ML21230A353
| ML21230A353 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/2021 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Burkhart, L, ACRS | |
| References | |
| NRC-1579 | |
| Download: ML21230A353 (220) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number: (n/a)
Location: teleconference Date: Wednesday, July 7, 2021 Work Order No.: NRC-1579 Pages 1-153 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 687TH MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +
8 WEDNESDAY 9 JULY 7, 2021 10 + + + + +
11 The Advisory Committee met via 12 Teleconference, at 9:30 a.m. EDT, Matthew W. Sunseri, 13 Chairman, presiding.
14 15 COMMITTEE MEMBERS:
16 MATTHEW W. SUNSERI, Chairman 17 JOY L. REMPE, Vice Chairman 18 WALTER L. KIRCHNER, Member-at-Large 19 RONALD G. BALLINGER, Member 20 VICKI M. BIER, Member 21 DENNIS BLEY, Member 22 CHARLES H. BROWN, JR., Member 23 GREGORY H. HALNON, Member 24 VESNA B. DIMITRIJEVIC, Member 25 JOSE MARCH-LEUBA, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 DAVID PETTI, Member 2 PETER RICCARDELLA, Member 3
4 ACRS CONSULTANT:
5 STEPHEN SCHULTZ 6
7 DESIGNATED FEDERAL OFFICIAL:
8 KENT HOWARD 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 1 CONTENTS 2 Opening Remarks by the ACRS Chairman . . . . . . 4 3 SECY-21-0029, Rulemaking Plan on Revision of 4 Inservice Testing and Inservice Inspection 5 Program Update Frequencies Required in 6 10 CFR 50.55a . . . . . . . . . . . . . . . 10 7 Break . . . . . . . . . . . . . . . . . . . . . . 62 8 (Continued) SECY-21-0029, Rulemaking Plan on 9 Revision of Inservice Testing and 10 Inservice Inspection Program Update 11 Frequencies Required in 10 CFR 50.55a . . . 62 12 Break . . . . . . . . . . . . . . . . . . . . . . 68 13 Vogtle License Amendment Request (LAR) 14 GSI-191 - Applying a Risk-Informed 15 Approach to Address Generic Safety 16 Issue-191, "Assessment of Debris 17 Accumulation on Pressurized-Water Reactor 18 Sump Performance" at Vogtle Units 1 and 2 . 69 19 Lunch . . . . . . . . . . . . . . . . . . . . . . 94 20 RG 1.9, Rev. 5, Application and Testing of 21 Onsite Emergency Alternating Current 22 Power Sources in Nuclear Power Plants . . . 94 23 Meeting Adjourned . . . . . . . . . . . . . . . 153 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P R O C E E D I N G S 2 9:31 a.m.
3 CHAIRMAN SUNSERI: It's 9:31. The meeting 4 will now come to order. This is the 1st day of the 5 687th meeting of the Advisory Committee on Reactor 6 Safeguards. I'm Matthew Sunseri, the Chair of the 7 ACRS.
8 I'll now call the roll to verify a quorum 9 and that communications are in place. We'll start 10 with Ron Ballinger.
11 MEMBER BALLINGER: Here.
12 CHAIRMAN SUNSERI: Vicki Bier?
13 MEMBER BIER: Here.
14 CHAIRMAN SUNSERI: Dennis Bley?
15 MEMBER BLEY: I'm here.
16 CHAIRMAN SUNSERI: Charles Brown?
17 MEMBER BROWN: I'm here.
18 CHAIRMAN SUNSERI: Vesna Dimitrijevic?
19 MEMBER DIMITRIJEVIC: Here.
20 CHAIRMAN SUNSERI: Greg Halnon?
21 MEMBER HALNON: Here.
22 CHAIRMAN SUNSERI: Walt Kirchner?
23 MEMBER KIRCHNER: Here.
24 CHAIRMAN SUNSERI: Jose March-Leuba?
25 MEMBER MARCH-LEUBA: I'm here.
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5 1 CHAIRMAN SUNSERI: Dave Petti?
2 MEMBER PETTI: Here.
3 CHAIRMAN SUNSERI: Joy Rempe?
4 (Pause.)
5 CHAIRMAN SUNSERI: Alright. Still having 6 trouble.
7 Pete Riccardella?
8 VICE CHAIRMAN REMPE: I'm here.
9 CHAIRMAN SUNSERI: And myself. So, we 10 have a quorum to go ahead and go forward and everybody 11 was loud and clear.
12 The ACRS was established by the Atomic 13 Energy Act and is governed by the Federal Advisory 14 Committee Act.
15 The ACRS section of the US NRC public 16 website provides information about the history of the 17 ACRS and provides documents such as our charter, 18 bylaws, federal register notices for meetings, letter 19 reports and transcripts of all full and subcommittee 20 meetings, including the slides presented at the 21 meeting.
22 The Committee provides its advice on 23 safety matters to the Commission through its publicly 24 available letter reports.
25 The Federal Register Notice announcing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 this meeting was published on June 15th, 2021, and 2 provides an agenda and instructions for interested 3 parties to provide written documents or request 4 opportunities to address the Committee.
5 The designated federal officer for this 6 meeting is Mr. Kent Howard. During today's meeting, 7 the Committee will consider the following: Our first 8 topic will be a SECY rulemaking on the revision of 9 inservice testing and inservice inspection program 10 update frequencies required in 10 CFR 50.55a. This 11 will be an information briefing.
12 The second topic is a Vogtle License 13 Amendment Request, risk-informed approach to address 14 Generic Safety Issue-191, "Assessment of Debris 15 Accumulation in Pressurized-Water Reactors," and 16 that's via a letter report.
17 And then the third topic is Reg Guide 1.9, 18 Revision 5, Application and Testing of Onsite 19 Emergency Alternating Current Power Sources in Nuclear 20 Power Plants. And this will also be a letter report.
21 A phone bridge line has been opened to 22 allow members of the public to listen in on the 23 presentations and Committee discussions. Excuse me 24 for a second.
25 (Pause.)
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7 1 CHAIRMAN SUNSERI: Okay. Joy is still 2 trying to be connected. We have received no written 3 comments or requests to make oral statements from the 4 members of the public regarding today's sessions.
5 There will be an opportunity for public 6 comment. We set aside time in the agenda for comments 7 from members of the public listening to our meeting.
8 Written comments may also be forwarded to Mr. Kent 9 Howard, the designated federal officer.
10 Somebody has their line open, so I would 11 appreciate if you could mute that. A transcript of 12 the open portion of the meeting is being kept and it 13 is requested that speakers identify themselves and 14 speak with sufficient clarity so -- and volume so that 15 they may be readily heard.
16 Additionally, participants should mute 17 themselves when not speaking. It's very critical for 18 that.
19 So, I have a couple of announcements to 20 make before we get into the formal agenda today and 21 I'm going to turn my camera on for this.
22 (Pause.)
23 CHAIRMAN SUNSERI: There we go. Alright.
24 It's understandable that a committee that has been in 25 existence for almost 70 years, such as the ACRS, will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 outlive some of its former members.
2 On behalf of the ACRS, I wanted to pay 3 respect to two former members that passed away in 4 June.
5 Dr. Ivan Catton served two terms starting 6 in 1989. He was chair of the Thermal Hydraulics 7 Subcommittee and the Fire Protection Subcommittee.
8 Former member Dana Powers credits Catton 9 for advancing an ACRS objective to move fire 10 protection to a more risk-informed basis. Dr. Catton 11 was also a professor emeritus at UCLA. He will be --
12 his expertise will be missed.
13 Dr. Max Carbon served two terms beginning 14 in 1975. During his tenure, he served as chair of the 15 Committee and also chair for several subcommittees.
16 Carbon is most recognized for his work on advanced 17 reactors.
18 Dr. Carbon came to University of 19 Wisconsin-Madison in 1958 to establish a nuclear 20 engineering program as part of a growing post-war 21 research emphasis on designing more efficient nuclear 22 power plants for generating electricity.
23 He subsequently became the head of that 24 program and was also professor emeritus at the 25 University of Wisconsin-Madison.
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9 1 Each time that I had the honor to 2 recognize contributions from former members like Dr.
3 Catton and Carbon, I'm inspired to work a little 4 harder to ensure that the nuclear engineering legacy 5 that they helped create lives on and I hope you are 6 equally inspired.
7 Alright. Secondly, I wanted to announce 8 that Dr. Peter Riccardella's time as an ACRS member is 9 coming to an end in August and this will be his last 10 full committee meeting.
11 When I joined the ACRS a few years ago, 12 Pete took me under his wing, showed me the ropes, so 13 to speak. And throughout the course of my tenure 14 here, he has been more than a colleague and I'm proud 15 to call him a friend.
16 So, I have some inside information that 17 says that this won't be our last opportunity for 18 members to bid Pete, you know, fond wishes going 19 forward and for now let's just all raise our hands 20 here in recognition of his last meeting.
21 If you can just go to the "raised hand" 22 feature, we'll see how many hands we can get raised up 23 in celebration of Pete and his career here. Like I 24 said, we will have an opportunity to bid him farewell 25 in a more explicit session, if you will.
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10 1 So, look at all those hands, Pete.
2 Congratulations. You have a lot of good colleagues 3 out there.
4 MEMBER RICCARDELLA: Thank you, Matt. I 5 appreciate it.
6 CHAIRMAN SUNSERI: Yeah. You'll get 7 another opportunity later. I just wanted to call 8 attention to this now, you know.
9 Alright. So, let's put those hands down 10 and we will get into the meeting. As it turns out, 11 our first agenda topic is the rulemaking on the 12 inservice testing and Dr. Riccardella will be leading 13 this session.
14 So, Pete, I'll turn it over to you --
15 well, before I do that, let me pause. I got a little 16 ahead of myself.
17 Let me pause here and ask, are there any 18 other members that have any questions about the agenda 19 or anything else you want to bring up before this 20 meeting gets started?
21 VICE CHAIRMAN REMPE: Pete, this is Joy 22 and I apologize for my technical problems this 23 morning, but I am on. I joined when you were making 24 the initial announcements. Thank you.
25 CHAIRMAN SUNSERI: Okay. Great. Alright.
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11 1 So, we have 100 percent attendance. Alright. So, not 2 hearing from anyone else, I will now turn the meeting 3 over to Dr. Riccardella.
4 Pete, go ahead.
5 MEMBER RICCARDELLA: Thank you, Matt.
6 Good morning. My name is Pete Riccardella. I am the 7 subcommittee chairman for this item on our agenda and 8 the purpose of this information briefing is for the 9 NRC to brief the full committee on the rulemaking plan 10 for revision of inservice testing and inservice 11 inspection program update frequencies required in 10 12 CFR 50.55a.
13 As stated by Matt in his introduction, 14 there will be an opportunity for public comment during 15 this meeting and we can set aside 10 minutes in the 16 agenda for comments from members of the public 17 listening to this meeting online.
18 I would like to reiterate that it is 19 requested that the speakers identify themselves and 20 speak with sufficient clarity and volume so that they 21 can really be heard.
22 At this time, I ask the attendees on the 23 Teams meeting, and on the bridge line, to keep their 24 devices on mute to minimize disruptions and unmute 25 only when speaking.
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12 1 We will now proceed with the meeting. I 2 call on Anna Bradford, division director of the 3 Division of New and Renewed Licenses, to make 4 introductory remarks.
5 Anna, are you there?
6 MS. BRADFORD: Yes. Thank you, Dr.
7 Riccardella. Can you please confirm you can hear me?
8 MEMBER RICCARDELLA: We can. We hear you 9 loud and clear.
10 MS. BRADFORD: Alright. Thank you. Also, 11 I want to thank the Chairman for those comments that 12 you made.
13 I think it's important that we remember 14 the long and distinguished history of this committee 15 and its members. So, thank you for that.
16 As mentioned, my name is Anna Bradford.
17 I'm the director of the Division of New and Renewed 18 Licenses in the Office of Nuclear Reactor Regulation.
19 Among our many other activities, we have 20 the technical lead when it comes to ASME code 21 activities and we appreciate the opportunity to brief 22 the ACRS on this rulemaking plan SECY paper today and 23 this SECY paper describes a proposed rulemaking that 24 would decrease the required frequency of inservice 25 testing and inservice inspection program updates in 10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 CFR 50.55a codes and standards.
2 This effort began with the EMBARK Venture 3 Studio project, which developed ideas for transforming 4 how the NRC might streamline the way it regulates 5 using 10 CFR 50.55a where the ASME codes and code 6 cases are incorporated by reference.
7 The EMBARK team developed three 8 recommendations, which the staff will briefly discuss 9 today.
10 All the recommendations will be 11 implemented, but only one, which is the relaxation of 12 the IST/ISI program updates, is a change to the 13 regulatory framework and, therefore, is the focus of 14 this rulemaking plan.
15 This relaxation is not likely to have any 16 impact on safety and will provide flexibility and cost 17 savings.
18 Engagement with external stakeholders 19 during the EMBARK project indicated that there is a 20 strong interest in the industry and this proposed 21 rulemaking, and I thank you for your interest and I 22 look forward to the discussion today. Thank you.
23 MEMBER RICCARDELLA: Thank you, Anna. Is 24 someone going to give us a brief description of what 25 the EMBARK program is or the EMBARK team?
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14 1 This is the first time, I think, the 2 Committee has had any exposure to it.
3 MS. BRADFORD: Yeah. This is Anna 4 Bradford again. The EMBARK team was a small 5 organization that was set up within NRR to think about 6 -- I'll call it -- these are all my words -- new and 7 creative ways that the agency can do its business 8 while still maintaining safety, whether it's 9 streamlining rules and regulations, whether it was 10 changing internal processes, changing external-facing 11 processes.
12 And so, this was just one of many 13 activities that they thought about to see if there 14 were ways that we could do our work better.
15 MEMBER RICCARDELLA: Thank you.
16 MS. BRADFORD: Yeah.
17 MEMBER BROWN: This is Charlie Brown.
18 Dennis, correct me if I'm wrong, I think we discussed 19 this at one other meeting and one of the responses we 20 got from the EMBARK approach, it was also to try to 21 encourage people to at least use some common sense in 22 terms of not overinterpreting stuff.
23 Am I incorrect in that was one of the 24 focuses of their previous discussions?
25 MEMBER BLEY: You are correct. We were --
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15 1 we had a session on EMBARK and on the Be Risk, At 2 Risk, whatever the title of that is.
3 CHAIRMAN SUNSERI: Be riskSMART.
4 MEMBER BROWN: Oh, that's right.
5 MEMBER BLEY: Be riskSMART. It was Be 6 riskSMART that you're talking about, Charlie.
7 MEMBER BROWN: Yeah, that's right. I'm 8 sorry. Thank you very much for fixing my brain here.
9 Okay. Pardon me. Go on.
10 MEMBER RICCARDELLA: Okay. So, I guess we 11 have a -- the presenter is Mark Yoo.
12 Are you there, Mark?
13 MR. YOO: Yes. Yes. Good morning, 14 everyone. My name is Mark Yoo. I was one of the 15 technical staff that helped develop this SECY paper.
16 Listed here are the other working group 17 members that contributed significantly to this effort 18 and are also here today to support today's discussion.
19 Next slide, please. Today's agenda will 20 start with the background information supporting the 21 SECY paper.
22 I'll be discussing the regulatory issue 23 and the proposed rulemaking where I'll also go more 24 into the scope, process and schedule, and also 25 conclude with the staff recommendations.
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16 1 Next slide, please. So, SECY paper 21-2 0029 titled "Rulemaking Plan on Revision of Inservice 3 Testing and Inservice Inspection Program Update 4 Frequencies Required in 10 CFR 50.55a" was issued 5 March 15th, 2021.
6 It requests Commission approval to 7 initiate a rulemaking to amend 50.55a to extend the 8 interval of inservice testing and inservice inspection 9 program updates.
10 The current update interval is 120 months 11 and this request would extend this interval to 240 12 months for licensees that update to the most recent 13 edition and addenda of the ASME OM Code and BPV Code 14 Section XI incorporated by reference into 50.55a.
15 The SECY paper also requests the 16 Commission to delegate signature authority to the EDO.
17 The EDO would redelegate this rulemaking activity to 18 the NRR office director.
19 This would be similar to the delegation of 20 signature authority to the EDO by the Commission for 21 incorporating, by reference, revised editions and 22 addenda of national codes and standards that are 23 routine in nature and represent the update of basic 24 codes and standards that have already been approved by 25 the Commission for incorporation by reference.
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17 1 It also requests Commission approval and 2 delegations for a potential subsequent rulemaking to 3 extend the update interval from 240 months to 288 4 months, and I'll provide additional details regarding 5 this later in this presentation.
6 Next slide. 10 CFR 50.55a contains NRC 7 requirements for the use of certain codes and 8 standards for the design, construction and operation 9 of nuclear power plants.
10 50.55a incorporates, by reference, various 11 ASME codes including the ASME Operation and 12 Maintenance Code, or the OM Code; ASME BPV Code, 13 Section XI, Division 1; ASME BPV Code,Section III, 14 Division I.
15 ASME updates these codes on a regular 16 basis through a consensus standards development 17 process. The NRC's current practice is to incorporate 18 each new edition as it is published, which is roughly 19 every two years.
20 50.55a(f)(4) provides the inservice 21 testing standard requirements for operating plants.
22 50.55a(g)(4) provides the inservice inspection 23 standard requirements for operating plants.
24 Per these regulations, licensees are 25 required to update their OM Code and Section XI "Codes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 of record" to the latest edition incorporated by 2 reference into 50.55a every 120 months. A licensee 3 Section III "Code of record" is generally maintained 4 throughout the life of the plant.
5 Next slide, please. Through an NRR EMBARK 6 Venture Studio project, the NRC formed a team to 7 evaluate possible options to streamline the Agency's 8 treatment of ASME codes.
9 The project team developed ideas to 10 streamline regulating using 50.55a that would improve 11 the clarity of 50.55a, improve process efficiency for 12 the use of ASME Code and Code Cases, and increase 13 flexibility to licensees implementing their IST and 14 ISI programs.
15 The project team conducted multiple 16 outreach activities internal to the NRC as well as to 17 external stakeholders. External interactions included 18 three public meetings.
19 The project team documented its efforts, 20 including the recommendations they chose to advance 21 for further action in a final report, which can be 22 found at this ADAMS accession number here.
23 Next slide, please. Here are the three 24 recommendations: 1, relax the requirement to update 25 IST and ISI programs every 120 months; 2, institute NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 direct final rules for unconditionally approved code 2 cases and; 3, decrease frequency of ASME Code edition 3 rulemakings.
4 The scope of the SECY paper discussed the 5 proposed rulemaking for just Recommendation 1. The 6 staff believes that the extension of the IST and ISI 7 program update interval would provide improved 8 flexibility and burden reduction to licensees while 9 maintaining safety.
10 The SECY paper includes a rulemaking plan 11 for just Recommendation 1 because it was determined 12 that this recommendation is outside the scope of 13 delegation of authority for routine ASME Code updates 14 and, therefore, requires Commission approval.
15 The staff will implement Recommendations 16 2 and 3, which are within the staff's delegation of 17 authority for rulemaking.
18 Next slide, please. The project team also 19 considered eliminating incorporation by reference of 20 ASME BPV Code Section III and XI and ASME OM Code from 21 50.55a and endorsing the codes through a regulatory 22 guide, but, at this time, no decision has been made to 23 remove anything from 10 CFR 50.55a.
24 Next slide, please.
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20 1 here, Pete? This is Walt. On that last slide I'm 2 just trying to think through the implications.
3 If you move the reference from the 4 regulations, i.e., 50.55a, and do it through a reg 5 guide, what alternative would be acceptable to the 6 staff to provide an equivalent level of -- how should 7 I say it? I'm not trying to endorse the ASME, but 8 they are the -- they are the gold standard when it 9 comes to boiler and pressure vessels and their upkeep 10 and maintenance and inspection.
11 So, if you go to a reg guide, what's the 12 implication of that? What alternative would be 13 acceptable to the staff to provide the equivalency?
14 MR. YOO: Dave Rudland, would you like to 15 speak to that?
16 MR. RUDLAND: Sure. This is Dave Rudland.
17 So, there are a lot of international codes and 18 standards that are out there that are, you know, 19 fashioned either similar to or, in some cases, 20 identical to ASME Code and an applicant could propose 21 to use any codes and standards.
22 If we were to remove these from the 23 regulations and endorse them to a regulatory guide, we 24 would have to review and approve whatever the 25 applicant proposed.
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21 1 And as we move towards different types of 2 reactors, that may be a possibility. I don't know at 3 this time, but a complete review would have to be done 4 similar to what we do in putting ASME Code into the 5 regulations.
6 MEMBER KIRCHNER: So, doesn't that then 7 introduce uncertainty into the regulatory process 8 rather than -- I hear all the arguments about 9 flexibility and international supply chains, et 10 cetera, et cetera, et cetera, but this is a -- we're 11 licensing reactors in the United States.
12 MR. RUDLAND: No, I agree.
13 MEMBER KIRCHNER: It almost works against 14 your intent under the EMBARK Venture Studio to 15 streamline things. It may actually introduce 16 complexity and uncertainty and more work for the 17 staff.
18 You'll have to be an expert on other 19 codes. You would have to review the other codes, et 20 cetera. I'm just concerned that this is not 21 necessarily an improvement.
22 MR. RUDLAND: No, I agree that there will 23 be additional work that would need to be done and an 24 additional burden on the staff to come up to speed on 25 those through the review process.
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22 1 Again, this is something that we were 2 considering, but, in discussions, we haven't made a 3 decision on how to move forward on it yet, but I think 4 we do realize that there would be additional burden 5 that would be required.
6 MEMBER KIRCHNER: Well, I should have 7 caveated my comments by saying that's just one 8 member's opinion.
9 MR. RUDLAND: Yeah.
10 MEMBER KIRCHNER: So, I'm not speaking for 11 the Committee.
12 MEMBER RICCARDELLA: Walt and David, this 13 is Pete. Dave, you know this has been one of my 14 concerns for a long time going back to my early days 15 as a member of the Committee, was the amount of time 16 that it takes to get new code editions approved and 17 also code cases approved.
18 And remember I had several meetings on 19 that maybe six, seven years ago and it seemed to me 20 that the -- what was the bottleneck was the fact that 21 it had to be rulemaking. It had to go into a rule.
22 So, I'm not sure if a regulatory guide is 23 the right vehicle to do it, but somehow for routine 24 things like approving code editions -- and, by the 25 way, the NRC staff sits on all of these consensus NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 committees and they usually, you know, their members 2 approve of these changes before they get issued and 3 yet it still sometimes takes four or five years to get 4 them incorporated into 50.55a.
5 So, you know, I don't think the intent 6 would be to change anything relative to ASME Code 7 versus international codes, it's just it -- why does 8 it -- couldn't you have some rule language that was 9 more generic that accepted changes on a more 10 streamlined basis than having to go through formal 11 rulemaking?
12 MR. RUDLAND: Yeah. I think that was one 13 of the objectives of the original EMBARK effort was to 14 investigate that because I think we also realized, you 15 know, the amount of time it takes us to incorporate by 16 reference these issues.
17 And as you'll see, as Mark mentioned a 18 second ago, I mean, there are several recommendations 19 that were made to try to streamline that really that 20 we have a certain regulatory process that we have to 21 go through.
22 And the focus is basically on code cases 23 and the streamlining of our code case approval process 24 because we know that that's how most of the major 25 changes to the code are implemented, you know, are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 initially implemented before they're put into a code 2 edition.
3 MEMBER RICCARDELLA: Yeah.
4 MR. RUDLAND: So, that was our overall 5 goal of this is really to focus on those things that 6 we knew would help streamline the process.
7 MEMBER RICCARDELLA: Yeah. So, Walt, I 8 don't think the intent is to allow alternatives to the 9 ASME Code, it's just to somehow streamline the 10 approvals of the updates and the code cases of the 11 ASME Code.
12 MR. RUDLAND: But to be clear, the 13 applicant always has the opportunity and has the 14 ability to be able to submit whatever they want, you 15 know. And they don't, you know --
16 MEMBER RICCARDELLA: Right.
17 MR. RUDLAND: -- and they don't -- if we 18 were to take it out of the regulations, they would 19 have that ability to choose a different code or a 20 different methodology that would be reviewed for our 21 approval.
22 MEMBER BLEY: This is Dennis Bley. I 23 wanted to jump in. Two things. The first is while 24 that's true, in many areas we've seen applicants don't 25 do that because it can take them a very long time to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 get through the review process.
2 And even in other areas we've seen that 3 code approvals take so long and in other areas it's up 4 to 20 years sometimes and we just lag behind for no 5 particular reason.
6 My second question, really, I've been 7 hearing "EMBARK" over and over, and when we first 8 learned of EMBARK Venture Studios, my impression was 9 that was a way to bring new software approaches and 10 graphical approaches into making things more 11 presentable, and this is nothing like that.
12 So, I'm kind of -- if somebody else could 13 take a little time before the day's over and tell us 14 how and why EMBARK Venture Studios was involved in 15 this and is this a precursor to things we're going to 16 see in the future, it would be helpful.
17 MS. BRADFORD: Dr. Bley, this is Anna 18 Bradford. One thing I wanted to mention about the 19 ASME Code, someone had mentioned that NRC 20 representatives sit on all the committees.
21 That's true, but that doesn't mean that we 22 agreed with everything that the ASME Code ended up 23 approving because, as you probably know, there are 24 usually votes on those items.
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26 1 itself approved, but we did not agree with when it 2 comes to a regulatory approach or application.
3 So, just because we sit on those 4 committees didn't mean we agreed with everything and, 5 therefore, we should be able to just, you know, stamp 6 everything "okay" once they revise the codes. I did 7 want to make that point.
8 MEMBER BLEY: Yeah.
9 MS. BRADFORD: I also would say that the 10 things that you all have mentioned as concerns, we had 11 similar thoughts, you know. So, in providing 12 flexibility, you might also provide uncertainty.
13 And probably years ago when we said, hey, 14 let's adopt the ASME Code into our regulations, we 15 probably thought that was a streamlining approach, you 16 know, that, hey, then if someone says they comply with 17 the Code, then we don't have to do too much review and 18 we're done; but now we're realizing that maybe, you 19 know, some flexibility needs to be offered at least in 20 the process for it.
21 We are not moving forward with this right 22 now. This is just something that we considered in our 23 discussions and we are very interested to hear your 24 all's thoughts, too, because, like we said, we had 25 similar concerns.
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27 1 The EMBARK studio, Dr. Bley, I think you 2 mentioned you thought they were concerned with sort 3 of, I'll call, graphics or making our presentations 4 better.
5 That's true, that's one small thing they 6 worked on, but they really worked on a wide range of 7 activities just as I mentioned before. How can we 8 streamline our processes? How can we make things more 9 user-friendly? How can we improve our rulemaking 10 processes when we adopt things like the ASME Code?
11 So, there was really -- they really looked 12 at a wide scope of things to see if they could be 13 improved.
14 Many of them were based on staff 15 suggestions, things that staff saw when they were 16 working on things. Hey, why do we have to endorse 17 50.55 in a rulemaking? Couldn't we just do it through 18 a reg guide? Well, let's think about that and explore 19 it and think about whether or not that would be cost 20 beneficial.
21 So, I think you're going to hear of ideas 22 coming through EMBARK that's really going to touch on 23 a wide variety of areas. I don't know if that helps.
24 MEMBER BLEY: Thanks, Anna.
25 MS. BRADFORD: Okay.
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28 1 MEMBER BALLINGER: Dave Rudland, this is 2 Ron Ballinger. You've mentioned code cases off and on 3 and you've mentioned that it was possible in the 4 future for a non-ASME code application.
5 Since the NRC endorses many of these code 6 cases, if an applicant wants to use a code like the 7 French code, for example, how do the code cases 8 complicate things?
9 MR. RUDLAND: Code cases are alternatives 10 to the code. They're approved alternatives to the 11 code, right?
12 So, if we have -- once we have 13 incorporated those by reference, they can use those as 14 an alternative without a review and approval.
15 If something comes in that's not approved 16 or not in the regulations, then they have to come in 17 with an exemption or amendment to use that and we 18 would have to review it in its complete state.
19 MEMBER BALLINGER: Yeah. So, what that 20 means is if somebody wants to use a foreign code, 21 there's actually an increase in complexity to have to 22 deal with it.
23 MR. RUDLAND: Yes. Yes, that is true.
24 Very true.
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29 1 today. I mean, there's no difference in that, I don't 2 think, Ron.
3 MEMBER BALLINGER: True. And I don't 4 think anybody is -- I think everybody is using the 5 ASME Code.
6 MEMBER RICCARDELLA: Yeah. Yeah, but I 7 had personal -- a lot of personal experience with this 8 when we were developing weld overlays to repair 9 stress-corrosion cracks in boiling water reactors and 10 pressurized water reactors.
11 And we had code cases that addressed a lot 12 of the details that went into this weld overlay design 13 and analysis and they were all agreed upon by the 14 staff. And yet, we hadn't gotten them formally 15 incorporated into 50.55a or whatever the specific 16 thing that endorses code cases are.
17 And so, each time I'd have to come in with 18 an RAI and we'd go through literally months of 19 interactions with the staff to approve this RAI that 20 was basically just implementing the code case that had 21 been already agreed to by the -- at least by the staff 22 members who are on the committees and, yet, they still 23 hadn't gone through the formal rulemaking process.
24 That was -- that seemed to be the issue is getting 25 through the rulemaking process.
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30 1 MR. RUDLAND: And so, Pete, the thing that 2 came out of this EMBARK was a more efficient process 3 to incorporate unconditionally approved code cases at 4 quicker pace. I mean, that was one of the things we 5 knew we needed to address. So, that's one of the 6 things that came out of the EMBARK effort that will be 7 incorporated as part of this complete effort that 8 we're talking about today.
9 MEMBER RICCARDELLA: Well, that's great, 10 Dave.
11 MEMBER HALNON: Yeah, this is Greg Halnon.
12 I got just a question or maybe it's an opportunity 13 because I agree with everything that people said, but 14 it's also my understanding that the staff members from 15 the NRC that are on these committees are typically on 16 there to represent their own personal experience and 17 expertise rather than the NRC as an agency.
18 So, is there an opportunity to not do a 19 series review of these things, but actually change 20 what the members of the Committee from the NRC are 21 actually there for and have them represent the Agency 22 and --
23 MR. RUDLAND: So, Greg, let me correct 24 you. The staff go to these committee meetings, but 25 they are representing the NRC.
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31 1 MEMBER HALNON: Okay.
2 MR. RUDLAND: In any committee the NRC has 3 one vote and we vote as, you know, as a group.
4 MEMBER HALNON: Yeah, but I guess the 5 question, though, is if the NRC on these committees 6 disagree with a nuclear code standard that they say it 7 can't be used for the nuclear industry as written, 8 then why even issue it?
9 I mean, what else is going to be allowed 10 to be used? I mean, I realize everything else is 11 going to be by exception.
12 MR. RUDLAND: Well, again, typically the 13 way it works is that if there's an issue, you know, we 14 write a condition that needs to be followed. The ASME 15 also is not, you know, we're not the ASME's only 16 client.
17 So, they have a lot of international folks 18 that use the code also, and so they want to publish 19 them so that they can use it regardless of what we 20 think of the code.
21 MEMBER HALNON: It gets back to the NRC 22 being the gold standard, the ASME being the gold 23 standard. I guess my point is if those don't come 24 together and agree that an issued code is appropriate 25 for the United States, why would another country even NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 want to use it then?
2 MEMBER RICCARDELLA: Well, Greg, you know, 3 on these committees there are often cases where the 4 code cases or the code changes get a negative vote 5 from the NRC staff member.
6 That happens a lot, and what happens is 7 then you -- the Committee goes back and they negotiate 8 and they look at specific -- the specific issues that 9 cause that negative vote and they change it, and 10 eventually they come -- something comes out that the 11 NRC staff does agree to.
12 I wasn't talking about code cases that had 13 negative votes from the staff members. I'm talking 14 about code cases where they ultimately -- all the 15 issues got resolved and the NRC staff member voted 16 positively, and then it still takes five years before 17 it gets incorporated into the regulations.
18 MEMBER HALNON: Yeah, Peter, and I'm 19 supporting your discussion there and that is the 20 information would be to allow that review to go in 21 parallel, or at least the NRC process to go in 22 parallel, with the code committee's process.
23 MR. RUDLAND: And that's something that, 24 again, that we're trying to do for these 25 unconditionally approved code cases.
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33 1 And I've been involved with ASME since the 2 '90s and I, you know, they've always been very 3 collegial between staff and those on the Committee.
4 And as Pete inferred, you know, the work 5 is always done to try to remove any negatives before 6 the code cases are published or the code actions are 7 published.
8 And we strive to do that as a staff also 9 because we don't want those conditions in there 10 either.
11 MEMBER RICCARDELLA: Okay.
12 MR. RUDLAND: So, you know, I think that 13 the effort is in that direction, it just doesn't 14 always -- it doesn't always work out.
15 MEMBER HALNON: Yeah, I just -- I question 16 an American society issuing a code in America that 17 America can't use. I don't get it, but that's fine.
18 We can move on.
19 MR. YOO: Okay. Next slide, please, Dave.
20 So, SECY-00-0011 discussed a request that is similar 21 to what is being requested now.
22 In the SECY paper in 2000, the staff 23 recommended eliminating the 120-month IST and ISI 24 update requirements if a licensee updates to a 25 baseline IST and ISI requirements with voluntary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 updates to NRC-endorsed Code editions.
2 The voluntary updates would be done 3 without prior NRC approval and the staff, at that 4 time, selected the 1995 edition with the '96 addenda 5 of the ASME OM and BPV Codes.
6 After discussion with the staff, the ACRS 7 recommended to the Commission to reject the staff 8 recommendation and retain the 120-month update 9 interval.
10 The Commission went with the ACRS' 11 recommendation and, via SRM, disapproved the staff's 12 recommendation and approved the option to retain the 13 120-month update interval.
14 Next slide, please.
15 MEMBER RICCARDELLA: What was the date of 16 that? Refresh my memory. What was the date of that 17 ACRS recommendation?
18 MR. YOO: I can find that real --
19 MEMBER RICCARDELLA: It was quite a while 20 ago, right?
21 MR. YOO: Yeah. The SECY was issued in 22 year 2000. I can find that.
23 MEMBER RICCARDELLA: Okay. No, that's 24 okay.
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35 1 2000.
2 MEMBER RICCARDELLA: Yeah. I think that, 3 you know -- well, for one thing, that didn't propose 4 just extending the period. It proposed eliminating it 5 and I think you do have to have this requirement for 6 updates.
7 But, you know, in the early days in the 8 1990s, the codes were still being developed and were 9 getting changed very frequently, and I think we've 10 gotten to the point now where the codes are more 11 stable and there's not as many changes and that kind 12 of goes along with extending the update period, I 13 think.
14 MR. YOO: Correct. Yeah. And so, the 15 staff met with ACRS in December of 1999 and the ACRS 16 made their decision in February of 2000.
17 MEMBER RICCARDELLA: Uh-huh. Yeah, the 18 ACRS doesn't make decisions, they make 19 recommendations.
20 MR. YOO: Or recommendation. I apologize.
21 MEMBER RICCARDELLA: Okay.
22 MR. YOO: Next slide, please. And so, 23 licensee IST and ISI programs describe licensee's 24 implementation of the ASME OM Code and ASME BPV Code, 25 Section XI requirement respectively.
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36 1 Licensee IST and ISI programs play an 2 important role in ensuring the safe operation of 3 nuclear power plants.
4 ASME continually updates the OM and BPV 5 Codes as technology evolves or new technical 6 challenges arise.
7 Per 10 CFR 50.55a, a licensee must update 8 their IST and ISI programs to the latest edition and 9 addenda of the ASME OM and BPV Code,Section XI, that 10 had been incorporated by reference, every 120 months.
11 They must do this within 18 months of the 12 start of their 120-month interval. The 120-month 13 interval corresponds to the 10-year ISI interval in 14 ASME BPV Code,Section XI, IWA-2430.
15 Next slide, please. In recent years, ASME 16 has made significant improvements to the OM Code to 17 address valve performance issues revealed by nuclear 18 power plant operating experience and through NRC and 19 industry valve testing programs; however, the 20 development of major modifications to the ASME Codes 21 typically takes more than a decade.
22 For example, ASME updated the OM Code and 23 the 2009 edition to improve the IST requirements for 24 active motor-operated valves. This was done in 25 response to a Generic Letter that the NRC issued in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 1989. So, this was a 20-year process.
2 ASME also updated the 2017 edition of the 3 OM Code to include improved IST requirements for 4 active air-operated valves. This was done in response 5 to a Regulatory Issue Summary that the NRC issued in 6 2000. So, this was a 17-year process.
7 These two major modifications took longer 8 than a decade to complete or, in other words, longer 9 than the current 120-month program update frequency.
10 This trend gives the staff confidence that 11 it is possible to extend the program update interval 12 without significantly affecting how frequently 13 improvements in the Code are required to be adopted by 14 licensees.
15 MEMBER BALLINGER: Yeah, this is Ron 16 Ballinger. For me, Bullet No. 2 is a big deal because 17 things have greatly improved in terms of how we build 18 these things and what we use for materials. So, I 19 think that's a major plus.
20 MR. YOO: Yeah. So, another point we 21 wanted to make was that the discovery of new 22 degradation mechanisms has showed great -- has slowed 23 greatly in recent years.
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38 1 and mitigation of active degradation.
2 In the 1980s, nuclear power plants 3 experienced many degradation mechanisms such as 4 intergranular stress-corrosion cracking, flow-5 accelerated corrosion, that challenged ASME to adapt 6 and provide examination, analysis and mitigation 7 techniques to ensure continued, safe operation.
8 However, the last degradation mechanism 9 that was discovered -- last major degradation 10 mechanism that was discovered was primary water 11 stress-corrosion cracking occurring in pressurized 12 water reactor pipe and head welds. This was 13 discovered in the early 2000s.
14 This shows that the discovery of new major 15 degradation mechanisms has slowed greatly in recent 16 years as PWSCC was identified over a decade ago. This 17 trend gives the staff confidence that new major 18 degradation mechanisms will be discovered less 19 frequently.
20 Next slide, please. So, the staff also 21 recognizes the long history and established process of 22 developing improvements and updates to the ASME Codes.
23 The ASME Code process has evolved to meet nuclear 24 community's needs.
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39 1 discovery of new degradation mechanisms or performance 2 issues are typically first addressed by ASME using 3 Code cases before incorporating into an edition.
4 ASME's use of Code cases has become 5 focused on new technology and methods with ASME 6 publishing ISI Code cases roughly quarterly and IST 7 Code cases on a rolling basis as they are completed.
8 The NRC reviews new and revised Code cases 9 and incorporates them into the regulations with 10 conditions, if necessary.
11 As noted previously, one of the EMBARK 12 Venture Studio recommendations was to incorporate by 13 reference noncontroversial Code cases using an 14 expedited process.
15 And, again, this would allow licensees to 16 use new approaches and technologies more promptly 17 without coming to the NRC for approval.
18 To address emergent degradation of 19 performance issues that have posed a significant 20 safety concern, the NRC can mandate the use of certain 21 Code cases to require additional analyses, 22 examinations and quality assurance activities to 23 supplement the applicable ASME Code edition. And this 24 is something that the NRC has done in the past.
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40 1 rulemaking scope would double the time between updates 2 for licensee's Codes of records for IST and ISI 3 programs from 120 months to 240 months. And this 4 would be licensees that have updated to the most 5 recent edition and addenda of the ASME OM Code and BPV 6 Code,Section XI, that have been incorporated by 7 reference in 10 CFR 50.55a.
8 Again, the current 120-month ISI program 9 update interval corresponds to the current 10-year ISI 10 interval in ASME BPV Code,Section XI.
11 For clarity and consistency, the staff 12 proposed the 240-month interval, or two ISI intervals, 13 in order to extend the Code of record update interval 14 while maintaining alignment with the ISI interval.
15 The proposed rulemaking would primarily 16 affect the requirements for IST standards and ISI 17 standards found in 10 CFR 50.55a(f)(4) and (g)(4) 18 respectively.
19 Next slide, please. This SECY paper also 20 requests approval for a potential future rulemaking to 21 extend the update frequency requirement from 240 22 months to 288 months. And this is because ASME is 23 considering extending the current ISI interval from 10 24 years to 12 years.
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41 1 recommend extending the IST and ISI program update 2 cycle to 288 months. Again, two ISI intervals or 24 3 years.
4 Therefore, the staff requests that the 5 Commission also approve this additional rulemaking and 6 delegation of authority in this rulemaking plan to the 7 EDO, but I want to emphasize that the staff is not 8 currently proposing to conduct that rulemaking and 9 ASME has not yet extended the ISI interval.
10 Next slide, please. The typical 11 rulemaking process includes development of a 12 rulemaking plan, regulatory basis, proposed rule and 13 final rule.
14 The staff recommended omitting preparation 15 of a regulatory basis and proceeding with the proposed 16 rule development.
17 As documented in the EMBARK Venture 18 Studios report, the staff had previously had 19 significant interaction with members of the public, 20 including industry stakeholders, on this regulatory 21 issue and proposed recommendations and, as discussed, 22 the staff proposes a clear and narrow scope of 23 rulemaking.
24 And, again, the staff recommended that the 25 proposed rule and the final rule be delegated to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 EDO, who would redelegate to the Director of NRR.
2 Next slide, please. The SECY paper is 3 currently --
4 MEMBER BLEY: Excuse me. This is Dennis 5 Bley. I was just thinking about that last one and I 6 assume those of you involved in this effort are 7 keeping abreast of Part 53 and they, too, were 8 streamlining the process some and what's happened --
9 and I'm not sure this is a negative. It's probably a 10 positive, but what's happened is because they skipped 11 some of the normal processing, they're having monthly 12 meetings with stakeholders and with the ACRS, which is 13 not clear to me what the tradeoff is there and I 14 wonder if you've been thinking about that.
15 MR. TAYLOR: Hey, Mark, this is Rob 16 Taylor. Can I take that one?
17 MR. YOO: Yes, please.
18 MR. TAYLOR: So, Dennis, thank you for the 19 question. As the deputy office director for New 20 Reactors, both of these projects are actually within 21 my shop. I'm very familiar with both activities.
22 I would say that Part 53, because it's 23 such a substantial crosscutting regulatory project 24 that we're trying to implement with an entirely new 25 framework, it has its own set of complexities.
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43 1 I think this is more narrowly focused.
2 It's an important thing that we're doing, but I think 3 we'll be like, okay, we're skipping the regulatory 4 basis piece.
5 We do that in other rulemakings when it's 6 pretty straightforward what we're trying to do, or 7 when we think it's pretty straightforward, so I think 8 we'll be okay in this particular case with skipping 9 it. So, I don't see them as exactly the same between 10 the two projects.
11 MEMBER BLEY: I wouldn't either, but 12 thanks, Rob. That makes more sense to me.
13 MR. TAYLOR: No problem.
14 MR. YOO: Okay. Next slide. Okay. The 15 SECY paper is currently with the Commission. The 16 schedule includes delivering the proposed rule to the 17 NRR office director 12 months after receipt of the 18 Commission's SRM. The final rule will be delivered to 19 the NRR office director 12 months after the comment 20 period for the proposed rule closes.
21 Depending on the timing of the 22 Commission's direction, the staff will consider 23 combining this rulemaking activity with the next 24 routine ASME Code edition or Code Case rulemaking if 25 it results in a more timely, efficient and an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 1 effective implementation of the Commission's 2 direction.
3 Next slide, please. To summarize, the 4 staff's recommendations in the SECY paper, the staff 5 is requesting that the Commission --
6 MEMBER BLEY: I'm sorry, Mark. Can I 7 interrupt you again? On your last slide -- can we go 8 back to the last slide? It's an interesting idea.
9 So, I take it this means you will be 10 absolutely prepared to move ahead with this rulemaking 11 the next time you get a rulemaking for the Code. So, 12 you're just saving it until that point; is that right?
13 MR. YOO: Victoria Huckabay, would you 14 like to speak to that?
15 MS. HUCKABAY: Yes. This is Victoria 16 Huckabay. So, what we're saying in the rulemaking 17 plan is that if it is -- if we find that the timing 18 permits and if it's efficient to do so from the 19 standpoint of the amount of effort involved, we may 20 combine this rulemaking, if it's approved by the 21 Commission, with the next routine ASME Code edition or 22 Code Case rulemaking.
23 Right now, you know, if we were to speak 24 theoretically as to where we are today, for instance, 25 right, well, let's just say if for some reason we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 receive the SRM from the Commission just in the next 2 few days, which we're not necessarily expecting, but 3 if it were to happen, right, we are currently not in 4 the position to do this sort of combining because we 5 have two ongoing rulemakings, the 2019-2020 Code 6 edition rulemaking and the Code Case Revision 39 7 rulemaking, which both happen to be in the final rule 8 stage and we are not working on the next Code Edition 9 or Code Case rulemaking just yet.
10 So, right now this may not be a good time, 11 but if we receive an SRM, let's just say, you know, in 12 the next few months, then there may be a good 13 opportunity to do so.
14 So, it just really depends on the timing 15 of where we are with the next routine Code Edition 16 rulemaking or Code Case rulemaking and when the SRM 17 arrives.
18 MEMBER BLEY: Okay. Thanks.
19 MR. YOO: Next slide, please. Okay.
20 Again, to summarize the staff's recommendation, the 21 staff is requesting that the Commission approve 22 initiation of a rulemaking to extend the interval for 23 the IST and ISI program updates from 120 months to 240 24 months for licensees that have updated to the most 25 recent edition of the ASME OM Code and BPV Code NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 Section XI that have been incorporated by reference in 2 10 CFR 50.55a.
3 It would also approve a future potential 4 rulemaking to extend the interval from 240 months to 5 288 months if ASME increases the ISI interval to 12 6 years, approve the staff's request not to develop a 7 regulatory basis for these rulemaking, and delegate 8 signature authority for these actions to the EDO.
9 Next slide. That concludes our 10 presentation. Are there any additional questions?
11 MEMBER RICCARDELLA: This is Pete. Could 12 we go back to the last slide, please. Those last two 13 bullets, I understand that you don't need a regulatory 14 basis.
15 When I looked into this several years ago, 16 one of the key things -- one of the big bottlenecks 17 and things that were slowing down the process were the 18 -- was the required OGC review. In other words, the 19 staff, the technical people had it all worked out and 20 then it took it a year, 18 months to get OGC review 21 and approval.
22 Does this last bullet maybe obviate the 23 need for that?
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47 1 they've been active in, you know, every step of the 2 process.
3 MEMBER RICCARDELLA: Um-hmm.
4 MS. BRADFORD: Dr. Riccardella, this is 5 Anna Bradford again. We would, of course, still get 6 OGC review because rulemakings are so fundamental and 7 important --
8 MEMBER RICCARDELLA: Yeah.
9 MS. BRADFORD: -- to what we do that we 10 definitely want their involvement and approval for 11 these, but I don't think it would take anywhere near 12 a year to 18 months for just OGC to review it.
13 MEMBER RICCARDELLA: Yeah. It has in the 14 past, I think.
15 MR. TAYLOR: Pete, just let me add we've 16 changed a lot of approaches. We have a great working 17 relationship with OGC.
18 That hasn't always been the case, but now 19 we bring OGC in on the projects on the front end as 20 opposed to providing the projects to them on the back 21 end. So, they're with us the whole way on some of 22 these important activities.
23 MEMBER RICCARDELLA: Okay.
24 MR. TAYLOR: So, it streamlines their 25 review substantially on the back end, but it does --
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48 1 occasionally it does take a little bit of time because 2 we are putting new rules in place and we need to be 3 very careful that we don't have unintended 4 consequences when we do that.
5 MEMBER RICCARDELLA: Yeah. I was just 6 wondering if the rule could actually be written with 7 more flexibility such that it admits future changes to 8 the ASME Code if approved by the EDO, for example, 9 without changing the rule.
10 MS. BRADFORD: I'm not sure I understood 11 that, Dr. Riccardella. Can you explain a little bit 12 more that thought?
13 MEMBER RICCARDELLA: Just to make the rule 14 say that we accept the ASME Code, these editions --
15 these specific editions/addenda, plus future revisions 16 to those codes, those same codes if approved by the 17 EDO.
18 I thought, you know, that would be my 19 interpretation of what's meant by that last bullet.
20 MR. TAYLOR: Pete, this is Rob Taylor.
21 So, we have to be careful that we can't -- so, I think 22 part of your answer is okay, but part I'm worried 23 about. We can't preapprove things in rulemaking 24 because that cuts the stakeholders and the public out 25 of the discussion.
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49 1 So, any updates to the ASME Code that we 2 want to incorporate into 50.55a, either via the Code 3 Cases or the editions, has to go through the 4 rulemaking process so that we give the public the 5 opportunity to engage.
6 The ability to delegate the authority from 7 the Commission down to the EDO already exists for most 8 Code Case update activities.
9 The unique nature of this one is because 10 there was a policy decision before by the Commission 11 on it, we felt we needed Commission approval to go 12 forward with this activity before -- that it didn't 13 fall within the purview of the delegated authority 14 that was given to the EDO. I hope that makes sense.
15 MEMBER RICCARDELLA: Yeah. Alright.
16 CHAIRMAN SUNSERI: Hey, Pete, Vicki's got 17 her hand up. You might want to recognize her.
18 MEMBER RICCARDELLA: Okay. Vicki?
19 MEMBER BIER: Sure. I have, I hope, a 20 quick question. You mention that the rate at which 21 new degradation mechanisms is -- are being discovered 22 is slowing down quite a bit. So, there isn't an 23 anticipation that there's going to be some urgent new 24 items showing up, you know, five years from now or 25 whatever.
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50 1 I assume that if that did happen, that 2 could be handled on a sort of case-by-case basis based 3 on the urgency of the issue; is that correct?
4 MR. RUDLAND: Vicki, this is Dave Rudland 5 from the staff. Yeah, the way that would be typically 6 handled, as the Code is handling it now, is that 7 they're developing analysis, methodology, mitigation 8 strategies through the development of Code Cases and 9 we're not proposing to change anything about -- right 10 now about our Code Case approval process. So, we'd be 11 able to approve that at the same pace that we are 12 right now.
13 And if it was something that we thought 14 was safety-significant, we could mandate a particular 15 Code Case directly into the regulations.
16 MEMBER BIER: Okay. Thank you.
17 MEMBER RICCARDELLA: Okay. So, are there 18 any other questions or comments from the members?
19 MEMBER BLEY: Pete?
20 MEMBER RICCARDELLA: Yeah.
21 MEMBER BLEY: This is Dennis. Is the 22 staff looking for a letter from us at this time? I 23 think this meeting -- no, you already had the 24 subcommittee meeting, so this is the final meeting on 25 it.
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51 1 MEMBER RICCARDELLA: Actually, we didn't 2 have a subcommittee. We decided to turn the 3 subcommittee --
4 MEMBER BLEY: Oh, this is it?
5 MEMBER RICCARDELLA: We decided to turn 6 the subcommittee into this information briefing and I 7 think the, you know, just calling it an "information 8 briefing" indicates that, I think, the plan is not to 9 write a letter, but that's open for Committee 10 consideration.
11 MEMBER BLEY: What are your thoughts?
12 You've been involved in this more than the rest of us.
13 MEMBER RICCARDELLA: I don't think we need 14 to write a letter on this topic. I think that the 15 staff is making progress in an area that needed to be 16 made and I don't think there are complexities that 17 require us to write a letter, but I'm open to input 18 from the Committee on that.
19 MEMBER BLEY: No, I think I agree with 20 you, but I wanted to hear what you thought.
21 MEMBER BALLINGER: This is Ron. I think 22 I may a little bit disagree. We wrote a letter a long 23 time ago in which we recommended not doing this, in 24 effect, and that became the policy.
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52 1 not eliminating the updates at all --
2 MEMBER BALLINGER: Right. Yeah.
3 MEMBER RICCARDELLA: -- as opposed to 4 extending them from 120 to 240.
5 MEMBER BALLINGER: Right. So, this -- I'm 6 wondering whether or not we should write a letter in 7 which we, you know, go over what we did in the past 8 and say, well, things have changed and this is why and 9 so now we approve.
10 MEMBER RICCARDELLA: Um-hmm.
11 MEMBER BALLINGER: We have done a letter 12 in the past, which this runs counter to.
13 MEMBER RICCARDELLA: Yeah. It might be 14 interpreted that way anyway, yeah. Yeah.
15 MEMBER BLEY: Maybe Rob Taylor could give 16 us a thought about whether the staff thinks it would 17 be useful to them.
18 MR. TAYLOR: So, of course. I'd be glad 19 to, Dennis. This is Rob Taylor again. Yeah, we don't 20 -- we're accommodating the ACRS' request here. So, we 21 certainly -- it's the ACRS' prerogative whether they 22 want to write the letter. The staff doesn't feel we 23 need one. We think we explained everything in the 24 paper.
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53 1 supportive of the staff, we wouldn't argue with that 2 at the end of the day, for sure. So, I mean, it's the 3 Committee's decision. The staff will be supportive 4 either way.
5 MEMBER BLEY: Okay. Thanks, Rob.
6 MS. BRADFORD: This is Anna Bradford. Can 7 I just add to what Rob said? I agree with what Rob 8 said.
9 I also do think, though, that people look 10 back to that letter from 20 years ago and say, well, 11 the ACRS was not supportive of changing this and, 12 yeah, it was a different kind of change, it was 13 eliminating altogether, but I think it might be 14 interpreted as the ACRS was not supportive of changing 15 the ten years, period.
16 So, again, of course it's up to the 17 Committee, but, you know, people do still look back at 18 that letter.
19 MR. RUDLAND: Yeah. Pete, this is Dave.
20 MEMBER KIRCHNER: Pete, going back to the 21 earlier conversation and Ron's point, probably the 22 ACRS back then -- I'd have to pull the letter up and 23 read it, but we certainly have a lot more knowledge 24 about these systems than we did 20 years ago. A lot 25 more experience, at least.
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54 1 MEMBER BALLINGER: Yeah. I mean, back 2 when -- in those early days we were dealing with alloy 3 600.
4 MEMBER KIRCHNER: Well, we had pressurized 5 thermal --
6 MEMBER BALLINGER: Yeah, all that stuff.
7 MEMBER KIRCHNER: -- shock, chloride 8 stress corrosion.
9 MEMBER BALLINGER: Yes.
10 MEMBER KIRCHNER: All those issues 11 suggested we don't know with high degree of confidence 12 --
13 MEMBER BALLINGER: But, in spite of that, 14 CDF and LERF for these kind of leaks, primary system 15 leaks, was still on the -- in the 10 to the minus 6 16 for -- at the 10-year ISI inspection.
17 Now, all these welds have been 18 dispositioned and they're using a different material, 19 so my suspicion is that the CDF for leakage in one of 20 these things, plus the improvement in leak rate 21 testing and all this kind of stuff will make the CDF 22 out of sight low (phonetic).
23 MEMBER RICCARDELLA: Yeah.
24 MEMBER KIRCHNER: So, reflecting on Anna's 25 comments, Pete, I was just thinking perhaps a very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 1 brief letter just acknowledging that the state of 2 knowledge and experience --
3 MEMBER RICCARDELLA: Um-hmm.
4 MEMBER KIRCHNER: -- in the last 20 years 5 allows the confidence to go from 120 months to 240 or 6 maybe to 288.
7 MEMBER RICCARDELLA: Um-hmm.
8 MEMBER BALLINGER: And we're only changing 9 the updates. We're not changing the fact that people 10 -- that if something happens --
11 MEMBER RICCARDELLA: Yeah.
12 MEMBER BALLINGER: -- we would find it --
13 we would find it much more quickly than we would have 14 15, 20 years ago.
15 MR. TAYLOR: I would simply say the staff 16 -- this is Rob Taylor -- the staff would be very 17 appreciative of such a letter.
18 MEMBER RICCARDELLA: Okay.
19 MEMBER PETTI: So, Pete, this is Dave. I 20 --
21 MEMBER RICCARDELLA: Scott Moore has his 22 hand up. Scott, do you have any information?
23 MR. MOORE: Yes, Chairman Riccardella.
24 The letter you're talking about is dated February 8th, 25 2000.
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56 1 For anybody from the public or anybody 2 else that's listening, it's available on the ACRS' 3 public website.
4 And for the members, I just emailed it to 5 all the members -- or I emailed the link to all the 6 members, so you should have it in your email.
7 MEMBER RICCARDELLA: Okay. Thank you.
8 MEMBER PETTI: So, Pete, this is Dave. I 9 tend to have the same thing that Ron had brought up 10 and supporting Walt. I think a short, sweet letter is 11 probably worth it.
12 MEMBER RICCARDELLA: Okay. Any --
13 MEMBER HALNON: This is Greg. I think 14 that any time you can support an output of the EMBARK 15 also would give the commissioners additional 16 confidence and moving forward on other transformations 17 as well.
18 MEMBER RICCARDELLA: Okay.
19 MEMBER BLEY: Yeah. Pete, this is Dennis 20 again. I've been convinced by this discussion.
21 Practical question, we don't have a full committee 22 meeting next month --
23 MEMBER RICCARDELLA: Yeah.
24 MEMBER BLEY: -- so would this roll over 25 to Ron or is this something we could actually pull off NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 this week?
2 MEMBER RICCARDELLA: Boy.
3 MEMBER BALLINGER: I'm open to anything.
4 I don't think that Pete is going to not answer the 5 phone.
6 (Laughter.)
7 MEMBER BALLINGER: If he does, I know a 8 guy from east Boston that might be able to help.
9 CHAIRMAN SUNSERI: So, if we gave you time 10 to put something together and we would visit it Friday 11 afternoon, would that be doable?
12 I mean, this is going to be a very short 13 letter, right? I'll reemphasize "very short letter."
14 MEMBER RICCARDELLA: Okay.
15 CHAIRMAN SUNSERI: Alright.
16 MEMBER RICCARDELLA: You know that famous 17 quote I always say, it's --
18 (Simultaneous speaking.)
19 MEMBER RICCARDELLA: -- write a short 20 letter, so I'll write a long one.
21 CHAIRMAN SUNSERI: So, don't be Napoleon, 22 be -- do something that --
23 MEMBER BALLINGER: I don't think we should 24 underestimate -- there's another angle to this and 25 that is this letter would be useful for the -- believe NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 1 it or not, the insurance companies, you know. They 2 really drive -- for nuclear plants, they really drive 3 a lot of things.
4 CHAIRMAN SUNSERI: Yeah, but it's -- you 5 know, I'm supportive of the letter, obviously, and we 6 can write it with Dennis. I just would think, though, 7 that as was mentioned here earlier today, we don't 8 approve these things, we just make recommendations.
9 So, you know, I'm not sure how that would affect what 10 the insurance companies do then.
11 MEMBER BALLINGER: Well, but what happened 12 was the last letter we wrote became policy.
13 CHAIRMAN SUNSERI: Only because the staff 14 chose to do that.
15 MEMBER BALLINGER: Yeah. Yeah.
16 MEMBER BROWN: Can I ask a question then 17 if we're going to do a letter or thinking about a 18 letter? Are the specific items we would be, quote, 19 agreeing with proceeding with the items listed on 20 slide 17?
21 The rest of it was discussion, but here 22 they at least say that's what they're recommending.
23 That's -- I presume that's what we would say we don't 24 have any objections to; is that correct?
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59 1 understand it, Charlie.
2 MEMBER BROWN: Alright. Just wanted to 3 make sure we knew what we were specifically going to 4 deal with. At least it was summarized nicely on this 5 last slide, in my opinion.
6 MEMBER RICCARDELLA: Yes.
7 CHAIRMAN SUNSERI: So, let me just do a 8 quick straw poll then of the Committee and we don't 9 have to make this a vote, but I'll just ask it this 10 way: Is anybody opposed to pursuing a short letter on 11 this topic as just been discussed?
12 (Pause.)
13 CHAIRMAN SUNSERI: Okay. So, I think 14 that's our answer, Pete. And I guess you'll enlist 15 some help on this. Maybe sounds like Ron wants to 16 contribute.
17 Anybody else that wants to contribute, you 18 know, if you could put together the draft and we'll 19 plan on tackling it Friday afternoon.
20 MEMBER RICCARDELLA: Yeah. You know, I am 21 not that heavily involved in some of the other topics, 22 so maybe I will excuse myself from some of the 23 meetings and work on generating a draft of the letter.
24 MR. TAYLOR: Can I interject and add one 25 thing, Matt?
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60 1 CHAIRMAN SUNSERI: Sure, Rob. Go ahead.
2 MR. TAYLOR: Thanks. And thank you, guys, 3 for the good discussion. This has been very, very 4 interesting to hear your perspectives and we always 5 appreciate coming to the Committee.
6 I think that the idea of doing a letter 7 this week, if you're going to do it, would be very 8 valuable.
9 Of course the Commission will take up and 10 make their decisions on the time frame they choose to, 11 but we provided this a few months ago to the 12 Commission, so they could be deliberating on it.
13 And if you delay sending the letter, you 14 miss -- you may miss the opportunity to inform and 15 provide your recommendations.
16 So, finishing it this week, if you're 17 going to take it up, would be phenomenal. I think the 18 Commission would appreciate having the ACRS' 19 perspectives.
20 MEMBER RICCARDELLA: Okay. Yeah. Well, 21 I think particularly in light of the fact that we're 22 on record of a previous letter that sort of is -- was 23 opposed to this type of a change.
24 VICE CHAIRMAN REMPE: It also makes your 25 last meeting very memorable, Pete.
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61 1 (Laughter.)
2 MEMBER RICCARDELLA: Yeah.
3 CHAIRMAN SUNSERI: So, before you go to 4 public comments, Pete, here --
5 MEMBER RICCARDELLA: Yeah.
6 CHAIRMAN SUNSERI: -- I just want to see 7 if there's anything else because what we're going to 8 have to do, unfortunately, is we're going to have to 9 take a 10-minute break before we go to public 10 comments. That's because somebody muted the public 11 line and we're going to have to reset it.
12 So, instead of going through all of that 13 stuff with everybody on the record, we'll take a 10-14 minute break while the public line gets reestablished 15 and then we'll call for public comments then.
16 But, Pete, I just want to make sure that 17 you have wrung out from the Committee any others --
18 any comments that you have before we do that. So, go 19 ahead.
20 MEMBER RICCARDELLA: Nope. I don't think 21 -- are there any other comments from the Committee?
22 I don't see any hands up or --
23 CHAIRMAN SUNSERI: Okay.
24 MEMBER RICCARDELLA: So, we'll take a 25 break now and reconvene at 10 minutes before the hour.
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62 1 CHAIRMAN SUNSERI: Right. So, this is 2 going to sound awkward, so let me just describe this.
3 So, we'll take a break, we'll reconvene, then we'll 4 ask for public comments, and then we'll take another 5 break, a longer break, to support our 11:30 session.
6 Alright. So, we will take a break until 7 10 til. Thank you.
8 (Whereupon, the above-entitled matter went 9 off the record at 10:40 a.m. and resumed at 10:50 10 a.m.)
11 CHAIRMAN SUNSERI: Okay. It is 10:50.
12 Pete, are you back?
13 MEMBER RICCARDELLA: I am back.
14 CHAIRMAN SUNSERI: So, do we have the 15 public line reestablished? I think I heard we do.
16 MR. DASHIELL: That is affirmative, Matt.
17 CHAIRMAN SUNSERI: Okay. Pete, go ahead 18 and call for your comments. I was contacted during 19 the break by NEI, Tom Basso. He wants to make some 20 comments, too, so there --
21 MEMBER RICCARDELLA: Okay.
22 CHAIRMAN SUNSERI: -- will be at least one 23 set. Go ahead.
24 MEMBER RICCARDELLA: So, are there any 25 members of the public that would like to make a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 comment at this time? Please do so.
2 MR. BASSO: Yeah. This is Tom Basso from 3 NEI, if I may.
4 MEMBER RICCARDELLA: Alright. Go ahead, 5 Tom.
6 MR. BASSO: Okay. Yeah. Good morning.
7 Again, my name is Tom Basso. I'm senior director of 8 Engineering and Risk at the Nuclear Energy Institute.
9 I also manage and coordinate the NEI Codes and 10 Standards Task Force.
11 I appreciate the opportunity to provide 12 the following comments that are in support of these 13 changes.
14 The NEI Codes and Standards Task Force 15 participated in the referenced public meetings with 16 the NRC EMBARK Studios and on December 3rd, 2019, 17 presented various recommendations on simplification of 18 10 CFR 50.55a, including extending the requirements to 19 update the inservice inspection and inservice testing 20 programs from every 10 years to up to 24 years.
21 From initial licensing of plants and 22 implementation of the inservice inspection and 23 inservice testing programs decades ago, the 120-month 24 update had more utility since it was a way to review 25 code inspection requirements and their impact and, in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 some cases, add or remove requirements based on newer 2 code versions; however, now there are less expansive 3 and impactive changes in the ASME Section XI and OM 4 codes. As plants and the codes have matured, the need 5 for a living ASME Code has been reduced.
6 Additionally, licensees can, and have, 7 implemented other mechanisms to quickly react to 8 emerging issues through industry groups to address 9 safety or regulatory concerns as compared to waiting 10 for the 120-month update or can, and have, implemented 11 Code improvements and relaxations by requesting use of 12 alternatives in accordance with 10 CFR 50.55a(z).
13 Licensees can always adopt later NRC-14 approved ASME code editions, but should not be 15 mandated to do so since they would already be 16 following an NRC-approved ASME Code Edition that 17 ensures adequate protection.
18 Again, change is necessary for safety 19 purposes and can be specifically stated or conditioned 20 in 10 CFR 50.55a or through other generic regulatory 21 communications.
22 Updating the station's ASME inservice 23 inspection and inservice testing plans is a 24 significant and costly effort. An update not only 25 involves revising each program's plan, but numerous NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 1 station maintenance and operating procedures, 2 databases and maintenance planning systems.
3 On average, an update consumes hundreds of 4 staff hours at approximately $1 million per program, 5 resources that could be applied to more safety-6 significant activities or station improvements.
7 NEI supports this change and appreciates 8 the staff pursuing expansion of the delegated 9 authority to make this rule change.
10 This would greatly benefit the industry 11 while maintaining adequate protection and safety of 12 the plants and the public.
13 NEI would recommend that ACRS document 14 their position on this change to encourage Commission 15 action in light of the previous ACRS position 16 documented in 2000. So, I'll appreciate that 17 discussion towards the end.
18 Just lastly, I didn't find the slides in 19 ADAMS and just was wondering if those could be made 20 available to the public and thank you.
21 MEMBER RICCARDELLA: Okay. Well, thank 22 you, Thomas. Are there any other members of the 23 public who would like to make a comment at this time?
24 (Pause.)
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66 1 we will close this session of the meeting and I will 2 take the action to prepare a draft letter for 3 committee consideration during this meeting.
4 CHAIRMAN SUNSERI: Thank you, Pete.
5 Appreciate that. Let me just ask our DFO, Kent 6 Howard, did you pick up on that comment about the 7 slides not being available?
8 So, if you could, let -- make those slides 9 -- post those in the normal location and let people 10 know where they're at.
11 MR. HOWARD: Not a problem, Matt.
12 Normally we attach them to the transcript, but I can 13 get them out. It's not a problem at all. So, we'll 14 have them up for you. Matter of fact, I can send them 15 directly, too, if necessary.
16 CHAIRMAN SUNSERI: Yeah. We want to send 17 them at least to the individual requesting them.
18 MR. HOWARD: Not a problem.
19 CHAIRMAN SUNSERI: Okay. So, any other 20 discussion on that topic?
21 MS. HUCKABAY: This is Victoria Huckabay.
22 If you don't mind, I will just briefly respond to Mr.
23 Basso. So, I just checked and --
24 CHAIRMAN SUNSERI: Normally we don' 25 respond to public comments on that. They just make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 1 those comments and so we --
2 MS. HUCKABAY: Not a comment, no, just 3 about the availability of the slides. I wanted to 4 provide the ADAMS accession number.
5 CHAIRMAN SUNSERI: Oh, okay. Thank you 6 very much.
7 MS. HUCKABAY: Is that okay?
8 CHAIRMAN SUNSERI: Yeah. Yeah. Sure.
9 MS. HUCKABAY: Okay. So, the ADAMS 10 accession number for the slides is ML21180A017. And 11 I am checking this morning to make sure that it is 12 available for all members of the public through a 13 public web-based search on the NRC website.
14 And if there are any issues with that, 15 we'll be working to rectify it this afternoon.
16 MR. BASSO: Thank you.
17 MS. HUCKABAY: Okay. That's all. Thank 18 you.
19 CHAIRMAN SUNSERI: Alright. So, at this 20 point, we are finished with that topic and at this 21 time I'd like to take a 30-minute break now, our 22 formal break, and we will reconvene at 11:30 Eastern 23 Time and take up the Vogtle License Amendment Request.
24 So, at this time, we are in recess until 25 11:30. Thank you.
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68 1 (Whereupon, the above-entitled matter went 2 off the record at 10:58 a.m. and resumed at 11:30 3 a.m.)
4 CHAIRMAN SUNSERI: It is 11:30. I am 5 reconvening the meeting. I'd like to make sure that 6 we have a quorum for this portion, so I'll call the 7 roll.
8 Ron Ballinger?
9 MEMBER BALLINGER: Here.
10 CHAIRMAN SUNSERI: Vicki Bier?
11 MEMBER BIER: Here.
12 CHAIRMAN SUNSERI: Dennis Bley?
13 Charles Brown?
14 Vesna Dimitrijevic?
15 MEMBER DIMITRIJEVIC: Here.
16 CHAIRMAN SUNSERI: Greg Halnon?
17 MEMBER HALNON: I'm here, Matt.
18 CHAIRMAN SUNSERI: Walt Kirchner?
19 MEMBER KIRCHNER: Here.
20 CHAIRMAN SUNSERI: Jose March-Leuba?
21 MEMBER MARCH-LEUBA: Yes, sir.
22 CHAIRMAN SUNSERI: David Petti?
23 MEMBER PETTI: Here.
24 CHAIRMAN SUNSERI: Joy Rempe?
25 VICE CHAIRMAN REMPE: Here.
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69 1 CHAIRMAN SUNSERI: Pete Riccardella?
2 MEMBER RICCARDELLA: Here.
3 CHAIRMAN SUNSERI: And I'll come back to 4 Dennis Bley?
5 And Charles Brown?
6 Okay. So, we're missing Dennis and 7 Charlie, but we do have a quorum. So, we will proceed 8 with the next session.
9 This is on a Vogtle License Amendment 10 Request and I will hand it over to Joy Rempe to lead 11 this session. Joy?
12 VICE CHAIRMAN REMPE: Thank you, Mr.
13 Chairman. On May 19th, a joint subcommittee composed 14 of members from our Accident Analyses and Thermal 15 Hydraulics Subcommittee and our Reliability and 16 Probabilistic Risk Assessment Subcommittee met to 17 review the staff's draft safety evaluation for the 18 Southern Nuclear Operating Company License Amendment 19 Request related to risk-informed resolution of Generic 20 Safety Issue-191 for the Vogtle electric-generating 21 plants, Units 1 and 2.
22 At the end of our meeting, subcommittee 23 members concluded that this topic was ready for 24 presentation to the full committee. Members also 25 recommended that the full committee provide a letter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 1 on this topic.
2 Because subcommittee members believed the 3 applicant and staff provided quality presentations 4 that throughly covered the topic during our meeting, 5 and because most full committee members were present 6 during our subcommittee meeting, members also 7 recommended that the staff alone could provide an 8 abbreviated presentation today.
9 And before we start this discussion, I'd 10 again like to request that participants mute your 11 computer phone lines -- or your computer microphones 12 and phone lines and, at this time, I'd like to call on 13 Caroline Carusone to provide opening remarks for the 14 staff presentation. Caroline?
15 MS. CARUSONE: Thank you. Good afternoon.
16 As Dr. Rempe mentioned, my name is Caroline Carusone 17 and I'm the deputy director of the Division of 18 Operating Reactor Licensing in the Office of Nuclear 19 Reactor Regulation. I'd like to thank the ACRS 20 members again for the invitation to present here.
21 There are decades of history related to 22 Generic Safety Issue-191 and Generic Letter 2004-02.
23 We're going to go through a brief background in our 24 presentation.
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71 1 that the actions taken by licensees and the NRC have 2 reduced the risk of this issue significantly. The 3 remainder of my comments will focus on the plant-4 specific risk-informed review.
5 In September of 2019, the NRC issued a 6 staff evaluation of Vogtle's systematic risk-informed 7 assessment of debris technical report. This provided 8 the basis for us to consider use of the technical 9 report for Vogtle in future licensing applications.
10 The NRC staff concluded that the technical 11 report contained information to address the NRC 12 Generic Letter 2004-02, except downstream effects.
13 In August of 2020, Southern Nuclear 14 Operating Company submitted a License Amendment 15 Request and an exemption to revise their licensing 16 basis to allow the use of risk-informed approach to 17 address safety issues discussing GSI-191. This was 18 supplemented in December of 2020 and again in February 19 of 2021.
20 The proposed License Amendment Request 21 would also add a new technical specification action to 22 address the condition of a containment sump made 23 inoperable solely due to the loss-of-coolant-accident-24 generated debris exceeding the analyzed limits.
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72 1 certain requirements of 10 CFR 50.46, requirements 2 associated with the emergency core cooling system 3 following a postulated loss-of-coolant-accident.
4 This review is different from typical 5 reviews in that we already reviewed the majority of 6 the technical information in the September 2019 NRC 7 staff evaluation. In that evaluation, we identified 8 areas that still needed to be addressed.
9 The licensee's August 2020 License 10 Amendment Request included specific responses to the 11 open issues in addition to other licensing requests, 12 including the technical specification changes and 13 exemption.
14 The NRC staff welcomes the letter report 15 from ACRS and we look forward to your comments, 16 recommendations and thoughts related to this topic.
17 And with that, I'll turn it over to Steve Smith of the 18 Technical Specifications Branch in the Division of 19 Safety Systems in NRR.
20 MEMBER MARCH-LEUBA: Caroline, this is 21 Jose March-Leuba. Can I ask you a process question?
22 MS. CARUSONE: Sure.
23 MEMBER MARCH-LEUBA: Yeah.
24 MS. CARUSONE: Yes.
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73 1 when we ask for a Licensing Amendment Request, all 2 that is required is a safety evaluation report and the 3 LAR gets issued.
4 Whenever there is an exemption request, is 5 there a different process that you must follow to 6 approve it?
7 MS. CARUSONE: No, there's not a -- we 8 would also do the same. We would do a safety 9 evaluation and do that review as part of our decision.
10 MEMBER MARCH-LEUBA: So, there is no 11 Commission involvement or vote or something like that?
12 MS. CARUSONE: No.
13 MEMBER MARCH-LEUBA: Okay. Thank you.
14 MS. CARUSONE: I will just caveat to say, 15 you know, on specific topics -- topical areas that may 16 be of interest, we would, of course, do our due 17 diligence to inform appropriate parties if we saw 18 anything sort of atypical outside of what typical 19 staff review would be appropriate.
20 MEMBER MARCH-LEUBA: But basically the 21 staff has the authority to issue exemptions to the 22 rule?
23 MS. CARUSONE: Yes.
24 MEMBER MARCH-LEUBA: That's what you're 25 telling me?
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74 1 MS. CARUSONE: Yes.
2 MEMBER MARCH-LEUBA: Okay. Thank you.
3 MS. CARUSONE: Sure.
4 MR. SMITH: Okay. Good morning. Just let 5 me know that you can hear before I start rolling on 6 here.
7 MS. CARUSONE: We can hear you, Steve.
8 VICE CHAIRMAN REMPE: Yeah, but it's very 9 low. Could you turn your volume up or get a little 10 closer to your mic?
11 MR. SMITH: I can try to do that.
12 Is that better?
13 VICE CHAIRMAN REMPE: Yes, it is. Thank 14 you.
15 MR. SMITH: Okay. Alright. Thanks for 16 getting me straightened out there. The staff is 17 looking forward to presenting this topic and receiving 18 feedback from the ACRS. I think we had a good 19 conversation in May and we appreciated the feedback we 20 got then.
21 I just wanted to emphasize today that this 22 issue has been touched by a lot of the NRC staff, 23 including people at NRR, Research, ACRS and in the 24 regions, and the input from all of these groups is 25 considered in our Generic Letter 2004-02 reviews, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 including the Vogtle review.
2 During the presentation, I'm going to try 3 to emphasize the important history and lessons learned 4 for this topic. As Dr. Rempe noted, we discussed 5 this pretty thoroughly in May. So, some slides I'll 6 spend more time on and some slides a little bit less.
7 I'm ready for Slide 2. Alright. Thanks, 8 Andrea. Key messages. It looks like -- I can only 9 see part of that slide. Okay. There we go. Okay.
10 Thank you.
11 The phenomena associated with the effects 12 of debris on long-term core cooling have been well-13 studied since the issue was originally identified in 14 the '90s and plants using the risk-informed methods to 15 resolve the debris issues are those that are most 16 challenged by debris.
17 And the evaluations that were performed by 18 those plants demonstrate that the actions taken have 19 significantly reduced the risk associated with the 20 GSI-191 phenomena.
21 I'm ready for Slide 3. Okay. This slide 22 shows the actions completed at the plants -- the major 23 actions taken, anyway.
24 All plants -- all PWRs install advance 25 design strainers and implemented administrative NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 controls to manage the debris sources in containment.
2 A lot of the plants took additional 3 actions to reduce the potential impacts of debris on 4 recirculation. For example, some plants reduced 5 problematic insulation types, some improved their 6 post-LOCA chemistry to reduce chemical precipitates, 7 and most plants -- probably all plants actually added 8 monitoring and mitigative actions to their emergency 9 operating procedures.
10 And the little photo on the lower right 11 shows -- that shows one of the original strainers, 12 which is actually probably a pretty good one, and the 13 larger strainer that's, you know, on top of that inset 14 -- or kind of under that inset shows the new larger, 15 more complex geometry strainer installed.
16 I'm ready for the next slide. Slide 4.
17 Slide 4 just shows some examples of the physical 18 testing that was done. This shows the -- the upper 19 left photo is fuel assembly testing for blockage at 20 Westinghouse.
21 The one to the right of that is testing at 22 Alden Labs. It's a strainer test. Texas A&M 23 University on the lower left, that was some boric acid 24 precipitation testing that was done.
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77 1 was quite a bit of chemical effects testing done and 2 this just shows some vertical loops where they were 3 running similar, but, you know, they did variations.
4 So, they had three running in parallel so they could 5 see how changing things would affect chemical effects, 6 how they changed head loss.
7 Anyway, the physical testing that was 8 done, there were hundreds of lab tests conducted 9 related to debris generation, debris transport, 10 chemical effects and debris bed head loss on strainers 11 and fuel assemblies.
12 The tests were conducted by fuel vendors, 13 engineering firms, labs and universities, and the 14 results of the test program were used to develop NRC 15 and industry guidance and evaluate how specific plant 16 designs will perform under postulated LOCA conditions.
17 And this just showed -- this slide -- we 18 went through what this slide shows, so I'm ready for 19 the next slide. No. 5.
20 Slide 5 discusses computer modeling that 21 was done and computer modeling was early -- in the 22 early days, it was used for modeling recirculation 23 flows using CFD.
24 More recently, this shows some of the more 25 recent computer modeling that was done and it was --
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78 1 these were used to evaluate boric acid precipitation 2 and thermal hydraulic performance in the core and in 3 the alternate ECCS flow paths.
4 Most of the modeling was performed to 5 evaluate the potential effects of debris blockage in 6 the core, and industry analysis was performed for each 7 reactor design, and NRC did confirmatory analysis 8 using TRACE to provide assurance that the industry 9 work was acceptable. And this is the more recent work 10 we've done on in-vessel.
11 Slide 6. This slide is one that was taken 12 from the Vogtle -- actually, this slide and the next 13 one are ones that were taken from the Vogtle 14 presentation that was presented in the May 15 subcommittee meeting.
16 And the staff agrees that these provide a 17 good perspective and a good history for this issue and 18 a good perspective on how the Vogtle license amendment 19 request fits into this.
20 So, I'm going to talk for a while on this.
21 If anything comes up, you know, there's a question, 22 please interrupt me and I will try to answer 23 questions.
24 MEMBER KIRCHNER: Steve, this is Walt 25 Kirchner.
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79 1 MR. SMITH: Yes.
2 MEMBER KIRCHNER: On the previous slide, 3 what methods were used for computation of fluid 4 dynamics to look at the boron precipitation problem?
5 Was that fluent or what --
6 MR. SMITH: We used -- actually, we didn't 7 use CFD and it wasn't me. I don't want to imply that 8 I was doing this work, but they -- actually, Research 9 used a modified version of TRACE to evaluate boric 10 acid precipitation.
11 MEMBER KIRCHNER: Yeah, I remember that.
12 Okay. That's not a CFD code in the normal sense, it's 13 a --
14 MR. SMITH: No.
15 MEMBER KIRCHNER: Okay.
16 MR. SMITH: I didn't mean to imply CFD --
17 the thermal hydraulic codes -- mostly for that slide, 18 those were thermal hydraulic codes we're looking at.
19 The CFD has been used for years and years 20 to evaluate the recirculation flows in the pools, you 21 know, something that's quite a bit probably simpler 22 than trying to model, you know, how boric acid is 23 going to build up in different regions of the core.
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80 1 recirculation.
2 MEMBER KIRCHNER: Thank you.
3 MR. SMITH: Okay. So, this is the time 4 line slide we're on. I'll just start at the 5 beginning.
6 GSI-191 was initiated in the '90s to study 7 the potential for debris to affect recirculation.
8 After a lot of study, the NRC issued Generic Letter 9 2004-02 in 2004 and, as you can see here, industry had 10 already been working on the issue and issued NEI 0407, 11 which is a major guidance document for the PWRs.
12 It was actually issued before the Generic 13 Letter was issued, so there was a lot of industry work 14 going on in parallel with the NRC work.
15 In 2005, plants submitted their initial 16 responses to the Generic Letter. And in between 2005 17 and 2009 there was a lot of interaction between 18 licensees, vendors and the NRC regarding adequacy of 19 the methods used to evaluate the associated phenomena 20 and the adequacy of the plant responses.
21 And there's still -- it kind of -- the 22 interactions kind of died down after that time, but we 23 still go back and forth a little bit. The guidance is 24 much better now and we are definitely making a lot of 25 progress in closing those things out.
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81 1 Okay. At the time of the issuance of the 2 Generic Letter, the PWR ECCS strainers were small and 3 had relatively large holes like the one we saw a 4 couple slides ago, and it was likely that these would 5 either let a lot of debris through or get blocked by 6 debris or both.
7 I thought somebody was asking -- I guess 8 maybe just somebody might need to mute. Anyway, the 9 old strainers were either likely to let a lot of 10 debris through, bypass or penetrate or clog or both.
11 The design basis assumption for most of 12 the plants was just that 50 percent of the strainer 13 would be blocked. It wasn't a realistic assumption.
14 And as long as the remaining 50 percent could allow 15 adequate flow, the system was assumed to work.
16 As we know now, the old strainers at most 17 plants would have likely been blocked with debris had 18 a large LOCA occurred.
19 Between 2004 and 2008 a lot of work was 20 done to quantify the potential for chemical effects 21 and provide guidance for modeling the plant 22 evaluations. Chemical effects were not identified by 23 GSI-191, but were postulated later.
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82 1 that could occur, could have a very large effect on 2 head loss.
3 In 2008, the NRC staff, you know, based on 4 all the stuff we just talked about, the study and the 5 testing that was done, we issued a significant amount 6 of guidance to provide an accepted basis for the 7 evaluations of most areas associated. The only thing 8 that we really didn't cover at that time was in-vessel 9 effects.
10 In 2008, another important thing to happen 11 was NUREG-1829 was issued and that's important because 12 it established a basis for the prediction of break 13 frequency, which underlies justification for the risk-14 informed evaluations.
15 And then to reduce plant risk in this time 16 frame, plants performed -- you know, we talked about 17 this earlier. They installed and tested new complex 18 geometry strainers and tests showed that these 19 strainers were effective at reducing head loss 20 compared to the vertical loop testing that was done.
21 They implemented the administrative 22 controls to manage debris and containment and some 23 plants performed modifications to reduce debris 24 sources.
25 In 2010, there was an SRM for SECY 10-0013 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 issued and that stated that time should be allowed to 2 perform testing necessary to understand in-vessel 3 effects and, at that time, industry was also doing 4 testing on -- steam or two-phase jet testing to try to 5 reduce zones of influence for insulation.
6 That testing didn't really pan out. They 7 weren't able to show that large reductions would occur 8 for most of the materials. They did show that some 9 modifications like adding fans and putting double --
10 I guess, double jacketing around some systems would 11 reduce the zone of influence.
12 So, it was used by a few people, but not 13 many people went in and did those kind of 14 modifications.
15 The main thing that we worked on was the 16 in-vessel effects and basically the Commission told us 17 that we should take the time needed to let this 18 testing be done, consider a risk-informed safety 19 conscious resolution to GSI-191, and the SRM also 20 stated that measures taken to date ensure that 21 adequate defense-in-depth is being maintained.
22 So, that basically told us, you know, that 23 the plants had adequate defense-in-depth and we should 24 study this before we might try to make them do things 25 to close the issue out.
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84 1 And then in 2012, another SRM was issued 2 that allowed plants to select one of three options, 3 which we discussed in May. And I have a slide on 4 this. Like, after we get through the next time line 5 slide, we'll go over those options quickly.
6 And one of the options did include -- or 7 actually two of them included risk-informed 8 methodology. No one actually selected Option 3, which 9 was one of the risk-informed ones.
10 So, that SRM also reemphasized that 11 adequate defense-in-depth was being maintained due to 12 the actions taken by licensees to date.
13 STP, which was the risk-informed pilot 14 plant, submitted its initial LAR in 2013. There were 15 significant interactions with ACRS regarding the STP 16 methodologies and, in 2013, the first in-vessel 17 guidance for low-fiber plants was also approved by the 18 NRC.
19 In 2014, STP changed its methodology to 20 the RoverD method, which we'll -- we did review in 21 May, but we'll go over that quickly later today, what 22 the RoverD method is.
23 I'm ready for -- I'm up to Slide 7 on the 24 time line. Okay. In 2013, STP submitted an updated 25 LAR based on RoverD. This was ultimately approved by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 the NRC in 2017.
2 Prior to the issuance of the STP 3 amendment, Vogtle submitted its technical report for 4 NRC review and the NRC staff conducted two audits of 5 the NARWHAL and BADGER software used by Vogtle and 6 their risk-informed analysis.
7 In 2018, Vogtle submitted an updated 8 technical report and this report was approved by a 9 staff evaluation that contained limitations and 10 conditions.
11 Also during this time period the PWR 12 Owners Group submitted an updated in-vessel 13 methodology that was intended to use plant-specific 14 inputs and parameters to allow the calculation of 15 higher allowable in-vessel debris amounts.
16 The staff never approved that topical 17 report, but along with the work that was done for that 18 report and significant NRC confirmatory work, we 19 determined -- we used that to provide a good basis for 20 the NRC staff guidance. And we discussed that 21 guidance in the May meeting and Vogtle used that 22 guidance for their closeout.
23 That was one of the limitations and 24 conditions was that they had to address in-vessel 25 effects, so they did use that guidance in their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 closure.
2 In 2020, Vogtle submitted its LAR that 3 contained most of the regulatory information, which we 4 talked a little earlier, the licensing information, 5 the exemption, the tech spec changes, and it also 6 responded to the technical issues that were identified 7 and that did include the evaluation of the in-vessel 8 effects.
9 And the staff review of the LAR is 10 completed at this point, and that was a lot of 11 talking. So, I'm just going to take a pause and see 12 if there's any questions before we move on to Slide 8.
13 VICE CHAIRMAN REMPE: I don't have any 14 questions. It was a good history. I appreciate you 15 going through it.
16 MR. SMITH: Alright. Thank you. Alright, 17 we're ready for Slide 8, Andrea. This is the slide 18 that I talked about during the time line.
19 This gives us the overall status of 20 compliance and it gives the three options that were 21 presented in the SRM that were approved by the 22 Commission in its SRM 12-0093.
23 Option 1 was the lower fiber plants. 19 24 of those units have closed out.
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87 1 performance of additional testing and analysis and 2 included the risk-informed resolution, which Vogtle 3 was following.
4 And we think there's going to be 34 units 5 to just use a deterministic resolution, and eight 6 units, including STP, that are going to use risk-7 informed methods to close the Generic Letter.
8 And Option 3 was to treat strainer 9 deterministically and in-vessel using risk analysis, 10 and no one selected this because the strainer is the 11 -- seems to be the long pole in the tent. It's harder 12 to evaluate the strainer. But most plants can use the 13 new in-vessel guidance to show that they won't have 14 issues with debris in the vessel.
15 I think the other thing I will say is that 16 we are getting close to closing out some of these 2a 17 deterministic plants. We have drafted letters for the 18 ones that have provided information for us and, I 19 think, in the near future we'll be getting some 20 letters out to some of those plants.
21 Slide 9. This slide just shows a pretty 22 simple overview of what the RoverD methodology or the 23 RoverD concept is. Basically the scenarios that meet 24 all the deterministic requirements and do not -- they 25 don't contribute to change in risk. So, those would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 be in the blue box on the bottom.
2 And then any scenario that fails any 3 deterministic criteria, they're assumed to contribute 4 to the change in risk caused by debris during 5 recirculation. So, that's where you get risk over 6 determination.
7 The risk is the top brown box and the 8 deterministically acceptable scenarios is the bottom 9 box and most of the scenarios go into the blue box on 10 the bottom.
11 Slide 10. This just gives an overview of 12 how the staff evaluated the Vogtle submittal. This 13 was discussed in more detail in the May subcommittee 14 meeting. I'll just wait for a minute and let you see 15 if you have any questions on that. We will go into a 16 little detail on a couple of these areas in the next 17 couple slides.
18 (Pause.)
19 MR. SMITH: Okay. I think we can move to 20 Slide 11. This just shows the five key principles of 21 risk-informed regulation that provide the basis for 22 the staff decision.
23 As I said before, a lot of technical 24 branches contributed to this review especially in the 25 area of Principle 4, which is the increase in risk NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 would be small. So, that has a lot of deterministic 2 and risk review associated with it.
3 I thought I heard somebody trying to ask 4 a question, maybe. Okay. An evaluation of all five 5 principles is used to complete the integrated 6 decision-making process. So, the licensee has to show 7 that all these principles are met.
8 Alright. We're up to Slide 12. This is 9 just a -- I only brought one of these from the May --
10 we had two in the May presentation, but they both show 11 similar things.
12 This is a graphic illustration of why the 13 risk-informed evaluations are able to demonstrate very 14 low risk. The graph shows the amounts of fiber that 15 can be generated by a double-ending guillotine break 16 in their RCS. The maximum average and minimum for 17 each size range are shown.
18 So, just for example, for the main loop, 19 the big piping welds, the most that can be generated 20 by a double-ended guillotine break is over 2200 cubic 21 feet or -- yeah, cubic feet. I forgot if it was cubic 22 feet or pounds, but it is cubic feet.
23 And the minimum would be about just under 24 300 cubic feet with the average being around 1200, so 25 that's only the very biggest welds generate that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 amount.
2 The other thing to think about here is 3 even if a break does generate a very large amount of 4 fiber, the amounts are significantly decreased during 5 transport.
6 The large and intact pieces of fiber won't 7 transport, some small fiber won't transport, and the 8 remaining amount of fiber is split between whatever 9 strainers are operating at the time. So, only a very 10 large base can generate enough debris to cause a 11 strainer failure.
12 There were fewer large welds than small 13 welds and this was -- this was very similar -- we saw 14 a very similar trend with the STP fibrous debris 15 generation amounts, you know, as far as, you know, as 16 soon as you made the welds somewhat smaller, any 17 branch connection just didn't generate nearly as much 18 as these very large welds and, just from the Vogtle 19 analysis, most 20-inch break scenarios would not 20 result in a failure due to fibrous debris limits.
21 So, when you get down to 20-inch breaks, 22 which would be a partial break on a main loop because 23 there's no 20-inch branch lines, I guess, the -- you 24 would -- most of those breaks would not cause an 25 issue.
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91 1 So, very few -- very few welds are 2 susceptible to generating enough debris to cause a 3 failure of the scenario.
4 Then slide 13. This is a high-level look 5 at the Vogtle overall risk from the issue. This shows 6 that they did identify some breaks contribute to risk 7 due to strainer failures, due to in-vessel there were 8 no breaks that contributed to risk, and this just 9 shows their overall risk numbers that are very low.
10 Okay. Slide 14. This is more of a 11 graphical view. This demonstrates where the Vogtle 12 risk lies with respect to the guidance in Reg Guide 13 1.174.
14 The red star shows Vogtle's baseline 15 change in core damage frequency attributed to debris, 16 and then the blue star shows the maximum value of all 17 the staff's confirmatory calculations.
18 And although that was in Region 2, there 19 was a significant amount -- slightly into Region 2, 20 there was a significant amount of conservatism with 21 that particular calculation the staff did. So, we are 22 confident that the Vogtle risk is in Region 3.
23 Slide 15 is a summary of the Vogtle review 24 and the staff conclusions. And I think we've been 25 through this, but just quickly they acceptedly -- they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 acceptedly evaluated the impact of debris. They used 2 the RoverD methodology.
3 Most break scenarios do not contribute to 4 risk. The in-vessel evaluation methods are 5 conservative and all those scenarios meet the 6 deterministic acceptance criteria.
7 And their analyses and their evaluations 8 meet the key principles, all five key principles, of 9 the risk-informed regulations and the change in risk 10 is very small.
11 Slide 16 is a little bit more general.
12 This isn't focused on Vogtle, but this discusses the 13 important lessons learned from the risk-informed 14 evaluations.
15 The first bullet provides the context in 16 that the plants using the risk-informed methods are 17 the most challenged PWRs because they have large 18 amounts of fibrous debris.
19 The analysis performed for Vogtle and STP, 20 which are two of the very high-fiber plants, 21 demonstrate that the actions taken to date have 22 significantly reduced the risks associated with debris 23 and ECCS for circulation.
24 In addition to showing that risk has been 25 reduced, the Vogtle and STP methods have provided an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 1 increase in safety by eliminating significant amounts 2 of personnel dose that would have been required to 3 remove the fibrous insulation and replace it with 4 probably reflective metal insulation, and those are 5 the big technical lessons learned from this issue.
6 And that completes the staff's 7 presentation and I'd be glad to take any questions.
8 VICE CHAIRMAN REMPE: Thank you. From my 9 perspective, you hit the key points I wanted you to 10 hit today. So, I appreciate you providing such a 11 great summary.
12 Members, do you have any other questions 13 or comments? I think, again, the great job that you 14 did during the subcommittee meeting is why you're not 15 getting a lot of questions from the members.
16 At this time, I think we need to open the 17 line for public comment, right, Matt?
18 CHAIRMAN SUNSERI: That's correct.
19 MR. DASHIELL: The public line is open for 20 comments.
21 VICE CHAIRMAN REMPE: Great. So, are 22 there any members of the public who would like to 23 provide a comment? And if so, please state your name 24 first before providing that comment.
25 (Pause.)
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94 1 VICE CHAIRMAN REMPE: I think we've given 2 folks out there an adequate opportunity and there are 3 no comments, so let's close up the public line.
4 And then, Matt, I guess I should turn it 5 over to you because, if you wish, we do have a draft 6 letter ready for consideration by the full committee.
7 CHAIRMAN SUNSERI: Alright. Well, thank 8 you, Joy. That was a good session. I would suggest 9 that we move right into review of the draft letter.
10 We can at least get it read into the 11 record before lunch and then there's some time after 12 lunch that we can work on it.
13 So, if the staff is ready to pull the 14 letter up and display it for us and if you are ready 15 to walk us through that, Joy, that would be good.
16 (Whereupon, the above-entitled matter went 17 off the record at 12:05 p.m. and resumed at 3:00 p.m.)
18 CHAIRMAN SUNSERI: Alright. Welcome back.
19 This is Matt Sunseri. We will reconvene the meeting.
20 The next topic on our agenda is Reg Guide 1.9, Rev. 5, 21 Application and Testing of Onsite Emergency 22 Alternating Current Power Supplies in Nuclear Power 23 Plants.
24 Charlie Brown -- Member Brown will be 25 leading us on this discussion. At this point, I'll NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 1 turn it over to Charlie.
2 MEMBER BROWN: Okay. Thank you very much, 3 Matt. Chris Cook, are you on the line?
4 MR. COOK: Yes, I am.
5 MEMBER BROWN: And I presume you are going 6 to do our opening remarks and Liliana is going to do 7 the presenting or am I wrong?
8 MR. COOK: You're absolutely correct.
9 That's how we'd like to proceed.
10 MEMBER BROWN: Okay. Do you have any 11 opening remarks you would like to make?
12 MR. COOK: I do. Should I begin?
13 MEMBER BROWN: Yes, sir. Take it away.
14 MR. COOK: You bet. Thank you. Well, 15 good afternoon, everyone. My name is Chris Cook and 16 I'm the branch chief of the Instrumentation, Controls 17 and Electrical Engineering Branch in the Office of 18 Research, Division of Engineering.
19 Thank you for the opportunity to provide 20 introductory remarks to help frame the purpose and 21 need for updating Reg. Guide 1.9.
22 Although GDC 17 and 18 discuss both onsite 23 and offsite power, the scope of this reg guide is 24 limited to only the onsite AC power sources.
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96 1 to endorse two IEEE standards, which we understand are 2 a high priority for use by IEEE standard committee 3 members and the industry.
4 Specifically, these are the updated 5 version of IEEE 387 on emergency diesel generators, 6 and the new IEEE 2420 on combustion turbine 7 generators.
8 Although it's only been a short time since 9 the team presented to the ACRS subcommittee, the team 10 has worked intensely on the material that they're 11 going to present to you today.
12 First, in the subcommittee meeting you 13 heard comments from NEI regarding their issue with 14 staff's use of a 30-day mission time.
15 Following the subcommittee meeting, the 16 staff revised that language in the Background section 17 of the reg guide.
18 Just yesterday, we took that revised 19 language to the CRGR and I'm happy to report that the 20 CRGR has no concerns with the revised language and 21 today's presentation will cover the revisions that 22 took place since the subcommittee meeting.
23 Second, I wanted to let you know that the 24 team fought very hard about the subcommittee's 25 comments regarding the approach staff took in Section NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 1 C(1) for technology-neutral power sources.
2 We have prepared several slides to discuss 3 our approach and explain how we continue to see that 4 section as one acceptable way to meet the regulation.
5 This section approaches the foundational 6 regulatory requirements by identifying the necessary 7 regulations and by referencing the applicable reg 8 guides in the various subsections.
9 For example, the appropriate seismic 10 qualifications for onsite power sources are specified 11 by referring to Reg Guide 1.100.
12 I also wanted to emphasize that staff are 13 open to considering future industry standards as 14 guidance for technology-specific power source 15 applications just like we did for EDGs and CTGs.
16 However, until those standards are 17 available, we think that Section C(1) highlights the 18 regulatory framework and provides a useful foundation 19 for identifying the necessary considerations.
20 So, with that as a short introduction, I 21 now turn the floor over to Lili Ramadan to make her 22 presentation.
23 MEMBER BROWN: Thank you, Chris.
24 MS. RAMADAN: Good afternoon. Today's 25 agenda we will be introducing the reason for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 1 revision to this regulatory guide.
2 We will be discussing existing guidance.
3 We will be pointing out the significant changes, the 4 proposed new guidance and going over public comments 5 and resolutions. Not all of them, but just a sample 6 of them.
7 Next slide. The current NRC guidance in 8 Regulatory 1.9 has not been updated since 2007. It 9 does not reflect all the possible types of different 10 onsite emergency power sources.
11 The main drivers for this update, as Chris 12 stated, is to endorse IEEE standard -- IEEE 387-2017 13 and the new IEEE standard 2420-2019, and introduce a 14 technology-neutral guidance to include other types of 15 emergency power sources for the onsite alternative 16 current electric power system.
17 This technology-neutral approach provides 18 a consistent regulation in an innovative and 19 transformative manner to demonstrate NRC's value of 20 openness to allow for efficiency and the review of new 21 technology applications.
22 This guidance also ensures that the 23 applicant and the staff are aligned regarding the 24 review criteria needed for all possible types of 25 different onsite emergency power sources and lays the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 1 foundational groundwork for the alternative power 2 supplies other than EDGs and CTGs.
3 Next slide. The current version of Reg 4 Guide 1.9, Revision 4, covers only the diesel 5 generator technology and endorses, with exceptions, 6 the 1995 version standard of IEEE 387.
7 Reg Guide 1.9 provides one method that the 8 staff finds acceptable from meeting the requirement of 9 onsite standby emergency AC power supply in accordance 10 with 10 CFR, Appendix A, General Design Criteria, GDC, 11 17 and 18.
12 Next slide. This Revision 5 endorses the 13 updated version of IEEE Standard 387 on EDGs where 14 emergency diesel generators are widely used as standby 15 emergency power sources for the onsite alternating 16 current power system.
17 Many of the testing and design 18 requirements from Revision 4 were removed since they 19 were incorporated in the IEEE standard 387-2017.
20 Next slide. This Revision 5 endorses the 21 new IEEE 2420 on CTGs where the use of emergency gas 22 turbine generator system is used to supply the standby 23 emergency AC power system.
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100 1 using gas turbine-driven standby emergency alternating 2 current power system. It provides the guidance needed 3 to ensure it is consistent with the intent of 10 CFR 4 Part 50 and Part 52.
5 Next slide. The proposed new guidance and 6 staff considerations and positions can be found in 7 Section C of the draft reg guide. We will refer to 8 C(1) as a section that addresses the new technology-9 neutral power sources.
10 C(2), we will refer to C(2) as a section 11 that addresses the EDGs as the power source, and we 12 will address C(3) as the section that addresses CTGs 13 as the power source.
14 C(1) provides the foundational groundwork 15 for other alternatives for onsite standby emergency 16 power sources other than EDGs and CTGs that meet the 17 intent of 10 CFR Part 50 and 10 CFR Part 52 18 requirements. The basis stems from meeting the 19 criterion 17 and 18.
20 C(1) provides a reasonable assurance that 21 the Class 1E power system can perform its intended 22 function to provide secure and reliable power whether 23 it be from a nuclear power plant, a facility, a small 24 modular reactor or advance reactors.
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101 1 technologies, but it ascertains the availability and 2 capability of the power sources treated in accordance 3 with Part 50 and Part 52 requirements.
4 In C(1), there are unique considerations 5 with each technology, but, again, those will be 6 evaluated at the time of application as is currently 7 laid out in C(1).
8 This just provides a current guidance to 9 ensure that the applicant and the staff are aligned 10 regarding the review criteria meeting the foundational 11 requirements through the referencing of applicable reg 12 guides in the various subsections of C(1).
13 MEMBER BROWN: Liliana?
14 MS. RAMADAN: Yes.
15 MEMBER BROWN: Granted that your comment 16 about the alternative power sources will have their 17 own unique characteristics and such, which will have 18 to be evaluated relative to the criteria you have 19 provided --
20 MS. RAMADAN: Correct.
21 MEMBER BROWN: -- however, there are also 22 a large number of plant application considerations 23 that it doesn't matter which alternative power source 24 you choose, you're going to have to -- it would have 25 to be addressed and those aren't identified at all.
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102 1 So, I mean, that's a little bit of a 2 difficulty in terms of saying that, you know, we can 3 just leave that open and hope somebody figures it all 4 out when they get there. It's a similar comment to 5 what I made in the subcommittee meeting.
6 I really didn't have a disagreement with 7 the fact that the new technologies, whether they be 8 solar, wind turbines, fuel cells, whatever somebody 9 comes up with, have their own unique characteristics, 10 they still have to interface with the plant.
11 The plant will look -- no matter what 12 plant we have, they will look like plants we have 13 today in terms of the functionality and there will be 14 pumps, motors, instrumentation, all kinds of other 15 goodies that require AC power just as it exists today 16 and you have to parallel and operate that new system 17 with those existing plants.
18 So, if you look at the existing CTG and 19 the EDG, sections 1 through 7, I believe, pretty much 20 everything in there describes the type of stuff that 21 interfaces with the plant.
22 All those new systems will undoubtedly 23 require cooling systems, so there's -- the only thing 24 unique is -- in a couple of cases is the fuel cell's 25 kind of unique, but it's still going to have to have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 1 some other type of interface to connect it to the 2 plant.
3 And those requirements to have that fuel 4 cell or solar system or wind turbine respond are not 5 contained in anything that's in the existing guidance 6 C(1) as you all have provided.
7 So, that's similar to the comment I made 8 earlier. I just wanted to make sure I was clear 9 relative to those particular thought processes. Okay?
10 MS. RAMADAN: Understood. It's a valid 11 concern, but, as we stated, and as we're trying to lay 12 the approach here in C(1), it's just an initial 13 groundwork -- foundational groundwork that states 14 these are the sections and the acceptance criteria 15 that we are looking for for whatever technology that 16 comes in these -- this is the -- just in alignment 17 between the applicant and the staff.
18 MEMBER BROWN: So, the ability to stop and 19 start this, to take heavy demand loads, to shed heavy 20 loads, and in order to parallel the existing plants 21 aren't even covered in the new capabilities you have 22 brought up that are listed in C(1). Not right now.
23 MS. RAMADAN: Not right now.
24 MEMBER BROWN: There's a number of other 25 ones as well. These new systems -- existing systems, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 1 the wire and iron generators, have a certain 2 characteristic set of harmonics.
3 None of the new systems that would even be 4 thought about these days require a lot of power 5 electronics, which generate their own characteristic 6 harmonics and we know it, but yet we don't say 7 anything.
8 So, I'm just mentioning that. I'm not 9 going to slow you down in your slide presentation. I 10 just wanted to let you know that that's what I've been 11 thinking. Okay?
12 MS. RAMADAN: Thank you.
13 MEMBER BROWN: Oh, yes, sir -- excuse me, 14 yes, ma'am.
15 (Laughter.)
16 MS. RAMADAN: That's okay.
17 MEMBER BROWN: Go ahead.
18 MS. RAMADAN: And C(2) and C(3) provide 19 the new and improved design and testing considerations 20 for EDGs and CTGs.
21 Next slide. As stated before, this 22 revision introduces a new technology-neutral concept 23 whereby C(1) again highlights the necessary regulation 24 framework to allow for the review of alternate onsite 25 power sources.
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105 1 C(2) highlights the most updated EDG 2 guidelines.
3 C(3) highlights the most updated CTG 4 guidelines.
5 This revision is the result of lessons 6 learned from license amendment review activities and 7 inspections, industry operating experience reviews, 8 design certification reviews, COL application reviews 9 and NRC staff analysis.
10 Next slide. Some of the --
11 MEMBER KIRCHNER: If I could, Liliana --
12 this is Walt Kirchner -- I would just concur with 13 Charlie in that functionally when -- you're opening 14 the door to alternate power sources, that's fine, but 15 functionally, at some point, you've got to parallel 16 them with the onsite AC power systems emergency 17 especially those buses that, you know, typically 18 they're providing a safety-related function in terms 19 of power.
20 That same functionality is required 21 whether it's a diesel generator or a combustion 22 turbine generator or de facto what you're saying is 23 we're allowing for an alternate offsite power source.
24 Not the normal offsite power source that 25 you assume is lost, but an alternate power source, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1 you still, from the AC power conditioning and load 2 acceptance, still have to functionally do the same 3 thing you do for a diesel-driven generator or gas 4 turbine generator.
5 So, I just concur with Charlie. It's 6 underdeveloped in -- it opens the door, but it doesn't 7 provide the kind of -- how should I say it -- level of 8 assurance that's required of the diesel generator or 9 the gas turbine alternative.
10 MS. RAMADAN: I appreciate the comment and 11 we agree it opens the door. And because we are 12 introducing a technology-neutral concept here, that's 13 the reason why it's very initial in its guidance and 14 it's just laying the framework, foundational 15 groundwork. As stated, it's just opening up the door.
16 When we receive that application, whatever 17 it is, and it falls into C(1), that's when we can get 18 into the nitty-gritty, so to speak.
19 MEMBER KIRCHNER: Yeah, but then you would 20 be arguing with people about what the level of the 21 nitty-gritty is necessary whereas if it was specified 22 before to be similar to what the diesels and the 23 combustion turbine generators have to meet or 24 interface with or how to prove their reliability, it's 25 just going to be a big food fight. That's one of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 1 difficulties (audio interference).
2 Did we lose something?
3 MEMBER BALLINGER: I think the aliens have 4 arrived.
5 MEMBER BLEY: You created a bit of 6 feedback, Charlie.
7 MEMBER BROWN: Did we lose the staff?
8 MR. COOK: No, I'm still here, Member 9 Brown. This is Chris Cook.
10 MR. MILLER: Kenn Miller. I'm still here.
11 MEMBER BROWN: The pictures are gone.
12 That's why I ask. Is Liliana still there?
13 MS. RAMADAN: I am.
14 MEMBER BROWN: Oh, okay. We got it back.
15 I'm sorry, I have no idea what caused that. It was 16 not me.
17 MR. COOK: It wasn't me either, sir, but, 18 I mean -- so, this is Chris Cook of the staff. I 19 mean, so a lot of what we were trying to do was in 20 C(1), is to go through and not be technology-specific, 21 as we've been saying, and to then point to the 22 specific regulatory guidance that would be there 23 should someone want to use an alternate technology 24 that we've had and you've understood that.
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108 1 best to, you know, what we were thinking was this was 2 a good way to start to get that sort of rubric out 3 there that people then could use to go forward on 4 that, lists all the different requirements as these 5 things come in that are unknown at this time.
6 MEMBER BROWN: Chris, if you look at the 7 EDGs and CTGs, the requirements 1 through 7, 8 definitions, the mechanical and electrical 9 characteristics, they are totally technology-neutral.
10 They only -- they are not design or technology-11 specific at all. That's why -- I mean, paralleling is 12 not technology-specific. You have to be able to do 13 that. There's nothing in there for that.
14 Accepting and rejecting large loads is not 15 technology-specific. There's nothing in C(1) for 16 that.
17 The starts and stops that it can endure 18 over some period of time is not in there. That's not 19 technology-specific at all.
20 The voltage in harmonic, the voltage drops 21 and everything else, which are not technology-specific 22 because the plant can't stand too big of changes, are 23 not in there at all.
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109 1 like the type of fuel and how you have to store it, 2 heat it, open the valves, feed it in or whatever, 3 that's technology-specific, but that's not -- those 4 you wouldn't include, but about 80 percent or 70 5 percent or whatever I could come up with as I went 6 through the EDG spec line by line and most should be 7 incorporated in C(1) because they're not technology-8 specific.
9 Anyway, that was -- I understand your 10 point, it's just that we've left out too much.
11 MEMBER BLEY: Charlie?
12 MEMBER BROWN: Yeah, Dennis.
13 MEMBER BLEY: Yeah. And I apologize to 14 the staff. I was not able to attend the subcommittee 15 meeting, but, in general, I agree with Charlie and, 16 you know, ways around this kind of problem could be 17 the things Charlie is talking about because there are 18 quite a few things that will have to apply to whatever 19 source that says there are also -- for many of these 20 there's going to be the issue of storage versus 21 production and how you deal with that.
22 It seems to me you need not only the kind 23 of things Charlie is talking about, but you need an 24 acknowledgment in this section that it's -- if not 25 early in development, something like that that says NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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110 1 there are details that are going to have to be 2 developed and fared out to -- essentially to the level 3 of the guidance that exists for turbine generators.
4 MEMBER BROWN: Dennis is --
5 MEMBER KIRCHNER: Dennis, this is Walt.
6 I'm just -- I'll agree with you and I'll just -- I 7 should have done this, and I apologize to the staff, 8 because I thought about it after the subcommittee 9 meeting.
10 Let's take the intermittent sources off 11 the table for the moment because that has some of the 12 complexities that Dennis just mentioned, how you store 13 the energy, et cetera, so that you have a reliable 14 source when you need it, but let's pick on something 15 like fuel cell technology.
16 Fuel cells take a while to start up and, 17 et cetera, et cetera. So, and then you've got to 18 convert essentially a DC power source into an AC --
19 there are a number of options to do that, but -- and 20 I won't try and solve them here, but it falls back on 21 what Charlie was saying. You still need that 22 functional interface with the existing AC emergency 23 power system. That applies to all the above 24 alternates.
25 So, whether I come in with a hydrogen-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 1 driven fuel cell or whatever alternate technology-2 neutral solution, I still got to do all those 3 functions that make it synchronize and accept the 4 load, et cetera, just like a diesel generator, just 5 like a combustion turbine. So, I'm just agreeing 6 vehemently with Charlie. I'll stop.
7 MEMBER BROWN: Okay. I think we've made 8 our point, Chris and Liliana. If somebody else has a 9 comment, speak up. We're not shy.
10 MS. RAMADAN: Member Brown --
11 MEMBER BROWN: Yes.
12 MS. RAMADAN: -- if I can state for C(1),
13 as sated before, we do reference applicable reg guides 14 in the various subsections of C(1) that point to other 15 regulations in order to get the specifics that you're 16 referencing to.
17 MEMBER BROWN: Those are not -- they don't 18 cover the type of stuff that I've just talked about.
19 I mean, it's -- if they did, then they wouldn't be 20 necessary in the diesel generator or the CTG part and 21 that's kind of the point.
22 Those are general regulations, so, I mean, 23 we can beat this to death right now, but we're 24 probably not going to have a little bit of a change in 25 positions, at least that I can tell.
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112 1 MEMBER HALNON: Charlie?
2 MEMBER BROWN: Yeah.
3 MEMBER HALNON: This is Greg. I'm trying 4 to follow you. I don't disagree with the concept that 5 any power source, you know, technology, whatever, it's 6 got to be able to interface with the plan 7 appropriately, but I'm not following the detail.
8 I see in C(1) right now that has to have 9 a discussion of the operability and functional 10 performance, address failure modes and effects and 11 discussing the interfaces and impacts, the onsite 12 emergency power system.
13 I see that and this -- so, whatever is 14 suggested or applied for will be -- we'll have to 15 address those issues and staff will have to review to 16 ensure that they're adequate.
17 So, where are you talking about putting 18 that detail in with all the other stuff?
19 MEMBER BROWN: Greg, that detail is in --
20 that level of information is in the EDG specs. That 21 interface involves load application and removals.
22 It involves paralleling that source with 23 the existing onsite, you know, the plant sources, if 24 you have to, for transferability.
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113 1 about you got to review and assess and discuss don't 2 address -- you have to make it up. You have to ensure 3 those other things are covered.
4 A simple solution to this would have been 5 to provide the guidance that you provided, but then 6 state that EDG and/or the CTG, whichever one you 7 wanted to pick, general, mechanical, electrical and 8 other characteristics that are there not for the 9 diesel and generator, they are testing requirements, 10 how you do this and how you do that, to ensure you 11 have reliability, paralleling, load removal and 12 application, voltage changes --
13 MEMBER HALNON: So, you're looking for 14 functional equivalency in some --
15 MEMBER BROWN: Functional equivalency, 16 that's right. And you don't have to -- you could just 17 reference the EDG.
18 I think it's -- I forgot the number of the 19 sessions. You don't want to repeat definitions, but 20 Sections 3 and 4, 5, 6 where they talk about 21 operability and testability.
22 You got a general statement on testability 23 where all it does is say it has to be able to be 24 tested. Review and discuss how you're going to test 25 all the stuff.
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114 1 MEMBER HALNON: Okay. So, you're looking 2 for an equivalent level of addressing the same issues 3 that we have for the traditional EDGs and CTGs.
4 MEMBER BROWN: Exactly, but those are 5 technology-neutral. That's the point that we've 6 missed the --
7 MEMBER HALNON: The interfaces are -- it's 8 like a black box power source, you know.
9 (Simultaneous speaking.)
10 MEMBER BROWN: In fact, yeah, you can put 11 a law down on the output of the diesel generator and 12 there's a bunch of stuff you have to meet. And that's 13 aside from the ability to get fuel into it or whether 14 it's got lube oil or all that other -- hydrogen fuel 15 cells need hydrogen. They're going to have to get it 16 from somewhere.
17 MEMBER HALNON: Okay.
18 MEMBER BROWN: How many hydrogen tanks do 19 you want ready to explode on the site? I say that 20 with tongue in cheek. I apologize.
21 MEMBER HALNON: No, I get that. I get 22 what you're talking about now. I see what you're 23 trying -- the equivalency is what I was trying to get 24 to, I think.
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115 1 then you don't want to have to rely on people bringing 2 all that stuff back to the fort with these general 3 review discuss and assess.
4 And, you know, I didn't disagree with any 5 of the 13 attributes, but there are more and there are 6 some details about those, you know, the interface 7 details that you got to pay attention to.
8 The other thing people miss when you talk 9 about alternative sources -- and Dennis mentioned one 10 of them -- say somebody wanted to use solar cells.
11 That's fine, but they are intermittent. If there's no 12 sun, you don't have anything. Same thing with wind 13 turbines.
14 So, you've got to store that energy 15 somewhere. You can't -- you need that on demand.
16 Well, that requires batteries and you don't have to 17 call out batteries, but you say you have to address 18 storage, blah, blah, blah, as a unique-type thing 19 because there are only a few alternative sources you 20 can deal with.
21 MEMBER HALNON: Those are intermittent 22 fuel sources.
23 MEMBER BROWN: Exactly. And they're 24 weather-dependent. I mean, if I was a licensee, I 25 would never depend on those and they take huge NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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116 1 acreage, but that's not for me to decide.
2 Fuel cells are local and they can be 3 handled, but you got to be able to provide hydrogen 4 tanks onsite for how long. How long does that 5 hydrogen source have to last and how easy can you get 6 replenishment into the site?
7 Those are application-specific, you know, 8 to the technology itself. Don't care about that other 9 than that you obviously have to address them, but it's 10 all the other stuff that's in the EDG and CTG 11 standards that really connect whatever that source is 12 to the plant as it stands and handle its transients, 13 responses, lights-out situations, how fast does it 14 start.
15 I don't remember all the details on the 16 commercial plants. I do know the Navy nuclear plants, 17 we had a 10-second -- the lights go out and within 10 18 seconds the diesel generator was up and accepting load 19 just fine.
20 And that's similar to what I've read in 21 the standards and the specs I've seen in the 22 commercial world since I've been on the Committee.
23 MEMBER HALNON: And that's just one of 24 them.
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117 1 big load to it, you don't want the voltage to drop to 2 50 percent of the voltage. Otherwise, all your loads 3 drop out.
4 MEMBER HALNON: Yeah.
5 MEMBER BROWN: So, it's that type of stuff 6 that's in the existing ones that when somebody comes 7 in with an alternative, you don't want to have to tell 8 them you left this out. They should know that already 9 that that's what you -- what's the expectations?
10 MR. MILLER: Member Brown, this is Kenn 11 Miller. Can I ask a question?
12 MEMBER BROWN: Yeah.
13 MR. MILLER: Again, my name is Kenn 14 Miller. I'm in the Electrical Engineering Branch with 15 Lili and, Member Brown, you've used the term "spec" 16 and "standard" and I think you're meaning -- you're 17 referring -- when you say those terms, you're meaning 18 the same thing and you're referring to IEEE 387 and 19 IEEE 2420.
20 MEMBER BROWN: Exactly. Yeah. Pardon me 21 for that, yes.
22 MR. MILLER: No, I just want to make sure 23 I'm catching that right.
24 MEMBER BROWN: Yeah, that's correct.
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118 1 your point is -- and, again, going back to what we did 2 with this reg guide, was given that we have detailed 3 standards for diesels and turbines already, and that's 4 why we have endorsements of those standards and those 5 do go into the details that you're describing, and, 6 yes, those details will apply to any chosen technology 7 that a licensee might choose to try to apply, but in 8 the absence of a standard that we typically endorse we 9 chose to stay at the regulatory level.
10 And the regulatory -- the regulations, you 11 know, describing the onsite power source envelope all 12 of the characteristics you're talking about.
13 And until the industry will come forward 14 with an approach, which would probably be followed by 15 the IEEE picking up a standards development process to 16 address those kinds of issues, and then we would 17 gladly endorse that standard as part of the regulatory 18 guidance document.
19 But at this time given that we don't have 20 that, we chose to go with the route of specifying the 21 regulations and we do -- and, as has been said, we do 22 point at some of the reg guides that deal with some of 23 the other issues dealing with onsite power supplies.
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119 1 that those are all issues that would have to be 2 addressed by an applicant if they were going to decide 3 to try to apply a different technology.
4 And, frankly, they should have the 5 knowledge to know that the requirements that are 6 specified in the two standards that are endorsed are 7 equally applicable and that they should, you know, 8 they'll have to deal with that and we will have 9 questions going through that process to deal with it.
10 MEMBER BROWN: Why don't you say that?
11 MR. MILLER: Because we don't have a 12 standard yet to do it.
13 MEMBER BROWN: You do.
14 MEMBER BLEY: Charlie?
15 MEMBER BROWN: Yes, Dennis.
16 MEMBER BLEY: The end point of that logic 17 is that you delete everything except C(1) and it 18 applies to everybody and we don't want to do that.
19 If you look at C(3), which is looking at 20 combustion turbines, it turns out that in that 21 standard we didn't have the data gathering 22 requirements that exist for the EDGs. So, you brought 23 that stuff over, put it in your reg guide, and that's 24 kind of where we're coming from is the things that we 25 can bring over and put in the reg guide now might save NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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120 1 you a lot of trouble later.
2 And this is -- you're so out of whack 3 between C(1) versus C(2) and C(3), we understand the 4 reasons, but you don't need to be as far out of whack 5 as it is.
6 And, like I said, you could get rid of 7 C(2) and C(3) by the same argument and just live with 8 C(1) for everybody.
9 MEMBER BROWN: Okay. Any other comments?
10 (Pause.)
11 MEMBER BROWN: Thanks, Dennis. Okay.
12 Liliana, are you there?
13 MS. RAMADAN: Yes. Yes. Okay.
14 MEMBER BROWN: Okay. Kenn, Chris, I 15 appreciate the input, and Liliana also. The purpose 16 of these meetings is to have this kind of discussion, 17 so that's much appreciated. And we hope we've 18 expressed our thought processes clearly enough that 19 you understand where we're coming from, but I suspect 20 we can move on right now.
21 (Pause.)
22 MEMBER BROWN: Okay. Liliana?
23 MS. RAMADAN: Yes, sir. Slide 9.
24 MEMBER BROWN: Yeah.
25 MS. RAMADAN: Alrighty. Okay. In slide NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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121 1 9, some of the -- we just provided a sample of the 2 supplements and clarifications to IEEE 387 and some of 3 -- they were addressed in C(2), the EDG section, and 4 specifically we looked at the testability and 5 synchronization capabilities that were supplemented to 6 address the testing of the EDGs while it parallels to 7 the grid.
8 If the offsite power grid experiences 9 transients, we're saying that the diesel should be 10 protected.
11 Also, in C(2) under the Design and Testing 12 Consideration section, in the language, we deleted the 13 language where it states, "simulate the parameters of 14 operation," and we replaced it to include the 15 allowance for testing of EDGs at the manufacturer to 16 envelope the parameters of operation under normal 17 standby condition, and we were specific on the 18 environments to include temperature and humidity.
19 Lastly, in C(2) the staff agreed to 20 include the EDG Owner Group recommendations to allow 21 for accelerated maintenance as appropriate.
22 Next slide. I wanted to point out that 23 there was a minor editorial typo in this slide. Where 24 it says, "addressing testing of EDGs," it should 25 actually read "CTGs." So, I just wanted to point NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 that out in case you received an older version.
2 MEMBER BROWN: That's on slide 10?
3 MS. RAMADAN: Yeah. Some people had 4 received an earlier version. I just wanted to point 5 that out.
6 MEMBER BROWN: Where it says "EDG" right 7 under the first bullet, it should be "CTG"?
8 MS. RAMADAN: Yes.
9 MEMBER BROWN: That makes sense since the 10 standard is the same.
11 MS. RAMADAN: Yes.
12 MEMBER BROWN: Thank you.
13 MS. RAMADAN: So, under the Design and 14 Testing Considerations in the CTG section, we clarify 15 the exhaust system needing to purge before startup or 16 during shutdown.
17 In addition, the design of the CTGs was 18 supplemented to consider the local environment 19 conditions to account for the significant pressure 20 loss associated with air intakes.
21 And lastly, the recommended parameters 22 were clarified to add additional items to be monitored 23 to indicate the need for an overhaul.
24 Next slide. This new guidance 25 supplemented both IEEE standards to include the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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123 1 verification of all subsystems such as fuel oil, lube 2 oil, cooling, starting and piping systems credited for 3 operation.
4 Other important changes that needed to be 5 noted, as stated before, many of the testing and the 6 design requirements from Revision 4 were removed.
7 Since they were incorporated in the updated IEEE 387, 8 the title of Reg Guide 1.9 changed to be more 9 reflective of a technology-neutral approach.
10 Next slide. In summary, we received 51 11 comments from NEI, IEEE and the members of public.
12 One of the significant changes we made was the 13 background section to combine the two sections on EDGs 14 and CTGs into one.
15 The rest of the comments we felt were 16 minor and were incorporated by editorial changes.
17 Several other comments did not require changes because 18 they were determined to be beyond the scope of this 19 regulatory guide.
20 Next slide.
21 MEMBER BROWN: Before you leave that, if 22 you would, I wanted to make sure I understood. When 23 I looked at the version you provided us for the full 24 committee meeting, there's a background which talks 25 about the onsite emergency alternating current power NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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124 1 sources, the bold heading.
2 And then you -- the combination you're 3 talking about, you would have a CTG and EDG and you 4 combined both of those on page 8.
5 MS. RAMADAN: Yes.
6 MEMBER BROWN: That's the combining you're 7 talking about, right?
8 MS. RAMADAN: Yes, sir. Yes.
9 MEMBER BROWN: Okay. Thank you. That's 10 all. I just wanted to make sure I had that calibrated 11 right.
12 CHAIRMAN SUNSERI: Hey, Charlie, this is 13 Matt. You have a couple of hands up. I don't know if 14 they're from before or if they're --
15 MEMBER BROWN: Oh, okay.
16 CHAIRMAN SUNSERI: Kenn Miller and Dennis 17 Bley.
18 MEMBER BROWN: Your all's hands up for a 19 reason?
20 (Simultaneous speaking.)
21 MR. MILLER: This is Kenn. Mine was up 22 from earlier. I forgot to take it down. Sorry about 23 that, Member Brown.
24 MEMBER BROWN: Okay. I've never learned 25 how to do raising hands on this Teams. I got to pay NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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125 1 attention to that. Thank you, Matt. Alright. Go 2 ahead, Liliana. Thank you.
3 MS. RAMADAN: Okay. So, slide 13. Some 4 of the comments of interest were from NEI and their 5 reference in the public comment table there No. 1, 2, 6 3 and 5.
7 MEMBER BROWN: And 7.
8 MS. RAMADAN: Um.
9 MEMBER BROWN: Forget 7. Just deal with 10 1, 2, 3 and 5.
11 MS. RAMADAN: In particular, in an NEI 12 letter dated February the 18th, NEI wrote to the NRC 13 during the public comment period their concern on --
14 their greatest concern in the statement and the 15 discussion section where it was stated that the onsite 16 emergency AC power source should be capable of 17 operating for a minimum of 30 days. And NEI did not 18 agree that that was a generic minimum requirement 19 regarding mission time for the emergency AC power 20 sources.
21 So, after two iterations, in resolution, 22 the staff removed the reference to 30 day. The staff 23 interpreted this requirement in GDC 17 to mean the EDG 24 mission time refers to the amount of time the EDG is 25 required to operate to supply power to safety systems NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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126 1 that mitigate the effects of accidents and events 2 delineated in the licensee safety analysis and to 3 power the equipment necessary for long-term core 4 cooling.
5 Therefore, the EDG mission time is 6 dependent upon the mission time of the equipment the 7 EDG is designed to support during the loop conditions.
8 MEMBER BROWN: Can I comment on that?
9 MS. RAMADAN: Yes.
10 MEMBER BROWN: I understand what you were 11 quoting, but 10 CFR 50.46(b)(5) states: Long-term 12 cooling. After any calculated successful initial 13 operation of the ECCS, the calculated core temperature 14 shall be maintained at an acceptably low temp value 15 and decay heat shall be removed for the extended 16 period of time required of the long-lived 17 radioactivity remaining in the core, which is -- could 18 be a long, long time.
19 Second, you also reference Reg Guide 1.27, 20 which is the ultimate heat sink regulatory guidance, 21 and the No. 1 guidance item in that says, the UHS 22 should be capable of providing sufficient cooling for 23 at least 30 days to permit simultaneous safe shutdown 24 and cooldown of all nuclear reactor units that it 25 serves and to maintain them in a safe shutdown NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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127 1 condition, and (2) in the event of an accident in one 2 unit, to limit the effects of that accident safely, to 3 permit simultaneous and safe shutdown and cooldown of 4 any remaining units, and to maintain them in a safe 5 shutdown condition. Procedures should be available 6 for ensuring a continued capability of the UHS to 7 provide sufficient cooling for 30 days -- after 30 8 days.
9 So, in reality, you will not get any 10 extended capability if you don't have AC power. So, 11 the mission time while -- you could look at the 12 mission time that was previously specified as not an 13 unreasonable starting point for anything. And if 14 somebody concludes they don't need that, that's fine.
15 I'm just pointing out that there's some 16 inconsistencies with not saying anything in their 17 ultimate heat sinks, which all the plants require 18 regardless of what they are. So, you've got to keep 19 them up for 30 days and then provide for extended 20 cooling after that, in your reg guide.
21 So, I'm just pointing that out. It's a 22 little bit counterintuitive to the objections that 23 were raised. That's just me based on my review.
24 MEMBER HALNON: Yeah, Charlie. This is 25 Greg. There's a long, long history with mission time NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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128 1 and the inspection space for the operating plants.
2 And just about any time an inspector comes onsite and 3 talks about mission time, it's not always clear in the 4 licensing basis which mission time you're talking 5 about, individual mission times and stuff.
6 And unless we're willing to take it on in 7 this reg guide, there will be backfit issues going on 8 for years after this might be in there.
9 So, my sense is that NEI is not wanting to 10 take that issue on as the generic issue and that they 11 want each of the individual plants to deal with it 12 appropriately based on the language in their safety 13 analysis report.
14 And the problem is is that, as you know, 15 many of the 1970 vintage safety analysis reports might 16 be three volumes and the 1980 -- late-'80 -- mid-'80 17 version or even now are 15, 20, 25 notebooks.
18 MEMBER BROWN: Well, Greg, just to comment 19 on that, the Rev 4 had this same guidance in it, 30-20 day guidance, in the Discussion section.
21 MEMBER HALNON: And that's the problem.
22 MEMBER BROWN: So, this has been around 23 for almost 15 years.
24 MEMBER HALNON: Right. And I would say 25 that the argument in the industry has been along that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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129 1 long, too, because the licensing bases don't always 2 either state 30 days or (audio interference).
3 So, I think that they wanted to try to 4 stay away from a generic issue coming up in this and, 5 you know, like I said, unless we're willing to take on 6 this as a generic issue now, I think that probably the 7 language that they came up with is where the industry 8 is at right now anyway.
9 MEMBER BROWN: Well, I would take a 10 slightly different path on that. I think any -- the 11 guidance is the guidance and 30 days, as long as it's 12 couched in the terms of being a reasonable starting 13 point absent any other analyses that justifies a 14 different mission time, that leaves it open such that 15 you have the ability, but you've at least got a 16 starting point that you have to look at.
17 MEMBER HALNON: Yeah. That's a valid way 18 of looking at it as well.
19 MEMBER BROWN: And if I was going to 20 suggest anything, that would be -- that would be the 21 approach I think we should take. I don't want to 22 dictate anything, but you got to start somewhere.
23 And if you look at the existing reg guides 24 and the requirements for ultimate heat sinks and the 25 10 CFR, you know, 50.46, whatever it is, (b)(5), words NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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130 1 about long-term cooling, it makes sense to have a 2 starting point and then have somebody tell you why 3 they don't need it, and that's fine.
4 So, anyway, that was just -- as I was 5 reviewing this stuff and I -- admittedly, I'm not --
6 don't have your commercial world experience at dealing 7 with these critical issues. So, anyway, that's just 8 my thought process.
9 MR. MILLER: Member Brown, this is Kenn 10 Miller.
11 MEMBER BROWN: Yes.
12 MR. MILLER: I think your assessment was 13 pretty on target and I think the approach we took with 14 the change here was to refer to that license basis 15 that that's the way that we saw it.
16 And also to speak to the Rev 4 version 17 versus the Rev 5 version, the initial version that you 18 saw at the subcommittee, I would say the language from 19 5 was a little bit softened from 4 because it said, 20 "up to 30 days," I believe, and it said, "typical."
21 So, you know, the words were intending to 22 make it -- provide some more wiggle room, so to speak, 23 there, but now we've got the, you know, we've got the 24 sentence basically referring to the license basis of 25 the plant, we reference 50.46(b)(5) and, as you've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 said, we've got the reference to Reg Guide 1.27.
2 So, all of that's there. We're just 3 stopping short of stating the 30 days. And, again, 4 this is in the Background section of the reg guide, 5 too, but -- and, as was previously specified, you 6 know, I think this is a topic that's been kicked 7 around with all the licensees and regulators for quite 8 a while and we're probably not done dealing with it.
9 MEMBER BROWN: Well, I've never seen a 10 thorn I didn't want to stick in my finger.
11 (Laughter.)
12 MR. MILLER: We appreciate your comments, 13 Member Brown, as well as the rest of --
14 MEMBER BROWN: No, I understand those 15 other points and I agree, but I -- and it's always 16 been in the background. I mean, but people read the 17 background. Those are part of the reg guide.
18 MR. MILLER: Yeah.
19 (Simultaneous speaking.)
20 MEMBER BROWN: -- guidance to licensees.
21 MR. MILLER: Yes, I agree. And I agree 22 that the background gets picked up by the inspectors 23 as well.
24 MEMBER BROWN: My personal opinion, and 25 it's not a Committee opinion, obviously, is that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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132 1 starting points are much better than vagueness and 2 it's -- you always worry about how robust is your 3 emergency power system.
4 And you'd like to be dependent on nothing 5 but being able to truck in fuel of some kind, whatever 6 it may be, whether it be sunlight or wind or hydrogen 7 for the alternate sources.
8 So, alright. Thank you. And thanks, 9 Greg. Liliana, are we back to the slides again?
10 Yeah. I think you're on slide 13 right now.
11 Are you ready to go to the next one or did 12 you finish that one?
13 MS. RAMADAN: I'm almost done. I'm in the 14 last bullet --
15 MEMBER BROWN: Okay.
16 MS. RAMADAN: -- where this -- just 17 another comment of interest. The staff continues to 18 believe that the EDG needs to have adequate internal 19 protection while it's in test mode in order to sustain 20 its mission while it parallels to the grid.
21 Next slide. Comments from -- we also 22 received comments from IEEE. They were almost 23 identical to that of NEI and they were addressed 24 accordingly.
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133 1 of the public to include clarification on the use of 2 the term "accident." And currently in this revision 3 it -- the language is -- it's consistent with the 4 terminology regarding the term "accident" as it is 5 endorsed in IEEE standard.
6 This endorsement does not add any new 7 regulatory positions regarding the design basis 8 events, anticipated operational occurrences, the loss 9 of offsite power with accident conditions.
10 There was also a need to clarify the 11 bypassing of noncritical trips to the EDG and 12 bypassing of noncritical trips during accident is 13 expected and it is important to take measures to 14 ensure that the spurious actuation of other trips.
15 It does not prevent the EDGs from 16 performing their function during accident mode of 17 operation. And all these comments were resolved in 18 the Public Comment table that was provided.
19 Next slide.
20 MEMBER BROWN: Before you go on, have you 21 all -- the public, did you resolve or go over these 22 comments with NEI and/or anybody else or are these 23 just -- we had that comment in the last subcommittee 24 that they had not seen your all's resolutions.
25 Have they now seen your all's resolutions?
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134 1 MS. RAMADAN: We provided NEI the ADAMS 2 number last week to ensure --
3 MEMBER BROWN: Okay.
4 MS. RAMADAN: -- that they had the 5 opportunity to review our resolution to their 6 concerns.
7 MEMBER BROWN: And that was the updated 8 resolution that you provided to the full committee for 9 review --
10 MS. RAMADAN: Yes.
11 MEMBER BROWN: -- for the Committee?
12 MS. RAMADAN: Yes.
13 MEMBER BROWN: Okay. Alright. Thank you.
14 VICE CHAIRMAN REMPE: So, could I ask a 15 question on that? Did NEI get back to you with their 16 response or --
17 MS. RAMADAN: NEI has not requested any 18 other meeting, that I am aware of, after their review 19 of the public comment table and the resolutions to 20 that.
21 VICE CHAIRMAN REMPE: Thank you.
22 MS. RAMADAN: Next slide. Slide 14.
23 MEMBER KIRCHNER: Liliana, before you go 24 on -- this is Walt Kirchner. The second -- I can't, 25 in parallel, get up the comment resolution with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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135 1 slides and find it, but the second comment from NEI 2 regarding environmental testing, so my -- is my 3 understanding correct that the expectation by the 4 staff is that that environmental testing will be done 5 as part of the procurement spec for the diesel rather 6 than inservice in the plant, which would be, I think, 7 as NEI was hinting, would be an extraordinarily 8 expensive undertaking.
9 MS. RAMADAN: Correct. It would require 10 the manufacturer to validate the design.
11 MEMBER KIRCHNER: So, yeah. So, you would 12 do that through the procurement -- auditing or 13 inspecting the procurement.
14 MS. RAMADAN: Correct.
15 MEMBER KIRCHNER: Correct. Yes. Thank 16 you very much.
17 MS. RAMADAN: Okay. Slide 14.
18 MEMBER BROWN: You did 14.
19 MR. MILLER: You mean 15.
20 MS. RAMADAN: 15. I'm sorry. I'm sorry.
21 MEMBER BROWN: I'm trying to stay on 22 schedule here.
23 (Laughter.)
24 MS. RAMADAN: Okay. Will do. Okay. This 25 last slide OGC has reconfirmed its NLO on the proposed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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136 1 revision presented at the ACRS subcommittee, which we 2 just had on the 25th, and on the latest proposed 3 language that came out of the feedback of the 4 subcommittee. OGC's position reaffirms that there is 5 no backfit concern with Revision 5 of Reg guide 1.9.
6 The regulatory guides are guidance 7 documents. They are not mandatory requirements.
8 Licensees can choose whether they want to commit to 9 the guidance and regulatory positions in this reg 10 guide.
11 Therefore, the staff is not imposing any 12 requirement upon the licensees when this reg guide 13 gets published.
14 As Chris mentioned earlier, just yesterday 15 the staff presented NEI's continued backfit concerns 16 to CRGR and the proposed resolution we had.
17 CRGR had no concerns with the revised 18 language in the current draft reg guide and today we 19 are briefing the full committee and expect a letter 20 with no objections in order to issue this new guidance 21 mid-July. And that concludes my presentation.
22 MEMBER BROWN: Okay. Thank you. Are 23 there any other comments from the committee members 24 right now?
25 (Pause.)
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137 1 MEMBER BROWN: Hearing no response, can we 2 get the public line open?
3 MR. DASHIELL: Public line is open for 4 comments.
5 MEMBER BROWN: Okay. Thank you very much.
6 Is there anybody on the public line that would like to 7 make a comment? If so, state your name, organization 8 and provide your comment.
9 MS. PIMENTEL: Yes. Good afternoon. My 10 name is Francis Pimentel and I'm a senior project 11 manager at NEI.
12 MEMBER BROWN: Can you speak up, please?
13 MS. PIMENTEL: I coordinated some --
14 MEMBER BROWN: Could you speak up? You're 15 pretty --
16 MS. PIMENTEL: Can you hear me?
17 MEMBER BROWN: You're not very loud.
18 MS. PIMENTEL: Okay. Is this any better?
19 MEMBER BROWN: I think that might be a 20 little better. Thank you.
21 MS. PIMENTEL: Okay. So, I coordinated 22 industry comments on draft Revision 5 to Reg Guide 1.9 23 and we appreciated the consideration and incorporation 24 of many of our comments; however, looking at the 25 newest revision it still appears that three of our top NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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138 1 priority one concerns were not addressed.
2 One relating to introducing and defining 3 the term "mission time" as it applies to emergency 4 diesel generators.
5 And two other comments related to the 6 supplements to the IEEE standard 387-2017 regarding 7 the testing environment (audio interference) --
8 MEMBER BROWN: Are you still there?
9 MS. PIMENTEL: -- these were our comments.
10 I'm still here. Can you hear me?
11 MEMBER BROWN: Yeah, we lost you there for 12 a minute.
13 VICE CHAIRMAN REMPE: Right when you said 14 "testing environment," we lost you.
15 MEMBER BROWN: Okay. So, regarding the 16 testing environment and the design considerations for 17 testability and synchronizing capability.
18 So, in regards to comments 1 and 2 in --
19 regarding mission time, we appreciated that the 20 original language talking about a 30-day mission time 21 minimum requirement was removed from the draft reg 22 guide; however, we disagree with the language that it 23 was replaced with and recommend that all reference to 24 emergency diesel generator mission time be deleted 25 based on the following: The proposed new language NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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139 1 provides a first-of-a-kind definition of "mission 2 time" by the NRC and conflicts with an already 3 established definition supported by the NRC in NEI 99-4 02, Rev 7, Regulatory Assessment Performance Indicator 5 Guideline for all SSCs as follows: Describe "mission 6 time" as the mission time models in the PRA for 7 satisfying the function of reaching a stable plant 8 condition where normal shutdown cooling is sufficient.
9 Note that PRA models typically use a mission time of 10 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, shorter intervals, as justified by 11 analyses and modeled in the PRA, may be used.
12 The proposed new language conflicts with 13 this established definition and is in direct contrast 14 to the industry's move to a more risk-informed 15 process.
16 Also, this new concept shouldn't be 17 introduced as part of the background discussion. We 18 believe it would be more appropriate to engage on this 19 issue with the PWR Owner's Group, which has thoroughly 20 researched and addressed the issue in PWROG 20014 NT 21 report, emergency diesel generator mission time.
22 Our past experience indicates that the 23 addition of an EDG mission time to this reg guide will 24 result in inspectors asking licensees questions 25 regarding diesel generator mission time, which has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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140 1 proven to result in long and costly resource-intensive 2 processes with no gain for either party.
3 And the concept of an EDG mission time 4 isn't applicable as in this report no Westinghouse, 5 B&W or CE plants are licensed with these reg guides 6 and no plant USFAR discussed an EDG mission time.
7 In addition, the safety analyses performed 8 by Westinghouse do not assume an EDG mission time.
9 Therefore, the concept of a mission time, as 10 identified in the reg guides discussed above, is not 11 applicable to any PWR Owner's Group plant's current 12 licensing basis.
13 In regards to C(2)(i), in the NRC 14 presentation earlier it stated that the new revision 15 included clarified language to state that the design 16 of the EDG encompasses the temperature and humidity 17 band of operation.
18 Also, during the presentation it was 19 spoken that the testing was to be done at the 20 manufacturer; however, the actual document doesn't 21 refer to the manufacturer and still states that the 22 designs that allows testing of the diesels to envelope 23 the parameters of operation, e.g., manual start, 24 automatic start, load sequencing, load shedding and 25 operation time, normal standby conditions and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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141 1 environment, e.g., temperature and humidity, that 2 would be expected if an actual demand were placed on 3 the system.
4 Therefore, our original comments regarding 5 temperature and humidity in the environment still 6 remains unresolved.
7 As stated in our previous comments, IEEE 8 387-2017 provides adequate guidance to assure diesel 9 generator safety function is not lost due to 10 environmental conditions.
11 It's our position that the reference to 12 temperature and humidity be removed from C(2)(i) 13 because it presents potential for misinterpretation, 14 it is a design criteria rather than a surveillance or 15 testing consideration and is redundant to the 16 standards. And, as stated in NEI's comments, the NRC 17 has already agreed to incorporate corrections based on 18 our position as previously documented.
19 The NRC response to Reg Guide 1.9 Rev 4 20 comment in a letter to NEI's Mr. Adrian P. Heymer from 21 NRC's William Reckley, included the staff agrees that 22 the use of the word "simulate environment" in 23 Regulatory Position 1.5 is subject to different 24 interpretation and the staff intends that the effects 25 of the environment, temperature and humidity, should NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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142 1 be considered in establishing the rating of the 2 diesel.
3 And the NRC also states later in the 4 letter that the staff agrees to include the 5 clarification in the next revision of Reg Guide 1.9 6 regarding the issue.
7 And our third priority comment was in 8 regards to position C(2)(iii) where we still disagree 9 with the proposed addition of position C(2)(iii) to 10 supplement IEEE standard 387-2017 for 4.4 Table 1 11 because the proposed items are in reference to the 12 preferred power source, otherwise known as the offsite 13 power, and is outside the scope of the IEEE 387 14 standard.
15 With respect to C(2)(iii)(a) reference is 16 made to the power quality of the preferred power 17 supply, offsite power, when the diesel is parallel to 18 the grid or in test mode.
19 The NRC proposes the consequences of 20 transient or degraded conditions, quote, should be 21 considered for loading impact on the diesel. Any 22 design associated with the preferred power supply 23 should be considered part of the remote protection 24 system and, as such, would be outside the scope of 25 IEEE standard 387.
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143 1 The design considerations applied here 2 would more appropriately be in the scope of other IEEE 3 standards, say, 308 and IEEE Standard 741 and possibly 4 Standard 765.
5 The position, as written, doesn't provide 6 the clarity of what's expected. Item 47 is a design 7 consideration for diesel-generated testing capability.
8 And for Position C(2)(iii)(b), the diesel 9 responding to an accident, loss of offsite power, or 10 both, while the diesel is in test mode and parallel to 11 the grid, is an example of a protection signal that 12 originates outside of the diesel scope for remote 13 protection systems.
14 IEEE Standard 387-2017 principle design 15 criteria is to ensure that the design of the diesel 16 will respond to the signal -- external signal, but is 17 not within the scope of IEEE 387 to design the remote 18 protection system.
19 That concludes our comments. Thank you 20 for giving us the opportunity to provide these.
21 CHAIRMAN SUNSERI: Charlie, you still 22 there? Any other public comments?
23 MEMBER BROWN: Yeah, I'm still here. I 24 didn't get my -- my mouse ran away from me. It saw a 25 piece of cheese.
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144 1 I wanted to get the NEI's name again. I 2 missed her name.
3 MS. PIMENTEL: Francis Pimentel.
4 MEMBER BROWN: Could you spell your last 5 name for me?
6 MS. PIMENTEL: Yes. P as in Paul, I, M as 7 in Mary, E, N as in Nancy, T as in Tom, E, L as in 8 Lisa.
9 MEMBER BROWN: Okay. Thank you.
10 VICE CHAIRMAN REMPE: Charlie, this is 11 Joy.
12 MEMBER BROWN: Yes.
13 VICE CHAIRMAN REMPE: I had trouble 14 hearing for whatever reason. Did the NEI persons 15 indicate they're still going to the CRGR on their 16 concerns?
17 MEMBER BROWN: No, they didn't.
18 VICE CHAIRMAN REMPE: Are we allowed to 19 ask them if they are planning to do so?
20 MEMBER BROWN: Francis, that was a comment 21 that came up during the subcommittee meeting a couple 22 of weeks ago that you all were sending a letter to the 23 CRGR.
24 Did you all do that?
25 MS. PIMENTEL: We are in the process of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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145 1 preparing a letter. We were looking to see what 2 comments during this meeting, you know, were going to 3 be discussed on -- and we will be finalizing that 4 letter within the next week.
5 MEMBER BROWN: Okay. Thank you. Anybody 6 else?
7 MR. BASSO: This is Tom Basso.
8 MEMBER BROWN: Yes, go ahead, Tom.
9 MR. BASSO: Yeah, this is Tom Basso. Tom 10 Basso, B-A-S-S-O --
11 MEMBER BROWN: Okay.
12 MR. BASSO: -- from NEI. I'm the senior 13 director of Engineering and Risk. So, as Francis 14 said, we are still reviewing the responses.
15 We did get -- we did get the 16 comment/responses late Thursday evening. So, with the 17 holiday we were not able to get with our members and 18 industry SMEs until yesterday and this morning in 19 prepping for the meeting today.
20 I've since reached out and requested if a 21 public meeting would be appropriate to see if we can't 22 work through these comments that we've made today 23 versus going to the CRGR.
24 And so, that's why we did not have a 25 public meeting. It was too short of a time frame for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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146 1 us to get out the draft and the comments to our 2 members and have them review it and develop a 3 response. That's the only comment I have. Thank you.
4 MEMBER BROWN: Okay. Thank you very much, 5 Tom. Thank you, Joy, for triggering that. I forgot 6 that one.
7 Is there anybody else on the public line 8 that would like to make a comment?
9 MR. MATHARU: Yes, Chairman Brown. This 10 is Gurcharan Matharu. I work for the USNRC, but as a 11 consequence of providing comments as a member of the 12 public, I have to partake as a member of the public in 13 this review process.
14 So, I have a couple of comments if you 15 don't mind giving me a couple of minutes.
16 MEMBER BROWN: Go ahead.
17 MR. MATHARU: So, I was part of the 18 original (unintelligible) that orchestrated the 30-day 19 mission time that you previously discussed (audio 20 interference) the very basis that we have in-house 21 views in the past and, like you identified, it's been 22 in some of the NRC inspection reports and NRC 23 documents for quite a few years. So, it's not a new 24 position.
25 And as you also pointed out, it's a good NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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147 1 starting point to discuss something that's supposed to 2 be an infinite amount of time that the diesels may be 3 required to function based on 10 CFR 50.45.
4 As far as the NEI comment and the 24-hour 5 mission time, we have thought about that also long and 6 hard, and I am not sure whether we can use risk-based 7 or risk-informed. Our thought process was we are 8 risk-informed and we are looking at it on a 9 deterministic basis for the mission time for the 10 diesel and looking at the operator experience there 11 are events that are related to loss of offsite power 12 due to hurricanes, severe weather. And it's hard for 13 me to perceive a diesel generator for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 14 offsite power being recovered when the whole grid or 15 (unintelligible) system in the vicinity of the nuclear 16 power plant is devastated.
17 And we've got a lot of experience after 18 Sandy, the tornados and the hurricanes that damaged 19 the network around Browns Ferry or Hurricane Katrina.
20 So, it kind of (unintelligible) for me to hear 24-hour 21 mission time. That's a PRA number that has got no 22 basis. I just want to clarify that.
23 And, Charlie, you requested, I guess, the 24 reviews and the NRC research project team to provide 25 comments and the resolution to the -- all the c NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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148 1 commenters.
2 I believe if you have not, as a member of 3 the public, seen the comment responses that will 4 developed with comments, these are relating basically 5 to bypassing the noncritical protective features 6 during shutdown mode which are critical for 7 maintaining shutdown cooling. And (unintelligible) 8 those comments, I would really appreciate NRC members 9 to submit those comments to public reviewers also.
10 Appreciate that. Thanks very much.
11 MEMBER BROWN: Thank you. I'm sorry, 12 would you please repeat your name and spell it for us?
13 MR. MATHARU: Yes. The last name is 14 Matharu, M-A-T-H-A-R-U.
15 MEMBER BROWN: First name?
16 MR. MATHARU: First name is Gurcharan.
17 I'll spell it for you. G-U-R-C-H-A-R-A-N.
18 MEMBER BROWN: That's G-U-R-C-H-A-R-A-N?
19 MR. MATHARU: N as in Nancy, correct.
20 MEMBER BROWN: Okay. Thank you. Did you 21 get that, court reporter? Did you get that?
22 (Pause.)
23 MEMBER BROWN: Okay. Thank you. Are 24 there any other public comments that we -- people on 25 the line that would like to make comments?
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149 1 (Pause.)
2 MEMBER BROWN: Okay. Hearing none, you 3 can close the public line.
4 MR. DASHIELL: The bridge line is closing.
5 MEMBER BROWN: Thank you very much. Let 6 me see where I am. I had some other thought before we 7 got this long and now I've lost it.
8 (Pause.)
9 MEMBER BROWN: Okay. One last round of 10 the members. Based on hearing anything, do you --
11 does that job your memories? Do you have any 12 additional comments or are you all -- is everyone 13 finished?
14 MEMBER HALNON: Charlie, this is Greg. I 15 think that the comments made the point on the 16 confusion and different points of view of mission 17 time. Those two words have caused a lot of 18 consternation in the industry.
19 And if I would recommend anything, would 20 be to look at not using those words, if it's very 21 possible to do it, because there's different 22 definitions and different uses for that both in risk 23 area, deterministic in the old SARs, new SARs, all 24 kinds of stuff. So, anyway, that just kind of made 25 the point there.
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150 1 MEMBER BROWN: Okay. We'll have an 2 opportunity to discuss that. Obviously the committee 3 will have to come to an agreement on what we would 4 want to say in the report, if anything.
5 Alright. Hearing --
6 VICE CHAIRMAN REMPE: This is Joy. I'm 7 still wondering if the staff, in light of the fact 8 that it sounds like the CRGR review is going to occur, 9 I mean, the staff made some changes since our 10 subcommittee meeting and I'm just kind of wondering if 11 the staff still wants to go forward as planned, is 12 what I'm --
13 MEMBER BROWN: They made the comment, from 14 what I understand, that they made the changes they 15 made and the changes we see where they eliminated the 16 30 days and stuff like that. And they changed the 17 environmental stuff somewhat, but not enough for NEI's 18 satisfaction. That CRGR came back and said, okay.
19 Now, NEI said they were going to prepare 20 a letter, but they were going to try to work with NRC 21 to work this out, the staff.
22 VICE CHAIRMAN REMPE: Right. Yes. I'm 23 just kind of wondering again, like, the staff said 24 they didn't get back to NEI -- I mean, or they hadn't 25 heard back from NEI yet and I just am wondering if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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151 1 they're going to make more changes.
2 MEMBER BROWN: I'm not sure we can tell 3 them what to do right now. I just -- that's the 4 status where it is right now, but the NEI -- oh, gee.
5 I didn't write it down.
6 Oh, Tom Basso commented that they were --
7 or maybe it was Francis. I can't remember which, but 8 they just got them on 7/1. That was last Thursday.
9 VICE CHAIRMAN REMPE: I heard what they 10 said, but apparently this is probably the first time 11 the staff's heard it, too.
12 MEMBER BROWN: That may well be. That may 13 well be.
14 VICE CHAIRMAN REMPE: Okay. Yeah, that 15 doesn't affect anything that we've heard today.
16 MEMBER BROWN: We can't provide an answer 17 or a discussion on that basis on the comments like 18 that in the meeting.
19 VICE CHAIRMAN REMPE: Okay. Thank you.
20 MEMBER BROWN: It's not our practice.
21 Anymore members have comments?
22 (Pause.)
23 MEMBER BROWN: Okay. Matt, with that --
24 oh, before I do that, I would like to -- the staff is 25 still online, aren't they? Liliana, Kenn?
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152 1 MR. MILLER: Yes, this is Kenn. I'm still 2 on.
3 MS. RAMADAN: I'm still on.
4 MEMBER BROWN: And NEI, I want to thank 5 you all for the comments and for the robust discussion 6 we had on these subjects.
7 I think that's the purpose of these 8 meetings is to have a -- make sure we hit the top-9 level issues and then thoroughly vet them while we are 10 deciding what we -- what path we may take.
11 So, I do appreciate your all's preparation 12 and the ability to provide your all's insights as to 13 why you did what you did as part of the meeting.
14 MR. MILLER: Member Brown, this is Kenn 15 Miller. What we will say, too, that we appreciate 16 ACRS' review of this and the input you have provided.
17 We appreciate it.
18 MEMBER BROWN: Thank you very much. I 19 love to get saddled with controversial reg guides.
20 (Laughter.)
21 MEMBER BROWN: Always fun. Matt, with 22 that, I guess I can turn it back to you for closeout.
23 CHAIRMAN SUNSERI: Okay, Charlie. Thank 24 you. And I presume you have a draft letter that you 25 are ready to share?
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153 1 MEMBER BROWN: Yes. Yes. It will be 2 interesting to discuss.
3 CHAIRMAN SUNSERI: Right. Right. Right.
4 Okay. So, what I suggest we do is we take a short 5 break here while we transition over and ask Sandra to 6 bring that letter or report up for our review and we 7 will take a 15-minute break here. So, we will 8 reconvene at 25 before the hour. That's 4:35. 25 9 before the hour. Okay?
10 MEMBER BROWN: That's about 15 minutes, 11 right?
12 CHAIRMAN SUNSERI: Yeah. Yeah.
13 MEMBER BROWN: It's a little more than 14 that. Okay. Alright. Thank you.
15 CHAIRMAN SUNSERI: Alright. I have it 16 right here in my notes and I didn't even look at it, 17 but, yes, the transcript stops here. Thank you.
18 (Whereupon, the above-entitled matter went 19 off the record at 4:18 p.m.)
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Vogtle Unit 1 and 2 Risk-informed Resolution of Generic Letter 2004-02 ACRS Full Committee Meeting July 7, 2021
Key Messages
- Underlying technical issues thoroughly examined for decades
- All plants reduced the potential for sump strainer blockage by installing improved strainers and taking other actions
- In-vessel downstream effects are determined to be low safety significance compliance issues
- Risk-informed submittals have contributed significantly to the state of knowledge of the effects of debris on long-term core cooling and its associated risk 2
Actions Completed at Plants
- Improved strainers
- Modified or replaced insulation
- Other physical mods
- Admin Controls
Physical Testing
- Debris generation and transport
- Chemical effects
- Strainer
- Fuel and reactor core
- Boric acid precipitation
Computer Modeling
- Thousands of computer model runs performed by utilities, vendors, engineering firms, and academia
- Supplemental and confirmatory analysis performed by NRC (Office of Research - TRACE)
Timeline for STP and Vogtle Risk-Informed GL 2004-02 Resolution Vogtle and Farley 90-Day Vogtle Sump Response to GL 2004-02 Strainer Upgrade Vogtle chose risk-informed approach Combined Vogtle and Updated Vogtle GL Farley GL 2004-02 2004-02 Submittal Submittal Vogtle Strainer Head Loss Testing STP switched STP Initial STP First LAR to RoverD Quantification Submittal method 2004 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2014 STP ACRS NEI 04-07 Revised content guide for SECY-10-113 Subcommittee Meeting GL 2004-02 submittal RG 1.174, Revision 2 GL 2004-02 WCAP-16530-NP-A WCAP-16793-NP-A, Revision 2 NRC SE of NEI 04-07 NUREG-1829 RG 1.82, Revision 4 WCAP-16406-P-A, Revision 1 SECY-12-0093 Proposed 3 RG 1.200, Revision 2 options of resolving GSI-191
Timeline for STP and Vogtle Risk-Informed GL 2004-02 Resolution (Contd) .
NRC agreed to review a Technical Report by Vogtle Vogtle Technical Report for risk-informed resolution NRC Staff Evaluation of Vogtle Technical Report NRC Audit Vogtle Fiber Penetration Testing Vogtle LAR Submittal Updated Vogtle NRC Technical Report Software NRC RAIs on Audit LAR Submittal STP revised NRC Audit LAR with NRC SE on STP LAR RoverD method Submittal Vogtle Responses to RAIs 2015 2015 2016 2017 2018 2019 2020 2021 2021 STP ACRS Subcommittee NRC technical evaluation of in-RG 1.174, Revision 3 vessel effects Meeting STP ACRS Subcommittee Meeting NRC review guidance on in-vessel effects STP ACRS Subcommittee Meeting NRC SE on TSTF-567 WCAP-17788-P, Revision 1 ACRS Letter on STP Submittal PWROG-16073-P, PWROG guidance on in-vessel effects and TSTF-567 RG 1.200, Revision 3
Overall Status of Compliance
- 3 Staff Requirements Memorandum options from SECY-12-0093
- Option 1 - Closed out using existing guidance - 19 Units, Low Fiber Plants
- Option 2 - Perform additional testing and analysis, including risk-informed resolution
- 2A Deterministic - 34 Units
- 2B Risk-Informed - 8 Units, STP has closed the issue
- Option 3 - Treat strainer deterministically and in-vessel using risk analysis - No one selected this option 8
Risk over Deterministic Methodology (RoverD)
Deterministic Test Data Debris Limit Established Risk Informed Analysis Calculate Debris for Individual Breaks R
over D
Scenario Deterministically Debris Acceptable No Calculated Testing Limit Yes 9
Evaluation of Vogtle Submittal
- Technical report contained most of the technical information (Staff Evaluation ML19120A469)
- LAR addressed regulatory aspects of change and technical issues left open after review of the technical report (Staff SE is complete)
- Staff evaluated the 5 key principles of risk-informed regulation per RG 1.174
- Staff used approved guidance to evaluate risk and deterministic aspects of the submittals 10
Staff Methodology Five Key Principles of Risk-Informed Regulation
- 2. Change is consistent with defense-in-depth philosophy.
- 1. The proposed licensing basis change meets the current 3. Maintain sufficient regulations or an safety margins.
exemption is requested. Integrated Decisionmaking
- 5. Impact of proposed
- 4. Proposed increases change should be in risk should be small monitored using and consistent with the performance Commissions Safety measurement Goal Policy Statement.
strategies.
11
Minimum Average Maximum Main Loop, 56 Welds 10-16 inch, 39 welds 6-8 inch, 77 welds 2.5-4 inch, 122 welds
< /=2 inch, 119 welds 12
Principle 4 - Risk Is Very Low
- Licensee evaluated the impact of debris on the
- Strainer
- Some breaks contribute to risk
- In-Vessel
- No breaks contribute to risk
- Majority of breaks bounded by test results and do not contribute to plant risk
- A few large, unlikely breaks generate much larger debris amounts and contribute to plant risk
- CDF < 10-6
- LERF < 10-7 13
Summary of Systematic Risk Assessment
- Results fall in Region III acceptance guidelines in RG 1.174, for very small risk increase
- CDF < 10-6
- LERF < 10-7 Maximum of staffs confirmatory calculations Vogtles base assessment 14
Summary of Vogtle Review
- Vogtle acceptably evaluated the impact of debris
- Vogtle appropriately considered both risk and deterministic aspects in the submittal
- Most break scenarios are addressed using conservative deterministic methods for strainer acceptance criteria
- Vogtles in-vessel evaluation method and simulations are conservative and meet deterministic acceptance criteria
- Vogtles analyses meet the key principles of risk-informed regulation
- Vogtles PRA results show that the change in risk is very small 15
GSI-191 Lessons Learned from Risk-Informed Submittals
- The plants most challenged by the effects of debris on sump recirculation are using risk-informed methods to resolve the issues
- The risk-informed analyses demonstrate that actions taken by licensees and the NRC have significantly reduced the risk of this issue
- Use of risk-informed methods to address the issue have resulted in increases in safety from a reduction in personnel exposure and considerable savings in resource expenditures 16
Questions?
17
Backup Slides 18
General Licensee Actions to Address Debris Effects on Long Term Core Cooling (LTCC)
- Installed larger strainers
- Removed unnecessary debris sources
- Removed/replaced some problematic materials, or reinforced with banding and jacketing
- Implemented administrative controls
- Control materials in containment
- Implemented procedural/operational changes
- Improved chemical effects attributes 19
Types of strainers
- Uniform Flow PCI stack disk strainer
References
- Staff guidance on coatings, chemical effects, and headloss
- Draft RG 1.229
- WCAP-16530 Chemical Effects
- WCAP-16406 Ex-vessel Downstream Effects
- In-vessel staff review guidance 21
Systematic Risk Assessment
- Sensitivity and Uncertainty Analyses (focused on CDF)
- Performed consistent with NUREG-1855 guidance
- PRA quality was verified
- The licensees use of high likelihood configurations was found to be acceptable and bounding of low likelihood configurations
- NRC Staff Confirmatory Calculations
- Used conservative inputs
- Results do not challenge Region III of the RG 1.174 22
Primary References
- (1) ML18193B162 - SNC Technical Report Submittal dated July 10, 2018.
- (2) ML19120A469 - NRC Staff Evaluation of the Technical Report dated September 30, 2019.
- ML21068A109 - Amendment Package for Vogtle GSI-191.
- ML21071A050 - Exemption Package for Vogtle GSI-191.
23
Limitations & Conditions
- Modify RHR strainer height and maintain plant configuration consistent with the Technical Report
- Maintain evaluation consistent with TR
- Evaluate in-vessel effects
- Address Key Principle 1 - change meets regulations
- Address Key Principle 5 - monitoring of impact of change
- Define key elements of the analysis in the FSAR
- Define elements of the analysis that would require NRC review prior to change
- Approach to ensure periodic update of risk-informed assessment
- Reporting and corrective action strategy in case the acceptance criteria of RG 1.174 are exceeded
- Correct coatings transport error and evaluate effect on risk 24
Plant LOCA Response Spray nozzles Fuel Assemblies Tank RWST Heat exchanger Valve Strainers CSS SIS Sump Safety Injection Containment Spray System (CSS)
(SIS) 25
ACRS Full Committee Meeting:
Rulemaking Plan on Revision of Inservice Testing and Inservice Inspection Program Update Frequencies Required in 10 CFR 50.55a July 7, 2021
NRC Staff
- Presenter:
- Mark Yoo, RES: Technical Staff
- Working Group Members:
- Sheldon Clark, OGC: Attorney
- Victoria Huckabay, NMSS: Rulemaking PM
- David Rudland, NRR: Technical Lead
- Thomas Scarbrough, NRR: Technical Staff
- Ian Tseng, NRR: Technical Staff 2
Agenda
- Purpose of the SECY Paper
- Background
- Regulatory Issue
- Proposed Rulemaking
- Scope
- Process
- Schedule
- Staffs Recommendation 3
Purpose of the SECY Paper
- SECY-21-0029 was issued March 15, 2021.
- Request Commission approval to initiate a rulemaking to amend 10 CFR Part 50.55a to extend the interval of inservice testing (IST) and inservice inspection (ISI) program updates.
- Current 120-month update interval would be extended to 240 months, after updating to the most recent Codes and addenda incorporated by reference in § 50.55a.
- Requests Commission to delegate signature authority to the EDO.
- Request Commission approval and delegations for a potential subsequent rulemaking to extend update interval from 240 months to 288 months.
4
Background
- 10 CFR 50.55a incorporates by reference various codes and standards, including:
- ASME Operation and Maintenance Code (OM Code)
- ASME Boiler and Pressure Vessel (BPV) Code,Section XI, Division 1
- ASME BPV Code,Section III, Division 1
- Per § 50.55a(f)(4) and (g)(4), licensees are required to update their OM Code and Section XI Codes of record every 120 months.
- Section III Code of record is generally maintained throughout the life of the plant.
5
Background
- Effort began as an NRR EMBARK Venture Studios (EVS) project.
- Developed ideas to streamline regulating using §50.55a to:
- Improve the clarity of §50.55a
- Improve process efficiency for the use of ASME Codes and Code Cases
- Increase flexibility to licensees in implementing their IST and ISI programs
- Conducted multiple outreach activities with internal and external stakeholders.
- Recommendations documented in EVS Report (ML20153A752).
6
Background
- Identified 3 recommendations to pursue:
- 2. Institute direct final rules for unconditionally approved code cases.
- 3. Decrease frequency of ASME Code editions rulemakings.
- SECY requests rulemaking for Recommendation 1.
- Would provide improved flexibility and burden reduction to licensees while maintaining safety
- Recommendation is outside the scope of delegation for routine ASME Code updates and requires Commission approval.
- Staff will implement Recommendations 2 and 3.
- Recommendations are within the staffs delegated authority for rulemaking.
7
Background
- Also considered eliminating incorporation by reference of ASME BPV Code, Sections III and XI, and ASME OM Code from § 50.55a and endorsing the Codes through a regulatory guide.
8
Background
- SECY-00-0011 discussed the staffs recommendation to replace the 120-month IST and ISI update requirements with a baseline of IST and ISI requirements and voluntary updates to NRC-endorsed Code editions without prior NRC approval.
- Baseline requirements: 1995 Edition with the 1996 Addenda of the ASME OM and BPV Codes.
- The ACRS recommended to retain the current 120-month update interval.
- The Commission via SRM disapproved the staffs recommendation and approved the option to retain the current update interval.
9
Regulatory Issue
- Licensee IST and ISI programs describe licensees implementation of the ASME OM Code and ASME BPV Code,Section XI requirements, respectively.
- 10 CFR 50.55a requires that every 120 months licensees must update IST and ISI programs to the latest edition and addenda of the ASME OM and BPV Section XI Codes incorporated by reference within 18 months of the start of 120-month interval.
- 120-month interval corresponds to the 10-year ISI interval in ASME BPV Code,Section XI, IWA-2430.
10
Regulatory Issue
- Major modifications to ASME Codes typically take more than a decade.
- 2009 Edition of OM Code included improved IST requirements for motor-operated valves in response to a 1989 NRC Generic Letter.
- 2017 Edition of OM Code included improved IST requirements for active air-operated valves in response to a 2000 NRC Regulatory Issue Summary.
- Discovery of new degradation mechanisms has slowed greatly in recent years.
- Last degradation mechanism discovered was primary water stress-corrosion cracking, which was in the early 2000s.
- Subsequently addressed in ASME BPV Code Section XI.
11
Regulatory Issue
- There is a long history and established process of developing improvements and updates to the ASME Codes.
- Discovery of new degradation mechanisms or performance issues are typically first addressed by ASME using Code Cases before incorporating into an edition.
- NRC would continue reviewing new or revised Code Cases for incorporation into the regulations on a biannual basis.
- One of EVS recommendations would be to incorporate non-controversial Code Cases using an expedited process.
- NRC can mandate the use of certain Code Cases to supplement the current Code of record if new safety concerns are identified.
12
Rulemaking Scope
- The proposed rulemaking would double the time between updates for the licensees Codes of record for IST and ISI programs from 120 months to 240 months for licensees that update to the most recent edition and addenda of the ASME OM Code and BPV Code,Section XI incorporated by reference
- Current 120-month ISI program update interval corresponds to the current 10-year ISI interval in ASME BPV Code,Section XI.
- The proposed rulemaking would primarily affect:
- 10 CFR 50.55a(f)(4), Inservice testing standards requirements for operating plants
- 10 CFR 50.55a(g)(4), Inservice inspection standards requirements for operating plants 13
Rulemaking Scope
- Potential future rulemaking to extend the update requirement from 240 months to 288 months.
- ASME is considering extending current ISI interval to 12 years.
- Staff is not currently proposing to conduct this rulemaking and ASME has not yet extended the interval.
- Staff requests Commission approval for the additional rulemaking and delegation of authority to the EDO.
14
Rulemaking Process
- Typical rulemaking process includes development of rulemaking plan, regulatory basis, proposed rule, and final rule.
- Staff recommended omitting preparation of regulatory basis and proceeding with proposed rule development.
- Staff recommended that the proposed rule and final rule be delegated to the EDO, who would redelegate to the Director of NRR.
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Rulemaking Schedule
- SECY is currently with the Commission.
- Deliver proposed rule to NRR OD - 12 months after receipt of Commissions SRM.
- Deliver final rule to NRR OD - 12 months after comment period for proposed rule closes.
- This rulemaking may be combined with the next routine ASME Code Edition or Code Case rulemaking.
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Staffs Recommendation
- Staff recommends that the Commission:
- Approve initiation of a rulemaking to extend the interval for the IST and ISI program updates from 120 months to 240 months, after updating to the most recent Codes incorporated by reference in § 50.55a.
- Approve a future rulemaking to extend the interval from 240 months to 288 months if ASME increases the ISI interval to 12 years.
- Approve the staffs request not to develop a regulatory basis for these rulemakings.
- Delegate signature authority for these actions to the EDO.
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QUESTIONS?
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BACK UP SLIDES 19
Recommendation on Priority
- Based on the Common Prioritization of Rulemaking Methodology, the preliminary priority for this rulemaking is medium.
- Indirect contributor toward the safety goal (enhancing NRCs regulatory programs and risk-informing the current regulatory framework by prioritizing efforts to focus on the most safety-significant issues).
- Significant contributor to the efficiency and reliability principles of Good Regulation (Efficiency and Reliability).
- Moderate contributor to the governmental priority (future regulatory benefit).
- Moderate contributor to the public priority (moderate public participation and moderate burden reduction).
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Estimate of Resources
- If approval to initiate rulemaking is received in FY 2021, costs associated with rulemaking development in FY 2021 through FY 2023 are expected to be low.
- Additional efficiencies will be realized if staff is able to combine rulemaking with a routine ASME Code Edition or Code Case rulemaking
- Proposed rulemaking would result in cost savings to licensees
- Each IST and ISI program update costs an estimated
$1M per reactor unit 21
EVS Recommendations Recommendation 2: Direct Final Rule for unconditionally-approved ASME Code Cases.
- Incorporation by reference of these Code Cases should be non-controversial.
- Developed through a consensus standards process.
- Only one adverse public comment was submitted related to unconditioned Code Case in the last three ASME Code Case rulemakings.
- Staff determined the requested condition was not needed.
- Results in improved efficiency as it would allow licensees to use new approaches and technologies more promptly.
- Reduces NRC and licensee resources spent on the submittal and review of alternative requests.
22
EVS Recommendations Recommendation 3: Decrease the frequency of rulemakings to incorporate ASME Code editions.
- Reducing the frequency continues to maintain safety while reducing expenditure of staff resources.
- This would alleviate bottlenecks that may come with implementing Recommendation 2, as OMB accepts only one rulemaking per CFR part at a time.
- With Recommendation 1, there would not be a strong driver to incorporate by reference new Code editions into §50.55a on the current 2-year cycle.
- The review of each edition would still be documented as each edition is released.
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10 CFR 50.55a Rulemaking Delegation of Authority
- Until 1976, the Commission approved each rulemaking to incorporate by reference certain portions of the ASME Code into§50.55a.
- Via SRM, the Commission delegated the authority to the EDO for amendments that are routine in nature and represent the updating of basic codes and standards.
- In 2010, the EDO informed the Commission that he intended to redelegate the authority to the Director of NRR.
- Expected to increase the speed at which new Code editions could be incorporated into regulations, increase accountability, and reduce inefficiencies and redundancies.
- Only applies to rulemakings pertaining to ASME BPV Code, Sections III and XI, the ASME OM Code, and related regulatory guides.
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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 July 7, 2021
Agenda
- 1. Introduction
- 2. Existing Guidance
- 3. Significant Changes
- 4. Proposed New Guidance
- 5. Public Comments and Resolutions
- 6. Questions and Comments Slide 2
Introduction Current NRC guidance in Regulatory Guide 1.9 has not been updated since 2007. It does not reflect all the possible types of alternative onsite emergency AC power sources.
The NRC is issuing Revision 5 of Regulatory Guide 1.9:
- Endorse new and updated IEEE standards
- Introduce technology-neutral guidance other than diesels, to include combustion turbine generators (CTGs) and other types of the emergency power sources for the onsite alternative alternating current (AC) electric power system.
Purpose of introducing technology-neutral provisions:
- Acknowledge that future applications may use alternative onsite emergency power supplies for advanced reactors and nuclear facilities.
- Provide an initial path in the regulatory review process for alternative power supplies.
- Establish a foundation for alternative power supplies by describing acceptance criteria.
Slide 3
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 facilities.
Slide 4
Significant Changes This revision (Rev 5) endorses one new and updates another IEEE standard 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 IEEE Standard 387-2017 was updated from 1995 version o Includes specific details on design and testing considerations Slide 5
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 o Industry developed this new standard in 2019 based upon Interim Staff Guidance (DC/COL-ISG-021) o Specifically includes additional guidance on CTGs principal design criteria, design features, qualification considerations, and testing requirements.
Slide 6
Proposed New Guidance Includes provisions for alternatives for onsite standby emergency AC 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.).
- References applicable guidance provided in Regulatory Guides:
1.75, 1.6, 1.81, 1.118, 1.89, 1.100, 1.164, 1.28, 1.155 and 1.189 Includes additional design and testing considerations for EDGs, CTGs, and other emergency AC power sources.
Slide 7
Proposed New Guidance (Cont.)
This Revision introduces a new technology-neutral concept for power sources other than EDGs and CTGs.
Since the range of possible alternative power sources is very wide in scope, the staff provided only basic foundations identifying the regulatory requirements for an alternative onsite power sources.
Revision 5 is only introducing guidelines for alternative power sources. The staff is open to reviewing and endorsing future industry standards for alternate onsite power sources.
Slide 8
Proposed New Guidance (cont.)
Sample Supplements and Clarifications to IEEE 387-2017:
Design and Application Considerations for testability and synchronization capabilities was supplemented:
- to address testing of the EDG operating in parallel with the preferred power source in the event the preferred power source has transients.
Design and Testing Considerations was clarified:
- The design should allow testing of the EDGs to envelop the parameters of operation.
Operations 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.
Slide 9
Proposed New Guidance (cont.)
Sample Supplements and Clarifications to IEEE 2420-2019:
- Design and Application Considerations for testability and synchronization capabilities was supplemented:
- to address testing of the CTG operating in parallel with the preferred power source in the event the preferred power source has transients.
- Design and Testing Considerations was clarified:
- The exhaust system should be purged before startup or during shutdown
- The pressure loss associated with the air intakes may be significant. Design should consider the local environment and the possibility of condensation of moisture from the ambient humidity
- Recommended Parameters was clarified:
- adding additional items to be monitored to indicate the need for an overhaul.
Slide 10
Proposed New Guidance (cont.)
- 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.
Slide 11
Public Comments and Resolution Summary:
- 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.
Slide 12
Public Comments and Resolution(cont.)
Comments of interest from NEI (Comments No. 1, 2, 3, and 5)
- Reference to a 30-day mission time for the EDGs represents a backfit concern.
o 30-day timeframe removed. Mission time now refers to licensing bases.
- A requirement for constructing a chamber for testing various atmospheric conditions would be impractical.
o Clarified language to state the design of EDG encompasses a temperature and humidity band of operation.
- The design requirement associated with preferred offsite power should be considered part of the remote protection system per IEEE Standard 387, hence, not within the scope of this regulatory guide.
o EDG has adequate internal protection to sustain its mission while paralleled to grid.
Slide 13
Public Comments and Resolution(cont.)
Comments of interest from IEEE
- Almost identical to NEI comments. They were addressed within the responses to NEI comments accordingly.
Comments from Members of Public
- Clarification on the use of terms accident
- Terminology used was consistent with the terminology in the endorsed version of IEEE Std 387-2017.
- Clarification for bypassing non-critical trips of EDG.
- Bypassing of noncritical trips during accidents is expected and it is important to take measures to ensure that spurious actuation of these other protective trips does not prevent the EDGs from performing their function during accident mode of operation.
The endorsement of these IEEE standards does not add any new regulatory positions regarding design basis events (DBE), anticipated operational occurrences (AOOs), loss of offsite power (LOOP) with accident conditions.
Slide 14
Steps Towards Issuance
- Briefed ACRS subcommittee and received feedback.
- Briefed Committee to Review Generic Requirements (CRGR) on NEIs contentions of possible backfit
- Brief ACRS full committee.
- Issuance of new guide is expected in July.
Slide 15
Questions and Comments
?
Slide 16