ML21064A304
| ML21064A304 | |
| Person / Time | |
|---|---|
| Issue date: | 02/18/2021 |
| From: | Derek Widmayer Advisory Committee on Reactor Safeguards |
| To: | |
| Widmayer, D, ACRS | |
| References | |
| NRC-1399 | |
| Download: ML21064A304 (295) | |
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: Thursday, February 18, 2021 Work Order No.: NRC-1399 Pages 1-238 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 FUTURE PLANT DESIGNS SUBCOMMITTEE 8 + + + + +
9 THURSDAY 10 FEBRUARY 18, 2021 11 + + + + +
12 The Subcommittee met via Video-13 Teleconference, at 9:30 a.m. EST, Dennis Bley, 14 Chairman, presiding.
15 16 COMMITTEE MEMBERS:
17 DENNIS BLEY, Member 18 RONALD G. BALLINGER, Member 19 CHARLES H. BROWN, JR. Member 20 VESNA B. DIMITRIJEVIC, Member 21 WALTER L. KIRCHNER, Member 22 JOSE MARCH-LEUBA, Member 23 DAVID A. PETTI, Member 24 JOY L. REMPE, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 ACRS CONSULTANT:
2 MIKE CORRADINI 3
4 DESIGNATED FEDERAL OFFICIAL:
5 DEREK A. WIDMAYER 6 KENT HOWARD 7
8 ALSO PRESENT:
9 BOB BEALL, NMSS 10 CYRIL DRAFFIN, Public Participant 11 SCOTT MOORE, Executive Director, ACRS 12 WILLIAM RECKLEY, NRR 13 JOHN SEGALA, NRR 14 MARTIN STUTZKE, NRR 15 NANETTE VALLIERE, NRR 16 17 *Present via telephone 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 C-O-N-T-E-N-T-S 2 Opening Remarks, Staff Introduction . . . . . . . 4 3 Subcommittee Meeting Purpose and Objectives . . . 5 4 10 CFR Part 53 - Subpart C - Design and 5 Analysis Requirements . . . . . . . . . . . 7 6 Lunch 7 10 CFR Part 53 - Subpart C - Design and 8 Analysis Requirements (cont.) . . . . . . 120 9 10 CFR Part 53 - Subpart D -
10 Siting Requirements . . . . . . . . . . . 204 11 Adjourn . . . . . . . . . . . . . . . . . . . . 238 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P-R-O-C-E-E-D-I-N-G-S 2 (9:30 a.m.)
3 CHAIRMAN BLEY: Good morning, the meeting 4 will come to order. This is a meeting of the Advisory 5 Committee on Reactor Safeguards, Subcommittee for 6 Future Plant Designs.
7 I am Dennis Bley, Chairman of the 8 subcommittee. And ACRS Members in attendance, I'm 9 going to track them all down, Derek, maybe you can 10 help me as I go through it?
11 Joy Rempe, Ron Ballinger, Charlie Brown, 12 Walt Kirchner, Dave Petti, Vesna Dimitrijevic, Jose 13 March-Leuba, and our consultant Mike Corradini, I 14 think is with us, but I haven't seen him on there 15 among us.
16 Two of our members were not able to get 17 here, one because of all the miserable weather in 18 Texas. Derek Widmayer of the NRC staff is the 19 designated federal official to this meeting. And Kent 20 Howard of the ACRS staff is the backup designated 21 federal official. Charlie Brown is my backup in case 22 I get knocked off, and will take over chairing until 23 I can get back.
24 The purpose of today's meeting is to 25 discuss the primary rule language for 10 CFR Part 53 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 Licensing and Regulation of Advanced Nuclear Reactors, 2 Subpart C, Design and Analysis Requirements and 3 Subpart D, Siting Requirements. The subcommittee will 4 gather information as well as relevant issues and 5 facts and formulate proposed positions and actions as 6 appropriate.
7 The subcommittee meeting is the second of 8 several scheduled to discuss preliminary proposed rule 9 language for Part 53. The current plan is for all 10 these subcommittee meetings to be held before any 11 proposed rule language is presented to the ACRS full 12 committee.
13 However, at the subcommittee's discretion 14 any matters can be considered for presentation to the 15 full committee. The ACRS was established by statute 16 and is governed by the Federal Advisory Committee Act, 17 FACA. However, a committee can only speak through its 18 published letter reports.
19 We hold these meetings to gather 20 information and perform preparatory work that will 21 support our deliberations, our deliberations at a full 22 committee meeting. The rules for participation in all 23 ACRS meetings including today's, were already 24 announced in the Federal Register on June 13th, 2019.
25 The ACRS section of the U.S. NRC public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 website provides our charter, bylaws, agendas, letter 2 reports and transcripts of all full and subcommittee 3 meetings, including slides presented there. The 4 meeting notice and agenda for this meeting were also 5 posted there.
6 As stated in the Federal Register Notice, 7 and in the public meeting notice posted to the 8 website, members of the public that desire to provide 9 written or oral input to the subcommittee may do so.
10 You should contact the designated federal official, 11 five days prior to the meeting when it's practicable.
12 Today's meeting is open to public 13 attendance, and we have received no written statements 14 or requests to make an oral statement. We have also 15 set aside ten minutes in the agenda for spontaneous 16 comments from members of the public who are attending 17 or listening to our meetings.
18 Due to the COVID pandemic, today's meeting 19 is being held over Microsoft TEAMS for ACRS and NRC 20 staff attendees. There is also a telephone bridge 21 line allowing participation of public over the phone.
22 A transcript of today's meeting is being 23 kept. We therefore request that meeting participants 24 on the bridge line, identify themselves when they ask 25 to speak and to speak with sufficient clarity and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 volume so they can be readily heard.
2 At this time, I ask that attendees on 3 TEAMS and on the bridge line, keep their devices on 4 mute to minimize disruptions and any online 5 discussion.
6 We will now proceed with the meeting and 7 I'll call on John Segala, Chief of the Advanced 8 Reactor Policy Branch of NRR to make introductory 9 remarks. John, please go ahead.
10 MS. SEGALA: Thank you and good morning.
11 Consistent with the Nuclear Energy Innovation and 12 Modernization Act, we are developing 10 CFR Part 53 a 13 new alternative regulatory framework for Advanced 14 Reactors that embraces risk-informed approaches and 15 performance-based criteria that will be technology 16 inclusive to a wide range of new technologies.
17 In order to meet the Commissions directed, 18 schedule to publish the final Part 53 rule by October 19 of 2024, we are having extensive stakeholder 20 engagement to solicit feedback to better inform the 21 staff's proposals. And to ensure a shared 22 understanding of what will be included in the final 23 rule.
24 We are here today, in the second of many 25 ACRS meetings we will be having this year, to seek NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 ACRS feedback on NRC's development of Part 53 2 preliminary proposed rule language for Advanced 3 Reactors. We previously briefed the ACRS Subcommittee 4 meet in January on the first set of preliminary rule 5 language, Subparts B and F.
6 Today we will be seeking ACRS feedback on 7 the second set of preliminary rule language in Subpart 8 C, Design and Analysis Requirements. And Subpart D, 9 Siting Requirements. Since November, we have held 10 three public meetings with stakeholders and have 11 received a wide range of feedback, which the NRC staff 12 is still assessing. We plan to share some of the 13 stakeholder feedback with the ACRS today.
14 We are looking forward to hearing from the 15 ACRS today on this second set of preliminary rule 16 language for Part 53 and any insights and feedback 17 that you all may have. This completes my opening 18 remarks. Thanks.
19 CHAIRMAN BLEY: Thank you, John.
20 MR. CORRADINI: Hi, John, just can I ask 21 quick question?
22 CHAIRMAN BLEY: Sure, go ahead, Mike.
23 MR. CORRADINI: John, the industry 24 feedback seems to be, a quick read of it, seems to be 25 -- I'm trying to find a good word, but I'll just say, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 all over the map and not as positive as I suspect 2 you'd want from a brand new rule for Part 53.
3 What is the plan for the staff? Are you 4 going to answer the comments one by one? Or are you 5 going to kind of give some sort of discussion on broad 6 aspects of industry feedback?
7 MS. SEGALA: Well I think, you know, 8 because Part 53 is, you know, technology inclusive, 9 you know, we do have a broad range of stakeholders 10 that are interested in this new regulation. So, it's 11 not surprising that we're receiving, you know, a 12 spectrum of comments and feedback on the proposed 13 rule.
14 But what we've been doing is as we have 15 been engaging with stakeholders on a particular 16 subpart, we're trying to make sure that we hear from 17 all stakeholders on a particular subpart. And then 18 start looking at those, the feedback that we got and 19 propose changes to those subparts and then discuss 20 those at future stakeholder meetings to get feedback 21 on where we're going.
22 So I think that's the general approach 23 we're taking. I don't know if, Bob Beall or Bill 24 Reckley, or Nan Valliere want to add anything to that?
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10 1 John.
2 MEMBER BALLINGER: This is Ron Ballinger.
3 CHAIRMAN BLEY: Go ahead, Ron.
4 MEMBER BALLINGER: You know, I went 5 through and I've tried to more or less correlate the 6 comments in the NEI letter with the slides that you're 7 going to present today. And apart from not calling it 8 NEI comments, stakeholder comment, a lot of the 9 stakeholder comments that are in your slides seem to 10 be relevant or correlated with the NEI letter. So I'm 11 kind of looking forward to that discussion.
12 CHAIRMAN BLEY: Okay, thank you, Ron.
13 Before we go ahead, I had something too that I need to 14 bring up. In our last meeting, at least on my part 15 and I think some of the other members, there was a lot 16 of confusion about the two tiers that were introduced 17 in Part B.
18 And we kind of -- I know Bill told us they 19 were going to go back and think about that and get 20 back to us. And I've done some of that as well. And 21 I've talked to some of the lawyers who interceded and 22 were involved back when this concept first developed, 23 before it was used in the design certification 24 process, which is a little different.
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11 1 of needed under Part 50, and similarly under 52 it 2 would have been needed. When your regulation is 3 essentially rule-based, to be able to separate the 4 essential rules from the important but not quite as 5 essential rules.
6 It seems to me that Part 53 is moving 7 toward a risk-informed structure, and that those 8 concepts not only aren't needed, but don't quite make 9 sense, at least to me. So, if you'll keep that in 10 mind as you go ahead. And I hope you'll talk some 11 about this. So whoever is up, please go ahead.
12 MR. RECKLEY: Thank you, Dennis. This is 13 Bill Reckley, and we have a slide and I'll try to talk 14 to that point.
15 If we could go to Slide 2, the agenda. As 16 was just talked about, our primary desire today is to 17 talk about Subpart C, the Design and Analysis subpart.
18 And then this afternoon we get into Subpart D on the 19 Siting Requirements.
20 But before we get into those discussions, 21 we do have a bit of a summary of our past discussions 22 on Subpart B, which lays out the safety criteria. And 23 also the whole structure, and this will go to some 24 degree to Dennis's last point.
25 So, if we could just go ahead and go to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 Slide 3, this is --
2 MEMBER REMPE: Bill, this is Joy. I know 3 we mentioned this a long time ago, maybe before we 4 even had the meeting in January, the prior year or so.
5 But when you came to us and talked to us about the, 6 what your intent was. And one of the members, and 7 maybe it was Dennis asked, how do interact with the 8 folks that are doing the ongoing Part 50.52, alignment 9 and lessons learned rulemaking?
10 How do you, is there still interaction 11 with the group doing that? And how much are you guys 12 learning from each other? Could you mention that, 13 upfront here?
14 MEMBER REMPE: Hi, Joy. This is Bob Beall 15 in the rulemaking branch. Yes, I interact with my 16 counterpart, Jim O'Connell. He's, we're making PM for 17 the 50.52 lessons learned rulemaking.
18 And so Jim and I share a lot of 19 information and conversations, and about what he's 20 doing and what we're doing. So that we don't have any 21 -- I understand what he's trying to do. And if 22 there's anything I need to incorporate in Part 53 and 23 bring back to the Working Group.
24 And so we do have those interaction. And 25 like an example, we had some of the -- basically the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 questions you just asked, Jim shared that with me 2 earlier this week and I shared that with the Working 3 Group.
4 So that's an example how we're interacting 5 and ensuring that we're in some type of lockstep so 6 that we understand what each of the two different 7 rulemakings are doing.
8 MEMBER REMPE: Great, thank you.
9 MR. RECKLEY: Okay, I would just weigh in, 10 and Nan is following it at NRR as well, but so we're 11 trying to fully, as Bob said, stay aware of what each 12 other is doing. We're a little freer, since we're 13 building the rule from scratch, if you will.
14 And so, but I won't say we'll be totally 15 consistent with where they come out, but we're 16 coordinating the activities. But each activity has 17 different constraints, if you will, so.
18 MEMBER REMPE: So, that's an interesting 19 response back. But we're starting to get ready to 20 prepare for a meeting on this Part 50.52 thing. And 21 when I think about what I've seen there, versus here, 22 if I were to draw a diagram that shows the various 23 steps that the applicant had to follow and what the 24 inputs are -- like the SDA, or multiple SDAs, or do 25 they have to have a PRA, et cetera?
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14 1 And when do you have public interactions, 2 the review? Would the steps and the inputs, and the 3 outputs still be the same even though you might get 4 licensing-basis events differently?
5 Those kind of issues are something that 6 I'm just kind of wondering about.
7 MR. RECKLEY: They would probably be very 8 similar. And we get, we'll get to that. Keep in 9 mind, Part 52 is a licensing process rule. The 10 technical requirements and a different licensing 11 process is in 50. We plan, and I'll get into this in 12 a second. We plan in Subpart H to support either of 13 those approaches.
14 And so there, the similarities might be 15 more clear because those processes are laid out in 16 legislation, and in existing infrastructure for 17 licensing in 52 and 50, and the related requirements 18 in Part 2 and other places.
19 And so there, there probably will be a lot 20 of similarity and Nan, did you want to weigh in since 21 this is getting into the licensing arena primarily?
22 MS. VALLIERE: Yes, I think you're going 23 to see a lot of similarity, a high degree of 24 consistency in the licensing process area. So, as 25 Bill said, I don't expect that, you know, they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 going to take a lot of divergence from the existing 2 processes in that respect.
3 MEMBER REMPE: So, when we get to 4 discussing that part, or if we ever discuss that part, 5 I would really like to understand what not only the 6 similarities are, but where are the differences?
7 MS. VALLIERE: Okay, thank you.
8 MR. RECKLEY: We'll get to that in 9 probably, May or June, so.
10 MEMBER REMPE: Looking forward to it.
11 MR. RECKLEY: So this is the graphic 12 reviews really from the start of this activity ever 13 since, as John mentioned, NEIMA directed us to do this 14 rulemaking. We started giving thought to what it 15 might look like, and really I've been using this same 16 basic slide since then, well over a year ago.
17 And we'll go through a little more detail, 18 than we went through in a public meeting a couple 19 weeks ago that some thought was more helpful than this 20 slide. But just at the highest level, Subpart B that 21 we talked about with this Subcommittee back in 22 January, is intended to layout the basic criteria, the 23 objectives of the overall rule.
24 And then the subparts follow an approach 25 that reflects the life-cycle of the facility and how NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 those different aspects of the life-cycle need to 2 address or support meeting the safety functions that 3 are defined in Subpart B. And so Design and Analysis, 4 that we'll be talking about today, as well as Siting 5 we'll talk about this afternoon.
6 Then Subpart E would be Construction.
7 We're getting ready to release the preliminary 8 language on construction to support a public meeting 9 coming up in a couple weeks. And then Subpart F on 10 Operations, and Subpart G on Decommissioning. And 11 then as we just mentioned, the licensing aspects will 12 be getting dedicated subparts. We currently as a 13 preliminary outline, have them in H and I.
14 And I want to talk each about, each of 15 those subparts in a little more detail. Kind of in a 16 "Table of Contents" format, so we can maybe discuss 17 them a little more than we have in the past.
18 So, if we go to the next slide, Slide 4 19 this goes to kind of the process that we were kind of 20 laying out. And how we would do interactions with 21 ACRS. We have a similar slide for interactions with 22 public stakeholders and internal communications and 23 interactions.
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17 1 framework, the safety criteria in Subpart B, and then 2 the rest of the subparts.
3 I look at this however, it's kind of like 4 writing a novel, in that we're constantly iterating, 5 or we expect to be constantly iterating as we go 6 forward. So, given this schedule on the interactions 7 issue, as you might imagine, we're currently writing 8 Subpart F on Operations.
9 We're still talking with stakeholders 10 about Subpart B, and to some degree even the overall 11 framework. Talking to you today about Design and 12 Siting, and so our plan is to constantly support this 13 communications and interactions and iterate.
14 So, one of the comments and criticisms was 15 we haven't put out an iteration on Subpart B and C.
16 That is in part, from our perspective, just because we 17 have these different interactions with public 18 stakeholders, ACRS, and our own internal 19 communications that we have to try coordinate.
20 So, we have or are preparing a, you know, 21 the next iteration even on Subparts B. And then 22 today's meeting will help us in terms of an iteration 23 on C and D that might come a month or two from now.
24 So --
25 CHAIRMAN BLEY: Bill, Bill --
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18 1 MR. RECKLEY: Yes, Dennis.
2 CHAIRMAN BLEY: This is Dennis. I know 3 you're going to get to it and I knew you're eagerly 4 awaiting it, but it seems to me Subpart B -- frankly, 5 meeting in today's staff there was questions we had on 6 Subpart B, so are causing me trouble.
7 So, it seems to me that's a really 8 important rule to get smoothed out as soon as 9 possible, because it effects everything else. Go 10 ahead.
11 MR. RECKLEY: We fully agree with that, 12 Dennis.
13 MR. CORRADINI: So Bill, this Corradini.
14 So to follow Dennis's question. So you're going to 15 return to B very shortly. Is that the plan? Because 16 I'm in the same boat as Dennis, I'm still confused 17 about that. And that leads me then to look at 18 everything else expecting a change in the future.
19 MR. RECKLEY: Yes, we'll get to a summary 20 or a review of Subpart B, where we are. And you all 21 are right, if we make major changes to Subpart B, then 22 what we're presenting to you today would have to be 23 adjusted likewise in a major way. And we're cognizant 24 of that.
25 MR. CORRADINI: So Bill, can I ask a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 question, a general question? And then you can stick 2 it away or choose to ignore it. As these reactors 3 become, I'll use the word, simpler, or less complex, 4 is the licensing approach of 53 able to handle that?
5 Or is this one size fits all?
6 In other words if I go from a 3000 7 megawatt thermal machine to a 10 megawatt thermal 8 machine, I wouldn't expect Part 53 would require the 9 same complexity of information that the staff would 10 need. Am I off base, or -- and I'm struggling to see 11 what so far I've read, how that's accommodated?
12 MR. RECKLEY: And that will be a 13 challenge. And when we get to feedback you can see 14 that's some of the feedback we're getting. And if I 15 can just hold until we talk about that feedback. But 16 --
17 MR. CORRADINI: Okay, I'm sorry. I don't 18 want to --
19 (Simultaneous speaking.)
20 MR. RECKLEY: Yes, but only at a high 21 level let me take a shot at it now. Our thinking is 22 that this rule will accommodate the whole range. And 23 that inherent in the processes that we were calling 24 out, there's the ability to grade those requirements 25 to accommodate that wider, that whole range or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 spectrum of reactor designs.
2 And our current thinking as we're laying 3 it out to you here, is that we don't have to have 4 different high level requirements. The grading 5 happens within each element. So, if you have a simple 6 design, the analysis that's required, and we'll talk 7 about it later since today's discussion is on design 8 and analysis, the design and analysis activities 9 should be easier because your machine is simpler.
10 MR. CORRADINI: Okay. I see where you're 11 going.
12 MR. RECKLEY: But we currently, but that's 13 the challenge. And some people said we missed the 14 mark on this. That, and they think the rule has to 15 specifically accommodate a difference. Saying this 16 machine is simpler, therefore a different set of rules 17 apply. We're considering that. That's the feedback 18 that we've gotten.
19 But as we've laid it out here, we say do 20 an analysis, and the assumption was the analysis could 21 be graded based, or almost by its nature be simpler, 22 if the machine itself was simpler, so. But we'll get 23 into that discussion when we get into the actual 24 Subpart C.
25 MR. CORRADINI: So let me end by an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 interesting way in which you've said it. The way you 2 said it, maybe I misinterpreted is that you would 3 start with a design and the analysis that's required 4 of it. And as the design becomes simpler, the 5 analysis could be simpler.
6 It would seem to me, the case I would 7 make, if I were a developer, if I really have an 8 advanced reactor of any size, I would try to do the 9 simplest analysis possible at the beginning and only 10 get complicated if I don't satisfy the margins I need 11 to guarantee safety.
12 So simple is the way I'd start it off 13 regardless of size. And I'm trying to struggle to see 14 at least in the language that we've seen so far, how 15 things are simpler here and more easy to at least 16 accommodate?
17 CHAIRMAN BLEY: Bill, I want to jump in, 18 this is Dennis and I do want to give you a chance to 19 go ahead and then we'll see how it progresses. But at 20 least the flavor that I got from the last meeting, 21 wasn't usually this ability to have gradations of what 22 you do depending on characteristics of the design.
23 Would it be addressed in guidance 24 documents, is that still the intent rather than the 25 rule itself? Let's say, you have to look at whatever NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 reactivity you're on, and the guidance will tell you 2 how much you have to do depending on characteristics 3 of your design. Go ahead, and I'll be quiet a while.
4 MR. RECKLEY: That's a good point. And 5 yes, Dennis by and large we think how that gradation 6 would work and how a simple design might differ from 7 a more complicated machine would be reflected in the 8 guidance.
9 MEMBER REMPE: So before you go on, I know 10 we're taking too many comments now, but I, this is why 11 I keep harping on the alignment, the 50.52 topic.
12 Because I think the guidance, for example, what's 13 required in a PRA could really help both your effort 14 as well as their effort. For this guidance is going 15 to be a very important feature. And the sooner it's 16 done, maybe it will dissolve some of the comments 17 we're seeing?
18 MR. RECKLEY: We hope that's the case.
19 And in our March meeting, public meeting, Guidance 20 Development is going to be one of the topics to see.
21 The staff has a number of things under way. And the 22 industry also has a number of things underway.
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23 1 forth? So, all of that, it's a good point and we 2 realize it.
3 And that's one of the things we'll be 4 talking to the industry about, is what may, what might 5 they start to develop guidance for our review and 6 endorsement. And what guidance will the staff be 7 developing basically on its own?
8 CHAIRMAN BLEY: Bill, I lied, I'm going to 9 jump in one last time. Where on this schedule, do you 10 have a column here for interaction with the 11 stakeholders or with the ACRS on initial guidance?
12 And I think getting some preliminary idea 13 of the structure of what these folks will believe or 14 think about for guidance, and what kind of schedule 15 that would be, would literally help alleviate some of 16 the questions we're asking, if we know where it's 17 going to fit.
18 So, don't respond to that now, but I hope 19 you can during the talks today.
20 MR. RECKLEY: Okay. All right. So again, 21 this kind of lays out where we think we will be in 22 needing to interact with the ACRS on the various 23 topics basically throughout the rest of this year, 24 into early next year.
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24 1 as John mentioned, in the direction that was given to 2 the staff by the Commission in the staff requirements 3 memorandum for our rulemaking plan. So, I think we 4 can go then to next slide.
5 And I've used this slide a number of times 6 too and it goes -- I like to come back to it because 7 it basically reflects all the discussions we've had up 8 to this point even, and will continue to have. In 9 that one of the founding things or the first 10 principles that we come back to is to try in a 11 technology inclusive manner, address what it is we're 12 trying to do.
13 And by and large, this is a 14 simplification, but what we're trying to do is make 15 sure that there's enough barriers in place such that 16 the inventory of radionuclides that will be generated 17 from a nuclear reactor, that's the one thing they all 18 have in common, is that the process itself is making 19 the radioactive materials and creating the hazard that 20 we as the NRC, have as our mission to try to make sure 21 is controlled before it reaches the public through 22 this simple diagram, the atmospheric dispersion arrow.
23 And that is accomplished by looking at 24 that inventory, and then again, the barriers that are 25 in place to retain it, or attenuate any releases, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 how they behave in normal operations. And how they 2 will behave when challenged by transients or 3 accidents.
4 And so, somewhat to Mike's point, if you 5 can develop a machine that -- this equation is largely 6 based on the DOE principles for non-reactor 7 facilities. And in that model, the inventory is 8 called material at risk, and the first factor is 9 called damage ratio.
10 If I can have a reactor such that the 11 material at risk and the damage ratio is close to 12 zero, meaning I don't have a way to get the 13 radioactive materials even out of the fuel, then 14 that's a simple design.
15 And should be, we should be able in the 16 probabilistic risk analysis, the deterministic 17 analysis, all of those analyses should be able to say, 18 hey, in this particular design, I've achieved really 19 the ultimate goal, which is the radionuclides never 20 get out of the first floor. They stay in the fuel 21 room most cases here, that we'll be talking about. So 22 --
23 MEMBER BROWN: Bill, isn't that kind of 24 pie in the -- this is Charlie. That kind of pie in 25 the sky?
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26 1 MR. RECKLEY: Um.
2 MEMBER BROWN: The idea that somebody --
3 MR. RECKLEY: That's a --
4 MEMBER BROWN: I mean --
5 MR. RECKLEY: Yes, that would give them a 6 little challenge. I'll leave it at, it would be a 7 real challenge.
8 CHAIRMAN BLEY: Bill, you've used this 9 slide. I think it's a wonderful slide to make your 10 point, but research reactors are essentially this.
11 They're sited within cities, and they're essentially 12 damaged, I can't remember the DNA terms but the real, 13 the potential releases is minimal.
14 MR. RECKLEY: And we've, I mean we've 15 looked at that. And to the degree the inventories are 16 similar and you have things like the TRIGA fuel that 17 can minimize any releases and address potential 18 accidents to limit thing like temperatures that might 19 relate to a release.
20 We're looking at that to see if we can 21 control. But when -- you know, there are a number of 22 things that are different. Most research reactors, 23 even if they're of a similar size as some of the 24 micro-reactors under discussion, end up with lesser 25 inventories for example.
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27 1 Because they're intermittent operation 2 versus what would be basically continuous operation 3 over the life of a facility, be it 10 or 20 years.
4 And so --
5 MEMBER BROWN: But they're also much less 6 power.
7 MR. RECKLEY: In general --
8 MEMBER BROWN: We're talking about power 9 reactors that are going to generate electricity for a 10 huge, large populations.
11 MR. RECKLEY: But yes, and but the 12 discussion typically has been on the micro-reactor 13 side, so even if it's on the megawatt, single megawatt 14 size, the inventory will be bigger for a power 15 production facility, than a research facility.
16 MEMBER BROWN: Most.
17 MR. RECKLEY: In most cases.
18 So, we are looking at all of that. And 19 again, we would be open to an argument that says if, 20 again back to if the damage ratio is very, very small, 21 then that is a great thing. We wouldn't want to 22 discourage it. And we'll take that into account in 23 assessing how many other barriers you need. So --
24 CHAIRMAN BLEY: Bill.
25 MR. RECKLEY: -- but, so let me take it, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 Dennis, or?
2 CHAIRMAN BLEY: Yes. Two things I wanted 3 to jump in with. One is it seems a reasonable idea 4 to, however damage ratio, there's a lot hidden in 5 there, and maybe a whole PRA is one way of thinking.
6 How do you get the damage ratio for all possible 7 scenarios?
8 But for the smaller reactors, the things 9 that approach experiments, this was brought up to me 10 yesterday by a few people. And we just had an 11 incident at the NIST reactor. We're going to try to 12 get a look at that. Are you guys thinking you can 13 learn anything from that that might be useful to you 14 here?
15 MR. RECKLEY: Yes, I'm sure we will. And 16 actually that's being, you know, our division actually 17 has the responsibility for the oversight of NIST.
18 There's a team there now, so yes, we'll be looking at 19 that.
20 MEMBER BALLINGER: This is Ron. I'm just 21 struggling to try to find where damage ratio is 22 defined in a document? I'm sure it is, but can you 23 tell me?
24 MR. RECKLEY: Let me get back to you on 25 what DOE letter that is. Offhand I forget the number.
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29 1 MEMBER PETTI: Hey, Bill. I just want to 2 support your thinking. I'm involved in a micro-3 reactor project. And I don't think it's pie in the 4 sky to think for some of these technologies, if we 5 know about them in the end, what's called power 6 reactor embodiment.
7 So take an HGTR something I know about, 8 and make it a micro-reactor. In fact the safety 9 issues just become much, much less because of some 10 simple considerations like surface dividing ratio of 11 a small micro-reactor compared to an MHTGR.
12 I think the same is probably true of an 13 SFR, if you were to, you know, shrink them down. So, 14 I think your thinking is right. And a lot of these 15 technologies will, a lot of our experience might be on 16 the larger size, but when you make them smaller, you 17 do get some safety benefits.
18 And that should all come through, you 19 know, in terms of the analysis that you do. But I 20 think fundamentally that's not a bad way to think 21 about it.
22 MR. RECKLEY: Thank you. And I guess to 23 a couple points that's been made in that particular 24 example even. We also don't want to mislead people on 25 how much might have to go into determining that first NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 factor, right.
2 And then obviously, the work on TRISO fuel 3 would support what Dave was just suggesting. But 4 that's been extensive to actually provide the 5 confidence that the -- and again I didn't want to 6 really introduce it into the reactor realm, but if 7 we're going to use the damage ratio term, the damage 8 ratio for TRISO fuel is supported by a decades-long 9 research activity that actually supports that 10 discussion.
11 So, even if you can break it down simply, 12 and say, yes, we're going to be able to give a lot of 13 credit to the first barrier. But I don't want to 14 mislead people, that that makes it easy. Because 15 providing the confidence in the first layer will 16 likely require proving the performance of that first 17 layer by a lot of experiments and analysis.
18 So, I mean we're trying to find the 19 balance here and I think you guys can appreciate the 20 challenge. And to Dennis's point, that if you're 21 going to be relying on the first layer more than we 22 have traditionally, you do have to then look at all 23 the events that we're challenging.
24 What temperatures it's going to reach.
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31 1 having to define as we'll talk about in the next few 2 slides, the licensing-basis events and the range of 3 challenges. And do you do that through a PRA, or is 4 there a simpler way? That's where we are on the 5 discussions with the stakeholders.
6 So, I think the point I was trying to make 7 on this slide has been made, hopefully. We can go 8 onto the next slide which shows another challenge that 9 we're trying to accommodate, and it's again another 10 slide I've used many times.
11 The other thing we're trying to do in Part 12 53 is to integrate the whole regulatory scheme. And 13 so in looking at Part 53 and where we want to end up, 14 we'll be facing challenges such as how does the rule 15 accommodate alternatives on the mitigation side of 16 this bow-tie diagram?
17 We know that a desire of generation four 18 technology plants, from the beginning, has been to 19 reduce reliance on things like emergency planning. We 20 have a proposed rule under way that gives some 21 alternative approaches to determining emergency 22 planning zone versus using the default, ten miles.
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32 1 cognizant of that as you're looking at the actual 2 behavior of a plant, and the analysis and the design 3 activities you're going to require.
4 Because you're building into this, the 5 possibility that you may not rely on things like 6 siting and emergency planning to provide additional 7 layers of defense-in-depth as we've traditionally 8 done. So, that puts more onus on the design and 9 analysis, to support those possible approaches.
10 One of the challenges is we're trying to 11 leave it open such that we're not -- that if any 12 design or designer, or licensee, applicant were to 13 choose to take credit for emergency planning, that 14 that remains open to them.
15 It would have made our life simpler if we 16 try to write this rule such that it was not needed.
17 But a challenge again that we're facing is we're 18 trying to leave it open for future designers, future 19 applicants to decide the balance between prevention 20 and mitigation.
21 And so that is another area when we get 22 into Subpart C that we have a specific requirement and 23 it'll be a point of discussion I can imagine.
24 MEMBER PETTI: So Bill, Bill, just a 25 question on that prevention, mitigation and defense-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 in-depth. I'm sure it's not something you put in the 2 rule, but in the guidance the balance between those 3 could depend a lot on the safety features and the 4 technology and the size of the machine.
5 So, I could imagine that how one 6 implements defense-in-depth at a micro-reactor might 7 be very different than this same technology at a power 8 plant scale. Are those things that you guys are 9 thinking about, how you incorporate the inherent 10 safety characteristics of some of these technologies 11 and what that means in terms of the, let's call them 12 the "overarching safety philosophies" that the Agency 13 has always used, and how it might change?
14 MR. RECKLEY: Well, they're trying to, 15 yes. And again, even on inherent, I have a slide 16 later and it's a question we've posed. We have some 17 notions but any thoughts when we get to the slide, 18 where we basically are asking a question, not posing 19 a position on whether additional guidance or even 20 newer language might be appropriate to address 21 inherent features. So, when we get to that slide a 22 little later, please.
23 MEMBER PETTI: Okay.
24 MR. RECKLEY: If you have a thought.
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34 1 us but we're trying to keep in mind the overall 2 structure. And what we might be getting in terms of 3 future requests.
4 So, if we go down to Slide 7, what I 5 thought I would do just to quickly provide a little 6 more detail than that structure figure that we've 7 used. Is to go through the subparts kind of in a 8 "Table of Contents" format. And we can discuss a 9 little more detail, some of them.
10 Subpart A is General Provisions, and I 11 wasn't planning to talk very much about this, but we 12 need to have a place in Part 53 where we provide the 13 normal things that you would see in 50 or 52 in 14 regards to how to communicate with us, and 15 definitions, and employee protection, and so forth.
16 So, this list of bullets is largely the 17 items out of Part 50 and 52. And the talk about those 18 kind of high level provisions and requirements, 19 responsibilities of licensees and so forth. So --
20 CHAIRMAN BLEY: Bill.
21 MR. RECKLEY: Yes.
22 CHAIRMAN BLEY: Yeah, I'm glad you're 23 going this. I've gotten comments from a lot of 24 members. So, to my favorite thing in regulations, 25 where does it fit in the structure? It sounds like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 you're kind of doing that, and I think that will help 2 a lot for all of us. Go ahead.
3 MR. RECKLEY: Okay, thank you. And no 4 apologize, we've had this, we just didn't present it.
5 Sometimes you over think how much or how well you're 6 communicating for example, just on that one figure.
7 So, then we can go to Subpart B.
8 MEMBER KIRCHNER: Bill, before you go on, 9 this is Walt Kirchner. On the definitions, have you 10 tried to, we had a conversation earlier this morning 11 on reconciling with 50 and 52, our consistency and 12 such. One of the most important definitions in 50.52 13 is safety related.
14 Have you come to some, do you have some 15 thinking on how you might define that for 10 CFR 53, 16 whether it's taking the formulation that is somewhat 17 Light-water reactor specific and make it a more 18 generic definition that would apply?
19 MR. RECKLEY: Yes, we are proposing a 20 definition in Subpart C, that we'll get to in a little 21 bit. And it's a little different and one of the 22 things that we're trying to come to grips with is, 23 when we have the same term and it's defined in 50 and 24 52, whether we change terms, whether we use a 25 different definition.
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36 1 In terms of safety related and again we'll 2 get to it in a little bit, but I don't think our 3 concept fundamentally is different. And we might try 4 to argue that ours is a more global definition in Part 5 53, and if you were to apply it to a Light-water 6 reactor you'd end up with the definition that's in 7 Part 50 and 52, but that will be a bit of a challenge, 8 but we --
9 MEMBER KIRCHNER: Okay, I'll look forward 10 to that because I've been thinking pretty hard on that 11 particular item.
12 MR. RECKLEY: And that will be again, one 13 of the, we have a running -- we're, the colliding 14 terms that we'll need to define. And there are some 15 terms that, and we pointed this out in, when we were 16 working on the Licensing Modernization Project NEI 17 18-04, they had similar or the same terms with 18 different definitions. So that will be a continuing 19 issue.
20 CHAIRMAN BLEY: Bill and Ron, your mics 21 are open. You going ahead -- oh, go ahead Ron.
22 MEMBER BALLINGER: And that's, it's open 23 because I want to speak, and I have a cat. The term 24 damage ratio was defined in a DOE handbook in 1994, 25 related to airborne release fractions for non-reactor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 nuclear facilities. If anybody wants to -- it 2 actually has an ML number, so, anyway you don't need 3 to tell me what it is, I know where it came from.
4 MR. RECKLEY: Okay, thank you. And again, 5 I don't want to exaggerate its incorporation here.
6 But it's a similar concept.
7 So, if we go then to Slide 8, it says 8 Subpart B, and I'm going to talk about this in a 9 little more detail. So this is just the format that 10 we provided in our January meeting. And instead of 11 dwelling here, I think we have a few slides I'd like 12 to revisit Subpart B.
13 So then Subpart C, we're going to talk 14 about today, that's Slide 9, the Design and Analysis.
15 And this is the existing format for the iteration that 16 we provided to you. Just in terms of timing, the 17 iteration, the first iteration that we provided to you 18 is for today's meeting, was actually released before 19 our last meeting with you in January.
20 So, we did touch on Subpart C in our 21 January discussions. We know the language you were 22 looking at doesn't reflect any of those conversations.
23 We will be looking to do future iterations and even 24 have some notes in today's presentation where we're 25 thinking of making some changes based not only on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 stakeholder observations, but also our meeting in 2 January. And then obviously, we'll take today's 3 meeting and that might get incorporated into even a 4 future iteration.
5 So, if we go to Slide 10. We'll also be 6 talking about this this afternoon. So this is just 7 the general outline of Subpart D. Some general 8 observations on siting. And then looking at external 9 hazards, the traditional site characteristics that one 10 needs to define, considerations related to 11 populations, and then the connection with Part 51 in 12 environmental. But again, we'll talk about this this 13 afternoon.
14 So Subpart E on Construction, Slide 11.
15 We're getting ready to release an iteration on Subpart 16 E to support public meetings in March. We've 17 basically broken this into two halves. One is on 18 typical construction. When I say typical, it would be 19 a project that would look a lot like what we're used 20 to, be it under a construction permit, or a combined 21 license approach, Part 52 approach.
22 But it is a construction, if you put it in 23 terms of housing, a stick build, if you will. This is 24 the current approach for, underway at Vogtle for 25 example. It would fall under this part.
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39 1 And we've defined the activities as what 2 management in control is needed, what you would have 3 to do throughout the construction process. What kind 4 of inspections and acceptance reviews would be needed?
5 And a section on communications. This is, this 6 section is dominated by quality assurance, quality 7 control kind of requirements.
8 And when you see it, you'll be able to 9 recognize right away that this is basically, again 10 dominated by quality assurance considerations.
11 The second half of this subpart on 12 construction and manufacturing, we're putting out 13 language again, to cover the quality assurance, 14 quality control aspects. But then also we're using it 15 as an opportunity to really begin the discussion on, 16 if this is going to be the approach, include it. And 17 we're assuming when we say manufacturing that we're 18 going to get into the realm of a manufacturing 19 license.
20 So, if the distinction for us between the 21 two is you can have modular construction, you can even 22 build modules just like is being done for Vogtle or 23 you would see in ship building activities and so 24 forth.
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40 1 being done as part of a, just to help in the 2 construction process, that's still a construction 3 activity.
4 Manufacturing as we're proposing it in 5 this first iteration is the activity that would be 6 undertaken through a manufacturing license from the 7 NRC, which is, it's a different vehicle. And really 8 reflects a more kind of factory fabrication of the 9 whole reactor, or at least major parts of the reactor.
10 We have questions and again, we're going 11 to use the upcoming interactions to talk about how far 12 this might go in terms of would people envision 13 loading fuel at the factory and then transporting a 14 loaded reactor to a site and so forth?
15 So, we currently have some rough 16 provisions for that. But if our normal goal would be 17 to say, we're shooting for the 80-20 kind of language, 18 when we're putting it out as preliminary, I'd say in 19 this area, we're somewhat less than 80-20.
20 Because we have a lot of questions on what 21 it is that the people foresee as kind of the business 22 model, the manufacturing model, and what we would need 23 to support in Part 53? So --
24 MEMBER KIRCHNER: Bill, this is Walt 25 again. If I might ask for clarification. New NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 manufacturing licenses, by and large they usually 2 involve special nuclear material. They usually 3 revolve around fuel. Isn't that the case?
4 MR. RECKLEY: There is a current provision 5 in Subpart F of Part 52. In ISO manufacturing, this 6 isn't like a fuel cycle facility that would have a 7 materials license to make fuel. So this isn't, you 8 know, the Westinghouse facility, or the General 9 Electric facility making fuel.
10 A manufacturing license is for a reactor 11 facility, and the only exercise that we've had for 12 manufacturing licenses is offshore power systems back 13 in the early 80s. And it is a different reactor 14 approach. And if you look at the history of Part 52, 15 or at least the way I look at it, Part 52 was oriented 16 towards standardization.
17 And so the design certification process 18 was a large element of getting the design 19 standardized. The manufacturing license was one step 20 further. And said, not only is this the design that's 21 standardized, but this is the process by which the 22 machine is going to get put together.
23 This is going to be the welding 24 techniques, this is going to be the, just think of 25 whatever else might be included in that and the NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 would review and approve not only the design, but how 2 it would be put together and issue that in a 3 manufacturing license.
4 So that was, to me that was kind of like 5 the ultimate standardization. And why it fits into 6 this new discussion of a factory assembled, a factory 7 setting for reactors.
8 MEMBER BALLINGER: This is Ron again.
9 With respect to say Part, transportation. How, with 10 a small source term, for some of these small reactors, 11 how is transportation to and from the site, even for 12 a plant that's been operated, differ from just 13 transporting spent nuclear fuel?
14 CHAIRMAN BLEY: Well, with that, as we 15 build this out, we'll see. We think you're right, 16 that we can handle the transportation element under 17 the existing requirements. The difference will be 18 that the design of the reactor itself will have to 19 foresee its use.
20 Not only as a reactor, but maybe as a 21 transportation package.
22 MEMBER BALLINGER: Got it.
23 MEMBER KIRCHNER: And also, the kind of 24 mechanical loadings and such are, that you have to 25 accommodate will have an impact on the design as well.
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43 1 (Simultaneous speaking.)
2 MEMBER BALLINGER: Right, but it's pretty 3 much the same, kind of analysis --
4 MEMBER KIRCHNER: You'll have to iterate 5 on that --
6 MEMBER BALLINGER: -- that you have to do, 7 right?
8 CHAIRMAN BLEY: No, I don't think so.
9 Well, it is currently my understanding is that NRC's 10 role in the transportation of the spent nuclear fuel 11 is to certify the casks. Everything else in that 12 process belongs to other agencies who protect that 13 cask in various ways.
14 But if we're shipping a new kind of 15 reactors with built in control systems and new fuel 16 and all that, I think the world of NRC is a lot 17 broader than it currently is. So, you know it, today 18 -- you guys still remember that time?
19 MR. RECKLEY: Some, but not to the degree 20 that we would need to take this concept all the way.
21 And that's why we're wanting to engage stakeholders 22 before we undertake it, because it -- and you're 23 right, it would have to address various things.
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44 1 irrelevant. Maybe during the transport phase, but 2 again, we really wanted to engage stakeholders to see 3 if there's a real interest in this.
4 We think there is, but we wanted to 5 confirm it before undertaking this activity, and doing 6 more interactions, even internally with our 7 transportation folks in NMSS.
8 So, that would be Subpart E on 9 Construction and Manufacturing. Subpart F gets into 10 Operations. And so, go to Slide 12. If you go to 11 Construction and Manufacturing, there's two segments.
12 Thinking on Operations, is it can somewhat be broken 13 down into three segments.
14 The first one is on the equipment, and the 15 focus would be on configuration controls, like it is 16 now. So, for safety-related equipment, those would be 17 addressed in Technical Specifications. And we'd have 18 the equivalent of limiting conditions for operations 19 and completion times.
20 Not really a new concept, but 21 configuration control for the safety-related functions 22 would be governed by Tech Specs. The configuration 23 management for safety-significant, this is the non-24 safety-related, but safety-significant category that 25 we'll talk about under Subpart C.
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45 1 We would really have to define, would the 2 -- it's envisioned, you'd have more licensing, you'd 3 have more flexibility for those structure systems and 4 components, but we need in the rules to define that 5 there does need to be controls for those equipment.
6 So, what kind of reliability assurance 7 program? How is maintenance performed and controlled?
8 So, that's an area we're currently working on. This 9 goes to, again, our goal would be that NEI 18-04, the 10 Licensing Modernization Project, remains as one way to 11 meet Part 53.
12 And that guidance includes the non-safety 13 related with special treatment category, and talks 14 about various forms of special treatment that might be 15 applied to that equipment.
16 Our challenge here is to incorporate that 17 concept into the rule, to make sure that that 18 equipment is actually controlled. There's measures in 19 place to make sure it is available, that it's 20 reliable.
21 Because as it's currently constructed, 22 there's a probabilistic element there, where the 23 contribution of this non-safety related with special 24 treatment equipment, might be to limit the frequency 25 of events.
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46 1 What that then means, you have to monitor 2 the availability and reliability of this equipment to 3 make sure that your frequency estimations in the PRA 4 are remaining valid.
5 So, it's an additional element that we 6 would be adding to support this -- and we'll get into 7 the discussion, in these two tiers, or two layers that 8 we're trying to carry throughout Part 53.
9 Then some other thoughts that we would 10 have for the operations, the equipment aspect of 11 operations is there would be a QA element, maybe 12 address age and management from the beginning.
13 Design control, this would be the 14 processes you need to make sure that you're 15 maintaining the design, or if you're changing the 16 design, that it's being assessed.
17 And as we'll talk about a little later 18 this morning, that the design and the analysis stays 19 either connected or you redo the analysis. But that's 20 an interface, back and forth, between maintaining the 21 design during operations in the subpart we'll be 22 talking about today.
23 And we talked about briefly, well, we 24 talked about it at the last meeting, the Facility 25 Safety Program. And the notion of using such a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 1 concept to look at the new information and assess 2 whether changes to the facility would be warranted.
3 Then the next segment of Operations 4 Subpart F, go to Slide 14, is Personnel. Let's see.
5 I'm not seeing it change, I'm not sure if others are.
6 MEMBER KIRCHNER: No, we have it. Slide 7 13 is showing, Bill.
8 MR. RECKLEY: Okay. So, this gets into 9 another very interesting area. And so, we're going to 10 start the discussions, I think, in April and May with 11 stakeholders, and this will include ACRS, on the 12 appropriate staffing and control of staffing for 13 Advanced Reactor Designs under Part 53.
14 And we have heard of proposals and 15 possible justifications for not only reducing staffing 16 levels, but for more dramatic change, like not having 17 licensed personnel attending the reactor. And the 18 possibility of going to an unmanned reactor, a totally 19 autonomous reactor, if you will.
20 So, we're looking at those to see, again, 21 over the range of activities we're hearing the 22 possibility of autonomous, unstaffed, all the way up 23 to facilities that would look more similar to current, 24 or plants, or plants like NuScale that have justified 25 reduced staffing, but keeping a structure with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 licensed operators, for example.
2 So, we're just thinking about how to roll 3 this out. We've prepared a paper, a White Paper to 4 support the discussions. We'll be releasing probably 5 in March to support more discussions in, like I say 6 April and May.
7 But one very rough outline would be if 8 we're to support that kind of flexibility that remove 9 and require a developer or an applicant to prepare a 10 concept of operations, which is a real systematic look 11 at what is the level of personnel in the facility.
12 So, it's somewhat analogous to looking at 13 the equipment, and doing a systematic review of what 14 operators do to either prevent or mitigate transients 15 or accidents and also help -- personnel might 16 contribute to causing them.
17 But in any case, that concept of 18 operations could look at the role in meeting the 19 criteria set up for what we'll talk about a little 20 later, the design-basis accident.
21 As well as the role in meeting, create 22 more risk-informed approaches, like the NRC Safety 23 Guide, and what might be the role of personnel. And 24 maybe we can make a distinction between those roles, 25 just like we do for equipment.
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49 1 But then we would lay out what are the 2 requirements for licensed personnel, and what are the 3 requirements for non-licensed personnel. We are even 4 looking at whether we could look at keeping the notion 5 of licensed personnel, but trying to scale that such 6 that it would not be as onerous as the current system 7 we have in place, under Part 55 and the current 8 structure.
9 So, this is going to be, in my view, one 10 of the more challenging things to try to address. Not 11 only in the rule, but in the guidance, and this might 12 be a case where we can write a rule, but the guidance 13 would be essential.
14 So, go ahead Dennis, I'm sorry.
15 CHAIRMAN BLEY: A few things jump at me on 16 this. One is especially if we talk about unmanned 17 facilities. One either has to think about concepts 18 like your material, but risk and damage ratio, getting 19 so small that it doesn't matter so much.
20 Or some kind of remote operations. If you 21 get into remote operations, man, that's going to be a 22 bag of worms. There's so many things that could 23 interfere with that.
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50 1 coordinated, you, the owners, have to have coordinated 2 with local police and fire organizations so that they 3 can deal with whatever problems might occur. Because 4 I know we're talking about this on your next slide, so 5 (audio interference) over there.
6 But it seems to me, and you guys can 7 correct me on this, we've got a lot of regulation to 8 protect operators, maintenance people, workers on 9 site, from radiation.
10 For normal, and maybe abnormal operations, 11 we're not so much looking at ongoing accident 12 conditions, or at least beyond-design basis accidents, 13 and I don't know if you thought about that at all.
14 And second some of the possible designs 15 might offer greater chemical and energetic kinds of 16 problems that are not maybe nuclide related, but are 17 especially dangerous for workers, or maybe for nearby 18 populations, are you thinking about that?
19 Or are you thinking somehow, OSHA, FEMA or 20 somebody else has to step in and regulate that side of 21 things, which could make regulation pretty tricky for 22 people.
23 MR. RECKLEY: We have a slide in talking 24 about other hazards coming up.
25 CHAIRMAN BLEY: Prepare.
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51 1 MR. RECKLEY: So, on other hazards, let me 2 just defer until we get to that. In terms of the 3 other discussion this is again, this is another area 4 that we're probably not going to be 80-20, when we 5 start putting out preliminary language.
6 We're going to be somewhere short of that 7 because we need to know what it is, and what is the 8 range. And there can be a dramatic difference, as you 9 mentioned, between totally unmanned, and just having 10 some staffing.
11 And the staffing might serve multiple 12 roles, but would it be feasible, and I don't know the 13 answer to this, but would it be feasible to ever have 14 a facility that didn't have anybody there? Even just 15 to support security aspects, as well as maintenance 16 aspects, as well as other things.
17 And if it's not foreseen, then we might be 18 able to back up a step and say, okay we may not have 19 to write this rule to go to that, to that level.
20 MEMBER BALLINGER: This is Ron again.
21 Dennis and I have been having these pie in the sky 22 discussions about autonomous and unattended, or 23 operation. Have you guys checked out with NASA, and 24 what they do, and how they treat autonomous and 25 unattended operation with respect to safety and things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 like that for this kind of thing?
2 Because they're used to that, and they 3 developed a set of criteria for mission control if you 4 will, for lack of a better word, but it deals with 5 autonomous and unattended operation with respect to 6 safety.
7 MR. RECKLEY: We looked at some of that.
8 But what you're specifically mentioning I'm not 9 familiar with, so I'm going to look that up. But we 10 have looked at guidance in this regard, for nuclear 11 and non-nuclear facilities.
12 And interacted with the national 13 laboratories, some of which are involved with Sandia 14 in particular, with the NASA programs, but let me make 15 a note to look specifically at that.
16 (Simultaneous speaking.)
17 MEMBER KIRCHNER: This is Walt Kirchner.
18 I have two comments. One, I'm struggling with whether 19 the payoff is there for you to make the distinction in 20 concept of operations for first tier and second tier 21 safety.
22 It would seem to me, it's the same 23 personnel. And you would want, if you get into a 24 situation where you are beyond the design-basis events 25 into, for lack of a better term, into a severe NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 1 accident like situation, it's the same personnel that 2 you would want to depend on, in my opinion, and have 3 trained for that contingency.
4 So, I'm struggling with the undue 5 complication that this potentially represents. Then 6 my second comment is that, to the extent that you 7 reduce the requirements for licensed personnel, or in 8 the ultimate, an unmanned, unintended plant, it seems 9 to me then that the requirements in terms of quality, 10 defense-in-depth go up inversely with the lack of 11 people present, I -- to first order.
12 In other words, the dependence on safety-13 related equipment and functions, I think you call them 14 safety functions, such as controlled reactivity and 15 safe shutdown become even more important as you reduce 16 the training, the requirements, the staffing.
17 So, that you have a robust defensive-in-18 depth to compensate for what you're entertaining here, 19 going down the view graph. Does that make any sense?
20 MR. RECKLEY: Yes, it does. And again, 21 this is very, very preliminary, and we have to talk 22 internally about various things. And you're right.
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54 1 design side.
2 One of the, and when we get to the 3 discussions on inherent, you know, one of the 4 definitions for inherent, when you talk to control 5 system people, inherent means total reliable. It's a, 6 so no question, right.
7 And so, if you're going to be relying on 8 inherent features, which again we're open to 9 discussing this, but then you're basically saying 10 there is no question of how this machine is going to 11 behave, and it's governed by the physics. And if that 12 could be proved, then that can be a supporting thing 13 for a lesser role for personnel.
14 The other point you made Walt, which is 15 good, which is you can get into this error that you 16 would have to think about. Where the role of people 17 and the possible mitigation, which on equipment side 18 would, tended to say, might have more flexibility if 19 ultimately you're increasing the role of people on the 20 severe accident side.
21 If you want to use that terminology. Then 22 the logic that I laid out here, where various people 23 would have to have lesser controls, if you will, that 24 might not make sense.
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55 1 about. And so, when we get into the discussions in 2 April and May we will have hopefully, thought this 3 through a little bit more, and be providing some 4 preliminary language. But all of this discussion 5 today is stuff we can take into account.
6 So, if we can then support, yes, the last 7 part of Subpart F, this segment, the third segment, 8 we'll talk about programs. And this isn't an all-9 inclusive list, but it would look into the programs 10 that a licensee has to have and maintain, radiation 11 protection, emergency preparedness, security.
12 You would have, possibly, some others in 13 here on QA, radiation protection, probably would, well 14 it would address both on-site and off-site things.
15 And so, this is just kind of a placeholder.
16 The list will grow as we go through the 17 process, but just to define it again, Subpart F into 18 its three parts. There would be the Equipment part, 19 the Personnel part, and then the Programmatic part, is 20 the way we're currently envisioning that would go.
21 So, Subpart H, next slide. Oh, skip G.
22 G is Decommissioning, and that would involve laying 23 out the requirements for the termination of 24 operations. The transition, as we currently do from 25 operations, that would be a possession only license.
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56 1 We would include the financial assurance requirements 2 here, most likely, and then the requirements for 3 transition to unrestricted use.
4 But we haven't really, this is one that 5 we've given less thought to how it would go, but the 6 initial thinking is, it may not be that dramatically 7 different then what we have now for a construction 8 kind of project.
9 How this looks for a manufacturing model, 10 we have to think through.
11 CHAIRMAN BLEY: Have you gotten any 12 stakeholder comments on this slide?
13 MR. RECKLEY: We really have not engaged 14 shareholders yet in the discussions on 15 decommissioning. The one comment that we do have is 16 maybe we could, if we had an error that we might not 17 have for instance, the guidance developed for a 18 particular subpart, maybe this would be one we would 19 hold off on the guidance because it's at the end of 20 the process.
21 But so, the short answer is no, we really 22 haven't had much discussion on decommissioning. So, 23 if we go to sixteen, that's getting into the licensing 24 arena. This goes to Joy's point, and what Nan weighed 25 in earlier.
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57 1 We're not necessarily seeing dramatic 2 changes to these processes. The guidance will become 3 important, things like the content of applications 4 might change as you change the design and analysis 5 requirements.
6 There's a different project on the content 7 to applications, not different related. A project 8 that we have currently ongoing, and an interaction 9 again with the, it's a DOE fund cost-shared industry-10 led effort, similar to licensing modernization on 11 content of applications.
12 Our hope is that that can help inform us, 13 and provide the guidance for what would be in terms of 14 a content to applications for Subpart H. So, really 15 all this slide does is break down existing reviews and 16 license types into siting, where we have site 17 suitability reviews, that's still an appendix in Part 18 50, limited work authorization, early site permits.
19 Then under the design element, the design-20 oriented things that we have, are standard design 21 approvals, design certifications, and manufacturing 22 licenses, again Subpart F, currently in Part 52.
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58 1 design, we've found in the past that the stakeholders 2 have asked to have a conceptual design review in the 3 process of findings in the past, as we have that 4 available.
5 This would be something similar that we've 6 did in the 80s for PRISM, for the MHTGR, those pre-7 application reviews. That's not currently captured in 8 a rule but we think we have available, so, but we just 9 have a question mark there.
10 Whether the rule should, might accommodate 11 something akin to a site suitability review, but less 12 than -- in the design realm, but less than the design 13 approval. Just a question. And then --
14 (Simultaneous speaking.)
15 MEMBER BROWN: Bill.
16 MR. RECKLEY: Yes, go ahead.
17 MEMBER BROWN: Is the thought process on 18 that similar to what you did with I&C about 12 years 19 ago, with the pre-licensing application, not 20 application, but pre-licensing review for I&C systems, 21 so they knew what to expect? Is that the kind of 22 thought process? I've forgotten what ISG it is, it's 23 ISG four, five, six, or seven.
24 MR. RECKLEY: In the digital I&C area?
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59 1 very fruitful for the subsequently redesigns, I know 2 they did those. And therefore, when they finally 3 submitted their license applications, their 4 application, it went pretty smoothly on AP1000 through 5 the NuScale.
6 MR. RECKLEY: Yes, I would put that more 7 in a guidance realm. Well, I mean again, we'll talk 8 to stakeholders about what they may want, but this 9 would be more the review of a specific design versus 10 developing the guidance, which I think you're 11 referring to. And I wasn't involved in that.
12 MEMBER BROWN: Well, it was pre -- before 13 they submitted the stuff, it was just, they sat down 14 with NRC, with the I&C folks --
15 MR. RECKLEY: Oh, okay.
16 MEMBER BROWN: -- and when through this is 17 how we'll approach, and then they, NRC identified what 18 they were expecting. And therefore they didn't end up 19 with as, you know, much back and forth when they 20 finally got the stuff submitted, so --
21 MR. RECKLEY: Oh, okay. Yes, then it 22 would be more similar to that.
23 MEMBER BROWN: I'm just wondering what 24 your thoughts --
25 MR. RECKLEY: Yes.
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60 1 MEMBER BROWN: You might want to talk to 2 them, and you'll find out how that worked, see if it's 3 practical, that's all.
4 MR. RECKLEY: Yes, thank you. Yes, in my 5 mind, the difference that we've traditionally set is 6 that the standard design approvals, like the topical 7 reports and other features that we have in place, or 8 the product lines that we have in place, provide a 9 document that you can reference in an application.
10 You get full credit for that interaction, 11 and that review. Whereas, the conceptual design 12 review, as we've traditionally described it, you don't 13 get that safety evaluation that you can actually 14 reference in an application.
15 It might be very fruitful, but you don't 16 get a referenceable document. It's the distinction we 17 typically make.
18 MEMBER KIRCHNER: Hey Bill, this is Walt 19 again, Kirchner. I participated in those reviews of 20 the PRISM and the MHTGR, on behalf of the NRC. And I 21 thought, and those were fairly mature designs, for a 22 conceptual design. I thought they were very useful.
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61 1 starting place to flush out a lot of the potential 2 licensing issues, concerns, matters, that whereas, 3 jumping right into a request for a design 4 certification or a combined operating license.
5 My goodness, that's a, for some of the 6 advanced concepts, it's almost like it's too much of 7 a leap. That's just one member's opinion. So, I 8 think, providing for this might prove useful for the 9 more advanced concepts with limited experimental data 10 behind them.
11 MR. RECKLEY: Thanks Walt. And we don't 12 disagree with that. We just thought we'd start, we 13 had that existing process to pre-application reviews, 14 and we had the ability to do it without changing any 15 rules.
16 So yes, we certainly want to continue to 17 encourage it. The question would be whether we want 18 to build something into Part 53 to specifically 19 address that?
20 Then under Site and Design, the actual 21 facility, the processes in Subpart H on licensing 22 would reflect current processes, either a construction 23 permit and operating license, or combined licenses.
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62 1 of applications for these various options and 2 combinations, and we're thinking maybe we can do that 3 in a table.
4 And if we go on to Slide 17 --
5 CHAIRMAN BLEY: Bill.
6 MR. RECKLEY: Yes, go ahead, Dennis.
7 CHAIRMAN BLEY: Let's go ahead with the 8 next two slides on Subparts I and J, and then we'll 9 take a break.
10 MR. RECKLEY: Okay good. Subpart A -- I, 11 I mean, is the Maintaining-Licensing Basis. Remember 12 this is separate from Subpart H, we'll start talking 13 about, but you do need within the rule, to have 14 processes for how to amend a license, that that's 15 currently the 50.90 series of regulations in Part 50.
16 How to update the FSAR? Our current plan 17 is to include a PRA. So, how do PRA's get updated?
18 We'd have a requirement. Then the standard 19 regulations related to NRC actions like suspension or 20 modifying a license, when taking special nuclear 21 material, back fitting, and requesting information as 22 we currently do under 50.54(f).
23 So, that's just maintaining the licensing 24 basis. And then ultimately, the next Slide, 18, Slide 25 18 --
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63 1 CHAIRMAN BLEY: Well, before you leave 17.
2 MR. RECKLEY: Yes.
3 CHAIRMAN BLEY: I want to make a 4 suggestion to you. Including the PRA, excuse me, I 5 think it's a very good idea, but I think that's a 6 place you should already be starting to think of what 7 kind of guidance you want here.
8 Just off the top of my head, the place it 9 has to be done thoroughly, and the same ideas would 10 have to be done if you weren't doing a PRA is the 11 search for damage scenarios. Scenarios that can lead 12 to damage, initiating events, that sort of thing, has 13 to be as thorough as possible.
14 However, just as we've talked in other 15 areas, the depth of analysis that's done after that, 16 somehow ought to scale to the hazard and the 17 complexity of the design.
18 So, I think that's a place we don't 19 currently have any guidance. People have done this, 20 working outside of the nuclear field. But I think, 21 it's a place you really have to start thinking early 22 about what that guidance could look like, go ahead.
23 MR. RECKLEY: Okay, thanks Dennis. I 24 agree with that, just another of many items we're 25 going to have to address, both in the rule and in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 associated guidance. So, if you'll go onto the next 2 Slide 18. There are --
3 CHAIRMAN BLEY: I've lost the slides.
4 Does everybody else have them? I've got hard copies 5 if we need them.
6 MR. RECKLEY: Yes, I'm still seeing them.
7 Is everyone else?
8 PARTICIPANT: I can see them.
9 CHAIRMAN BLEY: Okay, go ahead.
10 MR. RECKLEY: Okay. Then on Slide 18, 11 there are, we're just currently kind of keeping this 12 as the catch all. They may not all end up in Subpart 13 J, but there will be administrative and reporting 14 requirements that we have, that we have to track.
15 But this is also being, as items come up, 16 this is kind of our parking lot. So, there are a 17 whole host of other things to consider like financial 18 qualifications, the insurance crime that's currently 19 in 50.53(w). That's property insurance as well as 20 references over to financial protection, liability 21 regulation.
22 MEMBER KIRCHNER: Bill.
23 MR. RECKLEY: Yes.
24 MEMBER KIRCHNER: This is Walt Kirchner.
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65 1 answer it. I posed it to Dennis in an email. You've 2 mentioned quality assurance now, several times, but 3 I'm getting the impression that you're not going to 4 make a requirement equivalent to 50.52 of Appendix B.
5 And it begs the following question, if you 6 don't build an advanced reactor to the quality, and 7 codes, and standards of the existing fleet, why should 8 you potentially be covered under Price-Anderson?
9 And I'm not an expert, I'm not a lawyer in 10 this area, but it's a rhetorical question, that has 11 occurred to me. That somehow if we're building 12 advanced reactors to lesser standards, or quality, 13 then the existing fleet, it raises, in my mind, those 14 kinds of questions.
15 It's a more of a policy kind of thing than 16 --
17 MR. RECKLEY: Yes, and I don't think, and 18 we'll get into this a little bit under Design and 19 Analysis, but I don't think that -- I know, from a 20 status point of view the intent is not to do lesser 21 quality.
22 The question that's been posed is, do 23 alternatives to NQA-1 in Appendix B provide the same 24 quality, the same confidence in the performance of the 25 equipment? That's the question, whether there is an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 1 equivalency, not can we allow a lesser standard?
2 MEMBER KIRCHNER: Yes so, so I can see ISO 3 9000, for example, being pretty comparable to NQA-1.
4 MR. RECKLEY: So, but as we go through, 5 the other thing, and this will be, as we put this 6 thing together and look at it. Our first attempt 7 here, on this iteration, was instead of having a 8 dedicated appendix on quality assurance, was to build 9 quality assurance into each of the subparts.
10 That's an area that if we look at it as we 11 put it together and say, it's actually more confusing 12 to do it that way, we could, at a later time for 13 clarity, without actually changing the intent or how 14 it would work, come up with Subpart K, Quality 15 Assurance, and then put it all back together.
16 But we'll see as we put it together if 17 that turns out to be the case. Again, we're currently 18 are taking the approach of quality assurance has been 19 incorporated into each subpart, versus referring to 20 Appendix B, where all the quality assurance stuff was 21 together, so --
22 CHAIRMAN BLEY: Well we're going to get to 23 the Subpart C --
24 MR. RECKLEY: Right.
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67 1 hearing what say there. My reading, I might have 2 missed something, you know, consensus standards show 3 up in there at least as a one liner. I'm not sure 4 about QA, but you'll talk about that when we get 5 there.
6 MR. RECKLEY: Right.
7 So, I think, Dennis if you wanted to take 8 a break, then when we get back, we'll do a recap of 9 Subpart B, just because it's important. And then 10 we'll get right into Subpart C on Design and Analysis.
11 CHAIRMAN BLEY: Okay yes, I wanted to stop 12 here because I think your four slides on Subpart B 13 might take us a while. We're doing pretty well, let's 14 take a half hour break, come back at 11:40. We'll 15 recess to 11:40.
16 (Whereupon, the above-entitled matter went 17 off the record at 11:07 a.m. and resumed at 11:40 18 a.m.)
19 CHAIRMAN BLEY: At this time, we're back 20 in session. Bill, you're back on.
21 MR. RECKLEY: Okay, thank you, Dennis.
22 So, say we take a couple of slides and recap the first 23 iteration that we prepared, and made public, on 24 Subpart B, the Safety Criteria, and also discuss some 25 of the feedback that we've been getting in that, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 1 what we're considering in providing an iteration, or 2 an update to Subpart B.
3 So, that the current structure, as we 4 provided it last time, and discussed it at the last 5 meeting, was that the highest-level safety objectives 6 would provide reasonable assurance of adequate 7 protection and that's taken out of Section 182 of the 8 Atomic Energy Act.
9 And that the requirements would also set 10 out to define such additional measures, to minimize 11 danger to life and property, that Section 161 of the 12 Act empowers the NRC to do. And how our thoughts 13 were, that we needed to address both of those elements 14 in order to meet what we are taking from previous 15 Commission direction.
16 That any advanced reactor has to be, at 17 least, as safe as the reactors we've licensed to date.
18 And we have regulations and have addressed in the 19 licensing processes fairly concrete measures to do 20 both of those activities.
21 So, under Safety Objectives, we put in 22 Subpart B that the primary safety function is to limit 23 the release of radioactive materials from the 24 facility, and that applicant needs to identify such 25 supporting functions that might be necessary.
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69 1 And for many reactor designs, that would 2 be the traditional need to control power or reactivity 3 and the need to remove heat, the need to control 4 chemical interactions, and so forth.
5 The -- then we went into the tiers, and 6 I'm going to have a slide where we made an attempt to 7 address some of the comments we got last time, and 8 hopefully clarify the two tiers.
9 But we've identified the first tier that 10 included normal operations and staying under the 11 limits of Part 20, that's the 100 millirem value. And 12 then for Licensing-Basis Events, to stay under the 13 guidelines that are currently included in Parts 50 and 14 Part 72.
15 Sometimes we'll refer to the siting 16 criteria, that's the 25 rem over two hours at the 17 exclusionary boundary over the course of the event, at 18 the low populations on boundary. And laid that out as 19 the first tier criteria for unplanned events.
20 And then to define the second tier that, 21 which is associated with as low as reasonably 22 achievable for normal operations. And then for 23 licensing-basis events, bringing in the criteria of 24 the NRC safety goals.
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70 1 the need to identify licensing-basis events, to 2 support the assessments of the first and second tier 3 criteria, to provide defense-in-depth, and to provide 4 measures to protect plant workers.
5 So, if we go onto Slide 20, this is our 6 attempt, it's -- I understand it's a concept that's, 7 I think we're generally familiar with it. And we've 8 seen its use in things like 50.69. Certainly under 9 the Licensing Modernization Project, and NEI-00-04, we 10 saw the attempt to make a distinction between 11 different criteria.
12 I'm hearing a bit of an echo.
13 There we go. Thank you, Derek.
14 So, under the first tier -- let me back up 15 one step. And so, in setting out the tiers, for the 16 levels, the goal was to try to support what we've seen 17 evolve under 50, and 52, over the years. Because this 18 distinction between those things needed for under 19 50.69 safety-related.
20 But maybe the requirements for safety-21 related didn't line up with the risk significance, and 22 in some cases, the risk significance of an SSC, didn't 23 necessarily get captured in the regulatory treatments 24 that 50.69 was trying to align, better align safety 25 and risk management with the treatment of SSC's.
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71 1 Again, under LMP, you had safety-related 2 and non-safety related with special treatment that set 3 this out in some detail. So, we're just trying to 4 capture the motion of setting out a distinction 5 between the treatment of equipment, and as I mentioned 6 earlier, when we were talking about staffing, a 7 possible distinction in the role of staffing.
8 So, that throughout Part 53, we could set 9 out these different controls, different levels of NRC 10 control, additional flexibility for licensees, for 11 those elements in the second tier.
12 So, that was the goal, was to try to build 13 it from the beginning, would enable a distinction 14 between two levels of equipment, two levels of 15 staffing, two levels of regulation.
16 So, the first tier was set out as being --
17 well it has generally been used over the years, as at 18 least one of the components of adequate protection.
19 And that's been the 25 rem criteria as it's defined 20 in, or in both 50 and 52. And how it's applied to 21 traditional design basis accidents.
22 And so, we kind of kept that, hopefully 23 made it more clear that that's what we were using it 24 for. And so, under the left column, under the darker 25 blue, the first tier.
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72 1 We set out the first tier, Unplanned 2 Events, the Guidance, the criteria being 50.34, 52.79.
3 Then we go down and say, you have to identify required 4 Safety Functions to meet those criteria. Do you need, 5 obviously you need to retain the radionuclides.
6 Do you need other things like controlling 7 heat removal, heat generation, controlling chemical 8 interactions, in order to keep the dose below those 9 thresholds? To the degree you need any of those 10 things, that shows up in the safety classification, 11 the application of Appendix B, the inclusion in Tech 12 Specs and so forth.
13 So, that class of equipment, or that 14 grouping of equipment, that grouping of human actions, 15 if you're relying on programmatic controls, those 16 programmatic controls are going to get the most 17 scrutiny.
18 Licensees would have the least 19 flexibility. For instance, if they are included in 20 Tech Specs, they couldn't change them without NRC 21 approval. And you set out this whole grouping of 22 requirements needed to meet the first tier.
23 And then, but in doing that recognizing 24 that even for the current fleet, my view, my view is 25 that that's not, we wouldn't be satisfied with just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 saying that those have a certain boundary that's less 2 than 25 rem. Our current requirements go beyond that.
3 And so, capture those things in a second 4 tier. And really, to kind of get your head this, and 5 my own view is that the current framework that we have 6 for the operating fleet started off as basically 7 binary. It's safety-related. It's regulated. It's 8 non-safety related. It's basically unregulated.
9 I might exaggerate a bit, but if you go 10 back far enough, it was somewhat close to that kind of 11 a binary treatment. Over the years, starting 12 especially in the 80s and carrying through now, 13 especially with all the risks in trying to incorporate 14 the risk-controlled insights.
15 You started to try to introduce the 16 anatomy of the second tier. And so, this got you 17 things like, blackout diesels. Important to safety, 18 but not safety-related. In under 50.69 again, it got 19 you controls over that class of equipment that might 20 be important in the PRA, but not previously treated as 21 safety-related.
22 So, the whole notion of the second tier 23 was to try to set up from the outset, the new need for 24 more than just showing you meet 25 rem. And capturing 25 in that second tier, those things that would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 important to control in the risk from the facilities.
2 And so, that led to using the safety 3 goals, because we were trying to, as much as possible, 4 use existing standards, versus creating new things, as 5 being the criterion for the safety goal for the second 6 tier.
7 And then, if you go down, to identify the 8 Safety Functions that would come out of considering 9 that second tier.
10 It's going to be what is the equipment, in 11 terms of both its ability to limit the consequences of 12 unplanned events and to control the frequency of those 13 events, in terms of the risk and safety significance, 14 and to provide an added defense-in-depth. So, that's 15 the way the second tier would show up under the Safety 16 Functions' row there.
17 And then you go down to Design Features 18 and Programmatic Controls, again, and our desire is to 19 come up with a consistent treatment across all of the 20 subparts on how we would the second tier.
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75 1 staff.
2 But as we go through the subparts, we'll 3 just try to build this out. So, that is the notion, 4 Dennis, you had brought up earlier, the tiers, and 5 I'll be honest, I went into a thesaurus and tried to 6 use a word different than tier.
7 Just because Tier 1, Tier 2, Tier 2 is 8 used under Part 52 and having developed the appendices 9 in Part 52 for the various designs. And every other 10 word had just as much confusion, or had been used in 11 a different context.
12 But, the notion here is, and as we develop 13 this through the licensing process, the hope is that 14 this structure can hold, as we get into the licensing.
15 And it will be pretty close to what is in currently in 16 Tier 1 for Part 52.
17 It's supposed to be those things that are 18 most important, those things that licensees can't 19 control, can't change without prior approval. That 20 this logic will hold, and we can use this structure, 21 even as we go in, and it will be used throughout.
22 You're right, as we've used that language, 23 and again, if we could come up with different words, 24 maybe it would be better, but when we were developing 25 under Part 52, this tiered structure, in order to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 identify what would be certified in the design, what 2 would require prior NRC approval of changes, what 3 would actually, quote, "be certified".
4 And then, under Tier 2, Tier 2 what would 5 be appropriate to be in the FSAR, and go beyond, and 6 provide more detail then what would be under the Tier 7 1 and included in the certification?
8 We had to develop that, and -- Derek, are 9 you over there? Thanks.
10 We had to develop that, and use it both in 11 a legal construct, in terms of the rulemaking in Part 12 52, and try to align it with the technical 13 distinctions.
14 Again, I think we can work, and try to 15 make this align as we get into the development of 16 Subpart H. Maybe we, that will be an area to see if 17 we're successful. That's all.
18 I think I'll leave it there, and see --
19 did this help, hurt, or whatever? I think Walt, you 20 were the one that suggested maybe we could tweak this 21 figure to try to make it a little more clear. I tried 22 to do that, but Dennis, or any other members?
23 MEMBER PETTI: Well, my concern --
24 PARTICIPANT: Hello?
25 MEMBER PETTI: -- is that by bifurcating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 it, some people might comeback with the argument that 2 well, the first tier is right, the ones I really have 3 to meet, because they're the ones that are in the law.
4 And the second tier, I may not have to 5 meet, but that's not what the intent is. I don't know 6 how you argue against that, but whenever, you know, 7 separate things like that, that's a risk right there.
8 MEMBER BLEY: Well, and that gets to, you 9 know, that gets to be to be an interesting concept, in 10 that one of the things that might be different, and 11 especially when you look at the micro-designs, is 12 there's a possibility that they would have no Tier 1, 13 I mean the first tier.
14 Now I'm slipping. In other words, there 15 may be the ability to have inherent features such that 16 you wouldn't exceed 25 rem, which is a fairly high 17 threshold. But then the regulation of those micro-18 reactors would be in the second tier, because they 19 would have to logically have controls on other things.
20 But then, I shouldn't say an absolute.
21 I'm not sure that even a micro-reactor would have 22 nothing in the first tier, but they could have very 23 little in the first tier.
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78 1 appropriate, perhaps, in that they would have more 2 flexibility, there would be fewer things they would 3 need to get prior NRC approval for, there would be 4 fewer safety-related components, and so forth.
5 So, it could be, one of the results of 6 this, when you apply it to the micro-reactors, can be 7 a shift. And the second tier becomes the dominant 8 tier in terms of where the regulatory requirements 9 would actually be coming from.
10 MR. CORRADINI: That's okay, Walt, but 11 just a quick follow-up. So, explain to me the 12 flexibility in the second tier. Maybe I'm missing it.
13 It strikes me a requirement is a requirement.
14 So, you just explained how the first tier 15 might not be, what should I say, controlling, but the 16 second tier would be.
17 Where is the flexibility? It seems to me 18 the way this is presented, both of these are sets of 19 requirements that must be met. And normally the first 20 two would be the controlling ones, the others would 21 not be. Can you help me there?
22 MR. RECKLEY: Sure.
23 MR. CORRADINI: And then I'll come to 24 Walt.
25 MR. RECKLEY: Well, the flexibility would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 come in -- in what is built into the second tier for 2 flexibility.
3 If it's not requiring safety-related 4 equipment, then you have the flexibility of the whole 5 commercial market, for example, in order to procure 6 equipment.
7 In terms of programs, if it's not in tech 8 specs and it's in the FSAR, you have the -- you have 9 the additional flexibility of making changes without 10 NRC approval. So, there's where you get the 11 flexibility.
12 You still need to meet the rule, but the 13 rule would have built into it that the things 14 controlled under the second tier the licensee has more 15 control, has more ability to make changes, has more 16 responsibility put on them to maintain things in 17 accordance with their licensing documents as opposed 18 to having things defined in a structure such as 19 technical specifications and requiring prior NRC 20 approval.
21 So, at the highest level, yeah, they still 22 are regulatory requirements, but they have the 23 flexibility built into them, would be the goal.
24 So, I'm sorry, Walt. Go ahead.
25 MEMBER KIRCHNER: Yeah. Bill, after your NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 last presentation on this, I kind of thought that 2 rather than showing -- and it's not just the optics, 3 but kind of consistent with Mike's question, I kind of 4 would think it would have been serial so that, as you 5 suggested there maybe for a larger power plant the 6 dose, you know, at the boundaries may be the 7 controlling requirements.
8 I kind of thought of these serially. I'm 9 very -- for example, safety functions. I think 10 defense-in-depth is part of the required safety 11 functions, in my mind, that is built into the design.
12 And it may prove that with a smaller 13 reactor they can, you know, very -- excuse the choice 14 of words -- deterministic manner address those and 15 show that they're well below both the QHO and the dose 16 in 50.34 or 52.79.
17 So -- but you would still want to see that 18 defense-in-depth integrated into that diagram that you 19 showed earlier today and such.
20 So, I kind of thought of them more serial 21 than in parallel, or either/or, that you would go 22 through each tier as you've shown them in a more 23 serial manner rather than in an optional manner; but 24 if it's a requirement, they're both going to apply.
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81 1 perceive this correctly.
2 MR. RECKLEY: It's probably more likely my 3 limitations as a graphic artist, I think, and we're 4 not as -- the previous version of this, for instance, 5 under Safety Functions, just -- they listed the same 6 functions.
7 And I tried through discussion to say that 8 under tier -- under the first tier, if controlling 9 heat removal was a required safety function, then that 10 -- then at least one means of controlling heat removal 11 was going to end up in safety-related and in tech 12 specs, for example, and it's being set out to make 13 sure the dose relays under 25 rem.
14 MEMBER KIRCHNER: Yeah.
15 MR. RECKLEY: I had the same list of 16 functions under the second tier, but tried to explain 17 that -- the functions are basically the same.
18 I mean, equipment is either -- it's doing 19 something like removing heat or controlling 20 reactivity, but the reason you would have a second 21 system for heat removal is because of its risk 22 significance, its importance in defense-in-depth, its 23 contribution to the PRA, et cetera.
24 So, you would have an additional piece of 25 equipment for heat removal, but I understand the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 1 discussion, then, was having the same functions listed 2 was confusing.
3 So, it's not easy to try to get this, at 4 least for me, try to show this, but that would be the 5 distinction.
6 So, if you're removing heat from a passive 7 reactor cavity cooling system under the first tier, 8 you might actually have some fans under the second 9 tier which, you know, you wouldn't want to rely on as 10 your primary means because now you have to power a 11 fan, but it might be a very good way to reduce the 12 overall risk by having a backup to the passive heat 13 removal system.
14 MEMBER KIRCHNER: And if I might, since 15 I've interrupted, under these required safety 16 functions, I would take a different attack than what 17 is listed here.
18 I like the first sub-bullet, of course.
19 That's the whole idea of preventing, you know, the 20 atmospheric release from your earlier diagram, but 21 control of heat generation, heat removal, chemical 22 interactions, that's going to be fairly design-23 specific.
24 At a more fundamental level, I would 25 assert that if it's an advanced reactor, you can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 maintain control reactivity and shut it down.
2 That, to me, is primary. It's the 3 fundamental thing about nuclear reactors from any 4 other power production system.
5 You want to control the integrity, as 6 designed, of the plant's fuel and inventory, and don't 7 you want to maintain the capability of those barriers 8 to mitigate -- prevent or mitigate the consequences?
9 So, I would assert that the three bullets; 10 control heat, regeneration removal, and the chemical 11 interactions, are more design features and that there 12 is a higher level of means to define the required 13 safety functions that I think would apply to almost 14 all reactors of any size and any fuel configuration, 15 including liquid fuel.
16 That's just -- but I'm concerned about the 17 absence of control of reactivity and the ability to 18 achieve a safe shutdown as a primary safety function.
19 That's just a member's opinion.
20 MR. RECKLEY: And it's good and we've 21 heard that in stakeholders -- I think we have a bullet 22 on that and we will get to it when we talk about the 23 feedback.
24 One of the reasons that we weight it out 25 the way we did in terms of these are examples of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 1 safety functions that are likely to come into play, is 2 because under the advance reactor construct that we're 3 trying to do for Part 53, in some -- since it's 4 technology-inclusive, in some reactors the actual 5 inventory -- or inventories that you have to look at 6 will vary.
7 And if there's a significant inventory in 8 waste gas, then the designer and licensees for that 9 design, where significant inventory is in waste gas, 10 will have to define the safety functions for the 11 retention of that inventory and reactivity may not be 12 a safety function for that inventory.
13 And so, we needed the -- the thought was 14 we needed the flexibility to have this rule address 15 all of the source -- all the inventories, 16 traditionally all the source terms and the safety 17 functions would be different for different 18 inventories. That was part of the logic.
19 MEMBER KIRCHNER: No, I agree with you.
20 And I would assert that you need to maintain the 21 control and integrity of the as-design configuration 22 of both the plant's fuel and its radionuclide 23 inventories, whatever they are.
24 So, if they're a liquid fuel system and 25 they're off-gassing and, you know, they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 accumulating fission product gases in some kind of 2 design vessel or something, that would, in my mind, be 3 part of a critical safety function, but that's 4 separate from control reactivity and shutdown.
5 MR. RECKLEY: Right.
6 MEMBER KIRCHNER: So, it may be -- in that 7 particular design that may be the most -- and this is 8 where the risk -- the PRA kind of analyses come in 9 that you may find that's your most -- that may be your 10 Achilles heel, so to speak, in terms of a contributor 11 to risk.
12 MEMBER REMPE: So, along that point I 13 really liked the approach you laid out in the prior 14 slide, Bill, and we discussed it, I think, in the 15 meeting we had a couple -- well, a month ago or 16 whenever.
17 But I also note that even in the existing 18 regulation the critical safety functions and guidance 19 documents are -- slide differently in different 20 existing literature that the staff has.
21 And a couple of weeks ago we had an 22 advanced reactor code meeting and they had gone with 23 a different layout than what you presented on the 24 prior slide.
25 And I like the -- this is the NRC and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 today you mentioned it tied to the Atomic Energy Act 2 about controlling radionuclide release and then 3 defining subsidiary goals that make sure you can 4 control radionuclide release. The applicant would 5 come in and the staff would agree with them.
6 And so, I think consistently giving that 7 picture might be a good approach. What do you think?
8 MR. RECKLEY: Yeah, I think that I agree, 9 if we can. And it is very similar -- I mean, even 10 this construct is basically the same as the general 11 design criteria layout from 1968, or whenever that 12 activity was undertaken, in terms of if you look at 13 how that is laid out, it's basically laid out in terms 14 of reactivity fluid systems, which is really heat 15 removal, and the retention of radionuclides through a 16 structure. So, I think we're largely consistent.
17 I do agree with you to the degree we can 18 start to always talk about it in the same terms that 19 would be beneficial.
20 CHAIRMAN BLEY: You know, I appreciate 21 your (audio interference) here. I'm hanging up on 22 several points.
23 One, it seems like we're working really 24 hard to retain something that kind of grew randomly 25 over the years in response to those challenges.
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87 1 Two, adequate protection is a legal 2 concept for minimizing the danger, I think I can 3 easier think of it as a scientific concept, but (audio 4 interference).
5 This picture that you gave us today works 6 better than the one you gave us a week ago, but it 7 still -- I have trouble keeping it -- putting it all 8 together and seeing -- even though I've read C and D, 9 whichever one you looked at last month, and along the 10 discussion you had with Walt, if you look at that 11 safety functions, required safety functions there in 12 the box, if one were to lay this out more logically I 13 think you could get closer. Of course you wouldn't 14 have this simpler presentation.
15 If you take this transcript and look at 16 your long discussion here for the last 10 minutes, 17 maybe that's the basis for trying to put together a 18 white paper and that would really help. If you're 19 laying out this logic and writing (audio interference) 20 pictures, you know, so people could see it and talk 21 about it, it would help.
22 MR. RECKLEY: Okay. Yes, it was a 23 suggestion last time and it's a good one. We will try 24 to do that.
25 I don't know what form it would be in. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 are going to have to explain this in the Statement of 2 Considerations and other documents that we need to 3 prepare.
4 And so, to a degree we start to work on 5 that, which we need to, such a white paper could be a 6 vehicle.
7 CHAIRMAN BLEY: Yeah. I think so because 8 I, you know, this is kind of a key to at least the 9 language and much of the rest and at least to me it's 10 -- I know you want to be able to reflect this back and 11 show that we're doing many of the same things, but it 12 -- if your basis in 53, and I think it mostly is, 13 risk-informed, then these kind of arbitrary 14 distinctions don't work too well for me, anyway, you 15 know. It's the extent of a particular system's impact 16 on meeting the overall station performance of 17 retaining the radionuclides that's the real key and 18 they seem artificial.
19 We can't solve it here, so -- we can't 20 solve it very well or help you with that, something 21 coherent written down to work from.
22 MR. RECKLEY: Yeah. And one of the key 23 things that -- it might be subtle, but one of the key 24 things that drives this structure, which was a 25 decision at some point to maintain, was safety-related NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 designation, Appendix B application, tech spec 2 control, that kind of a structure.
3 If you go back and, you know, we had these 4 discussions not recently, to be honest, because we had 5 them a long time ago and kind of internally decided on 6 this approach.
7 But if you go back -- and I know, Dennis, 8 you are very familiar, something like NUREG-1860 9 basically said let the risk-informed insights that you 10 get from the assessments determine what special 11 treatment is needed.
12 And special treatment can be graded and 13 you really may not need such things as the 14 designation, because you can let the system drive the 15 special treatment.
16 And that could include something all the 17 way to the application of NQA1 down to some graded 18 approach and not have these designations built in.
19 We did decide, for good or bad, that we 20 were going to keep this structure with safety-related 21 designations and application of the high level quality 22 assurance in NQA1, Appendix B. And that is really 23 driving, to a large degree, this structure in the 24 tiers.
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90 1 see that and, again, that can be a point of discussion 2 as we go through the iterations.
3 CHAIRMAN BLEY: I think so far some of 4 these things aren't separable. Tech specs are in the 5 first tier, but special treatment, which is laid out 6 in the tech specs, is second tier.
7 I mean, I just -- I have trouble feeling 8 this -- the real separability of these things.
9 MEMBER KIRCHNER: Dennis, if I might, I 10 have the same problem, Bill. That's why I suggested 11 something a little more serial.
12 I mean, going back to just your comments, 13 you know, the whole idea of risk-informed and such as 14 a top-level approach would suggest that the -- let me 15 just -- not to rebuild your viewgraph in real-time, 16 but give you an example in my own limited mind about 17 how I would approach this, the control of frequency in 18 consequences rather than being in second tier, I would 19 have it up at the top of the first tier above normal 20 operations. And then you go, you get normal 21 operations, unplanned events and so on.
22 And likewise, to me, having defense-in-23 depth in the second tier just, as a former designer, 24 is just anathema to me. I mean, defense-in-depth 25 ought to be built into these safety functions. So, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 that's what I meant be "serial."
2 Just as Dennis said, you would have tech 3 specs and then special treatment and license programs 4 would be part of the design features and programmatic 5 controls it.
6 I don't want -- I'm just not convinced you 7 need the second tier to address 182 and 161 and then 8 trying to split them to line up with each of those 9 raise, at least for me, some artificialities of what 10 you really intend, which is a more holistic approach 11 rather than an either/or kind of set of buckets to 12 work through.
13 CHAIRMAN BLEY: Maybe your next slide will 14 help us some.
15 MR. CORRADINI: Bill, can I ask one -- a 16 different question, though, because, Bill, you used an 17 example that I thought was interesting.
18 You said that if I had the reactor to be 19 small enough thermal output, then perhaps what you 20 define as "first tier" would automatically mean that, 21 and the only thing that would be controlling is what 22 you call "second tier." That implies that everything 23 fits in the same -- under the same umbrella.
24 Could you not have a parallel path that if 25 something -- if some design is small enough -- I don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 even know what "small" is, but is small enough that 2 you would actually have a more restrictive 3 categorization kind of like the NPUF rule that you 4 have only allowable releases of 1 rem offsite.
5 And, therefore, with small machines, 6 whatever "small" is, you have a more deterministic 7 approach, but it's much simpler.
8 I'm -- what's troubling me is -- and, 9 again, I said this last time, but I'll just repeat 10 briefly, this -- as the size of the design gets 11 smaller, this becomes a really complicated overload of 12 regulation on something that ought to be very simple.
13 So, I guess I was asking -- there might be 14 a parallel way to do this if something -- if somebody 15 can -- and the parallel way might actually be more 16 restrictive.
17 It might be -- or essentially the second 18 tier might be the restrictive tier to do the 19 regulation upon.
20 I'm using the NPUF rule as an example 21 because -- I am not even sure if it's been approved 22 yet by the Commission.
23 But when we reviewed that a few years ago, 24 that essentially looked upon things in a manner that 25 was more deterministic.
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93 1 MR. RECKLEY: Yeah, for the decisions that 2 were being made under that rule, but -- yeah, as we 3 get into this next design and analysis, let's -- I 4 think we'll revisit this again and again. So, I --
5 your comment, Mike, is one we're hearing from others 6 as well.
7 I would caution that if you go back to the 8 integrated slide, even the 1 rem number is for 9 evacuation, right?
10 And so, you have to look at what the 11 safety margins are being applied to to see even what 12 the right dose number might be if it was to be used as 13 a criterion.
14 And as we talk about -- and this might be 15 today or definitely in future meetings -- what is the 16 flexibility that people foresee if you want to focus 17 in on micro-reactors, there is an argument to be had 18 that the relaxations that are being sought in a whole 19 host of areas for those -- the possible deployment of 20 micro-reactors puts even additional onus on making 21 sure the design is to the highest standard that a 22 systematic approach, whether it be PRA or some other 23 systematic approach, has made very clear that the 24 risks are appropriate because the deployment models go 25 beyond and we may not need to evacuate the local NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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94 1 population. It goes even further than those potential 2 relaxations.
3 So, we get into that, I think, in the next 4 section. Let's go on, if we can, to slide 21 and 5 we'll talk about some of the feedback, which is 6 similar to the feedback we're getting here.
7 Let's start with the first bullet. Some 8 people say get rid of the second tier. The thing we 9 heard last time was -- from ACRS committee members 10 was, again, clarify the two tiers. We continually 11 hear them on this.
12 Going forward we hope to clarify it.
13 You'll see language in a few weeks when we release an 14 iteration.
15 But, as I mentioned, our expectation is 16 right now in order to make this differentiation 17 between the regulatory treatment across all of the 18 subparts, we continue to grasp onto this concept and 19 maybe want to give it one more shot in the next 20 iteration to see if we can provide additional 21 explanation and understanding of that.
22 Go ahead, Dennis.
23 CHAIRMAN BLEY: One thing that does come 24 together for me, but you know, see how it relates to 25 the discussion in the proposed rule (audio NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 1 interference) today, and it eludes me a little bit, is 2 the distinction that we see in Part 52 with Tier 1 3 being the fixed things that you essentially have to 4 (audio interference) change to -- to the license to 5 change. And Tier 2 still requires things you have to 6 have that using your tools of this management at the 7 plant you can change on your own, subject to the 8 inspection looking, you know, later by the staff.
9 That makes sense to me, but I -- I'll 10 leave it at that.
11 MR. RECKLEY: Okay. And, again, we think 12 that would hopefully -- we're hoping, as we build this 13 out, that that construct would stay and that what we 14 call the "first tier" would align with Tier 1.
15 If there's something that is keeping the 16 dose less than 25 rem and the licensee is proposing to 17 make a change to it, that would require prior NRC 18 approval. And we get into this in the Operations 19 section.
20 If it is less than that, for instance, it 21 is some of the equipment or programs that are aimed 22 primarily, let's say, at beyond design-basis events 23 and meeting the QHOs, then the applicant would have 24 the ability to change those on their own and include 25 them in an update. So, that general construct, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 1 think, will stay.
2 We have to, as we work and put all the 3 pieces together, see if it does, but the initial 4 thinking is that it -- that construct you've described 5 should stay.
6 CHAIRMAN BLEY: Right. And this is 7 something you can't see now. If you did follow the 8 LMP and you came up with your licensing basis events, 9 those high consequence, higher frequency, the things 10 that under our current thinking might be beyond 11 design-basis would no longer be because they would 12 shift into the design-basis events that are covered 13 under Tier 1.
14 We kind of missed that here because we're 15 not seeing a practical application with this.
16 MR. RECKLEY: True. True. So, going 17 under that third sub-bullet there under the second 18 tier, there's some discussion of even if you keep two 19 tiers, whether the health objectives are the 20 appropriate metric, and some discussion about maybe 21 the development of an alternative metric to it -- to 22 the QHOs; or even if the QHOs are included, whether 23 they are put into the terms of the specific numbers of 24 the frequencies that we used in the first iteration.
25 So, again, one of the comments that we've received.
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97 1 We do -- and this is similar, I think, to 2 the comment from Walt -- have a comment that as 3 opposed to saying the applicant is required to 4 identify the fundamental -- to identify safety 5 functions, to actually include the fundamental safety 6 functions, the ones we've been talking about, into the 7 rule proper, again, we're reiterating on that.
8 One of the things that goes into our 9 thinking, I mentioned one already, the need to address 10 inventories or source terms within the plant that are 11 different than the reactor core.
12 And then the other possible wrinkle is 13 that we're still holding open the possibility that 14 fusion energy systems would be also addressed within 15 Part 53.
16 And they would obviously have different 17 safety functions supporting the retention of 18 radionuclides within that type of a facility.
19 So, if we go down then to slide 22, one of 20 the big comments from our last meeting is the 21 potential to address chemical hazards or non-22 radiological hazards. That was a good comment. We 23 currently have that under review looking at fuel cycle 24 facilities and other areas to determine how we would 25 address non-radiological hazards.
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98 1 Another comment from external stakeholders 2 was to do away with, as well as reasonably achievable, 3 requirements in Part 53 and our reference to them in 4 Part 20.
5 Some members in our last discussion with 6 this subcommittee actually expressed the view to keep 7 ALARA. We're working on that iteration.
8 But for now, given the long history of 9 including "as well as reasonably achievable" in our 10 regulatory structure, our leaning is to maintain it.
11 MEMBER PETTI: So, Bill, I don't remember 12 -- recall reading the industry comments on that. To 13 me, one of the arguments for leaving it is that the 14 greatest risk for some of these facilities may be to 15 the workers themselves and less to the public.
16 And so, this allows at least a focus 17 there, you know, to recognize that it -- that -- a 18 distribution of risk, if you will, is different and 19 this gives it that high-level visibility.
20 MR. RECKLEY: And I know it's been, you 21 know, we summarize things here. Even the ALARA 22 discussion varies between stakeholders and what they 23 have proposed.
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99 1 and where and how it's captured in the regulations.
2 MEMBER PETTI: So, help me understand 3 that. Is there -- I mean, is there subtlety in the 4 legal sense? If it's in, you know, a different part 5 of a rule, they have to in Part 20?
6 I saw that later but they said, oh, 7 they're not throwing away ALARA. They just don't want 8 it over here. It's okay to be over there.
9 I mean, tactically, does that change 10 something?
11 MR. RECKLEY: It has a potential, I think.
12 When we included it in Subpart B as kind of a primary 13 factor to consider and then something we would carry 14 through all of the subparts, one of the areas of 15 concern was the degree to which ALARA is then brought 16 into the design process. And a designer would be held 17 to showing how the design meets an ALARA concept.
18 So, it is tricky in that something like 19 ALARA is accomplished by all the things we continually 20 put together in our discussions.
21 It's part of the design, it's part of 22 programmatic controls, and it's even part of the human 23 element associated with operations.
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100 1 features needs to support ALARA, there is a concern 2 about how that would be implemented.
3 So, I understand where the concern is 4 coming from. I don't have a perfect solution to that 5 concern.
6 But from my perspective, as you've 7 mentioned, both in terms of occupational and public 8 releases, as well as reasonably achievable, the design 9 process has always been an element.
10 So, I -- how this would actually work, I 11 mean, we -- when we're interacting with stakeholders, 12 you have to -- and I would do the same if I were in 13 their boat. They have to not only look at what the 14 requirement is, but how might it be interpreted, how 15 might an inspector look at them and say, show me where 16 you meet this requirement. So, that's part of the 17 concern.
18 Then the last bullet, protection of plant 19 workers. Again, there was some concern about having 20 it up in Subpart B as kind of a primary objective of 21 the whole Part 53 effort.
22 And there was also some concern that we 23 were cutting and pasting and potentially paraphrasing 24 things from Part 20.
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101 1 protection of plant workers much along the lines, 2 Dave, as you were mentioning. It's always been 3 important.
4 For some designs the -- and actually even 5 for existing plants if you look up societal dose, 6 protection of the workers are probably higher than the 7 public. That will be even more so potentially for 8 some designs.
9 So, we're proposing to keep it and -- but, 10 to avoid confusion, we can refer to Part 20 as opposed 11 to paraphrasing.
12 So, that is the feedback we've received on 13 Subpart B. If you want to stay here for a second or 14 we can jump into how this gets reflected in the design 15 and analysis subpart.
16 MEMBER KIRCHNER: Just a quick, minor 17 point, Bill. This is Walt Kirchner.
18 When chemical releases, there is the 19 distinct possibility of having mixed releases with 20 some designs, and that makes things like your earlier 21 diagram in terms of returning the fission product 22 barriers and overall meeting the safety objectives 23 perhaps much more difficult.
24 So, it's just not chemical releases as a 25 chemical release. There's the distinct possibility of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 1 mixed releases and then interaction of the chemicals 2 with the environment or -- that would be of concern, 3 fire and other hazards.
4 MR. RECKLEY: Okay. Yes, thank you.
5 Yeah. And, again, we're looking --
6 MEMBER KIRCHNER: I wasn't trying to make 7 this more complicated --
8 MR. RECKLEY: Right. No.
9 MEMBER KIRCHNER: -- but if it's a 10 chemical that's carrying a fuel, that becomes a much 11 more difficult proposition.
12 MR. RECKLEY: Right. And you're looking 13 at both the radiological toxicity and the chemical 14 toxicity and, yeah, it's more complicated across the 15 board.
16 So, we are looking at, again, using the 17 fuel cycle facilities that face some of these 18 challenges as well.
19 It might be -- or probably will be more 20 complicated, in a reactor sense, because you have a 21 wider set of radionuclides involved and you have at 22 least, depending on some designs, a wider set of 23 chemical hazards involved. And then, as Walt just 24 brought up, the potential mixing of the two. So, as 25 if we didn't have enough on the plate, but we agree NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 1 that it needs to be addressed.
2 So, any other mentions or we're starting 3 on Subpart C?
4 (Pause.)
5 MR. RECKLEY: Let's go on, then, to slide 6 23. Okay. All we're setting up here is its context 7 in the general layout of our Part 53 structure.
8 We go on then to 24, just a -- kind of a 9 preview of what we'll be discussing. This is the 10 sections as they're currently laid out, the overall 11 design objectives, the design criteria for meeting the 12 first tier safety criteria, meeting the second tier 13 safety criteria, currently have a criteria for 14 protection of plant workers and, in this version, some 15 related design requirements. Then we get into the 16 analysis section, the categorization and special 17 treatment of equipment.
18 Going on then to slide 25. This, I think, 19 will be an area where we can have some really 20 meaningful discussion.
21 The application of analytical safety 22 margins to operational flexibilities, and this really 23 relates to some of the discussions we've already been 24 having in the relationship to micro-reactors in 25 particular, perhaps, in terms of simplifying possible NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 1 approaches and so forth in design, quality assurances 2 related to design, and then some interface activities.
3 So, before we get in, I just -- it might 4 be subtle, but the kind of language that we're using 5 here as we go down in terms of level of detail is 6 we're starting off with the safety criteria.
7 We talked about those under Subpart B.
8 Those are currently in the iterations, the 25 rem 9 number from 50.34 and the QHOs for the second tier.
10 So, those are the safety criteria.
11 Then we say under Subpart B, you have to 12 identify safety functions to meet those criteria.
13 Then we say you need to identify design features, 14 human actions and programmatic controls to meet the 15 safety functions.
16 So, if the safety function is heat 17 removal, a design feature might be the reactor cavity 18 cooling system.
19 And then you would have human actions and 20 programmatic controls to meet that to support that 21 design feature.
22 The next level down and what we start to 23 talk about under this section, Subpart C, Design and 24 Analysis, we introduce the term "functional design 25 criteria," which is to take the design feature that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 1 being used to support a safety function and actually 2 laying out what characteristics does that design 3 feature need to perform its job.
4 So, that's kind of the language we used.
5 I know it can get lost in the discussion. So, I 6 thought I would start off with at least trying to say 7 this is how we're using these terms.
8 MEMBER BROWN: Bill, what slide are you 9 on? I've got -- you're on 24; aren't you?
10 MR. RECKLEY: Actually, I was just laying 11 that out before we go on to --
12 MEMBER BROWN: Oh, I'm sorry.
13 MR. RECKLEY: -- the next discussion.
14 MEMBER BROWN: Alright. Thank you.
15 MR. RECKLEY: So, it's just kind of 16 background. Yeah, sorry. I should have had that on 17 a slide, but I didn't have that structure.
18 But even in the table of contents you're 19 seeing things like "functional design criteria" -- or 20 the "functional design criteria," that's the 21 terminology we use. So, sorry about that, Charlie.
22 If we go down, then I guess we can get 23 into the first specific subpart section, which is 400, 24 on the design objectives for this subpart.
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106 1 terms, saying the objective of this section, or 2 subpart, is to establish the overall design 3 objectives, tying them back to the safety criteria and 4 the identification of safety functions from Subpart B; 5 and to require that the design features that are 6 identified, when combined with the associated 7 programmatic controls, provide reasonable assurance 8 that the safety criteria, either the tier -- first 9 tier or second tier safety criteria are met.
10 And we'll talk about that as we talk about 11 the specific sections. So, that's the overall 12 objective of this subpart.
13 We go down then next to 410. This is --
14 maybe this would have been a better place to have the 15 discussion I was having on the terminology, but this 16 then -- Sections 410 and 420 are basically requiring 17 that functional design criteria be established for 18 those design features.
19 So, this is going to be things like heat 20 removal rates and, you know, the actual things that 21 are needed to define what a design criteria -- what a 22 design feature needs to have in order to fulfill its 23 function.
24 MEMBER BROWN: Bill?
25 MR. RECKLEY: Yes, Charlie.
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107 1 MEMBER BROWN: 410 -- this is a question 2 on terminology that I got lost on when I was looking 3 at it.
4 410 starts the title "Functional Design 5 Criteria for First Tier Safety Criteria." Then A is 6 "Functional Design Criteria," virtually a repetition 7 and you go through the rest of it.
8 In 420, you say "functional design 9 criteria for second tier safety," but you start off 10 with "design features."
11 Is there a distinction between first tier 12 and second tier that you don't need "functional design 13 criteria" down in the text?
14 You switched over the terminology of 15 "design features" whereas you used in A and B of 410 16 "functional design criteria" within the A and B 17 itself, and I was wondering if there is a distinction 18 that I lost.
19 MR. RECKLEY: It might be an inconsistent 20 way we've laid these out, which would be -- you know, 21 we will take that comment and look for consistency, 22 but 420 does require, later in the paragraph, for 23 functional design criteria to be defined for each 24 design feature used to meet the second tier.
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108 1 out, that we didn't keep the same sentence structure, 2 but the intent is it's the same.
3 MEMBER BROWN: I just -- if you look at 4 410, Item A says, functional design criteria must be 5 defined for each design feature.
6 420 doesn't start off by saying, 7 functional design criteria must be provided for each 8 design feature. It -- the terminology is just flipped 9 around. That's all I -- we ought to be consistent.
10 I'm just hoping I didn't lose the 11 technical understanding. That's what I was worried 12 about.
13 MR. RECKLEY: Yeah. I mean, for example, 14 under 420 B, but we don't do it until the middle of 15 the paragraph, we do say, functional design criteria 16 must be defined for each design feature relied on to 17 demonstrate compliance with the second tier safety 18 group.
19 MEMBER BROWN: I got it.
20 MR. RECKLEY: But your point is well 21 taken. By having them in different places, it can be 22 confusing. So, we'll look at that.
23 The intent was the same. We may have --
24 it's just the way we did the sentence structure.
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109 1 are things you put in place to meet functional design 2 criteria and it seems like the first tier just 3 reversed the way we were operating them.
4 So, that's all I -- I'll stop and you can 5 deal with that.
6 MR. RECKLEY: Yeah. We will look at the 7 language. Thank you.
8 CHAIRMAN BLEY: Can I get in a chance to 9 --
10 MR. RECKLEY: No, no. That's fine.
11 CHAIRMAN BLEY: In Subpart B, or in any of 12 the other subparts, do you anywhere lay out the thing 13 you told us earlier that Tier 1 are things you have 14 made a -- a change to the licensing basis to change, 15 and Tier 2 are things that could be done by the 16 licensee.
17 MR. RECKLEY: What you are seeing -- not 18 yet. That will get reflected in the future subparts 19 like on licensing and the control of licensing and 20 even, to some degree, under operations.
21 CHAIRMAN BLEY: Okay.
22 MEMBER BROWN: Yeah, Dennis, I did not 23 equate the second tier to the Part 52 Tier 1 and Tier 24 2 they way you said it.
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110 1 but I think Bill's made clear that's the intent.
2 MEMBER BROWN: Okay. That might ought to 3 be -- hopefully it should be reflected earlier rather 4 than later because I thought this Tier 2 stuff here in 5 Part 53 was like Tier 1 stuff, but just of a little 6 lesser importance, but didn't allow the applicant to 7 change it on his own.
8 That was the way I read this, so I lost 9 that distinction.
10 CHAIRMAN BLEY: The other thing I was 11 going to ask, because I think I heard this, there 12 isn't a distinction between Tier 1 and Tier 2 that 13 Tier 1 you have to do, Tier 2 you ought to do. These 14 are all requirements that have a different level of, 15 maybe, oversight.
16 MR. RECKLEY: That's right.
17 MR. CORRADINI: But the oversight is not 18 specified here.
19 MR. RECKLEY: Yeah. And that's the 20 difficulty of trying to -- in my novel analogy, trust 21 me, we'll get to that in Chapter 8. You're looking at 22 Chapter 2.
23 MEMBER BROWN: Yeah, but why shouldn't 24 Part B make that distinction since it's the overall 25 safety objectives?
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111 1 Why shouldn't that make the distinction 2 between first tier and second tier the way you just 3 phrased it?
4 MR. RECKLEY: Again, once we put it all 5 together, hopefully it will be -- people will be able 6 to see it in total and understand how the pieces fit 7 together.
8 But once we do that, if it makes more 9 sense from a clarity standpoint to have some of this 10 discussion under Subpart B, we can certainly look at 11 that.
12 But, again, the thinking was that you 13 start off at this high level and you make everything 14 consistent with it and hopefully when we get into the 15 licensing area, we can remain consistent, but it all 16 derives from these higher level principles.
17 And so, the licensing process is -- would 18 be driven by its relation to this higher level 19 discussion, not the other way around, was what we were 20 hoping.
21 CHAIRMAN BLEY: So, we're not doing 22 Subpart B today, but one last comment on that.
23 MR. RECKLEY: Yes.
24 CHAIRMAN BLEY: The thing that got me 25 started off wrong, if you will, is 53.22, the safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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112 1 functions when we read that and then immediately go 2 into first tier safety criteria and it felt like there 3 should be a link between the safety functions and the 4 two tiers of safety criteria, but there are not. And 5 that really set me astray, I think.
6 MR. RECKLEY: Okay. And, again, it's a 7 challenge to put this together. To be honest, one of 8 the things that we did do is switch around the order.
9 So, safety functions now follow the design criteria --
10 the first tier/second tier safety criteria.
11 (Simultaneous speaking.)
12 MR. RECKLEY: I know. So, let me see.
13 MEMBER BROWN: As opposed to Dennis making 14 the last comment in that relation, when I go back and 15 I look at Part B, I hate to say this, when you talk 16 about the first tier safety criteria, they all seem to 17 be firmly rooted in limiting things to, like, the 0.1 18 rem for this or the 25 rem for that, et cetera, et 19 cetera. That's in the first tier.
20 When you get to the second tier in Part B, 21 it starts -- it talks about those same things.
22 However, you throw in the "as well as reasonably 23 achievable" and you throw in -- well, maybe the 24 economics get thrown into this and you may not have to 25 do anything if it costs too much.
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113 1 That seemed to be a really big difference 2 between Tier 1 and 2 -- the second tier and first tier 3 in Part B.
4 And it makes -- it certainly makes the 5 second tier safety criteria seem, well, if it costs 6 too much, they're not important. I'll leave you with 7 that for future --
8 MR. RECKLEY: And in terms of the normal 9 operations, that is clear because the whole discussion 10 of ALARA includes a cost element.
11 So, that's --
12 MEMBER BROWN: I got that. It's just --
13 MR. RECKLEY: -- and that's intentional 14 and that is the flexibility that is provided by the 15 two tiers. We've been talking about what's the 16 difference. That is -- it's a large difference.
17 The numbers are lower, the performance 18 goals are significantly lower than 100 millirem, but 19 it also includes the ability to consider costs in the 20 assessment.
21 And that is generally aligning with the 22 whole concept of adequate protection, which means you 23 have to provide it and we don't care how much it 24 costs.
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114 1 different part of the Atomic Energy Act and that part 2 of the act that we've traditionally employed primarily 3 for backfit analysis where a risk threshold and 4 considering cost implications are allowed.
5 So, again, I think it fits not only within 6 Part 53, but it fits with how we've generally operated 7 over the years.
8 MEMBER BROWN: Well, my only thought if I 9 had -- 53.200 talks about safety objectives. That 10 paragraph would have been ideal at the end if you had 11 said, within that we've established two tiers; one 12 like this and the other one with the ALARA, et cetera, 13 et cetera. So it -- instead of having to root it out, 14 that's all.
15 MR. RECKLEY: Okay.
16 MEMBER BROWN: It's tough to figure it out 17 as opposed to having a quick statement of how you've 18 divided it up.
19 You divided it up by having the two 20 separate sections and hopefully people can figure out 21 what the difference is.
22 I'll quit now. I'm sorry.
23 MR. RECKLEY: No, no, no, you know, 24 clarity is the goal here. And so, these kind of 25 observations on how we might structure it -- and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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115 1 discussions like this where we're not really changing 2 what the technical requirements might be, but just 3 trying to make them more clear are good comments.
4 So, we will go back and look at how we 5 would put this together.
6 MEMBER BROWN: Okay. I am not objecting 7 to the approach. This is just a matter of 8 understanding it.
9 Until we had it today, I didn't quite put 10 all that together until I went back again and reread 11 Part B again.
12 MR. RECKLEY: Okay.
13 MEMBER BROWN: It just took me a while.
14 MR. RECKLEY: Okay.
15 MEMBER PETTI: I think the thing that I'm 16 taking away is if -- I know it's hard. This is worse 17 than writing a novel -- is to somehow embed succinctly 18 a rationale in the rule without it getting, you know, 19 overly wordy.
20 Because that's what people are tripping on 21 because there's not a rationale that they can easily 22 access to understand, you know, why the flow is the 23 way the flow is.
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116 1 was probably the most succinct way that I hear about 2 it relative to there is a risk threshold and a cost 3 threshold for the second tier requirements that don't 4 exist for the first tier. At least that's what I 5 heard you say.
6 MEMBER BROWN: That's excellent, Mike.
7 Thank you. Bill's explanation then was very clear.
8 Put it in Part B 53.200.
9 MR. RECKLEY: Okay. Thank goodness you 10 guys take transcripts. We'll go back to see how that 11 was said and we'll try to do better.
12 So, the note here was turning also to --
13 just to point out there are parallel activities and, 14 at some point, your subcommittee will start to hear 15 about these other activities like the technology-16 inclusive content application and advanced reactor 17 content application, two very similar activities, that 18 are looking to address not only the traditional 19 content of application, but also where we might 20 improve in terms of performance-based approaches to 21 regulation.
22 And the reason that's brought up on this 23 slide is historically one of the areas of concern is 24 how much of the initial licensing review is associated 25 with things like ALARA and the design aspect in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 1 conformance with -- to Appendix I of Part 50 and so 2 forth.
3 And we are thinking and developing some 4 guidance, there's actually even been draft language 5 put out, in terms of content of application where some 6 of this can adopt a more performance-based approach 7 and move some of the review from the initial design to 8 a performance-based element.
9 So, it is just a note that there's other 10 activities underway and that note is especially as it 11 relates to ALARA in the first sub-bullet of the second 12 tier. So, with that, I think we can go to slide 28.
13 MEMBER PETTI: Just a question on 27.
14 MR. RECKLEY: Yes.
15 MEMBER PETTI: I'm struggling with just 16 the English, "design features and functional design 17 criteria are determined through analysis."
18 Are you meaning that the design features 19 are validated that they meet the functional design 20 criteria, analysis is used to validate the design 21 features meet the functional design criteria?
22 MR. RECKLEY: Oh, thanks, Dave. Actually 23 that's a -- I was trying to make a distinction in both 24 for the first tier and the second tier that for normal 25 operations ultimately you can have a performance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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118 1 measure actually related to the release of effluence.
2 And, from a regulatory perspective, we can 3 come back and say we didn't look at your design in as 4 much detail as we may have historically, but we can 5 tell right away you're not meeting the performance 6 goals set out -- apparently set out in Appendix I to 7 Part 50, which is, you know, a couple millirem per 8 year.
9 Therefore, there's a performance-based 10 approach that can be taken for normal ops and showing 11 that you meet the 25 rem number or the QHOs, that's 12 done by analysis.
13 You can bring in performance-based 14 elements, but that it's not, per se, a measurable 15 parameter. It's you're showing compliance through the 16 analysis that you do.
17 Is that more clear?
18 MEMBER PETTI: Okay. And then just the 19 second question on the functional design criteria. In 20 some guidance, you'd point them potentially to the 21 advanced reactor design criteria as examples of 22 criteria that are associated with safety functions?
23 MR. RECKLEY: Yeah. They could bring in 24 Reg Guide 1.232 as an example of how they are meeting 25 safety functions.
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119 1 And the advanced reactor design criteria 2 does go a little beyond design functions and starts to 3 talk about design features and even functional design 4 criteria. So, the -- but that -- so, yes, they could 5 refer to that.
6 We haven't looked exactly where the ARDC 7 -- how far they go in terms of the functional design 8 criteria. That's a -- it's a good observation.
9 We'll go back and look to see if the -- at 10 what level does the ARDC go down to.
11 MEMBER PETTI: Alright.
12 MR. RECKLEY: Okay.
13 CHAIRMAN BLEY: Bill?
14 MR. RECKLEY: Yes, Dennis.
15 CHAIRMAN BLEY: To me, it feels like we're 16 just back from the break, but I expect many of you 17 back on the east coast are ready for lunch and this is 18 where we had it scheduled.
19 Although we were just really getting into 20 Subpart C, we are (audio interference) slides at this 21 point. So, this could be a good place.
22 If anybody wants to say anything about 23 that, do it. Otherwise, I'm going to declare a lunch 24 break now.
25 (Pause.)
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120 1 CHAIRMAN BLEY: We're going to recess for 2 lunch for one hour. Be back at five after 12:00 here, 3 five after 2:00 out where those of you in the east 4 are. We are now in recess.
5 (Whereupon, the above-entitled matter went 6 off the record at 1:06 p.m. and resumed at 2:05 p.m.)
7 CHAIRMAN BLEY: Okay. We are now back in 8 session. I've heard from one member, so I know we 9 have a quorum for the subcommittee.
10 Bill, before I turn it back to you, two 11 quick questions. One for now, and one for two slides 12 from now.
13 The first one is Ron said you had found 14 that old DOE paper. If you have something more recent 15 that you folks are hanging your hat on, or something 16 you've written, we'd be interested in seeing that.
17 And the other one, you know, the 18 functional design -- I'm sorry, the design 19 requirements of Section 440, there's a way that I 20 think I've seen elsewhere and it seems odd to me a 21 little, but maybe it's common, that says the system 22 shall be designed using generally accepted consensus 23 codes and standards wherever applicable.
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121 1 say, well, it doesn't apply.
2 So, on those two things, I'll turn it back 3 to you. Whenever it's convenient, maybe you can 4 address them.
5 Bill?
6 MR. RECKLEY: Thank you, Dennis. Yeah, 7 I'll get to that when we talk on the consensus codes 8 and standards.
9 I'll look for the DOE handbook. It seems 10 like that's the general time frame back in 2012, I 11 think, or whatever edition that was.
12 We can talk later. Something else out of 13 the general construct of the DOE orders handbook and 14 standards that we had raised to stakeholders actually 15 in the first meetings when we were talking about the 16 design criteria, that we still are searching to see if 17 it might have a role, is the use in the DOE 18 terminology and approach of a new mitigated event and 19 whether that might be a vehicle to, I think, as Mike 20 Corradini and others have suggested, it may be as a 21 way to greatly simplify matters in the DOE approach.
22 And it's been reflected in seismic design 23 criteria and in ANS 2.26 as well that if you can do an 24 unmitigated event and show it is below certain 25 thresholds, then you can, in the seismic design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 category, take that into account in both your design 2 of the structure and even what seismic hazard to 3 consider and we're still trying to toy with that.
4 Part of the issue and, again, this is 5 where if there's anybody with knowledge otherwise, 6 part of our hesitancy in exploring that further is we 7 have not seen any literature that even micro-reacttors 8 would show that an unmitigated event would be below 9 the thresholds that people are interested in, whether 10 it be the 1 rem number, or perhaps even lower, 11 depending on what relief they're seeking.
12 But I'll just drop that as a bug and if 13 anybody has insights, we'll probably come to a point 14 in a couple slides from now where that might be 15 brought into the discussion.
16 So, we've talked about this slide. Again, 17 the requirement being to come up with the functional 18 design criteria for any design feature for the 19 unplanned events for both the first tier and the 20 second tier.
21 So, in our first iteration that was 22 released, we kept -- or we had a design requirement in 23 this subpart to look at the protection of plant 24 workers in both the Part 20 upper limits, firm limits, 25 and then also the ALARA requirements in Part 20.
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123 1 As the note says, there's been some 2 discussion from stakeholders. We have slides at the 3 end of this subpart.
4 And, I'm sorry, Dennis, one thing I did 5 want to mention, the siting subpart is less 6 complicated an actually has fewer exchanges. And so, 7 the time we have allotted for that is probably more 8 generous than it needs to be.
9 And so, if it's okay, I think we can 10 extend this design and analysis discussion a little 11 past the agenda time frame because we can make up for 12 it in the siting subpart.
13 CHAIRMAN BLEY: Yeah. That's what it 14 looked to me as well. So, okay.
15 MR. RECKLEY: So, as I mentioned here, 16 there has been some stakeholder feedback on whether we 17 include the protection of plant workers and how much 18 it's included within the design requirements that 19 we've defined. So, that will be a matter we can 20 discuss as we go into future iterations.
21 MEMBER KIRCHNER: Bill, this is Walt 22 Kirchner.
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124 1 for protection of plant workers seems to make sense 2 here to me at this point in terms of flushing out 3 design criteria.
4 I'm tempted to ask, or just make a note, 5 that this recent event at NIST, which I have to admit 6 I'm not well-informed on, but where workers evidently 7 were exposed, would suggest that this kind of criteria 8 belongs here.
9 MEMBER PETTI: So, yeah, my concern --
10 we've struggled with this in the fusion program.
11 Tritium control in a fusion mission, or any mission, 12 has a lot of tritium. You could do it with bubble 13 suits or you can put glove boxes around lots of 14 equipment. One is an administrative sort of control, 15 the other is an engineering design control.
16 And the push was obviously for the 17 engineering design control. Yes, it costs more money, 18 but it was a surer way to protect the LOCAs. And 19 given the inventories involved, just the historical 20 precedence at Savannah River and other places that 21 dealt with tritium was that that's what we should do, 22 but putting it here makes me think about an 23 engineering solution instead of purely an 24 administrative solution. So, I think it's correct 25 there.
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125 1 MR. RECKLEY: Okay. Thank you.
2 MEMBER KIRCHNER: It's also consistent 3 with the past advanced reactor policy statements 4 where, you know, less reliance on programmatic 5 administrative controls and more reliance on, you 6 know, design features is one of my take-aways from the 7 advanced reactor policy statements.
8 MR. RECKLEY: Thank you, Walt. That's 9 just what I was about to also observe that it is 10 consistent with the overall agency position that it's 11 best to do it in the design process as opposed to rely 12 on programmatic or human actions in other areas. So, 13 again, we're considering this both in wording and the 14 overall resolution of public comments.
15 We can go on to slide 29.
16 CHAIRMAN BLEY: Bill?
17 MR. RECKLEY: Yes, Dennis.
18 CHAIRMAN BLEY: I agree with my colleagues 19 on this one (audio interference) operating in a 20 facility or (audio interference) performance (audio 21 interference) administrative controls that are (audio 22 interference) source of problems that (audio 23 interference).
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126 1 a letter from the Committee was necessary until we get 2 (audio interference). But if there are any areas, 3 this one just pops in my head, where a letter would be 4 useful, we can always do that. So, go ahead.
5 MR. RECKLEY: Okay. And, you know, there 6 will be decision points throughout the process. Like 7 I said, we're preparing our next iteration that will 8 include some changes to both Subparts B and C, and in 9 some areas a conscious decision not to make changes.
10 And then we'll see what, you know, what 11 the feedback is from stakeholders both external, ACRS, 12 and then also we have to run all this through 13 internal.
14 So, there may be points where a position 15 needs to, you know, a flag needs to be planted or 16 whatever.
17 I think the next iteration in the 18 discussions right after that would be -- would 19 probably be the point for that.
20 And this slide, Section 440, goes to 21 Dennis' question about the language of design features 22 used in generally accepted consensus codes and 23 standards and, you're right, in the language we say 24 "where applicable."
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127 1 put that in is, in some cases, there may not be 2 consensus codes in standards or an applicant might 3 choose not to use them.
4 In which case, they would have to make a 5 -- they would have to make all of the arguments that 6 would otherwise be resolved through the referencing of 7 the consensus code and standard.
8 But the primary reason we put in "wherever 9 applicable," at least for my first draft, was there 10 will be plenty of places where -- for advanced reactor 11 design to at least for some number of years there may 12 not be consensus codes and standards available.
13 CHAIRMAN BLEY: I suggest we use more 14 explicit language so it's clear what you mean.
15 MR. RECKLEY: Okay. We'll look at that.
16 MEMBER BROWN: I have another comment on 17 that.
18 We talk about consensus codes and 19 standards. Is that inclusive of current NRC Reg 20 Guides, interim staff guidance, branch technical 21 positions, et cetera, like that or this is in the 22 stuff segueing in from the commercial world?
23 It seems to me kind of -- I mean, in my 24 particular area, the I&C has -- you're going to need 25 instrumentation, going to need controls, you're going NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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128 1 to need protection systems of some sort.
2 The NRC guidance and requirements that you 3 have today, the Reg Guides are pretty -- are virtually 4 technology neutral and even plant characteristic-type 5 neutral. They can be whatever you want them to be, 6 but their guidance is certainly applicable.
7 So, you don't even mention the NRC 8 standard regulatory guides and other documents, 9 NUREGs, et cetera.
10 MR. RECKLEY: And what we do mean here is 11 those things that are set by standards development 12 organizations. So, IEEE, ANS, ASME, et cetera.
13 We don't mention NRC guidance in the rule, 14 but would certainly hope -- and we're looking now in 15 a number of areas where existing guidance might be 16 available to use to help show compliance with some of 17 the requirements here or even one level down from what 18 this rule language is going.
19 Once you were to determine, for example, 20 in the area of I&C, once you were to determine that 21 there will be a design feature associated with I&C and 22 then you can set functional design criteria for what 23 it needs to deliver in terms of timing and accuracy 24 and so forth, then it might very well be that there's 25 an existing Reg Guide that would support a particular NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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129 1 design or approach.
2 So, we don't refer to it, but we would 3 certainly hope that some of that material would be 4 relevant and usable once you get down into the design 5 of a specific system, for example.
6 MEMBER BROWN: Well, the NUREG -- the new 7 design -- DRG will be NUREG-800 Chapter 7 if it ever 8 gets to that point. A new edition or separate. It 9 embodies the framework from within which you would 10 develop your design. And how you can hope that maybe 11 somebody will decide that that's useful doesn't seem 12 to make a whole lot of sense to me.
13 MR. RECKLEY: In any case, that's a good 14 example of -- and we don't typically mention our own 15 guidance within the real language, but that guide is 16 developed in the same time frame as we're doing this 17 activity.
18 So, that would be a good example where we 19 certainly hope that guidance would help people meet 20 the requirements when they are looking at the role of 21 I&C in the design.
22 MEMBER BROWN: So, you're telling me the 23 existing 50 and 52 -- Part 50 and 52, all the existing 24 rules don't have any reference at all to NRC?
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130 1 that refer to Reg Guides or any kind of guidance 2 documents is rare.
3 I think maybe the ASME code case Reg Guide 4 is mentioned in the rule, but very few Reg Guides are 5 mentioned in rules because it usually goes the other 6 way around. The Reg Guide is developed to show how 7 you comport with the rule.
8 MEMBER BROWN: That's disturbing.
9 MR. RECKLEY: Okay. Going on then -- but, 10 by the way, the reason we want to do this is it's 11 encouraged by Congress, and also even within NEMA, 12 they continue to encourage the maximum use of 13 consensus codes and standards.
14 And so, we did this -- the reason we say 15 "generally accepted," is here is one area and the text 16 box is highlighting the potential issue, is that we 17 didn't want to be really specific because one of the 18 comments we're getting from stakeholders is -- I think 19 somebody mentioned in the QA area, might it be 20 possible to use ISO standards?
21 In other areas, if there are either ISO 22 standards, even potentially standards from other 23 countries or entities that are generally accepted, 24 might this rule make it easier to apply those 25 consensus codes and standards instead of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 traditional references to specific standards like ASME 2 and, to some degree, IEEE.
3 So, that's something we'll be talking 4 about as we go forward and exactly the language. And, 5 Dennis, I made a note on our language there.
6 So, the next one is just overall design 7 requirements in -- oh, I'm sorry. Yeah, on the next 8 bullet, the materials must be qualified for their 9 service conditions over the plant lifetime and have an 10 element or code requirement embedded. Its safety and 11 security must be considered together.
12 That's coming out of the advanced reactor 13 policy statement. I'll get to that. That's an area 14 we're getting comments on.
15 CHAIRMAN BLEY: I really like that, Bill.
16 I'm glad you said that.
17 MR. RECKLEY: Okay. Then the last one 18 here is -- if we're looking at the language to this, 19 what this one was intended to do was capture the code 20 requirement in 50.43(e) that basically says when 21 you're bringing forth the engineering approach, it has 22 to be proven by a combination of analysis, test 23 programs, the potential use of a prototype plant and 24 operating experience.
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132 1 maybe lost a little of its tie with that requirement 2 in 50.43(e), but that's the objective here.
3 So, any questions on that?
4 MEMBER PETTI: Yeah. This is Dave.
5 Were there concerns with the second bullet 6 or the fourth bullet, because you, quote, qualified.
7 I mean, there's an EQ requirement in the regs or in 8 the guidance.
9 This is pretty basic stuff, right, to 10 assure -- to come to an adequate assurance of safety 11 finding.
12 MR. RECKLEY: We didn't get much reaction 13 to the word "qualified." But the reason we ask the 14 question when we put it out is because, like a lot of 15 terms, it has its definition in the dictionary and 16 then it has maybe the history of what "qualification" 17 has met and the amount of work that goes into some 18 qualification activities.
19 But, again, in terms of stakeholder 20 feedback it did not seem to, at least preliminarily, 21 initiate any response.
22 MEMBER PETTI: That's good. Okay.
23 MR. RECKLEY: Alright. I think we can go 24 on to 30. This is --
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133 1 during the Gen IV project, the initial Gen IV project, 2 focusing on security by design. It's almost a 3 parallel to your discussion about admin versus design 4 fixes for (audio interference) people.
5 But it made a lot of sense to a lot of 6 people, that that's a preferred approach and it can 7 very much make it easier to ensure that security is 8 well covered (audio interference).
9 MR. RECKLEY: When we get to stakeholder, 10 we'll kind of go over that, but the biggest comment or 11 issue was not that they didn't recognize it as a good 12 practice, but whether it should be in the rule.
13 And if it wasn't done by the design 14 process, could it be compensated for on the other end?
15 Everybody, I think, would acknowledge it's not the 16 most efficient or desirable way to do it, but couldn't 17 it be done by just adding guns, gates, and guards if 18 it wasn't done at the design.
19 So, this is, you know, another one of 20 those areas we have to look at and say, how much do we 21 want to put good practice into the requirements?
22 As we go through the iterations and 23 looking at comments, that's an area we'll have to kind 24 of make a judgment on.
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134 1 interference) two things. I am convinced it's cheaper 2 in the long run, by a long shot. And, two, although 3 we do exercises, we haven't really tested the guns, 4 guards and gates security issues and I hope we don't.
5 MR. RECKLEY: Well, obviously we put it in 6 there. So, we had a similar thought when we put it 7 in. So, I think this slide in Section 450 is one 8 we'll end up talking a fair amount on.
9 In the iteration that you have that's 10 publicly available, the analysis in Section 450 can be 11 broken down into -- first, it starts off with the 12 requirement that there will be a probabilistic risk 13 assessment forum. And there's been a little reaction 14 to that, but not black-white arguments.
15 The second bullet is where a lot of the 16 discussion has focused in that we not only said that 17 a PRA needs to be done, but then we basically said 18 that the PRA is going to support the design and the 19 overall analysis effort by being used to pick 20 licensing basis events, classifying the equipment and 21 human actions, evaluating defense-in-depth and just as 22 a kind of central element of the design and licensing 23 approach and the analytical approach.
24 MEMBER MARCH-LEUBA: So, let me break in.
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135 1 this slide, right?
2 I just want to put on the record just a 3 little bit, if not a little much, of a simpler logic 4 in this approach.
5 It would be great if the PRA was actual 6 systematic search of everything that can possibly go 7 wrong in the plant, but it is not.
8 It is by necessity, by a scientific 9 method, it is incomplete and this is not hypothetical.
10 It just happened last year when the last reactor was 11 certified. The thing is the two limiting events 12 (unintelligible). So, it's not hypothetical. It 13 happens. And the way people think and the way the 14 human mind works, you ignore events. Okay?
15 And it's even more, because what the risk 16 analysts do to generate a fault tree is identify all 17 the components and ask the system engineer what 18 happens if Valve No. 27 fails? And the guy comes back 19 and says, eh, nothing because I have 28 that backs it 20 up. So, then that's how you build a tree.
21 With fault opinions, at best an Excel 22 calculation, and then you use those opinions, those 23 ideas of the design engineers, to identify what events 24 are important and you analyze those events properly 25 afterwards. You just confirm what the system NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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136 1 engineers thought based on the Excel calculations.
2 So, and this is what -- I mean, ACRS is on 3 the record, in a letter, saying that you should use 4 PRA, of course, to identify the basis events, but you 5 should also try to do more systematic and try to 6 understand what could possibly go wrong. Because what 7 I've seen happen is you start with the standard review 8 plan events and start removing the ones that don't 9 apply to your plant, but don't add any.
10 So, the rule should, in my opinion, be 11 much more strict and emphasize the fact that 12 identifying the design-basis events is crucial. That 13 if you follow -- if you're going to spend enough time 14 doing this and enough peer review and a lot of time on 15 it trying to identify what could possibly go wrong, 16 you will miss something. Every time we have a 17 significant accident is because somebody missed 18 something. Okay?
19 I put it on the record. You don't need to 20 defend it.
21 CHAIRMAN BLEY: Okay. But some of us need 22 to offer a comment. I agree with Dr. March-Leuba's 23 final conclusion. We need a thorough process to 24 identify these things, whether it's supporting PRA or 25 some other approach.
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137 1 There's probably been more work done in 2 the PRA area on identifying ways to do that although 3 it's not listed here in what you have for these -- in 4 the rule language here or in the PRA standard or 5 guidance document. It's necessary and there are a 6 number of very useful approaches that have been used.
7 Mr. Carl Fleming was at our meeting on PRA 8 standards a few months back and provided us a rather 9 nice package of papers that delve into some of those 10 methods. We've mentioned them in several of our 11 letter reports.
12 So, I'm agreeing that it really ought to 13 be emphasized, I think, in the rule, but that search 14 has to be very thorough and creative and not just 15 picking out previous lists especially for these new 16 designs.
17 The comment about how people decide 18 failure modes and what goes in fault trees just isn't 19 the way it's done. So, I'll leave it at that.
20 But I agree it would be really good to 21 beef up the description of how we search for these.
22 Because even if you don't do PRA, you've got to find 23 them and that's the place we slip up, I think.
24 MEMBER KIRCHNER: Bill, this is Walt 25 Kirchner.
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138 1 MR. RECKLEY: Yeah.
2 MEMBER KIRCHNER: You know, I had the 3 language open at the same time as you're showing your 4 viewgraph and my concern, to add on to Dennis' 5 comments and indirectly also respond to my colleague 6 Jose's comments, is this says you must do a PRA.
7 And, again, going back to very early this 8 morning, Mike Corradini's comments, you know, if 9 there's going to be a graded approach, can't we allow 10 that someone would do -- and I'll just use some 11 terminology probably incorrectly -- a hazard analysis 12 for a much smaller system and start with that and use 13 that as a basis for defining licensing basis events 14 and then subsequently SSCs and so on in this process.
15 It looks like it's a mandatory requirement 16 you will do a PRA as the -- as I read the language 17 right now.
18 MR. CORRADINI: This is Corradini. I 19 guess I agree with Walt.
20 The "must" part bothered me and the detail 21 bothered me. So, I'm curious what the staff felt that 22 required a "must."
23 CHAIRMAN BLEY: I'm going to jump in, too, 24 because I disagree not in principle, but in words, 25 with the last two comments.
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139 1 I like having "must" in here. But as I 2 said earlier, you need some pretty thorough guidance 3 on how one implements a PRA depending on the 4 complexity of the design and the -- I'll go back to 5 the language we borrowed from the DOE earlier, the 6 material at risk and the damage ratio kind of idea of 7 it should be scalable.
8 I still call it a "PRA" if it's 9 probabilistic and looking at risk.
10 MR. CORRADINI: So, Dennis, I think we're 11 saying the same thing. I guess there's other tools or 12 -- I mean, I'm not an expert. So, you're really the 13 expert in terms of this, but it just struck me that 14 this was very prescriptive. Almost too prescriptive.
15 CHAIRMAN BLEY: It does three things. It 16 searches for and identifies the scenarios, what can go 17 wrong; it identifies how likely those are; and it 18 identifies what the consequences -- or the range of 19 consequences on each one would be. And if you do 20 those three things, that's a PRA.
21 Now, he has a lot of guidance on how you 22 do one for a large, complex facility. We need some 23 guidance on how you simplify that for smaller systems 24 (audio interference).
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140 1 thing, but in different ways.
2 MEMBER KIRCHNER: On the topic of --
3 Dennis, I'm trying to -- I'm thinking back to the 4 existing Reg Guides which were really tailored for 5 PRAs for the existing fleet. Very comprehensive.
6 Very detailed.
7 Is there some way in this language that we 8 can -- I agree with you, I'm just wondering what the 9 expectation would be and -- I don't even want to raise 10 this, but I'll mention it -- uncertainty for advanced 11 concepts in the results of a PRA, but is there some 12 way that one could capture what you just said, Dennis, 13 in the language helping Bill so that -- my first 14 reaction is they're asking for PRA like you have for 15 the existing fleet and you really probably are going 16 to have great difficulty doing that -- so, I mean, 17 informing it with the kind of data that we have for 18 the existing design.
19 So, is there some way in this regulatory 20 language that it -- okay, keep the word "must," but 21 the PRA then is defined as you very clearly defined 22 it.
23 MR. RECKLEY: And this is Bill --
24 CHAIRMAN BLEY: They just needed the 25 guidance to go with it.
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141 1 MR. RECKLEY: Right. And what we're 2 working on now is we got the non-light water reactor 3 PRA standard just issued and the staff is reviewing 4 that.
5 And that will be an opportunity to look 6 and see within our guidance and what exists already 7 within the standard for making sure, I think, what 8 everybody is saying.
9 If you're going to require a PRA, make 10 sure the PRA is simple if the machine is simple. If 11 you have few things to break, then your trees should 12 reflect that you have a few things to break.
13 The reason light water reactor PRAs are 14 extensive and complicated is they have a lot of moving 15 parts and the parts interplay with each other.
16 A break on the secondary side provides 17 immediate feedback to the primary side. So, the 18 interrelationships and the complexity is what drives 19 the PRAs to be as extensive as they are, but Dennis 20 can weigh in -- he's, again, the expert here -- or 21 I'll ask Marty Stutzke to weigh in.
22 But we've come back and tried to say we 23 think the nature of PRAs are that simple machines will 24 or can have simple PRAs, but, Dennis or Marty, if you 25 want to weigh in?
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142 1 MEMBER MARCH-LEUBA: I want to weigh in a 2 moment.
3 What I was saying, is if you are going to 4 do a PRA, you better do a good PRA. It's not 5 laughable, I mean, because the last PRA we saw, 6 according to all the experts, was the best PRA ever 7 performed for this hazard configuration, an order of 8 magnitude, still missed the two limiting events.
9 That's my point, that over-relying -- just 10 because you spend ten man-years and you fill up 700 11 pages of cap trees (phonetic) doesn't mean you got 12 them all. It's the basis of the scientific method.
13 You cannot prove a negative. Okay.
14 MEMBER BALLINGER: But that's the nature 15 of any of these designs, you know? I mean, are we 16 hung up on the -- we've got, in our mind, a definition 17 of "PRA" that's very tied to light water reactors.
18 If you were to go out to the -- I don't 19 know -- oil and gas industry and tell them what is a 20 PRA, first they probably wouldn't -- you know, you 21 would get a different definition. It's just a risk 22 assessment of the system. And if you want to make the 23 EPZ the site boundary, you got to somehow demonstrate 24 that Part 20, you know, dose limits are met and a risk 25 assessment is one way to do it. Call it a PRA if you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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143 1 want. I don't know.
2 MEMBER REMPE: So, I'm curious still on 3 why the staff said you must have a PRA. I, again, am 4 thinking about what I've been reading about Part 50 5 and 52 alignment and the staff tied it to the severe 6 accident policy statement.
7 And if you go back to the severe accident 8 policy statement, it doesn't say you have to do a PRA 9 -- well, it says you need to use risk methods.
10 They basically say again what everyone 11 else is saying here today about that they realize that 12 some designs aren't really suited for a full PRA as we 13 think of for a large light water reactor.
14 They talk about that, you know, if you --
15 with the complexity and as you go further in the 16 licensing process, what might be more suitable.
17 So, those kind of -- what drove you to 18 decide we've got to do a PRA?
19 MR. RECKLEY: And I'll break it into two 20 elements. Again, the first and the second bullet.
21 The requirement -- our thoughts on requiring a PRA are 22 that it seems a logical continuation and evolution of 23 the risk-informed approach that saw a requirement for 24 a PRA added to Part 52 and the discussion that went on 25 at that time.
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144 1 And, at that time, the PRA was required 2 and everyone is looking at it for insights. We have 3 an SRP Chapter 19 to look for those insights.
4 It also includes, as you mentioned, the --
5 that chapter looks at the severe accident design 6 features and -- that were added as a result of the 7 severe accident policy statement.
8 The NRC has built this -- not only the 9 NRC. The nuclear industry and the NRC have built this 10 infrastructure starting in the '70s that I'll 11 acknowledge freely there are other risk assessment 12 tools.
13 The one that was selected by the nuclear 14 industry and the NRC is the PRA. And so, it just 15 seems a logical evolution of that process to require 16 the PRA to be performed.
17 And, again, the first bullet requiring a 18 PRA is consistent with Part 52 and it's consistent 19 with what's going to be put into Part 50. So, having 20 a PRA doesn't seem that controversial.
21 The second bullet is what generated more 22 response, was that you would actually use the PRA, 23 which when we did this iteration, seemed again like 24 the logical evolution.
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145 1 use it for insights for a design that continued to be 2 based largely on a deterministic approach of the 3 general design criteria and related regulations.
4 And so, our initial thought was, okay, 5 we're just going to take this step. This is an 6 evolution in risk-informed approaches.
7 We will not only require the PRA to be 8 performed, which is current requirements, we're going 9 to actually require it to be used in the theory that 10 it's actually a more systematic approach than the 11 deterministic way of saying, pick some reactivity 12 events, pick some loss of heat transfer events, some 13 -- pick some loss of inventory events and use those.
14 I'm sorry, I didn't mean that to come across as it 15 probably just did.
16 That is a systematic approach and it's a 17 fine approach, but, just as Jose was mentioning, it's 18 as good as an approach as how you execute it. It can 19 either be very good, or it can be haphazard, depending 20 on the events you pick and the discipline that you put 21 into it.
22 But our thinking at the time, and as we 23 get into comments later on, the use of the PRA in the 24 design process is a comment we got and it's one that 25 the next iteration we expect will take a step back NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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146 1 from saying the PRA is the primary design tool in 2 terms of picking your licensing basis events and 3 classifying the equipment and other things.
4 MEMBER REMPE: So, are you closing off the 5 option of having a worst case or maximum hypothetical 6 event? The second bullet seems to be that you might 7 be doing that.
8 I get that you need to justify the maximum 9 hypothetical event having some sort of risk method to 10 say you've systematically gone through possible 11 challenges and you've picked the worst case, but I'm 12 kind of wondering if the second bullet doesn't kind of 13 close off that option for potential applicants.
14 MR. RECKLEY: And that's been the 15 observation and why we're looking to probably change 16 that in the next iteration.
17 MEMBER REMPE: Oh, again, I'd really like 18 to tie this to what's going to be done with Part 50/52 19 alignment. Like, some guidance would be very helpful 20 that emphasizes risk methods more.
21 MR. RECKLEY: Right.
22 MEMBER REMPE: But, again, I guess we'll 23 have to see what you come up with.
24 MR. RECKLEY: Well, and, again -- and that 25 will be a point of discussion. We have one way to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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147 1 this through the licensing modernization and Reg Guide 2 1.233, NEI 18-04. So, we have one way to do this 3 that's been established.
4 Might there be additional guidance 5 developed either by industry or staff to say here's 6 another possible approach, that will be something we 7 talk about as we continue through this process.
8 CHAIRMAN BLEY: Bill, two points. One, 9 over the last 30 years there have been developed a 10 number of very useful tools developed by people doing 11 nuclear plant PRAs, some developed by the chemical 12 industry, some from aerospace.
13 In any case, a large number of tools that 14 help you be more systematic, more complete in 15 identifying, I'll call them, "initiating events and 16 scenarios."
17 There is no current guidance I'm aware of 18 in either of the PRA standards, or in NEI 18-04, or in 19 any of the NRC guidance documents on how to do that 20 systematic search, you know, starting with a blank 21 sheet of paper and not being biased by everything 22 that's been done before.
23 I think you really need that guidance.
24 This is -- we've suggested that several times already 25 and will probably do it more thoroughly in the future.
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148 1 The second point is this seems one more 2 place that if -- that you could save yourself a lot of 3 trouble if you'd get some white papers started that 4 will eventually become part of the statement of 5 consideration defining and justifying the Tier 1/Tier 6 2 stuff, talking about what do you mean by a PRA, what 7 kinds of PRAs could be done, but how can this process 8 be simplified?
9 I still look at it on various levels of 10 depth and the one I think you always got to do very 11 thoroughly is the identification of initiating events 12 and scenarios, what can go wrong.
13 And then, two, how do you figure out the 14 likelihood event and how do you figure out the 15 consequences? Those you can scale according to things 16 about the design.
17 And I think if you had white papers on 18 those, it would help a lot. And eventually I think 19 they ought to be part of the SSC and that same sort of 20 thinking could be reflected over in 50/52.
21 MR. RECKLEY: Okay. Thank you.
22 Again, this might be the part or place to 23 throw in the -- the other area, again, that we've 24 raised and I've not gotten much traction on is when 25 people say "maximum hypothetical," if that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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149 1 equivalent to unmitigated as it's used in the DOE 2 standards and in the other guidance documents like 3 ANS-2.26.
4 I mean, we also are looking to see where 5 infrastructure might be in place and guidance already 6 exists such that we could just adopt something like an 7 ANS or a DOE standard. So, I'll just leave it there.
8 The issue that often arises with maximum 9 hypothetical is if one picks hypothetical to be non-10 realistic and that starts to approach for me the 11 unmitigated approach that DOE takes, one can make 12 those arguments.
13 But what often creeps in is that it's not 14 necessarily unrealistic but a probabilistic argument 15 enters into the discussion.
16 And in my view, for example, maximum 17 hypothetical or unmitigated are, by their nature, set 18 out to be conservative to prove a point.
19 And if you can prove that point, then 20 things can be greatly simplified, but that differs 21 from a maximum credible accident where a frequency is 22 being introduced into the argument of -- and so, maybe 23 to Dennis' point, in such white papers we would have 24 to make a clear distinction between maximum 25 hypothetical or bounding or unmitigated events and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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150 1 maximum credible events where frequency is being 2 introduced based on the -- some either initiating 3 event frequency or reliability of equipment. So --
4 but those are the challenges we look at.
5 So, again, we are considering -- we've 6 gotten considerable feedback on this and we are 7 looking in the next iteration to make some adjustments 8 in recognition. Many of the comments are similar to 9 what we're hearing here today.
10 MR. CORRADINI: So, Bill, just one last 11 question because maybe you said it and I missed it, 12 but this requirement, does the PRA have to be 13 qualified based on some standard?
14 MR. RECKLEY: Yeah. It goes down to the 15 next one that we would consider it meeting either the 16 -- for light water reactor designs, the light water 17 reactor standard that reflects Reg Guide 1.200 and all 18 the related work or the recently issued non-light 19 water reactor standard which is currently under NRC 20 review.
21 Or if it didn't, then they would have to 22 justify some other approach, but the hope and the 23 thought was that, again, we have that infrastructure 24 for those two major technologies, non-light water 25 reactors and light water reactors.
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151 1 MEMBER MARCH-LEUBA: What I think we were 2 saying, or at least I was saying on this regard, is 3 there is no logical vision to include the use of the 4 maximum hypothetical, what you call the mitigated.
5 If for one of these small, super-safe 6 reactors you can live with it, why do the rest?
7 MR. RECKLEY: And, again, I don't know 8 that we would have strong disagreement. Our look at 9 the literature is we're not sure there's such a 10 machine exists.
11 MEMBER MARCH-LEUBA: Well, you just have 12 to analyze it and see if it does.
13 MEMBER PETTI: Yeah. I know of one that 14 I think meet that definition.
15 MR. RECKLEY: Okay. Anyway, so we're 16 looking at that. Again, if anybody has any thoughts 17 or experience especially for us on -- or to me, 18 anyway, the unmitigated approach, the assessment of 19 unmitigated events and whether that could be used in 20 this context, the attractiveness of that is there's 21 already a considerable infrastructure built around 22 that that we might be able to use.
23 So, I guess it's --
24 MEMBER PETTI: Bill, just a question on 25 the two years.
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152 1 Is that something that comes from one of 2 the standards, Y2?
3 MR. RECKLEY: It's another area we got 4 comments on, but especially the word "upgraded." We 5 were thinking to require it to be updated and assessed 6 every two years.
7 Marty, weigh in. Under 50.74, I think, is 8 that the current requirement or is the current 9 requirement four years, but at some periodicity.
10 So, we pick two years. That generally 11 goes with kind of once you enter the operational 12 phase, that these assessments should be done 13 periodically. I don't think there's --
14 MEMBER KIRCHNER: This is Walt. Just to 15 help you a little, I thought your facility safety 16 program was going to utilize an updated PRA at 17 frequent intervals to kind of offset, you know, 18 whether you had inspectors and all the rest.
19 MR. RECKLEY: Yeah. That would be part of 20 it. And then there would also be on the assumed, at 21 least in this construct that we proposed in the first 22 iteration, the notion was especially when you get into 23 the second tier requirements that you would be having 24 to look at the reliability of the equipment, the 25 actual operating history, and making sure that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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153 1 things you had set up in the PRA for meeting the QHOs 2 in the second tier were actually being satisfied.
3 So, you're going to have to run that 4 through the PRA on some periodic basis. We picked two 5 years. That's a traditional number for updating 6 licensing documents and so forth.
7 I'll have to go back and look what the 8 existing requirement is in 50.74, I think it is.
9 MS. VALLIERE: It's 50.71, Bill, and it's 10 four years in Part 50.
11 MR. RECKLEY: Thank you. Four years.
12 MS. VALLIERE: Yes.
13 MR. RECKLEY: Okay. So, the logic from 14 shortening it from four to two was the increased role 15 of the PRA and the need to really continue to validate 16 that you're meeting the second tier.
17 MR. CORRADINI: So, Bill, can I ask 18 another question? I'm sorry I'm putting you on the 19 spot, but I'm sure you've got staff -- colleagues that 20 can help you.
21 Is it fair to say the way you guys are 22 discussing this, that the MHA is a thing of the past 23 and everything's got to be an MCA? And, therefore, 24 you must do some sort of risk analysis to show that 25 you've bounded all the potential scenarios?
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154 1 MR. RECKLEY: No, I don't think that's 2 what we're trying to say. The use of an MHA, which, 3 by the way, is not a tool we've used on the power 4 reactor side, but the use of an MHA could still be 5 used especially to simplify the analysis that one 6 would do.
7 The logic here would be you need to do a 8 PRA and look at all of -- systematically look at what 9 can go wrong, as Dennis was saying.
10 And if you were able to show through the 11 Image A -- or through that collection of events that 12 you could simplify the analysis by looking at 13 something that bounded them all -- and I'll use a 14 simple example and don't take it too far, but let's 15 say back on that first slide where you had a damage 16 ratio, that you had a fuel farm that basically could 17 say there will be no relief below temperature X.
18 Okay?
19 And I go through all of the events and 20 look at what can go wrong with this plant and then say 21 of all of those events, I can bound it by saying I'll 22 take away, you know, everything but radiation to the 23 air -- and that's a maximum hypothetical -- and I 24 still show I'm under the temperature at which damage 25 ratio is basically zero.
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155 1 Then I could argue I've looked 2 systematically at what can go wrong, I took a 3 conservative approach to assessing the consequences of 4 a maximum hypothetical accident and I've assessed it 5 and there are no consequences.
6 CHAIRMAN BLEY: And you have taken a 7 conservative approach to the likelihood. You've 8 assumed it's going to happen.
9 MR. RECKLEY: Right.
10 CHAIRMAN BLEY: So, really those three 11 pieces kind of work. My hang-up -- it's not a hang-12 up. My claim is that you always got to do a detailed 13 search for the scenarios.
14 Maximum hypothetical or maximum credible 15 can't be proved if you've got the worst one unless you 16 can show that you've really thought through those 17 things.
18 MR. CORRADINI: But then, Dennis, I think 19 you're kind of saying, in essence, what I said, which 20 is the concept of an MHA can only be identified once 21 you've essentially gone through some sort of search of 22 what could happen, what is the likelihood of it 23 happening, and what are potential consequences in 24 bounding those consequences with a -- I won't call it 25 "simple," but with a bounding analysis.
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156 1 CHAIRMAN BLEY: With a bounding analysis.
2 And if you don't do that first part, you might be 3 missing something very energetic that happens right 4 next to this thing that sets it all in motion and 5 would create much broader consequences than you would 6 normally get to that thing you thought was maximum 7 hypothetical.
8 That's why you have to look to what can go 9 wrong.
10 MR. RECKLEY: Yeah. And the other, you 11 know, the other part from a practical standpoint as we 12 look at this, is, you know, maximum hypothetical is a 13 good -- I mean, it's a plausible approach to show that 14 there's no consequences to the public health and 15 safety, but --
16 CHAIRMAN BLEY: In use for research 17 reactors, too, though.
18 MR. RECKLEY: Right. And it has some 19 history in the research arena. The -- but the notion 20 that you're going to thereby greatly simplify the 21 analysis done for the machine overall, I would ask 22 people to really think if that's true.
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157 1 these machines, it's kind of easy for the NRC, 2 perhaps, to say, well, the MHA bounds and therefore 3 it's okay.
4 But if you don't think that any customer 5 is going to say, whether there's a health effect or 6 not, how often are components going to fail that kicks 7 this thing offline, I -- my personal think is that's 8 going to happen in any case.
9 And so, for all of the work to say you 10 don't need to do a PRA, are you just taking it out of 11 the regulatory arena but it's going to have to be done 12 anyway?
13 And so, the conservatism you piled onto 14 the licensing side, in theory, to save doing the PRA, 15 you don't save at all anyway because you're going to 16 have to do the PRA to show that this thing is going to 17 have a reliability greater than the 40 or 50 percent 18 that the light water reactor capacity factors showed 19 for the first 10 or 15 years.
20 So, you know what I mean? I think you 21 need to take a realistic view of the whole landscape 22 and be kind of realistic about are you really saving 23 by arguing that you don't need to do a more complete 24 assessment of not only failure modes, in effect, but 25 the actual probabilities that will go ultimately into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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158 1 giving some kind of estimate on the reliability of the 2 reactor as a whole.
3 But anyway, now I'm starting to preach.
4 So, I better shut up because I'm going beyond my realm 5 here.
6 MEMBER REMPE: Bill, I agree. I used to 7 work for a company many, many years ago and they did 8 economic risk as well as safety risk assessments.
9 I think the answer that might come back is 10 that the regulators should only be concerned about 11 safety and let the buyer beware and look at the 12 economic risk assessment.
13 Again, there's a lot of cost with the QA 14 required for the regulator, right? So, perhaps, you 15 know, you may be right, but I just kind of wonder. I 16 can see why it would --
17 MR. RECKLEY: And I do -- and that's why 18 I say I was going off the rails there, but -- because 19 I see the difference between a regulatory 20 responsibility and what the -- but I just -- the 21 argument that a lot of money gets saved one way or 22 another is my point.
23 I'm not sure that argument really is all 24 that compelling, but that's not for us to decide in 25 the end. You're exactly right, Joy.
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159 1 So, anyway, all that said, we're likely to 2 get some relief in this area, when we get down a 3 couple slides, to show the feedback and what we expect 4 to do in the next iteration.
5 Someone brought up that we use for the 6 analytical conforms to analytical generally accepted 7 methods and standards. That would include the PRA 8 standards.
9 The next bullet, the codes, you'd have to 10 go through an appropriate validation and verification 11 to qualify the codes. I don't think that's very much 12 in argument.
13 The next to the last bullet we did throw 14 in some things. We did not -- weren't sure got 15 captured and we just wanted to have a placeholder.
16 Fire protection obviously very important.
17 Aircraft impact assessments under the Part 50 and 52 18 regulations.
19 And the specific events that were 20 addressed most recently, the Fukushima-related 21 mitigation of selected beyond design-basis events.
22 And then I wanted to get into another 23 important element because I'm not sure it's been clear 24 that the analysis, the licensing basis events as we've 25 talked about them above and then the rest of 53.450, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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160 1 we would say the analysis of those events one 2 acceptable way to do that would be, as we've endorsed 3 in Reg Guide 1.233 on licensing modernization, which 4 is those assessments of events are using out of NEI 5 18-04 kind of best estimate approaches and then 6 assessing the uncertainties of frequencies and 7 consequences. That would be one way to do it.
8 But the other thing that's in NEI 18-04 9 methodology and we were proposing to require also in 10 Part 53 was the specific assessment of a design-basis 11 accident, which is done using only safety-related --
12 crediting only safety-related equipment, using perhaps 13 more traditional analytical approaches, a bit more 14 conservative than codes might be to do the thermal 15 hydraulic assessments under the PRA.
16 And here's where we tie this kind of back 17 to Subpart B that it's the design-basis accident 18 that's really being used to judge the first tier 19 safety criteria.
20 This is the assessment from which you're 21 getting the confirmation that there's no 22 conservatively assessed using only safety-related 23 equipment even that would trip the 25 rem at the 24 exclusionary boundary threshold.
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161 1 the DVAs?
2 MR. RECKLEY: Well, the DVAs would come 3 out of the overall assessment licensing basis event 4 that under -- and I'll give you two answers.
5 NEI 18-04 describes one way to do that, 6 which is you derive them out of the design-basis event 7 category as well as looking at potential high 8 consequence beyond design-basis events, but the 9 primary element is to pick them out of the design-10 basis event category at NEI 18-04.
11 Or especially as we get into the 12 alternative we'll be building in, they could be picked 13 by some other systematic approach and that might be 14 picked up in some kind of other standard.
15 Going back to the way it was done for 16 light water reactors, you could pick it out of ANS 17 51.1 and 52.1, for example, for PWRs and BWRs, would 18 tell you what your design-basis accident is.
19 So, if there is some other methodology 20 that's developed that has included a kind of 21 systematic approach to it, when we get down to the 22 next iteration, I think we would say that we'd be open 23 to such an approach.
24 MEMBER MARCH-LEUBA: Yeah, but shouldn't 25 the rule -- I mean, a specific variable of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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162 1 licensing basis events, which don't mean anything 2 because the DVAs are the ones under control, and then 3 the DVAs we don't specify how to do it?
4 MR. RECKLEY: Well, the current language 5 used is the 10 to the minus 4 frequency of the 6 underlying event frequencies, again, consistent with 7 what we endorsed in Reg Guide 1.233.
8 One of the discussions as we go forward is 9 if you want to separate the approach of selecting 10 events from such a frequency oriented approach, a PRA 11 approach, then we'll have to perhaps come up with 12 other approaches.
13 Although, even 51.1 and 52.1 for the 14 current structure basically tied those -- or had any 15 relationship between the DVAs and frequencies.
16 But as the current language that we have 17 for 53.450(e) talks about picking the design-basis 18 accidents from the event sequences with a frequency on 19 the order of 10 to the minus 4.
20 MR. CORRADINI: That's an upper bound.
21 That one piece of language you just quoted confused me 22 in Subpart E.
23 MR. RECKLEY: Yeah. I mean, under -- and 24 I should have had it open, but under LMP, for example, 25 they're selected from the event sequences ranging from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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163 1 10 to the minus 2 to 10 to the minus 4, plus 2 accounting for the uncertainty.
3 So, a 95th percentile event down to 10 to 4 the minus 4.
5 MR. CORRADINI: Okay. Because -- alright.
6 So, the way you just said it here isn't the way I read 7 the English in Subpart E.
8 MR. RECKLEY: Okay.
9 MR. CORRADINI: Because in there it says, 10 with an upper bound frequency less than 1 in 10 to the 11 minus 4.
12 So, the way you just said it in explaining 13 it to me makes perfect sense. It's just the way it's 14 worded in the subpart confused me. Sorry.
15 MR. RECKLEY: Yeah. No, no. And I find 16 it very difficult to write and we adopted -- later on 17 we adopted using the frequencies and then saying 18 accounting for uncertainties as opposed to trying to 19 -- I think the reason I put in "less than 10 to the 20 minus 4" was the assumption that you'd have to account 21 for uncertainties, but that --
22 MR. CORRADINI: Okay.
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164 1 uncertainties.
2 MR. CORRADINI: Okay. No, that helps, 3 Bill. Sorry to butt in there.
4 MR. RECKLEY: No, no.
5 MEMBER REMPE: Before you leave this 6 slide, when I was studying up for this meeting with 7 respect to this thing about enhancing the guidance, I 8 think that Section 2.3.1 of Reg Guide 1.174 might be 9 a good place to add some additional words because 10 there they already talk about the fact that although 11 you need to look at all the plant operating modes and 12 hazards groups, that it's also not necessary to have 13 a PRA of such scope. A qualitative treatment could be 14 sufficient for some applications and designs.
15 And so, that's a good starting place that 16 you might want to consider for beefing up the 17 guidance.
18 MR. RECKLEY: Okay. Thank you.
19 Alright. If we can go to slide 31, so a 20 couple notes. So, as we develop the next alteration, 21 as I had mentioned a couple times, I got allowing an 22 alternative risk-informed systematic approach to PRA 23 for the determination of licensing basis event, safety 24 classification, and evaluating defense-in-depth.
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165 1 of the members today. It's also something we got from 2 public stakeholders. So, that's something we'll 3 address in the next iteration.
4 There was some discussion in the next 5 iteration I'll try to clarify a little bit. The lower 6 -- or the higher frequency events, the anticipated 7 operational occurrences, I'd have to agree the 8 existing language that we have in the first iteration 9 is probably a little light on the anticipated 10 operational occurrence end. So, we've tried to 11 clarify that.
12 And then something out of our meeting with 13 this subcommittee in January is the discussion in your 14 lessons learned letter about end states.
15 And so, we will look -- the PRA -- non-16 light water reactor PRA standards talks about 17 analyzing events to define end state. So, we can 18 capitalize on that discussion within the PRA standard.
19 And then for the design-basis accidents, 20 the one we were just talking about within 53.450 on 21 analysis, at that point we can't even talk about a 22 safe, stable end state for the design-basis accident.
23 So, per the discussion we had in January 24 and in looking at that discussion, I think we can 25 address that in the next iteration.
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166 1 So, any discussion with that? If not, we 2 can go to slide 32 and the safety categorization.
3 (Pause.)
4 MR. RECKLEY: So, the definitions that we 5 would propose, and somebody had brought up earlier the 6 definition, so we would look, and we have in 53.460, 7 the need to categorize equipment and human actions.
8 And the first one is what equipment --
9 what human actions are relied upon to address the 10 design-basis accidents and meet the first tier safety 11 criteria? And those would be termed "safety-related."
12 Then the non-safety-related, but safety-13 significant, would capture those things that are 14 needed to provide or fulfill the second tier safety 15 criteria of meeting the QHOs.
16 And -- or are considered risk significant 17 within the probabilistic risk assessment using the 18 value from the PRA standard.
19 And it's actually consistent with NEI 18-20 04 that it be one percent of the cumulative plant 21 risk.
22 As we look at revising, in the next 23 iteration, the role of the PRA and categorizing the 24 events and categorizing the equipment, this is an area 25 that we'll have to look into because the non-safety-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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167 1 related, but safety significant, would not necessarily 2 -- it wouldn't work to quote the PRA if you weren't 3 requiring the PRA to be used for this purpose. And 4 so, we'll look, in the next iteration, to maybe modify 5 that language.
6 CHAIRMAN BLEY: But have you thought about 7 how deep you go on some of these? Let's say you have 8 a design -- we'll make up something that might be a 9 little silly, but it's happened in some other cases --
10 you have a design for which one of your design-basis 11 accidents relies on this particular system.
12 This particular system from your -- from 13 a hydraulics analysis and other things shows that you 14 need one train to operate, but you've built four 15 trains in.
16 Are all the components in all four trains 17 safety-related? Is it one train? Is it one plus one?
18 And if you do something like that, then it gets really 19 confusing going on to the other cases or if you stayed 20 with -- if you went with risk-significant, it would be 21 clear.
22 MR. RECKLEY: Yeah, that -- that would 23 have to be developed as people look at a possible 24 alternative.
25 The guidance that's available for at least NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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168 1 one approach, which is that described in NEI 18-04, 2 would basically say your single train can be safety-3 related and then -- depending on the nature of the 4 designs.
5 It was more clear when you talk about 6 passive. If you talk -- even under LMP if you talk 7 about having an active system, whether you could get 8 by with an assessment that one of -- one train of a 9 two-train active system would be differentiated in 10 safety classification gets a little fuzzy because you 11 would have to look at -- you'd really look at the 12 actual reliability of the system to make that 13 determination.
14 But the basic structure of the -- of NEI 15 18-04 that enabled us to address things like single 16 failure criteria and -- if you're not using the PRA 17 and you are proposing an alternate approach, then that 18 question of things like single failure criterion would 19 have to be answered within that approach. Maybe I'll 20 just leave it with that.
21 So, I can't give you a definitive answer 22 because it would depend on a number of things, whether 23 it was passive or active and so forth, but -- and we 24 have a slide later on even if we introduce the term 25 "inherent," that may be one additional complication, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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169 1 but the -- one of the reasons we were writing the 2 first iteration the way we did is because we had an 3 available guidance document that answered questions 4 like single failure criteria.
5 So, I probably didn't answer your 6 question, Dennis, but --
7 MEMBER KIRCHNER: Bill, this is Walt 8 Kirchner. I'm -- just a little clarification on that 9 I would ask for.
10 I thought the traditional definition of 11 "safety-related" was those SSCs. It did not include 12 human actions.
13 And certainly the advanced policy --
14 advanced reactor policy statements have always pointed 15 to less reliance on human actions.
16 So, one would expect, you know, longer 17 time constants, inherent feedback, passive mechanisms.
18 I'm a little concerned about what you mean 19 by "human actions" other than pushing the scram button 20 or activating TFAS (phonetic) and so on.
21 MR. RECKLEY: And what you're seeing is a 22 bit of a trailer for what's yet to come. The reason 23 we included human actions in this discussion is 24 because we're looking ahead to that segment of the 25 operation subpart that I mentioned earlier where we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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170 1 start to really look at what are the role of the human 2 actions and where there will be distinctions between 3 what's done by a licensed operator, what might be 4 allowed by a non-licensed staff, and the possibility 5 that you'd have no staff at all.
6 And so, the fact that we're kind of 7 looking at this as an integrated approach requires us, 8 we thought, and why we included it in here, to bring 9 this forward even into the analysis to say that when 10 you're doing the analysis under this subpart, the 11 analysis under 53.450, is also likely to be supporting 12 your staffing discussions under Subpart H and it has 13 to be reinforced that whatever analysis you've done 14 under 450 in this construct is showing that the --
15 whatever the role of the people might be is going to 16 carry forward.
17 So, for light water reactors the operators 18 have roles that they have to take during the course of 19 a design-basis accident. It might be in the later 20 stages, but most designs have a role for operators.
21 That would get reflected in Subpart H on 22 staffing to say, oh, a human being is being relied 23 upon to meet that 25 rem criterion in the first year.
24 Therefore -- and the "therefore" we have 25 yet to write, but in traditional, therefore, that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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171 1 going to be a licensed operator. That action is going 2 to have to be modeled and simulated and trained and, 3 et cetera, et cetera.
4 If, on the other hand, 53.450 analyses can 5 show that people serve no role, then that might 6 support the concept of operations that would be 7 required in Subpart H on the role of personnel.
8 So, the reason that it includes human 9 actions, you're right, we don't traditionally call 10 human action a safety-related thing, but we're looking 11 forward to how this will translate into Subpart H.
12 MEMBER KIRCHNER: Yeah, I get that. I 13 just wonder if that -- this introduces -- lowers the 14 expectations.
15 I mean, traditionally what we've done in 16 Chapter 15 analyses is you rely on the SSCs, they're 17 classified as safety-related and it's pretty much 18 hands off and you do the accident analysis to 19 demonstrate that you can meet the regulatory -- I 20 mean, sooner or later it ties to the dose offsite, but 21 basically there are a lot of surrogate regulations for 22 the LWRs.
23 And I'm just -- I'm -- I see where you're 24 going with it. I just would expect of an advanced 25 reactor that, at least for the design-basis accidents, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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172 1 human intervention would not be a requirement. That's 2 old-fashioned thinking, I'm sure.
3 MR. RECKLEY: It's an element of the 4 advanced reactor policy statement to try to minimize 5 human actions.
6 The question to us is always how to build 7 that into the requirements and whether it's -- whether 8 that is something that all designers will choose to 9 do.
10 We're trying to leave open to the designer 11 throughout this subpart that they have choices to 12 make.
13 Do they want the operational cost of 14 licensed operators? And is that more economic in the 15 long-term than putting in design features to try to 16 show you don't need them?
17 That is something we're not trying to 18 decide. We're trying to support either decision. So, 19 that's where we are in developing the --
20 MEMBER KIRCHNER: Yeah. But I guess, for 21 me, this would be something that would be more second 22 tier, the human factor.
23 In your first tier, I guess, I would see 24 the definition of "safety-related" restricted to the 25 SSCs needed to form your -- what you call your primary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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173 1 safety functions.
2 MR. RECKLEY: Right. I guess that may be 3 saying the same thing, but from the other direction.
4 Do I think it's likely that most advanced reactor 5 developers can show they don't need a human to meet 6 the 25 rem first tier criteria? I would hope so.
7 But we'll put it in there and then it will 8 be up to them to show that they don't actually need 9 human intervention.
10 MEMBER REMPE: So, I thought Walt was 11 going to go a different direction with his questions 12 because we were involved in an activity not too long 13 ago where it appears that an operator was required for 14 recovery to put the reactor in a safe, stable state 15 and the -- there was not really any documentation to 16 support it or what would happen if an operator didn't 17 act as expected.
18 And so, it sounds to me like you're 19 actually going to require some more documentation 20 about operator actions if they're needed, which I was 21 wondering if some of the stakeholders were concerned 22 about that.
23 MR. RECKLEY: We didn't hear too much.
24 But after you pointed it out, then we might hear next 25 round.
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174 1 (Laughter.)
2 MEMBER DIMITRIJEVIC: I have a question 3 about your third category, non-safety-significant.
4 Can safety-related things be in that 5 category?
6 MR. RECKLEY: No. That's the -- that's 7 really the remaining category for which the only 8 expectation for non-safety-significant SSCs would be 9 commercial-grade equipment and whatever restrictions 10 a designer or licensee wanted to put on it for their 11 own reasons not really -- nothing beyond commercial-12 grade being built into the safety assessment.
13 MEMBER DIMITRIJEVIC: So, my question is 14 here you're not using any risk insights, right, to 15 classify your conformance?
16 MR. RECKLEY: It depends on what the 17 approach would be. Under one acceptable method, which 18 is the NEI 18-04 method, risk insights are integral to 19 the determination especially of the non-safety-20 related, but safety-significant category.
21 That is going to be those events that are 22 coming out of the PRA as being needed to support 23 findings related to the NRC safety goal, as an 24 example.
25 MEMBER DIMITRIJEVIC: I think it's a very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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175 1 small category in the current PRAs. It's a much 2 bigger category is safety-related, non-safety-3 significant components. And this is what the most of, 4 you know, 50.69 is about, but you don't have this 5 category here.
6 So, you know, this category of non-safety-7 related or safety-significant is a very small 8 category. So I'm just surprised that you have 9 actually -- the biggest category, which this NEI guide 10 and 50.69 devotes a lot of things deserves special 11 treatment, reduction is a category where you have 12 safety-related but not risk-significant component.
13 MR. RECKLEY: The logic there is that that 14 process in 50.69, in general, comes out of a 15 historically very deterministic approach to the 16 classification and then overlaying a risk assessment 17 and finding that there were many safety-related SSCs 18 that, from the PRA's point of view, weren't really 19 contributing as much as expected to the risk argument.
20 And so, there was a category basically 21 created to address that and lower the expectation on 22 that set -- or subset of safety-related equipment.
23 Going into a new design the thought is 24 that a reactor designer will not over-classify 25 equipment such that you then have a category of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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176 1 safety-related but not safety-significant.
2 So, that was the reason that we even omit 3 this because it can be avoided from the initiation of 4 the design.
5 MEMBER DIMITRIJEVIC: So, it's a different 6 safety classification than we are to use now. That's 7 what will take care about this category. That's what 8 you are saying.
9 MR. RECKLEY: Yeah. The definition -- the 10 definition of "safety-related" should limit the amount 11 of equipment going into that category.
12 So, there should not be -- in our view, 13 there should not be as much over-classification as 14 might had been done in the earlier days of the 15 operating fleet.
16 MEMBER DIMITRIJEVIC: Alright. Thank you.
17 MEMBER KIRCHNER: Just an observation, 18 Bill. Are you going to reconcile this set of 19 definitions, these three bullets, with your colleagues 20 who are doing 10 CFR 50 and 52?
21 I think it would help immensely because 22 then when it comes to Reg Guides, we won't have the 23 four boxes that we often see as the -- kind of the 24 framework in the Reg Guides. So, getting this 25 simplified across the board would be certainly useful.
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177 1 But I wanted to go back to Dennis and say, 2 Dennis, did you say non-safety-related but risk-3 significant would be preferred?
4 CHAIRMAN BLEY: Preferred to what? I'm 5 not sure -- you're going way back in whatever I said.
6 My own thoughts in this area are that 7 safety-related is a holdover from the time of kind of 8 guessing what was going to be important and slapping 9 a classification on it.
10 Now that we have a risk assessment to pin 11 that down, the things that are risk-significant are 12 the things that ought to be treated as we always 13 treated safety-related and we shouldn't arbitrarily 14 declare anything safety-related, from where I stand.
15 Now, what they're doing because they're 16 going to have a PRA up front, they're going to know 17 what's important and they're going to develop their 18 own design-basis accident, the things that go into 19 that category are, you know, kind of meets what Bill 20 was saying before.
21 It's going to be self-regulated such that 22 almost anything that meets their label of "safety-23 related" will also be risk significant or is likely to 24 be risk significant.
25 So, I'm kind of okay with where they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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178 1 going. It's just I would have done it differently.
2 MR. RECKLEY: Okay. If we go, then, to 33 3 we've had this discussion somewhat, special treatment.
4 And this will be established that, you know, it has to 5 provide appropriate confidence.
6 The safety-related stuff we've already 7 talked about, it will fall under Appendix B. It would 8 fall under the existing PRA requirements defined under 9 Appendix B.
10 It would fall under technical 11 specifications and so forth. So, special treatment as 12 it's applied to safety-related will look much the way 13 it currently is described for the operating fleet.
14 The big change really will be the kind of 15 expansion of the discussion of special treatment for 16 non-safety-related but safety-significant SSCs and 17 making sure that they will perform as they're assumed 18 to perform under the right service conditions, under 19 the appropriate environmental conditions, and that 20 they're available and reliable as it's been modeled in 21 showing that they meet the second tier safety 22 criteria, which is currently proposed to be the QHO.
23 So, it's really the expansion of those 24 requirements in order to allow us to take more credit 25 for those, that category of equipment and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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179 1 performance of those functions to meet the QHOs that 2 then supports going forward in some of the other areas 3 that we'll talk about.
4 And then as Walt brought up human actions, 5 we thought even here to start to bring in the 6 discussion of human actions more so than what you'll 7 see in current regulations under Part 50, for example, 8 to start to build the argument that would be possibly 9 used in the later subparts on staffing levels, on the 10 development of concept of operations, which would 11 actually be more definitive in terms of this is the 12 role of people in meeting the safety objectives.
13 If we go to 34, this is an area I thought 14 we would probably have a fair amount of discussion on.
15 And I think we're okay still on time, but I will try 16 to speed it up a little bit.
17 But the -- this is where the flexibility 18 for advanced reactors starts to be introduced and this 19 was our attempt to say how you can capture that.
20 And it's through the analysis that would 21 show you're meeting some threshold, some target that's 22 been established by the designer that's more 23 restrictive than what would otherwise be required.
24 And the margin you gain from showing you 25 meet a lower threshold is the avenue to get relief in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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180 1 some other area.
2 So, the easiest one to explain, because 3 we're all familiar with it, is you run through your 4 licensing basis events. The expectation is most 5 advanced reactor designers will try to show that, at 6 the fence, they don't exceed the 1 rem in a month or 7 1 rem in 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> and, therefore, they can justify an 8 emergency planning zone that collapses to the site 9 fence or at least much closer to the site fence.
10 So, how is that arrived at? That's 11 arrived at picking 1 rem, which is more restrictive 12 than showing you meet either the -- than you would 13 show by the -- through meeting the QHOs and 14 establishing a more restrictive criteria.
15 And then the requirement, as it's written 16 in 470, is once you do that -- the goal of the 17 requirement in 470 is once you do that, that becomes 18 your new design standard that you have to show you 19 continue to meet because this has been one of the 20 questions of how once I set that and now I set things 21 in motion for the next 20 years and I do system 22 changes, I do power uprates, I do whatever, how do I 23 maintain the fact that I justify that I don't exceed 24 1 rem at the site and, therefore, don't need emergency 25 planning that has to be maintained throughout the life NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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181 1 of the facility or I have to have an option of 2 bringing emergency planning back into the possible 3 overall framework for that facility.
4 So, 53.470 is the avenue by which we're 5 trying to do that. And I know it's only a paragraph, 6 but it's a critical paragraph within Part 53 because 7 it's, again, saying I can establish more restrictive 8 goals.
9 And with the margin that I get from that, 10 I can trade it off against requirements that are most 11 likely going to be in Subpart H under Operations.
12 This is how I'm going to do siting, maybe 13 more flexibility in siting, more flexibility in 14 emergency planning, perhaps more siting -- more 15 flexibility in security, more flexibility in staffing.
16 And so, with that, I'll just kind of open 17 it up for discussion again because, from my 18 perspective, this is -- we've talked about advanced 19 reactors and how you can get some of the flexibility 20 that's been expected and this was our vehicle to try 21 to do that.
22 Dennis?
23 CHAIRMAN BLEY: Yeah. I was waiting to 24 see if somebody had discussion. And this is probably 25 a good place for a break.
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182 1 Do you think so, Bill?
2 MR. RECKLEY: Yeah, that's fine. And, 3 again, maybe during the break people will think about 4 this because this -- it goes to some of the earlier 5 discussions as well.
6 I mean, this idea that -- and this is 7 built on the fact that you do the analysis and from 8 the analysis you get the relief.
9 There's been, even today, some discussion 10 of isn't there a shortcut to even do less analysis?
11 So, we would have to work such an approach into this 12 construct.
13 I'll admit it's not currently there, but 14 whatever people wanted to do through the shortcut, you 15 also have to show, through that simplified assessment, 16 that you're confident that you're going to be 17 justifying all the relief that is being expected in 18 these other areas.
19 So, I'll kind of leave that as a thought 20 for people to consider during the break.
21 CHAIRMAN BLEY: Okay. That sounds good.
22 It's about 10 minutes till. Let's take a 20-minute 23 break. Come back at 10 after -- what is this back 24 east? Anyway, come back in 20 minutes.
25 (Whereupon, the above-entitled matter went NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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183 1 off the record at 3:48 p.m. and resumed at 4:10 p.m.)
2 CHAIRMAN BLEY: The question and 53.470 3 appears to be linked to the Tier 2 stuff and in the --
4 pardon?
5 MR. RECKLEY: Take us back to where you 6 were, if you would. This seems a little hard to parse 7 I guess for me.
8 MEMBER REMPE: Bill, if you're talking, 9 you're on mute.
10 MR. RECKLEY: Oh, there we go. Sorry 11 about that. It is difficult because it's the attempt 12 at trying to make this flexible and yet integrated so 13 in the bowtie figure of how you might capitalize on 14 the assessments that are done under 53.450. And to 15 use them to justify operating flexibility and so, as 16 Dennis mentioned, basically you're the, an applicant 17 would be setting up an alternative threshold that's 18 more restrictive than the regulations.
19 And then the goal of 53.470 is to just 20 maintain those. Once that decision is made to make 21 sure that all of the analysis and then all of the 22 subsequent programmatic controls are in place, to 23 maintain it.
24 The actual trading off of the margin will 25 be reflected in the later Subparts and again, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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184 1 example would be emergency planning where it can be 2 shown that the doses are less than one rem over the 3 time period.
4 You can use that to justify an alternate 5 emergency planning zone in siting, you could do the 6 dose calculation and if you meet the revised threshold 7 you could revise the population density guidance from 8 500 people per square mile out to 20 miles to some 9 lesser distance.
10 And we're looking to how that might 11 actually then also go into the concept of operations 12 and the possible justification of reduced staffing and 13 other areas, security and other areas.
14 We might be able to use that same logic 15 and so, again, it's a short paragraph but the intent 16 of it is to explicitly allow the tradeoff and then set 17 the requirements in place to maintain them after that 18 tradeoff is made.
19 MEMBER CORRADINI: So Bill, this is 20 Corradini, can I ask the question a little 21 differently? If this weren't explicitly written, that 22 still would be allowed it just wouldn't be explicit.
23 If they were to follow the, your 24 discussion about one rem at the boundary, that 25 allowed, that could allow them to do this. This just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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185 1 makes it an explicit opportunity. That's where I'm 2 confused. I thought this flexibility always existed.
3 MR. RECKLEY: It does both. It highlights 4 the opportunity and then it puts in place the 5 requirements to maintain it.
6 MEMBER CORRADINI: I got it now. I got it.
7 CHAIRMAN BLEY: So if I design my plant to 8 be more robust then I can cut some of my margins in 9 other areas but this requires me to keep, maintain 10 that robustness?
11 MR. RECKLEY: Right. Or to revisit how 12 you were trading off the margins.
13 CHAIRMAN BLEY: Sure. So, if I do that 14 because this is Tier 2, if I'm beginning to get where 15 you're headed with that, this is Tier 2 so, if I 16 decide to rebalance those margins, I have the freedom 17 to do that. Now you might come in and audit me on it 18 but it's something I can do on my own?
19 MR. RECKLEY: As we develop the Subparts, 20 yeah. Keeping in compliance, yes. You'll have the 21 inherent flexibility. The notion of not including 22 Tier 1 is that those things are not intended to have 23 flexibility.
24 CHAIRMAN BLEY: Right.
25 MR. RECKLEY: You will always meet Tier 1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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186 1 and you'll always meet it basically the same way.
2 There is no tradeoff of emergency planning in Tier 1 3 for example or any other criterion.
4 It's also based on an individual dose 5 number versus, well I won't get into that. So --
6 CHAIRMAN BLEY: Another thing that would 7 be very helpful to have explained then in the SOCs or 8 early in some kind of whitepaper.
9 MR. RECKLEY: Okay. Seeing no other 10 activity at the moment, we'll finish out the design 11 section in the next 10 or 15 minutes and then get into 12 siting. The, yeah, if we go to the next slide.
13 The quality assurance for design was 14 basically just Criterion III from Appendix B, which is 15 the Criterion related design activity.
16 And again, we brought in that it would 17 comply with generally accepted consensus codes and 18 standards of which we've already identified in QA one 19 as being one of those.
20 One of the discussions that we will have 21 going forward is if other consensus codes and 22 standards like the ISO standards might also fulfill 23 that expectations.
24 MEMBER PETTI: So, Bill, do you see a gap 25 analysis or something in the future with when we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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187 1 compare Appendix B to these other quality standards 2 and see if they really do cover all the bases?
3 Because I've heard different, I've heard 4 people steeped in this stuff tell me that ISO in no 5 way comes up to the level of NQA-1 Appendix B.
6 MR. RECKLEY: And the NRC did its study 7 and it varies by which criterion and activity you're 8 looking at but other places have taken, this is 9 stretching my memory here, which is not a good thing.
10 But there's been a nuclear component added 11 on to some of the ISO standards to kind of fulfill --
12 MEMBER PETTI: Ah, okay.
13 MR. RECKLEY: -- where some of those gaps 14 exist. So, it's not clear you could take the most 15 general of the ISO standards and simply say, I will 16 follow that but there has been activity to supplement 17 them to make them more amenable to the nuclear 18 community if you will.
19 Is my understanding. But yes, somebody 20 would have to show that the consensus codes and 21 standards that they're referencing actually fulfills 22 the underlying desire and provides the confidence 23 that's provided.
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188 1 to show for a particular activity like design versus 2 showing some collection of ISO standards meets the 3 equivalent of NQA-1 in its totality.
4 But we'll see as we get into additional 5 interactions. But --
6 MEMBER KIRCHNER: Bill, this is Walt.
7 Having looked at this a while back and I have to admit 8 it's a while back, I would say something along the 9 lines that David just suggested that the simple ISO 10 9000 would not come quite up to measure with the 11 totality of NQA-1.
12 I would also even suggest that of the 13 DOE's QA standard, which is derivative from NQA-1 and 14 after a fashion. The danger I see in breaking down 15 things like this is that yes, you'd have section in 16 NQA-1 that's design controlled.
17 But there are many other aspects to NQA-1 18 that support your ability to maintain that design 19 control. It's things as simple as records. So, it's 20 a little, if you pick and choose from Appendix B, be 21 careful because it's the integrated, all 18 sections 22 of NQA-1 that as a whole that really, you know, give 23 you the total effect.
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189 1 not complete. You see where I'm going with this?
2 MR. RECKLEY: I do and it is something 3 we're looking at and as we take the concept as I 4 mentioned earlier, we're not exactly wedded to this 5 breaking apart. It was a notion.
6 But when you see Appendix E on 7 construction, which is primarily quality assurance, we 8 really ran into something exactly what you're saying 9 because what do you do with the requirements for 10 audits and things that go beyond that particular 11 activity and are really aimed at the QA program 12 overall.
13 And so, it's a point well taken and we're 14 looking at it. We'll see kind of, taking this 15 attitude of wait and see once we get it all together 16 and if it makes sense that's fine or if it makes more 17 sense to put it back together.
18 The way we're doing it, it's easy to also 19 put back together if that's decided that's the best 20 way.
21 MEMBER BALLINGER: This is Ron, the ISO 22 standard that you're talking about is 19443, which I 23 have and it's pretty extensive.
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190 1 versed in the ISO numbering scheme and even the 2 content. So, but today's point yeah, somebody would 3 have to do that assessment. The last time the NRC did 4 it, it was, I think 10 or 15 years ago.
5 MEMBER BALLINGER: Yeah, this standard was 6 issued in, around 2018.
7 MR. RECKLEY: Okay. So, that's really all 8 I had on that one. If we can go to 36.
9 MEMBER PETTI: Just one more question.
10 MR. RECKLEY: Sure, Dave.
11 MEMBER PETTI: That's come up. In terms 12 of the ASME code to use, would an ASME accept a 13 Section 8 vessel instead of a Section 3 vessel if for 14 some reason the material was unique or the inability 15 to get an N stamp.
16 It is a code in standard, it is accepted 17 in many places but it's not, you know, it's not the 18 nuclear part of the code. Is that a hard rule on 19 that?
20 MR. RECKLEY: I'm not going to give you a 21 straight yes, no answer. We'll look into that and it 22 would depend on really the technology and what was 23 being derived from the reference to that code.
24 MEMBER PETTI: Okay.
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191 1 we'll necessary rule it out but we would have to look 2 and see what was in that division and make a judgement 3 on what was being provided.
4 MEMBER PETTI: Okay.
5 MR. RECKLEY: Okay. If we can --
6 MEMBER DIMITRIJEVIC: How -- sorry, this 7 is Vesna. How about the PRA code? The PRA now, they 8 been using design. Is it going to be applicant's --
9 up in addition to PRA standard.
10 MR. RECKLEY: The PRA itself, our thinking 11 is would be governed the PRA standard. So, either the 12 light water or non-light water reactor standard and 13 then the assessments that are built into that 14 standard, the independent reviews and so forth.
15 MEMBER DIMITRIJEVIC: All right.
16 MR. RECKLEY: So, if we can go then to 17 Slide 36. There's a section on interfaces that we'll 18 probably build in to all the Subparts just to try to 19 reinforce that they all have to fit together.
20 If we go on into 37, this is one of the 21 things we put out to stakeholders when we released 22 this Subpart as a question and that is, the treatment 23 of inherent features, basically those things that are 24 governed by physics without either a need to activate 25 or have an active or a passive engineered system to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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192 1 provide and whether it would be useful to have 2 additional discussion and guidance.
3 And it might help to go on then to 38, 4 which is Slide 38. This is Idaho National Lab, kind 5 of figure that basically goes through that for any 6 design you have basically the same concept we were 7 talking about before.
8 You have an inventory, you have a number 9 of barriers and traditionally you have originally for 10 large light water reactors, for the most part you had 11 active engineered features to do things like maintain 12 cooling of the cladding.
13 Then pressure relief to maintain the 14 pressure boundary and containment cooling systems to 15 maintain the reactor building in the final barrier. As 16 you move forward in time you started to have passive 17 systems to perform those roles.
18 And then at the bottom is just the concept 19 that it is possible to have for some designs and some 20 technologies and some power levels the ability to 21 perform those functions using inherent features.
22 Like reactivity feedback or heat removal 23 that might depend only on conduction and radiation and 24 not need a circulation path perhaps and so, as most of 25 you are aware, as we moved from active to passive NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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193 1 there were was a lot of guidance written.
2 A lot of thought that went into moving 3 from active to passive and just the question is if we 4 are to be moving from passive to inherent, what 5 additional guidance, what other discussions would be 6 needed to support to moving in that direction? You --
7 MEMBER MARCH-LEUBA: What's the difference 8 between passive and inherent? And haven't we been 9 taking credit for all this reactivity for bad, we take 10 credit for it all the time?
11 MR. RECKLEY: No, not exactly, Jose. What 12 they're proposing here, I believe, is that the 13 negative temperature coefficient of a solid moderator 14 is a shutdown mechanism. And so, I don't need --
15 MEMBER MARCH-LEUBA: If you're over --
16 MEMBER KIRCHNER: Yes, but not if you cool 17 down.
18 MEMBER PETTI: Well, if you cool down 19 super low but I'm just talking about it turns it 20 around so, do I have to have, you know, two --
21 MEMBER MARCH-LEUBA: So, does void 22 fraction in a boiler, I mean, if you overheat a 23 boiling water reactor it will produce voids and it 24 will shut down. It will maintain k-effective one 25 eventually, is what everyone of this is going to do.
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194 1 This is part of the analysis. It's part of your 2 effected margins.
3 (Simultaneous speaking.)
4 MEMBER KIRCHNER: Bill, to the extent that 5 people take credit for these inherent or passive 6 features, it would seem to me the logic that would be 7 applied would be similar to what you discussed a few 8 slides earlier about trading off analytical safety 9 margin.
10 So that you would have to demonstrate that 11 this is maintained over the lifetime of the plant. In 12 other words, you know, as you go through a burnup 13 cycle the negative temperature of coefficients may 14 change.
15 As you go through leaving a plant operate 16 for 40 years we may have, I'll make something up, you 17 may have CRUD deposition on a boundary that is 18 passably cooled and that reduces the cooling rate.
19 So, you know, it erodes the, over time the 20 performance that you had been credited for in the 21 initial analysis. So, it seems to me, these things 22 should be encouraged but they would have to be, how 23 should I say it, maintained over the lifetime of the 24 plant.
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195 1 tech specs is the right vehicle for doing that you 2 would have to be able to demonstrate that those 3 credited features over the lifetime of the plant would 4 still, you know, provide the desired performance.
5 MEMBER MARCH-LEUBA: Yeah, I don't think 6 the reactivity from that is going to degrade with what 7 lies instead. The problem I have actually, I have an 8 aversion to this, the first year replaces General 9 Design Criterion-27, thou shall have a shutoff 10 mechanism, that keeps the reactor shutdown, meaning k-11 effective less than one.
12 By controlling the heat rate. Meaning 13 that as long as you increase the heat rate a little 14 bit you will get a reactivity feedback and you will 15 maintain k-effective of one no matter what happens 16 under any conditions.
17 That's not the same thing as GDC-27. I 18 only think that you need to consider having a GDC-27 19 to the Tier 1 safety criteria. Shutdown of a reactor 20 must be a fundamental principle.
21 Being able to shut it down and not letting 22 it run out, run off when the temperatures was high 23 because you got activity feedback, it's not the same 24 as shutting down.
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196 1 a comparison, I don't know if you know this, the 2 pebble bed reactor in China, the small one, HTR-10, 3 they shut it down by shutting the circulator off, 4 letting the temperature rise, very tiny rise. And 5 then the temperature coefficient brings it down and 6 then xenon builds in.
7 MEMBER MARCH-LEUBA: That's correct. All 8 of the gas cool reactors do that.
9 MEMBER PETTI: Well all, lots a solid 10 moderator and I think we're going to see a lot of 11 different in innovative solid moderators come out in 12 the micro-reactor space beyond a graphite.
13 And they all tend to have this behavior 14 and it's just something that we haven't looked at, you 15 know, in the U.S., solid moderators besides graphite 16 haven't been plenty since the 70s.
17 MEMBER MARCH-LEUBA: But this is a backup 18 for the shutdown system.
19 MEMBER PETTI: No. This is where, this is 20 the key issue is that some designers I know want to 21 say that is their primary, that it's a safety 22 function. It's how they're going to implement the 23 safety function and then they'll use the LMP in the 24 second system, the rods in essence become that middle 25 category of the three in the characterization.
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197 1 MEMBER KIRCHNER: Yeah. But, Dave, you 2 know, sooner or later that system cools down and you 3 need the rods to effect a, as Jose is saying, a 4 positive shutdown.
5 MEMBER PETTI: For sure --
6 (Simultaneous speaking.)
7 MEMBER PETTI: -- function of the five in 8 terms of what power level it backs to, all that stuff.
9 MEMBER MARCH-LEUBA: And then our lessons 10 been learned that you have to analyze the transient to 11 its logical completion. In one reactor like this it 12 might be three months.
13 But you're leaving the reactor hot for a 14 while, eventually it's going to cool down and you're 15 going to return to power. You're not taking it to a 16 safe and a stable condition.
17 It might be acceptable. It's really great 18 that they have it but you are in a degrading, a 19 continuously degrading condition. You're --
20 (Simultaneously speaking.)
21 MEMBER PETTI: Yeah, but what if --
22 MEMBER MARCH-LEUBA: -- the rods.
23 MEMBER PETTI: But we just allowed a 24 design because they didn't violate SAFDLs to go 25 through a very similar approach.
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198 1 MEMBER MARCH-LEUBA: Yeah. No, it's okay 2 but we consider that, that's a defense-in-depth. I 3 don't know, so --
4 (Simultaneous speaking) 5 MEMBER PETTI: All I'm saying is that they 6 could --
7 MR. RECKLEY: So anyway --
8 MEMBER BROWN: Not all of us agreed with.
9 MR. RECKLEY: So again, I'll leave this 10 maybe, because we posed it as a question, we're not 11 proposing an answer. Yes, such features to some 12 degree have been built in before.
13 But as Dave is suggesting, the question 14 is, as they become the front defense mechanisms, what 15 additional guidance would we need and what, you 16 mentioned some of the concerns.
17 What we're posing to stakeholders is, to 18 what degree are proposing this that such that we need 19 to develop guidance to make sure that if you're 20 crediting an inherent feature, you're staying within 21 the boundary conditions in which you're confident that 22 that behavior is guaranteed.
23 Both within things like physical 24 conditions, temperatures and so forth, then over the 25 life of the facility, all of the questions that you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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199 1 raised.
2 So again, this question we're posing and 3 based on the feedback it might be another area where 4 guidance might be developed.
5 If we also need to look at the rule 6 language to support it, that might be another thing 7 that we talk about in a future iteration.
8 So, just so we can do design, I think 9 we'll go on to the public comments. Most of these 10 I've already talked about --
11 MEMBER MARCH-LEUBA: Before you go there 12 on that line, the problem I'm having, I put myself 13 with my hat as reactor designer with this rule is that 14 you having so much flexibility that I don't know what 15 you're approving and you're not approving.
16 I'm going to either be very concerned 17 about it and not believe you want to approve or yes, 18 think you want to approve and go see, bring it around 19 and see if you approve it.
20 The guidance doesn't tell me if I can do 21 this or not and this is not the only, I mean, there 22 are many where you say well, bring us a proposal and 23 we'll look it.
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200 1 to proposal needs to satisfy, which leaves me with a 2 lot of licensing uncertainty.
3 Yes, put it on the record. I know you 4 don't want to prescript it but there is a perfectly 5 good alternative, which is using exemptions when you 6 want to get out of the rule. As it is, I don't know 7 what you want me to do.
8 MR. RECKLEY: Okay, thank you. So, let's, 9 so again, I've talked about most of these in terms of 10 the comments and even given the hint at the direction 11 we're going.
12 The discussion of occupational dose, we 13 talked about the need to continue the discussion on 14 generally accepted in terms of Consensus Codes and 15 Standards.
16 I mentioned there was a suggestion that 17 security could be put off and be addressed by the 18 overall security program and not included within the 19 design activities, within this Subpart. Going on to 20 Slide 40.
21 A lot of discussion and we had it here 22 today, very similar discussions of not using the PRA 23 for the purpose of selecting your licensing basis 24 events and safety classifications.
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201 1 review, allow more, allow other approaches. Some 2 discussion that even the PRA itself should be 3 optional.
4 One issue that's come up kind of as a 5 continuing theme is our discussion all along in the 6 rulemaking plan, and even before the rulemaking plan, 7 was that we would use the guidance in Reg Guide 1.233, 8 the NEI 1804 methodology as one acceptable way for 9 this rule to be, to meet this rule.
10 And one of the comments, again a recurring 11 a theme has been, the rule may lean too much in that 12 direction. That it might actually end up requiring or 13 not allowing any other approach or requiring the use 14 of LMP.
15 And so, that's one of the areas where 16 we're looking trying to strike the balance to maybe 17 provide alternative but as we've said all along to 18 maintain that methodology is one acceptable way to 19 meet this rule.
20 That was, you know, from our perspective 21 that's why we undertook that initiative back when we 22 were doing LMP. We said we foresaw it being used for 23 what is now Part 53, so, you know, it was part of the 24 rationale for everything we've done in the last three 25 or four years.
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202 1 So, we want to maintain that. At the same 2 time, we're hearing those that are complaining or 3 observing that maybe we're precluding other methods.
4 So, as we prepare the next iteration, we'll look at 5 alternate approaches. Maybe more deterministic 6 approaches.
7 Then another discussion about consistency 8 with IAEA or other regulator's approaches that look at 9 PRAs somewhat differently and build them into the 10 regulatory structure somewhat different than what we 11 had proposed here. So --
12 CHAIRMAN BLEY: Bill?
13 MR. RECKLEY: Yes?
14 CHAIRMAN BLEY: As I read information from 15 various sources, a lot of this emphasis on developers 16 seems to be that they really are hoping for 17 consistency in regulation internationally so that they 18 can sell these things in many different places without 19 doing a full, you know, review everyplace they go.
20 Does that seem what they're after to you?
21 MR. RECKLEY: Yeah, that's the comment on 22 the international frameworks. That, to the degree we 23 can try to either be consistent with or at least that 24 whatever we put into this rule doesn't require 25 starting all the way over from scratch to go to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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203 1 another approach.
2 It is the desire. So, again, it's 3 something we're looking at and trying to do. We're 4 aware of this kind of issue and desire even before.
5 I think we've talked to you before about 6 having agreements with CNSC, the Canadian Nuclear 7 Safety Commission and kind of looking at our 8 approaches.
9 Because there are a number of potential 10 applicants that would look at both countries and then 11 obviously were involved in IAEA and some other 12 activities. So, yes. We're trying to do that.
13 Going on to 41. Some other observations 14 has been that defense-in-depth, while it's a good 15 philosophy should be addressed somewhere other than 16 incorporating it into the regulations.
17 Or, maybe and/or the guidance we could 18 clarify, what would be a defense-in-depth analysis 19 when either you're using an approach other than 20 licensing modernization that includes a methodology 21 for a defense-in-depth.
22 Or reflecting the decision, the discussion 23 we just had when there's a reliance on inherent 24 features, what additional measures might be taken for 25 defense-in-depth above those provided by the IAEA.
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204 1 What would be considered an inherent feature?
2 So, those are the, kind of discussion 3 points. Think we have one more slide, 42. So, that's 4 really the discussion and a summary of the feedback 5 we've gotten on Subpart C.
6 I think I can get through Subpart D 7 deciding one in the allotted time here. Largely 8 because Subpart D will look very familiar. We are 9 largely, we're not proposing dramatic changes to what 10 goes into the siting considerations.
11 But any last-minute discussion on Subpart 12 C, the design and analysis Subpart?
13 CHAIRMAN BLEY: No. But just a quick note 14 from me. We wrote a letter a year and a half ago on 15 your draft SECY paper on siting considerations for 16 advanced reactors, went with you toward option three.
17 Do you, in your opinion, is what you have in here 18 pretty well consistent with that?
19 MR. RECKLEY: Yes. In so, and the 20 language is the same. Actually, in our proposed 21 Subpart D the language is pretty much the same as the 22 existing language in part 100 and therefore the 23 methodology and flexibility that would come with the 24 options that we describe in SECY-20-45 would be 25 available under this.
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205 1 But we didn't mention it specifically but 2 it would be available because it was written to this 3 language that comes out of Part 100. I'll talk about 4 that as we, when we talk on the population slide.
5 CHAIRMAN BLEY: Okay, good.
6 MEMBER BROWN: This is Charlie. I did 7 have one comment or maybe it's a question, I'm not 8 sure which. This is on Slide 41, about the defense-in-9 depth required when you've got physics or inherent 10 features.
11 That it always disturbs me a little bit 12 when we think maybe DID is not required when some 13 unknown accident progression that nobody envisions all 14 of sudden rearranges, disturbs the inherent and/or the 15 physics-based feature.
16 A lot of stuff we don't know that we found 17 out later when we're doing designs, we're not familiar 18 with. So, I hope NRC is not compromising and leaving 19 -- I thought incorporating DID into the overall 20 thought process was the right way to do it. I hope 21 you don't throw that out. It's just my observation.
22 MR. RECKLEY: Yeah, this comes into play 23 specifically under our defense-in-depth proposal. We 24 had a requirement that no single element be credited, 25 I mean not -- be relied upon.
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206 1 And so, this question kind of comes in the 2 context of, well what if you have some inherent 3 feature, do you really need to back it up and again?
4 The comment was coming in the context of 5 the DID requirement that we included in the first 6 iteration that included the sentence, no single 7 feature shall be totally relied upon, words to that 8 effects.
9 MEMBER BROWN: Did you eliminate that in 10 your, did we not see the original version?
11 MR. RECKLEY: You saw the original 12 version. We're working on evaluating comments to see 13 if we might change anything in that regard.
14 MEMBER BROWN: If you decide to throw out 15 defense-in-depth you ought to explicitly address it 16 with us.
17 MR. RECKLEY: Oh, we will. When we come 18 in a future meeting, probably the March meeting if we 19 have one set up in March. We'll be bringing any 20 revisions we made to B and C in light of ongoing 21 discussion.
22 And then, as I said, these are going to be 23 continually iterated because we continue to get 24 comments, we continue to learn as we develop future 25 Subparts that something needs to be changed to make it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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207 1 work.
2 And so, this will be dynamic all the way, 3 well, logically, I mean, it'll probably be dynamic all 4 the way through the process. But at least until we 5 start to get the package together in the Fall.
6 We'll be constantly iterating. Hopefully, 7 converging so that each iteration is making less and 8 less changes, just tweaks. But yes, we would probably 9 come to you at the next meeting with any changes we're 10 thinking about for B and C, Subparts B and C.
11 MEMBER BROWN: Okay, thank you.
12 MR. RECKLEY: And then as Dennis has 13 pointed out, anytime you see us going in the wrong 14 direction, you can, you have an option then of saying 15 hey, maybe this is something that needs to come before 16 the full Committee.
17 (Simultaneous speaking.)
18 CHAIRMAN BLEY: I would say it happened 19 years ago, as recently as maybe 10 years ago is 20 everybody knew what defense-in-depth meant but you 21 didn't find in the rules and it essentially meant 22 something different to everybody.
23 I think the work that was done by the 24 staff on putting together the NUREG --
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208 1 management.
2 MEMBER KIRCHNER: Yeah, KM009.
3 CHAIRMAN BLEY: -- was really useful and 4 I'd hate to see it disappear. I mean, what we got 5 here is, when, it's essentially a fill the gap, as 6 Charlie was in saying in another set of words.
7 It takes care of, it helps cover our 8 uncertainty in identifying the areas where we have 9 uncertainty and making sure we have sufficient 10 defense-in-depth to support those areas is really 11 important.
12 It was one place I thought NEI, 19-04, 20-13 04 on the LMP did a really, the best job I've seen of 14 explaining how you bring all of the quantitative and 15 qualitative ideas together to really decide how much 16 defense-in-depth you need.
17 Twenty years ago, we'd gone so far 18 anything anybody wanted they just said defense-in-19 depth and we had no control of it. Pushing it aside 20 doesn't make much sense to me. I think refining it a 21 little bit here is important. But, you know, again, 22 it's one member.
23 MR. RECKLEY: Yeah, and I want to -- go 24 ahead. I'm sorry, Walt.
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209 1 jump in, Dennis, and say that or suggest that, and 2 Mary Drouin's work has a short list of considerations 3 and this second bullet is bothersome to me as it 4 probably is to Charlie.
5 I mean, I can't, I'm an advocate of these 6 advanced designs with inherent safety features and so 7 on but maintaining multiple fission product barriers 8 is just, you know, you can't, you have to have a 9 reasonable balance.
10 And you can't overly depend on one design 11 attribute. So, some, I, like Dennis said, I would 12 hope you do not drop this.
13 I think there's a way in your rulemaking 14 to very concisely in a paragraph outline what you mean 15 by defense-in-depth. So that would-be applicants have 16 at least a conceptual idea of what you are, what you 17 mean by DID as pertains to 10CFR 53.
18 MR. RECKLEY: Okay, thank you. And I 19 don't want exaggerate that stakeholders are not, are 20 wanting to do away with defense-in-depth or even in 21 some of the previous discussions as low as reasonably 22 achievable.
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210 1 stays as policy and philosophy and what gets 2 incorporated.
3 So, we saw this largely as an opportunity 4 to look at the policy statements that were done over 5 the last 30 or 40 years and there was a reason they 6 were adopted as policy statements as opposed to trying 7 to incorporate some of that into Part 50.
8 But given we're starting from scratch our 9 thought was this is an opportunity to take what the 10 Commission has said is important and important enough 11 to write down in a policy statement and actually 12 incorporate it into the, kind of the infrastructure of 13 the rule.
14 But again, that'll be something that as we 15 go through the iterations, we'll work out what 16 actually gets incorporated into the rule and what 17 might be addressed by guidance documents or remain as 18 Commission policy.
19 MEMBER KIRCHNER: Well, didn't you state 20 that defense-in-depth is policy or a philosophy, would 21 it not fit in, Bill, in your Part B?
22 MR. RECKLEY: Oh --
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211 1 know, then you can look for either in the design 2 section, Part C or you can look at it in the, I forget 3 which letter is operations, where you do defense-in-4 depth through tech specs or administrative and 5 programmatic controls.
6 MR. RECKLEY: Right. So again, I think 7 we're all-in agreement. We put it in there in the 8 first place. Maybe I should just cut to the chase, 9 expect it to stay there.
10 But we are listening to the nuances as 11 well, so there's, you know, the big question of 12 whether to keep it or not and then there's the 13 secondary questions of if it's kept, exactly how it 14 reads and what, is there opportunities to maybe 15 improve how it's written.
16 So, we're leaning at this point, in terms 17 of the next iteration, we're leaning towards the 18 latter, changing the wording a little bit but keeping 19 the overall thought as you read it the first time.
20 So, getting into siting, again, I'm hoping 21 I can get through this relatively quickly. Because 22 it's largely not introducing major changes. The way 23 it fits into the analysis and so forth, changes a 24 little bit.
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212 1 so, going on to 44, there's a 53.500, just a -- you 2 can go onto the next one if you will, 45. There's a 3 general requirement mentioning why, in the biggest 4 picture why we have siting considerations.
5 And it's basically to identify the threat 6 or the hazards that the site introduces to the plant 7 and then vice versa, the threats that the site 8 introduces to the environment.
9 So, looking at in both directions, that's 10 always been the general approach to the siting 11 requirements. The one thing that does get introduced 12 here, although it's not a dramatic change, I don't 13 believe, is the introduction and the tying of the 14 siting to the Subpart B first and second tier safety 15 criterion.
16 And we'll talk about that in large part on 17 the next Slide 46. So, the first part of that 18 discussion is what threat does the environment pose to 19 the plant. That's generally referred to as external 20 hazards.
21 The approach is that SSCs needed to meet 22 the first tier need to be designed to withstand 23 natural phenomena and manmade hazards up to the 24 design-basis external hazard level. And that's a 25 phrase that's taken out LMP NEI 18-04.
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213 1 And basically, it's the same thing we do 2 now, safety-related equipment needs to be designed to 3 withstand an external hazard level up to the design-4 basis earthquake, the design-basis flood, design-basis 5 wind loading.
6 That is basically comparable to what we're 7 doing now. We did add the second sub-bullet, which is 8 a bit of a change but I don't think it's a dramatic 9 change in that we adopted the seismic numbers of 1 in 10 100,000 years.
11 With added margin to address uncertainties 12 to be a standard that would be used for all external 13 hazards. The guidance now, there's a bit of a range 14 from hazard to hazard that's been introduced in terms 15 of the frequency and the probability of exceedance and 16 so forth from hazard to hazard.
17 So that's basically again, is what we do 18 now for safety-related SSCs and it reflects, again, 19 the approach in NEI 18-04 in terms of applying the 20 design-basis external hazard level.
21 We did maintain a specific requirement for 22 the safe shutdown earthquake ground motion and that 23 again, reflects the current requirement including the 24 establishment of the minimum .1g value.
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214 1 in Part 53 that's a departure from where we are now or 2 have been recently anyway. If we go onto 47. This is 3 a new requirement and it actually goes beyond current 4 requirements.
5 And that is, given you have a PRA that one 6 needs to do, the analysis required under 53.450, which 7 is the PRA, needs to address external hazard 8 frequencies and related SSC fragilities related to 9 those hazards within the PRA to the degree that's 10 possible.
11 And so, we're just trying to build in 12 looking forward that the external event PRAs would be 13 done. At the same time, we recognize the state of the 14 art might not be there for all hazards quite yet. Any 15 thoughts or questions on that?
16 MEMBER BROWN: Yeah, just I had forgotten 17 something so, I need you to refresh me. One of the 18 statements in 53.10, if I can make my picture big 19 enough to read it, was that they need to design or 20 address a range of estimated external hazard 21 frequencies to once in 100,000 years.
22 Is that standard on number? 100,000 23 sounds, how can anybody ever believe what you're 24 talking about?
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215 1 --
2 MEMBER BROWN: Okay.
3 MR. RECKLEY: -- the seismic approach.
4 MEMBER BROWN: Okay. I'm not as familiar 5 with the overall seismic stuff. That's why I asked 6 the question. All right. Sounds ridiculous to me, 7 but.
8 MR. RECKLEY: Well actually is the seismic 9 arena, given the ability to look at historical data, 10 that's why they've been able to do that and I'll ask 11 Dennis or somebody or Marty to please jump in, I'm not 12 a PRA expert.
13 But at least in geologic history you can 14 track things like that and so, you do have some 15 ability to look at earthquakes. There are other 16 hazards where you may not have the ability to 17 construct such an approach and that's why the ability 18 to do probabilistic hazard analysis in some other 19 areas is more challenging.
20 (Simultaneous speaking.)
21 MEMBER BROWN: The Mineral Springs 22 earthquake was kind of a surprise up here into the 23 North Anna, near North Anna so, I don't know, I never 24 saw an analysis of that but --
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216 1 can do a good job on the seismic, as Bill said. The 2 thing, surprisingly, it's things like meteorology 3 where we have only a 100-year history.
4 So, there it becomes more difficult to 5 construct the 1 in 100,000 event but certainly in the 6 seismic area, there's good geologic basis for what 7 they've been able to extract there.
8 MEMBER BROWN: Well, I'd like to see 9 somebody show that the one that occurred, that the 10 North Anna and Mineral Springs area in Virginia was 11 outside the 100, once in 100,000 years.
12 CHAIRMAN BLEY: It was not, Charlie. It 13 wasn't --
14 MEMBER KIRCHNER: It was not, yeah. It 15 was within it.
16 MEMBER BROWN: So it, so they didn't meet 17 the metric then? It shouldn't have happened in other 18 words?
19 MR. RECKLEY: Well no, actually the 20 opposite. The North Anna plant was designed for that, 21 it exceeded a little bit but in some frequency ranges, 22 I think. But again, Marty can weigh in.
23 But by and large the plant was already 24 designed for that or very nearly that level of a 25 seismic event.
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217 1 MEMBER BROWN: Okay, thank you. I learn 2 something all the time.
3 MR. RECKLEY: Okay. So, then we can go on 4 to 48, I think. This is again just the need to 5 characterize the site and to gather data on 6 meteorology, the geology, seismology, all of the -
7 ologies in order to understand the site.
8 What would happen if radioactive material 9 were to escape in terms of how would it be transported 10 in air, how would it be transported in water. Again, 11 nothing, this was largely just taken from the existing 12 requirement in Part 100.
13 And it makes a certain amount of sense. I 14 don't think we got any significant feedback that you 15 don't need to characterize the site.
16 You can go on to 49, I guess before we 17 leave site characterization, the potential model and 18 this is, when you get into the micro-reactor realm and 19 if the thought is these are being fabricated in 20 factories and being deployed, whether the degree to 21 which they would take bounding approaches to these 22 external hazards and then be able to also in this area 23 basically say they're compatible with this, you know, 24 this range of sites such that you could minimize some 25 of these evaluations.
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218 1 Along with the general discussion of 2 manufacturing licenses, something we want to 3 understand from the industry and other stakeholders on 4 exactly what is the model and what would Part 53 need 5 to address in terms of this kind of a deployment if 6 that's being contemplated, so --
7 CHAIRMAN BLEY: Bill?
8 MR. RECKLEY: Yes, Dennis.
9 CHAIRMAN BLEY: This jumped off the page 10 at me because we've been looking at something that 11 came up because of concerns about where micro-reactors 12 in particular might get sited as the NRC has now 13 developed the Reg Guide on volcanology, in case it's 14 too close to volcanos.
15 And you don't mention that one in your 16 list here and it came up particularly for some of the 17 new reactors. Seems like you ought to have it in 18 there.
19 MR. RECKLEY: Yeah, it would be addressed 20 in the external hazards that needs to be identified.
21 You're probably right. We can certainly add that. I 22 don't, again, we lifted this largely out of Part 100, 23 one could say geology includes volcanology but maybe 24 we'll add specifically. It's definitely --
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219 1 Guide on it recently.
2 MR. RECKLEY: Yeah, no, and its, 3 volcanology, volcanos have always been included in the 4 list of external hazards one needs to assess. It's, 5 the NUREG Guide or Draft Reg Guide is just going into 6 more detail on how to do that assessment. But yeah, 7 okay. Good point.
8 If we can go to 49, yeah, 49. This gets 9 into, Dennis, what you were saying and it's also an 10 area where we got some feedback in this area on the 11 population-related siting considerations.
12 We were looking at it as we developed SECY 13 20-0045 on alternatives to population density and so, 14 we're awaiting the Commission to make a decision on 15 that SECY paper.
16 And so, we didn't go much further than 17 that paper. What we've included here would allow that 18 flexibility but we didn't go much further than that.
19 So, what 53.530 talks about is the 20 definition of both the exclusion area boundary and the 21 low population zone using the existing criteria, 25 22 rem for two hours for the EAB or over the course of 23 the event for the low population zone.
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220 1 Part 53 should continue to allow a future advanced 2 reactor to meet the same criteria that existing plants 3 have or should we, for example, prohibit any plant 4 that would exceed 25 rem dose at the site boundary.
5 Our current approach is to try to support 6 the flexibility that advanced reactors can have an 7 exclusionary boundary and low population zone defined 8 as the site boundary if that's where, if they can show 9 that the dose does not exceed 25 rem.
10 So, it's setting up the equivalency, the 11 site boundary is the site boundary, it's the 12 exclusionary boundary, it's the low population zone 13 boundary.
14 But if there are advanced reactors that, 15 for whatever reason would be designed and have the 16 potential for the 25 rem offsite, thereby they're also 17 going to set up that they're going to need emergency 18 planning offsite, that that flexibility be provided.
19 So, it comes down to trying to allow 20 flexibility. So, the current language that we used 21 here allows the exclusionary boundary and low 22 population zone to collapse.
23 It also allows, if anyone were so to 24 choose, to keep with the existing system. So that was 25 the logic of using the existing language. The --
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221 1 MEMBER BROWN: Bill.
2 MR. RECKLEY: Yes?
3 MEMBER BROWN: Go ahead, I'll wait until 4 you're done.
5 MR. RECKLEY: No, no. Well, I was going 6 on to the next slide.
7 MEMBER BROWN: Oh, okay. I just want to 8 make sure I understand it. Effectively there's a 9 fence around the site most of the time of some sort.
10 A physical barrier around the site.
11 MR. RECKLEY: Right.
12 MEMBER BROWN: So, this would, if they 13 took advantage of this because they meet the 25 rem 14 that means somebody could have their backyard up 15 against the site boundary? Is that correct?
16 MR. RECKLEY: Yes. That the, usually the 17 way it is set up is you have a site boundary then 18 beyond the site boundary out to, typically about a 19 half a mile you have the exclusionary boundary where 20 the licensee has the ability contractually to control 21 people within that boundary.
22 MEMBER BROWN: Yeah, but you said you're 23 waiving that.
24 MR. RECKLEY: It could collapse if they 25 can show that the 25 rem won't exceed the 25 then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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222 1 you're right, you would not need an additional half a 2 mile distance or even any distance --
3 MEMBER BROWN: Somebody could build a 4 house right next door to the boundary if they meet 5 this requirement?
6 MR. RECKLEY: That's right.
7 MEMBER BROWN: So, wouldn't there be some 8 other physical safety concerns relative to people that 9 do that that have ulterior motives?
10 MR. RECKLEY: Yeah. As we get, then 11 there's another --
12 MEMBER BROWN: Safety, you know, physical 13 safety issues, you know what I'm talking about.
14 MR. RECKLEY: Yes. And actually, as we 15 get into the security arena there's another zone, the 16 owner-controlled area that is set up for security 17 reasons.
18 Sometimes, traditionally they might 19 overlap with some of these radiological areas just 20 because it made sense for an owner-controlled area and 21 an exclusionary boundary to line up.
22 But there is another consideration of 23 where people live and that is in the security realm 24 under the owner-controlled area.
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223 1 sense from a security standpoint to have people not 2 having their backyard at the fence, then that would be 3 another way but for reasons other than radiological to 4 have them be at a distance.
5 MEMBER BROWN: Yeah, I just wanted to make 6 sure there was still, is the safety or the owner-7 controlled boundary part of these Part 53 8 considerations or not?
9 MR. RECKLEY: It may be when we get to the 10 security program, which would be under Subpart H.
11 MEMBER BALLINGER: So then, in order to 12 avoid having to have evacuation plans and all that 13 stuff, you just simply build the plant where the fence 14 is out to the point where you don't exceed the 25 rem?
15 MR. RECKLEY: You could do that.
16 MEMBER KIRCHNER: But the PAGs, Ron, are 17 one rem.
18 MR. RECKLEY: Yeah, that's different than 19 emergency planning and having evacuation plans, which 20 as Walt said, is one rem.
21 MEMBER BALLINGER: Okay, well then that 22 just makes it a little further out. 1 over R-squared.
23 MR. RECKLEY: In theory, one could do 24 that.
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224 1 Plant up here just simply sold a lot of their land 2 right up to the boundary and now there's a giant 3 shopping center and the access road to the plant goes 4 through the parking lot for the shopping center. You 5 don't even know it's there.
6 MR. RECKLEY: So, again, I would just 7 weigh in, this is basically the current requirement.
8 And the EAB and the LPZ, the low population zone, 9 exclusionary, have always been defined in terms of 10 these dose values. So, this is the existing 11 requirement.
12 MEMBER REMPE: Bill, before you leave this 13 slide or if you, I'm not sure if you're done with your 14 sentence. Did you have another comment?
15 MR. RECKLEY: No, I did not.
16 MEMBER REMPE: Okay. So, on this last 17 item, it sounds like, again, I've seen this before, 18 that you're assuming a single release from an event 19 and as I recall the gas reactor has circulated, if it 20 had a LOCA, there's a circulating activity release.
21 And then you might later heat up and you'd 22 have additional releases coming out that might be more 23 substantial. So, is a release the word you want to 24 use in the second bullet?
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225 1 think, refers to the worst case. The worst two hours, 2 and in the low population zone if over the period, the 3 whole period of the release, which would be including 4 the PUF and the subsequent release.
5 MEMBER REMPE: Okay. So, what if there's 6 a design that's, because again you've got this, it's 7 the release associated with an event is basically what 8 I'm trying to be clear about and I hope the language 9 is clear.
10 Because I thought when I looked at it, in 11 an earlier section they talked about a single plume.
12 We want to make sure that it's recognized you could 13 have more than one release associated with an event.
14 MR. RECKLEY: Right. And keep in mind 15 also that, for Part 53, when we talk about a plant it 16 includes multi-units and so, not only could you have 17 different timing of different releases from a unit, 18 you could have different timing from different units 19 and you could have different timing in the case of an 20 external event from different inventories associated 21 with different units, so.
22 MEMBER REMPE: And I thought that was the 23 response you gave me back but I thought the language 24 I saw here still kind of talks like it's a single 25 release.
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226 1 MR. RECKLEY: Okay, that, we'll look at 2 that language and make sure it's clear that this is 3 looking in total and reinforces, again, one difference 4 for Part 53 is, it's multi sources, multi units.
5 And as you're saying, potential different 6 time frames. So, we'll look at that language and make 7 sure that in our copying it over from Part 100 we 8 didn't inadvertently lose the continuity of that 9 requirement.
10 Anything else on EABs and low population 11 zones? If not, we can go to Slide 50, which is 12 talking about the population center distance. This is 13 an existing requirement as well.
14 And it does start to get into the 15 relevance of SECY 20-0045 on population densities.
16 And just as a remainder, the low population, I mean, 17 the population center distance is currently defined as 18 the, you take the low population zone boundary.
19 So, traditionally that's been a number of 20 a couple miles and it's one and a third so, just one 21 way to think about it easily, if the low population 22 zone is three miles, the population center distance, 23 which is the distance between the plant and the 24 nearest population center of 25,000 people could not 25 be any smaller than four miles.
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227 1 And that was just developed in the, you 2 know, all of this was developed in the, kind of early 3 days. The NUREG-0396, the whole setting up of the 4 emergency planning programs and so the multiplying by 5 one and a third was just a way to add some 6 conservatism, make sure things like emergency plans 7 could be effectively done and to site them away from 8 somewhere where that might become an issue in the 9 value of 25,000 where the population center was 10 selected way back in the, it was probably in the 11 1960s, I guess.
12 So, we actually maintained that but as we 13 talked about in SECY 20-0045, if you're collapsing the 14 low population zone to the fence then you basically 15 have a low population zone distance of zero and one 16 and a third.
17 You don't, this doesn't come into play 18 unless you have a dose of 25 rem at some distance from 19 the plant. The last bullet on the slide, reactor 20 sites should be located away from very densely 21 populated centers.
22 And this is more or less the way the rule 23 is worded. It's one of the more general-worded rules 24 that you'll find, even including that sentence where 25 population, low population densities are generally NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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228 1 preferred.
2 This is where we addressed in SECY 20-0045 3 that instead of 500 people per square mile as the 4 population density out to a distance of 20 miles, we 5 would introduce a, or potentially introduce if the 6 Commission approves it, a consequence-oriented formula 7 where our recommendation, as Dennis mentioned, was 8 that the distance would be out to twice the distance 9 at which you get one rem dose to an individual over a 10 period of a month.
11 And so, it's roughly twice the emergency 12 planning zone distance, I mean, the, yeah, the 13 emergency planning zone. But that is what we 14 recommended. So instead of 20 miles, it could be a 15 smaller number.
16 But there still would be a limit on 17 population density. If there was a dose off site 18 exceeding one rem and if there were no doses off site 19 that exceeded one rem, then the only population-20 related requirement that comes into play is that 21 reactor sites should be relocated away from densely 22 populated centers, which is defined as 25,000.
23 And so, the interpretation in SECY 20-0045 24 is, if you have no dose exceeding one rem off site, 25 you could be located almost anywhere except for in a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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229 1 population center of greater than 25,000 people.
2 And so, that is the way this carries out 3 and this is what we brought into Part 53. As we'll 4 talk about, some stakeholders want that even further 5 relaxed but our current language in this iteration is 6 as I described it. So, questions on the population-7 related?
8 MEMBER BALLINGER: This is Ron. It looks 9 to me that most of this rule is assuming as a 10 practical matter that the plant that you're going to 11 install is going to generate electricity.
12 What about a plant that you want to 13 install that's just going to generate heat for use in 14 processing?
15 MR. RECKLEY: There's nothing in the rule 16 that we foresee that is totally dependent on the end 17 product. For example, whether it be electricity or 18 process heat. The --
19 MEMBER BALLINGER: But if you plunk this 20 thing down in the middle of a site where they're doing 21 mining and there's a lot of workers and things like 22 that, does that make a difference?
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230 1 activities because those areas are usually population 2 centers of less than 25,000 people.
3 If you start to talk about process heat 4 being district heating or process heat in an 5 industrial facility that is also in a densely 6 populated center, this could become a restriction.
7 So, one of the things again we would be 8 interested to hear from stakeholders is, if the 25,000 9 is going to become -- if they see 25,000 as an 10 obstacle to actually deploying these reactors as they 11 envision, might we need to look again to see if that 12 is a needed limitation?
13 Right now, we didn't do the assessment 14 because we didn't, we're not changing current 15 requirements. But if the thought was to put advanced 16 reactors into more densely populated centers, what 17 would need to be considered?
18 And what limitations would come with that?
19 That's a question. Since we didn't propose it, we 20 didn't need to come up with a justification. But if 21 it is going to be proposed, what would be the 22 argument?
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231 1 in siting.
2 MEMBER PETTI: So, Bill, this is all 3 depending on that document that you presented to us 4 that's not yet approved, right?
5 MR. RECKLEY: Yes. I mean --
6 MEMBER PETTI: Is that just, you know, a 7 time constant for the bureaucracy and the gears to 8 move or there is a chance that somehow higher up the 9 chain people that don't like and you have to, might 10 have to and rewrite this?
11 MR. RECKLEY: I mean, where it is right 12 now is for the Commission to consider. It's made it 13 through the process and it's with the Commission, so.
14 MEMBER BALLINGER: What document is that?
15 Excuse me, I'm sorry.
16 MR. RECKLEY: This is SECY 20-0045.
17 MEMBER BALLINGER: Oh, okay. I have it.
18 Thanks.
19 MR. RECKLEY: So, I don't know the answer, 20 David, as to what the Commission might decide. I 21 mean, if they, if the Commission were to decide just 22 to deny that SECY paper altogether and just stick with 23 the current requirement, the guidance, the key part 24 is, everything we've adopted up to this point is in 25 accordance with the existing guidance, existing rules.
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232 1 It's just the guidance that we were 2 proposing to provide additional flexibility by 3 shrinking the 20 miles. If the Commission were to 4 decide to maintain 20 miles at 500 people per square 5 mile, that would, you know, that would have an impact 6 on the deployment models.
7 CHAIRMAN BLEY: I'll just mention that we 8 wrote a letter on this in late 2019 and briefed the 9 Commission on this sometime after that so, we've 10 gotten our input to the Commission.
11 MR. RECKLEY: Yeah. I mean, from the 12 staff's point of view in writing Part 53, the question 13 is really at this point, whether to go beyond the 14 flexibility that's afforded by both the existing rules 15 and the guidance documents including the potential for 16 additional flexibility in SECY 20-0045.
17 Again, some stakeholders are saying it 18 should be opened up more than this. We will see what 19 arguments are brought forth to possibly support that 20 argument.
21 You know, it's always brought up so, I 22 might as well, you know, just pose it as a question to 23 the Committee, you know, it's always brought up, do we 24 want to revisit Ravenswood, right?
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233 1 proposed, I'll get my rivers wrong. Anyway, it was in 2 the middle of New York City, East River or Hudson 3 River. So, in a very populated place.
4 Would we want to go as far as to say there 5 are no requirements related to siting and population 6 and a reactor can make a case based on its consequence 7 assessments and be placed anywhere.
8 You know, that would be the question. The 9 long-standing policy of the Commission has been as 10 it's stated here, areas of low population away from 11 very densely populated centers.
12 If there's an argument that should no 13 longer be the position based on an analysis of 14 advanced reactors or potentially micro-reactors in 15 particular, should we, in Part 53, ask the Commission 16 to change that policy I guess, would be the question.
17 We're not proposing to do that. You guys 18 can think about it. You'll see this again as we go 19 through the iterations and as you see the total 20 package. I'll leave it then as a question because 21 we're at the end of the time. But I only have like a 22 couple more slides.
23 So, if we could do 51, we talked about the 24 interfaces. Basically, every subpart will have a 25 reminder of its interfaces with others.
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234 1 Obviously, external hazards goes back to 2 things like 53.540 on, I mean, I'm sorry, 450 on the 3 analysis and safety classification and so forth.
4 And applicants would have to also address 5 all the environmental requirements in Part 51. So, if 6 we go to 52, Slide 52. Some of the public comments I 7 already mentioned.
8 Specifically use of the site boundary as 9 the EAB and low population zone specifically as 10 opposed to, I suppose allowing the EAB and LPZ of 11 being outside the site boundary.
12 The comment I just made, that there's some 13 observation by some stakeholders that the safety 14 criteria does away with the need to worry about 15 population centers, population densities and so forth.
16 And sort of the last bullet there is a 17 notion that, and this goes to some of the other 18 discussion of maximum hypothetical accident and so 19 forth, it is impossible to just show that a particular 20 design is impervious to external hazards or some 21 subset of external hazards and therefore, not need to 22 do any additional analysis, any additional 23 characterizations of a site and so forth. And with 24 that, I go to the last slide, which is just questions.
25 CHAIRMAN BLEY: No, but you brought up NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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235 1 something I'd mentioned to my colleagues on the 2 Committee. If anybody is entertaining this idea that, 3 forgetting about what happened at Ravenswood is a good 4 idea, I'd suggest reading the chapter on Ravenswood in 5 Dave Oklin's book that all of you have access to. But 6 it might be something to talk about at a later time, 7 not now.
8 Any comments from the Committee? If not, 9 I'd like to get the public line open, so we could 10 entertain public comments and then I'll come back to 11 the Committee. While we're waiting for the line to 12 open --
13 MR. DASHIELL: Public line is open for 14 comments.
15 CHAIRMAN BLEY: I see he's still signed 16 in. Thank you, Thomas. If there's anybody in the 17 public that would like to make a comment, please 18 identify yourself and make your comment. Any public 19 comments?
20 MR. DRAFFIN: Yes, this is Cyril Draffin 21 from the U.S. Nuclear Industry Council. We appreciate 22 the effort that you've done today in terms of raising 23 issues.
24 We spend a lot of time thinking about the 25 topics and thinking about how these technologies can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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236 1 be developed and used and I think it's healthy to have 2 a dialogue.
3 And we look forward to the iteration as 4 people think about what makes sense, provide safety 5 and also enables this to be a transformative part that 6 the industry and others can rely upon. So, we --
7 (Simultaneous speaking.)
8 CHAIRMAN BLEY: Thank you very much. I'm 9 sorry, I thought --
10 MR. DRAFFIN: -- coming fast and we will 11 continue to try to be supportive of the NRC.
12 CHAIRMAN BLEY: Okay. Thank you very much 13 for your comment. We appreciate it. Anyone else?
14 All right, hearing none, Thomas, can we close the 15 outside line?
16 MR. DASHIELL: Outside line is closing.
17 CHAIRMAN BLEY: And now I'd ask members, 18 I'd first state that I don't see a reason yet to go to 19 the full Committee and consider writing a letter. But 20 if anyone disagrees, bring it up. Anyone like to add 21 something to your questioning today? Of the members 22 of the Committee? Well, thank you.
23 I have a couple things I wanted to mention 24 right here at the end. Bill, I don't know if when you 25 see it might be possible. So, let me start at a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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237 1 different point.
2 It's becoming clear to me from the 3 discussions today that the emphasis on flexibility and 4 what that does to the brevity of the language and the 5 rule, to me makes the Statement of Considerations or 6 whitepapers that would precede the development of 7 Statements of Considerations.
8 And the associated guidance documents, 9 really essential integral elements with the rule and 10 I don't see how we can evaluate the rule language 11 absent the SOC and key guidance documents.
12 Bill, when you talked about some of these 13 things, the story was really pretty good. I don't 14 know if you were talking from draft white papers 15 yourself or speaking extemporaneously, if it's the 16 latter, I suggest you get the transcript and see what 17 you said.
18 And I again, say that would be a good 19 starting point. Part 100.23 does mention volcanos so, 20 I say you need to do that here too.
21 I'd also ask, whenever it's possible, it 22 would be really good to schedule a discussion with us 23 on the development and structure of guidance. What's 24 going to be in the guidance documents, what kind of 25 documents do you envision, what things beyond what we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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238 1 currently have.
2 And likewise, as you begin to develop any 3 white papers that would support the SOC, bringing 4 those to us and letting us see it would be very 5 helpful. I guess that's all I wanted to say.
6 So, thanks to everyone. Bill, it was a 7 heroic day for you. You should be tired, have a good 8 weekend. Thank you very much for the presentation and 9 all of the discussion. And at this point, I think the 10 meeting comes to a close. We are adjourned.
11 (Whereupon, the above-entitled matter went 12 off the record at 5:38 p.m.)
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ACRS Future Plant Designs Subcommittee 10 CFR Part 53 Licensing and Regulation of Advanced Nuclear Reactors Subparts C and D Preliminary Proposed Rule Language February 18, 2021
Agenda 9:30 AM - 9:35 AM Opening Remarks 9:35 AM - 9:40 AM Staff Introduction 9:40 AM - 1:00 PM 10 CFR Part 53 Subpart C - Design and Analysis Requirements 1:00 PM - 2:00 PM Lunch 2:00 PM - 3:00 PM 10 CFR Part 53 Subpart C - Design and Analysis Requirements (continued) 3:00 PM - 5:30 PM 10 CFR Part 53 Subpart D - Siting Requirements 5:30 PM - 6:00 PM Discussion 2
NRC Staff Plan to Develop Part 53 Subpart B Subpart C Subpart D Subpart E Subpart F Subpart G Project Life Cycle Design and Siting Construction Operation Retirement Analysis Requirements Facility Safety Definition System External Construction/ Program
- Fundamental Safety & Component Hazards Manufacturing Design Surveillance Functions Site Ensuring Maintenance
- Prevention, Mitigation, Analysis Characteristics Capabilities/
Performance Criteria Requirements Configuration (e.g., F-C Targets) Reliabilities Environmental Control
- Normal Operations Safety Change Control (e.g., effluents) Considerations Categorization Design
- Other & Special Environmental Changes Treatment Considerations Staffing &
Programs Plant/Site (Design, Construction, Configuration Control)
Clarify Controls Analyses (Prevention, Mitigation, Compare to Criteria) and Distinctions Between Plant Documents (Systems, Procedures, etc.)
LB Documents (Applications, SAR, TS, etc.) Subparts H & I 3
NRC Staff Engagement Plan ACRS Interactions Stakeholder Interactions Framework Safety Criteria Design Siting Construction Operations Decommissionin Licensing General/Admin g
Sept 20 Nov 20 Dec 20 Jan 21 Feb 21 Mar 21 Apr 21 May 21 Jun 21 Jul 21 Consolidated Technical Sections Aug 21 Sept 21 Consolidated Technical Sections Oct 21 Nov 21 Consolidated Rulemaking Package Dec 21 Jan 22 ACRS Full Committee Feb 22 Mar 22 Apr 22 May 22 Draft Proposed Rulemaking Package to the Commission Jun 22 Jul 22 Aug 22 Sept 22 Oct 22 Concept/Introduction Discussion Interim Staff Resolution 4
First Principles See: SECY-18-0096, Functional Containment Performance Criteria for Non-Light-Water-Reactors, and INL/EXT-20-58717, Technology-Inclusive Determination of Mechanistic Source Terms for Offsite Dose-Related Assessments for Advanced Nuclear Reactor Facilities 5
Integrated Approach (NRC Activities)
Note that a goal of the current effort is to build from the Licensing Modernization Project and have that guidance (NEI 18-04, RG 1.233) be one acceptable way of meeting the requirements to be developed and incorporated into Part 53 6
Subpart A - General Provisions
- Scope
- Definitions
- Interpretations
- Written Communications
- Employee Protection
- Completeness and Accuracy of Information
- Specific Exemptions
- Deliberate Misconduct
- Combining licenses; elimination of repetition
- Jurisdictional Limits
- Attacks and Destructive Acts
- Information Collection Requirements: OMB Approval 7
Subpart B - Safety Criteria
- Safety Objectives
- Safety Functions
- First Tier Safety Criteria
- Second Tier Safety Criteria
- Licensing Basis Events
- Defense in Depth
- Protection of Plant Workers 8
Subpart C - Design and Analysis
- Design Objectives and Design Features
- Functional Design Criteria for First Tier Safety Criteria
- Functional Design Criteria for Second Tier Safety Criteria
- Functional Design Criteria for Protection of Plant Workers
- Design Requirements
- Analysis Requirements
- Safety Criteria and Special Treatment
- Application of Analytical Safety Margins to Operational Flexibilities
- Design Control Quality Assurance
- Design and Analyses Interfaces 9
Subpart D - Siting
- General Siting
- External Hazards
- Site Characteristics
- Population-Related Considerations
- Siting Interfaces
- Environmental Considerations 10
Subpart E - Construction and Manufacturing
- Scope and Purpose
- Part 1 - Construction
- (a) Management and Control
- (b) Construction Activities
- (c) Inspection and Acceptance
- (d) Communication
- Part 2 - Manufacturing
- (a) Management and Control
- (b) Manufacturing Activities
- (c) Fuel Loading
- (d) Communication
- (e) Transportation
- (f) Acceptance and Installation at the Site 11
Subpart F - Operations
- Transition from Construction/Manufacturing to Operations
- Part 1 - Maintaining Capabilities and Reliabilities of Safety Related and Safety Significant Equipment
- Design Features and Programs for Normal Operations (53.220(a) Criteria)
- Design Features and Programs for Normal Operations (53.220(b) ALARA Criteria
- Configuration Management for Safety-Related Design Functions
- Technical Specifications
- Configuration Management for Safety-Significant Design Functions
- Special Treatment (e.g., Reliability Assurance)
- Maintenance, Repair and Inspection Programs
- Quality Assurance
- Aging Management Programs
- Design Control
- Facility Safety Program 12
Subpart F - Operations, Contd.
- Part 2 - Establishing and Maintaining Appropriate Staffing
- Concept for Operations
- Identifying Role of Personnel in Meeting First Tier Safety Criteria
- Identifying Role of Personnel in Meeting Second Tier Safety Criteria
- Requirements for Licensed Personnel
- Staffing
- Training
- Medical Requirements
- Licensing (Applications, Examinations, Licenses)
- Requirements for Non-Licensed Personnel (Graded based on roles)
- Staffing
- Training
- Other Requirements 13
Subpart F - Operations, Contd.
- Part 3 - Radiation Protection
- Part 4 - Emergency Preparedness
- Part 5 - Security Programs
- Part 6 - Preparing for and Transitioning to Decommissioning 14
Subpart G - Decommissioning
- Termination of power reactor licenses (transition from operation to possession-only license)
- Financial assurance for decommissioning
- Transition to unrestricted use 15
Subpart H - Licensing
- General
- Siting
- Site Suitability Reviews
- Limited Work Authorizations
- Early Site Permits
- Design
- Conceptual Design Reviews?
- Standard Design Approvals
- Design Certifications
- Manufacturing Licenses
- Manufacturing, Transportation, Deployment
- Site & Design
- Construction Permit
- Operating License
- Combined Licenses
- Appendix A (Content Table) 16
Subpart I - Maintaining Licensing Basis
- Amendments to a license
- Application (review?)
- Public notice and consultations
- Issuance
- Updating FSAR
- Including PRA
- Revocation, suspension, modification of license for cause
- Retaking SNM
- Commission order for operation after revocation
- Suspension and operation in war or national emergency, (50.54(d))
- Backfitting and Issue Finality
- Information requests (50.54(f))
17
Subpart J - Administrative and Reporting
- Common standards
- Water pollution control act (50.54(aa))
- Selective implementation
- National emergency, can deviate from (relationship to Parts 50, 52) TS (50.54(dd))
- Reporting
- Share SNM and byproduct material between units (50.54(ee))
- Notifications (50.72, 50.73)
- Need to address FEMA deficiencies
- Financial Qualifications (50.54(gg))
- Creditor Regulations
- Receipt of aircraft threat (50.54(hh))
- Enforcement
- ASME (50.55(a)) & quality standards
- US/IAEA (50.54(jj))
- SNM (50.54(b)-(d))
- Bankruptcy (50.54(cc))
- Antitrust (50.54(g))
- Property insurance (50.54(w))
- Subject to laws & regulations -
- Liability / Price Anderson (50.54(h))
18
Recap of Subpart B Safety Criteria
- Safety Objectives o Reasonable assurance of adequate protection o Additional measures to minimize danger to life and property
- Safety Functions o Primary safety function is to limit the release of radioactive materials from the facility o Additional supporting functions must be defined
- First Tier Safety Criteria o Normal operations (§ 20.1301) o Licensing basis events (§§ 50.34(a)(1)(ii)(D) & 52.79(a)(1)(vi))
- Second Tier Safety Criteria o Normal operations (Performance objectives for liquid and gaseous effluents (10 CFR Part 50, Appendix I))
o Licensing basis events (Safety Goals)
- Licensing Basis Events
- Defense in Depth
- Protection of Plant Workers 19
Subpart B Flowchart ATOMIC ENERGY ACT Safety Objectives Adequate Protection (Sec. 182) and Minimize Danger (Sec. 161)
First Tier
§ 20.1301 - Normal Ops Two Tiers Second Tier
§ 50.34/52.79 - Unplanned Events of Safety Criteria ALARA for Normal Ops NRC Safety Goals for unplanned events Required Safety Functions (DBAs)
- Retention of radionuclides Control frequency/consequences Safety Functions - Control heat generation (QHOs)
- Control heat removal - Risk/Safety Significance
- Control chemical interactions - Defense in Depth Safety Classification Design Features and Tech Specs Programmatic Controls Chapter 15 Special Treatment Licensee Programs 20
Part 53 Subpart B Stakeholder Feedback
- Second Tier Safety Objectives o Proposal by some stakeholders to eliminate second tier o Some ACRS Subcommittee members supported revisiting the two tier framework to clarify requirements Staff Proposed Iteration: Maintain second tier to provide clarity on regulatory treatment (e.g., special treatment for safety significant SSCs) o Proposal by some stakeholders to not use QHOs as second tier Staff Proposed Iteration: Maintain use of QHOs as logical risk-informed criteria. Industry may develop guidance for analysis section to support other risk-informed (but perhaps more deterministic) approaches to support finding that QHOs are satisfied.
- Safety Functions o Proposal by some stakeholders to explicitly cite fundamental safety functions Staff Proposed Iteration: Maintain mention of fundamental safety functions as examples to maintain technology-inclusive framework (with potential use for technologies such as fusion energy systems and multiple source terms within plants) 21
Part 53 Subpart B Stakeholder Feedback Contd
- Non-Radiological Hazards o Some ACRS Subcommittee members noted inclusion of non-radiological hazards should be considered, such as chemical releases Staff Proposed Iteration: Under consideration by the Working Group
- As Low as Reasonably Achievable (ALARA) o Proposal by some stakeholders to exclude ALARA requirements for normal effluents or occupational exposures o Some ACRS Subcommittee members favored retaining ALARA requirements in subpart B Staff Proposed Iteration: Maintained requirements for normal operations and occupational exposures to be ALARA
- Protection of Plant Workers o Proposal by some stakeholders to exclude occupational dose from Part 53 or to confine to reference to Part 20 o Some ACRS Subcommittee members favored retaining occupational dose limits.
Staff Proposed Iteration: Revised to reference Part 20 22
Part 53 General Layout
- Subpart A, General Provisions
- Subpart B, Technology-Inclusive Safety Objectives
- Subpart C, Design and Analysis
- Subpart D, Siting
- Subpart E, Construction and Manufacturing Requirements
- Subpart F, Requirements for Operation
- Facility Safety Program
- Subpart G, Decommissioning Requirements
- Subpart H, Applications for Licenses, Certifications and Approvals
- Subpart I, Maintaining and Revising Licensing Basis Information
- Subpart J, Reporting and Administrative Requirements 23
10 CFR Part 53 Subpart C Layout
- § 53.400 - Design Objectives and Design Features
- § 53.410 - Functional Design Criteria for First Tier Safety Criteria
- § 53.420 - Functional Design Criteria for Second Tier Safety Criteria
- § 53.430 - Functional Design Criteria for Protection of Plant Workers
- § 53.440 - Design Requirements
- § 53.450 - Analysis Requirements
- § 53.460 - Safety Categorization and Special Treatment 24
10 CFR Part 53 Subpart C Layout
- § 53.470 - Application of Analytical Safety Margins to Operational Flexibilities
- § 53.480 - Design Control Quality Assurance
- § 53.490 - Design and Analysis Interfaces 25
§ 53.400 - Design Objectives and Design Features
- Design Objectives and Design Features o Establishes the overall design objectives by referring to the underlying safety criteria and the identification of safety functions.
o Design features must be provided such that, when combined with associated programmatic controls and human actions, there is reasonable assurance the safety criteria will be met.
26
§§ 53.410 & 53.420 -
Functional Design Criteria
- First Tier Safety Criteria o Effluents during normal operation do not result in a dose to an individual member of the public exceeding 100 millirem.
o Design features and functional design criteria for unplanned events are determined through analyses.
- Second Tier Safety Criteria o Doses from effluents during normal operation are as low as reasonably achievable (ALARA).
o Design features and functional design criteria for unplanned events are determined through analyses.
Note that performance-based approaches for Part 53 safety criteria for normal operations are being discussed as part of the advanced reactor content of applications project (ARCAP). Performance-based approaches for licensing basis events are being incorporated into sections on analyses and programmatic controls within Subpart F (Operations).
27
§ 53.430 - Protection of Plant Workers
- Functional Design Criteria for Protection of Plant Workers o Functional design criteria must be defined for each design feature relied upon to demonstrate compliance with occupational dose limits provided in Subpart C to 10 CFR Part 20.
o Functional design criteria must be defined for each design feature to ensure that plant SSCs achieve occupational doses as low as is reasonably achievable.
Note that inclusion of requirements for protection of plant workers within Part 53 is a topic of ongoing discussions related to Subpart B (Technology-Inclusive Safety Objectives) 28
§ 53.440 - Design Requirements
- Design features must use generally accepted consensus codes and standards
- Materials must be qualified for their service conditions over plant lifetime
- Safety and security must be considered together
- Design features must be demonstrated capable of accomplishing safety functions without adverse effects to other safety features Note that preliminary rule language refers o Analysis to generally accepted consensus codes o Test programs and standards and materials being qualified for their service conditions.
o Prototype testing These terms are topics for discussion.
o Experience Resolution may include rule language, discussions within rulemaking package, and/or developing guidance documents.
29
§ 53.450 - Analysis Requirements
- Probabilistic risk assessment (PRA) o Performed to identify potential failures, degradation mechanisms, susceptibility to hazards, other risks to safety functions o Used to determine licensing basis events (LBEs), classify safety significance and human actions, evaluate defense in depth, assess other challenges to plant safety o Conforms with generally accepted methods, standards, and practices o Maintained and upgraded every two years
- Analytical codes must be qualified for range of conditions for which they are used
- Analyses must assess fire protection, aircraft impacts, and mitigation of select beyond design basis events (BDBEs)
- Analyses must include design basis accidents (DBAs) 30
§ 53.450 - Analysis Requirements
- Note that possible changes being considered for next iteration as a result of interactions with public stakeholders and ACRS o Allowing alternative risk-informed, systematic approaches to the PRA for activities such as determining licensing basis events, safety classification, and evaluating defense in depth o Clarifying that licensing basis events range from anticipated operation occurrences to very unlikely event sequences.
o Addressing that analyses must be performed from event initiation to defined end state (e.g., safe stable end state for design basis accidents) 31
§ 53.460 - Safety Categorization and Special Treatment
- Safety Related (SR) o SSCs and human actions relied upon to function in response to design basis accidents
- Non-Safety Related but Safety Significant (NSRSS) o SSCs and human actions that perform a function that is necessary to achieve adequate defense-in-depth or are classified as risk significant Failure contributes 1% or more to cumulative plant risk Would cause a licensing basis event to exceed safety criteria
- Non-Safety Significant (NSS) o SSCs not warranting special treatment Note that criteria for NSRSS my change to address an iteration that supports alternatives to a PRA categorizing SSCs 32
§ 53.460 - Safety Categorization and Special Treatment
- Special treatment o Must be established to provide appropriate confidence that the SR and NSRSS SSCs will perform under the service conditions and with the reliability assumed in the required analysis to provide reasonable assurance of meeting the safety criteria
- Human actions o Must be capable of being reliably performed under the postulated environmental conditions present and be addressed by programs to provide confidence that those actions will be performed as assumed in the required analysis 33
§ 53.470 - Application of Analytical Safety Margins to Operational Flexibilities
- Allows adoption of more restrictive criteria to obtain safety margin for application to other areas
- Requires use of a design goal to ensure analysis, design features, and programmatic controls are established to support analytical margins Note that this provision would support integrated approach historically discussed for use in justifying alternatives in areas such as emergency preparedness and population-related siting considerations 34
§ 53.480 - Design Control Quality Assurance
- Establishes quality assurance requirements for design and analysis activities
- Derived from Criterion III in Appendix B to 10 CFR Part 50
- QA program must conform with generally accepted consensus codes and standards Note that preliminary rule language refers to generally accepted consensus codes and standards. This term is a topic for discussion. Resolution may include rule language, discussions within rulemaking package, and/or developing guidance documents.
35
§ 53.490 - Design and Analysis Interfaces
- Requires applicants and licensees to identify, control, and maintain interfaces between design and analyses activities and other activities o For example, configuration controls in Subpart F and the proposed facility safety program 36
Other Possible Topics for Discussion A topic for possible discussion is the consideration and treatment of inherent design features. An inherent design feature is one where the safety function is achieved through natural processes governed by the physical laws without reliance on the activation or operation of supporting active or passive systems. It may be helpful to develop guidance on how inherent design features are credited in analyses, verified and validated, and considered under safety classification and special treatment provisions of this Subpart.
37
Other Possible Topics for Discussion (Contd) 38
Key Public Comments on Subpart C Design and Analyses
- Occupational dose should not be included in Part 53.
- Need additional discussion on the term generally accepted as applied to consensus codes and standards
- Security should be assessed against NRC performance requirements, not required to be assessed within design processes.
39
Key Public Comments on Subpart C Design and Analyses
- Do not make PRA an implicit requirement for LBE selection, SSC classification, DID determinations o PRA insights should complement the safety review o Use of PRA should be optional if other risk-informed analyses are appropriate to use o Preliminary rule text for is supported by RG 1.233 implementation, but not supported by an applicant using a deterministic approach to classify SSCs o Deterministic approaches for some aspects may be appropriate and should not be excluded (allow combination of risk-informed and deterministic analyses)
- International regulatory frameworks have risk-informed approaches that certain vendors may choose to pursue o Part 53 should accommodate such approaches (i.e., IAEA SSR-2/1 and markets with dual-DSA/PSA requirements) 40
Key Public Comments on Subpart C Design and Analyses
- DID is important in supporting an adequate safety case for both LMP and non-LMP applications, but is best addressed in guidance rather than regulations.
- In guidance, NRC should clarify what DID analysis is required when physics or inherent features of a design have already resolved or removed the potential for releases of large amounts of radioactivity 41
Subpart C, Design and Analysis Discussion 42
Part 53 General Layout
- Subpart A, General Provisions
- Subpart B, Technology-Inclusive Safety Objectives
- Subpart C, Design and Analysis
- Subpart D, Siting Requirements
- Subpart E, Construction and Manufacturing Requirements
- Subpart F, Requirements for Operation
- Facility Safety Program
- Subpart G, Decommissioning Requirements
- Subpart H, Applications for Licenses, Certifications and Approvals
- Subpart I, Maintaining and Revising Licensing Basis Information
- Subpart J, Reporting and Administrative Requirements 43
10 CFR Part 53 Subpart D Layout
- § 53.500 - General Siting
- § 53.510 - External Hazards
- § 53.520 - Site Characteristics
- § 53.530 - Population-related Considerations
- § 53.540 - Siting Interfaces
- § 53.550 - Environmental Considerations 44
§ 53.500 - General Siting
- Overall siting considerations o Consider site in combination with design features and programmatic controls to satisfy first and second tier safety criteria.
o Identify and assess external hazards and site characteristics that could contribute to initiation, progression, or consequences of licensing basis events.
o Address potential adverse impacts on nearby environs as a result of normal operations or potential accidents.
45
§ 53.510 - External Hazards
- Structures, systems, and components (SSCs) needed to meet first tier safety criteria must be designed to withstand natural phenomena and man-made hazards.
o SSCs designed to withstand hazards up to design basis levels.
o Design basis external hazard levels must address hazards occurring with both routine frequency and up to 1 in 100,000 years, with added margin.
- Geologic and seismic factors must be considered to determine Safe Shutdown Earthquake Ground Motion (SSEGM).
o SSEGM is level of seismic activity at which SSCs must remain functional.
o The SSEGM for the site is determined considering the results of the geological, seismological, and engineering characteristics of a site and its environs.
46
§ 53.510 - External Hazards (cont.)
- Analyses required by § 53.450 must address external hazard frequencies and related SSC fragilities.
o Analyses (including beyond design basis events) must assess external hazards in order to meet second tier safety criteria.
o Functional design criteria and programmatic controls must be established to maintain performance of SSCs relied upon to meet safety criteria.
47
§ 53.520 - Site Characteristics
- Meteorological, geological, seismological, topographical, hydrological, and other characteristics of the site and surrounding area that could affect radioactive material escape should be identified, estimated, and considered in the analyses required by Subpart C (Design and Analysis).
48
§ 53.530 - Population-related considerations
- Every site must have an exclusion area, low population zone, and provide a population center distance as defined in § 53.120. Offsite radiological consequences estimated by analyses required by § 53.450 are used to define:
o Exclusion area such that any individual on the boundary for any two hour period following a release would not receive more than 25 rem total effective dose equivalent (TEDE).
o Low-population zone such that any individual on the boundary following a release would not receive more than 25 rem TEDE.
49
§ 53.530 - Population-related considerations (cont.)
- Offsite radiological consequences estimated by analyses required by § 53.450 are used to define:
o Population center distance that must be at least one and one-third times the distance from the reactor to the outer boundary of the low population zone.
o Reactor sites should be located away from very densely populated centers. Areas of low population density are, generally, preferred.
50
§§ 53.540 & 53.550 - Siting Interfaces and Environmental Considerations
- External hazards and site characteristics must be addressed by design features, programmatic controls, and supporting analyses to demonstrate compliance with first and second tier safety criteria.
- Applicants must demonstrate compliance with environmental protection regulations in accordance with 10 CFR Part 51.
51
Key Public Comments on Subpart D Siting Requirements
- Scope of required site characteristics and associated analyses should be first informed by risk/safety profile of the facility, and then the specific site, as necessary.
- Use of site boundary to replace EAB and LPZ
- Performance-based focus of safety criteria obviates need for considering distance to population center (i.e.,
prescriptive Section 53.530 not necessary)
- Consider higher level requirements to allow flexibility
- Characteristics of the site that have a significant impact on the ability to meet the safety criteria (examples, e.g.,
seismology, rather than prescriptive)
- Locate detailed expectations in guidance (e.g., seismic hazard) 52
Part 53 Rulemaking 53
Acronyms and Abbreviations ACRS Advisory Committee on Reactor FSAR Final Safety Analysis Report Safeguards IAEA International Atomic Energy ALARA As low as reasonably achievable Agency LBE Licensing Basis Event ARCAP Advanced Reactor Content of LMP Licensing Modernization Project Applications Project BDBE Beyond design-basis event LPZ Low Population Zone LWR Light-water Reactor CFR Code of Federal Regulations NEI Nuclear Energy Institute DBA Design-basis accident NRC U.S. Nuclear Regulatory Commission DID Defense-in-Depth NSRSS Non-Safety Related but Safety DSA Deterministic Safety Analysis Significant EAB Exclusionary Area Boundary NSS Non-Safety Significant EP Emergency preparedness OMB Office of Management and Budget F-C Frequency - Consequence ONT Other New Technologies FEMA Federal Emergency PRA Probabilistic Risk Assessment Management Agency 54
Acronyms and Abbreviations PSA Probabilistic Safety Assessment QA Quality assurance QHO Quantitative health objective SAR Safety Analysis Report SMR Small Modular Reactor SR Safety-related SSCs Structures, systems, and components SSEGM Safe Shutdown Earthquake Ground Motion TEDE Total Effective Dose Equivalent TS Technical Specifications 55