ML23087A087
| ML23087A087 | |
| Person / Time | |
|---|---|
| Issue date: | 03/01/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2289 | |
| Download: ML23087A087 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Kairos Power Licensing Subcommittee Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, March 1, 2023 Work Order No.:
NRC-2289 Pages 1-160 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 KAIROS POWER LICENSING SUBCOMMITTEE 7
+ + + + +
8 WEDNESDAY 9
MARCH 1, 2023 10
+ + + + +
11 The Subcommittee met via Teleconference, 12 at 8:30 a.m. EST, David A. Petti, Chair, presiding.
13 COMMITTEE MEMBERS:
14 DAVID A. PETTI, Chair 15 RONALD G. BALLINGER, Member 16 VICKI M. BIER, Member 17 CHARLES H. BROWN, JR., Member 18 VESNA B. DIMITRIJEVIC, Member 19 GREGORY H. HALNON, Member 20 WALTER L. KIRCHNER, Member 21 JOSE MARCH-LEUBA, Member 22 JOY L. REMPE, Member 23 MATTHEW W. SUNSERI, Member 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
2 ACRS CONSULTANTS:
1 DENNIS BLEY 2
4 DESIGNATED FEDERAL OFFICIAL:
5 WEIDONG WANG 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 C O N T E N T S 1
Page 2
ACRS Chairman Introductory Remarks 4
3 NRC Staff Introductory Remarks 6
4 Standards for Review of Test Reactors 5
and Construction Permits 8
6 Hermes Non-Power Reactor Preliminary Safety 7
Analysis -
8 Chapter 1, The Facility..........
9 9
Hermes Non-Power Reactor Preliminary Safety 10 Analysis -
11 Chapter 10, Experimental Facilities...
102 12 Chapter 12, Conduct of Operations....
132 13 Chapter 14, Tech Specs 139 14 Chapter 16, Other License Considerations 15 Public Comments................
106 16 Meeting Adjourned 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 P-R-O-C-E-E-D-I-N-G-S 1
8:30 a.m.
2 CHAIR PETTI: Okay. The meeting will now 3
come to order. This is a meeting of the Kairos Power 4
Licensing Subcommittee of the Advisory Committee on 5
Reactor Safeguards.
6 I'm David Petti, Chairman of today's 7
Subcommittee meeting. ACRS Members in attendance are 8
Charles Brown, Jose March-Leuba, Joy Rempe, Matt 9
- Sunseri, Ron Ballinger, Walt
- Kirchner, Vesna 10 Dimitrijevic, Vicki Bier, and Greg Halnon.
11 ACRS Consultants Dennis Bley and Stephen 12 Schultz are also present remotely. Weidong Wang of 13 the ACRS Staff is the Designated Federal Official for 14 this meeting.
15 During today's meeting the Subcommittee 16 will review the staff's safety evaluation on Kairos 17 Power Hermes Non-Power Reactor Preliminary Safety 18 Analysis. The Subcommittee will hear presentations by 19 and hold discussions with the NRC Staff, Kairos Power 20 representations and other interested persons regarding 21 this matter.
22
- First, we'll hear today about the 23 standards that the staff uses to evaluate and test a 24 non-power reactor, since most of what we review is 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
5 power reactors, which is a slightly different 1
standard. So, this is going to help us inform our 2
review.
3 The rules for participation in all ACRS 4
meetings, including today's, were announced in the 5
Federal Register on June 13, 2019. The ACRS Section 6
of the U.S. NRC public website provides our Charter, 7
- Bylaws, Agendas,
- Letters, and of course full 8
transcripts of all full and subcommittee meetings, 9
including slides presented there.
10 The meeting notice and agenda for this 11 meeting were posted there. Today's meeting is open to 12 public attendance. We have received no written 13 statements or requests to make an oral statement from 14 the public.
15 The Subcommittee will gather information, 16 analyze relevant issues and facts, and formulate posi 17
-- proposed positions and actions as appropriate for 18 deliberation by the full Committee.
19 A transcript of the meeting is being kept 20 and will be made available. Today's meeting is being 21 held in person and over Microsoft Teams for ACRS Staff 22 and Members, NRC Staff, and the Applicant.
23 There's also a telephone bridge line and 24 a Microsoft Teams link allowing participation of the 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
6 public.
1 When addressing the Subcommittee, the 2
participants should first identify themselves and 3
speak with sufficient clarity and volume so that they 4
may be readily heard. When not speaking, we request 5
that participants mute their computer microphone or 6
phone by pressing start six.
7 We'll now proceed with the meeting. I'd 8
like to start by calling up Bill Jessup.
9 MR. JESSUP: Thank you Member Petti for 10 the opportunity to present to the Subcommittee today.
11 I'm Bill Jessup, Chief of Advanced Reactor Licensing 12 Branch One in the Division of Advanced Reactors in 13 Non-Power Production and Utilization Facilities, or 14 DANU in the Office of Nuclear Reactor Regulation or 15 NRR.
16 Today the staff will be providing an 17 overview of the strategy that's been implemented to 18 support the staff's review of the Kairos Power 19 Construction permit application for the Hermes test 20 reactor.
21 Our recent interactions with the Kairos 22 Subcommittee have focused on discrete issues related 23 to the Kairos Power fluoride-cooled high temperature 24 reactor technology, also referred to as the KP-FHR 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
7 technology, including recent meetings on topical 1
reports for graphite and metallic materials.
2 Today's presentation will be the first of 3
many over the next several weeks, focused on the 4
staff's review of the broader aspects of the KP-FHR 5
technology as reflected in the Hermes construction 6
permit application.
7 The staff's presentation this morning is 8
going to cover the foundational aspects of the 9
construction permit application and review strategy, 10 including requirements and guidance that are specific 11 to testing facilities and the license type under 12 consideration.
13 The staff provided a similar presentation 14 to the Subcommittee at the outset of the Hermes review 15 in April 2022.
16 Given that we are nearing the end of the 17 construction permit application review, and before we 18 progress into more detailed presentations in the 19 coming weeks, the staff felt it appropriate to revisit 20 the aspects of the review strategy, and also provide 21 some examples of how the strategy was implemented 22 during the review.
23 The staff's looking forward to today's 24 discussion. Always appreciative of the Committee's 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
8 insights and comments.
1 And, with that, I'll turn it back over to 2
you, Member Petti.
3 CHAIR PETTI: We're ready to start.
4 MR. JESSUP: Okay. I'll turn it over to 5
Ben Beasley.
6 MR. BEASLEY: Thank you, Bill. Well, I am 7
Ben Beasley. I am a Project Manager in the Advance 8
Reactor Licensing Branch of DANU and NRR.
9 I'm the lead Project Manager for the staff 10 safety review of the Kairos construction permit 11 application for the Hermes test reactor. Presenting 12 in a few minutes will be Jeff Schmidt, the lead 13 technical reviewer for the application.
14 And, also here to help answer your 15 questions is Ed Helvenston. Ed is also a Project 16 Manager on the Hermes project and is in the Non-Power 17 Production and Utilization Facility Licensing Branch.
18 We will provide a brief overview of the 19 staff's review process and discuss a couple of 20 examples of how we conducted the review of the 21 preliminary design of a non-power testing facility.
22 Next slide, please.
23 So, the review of applications for non-24 light water reactors such as Hermes, is an important 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
9 milestone in advancing nuclear technologies in the 1
United States. It is the responsibility of Kairos and 2
other designers to demonstrate the safety of their 3
designs.
4 The NRC staff must perform its mission of 5
independently reviewing the safety of the designs in 6
an efficient and effective manner. Accordingly, the 7
staff's review of the preliminary design of Hermes was 8
focused on matters that are most safety significant.
9 The scope of the staff's review of the 10 design of a structure system or component was 11 commensurate with the risk posed by that SSC.
12 Although the application provided only 13 preliminary design of a testing facility, the mission 14 of the staff is unchanged. We must have reasonable 15 assurance of adequate protection to public health and 16 safety.
17 MEMBER MARCH-LEUBA: Can I interrupt you 18 in a moment?
19 MR. BEASLEY: Yes.
20 MEMBER MARCH-LEUBA: A PRA has not been 21 before, correct?
22 MR. BEASLEY: Has not.
23 MEMBER MARCH-LEUBA: Okay. So, how do we 24 determine what is risk significant?
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10 Let me be the devil's advocate and I'll 1
give you an extreme. Why are you not deciding by the 2
seat of your pants how this cuts corners in the 3
review?
4 Explain to me that. Why not that?
5 MR. BEASLEY: And so, I -- two thoughts.
6 First, it will be, you know, good for you to have the 7
examples that Jeff presents in a few minutes.
8 And
- second, I
didn't say risk 9
significance, I said safety significance. And so, 10 it's not based on a risk number. It's based on the 11 design of the system and what is needed to assure safe 12 shut down, you maintain subcriticality, you know, 13 provide cooling, those types of things.
14 And so, the design informs what is, needs 15 to be safety related.
16 MEMBER MARCH-LEUBA: I'm taking my 17 argument to extreme, to give you an opportunity. I 18 mean, I'm guessing there was application position, 19 right?
20 You have some slides that only would say 21 that you have not reviewed that method, because it's 22 not needed for a construction license. We will do it 23 later.
24 So, how do you know what the safety 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
11 significance is if you have no confidential what they 1
are?
2 I'm taking this is risk informed safety 3
significant review to an extreme.
4 MR. BEASLEY: Right.
5 MEMBER MARCH-LEUBA: And will let you 6
explain yourself. Jeff is dying here.
7 MR. SCHMIDT: I am. I am.
8 MR. BEASLEY: Well, I was going to say, 9
let -- you know, it's probably a good discussion to 10 have when he presents his examples.
11 MR. SCHMIDT: Yeah. You'll want to get 12 into it when we go down the slide, like the second one 13 down.
14 MEMBER MARCH-LEUBA: You know I'm talking 15 about that.
16 MR. SCHMIDT: Yeah, yeah. We can talk 17 about that.
18 MEMBER MARCH-LEUBA: I'm, you know, I'm 19 not to raise a portion of this risk informed being a 20 risk is mathematically and thoroughly performed 21 properly.
22 It is not mathematically incorrect. It is 23 often used improperly. And, I would like to use this 24 as a forum for discussion of how we have used it.
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12 And again, I'm exaggerating. Okay?
1 Before you do that.
2 MR. BEASLEY: And one other quick thought, 3
we didn't -- we didn't, I forget the term you used, 4
trim back our review, you know, cut corners in the 5
review.
6 MEMBER MARCH-LEUBA: Right.
7 MR. BEASLEY: We did not. You know, we 8
reviewed everything in the application to the extent 9
that information was provided, design information was 10 provided.
11 And so, again, you know, our mission was 12 to assure that its safe. And --
13 MEMBER MARCH-LEUBA: And the -- the scope 14 of the review was commensurate with the risk caused by 15 the design.
16 MR. BEASLEY: So, we can -- yes. We can 17 get into that --
18 CHAIR PETTI: So, let me just --
19 MR. BEASLEY: Now and in the future, in 20 Chapter information.
21 CHAIR PETTI: I might think very simply.
22 Construction permit operating different standards. A 23 non-power reactor power reactor, I think in that four 24 quadrant box it will be helpful to kind of understand, 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
13 you know, you're doing -- this is because that's a 1
construction permit.
2 It would be the same if it were a power 3
reactor or a non-power reactor. This is what I do 4
because it's an S-reactor. But, this is a power 5
reactor.
6 You know, both things are floating in it.
7 MR. BEASLEY: Um-hum.
8 CHAIR PETTI: I think we can get confused 9
sometimes. You know, so you might -- we might ask you 10 to say, okay, so if it were a power reactor, would it 11 be different?
12 Would the standard be different here or 13 not? So, we can figure out is it a CPOL issue? Or is 14 it a non-power reactor power reactor?
15 MR. BEASLEY: Okay.
16 CHAIR PETTI: In terms of the standard.
17 MR. BEASLEY: Yeah. And, I think what 18 we're presenting today will help --
19 CHAIR PETTI: Great.
20 MR. BEASLEY: Come up with that.
21 CHAIR PETTI: Great.
22 MR. BEASLEY: So, onto the next slide.
23 MR. SHAMS: If I may offer this here, 24 because it's --
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14 MEMBER MARCH-LEUBA: Can you state your 1
name?
2 MR. SHAMS: I'm going -- oh, sure. (Off 3
mic comment) Thank you. Mo Shams, I'm with the 4
staff.
5 So, I think these are incredibly important 6
questions. You know, how were we risked informed?
7 How did we apply the regulations?
8 But, I just wanted to make sure that we're 9
reflecting that we did not take any corners or cut any 10 corners in the review.
11 We've done the review as appropriately as 12
-- for the CP level of information needed by the 13 regulation and by the level of review associated with 14 that, as well as what we need for a research reactor, 15 or excuse me, a test reactor, Kairos is a test 16 reactor, what we need for a test reactor.
17 We looked at the regulations, what's 18 required.
And we hopefully throughout the 19 presentation today, we can particularly show you that.
20 It's not about a preference of a power 21 reactor versus a non. At the end of the day, we need 22 to make the safety case.
23 They're reactors. They're important for 24 us to make sure that we've seen the information we 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
15 needed to render the appropriate regulatory findings 1
on them. And, hopefully we can show you how we've 2
done that today.
3 MEMBER MARCH-LEUBA: Okay. If you keep 4
that in mind during the presentation, I won't keep 5
asking the same questions.
6 MR. BEASLEY: Okay. Okay. Well, and we 7
may not fully answer, you know, your concern or your 8
interest until we get into the Chapter presentations.
9 MEMBER MARCH-LEUBA: Yes. Just so you 10 understand, life is a degree of grace and course.
11 And, I'm reducing the area into black and white to 12 make it more to the point where you have to come up 13 with the answer. Whereas, it's 50 percent there.
14 (Off mic comments.)
15 MR. BEASLEY: Next slide, please. So, in 16 accordance with NRC regulations and the Atomic Energy 17 Act any Class 104c facility must be useful in the 18 conduct of research and development activities.
19 In its construction permit application, 20 Kairos states that it plans to apply for a Class 104c 21 utilization facility operating license.
22 Accordingly, the staff conducted its 23 review of the Hermes construction permit application 24 consistent with the regulatory requirements that apply 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
16 to testing facilities and support the conduct of 1
widespread and diverse research and development.
2 Many -- in CFR Part 50 requirements are 3
for power reactors and do not apply for testing 4
facility requirements such as combustible gas control, 5
ECCS requirement for LWRs, environment qualification 6
of electrical equipment, ATWS, and many others.
7 Testing facilities are subject to the 8
cited requirements in 10 CFR Part 100, including 9
accident reference doses. Testing facilities are also 10 subject to a few 10 CFR Part 509 requirements that do 11 not apply to research reactors, including a required 12 ACRS review of construction permit and operating 13 license applications and mandatory hearings for the 14 construction permit application. Next slide.
15 MEMBER BROWN: Does that mean you don't 16 have to talk to us? Is that including the ACRS?
17 So, this is a courtesy? That's the way I 18 read that sentence in that.
19 MR. BEASLEY: No, no. So, for a testing 20 facility, we do have to talk to you. For a research 21 facility, ACRS review is not required.
22 MEMBER BROWN: Okay. I didn't get that 23 differentiation. I'm sorry.
24 MR. BEASLEY: That's okay.
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17 MEMBER BROWN: Now, what is this? Is 1
this a testing facility?
2 MR. BEASLEY: This is a testing facility.
3 MEMBER BROWN: Not research?
4 MR. BEASLEY: Not a research facility, 5
right.
6 MEMBER BROWN: Okay. All right. Thank 7
you. I missed that nuance.
8 MR. BEASLEY: Yeah. And so, there are 9
requirements in 10 CFR 50 that apply to testing 10 facilities that do not apply to research facilities.
11 MEMBER BROWN: Thank you very much.
12 MR. BEASLEY: But then, there's also that 13 distinction of requirements that apply to commercial 14 licenses that do not apply to testing facilities. So, 15 it's kind of the three levels in requirements in CFR 16 50.
17 MEMBER BROWN: Well, my concern well, if 18 this is some kind of parochial protection systems, it 19 is a reactor.
20 MR. BEASLEY: Yes.
21 MEMBER BROWN: It does generate some 22 power. And, it should have safe, reliable reactor 23 protection and whatever -- whatever in lab safeguards 24 are requirement, whatever those are.
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18 I mean, I'm not saying they are, but 1
whatever they are. Okay.
2 MR. BEASLEY: Okay.
3 MEMBER BROWN: That was my concern when I 4
saw that. We lost a bubble, thank you.
5 MR. BEASLEY: Okay.
6 MEMBER REMPE: I have a question actually.
7 I know with Kairos it may not be a concern because 8
they aren't a light water reactor.
9 But, I think you said in the prior slide 10 that when you were talking about Part 50 requirements 11 that for power reactors don't apply to testing 12 facilities. And, you mentioned hydrogen, combustible 13 gas generation, 14 MR. BEASLEY: Right.
15 MEMBER REMPE: You don't have to worry 16 about it. If it were a water one, and it had 17 circular-based cladding, you just won't worry about 18 combustible gas generation?
19 MR. BEASLEY: If it's -- so, the 20 combustible gas control rule does not, it only applies 21 to power reactors.
22 So yes, if it was a water reactor testing 23 facility, then the combustible gas and hydrogen 24 control would not apply.
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19 MEMBER REMPE: That's good insight. That 1
might be less that you're kind of missing something 2
you might want to think about.
3 MR. BEASLEY: Well --
4 MEMBER REMPE: I'm just curious, because 5
it doesn't apply -- if this is just --
6 MR. SHAMS: Dr. Rempe, if I'm -- yes, if 7
I may comment on that, I'm sorry. If it's a relevant 8
act, then we'll look at it, regardless of it.
9 MEMBER REMPE: I would hope so.
10 MR. SHAMS: But, the requirement in the 11 reg -- yeah. The requirement in the Reg is for power 12 reactors. That doesn't mean that we would not look at 13 it as a relevant act for that reactor.
14 MEMBER REMPE: That's good to know. Okay.
15 Everyone in the staff is aware of that too. Okay.
16 MR. SHAMS: Absolutely.
17 MEMBER REMPE: Okay. Thank you.
18 CHAIR PETTI: Yeah. And, there's a 19 regulatory analysis white paper from Kairos where they 20 go through all the rules. And this is one of the ones 21 where the intent, you know, even though it's held to 22 be a specific thing, they argue that something has 23 sort of a relevance in a different sense.
24 MR. BEASLEY: Right.
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20 CHAIR PETTI: And they -- they've got to 1
do it. So, they did a pretty good job, I think, at 2
it.
3 MR. BEASLEY: Right.
4 CHAIR PETTI: And, in the buckets, they 5
both have a different requirement.
6 MR. BEASLEY: Right. And we did the same.
7 CHAIR PETTI: Right.
8 MR. BEASLEY: And so, there is a 9
requirement, 10 CFR 50.46(a), I believe it is, for 10 high point vents, it does not apply to SC facilities.
11 But, there is non-condensable gasses in this design.
12 And so, we asked the question, is it a, 13 you know, is there a need for a high point vent?
14 Would it affect the design if there's non-condensable 15 gases in there?
16 And, it doesn't have an effect on the 17 design. So, that's a case, and just a very small one, 18 where yes, the regulation didn't apply to this 19 facility, but, we considered it anyway just to make 20 sure that it wasn't an issue.
21 MEMBER REMPE: Thank you.
22 MEMBER MARCH-LEUBA: Okay. But, I like 23 his answer. The regulation doesn't tell you thou 24 shall have a high point vent.
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21 But, it tells you you should analyze in 1
Chapter 15 or the actual analysis, and one of them is 2
innovative of gasses. And, if you don't have a way to 3
get rid of them, you have a bad accident.
4 That is how we catch it. And, we keep 5
saying, and again, I do it every single day, on 6
selecting the accidents, we have to start with a white 7
piece of paper, because it's often very human to start 8
with the actions that all reactors have and to scratch 9
out the ones you don't have from that list and add the 10 ones that you do.
11 And, that is something that your review is 12 you have to get to really what is missing is the most 13 important part of all.
14 CHAIR PETTI: So, similarly, the rule will 15 probably act as an ATWS and station blackout. Okay, 16 it's not a primary, but you guys obviously think about 17 those sorts of events, right?
18 MR. BEASLEY: Yes.
19 CHAIR PETTI: For all systems, because, 20 you know, it's sort of a generic issue that you'd want 21 to look at as a for lack of action in the back up.
22 MEMBER HALNON:
- Well, it's my 23 understanding that it was on the applicant to consider 24 that and to justify why they didn't have to have 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
22 beyond design basis type, you know, the ATWS and other 1
things like these events.
2 Did they do that? Or, is that -- I didn't 3
review the safety analysis. But, really it's not 4
applicable to the analysis.
5 But, it was, it's on them to do that and 6
then you guys review it. You shouldn't be left to ask 7
a question or avoid if you don't see that.
8 MR. BEASLEY: Well, yeah. So, if there 9
was something that we felt was needed, then we would 10 ask them for that.
11 MEMBER HALNON: But, that's my point. Is 12 that you shouldn't have to feel it's needed. They 13 should justify regulation by regulation why they 14 shouldn't have to.
15 And, I believe that's in the guidance to 16 do that. I'll have to go back and look. But, I 17 remember reading where the applicant has to consider 18 all the regulations and tell you why this one doesn't 19 apply.
20 MR. BEASLEY: Right. And, they did that.
21 They -- I always prepare a topical report on 22 regulatory analysis, identifying which regulations are 23 required --
24 MEMBER HALNON: I'd love to see that.
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23 MR. BEASLEY: And which ones don't. And, 1
it was, that topical report wasn't just for a testing 2
facility. It was for their design.
3 And so, as a non-water reactor, you know, 4
what applies and what doesn't. And so, that's --
5 MEMBER HALNON: So, you weren't just left 6
to wonder way. You actually had --
7 MR. BEASLEY: Yes.
8 MEMBER HALNON: Some analysis then.
9 MR. BEASLEY: Yes.
10 MEMBER HALNON: Okay. I see.
11 MR. SHAMS: If I may make just one more 12 comment?
13 MR. BEASLEY: Yes.
14 MR. SHAMS: Mo Shams for the staff again.
15 So, it's just one of the probably the important 16 concepts to share is for research and test reactors, 17 currently the method is for safety assessment, risk 18 assessment is the maximum hypothetical event.
19 So, to your point, you've got to go 20 through a sheet, you know, a blank sheet of paper and 21 assume all the relevant accidents for that reactor, 22 and, then come up with an event that actually 23 encompasses all those.
24 And, our review would be actually to 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
24 scrutinize that assessment to see did they considered 1
all the relevant events. To your point, if it's not 2
a light water reactor, you know, you're going to need 3
to look at, you know, did they consider the right ones 4
from the light water reactor, and do we know have they 5
considered the relevant ones for that particular 6
technology, what makes sense.
7 So, to the point of the question about, 8
what if its light water reactors, would the hydrogen 9
explosion be relevant? Of course, it would be 10 relevant for a light water reactor. And, we'd want 11 to, you know, need to know that that the maximum 12 probability would capture that.
13 So, hopefully we'll walk you through that 14 today. We'll see what they have done and how they 15 have done it. So, that goes to the, how do we do a 16 risk assessment that works for them.
17 CHAIR PETTI: I think there will be lots 18 of questions on that.
19 MR. SHAMS: Yes.
20 CHAIR PETTI: How you get to every case, 21 so, yeah.
22 MEMBER REMPE: Since we're going down the 23 combustible gas rabbit hole, we're going to probably 24 add another piece of interesting information. In 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
25 Japan, I'm trying to understand what happened in Units 1
Three and Four. They can't identify the sources for 2
all the combustible gases.
3 And so, they're doing a lot of testing on 4
cabling and trying to see if combustible gases could 5
have contributed to the amount from the cabling 6
heating up so that they could get not only what they 7
saw at Unit Three, but also at Unit Four.
8 MR. SHAMS: Interesting.
9 MEMBER REMPE: So, even reactors we've 10 been running for a long time, we still can't 11 understand fully. And so, I wouldn't totally say oh, 12 we don't have to worry about that.
13 MR. SHAMS: Great point. Thank you for 14 that.
15 MR. BEASLEY: So, a primary focus, factor 16 influencing the safety review was the consideration 17 that Kairos submitted a
construction permit 18 application. For a construction permit, the level of 19 detail in an application and the associated NRC staff 20 review, are different then are needed for an operating 21 license.
22 The construction permit application 23 describes preliminary design of a facility. While an 24 operating license application needs to describe a 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
26 final design as well as administrative plans and 1
programs that are not provided in the construction 2
permit application.
3 Review guides for testing facilities does 4
not differentiate between the level of detail needed 5
for a construction permit versus an operating license 6
application. Or, provides specific guidance on what 7
maybe deferred to the license application.
8 In making this determination on what types 9
of things maybe reasonable deferred versus what is 10 required for a construction permit, the staff used its 11 technical judgment and also considered the 12 requirements in 10 CFR 50.34(a) and (b), regarding 13 information that must be included in preliminary and 14 final safety analysis reports.
15 In addition, the staff based its review on 16 the specific findings it needs to make before issuance 17 of a permit, which are provided in 10 CFR 50.35. As 18 provided by 10 CFR 50.35, the principal architectural 19 and engineering criteria for a design must be 20 described in a construction permit application.
21 But, some technical or design information 22 maybe left for later consideration in an operating 23 license application.
24 Not all safety questions need to be 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
27 resolved for the issuance of a permit. But, an 1
applicant must identify research and development which 2
is to be completed prior to the completion of 3
construction to resolve these questions.
4 In making a recommendation that a permit 5
should be
- issued, the staff also considers 6
requirements in 10 CFR 50.40 and 50.50.
7 CHAIR PETTI: So, just a question that I 8
-- it's the sub-bullet, the last sub-bullet of the 9
second bullet. That they have to com -- resolve the 10 safety questions by the completion of construction.
11 I thought it would always be prior to 12 being allowed to move to operation. Is that a 13 difference in those two?
14 I
- mean, there could be a
timing 15 difference. But, you're basically saying it has to 16 all be done before construction is complete.
17 MR. BEASLEY: Yes. And, I, you know, I'm 18 not sure which regulation that comes from.
19 CHAIR PETTI: I just -- yeah. I just 20 wondered if it was just the words meant something 21 different than what it says.
22 MR. BEASLEY: No. It --
23 CHAIR PETTI: Okay.
24 MR. BEASLEY: That's probably in 50.35.
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28 Is that right, Ed?
1 CHAIR PETTI: Yeah. And then the other 2
question is, okay, this is all CP. Is it any 3
different for a power reactor?
4 The CP guidance, in terms of what the CP 5
application has to describe?
6 MR. BEASLEY: No. So, this is --
7 (Simultaneous speaking.)
8 CHAIR PETTI: So, this is --
9 MR. BEASLEY: No, this is a testing 10 reactor, no. It --
11 CHAIR PETTI: This is a CP issue.
12 MR. BEASLEY: This is a CP issue. It's 13 not a --
14 CHAIR PETTI: Okay.
15 MR. BEASLEY: testing facility, so.
16 CHAIR PETTI: Okay.
17 MR. BEASLEY: Yeah.
18 MEMBER REMPE: So, I have another question 19 that's more pertinent to the Hermes facility. This 20 facility doesn't have any experimental facilities 21 capabilities in it, but the whole thing is sort of a 22 demonstration or an experiment.
23 I'm thinking Chapter 10 and the staff 24 response. And, although -- and again, this probably 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
29 is something that would come up with the operating 1
license, but on the other hand, as you go through and 2
review the construction permit as well as the 3
operating license, there's going to be things that you 4
don't know all the details.
5 You'll have some data, but there will be 6
extrapolation. Or, the codes won't be fully 7
validated. The coupled effects of radiation and 8
thermo-hydraulics and reactor physics behavior, 9
there's going to be some data obtained as it operates 10 that will confirm analyses.
11 And, I know that there's like an Appendix 12 A, what we have with a construction permit, where the 13 staff identifies things from the construction permit 14 that have to be answered for the operating license.
15 But, you also have a subset in Appendix A 16 which, by the way, isn't posted when I looked last 17 time. We don't have the staff's Appendix A yet, which 18 I'd like to see at some point.
19 But, anyway, will that Appendix A also 20 talk about things you're identifying as you go through 21 the review that you know won't even be available at 22 the time you start up with the operating license that 23 you'd like to see validated as data are obtained from 24 running this facility?
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30 MR. BEASLEY: So, Appendix A does include 1
the research and development activities that Kairos is 2
planning.
3 MEMBER REMPE: For this facility? For 4
this operating?
5 MR. BEASLEY: For this facility. You 6
know, and this maybe more of a question for Jeff.
7 But, I'm not aware of anything that we are putting off 8
past the operating license.
9 We expect the codes, the modeling codes 10 that they used to be validated for use in the 11 operating license. And, Jeff's going to talk a little 12 bit to that in his example.
13 So, it, you know, we want to assure safety 14 before they get --
15 MEMBER REMPE: They have to have --
16 MR. BEASLEY: To the operating license.
17 MEMBER REMPE: Fully validated codes for 18 the -- I mean, this is a new facility where you're 19 looking at corrosion effects of the -- of slide with 20 the graphite and long term behavior combined with the 21 radiation.
22 They'll be periodically looking at the 23 pebbles. And, you've got criteria if it's of such, 24 you know, if something is 10 percent off of the 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
31 validation that they're predicting, you're not going 1
to say, I want you to shut this thing down or 2
something.
3 Or, I just am a little surprised by that.
4 I have talked with a former member of ACRS, and issues 5
came up over the years with the insights gained for 6
flow instabilities.
7 And, I think that was something I thought 8
I'd seen in an upcoming slide here. Where you wanted 9
them to test -- and that was done for an operating 10 reactor in the U.S. over the years.
11 So, I guess I'm not sure that everything 12 is fully validated that you aren't going to be 13 exploring something from what I've read so far. And, 14 I think there may be some other things.
15 And, as I go through this review, I would 16 want us as members to be looking for things that ought 17 to be validated at this facility.
18 CHAIR PETTI: My view is there's a handful 19 of things that no matter want we do, no matter how 20 good a job Kairos does analytically, well, it's just 21 until you run the reactor, you're not going to know.
22 So, that's just the nature of it.
23 MEMBER MARCH-LEUBA: And, it is the reason 24 why we're building this facility.
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32 MEMBER REMPE: Right. Exactly.
1 CHAIR PETTI: Exactly. Exactly.
2 MEMBER REMPE: No. So, yeah. I think 3
there are some things. Only, I'm not sure I agree 4
with you.
5 But, you've been looking at it more than 6
I have. But, I'm going to be looking as I go through 7
this review for things.
8 And, I'm hoping that they're documented 9
and it's something that I don't think you want to --
10 I think you'd want someone at headquarters to be kind 11 of involved in this long term operation as they do 12 these tests and confirm this information.
13 MR. SCHMIDT: Yeah. Could I just 14 interrupt real quick? This is Jeff Schmidt from the 15 staff, Advanced Reactor Division.
16 So, the things that you are referring to, 17 you'll see a fair number of those are testing done 18 during say the construction and before the operating 19 license. In other words, there's a pretty extensive 20 Kairos testing program.
21 And, the specific thing you were talking 22 about was the decay rule system, which I do have a 23 slide on. You know, they have -- I would characterize 24 it as robust testing programs.
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33 So, we can get into that, where they are 1
looking for things. But, this is -- these would -- by 2
and large, these are programs that would be completed 3
before either the construction is completed, or the 4
operating license.
5 So, just put it in that time frame or that 6
reference.
7 MEMBER REMPE: There's nothing you think, 8
I mean, this is a test facility to demonstrate the 9
technology for subsequent reactor applications.
10 MR. SCHMIDT: Right.
11 MEMBER REMPE: I would think that it 12 wouldn't be fully validated. But, the thing is a low 13 power thing and the staff saying, okay, it's probably 14 going to be safe enough that we're not worried about 15 public protection.
16 But, I would think you'd want to have more 17 confidence in the performance or the technology before 18 19 MR. SCHMIDT: So, one of the areas that 20 might fall into the category you're speaking about, it 21 was when we discussed the fuel qual. Right?
22 There's a fuel qual program that will 23 inform the commercial reactor. Right, they're going 24 to take samples out of this reactor and inform 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
34 information for the test reactor.
1 So, if that's what you're referring to, 2
yeah. But, you know, we are making a reasonable 3
assurance finding her for the test reactor.
4 MEMBER REMPE: Thank you.
5 CHAIR PETTI: Yeah, so you know, if it's 6
a fuel thing so the tritium control in the system, 7
it's a hot, high temperature system. Tritium is going 8
to go places.
9 You know, it's not a public safety issue.
10 It's a worker safety issue. But, trying to prejudge 11 all of that before you have any operating things, it 12 seems difficult.
13 Yeah, it looks like, you know, they're 14 going to be able to meet the requirements. But, you 15 know, go talk to the utilities that are irradiating 16 with TPBARs.
17 You know, that's a low temperature system.
18 They don't like the fact that -- they've got tritium 19 going everywhere and it's a low temperature system, a 20 beryllium control.
21 Again, a worker safety issue. That's 22 really hard to analytically put your hands around. I 23 mean, so I see a number of things like that. That 24 until you get those operating figures and inform the 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
35 power the power reactor.
1 Those are just realities. That's why it's 2
a test reactor, right? I mean, I've already written 3
a paragraph of a letter saying, we think these are 4
things that everybody should know. They're just 5
there.
6 And, that's why they're building the test 7
reactor.
8 MEMBER REMPE: Yeah. And, I would hope 9
that and maybe it doesn't have to be in the 10 construction permit, but it seems like a good place to 11 start such a list and have it in Appendix A that we 12 expect to have data to confirm some of the information 13 that wasn't fully validated as a long term operation.
14 And, have that list identified and makes 15 sure that the, if there are any controls that the 16 staff wants to impose and say if you see something is 17
-- a lot more tritium coming out then you expect, or 18 something like that.
19 And have those kind of tech specs 20 identified so that everybody understands what's 21 expected when you have this type of a first of a kind 22 23 MR. SCHMIDT: Right.
24 MEMBER REMPE:
Little operating 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
36 experience. And, is that going to be in your Appendix 1
A or some place?
2 MR. SCHMIDT: Well, so not for the 3
construction permit. So, you're a step beyond us a 4
little bit in the operating license phase.
5 So, Appendix A does identify the research 6
and development activities that Kairos is undertaking 7
for, you know, for this reactor. And so, we'll, you 8
know, we'll -- or that need to be done in order to get 9
the license, operating license application.
10 But, that's a very good idea. I think, 11 you know, that is something that we, you know, we 12 should start thinking about and, you know, planning 13 ahead as we, you know, as we get the construction 14 permit finished.
15 If it is decided to award the permit, then 16 we would start thinking ahead about what we should do 17 with the operating license application. And certainly 18 the affirmatory activities that you're talking about 19 are, you know, a major purpose for building Hermes a 20 testing facility.
21 There are, you know, there's a lot of 22 reasons to building a testing facility. Kairos wants 23 to exercise a supply chain.
24 They want to develop the scale of craft 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
37 workers. They want to find out, you know, what costs 1
are like for building and for all the materials they 2
need.
3 So, there's a number of reasons beyond 4
just confirming the technical aspects that the testing 5
facility is being built.
6 CHAIR PETTI: So, just sort of a bigger 7
picture. This is the first low advanced reactor, non-8 light water reactor.
9 And, we're going to be talking later in 10 our meeting this week about how we're going to 11 approach our letter. And, it's going to be different 12 perhaps then previous letters. It's going to be more 13 high level.
14 The question is, when you don't have 15 operating experience, how do you make your assessment?
16 And, we've given it some thought.
17 And, the outlying kind of addresses sort 18 of a punch list of things that, you know, safety 19 margin for instance, it's critical in my opinion. You 20 go back to the early light water reactors, they do 21 tons of margin.
22 And so, it should be incumbent on the 23 applicant to show how they have a lot of margin in all 24 the different dimensions of what safety margin is.
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38 So, those are the things we're going to be 1
looking for as we think about it. Because, you know, 2
it's not going to be, you know, oh, let's see that 3
validation experiment and make sure that that code, 4
you know, is calculated right.
5 I think we have to see these things on 6
that. But, you know, do you really have the margin?
7 Do you, you know, how great is it? Where is it? How 8
are your safety functions implemented?
9 That's sort of a look at things. And 10 what's novel and new? And you guys, I think, are 11 thinking along the same lines as I am.
12 So, that's sort of, at least in my -- how 13 I'm looking at it.
14 MR. BEASLEY: Thank you. So, next slide, 15 Ed.
16 So, considering that the application is 17 for a testing facility construction permit, the staff 18 performed a, well, not a PRA risk informed reviewed, 19 but a generic risk informed review. In that the 20 review depth and scope were commensurate with the 21 safety significance of areas under review.
22 MEMBER MARCH-LEUBA: Let me air my 23 grievance. Excuse me. But, everybody in this room, 24 I have been trained to risk inform my decision whether 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
39 to ride a bike to work or take the metro.
1 And, at the end of spending two hours 2
doing that training, you just go by the seat of your 3
pants and do whatever you want. Because that's 4
basically the conclusion I got from that training.
5 And, I think it can be done better for 6
here. I mean, we have the mathematics and we have the 7
ways to actually go have two hypothesis and pick the 8
one that is better of the two.
9 And, thoroughness, instead of the seat of 10 the pants, is desired, when it's not your decision to 11 ride the bike or take the metro.
12 MR. BEASLEY: Yes.
13 MEMBER MARCH-LEUBA: I'm airing my 14 grievance.
15 MR. BEASLEY: Thank you. So, the staff 16 maintained a big picture safety perspective of the 17 Hermes design considering the small size of Hermes, 18 the short operating life, and the safety case with low 19 radiological consequences.
20 The staff tailored its review for the 21 unique and novel Hermes technology described in the 22 preliminary design. The staff used NUREG-1537, the 23 licensing guidance for non-power reactors to perform 24 the review.
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40 NUREG-1537 is designed to be technology 1
neutral and provides flexibility for a review such as 2
the Hermes application. NUREG-1537, part 1, is also 3
the guidance that Kairos used in preparing its 4
application. Next slide.
5 So, this is a list of the Chapters in 6
NUREG-1537 which aligns with the Chapters in Kairos' 7
preliminary safety analysis report and with the 8
staff's safety evaluation.
9 As noted on the slide, some of the NUREG-10 1537 Chapters, for example, Chapters like 16, 17, and 11 18, are not applicable to the construction permit 12 application.
13 The project core team in the Division of 14 Advanced Reactors and Non-Power Production and 15 Utilization Facilities reviewed technical topics 16 integral to the reactor design, such as fuel and core 17
- design, thermal and structural
- analysis, and 18 accidents.
19 Other topics reviewed by subject matter 20 experts from other divisions, include those such as 21 quality assurance, fire protection, site 22 characteristics, and emergency preparedness. Next 23 slide, please.
24 MEMBER HALNON: Hey, Ben?
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41 MR. BEASLEY: Yes?
1 MEMBER HALNON: Do you recall when the 2
last revision to NUREG-1537 was made?
3 MR. BEASLEY: I'm going to ask --
4 (Simultaneous speaking.)
5 MEMBER HALNON: If I recall it, it was 6
like three --
7 MR. BEASLEY: I'm not in the non-power --
8 MEMBER HALNON: It was like in '90 9
something.
10 MR. HELVENSTON: Okay. This is Ed 11 Helvenston from the staff. It was 1996.
12 MEMBER HALNON: So, given that, and the 13 fact that we have at least exercised the more 14 contemporary, is there any talk about adding lessons 15 learned and doing a revision so that we have some of 16 the -- I mean, the post-911 regulations are not 17 included.
18 The Fukushima regulations are not, I mean, 19 those orders are not included. A lot of things are 20 not included in 1537 now. And, it just seems like 21 it's old.
22 MR. BEASLEY: So, I'm not in the non-power 23 side of the Division. And so, I don't want to speak 24 for them.
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42 MEMBER HALNON: So, it's not a good 1
question for you.
2 MR. BEASLEY: Yes. It's not a good 3
question for me. I don't want to get myself in 4
trouble with other Branch Chiefs, committing them to 5
something.
6 MEMBER HALNON: Okay.
7 MR. BEASLEY: But so, --
8 MEMBER HALNON: I'd like to have a 9
conversation about that. Maybe somewhere about 10 whether or not 1537 used today as written is really 11 adequate for some of these new advanced reactors that 12 are coming online now.
13 MEMBER BALLINGER: Didn't they cover some 14 of this in the ISG? There's an ISG associated --
15 MEMBER HALNON: That maybe. And I --
16 MEMBER BALLINGER: That's for power 17 reactors.
18 MEMBER KIRCHNER: There's an ISG for 19 construction.
20 MEMBER HALNON: And, just a question out 21 there. Maybe I can look up and have a discussion 22 later on.
23 MR. SHAMS: If I may offer. Mo Shams with 24 the staff. We are making updates to 1537 by adding a 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
43 appendices if you would. And, intended -- I believe 1
we have --
2 MEMBER REMPE: Mo, talk to the mic side.
3 MR. SHAMS: I'm sorry. I'm sorry.
4 CHAIR PETTI: Yeah. Everybody out there 5
can hear you. But, not in here. Yeah, it's one of 6
the bad spots.
7 MR. SHAMS: I believe we have a section 8
that was developed for molten salt reactors. We're in 9
the process of endorsing another one that addresses 10 reactors like in Abilene Christian University.
11 So, to your point, there is an effort to 12 include the new technologies, the nuances associated 13 with it, the lessons learned that we've had, you know, 14 over time.
15 So, we're mindful of the new updates.
16 MEMBER HALNON: Okay. Good. Thank you, 17 I appreciate that.
18 MR. TAYLOR: And, Rob Taylor. Just one 19 other thing.
Especially going back to 911 20 requirements. The Commission made specific decisions 21 and we can go look at those about what the 22 applicability of those requirements were to different 23 facilities as they evaluated.
24 And, some of those played out over years 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
44 as they made decisions on the CAT II facilities and 1
things like that. So, we'd have to look at what the 2
Commission instructions were on those.
3 With regards to Fukushima, we have to look 4
-- we would look at Fukushima and ask the question, is 5
this applicable to a small test reactor of this design 6
and those lessons learned.
7 So, I mean, it's something we can do.
8 But, it -- given what we're supposed to do under 9
minimum regulations, you also have to ask yourself, 10 does that make sense for a research and test reactor?
11 MR. SHAMS: I'll build on what Rob said.
12 For Fukushima actually, we took a sweeping look at all 13 other facilities. We stated out with power reactors, 14 but we looked at all other facilities.
15 There were SECY papers that were written 16 up assessing where it was fuel facilities, whether it 17 was ISFSIs, whether it's research and test reactors.
18 For the research and test reactor community in 19 particular, we've identified a handful, and we looked 20 at the hazard and assessed if there's a need.
21 So, that look has been taken, you know, 22 taken into consideration as well.
23 MEMBER HALNON: Okay. And, thank you. I 24
-- yeah, I agree the Fukushima stuff -- really light 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
45 water, being a light water reactor, even though you 1
have to keep funding standards and other things, and 2
those are picked up in other Reg Guides and the sort.
3 So, but just an audit of 1537 seems like 4
it could be good.
5 MR. SHAMS: Yeah.
6 MEMBER HALNON: Could benefit from a look 7
back and a refresh. Thank you.
8 MR. BEASLEY: Thanks. So, Ed, we can go 9
to the next slide.
10 So, the staff conducted audits in the 11 topics listed on this slide. I identified the 12 approximate number of questions for each audit to 13 illustrate that we conducted a substantial review, 14 and, that our review dug into the areas that were 15 safety significant.
16 Jeff Schmidt is going to provide an 17 overview of a few technical items to illustrate how we 18 carried out the review on our preliminary design of 19 the testing facility.
20 So, I'm going to turn it over to Jeff 21 unless you have any other questions for me.
22 (No response.)
23 MR. BEASLEY: Okay. Next slide.
24 MR. SCHMIDT: Yeah. This is Jeff Schmidt 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
46 with the staff. I was lead technical reviewer for the 1
Hermes construction permit.
2 I wanted to give you two examples, I'm 3
sure we'll probably get into more, that covers some of 4
the questions that you were talking about earlier, 5
like what's it based on, preliminary information, what 6
maybe applicable for test reactors versus a power 7
reactor.
8 I picked out, I think, two examples of 9
interest and two that were, you know, were deemed to 10 be -- well, certainly the first one, deemed to be a 11 high safety significant system. And, I'll get into 12 that.
13 So, a decay heat removal system, is safety 14 significant for maintaining vessel temperature within 15 the accepted limits of the stainless steel 316.
16 You know, the staff's assessment was that 17 the vessel is probably the limiting component in this 18 design based on the available fuel margins. And, 19 we'll get into that when we get into the substantive 20 review.
21 But, you know, it became clear to the 22 staff early in the review that temperature 23 distributions within the vessel are going to need high 24 fidelity and that they're relatively close to some of 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
47 those stainless steel limits.
1 So, that was the primary focus of, well, 2
not primary, but a significant focus of what we found, 3
to put it in context. And, for those -- that vessel 4
to remain intact, the decay heat removal system has to 5
perform its function when you get it above a certain 6
power level, or threshold power level as its referred 7
to in the safety evaluation.
8 So, that's the context of why I picked 9
this system for discussion. I guess I covered the 10 second bullet that, you know, it's placed in service 11 when basically passive radiated cooling is not, is no 12 longer adequate.
13 There is a regime there where you 14 obviously always have that cooling component. But, 15 there is a time where that decay heat removal system 16 has to be placed in service.
17 And that placing in service was a focus of 18 the review too, in terms of what could happen placing 19 that system in service. Or, if that system, when it's 20 placed in service if you had a reactor shortly 21 thereafter, what would happen when you just met the 22 threshold power.
23 So, those were kind of areas of the review. The 24 staff went through the preliminary design and 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
48 identified potential failure modes.
1 So, we tried to take a high level look at 2
the system to see where potential failure modes could 3
be, especially if anything had to move into position 4
to perform that function.
5 And so, I think we'll probably be talking 6
about that fairly significantly during the 7
Subcommittee meeting. There was, you know, some 8
things identified that were just higher, of higher 9
interest than others.
10 CHAIR PETTI: Jeff, the question I had is 11 sort of the opposite, which is there is a system to 12 keep the salt hot.
13 MR. SCHMIDT: Yeah --
14 (Simultaneous speaking.)
15 CHAIR PETTI: I don't want to lose the 16 heat. I want to keep the heat held in there --
17 MR. SCHMIDT: Right, right.
18 CHAIR PETTI: -- in freezing events and 19 they don't claim that's a safety system.
20 MR. SCHMIDT: That's correct.
21 CHAIR PETTI: And I'm still, I guess, I 22 mean, I'll be asking about the thought process there 23 because I -- you know, if you freeze, as Ron would 24 say, it's a bad day. You'll probably fail welds and 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
49 the like, and so I keep thinking why isn't this safety 1
related?
2 So, you know, okay, under control heat 3
generation, I mean, you could have a separate safety 4
function for coolants that are hot, that have to stay 5
hot, but you could also put it under the umbrella of 6
controlling heat. You're trying to get it out or keep 7
it in depending on what's going on. I didn't see that 8
logic in any of their documentation, and again, I 9
haven't got into that chapter again.
10 MR. SCHMIDT: I will say on the second 11 slide, the next slide, we address that a little bit --
12 CHAIR PETTI: Oh, good.
13 MR. SCHMIDT: -- from a 72-hour kind of 14 coping time period. It is an area of interest to the 15 staff. Let's put it that way. If I could get to the 16 second slide, we could discuss it more.
17 Let's see, so as far as we audited -- so 18 the calculation that has been performed by Kairos has 19 been like the max heat removal system to keep the 20 vessel temperature intact, and you'll probably see 21 presentations with curves that show, you know, the 22 vessel temperature limit relative to the transients, 23 but we do get to your freezing question here also.
24 The staff also performed just to ensure 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
50 water tank volumes were sufficient for seven days of 1
cooling. Staff ensured testing plans, addressed 2
potential flow and heat removal and stability issues 3
during the transition and in-service phases, including 4
the effects of identified potential failure modes of 5
the system.
6 So, here the staff was concerned about, 7
you know, initially, at least the way it's described 8
now, the system is dry and water is introduced to the 9
system when you get to a certain threshold power.
10 The staff was concerned that that 11 evolution could lead to flow instabilities, and the 12 staff was also concerned that even once flow was 13 established, you know, the boiling process in these 14 tubes can be fairly violent and subject to things like 15 back pressure changes and things like that which might 16 cause an instability.
17 So, those, the staff asked questions in 18 that area and really focused on the testing plans.
19 So, they have a testing plan for those items and the 20 staff is going to, I hope, be heavily involved during 21 the testing process as well.
22 But, you know, the staff did identify 23 these issues. Kairos did respond that they are aware 24 of those and that that will be addressed in their 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
51 testing program as they come up with a final design of 1
the heat removal system.
2 MEMBER MARCH-LEUBA: And you expect that 3
this will be addressed in the final safety analysis 4
report, correct?
5 MR. SCHMIDT: I'm sorry, say that again?
6 MEMBER MARCH-LEUBA:
They will be 7
addressed in the final safety analysis report?
8 MR. SCHMIDT: Yes, yes, all of these, so 9
all of the testing programs. So, Appendix A, and 10 thank you, correct me if I'm wrong, are effectively 11 commitments by Kairos made in the PSAR of the testing 12 programs, so that's the way you should review that 13 appendix.
14 There is a separate list that the staff is 15 keeping for lessons learned, areas of interest to 16 inform the OL review. It's not part of the safety 17 evaluation, but there's a separate document out there 18 in our SharePoint drive that's saying, you know, 19 whoever is responsible for looking at this in the 20 future, look at these items, right? These are 21 identified areas that the staff should, at least the 22 staff as it is now that could identify are areas of 23 interest, so they're kind of like two separate 24 documents.
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52 MEMBER HALNON: So, Weidong, can we get 1
that uploaded to ours, that list? I know it's going 2
to be a moving target, but, because I've been keeping 3
my set of stuff, or at least point us to it.
4 MR. BEASLEY: So, confirming, Jeff, yes, 5
Appendix A is commitments that, things that Kairos 6
said that they were going to do during our audit 7
discussions. I'd like to think about the staff's 8
internal --
9 MEMBER HALNON: Okay, well, we can give 10 you our list and hopefully it will be --
11 (Simultaneous speaking.)
12 MR. BEASLEY: So, in some respects, those 13 are just staff notes for themselves --
14 MEMBER HALNON: I got it. I get it. I 15 know.
16 MR. BEASLEY: -- to allow them to think 17 about that.
18 MEMBER HALNON: Right, I understand.
19 Okay, we'll just make sure that our list is discussed 20 in the meetings and you guys can go --
21 (Simultaneous speaking.)
22 MEMBER BALLINGER: Yeah, I mean, in the 23 chapters that I've looked at, they've done a pretty 24 darn good job. I mean, the applicant looks at the 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
53 PDCs and discusses how they meet them.
1 The staff takes a look at it in the SE and 2
says here are how they compare with the PDCs, and by 3
the way, here are the following limitations and 4
conditions we're going to put on the system that have 5
to be satisfied before they're operating. So, it's 6
pretty straightforward, and at least from the ones 7
I've looked at, pretty thorough.
8 MEMBER HALNON: Yeah, I don't disagree 9
with that. What I see though is a lot of repeat back 10 of what the regulation requires. Yes, we'll do this.
11 It requires this. Yes, we'll do that, and then as you 12 go through it and we talk a little bit more about, you 13 know, referencing other things like 20.1406.
14 We're going to minimize contamination.
15 Okay, great. You know, how is that area through to 16 the translation into the operating license application 17 and who is taking a look at it from that perspective?
18 So, there's just things like that.
19 Now, I know those very overt commitments 20 are probably on your list as well. It's the -- I 21 wonder why things that, you know, pop into your mind 22 as you're reading this stuff based on past experiences 23 and biases, so those are the types of things, I guess, 24 that we just need to make sure that if we've got them 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
54 on our mind, to let you know about it.
1 MR. JESSUP: Yes, Member Halnon, that's 2
good feedback. This is Bill Jessup from the staff.
3 So, this is, you know, kind of the foundational 4
meeting today.
5 I think this is really good feedback we 6
can take into the chapter specific discussions, and 7
so, you know, we can go take a look at the notes we've 8
put together, go back to the SEs and see if there are 9
those items.
10 I think Chairman Rempe gave us similar 11 feedback about, you know, what are we keeping track 12 of? What's in Appendix A versus what are we keeping 13 track of? So, it's good feedback.
14 MEMBER HALNON: Well, at least for me, I'm 15 putting those thoughts, at least the major ones, in 16 the memos to Dave.
17 CHAIR PETTI: We don't SharePoints. I 18 don't think we would put our stuff on a SharePoint 19 site. We will have it in the memos so that that's our 20 way to translate to you guys hey, whoever is going to 21 pick this up in the future --
22 MEMBER HALNON: Some may be very important 23 and some may not be important at all --
24 MR. JESSUP: Right.
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55 MEMBER HALNON: -- but just the thought 1
process.
2 MR. JESSUP: I think it's clear we're 3
definitely going to hear you all's list.
4 CHAIR PETTI: Sure, yeah. No, I think the 5
other thing as I think about this and your earlier 6
slide about the number of questions, you know, in the 7
old review where we had the two stages, right, with 8
open items, we kind of collectively had this set of 9
ideas and it was sort of (inaudible).
10 Now, it comes to us with everything done 11 and sometimes you don't see all of the hard work that 12 was done behind the scenes, so it requires probably 13 the presentations to be a little bit different than 14 the way it used to be to convince us that you guys 15 have done the homework as opposed to us living it when 16 we did it in the optimal phase things in the past.
17 MR. SHAMS: That's great feedback. Mo 18 Shams with the staff. Great feedback, Dr. Petti, for 19 us, such that we continue to keep this process as 20 efficient as possible.
21 CHAIR PETTI: Right.
22 MR. SHAMS: We need to calibrate our 23 presentation to you in a way that satisfies that need.
24 I got you.
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56 MEMBER BROWN: Can I ask a technical 1
question as opposed to this esoteric (inaudible)? The 2
second bullet says the DHRS must be placed into 3
service above a certain threshold. Does that imply 4
that they need to have an automated system that does 5
that or is it totally operator in the present design?
6 I'm totally clueless as to what --
7 MR. SCHMIDT: Yeah, it doesn't get into 8
the details of that system. That's going to -- that, 9
right now, I'm reading it as operator action, but I 10 don't know the details of how that is implemented.
11 MEMBER BROWN: So, that's an open point?
12 MR. SCHMIDT: I would say it's more 13 consistent with the OL review to be looking at that.
14 I mean, we did have --
15 MEMBER BROWN:
As opposed to the 16 construction permit?
17 MR. SCHMIDT: That's right.
18 MEMBER BROWN: Oh, okay.
19 MR. SCHMIDT: That's right. I mean --
20 MEMBER BROWN: But we've got to design 21 systems.
22 MR. SCHMIDT: Right.
23 MEMBER BROWN: At some point, you've got 24 to have the systems being designed if you want it and 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
57 what the criteria are.
1 MR. SCHMIDT: Right.
2 MEMBER BROWN: And that just stuck out to 3
me in terms of how I'm glad DHRS had to be, you know 4
had a differential ahead of this, a power level 5
determination of when it was needed and when it was 6
not. You know, if not -- if it is needed, then it 7
sounds to me like you don't want distractions to 8
prevent it from not getting activated.
9 MR. SCHMIDT: So, you're kind of getting 10 to what I refer to as the staff notes, you know, that 11 are kept in the background. You know, this is a 12 preliminary design and I think everybody needs to 13 understand that. The details of a lot of exactly how 14 these things are implemented is going to be coming as 15 part of the OL.
16 So, you identified, I mean, we identified 17 human actions that could lead to problems where you 18 didn't turn it on when you should have or you've 19 turned it on too soon. Too soon can be as challenging 20 as too late, so you identified some of the things on 21 our list.
22 MEMBER BROWN: Okay, so this is a question 23 you've got on your list that would be answered later?
24 MR. SCHMIDT: That's correct.
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58 MEMBER BROWN: I don't have to go find it 1
2 MR. SCHMIDT: No, no.
3 MEMBER BROWN: -- two years from now?
4 MR. SCHMIDT: No. I mean, those --
5 MEMBER BROWN: All right.
6 MR. SCHMIDT: Those considerations, you 7
know, such as human error or human actions if it's a 8
manual system will have to be addressed.
9 MEMBER BROWN: Thank you.
10 MR. SCHMIDT: Let's go to the next slide, 11 please. Okay, this is getting back to the testing 12 plans I was referring to and I talked already a little 13 bit about this. You know, when in service, potential 14 dynamic loads on the structure, both due to the 15 transition phase and effectively thermal shock during 16 the transition phase is a concern to the staff, and 17 in-service evaporator boiling, you know, that's the 18 continuous operation mode. Those, again, I think were 19 pointed out and I think Kairos is addressing those as 20 part of their testing program.
21 Staff ensured the testing program 22 addressed the potential for corrosion and fouling in 23 the evaporator tube affecting both structural 24 integrity, that's kind of like the stress corrosion 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
59 cracking issue if you're running it for longer than 1
not, and the ability to remove any potential fouling.
2 You know, we're thinking of things like what's the 3
quality of the water source that are going into those 4
evaporator tubes? Those are the considerations.
5 Staff noted the DHRS design must 6
accommodate the highest heat loads for vessel 7
integrity and the lowest in-service heat loads to 8
prevent freezing without operator action within 72 9
hours.
10 So, this is kind of getting to your 11 question. This is like, you know, you have two design 12 constraints you're trying to design to. You know, the 13 detailed design will have to address those competing 14 design requirements.
15 You know, I think that it's possible to do 16 those, but we'll need the details of the design. So, 17 that's really the bullet there is final determination 18 of the accuracy of the decay heat removal system for 19 these competing designs will be made based on the 20 design presented in the FSAR.
21 So, the staff was concerned about could a 22 situation occur where you've met the threshold 23 requirement and you have to turn it on, but then you 24 trip and maybe you don't have the decay heat at --
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60 You know, it was necessary for vessel 1
cooling should you have a transient, but it also could 2
lead to a freeze situation in a shorter period of time 3
than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. So, the staff is focused on that 4
issue.
5 As Dr. Petti stated, you know, the 6
auxiliary heating system is non-safety related, so 7
we're using this 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> kind of as a guide to say 8
it's time to get the system back in service if it's 9
not in service at that time to prevent the freeze.
10 The design goal is to prevent freeze. Freeze is a 11 non-analyst condition.
12 MEMBER KIRCHNER:
And these 13 considerations, Jeff, are applied to just normal 14 operation of the primary system across the board, so 15 you're going to see all of these issues for the 16 primary system, including the reactor vessel.
17 MR. SCHMIDT: Yeah --
18 MEMBER BROWN: Does that imply you need an 19 automatic auxiliary heating system to make sure it 20 doesn't freeze as well?
21 MR. SCHMIDT: There is an auxiliary 22 heating system, but it's non-safety.
23 MEMBER BROWN: It's an automatic -- how 24 can it be non-safety if it's going to be, if you can 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
61 break the system?
1 MR. SCHMIDT: You can as long as, I mean, 2
as long as you have adequate decay heat. If you don't 3
have adequate decay heat, you wouldn't be turning off 4
that system. So, it's really a function of before the 5
threshold power, you still have to provide cooling, 6
and that will be passive needs and that will be 7
adequate.
8 At some point after like, say, a reactor 9
trip, you will have to go onto that auxiliary heating 10 system. What we want to do is just make sure it's far 11 enough out in time that you have capability to, you 12 know, restore that non-safety system.
13 MEMBER MARCH-LEUBA: What you're talking 14 about, what's the power source for the aux system?
15 MR. SCHMIDT: That, I would have to look 16 up.
17 MEMBER MARCH-LEUBA: It's likely offsite 18 electrical?
19 MR. SCHMIDT: I'd have to look it up. I 20 don't remember.
21 CHAIR PETTI: My concern is, you know, 22 when you start up a pebble bed, it takes a heck of a 23 long time to get it to equilibrium. So, they're 24 sitting at conditions.
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62 MR. SCHMIDT: Yeah.
1 CHAIR PETTI: It could be the entire four 2
years, that they'll never actually get to true 3
equilibrium where you have full 100 percent decay 4
heat, you know, if you shut down.
5 All of that has to be analyzed. I mean, 6
it's almost -- you know, it's not like something in 7
ten years where there's a true steady state and that's 8
what my concern was. It's complicated --
9 MR. SCHMIDT: Right.
10 CHAIR PETTI: -- in that startup.
11 MR. SCHMIDT: Yeah, it is complicated 12 because I think it's a function obviously of the decay 13 heat, but also maybe just the reactor power itself at 14 that point.
15 CHAIR PETTI: Yes.
16 MR. SCHMIDT: You know, so it's a function 17 of two powers if you will, and I agree, you know, it 18 is complicated.
19 MEMBER BROWN: It just seems to me you've 20 got competing issues. You've got to make sure you can 21 take it when it gets above a certain threshold --
22 MR. SCHMIDT: Yes.
23 MEMBER BROWN: -- so that the radiated 24 doesn't do the work, and you've got another threshold 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
63 on the bottom end because I can't let it get too cold 1
because otherwise the system is going to freeze, and 2
yet the whole system in which it breaks, and now it's 3
a non-safety system.
4 Just for some reason, my brain doesn't 5
work very well with that regardless of whether it's a 6
test reactor or a power reactor. I mean, it's got 7
enough --
8 MEMBER MARCH-LEUBA: Educate me about it.
9 Freezing is a bad thing, but isn't that an operational 10 concern more than a safety concern?
11 MR. SCHMIDT: So, I personally view 12 freezing at this point as just an unknown. I mean, it 13 could be argued that --
14 (Simultaneous speaking.)
15 CHAIR PETTI: It could. I mean, I have 16 seen Flibe freeze inside the welds, yes, in labs, in 17 lab scale stuff. Remember there's a weld at the 18 bottom of the vessel. That's the one that, you know, 19 you'd be worried about.
20 MEMBER MARCH-LEUBA: Does it expand like 21 ice does? I mean, I don't know what, if it expands a 22 lot.
23 CHAIR PETTI: So, let me just ask Jeff.
24 Is this a case where, I mean, given how complex this 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
64 is, that for the OL, you guys would do confirmatory 1
calcs and try to convince yourself?
2 MR. SCHMIDT: Yeah, I mean, I can't commit 3
to that at this point.
4 CHAIR PETTI: Right, but, I mean, this is 5
sort of moving in that direction.
6 MR. SCHMIDT: I think you could tell by 7
the purpose of the slide and what's stated here that 8
it is an area of concern for the staff, yeah, because, 9
you know, we're just not sure what happens with 10 freezing, right?
11 You could argue it's vessel protection.
12 You might, you know, you could argue it's safety 13 related. Maybe if it's frozen, I don't care if I 14 break welds or something like that, but that's not 15 where we are today.
16 Where we are today is to prevent freezing 17 within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. That's the design commitment. That 18 could evolve, I guess, if they're unable to finalize 19 this design. Well, then I, you know, I think we're 20 going to have to revisit that again. It's going to be 21 potentially revisited.
22 You know, I will say that all of these 23 issues have been brought up with Kairos. You know, 24 that freezing is as much a concern right now as it is 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
65 vessel integrity and the maximum temperatures and I 1
think I'll just have to leave it at that.
2 MEMBER HALNON: So, when you all look at 3
that, at the freezing, and the temperature range, and 4
low decay heat, just from experience, you know, when 5
you have a scram from a low decay heat perspective, 6
things happen.
7 There are other effects from other systems 8
and I will try to translate it, maybe like the inner 9
gas system or some other system that may either remove 10 a little bit of heat that's significant now because 11 you have a low decay heat, or maybe it would add some 12 heat ahead of the scram or the pressurizer heaters and 13 a little bit of vent insulation cause more heat than 14 the core was putting out and cause natural circulation 15 issues.
16 So, there's some interactions that go 17 forth beyond just the core and the decay heat recovery 18 system, so you might want to make sure that we look 19 at, you know, expand your bubble a little bit, your 20 circle of what you're going to analyze as you look at 21 low decay heat type situations.
22 MR. SCHMIDT: Yeah, I mean, I can think of 23 one system off the top of my head that, I mean, is 24 kind of in that same vein is the cover gas system.
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66 MEMBER HALNON: Right.
1 MR. SCHMIDT: Let's say you increase the 2
flow of the cover gas system, either it might be some 3
cooling effect associated with the Flibe and hence you 4
get to freeze faster, so that's kind of like a control 5
system if I were to group it that could, you know, 6
lead to an earlier freeze. You know, we are -- we 7
have noted that.
8 MEMBER HALNON: Okay, that's the thought 9
process I was hoping to get to.
10 MR. SCHMIDT: Yeah.
11 MEMBER HALNON: Good.
12 MR. SCHMIDT: You know, some of these 13 systems, I think, as you go through are not well-14 defined in a preliminary design. We're going to need 15 final design like flow rates and things like that to 16 really determine if that is a significant factor or 17 not.
18 You know, some of these things are on the 19 staff's mind, but we're not able to nail some of these 20 down yet without the final details, and I think you're 21 going to be hearing that multiple times, you know, in 22 the subcommittee meetings coming forward.
23 DR. BLEY: Hey, Jeff?
24 MR. SCHMIDT: Yes?
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67 DR. BLEY: Dennis Bley. This is an odd 1
question. All of these construction permits, we built 2
in language that implies completeness, but we know 3
there are gaps.
4 The one thing we came to on a couple of 5
cases in the past is what you really want for the 6
construction permit is to be convinced that there are 7
no issues that could become really important later 8
that construction or elements of the construction 9
could make it almost impossible to address, and we're 10 really trying to have a cushion and make sure there's 11 no real big thing sitting there.
12 Has there ever been a construction permit 13 issued with step-wise requirements? You know, before 14 you do this certain weld somewhere, you have to find 15 out the aggressiveness of some of the materials that 16 will be there?
17 I don't know that there ever has been a 18 construction permit that had a staging kind of way to 19 it. It's a stage thing itself in getting to the 20 operating license, but I'm just curious if there has 21 been.
22 MR. SCHMIDT: I'm going to have to call 23 for help here because this is my first construction 24 permit, so, you know, maybe others would be better 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
68 able to answer that question, like Ed. I'm looking at 1
Ed.
2 MR. HELVENSTON: Yeah, I'll say -- this is 3
Ed Helvenston from the staff. And this kind of works 4
into the research and development aspect of that 5
requirement that they identify R&D programs that are 6
important and for safety questions brought up during 7
the CP, and we have issued CPs that have had R&D 8
commitments associated with them in the past.
9 DR. BLEY: Yeah, I've not foreseen these, 10 but it seems like that could be really a safe way to 11 go if there are some things that remain as crucial 12 issues.
13 MR. SCHMIDT: This is Jeff Schmidt. Well, 14 in chapter one, there are the R&D items listed and 15 I'll just throw one out like the fluidic device. The 16 staff spent a fair amount of time contemplating. You 17 know, that's necessary for decay heat removal and we 18 were looking for failure modes associated with such a 19 device.
20 You know, that is listed as an R&D because 21 the design is conceptual at this point and they are 22 going through a series of tests of different fluidic 23 devices, and so, you know, that one, I don't know if 24 I'd call it step-wise, but, you know, they have a 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
69 program.
1 They have a schedule. They have, yeah, I 2
mean, they have a test. They're setting up testing 3
programs to find the final design, but I don't know if 4
it's -- I don't necessary consider it, you know, an 5
incremental step. In other words, it's just part of 6
their test program that's a continuum from the CP to 7
the OL.
8 DR. BLEY: Yeah, but it's kind of close, 9
so thanks. That helps. And there are some things 10 that are just really worth getting straight before you 11 build things. Okay, go ahead.
12 MR. SCHMIDT: So, yeah, I think the ones 13 listed in chapter one, I want to say it's 1.3.9, 14 section 1.3.9, and, you know, I think some of the 15 things that we'll be talking with the decay heat 16 removal system is another one of those things, right, 17 for the reasons we just described. Okay, let's go to 18 the next slide.
19 MEMBER DIMITRIJEVIC: Actually, I have a 20 question on this slide, this is Vesna Dimitrijevic, 21 and in the previous slide. So, I'm not seeing this 22 example.
23 For example, you have defined that DHRS is 24 safety significant
- because, you
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70 temperature, and you have discussed the two different 1
safety functions here. One is, you know, to cool the 2
vessel and one is to prevent freezing.
3 In the subtext of defining significance of 4
the system, we have, one of the options is that we can 5
discuss significant safety functions. So, did they go 6
into this process of defining the safety functions and 7
their significance? That's my first question.
8 My second question is (inaudible) what we 9
are calling the PRA mission times. One is that you 10 want to assure there is volume of the water tanks 11 enough for seven days of cooling, and here you want to 12 prevent the freezing within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and so why are 13 there those two different mission times discussed in 14 this case? So, those are my two questions.
15 MR. SCHMIDT: So, this is Jeff Schmidt.
16 The first part of your questions is, you know, Kairos, 17 as part of their PSAR, identified what they thought as 18 safety significance and the safety-related systems to 19 mitigate those events, and then the staff reviews 20 those. The second part of your question --
21 MEMBER DIMITRIJEVIC: Did they define the 22 safety functions in this process?
23 MR. SCHMIDT: Yeah, the safety functions, 24 yes, yes.
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71 MEMBER DIMITRIJEVIC: Okay, so they 1
defined the safety functions and then tagged them as 2
important and as not important, because we can see 3
here that cooling the vessel is an important safety 4
function, but prevent freezing was determined, maybe 5
wasn't even defined as a safety function.
6 MR. SCHMIDT: It was defined as a safety 7
function. I think the staff had concerns whether the 8
design could accommodate both. Yeah, their goal was 9
always to prevent freezing with a specific mission 10 time, and we had to ensure that the language was clear 11 throughout the document that that was a commitment.
12 I'm sorry, the second part of your 13 question was?
14 MEMBER DIMITRIJEVIC: This mission --
15 (Simultaneous speaking.)
16 MR. SCHMIDT: The mission, oh, mission 17 time. Thank you, yeah.
18 MEMBER DIMITRIJEVIC: You said about six, 19 seven days of cooling and 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> without operator 20 action.
21 MR. SCHMIDT: Yeah, so the 72 is borrowed 22 from the power reactors' phase for passive systems, 23 the utility, I think it's called resource document 24 URD. The seven days is kind of analogous to the 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
72 thought process for diesel fuel going out to seven 1
days.
2 They had the capacity to do seven days 3
and, you know, part of the, I guess, staff's concern 4
was, you know, if you have an external event that's 5
pretty severe, you know, would you have enough onsite 6
water to be able to cope with that? And that was kind 7
of where the seven days comes from. Again, it's 8
analogous to the diesel fuel for existing light water 9
reactors.
10 MEMBER DIMITRIJEVIC: All right, well, 11 thanks. I mean, you know, I would like to see some 12 systematic definition of these things. In the 13 beginning, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from what, from onset of what type 14 of transient?
15 Also, I wanted to add if you don't use the 16 PRA determining safety significance or something that 17 is basic principles like the systems which perform 18 safety-significant functions, the systems which are 19 preventing the important transients, the systems which 20 are bad for defense-in-depth.
21 So, that is always better when there is 22 some systematic approach to that instead of just 23 stating or say this is the case of this source. All 24 right, so this is just my personal comment.
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73 MR. SCHMIDT: Yeah, I guess I'd like to 1
follow up because I think Jose had the same comment.
2 So, there was, before the PSAR was submitted, there 3
was an analysis. I don't know if analysis is the 4
right word. There was a document that Kairos went 5
through and basically did like fault tree analysis on 6
the system.
7 So, they had their system, you know, to 8
the level of detail that was designed at that point, 9
and they went through a fault tree to basically say, 10 you know, how this would be addressed, what system 11 would be addressed, the potential failure modes of 12 these events, and the ones that they were going to 13 preclude by design.
14 So, there was a systematic approach that 15 Kairos used prior to the PSAR, and I'm sorry I can't 16 remember the name of that document. I'll have to get 17 back to you on that, but the staff did review to try 18 to determine if, you know, events not normally 19 considered were captured by this fault tree analysis.
20 MEMBER MARCH-LEUBA: Is that a docketed 21 document? The question is can we get a copy or was it 22 internal?
23 MR. SCHMIDT: It was an audit.
24 MEMBER MARCH-LEUBA: It was an audit?
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74 MR. SCHMIDT: It was an audit.
1 MEMBER MARCH-LEUBA: Do we have a Reading 2
Room that Kairos can put it in so we can look?
3 Because that's something we would be very interested 4
in.
5 MR. SCHMIDT: I'll get back to you on 6
that, yeah.
7 MEMBER MARCH-LEUBA: So, you'll take the 8
action item? Because that's some very interesting 9
document.
10 MR. SCHMIDT: Yeah.
11 PARTICIPANT: The functional failure modes 12 and effect analysis.
13 MR. SCHMIDT: Yeah, I think that was the 14 title of it, yeah, but I'm not 100 percent sure. I 15 reviewed it quite a while ago, so I'm not sure I 16 remember the name.
17 MEMBER KIRCHNER: It's interesting to 18 observe, Jeff, that we, with other applicants, we've 19 seen this too where they've done this kind of what I 20 would call what you just called it, failure modes and 21 effect analysis, kind of getting at Jose's point of 22 this blank sheet of paper, but it wasn't part of the 23 formal submittal. It wasn't part of the -- I think 24 you know which applicant I'm talking about.
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75 MEMBER MARCH-LEUBA: Yeah, the staff has 1
access to all of those non-docketed documents via 2
audits and we have access via Reading Room through the 3
courtesy of the applicant.
4 MEMBER KIRCHNER: And the staff, that's 5
correct.
6 MEMBER MARCH-LEUBA: Because they're not 7
public documents, so you cannot put it on your NRC 8
laptop. You have to go through their website.
9 MR. SCHMIDT: I guess the point I was 10 trying to make is that Kairos has done those type, 11 that type of work to try to identify events.
12 MEMBER MARCH-LEUBA: Yeah, that would 13 satisfy many, many of my questions, and I'm sure Walt 14 is in charge of Chapter 13, so it would satisfy many 15 of his questions too.
16 MR. SCHMIDT: Okay, yeah, let's move on.
17 The other example I wanted to get out in front of 18 everybody was, you know, how the staff approached the 19 methodologies and evaluation models.
20 Just for reference, there are illustrative 21 examples of some of the transients in a technical 22 report that's referenced in the PSAR, and so there are 23 figures comparing to larger than MHA in most cases, at 24 least for some of the transients, that kind of inform, 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
76 helped inform staff's review, but those codes are not 1
-- you know, they're using codes that have not been 2
validated. None of the codes have been V&Ved in this 3
submittal, so I think keep that in mind.
4 So, the staff focused on important 5
phenomenon. The methodologies and the codes pick up 6
the important phenomenon in an event and I'll just 7
throw out an example.
8 I reviewed the pebble handling system.
9 You know, one of them is that pebbles get out and they 10 oxidize in air. You know, what does the oxidation 11 model look like? Does it seem reasonable for the 12 matrix material that I expect to see, you know, for 13 this pebble?
14 So, we looked at, you know, are the 15 important phenomena picked up like oxidation and the 16 potential release due to oxidation? The range of 17 conditions evaluated, there was a fair amount of 18 discussion of do the methodologies really cover a 19 broad range of conditions?
20 The classic example is rod withdrawals.
21 You know, you're limiting rod withdrawal that may 22 bypass your flux rate trip and be more limiting than, 23 say, a fast, big pull withdrawal that would be 24 terminated by the flux rate trip, right?
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77 So, did the methodologies and the 1
construct cover events like that and was it explicit 2
in that it covers those events? So, that was an area 3
for the staff's review.
4 Consideration of uncertainties, the staff 5
said, you know, the document has to reflect there are 6
uncertainties associated with these and what 7
uncertainties are important and how will they be 8
captured.
9 You know, certainty values are not 10 available, but the concept of where you need 11 uncertainties, that's what the staff tried to pick up 12 in its review.
13 Identifying model conservatisms, and this 14 kind of goes with the margin is, you know, the staff 15 looked at areas where we thought margins may be 16 stressed, or challenged is probably a better word to 17 say.
18 So, margins in our review were always on 19 our mind and I alluded to the vessel as being one, and 20 the vessel and even like what are going to be your 21 temperature measurements for how many are you going to 22 have and where are they going to be type of questions.
23 You know, we didn't resolve all of those 24 to the level of detail because that's probably, you 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
78 know, commensurate with the OL, but we were asking 1
those type of questions of like you might need more 2
than just the outlet plan in this design as, say, what 3
might be a necessary temperature measurement for 4
vessel purposes.
5 So, all of those things, the staff looked 6
at through the chapter, you know, primarily the 7
Chapter 13 and 4 events. Again, I mentioned the codes 8
are not validated.
9 Staff performed a detailed review of the 10 MHA and underlying supporting calculations within the 11 limits of the preliminary design information. So, 12 there, there are supporting documents that we can look 13 at and a good example would be like tritium uptake.
14 You know, we spent a fair amount of time 15 reviewing tritium uptake models, methods, and release 16 fractions that would be associated with, say, tritium.
17 So, that is one calculation that I think, you know, is 18 more fleshed out, obviously, than some of the 19 underlying Chapter 13 postulated events. Next slide, 20 please?
21 So,
- because, you
- know, we haven't 22 performed V&V, the staff had to use a variety of means 23 to reach its reasonable assurance finding, and I 24 provided a list of -- you know, not all are used in 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
79 every case.
1 It was a case by case basis, but, you 2
know, when correlations were used, we would look to 3
see if those correlations are typically used in pebble 4
beds. Are they correlations that, say, Sandia is 5
using in MELCOR or its models? You know, are those 6
correlations reasonable at this stage of the design?
7 We reviewed journal articles that 8
performed similar analysis or similar modeling 9
approaches to get a feel for how the system responds, 10 whether the margins seemed reasonable. So, we did a 11 fair amount of, you know, journal searching, a lot of 12 times associated with the UC Berkeley Mark 1 design.
13 You know, we looked at some of those journal articles.
14 I looked at some journal articles on pebble design, 15 for example.
16 Integral tests, you know, primarily that 17 was in the area of fuel and I used the AGR program 18 data and the EPRI topical report for like, you know, 19 do fuel failure fractions look reasonable? You know, 20 is it reasonable to assume relatively small or 21 negligible transient-induced failures? I used the AGR 22 data to help inform that decision.
23 We did perform some scoping, what I would 24 call scoping calculations to inform our engineering 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
80 judgement. There, we utilized the UC Berkeley Mark 1 1
design that research had set up and we modified it to 2
the extent that could be supported with the 3
preliminary design information to model what we call 4
our Hermes-like design.
5 You know, we can't say it's Hermes because 6
we don't have the details to really say it's Hermes, 7
but there we wanted to get a feel for things like 8
power distribution, reactivity coefficients, whether 9
we were seeing the right signs, the signs were 10 consistent with like different areas of the core.
11 We ran some transients to see if the 12 transient behavior was somewhat similar to what was in 13 their illustrative examples. It's really focused on 14 the term scoping calculations.
15 Now, normally I use the word confirmatory, 16 but the level of detail is not sufficient to call them 17 confirmatory and they shouldn't be judged that.
18 Again, we were just trying to inform our engineering 19 judgment as best we could at the time with the 20 information provided.
21 MEMBER MARCH-LEUBA: In that light, I 22 don't really like the concept of technical reports 23 because all of this, the technical report is embedded 24 in the chapter of the PSAR, but by you issuing an SER 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
81 on the PSAR, are you implicitly approving this 1
methodology?
2 You're telling me you're not, that you are going 3
to have to issue a new SER for the OL? So, they're 4
going to have to attach, for example? I'm thinking of 5
topical report 017 --
6 MR. SCHMIDT: Right.
7 MEMBER MARCH-LEUBA: -- which is the 8
methodology.
9 MR. SCHMIDT: Well, okay, so 017 is a 10 technical report.
11 MEMBER MARCH-LEUBA: Correct.
12 MR. SCHMIDT: Yeah, that's referenced in 13 Chapter 4. So, to the level we're able to, yes, we're 14 effectively approving that. Could it change? Yes, 15 I'll give an example.
16 So, on the pebble handling system, they 17 use an oxide correlation that is specific to what the 18 journal article called the new A3-3 matrix material, 19 but Kairos is doing their own testing of their own 20 matrix material.
21 So, the methodology was reviewed, but the 22 actual final values may change because their matrix 23 material may be different than that, and hence the 24 oxidation rates may be different, or as, say, the 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
82 building or wherever the worst case where the pebbles 1
might spill, you know, might have different heat 2
transfer modes than are just assumed in this design 3
and maybe the temperatures could change.
4 So, I think the way to look at it is, the 5
way we looked at it was we were looking for important 6
physical phenomenon and methodology. The final values 7
are subject to change based on the preliminary nature.
8 MEMBER MARCH-LEUBA: Yeah, but the final 9
values were reflected in Chapter 13 of the FSAR.
10 MR. SCHMIDT: Yes.
11 MEMBER MARCH-LEUBA: The methodology is in 12 TR17. Is that fully reviewed? And if there is a lot 13 to change in that report, can they use that for the 14 operating license?
15 MR. SCHMIDT: Yeah, so it's incorporated 16 by reference, so if the PSAR changes, so when the PSAR 17 becomes the FSAR, that is subject to change, right.
18 That's going to be --
19 MEMBER MARCH-LEUBA: Because the technical 20 report cannot be used in the FSAR. It hasn't been 21 approved for any application.
22 MR. SCHMIDT: Well, like a modification to 23 that will likely appear in that.
24 MEMBER MARCH-LEUBA: Basically, I know 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
83 you're going to review it and we want you to review it 1
again.
2 MEMBER HALNON: The technical report 3
initially was done under the quality program 4
calculations, so it's subject to 50.59 as soon as you 5
issue the SER for the PSAR. I assume that any changes 6
from there on our is subject to 50.59 in some respect.
7 Just make sure that those changes you're talking about 8
are captured under the quality program. Is that --
9 I'm stating that. Is that correct?
10 MR. SCHMIDT: I guess I'm going to have to 11 defer whether 50.59 applies to a construction permit.
12 MEMBER HALNON: Well, it may not be 50.59 13 in itself, but it still, the changes have to be 14 controlled by some quality program and some --
15 MR. SCHMIDT: Oh, yes.
16 MEMBER HALNON: -- change program --
17 MR. SCHMIDT: Yes.
18 MEMBER HALNON: -- that allows you to 19 review it against the PSAR --
20 MR. SCHMIDT: Yes.
21 MEMBER HALNON: -- assumptions or what 22 you're going to reviewing in the FSAR has to start 23 from scratch.
24 MR. SCHMIDT: No, we don't anticipate 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
84 starting from scratch and all of the changes have to 1
be done under a quality program, yeah.
2 MEMBER HALNON: So, you'll have a record 3
of those changes and you'll know where it's been and 4
where it's going.
5 MR. SCHMIDT: Yeah, I know it has to be 6
done and I think we can audit those as we see fit, 7
but, I mean, we really care primarily about the final, 8
right. The emphasis will be on the final design and 9
we'll compare the final probably back to the PSAR.
10 MEMBER HALNON: Yeah, so much like a 11 calculation that's done onsite, maybe just a very 12 simple one that's referenced in the FSAR, you'll look 13 at the calculation to make sure it's all correct, and 14 then from there on out, any changes have to be 15 assessed through 50.59 to the FSAR.
16 MR. SCHMIDT: Right, after the --
17 MEMBER HALNON: So, is there an equivalent 18 thing in the construction portion? I know it's 19 controlled by the quality program, but is there --
20 MR. SCHMIDT: Yeah, beyond --
21 MR. SHAMS: I can respond to that.
22 MR. SCHMIDT: I'm going to need some help 23 on that, yeah.
24 MR. SHAMS: Mo Shams with the staff.
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85 There is. The space that the licensee would be in or 1
the applicant would be in after the construction 2
permit is the inspection phase.
3 We have every ability to go in and inspect 4
the construction activities, as well as their 5
implementation of their QA
- program, including 6
correction to their documentation calculations, as 7
well as, you know, whatever is being done on 8
construction itself. So, that's inherent in the 9
process that we apply during construction.
10 MEMBER HALNON: And the fact that it's 11 preliminary allows that final --
12 MR. SHAMS: Correct.
13 MEMBER HALNON: It's the final safety, but 14 what we're really interested in is making sure those 15 technical reports are validated or correct.
16 MEMBER REMPE: So, I have, one, I wanted 17 to note that I was glad to hear that the research 18 efforts to do the pilot plan evaluations were helpful, 19 and that you even further modified another design and 20 used the MELCOR code or whatever codes from research.
21 One of the things that I know we mentioned 22 to the staff when they presented and discussed them 23 with us was about what were some key assumptions or 24 properties that most affected the results, and did 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
86 those kind of insights come through and help you in 1
your evaluation of what Kairos presented for their 2
analyses to help you focus on hey, that data is not 3
yet available and it needs to be obtained?
4 And then in looking at your examples 5
again, I just want to reiterate a point I think, I 6
hope I tried to make before that I'm not sure it's 7
realistic to expect that everything will be validated 8
or done by the time the plant Hermes starts up because 9
of the fact that there's not much, if any, operating 10 experience for this type of reactor and its fuel, et 11 cetera.
12 And, I mean, we've heard that for a 13 demonstration facility like this, one can have a 14 lighter touch. It's just low power, but it sure seems 15 like that there are some key things that staff would 16 want to identify and say we're letting you have a 17 lighter touch, but we sure would like to see this 18 validated later on.
19 And I think those kind of things should be 20 documented somewhere so the folks that are out in the 21 region understand what headquarters has said and 22 perhaps consults with headquarters to say yeah, this 23 is what we need to do and how it will be monitored.
24 MR. SHAMS: So, Mo Shams with the staff.
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87 Let me try to take a shot at it because I think this 1
is an incredibly important sort of conceptual or 2
foundational thought on how we approach testing 3
research reactors.
4 MEMBER REMPE: Yeah, and this goes beyond 5
key permits.
6 MR. SHAMS: Absolutely, I think what 7
you're describing is totally integral to our thinking.
8 Do we have the right information to be able to 9
authorize that facility to operate? And that's what 10 we're seeking.
11 Now, the level of information drives what 12 we put in the tech specs, how much power. These 13 facilities are in their own dynamics with the staff 14 are and sort of a more dynamic operation than a power 15 reactor in the sense that they come back for renewals 16 or they come back for changes in the tech specs.
17 So, this is how we are actually sort of 18 applying what we know and the confidence that we have 19 in the safe operation of the facilities through the 20 different requirements that are applied to them.
21 And the entire nature of a test reactor is 22 one of let me start here and then I'll go forward to 23 be able to obtain the information, either offer it 24 just for other power reactors or for one that's 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
88 entirely based on that technology as well.
1 So, we're confident that we're going to 2
get to the place. Wherever they're starting is 3
commensurate with the information
- provided, 4
commensurate with the risk of the
- facility, 5
commensurate with the licensing terms for the 6
facility.
7 Kairos is not a 40-year facility. It's --
8 yes. So, that sort of informs our look into the 9
durability of the material or such that the burnup, 10 you know, sort of information for the fuel. That sort 11 of stuff all feeds into how we look at the facility 12 and what solution we get.
13 MEMBER REMPE: So, the tech specs are 14 where I expected it to be, but I hope that it's -- I 15 mean, the tech specs are kind of out there like in one 16 area, but there are certain concepts that one expects 17 to be evaluated and the tech specs would guide it, and 18 I just am wondering will there be a list of those 19 concepts?
20 And again, this is just the PSAR. I get 21 it that you could wait until later, but it just seems 22 like a good place to start making that list and have 23 it --
24 MR. SHAMS: Sure.
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89 MEMBER REMPE: -- documented and --
1 MR. SHAMS: Sure, and I think what Jeff 2
was indicating earlier is such thinking is honest. If 3
there's a formalized part which is Appendix A, these 4
are particular commitments that the applicant needs to 5
do, there's a formalized part. That's the research 6
plan and testing plan that's intended to be done.
7 There's also something else which is 8
Kairos is actually building three different 9
engineering units prior to actually they get into the 10 nuclear unit itself, to be able to validate certain 11 concepts.
12 So, and the point I'll get to, and I know, 13 the last one, is there's information that we need for 14 the test facility itself and there is information that 15 we're going to need from the test facility to the 16 power reactor, and to your point, we cannot start the 17 power reactors without the testing facility giving us 18 all of this information. So, one way or another, 19 we're going to need information from that machine.
20 MEMBER REMPE: So, I think we're on the 21 same path, but Appendix A is stuff, traditionally has 22 been stuff just needed to be completed by the 23 operating license --
24 MR. SHAMS: Yes.
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90 MEMBER REMPE: -- but my point is that 1
we're giving it a lighter touch. I think there are 2
some things that after you start operating also should 3
be done, perhaps to have a little more confidence 4
through the four years this thing's going, but also 5
for the future reactor, and where will they -- where 6
is that documented?
7 MR. SCHMIDT: So, can I kind of just -- I 8
think there's one other aspect and that probably won't 9
fully address your concern, but, you know, the other 10 thing that we are thinking about is, you know, we have 11 startup tests.
12 Startup tests will, you know, don't get 13 the time evolution failure modes maybe or concerns, 14 but they allow, you know, kind of like goal posts, and 15 to say that, just to say that like the Chapter 13 16 safety analyses are still valued, right, you know, 17 rods or reactivity coefficients.
18 So, we have been thinking, you know, what 19 needs to be in that startup test plan that would, you 20 know, inform us that, yeah, if they were to complete 21 that successfully, they could continue. If they 22 couldn't, then maybe they would have to pause, right.
23 So, the startup tests and the startup 24 tests for this reactor will be different and probably 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
91 larger than a traditional light water reactor, but the 1
staff has already been going there thinking about 2
things like what would this even look like?
3 MEMBER REMPE: This is good. I know so 4
many times in the past when we asked questions about 5
startup testing or operating procedures, we always get 6
the response oh, we're going to do that later. It's 7
not part of the operating license.
8 And again, I just kind of think a list 9
somewhere, and again, the startup test plans are 10 another place where it can be done, but just a list of 11 things that are areas that might be considered, that 12 will be better fleshed out at the operating license 13 stage, but I just think a list would be nice as again, 14 because it's not just with Kairos.
15 It's going to come up with other designs 16 we're reviewing, and it's just something to think 17 about that I think would be helpful for an early 18 indicator for the applicant as well as for the staff 19 in future reviews.
20 MR. SCHMIDT: Okay, thank you.
21 MEMBER REMPE: If one member's --
22 (Simultaneous speaking.)
23 MR. SCHMIDT: I guess I want to just 24 finish up my two slides here. Let's see, so we kind 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
92 of went through the various tools that were available 1
for the staff's review based on the preliminary 2
information. So, you know, I want to be clear what's 3
going to be like between now, the CP roughly, and the 4
OL.
5 So, review software quality assurance and 6
implementation. Those are things like, you know, part 7
of V&V, code error, code error notices. Are you 8
picking those up? Are they relevant? Are you 9
evaluating those?
10 Like code nodal maps, right, nodalization, 11 you know, we didn't go through like nodalization 12 studies to pick up if -- I mean, the state of the 13 models, I don't think it's -- that would be picked up 14 effectively as part of the OL or another topical 15 report that would, say, pertain to their KP-SAM code.
16 You know, we would look at nodalization studies there.
17 Review code inputs, we didn't ask for 18 input decks. We didn't go through and see if those 19 input decks are reasonable. Again, that is something 20 that would be done during, you know, really at the OL 21 stage for the final FSAR.
22 Material properties, you know, we have 23 obviously some insights into the material properties 24 based on the topical reports, things like effective 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
93 safety analysis, like the viscosity is a function of 1
temperature is kind of a key one.
2 You know, they acknowledge that they're 3
going to look at a range and the range is consistent 4
with their topical report. We didn't go and check 5
that their codes did that, that had that input. We 6
just kind of said, you know, these are important. You 7
need to include them in the methodology.
8 And we didn't exercise the applicant's 9
code or perform confirmatory analysis. I said 10 scoping. I'm clearly defining the difference between 11 scoping and confirmatory here. We just don't have the 12 design information to do what I would consider 13 confirmatory analyses at this point.
14 Justification of models may be provided by 15 test results. I indicated that the ADR program is 16 probably the most relevant one there. It will also be 17 their test results, right. They have an extensive 18 testing program. We'll be looking at that data.
19 The code V&V, the tradition sense of code 20 V&V will be done, and then other methods before and 21 during the operating license review. So, just to put 22 it in context, I mean, we'll be reviewing this I would 23 say similar to what we do for power reactors in the 24 sense of codes and methods. There's not going to be 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
94 a big space in that differential.
1 CHAIR PETTI: But in the end -- for 2
instance, there's a lot of pebble bed stuff out there 3
for gas pebble beds.
4 MR. SCHMIDT: Yes, yes.
5 CHAIR PETTI: And I'm sure they're going 6
to use those.
7 (Simultaneous speaking.)
8 MR. SCHMIDT: There are certain things 9
that they are examining whether they're applicable.
10 CHAIR PETTI: Sure, but I mean, just, you 11 know, calculating K-effect or calculating reactivity 12 coefficients, you know, I think you're going to start 13
-- you should use the (inaudible) cases to give you 14 some confidence that you're code knows what it's doing 15 16 MR. SCHMIDT: Right.
17 CHAIR PETTI: -- and then you move on, but 18 it's putting the salt with the pebble together that 19 there's just going to be little data, but they're get 20 some great thermal hydraulic data out of their test 21 facilities hopefully --
22 MR. SCHMIDT: That's right.
23 CHAIR PETTI: -- that will inform that.
24 So, you know, it's a patchwork, but in the end, the 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
95 only integral test is the actual reactor, right, so.
1 MR. SCHMIDT: Yes, that is correct, yeah.
2 MEMBER MARCH-LEUBA: My only question is 3
when I look at this technical report, it looks like a 4
topical report, and if it was a topical report, you, 5
Jeff Schmidt, would have written an SER underneath 6
that would be at least 50 page, if not 150 pages, no, 7
not yet.
8 But all I see in the documentation is half 9
a page in the SER for Chapter 4, so however we are 10 proving on the methodology by implicitly approving 11 Chapter 4 and the whole PSAR. I mean, whereas your 12 expectation is that it's going to be further reviewed.
13 They will have to do a lot more evaluation and we, the 14 staff, and I mean you, are going to look at it again.
15 MR. SCHMIDT: Yes.
16 MEMBER MARCH-LEUBA: So, that's why I 17 don't understand all of the technical reports.
18 MR. SCHMIDT: So, in some sense, it's 19 better. It's not a topical report because there are 20 probably going to be some changes to that inevitably, 21 and if we wrote a safety evaluation like you said, 22 there would probably be as many pages of limitations 23 and conditions as there are pages to the safety 24 evaluation. I'm not sure that makes a lot of sense at 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
96 this point.
1 MEMBER MARCH-LEUBA: But your expectation 2
is for the OL, the operating license, you will review 3
the methodology again?
4 MR. SCHMIDT: Yes.
5 MEMBER MARCH-LEUBA: Because it will have 6
changed.
7 MR.
SCHMIDT:
Absolutely, this is 8
methodology for a construction permit and the level of 9
detail, we thought it was commensurate with a 10 construction permit. Everything starts again at the 11 OL.
12 MEMBER MARCH-LEUBA: And you will not be 13 heard if I propose to the members that our letter says 14 that, that the methodology (inaudible) CP and the 15 methodology is expected to increase for the OL and we 16 have to review it again.
17 MR. SCHMIDT: Yes, I mean, I expect that 18 to be true.
19 CHAIR PETTI: Yeah, just, and, you know, 20 if you remember, other applicants we've had between 21 preliminary and final panel, it wasn't just changing 22 the correlation. There were major changes to 23 materials, the processes, and it took a lot of -- it 24 changed the whole nature of the review, but, you know, 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
97 so --
1 MEMBER MARCH-LEUBA: I'm more concerned --
2 CHAIR PETTI: This is why you serve a top 3
down functional thing. You do the best you think you 4
can.
5 MEMBER MARCH-LEUBA: You asked me to write 6
you a couple of paragraphs on TR 017 and this is what, 7
this is perfectly -- what we've done is more than 8
sufficient for the CP. The oil will change and will 9
need to be done again.
10 MR. SCHMIDT: Agree.
11 MEMBER KIRCHNER: We'd just like to make 12 an observation that the staff, back when the advanced 13 reactor policy statements were written, now we're back 14 in the '90s time frame, opined extensively on 15 prototypes.
16 And what I would just like to observe is 17 that this is a good thing, what's happening here with 18 the Hermes test reactor. They're not trying to make 19 that leap right to a power reactor. Yesterday, we 20 heard from another applicant. They are going to also 21 do a prototype.
22 And I think, again, this is a preliminary 23 design, so from what I see, this is one person's 24 opinion, I think the staff is doing a reasonable job 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
98 for where the applicant is at this point with the 1
preliminary design and this allows the technology to 2
go forward, and I think that's extremely important.
3 Not every I and T is going to be crossed at this 4
point.
5 Going back to technical reports, I could 6
see -- I'll make up a simple example which actually is 7
derived from what's in front of us from another 8
applicant is that there's a technical report on the 9
choice of the stainless steel material for a vessel, 10 reactor vessel, and a lower head. I could see that 11 changing as they learn more or they identify a better 12 material and so on.
13 So, that's just a rhetorical example, but 14 what I've seen so far there, yeah, you don't need 15 quite the in-depth that goes into a topical report for 16 a methodology that we were just talking about at this 17 point.
18 So, I think maybe we should ask the staff 19 about how they're going to handle technical reports 20 that are attached to FSAR or PSAR chapters in the 21 future and --
22 MEMBER MARCH-LEUBA: That's exactly what 23 I'm asking.
24 MEMBER KIRCHNER: -- the process there.
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99 MEMBER MARCH-LEUBA: One concern that I 1
have, I have --
2 (Simultaneous speaking.)
3 MEMBER KIRCHNER: That's only on FSARs, 4
so.
5 MEMBER MARCH-LEUBA: You know I have a 6
dirty mind and I'm thinking here an applicant can save 7
a lot of money by saying you already approved it 8
before, well, yeah, I'm going to use that one that you 9
approved and I'm not going to change it. Kairos is 10 too responsible to do that because I know them, but we 11 should not allow them the temptation.
12 MR. SCHMIDT: Yeah, I mean, we reviewed 13 the methodology to see if it picked up all of the 14 important phenomena. The final like correlations, for 15 example, they're all subject to either the test 16 programs or change at this point.
17 So, you know, I think the framework is 18 pretty good. I don't expect a lot of changes in the 19 overall framework, but the final details, I guess I 20 expect changes and the staff is going to have to re-21 review all of that stuff again to the level that it's 22 commensurate with an FSAR.
23 MEMBER MARCH-LEUBA:
All of the 24 correlations are going to be different and all of the 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
100 uncertainties are going to be different because --
1 MR. SCHMIDT: Certainly, the uncertainties 2
are not identified, yeah.
3 (Simultaneous speaking.)
4 MR.
SCHMIDT:
The theories of 5
uncertainties are. The final values are not.
6 MEMBER MARCH-LEUBA: So, it's going to 7
change.
8 MEMBER KIRCHNER: To repeat myself, when 9
the staff back 30 years ago opined about prototypes, 10 they basically looked at it in the sense of the 11 prototype should be of sufficient scale and fidelity, 12 these are my words, not the staff's words, such that 13 the primary safety functions can be demonstrated 14 through the concept, and that was how they basically 15 put together guidance on the topic of prototypes.
16 So, what we have in front of us now is 17 indeed a prototype that is addressing those major 18 safety functions, hopefully successfully.
19 MR.
SCHMIDT:
So, that ends my 20 presentation about that. Is there anything after 21 these slides?
22 MR. BEASLEY: The last slide is just 23 contact information.
24 CHAIR PETTI: Okay, so I have a question.
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
101 Let's talk about MHA for a minute --
1 MR. SCHMIDT: Okay.
2 CHAIR PETTI: -- because that's going to 3
come up. How do you establish the reasonableness of 4
the MHA? Is it, if I think in power reactor terms, is 5
it supposed to be sort of a worst-case DBA or is it, 6
because it's hypothetical, sort of slightly beyond the 7
DBA?
8 MR. SCHMIDT: So --
9 CHAIR PETTI: Because, I mean, we're going 10 to talk about it. I'm sure we're going to get into 11 that in detail.
12 MR. SCHMIDT: So, Ed can correct me or Ben 13 can correct me as we go, but, you know, the construct 14 is the MHA forms the box or outer envelope, and all 15 the DBAs effectively have to fall, you know, below it 16 or MHA bounds it.
17 And, you know, you look at both material 18 limits, like the stainless steel we were talking 19 about, as well as the dose criteria. So, all of your 20 events, and I'll just throw one out for an example, 21 like the salt spill accident, you know, that event, at 22 the end of the day, has to be bounded by the dose 23 associated with MHA.
24 So, the MHA is bounding from that, but it 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
102 is not a DBA. It also assumes some functions perform 1
as expected. Some safety-related functions perform as 2
expected and I'll give you a specific example, reactor 3
trip.
4 It assumes you have reactor trip and you 5
have at least three trains of decay heat removal. So, 6
with certain assumptions, what I typically call like 7
reactor system assumptions, system performance 8
assumptions, then the MHA bounds those other events.
9 CHAIR PETTI: So, you don't -- I mean, 10 let's go over the sodium reactors and unprotected 11 transients. You know, it was such a big deal back in 12 the day that EBR2 did with the reactor unprotected 13 transients, right.
14 MR. SCHMIDT: Right.
15 CHAIR PETTI: The system did not trip and 16 they showed the safety. That certainly sort of would 17 bound any MHA or could be a surrogate for MHA, but 18 you're saying that no, you tend to assume the safety 19 functions?
20 MR. SCHMIDT: There is a section called 21 precluded events. Those events are precluded. Those 22 are -- you know, there are certain assumptions that 23 will, that have to happen to ensure, I think, the MHA 24 is bounded.
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103 MEMBER MARCH-LEUBA: Is that consistent 1
with a single failure criteria or it's more of an LMP?
2 MR. SCHMIDT: The single failure criteria 3
is addressed. So, like when I talked about like the 4
5 CHAIR PETTI: Yeah, three out of four.
6 MR. SCHMIDT: -- I did one train.
7 MEMBER MARCH-LEUBA: No, I'm talking about 8
the MHA, what you were talking now about the precluded 9
events.
10 MR. SCHMIDT: The precluded events?
11 MEMBER MARCH-LEUBA: A lot of it's based 12 on single failure criteria or LMP frequency?
13 MR. SCHMIDT: I mean, it's not based on 14 LMP. I'll just give you an example, like an ATWS-type 15 event is precluded and, you know, we spent a fair 16 amount of time making sure that that was a reasonable 17 assumption based on like testing for control rod 18 insertion into the pebble bed, that you could have 19 adequate control rod insertion.
20 MEMBER MARCH-LEUBA: Yeah, and we have 21 approved, I mean, you guys have approved some reactors 22 for that.
23 MR. SCHMIDT: Well --
24 MEMBER MARCH-LEUBA: For no power.
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104 MR. SCHMIDT: Return to power, are you 1
referring to or you're referring to ATWS?
2 MEMBER MARCH-LEUBA: The high quality of 3
the scram system from reactor (inaudible).
4 MR. SCHMIDT: So, the staff looked at 5
aspects that could potentially challenge the 6
assumptions that went into the MHA is the best way to 7
say it. Again, reactor scram is assumed as part of 8
the MHA. The staff made sure that effectively in the 9
staff's mind, the probability of occurrence was low 10 and they had information supported by testing to 11 ensure that.
12 CHAIR PETTI: I mean, with this system, 13 you could do an unprotected transient and you're 14 probably going to be okay because of the strong 15 negative coefficient calculations, right, which I, you 16 know, have no reason not to believe that they're 17 right, so, but you're saying that you basically don't 18
-- that's sort of beyond.
19 MR. SCHMIDT: That's beyond, I think, what 20 is constructed for the MHA.
21 CHAIR PETTI: That's what they say, but, 22 I mean, are you referring -- is there some guidance 23 that you guys used to, this idea of the safety systems 24 program, I mean, is that written down somewhere that 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
105 1
MEMBER MARCH-LEUBA: What I'm hearing is 2
that this reactor is limited by the vessel, that the 3
fuel is so good that it's transferred immediately to 4
the vessel wall. There is no temperature.
5 CHAIR PETTI: Yeah, but, well, on a 6
reactivity event, I'm not sure that there's some 7
temperatures challenged. There is some temperatures 8
challenged on heat removal, right?
9 MEMBER MARCH-LEUBA: On long term.
10 CHAIR PETTI: Long term.
11 MR. SCHMIDT: I mean, they could be 12 challenged on both. I think you'll see the curves.
13 If we look at the curves in the illustrative example, 14 you know, vessel temperatures can be --
15 MEMBER MARCH-LEUBA: If you're going to 16 scram, the vessel will be --
17 (Simultaneous speaking.)
18 DR. BLEY: If you can use the microphone, 19 it will help.
20 MEMBER MARCH-LEUBA: It's extremely 21 (inaudible). Just talk to it.
22 MR. SCHMIDT: Okay, all right, yeah, sorry 23 about that. I apologize. Yeah, so, you know, all of 24 the events look at whether, their material limit and 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
106 the dose consequence. That's the best way to say it 1
and you'll see those plots. The plots are in the, I 2
want to say the appendix to technical report KPTR018.
3 So, you know, the temperatures feed the 4
releases, dose releases, as well as obviously the 5
limits. The limits for the fuel are, you know, 6
they're nowhere near the limits of the fuel, so that's 7
not really in play, but the vessel limits are, the 8
temperatures associated with the reflector and not 9
necessarily the reflector material limits, but the 10 dose associated with that, those temperatures, and 11 those are all discussed in the safety evaluation, but 12 the MHA is bounding from a dose standpoint.
13 CHAIR PETTI: Any other questions, 14 members, particularly those online?
15 MEMBER SUNSERI: This is Matt. I don't 16 have any questions. Thanks.
17 CHAIR PETTI: Well, then I guess I want to 18 thank you guys.
19 MEMBER MARCH-LEUBA: Are we asking for 20 public comments?
21 CHAIR PETTI: Oh, I suppose so. We'll go 22 out for public comment. If there's any member of the 23 public that wishes to make a comment, please unmute 24 yourself, state your name and your comment. Okay, I'm 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
107 not hearing any.
1 Then, again, I want to thank you. I think 2
this was good. It was productive. It clarified some 3
things, at least in my mind, so with that, I think we 4
should probably go for a small break. Let's --
5 MEMBER REMPE: Your agenda only gave us 6
five minutes. Can we have a little more than five 7
minutes?
8 CHAIR PETTI: So, yeah, let's come back at 9
10:45 then.
10 MEMBER REMPE: Okay.
11 CHAIR PETTI: Thank you.
12 (Whereupon, the above-entitled matter went 13 off the record at 10:26 a.m. and resumed at 10:46 14 a.m.)
15 CHAIR PETTI: Okay, folks. We're back in 16 session, and we've got most members, not all members 17 yet.
18 MEMBER SUNSERI: This is Matt. I'm here 19 if you need a quorum.
20 CHAIR PETTI: No, I think we have a 21 quorum. Subcommittee, so we don't have a quorum. So 22 we're going to deviate a little bit from the agenda.
23 The agenda says we're going to start with Chapter 1, 24 but the staff is going to present Chapter 1 in March 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
108 subcommittee. So we'll hold off doing that until we 1
hear their presentation, in which case we're going to 2
move in to the afternoon chapters.
3 So the first one up is Chapter 10. So if 4
Sandra could bring up the Chapter 10 memo. Is she 5
there? Yes.
6 MS. WALKER: I'm here. I just don't have 7
rights to share.
8 CHAIR PETTI: Oh, okay. Hold on. We're 9
going to do 10, 12, 14, 16, 17, and 18. The memos, 10 yes, because the staff will not present on these 11 because these really have limited information. But 12 for completeness, we're going to still provide a memo 13 on it.
14 So, Joy, it's yours.
15 MEMBER REMPE: Thank you. So when Dave 16 assigned Chapter 10 to me and I looked at it in the 17 application for Hermes, I said, hallelujah, it's only 18 a paragraph long, it's on experimental facilities, and 19 there are none; this ought to be easy. But, anyway, 20 I went ahead and wrote the background up and talked 21 about that and the guidance that was applicable.
22 And if you'll scroll down, Sandra, I did 23 read what the staff wrote, but then I got to thinking 24 about it a bit and, even though there aren't really 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
109 any experimental facilities, there is a capsule where 1
they can irradiate some specimens that it's not 2
supposed to affect reactivity, et cetera. But the 3
thing is the whole test reactor is an experiment, and 4
that is why I, even if you'll even go on down to later 5
parts, there's as lot of things that I just don't 6
think will be known, and that's what I harped on today 7
with the staff about that we hope they validate their 8
codes entirely.
9 We hope they have some adequate knowledge 10 about the performance of the instrumentation, which 11 isn't even identified what sensors they're going to 12 use in the construction permit because they don't have 13 to in a construction permit, but I think that's 14 unrealistic optimism and I think that there will be 15 some things that will have to be identified and 16 investigated further after the plant is granted an 17 operating license because it is a low-power facility 18 and I think the staff will have confidence for 19 adequate safety to give them a reasonable, have 20 reasonable assurance to let them have an operating 21 license.
22 But there ought to be some things that are 23 explored and validated more for continued operation of 24 Hermes, as well as follow-on power reactors, and I 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
110 think that a list ought to be formulated. Again, I 1
don't know what it will be. They might pick their 2
sensors and we may have confidence in them by the time 3
it starts operating, but I have a possible activities 4
include and I have a list there. If somebody wants to 5
add something to the list, I'm willing. This is a 6
draft memo to add it to the list if I agree with it 7
because it is my memo. And I don't think any 8
additional discussion on Chapter 10 is needed, but I'm 9
writing this mainly for the members also to think 10 about this as we go through and maybe in the final 11 letter have a better list than what I have in my memo.
12 And that's about all I wanted to say on 13 this chapter. Vicki, you look like you have a --
14 MEMBER BIER: Yes, I just have a question, 15 which you may not know the answer to. I would be 16 curious, do you sense that they probably do have a 17 first set of sensors picked out and just didn't want 18 to put it in a docketed filing or they really haven't 19 gotten that far in the design yet?
20 MEMBER REMPE: I don't know.
21 CHAIR PETTI: I mean, they're doing these 22 engineering test runs. They're going to have to have 23 some instrumentation there, some instrumentation. But 24 that's in no radiation, but they've got to have some 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
111 instrumentation for that. My guess is they're going 1
to test some stuff and see what works.
2 MEMBER REMPE: Okay. So they talk about 3
the Flibe as a fission product retention barrier.
4 Okay. So how far, what's the height of the Flibe over 5
the core if you're going to count that as a barrier 6
for fission product release, and I know I asked that 7
question and they said we haven't decided yet. Then 8
suddenly that level sensor becomes more important. In 9
light water reactor designs, water level is sometimes 10 a difficult thing to measure and what's the accuracy 11 of it. But there's just a bunch of questions that --
12 and, again, we're going to first-of-a-kind things, and 13 I just think it's important to start thinking about 14 this. And it's not just a Hermes question. It's 15 something that I think ought to be considered for a 16 lot of these test facilities.
17 MEMBER HALNON: So, philosophically, on 18 these prototypes and test reactors that will 19 eventually morph into a larger power-producing 20 reactor, are we expecting them to push the envelope in 21 the operating parameters and maybe even operate it at 22 values that it would not be? In other words, the 23 high-level limits and other things to get data so that 24 they can better inform the higher, for lack of a 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
112 better word, higher risk of the power reactor here?
1 MEMBER REMPE: That's something that came 2
up with another applicant we discussed, but, again, I 3
think that's something that the staff should 4
communicate to the applicant that has informed them 5
they're planning to do this and when they inform it 6
with Hermes. I haven't heard them talk about the 7
higher power ones like we have with other applicants, 8
so I wouldn't have put that in here. I'm just saying, 9
you know --
10 MEMBER HALNON: Well, that's why I was 11 just thinking philosophically because I wouldn't learn 12 a whole lot if I built a prototype and just ran it 13 straight and normal for five years and said, okay, 14 everything looks pretty stable and then not --
15 MEMBER REMPE: I think the staff's 16 responsibility with others who have told us they plan 17 to do it, and that was the question that I pursued in 18 a prior subcommittee meeting that, you know, how is 19 that interaction
- going, and the staff didn't 20 understand my question because maybe I didn't make it 21 clear enough, but I tried to follow-up because they 22 were like, well, it's appropriate to have it 23 authorized by DOE this time, but I'm like, again, you 24 guys really have no authorities being authorized by 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
113 DOE, but they actually are tasked these, not just the 1
applicant who is paying for that demo, and I think 2
that if NRC knows some things, they ought to be 3
pointing out those things. And I think it's just a 4
wise interaction; I don't think that I can do that 5
with this facility.
6 MEMBER HALNON: Yes. Authorized by DOE, 7
to me, didn't mean less study for lower standards of 8
allowing them to cut corners, but I don't know their 9
process. But, nevertheless, I had not heard, I mean, 10 we're treating this thing like it's going to be 11 operating in this envelope and we're going to be 12 gathering data, but is that data really useful after 13 a period of time?
14 CHAIR PETTI: My guess is that they 15 obviously have the design of the bigger machine in 16 mind. So, you know, assuming they have enough margin 17 in a normal operation, which they should, you know --
18 MEMBER HALNON: They would put it through 19 some exercises.
20 CHAIR PETTI: Yes. I mean, the tech specs 21 and LCOs at levels that would allow them to do that.
22 MEMBER HALNON: Yes.
23 MEMBER REMPE: But, again, that may be 24 something that they'll discuss with the staff later.
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114 What I really want, though, is to make sure the 1
headquarters staff is engaged in it because, to convey 2
my concern to Dave, I was like, well, Chernobyl was 3
actually a safety test after the plant was operating, 4
and we didn't want that to happen, although, again, 5
that's a much bigger reactor and a different type and 6
all that stuff. But that's a good way to communicate 7
my concern.
8 MEMBER BIER: Yes. And I agree with some 9
of the comments that Dave was making earlier, like not 10 that it necessarily affects what we say about this one 11 chapter. But the process is kind of opaque if there 12 are some topics that, you know, the staff doesn't 13 address explicitly in what they provide, we really 14 don't know is that because they haven't even gotten to 15 that yet and they don't have that info from the 16 vendor? Is it because they've already reviewed it and 17 decided it's a non-issue and they don't need to delve 18 deeper? It's really hard to see, like, what we're 19 critiquing.
20 CHAIR PETTI: I think this new process, I 21 mean, we've all picked it up. It puts a little bit 22 more work on the staff unfortunately, but they have to 23 come to us and not just tell us what they found but 24 lead us through their due diligence, right, so that we 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
115 get the confidence. And you didn't have to do as much 1
in the old process because we all did it together and 2
it developed out of a common understanding. That's 3
not necessarily come through the new process unless 4
you deliberately think about it.
5 MEMBER MARCH-LEUBA: Speaking of process, 6
for SHINE, we asked them, the reviewers, to write the 7
chair a paragraph for him to put in the letter. And 8
if there were conclusions and recommendations, now 9
would be the time to do it instead of waiting until 10 June.
11 CHAIR PETTI: Yes, yes, no, no, no. So 12 what I'm expecting, when we talk about how we treat 13 the outline of the letter, you'll see that, yes, 14 please write your memos thinking about me listing --
15 MEMBER MARCH-LEUBA: The memo is too long.
16 Now is the time to summarize my memo into one 17 paragraph for a new letter.
18 CHAIR PETTI: Sure. If you want to put 19 it, like, as a conclusion or something.
20 MEMBER MARCH-LEUBA: Oh, no, a separate 21 document, an email.
22 MEMBER REMPE: I will do that. I'll take 23 it -- actually, if I look at --
24 MEMBER MARCH-LEUBA: It makes your life 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
116 much easier if Joy gives you a paragraph on what she 1
meant for this --
2 CHAIR PETTI: But I think you need to see 3
the outline so that you can see the context in which 4
5 MEMBER REMPE: Well, you can write a 6
paragraph and throw it in the trash or do what you 7
want to do with it, and then I'll --
8 (Simultaneous speaking.)
9 MEMBER REMPE: Okay. One thing, though, 10 when I look at this, I see a typo on my part. Sandra, 11 the last thing led to several items that I recommend 12 members explore in our reviews of subsequent, because, 13 sorry, I was thinking about the final letter. But do 14 you see where I'm saying that?
15 MEMBER MARCH-LEUBA: The very last line --
16 MEMBER REMPE: The very last line. And 17 something I picked on Greg on in the past, so I better 18
-- I'm surprised Greg didn't pick on me today. But, 19 anyway, let's say items, yes, several items that I 20 recommend members explore. Members. And then delete 21 the words up to explore. And, again, this is a draft, 22 and I know it will come for signature for me later, 23 but I just was afraid I'd forget it because I looked 24 at this several times and tried to correct things like 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
117 that.
1 MEMBER MARCH-LEUBA: We don't want to fix 2
all the references the panel --
3 MEMBER REMPE: Yes, I didn't do much on 4
the references. I just listed what I thought should 5
be there. Anyway, that's all I have to say for that 6
simple paragraph I was assigned to read.
7 MEMBER MARCH-LEUBA: It's a new record.
8 You wrote a memo that is 20 times longer than the --
9 MEMBER REMPE: Well, the staff did two 10 pages, and I did two pages because --
11 (Simultaneous speaking.)
12 MEMBER MARCH-LEUBA: If the staff's 13 (inaudible) is shorter than the topical report, they 14 (inaudible).
15 MEMBER KIRCHNER: Just one observation I 16 would make is that, at the OL stage, a lot of these 17 things will be done.
18 MEMBER REMPE: Yes. I added that 19 paragraph to respond back to Dave where it says they 20 aren't related to items that will be done at the OL 21 stage. I'm talking about things that go beyond that.
22 MEMBER KIRCHNER: Well, yes. So that's 23 where I was going. So a lot of these things will be 24 done as part of the OL and the startup of the reactor 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
118 sample, instrumentation calibration set points and so 1
on and so forth. It will measure things like 2
reactivity coefficients, and they'll start pulling 3
rods or turning drums or whatever. So it would be --
4 I have no objection to this. I'm just saying that a 5
lot of these things will be picked up at the OL stage.
6 What might be interesting for us to think 7
about and you were hinting at, Joy, is that those 8
things that might go beyond, as Greg was saying, just 9
let's run it for four years and see how it goes kind 10 of thing to some of the testing that would perhaps, at 11 power, demonstrate, much like was done with EVR 2.
12 I'm not suggesting that for this particular machine 13 but where they just set it off on a significant 14 transient that it would have a --
15 CHAIR PETTI: Right. I mean, I've put 16 some notes in my outline about something that I think 17 we ought to discuss. They have no plans to do that.
18 I asked them explicitly whether they would do some 19 sort of transient testing to demonstrate the, you 20 know, the real robustness of the technology, if you 21 will, and they said they didn't. But that said, I 22 also have a list of things that you're not going to 23 know until you build it, right: beryllium control, 24 tritium control, lead ox control in the actual 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
119 environment with neutrons in a temperature grade. You 1
know, you can list a number of them. That's why you 2
have to build one. And, again, it was just to say 3
that there is some residual uncertainty, but that's 4
what a test reactor is about.
5 MEMBER MARCH-LEUBA: Sandra, can you show 6
us lower numbers to the paragraph with the staff 7
concerns? You recommended that ACRS request the staff 8
provide additional information.
Is this a
9 recommendation for the letter? I suppose not. What 10 you're asking is, in a future subcommittee, they 11 address this to us?
12 MEMBER REMPE: I just want more. Again, 13 we heard about some sort of internal list they have, 14 and it's just something that, again, how it gets 15 addressed is beyond my memo. I can beef up a little 16 more of what you're saying, Walt, but I tried to say 17 that when I had these, you know, I said, basically, 18 I'm not talking about the things in Appendix A, which 19 are what you're talking about of things that they 20 expect to be done, and I will add that the thing about 21 startup testing will obviously address some of these 22 things. But I'm thinking about things that will be 23 used that need to be addressed that can only be 24 addressed in a test facility for a first-of-a-kind 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
120 technology with little operating experience.
1 MEMBER MARCH-LEUBA: Yes. My concern is, 2
at this point, we could solve this by requesting the 3
staff in the next subcommittee meeting they address 4
this issue as part of Chapter 10. We don't have to go 5
into Chapter 10, but we can ask them to address it.
6 MEMBER REMPE: I would like that.
7 MEMBER MARCH-LEUBA: In which case, this 8
memo should not be part of the final letter because 9
they already addressed it in April. So if we can 10 rewrite this as a request or keep a (inaudible) that 11 says we have reviewed with the staff the following 12 items, you know, in the April meeting.
13 MEMBER REMPE:
- Well, it says our 14 discussions regarding Chapter 10, however, led to 15 several items we planned, I have now that I request 16 that members explore in reviews of subsequent 17 chapters. I don't know where. It may not get 18 addressed. If it doesn't get addressed, we'll put it 19 in the final letter. But I'm trying to give them 20 opportunities to say, yes, we know this isn't going to 21 be totally done, which I think is an important concept 22 to --
23 MEMBER MARCH-LEUBA: I see a procedural 24 (inaudible).
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121 MEMBER REMPE: (inaudible).
1 MEMBER MARCH-LEUBA: Yes. This is part of 2
our final letter.
3 MEMBER REMPE: It doesn't have to be part 4
of our final letter.
5 MEMBER MARCH-LEUBA: It is. It's going to 6
be in our appendix, right, on this memo?
7 MEMBER REMPE: Yes. But then we need to 8
say during our review we explored this (inaudible).
9 Dave has to put something about this in his letter, 10 either say we explored it and we've come to this 11 realization, which the staff has perfect knowledge and 12 that they don't need more or they need more. I don't 13 know how it should be resolved at this stage.
14 MEMBER MARCH-LEUBA: Well, all they have 15 to come is go directly to the microphone and say I do 16 solemnly swear that this part of Jeff's checklist --
17 MEMBER REMPE: Oh, I'm from Missouri.
18 They're going to have to give me a list to see that 19 it's complete. And I doubt they're going to be able 20 to do that at the end of the construction permit, but, 21 you know --
22 MEMBER MARCH-LEUBA: My impression is we 23 were in a hurry, and we wanted to have a final thing 24 in May.
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122 MEMBER REMPE: Yes, but they've got April 1
and full Committee May.
2 MEMBER MARCH-LEUBA: This is not their 3
final memo. In this form, this cannot be a final 4
memo.
5 MEMBER REMPE: It can be a final memo that 6
was -- I had comments in the last, in the SHINE review 7
that we got addressed in a subsequent meeting, 8
remember, about the instrumentation set points?
9 MEMBER MARCH-LEUBA: I'm just raising my 10 concern that (inaudible).
11 CHAIR PETTI: I don't actually think that, 12 I think we're better off leaving it as a list. I see 13 Matt's hand is up. Matt, Matt, go ahead.
14 MEMBER SUNSERI: Thanks, Dave. So just 15 listening to this discussion, I have not seen and I 16 wonder if it would be a fair request at some point for 17 the operating license or whatever to ask the applicant 18 to provide the strategic objectives and success 19 criteria they are aiming for as a result of the 20 operations of the facility over its life. You know, 21 I mean, they're doing it for some objective, right.
22 What are those objectives, and how will they know they 23 would support that? That could go a long ways in 24 addressing some of these questions, I think.
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123 MEMBER REMPE: I like that idea.
1 CHAIR PETTI: That's clearly an operating 2
license. I mean, I'm sure they're not there today, 3
right?
4 MEMBER REMPE: Yet, they're willing to pay 5
the money to get a construction permit?
6 (Simultaneous speaking.)
7 MEMBER SUNSERI: They probably have some 8
idea of what they're doing, or they wouldn't be going 9
this route, right? They wouldn't be pursuing a small 10 version, and they wouldn't be seeking a construction 11 permit if they didn't have some big picture ideal of, 12 strategically, what they want to accomplish. That's 13 all I'm saying.
14 CHAIR PETTI: Yes. And I think they could 15 write something at a fairly high level, though. The 16 question is the level of detail, I think.
17 MEMBER HALNON: Right. I think the level 18 of technical detail --
19 MEMBER REMPE: Matt, I think that's a 20 great idea, but I'm also wondering our mission is 21 safety and, I mean, I guess, I think they should do 22 it, but is that a safety request?
23 MEMBER SUNSERI: Well, it depends on what 24 their objectives are. I mean, you know, if they're 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
124 going to be, as Greg said, maybe operating the reactor 1
just to demonstrate some proof of principle or 2
something, that might not be. But if they're going to 3
challenge some of the safety limits because they don't 4
know or whatever, that could be.
5 MEMBER BROWN: Can I provide something 6
high level similar to what Matt just --
7 MEMBER REMPE: Sure.
8 MEMBER BROWN: -- went through? I'm 9
trying to figure out what --
10 MEMBER REMPE: Speak closer to your mike.
11 MEMBER BROWN: Sorry about that. I'm 12 trying to figure out what the objective of this review 13 is. This is a construction permit. They've written 14 an SE already, which says something. We are now 15 reviewing in very rapid time comments, you know, six 16 items or whatever the number is today, and there will 17 be more in the next subcommittee meeting. And we're 18 writing a memo. The purpose of the memo is to do 19 what? Are we rubber-stamping their SE? I'm using a 20 somewhat pejorative word. Let me finish my thought 21 process, okay? Putting aside my pejorative comment, 22 which was not meant to be nasty. And I'm taking this 23 from our discussion that we had relative to the decay 24 heat removal system today, relative to the concerns.
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125 But it's going to be addressed at the operating 1
license. Shouldn't our memos reflect at least our 2
concerns and -- we're not going to get any responses 3
to our memos because they're going to go on. So why 4
shouldn't our memos identify what we want to make sure 5
gets addressed at the operating license stage?
6 CHAIR PETTI: We should. So the decay 7
heat removal will come up when Walt's chapter comes 8
up, yes.
9 MEMBER BROWN: Yes, but his memo ought to 10 reflect that and, like mine on Chapter 7, would be to 11 say if the description and the architecture is not 12 complete but just kind of a sketchy thing, they ought 13 to make sure they comply with the fundamentals, et 14 cetera, and here's several items that we've emphasized 15 in past ones and say we'd like to hear about that at 16 the -- so, to me, that's the approach I was going to 17 take on Chapters 7 and 8 and probably look at Chapter 18 6, which is safeguards, as well, even though somebody 19 else is assigned that one. Oh, you got that? If I 20 have any feedback, I'll give it, but that's my 21 thought. And I didn't hear us talking about that in 22 terms of what the objective is for our memos. That's 23 what I was going to be doing.
24 CHAIR PETTI: Just as it was for SHINE.
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126 I think, yes, no, exactly. I mean, I figure if 1
they're important things that we think nothing less 2
than a punch list of items, safety concerns for the 3
OL, our letter is the only way to share that with the 4
staff.
5 MEMBER BROWN: Yes. And then we'll have 6
a more detailed review of individual chapter by 7
chapter, as opposed to this mass attack.
8 CHAIR PETTI: Well, these are all --
9 MEMBER BROWN: No, they're --
10 (Simultaneous speaking.)
11 CHAIR PETTI: Right. They're two-page 12 things --
13 (Simultaneous speaking.)
14 MEMBER BROWN: No, there's four. Even I 15 can read this in four days. The point is I fall 16 asleep halfway through; I'm just joking.
17 CHAIR PETTI: Even the ones in March, 18 there's not that much there.
19 MEMBER BROWN: Mine are like 20 pages long 20 in the PSAR, and there's some figures, and I haven't 21 read the SEs, but I did take a quick look. It's 7 and 22
- 8. I haven't looked at Chapter 6 yet. I've got to 23 really read them now.
24 MEMBER MARCH-LEUBA: It's only functional 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
127 containment on the decay heat.
1 MEMBER BROWN: Is that right? They hit 2
the decay heat --
3 (Simultaneous speaking.)
4 MEMBER BROWN: Okay. Anyway, I'm just 5
trying to make sure that I'm on the right track as to 6
how I write my memo here and that we ought to, I hope 7
that would be a consensus opinion that that's what we 8
ought to be focusing on.
9 MEMBER MARCH-LEUBA: Going back to the 10 problem at hand, if we can rewrite this paragraph to 11 say that at the OL we will expect the staff address 12 these issues because, when you're writing this, I 13 don't know if you want the staff to address these 14 concerns for you before the --
15 (Simultaneous speaking.)
16 MEMBER REMPE: Read the sentence that says 17 these concerns are not related to items that are, I 18 should say required to be resolved prior. I have 19 another typo. Get rid of the second not; I'm sorry, 20 Sandra. Right there. Do you see on the -- after the 21 bullets, there's a not, not required. Okay. These 22 are -- the second not. Not that one. Yes, right 23 there.
24 Okay. These concerns are not related to 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
128 those items that are required to be resolved prior to 1
issuance of the construction permit. Oh, actually, 2
that not was correct. But, anyway, but expect to be 3
resolved prior to operating license. I get that 4
there's some things that are going to be resolved when 5
the operating license is issued because those items 6
are identified by the staff and listed in Appendix A 7
of the staff SE. Rather, I'm talking about 8
uncertainties associated with the first-of-a-kind 9
technology demonstration facility that cannot be 10 resolved until after the facility is operational.
11 Again, it's just things that I think we 12 won't know because we're taking this lighter approach 13 with a small demonstration test facility.
14 MEMBER BROWN: No, but the safety issues 15 that we have to deal with need to be addressed before 16 the facility is operating. If we've got those, we 17 ought to identify --
18 MEMBER REMPE: Because the maximum 19 hypothetical accident doesn't have a large source 20 term, okay, so, yes, maybe they have a small amount of 21 radiation leak that's on the site and all this kind of 22 stuff, but the long-term ability of a new sensor to 23 perform in this corrosive environment with radiation 24 exposure --
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129 MEMBER BROWN: That's a different issue 1
from a safety. That's a shutdown and have to fix it.
2 CHAIR PETTI: That's an operation, it 3
could be an operation --
4 MEMBER BROWN: But if it fails, it' a 5
shutdown and fix it issue. It's not a safety-safety 6
issue because they will shut down if it breaks.
7 MEMBER REMPE: But if it's water level or 8
Flibe level and it's affecting their potential to 9
retain radionuclides, what if it's a reactivity 10 coefficient and they -- again, you can do some startup 11 12 MEMBER BROWN: When you find that out, 13 it's a shutdown and then they recalibrate. That's a 14 different issue, okay?
15 MEMBER REMPE: I'm not trying to get the 16 stuff that is required prior to operating license.
17 I'm trying to think about other things that are beyond 18 that.
19 MEMBER BROWN: Well, I think the key for 20 us is what's the safety issues we have to have 21 resolved before the operating license is granted?
22 What you're talking about are fundamental analytical 23 physics issues of some type or will the instrument 24 last long enough. That's an operating thing we find 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
130 out they're going to break. I mean, those are -- we 1
really ought to focus on what do we need to do for the 2
operating license, get those so we get those resolved.
3 And then, if we think there are what you call the more 4
esoteric issues, throw them in as how are these going 5
to be confirmed, okay, once the facility is operating.
6 Is there a test program, is there things they can take 7
periodically, is there whatever.
8 MEMBER REMPE: Okay. And so, again, I 9
think other people will deal with the things that are 10 documented in Appendix A that are what are needed for 11 the operating license. What I'm talking about is 12 Chapter 10, which is an experimental facility, because 13 some test reactors have irradiation capabilities and 14 you worry about their safe operation. This whole 15 thing is an experiment --
16 MEMBER BROWN: I understand that. But 17 we're mixing apples and oranges in terms of getting 18 the construction permit done and what has to be 19 satisfied to start up the plant as an operating --
20 MEMBER REMPE: And other people will take 21 care of that. I hope so, but I'm only a Chapter 10 22 person.
23 MEMBER BROWN: Well, that's what I tend to 24 look at, you know, for 7 and 8 and safeguards, and 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
131 they got to have some answer for the decay heat 1
removal thing. Do they need an automatic system for 2
that because they've got an upper end and a lower end?
3 Are they going to worry about a guy reading the meter 4
the right way or the glass panel or whatever hell he's 5
got to monitor stuff? To me, that's unsatisfactory.
6 You've got to have something that warns the operators, 7
and I'm going to be looking for that --
8 MEMBER REMPE: And those things are very 9
important and more important, frankly, than what I'm 10 bringing up here. I'm talking about --
11 MEMBER BROWN: That's why we ought to 12 focus on that.
13 MEMBER REMPE: Absolutely. But I only was 14 given Chapter 10.
15 MEMBER BROWN: Yes, I understand that.
16 That's my thought process.
17 CHAIR PETTI: Charlie, we agree with you.
18 MEMBER BROWN: Okay.
19 CHAIR PETTI: The strategy was there were 20 a bunch of chapters that had very little safety 21 significance.
22 MEMBER BROWN: I agree. We ought to get 23 off of Chapter 10 right now.
24 MEMBER REMPE: Absolutely.
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132 CHAIR PETTI: We're going to move beyond 1
those in this meeting and really the real meat starts 2
at --
3 MEMBER BROWN: In March, March 24th and 4
25th.
5 CHAIR PETTI: I thought these wouldn't be 6
a big deal. Of course, I'm wrong.
7 MEMBER BROWN: They're not.
8 MEMBER BALLINGER: So this was the ramp.
9 CHAIR PETTI: Right. This was --
10 MEMBER REMPE: This is the easy-off. I 11 thought, hallelujah, I only have a paragraph.
12 CHAIR PETTI: Okay. I move we can move to 13 the next --
14 (Simultaneous speaking.)
15 MEMBER REMPE: I need to figure out my 16 nots in that one sentence.
17 CHAIR PETTI: Chapter 12, please. Matt, 18 you up there?
19 MEMBER SUNSERI: Yes, I am.
20 CHAIR PETTI: It's yours.
21 MEMBER SUNSERI: So while Sandra is 22 bringing that up, I did look at Chapter 12, and I 23 guess I drew the long stake in the thing. My chapter 24 was several hundred pages long, considering all the 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
133 appendices and everything.
1 And, you know, I just want to make a 2
comment here. I've heard a couple of times either 3
members or maybe even staff refer to it that this gets 4
a lighter touch because it's a test reactor. I don't 5
support those statements. There's fewer things to do, 6
so there's less work overall, but the things that I 7
review I give it the same level of rigor in the 8
technical depth and detail as any other review that I 9
do. So I just want to be on record for that. This is 10 not a light touch for Chapter 12.
11 There were several activities covered in 12 Chapter 12. Conduct of operations. It involved 13 operator
- training, quality assurance
- program, 14 emergency plan, startup. And I apologize; this copy 15 of my memo was not the most up-to-date version. There 16 was also material and accountability control plan as 17 part of this chapter.
18 So my conclusion is, after a thorough 19 review of all these areas of performance, I do not see 20 anything that warrants additional chapter reviews at 21 this time, nor do they affect any crosscutting areas 22 that we would have to look at as far as the 23 construction permit goes. I do have a couple of 24 observations, though, that I would make and offer, so 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
134 if you could maybe put -- yes.
1 When I was looking at the conduct of 2
operations section specifically, I note that the plant 3
manager is assigned overall responsibility for 4
protecting personnel from radiation, from exposure to 5
radiation. However, the radiation protection function 6
and chemistry functions report to the manager of 7
technical services. And although this alignment is 8
satisfactory for the construction phase, I would 9
recommend that consideration should be given to 10 aligning those functions with the plant manager for 11 the operation phase. That's where it's really going 12 to count.
13 The Kairos stated that their operation 14 program will comply with 10 CFR 50.55 or, I'm sorry, 15 10 CFR 55, excuse me, and they will submit that plan 16 with their operating license application. That's 17 fine.
18 Looking over the quality assurance plan, 19 it has all the elements in there. It follows the 20 standard review plan, the guides. It parallels NQA 21 requirements. It parallels Appendix B and CFR 50 22 requirements. It's specific for this design.
23 However, I did note that there's one minor discrepancy 24 they might want to consider addressing in that in the 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
135 Chapter 12 of their PSAR they say that quality 1
assurance, which I think is good because I criticize 2
other organizations for not calling out where quality 3
assurance points out, so they do point out where 4
quality assurance fits in in the big scheme of the 5
operating model, but they have it reporting, and I'll 6
have to read my words here to make sure I get this 7
straight, I think it's Chapter 12 shows they're 8
reporting to the site executive, but, yet, Chapter 2 9
of the quality assurance program says it reports to 10 the -- maybe I have this backwards. Chapter 12 11 reports to the site executive. Chapter 2 through the 12 oh, yes, through the chief executive officer. Okay.
13 So it really doesn't matter. It needs to be 14 independent of production operations, and it is.
15 However, the Chapter 2 of the quality assurance plan, 16 which will be the governing guidance, is that the QA 17 function has access to all levels of management 18 necessary to assure effective execution of the program 19 irrespective of the organization structure, which I 20 agree with that statement. They should just put that 21 footnote in the PSAR, too, for consistency and 22 clarity. Just a nit.
23 On a positive note, they have a very well 24 thought-out emergency plan, and I just would like to 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
136 note, we've had comments on this before, but I would 1
note that it's a positive observation that they have 2
had early engagement with the city of Oak Ridge, Oak 3
Ridge Central Fire Department, the police department, 4
and medical center, county agency, state of Tennessee, 5
and other federal agencies. So we've been critical of 6
some of that in the past, and they're doing a good job 7
of engaging early.
8 Can you scroll further down a little bit, 9
Sandra? These next two areas, Kairos did not provide 10 any information on the material and control 11 accountability program, which is appropriate for this 12 phase. They're not going to be handling any special 13 nuclear material, so that will all be sent in, as they 14 say, during the operation license application.
15 And also Kairos did not present their 16 startup plan in saying that this will be presented as 17 part of the operating license also. And I think some 18 of the comments we just had in the previous Chapter 10 19 memo might carry over to things they want to consider 20 as they develop that startup plan. Anyway, we'll give 21 it a thorough review when it is submitted as part of 22 the operating license.
23 So that's really all I had as far as the 24 review. I'm not recommending any further, as I said 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
137 before, any further changes or discussion. I don't 1
want to take up the Committee's time with any 2
grammatical or typographical errors because there are 3
some in here, so if you have some send them to me.
4 I'll take whatever I get by Friday and I'll write my 5
final memo.
6 That concludes my presentation.
7 CHAIR PETTI: Thank you, Matt. Nice and 8
concise. Any comments, members?
9 MEMBER BALLINGER: Yes. I'd like to make 10 a comment for my time in the barrel over SHINE, and 11 that is what happened was we got the memos and they 12 had what are called recommendations and concerns in 13 them, and interpreted those recommendations and 14 concerns because the last thing that the person 15 usually said was I have no concerns, it's fine. But 16 when it came time to writing the letter, we got in 17 extensive discussions about things that we wanted the 18 letter to require the applicant to do, and that was 19 different than what was said in the memos because the 20 memo
- writer, in some
- cases, interpreted a
21 recommendation as being a requirement.
22 So we need to be very careful, I think, 23 this time around where, when we get to letter writing, 24 we don't end up in an infinite loop where we get 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
138 disagreements about what we would like the person to 1
do versus what we would recommend that they consider, 2
which is a lot different. So I can see that coming.
3 I can see that coming.
4 CHAIR PETTI: Good feedback for members as 5
they write their memos.
6 MEMBER BALLINGER: We're getting SEs with 7
no open items, right?
8 CHAIR PETTI: Right.
9 MEMBER BALLINGER: So that means there 10 shouldn't be any open items. And if we find what 11 amounts to open items, that's a big deal.
12 MEMBER HALNON: And that's to the staff, 13 not the applicant.
14 MEMBER BALLINGER: Yes. I mean, either 15 way --
16 MEMBER HALNON: Well, I mean, I think 17 we've talked about in the past. We don't tell the 18 applicant to do things. We work through the staff for 19 them to assess and, if they say, no, we're not going 20 to have them do it, then, you know --
21 MEMBER BALLINGER: But if we tell the 22 staff we disagree, you should do this, that feeds 23 right back to the --
24 MEMBER HALNON: Right. Just like we said 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
139 it would be good to see it in a corrective action 1
program, and then the applicant put it in the 2
corrective action program and we were happy at that 3
point on some stuff.
4 CHAIR PETTI: Okay. Thank you. Then 5
let's do tech specs. I can't remember. Is that you, 6
Greg?
7 MEMBER HALNON: Yes, it's me.
8 CHAIR PETTI: Chapter 14, Sandra.
9 MEMBER HALNON: Okay. So the tech specs, 10 at this point, obviously, are very nonspecific because 11 of the designs and parameters that you typically see 12 listed in tech specs is not there. But they did pare 13 it back effectively and accurately the requirements in 14 1537 and the ANC document that covers tech specs for 15 test reactors. So the framework is there, and it's 16 solid, so I don't really have any issues with the way 17 they have provided it and didn't have any issues with 18 the way the staff has did their SER from the 19 standpoint that, you know, they basically said the 20 same thing, it meets all the requirements and is a 21 very good springboard to get into the operating 22 license when you start getting the parameters set for 23 what you want to monitor and stay within the 24 envelopes.
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140 The concerns aspect of it is where I was 1
this morning on how do you tie it altogether? Tech 2
specs kind of ties the entire envelope of the plant 3
together at the end, and there's a lot of moving parts 4
right now relative to detailed design parameters 5
you're looking at, the decay heat removal envelope, if 6
you will, temperatures, and things like that. And I 7
started the review on Chapter 9, which is auxiliary 8
- systems, and there's a
tremendous amount of 9
information about how these systems are non-safety 10 related, but, and those buts are pretty extensive, you 11 know. So there's a lot of tentacles that could come 12 back on these auxiliary systems and other safety 13 systems that may be not necessarily specifically 14 covered by the ANC document and others because it's a 15 new technology.
16 So I said that there needs to be an 17 important mapping of some of these support systems and 18 support functional requirements that the tech specs 19 and the safety envelope that you want this plant to 20 stay within to ensure that tech specs is not too 21 narrow and focused just because it's not necessarily 22 a pool reactor or something to that effect, which is 23 really where most test reactors are, you know, 24 university reactors are.
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141 Just for example, functional containment.
1 This is the first time we'll use functional 2
containment, and how do you tech spec functional 3
containment? You've got to do something. You need to 4
have some, is it coolant monitoring, is that how 5
you're going to do it? Is it isotopes? You know, 6
what's too much, what's not enough, and that sort of 7
thing. So there's going to be a lot of, I'm sure, 8
back and forth with the staff and the applicant on 9
what the applicable limits need to be to ensure the 10 containment is adequate. And then how do you test it?
11 Is it through the pebble handling system and, when you 12 offload it, do you measure it? How do you look at the 13 offgas system? How do you measure to make sure the 14 containment is still there?
15 So I make that mention is that this first-16 of-a-kind reactor has to not assume that the past tech 17 specs are going to be all-inclusive of what we may see 18 going forward in this tech spec. So it will be an 19 interesting exercise to get there.
20 Another just an example I put in there was 21 that there's a heavy reliance on natural circulation 22
- cooling, and, you
- know, there's some passive 23 components in that, obviously, and some redundancy.
24 Is that going to be part of, you know, potential 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
142 operability aspect of tech specs? Those types of 1
things need to be carried through, and that's why I 2
said there needs to be a close mapping of all these 3
other systems to make sure that they're not affecting 4
the safety envelope that we're trying to maintain.
5 So there's nothing that we need to do on 6
this, but this is that list of things to look at as 7
we're going forward and thought processes that I was 8
hoping the staff was going to -- it sounds like 9
they're keeping a list and having the same type of 10 discussions internally.
11 Bottom line is that everything is fine for 12 this PSAR. It met all the requirements.
13 MEMBER MARCH-LEUBA: Let me pound once 14 again on my concern. These memos are going to be an 15 appendix to our letter to the commissioners, right?
16 That's the way we handled it before. And the 17 Commission is going to turn to the staff and say what 18 do these guys want us to do, and the staff will say I 19 don't know. I don't know what you want me to do with 20 this memo.
21 CHAIR PETTI: I didn't think we attached 22 the memos. I thought we just referenced them.
23 MEMBER BALLINGER: No, we attached them.
24 CHAIR PETTI: We did attach them?
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143 MEMBER MARCH-LEUBA: So they're really 1
part of the letter. Yes, we tell you don't bother to 2
read in too much detail, this is the important part, 3
but, I mean --
4 MEMBER HALNON: It says I recommend no 5
further actions. That means nothing. It's 6
information to the staff this is what we're thinking 7
about, and they can take it or leave it.
8 MEMBER MARCH-LEUBA: But these are 9
recommendations that the staff should look at during 10 11 MEMBER HALNON: That's --
12 (Simultaneous speaking.)
13 MEMBER MARCH-LEUBA: -- license stage.
14 MEMBER HALNON: Yes, but there's no 15 recommendations.
16 MEMBER MARCH-LEUBA: I'm just saying --
17 MEMBER DIMITRIJEVIC: Well, I have a, I'm 18 stubborn with this on the SHINE, too. We have our 19 concerns, but we have no recommendations. So how can 20 that be?
21 MEMBER HALNON: Concerns is not the right 22 word for that. You know, that's the template. It's 23 not concerns --
24 CHAIR PETTI: Observations?
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144 MEMBER HALNON: It's observations really.
1 MEMBER DIMITRIJEVIC: But you sort of also 2
recommend something to be done in, you know, 3
throughout the --
4 MEMBER HALNON: Or just discussion like we 5
do --
6 CHAIR PETTI: Can we change the template?
7 Just change concerns to observations.
8 MEMBER HALNON: Or just discussion. I 9
would just say discussion.
10 CHAIR PETTI: Or discussion.
11 MEMBER HALNON: Yes, that goes along with 12 our -- well, you letter reports have discussion. Our 13 letter report has discussions, and I think that's 14 probably appropriate because that's all it is at this 15 point.
16 CHAIR PETTI: It's not so much for the 17 Commission. It's for the staff. They've got an 18 internal list; we know that. Oh, well, we didn't have 19 that. Okay, we'll write that down.
20 MEMBER HALNON: But to Ron's point under 21 recommendations, was there anything that I thought 22 they needed to do differently in their SER that's a 23 draft that would translate back into a revision or 24 additions into the -- no, there's nothing.
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145 MEMBER DIMITRIJEVIC: Well, Greg, but 1
don't you want them to put something in the there for 2
the future things, like, you know, things that you 3
just discussed about? You know, that's some things 4
which, you know, like Jose put, there's heavy lines, 5
blah, blah, blah. I mean, don't you want that to be 6
somewhere?
7 MEMBER HALNON: Well, I don't think that 8
-- this is my position on what I think the staff 9
should do. For one, I don't consider myself smarter 10 than the reviewers that are going to be doing this.
11 I have a comment that maybe they didn't think about 12 overtly that, hey, that's a good idea, but I don't 13 think that they're not going to do this. I think that 14 they're going to do it. I think they may not do it 15 in, quote, mapping sense or something to that effect.
16 But when I get to the operating license review of 17 Chapter 14, I'm going to take those core systems and 18 I'm going to walk them through how they affect the 19 safety of the plant and decide whether or not I feel 20 like there should be a tech specs. Am I going to do 21 it comprehensively? No, I'm going to pick and choose 22 very maybe obvious and not so obvious ones and do 23 that.
24 I'm going to make the assumption that 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
146 they're going to do that, and I'm going to go check 1
it. I'm going to verify and validate that they did by 2
sampling. So this is my thought process on why I'm 3
going to do that.
4 MEMBER DIMITRIJEVIC:
That maybe 5
discussion is still not good thing. I was thinking 6
when we were listening in the morning, you know, about 7
this, you know, the reg and how it applies, and we 8
come up with this Appendix A, which contains both 9
commitments from the Kairos NRC expectations and maybe 10 there could be third category there insides from the 11 ACRS review or something like that, you know, 12 something which we identify in our letters, and I can 13 see that we identify those things which will be good 14 to be monitored for in the future, you know. And that 15 will not come this discussion. Maybe the concern 16 wasn't a good name, but maybe that, say, insights or 17 things to be monitored in the future. I don't know 18 how to call it, you know.
19 MEMBER HALNON: Yes. Well, that's kind of 20 descriptive of what it is. I mean, discussion is 21 probably just --
22 MEMBER DIMITRIJEVIC: Very general, you 23 know.
24 MEMBER HALNON: Yes.
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147 MEMBER DIMITRIJEVIC: What is the name of 1
-- does Appendix A has a title?
2 CHAIR PETTI: Well, we don't actually have 3
Appendix A out on SharePoint, so I don't know. These 4
are commitments, the commitments that Kairos has made 5
to the staff on the R&D they will complete prior to 6
the end of construction.
7 MEMBER DIMITRIJEVIC: You know, some 8
concerns also, the policy contain issues to be 9
addressed in the future identified by the staff.
10 MEMBER HALNON: That's on their one-off 11 list that they're talking about that they keep on 12 their SharePoint.
13 CHAIR PETTI: Staff can help you.
14 MEMBER DIMITRIJEVIC: So, basically, we 15 are sort of giving recommendation to that list. I 16 mean, you know --
17 CHAIR PETTI: So I can see us in our 18 letter having information that we think is important 19 that they have in the FSAR or the operating license, 20 and it could be a list. And whether we actually put 21 it in the letter or we make it an appendix, I don't 22 know, but there's a number of things that we're just 23 going to pick up.
24 MEMBER MARCH-LEUBA: All these items 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
148 belong as a recommendation for review and inclusion in 1
the FSAR, their operating license.
2 CHAIR PETTI: Yes, their future --
3 MEMBER MARCH-LEUBA: Future. But they 4
should be tasked as such in the letter so, when I read 5
it, I know what you're talking about.
6 MEMBER HALNON: My impression was that we 7
were looking at the PSAR and trying to render judgment 8
on whether or not the PSAR was adequate --
9 CHAIR PETTI: But we can't help ourself, 10 we skipped over that line.
11 MEMBER HALNON: Right. So that's why I 12 didn't bring it to the recommendation level because I 13 didn't see any missed open items, if you will --
14 CHAIR PETTI: I just worry that it could 15 become an extremely long list when you look at how 16 preliminary so much of it is, and it's fine at this 17 stage.
18 MEMBER HALNON: Right. And even, Joy, 19 your letter, you could have probably expanded that 20 bulletized list, you know, pages long.
21 MEMBER REMPE: Such as.
22 MEMBER HALNON: Right. You know, so what 23 is the most on your mind in general, not in general, 24 but, you know, what do you want to make sure they keep 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
149 in mind and what we're going to keep in mind as we go 1
2 CHAIR PETTI: So let me just ask, I mean, 3
I haven't gone back and read the letter that we wrote, 4
that you wrote, I wasn't part of the Committee, for 5
SHINE construction permit. Did you guys have a list 6
of things that you --
7 MEMBER REMPE: Oh, yes.
8 CHAIR PETTI: -- thought was important?
9 MEMBER REMPE: Yes. And, actually, the 10 Commission meeting, the topic of, you know, what's 11 needed for assurance for moving forward with the 12 construction permit versus an operating license. You 13 know, we got slapped back a little bit about asking 14 for to much. That was my takeaway from that 15 discussion with one of the commissioners that, again, 16 there is this list in Appendix A which I think the 17 staff was going to tell us we were going to get soon 18 and it will be documented.
19 But I have a question for Greg. I mean, 20 today, when I brought up these things, they said, 21 well, the tech specs will help, you know, will be one 22 mechanism, along with the startup plans, to help us.
23 In light of the fact that this is a first-of-a-kind 24 reactor, should the tech specs be more limiting? Do 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
150 you want more monitoring on this facility to make sure 1
it's not going south than you would with an operating 2
plant for a known technology? Do you have any feeling 3
for that yet? Because that's what I'm wondering about 4
because --
5 CHAIR PETTI: I think it all depends on 6
the margins, and there's huge margins.
7 MEMBER BALLINGER: Not got their head in 8
the ground. They're going to say, if there's 9
additional monitoring needed, they're going to say so.
10 MEMBER REMPE: Yes, but I'm asking Greg.
11 I know the staff will do this, but what's your gut 12 feeling? I know the staff will come up with 13 something, but I'm just curious as a person who's 14 running a plant for years and knowing about leaky 15 valves that were allowed to leak and tech spec changes 16 at TMI, too, you know, what do you think? Do you 17 think we should have more for a first-of-a-kind than 18 something that is well known?
19 MEMBER HALNON: Well, so the startup plan 20 will be approved by the staff, and that startup plan 21 will have some of those things in there. There are 22 some one-cycle only, first-cycle only tech specs that 23 we had when we started up the plants for testing, and 24 those eventually went away the next revision of tech 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
151 specs once you satisfy them.
1 So there's some one-time only tech specs 2
that may be in there. I would assume --
3 MEMBER REMPE: And is that included in the 4
PSAR, the acknowledgment that there will be some one-5 time tech specs? I mean --
6 MEMBER HALNON: No, I don't recall them in 7
there, but I think that --
8 MEMBER REMPE: That might be something to 9
add to your memo. It's up to you, but it's something 10 that I think additional attention should be paid to 11 the tech specs.
12 MEMBER HALNON: And a part of that comes 13 back to what we were talking about earlier about what 14 is the intent of having a test reactor. You're not 15 just going to run it for four years and say, okay, 16 everything runs really smooth. What is the intent, 17 and that might come back again to that same question 18 as, all right, if you're going to push the envelope, 19 how much margin are you going to allow them to get to 20 this tech spec limit before you say you've pushed that 21 too far because now you're in my realm of margin, 22 you're not in your realm of margin anymore.
23 So I think that's a very detailed 24 discussion and something that will have to take place 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
152 between the staff and the applicant.
1 MEMBER REMPE: And it would be good for us 2
to know about how that discussion went is what I'm 3
kind of --
4 MEMBER HALNON: Yes, and I would fully 5
expect that to be in the FSAR.
6 MEMBER REMPE: Yes. I think, again, if 7
it's not in the PSAR, if there's something like that 8
that we expect, it would be a good place to mention it 9
10 MEMBER HALNON: I'll go back and look at 11 that with that in mind to see if there was anything in 12 there. I don't recall just off hand --
13 MEMBER REMPE: I looked at the tech spec 14 thing because that was acknowledged in Chapter 10 and 15 the staff's PSAR or their SE, and I went and looked at 16 the tech spec and I surely didn't see anything, and 17 it's something I think might be mentioned.
18 MEMBER HALNON: I'll take a note and go 19 back and look and see if there's something in there 20 about potential one-time only or, you know, special 21 tests type tech specs. I don't know. I just don't 22 remember. If you didn't see it, then --
23 MEMBER REMPE: Well, I didn't, but, again, 24 I did this a couple of weeks before meetings. I had 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
153 other commitments the last week.
1 MEMBER HALNON: Okay.
2 MEMBER SUNSERI: This is Matt.
3 MEMBER BROWN: Oh, I'm sorry, Matt.
4 MEMBER SUNSERI: I just wanted to make a 5
comment on the tech specs. I mean, the tech specs are 6
the activities that the applicant or the operator uses 7
to bound the safety analysis. It's not the, it 8
wouldn't be the place to put things to limit 9
operational issues. It's just, it safeguards the 10 initiating conditions that ensures your safety 11 analysis is valid. So I just think about that.
12 MEMBER HALNON: Yes, I agree, Matt. And 13 that's why we don't have the final safety analysis, 14 obviously, so we don't know what needs to bound it.
15 But I agree we don't want to put operating limits in 16 here, we want to put safety limits with margin. There 17 are other programs that will provide the operating 18 envelopes.
19 MEMBER BROWN: I guess I'm going to ask 20 another question as to this is a construction permit.
21 When I looked briefly at 7, for instance, there's not 22 enough information in there to design the character of 23 the reactor protection and/or safeguard systems, for 24 whatever they are. It's general. There's some block 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
154 diagrams, but they're very block. They talk nothing 1
about the types of systems they would be using, 2
whether it's processors or FPGAs or whether -- they do 3
mention one-way data diode once, but it's off of 4
everything in a big line and you have no idea how 5
combined they are. Is it multiplex or what have you?
6 So that chapter is, if they're going to use this 7
chapter to build the reactor safety
- systems, 8
protection system, it's not adequate.
9 So when we did NuScale, I had a complete 10 11 CHAIR PETTI: Yes, but be careful.
12 NuScale was one step.
13 MEMBER BROWN: I understand that. We had 14 a single memo, but all I'm saying is the systems were 15 defined as to how they were going to design them. If 16 construction project, does this mean they can now go 17 build everything? If that's the purpose of this 18 construction process, that PSAR is not satisfactory 19 for neither Chapter 6, Chapter 7 or Chapter 8. I 20 haven't looked at 6 yet.
21 CHAIR PETTI: No, because that's not the 22 way to think about the construction permit. They 23 talked about it in this morning that it's about how 24 their design criteria and does the design address the 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
155 criteria at a conceptual level.
1 MEMBER BROWN: Is there going to be an 2
FSAR?
3 CHAIR PETTI: Of course.
4 MEMBER BROWN: Will we review that before 5
6 CHAIR PETTI: Absolutely.
7 MEMBER BROWN: -- the plant, before any 8
construction starts?
9 CHAIR PETTI: No.
10 MEMBER BROWN: Before the systems are 11 built?
12 MEMBER BALLINGER: Like we did SHINE.
13 Construction permit, operating permit.
14 MEMBER BROWN: I had a lot of detail on 15 SHINE.
16 MEMBER BALLINGER: When?
17 MEMBER MARCH-LEUBA: On the operating 18 license.
19 MEMBER BALLINGER: The operating license.
20 MEMBER BROWN: All I want to make sure is 21 when I come through and review it for the operating 22 license and they say, hey, we've already designed the 23 stuff, I'm going to just write a letter that says, 24 propose that it's unsatisfactory and doesn't --
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
156 MEMBER MARCH-LEUBA: That's correct.
1 MEMBER BROWN:
meet all the 2
requirements.
3 MEMBER MARCH-LEUBA: They design it at 4
their own risk. The NRC just has to give them a 5
license because it satisfies the requirement or not.
6 But the designer, the applicant designs everything at 7
their own risk. It has never happened that the NRC 8
has rejected it, but that's the process.
9 MEMBER BROWN: If that's the point, then 10 my comment on my memo is going to be fairly explicit 11 relative to it's not satisfactory for designing --
12 MEMBER MARCH-LEUBA: I think that we 13 should have a section here that says recommendations 14 for review of the operating license, write in the way 15 you want to because this is what you're writing here 16 is for construction it's okay but, from now on, the 17 staff needs to consider the following items.
18 MEMBER BROWN: For instance, defense-in-19 depth is how do you use computers in some of these 20 systems. That was covered in the other items we've 21 done. It was done, you know, suitably. And NuScale, 22 I mean, excuse me, SHINE was not, I mean, I accepted 23 less than what I would have seen for NuScale.
24 CHAIR PETTI: But, again, NuScale was a 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
157 one-step licensing.
1 MEMBER BROWN: So was AP1000, so was --
2 CHAIR PETTI: Right. So they were at the 3
FSAR stage.
4 MEMBER BROWN: I understand that. But so 5
I knew what they were hidden, but in SHINE there was 6
enough information in there so that I knew, I could 7
tell that defense-in-depth was going to be okay, they 8
knew they had processors and they knew they needed, 9
they were keeping everybody out, no connecting to the 10 internet. It was really clear.
11 MEMBER BALLINGER: But that was at the 12 operating license.
13 MEMBER MARCH-LEUBA: Yes. And when we 14 were reviewing Chapter 7 for SHINE, we walked inside 15 a containment and (inaudible) so where the control 16 room is going to be --
17 MEMBER BROWN: All right. I'll quit. All 18 I'm saying is I just, I just want to make sure the 19 architecture requirements and other types of stuff in 20 the reg guides that define how they get used --
21 MEMBER MARCH-LEUBA: This is the point.
22 We can make a recommendation about how that process 23 happens.
24 MEMBER BROWN: Okay.
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
158 (Simultaneous speaking.).
1 MEMBER HALNON: Yes. So I approached my 2
reviews with this is what they're going to do and 3
then, when we get to the operating license, the FSAR, 4
it's the what and the how.
5 CHAIR PETTI: And the how. That's a good 6
way to think about it.
7 MEMBER HALNON: And so if the what is 8
adequate, they're meeting the right codes, they've got 9
the right things, they say they're going to use 10 analytical issues, they're going to use test data for 11 this, the system is going to be able to take the 12 gasses and they're going to be able to scrub them, and 13 blah, blah, blah, blah, blah, you know, that's looking 14 at it almost like a system description as opposed to 15 a system design. There will be a design, and that 16 design will be summarized in the FSAR.
17 MEMBER BROWN: As long as I'm getting an 18 FSAR.
19 MEMBER MARCH-LEUBA: You will in a couple 20 of years.
21 MEMBER BROWN: Okay. Or whoever is met at 22 that time.
23 MEMBER MARCH-LEUBA: Maybe we can raise 24 these things as recommendations for ACRS review of 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
159 operating license. Fair warning: ACRS will look at 1
these items when you send us an operating license to 2
review. This is what we're going to look. You decide 3
whether you want to risk it or not; that's your job to 4
do it. But this is what we will look at.
5 MEMBER REMPE: Maybe give us a template.
6 Some of us may think we might get some additional 7
information as the review progresses in some of these 8
cases, so I, you know --
9 MEMBER MARCH-LEUBA: You want to finish the 10 thing by May. You're not going to get anything else.
11 MEMBER REMPE: When you're the first one 12 out of the gate, I would hope I get something else.
13 We didn't even see Appendix A and, you know, it's like 14 it's a big guess right now.
15 MEMBER BROWN: I don't remember that. I 16 don't think they did. I don't remember.
17 MEMBER BALLINGER: Somebody did.
18 MEMBER BIER: I like Jose's comment of the, 19 you know, these are notes to ourselves in the future 20 and, therefore, also notes to staff and licensee that, 21 you know, we don't want anybody to forget that 22 somebody is going to be looking at these things.
23 MEMBER HALNON: So back to Vesna's, it's 24 more insights from our review, which maybe that's the 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
160 right --
1 MEMBER MARCH-LEUBA: Our own Appendix A, 2
if you want to call it that way.
3 MEMBER DIMITRIJEVIC: Well, I was thinking 4
maybe we should say the name of this to be considered 5
in the future or consideration or something when we 6
just put discussion now.
7 MEMBER HALNON: That's true that many of 8
us, some of us won't even be here for the operating 9
license review, and that's the same thing with the 10 staff. So they're keeping their list of lessons and 11 insights, and that's the same thing that we're kind of 12 doing with these.
13 CHAIR PETTI: I think we understand the 14 comments. We need to break because we've got a P&P 15 subcommittee. So let's take a break, and we will be 16 back at 1:00.
17 (Whereupon, the above-entitled matter went 18 off the record at 11:50 a.m. and then went back on the 19 record at 1:01 p.m.)
20 CHAIR PETTI: Okay. So we officially 21 close the meeting, and we're going to continue working 22 on our memos.
23 (Whereupon, the above-entitled matter went 24 off the record at 1:01 p.m.)
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
By the Division of Advanced Reactors and Non-Power Production and Utilization Facilities, Office of Nuclear Reactor Regulation NRC STAFF REVIEW STRATEGY FOR THE SAFETY REVIEW OF THE KAIROS HERMES TESTING FACILITY CONSTRUCTION PERMIT APPLICATION Briefing for the Advisory Committee on Reactor Safeguards Wednesday, March 1, 2023
=
Background===
Test reactor - different licensing requirements than a commercial power reactor Construction Permit application - preliminary design.
The NRC staff performed an appropriate level of review, focusing on matters that are most safety significant, and the scope of the review was commensurate with the risk posed by the design.
Unswerving focus on adequate protection of public health and protecting the environment.
2
Testing Facility Licensing Kairos expects to apply for a Class 104c license for a utilization facility useful in the conduct of research and development activities. Accordingly, the staff conducted the CP review consistent with Section 104c of the Act.
Many 10 CFR Part 50 requirements are for power reactors and do not apply to testing facilities.
Testing facilities are subject to the requirements of 10 CFR Part 100, Reactor Site Criteria.
Testing facilities are subject to a few 10 CFR Part 50 requirements that do not apply to research reactors, including Advisory Committee on Reactor Safeguards (ACRS) review, and mandatory hearings for CP applications (10 CFR 50.58).
3
Construction Permits The level of detail needed in a CP application and associated NRC staff SER are different than for an OL (or combined operating license)
The CP application describes the preliminary design of the facility, while an OL application should describe the final design of the facility, as well as plans and programs not provided in the CP application The staff must make the following findings to issue a CP, based on 10 CFR 50.35:
Facility has been described, including the principal architectural and engineering criteria for the design Further technical or design information may be reasonably left for later consideration in the final safety analysis report (i.e., OL application)
Safety features or components requiring research and development have been identified Safety questions will be resolved prior to the completion of construction and the proposed facility can be constructed without undue risk to the health and safety of the public Staffs conclusions are also based on the considerations in 10 CFR 50.40 and 50.50 4
Risk-Informed Review For its CP application review, the depth and scope of staffs review was commensurate with the risk or safety significance of items under review The staff maintained a big picture safety perspective of the Hermes design. The scope and level of detail of the review considered the small size of Hermes and the anticipated strong safety case with low radiological consequences, and as appropriate for a testing facility CP application.
The staffs review is also tailored to the unique and novel technology described in the CP application, using the appropriate regulatory guidance in NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors. Other guidance (e.g., regulatory guides and industry standards) and engineering judgement are also used, as appropriate.
5
NUREG-1537 Review Areas/Chapters
- 1. The Facility/Introduction
- 2. Site Characteristics
- 3. Design of Structures, Systems, and Components
- 4. Facility Description
- 5. Coolant Systems
- 6. Engineered Safety Features
- 7. Instrumentation and Control
- 8. Electrical Power Systems
- 9. Auxiliary Systems 10.Experimental Facilities 11.Radiation Protection and Waste Management 6
12.Conduct of Operations Emergency Planning Physical Security Operator Licensing Startup Plan Human Factors Quality Assurance 13.Accident Analysis 14.Technical Specifications 15.Financial Qualifications 16.Other License Considerations 17.Decommissioning 18.Uranium Conversions 19.Environmental Review (Note that some NUREG-1537 chapters are not applicable to the Hermes CP application)
Hermes Review Examples Staff conducted audits of:
Site characteristics (~ 30 questions)
Nuclear design and accident analysis (over 100 questions)
Decay heat removal system (16 questions)
Instrumentation and Controls (16 questions)
General (reactor fuel, reactor coolant system, electrical power, chemistry control, inert gas system, radiation protection, emergency planning, financial qualifications and other topics) (~130 questions)
Example of DHRS review Example of methodologies and evaluation models 7
Overview of DHRS Review The DHRS is safety-significant for maintaining the vessel temperature within acceptable limits for SS-316 DHRS is placed in service above a threshold power where passive radiative cooling only is not adequate During this transition phase water is introduced to the guide tube and evaporator Staff reviewed the preliminary system design to identify potential system failure modes Staff audited the Kairos DHRS heat performance calculation which determined the level of system performance necessary to maintain the vessel below the SS-316 limit The staff preformed independent calculations to ensure water tank volumes where sufficient for 7 days of cooling Staff ensured testing plans addressed the potential flow and heat removal instabilities issues during the transition and in-service phases including the affects of potential failure modes 8
Overview of DHRS (cont.)
Staff ensured testing plans addressed the potential dynamic loads on the structure and components due to transition phase thermal shock and in-service evaporator boiling Staff ensured testing plans addressed the potential for corrosion and fouling in the evaporator tube affecting structural integrity and the ability to remove heat The staff noted the DHRS design must accommodate the highest heat loads for vessel integrity and the lowest in-service heat loads to prevent freezing without operator action within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Final determination on the adequacy of the DHRS to meet these competing design requirements will be made based on the final design presented in the FSAR Staff concluded that the preliminary design is consistent with the associated PDCs 9
Overview of Methodologies and Evaluation Models Staff review of the methodologies included:
Consideration of important phenomena Range of conditions evaluated Consideration of uncertainties Identifying methodology/model conservatisms Margin to acceptance limits Codes used for the CP evaluation have not been validated Staff performed a detailed review of the MHA and underlying supporting calculations within the limits of the preliminary design information 10
Overview of Methodologies and Evaluation Models (cont.)
Staff used various means to assess evaluation models to reach a reasonable assurance finding. Examples include:
The correlations or models used in the Kairos codes are used in established codes or evaluation models Review of journal articles which perform similar analysis or describe the use of similar modeling approaches for related applications Integral test results Scoping calculations to better inform engineering judgement Engineering judgement Staff plans for OL review will include:
Review software quality assurance program or implementation Review code nodalization Review code inputs Review assumed material property inputs Exercise the applicants code or perform confirmatory analysis Justification of models may be provided by test results, code verification and validation, or other method before or during the Operating License review 11
NRC Staff Contacts NRC Safety project managers for Kairos Hermes CP review:
Benjamin Beasley, Senior Project Manager, Advanced Reactor Licensing Branch 1 (301) 415-2062, Benjamin.Beasley@nrc.gov Samuel Cuadrado, Project Manager, Advanced Reactor Licensing Branch 1 (301) 415-2946, Samuel.CuadradoDeJesus@nrc.gov Edward Helvenston, Project Manager, Non-Power Production and Utilization Facility Licensing Branch (301) 415-4067, Edward.Helvenston@nrc.gov Matthew Hiser, Senior Project Manager, Advanced Reactor Licensing Branch 1 (301) 415-2454, Matthew.Hiser@nrc.gov 12