ML21223A098
| ML21223A098 | |
| Person / Time | |
|---|---|
| Issue date: | 06/25/2021 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Antonescu, C, ACRS | |
| References | |
| NRC-1564 | |
| Download: ML21223A098 (121) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Digital I&C Subcommittee Docket Number:
(n/a)
Location:
teleconference Date:
Friday, June 25, 2021 Work Order No.:
NRC-1564 Pages 1-104 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 DIGITAL I&C SUBCOMMITTEE 7
+ + + + +
8 FRIDAY 9
JUNE 25, 2021 10
+ + + + +
11 The Subcommittee met via Teleconference, 12 at 9:30 a.m. EDT, Charles H. Brown, Chair, presiding.
13 14 COMMITTEE MEMBERS:
15 CHARLES H. BROWN, JR., Chair 16 VICKI M. BIER, Member 17 VESNA B. DIMITRIJEVIC, Member 18 GREGORY H. HALNON, Member 19 WALTER L. KIRCHNER, Member 20 JOSE MARCH-LEUBA, Member 21 DAVID A. PETTI, Member 22 JOY L. REMPE, Member 23 MATTHEW W. SUNSERI, Member 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 ACRS CONSULTANT:
1 MYRON HECHT 2
3 DESIGNATED FEDERAL OFFICIAL:
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 AGENDA 1
Item Page 2
Opening Remarks by Chairman...........
4 3
Introductory Remarks 9
4 Purpose, Scope, and Regulatory Basis of RG 1.9
. 12 5
Purpose and Goals for Development of Proposed 6
Rev. 5 to RG 1.9 7
NRC Staff Positions in the Proposed Rev. 5 of 8
..................... 68 9
Resolution of Public Comments.......... 75 10 Status and Next Steps for Completion of 11 Final Rev. 5 to RG 1.9
............. 88 12 Public Comments................. 91 13 Closing Remarks by Chairman..........
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4 P R O C E E D I N G S 1
9:33 a.m.
2 CHAIR BROWN: It's 9:33. I'm going to --
3 I'm just checking the list of members that are here 4
right now so I make sure I get the names all correct.
5 MS. ANTONESCU: Awesome.
6 CHAIR BROWN: What I understand is --
7 Jose, you're here?
8 MEMBER MARCH-LEUBA: Yes, I'm muted.
9 CHAIR BROWN: Okay. Dave Petti?
10 MEMBER PETTI: Here.
11 CHAIR BROWN: Okay. Vicki?
12 MEMBER BIER: Yes, I'm here mainly just to 13 listen.
14 CHAIR BROWN: That's fine. Walt?
15 MEMBER KIRCHNER: Here, Charlie. Thank 16 you.
17 CHAIR BROWN: Okay. Thank you. If 18 there's other members on here that I haven't been able 19 to catch, let me know. I'm not trying to forget you 20 intentionally.
21 MEMBER HALNON: Charlie, this is Greg 22 Halnon. I'm on.
23 CHAIR BROWN: Yeah, oh, I missed you?
24 Okay. I thought --
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5 (Simultaneous speaking.)
1 MEMBER REMPE: This is Joy. I'm here.
2 CHAIR BROWN: Oh, Joy, you're there? All 3
right.
4 MEMBER SUNSERI: Charlie, this is Matt.
5 I'm on.
6 CHAIR BROWN: Oh, all right. So we're in 7
good shape then. I couldn't see anything on the 8
participants list for some reason.
9 MEMBER DIMITRIJEVIC: I'm here, Charlie.
10 It seems like you have a full house. Vesna, hi, good 11 morning.
12 CHAIR BROWN: All right. Thank you, Vesna 13 and Matt. And Dennis, is he on? I don't think so.
14 All right. Sorry for the delay. I'm 15 Charles Brown. I'm the Chairman for the Digital I&C 16 Subcommittee. The meeting will now come to order.
17 ACRS members in attendance are Matt 18 Sunseri, Jose March-Leuba, Vesna Dimitrijevic, Joy 19 Rempe, Dave Petti, Vicki Bier, Greg Halnon, and Walt 20 Kirchner. And Myron is not on right now. So he may 21 or may not be here.
22 MS. ANTONESCU: Member Brown, Myron is 23 here, too.
24 CHAIR BROWN: Oh, he is? Okay. I missed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 him.
1 All right. Christina Antonescu of the 2
ACRS staff is the Designated Federal Official for this 3
meeting. I presume, Christina, that the court 4
reporter is here and it is now on?
5 MS. ANTONESCU: Yes, he is.
6 CHAIR BROWN: Thank you. The purpose of 7
this meeting is for the staff to brief the 8
subcommittee on Proposed Revision 5 of Regulatory 9
Guide 1.9, Application and Testing of Onsite Emergency 10 Alternating Current Power Sources in Nuclear Power 11 Plants.
12 It is being revised to endorse updated 13 IEEE Standard 387-2017 for EDGs and incorporates 14 combustion turbine generators and endorses 2520-2019 15 IEEE Standard, CTGs for use as standby power supplies 16 for nuclear power generating stations, and provides 17 guidance for alternating power sources other than EDGs 18 and CTGs, which is a whole new section from the past.
19 The ACRS was established by statute and is 20 governed by the Federal Advisory Committee Act, FACA.
21 That means that the committee can only speak through 22 its published letter reports.
23 We hold meetings to gather information to 24 support our deliberations. Interested parties who 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 wish to provide comments can contact our office 1
requesting time.
2 That said, we set aside ten minutes for 3
comments from members of the public attending or 4
listening to our meetings. Written comments are also 5
welcome.
6 The meeting agenda for today was published 7
on the NRC's public meeting notice website, as well as 8
the ACRS meeting website.
9 On the agenda for this meeting and on the 10 ACRS meeting website are instructions as to how the 11 public may participate. No request for making a 12 statement to the subcommittee has been received from 13 the public.
14 Due to COVID-19, we are conducting today's 15 meeting virtually. A transcript of the meeting is 16 being kept and will be made available on our website.
17 Therefore, we request that participants in this 18 meeting first identify themselves and speak with 19 sufficient clarity and volume so that they can be 20 readily heard.
21 All presenters, please pause from time to 22 time to allow members to ask questions. Please also 23 indicate the slide number you are on when moving to 24 the next slide.
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8 We have a bridge line established for the 1
public to listen to the meeting. The public line will 2
be kept in a listen-only mode until the time for 3
public comment.
4 To avoid audio interference, I request all 5
attendees to make sure they are muted while not 6
speaking.
7 Can you confirm that the public line is 8
open?
9 MS. ANTONESCU: Thomas already confirmed 10 11 CHAIR BROWN: Okay. All right. Thank 12 you, Christina.
13 Based on our experience with previous 14 virtual meetings, I would like to remind the speakers 15 and presenters to speak slowly.
16 We will take a short break after each 17 presentation to allow time for screen sharing, as well 18 as the Chairman's discretion during longer 19 presentations.
20 We do have a backup call-in number should 21 MS Team go down and has been provided to the ACRS 22 members. If we need to go to the backup number, the 23 public line will also be connected to the backup line.
24 Lastly, please do not use any virtual 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 meeting feature to conduct sidebar technical 1
discussions. Rather, contact the DFO if you have 2
technical questions so we can bring those to the 3
floor.
4 We have scheduled a full committee meeting 5
in July 2021, which will be used to produce, generate 6
a report for this particular subcommittee meeting on 7
this Reg Guide.
8 We will now proceed with the meeting. I 9
believe Mr. Stanley Gardocki is doing the screen 10 sharing.
11 And Mr. Kenn Miller is the team leader for 12 the electrical engineering
- team, Division of 13 Engineering in the Office of Nuclear Regulatory 14 Research and will make introductory remarks before we 15 begin presentations by Ms. Liliana Ramadan. Kenn, 16 it's yours for your opening remarks.
17 MR. MILLER: Thank you, Member Brown, for 18 the introduction. Everybody hear me okay?
19 CHAIR BROWN: Yes.
20 MR. MILLER: Okay.
21 CHAIR BROWN: At least I can.
22 MR. MILLER: Okay. Good. So good morning 23 to the ACRS members and their staff, as well as other 24 participants in today's meeting.
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10 As was said, my name is Kenn Miller. I'm 1
a senior electrical engineer and team leader in the 2
Office of Research and as has been mentioned will be 3
presenting Version 5 of Reg Guide 1.9.
4 This revision was prepared by a team of 5
electrical engineers from both Research and NRR. We 6
found this to be an effective and efficient way, as 7
well as utilizing, you know, the broad technical 8
experience across our two offices to develop the best 9
technical product.
10 That effort was led by Research's Lili 11 Ramadan, worked very hard and diligently to get this 12 to this point, appreciate her efforts, in addition, 13 was supported by staff from NRR, Sheila Ray and Singh 14 Matharu. And the overall project manager also from 15 Research is Stan Gardocki, as has been mentioned.
16 And we also want to thank Christina for 17 her efforts in helping us set up this meeting with you 18 folks today at ACRS.
19 So this revision of 1.9 represents a 20 modification to its scope in that all previous 21 revisions addressed only the use of diesel engines as 22 the prime mover for emergency generators, while this 23 version takes a design-neutral approach in terms of 24 prime movers.
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11 It addresses diesels, combustion turbines, 1
and any other AC source potentially employed to supply 2
emergency electrical power.
3 This Reg Guide, as was mentioned also, 4
endorses the current version of IEEE 387 for emergency 5
diesel generators, as well as 2420 for combustion 6
turbines.
7 All other types the approach was to 8
identify and highlight all the necessary regulatory 9
requirements for onsite emergency AC power sources in 10 accordance with GDC 17.
11 In
- addition, this design-neutral 12 innovative and transformative approach allows for more 13 widely useful Reg Guide for newer plant designs of all 14 types, including small modulars and advanced reactors, 15 and supporting the plan to consolidate NRC's 16 regulatory guidance footprint.
17 This consolidation will reduce staff 18 effort needed to maintain regulatory guidance, also 19 should make it easier for industry to find and apply 20 necessary guidance in their activities.
21 So, again, we appreciate this opportunity 22 today to present this revision to you. And we can 23 move on with the agenda. Thank you very much.
24 CHAIR BROWN: Okay. Thank you, Kenn.
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12 Liliana, I guess you're on.
1 MS. RAMADAN: Thank you. Today's agenda, 2
we will be introducing this Regulatory Guide. We will 3
be discussing the existing guidance. We will be 4
pointing out the significant changes. We will be 5
discussing the proposed new guidance. And we will 6
summarize. Next slide, slide 3.
7 The current 2007 version, Reg Guide 1.9, 8
Revision 4 covers only the diesel generator --
9 CHAIR BROWN: Liliana?
10 MS. RAMADAN: -- technology.
11 CHAIR BROWN: Liliana?
12 MS. RAMADAN: Yes.
13 CHAIR BROWN: The screen sharing at least 14 is not showing up on my screen. There's the agenda --
15 MEMBER REMPE: It shows up on my screen, 16 Charlie. But --
17 CHAIR BROWN: The agenda just popped up.
18 MEMBER REMPE: Okay. There is a large 19 echo. So, if somebody has their mic on, please mute 20 it.
21 MS. RAMADAN: Okay.
22 CHAIR BROWN: I just lost the screen 23 sharing completely. The agenda is back up. You're on 24 slide 2 from what I understand right now as opposed to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 3 I think. Which one do you want, 3?
1 MS. RAMADAN: Slide 3.
2 CHAIR BROWN: Okay. There's slide 3. All 3
right. Thank you.
4 MS. RAMADAN: Okay. So the current 2007 5
version of Reg Guide 1.9, Revision 4 covers only 6
diesel generator technology and endorses with 7
exceptions the 1995 version standard of IEEE. 8 In this Revision 5, the NRC wanted to 9
implement a technology-neutral concept and include all 10 users of onsite emergency AC power sources.
11 In order to ensure a consistent regulation 12 in an innovative and transformative approach, the 13 staff is proposing this new revision to provide the 14 reasonable assurance on the evaluation criteria for 15 onsite emergency AC power sources to be applied 16 uniformly to the operating fleet, new, advanced, small 17 modular reactors, and nuclear facilities.
18 The benefits of converting Reg Guide 1.9 19 would be to reduce the number of Reg Guides that will 20 be required to cover each alternative.
21 It will also reduce the review process, 22 which includes public comments, and facilitate the 23 application processes by industry to use alternative 24 onsite emergency power supplies in the future. Next 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 slide, slide 4.
1 MEMBER REMPE: Could I interrupt with a 2
couple of questions, please?
3 MS. RAMADAN: Yes.
4 MEMBER REMPE: Okay. So some of the 5
material we received indicated that your office asked 6
the Office of Research to do a Research Assistance 7
Request. And out of curiosity, I was wondering what 8
research they provided that helped you update this Reg 9
Guide? Could you give some examples?
10 MS. RAMADAN: Could you repeat the 11 question, please?
12 MEMBER REMPE: Okay. So we were given 13 some material to review in preparation for this 14 meeting. And one of the items indicated that your 15 office asked the Office of Research, using a Research 16 Assistance Request, to help support the revision of 17 this Reg Guide.
18 And so please confirm that that 19 information is correct, because it was actually in a 20 status report we were given. But it piqued my 21 curiosity. And if it is correct, could you give me 22 some examples of what Research did to help you revise 23 this Reg Guide?
24 MS. RAMADAN: I will turn that over to our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 team lead, Kenn Miller. Kenn?
1 MR. MILLER: Yes. Can you hear me there?
2 MEMBER REMPE: I can.
3 MR. MILLER: Okay. So, in reference to 4
your question, I guess one thing I would mention, RAR 5
is a product of our work request system. It's a way 6
to, you know, to identify a scope of work to do and 7
then complete it. And it's usually submitted from the 8
organization that's wanting to do the particular work.
9 In this case, there wasn't particular 10 research per se that was done in reference to 11 development of this Reg Guide. It was primarily, 12 again, as was said, based on endorsing the newest 13 version of 387, as well as the new version of 2420 14 and, again, the general goal of going to a design-15 neutral approach.
16 So I guess specifically then there wasn't 17 actual research per se done to support this. And, 18 again, the terminology of the work request is I think 19 what gave you that question. So, okay, hopefully that 20 answers your --
21 MEMBER REMPE:
I appreciate the 22 clarification. Thank you.
23 MR. MILLER: Okay. You're --
24 MEMBER REMPE: The other question I had is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 related to what happened at Fukushima.
1 At the beginning of the Reg Guide, they 2
talked about the general design criteria. And they 3
mentioned the need to protect from seismic events, as 4
well as flooding events.
5 And later in the document they do mention 6
seismic events. But they don't ever talk about the 7
need to have leaktight doors, which I know are 8
existing in our U.S. plants.
9 But is that just in a different Reg Guide, 10 or why didn't this Reg Guide or even the IEEE standard 11 mention the need to consider location to protect from 12 flooding? Did anyone here my question? Or there's 13 dead silence.
14 CHAIR BROWN: I did.
15 MS. RAY: Lili, do you mind if I take that 16 one?
17 MS. RAMADAN: Go ahead, Sheila.
18 MS. RAY: This is Sheila Ray, senior 19 electrical engineer in NRR. Thank you, Member Rempe, 20 for your question.
21 So this, the IEEE standards are really on 22 the power sources themselves, on the electrical 23 aspects. However, there is an IEEE standard on 24 flooding, internal flooding that we are looking at.
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17 It's actually in development currently. So that is 1
covered in a different IEEE standard. And I believe 2
that's 833.
3 MEMBER REMPE: And will there be a Reg 4
Guide endorsing this other standard then later? I'm 5
just surprised that this Reg Guide doesn't mention 6
that at all, since it does mention the general design 7
criteria.
8 MS. RAY: So, since we haven't developed 9
the Reg Guide for IEEE 833, we haven't mentioned it.
10 I anticipate that may come in a future revision. We 11 are planning on endorsing or reviewing IEEE 833 for 12 endorsement when it's published.
13 MEMBER REMPE: Okay. Thank you.
14 MS. RAY: You're welcome.
15 MS. RAMADAN: Okay. Moving on to slide 4, 16 as stated before, Reg Guide 1.9, Revision 4 endorse 17 IEEE standard 387-1995 as an acceptable method for 18 satisfying the Commission's regulation with respect to 19 the design, qualification, and periodic testing of 20 diesel generators typically used as onsite electric 21 power systems for nuclear power plants. Next slide.
22 This revision endorses the two IEEE 23 standards, IEEE Standard 387-2017 and IEEE Standard 24 2420-2019, in full with supplements and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 clarifications.
1 The first IEEE standard, 387-2017, is a 2
standard where emergency diesel generators are widely 3
used as standby emergency power sources for onsite 4
alternating AC power system. Next slide, slide 6.
5 The second standard, IEEE Standard 2420, 6
is a standard where new reactor designs incorporate 7
gas turbines to supply the standby emergency AC power 8
system.
9 The IEEE Standard 2420 also incorporates 10 the interim staff guidance and other technical and 11 regulatory documents needed to implement the 12 technology-neutral concept approach into this new 13 revision. Next slide, slide 7.
14 Can I be heard? Slide 7. Does that sound 15 better? Can someone confirm?
16 MR. MILLER: Yeah, you're coming through 17 fine, Lili. This is Kenn.
18 MS. RAMADAN: Thank you. Some of the, in 19 slide 7, some of the significant changes that occurred 20 in this revision can be found under the design and 21 application considerations section.
22 Specifically, the testability and 23 synchronization capabilities were supplemented to 24 address testing EDGs in the event of offsite power 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 source that ensures that the diesel is protected and 1
can withstand any perturbations.
2
- Also, in the design and testing 3
considerations section, we clarify the simulation of 4
parameters of operation by modifying how the EDGs 5
envelop the parameters of operation.
6 We also clarify the allowance of using EDG 7
owner group recommendations for accelerative 8
maintenance as appropriate for obtaining a valid 9
review of rating basis if it was not possible due to 10 the absence of EDG manufacturers. Slide 8.
11 We also supplemented both IEEE standards 12 to include clarification --
13 CHAIR BROWN: Liliana, would you go back 14 15 MS. RAMADAN: Yes.
16 CHAIR BROWN: -- to the previous slide?
17 MS. RAMADAN: Yes.
18 CHAIR BROWN: The -- you said in the 19 absence of who for the EDGs? I didn't understand the, 20 this manufacturer recommended accelerated maintenance.
21 MS. RAMADAN: In the absence of the EDG 22 manufacturers, if for whatever reason they're no 23 longer in existence, we are allowing --
24 CHAIR BROWN: Oh, okay.
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20 MS. RAMADAN: -- the use for EDG owner 1
group, the recommendations --
2 CHAIR BROWN: Okay.
3 MS. RAMADAN: -- from the EDG owner 4
groups.
5 CHAIR BROWN: All right. I remember that 6
now. Okay. Thank you.
7 MS. RAMADAN: It's no problem. Slide 8.
8 We also supplemented both IEEE standards to include 9
verification of all subsystems such as fuel oil, lube 10 oil, cooling, starting, and piping systems credited 11 for operation.
12 Other important changes that need to be 13 noted, many of the testing and design requirements 14 from Revision 4 were removed since they were already 15 incorporated in the updated IEEE 387-2017.
16 Also, the title of Reg Guide 1.9 changed 17 to be reflective of the technology-neutral approach.
18 Next slide.
19 The thought of this new proposed guidance, 20 as stated before, was to make this Reg Guide 21 technology-neutral to cover diesel engine driven, 22 combustion gas turbine, and other alternatives for 23 onsite standby emergency power supplies that meet the 24 intent of 10 CFR 50 and 10 CFR Part 52 requirements, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 as well as consider small modular reactors, advanced 1
reactors, and nuclear facilities.
2 The criteria that was used to evaluate 3
power sources other than the EDGs and CTGs was derived 4
from GDCs 17 and 18.
5 The type of power sources that could be 6
used as AC sources are typically that of generators, 7
alternators, and inverters. This could include 8
biodiesel generators, hydro plants, and/or wind farms 9
for the rotating turbines converting mechanical power 10 to electrical power.
11 This guidance allows for new --
12 CHAIR BROWN: Liliana?
13 MS. RAMADAN: Yes.
14 CHAIR BROWN: Would you run through that 15 again?
16 MS. RAMADAN: So the type of power sources 17 that could be used as AC sources are typically that of 18 generators, alternators, and inverters.
19 CHAIR BROWN: Liliana, aren't generators 20 the same as we have on diesels and CTGs?
21 MS. RAMADAN: Yes.
22 CHAIR BROWN: I mean, a generator is a 23 generator regardless. So that's not necessarily new, 24 is it? That's not an alternate source.
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22 MS. RAMADAN: It's --
1 CHAIR BROWN: It's the same as we have 2
today.
3 MS. RAMADAN: Yes. But I'm just trying to 4
demonstrate what type of sources we're referring to.
5 CHAIR BROWN: Okay. But the alternate --
6 you're talking about, this is the other sources, AC 7
sources other than EDGs and CTGs section, right?
8 MS. RAMADAN: Yes, correct.
9 CHAIR BROWN: Okay. So, I mean, a 10 generator is a generator. And you've already really 11 covered those in the EDG regardless of what the 12 generator -- the only two things you've covered are 13 combustion turbines and diesels. Generators can be 14 applied to anything else, but yet generator, an AC 15 generator is an AC -- it's mechanical.
16 MS. RAMADAN: Yes.
17 CHAIR BROWN: So put those aside for a 18 minute. What other AC power sources did you all put 19 on your, think about? I mean, I thought of some.
20 Wind turbines was obviously one. Solar panels would 21 be another. Fuel cells would be another.
22 MS. RAMADAN: Biodiesel.
23 CHAIR BROWN: Hydroelectric, that's 24 interesting --
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23 MS. RAMADAN: Yes.
1 CHAIR BROWN: -- if you have a big 2
reservoir to deal with. But if you back off to wind 3
turbines and solar cells and fuel cells, what was the 4
other one you listed?
5 MS. RAMADAN: Biodiesel generator.
6 CHAIR BROWN: Well, biodiesels, that's 7
still a diesel generator.
8 MS. RAMADAN: Yeah.
9 CHAIR BROWN: I mean, whether you run it 10 with the germs running through it or you use oil --
11 MS. RAMADAN: Right.
12 CHAIR BROWN: -- it doesn't really make a 13 whole lot of difference. Whether it's a vegetable oil 14 or diesel fuel, it's still the same.
15 MS. RAMADAN: Right.
16 CHAIR BROWN: So the real only other 17 emergency sources you could deal with would be wind 18 turbines, solar power, fuel cells, and then you 19 mentioned hydroelectric, but not a whole lot of 20 plants. You know, that's a difficult draw on the 21 hydroelectric. But that's fine. But they're still 22 generators.
23 MS. RAMADAN: Yes.
24 CHAIR BROWN: So the really only unique 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 items are, that would be, haven't been used would be 1
solar, wind, and fuel cells --
2 MS. RAMADAN: Correct.
3 CHAIR BROWN: -- which are -- two of those 4
are weather dependent.
5 I'm trying to think of -- I didn't see 6
any, you know, requirements or anything else in there 7
that would, I don't know, emphasize the fact that 8
weather -- how in the world can you depend on the 9
weather to make sure you have emergency power?
10 And there was nothing in the criteria you 11 provided in Section C1 that would allow you to come to 12 that conclusion that it was satisfactory.
13 MR. MILLER: Hey, Lili. This is Kenn.
14 Would you like me to weigh in here a little bit?
15 MS. RAMADAN: Sure, sure.
16 MR. MILLER: Okay. Yes, I think the 17 intent of this part of the presentation was just to 18 illustrate the fact that there could be lots of other 19 types of sources for emergency power or albeit prime 20 movers for a generator like is used in a diesel. I 21 don't think it was meant to be an exhaustive list.
22 And, again, with the approach on the Reg 23 Guide in dealing with sources other than diesels and 24 combustion turbines, the idea was to present the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 requirements that would have to be met in terms of the 1
regulation for any other source that a licensee might 2
choose to apply.
3 So, again, I don't think the intent was to 4
have an exhaustive list or that we had a particular 5
type of source in mind. The goal was to have the 6
generic requirements that apply to all types of onsite 7
sources as described in GDC to help the applicant or 8
the licensee answer the regulatory requirements for 9
whatever source they choose.
10 CHAIR BROWN: Well, that's interesting.
11 But Section C1 does not really provide. It's just a 12 bunch of, it's largely a -- you list capability and 13 testability and that type of stuff. Then you just say 14 they should review, assess, and discuss. It doesn't 15 even come close to the layout or the architecture of 16 the guidance that is provided in C2 and C3.
17 MS. RAMADAN: I understand that.
18 CHAIR BROWN: I mean, I had a little bit 19 of difficulty -- let me finish, please.
20 I went back through all of the IEEE 21 standards, as well as the previous Reg Guides. And 22 there are principal design criteria that are specified 23 in each of those areas. And if you look at those 24 principal design criteria, they are fundamentally 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 performance-based and technology-neutral. You have to 1
start and stop, for instance.
2 There's a whole section in the original 3
Reg Guide covering paralleling, for instance. And 4
that's not even mentioned in C1.
5 There's a whole section covering start 6
demand, start failures, run, load demand, load 7
failures, how you assess those. You copied that from 8
the EDG stuff and put it into the CDG area, CTG thing 9
because it wasn't covered in that IEEE standard.
10 I mean, it's just a, there's just --
11 there's nothing there. I mean, it's largely discuss 12 and review these various types of technical items and 13 discuss them, and then we'll figure out what's good or 14 not good on the fly. That's what it looked like.
15 I had a hard time understanding that and 16 why that was -- and it doesn't even parallel with the 17 layout of design criteria and laid out in terms of a 18 bulletized format. It's very difficult to understand 19 Section C1, very difficult.
20 MR. MILLER: So --
21 CHAIR BROWN: But if you look at the 22 principal -- Sections 1, 2, 5, 6, and 7 of the IEEE 23 standard plus the annexes are also, for the most part, 24 technology-neutral, I mean, other than a cooling 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 system or a particular lube oil requirements or 1
something like that, which may not apply.
2 They could have been tailored to apply to 3
any other type of source of which would be solar, 4
wind, and/or fuel cells, as well as biodiesels or 5
anything else. But the biodiesel would be covered 6
under, fundamentally all the requirements under C2.
7 So, I mean, it seems that there was just 8
very, very little technical information or guidance.
9 The lead-in on C1 literally said, hey, these are 10 considerations. Whereas, the lead-in for C2 and C3 11 used a different set of words interestingly enough.
12 I'm going to find it so I don't get it 13 wrong. For C1 you said, the following considerations 14 should be addressed to meet the regulations in Part A.
15 In C2 you talked about the following regulatory 16 positions supplement the guidelines as related to the 17 design and testing considerations.
18 There's a
big difference between 19 regulatory positions and considerations in terms of 20 things you should, you know, evaluate in terms of 21 their, what I would call a regulatory type impact.
22 Same thing for C3, that's the way that one reads.
23 So it just -- I was kind of taken back a 24 little bit that we didn't parallel the layout and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 architecture of C2 and C3 and develop that.
1 And then since we don't have any IEEE 2
standards or any other standards to cover alternate 3
sources, it looks like Reg Guide 1.9 by default 4
becomes the equivalent of IEEE standards for the other 5
two considerations.
6 And that does not come across as being 7
very definitive in terms of what an applicant would 8
have to consider. There's very little guidance given 9
to the applicant other than to think about stuff 10 without any of the clarifications or positions you've 11 referenced in either for the CTGs or the EDGs.
12 I'm just wondering what went into that 13 thought process that got you to such a generalized 14 listing in each of those long paragraphs with multiple 15 sentences saying look at this, look at that, assess 16 and discuss.
17 MR. MILLER: This is Kenn Miller. I'll 18 add a few more comments, and then the rest of the 19 team, feel free to weigh in on this.
20 And I think you summed it up pretty well 21 at the end there. The reality is that in the case of 22 C1 and C2 we have IEEE standards which go into a lot 23 of detail about those particular applications 24 utilizing diesels and combustion turbines. Whereas, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 Section C was meant to be very broad, because of the 1
range of different technologies that could be applied 2
to an onsite source.
3 CHAIR BROWN: You're talking about C1.
4 MR. MILLER: Yeah, I'm sorry.
5 CHAIR BROWN: That's okay.
6 MR. MILLER: The other section --
7 CHAIR BROWN: For the others, I was just 8
trying to clarify.
9 MR. MILLER: Yeah, the other section 10 dealing with other than diesels and combustion 11 turbines, again, the approach was more to look at what 12 are the regulatory, the regulation requirements that 13 any source would have to have.
14 It's recognized that there would be a lot 15 of additional work that a licensee would have to do to 16 apply some other technology to an onsite source. And 17 given that we don't have standards, other standards to 18 look at in that case, the idea was to at least 19 acknowledge that in a section and at least highlight 20 all the regulatory requirements.
21 I think that's really kind of the 22 overarching premise of how we chose to put this Reg 23 Guide together and why there's not as much detail in 24 terms of the other sources than diesels and combustion 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 turbines. But again, that's because we have 1
standards, industry standards that have been developed 2
to address those.
3 So, again, I would allow any of the other, 4
Lili or any other team members to weigh in as well on 5
that.
6 CHAIR BROWN: Let me just springboard off 7
of your comments. If you literally look at -- and 8
I've got the Reg Guide in front of me now. I'm 9
shuffling papers, so don't panic.
10 You've got a number of categories, safety 11 classifications, then safety function, capacity, 12 capability, physical and electrical independence. I 13 mean, when you talk about safety systems, if you look 14 at some of the Reg Guides you reference, there are 15 like 45 years old, 1975 and, or 35 or 25, 1995 Reg 16 Guides on sharing.
17 If you look at the IEEE standard and you 18 talk about, you know, they are specific. But under 19 the principal design criteria, it says forget the 20 words mechanical and electrical. It's not just design 21 conditions. The unit shall be capable of operating 22 during any design-basis event without support. That's 23 not in C1.
24 And then it goes on and talks about you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 should have a minimum of operating cycles, 4,000 1
starts over a period of 4 years. There's a series of 2
testing requirements. And they've got seismic 3
response factor you have to deal with.
4 All those, you know, a large number of all 5
those principal design criteria apply to any source in 6
C1, and yet they're not even talked about. In C1, 7
seismic is not even listed.
8 So it just comes down to, there's the --
9 all the principal design criteria and all the other 10 sections on testability, manufacturing, operations, 11 all that stuff and both of those, two IEEE standards 12 are easily applicable. For instance, fuel type and 13 quality, all of the other AC sources you would go for 14 has to have some type of fuel supply.
15 Fuel cells need hydrogen. Solar powers 16 need sun. Wind needs wind. So biodiesels need -- you 17 know, is the vegetable oil suitable or not suitable?
18 How do we get it in?
19 There's discussions in the other 20 standards, including the Reg Guides, on how long you 21 have to be able to operate these systems, for 30 days 22 or so counted independent other than running some, you 23 know, checks on them. It's based on fuel supply.
24 That's not in, that's not even present in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 C1, yet they do exist in both of the IEEE standards as 1
well as some parts of the Reg Guide, the old Reg 2
Guide, Rev. 4, and have been carried over into Rev. 5 3
for those two items.
4 I compared Rev. 4 to Rev. 5 line by line.
5 And the incorporation of the later revisions, the IEEE 6
standards, were incorporated as you all stated 7
properly. But you didn't add a whole lot else after 8
that.
9 It's -- I mean, I'm all in favor. I think 10 it's a great idea to start trying to put, you know, 11 some information out there in terms what other sources 12 may be available other than just diesels, I mean, 13 diesel generators or combustion turbines.
14 But the information you put in C1 in my, 15 this is my personal opinion, I can't speak for the 16 committee in any way, shape, or form, is that they are 17 just generalizations and don't really think. It just 18 says address EMI and radio frequency interference.
19 Another example of that would be if you 20 have to go to solar power, solar panels and fuel 21 cells, you'd have to have electric power converters.
22 That's a solid state power conversion. And when you 23 do that, you end up generating harmonics. There's not 24 even a mention of harmonics, which you don't have to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 deal with as much on bio-iron (phonetic) type 1
generators.
2 So, I mean, it's, the thought process to 3
me is, if I had been in your shoes, okay, I would have 4
spring, used the other two IEEE standards in the Reg 5
Guide as a springboard for the architecture and 6
layout, you know, section by section and effectively 7
incorporated IEEE formats into C1, and then 8
incorporate those items that were general performance 9
only and technology-neutral type issues that are 10 discussed throughout the design criteria, testing, 11 manufacturing, qualification, et cetera, because those 12 are largely the same regardless.
13 So that's the point I was trying to make 14 when I made that earlier request.
15 I think NEI also made the comment about C1 16 was awkward and difficult to read. I've forgotten 17 which NEI comment it was, 17 or 18 or someplace back 18 there. And they suggested it be bulletized or 19 alphabetized or something like that.
20 And I would, I agreed with that. I didn't 21 see it in the review copy that we received for that.
22 And you said you were going to do something with that 23 NEI comment, but it did not get reflected in the copy 24 of the Reg Guide as we got it.
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34 So that's kind of where I'm coming down 1
from that standpoint. I haven't heard anything from 2
anybody else, any other members.
3 MS. RAMADAN: Can I make a comment here?
4 I think this Reg Guide provides the reasonable 5
assurance on the evaluation of the criteria. But it 6
cannot provide the specific acceptance criteria, 7
because it depends on the technology that is used.
8 You know, there's unique considerations 9
with each technology. And that will be evaluated at 10 the time of application.
11 But with this current guidance, it 12 basically ensures -- and I'm only referring to C1. It 13 ensures that the applicant and the staff are aligned 14 regarding the review criteria. And that's the reason 15 why it does not model the same architecture that C2 16 and C3, as is currently laid out.
17 CHAIR BROWN: I would disagree with you.
18 The principal design criteria as laid out in the IEEE 19 standards, very few of them tell you exactly how to or 20 anything else.
21 For instance, under these, you've got to 22 be able to start and load any power source. And 23 you've got to be able to do it from various 24 conditions. It doesn't tell you anything else other 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 than that.
1 You've got to be able to restart. What if 2
you have repetitive on and offs? How should that --
3 that's not -- that's a criteria. That's not a how-to 4
or a specific detailed design item. It just says 5
you've got to be able to beat that type of 6
performance.
7 And that's what, the IEEE standards 8
fundamentally reflect that. They do not contain 9
specific boundary conditions. They just say you need 10 to operate over the voltage and frequencies necessary 11 and seismic response spectra need to be -- I mean, in 12 other words, they just, it's all the way through.
13 It's very, very nonspecific.
14 For dynamic loads, you have certain 15 criteria that the power band cannot go out of. That's 16 not stated necessarily in C1. And that applies. You 17 don't have to have the same numbers that the EDGs and 18 the CTGs use. But you need to have it known that you 19 have to meet certain criteria for those types of 20 operations.
21 Start demands, how you assess failures, 22 and how you don't, that's not -- that's how you 23 analyze that you're going to meet the requirements.
24 So I would disagree that the IEEE 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 standards are not technology-neutral. And, obviously, 1
there's some pieces of them that, for the EDG, that 2
are focused on EDG support systems. You don't have to 3
incorporate those in C1. So --
4 MR. MILLER: Lili, Sheila Ray has got her 5
hand up.
6 MS. RAMADAN: Go ahead, Sheila.
7 MS. RAY: Hi, this is Sheila Ray, a senior 8
electrical engineer.
9 I did want to point out one of the reasons 10 we constructed or formatted C2 the way it is is to 11 align with GDC 17. And GDC 17 is very clear on 12 providing sufficient capacity, capability. It 13 discusses having sufficient independence, redundancy, 14 testability.
15 And those are attributes we align to C1 to 16 indicate these are items that are related to a 17 particular attribute in GDC 17. So there is a 18 rationale for formatting it the way we did.
19 And I would indicate that we did point to 20 the seismic. In the qualification, we indicated Reg 21 Guide 1.100 provides additional information. We 22 didn't provide specific information on seismic because 23 we find that that would be more particular to a 24 technology and we were more general.
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37 In the reliability section, we address, 1
you know, fail to start, fail to run. And we're 2
expecting the applicant to provide data and 3
demonstration that they can have 95/95 reliability.
4 And in the capability, we did address, 5
asked for the applicant to address fuel storage and 6
supply requirements. So that could be, you know, 7
hydrogen, solar. That's where we think that would fit 8
in.
9 So we're asking them to address 10 capability. We weren't particularly prescriptive. We 11 did want to leave it open for the applicant to provide 12 the information to us.
13 A lot of this section is based on our US-14 APWR review in that when we were looking at that 15 review, that was the first time we were looking at or 16 evaluating a combustion gas turbine as an onsite --
17 CHAIR BROWN: You're talking about --
18 MS. RAY: -- emergency source.
19 CHAIR BROWN: Which plant --
20 MS. RAY: A US-APWR design.
21 CHAIR BROWN: Yeah, oh, yeah, that's 22 correct. They use CTGs.
23 MS. RAY: Correct. And so, when we 24 started that review, we didn't have any guidance.
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38 There was no IEEE standard at the time. There's was 1
no guidance for combustion gas turbines. So our 2
thought process for C1 is to allow flexibility for new 3
reactors, advanced reactors to use other technologies.
4 As you mentioned, you know, there are some 5
sources that are available now. We wanted to leave 6
this open for innovation. If there's other sources, 7
what criteria would we look at to evaluate the source?
8 That is coming from GDC 17. And that's 9
why we laid out C1 as it is. It directly ties to the 10 criteria and the regulations.
11 CHAIR BROWN: I guess I just considered it 12 too vague when I went through those, all those 13 sections.
14 When I looked at, just look at the 15 combustion turbine section, you actually translated or 16 moved or incorporated I should say issues like load 17 run demands, load run failure evaluations, start 18 demands, start failures. And you didn't -- you 19 defined what they were so that people knew what they 20 were dealing with.
21 Those same criteria apply for any other 22 types of power source you come up with. They 23 specified how, you know, they gave you some 24 indications of how long did it have to be in service 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 to qualify as a valid demand that didn't fail. And 1
that's stuff that you need.
2 And then they listed a bunch of exceptions 3
that showed relative to, I mean, loss of offsite 4
power, accident, or other type operations, which are 5
related to plant conditions, again not specific to a 6
particular technology.
7 So it's that type of stuff that is 8
incorporated that you did move, took out of the EDG 9
and incorporated it into the Reg Guide, plus the CTG 10 Reg Guide, the IEEE standard for the CTG did not 11 incorporate some stuff that the EDG had.
12 So, I mean, when you go read that list, it 13 just provides, you know, what is the applicant 14 supposed to deal with, how is he supposed to address.
15 And it doesn't care about the technology telling him 16 how to at least make sure you get the information you 17 need.
18 I just think you're going to be full of 19 RAIs on any other power source other than the CTGs.
20 I have no problem with the EDG, CTG sections by the 21 way. Those came out just fine. The one I had 22 difficulty with is the C1.
23 MS. RAY: I do -- oh, I apologize.
24 CHAIR BROWN: No, go ahead.
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40 MS. RAY: So, in the US-APWR review, we 1
had a lot of RAIs to begin with because we didn't even 2
have the information we needed to do the full review.
3 And my opinion is this Reg Guide will at 4
least put applicants and staff in alignment to have 5
the right discussions to begin with to start the 6
review. These are the items we would like to see to 7
begin the review to ensure that onsite AC emergency 8
power source will meet the regulations.
9 And we have some criteria. They're a bit 10 vague. Sometimes they just point to other Reg Guides.
11 For example, in the qualification, we pointed to Reg 12 Guide 1.89 and 1.100. And that will give some 13 criteria and methodology on how to perform a 14 qualification.
15 So I do think there is some criteria 16 there. But it starts the conversation on what we're 17 looking for to meet the regulation.
18 CHAIR BROWN: Okay. Any comments from any 19 of the other committee members?
20 MEMBER KIRCHNER: Yes, Charlie. This is 21 Walt.
22 CHAIR BROWN: Yes.
23 MEMBER KIRCHNER:
I can
- envision, 24 especially with smaller reactors and perhaps more 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 passive the design concepts, that the emergency power 1
requirements may be quite a bit less, perhaps 2
proportionately, than they are for a large PWR.
3 One could see using battery systems, 4
whether you use an inverter or you use a DC/AC rig 5
like is often used for protection system power. It 6
would seem to me C1 would apply in that case.
7 I'm having a little trouble, though, 8
sorting out what the requirements would be should the 9
source of power be intermittent --
10 CHAIR BROWN: Well --
11 MEMBER KIRCHNER: -- and if you would 12 demonstrate the same performance requirements that you 13 get from a diesel or a gas turbine systems, both of 14 which can be started and loaded relatively quickly.
15 Again, depending on the actual reactor 16 design, you may have more time before absolutely 17 needing that emergency power. But, you know, 17 talks 18 about seconds for -- so the presumption for me would 19 be if you've got an intermittent source that you 20 somehow also have a battery bank to back up its 21 unavailability.
22 CHAIR BROWN: Well, the battery has to be 23 able to be charged.
24 MEMBER KIRCHNER: Yeah.
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42 CHAIR BROWN: And right now --
1 MEMBER KIRCHNER: So I'm wondering how, 2
I'm just wondering --
3 CHAIR BROWN: And it has to maintain its 4
charge.
5 MEMBER KIRCHNER: Right.
6 CHAIR BROWN: And it's simpler when it's 7
not used.
8 MEMBER KIRCHNER: Right.
9 CHAIR BROWN: So you, and you can't, 10 batteries, you can't just let them sit there. You 11 have to --
12 MEMBER KIRCHNER: No, no, I fully agree 13 with you --
14 CHAIR BROWN: I mean, you just can't 15 charge them up and let them sit. That does not work.
16 (Simultaneous speaking.)
17 CHAIR BROWN: I've got more experience 18 with submarine batteries than I care to shake a stick 19 at. Those are lead acid. But even more modern 20 batteries lose their power.
21 MEMBER KIRCHNER: Yeah.
22 CHAIR BROWN: And you just can't charge 23 them up and let them sit there for two months and then 24 expect them to be there. And then you have to have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 the power converters. And they won't last that long.
1 MEMBER KIRCHNER: I'm just trying to think 2
through how the Reg Guide, the Reg Guide points to the 3
option. Biodiesel to me is really just, that just 4
means your support systems have to be maintained 5
differently so the, that it doesn't turn to sludge on 6
cold weather, et cetera, et cetera --
7 CHAIR BROWN: Biodiesels, the EDG section 8
would work for biodiesels --
9 MEMBER KIRCHNER: Yes, exactly. So I 10 don't see a problem there in terms of alternate fuel 11 sources. And it could be a natural gas system with 12 storage or hydrogen or whatever.
13 I'm just curious how the, what the Reg 14 Guide would point to in dealing with an intermittent 15 source and how that meets 17 and 18, GDCs 17 and 18.
16 CHAIR BROWN: You're talking about sun or 17 wind.
18 MEMBER KIRCHNER: Yes.
19 MS. RAY: This is Sheila Ray. I would 20 consider that to, that should be addressed under 21 availability and also reliability. And if they have 22 battery backup systems, we do have other standards and 23 Reg Guides on battery, on DC systems.
24 CHAIR BROWN: Well, the problem with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 battery systems is you'd need a huge battery to 1
provide emergency power even in a small modular 2
reactor for more than short times to supply systems.
3 MS. RAY: I fully agree with you. I am 4
just commenting on where the guidance is. I'm not 5
saying that that's what they would do or that, you 6
know, we will expect to see that in the future. I'm 7
just pointing out there's other guidance on the DC 8
side.
9 CHAIR BROWN: But the nice thing about the 10 existing standards is they list time of operation and 11 availability. And it's largely limited by the ability 12 to replenish fuel, whether it's diesel fuel.
13 And I don't know how long right now in a 14 commercial plant today you can run your emergency 15 diesel, probably Matt or Greg could tell me, without 16 having a tank truck pull up and replenish the fuel 17 tanks. How often does it have to be refilled? Can 18 you run an emergency diesel at rating for a month 19 without replenishing fuel? I don't think so.
20 MEMBER HALNON: No, the answer is no. You 21 can run them up to seven days probably.
22 CHAIR BROWN: That's -- well, you can't do 23 that with batteries, okay, unless you've got something 24 continually charging them. And that -- you have to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 have a generator doing that. And if you've lost 1
offsite power, the only source you have is your 2
emergency generator.
3 And there's -- the ability to assess that 4
or to evaluate, you know, throwing those items in in 5
terms of period of operation relative to what you get 6
with diesels and CTGs, it's not triggered at all in C1 7
as I could envision.
8 Obviously, I did not -- I read, I 9
downloaded three or four of the Reg Guides and a 10 couple of the other. I couldn't get IEEE standards 11 other than the ones we've been using, which I compared 12 to the old ones. But, and there was not one for the 13 CTGs. So --
14 MEMBER HALNON: Charlie, this is Greg.
15 Can I ask a question?
16 CHAIR BROWN: Yeah, go ahead.
17 MEMBER HALNON: And I apologize. I had to 18 step out during the first portion of this. But the 19 CTGs, the fuel source is natural gas, right? Is that 20 21 CHAIR BROWN: I don't remember from US-22 APWR. I presume it was. I mean --
23 MEMBER HALNON: Yeah.
24 CHAIR BROWN: -- there's a lot of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 experience with that in the Navy because, you know, 1
most of the surface warships are gas turbine now --
2 MEMBER HALNON: Yeah. I --
3 CHAIR BROWN: -- aircraft carriers.
4 MEMBER HALNON: I guess I'd ask the staff, 5
is there any other fuel source for combustion gas 6
other than the gas portion of this?
7 MR. MATHARU: Yeah, this is Singh Matharu.
8 I'm in the electrical branch for the NRR. The gas 9
turbines can use flexible types of fuel from kerosene 10 all the way to natural gas. So there is a flexibility 11 in the fuel pipes.
12 MEMBER HALNON: Okay. Kerosene, I didn't 13 even think of that. But --
14 MEMBER KIRCHNER: They use jet fuel, Greg.
15 MEMBER HALNON: Okay. The 3.13 --
16 (Simultaneous speaking.)
17 MEMBER KIRCHNER: Then they can address 18 the storage issue --
19 MEMBER HALNON: Yeah, and that's, that was 20 where I was going. I didn't see a good description or 21 a good understanding of the storage of the fuel.
22 I see that under C3 there's 3.13. It 23 talks about fuel stability should be considered. And 24 it talked about low sulfur diesel fuel and biodiesel 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 front.
1 I just didn't see that matching up with 2
the CTG discussion relative to natural gas and some of 3
the other more exotic, I say exotic, but less known 4
fuel sources to the nuclear industry.
5 I didn't know if that should be expanded 6
and discussed a little bit more, or maybe that Reg 7
Guide 1.137, which I did not review, maybe that has it 8
in there.
9 MR. MATHARU: So the Reg Guide -- sorry, 10 this is Singh Matharu again. I apologize. The Reg 11 Guide 1.137 does not address the fuel types for gas 12 turbines.
13 MEMBER HALNON: Okay. You know, back in 14 the polar vortex timeframe, and I can't remember the 15 date, 2009 or something like that, whenever we had 16 that really bad polar vortex up in the Northeast, the 17 natural gas fuel supply was very, very minimally 18 available. Matter of fact, they were telling people 19 to conserve based on it. And we were one 400-megawatt 20 plant away from a complete blackout in the Northeast 21 during that timeframe.
22 And my question would be is, how does a 23 nuclear plant preserve a natural gas supply to be 24 assured enough to be able to credit it for an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 emergency situation given the fact that it's 1
completely out of their control? And I don't think 2
you can store enough natural gas onsite to run a 3
diesel for seven days, or, I mean, a CTG for seven 4
days.
5 MR. MATHARU: Yeah, this is Singh Matharu 6
again. You're absolutely right. If you were relying 7
on a pipeline to supply your fuel, your observation is 8
absolutely correct.
9 But the intent is to have adequate fuel 10 stored based on the type of fuel you are using. And 11 typically, you would expect like we pointed out here 12 earlier on, one of the other flexible fuels that you 13 can save and store just like diesels and electric fuel 14 oil.
15 MEMBER HALNON: Okay. So, while that 16 would be in the review of the staff's discussion or 17 the discussion in the SAR-type discussion where you 18 would review that and make a judgment on whether or 19 not there's adequate fuel supply and reliability, 20 given operating experience that we've seen in the 21 Northeast.
22 MR. MATHARU: That's absolutely correct.
23 So the intent would be that the, if the existing 24 plants wanted to replace their diesel generators with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 gas turbines, then the fuel requirements would remain 1
the same as such for enough supply to demonstrate that 2
you can replenish given the duration.
3 For the DGs, we are currently saying seven 4
days seems reasonable for the licensees and applicants 5
to demonstrate that within seven days they have other 6
sources available to replenish their onsite fuel 7
capability.
8 Similarly, if the existing licensee has 9
decided to switch to gas turbines, they would be 10 required to have enough onsite storage plus 11 demonstrate capability to replenish.
12 MEMBER HALNON: Okay. And from a diesel 13 fuel, that was adequately demonstrated during the 14 hurricane down in Miami or Homestead many, many years.
15 I think it was Hurricane Frederic that took out Turkey 16 Point's power systems. And they were able to get 17 diesel fuel in. That seems easier than natural gas or 18 even kerosene, other things that may not be quite as 19 easy to get.
20 But, again, as long as the staff is aware 21 and you're going to review that as part of the thing, 22 I think, you know, asking the questions.
23 But that goes back to Charlie's point that 24 it's going to be a lot of RAIs to say how are you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 going to prevent running out of fuel and how are you 1
going to replenish during a period of time, if it's 2
some fuel other than, you know, diesel fuel.
3 MR. MATHARU: Yes, you're absolutely 4
correct on that. Even diesel fuel, like you said, 5
during severe weather conditions, it may be a 6
challenge to get it onsite.
7 But typically what you'd find is the 8
licensees and we hope the applicants who are looking 9
at areas where there's potential for severe weather, 10 they'll make arrangements somehow to get fuel from 11 different sources in the event that the loss of 12 offsite power is in an extreme condition and would be 13 more than seven days to restore.
14 MEMBER HALNON: So would you all see 15 yourselves getting into looking at commercial 16 contracts with, to make sure that there are reliable 17 sources of -- in other words, an officer of a company 18 signs a license amendment, says don't worry about it, 19 we've got enough commercial contracts in place to get 20 the fuel in.
21 I mean, clearly we can't just take that 22 as, at face value. We'll have to go verify that. So 23 do you see yourselves actually getting into the 24 ability of vendors to be able to reliably do what they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 say they're going to do?
1 MR. MATHARU: I mean, we haven't gone that 2
far for a case up to now that I know of. But your 3
observation is correct. All licensees typically have 4
commercial agreements with suppliers.
5 And there is, in general, there is 6
guidance and understanding between licensees and 7
suppliers that nuclear power plants are a higher 8
priority for their consumables.
9 MEMBER HALNON: Okay. All right. Well, 10 thanks for the discussion. I appreciate it.
11 CHAIR BROWN: Is there any other comments 12 from the committee? Hearing none, I kind of gave you 13 my opinions --
14 MR. HECHT: Charlie, this is Myron Hecht.
15 I'm sorry to interrupt. I did have a question.
16 CHAIR BROWN: Yeah.
17 MR. HECHT: In Section, in all of the 18 sections of the, I shouldn't say all of the sections, 19 in particularly Section C2 and C3 with respect to the 20 CTGs and the EDGs, it seemed that the standards were 21 rather light on instrumentation and control. Why is 22 that?
23 MR. MATHARU: This is Singh Matharu again.
24 So the question on the table is the IEEE standard that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 we are trying to endorse has got limitations as far as 1
the level of detail for instrumentation and control 2
associated with the diesel generator and gas turbines?
3 MR. HECHT: Yes.
4 MR. MATHARU: Yes, that is kind of a 5
deliberative effort from the standards perspective.
6 And I am also -- this is Singh Matharu again.
7 I also participate in the working group 8
that's developing or has developed IEEE 387. And we 9
had to put some boundaries as to the extent of what 10 this standard will cover. And there's a figure in the 11 standard that draws those boundaries.
12 And you can go into other sources, other 13 support systems such as cooling water or HVAC, even 14 switch gear. So, in order to contain the warning of 15 the standard and the level of detail, we put a 16 boundary.
17 And you're right. So the instrumentation 18 and control is part of another standard, another 19 design effort. But you will not endorse that in the 20 standard or cover it as part of the Reg Guide.
21 MR. HECHT: Did I understand you to say 22 that the instrumentation and control of support 23 systems is covered in another standard or Reg Guide?
24 MR. MATHARU: The instrumentation and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 control systems would be part of a different standard 1
altogether. And they will not be diesel generator 2
specific. But they would give you guidance on what 3
kind of instrumentation and controls you would need 4
for specific systems --
5 (Simultaneous speaking.)
6 MR. MATHARU: -- different organization.
7 MR. HECHT: Can you be --
8 CHAIR BROWN: One --
9 MR. HECHT: -- specific as to --
10 CHAIR BROWN: Myron?
11 MR. HECHT: Yeah.
12 CHAIR BROWN: Just one observation, I went 13 back and compared 387-1995 to the 2017 version. And 14 they are roughly the same relative to instrumentation.
15 So, I mean, it's kind of been that way for a long, 16 long time. That's the only point of my comment.
17 MR. HECHT: Okay. Well, I think I heard 18 Matharu, Mr. Matharu answer the question that there 19 was another source from which, of guidance from which 20 that would be covered for all support systems.
21 And I was going to ask what specifically 22 is that guidance. Is it a Reg Guide? Is it an 23 industry standard, something else?
24 MR. MATHARU: I'm sorry. Yeah, sorry, I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 apologize. This is Singh Matharu again.
1 No, I'm not familiar with the specific 2
standard that says instrumentation and control for 3
diesel generators. But all I'm saying is there are 4
standards for general instrumentation and controls for 5
nuclear power plants.
6 MR. HECHT: Well, for nuclear power 7
plants, yes. But now we're talking specifically about 8
the support systems and more specifically about the 9
emergency AC power. And what's true for controlling 10 the positions of the fuel, the control rods is 11 different than what you would be using to measure and 12 control the output of a diesel generator.
13 MR. MATHARU: Yes, that is an accurate 14 statement and observation. Again, we did not indulge 15 into defining what level of instrumentation, 16 redundancy requirements, and type of instrumentation 17 that needs to be associated or installed as part of 18 the package that you will get and requirements in 19 terms of a diesel generator. We take care of that 20 boundary.
21 And it's been like that all the time. But 22 if there's a comment here, we can take that to our 23 IEEE working group and ask them to address it.
24 MR. HECHT: Well, I'm not strictly a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 member of the committee. So I'm not in a position to 1
make that comment at least in this forum. But --
2 (Simultaneous speaking.)
3 MR. HECHT: -- irrespective of the 4
boundary of what those standards are considering, 5
doesn't the regulatory guidance need to provide 6
additional information to the, to both the applicant 7
and the staff?
8 MR. MATHARU: On the -- this is Singh 9
Matharu. I'll ask Kenn, because the scope of the Reg 10 Guide was established by our research department. So 11 he can -- I'll point you to Kenn. Let's put it this 12 way.
13 MR. MILLER: Hi, this is Kenn. I 14 apologize. Could you ask your question again? I'm 15 not sure I followed it.
16 MR. HECHT: Okay. Well, the question is, 17 why is there not more information in the Reg Guide 18 about the instrumentation and control systems --
19 MR. MILLER: Oh.
20 MR. HECHT: -- for in particular the CTGs 21 and the EDGs where you do know specifically what 22 you're talking about, as opposed to the abstract 23 nature of C1?
24 MR. MILLER: So this is Kenn Miller again.
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56 I would go back to what Mr. Matharu said, that in this 1
case, you know, this Reg Guide is intended to be 2
providing guidance on onsite power supplies for 3
nuclear power plants. And, specifically, Reg Guide 4
typically get into utilizing industry consensus 5
standards in terms of addressing those requirements.
6 And in this case, going to Rev. 4, which 7
is the current version, it's endorsing IEEE 387, which 8
deals with diesels.
9 And as Singh also mentioned, the IEEE 10 approach with standards is to kind of draw boundaries 11 between them. And in the case of 387, it's dealing 12 with diesels themselves. Whereas the instrumentation 13 and control aspects of it are more generally covered 14 in other standards.
15 So, you know, in the case of our Reg Guide 16 here, we're just dealing with the scope in terms of 17 what's described in the standard. And in general, its 18 requirements do well to address the regulatory 19 requirements that are highlighted also in this Reg 20 Guide that this is intended to provide guidance to, 21 for the licensees to meet.
22 It's probably a little haphazard --
23 MR. HECHT: All right.
24 MR. MILLER: -- with that wording there.
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57 But I think that's the answer to your answer, that to 1
see guidance on those kinds of issues, there would be 2
other standards and other regulatory guidance which 3
deals with those aspects of those standards in terms 4
of in this case instrumentation and control, which 5
could apply, like as has been said, broadly to lots of 6
systems within the plant, not just onsite power 7
supplies, but all the other instrumentation and 8
control utilizing the plant.
9 MR. HECHT: Okay. So I understand the 10 argument about scope. I understand the argument about 11 past practice in these Reg Guides.
12 But the question is, is there a gap in 13 that case, because outside of general instrumentation 14 and control principles, which we know about on this 15 committee, what standards would apply to support 16 systems as opposed to the plant itself, or more 17 specifically, what standards would apply to emergency 18 AC power with respect to instrumentation and control, 19 not with respect to the power sources, or is there a 20 gap?
21 MR. MILLER: This is Kenn Miller. I'd say 22 that, you know, that's certainly a valid question, 23 that, you know, are there gaps in all aspects of 24 nuclear power plant design that aren't addressed, you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 know, in terms of guidance and/or industry standards 1
addressing, you know, design requirements of various 2
systems.
3 You know, we -- and, of course, we have 4
the regulations which have requirements of the designs 5
of these plants to ensure, you know, the safety of the 6
public. So, yeah, I think that's a valid question.
7 Whether there is a gap, I don't, I 8
couldn't speak to that here.
9 I think that the Reg Guide does do a good 10 job of, both Revision 4 and the Revision 5, dealing 11 with the design requirements so the regulatory 12 requirements necessary of onsite power supplies as 13 described in the GDC and, you know, how, you know, to 14 what level -- I mean, there's always a discussion 15 about to what level of detail do you go, you know, go 16 to to get adequate assurance that a particular design 17 meets that.
18 And going back to the comments about 19 coming up with, you know, licensees coming in with 20 other potential onsite sources, I think by definition, 21 you know, there's going to be more back and forth 22 between the regulator and the licensee dealing with, 23 you know, questions about that design versus those 24 that are covered in the existing standards like we've 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 been used to with EDGs in this case for onsite power 1
supplies.
2 MR. HECHT: The one point on this --
3 (Simultaneous speaking.)
4 MEMBER KIRCHNER: Myron, this is Walt 5
Kirchner. I would point out that in the -- I think 6
it's the ISG that Christina shared with us. There is 7
a section on there that points to the review 8
procedures and goes partway, I think, to answering 9
your question. I'll just quickly read a little of it.
10 It says, the reviewer reviews the purpose 11 and operation of each auxiliary supporting system and 12 teacher, including its components arrangement as 13 depicted in functional piping and instrumentation 14 diagrams. Subsequently, the design criteria analysis, 15 description, and implementation of the 16 instrumentation, control, and electrical equipment as 17 depicted on electrical drawings are reviewed to verify 18 consistency with acceptance criteria for Class 1E 19 systems. It verifies that supporting system redundant 20 instrumentation, controls, and loads, et cetera, et 21 cetera. So although it may not be in a standard, it 22 appears at least to be in the NRC's review procedures.
23 MR. HECHT: Okay. Thanks, Walt. Was that 24 document included in the package that --
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60 (Simultaneous speaking.)
1 MEMBER KIRCHNER: This was -- it took me 2
a few minutes to dig it up. This -- Christina has 3
sent us all, I think, about two weeks ago.
4 MR. HECHT: Okay.
5 MEMBER KIRCHNER: Okay. And it's ISG --
7 MR. HECHT: Okay, thanks.
8 CHAIR BROWN: Kenn, this is Charlie.
9 Walt, did you have anything else?
10 MEMBER KIRCHNER: No, sir.
11 CHAIR BROWN: Okay. Put aside the details 12 on instrumentation, Kenn. Okay? But alternate 13 sources could be a lot of different technologies. And 14 if you look at -- that could require some different 15 form of instrumentation than what we're conventionally 16 thinking of.
17 I mean, I hadn't thought about that in the 18 more esoteric broad thought process, particularly if 19 you had solar plus batteries plus power converters.
20 That would be one thing if somebody proposed this or 21 even if that applies even to fuel cells or some of the 22 other more esoteric type fuel sources that require 23 power electronics and batteries. And I would think 24 that that would be one of the items in the list, not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61
-- if you're going to have a list the way you all done 1
it which you sound like that's what you're going to 2
do.
3 If unique -- if some -- not unique but --
4 not even non-conventional. If there were unique 5
instrumentation considerations relative to current 6
plants, that's all. I don't know how you would phrase 7
that, if that ought to be thrown into that mix if 8
you're going to do this generalized review and 9
discuss.
10 MS. RAY: May I add that in the capability 11 section of C1, we included --
12 CHAIR BROWN: Is that in there?
13 MS.
RAY:
- Yes, it
- says, discuss 14 instrumentation of the variables necessary for 15 successful operation and to generate the abnormal pre-16 trip and trip signals required for alarm. So we do 17 feel it's addressed, and --
18 CHAIR BROWN: Okay. I see it.
19 MS. RAY: -- I --
20 CHAIR BROWN: I forgot that.
21 MS. RAY: If I may add, in the chat, one 22 of the electrical engineers has pointed out the 23 support systems for emergency power supplies are 24 typically reviewed by mechanical folks. And one of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 those support systems is instrumentation and control.
1 And we would expect instrumentation and control staff 2
to review those systems.
3 CHAIR BROWN: Okay, yeah. I went back and 4
looked. I forgot that.
5 MS. RAY: No problem.
6 CHAIR BROWN: Okay. Are there any other 7
comments from the Committee?
8 Hearing none, Kenn, I think we would -- we 9
have a meeting scheduled for the full committee 10 meeting during the first week after July the 4th. And 11 I guess we will be expecting you all to provide that.
12 I think it's about an hour and a half long.
13 So it should be based on the discussion 14 today. That should be more than enough time. We've 15 got almost -- we're only missing a couple of the 16 committee members. So we should be able to do that 17 within that time period. So that's the expectation 18 going forward. Do you have any comments?
19 MR. MILLER: When you said Kenn, I assume 20 you're talking to Kenn Miller, myself, right?
21 CHAIR BROWN: Yes, yeah, I sorry.
22 MR. MILLER: Okay. And yeah, so -- and 23 again, you're referring to the full committee review 24 of this same package?
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63 CHAIR BROWN: Yes, it's on the schedule 1
for the full committee week in July.
2 MR. MILLER: So my answer to that is, 3
yeah, I obviously will be there for that and ready to 4
deal with questions as they come there.
5 CHAIR BROWN: Okay. If there any 6
additional ones, with the intention to evaluate the 7
report. Okay?
8 MR. MILLER: Understand.
9 CHAIR BROWN: Which I will prepare, 10 hopefully. One last round before I go to public 11 comments, anybody want to make an additional comment?
12 Okay. Can we open the public line for 13 comment? Let me know when it's open.
14 MS. ANTONESCU: Thomas?
15 CHAIR BROWN: Thomas?
16 Should we be asking somebody else? I see 17 Thomas is here.
18 MS. ANTONESCU: Just a moment, Member 19 Brown. We'll contact Thomas. He wasn't ready 20 probably yet to close the meeting or to open the 21 public comment period. Just a moment.
22 CHAIR BROWN: Okay.
23 MS. RAMADAN: Member Brown, I have a 24 couple of other slides. Should I discuss them?
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64 CHAIR BROWN: Oh, we hadn't finished?
1 MS. RAMADAN: No, we were on --
2 CHAIR BROWN: I forgot all about that.
3 MS. RAMADAN: -- Slide 9.
4 CHAIR BROWN: Pardon?
5 MS. RAMADAN: We were just on Slide 9. We 6
were going on to Slide 10. There's just a few more.
7 CHAIR BROWN: Okay. Go ahead.
8 MS. RAMADAN: Slide 10, there were 39 NEI 9
comments. There was 12 IEEE comments and 3 from the 10 members of the public. The one significant change was 11 made to the background section which we combined two 12 sections on the EDGs and CTGs into one.
13 The rest of the comments were minor and 14 incorporated by editorial changes. Other comments did 15 not require changes because they were determined to be 16 beyond the scope of this regulatory guide. Next, 17 Slide 11.
18 MEMBER REMPE: Excuse me. This is Joy 19 again. NEI seemed to be very concerned about the 30-20 day mission time. Were there any additional 21 interactions between the staff and NEI and they 22 concurred with your response?
23 MS. RAMADAN: In response to that, 24 yesterday we were informed that NEI has comments on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 back fit and forward fit and had requested CRGR to 1
review this Reg Guide 1.9. We did our best to provide 2
our response in the public comment table. And we will 3
have the CRGR review to, in fact, discuss their 4
concerns.
5 MEMBER REMPE: I'm sorry, but what is the 6
CRGR?
7 MS. RAMADAN: The review for generic --
8 generic review requirements.
9 MEMBER REMPE: Okay. Thank you.
10 CHAIR BROWN: The 30-day requirement, 11 Liliana, that's consistent with the EDG, isn't it?
12 That's my memory.
13 MS. RAMADAN: I'm sorry. Can you repeat 14 that, Member Brown?
15 CHAIR BROWN: Yeah, the 30-day, I remember 16 something on the 30-day thing. And I remember reading 17 your response to their comment.
18 MS. RAMADAN: Correct.
19 CHAIR BROWN: But I think the 30-day thing 20 was pretty consistent with the EDG 30-day.
21 MS. RAMADAN: Correct. And the EDG is 22 also included in Revision 4. So our Revision 5 was 23 actually softened -- we softened the language. And we 24 disposition our comment as stated in the public 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 comment. So I believe since we were informed 1
yesterday, they do have further comments. I'm not 2
sure what their comments are but concerns on back fit 3
and forward fit.
4 CHAIR BROWN: Okay. Yeah, I read your 5
all's response on the 30-day thing. But one other 6
issue or point, I brought up you all had originally in 7
the December version which I reviewed for our 8
evaluation to review it or not had a continuous rating 9
item, Item 3.1. And the -- somebody is doing 10 something. It's gone. Can you hear me still, 11 Liliana?
12 MS. RAMADAN: Yes.
13 CHAIR BROWN: Okay. Yeah, you -- and that 14 version, you had a Section 3.1 for the CTG that 15 duplicated the 8,760 hours0.0088 days <br />0.211 hours <br />0.00126 weeks <br />2.8918e-4 months <br /> for -- from the EDG into 16 the CTG for consistency for the most part. And then 17 you deleted it when they asked you to delete it 18 because it was covered other places. And I didn't 19 particularly see that. But there was still the 6,000 20 and 4,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.
21 MR. BASSO: Hi, this is Tom Basso from 22 NEI. Are we unmuted?
23 CHAIR BROWN: Yeah, yeah.
24 PARTICIPANT: This is Bill --
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67 (Simultaneous speaking.)
1 CHAIR BROWN: Are you there?
2 PARTICIPANT: -- Wah (phonetic) from 3
NextEra. I can hear you.
4 CHAIR BROWN: Yeah, I haven't gone to 5
public comments yet. Can you hold on?
6 MR. BASSO: Yeah, I don't know if the ACRS 7
can hear me or not.
8 CHAIR BROWN: Yeah, yes, I can hear you.
9 This is Charlie Brown, the chairman. Can you hear me?
10 MR. MILLER: I'm not sure he's hearing 11 you, Chairman Brown.
12 CHAIR BROWN: Yeah, that's what I 13 gathered. We seem to have a problem with a two-way --
14 MR. BASSO: I think they still have this 15 line from the public muted for the ACRS.
16 MEMBER HALNON: Charlie, this is --
17 PARTICIPANT: The public meeting line is 18 not muted.
19 (Simultaneous speaking.)
20 PARTICIPANT: -- public comment that way.
21 PARTICIPANT: This is Ted. I'm on too, 22 Tom.
23 MR. BASSO: Okay.
24 CHAIR BROWN: Can anybody hear me?
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68 PARTICIPANT: Can you hear me?
1 MR. BASSO: Oh, yeah. I can hear you 2
guys.
3 PARTICIPANT: Okay, good.
4 MR. BASSO: I just think they can't hear 5
us.
6 CHAIR BROWN: Yes, we can.
7 MR. BASSO: They were calling -- I thought 8
they were calling for me. But it's a different 9
Thomas.
10 MEMBER HALNON: Charlie, I hear you.
11 You're fine.
12 PARTICIPANT: No, I think they were 13 calling for you, Tom.
14 CHAIR BROWN: Yeah, it's whoever is on the 15 phone now.
16 (Whereupon, the above-entitled matter went 17 off the record at 11:04 a.m. and resumed at 11:30 18 a.m.)
19 CHAIR BROWN: Okay. This is Charles 20 Brown. I've been informed that we're back in service 21 now relative to our phone lines. Kenn, are you there, 22 and Liliana?
23 MS. RAMADAN: Yes.
24 MR. MILLER: Yes, this is Kenn. I'm here.
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69 CHAIR BROWN: Okay. And I see you have 1
your last slide up. Is that correct?
2 MS. RAMADAN: Yes.
3 CHAIR BROWN: Is that -- you wanted this 4
one, Slide 11. Which one do you want, 12 or 11?
5 MS. RAMADAN: Twelve is fine.
6 CHAIR BROWN: Okay. That works for me.
7 You want to go ahead and proceed?
8 MS. RAMADAN: Sure, just a couple of 9
statements regarding this and conclusion. In summary, 10 we're expecting publication in a month. But given 11 today's discussion, that's probably not going to 12 occur.
13 Revision 5 removes the details of design 14 and testing consideration for EDGs since they were 15 already incorporated in IEEE Standard 387-2017. And 16 lastly, this Reg Guide includes provisions for 17 alternative emergency power sources for supplying 18 onsite AC electrical power systems. And thank you.
19 MEMBER REMPE: Could you elaborate about 20 your plans to delay, because it affects our plans.
21 Should we be waiting until you make some changes 22 before we have this discussed at full committee 23 meeting?
24 MS. RAMADAN: Given our -- yesterday where 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 we were informed NEI had some back fit and forward fit 1
concerns and having to go through CRGR, that's the 2
time frame we have to account for. Also given Member 3
Brown's comment regarding full committee review, that 4
adds to it. So the way the discussion occurred, our 5
expectation was to have publication in a month. But 6
given this discussion, that may change.
7 MEMBER REMPE: Okay. So I guess you're 8
not planning to make any changes before the full 9
committee meeting. You still want to keep the package 10 as it is, although maybe we should wait till it goes 11 through this review committee. But you're not 12 planning to make any changes based on the discussion 13 today. Is that true?
14 MS. RAMADAN: True.
15 MEMBER REMPE: Thank you.
16 CHAIR BROWN: Okay. Liliana, relative to 17
-- right now, you're all on the schedule for July.
18 MS. RAMADAN: July -- Member Brown, July 19 when? I'm sorry.
20 CHAIR BROWN: That first week, right after 21 July the 4th, Independence Day. I think it is July --
22 MR. MILLER: July 7th.
23 CHAIR BROWN: Yeah, it's July 7th, 8th, 24 and 9th. Our discussion is scheduled for July the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 7th, if I remember. Is that correct, Christina?
1 MS. ANTONESCU: Yes, I will let them know 2
later to make sure that I have the correct date and 3
time.
4 CHAIR BROWN: Okay. Well, I was just 5
looking at the agenda. And I think we were first at 6
9:30.
7 MS. ANTONESCU: Yes.
8 CHAIR BROWN: Okay. So the present 9
schedule, Liliana and Kenn, is this presentation will 10 be done between 9:30 and about 11:00 o'clock on July 11 the 7th. And it could shift a few hours if we changed 12 it to the later session, but -- I mean, a later time 13 segment. But right now, we're scheduled for July the 14 7th at full committee meeting. And if you're making 15 no changes, then we can proceed with that.
16 MS. ANTONESCU: Member Brown, I will 17 follow up with the staff to let them know the exact 18 time as I'm not sure what the latest final agenda is, 19 yes.
20 CHAIR BROWN: Okay. That works. Now does 21 that -- is that okay with you, Kenn?
22 MR. MILLER: Yes. This is Kenn Miller.
23 I understand we're scheduled for July the 7th from 24 9:30 till 11:00 at this point. And assuming there 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 were no changes to the Reg Guide or the package that 1
that could go forward as far as you're concerned -- as 2
far as ACRS is concerned?
3 CHAIR BROWN: Yes.
4 MR. MILLER: The charger committee 5
presentation, it's unclear to me at this point, as 6
Lily alluded to, that there may be -- I'm not sure how 7
that affects things here. So we'll need to ascertain 8
that and get back to Christina on that for sure.
9 CHAIR BROWN: Absolutely.
10 MS. ANTONESCU: Okay. Thank you.
11 CHAIR BROWN: We'll schedule it as it is 12 scheduled. And if these other things that have come 13 into play and want you all to delay it, you will have 14 to tell us.
15 MR. MILLER: Correct. Understand that.
16 That's the way I would see it too at this point, 17 Charles.
18 CHAIR BROWN: Okay. And a follow-up full 19 committee would not be in August. We don't have full 20 committee in August. It would be in September, first 21 week --
22 MR. MILLER: So again, just to repeat 23 back, our next option after the currently scheduled 24 July 7th week would be in September.
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73 CHAIR BROWN: Yeah, I don't know what the 1
schedule is. Right now, looks like --
2 MR. MILLER: Yeah.
3 CHAIR BROWN: -- we have a fairly full 4
schedule in. But you've got to let us know, and then 5
we'll see what we can do. Is that --
6 MR. MILLER: Got you.
7 CHAIR BROWN: -- okay, Matt? Matt and 8
Joy?
9 MEMBER SUNSERI: That's -- yeah, that's 10 correct. And by the way, I looked at the July 11 schedule, and it looks like it's scheduled for 3:00 --
12 this session is scheduled for 3:00 p.m. on --
13 (Simultaneous speaking.)
14 CHAIR BROWN: Oh, it is? Oh, okay.
15 MS. ANTONESCU: Yes, it does. So I was 16 going to follow up and make sure of the date of the 17 time.
18 CHAIR BROWN: Okay, sorry. I had the 19 wrong time.
20 MR. BROWN: And Member Brown, this is 21 Scott. The September meeting is in the week following 22 Labor Day.
23 CHAIR BROWN: Yeah, okay. We've got four 24 days scheduled. So that looks like it's going to be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 a full meeting.
1 MR. BROWN: It's going to be less than 2
what is scheduled now. And I'll go over that during 3
our next full committee meeting.
4 CHAIR BROWN: Oh, okay. All right. Well, 5
the point -- all I was trying to get the point across 6
to Kenn was if -- due to your all's dealing with these 7
other issues you feel the meeting in July needs to be 8
deferred, you need to let us know in as timely a 9
manner as you can. And I just wanted to make sure you 10 knew that the next available time for a full committee 11 meeting would be the week after Labor Day in 12 September.
13 MR. BROWN: Right.
14 CHAIR BROWN: So --
15 MR. MILLER: Yeah, this is Kenn Miller.
16 I understand that. Again, currently, we're scheduled 17 for July the 7th. Otherwise, it'll be the week 18 following Labor Day. And we need to ascertain whether 19 or not our July 7th presentation is affected by a CRGR 20 review.
21 CHAIR BROWN: Okay.
22 MR. MILLER: And let you know -- and let 23 Christina know as soon as possible.
24 CHAIR BROWN: Exactly. All right.
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75 MR. MILLER: Yeah.
1 CHAIR BROWN: Okay. With that in play --
2 excuse me, please. Excuse me for a minute. I think 3
we are now -- Thomas?
4 MR. DASHIELL: The bridgeline is open for 5
public comment.
6 CHAIR BROWN: Okay. This is Charles 7
Brown, the chairman of the subcommittee meeting. The 8
public line is now open. Would somebody -- I know 9
there are people that want to make comments.
10 So if we will be -- somebody speak up and 11 we'll start since I don't know who they are. We'll 12 just start and take you all in series. NEI, do you 13 want to go first? Uh-oh.
14 MR. BASSO: Hi, this is Tom Basso from 15 NEI.
16 CHAIR BROWN: Okay.
17 (Simultaneous speaking.)
18 MR. BASSO: -- go first?
19 CHAIR BROWN: Yeah, go ahead. Just start 20 there.
21 MR. BASSO: Okay. Thank you. Again, my 22 name is Tom Basso. I'm the senior director of 23 engineering and risk at the Nuclear Energy Institute.
24 Mr. Brown, you and I will be talking on several 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 things.
1 I did replace Steve Guyer who retired at 2
NEI. So we appreciate the opportunity, and we do 3
appreciate that NEI's comments have been considered 4
and were incorporated in what we submitted. However, 5
it appears that three of our top priority one concerns 6
were not addressed, one that relates to introducing 7
and defining the term, mission time, as it applies to 8
emergency diesel generators, and then two other 9
comments related to supplements to IEEE Standard 387 10 regarding testing environment and design 11 considerations for testability and synchronizing 12 capabilities.
13 Those you can find as NEI Comments No. 1, 14 2, 3, and 5 that we previously submitted. And so if 15 I could go through them quickly. Regarding the 16 comments on the emergency diesel generator mission 17 time, NEI does appreciate the original language 18 alluding to mission time minimum requirement being 19 removed from the draft.
20 However, we disagree with the language 21 that was inserted in its place. And so document our 22 concerns that this constitutes a back fit and a 23 forward fit and to ensure that it is reviewed, NEI 24 will be submitting a letter to CRGR requesting the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 review. To eliminate these concerns, we again 1
recommend that all references to the EDG mission time 2
be deleted in this Reg Guide, and we base that on the 3
following.
4 First, the proposed language provides 5
first ever specific definition of emergency diesel 6
generator mission time by the NRC. And it conflicts 7
with the definitions supported by the NRC and NEI 8
Document 9902, Rev. 7, the regulatory assessment 9
performance indicated guideline to all SSEs. And that 10 document states that mission time -- the mission time 11 modeled in PRA to satisfy the function of reaching a 12 stable plant condition where normal shutdown cooling 13 is sufficient.
14 Note that the PRA models typically use a 15 mission time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, shorter intervals 16 as justified by analysis and modeling PRA may be used.
17 The proposed new language in this Reg Guide conflicts 18 with this established definition and is in direct 19 contrast to industry's move towards a more risk 20 informed regulatory process.
21 Additionally, this concept should not be 22 introduced in this Reg Guide particularly as a 23 background discussion. The more appropriate place for 24 the NRC to engage in this issue may be with the PWR 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 Owners Group which has thoroughly researched and 1
addressed this issue as evidence in the PWR Owners 2
Group Document 20014MP, EDG mission time. And we've 3
referenced that in our comments.
4 And past experience dictates the addition 5
of the emergency diesel generator mission time to this 6
Reg Guide will result in inspectors asking licensees 7
questions regarding the mission time which has proven 8
to result in long, costly, and resource intensive 9
processes but no net gain in safety. The proposed new 10 language states that a 30-day mission time is typical.
11 This, in fact, is technically not correct.
12 As referenced in the PWR Document 20014, 13 no Westinghouse, BNW, or CE plants are licensed to 14 these Reg Guides. And no plant UFSAR discuss an EDG 15 mission time. In addition, the safety analysis 16 performed by Westinghouse do not assume a diesel 17 generator mission time. Therefore, to concept as 18 identified in this Reg Guide discussed above is not 19 applicable to any PWR Owners Group plant current 20 licensing basis.
21 So with
- that, some licensees have 22 researched and developed their own position on mission 23 time. For example, the NRC did engage Callaway where 24 the NRC ultimately concurred with a seven-day mission 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 time, and others are proactively researching. And 1
some sites have developed similar mission times less 2
than 30 days based, in part, on a number of items that 3
I won't go through in sake of time.
4 So that's our number one concern. Our 5
second concern has to do with specifically mentioning 6
environment, temperature, humidity. That would be 7
expected. An actual demand were placed on the system 8
as a requirement for testing appears to me that the 9
licensees' facilities need to be capable of altering 10 the emergency diesel generators installed environment 11 during periodical testing to include worst case 12 conditions.
13 We don't believe the NRC intends to 14 require the installation of equipment equivalent to an 15 environmental test chamber to be used periodically 16 during testing. In fact, that would not be practical.
17 Instead, we believe that the intent is to assume that 18 the diesel generator includes enough design margin to 19 envelope all expected environmental conditions and 20 will not inhibit the design function capability. So 21 as stated in our previous comments, IEEE Standard 387 22 provides adequate guidance to assure diesel generator 23 safety function is not lost due to environmental 24 conditions.
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80 And again, this guidance covers mechanical 1
and electrical capabilities.
That includes 2
temperature and equipment locations, min and a max and 3
average ambient temperatures, humidity, absolute 4
barometric pressure. Also regarding to ratings and 5
application, that standard identifies a diesel 6
generator shall have continuous and short-term ratings 7
with the output capabilities.
8 And then regarding design and application 9
considerations, it does include ambient air 10 temperatures, temperature quality, combustion air, 11 service environment, tornado, depressurization. So 12 basically, our position is that the reference to 13 temperature and humidity be removed from C-2.1 because 14 it presents potential for misinterpretation. It is a 15 design criteria rather than a surveillance testing 16 consideration.
17 It's redundant to the standard. And as 18 stated in the NEI comments, the NRC has already agreed 19 to incorporate corrections based on our position as 20 documented in an NRC response to our previous comments 21 on Reg Guide 1.9, Rev. 4. That's in a letter dated 22 August 22nd, 2007 that the staff agrees that the use 23 of the words, simulated environment, in Regulatory 24 Position 1.5 is subject to different interpretations, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 and that the NRC staff also stated the staff agrees to 1
include this clarification in the next revision which 2
will be this revision to Reg Guide 1.9 regarding this 3
issue.
4 So that's our second item of concern. And 5
then our last item of concern is Position C-2.3. NEI 6
disagrees with the proposed addition of Position C-2.3 7
to supplement IEEE Standard 387, Clause 4.4, Table 1 8
because proposed items are in reference to the 9
preferred power source, otherwise known as offsite 10 power. And it's really outside the scope of IEEE 11 Standard 387.
12 So with respect to Item A in 2.3, there's 13 a reference that's made to power quality of the 14 preferred power supply. When diesel is parallel to 15 the grid, the NRC proposes that the consequences of 16 transient degraded conditions should be considered for 17 loading impact on the generator and what consequences 18 and how to respond. So any design associated with 19 preferred offsite power should be considered part of 20 the remote protection system per IEEE Standard 387.
21 And as such, it's outside the scope of the 22 Standard 387. It is more appropriate or implied more 23 appropriate that the scope should be an IEEE Standard 24 308 or 741 or possible IEEE Standard 765. Similarly 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 with Position 2.3-B that responding to an accident and 1
loss of offsite power or both while the diesel 2
generator is in test mode and parallel to the grid, 3
there's again an example of a protection signal that 4
originates outside the scope -- or the EDG scope 5
remote protection systems.
6 Again, IEEE Standard 387 is a principle 7
design to ensure the design of the diesel respond to 8
the valid signal but is not within the scope of IEEE 9
standard to design these remote protection systems.
10 So again, this would be more related to IEEE Standard 11 308 and Standard 741. So that concludes my comments.
12 I do have a couple of folks online from 13 the various diesel generator owners group to respond 14 to any technical questions you may have on these 15 comments. And I appreciate the time for making these 16 comments. Thank you.
17 CHAIR BROWN: Okay. Thank you very much.
18 We do not get into discussions relative to public 19 comments during our subcommittee or full committee 20 meetings. So we are not going to be going through 21 this.
22 You are providing these comments, and I 23 presume you will be resolving those or addressing 24 those through the process that you mentioned a few 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 minutes ago.
You're resubmitting those for 1
reconsideration. Is that correct?
2 MR. BASSO: Yes, we will resubmit these.
3 And again, we're also going to send a letter to CRGR 4
from the --
5 CHAIR BROWN: Okay.
6 MR. BASSO: -- to take a look at this from 7
a back fit and forward fit perspective.
8 CHAIR BROWN: All right. But that --
9 MR. BASSO: Thank you, Charles.
10 CHAIR BROWN: -- concludes -- okay. That 11 concludes your comments then?
12 MR. BASSO: It does. Thank you very much.
13 CHAIR BROWN: Okay. Thank you. Is there 14 anybody else on the public line that would like to 15 make a comment?
16 Hearing none --
17 (Simultaneous speaking.)
18 MEMBER MARCH-LEUBA: Charlie, this is --
19 CHAIR BROWN: Go ahead. I'm sorry.
20 MEMBER MARCH-LEUBA: Yeah, since we don't 21 have -- with regard to comments, can we request from 22 the staff that they address the technical content on 23 these comments and tell us what their position is so 24 we can be more informed about our decision to support 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 or not support this request?
1 CHAIR BROWN: You mean right now?
2 MEMBER MARCH-LEUBA: Tell them for -- no, 3
no, no, for the full committee.
4 CHAIR BROWN: Oh, I would expect if they 5
-- Kenn, are you there?
6 MR. MILLER: I'm still here. I'm sorry.
7 What was the question?
8 CHAIR BROWN: Jose, ask your question 9
again.
10 MEMBER MARCH-LEUBA: Yes. Can we -- since 11 we're going to have a presentation in the July full 12 committee meeting, can you have a slide or two 13 addressing the public comments and what the position 14 of the staff is with respect to them?
15 (Simultaneous speaking.)
16 MR. MILLER: I'm sorry.
17 MEMBER MARCH-LEUBA: Yeah. Sorry. Go 18 ahead.
19 MR. MILLER: And I'm sorry. You're an 20 ACRS member you were saying?
21 CHAIR BROWN: Yes, Jose --
22 MEMBER MARCH-LEUBA: Yes, I am.
23 CHAIR BROWN: Yes.
24 MR. MILLER: Okay. I'm sorry.
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85 MEMBER MARCH-LEUBA: Jose March-Leuba, 1
ACRS member.
2 MR. MILLER: Right.
3 MEMBER MARCH-LEUBA: So --
4 MR. MILLER: I guess --
5 CHAIR BROWN: Go ahead, Kenn.
6 MR. MILLER: -- two things. One is it was 7
the -- I'm assuming that the comment resolution 8
document was forwarded to ACRS for this presentation.
9 Was that true?
10 CHAIR BROWN: Yes.
11 MR. MILLER: Okay. So the answer to the 12 question about what our positions were, you have that.
13 And I would assume that maybe there might be something 14 in the presentation to facilitate that discussion at 15 the full committee.
16 MEMBER MARCH-LEUBA: Yeah. What I'm 17 asking is one slide or two during the full committee 18 presentation that discusses the topic.
19 MR. MILLER: Well, we're -- yeah, we're 20 going to meet and discuss the outcome of today's 21 meeting. And we'll certainly -- that's a topic we'll 22 be talking about.
23 MEMBER MARCH-LEUBA: Okay. Thank you.
24 CHAIR BROWN: I presume, Kenn, if this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 subject and the letter to CRGR -- if we're going to 1
continue with July, you will be able to address these 2
public comments with us like as Jose requested in the 3
discussion. That's what I got out of your answer. Is 4
that correct? Presuming there's no other hold ups.
5 MR. MILLER: Yeah, I would say that's a 6
fair characterization. But like you said, we'll 7
definitely meet about this and we'll get back with 8
Christina concerning the ability to support the July 9
presentation.
10 CHAIR BROWN: Okay. That's fine. And 11 yes, we did --
12 (Simultaneous speaking.)
13 CHAIR BROWN: -- we did get your NEI 14 comments with your resolution --
15 MR. MILLER: Okay.
16 CHAIR BROWN: -- as part of the package 17 that Christina sent to us. So we have that.
18 MR. MILLER: Okay, very good. Thank you, 19 Charles.
20 CHAIR BROWN: Okay. Thank you, Kenn. Is 21 there any --
22 (Simultaneous speaking.)
23 MEMBER REMPE: Charlie, this is Joy.
24 Could I ask a question about how long it -- I mean, I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 guess NEI has not yet sent the letter to the CRGR.
1 And then they have some sort of meeting and make 2
decision. How long does that process usually take?
3 MR. MILLER: This is Kenn Miller. I 4
couldn't speak to that for sure at this point.
5 MEMBER REMPE: Because, I mean, it's a 6
couple of weeks now till the 4th of July week when we 7
have our full committee meeting. Is it -- since the 8
letter is not yet received, it just seems a little --
9 (Simultaneous speaking.)
10 MR. MILLER: Yeah.
11 MEMBER REMPE: -- to have it happen in 12 July right now.
13 MR. MILLER: I guess to make a statement, 14 I guess certainly the possibility for having to wait 15 till September for this is there. I'm just reluctant 16 to say for sure at this point.
17 MEMBER REMPE: Okay. Thank you.
18 MR. BROWN: Vice Chairman Rempe, this is 19 Scott Moore. Having been a former member of the CRGR, 20 if the CRGR has a meeting scheduled and if they aren't 21 going to take any written action on the letter, then 22 they can make a decision in the CRGR meeting. But if 23 they don't have a meeting scheduled yet and if they 24 aren't -- if they -- excuse me. If they are going to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 issue some kind of written document, then it can take 1
weeks to a couple months to resolve whatever comes to 2
them.
3 MEMBER REMPE: Okay. Thank you.
4 MR. BROWN: Chairman Brown, can we close 5
the public line?
6 CHAIR BROWN: Yeah, sorry. My phone was 7
still off. Yeah, I was going to say -- let me just 8
make one other query since we've had some 9
interruptions there. Is there anybody else on the 10 public line that would like to make a comment?
11 Okay. Hearing none, we will close the 12 public line.
13 MR. DASHIELL: Public bridgeline is 14 closing.
15 CHAIR BROWN: Okay. Thank you, Thomas.
16 I'll make one more round. Does anybody -- any of the 17 members have any comment that they would like to make?
18 MEMBER KIRCHNER: Charlie, this is Walt.
19 Just supporting Jose's position that if Kenn and his 20 staff could address this mission time because it comes 21
-- it's related to the idea of entertaining the use of 22 intermittent sources for this particular emergency 23 power application. So I would second Jose's request.
24 CHAIR BROWN: Yeah, there is -- you did 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 get a copy of the resolution that they provided to 1
NEI, didn't you?
2 MEMBER KIRCHNER: Yes, and I'm going to go 3
back and take a closer look.
4 CHAIR BROWN: Okay. That'll give you a 5
summary. I mean, I went through those. Like you, I 6
went through those because the mission time issue is 7
-- I mean, I kind of -- I didn't take any issue with 8
it or disagreeing with the request to delete it.
9 I thought a 30-day mission time was pretty 10 reasonable to have it available. And Greg supported 11 that based on his thought process of what his plant 12 experience is. But that's -- we'll have to wait and 13 see what happens, so -- okay. Hearing nobody else 14 from the --
15 (Simultaneous speaking.)
16 MEMBER REMPE: Charlie?
17 CHAIR BROWN: Yes.
18 MEMBER REMPE: I actually would like to 19 make a comment too.
20 CHAIR BROWN: Yes, go ahead. Go ahead.
21 MEMBER REMPE: As they -- if again they --
22 the CRGR comes back with some suggested changes, I 23 think there's been a lot of good comments made today 24 that -- of course, they're just from individual 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 members. But I think the staff might consider some 1
other changes before this comes back to us. But if --
2 again, if they're going to go full force with it, then 3
we'll have our letter in July and it will be what it 4
is. But I just would like to entertain that thought.
5 CHAIR BROWN: Well, if you have -- if your 6
notes give you a few -- some of those items that you 7
think fall into that realm of possibility, if you can 8
send me an email and a copy to Christina so we can 9
make sure that we get a response on them.
10 MEMBER REMPE: Okay.
11 CHAIR BROWN: Is that okay?
12 MEMBER REMPE: Uh-huh. Thanks.
13 CHAIR BROWN: That'd be great. Thank you 14 very much, Joy.
15 MEMBER REMPE: And in return, it would be 16 nice if Christina would send us an update when she 17 hears something about what's going to happen with this 18 whole situation.
19 CHAIR BROWN: The schedule?
20 MEMBER REMPE: Right.
21 CHAIR BROWN: Yeah. Christina, you'll do 22 that, right?
23 MS. ANTONESCU: Yes. Member Brown, also, 24 there is a comment from the public that the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 disposition of the staff's comments in the document 1
was not provided to them.
2 CHAIR BROWN: That -- I don't know how 3
that's done, so --
4 MS. ANTONESCU: If the staff can comment, 5
please.
6 CHAIR BROWN: Kenn?
7 MR. MILLER: If I could, I'd like to --
8 Stan Gardocki, are you on the line? I think the 9
public comment resolution document is probably not 10 published yet. I'm not certain yet. But perhaps Stan 11 could address that. He's our project manager for 12 this.
13 CHAIR BROWN: Stan?
14 MR. MILLER: Or Lily.
15 CHAIR BROWN: Liliana?
16 MS. RAMADAN: Correct. It is not 17 published right now.
18 CHAIR BROWN: So NEI is not aware of your 19 all's resolution?
20 MS. RAMADAN: Correct. It's not publicly 21 available. They can see the Reg Guide, but the public 22 comments are not yet publicly available.
23 CHAIR BROWN: The resolution to the public 24 comments?
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92 MS. RAMADAN: Correct, the resolution, 1
correct.
2 CHAIR BROWN: Well, that's kind of 3
interesting. I thought they were -- I thought people 4
were aware when you all made resolutions.
5 MR. MILLER: This is Kenn Miller. Stan, 6
I don't know if you're not hearing us or what. Your 7
mic is mute. But I would really like for him to weigh 8
in on that at this point.
9 My understanding is that we're still 10 within normal process in terms of when the comment 11 resolution document would be going public as far as 12 where we are in the revision process for this Reg 13 Guide.
14 MR. RAHIMI: Kenn, this is Meraj.
15 MR. MILLER: Oh, hi, Meraj.
16 MR. RAHIMI: Yeah, this is Meraj Rahimi.
17 I'm the branch chief of regulatory guide. Yes, the 18 comment resolution, I guess we provided the comment 19 resolution table to the members for this meeting, 20 right?
21 (Simultaneous speaking.)
22 CHAIR BROWN: Yes, we have it.
23 MR. RAHIMI: Okay, right. So it is still 24 pre-decisional. So we can -- I mean, we have the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 draft. It's pre-decisional response. So since this 1
is a public meeting, it should be this pre-decisional 2
comment resolution table available.
3 And of course, now we have the CRGR that 4
then we have to go to CRGR. So it still remains pre-5 decisional. But in terms of the NEI and members of 6
the public being able to see these pre-decisional 7
responses since we have provided to the ACRS member 8
for this meeting and this meeting is public, it should 9
be available to them.
10 CHAIR BROWN: It should be available to 11 who?
12 MR. RAHIMI: To members --
13 (Simultaneous speaking.)
14 MR. RAHIMI: -- because I think we made 15 the Reg Guide, this final draft Reg Guide available.
16 So the package should be available.
17 CHAIR BROWN: So --
18 (Simultaneous speaking.)
19 MR. GARDOCKI: No, this is Stan Gardocki.
20 The ACRS requests the Reg Guide. So we give them the 21 Reg Guide in draft form with watermarks (audio 22 interference). That's the only document requested at 23 the public meeting. The responses to public comment 24 (audio interference) have not been released to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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94 public.
1 MR. RAHIMI: Stan, you're breaking up. I 2
guess that that's the question that you are saying 3
that the -- I thought that the ACRS member, they do 4
have the comment and response draft.
5 MR. GARDOCKI: I did not give them the 6
response to public comment --
7 MR. RAHIMI: You did not?
8 MR. GARDOCKI: -- at least the members of 9
ACRS, no.
10 MR. RAHIMI: Okay.
11 MR. GARDOCKI: And a draft that's marked 12 pre-decisional is made public and actually used in 13 public meetings. They confer upon themselves the Reg 14 Guide as a draft to see if the comments have been 15 incorporated.
16 (Simultaneous speaking.)
17 CHAIR BROWN: Stan, this is Charlie Brown.
18 I had a -- and it's a good question for us. I'm 19 sitting here looking at the NEI comments plus your 20 all's NRC resolution paper. And I --
21 (Simultaneous speaking.)
22 CHAIR BROWN: Pardon?
23 MR. GARDOCKI: Then that was given to you 24 by Christina. That wasn't given --
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95 (Simultaneous speaking.)
1 CHAIR BROWN: That was passed on to us --
2 yeah, from the staff to our staff to us, and that's 3
all.
4 MR. RAHIMI: Okay.
5 CHAIR BROWN: So that's the only place it 6
went. It didn't go anyplace else other than to the 7
members of the committee.
8 MEMBER REMPE: It does have an ML number 9
on it.
10 CHAIR BROWN: Yes.
11 MR. RAHIMI: That's right. I mean, all 12 the documents do have ML number. But normally, they 13 are not publicly available. But when we meet with 14 ACRS after we have received OGC NLO, we do make it 15 publicly available just for the sake of the meeting 16 because this meeting is public meeting. So it should 17 be technically available because we receive -- I 18 believe we received OGC's NLO on the package, both the 19 Reg Guide, the final draft, and the comment response.
20 So I think definitely that we will speak 21
-- I guess I don't want to make a commitment on behalf 22 of our technical lead colleagues, Kenn Miller. But I 23 think for the full committee meeting, we need to speak 24 to the responses, to the comments. But now what's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 added now which we just started the process because 1
NEI has requested to go to CRGR. So as the result of 2
CRGR, the response might change.
3 MS.
ANTONESCU:
This is Christina 4
Antonescu. Also all the documents that are 5
transmitted to ACRS need to be clearly marked as pre-6 decisional so we're all aware of it.
7 MR. RAHIMI: That's right.
8 (Simultaneous speaking.)
9 MR. RAHIMI: -- pre-decisional and we have 10 received the OGC NLO, I think it should be okay --
11 MS. ANTONESCU: Yeah, but this one was 12 not.
13 MR. RAHIMI: -- to be made. I'm sorry.
14 This one --
15 MS. ANTONESCU: The one on the --
16 MR. RAHIMI: -- was not what?
17 MS. ANTONESCU: -- public comments -- the 18 one on the public comments resolution was not marked 19 as pre-decisional. We have not shared it with 20 anybody. But it was not marked as pre-decisional.
21 MR. RAHIMI: Oh, okay. If it is not, 22 yeah, it shouldn't be shared because we need to make 23 sure that the OGC has reviewed and has provided 24 (indiscernible). Then we need to watermark it with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 pre-decisional. But I think the thing now in the full 1
committee meeting which is in July, we'll try to do 2
that.
3 CHAIR BROWN: To do what? Get it to the 4
NEI or just to watermark it?
5 MR. RAHIMI: No, to watermark. I need to 6
make sure that the OGC has looked at this comment 7
response. That's -- I think I need to talk with Stan 8
and with the team because we definitely -- we want --
9 every document, we -- so make it available, it's 10 cleared by our Office of General Counsel.
11 MS. ANTONESCU: Yes, but this has to be 12 done prior to this meeting so we're all clear on 13 what's available for us and the public as this is a 14 public meeting.
15 MR. RAHIMI: Right. If we can do it, 16 we'll share it. If not, we'll state that the -- we 17 might not be able to share the document. But in terms 18 of the slide presentation, we can speak to it. Of 19 course, a slide also have to be looking -- needs to be 20 looked at by OGC. So yes, we do have some work to do 21 between now and the full committee meeting.
22 CHAIR BROWN: The full committee meeting 23 is a public meeting also. So be aware of that.
24 MR. RAHIMI: Yeah, that's right. That's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 right.
1 CHAIR BROWN: Did I miss anything, Matt 2
and Joy, relative to the meeting?
3 MEMBER MARCH-LEUBA: This is Jose.
4 CHAIR BROWN: Yeah, go ahead.
5 MEMBER MARCH-LEUBA: And you didn't ask 6
me, but let me interrupt. What I was asking is not 7
what your final conclusion is. What I was asking is 8
to educate me on the reasons that what is the issue, 9
what are the pros, what are the cons, and why -- not 10 what but why you reached the decision the way you did.
11 Do you understand? I mean, it is an 12 education value so we can make a decision because I'm 13 not an expert on this area. You are. So what I'm 14 asking on the slides for the full committee meeting 15 and the presentation is to educate me on the problem 16 or the issue. Thank you.
17 MR. RAHIMI: Yes, yes, Jose, yeah. I 18 certainly understand what you are asking in terms of 19 the -- yes, the comments that the NEI has made. And 20 right, what is the issue? So I'm sure my colleagues, 21 Kenn Miller and team, that they do understand what 22 you're asking.
23 MR. MILLER: This is Kenn Miller. Yes, 24 the why behind the resolution to the specific comment 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 in question on the comment document.
1 MEMBER SUNSERI: Hey, Charlie. This is 2
Matt. You asked me if there was anything else we 3
needed to discuss. I think we've covered everything.
4 I think these technical details of administrative 5
processing of information is internal ACRS business.
6 And I think you can adjourn the meeting at your 7
discretion.
8 CHAIR BROWN: I just want to make sure that 9
passed on the all rigmarole we've gone through. Right 10 now, we're going to remain scheduled for July. And we 11 will depend on staff, Kenn, for you all to inform us 12 whether all these other gyrations require us to 13 reschedule it to September or whenever you think it's 14 appropriate for the full committee meeting. Is that 15 a reasonable summation of where we stand?
16 MR. MILLER: Yes. This is Kenn Miller.
17 That's the way I understand it as well.
18 CHAIR BROWN: Okay. And based on what 19 you've heard, you will provide some additional slides 20 to discuss at least a couple of the issues as Jose 21 pointed out and as have been discussed in the meeting?
22 MR. MILLER: Correct. That's correct.
23 This is Kenn Miller. That's correct.
24 CHAIR BROWN: All right. Okay. With that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 in mind, it's now 12:10. I think we've completed our 1
business, and --
2 MR. MILLER: Member Brown, could I ask one 3
more question? This is Kenn Miller.
4 CHAIR BROWN: Sure. Yeah, go ahead.
5 MR. MILLER: So as far as this meeting is 6
concerned, what will we be getting from ACRS in terms 7
of the outcome of this meeting from your all's 8
perspective?
9 CHAIR BROWN: It would be result. It would 10 be the -- we have the meeting in July. I will be 11 preparing a report, and it could take multiple forms.
12 I'm not so sure what the form would take 13 right now because it's -- we have -- that can only be 14 determined via the full committee meeting when we can 15 all vote on how we want to address it. But I will 16 have a report ready for something. I can't tell you 17 what that is yet because I haven't written it.
18 Now Joy did have some questions, and she 19 said she would try to provide those to Christina and 20 I. And when we get them, we will forward them to you.
21 Is that okay, Joy?
22 MEMBER REMPE: No. Okay.
23 CHAIR BROWN: Okay.
24 MEMBER REMPE: If you delay and do not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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101 have the meeting in July, then I would suggest you go 1
through the transcript and look at individual member 2
comments and think about them for incorporation into 3
your updated Reg Guide. That was kind of where I was 4
going because I'm kind of thinking this is premature 5
to us having a full committee meeting unless this CR 6
-- the review committee puts a stamp of approval 7
because usually we wait till public comments are 8
addressed, even if you have a disagreement with the 9
public on some of them. But they understand.
10 They've seen the response, and everything 11 is good. Now if things move forward and we have that 12 meeting in July, I'm going to send Charlie a quick 13 note saying, you might want to consider these things 14 in your letter. This is not meant for you to --
15 CHAIR BROWN: I got it.
16 MEMBER REMPE: -- address. Okay?
17 CHAIR BROWN: I got it. Yeah, that's 18 fine. That's fine for me, Joy.
19 MEMBER REMPE: Okay. Does that sound okay 20 to you, Kenn? You understand what we're doing here?
21 MR. MILLER: I think so. So let me just 22 circle back to my original question. So this meeting 23 today was a -- this was an ACRS subcommittee review of 24 the Reg Guide 1.9 revision?
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102 MEMBER REMPE: Right.
1 MR. MILLER: And Member Brown was talking 2
about a document that's going to be prepared in 3
preparation for the full committee that we would get 4
to see also. And I'm asking when that would be?
5 MEMBER REMPE: At the full committee 6
meeting after you give your presentation and we've had 7
our discussion, he'll read a letter in the public 8
meetings saying his proposed thoughts for our letter.
9 And then we'll make comments and we'll iterate. And 10 you'll get a letter. Historically, if there is a lot 11 of comments from members that are saying, you need 12 more detail in the Reg Guide, we think you need to at 13 least acknowledge some other things that aren't there, 14 you're going to get a letter with a lot of changes.
15 Historically, the staff doesn't want those 16 kind of letters. They'd rather update the Reg Guide 17 and then bring it to us and have a nice clean 18 supportive letter or have us say, we don't need to 19 write a letter on it. But that's why I kind of keep 20 saying, are you sure you don't want to make any 21 changes, in my questions today. But no, you won't get 22 anything from us other than the transcript.
23 MR. MILLER: Right, okay. That was going 24 to be my next point then. So the only thing we're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 getting coming out of today's meeting is the 1
transcript?
2 MEMBER REMPE: And you probably won't have 3
it before July unless we pay a lot of money to have it 4
expedited.
5 MR. MILLER: Oh, okay.
6 (Simultaneous speaking.)
7 MEMBER REMPE: So I hope you took good 8
notes.
9 MR. BROWN: Mr. Miller, this is Scott 10 Brown, the executive director. The subcommittee 11 doesn't make any final decisions. It only advises the 12 full committee.
13 And so you can take any of the comments 14 you heard here from any of the members as their own 15 comments. And they will provide a draft of the letter 16 to the full committee. And that's the first time that 17 you will see it.
18 MR. MILLER: At the full committee?
19 MR. BROWN: That's correct. It'll be read 20 in at the full committee, and that's the first time 21 that you'll see it.
22 MR. MILLER: Yeah. So in terms of our 23 preps for that, assuming it happens in July, we just 24 have what we've heard today --
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104 MS. ANTONESCU: Kenn --
1 MR. MILLER: -- take it back to our --
2 MS. ANTONESCU: Kenn, this is Christina 3
Antonescu. I will follow up with a phone call with 4
you and explain everything in details.
5 MR. MILLER: Okay, yeah.
6 MR. GARDOCKI: This is Stan Gardocki. I'm 7
listening on the public line. You know this is still 8
open to the public.
9 CHAIR BROWN: Yes.
10 MR. GARDOCKI: Okay.
11 CHAIR BROWN: They're just muted.
12 MR. MILLER: That's all the comments I 13 have, Member Brown.
14 CHAIR BROWN: Okay. Thank you. And thank 15 you for -- it was a lively discussion. I appreciate 16 the back and forth. It's kind of a new area that you 17 all had to address. And there were -- the transcript 18 will show a number of different comments on it. But 19 I thought it was a valuable exchange. So I appreciate 20 the time and the thought process that you all put into 21 it. So with that, I will adjourn the meeting, and 22 have a good weekend.
23 (Whereupon, the above-entitled matter went 24 off the record at 12:16 p.m.)
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Revision 5 to Regulatory Guide 1.9, Application and Testing of Onsite Emergency Alternating Current Power Sources in Nuclear Power Plants NRC Staff Presentation to the Advisory Committee on Reactor Safety June 25, 2021
Agenda
- 1. Introduction
- 2. Existing Guidance
- 3. Significant Changes
- 4. Proposed New Guidance
- 5. Conclusion
Introduction Current NRC guidance in Regulatory Guide 1.9 has not been updated since 2007. It does not reflect all the possible types of different onsite emergency power sources that are available today.
The NRC is issuing Revision 5 of Regulatory Guide 1.9 as technology-neutral to include diesels, combustion turbine generators (CTGs), and other types of the emergency power sources for the onsite alternative alternating current (AC) electric power system.
Technology-neutral benefits:
Facilitate application processes allowing use of alternative onsite emergency power supplies in the future for advanced reactors and nuclear facilities.
Reduce the number of regulatory guides that will be required to cover other alternatives.
Reduce the overall regulatory review process.
Existing NRC Guidance Regulatory Guide 1.9, Application and Testing of Safety-Related Diesel Generators in Nuclear Power Plants was last updated in 2007 to Revision 4.
Regulatory Guide 1.9 provides guidance that the NRC staff considers as an acceptable method for satisfying NRC regulations (mainly GDC 17 and 18) with respect to the design, qualification, and testing of emergency power sources used in onsite AC electric power systems for nuclear power plants.
Significant Changes This revision (Rev 5) endorses the following two IEEE standards in full, with supplements and clarifications:
- IEEE Standard 387-2017, IEEE Standard for Criteria for Diesel Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations o Includes specific details based on lessons learned from comprehensive reviews of operating reactors, new reactor applications, and other nuclear facilities.
Significant Changes (cont.)
- IEEE Standard 2420-2019, IEEE Standard Criteria for Combustion Turbine-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations oSpecifically includes additional guidance on CTGs principal design criteria, design features, qualification considerations, and testing requirements, based on the reviews performed for the US-Advanced Pressurized-Water Reactor and other Interim Staff Guidance.
Significant Changes (cont.)
Clarifications:
- Design and Application Considerations in 387-2017 for testability and synchronization capabilities was supplemented:
- to address testing EDGs in the event the offsite power source has transients resulting in voltage and frequency perturbations.
- Design and Testing Considerations in 387-2017 was clarified:
- to include how the EDGs envelop parameters of operation.
- Operations in 387-2017 was clarified:
- to include that licensees should monitor EDGs cumulative operating time above the nominal rating for additional restrictions as specified in manufacturer-recommended accelerated maintenance requirements and industry consensus group recommendations.
Significant Changes (cont.)
Supplements:
- Both IEEE standards were supplemented to include verification of all subsystems such as fuel oil, lube oil, cooling, starting, and piping systems credited for operation.
Other important changes:
- Removal of testing and design requirements from Rev 4 because they have been incorporated in the updated IEEE 387-2017.
- Title of Regulatory Guide 1.9 changed to be more technology neutral, Application and Testing of Onsite Emergency Alternating Current Power Sources in Nuclear Power Plants.
Proposed New Guidance
- Includes provisions for alternatives for onsite standby emergency power supplies that meet the intent of 10 CFR 50 and 10 CFR Part 52 requirements in consideration for small modular reactors, advanced reactors, and other nuclear facilities.
- Includes criteria derived from General Design Criteria (GDC) 17 and GDC 18 (e.g., information on capacity, capability, independence, redundancy, testability, inspection, qualification, etc.).
- Includes additional design and testing considerations for EDGs, CTGs, and other emergency AC power sources.
Public Comments
- Received 51 comments from NEI, IEEE, and members of public.
- One significant change made to the background section was to combine the two sections on EDGs and CTGs into one.
- The rest of the comments were minor and incorporated by editorial changes.
- Several other comments did not require changes because they were determined to be beyond the scope of this regulatory guide.
Steps Towards Issuance
- Brief ACRS on changes and receive feedback.
- Issuance of new guide is expected in late June or early July.
Conclusion
- The staff expects publication of Revision 5 of Regulatory Guide 1.9 endorsing existing two industry standards within the next month.
- Revision 5 removes details of design and testing considerations of EDGs because these details were included in IEEE 387-2017.
- Revision 5 includes provisions for alternative emergency power sources (technology-neutral) for supplying onsite AC electric power systems.
Full Name User ActionTimestamp Antonescu, Christina Joined 6/25/2021, 7:34:06 AM Dashiell, Thomas Joined 6/25/2021, 8:43:38 AM Burkhart, Larry Joined 6/25/2021, 8:49:06 AM Wang, Weidong Joined 6/25/2021, 8:50:01 AM Matharu, Gurcharan Joined 6/25/2021, 8:57:16 AM Brown, Charles Joined 6/25/2021, 8:59:01 AM Kodali, HariJoined 6/25/2021, 9:01:50 AM
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