ML26071A279
| ML26071A279 | |
| Person / Time | |
|---|---|
| Issue date: | 02/05/2026 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-0559 | |
| Download: ML26071A279 (0) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
732ND MEETING ADVISORY COMMITTEE ON REACTOR SAFEGUARDS Location:
Rockville, Maryland Date:
Thursday, February 5, 2026 Work Order No.:
NRC-0559 Pages 1-34 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 732ND MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 THURSDAY 8
FEBRUARY 5, 2026 9
+ + + + +
10 The Advisory Committee met at Two White 11 Flint
- North, 11545 Rockville
- Pike, Rockville, 12 Maryland, and via videoconference, at 8:30 a.m. EST, 13 Gregory H. Halnon, Chair, presiding.
14 15 COMMITTEE MEMBERS:
16 GREGORY H. HALNON, Chair 17 DAVID A. PETTI, Vice Chair 18 CRAIG D. HARRINGTON 19 ANNIE M. KAMMERER 20 WALTER L. KIRCHNER 21 ROBERT P. MARTIN 22 SCOTT P. PALMTAG 23 THOMAS E. ROBERTS 24 MATTHEW W. SUNSERI 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1
DESIGNATED FEDERAL OFFICIAL:
2 LARRY BURKHART 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 CONTENTS 1
PAGE 2
Opening Remarks by the ACRS Chairman 4
3 Self-Assessment/Lesson Learned 9
4 Public Comment 34 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 P-R-O-C-E-E-D-I-N-G-S 1
8:30 a.m.
2 CHAIR HALNON: Good morning, this meeting 3
will now come to order. This is the first day of the 4
732nd Meeting of the Advisory Committee on Reactor 5
Safeguards.
6 I am Greg Halnon, Chairman of the ACRS.
7 ACRS members in attendance in person are Craig 8
Harrington, Annie Kammerer, Robert Martin, Scott 9
Palmtag, Dave Petti, and Tom Roberts.
10 Walt Kirchner and Matt Sunseri are 11 participating virtually via Teams. If I've missed 12 anybody, I think that's the entire committee, so I 13 don't expect anyone to speak up, but just in case, 14 speak up.
15 Larry Burkhart of the ACRS staff is our 16 designated federal officer. We also refer to that as 17 a DFO. And, he will be today, the DFO for today's 18 full committee meeting.
19 We do have a quorum.
20 The ACRS was established by the Atomic 21 Energy Act, and is governed by the Federal Advisory 22 Committee Act.
23 Under the Atomic Energy Act, ACRS must 24 advise the Nuclear Regulatory Commission on hazards 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
5 proposed and existing reactor facilities, and the 1
adequacy of proposed safety standards.
2 Following Executive Order 14300, the 3
Committee has narrowed its focus to those activities 4
necessary to fulfil its statutory obligations.
5 As a result, ACRS is prioritizing the 6
review and reporting of new reactor facilities and 7
proposed safety standards, with particular attention 8
to issues that are unique, novel, and noteworthy.
9 The Committee will consider other nuclear 10 safety matters at the direction of the Commission.
11 Please note that the ACRS speaks only 12 through its published letter reports. All member 13 comments should be regarded as only the individual 14 opinion of that member; not a Committee position.
15 Information about the ACRS activities such 16 as letters, meeting rules, and transcript are on the 17 NRC public website and can be found by searching, 18 about us ACRS, on the NRC's home page.
19 The ACRS provides an opportunity for 20 public input and comment on relevant, technical issues 21 during our proceedings.
22 For this full committee meeting, we have 23 received no written statements, or requests for verbal 24 comment. Written statements may still be forwarded 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
6 today's designated federal officer.
1 We have set aside some time at the end of 2
our meeting, the deliberations portion, for a public 3
verbal comment on the Committee technical reports.
4 A transcript of today's meeting is being 5
kept and will be posted on our website. When 6
addressing the Committee, participants should first 7
identify themselves, speak with sufficient clarity and 8
volume so that they may be readily heard.
9 If you are not speaking, please mute your 10 computer on Teams. If you are participating by phone, 11 press *6 to mute your phone, and *5 to raise your hand 12 on Teams.
13 The Teams chat feature is for only 14 communicating IT issues or brief meeting logistics.
15 Please do not use it for comments or questions on the 16 topics under the Committee discussion.
17 For everyone in the room, please put all 18 your electronic devices in the silent mode, and mute 19 your laptop microphone and speakers.
20 In
- addition, please keep sidebar 21 discussions in the room to a minimum since the ceiling 22 microphones are live.
23 For the presenters, your table microphones 24 are unidirectional and you'll need to speak into 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
7 front of the microphone to be heard online.
1 Finally, if you have any feedback for the 2
ACRS about today's meetings, please fill out the 3
public meeting feedback form on the NRC website.
4 Today we will be able to discuss and 5
develop a letter report on lessons learned and good 6
practices, from the previous and more recent 7
application reviews.
8 We, as a Committee, strive to continuously 9
refine our approach to these complex reviews by 10 applying these lessons to the ongoing and future 11 reviews, to gain not only proficiency, but to ensure 12 a cross-cutting and thorough technical review.
13 After this is completed, then we'll move 14 into our procedures and planning session, which is 15 more administrative.
16 So, before I go on further, I wanted to do 17 a mic check with Walt and Matt. Could both, are you 18 able to hear us okay, Matt and Walt?
19 MEMBER KIRCHNER: Yes.
20 MEMBER SUNSERI: Yes, this is Matt.
21 CHAIR HALNON: Okay, and Matt, I heard 22 your microphone, you're good?
23 MEMBER SUNSERI: Yes, Greg, I can hear you 24 all fine. Can you hear me okay?
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8 CHAIR HALNON: Yes, yes. I just wanted to 1
make sure that we didn't get into a distraction if 2
your mics didn't work, so appreciate that.
3 MEMBER SUNSERI: Yes, can I say one thing 4
before if you're done with your opening?
5 CHAIR HALNON: Yes, go ahead.
6 MEMBER SUNSERI:
Maybe you've got 7
something planned here, but I'd just like to 8
acknowledge this is the first full committee meeting 9
since the election of our new officers.
10 And I want to, I think the Committee 11 appreciates your commitment to support us. It's not 12 an easy job; it's a handful, and you don't get paid 13 anything extra.
14 So thank you for this service you're about 15 to provide us in the coming years. Thank you.
16 CHAIR HALNON: Thank you, Matt, I think 17 you set a high bar for us, so appreciate that --
18 (Laughter.)
19 CHAIR HALNON: -- that acknowledgment.
20 Anyone else got anything else to discuss?
21 MEMBER KIRCHNER: I'll go ahead and check 22 my mic, Greg, and second Matt's comments. Thank you.
23 CHAIR HALNON: Thank you Walt, and we do 24 appreciate both of your services over the last 4 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 years. Because Matt, you've been an officer several 1
times, so appreciate that.
2 And Walt, you made it easy for me. You 3
set a good glide path for us.
4 Anybody else want to get something off 5
their chest?
6 (Laughter.)
7 CHAIR HALNON: Okay, thank you. At this 8
time, I'm going to turn the meeting over to Dave 9
Petti.
10 Dave petti was our lead member on the 11 lessons learned, and self-assessment process. And, he 12 will lead us through this next session, so Dave?
13 VICE CHAIR PETTI: Okay, so before we get 14 into the letter, I thought it would be useful to have 15 a little bit of discussion from members about what 16 were their important takeaways, lessons learned from 17 the reviews they've participated in going back to 18 NuScale and Kairos.
19 One of the things that in the letter the 20 way I've drafted it, is I've not, I've organized the 21 thoughts in topic areas. But I've not purposely 22 prioritized them, per se.
23 So that's something that I'd maybe like 24 some feedback is if you think that that, this is 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
10 most important in that sub-category. We might change 1
the order of something, and things like that.
2 So, I just opened it up. Maybe start with 3
Walt. Walt, what's your big takeaways as we look 4
back?
5 MEMBER KIRCHNER: Thank you, Dave, I had 6
to find my microphone. I think the important takeaway 7
is over the last several years, it goes back to the 8
NuScale DCA review.
9 But more recently, the focus on what we've 10 defined as the safety case. And the fundamental 11 safety functions and how the designs that we're 12 reviewing, accomplish those.
13 And that has been a framework if you will, 14 to focus our reviews even further; cut through the 15 extraneous material.
16 There's a lot of material that the staff 17 looks at in the course of a thorough and comprehensive 18 review of an application.
19 But for the committee, I think our highest 20 value is to provide timely advice to the Commission.
21 And the best way to do that is to continue to 22 concentrate on the, pardon the poor choice of words, 23 the core of the safety case that an applicant is 24 presenting, and the staff has reviewed.
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11 VICE CHAIR PETTI: Okay, no, I appreciate 1
it.
2 MEMBER KIRCHNER: Thanks, I agree with you 3
completely, that's but Matt, I'll go with the 4
external.
5 MEMBER SUNSERI: Yes, thanks, Dave. So, 6
I think what I appreciate or I think is from a lessons 7
learned perspective, is how we continue to evolve our 8
internal process to move away from so much dependence 9
on the staff in the final SE.
10 Because as you recall, we started out with 11 a draft SE with open items. And then, we had a SE.
12 Then we switched to SE with just closed items.
13 And now we're kind of being able to look 14 at these applications somewhat independent of the 15 safety evaluation.
16 Clearly the staff is a stakeholder, much 17 as the applicant is stakeholders. And we need 18 interface and interact, and talk to those folks.
19 But the quality of our letters to me, seem 20 to be as good as they've ever been. And we're 21 spending a lot less time looking at SEs and draft SEs, 22 and things of that nature.
23 So I think that, and I think you got that 24 captured in your report.
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12 VICE CHAIR PETTI: No, I agree with that, 1
too. Good points. Tom?
2 MEMBER ROBERTS: Yes, having led the most 3
recent review that we had that was back in November, 4
I would certainly reinforce what both Walt and Matt 5
said in terms of the focus on what's unique, novel, 6
and noteworthy.
7 And something that a more formalized to 8
the committee during the interim review. And, we 9
jumped on that and as quickly as we could, given the 10 schedule, we identified what is unique, novel, and 11 noteworthy.
12 So in terms of lessons learned, early 13 engagement like we're having now with all these 14 projects to ensure that we have an open communication 15 among the committee, and then with the staff on what 16 we're saying is the focus areas, so that's something 17 we can do early. It helps focus what's coming later.
18 And the second final thing, what worked 19 well I thought with Natrium, was engaging with the 20 staff to understand what significant changes were 21 being made by the applicant during the process.
22 So just, we could have a fair amount of 23 effort end up being wasted when we have problems with 24 something the staff's already had problems with, 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
13 the applicant's in the process of either having 1
revised it, or already revised it, and we just don't 2
know.
3 Having that engagement with the staff, not 4
to duplicate their review, just to know what the hard 5
spots they're running into, and avoid us having to 6
spend a lot of time chasing down the same hard spots.
7 So I think all of that's captured in the 8
last letter I saw. Thank you.
9 VICE CHAIR PETTI: Scott?
10 MEMBER PALMTAG: Yes, being newer on the 11 committee, I don't really have much to compare to how 12 it was previously done.
13 But just watching what we've done, 14 especially the new Natrium stuff, I thought the review 15 with Tom went really well.
16 Just to reiterate on what Walt said is the 17 focus on the safety case, and fundamental safety 18 features.
19 My feeling is we're not here to check the 20 staff, or duplicate what the staff did. We have to 21 add value, and I think our value has kind of taken a 22 holistic view of what's going on, and kind of looking 23 at the safety case independently.
24 Looking at the whole picture, not just 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 whether all the boxes are checked.
1 CHAIR HALNON: Thanks.
2 MEMBER MARTIN: I think I'll begin with 3
earlier, your acknowledgment in the draft letter about 4
what appears to us that applicants will be pushing 5
much of the hard work to the OL.
6 And so, I took the opportunity the last 7
couple of months since we've brought up the lessons 8
learned, to coalesce a number of thoughts that I've 9
had going back from when I started.
10 There's those that were on then, recall 11 that I pushed early this idea this hazards working 12 group.
13 And, we had a great meeting with Bill 14 Reckley, and I think it was Michelle Hart, and anyway, 15 senior experienced staff or retirees in the case of 16 Bill.
17 And, we followed that up with another 18 meeting on cliff edge, which is getting not 19 necessarily under the umbrella of hazards.
20 But as we try to understand the safety 21 case, the safety case particularly related to the risk 22 informed framework, and how that of course into the 23 Part 50 rule, there are definitely, there's definitely 24 work to do to create a common understanding about 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 expectations from the staff's review standpoint. And 1
of course, our own.
2 Because again, one thing to have a Reg 3
Guide out there. And, it's another thing to actually 4
see it applied.
5 CPA is still very early in the process.
6 It's inherently going to have omissions that we would 7
rather not see, or see more completeness, but that's 8
not the process that is Part 50.
9 But to save time when we make the 10 statement like we perceive that the applicants are 11 pushing more to, to the OL stage, you want to make 12 sure that there is an understanding of expectations 13 going into that phase, before you meet them at the 14 end.
15 Because we don't want a situation where 16 oh, by the way, 18 months for review has gone by and 17 we see something on the screen that just doesn't 18 connect to the ultimate goal of getting their 19 operating license.
20 So, in trying to coalesce these thoughts 21 of hazards analysis and cliff edge effects, and the 22 application of NEI 18-04, I drafted a tome, 80+ pages 23 now.
24 Handed it off to a few people to get some 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 feedback. It has basically three elements, three main 1
critiques.
2 One addressing really more standardization 3
with regard to the really establishing requirements, 4
which is related to hazards analysis, which of course 5
you've heard me say on many occasions.
6 And then, bring in the experience that 7
I've had and of course others have had on Pele, with 8
applying the DOE process.
9 Of course, there's other activities out 10 there that maybe might want to coalesce some DOE and 11 NRC alignment, so there may be an opportunity there.
12 The second area that I address, is the 13 cliff edge question. I did notice that Dave in your 14 letter, you kind of acknowledged somewhere in there 15 about expanded figures of merit.
16 And kind of gets into this, this question 17 of how do you explore that space? So the space is 18 really a beyond design basis space.
19 And, in the light water experience, that 20 gets characterized fairly well. Whether the industry 21 and ourselves want to acknowledge it, for these light 22 waters in Part 50 and Part 52, there are beyond design 23 basis accidents you have to look at.
24 Or, you could call them design extension 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 events as the internationals do. But even things like 1
LOCA or ATWS, or hydrogen combustion, these are not 2
design basis events. These are beyond design basis 3
events.
4 And so, in moving towards a risk informed 5
process, what are those events for these new reactors?
6 And if you are going to follow the commissioners' 7
policy on advance reactors that you're going to be as 8
good or better than the light water reactors, is there 9
an expectation of an equivalence as far as the work 10 that has traditionally been done in that domain?
11 So, at the high level, there is the 12 question of how do you go about cliff edge? I think 13 one thing that's always annoyed me is that the Reg 14 Guide, and I don't know if it's 1.233 or Tom you might 15 correct me, where it says you need to show that there 16 are no cliff edge.
17 It's a -- you're proving a negative. It's 18 the language that's in the Reg Guide, to show that 19 there are no cliff edges, something like that.
20 And, it's always annoyed me that the 21 language is in there like that. Because you can't 22 really prove a negative in the same way. You have to 23 do the work.
24 The second --
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18 (Simultaneous speaking.)
1 VICE CHAIR PETTI: I know the staff 2
concluded the MSTGI has been proven. Is that 19.93, 3
but I can read the --
4 MEMBER MARTIN: And fine, but it's an 5
exercise on how you --
6 VICE CHAIR PETTI: Well, it is --
7 MEMBER MARTIN: It's not to give you know, 8
it's and there's always a cliff edge, right? I mean 9
there's --
10 VICE CHAIR PETTI: The question is at what 11 probability?
12 MEMBER MARTIN: And, well, and how do you 13 make the box? So that's the other, that's, yes, 14 Appendix B is that creating the box.
15 So, in light water reactor, these were an 16 advanced reactors, we have something called the beyond 17 design basis or severe accident entry point. So a lot 18 of plants, a lot of designs, will quantify or 19 characterize that entry point.
20 We need to see what these applicants think 21 is the entry point. And, I think that gets into this 22 point about other figures of merit, you know, they 23 need to protect themselves from getting into this 24 space. We need to know what that entry point is.
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19 And, I think that gets into the mechanics 1
of cliff edge effects. And so, I'm implying here that 2
we need like a Reg Guide on hazards analysis; a Reg 3
Guide on how to do cliff edge effects.
4 And then, the Appendix C that I've 5
drafted, is what I think is again an omission with 6
regard to the application of NEI 18-04.
7 It is if you read it, it is 95 percent 8
level one type activities. There is a section in 9
there that talks about identifying overall plant risk 10 metrics.
11 It's kind of like the level 2/level 3, 12 Section 3.3.5. No one has said a word about 13 establishing risk metrics in relationship to that 14 section.
15 So, that might be an OL thing to do, and 16 we'll see it. I'm not sure, nor do I see a level 2 --
17 (Simultaneous speaking.)
18 VICE CHAIR PETTI: -- talking about cancer 19 effect? Latent cancers and --
20 MEMBER MARTIN: Not that far.
21 VICE CHAIR PETTI: -- CDFs?
22 MEMBER MARTIN: Well, that could be 23 implied by that section. But it's mostly focused on 24 level 2-like things.
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20 So, you know of course the difficulty is 1
these plants don't necessarily have a core damage 2
frequency.
3 And so, what it acknowledges in that 4
section is that you can't find, it was encouraging 5
applicants to identify what might be equivalent.
6 Ultimately, it comes down to some kind of 7
consequence. So, in my write-up I refer to a 8
contrasting something called event sequence families, 9
which is in NEI 18-04, as a causal family of events, 10 right? LOCAs and loss of heat sinks, and you can go 11 on and on.
12 To something that's more focused on the 13 consequence, just like you do with the end of level 1 14 identifying core damage frequency.
It's a
15 consequence, a frequency.
16 Same thing with other plants, just 17 focusing say on a band of say, dose consequence.
18 CHAIR HALNON: Bob, I, you're getting into 19 some extremely detailed philosophy --
20 (Simultaneous speaking.)
21 MEMBER MARTIN: Well, it's --
22 CHAIR HALNON: -- so I'm just wondering --
23 MEMBER MARTIN: -- like, that's right.
24 Well, and so the lesson learned is that there 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
21 there is omissions.
1 Now, I've taken my 80-page thing and I 2
gave you, I gave Dave two, two things, which relate to 3
really the, this space of beyond design basis.
4 I think what I --
5 (Simultaneous speaking.)
6 VICE CHAIR PETTI: I don't necessarily 7
agree with your characterization of for instance 8
Natrium. Because I can read the document. They had 9
a CD, right?
10 MEMBER MARTIN: They --
11 (Simultaneous speaking.)
12 VICE CHAIR PETTI: I was really surprised 13 that they went all that way.
14 MEMBER MARTIN: They did, they did. Well, 15 and they, well, they kind of, now we had some debate.
16 I mean Walt actually brought up the comment about is 17 the core disruption event just what they chose say one 18 fuel rod failure, or is it I guess as IAEA I think had 19 concluded in their, one of their safety guides on 20 LMFBRs, is it the whole core?
21 They went with, used risk arguments to 22 narrow it down to, and I will admit it was a pretty 23 good story.
24 But again --
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22 (Simultaneous speaking.)
1 CHAIR HALNON: I know, but they were, they 2
were long before you were here with Part 53 3
discussions about whether you could actually calculate 4
those metrics for these designs, because you can't get 5
to those.
6 The damage is the same, you can't get to 7
the equivalent damage dates.
8 MEMBER MARTIN: Right.
9 VICE CHAIR PETTI: The fact that they 10 actually did it said to me, I mean it would be 11 interesting to really understand what it was.
12 And, I'm sure the staff is going to get 13 into it because I'm sure the staff is --
14 (Simultaneous speaking.)
15 MEMBER MARTIN: Well --
16 VICE CHAIR PETTI: -- at the OL stage.
17 MEMBER MARTIN: Well, the title of what I 18 titled this thing was, fragmentation of residual risk.
19 And that's kind of the broader concern, is that the 20 methods when you get out there, encourage basically a 21 divide and conquer approach in a range of where 22 epistemic uncertainty is much, much larger than the 23 aleatory uncertainties that basically has been used to 24 populate PRA models.
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23 And so, my concern is that they're going 1
through individually and knocking out events when in 2
fact, all those events could be gathered together 3
under a particular consequence.
4 Whether it's a core damage frequency or 5
some other --
6 VICE CHAIR PETTI:
But I
think 7
mathematically, you can prove that's not a problem.
8 MEMBER MARTIN: No, well so --
9 (Simultaneous speaking.)
10 VICE CHAIR PETTI: If in fact, I mean 11 again, it's two different arguments. If you just have 12 one or two lines of defense, and you're going to make 13 your argument or probability because you think you've 14 got a really good, then I'd buy your argument.
15 But when you have three or four or more 16 lines of defense, the probability is so low that the 17 number of sequences you'd have to have to get it into 18 a spot where you have to worry about, is --
19 (Simultaneous speaking.)
20 MEMBER MARTIN: My point is they've got to 21 do that work. Not that it's not bad or anything, it's 22 they just need to show the work.
23 And, I guess my background in --
24 (Simultaneous speaking.)
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24 CHAIR HALNON: That's the lesson is they, 1
you want to see the work.
2 MEMBER MARTIN: I want to see the work and 3
transparency of that.
4 CHAIR HALNON: You wrote a paper, a draft.
5 Not all of us have seen it. It's personal work of 6
yours, so on your personal time.
7 MEMBER MARTIN: Yes.
8 CHAIR HALNON: We're not going to 9
adjudicate it in this meeting, and/or try to convince 10 one side or there other whether or not the arguments 11 will. Because some of us are flying blind.
12 MEMBER MARTIN: Of course.
13 CHAIR HALNON: And, you haven't submitted 14 anything and it's not even, it's not even a work in 15 progress, I guess.
16 So let's stick to lessons learned if it is 17 you'd like to see that work, then that's the lesson 18 learned.
19 MEMBER MARTIN: Exactly. And that's what 20 mostly this is. I want to see the work of the --
21 (Simultaneous speaking.)
22 CHAIR HALNON: -- referring back to a 23 paper that not everyone has seen.
24 MEMBER MARTIN: -- with the cliff edge 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 effects, and the work with overall plant risk factors.
1 CHAIR HALNON: Okay.
2 MEMBER MARTIN: So, there would be three 3
items.
4 VICE CHAIR PETTI: You know what the 5
problem is, right? The PRA is not on the docket.
6 MEMBER MARTIN: And so, that is a problem.
7 VICE CHAIR PETTI: The test that's going 8
to be done because they don't want to put, I mean it's 9
a massive amount to put on the --
10 (Simultaneous speaking.)
11 MEMBER MARTIN: But see if you have a --
12 VICE CHAIR PETTI: So it will be done by 13 audit. It will be done by audit by the staff.
14 MEMBER MARTIN: Right, and so make the 15 safety case that's fundamentally based on the PRA, it 16 needs to be more visible. Particularly to us.
17 VICE CHAIR PETTI: That's not the -- yes, 18 okay, you can do it verbally, you can, you know. But 19 the guidance from the staff is you don't have to put 20 it on the docket. You have to put a summary, right?
21 MEMBER MARTIN: The PRA that was used in 22 Part 52 as a verification activity to demonstrate the 23 deterministic decisions are appropriate.
24 Now we're well we've flipped the script.
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26 Now Part 50 is still a little funny, right, where 1
they've integrated it. And Part 50 really is still a, 2
it's supposed to be a deterministic type thing.
3 Now Part 53 might be different. But I 4
would just say and yes, I'll acknowledge CPA is early 5
and some of these things would naturally be done 6
later.
7 But a lot of new people out there, and I 8
just, I think it's an opportunity to communicate that 9
we see these omissions at CPA, and that the rigor 10 associated with the three things I've mentioned, 11 really needs to be there. And, they should be 12 sensitive to it.
13 CHAIR HALNON: Again, that's a Bob 14 position, opinion, it's not a committee position 15 unless we --
16 MEMBER MARTIN: But you have asked for and 17 I put a lot of work into it.
18 CHAIR HALNON: But I didn't necessarily 19 want to get into the level of detail that you're 20 getting into, relative to individual attributes of a 21 PRA, and hazard analysis.
22 I get your lessons learned, they're in 23 there somewhere and I think you just summarized them 24 well.
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27 PARTICIPANT: Right.
1 MEMBER MARTIN: Now obviously going 2
forward is that at some point, I think we need to talk 3
to the staff like we did with cliff edge, and hazards.
4 Maybe early summer might be a good 5
timeframe where we can get something on the schedule.
6 Obviously, I've been gathering feedback. I got a 7
vision -- revision that largely influenced by Tom's 8
comments.
9 And then, I did have a PRA expert that I 10 worked with in Lynchburg, provide significant comment 11 on it, too.
12 CHAIR HALNON: Well, that adds another 13 dimension. Okay, we'll talk about how that paper can 14 get submitted to the agency.
15 MEMBER MARTIN: Well, to the rest of the 16 committee first, and --
17 CHAIR HALNON: Maybe not.
18 MEMBER MARTIN: Well, it's an email.
19 CHAIR HALNON: Sounds like it's a member 20 of the public type document at this point. So, we'll 21 talk later.
22 I'm not sure about the process. We'll get 23 our DFO and staff involved in how we do that to get 24 officially before the committee, or whoever needs 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
28 look at it.
1 But if you can talk about the cliff edge 2
effect, hazard --
3 (Simultaneous speaking.)
4 MEMBER MARTIN: Hazard --
5 CHAIR HALNON: -- cliff edge analysis --
6 MEMBER MARTIN: And then overall --
7 CHAIR HALNON: The current one is this 8
PRA, use of PRA in LMP, and for --
9 (Simultaneous speaking.)
10 MEMBER MARTIN: Or really just in this 11 space of overall.
12 CHAIR HALNON: Okay, so I think we got 13 that. Dave, from a lessons learned perspective, you 14 get, you understand where his head's at, right?
15 VICE CHAIR PETTI: I'm not sure I agree.
16 CHAIR HALNON: Well, that's not for to 17 agree. The committee will discuss --
18 (Simultaneous speaking.)
19 VICE CHAIR PETTI: Right.
20 CHAIR HALNON: -- that, but.
21 MEMBER ROBERTS: Let me offer this for 22 reflection. I think there is two discrete subjects 23 we're talking about here, and try to keep that in 24 mind.
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29 One is from a lessons learned perspective, 1
the defense line and the approach has the potential as 2
Dave said, to cover the kinds of completeness and 3
uncertainty questions that Bob's been raising.
4 And if you've got enough lines of defense, 5
it doesn't really matter if you haven't covered the 6
scenario, because you've got multiple ways of dealing 7
with that scenario.
8 So, that's not fully developed yet though.
9 We haven't reviewed the very comprehensive report from 10 GE or the BWRX-300 safety strategy.
11 And when we have that discussion, I think 12 we'll better refine what we think might be gaps there, 13 or whether it is complete.
14 It has the potential of being complete.
15 I think that's in Dave's draft letter.
16 The second one is follow up on the May 17 subcommittee meeting we had last year. I think that's 18 a completely separate issue that warrants some more 19 discussion.
20 I really don't see that as tied with the 21 lessons learned at this point. That's just kind of a 22 long-term process improvement if there's something 23 that we think we interested about the staff on, that's 24 something we can follow up on.
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30 Because maybe that takes some, give us 1
some thoughts away from that meeting. And it's 2
probably worthwhile for us at some point, to follow up 3
with what have they done with it.
4 So, I think there's two paths there, and 5
one is not really being covered today and the other 6
one is. I think it's in Dave's draft letter.
7 So it might be something worth reviewing.
8 MEMBER MARTIN: So, and there's a 9
temptation with a lessons learned activity, to focus 10 on what we've seen. And, I try to take an approach of 11 focusing on what we haven't seen.
12 And, knowing that it's early, but the 13 value of a letter like this is also to communicate 14 expectations moving forward. Not just to say we've 15 seen it, we generally like what we see.
16 But we need to say something more like 17 well, moving forward, and you did. You did 18 acknowledge they're pushing stuff to OL.
19 And maybe just put a little bit more in 20 there, and that's all I was offering a couple things 21 in this just overall plant risk space.
22 VICE CHAIR PETTI: My concern is we 23 haven't, well, we have seen a COL, but we've only seen 24 one. And mostly we've seen, we're seeing CPs. So, 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
31 is this mixed bag.
1 Yes, if we'd had a couple more OLs and 2
COLs, it would probably be a slightly different letter 3
than it is at this point.
4 CHAIR HALNON: Yes, right. I think the 5
lessons we're going to get from the OL is a compressed 6
timeframe and the overall amount of information will 7
be a whole different -- a fluid discussion.
8 VICE CHAIR PETTI: And I'd really like to 9
get to the letters. Craig, any?
10 MEMBER HARRINGTON: Just very briefly.
11 Like Scott, don't have a lot to compare to. Haven't 12 been on the committee long enough.
13 But a couple key things that one Walt 14 mentioned yesterday. Some of the TRs really more in 15 the TR space and I think at this point, the things 16 that I've seen have some designs with principle design 17 criteria where they've made changes from what's been 18 offered as examples in Reg Guides or others.
19 And really don't provide justification, 20 just here it is. And, those kinds of cases with no 21 justification frustrate me.
22 And the other thing that I'll highlight 23 and then turn it back to you, Dave, is we're in a very 24 dynamic environment now with a wide range of designs 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 coming through.
1 Varying levels of detail. There's several 2
different licensing approaches that are available, and 3
are being taken.
4 We have all of the changes from schedule 5
pressures and other issues. So, we have to be very 6
flexible in what we see, and how we react to it. And 7
finding new ways to work with what we get.
8 I'll stop there.
9 CHAIR HALNON: Thanks. Do you have any?
10 PARTICIPANT: I think everything is good.
11 CHAIR HALNON: Okay.
12 VICE CHAIR PETTI: Annie, you've only been 13 here --
14 (Laughter.)
15 MEMBER KAMMERER: Yes, this is my second 16 meeting.
17 VICE CHAIR PETTI: Yes.
18 MEMBER KAMMERER: But I do have a lot of 19 experience with the ACRS from the staff side, over the 20 course of 7 years.
21 And I will say that something I see 22 already is that yes, it's a very dynamic environment.
23 It's a new environment.
24 But I feel like, of course I wasn't, I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 didn't have the opportunity to see behind the curtain 1
before.
2 But I do feel like that the way the ACRS 3
operates now from what I have -- know, is it's much 4
more structured in a lot of ways.
5 And I think that the effort that has gone 6
on to focus the activities, and how to think about 7
what the kind of questions that are going to be asked, 8
and the kinds of things that are going to be looked 9
at, is really different.
10 Now I was gone for 10 years and I have to 11 commend the Committee and the staff, for the level of 12 effort that's been put in to really bring, it's not 13 possible in this dynamic environment, a lot of clarity 14 on exactly what the Committee is here for. What it 15
- does, and while still meeting the statutory 16 requirements of the Committee.
17 So, I just commend all for the efforts and 18 things like this lessons learned letter, I think is 19 really important for continuing to develop that 20 framework, and that process, and that understanding.
21 VICE CHAIR PETTI: Thanks for that 22 perspective, that's nice. That's good to hear.
23 That's my sense. I can remember presenting to the 24 ACRS.
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34 MEMBER KAMMERER: It was frightening.
1 VICE CHAIR PETTI: Well, that's what 2
everyone had me scared to death about, yes. And, I 3
survived. But thinking I'd be on the other side one 4
day, so. Okay, so with that, I think we can dismiss 5
the court reporter, right? Do I have to do anything 6
with that?
7 MR. BURKHART: Yes, I think the Chairman, 8
this is Larry Burkhart. I believe the Chairman might 9
take public comments.
10 VICE CHAIR PETTI: Oh, that's right.
11 CHAIR HALNON: Yes, so before we release 12 Allegra, we'll take public comments. I'm going to 13 open up the lines for public comment.
14 If you have a public comment, please raise 15 your hand, or we mentioned *5 over the phone. That 16 would raise your hand. Is there anyone from the 17 public that would like to make a comment? Okay seeing 18 none, hearing none, we'll go ahead and close public 19 comment period and Court Reporter Allegra, you are 20 released for the remainder of this meeting. Thank 21 you.
22 Dave, back to you.
23 (Whereupon, the above-entitled matter went 24 off the record at 9:06 a.m.)
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35 C E R T I F I C A T E 1
This is to certify that the foregoing transcript was 2
duly recorded and accurately transcribed under my 3
direction; further, that said transcript is a true and 4
accurate record of the proceedings; and that I am 5
neither counsel for, related to, nor employed by any 6
of the parties to this action in which this matter was 7
taken; and further that I am not a relative nor an 8
employee of any of the parties nor counsel employed by 9
the parties, and I am not financially or otherwise 10 interested in the outcome of the action.
11 12 13 14 15 16 17 Court Reporter 18 19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com