ML21257A231
| ML21257A231 | |
| Person / Time | |
|---|---|
| Issue date: | 08/17/2021 |
| From: | Dennis Andrukat NRC/NMSS/DREFS/RRPB |
| To: | |
| Andrukat, Dennis | |
| References | |
| NRC-2017-0227, RIN 3150-AK19 | |
| Download: ML21257A231 (69) | |
Text
PUBLIC MEETING TRANSCRIPT
Alternative Physical Security Requirements for Advanced Reactors Rulemaking: Draft Guidance (Target Sets)
August 17, 2021 3:00pm-4:30pm ET
00:00:00.000 --> 00:00:29.200 Andrukat, Dennis So I just started the transcription of the meeting this will capture the bulk of the discussions. So you will see A at. Some point when we get that kind of finalized that will go into atoms as well so Please note that the chat feature in teams does not get included into the transcript. So I do encourage the participants to please speak up for their comments and questions.
00:00:33.340 --> 00:00:34.730 Andrukat, Dennis OK, so.
00:00:36.020 --> 00:00:56.980 Andrukat, Dennis Couple more logistical things before we kick it off here, so the quick background we are in the proposed rule phase. We're developing/drafting this particular rulemaking. There is a docket on regulations.gov that the public may go to to keep a status of what's going on with the r ule.
00:00:58.050 --> 00:01:07.260 Andrukat, Dennis There are currently, we have potentially 3 guidance documents, implementation guidance documents associated with this proposed rule.
00:01:08.020 --> 00:01:11.510 Andrukat, Dennis So we've just added this 3rd one so the main
00:01:12.560 --> 00:01:43.960 Andrukat, Dennis draft guidance will be this DG 1365. We have NEIs document that's going to be NEI 20-05. The current plan would be this DG 1365 would endorse the NEI document in addition to providing the specific guidance for the alternatives themselves. NEI 20-05 will focus on the guidance for what we're calling the eligibility criteria.
00:01:44.470 --> 00:02:01.110 Andrukat, Dennis For now, the 3rd, the new one, that [NRC] just added this DG 5071, here that is a potential to revise reg[ulatory] guide 5.81 regarding the target sets and so the target set being the focus of today's meeting.
00:02:10.390 --> 00:02:28.390 Andrukat, Dennis OK, so at this time, I want to turn it over to Stacy Prasad of the of the NRC she's in the interoffice here. She's been gracious enough to join our group and help us out and [particularly] to the target set discussion.
00:02:29.000 --> 00:02:30.860 Andrukat, Dennis So I will go ahead and.
00:02:31.850 --> 00:02:47.620 Andrukat, Dennis And shoot out a friendly reminder. This is a public meeting. This it's on physical security. But it is a public meeting. So we'll keep the discussions at the public level right so with that I'll turn it over to Stacy Thanks Stacy.
00:02:48.680 --> 00:02:51.220 Prasad, Stacy Hi thanks, Dennis can everyone hear me.
00:02:52.250 --> 00:02:52.990 Prasad, Stacy Good OK.
00:02:53.830 --> 00:03:24.450 Prasad, Stacy So I'm gonna do a little recap of what Dennis just said. So why are we here so NEI did provide us guidance in 20 oh 5 which was just discussed and that's a draft technical report titled the approaches were considerations with technical analysis to demonstrate compliance with the eligibility criteria that was my rewarding above the title So what we're here to do today is we' re proposing a slightly different approach to the terminology and the processes so right now. I'm going to try to go through the slides quickly without questions.
00:03:24.530 --> 00:03:49.130 Prasad, Stacy So, please take notes you will have an opportunity to ask questions at the end. I've just given this presentation a couple of times and a lot of the questions people ask or answer later or sometimes we get stuck really long on a slide so I want to make sure we're able to address everything we care to address today.
Once I've finished going through an I tend to talk a little qui ckly will start back at this slide and then open workshop portion where we'll have discussions on all the slides.
00:03:53.200 --> 00:03:54.430 Prasad, Stacy Alright next slide Dennis.
00:03:59.780 --> 00:04:05.740 Prasad, Stacy Alright so here is the first terminology target sets so we have a definition there that you take a look at.
00:04:06.700 --> 00:04:17.150 Prasad, Stacy Well, it's basically saying our target sets are the what is being analyzed and this is kind of independent of the eligibility criteria that's being used to implement the alternative security controls.
00:04:18.000 --> 00:04:34.880 Prasad, Stacy So this definition that you're seeing it's similar, but it's different to the current target set definition.
Remember, the general public. You might not have seen it because it's mainly captured in a security related information guidance document. However, it's also available in the statements of considerations that I will read it to you want to check it.
00:04:35.930 --> 00:04:42.340 Prasad, Stacy The difference for this one is that it addresses the different different performance objective for these reactor designs, which is the off-site release.
00:04:45.800 --> 00:05:02.160 Prasad, Stacy So the current definition is target sets include in part, the combination of equipment or operator actions, which if all are prevented from performing their intended safety function or prevented from being accomplished would likely result in significant core damage barring extraordinary action by plant operations.
00:05:02.780 --> 00:05:10.530 Prasad, Stacy So the biggest difference in this is we added the word structures, so these are the items that are going to prevent a potentially significant radiological release.
00:05:11.100 --> 00:05:30.210 Prasad, Stacy So we don't include this specific screening criteria and this is this means like the 25 rem because you can't determine that without performing the analysis were calling that screening for achievable which is the next slide little preview. We want to make sure the right elements are identified, and they're using those correct elements to perform your analysis.
00:05:33.970 --> 00:05:34.970 Prasad, Stacy Alright next slide.
00:05:38.370 --> 00:05:56.970 Prasad, Stacy Alright so this is a new definition, so achievable target sets or those targets at that may affect the specific measures that you need to implement the requirements of part 73. So these are specific to meeting the new beat the [10 CFR 73.55](b)(3) requirement related to an offsite those greater than reference values.
00:05:58.170 --> 00:06:25.470 Prasad, Stacy In the NEI guidance document 20-05, we also use the term achievable targets in that document. It's only applicable to the DBT [(design basis threat)] that's the way th e current [regulatory] guide 5.81, which is the NRCs reg[ulatory] guide for how to identify target sets also discusses what achievable means. So we're proposing is that achievable be expanded to, I to identify. Not exactly the same but very similar concepts to what's in the eligibility criteria.
00:06:28.750 --> 00:06:47.570 Prasad, Stacy Alright so we're still trying to say that you may determine that nothing is achievable. You could you add target sets you screen them at the end of the screen, and you could say hey? Nothing is achievable and then you may have determined that you do not need to account for these target sets in the design of physical protection program, which is a little different wording and the guidance that was provided to us.
00:06:50.220 --> 00:06:51.310 Prasad, Stacy About next slide.
00:06:57.180 --> 00:07:24.160 Prasad, Stacy So I did the red circles, so it was clear to identify if there's a lot of words. On this slide also includes the definition of targets that achievable targets that in the NEI guidance document so you can flip back and forth to see the differences between what we're proposing and what was proposed by the industry here. So we agree with most of the things on this table, but we do have concerns related to the circle part. The concern is that no targets that could result in unintended relief of targets that requirements.
00:07:24.350 --> 00:07:36.190 Prasad, Stacy And that's including identification requirements. We do understand a lot of the stuff in the requirements,[]
the industry does have in the guidance document, but we don't regulate through guidance.
00:07:37.630 --> 00:07:38.380 Prasad, Stacy So next slide.
00:07:44.200 --> 00:08:04.860 Prasad, Stacy This is another one that's very busy if you're trying to match up the actual requirements with the wording in the CFR. There are little different and that's just a high level. Analysis of what I find them to mean so we could talk about that. During the workshop portion if you want. But unlike the safety side of the house security procedures and processes may not have the same controls required.
00:08:06.290 --> 00:08:21.110 Prasad, Stacy So the intended target sets requirements is to ensure licensees are doing what is necessary to demonstrate compliance with [10 CFR 73.55](b)(3) for the life of the reactor in compliance with [10 CFR 73.55](b)(3) means the ability to meet the performance objective of preventing offsite dose great[er than] the reference values.
00:08:23.860 --> 00:08:29.810 Prasad, Stacy So we feel that these things are important enough to be required, and not address holding guidance so for example.
00:08:30.420 --> 00:08:36.660 Prasad, Stacy If it's determined that you have no target sets do you need to document and maintain that process user developing identify target sets?
00:08:37.490 --> 00:08:52.300 Prasad, Stacy Uh if you have no target sets our target. That's not considered an element that requires periodic review for effectiveness. If there is an equipment or facility change that could adversely affect security So what regulation will require review and what will that review be required of.
00:08:53.570 --> 00:09:24.130 Prasad, Stacy And the last thing, and kind of all the same points that you're probably going to ask, if there [are] no target sets, are you still required [to] have a process for the oversight of targets that equipment to ensure changes are considered and this is [] configuration changes so in accordance with the draft guidance provided by NEI if performance criteria is met for example, it's based on the design. You could determine that no targets exist.
A few years later. You could have an unanticipated design change or a change a piece of equipment that could call into the validity.
00:09:24.180 --> 00:09:40.530 Prasad, Stacy At the conclusion of the initial analysis, so what's going to require you to consider configuration changes to determine if the documented target sets need to be changed so that things called a target set. We want to make sure that there are processes in place are going to captur e design changes configuration changes.
00:09:41.410 --> 00:09:44.690 Prasad, Stacy I think I practice this so much. I'm starting to lose my voice, I apologize.
00:09:46.720 --> 00:09:47.610 Prasad, Stacy Alright next slide.
00:09:53.780 --> 00:10:20.170 Prasad, Stacy Right this one is a little easier. This is just very high level, making the point of development of target sets does not consider the success or the effectiveness of the licensees physical protection program so targets identification is not equivalent to the targets. That process determine[s] achievability and just like it's not equivalent to how the physical protection program accounts for the target sets so they were for this process.
We're considering targets. It's a starting point, and then the inputs to the analysis.
00:10:22.570 --> 00:10:23.490 Prasad, Stacy Alright next slide.
00:10:26.640 --> 00:10:35.560 Prasad, Stacy Right if you read a reg[ulatory] guide 5.81 or NEI 13-05 and th is looks familiar. We actually stole it from NEI 13-05.
00:10:36.180 --> 00:10:42.020 Prasad, Stacy So everything you see, there in black is what we currently use for guidance to identify target sets.
00:10:42.580 --> 00:11:01.250 Prasad, Stacy With the new performance objective. We had to add a little additional information. because you don't just stop it. Damn it, you have to also analyze the release pathways, so the first block that you see that's kind of jutting out to the right a specific to identifying the structures with release barriers So what needs to be compromised in order for a release to occur.
00:11:04.130 --> 00:11:19.750 Prasad, Stacy It's not red, but the second to last box in the end, that says screen for achievable and this is the one in the past with the only thing it considered was the DBT. We're proposing achievable also considers things similar to the eligibility criteria with the offsite dose.
00:11:20.880 --> 00:11:26.250 Prasad, Stacy And then we're hoping you might have to perform a consequence analysis until the very end.
00:11:27.210 --> 00:11:28.980 Prasad, Stacy So it might save you a little bit of work.
00:11:31.770 --> 00:11:33.420 Prasad, Stacy OK next slide.
00:11:34.550 --> 00:11:36.580 Prasad, Stacy This is much easier without any questions.
00:11:38.320 --> 00:12:03.780 Prasad, Stacy Alright so this is just very high level with the eligibility criteria are so for a or assuming the source is so small that you're never going to get an offsite really is greater than the reference doses. This may be able to be bounded by your safety analysis. If that indicates that there's no offsite release greater than the reference values and that you can't use any tactic to exacerbate the offs et consequences beyond that reference dose.
00:12:05.560 --> 00:12:11.710 Prasad, Stacy B, high level, is saying, Hey there's a way to make it happen, but is it achievable within the DBT.
00:12:12.730 --> 00:12:18.330 Prasad, Stacy See it's kind of saying it can happen, it's achievable from the DBT can you mitigate the release.
00:12:19.750 --> 00:12:33.870 Prasad, Stacy And then there's also the option is when you're going through the process to identify achievable. Target sets that you don't meet any of the 3 just discussed eligibility criteria and then that you would continue screening and performing a consequence analysis.
00:12:38.750 --> 00:12:39.610 Prasad, Stacy Next slide.
00:12:42.650 --> 00:12:53.780 Prasad, Stacy The next few slides I'm not going to go into gross detail. These are the ones that I'm hoping that we could work together to get some additional information to fill out for for what we actually want to see for each of the 3.
00:12:54.660 --> 00:12:57.200 Prasad, Stacy Eligibility criteria so next slide.
00:13:01.720 --> 00:13:15.890 Prasad, Stacy OK last draft of the language you probably saw had the word hypothetical at band. We change this to DBT initiated vent. This makes more sense and it's more clear and if it's not I'm sure we will discuss it when we go back through.
00:13:17.510 --> 00:13:19.200 Prasad, Stacy Alright next slide.
00:13:21.580 --> 00:13:40.700 Prasad, Stacy Like I said, before [Criterion] A is kind of the worst failure of all the identified elements and structure is given that design. Can you get a release greater than the reference t hose so this is the one you're potentially able to use your safety analysis, so that the analysis that you're going to perform at [§§] 50.34 or 50.17 or 52.79 to bound this.
00:13:41.840 --> 00:13:53.360 Prasad, Stacy In this you also have to look at any tactic that can make the e vent worse through the DBT so there's other things that you do have to consider that might not be in the sa fety analysis, which would mean it's not it's not bound.
00:13:54.500 --> 00:14:11.200 Prasad, Stacy So if this analysis shows that no target that could result in an off-site those greater than the reference values.
Then this step. You will have you will have identified that there are no achievable. Target sets so all the targets are screened out but they're still identified and documented in accordance with the target set requirements.
00:14:13.190 --> 00:14:25.640 Prasad, Stacy Uh if you determine it's not bound by the safety analysis, and it could mean a DBT tactic can be used to create greater consequences was analyzed in the safety analysis, the targets that process would continue next slide.
00:14:30.690 --> 00:14:59.020 Prasad, Stacy Alright so high level. This is kind of saying so, you have a bunch of Target sets for example, will say that all the targets that you identified our house. Under one structure that provides protection from the release pathway if it's determined that the DBT cannot penetrate this release pathway. It's not within their tactics or abilities.
Then in this step. You could screen out all targets at Ciel targets would be unachievable and screened out.
However, if that is not the case.
00:14:59.530 --> 00:15:01.250 Prasad, Stacy The target that process will continue.
00:15:02.850 --> 00:15:03.520 Prasad, Stacy Next slide.
00:15:07.400 --> 00:15:32.700 Prasad, Stacy This one, saying high level, we identify target set is compromised or there any additional actions that will prevent the off-site release above the reference doses if so those elements will be added to the targets at as elements and the targets that will be screened out as unachievable again. So if you can do that. You take mitigated in recovery actions at this step that prevent the off-site release. You be able to screen out all your targets is unachievable.
00:15:34.270 --> 00:16:03.180 Prasad, Stacy This criterion was the hardest to wrap my head around because there's a lot more flexibility in here, so there's things that have to be decided such as what time actions can occur? Are we going to align with the way RAPT is and have a specific like eight hours or is there a different time analysis? That's going to be done for these specific reactor types. We also have to determine what time you can screen out target sets based on time to reach the performance objective, which again we have a defined value for today.
00:16:03.910 --> 00:16:13.640 Prasad, Stacy We just need a line if or get more information to make an informed decision. If that's going to be a good number or if more analysis needs to be done to verify with accurate for these react.
00:16:16.350 --> 00:16:17.170 Prasad, Stacy Next slide.
00:16:20.520 --> 00:16:37.380 Prasad, Stacy So this is just high level based on what I've been saying the previous slides, saying that the [safety] analysis, that's already performed by the licensee for these new reactors, can potentially bound the conditions in the target [set]. If that's so you don't need to perform an additional consequences analysis.
00:16:39.270 --> 00:17:00.850 Prasad, Stacy If that's not the case and you find out that there's something that's not analyzed or not bound under the umbrella of the safety analysis, then either the NEI guidance. That was provided which has I think it's Section 4 and provides a wealth of information about the kind of conseq uent analysis. It should be performed or potentially NRC guidance for what would be considered in this consequences analysis.
00:17:02.310 --> 00:17:03.320 Prasad, Stacy Alright next slide.
00:17:06.310 --> 00:17:15.340 Prasad, Stacy Alright so this is just an example slide to say you're in your targets. That process you were not able to screen out. Target sets in the past three steps so this is what you're left with.
00:17:15.990 --> 00:17:30.390 Prasad, Stacy There's a big paragraph there. That's pretty much the same you have options for how how you can protect target sets so you can protect a subset like the minimum cut se tting the target sets or you could choose to protect every single element that target set it's up to you.
00:17:32.030 --> 00:17:38.380 Prasad, Stacy The example that I want to talk about is not specific to the example. I wrote so I decide quickly.
00:17:39.340 --> 00:17:54.380 Prasad, Stacy For targets at for the new reactors all these will be one. There are kind of separate into elements and release barriers just for the purposes of that being new. It's different than how it is today. So when you see the target set will be A, B, C[, and G]'s targets at number one for example.
00:17:55.020 --> 00:18:19.810 Prasad, Stacy umif all three of these targets that had the same release barr ier. So it's ait was golf[(G)] for targets at 1, 2, and 3. The Licensee could choose to only protect [G] because in protecting G [theyre] protecting against offsite release greater than reference values so there are more ways to do it in no way does the identification of achievable target sets mean that you need to protect every single element in this sets.
00:18:22.440 --> 00:18:23.410 Prasad, Stacy Kind next slide.
00:18:26.610 --> 00:18:32.930 Prasad, Stacy Right This is just a high-level slide of things we came across when reviewing the NEI guidance.
00:18:34.030 --> 00:18:36.090 Prasad, Stacy The first point been stressed a bunch of times.
00:18:36.650 --> 00:18:38.810 Prasad, Stacy Uhm target sets do exist.
00:18:38.970 --> 00:18:41.670 Prasad, Stacy Uh and we think they have to be identified.
00:18:42.240 --> 00:18:56.280 Prasad, Stacy Uh it's what's being analyzed so in the NEI document. It talks about them as equipment and actions or safety and security structure systems and components so the? What is still in the guidance we're just calling that what the target set?
00:18:57.340 --> 00:18:57.720 Prasad, Stacy Uh.
00:18:58.780 --> 00:19:21.290 Prasad, Stacy Next slide kind of says the same thing. It's the what the analyzed part. The eligibility criteria specific to these reactor types is the screening for Achievability again. That's a little different than today. The way NEI has it is a cheap ability is specific to the DBT, which is the wording currently in reg[ulatory] guide 5.81. We're kind of already veering off that path in today's world.
00:19:22.540 --> 00:19:42.750 Prasad, Stacy I mean, it was last year, the year before, but we introduce the concept of reasonable assurance protection time so that allows another way for licensees for light water reactors to screen out a target set so going down the path of achievable and screening is also being expanded today from what it was initially identified and Reg[ulatory] Guide 5.81.
00:19:44.270 --> 00:19:44.850 Prasad, Stacy Next slide.
00:19:52.250 --> 00:20:01.240 Prasad, Stacy And this is just saying same kind of thing eligibility criteria are specific if the target is achievable. What not we need to be identified in the analysis.
00:20:02.440 --> 00:20:29.270 Prasad, Stacy With respect to the security modeling tools. We think it can be used, but we think there may be a little more guidance that needs to be added to the NEI document for example, guidance to ensure the inputs and the constants are the calculations are specific to the licensee response and do not use military data for example, without determining if that bounds license use responds bottom line. We're interested in how the licensees physical protection program is protecting the site, not any other party.
00:20:31.330 --> 00:20:48.170 Prasad, Stacy One more thing I'm modeling tools specific for target Identification. This may only be applicable to credible operator actions and it recovery actions so the identification of what needs to be analyzed is independent of the success of physical protection program and there is that little caveat, they are for.
00:20:49.230 --> 00:21:00.080 Prasad, Stacy Credible operator actions, which defines 6 criteria that you need to meet for something to be credible on one of those is for [in]cluding interference and in that when we do allow some licensee response.
00:21:01.000 --> 00:21:02.370 Prasad, Stacy To determine timelines.
00:21:05.560 --> 00:21:06.430 Prasad, Stacy Alright next slide.
00:21:08.020 --> 00:21:11.080 Prasad, Stacy Right and they do a quick summary and then we're going to go back to where I started from.
00:21:12.140 --> 00:21:14.520 Prasad, Stacy because I'm sure there's a ton of questions.
00:21:15.680 --> 00:21:35.560 Prasad, Stacy So, in summary, we're all trying to achieve the same thing. The safety and security for all reactor designs on there also appears to be a general agreement on a couple of things, so that's the new performance objective of preventing offsite dose. But the reference values were an agreement that there needs to be some kind of analysis or documentation on this show, if the eligibility criteria are met.
00:21:36.660 --> 00:21:41.310 Prasad, Stacy And we're all in agreement that the licensee can determine that there are no achievable targets at so that is a possibility.
00:21:42.860 --> 00:22:03.550 Prasad, Stacy So the biggest Delta seems to fall around the definition of a target set so NEI is calling what needs to be considered for the consequences analysis and for eligibility criteria and Alpha in particular equipment and operator actions for this presentation. We call those equipment and operator actions at target set but the analysis is used to determine if the target is achievable.
00:22:05.760 --> 00:22:12.820 Prasad, Stacy The reason for the distinction and we think the distinction is extremely important is that we don't get unintended really from the target set requirements.
00:22:14.230 --> 00:22:28.990 Prasad, Stacy The I mean, I guidance does address some of the wording of the current target sat requirements. However, like I said, We don't regulate by guidance and target sets are the foundation of the physical protection program so they're kind of a big deal. There will be designed changes there will be modifications, there will be.
00:22:30.060 --> 00:22:45.980 Prasad, Stacy Digital asset upgrades, we want to make sure the regulation tha t equipment actions and combinations being analyzed are correct to determine if the eligibility criteria can be used to implement the alternative security requirements and that target sets are being reviewed and maintained like they should for the lifetime.
00:22:46.980 --> 00:22:48.370 Prasad, Stacy Of all reactor designs.
00:22:50.740 --> 00:23:08.540 Prasad, Stacy And like Dennis said before just please refrain from using specific examples. We don't go into Sri or safeguards area. None of this is set in Stone. I'm not saying everyone agrees with everything that's been said.
Even in the NRC but this is a good working product that we have and we're looking forward to get input from you guys today.
00:23:12.180 --> 00:23:42.640 Andrukat, Dennis Awesome yeah, thanks Stacey and I think we can circle back up h ere. But yeah, I think that's a good point, too. At the end, there, you know this. This is I think will com e to a good spot that we wanted to share with the public in the in the industry, this may not be the end all, be all for what the guidance or regulations end up being but this is kind of the point that where we're at now and so you know, we'd like to hear back from the public. The industry you know is.
00:23:12.530 --> 00:23:12.800 Prasad, Stacy Alright.
00:23:42.690 --> 00:23:46.220 Andrukat, Dennis I'd like to start mostly with it NEI since this is NEI
00:23:47.220 --> 00:23:53.920 Andrukat, Dennis helping us with the guidance and this is something that we really need to get this proposed rule kind of out the door, but by no means.
00:23:55.210 --> 00:23:59.140 Andrukat, Dennis Does that mean? We don't want to hear from the rest of the publ ic as we want to hear from everyone.
00:23:59.940 --> 00:24:03.430 Andrukat, Dennis So state you want me to run back up to what the slide slide 5 f or you.
00:24:05.560 --> 00:24:07.300 Prasad, Stacy Yeah, 55 or 6 works.
00:24:07.750 --> 00:24:08.030 Andrukat, Dennis OK.
00:24:09.250 --> 00:24:10.080
+12*******46 (David Young) [David Young, NEI]
Hey Dennis,
00:24:11.040 --> 00:24:12.040 Andrukat, Dennis Yes, there. Is this David?
00:24:12.700 --> 00:24:22.410
+12*******46 (David Young) yeah, it is, he I had one quick question if I may just before we start to launch into all these a slide sequentially. I just want to understand one term if you go to slide 14.
00:24:22.750 --> 00:24:23.280 Andrukat, Dennis Sure.
00:24:23.500 --> 00:24:38.180
+12*******46 (David Young)
Uh so Stacy you had mentioned there or you, said from the slide hypothetical event. That's the text. You have there in red? Did you mean hypothetical and mitigated that's th e term? I think that the is that the term referring to that's currently in the pose languages hypothetical and mitigated event.
00:24:38.770 --> 00:24:42.680 Prasad, Stacy Yeah, so far into the language currently in the proposed language.
00:24:42.130 --> 00:24:45.420
+12*******46 (David Young)
OK, so you met hypothetical unmitigated OK great thank you. Thank you.
00:24:45.950 --> 00:24:46.500 Andrukat, Dennis Scrap.
00:24:47.850 --> 00:25:12.280 Andrukat, Dennis Yeah, and we're in you know, kind of in tandem with with the ta rget set specific type of start a conversation that we're having we are also continuously you know massage ING the rule text that was kind of last released right to include you know unmitigated hypothetical. But yes tha t that is the part of Criterion, a list at work.
00:25:03.780 --> 00:25:04.200
+12*******46 (David Young)
Uh-huh.
00:25:11.810 --> 00:25:14.300
+12*******46 (David Young)
That's the term OK alright thank thank you. Thank you.
00:25:20.790 --> 00:25:21.510 Andrukat, Dennis OK.
00:25:25.920 --> 00:25:26.380 Andrukat, Dennis So.
00:25:26.550 --> 00:25:27.720 Prasad, Stacy Go to the next slide Dennis.
00:25:27.860 --> 00:25:28.450 Andrukat, Dennis Sure.
00:25:32.900 --> 00:25:36.880
+12*******46 (David Young)
Well, that's not how do you should we just launch into here is that is that what you'd like us to do?
00:25:37.230 --> 00:25:49.830 Andrukat, Dennis Yeah, I was just about to say you know, I know you guys haven't really had very much time to to kind of see these so if you guys want it. I don't know if you guys wanted to kind of read these real quick, but yes, please.
00:25:50.840 --> 00:25:56.430 Andrukat, Dennis Feel free just to kind of time in this is workshop style if you will.
00:25:55.760 --> 00:25:56.540
+12*******46 (David Young)
Yeah, OK.
00:25:58.200 --> 00:25:59.000 Andrukat, Dennis We're kind of.
00:25:58.540 --> 00:25:59.030
+12*******46 (David Young)
Right.
00:26:01.180 --> 00:26:19.450
+12*******46 (David Young)
OK, well good well again this is David Young NEI and, Stacy,, thank you for that presentation. I thought I talk fast. But you beat me, first all that was yeah, so there's obviously a lot of there's some different thinking here. Obviously applied to some of these terms and approaches and concepts than what we've been.
00:26:19.920 --> 00:26:24.760
+12*******46 (David Young)
Uh you know, thinking here on our side for awhile so it's going to take some time. I think for us to digest.
00:26:26.210 --> 00:26:36.850
+12*******46 (David Young)
And get a better understanding of some of the points you're making here in some of the distinction. So I'm not even sure don't be able to ask a lot or even the right questions. Today can still trying to digest and understand some of the concepts that willwhat will give it our best shot.
00:26:37.090 --> 00:26:37.930 Andrukat, Dennis Absolutely.
00:26:37.580 --> 00:26:38.230
+12*******46 (David Young)
Uh.
00:26:39.430 --> 00:26:42.710
+12*******46 (David Young)
OK, so I guess the first question I had on at least on this slide.
00:26:44.290 --> 00:27:01.560
+12*******46 (David Young)
So, in the target set definition you know, barring extraordinary actions by plant operations could result in a potentially significant radiological release. I guess kind of two-part question there. What did you mean by potentially significant radiological release and how do? I determine that in advance of a consequence analysis?
00:27:03.290 --> 00:27:04.240 Prasad, Stacy Good questions.
00:27:05.240 --> 00:27:08.560 Prasad, Stacy We had similar questions and developing this definition.
00:27:09.130 --> 00:27:39.720 Prasad, Stacy Uh so that could result in potentially significant can mean different things. Different people those phrases took many, many meetings to eating the even get there? What we're trying to say is address the things that you think you need to analyze it determine if the performance criteria B 3 or the eligibility criteria and or are met. So I'm not sure what the exact words are but we want to ma ke sure that you're analyzing everything that could be closed. We don't want to put this specific we pot entially don't wanna put this specific performance criteria in the 25 gram.
00:27:39.770 --> 00:28:10.260 Prasad, Stacy In there because we don't want you to be able to screen out and say no target sets and get unintended really, for the targets that requirement so this is trying to say look at the things that you think are going to be important kind of what current target sets. You start somewhere. Right you start with PRA you start with your safety nails. If you start somewhere. And you say. Hey these ones look like they might result in significant core damage so for this? It would be hey. These are the elements that we think might result in a potentially significant rheological really, really so it's.
00:28:10.380 --> 00:28:11.360 Prasad, Stacy Things that you think.
00:28:11.910 --> 00:28:28.290 Prasad, Stacy My end up being achievable target sets. There's definitely a better way to say that that's what we're trying to say there. We don't want to exclude things that are closed that need to be analyzed. What we don't want you to also screen out in this point before the target that's identified does that make sense.
00:28:29.700 --> 00:28:48.180
+12*******46 (David Young)
Yeah, I think so, so just this morning common language. I what I'm hearing. You say is I have? Maybe I have some some target elements. I haven't particular set and I look at those and I say, boy, if all this stuff goes away. I'm just not going to get any kind of meaningful offsite dose. So I can I can not have to worry about that particular combination is that is that kind of what you're saying?
00:28:48.560 --> 00:29:03.420 Prasad, Stacy Correct you have to start somewhere right so we're expecting you to take a good educated guess. But it could be the same thing where if it inspector. The NRCS look at your analysis and says hey? Why don't you consider this grouping up things there all the things that you think?
00:29:04.500 --> 00:29:15.300 Prasad, Stacy We would want to see her that would be close. There's a better way to say that, but this is trying to say you don't look at everything but look at this stuff that's likely to challenge you meeting the performance criteria.
00:29:16.450 --> 00:29:22.540 Andrukat, Dennis Is this before applying any kind of screening right an or?
00:29:22.860 --> 00:29:23.260 Andrukat, Dennis Uh.
00:29:24.580 --> 00:29:29.950 Andrukat, Dennis I guess analysis at least in regards to to this rulemaking eligibility criteria right.
00:29:30.620 --> 00:29:34.660 Prasad, Stacy Correct so this is your initial best guess your identification part.
00:29:35.570 --> 00:29:41.460 Prasad, Stacy
[And your] grouping of different stuff, so in the NEI guidance, you guys do the same thing right.
00:29:42.020 --> 00:30:10.780 Prasad, Stacy So, in your section for eligibility criterion a you say you're doing the analysis of equipment and operator actions in your consequences analysis right and your figure. One also says safety and security. SSE 's so I don't think you met your looking starting from scratch and doing every single thing in a plant right you're making an informed guess for the equipment and the operator actions and those combinations that you're looking at your consequences analysis were asking for the same, the same level here.
00:30:12.820 --> 00:30:15.270
+12*******46 (David Young)
OK, alright, so sounds like again, this is really more of [Criterion] A.
00:30:15.470 --> 00:30:26.090
+12*******46 (David Young)
Uh it's more of a qualitative assessment based on my knowledge of the plant design and what kinds of releases I might be able to get but at this point, I'm not expected to do any kind of.
00:30:26.140 --> 00:30:28.930
+12*******46 (David Young)
Of quantitative analysis.
00:30:29.550 --> 00:30:31.560
+12*******46 (David Young)
Consequence analysis is is that right.
00:30:31.830 --> 00:30:32.370 Prasad, Stacy Correct.
00:30:32.120 --> 00:30:33.790
+12*******46 (David Young)
OK, OK.
00:30:33.550 --> 00:30:43.560 Prasad, Stacy That's we're proposing I know you're the NEI guidance discussed is doing. The consequences analysis for
[Criterion] Alpha and Charlie right up front we're saying maybe you don't need to do that.
00:30:45.910 --> 00:30:52.260
+12*******46 (David Young)
Now, some say this is all different way of thinking so I'm kind of struggling to make sure we're asking the right questions here. This this is a little bit different way of looking at it.
00:30:53.200 --> 00:30:55.720 Prasad, Stacy Yeah, I think everything is very.
00:30:53.820 --> 00:30:54.540
+12*******46 (David Young)
OK, so.
00:30:56.840 --> 00:31:06.860 Prasad, Stacy Not all the concepts, but in general, I think we're in alignment with a lot of the processes that we're trying to do, we're just making distinctions to target set and achievable target set.
00:31:07.520 --> 00:31:09.940 Prasad, Stacy That's different than the NEI guidance.
00:31:11.670 --> 00:31:12.970
+12*******46 (David Young)
OK, Alright.
00:31:15.150 --> 00:31:23.450
+12*******46 (David Young)
OK, I think that's all I had on t his slide, but but Dennis another you know interested stakeholders have any other questions on this slide, we go to the next one.
00:31:24.640 --> 00:31:30.690 Andrukat, Dennis Sure, I don't see any hands raised, but I'll give it a few seconds in case someone else would like to chime in.
00:31:39.340 --> 00:31:43.790 Andrukat, Dennis OK, not seeing any let me go on to the next slide here for you guys.
00:31:47.250 --> 00:31:50.180
+12*******46 (David Young)
OK, just yeah, just give me something to read this one more tim e sometimes.
00:31:50.310 --> 00:31:50.830 Andrukat, Dennis Sure.
00:31:53.070 --> 00:31:54.190
+12*******46 (David Young)
Greater than the gun.
00:31:59.220 --> 00:32:09.080
+12*******46 (David Young)
So here so here says heso you know here. We do reference the doseOK, so dose value. So is the so the achievable target set.
00:32:09.690 --> 00:32:12.820
+12*******46 (David Young)
Concept and what only comes into play.
00:32:14.890 --> 00:32:17.730
+12*******46 (David Young)
Only comes into play after I've done the consequence analysis.
00:32:19.990 --> 00:32:34.190 Prasad, Stacy No, we're trying to say that could happen before too. If depending on how it aligns with the eligibility criteria so all these three things need to be met if it's achievable to be unachievable.
00:32:34.660 --> 00:32:36.820 Prasad, Stacy It it, they would be or statements right.
00:32:37.180 --> 00:32:40.630 Prasad, Stacy Uh so as you're going through the process of targets.
00:32:39.420 --> 00:32:41.530
+12*******46 (David Young)
Oh, I see right right.
00:32:41.350 --> 00:32:41.810 Prasad, Stacy Yeah.
00:32:42.080 --> 00:32:42.780
+12*******46 (David Young)
I'm sorry go ahead.
00:32:44.080 --> 00:32:47.230 Prasad, Stacy I think that was it, I was probably repeat myself in a different way that was confusing.
00:32:47.380 --> 00:32:48.850
+12*******46 (David Young)
OK, right so this is the.
00:32:49.600 --> 00:32:54.270
+12*******46 (David Young)
And result of OK if you're a process where I've determined.
00:32:55.130 --> 00:33:01.260
+12*******46 (David Young)
OK, so I've gone through all these steps and and the conclusion is OK. I haven't actually I haven't achieved target set.
00:33:02.920 --> 00:33:12.910 Prasad, Stacy Yeah, you would only have an achievable target set if you didn't screen out in any of the other 3 or meet any of the other 3 eligibility criteria.
00:33:14.520 --> 00:33:19.020 Prasad, Stacy
'cause in meeting the eligibility criteria and how it aligns with the targets that process.
00:33:20.230 --> 00:33:27.330 Prasad, Stacy If you met it in your screen. Everything out your determine everything is unachievable right so you wouldn't have any achievable target sets.
00:33:29.240 --> 00:33:31.000
+12*******46 (David Young)
Right right.
00:33:32.710 --> 00:33:43.150
+12*******46 (David Young)
OK. Again, I'm just struck by you know, I guess a lot of it is again going to be very important on that first step.
We just talked about in the previous slide when you sort of do this qualitative assessment.
00:33:43.880 --> 00:33:47.780
+12*******46 (David Young)
Uh your initial bounding and grouping of these things too.
00:33:49.090 --> 00:33:53.160
+12*******46 (David Young)
Yeah, I guess you know if you think you could even be anywhere near the threshold you'd have to.
00:33:54.070 --> 00:33:58.720
+12*******46 (David Young)
Screen that into you know OK. I'm sorry. I'm thinking out loud here, so I'm just trying to.
00:33:59.340 --> 00:34:00.430
+12*******46 (David Young)
By my head around this.
00:34:02.410 --> 00:34:02.960
+12*******46 (David Young)
Yeah.
00:34:03.220 --> 00:34:06.900 Andrukat, Dennis Yeah, no this is good here right so it's a she.
00:34:07.180 --> 00:34:17.490 Andrukat, Dennis Uh can correct me if I'm wrong right so you know the way I guess I. I was thinking about it targets are coming your kind of your input your list of stuff that you're going to start.
00:34:18.570 --> 00:34:27.590 Andrukat, Dennis That you think you that you at least need to analyze you know i n some cases, maybe some of this stuff even though you may not have something.
00:34:28.140 --> 00:34:51.890 Andrukat, Dennis Definitive that says, I don't know I don't think that's going to be. You know, maybe possible you know, maybe that would still be included in the target set as your starting point and then as you start you know your analysis, which includes these proposed screen outs. That Stacy was talking about you know, and maybe it also might require a consequence analysis right so I think the use of screening out.
00:34:52.580 --> 00:35:05.870 Andrukat, Dennis Kind of helps stave off maybe doing a consequence analysis, which which I think might be burden reduction of sorts and helpful, but you know.
00:35:06.760 --> 00:35:16.560 Andrukat, Dennis So there's ways to to kind of narrow it down from a target set to achievable target set without doing a consequence in that list. So I don't know so I don't know if that's helpful.
00:35:17.450 --> 00:35:18.400
+12*******46 (David Young)
OK, you know.
00:35:20.570 --> 00:35:33.780
+12*******46 (David Young)
Yeah, again, she's just trying to I'm just trying to I think it's like people aren't here on the call just trying to kind of think about this little bit differently than some of the framework. We've been thinking about it before, but OK no. I I at least I think I understand this slide. So far unless anybody else, has any questions on this one.
00:35:36.250 --> 00:35:37.020 Andrukat, Dennis And I think.
00:35:38.350 --> 00:35:54.530 Andrukat, Dennis Just because you have something in this scheme here that we're presenting today just because something is listed as a target set doesn't necessarily mean at the end. It's going to have to get protective right. It's it's the starting inputs, if you will.
00:35:54.580 --> 00:36:10.630 Andrukat, Dennis Uh and then you have to it has to then get through the achievab le target set step right and then a Stacy kind of talked about it a little earlier, even after that, you know you still make a decision on what needs to be protected.
00:36:14.220 --> 00:36:14.700 Andrukat, Dennis OK.
00:36:14.460 --> 00:36:14.900
+12*******46 (David Young)
OK.
00:36:15.710 --> 00:36:16.240
+12*******46 (David Young)
Sorry.
00:36:16.570 --> 00:36:24.100 Andrukat, Dennis I'll give it a little just a few seconds here in case someone else would like to chime in on the achievable target set slide here.
00:36:25.900 --> 00:36:30.520 Prasad, Stacy I'm gonna say one more thing and then I'm not sure about doctor. Lyman still had a question because I saw his hand up.
00:36:31.110 --> 00:36:32.270 Prasad, Stacy Come what may
00:36:32.320 --> 00:36:49.880 Prasad, Stacy be a help to make it a little more senses target sets and the targets that requirement specifically in [10 CFR]
73.55(f)(1) through (4) and then the applicability of [10 CFR] 73.55 would be applicable to the identification of targets period.
00:36:51.160 --> 00:37:14.330 Prasad, Stacy
[10 CFR] 73.55 Bravo pour and I'll read it real quick so the licensee shall analyze and identify site specific conditions, including target sets that may affect the specific measures needed to implement the requirements of this section [and should] account for those conditions [] in the design of physical protection program so if you determine everything is unachievable. Then you will have determined that they may not affect the specific measures needed.
00:37:14.620 --> 00:37:23.380 Prasad, Stacy Uh so you do have the target sets, but you're determining they're not achievable. They're not going to affect the design of the physical protection program or they may not.
00:37:24.170 --> 00:37:25.310 Prasad, Stacy With the actual.
00:37:26.080 --> 00:37:26.950 Prasad, Stacy Bro language.
00:37:29.360 --> 00:37:30.890 Prasad, Stacy Doctor Lyman did you solve the question?
00:37:32.800 --> 00:37:37.270 Edwin Lyman Yeah, yeah, thanks for thanks for asking.
00:37:38.820 --> 00:37:46.770 Edwin Lyman So at this stage there's still no time limit the assumption is that the adversary would have an infinite amount of time to do what they want to do.
00:37:47.800 --> 00:37:48.290 Edwin Lyman Is that?
00:37:50.940 --> 00:38:22.370 Prasad, Stacy That would have to be determined if you go to the slides. We ta lk about the 3 eligibility criteria so for Charlie in particular. That talks about mitigation and recovery actions. So I don't think it's been decided or specifically discussed for when we're allowing free movement based on offsite assistance or at what time we're expecting the licensee on their own, without offside assistance to meet the at all times. So it's a similar process. I think you were involved in it, a lot, that we did fo r reasonable sure protection time.
00:38:22.830 --> 00:38:31.040 Prasad, Stacy I met with something similar will have to be done here. If we don't use the same exact process that we use for for the wrapper light water reactors.
00:38:32.880 --> 00:38:37.250 Andrukat, Dennis And I guess this is Dennis I guess I would I would add to that.
00:38:38.730 --> 00:39:07.960 Andrukat, Dennis You know any of the analysis rife Arabian Sea obviously would have matched what the facility right so for instance, if you're trying to invoke this proposed rule right you're going through this eligibility criteria such that you're eligible to then utilizing any of these alternatives that are in the other half of this rule right one of which is is trying to have zero on site responder so that's kind of where you get that then.
00:39:09.200 --> 00:39:31.790 Andrukat, Dennis Then that would have to be reflected in the analysis. Here, if you get to that step. You know if that makes any sense right like you can't sit there and say, I'm going to invoke zero insight responders, but then your eligibility criteria. If you're saying Charlie is relying on onsite responders like that would make sense.
00:39:34.370 --> 00:39:36.520 Edwin Lyman Right so if you wanted.
00:39:38.380 --> 00:39:39.800 Edwin Lyman If you want it to site.
00:39:40.450 --> 00:39:41.780 Edwin Lyman Criterion B.
00:39:42.430 --> 00:39:56.380 Edwin Lyman And then you would that would mean that essentially the adversa ry would have [] as much time as they wanted to try to...to try to because this offsite release and they can't do it right no matter how much time they have.
00:39:57.090 --> 00:39:57.400 Edwin Lyman With.
00:40:01.030 --> 00:40:04.800 Edwin Lyman because it just says whatever they do they can't achieve a target set?
00:40:06.710 --> 00:40:09.160 Edwin Lyman And it just sounds like it doesn't have any time limit.
00:40:10.770 --> 00:40:15.130 Prasad, Stacy I'm going to tentatively say yes just in case I'm missing a nuanced.
00:40:15.680 --> 00:40:27.320 Prasad, Stacy But yeah, it's pretty much a saying there's no tactic or measure. That's available within the DBT that will allow that potential to happen, either from damage to a source or from damage to release pathway.
00:40:29.180 --> 00:40:37.320 Prasad, Stacy And the DBT is in regulation at all times. So I don't think the re's a specific to that it's just really is was is what?
What's
00:40:37.910 --> 00:40:42.810 Prasad, Stacy in the DBT toolbox available to cause to cause damage.
00:40:41.250 --> 00:40:41.700 Edwin Lyman Right.
00:40:43.950 --> 00:41:06.700 Edwin Lyman Right now, I guess the because the the peculiar thing is that if and again. It is the case where you have no no onsite responders so essentially have free run of the plant forever and that case you can imagine that they could bring in reinforcements right that they wouldn't have to be within the confines of a single attack and so it just.
00:41:08.520 --> 00:41:19.590 Edwin Lyman I mean, it weren't getting it is. I don't think there's any rea listic way than any applicant could could cite this or you know be received this exemption, but
00:41:20.760 --> 00:41:23.360 Edwin Lyman but again, I think there are there other issues.
00:41:24.150 --> 00:41:31.230 Edwin Lyman I mean because it's unrealistic to begin with you can imagine all sorts of other possibilities. Alright would think so. That's my point.
00:41:33.260 --> 00:41:47.200 Andrukat, Dennis Now that's a good point, yeah, I I know we kind of on our end. We've kind of. We've talked about that idea, especially easier, one for us was or at least for me, it was criterion a thinking about that.
00:41:48.470 --> 00:41:55.130 Andrukat, Dennis You know you're right they would you know everyone would have to be able to justify but the thought process being you know the?
00:41:56.730 --> 00:42:05.430 Andrukat, Dennis If the plant you no matter what you did to it, you know, regard less of time now, I think time is something that that.
00:42:06.250 --> 00:42:10.790 Andrukat, Dennis I mean, I wouldn't say we that we fully agreed upon but.
00:42:11.870 --> 00:42:27.720 Andrukat, Dennis For all intensive purposes. Most of our conversations have talked about you know, maybe an infinite possibility. But that doesn't mean that's what's going to happen in the end, especially considering some of the other sister activities that that are that are happening th is AC just talked about.
00:42:30.430 --> 00:42:30.980 Edwin Lyman OK.
00:42:35.130 --> 00:42:36.650 Andrukat, Dennis Let me go back up here.
00:42:44.800 --> 00:42:47.220 Andrukat, Dennis OK, so I think we're on to this slide now.
00:42:49.640 --> 00:42:50.140
+12*******46 (David Young)
OK.
00:42:50.380 --> 00:42:53.910 Andrukat, Dennis I'll I'll start with with you if you have time to read.
00:42:55.740 --> 00:43:00.010
+12*******46 (David Young)
Yeah, I guess just only comment. I had here was, I'm sorry David Young, NEI.
00:43:01.430 --> 00:43:08.930
+12*******46 (David Young)
So sounds like here's Stacy that the part that was circled here that now was was kind of also the jumping off point for this.
00:43:09.670 --> 00:43:14.490
+12*******46 (David Young)
Development of this alternative thinking this alternative approach where the target sets.
00:43:15.600 --> 00:43:22.840
+12*******46 (David Young)
Uh I'll share more centrally considered, and drive the process is that kind of what? What started this whole rethinking.
00:43:23.830 --> 00:43:41.430 Prasad, Stacy It's one of the reasons there was a lot of factors in the working group that we were discussing but in answer in particular. We took heartburn with the no target sets and th e potential unintended relief from the requirements that address configuration changes and design changes.
00:43:43.870 --> 00:43:45.820
+12*******46 (David Young)
OK so it's both of those things all right.
00:43:46.660 --> 00:43:47.130
+12*******46 (David Young)
OK.
00:43:50.410 --> 00:43:53.110
+12*******46 (David Young)
Alright that's all I had on this one is.
00:43:54.450 --> 00:43:54.930 Andrukat, Dennis OK.
00:43:55.590 --> 00:44:01.000 Andrukat, Dennis We have a couple of seconds in case anyone else wants to wants to chime in please. Feel free to chime in.
00:44:09.670 --> 00:44:11.770 Andrukat, Dennis Can I go into the next year?
00:44:17.280 --> 00:44:19.210 Andrukat, Dennis I suspect there may not be too much.
00:44:19.260 --> 00:44:23.520 Andrukat, Dennis Uh here, although that the the concept.
00:44:23.970 --> 00:44:27.500 Andrukat, Dennis So I think it's uh helps help describe.
00:44:28.640 --> 00:44:31.260 Andrukat, Dennis Why we're calling the target sets you know?
00:44:33.300 --> 00:44:37.930 Andrukat, Dennis The starting point, the target sets a zip code, which is I think a little different. Then then what you guys were thinking.
00:44:39.540 --> 00:44:43.050
+12*******46 (David Young)
You know, I I think I think the slides helpful to the extent that you know when.
00:44:44.430 --> 00:44:55.380
+12*******46 (David Young)
When Stacy makes a comment about unintended relief. I'm assuming all these in the requirements that she's got in line so that's helpful for everybody to understand the context of her.
00:44:56.230 --> 00:44:58.350
+12*******46 (David Young)
Statement thereso this is helpful.
00:45:03.500 --> 00:45:05.490 Andrukat, Dennis Not seeing anyone else.
00:45:08.090 --> 00:45:10.380 Andrukat, Dennis If it's OK, I'm gonna go ahead and go on to the next slide.
00:45:23.300 --> 00:45:26.270
+12*******46 (David Young)
Yeah, Stacy, David Young, NEI, could you maybe just?
00:45:28.280 --> 00:45:30.630
+12*******46 (David Young)
Maybe just call this slide just one more time just.
00:45:31.750 --> 00:45:37.630
+12*******46 (David Young)
Talk to it again and you want to keep points that you were wanting to make on this one just to make sure I would just make sure I understand it.
00:45:39.920 --> 00:45:40.390 Prasad, Stacy Sure.
00:45:42.470 --> 00:45:44.870 Prasad, Stacy Right so this was just supposed to be a high level.
00:45:45.070 --> 00:45:49.670 Prasad, Stacy Uhm success with the licensees physical production program whether that be.
00:45:49.720 --> 00:46:02.610 Prasad, Stacy The the guards or whether that be the insider mitigation program are not directly related to the identification of what a target set? Is there more the ways for how you're protecting the targets at.
00:46:06.110 --> 00:46:08.210 Prasad, Stacy Does that clarify it at all or no?
00:46:08.450 --> 00:46:16.950
+12*******46 (David Young)
Well was was this, I mean was this comment or this slide was was or something was there. Something in our proposed guidance that that you thought said otherwise.
00:46:18.020 --> 00:46:21.550
+12*******46 (David Young)
I'm trying to understand the context for why this was set in the presentation.
00:46:22.320 --> 00:46:44.790 Prasad, Stacy Either something specific to the insider mitigation program that we weren't sure exactly what was meant so we just wanted to clarify that when we're saying, You're identi fying a target that you're not saying. Hey, are guard forces going to be great every day and keep everyone else. So, therefore, we don't have any target sets or hey. We have an insider mitigation program that's great, so we don't have any target sets.
00:46:46.170 --> 00:46:51.350 Prasad, Stacy That's what we were trying to say. I don't know if that's the way it was intended in the NEI guidance, but we just want to make sure that was clear.
00:46:52.140 --> 00:46:58.280 Andrukat, Dennis So so David this is Dennis you know, I'm here, yeah, so you know, we had a uh.
00:46:59.040 --> 00:47:19.160 Andrukat, Dennis You know one of our previous public meetings in there. We kind of talked about it and I think it was criterion a we were focusing at the time and I think there was some some comments made about how maybe Carty Renee could credit say Insider Mitigation Program, or the cyber security program.
00:47:21.050 --> 00:47:32.830 Andrukat, Dennis You know, so I don't know if this helps kind of clear it is not speaking specifically to criterion here, which is what we talked about before, but I don't know if that kind of h elps clarify.
00:47:34.040 --> 00:47:35.760 Andrukat, Dennis Maybe some of your thoughts on that.
00:47:40.120 --> 00:47:44.440
+12*******46 (David Young)
Is a way to protect elements but not to die so release?
00:47:45.330 --> 00:47:49.240
+12*******46 (David Young)
OK, I mean, yeah, I I mean, I as I'm reading it. I'm I'm.
00:47:50.100 --> 00:47:50.610
+12*******46 (David Young)
I don't.
00:47:51.650 --> 00:47:59.840
+12*******46 (David Young)
I mean, it makes sense to me, I'm just not sure I guess. I want to go back and look at [NEI] 20-05 to see maybe what? What it was we said that that may have suggested somethin g different so.
00:48:02.680 --> 00:48:03.290 Andrukat, Dennis Sure.
00:48:04.250 --> 00:48:07.030 Cubellis, Louis It is. Dennis, its Lou. May, I may I say something.
00:48:06.120 --> 00:48:06.530 Andrukat, Dennis Hello.
00:48:07.330 --> 00:48:07.930 Andrukat, Dennis Yes, Sir.
00:48:08.790 --> 00:48:40.730 Cubellis, Louis Yeah, David, Good afternoon, just want to add something that wh at Stacy said earlier specifically things like crediting insider mitigation or cyber security program any of those types of programs. Access authorization in the in the analysis. It really doesn't there's really no credit. I mean, it almost appeared to some staff that there was an attempt to removed characteristics from the consideration so for example.
00:48:41.210 --> 00:49:14.040 Cubellis, Louis Through Insider Mitigation program, the credit would be not considering active insiders that are part of the DBT in [10 CFR Part] 73. One and So what we're what we're tryin g to say is really the in the analysis sense or identification sense. There really isn't any credit for those things. Those programs mitigate the threat. They do not eliminate the threat and so those characteristics still need to be considered and analyzed.
00:49:17.600 --> 00:49:18.690 Cubellis, Louis Does that make sense?
00:49:17.870 --> 00:49:20.200
+12*******46 (David Young)
OK lunar that that that's helpful.
00:49:22.100 --> 00:49:35.550
+12*******46 (David Young)
Yeah, I mean, I guess we were when we coming for the right heard that guidance was sort of intended to shape the kinds of things you need to look at when you do the analysis. It wasn't meant to exclude things.
00:49:36.840 --> 00:49:41.270
+12*******46 (David Young)
But but what you said again clarified that so we will take a look at that text too.
00:49:43.450 --> 00:49:45.360
+12*******46 (David Young)
You know, see what changes we might need to make on that.
00:49:46.270 --> 00:49:47.930 Cubellis, Louis Great, thanks David I appreciate it.
00:49:48.950 --> 00:49:49.780
+12*******46 (David Young)
Yeah, thank you Lou.
00:49:52.090 --> 00:49:53.680 Andrukat, Dennis Awesome OK.
00:49:54.480 --> 00:49:57.950 Andrukat, Dennis I'll spend a couple seconds here, I'm not seeing anyone.
00:50:01.380 --> 00:50:03.870 Andrukat, Dennis Yeah, I'm gonna go ahead and go on to the next slide.
00:50:11.330 --> 00:50:14.470
+12*******46 (David Young)
But what this might be with one second, I'm just taking some notes here hold on a second.
00:50:14.830 --> 00:50:15.530 Andrukat, Dennis Sure, sure.
00:50:16.560 --> 00:50:20.040
+12*******46 (David Young)
OK, OK.
00:50:25.370 --> 00:50:26.290
+12*******46 (David Young)
Right OK.
00:50:30.460 --> 00:50:39.240
+12*******46 (David Young)
So just to clarify on I'm sorry, David Young, NEI, just to clarify the identify the target set elements again is sort of this, this first cut.
00:50:39.310 --> 00:50:42.610
+12*******46 (David Young)
Uh a qualitative assessment.
00:50:43.180 --> 00:50:46.080
+12*******46 (David Young)
Uh combinations that I think could.
00:50:46.760 --> 00:50:48.900
+12*******46 (David Young)
You could get close to or exceed.
00:50:49.840 --> 00:50:51.680
+12*******46 (David Young)
The dose limits.
00:50:52.940 --> 00:50:57.260
+12*******46 (David Young)
That's what I would be expected to do is as part of Step 3, is that is that right Stacy.
00:50:58.190 --> 00:51:22.440 Prasad, Stacy Uh correct and these aren't in stone, the way I'm looking at th is now and thinking that maybe the one red box? Do identify release barriers, which are the structures should be before Step 4, potentially but yeah, high level. What you said. That's what we're looking for in the guidance identify what you need to identify that you think might be an issue generate your target sets and then you're going to start the screening process, which is which is the analysis part.
00:51:24.090 --> 00:51:41.750
+12*******46 (David Young)
OK and then the subsequent step after that consequence analysis is in the end now. I do this full blown consequence analysis. I get a conclusion and if I'm still below, those limits, then I'm off to one sort of criteria or one set of requirements or from above it then I'm off to a different set of requirements that.
00:51:42.480 --> 00:51:44.590
+12*******46 (David Young)
Specially in resolving the consequence analysis.
00:51:45.890 --> 00:51:47.120 Prasad, Stacy Yeah, pretty much.
00:51:47.280 --> 00:51:49.050
+12*******46 (David Young)
Yeah, OKOK.
00:51:51.740 --> 00:51:52.170
+12*******46 (David Young)
OK.
00:51:53.320 --> 00:52:07.830 Andrukat, Dennis So Stacy for Criterion A, that's kind of a screen-out/off-ramp [] of sorts. So they may not have to do the consequences analysis for [Criterion] A and maybe even [Criterion] B.
00:52:09.090 --> 00:52:14.930 Prasad, Stacy Correct so that's the thought to kind of save because. The consequences analysis that that NEI talks about in their guide ends.
00:52:15.730 --> 00:52:47.070 Prasad, Stacy It is a pretty big analysis right and then different than any o ther analysis that you performed so if you can show when you're going through this process during eligibility criteria. A That Hey, there's there's no way we're going to get there. We can show that our safety analysis does bound the worst, the worst case scenario kind of then now you don't need to do a separate analysis, the same thing. If you can show. Hey there's nothing within the DBT toolbox that can be that can be used to achieve this target set.
00:52:47.450 --> 00:52:53.560 Prasad, Stacy Need to do the consequences analysis, but I think we're in agreement with that 1:00 in the NEI guidance for for [Criterion] B in particular.
00:52:56.140 --> 00:53:02.390
+12*******46 (David Young)
So, just thinking down the road here just that just a bit Stacy. I mean, it this way, it will be important to get the?
00:53:03.100 --> 00:53:08.770
+12*******46 (David Young)
Inspection guidance on this right for inspectors to come in and look at Step 3 because if there is some sort of.
00:53:09.540 --> 00:53:10.220
+12*******46 (David Young)
Uh.
00:53:11.600 --> 00:53:18.340
+12*******46 (David Young)
You know major difference of opinion on on your qualitative judgment as to what something he may have screened in and screened out.
00:53:19.130 --> 00:53:34.240
+12*******46 (David Young)
Uh and you know, and there's there's an assistance to show that something you screamed out was was adequate or not. I mean, you know you're going to be off doing a full inconsequence analysis anyway. Just as a result of an inspection issue and that potentially right or am I missing something there.
00:53:34.700 --> 00:53:44.280 Prasad, Stacy I mean, you could end up there, but we're hoping that when you screen something out that your analysis for screening it out. Whether that be your safety analysis or your analysis of the DBT.
00:53:44.330 --> 00:54:10.520 Prasad, Stacy He is sufficient so we're expecting those kind of analysis to provide the documentation that we would need this is kind of similar to today, if the licensee screens out of target set in accordance with reasonable assurance of protection time. So yeah, you're a lot of screen it out. I'm not really achievable anymore. At that point but it still has to be iden tified and documented so that we can come through to verify it. So it's very similar to what's going on today with that.
00:54:11.370 --> 00:54:24.050
+12*******46 (David Young)
Well, it, yeah, it well it. Yeah, it is, but it is, and I mean, you know the consequences of a major disagreement is you're going to be offering a consequence analysis, which is obviously a much bigger time consuming way of trying to resolve an inspection issue.
00:54:25.020 --> 00:54:38.620
+12*******46 (David Young)
So I guess I'll just leave you with this thought for the time being. I&I understand this is a workshop in world changing ideas, but you know, let's say. Let's say this approach comes to fruition at some point. It is going to be really, really important to have some engagement and dialogue on.
00:54:39.250 --> 00:54:41.910
+12*******46 (David Young)
Whatever ends up being expression guidance for this Step 3.
00:54:42.670 --> 00:54:45.160
+12*******46 (David Young)
Uh so that we're kind of all agree what?
00:54:47.440 --> 00:54:55.780
+12*******46 (David Young)
I you know what? What is going to be sufficiently called into question that is going to require the licensee to go off and do a consequence analysis.
00:54:57.180 --> 00:55:14.230 Prasad, Stacy Yeah, I think that's their there should be. I guess maybe specific criteria to say to show that your safety analysis bounds. This we're looking for these specific things something like that, and we really didn't pull this trigger what that's going to look like yet. We wanted to make s ure we have some kind of high level.
00:54:59.320 --> 00:54:59.840
+12*******46 (David Young)
OK.
00:55:16.020 --> 00:55:31.470 Prasad, Stacy Agreement with at least the processes to make sure it makes sense that the input from the public and Industry on that, so but you're absolutely correct the intention isn't to say. Hey, you, don't do this full consequences analysis and then we come out and say where's your consequence analysis?
00:55:32.670 --> 00:55:45.300
+12*******46 (David Young)
Exactly yeah, exactly well, I'd say just since we're just swapping ideas here. You know as we move through this and how some subsequent engagements if you are giving some thoughts too.
00:55:47.030 --> 00:56:06.800
+12*******46 (David Young)
What types of criteria you might put inspection guidance that would have to be the sort of I'll just say that you know the threshold. You'd have to meet before you might require licensee to do a consequences analysis. A great place to put that same thought would be in [N EI] 20-05 right for the filtering guidance for licensees upfront so everybody understands what the you know where the goal posts are.
00:56:08.260 --> 00:56:09.620 Prasad, Stacy OK, yeah, I noted that.
00:56:10.720 --> 00:56:11.460
+12*******46 (David Young)
OK, thank you.
00:56:16.160 --> 00:56:23.360 Andrukat, Dennis Can I give it a couple seconds in case someone else wants to chime in so far. Not seeing any hands raised not that you have to.
00:56:29.430 --> 00:56:31.800 Andrukat, Dennis You can go on to the next slide.
00:56:33.560 --> 00:56:36.430 Andrukat, Dennis Let's go on to the next one we already talked about this one right.
00:56:38.110 --> 00:56:38.860 Andrukat, Dennis You need to.
00:56:38.330 --> 00:56:39.660
+12*******46 (David Young)
I I think so, Dennis Yes.
00:56:39.960 --> 00:56:43.660 Andrukat, Dennis Yeah, so I don't know if you had anything further for this particular one.
00:56:49.240 --> 00:56:49.660
+12*******46 (David Young)
I.
00:56:49.710 --> 00:56:52.810
+12*******46 (David Young)
I don't listen it any you know th e other folks on the call do.
00:56:55.720 --> 00:56:56.140 Andrukat, Dennis OK.
00:56:57.050 --> 00:56:59.120 Andrukat, Dennis Not seeing anything OK, let's go on.
00:57:00.650 --> 00:57:01.160 Andrukat, Dennis OK.
00:57:05.940 --> 00:57:15.970
+12*******46 (David Young)
Yeah, so David Young, NEI, just again. I just think, maybe just to say it one more time. I thought you know the thinking here again, the seems like the major differences.
00:57:17.430 --> 00:57:19.290
+12*******46 (David Young)
In the presentation here today.
00:57:21.060 --> 00:57:23.970
+12*******46 (David Young)
You know staff is viewing eligibility criteria.
00:57:25.160 --> 00:57:30.090
+12*******46 (David Young)
As a screen message determine if you have and what are achievable target sets?
00:57:30.690 --> 00:57:40.240
+12*******46 (David Young)
You know, whereas we reviewing it in our right up in [NEI] 20-05. We were viewing this as design and operational criteria than applicant could meet too.
00:57:40.850 --> 00:57:46.140
+12*******46 (David Young)
Uh meet the alternative requirements, such as not maintaining an onsite armed response force.
00:57:47.050 --> 00:57:48.240
+12*******46 (David Young)
So I guess again just.
00:57:49.040 --> 00:57:53.810
+12*******46 (David Young)
I just want to stress that one more time that we were viewing it again as as sort of a set of criteria that.
00:57:55.730 --> 00:58:04.210
+12*******46 (David Young)
They could govern design and operational considerations that the applicant was going to propose to you know to meet something an.
00:58:05.470 --> 00:58:12.810
+12*******46 (David Young)
You know, and you're really viewing it as screening criteria for achievable target sets. That's the difference in the thinking as I understand it.
00:58:14.500 --> 00:58:14.910
+12*******46 (David Young)
That.
00:58:16.010 --> 00:58:17.840
+12*******46 (David Young)
No, I didn't get that right.
00:58:18.030 --> 00:58:22.000 Prasad, Stacy No, I mean, fish just because it's not fully developed.
00:58:24.000 --> 00:58:46.570 Prasad, Stacy I lost my train thought I was going to say so. We haven't looked at the text. But it's going to be in the red guide or the actual guidance that we're going to look at for th e eligibility criteria. We think the process for targets that identification an achievable target sets could stand independent of the eligibility criteria so there is a pathway to provide additional guidance. That's only specific to the eligibility criteria.
00:58:48.350 --> 00:59:02.160 Prasad, Stacy Just one of the biggest concerns is using the guidance in NEI 20-05 to get unintended really from target set requirements. So we're trying to find a happy medium to make sure that that does not happen.
00:59:03.130 --> 00:59:30.270 Prasad, Stacy Because I mean, all reactor sites have configuration changes at some point or design changes at some point or or some kind of change or the DBT changes that that's required to be analyzed again. So these things do happen. That's why we require periodic review. We're just trying to make sure that just because you use the eligibility criteria you're not getting out of this review process by saying no target sets. We just want to make sure that's clear.
00:59:34.050 --> 00:59:34.530
+12*******46 (David Young)
OK.
00:59:36.910 --> 00:59:40.290
+12*******46 (David Young)
And I guess maybe just ask the question I think I can get this right.
00:59:41.960 --> 00:59:45.500
+12*******46 (David Young)
I mean, but the rule couldn't for example, say something along the lines of.
00:59:46.090 --> 00:59:53.010
+12*******46 (David Young)
Uh you know, we really if you go down this path, we relieve certain target set requirements contained in you know 7355.
00:59:54.060 --> 01:00:01.530
+12*******46 (David Young)
You go through this criteria you get the alternative requirements and then maybe one of the requirements is to include things like you periodically have to check your?
01:00:01.870 --> 01:00:14.700
+12*******46 (David Young)
Uh you know the quality of your of your analysis periodically and make sure it's consistent with the DBT and and so forth. You know, I'm saying almost put the review stuff on the back end is that something guys talked about.
01:00:15.070 --> 01:00:22.580 Prasad, Stacy Yep, there's definitely a plus or ways to do it a specific requirements. We do, find very important, and we're not saying they have to be where they are now.
01:00:22.630 --> 01:00:55.350 Prasad, Stacy Now, this is just a process where proposing that has them in th eir nail because high level. The processes are similar to identify target sets or legal hates when I say that because they're not really similar just just in the fact that you're identifying that you're analyzing and then that you're protecting what's achievable in the end, so we're trying to kind of leverage that process that already exists as we think it works well. But you're absolutely correct. There's other avenues that we could add different regulatory language that addresses the specific things that were concerned about.
01:00:55.400 --> 01:00:59.980 Prasad, Stacy But it kind of just be duplicating the efforts that we already have and the requirements potentially.
01:00:58.980 --> 01:01:14.230
+12*******46 (David Young)
OK, so, so, so let's say this way, then then then maybe just maybe your yeah, your concerns so much necessarily unintendedly from trying to set up. It is to make sure that somehow always no matter how this thing ends up at target set considerations are always maintained.
01:01:15.900 --> 01:01:38.760 Prasad, Stacy Correct so it would be maybe calling if you want to call them something different or if something happens in the end, we use a different word. But in the end. It's the same thing. We want to make sure that things that you identified that you're analyzing in whatever analysis you're doing to show that you meet the eligibility criteria are some are somehow maintained that they are required to be subject to side.
01:01:38.060 --> 01:01:39.190
+12*******46 (David Young)
Yeah, yeah.
01:01:39.470 --> 01:01:47.510 Prasad, Stacy Let's see so it's the same stuff that we really are hard. Pressed on where it is, but it be the same thing, no matter where it was, I think.
01:01:40.550 --> 01:01:41.580
+12*******46 (David Young)
Yeah, bingo.
01:01:50.320 --> 01:01:52.350
+12*******46 (David Young)
Yeah, that's that's very helpful OK. Thank you, Stacy.
01:01:50.690 --> 01:01:50.980 Prasad, Stacy Yeah.
01:01:56.670 --> 01:01:58.800 Andrukat, Dennis Yeah, OK, I see.
01:02:00.980 --> 01:02:02.740 Andrukat, Dennis See Patrick you got your hand up.
01:02:03.450 --> 01:02:07.610 Asendorf, Patrick Joseph Yeah, this is Pat Asendorf from Tennessee Valley Authority so.
01:02:09.090 --> 01:02:12.620 Asendorf, Patrick Joseph My question is, I understand configuration control and.
01:02:13.290 --> 01:02:15.030 Asendorf, Patrick Joseph Yeah, it could be changes to the plant.
01:02:15.880 --> 01:02:23.650 Asendorf, Patrick Joseph But wouldn't that push this under other regulations such as 7358 or safety, security interface.
01:02:24.840 --> 01:02:26.530 Asendorf, Patrick Joseph Instead of target sets.
01:02:28.240 --> 01:02:52.510 Prasad, Stacy I mean, it could be it could be done at a bunch of different wa ys. But if that's the safety, security interface doesn't identify the elements that were used as the basis for the eligibility criteria so like the NEI guidance says equipment and operator actions. I don't think any slight wants to whenever there is a design change on any equipment or any action that they have to do this big analysis to make sure it doesn't invalidate.
01:02:53.590 --> 01:03:06.550 Prasad, Stacy That you identified no target sets so there still is going to be that subset of equipment that you know, hey, if something changes to these things or hey, if something is added or taken away the way it's currently controlled in the oversight of targets that process.
01:03:08.170 --> 01:03:09.740 Prasad, Stacy It has to be called something.
01:03:10.760 --> 01:03:14.840 Prasad, Stacy But yeah, whatever it is can be addressed in the safety, security interface? Absolutely.
01:03:18.880 --> 01:03:19.940 Asendorf, Patrick Joseph OK, thank you.
01:03:25.040 --> 01:03:29.080 Andrukat, Dennis I'll give it a couple seconds and kissed anyone else wants to chime in so far. I'm not seeing anyone.
01:03:32.980 --> 01:03:35.090 Andrukat, Dennis No? OK now go on to the next slide.
01:03:43.310 --> 01:03:43.850 Andrukat, Dennis OK.
01:03:45.700 --> 01:03:47.280 Andrukat, Dennis And I can skip over this one.
01:04:00.850 --> 01:04:06.230
+12*******46 (David Young)
So here in just, this is David Young, NEI, just confirming one more time so really Dennis looks like that that.
01:04:06.970 --> 01:04:20.740
+12*******46 (David Young)
Terminology derailed us for a while here on originally starting off is hypothetical and mitigated and I guess it looks like. Maybe it went to hypothetical but it looks like it's going to evolve into DBT initiated is that correct.
01:04:22.600 --> 01:04:30.140 Andrukat, Dennis Yeah, so some of the current thinking now is to at least add DBT initiated event because I mean that's This is what we're kind of talking about.
01:04:30.180 --> 01:04:36.270 Andrukat, Dennis Uh you know, I you know, we keep going back and forth on.
01:04:30.980 --> 01:04:31.860
+12*******46 (David Young)
Yeah, yeah.
01:04:36.840 --> 01:04:51.520 Andrukat, Dennis Trying to define hypothetical unmitigated as well. I think the key focus is probably more the unmitigated portion of that. At least that's where some of the questions and I assume that's probably where your question is probably more coming from.
01:04:53.270 --> 01:04:57.180 Andrukat, Dennis I think the hypothetical just a generic qualifier for all of these.
01:04:59.980 --> 01:05:00.480
+12*******46 (David Young)
OK.
01:05:00.760 --> 01:05:01.100 Andrukat, Dennis Right.
01:05:01.720 --> 01:05:09.840
+12*******46 (David Young)
All right, I mean, just my own print. This is just my own personal opinion at the moment is is I mean, I. I certainly do think DBT initiated is is clearer by you know, I mean, I I can sort of.
01:05:05.980 --> 01:05:06.300 Andrukat, Dennis Sure.
01:05:11.060 --> 01:05:18.090
+12*******46 (David Young)
I mean, I understand that term much better than hypothetical and you could always address unmitigated in some subsequent part of a sentence or a second sentence. But.
01:05:19.630 --> 01:05:22.100
+12*******46 (David Young)
I at least to me personally, I find this clearer.
01:05:23.620 --> 01:05:33.490 Andrukat, Dennis And I think you know, right at the end of the day. I you know, I think what we need to do is for [Criterion]
Alpha Bravo and Charlie criteria right is you know.
01:05:34.200 --> 01:05:51.440 Andrukat, Dennis We know what the starting point with describing the event right. These are all DBT initiated events right. We know the third thing in my mind, the third thing, which is OK. What's the end result kind of criteria. We placed it and for all three have the same which is not exceedin g the offsite.
01:05:51.490 --> 01:06:17.860 Andrukat, Dennis For reference dose values right so then the middle thing. I think is kind of what in my mind. At least changes from Alpha Bravo. Charlie is kind of like? What are you able to kind of credit or consider right with Alpha being the least amount of stuff right and therefore the hardest and then as you go up to Charlie. You get the credit, the most amount of stuff is that is that kind of Fair to break it down that way.
01:06:21.020 --> 01:06:24.760
+12*******46 (David Young)
Yeah, yeah, no no, I'm I'm just yes that's that's fine that's fine.
01:06:27.630 --> 01:06:35.300 Andrukat, Dennis Yeah, and so part of a right, yeah right. We had unmitigated you're right, it and it's been you know it's interesting.
01:06:34.810 --> 01:06:37.720
+12*******46 (David Young)
But I think we're going to get to that in a second go ahead go ahead.
01:06:37.220 --> 01:06:42.330 Andrukat, Dennis Yeah, yeah, yeah, it's interesting how just one work in can spark conversation sometimes.
01:06:45.770 --> 01:06:51.880
+12*******46 (David Young)
Yeah, I think this is where we're going to get to this part, th ough here. Denis that part you just mentioned on these next three slides so.
01:06:53.260 --> 01:06:53.670 Andrukat, Dennis OK.
01:06:54.500 --> 01:06:59.790 Andrukat, Dennis I'll give folks a couple of seconds to read this, but, yeah, David if you want to kick it off.
01:06:55.540 --> 01:06:56.170
+12*******46 (David Young)
Uh.
01:07:01.750 --> 01:07:02.510 Andrukat, Dennis Whenever you're ready.
01:07:02.240 --> 01:07:05.310
+12*******46 (David Young)
Sure, so I guess I you know couple of questions here so.
01:07:06.580 --> 01:07:08.630
+12*******46 (David Young)
So trying to understand here so.
01:07:09.610 --> 01:07:12.260
+12*******46 (David Young)
So this is what should not be credited and.
01:07:15.120 --> 01:07:18.640
+12*******46 (David Young)
So what about things like you know, engineered safety and security features.
01:07:20.190 --> 01:07:33.150
+12*******46 (David Young)
I guess I guess that's my first question what about engineers safety and security features and I'm trying to differentiate that maybe from security program so if I have certain engineered features that you know part of the licensing basis. They do certain things and certain conditions.
01:07:33.930 --> 01:07:34.710
+12*******46 (David Young)
Uh.
01:07:36.260 --> 01:07:45.880
+12*******46 (David Young)
And I can show that you know that and I can show that during my DBT initiated event. These kinds of actions would take place for these engineered features.
01:07:46.880 --> 01:07:47.940
+12*******46 (David Young)
Can those be credited?
01:07:49.610 --> 01:07:57.730 Andrukat, Dennis So can you do you mind just taking a quick minute for at least from NEIs point-of-view that might help?
01:07:58.780 --> 01:08:15.480 Andrukat, Dennis Yes, maybe others that may not be as familiar so in the three criteria. We talk about plant features and we talked about like engineered features, right? Do you mind to spending just a couple of seconds real quick to kind of explain the quick difference between those two.
01:08:17.800 --> 01:08:19.350 Andrukat, Dennis I know I'm putting you on the spot here.
01:08:19.700 --> 01:08:24.880
+12*******46 (David Young)
Yeah, Well, you know by engineered by engineered features I mean, things that are.
01:08:25.230 --> 01:08:37.300
+12*******46 (David Young)
Uh you know you know their part of the plant design. They're there for lack of better wording. Other constructed their permanent plant equipment their you know their installed you walk out there, you see this thing.
01:08:37.930 --> 01:08:40.830
+12*******46 (David Young)
Uh it's it's part of the licensing basis.
01:08:41.300 --> 01:08:42.080
+12*******46 (David Young)
Uh.
01:08:42.800 --> 01:08:49.210
+12*******46 (David Young)
You know, maybe it's controlled by some kind of ongoing requirements. Perhaps technical specifications or something else but you know it, it, it's a controlled.
01:08:50.070 --> 01:08:50.980
+12*******46 (David Young)
Design.
01:08:51.610 --> 01:08:54.400
+12*******46 (David Young)
Engineered built feature of your plant.
01:08:55.330 --> 01:09:08.380
+12*******46 (David Young)
And maybe this, this thing has a safety function. Maybe has a security function. Maybe has a combination function. Maybe it does doesn't. You know it's credited in in b oth areas, but I I'm what I'm trying to differentiate that is from things like.
01:09:09.320 --> 01:09:18.680
+12*******46 (David Young)
Uh like Lou talked about earlier you know programs. I understand where he was coming from. You know talking about things like insider mitigations I'm not talking bout programs.
01:09:19.280 --> 01:09:25.080
+12*******46 (David Young)
I'm talking about real hardware or things that are out there th at the DBT would have to.
01:09:26.090 --> 01:09:37.970
+12*******46 (David Young)
Just Roy render nonfunctional get through you know what you know, whatever your term is it something that would expend time and resources would have to be done for them to try to get the release of the trying to get.
01:09:39.350 --> 01:09:43.330
+12*******46 (David Young)
Can those engineered safety and security features be credited?
01:09:47.480 --> 01:09:56.510 Prasad, Stacy Based on what you said it kind of sounds like they would meet the definition of a target set so the things that you need to compromise in order to get that release.
01:09:59.890 --> 01:10:03.730 Andrukat, Dennis And then you're saying can they be credited or not credited under Alpha?
01:10:00.140 --> 01:10:00.820
+12*******46 (David Young)
OK.
01:10:07.260 --> 01:10:22.760
+12*******46 (David Young)
And to be clear for you answer that question to be clear what I mean? What I'm asking that question is why I'm doing my analysis right. I'm going to applicant. I'm doing my analysis. I've gathered my DBT information. I understand their characteristics. Their tactics and now I'm going to do my analysis on what they can do to my plant.
01:10:23.870 --> 01:10:29.420
+12*******46 (David Young)
And I have again, these certain features certain engineered installed hardware features.
01:10:30.190 --> 01:10:36.790
+12*******46 (David Young)
I I'm assuming because again I mean, the rich real world they'd have to get through them or do something to them to make it happen, I'm assuming I can.
01:10:37.540 --> 01:10:43.270
+12*******46 (David Young)
Right it goes in my assessment my initial screening assessment for target sets. Not that's why I'm asking.
01:10:45.960 --> 01:11:13.590 Prasad, Stacy I mean, it sounds like it based on your definition and what you're describing but I don't want to say a blanket yes. because there might be something specifically that I'm not understanding what you're saying but the initial identification of the targets that are all those things, including structures, so if these engineered features are structures that are permanent design that there all the time I would consider that something that an adversary needs to compromise in order to meet the obje ctive of [10 CFR 73.55](b)(3).
01:11:15.950 --> 01:11:32.140 Andrukat, Dennis Yeah, I think you're David you m ight be talking a little bit outside of the target set discussion here for a second right. Yeah, I think you're just trying to figure out wh ere we as far as what can be credited under engineering features right so.
01:11:32.420 --> 01:11:52.420
+12*******46 (David Young) (David Young)
Well, a little bit of no let me a little bit of both I mean, I. I think I think I I'm trying to ask it at least as I understand that the framework that Stacy's outlining here articulating here. I'm saying OK. So now I'm [a applicant] I'm sitting down. I'm going to do this assessment on the look and I think you know look at my Criterion, A and see if I can meet that and so I'm going to go through this qualitative assessment, but what I think.
01:11:53.030 --> 01:11:53.760
+12*******46 (David Young)
Uh.
01:11:54.820 --> 01:12:03.690
+12*******46 (David Young)
Or my target sets and what I need to know what I need to go thr ough the process with and it. It sounds like again as long as I can, reasonably make the case that these are.
01:12:04.990 --> 01:12:14.810
+12*******46 (David Young)
Engineered safety and security features there again part of my licensing basis. I've gotta maintain a[t] all times. You want operating that kind of thing that that I can.
01:12:15.930 --> 01:12:17.550
+12*******46 (David Young)
II can credit goes in my assessment.
01:12:20.680 --> 01:12:23.200 Reed, Beth Hi this is Beth Reed with NRR.
01:12:24.490 --> 01:12:28.420 Reed, Beth I believe some of the draft rule texts were shared in the past.
01:12:29.080 --> 01:12:32.330 Reed, Beth Actually says that a is the failure.
01:12:33.070 --> 01:12:34.220 Reed, Beth Engineered features.
01:12:35.130 --> 01:12:48.000 Reed, Beth So for a I do not believe you can credit the engineer features and so the loss of engineered systems for decay heat removal possible breaches blah blah blah so eh.
01:12:50.010 --> 01:12:57.750 Reed, Beth Previously released draft rule text says that you're actually we actually lose the engineer systems.
01:13:01.850 --> 01:13:04.730
+12*******46 (David Young) (David Young)
Yeah, but that was really faint and hard and hard to hear.
01:13:05.380 --> 01:13:08.180
+12*******46 (David Young)
So I didn't quite catch it.
01:13:06.990 --> 01:13:11.140 Reed, Beth I'm sorry I've never been I've never been accused of not being able to be heard.
01:13:10.630 --> 01:13:11.170 Andrukat, Dennis Yeah.
01:13:13.200 --> 01:13:16.200 Reed, Beth Let me make the mic a little closer sorry can you hear me better?
01:13:17.500 --> 01:13:19.500
+12*******46 (David Young)
A little bit better, a little bit better.
01:13:19.660 --> 01:13:32.320 Reed, Beth Yeah, So what I was saying, is that previously we released rule text that says that [Criterion] A is involves the loss of engineered systems for decay heat removal and.
01:13:33.270 --> 01:13:35.500 Reed, Beth And it goes on so no.
01:13:35.930 --> 01:13:36.300 Reed, Beth Right.
01:13:37.770 --> 01:13:43.520 Reed, Beth Can read from? What we released previously then you cannot take credit for engineered systems?
01:13:46.200 --> 01:13:48.650
+12*******46 (David Young)
Well then I I don't know what value this criterion is.
01:13:50.110 --> 01:13:52.690
+12*******46 (David Young)
And I'm not sure why well how that could even be realistic.
01:13:56.640 --> 01:14:04.780
+12*******46 (David Young)
If I'm coming to you with the designers an applicant and I'm sh owing you. These these this is this is my facility. This is what I'm licensed to.
01:14:05.990 --> 01:14:07.470
+12*******46 (David Young)
It it it.
01:14:09.250 --> 01:14:12.360
+12*******46 (David Young)
I guess I'm struggling understand why I can't credit those features.
01:14:13.090 --> 01:14:14.600
+12*******46 (David Young)
The DBT has to go through them.
01:14:16.770 --> 01:14:20.480 Andrukat, Dennis So so that I think this is kind of.
01:14:21.280 --> 01:14:28.420 Andrukat, Dennis Why we end up kind of having multiple kind of conversations you know kind of internally it this is just one aspect right, I mean?
01:14:29.050 --> 01:14:39.330 Andrukat, Dennis We have, we have 3 different criteria 3 different levels of what can be credited or not right so you know.
01:14:40.130 --> 01:14:50.130 Andrukat, Dennis Yeah, state you know talking internally. We've gotten brought in some additional insert folks to kind of help us out, especially with some conforming changes on the on the target set issue to make sure we weren't.
01:14:52.740 --> 01:14:58.480 Andrukat, Dennis Interfering or misaligning on on the target set stuff but.
01:14:59.440 --> 01:15:02.160 Andrukat, Dennis Yeah, if you're if you're saying so I mean.
01:15:02.740 --> 01:15:05.640 Andrukat, Dennis The Criterion, A That you that we have.
01:15:06.230 --> 01:15:07.490 Andrukat, Dennis Right that is right.
01:15:09.420 --> 01:15:11.960 Andrukat, Dennis So, but if we're talking about.
01:15:12.560 --> 01:15:17.320 Andrukat, Dennis You know, maybe that more discussion for Criterion Bravo or we just.
01:15:20.180 --> 01:15:21.320 Andrukat, Dennis Well, I'll just leave it at that.
01:15:24.460 --> 01:15:25.230
+12*******46 (David Young)
So.
01:15:26.650 --> 01:15:36.150
+12*******46 (David Young)
OK, so is the idea. I I I put my car on a table and vaporize it and doing it. Consequences now so I'm not sure what you're gaining then if you can't credit your facility.
01:15:37.010 --> 01:15:38.680
+12*******46 (David Young)
Or any aspect of your facility.
01:15:39.730 --> 01:15:42.860
+12*******46 (David Young)
Then you're just doing an instantaneous dispersal of the core.
01:15:39.820 --> 01:15:40.470 Reed, Beth Well, you can.
01:15:44.050 --> 01:15:47.430
+12*******46 (David Young)
And I I don't know what this criteria does for you.
01:15:44.260 --> 01:15:44.580 Andrukat, Dennis Yeah.
01:15:48.510 --> 01:15:49.210 Reed, Beth What?
01:15:48.690 --> 01:16:10.020 Andrukat, Dennis And I think what we're talking I think one of the ideas and correct me if I if I misread stuff. He said in the past, it would be correct hearing a might be able to account for some of those type of features, but without human interaction, or something to that degree, and that will maybe help differentiate between [criterion] Alpha
[and] Bravo, a little bit.
01:16:11.900 --> 01:16:30.950
+12*******46 (David Young)
Right we were fully so, so as I'm reading this slide. I I'm I'm thinking this. So me personally, I can chime in here from other folks meet person? My opinion I'm on board from our previous conversations and public interactions. I agree with operator actions; agree with mitigation recovery measures; agree with security programs.
01:16:31.890 --> 01:16:40.620
+12*******46 (David Young)
But I I think as we've been consistent in our feedback over the last 2 or 3 public meetings and an in comments that we've submitted.
01:16:41.300 --> 01:16:43.000
+12*******46 (David Young)
It uh.
01:16:43.760 --> 01:16:48.820
+12*******46 (David Young)
Is extremely difficult understand why this assessment can't credit?
01:16:49.720 --> 01:16:56.190
+12*******46 (David Young)
Actual engineered physical security [and] safety features that are part of your licensing basis.
01:16:58.820 --> 01:17:00.790 Reed, Beth He had this is free again so.
01:17:01.780 --> 01:17:02.860 Reed, Beth I'm sorry go ahead, Stacy.
01:17:04.190 --> 01:17:05.330 Prasad, Stacy Now go after you go ahead.
01:17:05.780 --> 01:17:15.490 Reed, Beth OK, so basically it goes to the Unmitigated, an while you can c redit the fuel type.
01:17:17.070 --> 01:17:27.790 Reed, Beth Physical chemical characteristics the engineer systems to help mitigate is what we say you can't take credit for because this is supposed to be.
01:17:27.840 --> 01:17:38.820 Reed, Beth The unmitigated then basically even though we're not putting it right in the rule language. It is Unmitigated.
So it's it's not as far.
01:17:40.850 --> 01:17:45.840 Reed, Beth To one side is put in the core in the middle field and see what happens, but it's not.
01:17:46.670 --> 01:17:47.480 Reed, Beth Including.
01:17:48.640 --> 01:17:53.560 Reed, Beth Functions, engineered functions to mitigate so somewhere in between that area.
01:17:56.680 --> 01:17:59.390
+12*******46 (David Young)
So so, so it's an unrealistic assessment.
01:18:02.320 --> 01:18:06.370 Reed, Beth I don't think it be unrealistic. I think it's gonna be a very low bar.
01:18:07.190 --> 01:18:22.890 Reed, Beth And you know it's not designed for everybody to meet this and that's why we have. There is a [Criterion] B and then there's a [Criterion] C. It's aIt's a graded approach to the very small ones with the lowest rad consequences.
01:18:24.300 --> 01:18:27.890 Reed, Beth Probably could meet Criterion, A and then if not, you go to [Cr iterion] B.
01:18:30.970 --> 01:18:31.720 Reed, Beth And so forth.
01:18:35.200 --> 01:18:59.880 Andrukat, Dennis So David this is Dennis again. It's on you know, I know we're kind of starting to run out of time. But in this you know this hitting I think on a question you guys have been struggling with and waiting for us on the unmitigated terminology for at least for a right you know, so one of the things struggling right. You know this unmitigated mean unmitigated by human actions, does it or does it mean unmitigated by?
01:19:00.110 --> 01:19:05.040 Andrukat, Dennis Uh features right which would include human actions.
01:19:05.800 --> 01:19:06.160 Andrukat, Dennis Right.
01:19:07.230 --> 01:19:16.590
+12*******46 (David Young)
Correct and we were on board with human mitigation. We you know again me personally that that's the way I've been sort of writing this guidance from the start is that?
01:19:18.080 --> 01:19:23.190
+12*******46 (David Young)
Red unmitigated to mean right you know go operator actions note no human mitigation of the event.
01:19:26.430 --> 01:19:57.040 Andrukat, Dennis Yeah, and I think an so that's you know, so I don't we don't have a definite answer for that not for today and you know that wasn't we didn't plan to have an answer on that today anyways. But it is definitely something we're still debating, especially considering what the rule language should say which like Beth was saying.
Currently we have the loss of the engineered system so we're trying to adjust the position between that versus it's just going to be.
01:19:57.400 --> 01:20:05.900 Andrukat, Dennis Uh like manual actions human actions, if you will so unfortunately. I don't have an answer for you today on the on the unmitigated piece.
01:20:01.760 --> 01:20:02.720
+12*******46 (David Young)
OK, so.
01:20:06.780 --> 01:20:07.570 Andrukat, Dennis Uh.
01:20:08.430 --> 01:20:14.130 Andrukat, Dennis I know that's not necessarily satisfying and that doesn't help you to also fully understand.
01:20:14.660 --> 01:20:15.700 Andrukat, Dennis Uh that or
01:20:16.790 --> 01:20:17.820 Andrukat, Dennis Criterion A.
01:20:19.570 --> 01:20:20.580 Andrukat, Dennis But maybe
01:20:20.100 --> 01:20:28.080
+12*******46 (David Young)
No, that that's fine, you know, maybe if you could take it back down and talk about. I mean, clearly you know as I'm going to be starting to work on [NEI] 20-05 and addressi ng.
01:20:28.720 --> 01:20:39.650
+12*******46 (David Young)
You know addressing comments and working with our members to update the guidance mean clearly that's a pretty critical important piece of information and I would hope we could get some clarity around it.
01:20:40.280 --> 01:20:41.670
+12*******46 (David Young)
You know sooner rather than later.
01:20:42.210 --> 01:20:43.330 Andrukat, Dennis correct correct.
01:20:43.480 --> 01:20:50.230 Andrukat, Dennis Uh and if I can, if it's OK. I'd like to [I see Ed Lyman] has h ad his hand up for a while now.
01:20:51.260 --> 01:20:52.080 Andrukat, Dennis I'd like to kind of.
01:20:53.650 --> 01:20:54.430 Andrukat, Dennis Jump over to him.
01:20:56.350 --> 01:21:09.460 Edwin Lyman Great thank you and first I just like to say. I appreciate that the staff has finally laid this concept out and you know in a logical fashion. I think really, for the first time.
01:21:10.730 --> 01:21:15.810 Edwin Lyman And so I appreciate that and you know, I'm still mystified.
01:21:16.930 --> 01:21:20.320 Edwin Lyman By Mister Young 's comments I feel like.
01:21:21.160 --> 01:21:24.020 Edwin Lyman This whole process is just being dragged in the circle.
01:21:26.110 --> 01:21:46.960 Edwin Lyman And we have the sensually the same discussion at the last meeting like point of this criterion is essentially this is a reactor where if its target set is disabled, meaning there's core damage. I guess, according the old definition an there's an offsite release.
01:21:48.870 --> 01:21:50.050 Edwin Lyman Which is below?
01:21:50.730 --> 01:21:56.670 Edwin Lyman Whatever you know regulatory threshold you decide if there's core damage and a release that.
01:21:57.750 --> 01:22:00.080 Edwin Lyman That will meet your criterion.
01:22:01.020 --> 01:22:14.690 Edwin Lyman So there are no you know you're already assuming that that what ever features were there to prevent cord damage had been disabled because I was one of the capabilities of the DBT so to keep going in circles and then to.
01:22:15.720 --> 01:22:46.720 Edwin Lyman You know, look for other, you know, crediting other features is getting nowhere and I agree with Mr. Young is totally unrealistic is not likely to be any system that will do that except the microreactor where the source term is so small that he didn't know if the adversary piled exp losives into the core and send him off and blew it to Kingdom come. It wouldn't cause wouldn't exceed the offsite dose. So so yeah, so I'm totally supportive of maybe not.
01:22:46.770 --> 01:22:54.520 Edwin Lyman Not even considering that as an option, but it sounds like Mr. Young is really talking about [Criterion] B and C.
01:22:56.210 --> 01:23:05.420 Edwin Lyman Where the design basis threat is defeated by various either engineered or, you know, safety features. So again, I don't understand why there's still confusion on that.
01:23:08.020 --> 01:23:08.550 Andrukat, Dennis No.
01:23:08.960 --> 01:23:11.450 Edwin Lyman I just want to make one more comment, but if I could share.
01:23:09.860 --> 01:23:10.520 Andrukat, Dennis Sure, sure.
01:23:13.870 --> 01:23:33.150 Edwin Lyman So on the slide where it's shown that you could potentially take out all the elements of targets that leading to core damage. But if you maintain a barrier against release that that would essentially be acceptable. I mean, it seems it would be very hard to demonstrate that.
01:23:34.380 --> 01:23:39.930 Edwin Lyman Because they would have to be a zero probability of a large release.
01:23:41.670 --> 01:23:55.590 Edwin Lyman Given core damage and I don't know you know if there's any credible system where there's absolutely zero probability that you would have a breach of a containment or confinement barrier if there's cord damage so.
01:23:55.640 --> 01:23:55.990 Edwin Lyman From.
01:23:58.150 --> 01:24:02.760 Edwin Lyman You know, I guess you for logic. You need to include that possibility, but I think.
01:24:04.310 --> 01:24:33.740 Edwin Lyman You know is it worth going through this exercise, including really unrealistic scenarios with regard to systems that no applicant is probably ever going to meet those criteria. Maybe you should think about what a realistic, and if an applicant really thinks they can make the case, that you have an in[de]structable reactor or reactor that can never harm. The public no matter what the desi gn is reference to it, then they can apply for exemption, but maybe it shouldn't be part of.
01:24:34.750 --> 01:24:35.950 Edwin Lyman rule here thank you.
01:24:38.540 --> 01:24:42.380 Andrukat, Dennis Yeah, thank you Dr. Lyman tha t's definitely good insights.
01:24:43.780 --> 01:25:12.540 Andrukat, Dennis Yeah, I know that's one of the aspects that I continually struggle with I know we're kind of. We just hit our 4:30pm mark here, but you know, I think that's something that that will kind of take into consideration and think about you know, sometimes for me as a project manager. I know we have the three criteria, but you know, I'm trying to look at a bigger picture of the ultimate you know, do we agree on the ultimate outcome as far as?
01:25:12.590 --> 01:25:20.790 Andrukat, Dennis The criteria which right now is the off-site reference. Those values right? Do we agree on kind of where the inputs in the analysis to be?
01:25:20.900 --> 01:25:33.820 Andrukat, Dennis Just to start to be looked at to be analyzed. You know whether it gets screened out into you know a or whether you're going to use [Criterion] A because of what you're crediting or [Criterion] B or C right those are something, we need to fine tune.
01:25:35.150 --> 01:25:39.170 Andrukat, Dennis Or you know, or if you even keep [Criteria] A, B, and C, so right now.
01:25:40.460 --> 01:25:56.790 Andrukat, Dennis
[Criteria] A, B, and C is still there and the other possibility is, you know, this is a proposed rule that we're that we're trying to get out and so we welcome the public comments on that, if that's the way it ends up being anyways for the proposal.
01:25:59.260 --> 01:26:03.350 Andrukat, Dennis So we are at 4:30 or just after.
01:26:06.850 --> 01:26:13.640 Andrukat, Dennis I don't know if it's worth [bringing it] up, so David [] because I know we have Bravo and Charlie so I didn't know if you wanted to make a quick.
01:26:15.620 --> 01:26:17.770 Andrukat, Dennis Highlight for those.
01:26:19.320 --> 01:26:22.830 Andrukat, Dennis Or if the general message, we're still kind of the same under for [Criterion] Alpha.
01:26:24.270 --> 01:26:31.280
+12*******46 (David Young)
Uh let let me just look quickly at my notes here and I appreciate you make use of a few minutes extra time and just take a look at these real quick.
01:26:34.920 --> 01:26:38.990
+12*******46 (David Young)
OK, ah, so again I guess you know the same.
01:26:42.820 --> 01:26:50.540
+12*******46 (David Young)
Under [Criterion] B we're going to answer all these. I did have a question about you know past the security systems. I'm assuming that that.
01:26:51.230 --> 01:26:51.980
+12*******46 (David Young)
Uh.
01:26:54.170 --> 01:26:55.420
+12*******46 (David Young)
It was my comment here.
01:26:56.320 --> 01:26:57.170
+12*******46 (David Young)
Uh.
01:26:58.790 --> 01:27:05.420
+12*******46 (David Young)
Oh no, I'm sorry, he was, I was asking you had a comment here in what cannot be credited active security features.
01:27:06.570 --> 01:27:15.760
+12*******46 (David Young)
By active security features I'm assuming what you mean something that somebody actually has to actuator or taken action for that feature to come into play is that is that what you meant by an active feature.
01:27:21.690 --> 01:27:22.940 Andrukat, Dennis I'll toss it over.
01:27:22.990 --> 01:27:25.480 Andrukat, Dennis To Stacy or Lou.
01:27:24.200 --> 01:27:24.610 Cubellis, Louis Yeah.
01:27:25.770 --> 01:27:36.520 Cubellis, Louis Yeah, this is Lou, that's right, David, it's aIt's not a passive feature like let's, you know, and this wouldn't be really relevant for the analysis because if it's not guarded then.
01:27:37.190 --> 01:27:41.680 Cubellis, Louis You know, it's not really there, but an example would be like the vehicle barrier system.
01:27:42.430 --> 01:27:48.420 Cubellis, Louis That's a passive feature right so you could include that in the facility characterization.
01:27:49.120 --> 01:27:50.320
+12*******46 (David Young)
Right OK.
01:27:51.250 --> 01:27:53.200
+12*******46 (David Young)
Yeah, OK, I'm working through that answer.
01:27:51.720 --> 01:28:00.040 Cubellis, Louis You know things like delay barriers that are deployed when they get an alarm condition that that's not something that you'd be allowed to credit.
01:28:03.400 --> 01:28:05.190
+12*******46 (David Young)
OK, that helps that helps.
01:28:06.020 --> 01:28:17.980
+12*******46 (David Young)
And then the only other question here. I had 2 more questions. One is I know there was some this is back on a I know we had some conversation during the last public meeting. I think it was left open.
01:28:18.570 --> 01:28:28.120
+12*******46 (David Young)
Uh and I think you guys indicate your go back and think about it, but was there ever any decision made on whether or not a reactor trip could be credited under Criterion A.
01:28:30.530 --> 01:28:40.600 Andrukat, Dennis Yeah, so we did go back and forth on that, so at this point. I think we kind of put that on hold. I think it's going to be part of the kind of the unmitigated.
01:28:41.770 --> 01:28:45.070 Andrukat, Dennis You know, I think one of the initial thoughts was you know tryi ng to
01:28:47.010 --> 01:28:55.730 Andrukat, Dennis kind of maintain consistency with the operating fleet, but also you know as we kind of you know as we just heard now right Criterion A.
01:28:56.180 --> 01:29:08.190 Andrukat, Dennis Uh continues to challenge us on spores what it can or what it s hould mean and so then therefore, that has to kind of follow suit. So I think that's really going to be that follow on discussion.
01:29:09.140 --> 01:29:10.370
+12*******46 (David Young)
OK, OK.
01:29:12.030 --> 01:29:26.120
+12*******46 (David Young)
Alright, well, I'm looking at the rest of Yeah. I think I don't have anything else. Dennis, I think you've answered all my questions and I really appreciate the discussion here today. I have a better understanding, I guess of the current thinking so thank you.
01:29:28.240 --> 01:29:29.770 Andrukat, Dennis Must have thank you. Thank you.
01:29:31.470 --> 01:29:36.880 Andrukat, Dennis Anyone else, I know we are 5 minutes over. But if anyone else would like to chime in.
01:29:37.590 --> 01:29:38.620 Andrukat, Dennis Yeah, please feel free.
01:29:51.110 --> 01:29:53.370 Kevin Deyette (Guest)
And it's just going to add new scope power can you hear me?
01:29:54.520 --> 01:29:55.170 Andrukat, Dennis Yes, Sir.
01:29:56.410 --> 01:30:07.910 Kevin Deyette (Guest)
OK, so we got this slide with the Criterion Charlie. It looks like there were still some unanswered questions so will there be an opportunity to discuss those at another time.
01:30:10.480 --> 01:30:15.390 Andrukat, Dennis Item at the ones on the slide here or you just talking about just in the conversation.
01:30:16.080 --> 01:30:22.160 Kevin Deyette (Guest)
Both the conversation and in on the slide, it, it's got questions posed but no answers.
01:30:23.860 --> 01:30:27.200 Andrukat, Dennis Correct and I think these are kind of the same type of.
01:30:27.910 --> 01:30:30.620 Andrukat, Dennis Of Headings for some of them right.
01:30:31.360 --> 01:30:33.510 Andrukat, Dennis But you're right so yeah, we will.
01:30:34.870 --> 01:30:42.160 Andrukat, Dennis So this might be a good segue, of sorts, for the kind of the next steps so we are planning to.
01:30:42.960 --> 01:31:02.360 Andrukat, Dennis Yeah, have another interaction. Whether that ends up being a public meeting or or a just a communication transmittal to NEI on summit. Maybe like our final set of comments if you will, I can call it that for NEI 20-05 right now draft D (Delta)?
01:31:03.690 --> 01:31:05.530 Andrukat, Dennis That we have in house that we're looking at.
01:31:06.770 --> 01:31:11.270 Andrukat, Dennis So it may be another public meeting you know, and then maybe we can talk about this some more.
01:31:13.080 --> 01:31:21.000 Andrukat, Dennis We are also trying to we've had a lot of discussions on this and I know it's bright hasn't been the most satisfying to get clear.
01:31:22.110 --> 01:31:24.820 Andrukat, Dennis Clear solid definite answers.
01:31:25.800 --> 01:31:26.250 Andrukat, Dennis But.
01:31:26.980 --> 01:31:47.300 Andrukat, Dennis I think we're also maybe trying to reach a point where maybe we just want to maybe get the proposed rule out there with the language with these statements consideration and the draft implementation guidance and kind of get it out there for the public to kind of digest and send us comments as well. And so that so maybe these might fall into the latter.
01:31:48.540 --> 01:31:49.900 Andrukat, Dennis If we don't get to it in time.
01:31:58.280 --> 01:31:59.680 Andrukat, Dennis Any other questions.
01:32:03.010 --> 01:32:04.560 Andrukat, Dennis Yeah, so.
01:32:06.610 --> 01:32:13.670 Andrukat, Dennis So I want to say thank you for everyone 's participation that we had some excellent questions. You know definitely have some more stuff to think about.
01:32:14.350 --> 01:32:29.170 Andrukat, Dennis You know, and if you have any additional input or suggestions for future topics related to the to this rulemaking. Feel free to send me an email if you're an individual that phoned in as an attendee.
01:32:30.450 --> 01:32:36.710 Andrukat, Dennis And your name isn't kind of registering on my system here. It's just a phone number. You know, Please send me an email.
01:32:37.670 --> 01:32:41.440 Andrukat, Dennis Saying that you attended in the phone number that you used to c all this.
01:32:42.480 --> 01:32:53.880 Andrukat, Dennis We are interested in comments and improving the rulemaking effort and I also again encourage everyone to kind of monitor the regulations.gov docket, which is
01:32:54.600 --> 01:33:05.380 Andrukat, Dennis NRC dash 2017 dash 0227 like you see on the screen. You also see the kind of the standard public meeting feedback link there, so if you have feedback on a public meeting.
01:33:06.350 --> 01:33:09.540 Andrukat, Dennis It in and of itself feel free to use that link.
01:33:10.990 --> 01:33:14.130 Andrukat, Dennis So we're at the end of the meeting and.
01:33:14.430 --> 01:33:36.390 Andrukat, Dennis Uh you know feel free to go to the NRC public meeting web page and click on the recently held meetings button and look for this meeting. There's also a feedback link there that the slides are also posted there. I also posted the [ADAMS] ML [number] for the slides in the chat and so I'd like to thank everyone hope.
Everyone has a good evening and we're adjourned for today. Thank you.