ML22140A232

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ML22140A232
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Issue date:	03/10/2022
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UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

+ + + + +

34TH REGULATORY INFORMATION CONFERENCE (RIC)

+ + + + +

TECHNICAL SESSION - TH25

PRACTICAL EXPERIENCE IN EXECUTING A 10 CFR PART 52

COMBINED LICENSE FOR VOGTLE UNITS 3 AND 4

+ + + + +

THURSDAY,

MARCH 10, 2022

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The Technical Session met via Video-

Teleconference, at 8:30 a.m. EST, Omar

Lopez-Santiago, Deputy Director, Division of

Construction Oversight, Nuclear Regulatory

Commission, presiding.

PRESENT:

OMAR LOPEZ-SANTIAGO, Deputy Director, Division of

Construction Oversight, RII/NRC

ZACH HARPER, Manager, Plant Licensing Engineering,

Westinghouse Electric Company, LLC

AMY CHAMBERLAIN, Nuclear Development Regulatory

Affairs, Southern Nuclear Operating Company NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 2

NICOLE COOVERT, Chief, Construction Inspection

Branch I, Division of Construction Oversight,

RII/NRC

VICTOR HALL, Chief, Vogtle Licensing & ITAAC

Branch, Vogtle Project Office, NRR/NRC

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 3

P R O C E E D I N G S

(8:30 a.m.)

MR. LOPEZ-SANTIAGO: Good day and welcome

to the third day of the 2022 Regulatory Information

Conference, or the RIC. This morning, we're going to

have a great panel of discussion about our experience

executing the first Part 52 Combined License for

Vogtle Units 3 and 4.

My name is Omar Lopez-Santiago. And I'm

the Deputy Director for the Division of Construction

Oversight in our Region II Office in Atlanta,

Georgia.

I'm going to be the Chair for today's

panel discussion. This is a busy time for Vogtle and

all of us as we work together to ensure that the first

new powerplants built in this country in over ten

years are safe.

We meet today, we have the following

panelists: first, Zachary Harper. Zach is the

Manager of Westinghouse Plant Licensing Engineering

team and his group is responsible for Westinghouse

Licensing Activities related to new plant builds.

Next we have Amy Chamberlain. Amy is the

Nuclear Development Regulatory Affairs Manager for

Southern Nuclear. In this role, Amy supports Vogtle NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 4

3 and 4 construction licensing needs.

Next we have Nicole Coovert. Nicole is

the Branch Chief of the Construction Inspection

Branch 1 in DCO in the same division I work for and

Nicole is responsible for managing the construction

inspection program of Vogtle's Units 3 and 4.

And last but not least, Victor Hall. Vic

is the Branch Chief of the Vogtle Project Office at

the Office of Nuclear Regulatory Regulations. Sorry,

Nuclear Reactor Regulations, NRR and he's responsible

for licensing and overseeing the construction of

Vogtle 3 and 4.

In today's panel, we're going to be

discussing the following topics: We're going to be

talking about licensing, ITAAC and you are going to

hear that word a lot, ITAAC means Inspections Tests

Analysis and Acceptance Criteria.

The construction inspection program and

applying lessons that we have learned throughout this

process to future applications. As a reminder, this

is a panel discussion so we encourage everybody, the

audience, to ask questions to the panelists and

please use the chat function in the application.

So as an introduction and a start to

kicking off the panel discussion, please Vic, tell us NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 5

a little bit about your work with Part 52.

MR. HALL: Thanks Omar. And welcome to

everyone to the Regulatory Information Conference.

So in Part 52, I won the Part 52 lottery and it's the

jackpot because I have the best job in the world.

What I mean by that is the work that we

get to do is so unique and so important to the country

that again I feel incredibly blessed and lucky to do

what I do.

So I'm the Branch Chief of the Vogtle

Project Office in the Office of Nuclear Reactor

Regulation. I love our tag line. In NRR, it's we

make the safe use of nuclear technology possible.

And as you might have gleaned from the

name Vogtle Project Office, we do that very

specifically for the Vogtle Construction Project

which is as Omar mentioned, the first nuclear

construction project in this country in over 30

years.

So this is going to sound really corny.

I want to apologize, but it's like 8:30 in the morning

here in D.C. and I'm the king of bad jokes, but what

we do in the office is kind of magic. It's making

safety from nothing.

As a regulator, you know, we don't make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 6

a single pump or a valve, we don't design anything,

we leave that to Zach and the good folks at

Westinghouse. We don't build the plant, we leave

that to Amy and the fine folks at Southern.

But what Nicole and I get to do is from

paper. We help create the rules, we inspect, we do,

you know, we don't create anything, but we make

safety.

We're able to create the plant, make the

plant safe through our regulatory structure through

our licensing and through our oversight which we do

at VPO.

And that's kind of a cool thing when you

think about it, it's an influential pursuit of making

something safe without actually touching it. And so

it's a kind of a unique thing. And it takes

incredibly talented folks to do that.

There's a skill, there is a special

knowledge that goes into being a regulator and making

that happen. And that's where I feel perfectly lucky

because I'm working with the folks in the Vogtle

project office who are just really good at what they

do.

We have, there are 11 of us, we are

engineers, project managers, who have since the very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 7

beginning of Part 52 worked on this unique process to

make and make the plant safe. Part 52 is kind of a

unique beast.

It's the first time we're ever going

through this process. If you've heard me talk about

Part 50 in the past, you know, it was derived from

the FCC's regulations on building communications

tower.

There was a separate construction permit

for building them and then operating them. So, you

know, you're talking about 1950s type regulatory

structure. And Part 52 which is born in the 1990s

was meant to standardize plants, bring some stability

to the very first structure, and you know, we now

have 20 years' experience of design certifications,

combined licenses and a lot of lessons learned from

that.

And we're in the first kind of stages of

this overseeing construction to the very end which is

really exciting in getting to see all of that come

together.

So in terms of Part 52, my experience is

the last four years working with incredible people

who have incredible experience and getting a chance

to see this plant come out of the ground and be done NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 8

safely.

MR. LOPEZ-SANTIAGO: Okay, great.

Nicole, what about you?

MS. COOVERT: Good morning. As Omar said,

I am, my name is Nicole Coovert. I am the Branch

Chief in the Division of Construction Oversight in

the DCO Region II Office. And I would echo Vic Hall

that the folks that I have the pleasure and

opportunity to work with every day are just

incredible inspectors with skill sets that go across

many different disciplines and experiences.

And when I say inspectors, it's Region II

inspectors. All of us are involved in the Vogtle

project and performing inspections. So it's part of

our mission. We regulate and provide inspection

oversight.

Other construction activities for the

Vogtle Unit 3 and 4 sites that's located in

Waynesboro, Georgia. And this is to provide

reasonable assurance of adequate protection for

public health and safety to promote common defense

and security and to protect the environment.

The Division of Construction Oversight

also implements the inspection program which includes

resident and regional inspectors with the support NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 9

from headquarters technical experts as Vic Hall was

referring to.

And what keeps us busy, very busy, is the

planning, scheduling and completing of three

different types of inspections which are construction

inspections, initial test programs, and operational

program inspections.

The resident and regional inspectors at

Vogtle exert significant time and resources to verify

that the licensee's construction and completion of

inspections, tests, analyses, and acceptance criteria

deserve more say and we'll say that a lot today, is

what we call ITAAC.

As part of the new reactor licensing

process for the licensee of Part 52, a combined

license enables the licensee to construct a plant and

operate it once construction is complete.

And if certain design-specific pre-

approved sets of performance standards, or ITAAC,

identified in a combined license are satisfied. So

essentially, the ITAAC or necessary information, that

when successfully completed by the licensee, provide

reasonable assurance that the facility has been

constructed and will operate in accordance with the

combined license, the provisions of the Atomic Energy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 10

Act of 1954 as Amended and the NRC's rules and

regulations.

So through licensing and inspection

activities, when the NRC makes that determination

that all ITAAC is satisfied, the NRC would authorize

licensee to load fuel, initial plant startup, an

operation which we also commonly call and refer to as

the 52-103G finding.

MR. LOPEZ-SANTIAGO: Thank you, Nicole.

Amy, your turn.

MS. CHAMBERLAIN: Sure. I'm Amy

Chamberlain. I'm the Nuclear Development Licensing

Manager for Southern Nuclear. And I have actually

spent most of my career working in Part 52.

The last eight years I've been here with

Southern working to build the Vogtle 3 and 4 plants

in Augusta, Georgia. My team is based out of our

Birmingham office so we are responsible for license

amendments, exemption requests, alternatives, and

really being the forward-looking organization to take

some of that work off of the folks at the site.

And so for the last eight years we've

been working very closely with Westinghouse and

Zach's team to process these license amendments and

various changes to our license.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 11

So but before I came to Southern, I also

have worked in other Part 52 applications and pre-

applications. So I've seen Vogtle 3 and 4 actually

get constructed and getting really, really close to

coming aligned.

It's really personally for me something

I wanted to see for our industry. So I'm really

excited, like you said, it's a very busy time at the

site. And we're working hard to get those ITAAC

closed. So that's my role for Part 52.

MR. LOPEZ-SANTIAGO: Thank you, Amy.

Zach, what about you?

MR. HARPER: Good morning, everyone. My

name is Zach Harper. I'm the Manager of Licensing

Engineering here at Westinghouse. I have about 12

years of experience working in Part 52.

I started when we were still developing

the design certification document. And my experience

there was primarily working in the ISG 11 process

which now is in RG 1.206 and supporting the ACRS

meetings and the various chapters, the responses to

the NRC's Request for Information.

I also supported the different license

applications for AP1000 and as well as I've also

supported some international efforts in China, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 12

supporting their licensing process as well.

Since the design certification timeframe,

I've been supporting Amy and her team to develop

inputs to their license permit amendment requests and

the Tier 2 departures, that are written under the

Section 8(b)(5)(B) criteria as well as supporting the

site teams with ITAAC closure via engineering inputs.

I have a pretty unique job where I get to

sit between the Westinghouse engineering team that

defines the requirements and specifies the design for

the plant.

I also work with the construction

engineers on site to make sure that, you know, we

understand their needs and how, what we can do within

the bounds of license to make their job easier and

more efficient.

And then working with the team, the ITAAC

team there on site to understand where they're

struggling or in need of changes or clarification on

requirements or what design inputs they need for

ITAAC closure.

I'm excited to be with you today. I look

forward to the questions that we can answer.

MR. LOPEZ-SANTIAGO: Thank you,

everybody. So let's start with licensing. And this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 13

question is for Amy. Amy, from your license

perspective, what do you perceive to be the greatest

benefit to executing a Part 52 combined operating

license?

MS. CHAMBERLAIN: So I would say it's two

parts and they're kind of intertwined, certainty and

finality. So those, so certainty and what has been

designed has been licensed and constructed in the

Part 52 process.

We're required to construct in accordance

with our license and I will say during construction,

this always, this hasn't always been a benefit and it

sometimes has been a challenge, but I personally

believe that when we become operational, we'll have

certainty in our licensing basis through the work

that we have done as a licensee through the various

processes including ITAAC.

And finality plays into that certainty.

We have, the DCD has finality and that through the

process has gained a certainty in the construction

process also. I don't know, Zach, you want to chime

in on finality and the DCD?

MR. HARPER: Yes, I think that that's

really one of the key advantages of, you know, the

Part 52 process where you get that finality and you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 14

get those safety issues identified and resolved up

front in the process and resolved.

And then through the COL application that

designs application process, that design has finality

and that goes up through the start of the plant.

I would say that, you know, just to jump

off of the question that you have, another key benefit

of the Part 52 process is standardization.

You know, for me, I perceive, you know,

the Part 52 process, you know, the key advantages is

standardization, design finality, resolving those key

issues up front prior to construction.

So for, you know, the key success for, of

a new nuclear build, you know, standardized design

developed through a standard procurement and

construction process and is licensed in a standard

approach and it's perhaps the most salient lesson

learned from, you know, the 1980s of their nuclear

builds.

And it was recognized through the

development of the Utility Requirements Document, the

URD and the promulgation of the Part 52 and allowing

that standardization and the finality of it really

gives a designer and a licensee the confidence to

know that once that plant is constructed that it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 15

going to start up and operate.

MR. LOPEZ-SANTIAGO: Okay. Vic, this

question is for you. How has the NRC managed to cut

license amendment review times in half compared to

the review times for the operating fleet? Can you

apply that for all licensing work done by the NRC?

MR. HALL: Thanks, Omar. So I'm going to

give a little background and context. Because as Amy

mentioned, there have been a fair number of licensing

actions since the combined licensing from 2012.

We have, the NRC has issued and posted

just over 200 licensing actions which includes

license amendments, examinations and code

alternatives and the last four years really since the

formation of office bubble project office and another

group we'll talk about called the Vogtle Readiness

Group, the VRG.

We managed to keep our review time around

six months which is about half of the standard time

for a, I'll call it a routine licensing action inside

the Agency and the most important thing is we've done

it with the same come and high rigorous standard of

safety.

So there, you know, it's not like we're

just doing them quicker. It's still, it's a matter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 16

of being finding efficiencies and doing things kind

of to the pace it's required for construction

because, you know, what's different about Vogtle

obviously to the rest of the fleet is they're building

a plant and there's a need to change the license as

things come up as construction is showing that the

plant designs will be a little bit different than

what we originally anticipated.

So how we've gotten there, you know, the

first thing is we have amazing people working on this.

The Project Managers that we have on our team are

extremely experienced in Part 52 and new reactors.

They're problem solvers. And so they

know their craft. And then again, it is a craft to

be an NRC Project Manager that knows the regulation,

that understands the engineering side of it and can

bring those two together towards safety.

So we have amazing people that work on

this who are currently motivated. And really I'm

going to say a huge tip of the hat to communications

that we've done for this project.

I mentioned the Vogtle Readiness Group.

It's kind of, we took our lessons learned from the

watts bar reactivation and built this, I'll call it

a team.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 17

But really it was still our independent

parts of our agency working together and just

communicating nonstop. We've had, I think 40

different VRG meetings in the last four years.

And it's really just bringing together

different parts of the Agency. The Vogtle project

office chairs part of it, Nicole's group and Omar,

your group obviously in the did the new construction

oversight and Region II chair it.

And we have other support from NRR. And

we bring together all the different parts of the

agency. We bring together our tech groups. We bring

together our legal side.

We bring together our security folks, our

IP folks and we have discussions about what's coming,

and how we can solve the problems in front of us. So

that's internally. Externally, we've been meeting

with the licensee and with all our stakeholders very

frequently to make sure that we see problems, or see

the questions that are coming up ahead of time and

set ourselves up for success.

We set up a cadence of weekly public

meetings for licensing actions. You know, our teams

are probably going to be required to face off, you

know, having close to 10 to 12 licensing actions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 18

inhouse at a time. Right?

And so those weekly meetings were really

key for us to be able to talk about the issues that

were in front of us and talk about the challenges.

A lot of pre-application engagement so

those meetings were fantastic to be able to get a

feel for what was coming. And quite frankly, again,

it's been thanks to those types of communications

that the qual of the applications that have come in

from Southern had a good and put a lot of state to

complete our views in shorter times.

So I think it's been just communications,

communications, communications that they've really

allowed us to move at a faster pace than typical.

If you guys are fair for me, Omar, to say

the rest of the Agency should just communicate and

yes, fix it all. It's a completely different set of

challenges and different scale that we've been

working on, but I do, I am very proud of the work

that we have done at the Agency in licensing.

I do think there are lots of really good

lessons learned. We'll talk about lessons learned,

there's lots of positives we can draw from the work

we've done on licensing and again help build our

efficiency in that place as we go forward.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 19

MS. CHAMBERLAIN: I --

MR. LOPEZ-SANTIAGO: Okay, thank you. Go

ahead, Amy.

MS. CHAMBERLAIN: Yes, if I could just

jump off of that. I, you know, the communications

have been key, but it's been kind of specific and one

of the things we did a number of years back was talk,

work with NRC to define what we say are high, low and

medium complexity bars.

So we knew, Zach and I knew going in what

bars we thought were high complexity just based on

the amount of engineering work involved or the

internal churn on creating the arguments of why we

needed the license amendment.

And so extending that, those lessons

learned that we have learned internally between our

two organizations and opening up that line of

communication with the NRC, so that we were

communicating, hey, this one's coming in, this

licensing action is coming in and we think it's medium

complexity because of X, Y and Z.

It really helped the staff prepare for

those pre-application meetings so that they had the

right folks in the room for those meetings. And then,

down the road they could plan, okay, this one is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 20

very high complex bar.

We are most likely going to need an audit

of this work and we would have all of that planned in

advance before we even submitted the licensing

action.

So I think that was key, but then also on

the other end because, you know, we're nuclear. We're

always learning, we're always trying to get to

excellence. We took a lot of feedback from the early

days as submitting these licensing actions and really

worked them in to submittals.

Each time we learned, we learned

something that hey, we expect the staff to ask this

question and so making sure we had it up front in the

signals and one interesting thing I love data.

And you could see from our submittals if

you look in ADAMS at the number of RAIs. They really

decrease over time as we got better with that

communication.

So and as Vic said, just because I like

numbers, we actually have somewhere around 15

exemptions and alternatives today. And we're

currently on amendment 188 for Unit 3 and 186 for

Unit 4.

MR. LOPEZ-SANTIAGO: Okay, we got a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 21

question for Vic. Vic, why are many advanced reactors

designers not taking advantage of Part 52 and instead

opting for Part 50?

MR. HALL: Yes, great question. And I

listened in to some of, I think it was Tuesday's

session on advance reactors. And heard, I think it

was the folks at X-energy talking about looking at

using Part 50. You know, my guess, again, this is a

guess because I think we're kind of focused on the

back end construction, but if you look at going way

back to what it takes to get a certified design and

a COL, I imagine there's some calculations that go

back to how much it's going to cost for that delible

work so, you know, we're, the NRC is developing a

Part 53 which is going to be a technology neutral

framework which I know just about, you know, this

much about.

But that might be the future for advanced

and smaller reactors. I think Part 50 and Part 52

are still the standard for a large light water nuclear

reactor.

So if you're looking at a smaller plant,

small modular plant, you know, I don't know how to

tell enough to put together. So it's a fair question,

it's probably better directed at those designers who NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 22

are looking at advanced reactors.

And I think it's going to take into the

totality of the process. At the very beginning, if

you look back at Zach when you start, when Zach

initially submitted the D.C. for Westinghouse, we're

talking gosh, 2000, I'm going to mess up my math here,

2002 timeframe is when you first applied I think for

the D.C. AP1000.

So you're looking at a long stem between

that and where we are now. I think the some shows

going through it.

MR. LOPEZ-SANTIAGO: Okay. So let's move

on to ITAAC for a little bit and then we might go

back. We might come back to licensing. So Nicole,

what preparation was required for complex ITAAC such

as structural reconciliation, the ASME ITAACs or

long-lead items?

How has the NRC been inspecting ITAAC and

how does that relate to the 103G finding?

MS. COOVERT: Oh, thanks, Omar. Well,

first of all, you know, complex long-lead ITAAC, you

know, as you said, one of the examples is the ASME

related systems like reactor coolant system or the

passive core cooling system.

You know, for our inspections, we verify NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 23

that the systems were designed, constructed,

fabricated, installed, and tested to the required

codes and standards.

For these long lead ITAACs, the NRC has

been inspecting these activities since the beginning

of the construction projects and as we're approaching

Unit 3 all ITAAC complete milestone, we actually had

relatively minimal inspections remaining compared to

the amount of inspections that we've already

completed.

So to give you understanding of our

inspection process for these complex ITAAC, so early

on in the construction project, the NRC performed

vendor inspections and observed the initial

fabrication and construction in our key AP1000

components all over the world.

A couple of examples is the inspected

major reactor coolant system components and

containment fabrication in Japan, Korea, Italy. We

have our inspectors out there at these facilities

performing those inspections.

We inspected safety related, key

electrical component fabrication in Switzerland. We

also went to the Wyle Labs (inaudible) in the United

States to observe squib value testing and we observed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 24

fabrication of modules, mechanical skids, ASME system

piping assemblies, at multiple different vendors.

So following that, the NRC will also

perform multiple design specification inspections at

the design authority, Westinghouse.

And Zach was present for I would say most

of those inspections in the corporate office. And

this was to verify that the design of this key AP1000

component system structures would meet the acceptance

criteria and that the design ensured that the most

probable transients, the most probable occurrences

that would occur during normal operation and

operational transients would have least radiological

risk and those with extreme situations have the

potential for the greatest risk are the least likely

to occur.

And essentially, that is the licensees

accident analyses that is described in their Updated

Final Safety Analysis Report. And from there, the

NRC inspection staff who performed installation

inspections at the Vogtle site will verify that the

license was constructed, welded and performed non-

destructive testing for ASME systems, in accordance

with applicable code.

You know, other inspection attributes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 25

included verifying welder welders were qualified,

construction activities were reviewed and approved by

authorized nuclear inspectors as required and then

our final aspect inspections verify that the as-built

conditions meet the design and if they don't how are

they reconciled.

These inspections, they include pre-

operational component and system testing like

verifying a flow rate or system functionality as

designed, or performing components or system

walkdowns to verify compliance with seismic,

equipment reliability in harsh environments like high

pressure, temperature, moisture such that the

component/system would perform its intended function

during a design basis accident.

So to better inform and prepare our

inspectors for these tests, including start-up

testing, the NRC and the Chinese regulator, National

Nuclear Security Association, or NNSA, participated

in an inspector exchange program that lasted several

years and allowed approximately 18 NRC inspectors to

travel to China to Sanmen nuclear power plants and

witness first hand some of these activities.

Additionally we were able to engage with

Southern Nuclear and Westinghouse staff at Sanmen and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 26

that helped us to get an understanding of the

differences or the changes that we would see in the

U.S. AP1000 plants.

So definitely, as I describe it, it's a

very complicated for these long-lead inspection

program for some of these ITAAC and it's happened

over the years.

And so as Amy had said and Vic had said,

one of the most important key lessons learned is to

communicate and communicate often. Some of these

other activities like the structural reconciliation

and that is to verify the seismic category Class 1

structures like a containment shield building.

You know, they didn't have the formal

structure, the documentation structure like ASME Code

does in the system N5s so we met with Zach and

Westinghouse and Southern Company years ago to

determine what those final documents would look like.

So all of these things are planned in

advance. So lessons learned is for complicated long-

lead activities whether it's non-ITAAC or ITAAC, it

is very important to understand what the end product

looks like so that you can plan it and be prepared

for those complicated issues. Thanks, Omar.

MR. LOPEZ-SANTIAGO: Thank you, Nicole.

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So this question is for Zach. Zach, do you have any

lessons learned about the easiness of it to inspect

ITAAC?

MR. HARPER: Yes. So I would just maybe

leverage a little bit off of Nicole's response. She

was talking about the lessons learned related to the

planning activities.

I think for us one of the key lessons in

terms of inspectibility for those long lead type

ITAAC or the ITAAC that we were having to perform

very early in the project, was we had, I would say an

area of struggle where Westinghouse did not

necessarily appreciate what a targeted ITAAC meant.

Where, you know, we would have activities

such as EQ or ASME and, you know, the NRC had

identified those to be inspected, but those

activities for example were already complete.

So you know, for us, you know, us thinking

okay, targeted ITAAC inspection, we will provide all

of the documentation at the end. I think one of the

lessons there for us was, okay, when they say target

it, we'll make sure that, you know, they're, we have

to plan that out, make sure that they're on site at

the vendor at Westinghouse.

Most of the remaining target ITAACs are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 28

on site so it's not as applicable right now, but when

we had first started, it was I would say taxing on

both Westinghouse and the NRC to make sure that to

catch up and identify, okay, how can we satisfy the

ITAAC and make sure that we had a good understanding

of what needs to be completed.

So I would say that was one lesson learned

for us. Another would be an area that for

inspectibility, where there's not a basis document

for an ITAAC, like what you would have for a tech

spec so we really never go back and forth on what

tech specs mean because there's a basis, there's

analyses that they describe exactly what the

intention of that tech spec is.

There's not for an ITAAC and so I think

the lesson for us was, okay, for ITAAC that, because

you, ITAAC really just have a very basic statement.

They have a design commitment test and

then an acceptance criteria and, in some cases, that

can be taken different ways. So I think clear

communication between Westinghouse and Southern and

Southern and the NRC on how that ITAAC will be

completed and the documentation that will be provided

as an important part of the inspectibilty for an

ITAAC.

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Another example would be during testing

such as hot functional testing where hot functional

testing is a very dynamic evolution where a lot of

tests are happening.

It's a very coordinated event where the

site, where the plant heats up, tests are performed,

and then the plant cools back down. So for us,

something that we had learned in China that we had

applied here in the U.S. was to establish predictive

analyses prior to that hot functional testing.

That way the, you know, when the test is

run, Westinghouse can do a quick post-test analysis,

confirm that the ITAAC, yes, the ITAAC can be met and

then move on to the next test.

And then the ITAAC paperwork can be

verified later. And then having a good understanding

between Westinghouse and Southern and if it's

targeted, the NRC up front will look at what we

planned to do.

But I think that's an area that I would

say was a success, is having that good plan

established, having those predictive analyses already

run that way we knew that we met the ITAAC whenever

we did our post-test analysis and we could just move

on to the next test and not have any delays.

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MR. LOPEZ-SANTIAGO: Thank you, Zach.

Amy, do you have anything to add?

MS. CHAMBERLAIN: Yes, I'll just echo

Nicole and Zach, you know, that, I mean, that

overcommunication especially with the dynamic

construction situation ensuring that the staff

inspectors have access to see what they need to see

to inspect is critical.

And then on the ITAAC language itself,

verbatim compliance, I'll just say a little less than

half of all the licensing actions we've submitted

were ITAAC related.

We need to make some sort of change so

that verbatim compliance, I think that's a lesson

learned. It was for us, we learned while we went,

but also for future applications, making sure that

you're very clear on that language so that it can be

inspected.

And then, you know, as Zach said, there's

no basis documents so there's certain words that you

would think we all understood what they meant, but

there's a lack of definition of them.

And so I would say that ensuring that

those specific words like as built were in your

licensing basis and your Tier I and your COL could NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 31

really help a future applicant so that everybody is

on the same page with ITAAC.

MR. LOPEZ-SANTIAGO: Thank you. So this

question is for Zach. And it's a little bit long so

I'm going to, bear with me here. So the China AP1000

project, even as a first of kind plant, were finished

in about eight years and have already been

operational for a few years.

But it is already more than 10 years for

the construction of Vogtle Units 3 and 4 which have

been delayed again and again. From your perspective,

what are the reasons for the delays for the Vogtle

project? Were any lessons learned from the China

AP1000 products used to help the Vogtle project?

MR. HARPER: Okay, all right. So I think

just as a little bit of background, so there are four

AP1000 plants that are operating safely in China.

China uses a Part 50 type process where

it's kind of like a modified type 50 process where

they have a PCR that's required to obtain a

construction permit for the AP1000 that have been in

around in the 2009 timeframe.

Then they construct and to load fuel they

submit an FSAR, a Final Safety Analysis Report, to

the China National Nuclear Safety Administration, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 32

NNSA, and then something that's a little bit

different than Part 50, they have something called an

RFSAR which is a Revised Safety Report which they

submit about a year after initial operation.

And the plants, the plants have been

operating safely in the United States for quite some,

or have been operating in China for a few years now

and they're performing very well.

The, in terms of a comparison between a,

this is really a comparison of a Part 50 to a Part 52

process, so I don't think that the delays either in

China or here in the U.S. were resolved of the

regulatory process. The regulatory process is

robust.

It can be trying at times no matter what

process you follow. I don't think we're necessarily

victims of a Part 52 process. I don't necessarily

agree with that part of the comment.

I think the, in terms of lessons learned,

yes, there were a lot of lessons learned that were

brought from the China projects to the U.S. Some

examples were for, you know, we for the first of a

kind testing where the design certification has a

subset of tests that were identified as being special

where they, where these tests are really there to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 33

demonstrate phenomena of the plant acting, make sure

that the phenomena of the plant is performing as

expected.

These are tests like natural circulation

tests. There's the in containment reflow and water

storage tank test, heat up test, so on and so forth.

So those tests were run in China and we

were able to demonstrate that the plants were the

same build in China as here in the U.S. And we were

able to successfully write license amendment requests

to take advantages of those tests and show that the

performance in the United States would be the same as

the performance here, or the performance in China.

So that was one example. Another example

or you know, detail design changes that are

identified since they're and it's the advantages of

standardization where it's a standard design.

They have the same plan, well, same

nuclear island in China as they do here. Their

turbine building is a little bit larger because of

the different standards, but you know, those design

changes we, as they are developed for China, they're

reviewed for applicability and if they're good

changes to be made, they roll right into the design

for the U.S. plants.

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So that's a very, it's an active process.

It's ongoing as the plants are built and constructed

there. So I think I'll pause there. If there's more

questions later, we can address more.

MR. LOPEZ-SANTIAGO: Okay, thank you,

Zach. We have a question for Amy. Amy, regarding

documentation of ITAAC, there was a lot of

preparation including table top and exercise on how

to close ITAAC.

Still it seems that closure

recommendation for the final ITAAC appears to have

encountered significant problem at the last moment

holding up the 103g finding. What went wrong and

what lessons are there for future Part 52 applicants?

MS. CHAMBERLAIN: So we've mentioned that

we've been working the close, as the comment

suggests, we're working to close ITAAC basically

since the beginning of the project.

And you know what we see in the ICN

submittals, are a list of reference to principle

closure documents. And at times, these can be a lot,

hundreds of documents that go in, that are referenced

in a single principle closure document.

And so for many of the ITAAC that are

left, there are significant portions of them that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 35

already completed. But as the comment mentions,

there is documentation that still needs to be

completed.

And we do hold ourselves to a very high

standard. We want to complete this plant in a safe

and quality way and so we've got to get the

documentation right.

And the documentation comes after

construction is complete so that's where you would

see so why we haven't submitted all of the ICNs for

Vogtle 3 and 4 at this point in time.

MR. LOPEZ-SANTIAGO: Okay, thank you. So

let's move on to the next section of Construction

Inspection. We have a question for Nicole.

So, Nicole, with so much construction

going on and with inspection progress being hampered

by the pandemic, how can you be sure that NRC has

inspected what needs to be inspected to ensure that

the plant is being built safely?

MS. COOVERT: Thank you, Omar. And that's

a very good question, a very valid question for our

inspection group and our program.

So during the COVID-19 pandemic, our

inspection program kept track with Southern Nuclear

company's construction activities and at the same NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 36

time, we specifically prioritized, you know, our

inspections to one, focus on the mission critical

activities, but also through high transmission times,

prioritize our inspector safety and the safety of the

plant workers that we interface with.

So during the entire pandemic, this did

not change. We, our residents continue to connect

daily with the key on-site activities, such as: the

plan of the day, and work activities, pre-job briefs.

We also use both remote and on-site means

to implement the construction program. With that

focus of the nearing the 52 103g finding so we can

talk through inspections remotely from possible, but

during times the high transmission we specifically

reserve the onsite inspection for those critical

mostly activities which included directly observing

first of a kind AP1000 testing and significant test

activities that are typically only performed during

once in a lifetime the plant.

So some of the examples that we were on

site that's been specifically saw face to face and

observed during our inspections was the Unit 3, the

reactor vessel and reactor coolant system hydrostatic

tests. We saw the Unit 3 hot functional testing, the

containment structural integrity test and integrated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 37

leak rate test for containment for both Units 3 and

4.

And we also had inspectors on site to

observe installation of safety related items that

become inaccessible once construction is complete or

when the plant is operating.

So for example, we were onsite observing

the rebar installation and concrete placement for the

Unit 4 seismic Cat 1 structures, our containment and

shield building.

But I will note that, you know, as I

discussed in the earlier section about these long

lead ITAAC, you know, we have done so many different

types of inspections over the years that, you know,

we have confidence in those activities that we've

inspected.

And when there are non-enforcement is

identified, then we build and inspect those as well.

But again, our inspections are not focused on one

specific activity, but we ensure that this mission

critical activities are observed. So hopefully that

answers your question. Thank you.

MR. LOPEZ-SANTIAGO: Thank you, Nicole.

Vic, what have you taken from the NRC's

transformation to be a risk-informed regulator for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 38

the construction inspection program?

MR. HALL: So and I don't mean to back us

any, Nicole had a good point. I want to key off of

it. I'll answer that question, but I'm, Nicole,

you're bringing back some really good memories of,

good relative memories of early on in the pandemic

and our discussions about how we keep our people safe

and, you know, what was going on at the site.

And I remember pretty early on, I think

Southern was one of the very first utilities to have

a massive testing facility outside of the plant.

And they were communicating their cases

so we were able to make a judgment call as to whether

it's safe for our folks. So you know, Nicole, we

sound like we're the same organization, but we

obviously have plenty of discussions and don't always

agree, but I've remember being incredibly impressed

with your side of the house when you're just making

sure our people were safe, but at the same time we're

also getting the job done to make sure that we're

looking at everything that we need to look at and

making sure our folks weren't in harm's way.

As far as transformation goes, Amy keyed

on data earlier on. And I like jumped, you probably

didn't notice it, but I like jumped on chair when she NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 39

did it because that has been to me, we're in the

information age, the biggest ability for us to think

differently about how we do what we do.

We developed a construction inspection

program, you know, over the course of a decade, with

an idea of how construction's going to play out in

the first of our Part 52.

And, of course, it's not going to be

exactly as you design it. Right? It's just there's

no working so we're not going to be able to design it

perfectly.

So being able to look back now at several

years of experience and using that data to look at

where we can be more efficient, where have we seen

enough of certain activities when it comes to looking

at ITAAC and really, you know, spend our time in the

right places has been for me, eye opening.

We build a dash board relatively early on

in the Vogtle project where we just gathered up

everything we could. I mean, what we build our time

for hours and what our cultural, what our specialties

were we were using and that was to me key and just

eye opening.

Plus, going down the regions and just,

hey guys, here's what we got data wise. You know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 40

where can we work together to adjust our inspection

program and what are you seeing as inspectors as the

key places to go.

So to me, transformation has been just

this wonderful use of data to be able to tailor our

program and be more efficient.

MR. LOPEZ-SANTIAGO: Thank you, Vic. We

have a question for Nicole. Nicole, can you explain

more specifically the remote inspections of ITAAC

versus completion on site? How does remote

inspection of ITAAC work?

MS. COOVERT: Okay, thank you, Omar. Well

essentially as the definition or of the acronym,

ITAAC, it's Inspection Tests, Analyses and Acceptance

Criteria, so those all have different functions and

abilities to inspect those areas.

So inspections can be done either onsite,

they can be done remotely, but definitely the testing

or the acceptance criteria and analysis is all prime

candidates for remote activity, remote inspections,

because as Amy said and Zach said, some of these

documents are thousands of pages.

And that's just one document that support

a closure of an ITAAC. So you know, there are

definitely opportunities to do remote inspections.

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We actually, before the pandemic, there

was, you know we had big team inspections. We would

have a one-week off-site inspection looking at this

documentation and then we would have on-site

inspections as well.

So that's no different than we did before

the pandemic. To handle the specific inspections

that we wanted to do during the pandemic to observe

testing or their inspection activity, then we would

be very deliberate that we'd send folks on site to

see those activities, we'd coordinate with the

licensee when this event was specifically going to

happen so there was no compromise to our inspection

program where we missed opportunities. We just did

it differently.

MR. LOPEZ-SANTIAGO: Thank you, Nicole.

Amy, from Southern's perspective, can you tell us

about the NRC's findings on cable separation?

MS. CHAMBERLAIN: Yes. So we take these

findings very seriously. We've taken corrective

actions in the instances of separation

nonconformances and we put measures in place to

present reoccurrence going forward as we complete

construction, remain focused on safety and quality as

our top priorities.

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MR. LOPEZ-SANTIAGO: Okay, thank you,

Amy. Now this question is for Zach. Zach, from a

design authority perspective, what are the key

processes you have implemented to ensure the

constructive plant aligns with the design and

licensing basis?

MR. HARPER: Yes, well this is a good

question. This is probably as far as to lessons

learned, this would probably be the number one. And

I think that so I guess a little bit of background.

When we had initially, you know when

Southern received their design or their construction

or their combined operating license in the 2012

timeframe, within I would say like one or two months,

we started to identify at site there were things being

implemented at the field that were not in alignment

with the license so we had, you know, paused to take

a close look.

And I think and at that point, we began

to implement changes within the Westinghouse process

to ensure that the design aligns with what's actually

constructed at the constructed plant.

So and we really haven't had significant

issues, you know, after those big changes were

implemented. And so what could we do, so what we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 43

really didn't have the benefit of any NEI 96-07,

Appendix D at that time, because it wasn't written,

it was written after our lessons?

The, what we, the primary thing is we

established a licensing basis review for every

document that was developed and you can imagine how

many documents that we create, we perform a licensing

basis and back determination to confirm that document

aligns with the applicable FSAR so the Vogtle FSAR

and the other licensing documents.

And there's, we developed a very robust

procedure qualification program for people that are

developing documentation, qualification program for

people that are identifying non-conformances at site

and reviewing those non-conformances and really a

culture shift to ensuring like what Amy had said

earlier verbatim compliance to the license and making

sure that we're meeting every word that is said.

We've done other things as well. We've

done compliance reviews. We've taken certain scopes

of work, we've picked, you know, the commodities

within the plant (inaudible) to check to make sure

that they're within the bounds of the license.

So what we did in terms of passing the

lessons learned, when we wrote NEI 9607 Appendix C, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 44

in Section I think 411, we added, you know, basically

a sentence, a few sentences in there that says during

the construction period, you know, you document your

basis for no impact of the license as you go along.

So that was kind of our attempt at passing

those lessons to others in the industry and it, you

know, I think it's important, you know, to pass those

and the other is really what I said before is the

verbatim compliance making sure that when we wrote

the design certification, it seemed like a good idea

at the time to write, you know, ambiguous statements

like generally or this is representative, but and

that was a good idea at the time because we thought,

oh this is going to give us wiggle room as we go

forward.

And as it turns out, it's really

difficult to inspect to that type of language and so

throughout the construction, a lot of the changes

that we actually made are not necessarily design

changes, they are changes to improve the clarity of

the license, to very clearly state what we are going

to do.

Because there's a lot of detail in there,

but even with that said, it was, you know, loading

that license with the variances that you're going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 45

take and, in some cases, getting NRC approval to do

that when we were required to was a very important

lesson for us.

And you know, those that work in

Westinghouse on the AP1000 it's really a culture.

Does what you're doing comply with a license? And

it's a question that, you know, our group receives a

lot of questions every day on that questioning

attitude, hey, can I do this, can I do that?

And when necessary, we get Amy's team

involved and to make sure that they're comfortable

with those decisions.

MR. LOPEZ-SANTIAGO: Okay, thank you,

Zach. And we have one more question for Vic and

Nicole. Okay, sorry, right. So would the NRC

establish a singular branch or office like DCO or VPO

during the construction of future SMR projects, small

modular reactor projects?

MR. HALL: So Nicole, you can jump in

too, but I hope so because I think the combination of

VPO and DCO has worked well. You know, as we start

putting a lot of lists together, I'm sure we'll do

the environmental scan to see what the future of the

power looks like and put together the right type of

organizations that combine the expertise whether it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 46

ITAAC or whether it's Part 50 based plant with the

inspection staff.

Again, I think that looking at the

success we've had really with the VRG gives Vogtle a

written script which brought together all different

parts of the Agency.

I thinks that's, you know, that's just

almost a common sense recommendation of how we put it

together so I think well have to wait and see out

there and I think we've just got to sort our

application scenarios right now.

And NuScale, has their certified design,

but I'm sure NRC managers will be looking very hard

at what's the right organizational structure for when

we're ready for construction inspection plans.

MS. COOVERT: And I can't agree with you

more, Vic, because, you know, one of the key lessons

learned and I know that's the next topic, but the

Vogtle readiness group really was a part as a

fantastic lessons learned from Watts Bar that we were

able to not only communicate inspection licensing

issues, but we were also looking at, you know, the

logistics so to speak or the budget or staffing of

all of these different activities so it's a very solid

structure on how to look at those different aspects NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 47

of an inspection program and oversight program.

And we, the one note I would say is that,

you know, whatever the organization looks like, we

have in this panel we have a senior manager nuclear

from the NRC, Mr. Omar Lopez.

He is our champion for the small modular

reactor program so I know that we will get the DCO,

the Division of Construction Oversight lessons

learned into what that project looks like in the

future.

MR. LOPEZ-SANTIAGO: Thank you very much.

Before we move on to the next section, there's a

question here, Nicole, for you. How would ITAAC work

if the majority of the advance reactors would be

manufactured off site and would start with minimal

on-site construction?

MS. COOVERT: So that's a great question.

And that goes, that model is exactly what we did for

the AP1000 that the vendor inspectors which went to

facilities all over the world were key inspection

attributes for completing ITAAC.

So whether it's done on site, it's done

in a fabrication shop, all of them are verified to

have the nuclear standards for appropriate quality

assurance program and they're inspected with all of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 48

the rigor that an on-site inspection would perform as

well. So it would be the same model.

MR. HALL: And Nicole, you're bringing

back good memories. And before I used to wear ties,

I wore a Polo shirt and hardhat, and I remember I got

a chance with the vendor inspection staff to travel

to Korea.

We watched the pouring of the ignot unit,

that piece just lump of metal that eventually formed

the reactor vessel and so we have inspectors who are

able to go all over the world and inspect these

vendors that are building plants.

I do think that we will have to think a

little differently about other plants. I mean, it's

going to be a different model versus, it's likely to

be a different model versus these large construction

sites on site so, you know, I have something we're

looking at too and I think we'll have to be times in

a changing world and how we can best adapt to that.

MS. COOVERT: Yes, I absolutely agree

with you, Vic. And we have other types of facilities

like the field facilities, you know, that we can

leverage lessons learned from multiple business

lines, not just construction reactors or operating

reactor business lines.

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MR. HALL: Good.

MR. LOPEZ-SANTIAGO: One more question

for Nicole. Nicole, has the NRC considered

incorporating regulatory office site guidelines to

supplement the reactor off-site process and then

begin termination process to help to remove ITAAC

from some other nonsignificant interest?

MS. COOVERT: Okay. That's, I will, I

want to call my friend, Mr. Vic Hall, because what we

do is for both the inspection process and the

oversight, the program office, we are continuously

reviewing our procedures, our manual chapters to

ensure that they're not only risk informed, but when

we come across lessons learned, that we are

absolutely discussing them, how do we incorporate

them, real time.

So we're not waiting for the next project

to make changes to inspection program. Vic, anything

else you want to add to that?

MR. HALL: Yes, I'm sure we'll talk about

this a little bit more. We talked to this concern,

but we are a learning organization that's always

looking to get better.

You know as I heard Amy and Zach talking

earlier about the compliance versus safety, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 50

again, an ITAAC war story here, and you know, I think

we're painting a picture of everything being rosy,

but not everything has worked perfectly.

And one of my least favorite ITAAC

stories was I got a call, Amy, or from one of your

colleagues was working on ITAAC, said Hey, we got

there's an ITAAC, this was very specific because we

need to test our tanks of water.

And to test them, you can either fill

them with nitrogen because the ITAAC very

specifically says test them by filling with nitrogen

air.

Now they said that, because in what

plants operate to fill with nitrogen, 100 percent

nitrogen, but to test them, you could use anything.

You could use any kind of gas. It would not change

the flow with the acceptance criteria.

And the question is well, can we just use

air which actually is 70 something percent something

nitrogen anyway. And you know, it was a tough call

and legally, the language of the law of compliance

said now it's got to be nitrogen.

You know, we would be relatively easy

license now, but you're talking about time to do that.

And in the construction environment, that's just not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 51

a realistic so I know the folks at Southern had to go

find tanks of nitrogen because to fill this reactor

full of nitrogen to comply with the letter of the law

for the ITAAC language.

And that was a shame. To me that was

okay, a good lesson that could be learned there. What

we really should be focusing on safety versus just

the compliance. Again, if someone did the right

thing, we were you know, it was the letter of the

law.

It was Tier I information so it was

relatively unbendable, but it pointed to again,

certainly if you look forward to writing ITAAC

language, to be more realistic and just to get a

takeaway learned from the last year of construction,

I think we can make improvements.

And so along those lines, you know, I

think we're always looking to improve our guidelines

for the reactor process for the significant

determination process.

So we're always looking to improve and

looking for feedback there as well.

MR. LOPEZ-SANTIAGO: Okay, thank you,

Vic. Let's go to the last section. Applying lessons

learned to an advanced reactor and future NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 52

applications. This question is for Amy. Amy, what

should the NRC do differently if when we have another

reactor construction project?

MS. CHAMBERLAIN: Differently? I think

we have to look at what we've done, well in this, in

what we've done for three and four. I mean, the

communication, the VRGs we've already mentioned

those.

Those are the key features that need to

keep those communication lines open with the NRC. I

know when I first came on about eight years ago, there

were some lines open, but maybe they are not anything

like what we have today that we've built and we've

added to over time. So I think those would, the key

features to keep moving forward we kind of touched

along the CROP, the inspection process.

I think there's further opportunity for

that are informed. That process and then I think we

have more lessons we are going to learn as we come,

as three and four comes online.

A particular focus for me is how is Tier

I going to affect us as we are operating? So those

would be key things I think, lessons learned, things

that the NRC should consider going forward.

MR. LOPEZ-SANTIAGO: Anything from you, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 53

Zach?

MR. HARPER: Well I agree with Amy. I

think that a lot the struggles and towards the

beginning of the project they have since been

resolved with really good communication.

And I think that, you know, carrying that

and they've been implemented it's like, so I think

that the process that we have now, today and with the

open lines of communication with the headquarters

organization and with Region II, the onsite

inspectors I think that is what really needs to be

taken forward.

MR. LOPEZ-SANTIAGO: Thank you. This

question is for Vic and Nicole. What advice would

you give your NRC colleague who are building a

construction inspection program for advanced

reactors?

MR. HALL: You went first, is it okay, if

I start this one first?

MS. COOVERT: Go ahead, Vic.

MR. HALL: I just volunteer. Sorry. No,

that's a great question. Everyone's obviously

interested in what's going to happen with advance

reactors.

I know that some motions use a director NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 54

in venue and they are working on what is a pretty

fascinating and very interesting framework for Part

53. Which was meant to take us forward for advance

reactors.

You know, from what I've seen from them,

it's been again, just really, really cool work and

it's Vogtle's right, I'm proposing that Vogtle is the

best project in the world.

But looking forward to some very

interesting stuff and so again you're building a

relative structure that's going to work for many

different technologies, and you know, I think, I know

for a fact that they've been taking their all lessons

learned from what we've done in the past.

And we will be putting together lessons

learned for this project as well which, you know, I'm

looking forward to sharing with them and then helping

them develop the program.

I do want to give applaud for our lessons

learned because I know that we saw our behind-the-

scenes stuff, special moderator Jim Gaslevic is

leading our effort to put together our lessons

learned effort from this stage of Part 52.

Our goal is once the thing is online,

103g, we have behind-the-scenes the first 52.103g, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 55

we're looking at having public meetings and gathering

more feedback and really capturing, especially

capturing these lessons learned from the last few

years just to get, to see different what is going

well, what may improve and help that team in the

future for advance reactors.

MS. COOVERT: Yes, and the only thing I

would add to Vic's perspective, is I agree with

everything that he said, is that the one definite

recommendation is the communication as Zach and Amy

both said.

Having those open, direct understanding

each other and your communication styles, you know,

that's very important to get through if you want to

be efficient and effective getting through some of

these complicated issues, that's when you really

challenge your communication and your working status

because they can get very difficult.

And so establishing open communications

very is a key lesson learned from the very beginning.

Also having, I would recommend a VRG like

organization within the NRC and the benefit of that

is you're having key senior managers across the

Agency that you can leverage and resolve issues in a

very timely manner or get the resources to do so.

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So that was when we restarted that up

after Watts Bar, that was a, it really quickly

promoted a faster resolution of some of these issues.

For an inspection standpoint, I would say

that, you know, continue to have a formal oversight

process that allows repeatability, consistency, you

have a defined methodology of how you're doing

inspections, you understand what your inspection

scope is and when it's complete.

And then big picture, I would say

organizational flexibility and agility. You know,

with different things happening in the industry, with

VC summer, when that situation occurred and just the

different challenges you face, including COVID.

You really have to have an organization

that can turn on a dime and still keep safety its

number one focus. So those are the recommendations

I would have the lessons learned.

MR. LOPEZ-SANTIAGO: Thank you. So

before we go to the next question, Vic, I have a

follow up for you. You mentioned that the VPO office

which is sponsoring a lessons learned effort for the

Vogtle Project 3 and 4. How do you plan to engage

the public so you can get their input?

MR. HALL: Thanks, Omar. We are planning NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 57

public meetings. What's kind of nice about the

virtual world is it's so a lot easier to gather folks

from all around the world really to meet in forums

like this so if there is a silver-lining to the

pandemic, it's these kind of use of technologies.

But I think in everything we do, we are

trying to get as much feedback from all stakeholders.

And so for the lessons learned, absolutely, we will

be looking to again, engage the public, engage all of

our stakeholders and, you know, I'd like to hear the

criticism.

I want to hear where we could have done

better. And feed those awesome again for the future.

Because again, I think we've done great work, but

we're humans and we are a learning organization

committed to getting better and learning.

So absolutely, there will be follow up on

lessons learned. And I will say one more thing when

it comes to communications. You know, we're not the

IRS, you can call us, you don't get a recorded line.

If you email or call us, you're getting

a person and so if you have questions, if you want to

call up, if you have things you want to feed us before

hand, you have my email, you have Omar's email

address, you have Nicole's email address and phone NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 58

numbers.

Reach out to us anytime because we do

want to hear back. We do want to hear from as many

possible stakeholders and we do want to engage as

many people as possible.

Again, the more opinions you get, the

more diverse gift thought we get the better we will

be in the future.

MR. LOPEZ-SANTIAGO: Thank you, Vic. We

have a question for Zach. Zach, how much did having

a reference combined operating license help licensing

and construction of Vogtle or it did not help?

MR. HARPER: Well, I think it did help.

The, so take back in time, there's a design center

working group that was made up of, you know, TVA,

Southern Nuclear, Scania, (inaudible) there was Duke,

what progress at the time.

And they made up a group and the RCOLA

originally was Belafonte. It transitioned to Vogtle

maybe the 2008 timeframeish. But ultimately what

that group did and they partnered -- there's another

organization called New Start and really what they

were doing is establishing what a Part 52 license

would look like and what those RCOLA applications

would look like, so.

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And the reference kind of set the

standard, it set, you know, what everyone else

followed and that just contributed to you know, the

standardization of the plant.

Because when all the words in the

licensing basis are the same, then you know, you have

one issue, one solution, one implementation into

multiple plants.

So I think that you know that process,

what happened with New Start and you know, part of

what they were doing was they were closing COL

information items.

It's like certain information items are

things that specified in the DCD requirements to a

COL that need to be closed. And they were developing

plans for closure and some plans closure would be

hey, Westinghouse, go do this work and some cases it

would be some site-specific evaluation.

Others it would be ways that could be

addressed by a licensee in a standard way in the same.

And so I think that RCOLA process was helpful in

bringing the licenses, moving the ball forward,

moving the licenses through the RCOLA application to

a COL.

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being built. But even still, I still think it was an

advantage having all of those utilities involved

because frankly there was not a Part 52 license

before. There wasn't a COL that had intended to

build.

And having inputs from different

utilities into a standard way of submitting a license

I think was a big advantage because it, you know,

established an industry precedent for that

application that was ultimately approved and is being

constructed and will hopefully start soon.

MR. LOPEZ-SANTIAGO: Thank you, Zach. So

this question is for everybody here so. Given the

chance to go back in time, what would you do

differently? Let's start, who wants to start? Don't

make me pick. Okay, let's go with Amy.

MS. CHAMERLAIN: Thats a great question.

Let me think about it for a minute.

MR. HARPER: Do you --

MS. CHAMBERLAIN: I'll --

MR. HARPER: -- do you want me to --

MS. CHAMBERLAIN: I'll go and, you know,

I'll be honest, my rule of thought is licensing. You

know, that's where I think and I think I'd go back to

the verbatim compliance and what Zach mentioned on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 61

how many changes we needed to make and not just ones

that required NRC approval, but the departures that

we made through our own 50.59 like process that we

had to provide so much clarification in the FSAR to

allow for construction, to allow for inspectibility.

I think if I had it to do over again,

with all the knowledge I have now, is to go back to

those days. You know it's easier to do something

right, you know, do it once, I tell my kids all the

time, you know, it's better to do it right once than

having to go back and do it again.

And so that would be the only that, not

the only thing, but I think that'd be the major thing

that I'd go back and do is look at the DCD and Vogtle

3 and 4's COL application from in that light. Zach,

did you want to add?

MR. HARPER: Well, I agree with you. I

think that that's good. What, not to repeat what you

said, I would also bring up the, I think the

implementation of Tier II star, you know, if I had to

go back and do it all over and give someone, you know,

tell someone the future I would talk to them about

Tier II star. I don't think that part of the

regulation was necessary.

I think that we could have done other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 62

things in the license. You know, since that time

we've implemented, you know, certain criteria or

Southern has impletmented certain criteria in their

COL to address that, but you know, if I could go back

in time, then Tier II star would be at the top of the

list to either identify those requirements, put them

in an ITAAC somehow or identify those requirements

and say hey, this is just like an FSAR.

We have to comply with the FSAR no matter

what. It's, you know, a Tier II star requirement in

terms compliance, what's actually put in it's final

resting place, you know we're required to follow that

just as much as we are to follow words in the FSAR.

And you know we can, the industry has

demonstrated the use of 50.59 for years safely,

across the industry through the operating plants and,

you know, I think that was probably a bigger lesson

learned that has been implemented in several of the

new, the more recent design certifications where they

dont have that.

So I am happy to see that others have

been able to take advantage of that lesson.

MR. LOPEZ-SANTIAGO: I'm sorry, very,

very, high level. Will you explain what Tier II star

is for the audience that might not know.

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MR. HARPER: Oh, sure. So in a design

certification, there's two tiers, there's Tier I

which is made up of mostly the ITAAC, there's some

other information, but that any time you change,

touch anything in Tier I, it requires the NRC's prior

approval.

The, in Tier II that's what a traditional

operating plant's final safety evaluation report

looks like. It has the same structure, it follows

the Reg Guide 1.70 format.

And you know, there's provisions within

50.59 that allow you to make, that allow utility to

make changes without prior NRC approval.

Within Part 52 however, there's an

additional criteria that was added to the design

certification rules that information that is

bracketed and italicized and has a little star next

to it requires NRC approval to change.

So that, at a high level, that's really

it's information that a traditional operating Part 50

plant would be able to make changes to without NRC

approval, it's for you know, for Part 52 plants that

information requires it.

MR. LOPEZ-SANTIAGO: Okay. Thank you.

Nicole, you want to go next?

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MS. COOVERT: Sure, the one thing I would

note in looking, if I could go back in time, is I

would look at a possible more flexible inspection

program.

And I say that because we created from

the construction reactor oversight process, we have

as I talked about earlier, we have manual chapters

that have and inspection procedures and that

framework is outstanding.

In really looking at types of inspections

so that you have a good broad regulatory breadth of

inspections that happened over this huge project.

In developing those, we also made

inspection plans that in some times and in some cases,

were very restrictive and didn't allow us the

flexibility that we have since incorporated into our

program.

And I say that because the benefit we had

and the foresight we were having at the time was, I

mean, I believe the renaissance was happening, we

needed to be prepared for multiple new construction

projects, all in different phases.

So it was very important to have that

kind of rigor and structure. But as we worked through

Vogtle's inspections sometimes we found areas that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 65

could make improvement and changes.

And so Vic had referenced it earlier in

this discussion that we worked with VPO several years

ago and we went and we essentially looked at every

single activity that we've done to date, the hours,

inspection hours, we have done in certain areas,

functional areas, types of valves, welding,

companies.

And so we were able to go back and say

put some more flexibility into our program because we

did that assessment. So again, Vic said it perfectly.

We're a learning organization, we've

never going to be perfect, but we, if we have that

mindset to keep looking forward, we're not stuck in

something that's not flexible or agile, but that is

the recommendation I would make if I was going back

in time.

MR LOPEZ-SANTIAGO: Thank you. Vic, what

do you have for us?

MR. HALL: There's so many things I would

change if I could go back and I probably wouldn't

have as much grey hair. You know what I'm saying?

There are a lot of nuggets today.

I think just ideas that talk about the

history of how things were developed and Zach, when NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 66

you talked about targeting of ITAAC and I still

remember early discussions when we were talking about

should we have a public list of targeted ITAAC and

how you balance that idea of independence into being

offering clarity and then openness to what we were

going to inspect so adding in every area there's

things I'd love to go back to and change.

But I think along the way, we've

appropriated all of those lessons, but I think we've

tried along the way to improve along the way so I

appreciate the comments on Tier II star. I know

that's been a sore point.

Certainly, the idea of this compliance

versus safety and looking at the language of the

ITAAC, boy if I could go back and re-write some of

those ITAAC, I'd love to because I think there's

certainly room for improvement in those.

But having said that, I think we've done

an admirable job, again you know, making the magic

happen, making safety come through these words that

other humans have to understand so I'm proud of what

we've done, I know that there are plenty of things

that we can improve from and I'm looking forward to

making a better safe nuclear industry.

MR. LOPEZ-SANTIAGO: Thank you, Vic. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 67

from the conversation this morning, I have heard the

following things, for example, communications. From

communication and frequent communication is very

important to ensure that all the stakeholders are on

the same page and to avoid problems down the road.

Also, we heard that when you're

developing your design certification, your license,

your ITAAC, it's very important to make sure like

you're very specific and you're clear to avoid

confusion down the road because every person has a,

will have a different many interpretations of what

you originally intended to write.

So anything before closing, anything else

that you guys would recommend or give any advice to

the people that are trying to put in place new advance

reactors?

And we have four minutes. If you were

King for the day, what would you change?

MR. HALL: I'll have to say, the folks

that have joined today and the last day of the RIC is

usually the tough point in that people are tuned out

from all of the speeches so if you're on the call

today and you're listening, you are probably way

ahead of the game than you're understanding of

nuclear processes and your interest in the Part 52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 68

and everything else so you know I thank you for

listening certainly today.

Again I would welcome or invite you to

stay engaged, to give us a call if you have questions

on what you heard today and talk more because I think

it's important to keep dialogue going.

Communication is going to be across

everything. And we talked a lot about communication.

We're doing a lot about that, it's being deliberate

about how you communicate, in such a manner as I

understand, I'm going to talk more, I'm going to have

more meetings.

Gosh no one wants more meetings, but it,

I think we've been very deliberate in structuring who

will bring it in, how we're bringing folks in, making

sure engaging the public.

I know we've had Vogtle witness groups

down near the site to make sure we're able to reach

the local communities which is just, you know,

critically important for what we do in the NRC so

being deliberate and moving forward is going to be

key.

MR. LOPEZ-SANTIAGO: Zach, you're on

mute, Zach.

MR. HARPER: Sorry. I don't think that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 69

I have any other really lessons learned for the

advance reactors. I think that you know, I think

that a lot of them are in their pre-application stages

at this point and I think that you know, they're in

there still developing their technology.

I would say that there is a lot of, you

know, I get a lot of questions on Part 52 and I think

that, you know, there are balances between Part 50

and Part 52.

You get the advantages of that signed

finality and you get the advantages of the

standardization and you get certainty and those

issues and all the issues resolved up front.

That's big advantages. The downsides is

that it can be challenging during construction to

make changes to that license because you have a

license.

And so as the plant is being constructed,

you don't want the delays and, you know don't want

the licensing process to cause delays.

So you know, it's really a balance on

what the advance reactors on what their strategy is,

their licensing strategy is going to be. And I think

that the challenges, building a nuclear reactor is

challenging no matter what.

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No matter what process you follow, Part

50, Part 52, Part 53, it's all going to be

challenging. There's not a process that's going to

make things just easy.

So but I think that some of the key

lessons that we talked about today apply regardless

of what process that we're following and you know, I

just thank everybody that stuck around at this point

for their time and I appreciate sharing with you.

MR. LOPEZ-SANTIAGO: Thank you, Zach.

Nicole, Amy, any last words?

MS. COOVERT: Again, I -- oh, go ahead,

Amy.

MS. CHAMBERLAIN: Just real quick. I

haven't said it and I almost always say it when I

talk to folks. If you look at Unit 4, we've applied

lessons learned on Unit 3 right to Unit 4 and so as

Zach said, standardization we have two plants next to

each other that we're building the same and we're

learning and applying it.

Things just go smoother on Unit 4 so I

think to future applicants, that is something you

should definitely, you know, look at that even though

Part 52 might be difficult at times to construct,

once you apply those lessons, you do gain a lot of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 71

benefits thankfully. Go ahead.

MR. LOPEZ-SANTIAGO: Thank you. Nicole?

MS. COOVERT: Yes, the only thing I would

add is that, you know, today you heard three different

independent perspectives. We all have our individual

roles in this, but I can tell you that from what you

heard today that every one of us, every position, our

number one focus is the safe construction and

operation of these nuclear power plants.

So, you know, that's a commonality that

we have even in our different independent rules.

Thanks, Omar.

MR. LOPEZ-SANTIAGO: Well, thank you all

of you for your participation and sharing your

thoughts of our lessons learned of implementing the

Part 52 for Vogtle 3 and 4. So that's all we have.

Thank you very much and have a great day.

(Whereupon, the above-entitled matter

went off the record at 10:01 a.m.)

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14TH ST., N.W., STE 200 (202) 234-4433 www.nealrgross.com WASHINGTON, D.C. 20009-4309