ML20339A569
| ML20339A569 | |
| Person / Time | |
|---|---|
| Issue date: | 11/02/2020 |
| From: | Derek Widmayer Advisory Committee on Reactor Safeguards |
| To: | |
| Widmayer, D, ACRS | |
| References | |
| NRC-1207 | |
| Download: ML20339A569 (173) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Future Plant Designs Subcommittee Docket Number:
(n/a)
Location:
teleconference Date:
Monday, November 2, 2020 Work Order No.:
NRC-1207 Pages 1-130 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 FUTURE PLANT DESIGNS SUBCOMMITTEE 7
+ + + + +
8 MONDAY 9
NOVEMBER 2, 2020 10
+ + + + +
11 The Subcommittee met via Teleconference, 12 at 2:00 p.m. EST, Dennis Bley, Chairman, presiding.
13 14 COMMITTEE MEMBERS:
15 DENNIS BLEY, Chairman 16 CHARLES H. BROWN, JR., Member 17 VESNA B. DIMITRIJEVIC, Member 18 WALTER L. KIRCHNER, Member 19 JOSE MARCH-LEUBA, Chairman 20 DAVID A. PETTI, Member 21 JOY L. REMPE, Member 22 23 ACRS CONSULTANT:
24 MICHAEL L. CORRADINI 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 DESIGNATED FEDERAL OFFICIAL:
1 DEREK WIDMAYER 2
3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 C-O-N-T-E-N-T-S 1
Opening Remarks - Dennis Bley, ACRS.......
4 2
Update of Staff Endorsement of the ASME/ANS Non-LWR 3
PRA Standard - Michelle Gonzalez, RES... 10 4
Staff's Review and Comments During First and 5
Recirculation Ballots -
.......... 28 7
Resolution and Disposition of Ballot Comments and 8
Future Activities/Revision of Non-LWR PRA 9
Standard - Karl Fleming, JCNRM
...... 41 10 Scope of the Endorsement RG and Staff position issues 11 to be addressed in RG - Martin Stutzke, NRR. 84 12 Internal/External Stakeholders Engagement and plan for 13 Issuance of Endorsement RG -
14 Donna Williams, NRR...........
124 15 Meeting Adjourned...............
130 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 P-R-O-C-E-E-D-I-N-G-S 1
(2:02 p.m.)
2 CHAIRMAN BLEY: Good afternoon. This 3
meeting will now come to order. It's a meeting of the 4
Advisory Committee on Reactor Safeguards Subcommittee 5
on Future Plant Designs. I'm Dennis Bley, chairman of 6
the Future Plant Designs Subcommittee.
7 ACRS members in attendance are Joy Rempe, 8
Charlie Brown, Walt Kirchner, Dave Petti, Jose March-9 Leuba, Ron Ballinger, Vesna Dimitrijevic, Matt 10 Sunseri. Our consultant, Mike Corradini, is with us 11 and we'll see if Pete Riccardella joins us.
12 Derek Widmayer of the ACRS staff is the 13 designated federal official for the meeting. And Ken 14 Howard of the staff is the backup.
15 The purpose of today's meeting is to 16 review the staff's plans and status for endorsing the 17 non-light-water reactor PRA standard in the draft 18 Regulatory Guide.
19 The subcommittee will gather information, 20 analyze relevant issues and facts and formulate 21 proposed positions and actions as appropriate.
22 All but three members of the full 23 committee attended the first meeting of this topic 24 last year, and all but one are present right now.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 The matter -- I'm sorry, this matter will 1
be brought back to this subcommittee when the draft 2
Reg Guide is prepared. Therefore, I do not expect 3
that we will bring it before the full committee this 4
year, but I'll ask the members if they agree at the 5
end of today's meeting.
6 The ACRS was established by statute and is 7
governed by the Federal Advisory Committee Act, FACA.
8 The NRC implements FACA in accordance with regulations 9
found in Title 10 of the Code of Federal Regulations, 10 Part 7. The Committee can only speak for its 11 published letter reports.
12 We hold meetings to gather information, 13 perform the preparatory that will support our 14 deliberations at a full committee meeting.
15 The rules for participation in all ACRS 16 meetings, including today's, were announced in the 17 Federal Register on June 13th, 2019.
18 The ACRS section of the US NRC public 19 website provides our charter, bylaws, agendas, letter 20 reports and full transcripts of all full and 21 subcommittee meetings, including the slides presented.
22 The meeting notice and agenda for this meeting were 23 posted there.
24 As stated in the Federal Register Notice 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 and in the Public Meeting Notice posted to the 1
websites, members of the public who desire to provide 2
written or oral input to the subcommittee may do so 3
and should contact the designated federal official 4
five days prior to the meeting as practicable.
5 Today's meeting is open to public 6
attendance and we have received no written statements 7
or requests to make an oral statement.
8 We have also set aside ten minutes in the 9
agenda for spontaneous comments from members of the 10 public attending or listening to our meetings.
11 Due to the COVID pandemic, today's meeting 12 is being held over -- it's not Skype -- it's over 13 Teams for ACRS and NRC staff attendees. There is also 14 a telephone bridge line allowing for participation of 15 the public over the phone.
16 A transcript of today's meeting is being 17 kept.
Therefore, we request that additional 18 participants on the bridge line identify themselves 19 when they are asked to speak and to speak with 20 sufficient clarity and volume that they can be readily 21 heard.
22 At this time, I ask that attendees on 23 Skype and on Teams and on the bridge line keep their 24 devices on mute to minimize disruptions, and unmute 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 only when speaking.
1 Before proceeding with the meeting, I want 2
to offer two comments. First, is technical. A number 3
of issues were raised last year that both the staff 4
and Mr. Fleming of the writing group for the standard 5
assured us would be considered further.
6 As a heads-up to the presenters, and as a 7
reminder to the members, here is a short summary of 8
those issues. One had to do with quality assurance 9
and we're curious about what quality assurance/quality 10 control requirements the staff feels the PRA must 11 meet.
12 Will the staff be requiring the PRA to 13 support use of an LMP and a license application need 14 to be elevated to Tier 2? That was talked about a bit 15 last time. What other alternatives is the staff 16 considering? To what extent can the staff rely upon 17 the industry's peer review process for such 18 applications? What guidance, including ISG 28, is the 19 staff considering? Must there be changes to the 20 application acceptance review process?
21 Some work was in progress on assembling 22 operating experience from experimental reactors. If 23 anyone has information on whether that's been 24 finalized and if it's providing useful information, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 we're interested in that.
1 We were told the standard would ensure 2
there's clarity that all potential hazards are to be 3
considered under other hazards described in the 4
standard. And does the standard apply to all 5
applications under Parts 50 and 52?
6 The staff developers said yes -- the staff 7
and the developers said yes, but in Section 3.3.3, and 8
elsewhere in the standard, they only list conceptual 9
design, design certification and combined operating 10 license -- that last one, the right term now is 11 "combined license" -- which are all issued under Part 12
- 52. There is no mention of construction permits or 13 operating licenses issued under Part 50.
14 It was said that the developers of the 15 standard were seeking appropriate warning language or 16 a means to deal with the problem of truncation of low-17 frequency scenarios and cut sets especially with 18 respect to risk achievement.
19 Also, it appears that the staff no longer 20 plans to endorse the 2013 version of the standard, but 21 will address the revised version expected in 2021.
22 Please correct me if I'm wrong on that.
23 My second comment is a somber one. I want 24 to take just a moment to pay respect to one of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 leaders in the development and applications of PRA, 1
Dr. B. John Garrick, who passed away early yesterday.
2 John served and chaired our sister 3
committee, the ACNWM, for ten years. And that was 4
followed by two terms as chairman of the US Nuclear 5
Waste Technical Review Board.
6 I believe his first involvement in the 7
nuclear business was as a student at the old Oak Ridge 8
School of Reactor Technology in 1954 and '55 where he 9
made lifelong connections with many of the innovators 10 in the industry.
11 Karl Fleming, George Apostolakis, John 12 Stetkar and I all worked with John for many years at 13 Pickard, Lowe & Garrick. A 2014 gift from John and 14 Amelia Garrick established the B. John Garrick 15 Institute for Risk Science at his alma mater, UCLA.
16 May you rest in peace, John.
17 We will now proceed with the meeting and 18 I call upon Michelle Gonzalez from the Office of 19 Research to begin. Michelle, please go ahead.
20 MS. GONZALEZ: Thank you, Dr. Bley. Good 21 afternoon. I am Michelle Gonzalez. I am our risk and 22 reliability analyst from the Office of Research, 23 Division of Risk Analysis.
24 And joining me in this briefing will be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 Anders Gilbertson from the Office of Research. He is 1
the JCNRM voting member. Karl Fleming from the 2
Joint Committee on Nuclear Risk Management, or the 3
JCNRM. He is the chair of the JCNRM writing group for 4
the non-LWR PRA standard. Martin Stutzke, he is the 5
senior level advisor from NRR. And Donna Williams, 6
she is the NRR project manager on this work.
7 So, in this briefing, we want to provide 8
you a status update and discuss the plans to develop 9
the Reg Guide to endorse the advancement of non-LWR 10 PRA standard.
11 Slide 2, please. Donna, next slide, 12 please.
13 MS. WILLIAMS: I apologize. I'm trying to 14 advance it and it's not going for me. One second.
15 There we go. Do you see it now?
16 MS. GONZALEZ: Not yet.
17 MS. WILLIAMS: Let me try sharing again.
18 (Pause.)
19 MS. WILLIAMS: Okay?
20 MS. GONZALEZ: Yes.
21 MS. WILLIAMS: Very good.
22 MS. GONZALEZ: Thank you. So, in today's 23 briefing, I will start by providing an update on the 24 efforts related to the endorsement of the standard.
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11 Then, Anders will provide an overview of 1
the NRC ballot review and comments. Karl Fleming will 2
discuss the resolution and disposition of ballot 3
comments and provide an overview of future JCNRM 4
activities related to the standard.
5 Then, Marty will discuss and go over the 6
-- what we envision for the scope of the Reg Guide and 7
he will also go over the issues that we have already 8
identified as having a staff position. Those are the 9
issues that we will be addressing in the Reg Guide.
10 And finally, Donna Williams will discuss 11 a communication plan and the plan schedule for 12 endorsement.
13 Slide 3, please. Donna, next slide, 14 please. Thank you.
15 So, as a little bit of -- well, just skip 16 one slide. There you go. So, as a little bit of 17 background I'll just provide a quick overview.
18 The advanced non-LWR PRA standard was 19 issued by ASME and ANS in 2013 as a trial use 20 standard. Lessons learned from the pilot applications 21 were used to improve the standard and were 22 incorporated into the latest version of the standard 23 that was initially balloted in May of this year.
24 So, the scope of the standard includes 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 Level 1, Level 2 and Level 3 PRA. It includes all 1
hazards, including internal and external events, and 2
all operating modes.
3 This standard actually includes 4
requirements for low-power shutdown and then it also 5
covers different licensing phases from design, pre-6 operational and post-operational phases.
7 Next slide, please. Slide 4. So, like 8
Dr. Bley mentioned before, we briefed the subcommittee 9
last year on October 2nd. From that briefing, there 10 has been a lot of progress related to the review of 11 the standard.
12 So, at the moment, we presented to the 13 ACRS the action plan for endorsement being -- just in 14 that briefing, we were still planning on endorsing the 15 trial use standard.
16 So, during that briefing, we presented 17 from the JCNRM, expressed his concerns about the NRC 18 plans of endorsing the trial use standard. So, 19 basically, following that meeting, NRC received a 20 letter from the JCNRM again expressing their concerns 21 about the NRC endorsement plans and providing an 22 updated schedule for finalization on the standard.
23 So, we, at the
- NRC, had previous 24 discussions with management and the team and the NRC 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 decided to agree -- or agreed to wait for a final 1
version of the standard to proceed with endorsement.
2 We responded back to JCNRM agreeing to the 3
proposed schedule, which stated that the JCNRM would 4
have a stable version of the standard, what they call 5
pre-editing version, by December of 2020.
6 After that, we went back and updated our 7
endorsement action plan. We just -- pretty much just 8
updated the schedule and reorganized some of the tasks 9
of the plan.
10 So, the standard went out for initial 11 ballot in March 24th of this year. This was a 60-day 12
-- 60-calendar-day review period. So, the NRC 13 provided comments to the JCNRM in May and -- with an 14 approval vote on the ballot.
15 This ballot did not pass. So, a 16 recirculation ballot was completed in August. This 17 time around unanimous consensus was issued.
18 CHAIRMAN BLEY: This is Dennis.
19 MS. GONZALEZ: Yes.
20 CHAIRMAN BLEY: I'm assuming Karl's going 21 to give us some details on that process; is that 22 right?
23 MS. GONZALEZ: I think Anders Gilbertson 24 will provide some update on that, and then also Karl 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 will provide the JCNRM, yes.
1 CHAIRMAN BLEY: Okay. Thanks.
2 MS. GONZALEZ: So, other than that, we 3
received the NEI's peer review guidance for the 4
advanced non-LWR PRA standard in June.
5 So, the project team completed an initial 6
review of the document and discussed findings with the 7
NEI at a recent public meeting.
8 We are proposing -- or we are -- we're 9
going to be having a follow-on meeting on December 10 just to discuss those comments in more details.
11 Next slide, please, Donna. So, the 12 endorsement plan. As I mentioned before, other than 13 the schedule, our endorsement plan has not changed 14 much since we last discussed it in October of last 15 year.
16 So, in this slide, I just want to 17 summarize the activities or tasks that we are focusing 18 on.
19 First off, is the standard development 20 support. The NRC has a representative in the JCNRM 21 Standard Development Working Group.
22 The NRC representative is Hanh Phan. He 23 has been involved throughout the development process.
24 He provides the NRC perspective and he -- by active 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 participation in the working group efforts.
1 So, as mentioned
- before, the NRC 2
participated in both the initial ballots and the 3
recirculation ballots.
4 The NRC submitted approximately 500 5
comments on the initial ballot and about 70 comments 6
in the recirculation ballot.
7 Anders will go into more details in his 8
presentation on the type of comments that we submitted 9
to the JCNRM.
10 So, now that developing efforts are 11 complete, we're focusing on the preparation for review 12 and endorsement of the standard and the NEI's peer 13 review guidance.
14 So, even though that we have plan on 15 endorsing the standard with the Reg Guide, we are 16 starting other options for endorsement or looking into 17 maybe like a more time efficient option in order to 18 support near-term licensing activities.
19 So, we are trying to somehow accelerate 20 the process knowing that the Reg Guide development 21 process with the different levels of review and 22 approvals sometimes ends up being a lengthy process.
23 So, we are discussing the different options with 24 management and OGC.
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16 Some of the things that we're looking into 1
is if having a trial use Reg Guide or an ISG would be 2
a good option for endorsement going forward.
3 Next slide, please, Donna. Slide 6. So, 4
the -- when I talk about the preparation for review 5
and endorsement of the standard, this includes a 6
series of tasks.
7 First off was the scope of regulatory 8
activities for the advanced non-LWR standard. This 9
pretty much has been completed and I will provide more 10 details in the next slide, and also Marty will discuss 11
-- will have a broader discussion in his presentation.
12 Identifying the technical expertise to 13 review the standard, we have assembled a group of 15 14 reviewers with the needed technical expertise in the 15 different technical areas of the standard. These 16 reviewers have become familiar with the standard with 17 the experience gained through the ballot process. So 18 these reviewers have already started building or 19 identifying some of the issues that we'll be bringing 20 up when we go for the Reg Guide development process.
21 So, we are in the process of developing 22 detailed guidance for the reviewers to follow when 23 they're reviewing standard for endorsement. We expect 24 to have a step-by-step guide, or something like a flow 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 chart, that the reviewers can follow to make sure that 1
they don't miss anything through the review and up 2
through the review endorsement process.
3 We are working together with Sandia to 4
develop a database to compare the non-LWR PRA standard 5
to other PRA-related standards like the Level 1/LERF 6
or the staff position that we took in 1.200.
7 And going forward, we will be comparing 8
also to standards that have been issued for trial use, 9
but have not been endorsed yet. So, this should be --
10 or will be a good tool to ensure consistency among the 11 different PRA standards.
12 Develop a staff position for an acceptable 13 PRA and identify policy issues. Based on the ballot 14 reviews the NRC staff has identified some issues that 15 we will be taking a staff position on. We intend to 16 have early communication of these issues for public 17 interaction, public meetings, and maybe issue an 18 interim endorsement letter of a White Paper to provide 19 our views on the standard.
20 CHAIRMAN BLEY: Michelle?
21 MS. GONZALEZ: Yes.
22 CHAIRMAN BLEY: Approving endorsing the 23 standard, which to me is not independent from the work 24 going on in developing the new rule, Part 53, which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 will include -- or when it is published, we've been 1
assured there will be published additional guidance 2
documents to support applying the rule, but these two 3
are tied pretty closely together, at least in my mind.
4 Can you tell me how they're being 5
coordinated?
6 MS. GONZALEZ: So, we have -- we have been 7
keeping some track of on the efforts related to Part 8
- 53.
9 Maybe that's one of the things that we've 10 taken into account when thinking of developing a trial 11 use Reg Guide.
12 If we do develop a trial use Reg Guide now 13 once Part 53 is issued and I think -- I'm sorry, 14 Marty, to throw you here again, but I think it's --
15 what was it? 2022? 2021?
16 So, we can go back and revisit our Reg 17 Guide and, you know, publish it as a final use -- or 18 a final Reg Guide.
19 CHAIRMAN BLEY: Okay. I think a number of 20 the issues that the Committee -- members of the 21 Subcommittee focused on a year ago are probably more 22 appropriate for inclusion in guidance supporting Part 23 53.
24 Maybe Marty can talk about that some when 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 it's his turn.
1 MR. STUTZKE: Yes, Dennis, I'll be happy 2
to. Also, I'm on the Part 53 rulemaking team.
3 CHAIRMAN BLEY: Good.
4 MR. STUTZKE: Occasionally I get to sleep.
5 MS. GONZALEZ: Okay. So, Donna, slide 7, 6
please.
7 So, the scope of regulatory activities.
8 The endorsement of the standard will address 9
acceptabilities of base PRAs for licensing stages on 10 the Part 52, COL fuel load and operations -- and Part 11 50, construction permit and operating license, 12 including license applications that implement the LMP 13 guidance.
14 Even though we're not taking into account 15 Part 53 at this moment, we will have a discussion 16 included in the background section of the Reg Guide.
17 So, endorsement will include all technical elements of 18 the standards and NEI's peer review guidance. It will 19 look at the standard as a whole even though that the 20 standard cover elements that have not been previously 21 endorsed yet.
22 This is actually a point where the 23 comparison database will be useful when others are 24 looking to endorse the other standards like the low-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 power shutdown or the Level 3 PRA standard.
1 This will be a good way of keeping track 2
of what has been done under the non-LWR standard.
3 MEMBER DIMITRIJEVIC: I have a question on 4
this. I am very interested in this.
5 MS. GONZALEZ: Yes.
6 MEMBER DIMITRIJEVIC: What does this 7
paragraph say? It says that staff will address 8
acceptability of base PRA for all licensing stages.
9 Does that mean that staff will define what 10 is considered "acceptable" in the design certification 11 phase, for example?
12 MS. GONZALEZ: Yes.
13 MEMBER DIMITRIJEVIC: Then just give me 14 example. Will it say that they have to meet Category 15 1, for example?
16 What does it mean we'll address 17 acceptability?
18 MS. GONZALEZ: The acceptability of the 19 base PRA.
20 MEMBER DIMITRIJEVIC: Okay. Does this 21 mean the base PRA will have to be reviewed and it will 22 have to meet some capability category before, for 23 example, this is issued?
24 MS. GONZALEZ: I'm sorry, I don't follow 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 the question.
1 Marty, can you --
2 MR. STUTZKE: Yes. All that it means is 3
that we will address the need for peer review at each 4
one of these stages; design certification, COL, fuel 5
load and operations.
6 And we will also address the required 7
capability category at each stage.
8 MEMBER DIMITRIJEVIC: Okay. So, that 9
means when you -- the Reg Guide will have this 10
- defined, the design certification, this is 11 requirement, for example.
12 I'm just concentrating on design 13 certification because that's what we are reviewing 14 right now.
15 So, the thing is will that define 16 acceptability of the PRA in the design stage?
17 MR. STUTZKE: That's correct. We --
18 MEMBER DIMITRIJEVIC: Because that's not 19 defined anywhere now, right?
20 MR. STUTZKE: No, and that's one of the 21 issues we're trying to help resolve and provide 22 further clarity.
23 MEMBER DIMITRIJEVIC: So, you are planning 24 to provide clarity in this?
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22 MR. STUTZKE: Yeah. Yes. We will provide 1
an exhaustive table by supporting requirement 2
indicating exactly what capability category at what 3
licensing stage.
4 MEMBER DIMITRIJEVIC: Okay. So, that 5
would imply the peer review would be required in the 6
early licensing stage.
7 MR. STUTZKE: That's correct.
8 MEMBER DIMITRIJEVIC: Which is not the 9
case now.
10 MR. STUTZKE: That's true.
11 MEMBER DIMITRIJEVIC: Okay. So, how does 12 the -- alright. Okay. That's -- those were just my 13 questions. I want to be clear about this.
14 MR. STUTZKE: Yes. Surely.
15 MEMBER DIMITRIJEVIC: Okay.
16 CHAIRMAN BLEY: And thanks, Marty.
17 Looking at the side panel here I see that Karl Fleming 18 has raised his hand.
19 We don't usually use that, Karl. I think 20 you can open up and speak in if you have something you 21 want to say.
22 MR. FLEMING: Well, I just wanted to say 23 that for some reason I don't see the slides on my 24 Teams screen.
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23 It's not a problem because I have copies 1
of the slides, but I don't actually see them. I don't 2
know if that's just me or whether it's a common-cause 3
failure of some sort.
4 CHAIRMAN BLEY: Is anybody else having 5
trouble with it? You might want to restart. But if 6
you're following okay, you're probably best just to 7
stick on.
8 MR. FLEMING: Yeah.
9 MS. GONZALEZ: Thank you, Marty.
10 So, we will provide clarifications and 11 qualifications to address NRC recirculation ballot 12 comments.
13 During the ballot comment period, we 14 provided some comments that we marked as deferrable or 15 we said that these were -- the way that we categorize 16 them was as an observation.
17 These usually were comments that generally 18 involved regulatory implementation issues. So, we 19 will be taking a staff position on those issues that 20 we have already identified.
21 Next slide, please. Slide 8. So, this 22 slide just reiterates what I have communicated on the 23 previous slides.
24 The efforts on the comparison of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 standard will continue. We are starting to work on 1
drafting the Reg Guide.
2 We have outlined section of the standards 3
and identify those sections or areas that will be 4
different from Reg Guide 1.200, but keeping in mind 5
that we might end up going a different route for 6
endorsement, like I mentioned before, you know, if we 7
go for a trial use Reg Guide or if we issue interim 8
staff guidance.
9 We continue engaging internally with 10 management. We've had a few discussions with OGC 11 related to the options for endorsement. We plan to 12 come -- are coming back to the ACRS once we have 13 developed a draft guidance.
14 We will continue communicating with the 15 public through public meetings. We had a public 16 meeting actually last week and we will continue having 17 meetings every two to three months.
18 Slide 9, please. So, this slide I just 19 wanted to point out some of the main difference that 20 we have already identified or those areas that our Reg 21 Guide will be different from Reg Guide 1.200.
22 The structure that will follow this Reg 23 Guide we'll be producing to 1.200, but we will have 24 additional discussion on the background sections 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 related to the different operating phases under Part 1
50, Part 52, and then we'll have some discussion on 2
Part 53, too, Part C, which is the staff reg guidance.
3 We will include information on an 4
acceptable PRA for Part 50 applications, including 5
construction permit, operating license, providing 6
updates and Part 52 for design certification, combined 7
license, fuel load, et cetera.
8 Part C, which is also where we include the 9
information for technical elements, will have -- will 10 be updated to include the 19 technical elements that 11 are present in the standard.
12 So, Appendix A, which is where the NRC 13 points out or the staff position on the standard, 14 we're envisioning on having two different tables.
15 One that will have the staff position on 16 the standard. This is the normal -- the table that we 17 usually use where we point out if there are no 18 objections, if there are no objections with 19 clarifications or qualifications. And then we will 20 have a second table which would be similar to what was 21 done in ISG-028 where we would point out those 22 challenges on meeting requirements for DC or COL 23 applications.
24 So, with that, if there are no further 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 questions --
1 CHAIRMAN BLEY: I have one more.
2 MS. GONZALEZ: Okay. Sure.
3 CHAIRMAN BLEY: Two things. Since you 4
mentioned the operating license and construction 5
permits, I will remind the writers of this standard 6
that the new version we were looking at for this 7
meeting still does not mention construction permits 8
and operating licenses.
9 And the other thing is, are you 10 anticipating just one more meeting with ACRS after you 11 have a draft guide or is there something along the way 12 that you're anticipating?
13 MS.
GONZALEZ:
I think we were 14 anticipating to have the next meeting when we have the 15 draft guide, but I guess that's up to discussion with 16 the team and we do with the ACRS.
17 If there's any for an additional meeting 18 before that, we would be able to support or do that.
19 CHAIRMAN BLEY: Because I think the only 20 reason you might want another one is you might not 21 want surprises after you're all done.
22 That would be -- but that's up to you to 23 decide.
24 MS. GONZALEZ: Okay. So, it would be --
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27 yeah, that would be a good way of having some early 1
communication. I will take that into account. Thank 2
you.
3 MR. PHAN: Hello, Dr. Dennis. This is 4
Hanh Phan, NRC, NRR, Advanced Reactor Division, 5
Technical Branch.
6 In our plans, we have ACRS briefings twice 7
a year just because last year the delay of the 8
issuance of the standard. That's why we had only one 9
since October of last year until now.
10 But in the future, our plan is to briefing 11 the ACRS twice a year. So, we like to have no 12 surprises when we issue a key -- a mass document.
13 CHAIRMAN BLEY: Very good.
14 MS. GONZALEZ: Okay. So, with that, I'll 15 pass it on to Anders for his discussion.
16 MR. GILBERTSON: Okay. Thank you, 17 Michelle.
18 Can everybody hear me?
19 CHAIRMAN BLEY: Yes.
20 MR. GILBERTSON: Great. Okay.
21 Good afternoon, everyone. My name is 22 Anders Gilbertson. I am a reliability and risk 23 analyst in the Office of Nuclear Regulatory Research, 24 Division of Risk Analysis.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 And the next several slides I am just 1
going to go into a little more detail to discuss the 2
NRC's efforts to prepare for, and our participation 3
in, the JCNRM consensus balloting process for the 4
advanced non-LWR PRA standard.
5 I'll be coming at this from a little more 6
of the NRC perspective. I think Karl Fleming is going 7
to sort of provide the complement to that in talking 8
more about the JCNRM responses to our comments as well 9
as other comments received from the voting members.
10 So, slide 11, please. Okay. So, as 11 Michelle had mentioned, there had been a number of 12 activities that occurred since the last briefing to 13 the subcommittee in October 2019.
14 I think we had probably reported to the 15 subcommittee that we did hold an internal kickoff 16 meeting just a few weeks before our briefing to the 17 subcommittee.
18 And that was our formal kickoff to 19 initiate the staff's review efforts and efforts to 20 really start getting the staff familiarized with the 21 then-current draft version of the advanced non-LWR PRA 22 standard, including this understanding the structure, 23 the organization, differences and similarities between 24 that standard and the related LWR PRA standards.
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29 And as well as understanding -- a part of 1
understanding the organization and structure is 2
getting used to the slightly different approach that's 3
taken in the advanced non-LWR PRA standard where it is 4
-- it starts from initiating events and it's a full-5 scope analysis that goes all the way to consequence.
6 So, in terms of comparing that against the 7
LWR PRA standard paradigm it's a little bit of a 8
different mode of thinking.
9 So, in the intervening time period leading 10 up to early January, the staff worked to familiarize 11 and review that standard.
12 And then we had a 1-1/2-day webinar that 13 was conducted by Karl Fleming, and that was intended 14 to further help familiarize the staff with the 15 standard to reveal and discuss some of the thinking 16 behind the author's intent, how they wrote certain 17 parts of it, how they organized it, how different 18 pieces of that standard used themselves to perform and 19 complement the whole analysis.
20 And like I said before, you know, this 21 webinar was -- it was covering the scope, the 22 structure of the organization, the interrelationships 23 between the different portions of the standard, and it 24 talked about insights from the pilots that were 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 performed of the trial use -- the trial use standard, 1
advanced non-LWR PRA standard.
2 And then also it served to help 3
familiarize staff with the licensing modernization 4
project for when we're considering what our staff 5
position is going to look like.
6 So,
- granted, that is more of an 7
application of the standard, the LMP, it's still very 8
relevant because there was a lot of -- there are a lot 9
of connection points there between that application 10 and the development of the non-LWR PRA standard.
11 After that, there was -- the JCNRM 12 conducts what's called a readiness review, which I 13 actually participated directly in that review.
14 And this is just a review to assess 15 whether the advanced non-LWR PRA standard was 16 developed based on the JCNRM's agreed-upon rules and 17 conventions.
18 So, you know, common use of language, 19 phrasings and different requirements that are -- and 20 requirements that are similar, proper use of the 21 action verbs that occur throughout all these 22 requirements.
23 So, that was another good point of 24 interaction and provided an opportunity to familiarize 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 with the standard.
1 And then leading up to the first 2
consideration ballot there was another webinar just 3
before that ballot opened.
4 And that was intended to help prepare NRC 5
staff and the other JCNRM voting members for the 6
ballot review process, and also to provide context for 7
that ballot review to -- in some sense, it kind of 8
laid out the ground rules and, you know, what was 9
being looked for and recognition of how that standard 10 worked.
11 And so, you know, all of these steps were 12 instrumental in helping to prepare the NRC staff for 13 performing what was really quite a substantial review 14 and, you know, we had developed feedback to the JCNRM 15 for their consideration.
16 And I guess, you know, the next couple of 17 slides I'm going to talk about the first consideration 18 ballot and the recirculation ballot.
19 And, you know, the first consideration 20 ballot, it was generally understood that their -- it 21 wasn't intent necessarily on achieving consensus.
22 It was understood there was going to be 23 enough feedback that the JCNRM would have to take that 24 feedback, they would have to address it, resolve it, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 and then go for another, at least, one round of a 1
recirculation ballot. So, that the JCNRM didn't 2
achieve consensus wasn't entirely unexpected.
3 But if you proceed to slide 12, Donna, 4
we'll start talking about first consideration ballot.
5 So, as Michelle mentioned, this is about a two-month 6
period.
7 JCNRM received over 1300 comments. The 8
NRC did vote to approve and we did submit about 488 9
comments for that ballot. And I'll provide some 10 additional detail on those comments in the next slide.
11 The review, like I said, it was quite 12 substantive. There were a number of NRC review team 13 members about -- I think we have about 12 to 14 14 technical leads that also reached out to other NRC 15 staff and subject matter experts to address some 16 technical issues as they arose.
17 And I did want to point out that, you 18 know, the staff voted to approve and the NRC expressed 19 in its vote commentary that there's still a number of 20 issues that needed to be addressed before the advanced 21 non-LWR PRA standard would be considered ready for 22 use.
23 So, in providing our vote to approve, it 24 was much more intent on facilitating the forward 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 progress of the JCNRM and supporting the schedule that 1
they had committed to through our correspondence with 2
them.
3 Okay. Next slide, please. Slide 13.
4 Okay. So, like I said, the NRC submitted about 488 5
comments or so.
6 Many were editorial in nature or provided 7
some minor technical changes, but some of the more 8
substantive comments related to the listing that you 9
see here.
10 So, the nature in the application 11 screening criteria that are defined in the standard, 12 treatment of screening contributors, issues related to 13 certain definitions of terms, requirements related to 14 uncertainty, addressing issues associated with related 15 requirements and language and the LWR PRA standards.
16 That item in particular is probably a more 17 broadly assessed issue across all of the requirements 18 because there's so much of a relationship between this 19 PRA standard and the Level 1/LERF PRA standard, for 20 example.
21 There were -- we provided comments on how 22 some of the requirements would map to different stage 23 of the licensing process.
24 And then also we had a comment on use of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 the term "de minimis," which we had, you know, 1
identified as something that was closely related to --
2 I guess it's below regulatory concern, which -- and 3
so, it was being used in a different context and we 4
had pointed out that it had a slightly different 5
meaning in the regulatory space.
6 So, these were in -- you know, we had a 7
handful of comments for each one of these areas, but 8
this is just sort of the high-level overview of what 9
we have provided.
10 On the whole, I think that a lot of the 11 issues, like I said, there were a lot of minor 12 technical changes, you know, something was left out or 13 something needed to be phrased just a little bit 14 differently.
15 So, it's kinds of things that the NRC --
16 we could readily address in a clarification to a given 17 requirement in our regulatory guidance document or 18 whatever endorsing vehicle is, but, you know, things 19 that we would hope to have, you know, cleared up by 20 the JCNRM so that we didn't have to take those kinds 21 of clarifications and qualifications.
22 And the JCNRM was very accommodating in 23 that regard. So, it was a good relationship between 24 the two.
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35 Slide 14, please. Okay. So, the JCNRM 1
recirculation ballot. That started in late July and 2
ended in -- it was about a month long and ended in 3
August.
4 The JCNRM received a total of 86 comments.
5 As Michelle had mentioned, and I think we've taken 6
specific effort to point out as we've gone along and 7
briefed management and others, the JCNRM received 8
unanimous consensus from their consensus body on this 9
PRA standard.
10 And for the NRC's part, you know, we had 11 submitted 70 comments. But very similar to what we 12 did on the first consideration ballot, we had 13 submitted those comments and -- but also approved, 14 obviously, in the same -- you know, for the same 15 intent to basically make sure that there was continued 16 support for the forward progress.
17 The issues that we identified, you know, 18 some of them were regulatory issues. Michelle had 19 mentioned also that, you know, we had provided some of 20 these comments more in the form of an observation 21 versus a comment that was intended to try and compel 22 the JCNRM to make a change.
23 So, in the end, you know, some of these 24 comments were deferred to the next revision of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 advanced non-LWR PRA standard, and some were deferred 1
to resolution of issues in the related LWR PRA 2
standards in which there is significant ongoing work 3
even now to wrap up many of those efforts.
4 And so, the NRC was -- we were in 5
agreement with that. We understood -- you know, we 6
felt that this document was at a point of -- had a 7
good enough maturity that we could pick it up, we 8
could start reviewing it and start formulating our 9
staff position.
10 So, slide 15, please. Okay. So, I guess 11 I touched on some of these already. So, there were no 12 additional technical changes implemented by the JCNRM.
13 Some editorial changes were to be made and those were 14 subsequently agreed upon by the Consensus Committee.
15 And, like I said, some comments were 16 deferred to the next revision of the non-LWR PRA 17 standard and others to the LWR PRA standards.
18 So, in general, I think what I would want 19 to point out from this slide and these points and some 20 other points that Michelle has raised, is that we --
21 the staff recognized that there are significant 22 connections and interrelationships between the 23 requirements that were developed for the advanced non-24 LWR PRA standard, you know, recognizing, of course, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 that a large number of the requirements are derived or 1
adopted directly from the Level 1/LERF LWR PRA 2
standard.
3 Which is, you know, particularly important 4
because not only have those requirements enjoyed quite 5
a bit of experience over the past decade or two, but 6
they also have a staff endorsement in Regulatory Guide 7
1.200.
8 So, there's an established understanding 9
of how things seem to work and, in fact, you know, 10 many of those requirements are actually -- are already 11 technology neutral.
12 So, it's just to say that the staff 13 understand there is a lot of connection points there 14 and recognizing that the non-LWR standard is going 15 first forward for publication endorsement before the 16 related LWR standards. The staff are sensitive to 17 that and we are preparing for that.
18 As Michelle had mentioned, you know, we 19 have this comparison -- PRA standards comparison 20 database that's being prepared that's intended to, in 21 the end, provide the staff with this objective 22 assessment of the differences between these different 23 standards.
24 And so, that will be tremendously helpful 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 in helping to ensure consistency of our endorsement 1
and our staff position.
2 Slide 16, please. So, the next steps for 3
the NRC, so the advanced non-LWR PRA standard is 4
moving forward to its publication process.
5 The NRC staff are -- we are all preparing 6
and starting our reviews of the advanced non-LWR PRA 7
standard.
8 At this point, we do have available to us 9
this pre-technical editing version such that we can --
10 the technical aspects of it are stable enough that we 11 can -- the staff can start developing our position.
12 And, of course, ultimately we will have to 13 pick up and do a comparison against whatever the final 14 published version is, but notionally that shouldn't be 15 any substantive difference as the technical aspects of 16 it shouldn't be changed through the technical editing.
17 And so, in that regard, we are ready to 18 endorse, we're ready to start thinking about it, what 19 our endorsement and our staff position will look like.
20 We do expect that we will have 21 clarifications and qualifications. So, you know, 22 that's reflective that, you know, we -- not everybody 23 agrees on everything.
24 The JCNRM is a consensus body and they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 have a number of voting members, and the NRC is just 1
one of those voting members.
2 But of course, you know, the NRC, as far 3
as an endorsement is concerned, we retain the final 4
say over what our endorsement actually is.
5 And so, you know, as we continue to work 6
on this, we are deliberating on some of the 7
challenging regulatory issues.
8 Marty will speak to that in a little more 9
detail, but I just want to point out in this last 10 bullet, you know, we are confident that we have had 11 enough exposure to the context of this standard that 12 we don't foresee any significant issues coming up.
13 In that
- regard, you
- know, almost 14 everything is -- it's on the table right now and we 15 understand what we're -- generally what our staff 16 position is, the directions they're going to go in.
17 Okay. Slide 17, please. Okay. Let's see 18 here. So, the -- I guess I probably touched on a lot 19 of this already.
20 So, let's see. The final publishing 21 period, it will be, you know, endorsed. We will pick 22 up the final version.
23 And so, as far as the next -- what the 24 staff is planning for after the final publication, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 they -- we understand, and the JCNRM has communicated, 1
that another revision effort will be initiated not 2
long after the final publication of this first edition 3
of the advanced non-LWR PRA standard.
4 And, like I had mentioned before, this is 5
just to accommodate all of the interrelationships 6
between this standard and the related LWR PRA 7
standards, many of which have issues -- technical 8
issue that are -- have been resolved since the 9
advanced non-LWR PRA standard was sort of frozen into 10 its process so that it could move forward. So, there 11 is alignment to be achieved on some of those issues.
12 And, of course, you know, as the JCNRM 13 moves forward with that revision process, there may be 14 lessons learned from applications of the advanced non-15 LWR PRA standard.
16 And then at some point, the staff, you 17 know, we would notionally have our draft staff 18 endorsement and staff position made available to the 19 public and for the JCNRM to consider.
20 So, I think that is -- that's the end of 21 my slide presentation. So, I will pause there for any 22 questions.
23 (Pause.)
24 MR. GILBERTSON: I'm not hearing any. So, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 I will hand it off to Marty Stutzke -- or, I'm sorry, 1
Karl Fleming.
2 Please, go ahead, Karl.
3 MR. FLEMING: Yeah. Thank you very much, 4
Anders. I assume my voice can be heard now okay.
5 MR. GILBERTSON: Loud and clear.
6 MR. FLEMING: Yeah. Again, I don't see my 7
slides showing up on my Teams center. So, I'll be 8
looking at my slides separately.
9 And if we can show slide 2, first of all, 10 again, I'm Karl Fleming. I'm the chairman of the Non-11 Lightwater Reactor Working Group responsible for 12 drafting the standard and also a member of the JCNRM.
13 Slide 2 is simply a disclaimer to say that 14 I'm here to pass along information to the ACRS about 15 the standard and the balloting process, and I'm not 16 empowered to make any commitments or decision on 17 behalf of the JCNRM. It's just a -- sort of a 18 standard disclaimer and you've seen this disclaimer 19 before.
20 If we can go on to my slide 3, the topics 21 I'll address here, I'm going to go over some of the 22 same ground that Anders has gone over from more of the 23 JCNRM perspective, talk a little bit about the first 24 ballot and what we had to do to address the comments 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 that came out of that first ballot.
1 Then we'll work on to the recirculation 2
ballot where we were able to achieve full consensus, 3
and then talk about some of the next steps moving out 4
into the future.
5 On slide 4 of my package, this slide 6
you've seen before. I showed it last year. It's just 7
a reminder of the differences -- some of the key 8
differences between this standard and the -- some of 9
the supporting LWR standards.
10 We are addressing multiple plant operating 11 and shutdown states. The scope of our standard 12 includes taking scenarios out and developing, when 13 there is a release, mechanistic source terms and 14 radiological consequences.
15 We've adopted a
technology-inclusive 16 approach for risk metrics that can be applied to any 17 reactor and the way they're articulated in the 18 standard; frequencies of event sequences, event 19 sequence families and release categories.
20 We also have quantified mechanistic source 21 terms, radiological doses and health effects. And we 22 have -- there's options for user-defined end states 23 that make sense for specific reactors.
24 CHAIRMAN BLEY: Yeah, this is Dennis. I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 want to ask you a question. I'm not suggesting a 1
change to the standard, but it's a more general 2
question.
3 Since we've started looking at some of the 4
new designs and there are other even more novel 5
designs that will be showing up, we think, in the next 6
year or two, or a few more, it's become clear that 7
there seems to be no guidance in the staff's guidance 8
documents, or in the standards, to help with how one 9
searches for a unique initiating event.
10 Especially in novel technologies where 11 there might be highly energetic events that you 12 wouldn't have thought of for other designs.
13 And I, you know, we all know there are 14 some methods that can help you do that, in addition to 15 starting from scratch, so that you don't prejudice 16 your options of what you look at, but have you thought 17 about that and where that kind of guidance belongs?
18 I think we might be -- some new vendors 19 who are new to this process might be surprised when 20 they're asked to -- how thorough that search has been 21 and I don't think there's a lot of good guidance on 22 that.
23 MR. FLEMING: Yeah. That's a good --
24 yeah, let me see if I can handle that.
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44 The one thing that took me a long time to 1
appreciate working on these standards is that the 2
standards committees, especially coming from ASME, are 3
really loathe to mix very much guidance on how to do 4
things into the standards.
5 Now, that's not to say we don't have -- we 6
do have some guidance in the form of notes and so 7
forth, but the focus has always been to write the 8
requirements for what to do with minimal references to 9
how to do.
10 CHAIRMAN BLEY: But I'm not objecting to 11 that. And the standards say -- the standards to say 12 find them all, but --
13 (Laughter.)
14 MR.
FLEMING:
Yeah.
There are 15 requirements to do a systematic search for initiating 16 events taking into account the reactor-specific safety 17 functions and barriers and so forth. But as a more 18 direct answer to your question, I think some of the 19 documents that were put together for the LMP process 20 provides a better guidance on actually how to do that.
21 In particular --
22 CHAIRMAN BLEY: I think the document does, 23 in NEI-04 or whatever.
24 (Simultaneous speaking.)
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45 MR. FLEMING: No, but some of the 1
supporting documents for
- that, the supporting 2
documents, for example, some of the work that EPRI did 3
on working out the transitions between process hazards 4
analysis and PRA where they tried to develop tools for 5
-- especially focused on things like molten salt 6
reactors and so forth. So, there were --
7 MEMBER DIMITRIJEVIC: Karl?
8 MR. FLEMING: Yes.
9 MEMBER DIMITRIJEVIC: This is Vesna 10 Dimitrijevic. I want to continue on Dennis's question 11 with a little of different turn. So it will not, you 12 know, fall under this guidance thing, but actually 13 maybe Dennis asking about, which we have account, is 14 that type of uncertainty which there is no attempt to 15 address.
16 We try to address parameter uncertainty, 17 modeling uncertainty as well as we can, but addressing 18 completeness uncertainty is never discussed. This is 19 the most difficult uncertainty to address because we 20 don't know what we miss because if we know what we 21 miss, we would not miss it, right?
22 MR. FLEMING: Right.
23 MEMBER DIMITRIJEVIC: So, therefore, 24 addressing completeness uncertainty for those plants 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 should be essential in the guidance. Because if we 1
cannot address this uncertainty implicitly or 2
explicitly, we need to add this to the part where the 3
expert panels have to do the review to establish level 4
of completeness of the PRA.
5 MR. FLEMING: Right. Well, yeah, I think 6
that the completeness issue is really a generic issue 7
for all PRAs. Now, we've been working on light-water 8
reactors for so many years. Maybe people don't really 9
seem to worry too much about that, but it is a generic 10 issue for all reactors.
11 And one of the things that the JCNRM has 12 put a constraint on us is to try to make sure that 13 anything that's really applicable to all reactors, 14 including light-water reactors, be consistently 15 applied in, you know, in all the standards. So --
16 MEMBER DIMITRIJEVIC: Yes, but this is 17 really big issue here because there is no experience 18 for that. You know, we have much less experience with 19 non-light-water reactor. So, therefore, completeness 20 uncertainty should be really much bigger issue here 21 and it's not discussed anywhere.
22 Also, the task risk-informed -- risk-23 informed means -- it is not risk-based, it is risk-24 informed in support to the existing regulation.
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47 However, applicability of existing regulation for non-1 light-water reactors is also questionable and has 2
uncertainty associated with it.
3 So, therefore, just in general, to accept 4
this risk-informed term and, you know, to accept how 5
the existing regulation is applicable, some really 6
strong expert panel which will consist of the people 7
with experience in thermal hydraulics and the PRA and 8
regulations sitting together and making sure that this 9
process is pretty complete should be made as a 10 requirement somewhere, in my opinion.
11 I'm really struggling with this because, 12 as Dennis said, from our experience in the advanced 13 reactor use, we already realize that you can miss some 14 important thing because the design is different, which 15 you, you know, look in.
16 MR. FLEMING: Okay.
17 MEMBER DIMITRIJEVIC: And we start having 18 the steps which are completely different what we are 19 used to. That could be a lot of misses of the things 20 which we have not experienced before.
21 So, one of my main comment, and I am glad 22 that Dennis started here, on all of this process is 23 the completeness uncertainty issue should definitely 24 be addressed in Reg Guide and the standards.
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48 MR. FLEMING: Yeah, I think that's a good 1
point, but I think that -- I think it's really not --
2 it's not really that -- it won't be effective to try 3
to address that issue on a generic technology-neutral 4
basis.
5 And I think if you break it down -- if you 6
break that question down to high-temperature gas-7 cooled reactors, which there's been PRA work all the 8
way back into the '70s, sodium-cooled fast reactor 9
have a similar level of experience -- each reactor 10 technology will have to be looked at, you know, 11 separately for that question.
12 But I do believe that some of the 13 supporting work that was done in the licensing 14 modernization project, the work done at EPRI and the 15 supporting technical reports that back up NEI 1804 16 provide, you know, additional guidance aimed at how 17 you build your first -- you know, your master logic 18 diagrams and your process hazards analyses and 19 structured approaches to find completeness of 20 initiating events.
21 CHAIRMAN BLEY: Karl, that helps.
22 Are those actually called out in 1804?
23 MR.
FLEMING:
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49 that were published for the Department of Energy.
1 And all those supporting references -- in 2
fact, all those documents were updated in March 2020 3
and we can provide those references.
4 CHAIRMAN BLEY: If you could get that to 5
Derek, I think that would be very helpful for us 6
because we're raising this issue in other places as 7
well.
8 We'd find that very useful if you can do 9
that.
10 MR. FLEMING: Yeah. I'm not claiming it 11 will completely answer your question, but there is 12 substantial additional guidance along these lines that 13 I can cite.
14 CHAIRMAN BLEY: It will help. Thanks.
15 MR. FLEMING: Okay. Good.
16 MEMBER REMPE: Karl, this is Joy. And I 17 apologize because at the beginning of this slide I got 18 distracted with something else. So, maybe you've 19 covered it.
20 But when I was looking through the 21 standard that we were sent most recently, I really 22 wanted to see something about the risks that are 23 associated with the transport to the installation or 24 removal of a reactor with a loaded core, then 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 transport from the site.
1 And it's sort of related to completeness, 2
but what I saw in the standard was still focused 3
within the boundaries of the plant and they didn't 4
talk about some of these unusual states.
5 And I'd note that this isn't something 6
that's just for non-LWRs like the micro reactors. We 7
even had a loaded -- have a loaded core moving with a 8
recent LWR that's an advanced reactor that we've been 9
reviewing.
10 So, is there something that I've missed?
11 I mean, it had a lot of pages. It's grown this most 12 recent standard.
13 Am I missing -- I sure didn't see anything 14 that really alerted people to the unusual types of 15 operating and shutdown states associated with non-16 LWRs.
17 MR. FLEMING: Yeah. I think your 18 observation is correct. This standard covers the 19 plant after it's been constructed and started up.
20 It doesn't involve transportation of 21 components to the site or disposal afterwards or 22 whatever. It's just the plant. As far as --
23 MEMBER REMPE: Well, the plant is shut 24 down and some other units might be operating. You may 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 be moving a unit.
1 MR. FLEMING: Oh, yes. It does account for 2
the fact that some reactors might be in different 3
operating states at the time of initiating event, yes, 4
but it's an already-built plant is the assumption in 5
the standard.
6 MEMBER REMPE: But, still, the module 7
reactor is one of their economic selling points. You 8
don't have to wait until it's all constructed before 9
you start up.
10 And that's where I -- I think, again, I 11 don't think you can solve the problem, but I think the 12 standard ought to alert the analysts to think about 13 the problem.
14 MR. FLEMING: No, the construction of new 15 units, while the other units are under construction, 16 is not covered in the standard. It's not intended to 17 be covered.
18 MEMBER REMPE: Why not?
19 MR. FLEMING: Well, it's -- it's just 20 outside the scope of what we're able to do, you know.
21 MEMBER REMPE: You've got these -- some 22 of these designs that we've been told about, I think 23 that it might mention that somehow or other. But, 24 anyway, I'll let you go on, but I was hoping to see 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 something about --
1 MR. FLEMING: It's simply outside the 2
scope. I -- and as to why, you know, I can't really 3
answer that. This is what we were able to achieve and 4
this is what the JCNRM asked us to do.
5 You know, a lot -- you know, what the --
6 a lot of what we were tasked to do in this working 7
group is to come up with something that was comparable 8
to the light-water reactor standard, but would also be 9
able to handle different types of reactors.
10 The light-water reactor PRA standards 11 don't handle these issues either. So, we were 12 basically held to the yardstick of trying to come up 13 with comparable, but yet account for different reactor 14 technologies, different reactor designs and do it in 15 a technology-inclusive way. So, that's as far as we 16 could take the problem.
17 CHAIRMAN BLEY: Having participated in 18 some of this kind of work I can understand that, Karl, 19 and that you're constrained by a broad range of 20 participants as to what you can do.
21 But I think, Joy, this is something we 22 ought to bring up with the staff because the staff 23 guidance ought to point out the places where there are 24 gaps in the standard and where applicants are going to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 be responsible to consider it.
1 So, that might be a reasonable approach 2
for us to take.
3 MEMBER REMPE: I'd go for that.
4 MR. FLEMING: Right. Now, on the pre-5 operational design stages, the one thing -- we don't 6
get into U.S. -- well, there are exceptions to this, 7
but this is an international standard and we don't --
8 we're not writing this tied to the U.S. regulatory 9
structure, per se, although we do mention some 10 examples in there.
11 But the -- this question about what kind 12 of PRA you need for what type of license application 13 is viewed to be beyond the scope of the standard.
14 It's something that has to be done by the 15 user in conjunction with his regulator -- his or her 16 regulator to define what is the type of PRA that's 17 needed.
18 So, the way we talk about that in the 19 standard is that we support the PRA being done at 20 different pre-operational design stages all the way up 21 through and including operational stages.
22 We have specifically put the capability in 23 here to do -- to support something like a design 24 certification PRA where the PRA addresses a range of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 sites.
1 So, this was -- that's probably why you 2
see mention of a design certification application in 3
the standard, but we don't -- we've tried -- in the 4
latest revisions to this we've tried to strip out most 5
of the explicit references to U.S.-specific licensing 6
positions and policies. That's something that needs 7
to be done in the regulatory guide.
8 And, you know, roughly 80 percent of the 9
requirements are common to the light-water reactor 10 standards.
11 One of the things that came out in Anders' 12 presentation, and I'll get to, you know, my version of 13 that, is that the NRC requested that the JCNRM put 14 priority on this non-light-water reactor standard and 15 we got it sequenced ahead of the next edition of the 16 light-water reactor standard, which is still going 17 through the balloting process.
18 So -- and that was done to try to 19 accommodate NRC's priority -- prioritization and also 20 to persuade NRC to endorse this version of the non-21 light-water reactor standard rather than the trial use 22 version that was published in 2013.
23 So, that lent itself to a structure where 24 we could only go so far to get alignment with the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 light-water reactor standards that are still being 1
processed and standardized.
2 DR. CORRADINI: So, Karl, this is 3
Corradini.
4 What sorts of things are in the 5
requirements here that aren't in the light-water 6
reactor standards? Can you give me a couple of big 7
differences?
8 MR. FLEMING: Well, right -- well, the 9
pre-operational
- stages, that's currently being 10 addressed in the -- in an ALWR standard, which is not 11 out yet for trial use.
12 The LWR standards don't specifically cover 13 how you do a PRA for a range of sites. The light-14 water reactor standards don't deal with multi-unit --
15 multi-reactor accident sequences. They only deal with 16 one reactor accident sequences.
17 This standard is intended to cover all the 18 sources of radionuclides in the plant. And the 19 current light-water reactor standards are -- basically 20 only account for the reactor source term.
21 So, that's -- there is a low-power 22 shutdown standard that we've made use of to get the 23 low-power shutdown states. So, that's basically the 24 key points I wanted to make on that slide.
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56 DR. CORRADINI: So, let me say one back to 1
you to make sure I understand what you're saying.
2 So, for example, if I have a non-light-3 water reactor that might have multiple modules and how 4
to address that, that's covered in this current 5
standard?
6 MR. FLEMING: Yes, it is. Yes, it is.
7 DR. CORRADINI: Okay.
8 MR. FLEMING: Yes. And, again, that --
9 you know, all these kinds of features and processes 10 that we have addressed in this is all dictated by the 11 stakeholders that wanted the standard. So, it was all 12 driven by those kinds of considerations.
13 DR. CORRADINI: Alright. Thank you.
14 MR. FLEMING: So, in slide 5, the way 15 we've organized this, you know, the multi-part 16 standard structured in the light-water reactor 17 standard wasn't too workable for us and the users 18 wanted to have a -- more of what's called a fully 19 integrated standard to be able to handle the types of 20 applications we were looking for here.
21 So, we've organized this by technical 22 element in the 18 -- Michelle said there were 19 here.
23 I have to maybe go back and count them, but all the 24 technical elements in our standard are listed in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 slide, and the applicability to different hazard 1
groups and internal events, other internal hazards 2
like internal fires and floods, and external hazards 3
are indicated in this slide.
4 So, this is the way we've structured the 5
analysis and we modified some of the language that 6
describes these to be more generally applicable to our 7
types of reactor.
8 So, you've seen this before and this 9
structure has been maintained in the latest version of 10 the standard.
11 If we go on to slide --
12 MEMBER DIMITRIJEVIC: Karl?
13 MR. FLEMING: Yes.
14 MEMBER DIMITRIJEVIC: This is Vesna. You 15 have this mechanical source term and you just respond 16 on the question on the multi-units. Is this multi-17 units consideration included in the source term 18 analysis?
19 MR. FLEMING: It's included all the way 20 throughout in the multiple plant -- in the plant 21 operating states, initiating events, event sequences, 22 everything. There's multi-unit references throughout 23 the standard.
24 MEMBER DIMITRIJEVIC: But the biggest 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 input would be on the source term analysis so --
1 MR. FLEMING: Yes, source term. Yes, 2
absolutely. If there's multiple releases from 3
different sources, that would be covered as part of 4
the source terms and consequences. And because of 5
- that, the frequencies the event sequence 6
frequencies in the standard are measured in terms of 7
per plant year where the plant is the thing that 8
you're analyzing which may involve multiple reactors 9
and would also involve other nonreactor sources.
10 So, in order to have a coherent way to 11 measure those frequencies, we measure on a per-plant 12 year and that's similar to the way we do it in the LMP 13 process.
14 DR. CORRADINI: So, when you say "a 15 plant," Karl, you mean a particular site? I'm not 16 sure I follow your definition of the plant here.
17 So, a plant could have multiple modules?
18 MR. FLEMING: Yeah -- well, it's the 19 entity that defines the thing you're trying to 20 analyze, okay? So, you -- it's not intended to cover 21 co-located reactor -- you know, if you're going to 22 build a new plant, a new non-light-water reactor plant 23 on an existing site, this is the plant PRA.
24 And if it involves multiple reactors -- we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 don't get into co-located plants that are already 1
there when you build the plant.
2 We don't go into that level of site PRA, 3
but we do the multi-reactor and multi-source within 4
the plant that the user wants to do the PRA on.
5 So, it's all defined by the user, what the 6
user wants to analyze.
7 DR. CORRADINI: So, just to go a little 8
step further, so let's say I've got Site X and Site X 9
has old Plant A and new Plant B.
10 Plant B would essentially analyze Plant A 11 as an external hazard?
12 MR. FLEMING: We don't actually go into 13 full -- this is not -- the scope of this standard 14 doesn't cover what -- I think what you're alluding to 15 would be a whole site PRA that has a mixture of old 16 and new units.
17 DR. CORRADINI: Okay.
18 MR. FLEMING: We only cover -- you know, 19 we just draw a boundary around the plant --
20 DR. CORRADINI: Okay.
21 MR. FLEMING: -- that you want to maybe 22 license or build or whatever that may involve multiple 23 reactor modules. That's as far as we go here.
24 DR. CORRADINI: Thank you.
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60 MR. FLEMING: Now, going back over some of 1
the topics that Anders has already covered, I'll give 2
you another sort of spin on those types of things.
3 We got 1319 comments, including 489 from 4
the NRC staff. As Anders mentioned, we had meetings 5
with all the people that provided comments and we had 6
special meetings with the NRC staff to --
7 CHAIRMAN BLEY: Karl?
8 MR. FLEMING: Yes.
9 CHAIRMAN BLEY: That's a big number.
10 Were they mostly substantive or mostly 11 editorial?
12 MR. FLEMING: I'd say probably most of 13 them were editorial. In fact, clearly the vast 14 majority of them were editorial.
15 But when you're writing standards, those 16 editorial comments are very important to get -- to 17 make sure that the standard is interpreted right.
18 So, we have quite a lot of rules and 19 regulations about what verbs to -- action verbs to use 20 and those types of things.
21 CHAIRMAN BLEY: Fair enough.
22 MR. FLEMING: But the vast majority of 23 them were editorial. I also want to say that all the 24 comments and all the resolutions of the comments are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 documented in the -- what's called the CNS Connect 1
website that ASME runs.
2 And when this gets to the point of ANSI, 3
the National Standards Institute, to get their moniker 4
on that, they look very carefully at what were the 5
comments and what was the disposition of the comments.
6 Even if the comment is attached to a 7
favorable vote, it has to be dispositioned. And the 8
documented dispositions to all those comments is 9
available.
10 And if the ACRS would like to see that, 11 those can easily be made available as well as the 12 recirculation ballot comments as well.
13 So, we have -- we had some special 14 meetings with the NRC staff to go over their 15 particular comments and our resolution of those, the 16 vast majority of which led to revisions of the 17 standard.
18 I'd have to say that all the comments, 19 especially the NRC comments, the resolution of those 20 substantially improved the quality of the technical 21 quality of the standard.
22 There were very, very few cases where the 23 writing group and the JCNRM simply agreed to disagree 24 on maybe a technical point of the standard. So -- but 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 all that dialog and disposition, as I say, is fully 1
documented.
2 Because of the sequencing where we put our 3
standard in front of the light-water reactor standard, 4
which I have mentioned is still going through the 5
balloting process, we did the best we could to get 6
alignment with the supporting LWR standards. We can 7
only go so far.
8 So, we also had to then throw our comments 9
over the fence -- these comments over the fence to the 10 LWR folks because they were going to have to deal with 11 the same comments for the light-water reactors.
12 As I
mentioned, we documented our 13 responses. We reached out to all those that provided 14 comments and we retain concurrence that our strategy 15 to resolve them was acceptable to the reviewer. As I 16 mentioned, there are very few cases that we have any 17
-- agree to disagree.
18 Of course the distribution, you know, the 19 NRC is one member of the JCNRM. And, as Anders 20 mentioned, there was a large staff of people available 21 to provide all their comments, but this was the 22 distribution of comments by individual that provided 23 comments. All the people that provided comments are 24 here and, you know, again we appreciate all the -- I'm 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 sure that a large investment of resources invested by 1
the NRC to provide these comments.
2 Now, getting into the changes that were 3
made after the first ballot went out, and a lot of 4
these came from the NRC staff review, we made some 5
changes to the screening criteria.
6 So, we put limits on the cumulative 7
impacts -- the cumulative risk impacts of the 8
screened-out items instead of just looking at 9
individual item-by-item screening criteria.
10 We had mixed together in a
given 11 requirement what to do for pre-operational cases and 12 what to do with an as-built operated built --
13 CHAIRMAN BLEY: So, you're on slide 6 now, 14 Karl?
15 MR. FLEMING: I'm sorry. I'm back up to 16 slide 8.
17 CHAIRMAN BLEY: 8, okay. Thank you.
18 MR. FLEMING: Sorry. Sorry. I'm flipping 19 slides without telling you. Sorry.
20 CHAIRMAN BLEY: Just give numbers and 21 she'll get the right one up for us.
22 MR. FLEMING: Yeah. So, on the second 23 bullet on this one, we had to separate out -- the way 24 we handled pre-operational PRAs was to put work-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 arounds or put specific things on how you could meet 1
a requirement at a given capability level if you're 2
trying to do a PRA before you've had all the 3
information from an as-built operated plant.
4 And just to make things more coherent, we 5
decided to separate those out instead of mixing them 6
together in the same requirement so that provided a 7
little bit better structure.
8 The NRC, as Anders mentioned, this de 9
minimis concept we introduced into the standard. One 10 of the feedbacks we got from our pilot study, one of 11 the major pilot studies was done on the PRISM plant by 12 GE Hitachi.
13 They had some problems with what to do 14 with low numbers. Low numbers for frequency and low 15 numbers for consequence.
16 I mean, what do you -- do you present a 17 result like I had 10 to the minus 27 latent cancer 18 fatalities, you know, things like that?
19 So, what we did is we came up with 20 reporting thresholds that if you calculate some 21 frequency level below a certain level, and we picked 22 ten to the minus seven per plant year, just report it 23 as less than ten to the minus seven per plant year and 24 don't try to write down 10 to the minus 27 or 28 or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 whatever. And this was just simply a recognition of 1
the limitations of the PRA technology.
2 So and a
similar thing for 3
consequences. If, for example, you calculate a very 4
low dose and if you integrate it over the population, 5
you get a number of latent cancer fatalities that's a 6
fraction of what you would get from background 7
radiation over this duration to release, then just 8
don't -- you know, just say less than X, whatever X 9
is.
10 So, we took the term "de minimis" out, but 11 we retained the idea of having reporting thresholds so 12 that we don't try to take seriously numbers that we 13 really can't defend.
14 So, if we go on to slide 9, the way we do 15 our event sequence development, we had a technical 16 element called event sequences, and it goes all the 17 way out to an end state that might involve a release.
18 And what we found was that there was a 19 little confusion between both the event sequence 20 analysis element and the mechanistic source term 21 analysis element. Both covered the question of how 22 you define your end states and release categories.
23 So, we sorted that out so there was more 24 a coherent division of responsibilities for where 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 those are.
1 One important thing is that, you know, the 2
light-water reactor standard for external hazards like 3
seismic events, for example, since it only deals with 4
single reactor PRAs, the requirements for building 5
your plant response model using the results of the 6
internal events analysis, we had to modify those so 7
that initiating events that might involve two or more 8
reactor modules and sources were adequately handled.
9 Similarly, you know, requirements were, 10 for example, the seismic equipment list to make sure 11 you had those accident sequences involving multiple 12 reactors taken into account.
13 Then on slide 10, there were a lot of 14 comments on definitions. The definitions are 15 important because any special term that's used in the 16 technical requirements that has something other than 17 a common English meaning needs to be defined properly.
18 And that's really an extension of the technical 19 requirements.
20 So, we had to refine and improve our 21 definitions of safety functions, bounding site, add 22 initiator human failure event and those types of 23 things to get clarity in what the meaning in the 24 technical requirements were.
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67 We had to chase around some changes that 1
were made in definitions of terms in the next edition 2
of the LWR standard. And so, that led to some changes 3
there.
4 And then we had a number of comments of a 5
purely editorial nature and we fixed all those in the 6
first balloting process.
7 We then, as Anders mentioned, we issued 8
this for -- through the process we reached out and 9
negotiated resolutions with all the reviewers, 10 including the NRC staff reviewers.
11 And then used that to formulate a 12 recirculation ballot version of the standard, which is 13 pretty much the standard that was approved from a 14 final analysis.
15 We had 86 comments that were posted on the 16 recirculation ballot, including 70 from the NRC staff.
17 Again, we reached out to all the commenters and 18 developed our strategy to resolve all these comments.
19 And we came to the position that we didn't 20 think that any further changes or another round of 21 recirculation ballot would be necessary to move 22 forward.
23 And after posting our responses to all the 24 comments, we were able to achieve a perfect 30-to-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 nothing vote on approving the standard.
1 This was the first unanimous approval of 2
any PRA standard out of the JCNRM, which we were quite 3
glad to achieve. And it's only the result of spending 4
a lot of time talking and discussing resolution 5
strategies with all the people that supplied the 6
comments.
7 In the disposition of the recirculation 8
comments, we were able to resolve 14 of them by 9
basically presenting our position that we didn't think 10 any changes were necessary. We classified 24 as 11 editorial that we said could be fixed prior to 12 publication.
13 There were 13 comments that we thought 14 were good comments, but there were comments that 15 involve guidance that really didn't affect the wording 16 of the technical requirements.
17 And while we agreed with the comments, we 18 thought that we would want to defer addressing these 19 until the next opportunity to revise the standard down 20 the road, which I'll talk to separately here on my 21 last slide.
22 DR. CORRADINI: Karl, before you leave --
23 MR. FLEMING: Yes.
24 CHAIRMAN BLEY: Karl, you earlier said 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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69 guidance doesn't belong in a standard. What's the 1
deal here?
2 MR. FLEMING: Well, I did, but I also 3
said, if you remember what I said, I said that it was 4
discouraged to include a lot of guidance in the 5
standard, but, nonetheless, we have these things 6
called non-mandatory notes. And the non-mandatory 7
notes essentially are interpretations of the 8
requirements and guidance on what the requirements 9
mean.
10 So, it's not really guidance on how to do 11 the PRA. It's more like guidance on how to interpret 12 what the requirements are. So, sorry for the 13 confusion.
14 DR. CORRADINI: So, Karl, where do these 15 non-mandatory notes show up? Like an appendix?
16 MR. FLEMING: Yeah. So -- okay. For each 17 technical element, for example, one technical element 18 would be initiating events analysis.
19 Okay. The first part of that would be 20 objectives -- it will be objectives of the analysis.
21 They'll be the high-level requirements, the supporting 22 requirements, references, if they have them.
23 Then we'll have peer review requirements 24 for that technical element that are unique to that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 technical element. Then the final part of each 1
section would be the non-mandatory notes.
2 DR. CORRADINI: Okay.
3 MR. FLEMING: Yeah. So, every one of the 4
18 sections of our requirements has that structure.
5 And we try to structure it that way so it's -- all 6
these notes are close to where the requirements are in 7
the standard.
8 DR. CORRADINI: But these notes are 9
explanatory on what to do -- I'm sorry, what is 10 required, excuse me --
11 MR. FLEMING: Yes.
12 DR. CORRADINI: -- versus how to go about 13 it.
14 MR. FLEMING: Exactly. Exactly.
15 They're explanatory notes to interpret 16 what's the meaning of the technical requirement and 17 how to apply the requirement to an existing PRA, not 18 how to do the PRA.
19 27 comments were really not unique to the 20 non-light-water reactor standard. They were valid 21 issues that apply to LWRs as well.
22 And we -- by this time, we just decided to 23 defer those to the LWR standards groups. And whenever 24 those standards get finalized, we'll have an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 opportunity to come back and incorporate any new 1
wrinkles into this -- in a future rendition of this 2
standard.
3 Eight of the comments were basically set 4
out to express a regulatory position from the NRC.
5 And the NRC did not intend any changes to be made, 6
they just wanted the stakeholders that were 7
participating in the balloting process to have a heads 8
up on some of the regulatory positions. So, these 9
were just -- did not require any final changes.
10 So, as a result of that, we have reached 11 the -- you know, the resolution as far as this 31-to-12 nothing vote, but we're not done yet.
13 We go on to the next slide, slide 13. In 14 order for this thing to get out and published as a 15 final standard, it's got to be approved by the boards 16 of ASME and ANS.
17 It's got to go through a public review 18 process, it's got to go through a final editorial 19 process, and then it finally gets published.
20 So, where we're standing today is that 21 we've completed the ASME board review. When the ASME 22 board reviewed it, the chairman of that board said 23 they were uncomfortable with having these 24 editorial 24 comments made without having the JCNRM weigh in.
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72 So, in the last JCNRM meeting, we had a 1
voice vote to have the JCNRM approve the changes that 2
were made to address those 24 editorial comments.
3 In fact, we've now decided that when 4
additional editorial comments are made by the editing 5
team, which is now working on the standard, any 6
further editorial comments will also be run by the 7
JCNRM to make sure they agree with all those 8
additional editorial changes.
9 A 60-day public review has been initiated 10 and that public review period will end on 12/15/20 and 11 the ANSI -- ANS boards and the ANSI boards need to 12 finish their reviews.
13 So, given the timing of the 60-day review 14 period, it does appear that the final published 15 version won't come out until early 2021.
16 All the changes that are being made, 17 though, between what's on the table now that you're 18 available to see right now, and what will come out at 19 the end, are really purely editorial in nature and 20 should not affect the technical understanding of the 21 review.
22 Now, we've obligated now to, as Anders 23 mentioned, to issue a future revision of this 24 standard. And some of the things that have to happen 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 before we can do that are listed on my last slide 1
here, No. 14.
2 The Level 1/LERF standard, the next 3
edition of that needs to get finished with the 4
balloting process, which is ongoing. It hasn't 5
achieved a consensus vote yet.
6 It's been out for a ballot and, I believe, 7
recirculation ballot and there's still outstanding 8
comments that need to be resolved.
9 We also have made use of information from 10 the low-power shutdown Level 2 and Level 3 standards.
11 And each of those standards is going to have to be in 12 alignment with the next edition of the LWR standard as 13 well.
14 So, those -- at a minimum, those first two 15 bullets would have to be done before it would justify 16 our group to make another edition of our standard. At 17 which time, we'll be able to get more perfect or more 18 complete alignment with the supporting standards.
19 In parallel with that work -- and I -- we 20 don't have any control. I mean, my working group 21 doesn't have any control over these first two bullets.
22 NRC will be proceeding with their 23 regulatory guide and perhaps interim or draft 24 regulatory guides along the way.
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74 So, we expect that we'll get feedback from 1
that process that might give us an opportunity to 2
rethink some of our specific supporting requirements.
3 And I think most important on this slide 4
is that we have ongoing stakeholders right now that 5
are using the standard to support licensing 6
interactions with the NRC staff.
7 And we expect that the stakeholder 8
feedback from those processes will provide us good 9
insights on what to do.
10 So, those are some of the things that will 11 influence the next edition of our standard. It's 12 difficult to speculate on the timing of that because 13 of all the other things that have to fall into place, 14 especially these first two bullets on the slide, 15 before we would have the right material to move 16 forward.
17 CHAIRMAN BLEY: Karl, related to this, is 18 there any effort where -- either sponsored by the 19 industry or maybe the staff wants to speak on this one 20 as well -- to put out some kind of summary document on 21 the experience of the pilot plants and maybe early 22 adopters of this for general information?
23 MR. FLEMING: Well, I think that's a good 24 idea. I'm not aware of any particular plans to do 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 that, but I would -- our working group would greatly 1
welcome such an activity.
2 There's a couple of things that, Dennis, 3
you mentioned at the beginning. I do believe that 4
we've made it clear that all hazards are expected to 5
be addressed. All the hazards that we're aware of, at 6
least, are addressed.
7 And our screening criteria that we've 8
developed, we've developed with the view that entire 9
hazard and hazard groups may be screened out.
10 In this standard, we have taken the 11 position that it's possible to screen out internal 12 fire hazards as a hazard group.
13 We still require consideration of internal 14 events and seismic events, but we do -- our 15 stakeholders believe that, in some cases, they think 16 that they can design -- basically design out any 17 significant risk contributors from things like 18 internal fires.
19 CHAIRMAN BLEY: That would be interesting 20 to see. It doesn't seem possible so far, but who 21 knows. Perhaps.
22 MR. FLEMING: Yeah. Well, we put the 23 capability to do that. Now, whether people can 24 demonstrate they can meet that, that's another 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 consideration, but our screening criteria are designed 1
to be able to handle that.
2 Let's see. What else? Yeah, the question 3
about 50 versus 52. We -- there's no reason why you 4
can't use the standard for a Part 50 application.
5 The fact that we may have mentioned 52, or 6
examples that fit into 52, is maybe just a 7
coincidence. So, there's no reason, in principle, 8
that I can see.
9 And as far as --
10 CHAIRMAN BLEY: I think we'd agree with 11 that as well, except when somebody picks up a standard 12 and starts using it if all the call-outs are to one 13 thing, they might be reluctant to use it without a 14 clear statement up front that says this is for all 15 applications.
16 MR. FLEMING: Right. And one other --
17 yeah, one other thing that was mentioned earlier that 18 I sort of wanted to comment on -- and this sort of 19 came up in some of the comments, I believe, even in 20 the recirculation ballot comments that we got from the 21 NRC -- so, you know, there were comments along the 22 lines that, okay, someone does an early design stage 23 PRA and they do the -- and they apply the standard and 24 then later on they upgrade their PRA to a different 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 design stage, 1
They might do a design certification 2
application PRA for their design certification, and 3
then later on they might be wanting to apply this to 4
a specific
- site, specific PRA based on the 5
application.
6 And one of the thoughts that we had is 7
that if you're doing another PRA for a more advanced 8
design stage or more specific site characterization, 9
it's a different PRA.
10 So, the way the standard structure -- I 11 mean, it's a different state of knowledge. You're 12 going to have to rethink how you apply the standard, 13 how you define your capability categories, what risk 14 significance criteria you're going to use.
15 So, the way we look at these things that, 16 you know, if you have an old PRA that you're upgrading 17 for a new licensing stage, it's a different PRA and 18 you'd have to sort of, you know, reestablish how 19 you're going to apply the PRA standard.
20 And things like peer reviews, you know, 21 you have to peer review -- you know, you'd have to 22 peer review a new PRA because it's a different PRA.
23 So, that pretty much concludes what I had 24 prepared to talk about. I appreciate the excellent 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 questions.
1 CHAIRMAN BLEY: You started me to think of 2
one more thing there.
3 So, in the last meeting, the staff pointed 4
out their guidance in the Reg 1855, you know, 1 now, 5
on treatment of uncertainties in PRA and I know the 6
standard addresses that at various levels.
7 One thing you and I talked about a long 8
time ago is if you really think about uncertainty 9
properly as you move along the stage of more refined 10 design, you should have allowed enough uncertainty 11 early on which ought to be zeroing in rather than all 12 of a sudden the risk changes wildly in one direction 13 or the other.
14 Any guidance on that? I don't remember 15 seeing anything.
16 MR. FLEMING: Well, the one thing that 17 touches on that, Dennis, is that one thing that's 18 throughout all the technical elements, every -- you 19 know -- well, let me back up a little bit.
20 When we inherit the LWR standard, we have 21
-- already have, you know, brought in a lot of 22 requirements that deal with uncertainty to start with.
23 And for almost every single element we 24 have a specific requirement to identify the unique 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 sources of uncertainty associated with the lack of 1
design details or operational details for an early 2
design stage PRA.
3 So, we call out specific -- special 4
uncertainty requirements for that part of the 5
uncertainty and at least flag the --
6 CHAIRMAN BLEY: A follow-on question from 7
me would be -- because I haven't done it -- have you 8
seen examples in the peer review process of how people 9
actually deal with that and if they're convincing in 10 their completeness of what those uncertainties are?
11 MR. FLEMING: I can't say that I have. I 12 don't think we have a substantial amount of peer 13 review experience against the standard.
14 There was -- TerraPower, one of our 15 stakeholders associated with the standard, Brian 16 Johnson was our working group member on that, several 17 years ago did a peer review against his traveling wave 18 reactor PRA that was based on the trial use version of 19 the standard where we had similar types of design 20 stage uncertainty requirements.
21 And we've asked TerraPower to provide a 22 public review of -- you know, a public -- for public 23 consumption version of their peer review report to see 24 whether we have any of those.
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80 And I -- the last time I checked, that 1
hadn't been through their legal department yet, but 2
that's the -- that's the one area where we have some 3
evidence, at least anecdotal evidence, that there has 4
been some peer review against the standard.
5 CHAIRMAN BLEY: Okay. That would be 6
interesting to see.
7 Do any of the other members have any 8
questions for Karl?
9 MEMBER PETTI: Yeah. This is Dave.
10 Do you hear me?
11 MR. FLEMING: Yes.
12 CHAIRMAN BLEY: Yes, indeed.
13 MEMBER PETTI: So, let me just give you a 14 data point about the impact of design detail and the 15 lack of it on cost.
16 It's quite clear in the literature when 17 you don't have a lot of design detail, you tend to 18 underestimate the cost early, and the cost grows as 19 the design evolves. And this is not even -- this is 20 in almost any engineering -- large engineering 21 endeavor.
22 So, I think of that relative to your 23 concerns about uncertainty in the PRA and I just worry 24 that it may be also the case in the uncertainties just 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 because of sociological aspects of a design and how 1
that all works.
2 There's a lot of literature out there 3
about the group think that occurs in design 4
organizations particularly from a cost perspective, 5
but I would imagine it might leak over into these 6
other things. So, just something to think about.
7 CHAIRMAN BLEY: It certainly does apply 8
and you have to be really disciplined about searching 9
for those sources and that can be very helpful.
10 And you could do it on the economic side, 11 too. If you put the effort in -- you're right. If 12 you don't put the effort in, you always underestimate 13 and I think that's true of --
14 MR. FLEMING: Yeah. If I could offer 15 another insight into that -- I appreciate the point 16 and, in my experience being project manager in 17 estimating costs of doing work and so forth, I 18 certainly understand why, but I think there's a 19 compensating tendency in human nature that tends to 20 compensate for that.
21 And that is that the way -- you know, 22 there's a tendency to cover your lack of knowledge 23 with conservatisms.
24 Even though the spirit of PRA is to try to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 base everything on realistic, you know, realistic 1
assumptions and realistic inputs, I think there's a 2
human nature input to be somewhat conservative in the 3
way they account for the lack of information.
4 So, I think that that doesn't necessarily 5
offset entirely your point, Dave, but I think it tends 6
to at least partially compensate for it.
7 MEMBER REMPE: Well, I have to -- we 8
renewed a plant recently. And when we had an earlier 9
discussion with them about their PRA, they put up a 10 plot showing the risk is a function of time. And it 11 started out that the risk was low and then it grew 12 because more design information came in. And then 13 they added some safety features or got more data to 14 reduce it.
15 And it was an interesting plot as a 16 function of time that had nothing really to do with 17 the design. It was knowledge and their ability to 18 assess the plant.
19 And it's just -- it would be nice to see 20 that for a lot of plants and how their design has 21 evolved and their risk estimates have evolved.
22 CHAIRMAN BLEY: Well, this is different 23 because, you know, how you do expert elicitation to 24 deal with that.
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83 MEMBER REMPE: Yes.
1 CHAIRMAN BLEY: So, I think we're going to 2
take a break now and then we'll come back. We're a 3
little behind schedule so we might go over a little 4
bit. I don't think so. I think it will go reasonably 5
well.
6 Marty is next and his will probably be 7
very interesting for us and have a lot of discussion.
8 So, let's take a break from now until about -- let's 9
go until 10 after and then come back.
10 (Whereupon, the above entitled matter went 11 off the record at 3:52 p.m. and resumed at 4:10 p.m.)
12 CHAIRMAN BLEY: I think it's time to go.
13 Before you start, Marty, I see you have slides that 14 talk about Part 50 as well as Part 52.
15 And maybe you can talk a little -- I see 16 three things all bound together; the Part 50/52 17 nationalization, the rulemaking, the Part 53 18 rulemaking, this work on the standard and guidance, 19 whether it's separate or together on how you use 20 these. I see some difference likely if we do small 21 risk-informed applications using the standard or if we 22 use an LMP application using this standard.
23 So, if you can touch on those during your 24 talk, I'd appreciate it. Marty doesn't have a lot of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 slide and neither does Donna, I think, at the end.
1 So, there might be a lot more talk than there are 2
slides.
3 So, I think it's okay for you to go ahead, 4
Marty.
5 MR. STUTZKE: Very good.
6 Well, to reintroduce myself, I'm Marty 7
Stutzke, the senior technical advisor for PRA and NRR, 8
Division of Advanced Reactors and Non-Power Production 9
and Utilization Facilities, or DANU. That last phrase 10 means we also deal with research and test reactors.
11 Slide 19, Donna. So, I've tried to put 12 together a graphic here that indicates the scope of 13 the staff's endorsement.
14 The boxes in yellow are the Part 52 15 pathway, and the blue boxes are the Part 50 pathway, 16 and I provided the references to the various 17 regulations.
18 But, in essence, you have three ways to 19 get into the combined license from a design 20 certification, the standard design approval and 21 manufacturing license.
22 And the regulation says if you have a COL 23 that is based on one of those, then you must use an 24 update, for example, the design certification PRA, but 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 it's also possible to submit a so-called custom COL 1
that is not based on a design cert standard design 2
approval and manufacturing license.
3 So, we're sensitive to that to try to 4
understand what the difference is as far as PRA 5
acceptability.
6 Going a little bit further, there's the 7
fuel load PRA. And then finally a requirement for 8
updating, to be precise, maintaining and upgrading PRA 9
during operations. In the green box, you'll see LMP 10 fits into this process as well.
11 I should point out, you know, I want to 12 remind you there are various uses of the PRA during 13 the initial licensing phase.
14 For example, the identification of severe 15 accident vulnerabilities, demonstration that you make 16 the safety goal policy statement.
17 Occasionally, the PRA has been used to 18 inform reliability assurance programs, the RAP. It's 19 been used to inform Regulatory Treatment of Nonsafety 20 Systems, or the RTNSS program.
21 It's been used to inform design acceptance 22 criteria, DACs, and of course it's been put into the 23 severe accident mitigation design alternatives, the 24 SAMDA, analyses.
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86 All of these things happen whether or not 1
LMP is being implemented. So, LMP is like another 2
risk-informed application that would come in on top of 3
it, which we of course need to address.
4 Then further down on my slide, the Part 50 5
pathway, what I want to indicate there is that our 6
working hypothesis is that a PRA done for a 7
construction permit would roughly equal the PRA done 8
for a combined license application.
9 And similarly, the hypothesis that an 10 operating license PRA is roughly equal to the fuel 11 load PRA. We intend to look at that in some detail 12 and obviously the level of detail for the plant design 13 is different like that.
14 Then I would also point out at the 15 combined license application
- stage, and the 16 construction permit stage, you actually have site 17 selection. And that changes some of the requirements 18 and standard or how they're implemented.
19 At the fuel load and the operating license 20 stage you have the ability to actually perform plant 21 walk-downs.
22 And during operations, you begin to 23 actually accrue operating experience, which affects 24 your estimates of component reliability, initiating 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 event frequencies, things like that.
1 CHAIRMAN BLEY: Marty?
2 MR. STUTZKE: Yes, Dennis.
3 CHAIRMAN BLEY: Two related things.
4 You don't talk about early site permits, 5
but I guess I can see that that really doesn't involve 6
getting into the design. So, that's probably outside 7
the scope of what we're talking about here.
8 You do have a box for standard design 9
cert. It's a little unclear to me, even reading the 10 regulations, how one gets from a standard design 11 application to a COL, to a combined license. It's 12 certainly more arduous than going from the design 13 cert.
14 Does that work out well?
15 MR. STUTZKE: I'll have to defer that not 16 being a licensing engineer for --
17 CHAIRMAN BLEY: Nobody's done it. I'd be 18 surprised if they do.
19 MR. STUTZKE: But that being said, we've 20 issued standard design approvals in a number of cases.
21 CHAIRMAN BLEY: For plants for which we 22 did a design cert, which did all the work.
23 MR. STUTZKE: Right. So, it's -- yeah, 24 it's hard to say. I'm just trying to cover the bases 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 to make certain I understand the inputs of various 1
phases.
2 As I had indicated before, and Karl had 3
talked about, let's be explicit. For the LWR PRA 4
standard when you read it, it appears that all 5
requirements appear all -- or need to be met all the 6
time. And that's because that standard evolved from 7
the current operating fleet.
8 When we begin to look at design 9
certifications for light-water reactors, we realize 10 that doesn't work.
11 There are certain requirements that cannot 12 be applied or cannot be met due to the lack of 13 operating experience, for example, due to the lack of 14 site selection, this sort of thing.
15 And to that end, the staff developed 16 interim staff guidance 28 that said, okay, we will 17 grant you relief at this stage of the licensing cycle 18 accordingly.
19 To a large extent, the non-light-water 20 reactor PRA standard has addressed that. You will 21 find the caveats, conditional phrases, in many, many 22 of the requirements that says: During the pre-23 operational stage, do this, or prior to site 24 selection, do that.
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89 Okay. So, the requirements are very clear 1
and, as I had discussed before, we will come up with 2
an explicit list of every supporting requirement and 3
how it applies, or does not apply, to each one of 4
these stages, whether it's design certification, 5
combined license or construction permit, so forth and 6
so on, but try to make all of that clear like that.
7 MEMBER DIMITRIJEVIC: Marty, this is Vesna 8
Dimitrijevic. I have a question about -- we have many 9
discussions in the committee about this. It's about 10 the -- that because we have the COL which is not 11 anymore licensing, you know. So, when it comes to the 12 fuel load and operation, whatever PRA is developed in 13 that phase may have -- there is not any requirement 14 for that PRA to be reviewed by the NRC.
15 MR. STUTZKE: That is --
16 MEMBER DIMITRIJEVIC: And it was used 17 before is not tracking those -- there's no requirement 18 to track it in those phases.
19 MR. STUTZKE: That's correct. They are 20 required to have it and we can come onsite and inspect 21 it if we so choose to do so.
22 MEMBER DIMITRIJEVIC: So, the conclusions 23 which are made previously, if they change because of 24 the, you know, completing the PRA and adding those 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 things that they will -- it may happen that they never 1
confirm.
2 MR. STUTZKE: Yes, it is a concern. And 3
I imagine that once we get a fuel load PRA, we'll be 4
onsite to have a good look. I mean, it is an oddity 5
and --
6 MEMBER DIMITRIJEVIC: I'm just not sure I 7
-- that is not -- the only requirement is they apply 8
for some risk-informed application in that time, 9
right?
10 MR. STUTZKE: That's correct.
11 MEMBER DIMITRIJEVIC: But if they choose 12 not to apply, but they already have exemptions from, 13 you know, general design criteria or whatever base on 14 the PRA and then things are never confirmed later in 15 the -- you know. And that is requirement to confirm 16 PRA assessment. It would be very nice -- maybe this 17 Reg Guide is a, you know, a good place to define how 18 does NRC follow PRA to the last phase.
19 MR. STUTZKE: Okay. I've made a note to 20 that effect. Thanks. I think it's a good 21 observation.
22 CHAIRMAN BLEY: There's something related 23 to this, Marty, and I don't know if you're aware of.
24 Back when DAC were prevalent, we argued to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 Commission that the Committee -- well, two things:
1 that inspection shouldn't be enough; there ought to be 2
a pretty thorough review by the staff. And we got 3
commitments that there would be.
4 We also suggested that we should be 5
involved because it hasn't been done before, and 6
there's an SRM that directs the staff to involve us at 7
least in the first couple of days.
8 I can see the -- looking at the PRAs it's 9
fitting within that area and we might go to the 10 Commission at some point and reiterate that because 11 it's been ten years or so since that SRM and nothing's 12 reached that stage yet.
13 So, go ahead, but that's still something 14
-- this is an untested area. And even from the 15 statements of consideration of Part 52 from the 16 Commission, there was a fairly strong statement that 17 until we get some experience, there might be special 18 conditions that apply. Go ahead.
19 MR. STUTZKE: Well, you know, to follow up 20 on that and one thing that I've been interested in, is 21 you'll see that upper box, Operations 5071 H-2, 22 requires COL applicant -- or COL holders to maintain 23 and upgrade their PRAs throughout the life of the 24 plant.
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92 And the question is, how would we know?
1 And the answer is, well, they have to periodically 2
submit updates to the FSAR and so we could look at 3
that. But, you know, I've been considering it's like 4
what would we do with that type of information? So, 5
it's on my list of issues to be resolved here.
6 CHAIRMAN BLEY: If we get to a point, and 7
I don't think we're there yet, when you folks have 8
thought this through pretty well, you know, that might 9
be an appropriate point for a letter from the 10 Committee to the Commission talking about some of 11 these key issues and talking about how they get 12 resolved in the future. Keep that in mind.
13 MR. STUTZKE: Yeah, I certainly will.
14 Donna, let's move to slide 20, please.
15 Mine updated. Does everybody see slide 20? Well, 16 probably good enough.
17 Okay. So, I just wanted to provide here 18 some notes on the Part 50 pathway. There is no 19 current regulation that requires Part 50 construction 20 permits or operating license applicants to have a PRA.
21 However, you can go back to the 1985 22 severe accident policy statement and the Commission's 23 expectation that a PRA will be completed for all new 24 plants to identify severe accident vulnerabilities.
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93 This one is interesting. It was issued 1
four years before Part 52 actually existed. So, it's 2
clear to me that they intended to apply it to Part 50 3
plants.
4 Further on, the safety goal policy 5
statement -- well, the reactor advanced -- or the 6
advanced reactor policy statement provides the 7
expectation that plants will comply with the safety 8
goal policy statement.
9 And that is -- there's been several 10 revisions to the advanced reactor statement -- policy 11 statement.
12 I'd also point out that the safety goal 13 policy statement was issued before Part 52 by about 14 three years. And as part of our lessons learned, you 15 know, there is an ongoing rulemaking to align Parts 50 16 and 52 that will include PRA requirements for Part 50 17 CPs and operating licenses.
18 I'm not totally familiar with the time 19 frame at which that alignment will happen. Our 20 strategy is we better be prepared. We can anticipate 21 getting some non-LWR Part 50 applications in the 22 future sooner rather than later. So, we just want to 23 be prepared to be able to deal with that.
24 Okay. Next slide, please, Donna. So, No.
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94
- 21. So, we have been compiling a list of -- well, 1
we'll call them "considerations," but I don't want to 2
call them "issues," per se, but things that we need to 3
think about while we are in the process of endorsing 4
the standard and providing regulatory guidance on PRA 5
acceptability.
6 And it's just presented here as a list of 7
items, but let me go into some detail on these.
8 Supporting requirements for internal and external 9
hazards during shutdown and low-power operations.
10 When you actually read the non-LWR PRA 11 standard, it's similar to the LWR standard, the Level 12 1/LERF standard. And you come to fire and it says:
13 This only applies to the at-power plant operating 14 state.
15 And that has given a number of the staff 16 some considerable headaches and discussion about what 17 do we do.
18 In fact, when you go to the APR1400, there 19 was some treatment of low-power shutdown fires like 20 this.
21 I have approached the folks in Research to 22 see are there technical -- what technically needs to 23 happen in order for somebody to be able to perform a 24 fire analysis for the low-power shutdown operating 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 states?
1 So, it's a bit of concern. I mean, my 2
naval experience when we were in dry dock in the 3
shipyard says there's a lot of fires when the plant is 4
shut down and it's something that we need to look at.
5 CHAIRMAN BLEY: And there's a lot of 6
temporary fire sources. I missed that in the standard.
7 I assume the staff submitted some comments 8
in that area and maybe you didn't get what you wanted?
9 MR. STUTZKE: Well, there's that and then 10 there's -- as Anders pointed out, it's what we thought 11 we could address in our regulatory guidance.
12 CHAIRMAN BLEY: Okay.
13 MR. STUTZKE: So, in other words, we could 14 just say, okay, we disagree with that -- you know, 15 we're going to make a clarification or qualification 16 to the standard and say, oh, we expect you to do low-17 power shutdown fires.
18 CHAIRMAN BLEY: Exactly. And, you know, 19 from our discussion with Karl a minute ago, and also 20 you and Karl a year ago, there are a number of things 21 that are kind of on the boundary that maybe are 22 outside the scope of the standard, but the staff needs 23 to kind of pick up the exceptions on the boundary and 24 pull them into your guidance.
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96 MR. STUTZKE: Yeah, exactly. Like, for 1
example, the treatment of co-located plants, you know, 2
construction risks.
3 So, you're operating one module and you're 4
building additional modules and how should that be 5
considered. So, yeah, I've added it to my list and 6
we'll go from there.
7 A second point here is the use of seismic 8
margins analysis versus the use of seismic PRA. If 9
you go
- back, the Commission issued a
staff 10 requirements memorandum, SECY 93-087, that approved 11 the use of PRA by seismic margins analysis.
12 And they even specified that the review 13 level earthquake should be 1.67 times the safe 14 shutdown earthquake, which we now understand to be the 15 certified seismic design response spectra.
16 When you go to the non-LWR PRA standard, 17 there isn't a section on how to do a seismic margins 18 PRA. That is different than the Level 1 plus LERF 19 standard for the light-water reactors.
20 Instead, what the non-LWR PRA standard 21 directs you to do is, prior to site selection, pick a 22 bounding site and justify it and do, in fact, a 23 seismic PRA on that bounding site.
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97 would revise that PRA using the actual site-specific 1
seismic hazard curve like this.
2 CHAIRMAN BLEY: Marty?
3 MR. STUTZKE: Yes, Dennis.
4 CHAIRMAN BLEY: My reading of Part 52 and 5
our discussions with various members of the staff on 6
Part 52 and going to a pre-fuel load PRA, is that at 7
that point one needs a seismic PRA, not a margin 8
study.
9 Am I wrong in that?
10 MR. STUTZKE: No, that is correct for the 11 light-water reactors.
12 CHAIRMAN BLEY: Okay.
13 MR. STUTZKE: What we're considering now 14 is upon submittal -- or the COL PRA would actually be 15 a site-specific seismic hazard PRA.
16 CHAIRMAN BLEY: Okay.
17 MR. STUTZKE: So, that would accelerate 18 what we're doing in the light-water reactor world. I 19 mean, see, part of the problem that you have, in 20 general, with seismic margins analysis is that they 21 use risk surrogates like core damage frequency and 22 LERF, right? You work with that model.
23 None of those risk surrogates are defined 24 in the non-LWR PRA standard.
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98 CHAIRMAN BLEY: On purpose, because they 1
don't apply to all designs, yeah.
2 MR. STUTZKE: Exactly. So, now you have 3
the problem if you were to contemplate doing a seismic 4
margins analysis, what's the appropriate figure of 5
merit, you know? How would you begin? So, you've got 6
that issue to deal with.
7 So, I tend to agree, you know, I favor 8
this idea of picking a bounding site and doing a 9
seismic PRA and, you know, you'll get a lot of 10 fragility information, things like that.
11 You'll get your model set up. So, in 12 principle, it's it should be relatively 13 straightforward to replace it with site-specific 14 hazard.
15 The problem is how to define the bounding 16 site and justify it. And that's not addressed in the 17 standard and it may be something that we need to 18 address in our guidance.
19 CHAIRMAN BLEY: Uh-huh.
20 MR. STUTZKE: Case in point is it would be 21 easy for a designer to go and look at the responses to 22 an interim task force recommendation 2.1, the 23 Fukushima work, because everybody was required to 24 redefine or reassess their seismic hazard using the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 latest information and models.
1 So, it would be easy for a designer to go 2
and say, okay, I'm going to pick my bounding site by 3
considering that set of publicly available 4
information.
5 And a little bit further, you know, to 6
think down the road it's like, okay, I'm going to 7
pick, for example, Diablo Canyon.
8 Then you want to situate your advanced 9
non-LWR in Alaska and lo and behold you find out you 10 haven't bounded the seismic hazard.
11 The Alaska seismic hazard is larger, in 12 general, than it is in California.
13 CHAIRMAN BLEY: Right.
14 MR. STUTZKE: So, what to do about that?
15 Well, then you, you know, the point I'm trying to make 16 is you need to be careful in trying to pick what the 17 bounding site is with that.
18 And at the same time, you could end up 19 having a bounding site and you need to do it not only 20 for the seismic PRA, you need to do it for the 21 external floods, for the high wind analysis and so 22 forth.
23 And the problem then is you end up with a 24 bounding site that is not physically realistic. It 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 would have the worst earthquake hazard, the worst 1
hurricane hazard, the worst tornado hazard, so forth 2
and so on.
3 So, it's something that we're going to 4
need to be able to address and that's the essence of 5
that note there.
6 On Item No. 3, acronyms and definitions, 7
the issue there is trying to maintain consistent with 8
the -- consistency with the other PRA standards and 9
previous staff endorsements in our guidance.
10 I don't believe Anders or Michelle 11 mentioned the fact we have a contractor currently 12 building us a database of all of the different 13 requirements and all the different standards, what we 14 said about it when we endorsed it and previous 15 versions of Reg Guide 1.200 and ISG 28.
16 And the idea is to try and link all that 17 together and put it on one screen so we can begin to 18 easily assess the consistency issues.
19 CHAIRMAN BLEY: How is that work coming 20 along? Do you expect results soon?
21 MR. STUTZKE: I think it will be a couple 22 of more months. We got hung up around copyright 23 issues with ASME.
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101 to seeing that when you get it.
1 MR. STUTZKE: Yeah. I've tried to do it 2
offline, you know, myself. It's an enormous effort.
3 Especially if you're looking for whether or not 4
there's a comma there, these sorts of things.
5 Okay. Item No. 4 there, the endorsement 6
of the non-mandatory appendices. Karl had pointed 7
these out. There's 54 in the standard and they 8
basically fall into three groups.
9 There are notes that inform the various 10 supporting requirements. And one of the nice things 11 they did when they wrote the standard is these are all 12 hyperlinked in the document.
13 So, you can flip back from a supporting 14 requirement and read the note rather than thumbing 15 through 50 pages to find the note. It's very handy.
16 The second category of non-mandatory 17 appendices are what I'll call "commentaries." In 18 general, it's commentary on the state of practice to 19 try to orient the reader and the user of the standard 20 on what's been done, provides references, things like 21 this. Then the third category of non-mandatory 22 appendices I categorize as, like, guidance or details.
23 So, anyway, we're in the process of 24 deciding which of those non-mandatory appendices we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 need to endorse, which ones we -- and then we don't 1
need to endorse it like that.
2 Okay. Item No. 5. Risk-significant 3
measures, including the reporting of absolute risk 4
significance and relative risk significance.
5 As you know, in the light-water reactor 6
world, risk significance is determined by relative 7
measures. For example, pressure vessel importance and 8
risk achievement scores, both of those are relative to 9
the baseline risk of whatever it is that you're 10 assessing like this.
11 The non-LWR PRA standard allows the use of 12 relevant risk significance measures, but it also 13 allows one to use absolute risk significant measures 14 and it defines what those are.
15 So, that is, in fact, consistent with a 16 letter that the ACRS wrote after the 616th meeting.
17 It was back in July of 2014 where the advice to the 18 staff was we should reevaluate criteria used to 19 determine risk significance in a manner that's 20 consistent with a broad spectrum of designs and 21 absolute measures of overall risk.
22 So, in fact, that's what the standard has 23 done and we will consider that when we go off to 24 endorse it.
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103 That being said, the relationship between 1
relative risk significance and absolute risk 2
significance is not always direct as one would expect.
3 It's possible for something to be not 4
absolutely risk significant, but it will be relative 5
risk significant. And vice versa, it's possible 6
depending on how close the absolute -- or the risk is 7
to any risk target.
8 So, I've been trying to understand this 9
from the mathematical perspective and it's a little 10 perplexing right now.
11 CHAIRMAN BLEY: Marty?
12 MR. STUTZKE: Yes, Dennis.
13 CHAIRMAN BLEY: I was slow in taking 14 notes. I liked your organization of the three kinds 15 of non-mandatory appendices.
16 What were the names you used again?
17 MR. STUTZKE: Okay. The notes that inform 18 the supporting requirements, those are the hyperlinks 19 in the document.
20 CHAIRMAN BLEY: Right.
21 MR. STUTZKE: Commentaries on the state of 22 practice. And the third category is guidance and 23 details --
24 CHAIRMAN BLEY: Thank you.
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104 MR. STUTZKE: -- on various technical 1
elements.
2 CHAIRMAN BLEY: Continue.
3 MR. STUTZKE: Surely. So, okay. So, 4
enough on risk significance.
5 The reason why it's important is that the 6
standard requires that you define how you're going to 7
define "risk significance" early on while you're 8
developing the PRA because the supporting requirements 9
then key off.
10 In other words, you'll have a supporting 11 requirement that will say for the risk significant 12 items do X, Y and Z.
13 And so, it's important you understand up 14 front how you're defining "risk significance," so you 15 can actually meet the requirement.
16 If you were to change the definition of 17 "risk significance" midway in the PRA, you've 18 introduced a discontinuity there. It doesn't work.
19 So, you pick a definition and you need to 20 stay with it during the analysis.
21 MEMBER DIMITRIJEVIC: But you also need --
22 Marty, this is Vesna again.
23 You also need to define the risk measure 24 you're going to use for this because in order to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 define the significance, you have to go towards the, 1
you know, what risk measure -- you're not looking 2
anymore at core damage and LERF and everything was 3
this simple. You have to look in some of these 4
categories. I mean, you have to define what's your 5
risk measure.
6 MR. STUTZKE: Absolutely. And, you know, 7
we will require at least risk measures consistent with 8
the quantitative health objectives in the safety goal 9
policy.
10 So, specifically individual early fatality 11 risks and individual latent cancer fatality risks.
12 And you would have to do risk significance using both 13 of those.
14 In addition, if you're in the LMP, there 15 is a third category which is -- I remember it as the 16 frequency of sequences that cause the offsite dose or 17 the dose at the exclusionary boundary to exceed a 18 certain value. Karl will know exactly what that is, 19 but, in other words, you can have a third in there.
20 In addition to the LMP, the LMP target 21 curve itself now when it comes to definition that you 22 can apply relative -- or absolute risk significance 23 to.
24 Yeah, it's extremely important to define 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 what those --
1 MEMBER DIMITRIJEVIC: Yeah, it becomes 2
extremely complicated because now you have to have all 3
-- you have to know all results to the end in order to 4
determine what's significant.
5 MR. STUTZKE: Yeah. What I'm personally 6
concerned is, you know, the computers have a marvelous 7
ability to pump out tables and tables of numbers.
8 And it's like -- it's the interpretation 9
of that output, I think, will be difficult for 10 applicants, as well as for the staff.
11 As you say, you need to find the --
12 consider it all together and I think it will be 13 challenging to begin one.
14 CHAIRMAN BLEY: Marty?
15 MR. STUTZKE: Yes, Dennis.
16 CHAIRMAN BLEY: This is the -- a really 17 key list you're going through and I'm wondering if 18 you're expecting, on some of these issues, you're 19 going to want to write SECYs to the Commission looking 20 for their guidance.
21 Have you thought about that?
22 MR. STUTZKE: Yes. Yes, I have.
23 CHAIRMAN BLEY: I suppose I'd say when you 24 get to that point, I think it would be helpful if you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 brought those through the Committee and let us make 1
comment on them as well.
2 MR. STUTZKE: Absolutely.
3 To make a small joke, I like the idea of 4
defense-in-depth and the Committee --
5 CHAIRMAN BLEY: That's a very small joke.
6 MR. STUTZKE: Yeah. The Committee's advice, 7
you know, and the recommendation is extremely valuable 8
to us.
9 Okay. Donna, let's move to slide No. 22.
10 We need to speed it up a little bit here. The notion 11 of peer review, as you remember, in the light-water 12 reactor world, we do not require peer reviews to be 13 conducted for design certifications or combined 14 license applications.
15 We expect to change that consistent with 16 the standard that requires appropriate peer reviews at 17 all stages of the licensing process, you know, design 18 cert, combined license, fuel load, so forth and so on.
19 Those don't necessarily have to be full 20 scope peer reviews. They could be focus scope to look 21 on the new requirements that have come into play or 22 things that have been changed.
23 One of the issues that we've identified 24 here is the need to reassess or relook at the high 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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108 level of requirements and supporting requirements as 1
the design on the PRA evolves.
2 In other words, just because a requirement 3
was met by a previous peer review doesn't necessarily 4
mean that it's met at subsequent peer reviews.
5 CHAIRMAN BLEY: Yeah, Karl talked about 6
that a bit in a different way, but that --
7 MR. STUTZKE: Yes. He said it's a new PRA 8
and I don't know that I would agree. But, yeah, 9
that's the issue.
10 CHAIRMAN BLEY: Have you tossed around the 11 thought that the whole industry has a different level 12 of expertise in some of the novel designs that may be 13 coming up?
14 And if that changes how the staff 15 considers these peer reviews, you're going to have to 16 get into them more deeply than you have for LWRs?
17 MR. STUTZKE: Yes, we will.
18 We're not going to -- how do I say this?
19 We believe doing a peer review is a really good thing 20 because it helps, you know, reduce the burden on the 21 staff.
22 It lets us focus on other aspects of the 23 design, but we don't believe that the peer review 24 will, you know, eliminate our need to go and do some 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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109 review ourselves, PRA, audits and stuff.
1 So, we're not going to, you know, just 2
say, well, because it's a peer review we accept it and 3
we're done.
4 But, you know, that being said, when you 5
actually go through all the licensing steps here, it's 6
a lot of peer review and you need to find qualified 7
peer reviewers that don't have conflicts of interest 8
and things like that. I think it will be a challenge.
9 And, also, as Michelle had mentioned 10 earlier, we have received draft guidance from NEI, NEI 11 20-09, that talks about their peer review which 12 amplifies the guidance in the standard and we have 13 submitted comments. There's a public meeting in 14 December to talk about that.
15 Okay. Item No. 7 has to do with 16 supporting requirement capability categories. And to 17 orient you a little bit, the capability category has 18 to do with the scope and level of detail that's in the 19 PRA, the plant specificity and a nebulous quantity 20 called "realism" in the PRA, but the general idea is 21 Capability Category 2 should be more detailed, more 22 plant-specific, more realistic than Capability 23 Category 1.
24 Now, the challenge is Interim Staff 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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110 Guidance 28, which applies to design certs and 1
combined licenses for light-water reactors, that says 2
Capability Category 1 is adequate.
3 And it's adequate in the sense to meet the 4
uses of the PRA that I had talked about a couple of 5
minutes ago, the identification of severe accident 6
vulnerabilities, demonstrating compliance with the 7
Commission's Safety Goal Policy Statement, so forth 8
and so on like that.
9 But that being said, at the 616th ACRS 10 meeting a letter was issued in July of 2014 that urged 11 the staff to adopt Capability Category 2 for design 12 certs and combined licenses. And I would also observe 13 Reg Guide 1.174 generally expects Capability Category 14 2 for any risk-informed application.
15 So, we have this problem of -- or this 16 issue of the legacy of light-water reactor design 17 certifications at Cap 1 versus the desire to go to Cap 18 2.
19 Obviously, for LMP implementation you 20 would be at Capability Category 2, but I did a little 21 digging into the standard. There's only about 20 22 percent of all the supporting requirements make a 23 distinction between Capability Category 1 and 2. 80 24 percent of them, the requirement applies across all 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 capability categories.
1 So, we're talking about very few things 2
that actually differentiate -- well, as far as raw 3
numbers, I mean, that could really be significant like 4
this. So, anyway, it's on the list there.
5 CHAIRMAN BLEY: Okay. I think Karl wanted 6
to make a comment. Go ahead, Karl.
7 MR. FLEMING: Well, yeah. I just wanted 8
to fill in a
couple of items from Marty's 9
presentation.
10 One of them was, okay -- oh, on the 11 seismic margin, I think Marty captured some of the 12 reasons why we don't address seismic margins.
13 In principal, I think you could develop a 14 seismic margins method, but some research would need 15 to be done.
16 But one of the things that need to be 17 considered here for an LMP application, we're not just 18 looking at the applicability of beyond-design basis 19 events, we're looking at anticipated events and less 20 likely as well as beyond-design basis events.
21 In reference to a point that Vesna made, 22 the standard requires you to specify which risk 23 measures you're going to use for calculation of risk 24 significance either by absolute or relevant metrics.
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112 And of course that's -- that's also broken 1
down into what different consequence measures that 2
your PRA application will require, site bound, re-3 dose, safety goal-type metrics and so forth.
4 Another -- Marty indicated there was a 5
third risk criteria out of LMP. The two safety goal 6
QHOs were two of them.
7 The other one had to do with maintaining 8
the requirements in 10 CFR 20, which is to maintain 9
the frequency of 100 millirem doses to be less than 10 once per year to be in compliance with 10 CFR 20.
11 So, just a couple comments I wanted to 12 make there -- oh, one final one. The standard -- the 13 non-light-water reactor standard only excludes 14 internal fire at low-power shutdown.
15 All the other hazards are -- there's no 16 restrictions on other combinations of hazards in low-17 power shutdown.
18 CHAIRMAN BLEY: Thanks, Karl.
19 Go ahead, Marty.
20 MR. STUTZKE: Yeah. So, Item No. 8 here, 21 the question is, when would we commence --
22 MEMBER DIMITRIJEVIC: Can I say one thing 23 on capability category? Just my observation. That 24 was my concern in the previous part of presentation 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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113 because the Capability Category 1 was requested for 1
design certification.
2 When I look in this new standard, for 3
- example, I
was mostly concerned
- about, like, 4
uncertainty requirements. For Capability Category 1 5
uncertainty requirements usually say do the point 6
estimate and do some qualitative estimate of 7
uncertainty range.
8 So, what could happen if the conclusion is 9
the Capability Category 1 is enough for design 10 certification, then all submittals that have come so 11 fast can overdo the PRA. The requirements will be 12 significantly relaxed even if we come just from 20 13 percent of the high-level requirements.
14 So, and of course, the new plants cannot 15 meet Capability Category 2, in some cases, because of 16 the lack of plant-specific data procedures and things 17 like that.
18 So, thing is what I believe the best 19 solution at this moment -- I mean, it's a personal 20 opinion -- is just to go per requirement, per 21 requirement, and for them decide what capability 22 category would be acceptable.
23 Because just saying Capability Category 1, 24 then they can come with just very rough PRA in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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114 design certification phase based on the requirements.
1 MR. STUTZKE: Right. And we don't 2
necessarily agree that Capability Category 1 is going 3
to be adequate anymore for non-LWRs.
4 One thing I would point out is regardless 5
of what design stage you're in, whether it's design 6
cert, combined license, whatever, if you have one of 7
these, I call them Type 2 requirements that makes a 8
distinction between Capability Category 1 and 2, you 9
can always meet the Category 2 requirement.
10 What happens is that as the design stage 11 evolves and you move through it, a different 12 supporting requirement then will come into play and 13 the old one becomes set aside, for lack of a better 14 word.
15 So, it avoids the problem where you had in 16 ISG 28 that says, no, you can't meet Category 2 at 17 design cert. The standard is written so that that's, 18 in fact, possible, but we need to look at it.
19 CHAIRMAN BLEY: That's a nice improvement 20 here.
21 MR. STUTZKE: Well, it's clearer, you know.
22 The question is whether we agree with it now, but 23 that's what we're doing.
24 Okay. So, Item No. 9, quality assurance.
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115 I'll try to present it like this. We haven't reached 1
any decisions yet like this.
2 But if I go back to 10 CFR Part 50 3
Appendix B, and I'm reading the QA requirements and I 4
come to things like design control, and I find a 5
sentence in there that says, oh, design control 6
measures apply to reactor physics, stress, thermal 7
hydraulic and accident analyses. So, one could reach 8
the opinion, okay, then I have to apply Appendix B to 9
my PRA like this.
10 At the same time, I can come back to when 11 Reg Guide 1.174 was originally written back in 1998 12 and there's language in that regulatory guide that 13 says: The pertinent requirements for quality 14 assurance of Appendix B are met if you do the 15 following: Use qualified personnel, you have 16 document control procedures, including independent 17 review verification and checking, maintenance of 18 records and corrective action programs.
19 And the point I'm trying to make is that's 20 expressly laid out in Reg Guide 1.174 that former 21 committee ACRS approved, the Commission approved it, 22 so forth and so on.
23 Then if I look at the statement of 24 considerations that was issued in the 2007 rulemaking 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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116 on Part 52, what it says is the PRA itself is not Tier 1
1 or Tier 2 information.
2 The description of the PRA and its result 3
is, in fact, Tier 2, but not the PRA itself. We don't 4
require applicants to submit the PRA like this.
5 And based on that, ISG 28 says:
6 Therefore, the PRA is not subject to Appendix B 7
quality assurance.
8 So, what I would say is this is one of the 9
open issues and we will get in touch with the QA folks 10 here and probably OGC will get involved.
11 And, as Dennis had mentioned before, it 12 might require some Commission direction to resolve it 13 like that.
14 MEMBER KIRCHNER: Marty, this is Walt 15 Kirchner.
16 What's changed here, for me, my perception 17 of what's different now, is that if you go to what we 18 expect 10 CFR 53 to look like, then you're actually 19 making your -- how should I say it -- your licensing 20 case based on the PRA.
21 I don't want to say this -- my observation 22 now is that the PRA supplements the licensing case now 23 and a vehicle to demonstrate compliance with the 24 Commission's safety goals, but it's not the licensing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 basis.
1 And I may not be using the right clinical 2
terminology, but if we go forward and we use, like, a 3
frequency consequence curve as a basis for selecting 4
events and then classifying systems -- structure 5
systems and components, et cetera, et cetera, then it 6
becomes a much more integrated integral part of the 7
licensing basis.
8 Do you want to make any observation on 9
that on what that should entail in terms of quality 10 assurance?
11 MR. STUTZKE: Well, you have expressed the 12
-- you know, the crux of the issue here because, you 13 know, new plants would be designed even under Part 52 14 if they implement LMP, I mean, one of the intents of 15 LMP is licensing basis event selection and system 16 structure and component classification, which are some 17 very fundamental things to the safety case.
18 So, you know, and the issue is, well, 19 based on that, why isn't it being controlled under 20 Appendix B, quality assurance?
21 So, you know, I can't answer the question 22 definitively yes or no at this time other than to tell 23 you we're intensely aware of it.
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118 by certain external stakeholders to replace Appendix 1
B quality assurance with perhaps an international 2
standard like ISO 9000, things like that.
3 And so, I mean, let alone whether that 4
standard is adequate for the actual design of the 5
equipment, how does it treat the analysis or 6
specifically the PRA needs to be looked into.
7 MEMBER KIRCHNER: Well, where I'm coming 8
from, I guess, is NQA-1. Whether it's called Appendix 9
B or ANSI, ASME, NQA-1, to me is immaterial. I mean, 10 they're one in the same essentially in terms of how 11 they function and such.
12 I'm just coming -- I'm thinking -- what 13 I'm thinking about, I'm zeroing in on the design 14 control aspect and now you're making your design 15 decisions -- you're not informing them with PRA.
16 You're almost making your -- I'm repeating 17 myself -- your safety case based on the PRA and then 18 demonstrating, you know, once you procure and build, 19 et cetera, that you've got a plant that matches the 20 PRA that was used for the LMP or whatever 10 CFR 53 21 looks like.
22 So, I just think -- it seems to me it goes 23 a little bit beyond Reg Guide 1.174 requirements for 24 QA.
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119 MR. STUTZKE: Yeah.
1 MEMBER KIRCHNER:
Just one member's 2
opinion.
3 MR. STUTZKE: I appreciate, you know, the 4
comment and it's, as I said, I think this one will be 5
-- require some substantive effort on our part in 6
order to put it to bed one way or the other.
7 Okay. Last, but not least, is my tenth 8
point here. This notion that for micro reactors -- I 9
don't know how to say -- it almost begs the question 10 we know that the risk is small, so why do we have to 11 do a lot of PRA work like this?
12 And the issue here that I'm speaking to is 13 that when you look at the non-LWR PRA standard, it is 14 monolithic with respect to the supporting 15 requirements.
16 It doesn't care that your plant is small.
17 You still need to do all these requirements in order 18 to meet the standard like that.
19 So, the question arises, is there some way 20 that you can do less or right-size the PRA based on 21 your size of the reactor that you're trying to apply 22 it to like this.
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120 reactors.
1 DR. CORRADINI: But, Marty -- this is 2
Corradini.
3 MR. STUTZKE: Yes.
4 DR. CORRADINI: That's true, but for 5
research and test reactors you don't have a maximum 6
credible accident.
7 You have a maximum hypothetical accident 8
that's unphysical and then you develop a source term 9
from that to show that you're okay.
10 So, if a micro reactor takes that 11 approach, then that should be appropriate.
12 MR. STUTZKE: And that's, in fact, been 13 recommended by industry under the Part 53 rulemaking 14 effort.
15 DR. CORRADINI: Say that again, please.
16 I didn't appreciate what you just said.
17 MR. STUTZKE: Yeah. NEI has submitted a 18 comment on our Part 53 rulemaking plans. And one of 19 the things that they raised was the notion of use in 20 the maximum hypothetical accident for smaller reactors 21 that would be licensed under Part 53.
22 DR. CORRADINI: But it still requires the 23 staff to -- I'm trying to think of the right word here 24
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121 hypothetical. Is it hypothetical enough? How 1
bounding is it?
2 You're still looking for a bounding event 3
that simplifies all your subsequent analysis.
4 MR. STUTZKE: Yes. Yes.
5 DR. CORRADINI: Okay.
6 MR. STUTZKE: And it gets worse if you try 7
to define the, you know, maximum hypothetical accident 8
or maximum credible accident in terms of frequency.
9 I've read a lot of literature on that that 10 says, oh, you know, if the frequency is below ten to 11 the minus seven, it's not credible, that sort of 12 thing.
13 And, you know, my -- first of all, whether 14 that's an appropriate number to use is one thing.
15 Second of all, is you just talked yourself into doing 16 a PRA to convince me that's -- and you may not be in 17 the position to do that kind of in-depth PRA.
18 DR. CORRADINI: But I think, though, Walt 19
-- or, Marty, excuse me, if you look at the final 20 safety analysis report of research reactors, it's 21 assumed it's small enough that it's obvious, but it's 22 never quantified.
23 MR. STUTZKE: Okay.
24 DR. CORRADINI: I mean, this kind of makes 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 me want to go back and remind myself of -- because all 1
these FSARs for the research reactors are quite 2
available and they're relatively simple, but quite 3
hypothetical bounding events that are used to develop 4
the source term.
5 MR. STUTZKE: Right. And they bounded the 6
consequences. They did calculate consequences.
7 DR. CORRADINI: Correct. Correct. Yeah.
8 Because when we re-licensed our reactor here, that's 9
exactly what NRC required us to do.
10 And then they brought in a laboratory as 11 a reviewer. The staff brought in a laboratory 12 personnel as a reviewer for the associated consequence 13 analysis.
14 MR. STUTZKE: Yes. Yeah.
15 CHAIRMAN BLEY: Go ahead, Marty.
16 MR. STUTZKE: But, you know, anyway, 17 nevertheless if somebody comes in under Part 50 or 52, 18 they're going to be told, well, you have to do the 19 PRA.
20 DR. CORRADINI: Okay. Good point.
21 MR. STUTZKE: You may have bounded the 22 consequence, you know, and convinced us -- so, that's 23 what the issue here is. Can we grant any relief -- or 24 should we grant any relief.
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123 And with that, I am concluded unless there 1
are other questions. I see Karl's hand is up.
2 MR. FLEMING: The one thing I wanted to 3
emphasize here as far as the standard is concerned, 4
and this is true not only for the non-light-water 5
reactor standard, but also the light-water reactor 6
standard, there is nothing in the standard that says 7
that you have to apply all the requirements in the 8
standard.
9 It says that the user selects the scope of 10 the PRA for his or her application and what 11 requirements he wants to adhere to for his 12 application.
13 All this business about meeting Capability 14 Category 2 for this, that and the other, that's all 15 done external to the standard in regulatory guides and 16 things like that.
17 So, there's nothing in the standard that 18 says you have to meet all the requirements even for 19 the light-water reactor standard.
20 CHAIRMAN BLEY: I think that's true.
21 We'll look at this with whatever the staff comes up 22 with later on.
23 So, any other questions for Marty?
24 (Pause.)
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124 CHAIRMAN BLEY: I think, at this point, 1
we'll go back to Donna Williams and wrap this day up.
2 MS. WILLIAMS: Okay. Hi. I'm Donna 3
Williams, project manager in NRR and the project 4
manager for this project.
5 I'm going to cover briefly the staff's 6
plans for engaging the stakeholders in our schedule 7
for endorsement. And a lot of this has been covered 8
before. So, I can go through it fairly quickly.
9 So, the reviewers supporting this effort 10 are from both NRR and the Office of Research. The 11 applicable branch chiefs in each office are briefed on 12 a regular basis on the status of the project and are 13 intimately involved in a resolution of issues as they 14 arise.
15 Division management is also informed of 16 the status of the staff's review and the challenges 17 are identified by the staff.
18 And higher levels of management are 19 informed through routine reports of advanced reactor 20 infrastructure activities.
21 Because the guidance and advanced reactor 22 reviews and PRAs continue to evolve, we're aware of 23 the need to ensure their efforts are aligned with 24 other agency activities.
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125 As you mentioned earlier, the team has 1
reached out to staff that are involved in other 2
activities that may affect or may be impacted by the 3
positions that are developed on the non-LWR PRA 4
standard such as the Part 53 rulemaking, the 5
rulemaking to align Parts 50 and 52, and endorsement 6
of the latest revisions of the light-water reactor PRA 7
standard.
8 So, we need to be aware not only of the 9
decisions they're making, but also the schedule on 10 when they'll be issuing the documents. The staff has 11 also reached out early to ODC to discuss the various 12 processes that we're considering and the legal 13 implications of vendors referencing them in 14 applications.
15 Regarding external stakeholders, it's 16 important for the staff to have a continuing dialogue 17 with the applicants that plan to use the standard, as 18 well as members of the public, to ensure a better 19 understanding of NRC expectations for PRAs, and to 20 enable a more effective NRC review when applications 21 are submitted.
22 We made our project plan publicly 23 available and will update it as needed if our plans or 24 schedule changes.
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126 During the balloting process for the 1
standard, the staff met with the JCNRM Working Group 2
several times to get clarification on the intent of 3
the standard and to ensure understanding of the 4
staff's comments.
5 We are also exchanging information with 6
individual vendors who plan to submit applications for 7
advanced reactors in the near term to understand their 8
plans and schedules regarding use of the standard.
9 This will help us in identifying an 10 endorsement vehicle and schedule that best supports 11 these plans.
12 Finally, as Michelle mentioned, we're 13 holding public meetings every two or three months to 14 discuss the endorsement process with the broader 15 audience.
16 We use these opportunities to share issues 17 and positions the staff is considering and to seek 18 feedback from the stakeholders.
19 Some of the plan for endorsement, the 20 staff's plan for endorsement of the standard was 21 initially through the regulatory guide process.
22 The current schedule calls for issuance of 23 the draft Reg Guide at the end of 2021 with a public 24 comment period through March of 2022 and issuance of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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127 the final Reg Guide at the end of 2022.
1 As has been mentioned, the staff is 2
exploring other options that may be used in lieu of 3
the draft Reg Guide to communicate the staff position 4
and seek public comments on a similar schedule.
5 One option is a trial use Reg Guide. This 6
would allow the staff to obtain lessons learned from 7
a pilot project and provide for a longer comment 8
period that may align better with the schedule for 9
future updates to the standard. Another option would 10 be to issue interim staff guidance.
11 CHAIRMAN BLEY: Looking at your schedule 12 13 MS. WILLIAMS: Uh-huh.
14 CHAIRMAN BLEY: -- and looking at the 15 list of issues that Marty put forward that are going 16 to require a fair amount of staff research and 17 organization and, I expect, a few SECYs, it seems 18 hopeful.
19 MS. WILLIAMS: Yes. This schedule we do 20 not have, you know, issuance of SECY papers 21 specifically called out in a schedule.
22 And you're right. If we do require, you 23 know, Commission input or Commission decision, that 24 will delay things.
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128 CHAIRMAN BLEY: Okay. Are you locked into 1
this schedule or do you have flexibility if those 2
issues develop?
3 MS. WILLIAMS: I wouldn't say we're locked 4
in. Actually, this is an extension from the original 5
schedule that we issued, which was issuance of the 6
draft guidance, I think, in September of 2021.
7 So, we've already pushed it out a few 8
months, but we do -- so, my second bullet there talks 9
about, you know, be mindful of the potential 10 applicant's plans for submitting applications that 11 will reference the standard.
12 We're looking at other ways to get 13 information out earlier. So, if we do need to push 14 back getting a draft Reg Guide out or whatever 15 endorsement process, we plan to use other sort of 16 interim communication processes like, you know, a 17 White Paper or interim endorsement letter, that will 18 provide something written that doesn't have, you know, 19 the finality of a Reg Guide, but does communicate 20 staff positions and provides opportunity for, you 21 know, feedback from the applicants.
22 CHAIRMAN BLEY: Okay.
23 MS. WILLIAMS: Alright. So, this 24 concludes the staff presentations. We thank the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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129 subcommittee for the opportunity to present the status 1
of our review to you, and I'm happy to answer any 2
additional questions you have.
3 CHAIRMAN BLEY: Okay. At this point, I'll 4
ask the members if they have any questions. We'll 5
have a comment period for all the members after that.
6 Any questions from the staff? And while 7
we're doing that, if we can get the phone line open 8
for public comments, I'd appreciate it.
9 (Pause.)
10 CHAIRMAN BLEY: Do we know if the phone 11 line is open?
12 (Pause.)
13 CHAIRMAN BLEY: Derek? Makeeka? Somebody?
14 (Pause.)
15 CHAIRMAN BLEY: I take it that means it's 16 open.
17 PARTICIPANT: The public line is open.
18 CHAIRMAN BLEY: Okay. Thank you.
19 Is there anybody in the public who would 20 like to make a comment? If so, please state your name 21 and make your comment.
22 (Pause.)
23 CHAIRMAN BLEY: Hearing none, let's close 24 the public line and rather than ask everyone to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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130 comment, at least right now I think my opinion is that 1
we will not have a full committee meeting next month 2
or December -- I forget when we had it scheduled --
3 and we would not be writing a letter at this time.
4 If you have any comments for the members, 5
if anyone thinks we really need to write a letter at 6
this time, speak up when you make your comments. I'll 7
leave it open for a few minutes for anybody to 8
comment.
9 (Pause.)
10 CHAIRMAN BLEY: This may be a first.
11 Well, I'd like to thank the staff and Karl for these 12 presentations and the discussion.
13 I think they clarified a few of the things 14 from last time, but the toughest issues kind of remain 15 and we'll look forward to hearing from the staff on 16 how they plan to address them. And don't think those 17 really impact the standard itself, but they will 18 certainly impact the guidance that staff puts together 19 for the use of this standard.
20 So, hearing no comments from members, at 21 this time, we're adjourned. Thanks, everyone, for 22 being here.
23 (Whereupon, the above-entitled matter went 24 off the record at 5:16 p.m.)
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Status and Plans to Develop Regulatory Guide Supporting the Advanced non-LWR PRA Standard Michelle Gonzalez, RES Anders Gilbertson, RES Karl Fleming, JCNRM Martin Stutzke, NRR Donna Williams, NRR Briefing for the Advisory Committee on Reactors Safeguards Subcommittee on Futures Plant Designs November 2, 2020 1
Presentation Outline 1.
Update of Staff Endorsement of the ASME/ANS Advanced Non-LWR PRA Standard (Michelle Gonzalez) 2.
Staffs Review and Comments During Ballots (Anders Gilbertson) 3.
Resolution and Disposition of Ballot Comments and Future Activities (Karl Fleming) 4.
Scope of the Endorsement RG and Staff Position Issues to be Addressed in RG (Martin Stutzke) 5.
Internal/External Stakeholders Engagement and Plan for Issuance of RG (Donna Williams) 2
=
Background===
- The advanced non-light water reactor (ANLWR) PRA standard (ASME/ANS RA-S-1.4-2013) was issued in 2013 by ASME/ANS for trial use.
- The scope of the standard includes Level 1 PRA through Level 3 PRA, all hazards and all operating modes.
- The requirements in this standard cover PRAs performed during design, pre-operational, and post-operational phases.
3
Background (contd)
ACRS Subcommittee on Future Plant Designs - October 2, 2019
- Action plan for endorsement (ML20104C132)
- Possibility of endorsing the trial use standard Updates from last ACRS meeting
- Letter from JCNRM (ML20031D602)
- NRC response letter to JCNRM (ML20045G141)
- Updated action plan for endorsement
- Updated schedule
- Task reorganization
- JCNRM ballot of the ANLWR PRA Standard
- Initial ballot-May 2020
- Recirculation ballot-August, 2020
- Performance of PRA Peer Reviews Using the ASME/ANS Advanced Non-LWR PRA Standard (NEI-20-09) 4
Endorsement Plan
- Standard development support
- NRC staff member provides support to the standard development working group
- Initial review and ballot comments submitted on May 22, 2020
- Recirculation ballot review/comments submitted on August 20, 2020
- Unanimous consensus achieved following recirculation ballot
- Preparation for review and endorsement of the ANLWR PRA standard and NEIs peer review guidance (NEI-20-09)
- Staff is consulting with NRC management and OGC to select the best option 5
Preparation for Review and Endorsement of the ANLWR PRA Standard Determine the scope of regulatory activities for the ANLWR PRA standard - complete Identify the needed technical expertise to review the ANLWR PRA standard for endorsement - complete Detailed guidance for staff review of the ANLWR PRA standard for endorsement Comparison of the ANLWR PRA standard to other related LWR PRA standards and guidance (i.e., ISG-028)
Develop the staff position for an acceptable ANLWR PRA
- Early communication of staff views and perspectives Identify and resolve technical and policy issues 6
Scope of Regulatory Activities Staff endorsement will address acceptability of base PRAs for all licensing stages under Part 52 (DC, COL, fuel-load, and operations) and Part 50 (CP, OL) including license applications that implement the LMP guidance (NEI 18-04, Rev. 1 as endorsed in RG 1.233)
Staff endorsement will:
Include all technical elements of the standard and NEIs peer review guidance (NEI-20-09)
Provide clarifications and qualifications to address NRC recirculation ballot comments marked as deferable, which generally involve regulatory implementation issues 7
Ongoing Work
- Development of draft regulatory guidance
- Options: issue as trial use RG, a final RG, or ISG
- Engagement with external stakeholders (public, potential applicants) 8
Regulatory Guide Structure A. INTRODUCTION B. DISCUSSION
Background
Consideration of International Standards Documents Discussed in Staff Regulatory Guidance C. STAFF REGULATORY GUIDANCE An Acceptable Base PRA National Consensus Standards and Industry PRA Programs Demonstrating the Acceptability of a PRA Used to Support an Application Documentation to Support a Regulatory Decision D. IMPLEMENTATION APPENDIX A - NRC REGULATORY POSITION ON THE STANDARD APPENDIX B - PRA MAINTENANCE AND UPGRADE APPENDIX C - NEI 20-09 ENDORSEMENT 9
NRC Staff Preparations for and Participation in the JCNRM Consensus Balloting Process for the ANLWR PRA Standard Anders Gilbertson, RES 10
Staff Preparations for JCNRM Consensus Ballots
- Staff began familiarization themselves with the draft ANLWR PRA standard in September 2019
- Webinar on ANLWR PRA standard was held to help familiarize staff with JCNRM Working Group thinking and latest changes (1/8/20 - 1/9/20)
- Participated in JCNRM Readiness Review for the ANLWR PRA standard
- Orientation webinar for the first consideration ballot for ANLWR PRA standard (3/23/20) 11
Staff Participation in First Consideration Ballot
- First consideration ballot for the ANLWR PRA standard (3/24/20 - 5/26/20)
- JCNRM received over 1,300 comments in total
- NRC voted to approve; submitted 488 comments
- NRC comments represent a broad set of staff views and perspectives
- NRC comments identified several technical issues needing attention before standard was considered ready for publication and use
- JCNRM worked with commenters to resolve their issues and concerns and revised the ANLWR PRA standard for a re-ballot 12
Staff Participation in First Consideration Ballot
- Some key technical issues on the first consideration ballot needing attention
- The nature and application of screening criteria
- Treatment of screened contributors
- Issues related to certain definitions of terms
- Requirements related to uncertainty
- Addressing issues associated with related requirements/language in the LWR PRA standards
- How some requirements would map to different stages of the licensing process
- Use of the term de minimis 13
Recirculation Ballot
- Recirculation ballot for the ANLWR PRA standard (7/23/20 - 8/26/20)
- JCNRM received a total of 86 comments
- Ballot passed by with unanimous consensus
- NRC submitted 70 comments
- NRC comments included a mix of proposed technical changes and observations related to regulatory issues 14
Recirculation Ballot
- JCNRM resolution of comments from the recirculation ballot
- No additional technical changes were implemented; some editorial changes to be made
- Some comments deferred to the next revision of the ANLWR PRA standard
- Other comments are deferred to the pending resolution of the issue for the next edition of the ASME/ANS Level 1/LERF LWR PRA standard 15
Next Steps
- The NRC supports the JCNRM finishing the publication process and issuing the ANLWR PRA standard for use
- The staff are ready and able to endorse the ANLWR PRA standard, with clarifications and qualifications anticipated
- The staff continue to deliberate on some challenging regulatory issues, but are confident there should not be significant unforeseen issues associated with the endorsement of the ANLWR PRA standard requirements 16
Considerations for Staff Endorsement of the ANLWR PRA Standard
- A technically stable version of the ANLWR PRA standard is available now for the staff to start reviewing for endorsement
- The final published PRA standard will be the document officially endorsed
- The JCNRM anticipates initiating a revision of the ANLWR PRA standard shortly after the final publication of the first edition in order to:
- Align with LWR PRA standards on deferred issues
- Consider lessons learned from applying the PRA standard
- Potentially consider draft staff endorsement 17
Scope of the Endorsement RG and Staff position issues to be addressed in RG Marty Stutzke, NRR 18
Scope of the Staffs Endorsement COL 10 CFR 52.47(a)(46)
- DC: 10 CFR 52.47(d)(1)
- SDA: 10 CFR 52.47(c)(1)
- ML: 10 CFR 52.47(e)(1)
- Custom COL DC 10 CFR 52.47(a)(27)
Fuel Load 10 CFR 50.71(h)(1)
Operations 10 CFR 50.71(h)(2)
Operating License Part 50 (see notes)
Operations Construction Permit Part 50 (see notes)
LMP (NEI 18-04, Rev. 1)
CP PRA COL PRA OL PRA Fuel Load PRA Site Has Been Selected Ability to Perform Plant Walkdowns Operating Experience 19
PRA for Part 50 Applications There is no regulation that requires Part 50 CP and OL applicants to have a PRA. However:
- The Severe Accident Policy Statement [50 FR 32138; August 8, 1985]
provides the Commissions expectation that a PRA will be completed for all new plants to identify severe accident vulnerabilities.
- The Advanced Reactor Policy Statement [73 FR 60612; October 14, 2008] provides the Commissions expectation that new plants will comply with the Commissions Safety Goal Policy Statement [51 FR 28044; August 4, 1986, as corrected and republished at 51 FR 30028; August 21, 1986].
- The ongoing Part 50/52 alignment rulemaking [NRC-2009-0196; RIN-3150-AI66] will include PRA requirements for Part 50 CPs and OLs.
The staff anticipates receiving ANLWR Part 50 CP applications in the future.
20
21 PRA-Related Areas Under Consideration Staff to provide and confirm its position on the following areas prior to issuance of the final endorsement RG:
- 1. PRA standard supporting requirements for internal/external hazards during LPSD (fire, floods, winds, etc.)
- 2. Seismic margins analysis vs. seismic PRA
- 4. Endorsement of non-mandatory appendices
- 5. Risk-significance measures, reporting of absolute risk and relative risk
22 PRA-Related Areas Under Consideration (contd)
- 6. PRA peer review guidance and expectation including the need for peer reviews to reassess compliance with high-level requirements and supporting requirements as the design and PRA evolves
- 7. PRA capability category for applications
- 8. Commencement of PRA maintenance
- 9. Quality assurance requirements of 10 CFR Part 50, Appendix B
- 10. How to right-size the PRA effort for microreactors
- 11. Others?
Internal and External Stakeholder Engagement and Plan for Endorsement Donna Williams, NRR 23
Stakeholder Engagement
- Internal
- Briefings to management in NRR and RES
- Interactions with staff leads on activities related to advanced reactor PRAs
- Early engagement with OGC
- External
- Project Plan made publicly available
- Meetings with JCNRM to clarify staff comments
- Discussions with individual potential applicants
- Public meetings 24
Plan for Endorsement
- Planned endorsement schedule (if issuing draft/final RG is preferred)
- Draft Guidance - December 2021
- Public Comment - December 2021 through March 2022
- Final RG published - December 2022
- Staff is evaluating options for communicating staff positions in a more informal method at an earlier time frame such as a white paper, interim staff guidance, or interim endorsement letter 25
Acronyms ANLWR - advanced non-light water reactor ANS - American Nuclear Society ASME - American Society of Mechanical Engineers COL - combined license CP - construction permit DC - design certification ISG - interim staff guidance JCNRM - Joint Committee on Nuclear Risk Management LMP - licensing modernization project LPSD - low-power and shutdown LWR - light water reactor NEI - Nuclear Energy Institute NRC - Nuclear Regulatory Commission NRR - Office of Nuclear Reactor Regulation OGC - Office of the General Counsel OL - operating license RES - Office of Nuclear Regulatory Research RG - regulatory guide SC - subcommittee SP - staff position SR - supporting requirement SSC - structure, system, and component 26
Comment Resolution and Status ASME/ANS RA-S-1.4-2020 By:
Karl N. Fleming Chair JCNRM Non-LWR Writing Group KarlFleming@comcast.net Briefing for the Advisory Committee on Reactors Safeguards Subcommittee on Futures Plant Designs November 2, 2020
Disclaimer The information and material provided in this presentation was prepared by the ASME Joint Committee on Nuclear Risk Management and its Working Group on Non-Light Water Reactors.
It is for informational purposes only and are not intended to be construed as a formal commitment by ASME or ANS.
ACRS October 2019 2
Discussion Topics March 2020 Ballot Comment Resolution August 2020 Recirculation Ballot Comment Resolution ASME Board Comment Resolution Current Status JCNRM July 2020 3
Scope of Standard
Multiple plant operating and shutdown states
Event sequences developed to end states with mechanistic source terms and offsite radiological consequences
Technology inclusive end states and risk metrics
Frequencies of event sequences, event sequence families, and release categories
Mechanistic source terms, radiological doses, and health effects
Options for user defined end states (e.g sodium boiling)
Event sequences involving two or more reactors or radionuclide sources
Supports PRAs done at preoperational design stages
Supports PRAs performed for a range of sites
Requirements to address uncertainties in establishing passive system reliability
80% of technical requirements common to LWR PRA standards 4
ANS June 2020
Technical Elements with Integrated Treatment of Hazards 5
ANS June 2020
March Ballot Comment Summary
1,319 comments posted including 489 from NRC staff
Several meetings with NRC staff to facilitate their review
Resolution of comments resulted in significant improvements to technical quality of the Standard
Many comments were applicable to LWR source material that was mostly from the Next Edition
Common comments shared with LWR WGs
Most addressed using changes being made by LWR WGs to address their recent ballot comments
We documented our responses and reached out to all those submitting comments to obtain concurrence on resolution; comment resolutions posted on C&S Connnect
In very few cases the disposition involved disagreement JCNRM July 2020 6
Ballot Commenter Distribution JCNRM July 2020 7
Significant Changes to Prepare Recirculation Ballot 1 of 3
Changes to the screening criteria to put limits on the cumulative risk impacts of the items screened out.
SRs that included requirements for PRAs on both operating and pre-operational plants have been separated into different SRs resulting in some renumbering of the SRs from the balloted version.
The term de minimis has been removed and replaced by requirements for the reporting of small values of frequency and consequence. Some changes were made to address the confusion that was created between these reporting values and the screening criteria.
JCNRM July 2020 8
Significant Changes to Prepare Recirculation Ballot 2 of 3
Clarifications made to improve the interface in the requirements in Event Sequence (ES) Analysis and Mechanistic Source Terms (MST)
Analysis for the definition of release categories.
Requirements to define Release categories in Event Sequence Analysis (ES) as needed to define event sequence families and end states.
Additional requirements to refine release category definitions to support calculation of source terms is covered in Mechanistic Source Terms( MS) Analysis.
Requirements in all the hazards sections for use of the internal events PRA in developing plant response models modified to require the introduction of new initiating events that impact multiple reactors and sources of radioactive material that may not be present in the internal events PRA models.
JCNRM July 2020 9
Significant Changes to Prepare Recirculation Ballot 3 of 3
Revised definitions have been introduced to address terms such as safety function, bounding site, at-initiator human failure event, risk-significant plant operating state, and initiating event.
Changes to the definitions were made to achieve alignment with the latest versions in the Next Edition of LWR standard.
Some comments received were of a purely editorial nature. Resolution of these comments deferred to the technical editors who will format the document before publication.
JCNRM July 2020 10
Disposition of Recirculation Ballot Comments
86 comments posted on the recirculation ballot including 70 by NRC
NLWR WG reached out to all commenters and conducted webinar with the NRC staff to discuss comments and their resolution
All commenters agreed that none of the comments would require additional changes to support an approval to move forward with the standard
The recirculation ballot passed on a 31-0 vote to approve the publication of the standard, first unanimous approval of a JCNRM PRA standard JCNRM July 2020 11
Disposition of Recirculation Comments
14 comments were resolved during reach-out sessions and did not require any changes to the Standard
24 comments were classified as editorial to be fixed prior to publication
13 comments unique to the NLWR standard involve guidance are deferred to a future edition and do not impact requirements.
27 comments were not unique to the NLWR standard (i.e., they are shared by other JCNRM PRA Standards) and referred to to the LWR working groups for resolution
8 comments reflect NRC regulatory policies or positions and and were not technical issues requiring any changes to this international PRA standard.
Full consensus of the JCNRM commenters was reached on the resolutions JCNRM July 2020 12
Next Steps for this standard ASME Board requested that the JCNRM vote on the 24 editorial comments JCNRM approved the changes to correct the editorial comments at the September 2020 meeting.
60 day public review is ongoing and closes 12/15/20 ANS Board and ANSI reviews ongoing Expect publication in early 2021 JCNRM July 2020 13
Next Edition Considerations Finalize alignment with LWR standards Next Edition L1/LERF Standard ANSI versions of LPSD, L2, and L3 Standards Insights from NRC endorsement RG Stakeholder feedback from application of current ANLWR standard JCNRM July 2020 14
QUESTIONS?
JCNRM July 2020 15