ML21323A025

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Transcript of Advisory Committee on Reactor Safeguards Materials, Metallurgy and Reactor Fuels Subcommittee Meeting - November 16, 2021, Page 1-31 (Open)
ML21323A025
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Issue date: 11/16/2021
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Advisory Committee on Reactor Safeguards
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Brown, C., ACRS
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NRC-1749
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Advisory Committee on Reactor Safeguards Metallurgy & Reactor Fuels Subcommittee Docket Number: (n/a)

Location: teleconference Date: Tuesday, November 16, 2021 Work Order No.: NRC-1749 Pages 1-31 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1716 14th Street, N.W., Suite 200 Washington, D.C. 20009 (202) 234-4433

1 1

2 3

4 DISCLAIMER 5

6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9

10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.

16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.

20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +

4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +

7 METALLURGY & REACTOR FUELS SUBCOMMITTEE 8 + + + + +

9 TUESDAY 10 NOVEMBER 16, 2021 11 + + + + +

12 The Subcommittee met via Video 13 Teleconference, at 9:30 a.m. EST, Ron Ballinger, 14 Chairman, presiding.

15 COMMITTEE MEMBERS:

16 RONALD G. BALLINGER, Chair 17 CHARLES H. BROWN, JR. Member 18 VESNA B. DIMITRIJEVIC, Member 19 GREG HALNON, Member 20 JOSE MARCH-LEUBA, Member 21 DAVID PETTI, Member 22 JOY L. REMPE, Member 23 MATTHEW W. SUNSERI, Member 24 ACRS CONSULTANT:

25 STEVE SCHULTZ NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

2 1 DESIGNATED FEDERAL OFFICIAL:

2 CHRISTOPHER BROWN 3

4 ALSO PRESENT:

5 TIMOTHY LUPOLD, NRR 6 SCOTT MOORE, Executive Director, ACRS 7 TOM SCARBROUGH, NRR 8 JAMES STECKEL, RES 9 EDWARD STUTZCAGE, NRR 10 IAN TSENG, NRR 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

3 1 AGENDA 2 Item Page 3 Opening Remarks and Objectives, 4 Professor Ron Ballinger, ACRS.......................4 5 Staff Opening Remarks 6 Ian Tseng, Acting Branch Chief, NRR.................8 7 Reason for the Revision 8 James Steckel, RES/DE/RGPMB.........................8 9 Key Changes and Response to Public Comments 10 on Proposed Revision 6 to Regulatory Guide 11 1.26-Draft Regulatory Guide 1371 12 Thomas Scarbrough, NRR/DEX/EMIB....................12 13 Edward Stutzcage, NRR/DRA/DRCB.....................18 14 Timothy Lupold, NRR/DANU/UTB1......................22 15 Committee Discussion 16 Ron Ballinger, ACRS................................23 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

4 1 P R O C E E D I N G S 2 9:30 a.m.

3 CHAIR BALLINGER: Good morning. It's 4 9:00. And we'll start our meeting. The meeting will 5 now come to order.

6 This is a meeting of the Advisory 7 Committee on Reactor Safeguards Subcommittee on 8 Metallurgy and Reactors Fuels. I'm Ron Ballinger, 9 chairing this subcommittee meeting.

10 The ACRS members in attendance are Charles 11 Brown, Dave Petti, Dennis Bley, Greg Halnon, Jose 12 March-Leuba, Joy Rempe, and Vesna Dimitrijevic.

13 MEMBER SUNSERI: Hey, Ron. This is Matt.

14 CHAIR BALLINGER: Say again.

15 MEMBER SUNSERI: Matt Sunseri --

16 CHAIR BALLINGER: Oh, how did I manage to 17 do that? Well, you're not on the list. Okay. Sorry, 18 sorry.

19 The purpose of today's meeting is to 20 discuss Reg Guide 1.26, Revision 6, Quality Group 21 Classifications and Standards for Water-, Steam-, and 22 Radioactive-Waste-Containing Components of Nuclear 23 Power Plants.

24 By way of background, the Committee has 25 previously reviewed Revision 5 of Reg Guide 1.26. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

5 1 as a result of this review, we made the following 2 recommendation, in quote, the next revision of Reg 3 Guide 1.26 should be broadened to include a set of 4 basic principles for assignment of components to each 5 quality group.

6 Revision 6 of this Reg Guide is largely 7 responsible, responsive to our recommendation. It now 8 includes an appendix, Appendix A, Alternative 9 Classification of Components in Light-Water-Cooled 10 Nuclear Power Plants, and expands the discussion of 11 component classifications. This represents a 12 substantial expansion.

13 Revision 6 also provides an expanded 14 discussion of the use of risk-informed input to the 15 classification of components.

16 The subcommittee will gather information, 17 analyze relevant issues and facts, and formulate 18 proposed positions and actions as appropriate.

19 The ACRS was established by statute and is 20 governed by the Federal Advisory Committee Act, FACA.

21 The NRC implements FACA in accordance with its 22 regulations found in Title 10 of the Code of Federal 23 Regulations, Part 7.

24 The committee can only speak through its 25 published letter reports. We hold meetings to gather NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

6 1 information and perform preparatory work that will 2 support our deliberations at a full committee meeting.

3 The rules for participation in all ACRS 4 meetings, including today's, were announced in the 5 Federal Register on June 13, 2019.

6 The ACRS section of the U.S. NRC public 7 website provides our charter, bylaws, agendas, letter 8 reports, and full transcripts of all full and 9 subcommittee meetings, including slides presented at 10 the meetings. The meeting notice and agenda for this 11 meeting were posted there.

12 As stated in the Federal Register notice 13 and in the public meeting notice posted to the 14 website, members of the public who desire to provide 15 written or oral input to the subcommittee may do so 16 and should contact the designated federal official 17 five days prior to the meeting as practical. And I 18 might add the designated federal official for this 19 meeting is Christopher Brown.

20 Time is provided in the agenda after 21 presentations are completed for this oral statement 22 and for spontaneous comments from members of the 23 public attending or listening to our meetings.

24 Today's meeting is being held over 25 Microsoft Teams, which includes a telephone bridge NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

7 1 line allowing participation of the public over the 2 computer, over their computer using Teams or by phone.

3 A transcript of today's meeting is being 4 kept. Therefore, we request that meeting participants 5 on Teams and on the Team call-in line identify 6 themselves when they speak and to speak with 7 sufficient clarity and volume so they can be readily 8 heard.

9 Likewise, we request that meeting 10 participants keep their computer and/or telephone 11 lines on mute when not speaking.

12 At the end when we ask for public 13 comments, you'll need to use star 6 I believe to 14 activate your participation, if you will.

15 At this time, I ask the Teams attendees to 16 make sure they are muted so we can commence the 17 meeting.

18 We'll now proceed and call on Ian Tseng, 19 I hope I'm pronouncing that right, Acting Chief for 20 Mechanical Engineering and Inservice Testing Branch, 21 for opening remarks. Ian?

22 MR. TSENG: Hello, everybody. Thank you 23 all for gathering and thank you for your time. Thank 24 you to the ACRS for your time and your inputs for 25 Revision 5 and into Revision 6 of Reg Guide 1.26.

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8 1 You know, based on your recommendations 2 and other input, we feel that Reg Guide 1.26 3 represents, and Revision 6 represents a substantial 4 improvement, as you discussed earlier. And we look 5 forward to your further feedback and discussion on 6 this topic. Thank you.

7 CHAIR BALLINGER: Thank you. One last 8 thing, I would ask the members as part of the 9 observing the presentation to consider whether or not 10 we should write a letter based on this review.

11 We haven't scheduled a meeting, a 12 presentation at a full committee for December. But we 13 could schedule it at a later date. So please keep 14 that in mind for our discussion at the end.

15 Okay. I think it's -- is it Jim Steckel 16 that's going to do the presentation?

17 MR. STECKEL: Yes, it is. Good morning to 18 the committee members. This is Jim Steckel. I've 19 been the designated project manager for actually close 20 to the two years now that it's taken to bring this to 21 fruition. And as was pointed out a moment ago, Ian 22 Tseng is the branch chief.

23 And the other members that had significant 24 input to this technically are shown, Tom Scarbrough, 25 Ed Stutzcage, Tim Lupold, Nick Hansing. Nick Hansing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

9 1 was the original technical lead on this, and he's come 2 back to help support the presentation, and Tuan Le.

3 I'd like to move forward then with the key 4 changes summarized in just this one slide here.

5 Revision 5 was an administrative update. And the 6 proposed Rev. 5 was presented to ACRS in October 2016.

7 The ACRS letter from that time stated the Rev. 5 8 should be issued. The next revision should be 9 broadened to include basic principles for assignment 10 of components to each quality group.

11 The EDO responded indicating that Rev. 5 12 would be issued, and Reg Guide 1.26's next revision 13 would address the ACRS recommendations.

14 And the NRC issued proposed Rev. 6 to Reg 15 Guide 1.26, which happened to be Draft Guide 1371, for 16 public comment in April of this year. Some comments 17 were received back. And those comments have attempted 18 to be answered as well in this revision.

19 The key changes include a new appendix, 20 which is the alternative classification. And it 21 discusses component classification methods described 22 in the ANSI Standard 58.14 from 2011.

23 The updated NRC staff position on 24 classification of Quality Group C components was also 25 reflected in the latest guidance on systems that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

10 1 contain radioactive material. And the NRC staff 2 improved proposed Revision 6 in response to public 3 comments.

4 We'll be switching to different speakers 5 as we go through the slides. Of course, if you have 6 any comments or questions at any time, you may go 7 ahead and ask.

8 The Appendix A to Revision 6 indicates the 9 applicant or licensee may propose use of the 10 classification method in ANSI 58.14 subject to 11 considerations discussed in Reg Guide 1.26, Appendix 12 A.

13 ANSI 58.14 scope is broader than that 14 indicated in Reg Guide 1.26 to apply to pressure 15 integrity for water, steam, or radioactive material 16 components.

17 ANSI 58.14 does not include a radiological 18 criteria in Reg Guide 1.26 to complement application 19 of ANSI 58.14 with regard to Reg Guide 1.26. We will 20 hear clarifications on these items as we go through 21 the slides.

22 Based on terminology differences, ANSI 23 58.14 users should consider full scope of 10 CFR Part 24 50, Appendix A when preparing their applications.

25 Continuing with Appendix A, specific NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

11 1 guidance provided for ANSI 58.14 users in developing 2 Class 1 to Class 4 Quality Group A to D is included.

3 The user should apply applicable ASME Boiler and 4 Pressure Vessel Code, Section 3, Subsection NF for 5 snubbers. ANSI 58.14 users should review plant-6 specific design in comparison to Reg Guide 1.26.

7 Because specific Reg Guide 1.26 topics 8 such as the spent fuel pool are not addressed in ANSI 9 58.14, users should ensure that containment 10 penetration regulations are all met. And applicable 11 users may include 10 CFR 50.69, risk-informed 12 categorization and treatment as part of 13 classification.

14 In Quality Group C, the modification is 15 that systems other than radioactive waste management 16 not covered by regulatory positions 2(a) to 2(c) that 17 contain or may contain radioactive material and whose 18 postulated failure could result in conservatively 19 calculated potential offsite doses that exceed 0.1 rem 20 total effective dose equivalent, only single component 21 failures need be assumed for those systems located in 22 Seismic Category I structures.

23 And no credit should be taken for 24 automatic isolation from other components in the 25 system or for treatment of released material unless NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

12 1 the isolation or treatment capability is designed to 2 the appropriate seismic and quality group standards 3 and can withstand loss of offsite power in a single 4 failure of an active component.

5 I believe Tom Scarbrough is designated to 6 step in and go --

7 MR. SCARBROUGH: Yes --

8 MR. STECKEL: -- through some of the 9 technical components.

10 MR. SCARBROUGH: Thanks, Jim. This is Tom 11 Scarbrough. I'm in the Mechanical Engineering and 12 Inservice Testing Branch in NRR.

13 The next slide, if you want to, Jim, move 14 us down to the next slide. Yeah, so in response to 15 all the comments, we received a few comments, not 16 really a significant amount.

17 The first one had to do with our reference 18 to the regulations in the introductory part of the Reg 19 Guide. And the public comments suggested that we 20 include references to 10 CFR 50.54, which is 21 conditions of licenses.

22 And it discusses, you know, the SSCs 23 subject to the codes and standards in 55, 10 CFR 50.55 24 Alpha must be designed and fabricated, erected, 25 constructed, tested, and inspected to quality NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

13 1 standards commensurate with the importance to safety 2 and the safety functions performed. And we agreed 3 with that. So we include that in the introductory 4 portion.

5 And also another, the comment also 6 suggested that we reference 10 CFR 50.55, which is 7 conditions for construction permits, combined 8 licensees, et cetera. And that's a similar 9 requirement that you meet the requirements of 10 CFR 10 50.55 Alpha. And so we included that as well. So we 11 agreed with those comments.

12 Another public comment had to do with the 13 reference to 50.69. Now, the ANS standard does refer 14 to 50.69 and indicate that that is another 15 classification approach that you could use.

16 And the public comment suggested that we 17 include some more detail regarding table 1, which sort 18 of breaks up the classification in Reg Guide 1.26 into 19 several different classes. And so we added that.

20 It's a rather long footnote. But it 21 describes sort of the concept of 50.69 and references 22 back to some of the statements that the Commission 23 made in the Federal Register notice when 10 CFR 50.69 24 was issued finally.

25 And it talks about RISC-3 equipment, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

14 1 is safety-related but low safety significant, and 2 RISC-4, which is nonsafety-related, low safety 3 significant.

4 But basically it talks about the fact that 5 even though you're not applying the detailed, some of 6 the detailed special treatment requirements, there's 7 still an expectation that the equipment is designed to 8 be able to perform its safety function.

9 It still has to have environmental 10 capability. It still has to have seismic capability.

11 But the amount of sort of special treatment QA could 12 be reduced for that, those types of components.

13 So that's sort of the message there that's 14 in that footnote for those. So we added that. Jim, 15 next slide, please. Another -- I think we went too 16 far.

17 MR. STECKEL: Going the wrong direction.

18 Can we go down?

19 MR. SCARBROUGH: There we go.

20 MR. STECKEL: And --

21 MR. SCARBROUGH: There we go. Great.

22 Thank you.

23 Another one had to do with a reference to 24 Quality Group C components. And it was asking about, 25 you know, it sort of was thinking that we were making NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

15 1 all important safety equipment that goes beyond 2 safety-related in Quality Group C. And we weren't 3 really.

4 What we were talking about was if it was 5 such that it had radioactive material and things of 6 that nature, we added a statement in Reg Guide 1.26 7 that if the component's failure could result in a 8 significant offsite release they should be included in 9 Quality Group C.

10 We weren't trying to say that all 11 important safety equipment is Group C. And so we 12 explained that in the response about the comments.

13 So we were mostly talking about spent fuel 14 pools, because the ANS standard doesn't really discuss 15 the concept of spent fuel pools very, what we thought 16 in much detail. But they are covered in Reg Guide 17 1.26.

18 So we wanted to make sure there wasn't a 19 disconnect between the ANS standard and the guidance 20 that's in Reg Guide, you know, 1.26. So that was --

21 we explained that in the response to public comments.

22 MEMBER HALNON: Hey, Tom?

23 MR. SCARBROUGH: Yes.

24 MEMBER HALNON: Tom, this is Greg Halnon.

25 Just a quick question. Something got my interest.

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16 1 When you talk about systems with 2 radioactive materials, is that by design or by actual 3 condition, because -- the reason I ask is because I 4 know I worked in a plant where we backed up a lot of 5 radioactive fluid into the nitrogen system, which was 6 not supposed to be radioactive but then forever now it 7 was in the radioactive system. Does that change the 8 classification, or do you just go by what it's 9 designed to do?

10 MR. SCARBROUGH: Well, this is the design 11 aspect, right. So this is -- at this point, it's 12 still in the design phase. I mean, that would 13 definitely have the licensee go back and rethink 14 whether or not this might need to be reclassified.

15 But this is the initial design, you know, 16 qualification, sort of classification for the 17 components.

18 MEMBER HALNON: Okay. Because, you know, 19 some of these things are in situ. I mean, some of 20 these plants will be trying to -- for instance, 50.69 21 classification system is being done after 30 years of 22 operation.

23 So I guess you'd have to start with where 24 you're at. I mean, you can't go back and say, well, 25 it was never supposed to be radioactive, so I can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

17 1 classify it as something else.

2 MR. SCARBROUGH: Right. And it should --

3 I'm not sure if licensees would go back and try to 4 revamp their Reg Guide 1.26 classification if they're 5 going to use 50.69. They might start from where they 6 are and move forward --

7 MEMBER HALNON: Okay. That's what I 8 figured.

9 MR. SCARBROUGH: Yeah. I think where this 10 might come in handy was for the new small reactors 11 that have very few valves and maybe sometimes no pumps 12 at all, this ANS standard might be very helpful for 13 them, because it's more of a holistic approach than 14 maybe what was done in the past for the very large 15 light water reactors.

16 So I think, you know, in this case, you 17 know, some small reactors might think that this is a 18 more straightforward approach for them than what maybe 19 has been used in the past.

20 MEMBER HALNON: Okay. Thanks. Appreciate 21 it.

22 MR. SCARBROUGH: Thank you. And then the 23 next bullet here has important to safety. I know 24 there's a lot of discussion going on with important to 25 safety and that, and there's a whole different staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

18 1 effort looking at important to safety.

2 But from the Reg Guide 1.26 perspective, 3 we did not feel we needed to go back and address that 4 aspect for Reg Guide 1.26. You know, that's a whole 5 different effort to look at that area. So we 6 explained that, you know, we were not going to try to 7 tackle that issue as part of this Reg Guide. Okay.

8 So next slide, please, Jim.

9 MR. STECKEL: It's a little sluggish.

10 MR. SCARBROUGH: Okay. No problem. Yeah, 11 I know how that is.

12 The next slide has to do with the change 13 in the threshold for classification of systems 14 containing radioactive material of Quality Group C.

15 And if Ed is on the phone, Ed, do you have 16 anything to add? Do you want to add regarding the 17 change we made regarding the Quality Group C for 18 radioactive material?

19 MR. STUTZCAGE: Yeah, I could do that. No 20 problem, Tom. Thanks. Yeah, this is Ed Stutzcage 21 with the Radiation Protection and Consequence Branch.

22 So we made the change to this section. So 23 Reg Guide 1.26 always had this criteria on the 24 radiological dose criteria for Quality Group C. And 25 the criteria since Rev. 1 in 1974 has been 500 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

19 1 millirem whole body or its equivalent to any part of 2 the body.

3 And as you know, that was tied to the, I 4 mean, the regulation for the public dose limit. And 5 that regulation was changed in the 1990s.

6 And the majority of our guidance that had 7 used 500 millirem in the past, for example, for liquid 8 and gaseous tank failures in BTP 11-5 and 11-6, that 9 has long been updated from 500 millirem to 100 10 millirem. And there's a few other guidance, too.

11 So we thought it was appropriate to update 12 that from 500 to 100 millirem. And also the whole 13 body criteria is obviously the old dose methodology, 14 which the majority of guidance and regulations and 15 stuff have been updated to TEDE. So we changed that 16 to 100 millirem TEDE.

17 And the other piece of that was it 18 referenced meteorological information from Reg Guide 19 1.3 and 1.4, which are, have been withdrawn reg 20 guides. So we wanted to remove that reference. So 21 that's really what we did in regard to that.

22 MR. SCARBROUGH: Okay. Thanks, Ed. So 23 the next bullet had to do with the reference to, so 24 the guidance for 50, the 10 CFR 50.69. There was a 25 discussion there of the public comments said, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

20 1 know, should we go back and revise Reg Guide 1.201, 2 which is the guidance document for 10 CFR 50.69.

3 And we replied, what we did was we 4 expanded the discussion or we have a discussion in Reg 5 Guide 1.26, Appendix A to talk about that there's this 6 other alternative approach for classification 50.69, 7 and the guidance for that is in Reg Guide 1.201.

8 But we didn't feel that we should try to 9 go in and start adding guidance that would be more 10 applicable to 1.201 in Reg Guide 1.26. That's really 11 more appropriate to put that right into 1.201.

12 Now, in the future, there might be some 13 update to Reg Guide 1.201, because we do have 14 licensees who are implementing 50.69. There's been 15 feedback on that approach, on how that is. And 16 there's some new approaches that are actually being 17 discussed regarding classification for 50.69.

18 So I can definitely see in the future 19 there would be, you know, a consideration to update 20 Reg Guide 1.201 to include that new information. But 21 we didn't want to try to do that here. We're going to 22 try to keep that separate and have that applied right 23 in Reg Guide 1.201.

24 Then the last bullet there just had the 25 total suggestion. We know, for example, there was a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

21 1 place where in the subcategory of Quality Group C we 2 had and, then we had or between the subparagraphs.

3 And we decided we'd just go back to the 4 original language in one of the initial reg guide 5 revisions to just not have any and, the word and, or 6 the word or in between them. It just was adding 7 confusion.

8 So we just went back to the original 9 language from the Reg Guide, which everyone had used 10 in the past. So we made that clarification. And we 11 thought that was a good clarification.

12 So basically that was our, the public 13 comments. It was a very, relatively short list of 14 public comments that we had. We didn't seem to have 15 people have any real concern with what we were saying 16 in Appendix Alpha. So that was good to see.

17 And then if we go into the next slide, it 18 has to do with high temperature reactors. One of the 19 discussion items we had way back in 2016 with ACRS was 20 how do we deal with non-light water reactors.

21 And we did explore that effort. And we 22 actually made some initial efforts in drafting some 23 things. But it was determined that it was really more 24 appropriate for, you know, the advanced reactor group.

25 And so Tim Lupold, if you're there, can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

22 1 you talk about this slide?

2 MR. LUPOLD: I am here, Tom. Thank you.

3 Yes, originally we had intended to include the 4 standards related to advanced reactors, high 5 temperature reactors in Reg Guide 1.26.

6 But as that Reg Guide went through the 7 reviews and the various divisions within the NRC, the 8 Division of Advanced Reactors and Non-Power 9 Utilization Facilities decided that it was more 10 appropriate to separate the requirements for the 11 advanced reactors from those requirements from light 12 water reactors.

13 Therefore, the decision was made, take 14 that information and put it into the next revision of 15 Reg Guide 1.87, which is the reg guide which was being 16 used to assess the acceptability of the ASME Code, 17 Section 11, Division 5 for high temperature reactors.

18 That was brought, that reg guide was 19 actually brought to ACRS back in July. It was on July 20 20th. And Appendix A to that draft guide contained 21 the criteria and the categorization for components 22 listed in that.

23 So that's about all I really have, if 24 there are any questions. If not, we can move on to 25 the next slide.

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23 1 MR. SCARBROUGH: Okay. Jim, do you want 2 to take it from here?

3 MR. STECKEL: Yes, yes, I shall. So this 4 latest revision of 1.26 has been through NRC E 5 concurrence review. And the NRC staff will address 6 NRC management and ACRS recommendations when we are 7 finalizing everything.

8 Remember, it's been through public comment 9 already. And we plan to issue Rev. 6 of 1.26 by early 10 sometime next year. You know, we just wrap up a few 11 more things, and it should be available and published 12 early next year. And basically that concludes our 13 presentation.

14 CHAIR BALLINGER: Thank you. I'm not sure 15 whether we've established a record. But we've got to 16 be pretty close for time.

17 We'd like to open the discussion for 18 members, particular remember the question that I asked 19 about earlier, should we consider a letter or not for 20 this.

21 MEMBER BLEY: Hey, Ron, it's Dennis.

22 CHAIR BALLINGER: Yeah.

23 MEMBER BLEY: By the way, you're on a roll 24 after yesterday.

25 CHAIR BALLINGER: Yeah, I know. That's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

24 1 right.

2 (Laughter.)

3 CHAIR BALLINGER: Well, we'll mess that up 4 tomorrow.

5 MEMBER BLEY: I'd just say, I really 6 appreciated the staff's presentation. It was well 7 organized and discussed. And I don't know if they 8 were just responsive to us or if this was always their 9 intent. But I am pleased that they've addressed those 10 things we brought up previously.

11 So, you know, a letter might be 12 appropriate but very short to address, say, that we 13 agree they've responded to our previous comments. But 14 I don't think it's really necessary. I don't know if 15 the staff has said whether they'd really like one or 16 not.

17 So I kind of leave it back to you. I 18 think it would be reasonable to write a very short 19 letter. If we want to, I'd support that.

20 CHAIR BALLINGER: Other members?

21 MEMBER HALNON: Yeah, Ron, this is Greg.

22 I agree with Dennis. You know, normally when I read 23 through these things, I get a page of notes and 24 questions and whatnot. And I don't even have two 25 lines of questions that I had.

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25 1 And so I think it's a good job. I, you 2 know, wasn't here for the first subcommittee when this 3 was discussed. But the new document looks good. So 4 I support what Dennis said.

5 CHAIR BALLINGER: Yeah, this is one case 6 at least in my memory, not many before this, where we 7 have a one-to-one correlation almost exactly between 8 our recommendations and the next revision. So that I 9 think was very well done.

10 MEMBER REMPE: So this is Joy. And this 11 seems like a good candidate for this alternate 12 process, where it's discussed at P&P, and you'd make 13 the comment that at the subcommittee meeting all 14 members thought the staff did a good job and addressed 15 our prior comments, and we didn't think a letter was 16 necessary, but we thought it was a good job and have 17 it as a memo that's documented, unless the staff wants 18 a letter.

19 CHAIR BALLINGER: Well, let me ask Ian if 20 he's still there.

21 MR. TSENG: I'm here. This is Ian. Tom, 22 do you have any thoughts? I mean, I could kind of go 23 either way.

24 MR. SCARBROUGH: Yeah, this is Tom 25 Scarbrough. You know, we had significant discussion NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

26 1 at the previous meeting in terms of the direction.

2 And the ACRS provided very strong, good direction on 3 what we should do with Reg Guide 1.26. And we 4 followed through on that.

5 And since we did have, you know, an EDO 6 letter going back, I mean, it was kind of elevated in 7 that sense. So it seemed, to me it seemed like 8 elevated.

9 So, if it was agreeable to ACRS to have a 10 brief letter going back, I think that would help sort 11 of close the loop. But it's really up to ACRS.

12 Thanks.

13 CHAIR BALLINGER: Of course, knowing, of 14 course, that we don't speak except as a committee in 15 the whole (audio interference) and that would have to 16 be a brief presentation, I don't know how you could 17 get much briefer than the one you gave, but at that 18 meeting, and then we would produce a letter. So that 19 would be the procedure for doing a letter.

20 For doing a P&P, the P&P option that Joy 21 mentioned, that could happen in December. But the way 22 I'm reading it is that the staff would appreciate a 23 letter, as short as it might be. And so that would be 24 at least my thought.

25 So we have a number of other members NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

27 1 listening in. And I'd appreciate if they could chime 2 in and provide their opinion, because this has got to 3 be a sort of a consensus.

4 MEMBER MARCH-LEUBA: Yeah, this is Jose.

5 A question for the staff, considering that this letter 6 will not be able to be issued until at least the first 7 week of February of next year, is your opinion that 8 the letter will be valuable still stand?

9 MR. SCARBROUGH: Well, I think -- this is 10 Tom Scarbrough again. I think the fact that the 11 letter might not come out until, you know, February, 12 I know Jim was hoping to have this out in early 13 January.

14 So maybe the memo might be an acceptable 15 alterative, because it will close the loop on this.

16 So there will be a documented close-out. So, with 17 that understanding, I would be fine with the 18 memorandum approach.

19 MR. TSENG: And this is Ian. I support 20 that path forward as well.

21 MEMBER MARCH-LEUBA: So I don't know if 22 we're voting, Ron. But my vote is to do the memo in 23 the first week of December.

24 CHAIR BALLINGER: That is fine with me.

25 (Simultaneous speaking.)

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28 1 CHAIR BALLINGER: Dennis, what do you 2 think?

3 MEMBER BLEY: I agree. Let's do the memo.

4 CHAIR BALLINGER: Okay.

5 MEMBER SUNSERI: Hey, just as a, I mean, 6 I don't -- I support -- this is Matt. I support the 7 memo kind of approach.

8 But I'm looking at the December agenda 9 right now. And presuming that this is a short 10 presentation, I mean, as short as it was today, it was 11 pretty short, and if we had the letter well drafted 12 and it was short, there's time in December to get it 13 out.

14 MEMBER REMPE: Matt, would it have to be 15 reposted in the Federal Register?

16 MEMBER SUNSERI: We could do it as part of 17 P&P I believe, because we would be doing the memo as 18 part of P&P anyway. So --

19 MEMBER REMPE: A presentation by the 20 staff, you could have a full letter in P&P.

21 MEMBER SUNSERI: I mean, I was trying to, 22 I'm just trying to create the opportunity, Joy, you 23 know.

24 MEMBER REMPE: I just am wondering about 25 the rules of the game here. This is more about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

29 1 process than -- I understand what you're saying. But 2 I thought that would be hard to bring in a new topic.

3 MEMBER BLEY: No, we're more than two 4 weeks out. They can do an addenda. We've done that 5 many times.

6 MEMBER REMPE: Okay. That's what I 7 thought you'd have to do.

8 CHAIR BALLINGER: Okay. So let's be --

9 let me make sure we're clear. The December letter 10 would require a presentation by the staff. The memo 11 does not require, would not require a presentation by 12 the staff.

13 So I guess I'm now rereading for the third 14 time the thoughts. And that is that should we be able 15 to adjust the schedule that we would ask the staff for 16 a presentation, as brief as it might be, in December, 17 and we would produce a letter.

18 MEMBER SUNSERI: Okay. I'm going to 19 withdraw my comment. We're making it way too 20 complicated. Let's just --

21 CHAIR BALLINGER: Yeah, yeah.

22 MEMBER HALNON: So, to be clear, we're 23 talking about the memo that Scott would write as part 24 of the P&P, correct?

25 CHAIR BALLINGER: Yeah. What would happen NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

30 1 is I would produce a short paragraph or so for 2 including in P&P. We would have a discussion. And at 3 that point, if we're in agreement, then there would be 4 a memo that Scott would produce.

5 MEMBER HALNON: Right.

6 MEMBER BLEY: Hey, Ron, it's Dennis. Last 7 thing, because I agree with Matt on this, you are 8 chairman of the subcommittee. Matt's chairman of the 9 full committee. If you and Matt could chat offline 10 after this, you could pick the best path forward.

11 And we all seem supportive of either 12 approach. So, I mean, that's -- we don't need to 13 negotiate crossing the Ts and all that here.

14 CHAIR BALLINGER: That's fine. That's 15 fine as well. Okay. Unless there are other comments 16 from members suggesting a different path forward, that 17 would be what I would propose.

18 The five-second doughnut and committee 19 member rule. Hearing none, then that's what we will 20 do. I will get together with Matt. And we'll make a 21 decision.

22 Now, we need to also -- unless there are 23 other comments from members, we need to now take, ask 24 for public comments. If there are members of the 25 public that would like to make a comment, I think you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

31 1 need to use star 6 and then make your comment, please.

2 I guess the comment and doughnut rule 3 applies to public comments. So, having, hearing no 4 public comments, unless there are other last minute 5 comments, we appreciate, I can speak for the committee 6 and they can speak as well, the presentation.

7 Once again, it was a case where the staff 8 in large part responded directly to a committee letter 9 for Revision 5. And we appreciate that greatly.

10 So, unless there are other comments, then 11 I would say that this meeting is adjourned.

12 (Whereupon, the above-entitled matter went 13 off the record at 10:09 a.m.)

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NRC Regulatory Guide 1.26, Revision 6 Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants NRC Staff ACRS Presentation November 16, 2021

NRC Staff Team Members for RG 1.26 Revision

  • James Steckel, RGPMB/DE/RES
  • Edward Stutzcage, DRCB/DRA/NRR

Reason for Revision

  • Revision 5 to RG 1.26 was an administrative update
  • Proposed Revision 5 presented to ACRS in October 2016
  • ACRS letter dated 10-17-2016 stated:

- Revision 5 to RG 1.26 should be issued

- Next revision to RG 1.26 should be broadened to include basic principles for assignment of components to each quality group

  • EDO responded on 12-13-2016 that Revision 5 to RG 1.26 would be issued, and next revision to RG 1.26 would address ACRS recommendations
  • NRC issued proposed Revision 6 to RG 1.26 (DG-1371) for public comment in April 2021 3

Key Changes

  • New Appendix A, Alternative Classification for Components in Light-Water-Cooled Nuclear Power Plants, discusses component classification method described in American National Standards Institute (ANSI)/American Nuclear Society (ANS) Standard 58.14-2011, Safety and Pressure Integrity Classification Criteria for Light Water Reactors.
  • Updated NRC staff position on classification of Quality Group C components to reflect latest guidance on systems that contain radioactive material.
  • NRC staff improved proposed Revision 6 to RG 1.26 in response to public comments.

4

Appendix A to Revision 6 to RG 1.26

  • Applicant or licensee may propose use of the classification method in ANSI/ANS-58.14-2011 subject to considerations discussed in RG 1.26, Appendix A
  • ANSI/ANS-58.14 scope is broader than RG 1.26 to apply to pressure integrity for water, steam, or radioactive material components

Appendix A to Revision 6 to RG 1.26 (continued)

  • Specific guidance provided for ANSI/ANS-58.14 users in developing Class 1 to 4 (Quality Group A to D)
  • Users should ensure that containment penetration regulations are met
  • Applicable users may include 10 CFR 50.69 (risk-informed categorization and treatment) as part of classification 6

Quality Group C Modification in RG 1.26

  • Systems, other than radioactive waste management systems, not covered by Regulatory Positions 2.a through 2.c that contain or may contain radioactive material and whose postulated failure would result in conservatively calculated potential offsite doses that exceed 0.1 rem total effective dose equivalent; only single component failures need be assumed for those systems located in Seismic Category I structures, and no credit should be taken for automatic isolation from other components in the system or for treatment of released material, unless the isolation or treatment capability is designed to the appropriate seismic and quality group standards and can withstand loss of offsite power and a single failure of an active component.

7

Response to Public Comments

- Response: Complete

- Response: Added detailed footnote to Table 1 in RG 1.26 discussing 10 CFR 50.69 8

Response to Public Comments (continued)

  • Comment: Add technical basis for including important to safety items in Quality Group C or delete

- Response: Explained ANSI/ANS-58.14 provides consensus recommendation for Class 3 components (Quality Group C) and that applicants/licensees may propose a different classification method for those components

  • Comment: Term important to safety is ambiguous

- Response: NRC staff does not consider a safety need to develop a specific definition of important to safety at this time 9

NRC Response to Public Comments (continued)

  • Comment: Explain change to threshold for classification of systems containing radioactive material as Quality Group C

- Response: RG 1.26 updated to clarify reason for change to threshold for classification of systems containing radioactive material

  • Comment: Appendix A to RG 1.26 contains information that should be included in RG 1.201

- Response: RG 1.26, Appendix A, revised to clarify reference to RG 1.201 with consideration of future improvements to RG 1.201

  • Comment: Specific editorial suggestions

- Response: Complete 10

High Temperature Reactor Quality Group Classification

  • Proposed Revision 2 to RG 1.87, Acceptability of ASME Code,Section III, Division 5, High Temperature Reactors, (DG-1380) issued for public comment in August 2021.
  • Appendix A, High Temperature Reactor Quality Group Classification, in DG-1380 establishes quality group assignments for mechanical systems and components for non-light-water reactors.
  • DG-1380 discussed with ACRS on July 20, 2021.
  • RG 1.26 relies on DG-1380 for high-temperature reactor quality group classification.

11

Next Steps

  • NRC staff has distributed proposed Revision 6 to RG 1.26 for NRC management review
  • NRC staff will address NRC management and ACRS recommendations when finalizing Revision 6 to RG 1.26
  • NRC plans to issue Revision 6 to RG 1.26 by early 2022 12

QUESTIONS?

13

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