ML25092A154
| ML25092A154 | |
| Person / Time | |
|---|---|
| Issue date: | 03/05/2025 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-0242 | |
| Download: ML25092A154 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
723rd Meeting Advisory Committee on Reactor Safeguards Location:
teleconference Date:
Wednesday, March 5, 2025 Work Order No.:
NRC-0242 Pages 1-16 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 723rd MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 WEDNESDAY 8
MARCH 5, 2025 9
+ + + + +
10 The Advisory Committee met via Video 11 Teleconference, at 8:30 a.m. EST, Walter L. Kirchner, 12 Chair, presiding.
13 COMMITTEE MEMBERS:
14 WALTER L. KIRCHNER, Chair 15 GREGORY H. HALNON, Vice Chair 16 DAVID A. PETTI, Member-at-Large 17 RONALD G. BALLINGER 18 VICKI M. BIER 19 VESNA B. DIMITRIJEVIC 20 CRAIG D. HARRINGTON 21 ROBERT P. MARTIN 22 SCOTT P. PALMTAG 23 THOMAS E. ROBERTS 24 MATTHEW W. SUNSERI 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 ACRS CONSULTANTS:
1 DENNIS BLEY 2
CHARLIE BROWN 3
4 DESIGNATED FEDERAL OFFICIAL:
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 CONTENTS 1
2 Opening Remarks by the ACRS Chair 3
1.1 Opening statement..............
4 4
1.2 Agenda and items of current interest 6
5 6
Incorporation by Reference of IEEE 603-2018 Rulemaking 7
(Update to Title 10 of the Code of Federal Regulations 8
(10 CFR) 50.55a(h))
9 2.1 Remarks from the Subcommittee Chair 7
10 2.2 Presentations and discussions with applicant 11 representatives and NRC staff.......... --
12 2.3 Committee deliberation........... --
13 2.4 Preparation of reports 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 P R O C E E D I N G S 1
8:30 a.m.
2 CHAIR KIRCHNER: Good morning. The 3
meeting will now come to order. This is the first day 4
of the 723rd meeting of the Advisory Committee on 5
Reactor Safeguards.
6 I'm Walt Kirchner, Chairman of the ACRS.
7 ACRS members in attendance in person are Ron 8
Ballinger, Greg Halnon, Robert Martin, Scott Palmtag, 9
Dave Petti, Thomas Roberts, Craig Harrington, Vicki 10 Bier, and we expect Matt Sunseri to join us after 11 lunch. In attendance virtually is Vesna Dimitrijevic.
12 And we have, from our consultants, Dennis Bley and 13 Charlie Brown joining us virtually.
14 If I've missed anyone, either ACRS members 15 or consultants, please speak up now.
16 Christina Antonescu of the ACRS staff is 17 the Designated Federal Officer for this morning's full 18 committee meeting. No member conflicts of interest 19 were identified, and I note that we have a quorum.
20 The ACRS was established by statute and is 21 governed by the Federal Advisory Committee Act, or 22 FACA. The NRC implements FACA in accordance with its 23 regulations.
Per these regulations and the 24 Committee's bylaws, the ACRS speaks only through its 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 published letter reports. Therefore, all member 1
comments should be regarded as only the individual 2
opinion of that member, and not a Committee position.
3 All relevant information related to ACRS 4
activities, such as letters, rules for meeting 5
participation, and transcripts are located on the NRC 6
public website, and can easily be found by typing 7
about us ACRS in the search field on the NRC's 8
homepage.
9 The ACRS, consistent with the Agency's 10 value of public transparency and regulation of nuclear 11 facilities, provides opportunity for public input and 12 comment during our proceedings.
13 We have received no written statements or 14 requests to make an oral statement from the republic 15
-- I'm sorry, the public.
16 (Laughter.)
17 CHAIR KIRCHNER: And the republic --
18 that's the broader public.
19 Written statements may be forwarded to 20 today's Designated Federal Officer, and we have also 21 set aside time at the end of this meeting for public 22 comments.
23 The transcript of the meeting is being 24 kept, and will be posted on our website.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 When addressing the Committee, the 1
participants should first identify themselves and 2
speak with sufficient clarity and volume so that they 3
may be readily heard. If you are not speaking, please 4
mute your computer on Teams. If you're participating 5
by phone, press star-six to mute your phone, and star-6 five to raise your hand on Teams.
7 The Teams chat feature will not be 8
available for use during the meeting. For everyone in 9
the room, please put all your electronic devices in 10 silent mode and mute your laptop microphone and 11 speakers. In addition, please keep sidebar discussing 12 in the room to a minimum, since the ceiling 13 microphones are live.
14 For presenters, your table microphones are 15 unidirectional and you'll need to speak directly into 16 the front of the microphone to be heard online.
17 Finally, if you have any feedback for the 18 ACRS about today's meeting, we encourage you to fill 19 out the public meeting feedback form on the NRC's 20 website.
21 During today's meeting, the Committee will 22 consider the following topic, incorporation by 23 reference of IEEE 603-2018 Rulemaking. And this is an 24 update to Title 10 of the Code of Federal Regulations 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 Part 50.55 AH.
1 With that, if there are not any opening 2
comments from members, we'll turn in a moment to 3
Member Tom Roberts. But before we do, I would just 4
point at that today's morning session is likely to be 5
brief. After we're finished with this, for the court 6
reporter we will not need you again until tomorrow 7
morning.
8 Tomorrow morning we will take up the VC 9
Summer subsequent license renewal application. This 10 afternoon is devoted to our planning and procedures 11 session.
12 So with that, I will now turn to Tom 13 Roberts who chairs our Digital INC and Electrical 14 Systems Subcommittee. Tom?
15 MR. ROBERTS: Thank you, Mr. Chairman, and 16 good morning. We held a meeting of the Digital INC 17 Subcommittee on February 20, about two weeks ago, to 18 receive a briefing from the staff on proposed 19 rulemaking that Walt mentioned to incorporate by 20 reference the 2018 version of the IEEE standard 603 to 21 regulation.
22 603 is titled the IEEE Standard Criteria 23 for Safety Systems for Nuclear Power Generating 24 Stations. And Title 10 of the Code of Federal 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 Regulations Part 50 subsection 55 AH currently 1
incorporates by reference the 1991 version of that 2
standard, as well as two versions of an earlier 3
standard of the IEEE 279.
4 While this rulemaking may seem 5
straightforward, the are several issues important 6
safety that are of interest to us. For one, the 2018 7
version of IEEE Standard 603 includes guidance for 8
mitigating common cause failures within a protection 9
or safety system, and the proposed rulemaking intends 10 to exclude all but the first sentence of this 11 guidance.
12 Also, there was an earlier attempt in 2015 13 to incorporate the latest version of IEEE 603 into 14 regulation, and this attempt resulted in several NRC 15 staff non-concurrences, three suggestions from this 16 Committee, and disapproval from the Commission to 17 proceed with the rulemaking.
18 The staff covered that history in their 19 briefing, including how each of the previous issues 20 was resolved into this relatively straightforward 21 proposed rulemaking.
22 Most of the discussion at our subcommittee 23 meeting related to the scope of the accompanying 24 guidance, that we replace the non-endorsed IEEE 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 guidance on common cause failure and resolve open 1
items from the earlier ACRS letter report.
2 During the subcommittee meeting, we 3
learned that the staff's rulemaking plan had changed 4
shortly before the subcommittee meeting. In the 5
original plan that we were presented before the 6
meeting, staff was planning to request public input on 7
the scope of guidance that should accompany the 8
revised rule, with the intent of writing the guidance 9
as part of the final rulemaking.
10 Shortly before our subcommittee meeting, 11 the staff changed that plan to instead draft the 12 accompanying guidance before requesting a vote from 13 the public. With this change, the staff worked to 14 prepare the proposed rulemaking doc which is not 15 complete, and a detailed review by this Committee is 16 therefore premature. Because of that, we are not 17 asking the staff to make a presentation to the full 18 Committee at this time.
19 So, I propose that our next action is to 20 review the draft guidance when the staff is ready to 21 provide it to us. At the meeting last month, they 22 estimated June. But it's yet to be written and I'm 23 sure the plan will evolve as they write the guidance.
24 When we get the guidance, we would 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
10 evaluate the need for the ACRS to review the guidance 1
in the same manner that we would consider the need to 2
review revisions to regulatory guidance. So, we have 3
a process that has us consider the need to have a 4
review before going out to public comment, and a 5
second review is whether we should -- or second 6
consideration is whether we need to review it after we 7
get it back and they've incorporated public comments.
8 So, we -- I reckon we follow that same 9
process. I'll review the guidance when it's provided, 10 and I'll provide a recommendation in the planning and 11 procedures portion of a full committee meeting as to 12 whether or not we should review the guidance prior to 13 release for public comment.
14 In the meantime, the ACRS staff has 15 reserved a time slot in June as a placeholder, in case 16 we determine a subsequent subcommittee review the 17 guidance is necessary.
18 So, in summary, it's very, I think, 19 premature to have more review of this, as the staff 20 has changed their plan to write the guidance before 21 they go out for public comment. I suggest we stand 22 back, let them follow their process, come back to us 23 when they've got the guidance ready, and then we'll 24 reconsider whether or not we should have a
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 subcommittee review and then a subsequent full 1
committee review at that time, before it goes out for 2
public comment.
3 Do members have any comments or questions 4
on the plan?
5 MR. HARRINGTON: Just one, Tom -- this is 6
Greg. I may have missed it, but why did we spend four 7
hours talking about this already, instead of waiting 8
for the public comments? Which is typical -- what we 9
typically do is wait for public comments.
10 MR. ROBERTS: Sure. The rulemaking is 11 provided to us, ask the public to suggest the scope of 12 guidance, but they were going to go out this month --
13 you know, as I understand it, at least -- after we 14 finished the meeting. So, they briefing us before 15 they went out for public comment.
16 MR. HARRINGTON: So, they requested the 17 meeting to brief us --
18 (Simultaneous speaking.)
19 MR. ROBERTS: They requested the meeting 20 to brief, because they said they were ready -- they 21 had an unexpected change in their plan, part of the 22 management review, as I understand it, to write the 23 guidance first.
24 (Simultaneous speaking.)
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
12 MR. HARRINGTON: I was virtual for the --
1 virtual for the meeting, and sometimes you miss 2
snippets and you don't have the opportunity to go back 3
and ask. Was there -- as I listened to it, I didn't 4
hear anything unique about this from the standpoint of 5
earthshattering safety issues, from the standpoint of 6
incorporating this IEEE into the rule. Did I miss 7
something there?
8 I understand the common cause issue, we've 9
litigated that and adjudicated that, and every other 10 word-itigated -- whatever word you want to put out 11 there. What was -- what do we expect, I guess, coming 12 down to -- is the public or the NEI and the industry 13 in line with this? Are they okay with it? Or do we 14 expect a huge pushback?
15 MR. ROBERTS: I think from my perspective, 16 that's all future, it hasn't gone out for public 17 comment. They've had some public meetings in 18 preparation for setting the guidance out, and they've 19 incorporated some of the NEI suggestions into the 20 proposed rulemaking.
21 MR. HARRINGTON: But there's no -- I mean, 22 from the results of those public meetings, there's 23 nothing too toxic about this? There an anticipation 24 of getting this done without a lot of extra time, our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 review time put into it, or is there some issue that 1
we have to really focus in on?
2 MR. ROBERTS: Yeah, I'll let -- the staff 3
is here, I'll let them answer, too. There's two 4
things I would point out, one is the scope of the 5
common cause failure guidance is something that may be 6
either future work when they're done with this 7
guidance. Because there is more, if you'll actually 8
be working on the next revision of the 603 --
9 (Simultaneous speaking.)
10 MR. HARRINGTON: Yeah, and this sort of 11 kicks the can down the road --
12 (Simultaneous speaking.)
13 MR. ROBERTS: It may kick the can down the 14 road. But we've had comments from this Committee last 15 year on this, on the treatment of common cause 16 failures, and this guidance will be a chance when 17 we'll sum that up. You know, things like where the 18 echelons of defense that used to be in the branch 19 faculty position via that NUREG CR 6303, where that 20 ends up -- you know, that may roll into this, it may 21 be a future effort.
22 But I think there is -- it's yet to come.
23 But I'm not aware of anything that's controversial, 24 beyond the questions that we were asking back in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 February. And I'll let Sam talk.
1 MR. BLAS: Just to --
2 MR. ROBERTS: Yeah, if you could either 3
stand under that green light there, or --
4 CHAIR KIRCHNER: You can, better yet, just 5
take this mic. You can just come over here.
6 MR. BLAS: Whatever you guys prefer, I'm 7
just here to support.
8 MR. ROBERTS: Yeah, come up -- just give 9
us your name and then, if you could just --
10 (Simultaneous speaking.)
11 CHAIR KIRCHNER: You can just come right 12 up here.
13 MR. BLAS: So, good morning. I'm Gilberto 14 Blas, one of the staff who presented on the 15 incorporation by reference of IEEE 603-2018. With 16 regards to the comment with regards to NEI, so we did 17 hold a meeting back in 2023 and we did receive a 18 letter from NEI supporting the incorporation by 19 reference of 2018 to the regulations at the time.
20 So aside from that, they have submitted 21 letters in response to the ADVANCE Act, 50.55 AH, but 22 that's being treated in parallel.
23 MR. HARRINGTON: Okay, so right now a 24 common cause issue, there's not a real hanging issue 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 out there?
1 MR. BLAS: Not at this time, that we know 2
of.
3 MR. HARRINGTON: Okay, thank you.
4 MR. ROBERTS: Yeah, I would observe that 5
the ACRS wrote a letter in 2014 on the previous 6
version, and there were three suggestions. And at 7
least one of them is going to be rolled into the 8
guidance that's yet to be written, and the other two 9
probably will also have some tentacles into the 10 guidance. So, we'll be interested in seeing how the 11 previous ACRS comments will be incorporated into the 12 guidance.
13 CHAIR KIRCHNER: Okay, further comment?
14 (No audible response.)
15 CHAIR KIRCHNER: Thank you, Tom. So, this 16 is somewhat unusual, and I see we have a number of 17 people online, so let me just explain why we're in 18 this situation, why we have a truncated meeting this 19 morning.
20 We provide, through the Federal Register, 21 a notice of our agenda well in advance of the meeting.
22 So, that ties us down a little bit in terms of our 23 flexibility. We try and write our Federal Register 24 notice as general as possible in anticipation of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 sometimes a change coming within the -- after we've 1
already sent that out for public notice.
2 So, we will close this morning session 3
here and then reconvene at 1:00 o'clock this afternoon 4
in our planning and procedures session, and that is 5
also open to the public.
6 And with that, we are in recess until 1:00 7
eastern time.
8 PARTICIPANT: It's been noticed to start 9
at noon.
10 CHAIR KIRCHNER: Okay, my mistake, let me 11 make that clear again. We will then take up our 12 planning and procedures session at 12:00 o'clock 13 Eastern Time. Thank you.
14 (Whereupon, the above-entitled matter went 15 off the record at 8:44 a.m.)
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