the public at this point.
5 MR. WARD:
Okay.
6 (Slide.)
7 To start off I'll give you a little background 8
to why we are talking -- what this NUREG is and why we are 9
talking about it today.
i 10 At the time the Commission issued the final 11 advanced reactor policy statement, which was in June of 12 last year, they asked the Staff to prepare a NUREG to
()
13 document the development of the policy statement to include 14 the revisions, in going from the initial proposed policy 15 back in '85 to the final July '86 version of the policy.
16 The Staff, in looking, putting that NUREG 17 together, also felt it would be useful if we expand it to 18 cover factors important to implementation of the policy 19 statement.
We discussed expanding the NUREG in that 20 fashion with OPE and with members of the Commissioners' 21 staffs and got agreement that, yes, we could go ahead and 22 make it -- the NUREG address both of those subjects.
So 23 the NUREG today that you are looking at has on the first i
24 half basically a summary of public comments and the 25 development of the policy statement and the last half deals ACE FEDERAL REPORTERS, INC.-
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with the implementation factors, dealing with 2
implementation.
3 (Slide.)
4 At the time the Commission was considering 5
issuing the policy statement there were two meetings with 6
ACRS to review the policy statement itself.
One is 7
subcommittee meeting in September of '85 and then a full 8
committee meeting in October of
'85.
We, at that time, 9
discussed the development of the policy statement, the 10 public comments, the disposition of those public comments, 11 the changes that we made in going from the proposed to the 12 final policy.
ACRS issued a letter on October 16,
'85,
()
13 supporting the final policy statement.-
14 I don't intend to go back and, today, revisit 15 the development of the policy statement.
He have done that.
16 The policy is out.
I don't think -- I'd rather concentrate 17 on the factors dealing with implementation today.
I just 18 wanted to mention that up front.
19 (Slide.)
20 To quickly hit it again, the_ purpose of the 21 NUREG was to document the development of the policy.
22 That's one half.
The second half is to provide guidance 23 regarding implementation of the policy statement.
It 24 basically hits five subjects.
25 We talk about, in a little more detail than the O
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policy statement talks about, what reactors are considered 2
advanced reactors; what the Staff review approach is going 3
to be; the --
4 MR. MICHELSON:
On this question of what 4
5 reactors -- are you going to talk later about what reactors 6
you think fall into this and why others don't?
From the wording of the policy statement it's not clear to me what 7
1 8
falls in.
9 MR. KING:
I have a slide that talks about our i
10 proposed definition or proposed words in there.
We'll come 11 to that.
j 12 MR. MICHELSON:
Thank you.
()
13 MR. KING:
We have a section in the NUREG on the 14 applicability of related Commission policies and practices; 15 some guidance on what our information needs are; and, maybe 16 most importantly, I want to stress that this NUREG is not 17 directed towards specifically the three DOS designs.
This 18 is to be generic guidance that the Staff would follow for 19 any design; DOE designs or anybody else that comes in with 20 a design that we agree to review.
21 MR. MICHELSON :
Is it a good place to tell me 22 whether or not this covers certain kinds of light water 23 reactors?
24 MR. KING:
Yes.
I think --
25 MR. MICHELSON:
It does appear to but why
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doesn't it cover all innovative light water designs?
By 2
" innovative" I mean four-train versus two-train or other 3
kinds of changes.
It's not clear where this thing cuts off.
4 MR. KING:
When we get to the definition of 5
" advanced reactors" let's talk about that.
6 MR. SIESS:
Will you cover CANDU?
7 MR. KING:
Well, you asked me that before and I 8
told you I don't know much about CANDU.
9 MR. SIESS:
If you don't know much about it it 10 must be advanced?
11 MR. EBERSOLE:
The ABWR?
12 MR. KING:
No.
()
13 MR. MICHELSON:
You can't tell from reading that 14 document that ABWR is not covered.
15 MR. SIESS:
16 MR. MICHELSON:
I think Westinghouse's might be 17 also.
18 MR. EBERSOLE:
Why shouldn't it cover that?
Why 19 shouldn't they be considered in direct competition with 20 each other?
21 MR. KING:
ABUR, the SP-90 plants and CBA PWR 22 all considered --
23 MR. EBERSOLE:
Don't speak of that one.
24 MR. KING:
They are all considered evolutionary 25 designs that still the requirements are tied very closely i
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1 to the standard review plan and we feel that this policy, 2
the advanced reactor policy, the review we are doing, are i
3 for designs that are not tied closely to the standard 4
review plan.
i 5
MR. MICHELSON:
But when people put integral 6
pumps into the pressure vessels and so forth, that's not 7
considered now innovative or advanced or something?
We 8
don't do it in this country at all yet.
9 MR. KING:
No.
Other people in the world do it.
10 MR. MICHELSON:
Yet it seems ABWR is not covered 11 yet it appears to me it would be quite innovative.
I 12 MR. WARD:
I guess the argument is the body, you
()
13 know -- most of the body of present regulation applies --
14 you can see your way applying it to ABWR and APWR.
I 15 MR. MICHELSON:
True.
16 MR. KING:
That's basically what we have come up 1
17 with.
18 MR. MICHELSON:
If you write a definition that 19 says if you write a design that doesn't fit our regulations 20 this is the policy that covers it, it doesn't say that.
21 MR. KING:
Well, maybe we ought to talk about 22 that.
It's intended to say that.
23 If a design -- if the requirements of the i
24 standard review plan apply to that design, you know, pretty 25 much in total -- maybe some minor areas or some areas where
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you might have to make a change -- but if pretty much the 2
bulk of the standard review plan requirements apply to 3
design it does not fall in the category _of an advanced reactor under the definition we are proposing.
4 5
MR. MICHELSON:
That I could understand.
6 MR. EBERSOLE:
Does that mean there will be new 7
standard review plans.for advanced reactors?
8 MR. MICHELSON:
I suspect --
9 MR. KING:
It's not at this point our plan to l
10 write a new standard review plan for advanced reactors 11 because it takes a lot of resources to do that and we don't 12 know what the future of these will be.
If these really
, ()
13 catch on and people are going to buy them we may want to 14 rite them.
15 MR. MICHELSON:
You say PIAS doesn't fit our 16 standard review plan -- I don't see that.
I think I can 17 ta'ke the standard review plan and pretty well apply it for 18 PIAS.
i 19 MR. KING:
I disagree with you.
But --
20 MR. MICHELSON:
Just as well as I could for APWR.
I 21 MR. EBERSOLE:
I would like to have you
/
22 criticize what I'm about to say.
The standard review plan 4
23 was a patch in its own right, the whole idea.
It was a 24 patch to say, in extrapolated detail:
This is what I meant 25 by general criteria, et cetera, et cetera, all those l
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general body of regulations that preceded the standard 2
review.
Because this says to the industry:
Uatch it, 3
follows, this is how I'm going to look at your detailed 4
plant.
It is kind of a negative set of prescriptive 5
requirements.
6 MR. KING:
It was written with'the current 7
generation PURs and BURS in mind.
8 MR. EBERSOLE:
But it was written in defense of 9
the fact that plants were coming out of,the ground in all 10 shapes and sizes and irrational design details and this was 11 really to narrow the scope of the nonprescriptive 12 regulations.
It says I'm going to review them in certain
()
13 levels of detail if I don't find this or if I find that 14 wrong I'm going to cause you to fix it.
You are going to 15 have to do something like that with the new plants.
16 MR. KING:
At this point I think it's premature 17 to decide what we are going to do with new plants until wo 18 see where they are going.
19 At this plant we ought to mention the advanced 20 reactor policies are really directed at reviews at the 21 preapplication stage, conceptual station; to give early 22 guidance, early interactions and early guidance to 23 designers on what the requirements would be for new designs 24 where the standard review plan or major portions of the 25 standard review plan do not apply.
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()
1 MR. MICHELSON:
Why can we even consider 2
standardization then as part of this policy, which it does j
3 seem to do?
I don't think you can ever standardize at that j
4 stage of the game.
5 MR. KING:
It doesn't say we are standardizing 6
at the conceptual design stage.
All it says is in your i
7 plans for these advanced plants, let's talk, let's think 8
about standardized plants.
Let's not think about 9
one-of-a-kind plants.
We want to see for your long-range I
}
a l
10 plans that you are shooting for standardized plants.
It t
{
11 doesn't say we are standardizing at conceptual design stage.
9 l
12 There's probably a lot of design evolution that has to take
()
13 place but we would like to see either long range plans be 14 directed towards coming up with standard-plants.
That's i
15 wait is intended to say.
16 MR. EBERSOLE:
That's what's intended.
17 MR. KING:
We've already hit most of this.
1 j
18 (Slide.)
19 It's directed towards preapplication stage 20 reviews or conceptual design reviews.
We plan to document j
21 reviews of advanced plants at this preapplication stage, i
I l
22 via an SER, which we are now in the Office of Research, we i
i 23 will ask for NRR concurrence.
Certainly for the first l
l 24 three the DOE designs, the Commission has asked to see the 25 SER before it is formally issued.
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1 MR. EBERSOLE:
What does "NRC concurrence mean"?
j e
2 MR. KING:
NRR concurrence.
3 MR. EBERSOLE:
NRR.
Okay.
I
)
4 MR. KING:
That means we in Research are going l
5 to come up with a draft SER.
6 MR. EBERSOLE:
That says you are now permitted l'
j 7
to do what?
Proceed to design or build or what?
l 8
MR. KING:
No, it means here is licensing 9
guidance for future plans to be contained in this SER.
j, j
10 MR. EBERSOLE:
That's even preliminary to the i
11 preliminary?
1 12 MR. KING:
It's guidance at the conceptual
()
13 design stage to when these des'igners proceed on -- they 14 have a fairly good understanding of what the licensing 1
15 requirements are.
j 16 MR. WARD:
This is your formal reaction to it.
i 17 MR. EBERSOLE:
Will that have the quality of l
j 18 detail or warnings that are contained in present standard-i~
19 review plan terminology, if you don't do it this way we are 20 going to cause trouble?
i 21 MR. KING:
That might be very design-specific.
22 I can't say at this point.
If we find something that is i
23 just what we feel is totally unacceptable, yes, we will say i
j 24 that.
I think you'll have to wait and see what the SERs e
l 25 look like before we can answer that.
i i
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l MR. HARD:
Tom, the Staff review of an advanced 2
reactor conceptual design, this is at the level that PRISM 3
and SAFR are now or are going to be in?
That's what you 4
are starting on now for those three plants and this is the 5
general scheme that you have for all conceptual designs 6
coming from wherever in the next few years?
7 MR. KING:
This is generally how we would intend 8
to document the review.
i 9
MR. WARD:
So the advanced design is presented 10 to you in what, a five-foot shelf of books?
Or a two-foot 11 shelf of books?
12 MR. KING:
Two or three notebooks is what it
()
13 turned out to be for the three DOE plants.
Med will give 14 you a copy if you don't have a copy of it.
15 MR. SIESS:
That's the PSIDs?
16 MR. KING:
For the DOE plants we call them PSIDs.
17 Ue may not call them that for every plant but that's 18 generally what we had in mind, that level of detail, that 19 size of documentation.
20 MR. WYLIE:
Let me ask you, where you say " Staff 21 review of advanced reactor" -- now, considering the NUREG 22 in the standardization policy section, you say " advanced 23 reactor," this is intended to be consistent with the 24 Commission's policy for a total plant submittal?
25 MR. KING:
First, I probably should state ACE FEDERAL REPORTERS, INC.
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}
j 30692.0 27 1
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1
" advanced reactor conceptual design."
2 The second thing that the draft NUREG does ask j
3 for is when someone sends in an advanced reactor conceptual i
4 design they sends in the design for the whole plant, not l
5 just a piece of it.
We asked for that under the section 4
l 6
that deals with standardization.
7 MR. WYLIE:
That's intent is it?
Total plant?
1 8
MR. KING:
Total pl' ant.
i 9
MR. WARD:
And that's what those require, there?
10 MR. KING:
Yes, they design the total plant.
4 j
11 MR. EBERSOLE:
A little earlier I referred to l
12 two interpretations, one, GDC-19 and the fiasco that came
()
13 from that that resulted in the new fire standards and a l
14 design detail of the Fort St. Vrain which is the water l
15 buffered seal which is really the death knell of that j
16 project at this stage review would be nowhere near picking i
j 17 up that level of detail, wouldn't it?
j 18 MR. KING:
Yes, it would.
We specifically
)
19 looked up the MHTGR review if they had water-cooled j
20 bearings on their circulators.
We want to learn from j
}
21 operating experience and make sure that's factored in early 22 on in the design.
23 MR. EBERSOLE:
You know GDC-19, what I mean,
)
24 that says you have to shut down the plant with nobody in l
25 the control room and no damage.
That was the first 4
i 3
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interpretation.
2 MR. KING:
All three designs are proposing 3
nonsafety grade control rooms and reduced operator 4
responsibilities and actions and we are looking at those 5
questions.
6 MR. EBERSOLE:
Okay.
7 MR. KING:
When we are all done reviewing the 8
conceptual designs the real intent of our SER is to provide 9
guidance to the designers but also it is intended to form 10 the basis for performing an actual licensing review.
11 Someone would take one of these conceptual designs, turn it 12 into a preliminary or final design and come back in here
()
13 for formal application, the intent would be we wouldn't 14 start from ground zero again, we would build upon what has 15 boon developed in the review at the conceptual design stage 16 in terms of licensing requirements, Staff position and that 17 kind of thing.
18 MR. EBERSOLE:
I read in here that every 19 consideration is given to walkaway designs.
I take it you 20 are really going to look hard at full automation?
21 MR. KING:
Yes.
He are looking -- the designs --
22 you are talking about the three DOE designs that are being j
23 proposed as eliminating as much as possible operator 24 actions.
25 MR. EBERSOLE:
llave you got, and I hope you are ACE FEDERAL. REPORTERS, INC.
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1 going to say yes or will produce it, a set of guides that 2
says:
When you automate and when you do not?
And the 3
reasons for so doing?
To start with, the basis for the 4
judgment when you automate and when you do not?
5 MR. KING:
I'm not sure we are going to produce 6
that document.
7 MR. EBERSOLE:
How can you not?
8 MR. KING:
We are looking at the DOE plants what 9
is proposed, and we'll determine what is acceptable --
1 10 MR. EBERSOLE:
But that's a bottom up?
When do 11 I automate?
When do I not?
12 MR. KING:
We are looking at what is proposed by
()
13 the designers.
14 MR. EBERSOLE:
It's sorts of a low level safety 15 goal --
16 MR. SIESS:
Jesse, you don't need to have 17 automation to have walkaway capabilities.
It's one way of 10 getting it.
19 MR. EBERSOLE:
It's one way because I suspect it 20 will have to be the way.
I'm not sure.
You are talking 21 about PIAS.
22 MR. SIESS:
Low enough core temperatures --
23 MR. EBERSOLE:
Yes.
It may be.
I wonder.
24 MR. SIESS:
Just sit there and let it boil.
25 MR. MICHELSON:
Look at NUREG-1226, it appears O
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that there is kind of a two-stage licensing process being 4
j 2
defined here, although I never found it explicitly stated.
i-i 3
In some parts you talk about conceptual design 4
4 stage and in other parts you talk about design approval and 1
5 certification.
3 6
Those -- in the conceptual case, yes, you can i
j 7
take a lot of handwaving and whatever but I'm not sure that 8
you ever do any kind of approval or certification on the j
9 concept but maybe you can clarify that.
1 l
10 But is there indeed sort of a 2-stop process we 11 are talking about here?
You are going to look at concepts 1
I 12 just for interest and then later you'll get serious when
()
13 they come in for design certification?
For approval?
14 It is not explicitly stated but you keep 15 throwing those two terms into the wording.
Many times in I
16 the same paragraph.
And it looks like it's a two-stage d
f 17 process of some sort, although you are not really outlining 18 it that way.
)
i 19 MR. KING:
I think when you look at the whole --
1 j
20 going from developing an advanced design through to the i
i j
21 point where we actually get it licensed and built, it j
l 22 probably is a two-step, maybe a three-step process, if you I
i 23 consider a CP in an OL station.
1 24 imat we're talking about is the first step.
11e i
25 are looking at the plant before they come in for an actual i
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license application and we are developing some guidance at 2
that point that designers can use.
3 MR. MICHELSON:
What kind of commitments does 4
the agency make in terms of what it will accept, at the 5
conceptual design stage where you are still pretty fuzzy on 6
the details?
Are you giving any kind of commitments about 7
accepting the -- certain aspects of the detail design when 8
it comes in?
9 MR. KING:
We hope to be able to say:
Designs 10 will be licensable provided the following.
Maybe some 11 things have to be demonstrated.
Maybe some additional j
12 information provided.
()
13 MR. MICHELSON:
It's not clear reading this 14 document how much you have to have at the conceptual stage 15 in order to make such statements concerning the detail 16 stage when it comes in.
It is not clear because that's now 17 a two-step process and I thought it was a one-step process.
18 MR. WARD:
What are you saying, Carl?
Let's say 19 the Staff agrees, seems to agree to something in the SER i
20 he's talking about here.
21 MR. MICHELSON:
In the conceptual stage.
l 22 MR. WARD:
But then when they see it more fully 23 developed they change their minds?
1 24 MR. MICHELSON:
They may want to change their 25 mind.
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MR. WARD:
Or maybe there's some new information 2
outside that causes them to change their mind.
3 MR. MICHELSON:
It's not clear to me how this 4
process works.
5 MR. WARD:
IMat's going to happen?
Is the 6
Applicant going to take you to court at that time or is the 7
Applicant going to expect that sort of thing?
Is that the 8
question?
9 MR. MICHELSON:
That's the idea, basically.
10 MR. KING:
There's no legal binding outcome of 11 this review like there would be from a CP or OL review.
12 But the intent is to try and converge as much as possibic
()
13 as we can at this point.
There's always the option that 14 maybe later on new information will surf ace and we have to 15 change our mind.
That's always a possibility.
16 MR. MICHELSON:
How much information do you want 17 at the conceptual stage to get those kind of preliminary 18 approvals.
It's not in this document what you want at 19 conceptual stage.
20 MR. KING:
I think you have a good point.
We 21 perhaps need to put in a better definition of what we need' 22 to see at this point.
We do call for a full scope PRA, and 23 for reviewing the entire plant.
24 MR. MICHELSON:
I don't know how you can do that 25 at the conceptual stage unless your concept is different ace FEDERAL REPORTERS, INC.
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2 MR. KING:
It's at the design stago.
It 3
wouldn't get into the detailed modeling breakers and 4
instrument lines and things that haven't boon set yet at 1
5 conceptual design stage but it could model in a broader 6
senso, systems and major components, accident scenarios.
t 7
MR. MICllELSON:
If you would put in a definition 8
of what you expect to soo at the conceptual design stage in 9
order to give some of those preliminary approvals with some i
10 certainty that they will stick, that would be very helpful.
11 To me I could never find it in this document.
12 MR. KING:
I think you have a good point and I
()
13 do, I think I want to look at it again and soo if we can 14 botter define what it is wo need to sco.
15 MR. M ICilELSON :
But it is sort of a two-stage 16 thing, then, that you have in mind.
You expect the utility l
17 to come in with a concept developed far enough so that you I
18 could say yes, this concept looks liko we could probably 19 licenso it, send me the details?
20 MR. KING:
Yes.
The policy was to have that 21 carly interaction and then that would be followed by the 22 formal application process.
1 23 MR. EBERSOLE:
To look back a little bit into j
24 history, it is just absolutoly astonishing to recall the 25 immaturity of the licensing prospects -- say along about C) i i
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'72, when somebody wrote up here and says you better look 2
out for pipes that break outside of containment.
And that 3
had not even been thought of to look at by most designers.
4 I'm just trying to get a little depth of 5
perspective into this.
You certainly are not going to 6
leave laying aside any such fundamental things as that.
7 There's a lesson there.
8 MR. KING:
Definitely not.
9 MR. EBERSOLE:
There's a lesson there how far
}
10 you can go and be so blind.
I 11 MR. KING:
One of the things that's coming out i
12 of the three DOE plants, trying to concentrate their safety
!O 13 ereteme in the nuc1eer te1end, ther ere tryina to uee 14 passive safety systems, and trying to take a lot of these i
15 balance of plant systems and say they have no safety 16 function.
That's certainly one of the key things we need 17 to look at.
18 MR. EBERSOLE:
Are they going to get the I
19 afterheat out no matter what?
20 MR. KING:
The intent is not to, you know,
)
21 restrict our review just to what DOE says is a safety 22 system.
He are going to look at the whole plant and see is t
23 that really logical to do it that way or should it be done i
i 24 differently?
25 MR. EBERSOLE:
That's the way they ought to do o
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it.
That other stuff ought to never have to operato.
2 MR. WARD:
Lot me ask you a couple of questions, 3
Tom.
l 4
If you were to try to define more explicitly j
5 what Carl is asking for, the scopo of the detail that would 6
be in this design concept -- concept description -- are you 1
7 satisfied that the throo DOE plant descriptions are 8
adequato in scope and detail for that?
9 In other words, if you are going to try to writo 10 down some definition of that, would you be just trying to 11 capture what evolved or somohow was the level of detail in 12 the scope that was reached for those three studios?
Is
()
13 that about right?
Or after doing that have you got some i
14 misgivings one way or the other?
2 15 MR. KING:
Wo have gono far enough in the review 16 of the HTGR that we've developed a number of roquests for i
17 additional information.
I think betwoon what DOE submitted i
18 and what wo are finding out we nood in terms of additional 19 information, we could take those two and como up with a 20 fairly docent definition of what we would liko to say.
21 It has sort of boon an iterativo process in tho l
22 beginning but we are far enough along now I think to como 23 up with a fairly decent definition.
24 MR. MICHELSON:
Would you say that is tho l
25 conceptual design stage that they are at now then, in other 3
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words?
I 2
MR. KING:
Yos.
l 3
MR. MICliELSON:
In the IITGR caso?
4 MR. KING:
Ye s.
5 MR. !!ICI!ELSON:
Because I was worried you might 1
6 think that was the detail design stago, for instanco, which j
7 would give mo a little problem.
8 MR. KING:
No.
Conceptual design stago.
9 MR. WARD:
I think those books up thero on the l
10 shelf are about the lovel, although he's got somo --
J 11 MR. MICIIELSON:
What's the difference betwoon a l
12 PSAR and FSAR procobs is -- I don't know.
I consider that
()
13 an FSAR process.
1' 14 MR. KING:
About 10 or 15 more notebooks.
15 MR. WARD:
They are doing this earlier than PSAR.
16 MR. MICf!ELSON:
That's about what you used to 17 got PSAR at one timo.
Now you got a lot more.
In the 18 carly days it was a two-volume sot, in fact.
19 MR. EBERSOLE:
Romomber wo have somo designa 20 today liko Westinghouso that invado the safoty systems 21 ovory time they trip, namely the aux food water systems.
22 We have other moro prudently designed plants that don't do 23 that.
Are you going to include in this now conceptual 24 design area some controls ovor the design which sa'ys I will 25 not invado an acceptablo degroo of rodundancy on a routino 1
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basis?
I will hold them in reservo for the true emergency?
2 Do you follow me?
3 MR. KING:
Ye s.
All the designs do hold thoso 4
in reservo.
They aro not used overy timo.
5 MR. EBERSOLE:
They are going to be testod 6
frequently but not in a way to porturb the routino 7
operation of the plant and therefore invite the value in 8
the course of testing?
9 MR. KING:
We are certainly considoring testing 10 to verify they are operable, certainly considering how 11 often they are challenged.
But what we are looking at for 12 the designs, we are looking at what is proposed for those
()
13 and we'll give some foodback on that.
We are not planning 14 at this time to como up with some generic guidanco to apply 15 to any plant.
16 MR. EBERSOLE:
Right now the testing process 17 itself is as serious a challongo to safety as anything olso 18 the way wo test them.
Wo throw the plant into transients 19 more often by testing than anything else.
20 MR. KING:
Testing is cortainly one of the 21 things looked at.
What can you do to verify thoso 22 passively in an ultimato line of defonso system.
23 MR. WARD:
Ono moro question.
On the chart here, 24 when you talk about, before you issue an SER, NRR 25 concurronco, and then Commission review, maybe you told us O
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but I didn't catch it.
What do you mean by " Commission 2
review"?
3 MR. KING:
For the throo DOE plants the 4
Commission has asked to soo the SER that we writo on each 4
5 of those before wo formally issue it.
Because it involves 6
-- thoso reviews involve some major decisions, with policy 7
implications:
No containment building, for examplo; no 8
omorgency ovacuation plan.
They would like to soo what the 9
Staff is coming up with before wo put it on the stroot.
I 10 They have asked for that and I think that's good because wo 11 want to make sure when this work is'dono and this SER is i
12 issued, that it carries somo weight, that wo just haven't O
12 weeted eur time.
I think or seeties the NRR concurrence 14 and getting the Commission to look at it when it finally 15 comes out it will be an agency position, not just a j
16 research offico position.
i 17 MR. WARD:
Well, that's good.
18 MR. KING:
That's the intent.
19 MR. MICllELSON:
Question on your last.
When you 20 say when an application is filed did you mean application 21 for design cortification approval and application or an j
22 application to build a plant?
23 MR. KING:
Either one.
A formal application.
l 24 MR. MICllELSON:
Because the first SER in tho 25 previous bullot was -- that's the conceptual design SER, I
+
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assumo?
2 MR. KING:
Yes.
Yes.
3 MR. MICHELSON:
Now the next bullet is the 4
detailed design and cortification SER?
It would have to bo 5
another one written for that purposo I assumo?
6 MR. KING:
If that happens there would have to 7
be another SER.
4 a
l 8
MR. MICilELSON:
I think I'm finally getting f
9 thero.
Thank you.
10 (Slido.)
11 MR. KING:
Okay.
This is just a slido on the 12 status whero wo stand on this:
Develop the NUREG, send it O
12 out ror tatersei review in NRR Reseerch, OGC, we heve 14 gotton comments back.
All the parties that we have sont it i
15 to -- wo are hero today, as the first stop towards getting 16 your review.
Wo would like a lottor on what you think of J
17 the draft NUREG.
18 I understand you would like possibly at the next i
19 full committoo mooting to havo this subject put on the 20 agonda?
21 MR. WARD:
Yos.
Lot's assume that for now.
22 MR. KING:
We'll do that.
23 After wo got your review we plan to send this 4
j 24 NUREG to CRGR for thoir review and then, after going i
25 through CRGR, the Commissionors have asked to soo it before
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1 it is formally issued.
2 It's sort of follow the same steps that 3
NUREG-1225 is taking for the one that implomonts the 4
Commission's policy on standardization.
They have asked to i
1 5
soo that one and it's down thoro for review.
This is t
6 following the same stops.
7 The Commission may issue it for public comment, 8
I don't know.
We'll soo what they do with it but we hopo 9
sometimo toward the end of May to havo the draft NUREG to j
10 CRGR, and then hopefully in a few wooks they will act on it 11 and got it to the Commission sometimo this summer.
I i
12 That's a rough idea of the status.
l
()
13 (Slide.)
t 14 Uo sont it out for Roscarch review, this is a i
15 summary of the comments wo got back.
16 Ono version didn't talk about foos at all; wo i
17 add somo words that banically say this is proapplication i
l 18 review that will not be a -- thoro will not be a foo 19 charged for that.
1 l
20 Ho have a comment on the extent to which l
21 oxisting licensing critoria are to be used.
Wo want to 22 oxpand what's in thoro to basically state we want to build 23 on DiR critoria.
Wo don't want to throw out ovarything 24 that has boon developed for the last 30 years and start j
25 again.
Uhoro it's practical to uso something that has boon 1
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V 1
developed for LUR plants we plan to uso it, given that 2
guidance to the advanced reactor designers.
This NUREG 3
would document that as generic guidance and therefore 4
develop for the unique characteristics of an advanced 5
design, develop the guidance for that.
6 MR. MICHELSON:
llow are you going to decide when 7
you need some new criteria?
It says "where feasible, use 8
what you've got."
Who decidos it's feasible to uso it and 9
where it isn't feasible and so forth?
Is that just going IC to be an evolutionary process of some sort?
11 MR. KING:
It's going to be an evoluti.onary 12 process but we asked the designers to take a crack at that
(~l 13 in that submitted and then as we review it in the design (j
14 stage the SER will address that.
15 MR. MICHELSON:
Right now you do not intend to i
16 l formulato a new not for this purpose?
You are going to try 17 the old set first?
10 MR. KING:
Uo do not intend to como up with a 19 new set of GECs for advanced plants or standard review plan 20 or anything like that.
21 MR. MICHELSON:
In a specific case just as an 22 example, what are you going to do about coro cooling 23 calculations based on our prosent Appendix K and so forth?
24 MR. KING:
Appendix K would not apply.
25 MR. MICHELSON:
llow are you going to handlo that rm.
(-)
Acti.I;i:i)tinai. Ill:Pouliins, INC.
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situation kooping in mind the enormity of the expense of 2
doing all the R&D of such research for light water, lot 3
alono gas-coolod.
4 MR. KING:
Appendix K will not apply.
5 MR. MICHELSON:
How are you going to handle that?
6 MR. KING:
Appendix K will not apply to any of 7
those three designs.
8 MR. MICHELSON:
Isn't that the heart of this?
9 MR. KING:
Yes.
Keeping the fuel at a certain 10 temperaturo -- this is the heart of the whole business.
11 For each of the three designs, critoria and data to support 12 those critoria are being proposed.to maintain fuel
[
()
13 integrity.
14 MR. MICHELSON:
How long do you think it's going 15 to tako whero we've ggt some even reasonable assurance that l
16 wo can do thoso calculations for an advanced reactor?
How 17 much R&D of fort do you think it's going to take to got that 18 reasonablo assuranco?
It's going to take two things, timo 19 and money.
1 20 MR. KING:
Loss than for LWRs because you havo i
r 21 to remember wo are not in a two-phase flow situation.
l 22 MR. MICHELSON:
I don't want to got into the 23 dotails.
Any way you slico it it's going to get a lot of I
24 timo and money to got the confidenco that wo prosently havo 25 in our Appendix K.
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MR. KING:
What we are looking at for the DOE 2
designs their proposal to what the criteria should be, 3
equivalent to Appendix K, and their plans to develop the 4
data base to support those criteria and we will look at the 5
criteria and plans to develop the data base and provide 6
some guidance at this stage as to whether that looks 7
adequate or not adequate.
8 MR. MICHELSON:
Keeping it as a caveat on the 9
license certification process?
10 MR. KING:
But the burden is on the licensee to 11 develop the data that's needed to support the fuel i
12 integrity criteria, for example.
()
13 MR. SIESS:
Carl, part of the problem is your 14 confidence level is usually higher before you spend all 15 that time and money.
16 MR. MICHELSON:
That's right.
You don't really 17 know what your problems are until you put those things up 18 and some have been done, of course but it's still --
19 MR. SIESS:
You have EPR-2 --
20 MR. MARK:
And Fort St. Vrain.
All that I
21 arithmetic is done.
22 MR. MICHELSON:
I don't think you'll find that 23 so.
24 MR. EDERSOLE:
On your second bullet do you have 25 any to add to 6.5.3.1 on the second bullet?
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~
l MR. KING:
Here now?
2 MR. EBERSOLE:
Are-you going to say about the-3 single failure criteria,'for instance?.Do you know yet?
d 4
MR. KING:
I think we'are basically going to say-5 it applies.
4 6
MR. EBERSOLE:
Is that all?
7 MR. KING:
I don't have words to give you today.
8 MR. EBERSOLE:
I-thought that surely had been 9
condemned since we have great numbers of examples of 10 failure of the single failure criteria.- Look at 11 Davis-Besse.
Are you going to let that prevail or do you 12 suggest changing it?
Make some more words.
()
13 MR. KING:
I don't have the words yet that are 14 going to be inserted in that section.
15 MR. EBERSOLE:
That's what I would rather hear 16 you say.
17 MR. KING:
What I was going to propose is, 18 hopefully by next week I'd have a version put together that 19 incorporates these comments, incorporates anything that 20 comes out of today's meeting.
I'm going to propose that we 21 try and get that to you before the full committee meeting.
22 MR. EBERSOLE:
The-only one of the commissioners 23 th'at took much of a look and interest at this was 24 asselstine.
He really bore into it.
25 MR. MICHELSON:
Under the severe accident policy ace-FEDERAL REPORTERS, INC.
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'/
'o 1
as it relates to these designs how are you going to view 2
the potential rupture, say, of a liquid metal pipe?
Are 3
- you going to declare that just simply incredible, 10 to the 1
4 minus 12 probability?
Or are.y(u going to-deal with the 5
consequence of a liquid metal line, rupture?
6 MR. KING:
Yes.
e
+
]
7 MR. MICHELSON:
And you'are going to deal with 8(
the fire and so forth?
I 9
MR. KING: !Yes.
l 10 MR. MICHELSON:
That will be a requirement that i
' 11 they rupture a pipe and do at-least a severe accident j'
12 analysis?
O 13 MR. x1no:
ror the two oos 11auid mete 1e 9 ente 1
14 we are looking at now the entire primary system is inside 15 the pot so it does'nt' matter.
They do assume the primary 16 pipe fully ruptures in here as part of the design basis or 17 accident analysis.
18 For the intermediate system where you are going 19 outside the containment, outside, they are also assuming a 20 full guillotine rupture and the fire protection features l
21 are being proposed to deal with that full rupture.
i.
l 22 MR.,MiCHELSON:
It seems like you'd almost have 23 to.
24 MR. KING:
The other alternative is make a 25
' leak-before-break like on Clinch River.
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1 MR. MICHELSON:
You are not smart enough yet on 2
liquid metal.
3 MR. KING:
We accepted it on Clinch River.
4 There was at the time the judgment that the fracture 5
mechanics data base was sufficient to support it.
6 MR. MICHELSON:
There's always this exception 7
like corrosion, stress type corrosion and so forth.
If 8
those exist than you don't use it.
You'd have to be 9
assured that no such mechanisms exist and maybe we have 10 enough data base now.
11 We thought we were smart on water 10 years ago, 12 too, and sure learned a lot in the last 10 years.
()
13 MR. WARD:
Chet?
14 MR. SIESS:
Tom, you could do the profession a 15 real service if you could get down some good points on 16 defense in depth.
Everybody uses the words and they don't 17 always mean the same thing by it.
4 18 MR. KIhG:
Yes.
1 19 MR. SIES3:
You have a suggestion of it here.
i j
20 Some people are talking about defense in depth as being the 1
21 multiple barriers, cladding and vessels -- others talk 22 about prevention versus mitigation.
They are all sorts of i
23 different meanings of it and I hope you wouldn't try to I
24 come up with just one but maybe list as many as people are i
25 using.
It's a catch-all expression.
It sounds good.
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1 MR. KING:
My intent is to define what I mean by 2
" defense in depth," the considerations that go into it, 3
multiple barriers, backup systems, prevention versus 4
mitigation.
The intent is to address those alternatives --
5 MR. SIESS:
As alternatives?
6 MR. KING:
They are all considerations.
7 MR. SIESS:
You lump them altogether as being 8
defensive, then?
Multiple margins?
Multiple conservatisms?
9 Do you consider Appendix K with conservatism 10 piled on top of conservatism as defense in depth or just 11 the result of ignorance?
12 Our seismic design which is conservatism at each
()
13 step and not really knowing what the final result is, is 14 that defense in depth?
It's certainly conservatism in 15 depth but that's not, certainly the same thing people talk 16 about when they talk about multiple barriors.
17 MR. KING:
I think about the latte - things more 18 margin than defense in depth.
19 MR. SIESS:
More margin is defense in dopth?
20 MR. KING:
No.
It's separate from defense in 21 depth.
It's defense in design.
22 MR. SIESS:
Margins are usually provide against 23 uncertainty in some fields, anyway.
24 MR. KING:
Yes.
25 MR. SIESS:
There's some talk of margins in the ace-FEDERAL REPORTERS, INC.
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! ()
t 1
policy statement as if it is margin against the -- beyond 2
the design basis accident.
That I don't understand at all.
3 If I've got a design basis accident and then i
4 I've got something beyond the design basis accident, I f
5 don't protect against the second accident by putting a i
6 margin in the first one.
I protect against the second one 7
by designing for it.
8 Maybe, with less margin.
I don't know.
9 MR. WYLIE:
If you can define it.
10 MR. SIESS:
If I can define it.
i 11 If it's margin against uncertainty it is not 12 margin -- if they are beyond the design basis accidents
. ()
13 that we can't imagine, then.we'd hope that our margin i
14 covers those.
But there's some suggestion, you know, that 15 there is a measurable margin against some definable l
i 16 "beyond the design basis accident."
This is what we are I
17 going through now.
We are looking at containments to seo 18 how much margin they've got for core melt.
They weren't 1
19 designed for core melt.
They were designed for something i
20 else with margins.
And any margin they've got against core 21 melt is fortuitous and highly variable.
That bothered me a i
)
22 little bit.
j 23 Is severe accident going to be a design basis
]
24 accident or are we going to end up on advanced reactors 25 with something like a double ended LOCA with enough margin
- ()
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1 to take care of a severe accident?
Or something?
Or are 2
you going to ask them to design that?
i 3
MR. KING:
Well, they've already defined it.
t 4
They have defined a design basis accident envelope.
5 They have also designed the plant to accommodate i
6 accidents beyond design basis, ATWS events, station j
7 blackout events.
8 MR. SIESS:
That doesn't make any sense to me.
9 MR. WARD:
That doesn't make any sense to me, j
10 designing beyond design basis.
I 11 MR. KING:
But the plants are designed to 12 accommodate the beyond basis low p,robability events.
The
()
13 reason they don't call them " design basis accidents" is
.14 because they can use nominal best estimate evaluations when i
l 15 you get out into that regime.
16 MR. HARD:
Maybe Chet is suggesting that our i
[
17 little world would benefit from some clarity in your -- if 18 you have an opportunity to introduce some clarity into this 19 discussion.
j 20 MR. SIESS:
We are sort of opening a new book
]
21 here.
Not completely because we have looked at HTGRs and 22 we have looked at LMRs.
But we've got a chance to get to a 23 logical conclusion by a better route than we did on water 24 reactors where the designs were enveloping accidents --
-r 25 that turns not to envelop anything.
4 t
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BRT-O 1
MR. KING:
You are saying now maybe we ought to 2
consider stop using design basis and beyond design basis 3
terminology?
4 MR. SIESS:
Your design basis'could be' safety 5
goals and to demonstrate that you have to back down to some 6
next level of basis of some kind of an accident.
7 MR. KING:
Could be.
j 8
MR. SIESS:
If we were doing water reactors all 9
over again presumably, to meet a design basis as a safety 10 goal we'd start with a severe accident, not with a LOCA.
11 MR. EBERSOLE:
You are going to say something 12 about the distribution of probability, it's now 10 to the
()
13 minus 4 for core on the floor and 10 to the minus 6 if it 14 gets away; that's the ratio put into the containment versus 15 the core melt prevention systems.
16 Are you going to say anything about the 17 distribution of these probabilities in the defense in depth 18 picture?
19 MR. KING:
We intend to talk about distribution 20 of probabilities.
21 MR. EBERSOLE:
That thing can shift back and 22 forth depending on reliability of the core cooling system l
23 designs.
You can reduce the containment reliability if you-24 had a better core cooling system.
25 MR. KING:
What I intended to talk about under O
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i 30692.0 51 (S) 1 the defense in depth paragraph is that there are a number 2
of aspects to defense in depth.
It's just not multiple
{
3 barriers, there are other things.
And I wanted to get the t
4 thoughts in when the Staff is looking at a plan and talking i
5 about defense in debth, these are the kinds of 6
considerations that we are going to bring in when we are i
j 7
looking at those advanced designs.
It doesn't mean we are 1
8 going to give more weight to one than the other.
I just l
9 wanted to get on the record that the Staff is not giving up i
10 defense in depth, and when we talk about defense in depth i
j there are a number of aspects about that we are talking 11 12
- about, t
j
()
13 MR. EBERSOLE:
Defense in depth is just another 1
14 way to get diversity in safety.
1 j
15 MR. KING:
Applying defense in depth for the i
16 most part is going to be design-specific.
It depends on 17 what the design looks like, whether you feel you need i
]
18 multiple barriers or a backup cooling system.
We can't say 19 that in here because this is a generic document because
~
i 20 it's more a document to go on record saying here are the
)
l 21 kinds of things we are going to look at and the kinds of 22 considerations we are going to bring into this review.
j 23 MR. EBERSOLE:
Is it going to include a l
24 geographic distribution of the plants where maybe one of 1
25 the major elements of safety is the dif ference if you can l
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1 still put a commercial plant in the middle of the Idaho 2
desert and it will be pretty safe.
3 MR. SIESS:
Only for people.
Not for the 4
environment.
5 MR. EBERSOLE:
Well, for heaven's sake --
6 Mk. WARD:
I guess we mixed the discussion 7
what's meant by " defense in depth" and " design basis 8
accidents."
But I think as I understood what Chet was 9
saying --
10 MR. SIESS:
There are two different things I was
't 11 saying.
~i 12 MR. KiRD:
Yes, two different things.
But our
()
13 existing -- you know -- discussions about those two things 3
14 are really pretty muddied because of the way things have 15 evolved over the last generation.
~
16 You have got an opportunity, here, to be a l
17 clarion voice for rationality, or something.
But I guess I 18 always have sort of a hangup on design basis.
19 Now we've evolved to a point where certain
'1 20 classes of hypothesized accidents we are willing to accept 21 probabilistic and risk-based arguments on.
Other classes 22 we are not.
We like to pretend we are being absolute and 23 deterministic about that.
But we design for both of those r
24 and I don't know if it's particularly useful to call either 25 of those " design basis accidents."
It's sort of an archaic Ace-FEDERAL RneonTnas, INC.
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definition that doesn't seem to be serving us too well.
2 MR. KING:
You know the approach we are taking 3
on these DOE designs is they proposed the design basis 4
envelope for the plant.
But we are looking beyond that, at j
5 lower probability accidents.
And they are looking beyond 6
that at lower probability accidents and they are saying:
7 Our plant can withstand these lower probability accidents 8
up to some point.
And we are going to design the plant to 9
do that.
Now maybe there's a semantics prdblom that wo 10 don't call it " design basis" but I think --
11 MR. WARD:
Usually when there's a semantics 12 problem there's some muddy logic behind it.
()
13 MR. SIESS:
Are you going to have two safety 14 critoria?
I think the term they use is the " top level."
15 For what wo are calling " severe accidents,"
l 16 essentially our criterion for acceptability is a safety j
17 goal.
That's a gross oversimplification because we've got 18 six safety goals now.
l 19 But, for the so-called " design basis accident,"
20 for light water reactors, we have a dif ferent criterion for 21 acceptability and that's part 100.
22 MR. KING:
Yes.
i 23 MR. SIESS:
Now, I'm not sure that if wo started 24 with the safety goal as a critorion, we'd over back down to 25 have part 100 as a critorion for a large LOCA, or for " design
()
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)
1 basis accident."
We would have satisfied just the ono.
J 2
Here we talk about two levels and are they i
3 related or are they separate?
That is, is the idea that if 4
you meet the design basis accident critoria, whatever they I
5 might be, part 100, with sufficient margins, then you will 6
automatically meet the upper levol safety goal critorion?
7 Is that the way the approach is to go?
8 MR. KING:
No.
I'm not proposing that approach.
9 MR. SIESS:
This is one design approach.
You 10 design for expected loads and check for the unusual loads.
11 MR. WARD:
Yos.
12 MR. SIESS:
In my field of structural
()
13 engincoring wo uso a term called " limit states."
Wo design 14 for different limit states.
One might be visibility limit
- ~
15 stato and one might be an ultimato failure limit stato.
Wo 16 allow different stressos and different loads depending on 17 them but they are both checked and given equal weight.
18 The other approach was to design for visibility i
19 with enough margin that you thought you'd take caco of the 20 unusual as long as it wasn't too unusual.
It's a very 21 nonquantitativo -- I just don't soo how we can talk about 22 design basis accidents without some acceptance critorion 23 liko part 100.
24 MR. KING:
Acceptanco critoria, for the throo 1
25 DOC designs, the designers are proposing acceptanco Ace FEDERAL. ReponTnns, INC.
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critoria.
2 MR. SIESS:
Like part 100?
3 MR. KING:
Protectivo action guidelines dosos is 4
what is proposed for design basis as well as some of the i
5 beyond design basis events because they -- their proposal 6
is not to be required to have off-site ovacuation plans so 7
they are taking a much lower off-sito release limit and 8
imposing that on their plant.
9 The question wo have to f aco is, given their 10 design, given the accidents and the performance of the s
11 plant in those accidents will we be willing to say you 12 don't need off-cito evacuation plans?
The Commission's
()
13 policy statomont doesn't require them to do that.
14 MR. SIESS:
That doesn't bother mo at all I
15 because if my goal, my critorion is the safety goals, and I 16 can moet the safoty goals without ovacuation, then fino.
17 That just fits into the picturo, if safoty goal is the la critoria.
19 MR. KING:
We say those plants have to moot the 20 safety goals.
Wo say that.
21 MR. SIESS:
But the safety goal requires i
22 considerations of what, as I road this, requires 1
23 consideration of beyond the design basis accidents.
l 24 MR. KING:
Those plants are doing that.
You aro l
25 saying wo don't give them any guidanco in hero to toll them O
I I
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1 to do that?
Is that your problem?
2 MR. SIESS:
Do you expect to have somo 3
intermediate performance critorion like part 100?
4 Right now in a water reactor, presumably you 5
have to moot the safety goals.
ilo haven ' t gotten quito 6
that far yet.
But you still have to moet part 100.
7 MR. KING:
Yo s.
Same thing on those plants.
8 MR. SIESS:
You expect to have two levels of 9
acceptability for off-site consequences, depending on the 10 probability?
)
11 MR. KING:
ilo can talk about that for the throo l
1 12 DOE designs.
lihat they are proposing is staying below the O
13 orotective ection ouidetine doeee for deeion besis end 4
i 14 beyond design basis ovents.
15 MR. EBERSOLE:
Evacuation is protectivo action?
I 16 MR. KING:
EPA protectivo action guidelines, 1 17 rom, wholo body --
18 MR. EBERSOLE:
lihat kind of weathor?
l 19 MR. KIhG:
For the accidents called design basis 20 accidents it's under the 95 porcent confidenco motoorology; j
21 for tho accidents that fall out in the beyond the design 22 basis accident rango it's in tho 50 percent nominal weathor l
23 conditions.
That's what's being proposed.
24 MR. SIESS:
And they have defined those beyond i
25 the design basis accidents?
i i O Acti Fi!DI!RAL Riiroimms, INC.
202 347 3700 Nationwide Coverage fur) 3% (M6
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(
1 MR. KING:
Yes.
2 MR. SIESS:
So they are actually design basis 3
levol accidents at level 2, say?
Critorion 2?
PAG?
]
4 MR. KING:
Maybo you want to call them that.
As 5
semantics --
6 MR. WARD:
That's what it amounts to and it 7
would help clarify things if you would.
Why don't you do i
8 that.
9 MR. SIESS:
I can't buy the expression "boyond 10 the design basis" for something that's not yet designed.
j 11 It's perfectly acceptable for a plant already designed and 12 built to look at the margins it has for things beyond tho
- ()
13 design basis but for something that -- onco you've 1
14 ostablished the "boyond the design basis accident" for now 15 plants it scoms to me it is now part of the design basis I
16 alboit with definito acceptanco critoria.
17 MR. WARD:
If you are going to design to it, uso 18 it as a basis for design.
l 19 MR. SIESS:
It's just semantically absurd and I i
20 guess it just bothers me.
21 MR. WARD:
It's logically absurd.
j 22 MR. SIESS:
Logically stupid.
l j
23 MR. MICilELSON:
The thing that bothers me on j
24 this whole conversation is the light water reactors, wo j
25 have kind of reached the point now whoro wo think wo O
i l
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understand the uncertaintios in our PRA-type answers.
Sie 2
think we kind of understand it.
But I'm not at all cortain i
3 that we are in a position to put any great confidence in a 4
PRA dono on a liquid metal reactor today.
You don't have 5
an experience base.
You don't havo 100 of them running out 5
there to give you some confidence.
Your uncertaintios must be very large at best.
Ilow are you going to deal with tho 8
uncertainty problem in the PRAs and whatever you do in l
~
9 terms of mooting a sovoro accident policy statomont and so 10 forth?
Ilow are you going to approach this whole thing?
l 11 You don't have an experienco baso upon which to make thoso 12 judgments.
You don't even have comparablo components in
- O 13 ment ceeee to took to.
14 All you've got are some prototypes hero and 15 thoro, and maybo what you are proposing for a llTGR maybe l
16 may not look like anything at Fort St. Vrain an.1 the only 17 thing you have over got running is somothing in a i
18 laboratory?
iMat do you think your PRA is to be based on?
19 MR. KING:
That's a good question and I think
(
e l
20 it's a question wo have to wrestle with doing this review.
l 21 lihat are the uncertaintios?
Do we really fool wo know what 22 they are?
23 MR. MICllCLSON:
llow largo they aro I don't oven
\\
24 want to got into but you cortainly havo to realize they aro
}
25 a little fuzzier about the water reactors.
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MR. WARD:
Carl, the PRA will mean as much as it 2
can given what's known.
But are you suggesting that it 3
might mean so little that it's not worthwhilo?
Or are you 4
just cautioning --
l 5
MR. MICHELSON:
I'm asking how are wo going to 6
approach the uncertainty question of the PRA, and how will f
^
7 we decide that we really are mooting the safety goal in the 8
caso of tho HTGR as opposed to a light water reactor whore 9
at least we've got a lot of roactors and experience to look 10 at and say well, goo, our experienco at least indicatos j
11 this -- wo are not quito sure about that --
I l
12 MR. SIESS:
Thore is one solution for this.
()
13 When you have uncertaintion there are two things 14 can you do about it.
Ono is you can try to reduco taom by 15 research or testing or something like that.
The other is 16 trying to eliminato their causo.
You go to a process or a 17 system that is so simplo that the uncertaintios are either 18 reduced or are casily reduced by roscarch.
l 19 MR. WARD:
llhy do you say "so simple"?
20 MR. MICHELSON:
Maybe a PIAS, for instance, 21 might possibly --
22 MR. SIESS:
It's casier to reduco tho 23 uncertaintion in the calculation for a PIAS than it is for 24 a water reactor with 20,000 valvos and all of that junk in f
j 25 it.
1 f ()
Acit FriininAL Ri:PonTiins, INC,
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1 MR. WARD:
You might reduce the uncertainty by 2
making it more complicated.
I don't know.
3 MR. SIESS:
You might reduco -- increase the 4
reliability but the uncertainty of predicting that 5
reliability will be high.
The uncertainty is always on the 6
exponent in the probability term, not on the capacity of 4
7 the components, you soo.
A factor of two on the componont 8
is tremendous.
A factor of two in the probability is 4
9 nothing.
10 Thoro are ways of designing around uncertainties.
11 This is what engincors do all tho timo.
12 MR. MICilELSON:
IITGR, for instanco, is a O
13 retetively cometex device.
14 MR. SIESS:
It is.
Parts of it.
That's why 15 they got --
16 MR. MICilCLSON:
And our experience is pretty 17 limited on itTGR in terms of the kind of experience for PRA 18 calculations.
I 19 MR. SIESS:
But the uncertainty regarding 20 operator action as a function of timo is greatly reduced in j
21 a IITGR, you soo.
2 22 MR. MICilELSON:
That we could probably 23 understand bottor.
That's why I wondered how you are going q
24 to deal with uncertainty --
25 MR. SIESS:
I remember many years ago when the ECCS i
Acti FEDERAt. Rni>oRTuns, INC.
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Nationwide Coverage Nub 33MM6 J
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BRT
()
l 1
problem in the Appendix K issue or the hearing came up and 2
Stovo Annower camo in here and said the trouble with ECCS i
i 3
is you can't show it works by some calculations on the back t
4 of an onvolopo.
5 If it was a system that you could show it worked 6
by calculations on the back of an onvolope, tho i
7 uncertainties either would be small or it wouldn't tako j
8 much work to reduce them.
But if you have to make s
i 9
calculations on six hours on a Cray, you know -- what the 10 holl.
I think that's one of the things that people should 11 be siming for in the advanced reactor systems that are moro 12 casily calculated.
Those words appear somowhere in
()
13 something I road.
14 MR. MICl!ELSON:
I'd be comfortablo if the policy l
15 statomont talked more about the uncertainty in the PRA and 1
16 about the fact you happen to have one.
llaving one doesn't 4
17 mean a thing to me if you don't have a data base of somo 18 sort with which to narrow the uncertainty bands on the PRA.
19 And thoro's nothing said about uncertainty.
20 MR. KING:
Undor the defonso in depth paragraph 21 wo talk about uncertaintios and I think I might want to 22 oxpand that a little bit.
23 MR. MICilELSON:
Yos.
It has got to be more than 24 a PRA to be comfortable with when it's a now technology.
25 MR. SIESS:
But if you had a system that i
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oliminated all possible common modo failures, right there 2
you would reduce the PRA uncertainty by a tromondous amount.
3 MR. MICilELSON:
llopefully it wasn't also a bomb.
4 Presumably on bomb wo havo reduced this -- reduced tho 5
probability -- the experienced ignition theory --
6 MR. SIESS:
Mr. Chairman, Zoltan has boon --
i 7
wants to add somo words of wisdom.
a 8
MR. ROS2TOCZY:
Zoltan Rosztoczy.
9 In the standard design base type of approach wo 10 are used to using the bottom number calculating a peak 11 temperaturo for examplo and comparo it against the critoria i
12 and mako a decision on that.
Wo aro talking about sovero
()
13 accidents and PRAs, that's a different ball gamo.
1 14 By performing the PRA you do como up with bottom l
15 numbers, do como up with coro damagos, do como up with 1
1 16 those numbers.
But thoso end numbers, those bottom numbers i
17 are not used the samo way and should not be used tho samo l
18 way how wo use bottom numborn in tho moro dotorministic
]
19 design base analysis.
20 The main purpose of the PRA and the main bonofit 21 gained from the PRA is the insight that wo gain by doing it.
l 22 By finding out where are the wonknossos in the system, 23 whoro do the common modo failuros como from, what 24 combination of single failuros are somo kind of a problem 25 for a given system and then wo try to do somothing about
(
4 i
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1 those to try to oliminato those ovents from happening and 2
also to soo that tho type of protection that would bo 3
provided in such a caso is there and it is availablo so tho j
4 PRA is expected to be used moro along thoso linos than in 4
5 terms of taking a bottom number and comparing it to 6
somothing.
7 Uo bollevo that it is a useful tool, even though i
8 when you do a PRA for a conceptual design it is nowhoro 9
closo to oporato -- well, maybo that's not not the right 10 word for PRA -- but that's a detail -- than it could bo for j
11 for a moro established design.
Novartholoss, it points a
?
12 cortain direction and indicatos where the weaknessos are
()
13 coming from, the potential weaknessos aro coming from and
]
14 then we can work on those specific problems and soo what 15 can be dono about tho a.
i 16 MR. SIESS:
I agroo with you 100 porcont.
But
)
17 the Commission has promulgated a safety goal which is j
18 defined in terms of a probability and the only way you can 19 demonstrato complianco with that safoty goal is the bottom
)
20 lino of a PRA.
Until they chango that policy, that's it.
I 21 MR. ROS2TOCZY:
Ploano koop in mind the purposo j
22 of the safoty goal is to provido guidance for the Staff in l
23 its work ostablishing tho requiremonto.
The safoty goal is l
24 not a roquiremont.
The safoty goal, if you look at tho
)
l 25 so-called " specific" --
(
i 1
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1 MR. IlARD:
Ilo must be reading our draft lotters.
2 MR. ROSZTOCZ Y:
If you look at the so-called --
3 the safoty goals, the two critoria, on fatalition, thoso 4
are definitely mot by any of thoso designs and wo expect to 5
moot thoso with a very largo margin so I don't think thoso 6
will be questioned.
7 If you look at some of the other statomonts in 8
the safety goal policy statomont which -
" safety goals" 9
with quotations marks at the prosent timo -- the frequency 10 relating to sovoro ovonta and the ono relating to the largo 11 roloasos, thoso are more rostrictivo, significantly more 12 rostrictivo and those are going moro in the direction that O
12 ene would have to took at up otoee.
14 MR. MICilELSON:
I think I understood your 15 discunnion but I have a little problem.
I can do a fino PRA 16 and oven think I'm clone to right and ovon estimato fairly 17 low uncertaintical but how doos this mean much if I havo no la data base upon which to ostimato, for instanco, the 19 probability of a pipo rupturo 20 motorn from it -- wo just 20 don't havo the experienco bano upon which to datormino the 21 frequency of the occurrenco.
22 lihatover frequency you buy, if it looko 11ko a 23 nonproblem, it may be a very norious problom.
I 24 Do you think 20 yearn ago they thought problomo 25 in the HilR woro extonnively obnorved?
No.
The problem wan l O l
l Acit.FliniinAL IlitronTiins, INC.
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i 30692.0 65 BRT i
1 thought to have boon solved.
A PRA dono 20 years ago 2
probably would have put very low numbers on the probability j
3 of a cracking failuro.
h j
4 So it's right.
It's only judgmonts and only I
i 5
good to spot what you think -- holps to highlight what t
1 j
6 appoor to be the problems today based on whatever 1
7 experienco you have.
It doesn't do too well in -- whoro j
8 you have no experienco holping with the confidenco unloos
]
j 9
you do a sensitivity study, varied by vast amounts.
l 10 MR. WARD:
It's a poor tool but it's way ahond j
11 of the next boat thing.
3 12 MR. MICIIELSON:
I'm not arguing with that.
But 4 ()
13 what this does is croato uncertainty, then, in the bottom i
l 14 lino results and I think a big indotorminato whoro thoro's i
j 15 very littlo frequoney dato, too, upon which to do your j
16 calculations.
You aro doing tho boat you can but it is l
17 still minimal until you got a few hundred roactor years la experienco like wo do on light water.
19 What we are doing is developing a safoty goal i
20 based on our comfort with light water reactors and trying 1
l 21 to say it applion to a whole now technology in the semo way 4
I 22 and somohow wo can do the magic PRAs, and in this rango --
l 23 wo are crazy.
J j
24 MR. WARD:
The PRA at this stago can at least 1
j 25 help you to kind of zoro in on the sorts of oxperionco you
(
1 i
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1 ought to be kooping an oyo on.
l r
]
2 MR. MICIIELSON:
At least it can holp you to l
3 highlight what you bottor worry about now but it doesn't J
I 4
holp you very much until you got a good data base.
5 MR. WARD:
It's not a substituto for judgment.
6 MR. ROSZTOC2Y:
Just an was said, it's the j
7 bonofit of the PRA, as Mr. Ward said, you identify tho 0
arons whoro moro data is noodod, tho area whoro the major l
1 9
courco of uncortainty is coming in and should it turn out 10 that one of thoso designs becomon a real candidato for a I
]
11 number of reactors, then thoso would bo the aroan whero I
12 both industry and us would have to opond our rosourcos to i O la try to aenerate thet iaformation.
]
14 MR. WARD:
Lot mo ask you a little different 15 quantion that really in more rolated to two of the DOC i
l 16 donignn than the topic today but I would still liko to ask
)
17 it.
f i
i 10 You montionod beforo, an I understood it, for j
19 the Clinch Rivor donign the Staf f accepted 4
j 20 lonk-boforo-break argumont as justification for tho donign 21 not having to provido omorgency cooling that could dual r
I 22 with inntantaneous doublo guillotino break of primary pipor i
i 23 in that correct?
24 MR. KING:
Corroct.
e 1
25 MR. HARD:
flut an I understand it in both tho
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SAFR and the PRISM donigns, the DOE donign concepts --
2 MR. KING:
Yon.
3 MR. WARD:
-- are not invoking that sort of 4
argument?
In thoro como obvioun roanon why not?
5 MR. KING:
Wo are trying to simplify the design.
6 You recall in tho SAFR and PRISM it's all incido the pot.
t 7
The break in the pipo although it will chango tho flow rato I
8 insido the coro it won't spill out and cauno a nodium firo 9
and they have analyzod that you can have a doublo-onded 10 break within the coro and they are saying that the plant P
11 can still, oither through inhoront moann or by itr control 12 rodn, shut itnolf down and not ovorhoat the coro.
O 13 "a
"^ao it'a avde aort or a ecoao ic --
14 sort of economically noconnary or worthwhile to make that
[
i 15 argument for Clinch River but it's not for thono other two i
16 donignn?
In that really basically what it in?
I know they 17 are difforont.
I i
18 MR. KING:
Wo havo to talk primary and I
19 intormodiato nystems.
Clinch Rivor was a loop plant, the 20 primary pipo wan outsido tho voonal.
t 21 Thoro a break won moro norioun in torms of a 22 sodium firo.
It wan alno moro norious in tormn of loning i
23 the cooling inventory in the roactor vonnel no they didn't 24 want to havo to dontgn for a double-ended rupturo.
That 25 would have counod ponnibly nomo additional nafoty synto in O
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I to be added to the plant.
i 4
l 2
What they did was mado the caso that 1
3 leak-boforo-break applied.
They had the fracturo mechanics j
i 4
data to make that caso.
The leak dotection system, tho l
l 5
in-norvico inspection commitments, that wo said:
Okay.
[
6 Wo'11 accept that.
i 7
MR. WARD:
So thoro was incontivo to go to tho 0
troublo to make tho argument.
9 MR. KING:
Yon.
Now PRISM and SAFR, with tho s
j 10 primary syntom all insido the pot, thoro in no ISI, thoro 1
j 11 in no loak actoction you can havo in thoro no you really I
l 12 can't mak; Lho argumont but plun you don't have to make tho
()
13 orgument becauno you are not worried about losing your l
14 cooling inventory with a break.
1 1
j 15 For the intermediato nystem inntoad of making i
16 the argument they havo just donigned the firo protection 1
1 17 featuron to accommodato a doublo-onded rupturo.
Sinco all la tho docay hoat removal syntom featuron are annociated with
(
l 19 tho vonnel and the primary nyatom, you don't nood tho i
j 20 intermediato nyntom for heat trannfor liko you did for i
j 21 Clinch Rivor.
i
{
22 MR. WARD:
Okay.
23 MR. KING:
You junt don't nood it in thono i
j 24 planto.
i 25 MR. WARD:
I undorntand.
Thank you I
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MR. KING:
I guons wo are roady to talk about 2
the NUREG now.
i i
f
)
3 MR. WARD:
Why don't wo tako a brook now.
Thin i
i 4
in a natural timo to tako a break and we'll como back at i
i 5
10:15.
j 6
(Rocoon.)
l 7
MR. KING:
What I wanted to do next was go i
8 through basically noction 5 of tho NUREG, which deals with
]
9 implomontation.
This in just an outlino of NUREG.
l 10 (Slido.)
l 1
i j
11 Part 1 in development, part 2 in the stuff in 1
12 noction 5, and I have a vugraph to addronn each of those 13 voiat here.
so tant wili de the remataina eart of the
- O 1
l 14 pronontation, in to go through what wo havo in mind for 1
j 15 oach of thono points.
i Ii 16 (Slido.)
l i
17 Dofinition of " advanced roactorn."
The policy 1
10 statomont nayn they have to bo significantly difforont than 19 curront gonoration light water reactorn and it listn 1 20 think 11 attributon in thoro that they would liko to noo.
l i
21 What wo aro proponing in thin NUREG in to go a j
)
22 little further than that and put in nomo words, two thingn,
}
23 ono, that the real dotormination of putting the roactor in t
24 tho advanced category that falls under thin policy 25 otatomont or not in thin catogory will bo banod upon how l
Acti.Fi:niinAi. Riti>onit ns, INC.
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clone its requiremonto would fall to the standard review 2
plan requiromonto.
l 3
MR. MICilELSON:
That's not explicitly statod, 2
i 4
though, in the NUREG in it?
5 MR. KING:
Lot mo noo if I can find the page.
3 6
It may nood nomo clarification.
i 7
MR. MICilELSON:
In my reading of it I kopt 8
asking myself why doonn't the ADWR fit thin?
9 MR. WYLIE:
It anyn that, I boliovo, on pago 5-2;
]
10 top of 5-2.
l 11 MR. KING:
Top of pago 5-2, you aro right.
In
]
12 whoro wo put it in.
If it noods nomo clarification --
13 MR. MICllELSON:
It just says they are clannified f
14 an "advancod" and aro reviewod as part of tho activition 15 under advanced policy and no forth; naybo that's -- in that j
16 what you think --
17 Mit. WYLIE:
It nays "and are expected to havo la liconning requiremonta nignificantly differont than thono 19 contained in the light water standard roview plan, i
20 NUREG" --
21 MR. WARD:
It nayn it's not really using that an l
22 a dofinitlon.
23 M it. MICilELSON:
ABWR fits that.
Cortain anpoeta 24 of it aron't covorod by the ntandard review plan.
i 25 MR. KING:
But it'n not nignificantly difforont.
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(
1 The second point is it has really to bo looked 2
at on a caso-by-case basis and a judgment mado.
I don't 3
think you can put an ironclad definition in hero not 4
knowing about what other p' ants como down the road.
5 MR. MICHELSON:
Thora was another definition, I 6
don't havo it in front of mo but all it says is it has to 7
bo significantly different.
By golly, when you put all 0
your pumps and so forth insido a vossol, that, to me, 9
soomed significantly different.
10 MR. KING:
Ono person's judgment on significant 11 may bo difforont than others'.
I'll look at thoso words 12 again.
Maybo I nood to clarify them.
That the real
()
13 distinction wo are trying to mako is, if a plant is close 14 to the standard review plan requirements, then it's not 15 advanced as falls under this policy statomont.
16 If you really have to make major changos to the 17 standard roview plan to licenso the plant --
18 MR. MICllELSON:
That might bo the way to defino 19 it.
I'd have no quarrol.
I don't have any problem oither 20 way on ABWR --
21 MR. MARK:
In PIAS significantly difforont?
22 MR. KING:
Our judgment is yes.
23 MR. MICIICLSON:
You think it usos systems that 24 aro just not covered by the standard review plan?
25 MR. KING:
Yos.
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borated pool by natural convection that shuts the plant 2
down -- I think it's significantly different.
3 MR. MICHELSON:
PWRs use borated pools.
They 4
are inside the vessel but they are certainly a borated pool.
5 MR. KING:
We put it in the " advanced" category.
6 If somebody submitted PIAS we would look at it under the 7
charter of this policy statement but I'll look at these 8
words again and maybe they need some clarification.
That's 9
the basic distinction and the basic addition.
10 MR. MARK:
Put this in the footnote:
If you are 11 not sure, phone Tom King.
12 I really believe if'someone submitted a plant
()
13 they wanted reviewed, it would be more than Tom King that 14 would have to make that decision whether we look at it 15 under this policy statement or look at it someplace else.
16 MR. MICHELSON:
Even though we are saying it has 17 to be deviated so we can't use a standard review plan we 18 are still saying we can use a standard design criteria.
19 MR. KING:
What we are saying is for an advanced 20 plant there are some portions of LWR criteria that are 21 probably going to be applicable and let's not throw those 22 out the window.
Let's build upon what we can but we expect 23 there will be significant portion of that that we would not 24 be able to use because the plant is very different.
25 MR. MICHELSON:
I think you'd find there's a lot O
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of standard review pla'n that you can use for the HTGR, 2
electrical area and so forth.
The same argument would 3
portain.
4 MR. EBERSOLb:
On that topic the HTGR, and the
~
5 gas reactors, one of the major advantages is you can get 6
superheat and therefore much more thermally efficient 7
plants.
]
8 Is there anything even dimly in sight to 9-resurrect the BONUS concept, which would give simple i
10-coi1 figuration, of course direct boiling by emerge heaters, t
11 to produce super-heated steam and overcome the thermal 12 disadvantage of both PWRs and BURS?
Why did BONUS fail?
O 13 Ma. x No=
heve ne idee.
1 cen't enewer thet 14 question.
15 MR. EBERSOLE:
Was it a fuel failure?
You don't 3/
16 know?
17 MR. KING:
I don't know.
I have heard of BONUS 18 but I don't Anow any details about it.
19 MR./EBERSOLE:
If it had worked then it would 20 have ridden into the advantageous part of the 21 high-temperature gas reactor and liquid metal reactor t
22 because it would have brought up thermal efficiency the way 23 it ought to be.
24 MR. WARD:
What's the point?
l 25 MR. EBERSOLE:
I wonder if it can be resurrected O
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as a concept and take advantage of the point that if you 2
have to make steam to turn turbines which is the only way l
3 we know to generate electricity, for God's sake make it as 4
simple as possible.
i 5
MR. WARD:
Are you asking would it be an 6
advanced reactor under this definition?
7 MR. EBERSOLE:
Would it be?
8 MR. KING:
I don't know what it looks like.
I 9
can't answer that.
10 The review approach that the Staff would apply 11 generally has these characteristics that we talked about 12 before.
We would develop additional criteria and guidance
()
13 to address the unique characteristics of the design.
14 (Slide.)
15 I think we mentioned there are certain parts of 16 the plant where LWR standards would apply.
17 DC power systems, for example, all the advanced 18 plans have advanced grade DC power systems.
I would assume 19 most of the LWR requirements would apply.
But when you get 20 into helium systems and sodium systems, unique things, 21 that's where this licensing guidance -- the real 22 fundamental purpose of the review at this stage is to 23 develop the guidance for these unique characteristics.
24 The Commission's policy statement encourages 25 designs to have enhanced margins of safety over current i
v ACE-FEDERAL REPORTERS, INC.
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1 l
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generation LWR.
It doesn't require it, so, in terms of 2
requirements we are limited to what the policy statement 3
says which is advanced plants have to meet the same overall 4
requirements that LWRs meet:
Same safety goals, same part 5
100 releases, part 20 releases, that kind of thing.
But it 6
does encourage them to do better.
7 In the case of the three DOE plants, an example 3
of the way they are trying to do better is meet the 9
protective action guidelines instead of part 100.
10 What the draft NUREG does is tries to define a 11 little bit, put a few words in and talks about the things 12 we are going to look for to assess whether it has enhanced
()
13 safety characteristics.
We are going to look and see how 14 well these designs incorporate those 11 characteristics in 15 the Commission's policy statement; whether they have 16 margins and defense in depth to account for uncertainties; i
17 whether they have the ability to prevent core damage from 18 any low probability event such as ATUS and station blackout.
19 (Slide.)
20 There's a second page to this.
21 MR. EBERSOLE:
What about sabotage?
22 MR. KING:
We are going to look at sabotage.
We 23 didn't put any words in, in this draft NUREG on sabotage, 24 to say anything more than what is already in the Code of 25 Federal Regulations on that.
But as part of the DOE review O
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we are going to look at sabotage from the standpoint of do 2
these designs increase -- make it harder for someone to 3
sabotage or make it easier for someone to sabotage.
I
+
4 think in general the tendency is it's going to make it 5
harder.
There aren't enough active components, below grade 6
systems.
7 MR. EBERSOLE:
If somebody goes maliciously into 8
these systcms they will lock out to a safe state -- are you I
9 going to look at it in that detail?
Rather than just say 10 they can't open the door.
They will lock out to a safe i
11 state and will always be sensitive --
t 12 MR. KING:
We are going to look at it from the i
()
13 standpoint are these plants more or less vulnerable to 14 sabotage than LWRs, due to their inherent characteristics.
l 15 MR. MICHELSON:
A nice inherent characteristic 16 is a fire source because it's always easy to inactivate 17 fire protection arrangements and I can't imagine anything 18 nicer than sodium on the floor to build my fire with and j
19 it's not'hard to inactivate fire protection features.
You 20 are going to have to concentrate real hard on keeping 21 people away from the sodium portion of the system, 22 including the drain lines that you have to have.
You can't i
23 build systems without the ability to drain them and so 24 forth.
You are going to have small drain lines, drain 25 valves --
1 3
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MR. KING:
Except I think there's one thought 2
that the DOE plants in the sodium fire protection areas, 3
the difference between these and Clinch River -- Clinch i
4 River relied on inerted cells and the ability to nitrogen 5
flood some areas that weren't normally inerted.
These 6
designs don't require those active type systems to be there.
7 They use catch pans and drain tanks, and fire suppression 8
decks, which are sort of a passive component.
9 MR. MICHELSON:
It's not hard to inactivate fire 10 protection arrangements.
That's not hard to do at all.
11 That's the easiest thing you can do.
12 In a light water reactor creating LOCAs is not
()
13 that difficult but our mitigation equipment functions very 14 well because it was designed as if such a LOCA -
generally 15 designed so they can be created.
But if you are designing 16 on the assumption you can't create a large LOCA -- you say 17 yes, you do, you put fire protection in, but fire 18 protection alone is the easiest thing probably you have to 19 inactivate.
It's a very simple thing to inactivate.
20 MR. KING:
I'll talk to the DOE designs.
The 21 other thing they are doing is making the plant designs less 22 susceptible to fire.
23 There are many areas in the plant if a fire 24 occurs it has no safety significance.
Even though you have 25 fire protection probably for economic reasons, it is not a rb ACE FEDERAL REPORTERS, INC.
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30692.0 78 BRT 1
public health and safety concern.
2 MR. MICHELSON:
I have heard these same words 3
about conceptual designs before.
4 MR. KING:
That's a good point.
You have to 5
koop that in mind.
It's a conceptual design.
6 MR. MICHELSON:
And you've got a very good fire 7
source -- very intense fire source which makes it difficult 8
to design for -- for self-cooling when you have a massive 9
fire source, self-cooling is not -- it's very difficult to 10 protect plants against massive fire.
And you also have a 11 new dispersion mechanism, not necessarily thought of when 12 you calculated how far you had to evacuate when the (m
(_)
13 Russians found out.
Things get really dispersed with big 14 fires.
In fact all of Europe might see it.
15 MR. EBERSOLE:
On the subject of sabotage 16 another matter I think is important I only recently heard 17 and I attribute this to jurisdictional strength in a small 18 segment of the technology, and the absence of central 19 control over jurisdictional leadership, the fact that the 20 security systems we have now that prevent entry into 21 critical places, when you have a simple failure like power 22 failure, which you can go find a fuse and pull it out, 23 guess what happens?
All the doors lock up.
24 The question has to be raised, should they be 25 locked up or should they be opened up?
The jurisdictional
(
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1 pressure that comes to the utilization of specialists who 2
have strong arms is that the security system people would I
3 always lock things up.
To hell with everything else, they' t
i 4
want to lock it up, keep invaders from coming in with, j
5 perhaps, little, if any, regard as to what the hell happens 6
to the plant?
They just kept the people out.
Do you 7
follow me?
8 MR. KING:
Yes, I follow you.
9 MR. EBERSOLE:
That says to me we are still 10 suffering from jurisdictional -- an overload of 11 jurisdictional control.
In small sectors.
The absence of 12 any central themes.
()
13 MR. KING:
At this stage of the review we would 14 look at that consideration from the standpoint of:
Are 15 there areas of a plant where an operator has to go to 16 maintain control, to keep it in a safe shutdown condition?
17 I think in general the tendency in these designs 18 is to remove those areas.
The operator doesn't have to do 19 anything so if he can't get in it doesn't matter.
20 MR. EBERSOLE:
There was the same sort of thing 21 in fire protection.
The fire protection people want to 22 come in and just wet the whole plant.down, switchboards and 23 everything.
I think that's partially fixed but the system 24 aspect of that is not, 25 MR. MICHELSON:
We find out we haven't stopped a
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them from wetting down large areas, we are also not smart T
2 enough to figure out where water flows and where it goes.
3 MR. KING:
At this stage we would look at the 4
fire protection question.
Are there areas of the plant 5
where inadvertent actuation is going to cause a problem, 6
where a guy randomly spraying water around would cause 7
problems?
The tendency of the DOE designs is to remove 8
those areas, don't have areas like that.
But again at this 9
point in the review we would at least ask that question.
10 We may not get into what kind of locks do they have on the 11 doors.
Certainly we won't get into that kind of detail but 12 we would ask in a conceptual sense those questions and make
()
13 some judgment is it better or worse than LWRs.
14 HR. WARD: insofar as sabotage protection of 15 these plants, their resistance to sabotage threats, it 16 seems to me that your review might want to establish 17 whether there's some unique -- whether these plants might 18 be uniquely more vulnerable to sabotage than the existing 19 population of LWRs.
As Carl is suggesting, sodium fires 20 might be something unique.
21 But, as far as encouraging or insisting or 22 encouraging that they be uniquely less vulnerable to 23 sabotage than the existing LWRs, there doesn't seem to be 24 much logic or point in that?
25 MR. KING:
No.
And we are not doing that.
We
- (:)
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i 202-347-3700 Nationwide Coverage 800-336-6646
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/-b) 1 are just trying to address the sabotage question from the 2
standpoint of are they better or worse than LWRs in, terms 3
of their vulnerability; not impose any new requirements.
4 MR. WARD:
Yes.
5 MR. WYLIE:
Shouldn't that be a goal for a 6
designer of advanced plants, to design them in such a way 7
that they are less vulnerable to sabotage and therefore 8
open the plants up?
As Jesse pointed out, now we lock them 9
up.
You can hardly operate in times of emergency.
10 MR. WARD:
You mean if the sabotage resistance 11 would be more inherent in the process rather than depend on 12 cowboys and locks?
()
13 MR. WYLIE:
That ought to be an objective.
14 MR. EBERSOLE:
I can imagine, for instance --
15 sure --
16 MR. WARD:
I won't object to that but I guess I 17 object to some big thrust to make them more resistant as a 18 nackage than the present LWRs would be.
19 MR. WYLIE:
If it can't be done, it can't be 20 done, but what I'm saying, just like a lot of things that 21 we looked at in the light water reactors, where prudence 22 would have dictated that you made it harder to sabotage 23 something and they didn't do it just because it wasn't a 24 stated goal.
25 MR. EBERSOLE:
Just take the case of the scram O
ACE FEDERAL REPORTERS, INC.
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()
1 system.
It could be rigged to be virtually like in a safe, 2
like a bank vault, and as you back out of it you set it and 3
it would remain stable and functional but if you tried to 1
{
4 go in it would trigger the safe.
}
5 MR. KING:
Go one step further, if the scram i
6 system doesn't work you have negative feedbacks that will 7
shut the plant down.
8 MR. EBERSOLE:
That's even better.
t 9
MR. KING:
That's what's being done.
i 10 MR. WYLIE:
I wouldn't attempt to set a design 11 because we don't know much about it but it ought to be a 12 stated objective; that they try to design these plants so
()
13 that they don't have to be locked up.
14 MR. EBERSOLE:
Since no attention at all has
)
15 been paid to this in the current designs other than putting 16 keys and locks on doors, I think that's an overlooked area, 17 sabotage.
And it shouldn't be, that we should just say
]
18 they need be more better than Davis-Besse, for instance, l
19 which had only two aux feed pumps, steam driven.
I 20 MR. KING:
You are proposing we ought to impose 21 some requirements for better sabotage resistance to these 22 plants?
23 MR. EBERSOLE: -Intrinsic, if possible.
24 MR. WARD:
I'm troubled.
I hear what you are l
1 j
25 saying but then in a few minutes Carlisle is going to say
(
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30692.0 83
(
l he can think of ways to -- that there isn't any such thing 2
and when he starts to look at details, a clever saboteur 3
can think of ways to key it so you have got to go to locks i
4 and cowboys and castles.
5 MR. WYLIE:
You may have to lock up certain I
6 parts of the plant.
7 MR. EBERSOLE:
Because you can't be perfect, 8
Dave, doesn't mean you couldn't be good.
9 MR. WYLIE:
One of the things we point out if we 10 improve the decay heat removal of the light water reactor 11 we could open up the plant for operations.
12 MR. EBERSOLE:
They have stolen the crown jewels,
()
13 too, but it wasn't easy.
14 MR. WYLIE:
I don't think it ought to by law --
i 15 I think it ought to be a stated objective.
16 MR. EBERSOLE:
I agree with you.
17 MR. MICHELSON:
The real problem with defining.
]
18 the threat, of course.
j 19 MR. WYLIE:
I wouldn't even try to do that.
l 20 MR. MICHELSON:
You don't want to change the 21 threat.
You just want to improve the resistance against 22 the present threat?
Is the present threat realistic for i
23 these advanced plantsI Well, I don't know.
We'd have to l
24 think about it.
25 MR. WYLIE:
I don't know either.
- ()
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1 MR. MICHELSON:
How they are laid out, whether a 2
truck bomb is a threat or not.
3 MR. WYLIE:
It may just fall out that they could 1
4 do very simple things that would improve it.
5 MR. MICHELSON:
Would you want the control room 6
outside the area you know because it might be nice from-a I
7 modular viewpoint, it would be a fine target from a truck 1
8 bomb viewpoint.
9 MR. EBERSOLE:
Maybe the control room is not 10 important anymore.
11 MR. MICHELSON:'
Maybe it's not.
You have to see 12 the design.
()
13 MR. WARD:
Carson?
14 MR. MARK:
I don't think that sabotage, no 15 specific proposals about it should be a requirement.
But 16 it shouldn',t be lost, and you should expect that the 17 designers are going to think through things -- it should be l
18 in there in that sense.
That you ask that it be considered.
19 MR. KING:
I think it is.
I agree with you, l
20 MR. WYLIE:
But you know what we are going to 21 run into is, in the review of these FSARs, and some of 22 these later plants where we looked at them we asked i
23 questions:
Why didn't you do so-and-so?
24 They say:
Oh, it wasn't a requirement it wasn't 25 even considered.
The design basis threat hasn't been j
}
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1 changed, pou know.
As Carl pointed out a moment ago, where i
2 you locate the control room -- well, we put it there 3
because we wanted it there.
It's not because -- there's no 4
requirement it be put anyplace else, even consider it.
5 MR. WARD:
That seems to raise the question, I 6
think there are several places in the policy statement 7
where it says designers will be encouraged to do this or 1
8 that.
I guess this is one of those encouragements?
]
9 MR. WYLIE:
Well, yes.
10 MR. WARD:
Does that have any operative meaning i
]
11 at all?
)
12 MR. KING:
We can't enforce it.
()
13 MR. WYLIE:
Charlie is suggesting in the case of, 14 you know, the example he was giving, it didn't have any 15 meaning.
The designers said well, we weren't required to 16 protect the control room so we didn't even think about it.
l 17 MR. EBERSOLE:
All you are going to get with 18 your current instruction is a bunch of locks again.
19 MR. KING:
If we get that for advanced plants 20 what I would envision, the SER would come out and say there 1
21 are no extra benefits or reduced vulnerabilities to 22 sabotage to these plants because there are control rooms 23 outside the fence or whatever it turns out to be.
We are 24 going to make some statement on sabotage.
We are not going 25 to impose any additional requirements.
)
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MR. WARD:
But what will you say?
What do these 2
three documents say?
Are the control rooms all outside the i
3 fence?
4 MR. KING:
The HTGR is outside the fence.
5 MR. MICHELSON:
Are they in a vulnerable 6
location from the viewpoint of a truck bomb?
i 7
MR. KING:
From our review to date the control 8
rooms have no safety function.
If the truck bomb went in 9
and blew it up --
10 MR. MICHELSON:
They have been a'nalyzed for 11 instantaneous loss of control room and personnel and 12 there's no safety problem?
Is that what you are saying?
()
13 MR. KING:
From a review of the data it looks l
14 like that's the case.
I'm not willing to --
15 MR. MICHELSON:
The instantaneous loss of 7
16 control room --
I 17 MR. EBERSOLE:
What about the intake building 18 and a sabotage barge collision with appropriate explosives 19 or incendiaries.
20 MR. KING:
The balance-of-plant as proposed in 21 these designs has no safety function.
It is not there for 22 decay heat removal.
I 23 MR. MICHELSON:
You don't need any water?
24 MR. KING:
Don't need any water.
Everything k
25 that's required for decay heat removal is in a protected
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1 area in the nuclear island 2
MR. MICHELSON:
And the doesn't have to be 3
cooled from the outside?
4 MR. KING:
Other than natural draft of the area.
i 5
No power.
No operator action.
No valves to close or open.
6 MR. WYLIE:
It's inherently safe.
4 7
MR. EBERSOLE:
Sounds great.
l 8
MR. KING:
Our initial feel is i$has 9
characteristics more resistant to sabotage than the current 10 LWR.
All three designs.
11 MR. WARD:
It has gotten that because you have 12 encouraged them to do it or they were encouraged by
()
13 something or not because it was a requirement?
1 14 MR. KING:
Not because it was a requirement.
15 MR. WARD:
What do you do if after you analyze i
16 these three you conclude that-well, one of them really is 1
17 somewhat vulnerable to a truck bomb near the control room?
ii 18 Let's just say -- what are you going to say in the SER, 19 then?
What would you. say?
The SER?
l 20 Would you say we really don't like this but 21 since we didn't define a requirement in this area, I guess 4
i 22 we'll live with it anyway?
23 MR. KING:
We would probably say our guidance 24 would be to put the control room inside the protective area.
i 25 Otherwise there may be a licensing problem due to sabotage i (:)
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vulnerability.
2 MR. WARD:
How would it be a licensing problem k
3 if there's no requirement?
4 MR. KING:
If we could show there's some safety 5
problem from a sabotage event, I think we could put some 6
words in the SER that would be pretty negative in terms of
{
7 that design feature.
Maybe you are right.
Maybe there's 8
no requirement tied with that but we could be negative in 9
the SER.
10 MR. EBERSOLE:
The CRGR would stop you because 11 they would demand a probabilistic study and sandia would go 12 off and fill reams of paper again.
()
13 MR. KING:
We went through this on the SAFR 14 plant where they had their steam generators, because 15 there's sodium on the shell side and water on the tube side i
16 they have to have a pressure relief system.
If there's a 17 sodium water reaction there's a ruptured desk and all 18 inventory blows out into a tank that tank it blows out into 19 was not in the protected area.
We looked at it from early 20 on in the design as to one of these early interactions we 21 had, looked at it from the sabotage standpoint and said we 22 sure think that tank ought to be inside the protected area.
23 They moved it.
24 MR. MICHELSON:
One of the things you have to be 25 real careful about is declaring that you don't worry about, ACE FEDERAL REPORTERS, INC.
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say loss of the control room -- that's taken care of by 2
other means.
3 Are you aware of working on a generic issue
~
4 concerning system interaction and its true significance.
5 For instance, in making your statement on the 6
control room you probably have gone through an analysis 7
that says I don't need this function, this, or this 8
function.
9 You haven't gone through, necessarily what the
]
10 analysis says:
Here are the ways in which this particular 11 device in the control room can fail.
Here are what the 12 spurious or unwanted actions it can cause as a result of j ()
13 those failures are, in terms of effects out in the' plant.
14 And so forth.
I'll bet you haven't done that.
You just 15 said I don't need the function because they are satisfied 16 locally.
That's how far your analysis has gone to date 17 because you don't know how to do the systems interaction 18 without quite a bit more thinking than the agency has given.
19 It sounds fine on first blush but it may not be so nice 20 when you get to the details.
21 MR. KING:
We got to the issue on the HTGR.
22 Maybe Pete will correct me if I'm wrong.
What we said was 23 no, that analysis has not been done.
They are proposing 24 that the control room can't cause any detrimental effects 25 to the safety systems of the plant.
We said you are going
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to have to do a systems interaction type analysis to show 2
that.
It doesn't necessarily have to be done now at the 3
conceptual design stage but the SER will say that that 4
system interaction analysis will have to be done as part of 5
a licensing review and will have to be demonstrated.
6 That's the kind of guidance we'd have in the SER.
7 MR. MICHELSON:
It's almost an unlimited 8
possible combination of things depending on the device 9
being used to destroy the control room, how fast, whether 10 it's a heatup or instantaneous explosion or just what.
11 There's a whole lot of time and history that will vary how 12 these interactions will occur.
()
13 It's almost fascinating, you can't just suddenly 14 chop off the control room and throw it away.
You have to 15 worry about how it interacts as this scenario evolves, the 16 time sequence of those interactions.
Boy, they get 17 fascinating and I don't really know how you do it.
18 MR. KING:
What's proposed, using the HTGR again 19 as a control room, no matter what you do or don't do in the 20 control room the plant can still shut itself down and 21 remove decay heat.-
22 MR. MICHELSON:
It has functions locally that 23 can do it.
The question is do you get to them before the 24 interaction signals get to them that cause other things to 25 happen.
You have to have a great depth of understanding on O
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the total logic arrangement of'this system as to whether 2
you are even locked out of actions locally depending on how 3
the control room failures were occurring.
A lot of control 4
room failures lock out local operations.
5 MR. KING:
With a passive decay --
6 MR. MICHELSON:
You have to be terribly careful 7
with design.
8 MR. KING:
Let me pursue that a little further.
9 With a passive decay heat removal system and a shutdown 10 system that relies on negative temperature feedbacks, there 11 is not much that can happen in the control room that can 12 turn those off.
There's nothing that can happen.
()
13 MR. MICHELSON:
You do have to take heat out of 14 that building somehow.
You are generating heat in that 15 building.
It cannot be confined in the vessel forever.
It 16 must be removed.
17 I would go and just take a hard look at the heat 18 removal mechanisms and how they can be inactivated or how 19 spurious operations can cause loss of this or that in an 20 unpredicted sequence such as to damage that equipment in 21 the short term and make it unavailable for the long term.
22 Ultimately you will get maybe a little hitch if you haven't 23 thought through every step because you do have to take the 24 heat out.
There's no such thing as a device that can take 25 it own heat.
In a nuclear reactor you can't take the heat
)
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1 forever.
You have to remove it.
And it has to take active 2
components to do it.
3 I haven't seen a proposal yet that will absorb 4
its heat forever without being transported out in some 5
fashion.
6 MR. KING:
These designs are designed not to 7
have it.
Natural convection of air over the vessel.
8 MR. MICHELSON:
Radiators?
No fans?
Nothing?
9 You are going to circulate the liquid from the reactor out 10 into the exchangers?
11 MR. WARD:
You have to look at the designs.
12 They claim it will do it.
(')
13 MR. MICHELSON:
There's no valves in any of this 14 that they can be closed?
15 MR. KING:
No.
16 MR. MICHELSON:
That's truly great.
Very low 17 power density --
18 MR. KING:
In principle what you are saying is 19 right.
You have to look at the control room very carefully i
20 to see what vulnerabilities it has and certainly at the 21 conceptual stage we are going to look at it:
Does it have 22 the potential of being -- having a nonsafety implication.
23 MR. MICHELSON:
It's a true walkaway situation?
24 MR. KING:
Essentially.
At the control room.
25 MR. MICHELSON:
You can fiddle with the controls O
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anyway you want to, no matter what you do wrong you can 2
walk away?
i 3
MR. KING:
That's what's being proposed.
i l
4 MR. MICHELSON:
That's a good design criteria.
a 5
Put that down number 1.
I don't think you'll need any 1
j 6
other design criteria.
2 I
7 MR. KING:
Our job is to see --
)
8 MR. MICHELSON:
I haven't seen that one written 9
down anywhere.
I didn't realize it was going to go quite 10 that well.
11 MR. WARD:
That's not a criteria they proposed 12 but that's what they are getting in some of these design j ()
13 concepts.
14 MR. KING:
But because they are proposing a f
15 design like that they are saying we wanted relief in some 1
l 16 other areas.
That brings me to the last bullet here.
I j
17 They want credit for the advanced design j
18 capabilities.
They don't want to have diesel generators, l
19 emergency evacuation plans, safety grade control room, and 20 several other things.
l 21 I think our job at this conceptual design stage 22 is to see, based on the design and potential for that l.
23 design to achieve these good inherent safety 24 characteristics, where could we back off and give credit in i
j 25 some of those other areas?
That's really the key guidance o C:)
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l 30692.0 94 BRT (2) l that's going to come out et the conceptual design review j
i i
2 stage and that's the intent of the Commission's policy 3
statement and that's really the bottom line of the approach 4
I 4
the Staff has taken.
We'll get to the point where we give 5
some guidance in that area.
j 6
Granted maybe five years from now if new I
7 information comes in that guidance may not be any good but i
8 it's better than not interacting at all until the OL stage 9
-- PSAR.
i 4
10 MR. MICHELSON:
I recall a long time ago a 11 reactor concept that did require a pump but other than that 12 it was just a type of pot.
I'm hoping this does work well
()
13 and even doesn't require the pump, the air to air, natural j
14 convection, no louvers on the air -- nothing like that --
4 15 oh, boy.
1 j
16 MR. KING:
If you can come out to Gaithersburg 17 next Wednesday you'll see these designs.
4 18 MR. WARD:
He won't be.there.
Do these design 19 concept descriptions suggest areas of tradeoff?
l 20 MR. KING:
Yes.
I don't think there's any one f
21 section you could turn to that says here's the tradeoffs 1
22 but --
23 MR. WARD:
But throughout they are suggesting j
24 things?
And you are going to respond to those in the SERs?
25 MR. KING:
Yes.
Yes.
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A good example is emergency diesel generators.
2 They are proposing they not be safety grade diesel 3
generators because AC power isn't needed for any of these 4
safety functions.
5 MR. EBERSOLE:
Gee, when you say that you really 6
have said an advantageous thing.
7 MR. MICHELSON:
No batteries?
8 MR. KING:
We don't need batteries to do 9
anything to open or close valves.
You have batteries 10 because you want to have instrumentation on line so you can 11 confirm what's happening.
12 All right, the next area is the related policies,
()
13 practices and regulations.
14 MR. EBERSOLE:
The single failure criteria.
15 Just stick with that the way we have it now -- we are lost.
16 MR. KING:
I couldn't hear you.
17 MR. EBERSOLE:
We have too many examples of the 18 single failure criteria breaking down.
Maybe Davis-Besse 19 is the best example.
Or SONGS.
There's lots of them.
20 MR. MICHELSON:
Jesse, there isn't anything to 21 fail so why worry about the single failure?
22 MR. EBERSOLE:
If that's so why is it up there?
23 No active --
24 MR. WARD:
Let him say what he 's going to say.
25 MR. EBERSOLE:
No active failures?
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1 MR. KING:
What this NUREG is saying is defense 2
in depth is still a consideration in those reviews, no 3
matter what criteria a designer is going to come in with 4
and propose.
He are still going to look at these plants 5
from the standpoint of do they need things like multiple 6
barriers?
The question of prevention versus mitigation?
7 Multiple systems.
8 Are the uncertainties large enough that we may a
9 want to add an additional barrier?
An additional system?
10 Certainly, at least a single failure criteria is 11 going to have to be applied.
I don't think we are going to 12 make it -- have a design where you say I just can't get a
()
13 leak in this particular pipe or this particular vessel.
I 14 think it's going to have to be considered.
15 What we are trying to say in this NUREG is not, 16 in all of these things how they are applied are design 17 dependent so we can't say exactly how they are going to be 18 applied but we want to get across in here that these are 19 the kinds of considerations that the Staff is going to have 20 to look at when we review a specific design.
21 MR. EBERSOLE:
Keep in view that the single 22 failure criterion when it is applied to the complex systems 23 before today where there are thousands of interdependent 24 elements it only takes two discrete failures, sometimes of 25 dif ferent kinds -- maybe one a valve here and a DC power O
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1, 1-supply here or whatever -- it only takes two to lock the 2
plant up.
You can find lots of just two failures that will 3
lock up the plant.
4 MR. KING:
You may be right.
I can't say yes or 5
no to that.
6 MR. EBERSOLE:
It's a daisy chain of infinite 7
length.
You can pull out one here and one way down here 8
and the chain breaks.
So the single failure criterion 9
makes very little sense when there are so many 10 interdependencies.
I think you can say something about 11 this.
12 MR. KING:
I think that's where a PRA helps you.
()
13 If multiple failures are possible and they are likely to 14 occur, a PRA should pick those out.
15 MR. EBERSOLE:
They have relate to the number of 16 interdependencies.
17 MR. KING:
Certainly on the HTGR, a PRA is being 18 used to select the accident -- design basis accident anyway, 19 whether it's a single failure or multiple failures, if it 20 has a probability greater than 5 times 10 to the minus 21 7th, in the case of the HTGR, it is thrown in the design 22 basis anyway.
23 MR. EBERSOLE:
Yes.
24 There is another sense of the single failure 25 criterion I always found troublesome and that is how long O
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does it last?
Is it a failure which, if it occurs and 2
locks you up in half a minute you've had it?
Or can you go 3
patch it?
4 I can stand a single failure criterion made out i
5 of 14 dozen two-by-four boards as long as I could patch it 6
as fast as it broke.
So there's no time depth for it.
7 MR. M ICHELSON:
That's included in the PRA, 8
though.
That's all supposed to be factored into a good PRA.
9 MR. EBERSOLE:
What can you do with time?
j 10 MR. KING:
Time is a consideration.
I think 11 time can be considered a barrier, itself, or a line of 12 defense.
! ()
13 MR. EBERSOLE:
Time is of no value, though,
]
14 unless you defined what you are going to do within it and 1
15 that is not done.
l 16 MR. KING:
That's right.
17 MR. EBERSOLE:
So time is of no value if you are j
18 locked out.
19 MR. KING:
That's right.
20 I didn't plan to come in here and come up with a j
21 new single failure criteria for the industry.
The intent l
22 of this was to get across that the Staff is going to have 23 these considerations when we look at your plant.
We are 24 not throwing that out the window because you are calling l
25 these plants advanced.
O i
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MR. MICHELSON:
Just as aside question, the PRA 2
doesn't even think about a single failure criterion?
It is 3
not a consideration of the PRA, is it?
4 MR. ROSZTOCZ Y:
Yes.
5 MR. MICHELSON:
I thought you went through all 6
events and probabilities and just put numbers on those.
In 7
your cut sets you can get any combination depending on what 8
comes through?
9 MR. ROS ZTOCZ Y:
In event the system can function, 10 then the probability of the single f ailure is higher and 11 it's a system failure, common mode failure, so you carry 12 that probability and then you combine it with other single
.sj 13 or other multiple failures and if the -- as long as the 14 combination is coming up high, then it stays.
If it comes 15 low then it gets cut out.
16 MR. MICHELSON:
Sort of a way to examine that 17 indirectly because you have done all your fault tree 18 probabilities and branched them, you have your combination.
19 It's always what you haven't thought of is what creates 20 uncertainties or whether your numbers aren't right that 21 creates uncertainties.
22 MR. ROS ZTOCZ Y:
When you are handling a system 23 which was designed against a single f ailure, then it should 24 not be in there, that the probability should be so low --
25 the probability of losing the function should be very, very f}
(_-
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low because you design against it.
But in a PRA you are 2
also faced with systems which were not designed against a 3
single failure and then it comes into play.
4 MR. MICHELSON:
And a PRA never includes what 5
you haven't thought of.
It can't.
You can't draw it in as P
6 input if you can't think of it.
7 For instance, water running down a ventilation 8
duct and pouring out onto a board.
Unless you thought of 9
that as a possibility for_a pipe break somewhere else in 10 the building the PRA wouldn't deal with it -- wouldn't 11 recognize the loss of that board as a result of the pipe 12 breaking.
If you hadn't realized and didn't tell the
()
l 13 program that there is a route here.
You can't even put a 14 probability on it existing if you don't know about it.
15 MR. ROS ZTOCZ Y:
I think that statement is true
~
16 for everything.
Not just the PRA.
If we haven't thought 17 of it, we don't put it into our codes.
18 MR. MICHELSON:
So what you know or thought 19 about, not covering all system interactions -- you just 20 can't do something you don't know about.
21 MR. KING:
The other policies practices we 22 address in the NUREG, we state we expect advanced' plants to 23 comply with the safety goal.
It might be self-evident, but 24 we put the words in there anyway.
We expect them to comply T
25 with the severe accident policy and the implementation O
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i l
1 guidance that comes out of the Staff's work on the severe i
2 accident policy.
'3 Some of that guidance may be specific to LWRs.
4 We'll have to look at that.
But,.in general, we are 5
expecting advanced plants, we require advanced plants to 6
provide a PRA at the conceptual design stage to evaluate 7
its plant against TMI actions,. unresolved actions,
'8 unresolved safety issues,.the things that are called for in 9
the advanced reactor policy statement. 'In reviewing.the
-10 three DOE plants we are asking that they make that 11 comparison as part -- at the-conceptual design stage.
12 The source term changes that are going on for LWRs.
O 13 ao#'t x o it ther 111 de e9911cee1e to theee 9 e#te or 1
14 not, but if they are it.would certainly allow them --
15 consider them for application to the advanced plants.
16 Standardization policy, we are not asking to 17 standardize ---
18 MR. MICHELSON:
Excuse me.
On source term, if I 19 understand it correctly, we've kind of arrived at these 20 source terms based on mechanistic changes -- as.we look at 21 the source term,.we have modeled, I think, what is 22 happening in order to arrive at some percentages of which-J 23 elements get out in the environment and so forth.
But that 24 model is presently a light water reactor fuel 2S disintegration model of some sort for source term?
We
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hvven't done source terms for a HTGR, have we?
Or is it 2
the same?
3 MR. ROSZTOCZ Y:
I believe that statement is 4
correct.
The work that has been done in recent' years, and i
5 a large amount of work has been done, was basically having 6
in mind the water reactors.
How easy it is to transfer 7
this, to establish a gas-cooled or sodium reactor with 8
maybe a somewhat different fuel design and different fuel 9
concept, I am not sure.
1 10 MR. MICHELSON:
So there isn't a magic source 11 term for all reactors?
12 MR. ROSZTOCZ Y:
The new approach to source term
()
13 that you mention, it's up to now due to current calculation.
14 The source term is really not dependent -- it arbitrarily 15 says take so much of.the particles, so much of the solids --
16 that's what you work with.
17 MR. MICHELSON:- But it's really a water reactor --
18 the way it was developed was developed considering water-19 reactor data?
20 MR. ROSZTOCZ Y:
That one is so coarse that one 21 might argue that something simildr, not necessarily the 22 same numbers but based on today's knowledge, some similar 23 thing could be established which would cover those -- I'm 24 not sure, Pete might be able to tell us whether we use the 25 same source term for the Fort St. Vrain case?
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MR. WILLIAMS:
I'd be very happy to comment on 2
that.
My name is Pete Williams.
3 Fort St. Vrain's source term had its roots in 1
4 the old TID.
However certain modifications and time delays 5
were allowed.
6 MR. MICHELSON:
The percentages were the same, 7
just the time sequence was different?
8 MR. WILLIAMS:
The iodines were the same.
But 9
it was a dif ferent design basis accident.
But the 10 fractional releases were the same.
11 This.was more or less continued with the 12 conceptual plans that were done, developed during the
()
13 million dollars '70s, although some modification, again, 14 with time delay, was allowed so the two-hour dose was not a 15 large factor.
With the MHTGR, a new source term is being 16 determined based on the fact that the fuel is not designed --
17 the fuel design -- design should not permit the fuel to 18 exceed a certain temperature where a large fraction of 19 these products would be released.
That's our review; it is 20 developed to agree with these.
21 MR. MICHELSON:
What about the severe accident l
22 source term?
23 MR. WILLIAMS:
This is what is proposed.
24 MR. MICHELSON:
The severe accident is where 25 things have got way out of hand of your predicted
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temperatures, wtgtever, in some manner, melting the core a
2 down.
3
.Would the source term be any different for a 4
metal reactor in that case than it would for a water 5
reactor?
6 MR. WILLIAMS:
I can't go into the full' design 7
details --
8 MR. KING:
Maybe I ought to comment on that.
9 What is being proposed is to get to a situation where you 10 have wholesale releases from the HTGR, would be such a low 11 probability event that what is being proposed is we don't 12 have to consider events of that low probability; therefore,
()
13 we don't have to consider' the source term either for siting 14 or emergency evacuation.
15 MR. MICHELSON:
Even under the severe accident 16 policy you don't have to?.
17 MR. KING:
What is being proposed is even under 18 the severe accident policy we don't have to go that far in 19 looking at severe accidents, because the probability of the 20 event that gives you the wholesale problems in a HTGR is i
21 very, very low.
22 MR. WILLIAMS:
I would like to say one more i
23 thing.
It's mentioned meltdown, a HTGR really has a 24 surrounding core.
25 MR. MICHELSON:
..e are thinking of the whole ACE FEDERAL REPORTERS,' INC.
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" advanced" spectrum, not just HTGR.
2 MR. EBERSOLE: -When we get!into this term " source 3
term," it always bothers me; I don't think everybody knows l
4 what they are talking about.
The source term historically 5
is'what gets outside the containment.
You are talking 1
6 about what gets out of the fuel, aren't you?
7 MR. KING:
The HTGR, they call their fuel the 8
containment.
There is no containment building.
9 MR. EBERSOLE:
Oh, okay.
In that case -- but I 10 think it ought to be a sharply defined thing.
11 MR. KING:
You have to define what you mean by 12 source term.
I agree.
()
13 MR. EBERSOLE:
The classical one is what-leaked 14 out of the containment.
I 15 MR. KING:
Traditionally on LWRs, it's what's 16 leaked to the containment building and then you get a leak 17 rate.
18 MR. EBERSOLE:
I'll'make a contest on that; it's 19 what gets into the atmosphere.
20 MR. WARD:
It is whatever your footnote says.-
21 MR. EBERSOLE:
That's right.
When you get down 22 to it that is what it should be.
1 i
23 MR. SIESS:
Maybe that's another service you I
24 could provide.
Define source term.
25 MR. MICHELSON:
Yes.
(:)
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MR. SIESS:
Source term-A, B,
C, level 1, 2,
3 --
(
2 MR. EBERSOLE:
Am I right, isn't it where you-3 start applying meteorological distribution?
4 MR. SIESS:
Why don't get it down to the point 5
where somebody.is exposed to it?
6 MR. EBERSOLE:
I don't care what it is.
Just 7
define it, for God's sake.
8 MR. KING:
When we write the SER, we are going 9
to have to be clear on it.
10 MR. SIESS:
It's the inventory of radioactive.
11 materials on various stages of the game.
12 MR. MICHELSON:
It depends on which game is
()
13 playing at the time.
14 MR. SIESS:
The same thing with prevention and 15 mitigation.
Is the containment mitigation against what's 16 inside the containment, it's prevention if you are outside 17 the containment.
s 18 MR. EBERSOLE:
The the gas reactors can surely 19 claim with merit it's what gets outside the fuel.
20 MR. WARD:
Okay.
Why don't we go ahead.
21 MR. KING:
Standardization policy.
We have some 22 words in the NUREG on standardization.
The intent of those 23 words is not to standardize at the conceptual design stage.
8 24 The intent of those words is to encourage designers to'
)
25 think standardized plants for future advanced plants and
()
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l then at the conceptual design stage things like 2
modularization or standardized construction practices ought 5
3 to be factored in early in the design stage, because if-we 4
are shooting for a standard plant they ought to take 5
advantage of these kinds of things that can contribute to 6
standard plant.
7 We also asked that they implement the completo 8
design for review at this stage; not just a~ portion of it.
9 Again, that's consistent with the Commission policy on 10 standardization which is shooting for the whole plant to be 11 standardized so we want to see the whole plant at this 12 stage.
3
()
13 MR. WARD:
Does that mean -- I guess I don't --
i 14 this is probably another dumb question but after the stage 15 of -- let's say somebody decides they want to build a PRISM 16 plant.
Next year you write the SER, and conceptual -- and 17 you say and they are encouraged and go ahead.
Could they 18 just apply for a construction permit at that time to build 19 one plant?
Or do they have to go through the process as if 20 there was intention to build several plants and go through 21 the design certification?
22 M R.- KING:
They could apply for one.
They could 23 apply for standard plant review right through certification.
24 There's no restriction on what they apply for.
We are 25 encouraging they follow the standard plant review route
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through certification -- follow the Commission's policy on 2
standardization.
And then utilities that want to buy that 3
plant would reference that design and build it.
But 4
there's no requirement that says that they have to go that 5
way.
They could go the other way.
.6 Existing regulations and guidelines -- we are 4
7 going to state in here they have to be reviewed for 8
applicability at the conceptual design stage.
9 Lastly, we encourage the use of industry codes 10 and standards.where practical.
ANS has developed and has 11 under way at the present time. liquid metal reactor 12 standards.
We would like future designers to build upon
()
13 those.
HTGR, the ASME code has sections for HTGR, and 14 apply to the HTGR as well as the liquid metal reactors.
We 15 would like advanced designers to build upon those.
16 There's considerable thought and energy and 17 effort put into developing those.
We'd like to see those 18 used.
19 (Slide.)
20 Supporting technology.
This is pretty important.
]
21 These are new designs, they are paper designs.
What 22 supports those designs?
We have some words in tho'NUREG to 23 sort of list the things we want to see presented at the l
24 conceptual design stage that support the design.
j 25 What existing operating experience?
Tell us O
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1 what existing operating experience supports the proposed 2
design.
3 What R&D programs are they proposing to support j
4 licensing that design?
Foreign information and data?
5 Specifically we say we ought to not only look at it, but if 6
they want to use it in terms of supporting their license, 7
we would consider that acceptable as long as we have full 8
access to the data.
9 The prototype test.
The Commission's policy l
10 statement says that a prototype is not required.
In a 11 general sense, we are not saying every new plant has to i
12 have a prototype.
The policy statement says that.
What we
()
13 are doing is putting a little.more definition on what that l
14 means in the draft NUREG.
Basically what we are-proposing i
i 15 is there be a case-by-case judgment.
As we look at each j
16 design we'll make a case-by-case judgment as to whether we 17 believe prototype ought to be built-before we would license 18 the plant and the things we would consider in that judgment 19 are:
Departure from proven technology; what are the 20 uncertainties in its performance; the degree of defense in i
21 depth -- by that I mean if they have some new, novel future 1
22 but it's backed up by something more traditional and we 23 have more confidence in it_maybe wo won't have to build a 24 prototype to test the novel feature.
But if they have a 25 novel feature and they are relying on that as a key safety O
i
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I characteristic of the design, maybe we will want to see it 2
tested, and any R&D that they are proposing.
3 MR. WARD:
I guess this issue of prototype or 4
not is -- there's already a policy issued and agreed to, 5
although there's going to be some interpretation.
But I 6
sure find it hard to believe that -- there was sure an 7
awful lot of prototyping of LWRs.
You know, lots and lots.
8 And to think that we'd really go charging off towards some 9
standard design of LMR or something without more i
10 prototyping just seems to me to be so unrealistic that it 11 is not useful to talk about it.
j 12 MR. KING:
There's two aspects to the prototype;
()
13 one, the safety and licensing aspect; and one, the market 14 ability aspect.
We are looking at the safety and licensing 15 aspect.
You need a prototype to verify that plant is 16 licensable and safe.
l 17 I think when you look at the marketability maybe-i 18 the need for a prototype is even greater because if I were 19 a utility I wouldn't buy one of these new designs until 20 somebody could prove to me that it works, it has the 21 availability that's advertised, you can build it at the i'
22 cost advertised, and DOE is considering, you know, both j
23 needs -- both of those aspects in looking at the prototype.
i 24 We have to make that distinction in our review.
i 25 MR. WARD:
Even from your standpoint, I don't ACE-FEDERAL REPORTERS, INC.
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know, I'd certainly be inclined to say the prototyping 2
would be the norm and you might consider exceptions from-
}
3 that.
If they could be justified.
i j
4 MR. KING:
On the three DOE plants -- well, the 5
two LMRs are proposing prototypes.
The HTGR is not for 6
licensing.
)
7 Basically the position we are going into the SER 8
with or going into the review with is that for the HTGR, we 9
believe a prototype is necessary unless you can demonstrate 10 why it isn't.
I don't have an answer to that yet, but 11 that's my own personal approach to looking at need for 1
12 prototype.
It is significantly different in a' lot of ways.
.( )
13 than what has ever been built before.
14 MR. MICHELSON:
We are talking certifying the 15 design even without a prototype.
I wonder if the FAA has 16 over certified an aircraft as airworthy without at least 17 two or three of them built first.
i 18 MR. SIESS:
They have to be.
The prototype has 19 to be flown before it's certified.
i 20 MR. MICHELSON:
But under a special license, not 21 for public use.
22 MR. SIESS:
I'm sure a plane is flown and tested, 23 flight plan maneuvers before it's certified.
24 MR. MICHELSON:
I think the FAA requires a 25 minimum of three of those aircrafts.
(
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MR. EBERSOLE:
Even the military aircrafts have i
2 to have X-Bs, Y-Bs, and whatever.
3 MR. MICHELSON:
Here we are going to certify it 4
off the paper without one over having been built.
5 MR. KING:
That's DOE 's proposal on the HTGR.
6 MR. M ICHELSON :-
That's hard to buy.
7 MR. KING:
They believe between the R&D program 4.
8 that supports the design, the existing experience, Fort St.
9 Vrain and worldwide experience, and the inherent safety 10 characteristics which have lots of margin to account for 11 uncertain' ties, they they can demonstrate we don't need a 1
12 prototype.
That's one of the questions we are going to g ()
13 have to wrestle with in the SER.
14 MR. SIESS:
Even setting and certifying a 15 prototype doesn't guarantee they don't fail.
They still do 16 and they still kill people.
J 17 MR. MICHELSON:
But it certainly narrows the 18 uncertainty.
19 MR. SIESS:
It only narrows some of the 20 uncertainties.
They don't crash one to see if it will burn.
21 MR. EBERSOLE:
While you are in this matter, are 22 we going to resurrect the old idea we started with that we l
23 go out to Idaho or Arizona or someplace, that we start with 24 the most assured piece of comfort we can get, which is 25 space from sensitive conters in -- after all, I think i
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that's something we all know we can res11y count on.
1
^
2 There's a bottom line safety. feature.
3 MR. KING:
The PRISM design does do that.
Their 4
long-range plan is to build a module in Idaho, run it
^
5 through its paces and demonstrate it works.-
6 MR. EBERSOLE:
So the price ~is long transmission 7
line.
That's all right.
8 MR. KING:
It may not even have a turbine on it.
j 9
It may just be a test without a turbine to demonstrate the 10 safety.
That's their approach.
11 The SAFR design, I'm not sure where they will 12 build it, but they will build one to go on a grid somewhere
()
13 but they would build it and test it before certification.
1 14 The idea on the HTGR is not to do that.
15 MR. EBERSOLE:
Palo Verde is a fine example of 1
t 16 where to put plants.
l 17 MR. MICHELSON:
Does the HTGR look like Fort St.
18 Vrain?
19 MR. KING:
No.
The fuel blocks do, but the rest I
i 20 don't.
I 21 MR. MICHELSON:
That's the only one of any 22 significant size built.
The foreign experience is a little l
23 help, but that's also not looking too much like this.
24 MR. KING:
They are relying on the AVR in 25 Germany.
1 1
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MR. MICHELSON:
They are relying on what you 2
think it is.
Not what you know.
]
3 MR. KING:
Certainly as we get into this review, 4
and we are going to get back into these issues as they 1
l 5
apply to these specific plants, this isn't the end.
All of
)
6 these things we are going-to have to address on the
{
i 7
specific plants.
}
8 My last slide deals with less prescriptive 9
criteria.
The policy statement the Commission issued I
10 stated in there, where we don't build upon LWR cited 11 criteria, the Commission would consider the use of less q
i 12 prescriptive criteria on advanced plants.
O 12 ue tried to eee in the sua80 eo e auideace ee to 1
1 14 what kind of information do we need, what kind of 15 considerations have to be addressed if we are going to use 16 less prescriptive criteria.
1 17 Uhat is in the NUREG is basically eight areas 18 that someone, a designer was proposing less prescriptive 19 criteria for the plant,'would have to address in order for a
20 us to consider those criteria as being acceptable.
21 These eight items came from a program we had 22 with MIT over the past couple of years, where they used an j
23 example of nonprescriptive criteria.
What it was was a 24 nonprescriptive criteria to deal with loss of off-site J
25 power.
They proposed a probabilistic goal that loss of i O 1
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off-site power would not be -- not contribute more than a 2
certain fraction of the core melt frequency.
They applied 3
that to an LWR.
4 This was an example, trial type example to see 5
how does nonprescriptive regulation work.
As part of that 6
study, we reviewed what they came up with and came up with 7
what we felt were the considerations that someone would 8
have to address if they were going to actually go forth 9
with less prescriptive criteria like that.
10 Basically these eight, the ones that come in 11 with less prescriptive criteria -- they have to talk about:
12 What does this criteria mean in terms of a change in scope
()
13 of regulations?
Are they proposing that some don't apply 14 any more and this new proposed criteria replaces certain 15 things?
We have to have a good understanding of what that --
16 the implications of that are.
17 Does the -- how does the nonprescriptive 18 criteria, less prescriptive criterion enhance safety?
And 19 why do it if it's not going to enhance safety?
20 How can you preserve defense in depth?
Are you 21 going to get caught into an argument on a probabilistic 22 type goal?
You are in a numbers game trying to show that 23 your one system does the job and are they proposing to get 24 rid of defense in depth?
They are going to have to address 25 that question.
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The impact on standardization, a designer, 2
probabilistic goal, probably a guy can meet it 10 different 3,
ways.
That's not condusive to standardization, and if it 4
leaves it up to each individual designer to design his 5
plant, you know, on a case-by-case basis, that is something 6
we need to understand.
How are they implementing 7
standardization if they go with less prescriptive criteria.
8 The scope of supporting analysis.
You have the
~
9 probabilistic goal and some less prescriptive goal.
What 10 kind of analysis is required to support meeting that?
They 11 need to provide, tell us what their thoughts are on that.
12 Then standard methodology.
Whatever analysis
()
13 you do decide you need, we feel there should be some kind 14 of standard methodology so you are not into haggling how
~
15 you calculated things.
16 MR. WARD:
What do you think about that?
Is 17 there any realistic potential for this approach?
I mean, I 18 think one of your public commenters or somewhere I read 19 concern with this sort of approach is you are going to end 20 up haggling forever about analyses rather than designs.
21 Maybe that's better.
Maybe that's worse.
I don't know.
22 MR. KING:
It's a certain, certainly.
At our 23 level it is a concern.
He don't want to get into a 24 situation where we are haggling over numbers and haggling 25 over designs.
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(
l We want to make sure that if we accept using l
2 some less prescriptive criteria that we know what the 3
ground rules are that have to be met or demonstrated to 4
show that you meet that.
Just don't come in with~a 5
criteria and say we are going to meet this without an
]
6 understanding of how you are going to meet it.
That's 7
basically what we are saying.
We just don't want somebody 8
to propose a criteria without having thought about these 9
things and telling us how, if we implement that criteria, 10 how are these things going to be addressed.
11 MR. EBERSOLE:
When you say before they tell you 12 how to do it that means in substantial detail early enough
()
13 so there-is no longer this great horrible tripling of costs 14 to fix things that are already cast in place.
15 MR. KING:
That would be the intent.
That we'd 16 have the ground rules --
17 MR. EBERSOLE:
So you'd have then a 18 configuration in detail that you could sign on the bottom 19 and say:
Build it.
l 20 MR. KING:
We'd have a procedure that when they 21 do the final design -- and they address these things, and 22 follow the ground rules that are laid out after they 23 address these things --
24 MR. EBERSOLE:
That's a little far away.
When 25 you have say " procedure" you leave me a little bit --
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MR. KING:
We are not going to have a final 2
design at the conceptual stage, but what we'd have is an 3
understanding of how you would implement this.
4 MR. EBERSOLE:
At a later stage you would have 5
in hand a relay number and a contactor and a motor and a 6
pump, whatever?
7 MR. KING:
Yes.- We'd have to know when we look 8
at that final design and look at that criteria that that 9
final design supposedly meets that we know how we are going i
10 to make that judgment that it's okay or not okay.-
11 MR. EBERSOLE:
You think these individual pieces 12 and components would be of a quality suitable for
. ()
13 certification as a module or component?
14 MR. KING:
At the final design stage we are j
i 15 going to have to agree on how much of that detail do we 16 have to know and have to certify.
t 17 MR. EBERSOLE:
I'm looking at this like on a 4
18 generator on an airplane engine or something.
It's a good 19 part.
4 20 MR. MICHELSON:
At the conceptual stage it 21 appears to me that this is a rather impressive list of 22 things that both the originator of the concept will have to 23 develop and the Staff will have to review.
24 Is it Staff equipped -- keeping in mind it will j
25 take a lot of homework to come up to speed, even, to which i
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to review some of these concepts from a totally new 2
viewpoint?
Is the agency ready to commit to that -- commit 3
that kind of resources?
You don't do it with seven people 4
on one little group, that's for sure.
5 Thbse are a lot of areas in which the Staff 6
itself has probably never sat down and given great thought 7
to as to how it applies in the case of gas-cooled or 8
whatever.
9 This must be quite a manpower intensive effort 10 to do it to the depth required.
11 MR. KING:
Your question, and you have a good 12 point.
I think what you are saying is:
People use the
()
13 term " nonprescriptive" or "less prescriptive" regulation 4
14 kind of loosely.
Maybe until you really sit down and think 15 about what that means and what's the impact on the Staff --
l 16 MR. MICHELSON:
Not just that but having decided 17 that you'll accept, you know, use of broad scale criteria, 18 now that means you -- your review effort is kind of a 19 different kind, because you don't have any previous 20 experience, necessarily, upon which to base it -- base your 21 decision.
22 Each one is an ad hoc review, perhaps a very 23 intense ad hoc review.
You don't know what they are going 24 to come up with having not prescribed ahead of time the 25 bounds on it.
These would be almost boundless criteria
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'l depending on how they are written.
2 MR. KING:
You_are hitting the nail on the head.
3 If you want to shift the nonprescriptive criterion, it is a 4
big job.
.t 5
MR. MICHELSON:
Nonprescriptive criteria can 6
result in very extensive review resources.
They. haven't 7
bounded what they can come in with, i
]
8 MR. KING:
Commission policy says we have tx) be 9
open to consider it and what we are trying to say in this i
10 NUREG is it's a big job.
Here's the things you have to 4
a 11 look at if you are going to consider it.
1
]
12 MR. MICHELSON:
Have we budgeted?
I gather this q ()
13 sort of thing could come in, in the next year, two year i
14 time frame; is that correct?
The conceptual design for i
15 review, could they be within the next 18 months?
t 16 MR. KING:
We've got three now.
17 MR. ROSZTOCZ Y:
We have three of them in.
i 18 MR. MICHELSON:
Do you think the HTGR, for
[
19 instance, is going to come in under this?
How much have j
20 you budgeted?
Specifically, say, the HTGR?
i l
21 MR. KING:
Right now we've got, probably 22 somewhere in the neighborhood of technical assistance money, 23 500 to 700 K.
l 24 FTEs, this year on the HTGR, probably around 25 five or six.
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1 But, granted the HTGR we are not reviewing it 2
under the -- we are not taking a totally less prescriptive 3
or nonprescriptive approach on the HTGR --
4 MR. MICHELSON:
Are you intending to certify the 5
HTGR?
6 MR. KING:
Their long-range plan would be after 7
the conceptual design review is done to come back in and 8
file a formal application for -- and standard plant review 9
that would go through certification.
10 MR. MICHELSON:
That could be certified within, 11 say, two years or three years?
12 MR. KING:
I think their schedule calls for --
()
13 it's in mid-1996 or something.
14 MR. MICHELSON:
Before they come in for an 15 application for certification?
16 MR. KING:
No. To have the certified design 17 review done.
18 MR. MICHELSON:
Oh.
19 MR. KING:
File in
'89, in the
'95,
'96 design 20 approval --
21 MR. MICHELSON:
If it's that long dragged out I 22 guess we can find the money and do the work.
23 MR. KING:
Again, we haven't had anybody come in 24 and say I want to do this design on a less prescriptive or 25 nonprescriptive set of criteria, although what we are O
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1 saying is if somebody wants to come in and do that there's 2
a lot of things they have to address.
i 3
MR. MICHELSON:
They can come in and say we will 4
not use the BDCs, here's what we will be using and that l
5 forces you to review ad hoc the whole way of doing it with 6
whatever you've budgeted.
7 MR. KING:
No, I think what it does is forces us i
4 8
to sit down and figure out what would be the resource 9
implications on Staff if we are going to proceed and do 10 this.
l 11 We are budgeted to review the three DOE designs 12 right now.
This NUREG is not directed exclusively at th'em.
O 13 This is sort of a generic type thing for future application 14 for future reviews.
15 MR. WYLIE:
You are comfortable with the present a
16 resources to do your work that you have?
17 MR. KING:
For the three DOE plants; yes.
We 18 are not budgeted to do anything more than those right now.
19 MR. WYLIE:
But if something does happen --
20 MR. KING:
We'll have to see what the resource 21 implications are.
22 MR. MICHELSON:
But the resource is just to i
23 review the conceptual design without making certification?
24 MR. KING:
Yes.
1 I
25 All right, the last two items:
What's the O
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impact on NRC's oversight of construction and enforcement 2
at the operating stage and how would you implement 3
backfits under some nonprescriptive or less prescriptive 4
approach?
They need to address that -- concludes my slides 5
if you have any questions.
6 MR. WYLIE:
I have a couple of questions.
The 7
Commission's policy statement listed some attributes which 8
could assist, some of which you have addressed.
9 Did you address the one on -- maybe there's 10 three -- maybe I just missed it -- on providing reliable 11 equipment on the balance-of-plant is one of the attributes 12 they state.
Another is designs that provide easily
()
13 maintainable equipment and components.
And then reducing 14 potential radiation exposure to plant personnel.
15 Is that covered in your NUREG?
16 MR. KING:
No, it is not.
The reason it's not 17 is we didn't try to repeat or give guidance on -- there's 18 11 things listed in the Commission's policy statement, 19 attributes that they would like to see.
We didn't make the 20 NUREG try and address each one of those.
21 We only tried -- put in the NUREG-addressed 22 items that maybe are related from other Commission policies, 23 other Commission practicos, considerations.
We didn't try 24 and expand on each of those 11 attributes unless we felt it 25 was necessary, because there was some other policy or some
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1 other thing in the Commission -- some other consideration 2
that wasn't addressed in the Commission policy statement.
3 MR. HYLIE:
Have you given thought to how you 4
are going to address those?
Or are you?
5 MR. KING:
We are going to address them in terms 6
of doing the review of the designs that come in under the 7
policy statement.
4 8
MR. WYLIE:
You are not going to give them any 9
guidance?
10 MR. KING:
I'm not going to give them any 11 guidance beyond what is stated on the policy statement on 12 those.
Those are --
()
13 MR. WYLIE:
How much more you are going to 14 reduce radiation exposure to plant personnel over what, for 15 example?
16 MR. KING:
That's right --
17 MR. UYLIE:
How you are going to provide more 18 reliable equipment to the balance-of-plant --
19 MR. KING:
Didn't intend to give them any more 20 guidance in those areas.
21 MR. SIESS:
That item on balance-of-plant struck 22 me as a little bit strange.
It says " Designs that provide 23 reliable equipment for balance-of-plant (or safety system 24 independent for balance-of-plant)."
25 In view of the fact that all of the designs you
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1 have got coming in have proposed the parenthetical solution, t
2 I was a little surprised to see the statement, still keep 3
that in parentheses rather than the other way around.
4 This is going to be one of the major issues in
'5 this plant --
i 6
MR. KING:
Yes.
}
7 MR. SIESS:
-- with relation to balance-of-plant, j
8 whether it could be ignored.
9 MR. KING:
Yes.
One of the issues is does the j
10 balance-of plant really have no safety significance?
Both 11 from doing a function, and also from does it contribute to
)
12 challenging safety systems, do failures out there
- O ta coeerieete to ca 11ee9 no eefeer svetems2 1
14 MR. SIESS:
About potential exposure to plant 15 personnel, I think we have some idea from Fort St. Vrain of 16 what you can accomplish there.
j 17 MR. KING:
Yes.
i 18 MR. SIESS:
I think their exposures run two 19 orders of magnitude lower than BWRs.
l 20 Can we achieve anything like that with an LMR?
i 21 MR. KING:
The LMR exposures are less than LWRs, i
22 too.
I don't have the numbers, but I can get you the 23 numbers.
They are lower, probably an order of magnitude.
i 24 MR. EBERSOLE:
Back in '66 I was a little bit i
25 shocked to find somewhere in the ASME -- in the nuclear i
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business, ASME had concluded under the wise guidance of 2
their nuclear colleagues, that they didn't need to have 100 3
percent safety anymore.
As a matter of fact, there were 4
about half a dozen or if not more than that blanked off J
~
5 safety valvo pads on the Browns Ferry plant.
They.had a 60 6
percent relief capacity.
7 That had behind it the convincing to ASME people, i
8 from the nuclear statement that they would always scramble 9
plant.
Okay?
And so they'd get the power down.
10 Well, as you know prior to that time we all had 11 100 percent relief for safety, and the Japanese, I think,
}
12 has high bypass.
t
()
13 So this matter of the influence of the balance l
14 of plant on its ability to receive full power output gets j
15 to be quite a significant thing.
If you are going to turn 16 the turbine off, are you going to demand that you have a 17 full relief capacity for full power?
Or you even might i
18 consider, in the case of the boilers, even depressurizing 19
-- overloading because of the negative power coefficient.
20 I'm just bringing up the subject of balance of 21 plant in this context.
I thought it was sad, and that's 22 really what opened up the ATUS question, because of the 23 autocatalytic effects of pressure on a trip without fashion 24 rod insertion or any rod insertion at all.
(
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1 show that at 4000 pounds in about 30 seconds, if you didn't 2
get the rods going.
3 Whereas it wouldn't have been quite that bad if 4
you had a lot of relief.
And it might have even gone dead 5
if you had 150 percent.
6 MR. KING:
We look at the three DOE designs ' f rom 7
the standpoint of losing your heat sink, losing your 8
turbine, what happens to the primary system.
j 9
MR. EBERSOLE:
What of the most important 10 aspects of balance-of-plant as where does the heat go?
11 MR. KING:
We look at that.
12 MR. EBERSOLE:
You need these to open; not shut.
O 13 an u^ao we11, ta #xe, re -
tee me eaare e
14 question.
The policy statement session a lot about i
j 15 encouraging simplification in designs.
The implementation i
16 plan, Tom, doesn't seem to talk too much about that.
Maybe l
17 that's good.
18 But I guess I sort of am worried or suspicious 19 that all this talk about the wonderful benefits of j
j 20 simplification is blowing in the wind a little bit, and it 1
21 might be doing a disservice to the whole program to really 22 anticipate or pretend that there is really going to be some l
23 big benefit or some big possibilities, safety benefits from j
24 what people call simplicity.
25 I guess my concern is this:
It seems to me that O
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1 the whole history of engineered systems is that, in order 2
to -- as they evolve, to get them to be efficient and 3
reliable -- and reliable, and I really mean that part, they 4
tend to become more complex.
In fact, some of the things 5
we are being asked for under this policy statement were, 6
for example, you talk about making it easier for the 7
operator by automating things.
That's really making the 8
machine more complex, not more simple.
9 I don't want to go on and on.
But I remember as 10 a student when jet engines were new for airplanes at that 11 time, and, man, the big deal was that they were nimple.
12 It's just this rotating thing and it was really simple.
(')
13 Well, they became pretty darned complex and they 14 are, today, awfully complex.
But they are also 15 terrifically reliable and are getting more efficient.
In 16 fact, they are even making them big.
The advantage of 17 scale is very clear with them.
They only put two on big 10 airplanes now instead of four.
19 I just am hoping for some kind of simplicity of 20 the sort that people who sit around the table talk about is 21 not really going to happen.
It's not useful to have a 22 policy that seems to be depending on that.
23 MR. SIESS:
One of the comments on the policy 24 statement I recall pointed out that the early water 25 reactors in this country were simple.
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MR. WARD:
That what?
2 MR. SIESS:
The early water reactors were simple, 3
and we've managed to complicate them quite a bit in the 4
past 20 years.
5 If you ever visited Big Rock or looked at some 6
of the older plants -- and I've seen figures on how many 7
valves -- there's 10 times as many valves in the new plants 8
as we had in the old ones.
And I don't think the designers 9
were responsible for all of that.
10 MR. EBERSOLE:
I would like to say --
11 MR. SIESS:
The regulators had something to do 12 with it.
()
13 MR. EBERSOLE:
I go along with you.
14 MR. MICHELSON:
They had a lot to do with it.
15 MR. EBERSOLE:
When automobiles first came out 16 with automatic transmission they said the damn things would 17 never work.
They have worked very well, but that was in 18 the early '30s.
19 There's two regimes to look at here.
One of 20 them is to improving the plants, and efficiency and 21 reliability and general commercial valuer go ahead and 22 complicate them if you want because it's motivated by 23 making the plant better for commercial purposes, and I 24 don't have any problem with beaucoup systems put on there 25 that work better to get electricity on the lines.
But when (1) 1
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1 I come back to the safety function and our experience, Dave, 2
doesn't include this, when we have potential for disaster 3
as high as we have, these plants are novel, I think, in 4
their need for simple retreats to simple and understandable 5
points of safety.
Like a life boat on a ship is a simple 6
thing.
7 You don't need to think about and analyze as 8
many elements of its features to make it simple.
You don't 9
need to think as hard about it.
The damn thing floats in 10 all kinds of weather.
It doesn't have any silicon intersupport.iv 11 necessities on it.
12 So I think there's really two fields of thought
()
13 here.
One is go ahead and complicate the plant for 14 commercial value just like the automobiles today are 15 getting high efficiency with engines and combustion systems 16 we don't understand.
17 But when it has to go home, I think simplicity 18 is another field within which you can profitably reduce the 19 number of elements to keep it safe so that they are 20 comprehensible by somebody, almost, on the street.
That's 21 why I endorsed the notion of the old man and the shack in 22 the yard, the night watchman who can take a boiler home 23 because all he needs is a jockey pump ~and a gauge glass.
24 MR. MICHELSON:
Why don't you drop the power 25 density on the fuel and --
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1 MR. EBERSOLE:
I don't care how you did it.
2 MR. MICHELSON:
Nobody wants to run it.
Nobody 3
can make any money running it.
4 MR. EBERSOLE:
If you can guarantee you can drop 5
the power density down --
6 MR. MICHELSON:
Drop it down to very low values.
7 MR. EBERSOLE:
On the other hand I like to run 8
things full out, too, Carl.
I just want a place to go when 9
I can't.
10 MR. KING:
Let me say something before we clone.
11 A lot of questions are ccming up on things in the 12 Commission's policy statement.
The policy statement is out.
()
13 I'm not looking to change that.
I'm not suggesting we want 14 to change that.
I'm here saying we'd like to put a NUREG 15 on the street that gives some additional guidance on how we 16 are going to implement that.
That's what I'm looking for 17 some feedback on.
18 MR. SIESS:
I could make a distinction in my 19 mind between a complex system and a system requiring a 20 complex analysis.
21 I can think after multiplicity of systems and
~
22 redundance and all of this, and yet it's easy.to show by 23 analysis how it works and that it works.
I can think of 24 simpler systems, that is one system, say, and we could 25 spend a billion dollars showing that it works.
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~
1 I think -- and there's some emphasis in here on 2
things that are easier to analyze, easier to show.
3 Let's put it this way:
Easier to convince the
~
4 NRC and the ACRS that it will work.
5 MR. MICHELSON:
In the extreme, the university 6
research reactors are pretty darned safe, but you sure 7
don't get much useful heat out of it.
It's a reactor and 8
it generates its energy by nuclear figures.
But extremely 9
low power density but you can walk away; just push a button 10 and walk away.
Fact is, I don't think you even really need 11 to push the button and walk away.
12 MR. SIESS:
The things we are looking at over
)
13 the horizon have large heat sinks built into them.. A big 14 pot of sodium and big chunk of graphite.
And to me that is 15 a major st'ep forward because that simplifies the 16 operational problems and operational transient problems.
17 MR. MICHELSON:
That's right.
That's a good 18 direction to go in.
You are trying to get simplicities of 19 principle.
It buys a lot of time.
20 MR. EBERSOLE:
It raises the question about 21 graphite burning, like sodium.
22 MR. SIESS:
Nothing is perfect in this world.
23 MR. KING:
It's something that has to be looked 24 at.
25 I have gotten a number of comments today that I O
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()
I will factor into the next version of the NUREG.
I'll try 2
and get that next draft to you next week before the full 3
committee meeting.
4 MR. SIESS:
Transparent ceramics that don't burn 5
substituted for graphite?
6 MR. KING:
After the full committee we would 7
like to have a letter giving any additional thoughts or 8
position on this NUREG that you have; and factor that into 9
the copy that goes to CRGR, but that's basically where I 4
10 see things today.
11 MR. WARD:
Okay.
Does anyone -- you know, I 12 guess the course we are on is to have Tom come to the full
(')
13 committee meeting in May.
If the full committee thinks it 14 has something to say at that time it will say it.
I guess 15 they'd like to say something.
I guess I know what they'd 16 like us to say.
17 MR. MARK:
This is the most wonderful NUREG we 18 over saw.
19 MR. WARD:
Does the subcommittee have anything 20 to say?
21 MR. SIESS:
Did we reserve our comments on the 22 policy statement until after the public or did we make them?
i 23 DR. EL-ZEFTAWY:
We made them after the public.
24 MR. SIESS:
Now we are just talking about the 25 NUREG.
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1 MR. MARK:
The policy statement is out even with 2
the misprint that they have propagated over and over again, 3
"borat" instead of " rate."
4 MR. WARD:
The policy statement is pretty 5
general and thinks how it's going to be implemented and 6
there's a lot of room for maneuvering in this.
If we do 7
have some points of view,-I guess it is not hopeless that 8
they will be -- could be influential.
9 MR. MICHELSON:
You know, the policy statement 10 is probably an innocent document.
It doesn't really say 11 much in terms of concrete things.
It says we are going to --
12 it's a little fuzzy in places, but I think it's saying we
()
13 are going to start looking at conceptual designs and here's 14 the planner in which we are going to look at it and later 15 on we might even think about certifying the designs, but it 16 doesn't say how we are going to do that because that's 17 another policy statement.
It doesn't say much, really.
It 18 doesn't -- I didn't find any harm in it.
Maybe there's 19 some good in it, depending on your view.
I didn't find 20 much.
21 I think the agency could proceed without the 22 policy statement.
23 MR. WYLIE:
Are you talking about without the 24 NUREG?
25 MR. MICHELSON:
Well, the NUREG just sort of t*
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looked at all the comments and so forth.
That's all NUREG 2
did.
3 MR. WYLIE:
I wasn't sure which one you were 4
talking about.
5 MR. MICHELSON:
I was talking about the actual I
6 policy statement.
7 MR. SIESS:
I don't find the NUREG adding an 8
awful lot to it.
9 MR. MICHELSON:
It didn't add anything.
10 MR. SIESS:
I think it tightened up a little bit 11 on the definition of advanced reactor,~but it sort of ends 12 up saying an advanced reactor is one that will be reviewed
()
13 by the advanced reactor group, which, internally, I guess, 14 is an important policy.
15 The guidelines on whether or not there be a 16 prototype test aren't all that much clearer.
Bring us one 17 and we'll tell you.
18 I don't find it much of an advance beyond the 19 policy statement.
I guess it can't be because a policy 20 statement is a policy statement and I think it does a 1
21 little bit to help understand the policy statement.
I i
22 think its greatest use is going to be guidelines to the 23 Staff.
\\
24 This is where the Staff comes out and says this 25 is how we are going to do some things, and they can always i
l C)
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point back to it to the Commission.
2 MR. MICHELSON:
But it's not very concrete.
3 MR. SIESS:
No.
It was a policy statement --
4 MR. MICHELSON:
It's not clear you even need to 5
do it, except just to tidy up a little more formally.
6 MR. SIESS:
The statement seems ta) say an 7
advanced reactor was one.that was different, but it was 8
also one that was better.
9 MR. MICHELSON:
Innovative.
10 MR. SIESS:
Anything that had these features, 11 some or all of these features, was going to be an advanced 12 reactor.
(']
13 MR. EBERSOLE:
But it also said it didn't have 14 to be any safer and my yardstick is to compare it to San 15 Onofre or Davis-Besse or TMI 2.
16 MR. SIESS:
It's hard to say that they've got to 17 be safer without saying what you are going to be doing 18 about existing ones.
19 MR. EBERSOLE:
It's the age-old problem of for 20 God's sake let's don't say what we've done already isn't 21 safe.
22 MR. SIESS:
What we've done already is safe.
23 Let's face it.
It's safer than airplanes.
24 MR. WYLIE:
The record shows it.
25 MR. EBERSOLE:
That's kind of a legal jeopardy ACE FEDERAL REPORTERS, INC.
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in saying we've got to nake things safer.
2 MR. SIESS:
I guess if we are going to write a 3
letter we-need to have the Staff in, but I'm trying to 4
figure out what we might say in a letter.
5 MR. WYLIE:
Might I comment on the definition 6
and budget or something?
7 MR. SIESS:
Do you think there's anything in 8
here that involves your interpretation er how you are going 9
to do it that you think needs comments?
10 Let me say something a little differently.
He 11 advise the Commission, theoretically, and I'm not sure what 12 advice we could give the Commission about the NUREG.
Is 13 there any advice we could give you about the NUREG?
14 MR. KING:
I guess what I was looking for is 15 does it look complete enough in terms of general guidance?
16 Is there something in terms of a technical aspect we should 17 address in a NUREG like this?
18 MR. MICHELSON:
The trouble is, if you want to 19 be more specific than you have been -- yes, I-think you 20 ought to be more specific in far more areas.
21 MR. K4NG:
This is not intended to be a standard 22 review plan.
It's just basically how we are going to do 23 i business.
i 24 i
MR. SI]SS:
I'm sure you have missed something.
I 25
!You know --
()
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'u) 1 MR. KING:
If you had any thoughts on what that 2
is or what should be in here, that's what I would like to 3
have, or if there's something in here you don't agree with, 4
I would like to have that.
5 MR. MARK:
He's just going by probabilities.
6 MR. MICHELSON:
It's a very open-ended document.
7 It won't tie you down much.
It doesn't tell me ahead of.
8 time very well what you are going to do either, for that 9
matter.
It isn't even real clear that -- what your steps 10 are. There's some vague allusion to some of it, you are 11 going to tidy up, you know.
12 You really are going to go through a two-step
()
13 review process, but if you are maybe you can make that 14 clearer.
I think it's perhaps in there.
Maybe not.
15 MR. SIESS:
I was trying to visualize an 16 instance where somebody might say:
Look, you can't do that 17 because you didn't say you were going to do that in the 18 NUREG.
You said this in the NUREG and now you are doing it 19 differently.
i 20 Your answer would be:
So what?
That's not 21 binding.
It's not a standard review plan.
22 MR. KING:
I agree.
It doesn't bind us and we 23 can change our minds later on, but at least it gives people 24 an idea.
25 MR. SIESS:
It looks to me that what you've done C:)
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here is at this point in time you have reviewed how the 3
2 policy came to be.
3 MR. KING:
Yes.
I 4
MR. SIESS:
And looking ahead, how you expect to 5
use it.
6 MR. KING:
Yes.
7 MR. SIESS:
Which is not a bad idea.
8 MR. MICHELSON:
But it's not something worthy of 9
our comment, is it?
10 MR. MARK:
Well, sure it is.
It needn't be much, 11 but I think we want to assure the Commission that we've 12 seen it and we don't have anything nasty to say about it.
(}
13 That's all.
14 MR. MICHELSON:
If that's what you want -- there 15 will be a little more caveat in it.
16 MR. WYLIE:
I think we ought to present it to 17 the full committee because we don't have a monopoly on 18 thoughts here.
19 MR. MICHELSON:
You have almost half the 20 committee here right now.
21 MR. WARD:
They will hear less about it.
22 Okay, we'll plan on that.
Tom, you said you'd 23 have a new draft available.
When might that be available?
24 MR. KING:
Sometime next week.
25 MR. WARD:
Maybe Med can try to get that to us.
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DR. EL-Z EFAWY: We have an hour in the full 2
committee on Thursday.
3 MR. WARD:
Is that enough?
An hour?
4 MR. MARK:
You, I suppose personally and perhaps 5
a couple of colleagues, have put this NUREG together?
6 MR. KING:
Correct.
7 MR. MARK:
Could you tell us what you think has 8
been accomplished by doing it?
9 MR. KING:
I think it has documented how we are 10 going to approach the review.
11 MR. MARK:
I'm supposing you had to bat your 4
12 heads together and think here we have this policy statement, fx
(}
13 how are we going to respond?
Well, you forgot this, you t
l 14 forgot that, when you put it altogether and that you 15 thought it through to a greater extent than you would.have 16 done without it.
17 MR. KING:
It forced us to sit down and think 18 about how we tie in with other things going on in the 19 Commission and how we are going to approach the review.
20 MR. MARK:
If that's all it does, it's still 21 worth doing.
22 MR. KING:
And get it down on paper for 23 everybody to see.
24 MR. MARK:
And talked it through so that you 25 knew what you were willing to put on paper.
(~)
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1 MR. MICHELSON:
Whether it was worthy of our 2
comment is the question.
I think there's nothing wrong 3
with saying we have seen it and we don't have any real 4
problem with it.
That's fine.
4 5
MR. MARK:
They are dependent on a chain through 6
CRGR to the Commission, and they are going to be asked at 7
each step, hey, did the ACRS have anything to say?
Did you 8
give them a chance?
We should tell them yes.
9 MR. WYLIE:
I think the point Carl made,'this is 10 a two-step review process might be made more clear.
11 MR. KING:
Okay.
1 12 MR. EBERSOLE:
The second step, I like to think
()
13 that you'll have a great deal of fine structure and detail 14 in it which you really get down to it.
I am sure you do.
15 And the second basic thing is you'll get that 16 carly on so it can be manipulated and fixed and twisted 17 into the right shape without heavy cost as has been our 18 past experience.
I sort of consider our present plants as 19 carrying a burden of 3:1 on cost because we had to go back 20 and fix them after the owners, builders, operators, made 21 their interpretation and cast them in place.
22 MR. KING:
It's the decision to work with the 23 designers.
24 MR. EBERSOLE:
That gets down to breakers and 25 pumps and valves and all sorts of things.
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s-l 1
MR. MICHELSON:
We won't really, then, break 2
ground until after the FSAR was written and approved.
In 3
the old days it was done after the PSAR --
4 MR. EBERSOLE:
That's not in any stretch of the 5
-imagination an appropriate detail.
i 6
MR. MICHELSON:
The design comes further.
7 That's what I fully didn't appreciate from some of the 1
8 reading.
We certainly can't certify the conceptual designs.
9 MR. EBERSOLE:
You can't tell what a plant is 10 from that.
11 MR. MICHELSON:
Tell better f rom the PSAR --
12 MR. WARD:
Let's see.
I guess the next sort of
}
13 serious work that you'll be throwing at the subcommittee is 14 the review of the SERs, which will becoming out in
'88, you 15 said?
1 16 MR. KING:
We would hope for tho' HTGR to have a 17 draft SER for you to look at in October of this year and 18 for the LMRs, January-February of next year, but we would 19 hope to have at least one get together before then to talk 20 about where we stand in some of these major issues and what 21 is happening in that area.
22 MR. WARD:
You talked about doing that later in 23 the year and you had asked earlier if we ought to have kind 24 of a rebriefing'on the three concepts between now and then i
25 and I said no, I didn't think we did.
w I
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But sitting here this morning, I guess I 2
wondered about that a little bit, that maybe we do need 3
kind of a reminder of what these three designs are at sometime.
4 Does the subcommittee have any-opinion on that?
5 MR. MICHELSON:
I'd like to hear it,-because I 6
wasn't here the last time we got the reminder, and I wasn't 7
a member before that.
8 MR. KING:
Maybe we ought to do that fairly 9
quickly, next month or two, if we could.
10 MR. EBERSOLE:
I think repetition wouldn't hurt.
11 MR. WARD:
I think it may be a good idea, so 12 let's schedule that before too long.
Charlie, maybe if we
()
13 are going to do that --
14 MR. WYLIE:
I'll just defer that.
15 DR. EL-ZEFTAWY:
The end of May.
16 MR. WARD:
All right.
Any other questions?
17 Comments?
Threats?
Anything?
18 MR. MARK:
Gems?
19 MR. MICHELSON:
Jibes?
20 MR. WARD:
All right.
Thank you very much.
21 Adjourn.
22 (Whereupon, at 12:00 noon, the meeting was 23 adjourned.)
24 i
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CERTIFICATE OF OFFICIAL REPORTER 0
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON ADVANCED REACTOR DESIGNS DOCKET NO.:
PLACE:
WASHINGTON, D.
C.
DATE:
FRIDAY, APRIL 24, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
2 (siot)
(TYPE JOE REITNER Official Reporter ACE-FEDEp L REPORTERS, INC.
Reporter s Aff111a lon 0
h,
l4l RES STAFF PRESENTATION TO THE g
O ACRS
'gPigggIgT 0gFgE]C f
SUBJECT:
N r
DATE:
APRIL 24,1987 PRESENTER:
T. L. KING O
PRESENTER'S TITLE / BRANCH /DIV:
ACTING CHIEF, gCggjCTORS #D GENERIC DIVISION OF REGULATORY APPLICATIONS PRESENTER'S NRC TEL. NO.:
492-7014 SUBCOMMITTEE:
ADVANCED REACTORS O
O BACKGROUND AT THE TIME THE FINAL ADVANCED REACTOR POLICY STATEMENT WAS ISSUED (7/8/86) THE COMMISSION ASKED THE STAFF TO PREPARE A NUREG DOCUMENTING THE DEVELOPMENT OF THE POLICY STATEMENT (REVISIONS FROM PROPOSED TO FINAL POLICY).
STAFF, IN DISCUSSIONS WITH OPE AND OCM, SUGGESTED THAT THE NUREG BE EXPANDED TO COVER FACTORS IMPORTANT TO IMPLEMENTATION OF THE POLICY STATEMENT.
~
O d
O O
__-_m. _.,
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PREVIOUS ACRS REVIEW DEVELOPMENT OF ADVANCED REACTOR POLICY STATEMENT WAS DICUSSED WITH ACRS ON:
9/25/85 SUBCOMMITTEE MEETING 10/10/85 FULL COMMITTEE MEETING AT THAT TIME THE PUBLIC COMMENTS RECEIVED AND THE MAJOR CHANGES FROM THE PROPOSED TO THE FINAL POLICY WERE '
r DISCUSSED.
O ACRS LETTER WAS ISSUED ON 10/16/85 SUPPORTING THE POLICY STATEMENT.
l 1
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,------------,,..,,,---.-,m-
,,,.,,,--,-------n-r -,,- - - - -
O PURPOSE OF NUREG-1226 DOCUMENT DEVELOPMENT OF THE COMMISSION'S POLICY STATEMENT ON ADVANCED NUCLEAR POWER PLANTS, INCLUDING THE REVISIONS MADE IN GOING FROM THE PROPOSED TO THE FINAL POLICY.
PROVIDE GUIDANCE REGARDING IMPLEMENTATION OF THE POLICY STATEMENT ADDRESSING:
WHAT REACTORS ARg CONSIDERED TO FALL WITHIN THE, CHARTER OF THE POLICY STATEMENT, STAFF REVIEW APPROACH APPLICABILITY OF RELATED COMMISSION POLICIES AND PRACTICES
-l INFORMATION NEEDS j
GENERAL GUIDANCE APPLICABLE TO ANY REVIEW
[
O USE OF NUREG-1226 POLICY STATEMENT AND NUREG-1226 ARE DIRECTED TOWARD REVIEWS CONDUCTED AT THE PRE-APPLICATION STAGE.
E I
STAFF REVIEW OF AN ADVANCED REACTOR WILL BE DOCUMENTED VIA AN SER, INCLUDING NRR CONCURRENCE COMMISSION REVIEW RESULTS OF STAFF REVIEW ARE INTENDED TO FORM THE BASIS FOR AN ACTUAL LICENSING REVIEW, IF AN WHEN AN i
APPLICATION IS FILED.
l l
i O
=
O STATUS AND PLANS FOR NUREG-1226 NUREG-1226 HAS RECEIVED INTERNAL STAFF REVIEW (NRR, RES, OGC)
ACRS REVIEW - LETTER IS DESIRED.
AFTER ACRS REVIEW IT WILL BE SUBMITTED TO CRGR.
AFTER CRGR APPROVAL IT IS TO BE SENT TO THE COMMISGIbNERS (AT THEIR REQUEST) FOR REVIEW PRIOR TO ISSUANCE.
COMMISSION MAY ISSUE IT FOR PUBLIC COMMENT.
1 O
C\\
%si MAJOR COMMENTS RECEIVED ON DRAFT DISCUSS FEES.
WORDS TO BE ADDED TO SECTION 5.2 STATING THAT FEES WILL NOT BE CHARGED FOR REVIEWS DONE UNDER THE CHARTER OF THE POLICY STATEMENT.
DISCUSS EXTENT TO WHICH EXISTING LICENSING CRITERIA ARE TO BE USED.
WORDS TO BE ADDED TO SECTION 5.2 STATING THAT ADVANCED REACTORS ARE TO BUILD UPON EXISTING LWR
{)
CRITERIA, WHERE PRACTICAL.
j EXPAND DISCUSSION OF DEFENSE IN-DEPTH TO INCLUDE MULTIPLE BARRIERS, PREVENTION VS. MITIGATION AND SINGLE FAILURE CRITERION.
WORDS TO BE ADDED TO SECTION 5.3.1.
1 DEFINE DESIGN APPROVAL AND DESIGN CERTIFICATION WORDS TO BE ADDED TO SECTION 5.3.4.
C:)
1 I
i
O C OhlTEMT-NUREG-1226
" DEVELOPMENT AND UTILIZATION OF THE NRC POLICY STATEMENT ON THE REGULATION OF ADVANCED NUCLEAR POWER PLANTS" I)
DEVELOPMENT OF POLICY STATEMENT II)
GUIDELINES FOR UTILIZATION l
DEFINITION OF ADVANCED REACTORS j
REVIEW APPR0[CH RELATED POLICIES, PRACTICES 8 REGULATIONS DEFENSE IN DEPTH SAFETY GOAL POLICY SEVERE ACCIDENT POLICY STANDARDIZATION POLICY USE OF EXISTING REGULATIONS & GUIDELINES USE OF INDUSTRY CODES & STANDARDS SUPPORTING TECHNOLOGY
~.
USE OF NON-PRESCRIPTIVE DESIGN CRITERIA 1
l
\\
O DEFINITION OF ADVANCED REACTORS REACTORS THAT ARE SIGNIFICANTLY DIFFERENT THAN CURRENT GENERATION LWRS, a
DESIRED ATTRIBUTES LISTED IN POLICY STATEMENT.
1 LICENSING REQUIREMENTS SIGNIFICANTLY DIFFERENT THAN-THOSE CONTAINED IN THE STANDARD REVIEW PLAN.
O FINAL DETERMINATION WILL BE ON A CASE-BY-CASE BASIS.
1 e
- o 1
,~_ _____-
.n
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REVIEW APPROACH BUILD UPON LWR CRITERIA, WHERE PRACTICAL.
DEVELOP ADDITIONAL CRITERIA AND GUIDANCE TO ADDRESS THE UNIQUE CHARACTERISTICS OF THE DESIGN.
EXPECT ADVANCED DESIGNS TO HAVE ENHANCED MARGINS OF i
SAFETY OVER CURRENT GENERATION LWRS BY:
\\
7 INCORPORATING THOSE CHARACTERISTICS LISTED IN THE POLICY STATEMENT UTILIZING MARGIN AND DEFENSE IN-DEPTH TO ACCOUNT FOR UNCERTAINTIES HAVING THE ABILITY TO PREVENT CORE DAMAGE FOR MANY LOW PROBASILITY EVENTS, SUCH AS:
ATWS STATION BLACKOUT O
1 Ikk REVIEW APPROACH (CONT'D) 4 EXPECT. ADVANCED DESIGNS TO COMPLY WITH COMMISSION'S POLICIES ON SEVERE ACCIDENTS, SAFETY GOALS AND STANDARDIZATION.
CONSIDER GIVING CREDIT FOR ENHANCED SAFETY CHARACTERISTICS INCORPORATED INTO THE DESIGN VIA CHANGES IN CRITERIA OR REDUCED ADMINISTRATIVE REQUIREMENTS, t
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RELATED POLICIES, PRACTICES AND REGUIATION MAINTAIN DEFENSE-IN-DEPTH:
SINGLE FAILURE CRITERION MULTIPLE BARRIERS / SYSTEMS ACCOUNT FOR UNCERTAINTIES PREVENTION VS, MITIGATION COMPLIANCE WITH SAFETY GOAL POLICY COMPLIANCE WITH SEVERE ACCIDENT POLICY PRA AT CONCEPTUAL DESIGN STAGE
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SOURCE TERM CHANGES
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STANDARDIZATION POLICY CONSIDER STANDARDIZATION AT CONCEPTUAL DESIGN STAGE.
PRESENT COMPLETE DESIGN FOR REVIEW AT CONCEPTUAL STAGE.
EXISTING REGULATIONS AND GUIDELINES REVEW FOR APPLICABILITY ENCOURAGE USE OF INDUSTRY CODES AND STANDARDS, WHERE PRACTICAL.
SUPPORTING TECHNOLOGY UTILIZE EXISTING OPERATING EXPERIENCE i
DESCRIBE R&D PROGRAMS f
r FOREIGN INFORMATION AND DATA PROTOTYPE TEST:
CASE-BY-CASE JUDGEMENT BASED ON:
, DEPARTURE FROM PROVEN TECHNOLOGY UNCERTAINTIES IN PERFORMANCE DEGREE OF DEFENSE IN-DEPTH OTHER R&D PLANNED I
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USE OF LESS-PRESCRIPTIVE CRITERIA
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POLICY STATEMENT ENCOURAGES DESIGNERS TO PROPOSE CRITERIA APPLICABLE TO THEIR DESIGNS AND INDICATES THAT NRC WILL CONSIDER LESS-PRESCRIPTIVE CRITERIA.
GUIDANCE IS PROVIDED ON WHAT SUPPORTING INFORMATION IS NEEDED TO EVALUATE THE ACCEPTABILITY OF USING LESS-PRESCRIPTIVE CRITERIA.
CHANGE IN SCOPE OF REGULATIONS?
i ENHANCEMENT OF SAFETY?
PRESERVATION OF DEFENSE IN-DEPTH?
IMPACT ON STANDARDIZATION?
SCOPE OF SUPPORTING ANALYSIS?
STANDARD METHODOLOGY?
IMPACT ON NRC OVERSIGHT OF CCNSTRUCTION, ENFORCEMENT?
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IMPACT ON BACKFIT?
Y
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