ML25098A099
| ML25098A099 | |
| Person / Time | |
|---|---|
| Issue date: | 03/13/2025 |
| From: | Robert Kuntz NRC/NRR/DORL/LPL3 |
| To: | |
| References | |
| NRC-0251 | |
| Download: ML25098A099 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
2025 Digital I&C Lessons Learned Workshop Docket Number:
(n/a)
Location:
teleconference Date:
Thursday, March 13, 2025 Work Order No.:
NRC-0251 Pages 1-117 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 2025 DIGITAL I&C LESSONS LEARNED WORKSHOP 4
+ + + + +
5
- THURSDAY, 6
MARCH 13, 2025 7
+ + + + +
8 The meeting was convened via 9
Videoconference, at 2:00 p.m. EDT, Robert Kuntz, 10 Facilitator, presiding.
11 PRESENT:
12 ROBERT KUNTZ, Facilitator 13 SAMIR DARBALI, Electronics Engineer, Division 14 of Engineering and External Hazards, 15 Office of Nuclear Reactor Regulation 16 TANIA MARTINEZ NAVEDO, Acting Director, 17 Division of Engineering and External 18 Hazards, Office of Nuclear Reactor 19 Regulation 20 DEANNA ZHANG, Senior Reactor Operations 21 Engineer, Quality Assurance and Vendor 22 Inspection Branch, Division of Reactor 23 Oversight, Office of Nuclear Reactor 24 Regulation 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 ALSO PRESENT:
1 EARL BERRY, Southern Nuclear 2
HARRY BURKE, Southern Nuclear 3
ALAN CAMPBELL, Nuclear Energy Institute 4
JEREMY CHENKOVICH, Dominion Energy 5
RON DISABATINO, Constellation Energy 6
PAREEZ GOLUB, Sargent & Lundy 7
JAMES HOLLOWAY, Dominion Energy 8
ASHLEY RICKEY, Constellation Energy 9
MARK SAMSELSKI, Constellation Energy 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 C-O-N-T-E-N-T-S 1
Opening Remarks.................
6 2
NRC Presentation 1: ISG-06 DI&C Licensing 3
Background/History/Efforts
........... 12 4
Industry Presentation 1: Project Highlights... 27 5
Industry Presentation 2: Industry Feedback 6
Industry Presentation 3: Future Projects 7
Public Comments..................
8 Adjourn 9
10 NEAL 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
(2:00 p.m.)
2 MR. KUNTZ: We'll go ahead and get 3
started.
4 My name is Rob Kuntz. I'm a senior 5
project manager in the Division of Operating Reactor 6
Licensing and the meeting today is a public workshop 7
between the industry and the NRC staff to discuss 8
lessons learned from digital instrumentation and 9
control licensing activities. It's an information 10 meeting with a question and answer session and the 11 purpose of the meeting is for the staff to meet 12 directly with individuals to discuss technical issues.
13 PARTICIPANT: Got a little echo.
14 MR. KUNTZ: Okay. Typically I'd mute the 15 chat, but I couldn't get that done today.
16 So before we get started one -- a couple 17 just admin things: For those that are guests of the 18 NRC you'll need escorted outside of the room to get to 19 the lobby or to the restroom or anything.
20 Also in case of emergency, you go out this 21 door, take a right, and then a quick left is the south 22 stairwell. We'll go down the stairwell and it will 23 exit us to the back of the building. I think we'll go 24 up to 355 and then take a first left down and then to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 the next road and congregate.
1 I've got meeting sign-ins. If everyone 2
could sign in so that if we do have to -- this will 3
into the meeting summary and also if we have to 4
somehow -- if we need to muster someplace in case of 5
an emergency we'll have that as well.
6 Since this is transcribed; we'll have 7
someone transcribing the meeting, it's important that 8
you identify yourself when you're speaking so that we 9
get that in the transcription as well.
10 The meeting today is scheduled to run from 11 2:00 to 5:00. And then we're also scheduled to meet 12 from 9:00 a.m. to 5:00 tomorrow. And tomorrow we'll 13 be the Two White Flint auditorium, not (audio 14 interference) those that are participating live here.
15 16 Typically we do introductions, but that's 17 probably a little much. Tania, why don't I turn it 18 over to you for opening remarks?
19 MS. MARTINEZ NAVEDO: Sure. Certainly.
20 Good afternoon. My name is Tania Martinez Navedo.
21 I'm the Acting Director for the Division of 22 Engineering and External Hazards at the Office of 23 Nuclear Reactor Regulation here at the NRC. Thank you 24 all for coming today.
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 So as we are observing that the operating 1
plants are going to operate beyond 60 years, digital 2
I&C upgrades are becoming more critical to maintain 3
plant safety. In that regard we understand the need 4
for clear guidance to enable high-quality applications 5
and successful review of license amendment requests.
6 This workshop provides an opportunity to 7
share what we have learned from using the licensing 8
guidance in ISG-06, and in particular the alternate 9
review process. The workshop is part of our 10 activities to improve the efficiency of licensing 11 reviews as part of the ADVANCE Act. The staff will 12 present their insights from recent licensing reviews 13 and will identify key areas of the application and 14 review. The staff will also discuss plans to add 15 clarity to the guidance.
16 So we look forward to the industry 17 presentations and invite engaging dialogue during the 18 open discussion portions of this workshop. Thank you 19 very much. I'll pass it onto Alan.
20 MR. CAMPBELL: All right. Thank you guys 21 very much. We have two speakers for our opening 22 remarks. First I'd like to ask Ron DiSabatino, who's 23 the Engineering Vice President from Constellation.
24 MR. DiSABATINO: Yes, thank you. I, one, 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 am thrilled to see this group of folks working 1
together on an incredibly important topic (audio 2
interference) hit the nail on the head. From my 3
perspective when you look at the demand for energy in 4
the country, nuclear is there to meet that demand.
5 And with the operation of our plants to 80 years the 6
upgrades to digital control systems is going to be an 7
absolute critical part of that. So the work that the 8
folks who are the best and the brightest in the 9
- industry, from our regulatory staff to the 10 licensees/vendors, are putting in now is going to 11 really pave the way for the future to really drive 12 that safety and reliability improvement that these 13 systems provide.
14 Just a little bit on my background: I've 15 been with Constellation for about 18 years; spent most 16 of my time in engineering roles early in my career at 17 Peach Bottom Station, and spent some time in 18 maintenance and then operations. I was Peach Bottom's 19 plant manager until coming into the corporate 20 engineering role about a year-and-a-half ago. And I 21 had the opportunity when I get back to Peach Bottom --
22 one of my favorite things to do was talk with the 23 folks in the control room and the technicians.
24 And I spent a day down at Peach Bottom 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 about two weeks ago and was up in the control room 1
talking to some reactor operators who I hadn't seen in 2
a couple of months. And so they asked me questions 3
about what I'm up to now and I kind of told them about 4
my role in corporate engineering. And when they 5
realized I was in corporate engineering, the first 6
thing they asked me about was the Limerick Digital 7
Modernization Project. They really were highly aware 8
of the potential improvements with the reactor 9
operator, at the controls in a transient or accident 10 scenario that project and those system modifications 11 really provide them.
12 And on Tuesday I had the chance to be down 13 at Calvert Cliffs Station, who's in a refueling outage 14 right now, and was talking with some I&C techs and it 15 was the same exact discussion. They were asking about 16 what I was up to and told them some of the projects 17 that our corporate engineering is working on. And the 18 I&C technicians, number one interest was the Limerick 19 Digital Modernization Project. They're the folks who 20 are responsible for maintaining equipment. They 21 perform the logic system functional testing.
22 And immediately they understood the 23 benefits of system testing and reliability. And gone 24 will be the days at a plant like Limerick with that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 project where a stuck contact on an AGASTAT relay is 1
a latent vulnerability that you would find through 2
testing and have to worry about fault exposure and 3
past operability. So the opportunity for the systems 4
and the reliability, the operational risk reduction, 5
and the improvement in reliability is really the best 6
opportunity we have as an industry to make a step-7 change improvement to safety and reliability.
8 We can do modifications to individual 9
systems and components to drive changes and 10 improvements, but a holistic step change in safety and 11 reliability is afforded to us by these digital 12 systems. Now is the time with working with a very 13 collaborative and open dialogue effort to really make 14 the requirements, right? It's about process should be 15 predictable and reliable for us to work through the 16 regulatory licensing process to ensure all the 17 requirements are met and the codes or standards are 18 aligned and referenced properly. We'll really set up 19 generations of work for our engineering and our 20 regulatory staff to go work through as every plant in 21 the country is going to want to follow suit and do 22 some more upgrades. Thanks.
23 MR. CAMPBELL: Great. Thank you, Ron.
24 And next we have Mr. James Holloway, who's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 the Engineering Vice President for Dominion.
1 MR. HOLLOWAY: Yes, James Holloway, Vice 2
President of Engineering for Dominion.
3 I would say ditto to what Ron said because 4
he took a lot of my (audio interference).
5 (Laughter.)
6 MR. HOLLOWAY: But when I was thinking 7
about this I said, hey, what we're here to do is 8
improve the response toward the reactor operator 9
controls. I was a design engineer and that was my 10 number one, hey, how can we equip that operator at the 11 board to respond to any situation we throw at them?
12 And we've been given a gift here recently, the ADVANCE 13 Act. If we leverage the ADVANCE Act and the 14 efficiencies that it will bring, I think we can take 15 digital to the future. It is our future.
16 So I think that's a key element to what 17 we're doing.
18 The lessons learned we gather here will 19 allow us to revise ISG-06 in the future and benefit 20 from some of the tools out there that are already in 21 the industry and other places like IEEE (audio 22 interference) that we can leverage to help us improve 23 our digital systems.
24 So it's a great time at Dominion. We're 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 licensing all of our plants to go to 80 years. V.C.
1
-- I mean North Anna and Surry are already licensed to 2
go to 80 years, and digital I&C upgrade is a bit part 3
of that. So we're investing a lot of money into the 4
process and working with the industry to implement 5
that.
6 So as Ron said, this workshop is a great 7
opportunity for us to collaborate, work together to 8
build a digital I&C system and a framework for the 9
future.
10 I'll leave you with a quote. I'm a quote 11 guy.
12 (Laughter.)
13 MR. HOLLOWAY: It says real generosity 14 toward a future lies in giving all to the present. So 15 in the present let's maximize this workshop where we 16 work together I think to build on the platform we've 17 laid and build to the future. So thank you.
18 MR. CAMPBELL: Thank you, James.
19 MR. KUNTZ: Okay. So this is Rob Kuntz 20 again. I should have mentioned at the start the kind 21 of agenda for today. We've already through the 22 opening remarks and introductions. Samir will go 23 through NRC background and then we'll get to the 24 industry's first presentation, take a break, and then 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 we'll get through the remainder of the industry 1
presentations before we adjourn today. And we'll 2
leaves periods of time in each session for public 3
comment after we get done with our process things.
4 The other intention we had so that we 5
could get through the presentation focused -- the 6
first topics that come up that aren't directly --
7 necessarily directly related to the presentation we're 8
going through our intention is to kind of park those 9
and then get to them tomorrow afternoon. So we'll try 10 to keep a running list of kind of open discussion 11 items that we'll get back to tomorrow afternoon is the 12 intention because tomorrow morning we'll get through 13 the remainder of the NRC presentations, lessons 14 learned, and then the afternoon tomorrow is intended 15 to be mostly an open forum for discussion. Okay?
16 Are there any questions before I turn it 17 over to Samir?
18 (No audible response.)
19 MR. KUNTZ: No? Okay. Pull you up here, 20 Samir.
21 MR. DARBALI: All right. So good 22 afternoon, everybody. Thank you for making the 23 workshop. I'm very glad to see so many people here, 24 a lot of familiar faces and other new faces. So this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 is great.
1 So for this presentation, it's just going 2
to be an introduction to what ISG-06 is. A lot of you 3
are familiar with the process. Some are fairly newer 4
so we just want to make sure everybody understands the 5
basics. Tomorrow morning the staff will present our 6
lessons learned from applying that.
7 So next slide, please? All right. So 8
James mentioned the ADVANCE Act. And so the ADVANCE 9
Act was issued last year and with that came an 10 improved or revised mission statement for the NRC. So 11 what do we do at the NRC? We protect public health 12 and safety and we advance the nation's common defense 13 and security for the benefit of society and the 14 environment. How do we do that? We do that by 15 enabling the safe and secure use of and deployment of 16 civilian nuclear energy technologies and radioactive 17 materials through efficient and reliable licensing, 18 oversight, and regulation. And that's kind of why 19 we're here today.
20 So next slide? So again, this workshop is 21 part of a broader effort to enable safe and secure use 22 and deployment of civilian nuclear energy 23 technologies. And for this workshop we're going to be 24 mostly looking at the efficient and reliable 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 licensing.
We'll cover some oversight and 1
inspections. And we're not going to be covering a lot 2
of the regulatory aspect, but the staff is working on 3
parallel efforts to improve our regulatory 4
infrastructure.
5 So our objective is for staff and industry 6
to share our lessons learned and our insights from 7
using ISG-06 Revision 2. We want to request your 8
feedback on those lessons learned and collaboratively 9
we want to identify challenges and areas where we can 10 improve on those processes.
11 Next slide? So this slide is intended to 12 show how our work today fits into the overall I&C 13 regulatory infrastructure organization. So that 14 regulatory infrastructure, we have our policy and 15 requirements on top. So that would be our regulations 16 in Title 10 of the Code of Federal Regulations as well 17 as a
Staff Requirements Memorandum from the 18 Commission. That's the regulatory basis for what we 19 do. We have our Regulatory Guidance for Industry. So 20 that's Regulatory Guides that endorse industry 21 standards or guides for best practices. And that's a 22 way in which the staff informs industry that those 23 regulatory requirements can be met.
24 And then we have our NRC staff review guidance 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 that we perform our licensing reviews. We need 1
guidance for the staff to be able to provide 2
consistent and reliable reviews.
3 So we have different documents that we use 4
depending on the technology used. So the Standard 5
Review Plan, that's for operating large light water 6
reactors. We have Branch Technical Positions which 7
provide additional specific guidance on various 8
topics. The I&C ISGs, I think they were developed 9
around the 2008 time frame. We've been able to take 10 a lot of that material and put them into permanent 11 guidance. So as we'll talk about more today and 12 tomorrow, we do want to take the guidance in the ISG 13 and make it more permanent in the SRV.
14 And then we have the Design-Specific 15 Review Standard for small modular reactors, the Design 16 Review Guide, which is performance-based, technology-17 neutral for advanced reactors. And for non-power 18 production and utilization facilities we have NUREG-19 1537. So again, the focus of our workshop is on ISG-20 06, which is part of the NRC staff review guidance.
21 Next slide? So the purpose and scope of 22 ISG-06. So ISG-06 defines the licensing process that 23 the staff uses to perform our licensing reviews or 24 license amendment requests that are associated with 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 digital I&C modifications. And it's geared for 1
operating plants or new plants when they become 2
operational. So it's more on the digital upgrade-type 3
of licensing review. It provides guidance for staff 4
activities that are performed before the LAR is 5
submitted, so personnel activities as well as review 6
activities during -- after the LAR has been submitted.
7 And then the staff uses those processes in 8
the ISG to evaluate that compliance with NRC 9
regulations and we use the ISG along with other review 10 guidance including that Chapter 7 of the SRV. One 11 thing to note here is the ISG was written mostly by 12 I&C staff for I&C staff. And as we have learned, a 13 lot of these modifications impact other technical 14 areas in the review and so we are trying to work 15 closer with those other technical areas like human 16 factors engineering and equipment qualification to 17 ensure that we are consistent in the expectations and 18 the material that we're trying to review.
19 Next slide? So ISG-06 Revision 1 really 20 came about I think as a part of a staff and industry 21 effort after the Oconee licensing review. There was 22 a lot of lessons learned from that and we're looking 23 at how to standardize that review process.
24 So when Revision 1 was developed a few 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
17 concepts were introduced. These concepts or these 1
terms are used in other licensing review areas, so we 2
want to be clear that the way we use the terms tiers 3
and phases are very unique to the ISG. So we're not 4
trying to use a generic term that's used in other 5
processes.
6 So tiers are really a way to enable a 7
graded approach in our review depending on how much of 8
pre-approved topical report platform is being 9
referenced in an application. So an application that 10 is going to use a topical report that has no changes 11 from it, that would be a Tier 1 in which the staff 12 would focus mostly on those application-specific 13 areas of the review. If there are changes to that 14 previously-approved topical report, then that would be 15 considered Tier 2. And if the application is going to 16 reference or it's going to be based on a platform 17 topical report that has not been reviewed by the 18 staff, then that would be a Tier 3 licensing review 19 and it would include more effort to perform that 20 platform-level evaluation.
21 So topical reports, they are not all the 22 same, but also we've been reviewing topical reports 23 for decades. And so there are some topical reports 24 that have gone through multiple revisions. So 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
18 topical report that has been recently revised and is 1
referenced in an application is more likely to be a 2
Tier 1 review, but if an application is going to 3
reference a topical report that was last revised 10 or 4
plus years ago, there are likely going to be 5
technology changes, process changes. That would make 6
it more of a Tier 2 review.
7 And the concept of phases really is a way 8
to divide or group those activities as far as they 9
relate to the licensing review process. So pre-10 application meetings or pre-submittal meetings are 11 what we call Phase 0 meetings. Phase 1 is that 12 license amendment request submittal. Phase 2 is 13 unique to the tier process and it's a continued review 14 or supplemental information.
15 Something unique about I&C reviews is that 16 since ISG-06 Revision 1 we've accepted applications 17 that are not complete. That's not the same for other 18 technical reviews within the NRC. So a lot of our 19 project managers, they see, oh, you accepted an 20 application that's not complete. Well, we've kind of 21 allowed for that process. And the idea is that 22 supplemental information is provided during the review 23 and it helps the staff to complete our evaluation.
24 And then Phase 3 is the implementation 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
19 the modification and NRC inspection.
ISG-06 1
references Phase 3, but it doesn't provide much 2
guidance because we have inspection procedures that 3
cover how to do those inspections.
4 Next slide, please? Okay. So Revision 1 5
of the ISG was used in the review of a few 6
modification efforts. Diablo Canyon being one and 7
Hope Creek being another. So the staff identified 8
areas where we could make improvements. And we 9
engaged with industry who had expressed that 10 significant efforts were being required to procure, 11 develop, implement, and go through -- all the way 12 through factory acceptance testing before the license 13 amendment was issued. And so we were looking at ways 14 in which we could make that process more efficient.
15 So as part of the Integrated Action Plan 16 for digital I&C, back in 2017 staff and industry, we 17 formed a joint group to find ways to get those lessons 18 learned and improve the process in ISG-06. So took 19 about two years before we were able to issue Revision 20 2 in late-2018. And the two major things that came 21 from that revision is we made the tiered review 22 process more efficient.
23 Before the tier process was based a lot on 24 the guidance on Branch Technical Position 7-14, which 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
20 covers planning, documentation, and also the review of 1
the design outputs from the life cycle phases. And so 2
we were looking at if we are going to be looking at 3
those design outputs, do we really need to focus also 4
on the planning? So we determined, well, we can focus 5
more on those design outputs. We don't need to put 6
that much focus on the planning. We also made other 7
improvements to make that tier process more 8
streamlined. But then we also introduced the 9
alternate review process, which kind of looks at, hey, 10 let's focus on the planning. What can we get or 11 leverage from that?
12 And that gets us to our next slide. Okay.
13 So the alternate review process, or ARP, was developed 14 with the thinking of how can we approve those designs 15 that we had already looked at: Diablo Canyon, Hope 16 Creek, in a manner that was more efficient and in a 17 manner that we can make our safety determination 18 earlier in the review? So that was the thinking at 19 the time.
20 And we looked at, well, what would an 21 application have to look like for us to do that? So 22 we said, well, the system has to be based on an NRC-23 approved topical report without changes. That's going 24 to enable the staff to do -- to focus strictly on the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 application side of that license amendment request.
1 The system has to be developed by a vendor or a 2
developer that has an NRC-approved quality assurance 3
program. And that enables the staff -- again, we 4
don't need to do a QA review for those processes. So 5
again, we focused on those application-specific 6
activities.
7 We introduced the concept of a vendor 8
oversight plan. And licensees have always performed 9
oversight of their vendors, but we were looking for a 10 way in which we could review a document that captured 11 all of those license procedures and activities that 12 ensure that the vendor is meeting their procurement 13 commitments. So we said, well, we'll look at a 14 summary of that Vendor Oversight Plan and that will 15 help us to take credit for the licensee performing 16 oversight of those implementation and test activities.
17 And another aspect for the alternate 18 review process was that the license amendment request 19 was going to contain all the information necessary for 20 the staff to make their safety evaluation. So we were 21 going to do away with that supplemental information.
22 So the idea was we get an application. It's complete.
23 It leverages all of the staff's previous approvals.
24 And so the intent was we can issue a safety evaluation 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 before implementation and testing. But also a review 1
would take normally two years. Maybe this is 2
something we can do in 14 months, plus or minus 2 3
months. But something that, hey, we can issue our 4
safety determination much earlier if an application 5
met that criteria.
6 Next slide? Okay. So what does the staff 7
focus on when we're using the alternate review 8
process? We focus on the system design to make sure 9
it meets the regulatory requirements. And that's true 10 also for the traditional tiered review. But for the 11 ARP we also focus on the development process. Again, 12 demonstrate that it is -- that system is going to be 13 developed and it's going to be of sufficiently high 14 quality.
15 Again, we look at the summary of the 16 licensee's Vendor Oversight Plan and additional 17 commitments from the licensee to perform vendor 18 oversight and implement those remaining life cycle 19 phases consistent with the license amendment request, 20 consistent with industry standards. And so again, 21 what happens after we issue a license amendment. So 22 final implementation and factory acceptance testing 23 would go into NRC inspection processes apart from the 24 site inspections.
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
23 Next slide? So this slide a lot of you 1
have seen some version of it. It has evolved. As we 2
keep using it we keep modifying to make sure it 3
reflects our latest understanding of the processes, 4
but the top part is the traditional review process.
5 The middle part is those licensee and vendor life 6
cycle development activities. And at the bottom it's 7
the ultimate review process staff activity.
8 One thing we added was the NRC pre-9 application meeting boxes because that's a key 10 important activity. And also the Phase 0 meetings 11 box. It used to say -- the first box used to say 12 modification concept and Phase 0 meetings. We 13 realized we still having Phase 0 meetings up to 14 submittals, so we kind of extended that there.
15 But the key differences are for a 16 traditional review process there is that Phase 0 17 opportunity to provide supplemental information --
18 sorry, Phase 2 opportunity to provide supplemental 19 information. So the licensee will provide a license 20 amendment request containing the -- probably the 21 system requirement spec and how the design is going to 22 meet those -- that regulatory criteria.
23 So the staff would start that review. And 24 then as we're doing the review the licensee's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 developing that Phase 0 output based on the design 1
output. And so the staff would review that 2
information once submitted. We perform regulatory 3
audits. And then typically around the time of factory 4
acceptance testing the staff would complete their 5
draft safety evaluation.
6 After that it may take a month or so, 7
depending on how big that safety evaluation is, for 8
that draft safety evaluation to go through internal 9
reviews, concurrences, approvals. That whole thing 10 has to be processed. And then as the system is moved 11 to the site the license amendment is issued and then 12 activities like site acceptance testing and 13 installation testing is part of a regional NRC 14 inspection.
15 For the alternate review process, because 16 as it was intended there is no opportunity to 17 supplement, it takes the licensee a little more time 18 to gather all the information to demonstrate 19 regulatory requirements are being met. So once that's 20 submitted -- that would be Phase 1. But once that LAR 21 is submitted the staff will perform the review. We 22 will do regulatory audits. And something new from the 23 alternate review process is there is going to be 24 vendor inspection. And some vendor inspections are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 going to be performed in parallel to that licensing 1
review.
2 It was intended that the license amendment 3
for the alternate review process would be issued 4
around the time of implementation before factory 5
acceptance testing. And so factory acceptance testing 6
would be covered by a vendor inspection of the vendor 7
and a regional inspection to ensure that the licensee 8
is performing oversight of the vendor during factory 9
acceptance testing. And those regional inspections 10 would continue once the equipment is sent to the site 11 again for that acceptance testing and installation 12 testing.
13 Next slide? This slide shows pretty much 14 the same information in a different way. In the 15 middle are those life cycle activities. On the left 16 are the traditional review process activities. On the 17 right is the alternate review process activities.
18 Pre-application meetings for both processes are going 19 to cover design concept and high-level system design.
20 And then for the traditional review process the 21 licensing review covers from the detailed design all 22 the way to factory acceptance testing. Regional 23 inspections would focus on site acceptance testing and 24 site installation.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 For the alternate review process the 1
licensing review would be focusing on the detailed 2
design up to part of fabrication. And then vendor 3
inspections could take place anywhere from the 4
detailed design all the way to factory acceptance 5
testing. Regional inspections would then cover 6
factory acceptance testing through site installation 7
and startup.
8 Next slide? Okay. I think this is my 9
last slide, but we used the alternate review process 10
-- first time it was used was for the review of the 11 Waterford Core Protection Calculator System. That was 12 issued in 2021. And we did have workshops in 2021 and 13 2022 to get more lessons learned from that review.
14 And since then we've been applying the ISG in other 15 licensing reviews as well as several pre-application 16 meeting engagements. And so we've shared some of our 17 lessons learned before and we're going to be 18 discussing those in more detail tomorrow.
19 But I believe that would be my last slide.
20 Thank you.
21 I
guess we're holding questions for 22 23 MR. KUNTZ: It's up to you. I mean, we 24 can --
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27 MR. DARBALI: I think time-wise -- I mean, 1
we can have -- we can answer a few questions if you 2
have any.
3 MR. KUNTZ: Anyone on the line have a 4
question for Samir? Sorry. This is Rob Kuntz.
5 (No audible response.)
6 MR. KUNTZ: Okay.
7 MR. DARBALI: All right. Thank you.
8 MR. KUNTZ: Thanks, Samir.
9 So our next presentation will be -- who's 10 going to go first?
11 PARTICIPANT: We'll be presentation 3.
12 MR. KUNTZ: Okay. I should have mentioned 13
-- again this is Rob Kuntz -- there's printouts of the 14 material from today on the back table. As well as 15 those that are participating virtually, the meeting 16 notice was updated this morning with the ADAMS 17 accession numbers to all the presentation materials.
18 So they're available at the public website. And in 19 the room there are hard copies (audio interference).
20 Sorry.
21 MS. GOLUB: That's okay. Thank you very 22 much.
23 I'm Pareez Golub. I work with Sargent &
24 Lundy. Thank you very much to the NRC for sponsoring 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
28 this workshop. As Samir noted, this is our third one 1
and we really appreciate as an industry having all of 2
the engagement with the staff in this area. It's an 3
important area -- as our initial speakers described, 4
very important area for sustainability, for safety, 5
for a whole series of good reasons. So important we 6
have these types of workshops and this type of 7
engagement.
8 Next slide? So for the agenda today I'm 9
going to talk a little bit about industry objectives.
10 For the first time we did this, which Samir was 11 referring to earlier, when the ISG-06 was -- when ISG-12 06 Revision 2 was formed, the alternate review process 13 and how we engaged with the NRC at that time. That 14 was about eight years ago. And then a little bit 15 about our current initiatives and our current 16 objectives and what that change looks like. I'll 17 refer to some of the digital licensing projects, we 18 kind of call them the modern ones. It's the ones that 19 really occurred after the alternate review process was 20 issued. And then some of the key challenges, lessons 21 learned, and then acronyms just I didn't clutter up 22 the slides with too many words.
23 Next slide? Okay. So from like a big 24 picture perspective, as Samir said, the Integrated 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 Action Plan had a bunch of different pieces to it.
1 The digital licensing process was one of those pieces.
2 So about eight years ago, in like the 2016-2017 time 3
frame, the industry, the NRC -- and there's actually 4
folks in the room right now that were part of all of 5
that work that took place. There was a number of 6
initiatives that we looked at. And for the digital 7
licensing process we had objectives that we really 8
wanted to go after. So we polled the industry and 9
this is what the industry really wanted.
10 We wanted regulatory finality earlier in 11 the project life cycle to lower project risk. So 12 waiting until after the factory acceptance test, 13 utility is -- we're up against their outages and 14 outages take a long time to plan. So there was a 15 desire for finality earlier in the project life cycle.
16 Looking forward to support
- that, 17 regulatory approval based on planning and requirements 18 documents versus the detailed design and testing 19 output documents. That was part of the previous 20 processes, the existing processes.
21 And then very important of course is 22 streamlined efficient licensing process. What was 23 very clear what needed to be part of the LAR. So 24 industry wasn't guessing. I think for anybody who 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
30 works in this space knows we have to really align the 1
design timeline, the design documents, and that whole 2
life cycle against the licensing documents and life 3
cycle and make sure that you have that alignment so 4
when it's time to submit the LARs, Samir was talking 5
about earlier, that LAR is complete. So to do that 6
you need to know up front what needs to be part of 7
that LAR? How do we really leverage the design 8
documents and make sure we have them ready when we hit 9
that LAR milestone date.
10 And then this last item is a very 11 important one, and it does align again with something 12 Samir said, that we in industry space -- at that time 13 we were really focused on more of a like-for-like 14 analog to digital system replacement. We weren't as 15 focused on changes that would impact tech specs, 16 significant main control room changes. We were really 17 more focused on the bigger picture changes to these 18 systems. So a little bit of a -- I'd say a very 19 different view than when we actually started doing 20 these projects and recognizing really the power of the 21 technology and the impact to safety and the impact to 22
-- Ron referred to operational risk reduction earlier.
23 When we really started recognizing that we started to 24 see that we needed to do more than a like-for-like or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 just addressing obsolescence-type of issues.
1 Next slide?
So current industry 2
objectives. Similar to the previous ones, still 3
looking for regulatory finality earlier in the life 4
cycle, still looking for the same types of documents 5
to be part of the LAR, still looking for a clear 6
licensing process where everybody knows what they're 7
supposed to do.
8 But because of this everybody getting 9
smarter, we realized that there's a lot more you can 10 d o w i t h t h e e q u i p m e n t.
11 And for longer-term operations to really -- to 12 optimize maintenance, to drive down operational risk, 13 to even workforce development. We're bringing all 14 kinds of new people into this business. If we're 15 going to get to 80 years we need technologies in place 16 that can support the people that are coming into our 17 business, into the regulatory, into the industry.
18 We realized that we need to make changes 19 to the main control room. We have obsolescence issues 20 there. We want to aggregate data and information. We 21 want visual displays that really allow the operators 22 to engage and do their work better.
23 There are I&C architecture changes that 24 are available. The folks did a great job that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 designed these reactors, but over time we've realized 1
that maybe we don't need all of that redundancy.
2 Maybe it's safer to have simpler plants, simpler 3
systems.
4 And then of course I know we've talked a 5
lot in this space about this, but surveillance 6
reduction is very important. Equipment that doesn't 7
need to be touched. We'd rather not touch because 8
there's always the opportunity to introduce human 9
error when you're opening up cabinets where equipment 10 is functioning perfectly. So reducing surveillances, 11 eliminating surveillances by credited self-12 diagnostics. And then of course other changes as 13 well.
14 That one at the bottom is kind of a big 15 one that we're just now recognizing, that we've been 16 so focused on replacing the equipment, but once we 17 have these massive installations in place there's 18 going to be changes to those installations, right?
19 There may be small changes, bigger changes, but as 20 operators use the equipment there's going to be 21 changes. So we need to make sure that the process, 22 the regulatory process also addresses those installed 23 logic/software changes and there's a clear efficient 24 process to do that as well.
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33 Next slide, please? So this slide, it 1
kind of covers similar to what Samir was covering. We 2
see the box for ISG-06. It was issued in 2018, so we 3
were working on it the couple years previously. The 4
NRC did allow us to provide good input to them as that 5
process was developed. We look forward to engaging 6
with the staff again as -- now that we have a little 7
runway and we know what's going to happen when we 8
start to use these processes, and especially engage in 9
these projects. I think we're in a better position 10 now as an industry to understand what we're up 11 against. And the NRC is as well. So I think we --
12 once again, we're looking forward to providing that 13 input to the NRC.
14 Waterford was first considered very 15 successful I think by the utility, who's going to be 16 speaking tomorrow, as well as by the regulator in 17 terms of a pilot project for the alternate review 18 process. It was a smaller pilot project.
19 Next up we have Limerick and Turkey Point.
20 just say Turkey Point was submitted and withdrawn, but 21 it had nothing to do with the regulator, with the 22 licensing process. There were other issues going on.
23 Limerick was the larger scale demonstration project 24 for ISG-06, for the alternate review process. Mark, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 who's here, is going to be talking about that next.
1 Peach Bottom, we have again a smaller 2
project. This is more of a like-for-like replacement.
3 That's the first-time use of a new platform.
4 And then I have many in planning, because 5
if you look around the room there's folks representing 6
multiple utilities here: APS, Dominion, Southern.
7 There's lots of folks who are looking forward and have 8
taken phased approaches to their modernization work at 9
their sites. So there's a lot of folks looking to see 10 how this process develops, who want to participate in 11 this work, who are looking at the precedents that are 12 being put into place and really wanting to take 13 advantage of them. So a lot of work coming down the 14 pike for our industry in this space.
15 Next slide? So this a little bit of a 16 laundry list of different topical areas that as we 17 have been working with these early projects, early 18 movers. Of course very difficult to be a first-of-a-19 kind project, very difficult to be an early mover, 20 which I know I don't need to say to the folks from 21 Constellation here, and Westinghouse here. Not easy 22 to be an early mover. But the great thing for the 23 industry, for the regulator is there's a lot of 24 lessons learned that are coming out of this work that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 we really want to take advantage of as we start 1
thinking through really a pretty large series of 2
projects that are coming down the pike.
3 So these are -- I'm not going to name, but these 4
are the different topics I'm going to talk about in a 5
couple minutes.
6 Okay. Next slide? So the first one is 7
plant licensing basis. So this is -- I'm going to say 8
this. It's going to sound like I'm talking to the 9
industry, but I'm really saying it for everybody, 10 because it's actually been the NRC that has done a 11 nice job of in a way pointing out where in industry --
12 we maybe have been treating NRC guidance that's really 13 written for NRC reviewers to do their work. In a way 14 we've been treating it like an industry procedure or 15 like it's regulation. And it is not, right?
16 It is a framework. It is an approach.
17 But there's a lot of space where we need to understand 18 what is our licensing basis? Do GDCs apply to us?
19 Did our plants go online before 10 CFR 50.34(f) was 20 even applicable? Right? We need to understand what 21 is our licensing basis? And then based on that, based 22 on the plant, based on the UFSAR really make good 23 decisions on what we're going to include in the LAR, 24 whether or not we're going to say that we're going to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 commit to IEEE 603 as an example, or commit to other 1
-- decide that we want to do our HFE in accordance 2
with NUREG-0711. I mean these are decisions that 3
plants need to make, and they need to make it 4
understanding what their licensing basis is.
5 And as we've been told kind of repeatedly 6
by the regulator, if you include it, we will review 7
it, right? That's the job. So it's not that people 8
are going to say you don't need to include that, 9
right? We have to -- we as the industry need to make 10 that decision. And I do appreciate some of the 11 guidance we've gotten from especially the project 12 management staff at the NRC to help us think through 13 that a little bit better.
14 The next one is scope of LAR versus 50.59.
15 And this kind of came up early one of these early 16 projects where the NRC asked very specifically what is 17 the scope of your LAR and what is the scope of what 18 you're changing under 50.59? And again, in industry 19 space we really need to think through that early in 20 the project life cycle so that when we come in to talk 21 to the NRC about what we want to include in our LAR, 22 it's really focused on that which needs to be 23 included, not just sort of whatever is happening with 24 the modification.
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37 So one thing that we're thinking about in 1
industry space is really doing good 50.59 work earlier 2
in the design life cycle, earlier in the project life 3
cycle. Right now we tend to do sort of like an early 4
screening, early evaluation, but then do the big one, 5
the full one later. We kind of want to change that 6
because what we're thinking now is that that screening 7
that's done is really critical to determining the 8
scope of the LAR.
9 And there may be stuff that we can do 10 under 50.59 which we've been submitting to the NRC 11 because we assumed we had to. So I think there's a 12 good lessons learned for industry in that space.
13 Let's make sure we know how -- do our screening, get 14 our scope of the -- what needs to be done in the 15 evaluation. Cut it down to that which is essential.
16 And then based on that determine what the scope of the 17 LAR is. And this is going to be even more important 18 as we start thinking about changes we want to make to 19 installed systems.
20 I know the staff has always said that if 21 you're doing this type of work and it's an edge case 22 and you're concerned am I getting carried away with 23 putting stuff under 50.59, pre-submittals meetings, 24 and that type of stuff, yes, the staff has always been 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
38 very supportive to come in, have that conversation.
1 And then as part of that the preliminary 2
hazards analysis is maybe a polite way of saying CCF, 3
but that's another item that we need to think about 4
earlier in the design life cycle because the impacts 5
of discovering later that what you think is your 6
argument for determining that CCF is not credible, of 7
if it is credible, your coping analysis -- the impacts 8
of that later in the project, whether it's for the 9
regulator doing the review or for the utility/licensee 10 thinking about the project can be pretty significant.
11 So that's something else that we're going to be --
12 we're going to take as a lessons learned in industry 13 is to really do that kind of work really in the life 14 cycle and understand the impacts of it.
15 Next slide, please?
16 MR. TANEJA: Pareez?
17 MS. GOLUB: Yes?
18 MR. TANEJA: A quick question. So what 19 you're saying is a one modification project could be 20 split into a 50.59 mod, and then LAR, and then a one 21 project?
22 MS. GOLUB: Yes.
23 MR. TANEJA: So not just like a one 24 project? Because LAR is needed for a portion of it, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 so everything becomes LAR. But you're saying you can 1
selectively break it out?
2 MS. GOLUB: Yes.
3 MR. TANEJA: Okay. All right.
4 MS. GOLUB: Yes, based on the screening.
5 Based on what screens in --
6 MR. TANEJA: Right.
7 MS. GOLUB: -- that's really determines 8
the content of the LAR. Because we've been kind of 9
making assumptions that something's going to be a LAR, 10 the concern is that we may be screening in too much 11 because we haven't really gone through and done that 12 systematic really careful methodical look at the 13 content.
14 MR. TANEJA: Yes.
15 MS. GOLUB: Next slide? So human factors.
16 Again, some of these early mods this has been a bigger 17 issue. Right now in control rooms all over the U.S.
18 there's a lot of equipment that is obsolete. I mean, 19 everything works fine. I don't want to -- it's not a 20 safety issue. But there is obsolescence concerns that 21 need to be dealt with. And Ron was talking about this 22 earlier, but if you -- I've heard the folks at 23 Limerick, their operations staff talk about the impact 24 of this modification on the control room. It's very 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
40 compelling. And I know there are folks at the NRC 1
that heard similar things.
2 I know I saw on the presentation on HFE 3
there was a reference to some of the work done with 4
INL and their HSSL. And hearing the operations staff 5
talk about it, very powerful. Great opportunities to 6
really drive down risk in that space. So we want to 7
take advantage of it. We want to have that type of 8
great data, visuals, all of it for our operators and 9
the important work they're doing.
10 But in this space this is kind of a case 11 where in some ways we made assumptions about what we 12 needed to submit to the NRC based on what we read in 13 some of the guidance documents. And so all I'm going 14 to say is -- I'm not going to go through this whole 15 thing. Rick Paese is in the back. If anybody has a 16 question about this, please stop by, talk to Rick. He 17 can talk your ear off on this particular topic.
18 But the big item is that 10 CFR 50.34(f) 19 is not required for most of the operating fleet. And 20 you need to look at your -- this kind of goes back to 21 the first slide on plant licensing basis. You really 22 need to look at your licensing basis, look at what you 23 committed to and the confirmatory orders, understand 24 what your commitment are, and then based on those 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
41 commitments, based on what you have there, you can 1
make decisions on what you need or not need at all to 2
submit to the NRC as part of your LAR.
3 So we need to get a little savvier in 4
industry space. And again, we have the opportunity to 5
share our thinking with the staff if we feel we need 6
to from a risk reduction perspective. So I think this 7
is a very good example of -- again, this was another 8
case where I think the NRC gave us some careful 9
feedback along the way regarding thinking about what 10 we need to do in this space.
11 Next
- slide, please?
Equipment 12 qualification. So earlier Samir was talking about the 13 fact that the alternate review process, one of the 14 principles was that it was a single submittal. And as 15 we have used the process from the very beginning we 16 have not been able to do that in industry space. We 17 have not been able to do a single submittal, in part 18 because of EQ. As it turns out it's very difficult to 19 identify every single piece of equipment that you need 20 for the modification right at the beginning, right 21 when you're going to submit your LAR. There's always 22 equipment that is identified later, perhaps is 23 qualified later. Maybe you want to assemble your 24 cabinet and then qualify it. So this EQ item is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
42 pretty difficult.
1 In one utility's case the results are not 2
going to be complete before the SER is projected to be 3
done, so a license condition was used. Putting 4
together the license condition was pretty challenging, 5
pretty challenging. So for industry we kind of see 6
this as a good area for an enhancement, maybe a change 7
in the licensing process.
8 Our recommendation is that we treat 9
equipment qualification similar to the way we treated 10 the factory acceptance test where, as Samir described 11 earlier, that's really covered by the licensee's 12 vendor oversight program. And then ultimately of 13 course it's in NRC inspection space. But taking that 14 out of the license amendment review space -- I mean, 15 it's not that it's not reviewed at all. I'm talking 16 about the ultimate last report. Taking that out of 17 the LAR review eases up some of the scheduling issues.
18 And then of course some of the difficulties when you 19 don't have that certainty and need to go down a 20 different path, like a license condition, which is not 21 easy. So this is really I think a great area and I 22 think we have alignment maybe with the NRC on this one 23 as well. We've talked about this a lot.
24 Precedent licensing actions. So again as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 discussed earlier, approved topical reports, these 1
approved topical reports, we want to leverage the 2
topical report and any predecessor licensing action.
3 So it may not be a topical report. It may be another 4
licensee's LAR, the -- again, some of these 5
demonstration project, early movers, they're going to 6
set precedents that we want to be able to take 7
advantage of in industry, because part of making this 8
efficient is -- it's kind of me-too'ing it, right?
9 And so we want to be able to do that.
10 We struggled in -- with some of these 11 early movers to really apply these precedent licensing 12 actions. In the case of topical reports, yes, the 13 topical report is approved, but there are often things 14 that say the approval is for the platform but not for 15 the application. Or maybe it's for parts of the 16 application but not the full application. And we've 17 struggled on -- in terms of how do we best apply that 18
-- the SER? In some cases the SERs for these 19 different topical reports are written very 20 differently. And so we read it and we think, oh, 21 well, that means we can apply it in this case, but 22 that's not what -- that's not really what it meant.
23 And so I think having -- for the NRC's 24 consideration having some consistency maybe in the way 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 they're written or even having a process for the 1
topical report reviews specific to I&C so that all of 2
us understand how that report is -- should be written, 3
what the information is the NRC is looking for, and 4
then what the -- really what the limitations are for 5
the licensees and the OEMs who try to use them.
6 And the same for previous licensing 7
actions. I'll say that we need to have better clarity 8
on how do we use those actions? Some of the 9
information is of course proprietary, but even when 10 you have access to that it can be difficult to 11 understand how to use them. And as we move forward 12 especially with the sort of -- we're going to have a 13 lot of applications, right, that are going to need to 14 use these -- use the precedents that are coming down 15 the pike. We need to understand how to apply them.
16 Next slide? So the top item is really 17 thinking about -- and I know that's why we're all 18 sitting here is because we do want to reassess the 19 alternate review process, the tiered processes. The 20 NRC has been very flexible in terms of trying to meet 21 the industry requests to use the ARP even though we 22 didn't exactly meet the prerequisites for it. So 23 we've been calling it -- the term we've been using is 24 hybrid. These are hybrid processes.
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45 But I think from a big picture perspective 1
what we've realized with these -- all of these early 2
movers is we just need to think through what does this 3
look like? How do we make sure that the range of 4
plant changes -- whether it's a simple logic change 5
for an existing installation or it's a full system 6
replacement, how does that really look in the 7
licensing process? How do we make sure that we in 8
industry space, we understand what the expectations 9
are? And again, we can make sure that our projects 10 and our products are ready and able to support the 11 licensing timeline, that they can go into the LAR.
12 Vendor oversight. So vendor oversight, as 13 Samir said, this was a critical piece of the alternate 14 review process, making sure that if the NRC's review 15 and approval was based on the planning and 16 requirements documents that the licensee had the 17 obligation to make sure that the OEM continued to 18 follow their NRC-approved process. And of course the 19 NRC would inspect all of that as well. But this has 20 become a big item for licensees, and I think it's a 21 positive. Actually I think this is a good opportunity 22 for everybody to understand what is happening with the 23 platform development.
24 But the item I wanted to mention here is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 that there was a pre-submittal meeting and Greg 1
Galletti -- I'm not sure if he retired. He did?
2 Okay. Yes.
3 So Greg Galletti at one of these pre-4 submittal meetings listed off like five items he said 5
should be part of the vendor oversight, the Vendor 6
Oversight Plan summary which is included in the LAR.
7 This is the ones that I had captured from that 8
meeting. But I think it's important that we provide 9
licensees guidance for what should be in the VOP?
10 What should be in the summary? And I know we've 11 talked about that in workshops before, but these 12 items, if this is what the staff would -- wants to 13 make sure is covered in the summary, then we need to 14 capture that in the new process.
15 Okay.
Next slide?
Pre-submittal 16 meetings. I think this is an area where industry and 17 NRC we generally thought pre-submittal meetings have 18 been a very effective tool to reduce regulatory and 19 project risk. Give the industry a chance to come in, 20 talk through some of the hard areas, get feedback from 21 the NRC, make sure that we're going down the right 22 path in terms of what we want to submit or not submit 23 to the NRC, make sure it's the right documents.
24 Really appreciate the NRC's engagement on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 these pre-submittal meetings, both from the reviewers 1
and the leadership. These meetings, they're well-2 attended. NRC has been really well-prepared. And 3
I'll tell you, on the licensee side of the house 4
there's a lot of work that goes into those pre-5 submittal meetings: putting together the slides, the 6
dry runs. It's a production. So we really appreciate 7
the staff's engagement in this area.
8 Having gone through a whole series of 9
these meetings, submitted the LAR, and then working 10 our way through the review process, we do have some 11 ideas about how to maybe make it more effective, make 12
-- kind of get a little more bang for the buck from 13 everybody concerned.
14 One thing we recognize is sometimes we 15 have these pre-submittal meetings but the folks that 16 eventually end up being the prime reviewers for the 17 LARs aren't in the pre-submittal meeting. So industry 18 is making a good-faith effort to explain things, to 19 get the feedback. And then at the back end we don't 20 always have those folks who have heard all of those 21 early discussions. They're now reviewing that LAR 22 product and they don't have that -- all of the 23 insights that came before. So one thing we want to 24 think about is how do we bridge that gap? Is there 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
48 better tool we could use to communicate, that type of 1
thing?
2 The meeting minutes that come out of these 3
meetings, they're usually at a very high level. Is 4
there a way we can capture a little more of the 5
discussion, maybe more of the flavor of the comments, 6
of the questions? When we go back and we read those 7
major modification minutes -- I mean, we capture our 8
own notes, but go back and read them, we don't always 9
see a lot of the information that was discussed. And 10 again, it would really help us as we try to hone in on 11 what is the essential material we need to provide the 12 staff to have that streamlined and efficient review?
13 We want to think more about LAR content.
14 it's not that we don't talk about it; we talk about it 15 all the time, but really think about again what is the 16 essential -- what are the essential documents that we 17 need to provide the staff to make sure we really 18 address the big ticket items that we need to focus on 19 in the LAR review? Because what happens is if we 20 don't include it in the LAR up front, we end up having 21 to address it in RAIs and it's usually more painful as 22 it moves later into the project life cycle. We want 23 to do a better job up front of providing what's 24 needed.
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49 And I talked about precedent licensing 1
actions already.
2 And then this was an idea that has come 3
up. We've been talking to folks who work in different 4
regulatory areas, but use of white papers. Maybe the 5
slide presentation isn't the best method of 6
communicating. Maybe we want to write white papers, 7
submit white papers and use that where you can get 8
more information and then use that as a way of 9
eliciting feedback. So we're open to different ideas 10 on how to make good use of these pre-submittal 11 meetings, but really have more durable results that 12 come out of it.
13 And then another enhancement, and this was 14 an idea from one of our Southern Licensing colleagues 15 here that -- looking at other regulatory areas: EPU, 16 license renewal. There are other tools that folks are 17 using, other readiness assessment tools. Maybe 18 there's something we can borrow from those other 19 areas, again as we move forward and we think about how 20 do we do this more efficiently to make sure that the 21 LAR that's submitted is complete, is what's needed.
22 Okay. Next slide? I think this may be my 23 last slide here. So from a big picture perspective 24 I'll say the NRC project managers -- having consistent 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 PMs for these different digital LARs has been super 1
helpful. Really helpful. Because we're able to -- in 2
planning meetings able to have discussions, able to 3
ask questions, refer to other licensing actions. So 4
we thank the NRC for having those consistent PMs.
5 Very helpful.
6 And then the last item is NRC review 7
schedules. So for some of these early movers the NRC 8
had provided a review schedule that was like a bar 9
chart. It kind of laid out the different branch 10 reviews and what those time frames were. And we had 11 it at the beginning and then as the project continued 12 and RAIs and different things happened, we didn't keep 13 refreshing that. But when I was thinking about this 14 presentation I was thinking back to when we had that 15 tool. I think the tool would be very helpful because 16 in some cases, again for some of these early movers, 17 there were topical areas we thought were complete, we 18 thought were closed, but they were not. There were 19 some open items remaining.
20 And I if the licensee had recognized that 21 earlier on, had understood that earlier on, may have 22 changed the focus of our pre-submittal meetings, 23 changed up the order of what was presented or 24 addressed it different -- or not pre-submittal 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 meetings -- of the LAR engagement meetings when we 1
were kind of going through the review phase. But I 2
think having that tool and understanding -- having it 3
updated, understanding where the staff was in their 4
review would be very helpful, very, very helpful in 5
industry, really understanding what to expect.
6 Next slide? Okay. And that's the end of 7
the presentation, the end slide. Thank you.
8 DR. AL RASHDAN: Okay. So we open up for 9
questions.
10 Mr. Kuntz: Sorry, it's Rob Kuntz again.
11 They had mentioned that -- Sorry. The court reporter 12 requested that we again remind people to identify 13 themselves when they're speaking. But -- so should we 14 open up for questions? Are there any questions from 15 the staff, I think, maybe?
16 (Simultaneous speaking.)
17 DR. AL RASHDAN: So my name is Ahmed Al 18 Rashdan. I'm from Idaho National Lab, and I'm also 19 the plant modernization lead for the light-water 20 reactor sustainability program -- the DOE Light-Water 21 Reactor Sustainability Program.
22 So the question I have is that -- so the 23 VOP doesn't end once the -- the license is issued and 24 the plant is commissioned; it still continues 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
52 afterwards, right?
1 MS. GOLUB: That is --
2 DR. AL RASHDAN: And you're planning to 3
enforce that through an inspection dedicated just for 4
that; is that correct?
5 MS. GOLUB: You mean the Vendor Oversight 6
Plan? Yeah. That oversight plan -- I mean, if you 7
read any of the -- or even the summaries that are 8
available publicly, they go all the way through 9
implementation through testing.
10 DR. AL RASHDAN: But then, post-testing, 11 what happens afterwards? Then it becomes part of an 12 inspection to verify compliance?
13 MS. GOLUB: Well, it's part of the NRC's 14
-- the NRC can inspect anytime during that life cycle.
15 But once it's commissioned, the product is -- or the 16 system is commissioned, the VOP is done. Then the 17 plant has other programs which will manage it. I 18 don't know, Mark, if you want to speak to that a 19 little bit.
20 MR. SAMSELSKI: The VOP is archived. All 21 the actions are complete. As Pareez indicated, it's 22 available for inspection. And then the intent is you 23 go into operational mode of the system that you just 24 installed, and the normal planned procedures 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
53 then cover the maintenance and operation of the 1
modification.
2 MS. ZHANG: So maybe if I can help a 3
little bit -- this is Deanna Zhang from the Quality 4
Assurance and Vendor Inspection Branch.
5 So, for a licensing action, the summary of 6
the VOP that we have on the docket that we review goes 7
through the factory acceptance testing phase. So, 8
once the factory acceptance testing phase is complete, 9
the oversight activities that are governed by the VOP 10 summary that is part of the safety evaluation is done.
11 Now, you're talking about post-delivery. Any of that 12 and the vendor oversight activities, in terms of the 13 NRC's oversight -- that continues. It's of the VOP 14 implementation as well as off-site
- testing, 15 installation, all those activities.
16 That is subject to the NRC's inspection.
17 It may not be part of the VOP implementation 18 inspections, but it would carry on all the way through 19 the system's commission.
20 DR. AL RASHDAN: Thank you. Thank you.
21 MS. ZHANG: You're welcome.
22 MR. KUNTZ: Okay. Were there any other 23 questions? Two more.
24 MS. ZHANG: Oh, Rich.
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54 MR. STATTEL: Rich Stattel, General 1
Electric. In your presentations, I didn't hear any 2
discussion about the changes that were made to the 3
Tier 1 through Tier 3 processes. And those changes 4
are very significant, as you know. And I understand 5
that since that publication, that you haven't had any 6
applications that use those tier processes.
7 But for example, in the Tier 1 through 3 8
processes, there's no longer a requirement to submit 9
the planning documentation, right, as is required for 10 the alternate review process. And that's a pretty 11 significant change because that was a big part of the 12 older safety evaluations. So is there anything you 13 can say about those changes?
14 MS. GOLUB: Are you asking me or Samir?
15 MR. STATTEL: Well, I guess more Samir 16 because, you know, they were a part of that revision, 17 right? So, when you compare -- so not -- the revision 18 didn't only introduce an alternate review process. It 19 revised all four of the review processes. Right?
20 Now, I understand that everyone is kind of 21 targeting the alternate review process and the 22 inspection processes and the VOP, but none of that 23 applies to the Tier 1 through Tier 2 reviews.
24 MR. DARBALI: Yep. So this is Samir.
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55 Yeah, Rich, I agree, and I kind of mentioned a bit on 1
that when we're talking about the improvements. So 2
yes. I don't know if you saw my entire presentation.
3 So I mentioned the updates we made when we did 4
Revision 2. So --
5 MR. STATTEL: I might have missed the 6
first few minutes.
7 MR. DARBALI: Okay. So maybe that was 8
that, but yeah. So I covered that when we revised the 9
ISG, we made improvements to the tier process, and we 10 mentioned -- right -- I mean, it used to focus -- it 11 was mostly based on BTP 7-14 criteria, so we focused 12 on the planning and focused on the review of design 13 outputs.
14 And so now we kind of took out the 15 planning. Now the focus on the design output --
16 because why would you review planning if you have 17 result? And now the planning part is for the 18 alternate review process, along with the VOP.
19 And we kind of tried to show in that 20 diagram that yes, the -- even though you are getting 21 your license amendment determination later, you are 22 looking at output documents, whereas now on the ARP, 23 you've got to focus -- well, what does my VOP cover?
24 Now I got to think about inspections against the VOP.
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56 So yes. I mean, you are kind of trading 1
-- you're still doing a lot of documentation review, 2
but now you're kind of trading what part of the 3
development you're focusing on.
4 MR. STATTEL: Okay.
5 MR. DARBALI: Yeah. Thank you.
6 MS. JOHNSTON: Jeanie Johnston, Southern 7
Nuclear. Pareez, in your presentation, on the last 8
slide, you talked about the schedule tool. Is that 9
what is also referred to as an open items list during 10 audit or something else?
11 MS. GOLUB: It was something else, Jeanie.
12 MS. JOHNSTON: Okay.
13 MS. GOLUB: It was a -- I think the -- the 14 Project Manager, I thought, had put -- I thought 15 Michael Marshall had put that together, and it was 16 like a bar chart. So it's a schedule --
17 MS. JOHNSTON: Okay.
18 MS. GOLUB: -- and then a bar chart, but 19 each of the bars was a different NRC -- either review 20 branch or topic, topical area. And so it gave a -- it 21 gave the licensee the opportunity to understand the 22 length of each of these reviews, and then it also gave 23 a sense of, okay, we've gotten past that point. We 24 haven't received an REI. Maybe that area is closed.
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57 Maybe we've completed that work.
1 So it kind of helped them gauge how they 2
were moving through that review process. But it was 3
nicely laid out, and there were a lot of -- there's a 4
lot of additional information just spread out around 5
the edges of it. Very helpful tool, so --
6 MR. SAMSELSKI: Do you mind if I add?
7 MS. GOLUB: Yeah. Please.
8 MR. SAMSELSKI: This is Mark Samselski 9
from Constellation. It was used as a communication 10 tool, almost like a work breakdown structure along 11 with a tracker. So it was beneficial to understand 12 where the review process was and the status, as Pareez 13 indicated.
14 MR. KUNTZ: Any other questions in the 15 room?
16 MR. QUINN: Ted Quinn from Paragon. I 17 thought of something to add to what Pareez was doing, 18 and it had to do with all of the documents in ISG-06 19 that are submitted along with the LAR. And as a 20 result of Phase 0 for us at Turkey Point, nine Phase 21 0 means, one, it resulted in NRCS for the D3 early.
22 It was one of the documents that are submitted.
23 And the result is there was a license 24 amendment by Turkey Point very early, much earlier 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
58 the program, so that by the time a LAR went in -- but 1
I just ask you during the review of ISG-06, you 2
consider the document sequencing as well as the LAR 3
sequencing. Thank you.
4 MR. DARBALI: Yeah. I think -- this is 5
Samir. I think in that aspect, the D3 assessment is 6
sort of taken as a -- not a topical, but it's 7
something to leverage if you can already have that 8
ready before the license amendment request. Yes.
9 MR. QUINN: Okay. Thank you.
10 MR. CAMPBELL: So we're -- this is Alan 11 with NEI. We're talking about looking at these other 12 licensing review activities. You know, it's pretty 13 commonplace and larger applications for pre-submittal 14 documents, or I think we suggested white paper.
15 That's similar to the kind of -- you know, it doesn't 16 just have to be a tool; it can be a process thing that 17 would help once we get into the peer review, so 18 looking kind of comprehensively at where else are some 19 of these good ideas from other licensing application 20 areas?
21 MR. KUNTZ: Is there any other -- Rob 22 Kuntz here. Is there any other questions in the room?
23 Okay. Is there anyone on the line that had a 24 question?
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59 Kind of scheduled for a break right now.
1 Does that sound good? Okay. So we'll readjourn at 2
3:30? Does that sound good? 3:13? All right. So 3
we'll readjourn at 3:30. Thank you.
4 (Whereupon, the above-entitled matter went 5
off the record at 3:13 p.m. and resumed at 3:33 p.m.)
6 MR. KUNTZ: Good afternoon, everybody.
7 We're getting started, everyone. Thank you.
8 (Simultaneous speaking.)
9 MR. SAMSELSKI: Okay. Good afternoon, 10 everybody. My name is Mark Samselski, and I'm General 11 Manager at Constellation. I appreciate everybody's 12 time this afternoon. I appreciate the NRC giving the 13 opportunity to talk about the Limerick Digital 14 Modernization Project and the lessons learned that 15 we've had through piloting the alternate review 16 process that's in ISG-06.
17 Today I'll be presenting along with Ashley 18 Rickey. Ashley is the Lead Licensing Engineer. I'll 19 allow her to introduce herself.
20 MS. RICKEY: Hi. I'm Ashley Rickey from 21 Constellation. I'm the Lead Licensing Engineer for 22 the Limerick digital upgrade, and again, appreciate 23 the opportunity to speak to the group and share our 24 lessons learned. Thanks.
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60 MR. SAMSELSKI: So, again, Mark Samselski.
1 Limerick is a pilot project for the alternate review 2
process. We're working with the Department of Energy.
3 We're testing -- hydroing, I guess, is maybe a better 4
term for our industry -- the alternate review process 5
along with a lot of other industry guidance that we 6
use.
7 Limerick is a boiling water reactor. We 8
began operation -- commercial operation in 1986 for 9
Unit 1 and 1990 for Unit 2. It's located right 10 outside Philadelphia, Pennsylvania. We currently 11 started our first license extension, and we're 12 operating both units to 2044 and 2049.
13 Next slide, please.
14 Again, we employ a lot of folks in the 15 Delaware Valley area region. We power over two 16 million homes for our customers with carbon-free 17 electricity. We have 724 employees, and we're 18 evaluating a potential subsequent license extension 19 for an additional 20 years for both units.
20 Again, we're testing the alternate review 21 process, partnering with the DOE. We have a lot of 22 lessons learned. I'm going to turn it over to Ashley 23 here for a few minutes to talk about the licensing 24 process, where we're at now, and how we've been 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 working on the project so far to date.
1 Ashley?
2 MS. RICKEY: All right. Thanks, Mark.
3 So, in support of this project, there's 4
been three LARs that have been proposed to support the 5
project. So we did our main LAR, what we call the 6
modification or the principal LAR, which was submitted 7
back in September of 2022. We conducted 12 pre-8 submittal meetings starting back in June of 2021. And 9
this is our largest LAR to date, and the SER is still 10 pending on that one.
11 We did, secondly, an installation support 12 LAR. This aids in pre-outage demolition of RRCS, 13 which will help us to better install the new PPS 14 system within our designated outage time frame. And 15 we did have the SER issued for this LAR back in 16 October of this past year.
17 A third LAR that we're going to be 18 planning to submit -- we're nearing completion of 19 having it ready to submit and hoping to have it 20 waiting for us to submit by the end of March, and 21 we're going to submit it after the modification LAR, 22 main SER, is issued to prevent any LAR linkages. And 23 basically, that helps us bring back in any instrument-24 related RICTs that we took out in previous LARs. So 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 three main LARs for this project.
1 All right. So this LAR plan was developed 2
in accordance with ISG-6, Rev 2, to streamline the 3
process and to test out implementing the ARP. We saw 4
this as a crucial time and a crucial component to test 5
out the ARP, and Limerick was among the first to use 6
this for a large-scale protection system. I guess we 7
really were the first.
8 So we extensively did utilize the pre-9 submittal meetings, which was a great experience. We 10 talked through a lot of plans and tried to reduce 11 risks associated with what we were planning to 12 present.
13 I don't know, Mark, if you want to talk 14 about what we went through in those pre-submittal 15 meetings.
16 MR. SAMSELSKI: Yeah. So I'm going to 17 take one step back just to ground -- this is Mark 18 Samselski again -- to ground everyone in the room for 19 the scope of the modification. We're replacing the 20 reactor protection system, the isolation system -- we 21 call it nuclear steam supply shutoff system, N quad-S; 22 you may hear me use that term today -- as well as the 23 emergency core cooling system functions, ECCS. If 24 you're a PWR -- pressurized water reactor -- familiar, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 it's ESFAS, the engineered safety actuation system.
1 So we are taking those multiple systems 2
that are logic-based, trip unit-based systems that are 3
very segmented and on their own, and integrating them 4
into a digital platform. We're using a safety-related 5
digital platform to integrate those functions and use 6
the benefits of digital technology to increase our 7
safety and give the operations teams, Limerick, a 8
better understanding of what's going on in the 9
facility and allowing them to respond more efficiently 10 and effectively to any type of anticipated operational 11 occurrences.
12 So, during the pre-submittal meeting 13 process, we really were looking at this to reduce 14 risks and streamline the licensing process and the 15 review cycle. And we discussed many, many topics.
16 Pareez talked about meeting minutes and meeting notes 17 and the preparations it takes for a licensee to 18 prepare for those. And these five that I've listed 19 here today are just a small scratch of the surface.
20 So, with a new digital system, as we as an 21 industry become more intelligent and smarter, we see 22 benefits to upgrading technical specifications to 23 incorporate features that are enabled by digital 24 technologies. We also had many discussions on human 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 factors engineering, moving and modernizing our human-1 machine interfaces, the main control room, from analog 2
equipment, disparate equipment all over the room, to 3
a consolidated flat panel integrated display.
4 We've also discussed the adoption of 5
touchscreens, the removal of hand switches, push 6
buttons, things of that nature, and what that does on 7
the human factors engineering aspect in those reviews 8
that are required.
9 Another topic we discussed was diversity 10 and defense in depth, our approach to common cause 11 failure, and those items to identify what may be or 12 may not be susceptible to a common cause failure.
13 Furthermore, going to digital allows some operational 14 efficiencies to be gained by the licensees. Where we 15 saw this was a topic called sensor consolidation.
16 So we discussed this at length with many 17 of the members of the staff during the pre-submittal 18 meetings about reduction of sensors but still 19 maintaining the ability to safety operate the 20 facility. And that is enabled by digital technology 21 and the way that digital technology can share 22 information to allow the logic to make decisions.
23 Also, during the diversity and defense in 24 depth discussions, we had discussions around key 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
65 documents being submitted early. And we were under 1
the impression that this would -- during the pre-2 submittal process, this would foster better discussion 3
and a better understanding of the system design and 4
the diversity and defense in depth to assess a common 5
cause failure as the design is developed. So that was 6
one of the key documents we submitted early on in the 7
project, about five to seven months prior to the 8
submittal.
9 Next slide, please.
10 So, with all this on a large-scale digital 11 upgrade, digital modernization, there's a lot of 12 lessons learned. And we can talk about engineering 13 lessons learned. We could talk about licensing 14 lessons learned. But we're here to focus on the 15 licensing lessons learned today.
16 And so, through the discussions and the 17 bullet points on the next several slides, we'll cover 18 scoping, using the Interim Staff Guidance 6 process, 19 a little bit more details about the pre-submittal 20 meetings, vendor oversight, the open item process that 21 we use during an audit, and equipment qualification, 22 as Pareez touched on earlier, the application of 23 precedent and risk insights, human factors, and again, 24 technical specifications. So all of these items today 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
66 we're going to touch base a little bit during the 1
conversation.
2 Next slide, please.
3 So I think we all kind of are here today 4
because we recognize this as an industry. The Interim 5
Staff Guidance 6 Alternate Review Process does not 6
thoroughly address all aspects of a large-scale 7
upgrade for protection systems. So we all agree 8
there's always room for improvement, lessons learned.
9 That's why we're here.
10 We do want to state that we actually 11 benefit a lot from pre-submittal meetings. As Pareez 12 spoke a few minutes ago, the staff was well prepared.
13 But it allows us to gain insights on what we need to 14 prepare for our submittals. Our perspective is, for 15 the Limerick digital modernization, the licensing 16 action is considered a hybrid LAR, as Pareez indicated 17 a few minutes ago.
18 There's a
lot of things we have 19 supplemental that we've provided at a later date, so 20 we've worked around that, and the project management 21 team has really engaged us well and worked with us on 22 that aspect of planning those types of submittals.
23 So we did talk about this during the pre-24 submittal process. So there was a pre-submittal 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
67 meeting about what would be supplemental documents 1
that would be provided. So, again, the pre-submittal 2
process -- and I'll go, again, into it a little bit 3
deeper on the next slide -- is really around how we 4
can address all these big things, all the topics that 5
we need to understand for a large-scale modernization 6
project.
7 Next slide, please. Oh. Perfect. Thank 8
you.
9 So I'm going to touch on pre-submittal 10 meetings here, and there's quite a bit. They're 11 valuable, right? It helps us understand what the 12 staff needs to review, and it helps us understand what 13 we need to provide and clarification on the best, 14 sometimes, format to provide because if we just throw 15 out words on a piece of paper, it may not be the best 16 format to help the reviewers come to a conclusion.
17 So, when we look at this, though, many of 18 the digital retrofit initiatives being contemplated 19 across our industry in safety-related systems involve 20 significant complexity for first of a kind at this 21 stage, right? Limerick was a pilot project. It was 22 very big. We were very ambitious. We had a lot of 23 scope. But it's first of a kind, and we'll see the 24 first adopters of the process still continue to be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 first of a kind.
1 And I think, Pareez, you said it well 2
earlier, that with repetition, it becomes more and 3
more comfortable to folks to get through. But these 4
first ones, we're going to have some lessons learned.
5 We thought the pre-submittal meetings were 6
also advantageous to mitigate those project and 7
regulatory risks to align on the necessary detail for 8
a complete application. This, again, really allowed 9
us to make sure that we were hitting the mark.
10 I
mentioned this earlier.
The 11 participation from the NRC branches was fantastic.
12 Staff was well prepared, came with great questions.
13 It allowed us to prepare and be ready to have a 14 complete submittal.
15 Where we would like a little bit more give 16 and take, I think, is the meeting minutes and 17 distribution to make sure that the topics are fully 18 understood, that we feel that we have complete 19 alignment and there's no clarification needed. And it 20 also will allow the industry to understand what's the 21 next topic to bring.
22 When we start talking about it at a high 23 level, we start with what's the scope of the 24 modification? What's the scope of the license 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 amendment request going to be? And then we could 1
break down a work breakdown structure, essentially, of 2
what the topics are to bring to make sure we have a 3
complete alignment to know what rod to bring.
4 With that, I think there's also something 5
here as we go through the Limerick licensing process 6
and the vendor oversight process. We believe that 7
there could be a benefit to have the region involved 8
in some of the pre-submittal meeting discussions at 9
that point. There's benefit for alignment to 10 understand what the regional inspectors will have on 11 their plate as well as what will be coming out of the 12 headquarters office for the NRC as well.
13 A couple of best practices here for the 14 pre-submittal meetings I noted -- meetings should be 15 conducted early and frequently. And we don't think it 16 always needs to be a formal face-to-face protocol.
17 Remote meetings -- we were a COVID project. All of 18 our meetings for pre-submittal were remote, and we 19 didn't see that it was a hindrance once we all became 20 more comfortable with remote meetings. So I thought 21 that was a very good benefit, and with remote 22 meetings, I think you could increase the frequencies 23 of those discussions for alignment.
24 Where we also had another best practice is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
70 we had a list of discussion topics for upcoming 1
meetings. And Ashley and her predecessor worked with 2
the project management staff to get alignment on those 3
items in advance so that we could discuss through 4
items like equipment qualification, common cause 5
failure, tech spec changes, and then getting that 6
feedback to understand what that complete submittal 7
looks like. So there was a very good benefit to that 8
discussion.
9 And then another best practice is we 10 prepared a lot of materials. It was in PowerPoint 11 format, so there may be an area for improvement on the 12 format and how to have that information be prepared.
13 But we did have a lot of material available to enhance 14 the discussion to help through the understanding 15 around the new proposed system architectures and 16 things that way. We did use PowerPoint. We saw that 17 as a benefit. But there could be other support 18 documentation forms that enhance that conversation.
19 Next slide, please.
20 So, for vendor oversight, I think this is 21 going to be the biggest one for the industry to get a 22 little bit more improved alignment on. Having 23 objective criteria is needed for us to understand, how 24 do we show compliance? We did have discussions during 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
71 the pre-submittal meetings. We had good feedback and 1
good engagement from the staff. But we think that if 2
there's something written down with the expectations, 3
we could have a more efficient, more streamlined 4
engagement on preparations for the vendor oversight.
5 We really wanted to find what needs to be 6
addressed, the timing, and the objectives. So that's 7
where we saw some -- a little bit of improvement in 8
that area for our discussions.
9 Also, we had regular and proactive 10 communications that occur among the licensee, the 11 headquarters, as well as the regional inspectors.
12 This was post-LAR submission. There were several 13 Fridays where our resident and the folks from the 14 region -- and there's representatives here from 15 headquarters -- are on the phone with our licensing 16 department and project members to understand where 17 we're at in the project moving forward.
18 It really allows us to support 19 organizational adjustments, and it's not just people.
20 It's really about capabilities, technical authority, 21 understanding what's going to be reviewed and where 22 we're at in that inspection space. It allows us to 23 have coordination of schedules. You can imagine 24 something this large -- I mean, it -- when we talk 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
72 about it, it sounds like a small project. Living it 1
every day, it's a big project, okay?
2 So coordination of schedules, priorities, 3
resources -- this is really important to have these 4
conversations. So, again, this is post-submission of 5
the license amendment request, and it's more of a 6
tactical item, but understanding what goes into that 7
in the pre-submittal, early-on discussions, lining up 8
the expectations, will set up the next licensee for 9
success.
10 And then, if you don't have these 11 proactive communications, maybe there is a
12 clarification on what the anticipation for regular 13 communications are regarding schedule among all 14 stakeholders. Periodic check-ins always work.
15 Sometimes, based on where you're at in the project, 16 you may be at a more infrequent check-in. Maybe 17 during other phases of the project, you're at a more 18 frequent check-in with the inspectors and the review 19 staff.
20 So that's a tool that you have to find the 21 right size for where you're at in the project. And I 22 know I'm probably preaching to the choir with all the 23 student projects, but this is really important because 24 there's resource constraints and planning by the NRC 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
73 as well as the licensee and their vendors.
1 And then IP 52003 -- it's the inspection 2
guidance. There may be an opportunity here to 3
consider some of that criteria and guidance be 4
reviewed and considered for inclusion into the next 5
revision of Interim Staff Guidance 6 for the alternate 6
review. That may be something to pull from to 7
understand what the objectives are and how to make 8
those observations a little bit more streamlined, 9
effective, and efficient.
10 MR. SAMSELSKI: So the open item audit, we 11 as the licensee perceive this process as beneficial 12 for helping the staff understand our submissions. We 13 use -- the presubmittal gave us an opportunity to talk 14 about it early on and frequent.
15 This gives us an opportunity to answer any 16 what I'll call low-hanging fruit, where like this, you 17 know, ask a question and it might be in a document, 18 help find it in a document that was submitted. We see 19 that as a benefit.
20 Why do we see that as a benefit?
21 Responding to RAIs is a burden, could be a burden on 22 the licensee, right. I know it's - the staff has 23 their process to generate an RAI. We're trying to 24 minimize RAIs, always the goal is for no RAIs for 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
74 license amendment request.
1 But we really want to minimize the need 2
for RAIs. So we see the open item process as a chance 3
to clarify anything that may be on the mind of the 4
reviewers. So it really, it helps reduce the RAIs, it 5
helps aid in fostering an environment that's conducive 6
to providing clarity. Alleviates the, what I perceive 7
as the administrative burden for the NRC, as well as 8
the licensee.
9 But we have some areas that we need to 10 make sure that we understand, right. We need to make 11 sure that they're coupled, the questions for the open 12 item process, are coupled to regulatory and/or safety 13 conclusions that are needed.
14 There were opportunities at times to ask 15 questions that may not be pertained to the 16 application. It may be perceived as a nice-to-know, 17 and maybe it is tied to a regulatory or safety 18 conclusion. But we need to make sure that we align 19 during that open item audit, that it's adding value to 20 both organizations.
21 So that's an effort for coordination 22 between the staff and the licensee to ensure that the 23
- the questions are thorough and accurate and the 24 responses are thorough, and thereby reducing the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 number of RAIs at a later date.
1 One of the best practices from this 2
process, we use SharePoint, so Mircrosoft SharePoint 3
a lot at Constellation. So we created a SharePoint, 4
or you know, for other licensees it may be a similar 5
portal to have the involved stakeholders communicate 6
effectively and efficiently.
7 You know, we had open items, a list, and 8
a running tab, and we worked through that process.
9 Again, being a pilot project, it was one of those 10 items where we kind of figured out how to work best.
11 But you know, Michael Marshall, the PM for Limerick, 12 was very helpful in understanding what the needs were 13 for the staff, along with the needs for the licensee 14 to work that relationship and conversation together.
15 Next slide, please.
16 So I think this is the last slide. You 17 know, this is a summary of the last things for areas 18 for improvement. And again, we're testing a process, 19 going through the process for the first time on a 20 large modernization effort.
21 I believe, Pareez, you touched on this 22 earlier. Equipment qualification, you know, I think 23 the aspect is not sufficiently considered. We believe 24 that the approach used for factory acceptance testing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 can be applied to the equipment qualification process.
1 Because as you get deeper and deeper into your 2
detailed design activities, you've established already 3
what your criteria is that that component needs to 4
establish to.
5 And through an upgrade, we know the 6
- seismic, the environmental, and the EMIR by 7
environment requirements that we're selling the 8
upgrade in. So we've established the requirements, 9
demonstrating what may - like a part may change during 10 detailed design because you find something. The 11 current process doesn't allow that one-for-one change.
12 You know, you're waiting for this documentation.
13 So I
think there's an area for 14 improvement, for improving the equipment qualification 15 process for this so that we could support, you know, 16 qualifications that may have to be - happen after the 17 LAR submission.
18 Human factors. I think tomorrow there's 19 a presentation from the staff on human factors. But 20 for Limerick, we are making wholesale changes to the 21 human factors of the main control room. We worked 22 with the staff, that was fantastic. We understood 23 what we needed to provide to the staff. We found that 24 out through the pre-submittal process. That was very 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
77 efficient.
1 Where I think this is, as Pareez put it, 2
there are inefficiencies to assuming that NUREG-0711 3
is just to be blanketly applied. The licensees really 4
need to understand their existing human factors, 5
engineering, licensing, and commitments.
6 And but it's at their discretion to use 7
what's available to them. And that's through that 8
pre-submittal process. You can lay out how as a 9
licensee you're going to do that and staff, you know, 10 may give some feedback on what that methodology is or 11 there may be an IEEE standard or a NUREG that may 12 support that.
13 So it's a plus and a minus for human 14 factors, I just want to note that.
15 Technical specifications.
Technical 16 specifications, you know, additional submissions may 17 be needed as the design is developed and that you may 18 include new components.
19 So we need to understand what that looks 20 like later on. We submit tech spec markups right with 21 the LAR submission. But as the detailed design may be 22 completed and the FMEAs for the software-based system 23 is done, you may have to put a component to make that 24 software-based system compatible with the existing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 facility.
1 So you need to understand that that new 2
component may or may not require a surveillance 3
because it's not covered by the surveillance reduction 4
at the platform that you may have selected. So that 5
may require an additional submission to update 6
technical specifications at a later date, you know, 7
either to add a surveillance or maybe remove a 8
surveillance. Yeah, you don't know as you get through 9
the detailed design.
10 And then the application of precedent. I 11 think this is a big one for us to understand and 12 understand what this means. And we tried our best to 13 understand that during the presubmission process. But 14 it's essential to guide licensees on how the staff 15 might integrate risk and some other items and 16 considerations into the application by using 17 precedent.
18 So we're trying to understand that, you 19 know, we're a continuously learning industry, and this 20 pilot project is one of those examples. But the 21 licensees don't know, always understand how risk 22 insights or risk of the application may be considered 23 in the review process. So we need to have a 24 conversation that how do we incorporate that and make 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 sure it's clear to the licensees on how that's 1
applied.
2 And then the last one here, just as a 3
lessons learned for everyone involved, submissions 4
should strictly adhere to the requirements outlined in 5
ISG-06 to promote efficiency, right. So the alternate 6
review process, it's based on early planning, early 7
submissions of requirements-based design. And then, 8
but if you include more things in that - those 9
requirements, it's always going to be reviewed.
10 Pareez, what was the language that you 11 used earlier today, I think --
12 MR. GOLUB: Submit it and we'll review.
13 MR. SAMSELSKI: Yeah, if you include it, 14 we will review it. And so really it's, this is 15 feedback to the industry on this one. Only include 16 what you need. Don't include something that may not 17 be required as part of the alternate review process.
18 And then because whatever you submit in 19 the requirements process, it's up for implementation 20 of that in the detailed design for audit or 21 inspection. So you know, be cognizant of the 22 requirements that you're submitting and only provide 23 what you need.
24 And that should be my last slide. Again, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 thank you. I appreciate your time and if there's any 1
questions.
2 MR. KUNTZ: We've got a question.
3 DR. AL RASHDAN: Ahmed Al Rashdan, INL, 4
Idaho National Lab. So you mentioned earlier that you 5
went with a hybrid LAR approach, with ARP and LAR, I 6
think the second or third slide. So I was wondering 7
why did you get into this conclusion?
8 MR.
SAMSELSKI:
Because of the 9
supplemental. So the alternate review process 10 requires everything to be provided once and up front.
11 Through negotiations and discussions with the project 12 management staff, we had planned supplementals to be 13 provided at a later date. So that's why we consider 14 it a hybrid-type process.
15 DR. AL RASHDAN: Were there any challenges 16 with adopting this approach? Hope we can think of 17 some more I would say.
18 MR.
SAMSELSKI:
It
- does, it does 19 complicate things more. If you plan, you can 20 efficiently get through that. However, nothing is 21 perfect. We were going through some tough times with 22 COVID. And the equipment qualification process is 23 where we hit a bump in the road. And that's been the 24 longstanding issue for the project.
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81 MS. RICKEY: A lot of logistics involved 1
in all the supplements, right, for the staff and for 2
the licensee. So it's a lot of extra documents to 3
submit, a lot of extra documents to review for the 4
review team. And so that was definitely a challenge 5
to keep track of all of those and make sure we're 6
submitting all the right versions at all the right 7
times. And so that was definitely a challenge.
8 MR. DARBALI: And from the staff's view, 9
this is Samir. So we haven't gotten an application 10 that meets the ARP as it was written, and we probably 11 won't. And we'll talk more about that tomorrow. But 12 that just means every application that we're seeing, 13 we were kind of having to craft a new custom review 14 process for each application that takes aspects of the 15 ARP and aspects of the tiered review process.
16 So it does become a challenge because 17 we're, sometimes we don't know, you know, which lane 18 we're in.
19 DR. AL RASHDAN: Thank you.
20 MR. STATTEL: So I have a question. So in 21 ISG-06, I mean, the entire premise of getting the 22 early license amendment was that elimination of the 23 Phase 2 submittal. So the whole premise of being able 24 to do that early was having all of the information up 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
82 front, right.
1 And it sounds like in every application 2
we've done since then, we've basically compromised 3
that. Does that in turn affect the timing of the 4
issuance of the license amendment?
5 MR. DARBALI: So yes. So we don't have a 6
lot of, you know, examples, but so Waterford, I 7
believe one of - there was late submittal for EQ 8
summary results. And what ended - I mean, we were 9
able to complete the review within the requested 10 timeframe.
11 But basically we finished our evaluation 12 of that late June/early July 2021. FAT was in August, 13 last July/August. So we did - so we were done with 14 the licensing review. We did an inspection of FAT, 15 and I guess after we finished our inspection is when 16 the license amendment was issued.
17 So even though we tried to follow ARP, the 18 timing didn't really provide the benefits that they --
19 MR. STATTEL: So would you say had that 20 information been available in the initial submittal, 21 would the license amendment have been able to - been 22 issued sooner?
23 MR. DARBALI: Yes.
24 MR. STATTEL: Right prior to --
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83 MR. DARBALI: Because that, yes, that was 1
one of the lesson --
2 MR. STATTEL: So that's the consequence --
3 MR. DARBALI: Yes.
4 MR. STATTEL: - of going to a hybrid 5
approach.
6 MR. DARBALI: Right, right.
7 MR. STATTEL: Okay, thank you.
8 MR. KUNTZ: Anyone else in the room?
9 Sorry, this is Rob Kuntz. Is there anyone else in the 10 room that has a question? Anyone online have a 11 question, on the line? Okay.
12 MR. CAMPBELL: So we previously planned to 13 have Jacob Champagne from Entergy. Jacob's unable to 14 join us this afternoon, so he'll be presenting 15 tomorrow morning I think first thing. Yeah.
16 So next we'll turn it over to Dominion.
17 We have Jeremy Chenkovich.
18 MR. CHENKOVICH: So hello, everybody, I'm 19 Jeremy Chenkovich. I am the Safety Platform Lead 20 Engineer for SLR upgrades in the North Anna and Surry 21 power stations. Those are our two Virginia plants.
22 You can go ahead and go to the next slide.
23 We'll just kind of give an overview. I 24 think the idea here is that we give you guys a teaser 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
84 for the scope and breadth of our major projects.
1 North Anna and Surry are Westinghouse 2
three-loop pressurized water reactors. Little bit 3
different that its - North Anna is a 7300 solid state 4
protection system plant. There's a lot of those 5
around. Surry's the older and it's 7100 relay 6
protection logic.
7 This is subsequent license renewal INC 8
projects, so the scope is really just the I&C systems, 9
not all the field components necessarily. We're 10 strategically making upgrades to those things as we 11 go, but they're not really the crux of it. We're 12 going after the things in the instrument rack 13 basically.
14 So we'll go over this phased approach 15 we're taking. We've kind of got it sorted by system 16 modification, and then we'll talk about some of the 17 design activities we're doing in support of this. So 18 next slide, please.
19 All right, so my previous director 20 insisted we include this picture on every 21 presentation. Yeah. The idea is that we're 22 communicating what we're trying to do here.
23 So what happened when we were scoping all 24 these I&C upgrades with our SLR projects is we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 realized that, you know, 80% of the control room was 1
in our scope. So they, the company at that decision 2
made the time, we're going to go after main control 3
room modernization with this project.
4 So this is definitely a modernization 5
project, not an obsolescent system replacement-type 6
project. We're going to look to leverage the 7
technologies to get all the things we've heard 8
discussed, tech
- specs, surveillances, overall 9
- benefits, operations, interface optimizations, 10 everything we can in the course of this.
11 The idea is we do these one-time, very 12 difficult efforts to make everyone's life easier in 13 the future.
14 MR. DARBALI: Could you move close to the 15 mic?
16 MR. CHENKOVICH: Is my voice not carrying?
17 I'm sorry. I could, you know, operate with my back to 18 the audio. We can go ahead and go to the next slide.
19 MR. DARBALI: Okay.
20 MR. CHENKOVICH: So we have projects.
21 There are some criteria for inclusion with our 22 subsequent license renewal projects, mainly that they 23 weren't already budgeted for us in Virginia. We did 24 an enhanced capital return for certain projects that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 meet the state's criteria.
1 So that's basically what drove a lot of 2
the project selection. It had to be going obsolete 3
between year 60 and 80. You couldn't already be 4
obsolete. And we couldn't already have it budgeted as 5
basically the two main criteria.
6 But in addition to that, we have goals.
7 We of course want to enhance safety across the board.
8 We're going to address obsolescence. That of course 9
is the main driver for inclusion. But like I 10 mentioned, reduced O&M cost. The idea is that we make 11 what we're touching easier to work with if we possibly 12 can.
13 So the fourth item there, standardized 14 designs, that is the key supporter to our approach.
15 So basically the entire scope of the IC system on the 16 non-safety side that's in the instrument rack or is 17 anyways in our scope. So we pursuing a plant-wide 18 DCS, distributed control system. And we would like to 19 have a single platform solution on the safety side.
20 We already did all this workout, by the 21 way. This is public knowledge. We've forwarded it to 22 Westinghouse, but these inverse innovation with DCS 23 and comment sheet for safety systems.
24 But the idea is that linearity does not 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
87 vary from system to system. You don't need specific 1
training, specific procedures for all these different 2
technologies. Procedures, procedures look the same 3
from system to system. You're not really dealing with 4
all the disparate technologies we have down there.
5 The other thing, the very bottom bullet, 6
minimize equipment. Our philosophy has been with this 7
project acquire once, use many is what we say. To the 8
degree we can.
9 We understand that there are safety 10 implications to using one signal in multiple places.
11 But where we can leverage that, we find, you know, 12 some of these older systems have
- five, six 13 transmitters all sensing that same thing because 14 they're each tied into different systems. We can 15 simplify a lot of that, reduce maintenance, reduce 16 equipment in the plant. Next slide.
17 So I want to start in with Surry because 18 that's our lead unit for most of these projects. And 19 we have this phase terminology, so you've heard a lot 20 of phase terminology in other forms here. So I'll 21 just clarify for us that Phase Zero is basically 22 laying the groundwork in the infrastructure of.
23 Phase 1
is the non-safety systems 24 generally, and Phase 2 is the safety systems 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 generally. So you'll kind of see that as we progress 1
here.
2 So at Surry, the infrastructure is pretty 3
much done. There's some pieces to our instrument 4
ground system that are still outstanding, but in 5
general that's done. You see a technical support 6
center relocation there.
7 We basically took the TSCs that were 8
adjacent to the control room at Surry and North Anna, 9
relocated them. And you see what we call a digital 10 control equipment room is going to take its place.
11 And we chose that because we wanted the real estate 12 adjacent to the control room to house a lot of the 13 computer equipment. So we did actually emergency plan 14 of LARs to relocate the TSCs up at North Anna. Surry 15 accomplished that.
16 Those are done. I think all the 17 relocation activities are complete. The DCER, we call 18 it, digital control equipment room, that's going in 19 its place. Those activities are proceeding right now.
20 We are demoing I think a lot of the demos too.
21 And we're getting, we're ready, power 22 realized grounding was HVAC, laying the groundwork for 23 putting a lot of the core that were non-safety and 24 some of our safety pieces in this room.
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89 Okay, and then we started getting into 1
actual plant systems. So Surry has a plant computer 2
and it's already innovation. So we're just migrating 3
that from a very old innovation version to 3.8, the 4
new system.
5 What we call Controls Platform & Network 6
Infrastructure as the backbone of our - our DCS.
7 Right, the infrastructure CPNI mod is basically the 8
backbone of the DCS. We're going to add systems to it 9
over time. So a lot of the core elements, to list the 10 centralized cyber, all the network switches and things 11 are going in with the CP online.
12 Interestingly, Surry has a low level 13 intake structure that's I think almost two miles away 14 from the facility where their circ water pumps are at.
15 It's currently controllable on their plant computer 16 network that is being migrated onto this plant-wide 17 DCS. You can go to the next slide.
18 Annunciator. We are currently installing, 19 I think right now, annunciator replacements at North 20 Anna. This is the similar mod at Surry, where we're 21 replacing the white box annex with, you know, flat 22 panel displays. But the nuance here is that we're 23 transitioning. We're starting to take a step away 24 from the traditional light box alarming to get into 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
90 some more advanced concepts. Like how they build new 1
plants.
2 We're integrating some of the disparate 3
systems now. There's a separate turbine controls 4
network currently. What's interesting is the analysis 5
plant mods. For those of you familiar with the 6
nuclear plants of this vintage, that is a huge amount 7
of random equipment, I'll say. Those are going to get 8
broken up into multiple pieces and converted to the 9
plant-wide DCS.
10 Moisture separator reheaters. We're 11 actually pursuing automation there. We would like to 12 achieve automated startup and cooldown. You know 13 those temperature curbs you have to stay within when 14 you're warming things up.
15 Waste disposal water recovery panels.
16 Secondary drains, water heaters. It's interesting, 17 there's another SLR project mechanical to replace 18 those vessels. And we're taking that opportunity to 19 significantly change the control schemes as opposed to 20 random single control loops. So on each vessel 21 they're all going to be integrated together into a 22 more modern control center.
23 And then you see our first safety mod is 24 ICCM. Those designs are well underway. That is going 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 to be common to you for us, by the way. And we're 1
going to pursue steam generator water level control at 2
Surry. We have not really kicked that off yet. We're 3
still working on the conceptual and the specification 4
development for that.
5 A lot of these are in design currently, 6
and at various stages. Next slide, please.
7 So now we're getting to the parts that are 8
more in the future for us. You see another part for 9
the balance play at the rod position, indication rod 10 control.
11 And then we start getting into phase two, 12 which is where start building in LARs in our outlooks 13 that we may get there. So our first one on deck is 14 EDG sequencer. Basically the timing of, you know, 15 stripping the bus and sequencing when it's back on.
16 Our aux shutdown panels. There are a lot 17 of remote locations out in the facilities to meet 18 various criteria that have control of interface that 19 give an operator control outside of the control room.
20 We have ideas about how to accomplish that.
21 And then the NSSS rod. It's similar to 22 what's been done at I think Dyersburg and Braidwood 23 and McGuire and Catawba. Basically it would be 24 replacing a portion of the 7300s and the 7100 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
92 cabinets. All right.
1 And then basically be the big one, we call 2
it RPS, I'm sorry, reactor protection system.
3 Engineered safety features, nuclear instrumentation, 4
main control room conversion. And our AMSAC 5
replacement, which ultimately will be our diverse 6
actuation system.
7 We presupposed the need for that with our 8
mods. We initiated this project in 2017. I know 9
there's been discussions about risk informing and 10 other approaches to that. But given the scope and 11 breadth of our mods, we built it in from the beginning 12 with the idea that we can just add functions to it as 13 necessary as we go.
14 Interestingly, we've already encountered 15 that on ICCM. We want to take category A variables 16 and split them so that they're variable on both 17 platforms so that you can look at that as the first 18 instance of the dash.
19 And then there's some lower priority mods 20 that we can, we may not actually get to. Condensate 21 polishing, station blackout diesel, and some of the 22 back panel EDG controls. So that's Surry, and I'll go 23 much quicker through North Anna. You'll see a lot of 24 similarities.
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93 Similarity, they're done with their 1
infrastructure. They're at basically the same point 2
with their digital control equipment and their TSC is 3
going to convert. They're relocated and has been 4
noted, they're starting to add more equipment to these 5
locations.
6 They're doing rod control much earlier.
7 You can go to the next slide. So then they'll be the 8
lead plant for rod control. I think you went back 9
one.
10 They're going to be slightly in the lead 11 on ICCM, so we've been collaborating a lot between the 12 two sites about what the optimal answer is to certain 13 design questions and operator interface questions.
14 They're installing the first piece of secondary 15 training upgrades now.
16 Similar scope. You can go to the next 17 slide. This is all repeats in a slightly different 18 sequence. North Anna is electing to declare their 19 advanced alarming later. It had already, had been 20 their site capital plans, annunciator upgrade. So 21 they're already accomplishing that.
22 They're going to integrate the advanced 23 alarming concepts later in their sequence. And then 24 use interface to much the same as ours. I guess 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
94 process protection is slightly different. That it 1
would be a subset of RPS, and our plant terminology is 2
basically a version of 7300 at North Anna that 3
acquires the safety signals in those by stable 4
actuation.
5 So North Anna is learning from Surry, 6
because I think Surry's initial vision was that these 7
phases would be laid out a certain way. And it turns 8
out I think we were really ambitious about what we did 9
accomplish, a chunk of work. So North Anna is taking, 10 is basically breaking those chunks of work into 11 smaller bite-sized pieces. You can go to the next 12 slide.
13 Also they're taking a more phased approach 14 to the main control room converting. And if you saw 15 Surry's Phase 2B, basically that is a lot of scope to 16 try and get done in a certain outage - in a single 17 outage cycle. So North Anna's trying to take a more 18 gradual - a gradual approach to the conversion.
19 We don't know what that looks like, quite 20 frankly, in post just yet, but we will see once the 21 50.59s get to a point where we can start having 22 conversations like that.
23 So the timeframe, we haven't really 24 published it to this point, but we did respond to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
95 RIS-2025-01, I think. Our current targets, and this 1
is, you know, just what we know right now is Surry's 2
the middle of 2028, and North Anna is in 2031, I 3
believe. So that is always subject to change based on 4
what we find and how we progress through to do it.
5 Next slide.
6 So here's pictures. This is basically a 7
3D image of the Surry main control room currently.
8 See very little digitization. There's some - there's 9
a panel at the corner of the vertical boards that's 10 basically your alarm list from your current plant 11 computer to the old annunciator tile window and a lot 12 of, you know, single indications, knobs and switches.
13 It's also quite busy in the back with the 14 operator cockpits. You can see all the chairs and 15 people facing off in different directions.
16 So we've had some work in the past at the 17 beginning of this project to try a postulated end 18 state for the control room modernization. What we 19 found is we need to do more work.
20 We need to get actual conceptual design 21 building on that now to better inform all these 22 different mods as we proceed to do things in 23 intelligent ways. We're probably going to get to some 24 point where we need to undo something we had done 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
96 previously. So you can go to the next slide.
1 This is our concept, I think, from INL, 2
about what our control room end state could look like.
3 This has not, again, this has not had heavy conceptual 4
design behind it. But the idea is that we aggregate 5
information into large system reviews on the vertical 6
boards.
7 We repurposed what those annunciator 8
bundles are by building in advanced alarm concepts to 9
things that are maybe more useful to be front and 10 center for an operator. Basically you see two RO, 11 reactor operator, work stations up front and then a 12 similar reactor operator work station behind them for 13 oversight. And you see safety panels in the middle.
14 This is notional derived, very all up in 15 the air at this point. This is just one thought of 16 what it could look like.
17 So you imagine with our phased approach 18 the incremental steps we need to take to get from 19 point A to B. And it's changed design-wise a couple 20 times already. It can be concerning, right. We don't 21 want to do rework because of it's inefficient.
22 But in order to get from point A to B, you 23 have to do something. You have to start making room 24 on the boards to make real estate available for these 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
97 kinds of answers. So we ended up breaking up things 1
we thought we could get done all in one time into 2
smaller pieces and we're proceeding that way. Next 3
slide, please.
4 Some of the terms we've used to get to 5
this point. We have a number of simulation devices.
6 This is our glass panel simulator. I think 7
Commissioner Caputo visited it within the last year.
8 Fairly recently.
9 And this has actually turned out to be 10 highly useful. We did not anticipate that it would be 11 as useful as it is or as originally intended to 12 offload ops training basically activities from the 13 plant reference simulator, to free it up for our 14 purposes.
15 Well, it's turned out we can do a fair 16 amount of testing on our systems on this. Simulation 17 software has developed to the point where I can have 18 instances of the actual plant simulation in various 19 places. So this is basically giving you the actual 20 plant simulator feedback with a different interface.
21 You can go to the next slide. I have some more 22 bullets about this, of what I just said.
23 So we're deploying some multistage 24 validation approaches to human factors as we proceed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 in preparation with the need-to-know safety system.
1 We've done conceptual validations on this system for 2
Surry. And we're also intending to use it for every 3
other validation as part of that SV process if we can.
4 We also have a second plant reference 5
simulator plans, basically to get the end state in 6
front of the operators maybe a year or two ahead of 7
when an actual plant actually changes to support 8
licensing and training activities. Because as you 9
see, that's quite a big step in that last phase. And 10 that's when a lot of the questions we've received at 11 this point have revolved around. Next slide.
12 So I know that's high level. I went 13 through it fairly quickly. I hope if there's any 14 questions, I'm happy to answer what I can.
15 MR. KUNTZ: Any questions? Okay, were 16 there any questions online?
17 MR. QUINN: I'll ask a question. Ted 18 Quinn, Paragon. It looks like you have maybe equal or 19 larger amount of mechanical work as I&C. Is that 20 true?
21 MR. CHENKOVICH: We have quite a few 22 subsequent license renewal modifications in our whole 23 portfolio. I mean, we work hard just visualize each 24 piece of that. But yes, there are quite a few 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
99 mechanical replacements.
There's generator 1
replacements, feedwater and vessel replacements.
2 Surry's replacing a steam generator. There's a lot of 3
mechanical work happening coincident with this work, 4
yes.
5 MR. QUINN: Excellent, very good.
6 PARTICIPANT: Those phases -- Steve opened 7
your Constellation. Those phases are the outages, so 8
it's basically, unit one and then the AP --
9 MR. CHENKOVICH: In general. As it turns 10 out, we may subdivide them further, yes. But there 11 were originally four phases conceptually, and it's 12 kind of evolved from there.
13 PARTICIPANT: So in your planning efforts 14 for your LAR, are you going to take those into 15 consideration of when you're going to submit?
16 MR. CHENKOVICH: Absolutely. We may 17 actually feed some pre-application information back 18 into that to kind of true up the LAR boundaries for 19 some modifications. Because doing a lot of those 20 things at the same time may be troublesome.
21 PARTICIPANT: Okay. Thanks.
22 DR. AL RASHDAN: So just a strategy 23 question. Do you think taking so much work at once, 24 making it all together it's a good idea? I mean, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 isn't that a bit complicating the licensing approach 1
for you? I don't know, I mean just thinking here on, 2
hear your thoughts about this.
3 MR. CHENKOVICH: Well, candidly, I was 4
surprised my company actually went this far with this 5
project, yes. But we were very lucky that the State 6
of Virginia gave us incentive to pursue these things.
7 So we're taking the feedback that the 8
state is giving us and say we want you to operate as 9
long as you can basically. We like nuclear power, we 10 know it's safe. We want you to keep going. So we're 11 trying to accomplish as much as we can while we have 12 this incentive.
13 DR. AL RASHDAN: Makes sense, thank you.
14 MR. CHENKOVICH: Yup.
15 PARTICIPANT: I would say this from an 16 outage standpoint, there are long duration outages at 17 Surry, steam generator replacement for one, which will 18 enable us to piggyback off of the long duration 19 outage.
20 MR. CHENKOVICH: We are definitely going 21 to try and leverage those long duration periods as 22 much as possible at this point.
23 MS. JOHNSTON: What's the timeline for 24 submitting the LAR, do you know at this point?
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101 MR. CHENKOVICH: We haven't really had 1
much in that area. We are actually just starting 2
conceptual designs on a lot of the safety systems now.
3 So it's very up in the air, like initially in our RIS 4
response we were targeting 2028 submittal, which means 5
we would be having pre-application meetings.
6 We've communicated maybe even by the end 7
of this year. But there's nothing firm beyond that 8
point.
9 DR. AL RASHDAN: Do you have dates 10 assigned to your status? Like deadlines?
11 MR. CHENKOVICH: What are we thinking 12 here? Yes, we have schedules, yeah.
13 DR. AL RASHDAN: How optimistic are they, 14 let's put it that way? Like, I mean, I know there are 15 going to be delays and so on, but are we talking years 16 or like --
17 MR. CHENKOVICH: We're talking in years.
18 Surry extends to 2033, I think, and North Anna is 19 based in the late 2030s. So yeah, it's very spread 20 out.
21 MR. CAMPBELL: I would just add, you know, 22 I probably should have said this before Jeremy gave 23 the presentation but, you know, this is obviously more 24 forward-looking at this point in what we're looking to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
102 do in the hopefully near future with both Dominion and 1
SNC as examples. I know there's others in the room 2
that can provide additional examples.
3 But really we wanted to use this time to 4
highlight the need. I know this is a lessons learned 5
workshop but, you know, there was a point made in one 6
of the plenary sessions yesterday about building upon 7
lessons learned and taking advantage of, you know, 8
capturing those and learning very immediately after 9
that.
10 And so these are projects that are looking 11 to really leverage and use this meeting here that 12 we're having today and tomorrow as a springboard and 13 also reinforce, you know, some of the recommendations 14 that we've made through the ADVANCE Act with NEI and 15 the importance of this to the industry to really 16 incorporate these lessons learned moving forward.
17 So yeah, thanks, Jeremy, for providing the 18 presentation. I'll turn it over to Harry Burke with 19 Southern Nuclear.
20 MR. BURKE: Thank you, Alan, for setting 21 the stage. I definitely appreciate it.
22 As Alan said, I'm Harry Burke from 23 Southern Nuclear. I am the Digital Program Manager 24 for all the digital projects that we are running at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
103 Southern Nuclear come through my program. I'm in 1
charge of the financials and executions, as well as 2
part of a strategy. I co-strategize with the CDO 3
Group, specifically Ray Herb (phonetic) from CDO.
4 So just to give you a little bit of 5
backstory about the Southern Nuclear fleet, we do have 6
two Westinghouse vintage PWRs with 7300 protection 7
cabinets. That's the Farley Unit and 2 and Vogtle 8
Unit 1 and 2.
9 We also have a Hatch Unit 1 and 2. It's a 10 BWR vintage. And then of course as everyone knows we 11 have Voglte 3 and 4, which is the new AP1000 vintage.
12 So next slide, please.
13 So the digital program, we look to 14 strategically implement digital progress across the 15 Southern Nuclear fleet using a standardized approach 16 for training aspects, also for researchers working on 17 similar technologies. Ameliorization of proficiency 18 that's built throughout using the same technology 19 across your fleet and consolidation of expertise for 20 support. Because you have multiple different 21 platforms and multiple different stations, you lose of 22 that expertise and end up being resource-limited 23 across your fleet.
24 We are taking a similar approach that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
104 Dominion just spoke of about doing a standardized 1
approach across our fleet. Next slide.
2 So the intent of the digital program is to 3
do ops center focused and I&C focused scoping. We're 4
looking to optimize plant performance in operations 5
with single point vulnerability -- I can't say that 6
for some reason - elimination and risk removal.
7 We're also looking at ways to automate the 8
plant so instead of an operator having to take a male 9
switch to get a full rate locked in, we're looking to 10 provide that automatic control to the operator so they 11 don't have to sit there and have an error likely 12 situation.
13 We're also looking to, where we have a 14 time-critical operator actions, looking to see if we 15 can build some automation into that to allow those 16 operators to easily meet those time-critical actions.
17 We're also looking to improve equipment 18 reliability by adding the monitor and diagnostic 19 capabilities of the systems that the digital systems 20 have already built into them to help us monitor and 21 protect that equipment.
22 We're also looking to reduce O&M costs by 23 crediting the reliable diagnostics that these systems 24 do on their own, thereby reducing our manual 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
105 surveillances and operational risk. Next slide, 1
please.
2 So the digital program came into existence 3
through the modernization implementation plan. We 4
took that a step further and we actually created an 5
end vision for each one of our sites.
6 What the end vision does it take all of 7
the different phases, similar to what the main has 8
that actually builds the roadmap of how all of them 9
will impact and change the control room so that 10 operations is well aware of it. It's been human 11 factors evaluated for each one of the phases.
12 And there's a roadmap so that there's not 13 a rework or taking things out after one phase is done 14 and the next phase has to take that piece of equipment 15 out. We've done that work. We came up with eight 16 phases for Farley, ten phases for Hatch, and seven for 17 the Vogtle 1 and 2 sites.
18 So that was a
very strategic and 19 integrated and holistic approach with human factors in 20 mind and operations focus in mind to maintain that 21 continuity of operations throughout each one of these 22 phases.
23 It also looked at what the site needs and 24 prior code the site needs for their obsolescence and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
106 their issues and their risks that they currently have 1
and balance that against the digital strategy to come 2
up with a centric approach to upgrading and 3
modernizing the Southern Nuclear fleet. Next slide.
4 All right, so for the Farley project 5
specifically, there are no near-term projects that's 6
less than five years that are going to require a LAR 7
or use the ISG-06 process. The majority of those 8
projects or all those projects will utilize the 50.59 9
process.
10 That in-core core cooling monitoring 11 system, that is their first safety platform upgrade at 12 Farley. That will be a, upgrading that to Common Q 13 along with addressing the reactor vessel level 14 indication. That, again, is not expected to require 15 a LAR. It expects to use the 50.59 process.
16 We do have longer term modifications that 17 will use the LAR and will utilize the ISG-06 process.
18 Next slide.
19 Same kind of situation in Hatch. The 20 near-term projects are going to utilize 50.59. There 21 is a reactor protection project that is on the cusp of 22 that five years but might end at five years. That 23 will require a LAR and will utilize the ISG-06 24 process. And there are some other longer term 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
107 modifications that will require a LAR and utilize the 1
ISG-06 process. Next slide.
2 For the Vogtle project, there is one 3
project of note that it's within the five-year 4
timeline that will require a LAR. I'll talk about 5
that in a second.
6 But our first safety upgrade for the 7
digital modernization is the PAM system. That is 8
going to be replaced with a Common Q system. That's 9
going to be in 2029, spring or fall. That is expected 10 to use the 50.59 and not require a LAR.
11 The reactor protection project, that 12 letter of intent is going to be in early 2026, maybe 13 even late 2025, depending on how much Jeanie will let 14 me submit that early. And then we are anticipating 15 submitting that LAR in February 2028. And then the 16 longer term modifications, there are projects that 17 will require a LAR and utilize ISG's process. Next 18 slide.
19 So obviously I didn't go into great detail 20 about every single project, but I wanted to bring up 21 what's in the near term and long-term for Southern 22 Nuclear. But the thing I really wanted to address, 23 and I'm going to read this whole line for line, 24 because I spent some time writing this one.
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108 So the obsolescence and aging of the 1
current control and protection system in the nuclear 2
fleet is quickly growing to be a heavy burden. The 3
industry has done well to maintain and keep these 4
systems at peak readiness but has had to endure great 5
lengths in cost and maintenance efforts to the ever-6 growing difficulty in finding parts and expertise.
7 That's upgrading the older control 8
protection systems to advanced digital system is 9
crucial to continued safe and reliable operation 10 throughout the industry. The Southern Nuclear digital 11 program will be upgrading systems that will require a 12 LAR and use ISG's process.
13 Ensuring efficiency, repeatability, 14 timeliness, and accuracy in the ISG-06 process, along 15 with continued interaction with the NRC is critical 16 for the success of the projects at Southern Nuclear 17 and throughout the industry.
18 And with that, I will open it to 19 questions.
20 DR. AL RASHDAN: Last one, I promise. Was 21 there a specific criteria for why you selected those 22 specific systems at those specific plants?
23 MR. BURKE: Yes, so those systems were 24 either based on obsolescence or plant risk. Some of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
109 them were obsolete and on the verge of being reduced 1
to maintain the plant in operation. Those ones were 2
prioritized. Some of the systems that were selected 3
were prioritized based on operational needs due to 4
work-arounds and some other issues that ops are 5
challenging with.
6 So they were all done with some mitigation 7
or elimination with that in mind, with also ensuring 8
that we maintain the standardization across so that 9
we're not doing the same project at two different 10 fleets at the same time to utilize those efficiency 11 gains.
12 DR. AL RASHDAN: Thank you.
13 MR. KUNTZ: Any additional questions in 14 the room?
15 MR. QUINN: I'll ask one. Ted Quinn.
16 Similar to when you have a large human factors element 17 in what you were just showing, is that going to be 18 similar, significant vertical board changes?
19 MR. BURKE: Yes, so and that's what the 20 end vision actually did, it actually went through each 21 one of those stages and had a human factors evaluation 22 and an ops evaluation done on each one of those 23 stages.
24 MR. KUNTZ: Okay.
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110 MR. DARBALI: There's a hand raised 1
online.
2 MR. KUNTZ: Okay.
3 MR. FOX: Yeah, this is Charlie Fox from 4
APS. I noticed that in your scheduling you have a 5
normal five-year schedule for an RPS upgrade. Are you 6
expecting within a normal five-year period of mod to 7
be able to get through the ISG-06 plan?
8 MR. BURKE: Yes. So part of our schedule 9
development is we actually built in sufficient time 10 for both the LAR creation and submittal and review to 11 meet our deadlines. In fact, we actually added a 12 little bit of time in there based on some recent 13 feedbacks from some industry folks in here.
14 MR. KUNTZ: Anyone else online have a 15 question? Anybody else in the room? Okay.
16 Our agenda would allow us some time for 17 public comment, so is there anyone in the room on 18 online that would like to ask questions of the NRC 19 staff about the discussion today? I suspect we've 20 probably addressed them as we've gone, but then you'd 21 like to ask anything of the staff, now is an 22 opportunity. There'll be others tomorrow as well.
23 Okay.
24 MR. SAMSELSKI: I do have a question.
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111 MR. KUNTZ: Rich Stattel.
1 MR. SAMSELSKI: Yeah, this is Rich Stattel 2
from General Electric. So in the recent RIS-25-01 was 3
sent out, is the NRC planning on putting some kind of 4
report together based on the findings, are there 5
responses to that?
6 Because there wasn't - there wasn't 7
anything mentioned in the RIS or the understanding is 8
that the NRC would use that for staffing and planning, 9
for the workload in the next two years, right? Is 10 there anything that we would see on the outside that 11 would result and would help us to plan as well?
12 MR. DARBALI: So this is Samir. We have 13 not discussed if that information will be shared 14 publicly. I don't know if there's an expectation that 15 that's communication between the licensee and the 16 staff. But like you said, it's for us to better 17 understand what's coming and how we could prepare to 18 support that.
19 MR. KUNTZ: Okay, any other questions in 20 the room? Anyone online have any questions? So the 21 plan then is in the morning to pick up with one more 22 lesson learned from the industry. And then we'll work 23 through the staff's presentations and lessons learned 24 at 9:00 a.m. tomorrow.
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112 Was that on anything else you wanted to 1
add? Okay, Alan, anything else before we adjourn 2
today?
3 MR. CAMPBELL: Yeah, I'll just quickly 4
recap. You know, it's just listening, obviously we've 5
put a lot of effort into, you know, consolidating 6
lessons learned. And but hearing it and hearing our 7
future really my takeaway is we're really matured in 8
our understanding of these systems over the last 9
probably six years or so in the development.
10 You know, where we thought we were with 11 the ARP during its initial creation. The industry's 12 matured and using is less from an obsolescence patch 13 or band-aid there and more to an enabling technology.
14 And something that we're really looking to change the 15 way the operators can engage with the plant more.
16 And so I think what we're hearing is the 17 need for this process to adapt with that and the use 18 of, you know, having a process that's adaptable.
19 We're hearing projects that range in scale and scope.
20 And just having a scalable and adaptable process you 21 know, for us is really the main goal from collecting 22 these lessons learned and then taking those next steps 23 forward.
24 And so we're looking forward tomorrow to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
113 hearing the staff's experience through these processes 1
and to see if there's similarities from your 2
perspectives as well and looking forward to the open 3
discussion pieces as well. So thank you.
4 And I would just offer, I know we have a 5
few of the engineering VPs from the industry. I know 6
I didn't ask you to prepare any closing remarks, but 7
if you guys had any takeaways, either Ron, James, or 8
we also have Earl Berry from Southern Nuclear here as 9
well. You don't have to.
10 (Laughter.)
11 MR. BERRY: I appreciate my friends.
12 Thank you very much. You know, Alan, you said it 13 well. We're really here to share those lessons 14 learned. And I think the teams have done a really 15 great job with that.
16 You know, I got to sit through the RIC all 17 week, and a lot of the things that we talked about I 18 think perfectly overlap with what our objectives are 19 here today and what you've been talking about here.
20 There's no way we're going to meet the demands that 21 we've talked about without working together and 22 working through some of these challenges.
23 And the biggest key to doing that is to 24 understand what everybody's needs are. I think you've 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
114 seen the lessons learned and we've talked a little bit 1
about some of the needs. One of the things that, and 2
I know you obviously did this RIS and we've done 3
things at NEI also to understand the demand for, you 4
know, across our industry.
5 But one of the things that I think is, it 6
should be painfully clear to everybody that's in our 7
industry is that with our needs today, we really have 8
no choice but to upgrade our plants and of course 9
build new ones, which will have these same digital 10 systems. Hopefully some newer ones will be introduced 11 here soon.
12 And they're all going to be implemented.
13 Well, we talk about great schedules and how we've laid 14 them out. The reality is they're all implemented on 15 top of each other, right. They're all implemented 16 with technologies that have limited shelf lives, 17 right, limited windows that their manufacturers 18 create. And to start to end of this process means 19 that we have lost most of that.
20 So I am lucky enough to have one of the 21 newest plants in the world, right. I have to replace 22 the digital systems. He has to replace the digital 23 systems. We're not talking about that here because 24 this is slightly different, but he has to go replace 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
115 them. That's starting for new plants. That's the 1
nature of the digital systems.
2 So while we are talking about 3
modernization of the existing systems and we're 4
talking in that vein, I'd like us to think about the 5
bigger picture here, which is this has to continue, 6
and it has to get faster. A lot of my peers, a lot of 7
our peers, you've got some of the bigger ones here 8
today, they're kind of waiting for us. That's 9
generally how they work.
10 But the pressure on them is increasing, 11 and it's increasing fast. You know, Harry's nice when 12 he says, you know, we're doing these things because 13 they're obsolete and we maintain our systems. But 14 that's an 8086 computer we have to replace at Vogtle.
15 We picked a system which may not seem as important, 16 but it's because it's an 8086 computer. That's what 17 we have to replace.
18 We have systems like that. You all know 19 the difficulties of them. And when we go through and 20 we refurbish some of these components, because we 21 can't replace them, our maintenance is to refurbish.
22 There are pieces in those systems that cannot be 23 refurbished because they are not available. They 24 haven't been available for 20 years.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
116 So we have teams, extenders, doing 1
remarkable things to keep them alive. This is an 2
absolute imperative. This 100% aligns with the 3
mission statement that you have here at the NRC, and 4
we love that mission statement, by the way. And this 5
process I think, you know, we're all in. I think we 6
heard that. We're excited by it.
7 And we're looking forward to that 8
discussion tomorrow because we know you all have great 9
ideas on what you're going to do in that next 10 revision. So I'm looking forward to it. I think 11 we've started well, and I thank you very much for the 12 discussion.
13 Thank you guys for the opportunity.
14 MR. DARBALI: Rob, somebody asked if we 15 could share the schedule for tomorrow.
16 MR. KUNTZ: Yup.
17 MR. DARBALI: You had it up.
18 MR. KUNTZ: I did have it up earlier. So 19 let me pull it up again. Yeah, so tomorrow morning 20 we'll begin at 9:00 a.m., that's sharing. And with 21 the industry presentation, one more lessons learned.
22 And then the staff will work through 23 their presentations, digital I&C lessons learned and 24 human factors in vendor inspection. And then the plan 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
117 is to adjourn, have lunch, and finish up with 1
inspection, inspection plans. And then we'll have an 2
open discussion as we discuss, talk about anything 3
that we didn't get to during the discussions up to 4
that point.
5 Okay? All right, so with that we'll go 6
ahead and adjourn for today and we'll get going at 7
9:00 a.m. tomorrow. Thank you.
8 (Whereupon, the above-entitled matter went 9
off the record at 4:50 p.m.)
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