ML24017A222
| ML24017A222 | |
| Person / Time | |
|---|---|
| Issue date: | 12/06/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2654 | |
| Download: ML24017A222 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards 711th Full Committee Meeting Docket Number: (n/a)
Location: teleconference Date: Wednesday, December 6, 2023 Work Order No.: NRC-2654 Pages 1-175 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 711TH MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +
8 OPEN SESSION 9 + + + + +
10 WEDNESDAY 11 DECEMBER 6, 2023 12 + + + + +
13 The Advisory Committee met via hybrid In-14 Person and Video-Teleconference, at 8:30 a.m. EST, Joy 15 L. Rempe, Chairman, presiding.
16 17 COMMITTEE MEMBERS:
18 JOY L. REMPE, Chairman 19 WALTER L. KIRCHNER, Vice Chairman 20 DAVID A. PETTI, Member-at-Large*
21 RONALD BALLINGER, Member*
22 CHARLES H. BROWN, JR., Member 23 VICKI M. BIER, Member 24 VESNA B. DIMITRIJEVIC, Member*
25 GREGORY H. HANLON, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1 JOSE MARCH-LEUBA, Member 2 ROBERT P. MARTIN, Member*
3 THOMAS E. ROBERTS, Member 4 MATTHEW W. SUNSERI, Member*
5 6 ACRS CONSULTANT:
7 DENNIS BLEY 8 STEPHEN SCHULTZ 9
10 DESIGNATED FEDERAL OFFICIAL:
11 DEREK WIDMAYER 12 13 ALSO PRESENT:
14 HAROLD ADKINS, PNNL 15 GARILL COLES, PNNL 16 AMY CUBBAGE, NRR*
17 ROBERT ELLIOTT, NRR 18 ANDERS GILBERTSON, NRR 19 SHANA HELTON, NMSS 20 STEVEN LYNCH, NRR 21 STEVE MAHERAS, PNNL 22 JONATHAN MARCANO, NMSS 23 TIM McCARTIN, NMSS 24 WILLIAM RECKLEY, NRR*
25 JOSEPH SEBROSKY, NRR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 1 JESSE SEYMOUR, NRR*
2 JEFF WAKSMAN, DoD 3 BERNIE WHITE, NMSS 4
5
- present via video-teleconference 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
4 1 P-R-O-C-E-E-D-I-N-G-S 2 (8:30 a.m.)
3 CHAIR REMPE: So good morning. This 4 meeting will now come to order. This is the first day 5 of the 711th meeting of the Advisory Committee on 6 Reactor Safeguards.
7 I'm Joy Rempe, Chairman of the ACRS.
8 Other members in attendance are Ron Ballinger and 9 Vicki Bier. Charles Brown will be here shortly. He 10 appears to be held up in traffic.
11 Vesna Dimitrijevic, Greg Halnon, Walt 12 Kirchner, Jose March-Leuba, Bob Martin, Dave Petti, 13 Tom Roberts, and Matt Sunseri. We do have a quorum 14 today and the committee is meeting in-person and 15 virtually.
16 The ACRS was established by the Atomic 17 Energy Act and is governed by the Federal Advisory 18 Committee Act. The ACRS section of the USNRC public 19 website provides information about the history of this 20 committee and documents such as our charter, bylaws, 21 federal register notices for meetings, letter reports, 22 and transcripts of all full and subcommittee open 23 meetings, including all slides presented at such 24 meetings.
25 The Committee provides its advice on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 1 safety matters to the Commission throughout its 2 publicly available letter reports. The federal 3 register notice announcing this meeting was published 4 on November 13th, 2023.
5 This announcement provided a meeting 6 agenda as well as instructions for interested parties 7 to submit written documents and request opportunities 8 to address the Committee. The designated federal 9 officer for today's meeting is Mr. Derek Widmayer.
10 The communications channel has been opened 11 to allow members of the public to monitor the open 12 portions of the meeting. The ACRS does invite members 13 of the public to use the MS Teams link to view slides 14 and other discussion materials during these open 15 sessions.
16 The MS Teams link information was placed 17 in the federal register notice and agenda on the ACRS 18 public website. We have not received any written 19 comments or requests to make oral statements from 20 members of the public regarding today's sessions.
21 However, periodically the meeting will be 22 open to accept comments from participants listening to 23 our meetings. Written comments may be forwarded to 24 Mr. Derek Widmayer, today's federal -- today's 25 designated federal officer.
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6 1 During today's meeting, the committee will 2 consider the following topics: Technology Inclusive 3 Content of Application Project, Advanced Reactor 4 Content of Application Project, TICAP/ARCAP guidance, 5 and transportation framework for microreactors. A 6 transcript of open portions of the meeting is being 7 kept, and it's requested the speakers identify 8 themselves and speak with sufficient clarity and 9 volume so they can be readily heard.
10 Additionally, participants should mute 11 themselves when not speaking. Do any of my colleagues 12 have any comments? Oh, somebody does.
13 VICE CHAIR KIRCHNER: Yes, Madam Chair.
14 We would be remiss to not recognize an important 15 transition, and so on behalf of the Committee I would 16 just like to note that as Dr. Rempe completes her 17 second term as Chair of the Committee, we want to all 18 acknowledge your dedication and efforts for the 19 Committee and service, and a very distinguished career 20 to go along with it.
21 So on behalf of the Committee, thank you.
22 And I also would be remiss if I didn't remind you that 23 you're still chair until midnight, 12:31.
24 CHAIR REMPE: To sign those last letters.
25 VICE CHAIR KIRCHNER: Thank you for your NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 1 service.
2 CHAIR REMPE: Thank you, Vice Chair. It's 3 been an honor to serve. If there aren't any other 4 comments, then, I'd like to ask Dave Petti to lead us 5 through our first topic of today's meeting. Dave?
6 MEMBER PETTI: Hey. Good morning, 7 everyone. Before we get into the details, is anybody 8 -- Joe, anybody from, you know, management want to 9 make a statement?
10 MR. LYNCH: Yes. This is Steven Lynch, 11 the chief of the advanced reactor policy branch.
12 Thank you all for meeting with us today. The NRC 13 staff is dedicated to the development of guidance to 14 support the effective licensing of non-light water 15 reactors.
16 Today we are going to share with the 17 members our work related to the preparation of the 18 Technology-Inclusive Content of Application Project, 19 or TICAP, and Advanced Reactor Content of Application 20 Project, or ARCAP guidance.
21 The purpose of these guidance documents is 22 to provide technology-inclusive, risk-informed, and 23 performance-based application guidance for non-light 24 water reactor application, with an emphasis on 25 portions of the safety analysis report derived using 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 1 the Licensing Modernization Project, or LMP process to 2 identify licensing basis events, classify and 3 establish performance criteria for structures, 4 systems, and components, and evaluate defense in-5 depth.
6 These documents represent the culmination 7 of years of work supported by NRC staff experts in 8 licensing, policy, and technical disciplines, and have 9 benefitted from feedback provided by the ACRS and 10 various subcommittee meetings, and formal comments 11 provided by stakeholders.
12 We look forward to engaging with the 13 members on these important documents today. I will 14 now turn the presentation over to our staff, leading 15 off with our primary lead for this effort, Joe 16 Sebrosky.
17 MR. SEBROSKY: Good morning. My name's 18 Joe SEBROSKY. I'm a senior project manager in the 19 Advanced Reactor Policy Branch, and as Steve noted on 20 slide 2, as Steve noted, the purpose of this meeting 21 is to provide a high-level overview of TICAP, 22 specifically Regulatory Guide 1.253 and the nine ARCAP 23 interim staff guidance documents.
24 So as far as the agenda goes, we'll 25 provide a high-level overview of the ARCAP and TICAP NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 1 structure, a discussion of the Licensing Modernization 2 Project, providing additional background on LMP based 3 on questions that were raised during the subcommittee 4 meetings on this topic.
5 And then we'll get into a discussion of 6 Regulatory Guide 1.253, and then just a high-level 7 overview of the nine ARCAP ISGs.
8 VICE CHAIR KIRCHNER: Could you move your 9 microphone closer to the --
10 MR. SEBROSKY: Is it any better? On Slide 11 3, what I'm showing -- it's kind of a busy slide, but 12 this is a listing of the 10 documents that we're going 13 to be discussing today, and if you look at the bottom, 14 you'll see draft reg guide 1404, rev 0, and you'll 15 also see draft reg guide 1404 rev 1.
16 What we did is we went out with two 17 separate comment periods for draft -- reg guide 1404, 18 which is the basis for reg guide 1.253. Rev 1 was 19 issued to provide additional guidance related to 20 probabilistic risk assessment at the construction 21 permit stage, and my colleague Anders Gilbertson is 22 going to be discussing what was in revision 1 in that 23 area.
24 And if you look at the bullets up at the 25 top, we issued nine draft ISGs in rev 0 of the reg NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 1 guide -- draft reg guide in May of 2023. And then we 2 issued rev 1 in September of 2023.
3 All of the documents that are in this 4 table are -- appear on our public web page, and 5 there's a link on this slide to that public web page.
6 If you go to table 2, that web page -- you'll find a 7 link to all of these documents.
8 You also see you have succession number 9 links for these documents, and then the 10 regulations.gov doc it IDs. All the way over on the 11 right column, you'll see the number of comments that 12 we received on the various documents, and it's -- I 13 like to point out that the most comments that we 14 received are on the draft regulatory guide.
15 We received 73 comments on rev 0 and then 16 30 comments on rev 1. The second document that 17 received the most comments were the ARCAP -- was the 18 ARCAP Roadmap ISG. That's to be expected. Those two 19 documents are the two most important documents that we 20 issue for public comment.
21 On slide 4, the purpose of this slide is 22 just to let the ACRS know and the stakeholders know 23 that we made 20 documents available a month prior to 24 the ACRS subcommittee meeting to support the 25 interactions with the ACRS. And if you open up the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 1 link on this page, you're going to find the 20 2 documents.
3 There's 10 documents associated with the 4 various guidance documents, and then there's also 10 5 comment resolution tables. And when you look at the 6 guidance documents themselves, you'll see ID numbers 7 associated with the changes that we made as a result 8 of the comments.
9 And you can go back to the comment 10 resolution table, and you'll see the comment and the 11 comment response that led to the change in the 12 document. And as I indicated earlier, the ARCAP/TICAP 13 public web page provides links to key meetings and 14 documents associated with the development of these 10 15 guidance documents.
16 So the next couple slides, just providing 17 a high-level background on what ARCAP and TICAP is all 18 about. The guidance we're developing, as Steve Lynch, 19 my boss, indicated, are guidances for developing and 20 reviewing technology-inclusive, risk-informed, and 21 performance-based guidance for non-light water reactor 22 applications. It's limited to non-light water reactor 23 applications at this time.
24 It's also limited to 10 CFR Part 50 and 52 25 applications. And we prioritize the development of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 1 this guidance based on the near-term prospects for 2 non-LWR applicants that tend to use the LMP process.
3 We do intend down the road to revise the guidance to 4 support Part 53 rulemaking language based on the 5 commission decision and direction on Part 53.
6 On Slide 6 -- so ARCAP is broad in nature.
7 It's intended to cover guidance for non-LWR 8 applications. Here's a listing of the different 9 applications. So you see for Part 50, you have 10 construction permits and operating licenses.
11 It's intended to support that, and under 12 Part 52 it's intended to support combined licenses, 13 design certifications, standard design approvals, and 14 manufacturing licenses.
15 You do see an asterisk on standard design 16 approvals and manufacturing licenses. At this time, 17 reg guide 1.253 does not currently address 18 manufacturing licenses and standard design approvals.
19 If an applicant -- if a manufacturing 20 license or a CA applicant chooses to use the LMP 21 process, they're encouraged to discuss their plans 22 with the NRC during the pre-application phase. The 23 ARCAP ISGs, however, do include standard design 24 approval and manufacturing licenses.
25 MEMBER HALNON: Hey, Joe, in many places NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 1 throughout this, we talk about, if you want to do some 2 -- just something different. We encourage the 3 applicant to talk pre-application, which -- it's a lot 4 more importance in that, obviously, because of the 5 potential impact to the strategy that they're going to 6 try to employ to get an application.
7 When you say that, are you encouraging it 8 because you say there is a pathway that you already 9 envision that could be done, or that you're just --
10 bring me a rock and we'll let you know if it's okay?
11 MR. SEBROWSKY: I think it's the former.
12 We believe there is a pathway, and it's just a matter 13 of -- the encouragement is to prevent surprises.
14 MEMBER HALNON: Okay. So when we hear 15 that, we -- at least, we are encouraged that there is 16 a pathway and that we're not just saying, you know, 17 let's discuss it because 50-50 chance of getting it.
18 You think they're -- you'll be able to work with the 19 applicant to come through with some reasonable 20 regulatory pathway?
21 MR. SEBROWSKY: Yeah. In the specific 22 case of manufacturing licenses and standard design 23 approvals, we believe the guidance that is provided in 24 reg guide 1.253 and you've got 2107 when it comes to 25 certs, is generally going to be applicable. I think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 1 the committee's been briefed on the manufacturing 2 license SECY paper that's going to be going forward.
3 And there's a lot of options for manufacturing 4 licenses.
5 So it's -- that was one of the comments we 6 received, was add additional guidance for 7 manufacturing licenses, and it became somewhat 8 burdensome to figure out how you would do that, given 9 some of the things that are being considered in that 10 SECY paper.
11 MEMBER HANLON: Okay.
12 CHAIR REMPE: I have a question about 13 SDAs. I recall in recent times, the SDA has been 14 given something that's gone through a certification 15 for designs, and it's kind of, oh, let's do this too 16 since we've got all the material.
17 Now we're reaching a situation where some 18 folks are going to do SDAs for things that aren't 19 certified design, and can they get away with a lot 20 less material and just say, oh, we're going to leave 21 after the COL? Is there some minimum threshold that 22 they've got to provide?
23 MR. SEBROWSKY: Yes. So I'll try to 24 answer that question. Bill Reckley, I believe you're 25 on the line, so -- and I believe Amy Cubbage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 1 (phonetic) is also on the line, so they can help if I 2 mischaracterize it.
3 So the difference between and SDA and the 4 design cert at a high level from my perspective is an 5 applicant under a standard design approval is allowed 6 to say, here are the areas for which we're looking for 7 our standard design approval. They can limit the 8 amount of material that they're looking for approval.
9 You don't have that same option with the 10 design cert. The design cert is based on final FSAR-11 type level information, and you are allowed things 12 like operational programs that clearly fall outside of 13 a design cert, wouldn't be the responsibility of an 14 applicant.
15 When you look at the design certification, 16 you see things like COL action items that essentially 17 say, okay. This radiation protection program is 18 something that's outside the scope and is going to be 19 expected to be addressed as part of the COL. So --
20 CHAIR REMPE: Can they go to extremes and 21 say, well, we only want to do the -- I don't know, the 22 ECCS. We're not going to do, I don't know, a lot of 23 other major aspects of the design. It just seems like 24 -- is there a critical set of material that they've 25 got to cover? Or are you -- some that you don't --
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16 1 MR. SEBROWSKY: I don't know. I just know 2 that there is --
3 MS. CUBBAGE: Joe --
4 MR. SEBROWSKY: You don't --
5 MS. CUBBAGE: Joe, could I?
6 MR. SEBROWSKY: Yeah. Go ahead, Amy.
7 MS. CUBBAGE: Yeah. Hi, Amy Cubbage, NRC 8 staff, just to kind of add to what Joe is saying. So 9 in best practice, all of the -- it used to be called 10 final design approvals, now it's standard design 11 approvals -- were for the full scope as you mentioned, 12 Dr. Rempe. It was kind of in concert with a design 13 cert. It was an extra step. It used to be a 14 mandatory step prior to design certification was to 15 get the final design approval.
16 But the rules do allow for a standard 17 design approval of a complete design, or major 18 portions thereof. So the idea of what a major portion 19 is somewhat up for discussion.
20 However, you know, anything that is not 21 resolved would be the responsibility of the COL 22 applicant. And even with the standard design 23 approval, there is -- since there's no rulemaking or 24 hearing, the whole standard design approval would be 25 up for hearing opportunity for the combined license NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 1 applicant. Did you have any more specific question on 2 that, Dr. Rempe?
3 CHAIR REMPE: No. You've answered my 4 question. It's a fuzzy area of what a major portion 5 thereof is --
6 MS. CUBBAGE: Yeah, and --
7 CHAIR REMPE: That's communicated well to 8 applicants as well as the popular press, and what is 9 coming down the pike. And this is beyond the scope of 10 this meeting. I realize it. But I saw --
11 MS. CUBBAGE: The one thing I could offer 12 is that for the portions of the design that the SDA 13 applicant is not providing, they would be required to 14 provide interface requirements and conceptual design 15 that would help us to be able to assess the portion of 16 the design that they are seeking staff-level approval 17 of.
18 CHAIR REMPE: I think it may come up to be 19 a problem in the future, but we'll see.
20 MS. CUBBAGE: Yeah. In practice, if it's 21 the scenario you suggested, like maybe it's just the 22 ECCS or just some analytical tools, the applicant 23 would probably be better served using the topical 24 report process.
25 CHAIR REMPE: Thank you. Go ahead.
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18 1 MR. SEBROWSKY: Thanks, Amy. So 2 continuing on with the slide, the last bullet down at 3 the bottom, the point that we were trying to make is 4 ARCAP encompasses TICAP. TICAP is guidance for off-5 normal reactor states only. It's based on the 6 licensing modernization project. But ARCAP 7 encompasses both TICAP and everything else that's 8 needed for a license application.
9 MEMBER BROWN: What's off-normal mean?
10 Maybe I forgot.
11 MR. SEBROWSKY: So when you look at -- as 12 Steve Lynch mentioned, one of the things that the LMP, 13 the licensing modernization project, does it is 14 identifies the licensing basis events, and the SSC 15 categorization. So by definition, you're looking at 16 design basis and accident-type things which you would 17 not expect.
18 MEMBER BROWN: That's what you mean by 19 off-normal?
20 MR. SEBROWSKY: Yes.
21 MEMBER BROWN: Fundamentally beyond design 22 bases?
23 MR. SEBROWSKY: No. So there's design 24 basis accident --
25 MEMBER BROWN: Right.
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19 1 MR. SEBROWSKY: And we'll be getting to 2 this in a little bit.
3 MEMBER BROWN: Oh, okay.
4 MR. SEBROWSKY: Yeah, not a normal --
5 MEMBER BROWN: Yeah, that's what I'm 6 trying to get --
7 MR. SEBROWSKY: So, for example, LMP -- we 8 have a chapter 9 on normal effluence. We have an ISG, 9 ARCAP ISG, on Chapter 9 for normal effluence. The LMP 10 process doesn't look at that. What Chapter 9 does is 11 it provides guidance to ensure that we have sufficient 12 information in the application to ensure that normal 13 effluence, you'll meet the end of the line 14 requirements if that's the (8:51:57 phonetic) RR 20.
15 MEMBER BROWN: Okay, thanks.
16 MR. SEBROWSKY: So on slide 7, as I just 17 stated, the TICAP scope is governed by the LMP 18 process, and I mentioned a couple times that the LMP 19 process is used just like the licensing basis events, 20 develop SSC, structured systems and component 21 categorizations to ensure defense and depth is 22 considered.
23 Industry developed the key portions of the 24 TICAP guidance, and you find that in NEI 2107. The 25 second bullet gives you the link for that document, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 1 and reg guide 1.253, which was issued as DG 1404, 2 proposed to endorse NEI 2107 revision 1 with 3 clarifications and additions.
4 There's a sub-bullet here that at this 5 time there's no proposed exceptions in the reg guide.
6 There's only clarifications and additions. The next 7 four slides -- and I'll be looking to Bill Reckley, 8 who's on the team, to go over these slides.
9 These are new slides from what we 10 presented in the ACRS meeting, and the reason we're 11 providing this background is there were some questions 12 that were asked. How the full scope here is 13 developed, and also a question about how chemical 14 effects are considered, and also the difference 15 between a fundamental safety function and a required 16 safety function.
17 So the first two slides out of four just 18 give the background on the LMP, some of the key 19 guidance documents, NEI 1804 rev 1. There's a link to 20 that document. Reg guide 1.233, which endorses NEI 21 1804, and there's a link on this slide to that 22 document. And finally, the last ink is the reg guide 23 1.247, which is the trial use PRA guidance for non-24 light water reactors.
25 On slide 9, it's just a reminder that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 1 LMP process has been endorsed by both the ACRS and the 2 Commission. Because it's so fundamental, the staff 3 decided to request that the Commission approve this 4 process. So what you see here on this slide is the 5 link to the SECY paper that requested the Commission 6 review the approval process, and then the staff 7 requirements memorandum endorsed it.
8 Also on this page, you see a reference to 9 an ACRS letter. The ACRS was involved with the 10 development of the LMP throughout the process, 11 including a review of reg guide 1.233.
12 They were also specifically asked to take 13 a look at the basis that was in the SECY paper, and 14 there's just a quote from the ACRS letter that 15 recommended that the Commission adopt the proposed 16 approach.
17 So those are the two background slides, 18 and then on this slide, slide 10 and slide 11, I am 19 going to be relying on Bill Reckley to help out on 20 these slides.
21 So there were two questions that were 22 asked in the subcommittee meeting. What's the 23 difference between a fundamental safety function and 24 a required safety function, which we'll address on 25 slide 11. There was also a question about how are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 1 chemical attacks considered for some of the designs, 2 like a high-temperature gas cooled reactor. How is 3 that considered under the fundamental safety 4 functions?
5 So this first bullet talks about the 6 fundamental safety functions, which are typically 7 sometimes shorthand referred to as control, cool, and 8 contain. Control heat generation. Control heat 9 removal and retain radionuclides.
10 The asterisk for the fundamental safety 11 functions, you know, it's said even sequences 12 involving chemical attacks such as air and water 13 intrusion in a high-temperature gas cooled reactor are 14 considered one addressing fundamental safety issues.
15 And we'll walk through that in the next slide.
16 What this slide also shows is, you look to 17 the right and you'll see, this is figure 3.3. It's 18 from a flow chart for NEI 1804, and it discusses how 19 you develop the PRA.
20 And it's a bit of an eye chart, but the 21 reason that you have a circle there, a dotted circle, 22 is embedded in the development of the full scope PRA 23 on the front end is an expectation that a hazard 24 analysis is done.
25 And it lists examples in NEI 1804, what 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
23 1 type of hazard analysis is expected to be performed on 2 the front end and iterated throughout the development 3 of the full scope PRA. And the examples that are 4 provided are process hazard analysis, failure modes 5 and effects analysis, and reactor-specific initiating 6 events. Before I go on to slide 11, Bill Reckley, is 7 there anything you wanted to add on slide 10?
8 MR. RECKLEY: No, I think you did it.
9 Again, the message is that built in to the LMP is your 10 iterating on both the design and the PRA and the 11 analysis. And a key part of that is to do a thorough 12 assessment of what can go wrong, the hazards analysis, 13 and, as Joe mentioned, it points out to use PHAs or 14 process hazards analysis, and vary your modes and 15 effects analysis.
16 So another reference people can look at 17 during the development of Part 53, the staff developed 18 a DG 1413 that the Committee -- actually, the 19 Committee recommended we develop, and we developed it.
20 And it also has a discussion of basically how to look 21 through and make sure we are identifying and 22 adequately addressing hazards, whether you use the LMP 23 or not. So I --
24 MEMBER PETTI: This is Dave. I had a sort 25 of a fine point that surprised me. Are the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 1 fundamental safety functions only have to be 2 identified in design basis space, or does it have the 3 full licensing basis? So if you felt, for instance, 4 chemical attack was a design basis event only, does 5 that mean it's not a fundamental safety function?
6 MR. RECKLEY: Well, we'll get into 7 chemical attacks specifically on the next slide.
8 MEMBER PETTI: Okay.
9 MR. RECKLEY: Let's do it there, because 10 there's a little flow chart that we can use.
11 MEMBER PETTI: Okay.
12 MEMBER MARTIN: Bob Martin. I had a few 13 questions back in the subcommittee on the hazards 14 analysis, and it would be out of character if I just 15 didn't say something to that regard. But one of my 16 points back in, I guess last month, was that the 17 specificity on hazard analysis currently in what you 18 all drafted is still very high-level.
19 And while I know there's, you know, a camp 20 that would argue that, you know, it provides the 21 greatest amount of freedom, it also provides the 22 greatest amount of subjectivity. And that -- you 23 know, while I'm not going to try to steer the ship in 24 any direction, but down the road I think we're going 25 to need more specificity with how to prepare those 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 1 analyses so that you have the certainty downstream, 2 which downstream will be in PRAs, in the selection of 3 events, that you have some objectivity to those final 4 results.
5 Otherwise, we'll find ourselves in debates 6 about, you know, this choice, that choice, and it'll 7 just be never-ending. So just a comment, but --
8 MR. RECKLEY: Yeah. I would just make an 9 observation. I think we agree with you. However, the 10 guidance that we're doing at this point is -- one of 11 the limitations is it's 12 technology-inclusive, and the more specific you get, 13 the harder it is to stay out of particular 14 technologies or events because the specific hazards or 15 the specific vulnerabilities start to tend to be 16 dependent on the technology.
17 And so what I would expect is, as we go 18 forward, starting at what you say is a relatively high 19 level here, as we start to address individual 20 technologies, it will be inevitable that we'll get 21 more specific.
22 MEMBER MARTIN: Just to finish my thought, 23 is the Department of Energy has a methodology that is 24 of the same --
25 technology-inclusive, and I would certainly encourage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 1 you all to look at what they have done there for that 2 process.
3 MEMBER BIER: This is Vicki Bier. One 4 follow-up to Bob's comment. At a meeting in Wisconsin 5 on Monday, I found myself telling colleagues that the 6 paperwork for getting through the regulatory process 7 seems inversely related to how prescriptive it is.
8 If you have an extremely prescriptive 9 regulation, you need exactly this kind of gauge or 10 valve or whatever. You can -- you don't -- you have 11 no flexibility in design or operation or whatever, but 12 you can get through the approval process trivially.
13 Somebody comes and looks and says, yes. You have the 14 right thing in place, or you're testing the pump often 15 enough or whatever, and it's a very easy approval.
16 Whereas if you have a very open-ended 17 regulation, you can need thousands of pages of paper 18 to justify how you're complying or why you should be 19 viewed as complying.
20 So I understand the issue of not wanting 21 to be too prescriptive, but it creates its own burdens 22 going that route, so just a comment.
23 MR. SEBROWSKY: So moving on to slide 11, 24 and again, I'll look to Bill Reckley for help on this, 25 so I'll do the introductions. So one of the questions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 1 that was asked on the subcommittee meeting was a 2 simple question: what's the different between a 3 fundamental safety function and a required safety 4 function?
5 So the first two bullets, you see the 6 definition of a fundamental safety function -- safety 7 functions that, as the previous slide noted, control, 8 cool, and contain.
9 When it comes to required safety 10 functions, this definition of required safety 11 functions comes out of NEI 1804, and there's a reason 12 why we have a frequency consequence curve on this 13 slide in the lower left-hand corner.
14 So I'll read the definition: a PRA safety 15 -- a required safety function is a PRA safety function 16 that is required to be fulfilled to maintain the 17 consequences of one or more design basis events, or 18 the frequency of one or more high consequence beyond 19 design basis events, inside the frequency consequence 20 target.
21 So to highlight the definition, what you 22 see in the figure in the lower left-hand corner is a 23 frequency consequence curve. And you see a horizontal 24 line. That horizontal line goes to the definition of 25 design basis events -- the consequence of one or more 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
28 1 design basis events inside the frequency consequence 2 curve. So that's one of the aspects of a required 3 safety function.
4 The vertical line goes to the second part 5 of the definition -- one or more high-consequence 6 beyond design basis events inside the frequency 7 consequence curve. So that's what you see as far as 8 the vertical line that's shown on the slide.
9 Required safety functions are addressed 10 for required safety functions by safety-related 11 structures, systems, and components and are analyzed 12 as part of the design basis accidents.
13 MEMBER HANLON: So those arrows are not 14 meant to say that exclusively safety function has to 15 reduce the dose. It's just showing it has to be on 16 that side, left side of the curve.
17 MR. SEBROWSKY: That's correct.
18 MEMBER HANLON: Okay.
19 MR. SEBROWSKY: And then on the right, 20 what we have again, it's a bit of an eye chart and 21 I'll ask Bill to walk through it. But it's an example 22 from a modular high-temperature gas cooled reactor and 23 how the required safety functions for this particular 24 design were developed using the process that's 25 outlined in NEI 1804.
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29 1 And Bill, I'll turn it over to you to walk 2 through that.
3 MR. RECKLEY: Okay. And as the previous 4 slide showed -- I mean, I know we can get wrapped 5 around the axle talking about safety functions. But 6 in general, the fundamental safety functions are a 7 place to start when you're doing the design, right, 8 even a conceptual design.
9 If I'm designing a car, I can start off 10 with the notion that I need to stop the car, right?
11 I have to have the ability to stop the car. I don't 12 need -- I can assume that from the start.
13 But as Joe said, the required safety 14 functions, they take on a special meaning because we 15 are starting to put in the functional requirements.
16 They are needed in order to limit the consequences for 17 the frequency of particular sets of transients.
18 Now for the MHGGR, we often use this 19 example of how the required safety functions were 20 generated for the MHGGR, and you can see there's some 21 design choices that are made as you go down through.
22 But you start on the premise that we need 23 to contain the radionuclides, and then how is that 24 done? You get down to the middle for the MHGGR. The 25 emphasis was to control the transport from the core, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 1 and so that goes to the development of the trisofuel 2 (phonetic) concept, to keep -- the best way to do it 3 for that design is to keep the radionuclides within 4 the core itself.
5 So what is needed to do that? Well, you 6 need to be able to control the reactivity. You need 7 to be able to remove the heat. And for the MHGGR, 8 they laid out separately that because the intrusion of 9 air or steam could affect not -- the graphite, the 10 structure of the core itself, that was identified as 11 a required safety function.
12 Sometimes that's treated more in terms of 13 an event, the challenges; for example, heat removal, 14 if you don't maintain the geometries. But it's also 15 been a convention just to identify that separately as 16 a required safety function.
17 And then given that design decision, the 18 other thing we're showing on this slide is that HGGRs 19 in general have proposed, then, that the role of 20 something like a containment structure or the reactor 21 building in this case could be there for defense and 22 depth.
23 But it's not necessarily going to be 24 identified as a way to fulfill the required safety 25 function and thereby warrant a designation as safety-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 1 related.
2 So that kind of is our attempt to explain 3 the difference. But it's not surprising when you look 4 down at the bottom that two out of the three of those 5 are basically the same as the fundamental safety 6 functions, because the fundamental safety functions 7 have basically been defined based on years of 8 experience.
9 And like I say, a lot of it's just kind of 10 common sense that if I'm going to make a car, I have 11 to be able to stop it. If I'm going to make a 12 reactor, I need to be able to remove the heat.
13 CHAIR REMPE: This is Joy, and it's clear 14 my question wasn't very clear at the subcommittee 15 meeting. It wasn't that I needed to understand the 16 differences between the fundamental safety functions 17 and the required safety functions. It was, how will 18 the reader interpret the guidance and what's in the 19 guidance to understand what to do.
20 I note that 1804 doesn't mention the word 21 "chemical attack." It has the one word chemical, but 22 it's way back on page 95. It's on something not 23 related to the safety functions.
24 It doesn't mention air ingress. It 25 doesn't mention water ingress. At the beginning of 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
32 1 reg guide -- or of -- I guess it was -- jeepers. It 2 was, like, 2107, I believe, they talk about the fact 3 that 1.233 has a different interpretation of 4 fundamental safety functions than what NEI had. But 5 it's fundamentally the same.
6 And then if you get into the actual 2107, 7 when they go through an example, they have a statement 8 that says the fundamental safety functions of 9 controlling heat generation, controlling heat removal, 10 controlling chemical attack, and retaining 11 radionuclides have been achieved.
12 As you've mentioned, Bill, as you did in 13 Part 53, I really liked what you did to outline that 14 with stopping a car, that what you want to do as a 15 nuclear regulatory agency is control radiation 16 release. And then you have supporting safety 17 functions that help you accomplish that objective.
18 And what I was simply saying is, I think 19 the reg guide, the draft guide that you have here, 20 ought to explicitly say, if you want to go this time 21 with what the NEI folks did in 2107 and let the 22 applicants know your expectations that they would have 23 to identify what they believe are the fundamental 24 safety functions for their design.
25 Because yeah, with the HGGR, folks know to 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
33 1 worry about control chemical attack and air ingress 2 and oxidation of graphite. But there's other designs 3 that might have graphite where perhaps they don't 4 worry about combustible gas generation from their 5 graphite.
6 And I just think the guidance needs to 7 highlight that somewhere, is what I was trying to get 8 to, not to explain to me what it means, but to make 9 sure that the applicants have it in the guide. Okay?
10 MR. RECKLEY: Okay. I -- yeah. At a high 11 level, I think -- and I understand what you're saying, 12 that there's a problem staying always at the high 13 level. But at the high level, we would argue that 14 should be done on the previous slide when you're doing 15 your process hazards analysis, failure modes and 16 effects analysis, and other evaluations of what can go 17 wrong inside a reactor. But I understand what you're 18 saying.
19 CHAIR REMPE: Yeah. Just make sure the 20 applicants know what you want them to do --
21 MR. RECKLEY: Right.
22 CHAIR REMPE: -- is all I'm trying to say.
23 Include in the documentation.
24 MR. RECKLEY: All right.
25 CHAIR REMPE: Thank you.
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34 1 MEMBER BIER: I have one other minor 2 comment on the frequency consequence curve. It's kind 3 of off-topic for the things we really need to address 4 today, but I'm providing it just because I made the 5 same comment at a different presentation last month, 6 and it's still relevant here.
7 I realize these curves are pretty commonly 8 used, but I'm not really thrilled with them because, 9 for example, if a particular reactor design went 10 slightly above the curve at one consequence level but 11 was way, way, way below the curve at most other 12 consequence levels, I would view that as being kind of 13 overall favorable, and not ding them for having 14 slightly exceeded the curve.
15 So I'm just providing that as kind of food 16 for thought, not that I expect any response, but --
17 MR. RECKLEY: The general response is, 18 this is a tool we help in our decision making. I 19 would agree with you. Hopefully we never come down to 20 it's black and white, and this is the answer, not 21 just, it is a tool that helps us in the decision 22 making.
23 MEMBER BIER: Perfect, thank you.
24 MEMBER ROBERTS: Yeah, this is Tom 25 Roberts. Bill, you may have just answered the 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 1 question I was about to ask, but I look at the bottom 2 right of that curve, and there's a requirement to look 3 at cliff edge effects in the LMP and there's a 4 requirement to address uncertainty -- things like 5 completeness uncertainty in the analysis.
6 The way the curve is drawn, it implies 7 that five times 10 to the minus seven, you can do 8 basically whatever you want. And the way I read the 9 requirement for a cliff edge assessment and the 10 uncertainties is, that's not the case.
11 There are other assessments that need to 12 be done to test either the uncertainty or the veracity 13 of -- do you really know that five times 10 to the 14 minus seven?
15 And if there was a characteristic where 16 you had a right turn like this curve shows, I would 17 think that would be almost the definition of a cliff 18 edge effect if you then need to go consider whether 19 other actions are needed.
20 I was wondering if you had any 21 observations on that, and --
22 MR. RECKLEY: Well, just --
23 MEMBER ROBERTS: -- do I have that right?
24 MR. RECKLEY: You have it right, and you 25 cite the cautions that we've expressed did not look at 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 1 five times 10 to the minus seven as a bright line 2 cutoff value, because you do need to look below it to 3 look for uncertainties.
4 You need to look below it to look for 5 cliff edge kind of effects, and some of this is 6 addressed in the PRA standard as well, that you need 7 to look below it just because you're going to add up 8 all the risks later on for comparison to the 9 cumulative risk measures.
10 And the events that are below it can 11 contribute to that as well. So just -- yeah, 12 generally, yes. You have it right.
13 MEMBER ROBERTS: Yeah, I found very little 14 finding a definition for the process or expectations 15 for cliff edge effects determination, and I was 16 wondering if that was something you had thought about 17 adding more guidance to.
18 There's an FAQ that I think INL put out, 19 one of the guidance documents for LMP that says, well, 20 it's not really a PRA. It's more of a sensitivity 21 analysis based on the design.
22 And I was wondering if you think there's 23 enough guidance out there, or whether more ought to be 24 provided, or whether it's just a matter of getting 25 experience and then deciding after there's more 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 1 experience whether there's more guidance needed.
2 MR. RECKLEY: To my knowledge, we don't 3 have anything under development. So I think at this 4 point we'll see, at least with the applicants that 5 we're dealing with, if that seems to be an issue. But 6 it's a good observation, but we'll take it back as 7 something to think about.
8 MEMBER ROBERTS: Sure. It's in the 9 regulatory guide 1.242 --
10 MR. RECKLEY: Right.
11 MEMBER ROBERTS: -- an EPZ determination.
12 So that's an opportunity, certainly, to gain 13 experience from the next few months.
14 MR. RECKLEY: Right.
15 MEMBER ROBERTS: Thank you.
16 MEMBER BROWN: Bill, this is Charlie 17 Brown. On this slide and the previous slide, I just 18 couldn't resist to jump in to use your car example 19 since that seems to be a favorite example these days.
20 Obviously, if you've got a car, you said 21 you're going to need brakes. But if you don't know 22 what to do with the brakes, do you know what the car 23 looks like? Is it going to have steering? Are you 24 going to have doors? Are you going to have windows?
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38 1 it have to deal with?
2 So for some reason, we lose sight of the 3 bigger picture by not having an architecture of what 4 we're doing. What we're doing with this kind of 5 boggles my mind to think that I could control core 6 heat generation. A radioactivity control system does 7 that in today's plants.
8 You have to have a side, independent thing 9 that rapidly shuts it down if your control -- your 10 major control reactivity system doesn't work or you 11 have some excursion you can't imagine, just because 12 some analysis said I'm at 10 to the minus seven or 10 13 to the minus eight.
14 For some reason, when I look at these and 15 we discuss it, we lose sight of -- what is the 16 architecture of the plant I look at if these points 17 are valid and the core heat generation and the removal 18 of core heat, chemical attack, et cetera.
19 But you really need to know what the car 20 looks like before you can start piecing these pieces 21 together. So an example would be if you have -- and 22 you can do it non-prescriptively -- what we've done 23 focusing on even the light water reactors when we get 24 something new in, or the reactor trip and safeguard 25 systems.
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39 1 We want to see the architecture. What 2 does the system look like? And then you can define --
3 you can build it with brick. You can build it with 4 pneumatics, mag amps, backing tubes, transistors, 5 integrated circuits, microprocessors, or FPGAs. It 6 doesn't matter if you know what the architecture looks 7 like.
8 And then you can say if it's independent 9 and redundant and then has some other criteria, some 10 fundamentals, then you know you've got something that 11 you can work with. I've missed that a little bit in 12 focusing on, what does the plant look like?
13 And yet we focused on -- I don't disagree 14 with these fundamental features, but you need to have 15 an architecture of what the plant looks like in order 16 to assess each one of them. And that's not really 17 covered a whole lot in these discussions, or at least 18 I missed them. It's just a bigger point.
19 MR. RECKLEY: Yeah. Basically, that's 20 part of the iterative process that we talk about, and 21 the fact that all of these things like remove core 22 heat, if you then go on in the process, you know, the 23 flow chart doesn't stop here. The flow chart actually 24 kind of starts here, that you will determine all the 25 specifics and, as you've referred to it as, the 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
40 1 architecture that will be needed.
2 Obviously, to know how to remove core 3 heat, I need to know how much core heat. Does that 4 amount of core heat compare to my heat removal 5 capability that then that will provide feedback into 6 how quickly, for example, my reactivity control system 7 needs to work?
8 So all of that -- agree with you, Charlie.
9 It's just that we're at -- we're talking at the 50,000 10 foot level but you're exactly right. At one point, 11 all of these designs have to get deep down into the 12 grass. Mixing metaphors here, but anyway, Joe, I'll 13 turn it back to you, I think, unless there's more 14 questions on LMP.
15 This was intended just to be a little 16 background. If we need to, this will keep coming up 17 -- the LMP and as we're trying to work through its 18 first implementation on the advanced reactor 19 demonstration program plants. So, you know, whenever 20 we need to -- whenever the committee thinks it would 21 be useful, we can come back and have similar 22 discussions.
23 VICE CHAIR KIRCHNER: Just -- this is Walt 24 Kirchner. Just one observation -- I think the crux of 25 the problem, Charlie, and somewhat related to your 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
41 1 observation is that when you get to this stage with 2 that definition, how do you classify the SSCs?
3 I think that's where the -- you know, 4 there's going to be, I think, between the NRC and the 5 applicants, that's where there's going to be the major 6 rub because whether you call it safety-related, or 7 important to safety, or all the old -- we've got the 8 RTNSS or whatever the other definitions were.
9 It's going to be a question of, what's the 10 quality of that component that helps keep you below 11 the line on the FC targets, and to what quality does 12 it have to be designed, built, and tested, and its 13 pedigree? And I think that's really where this will 14 become a little more problematic in the 15 implementation. It's just an observation. It doesn't 16 require a response.
17 MEMBER MARTIN: Let me add to that. I 18 will say a lot of the questions related to the 19 ambiguity associated with the actual implementation 20 of, you know, a whole preparation of the safety case.
21 There is certainly precedent and, you 22 know, associated with past rulemaking where, you know, 23 the NRC or maybe more in the case of, you know, 24 getting support from the research branch of preparing 25 a -- kind of a thorough demonstration sample problem, 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
42 1 which conveys a level of expectation maybe beyond 2 anything else that's been done. And I know, maybe 3 that's easy responses.
4 NEI has, you know, unseeable problems. I 5 would say that's not the same as, you know, when the 6 NRC does that. And it's never too late, say, to 7 initiate an effort like that. But I do think industry 8 would probably appreciate some sample problem that's 9 been initiated by the NRC that maybe clears up some of 10 these questions.
11 Throwing that out there, but an example 12 I'm giving is -- in my own experience is with the rule 13 change and the ED8, or, you know, 50.46, or best 14 estimate LOCA. They went through extensive exercise 15 demonstrating, you know, what best estimate LOCA would 16 look like through the code scaling applicability and 17 certainty process. Very technical, brought in 18 technical experts from labs and such.
19 I think it added a lot of credibility and 20 addressed a lot of that ambiguity with such a 21 significant rule change. Again, not a rule change in 22 this case, but it is leading towards major change.
23 And relying on industry to demonstrate is not the same 24 as doing it yourself.
25 MR. SEBROWSKY: Thank you. So we'll move 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 1 on to slide 12. The reason that we went into the 2 background on the licensing modernization project is 3 because it's a key input to NEI 2107 and the TICAP 4 guidance.
5 What the slide shows now in the red 6 highlight is the portion of the safety analysis report 7 that is derived from NEI 2107 based on the LMP 8 process. So you see we're going to a 12-chapter 9 format for the SAR versus an 18- or 19-chapter format 10 that you see for light water reactors.
11 And just to point out, when you talk about 12 LMP being -- addressing licensing basis events, you 13 see that in chapter 3, SSC categorization. You see a 14 discussion of how that's developed in chapter 5, and 15 then safety-related SSCs would be expected to be shown 16 in chapter 6, and non-safety related with special 17 treatment in chapter 7.
18 The plant programs associated with 19 ensuring the reliability and availability of those 20 SSCs that you assumed in the full scope PRA would be 21 in chapter 8.
22 The next portion of this slide is 23 highlighting the overall expectation for the guidance 24 and what we would expect in an application. And it 25 goes beyond the SAR. But what this shows is you see 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 1 chapter 9, 10, 11, and 12 coming from specific ARCAP 2 ISGs. You see a highlighted box down below on the 3 chapter 2, which is site information. That is not 4 something that's developed by the LMP process. And 5 over on the right, you see additional portions of the 6 application, including things such as tech specs.
7 MEMBER HANLON: Joe, did you -- in our 8 subcommittee, we talked a little bit about the notable 9 absence of decommissioning strategies in this. Did 10 you all think about that, and seeing where that could 11 fit?
12 MR. SEBROWSKY: Yeah. We have thought 13 about it, but we haven't come up with an answer yet.
14 MEMBER HANLON: Okay. Clearly it's not as 15 critical as the ones you have there, but it certainly 16 is showing up to be quite an expensive and regulatory 17 complex -- I think more than hat we expected. So 18 thanks. I'll be looking forward to seeing where that 19 might fit.
20 MR. SEBROWSKY: So again, what this slide 21 is showing with the red highlighted boxes is where --
22 how we address by the ARCAP ISGs the other part of the 23 applications. 9, 10, 11, and 12 have separate ISGs as 24 well as chapter 2.
25 And then you will see, for the additional 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 1 portions of the applications, in some cases we 2 developed a separate and distinct ISG. For example, 3 for tech specs in service inspection and service 4 testing, and also for prior protection for operations.
5 In other cases, the ARCAP roadmap ISG 6 itself points to and develops the guidance for other 7 portions of what we expect in the application.
8 So slide 13, some of the common changes 9 that we made, the ISGs and the TICAP reg guide is 10 applicable now only for non-light water reactors. We 11 recommend that if a light water reactor applicant 12 wants to use ARCAP and TICAP, since it is technology-13 inclusive, that they engage in pre-application 14 discussions with the staff.
15 All ISGs now provide applicant guidance as 16 well as NRC staff review guidance, and we removed 17 references that did not have a complete NRC staff 18 review.
19 In some cases, if you look at Appendix 20 Delta of the ARCAP roadmap ISG, you will see that we 21 do list ISGs that are in development that could result 22 in a future revision to our ISGs.
23 One of the things that we stress is the 24 importance of principal design criteria. TICAP 25 guidance covers the principal design criteria 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 1 associated with the licensing modernization project.
2 That's for off-normal conditions.
3 If you look at the ARCAP roadmap ISG, it 4 also provides expectations for principal design 5 criteria for normal operations like those associated 6 with a control of normal effluence to ensure that you 7 meet 10 CFR part 20 underlying requirements.
8 There is a backstop and reg guide 1.232 9 does provide guidance for developing principal design 10 criteria for non-light water reactors that is 11 available for reviewer and applicant consideration.
12 The ARCAP -- because of the importance of 13 principal design criteria, it's recommended that 14 during the pre-application phase, the identification 15 of those principal design criteria are discuss with 16 the staff.
17 So what I'd like to do now is turn it over 18 to my colleague, Anders Gilbertson, to walk through 19 reg guide 1.253. Anders?
20 MR. GILBERTSON: Okay. Thank you, Joe.
21 Good morning, ACRS committee members. My name is 22 Anders Gilberston. I'm a senior project manager in 23 the policy branch and DANU. And this morning, I'll 24 just be going over a quick overview of the TICAP 25 guidance and the staff's endorsement thereof in reg 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 1 guide 1.253. Slide 16, please.
2 So I'll step through some of these points 3 relatively quickly, because it's really just a matter 4 of sort of re-emphasizing some of the things that Joe 5 mentioned earlier.
6 Just generally overall, you know, the 7 TICAP guidance is a technology-inclusive approach for 8 developing the content of applications. It's based on 9 the LMP methodology like we've talked about.
10 And really, the guidance is intended to 11 promote more efficient development and review of those 12 LMP-based applications, understanding they're going to 13 look a little different than what we are used to 14 seeing.
15 Along those lines, the structure of the 16 TICAP-based safety analysis report differs from the 17 traditional structure of an SAR based on the LWR 18 standard review plan. And of course that's again as 19 a matter of accommodating the outcomes that come from 20 implementing the LMP methodology.
21 And I'm skipping to the last point. We've 22 already kind of talked about the LMP, that TICAP is 23 governed by the LMP methodology. You know, the LMP is 24 not just risk-informed and performance-based, but it's 25 also PRA-led.
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48 1 So in that regard, you know, one of the 2 points to emphasize here is that the optimal endpoint 3 of the development of the PRA to support 4 implementation of LMP is a logic model, a PRA logic 5 model that addresses all sources, hazards, and all 6 plant operating states.
7 And it comprises the full spectrum of 8 analyses that start from initiators and go all the way 9 out to consequences. So as we understand looking at 10 our previous discussion about the frequency 11 consequence curve.
12 However, in this context, you know, the 13 guidance that we developed in reg guide 1.253, 14 appendix Alpha in particular, we recognize that when 15 we're using LMP in the two-step licensing process in 16 Part 50, it's understood that, generally speaking the 17 LMP methodology is going to be implemented to some 18 intermediate stage of completion in doing that.
19 The information that's provided at the 20 construction permit stage is preliminary in nature.
21 The staff are making different findings at the CP 22 stage. So recognizing that that situation, that we 23 also acknowledge the PRAs supporting the construction 24 permit application, it's very likely going to be 25 something less than this sort of so-called optimal 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 1 endpoint.
2 It's not that it couldn't be more mature 3 and more well-developed or nearly complete, but for 4 the most part, understanding the flexibility that's 5 intended to be afforded by the two-step process, 6 that's generally what we expect to see.
7 So accordingly, it's important for us to 8 understand and establish what the minimum needed is 9 for an acceptable PRA supports the LMP-based 10 construction permit application as a matter of helping 11 the staff determine how they would arrive at their 12 findings under a 10 CFR 5035 alpha and other related 13 construction permit regulations.
14 And so, of course, this is the subject of 15 the guidance in appendix alpha to reg guide 1.253, and 16 this has direct relationships to the content of a 17 construction permit application. Slide 17, please.
18 So this graphic is really just to show the 19 general high-level structure of the first eight 20 chapters of the safety analysis report, resulting from 21 using NEI 2107 and also just to provide the overall --
22 a synopsis of the purpose of reg guide 1.253.
23 As I mentioned in the last slide, the 24 structure is notably different from the SAR structure 25 dictated by the standard review plan, and I'll talk 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 1 about that in a little more detail on the next slide.
2 But again, this structure is really 3 tailored to foster a better understanding of the 4 licensing basis as it's developed through the process 5 of implementing the LMP methodology. We can go to 6 slide 18, please.
7 Okay. So given the prominent roles of PRA 8 and the LMP methodology, much of the information in 9 chapters 1 through 8 of the SAR dictated -- that are 10 dictated by the TICAP guidance, either directly or 11 indirectly related to or derived from the PRA itself.
12 So because TICAP dictates this new SAR 13 structure, we developed this visual map which we sort 14 of have affectionately termed this Where's Waldo 15 graphic to help identify where risk and PRA-related 16 information is expected to be found in the first eight 17 chapters.
18 To be clear, that label is not to say that 19 the PRA information is considered to be obscured or 20 hidden as though you're trying to find Waldo. Rather, 21 it's more to convey that familiarization with this new 22 structure may require some extra attention.
23 And to that point, for example, the TICAP 24 guidance in the structure, it doesn't include a 25 chapter on severe accidents like you'd find in chapter 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 1 19 for an LWR SAR, and that would otherwise be 2 expected to contain much of the information on a PRA.
3 And instead, that information, as shown in 4 this color-coded diagram, would be located in chapters 5 1 and 2, and the related results to the PRA and other 6 PRA-derived information would largely be addressed in 7 chapters 3, 4, and 5.
8 So again, this was assembled and we used 9 this as kind of a tool to help the staff understand 10 where we're going to find this information as a matter 11 of helping us determine what this guidance on PRA 12 acceptability for the construction permit stage would 13 look like. Slide 19, please. Okay.
14 And continuing along with that theme, this 15 is another diagram that we presented at the 16 subcommittee meeting earlier this year. And again, 17 this diagram really is intended to provide a visual 18 representation of the overall process for implementing 19 the LMP methodology, and the development of the PRA 20 that goes along with it and related engineering 21 analyses as it relates to the two-step licensing 22 process.
23 I would emphasize that this is a somewhat 24 simplistic diagram. For example, you don't see 25 representations of the iterations that would occur.
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52 1 So that -- they still are there. They're just not 2 shown here because this was more focused on trying to 3 arrive at what information.
4 And what we would expect to see in the CP 5 application itself, and then helping -- and using that 6 information to help us backtrack and understand, given 7 our understanding of the PRA acceptability paradigm, 8 that we have -- the staff have described other 9 guidance documents like reg guide 1.247 and 1.200, 10 what that guidance ought to look like. Okay. So 11 slide 20, please.
12 All right. For just the last couple of 13 slides that I have to present on, I just wanted to 14 focus on a couple of key points -- a few key points of 15 that guidance in appendix alpha. The first point 16 being that, like I mentioned before, it talks about 17 addressing all sources, hazards, and plant operating 18 states.
19 So the term "address" is taken to mean 20 that these items are identified and dispositioned, as 21 we've shown here, and where dispositioning means that 22 they are accounted for by one of the four sub-bullets.
23 So either modeled directly in the PRA 24 logic model, screened out of the PRA logic model 25 through some acceptable screening processes, accounted 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 1 for using the risk-informed supplemental evaluations, 2 or accounted for using the design basis hazard levels 3 for the hazards other than internal events.
4 And Joe, if you can cue the animation, the 5 next box here, I just want to point out that generally 6 speaking the guidance in NEI 2107 talks about the PRA 7 in a very general sense. And this is really -- this 8 -- just to emphasize that in that context what we're 9 taking that to mean is really the PRA logic model, 10 screening analyses, and the risk-informed supplemental 11 evaluations that would really comprise this sort of 12 more general conceptual notion of the PRA.
13 And that comes with an understanding that 14 the staff have provided definitions of what a PRA is 15 in reg guide 1.247, which is a little more specific 16 than this. Moving on to the next point, as I 17 mentioned previously, to be minimally acceptable, the 18 PRA logic model supporting the LMP-based CP 19 application should at a minimum represent the internal 20 events and power reactor contributions to risk.
21 Now that's a relatively limited scope.
22 However, the thinking behind that is that such a PRA 23 would help demonstrate the applicant's ability to 24 develop the essential elements of the PRA logic model 25 that are needed to represent the plant and its 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 1 response to perturbations, establish the foundation 2 for the PRA that will evolve as the LMP methodology 3 progresses and design information matures.
4 And also, you know, while the staff --
5 we've described that -- we're describing what is 6 minimally acceptable for the PRA logic model. From a 7 practical standpoint, achieving only the minimally-8 acceptable PRA logic model is generally not expected 9 to realize the full benefits afforded by the LMP 10 methodology as a matter of design optimization.
11 So the staff are charged with providing 12 and developing this guidance to help describe what is 13 needed as a matter of arriving at a regulatory 14 finding. So that's a different thing than realizing 15 the benefits, the full benefits of the LMP 16 methodology.
17 And so it's just to acknowledge that 18 design -- we understand design information at the CP 19 stage is preliminary in nature. We're not -- staff 20 aren't making a final safety finding like we will at 21 the OL stage.
22 It's important to note that the 23 effectiveness of implementing LMP at the construction 24 permit stage will necessarily depend on both the 25 maturity of the design and the maturity of the PRA.
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55 1 MEMBER ROBERTS: Two questions. One's 2 --
3 MR. GILBERTSON: Yes.
4 MEMBER ROBERTS: Did you say appendix B on 5 the title of the slide?
6 MR. GILBERTSON: So -- okay. So in the 7 draft guide, DG 1404, it was designated as appendix 8 bravo. Based on some of the public comments we got, 9 we eliminated what was appendix alpha in the DG, and 10 what was appendix bravo was elevated to appendix --
11 MEMBER ROBERTS: Oh, okay. Thank you.
12 MR. GILBERTSON: Yes.
13 MEMBER ROBERTS: The third sub-bullet 14 there, category using risk-informed supplemental 15 evaluations, would that include the cliff edge effects 16 determination? Because I was looking at the text of 17 appendix B, which I guess is appendix A now, and it 18 specifically refers to NUREG 1855 is what you mean by 19 risk-informed supplemental evaluations. But I would 20 also include the cliff edge effects determinations?
21 Have you all included?
22 MR. GILBERTSON: Yes. So, it could. It 23 could. I would note that while that is an option for 24 a designer, there are requirements in the non-LWR PRA 25 standard that do specifically address cliff edge 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
56 1 effects.
2 So if an applicant were so inclined to try 3 to meet and adhere to those requirements at the 4 construction permit stage, they may address it through 5 the PRA logic model as well.
6 MEMBER ROBERTS: As a general comment, 7 going through the whole 21 chapter 7 and the reg 8 guide, I didn't see a whole lot of discussion on cliff 9 edge effects. So I'm not sure where I would find it 10 in your Where's Waldo diagram. Where's it at, Waldo?
11 It seems like it might be here in that 12 third sub-bullet, but dead even in the text it doesn't 13 talk about cliff edge effects as far as the scope of 14 these risk-informed supplemental evaluations. So, 15 something to think about, whether it needs to be more 16 clear enunciation of what's expected in the 17 application and where it would be for cliff edge 18 effect determinations, given its use in analyses like 19 the emergent planning zone. Thanks.
20 MR. GILBERTSON: Understood.
21 MEMBER HANLON: And there's one other 22 question, maybe comment. Given that the CP stage is, 23 as you mentioned, not necessarily a very mature design 24 -- probably more than a concept but less than a -- you 25 know, less than an actual plant design. Do you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
57 1 concede or perceive that potentially when you get to 2 the OL application stage, there would be a significant 3 difference in the licensing basis event selections 4 and/or chapter content?
5 MR. GILBERTSON: It's -- yes. There -- we 6 generally expect that there will be some differences.
7 I think generally that's going to depend on the amount 8 of -- I guess, the amount of enterprise risk than an 9 applicant is willing to take.
10 If they're employing conservative 11 assumptions leading up to the construction permit 12 application, understanding that they are -- from that 13 point forward, they're going to start engaging in 14 procurement, actual construction, and they're going to 15 be doing things that are difficult to change, you 16 know, it's possible you could see things that, as they 17 go forward and they realize that some of those 18 conservatisms were not entirely necessary, maybe we 19 start to see things.
20 There's some class of SSC classifications 21 that could go from safety-related to non-safety 22 related special treatments. And it could go the other 23 way as well. They could make a decision. So yeah, I 24 think that's certainly a possibility, and it's 25 something the staff will certainly be paying attention 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
58 1 to.
2 MEMBER HANLON: So my comment is, if you 3 look at -- if you take economics out of the equation 4 of viability of these plants, and just look at the 5 safety aspect, this works really well.
6 You add the economics back in. Presently, 7 we're seeing seed money. We're seeing grant money, a 8 lot of things that are pushing a design forward, maybe 9 beyond where a minimal construction permit application 10 might see.
11 As we get further into it, we're seeing 12 some vendors drop off or seeing some of our applicants 13 drop out. We're seeing some potential customers move 14 away from this because of the economics of it, not 15 anything to do with the safety or anything like that.
16 It's all the economics.
17 And my comment and perception is that 18 feels like the construction permits, if they do come 19 in, they're going to come in as close to minimally 20 acceptable as possible, if nothing else as a marketing 21 tool to say, I have a -- that you could buy and move 22 forward with.
23 So I think that's spread between what you 24 see in construction permit and operating wise this is 25 going to continue to widen with construction permit 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 1 going more towards the minimal now. So it's just a --
2 it's a perception at this point, but I think that we 3 need to be ready for some significant difference 4 between a construction permit application and an 5 operating license if we get to that point.
6 MR. GILBERTSON: Yes. I think that's a 7 good observation, and, you know, that sort of points 8 to the enterprise risk that then really is being taken 9 on by applicants.
10 And I think having a well-defined process 11 like LMP where you understand what your endpoint needs 12 to be; that at the end of the day when you have 13 completed your PRA, you are also going to subject it 14 to normal processes like a peer review and 15 understanding that we have established, endorsed 16 processes, you know, procedures for that.
17 So I think that helps, but yeah. How that 18 ends up will remain to be seen.
19 MEMBER HANLON: One last question on -- I 20 can wait till the -- I'll have a comment at the end on 21 the ISGs, but it's more process-oriented so we'll go 22 on after.
23 MR. GILBERTSON: Okay.
24 MEMBER MARTIN: I mean, a follow-up on 25 your comment, Greg, or at least a thought as you were 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
60 1 expressing your last comment. In looking at the 2 statement about the LMP-based construction permit 3 application, I keyed on the word "at a minimum" or "as 4 a minimum."
5 And I agree that what you're focusing on 6 is, you know, the right, you know, right emphasis.
7 But whenever you say something like "at a minimum," it 8 begs the question, is -- where is that line? And even 9 with the focus on internal events, power reactor PRA 10 logic models, you could still stretch that model out, 11 you know, almost indefinitely.
12 What guardrails would you have, you know, 13 for a review process that comes in with, you know, 14 just rock? Now to lead the witness, I do think that 15 there's a role for deterministic analyses to serve and 16 to define guardrails.
17 I mean, I think, you know, roles of non-18 safety equipment can certainly impact the progress of 19 an event, and certainly in the early stage of design, 20 you know, there is a considerable amount of 21 uncertainty with the role of those SSCs that have been 22 otherwise, maybe, deterministically evaluated as non-23 safety.
24 Anyway, would you please comment on what 25 are -- first, the guardrails and whether you see the 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 1 value of other kinds of analyses to kind of tell the 2 full story first?
3 MR. GILBERTSON: Yeah. So I think the 4 guardrails in this regard, and what we were generally 5 thinking of when we developed this guidance, really 6 those technical elements in the non-LWR PRA standard 7 that are affiliated with the internal events, the 8 fundamental foundational elements of the PRA.
9 Embedded in that are the deterministic 10 analysis that you absolutely have to have to represent 11 the plant response, plant behavior, which includes 12 your thermohydraulics analyses; influence of operator 13 actions on, you know, how it's expected to be 14 operated; timing of your accident sequences.
15 And while in many -- you know, for a PRA, 16 those analyses may be rolled up to be representative 17 of certain classes of event sequences as a matter of 18 helping to simplify the problem. And you're not doing 19 a -- for example, a SOARCA-type analyses for every 20 single event sequence or cut set.
21 Those deterministic analyses do underpin 22 the PRA, and are -- yeah. They're absolutely crucial.
23 So if you don't have that and we can't see that you're 24 representing your plant behavior appropriately, that's 25 a big issue. So I would say those are the sort of 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
62 1 guardrails. Okay? Okay. Slide 21, please.
2 VICE CHAIR KIRCHNER: Anders, just before 3 you go on, I think buried in the previous slide in the 4 major subheading it said -- hazards analysis. Let me 5 just look at your slide. What I'm thinking about is 6 a particular, at the CP stage, consideration of 7 seismic hazards.
8 Maybe just that -- as you were just 9 saying, maybe that's an example of the deterministic 10 analysis that a first-order cut should be done for, 11 you know, what's the safe shutdown, earthquake or the 12 equivalent, because that's such a dominant factor 13 going into the construction phase. Is that what you 14 were implying or guiding or asking for in that place 15 in the -- sorry for that. The slide --
16 MR. GILBERTSON: Slide --
17 VICE CHAIR KIRCHNER: Slide 20, sorry.
18 For hazards other than internal events, does that 19 include for seismic?
20 MR. GILBERTSON: It -- well, yeah. That 21 could be. That could be one example of it. And I do 22 actually -- on the next slide, that's actually one of 23 the examples that I give about when we talk about the 24 applicants' plan for further developing their PRA.
25 So yes, at the CP stage, you know, seismic 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 1 may fall into this category of being accounted for by 2 this category of DBHLs, if you will. And yes, yeah.
3 There -- it's -- at the end of the day, one of the 4 things that we're looking for is understanding how all 5 of these risk contributors have been considered.
6 Again, do they meet the QHOs -- I'm sorry.
7 Not do they meet the QHOs, have they provided at least 8 a qualitative explanation of how they think the QHOs 9 could be met at the CP stage.
10 They're not required to meet them at the 11 CP stage, understanding that -- for example, for 12 seismic, if they did something that was akin to a 13 margins analysis where they're just characterizing the 14 margin they have, and there's not -- there are no 15 event sequences, per se, going out and calculating 16 consequences.
17 We would still expect to see some sort of 18 characterization based on that seismic risk of how 19 that impacts the QHOs, so -- okay? All right. Slide 20 21, please.
21 Okay. So just to wrap this up, so some of 22 the other key points -- again, at the construction 23 permit stage, the -- a self-assessment of the PRA 24 logic model, the screening analyses, and the risk-25 informed supplementary evaluations is something that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 1 we view as being very important and can help reduce 2 the need for in-depth NRC review.
3 This is the sort of thing that would allow 4 us to help -- to focus more on key assumptions and 5 sources of uncertainty as we're looking at the PRA.
6 It is possible that such a self-assessment could take 7 the form of a peer review at the construction permit 8 application stage, but it's not required as such.
9 But it is notable, again, like I mentioned 10 before, we do have established processes that have 11 been endorsed by the NRC staff to that effect.
12 Another thing we wanted to point out is that as you 13 follow the guidance in reg guide 1.253, one of the 14 outcomes would be these preliminary -- a complete set 15 of licensing basis events and SSC classifications that 16 are provided.
17 And again, the completeness of those items 18 is going to be contingent or related to the amount of 19 preliminary design information, and it should be 20 consistent with that, understanding that there can be 21 varying degrees of maturity in that design 22 information.
23 And then, of course, the applicant's 24 determination of risk metrics and comparisons with the 25 QHOs like I had previously mentioned.
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65 1 And then finally, understanding the PRA 2 will continue to evolve. Another important piece is 3 understanding, like I said, the applicant's plan for 4 evolving and continuing to develop their PRA as they 5 construct -- as they iterate on their design and get 6 to the final design information.
7 So like I mentioned, if they are using a 8 seismic DBHL at the CP stage, understanding how 9 they're going to transition from using a DBHL to a 10 seismic PRA, POL stage, would be an important aspect 11 of evaluating the construction permit application.
12 And then of course as the -- you know, CP 13 holders are always encouraged to keep NRC staff 14 apprised of changes to their completion plan that 15 would expect to significantly affect the facility, the 16 design.
17 MEMBER DIMITRIJEVIC: This is Vesna 18 Dimitrijevic. You know, so far I didn't really, you 19 know, feel I have to comment on everything. But here, 20 I did feel, you know, how can you say yet complete?
21 I mean, what does that mean, yet complete? Obviously, 22 it's not going to be complete in this stage. You 23 know, design is preliminary. A lot of hazards wasn't 24 considered. The PRA would be significantly different 25 in the OL stage.
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66 1 So for that part, the SSC classification 2 would not be complete in that stage. So why did you 3 feel you had to say here, yet complete? You didn't 4 say yet complete for CP stage. Why do you say here 5 yet complete?
6 MR. GILBERTSON: Yes, so -- right. Thank 7 you. So what that is really referring to is in this 8 idea that the information's provided on the set of 9 LBEs and SSC classifications. That completeness is 10 really dependent on the consistency with the 11 preliminary design information provided at the time of 12 the CP application.
13 So really, that's what that is intended to 14 mean. We understand it's not -- there may be new LBEs 15 that are identified as they develop detailed PRA 16 models leading up to the OL stage.
17 So it's -- perhaps it's -- you know, 18 completeness is also a matter of meeting the 19 requirements under 10 CFR 50 34 alpha as it relates to 20 assessing the risk of the facility and of the 21 operation of the facility which, again, implies that 22 you're looking for the full scope of risk contributors 23 to which that facility could be exposed.
24 Does that help answer the question?
25 MEMBER DIMITRIJEVIC: Well, no. You know, 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
67 1 this is just -- you have discussed in previous slides 2 how not complete that is. I mean, you know, talking 3 just -- you answered power and things like that. So 4 obviously, if -- you know, and you're referring to 5 alpha which is just, you know, the -- you're after 6 this alpha which is just ASME PRA standard which 7 define the scope.
8 This is not satisfying scope, so it's 9 definitely, you know, minimal expectation is far 10 complete scope. So I just want to say, I don't see 11 why you need to say this here because it's definitely 12 not right. And let me just ask you something by -- we 13 just mentioned this appendix alpha.
14 You have two tables in the end of appendix 15 alpha, and the first one, A2, and A3. Are you 16 familiar with them? You know, because in A2, it's 17 just defined minimum requirements, the minimum -- the, 18 you know, the high-level requirements expected for PRA 19 to meet in this stage, right? That's your A2 table.
20 MR. GILBERTSON: Correct.
21 MEMBER DIMITRIJEVIC: And here I wasn't 22 really sure what does the A3 table present, because it 23 says just additional, you know. The first one is 24 minimally acceptable and the next one is with 25 additional PRA elements. Is that table supposed to 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 1 define expectation in OL phase or it's just -- I 2 wasn't sure what the function of table A3 in appendix 3 A was.
4 MR. GILBERTSON: Okay, yeah. Thank you.
5 So the short answer to that is no. It doesn't provide 6 expectations for the OL stage. What table alpha 3 is 7 intended to do is, you know, when the staff went 8 through this exercise of applying the process in the 9 non-LWR PRA standard to determine what supporting 10 requirements would be applicable for the construction 11 permit stage, we were considering a very broad range 12 of potential design maturities.
13 And what we didn't want to have happen was 14 that an applicant comes in and they end up doing quite 15 a bit more beyond just an internal events model. They 16 try to address other external hazards and such using 17 the PRA standard, and not have those staff positions 18 available to them.
19 Again, they're not requirements and 20 nothing in those tables are intended to -- either for 21 table A2 or A3 -- are intended to imply that there is 22 necessary compliance. And we've actually -- we've 23 augmented some of the -- there's a short preamble 24 we've added before those tables to that effect. So 25 it's really just a matter of saying, look. The staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 1 went through this process.
2 We consider a very broad range of design 3 maturities, you know, as a matter of hopefully helping 4 applicants understand where we're at with some of 5 those requirements, should they choose to try and meet 6 them.
7 MEMBER DIMITRIJEVIC: Well, it's not just 8 design maturity that you tend to put in the first 9 thing. It's a scope, you know. It's not just design 10 maturity. It is the scope of the PRA which is in the 11 -- you know, significantly changed between those two 12 phases, you know. And, you know, in your SAR after 13 the first two chapters, which are really heavy with 14 information, then it comes this next, you know, for 15 the TICAP, the next, you know, six chapters which may 16 all significantly change, you know, when the scope of 17 the PRA change. So, I mean, I sort of, like, don't 18 really have a good idea how this all is going to work, 19 so --
20 MR. GILBERTSON: Okay. Yeah, I guess as 21 far as scope, I guess I would probably relate the same 22 point that, again, it was -- if an applicant chose to 23 try and meet a broader scope, we wanted to make sure 24 that they had that information available to them of 25 what the staff thought. And determining, you know, in 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
70 1 terms of scope, that's in some regards identifying the 2 supporting requirements.
3 And then, of course, level of detail would 4 be sort of analogous to which of the capability 5 categories. So we're trying to address those four 6 aspects of PRA acceptability: scope, level of detail, 7 PRA technical elements, and plant representation. But 8 I take your point that it's -- how those tables end up 9 being used and met, we'll have to -- we'll see how 10 applicants come in with that.
11 MEMBER MARCH-LEUBA: This is Jose --
12 MEMBER DIMITRIJEVIC: Okay. Thanks.
13 MEMBER MARCH-LEUBA: Let me ask this from 14 a different point of view. We'll think outside the 15 box. I think all the discussion we're having is 16 academic because you're talking the difficulty of the 17 first of a kind reactor, but the only justification 18 for having to spend so much effort, time, and money on 19 these methodologies because we're not having a 20 resurgence in the nuclear industry. And we're going 21 to maybe land from 10 to 20 of a kind.
22 By the time you're building the second 23 one, CP and OL are going to be 90 percent equal, and 24 then you build the fifth, they're going to be 99.9 25 percent equal, and you'll be reusing the PRA that you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 1 did for -- during number four.
2 So the first of a kind can be this 3 exception, and certainly the applicant would have to 4 construct a risk. If they change the design too much 5 they will have to do some extra work. But the 6 expectation this will work, the projects, maybe this 7 here we have some problems. So I think the discussion 8 is not -- it's an exception, different kinds of 9 exception.
10 MR. GILBERTSON: Yes. I would definitely 11 agree with -- yeah. The first of a kind is going to 12 be quite unique as they figure out how to navigate 13 this, as well as the staff --
14 MEMBER MARCH-LEUBA: Yeah.
15 MR. GILBERTSON: -- and the lessons 16 learned as they go along in understanding what do they 17 need? What do they not need? What's good enough?
18 MEMBER MARCH-LEUBA: The methodology we 19 work, the second, third, and fourth -- certainly for 20 the 20th.
21 MR. GILBERTSON: Yes, yes. That is the 22 intent. Okay. If there are no more questions, I'll 23 turn it back to Joe. Thank you.
24 MR. SEBROSKY: So the rest of the 25 presentation is overview of the various ARCAP ISGs.
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72 1 We already talked about the ARCAP roadmap. This slide 2 just provides additional information. Previously I 3 mentioned that, in some cases, the ARCAP roadmap ISG 4 will point to different guidance documents. Like for 5 the first eight chapters, it's pointing to reg guide 6 1.253 or for technical specifications pointing to the 7 ARCAP ISG on technical specifications.
8 When you look at the ARCAP roadmap, you'll 9 notice that some of the guidance itself contained, 10 like, for emergency plant security, financial 11 qualifications and insurance and liability. There are 12 four appendices in the ARCAP roadmap ISG. The 13 appendix A is a pre-application guidance. Back in 14 2021, we had talked to the ACRS at a high level about 15 what would be in appendix A.
16 Appendix B, the applicability of 17 regulations to non-light water reactors back in 18 previous discussions with the ACRS in 2021, we just 19 referred to a white paper that was under development.
20 We ended up capturing that white paper and putting it 21 in appendix B.
22 Appendix charlie is construction permit 23 guidance. When you look at that appendix, you're 24 going to see that it lifts much of the interim staff 25 guidance for light water reactors that are applicable 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
73 1 for both light and non-light water reactors. It's 2 italicized in that appendix, and then there's non-3 italicized text that's specific to non-light water 4 reactors.
5 Appendix delta, as I indicated previously, 6 that's a listing of some of the draft documents that 7 are under development that could affect future 8 revisions to the ISGs. The reason that the listing in 9 the additional portions of the application is shown on 10 the right of this slide is, that is the general format 11 of the ISG.
12 You'll see the discussion of the first 12 13 chapters, and then you'll see a section on tech specs 14 and it follows the format. For chapter 2, I 15 previously discussed and it's on the slide. It's 16 outside -- the site information and characterization 17 is outside the scope of the LMP process, so chapter 2 18 of the ISG provides guidance on the scope and approach 19 for selecting the external hazards which must be 20 considered in the plant design.
21 The selection of the external hazards is 22 to be informed by probabilistic external hazards 23 analysis once supported by available methods, data, 24 standards, and guides. If that's not available, then 25 additional deterministic analysis is expected to be 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
74 1 used.
2 Chapter 2 does limit the amount of 3 information that needs to be provided in the SAR to 4 that necessary to establish design basis external 5 hazards. Other information we expect would be 6 available by audit in some cases, and supporting 7 things that are on the document.
8 Chapter 2 does refer to existing site 9 evaluation guidance that you find for light water 10 reactors in various reg guides where appropriate, and 11 it is based on the requirements in 10 CFR Part 100 12 sub-part B.
13 Chapter 9 and 10, these again are 14 associated with normal operations. Chapter 9 is for 15 normal effluence, control of routine plant effluence, 16 plant contamination, and solid waste. Chapter 10 is 17 for control of occupational doses.
18 Previously, when we briefed the 19 subcommittee on Chapter 11, which is organization and 20 human interactions, Jesse Seymour provided these 21 overview slides. Jesse is available via Teams to 22 answer any questions, but I'll be doing a Chapter 11 23 overview on this slide and the next.
24 So Chapter 11 covers organization and 25 human systems interactions. Like the other ARCAP 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
75 1 chapters, Chapter 11 provides guidance for both 2 applicants and staff. The chapter draws upon the 3 existing NUREG 0800 standard review plan where 4 appropriate. But where it does, it also adapts the 5 guidance to make it technology-inclusive for non-light 6 water reactor use.
7 A portion of Chapter 11 provides guidance 8 regarding the construction, management, and operating 9 organization in a manner that parallels that of NUREG 10 0800, but does so at a higher level while still 11 covering a similar scope in areas like staffing, 12 training, and qualifications.
13 The chapter also incorporates an 14 underlying assumption that advanced non-light water 15 reactor applicants coming in under 50 -- 10 CFR Parts 16 50 and 52 will need to navigate applicability issues 17 for some regulations, and potential exemptions for 18 others. So this is addressed as relevant within the 19 scope of the guides.
20 A key example is that of licensed operator 21 staffing, where the exemption process of NUREG 1791 is 22 explicitly called out. Importantly, though, there is 23 no treatment of either remote or autonomous operations 24 within the guidance, and in that sense, Chapter 11 25 remains geared towards what would be considered to be 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 1 more traditional concepts of operations.
2 Additionally, a number of lessons learned 3 from both the OL combined license and new scale design 4 certification review processes are incorporated as 5 well. This includes staff takeaways concerning the 6 cold licensing of operators at plants that are under 7 construction. Finally, guidance is also provided for 8 evaluating the adequacy of human factors, 9 considerations within an application as well as 10 whether HFE-related post-Three Mile Island 11 requirements have been appropriately addressed.
12 MEMBER HANLON: Joe, that doesn't preclude 13 an applicant coming in and engaging on remote or 14 autonomous operations. It's just, there's no guidance 15 for it. Correct?
16 MR. SEBROSKY: That's correct. Jesse, did 17 you want to elaborate on that?
18 MR. SEYMOUR: Yeah, Joe. That's a -- this 19 is Jesse Seymour from the operator licensing and human 20 factors branch. You know, you characterized it 21 correctly, and, you know, just to, you know, reiterate 22 that point, you know, applicants can come in and have 23 those engagements with us and talk about, you know, 24 remote and autonomous, you know, potential 25 considerations.
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77 1 Our current stance is that, you know, if 2 we do have those types of outreach, we would, you 3 know, use some of the work that we have done shaping 4 our thinking for Part 53 and elsewhere to inform how 5 we would approach those types of discussions and any 6 potential exemption or request that may come down the 7 pike. But again, we're not explicitly speaking to 8 that.
9 You know, again, this is geared more 10 towards the traditional, you know, locally staffed, 11 right there at the plant concept of operations where 12 the operators are there.
13 MEMBER HANLON: Thanks, Jesse.
14 MR. SEBROSKY: So the last bullet on this 15 slide just notes that the guidance that's in this 16 chapter supplements the licensing modernization 17 project guidance and the TICAP guidance. Jesse, is 18 there anything else on Chapter 11 that you wanted to 19 bring to the committee's attention?
20 MR. SEYMOUR: No, Joe. That covers 21 everything. Thank you.
22 MR. SEBROSKY: Thanks. So I'll move on to 23 Chapter 12. So Chapter 12 is post-manufacturing 24 construction inspection, testing, and analysis 25 program.
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78 1 And it's -- the purpose of this ISG is to 2 demonstrate to the extent possible that the safety-3 related and safety-significant structures, systems, 4 and components were constructed and will operate in 5 accordance with the design and as described in the 6 safety analysis report.
7 Phase 1 guidance in the ISG is associated 8 with pre-fuel load operation and includes program 9 application content that will support making a finding 10 that the constructed plant has met the requirements 11 that will allow an operating license to be issued 12 under 10 CFR Part 50, or fuel to be loaded under 10 13 CFR Part 52.
14 Phase 2 guidance is associated with post-15 fuel load operations and covers initial startup 16 testing up to and including initial power exception 17 testing. The ISG differentiates between Part 52 18 applicants that must include inspections, tests, 19 analysis, and acceptance criteria, or ITAC, and 10 CFR 20 Part 50 applications that are not required to include 21 an ITAC.
22 The requirements that describe pre-23 operational testing and initial operations are found 24 in 10 CFR 5034 B6 triple I which describes information 25 to be included in the final safety analysis report in 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 1 10 CFR 5279 A28 for combined license applicants.
2 The last two bullets on this slide 3 reiterate that the guidances both for pre-operational 4 testing prior to fuel load and initial startup testing 5 after initial fuel load up to and including initial 6 power testing. That's Chapter 12.
7 The next three slides cover the ISGs that 8 are outside the traditional SAR structure. This slide 9 is on the ARCAP ISG associated with in-service 10 inspection and in-service testing. The ARCAP in-11 service inspection and in-service testing interim 12 staff guidance is based on the use of plant-specific 13 probabilistic risk assessment to identify the 14 structures, systems, and components to be included in 15 the programs.
16 The in-service inspection guidance is 17 based on ASME boiling pressure vessel code section 11 18 division 2 for developing the in-service inspection 19 program using risk information and an expert panel.
20 And in ASME boiler pressure vessel code section 3 21 division 5 are designs using high-temperature 22 materials.
23 The ISG notes that the ASME is developing 24 a code case for flaw evaluation for high-temperature 25 materials, and until the code case is issued and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 1 approved by the NRC, an applicant should provide 2 appropriate justification for flaw evaluation 3 acceptance criteria for any components in which the 4 temperature exceeds the temperature limits on the 5 approved ASME.
6 On slide 30, which discusses the in-7 service testing portion of the ISG, the in-service 8 testing guidance is based on existing in-service 9 testing program approach with additional guidance for 10 passive components. The ISG notes that ASME is 11 developing the OM 2 code that will provide high-level 12 requirements for in-service testing activities for 13 non-light water reactors.
14 Like the in-service inspection guidance, 15 the guidance relies on client's specific risk 16 information to determine the scope of the in-service 17 testing program and proposed testing frequencies.
18 The next slide is the ISG associated with 19 technical specifications. The reason we developed the 20 ISG is the text in 10 CFR 56, regulations for tech 21 specs contents, needs to be adapted to correlate to 22 the analysis and outputs of the risk-informed 23 licensing modernization project approach described in 24 NEI 1804.
25 The guidance addresses contents -- content 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 1 for tech spec administrative control sections and 2 provides a recommended tech spec format. This is the 3 last slide for the ISGs, and it's associated with fire 4 protection for operations.
5 The staff developed the ARCAP ISG for fire 6 protection for operations to provide guidance for non-7 light water reactors. Fire protection for the design 8 for non-light water reactors is covered by a 9 combination of the ARCAP roadmap ISG and the TICAP 10 guidance.
11 Although NFPA 805 does not apply to non-12 light water reactors, the concepts associated with the 13 risk-informed approach are captured in the ISG. The 14 elements in the ISG include management, policy, and 15 program direction and the responsibility of those 16 individuals responsible for the program implementation 17 and the integrated combination of procedures and 18 personnel that will implement the fire protection 19 program activities. So with that slide, that ends the 20 presentation.
21 MEMBER HANLON: Joe, I had one last 22 question on the tech spec. The way your word was on 23 there made me think of a new question, and today's --
24 well, by the nature of tech specs, they're 25 deterministic and that's what the operators need to 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 1 use to determine whether they're in or out of the 2 allowed operating envelopes.
3 But the industry has developed two, that 4 I know of, risk-informed tech spec approaches with 5 completion times and surveillance intervals. This --
6 is that reflected? I don't know the answer to it. Is 7 that reflected in those risk-informed methods of 8 applying tech specs? Is that reflected in this new 9 regime?
10 MR. SEBROSKY: So we don't specifically 11 call out those initiatives in the ISG. And I'll look 12 to Rob Elliot, who's in the room. If I 13 mischaracterize anything, he's the person who helped 14 us with the tech specs.
15 What it does, it doesn't go into that 16 level of detail. What it does, is when you look at 17 the 5036 criteria and you try to use that criteria on 18 an LMP-based project, it doesn't match. So what you 19 see in the guidance is essentially tables that say, 20 here's the 5036 criteria, and it repeats it. And 21 it'll say in the right-hand column, this is the output 22 from the LMP that you can use to address that portion 23 of tech specs. So it's at a higher level than --
24 MEMBER HANLON: Okay.
25 MR. SEBROSKY: -- those initiatives that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 1 you were discussing. And -- Rob, is there anything 2 else?
3 MR. ELLIOTT: -- my microphone here.
4 MR. SEBROSKY: So that green --
5 MR. ELLIOT: Yeah, so as Joe says, it 6 addresses the criteria for establishing what needs to 7 be LCOs, how you would also apply the LMP guidance for 8 safety limits, and going over safety system settings.
9 It encourages use of a similar format and content as 10 the standard tech specs, which means that risk-11 informed completion times and risk-informed frequency 12 control programs would be available to the licensee to 13 utilize, same as it would for any other programmatic 14 element. And there are other risk-informed 15 improvements that have been made and are continuing to 16 be made, you know, or we're working on today, such as 17 risk-informed improvements to LCO 303.
18 MEMBER HANLON: Okay. So like my previous 19 comment, it doesn't preclude them coming in and 20 saying, this is how I want to apply tech specs in a 21 risk-informed way, and it provides -- does provide 22 adequate guidance for the staff to not, you know, 23 reject it but to actually take a hard look at it, that 24 maybe it's a good approach.
25 MR. ELLIOTT: Yeah, it does not.
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84 1 MEMBER HANLON: Okay.
2 MR. ELLIOT: Typically with tech specs, 3 though, you're right. The deterministic aspect of it 4 is operability, right?
5 MEMBER HANLON: Right.
6 MR. ELLIOTT: And operability is not risk-7 informed. Operability either -- it can perform a 8 safety function or it cannot. But as far as 9 determining what the content of the tech specs are, 10 that can be risk-informed.
11 MEMBER HANLON: Okay. I just want to make 12 sure that we weren't ignoring the improvements we've 13 made in the risk-informed approach to the tech specs 14 previously. And I wasn't -- ignoring is a strong 15 word. But, I mean, maybe in round of --
16 MR. ELLIOTT: Those options are made 17 available to the applicant.
18 MEMBER HANLON: Okay. Thanks. I 19 appreciate it. Thanks, Rob.
20 MEMBER PETTI: Could we get that repeated 21 for the court reporter?
22 MR. ELLIOTT: Rob Elliott of the tech spec 23 branch. Rob Elliott of the tech spec branch. That 24 ends our presentation.
25 MEMBER PETTI: Okay. Yeah, thank you. At 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
85 1 this point, I'm thinking that we've been at this for 2 two hours, and maybe we ought to take a break and then 3 we can come back and have a discussion among the 4 members and the next steps.
5 CHAIR REMPE: Dave?
6 MEMBER PETTI: Yeah? Or do you want to go 7 for public comment, I guess?
8 CHAIR REMPE: I'd go for public comment 9 first --
10 MEMBER PETTI: Yeah.
11 CHAIR REMPE: -- and then I think I need 12 to let the court reporter go. Are you going to 13 present the letter, or do you have in your mind you 14 want to have some discussion before you present the 15 letter?
16 MEMBER PETTI: No. I mean, I'm ready to 17 present the letter. I'm actually making some changes 18 right now based on some really good comments I heard, 19 some ideas, so --
20 CHAIR REMPE: Okay. So anyway, let's go 21 ahead and do public comment --
22 MEMBER DIMITRIJEVIC: The first case, if 23 you guys are not going to have a discussion, I just 24 want to add something in this moment, which was part 25 of discussion during this meeting. And because under 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 1 something which Jose said, that this was academic, I 2 just want to make sure that we understand how much 3 scope of the PRA is going to change.
4 Because in the minimalist PRA, we are not 5 going to have a different plant operating state. We 6 are not going to have an internal flood. We are not 7 going to have internal fire. We are not going to have 8 a seismic -- any other hazards, high winds, external 9 flooding.
10 So all of those things will be added in 11 the later stage, and that will totally change the 12 scope of the PRA and also risk profile. So it's not 13 just about design. Design can stay totally the same 14 as in CP phase. It's the scope of the PRA that will 15 change, and I can explain if anybody has a question, 16 why those things are not likely to be part of the CP 17 because that agreement is not layout, cable send 18 layout, there is no shutdown schedule, things like 19 that.
20 So it is when the scope totally change, 21 risk profile is totally going to change. And 22 therefore, risk information is going to change. I 23 just wanted to add this for the benefit of the members 24 to keep that in mind.
25 MEMBER PETTI: Okay. Thank you, Vesna.
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87 1 Let's do public comment. Anybody wishing to make a 2 comment, please unmute yourself, identify your name 3 and your organization and your comment. I don't see 4 anything. Does anybody in the room see anything?
5 CHAIR REMPE: No.
6 MEMBER PETTI: Okay. Then I recommend we 7 take a 15-minute break and move to --
8 CHAIR REMPE: Before we do that --
9 MEMBER PETTI: Yeah.
10 CHAIR REMPE: Before we do that, first of 11 all, I'd like to ask -- tell the court reporter we're 12 done for the time period and to please come back at 13 1:00 p.m., okay? Thank you. And then I agree with 14 your suggestion, Dave. Let's do -- because you did 15 say you have a couple of changes. Do you think 15 16 minutes is enough, or you want to --
17 MEMBER PETTI: Absolutely. Absolutely.
18 No. I can do it in 15.
19 CHAIR REMPE: Okay. So if I do my math 20 correctly, that means we'll come back at 10 till 11:00 21 on the east coast. Does that sound right to 22 everybody? Okay. Thank you. We're going to be 23 recessed, then.
24 (Whereupon, the above-entitled matter went 25 off the record at 10:35 a.m. and resumed at 1:00 p.m.)
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88 1 CHAIR REMPE: Okay, I have it's 1:00 p.m.
2 on the East Coast and we're back in session. And I'd 3 like to ask Member Ballinger to lead us through the 4 NMSS topic.
5 MEMBER BALLINGER: Thank you, Madam Chair.
6 I'm violating my own rules. Thank you, Madam 7 Chairman. Today's presentation is a bit of a shrunk 8 version of the same presentation, which we had at a 9 subcommittee meeting. And so we requested that we 10 have this presentation after which we'll have 11 deliberations on whether or not we decide to write a 12 letter as a committee. We have a draft of a draft, 13 which is available. Which if we decide to do so, 14 we'll go into that afterwards. So with that, Shana, 15 are you ready? Do you want to make a few words?
16 MS. HELTON: Yes, thank you. So thank you 17 for the opportunity to be here today to present before 18 the full committee. As you said, this is going to 19 give the members an update essentially from the 20 November 17th subcommittee that we had on this same 21 topic. And just would like to note a couple things.
22 This is for one, a very high priority project for 23 NMSS. As we continue fulfilling our regulatory role 24 of ensuring that advanced technologies are maybe used 25 safely and securely.
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89 1 And I want to just extend a thanks to 2 everybody whose at the table for this meeting, 3 including Jeff Waksman from the Strategic Capabilities 4 Office, Harold Adkins, Steve Maheras, and Garill Coles 5 from the Pacific Northwest National Laboratory. Of 6 course, Bernie is at the table and behind me we have 7 Brian Wagner, Tim McCartin, Jonathan Marcano from the 8 NRC all with a great deal of expertise who will 9 contribute to a good discussion today. I'd also like 10 to note that Steve Short and Peter Lowry from PNNL and 11 Virgil Peoples from INL supported the subcommittee 12 meeting and will be in attendance through Teams for 13 this meeting today.
14 So those are the folks in the room and 15 supporting online. There have been many other staff 16 across the NRC and NMSS, NRR, and NSER who've been 17 involved, as well as staff from the U.S. Department of 18 Transportation. And they all deserve a lot of credit 19 for supporting our evaluation of the risk methodology 20 that you'll hear about today.
21 So we appreciate the views that ACRS has 22 on this matter. After the subcommittee, we went back 23 and talked through what we heard. And our goal today 24 is to be responsive to some of the views that we heard 25 back on November 17th and answer any questions that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
90 1 the full committee might have. So thanks again for 2 the opportunity. And as you know from Dr. Ballinger, 3 this is shorter than we had on the 17th. I'll stop 4 there and turn it over. Thank you.
5 MEMBER BALLINGER: Two things, I'm remiss.
6 For the Court Reporter, the person speaking was Shana 7 Helton. And do we need to identify those members that 8 are conflicted?
9 FEMALE SPEAKER: Yes.
10 MEMBER BALLINGER: And that would be Bob 11 Martin and --
12 FEMALE SPEAKER: Dave Petti.
13 MEMBER BALLINGER: -- Dave Petti. Okay.
14 Dave's -- So those are the two that are conflicted.
15 So what that means is that any deliberations that we 16 do, they can't participate in. So with that, is it 17 Jeff that's going do the -- do the deed?
18 MR. WAKSMAN: Yes. Again, I just want to 19 thank everyone for coming together today. You know, 20 I do think that this is going to be important. I 21 don't know what my opinion is worth, but I do think 22 that the short-term path forward for advanced reactors 23 is going to be micro-reactors. I think they're more 24 forgiving from a regulatory perspective. And I think 25 their cost is low enough that you can get to an nth of 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 1 a kind on them and get that learning and be able to --
2 be able to make this happen. But admittedly, I think 3 a lot of the micro-reactor developers have a hand wavy 4 approach to how they're actually going to move these 5 things in the real world. And that's really what 6 we're here to do is to make it actually rigorous. You 7 know, how do we actually regulate actual micro-8 reactors in the real world?
9 So obviously a lot of appreciation for my 10 team at PNNL and that works at PNNL, as well as, you 11 know, the NRC team and Bernie and Shana and everybody 12 else. And so that said, I'm going to evacuate this 13 table for someone smart enough to answer any technical 14 questions and I'll be sitting over there in case 15 anybody needs me.
16 CHAIR REMPE: Folks online say they can't 17 hear. And both of the -- all the three indicators I 18 have say they should be.
19 MR. BURKHART: This is Larry Burkhart.
20 Can someone online verify if you can hear us or not?
21 (simultaneous speaking) 22 CHAIR REMPE: Sorry for the interruption.
23 MR. WAKSMAN: Can I get an audio check for 24 my mic?
25 (simultaneous speaking)
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92 1 MR. WAKSMAN: So as I was saying, I'll be 2 over in that part of the room. And I'm going to let 3 the folks at the table who can answer the technical 4 questions, take their place here. So thank you and 5 look forward to a good discussion.
6 MR. BLEY: This is Dennis Bley. May I ask 7 you a quick one? It's not technical. You made a 8 strong statement about the low cost of the micro-9 reactors and I guess I wouldn't challenge that on a 10 per plant basis. How about on a per megawatt basis?
11 Do you have any basis for saying it's a lower cost 12 option?
13 MR. WAKSMAN: Well, this is just my 14 opinion and I'm not trying to speak for the industry 15 here. I think everybody would agree that on a per 16 megawatt basis, micro-reactors are going to be more 17 expensive than larger reactors. But the idea is that 18 the capital cost to get to a unit in taxi, get 19 electricity production is what would in raw dollars be 20 less. From my position, you'd hope so. So I don't 21 believe, you know, my position that the federal 22 government is going to go and purchase ten AP-1000s 23 any time soon. But they could purchase ten micro-24 reactors. That could be budgeted. So that's why I 25 think we could get to nth of a kind and get that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
93 1 learning in the same way that in the space world where 2 I used to work at NASA, you know, space (inaudible) 3 we're building enough rockets that they get the 4 learning that a rocket that launches once every two 5 years will never get. But that's just my opinion with 6 all the standard caveats. I don't speak for the 7 Department of Defense when I make statements like 8 that. Does that answer your question?
9 MR. BLEY: That's what I expected.
10 Thanks.
11 MR. ADKINS: This is Harold Adkins. I'd 12 like to thank the ACRS for having us back to discuss 13 the risk-informed licensing methodology. Next slide 14 please. One of the things that we're going to do 15 today is in the interest of time, move very quickly 16 through the front matter because it's merely close to 17 a repeat of what we presented previously. And we want 18 to get to trying to answer the ACRS's questions that 19 they had for us a little more completely than last 20 time.
21 Again, to provide some background 22 information. The purpose is to propose this risk-23 informed regulatory approach for the transportation of 24 transportable nuclear power plants in support of an 25 NRC draft safety evaluation. I'm going to give a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
94 1 brief description, but we'll skip through that very 2 quickly -- briskly. And then a description of 3 proposed risk-informed regulatory pathway, overview of 4 proposed risk evaluation guidelines very brief, 5 discussion some quantitative risk assessment process 6 details and the fact that we're leveraging PRA defense 7 in depth and safety margin to return back to an 8 equivalent safety set. And then go through some minor 9 example results. And then we'll get to brief 10 clarification response to questions that the ACRS 11 raised on November 17th.
12 Next slide please. One of the things that 13 I want to warn you here real quickly, this slide image 14 on the right is merely a cartoon. Okay? And one of 15 the things that we're going to provide a little more 16 detail to is what the conveyance would look like and 17 all the rigor that goes into a standard transport 18 versus what you see as basically a slightly overweight 19 transport that's depicted here.
20 You know, just to recap, many of the 21 advanced reactor vendors are developing TNPPs to make 22 higher density energy readily available for DoD 23 applications, HADR, and also clean zero carbon energy 24 for a variety of austere and off-grid locations. And 25 the main objective here is these TNPP inventions would 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 1 be factory produced, fueled, acceptance tested, and 2 deployed as sealed units. And the main thing that 3 we're focusing on is the post-use transport, which 4 would provide the highest radionuclide inventory. And 5 that would largely be held up in the reactor module.
6 So when I use the acronym TNPP, what we're 7 referring to is the reactor module because that would 8 likely still present the same issue if you were able 9 to transport the whole plant. And the example that we 10 use is Project Pele.
11 Next slide please. So just to go back 12 through the risks -- the need for risk-informed 13 regulatory approach. Right now, the intent and the 14 understanding is that this risk-informed evaluation 15 approach would only apply to hypothetical accident 16 conditions. There's always the intent to be able to 17 meet the performance requirements that would be 18 associated with the normal conditions of transport.
19 And what I'm referring to is the sequential 30-foot 20 drop, crush, puncture, free drop, 30 minute engulfing 21 fire, things of that nature.
22 And what we plan on doing is -- and what 23 we're proposing is leveraging compensatory measures, 24 defense-in-depth, and a philosophy to establish 25 equivalent safety back to the state that the codified 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 1 regulatory requirements would lead us to. And also 2 this only applies to a TRISO-fueled reactor similar to 3 the demonstration item that we identified that we're 4 interested in possibly licensing for transport in the 5 future.
6 And one last clarification is for the time 7 being as Jeff stated on our previous interaction that 8 there is no intent at this time at all to transport 9 Pele off site from the INL reservation. As we've also 10 discussed, one of the things that we're looking at 11 right now is the best possible pathway is through 10 12 CFR 71.12, which is an exemption process. And that 13 isn't to take all of the requirements off the table.
14 is to meet largely all the requirements with the 15 exception of maybe one or two that were heavily 16 challenged based on the state of the reactor design 17 and where the codified regulatory requirements apply 18 to thick wall pressure vessels and the gap that is 19 provided by those too until they come together over 20 time when the regulatory requirements possibly change 21 in how they consider TNPPs more in line with how 22 they're defined.
23 I think it went into the exemption 24 process, what we prefer and then the associated idea 25 that we're conveying here with the exception. There 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 1 are some other opportunities. We could leverage a 2 special packaging authorization, but that would only 3 give you a one-time shipment. And we're talking about 4 a single time per year shipment -- two shipments 5 total.
6 Next slide please. So reasoning behind 7 the selection of this regulatory approval pathway is 8 that PRAs have been used and utilized all the way from 9 the 70s for nuclear reactor licensing, WASH-1400 gives 10 quite a bit of detail. Not the 70's, I apologize, it 11 was proposed in the 70s, but has been used since the 12 2000s to apply risk-informed licensing applications.
13 PRA has also been used to assess dry cast storage and 14 transportation. And one final thing to note is that 15 risks of transportings to the nuclear field at Yucca 16 Mountain repository by truck and rail. What was 17 proposed in that is exactly what we're discussing 18 today and the implications associated with what would 19 happen over that transit duration and things of that 20 nature in the exact some way.
21 We're proposing this to the NRC to aid in 22 the development in the near term per approval pathway 23 to drive advanced factory-produced TNPP development 24 and deployment. And also to bridge the gap between 25 the framework -- the current regulatory framework that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 1 exists around thick wall pressure vessels and current 2 TNPP technology until the codified regulatory 3 requirements if there's a need to change would more so 4 accommodate TNPPs or at least the technology would 5 grow and refine to the extent that it would meet all 6 those codified regulatory requirements. This would 7 also provide some buffer time for strategic regulatory 8 considerations and possible rule making in the future 9 if that's needed.
10 Next slide. I'd like to hand this over to 11 Garrill Coles, my colleague.
12 MR. COLES: Thanks, Harold. I'm going to 13 do the next four or five slides on the risk-informed 14 process itself. Really high overview. So we contend 15 -- PNL contends the demonstration of acceptable risks 16 if an exemption process is used as indicated by 17 Harold, will require a quantitative risk assessment 18 given possible complexities and uncertainties about 19 the package performance potential risk to the public.
20 And the fact is this will a first of a kind endeavor.
21 The PRA provides such a rigorous quantitative approach 22 concerning risk evaluation guidelines, assessment 23 using PRA worked best when supported by guidelines 24 about acceptable risk because that provides a key 25 basis for risk-informed decision making. However, 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
99 1 regulatory risk evaluation guidelines using PRA do not 2 exist for transportation packages like they do for 3 cited nuclear power plants.
4 That said, risk-informed decision making 5 guidance is proposed for nuclear material and waste 6 applications in a 2008 NRC report referred to in this 7 presentation as a 2008 RIDM -- risk-informed decision 8 making report. This guidance included proposed 9 quantitative health guidelines developed from the NRC 10 safety policy statement. But this approach has not 11 been endorsed for use by NRC for transportation.
12 Next slide. However, PNLL proposes 13 surrogate measures for the qualitative health 14 guidelines proposed in the RIDM report. In the same 15 way that core damage frequency and large earlier 16 release fractions are used instead of health effects 17 are risk-informed advocations for the current fleet of 18 nuclear power plants as justified in NRC NUREG 1.200.
19 Specifically PNL proposes formulating goals in terms 20 of pairs of radiological dose and lack and limits to 21 individual receptors.
22 (audio interference) 23 MR. COLES: So you know, frequency is a 24 likelihood measure. That's the most direct way in 25 this case. And using the examples where we derive the 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 1 pairs from, those were all done, including the LMP 2 sample, they used the frequency. This is a common way 3 and that's what's used currently for the current --
4 MEMBER MARCH-LEUBA: Well, that is applied 5 to us, visionary reactor to a person living in the --
6 on the boundary, which is leaving them a whole year.
7 Whereas this reactor is moving through my house. And 8 then it spends a minute in front of my house. Think 9 about it because these units don't make sense to me.
10 MR. COLES: Okay. I'm not sure what the 11 question is.
12 MEMBER DIMITRIJEVIC: Hi. This is Vesna 13 Dimitrijevic. I just wanted to add something that 14 Jose completely right. You have mixed a little here.
15 It's a different event sequence frequency because that 16 includes both likelihood and frequency. When you say 17 active, then frequency, you know, frequency can be 18 bigger than one because you can have more than two 19 events or three events per the year. So you have to 20 really define what do you mean by this. And I mean 21 having that for transport, then it would be, you know, 22 what is the probability of having accident by 23 transport. What would, you know, correspond to this 24 number by active -- Frequency is not the likelihood.
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101 1 you know, -- Likelihood includes probably to get them 2 with frequency. So you know, as I said, frequency can 3 be bigger than one, you know, because it defines the 4 number of the events. So you have to actually re-5 define your Y axis.
6 MR. COLES: So what I heard you say was 7 using frequency, you could have frequencies greater 8 than one. If you look at the current slide, you'll 9 see that these frequencies are quite low. So these 10 are very rare events. The use of the language up 11 here, probabilistic risk assessment that we're talking 12 about. So we don't entertain -- If we thought we 13 could have an event that was close to one, we would --
14 that's a nonstarter. We would never do a transfer.
15 Right?
16 (simultaneous speaking) 17 MEMBER DIMITRIJEVIC: -- after the event 18 is something which, you know, defines event and then 19 probability that you will have a release in this case 20 when you're talking about. So that mix of dustings is 21 the small, but just probability that you will have, 22 you know, traffic accident or something, those numbers 23 -- those are the event numbers. That's what I'm 24 trying to tell you, which means you're going to have 25 an event, which causes the sequence of events. You NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
102 1 know, how the package responds to those events. And 2 those probabilities are rather small, you know?
3 MR. COLES: I'll just repeat, right, that 4 for the current fleet of nuclear power plants, this 5 metric of frequency, core damaged frequency is the 6 primary risk metric that's used in risk-informed 7 applications currently. And in this discipline of 8 probabilistic risk assessment, the use of frequency is 9 the most common metric -- likelihood metric that's 10 used.
11 MEMBER DIMITRIJEVIC: Yes. Okay, so this 12 is very good. I can explain to you what I'm trying to 13 say on core damage frequency. Core damage frequency 14 is caused by a bunch of events. You know, one of the 15 events could be just regular (indiscernible due to 16 accent) and frequency of (indiscernible due to accent) 17 per the air could be bigger than months for the year.
18 Then the question is how do systems respond? So if 19 you have a (indiscernible due to accent), which of 20 course let's say 1.2 times per year, as long as you 21 have it worked out for PWR and everything else looks 22 fine, probability of systems failing is small. So 23 this is not an event itself. It's event sequence.
24 It's event (indiscernible due to accent) respond to 25 mitigating systems.
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103 1 MR. COLES: I don't think I have an 2 argument with anything you've said just now.
3 MEMBER DIMITRIJEVIC: But when you say 4 "accident", what is that? When you say "accident 5 frequency", what do you consider accident?
6 (simultaneous speaking) 7 MEMBER DIMITRIJEVIC: -- then like direct 8 fire or how did the package respond to that? What is 9 the accident?
10 MR. COLES: So to use your explanation, 11 when I said "accident frequency", we meant to refer to 12 the entire scenario, whatever that is. Now unlike 13 nuclear power plants where there's mitigating systems 14 and you know, to provide some measure of protection 15 against an initiating event, road accidents -- there 16 really isn't any mitigating systems. So the 17 initiating event generally determines the likelihood 18 of the entire accident scenario. So when I say 19 "accident frequency", I do mean the entire scenario if 20 that helps.
21 MEMBER DIMITRIJEVIC: Right. So you can 22 call it "accident sequence frequency", that would be 23 more accurate. But then the Jose points happens. If 24 you're only transporting this once in three years, 25 right, then do you consider this in this initial think 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
104 1 tank process response? See, it's not really clear 2 when you say "once per year". And how many units you 3 do per year? It's different than when you have a 4 standard unit. You know? So I had to look in the 5 (indiscernible due to accent) to see how you can 6 define this more precisely when it comes to the units.
7 I mean, you know, is this per transport or based on 8 the number of transports you have per year?
9 MEMBER BALLINGER: Can I propose a 10 metallurgical get out of jail free card? You're only 11 going to transport it once per year.
12 MALE SPEAKER: That's right.
13 MEMBER BALLINGER: So in effect, that 14 scale on the left can be --
15 MALE SPEAKER: Precisely.
16 MEMBER BALLINGER: -- per transport if 17 it's only one --
18 MALE SPEAKER: Precisely.
19 MEMBER BALLINGER: -- and then a little 20 note on the bottom that says oh, by the way, if you're 21 more than one, does it just scale or am I way out of 22 -- way out of bounds? I need to get Vicki's and 23 Vesna's --
24 VICE CHAIR KIRCHNER: It depends on the 25 transport route, among other things --
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105 1 MEMBER BALLINGER: Yeah.
2 VICE CHAIR KIRCHNER: -- because it's a 3 moving --
4 MEMBER BALLINGER: Yeah, yeah.
5 VICE CHAIR KIRCHNER: -- source term. But 6 I think -- I guess the way I was looking at it, Jose 7 told us that this is per accident frequency per 8 transport.
9 CHAIR REMPE: It's per year per transport.
10 I think they actually did some calculations to say 11 this is the frequency per year, but they assumed a --
12 (simultaneous speaking) 13 CHAIR REMPE: Yeah, but if they have four 14 of them going to different locations, it would be 15 four. So you need to change the Y axis to say per 16 transport per year or per year per transport. It's up 17 to you. But I think that's what you need on this 18 graph and it would avoid this problem. Right?
19 MEMBER BALLINGER: It's really a simple 20 fix by just changing the scale.
21 MEMBER BIER: I mean a couple of comments.
22 First of all, there still are mitigating features 23 because the cask itself is a mitigating feature. It's 24 not like every time the truck rolls off the side of 25 the road, you automatically have a disaster. And you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
106 1 know, but also like following up on Vesna's point, if 2 you're doing a PRA for a stationary power plant, you 3 may eventually have the results in terms of frequency 4 per year, but you have different events that are 5 measured in different ways. So the likelihood of a 6 pump failing to start is per time you ask it to start, 7 not per hour or per year. So anyway, I don't think 8 it's a huge issue in terms of the methodology, but I 9 think it should be clarified just for explanation.
10 MR. COLES: Thank you. This slide shows 11 our process using PRA. The primary difference between 12 our process a conventional PRA, and that would be used 13 for reactors for example, is that we use the accident 14 development process to select and define what we call 15 bounding representative accidents. These are 16 accidents that are similar nominalogically. We add 17 the frequency of each of those accident scenarios and 18 we use the worse case consequences of the accidents in 19 that group. So the bounding representative accidents, 20 so truly (audio interference) 21 MEMBER BIER: Quick clarification. When 22 you look at the frequency of that bounding accident or 23 whatever the arm, I guess is representative -- not 24 reactor -- the bounding representative accident, is 25 the frequency of that exact event or all of the events 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 1 bounded by that event?
2 MR. COLES: So it's all the events in the 3 group, you know, so we actually add them together.
4 MEMBER BIER: Okay.
5 MR. COLES: I'm not going to go through 6 the steps. The primary steps, right, are 7 identification of the accident sequences. You see, I 8 used the word "accident scenarios" there on the slide.
9 And then, you know, we determine the likelihood of 10 those bounding representative accidents. And the 11 consequences are an important part of this analysis 12 also to perform -- any PRA is to perform an 13 uncertainty analysis. And in this case, we performed 14 quite a few sensitivity studies because of certain 15 modeling assumptions.
16 MEMBER MARCH-LEUBA: How do you develop 17 the likelihood on number five? Is the proposal here 18 or do you look at the number of (audio interference) 19 MR. COLES: There's kind of two kinds of 20 uncertainty. One is what we call parametric 21 uncertainty. That has to do with data. Another kind 22 of uncertain is what we call model uncertainty. It 23 has to do with our uncertainty about assumptions we 24 make. So we looked at both of those things. Each 25 element of the PRA, we made a quite long list of all 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 1 the assumptions and bases -- assumptions that were 2 made to perform for example identification of access 3 or determination of consequences. And we examined 4 each of those in turn and we performed sensitivity 5 studies where we thought that a different assumption 6 could produce a different result.
7 For the kind of uncertainty that we call 8 parametric uncertainty, has to do with data. So we 9 did the best that we could with the data available.
10 But there's not as much -- This is sort of a new 11 endeavor. There's not a lot of road data. But to the 12 extent we could, we kind of did a hybrid uncertainty 13 analysis where we tried to understand the variability.
14 Right? There's some variability state to state and 15 year to year, an actual rate -- accident crash rate 16 can go up or down a little bit.
17 MEMBER MARCH-LEUBA: You need the 18 Department of Transportation statistics of how many 19 miles of track in a year and how many accidents 20 happen. I mean it will depend on the type of accident 21 because everybody's had a fender bender. I don't know 22 anybody that (indiscernible due to accent).
23 MR. COLES: I have to indicate that we did 24 use GIS and all kinds of other like in the previous 25 slide set --
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109 1 (simultaneous speaking) 2 MEMBER MARCH-LEUBA: The Court Reporter is 3 going to try to say mumbo jumbo.
4 MALE SPEAKER: Okay. Got you.
5 MR. MAHERAS: We're going to talk about 6 this more on Slide No. 12, but we did use -- we did 7 use Department of Transportation vehicle accident rate 8 data as the starting point in the analysis.
9 MEMBER BALLINGER: Excuse me. You need to 10 state your name for the Court Reporter.
11 MR. ADKINS: That was Steve Maheras.
12 MR. MAHERAS: Thank you, Harold. And that 13 rate is composed of two parts. Right? The first part 14 is the number of accidents that take place. But I 15 also need the mileage traveled for the class of trucks 16 that I'm interested in analyzing. It would be 17 inappropriate to take the number of accidents for 18 trucks and divide it by passenger car mileage for 19 example. So I need a --
20 (simultaneous speaking) 21 MR. MAHERAS: Yeah. And the type of --
22 MEMBER MARCH-LEUBA: On 495, there's an 23 accident every day.
24 MR. MAHERAS: Right. Exactly right.
25 Exactly right. Now I will say though -- I will say 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 1 though that the Department of Transportation only 2 reports in distinct functional road types. So 3 interstates, highways, et cetera. So we get what we 4 get in terms of our accident rate data.
5 MEMBER MARCH-LEUBA: So basically there is 6 a -- You can just define the number of years. You may 7 not be able to assign an uncertainty with much vigor, 8 but you can just define.
9 MR. MAHERAS: Yes.
10 MR. WAKSMAN: By the way, Steve, wasn't it 11 a point that you made last time that folks who drive 12 these sorts of trucks, these are special permitted 13 drivers and generally safer -- you would be avoiding 14 particularly difficult routes. So while there's 15 uncertainty, these could be viewed as almost like a 16 bounding. The real frequency would be probably less.
17 MR. MAHERAS: Well, yes, Jeff. We've been 18 doing an examination of the number of accident for 19 these very large trucks. And it looks to us based on 20 data that we just got from our DOT colleagues that 21 these very large trucks encompass about 0.6 percent of 22 the total number of accidents. Now that's the good 23 news. Right? The bad news is that DOT does not 24 collect data for these very large trucks anymore.
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111 1 they gave us what they had, but what they had is a 2 little bit dated in nature.
3 We also talked to the Canadians about what 4 they do with their accident rate data. And they also 5 collect data for trucks of 26,000 pounds and higher 6 and Pele would be a truck of about 150,000 pounds. So 7 there's a difference here. Right? And we're limited 8 by the data that's collected by the agencies.
9 MEMBER BALLINGER: I wonder why the 23,000 10 or 26,000 because the standard tractor trailer is --
11 the limit is about -- usually about 60,000 pounds for 12 the kind you see on the road. And when you get above 13 that, the permitting, I just spent an extra 3-1/2 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> coming back from Syracuse to Boston following a 15 large load. It took up three lanes with police cars 16 and had a backup behind it about 12 miles long because 17 of the restrictions that they had to have on these 18 very large loads. So if they got in an accident, it 19 would have been, I don't know what.
20 MR. MAHERAS: Right. I mean we've all 21 seen these very large loads. A typical semi, about 70 22 feet tall including the tractor and the trailer. Our 23 load would be closer to about 94 feet long, including 24 the trailer, the tractor, and the stinger on the end.
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112 1 pounds. A semi, five axels usually. Ours, nine 2 axels. So there are some important distinctions that 3 need to be made between what our load would look like 4 and a regular semi that goes down the highway would 5 look like.
6 MR. COLES: Actually, Steve has a slide 7 that he's going to go into in a lot of detail a little 8 bit later. So maybe we can just go onto the next 9 slide and we'll get to Steve's slide in a minute.
10 I just wanted to show you again, a summary 11 of the demonstration PRA risk results against the 12 proposed risk evaluation guidelines. We see that 13 there's just one BRA -- bounding representative 14 accident that falls above the line. This is what we 15 call hard impact road accident that leads to release 16 of radioactive material and degraded shielding. It's 17 defined by collision with a very heavy vehicle with 18 unyielding objects like bridge abutments. And there 19 was a lot of detail in the datasets to understand what 20 the crash involved. And so we were able to parse 21 those into objects that were heavy and objects that 22 were light.
23 Next slide. So this is where we start our 24 discussion of followup issues from the last meeting.
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113 1 that was brought up was this concern of edge effects, 2 which is something that is discussed in our report.
3 That was Tom maybe. Yeah. So one possible example of 4 a cliff edge effect is -- in PNNLs opinion is 5 criticality because it occurs at least in our 6 demonstration at very low frequencies, less than five 7 _ per year. But it could produce a proportionately 8 greater dose than other kinds of accidents. Because 9 other kinds of accidents, we're damaging the 10 containment and we're releasing a certain amount of 11 material.
12 In this case, we have a completely 13 different phenomenon. We have criticality. So what 14 we say in the report was found to be acceptable 15 because of its low likelihood using our risk 16 evaluation guidelines. It really should be 17 investigated further because of this effect. Other 18 factors -- We did examine other factors. We didn't 19 identify anything else that we thought represented a 20 cliff edge effect. We did keep good track of all of 21 our assumptions. But that's something that an actual 22 application would have to think about -- take into 23 account.
24 The second issue is --
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114 1 just said. So you're saying that the criticality 2 would no longer be considered acceptable based on 3 probability because of the cliff edge effect 4 assessment or you'd have to think about it some more?
5 MR. COLES: In an actual application, 6 we're saying that even though -- even though it's low 7 enough that we would find it acceptable using our 8 proposed risk evaluation guidelines, the applicant 9 should still take a look at cliff edge effects. And 10 we're suggesting this might be an example of that 11 criticality.
12 MR. MAHERAS: Yeah. And I think you --
13 How do we understand by what you mean by you would 14 consider it acceptable? And it seems like you're 15 saying you would consider it to have met a risk 16 metric, but because the risk-informed approach 17 requires more than just meeting numeric metrics, you 18 would not consider it acceptable subject to additional 19 evaluation that might bring it into acceptability 20 based on some other analysis. I think that's kind of 21 what I'm getting to.
22 MR. COLES: You said that really well, 23 better than I did.
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115 1 advice on what they should have in their safety 2 evaluation. I'm hearing you're thinking about making 3 some changes with that graph, putting "per transport".
4 With this adding some additional text, what is your 5 plan? I mean it's really not our purview to be 6 advising PNNL, what to do with their report. But 7 what's going to happen on this? I mean this seems 8 like the best approach is for the staff to recommend 9 some changes, then you guys do whatever.
10 MR. COLES: So if I understand the 11 question, you said do we have plans to change the risk 12 evaluation guidelines? No. We do have a slide to 13 show you in total what needs to be considered in an 14 application. And if we haven't answered your question 15 then -- I think we intend to answer your question in 16 that slide.
17 CHAIR REMPE: Yeah. Okay. So --
18 MR. COLES: But we're not going to change 19 the guidelines.
20 (simultaneous speaking) 21 CHAIR REMPE: Maybe an applicant will see 22 this slide to ACRS sometime in the future. But our 23 best pathway is to provide the staff guidance on what 24 they should put in their evaluation of this report is 25 the point I'm trying to make here because we really 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 1 have no purview for --
2 (simultaneous speaking) 3 MEMBER BALLINGER: With any letter that we 4 would write would feed back to PNNL through the staff 5 --
6 CHAIR REMPE: Absolutely.
7 MEMBER BALLINGER: -- so I mean it's 8 covered.
9 CHAIR REMPE: Yeah.
10 (simultaneous speaking) 11 MEMBER BALLINGER: -- feels that this 12 warrants more information, more analysis, they will 13 say so. And any applicant that would come later on 14 would run into that.
15 CHAIR REMPE: Absolutely. But I'm just 16 making the point, it's nice of you to say that this 17 should be evaluated. You may have a slide coming up, 18 but our pathway is really just a letter to the staff.
19 VICE CHAIR KIRCHNER: Is this one just a 20 very design dependent issue? It's generically 21 treated. I mean, you know, the existing rules are 22 treated generically. But if you're seeing that -- I 23 assume this is just using the Pele design. Right? So 24 there are design options that they can implement to 25 mitigate the consequence and perhaps -- I don't know 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 1 about the frequency. I don't know exactly which event 2 this is, but I'm assuming it's complete water 3 submersion.
4 MR. WHITE: So this is Bernie White, NRC 5 staff. We'll talk a little bit in our presentation 6 about criticality safety. One of the requirements for 7 a package approval is to be subcritical.
8 VICE CHAIR KIRCHNER: Right.
9 MR. WHITE: We have never received an 10 exemption request from that.
11 MALE SPEAKER: Yeah. I would hope not.
12 (simultaneous speaking) 13 MR. WHITE: Therefore, any package we 14 approve will be subcritical.
15 MR. MARCANO: This is Jonathan Marcano, 16 NRC. Dr. Rempe, in our evaluation endorsement, we do 17 have the caveat of one single shipment per year as 18 part of the calculation of the frequencies. And 19 that's also on the PNNL report. It is clearly 20 caveated. So we do have some notes that talks about 21 the specificity of the calculation of the frequency.
22 MALE SPEAKER: Thank you, Jonathan 23 Marcano.
24 MR. COLES: So on this slide, we just had 25 -- We were talking about recovery. I guess we were 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 1 about to talk about recovery. Is that right? Yeah.
2 So regarding -- someone suggested -- I think someone 3 on this side -- that we consider recovery. The way we 4 think about recovery is recovery -- it can involve 5 increased occupational dose for radiation protection 6 workers. Right? But that dose -- occupational dose 7 is managed by recovery plant, which Steve will talk a 8 little bit more about, under a Radiation Protection 9 Program. And it's not managed under the risk 10 evaluation guidelines. And it's small in comparison 11 to the dose directly from an accident.
12 Reduction of accident risk, if it's even 13 possible -- remember not quite like a wreck -- you 14 have a crash, let's say and you damage the raptor.
15 The release is over in probably minutes. So the way 16 we think about recovery is that occupational dose to 17 radiation workers.
18 Number three, multiple shipments -- I 19 think -- Did we discuss that enough? I think we did.
20 Yeah. And then while we're not seeking generic 21 approval just to be clear, PNL believes that the 22 proposed approach could have generic applicability.
23 And in fact, a similar approach was used for the 24 National Nuclear Safety Administration, a package that 25 didn't meet the codified requirements. However, that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
119 1 said, PNL believes the approach could be demonstrated 2 for other modes of transport and other types of 3 packages because the demonstration would no doubt 4 provide useful insights.
5 So with that, I'm going to turn the next 6 slides over to Steve Maheras.
7 MR. MAHERAS: Thanks, Garill. So the 8 issue of state level accident rates versus route-9 specific accident rates is an issue that you will find 10 in every transportation risk assessment that you'll 11 ever work on. For perspective as I said before, a 12 Pele truck, it would weigh about 150,000 pounds. A 13 normal semi, 80,000 pounds. The data though starts 14 off at a weight of 26,000 pounds. So when you're 15 150,000 pounds, you require a state-issued permit for 16 each and every state that you operate on. And these 17 permits are designed to provide a measure of safety 18 for that load going down the road.
19 They specify things like requiring a 20 survey of the route because if my load does not fit, 21 it does not ship. So the infrastructure has to be 22 able to handle the load. Often times you will see in 23 permits, time of day and day of week restrictions.
24 You'll often see specification of the tires and the 25 spacing on the axels. You'll see specification of the 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 1 speed that the load can travel, warning signs and 2 lights, use of escorts, et cetera.
3 The other point to consider that vehicle 4 mile data, the denominator in the accident rate 5 equation is not reported for specific locations. So 6 DOT reports for functional system levels. That's like 7 interstates, other freeways, expressways, et cetera or 8 they report by vehicle type or road type level.
9 Interstates, arterials, other roads, et cetera. So 10 really we are stuck with state-specific accident rate 11 data as low as we can go in dividing up the data.
12 So in addition, the existing analyses were 13 not designed to estimate the risk at any one point on 14 the route. Rather, they were designed to integrate 15 the risk over the entire route in a manner that's 16 consistent with the risk evaluation guidelines. And 17 so the way these routes were developed was the first 18 thing that we did was we ran a routing computer code 19 to give us a route that complied with DOT routing 20 rules for spent fuel. So that was our baseline.
21 And then we looked at that route and said 22 are there any deviations that we would like to also 23 analyze? So for this particular route, Idaho Falls, 24 (inaudible), we said well, let's look at taking the 25 bypass around Denver. The bypass around Denver is not 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
121 1 an interstate so it is not a state-preferred route.
2 So it did not come up in my original routing analysis 3 going down from Idaho Falls, but it makes sense to try 4 to bypass the population in Denver. Okay?
5 VICE CHAIR KIRCHNER: It's a better 6 quality route.
7 MR. MAHERAS: It's brand new too. It's 8 brand new. It's a toll road. I don't know how much 9 they charge for our load. I have no idea. But yeah, 10 it's a very good road and it bypasses the population 11 center. And it bypasses the mousetrap in particular.
12 Right? And so it is a reasonable augmentation to 13 discuss with the state if we were to ship. Right?
14 So after we get the accident rates, right 15 --
16 MEMBER ROBERTS: Steve --
17 MR. MAHERAS: Yes.
18 MEMBER ROBERTS: -- I had a -- Over here.
19 I had a question about qualitative, you know, societal 20 risk kind of goals. And it seems like something would 21 motivate you to take the bypass rather than going 22 through Denver. There's really nothing that I'm 23 saying in your risk metrics that would drive that.
24 It's just more of a qualitative after the fact, let's 25 go and see what we can do to minimize risk because 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
122 1 there's something else driving the desire to go around 2 Denver, instead of going through Denver.
3 MR. MAHERAS: No. It was more like 4 looking at a map to see if the route makes sense.
5 Right? Because you know, we have all these great 6 computer codes that analyze routes. Right? But we 7 always have to look at a map after we run the route to 8 see if the route makes sense. And this was a case 9 where, gee, you know, maybe we ought to try and bypass 10 the mousetrap in favor of taking that nice non-11 interstate toll road that exists around. So really it 12 was an idea of seeing what the route was and seeing 13 that there's a deviation that could work in our favor.
14 MR. COLES: Steve, could I just interject 15 a little bit?
16 MR. MAHERAS: Yeah.
17 MR. COLES: So from a PRA point of view 18 and the point of view of the methodology, right, we 19 view that as defense in-depth -- another defense in-20 depth measure, which is part of the approach.
21 MEMBER ROBERTS: Yeah. Now, you know, the 22 only thing about that route would be that the state 23 would have to approve the deviation. Right?
24 VICE CHAIR KIRCHNER: More importantly, it 25 would reduce the number of people potentially at risk.
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123 1 That's the --
2 MEMBER ROBERTS: Absolutely.
3 VICE CHAIR KIRCHNER: -- what you want to 4 optimize on.
5 MEMBER ROBERTS: Yeah.
6 VICE CHAIR KIRCHNER: If you go right 7 through the center of Denver and you get stuck of have 8 an accident, you're going to maximize the potential 9 exposure.
10 MEMBER ROBERTS: Yeah.
11 VICE CHAIR KIRCHNER: If you do a loop 12 around Denver, you've got a low population zone --
13 MEMBER ROBERTS: Right.
14 VICE CHAIR KIRCHNER: -- versus a high 15 population zone.
16 MEMBER ROBERTS: I absolutely agree 100 17 percent, but we're just the -- You're talking about 18 the last bullet, it talks about variabilities. But 19 back on the first bullet, there's a lot of 20 variabilities. And maybe they're in the et cetera at 21 the end, unexpected weather. The route may be flat 22 going through Denver and hilly going around it. I 23 don't know.
24 VICE CHAIR KIRCHNER: It's flat going 25 around.
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124 1 MEMBER ROBERTS: Either way, I mean just 2 hypothetically.
3 MEMBER HALNON: At what point, I mean out 4 of all those assessed in this, you know, that great 5 idea of going on the pretty road may not be such a 6 great idea because you're actually increasing the risk 7 of an accident even though you may expose less people.
8 MEMBER ROBERTS: Correct. Correct.
9 That's absolutely true. And so that's why in these 10 kinds of cases when you actually ship fuel, first of 11 all, you drive the route to make sure that it's 12 acceptable.
13 MEMBER HALNON: You check the weather 14 forecast.
15 MEMBER ROBERTS: Second of all, you work 16 with your state that you're transporting through to 17 make sure that they agree with what you're proposing 18 for an alternate. Right? So this is not something 19 that happens 100 percent on us. Right?
20 MEMBER HALNON: Okay. But the state 21 doesn't have a PRA and an analyst or --
22 (simultaneous speaking) 23 MEMBER HALNON: -- sitting in the 24 background.
25 MEMBER ROBERTS: The state has traffic 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
125 1 people though. And they know their roads.
2 MEMBER HALNON: All right. So I come from 3 a state where I would not trust the traffic people.
4 MEMBER ROBERTS: What state is that?
5 MEMBER HALNON: Hawaii. No, I'm just 6 kidding. But they're not -- They don't do with 7 nuclear fuel all that often.
8 MEMBER ROBERTS: Oh, but they deal with 9 HAZMAT every day. Right?
10 MEMBER HALNON: So that's where you're 11 coming from. So it's extrapolating from their 12 experience from other stuff.
13 MEMBER ROBERTS: So the routing rules for 14 HAZMAT are similar to, but not exactly the same as for 15 rad material.
16 MEMBER HALNON: Okay, so the same goal.
17 Prevent the accidents.
18 MEMBER ROBERTS: Yeah, the same goal.
19 Yeah.
20 (simultaneous speaking) 21 MEMBER ROBERTS: Right.
22 MEMBER HALNON: I get it.
23 MEMBER ROBERTS: Yeah.
24 MEMBER BIER: I have a question that is, 25 I think not the presenters, but maybe for Ron or Joy, 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
126 1 which is are we supposed to be assessing the adequacy 2 of the methodology or assessing whether we think it's 3 safe for Pele to ship? Because the two are kind of 4 different things.
5 MEMBER BALLINGER: When we first started 6 looking at this with Bernie, I think he thought we 7 were nuts because in our opinion, that would be Chris 8 and myself, we looked at it. And there was that one 9 sentence in there that said, by the way, this 10 methodology might apply to non-Pele. And so it was 11 the methodology --
12 MEMBER BIER: Okay.
13 MEMBER BALLINGER: -- that we were 14 thinking about. But as soon as that one sentence was 15 in there, that opens up the flood gate to what we've 16 been talking about all along. And I don't know if 17 people have more than one epiphany, but I'm thinking 18 that this is an important -- important evaluation.
19 And if I was to vote for a letter, I would vote for a 20 letter for sure. But not with the letter that we now 21 have, my bad. But I think that a lot of the topics 22 that we've been discussing may not impact Pele, but 23 later on down the road, hopefully we will have to try 24 to ship one of these things and it won't be Pele 25 because it's a DoD thing. So there's some information 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 1 here that I think needs to be pointed out, but that's 2 one person's opinion.
3 CHAIR REMPE: In our subcommittee 4 discussions when we were talking with the staff, I 5 think one of the staff members had a good point back.
6 He said you know when we were looking at this, we were 7 thinking about something like Pele, but we didn't 8 maybe perhaps think that our document would be 9 construed as approving a methodology that would be 10 used elsewhere. And I think that at least that staff 11 member thought yeah, maybe we should be looking at it 12 more carefully with what could happen from this 13 evaluation thinking is kind of where I'm at it too.
14 MR. MAHERAS: So I think I'm still on 15 deck. So after we get the accident rates, we combine 16 the accident rates with probabilities of specific 17 accidents to yield frequencies for the entire route.
18 We talked about frequency maybe being per transport 19 instead earlier. This is the same approach as we used 20 in the -- in the repository EIS and other -- other 21 Department of Energy and NRC environmental documents 22 that deal with transportation.
23 If there is concern about specific areas 24 of routes, those usually come out when someone 25 actually drives the route to look at the 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 1 infrastructure. So correlations between accident rate 2 target hardness. And by that, I mean what could it 3 hit and how hard is the thing you hit. Presence of 4 streams, rivers, and other route hazards could be 5 addressed in that survey and through the use of 6 appropriate compensatory measures. All that being 7 said, additional analyses could be useful to explore 8 the impact of the variability in the accident rates.
9 And with that, I'll turn it over to Harold if there's 10 no other questions.
11 MR. ADKINS: I believe I'm next up. Next 12 slide please. So one of the questions, I think the 13 Committee had, Subcommittee, I guess previously was 14 how would this be used? Right? How would it be a 15 vehicle that leads to or is integrated into the 16 process of developing a safety analysis report 17 application that the NRC would review? And the one 18 thing that immediately stood out to us that we wanted 19 to make clear is, you know, we talked about the 20 application of the methodology only applying to 21 postulated hypothetical acts in a condition evaluation 22 and being able to meet the dose and containment 23 criteria. Right?
24 So ultimately we take a lot at the all 25 influencing physical, chemical, and environmental 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
129 1 loading conditions that would adversely affect the 2 package performance in the first place in the exact 3 same light that the NRC would expect an applicant to 4 do. And taking a look at the configuration, applying 5 all of the applicable consensus standards, ASME code 6 standards, some of the NRC transportation regulatory 7 guides -- reg guide 7.1 through 7.13, the NRC standard 8 review plans, all of the process that currently exists 9 right now to a tee from beginning to end.
10 And ultimately that would express that 11 there's a need for the packaging to meet the 12 deterministic demonstrate requirements -- the 13 Demonstration Unit would meet, in this particular 14 case, I guess that's kind of misleading, but that 15 determinalistically would be found to meet all the 16 normal conditions of transport, but then would apply 17 to only let's say a suite or a handful of items that 18 were presented challenges or maybe uncertainty as far 19 as whether they're able to meet the metrics as part of 20 the postulated hypothetical accident conditions. And 21 then those would be exploited to determine, you know, 22 how robust and what some of the propensity or 23 uncertainty would be associated with that and develop 24 the compensatory measures to accommodate and provide 25 equivalent safety and leveraging DoD and safety margin 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 1 and things of that nature that we previously 2 discussed. And then applying for an application 3 through 10 CFR 71.12 to leverage all of this 4 culminating information as part of the application to 5 get -- to approach the pathway of getting this 6 certificate of compliance. Right? Just to give you 7 a rundown.
8 Next slide. And I think I have to hand 9 this over to one of my colleagues, Steve Maheras.
10 MR. MAHERAS: So I'm going to talk a 11 little bit about how transport would actually be made 12 if Pele were to actually be moved in the future at 13 some point in time. So first of all, the transport 14 would be made in compliance with the DOT rules. That 15 is a given. Because of the size of the truck, we 16 talked about Pele being a 150,000 pound load. We'd 17 need to get state permits for each and every state 18 along the route and that would include an evaluation 19 of the proposed route that was going to be used and 20 any alternative routes that an applicant proposed for 21 transport. And this is to verify that the 22 infrastructure can accommodate the vehicle and the 23 load because if it doesn't fit, it doesn't ship.
24 Alternative routes are often times 25 included in these analyses in case of bad weather, 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 1 road closures, et cetera. The proposed route must 2 meet the requirements of the DOT routing rules. These 3 routes are chosen to minimize radiological risks.
4 They typically will involve interstates and bypasses 5 or beltways around a city, but states have also got 6 the opportunity to designate preferred routes. You 7 know, and this lets them based on their state-specific 8 local knowledge, designate routes that they would 9 prefer be used instead of interstates.
10 MEMBER BIER: I was questioned about -- I 11 mean I understand all this stuff --
12 MR. MAHERAS: Right.
13 MEMBER BIER: -- that, you know, the 14 states would still have to do their thing --
15 MR. MAHERAS: Right.
16 MEMBER BIER: -- like for the other 17 shipment.
18 MR. MAHERAS: Yeah.
19 MEMBER BIER: But I have a question about 20 how you envision your analysis method being used 21 because if we end up in a mode of say nth of a kind 22 and you know, there's some facility down the street 23 from Greg's house in Ohio and they're shipping -- you 24 know, they're shipping one reactor a month for the 25 next eight years, but two different destinations. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
132 1 are you envisioning that after they propose their 2 route and get their state approval that you would go 3 through the same laborious process you went through of 4 where the wiggly parts in the road and are they are 5 high elevation or whatever? Or are you envisioning 6 the site next to Greg's house could get kind of a 7 blanket approval to ship say anywhere that satisfies 8 the various state and you know, some other generic 9 form of requirements? You know, no dirt roads and you 10 know, et cetera.
11 MR. MAHERAS: Okay. What you're 12 describing is what we would call the run scenario.
13 MEMBER BIER: Yeah.
14 MR. MAHERAS: And we're very much in the 15 crawl scenario.
16 MEMBER BIER: Okay.
17 MR. MAHERAS: We're very much in the crawl 18 scenario right now.
19 MEMBER BIER: So your sense is it's not 20 that you would propose reimplementing what you just 21 did once a month for eight years, but just that this 22 was a learning experience and we might see you back in 23 a few years with a more generic proposal?
24 MR. MAHERAS: I think it's very much a 25 discussion that applicants and the NRC will have to 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 1 have if God willing --
2 MEMBER BIER: Yeah.
3 MR. MAHERAS: -- more of these transports 4 are made.
5 CHAIR REMPE: So we interrupted you 6 earlier. My take is that basically we can't get the 7 data from the states because they just give you the 8 total accident rate for their state. Well in PRA 9 especially with these new designs, there's often a 10 lack of data. So what we typically, I think do with 11 PRA is we applying engineering judgements. So if I 12 saw an elevated location near a high population area 13 --
14 MR. MAHERAS: Right.
15 CHAIR REMPE: -- that's subject to black 16 ice in the Winter in Idaho where the semis often go 17 off, I might take that average accident rate and bump 18 it up by a factor of ten just because of engineering 19 judgement tells me that it could not only have higher 20 frequencies, but I also know there's higher 21 consequences.
22 MR. MAHERAS: Or I might choose not to 23 ship when those conditions exist.
24 CHAIR REMPE: I just don't think you can 25 go around on anything that's reasonable around 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 1 Pocatello. But you look for it, yeah, it would be 2 better to go around and find a different place. But 3 if there is no other place that you're estimating the 4 risk, I think you've got to do something like that.
5 MR. MAHERAS: It's quite common to limit 6 shipments to prescribed times of the year --
7 CHAIR REMPE: That would be good --
8 (simultaneous speaking) 9 MR. MAHERAS: And I'll give you an example 10 of that. This is not Pele, but it's another site.
11 Okay, so Big Rock Point, right, is a reactor that has 12 a large tourist population in the Summer. So while we 13 would dearly love to move the casks off of that site 14 in the Summer, one of the things that we're going to 15 have to consider is the tourists that inundate that 16 area at that time. And that is part of the 17 transportation planning process that occurs for every 18 shipment every time fuel is moved.
19 CHAIR REMPE: So what I'm hearing is the 20 methodology has some other backstops --
21 MR. MAHERAS: Right.
22 CHAIR REMPE: -- that are considered 23 before it happens. But if I'm approving a methodology 24 for estimating the risk, what I'm trying to say is use 25 some engineering judgement with your limited data to 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 1 give us a better estimate and not just throw it into 2 the uncertainty analysis and sensitivity study 3 analysis bit.
4 MR. COLES: Yeah, Joy. I think that's 5 right. This is Garill again. And I know you know 6 this, but in the report itself, we did examine a lot 7 of these assumptions about the route. And we 8 performed fairly extensive sensitivity assessment.
9 And I think those kinds of observation hazards, they 10 -- I think absolutely right. They need to be 11 examined. And the way we propose to do that is with 12 sensitivity and with uncertainty analysis.
13 CHAIR REMPE: But I'm just saying maybe 14 the base case could also use some intellect --
15 MR. MAHERAS: Oh, absolutely.
16 CHAIR REMPE: If you drive the route --
17 It's really the people who are driving the routes 18 should look for some of the more dangerous parts on 19 the road. And use some engineering moment on the data 20 --
21 MR. MAHERAS: Yeah.
22 CHAIR REMPE: -- and not just average the 23 data.
24 MR. MAHERAS: We actually had a project 25 this year where we took some young engineers and they 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 1 built the equivalent of a Google car with a rotating 2 camera on the roof to do the route survey. So those 3 kinds of things, I think can be incredibly helpful.
4 This is something that the Army does on a kind of 5 standard practice basis also.
6 MEMBER BALLINGER: I need to make a 7 comment that we should not be using the chat feature 8 of Teams and apparently some people are. So please --
9 MR. MAHERAS: It's not us.
10 MEMBER BALLINGER: Well, somebody is.
11 Whoever it is, please don't use the chat feature.
12 MEMBER BIER: One other question. In your 13 experience, not necessarily in this report, have you 14 done sensitivity analysis to see how much difference 15 there is from one route to another, say for the same 16 destination?
17 MR. MAHERAS: Yeah, we've done some 18 examination of that on other projects. And I'll give 19 you an example. When we did the repository EIS, we 20 analyzed a case where we would use all trucks for 21 transporting the waste to the repository. Those 22 trucks according to the rules, right, would have gone 23 right through downtime Vegas on their way to Yucca 24 Mountain. Right? Right through the spaghetti bowl is 25 what that intersection is called. Right? And so we 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 1 said okay, so let's look at other things. And we 2 looked at the back way into the site through Death 3 Valley. We looked at alternatives that would even 4 come all the way around the site. So we looked at 5 about eight different -- eight different other routing 6 strategies. Right? And they make some difference.
7 The major difference that you will see is getting out 8 of downtown. So if there is a bypass around the city, 9 wicked good thing to use. Right? But you have to 10 balance that in an EIS, especially with increasing the 11 distance. Because increasing the distance increases 12 the traffic deaths that you might calculate. The ones 13 that aren't related to the cargo that are related to 14 just the truck being on the road. Right? So, yeah.
15 MR. BLEY: Could I jump in? This is 16 Dennis Bley. I really like everything you've been 17 talking about. I like your discussion with Joy about 18 bringing engineering or expert information or 19 judgement into the analysis. And there are ways to do 20 that might be better than doubling or multiplying by 21 ten or something like that. But that makes sense.
22 There's two issues you haven't talked 23 about much that at least a few years ago when I was 24 involved in some of this, turned out to be pretty 25 significant. And the one you touched on a little bit, 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 1 which is local police or state police might encourage 2 restricting access through very busy parts of cities 3 at busy hours. And you touched on that. I think 4 that's covered.
5 The other one though -- and maybe this has 6 improved in the last ten years. It used to be pretty 7 significant because as you move from one area to 8 another, whether it's the state police at the state 9 borders or maybe it gets turned over to local police 10 in certain others, the turnover of the escort 11 sometimes led to really big delays or problems. And 12 you haven't talked much about that. Have you looked 13 at that?
14 MR. MAHERAS: Yeah, that's an operational 15 issue that we had given some thought to. It's not 16 reflected in the PRA, but it's definitely the 17 consideration in the transportation planning for an 18 actual shipment. Right? So what happens is the 19 shipment arrives at border A and the folks that are 20 supposed to escort it into the next state don't arrive 21 on time, they're late, whatever. Right? And so then 22 they can't perform the escorting. Now that is 23 ameliorated a little bit in the DOE world because 24 people will track shipments with Transcon is what the 25 tool is called. And so what that gives you is the 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 1 state that's getting the shipment will see that 2 shipment arrive on their screen roughly an hour before 3 it gets to the border, so they're reminded that they 4 need to -- that it's going to be arriving.
5 But it really all comes down to pre-6 transport coordination between law enforcement in all 7 of those states along the entire route. And really 8 communication is the key to that process. A lot of 9 this is done through what the DOE has now, the 10 National Transportation Stakeholders form. And so 11 that's where people from each one of the states can 12 get together. They know each other. So they're not 13 getting cold calls. They all know each other. They 14 work together on projects, et cetera. So it really 15 does streamline the planning. And shipments in this 16 venue typically start to be discussed two to three 17 years before they're made. Right? So that everybody 18 knows what's coming and what it's going to look like 19 and who's involved and what the planning is going to 20 look like, et cetera, et cetera, et cetera. Right?
21 MR. BLEY: So thank you. It sounds as if 22 things have improved since I was touching on this some 23 years ago. I recall some cases where shipments got 24 stalled in less than optimal places for a fairly long 25 time. And I'm glad that's no longer the issue it used 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
140 1 to be.
2 MR. MAHERAS: Yeah. So one of the other 3 things that happens on spent fuel transports is that 4 they're required to have commercial vehicle safety 5 alliance level 6 inspection of the load and the 6 tractor and the trailer. And so what that inspection 7 is designed to do is it's designed to show that, that 8 vehicle and load are defect-free before departure.
9 And that is a big help to us in making the transport 10 because many states downstream will see the decal that 11 we've put on the car that shows that they made the 12 inspection and they will choose not to inspect, which 13 is a good ALARA practice at times. Right? But this 14 is a well-established process that's used for every 15 shipment that's made. So we would rely upon that or 16 the Army equivalent.
17 I'm taking up a lot of time here. This is 18 the last slide, I promise. So we would also evaluate 19 the route from the perspective of protection of that 20 shipment. We would use likely NRC guidance of the 21 Army equivalent. And what this means though is 22 coordination with law enforcement agencies along the 23 route, identification of safe parking in case of 24 mechanical issues, bad weather, hazardous road 25 conditions or unanticipated problems.
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141 1 We would want to have all of our 2 identified and specified compensatory measures in 3 place. You know, time of day, day a week 4 restrictions, rolling road closures, escorts. A 5 shipment would only be conducted after it had been 6 coordinated with all the effective states and tribes 7 as part of the transportation planning process that 8 includes notification of those states and tribes along 9 the route, shipment tracking, shipment status, and 10 emergency response plans and procedures are in place.
11 And then we would want to ensure that the 12 shipments avoid bad weather. Black ice for example, 13 hazardous roads through constant communication with 14 drivers monitoring road conditions and restricting 15 travel when adverse conditions pose a threat to the 16 transport. So any delays would be coordinated with 17 the downstream states and tribes. But nothing that I 18 put on this slide is new. Right? This is what 19 happens today. Right? Yeah.
20 MR. ADKINS: One last point. This is 21 Harold Adkins. Unlike what we did on the last 22 presentation, we went and populated the tail end of 23 this presentation with all the applicable references 24 so they're available to you that we've discussed 25 today.
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142 1 MEMBER HALNON: Are all the decisions to 2 what you just mentioned is weather, road conditions 3 getting worse or whatever? Are all those decisions on 4 the drivers themselves or how does that work? I mean 5 are they in communications with law enforcement that 6 are escorting them?
7 MR. MAHERAS: They're in communications 8 with the escorts and they're also in communication 9 with the movement control centers used for the 10 dispatcher, the home office --
11 MEMBER HALNON: Is there one person in 12 charge?
13 MR. MAHERAS: Oh. I will have to check 14 that and get back to you. I don't know off the top of 15 my head if they have a duty officer who -- I don't 16 know the answer to that.
17 MEMBER HALNON: Okay. I'd be curious 18 because the communication is -- I mean you've got 19 health effects, maybe the driver or someone else that 20 could -- you know, other things that are outside the 21 scope of road conditions. There's other things that 22 can happen. I was just curious if there was one 23 person in charge, you know, 24/7 or at least while 24 it's on the road moving.
25 MR. MAHERAS: Yeah, there's a 24/7 number, 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
143 1 but it rings the Control Center. And what I don't 2 know the answer to is the precise staffing of the 3 control center. I'll have to get back to you on that.
4 MEMBER HALNON: Yeah, I'd appreciate that 5 definitely. Thank you.
6 MALE SPEAKER: I'd like to turn it over tO 7 NRC.
8 MEMBER BALLINGER: We're about to have our 9 discussion on this presentation. But may I suggest 10 that before -- we take a break between this 11 presentation and the NRC presentation. Is that 12 appropriate?
13 CHAIR REMPE: That would be fine. I have 14 one just comment about your backup slide about 15 corrosion and oxidation. And I get it that, that's 16 something typically considered. But as Jeff mentioned 17 in his opening remarks, right now we're getting a lot 18 of micro-reactor designers that are perhaps -- I think 19 you used the phrase "hand waving some things".
20 MEMBER BALLINGER: Yeah.
21 CHAIR REMPE: And again, I think that's 22 why it's important for the staff in their evaluation 23 to make sure it's documented because it's something 24 that is a guide for the staff when they're looking at 25 these things, as well as applicants. And so I know 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
144 1 it's a backup slide and you didn't present it, but I 2 didn't buy that one, just that it's typical -- saying 3 that on the transcript. Okay?
4 MR. WHITE: Bernie White, NRC staff. We 5 added it to our evaluation.
6 CHAIR REMPE: Okay. And so your request 7 for a break is -- Right now, I've got 26 after. If we 8 came back at 40 or 20 til, is that fine? That gives 9 you 14 minutes.
10 MEMBER BALLINGER: Say it again.
11 CHAIR REMPE: Let's get going so --
12 (simultaneous speaking) 13 CHAIR REMPE: Yes?
14 MEMBER BALLINGER: No. No, 2:40 unless we 15 negotiate. 2:40.
16 CHAIR REMPE: Yes, okay. And we're going 17 to take a break and come back and the staff can be 18 ready for their presentations and I'm going to mute 19 us.
20 (Whereupon, the foregoing matter went 21 off the record at 2:26 p.m. and went back on the 22 record at 2:40 p.m.)
23 CHAIR REMPE: Okay. It's 2:40 and I'm 24 going to turn it back over to you, Ron.
25 MEMBER BALLINGER: Thank you. Mr. White 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
145 1 tells me that he can finish his talk in ten minutes.
2 I can assure him that we'll just abuse it.
3 CHAIR REMPE: It's a challenge.
4 MEMBER BALLINGER: Take that as a 5 challenge. Anyway, Bernie, go ahead.
6 (laughter) 7 MR. WHITE: Let me start by saying, I 8 didn't say I could limit your questions to ten 9 minutes, I can finish my talk in ten minutes. Thank 10 you. Thank you.
11 So we're to talk to you a little bit about 12 the methodology. We're not going to rehash what we 13 did at the subcommittee meeting telling you why we 14 think it's acceptable. We're going to talk about 15 things that we heard at the subcommittee meeting and 16 provide some information on things, you know, to help 17 inform your decision. Some of those things will 18 include overview of NRC requirements for spent fuel 19 transport, limitations of the methodology, 20 clarifications that we're making to the endorsement 21 based on the subcommittee comments, and then an 22 updated slide on the next steps.
23 So for package, the shipper would ensure 24 that the package to be used has contents that are 25 approved for shipment. If not, they would obtain an 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 1 amendment to the NRC approval.
2 In the next slide, I'll provide level of 3 review of NRC package review. If the shipper does not 4 have an approved route -- you know, we heard about 5 route approvals earlier --
6 (off record comments) 7 CHAIR REMPE: This is Joy Rempe. We have 8 some interference from someone who needs to mute their 9 phone out on the internet with someone named Kyle.
10 Thank you.
11 (laughter) 12 MR. WHITE: So if the shipper does not 13 have an approved route, the route approval -- a route 14 approval would be required. Staff in our office of 15 nuclear securities response reviews applications for 16 route approvals. So more information on both route 17 approvals and transport security requirements can be 18 found in NUREG-0561 Rev 2, physical protection of 19 shipments of a radiator reactor fuel. Some of the 20 criteria used in route selection include minimizing 21 transport time, availability of swift local law 22 enforcement agency response, availability of locations 23 for safe havens, availability of appropriate rest and 24 refueling stops.
25 During its route reviews, the staff checks 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
147 1 for the accuracy with respect to names of state and if 2 appropriate for the route, tribal contacts, 24-hour 3 state phone numbers, phone numbers for each local law 4 enforcement agency along the route, and the path of 5 route across each state. If contact is needed during 6 shipment, it should not be delayed due to having an 7 incorrect phone number. The route will be physically 8 inspected -- The route should be physically inspected 9 as well. One doesn't want to try and take a 10 semitrailer under a bridge or tunnel that doesn't have 11 sufficient height. You laugh. I've seen it.
12 In addition, route selection will need 13 information related to weather, road closures, and 14 events with large gatherings such as concerts, fairs, 15 or sporting events that may be close to the route. I-16 95 goes right through Bolivar, not too far from the 17 Orioles and Ravens stadium. You wouldn't want to take 18 hazardous material up there this Sunday afternoon at 19 1 o'clock.
20 So the security requirements in Part 73 21 for spent fuel shipments have advanced notification 22 requirements for radiated reactor fuel. No later than 23 two weeks prior to the shipment or prior to the first 24 shipment of a series of shipments, the licensee shall 25 arrange for state law enforcement escorts. Positional 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 1 information sharing when requested, coordinate with 2 local law enforcement for response and assistance.
3 Other security requirements include leading and 4 trailing vehicles, armed escorts, and communication 5 requirements.
6 The communication requirements for spent 7 fuel shipments by road are to provide the escorts with 8 capability to call for assistance if necessary, allow 9 progress of the shipment to be tracked, provide the 10 escorts with a way to quickly develop new local law 11 enforcement contacts, and if needed, obtain new route 12 information when unexpected detours become necessary, 13 and coordinate the movement of and transport of escort 14 vehicles when more than one vehicle is used in a 15 shipment.
16 At a high level, the methodology 17 endorsement is being limited to two road shipments and 18 only for the tristructural isotropic or TRISO-based 19 project Pele transported with micro-reactor. So why 20 are we doing that? Well, for a couple of reasons.
21 First, we've reached out to other micro-reactor 22 vendors and nobody has indicated a need to use this.
23 Secondly, opening it up for widespread use would bring 24 in some complicating factors, which I'll get into in 25 a couple of minutes.
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149 1 Application of methodology would also be 2 for a specific route that would be provided in the 3 package application. While the methodology is generic 4 and could be used for other transport of micro-5 reactors, we're limiting it to Pele. Endorsing the 6 methodology for more widespread use could have policy 7 issues for which commission direction may needed and 8 potentially consideration of rule making.
9 In addition, more widespread use at the 10 NRC -- For more widespread use, the NRC would have to 11 consider co-located hazards for transport of multiple 12 or large numbers of transportable micro-reactors along 13 the same route or a similar route. Given the amount 14 of uranium in the project Pele transportable micro-15 reactor, which is less than any single pressurized 16 water reactor fuel assembly, any release due to an 17 accident is not expected to be large when one compares 18 it to a reactor accident.
19 The methodology is consistent with 20 existing commission policy by limiting consequences to 21 the maximum exposed individual to meet the 22 quantitative health objectives. While we did not 23 focus on the numbers used in the calculations 24 performed by Pacific Northwest National Lab, we do 25 note that in their sensitivity analysis, they showed 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 1 that, you know -- for their demonstration that the 2 dose to an individual is most sensitive to reactor 3 cool time and drops off quickly with distance from the 4 accident. It did not appear to be sensitive to 5 exposure time as well.
6 Now I'll turn it over to Jonathan for the 7 next few slides.
8 CHAIR REMPE: Just to try and make sure 9 you don't make that ten minute thing, what are the 10 other micro-reactor folks -- you said none of them are 11 interested in using this methodology. Have they given 12 you a clue on what they plan to use for methodology?
13 MR. WHITE: So the ones that have told us 14 said one of two things. Either we're going meet Part 15 72 or we're going to use 71.41(c), which authorizes 16 alternate test -- environmental test conditions. If 17 you remember back to the subcommittee meeting, we 18 talked briefly about the Trojan reactor vessel, that 19 is something similar. While we did exemptions for 20 that, it did use alternate environmental test 21 conditions. The big difference between that approval 22 and this is that for that type of approval, while you 23 could do a lower test, you still have to meet the dose 24 rate and containment criteria in Part 71. So there's 25 no way of having an out for meeting those.
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151 1 CHAIR REMPE: Thank you.
2 MEMBER MARCH-LEUBA: So I can think of 3 what we're doing, what is the final product of 4 (indiscernible due to accent)? Is it an SER? Is it 5 NUREG? Is it a letter?
6 MR. WHITE: So we are issuing a letter 7 that would endorse the methodology, you know, with 8 certain caveats.
9 MEMBER MARCH-LEUBA: You sign it or it is 10 it signed by --
11 MR. WHITE: It won't be signed by me. My 12 pay grade's not high enough to use the euphemism.
13 MEMBER MARCH-LEUBA: (audio interference) 14 MR. WHITE: It will be from probably my 15 branch chief, (inaudible). Okay? Along with that 16 will be accompanied -- we don't call it a safety 17 evaluation report. And the reason we don't is because 18 typically SERs you compare with rules. You know, 19 regulations. We're not doing that because there are 20 no rules for this. You know, if we were to approve an 21 exemption, you have to show that it doesn't endanger 22 the public health and safety, which is fairly 23 subjective.
24 MEMBER MARCH-LEUBA: So particularly, it's 25 a letter of approval.
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152 1 MR. WHITE: We call it a methodology 2 evaluation.
3 MEMBER MARCH-LEUBA: We like this 4 methodology and (indiscernible due to accent) because 5 you're going to need my license anyway.
6 MR. WHITE: Right, for -- Right, for this 7 specific use for two transports by road. Yep. Mmm 8 hmm.
9 MEMBER MARCH-LEUBA: Thank you.
10 MR. WHITE: Mmm hmm.
11 MR. MARCANO: Thanks, Bernie. So this is 12 Jonathan Marcano, NRC. So in these next two slides, 13 I will be covering the topics for which the staff made 14 additional clarifications to our draft methodology 15 endorsement as a result of the discussions we had 16 during our subcommittee meeting to ensure that we 17 clearly described the scope of our endorsement.
18 The first topic for which the staff added 19 language is with regards to the applicability of our 20 endorsement to the approaches and that our endorsement 21 does not extend to the basis and the (indiscernible 22 due to accent) of numerical assumptions and estimated 23 results. So we're focusing on that systematic 24 approach as described by the methodology. And this is 25 due because as we have been discussing, the PRA base 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 1 the frequencies on a hypothetical route and the four 2 doses they use in engineering adjustment to estimate 3 package damage and the release of radioactive material 4 rather than performing quantitative renewing 5 evaluations.
6 We also added one new section to the draft 7 methodology endorsement on the approaches to 8 estimating likelihood of accidents. This was a topic 9 that was brought up with regards to the application of 10 conditional modifiers to the frequency of highway 11 accidents. So in that, we -- For that specific 12 section, the NRC considers in our endorsement that the 13 estimates of likelihood of accidents scenarios are 14 inputs to the methodology and not part of the 15 methodology itself. So our review of the application 16 -- the future application that utilizes the 17 methodology, when we receive that, then our 18 expectation -- our review will be no different on any 19 review. Right? And our expectation is that the level 20 of justification of the approaches and numerical 21 assumptions will be commensurate as important to 22 safety. And that includes the use of data, frequency 23 estimate, conditional modifiers, among others.
24 MEMBER MARCH-LEUBA: Did you allow 25 acceptance criteria, the frequency consequence 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 1 (indiscernible due to accent) charts?
2 MR. MARCANO: We did. And our endorsement 3 pretty much states that the development of the risk 4 evaluation guidelines is consistent with existing 5 commission policy and guidance.
6 MEMBER BIER: Excuse me.
7 MR. MARCANO: Yes.
8 MEMBER BIER: Can we either see a version 9 of those charts here if you have them in backup or if 10 not, I can probably talk about them.
11 MR. MARCANO: I'm now wondering whether or 12 not there's been a substantial enough change as a 13 result of the subcommittee meeting. I don't think we 14 have the current version.
15 MEMBER BIER: Well, I think any version is 16 --
17 MR. MARCANO: Well, we have a version.
18 MEMBER BIER: Yeah. I mean I can talk 19 from what I have. I don't think I can display it 20 because I'm not logged into Teams. But I'm wondering 21 if this is probably something I should have asked the 22 lab folks before and not you guys. But I'm pondering 23 those frequency consequence charts. And there are 24 places where there are like two events with very, very 25 similar consequences and maybe one more likely than 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 1 the other. And I think in the usual use of those 2 charts, the dividing line would be compared against a 3 complimentary cumulative in which case the likelihood 4 of those two events with similar consequences would be 5 added. You know, because like if I pick like 12 6 representative accident types or whatever and show 7 them each as a little dot, I could subdivide them and 8 get you know, a 1,000. And they would all be, you 9 know, dots but very, very low.
10 MEMBER MARCH-LEUBA: When we start doing 11 the LMP original discussions --
12 MEMBER BIER: Yeah.
13 MEMBER MARCH-LEUBA: -- the answer is that 14 they group it into different types of accidents.
15 MEMBER BIER: Yeah, but still for a 16 fission reactor, you would combine them all.
17 (simultaneous speaking) 18 MEMBER MARCH-LEUBA: -- in focus on 19 Wednesday, focus on Thursday, focus on Friday.
20 MEMBER BIER: Yeah. Yeah. Yeah.
21 MEMBER MARCH-LEUBA: Right before it goes 22 down. Right?
23 MEMBER BIER: Yeah, exactly.
24 MEMBER MARCH-LEUBA: It would make more 25 sense. So the question is how did you group it?
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156 1 MEMBER BIER: Yeah. Anyway, I mean if we 2 can go over that more offline or whatever, but it's 3 just something that didn't occur to me til now.
4 MR. MARCANO: This is Jonathan Marcano.
5 And Brian, you might also want to jump in. That's 6 something that we also discussed and we evaluated. We 7 definitely don't want to see those events. Just 8 seeing those -- Yeah, so we would definitely look at 9 that and consider that.
10 MEMBER BIER: Because it's something I 11 feel like I was slow to catch onto. It bothered me 12 last time in subcommittee and I couldn't quite figure 13 out why. And all of the sudden today, I figured out 14 what it was that was bothering me, so okay.
15 MR. MARCANO: Yeah. Same for the data, 16 same for the accident data. Right? I mean you don't 17 want to see those just divided by 1,000, so 18 definitely.
19 MR. MCCARTIN: Yeah. Tim McCartin, NRC 20 staff. And this is that dividing line that we see 21 between approving of the methodology and how it's used 22 in an amendment 4 request. And you're absolutely --
23 any methodology can be used inappropriately. And so 24 the review has to look at these types of things to see 25 how the risks are calculated and what it means. But 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 1 that's part of the review using the methodology, but 2 it's a critical part of our review.
3 MEMBER BIER: But I think you're 4 describing it accurately. It doesn't call into 5 question all the zillion hours of work that the team 6 did to generate that, but it could be plotted in maybe 7 a more informative way or more expressive way.
8 MR. MARCANO: Bernie, we can go to the 9 next slide. The next one, yep. Another topic we 10 added clarifications was on consideration of 11 (indiscernible due to accent). We already talked a 12 little bit about this. The methodology does include 13 consideration for (indiscernible due to accent) by 14 retaining event sequences with extremely low 15 frequencies. However, the staff added language to 16 note that the application -- the future application 17 that applies to this methodology should address doses 18 to a worker and a member of the public to ensure that 19 there are no (indiscernible due to accent).
20 And on this note, I also believe that it 21 is important to note that as described in the 22 methodology, the design of the package will address 23 the elements for passive heat removal to ensure that 24 the TRISO fuel will maintain its structural integrity 25 necessary to retain fission products. And this will 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 1 be another area the staff will be reviewing during our 2 approval.
3 Finally, we included language to clarify 4 that the applicant will need to use appropriate 5 initial and boundary conditions to evaluate damage to 6 the package, which will include any material 7 degradation such as corrosion, oxidation, or 8 radiation. Like we have been discussing, this is 9 consistent with our reviews. And it is required by 10 the regulations in 71.43 (d). And I'll turn it back 11 to Bernie.
12 MR. WHITE: Thanks, Jonathan. So now I'll 13 talk a little bit about our review, what we would 14 expect for an exemption request. So an exemption 15 request authorized transport of irradiated material, 16 in this case, irradiated fuel, must show that the 17 exemptions authorized by law will not endanger life of 18 property, nor the common defense and security. Since 19 it's NRC's practice not to use categoric exclusion in 20 CFR 51.22(c)13 for approval of package designs for 21 packages to be used for transport of licensed material 22 when approving exemptions, the application should 23 include an environmental report.
24 A safety review for Project Pele using the 25 methodology would include evaluation of the 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 1 probabilistic risk assessment and much of the same 2 information that the NRC receives for routine package 3 approval. The application for a package evaluated by 4 the analyses would include structural materials and 5 thermal analysis of the tests and conditions for 6 normal conditions of transport to determine that the 7 package meets the post-test criteria. In addition, 8 the application should include structural materials 9 and thermal analyses for hypothetical accident 10 conditions. And depending upon whether the post-test 11 criteria are met, the accidents determined by the 12 probabilistic risk assessment.
13 The analyses for normal conditions of 14 transport in hypothetical accident conditions are 15 performed from material properties at the temperature 16 of the test and would include any material degradation 17 such as corrosion, oxidation, or radiation damage.
18 These analyses are also benchmarked to known data.
19 For example, impact limiter test or skill model drop 20 tests.
21 The results of these analyses inform the 22 containment shielding and criticality analyses to 23 provide the input for the damaged state of the 24 package. Typically the containment analysis 25 determines whether the package meets the release rates 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 1 for Type B packages. Using the methodology, the 2 containment analysis would also provide the quantity 3 of material released and the (inaudible) fraction that 4 would be used to determine their portion of the dose 5 consequences.
6 The shielding analysis typically would 7 show that the package meets the regulatory dose rates 8 after evaluation of the test for normal condition of 9 transport and hypothetical accident conditions.
10 However, the methodology analysis would go a step 11 further to determine the total effect of dose 12 equivalent to the maximally exposed individual if the 13 containment and dose rate criteria after accident 14 conditions cannot be met. The criticality review 15 would ensure the package is subcritical. The NRC has 16 never been requested to approve a package that would 17 need an exemption from any of the subcriticality 18 requirements.
19 For the sake of brevity, I haven't talked 20 about the procedures except sensor maintenance program 21 were also a part of a package application. In 22 addition to the safety review, the application for an 23 exemption must show that the shipment will not be --
24 will not endanger the common defense and security.
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161 1 meet the appropriate security requirements, which for 2 this would be for shipment of a radiated reactor fuel.
3 Finally, the package approval using 4 exemption would need to be accompanied by an 5 environmental report. The NRC would perform an 6 environmental analysis to determine the potential for 7 environmental impacts, which could result in either a 8 finding of no significant impact or FONSI, which would 9 be documented in environmental assessment or the need 10 to perform an environmental impact assessment. As you 11 heard stated earlier, there currently are no plans to 12 move this off site.
13 If that's the case, staff could do a 14 safety review of the application, but not approve the 15 shipment -- the package for shipment. Which means 16 that in order to approve the package for shipment, we 17 would need an environmental report, which would 18 specify the route and location for which the package 19 would be going. So it would be a safety review.
20 Here's our safety findings. Have a nice day.
21 MEMBER HALNON: Would that environmental 22 review also include alternatives to the shipping? In 23 other words, keeping it where it's at?
24 MR. WHITE: Yep, it would. Yep. And so 25 you know, while PNL went over a sketch that it had for 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
162 1 the Project Pele micro-reactor transport might look 2 like, this is a drawing I received from NAC 3 International for a package of similar weight to what 4 Pele might be. This is what, you know, their proposed 5 vehicle would look like for that one particular 6 package.
7 MEMBER BROWN: Can I ask a question 8 relative to this? This is pretty small. This is not 9 a huge amount of irradiated fuel. And there's much 10 larger quantities of irradiated fuel shipped 11 throughout this country today with little, if any 12 effect. And I presume you all have been involved --
13 somebody's been involved and I won't go into the 14 details. And my curiosity here is this sounds like, 15 you know, we've got a nat running around and we're 16 going to kill it with a maximum hammer or pickaxe that 17 we can get our hands on and smash it to pieces. I 18 mean it's -- this is -- and it's separated from the 19 whole package. I mean this is four packages that gets 20 shipped, you know, with the prior four modules. And 21 this is a smaller 20 x 8 x 8, whatever the dimensions 22 were in the figures. And even within that package, 23 it's a little bitty hunk of stuff.
24 And it seems the benefits of something 25 like this application in terms of the country's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
163 1 electricity sources and various vital internal 2 country, you know, Defense Department basis critical 3 communications setups that you don't want to lose, 4 that you can decouple from the existing grid and then 5 use. It seems to me that we ought to be using our 6 heads in terms of how this is -- I'm not saying be 7 unsafe, but recognize that you've really got to 8 compound a lot to make this little bitty trunk full of 9 stuff be a real hazard to the safety of the 10 population.
11 I'm just looking for some -- How do you 12 apprise -- you're dancing around -- You're like doing 13 a stork dance around all these issues with exemptions 14 and everything else when as is, you've got to do this, 15 then you've got to do this, then you've got to do 16 this, then you've got to do this. And it just seems 17 to me somewhere along the line, you ought to develop 18 a way to look at this as something that could be 19 pretty vital to the country. And how do we do this 20 without literally squashing it before it ever gets off 21 the ground?
22 I'm just -- I'm a skeptic sitting here.
23 I can't believe I'm talking like this since I'm 24 normally looking to shut everything down as fast as 25 you can. But it seems to me -- and that's based on 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
164 1 some past experience I've had, even though I didn't do 2 it myself, but I was involved in it and knowing what 3 was going on. So I'm just throwing that out to try to 4 throw some common sense and everything else as opposed 5 to trying to make -- buckling up your armor so nobody 6 could stick any spears in your chest.
7 I'll stop right there. I just think this 8 is a good idea when you look at how it can be applied 9 throughout the country. It's very vital electrical we 10 might need in the future. It's a small thing in a lot 11 of these hot places, as well as some medical 12 facilities that are critical that you have to keep 13 powered in order to protect a lot of people. And 14 nobody wants to use diesel generators. That's kind of 15 crazy also, but that's another issue. Okay, I'll stop 16 right there. Sorry about that.
17 MEMBER MARCH-LEUBA: In that line of 18 though, I'm sure that (indiscernible due to accent) 19 Pele, but I'm sure that the plan for DoD is to 20 (indiscernible due to accent) this reactor to the PNL 21 and keep it as museum in the Richland Desert.
22 Richland, Washington. But in reality, if only one is 23 built and it never gets needed, it will be a national 24 security nuclear emergency. It's (indiscernible due 25 to accent)in the desert, in the Sahara. So it 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
165 1 wouldn't be a bad idea for whoever is above our pay 2 rate to help plan for transportation in an emergency.
3 Once you have 20 of them, that's a different issue.
4 But only one and you keep it in the desert, there's 5 nothing -- a significant chance that some guy at 6 (indiscernible due to accent) says hey, it would be 7 nice to have it in Germany -- based in Germany. So I 8 will think ahead.
9 MR. WAKSMAN: So just for awareness, Jeff, 10 the plan for the Pele prototype after it's done is to 11 turn it over to the Department of Energy, so it will 12 be in the Idaho Desert and they'll be able to signs 13 whatever out of it until it's done. And then they'll 14 probably take it apart.
15 MEMBER MARCH-LEUBA: That's right. (audio 16 interference) 17 MR. MARCANO: But going back, this is 18 Jonathan -- This is Jonathan Marcano, NRC. Going back 19 to the comment made by Mr. Charles, the previous 20 studies done on transportation, you know, have 21 demonstrated that the doses are very low. And what 22 obviously we're doing here, right, we are seeing an 23 applicant -- a potential applicant that will 24 potentially require -- request exemptions. Right?
25 But what you can at least early on, derive from the 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
166 1 report is that the doses are -- when you see the 2 doses, they drop significantly low from 25 meters to 3 100 meters. So it kind of remains consistent with 4 some of the previous conclusions that have been made 5 in the safety of transportation.
6 MEMBER BROWN: I'm just making an 7 observation that are responsible for hundreds of major 8 systems to be delivered and sent -- and designed and 9 built. And we always have specifications that are 10 very constraining and everything else. It turns out 11 when you start building them, you can't always meet 12 your specifications. And everybody's ringing their 13 hands and saying what do we do? And the way I used to 14 manage the program is if you didn't have exceptions, 15 you wouldn't need approvals. There's times to use 16 your head and accept what you get. Don't change the 17 spec, but just keep on going and do what you need to 18 do to get it delivered.
19 And I just -- I'm just -- my only purpose 20 in my comment is to use some common sense in systems 21 like this that are obviously not really a hazard per 22 se when you really get down to the nitty gritty. And 23 there's a lot of ways to transport something like this 24 with a lot of escort and get it there safely. So I 25 just -- That's the only purpose of my -- Don't get 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
167 1 wrapped in your -- Oh, my God, I can't do anything 2 because the rule says. You've got the capability 3 here. You make the rule. Say okay when it makes 4 sense. That's all.
5 MR. MCCARTIN: Yes. And I think we're 6 being appropriately cautious. But you're right, there 7 isn't a lot of fuel compared to maybe a spent fuel 8 shipment. But there is enough plutonium there that it 9 does present a hazard. And it's a very significant 10 hazard. The containment requirements for 11 transportation are such that releases are maintained 12 very low because they need to be. You can't release 13 a lot of respirable plutonium. And so I think what's 14 being done today is for this potential exemption, 15 we're looking at the risks associated with it and 16 doing an appropriate calculation that looks at well, 17 what might happen -- what might be the releases so we 18 can make a risk-informed decision.
19 I understand that, you know, the safety 20 record in transportation is superb, but that doesn't 21 mean you can relax things. You need to appropriately 22 look at it. I'd like to think we're doing the 23 appropriate amount of consideration for this risk-24 informed approach. But you know, the hazard is there.
25 I mean, there is enough plutonium there to cause a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
168 1 serious problem should there be an accident that we 2 would hope never would happen. And you're correct, 3 there are many compensatory measures to transport this 4 safely, but you don't want that accident to happen.
5 And so at least I think we're applying the 6 appropriate level of resources and effort to this.
7 But you know, we acknowledge, you know, there are --
8 we need to always look in the mirror and say are we 9 doing the right resources for the right reasons? It's 10 an appropriate caution.
11 MEMBER HALNON: You know, a few words and 12 a lot of words over here. Really needs to be 13 commensurate with the risk is what you're saying and 14 have a process that allows you to do that. And the 15 reason I say that is because when I see an 16 environmental report, it scares the heck out of me.
17 I've seen some two-page environmental reports in the 18 PSDARs and I've seen 3,000 page environment reports 19 and they still have an environmental report on it. So 20 if we're talking a PSDAR level environmental report 21 with maybe some stop over or, you know, bigger things, 22 that's fine.
23 But if we're talking environmental reports 24 that would cost, you know, hundreds of thousands of 25 dollars for even -- even more than that probably for 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
169 1 a vendor to do. And then you have to do one, you 2 know, applicants will start doing them to get a heads 3 up on what you might be doing. And before you know, 4 you're ratcheted into, you know, a huge bureaucratic 5 type thing. So that's what the comment, I think would 6 be extrapolated to is be careful. Don't make it 7 bigger than it has to be.
8 CHAIR REMPE: I have a different question.
9 I do appreciate you've made a lot of changes to 10 address comments from the subcommittee meeting. But 11 like on Page 2 of your evaluation, it said, "The staff 12 reported PNL's proposed approach to determine the risk 13 of transporting the micro-reactor". And you heard 14 this also during the subcommittee meeting expand upon 15 the fact that they average the accidents over the 16 road. You heard them today say hey, we don't have 17 data. You're approving or endorsing an approach that 18 doesn't try -- that may miss the fact that certain --
19 that accidents may be higher at certain locations.
20 And I'm not sure again if you endorse this that it 21 will be clear to the applicants and the staff 22 reviewing it that they need to go into more depth, 23 have some sensitivity studies and certainly consider 24 higher frequency locations along the road that might 25 be near high population zones.
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
170 1 MR. MCCARTIN: Tim McCartin, NRC staff.
2 Point well taken. We had made changes as Jonathan 3 talked to specifically the frequency approach, but --
4 CHAIR REMPE: I don't see it in the slides 5 that were done. Did I miss it?
6 MR. MARCANO: That was on Slide -- I 7 talked about it on Slide No. -- This is Jonathan 8 Marcano, NRC, Slide No. 5 of today's presentation.
9 And we added --
10 MR. MCCARTIN: Well, we added an 11 exception. Now it doesn't say that on the slide.
12 Jonathan mentioned it in talking --
13 CHAIR REMPE: Okay.
14 MR. MCCARTIN: -- and it might have --
15 CHAIR REMPE: It must have gone right past 16 me.
17 (simultaneous speaking) 18 CHAIR REMPE: I don't see that and that's 19 --
20 MR. MCCARTIN: Right. Yes. But --
21 CHAIR REMPE: That's good.
22 MR. MCCARTIN: Right. And once again, 23 it's always informative to present the information to 24 others. And I think -- you know, once again, I think 25 we'll go back and re-read it again. There may be 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
171 1 other additions to make this point clear because 2 you're right, people will read some of those words.
3 In the sentence you read, it might imply we've agreed 4 with the risks.
5 CHAIR REMPE: Or the methodologies were 6 calculated.
7 MR. MCCARTIN: Well, that's what we want 8 to make clear. We agree with the methodology. There 9 is a significant review. The methodology is 10 relatively easy to review. Looking at how it's used 11 and how they develop the inputs, that is a much more 12 intensive review. And it will have to get to the --
13 as we have said, commensurate with the significance to 14 safety, there's certain things that, you know, if that 15 frequency averaged over the route has a large impact 16 on the risk, then that's got to be looked at and it's 17 got to be justified.
18 CHAIR REMPE: That will be clear in the 19 text you've added, which we're not seeing (audio 20 interference) 21 MR. MCCARTIN: I will say I hope it is, 22 but I completely promise that I'm going to go back and 23 re-read the document. And I think there are some of 24 these points that we want to be perfectly clear, not 25 only for the general public and others that might read 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
172 1 it. But for a potential applicant when they apply 2 things, you do understand that the methodology is 3 this. All these other things are going to need 4 careful review consistent with their significant 5 safety. That is a critical part of the endorsement 6 that I will say I'd like to think we are --
7 (simultaneous speaking) 8 MR. MCCARTIN: We will challenge ourselves 9 to re-read again and make sure that it is.
10 CHAIR REMPE: Thank you.
11 MR. MCCARTIN: Yeah.
12 MR. WHITE: Sorry. Bernie White, NRC 13 staff. I was making a note. So the next steps. Our 14 initial plan is to issue the commission paper by the 15 end of January and that's dependent upon, you know, 16 the outcome of the full committee deliberation and any 17 letter we might receive from it. Begin pre-18 application engagement with ANC in the first quarter 19 of 2024. ANC has indicated we'll receive a package 20 application to do a safety review in the fourth 21 quarter of 2024. And we're looking about a year -- a 22 year and change for us to issue our findings of that 23 safety review. The endorsement for the framework 24 would be dependent upon (a), when we issue the 25 commission paper and (b), whether or not it maintains 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
173 1 its status as an information commission paper.
2 MEMBER MARCH-LEUBA: So NRC is going to be 3 asking for the license, not DoD?
4 MR. WHITE: No. NAC -- NAC -- NAC 5 International --
6 MEMBER MARCH-LEUBA: Oh. They're the ones 7 that we --
8 (simultaneous speaking) 9 MR. WHITE: Right. So SCO has a contract 10 with BWXT to design and develop the reactor and build 11 it. BWXT contracted with NAC International. Not NRC, 12 NAC to do a package application.
13 VICE CHAIR KIRCHNER: Just for this 14 particular case because again, you're limiting it to 15 TRISO fuel design, AKA right now, the Pele. This is 16 only to move it to Idaho.
17 MR. WHITE: No. No.
18 VICE CHAIR KIRCHNER: It's to take it away 19 from Idaho?
20 MR. WHITE: Take it away from Idaho after 21 it's been used.
22 VICE CHAIR KIRCHNER: Through the route 23 that you showed us in the subcommittee or --
24 (simultaneous speaking) 25 VICE CHAIR KIRCHNER: So to get it to some 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
174 1 decommissioning place?
2 MR. WHITE: Yeah. So the reactor is going 3 to be designed and built by BWXT. The fuel is being 4 built by BWXT. They will be shipped separately. The 5 fuel will be shipped in an NRC-approved package.
6 We're working on that review right now. Standard 7 normal operating practice for package removal, right, 8 will be operated in Idaho. And somebody from -- jump 9 in if I make a mistake please. The intent is that the 10 safety review we do would demonstrate that it can be 11 done. Not the fact that they're going to move it from 12 Idaho to a specific location.
13 VICE CHAIR KIRCHNER: Okay, yeah.
14 MR. WHITE: And that's the reason why we 15 put in a safety review and not authorizing package 16 approval. Because if we were authorizing package 17 approval for an exemption, we would have to have an 18 environmental report, which would look at the route --
19 the exact route that was being taken. Even if we 20 didn't have a route-specific approach, it would look 21 at that route that was being taken and the 22 environmental consequences along that route for 23 shipment. That's the end of the NRC presentation.
24 MEMBER BALLINGER: Thank you. Are there 25 questions from the member before we go out for public 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
175 1 comment? Okay. Now's the time to go out for public 2 comment. If there are members of the public or in the 3 room, I guess, that would like to make a -- provide a 4 statement, please give us your name and your 5 organization and then make your comment. Since 6 there's no ground swell, I don't think we have any 7 comments. So that concludes the presentation and the 8 public comments. So we thank you very much for your 9 presentation. Our next step is to basically talk 10 amongst ourselves and decide our path forward.
11 CHAIR REMPE: So Ron, I think at this 12 time, do we want to let the Court Reporter be done?
13 MEMBER BALLINGER: Yeah, that was my next 14 thing was to decide what we want -- that was the next 15 thing. I don't think we need the Court Reporter. I 16 think we're done.
17 CHAIR REMPE: Yeah. So Court Reporter, at 18 this point, we want to thank you for your services and 19 you're done for this meeting.
20 (Whereupon, the proceedings went off the 21 record at 3:21 p.m.)
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
Advanced Reactor Content of Application Project (ARCAP) Interim Staff Guidance (ISG) Documents and Technology Inclusive Content of Application Project (TICAP) Guidance Documents Status ACRS Full Committee Meeting December 6, 2023
Purpose and Agenda
- Provide a high-level overview of the Technology Inclusive Content of Application Project (TICAP) Regulatory Guide 1.253 and the nine Advanced Reactor Content of Application Project (ARCAP) Interim Staff Guidance Documents
- Agenda High-level overview of ARCAP and TICAP structure Discussion of Licensing Modernization Project Discussion of Regulatory Guide 1.253 (TICAP Guidance)
Discussion of ARCAP interim staff guidance documents 2
Background - How to Access Draft Documents and Comments
- Revision 0 of ten draft documents were reissued in May of 2023 (ADAMS Package No. ML23044A038).
- Revision 1 of the TICAP guidance was issued is September of 2023
- All of the documents are available in Table 2 of the public ARCAP/TICAP webpage https://www.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/advanced-reactor-content-of-application-project.html ARCAP ISG Title ADAMS Regulations.gov # of Accession # Docket ID Comments Draft DANU-ISG-2022-01, Review of Risk-Informed, Technology-Inclusive Advanced Reactor Applications -
ML22048B546 NRC-2022-0074 68 Roadmap Draft DANU-ISG-2022-02, Chapter 2, Site Information ML22048B541 NRC-2022-0075 12 Draft DANU-ISG-2022-03, Chapter 9, Control of Routine Plant Radioactive Effluents, Plant Contamination and Solid ML22048B543 NRC-2022-0076 13 Waste Draft DANU-ISG-2022-04, Chapter 10, Control of Occupational Doses ML22048B544 NRC-2022-0077 2 Draft DANU-ISG-2022-05, Chapter 11, Organization and Human-System Consideration ML22048B542 NRC-2022-0078 12 Draft DANU-ISG-2022-06, Chapter 12, Post Construction Inspection, Testing and Analysis Program ML22048B545 NRC-2022-0079 9 Draft DANU-ISG-2022-07, Risk-Informed ISI/IST Programs ML22048B549 NRC-2022-0080 43 Draft DANU-ISG-2022-08, Licensing Modernization Project-based Approach for Developing Technical ML22048B548 NRC-2022-0081 8 Specifications Draft DANU-ISG-2022-09, Risk-Informed, Performance-Based Fire Protection Program (for Operations) ML22048B547 NRC-2022-0082 23 Draft Regulatory Guide 1404, Guidance for a Technology Inclusive Content of Application Methodology to Inform the ML22076A003 NRC-2022-0073 73 Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Advanced Reactors Draft Regulatory Guide 1404, Revision 1 - added Appendix B to provide additional guidance for expectations for a ML23194A194 NRC-2022-0073 30 probabilistic risk assessment (PRA) at the construction permit (CP) stage 3
ARCAP/TICAP Background
- Material to support todays meeting available at: ML23283A092 Includes ten comment resolution tables and ten guidance documents Guidance documents provide a comment identification that provides a reason for the change
- ARCAP/TICAP Public Webpage provides links to key meetings and documents associated with the development of these documents (see: https://www.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/advanced-reactor-content-of-application-project.html) 4
ARCAP/TICAP Background
- Guidance for developing and reviewing technology-inclusive, risk-informed, and performance-based non-light water (non-LWR) applications
- Being developed to support 10 CFR Part 50 and 10 CFR Part 52 applications Needed to support expected near-term non-LWR Part 50/52 applications using the licensing modernization project (LMP) process in NEI 18-04, Revision 1
- The NRC staff intends to revise the guidance per the final Part 53 rulemaking language 5
ARCAP Background
- Broad in nature and intended to cover guidance for non-LWR applications for:
combined licenses construction permits operating licenses design certifications standard design approvals*
manufacturing licenses*
- Encompasses TICAP TICAP is guidance for off-normal reactor states only.
o ARCAP encompasses everything needed for a license application.
- RG 1.253 does not currently address MLs and SDAs. ML and SDA applicants are encouraged to discuss their plans to use the RG with the NRC during the preapplication phase 6
TICAP Background
- TICAP scope is governed by the LMP-based process LMP uses risk-informed, performance-based approach to select licensing basis events, develop structures, systems, and components (SSC) categorization, and ensure that defense-in-depth is considered
- Industry developed key portions of TICAP guidance See NEI 21-07, Revision 1, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Utilizing NEI 18-04 Methodology, (ADAMS Accession No. ML22060A190)
- RG 1.253 (issued as DG-1404) proposes to endorse NEI 21-07, Revision 1, with clarifications and additions There are no proposed exceptions 7
Licensing Modernization Project Background
- LMP governing guidance documents:
- NEI 18-04 Revision 1, Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development, (ML19241A472)
- Regulatory Guide 1.233, Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors, (ML20091L698)
- RG 1.247. TRIAL - Acceptability of Probabilistic Risk Assessment Results for Non-Light Water Reactor Risk-Informed Activities, (ML21235A008) 8
Licensing Modernization Project Background
- LMP Process endorsed by the ACRS and the Commission
- SECY 19-0117, Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light-Water Reactors, (ML18311A264)
- Staff Requirement Memorandum ML20147A504
- The ACRS issued a letter dated March 19, 2019 (ADAMS Accession No. ML19078A240)
- Observed that the SECY paper proposes the next evolution of a licensing approach that has been developed over the past 30 years, and recommended that the Commission adopt the proposed approach 9
Licensing Modernization Project Background NEI 18-04 (LMP)
Figure 3-3. Flow Chart for Initial PRA Model Development
- LMP System Engineering Inputs
- Fundamental Safety Functions*
- Control heat generation
- Control heat removal
- Retain radionuclides
- Event sequences involving chemical attack such as air and water intrusion in an HTGR are considered when addressing the FSFs.
- Hazards Analyses
- Process Hazards Analysis
- Failure Modes and Effects Analysis
- Reactor Specific Initiating Events 10
LMP Approach to Safety Functions
- Fundamental Safety Functions: Safety functions common to all reactor technologies and designs; includes (1) control heat generation (reactivity), (2) control heat removal and (3) confinement of radioactive material
- Required Safety Function: A PRA Safety Function that is required to be fulfilled to maintain the consequence of one or more DBEs or the frequency of one or more high-consequence BDBEs inside the F-C Target MHTGR 11
ARCAP and TICAP - Nexus Outline Safety Analysis Report (SAR) - Additional Portions of Application Based on TICAP Guidance
- Technical Specifications
- 1. General Plant Information, Site Description,
- Technical Requirements Manual and Overview
- Quality Assurance Plan (design)
- 2. Methodologies and Analyses and Site
- Fire Protection Program (design)
Information*
- Quality Assurance Plan (construction
- 3. Licensing Basis Event (LBE) Analysis and operations)
- 4. Integrated Evaluations
- 5. Safety Functions, Design Criteria, and SSC
- Security Plan Safety Classification Audit/inspection of Applicant Records
- Cyber Security Plan
- 6. Safety Related SSC Criteria and Capabilities
- Calculations
- SNM physical protection program
- 7. Non-safety related with special treatment
- Analyses
- Fire Protection Program (operational)
- 8. Plant Programs
- System Descriptions
- Radiation Protection Program
- Design Drawings
- Offsite Dose Calculation Manual Additional SAR Content -Outside the
- Design Specs
- Inservice inspection/Inservice testing Scope of TICAP
- Procurement Specs (ISI/IST) Program
- 9. Control of Routine Plant Radioactive
- Environmental Report and Site Effluents, Plant Contamination, and Solid Redress Plan Waste
- Financial Qualification and Insurance
- 10. Control of Occupational Doses and Liability
- 11. Organization and Human-System
- Fitness for Duty Program Considerations
- Aircraft Impact Assessment
- 12. Post-construction Inspection, Testing and
- Performance Demonstration Analysis Programs Requirements
- Nuclear Waste Policy Act
- SAR Chapter 2 derived from TICAP guidance as supplemented by ARCAP interim
- Operational Programs staff guidance Chapter 2, Site Information
- Exemptions, Departures, and
- Safety Analysis Report (SAR) structure based on clean sheet approach Variances )
- Additional contents of application may exist only in the SAR, may be in a separate document incorporated into the SAR, or may exist only outside the SAR. 12
- The above list is for illustration purposes only.
TICAP and ARCAP Roadmap Common Guidance
- Applicability is now only for non-LWRs Recommends that light-water reactor applicants wanting to use ARCAP/TICAP guidance engage in pre-application discussions
- All ISGs provide applicant guidance and NRC staff review guidance in separate sections
- Removed references that did not have complete NRC staff review Appendices added to several ISGs to list in-development guidance documents that could affect future revision of those ISGs 13
TICAP and ARCAP Roadmap Common Guidance
- Importance of Principal Design Criteria (PDC)
TICAP guidance covers PDCs associated with the licensing modernization project (i.e., those associated with off-normal conditions)
ARCAP Roadmap ISG and associated ISGs (e.g., ARCAP Chapter 9) contains PDC guidance for normal operations RG 1.232, Guidance For Developing Principal Design Criteria For Non-light-water Reactors, (ML17325A611) provides additional guidance for reviewer consideration ARCAP Roadmap ISG recommends discussion of PDC during preapplication phase 14
Technology Inclusive Content of Application Project and Staff Endorsement in RG 1.253 15
TICAP - High Level Overview
- Goal is to develop technology-inclusive guidance that proposes an optional formulation of advanced reactor application content that is based on a risk-informed, performance-based approach for demonstrating that plant safety meets the underlying intent of the current requirements
- Guidance is intended to increase efficiency of developing and reviewing an application
- Scope is governed by the LMP methodology to facilitate a systematic, technically acceptable, and predictable approach for developing key portions of a designs SAR The LMP methodology provides processes for identifying LBEs, classifying and establishing special treatments for certain SSCs, and ensuring DID adequacy
- The LMP methodology is based on a full-scope probabilistic risk assessment (PRA)
All sources of radiological material, all hazards, all plant operating states, full analysis of scenario progressions (i.e., analyzed from initiator to radiological consequence) 16
TICAP - High Level Overview NEI 21-07 (TICAP) RG 1.253 Safety Analysis Report Outline (TICAP)
- 1) General Plant/Site Description and This RG endorses the methodology Overview of Safety Case described in NEI 21-07, Revision 1, as
- 2) Methodologies and Analyses one acceptable method for use in
- 3) Licensing Basis Events developing certain portions of the SAR
- 4) Integrated Evaluations for an application for a non-LWR CP or
- 5) Safety Functions, Design Criteria and OL under 10 CFR Part 50, or a COL, or DC under 10 CFR Part 52.
SSC Safety Classification However, the NRC staff provides
- 6) Safety-Related SSC Criteria and clarifications and additions to certain Capabilities statements in NEI-21-07, Revision 1,
- 7) Non-Safety-Related with Special Treatment as discussed below.
(NSRST) SSC Criteria and Capabilities
- 8) Plant Programs 17
TICAP Guidance 18
TICAP Construction Permit/Operating License Guidance 19
Construction Permit PRA Acceptability Key Points from RG 1.253, Appendix A:
- All sources, hazards, and plant operating states (POSs) should be addressed (i.e., identified and dispositioned) in the CP application, where dispositioned means each item is either:
Modeled in the PRA logic model,*
NOTE: Generally referring to the PRA Screened out of the PRA logic model with justification,* implies these three items Accounted for using risk-informed supplemental evaluations, or Accounted for using design-basis hazard levels (DBHLs) for hazards other than internal events
- As a minimum, the LMP-based CP application should be supported by an internal events, at-power, reactor PRA logic model, which represents the fundamental plant response model that:
helps demonstrate the applicants ability to develop an acceptable PRA logic model and establishes an acceptable foundation for upgrading the PRA logic model as the design progresses while acceptable for the CP stage of licensing, achieving only the minimum scope of the PRA logic model may not realize the full benefit of the LMP methodology
- The ASME/ANS non-LWR PRA consensus standard, ASME/ANS RA-S-1.4-2021, provides requirements and processes for defining the scope of the CP PRA logic model.
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Construction Permit PRA Acceptability Key Points from RG 1.253, Appendix A (continued):
- A self-assessment of the PRA logic model, screening analyses, and risk-informed supplementary evaluations helps reduce the need for in-depth NRC review This could be a peer review but is not required as such
- Further expectations The CP application should provide a plan for maintaining and upgrading the PRA during construction.
o Example: Replacing a seismic DBHL with a seismic PRA o CP holders are encouraged to keep the staff advised of changes to the PRA completion plan that significantly affect the design.
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Advanced Reactor Content of Application Project Interim Staff Guidance Documents - Overview 22
ARCAP Roadmap Overview Additional Portions of Application
- Provides guidance for other portions of the
- Technical Specifications
- Technical Requirements Manual application outside of ISGs including emergency
- Quality Assurance Plan (design)
- Fire Protection Program (design) plan, security, financial qualification and insurance
- Quality Assurance Plan (construction and operations) and liability
- Security Plan
- Includes four appendices
- Cyber Security Plan
- SNM physical protection program Appendix A - Preapplication Guidance
- SNM material control and accounting
- Fire Protection Program Appendix B - Applicability of Regulations to non- (operational)
- Radiation Protection Program light water reactors
- Inservice inspection/Inservice testing Appendix C - Construction Permit Guidance (ISI/IST) Program
- Environmental Report and Site Appendix D - Draft Documents Under Redress Plan
- Financial Qualification and Insurance Development and Liability
- Fitness for Duty Program
- Aircraft Impact Assessment
- Performance Demonstration Requirements
- Nuclear Waste Policy Act
- Operational Programs 23
Chapter 2 Overview
- Chapter 2 provides guidance on the scope and approach for selecting the external hazards which must be considered in the plant design.
- The selection of external hazards is to be informed by a probabilistic external hazards analysis, when supported by available methods, data, standards and guides.
- Chapter 2 limits the amount of information that needs to be provided in the SAR to that necessary to establish the design basis external hazards.
- Chapter 2 refers to existing site evaluation guidance (e.g., RGs) where appropriate.
- The guidance in Chapter 2 is based upon the requirements of 10 CFR Part 100, Subpart B.
- 12 comments received.
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Chapter 9 Overview
- Applies a performance-based approach for level of detail of information provided in the SAR related to control of routine plant radioactive effluents, plant contamination and solid waste 25
Chapter 10 Overview
- Applies a performance-based approach for level of detail of information provided in the SAR regarding the control of occupational dose 26
Chapter 11 Overview
- Supports Part 50 and 52 non-LWR applications with relatively traditional concept of operations Does not address remote or autonomous operations
- Guidance to applicants and NRC reviewers on:
Organizational staffing Qualifications Training Operator Licensing: staffing exemptions, licensing during plant construction (i.e., cold licensing), considerations for new programs, other exemptions
- NRC staff also incorporated human factors engineering (HFE) guidance to supplement LMP and TICAP guidance 27
Chapter 12 Overview
- Intended to provide guidance to the NRC staff regarding application content that would support making the finding that the constructed plant has met the applicable Part 50 and Part 52 regulations to support issuance of an operating license or authorization to load fuel, respectively
- ISG differentiates between 10 CFR Part 52 applicants that must include inspections, tests, analyses and acceptance criteria (ITAAC) and 10 CFR Part 50 applications that are not required to include ITAAC.
- Requirements to describe preoperational testing and initial operations in OL and COL applications are contained in 50.34(b)(6)(iii) and 52.79(a)(28), respectively.
- Provides guidance for:
post-manufacturing and construction inspection, preoperational testing (i.e., tests conducted following construction and construction-related testing, but prior to initial fuel load), analysis verification, and initial startup testing (i.e., tests conducted during and after initial fuel load, up to and including initial power ascension).
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ARCAP ISI/IST Overview
- The ISG provides guidance for developing risk-informed, performance-based ISI/IST programs for non-LWRs.
- The ISG guidance is based upon the use of a plant-specific PRA to identify the SSCs to be included in the programs.
- The ISI guidance is based upon the use of:
ASME BPV Code,Section XI, Division 2, Requirements for Reliability and Integrity Management (RIM) Programs for NPPs, for developing the ISI program using risk information and an expert panel.
ASME BPV Code,Section III, Division 5, High Temperature Reactors, for designs using high temperature materials and notes that ASME is developing a flaw evaluation Code Case for high temperature materials.
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ARCAP ISI/IST Overview (continued)
- The IST guidance is based upon:
Existing IST program approach, with additional guidance for passive components, and notes that ASME is developing a new OM-2 Code for inservice testing of components in new and advanced reactors, including non-LWRs.
Using plant-specific risk information to determine the scope of the IST program and proposed testing frequencies.
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ARCAP Technical Specifications -
Overview
- The text in the 10 CFR 50.36 regulations for TS content needs adaptation to correlate to the analysis and outputs of the risk-informed LMP approach described in NEI 18-04.
- Guidance addresses content for TS administrative controls section and recommended TS format 31
ARCAP Fire Protection for Operations-Overview
- 10 CFR 50.48(a) requires that each operating nuclear power plant have a fire protection plan that meets the requirements of either 10 CFR Part 50, Appendix A, Criterion 3 for LWRs or the applicants proposed principal design criteria that have been deemed acceptable by the NRC.
Although 10 CFR 50.48(c) - NFPA 805 - does not apply to non-LWRs, concepts associated with this risk-informed approach are included in the draft ISG
- The scope of this ISG addresses the review of the application content regarding the fire protection program for operations including application descriptions of:
Management policy and program direction and the responsibilities of those individuals responsible for the program/plans implementation.
The integrated combination of procedures and personnel that will implement fire protection program activities.
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Acronyms and Initialisms ADAMS Agencywide Documents Access DBA design-basis accident HFE human factors engineering and Management System DBE design-basis event HTGR high temperature gas cooled ANS American Nuclear Society DBEHL design-basis event hazard level reactor AOO abnormal operating occurrence (NEI 18-04) HPB helium pressure boundary ASME American Society of Mechanical DBHL design-basis hazard level ISG interim staff guidance Engineers (NEI 21-07) ISI inservice inspection ARCAP Advanced Reactor Content of DC design certification ISG inservice testing Applications ITAAC inspections, tests, analyses and DG draft regulatory guide ARCOP Advanced Reactor Construction acceptance criteria Oversite Process DID defense in depth LBE licensing basis event BDBE beyond design-basis event EAB exclusion area boundary LCO limiting condition for operation CDC complementary design criteria FOAK first-of-a-kind LMP Licensing Modernization Project CFR Code of Federal Regulations FR Federal Register LPSD low-power and shutdown COL combined license FSAR final safety analysis report CP construction permit FSF fundamental safety function GSI generic safety issue 33
Acronyms and Initialisms (continued)
ML manufacturing license PDC principal design criteria SRM staff requirements memorandum NEI Nuclear Energy Institute POS plant operating state SSC structure, system, and component NEIMA Nuclear Energy Innovation and PRA probabilistic risk assessment TEDE total effective dose equivalent Modernization Act PSAR preliminary safety analysis report TICAP Technology-Inclusive Content of NFPA National Fire Protection RFDC required functional design criteria Applications Association TIRICE Technology-Inclusive, Risk RG regulatory guide NLWR non-light-water reactor Informed Change Evaluation RSF required safety function NPUF non-power utilization facility TIMaSC Technology-Inclusive Management SAR safety analysis report of Safety Case NSRST non-safety-related special treatment SDA standard design approval TS Technical Specification NST no special treatment SE supplemental evaluation OL operating license SR safety related 34
NRC REVIEW OF A RISK-INFORMED METHODOLOGY FOR A TRANSPORTABLE MICRO-REACTOR PACKAGE Advisory Committee on Reactor Safeguards December 6, 2023 Bernard White, Senior Project Manager Jonathan Marcano, Senior Risk and Reliability Analyst Division of Fuel Management Office of Nuclear Material Safety and Safeguards 1
Agenda
- Overview of NRC requirements for spent fuel transport
- Methodology limitations
- Endorsement clarifications from ACRS subcommittee meeting
- Next steps 2
NRC Requirements for Spent Fuel Shipments
- Package approval and benchmarking
- Route approval
- Route selection criteria
- Safe havens
- Contact information
- Security
- Pre-Plan & coordinate w/States & Tribes
- Armed escorts
- Monitor shipments
- Advanced notifications 3
Methodology Endorsement
- Scope limited to:
- Two shipments by road only for Project Pele
- Specific route
- Tri-structural isotropic (TRISO) fuel only
- Widespread use would necessitate further discussion, such as
- Generic applicability and rulemaking
- Numerous (1 vs 100) shipments and co-located hazards
- Societal risk 4
Clarifications as Result of ACRS Subcommittee
- NRC staff added additional language to sufficiently describe the scope of the Methodology Endorsement
- Endorsement limited to approach and not the justification of numerical values (e.g., frequency estimates, dose calculations)
- Justification of numerical values will be addressed during the review of an application 5
Clarifications as Result of ACRS Subcommittee
- Applicant should consider cliff-edge effects (e. g., Regulatory Guide 1.233)
- Revised to include for material degradation, such as corrosion, oxidation, or radiation, as required by Title 10 of the Code of Federal Regulations 71.43(d) 6
- Safety review
- PRA
- Structural evaluation Drawing courtesy of NAC International
- Normal conditions of transport and
- Hypothetical accident conditions Methodology
- Thermal evaluation
- Normal conditions of transport and
- Hypothetical accident conditions Methodology
- Containment evaluation
- Shielding evaluation (dose consequences)
- Criticality safety
- Materials evaluation
- Protect the common defense and security
- Environmental review 7
Next Steps Issue Commission Pre-application Receive NAC Issue Safety Paper Engagement Package Review of (Information) with NAC Application Package Design January 31, 2024 First Quarter Fourth Quarter Early 2026 2024 2024 Methodology approval needed by NAC in January 2024 8
Development and Application of a Risk-Informed Approach for Regulatory Approval for Highway Shipment of a Microreactor Harold Adkins Garill Coles Steve Maheras Advisory Committee on Reactor Safeguards Meeting December 6, 2023 Washington D.C.
Purpose and Major Elements of Presentation
Purpose:
Provide background information on proposed risk-informed regulatory approach for the transportation of a transportable nuclear power plant (TNPP) in support of NRC draft safety evaluation
- 1. Brief description of the demonstration TNPP
- 2. Description of the proposed risk-informed regulatory pathway for TNPP transport and why it is needed
- 3. Overview of proposed risk evaluation guidelines
- 4. Overview of quantitative risk assessment process using an integrated assessment process based on probabilistic risk assessment (PRA) methods which includes use of sensitivities and uncertainty analysis and consideration of defense in depth (DID) and Safety Margin (SM)
- 5. Example results of applying the proposed PRA and risk evaluations guidelines to the demonstration TNPP using proposed approach
- 6. Brief clarification in response to questions raised during the November 17 ACRS meeting.
2
Project Pele TNPP Package used to Demonstrate Risk-Informed Regulatory Pathway
- Many advanced reactor vendors are developing TNPPs to make higher density energy readily available for:
Department of Defenses (DODs) domestic infrastructure resilient to electric grid attack Enabling rapid response during Humanitarian Aid and Disaster Relief (HADR) operations Clean, zero-carbon energy in a variety of austere conditions and off-grid locations
- These TNPP conventions would be factory produced, fueled, acceptance tested, and deployed as sealed units prepared for transport and retrieved for refueling and reapplication Semi-Tractor and Trailer Carrying Reactor Module
- Project Pele is a HTGR using HALEU UCO TRISO fuel Photo courtesy of News & Technology for Global Energy Industry, April 21, 2022 1 to 5 MWe, minimum of 3 years of full power operation https://www.powermag.com/green-light-for-project-pele-defense-departments-mobile-nuclear-microreactor-demonstration/
Comprised of a Reactor, IHX, Control, and Power Conversion Module Reactor Module contains a vast majority of radioactivity Acronyms: MWe - megawatt electric; HTGR - high temperature at EOL (remainder in IHX Module) gas-cooled reactor, HALEU - high-assay low-enriched uranium; UCO - uranium oxycarbide; TRISO - tri-structural isotropic; IHX -
Each module contained in and integral with separate intermediate heat exchanger; EOL - end of life; ISO- International ISO-compliant CONEX box-like containers Organization for Standardization; CONEX - container express 3
Need for Risk-Informed Regulatory Approach and Basis for Proposed Regulatory Approach
- A TNPP with its irradiated fuel contents prepared as a package for transport could be challenged to meet the entire suite of regulatory performance requirements in 10 CFR 71 as they are intended for thick-wall steel vessel for SNF transportation package It is anticipated that the TNPP will be capable of being deterministically shown to comply with the Normal Conditions of Transport (NCT) as outlined in 10 CFR 71.71 However, it may be challenging to demonstrate that the level of robustness of current proposed TNPP technology can fully meet the dose rate and containment success criteria after Hypothetical Accident Conditions (HAC) tests as outlined in 10 CFR 71.73 E.g., Sequential 30 ft free drop, crush, puncture free drop, 30-minute engulfing hydrocarbon fire, and water immersion tests
- Leverage compensatory measures, defense-in-depth approaches, and philosophies to establish equivalent safety. Also leverage consideration of TRISO, compact, fuel sleeve, core, and reactor structure related inherent retention and protection boundaries
- If Fissile Material or Type B package postulated HAC requirements (10 CFR 71.73) cannot be directly met, then other options such as 10 CFR 71.41(c), 10 CFR 71.41(d), or 10 CFR 71.12 (Exemption) are possible
- Preferred initial pathway identified by PNNL is the Exemption process that allows compensatory actions to protect the basis of exemption if acceptable risk is demonstrated Can apply to more than a single shipment unlike Special Package Authorization (10 CFR 71.41(d))
Flexibility in deviating from deterministic requirements compared to Alternative Environmental and Test Conditions 4
Reasoning Behind Selection of this Regulatory Approval Pathway
- Quantitative risk analysis approaches such as Probabilistic Risk Assessment (PRA) are used in risk-informed regulatory approaches for the NRC:
PRAs have been conducted since the 1970s for nuclear reactors starting with WASH-1400 and used since the 2000s for risk informed licensing applications.
PRA has also been used to assess:
Dry cask storage systems at a nuclear power plants (see NUREG-1864)
Transportation of spent nuclear fuel (SNF), most notably in NUREG/CR-4829, NUREG/CR-6672, and NUREG-2125 Risks of transporting SNF to the Yucca Mountain repository by truck and rail (DOE/EIS-0250)
- Proposed to NRC as an aid in developing a near-term approval pathway to drive Advanced Factory-Produced TNPP development and deployment
- Bridges the gap between the current regulatory framework (thick-wall steel vessel based) and the level of robustness of current proposed TNPP technology
- Provides buffer time for strategic regulatory considerations and possible rule making to accommodate advanced, transportable, microreactor conventions 5
Risk-Informed Regulatory Approval - Using Exemption Process
- Quantitative Risk Assessment - Demonstration of acceptable risk will require a quantitative assessment given (1) the complexities and uncertainties about package performance and (2) potential risk to public. PRA provides a rigorous quantitative approach Unlike the approval pathways used in the past (e.g., Trojan Reactor Vessel), it is unlikely that all accident scenarios can be screened based on likelihood.
- Risk Evaluation Guidelines - Quantitative risk assessments work best when supported by guidelines about acceptable risk as a key basis for regulatory decisionmaking
- However - risk-informed regulatory guidelines using PRA do not exist for transportation packages like they do for nuclear power plants (NPPs)
- That said - The proposed risk evaluation guidelines are based on the risk-informed decision making (RIDM) guidance in NRC 2008 report for nuclear material and waste applications (ML080720238)
- This guidance includes proposed quantitative health guidelines (QHGs) developed from the 1986 NRC Safety Policy Statement for the worker as well as the public
- Challenges remain in its implementation and the approach has not been endorsed for use by NRC as that would be a policy decision 6
Justification for Using Surrogate Measures for QHGs
- However, PNNL proposes using surrogate measures for QHGs proposed in the NRC 2008 RIDM report In the same way that Core Damage Frequency and Large Early Release Fraction are used instead of health effects for risk-informed applications for the current fleet as justified in NRC RG 1.200.
- Specifically, PNNL proposes formulating goals in terms of pairs of radiological dose and likelihood limits to an individual receptor which are more feasible to achieve:
Reduces calculational burden by eliminating determination of health effects Dose limits can be compared to other federal/international dose limits used in related contexts Determining likelihood and consequence as pairs provides added information for decisionmaking
- PNNL examined the use of dose consequence and likelihood from other applications NEI 18-04 provides risk-informed licensing basis development for advanced non-light-water NPPs DOE-STD-3009 applies risk ranking using dose and likelihood for nonreactor facility nuclear safety analysis NUREG-1513, NUREG-1520, and 10 CFR Part 70 Subpart H provide guidance used in Integrated Safety Analysis (ISA) for determining performance requirements for nuclear fuel cycle facilities The Q system in Appendix I of International Atomic Energy Agency (IAEA) Specific Safety Guide (SSG)-26 uses a reference dose to determine an upper quantity limit of radionuclides in Type A package (greater quantities require Type B)
Exposure time - 30 min 7
Proposed Risk Evaluation Guidelines Proposed risk evaluation guidelines compatible with NRC nuclear safety goals, Qualitative Health Objectives, and NRC-proposed QHGs in the NRC 2008 RIDM report For the Maximum Exposed Member of the Public For the Worker 8
Integrated Risk Assessment Process
- Uses probabilistic risk assessment (PRA) approaches and methods to the level of Bounding Representative Accidents
- A transportation PRA on the Project Pele TNPP was performed as a demonstration of the approach, applying the following steps:
1.Compilation of the TNPP design and Shipment Route Information -
which is information intensive and should be started early 2.Identification of the Package Safety Functions 3.Identification and Development of Accidents Scenarios 4.Definition of Bounding Representative Accidents 5.Development of Likelihood for Bounding Representative Accidents 6.Development Bounding Consequences for Bounding Representative Accidents 7.Comparison of Risk Results to Proposed Risk Evaluation Guidelines 8.Assessment of Sensitivities and Model Uncertainty 9.Assessment of Defense-in-Depth and Safety Margin 9
Summary of Demonstration TNPP PRA Risk Results
- Risk for the Bounding Representative Accident Results Shown Graphically For the Maximum Exposed Member of the Public For the Worker Note: BRA 9A and 9B - two kinds of flooded criticality events - are not shown here because their consequences were not calculated given that their likelihoods were determined to be extremely low.
BRA 10 - reactivity insertion caused by crash impact leading to criticality was not developed because it was anticipated the demonstration design will preclude (or design against) this possibility (e.g., using locking mechanisms) 10
Follow-up Topics From the Last Meeting
- 1. Cliff edge effects Criticality is an example because even though it occurs less than a frequency of 5E-07 per year it introduces a new phenomenon and might produce a dose greater than 750 rem dose.
Other factors that could impact risk are seen as having just incremental effects.
- 2. Modeling accident recovery The purpose of recovery is to mitigate occupational exposure Reduction of accident risk using recovery action (if possible) is not credited in the PRA Recovery can involve increased occupational dose for radiation workers. However, this dose is managed by a recovery plan under a radiation protection program and not under the Risk Evaluation Guidelines
- 3. Risk Evaluation Guidelines for multiple shipments The demonstration was done for a shipment in one year. It could be applied per TNNP for multiple shipments per year by increasing the accident frequencies proportionately.
- 4. Generic Applicability PNNL believes that the approach has generic applicability and in fact used a similar approach for DOE National Nuclear Security Administration for a package not meeting the codified requirements.
However, the approach should be demonstrated for other modes of transport (e.g., barge, rail, maritime) and other types of packages, because there would no doubt be differences and knowledge transfer.
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Follow-up Topics From the Last Meeting
- 5. Use of state-level accident rates versus route segment-specific accident rates Accident rate data are for trucks > 26,000 lbs. and legal weight trucks have a maximum weight of 80,000 lbs.
Trucks that would carry a Reactor Module would weigh approximately 150,000 lbs. and would require a state-issued permit to be operated on interstates, highways, and roads These permits are issued by a state to provide permission for an oversize or overweight vehicle and load to travel on a specific route, and potential hazards are mitigated through permit conditions such as requiring route surveys, the time of day and day of week during which travel is allowed, the number or spacing of the vehicles tires to distribute the weight of the load, the speed that the load can travel, the use of warning signs and lights, the use of escorts, etc.
Vehicle-mile data are not reported for specific locations Reported at the functional system level (interstates, other freeways and expressways, etc.) for each state, for rural and urban areas (DOT Table VM-2)
Reported by vehicle type for road type level (interstates, other arterials, other roads), for each state, for urban and rural areas (DOT Table VM-4)
Existing analyses are not designed to estimate accident risks at specific locations along the routes; rather, they are designed to integrate the risk over the entire route in a probabilistic manner consistent with the Risk Evaluation Guidelines SNF routing requirements in 49 CFR Part 397, Subpart D are specifically designed to minimize radiological risks, and consider available information on accident rates, transit time, population density and activities, and the time of day and the day of week during which transportation will occur to determine the level of radiological risk Base vehicle accident rates are combined with conditional probabilities of specific accidents to yield annual frequencies for entire route This is the same approach to accident frequency that was used in the Yucca Mountain EIS (DOE/EIS-0250), NUREG/CR-4829, NUREG/CR-6672, and NUREG-2125 Correlations between accident rate, target hardness, presence of rivers and streams, and other potential route hazards could be dealt with by a route survey and appropriate compensatory measures That said, an uncertainty analysis or sensitivity study is needed to explore the impact of the variability in the base vehicle accident rate on the risk.
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Applying the Proposed Risk Informed Licensing Methodology to a Draft NRC Safety Evaluation/Safety Analysis Report (SAR) Application For an applicant to receive transportation package licensing approval, they must develop a complete transportation package safety basis as part of their application that demonstrates reasonable assurance of adequate safety to the public, worker, and environment is provided. This would involve:
- An assessment of all influencing physical, chemical, and environmental loading conditions that would adversely affect package performance when considering all disciplines (structural, thermal, containment, shielding, criticality, operations, and acceptance) to verify maintenance of subcriticality, retention of radionuclide inventory, and adequate shielding and thermal management
- Application of all applicable consensus standards (e.g., ASME Codes and Standards), NRC Transportation (Division 7)
Regulatory Guides (e.g., Regulatory Guide 7.1 - 7.13), NRC Standard Review Plans (e.g., NUREG-2216), etc., and using Regulatory Guide 7.9 as standard format and content guidance of Part 71 applications to:
Deterministically demonstrate TNPP package compliance with dose rate and containment success criteria after Normal Conditions of Transport (NCT) as outlined in 10 CFR 71.71 Deterministically demonstrate TNPP package compliance with dose rate and containment success criteria after Hypothetical Accident Conditions (HAC) tests as outlined in 10 CFR 71.73 or fully exploit the design to determine the level of robustness and capacity to meet these requirements Develop legitimate compensatory measures while employing quantitative risk assessment using an integrated assessment process based on PRA methods which includes use of sensitivities and uncertainty analysis and consideration of DID and SM to reestablish equivalent safety only for those challenges identified through a rigorous screening of HAC related assessments Request that NRC consider an exemption following the process outlined in 10 CFR 71.12 and leverage the substantiating information from the previous step to protect the basis of exemption and demonstrate acceptable risk 13
How would a shipment of a TNPP be conducted?
l Three axle stretch trailer l l Four axle stretch tractor l A Reactor Module shipment would be conducted in a manner similar to current SNF shipments. This requires that:
- 1. The shipment is made in accordance with U.S. Department of Transportation Hazardous Materials Regulations (49 CFR Parts 171-180)
- 2. A state permit has been obtained for the oversize/overweight vehicle (about 150,000 lb.) that carries the reactor module This includes an evaluation of the proposed route and any alternative routes to verify that the transportation infrastructure can accommodate the truck and its load Alternative routes included in case of weather, road closures, etc.
- 3. The proposed transportation route and any alternative routes must meet the requirements of 49 CFR Part 397, Subpart D These routes are chosen to minimize radiological risks Interstates, and interstate bypasses or beltways around a city States may also designate preferred routes as alternatives or in addition to interstates, and interstate bypasses or beltways
- 4. The vehicle and its load have received a Commercial Vehicle Safety Alliance (CVSA) Level VI inspection This requires the vehicle and the load to be defect-free prior to departure.
14
How would a shipment of a TNPP be conducted?
Also required are that:
- 5. The proposed transportation route and any alternative routes have been evaluated from a security perspective NUREG-0561, Physical Protection of Shipments of Irradiated Reactor Fuel, or the Army equivalent Includes coordination with local law enforcement agencies and identification of safe parking areas in case the shipment is delayed en route due to mechanical problems, bad weather or hazardous road conditions or other unanticipated problems
- 6. All identified and specified compensatory measures are in place Time of day and day of week restrictions, rolling road closures, escorts fore and aft, etc.
- 7. Conducted only after the proposed shipment is coordinated with all affected States and Tribes as part of planning and communication Advance notification of the States and Tribes along the route, shipment tracking, and shipment status Emergency response plans and procedures in place
- 8. Ensuring that the shipment avoids bad weather and hazardous roads through constant communication with drivers and by carefully monitoring road and weather conditions and restricting travel when adverse conditions pose a threat to shipment safety Any delays (traffic, weather, mechanical issues, etc.) are coordinated in real time with downstream States and Tribes.
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Questions Discussion
References
- 10 CFR Part 71. 2023. Packaging and Transportation of Radioactive Material. Code of Federal Regulations, U.S. Nuclear Regulatory Commission. Available at https://www.govinfo.gov/app/collection/cfr/2023/
- 49 CFR Parts 171-180. 2023. Hazardous Materials Regulations. U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration. Available at https://www.govinfo.gov/app/collection/cfr/2022/
- 49 CFR Part 397. 2022. Transportation of Hazardous Material; Driving and Parking Rules, U.S. Department of Transportation, Federal Motor Carrier Safety Administration. Available at https://www.govinfo.gov/app/collection/cfr/2022/
- IAEA. 2022. Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material (2018 Edition), Specific Safety Guide No. SSG-26, Revision 1, International Atomic Energy Agency, Vienna, Austria, dated 2022
- NRC. 1975. Reactor Safety Study. An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants. Report No. WASH-1400 (NUREG 75/014). U.S. Nuclear Regulatory Commission, Washington, DC. October.
- DOE. 2002. Final Environmental Impact Statement for a Geologic Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca Mountain, Nye County, Nevada. Report No. DOE/EIS-0250. U.S. Department of Energy, February.
- DOE. 2014. DOE Standard - Preparation of Nonreactor Nuclear Facility Documented Safety Analysis, DOE-STD-3009-2014, U.S.
Department of Energy, Washington, D.C., November.
- NRC. 2002. Integrated Safety Analysis Guidance Document, NUREG-1513, U.S. Nuclear Regulatory Commission, Washington, D.C.,
May.
- NRC. 2007. A Pilot Probabilistic Risk Assessment of a Dry Cask Storage System at a Nuclear Power Plant. Report No. NUREG-1864.
U.S. Nuclear Regulatory Commission, Washington, DC. March.
- NRC. 2014. Spent Fuel Transportation Risk Assessment. Report No. NUREG-2125. U.S. Nuclear Regulatory Commission, Washington, DC. January.
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References
- NRC. 2015. Standard Review Plan for Fuel Cycle Facilities License Applications, NUREG-1520, Revision 2, U.S. Nuclear Regulatory Commission, Washington, D.C., February
- NRC. 2020. Standard Review Plan for Transportation Packages for Spent Fuel and Radioactive Material. Report No. NUREG-2216.
U.S. Nuclear Regulatory Commission, Washington, DC. August.
- NRC. 2020. Acceptability of Probabilistic Risk Assessment Results for Risk Informed Activities, Regulatory Guide 1.200, Revision 3, U.S. Nuclear Regulatory Commission, Washington, D.C., December.
- NEI. 2019. Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development. NEI 18-04. Nuclear Energy Institute, Washington D.C. August.
- Sprung JL, DJ Ammerman, NL Breivik, RJ Dukart, FL Kanipe, JA Koski, GS Mills, KS Neuhauser, HD Radloff, RF Weiner, and HR Yoshimura. 2000. Reexamination of Spent Fuel Shipment Risk Estimates. Report No. NUREG/CR-6672. Sandia National Laboratories, Albuquerque, New Mexico. March.
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Back Up Slides 19
Follow-up Issues From the Last Meeting Consideration of corrosion and oxidation:
Consideration of corrosion and oxidation and chemical interaction are typical concerns included in a hazard identification checklist and though these terms are not mentioned in the Hazardous Condition Evaluation worksheets in the Appendices of the report, these phenomena were considered when postulating ways that the containment could fail during transportation. Their impact is encompassed by random failures that might occur in containment (e.g., isolation devices).
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