ML21119A052

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Transcript of Advisory Committee on Reactor Safeguard 684th Full Committee Meeting - April 8, 2021, Pages 1-258 (Open)
ML21119A052
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Issue date: 04/08/2021
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Advisory Committee on Reactor Safeguards
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Montgomery, S, ACRS
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NRC-1473
Download: ML21119A052 (327)


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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Advisory Committee on Reactor Safeguards Docket Number: (n/a)

Location: teleconference Date: Thursday, April 8, 2021 Work Order No.: NRC-1473 Pages 1-258 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 684TH MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +

8 THURSDAY 9 APRIL 8, 2021 10 + + + + +

11 The Advisory Committee met via 12 Teleconference, at 9:30 a.m. EDT, Matthew W. Sunseri, 13 Chairman, presiding.

14 15 COMMITTEE MEMBERS:

16 MATTHEW W. SUNSERI, Chairman 17 JOY L. REMPE, Vice Chairman 18 WALTER L. KIRCHNER, Member-at-Large 19 RONALD G. BALLINGER, Member 20 DENNIS BLEY, Member 21 CHARLES H. BROWN, JR., Member 22 VESNA B. DIMITRIJEVIC, Member 23 JOSE MARCH-LEUBA, Member 24 DAVID PETTI, Member 25 PETER RICCARDELLA, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 ACRS CONSULTANTS:

2 MICHAEL L. CORRADINI 3 STEPHEN SCHULTZ 4

5 DESIGNATED FEDERAL OFFICIAL:

6 DEREK WIDMAYER 7

8 9

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3 1 CONTENTS 2 Opening Remarks by the ACRS Chairman . . . . . . 4 3 Regulatory Guide (RG) 4.26, "Volcanic Hazard 4 Assessments for Nuclear Power Reactor 5 Sites" . . . . . . . . . . . . . . . . . . 9 6 Committee Deliberation on RG 4.26, "Volcanic 7 Hazard Assessments for Nuclear Power 8 Reactor Sites" . . . . . . . . . . . . . . 68 9 Overview of the NRC Safety Research Program 10 Related to the Biennial Review . . . . . . 75 11 NuScale Topical Report, "Control Room Staffing" 12 Committee Deliberation on NuScale Topical Report, 13 "Control Room Staffing) . . . . . . . . 166 14 Adjourn 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 9:36 a.m.

3 CHAIRMAN SUNSERI: The meeting will now 4 come to order. This is the first day of the 684th 5 meeting of the Advisory Committee on Reactor 6 Safeguards. I'm Matthew Sunseri, chair of the ACRS.

7 I will now call the roll to verify a 8 quorum and communication. I'll start with Ron 9 Ballinger.

10 MEMBER BALLINGER: Here.

11 CHAIRMAN SUNSERI: Dennis Bley.

12 CHAIRMAN BLEY: I'm here.

13 CHAIRMAN SUNSERI: Charles Brown.

14 MEMBER BROWN: Here.

15 CHAIRMAN SUNSERI: Vesna Dimitrijevic.

16 MEMBER DIMITRIJEVIC: Here.

17 CHAIRMAN SUNSERI: Walt Kirchner.

18 MEMBER KIRCHNER: Here.

19 CHAIRMAN SUNSERI: Jose March-Leuba.

20 MEMBER MARCH-LEUBA: Here.

21 CHAIRMAN SUNSERI: Dave Petti.

22 MEMBER PETTI: Here.

23 CHAIRMAN SUNSERI: Joy Rempe.

24 VICE CHAIRMAN REMPE: Here.

25 CHAIRMAN SUNSERI: Pete Riccardella.

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5 1 MEMBER RICCARDELLA: I'm here.

2 CHAIRMAN SUNSERI: All right. And myself, 3 so we have a quorum and everyone came through loud and 4 clear.

5 The ACRS was established by the Atomic 6 Energy Act and is governed by the Federal Advisory 7 Committee Act. The ACRS section of the U.S. NRC 8 public website provides information about the history 9 of the ACRS and provides documents such as our 10 charter, bylaws, federal register notices for 11 meetings, letter reports, and transcripts of all full 12 and subcommittee meetings, including the slides 13 presented at the meetings.

14 The committee provides its advice on 15 safety matters to the Commission through its publicly 16 available letter reports. The federal register notice 17 announcing this meeting was published on March 10, 18 2021, and provides an agenda and instructions for 19 interested parties to provide written documents or 20 request opportunities to address the committee.

21 The Designated Federal Officer for this 22 meeting is Mr. Derek Widmayer.

23 In today's meeting, the committee will 24 consider the following. Our first topic is Regulatory 25 Guide 4.26, Volcanic Hazards Assessment for Nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 Power Reactor Sites. Part of our deliberation on this 2 will be deciding whether or not we will write a letter 3 report on this topic.

4 Second, our review of Nuclear Safety 5 Research Program related to Biennial Review. This is 6 the beginning of our periodic review of the Agency's 7 Safety Research Program. Our review will conclude 8 ultimately with the letter report, however, that's 9 going to be out in the future.

10 NuScale Topical Report on Control Room 11 Staffing, we will begin deliberation on a letter 12 report today after hearing a presentation on the 13 topic. It is not likely -- maybe I should say it is 14 likely that this report will continue on and be 15 concluded in the May full committee. Portions of this 16 NuScale Topical Report presentation may be closed to 17 the public to protect proprietary information.

18 I also want to note that on today's agenda 19 we have a hard stop at 1:30 Eastern Time today. It's 20 scheduled for our lunch break, but it's more like a 21 working lunch for ACRS members because we're going to 22 conduct our annual training for special government 23 employees during that time period, so we have people 24 waiting on us and we'll have a hard stop at 1:30.

25 A phone bridge line has been open to allow NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 1 members of the public to listen in on the 2 presentations and committee discussions. We have 3 received no written comments or requests to make oral 4 statements from members of the public regarding 5 today's session. There will be an opportunity for 6 public comment. We have set aside time in the agenda 7 for comments from members of the public attending or 8 listening to our meeting. Written comments may be 9 forwarded to Mr. Derek Widmayer, the Designated 10 Federal Officer.

11 A transcript of the open portion of the 12 meeting is being kept and it is requested that 13 speakers identify themselves and speak with sufficient 14 clarity and volume so that they can be readily heard.

15 Additionally, and very important, participants should 16 mute themselves when not speaking.

17 So I just want to call attention to 18 something that I see in the attendees' list. During 19 this week's meeting we have two invited experts that 20 will be joining us periodically throughout the various 21 sessions. Dr. Vicki Bier and Mr. Greg Halnon are 22 those participants. Vicki's background is in risk 23 analysis and is similar to Vesna's. Greg's background 24 is in commercial plant operations and it's very 25 similar to mine. Their participation is much like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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8 1 that of our consultants. They may ask questions for 2 technical clarification or provide factual 3 information. Members may call upon them for factual 4 information. However, they will not be participating 5 in any of the committee's deliberations or decision-6 making activities. Look forward to seeing their 7 interaction.

8 That is all of the business that I wanted 9 to note. I'll call on the members now to see if you 10 have any questions with the agenda or any comments 11 that you'd like to make before we get started.

12 Okay, we will go into our first topic 13 which is Reg. Guide 4.26, Volcanic Hazard Assessment 14 for Nuclear Power Reactor Sites. And I'll turn the 15 floor over to Dennis Bley, chairman of the 16 subcommittee of this activity. Dennis.

17 CHAIRMAN BLEY: Thank you very much, Mr.

18 Chairman. We look forward to this presentation. This 19 is one of those unusual cases where the staff has come 20 back to us a little earlier than we expected and this 21 will be the last review on this Reg. Guide.

22 We met with the staff last year. It was 23 in February. And saw the first version and had a very 24 good session. There were a number of comments and I 25 think over the last year, the staff has received NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 1 public comments, as well as had the benefit of the 2 transcripts of our discussions, and they prepared a 3 final draft of the Reg. Guide on volcanic hazards and 4 we look forward to hearing about that.

5 I'll now ask Jenise Thompson of the staff 6 to continue with the presentation. I guess we need 7 the slides up.

8 MS. THOMPSON: I'll get the slides up 9 right now.

10 CHAIRMAN BLEY: Okay. Thank you.

11 Perfect.

12 MS. THOMPSON: Let me engage my laser 13 pointer. All right. Thank you. So good morning. My 14 name is Jenise Thompson and I'm the technical lead on 15 Reg. Guide 4.26. I'm also a geologist in NRR and was 16 part of the team that has spent the last over two 17 years developing first Draft Guide 40.28 and now Reg.

18 Guide 4.26 with staff from multiple divisions in NRR, 19 multiple offices across the NRC, as well as contractor 20 support from the Southwest Research Institute.

21 My presentation today will primarily focus 22 on the changes that we have made to Draft Guide 40.28 23 since we were last before ACRS. We were before you in 24 February of last year, received many useful comments 25 that we believe we've addressed in the Reg. Guide 4.26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 which was issued as a draft for public comment in 2 March of last year. We had an extended public comment 3 period, receiving 23 overall comments through the end 4 of July. Two of those comments were from members of 5 the public and we received 21 comments from NEI.

6 And today, I'll focus on a lot of the 7 changes that we've made as we've incorporated those 8 comments into Reg. Guide 4.26. These will generally 9 cover topics including screening criteria, proximal 10 hazards, incorporation of risk insights, enhancing the 11 flexibility of the proposed process using the SSHAC 12 method, clarifications related to tectono-magmatic 13 models, and some additional clarifications 14 particularly related to the referencing of 15 international standards. There are some -- I'm sorry, 16 is there a question?

17 CHAIRMAN BLEY: Yes. This is Dennis Bley.

18 When we reviewed this with you a year ago, the Draft 19 Guide we had was DG 13.64 and now I find the documents 20 we have and in your discussion it's called Draft Guide 21 40.28. Did you rename it or what happened?

22 MS. THOMPSON: Yes. So after we were 23 before ACRS in February -- I'm sorry, is there another 24 question?

25 CHAIRMAN BLEY: No.

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11 1 MS. THOMPSON: Oh, okay. So after we were 2 before you in February, there was a change made to 3 recategorize the guide instead of it being in Section 4 1 of Reg. Guide, it was moved to Section 4 because it 5 was related to siting. So that's why it was given a 6 new Draft Guide number and a new Reg. Guide number.

7 CHAIRMAN BLEY: Okay. Thank you.

8 MS. THOMPSON: You're welcome. Okay, 9 there we go. Sorry, I lost my slides for a second.

10 So I'll go over the changes that we've 11 made from the Draft Guide to the current Reg. Guide.

12 I'll highlight some of the differences including those 13 related to a screening criteria, as well as the 14 referencing or use of international standard. And 15 then I also want to note that the resolution or 16 disposition for all of the comments has been tracked.

17 So that's available as well.

18 As I mentioned, the initial screening 19 criteria is something that we had several public 20 comments on and a lot of discussion, both before ACRS 21 when we were there in February and with the public 22 commenters. An applicant would need to consider both 23 regional volcanos and larger distant volcanos in the 24 initial screening criteria. For the regional volcanos 25 would be to continue to the site characterization NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 information for the site region which is 320 2 kilometers or 200 miles from the proposed site, to 3 identify ant Quaternary or volcanos that are 2.6 4 million years or younger within that site region.

5 The staff also identified the need to 6 consider potential hazards from larger, more distant 7 volcanos like Yellowstone that might be located beyond 8 the site region. And rather than providing a distance 9 from the site to the potential hazard or the source 10 volcano, we determined that if Quaternary ash deposits 11 are located within the site vicinity that is 40 12 kilometers or 25 miles from the proposed site, then 13 the source volcano for that ash deposit should be 14 evaluated even if it's located beyond the site region 15 of 320 kilometers or 200 miles from the proposed site.

16 And both of these screening criteria 17 leverage existing information that would be available 18 to every applicant from their geologic site 19 characterization and this is what's performed under 10 20 CFR 100.23. So this is information that would already 21 be available and wouldn't constitute a separate 22 volcanic analysis.

23 I'm going to walk through a quick example 24 of that that I think will make this a little bit 25 clearer.

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13 1 So we're using the Vogtle site as an 2 example here because many of us are very familiar with 3 this site. And the top photo here is showing a 4 geologic map and the black circle is the 200 mile or 5 320 kilometer radius from the site itself which is the 6 nice little red star in the center. And looking at 7 the available information from the geologic site 8 characterization it's very easy and simple to 9 determine if there are no Quaternary volcanos within 10 that site region. So that's the first screening 11 criteria taken care of.

12 Moving to the lower photo, it's a geologic 13 map of the site vicinity and that black circle is now 14 the 40 kilometer or 25 mile radius and this is at a 15 much greater level of detail and a focused 16 characterization for this site vicinity. And again, 17 we can very easily determine from the geologic site 18 characterization information that there is no 19 Quaternary ash within the site vicinity for the Vogtle 20 site. This allows an applicant to make a very simple 21 determination based on existing characterization 22 information and for the Vogtle site region that 23 conclusion is that there's no evidence of Quaternary 24 volcanic hazards. So this is an example of how this 25 screening would apply for a particular site.

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14 1 DR. CORRADINI: I had a question. This is 2 Corradini.

3 MS. THOMPSON: Yes.

4 DR. CORRADINI: For the current operating 5 power plants, what current operating power plants what 6 I'll say factor in -- not factor in, but meet this 7 criterion that they had to consider the volcanic 8 hazard?

9 MS. THOMPSON: So there is one current 10 operating facility and that's the Columbia facility in 11 eastern Washington State that did consider volcanic 12 hazard.

13 DR. CORRADINI: And the criteria that 14 we're going to see following this, they kind of 15 screened in, they meet the revised regulation?

16 MS. THOMPSON: So if they were to apply 17 for a new reactor at their same location, then yes.

18 They would screen in for an analysis.

19 DR. CORRADINI: But what I guess I'm 20 saying is how they met the screening in -- they 21 screened in, let's just go through the way you said it 22 that if there was a new power plant proposed in that 23 area, they would screen in. The Reg. Guide changes 24 that we're going to hear about would make the new 25 plant proposal a similar analysis procedure as the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 current Columbia or different?

2 MS. THOMPSON: It would be similar.

3 DR. CORRADINI: And if it's different, as 4 you proceed through this, I'd like to understand how 5 it's different.

6 MS. THOMPSON: So it would be similar.

7 The previous licensing actions for other nuclear 8 facilities including the Columbia site were something 9 that we considered in detail in developing the content 10 of this Reg. Guide. We went into it a lot more detail 11 in the February briefing and once I finish with this 12 presentation, I can walk through the Columbia site 13 specifically, but that's --

14 DR. CORRADINI: No, that's --

15 MS. THOMPSON: Okay. I thought you were 16 going to say --

17 DR. CORRADINI: You did answer my 18 question.

19 MS. THOMPSON: Okay. This process would 20 not be inconsistent and later on in my presentation 21 I'll walk through what the process would be for a site 22 that does screen in.

23 DR. CORRADINI: Thank you so much.

24 MS. THOMPSON: We'll get to that.

25 MEMBER BALLINGER: This is Ron Ballinger.

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16 1 You mentioned the Yellowstone volcano and I'm 2 wondering since it hasn't erupted -- that hasn't 3 erupted for a very, very, very, very long time, and 4 what I've seen of the sort of the public presentations 5 on such a volcano, it would be hard to imagine that 6 the entire eastern -- not eastern -- yes, the entire 7 region of the country east of that volcano would not 8 be covered with ash. So are we getting a little more 9 speculative than we need to be for that kind of 10 volcano?

11 MS. THOMPSON: Well, that's part of the 12 reason why instead of providing a distance, we are 13 proposing a screening by the presence of Quaternary 14 ash within the site vicinity so that evidence of a 15 Quaternary eruption within the site vicinity could be 16 used as potential likelihood that hazard being present 17 in the site vicinity again.

18 There's some additional information that 19 we can get to. A lot of it goes to modeling of the 20 potential, the tectono-magmatic model for the system 21 that's being considered. We can get to that as well 22 and I also wanted to call on Dr. Britt Hill who's a 23 volcanologist and consultant to the staff.

24 Britt, did you have anything specific that 25 you wanted to add?

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17 1 DR. HILL: This is Britt Hill. Am I being 2 heard?

3 MEMBER BALLINGER: Yes, to me.

4 DR. HILL: Yes, the last major Yellowstone 5 eruption was about 600,000 years ago, so it would fall 6 well within our Quaternary period. And it isn't the 7 entire part of the country, but parts of the Midwest 8 were receiving on the order of ten centimeters worth 9 of ash.

10 And really, at this stage, all we're 11 saying is that if you have the ash from that kind of 12 an eruption present over the last say 600,000 years, 13 you would proceed to the next step of the analysis and 14 this next step of the analysis includes the tectonic-15 magmatic model which is taking not just a strict age 16 or distance criteria, but also assemble the thoughtful 17 rationale about is such a huge eruption credible given 18 the current tectonic and magmatic system, not the 19 system that was operating 600,000 years ago.

20 So just because it screens in early 21 doesn't mean that there would have to be a full-blown 22 analysis, just that you proceed to the next step of 23 the analysis and give it some technical rationale of 24 why it would be or not be considered credible.

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18 1 the 600,000 years?

2 DR. HILL: It's very small. I believe the 3 age is 620,000 for (inaudible) range.

4 DR. CORRADINI: Okay. Thank you.

5 CHAIRMAN BLEY: This is Dennis. Ron got 6 me thinking a little bit, but I believe at our last 7 meeting we expressed some concerns about having a 8 strict distance requirement because ash can travel a 9 long way. And this approach of having to find ash 10 nearby and then looking at where it came from seems to 11 make a lot of sense to me. And I think it covers the 12 issue Ron was bringing up.

13 MEMBER BROWN: This is Charlie Brown. I 14 think I raised some skepticism in the last meeting, as 15 well as the complexity of this particular Reg. Guide.

16 Two questions, one, I wanted to make sure 17 I understood the Columbia situation. That would have 18 screened in to this Reg. Guide, correct? I mean I'm 19 looking at the Reg. Guide in the first background part 20 of it. It's like 216 kilometers.

21 MS. THOMPSON: Correct.

22 MEMBER BROWN: So that would have had to 23 go through this drill, you know, this process. Okay.

24 MS. THOMPSON: Yes.

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19 1 shouldn't have asked the first question, oh, okay, is 2 if you find ash and I'm spring boarding off the last 3 answer, you would then find the ash at some level and 4 then you have to step through this process and it 5 sounded like you had to start evaluating the 6 probability of another eruption or something that 7 occurred 600,000 years ago. That just seems to me to 8 be a stretch.

9 MS. THOMPSON: So that is something that 10 I'll get to in the presentation. In the Draft Guide 11 that would have been the process if the applicant were 12 following the steps. The revisions that we've made to 13 the Reg. Guide are highlighting some enhanced 14 flexibility that applicants can take so that instead 15 of calculating probabilities of eruption or 16 probabilities of the hazard reaching the site, there 17 is now a path for engineering analysis which I'll 18 explain in some of the later slides. But that would 19 allow an applicant to assume a certain level of hazard 20 and then perform an engineering analysis of their 21 selected design instead of calculating the probability 22 of eruption or hazard. But I'll get to that.

23 MEMBER BROWN: I noticed that you had 24 changed the figure so you could -- there's an arrow 25 going up the side. I think it's around step three and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 it goes down to evaluating of the -- step six or 2 something like that. Five or I guess it's six.

3 MS. THOMPSON: Exactly, yes. Step six and 4 then step seven.

5 MEMBER BROWN: Right. So that's what you 6 then see. When we were questioning that before, 7 you've added this as a work around, in other words, to 8 not -- to eliminate going through all this what I 9 would call somewhat -- I'm not trying to be critical.

10 It's obviously more speculative, so you're giving them 11 a chance to look at SSCs and the site characteristics 12 and a few things like that as opposed to going through 13 all that other stuff. Is that correct?

14 MS. THOMPSON: That's correct.

15 CHAIRMAN BLEY: This is Dennis. I want to 16 interrupt. We don't have much time this morning.

17 MEMBER BROWN: Oh, I'm sorry.

18 CHAIRMAN BLEY: Can you hold the questions 19 that deal with part of the presentation that's coming 20 later on the process when we get to that point?

21 MEMBER BROWN: That's what I was going to 22 do. You got ahead of me. Thank you.

23 MS. THOMPSON: Okay.

24 MEMBER BROWN: Thank you.

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21 1 on. So we also made some changes to the screening for 2 proximal hazards. The staff recognizes that some 3 volcanic hazards are restricted to within about 40 4 kilometers or about 25 miles from a source volcano or 5 vent. Examples of these types of hazards would be 6 things like debris, avalanches, missiles and gases, 7 atmospheric phenomena like lightning or blast 8 overpressure, ground deformation and hydrothermal 9 systems.

10 So if a site is located greater than 40 11 kilometers or 25 miles from an existing or potential 12 new event, it's reasonable for an applicant to screen 13 out proximal hazards from further consideration.

14 The staff also noted and put into the Reg.

15 Guide 4.26 that if a site is located within 40 16 kilometers or 25 miles from an existing or new event, 17 we encourage pre-licensing consultation to determine 18 what would be considered the appropriate scope of 19 analysis for these proximal hazards for that 20 particular facility at that particular site. And so 21 that is reflected in Reg. Guide 4.26.

22 There were a lot of questions when we were 23 before ACRS.

24 VICE CHAIRMAN REMPE: Excuse me.

25 MS. THOMPSON: Sorry, go ahead.

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22 1 VICE CHAIRMAN REMPE: On the prior slide, 2 this is Joy, I mentioned at the last meeting about 3 other co-located or nearby facilities. And of course, 4 I think because I worked at INL for many years, the 5 fact that it's got a couple of reactors operating that 6 are in confinement buildings where ash could come in, 7 there's a fuel fabrication -- processing type facility 8 there. And I don't think that this site is unique.

9 There's other sites where you might have other 10 industrial hazards that could be affected by ash that 11 could affect the new plant.

12 Does this Reg. Guide deal with that? If 13 you're starting to site a new plant, what about ash 14 effects on other facilities that are nearby that could 15 impact the operation of the new reactor?

16 MS. THOMPSON: So the purpose of this 17 guide is really to look at the effect of the volcano 18 on the proposed facility. I don't know if Britt wants 19 to weigh in on the effect from other co-located 20 facilities that may be affected by a volcanic hazard, 21 but it wasn't the intent for an applicant to use this 22 guide to perform a volcanic hazards assessment for 23 each of the co-located facilities, but that in the 24 consideration of nearby facilities and the hazards 25 that those facilities may pose to the proposed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 facility, it would be encompassed within that 2 consideration of other man-made hazards rather than 3 within volcanic hazards.

4 VICE CHAIRMAN REMPE: Will the other man-5 made hazards consider explicitly volcanos and ash?

6 MS. THOMPSON: They would consider the 7 hazard to the facility from the nearby facility. I 8 don't know if they would look at the root cause of the 9 hazard that is induced from the other facility. So I 10 don't know if the other facilities are performing a 11 volcanic hazards assessment to determine what their 12 effect on the proposed facility would be.

13 VICE CHAIRMAN REMPE: It's just something 14 that I kind of think if we're going to do it for the 15 new facility that they need to think about what 16 happens to the other nearby or near proximity 17 facilities.

18 CHAIRMAN BLEY: I agree with that and I 19 think a warning to that effect might go in here. Do 20 we have anybody from the staff who's from the --

21 Center of Expertise on External Hazards with us? If 22 we do, they might be able to address this for us and 23 how they think about it.

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24 1 we have anyone on the call today who deals 2 specifically with man-made hazards unless the branch 3 chief would like to chime in or we can take this as a 4 takeaway to go back to our man-made hazards staff for 5 some consultation.

6 VICE CHAIRMAN REMPE: I know I brought 7 this up or at least I tried to in the prior meeting 8 and I thought that we would hear about it the next 9 time we met. And so yes, I would like to hear about 10 this.

11 MR. O'DONNELL: Yes, this is Ed O'Donnell 12 of the Reg. Guide Branch. I'll just jump in. The 13 Reg. Guides are forward fitting. They're not -- we 14 consider this is for a new site. It's a siting thing.

15 And it wouldn't be -- not necessarily be appropriate 16 for an existing facility that's already sitting there.

17 VICE CHAIRMAN REMPE: I'm talking about a 18 new facility that might be proposed at a site where 19 there are other facilities that could be affected by 20 volcanic ash or whatever and I don't think the INL 21 site is unique. I mean there might be other types of 22 plants with other types of hazards nearby that might 23 be sited. I am talking about a new facility and if 24 you're going to consider this hazard's effect on the 25 new facility, well, it could also affect other nearby NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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25 1 hazards is what I'm trying to convey here.

2 MR. O'DONNELL: I understood that. I 3 understood it.

4 MS. THOMPSON: What I can take as a 5 takeaway is I will consult with the man-made hazards 6 staff who do those reviews to see if they consider 7 failure of nearby facilities from a natural event in 8 the course of their review for a new site that's 9 considering nearby facilities.

10 VICE CHAIRMAN REMPE: Thank you.

11 MS. THOMPSON: All right, we'll move on to 12 the next slide. We made several changes -- we made a 13 lot of changes, actually, to better align Reg. Guide 14 4.26 with existing risk insights and guidance on using 15 risk insights. This was particularly in response to 16 a lot of comments that we received in February from 17 ACRS as well as comments from the public.

18 The comments from the public were very 19 specific on using Reg. Guide 1.233 which endorses NEI 20 1804 which is guidance for design basis event 21 sequences and beyond design basis event sequences.

22 And to address these comments, we actually added staff 23 to our working team to develop this Draft Guide who 24 had a lot of experience with both using risk insights 25 and the development of Reg. Guide 1.233 and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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26 1 endorsement, review and endorsement of NEI 1804.

2 And you'll see in Reg. Guide 4.26 that 3 we've integrated that guidance into the use of risk 4 insights in the volcanic hazards assessment. So Reg.

5 Guide 1.233 requires the mean 5th and 95th percentiles 6 in the consideration of design basis events and beyond 7 design basis event sequences. And those percentiles 8 are obtained from some form of probabalistic analysis 9 which for volcanic hazards would be from something 10 like a PVHA or a probabalistic volcanic hazard 11 assessment. And this process would allow an applicant 12 to evaluate the hazard contribution to the initiating 13 design basis event and beyond design basis event 14 sequences and to assess the significance using the 15 ASME/ANS methodology listed here.

16 And we do have staff who provided a lot of 17 insight to us on the use and integration of this Reg.

18 Guide and the endorsed NEI guidance here today that 19 can answer your specific risk insights related 20 questions. I don't know if you want to ask those now 21 or wait until the end of the presentation.

22 CHAIRMAN BLEY: I think we can wait until 23 we get into your process.

24 MS. THOMPSON: Okay, then I'll move on.

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27 1 to the guide to reflect the enhanced flexibility of 2 the proposed process. And I'll briefly walk through 3 this flow chart because it is new and different from 4 what we initially had in the Draft Guide.

5 So at the top you see our screening 6 criteria --

7 CHAIRMAN BLEY: Jenise?

8 MS. THOMPSON: Yes.

9 CHAIRMAN BLEY: When you got to this 10 point, I wanted to ask you a question. At this point, 11 are you considering any revisions to the draft of this 12 Reg. Guide that we received for this meeting?

13 MS. THOMPSON: We have made a few changes 14 since it was sent to ACRS. So there are a few changes 15 that have been made subsequent to the draft we sent to 16 you. And depending on your feedback here today and 17 whether ACRS would like to write a letter with 18 comments, we are open to making changes based on 19 feedback received.

20 CHAIRMAN BLEY: In particular, I found 21 this figure and the next very helpful and was kind of 22 hoping you'd say well, you decided that instead of 23 just presenting Figure 1, you'd present these two 24 because they really talk out the pathways for the 25 process. Go ahead. I think this is nice and might NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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28 1 enhance your Reg. Guide if you had both of them in it.

2 MS. THOMPSON: Okay.

3 CHAIRMAN BLEY: And if you can't do color, 4 you could do bold or something to clarify.

5 MS. THOMPSON: All right. So I appreciate 6 that feedback. So we have the screening at the top, 7 Quaternary volcanos in the region, yes or no. If no, 8 are there Quaternary volcanic deposits in the 9 vicinity? If both of those are no, this process does 10 not apply to that particular site. If either one is 11 a yes, they would move to screen volcanic hazards.

12 I went through most of these steps in more 13 detail at the February meeting, so I'll just touch on 14 them at a high level. For the screening of volcanic 15 hazards, this would be to determine which volcanic 16 hazard may reasonably reach the proposed site. If you 17 can screen them out that would be a yes. If you've 18 screened them, then the assessment is complete and you 19 would document your results. If the answer is no, 20 that some of these would screen in, you cannot screen 21 them out, you would move to developing initial risk 22 insights.

23 And the intent here at the first stage of 24 initial risk insights is really to consider whether an 25 engineering approach would work for the particular NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 1 site. So for something like ashfall, are there two 2 centimeters of ash in the vicinity of the site and the 3 ash screens in as a hazard, would it be reasonable to 4 consider an engineering analysis option based on the 5 risk insights, what you know of your proposed 6 facility. Would it be reasonable to jump straight to 7 evaluate your SSC performance? Or do you really need 8 to evaluate the eruption potential or hazard 9 potential? And this is where the two paths diverge.

10 CHAIRMAN BLEY: This is the place where I 11 wanted to raise a couple of issues. And I want to 12 mention for Charlie, the questions you were raising 13 earlier, don't raise them here, wait until the next 14 slide because that's where they're giving you a way 15 that's just a little different than what you see here.

16 When one looks at whether an engineering 17 analysis option is possible, if the issue we're 18 dealing with is ash and you very specifically say that 19 the ash particulate size is very much smaller than 20 what we usually see in wind-blown sand, but I mention 21 when people were developing regulation and approaches 22 for dealing with new reactors in the Middle East, some 23 of the desert sandstorms they have has very, very fine 24 sand, dust mixed together. And the stories I heard 25 from people who lived in that area and worked there, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 as you find that gets into things you felt were 2 completely sealed.

3 So my concern of when we look at 4 engineering options and mitigation kinds of 5 strategies, we think of particulates we're more 6 familiar with and think we can handle them very well 7 and from what I've heard and I've not seen the 8 evidence, dealing with very fine particulate can lead 9 you into problems that are much more difficult to deal 10 with on an engineering basis.

11 Nothing in the Reg. Guide warns people 12 about -- and if you don't have people who are very 13 conversant in how this stuff behaves, we could be 14 overly optimistic in our ability to do engineering 15 options.

16 Have you talked about that at all?

17 MS. THOMPSON: So we did talk about that 18 in the context of some of the comments from the --

19 that were received from the public. And we actually 20 had a public meeting with some of the commenters to 21 ask are there additional research or papers, 22 literature available on the effects of things like 23 fine particulates, volcanic ash on nuclear facilities 24 or on engineering components within a nuclear 25 facility? And we were not made aware of any.

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31 1 So we did go looking to see if there was 2 at least available information that could be cited or 3 referenced in this Reg. Guide, but we didn't identify 4 anything at the time. So if there are references or 5 operational experience that someone is aware of, we 6 are absolutely open to hearing to what that is and 7 finding that reference.

8 CHAIRMAN BLEY: I don't have a reference 9 for you, but I was involved some with the people who 10 were helping the United Arab Emirates as they were 11 beginning to build their regulatory process. And 12 that's where I heard these stories from people who 13 dealt with that kind of fine particulate. They might 14 have information on how it affects equipment.

15 Our comments last time about we don't have 16 any real guidance here for helping people understand 17 what this does to the failure rate of the various 18 kinds of equipment, we still don't have anything. The 19 Reg. Guide points to two sources, the ASME/ANS 20 standards and also to NEI 18-04, but there's really no 21 help there if you go and look in those two documents.

22 It tells you to worry about stuff like this, but it 23 doesn't tell you any way to determine the failure 24 rates.

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32 1 contacts through regulatory organizations with people 2 in the Emirates or other places like that or near 3 volcanic sites, you might get information from them 4 that would be helpful. I would think they've delved 5 into pretty well.

6 I saw Mike Corradini has his hand up. Do 7 you have anything, Mike?

8 DR. CORRADINI: No, Dennis, you -- you're 9 right on the money. When I was part of a review of 10 Barakah the FANR group there -- which is the 11 regulatory group -- does have some criteria. But --

12 but you've already identified it. So there was no 13 point to -- to add to it.

14 CHAIRMAN BLEY: Okay, and the number of 15 former -- I don't know if they're still there -- a 16 number of former NRC people had gone over to support 17 their development of the regulation. So you may have 18 some informal as well as formal contacts into that 19 organization. I -- I think it's worth pursuing. We 20 really don't have any help for people who are trying 21 to evaluate this other than saying -- assume 22 everything fails, which isn't very helpful. Ron 23 Ballinger?

24 MEMBER BALLINGER: Yes, I -- I would talk 25 a little bit to the gas turbine people because that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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33 1 where ash and fine sand can be very, very hazardous.

2 There have been a number of occasions where an 3 airplane has been foolishly flown too close to an ash 4 cloud and that shut down the engines -- not because of 5 lack of air or anything like that, but because the 6 ash, when it got to the hot section of the engine, 7 that was a big problem. And also, in the Middle East, 8 what happens is the fine sand gets precipitated out on 9 components and then when they start the engine up it 10 turns -- it melts and all that kind of stuff. And it 11 really is a -- it does affect the reliability of gas 12 turbines. So a plant that might have a gas turbine as 13 part of their emergency power -- you know, it's a bit 14 far fetched, but that's where you would find 15 information. Where there was a lot -- a lot --

16 there's actual data on that.

17 CHAIRMAN BLEY: Okay. I think that could 18 be helpful for the staff. The other thing I would 19 mention is -- we aren't quite there yet, but in step 20 6 they warned about ash and suggest an engineering fix 21 could be oil bath filters. And sometimes those can 22 lead to unintended consequences, and I -- I just 23 mention this because our instrument error systems 24 years ago, and service error systems advance used oil 25 filters, and on a number of occasions the oil got NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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34 1 carried over into the air stream and made those 2 systems unusable for a long period of time. And it's 3 almost impossible to clean them up if -- if that ever 4 gets into systems such as that. And I expect the ash 5 to get into those systems as well. So it's -- it's a 6 place where you might have some vulnerability and some 7 unintended consequences of an engineering fix that 8 hasn't been thought through thoroughly with enough 9 information about how these things behave. Jenise, go 10 ahead please.

11 MS. THOMPSON: Okay. So path one is the 12 traditional probabilistic VHA. So an applicant would 13 not take the engineering analysis option, but would 14 instead proceed to step 4 which is to evaluate the 15 eruption potential or hazard potential. This would be 16 through the calculation of the likelihoods of eruption 17 or the hazard reaching the site. The applicant would 18 then move to step 5 to develop additional risk 19 insights based on the eruption potential, or the 20 hazard potential. And if the risk is at an acceptable 21 level, an applicant would end the assessment and 22 document the results. If they are not, they would 23 proceed to step 6 and step 7, which are also the two 24 main steps in path two, which I am going to show you 25 next.

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35 1 So path -- path --

2 (Simultaneous speaking.)

3 CHAIRMAN BLEY: Yes -- so -- come back, 4 come back to your last -- path one slide.

5 MS. THOMPSON: Okay.

6 CHAIRMAN BLEY: Two issues here. One, I 7 am going to state my own interpretation of the 8 guidance you're giving people on evaluating the 9 eruption potential when -- when you talk -- and I 10 forget the exact words for the modeling that you use 11 for volcanoes -- in some ways that's analogous to the 12 modeling we do for earthquakes as well. And you 13 suggest the -- the SSHAC process for -- for dealing 14 with the uncertainties and unknowns or partial 15 unknowns in that process. And a number of members 16 raised issues that this is very speculative. But I 17 think it's -- there's -- there's a lot of information 18 that's been developed to support those models. And 19 maybe, after I'm finished here, you can talk a little 20 about that and a little about how the SSHAC process 21 let's you bring the -- all the information that's 22 available to the analysis. That's number one -- and 23 if you can talk about that some, I think it would be 24 helpful to us.

25 And number two is, when you get down to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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36 1 the bottom there, as you say, you go to evaluating the 2 performance and evaluating mitigating actions -- and 3 the thing that bothered -- the only thing that 4 bothered me out of your flow charts here is they seem 5 to imply that there's always a successful endpoint.

6 And that might not be true. We might not be able to 7 mitigate -- or the performance might not be good 8 enough. And I didn't see anything in the text to 9 really clarify that.

10 That's point number two. So if you can 11 talk about those two, I would appreciate it. And then 12 go on to the next slide.

13 MS. THOMPSON: Okay, so I actually have a 14 slide coming up on the clarifications we made with 15 respect to SSHAC, but I will speak very high level 16 about those now and then we can get more into the --

17 the detail. But essentially in using a SSHAC to 18 evaluate the eruption potential or hazard potential 19 it's bringing together a group of experts to evaluate 20 all of the information and reach a consensus on the 21 eruption potential or the hazard potential at a high 22 level. That's what we're proposing to use here.

23 As for the end of the flow chart here, we 24 appreciate that comment and that's why we actually 25 removed the A. There used to be an acceptable down NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 1 here. And there was also a (inaudible) here taking 2 you to another step in the process. But as you'll see 3 later in the presentation, that is something that 4 we've actually removed from both the -- the reg guide 5 and the flow chart. And the reason for that is that 6 it -- it would be possible to end the assessment and 7 document your results without A, the desired outcome.

8 Because this is just a -- this is a hazard evaluation 9 that's informing a siting decision, but this isn't a 10 how to make your siting decisions reg guide, it's the 11 assessment of the hazard at your potential site and 12 documenting what that lingering hazard is after you 13 have evaluated your SSC performance and evaluated your 14 mitigating actions is -- is still a successful outcome 15 for analyzing your hazard even if the outcome on the 16 facility isn't the desired outcome.

17 CHAIRMAN BLEY: Okay, I -- and I don't 18 know if it's worth a few words like you just gave me 19 being in the text for -- for a reader like myself. It 20 would be useful to have that there, but I -- I see 21 your point.

22 MS. THOMPSON: Okay.

23 MEMBER BROWN: I wanted to echo Dennis's 24 comment. I -- because when I looked at this I saw the 25 A down on -- on step 7. And now that's -- that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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38 1 disappeared. So obviously -- you -- that's -- was not 2 -- that was -- the A was in the copy you gave us for 3 review.

4 CHAIRMAN BLEY: That's correct, yes.

5 MEMBER BROWN: And -- and I think it --

6 some of this stuff you say, it makes a lot of sense.

7 But to -- to the relatively uninitiated, or lower-8 level mind people like me, some of that explanation 9 works real well to clarify with what your thought 10 process is for this whole --

11 (Simultaneous speaking.)

12 MEMBER BROWN: -- it's relatively complex, 13 so the -- your all's comments like that would make a 14 lot of difference, I think, if people tried to work 15 their way through it. I just -- just wanted to make 16 sure you're -- there's more than one person thinking 17 that way.

18 MS. THOMPSON: Yes, and -- like I said, 19 the reg guide -- the version that was sent to ACRS 20 ahead of today's presentation -- we have made some 21 changes. You've already noted what some of them have 22 been, so the -- some of these are already reflected in 23 the updates that we've been -- been making since we 24 sent you the version that we had that was current, I 25 guess back in March when we sent it to you. So -- but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 1 I'll make a note of this to ensure that we include 2 additional clarifying texts.

3 CHAIRMAN BLEY: Great, thank you Jenise 4 because I -- I looked through your slides, and I 5 didn't even notice the A had disappeared, which would 6 have helped a little bit. But I -- I would have still 7 had a bit of the same question, so -- go ahead.

8 MS. THOMPSON: Okay, all right. So the 9 second path of this enhanced flexibility approach is 10 the engineering path. And that, as you have noticed, 11 is the (inaudible) off of the engineering analysis 12 option that would allow an applicant to either 13 evaluate the (inaudible) performance, or evaluate the 14 mitigating actions. And then to even have the 15 possibility of iterating between steps 6 and steps 7, 16 considering changes to either mitigating actions or 17 enhancements to their select design based on their 18 evaluations.

19 And to do these analyses, the applicant 20 would bound the hazard level at the screening -- or, 21 would bound the hazard at the screening level. So if, 22 at step 2, an applicant determined that six inches of 23 ash was the hazard of consideration -- the volcanic 24 hazard to be considered for this particular site, then 25 at the step 6 or step 7 six inches of ash is what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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40 1 those evaluations would consider for either SSC 2 performance or mitigating actions. So this would 3 allow an applicant to assume this bounding hazard 4 level, evaluate SSC performance, and/or the mitigating 5 actions. And then also to see if the hazard is a 6 potentially significant contributor to initiating 7 event sequences. So that is path two for engineering.

8 And I will pause because I know that there were some 9 questions on the engineering side -- or did we already 10 address those?

11 CHAIRMAN BLEY: You kind of did. But I --

12 I guess the points we all were talking about on how 13 you evaluate the likelihood of ash causing failures in 14 equipment remains an issue that at least I think 15 deserves a note that, you know, there's no clear path 16 forward here as yet. Somebody is going to have to 17 develop this. Again, in steps 5 and 6 the references 18 to the -- the PRA standard and to the NEI document on 19 what's known as -- well, the new regulatory process --

20 they identify the issue, but they really don't give a 21 you a way out. And right now steps 5 and 6 make it 22 sound like all you have to do is go look it up in 23 those two documents and you can solve these problems.

24 And that's -- that's not true.

25 DR. CORRADINI: Dennis, this is Corradini.

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41 1 Can I break in with a question? Or are you still in 2 the middle?

3 CHAIRMAN BLEY: You've broken in -- you're 4 fine.

5 DR. CORRADINI: Okay, but -- so can I go 6 back to the Columbia Station as an empirical example?

7 Where did they screen out -- or did they have to go 8 through this analysis? If I -- (inaudible) here, can 9 you remind me where they screened out?

10 MS. THOMPSON: So the Columbia facility 11 essentially went through the full analysis and 12 identified the appropriate mitigating actions for 13 their design-basis volcanic event, which was a -- an 14 ash fall event from a cascade eruption. So they have 15 a series of mitigating actions for that particular ash 16 fall hazard.

17 DR. CORRADINI: Okay, so they followed 18 what -- what you would call here path one, and 19 successfully went through that analysis?

20 MS. THOMPSON: Actually, I'm going to 21 defer to Britt here. Did they do the full path one 22 with the eruptions potential or hazard potential? I 23 -- this was well before my time.

24 DR. HILL: Yes, this is Britt Hill, 25 Consultant for the NRC staff. Columbia -- it's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 1 little more complicated pathway. They receive their 2 initial construction permit and had used a 3 deterministic approach to say, the maximum ash fall --

4 I forget the exact number, but it was a couple of 5 inches, perhaps for a cascade volcano. The 6 construction permit started, I believe, in the late 7 '70s. And then during construction Mount St. Helens 8 erupted and deposited -- I think it was roughly twice 9 the amount of ash at the site than -- it was 10 originally used as a design basis.

11 So before they got their operating permit, 12 they updated the design basis to include the 1980 ash 13 fall from Mount St. Helens. And basically all that 14 changed was some operational procedures where they had 15 some ash -- have some ash mitigation strategies in the 16 event a cascade volcano produced an ash fall eruption.

17 Part of those mitigation strategies include puffing 18 out the air filters on the emergency diesel generators 19 with oil bath -- or, with oil bath air filters on the 20 EDGs. And an increased maintenance cycle on several 21 other filtration systems.

22 (Simultaneous speaking.)

23 PARTICIPANT: Yes --

24 MEMBER KIRCHNER: Britt, this is Walt 25 Kirchner. That's what I remember -- that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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43 1 mitigating -- I can't find the word right now --

2 DR. CORRADINI: Compensatory --

3 MEMBER KIRCHNER: Compensatory where --

4 what is the change out and the emergency diesel 5 generators to those oil bath filters.

6 DR. HILL: Right, so they -- they 7 basically took the engineering path -- path two here.

8 (Simultaneous speaking.)

9 DR. CORRADINI: Okay -- okay, so --

10 DR. HILL: Screening analysis, bounded the 11 ash, and then -- hey, we've got some mitigating 12 approaches that would work.

13 DR. CORRADINI: Okay, so in essence they 14 took a out-of-step engineering and -- well, not out-15 of-step -- but they took the new pathway even though 16 it didn't exist at the time?

17 DR. HILL: That's correct.

18 DR. CORRADINI: Okay, thank you.

19 CHAIRMAN BLEY: Well, no pathways existed 20 at the time, so -- that was fair. I -- one comment --

21 last comment from me on -- in this area, Jenise.

22 First, earlier you said you had comments on ACRS and 23 -- you had comments from individual members at the 24 last meeting. We only speak through our letters, of 25 which we might speak again -- we'll decide that after NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 1 this session.

2 As I read this and think about it, your 3 path two is kind of the easiest way through. And I am 4 just wondering if it would make the presentation and 5 the reg guide smoother -- especially if you use the 6 pictures -- if you made what is now path two, path 7 one, and vice versa? And then path -- the path 8 through the full analysis is the most detailed one, 9 which you'd go to if you had to? But that's just from 10 me, so you guys can think about it. And please go 11 ahead with the presentation.

12 MS. THOMPSON: Okay. Well we'll consider 13 reorganizing the flow chart. It's been through 14 several iterations as you guys have noted. All right.

15 So I -- I said we expanded -- I said we'd get to SSHAC 16 later, and here we are. We expanded on the guidance 17 of using SSHAC for volcanic hazards assessments. We 18 clarified the selection of study levels. There are 19 four different choices -- one through four -- that 20 would -- could be appropriate, depending on the 21 volcanic hazard analysis. We clarified that both 22 study levels three and four provide equivalent 23 regulatory assurance because one of the comments we 24 received from the public was that it was not clear 25 that that was being stated in the reg guide, and we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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45 1 wanted to clarify that point. We also provided 2 clarifying text on the flexibility of using a SSHAC 3 for a VHA by a prospective applicant. And then we've 4 also added text to encourage pre-application meetings 5 for any applicant that is considering using a SSHAC as 6 part of their VHA. And part of the reason for that is 7 to ensure that the applicant is choosing the 8 appropriate SSHAC study level at the onset of their 9 process rather than choosing a study level, getting 10 start, and then realizing that they need to change 11 study levels for whatever reason.

12 And we also have someone from our working 13 group here who can answer any more detailed questions 14 you may have specific to SSHAC. So I will pause if 15 there are any questions.

16 (No audible response.)

17 MS. THOMPSON: All right, I will move 18 forward. I mentioned this before, we -- and I 19 presented this at the February meeting of last year 20 regarding the tectono-magmatic model. We provided 21 some clarifying text based on feedback from the public 22 comments that the tectono-magmatic model essentially 23 integrates the tectonic and volcanic information into 24 a logical framework and that it's not a complex 25 numerical model, but it's rather a conceptual model NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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46 1 for a volcanic system, and it would allo an applicant 2 to determine if -- or which of the Quaternary 3 volcanoes -- again, that's the 2.6-million-year or 4 younger volcanoes in a region of interest -- are 5 potentially active given th current tectono-magmatic 6 conditions.

7 And the reason for this is because 2.6 8 million years is a really long time for some volcanic 9 systems. While there are some volcanic systems that 10 are active continuously for millions of years, there 11 are other systems like the Cascades that have shorter 12 life cycles on the order of hundreds of thousands of 13 years, rather than millions. So not all Quaternary-14 aged volcanoes may need to be considered in a volcanic 15 hazards assessment. And a tectono-magmatic model 16 would present the rationale and justification for why 17 some Quaternary volcanoes would need to be considered, 18 but some Quaternary volcanoes in the same region would 19 not.

20 CHAIRMAN BLEY: Jenise?

21 MS. THOMPSON: Yes.

22 CHAIRMAN BLEY: Yes, this is a -- a point 23 for -- a question on the uncertainties involved here.

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47 1 volcanologists on the validity and value of these 2 tectono-magmatic models and their ability to be help 3 you pin these numbers down with -- you know, it's just 4 some level of comfort.

5 MS. THOMPSON: I am actually going to 6 defer to Britt on that because he has a lot more 7 experience with these tectono-magmatic models than I 8 do.

9 CHAIRMAN BLEY: Sure.

10 DR. HILL: Sure. In terms of consensus, 11 the concept of using tectono-magmatic models for these 12 exact purposes was incorporated into the IAEA site-13 specific safety guide 21 and that also was an 14 intrinsic part of the process they were using in the 15 supporting tech doc. It's been applied, I think most 16 successfully in Japan recently for some of their 17 volcanic hazards related studies for the nuclear waste 18 repository siting. But I would caveat this a little 19 bit in that there have been very few formally 20 conducted probabilistic volcanic hazards assessments.

21 And only one or two that I am aware of that have even 22 used the IAEA approach. Specifically that was applied 23 in Armenia back about ten years ago.

24 So it's hard to say that there is a broad 25 consistency with something called the tectono-magmatic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 1 model, however it's long been recognized in 2 volcanology that there are spatial and temporal 3 patterns that are controlled by evolution of the 4 tectonic regime as well as the magmatic system over 5 periods of hundreds of thousands to millions of years.

6 So I think this concept is well-embraced by the 7 community even if it hasn't been called a tectono-8 magmatic (inaudible) model.

9 CHAIRMAN BLEY: For those few cases where 10 you've seen a detailed analysis, were there severe 11 critiques of them? Or pretty much agreement that it's 12 as good a job as you can do with what we know?

13 DR. HILL: Well, I was on part of the IAEA 14 review team for the Armenia mission and we found the 15 rationale presented for excluding some of the 16 volcanoes within the region of interest to be 17 supportable and technically justified. I -- familiar 18 with several Japanese examples -- or the Japanese 19 example that eliminated several Quaternary systems 20 from consideration as being reasonable and accepted.

21 CHAIRMAN BLEY: Okay, thank you. And 22 Jenise, I'm going to (inaudible) something you're 23 going to get to later, but it -- it's -- I'm just a 24 little curious about it. You -- you actually base a 25 lot of what you developed here on those two reports --

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49 1 the tech doc and the (inaudible), but you specifically 2 do not endorse them. And then you have a section 3 where you go to great pains to explain why you're 4 different from them. And if you're not endorsing 5 them, I don't know why you want to do that. So when 6 you get to that part of your presentation you can talk 7 about this one. I'll let you go ahead.

8 MS. THOMPSON: Okay. Yes, we're two 9 slides away from -- from that part of the 10 presentation. So just to finish with the tectono-11 magmatic model -- it's a way to evaluate potential for 12 non-stationary processes, such as eruption rates and 13 hazard characteristics. So this is all, again, 14 revisions that have been made and are reflected in Reg 15 Guide 4.26.

16 As I mentioned earlier, we made 17 significant changes to the flow chart. This included 18 deleting siting considerations. So the flow chart you 19 see here is what was presented last February -- what 20 was included in the draft guide that went out for 21 public comment. And we've removed siting 22 considerations at the end here. And the reason for 23 that is we had a lot of internal discussions amongst 24 the staff and ultimately determined that it wasn't 25 consistent with the scope of the regulatory guide --

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50 1 which is really focused on evaluating the potential 2 natural hazards at the proposed site -- in this case, 3 volcanic hazards. So the siting considerations wasn't 4 really part of the evaluation of the hazards at the 5 site.

6 We've also provided -- we -- the 7 restricted extent of some volcanic hazards. We've 8 captured that concept within the text. And then also 9 we received some public comments that siting 10 considerations within the scope of a hazard evaluation 11 reg guide was creating some confusion with the 12 consideration of alternative sites that is included as 13 part of the environmental review. So it just wasn't 14 consistent so it -- it has been removed -- all of that 15 text. And then the flow chart revised accordingly.

16 The last few clarifications I have to 17 share are related to the treatment of international 18 standards. We've provided an enhanced discussion on 19 the consideration of international standards including 20 the IAEA (inaudible) and (inaudible) 21. The reason 21 we include and consider this is a requirement of 22 Management Directive 6.6. So if there is a relevant 23 IAEA guide or standard we do need to consider it and 24 document why we are or are not endorsing that guidance 25 within our related regulatory guide.

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51 1 So we provided text to clarify that using 2 -- although using the IAEA information is not an 3 endorsement of the IAEA guidance, because this reg 4 guide is not a detailed technical report, and the IAEA 5 documents do provide and have consolidated a lot of 6 very useful and relevant technical information, that 7 it would be appropriate to reference those technical 8 sources of a lot of information within this regulatory 9 guide.

10 And then the final clarification that 11 we've made within the consideration of international 12 standards is to supplement the discussion of the USGS 13 -- the United States Geological Survey and their 14 statutory role to monitor potentially hazardous 15 volcanoes in the United States, which again is a 16 deviation from the IAEA guidance that would not have 17 the monitoring of volcanoes being performed by the 18 USGS, but that would be the responsibility of a 19 prospective applicant or eventual licensee. So those 20 were some of the reasons why that -- that discussion 21 is as long as it is. And I know there were some --

22 some questions. I don't know if I addressed them all 23 or if you had additional follow up.

24 CHAIRMAN BLEY: That's fine. Go on to 25 your last one.

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52 1 MS. THOMPSON: Okay. So in conclusion, 2 we've spent a lot of time looking over the comments 3 that were shared at the previous ACRS briefing, as 4 well as the public comments that we received during 5 our public comment period. The staff working group 6 believes that Reg Guide 4.6 is maximizing the 7 flexibility in this VHA approach, again, through those 8 two different paths. Either the traditional VHA or 9 the engineering approach. And we've also made 10 significant revisions to adopt and integrate the 11 current PRA guidance on developing risk insights and 12 how that would be applied in the context of volcanic 13 hazards.

14 For all these reasons the staff believes 15 that Reg Guide 4.26 is ready for issuance. One thing 16 I will add in closing is that part of the reason the 17 schedule was moved forward is because the ANS standard 18 that at the time was under development -- last year --

19 has been on a bit of a hold due to pandemic 20 considerations and other things. So we will evaluate 21 the need to revise Reg Guide 4.6 when that ANS 22 standard on VHA is issued at some point in the future.

23 And we do have one of our staff working group members 24 who is on that ANS committee and is keeping us updated 25 on the progress that they are making. And with that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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53 1 -- that is the end of our presentation and hopefully 2 there's enough time to answer any questions you may 3 have.

4 CHAIRMAN BLEY: Thank you and I -- I guess 5 our history with the ANS standards is -- it takes a 6 long time for them to get approved. Do you have any 7 estimates for when you think that might happen? I 8 know that won't be -- they're probably not any more 9 thorough in guessing on your -- the volcanoes --

10 (Simultaneous speaking.)

11 MS. THOMPSON: We do not. The -- the last 12 date that we had heard was some time the first half of 13 2022. But it's been well over a year since we've 14 heard any further updates. So I don't actually know 15 other than some time after 2022 I think would be 16 reasonable.

17 CHAIRMAN BLEY: Okay, thank you. I see 18 Greg Halnon has his hand up. Greg, please go ahead.

19 MR. HALNON: Thank you, Dennis. Just a 20 comment -- and goes back to Joy's question early on 21 about the existing plant -- or facilities. We saw 22 this play out during the Fukushima response where we 23 had an application of some new standards to existing 24 plants. And it's a very practical consideration to 25 think that the newer plant sitings are going to end up NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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54 1 either on or near existing nuclear plants. I sited an 2 SMR in the past and the nuclear plants existing sites 3 came very high up on the ranking process when you 4 place an SMR. So it's a very practical question and 5 I think it needs to be emphasized that we need to not 6 get in the same quandary that we did with the existing 7 plant sites -- for example, applying new flooding 8 standards and others. I can see where mitigating 9 actions may have to be taken at a new site and there's 10 an existing site next to it with a licensing basis 11 that -- it would apply. And then you have to -- this 12 quandary between I'm doing one -- you know, I'm less 13 than a mile away. I'm taking action on the existing 14 site -- not -- so I would just emphasize that question 15 needs to be really applied -- looking at the lessons 16 learned from the Fukushima response that we just went 17 through.

18 CHAIRMAN BLEY: Okay, thank you. Members 19 at this point -- well, I'm going to ask for public 20 comments. But before that, give some thought. As 21 soon as this is finished we're going to have a session 22 for discussing whether we want to write a letter and 23 what issues remain. And we will go into that very 24 shortly. So I am not going to go around for comments 25 from everyone. But after public comments, if there's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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55 1 anything you individually would like to get on the 2 record while we're in this presentation, I'll give you 3 that opportunity. Can we have the public line open?

4 MEMBER BROWN: Will Jenise still be there 5 when we finish the public stuff?

6 (No audible response.)

7 MEMBER BROWN: This is Charlie.

8 MS. THOMPSON: Yes, I will be there --

9 (Simultaneous speaking.)

10 PARTICIPANT: Yes, I had a question. I 11 don't want to interrupt, I --

12 MS. THOMPSON: I will be on the call until 13 11:30.

14 MEMBER BROWN: Okay, I had one other 15 question that I didn't -- that I didn't interrupt 16 anything for. I'll wait until after the public 17 comments. Go ahead, Dennis, thank you.

18 CHAIRMAN BLEY: Go ahead with the 19 question.

20 MEMBER BROWN: No, it's just a -- in steps 21 6 and 7, I walked -- as I walked through that as I was 22 reviewing it, I wanted to confirm that this looked to 23 me like engineers, people sitting around and -- under 24 steps 6 and 7 -- and looking at the equipment and 25 doing what I call engineering judgment evaluations and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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56 1 analyses of their systems relative to the thing they 2 may have to consider from -- you know, various items.

3 It didn't talk about getting into any types of 4 probabilistic stuff. It looked like fundamentally 5 engineering judgment -- deterministic engineering 6 judgment. Is that a valid thought process for a 6 and 7 7?

8 (No audible response.)

9 MEMBER BROWN: Are you there?

10 MS. THOMPSON: Sorry, I was muted.

11 MEMBER BROWN: Okay.

12 MS. THOMPSON: Of course. It was going to 13 happen at least once.

14 MEMBER BROWN: Did you -- well, it happens 15 to me all the time. I'm so old. Did you hear my 16 question?

17 MS. THOMPSON: Yes, I -- I heard your 18 question. So we're -- step 6 and step 7, it's really 19 meant to be -- we purposely did not put in a lot of 20 prescription in an effort to keep things technology-21 inclusive. So what we were aiming for was to provide 22 a -- a framework for decision making that could 23 include consideration of the performance of SSCs 24 rather than a specific evaluation based on existing 25 design -- trying to be non -- trying to be technology NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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57 1 inclusive. So --

2 (Pause.)

3 MEMBER BROWN: I'm just wondering --

4 (Simultaneous speaking.)

5 MS. THOMPSON: I don't know if that --

6 MEMBER BROWN: I'm just worried about 7 getting too analytical in -- and getting wrapped up in 8 uncertainties of equipment performance and -- I mean, 9 engineers sit around and do this all the time. Just 10 say, hey, do we think this stuff work okay or not?

11 And generally you can -- I just read that as if we 12 were going to be able to use some judgment, that's 13 all. That was one of my concerns when I first saw 14 this last time. Seems like we're going to make sure 15 we can do that. That's all.

16 MS. THOMPSON: Okay.

17 MEMBER BROWN: And if the answer is yes, 18 then I am happy. If the answer is no, then I guess 19 I'm not. Did you say yes, or not?

20 (Laughter.)

21 MS. THOMPSON: I think it would be 22 considered appropriate if -- to use some engineering 23 judgment.

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58 1 Jenise. Go ahead, Dennis. Sorry.

2 CHAIRMAN BLEY: Okay. Thomas, can we get 3 the --

4 (Simultaneous speaking.)

5 VICE CHAIRMAN REMPE: Dennis, this is Joy.

6 I kind of raised my hand. Before you go to the public 7 line, I guess I want to reiterate to make sure that 8 everybody understands what my concern is.

9 It's not just other NRC licensed 10 facilities that have different requirements. I'm 11 looking at even other non-NRC, nuclear or non-nuclear, 12 facilities that might be impacted by ash that could 13 affect the new facility. And again, this comes up 14 with the facilities out at the site which are in this 15 case nuclear, not licensed by NRC but authorized to 16 operate by DOE, that might have some adverse effects 17 from ash going over that might impact the new 18 facilities' operation and strategies for dealing with 19 the event. Okay?

20 CHAIRMAN BLEY: Yeah, thanks, Joy.

21 VICE CHAIRMAN REMPE: Thank you.

22 CHAIRMAN BLEY: Is the public line open?

23 Hello, hello? Gary --

24 (Simultaneous speaking.)

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59 1 we please open the public line?

2 CHAIRMAN BLEY: While we're waiting for 3 the public line to get open, I see Gary Becker from 4 NuScale wants to say something. So this is a fine 5 time. Go ahead with your comment.

6 MR. BECKER: Thank you. First of all, can 7 you hear me okay?

8 CHAIRMAN BLEY: Just fine.

9 MR. BECKER: Okay. Yes, thank you. I've 10 joined the Teams format here so using this opportunity 11 for the public comment to make mine. And at the 12 outset, I want to say this might be a bit of a lengthy 13 comment. So I don't intend to abuse my time here, but 14 I do have some important points to make. We, NuScale 15 -- on behalf of NuScale, I'd like to say there are 16 substantial improvements in this version of the 17 guidance.

18 We appreciate staff's resolution of some 19 of our industry's concerns in the previous version, 20 and they were substantial. The improved in clear 21 ashfall region of interest is helpful, the use of the 22 NEI 1804 sequence definitions, the new path to step 6 23 and 7, option 2 as it was termed in the flowcharts, 24 and clarification on the tectono-magnmatic model.

25 Those are all improvements in this version of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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60 1 guidance, and we appreciate staff heeding our inputs 2 on those issues.

3 But I do -- I still see substantial 4 questions and challenges throughout the document.

5 There are notable ambiguities, gaps, and challenges 6 that -- ambiguities and gaps and that are going to 7 make, in my opinion, this guidance difficult to 8 implement and creates a lot of uncertainty on whether 9 it's a workable approach, the ambiguities in the level 10 of SSHAC study that's needed. Staff have included 11 more qualitative descriptors, but they're still --

12 it's still completely subjective as to the level of 13 SSHAC study.

14 There's a term, maximum magnitude event, 15 that's introduced in step 2. But it's never 16 explained. It seems to relate to how far a hazard can 17 travel. But in step 3, it seems to refer to the scale 18 of a hazard once it reaches the site. I don't know 19 how that's determined, whether that's through the 20 SSHAC determination, whether it's a simpler SSHAC 21 determination. I'm not sure.

22 Step 3 seems to provide an option for a 23 simplistic risk-informed determination. But it 24 includes statements that the unsuccessful performance 25 of a facility's DBE and BDBE sequences might have such NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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61 1 a small likelihood of occurrence that a maximum 2 magnitude volcanic hazard would not represent 3 potentially significant contribution to initiating 4 events. There's a similar statement with respect to 5 consequences. I don't know what that statement means 6 or how it's supposed to be used. It seems to provide 7 an opening, but I don't know if it's workable.

8 There's gaps in here. Step 5 refers to 9 volcanic hazard sequences as either design basis or 10 beyond design basis. But there's no differentiation 11 between those two classes as to how they're treated in 12 the guidance. So I'm not sure why they're defined.

13 Throughout the guidance, it refers to a 14 volcanic hazard alternatively as either an initiating 15 event or a contribution to an event sequence. Those 16 are completely different, of course. And it seems to 17 imply, at least in some cases, that we may need to 18 consider a volcanic eruption during some other event.

19 Of course, that's a serious concerns of ours if that 20 is indeed the case.

21 And then step 6 which Mr. Brown just 22 touched on talks of evaluating the existing design 23 basis of SSEs. And it seems to imply that the 24 licensing analysis, the final safety analysis report 25 somehow comes after the design is completed and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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62 1 design basis is established. And that's simply not 2 the case. It's not reflective of a design process 3 that would include these hazards if they're found 4 within the design documentation itself. So it seems 5 to misrepresent how the design process would actually 6 be done and create some uncertainty in staff's 7 expectations there.

8 So at the end, and then I'd like to make 9 note of more major concern which is, again, in step 6.

10 I don't know which SSEs I'm evaluating for there, 11 resilience to a volcanic hazard. There's no 12 indication of whether we're talking all safety-related 13 SSEs, seismic 1 SSEs which would be even broader, or 14 we're just talking about SSE if I needed to respond to 15 the volcanic hazard.

16 And if that's the case, what response is 17 warranted for volcanic hazard? Does it simply say, 18 shut down, or something else? I understand Ms.

19 Thompson's last statement that that's intended to 20 provide some flexibility, a framework. But to me, 21 that just creates a huge question mark that's ripe for 22 dispute and challenges during implementation.

23 So again, that was a lot, and I have -- I 24 could go on. I'd note that consequences of an event, 25 a volcanic sequence, are nowhere considered in this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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63 1 risk-informed guidance. But that brings me to my 2 ultimate point which is that we think this would have 3 been appropriate to republish for public comments, and 4 we understand staff don't intend to do so.

5 So in the alternative, we think it may be 6 preferable to delay the issuance until there's an 7 opportunity to try this out. I think there's enough 8 question marks in here, and the ACRS have touched on 9 even more today, that we're really not sure if this is 10 going to be practicable to use. And we, NuScale, on 11 behalf of a future licensee of our design of course 12 have a substantial interest in its use.

13 So we think that perhaps an in-depth 14 tabletop exercise with NRC, INL because it's a future 15 site of potential multiple reactors, and the potential 16 applicants for those reactors -- current and potential 17 applicants for those reactors. Some kind of tabletop 18 exercise could be appropriate. Or perhaps even 19 better, a deeper look into -- a deeper trial into 20 using this guidance could be a pilot project designed 21 to implement it in a collaborative manner between 22 staff and a near-term applicant.

23 And that kind of use -- that kind of trial 24 and use could reveal and help clarify all the 25 ambiguities and inconsistencies I've touched on. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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64 1 at the end of the day, I just want to say that once 2 this reg guide is in place, we and several other 3 vendors and applicants are going to be the ones to 4 have to use it for the first time. And if it's not 5 don't correctly, it's going to present a substantial 6 impediment to these projects. And so we really want 7 to make sure we get this right on the initial 8 issuance. Thank you.

9 CHAIRMAN BLEY: Thank you, Mr. Becker. I 10 see that Professor Bier is wanting to make a comment.

11 Please go ahead.

12 DR. BIER: Hi. Sorry, I had to unmute 13 myself. I just wanted to respond briefly to -- I 14 think it was Joy's earlier comment that nuclear plant 15 PRA does take into account things like impact from a 16 chemical accident nearby or possible aircraft impact 17 if a plant is located really near an airport, and 18 those kinds of things. Again, even though as Joy 19 pointed out, those facilities are not regulated by 20 NRC, they certainly could have an impact on nuclear 21 operation following a volcanic eruption.

22 VICE CHAIRMAN REMPE: So Vicki, the 23 question I'm raising is, do they consider volcanic 24 eruptions? For example, I do know the INL facilities 25 authorized by DOE do. But as Greg mentioned, they may NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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65 1 have different requirements than what's in this new 2 reg guide? What about the other non-nuclear hazards?

3 Do they consider volcanic ash in your experience?

4 DR. BIER: I would be surprised. My 5 experience with chemical facilities is a very, very 6 long time ago. But I would be surprised if their risk 7 analyses go to that level of detail.

8 VICE CHAIRMAN REMPE: That's where I'm 9 going to that somebody needs to bump it up a bit.

10 Thank you.

11 DR. BIER: Yeah.

12 CHAIRMAN BLEY: Okay. Thank you. I'm 13 going to assume the public line is open and ask if 14 there's any members of the public who would like to 15 make a comment. If so, please state your name and 16 give us your comment. And now I'll question my 17 assumptions since -- hello? I guess I will now ask 18 our staff, is the public line actually open?

19 PARTICIPANT: Yes, the public line is open 20 for comments.

21 CHAIRMAN BLEY: Okay. So we now 22 understand the line is open. If anybody is out there 23 and wants to make a comment, please state your name 24 and give us your comment.

25 (No audible response.)

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66 1 CHAIRMAN BLEY: Hearing none, let's close 2 the public line.

3 PARTICIPANT: Closing public line.

4 CHAIRMAN BLEY: Mr. Chairman, back to you.

5 I thought we'd be there with minutes to spare, but 6 we've stretched it out a little bit. Do you want to 7 take a break before we go into our discussion period?

8 CHAIRMAN SUNSERI: Yeah, let me -- we have 9 30 minutes until our next session starts. We do need 10 a break, so we'll go ahead and take a 20-minute break 11 at this point in time. We'll reconvene at 20 after 12 the hour.

13 We'll deliberate for 10 minutes, and we'll 14 have time later on in the meeting where we can 15 continue deliberations. But we can at least start the 16 discussion. Is that acceptable to you, Dennis?

17 CHAIRMAN BLEY: That's fine. And at that 18 time, Derek will have some notes from me to put up on 19 the screen.

20 CHAIRMAN SUNSERI: Okay.

21 CHAIRMAN BLEY: Thank you.

22 CHAIRMAN SUNSERI: Very good. So we will 23 take a break here until 20 after the hour, and we'll 24 reconvene then. Thank you.

25 (Whereupon, the above-entitled matter went NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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67 1 off the record at 10:58 a.m. and resumed at 11:20 2 a.m.)

3 CHAIRMAN SUNSERI: Okay. It's 20 after.

4 We will reconvene the meeting with a quick roll call.

5 I'll start with Ron Ballinger.

6 MEMBER BALLINGER: Here.

7 CHAIRMAN SUNSERI: Dennis Bley?

8 CHAIRMAN BLEY: Here.

9 CHAIRMAN SUNSERI: Charles Brown?

10 MEMBER BROWN: Here.

11 CHAIRMAN SUNSERI: Vesna Dimitrijevic?

12 MEMBER DIMITRIJEVIC: Here.

13 CHAIRMAN SUNSERI: Walt Kirchner?

14 (No audible response.)

15 CHAIRMAN SUNSERI: Jose March-Leuba?

16 MEMBER MARCH-LEUBA: Yes.

17 CHAIRMAN SUNSERI: Dave Petti?

18 MEMBER PETTI: Here.

19 CHAIRMAN SUNSERI: Joy Rempe?

20 VICE CHAIRMAN REMPE: Here.

21 CHAIRMAN SUNSERI: Pete Riccardella?

22 MEMBER RICCARDELLA: Here.

23 CHAIRMAN SUNSERI: And Walt Kirchner?

24 MEMBER KIRCHNER: I'm here, Matt. Sorry.

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68 1 right. So we just have a short period of time here, 2 10 minutes to get started with our deliberation on 3 this topic. I'm going to ask -- and I've already 4 confirmed with the transcriber that we'll continue 5 transcribing through this part of the meeting since 6 we're not actually writing a letter at this point in 7 time and still gathering important information that we 8 might need for a later date.

9 So we're going to continue with the 10 transcription. And we have to terminate directly at 11 11:30 so we can get into the next topic. We are 12 pretty tight on time this week, so I'll turn it over 13 to Dennis.

14 CHAIRMAN BLEY: That's 10 minutes. Rather 15 than a deliberation, let me run -- I made -- I 16 prepared some slides to kind of lead the discussion.

17 So let me run through a couple quickly. I think the 18 first few aren't particularly relevant to our 19 discussion. So Sarah, can we go to the next one?

20 I have two slides reflecting back a year 21 ago to the meeting in February. At that time, and 22 I've looked through the transcript, the general scope 23 of the draft guide seem to be about right to most 24 members. But they had a lot of questions and wanted 25 to see what comes next.

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69 1 There was fairly through coverage of 2 volcanic hazards. And the approach draws heavily on 3 the IAEA SSG-21 and (inaudible) 7095. And also, the 4 staff made sure it was consistent with their previous 5 use of volcanic hazards for specific sites, both 6 reactors and production sites. Next slide.

7 We identified a few issues in the meeting.

8 The process or methodology in the reg guide seemed 9 reasonable, but the risk-informed process was 10 confusing to some of us. We raised some issues about 11 that. There were public comments in this area too.

12 It provides no guidance on equipment 13 failure rates give a particular volcanic hazard, 14 although it does note especially ashfall could be a 15 significant problem. We raised the issue of nearby 16 facilities. And I kind of thought that might be 17 cleaned up in this presentation, but it's still 18 hanging there. We'll have to talk about that some.

19 Next slide.

20 These are my thoughts after I went through 21 it, and I think this is an appropriate point to raise 22 any particular thing. I have one slide on the -- what 23 I thought was positive and several others on areas we 24 might want to talk about. I though the revised guide 25 was responsive to our discussion and to the public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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70 1 comments. I thought they did a great job on that.

2 Excuse me.

3 There were substantial improvements in the 4 flowchart for volcanic hazards assessment. And the 5 text on both potential volcanic hazards and the text 6 supporting the process steps were greatly improved.

7 And that helped me a lot. If anybody wants to talk 8 about other things positive, this would be a good 9 spot. Otherwise, I'll go on to the next slide.

10 (No audible response.)

11 CHAIRMAN BLEY: Next slide. Some things 12 for us to talk about, the process map. Walt, this was 13 answered pretty well today. So I think this first 14 one, at least for me, has gone away. And we might 15 want to encourage the staff to add -- if we write a 16 letter, encourage the staff to add some explanatory 17 discussion and they seem willing to do that. Next 18 slide.

19 This had to do about equipment failures.

20 We had a fairly long discussion today on that. They 21 attempted to deal with it this time around by 22 suggesting that the PRA standard provides the 23 wherewithal to determine equipment failure modes, but 24 it really doesn't talk about it at all. Next slide.

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71 1 1804 document. And that alerts people to the problem, 2 but it doesn't really provide a way out. So we don't 3 have anything. My feeling on this is we ought to 4 mention something about it. But I think the process 5 works without providing the data at this time.

6 But we've suggested three or four places 7 the staff could look get some guidance on -- maybe 8 that goes in a separate guidance document on the issue 9 of how these volcanic hazards can affect equipment.

10 What would be qualitatively or quantitative when we 11 know qualitatively it gets worse. Failure rates get 12 worse, but we don't know how much. And there might be 13 sources that'll help that.

14 MEMBER PETTI: Dennis?

15 CHAIRMAN BLEY: Yes, sir.

16 MEMBER PETTI: I have a question. Given 17 that the reg guide was moved from section 1 to section 18 4, it seems like the staff thinks this is a siting reg 19 guide. And many of these issues about the facility 20 and data for SSEs or whatever are more on the design 21 side than they are on the siting side. So I'm just --

22 I'm not even sure I know the answer. But it's just 23 something that I guess we have to think about at this 24 point.

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72 1 is still titled for proposed nuclear power reactor 2 sites, although it could be used for other kind of 3 sites. So I'm not sure why they restrict it to 4 nuclear power reactor sites which would be in the ones 5 instead of the fours where they started. But when you 6 get to their process where they did a quantitative 7 evaluation or semi-quantitative evaluation, they do 8 need to look at the design capabilities and fixes.

9 So it's embedded in the process. I don't 10 think we can do much more at this point other than to 11 remind everybody it's an issue. They've done that, 12 but they also kind of said it would solve. But I 13 don't think that's true at all. Somebody else was 14 trying to talk? Excuse me.

15 MEMBER DIMITRIJEVIC: Dennis, this is 16 Vesna. I mean, I was waiting for them to make some of 17 my -- we don't have too much time. But the things is 18 that we have to decide that we're going to write the 19 letter, right? That's one of the thing.

20 And if you write the letter, would that be 21 letter endorsement, length of comment? And are we 22 ready? For example, I'm not sure am I ready to 23 support the issue in this reg guide now because some 24 of those things which you brought are also very true.

25 It's very (inaudible) what are risk-informed insights?

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73 1 I mean, they state the PRA. They use the 2 PRA application guidance. But there is not too much 3 of the PRA there, if anything. There is not any 4 quantitative really other than something on initial 5 event frequency which is the long way back to the 6 shack, the PE and PA hazards.

7 So when we had the meeting in February, 8 they gave us some guidelines, what was the draft 9 timeline. And based on that, you said at the 10 beginning they're sort of early on schedule. But 11 based on this draft timeline, they told us they have 12 -- that in this time, 2021, they're applying to have 13 the feedback from prospective applicants which will be 14 using method and then the draft guide based on that.

15 And I think that will be extremely useful.

16 That was also mentioned regarding from NuScale. If 17 they're having something with an exercise or pilot, 18 even the -- not the real application but some go 19 through application, how will this work? That will be 20 very -- and that will point out what is missing very 21 clear. So I'm not sure they -- why they're having to 22 issue this reg guide action.

23 CHAIRMAN BLEY: They got the public 24 comments. They provided them to us with their 25 discussion of them.

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74 1 MEMBER DIMITRIJEVIC: Yeah, but that's not 2 the same as running application, public comments on 3 that. I mean, even in the text, they have so many 4 (inaudible) expressions. But if you're running 5 application and try to have some tabletop exercise to 6 see how that will actually work, that's different than 7 just having public comment.

8 CHAIRMAN BLEY: Well, our time is up.

9 You've raised a lot of good things, and we'll have to 10 come back to this and decide. I have my own feelings 11 about that, and we'll talk about that then. Mike, do 12 you have something quick?

13 DR. CORRADINI: Yeah, Dennis. I guess I'm 14 with Vesna. I think having the tabletop exercise to 15 work through this path 1 strikes me as a very useful 16 endeavor. And I don't see the rush necessary to get 17 the reg guide out.

18 CHAIRMAN BLEY: I think I have to go back 19 to the Chairman now. Our time is up, and we'll come 20 back to this later this week.

21 CHAIRMAN SUNSERI: Thank you, Dennis. And 22 I appreciate the brevity here. It's a difficult spot.

23 So I think we'll have some time later today after the 24 NuScale presentation perhaps. So that'll be one 25 opportunity. Then after P&P tomorrow, we'll have a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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75 1 chance to work on it as well.

2 So at this point in time, I will turn to 3 Joy Rempe, our subcommittee chair, for the research 4 review activity to begin the next topic overview of 5 NRC research programs related to biennial review.

6 Joy?

7 VICE CHAIRMAN REMPE: Great. I think I'm 8 going to turn it over to Ray Furstenau. I have not 9 been -- I was listening to the discussion. Ray, are 10 you there?

11 MR. FURSTENAU: Yes, yes. I'm here.

12 VICE CHAIRMAN REMPE: Great. Go ahead and 13 get your slides up and proceed.

14 MR. FURSTENAU: All right. Nick, can you 15 -- can you help with the slides, Nick?

16 MR. DIFRANCESCO: I need access.

17 MR. WIDMAYER: You should be good now, 18 Nick.

19 MR. FURSTENAU: All right. I'll get 20 started then. And thank you, Chairman and the 21 Committee, for the opportunity to come talk to you 22 about our research programs. And geez, I was just 23 thinking, it doesn't seem like two years already since 24 the last biennial review. But I always look forward 25 to getting your feedback and input to this. Can we go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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76 1 to the next slide, please?

2 So the agenda for the two hours we had for 3 today is I'll give a brief overview of some program 4 updates, some office focus areas, touch on your past 5 recommendation. And then I'll have the divisions each 6 give an overview of what they've been doing and are 7 doing in their divisions and then hopefully leave a 8 little bit of time for discussion. And if that's okay 9 with the Committee, I'll go to the next slide.

10 I just want to touch briefly on the 11 organization. We've had some changes since the last 12 review I think in the Division of Engineering.

13 Believe it or not, I'm one of the old timers now in 14 the leadership group.

15 I came to the NRC in 2018 and I really 16 like being in the Office of Research. I think Louise 17 Lund, Division of Engineering, she came on board with 18 research in August of 2019. A longtime NRC employee, 19 Jeremy Bowen, he came on board in, I think, February 20 of last year.

21 And in the Division of Systems of 22 Analysis, many of you know Kim Webber. She was the --

23 formerly the Deputy Director of this division. And 24 then Mike Case retired and we selected her as the 25 Division Director.

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77 1 And then she has since brought on board 2 Terry Lalaine as the Deputy Director. And Terry was 3 in the NRC's SESCDP program, but she's not from the 4 NRC. She's -- her last assignment was with Edgewood 5 Chemical Biological Center, a part of the Army Test 6 and Evaluation Command. And she'll hopefully offer a 7 different perspective on research and having different 8 ways of thinking is always good. So we're really 9 happy to have Terry Lalaine on board.

10 And in the Division of Risk Analysis, Mark 11 Thaggard was promoted to the Director position. And 12 Christian Araguas, he's the new Deputy Director. He 13 came from the same SESCDP class as Terry and Jeremy.

14 And so -- and Christian has been in research before, 15 so we're glad to have Christian on board. So those 16 are new changes in the leadership at research. Next 17 slide, please.

18 In this program at a glance slide, I won't 19 spend too much time on it. But it shows you where our 20 main -- main business line, of course, is operating 21 reactors with smaller portions in advanced reactors, 22 new reactors, and then the NMSS business lines of 23 material users in spent fuel and low level waste. And 24 overall, 197 FTEs and 40 million, that's a little bit 25 lower than the FY20 budget. I think we had about 205 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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78 1 or so FTEs authorized and about 43 million in 2 contracts.

3 And as we look ahead, we don't have the 4 final '22 numbers yet and we're working on the '23 5 budget. I think the outlook for research is pretty 6 stable, maybe growing slightly but pretty stable. And 7 I'm pretty happy about that. Next slide, please.

8 CHAIRMAN SUNSERI: Hey, Ray, this is Matt.

9 I have a question.

10 MR. FURSTENAU: Yes, Matt.

11 CHAIRMAN SUNSERI: If you want to address 12 this later on or if it'll be addressed later on, 13 that'd be fine. You don't have to do it right now.

14 But it just seems to me like this strikes me as the 15 largest percentage of, quote, research is being 16 directed at operating reactors.

17 And I guess maybe I think of research a 18 little differently. It seems to me like we might've 19 wrung out all the research topics that are needed to 20 keep the existing fleet going and that there would be 21 more effort being put to advanced designs, the 22 materials, those that are using the new reactors, and 23 what to do with the spent fuel. So any comment along 24 those lines?

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79 1 think that's a good observation, Matt. And I guess 2 I'd answer that a little bit by we have this business 3 line structure. And I think some of the background 4 information we provided you may help with that too.

5 We've provided you, for example, the FY23 6 list of research activities that we're asking for 7 funding for. And again, most of those are in the 8 operating reactor business line like you said. But 9 some of that -- some of the work that's being done, 10 although it's under the operating reactor business 11 line, will have applicability to advanced reactors and 12 new reactors as well.

13 I'd like to see more personally. But the 14 -- we have some limitation on the advanced reactor 15 funding because it's not part of the fee base. And 16 I'd like to -- personally like to see that grow a 17 little bit more. But I think there is work being done 18 under the operating reactors that does apply to 19 research in advanced new reactors as well. But I 20 think that -- and that background information is kind 21 of an eye chart we provided you. I know that's a lot 22 of individual.

23 But that's where I think some of the 24 recommendations you've given in the past on when is 25 enough, enough on research and how do we know when to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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80 1 start and stop activities. Feedback from you guys 2 would be very, very helpful for us. But I think we 3 work closely with the business lines through our 4 program reviews to make sure that we're doing work 5 that is of value to the NRC, is applicable and is 6 useful to the licensing offices. And that's where we 7 get the most of our funding is from operating 8 reactors.

9 (Simultaneous speaking.)

10 CHAIRMAN SUNSERI: That's good, Ray.

11 Thanks for that perspective. And I agree that I think 12 that some of the operating stuff will be applicable to 13 the advanced ones.

14 I have the privilege of being the working 15 group lead for the engineering area. So we'll be 16 looking closely at that as we go forward with our 17 review. Thank you.

18 (Simultaneous speaking.)

19 VICE CHAIRMAN REMPE: Well, Ray, since 20 we've interrupted you -- and I think you're done, 21 right, Matt? I didn't interrupt you?

22 MR. FURSTENAU: No, go ahead, Joy.

23 VICE CHAIRMAN REMPE: So I guess when you 24 brought up about you were looking for comments about 25 when to sunset a project, I was going to ask you on a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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81 1 later slide. I guess I also wanted to just give you 2 a heads up that because this is your kickoff meeting 3 for the upcoming biennial review and we'll be talking 4 with each division head later, I plan to spend a lot 5 more time on your slides to get a higher level 6 perspective.

7 MR. FURSTENAU: Okay.

8 VICE CHAIRMAN REMPE: And one of the 9 things I wanted to mention was we have provided 10 recommendations in the past about projects that should 11 be sunset. And I know COVID affected things, but I 12 don't see any of those sunset. Commissioners, one of 13 them in particular regularly asked us about projects 14 that should be stopped.

15 Can you give us any good examples of ones 16 that were sunset that we -- when I look at the project 17 list you provided us, I see they're still saying we're 18 going to try finishing up next year. It's not 19 happened this year. And can you give us some good 20 examples where this process is working?

21 MR. FURSTENAU: If it would be okay with 22 the Committee, maybe I can have a -- in one of the 23 division discussions, I'd like to prepare for that 24 better, Joy, and give some good examples over the past 25 -- not just the past year, but maybe the past couple NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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82 1 of years. We're still -- I think we need to do a 2 better job of really looking when enough is enough, 3 especially on some of the long-term activities that 4 have been going on for decades. But it's okay with 5 you, I'd like to prepare myself a little bit better 6 and maybe just have a separate discussion on that 7 because I'm afraid we'll -- I'll get bogged down with 8 it on this presentation. Is that okay?

9 VICE CHAIRMAN REMPE: Of course. And so 10 we'll look forward to that in each of the division 11 discussions that they will have a slide talking about 12 that.

13 MR. FURSTENAU: Yeah, yeah.

14 VICE CHAIRMAN REMPE: Is that the path 15 forward?

16 MR. FURSTENAU: That's the path --

17 VICE CHAIRMAN REMPE: Yeah, that sounds 18 fine.

19 MR. FURSTENAU: That's the path forward, 20 and then I'll talk with our folks. I may lead off one 21 of the first ones to just kind of go overall in 22 general and then leave it to the divisions. We may do 23 it that way in the subsequent discussions, if that's 24 okay.

25 VICE CHAIRMAN REMPE: Thank you.

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83 1 MR. FURSTENAU: All right. Thanks.

2 CHAIRMAN SUNSERI: So I think Dennis had 3 a question and then Ron after him.

4 CHAIRMAN BLEY: Okay, thanks. Yeah, I 5 like the point Matt brought up, and I understand your 6 constraints. And maybe here's an area where we in 7 writing to the Commission can suggest some things that 8 might help. In the past, people were very creative in 9 the -- when there were issues brought up, say, from 10 NRR and being able to include issues that'll be 11 important for future reactors as well.

12 And as you said, you try to incorporate 13 those things. But some of these are really important 14 and maybe should be raised to a level to suggest 15 getting additional funding to support some of this 16 forward looking work instead of trying to shoehorn it 17 in places where it sort of belongs but maybe not 18 quite. So something we can think about.

19 MR. FURSTENAU: Yeah, thank you.

20 (Simultaneous speaking.)

21 VICE CHAIRMAN REMPE: And Ron, I saw your 22 hand too. I wasn't looking at the hands, but I will 23 continue to monitor it. Go ahead.

24 MEMBER BALLINGER: Human nature being what 25 it is, have you thought about a radical approach of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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84 1 trying an automatic sunset on projects so that it 2 offloads some of the responsibility for making a 3 decision that might be, I don't know, whatever? And 4 that requires then that the sponsor to that provide a 5 new justification for a new project. It's a way that 6 might be consider, although kind of radical, I guess.

7 MR. FURSTENAU: No, I think that's a good 8 thought, Ron. You're reminding me of one thing that 9 we have been doing on continuing research. We try to 10 look at how old are these requests.

11 I think all of you are aware most of our 12 activities in research are done through the generation 13 of a user need that we work with the business line 14 office to come up with. But some of those are quite 15 old. They're many years old.

16 And I think it goes a little bit along 17 with what you were suggesting. But what we have been 18 doing is taking some of those older user needs and 19 kind of declare victory and say, hey, these are good.

20 We got what we wanted out of these. And if there's 21 something that seems like a next step, let's create a 22 new user need if it's really needed to kind of clean 23 up some of that old activity.

24 MEMBER BALLINGER: Yeah, that's a good 25 idea because in a lot of -- in all cases when I've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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85 1 reviewed stuff, what I've done is asked for the user 2 need. And very often, it comes out that there's no 3 relationship between the project itself and the 4 original user need. It's just developed a life of its 5 own.

6 MR. FURSTENAU: Yeah, yeah. That happens 7 because I think sometimes what occurs is the work is 8 good work as far as peer research goes. But at what 9 point is it goes beyond what we need from a regulatory 10 standpoint and when to say, we've had enough. If 11 somebody else wants to pick it up like a national lab 12 or an Office of Science or somebody -- or Office of 13 Nuclear Energy for research's sake, have at it. But 14 we need to determine on the regulatory side when we've 15 done enough research on a particular topic.

16 MEMBER BALLINGER: Thank you.

17 MR. FURSTENAU: I think Mike Corradini has 18 his hand up too.

19 DR. CORRADINI: No, I didn't. If I did, 20 it was my mistake. I apologize, Ray.

21 MR. FURSTENAU: Okay. Can we go to the 22 next slide, please? This is just a -- I put it in my 23 background because the thing now is with these 24 backgrounds for meetings like this, we have kind of a 25 boring NRC template. But we thought we'd make one for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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86 1 research that has kind of research by the numbers on 2 it. So we just wanted to show you that. Next slide, 3 please.

4 VICE CHAIRMAN REMPE: Ray, hold on. I had 5 a question on this --

6 MR. FURSTENAU: Okay.

7 VICE CHAIRMAN REMPE: -- slide too. Okay.

8 In the past with the Fukushima events, research could 9 show how their products helped the Agency address an 10 issue. Can you give me a good example case where the 11 research in the last year or two has helped the Agency 12 addressed a regulatory issue or something that you 13 plan to provide important input to in the next year or 14 so?

15 MR. FURSTENAU: Well, I think -- and I 16 will ask for a lifeline if I mess up the details. But 17 kind of like the boron redistribution activities in 18 dealing with NuScale, I think we contributed quite a 19 bit of support for that resolution. Some of those 20 questions came out of the ACRS Committee, if I recall 21 right.

22 VICE CHAIRMAN REMPE: That's a very good 23 example, something where your tools actually provided 24 input that the licensee couldn't. So thank you.

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87 1 slide, please. I wanted to give some just very brief 2 updates on these activities. The Nuclear Energy 3 Innovation Capabilities Act, I know that many of you 4 hearing presentations from others in the NRC about 5 NEIMA and what milestones and restrictions NEIMA puts 6 on the NRC.

7 But the NEICA is kind of the lessor known 8 of the NE acts. And I really look at the NEICA as a 9 great opportunity for the NRC. And what I wanted to 10 -- and it's mostly dealing with our interfaces with 11 the Department of Energy. And we're doing work with 12 DOE through the National Reactor Innovation Center.

13 We have monthly discussions with Ashley Finan out in 14 Idaho and Alice Caponiti and NE as far as how we can 15 contribute to each other's success in the testing and 16 the concepts that are being tested at NRIC.

17 We're also participating in some of the 18 safety reviews of the VTR. We're learning from that, 19 that we're not licensing that reactor. So it's a 20 great opportunity to learn from what DOE is doing in 21 that space as well.

22 The Advanced Reactor Demonstration 23 project, for example, that also falls under the 24 umbrella of NEICA. And we have a separate addendum, 25 we call it, to the MOU with DOE on that. We're also, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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88 1 of course, doing work on source term and MELCOR work 2 on some of the new codes that are -- trying to 3 interface with the new codes that are being developed 4 with DOE as well as other modeling and simulation 5 tools.

6 The next item, university program research 7 and development grants, I might've spoke briefly about 8 this last fall to all of you. But in the past, for 9 the past over ten years from -- I think 2010 to 2019, 10 pretty much that grant program was university 11 fellowships, scholarships, and faculty development 12 grants. And that was pretty much it, nothing wrong 13 with that, nothing wrong with those types of grants.

14 But in FY20 when the previous 15 authorization ran out and in FY20, we really went by 16 the appropriation language. We decide to take 17 advantage, if you will, of the language that the 18 Congress gave us that really pointed towards using 19 some of the funding for mission-related R&D grants.

20 Really, universities are just the greatest thing there 21 is, I think, for looking ahead and knowing what might 22 be going on five, ten years in the future and doing 23 research on that.

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89 1 development grants in fiscal year 20. But we also 2 awarded as part of the funding and we had a little 3 bit, the carryover funding, 7.2 million in 15 grants 4 to universities on activities that would be related to 5 future efforts, future mission-related R&D at the NRC.

6 So we're really excited about that.

7 They're three-year grants, so they're 8 multi-year grants. We fund them all up front, up to 9 500,000 dollars a year. And we're going to do that as 10 well in fiscal year 21.

11 And I hope at some point, we can kind of 12 have a link to what we're doing at the NRC in our 13 future focus research projects which we briefed you on 14 last fall. Grants are a little -- we have to be 15 careful with grants. Once the grants are awarded, we 16 can't direct the work.

17 But I think we can learn a lot from the 18 universities. And it'll help us think about what we 19 may want to do with our internal funding in the future 20 as well. So I'm excited about IUP as well as the 21 future focused research that I've talked to you about 22 before. And then a code investment plan --

23 DR. CORRADINI: Ray?

24 MR. FURSTENAU: Yes?

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90 1 ask a process question about the IUPs or the grant 2 program?

3 MR. FURSTENAU: Sure.

4 DR. CORRADINI: In deference to the DOE 5 NEUPs which have certain eligibility requirements, the 6 eligibility requirements for NRC are much more 7 restrictive in terms of not allowing a PI to be an H-8 1B cardholder while they're waiting for their green 9 card or their citizenship. Why is that? I don't 10 understand why NRC's requirements are more restrictive 11 than DOE's for the faculty or senior scientists that 12 are trying to participate or competitively win these 13 awards.

14 MR. FURSTENAU: Yeah. I can't answer that 15 question precisely, Mike. I know when we develop 16 these funding opportunity announcements, a big part of 17 the review is going through our internal reviews, 18 general counsel, and make sure that we are complying 19 with the statutes on this stuff. So it may not match 20 up with DOE's.

21 We try to make it clear, if we can, 22 whether all the applicants like it or not, but try to 23 make it clear what our rules are. But I have gotten 24 similar feedback, Mike. And I wish I could give you 25 a better answer right now.

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91 1 DR. CORRADINI: So what I'm hearing is you 2 would prefer them to be consistent, but it's kind of 3 out of your hands? And it's in contracts or some 4 other part of NRC in terms of deciding the eligibility 5 requirements?

6 MR. FURSTENAU: Yeah, as far as the 7 citizenship requirements. I don't want to blame it, 8 if you will, on another part of the NRC. We all get 9 into this, review it, and see what we can all accept 10 in order for us to be able to issue the funding 11 opportunity announcements.

12 DR. CORRADINI: But I wanted to ask it 13 because the inconsistency struck me as unusual.

14 MR. FURSTENAU: Yeah.

15 VICE CHAIRMAN REMPE: Ron, do you have a 16 question?

17 (No audible response.)

18 VICE CHAIRMAN REMPE: I guess not. Go 19 ahead, Ray. I think I interrupted you. Did you --

20 MR. FURSTENAU: No, that's okay. I --

21 (Simultaneous speaking.)

22 MEMBER BALLINGER: I forgot to lower my 23 hand. Sorry.

24 MR. FURSTENAU: Okay.

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92 1 have a question. You said, well, it's great. You 2 give them funding for three years in advance. You're 3 not allowed to direct the research. What about 4 monitor it? What if they just go do something else?

5 And is there any sort of monitoring and reviewing and 6 making sure they're doing what the original scope is?

7 MR. FURSTENAU: Yeah, yeah. We do have an 8 obligation for that. I think one thing that we're --

9 it's taking some -- I guess some learning on our end.

10 I think most the time, our folks that prepare the FOAs 11 and all of us are used to fellowship, scholarships, 12 faculty development grants have been pretty much hands 13 off. And so we kind of have to break that mold as far 14 as the hands off for this.

15 We don't want to direct the work once we 16 award the grant. We don't want to do that. But what 17 I'd like to see happen is -- and I think universities 18 would be more than happy to do this is to provide us, 19 like, a virtual seminar periodically, maybe once a 20 year or where they're far enough along in the grant to 21 tell us what they are doing.

22 And that helps get us excited and start 23 thinking about, hey, this might be the next big thing 24 we ought to be worrying about from a regulatory 25 standpoint. So we haven't completely settled that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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93 1 yet, Joy, about how much we can interface with the 2 grant recipients. I'd like to see more of it without 3 directing the work.

4 VICE CHAIRMAN REMPE: A while back, you'd 5 said you wanted to give us periodic reviews on 6 specific topics, and this was one of those topics. I 7 know we're going to be having three upcoming meetings.

8 Is it possible to still have that as part of the 9 discussion at one of these meetings or a separate 10 meeting?

11 MR. FURSTENAU: Yeah, I think maybe a 12 separate meeting might be better.

13 VICE CHAIRMAN REMPE: Okay.

14 MR. FURSTENAU: An update on these IUP 15 grants, these mission-related IUP grants, they're just 16 starting, many of them. And so -- and we have to get 17 settled internally how much we're allowed to interface 18 with those. We're not in agreement -- we are not in 19 agreement internally, Joy. I'll tell you that as far 20 as what we can and can't do. So we have to work that 21 out internally within the Agency.

22 But for example, we had at the RIC -- I 23 hope many of you were able to attend the RIC. We had 24 an IUP future focused research session that I chaired, 25 and we had Dr. Camille Palmer from Oregon State and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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94 1 was gracious enough to participate in our panel and 2 talked about the dynamic risk assessment for nuclear 3 cybersecurity IUP project that she was working on.

4 And I want to do more of that, get the PIs and the 5 students being able to maybe publicize what they're 6 doing more to the NRC staff. I think it'll help all 7 of us.

8 VICE CHAIRMAN REMPE: It could also help 9 with hiring and replacement of staff as --

10 MR. FURSTENAU: Of course.

11 VICE CHAIRMAN REMPE: -- they retire. So 12 I think these interactions are great. It looks like, 13 Stephanie, you have your hand up. Are you trying to 14 say something?

15 MS. COFFIN: Well, I was just going to --

16 if you don't mind, I was going to just add that as 17 part of the grant awards, they are required to submit 18 status reports. And so that's -- and we do have folks 19 who are overseeing and reviewing those status reports.

20 So we do make sure that they're progressing down the 21 path, consistent with why we gave them the award in 22 the first place. Thanks.

23 VICE CHAIRMAN REMPE: Thank you. Go 24 ahead, Ray.

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95 1 mention the code investment plan. We had a -- I think 2 you may be familiar with this. We've probably 3 mentioned it before, and I think Kim Webber is going 4 to mention it in more detail.

5 But back in the SRM we had from the 6 Commission for the '21 budget, the Commission had 7 asked us to work with other offices to review in a 8 holistic way the existing inventory of codes that we 9 use to develop a long-term investment plan to support 10 future use and resource requirements. And that's 11 coming along quite well. And that may be one of those 12 topic areas that we could give you an information 13 briefing on. We're probably in the next few months be 14 at a really good point to maybe provide you an 15 information briefing on that, if you're interested.

16 VICE CHAIRMAN REMPE: I think that'd be 17 great. Just work with Hossein and let's get it on the 18 schedule.

19 MR. FURSTENAU: Okay. All right. Okay.

20 And then external collaboration, we talked about our 21 DOE -- interfaces with DOE and of course EPRI. And 22 our international collaborations is mostly through the 23 NEA. I wanted to point out -- and I'll talk a little 24 bit more about this in the next slide.

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96 1 Halden project that the FIDES. The framework for 2 radiation experiments that the NEA is putting together 3 is just about ready to kick off. And we're involved 4 in several of those joint projects. So next slide, 5 please. So our research priority areas, and Chairman 6 Hanson has mentioned his three As, his priorities 7 being advanced reactors, accident tolerant fuels, and 8 academia. And I look at that from research as 9 strengthening our university ties and innovation that 10 we can learn from the universities on.

11 So those three things are certainly on our 12 list. Fleet modernization and use of new technology 13 is on our list too. And I think some of these things 14 that are listed here, digital twins advanced 15 manufacturing and cybersecurity, those things are also 16 being addressed through the admission-related R&D that 17 the universities are doing research on as well as our 18 future focused research activities as well.

19 And then I mentioned before building on 20 our success with FIDES. I really want to push for a 21 leadership role from research and in the governing 22 board for those activities. And we're looking forward 23 to not only some fueled experiments that are planned 24 under those JEEPs but also some JEEPs that are --

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97 1 some material irradiation JEEPs as well.

2 VICE CHAIRMAN REMPE: So Ray, this is 3 another one of these slides where I wanted to ask a 4 lot of questions about.

5 MR. FURSTENAU: Oh, sure.

6 VICE CHAIRMAN REMPE: And one of them is 7 related to what Matt had mentioned about -- and Dennis 8 inferred about the general agreement among the 9 different offices, that these are the priorities 10 because the risk -- enterprise risk or the 11 prioritization aspect and the list of projects that we 12 were provided, it really requires that the whole 13 Agency buys in to these are the priorities. And I'm 14 just wondering are you seeing much of that? Or is it 15 because they realize in their offices they've got 16 certain tasks got to be done for the existing fleet.

17 So that's why they -- I mean, they've got 18 to get the work done. They're licensees. They 19 provide funding. The NRC is caught in a cost 20 reimbursable basis. So I get why things aren't 21 changing very quickly. But what does it mean when you 22 say these are the priority areas? How does that work?

23 MR. FURSTENAU: Yeah, I think -- thanks 24 for that question, Joy. I was going to talk a little 25 bit to that on the next slide, but let's just do it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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98 1 here. That activity list that we provided you as 2 background, that's, of course, being done as a budget 3 document.

4 But when we prepare those, that list, that 5 is within -- with full engagement of the business 6 lines. And we started these program reviews a couple 7 of years ago where we're trying -- what we're trying 8 to do is get it all out on the table. Hey, business 9 line leadership, like, NRR. Hey, this is what we're 10 doing for you. These are the successes. This is what 11 we see planning for the FY23 budget.

12 So we do these program reviews as part of 13 preparation for the budget. And then we have kind of 14 a rough algorithm to prioritize these items. But we 15 iterate on that with the business lines to make sure 16 that the priorities are aligned with the business line 17 and the Agency. And so a combination of the program 18 reviews and iterations on research activities 19 priorities are a couple of the main ways we do that.

20 VICE CHAIRMAN REMPE: So they participate.

21 But even their hands are tied because they've got to 22 address the near term issues. But I guess what you're 23 -- earlier you told us is, well, they try and do 24 research that also will help these activities that 25 they're not directly -- if there's not funding for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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99 1 them. Is that the best way that you can kind of 2 answer the question that Matt and Dennis raised?

3 MR. FURSTENAU: I think we -- in 4 prioritizing the research, we also, of course, have 5 made what we call major unfunded lists as well. And 6 what we're doing for the FY-3 budget cycle as well --

7 and this is not ready for prime time. But in high 8 level planning guidance, the Commission has asked us 9 to prepare plus 10 and plus 20 percent increment list 10 above the baseline budget for research activities in 11 the Agency.

12 So now we're working that along with the 13 business lines to kind of look ahead farther. So I 14 see that as another major opportunity to get it all 15 out on the table on what research activity needs are 16 without being restricted by a baseline budget with no 17 hope of being above that line. I'm very encouraged by 18 that is what I'm trying to say, Joy. And we're really 19 working on that list right now.

20 VICE CHAIRMAN REMPE: That's good. Okay.

21 So on a different topic, on the advanced reactors, the 22 reference plant evaluations is a place where I might 23 see that ongoing research could really help with 24 ongoing Agency initiatives with rulemaking for Part 25 53, for example. How are those reference plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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100 1 evaluations coming along, and are they ready for some 2 sort of report to us? Or what's your feeling about 3 that?

4 MR. FURSTENAU: Yeah, the reference plant, 5 I think that's a -- for advanced reactors are a good 6 activity that's being done. And I forget that and 7 maybe --

8 MS. WEBBER: I'll talk about it, Ray, in 9 mine.

10 MR. FURSTENAU: You'll talk about it?

11 Good. I forgot whether we've done three or four of 12 those to date. And then we're going to have -- I 13 think we were planning for a public meeting on those 14 sometime this year. Is that correct, Kim?

15 MS. WEBBER: Well, so the public meeting 16 that you may be referencing is for our advanced 17 reactor source term workshop which will be later this 18 year. But when I get to my presentation, Joy, that'll 19 be something I talk about.

20 MR. FURSTENAU: Okay.

21 VICE CHAIRMAN REMPE: And then on the new 22 technologies, one of these is a future focused 23 research initiative, the digital twins.

24 MR. FURSTENAU: Right.

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101 1 it's kind of progressed from being a future focused 2 research initiative to becoming something that's part 3 of the user need process? Or has it had a higher 4 success story? Or are all of these still just future 5 focused research projects are still in that category, 6 they've not moved on to something that is more of a 7 success?

8 MR. FURSTENAU: Well, I think, like, 9 digital twins, let's take that as an example. Digital 10 twins is a future focused research. I think we've had 11 a very successful first workshop on that activity, and 12 then we also presented what we have done and what we 13 plan to do at the RIC.

14 And I really think that this is one that 15 will turn into a user need. I think it's inevitable, 16 Joy, and digital twins. And I think there's a lot of 17 -- with digital twins, for example, we have another 18 activity on future focused research on dynamic PRAs.

19 And I think that'll start to meld into 20 digital twins as well. So I think there's -- I know 21 a lot of excitement with the staff. And I think as we 22 progress through our future focused research 23 activities, they ultimately -- if they're successful, 24 I would think would turn into user needs. Some won't, 25 but I expect many of them will.

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102 1 MR. BOWEN: And I'll be talking a little 2 bit more in detail about digital twins in my 3 presentation too.

4 VICE CHAIRMAN REMPE: Thanks.

5 MR. FURSTENAU: Okay. Thanks, Jeremy.

6 CHAIRMAN SUNSERI: So this is Matt. I 7 just want to remind us that we have a hard stop at 8 1:30. We're about a quarter the way through on time 9 and a quarter the way through the slides. So we're 10 right on track, but let's not bog down. All right.

11 MR. FURSTENAU: Okay, okay. Thank you.

12 So anything else on this slide? Thanks for your 13 comments and questions. Next slide. All right.

14 On your biennial recommendations, I think 15 we've been -- we've really been taking them to task 16 because I think they're obviously good 17 recommendations. We agree with them, and I think we 18 are doing actions that I've talked about many of those 19 already. And it's -- I think the -- like, you asked 20 me about the -- how do we make sure these are at the 21 right Agency level and that we're getting engagement 22 from the right levels of management.

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103 1 then -- but we still have to encourage folks that it's 2 okay to say, hey, we've done enough and we want to 3 stop this research and start something new.

4 And I think part of what as leaders in 5 research what I've got to give people assurances there 6 is life after that particular research activity that 7 we need our researcher's expertise to think beyond the 8 project that maybe they've been working on for the 9 last many, many years and use their expertise in 10 developing new ideas and new research starts because 11 I think like I mentioned early, our funding is pretty 12 stable. I think the Agency is recognizing the role of 13 research in helping the Agency be ready for life 14 extensions in the existing fleet and the license 15 renewals in the existing fleet as well as the -- being 16 ready for the advanced reactors. So next slide.

17 VICE CHAIRMAN REMPE: Oh, Ray. I'm sorry.

18 I have a question on that slide too.

19 MR. FURSTENAU: Okay.

20 VICE CHAIRMAN REMPE: This year, I think 21 I've brought this up before. We've been having these 22 information briefings on selected topics --

23 MR. FURSTENAU: Yes.

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104 1 process is working because it is just information 2 member comments. It's not a consensus type of input.

3 Second question is that over the years ACRS has 4 provided more detailed reviews on things such as 5 ideas, Level 3 PRA, and consequential steam generator 6 tube rupture efforts. Are there any projects that you 7 see where a more thorough engagement from ACRS is 8 needed?

9 MR. FURSTENAU: Well, I think maybe I'll 10 reserve that towards the end of maybe the division 11 reviews because I think as we get feedback, just like 12 through questions like this, I get a lot out of the 13 feedback you guys provide, even if it's not formal.

14 You get me to start to question. Okay, are we going 15 about our plans the right way? So it's valuable. But 16 as far as specific activities, maybe when we get 17 through our reviews, not just today but later, that 18 will provide me maybe a lot more information to give 19 you feedback on areas that I think you could provide 20 more detailed reviews on.

21 VICE CHAIRMAN REMPE: Okay. Keep it in 22 mind. Thank you.

23 MR. FURSTENAU: Okay. All right. Any 24 other questions, because I'm going to turn it over now 25 to the divisions. Jeremy Bowen is going to talk on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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105 1 engineering. And Division of Risk Analysis will be 2 Mark Thaggard, and systems analysis, Kim Webber. I'll 3 be on the line the whole time as well, and I'll kind 4 of close things up. And any last questions for me 5 before I turn it over to Jeremy?

6 VICE CHAIRMAN REMPE: I don't have any 7 questions for you, but I guess I should point out that 8 as Matt mentioned, he'll be the lead on the group that 9 looks at the Division of Engineering. Vesna will be 10 the lead on the risk analysis area, and then Dave 11 Petti is taking over the systems analysis area. Okay?

12 MR. FURSTENAU: Okay. Sounds good. Thank 13 you. And with that, go ahead, Jeremy. And thanks to 14 the Committee and Chairman for having us come here 15 today. I appreciate it. All right.

16 MR. BOWEN: So good morning, everybody.

17 I'm Jeremy Bowen. Like Ray said, I'm the Deputy 18 Director in the Division of Engineering. So happy to 19 be here to provide kind of an overview of our 20 activities that we're engaged in and highlight some of 21 the work that our team has accomplished recently. So 22 obviously, please stop me at any point with questions.

23 So the Division of Engineering, DE, we 24 provide technical expertise and research support for 25 a spectrum of engineering issues related to operating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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106 1 reactors, new reactor design and siting, and spent 2 fuel management. So more specifically, we maintain 3 core Agency expertise in materials and component 4 integrity analyses, corrosion, metallurgy, non-5 destructive examination, electrical engineering, 6 instrumentation control, seismology, geotechnical, 7 structural engineering. That's a lot. It's many that 8 I'll call the, quote-unquote, traditional engineering 9 fields.

10 But in addition, we also provide support 11 and management for Agency-wide programs related to 12 regulatory guides, generic issues, consensus codes, 13 and standards. So this slide here shows how these 14 activities are kind of divided up across the division.

15 Ray mentioned that Louise and myself have joined since 16 the biennial review.

17 We've also had a couple of changes at our 18 first-level supervisor level since then. So Chris 19 Cook has taken over as the branch chief for the 20 electrical engineering and I&C branch. And Meraj 21 Rahimi has joined us and taken over as the branch 22 chief for the reg guides and generic issues at project 23 management branch.

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107 1 is really only having the expertise, the foresight, 2 the agility to respond and support resolution of the 3 various engineering challenges that are faced by our 4 partner organizations. So for reference, you see here 5 on the slide across all the business lines, the 6 overall budget for the combined engineering projects 7 is roughly 12 million dollars and about 68 FTE. It's 8 been relatively stable for the past few years, and we 9 really kind of expect that to continue in the near 10 term.

11 And there'd obviously be some areas that 12 are increasing and others that are decreasing. So 13 with that, I'll kind of get into some of the 14 specifics. Nick, if you want to move on to the next 15 slide. All right.

16 So just to kind of set the stage, you'll 17 see the format of this slide mirrored throughout the 18 remainder of the presentation, including the other 19 divisions. So for each product area, my colleagues 20 and I will touch on the regulatory objective, 21 highlight some of the key milestones accomplished or 22 planned for this fiscal year, and then touch briefly 23 on our future plans. And so I'll start with the 24 materials area.

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108 1 maintain and enhance our modeling capabilities, assess 2 degradation, and evaluate new uses of materials.

3 Going into the milestones for this year, several of 4 these should be familiar to the Committee. The first 5 one listed is a new addendum to our memorandum of 6 understanding with the Department of Energy on the 7 Nuclear Energy Innovation Capabilities Act.

8 This one is specific to the light-water 9 reactor sustainability project. DOE and the national 10 labs have numerous activities underway to look at plan 11 sustainability, long-term operations. So this new 12 addendum really facilitates our engagement with DOE 13 and the labs and to help us stay involved and aware of 14 all the various work that's going on in this area.

15 Ray actually signed the updated MOU within 16 the last couple of weeks, and we're just waiting on 17 DOE to kind of countersign. But we've been engaged 18 throughout all those activities. In fact, there was 19 a -- the -- one of the -- sorry, the program review --

20 the spring program review was yesterday.

21 So the next item in the area of advanced 22 manufacturing, we've actually been issuing several 23 reports on the various technologies, including laser 24 powder bed fusion, cold spray, direct energy 25 deposition or 3D printing, electron beam loading, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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109 1 powder metallurgy, hot isostatic pressing. These 2 obviously support licensing reviews. So I think Joy 3 Rempe was asking a question earlier about an example 4 of how research has provided some value. So these 5 reports that we're issuing are directly going into 6 licensing review support.

7 So we've also issued a TLR on modeling and 8 simulation advanced material -- advanced manufacturing 9 and then one on microstructure properties. And we're 10 currently finalizing one on inspection and then the 11 gap analysis. Not on the slide, but I also want to 12 mention that we had a good workshop on AMT back in 13 December.

14 And we have a series of -- we're calling 15 them staff training seminars or knowledge management 16 activities that are going on throughout the year.

17 Those are being put on by NIST for us. We had the 18 first one back in October, and we actually have 19 another one coming up later this month.

20 So moving on to the next item, Ray 21 mentioned FIDES. And we briefed you a couple months 22 ago about how this activity is replacing some of the 23 capabilities provided by Halden. So our DOE partners 24 have really supported us in developing two material 25 JEEPs, and we'll be working with our international NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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110 1 colleagues to kind of gain support for those JEEPs and 2 get them approved and funded. Again, Ray signed the 3 agreement recently, and plans are being made for the 4 first meeting with FIDES.

5 Onto digital twins, so there was some 6 interest in this. You obviously heard about it, the 7 future focused research program briefing that we gave 8 a little while ago. And the regulatory viability of 9 digital twins, you're correct. That's one of the 10 first future focused research projects that was funded 11 for fiscal year 20.

12 Like Ray said, we've made a lot of great 13 progress and mentioned the workshop back in December.

14 There was actually over 300 attendees at that 15 (inaudible) vendors, licensees, academia. It was a 16 really good workshop. I think we were actually ahead 17 of a lot of our colleagues and Department of Energy 18 and others kind of starting the conversation on 19 digital twins.

20 So we've actually had our staff publish an 21 extensive Nucleapedia site page on digital twins that 22 actually went live earlier this week. So again, 23 making some good progress there. And on the several 24 tasks that are associated with the project, we 25 actually received the first draft document from our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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111 1 contractor a couple months ago, and that's outlined in 2 the current state of technology and application of 3 digital twins.

4 So we're finishing a review of that and 5 expect to issue the associated technical letter report 6 in the coming weeks. And then finally on the advanced 7 reactor front, I think this is an area where everybody 8 recognizes we're heavily engaged with our domestic and 9 international partners to understand all the aspects 10 and implication of materials for advanced reactors.

11 Probably no surprise, one of the most prominent 12 activities this year had been our review and 13 endorsement of ASME Code Section 3, Division 5.

14 Again, I think everybody knows this is the 15 consensus standard for construction of components of 16 high temperature reactors. And we actually have -- I 17 think it's a July Committee briefing on this specific 18 activity. So I'll move a little into the -- so was 19 there a question?

20 VICE CHAIRMAN REMPE: Yes, I just wanted 21 to follow up on your comment about the advanced 22 manufacturing. You said that your letter reports are 23 being considered in licensing reviews. So people have 24 started to submit components that are 3D printed for 25 the reactors?

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112 1 MR. BOWEN: So nobody submitted a 2 licensing action associated with an advanced 3 manufactured component. The components that have been 4 installed or are preparing to be installed right now 5 in plants have been through a 50.59 process. But I'm 6 sorry if I misspoke. But what I meant was that the 7 information on our technical letter reports is being 8 turned into review guidance for the staff to support 9 anticipated future applications.

10 VICE CHAIRMAN REMPE: So it's for future 11 applications. The 50.59 process does not require any 12 specific guidance from the research that's been done.

13 Is that --

14 MR. BOWEN: That's correct. Licensees are 15 able to do that analysis on their own, and that's how 16 the first two components have actually been installed.

17 VICE CHAIRMAN REMPE: Okay. Thank you.

18 MR. BOWEN: Sure.

19 CHAIRMAN SUNSERI: Jeremy, this is Matt.

20 Just a question for you and maybe a little, as 21 somebody said, telegraphing what we might be looking 22 for or when we get the detailed presentation on this 23 topic later. But once again, I've asked manufacturing 24 technologies that while these components are going to 25 be very intricate so non-destructive examination and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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113 1 inspection to verify quality is going to be a very 2 important aspect. And you mentioned inspection in DE 3 analysis as part of your remarks earlier. Will we 4 hear more about the details of that during our deeper 5 dive on this topic later?

6 MR. BOWEN: Certainly. We can certainly 7 go into more details. We'd be happy to kind of give 8 you an overview of all those reports. But yeah, we 9 can certainly touch on that one.

10 So the one on inspection, that one is 11 still kind of going through the finalization. So that 12 one actually has not been issued. But I suspect 13 probably by the time we get to the more detailed 14 reports, more detailed discussion, we may have it 15 issued. If not, we can -- regardless, we can cover 16 it.

17 CHAIRMAN SUNSERI: Okay. I think my 18 colleague, Ron Ballinger, who's a metallurgist here 19 would be able to describe our concern maybe more 20 succinctly or more impactfully. But these things are 21 going to be difficult to inspect just because of their 22 geometry. So we're interested in how that's going to 23 be happening. So thank you.

24 MR. BOWEN: Certainly. Okay. So no other 25 questions right now. I'll touch on some of the long-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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114 1 term plans before moving to the next area. So in the 2 materials area, for long-term plans, we've put 3 together a pretty comprehensive code investment plan 4 that Ray mentioned.

5 Although most of the codes are managed and 6 maintained by our colleagues in DSA, and Kim is going 7 to touch on this a little bit more, we do have a 8 couple in DE that cover probabilistic fracture 9 mechanics, specifically extremely low probability of 10 rupture, xLPR, and FAVOR, the fracture analysis of 11 vessels code. So xLPR was actually released last 12 spring and garnered a lot of stakeholder interest.

13 Now we're actually turning to how we can -- our 14 activities can support maintenance and upgrade and 15 maintain the tools so that they're the state of 16 practice. This was going to involve release of 17 package updates, independent verification and 18 validation, and we're also working on sending up users 19 groups for both of those codes.

20 I actually think that we -- my 21 understanding is we're looking for a date to come 22 brief the Committee on the PFM, the NUREG, and the 23 draft reg guide that we just put out on both the 24 codes. So shifting back to advanced reactors a little 25 bit, a couple of areas that we see as high priority to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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115 1 be ready for future applications are molten salt and 2 graphite. So for molten salt, we're looking at 3 performance characteristics along with corrosion and 4 compatibility.

5 We've actually been engaging with our tech 6 counterparts in this area to kind of get an 7 international understanding. They've been doing a lot 8 of work. We had a bilateral with them about a month 9 ago. Similarly for graphite, we've been engaging with 10 our international counterparts in the UK. They've 11 been doing a lot of work in that area. And then in 12 both areas, again, the objective here is to support 13 development of future licensing review guidance.

14 MEMBER PETTI: Yeah, I have a question in 15 the molten salt area. This is Dave.

16 MR. BOWEN: Sure.

17 MEMBER PETTI: Are you guys looking at a 18 broad set of salts, because there's more than one 19 being talked about in different reactor concepts.

20 MR. BOWEN: Yes. Unfortunately, you -- if 21 I were to -- if you were to ask me specifics, you 22 would exceed my level of knowledge here. But I do 23 know that we're looking at multiple salts.

24 MEMBER PETTI: Great, thanks.

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116 1 on this slide is talking about artificial 2 intelligence, machine learning, kind of digital twins.

3 So really at a high level here, we recognize the 4 evolving nature of how data will be used by the 5 nuclear industry. There's an increased amount of data 6 in support of buying enhanced tools to analyze the 7 data in different ways and more rapidly. The 8 combination will likely drive future decisions by 9 designers, vendors, and licensees.

10 I think Kim is going to talk a little bit 11 about this more in her presentation. But just kind of 12 in general, we're taking steps really to be ready to 13 understand the impacts of those decisions on 14 regulatory applications. For the materials area 15 specifically, what we're looking at here is working to 16 understand how licensees and vendors intend to 17 leverage that information from really advanced sensors 18 and advanced manufacturing techniques to influence 19 decisions associated with plant materials and 20 components such as manufacturing, qualification, 21 inspection, maintenance, replacement, that sort of 22 stuff, so --

23 MEMBER PETTI: So a question, just a 24 clarification. So that's why the stuff is in this 25 branch because as I -- I think of digital twins fairly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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117 1 broadly. And I couldn't figure out why it was stuck 2 in a materials department or branch because it is so 3 broad, it could be -- I mean, it could be at the full 4 engineering level. But it may not fit in your other 5 branches, I guess.

6 MR. BOWEN: Yeah, yeah. Digital twins, 7 it's far reaching and very broad. It was -- it's 8 happened at one of our -- one of our branch chiefs was 9 the information that submitted the proposal for the 10 future focused research. But we actually have kind of 11 a working group that's involved in this. And it's all 12 three divisions within research. And we actually have 13 folks from our partner organizations and NRR and NMSS 14 and NSIR as well because, like you said, we recognize 15 the digital twins goes far beyond just materials.

16 MEMBER PETTI: Okay, great. That helps.

17 Thanks.

18 MR. BOWEN: Okay. If there's no other 19 questions on materials, I'll move along to electrical 20 and I&C. So here you'll see a similar purpose and 21 objective. In the electrical area, we're looking at 22 the impacts of long-term operations, updates to the 23 industry guidance, and condition monitoring.

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118 1 then a new piece for us, we're starting to build 2 capacity to support regulatory decisions associated 3 with cybersecurity. So on the milestones for this 4 year, in electrical, our primary focus has really been 5 moving towards closure of research in cable aging, and 6 I think this gets a little bit to Joy Rempe's question 7 earlier.

8 So this project has been going on for 9 several years. It's really designed to help us 10 understand the ability of different techniques to 11 track the aging of cables over time. We've completed 12 -- even with some of the challenges with COVID, 13 there's been some delays and such.

14 But we have been able to complete all the 15 aging of all the sample cables to an equivalent of 80 16 years. So now the final piece of this project is to 17 perform the LOCA testing to confirm our guidance on 18 environmental qualification. Again, we run into some 19 challenges with that, some aspects due to COVID.

20 But we've really been focused on how can 21 we bring this to closure and move on, get the 22 information we need, and make the regulatory decision 23 to move forward. So kind of getting to the point 24 about bringing research to closure when it's at the 25 appropriate time. So also in the electrical area, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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119 1 we're finishing up a technical letter and a reg guide 2 on degraded voltage and loss off voltage protection.

3 These documents similarly support long-4 term operation, set us up for kind of a more 5 comprehensive review and update of our electrical reg 6 guides to ensure they're aligned with the latest IEEE 7 and NIC consensus codes and standards. So the next 8 two bullets here are growth areas for us. So similar 9 to digital I&C, industry has expressed in various 10 forms that wireless is seen as an enabling technology 11 for them and allowing to support streamlining 12 functions, enhancing data flow, and will really result 13 in substantial cost savings.

14 So we've actually recently initiated 15 research activities in both the safety and security 16 aspects of wireless. And the goal here is to develop 17 an understanding of which types of wireless 18 technologies can or have been used in nuclear 19 facilities near critical functions. Again, having 20 this information (inaudible) kind of take the next 21 step, develop guidelines for the safe and secure use 22 of wireless technologies.

23 Clearly linked with this is cybersecurity 24 with the full implementation of the inspection of the 25 cybersecurity regulations across the nuclear fleet.

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120 1 I think this is an area where our regulatory 2 understanding continues to evolve. We've actually 3 been supporting (inaudible) incorporate lessons 4 learned and looking into what comes next for 5 cybersecurity.

6 And at the same time, new technologies 7 such as wireless, digital twins, AI, those all 8 introduce questions about the impact of cybersecurity 9 on a plant. So because of that, this is an area where 10 we're actually looking to building staff capacity 11 through selected hiring actions. We brought somebody 12 into the division with over 20 years of cybersecurity 13 expertise this past summer.

14 We're also doing external training and 15 seminars. And those have been well received by the 16 staff. So that's why you see this listed both under 17 our FY21 milestones and under our long-term plans.

18 The other item that's listed under long-term plans is 19 completion and document of the cable LOCA testing and 20 analysis.

21 So again, as I mentioned, really the final 22 phase of that project is expected to completed now 23 likely into next year at which point we'll be 24 documenting the findings and updating any guidance 25 that's necessary. But now we're starting to think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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121 1 about whether that really gives us sufficient 2 resolution of all the questions surrounding aging of 3 electrical systems or whether there's some other 4 aspect that we need to kind of consider to close in 5 the gaps. So I'll pause there, see if there's any 6 questions on electrical and I&C.

7 VICE CHAIRMAN REMPE: I don't have any 8 questions, but I'm going to start being mindful of 9 time because we do have follow-up meetings with each 10 of these divisions. So if you could try and finish in 11 maybe five minutes, that would give everyone more time 12 that follows after you.

13 MR. BOWEN: Sure. I'll do my best. So 14 for structural geotechnical seismic, third technical 15 arm of the division, I won't go through the purpose.

16 You can read that in the interest of time.

17 Key milestones for this year, first, joint 18 research project with USGS on seismic hazards, seismic 19 source characterization. This is kind of an extension 20 of the post-Fukushima activities for the periodic 21 assessment of natural hazard information. This is 22 looking at the Central and Eastern U.S. seismic 23 hazards.

24 The next slide on alkali-silica reaction, 25 again, another good example getting to where we're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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122 1 trying to bring things to closure. We've -- the 2 research itself was completed end of last year. We've 3 received nearly all the final reports from our 4 contractor. We're expecting the final one this month.

5 And really all that's left is kind of document 6 everything in a NUREG to serve as knowledge management 7 purposes.

8 Next, touching quickly on irradiation of 9 induced concrete degradation, work in this area has 10 kind of continued -- expected to continue through 11 2023. But this year, we're going to be publishing a 12 couple of NUREGs on kind of the state of knowledge and 13 several -- research on addressing fluence calculation 14 and then also a research information letter on 15 modeling physical properties of degraded concrete.

16 The final item listed relates to alternative 17 regulatory pathways for risk-informed performance-18 based seismic safety.

19 We've certainly come a long way in risk 20 informing seismic decision -- rates for decisions 21 associated with seismic. But there's general 22 consensus we can do more. So we're on the verge of 23 issuing a research information letter discussing 24 alternative methods to approach seismic safety.

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123 1 research. The second phase will focus more on 2 advanced reactors and will actually have a tie into 3 seismic isolation. A little more on that topic, that 4 scenario where we're working with some experts at 5 Southwest Research Institute to develop methodologies 6 and guidance on the use of seismic isolation.

7 This is -- seismic isolation has been a 8 topic that's come up in the past. This time around, 9 there's a lot of industry interest that's actually the 10 parallel work being conducted by the Department of 11 Energy. The DOE on behalf of industry is actually 12 developing a topical report that they expect to submit 13 to the Agency here within the next year, so relatively 14 complementary work going on in that area.

15 The second item under long-term plan 16 relates to guidance on concrete structures and 17 containments, research underway to look at how 18 concrete-steel bonding is affected by high levels of 19 radiation. And then once work is complete here, we'll 20 document that in a NUREG. The final item I want to 21 touch on, on this slide, I'm going to probably take a 22 minute longer here is harvesting.

23 So we're actively engaged with EPRI and 24 DOE and industry to collect harvested materials from 25 decommissioned plants. We're actually doing a pilot NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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124 1 study right now to pull concrete from SONGS. And that 2 actually will be expanded based on the results of this 3 pilot activity.

4 And although we included harvesting here 5 on the -- related to the structural work, harvesting 6 is actually extending well beyond this. We're looking 7 at other materials, RPV internals, piping, other 8 components. And we have several international 9 agreements that are in place.

10 And so the point really I want to make is 11 that there's a lot of value and potential for 12 harvesting. It's kind of at a historical high right 13 now due to that interest and the availability. So 14 this probably an item we'll share a little bit more 15 details in our follow-up brief. So any questions on 16 this one?

17 (No audible response.)

18 MR. BOWEN: All right. With that, I'll 19 move to my last slide. So as I mentioned earlier, DE 20 serves as a coordination role for reg guide generic 21 issues and consensus codes and standards as well. In 22 the reg guides, we've done a lot of work in the past 23 year to kind of enhance the program which resulted in 24 a streamlining process, really enhanced customer 25 service to our partner offices, and clarity for our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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125 1 internal and external stakeholders.

2 And so we're really memorializing these 3 improvements in an update to the management directive.

4 On generic issues, I'm happy to say that we currently 5 have none that are open. The two GIs that most 6 recently closed, GI-199 on seismic and GI-204 on 7 upstream dam failure, were closed at the end of last 8 year with the final post-Fukushima reevaluations. And 9 we're continuing to provide program support for the 10 high energy arc fault pre-GI. And Mark is going to 11 provide a little bit more detail on that in a moment.

12 On the consensus codes and standards 13 front, obviously we continue to lead engagement here.

14 Luis, my boss, is the Agency standard executive. One 15 thing that we'll note, like others, we've seen a 16 silver lining from the past year of virtual 17 interaction. We've actually had a lot -- more staff 18 have been able to participate in codes and standards 19 meetings. And this has really helped with succession 20 planning, staff development, that sort of activity.

21 Then moving on to support advanced 22 reactors, we've been interacting with multiple forms 23 to kind of understand industry interest. When their 24 prioritization of standards for advanced non-light 25 water reactors, as I'm sure you can imagine, there's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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126 1 various perspectives out there. So we're really 2 working with our industry counterparts to try and 3 bring a little bit more clarity to the situation.

4 And then the last bullet on the slide, it 5 just is a recognition on our part that as we move 6 forward, with implementing all these activities, we 7 recognize the budget might not actually reflect the 8 resources. And so this is just an area we're mindful 9 of as well kind of implement all these activities. So 10 unless there are any questions, that concluded my 11 portion of the presentation and I'll turn it over to 12 Mark next.

13 CHAIRMAN SUNSERI: Hey, Jeremy, just one 14 quick question. And once again, this can deferred 15 until we get into the deep dive part at a future 16 meetings. But on the harvesting, I think one of the 17 things that we've heard and we know from our 18 experience is it can be quite expensive just getting 19 the part out of the plant and getting it to wherever 20 it needs to be analyzed and dissected, et cetera. Has 21 there been any thought about instead of taking the 22 part to the research facility, bringing the research 23 to where the part is and testing in situ and doing 24 things like that?

25 MR. BOWEN: Yeah, thanks for the question.

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127 1 I mean, that's certainly something to think about. As 2 you said, this is an area where I think there's a lot 3 more interest and a lot more -- we're seeing some more 4 willingness, I guess, because as you point out, you've 5 got to have a willing partner in a licensee because it 6 obviously takes time and money and it affects their 7 schedule.

8 But yeah, that's -- we've been able to 9 connect with the current activities where there has 10 been mutual interest. And I think we're starting to 11 try and be a little bit more creative in our thinking 12 about what comes next. But I mean, you raise a very 13 good point, and that's certainly we can discuss in a 14 more detailed briefing, so --

15 CHAIRMAN SUNSERI: Thank you.

16 MR. BOWEN: Sure. Any other questions?

17 (No audible response.)

18 MR. BOWEN: Well, thanks. I'll turn it 19 over now to Mark.

20 MR. THAGGARD: Okay. Good afternoon. I'm 21 Mark Thaggard, Director of Division of Risk Analysis.

22 So this line shows that there are four branches within 23 the division. The only change I want to note in terms 24 of branch chiefs is Mehdi Reisi Fard is taking over as 25 the chief of the performance and reliability branch.

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128 1 That branch was previously -- the previous branch 2 chief was Felix Gonzalez, and he left the Agency a few 3 months ago.

4 So the focus of the division is to ensure 5 that the Agency has the tools and methods needed for 6 developing and incorporating risk insights into our 7 regulatory programs. And I've listed our budget 8 information up here for FY21. Next slide. So I'm 9 just going to go through the four branches, beginning 10 with the probabilistic risk assessment branch.

11 That branch's main responsibility is to 12 maintain and enhance computer tools and methods used 13 by the Agency for conducting risk analysis, the SPAR 14 models, and SAPHIRE code. In FY22, we plan to make 15 efforts to put the SAPHIRE code -- make it available 16 to run on the cloud. We think that this is going to 17 make it easier for us to provide access to the code 18 and also should provide some improvements in terms of 19 our ability to maintain security controls over the 20 code.

21 Of course, we've been working on the Level 22 3 PRA project for quite a while. Our current plans 23 are to finish that project in FY23. We actually 24 anticipate getting most of the documentation filled 25 out prior to completing it this fiscal year along with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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129 1 most of the technical work. But of course, we still 2 got some follow-on work to do once we get the initial 3 documents done. So that's why they project the 4 schedule right now to get it completed in FY23.

5 Some long-term plans in that branch, we're 6 looking -- and our main focus is to increase 7 developability of our risk tools for non-PRA 8 practitioners. We think this is kind of important 9 given the greater use of -- the greater focus on using 10 risk insights (inaudible) our regulatory programs. So 11 we want to make sure that people have the tools to be 12 able to understand what the risks are, even if they 13 don't -- even if they're not PRA practitioners.

14 We are currently working on what we call 15 a risk app, a tool for the licensed reviewers and 16 inspectors to be able to quickly gain risk insights 17 without actually having to run the SPAR modes. And 18 that's shown some real promise. So that's something 19 that we're going to put a lot of focus on and try and 20 get that completed.

21 And of course, we're continuing our 22 efforts in terms of making sure that we have models 23 developed as the new reactor designs come online.

24 We're currently starting efforts to develop a SPAR 25 model for the Vogtle 3 and 4 units. Any questions?

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130 1 Otherwise, I'll move to the next slide.

2 (No audible response.)

3 MR. THAGGARD: Okay. So the performance 4 and reliability branch, their main responsibilities 5 are to maintain our operational experience databases 6 that we use for keeping our risk tools updated. That 7 branch also have the responsibility for leading the 8 Agency's effort on developing PRA standards as well as 9 they run the Accident Sequence Precursor Program.

10 This year, our focus is to complete the ASP 11 (inaudible) report which we just actually just 12 completed a couple of weeks ago.

13 We also have developed a data 14 visualization tool for looking at our actual results 15 which we made available to the licensing staff and the 16 regions to, again, help them to give them some risk 17 insights in their areas. Early next year, we hope to 18 endorse the non-light water reactor PRA standards.

19 That standard was going to be put up for trial use.

20 Some long-term activities that we have 21 planned, so we've been working. We have a future 22 focused research effort looking at the licensed 23 modernization project, a plan to the existing 24 operating metrics. We've had some preliminary 25 discussions with NRR, and they seem to think that that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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131 1 particular effort may have some promise. They may 2 want us to do some follow-on work in that area.

3 So our current plans are to complete the 4 future focus research project and then to re-engage 5 NRR to see if they want us to do some follow-up work 6 in that area. And as Jeremy mentioned, so we also 7 have some work that we're doing looking at AI. We're 8 currently working on a long-term research project, a 9 feasibility study looking at the use of predictive AI 10 to study operational experience data.

11 We also are in the process of entering a 12 memorandum of understanding with DOE to collaborate 13 with them on their use of AI on OpE data. So we're 14 doing -- we're starting to get some engagement in that 15 area as well. And then we are -- as I mentioned, one 16 thing that we've realized is that we need to have a 17 better understanding of being able to quantify the 18 uncertainties of -- identify the uncertainties in our 19 PRA analysis.

20 We think this is an important area, 21 especially as we have advanced reactors where you 22 won't have as much operating experience data. So 23 we're starting to put some effort in terms of looking 24 at the uncertainties. Any questions on any of that?

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132 1 elaborate a little bit more about explore 2 applicability of L&P (inaudible) concepts to the 3 current generation of LWR plants? I mean, I'm aware 4 of the study where they tried to apply it to a PWR 5 years ago. What are you doing here?

6 MR. THAGGARD: Yeah, so one of the things 7 that we're doing is we're taking the -- we're looking 8 at the chapter. I believe it's Chapter 15, I guess, 9 of the standard review plan of NRR. It has a lot of 10 deterministic things that they need to look at, and 11 we're trying to apply the L&P to see if some of those 12 things that they're required to look at under that 13 requirement is really needed. What's the risk 14 associated with it?

15 And NRR at the same time, they've got an 16 effort going on where they're trying to go back and 17 look at their review process and see if there's some 18 things that they shouldn't be doing. So when they 19 found out that we had this future focused research 20 project, they see there may be some application. So 21 they wanted us to complete the first phase of that.

22 It was kind of like a scoping effort to 23 see basically how we could apply. In the case of what 24 we're doing with the future focused research effort is 25 we're using the results from the Level 3 PRA and we're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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133 1 basically applying that to come up with the curves 2 that you need to develop the L&P program. And so once 3 we get that first phase of that report, NRR wants to 4 take a look at it and see if it's going to give them 5 the kind of insight -- that it's moving into the area 6 to give them the insights that they need to help 7 identify some of the review areas that they need to 8 scale back on or cut out.

9 VICE CHAIRMAN REMPE: Okay. Thank you.

10 MEMBER DIMITRIJEVIC: I have a little 11 higher level question on the PRA and use of -- and how 12 do you look in the future with. This is Vesna. So my 13 question is in the general, did you have -- did you 14 try to have some long-term plan?

15 What is the goal to accomplish in the PRA-16 related future developments, because are we trying to 17 make sure -- and also the division is between new and 18 operating reactors in this area. Are we trying for 19 future PRA to be as complete as possible or to produce 20 as accurate number as possible, which I would not ever 21 define as a goal. Or we are trying to define the 22 application, much more flexibility of application on 23 the PRA than just developing these models to be more 24 complex, more involved?

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134 1 in HRA, we are looking to improve accuracy of the 2 numbers. But we always say that numbers are not the 3 goal of the PRA. Or if we are looking in the --

4 defining the -- trying to make sure that we didn't 5 miss any hazards.

6 Are we pretty complete in this moment?

7 This PRA acceptability is basically important if you 8 are expecting many new risk-informed application from 9 the operating fleet. And I think basically now since 10 we are -- right now, we are seeing this 50.69. And 11 that will pretty much complete the risk-informed 12 status.

13 So I was thinking, I mean, you have a 14 submission of when we talk about the new reactors.

15 The PRA which was introduced in '75 and introduced 16 (inaudible) in '95. And now we are talking 25 years 17 after that. Are we going to have some different 18 vision of the greater use and what is applicable to 19 certain standards? Are we trying to use always the 20 same tools or we are trying to develop something new?

21 MR. THAGGARD: Well, it's a little bit of 22 combination of both. And it's probably something we 23 need to maybe get into when we have the more detailed 24 program review. We need to have tools available 25 because especially for new reactors.

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135 1 They're required to do a PRA analysis.

2 And the staff at the Agency has to have the tools to 3 be able to evaluate if they make changes. We're not 4 -- and our goal is not to necessarily continue doing 5 what we've always done.

6 But we recognize that the tools that we 7 have in place right now are not complete. So we need 8 to make sure that they're complete from the standpoint 9 of being able to analyze the different things that we 10 know that the licensees are going to do. For example, 11 we know that licensees are looking to do certain 12 things with the FLEX equipment.

13 We've incorporated the ability to handle 14 FLEX in all our SPAR models. But it's only in the 15 case of ELAP conditions. Well, we know licensees are 16 planning to go beyond the use -- FLEX equipment beyond 17 ELAP conditions. So we need to make sure that our 18 licensing staff have the capability being able to 19 analyze when licensees come in and use their PRA in a 20 slightly different manner. So --

21 MEMBER DIMITRIJEVIC: You said exactly 22 very right what I was going to try to put on this high 23 level. But then when you said new reactors have to do 24 the PRA, that meant -- is that the statement which is 25 always true because if you're having totally new NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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136 1 (inaudible) the safety, is this full scope PRA 2 required in this case?

3 That's one of the things we have to think 4 at this moment in my opinion. It is because if you --

5 if they have different safety, then maybe PRA can be 6 used in some greater application in defining design 7 basis events or the safety specification or things 8 like that. But the full scope PRA may not be 9 necessary if there is no peak source term. There is 10 inherent safety that things can be. So this is what 11 I was thinking. Can we look in the different --

12 MR. THAGGARD: Okay.

13 (Simultaneous speaking.)

14 MEMBER DIMITRIJEVIC: -- application of 15 the PRA?

16 MR. THAGGARD: Yeah, yeah. Okay. I 17 understand where you're going. So I misunderstood 18 completely. So yeah, this is probably something we 19 should probably hold off and have a more detailed 20 discussion on because you're probably getting into 21 some of the licensing stuff that I'm not familiar 22 with. And we may need to get some NRR colleagues in 23 on the discussion because one of the things that we 24 are looking at right now in terms of the non-light 25 water reactor PRA standards to some of the issues that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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137 1 you raised.

2 What I was referring to is the 3 requirements for new reactors which like the Vogtle 3 4 and 4 units. Those are classified as new reactors.

5 The advanced reactors -- the requirements for -- PRA 6 requirements for the advanced reactors, that's going 7 to be laid out in the new rule that's being developed 8 under Part 53. So what's all going to be in that 9 requirement, I can't really speak on that right now.

10 MEMBER DIMITRIJEVIC: Okay. Well, this is 11 -- yes, my question is, do you -- in your research 12 requirements, are you looking in this application from 13 the CFR 53 needs? And is there some research in 14 advance of the PRA which can be related to these 15 needs?

16 MR. THAGGARD: Oh, yes, yes. We're 17 actively involved in that. So we -- NRR has already 18 identified a couple of areas which I probably don't 19 want to -- I don't want to touch on because I don't 20 want to put them in a -- because they haven't 21 specifically told us that they want us to do it. But 22 they've identified a couple of areas where they think 23 that we're going to need to do some work to help them 24 out.

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138 1 I agree with Vesna that a long-term vision is a good 2 idea. But I also am mindful of time. So I'm going to 3 do the same thing I did to the prior speaker and say, 4 can you finish your presentation in about five 5 minutes?

6 MR. THAGGARD: Sure, sure.

7 VICE CHAIRMAN REMPE: Thank you. I'm 8 sorry to do this, but we do have follow-on meetings.

9 MR. THAGGARD: No, no. That's fine. So 10 --

11 (Simultaneous speaking.)

12 MR. THAGGARD: -- in the fire and the 13 external hazard branch, their primary focus is doing 14 the research in the fire area and also external 15 hazards with the exception of seismic. We don't have 16 seismic. So obviously, the two big areas that we're 17 working on right now is the PGI for the aluminum HEAF.

18 We're hoping to be at the -- by the end of 19 -- early fiscal year 22, we hope to be able to 20 quantify the risk associated with those events. So 21 we're putting a lot of effort into that effort right 22 now. And then the probabilistic hazard assessment, we 23 are actually hoping to be done with phase one of that 24 work this fiscal year. So that project is quickly 25 coming to closure.

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139 1 Long term, one of the -- a couple of 2 things we're moving into right now, so we are starting 3 to provide more support for NMSS primarily in a 4 decommissioning and waste area. So we've got a couple 5 of projects in that that we're supporting them. And 6 I think there's going to probably more work in that 7 area. And then so if there are no other questions, I 8 guess we'll move on to the next slide.

9 So the last branch is human reliability 10 and human factors and reliability branch. I think 11 most of the work in this branch is conducting, you 12 guys are familiar with because we briefed you several 13 times on the ideas and methodologies. That's one of 14 the main things that that branch is working on as well 15 as collecting data to support that methodology, the 16 SACADA project.

17 A couple of things that they're also 18 working on that may not be as a high visibility is 19 they're currently working on a human factors 20 engineering review guidance for non-light water 21 reactors. That's a high priority for NRR, and we're 22 expecting to get that done this fiscal year. And as 23 I said, we're continuing to collect date for the ideas 24 and methodology. Long term --

25 CHAIRMAN BLEY: Mark?

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140 1 MR. THAGGARD: Yes?

2 CHAIRMAN BLEY: I'm not familiar with that 3 last one you talked about, the human factors 4 engineering review guide for non-LWRs. But what kind 5 of things are special about non-LWRs that you'd need 6 new guidance in this area?

7 MR. THAGGARD: So one of the things that 8 they wanted us to do was to take the current guidance 9 which is in NUREG 0700 which is a very voluminous 10 document. And they wanted us to take that and see if 11 we can make it more easier, user friendly version for 12 license reviews. So we're working on that. But I 13 think that --

14 CHAIRMAN BLEY: That would be applicable 15 to both existing kind of reactors and new ones.

16 MR. THAGGARD: Yeah, it is, although the 17 people in (inaudible) are the ones that think that 18 there's a bigger need for it right now. But I agree 19 with you. I think it has an application for both.

20 But they anticipate things getting, like, unique type 21 of control rooms and control room designs, that they 22 think that the current guidance doesn't cover. So 23 they want us to take a look at that.

24 CHAIRMAN BLEY: Okay, thanks.

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141 1 what we're trying to do in that branch is we're 2 actually trying to move into the IDHEAS-G methodology 3 for doing HRA. We're actually trying to see if 4 there's some applicability in some of the other 5 program areas, like, for example, in the physical 6 security area as well as some of the NMSS work. So 7 we're trying to expand the use of that and see if it 8 has application outside of the reactor program. So 9 those are the main things I wanted to cover. Any 10 other questions?

11 (No audible response.)

12 MR. THAGGARD: Okay. If not, then I guess 13 I'll turn it over to Kim.

14 MS. WEBBER: Okay. Good afternoon, 15 everybody. My name is Kim Webber. I'm the Director 16 of the Division of Systems Analysis. In DSA, we have 17 budget for 62 staff with 54 on board. Our contract 18 funding for this year is about 17 million dollars.

19 DSA staffing and contract levels have been 20 relatively flat over the last few years. And we're 21 expecting that to remain flat into 2023. From a 22 workload perspective, we're finishing a lot of 23 research and co-development activities for near term 24 ATF concepts in high burnup fuel. In addition to 25 generic advanced reactor activities, we're also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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142 1 anticipating growth in co-development activities for 2 plant-specific advanced reactor designs and in the 3 data science and artificial intelligence areas that 4 I'll tell you about momentarily.

5 As you may be aware, DSA has four branches 6 and the names of the branches along with their chiefs 7 are shown on this slide. As you know, Richard Lee 8 retired in January. And while we're sad to see 9 Richard go, Hossein Esmaili who's very accomplished 10 and is doing a great job was selected as DSA's newest 11 branch chief in the fuel and source term code 12 development branch.

13 Combined, the technical research areas in 14 DSA are very broad, and they include fuel performance, 15 reactor physics, reactor systems, source term, 16 accident progression, severe accident, accident 17 consequences, radiation protection, and health 18 physics. Next slide, please. Before I jump into 19 highlight DSA accomplishments and the planned work on 20 the next five slides, I just want to take a few 21 minutes to talk about some of the DSA focus areas.

22 We talked -- Ray talked a little bit about 23 the visibility of ATF and advanced reactors. And as 24 you've heard me say many times, our goal is readiness 25 to support the regulatory offices. So we want to have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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143 1 our codes and the expertise available to perform 2 confirmatory analysis on a wide range of technical 3 areas when requested by the program offices.

4 As you know, code development and 5 maintenance is a large part of DSA's focus. Not only 6 does that work support regulatory oversight activities 7 like licensing, it also supports maintaining our core 8 competencies and the expertise. In addition to also 9 providing knowledge management tools as technologies 10 change over time, I'd be remiss if I didn't thank you 11 all for your hard work over the last few years 12 reviewing our advanced reactor code development 13 reports.

14 We look forward to the division portion of 15 the biennial review where we will take time to answer 16 more specific questions that you have on this topic.

17 We understand your interest in knowing more 18 specifically how the reports were modified to reflect 19 your recommendations. And I've been in contact with 20 Derek Widmayer to determine a path forward to 21 communicate that with you.

22 As Ray and Jeremy and Mark have mentioned, 23 a new technical area for RES and also for DSA is in 24 data science and artificial intelligence. There are 25 many efforts across the office that -- and you heard NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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144 1 about some of those by Jeremy and Mark. And really 2 the purpose of our initiative is to learn how these 3 technologies might be used by our licensees and 4 applicants and also to build organizational capacity 5 within the Office of Research and across the Agency, 6 and we'll do this through training and completion of 7 use cases which enable hands on experience with 8 robotic process automation and artificial intelligence 9 that include machine learning and natural language 10 processing techniques.

11 The goal of these activities is really to 12 identify the gaps in our regulatory framework and help 13 develop guidance as necessary. Additionally, some of 14 our staff's use cases involve applying AI and data 15 science techniques for process and analytical 16 improvements. In DSA, some examples include using 17 natural language processing to predict resources for 18 licensing actions and using autonomous control 19 algorithms to simulate BWR power cycles.

20 A large source of experimental data for 21 our code validation activities is through leveraged 22 domestic and international experimental programs such 23 as those organizations shown in the fifth bullet on 24 this slide. We use our code sharing program such as 25 the RAMP, CAMP, and CSARP programs to support our code NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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145 1 development activities through a large community and 2 monetary contributions. This offsets some of the 3 costs for our code development activities.

4 Since the last biennial review, we've been 5 developing the code investment plan which Ray referred 6 to earlier. This was requested by the Commission in 7 a staff requirements memorandum associated with the 8 FY21 budget formulation cycle. This plan provides a 9 framework for identifying the costs associated with 10 developing, maintaining, modernizing, and 11 consolidating the NRC's 40-plus scientific codes.

12 It's also being used to plan code 13 development and budget activities. I'll just pause 14 there to see if there are any specific questions 15 because I thought since I was presenting at the end of 16 the meeting, I wouldn't have that much time to talk 17 about it. But we'd also be happy to talk more about 18 the code investment plan in a separate meeting.

19 Lastly, DSA is leveraging some of the RES 20 future focused research funding to identify areas of 21 research that are on the horizon, including TRACE 22 modernization, dose assessments for people who own 23 pets treated with radioisotopes, and the use of drones 24 that could be used for decommissioning site 25 assessments. Next slide, please. For all the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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146 1 technical areas that I'll cover in the next few 2 slides, the regulatory purpose remains the same, to 3 maintain and enhance the tools and expertise to 4 support a wide variety of NRC regulatory oversight 5 activities.

6 Each slide will identify the technical 7 area focus under the regulatory purpose. For this and 8 the remaining slides, I'll just cover a few 9 highlights. But I'm happy to answer any questions 10 that you have on topics that I don't cover.

11 In the thermohydraulics area in addition 12 to major code releases for TRACE and SNAP, a few 13 highlights include the completion of several BlueCRAB 14 Advanced Reactor reference plant models in FY21. In 15 particular, we completed or will have completed 16 reference plant models for molten salt reactors which 17 is really towards the end of the year, microreactor, 18 sodium fast reactor, gas cooled pebble bed reactor.

19 The reference plant models are based on publicly 20 available plant designs.

21 They give us the means to test the 22 BlueCRAB suite of codes and to provide a foundation 23 for more efficiently creating models of applicant 24 designs to support confirmatory analysis as requested 25 by NRR. And I know there was some interest in knowing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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147 1 how we're using these reference plant models. Steve 2 Bajorek and others have written an ENS paper reporting 3 on their use of our microreactor reference plant 4 model. If that's something that you're interested in, 5 we'd be happy to provide that paper to you.

6 We're also developing TRACE plant input 7 decks that are representative of most of the PWR and 8 BWR in the operating fleet. Doing this ahead of 9 license submittals improves the efficiency and time 10 needed to modify plant input decks and is similar in 11 concept to the reference plant model approach for 12 advanced reactors. This year, we plan to complete 13 input decks for Palo Verde and Point Beach.

14 I'll go to the next slide unless there are 15 questions. In the fuels and neutronics area, in 16 addition to major code releases for FAST, SCALE, and 17 PARCS, a few highlights include the completion of ten 18 literature reviews on a range of topics related to 19 near term ATF concepts, high burnup fuel, and 20 increased enrichment related to fuel performance, 21 neutronics, fuel transportation and storage, and 22 source term and severe accidents. A chrome coated 23 phenomena identification and ranking table or PIRT 24 report was used to support development of NRR's 25 interim staff guidance on chrome coated cladding.

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148 1 Reports on neutronic impacts of ATF 2 increased burnup and enrichment will be completed by 3 this fiscal year -- by the end of the fiscal year.

4 Over the last several months, my staff has 5 collaborated with INL to assess FAST and BISON fuel 6 performance codes against one of the EBR-II 7 experiments. As an outcome, FAST has the capabilities 8 to model sodium fast reactor metallic fuel rods, 9 although improvements in fission gas release and fuel 10 swelling models will be beneficial. And we'll have to 11 do that over some time. I'll go on to the next slide.

12 MEMBER PETTI: Kim, I have a question.

13 MS. WEBBER: Sure.

14 MEMBER PETTI: Do you see or do you have 15 any resource constraints in terms of your support for 16 ATF and your support for advanced reactors? Or are 17 they different enough staff that you're able to make 18 progress on both without hindering either?

19 MS. WEBBER: I think that's a really 20 question, Dave. Actually so far we have been able to 21 do all of the work that we've been asked to do without 22 sort of a bottleneck relative to our skill sets being 23 divided between two high-visibility areas.

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149 1 staff were promoted this year and moved out of the 2 organization. So we are trying to fill those 3 vacancies with folks who have co-development skills, 4 fuels, severe accidents and other areas. So I think 5 so far we're doing okay, but with the anticipated 6 increase of workload with advanced reactors that's a 7 focus area for us, clearly.

8 MEMBER PETTI: All right. Okay. Thanks.

9 MS. WEBBER: Okay. Sure. In the accident 10 progression --

11 DR. CORRADINI: Kim?

12 MS. WEBBER: Yes?

13 DR. CORRADINI: This is Corradini.

14 MS. WEBBER: Hi.

15 DR. CORRADINI: Hi, how are you?

16 MS. WEBBER: Good.

17 DR. CORRADINI: To follow on Dave's 18 question, if you get in a bind how are you going to 19 prioritize? Do you have a prioritization scheme if 20 you actually get in a bind? Like too much is coming 21 in the front door and somebody's got to go first and 22 somebody go second, do you have a prioritization 23 scheme?

24 MS. WEBBER: So for ATF, as you may be 25 aware, what we're really focused on are the near-term NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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150 1 fuel concepts, which are chrome-coated cladding, 2 chrome-doped fuel, and to some extent this FeCrAl-3 coated cladding. Although the more longer-term 4 concepts like silicon carbide-clad fuel and those 5 unique fuel types -- we're not really doing a lot of 6 work in that area because there's not a demand signal 7 from the industry to work on those in the shorter 8 term. So in the term -- in the area of accident-9 tolerant fuel I think we're doing pretty well relative 10 to understanding the priorities.

11 When it comes to advanced reactors, as you 12 know, the market is pretty volatile. There's a lot of 13 money in advanced reactors and there's a lot of 14 interest. There's bipartisan support. And so we're 15 basically taking a couple of different approaches.

16 We're following what's going on with DOE funding 17 streams to help us understand where the priorities may 18 lie within that industry. And there we're also very 19 -- we're collaborating with the licensing folks in NRR 20 to understand licensee -- I'm sorry, or applicant 21 communications with the licensing organization to 22 understand the priorities.

23 So we feel at this time that we understand 24 those priorities and we're trying to get these 25 reference plant models for advanced reactors and also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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151 1 the TRACE input decks ready so that we can support 2 whatever technologies come our way. So we're doing 3 the very best that we can with the resources available 4 and understanding that the priorities could shift, but 5 I think we're doing really well actually. I'm very 6 proud of the work that my staff has done over the last 7 few years to get us ready.

8 DR. CORRADINI: Okay. Thank you.

9 MS. WEBBER: Yes. Okay. I think we're on 10 slide 5. Or sorry, on the next slide. Yes, accident 11 progression, source term.

12 So in this area I wanted to highlight a 13 couple of key areas. We released a new version of 14 MELCOR which contains many improvements for more 15 reliable calculations for operating reactors and many 16 models for non-light water reactors and advanced fuel 17 technologies. So those referenced plant models 18 include sodium fast gas-cooled reactor, microreactors 19 and sodium -- or molten salt-cooled pebble-bed type 20 reactor design.

21 Also staff's supporting updates to Reg.

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152 1 ton uranium, peak rod average, enrichments up to eight 2 weight percent and near-term ATF concepts.

3 In May 2020 we issued a memo which is 4 publicly available where my staff recommended using 5 the accident source terms from a Sandia report 6 developed for mixed-oxide fuels. That was SAND2011-7 0128, if you're interested.

8 We also completed, or will be completing 9 a major milestone for ATF and high burnup, and that's 10 the severe accident PIRT. And the report for that 11 will be done at the end of May.

12 Next slide, please? As I indicated --

13 VICE CHAIR REMPE: Kim, I'm sorry, before 14 you leave that one, on all these basically reports 15 where you don't -- or you're allowing applicants to 16 use intermediate and high burnup fuel, are there data 17 to support this or are you extrapolating from the 18 available data?

19 MS. WEBBER: So that's a -- thank you for 20 the question, Joy. That's something that we're 21 concerned about, quite frankly.

22 For chrome-coated and chrome-doped fuel we 23 feel like there's enough data to support the 24 development of those fuel types except -- and maybe 25 one area where we're keenly watching the R&D is in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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153 1 context of high burnup. While we have information up 2 to 68 gigawatt-day per metric ton for high burnup 3 fuel, we're hearing that the industry wants to go even 4 higher than that on a peak rod average perspective.

5 So there's some data that we're looking for there.

6 And then also with regard to fuel 7 fragmentation relocation and dispersal we're also 8 trying to understand what industry -- the vendors, the 9 three fuel vendors are doing relative to being able to 10 address FFRD at high burnups.

11 And so one of the things that we're 12 involved with, and I think I mentioned it on the 13 previous slide, is that we're involved with a couple 14 of international experimental programs, QUENCH-ATF and 15 SCIP III, which are focused on high burnup and FFRD 16 and ATF experiments, fuel performance experiments.

17 So I think it's a good question, Joy, and 18 it's one that we continually ask our colleagues at 19 Department of Energy and the national labs to help us 20 obtain data early before the applications come in.

21 VICE CHAIR REMPE: So in the follow-up 22 meeting I'd be interested in hearing a bit more about 23 this and what the criteria are for when you have 24 enough data that is beyond the level of detail we can 25 get to today. Thank you.

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154 1 MS. WEBBER: Okay. And the scope of the 2 question is ATF?

3 VICE CHAIR REMPE: Yes, although I --

4 perhaps it's also going to have to go -- limited --

5 with no longer having Halden, if there's any non-ATF 6 fuels where they're trying to explore this, I'd be 7 interested what the staff is going to do about this.

8 MS. WEBBER: Okay. Great. I just took a 9 note, so we'll try to cover that in the division 10 meeting.

11 Okay. So back on the consequence analysis 12 and data science slide. So again I mentioned that 13 data science and AR are a new area for us. We're 14 concentrating our expertise for this in the Accident 15 Analysis Branch, although expertise in other DSA 16 branches is also growing. It's a pretty hot area that 17 lots of folks are interested in and I see that they 18 understand that there's value to using these 19 capabilities.

20 So we're growing our knowledge and 21 understanding of the capabilities in those areas 22 across the division, although the reason why we're 23 focusing the expertise in this branch is because work 24 in the accident consequence analysis area is 25 anticipated to decline with the completion of Level 3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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155 1 PRA study and the remaining SOARCA uncertainty 2 analysis. So our goal is for AAB to become a leader 3 in this area through staff training, independent study 4 activities, degree certification programs and even 5 external hiring of data scientists.

6 AAB has begun developing an AI strategy 7 that will help build organizational capacity and the 8 staff expertise to apply data science and AI 9 techniques within the agency, within the Office of 10 Research, within the Agency for Process Improvements 11 and also to evaluate the safety of industry's uses of 12 those technologies.

13 A few other highlights I wanted to 14 mention: So we anticipate completing a consolidated 15 SOARCA summary, an uncertainty analysis summary report 16 this year with most of the important and potentially 17 useful insights from the other three uncertainty 18 analysis from Peach Bottom, Surry and Sequoyah 19 uncertainly analysis.

20 And this is the final work product for 21 SOARCA. So I think one question that was asked 22 earlier was what activities are being sunset? And so 23 this is clearly -- the SOARCA series of activities is 24 finding its way to completion. And again that's why 25 we're trying to cross-train staff in the AI and data NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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156 1 science area.

2 Additionally in FY '20 and '21 we'll have 3 released two versions of the MACCS code which include 4 NOAA's HYSPLIT's data practice atmosphere transport 5 and dispersion model, a gross domestic product-based 6 economic model and the near-field models which we had 7 said we would deliver in the context of the Volume 3 8 advanced reactor co-development reports.

9 And then on the last slide, in the 10 radiation protection and health physics areas the 11 Radiation Protection Branch has the lead for NRC's 12 Annual Abnormal Occurrence Report to Congress in 13 addition to the Annual Arrears Report. They maintain 14 17 citing and licensing dose assessment codes that are 15 used by the staff and by domestic and international 16 organizations.

17 A couple of highlights include the 18 completion in FY '20 and FY '21 of a number of updates 19 to several codes that are shown here on this slide.

20 And then additionally in FY '22 we anticipate 21 completing the consolidation of the atmospheric 22 transport and dispersion codes that are described in 23 the Advanced Reactor Co-Development Volume 4 Report.

24 And so this concludes my presentation and 25 I'll turn the meeting back over to Ray.

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157 1 MR. FURSTENAU: Okay. The next slide.

2 Just like I said in the introduction, we really value 3 the feedback we get from the Committee and look 4 forward to the division interactions we'll have in the 5 future and any suggestions throughout the process on 6 our approach and structure and topic areas. I know 7 one particular area that I kind of failed to open on 8 and want to have a further discussion is on research 9 stops and completions that we have had in the past.

10 Some of that was touched on, but we'll go into that in 11 more detail in the future discussions.

12 And with that I'll turn it back over to 13 the Chairman, or Joy.

14 VICE CHAIR REMPE: Thank you. I want to 15 thank you as well as your staff and I apologize for 16 having to follow the time because it looks like we 17 actually have a little bit of extra time.

18 I know I'm very interested in some follow-19 up items mentioned. I know Kim mentioned not only 20 some reports, but also this integrated code program 21 plan that you as well as Kim mentioned that I hope we 22 can follow up in some of these meetings, as well as 23 some of the other follow-on discussions.

24 Do other members have some comments they'd 25 like to bring forth at this time?

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158 1 MEMBER PETTI: Yes, Joy, I was interested 2 -- I didn't want to get into it because of the time, 3 but the use of AI in the accident analysis realm and 4 what's being thought about going forward. I would 5 imagine you have a gazillion calculations on some of 6 the existing fleet and whether you can use AI to 7 harvest more from those calculations. When someone 8 asks the question that falls between two calculations, 9 is there a way that you can save yourself some time by 10 not running another calculation but using AI tools to 11 help you. Those are the sorts of things I'd be 12 interested in.

13 VICE CHAIR REMPE: Okay. Vesna or Matt, 14 do you have any other comment?

15 MEMBER DIMITRIJEVIC: Yes, I was going to 16 just say before we have individual meetings on those 17 three topics, it will be really useful if staff can 18 think about how can we be of the most help and ask us 19 that before the meeting so we can have some things to 20 think before we meet individually.

21 VICE CHAIR REMPE: Good point.

22 Matt?

23 CHAIRMAN SUNSERI: Actually, Joy, I've got 24 -- this meeting was very helpful for me. I've pretty 25 much now fleshed out what I would consider an outline NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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159 1 for the future follow-on meeting with the Engineering 2 Branch. And just real briefly I'll just touch on 3 these. And of course this doesn't have any input from 4 the rest of the members, which I will seek 5 independently, but I'm interested in following up on 6 the strengthening collaboration activities which we 7 mentioned in our previous letter, specifically the new 8 addendum to the MOU with DOE, and advanced 9 manufacturing technology research. The nuclear 10 industry is not the first people to deal with advanced 11 manufacturing, so what kind of collaboration is going 12 on outside that?

13 There's a whole list of topics that I 14 throw into the category of life beyond 60. That's the 15 radiation-induced concrete degradation, concrete steel 16 bonding degradation with age, cable aging, LOCA 17 testing for EQ. I'm going to throw in the harvesting 18 topic in that list also as far as bringing new 19 research and the innovation that's going in there.

20 Dave mentioned molten salt, so we'll want 21 to look at the scope of molten salt research.

22 Also Dave mentioned the use of artificial 23 intelligence, which I will add to my list.

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160 1 application specific of it.

2 It was mentioned about seismic isolation 3 for advanced light water reactors. My question is is 4 there any application for the existing fleet?

5 The advancement of wireless technology as 6 enabling technology. We want to hear more about the 7 safety application and the security risk.

8 And lastly, we're curious -- I'd be 9 curious about the experience you're getting developing 10 cyber expertise and where you see that's going in the 11 future.

12 So I know that's a pretty long list. We 13 don't have to discuss it right now, but we will have 14 an informal meeting to flesh out the details of this 15 future meeting some more. But that's just kind of 16 where my head is at right now. That's all.

17 VICE CHAIR REMPE: Okay. So for each of 18 the leads the next step is to develop a list such as 19 what Matt has. And we've done this in the past and my 20 vision; but again, we're always open to suggestions 21 for improving this, is to have that list provided to 22 each of the division directors and have an informal 23 meeting to discuss it before we schedule the next 24 meeting. But I would like to see those meetings 25 scheduled this summer just so that we can get our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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161 1 report together and issued by the end of this calendar 2 year. So I'll work with the leads and we'll do this.

3 But, Ray, I did mention to you several 4 topics that we might want to discuss in addition to 5 that such as if there's any projects that you feel 6 needs to have a more thorough review such as we did 7 with the Level 3 PRA or ideas, or the other example, 8 the CSGTR, let us know. That's kind of outside the 9 biennial, but again we're here to help the Agency and 10 you're well aware of where there might be some needs 11 that we might not pick up on our own. Okay?

12 MR. FURSTENAU: Yes, I think that will 13 rise -- some of that might rise to the top as we start 14 the biennial, the most detailed biennial review. So 15 I definitely will have an action on that, Joy.

16 Thanks.

17 VICE CHAIR REMPE: Okay. Do any other 18 members have comments? And then I guess we need to 19 open up the line for the public, please.

20 MEMBER BALLINGER: Yes, this is Ron. I 21 have a comment of support, what Matt was going into.

22 From a materials item, I'm very much interested in 23 knowing for a particular area what are the exact goals 24 for each one of these projects and how does that goal 25 apply to something that the Agency actually needs to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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162 1 know? So that's where I'm coming from.

2 VICE CHAIR REMPE: Okay. Is the public 3 line open?

4 MEMBER KIRCHNER: Joy, this is Walt.

5 OPERATOR: The public line is open for 6 comments.

7 VICE CHAIR REMPE: Okay. I heard someone 8 else say something.

9 MEMBER KIRCHNER: Yes, this is Walt, Joy.

10 VICE CHAIR REMPE: Okay. Walt, could I 11 ask you to wait? Let's get the public comments and 12 then I'll come back to you. Okay?

13 Are there any members of the public who'd 14 like to make a comment at this time?

15 (No audible response.)

16 VICE CHAIR REMPE: I think I've given it 17 the five-second rule, so I'm going to go --

18 CHAIRMAN SUNSERI: Did we lose you, Joy?

19 VICE CHAIR REMPE: Yes. Yes, I'm sorry.

20 Please close the public line.

21 And then, Walt, would you like to make 22 your comment?

23 OPERATOR: The line is closed.

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163 1 Investment Plan because that over the last two cycles 2 of our biennial reviews has been of much interest. So 3 I think Ray volunteered to -- or maybe it was Kim --

4 to give a briefing on that. That gives us a little 5 longer range perspective to complement the kind of 6 near-term review of the individual activities.

7 VICE CHAIR REMPE: I agree. I think 8 actually I -- because, great, the Commission did send 9 that SRM out, and so I'm very interested in seeing 10 what the staff's response is.

11 I also liked Vesta's comment about the 12 flexibility for applications of PRA because I think 13 that's something that's coming up with Part 53 14 interactions about a graded approach. And so I'd like 15 to hear more about that.

16 Any other members?

17 CHAIRMAN SUNSERI: José has his hand up.

18 VICE CHAIR REMPE: Oh, I'm sorry, I didn't 19 see that. José?

20 (No audible response.)

21 VICE CHAIR REMPE: José, your hand's up?

22 CHAIRMAN SUNSERI: Un-mute, José.

23 MEMBER MARCH-LEUBA: I have a double mute 24 button.

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164 1 back will you give us a status report on the KATHY 2 data? That was the ATWS ICPR experiments that were 3 performed in Europe.

4 MS. WEBBER: Okay.

5 MEMBER MARCH-LEUBA: We haven't heard 6 anything in two or three years about it.

7 MS. WEBBER: Okay. Sure. Yes, we'd be 8 happy to give you status.

9 VICE CHAIR REMPE: Excuse me. My 10 microphone was on mute. But that should go in the 11 list that Dave's preparing, José, and so Dave and you 12 develop that list. In fact all of the leads send it 13 around to all the group so that we make sure that all 14 of our comments are document and we can work with the 15 staff to make sure everyone's comments are anticipated 16 in advance. Okay?

17 MEMBER PETTI: I'm taking notes.

18 (Simultaneous speaking.)

19 MEMBER MARCH-LEUBA: -- Dave an email as 20 we speak.

21 VICE CHAIR REMPE: Great. Thank you.

22 And with this we're about three minutes 23 over. And I apologize, Mr. Chairman, but we did the 24 best we could.

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165 1 got a three-minute late start, so you did right on 2 time.

3 All right, Committee. We're going to roll 4 into this training -- annual training. There's a 5 separate TEAMS invitation. It should be on our 6 calendar to do that, but we've been at this for over 7 two hours now, so I'm going to at least call for a 10-8 minute break so we can at least heat up our lunch or 9 whatever we're going to need for eating over this 10 period of time and the bathrooms breaks and all that 11 stuff.

12 So we will resume with the training -- let 13 me say this more succinctly here: We are going to 14 recess from this session. We will resume our training 15 in 10 minutes, and that will be -- we'll just call it 16 a quarter to the hour. A quarter to the hour we'll 17 resume with the training on a separate line.

18 That is all. Thank you. We are recessed.

19 (Whereupon, the above-entitled matter went 20 off the record at 1:34 p.m. and resumed at 3:32 p.m.)

21 CHAIRMAN SUNSERI: The meeting will 22 reconvene. It's 3:32 Eastern Time. I'll begin with 23 the roll call.

24 Ron Ballinger?

25 MEMBER BALLINGER: Here.

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166 1 CHAIRMAN SUNSERI: Dennis Bley?

2 CHAIRMAN BLEY: Here.

3 CHAIRMAN SUNSERI: Charles Brown is here.

4 Vesna Dimitrijevic?

5 MEMBER DIMITRIJEVIC: Here.

6 CHAIRMAN SUNSERI: Walt Kirchner?

7 MEMBER KIRCHNER: Here.

8 CHAIRMAN SUNSERI: Jose March-Leuba?

9 MEMBER MARCH-LEUBA: Here.

10 CHAIRMAN SUNSERI: Dave Petti?

11 (No response.)

12 Joy Rempe?

13 VICE CHAIRMAN REMPE: Here.

14 CHAIRMAN SUNSERI: Pete Riccardella?

15 MEMBER RICCARDELLA: I'm here.

16 CHAIRMAN SUNSERI: Dave Petti? Dave, if 17 you're there, unmute. I see he signed in.

18 (No response.)

19 Okay. Well, he must be having difficulty.

20 But we have a quorum. So, let's proceed 21 forth.

22 Our next topic on the agenda is NuScale 23 Topical Report on Control Room Staffing. We will 24 begin this as an open session, and we'll only close it 25 if we get into the need for a discussion of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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167 1 proprietary information, which at this point in time 2 we don't have any. That's just a contingency. So, at 3 this point, I would turn to Walt Kirchner, 4 Subcommittee Chair, to kick off the session.

5 Walt?

6 MEMBER KIRCHNER: Yes. Thank you, Mr.

7 Chairman, and I'll keep my remarks brief.

8 We had a Subcommittee meeting on this 9 topic of NuScale control room staffing just last month 10 on March 16th. And we had thorough presentations 11 then, and we did have the benefit of a closed session 12 as well.

13 So, at this point, I'm going to go 14 directly to NuScale and turn it over to Jim Osborn.

15 Jim, please take it away.

16 MR. OSBORN: Thank you. Thank you, Walt.

17 Yes, my name is Jim Osborn, and we 18 appreciate the opportunity to make this presentation.

19 There's really no new material here, just a summary of 20 what we presented back in March.

21 And so, as we go to the next slide, we 22 also have the same presenters. So, myself and Doug 23 Bowman will be the primary presenters, and then, Pat 24 Learly and Nadja Joergensen may also chime in.

25 Then, the agenda is on the next slide.

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168 1 And it's an abbreviation of the agenda that we 2 provided in the presentation in March, just a little 3 less detail. So, hopefully, we'll get through that.

4 So, I'm going to turn it now to Doug 5 Bowman to go through the topics here.

6 MR. BOWMAN: Okay. Thank you, Jim.

7 So, as Jim stated, this is going to be a 8 summary of what we presented back to the Subcommittee.

9 So, our agenda today, we will cover regulatory 10 requirements, our Topical Report purpose and overview, 11 the revised control room staffing, and then, the 12 issues confronting the Shift Technical Advisor. And 13 at the end, of course, we'll -- not just at the end --

14 anytime you feel, you can jump in with questions for 15 us.

16 All right. So, we'll go back through and 17 walk through our regulatory requirements and guidance 18 that we are using for this Topical Report.

19 The first one is really the most important 20 to us. It's NUREG-0800, Chapter 18, and, in 21 particular, Appendix B, which is the "Methodology to 22 Assess the Workload of Challenging Operational 23 Conditions in Support of the Known Staffing Level."

24 That's really the framework that we use to build our 25 methodology for assessing control room staffing.

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169 1 And then, the two regulations below, 2 10 CFR 50.54(m) is the current regulation on minimum 3 control room staffing. And then, 10 CFR 50.120 is, of 4 course, the training room, but, within it, the 5 particular item we are looking at is (b)(2)/(3), which 6 is the STA Training Program.

7 All right. On Topical Report purpose, 8 this Topical Report is intended to be used as an 9 alternate method for a future licensee to establish 10 minimum licensed operator control room staffing. But, 11 really, what we did was we took the regulatory 12 guidance in NUREG-0800, Appendix B, and we used it to 13 validate a safe alternative staffing plan.

14 CHAIRMAN SUNSERI: Are we there? Did we 15 lose the speaker?

16 MEMBER KIRCHNER: Doug, did we lose you?

17 CHAIRMAN SUNSERI: Whenever they drop off 18 in mid-sentence like that, that's a giveaway.

19 (Laughter.)

20 MR. SNODDERLY: So, we gained Dave Petti, 21 but we lost Doug.

22 CHAIRMAN SUNSERI: I know; it was 23 simultaneous. I wonder if there was a connection 24 there somehow.

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170 1 pause here.

2 CHAIRMAN SUNSERI: Yes, I imagine the 3 NuScale folks can reach out to the presenter.

4 MR. CHITTY: We're doing that now.

5 CHAIRMAN SUNSERI: Yes, thank you.

6 (Pause.)

7 MR. BOWMAN: Hello. I apologize. I guess 8 somebody will have to tell me where I got lost at.

9 MR. SNODDERLY: Yes, you're back, Doug.

10 We can hear you.

11 MEMBER KIRCHNER: We have you, Doug, but 12 we'll now need the viewgraphs.

13 MR. BOWMAN: Yes, I've got to get to the 14 point where I can share once again. There, you should 15 be able to see it now.

16 MR. SNODDERLY: We can see it, Doug.

17 MEMBER KIRCHNER: Yes, it's good, Doug.

18 Go ahead.

19 MR. BOWMAN: Was this the slide I dropped 20 off on?

21 MEMBER KIRCHNER: Yes, you dropped off on 22 the bullet.

23 MR. BOWMAN: Okay. Excellent. I'll just 24 go back through it again then. Okay.

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171 1 Report is we took the regulatory guidance in 2 NUREG-0800, Appendix B, and we used it to validate a 3 safe alternative staffing plan to 10 CFR 50.54(m).

4 And also, the Topical Report provides justification 5 for elimination of the STA, which is reflected in we 6 would seek exemption -- a future licensee would seek 7 exemption from 10 CFR 50.120(b)(2)/(3), in particular.

8 So, this new minimum control room staffing 9 requirement would replace guidance of either 10 CFR 10 50.54(m) or the eventual DCA staffing rule that would 11 be included whenever we get our design certification 12 rule.

13 This resulting minimum staffing would be 14 implemented in the licensee's tech specs, and the 15 staffing plan would apply to any design that could 16 meet the conditions of applicability in the Topical 17 Report.

18 So, for example, right now, of the designs 19 we know of, our current DCA design, this Topical 20 Report could be applied to. Our future STA, the most 21 accurate thing I could say is that we would need to 22 see the final design all the way through from a COLA 23 in order to determine if this Topical Report could be 24 applied to that design. So, as far as I know right 25 now, the only design that would really meet the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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172 1 conditions of applicability in this Topical Report is 2 the design certification, the DCA design.

3 And, of course, understand we intend this 4 to be used by a COLA. So, we'd really need to see 5 what a COLA wanted to do with it in order to ensure 6 that we really were meeting all the requirements of 7 the conditions of applicability.

8 All right. So, operator roles for 9 advanced designs of passively cooled reactors.

10 Did I skip a slide? Yes, I did. Okay.

11 Contents of the Topical Report. What's in 12 it? Regulatory acceptance criterion requirements; 13 conditions of applicability -- and we'll talk about 14 those -- input to staffing plans from human factors 15 engineering, a program that includes task analysis and 16 staffing and qualification analysis, and analysis of 17 the Shift Technical Advisor position. There is 18 discussion about additional staffing considerations; 19 importantly, Reg Guide 1.114, which describes the role 20 of the operator at the controls. And also, very 21 important to our staffing plan, the fact that we will 22 have a senior reactor operator who's dedicated to 23 oversight of refueling activities.

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173 1 validation trials.

2 VICE CHAIRMAN REMPE: Doug?

3 MR. BOWMAN: Yes?

4 VICE CHAIRMAN REMPE: This is Joy. Could 5 I ask a question for a minute?

6 MR. BOWMAN: Absolutely.

7 VICE CHAIRMAN REMPE: Okay. So, during 8 the Subcommittee meeting, I started to bring up in the 9 open session, but I explored it more fully in the 10 closed session, about the fact that the simulator we 11 saw in July 2019 was not configured with the design at 12 that time, and because that it was showing some data 13 to the operators that would not be present with the 14 sensors that were planned at that time. And during 15 the discussion, we explored that further and we 16 learned that, no, it still hasn't been updated to be 17 consistent with the as-planned design that was 18 currently submitted with the DCA.

19 However, I believe you assured me during 20 the closed session that the fact it was showing extra 21 data that would not be present to the operator, it 22 would not impact the results of this Topical Report, 23 as presented to the staff. And I got the impression 24 -- but I'd like you to verify -- that at some point, 25 because I only noticed one parameter that was showing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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174 1 during the visit, but I don't know if there are other 2 parameters out there.

3 So, I'm kind of curious, when do you plan 4 to do an in-depth review to say, okay, the operator 5 sees this, and, yes, indeed, assuming the sensor 6 works, the operator would, indeed, see that data?

7 Because there's been some other instances with 8 operating plants recently where they had assumed some 9 data would be displayed, and they learned the sensor 10 doesn't show that data. And so, I'm just curious, 11 what is NuScale's plan? Will it happen with the COL 12 application? Or when will you do such an evaluation?

13 And is there a regulatory requirement that you do it, 14 or is it just you're planning to do this on your own?

15 MR. BOWMAN: So, in terms of the simulator 16 and its current use as a human factors engineering 17 platform, we developed our own methodology to do a 18 validation of the simulator. It reflects a lot of 19 what ANSI-3.5 reflects. And ANSI-3.5 is the standard 20 that's used to evaluate training simulators.

21 But recognize that ANSI-3.5, the basis of 22 what you have to validate on your simulator in 23 ANSI-3.5 is absolutely based on what the contents of 24 your training program are. So, you have to ensure 25 that those items that you've taken in your training NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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175 1 program are properly reflected on the simulator.

2 There's other aspects of the simulator 3 that can be mimicked or really not show up at all, if 4 they don't impact the training. We took the same 5 avenue whenever we reviewed this for the human factors 6 engineering tool.

7 So, the only fixed place I can tell you 8 right now that we would do an evaluation like that is 9 in support of getting a simulator that we could 10 utilize for operator training for the first COLA 11 applicant.

12 VICE CHAIRMAN REMPE: And so, as part of 13 that, you will go through and say, okay -- because, 14 again, the simulators are based on some sort of 15 thermal-hydraulic (audio interference) codes, right?

16 MR. BOWMAN: Yes.

17 VICE CHAIRMAN REMPE: But they can give 18 you a lot more data than what instrumentation can give 19 you.

20 MR. BOWMAN: Sure. Absolutely. Yes.

21 VICE CHAIRMAN REMPE: And you will do a 22 very thorough check to make sure that what's given to 23 the operators will, indeed, be present in the plant?

24 MR. BOWMAN: Yes. Of course.

25 VICE CHAIRMAN REMPE: Okay. Thank you.

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176 1 MR. BOWMAN: Yes.

2 All right. Any other questions while 3 we're here?

4 (No response.)

5 All right. Operator roles for advanced 6 design passively cooled reactor. The NuScale HFE 7 analysis is focused on how operator roles are changed 8 for our advanced design passively cooled reactors.

9 A big part of this is engineering design 10 improvements that we have made across the entire suite 11 of engineering safeguard features for the NuScale 12 plant. All of our engineering safeguards are very 13 simple and they rely on either passive or failsafe 14 design elements.

15 These engineering advances have resulted 16 in the NuScale plant having fewer critical safety 17 functions to monitor than a traditional, large light 18 water reactor. Additionally, there are only a small 19 number of important human actions for beyond design 20 basis events that come from the PRA analysis, and 21 these can be accomplished by a single operator working 22 from the main control room.

23 So, the second piece of this, control room 24 design advances, they result in lower crew workload 25 and significantly improved situational awareness. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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177 1 control design at NuScale includes a central operator 2 interface in the main control room that includes a 3 display and trend monitoring for up to 12 units in a 4 single location. So, this reduces the need for the 5 operator to navigate through multiple unit interfaces 6 to view operational parameters.

7 We have automatic and continuous critical 8 safety function monitoring and a tiered audible and 9 visual operator notification scheme that provides at-10 a-glance assessment and understanding of all emergent 11 plant issues. And we also provide direct linkage 12 within the HSI to the procedures that will address 13 those conditions.

14 And then, the third piece of this is 15 really the decades of industrywide improvements in 16 operator license training. It is increased operator 17 readiness with specific relevance to operation of the 18 facility.

19 And I'm going to walk through those 20 improvements. We have another slide that outlines 21 those improvements, because they also apply to our 22 request to eliminate the STA position.

23 And then, finally, all of our initial HFE 24 trials have shown that operators have a very high 25 situational awareness, very low workload, and large-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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178 1 term time margins in task completion in this plant 2 design. And that includes the work we did in the 3 original staffing plan validation, the integrated 4 systems validation, and some additional informational 5 internal tests we performed as well.

6 MEMBER BALLINGER: This is Ron Ballinger.

7 Can I ask a question?

8 MR. BOWMAN: Sure.

9 MEMBER BALLINGER: You've conclusively 10 shown that your operators have very high situational 11 awareness. You haven't shown that a potential 12 customer's operators have very high situational 13 awareness. How are you going to bridge that gap, if 14 you can?

15 MR. BOWMAN: So, I would certainly say 16 that our training programs, at least the training 17 programs I'm familiar with and the one we're putting 18 together for NuScale, would assess an operator's 19 ability to maintain situational awareness. Certainly, 20 we train and provide operators with tools to allow 21 them to maintain situational awareness, but we also 22 evaluate those conditions in the simulator. It's 23 certainly not the same format, but we absolutely, in 24 my experience as a trainer and a training supervisor, 25 we absolutely focused on operators understanding what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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179 1 the current status was. That really shows up in the 2 current industry with the use of interim briefs, for 3 example, and other things that are used to make sure 4 the entire crew knows everything that's going on in 5 the plant at a given time. So, I would expect that 6 our training program that's developed would include 7 those aspects of maintaining situational awareness for 8 future NuScale operators.

9 MEMBER BALLINGER: So, again, what you're 10 banking on is that, if a reactor operator can pass the 11 NRC test, the reactor operator exam, that that's 12 sufficient qualification to enter your training 13 program?

14 MR. BOWMAN: Well, I certainly wouldn't 15 phrase it that way. To enter our training program --

16 well, to get to the point of having an exam, they 17 would have to go through our own testing, and we would 18 then -- a future licensee would have to go through 19 their own testing and ensure that that operator is 20 ready to take their exam.

21 But I'm talking about continued evaluation 22 and continuing training afterwards as well. It's not 23 just the initial training program or the initial 24 license. It's the continuing training, especially 25 where you ensure that the operators can maintain that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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180 1 level of situational awareness while they perform the 2 functions of the licensed operator.

3 MEMBER MARCH-LEUBA: Are you done, Ron?

4 Because I would like to follow this --

5 MEMBER BALLINGER: Yes, I'm just trying to 6 make the connection between operating a single plant 7 and operating 10 or 12 with the same staffing or less.

8 Thank you.

9 MEMBER MARCH-LEUBA: So, this is Jose.

10 Let me bring my favorite point once more.

11 The reason three operators can handle 12 12 plants is because NuScale has developed a beautiful 13 user interface, really good. My question to you is, 14 have you considered -- what steps are you going to 15 perform to ensure that the computer maintains 16 operational awareness properly; it does not get 17 confused? That you have not made errors in the 18 software of logic or built-in errors, like personal 19 screens, when you get into a situation in which you 20 have not tested because you have two hardware 21 failures.

22 What steps will you take to ensure that 23 the control room -- I'm not talking about the 24 simulator; I'm talking the real control room -- the 25 computer knows what the state of the plant is and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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181 1 provides information to the operator that is correct 2 and accurate?

3 MR. BOWMAN: So, I'm certainly not as 4 familiar with our requirements for software, but we do 5 have a wide range of QA requirements that are 6 associated with software. So, that software has to be 7 tested and validated to ensure it meets its required 8 function. And that's part of a rather extensive 9 program to ensure software integrity and ensure that 10 any installed updates, the original installation or 11 any installed updates, would meet those requirements 12 and would be safe and secure from the standpoint of 13 cyber security and in terms of integrity in terms of 14 its function to perform in the plant.

15 MEMBER MARCH-LEUBA: Let me give you two 16 counter examples. When we were last July -- or was it 17 two years ago? -- we had a tutor there, but the 18 operator's console froze. It went black and had to 19 reboot. Obviously, that software had problems. It 20 should not have passed the QA requirements. And I 21 realize it was not production level. So, what I'm 22 asking you is, what procedures, what staff review, are 23 you going to have to ensure that that doesn't happen 24 during a LOCA, a real plant event?

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182 1 apologize for bringing this up -- but I'm sure Boeing 2 has more software engineers than you have and spend 3 two orders of magnitude more money doing the 737 Max, 4 and so forth. And the computer decided to push the 5 nose of the plane down. Okay? What assurance do we 6 have that your computer won't tell the operator to 7 push the nose of the plane down?

8 I'm sensing from you too much confidence 9 and for the operators too much overreliance on the 10 computer. That's my two dimes, and you don't need to 11 answer that. I've put this on the record many times.

12 I hope you mix it into the letter.

13 Thank you.

14 MR. BOWMAN: Thank you, Jose.

15 Okay. I understand your question. It's 16 not one that I personally can answer, but there is a 17 -- I guess I'll take a stab at it.

18 So, I talked a little bit about software 19 QA, but the piece of the program is that all of our 20 safety functions run off of the HIPS platform, which 21 has been previously reviewed by the ACRS and the staff 22 in a Topical Report. And that HIPS architecture is 23 the one that ensures that we maintain safety in the 24 plant. And that's separate from the software that we 25 are talking about that runs the human-system interface NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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183 1 and the control system.

2 Okay.

3 MEMBER MARCH-LEUBA: So, why do we buy 4 into have three operators in the room? You're saying 5 we don't even need them?

6 MR. BOWMAN: Because that's our accepted 7 staffing plan. That's our accepted staffing plan.

8 MEMBER MARCH-LEUBA: So, they perform 9 functions.

10 Okay. Go on.

11 MR. BOWMAN: Yes, they do perform 12 functions.

13 MEMBER KIRCHNER: Yes, Jose, I think the 14 important thing in Doug's response here is that 15 there's an independent way to shut down the plant and 16 get it in a safe shutdown condition. That's different 17 from the economics of operational reliability and 18 such. I think you need the operators there for both 19 purposes. But, as Doug pointed out, you want to make 20 sure that independent HIPS system provides those 21 necessary protection functions.

22 MEMBER MARCH-LEUBA: The protection system 23 provides protection for the first two or three seconds 24 on any transient; some of those transients it may be 25 longer. After that, the operator takes control of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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184 1 plant and he's supposed to do the right things. And 2 the plant is already shut down and you're on decay 3 heat. I can think of hardly no accident in operating 4 plants that happens where the control rods are out.

5 All of the problems happen after the control rods are 6 in.

7 MEMBER PETTI: Okay, but I'm confused.

8 Can NuScale please clarify? Operators do not have to 9 do anything for a certain amount of time following 10 safe shutdown? Isn't it 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />?

11 MR. BOWMAN: Within the design, yes, that 12 is --

13 MEMBER PETTI: Within the design basis?

14 MR. BOWMAN: Correct. I also --

15 MEMBER PETTI: I don't understand this 16 line -- let me just finish -- I don't understand this 17 line of arguing. It's an argument; I understand that.

18 But if there were 12 people in the control room and 19 the computer crapped out, it wouldn't make a -- you 20 know, how is that different if three people are in 21 there? That's an issue about the reliability of that 22 system, which is an important question, but it seems 23 somewhat of orthogonal to what we're talking about 24 here.

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185 1 would you care to explain to me what those three 2 operators were doing during the HRA testing that this 3 report documents? They were just tweaking their 4 thumbs? They were not doing anything? The plant was 5 melting and they were not doing anything? Because one 6 of the tests involved a core uncovering.

7 MEMBER PETTI: The tests were outside the 8 design basis.

9 MEMBER MARCH-LEUBA: Right. So, the 10 operators were needed and we're taking credit for 11 them. Okay. I'll give up this line of --

12 MEMBER PETTI: That's fine. I understand.

13 MEMBER MARCH-LEUBA: Obviously --

14 MEMBER PETTI: You were talking about 15 events beyond the design basis, is what you meant in 16 your question?

17 MEMBER MARCH-LEUBA: I'm talking about 18 design basis. I'm talking of why are the operators 19 there. And are the operators being advised by 20 computer software that, apparently, has some QA, but 21 my experience is not that very good. Okay.

22 MR. BOWMAN: Okay. I'll continue on. All 23 right.

24 So, I just went through and we talked 25 about the initial set of human factors engineering NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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186 1 evaluations that we did; staffing plan validation; 2 integrated systems validation, and some of the 3 information on internal tests, we did to look at some 4 of our proposed staffing.

5 Following that, we did a revised control 6 room staffing, which is what the Topical Report of 7 interest that we're talking about. This revised 8 control room staffing included two senior reactor 9 operators and one reactor operator. We used the same 10 methodology for the original staffing plan validation 11 and the revised staffing plan validation, and there 12 were some minor differences. And those are described 13 in the revised staffing plan validation test report.

14 So, based on the information and data 15 obtained from those initial efforts, we decided that 16 we could operate in a more optimal format the staffing 17 we're talking about. So, I'll walk through a little 18 bit about what the roles and responsibilities are.

19 There are two SROs and one RO. One of the 20 SROs must assume the command and control of the 21 control room, the control room supervisor position.

22 The other two operators -- one of them, at a minimum, 23 an SRO and one an RO -- would take the roles of RO1, 24 which is the lead role to monitor the plant and 25 perform initial assessment and triage of possible off-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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187 1 normal conditions. And the other operator addresses 2 plant evolutions requiring more time and backs up and 3 assists the other two operators. Additional staffing 4 can, of course, be called in to support planned higher 5 workload periods.

6 The data we got from the revised control 7 room staffing remained in line with our earlier tests.

8 Task performance was successful. We had large margins 9 at the completion of the timed activities. We had low 10 workload scores. Even when measured workload reached 11 relatively higher levels, task performance was not 12 negatively affected during the scenarios. And we had 13 high situational awareness scores. Notably, scores 14 remained high during the peaks in measured workload, 15 demonstrating the test participants maintained 16 awareness of plant conditions, even during challenging 17 conditions.

18 All right. So, that really is our slides 19 that cover the revised control room staffing. We're 20 going move on now and talk about the Shift Technical 21 Advisor position.

22 The Shift Technical Advisor position was 23 established after the TMI-2 as a temporary role until 24 the qualifications of the man-machine interface were 25 upgraded, as explained in the NUREG-0737, the TMI NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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188 1 Action Plan Requirements.

2 During discussions with the NRC staff and 3 during previous ACRS subcommittee meetings, there was 4 discussion and acknowledgment that the NRC licensing 5 actions had occurred later over some time to formalize 6 the position. None of those actions, however, have 7 addressed this wording in the NUREG about how the 8 position may be retired.

9 And our NuScale Topical Report explains 10 the upgrades of the operator training and the man-11 machine interface in the NuScale design that have 12 allowed for us to sunset the STA position. Those 13 upgrades for the Shift Technical Advisor include 14 upgrades to the licensing of the -- the training of 15 the licensed operators.

16 Following the issuance of the TMI Action 17 Plan, training of operators was upgraded by the 18 industry as a whole, and these include:

19 Those training programs must be developed 20 using a systems approach to training, as required by 21 10 CFR Part 55.

22 They include generic fundamentals of math, 23 physics, thermodynamics, and component design topics 24 that are of specific relevance to the operation of a 25 nuclear power plant.

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189 1 Training for mitigating core damage, a 2 very important aspect of this.

3 Plant-specific training, including plant 4 systems; plant-specific reactor technology, including 5 core physics data; plant chemistry and corrosion 6 control; reactor plant materials; reactor plant 7 thermal cycle; transient and accident analysis, and 8 emergency procedures.

9 Completion of this training is required by 10 NUREG-1021, and specifically delineated on Form 398, 11 Personal Qualification Statement for the Licensee.

12 It is important to note that, from this 13 list, only a specific commercial nuclear power plant 14 training program would be guaranteed to include all 15 these elements for mitigating core damage. Plant 16 systems, plant-specific reactor technology, transient 17 and accident analysis, and emergency operating 18 procedure training could only be acquired at a plant-19 specific training program.

20 Also note these training requirements are 21 also repeated in the topical section of Report 1.5 as 22 part of the conditions of applicability for use of 23 this alternate staffing plan.

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190 1 the industry as a whole to comply with NUREG-0737 2 provide a specific list of the elements, the 3 engineering expertise that are germane to operating a 4 commercial nuclear power facility.

5 NuScale control room upgrades. So, our 6 HSI features that provide an at-a-glance assessment of 7 plant conditions and facilitates early detection of 8 degrading conditions. We've provided condensed and 9 easily viewable overview screens, safety function 10 displays. We allow for ease of navigation and a 11 universal display of all active processes. Anybody 12 with a human-system interface display can see all 13 active processes in the control room at that time.

14 Safety function monitoring is integrated 15 into the man-machine interface. Our emergency 16 operating procedures are embedded in the interface and 17 directly link to the safety functions. And we also 18 provide for active monitoring of emergency action 19 levels in the emergency plan.

20 And this, again, is all required by the 21 conditions of applicability for the report.

22 Additional considerations for NuScale 23 power plants. This is repeated from earlier points, 24 but are worth reiterating here, as they pertain to 25 sunsetting of the STA position for this plant design.

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191 1 It includes advances in design features 2 that reduce the need for additional oversight. The 3 use of passive safety features and lower operational 4 complexity have resulted in no operator actions for 5 design basis events, as well as an improvement in 6 overall safety.

7 The design only has two important human 8 actions associated with beyond design basis events 9 that have a very small probability of occurrence.

10 Both are simple, straightforward actions that can be 11 completed from the main control room, and they also 12 have large time margins to complete tasks that 13 historically would need to be completed without delay.

14 All right. I know I showed this slide 15 last time, too, but we're going to go ahead and look 16 at it again. So, again, showing two pictures. I'm 17 going to provide a little bit different view of this 18 this time.

19 The top is a plant I'm very familiar with, 20 D.C. Cook's Unit 1 control room simulator. The bottom 21 is the NuScale control room simulator.

22 We provided a real and positive impactful 23 upgrade that occurred when we considered the 24 capabilities of the NuScale HSI. One piece that I 25 don't think I did a good enough job of relaying last NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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192 1 time, we utilized the experience of the former 2 operators that participated in the design of the 3 NuScale HSI, and we addressed those items that our 4 experience told us were most impactful to how an 5 operating crew performs.

6 And the example I'll give you is one 7 that's very, very appropriate for Cook. Cook, when I 8 arrived in 1999, had a very archaic annunciator 9 system. There was well over 1,000 alarms in the 10 control room, alarm tiles, and there was no way to 11 silence the alarms outside of acknowledging every 12 alarm that was in at the time. So, after a trip, you 13 would have between 500, maybe a third to a half of the 14 alarms would be in, and operators had to walk around 15 the room and depress each tile that was lighted with 16 an alarm in order to silence that alarm.

17 So, that, to me, was a very important 18 aspect of what we addressed at NuScale. And we have 19 done a very good job of addressing alarm avalanche in 20 this design. We provide for a tiered alarm system, so 21 that not everything that shows up as an operator 22 notification has an alarm sound with it. It is 23 provided to the operator on an appropriate level and 24 allows them to address it as it's prioritized. So, we 25 do that prioritization work for the operator. They NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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193 1 can, then, address those things that are truly alarms 2 in a NuScale plant or those things that truly have 3 operator actions associated with them.

4 So, with that, I will move on to the next 5 slide, which is questions. Are there any further 6 questions?

7 MEMBER MARCH-LEUBA: No, but there are 8 some comments.

9 What confidence can you give me that that 10 alarm prioritization system will work as designed in 11 the presence of some hardware failures? I mean 12 instrument errors, routers freezing, signals out of 13 timing. That's what I was talking about, the computer 14 being aware of the situation. The computer needs to 15 know what the true state of the plant is to be able to 16 filter those alarms.

17 And I'm not hearing the answer I want to 18 hear. It is we are going to have a thorough and 19 exhausting search and verification to ensure that the 20 computer is doing the right thing. You're telling me, 21 "Aw, it's not important."

22 So, please, elaborate more. I mean, 23 what's the probability in terms of PRA that the alarm 24 filtering will mess up?

25 MR. BOWMAN: Well, that's certainly not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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194 1 something that PRA evaluated. We provide for network 2 monitoring of the system, and part of the system's 3 network monitoring would ensure that all of the 4 communications are appropriate. If that separate 5 network monitoring item detected a problem, it would 6 enunciate it to the control room. If that problem was 7 to the point where you had a frozen control system, we 8 would place the plant in a safe condition, meaning we 9 would trip and ensure that decay heat removal was in 10 service. And then, we would go back and stay in that 11 condition until we had repaired the control system.

12 MEMBER MARCH-LEUBA: But you are planning 13 to test all those functions, right?

14 MR. BOWMAN: Absolutely. We have an 15 extensive QA program. There's items in Chapter 14 16 that would require preoperational testing during 17 startup of a plant.

18 MEMBER MARCH-LEUBA: No, no, not 19 preoperational testing, but thorough testing of the 20 software. The fact that while I was there the 21 operator control froze and had to be rebooted doesn't 22 give me much confidence on your testing program.

23 MR. BOWMAN: But that testing program is 24 for a simulator, not for a control system.

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195 1 input control, which would be the same that we're 2 going to reveal in plant. It was the operator 3 control, the one that froze.

4 I'm just saying, I don't hear, I'm not 5 hearing from you any concern about all the problems.

6 What operating system are you using for this console?

7 I assume it's some version, some flavor of UNIX.

8 MR. BOWMAN: No. No, no. We use Windows 9 Presentation Foundation for the human-system interface 10 software. That was developed to support a simulator.

11 MEMBER MARCH-LEUBA: It's running on top 12 of Windows?

13 MR. BOWMAN: Yes, for the simulator.

14 MEMBER MARCH-LEUBA: Oh, even better.

15 MR. BOWMAN: That's not what the design 16 system -- that's not what the digital control system 17 is going to be operating as.

18 MEMBER MARCH-LEUBA: The operator's 19 console --

20 MR. BOWMAN: This is the simulator.

21 MEMBER MARCH-LEUBA: I'm asking about the 22 operator console, the three screens that are sitting 23 in front, on top of the desk of the operator.

24 MR. BOWMAN: Sure, but our plant --

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196 1 slide with the picture?

2 MR. BOWMAN: Sure.

3 MEMBER MARCH-LEUBA: So, you can see what 4 I'm talking about.

5 You see the operator? He has four 6 screens.

7 MR. BOWMAN: Yes.

8 MEMBER MARCH-LEUBA: Those are running on 9 Windows?

10 MR. BOWMAN: Yes, for the simulator.

11 That's not our, that's not our digital control system.

12 That's simulator software.

13 MEMBER MARCH-LEUBA: Yes, but in a real 14 power plant where, instead of controlling it to a 15 computer simulation, you plug it into the real 16 instruments, you will be using the same software. The 17 operator will be clicking on the same buttons and 18 using the same Windows software?

19 MR. BOWMAN: We have not selected a DCS 20 vendor yet. That is not the design -- that is not the 21 digital control system software. That's a simulator 22 that was built to emulate what would eventually be 23 our --

24 MEMBER MARCH-LEUBA: So, how have you 25 tested the performance of the operators if you do not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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197 1 perform any on a prototypical device? I mean, the 2 simulator is supposed to be exactly the same as what 3 the control room will be.

4 MR. BOWMAN: Yes, your simulator must 5 behave --

6 MEMBER MARCH-LEUBA: Okay, I'm giving up.

7 MR. BOWMAN: -- appropriately for the 8 operator.

9 MEMBER MARCH-LEUBA: I thought this was in 10 UNIX. You're using Windows. I mean, God. Okay.

11 Whew. All right.

12 CHAIRMAN SUNSERI: Jose, I don't think 13 you're getting the full story here. What he's trying 14 to tell you is the real plant will undergo a testing 15 program with the installed equipment, as we've 16 analyzed it through the Topical Reports and everything 17 that we reviewed as far as the DCA.

18 What you're looking at in this picture is 19 the simulator which is not designed or constructed to 20 those same standards, but has algorithms and models 21 that emulates what goes on in the real plant. So, the 22 fact that this thing locked up because of some problem 23 with Windows, or whatever, is completely different 24 than what will be installed in the plant, is what he's 25 trying to tell you.

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198 1 MEMBER MARCH-LEUBA: Matt, I think I 2 understand the technology better than you. The only 3 difference between a simulator and a control room is 4 that the cables at the end connect to a computer 5 instead of connecting to the plant. Everything else 6 is supposed to be the same.

7 CHAIRMAN SUNSERI: That is not accurate.

8 There's very few simulators that are built that way.

9 MEMBER MARCH-LEUBA: In the control room, 10 in the simulators I used to visit and work with, they 11 mount the actual protection system hardware on the 12 panels. So, it doesn't mount only one challenge to 13 the floor, to save money.

14 So, you're telling me that all of this 15 software that you are showing here, you are going to 16 start from scratch and reprogram it again in the 17 plant?

18 MR. BOWMAN: All I'm telling you right now 19 is we don't have a digital control room vendor 20 selected.

21 MEMBER MARCH-LEUBA: So, how do you know 22 the operator will be able to perform the functions if 23 you don't know what he's supposed to be doing, what 24 screens he's going to see?

25 MR. BOWMAN: They will have to emulate the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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199 1 screens that are there in the simulator with their 2 software.

3 MEMBER MARCH-LEUBA: Okay, I give up. I 4 give up. I mean, I understand my colleagues not 5 seeing the problem, but you don't see the problem I'm 6 talking about? Okay, I give up.

7 MR. BOWMAN: ANSI-3.5 does not require you 8 to run a design, a digital control system in your 9 simulator. It only requires that the operators that 10 the operator's interface is the same --

11 MEMBER MARCH-LEUBA: I'm talking about the 12 operator interface.

13 MEMBER KIRCHNER: We have somebody who has 14 an open mic.

15 Okay. Go ahead again, Doug.

16 MR. BOWMAN: So, ANSI-3.5 does not require 17 you to run the digital control system or the human-18 system interface software in the simulator; only that 19 what the operator experiences matches what he would 20 see in the real plant. That's the way ANSI-3.5 works.

21 That's the way training simulators can work.

22 MEMBER MARCH-LEUBA: And so, your 23 expectation, then, is all of this software you have on 24 all those 150 blue screens I see in the picture, 25 you're going to throw it away, and then, start from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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200 1 scratch when you build your first module?

2 MR. BOWMAN: For a design? For the 3 digital control system?

4 MEMBER MARCH-LEUBA: No, no, no. For the 5 displays and the user interface. There are things 6 that the operator clears with his mouse on those four 7 screens in front of him. All of that software, you're 8 going to throw it away and start from scratch?

9 MR. BOWMAN: We'll be using it for the 10 simulator.

11 MEMBER MARCH-LEUBA: No, no. Imagine this 12 is the real control room. It would look exactly the 13 same. Correct?

14 MR. BOWMAN: Yes.

15 MEMBER MARCH-LEUBA: I mean, yes, okay.

16 And the software that is running on those four screens 17 that the operator has his mouse on, who's going to 18 develop that? You want him to use the one he uses --

19 MR. BOWMAN: We don't know yet. We 20 haven't selected a vendor yet.

21 MEMBER MARCH-LEUBA: And what testing are 22 you going to do on that? You're not going to use this 23 one?

24 MS. JOERGENSEN: Jose, this is Nadja 25 Joergensen. Can I step in here?

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201 1 MEMBER MARCH-LEUBA: Yes.

2 MS. JOERGENSEN: The simulator design is 3 outside of the scope of this, and we're here to 4 discuss the operators and the operating staffing. So, 5 we're not prepared to discuss this any further.

6 MEMBER MARCH-LEUBA: Okay. At least 7 that's an answer that I can understand.

8 MEMBER KIRCHNER: But I think we shouldn't 9 let it drop just there, Jose. Matt was onto where I 10 would have answered, and I think Doug was trying to 11 answer. It's that, when you get to the COLA, they are 12 going to have to build out the actual digital control 13 room and they haven't selected the vendor yet.

14 How much of this functionality is 15 recycled, I think it would be hard to say at this 16 point. But, for the purposes of the review of this 17 Topical Report, the expectation I think has to be that 18 the actual control room and the simulator that's used 19 be high-fidelity representation of what the actual 20 build is for purposes of training and such. And at 21 that juncture, then, they would have to verify the 22 qualifications and the functionality, et cetera, with 23 this staffing plan, as part of the acceptance criteria 24 for the actual plant.

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202 1 demonstrate is that, from a workload -- and it's more 2 than just workload -- but from a workload standpoint, 3 that the plant can be, a 12-module plant could be 4 safely operated and securely shut down under a wide, 5 you know, as per the FSAR.

6 So, I think at this point that's really 7 the focus here for us. Is this feasible? Are there, 8 will there be in the actual plant the functionality 9 and capability to achieve this safe shutdown?

10 So, I'm kind of looking at it right now 11 not as a software qualification set of issues, but 12 that, I think, comes when you actually build out the 13 actual plant and the simulator that's used to train 14 the operators.

15 CHAIRMAN BLEY: Walt, can I turn your 16 words around just a little bit?

17 MEMBER KIRCHNER: Yes, go ahead, Dennis.

18 CHAIRMAN BLEY: To use this Topical 19 Report, if it's approved, they're going to have to 20 prove that their actual plant delivers the same 21 information in the same ways to the operator as was 22 done with the simulator during the test programs. If 23 they can't do that, they've got to redo the testing on 24 the actual kind of system that's running.

25 But I was thinking back to Jose's first NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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203 1 questions, and I was left a little cold on the answers 2 about why you've got three people in the control room, 3 and if you had an STA, what that role would be, and if 4 you don't have the STA, how the existing operators out 5 of the three will fulfill that role.

6 One of the things that was discussed is, 7 if we start having problems in the computer system 8 that drives this plant and drives the operator 9 interface, and it isn't detected by the software 10 oversight systems, how do the operators identify that?

11 And I would hope that, when you run drills, they 12 include drills that have problems, not complete 13 failure, but problems in that interface that the 14 people have to detect, and then, work around. If 15 you're not doing that, we aren't getting to see how 16 the current set of operators, or in the previous 17 tests, the set of operators that were there with the 18 STA, are dealing with those kind of problems and what 19 they're about.

20 When we were at the site, there was some 21 explanation of what the roles are of all three people 22 and what they're doing. And, I mean, none of that 23 came across today. So, that was my comment on the 24 discussion we had earlier.

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204 1 the three operator roles very quickly. And I 2 recognize Jose's question is, if we don't need the 3 operators within the design, what do we need them for, 4 or at least that's the way I would restate it.

5 So, the operators are there to address 6 beyond design basis conditions. So, the examples of 7 the two important human actions, they have to perform 8 those. They are there to ensure that the appropriate 9 emergency plan stakeholders would be notified in the 10 case of an emergency to take appropriate, either 11 protective actions or, certainly, from the standpoint 12 of communication of emergency plan status. That's 13 another important role for them to do. And they're 14 there to ensure that we can economically operate the 15 plant.

16 And so, that's really the roles that I can 17 come up with for the operators because they really 18 don't serve a function within the design. The design, 19 our safety case is predicated on the fact that, as we 20 discussed earlier, our engineered safeguard featured 21 are simple, passive, and failsafe, or I should say, 22 "or failsafe."

23 And so, I guess the last role for the 24 operators, then, would be the fact that they would 25 want to ensure, if a design basis incident/accident NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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205 1 occurred, that the appropriate safety functions did 2 occur. So, that would be another role for them.

3 So, is that what you're after? Or is 4 there something different?

5 CHAIRMAN BLEY: There's something more.

6 And the something more is, if the system doesn't 7 operate the way you expect it to operate, the 8 operators should be able to identify that, diagnose 9 what's going on, and save the day, if you will.

10 MR. BOWMAN: So, when you say, "save the 11 day," what are you -- so, if we had a major 12 malfunction of the control system, our intention is 13 the operators will place the plant in a safe 14 condition, and then, stay there until --

15 MEMBER KIRCHNER: Well, that's the answer 16 I'm looking for, Doug.

17 (Laughter.)

18 MR. BOWMAN: Yes.

19 MEMBER KIRCHNER: For example, where 20 Dennis was going, I was going as well in my own mind.

21 Going back, for example, if we could, to just one of 22 Jose's concerns, you know, to avoid alarm avalanche, 23 you have the computer deciding the priority of these.

24 I would expect that you would tell me that the Shift 25 Supervisor would be overlooking, say, a loss of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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206 1 functionality of that control system and the displays, 2 and then, have the responsibility to, then, direct the 3 operators to shut the plant down, or whatever 4 response, in light of loss of large, say, a loss of a 5 large part of the functionality of the display system.

6 MR. BOWMAN: Yes, we do do that. They do 7 do that. We do demonstrate that. Certainly, the 8 malfunction we've used in the past is the fact that 9 the system displays network traffic that's 10 inappropriate, and then, we have this network traffic 11 monitor that enunciates to the control room and tells 12 them that your control systems failed and you need to 13 take appropriate actions. But those actions are 14 identical to evacuating the control room as well. We 15 would take the same actions if we were going to 16 evacuate the control room as well.

17 It's really a loss of the ability to 18 control the plant, right, either way? Either I can't 19 stay in the control room or I no longer have 20 significant control over the plant. Then, the 21 operators will be expected to place the plant in a 22 safe condition.

23 CHAIRMAN BLEY: Well, let me take you back 24 to something that is in the older plants that you've 25 worked with. And we've seen a number of plants that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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207 1 rely heavily on instrument error. And we've designed 2 the system, so if the instrument error, one train of 3 it drops to zero pressure, everything fails safe.

4 Then, it works great. And the people know what's 5 going on.

6 But we've had occasions where 7 contamination or very slowly degrading pressure have 8 occurred in those systems, and they don't fail in the 9 on/off way. They start going down gradually and 10 equipment that depends on them starts failing at 11 various points in time.

12 And we've seen the same kinds of things 13 with instrument ACE power. And those get very 14 confusing for operators and they're much harder to 15 spot. If, when you run people through a drill on a 16 problem with the interface, it just goes blank, well, 17 that's easy; you've got a solution for that. But if 18 it's failing in more subtle ways or not all at once, 19 that's a much tougher problem for operators.

20 And my point earlier was I hope you run 21 simulations like that to get people thinking about 22 these various ways things can go wrong.

23 MR. BOWMAN: Right. But, for example, to 24 address the conditions you discussed in the past, you 25 know, plants came up with clear lines in the sand.

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208 1 So, the plant I'm most familiar with, Cook, if you got 2 below 80 pounds in instrument air pressure, you 3 tripped the unit because you knew that there was other 4 things that happened below that. So, instead of 5 trying to continue to ride out that and investigate 6 and diagnose that condition, we set clear lines in the 7 sand for the operators to take those actions.

8 And the same thing happened with 9 electrical power, right? We wound up and we built the 10 graded voltage relays to address those conditions, 11 instead of having operators trying to assess what's 12 going on during a degradable condition.

13 CHAIRMAN BLEY: Yes, we do, and that's 14 because we had had experience with those things. We 15 haven't had experience with this system, and there 16 will be some kinds of failure modes, a failure mode 17 less obvious, and that's kind of where I've been 18 coming from: how do we get the operators trained to 19 look for situations where the system isn't working the 20 way they thought it would?

21 MR. BOWMAN: So, I guess I would at this 22 point have to fall back on the fact that we have a 23 systematic approach to training, and the operators --

24 you know, we will do an evaluation of all these 25 systems. Sure, the control systems are new, but we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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209 1 would have to evaluate and build training programs 2 that would address the control system and its failure 3 modes and effects.

4 MEMBER BALLINGER: This is Ron.

5 I'm sitting here understanding that what 6 we have here is a difference between two world views.

7 With respect to the 737 issue, that was a combination 8 of a design problem where you had a single point of 9 failure that could kill you. But notice that pilots 10 that were trained in the U.S., when presented with the 11 same problem that caused the death of several hundred 12 people outside of the U.S., they saw that that problem 13 was no problem; they dealt with it.

14 In the case of the other pilots, which 15 nominally had the same kind of training, they did not 16 react in a way that solved the problem. So, there's 17 that issue.

18 You know, we've got a system here which 19 represents the best technology that exists today, 20 much, much better than we've had in the past, and 21 that's the good news. The bad news is that we now 22 have a technology that's much, much better than we've 23 ever had in the past. And what we're doing is we're 24 going to offload -- by your own words, you don't need 25 the operators. Well, that may be true; you don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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210 1 need, you may not need the operators. And so, what 2 you're effectively saying is, we don't need the 3 operators, but we have a darn good ejection seat. In 4 other words, the safety system has got to work.

5 MR. BOWMAN: I wholeheartedly agree with 6 your assessment.

7 MEMBER BALLINGER: And it's a problem.

8 They've had several aviation accidents, by the way, 9 where the operators of the airplane -- and I won't 10 even call them "pilots" because they're, basically, 11 computer operators -- followed the computer right into 12 the side of the mountain. So, again, they didn't have 13 an ejection seat. You guys do have an ejection seat.

14 MR. BOWMAN: Yes, I agree.

15 MEMBER KIRCHNER: Members, are there 16 further questions of Doug and the NuScale team?

17 MEMBER BALLINGER: Gosh, the fact that he 18 just made a comment like that has left everybody 19 speechless.

20 CHAIRMAN BLEY: Yes. A little parable.

21 I really like The Hitchhiker's Guide to the Universe.

22 Do you remember that? Did you read it? Somewhere in 23 the third or fourth volume there was a major disaster 24 that killed millions of people. And when they tracked 25 it down, it came to a little widget on the inside of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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211 1 something that controlled their air conditioning 2 systems. But when they finally figured it all out, 3 what they required people to do was, whenever you 4 designed something, you had to write these words on 5 what you designed: "The only difference between 6 something that can fail and something that cannot 7 possibly fail is, when the thing that cannot possibly 8 fail fails, it's a real disaster."

9 So, that's kind of where this stuff is 10 coming from. You would always use this wonderful 11 system, and we'll assume that it will work when you 12 get it in the real configuration, but you've got to be 13 looking for cases where it isn't working right.

14 That's all we were getting at.

15 And I'll be quiet, and Greg's wanting to 16 talk.

17 MEMBER KIRCHNER: Yes, I think Greg had 18 his hand up. Go ahead, Greg.

19 MR. HALNON: Thank you.

20 It's been a long time since I've seen the 21 simulator. I have just a couple of questions and it 22 shouldn't take too long.

23 Back to the STA issue -- and I recognize 24 the simpler design and the older regulatory aspects of 25 being able to replace the STA position with a Shift NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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212 1 Supervisor or someone else who has the requisite 2 training -- through the years when I've been in 3 transients, I've relied pretty heavily on the Shift 4 Technical Advisor or someone else that is independent 5 of the actual implementation of the procedures to 6 ensure that we're doing the right thing and that we 7 haven't missed something.

8 And in a lot of cases the computer can 9 compensate for some of those things, and I think 10 that's probably where you guys are talking to.

11 There's a couple of things. One is you have 12 12 reactors. You have a new technology. You have other 13 things that have to be done by operators, coordinating 14 response outside of a control room, and other things.

15 I'm assuming that, with this Topical 16 Report, which I have not read -- so, forgive me for 17 that -- but this is just really looking at the minimum 18 staffing and not what actual staffing will be from an 19 operations perspective, maybe not licensed operators, 20 but there's got to be some consideration of the other 21 things that need to get done outside of accident 22 conditions as well.

23 So, is that accurate? I mean, we're not 24 really talking about minimum staffing that's going to 25 be there all the time, but the operation staffing is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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213 1 probably going to be a little bit more robust than 2 just three or four operators?

3 MEMBER KIRCHNER: Do you want to answer 4 that?

5 One of the points you made, Greg, is that 6 they will -- and I think this is a requirement of 7 10 CFR 50 -- I'm forgetting the numbers right now.

8 They would have an SRO on the plant floor for any 9 refueling operations and evolutions. That's one 10 example of additional shift being available.

11 My understanding, Doug, is that you would 12 have a number of other operational staff outside the 13 control room for the balance of plant as well.

14 MR. BOWMAN: So, to address his question, 15 yes, this Topical Report merely addresses the minimum 16 staffing, as defined in the tech specs. So, that's no 17 different than the current plant. As I think I've 18 stated before, in my experience at Cook, our minimum 19 staffing was four ROs. Well, you almost always had a 20 fifth RO. Could you operate with four? Sure, but you 21 almost always had a fifth. And we had administrative 22 requirements that required you to have an additional 23 SRO on staff, and that was required. That wasn't part 24 of your tech specs. That was an administrative 25 requirement.

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214 1 So, all we're trying to do is define bare 2 minimum staffing to ensure the plant could be safely 3 operated, as defined in tech specs. That's what the 4 Topical does.

5 MR. HALNON: And that's what I suspected.

6 Yes, that's what I suspected, Doug. Thanks.

7 The other question is, in the present tech 8 specs, for many of the operating plants there's a 9 provision for, if you go less than minimum staffing, 10 you have a certain amount of hours to get somebody in.

11 Whether that's by calculation or guess, I'm not sure.

12 But, for instance, if somebody had to call off sick or 13 somebody had to leave because of a family emergency, 14 we had two hours to get another person to fill that 15 minimum. Have you guys done an analysis to see how 16 long it is adequate to wait for somebody to come in 17 when you're less than minimum staffing?

18 MR. BOWMAN: Yes, we're doing the same 19 thing. And honestly, the idea that we're having two 20 SROs and one RO reflects that as well. Because we 21 would never lose a function with loss of a single 22 person, right. We've always got at least one SRO and 23 one additional operator in the plant. So, we never 24 lose the SRO function with the way we've defined our 25 minimum staffing. We use the two-hour limitation as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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215 1 well to restore the three-person minimum staffing.

2 MR. HALNON: Okay. The last question, 3 what struck me when I saw that picture was just the 4 amount of blue light. Is there a study or any kind of 5 concern of the long-term physiological effects of just 6 being flooded with blue light 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a day for three 7 or four days a week for a year or more? I mean, is 8 there any problem with that?

9 MR. BOWMAN: We actually selected the 10 colors based on input from human factors engineers.

11 Some of our early screens -- I was trying to get back 12 to the picture, but, for some reason, my Adobe has 13 frozen. That darker color, it's not really blue. It 14 kind of shows up blue in the picture. It's actually 15 more like a black. It actually works better in terms 16 of not overloading the eyes. Some of our earlier 17 screens had a lot of white in them, and that wound up 18 being very bright and kind of fatiguing after a while.

19 So, this is actually, the colors are actually selected 20 to minimize eye fatigue.

21 MR. HALNON: Is there any medical studies 22 or anything that says that the long-term exposure to 23 that, I mean, the screen light -- I mean, you have a 24 tremendous amount of screens in there. Back when we 25 were little, mommy always told me to stay away from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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216 1 the TV set. She would have a heart attack if she saw 2 me in this place.

3 MR. BOWMAN: I can only say we're not 4 using cathode ray tubes anymore.

5 (Laughter.)

6 MR. HALNON: Yes, I guessed that.

7 MR. BOWMAN: So, like I said, what we 8 really got, we got from our human factors engineers in 9 terms of colors, interestingly enough, and they really 10 pushed us toward the darker colors rather than the 11 lighter colors we had seen in some other designs. So, 12 I can't really answer the medical piece.

13 MR. HALNON: Yes, I'd be interested to see 14 if there's any studies out there for long-term 15 exposure to screen light that is that intense. It 16 just seems very intensive to me at this point. But 17 that's probably another topic at another time.

18 Thanks.

19 CHAIRMAN BLEY: Just to follow up on that, 20 I hadn't thought about that one, Greg. That's good.

21 During your development work and your testing, did you 22 ever go through periods where people had to spend six 23 or eight, or longer, hours in that control room 24 lockup?

25 MR. BOWMAN: We actually did, during NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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217 1 integrated system validation, we did what we 2 colloquially call "a day in the life of an operator."

3 So, there was, essentially, a full-shift coverage for 4 that, and we didn't --

5 CHAIRMAN BLEY: And did you have any 6 problems?

7 MR. BOWMAN: We didn't note any problems, 8 but it was only one day.

9 CHAIRMAN BLEY: Oh, just once?

10 MR. BOWMAN: Yes.

11 CHAIRMAN BLEY: Okay. That wouldn't do it 12 probably. Okay.

13 MEMBER MARCH-LEUBA: Hey, I was very 14 negative earlier. Let me try to put my case a little 15 more succinctly.

16 I have no issue with the staffing. In my 17 mind, it's whether it would require zero or one 18 operator because three is an overkill with this user 19 interface. My concern is that that conclusion is 20 conditional with the computer operating as advertised.

21 And I don't see much effort being planned to make sure 22 the computer runs as advertised. Okay? Maybe that 23 puts my concern more clearly.

24 MR. OSBORN: This is Jim Osborn.

25 I think, as Doug has alluded, part of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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218 1 these questions cover into Chapter 7 and the software 2 and the logic, and whatever. And that has all been 3 reviewed and approved. And so, the actual 4 implementation of the software V&V and the software 5 testing, as it's developed by both the vendor and the 6 installation at the plant, will go through all the 7 required testings and validations, in accordance with 8 the DCA, particularly, like I said, Chapter 7.

9 So, I think that whether you had three 10 operators or 10 operators, it wouldn't matter if the 11 computer is lying to you, so to speak. So, I'm not 12 sure this is germane to staffing level questions.

13 MEMBER MARCH-LEUBA: Yes, my thing is it's 14 not germane to staffing levels, but it is a condition 15 sine qua non. That's Latin. You cannot reach the 16 conclusion of the staffing. So, the conclusion of the 17 staffing, which I wholeheartedly agree, two operators, 18 because when you say, "three," you mean you can do it 19 with two. Two operators can control 12 units issues 20 without breaking a sweat as long as the computer 21 works.

22 So, that's my concern, that the computer 23 has to work. And when you have a computer running on 24 Windows, and possibly reusing modules that you have 25 been programming over the last 10 years on your spare NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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219 1 weekends -- I do this for a living. I mean, you know, 2 when I look for this, I should charge not by the 3 performance, but I should charge by the error because 4 I produce more errors than solutions, and everybody 5 else does, too.

6 Okay. So, again, I have no issue with the 7 staffing. Two operators can do the job perfectly as 8 long as the computer works. And I don't see where the 9 staff is going to be reviewing this software, this 10 control room that we rely so much on, in the future.

11 I don't see those commitments.

12 Over and out.

13 MEMBER KIRCHNER: Well, Jose, just to 14 follow up, because I share your concerns, I agree with 15 your conclusion and share your concerns. My 16 expectation is at the COLA stage they will have to 17 demonstrate in the process of building out the actual 18 control room, and whatever simulator is used to mimic 19 the actual control room, that the staff would review 20 the fidelity of the simulator to the actual plant, and 21 in the course of building out the actual plant's 22 control rooms, and the qualification and testing, they 23 will have to demonstrate this. But you are correct --

24 MEMBER MARCH-LEUBA: Are we hearing from 25 the staff later on?

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220 1 MEMBER KIRCHNER: Yes.

2 MEMBER MARCH-LEUBA: Can we ask them?

3 MEMBER KIRCHNER: I think we should 4 explore this with the staff.

5 MEMBER MARCH-LEUBA: I got a real strong 6 pushback from the staff on the boron dilution issue, 7 saying, "No, no, in the COLA we don't review nothing."

8 That's where I'm coming from. So, I would like to 9 hear from the staff that, yes, they will take the fact 10 that the operator relies a lot on this software 11 performing --

12 MEMBER KIRCHNER: Right.

13 MEMBER MARCH-LEUBA: -- and we are going 14 to make a serious effort on reviewing this. Because 15 we cannot trust just the vendor saying, "Yeah, yeah, 16 it's okay."

17 VICE CHAIRMAN REMPE: And I point out that 18 there's been an example, a couple of examples 19 recently, with post-Fukushima additions to simulator 20 software, where it was assumed that a sensor would 21 perform to a certain depth, and they found out it 22 didn't, right?

23 MEMBER MARCH-LEUBA: Yes, that's a very 24 recent event.

25 VICE CHAIRMAN REMPE: And this is a new NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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221 1 plant that's got a different type of sensor dependency 2 on things. And so, that's why I am concerned about 3 that point. So, yes, I'd like to know how the staff 4 verifies that the simulator is showing what the 5 instrumentation in the plant will actually show the 6 operators.

7 MEMBER KIRCHNER: Well, there's two 8 aspects to this, Joy. This is Walt.

9 This first is what actually is built in 10 the plant, tested in acceptance testing, and 11 qualified. And then, there's what the simulator 12 mimics for the actual plant.

13 VICE CHAIRMAN REMPE: And today, I'm into 14 to the second.

15 MEMBER KIRCHNER: There are two separate 16 sides to this.

17 VICE CHAIRMAN REMPE: Yes, and I'm into 18 the second part of this today.

19 MEMBER KIRCHNER: Right. But, as you 20 pointed out, what we observed in the visit, one of the 21 -- perhaps let me put it this way: the danger with 22 the simulator is you've got something -- like I had 23 presumed it was RELAP -- results that drive this 24 simulator. You've got a lot more information for the 25 instructor as a result of running something like a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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222 1 systems code than you would actually see in the plant.

2 To the extent that any of that additional information 3 is displayed and changes the response or the 4 situational awareness of the operators being trained, 5 that could be of concern.

6 So, obviously, down the road, for the 7 actual plant, when they're training the operators, one 8 would want to look at the fidelity of the simulator to 9 the actual plant display and not have a situation 10 where you're providing more information that would 11 help the operator than is actually going to be 12 available in the plant.

13 Did I say that well? I hope so.

14 VICE CHAIRMAN REMPE: Absolutely, and 15 again, as I mentioned -- and Jose confirmed -- we've 16 heard of an example in the existing fleet with the new 17 instrumentation related to the post-Fukushima action 18 items. But, in this particular plant, where this 19 instrumentation is different in some cases, or in one 20 case still to be developed, we want to make sure that 21 at least we have a high-fidelity simulator that's used 22 to train the operators which is correct.

23 MEMBER KIRCHNER: Perhaps maybe this is a 24 good juncture to turn to the staff presentation. A 25 lot of our questions seem to be about inspection and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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223 1 other aspects during the COLA phase.

2 So, if there are no further questions of 3 NuScale right now, let me turn to the staff. And I 4 believe Getachew Tesfaye is going to take the lead for 5 the staff presentation.

6 VICE CHAIRMAN REMPE: And so, Walt, I 7 guess I would like to acknowledge that I understand 8 that this question I'm raising isn't relevant to how 9 operators are in the control room issue, but it's a 10 safety issue. And in our holistic review, we do often 11 bring up other items, and that's just the nature of 12 the beast. And actually, that's what we're here for 13 with the Agency.

14 MEMBER KIRCHNER: Right. And it will show 15 up later today when we read our letter as well.

16 So, Getachew, are you there?

17 MR. TESFAYE: Yes, I'm here.

18 MEMBER KIRCHNER: Sir, go ahead, please.

19 MR. TESFAYE: Yes. Can you please give me 20 the rights to present my slides. I'm not a presenter 21 right now.

22 MR. SNODDERLY: I believe Maurin could 23 also do that.

24 MR. TESFAYE: No, the slides --

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224 1 could give Getachew rights, that's fine, but I think 2 Maurin also has rights.

3 MR. TESFAYE: Yes, I've got it now.

4 MR. SNODDERLY: Okay.

5 MR. TESFAYE: Thank you.

6 Good afternoon. My name is Getachew 7 Tesfaye. I'm the NRC Project Manager for the NuScale 8 Licensing Topical Report on the Control Room Staffing 9 Plan, Topical Report TR-0420-69456.

10 The technical reviewers are: Maurin 11 Scheetz, Lauren Nist, and Jessee Seymour.

12 Before I turn over the mic to the 13 technical staff to present their justification for 14 approving the Topical Report, I would like to go over 15 some process-related items for the record.

16 Revision 0 of the Topical Report was 17 submitted for NRC review and approval on June 11th, 18 2020. The Topical Report documents the technical 19 basis for the minimum staffing contingent of three 20 licensed operators from a single control room for up 21 to 12 NuScale power modules and the associated 22 facilities.

23 Subject to the conditions of applicability 24 discussed in Section 1.5 of the Topical Report and 25 also listed in Section 5 of the Safety Evaluation, a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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225 1 NuScale facility licensee or COL applicant may use the 2 Topical Report as the technical basis for an exemption 3 request from the staffing requirement in 4 10 CFR 50.54(m) or alternative staffing requirement in 5 the DC rule, and the STA training requirement in 6 10 CFR 50.120.

7 From August 17th to September 10th, 2020, 8 the staff conducted an audit, observed video 9 recordings of the validation activities, a review of 10 validation test data and results, and identified 11 information that would require docketing to support 12 the regulatory finding.

13 Following the audit, on October 21, 2020, 14 the staff issued a request for additional information 15 containing 15 questions. On December 17, 2020 -- I'm 16 sorry, I have to advance the slides as well; I 17 apologize for that -- on December 17, 2020, NuScale 18 completed its response to the 15 RAI questions and 19 submitted Revision 1 of the Topical Report with 20 updated information.

21 The NRC staff submitted an Advanced 22 Topical Report Staff Evaluation to this Committee on 23 February 9, 2021, and presented its finding to the 24 ACRS NuScale Subcommittee on March 16 of this year.

25 During the Subcommittee meeting, we informed you that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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226 1 we were in the process of finalizing an information 2 SECY paper to the Commission regarding this Topical 3 Report.

4 On April 5, 2021, SECY 21-0039 was issued 5 to the Commission. We expect that it will be made 6 publicly available by April 19, 2021. As we indicated 7 earlier, the purpose of the SECY is to inform the 8 Commission of: one, NuScale's proposal to eliminate 9 the Shift Technical Advisor, STA, position from its 10 control room staff; and two, the staff's performance-11 based approach to approving NuScale's proposal, which 12 constitutes a first-of-a-kind approach to control room 13 staffing and represents a shift from existing Agency 14 and industry practice, with implication for Commission 15 policy.

16 That's all I have for my part of the 17 presentation. Before I hand over the mic to the 18 technical staff, I'd be very happy to address any 19 questions you may have. Thank you.

20 MEMBER KIRCHNER: Well, I have a question, 21 Getachew. This is Walt Kirchner.

22 MR. TESFAYE: Please.

23 MEMBER KIRCHNER: Since you're addressing 24 a first-of-a-kind, now the staff has already looked at 25 the Vogtle plant, which also is moving in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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227 1 direction of a digital display functionality for 2 control room operation of the plant. When you say, 3 "first-of-a-kind," are you talking about the fact, the 4 multiple modules with this size crew? Or are you 5 talking about just the transition to a digital-6 operated nuclear power plant?

7 MR. TESFAYE: No, I'm talking about first-8 of-a-kind for not having an STA in the control room.

9 MEMBER KIRCHNER: Okay. All right. I 10 thought for a moment there you were saying first-of-a-11 kind with regard to digital display and control.

12 Okay. Thank you.

13 MR. TESFAYE: Thank you.

14 All right. With that, Maurin, Lauren, 15 please go ahead.

16 MS. SCHEETZ: Thank you, Getachew.

17 This is Maurin Scheetz. I'm a technical 18 reviewer and operator licensing examiner in the 19 Operator Licensing and Human Factors Branch in the 20 Office of Nuclear Reactor Regulation, Division of 21 Reactor Oversight.

22 I'm one of three staff reviewers who 23 evaluated the Topical Report. The other reviewers are 24 Lauren Nist and Jessee Seymour, who are also in my 25 Branch. We were assisted during our review by Dr.

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228 1 Brian Green, who is our human factors engineering team 2 lead, and our Branch Chief, Chris Cowdrey. Lauren, 3 Dr. Green, and I also reviewed the human factors 4 engineering design for the NuScale Design 5 Certification Application. We also consulted with Dr.

6 Dave Desaulniers, the NRC's Senior Technical Advisor 7 for Human Factors, and Dr. Jing Xing and Dr. Amy 8 D'Agostino, two of our colleagues from the Human 9 Factors and Reliability Branch in the Office of 10 Research.

11 I think at this point what I want to do is 12 answer the question that came up during NuScale's 13 presentation regarding the regulatory aspects of 14 simulator fidelity. And I'm going to pass the mic 15 over to Lauren Nist to answer that question first, if 16 that's okay with the Committee.

17 MEMBER KIRCHNER: Please. Go ahead.

18 MS. NIST: Thank you.

19 Good afternoon. This is Lauren Nist of 20 the NRC, Maurin's colleague.

21 So, I was trying to take some notes here 22 just to make sure I give a comprehensive response to 23 the question that Member Rempe raised. And so, I'm 24 going to ask, also, Jessee Seymour and Maurin to 25 provide input as well, if I fail to cover anything in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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229 1 this response.

2 But, essentially, as I understand it --

3 and correct me if I'm wrong here -- the question is, 4 how does a facility licensee verify that its simulator 5 that is used for the purposes of operator training and 6 licensing has adequate fidelity to the actual plant?

7 Is that the question that is being desired to be 8 answered?

9 VICE CHAIRMAN REMPE: Yes.

10 MS. NIST: Okay. Wonderful.

11 So, to be used for operator initial 12 license training, as well as part of the operating 13 test, the simulator operating test on the NRC initial 14 license exam, and also, to be used for operator 15 requalification training, the simulator needs to meet 16 the requirements in 10 CFR 55.46. So, I'm going to 17 tell you two guidance documents, and then, I'm going 18 to explain the portions of them that help ensure these 19 requirements are met. And these are fidelity 20 requirements in 55.46, making sure that operators are 21 trained to do their job, so that they take the right 22 actions in the plant, when needed.

23 So, Regulatory Guide 1.149 endorses ANSI 24 Standard 3.5 as a way to meet these requirements for 25 simulators that are used for operator training and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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230 1 examination. There are multiple tests that are 2 described in ANSI-3.5. Performance tests are one 3 category of tests that are described in there. And 4 there are different kinds of performance tests on the 5 simulator that are done to ensure that the simulator 6 has sufficient fidelity to the plant control room 7 design, where the operators actually are working and 8 doing their jobs.

9 So, what is sufficient fidelity? Well, 10 one measure of sufficient fidelity is that there 11 should not be any, quote, "noticeable differences" 12 between a simulator and the plant. So, a "noticeable 13 difference" is further defined in the ANSI standard 14 as, essentially, something that would impact the 15 operator's job, if they were to do it in the plant.

16 So, if it's something that would result in, say, 17 negative training, that's a noticeable difference that 18 the facility licensee needs to take the right actions 19 to address.

20 And one way to do that would be to enter 21 it into some kind of tracking system that's auditable, 22 that tells you what the issue is, and do a training 23 needs analysis, which is also a process further 24 defined in the ANSI standard, to figure out what's the 25 impact on the operators here. And then, it needs to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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231 1 be corrected if it would result in negative training 2 and have an impact on operator performance in the 3 plant.

4 So, we do several inspections to ensure 5 that there is continuation of simulator fidelity, 6 which, by the way, continued assurance of simulator 7 fidelity over time is also a requirement in 55.46, I 8 think Part (d). So, in the past, we used to have 9 -- many, many years ago, facilities used to send us 10 forms -- I believe the form was NRC 474 -- with all 11 the performance tests, all the results of the 12 performance tests.

13 So, for example, they would run a reactor 14 scram in the simulator, and then, they would measure 15 all the parameters. Okay, five minutes, one minute 16 after scram, at time of scram, what are these 17 parameters showing in the simulator? And by 18 "parameters," I mean, you know, pressurizer level, 19 steam generator water levels, steam generator water 20 flow, control rod positions.

21 So, they would take these parameters, they 22 would mark them down, and they would compare them to 23 actual operating experience from the plant. And then, 24 they would have tolerances that are also part of the 25 appendices of the ANSI standard, which say, for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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232 1 example, like, okay, if you're modeling, say, reactor 2 trip and scram in your simulator, it needs to be 3 within plus or minus 1 percent of what operationally 4 has been shown to be what that parameter does in those 5 situations.

6 So, we no longer receive all that 7 information from the facility and look it. But what 8 we do do is conduct inspections. So, for example, we 9 have an inspection procedure that is performed prior 10 to the initial operator licensing exam at a facility 11 which looks at the results of performance testing. It 12 also looks very closely, prior to any -- any --

13 operating licensing exam that we give at a facility.

14 It's called -- and I think we've used this term 15 before -- the "scenario-based testing".

16 So, what this does is looks to see if, for 17 a given scenario, say that you are going to administer 18 for an operator licensing exam. You want to make sure 19 that the simulator is modeling exactly what it is 20 supposed to model as compared to the design 21 documentation that you have. Because, as is discussed 22 in the regulations, the simulator needs -- it is 23 derived, its data, its configuration is derived from 24 a specific reference plant.

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233 1 from walking through the control room, if it's built, 2 and you look at a console and say, "Oh, yes, these 3 switches are here. Yes, these switches are in the 4 control room," or, yes, this panel or this software, 5 page 292, that shows me how to operate boration and 6 dilution in the simulator, I could pull that up in the 7 control room, and it looks the same. And you can 8 compare them.

9 Sorry, did I lose you guys?

10 VICE CHAIRMAN REMPE: Yes, just briefly.

11 You said, "these," and then, it blanked out.

12 MS. NIST: Oh, okay. I'm sorry. Sorry 13 for that. Okay. I'm not sure what happened.

14 But, essentially, these tests and these 15 inspections are part of the activities that we do to 16 ensure that there is adequate fidelity.

17 And then, again, when we recall 18 inspections, whenever --

19 VICE CHAIRMAN REMPE: So, could I 20 interrupt a minute? I appreciate what you're telling 21 me, but maybe you're going into a lot more detail than 22 what I need. Okay? Could I try and focus it a little 23 bit here?

24 MS. NIST: Absolutely. Please.

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234 1 was information provided by a sensor before it could 2 provide data, because it only would show a water level 3 at a certain value or higher. And recently in the 4 operating fleet, they have a requirement with the new 5 post-Fukushima actions saying that, if the water drops 6 below a certain level, they need to take action. And 7 the instrumentation's been involved -- or installed, 8 and they noticed it, in one case the inspector noticed 9 it, in another case the licensee noticed that the 10 instrumentation did not provide data to such a low 11 value.

12 So, do all of these requirements -- they 13 sound great. They're supposed to do this. But is 14 there an instrumentation person involved in this 15 process that actually goes, "Okay, I know what the 16 sensors are in the plant and these sensors can provide 17 the data required for the operator actions."? Is that 18 what you're telling me? Yes, it should be, and in the 19 case of the operating fleet, there were a couple of 20 hiccups with this new sensor and we need to be more 21 careful when new instrumentation is involved?

22 And we know that this NuScale plant is 23 going to be different. So, we're going to have an 24 instrumentation engineer involved to make sure that 25 things in the simulator for training operators will, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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235 1 indeed, be possible in the real plant?

2 MS. NIST: So, let me see here. I don't 3 know that we have anticipated having an 4 instrumentation expert available, just because we --

5 I mean, we don't have a NuScale simulator to go out 6 and inspect for operator licensing yet. That's a 7 little further down the road.

8 VICE CHAIRMAN REMPE: Sure. I get that, 9 and that's what I'm thinking; it's further down the 10 road. Clearly, when I brought this up at the meeting, 11 people weren't expecting it from the staff. And they 12 had, basically, assumed the simulator was accurate.

13 And so, it took a while to kind of explain where I was 14 coming from. And so, that's why I'm bringing it up.

15 But do you think it should be and is it 16 possible? Because, again, I'm more thinking about the 17 COL application.

18 MS. NIST: Yes.

19 (Phone ringing.)

20 Excuse me for one moment. I'm going to 21 turn this off. Sorry about that.

22 So, I think it's important to distinguish 23 -- and Doug alluded to this earlier -- it's important 24 to distinguish the simulator that we've all been 25 seeing at the NuScale facility from one that would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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236 1 used for operator licensing. It may be located in the 2 very same building out in Corvallis, Oregon, at some 3 point in time. That may be what happens. But, right 4 now, the simulator that they have is characterized, 5 essentially, as one for, as I understand it at least, 6 design development and validation, as they developed 7 the design that was certified last year and continue 8 to do further development.

9 So, the lens, I guess you could say, the 10 focus that we have for this exercise is not 11 necessarily entirely on how the requirements of 55.46 12 for operator licensing and training are satisfied.

13 However, we are concerned, we were concerned with 14 fidelity of the simulator that was used for this 15 validation test that was the subject of the Topical 16 Report, as well as the integrated system validation 17 test and the previous staffing plan validation test, 18 because of some of the issues that were raised today.

19 You want to make sure that this, the tool 20 that you're using to validate the HFE design, the 21 staffing level, can adequately create a simulated 22 environment that gives you confidence that in the 23 actual control room the operators are going to be 24 experiencing the same demands in the performance of 25 the tasks that they're being assigned to do.

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237 1 So, we --

2 VICE CHAIRMAN REMPE: So, I brought this 3 up at the Subcommittee meeting. I found one parameter 4 that the Applicant says, "This won't matter in what 5 the operators do." And I believe that. Did you guys 6 go back and say, "Okay. Is there any other parameter 7 that was shown to the operators that's going to be 8 not" -- was this simulator adequate for the 9 evaluation? Did you think about that? So, I have no 10 idea. I was there for like -- I don't know -- maybe 11 20 minutes or something.

12 MS. NIST: So, you and I had talked about 13 this in part at the Subcommittee meeting. And I did 14 explain then that we looked at simulator tests that 15 were conducted before this. NuScale provided the 16 results of all of the scenario testing, which I will 17 explain about that, you know, what we really looked at 18 there. But they basically said, "Here are the 19 scenario that are going to be used for this validation 20 test. Here's how the plant is supposed to behave."

21 We did some independent confirmation of 22 that against what the scenarios said during our 23 observations of those scenarios, making sure the 24 simulator was doing what that scenario guide said it 25 was supposed to do. And we also looked to see, okay, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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238 1 well, the design documentation -- you know, for 2 example, in the Chapter 15 analysis, it talks about 3 how the plant is supposed to behave during certain 4 events that were in those scenarios. So, we made sure 5 that it aligned with that.

6 We also looked at simulator differences 7 lists that they had generated that shows deltas in the 8 simulator, what it shows as opposed to what the 9 current design documentation is.

10 So, did we go back and compare to the 11 design documentation to make sure they had gotten them 12 all? No, that was not within the scope of our review.

13 VICE CHAIRMAN REMPE: Okay. Thank you.

14 MEMBER MARCH-LEUBA: Yes, this is Jose.

15 I can assure you the simulator produces 16 400 percent differences with respect to the design 17 documentation when it comes to boron reactivity, 18 because I've looked at it. Okay? Sorry, I shouldn't 19 have said that. It's true.

20 But your presentation on it was very good.

21 What it shows is the simulator technology is mature.

22 And we have been doing simulators for the last 50 23 years and we know how to do them. And therefore, I 24 have no concern with that. I'm hoping NuScale and the 25 staff does their job according to all these ANSI NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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239 1 standards and everything; I mean, that is going to be 2 done right. Okay?

3 My concern is, in front of the simulator 4 you have those 13 big screens -- and what is it? -- 12 5 or 16 littler screens, and they're running software 6 that becomes the software, the user interface for the 7 operator. That is new. That is revolutionary. And 8 all this alarm filtering, all these green lights that 9 show up next to each module, as opposed to a red 10 light, that's what allows the operator to have 11 situational awareness, because the computer has the 12 situational awareness for them and tells them. All 13 that is new.

14 So, let me ask you a specific question.

15 At the COLA stage, does the staff have any plans to 16 review this user interface, not the simulator, the 17 real control room, the user interface, the 16 littler 18 screens in front of the operators and the 13 bigger 19 screens on the back wall? Do you have any plan to 20 review that?

21 MS. NIST: So, sir, you said COLA stage?

22 MEMBER MARCH-LEUBA: Yes.

23 MS. NIST: That's when we receive a COL 24 application. They can't construct, start construction 25 maybe until they see --

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240 1 MEMBER MARCH-LEUBA: So, your answer is, 2 "No, we are not planning to review during the COLA 3 stage?"

4 MS. NIST: It's not possible; that's 5 correct.

6 MEMBER KIRCHNER: Give her a chance to 7 finish.

8 MEMBER MARCH-LEUBA: Right.

9 MS. NIST: My answer is that it is not 10 possible to do that.

11 MEMBER MARCH-LEUBA: I knew that. I was 12 asking you the question, so you would put it on the 13 record. Apparently, other people don't know that.

14 At which point will that be reviewed?

15 MS. NIST: So, to do what you're doing --

16 to make sure I understand correctly, you're asking, is 17 there going to be an inspection of the --

18 MEMBER MARCH-LEUBA: A review.

19 MS. NIST: Of the --

20 MEMBER MARCH-LEUBA: Not an audit. A 21 review. This is a first-of-a-kind, very complex piece 22 of software with high, high, high probability of 23 failure. Is there going to be a review?

24 MS. NIST: So, I guess I'm just -- I'm not 25 the expert on Chapter 7, ITAAC. So, I'd have to defer NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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241 1 to your conversations with the staff that occurred 2 during the DC review, or to someone else, because I 3 don't, I mean, I don't know what the answer is.

4 MEMBER MARCH-LEUBA: I was afraid of that.

5 I yield the remainder of my time.

6 MS. SCHEETZ: Well, Lauren, hey, this is 7 Maurin.

8 Regarding Jose's question, I'm sure 9 there's lots of ITAAC in Chapter 7 that we are not 10 familiar with, of course. But there is an ITAAC in 11 Chapter 18 for human factors inspections, tests, 12 analyses, and acceptance criteria.

13 So, there's one ITAAC, and that's -- I'm 14 just reading it -- "The configuration of the main 15 control room in HSI is consistent with the design 16 verified and validated by the integrated system 17 validation and as reconciled by the design 18 implementation plan."

19 MEMBER MARCH-LEUBA: So, does that include 20 a software review to identify all the "Easter eggs" 21 that are inside there?

22 MS. SCHEETZ: At this point, I can't -- I 23 don't know for sure. I don't think so, because it's 24 an HFE ITAAC, but maybe we could answer your question 25 getting some help from the --

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242 1 MEMBER MARCH-LEUBA: And this my point; 2 I'm trying to make it here, and everybody is screaming 3 at me when I do it. That software, even if I'm doing 4 it, is going to have errors. It's the first-of-a-5 kind. And we are 100 percent relying on it to allow 6 operators to do their job. At least acknowledge that 7 I can be a little uneasy about the situation.

8 MR. TESFAYE: This is Getachew Tesfaye.

9 May I add a few points about this request?

10 MEMBER MARCH-LEUBA: Yes, please.

11 MR. TESFAYE: Yes, I mean, this Topical 12 Report has not yet been referenced in a licensing 13 application. When the NuScale standard design 14 approval comes in, it comes in with all the chapters.

15 Maybe would it be appropriate to ask this question 16 when this Topical Report is actually referenced in a 17 licensing application?

18 MEMBER MARCH-LEUBA: I think more 19 appropriate would be to have a condition on the 20 Topical Report, SE, that says: our conclusions that 21 one or two operators can handle 12 reactors under all 22 conditions is based on the supposition that the 23 software works as designed and has been validated, 24 verified, and testing thoroughly.

25 Therefore, 10 years from now, when this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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243 1 plant is built, the staff will see that condition and 2 will say, "Have you validated the software?" Because 3 I don't see that ITAAC. I don't see that condition.

4 I don't see that -- NuScale has a built-in design or 5 necessity to make this software work well. Okay. So, 6 they're going to try to make the best job possible.

7 But I build software for living, guys. I 8 know how this thing ends up. Somebody's going to make 9 a mistake on the alarm filtering. There is going to 10 be a condition in which three sensors froze, and that 11 will be an untested condition because you only tested 12 one.

13 MS. BRADFORD: This is Anna Bradford.

14 MEMBER MARCH-LEUBA: What could possibly 15 go wrong?

16 MS. BRADFORD: This is Anna Bradford from 17 NRR. Can I just say one thing?

18 MEMBER KIRCHNER: Go ahead, Anna.

19 MS. BRADFORD: And I'm sorry. Again, this 20 is Anna Bradford. I'm the Director of the Division of 21 New and Renewed Licenses.

22 And I hear you and I feel like we're at a 23 little bit of a disadvantage because we do not have 24 our digital I&C experts here. I certainly am not a 25 digital I&C expert and not able to explain what we do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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244 1 in terms of V&V and why we do feel comfortable with 2 these systems.

3 So, I don't know if there's some 4 particular questions you would like us to take back to 5 those staff. But, like I said, I think we're at a 6 little bit of a disadvantage here, but I feel like 7 there are answers to your questions, but we don't have 8 those staff on the line. So, whether we can take some 9 questions back, or there's some other way to address 10 this --

11 MEMBER MARCH-LEUBA: Yes, Anna. I 12 apologize for coming out so negative, but it's the 13 only way I know how to do it. Okay?

14 What I want to say, it's impossible to 15 review the control room until the control room exists.

16 The Chapter 7 guys are going to tell you, "What 17 software do you want me to review? It doesn't exist 18 yet." It doesn't exist.

19 What I will feel more comfortable, I would 20 relax a little bit better and my blood pressure will 21 go down, and my doctor will be happy, if you tell me, 22 "We have a plan because this is a first-of-a-kind, and 23 there is so much reliance on this alarm filtering, 24 situational awareness for the computer to the 25 operator, being a first-of-a-kind, we have plans to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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245 1 review it when it exists."

2 MR. MOORE: Member March-Leuba, this is 3 Scott.

4 I think what we're hearing from the staff 5 is they don't have the right people before the 6 Committee right now to be able to answer that 7 question, and they're asking, can they take that away 8 and get back to the Committee? Would that be okay?

9 MEMBER MARCH-LEUBA: May I ask when 10 they're going to come back?

11 MR. MOORE: I think that would -- Anna, 12 can you answer that?

13 MS. BRADFORD: I would hope we could get 14 back to you -- well, it's 5:15 here on the East Coast 15 right now. So, I don't want to promise today, but 16 maybe COB tomorrow.

17 MEMBER MARCH-LEUBA: Yes, our plan, which 18 we are not going to accomplish, was to have the letter 19 written today.

20 MEMBER KIRCHNER: No, we will not finish 21 the letter today.

22 MEMBER MARCH-LEUBA: No, no, but that was 23 the plan.

24 MEMBER KIRCHNER: Okay. But I think the 25 more holistic request might be appropriate, Jose, of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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246 1 the staff. And that is, if they would be able to tell 2 us, if there's a COLA application, what is the process 3 and what inspections will be made of the buildout of 4 the actual control room and its testing and 5 validation? And the software, obviously, as you point 6 out, is a major part of it in this particular design.

7 But there are, just like when the actual 8 plant is built, the instruments have to be 9 demonstrated to be qualified for the environment and 10 tested, et cetera. So, it seems to me it's more a 11 question of how the integrated system as built out, 12 the final control room, is inspected and verified for 13 functionality, including software.

14 Does that make sense, Anna?

15 MS. BRADFORD: Yes. Thank you.

16 MEMBER KIRCHNER: You're welcome.

17 MS. BRADFORD: I wrote that down as you 18 were talking. So, I will get that question to our 19 experts and we will try to get back to you as soon as 20 we can.

21 MEMBER KIRCHNER: Thank you very much.

22 MS. SCHEETZ: Okay. This is Maurin again.

23 I'm going to continue.

24 Can you go back to slide 4, please?

25 Great. Thank you.

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247 1 So, at the Subcommittee meeting, we 2 discussed our review activities, observations, and the 3 basis for our conclusion that the staffing plan 4 discussed in the Topical Report is acceptable. This 5 slide shows the main parts of the technical 6 justification that support our conclusion.

7 We found that the validation test 8 methodology was adequate; the validation scenarios 9 were sufficiently challenging, and that the validation 10 test results support the new minimum staffing level.

11 Regarding the elimination of the Shift 12 Technical Advisor, or STA, we assessed whether NuScale 13 reasonably reallocated the tasks that were previously 14 assigned to the STA. We also found several other 15 factors that support elimination of the STA at a 16 NuScale plant.

17 At the Subcommittee meeting, we discussed 18 each of these four parts of our technical 19 justification in detail. When we discussed the 20 results of the validation tests, there were some 21 questions about NASA-TLX, which is the tool that 22 NuScale used to measure workload.

23 Next slide, please.

24 Workload is comprised of the physical, 25 cognitive, and other demands that tasks place on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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248 1 control room personnel. It's important to measure 2 workload levels and find that they are not excessive 3 because high workload may cause degraded task 4 performance, especially under stressful situations, 5 and this may leave the operators with little or no 6 margin for dealing with added complications.

7 Measurement of workload is one of several 8 indicators used to review proposed staffing levels.

9 Successful task performance is the main indicator, and 10 situation awareness is another indicator, because, 11 like workload, it can impact task performance. For 12 example, a crew may not perform a task accurately and 13 on time because they do not understand the plant 14 status. NuScale used these three measures in their 15 staffing plan validation.

16 There were several questions, like I said, 17 about NASA-TLX, the method that NuScale used to 18 measure workload during validation testing. NASA-TLX 19 has been used successfully around the world to assess 20 workload in various environments, such as commercial 21 aircraft cockpits, and is commonly used in the nuclear 22 power industry.

23 As discussed in NUREG-7190, which is 24 titled, "Workload Situation Awareness and Teamwork,"

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249 1 for measuring workload in nuclear power plant control 2 rooms. It's a self-rating method in which individuals 3 report perceived workload along six dimensions. Those 4 dimensions are: mental demands, physical demands, 5 temporal demands, own performance, effort, and 6 frustration.

7 After the March Subcommittee meeting, Dr.

8 Jing Xing provided some additional information about 9 NASA-TLX and shared a paper from the Halden Reactor 10 Project with ACRS titled, "An Efficient Screening 11 Technique for Acceptable Mental Workload Based on the 12 NASA Task Load Index - Development and Application to 13 Control Room Validation". This paper establishes 14 NASA-TLX as a valid method for measuring workload in 15 modern nuclear power plant control rooms.

16 One of the questions that came up during 17 the Subcommittee meeting was whether NASA-TLX measures 18 cognitive demand. The answer is yes. NASA-TLX 19 measures cognitive demand through three subscales:

20 mental demand, temporal demand, and effort.

21 Like I said before, we have Dr. Xing here 22 to answer any additional questions regarding the 23 validity of NASA-TLX for the purpose of measuring 24 workload.

25 So, I could take this time now, if there NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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250 1 are any questions about NASA-TLX that the Committee 2 has.

3 CHAIRMAN BLEY: This is Dennis Bley.

4 I appreciate the material Jing sent to us, 5 and that answered all my questions. Thank you.

6 MS. SCHEETZ: Okay. Thank you.

7 Next slide, please.

8 So now, I'm going to talk about the STA 9 position. The STA is a valuable position that has 10 been in place for over 40 years at nuclear power 11 plants in the United States. As such, we carefully 12 examined NuScale's proposal for eliminating the STA 13 position. This slide summarizes the additional 14 factors we found that support elimination of the STA 15 at a NuScale plant, and they are:

16 The NuScale Control Room Human-System 17 Interface Design, which reflects state-of-the-art 18 human factors engineering principles and includes 19 features that alert the crew when a safety function is 20 challenged, a plant parameter has exceeded an 21 emergency action level, and a system component may be 22 inoperable.

23 The NuScale plant design, which reduces 24 operational complexity as compared to operating 25 reactors, does not require operator actions during NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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251 1 design basis events and provides an overall 2 improvement in safety.

3 The Licensed Operator Training Program, as 4 detailed in the Topical Report, which prepares 5 operator to effectively identify and respond to 6 abnormal events in the plant.

7 The availability of a second senior 8 reactor operator on shift who can provide advice, 9 assistance, and an independent assessment of events.

10 The on-shift operators have time, without 11 challenging plant safety functions, to get assistance 12 from off-shift resources when faced with a situation 13 that is not covered by training or procedures.

14 And finally, the results of the revised 15 staffing plan validation tests, which demonstrate that 16 operators can interpret the indications provided on 17 the HSI without adequate performance across a variety 18 of measures, as well as our own observations that we 19 had that this staffing model is effective.

20 We benefitted from observing three 21 different validation tests and a variety of 22 challenging scenarios in the simulator in the NuScale 23 control room simulator. What we saw operators doing 24 in the control room is so different when compared to 25 operating reactors.

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252 1 The control room supervisor spent most of 2 his time standing back and assessing the plant and 3 overseeing procedure steps that were managed by the 4 reactor operators. The control room supervisor was 5 not buried in one or more procedures and directing 6 each procedure step.

7 The reactor operators spent a lot more 8 time observing and confirming automations, not turning 9 switches. With the relatively large amount of 10 automation and reduced reliance on operator actions, 11 the control room supervisor and the reactor operators 12 have much more time and bandwidth for monitoring and 13 observing the units in a control room that uses large, 14 overview screens to help operators quickly see the 15 status of each unit.

16 In closing, our conclusion regarding the 17 Shift Technical Advisor is based on our assessment of 18 the changes in the nuclear industry and to operator 19 requirements that have occurred over time. And our 20 conclusion is specific to the NuScale design.

21 We have confidence that a degreed 22 individual is not needed to improve the ability of the 23 shift operating personnel to recognize, diagnose, and 24 effectively deal with plant transients and other 25 abnormal conditions in the presence of these other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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253 1 factors.

2 We believe the regulatory basis for the 3 Shift Technical Advisor has some flexibility, and 4 therefore, we have informed the Commission via an 5 information SECY on this matter of eliminating the STA 6 for NuScale.

7 And that concludes our presentation.

8 Thank you.

9 MEMBER KIRCHNER: Maurin, this is Walt 10 Kirchner.

11 A specific question to your closing 12 statement there on the STA: you said a degreed person 13 is not necessary?

14 MS. SCHEETZ: That's correct. That's 15 meaning the STA, which had to have a degree. So, by 16 saying the STA is not necessary, we are saying that a 17 degreed person, in addition to -- for the minimum 18 staffing plan is not necessary for NuScale. That's 19 correct.

20 MEMBER KIRCHNER: All right. Thank you.

21 CHAIRMAN BLEY: I'm just curious. Do you 22 see this as a policy issue? Do you need to await a 23 decision from the Commission on the paper you sent up?

24 MS. SCHEETZ: So, this is Maurin again.

25 So, we see it as an impact to existing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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254 1 Commission policy which says that a person with an 2 engineering degree needs to be on shift as the STA.

3 So, it impacts existing Commission policy and the way 4 that operating reactors have been staffing for years 5 and years. So, we did communicate with the 6 Commission, via the information SECY, that our intent 7 was to approve this Topical Report for NuScale that 8 doesn't have the STA as part of the staffing plan.

9 As far as waiting for the Commission to 10 respond, Getachew, can you answer that better?

11 MR. TESFAYE: Well, there is a wait 12 period. The SECY has been issued to the Commission, 13 and they would have at least 10 days, I believe, to 14 look it up and see if the status can be changed into 15 a voting SECY. That's why we're waiting until April 16 19th to make it public.

17 CHAIRMAN BLEY: Okay. So, on a thing like 18 this, if the Commission does nothing, that's, 19 essentially, them saying they agree with you?

20 MR. TESFAYE: That's correct.

21 CHAIRMAN BLEY: It's an exception sort of 22 thing. Okay. Thank you.

23 MEMBER KIRCHNER: Members, further 24 questions of the staff?

25 (No response.)

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255 1 Hearing none, can we turn to open the 2 public line, Thomas, and see if we have any comments 3 from the public?

4 PARTICIPANT: The public line is open for 5 comment.

6 MEMBER KIRCHNER: Thank you.

7 For members of the public, are there any 8 comments you wish to make? If so, please identify 9 yourself and make your comment.

10 MS. FIELDS: I have a comment. My name is 11 Sarah Fields. I'm with Uranium Watch in southeast 12 Utah.

13 I also commented on the Subcommittee's 14 hearing or meeting in March. So, some of my comments 15 will actually duplicate those comments.

16 Some of the things that the ACRS should 17 take into consideration: the only reason to reduce 18 the number of operators in the plant is to save money.

19 It is not being proposed to improve the safety of the 20 plant.

21 The NuScale design for SMRs has no 22 operational history, so there will be a number of 23 aspects of the plant construction/operation that will 24 need to be tested and verified. And during that time, 25 it seems that the number of plant operators should not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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256 1 be reduced.

2 That initial one-year, maybe two-year, 3 period for the operation of one SMR unit, and then, 4 building out to more operational units, will be really 5 tricky. The whole design, it's a paper design mostly 6 at this time. And the NRC and NuScale have relied on 7 a lot of assumptions that will need to be thoroughly 8 vetted and verified over the first couple of years.

9 The NuScale design for design 10 certification is not a final design, and there are 11 dozens of COL items, including the development of 12 operator actions to address plant conditions; most 13 notably, the possibility of boron dilution that could 14 result in core damage.

15 So, sections related to plant safety and 16 plant shutdown for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without operator actions 17 have not really been verified. I have a strong 18 feeling that, if and when there is a COL application, 19 that there will be times when plant operator actions 20 will be needed before 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

21 So, NuScale and the NRC do not have a 22 complete and final picture of possible operator 23 actions and the data that must be available to plant 24 operators to maintain the plant in a safe condition.

25 And right now, the only U.S. company that has plans to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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257 1 site a NuScale-designed SMR is the Utah Associated 2 Municipal Power Systems, or UAMPS. And UAMPS has 3 absolutely no experience whatsoever in designing, 4 constructing, and operating any kind of nuclear 5 reactor.

6 Also, NuScale and the NRC want to be able 7 to reduce the size of emergency planning zones and 8 offsite emergency plans.

9 So, there are a lot of other related 10 issues that the ACRS and NRC and NuScale should take 11 into consideration.

12 Thank you for this very informed 13 discussion and for all the NuScale and NRC and ACRS 14 efforts. The end.

15 MEMBER KIRCHNER: Thank you, Sarah.

16 Other members of the public, comments?

17 (No response.)

18 Hearing none, I think, Thomas, we can go 19 ahead and close the public line.

20 PARTICIPANT: Closing the public line.

21 MEMBER KIRCHNER: Thank you, sir.

22 So, Members, at this point, further 23 questions of the staff and NuScale?

24 (No response.)

25 Hearing none, at this point I'll turn it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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258 1 back to you, Mr. Chairman. I think that completes our 2 presentations on the subject.

3 CHAIRMAN SUNSERI: Thank you. Thank you, 4 Walt, and thank you, Members, and Staff, and NuScale.

5 So, let me turn this question to you, 6 Walt. Do you have something that you are prepared for 7 us to start reviewing?

8 MEMBER KIRCHNER: We could post the 9 letter. I think Mike Snodderly and Tammy are 10 available. We could do an initial read-through.

11 CHAIRMAN SUNSERI: Okay. So, let's do 12 this: let's take a 10-minute break here -- we've been 13 at this for over two hours -- for a transition to let 14 them put the document up on the screen, so we can read 15 it. And then, you can read through it and we can go 16 into high-level comments.

17 MEMBER KIRCHNER: Good. That would work.

18 Thank you.

19 CHAIRMAN SUNSERI: Okay. So, we will take 20 a break here until a quarter 'til, and then, we will 21 reconvene with the reading.

22 Thank you.

23 (Whereupon, at 5:36 p.m., the foregoing 24 matter went off the record.)

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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RG 4.26 - Volcanic Hazards Assessment for Proposed Nuclear Power Reactor Sites NRC Staff Presentation to the Advisory Committee on Reactor Safeguards April 8, 2021

Introduction

  • After 2/20/20 ACRS meeting, Draft Guide 4028 issued on 3/20/20 for public comments
  • 23 comments received by 7/31/20

- 2 from members of the public

- 21 from NEI

  • Most comments incorporated into revisions

- Differences for screening, international standards

- Resolution tracked for all comments 2

Initial Screening

  • Continue to use site characterization for 320 km (200 mi) of proposed site

- Identify Quaternary (2.6 Myr) volcanoes

  • If Quaternary ash deposits 40 km (25 mi) of proposed site, the source volcano must be evaluated even if >320 km (>200 mi) away.

- Leverages existing geologic site-characterization information.

3

Example Screening

  • Vogtle site region
  • No Q volc 320 km
  • No Q ash 40 km
  • SER 2.5.1 states site characterization did not find evidence of Quaternary volcanic hazards.

4

Proximal Hazards

  • Some volcanic hazards restricted to 40 km (25 mi) from source

- e.g., debris avalanches, missiles & gases

  • If site >40 km (>25 mi) from existing or potential new vent, then proximal hazards would screen-out.
  • If site 40 km (25 mi) from an existing/new vent, pre-licensing consultation is warranted to determine scope of analysis.

5

Aligned Risk Insights with Guidance

  • Integrate RG 1.233/NEI 18-04 guidance for Design Basis Event (DBE) and Beyond DBE (BDBE) sequences
  • Requires mean, 5th, and 95th percentiles from a probabilistic analysis
  • Evaluate hazard contributions to initiating DBE and BDBE sequences
  • Assess significance with ASME/ANS RS-A-1.4-2020 methodology 6

Enhanced Flexibility

  • After screening, 2 paths for analysis
  • Path 1: Traditional Probabilistic VHA
  • Calculate likelihoods of Eruption and/or Hazard
  • Apply risk insights 7

Enhanced Flexibility

  • Path 2: Engineering
  • Bound hazard at screening levels
  • Evaluate SSC performance and/or mitigation

Expanded SSHAC Guidance

  • Clarifies selection of study levels 1-4 for volcanic hazards analyses
  • Clarifies that both study levels 3 & 4 provide equivalent regulatory assurance
  • Clarifies the flexibility of SSHAC for VHA applications
  • Encourages pre-application meetings for SSHAC use in a VHA 9

Clarified Tectono-magmatic Model

  • Integrates tectonic & volcanic information into a logical framework

- Conceptual, not a complex numerical model

  • Determine if all <2.6 Ma volcanoes in region of interest are potentially active in current tectono-magmatic conditions
  • Evaluate potential for nonstationary volcanic processes

- Such as eruption rates, hazard characteristics 10

Deleted Siting Considerations

  • Not consistent with scope of a regulatory guide on evaluation of natural hazards.
  • Restricted extent of some volcanic hazards captured in the text.

11

Additional Clarifications

  • Enhanced discussion on Consideration of International Standards.
  • Clarified that use of IAEA information is not an endorsement of IAEA guidance.
  • Supplemental discussion of the US Geological Survey role in monitoring potentially hazardous volcanoes.

12

Conclusions

  • Revisions are responsive to ACRS and public comments.
  • RG 4.26 maximizes flexibility in VHA approach and adopts current PRA guidance for developing risk insights.
  • The NRC staff believes RG 4.26 is ready for issuance.
  • Evaluate need for update when ANS standard on VHA is issued in future.

13

LO-101340 April 1, 2021 Project No. 99902078 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

NuScale Power, LLC Submittal of Presentation Materials Entitled ACRS Presentation: NuScale Control Room Staffing Topical Report, PM-101338, Revision 0 The purpose of this submittal is to provide presentation materials to the NRC for use during the upcoming Advisory Committee on Reactor Safeguards (ACRS) Full Committee meeting on April 8, 2021.

The enclosure to this letter is the nonproprietary presentation entitled ACRS Presentation:

NuScale Control Room Staffing Topical Report, PM-101338, Revision 0.

This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.

If you have any questions, please contact Nadja Joergensen at 541-452-7338 or at njoergensen@nuscalepower.com.

Sincerely, Carrie A. Fosaaen Director, Regulatory Affairs NuScale Power, LLC Distribution: Anna Bradford, NRC Michael Snodderly, NRC Michael Dudek, NRC Getachew Tesfaye, NRC Bruce Bavol, NRC

Enclosure:

ACRS Presentation: NuScale Control Room Staffing Topical Report, PM-101338, Revision 0 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

LO-101340

Enclosure:

ACRS Presentation: NuScale Control Room Staffing Topical Report, PM-101338, Revision 0 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

NuScale Nonproprietary ACRS Presentation NuScale Control Room Staffing Topical Report April 8, 2021 1

PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Presenters Jim Osborn Licensing Engineer 4 Doug Bowman Plant Operations Supervisor Patrick Leary Senior Reactor Operator 5 Nadja Joergensen Licensing Supervisor 2

PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Agenda

  • Regulatory requirements
  • Topical report purpose and overview
  • Revised control room staffing
  • Shift technical advisor (STA)
  • Questions 3

PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Regulatory Requirements and Guidance

- Appendix B- Methodology to Assess the Workload of Challenging Operational Conditions in Support of Minimum Staffing Level Review

- Minimum staffing requirements per shift for on-site staffing at nuclear power units

- STA training program 4

PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Topical Report Purpose

  • The topical report is intended to be used as an alternate method for a future licensee to establish minimum licensed operator control room staffing.
  • A future license applicant will use the approved topical report as a technical basis to support an exemption request from:

- 10 CFR 50.54(m), or

- Other alternative control room staffing regulations (e.g., design certification rule)

- And, 10 CFR 50.120(b)(2)(iii)

  • This future licensee would adopt the control room staffing levels from the topical report as part of their Technical Specifications 5

PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Contents of Topical Report

  • Regulatory acceptance criteria and requirements
  • Conditions of applicability
  • Input to staffing plan from Human Factors Engineering Program

- Task Analysis

- Staffing and Qualification Analysis

  • Analysis of the STA position
  • Additional staffing considerations (RG 1.114 and senior reactor operator (SRO) oversight of refueling)
  • Staffing Plan Validation (SPV) Trials
  • Revised Staffing Plan Validation (RSPV) Trials 6

PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Operator Roles for Advanced Design Passively Cooled Reactors NuScale Human Factors Engineering analysis has focused on the changing role of control room staff:

  • Engineering design improvements resulted in overall lower operational complexity and no operator actions for design bases events
  • Control Room design advances result in lower crew workload, and significantly improve situational awareness
  • Decades of industry wide improvements in license operator training has increased operator readiness with specific relevance to operation of the facility All initial HFE trials have shown operators have very high situational awareness, very low workload, and large time margins in task completion in this plant design
  • Staffing Plan Validation, Integrated Systems Validation
  • Informational internal tests 7

PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Revised Control Room Staffing

  • Two senior reactor operators, one reactor operator
  • The same methodology was used for the original Staffing Plan Validation (SPV) and the Revised Staffing Plan Validation (RSPV)
  • Minor differences between the SPV and RSPV are described in the RSPV Test Report 8

PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Revised Control Room Staffing

  • Test result of Revised Staffing Plan Validation remained in line with earlier tests
  • Task performance was successful
  • Large margins to completion of timed activities retained
  • Low workload scores
  • Even when measured workload reached relatively higher levels, task performance was not negatively affected during these scenarios
  • High situational awareness scores
  • Notably, scores remained high during the peaks in measured workload - demonstrating that test participants maintained awareness of plant conditions even during challenging situations 9

PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Shift Technical Advisor

  • STA requirement established after the TMI-2 accident as an interim measure

- NUREG-0737 states that, the STA position may be eliminated when the qualifications of the shift supervisors and senior operators have been upgraded and the man-machine interface in the control room has been acceptably upgraded.

  • The topical report presents how these two conditions have been met for the NuScale Power Plant 10 PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Shift Technical Advisor

  • Upgrades to training of licensed operators

- NUREG-0737 training requirements now incorporated:

  • developed using a systems approach to training (as required by 10 CFR Part 55)
  • Includes the (generic fundamental) math, physics, thermodynamics, and component design topics that are of specific relevance to the operation of a nuclear power plant
  • training for mitigating core damage
  • plant specific training, including:

>> plant systems, plant specific reactor technology (including core physics data),

plant chemistry and corrosion control, reactor plant materials, reactor plant thermal cycle, transient/accident analysis, emergency procedures

- Completion of the training is required by NUREG-1021, and specifically delineated on NRC Form 398, Personal Qualification Statement-Licensee.

11 PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Shift Technical Advisor

  • NuScale Control Room Upgrades

- HSI features that provides 'at-a-glance' assessment of plant conditions and facilitates early detection of degrading conditions

  • condensed and easily viewable overview screens, safety function displays
  • ease of navigation
  • universal display of active processes

- safety function monitoring integrated into the man-machine interface

- emergency operating procedures are embedded into the interface and directly linked to the safety functions

- active monitoring of emergency action levels in the emergency plan 12 PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

STA - Additional Considerations

  • Additional Considerations for NuScale Power Plants

- advances in design features reduce the need for additional oversight

- the use of passive safety features and lower operational complexity have resulted in no required operator actions for design basis events, as well as improvement in overall safety

- the design only has two IHAs associated with beyond design basis events that have a very small probability of occurrence

  • both IHAs are simple, straight-forward actions that can be completed from the MCR by a single operator
  • these IHAs also have large time margins to complete tasks that historically would need to be performed without delay 13 PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Human System Interface 14 PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Questions?

15 PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Acronyms CRS Control Room Supervisor DCA Design Certification Application HFE Human Factors Engineering HSI Human System Interface IHA Important Human Actions MCR Main Control Room NRC Nuclear Regulatory Committee RO Reactor Operator RSPV Revised Staffing Plan Validation SDA Standard Design Application SM Shift Manager SPV Staffing Plan Validation SRO Senior Reactor Operator STA Shift Technical Advisor 16 PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Portland Office Richland Office 6650 SW Redwood Lane, 1933 Jadwin Ave., Suite 130 Suite 210 Richland, WA 99354 Portland, OR 97224 541.360.0500 971.371.1592 Charlotte Office Corvallis Office 2815 Coliseum Centre Drive, 1100 NE Circle Blvd., Suite 200 Suite 230 Corvallis, OR 97330 Charlotte, NC 28217 541.360.0500 980.349.4804 Rockville Office 11333 Woodglen Ave., Suite 205 Rockville, MD 20852 301.770.0472 http://www.nuscalepower.com Twitter: @NuScale_Power 17 PM-101338 Revision: 0 Copyright 2021 by NuScale Power, LLC.

Template #: 0000-21727-F01 R6

Presentation to the ACRS Committee NuScale Power, LLC (NuScale)

Safety Evaluation NuScale Control Room Staffing Plan Topical Report (TR)-0420-69456, Revision 1 April 8, 2021

Technical Reviewers:

Maurin Scheetz Lauren Nist Jesse Seymour Project Manager:

Getachew Tesfaye 2

Topical Report Application Review Overview Topical Report Application Audit and Request for Additional Information Revised Topical Report Information SECY on STA Elimination 3

The staff concludes the proposed staffing is acceptable.

Task performance results, workload STA tasks re-scores, and allocation situation reasonable awareness acceptable Additional Test factors that methodology Sufficient support STA role adequate technical elimination justification to approve the topical report 4

Measuring Workload:

NASA Task Load Index (TLX)

  • A commonly used method, validated in numerous studies, used in nuclear industry
  • Self-reported metric of perceived workload
  • Multi-dimensional ratings on six subscales:
  • Mental Demands
  • Physical Demands
  • Temporal Demands
  • Own Performance
  • Effort
  • Frustration 5

The staff considered additional factors that support STA elimination.

Licensed Operator Second SRO Training on shift can Programs assist Operators have time to No Immediate get off-shift Operator assistance Actions Validation test Control STA not results and Room HSI staff design necessary observations 6

  • Office Overview
  • Program Updates
  • Office Focus Areas
  • ACRS Recommendations Agenda
  • Division Overviews
  • Engineering
  • Risk Analysis
  • Systems Analysis
  • Discussion 2

Office at a Glance: RES 3

4

Nuclear Energy Innovation Capabilities Act MOU Integrated University Program Research &

Development Grants Research Program Future-Focused Research Updates Code Investment Plan External Engagement and International Collaboration 6

Research Priority Areas for FY21-23

  • Advanced Reactors
  • Fleet Modernization / Use of New Technology
  • LWR Long Term Operation
  • Digital Twins
  • Advanced Manufacturing
  • Human Performance
  • Cybersecurity
  • Building Success with FIDES
  • Strengthening University Ties and Innovation 7

ACRS 2020 Biennial Recommendations Office Recommendations

  • Initiate effort for research projects with longer-term horizons to help prepare the agency for upcoming challenges
  • Strength collaboration with other Agencies and Organizations
  • Effective process for terminating research activities that cease to be an agency priority Action Taken
  • Established FFR Program, IUP R&D, and Agency Innovation Program
  • Executed NEICA MOU, Founding FIDES under NEA, Strengthened Collaboration with EPRI and DOE
  • Program Review Engagement with NRR through program reviews, closure of old user needs, culture that supports necessary research starts and stops 8

9 Overview of Research Activities

Division of Engineering

$12.2M; 68 FTE Component Corrosion & Instrumentation, Structural, Regulatory Integrity Branch Metallurgy Controls & Geotechnical & Guidance & Generic Raj Iyengar Branch Electrical Seismic Engineering Issues Branch Steve Frankl Engineering Branch Meraj Rahimi Branch Dogan Seber Chris Cook

Component Integrity, Corrosion, and Metallurgy

  • Regulatory Purpose
  • Enhancing analytical computational modeling and capabilities, assessing materials degradation in operating reactors, and evaluating advanced reactor materials and advanced manufacturing technologies
  • Key Milestones in FY21
  • Establish LWRS NEICA Addenda
  • Issue remaining technical letter reports for AMT
  • NEA FIDES approval for materials Joint Experimental Projects (JEEPS)
  • TLR on the state of technology of applications of digital twins
  • Long-term Plans
  • Code development plan/strategy (xLPR, FAVOR)
  • Guidance development for molten salt and graphite reviews
  • Use of data analytics, AI/ML, etc., digital twins for materials

Electrical Engineering, Instrumentation, and Controls

  • Regulatory Purpose
  • Enhance acceptance criteria for LTO, review industry guidance, confirm condition monitoring techniques
  • Support licensing reviews, update regulatory guidance on IEEE & IEC consensus codes and standards, streamline regulatory guidance
  • Enhance cybersecurity program
  • Key Milestones in FY21
  • Completion of cable aging and LOCA testing
  • TLR & RG on degraded voltage and loss of voltage protection
  • Initiate development of criteria for review of wireless technologies
  • Build cybersecurity research capacity
  • Long-term Plans
  • Build cybersecurity research capacity
  • Complete cable LOCA testing and analysis

Structural, Geotechnical and Seismic Engineering

  • Regulatory Purpose
  • Support seismic safety assessments and POAHNI, enhance use of risk in determining seismic hazard estimates
  • Support LTO actions, improve understanding of risk-significance of structural issues and risk-inform licensing decisions
  • Key Milestones in FY21
  • Joint USGS research on seismic hazard & source characterization
  • TLRs on ASR and concrete degradation
  • Research on irradiation induced concrete degradation
  • Identify alternative regulatory pathways for RIPB seismic safety
  • Long-term Plans
  • Initiate activities related to seismic isolation for ANLWRs
  • Issue/update guidance on concrete structures and containment
  • Pursue harvesting opportunities

Agency Program Support

  • Regulatory Purpose
  • Coordination of agencywide programs related to Regulatory Guides, Generic Issues, and consensus codes & standards
  • Key Milestones in FY21
  • Update MD 6.6 for Regulatory Guides
  • Continue program support for the High Energy Arc Fault pre-GI
  • Coordinate participation in Standards Development Organization, and conduct the Annual Standards Forum
  • Engage industry on interest & prioritization of standards for ANLWRs
  • Long-term Plans
  • Increase resources to support regulatory guidance development across all business lines

Division of Risk Analysis

$8.7M; 42 FTE Probabilistic Risk Performance & Fire and External Human Factors &

Assessment Branch Reliability Branch Hazards Branch Reliability Branch John Nakoski Mehdi Reisi Mark Henry Sean Peters Fard Salley

PRA Tools and Methods Development

  • Regulatory Purpose
  • Maintain and enhance tools & methods to perform risk evaluations to support the agencys licensing and oversight responsibilities and to optimize use of NRC resources
  • Key Milestones
  • Finalize cloud based SAPHIRE in FY22
  • Complete Level 3 PRA project in FY23
  • Long-term Plans
  • Improve access to risk insights for all NRC staff by building off of SPAR models, Level 3 PRA project, data analytics, and risk application.
  • Develop risk assessment guidance documents
  • Update SPAR models (routine updates, FLEX, external hazards)
  • Develop SPAR models for new reactor designs

Assessment of Plant Performance and Equipment Reliability

  • Regulatory Purpose
  • Better inform the staffs understanding of integrated reactor and site risk providing risk insights about safety margins relative to the Commission Safety Goals
  • Key Milestones
  • Complete Annual Accident Sequence Precursor (ASP) Report (FY21)
  • User-friendly data visualization of ASP findings (FY21)
  • Continue to collect and analyze data on NPP operation
  • Publish trial use endorsement of Advanced non-LWR PRA Standard (FY22)
  • Long-term Plans
  • Development of consensus standards on PRA and develop guidance on the application of approaches and methods that support the use of risk tools in regulatory decisionmaking
  • Feasibility study of using predictive analytical methods to study OpE data
  • Explore applicability of LMP concepts to current generation of LWR plants
  • More explicit consideration of the risk of all hazards and uncertainties in analyses

Analysis of Fire and External Hazards

  • Regulatory Purpose
  • Reduce variability and increase realism of the NRCs and licensees risk analyses
  • Key Milestones
  • Complete Pre-Generic Issue 018 on aluminum High Energy Arcing Faults (HEAF) in FY22
  • Complete Probabilistic Flood Hazard Assessments (PFHA) pilot projects (FY21)
  • Long-term Plans
  • Develop guidance for NMSS on subsurface surveys for decommissioning sites and evapotranspiration covers at UMTRCA sites
  • Publish PFHA Guidance
  • Investigate potential fire risk for advanced reactors

Evaluation of Human Factors and Reliability

  • Regulatory Purpose
  • Reduce variability and increase realism of the NRCs and licensees risk analyses
  • Key Milestones
  • Publish Human Factors Engineering Review Guidance for non-LWRs (FY21)
  • Complete efforts to develop data structure and performance influencing factor effects for the IDHEAS method (FY22)
  • Long-term Plans
  • Human reliability and human factors evaluations of physical security simulation programs
  • HRA data collection to support HRA methods
  • Improve NRC capabilities and use of HRA tools in all program offices for risk-informed decision-making

Division of Systems Analysis

$17.2M; 62 FTE Code and Fuel and Source Accident Analysis Radiation Reactor Analysis Term Code Branch Protection Branch Branch Development Jonathan John Tomon Chris Hoxie Branch Barr Hossein Esmaili

DSA Focus Areas

  • Near-term ATF, High Burnup/High Enrichment Readiness
  • Advanced Reactor Readiness
  • Code Development and Maintenance
  • Data Science and Artificial Intelligence
  • Leveraged Experimental Programs and Collaborations with EPRI, DOE, CSNI and other organizations
  • Leveraged Code Enhancements and In-Kind Contributions through RAMP, CAMP and CSARP Code Sharing Programs
  • Code Investment Plan
  • Future Focused Research Activities 21

Thermal-Hydraulics Analysis

  • Regulatory Purpose
  • Maintain and enhance tools & expertise to support the agencys licensing in the areas of thermal-hydraulic, reactor core physics, coolant systems performance and computational fluid dynamics analyses for light water and advanced reactors
  • Key Milestones
  • Released versions of TRACE and SNAP (FY21)
  • Completed several BlueCRAB Advanced Reactor reference plant models (FY21)
  • Completed regulatory support for NuScale (FY20) and SHINE facility (FY21)
  • Completion of Palo Verde and Point Beach plant decks (FY21)
  • Long-term Plans
  • Perform confirmatory analyses for ATF/HBU, SMR and Advanced Reactor licensing as requested
  • Complete Implementation of Advanced Reactor code development plans
  • Modernize TRACE/PARCS plant decks
  • Assess TRACE against data from CSNI/NEA experimental programs, including Rod Bundle Heat Transfer at Penn State University

Fuels and Neutronics Analysis

  • Regulatory Purpose
  • Maintain and enhance tools & expertise to support the agencys licensing in the areas of fuel performance and neutronics analyses for light water and advanced reactors
  • Key Milestones
  • Released FAST 1.0, SCALE and PARCS to support ATF and Advanced Reactors (FY21)
  • Completed many ATF/HBU-related milestones (FY20/21)
  • Assessed FAST with EBR-II Data for Metallic Fuel (FY21)
  • Completed reports for criticality/shielding of ATF/HBU transportation/storage (FY21)
  • Long-term Plans
  • Perform confirmatory analyses for ATF/HBU, SMR and Advanced Reactor licensing as requested
  • Complete implementation of Advanced Reactor code development plans
  • Assess FAST against data from FIDES JEEPs, OECD/NEA, and other international programs (SCIP, QUENCH-ATF)

Accident Progression and Source Term Analysis

  • Regulatory Purpose
  • Maintain and enhance tools & expertise to support the agencys licensing in the areas of source term and severe accident analyses for light water and advanced reactors
  • Key Milestones
  • Released new version of MELCOR (FY21)
  • Complete RG 1.183 analysis for HBU near-term ATF concepts
  • Completion of Severe Accident PIRT for ATF/HBU (FY21)
  • Completed MELCOR Advanced Reactor reference plant models (FY21)
  • Planning public workshops for Advanced Reactor source term project (FY21), and source term calculations for HBU Fuel (FY21) and Cr-Coated cladding (FY22)
  • Long-term Plans
  • Perform confirmatory analyses for ATF/HBU, SMR and Advanced Reactor licensing as requested
  • Complete MELCOR Modernization (FY24)
  • Complete Implementation of Advanced Reactor Code Development Plans

Consequence Analysis & Data Science/AI

  • Regulatory Purpose
  • Maintain and enhance tools & expertise to support the agencys licensing and oversight activities in the areas of severe accident response and offsite consequences
  • Build expertise in data science and the use of artificial intelligence to support regulatory reviews that utilize these new capabilities
  • Key Milestones
  • Releases of MACCS v4.0/4.1 incorporate near-field atmospheric transport and dispersion models for SMR and Advanced Reactor licensing (FY20/21)
  • *Complete SOARCA UA summary report (FY21)
  • Complete AI Strategy document (FY21/22)
  • Complete Level 3 PRA (FY23)
  • Long-term Plans
  • Perform confirmatory analyses for SMR and Advanced Reactor licensing as requested
  • Identify and complete AI/ML use cases to build staff expertise and organizational capacity

Radiation Protection Analysis

  • Regulatory Purpose
  • Maintain and enhance tools & expertise to support the agencys licensing and oversight activities in the areas of radiation protection and health physics for light water and advanced reactors
  • Key Milestones
  • Complete annual congressional Abnormal Occurrence (AO) and Radiation Exposure Information and Reports System (REIRS) Reports
  • Code development and maintenance for 17 siting/licensing dose assmt. codes
  • Support incident response and dose assessment using RASCAL and RADTRAN
  • Released NRC-RADTRAN v1.0, NRCDose3 v1.3, HABIT v2.2, RADTRAD-AC v5.0.2, Turbo FRMAC & IMBA to the RAMP website. Added new codes to RAMP (FY20/21)
  • Consolidate atmospheric transport and dispersion models (FY22)
  • Long-term Plans
  • Perform confirmatory analyses for ATF/HBU, SMR and Advanced Reactor licensing as requested
  • Complete RASCAL 5.0 development and RAMP Code consolidation efforts (FY23)

Closing Remarks

  • Value from Committee Feedback
  • Looking forward to RES Division Interactions
  • Open to suggestions on approach, structure, and topics 27

References

  • ACRS Biennial Review and Evaluation of the NRC Safety Research Program, dated April 13, 2020 (ML20100F066)
  • Office Response Letter, dated May 19, 2020 (ML20136A330) 28

Acronyms

  • HEAF - High-Energy Arc Fault
  • REIRS - Radiation Exposure Information and Reporting
  • AMT - Advanced Manufacturing Technologies
  • HRA - Human Reliability Analysis System
  • ANLWR - Advanced Non-Light Water Reactor
  • IAD - Irradiation-Assisted Degradation
  • RES - Office of Nuclear Regulatory Research
  • AO - Abnormal Occurrence
  • IDHEAS - Integrated Human Event Analysis System
  • RG - Regulatory Guide
  • RIPB - Risk-Informed, Performance, Based
  • ASR - Alkali-Silica Reaction
  • ISG - Interim Staff Guidance
  • LAR - License Amendment Request
  • SACADA - Scenario Authoring, Characterization, and
  • BWR - Boiling Water Reactor
  • LOCA - Loss of Coolant Accident Debrief Application
  • CAMP - Code Application and Maintenance Program
  • IUP - Integrated University Program
  • SAPHIRE - System Analysis Program for Hand-on
  • CSARP - Cooperative Severe Accident Research
  • MACCS - MELCOR Accident Consequence Code System Integrated Reliability Evaluations Program
  • NEA - Nuclear Energy Agency
  • SCALE - Standardized Computer Analyses for Licensing
  • CBJ - Congressional Budget Justification
  • CCF - Common Cause Failure
  • NPP - Nuclear Power Plant
  • SCIP - Studsvik Cladding Integrity Project
  • CFD - Computational Fluid Dynamics
  • OEDO - Office of the Executive Director for Operations
  • SNAP - Symbolic Nuclear Accident Package
  • DI&C - Digital Instrumentation and Controls
  • OpE - Operating Experience
  • SOARCA - State-of-the-Art Reactor Consequence Analyses
  • DOD - U.S. Department of Defense
  • PARCS - Purdue Advanced Reactor Core Simulator
  • SPAR - Standardized Plant Analysis Risk
  • DOE - U.S. Department of Energy
  • PFM - Probabilistic Fracture Mechanics
  • SRM - Staff Requirements Memorandum
  • EDD - Embedded Digital Devices
  • SWP - Strategic Workforce Planning
  • EPID - Enterprise Project Identification
  • TRACE - TRAC/RELAP Advanced Computational
  • EPRI - Electric Power Research Institute
  • RADTRAD - Simplified Model for Radionuclide Transport Engine, or expanded, Transient Reactor Analysis Code,
  • EPZ - Emergency Planning Zone and Removal And Dose Estimation Reactor Excursion and Leak Analysis Program, Advanced
  • FAST - Fuel Analysis under Steady-state and Transient
  • RAMP - Radiation Protection Computer Code Analysis Computational Engine
  • FIDES - Framework for Irradiation Experiments and Maintenance Program
  • UA - Uncertainty Analysis
  • FTE - Full Time Equivalents
  • RASCAL - Radiological Assessment Systems for
  • xLPR - Extremely Low Probability of Rupture Code
  • GALE - Gaseous and Liquid Effluents Code Consequence Analysis
  • GI - Generic Issue 29