ML25106A296
| ML25106A296 | |
| Person / Time | |
|---|---|
| Issue date: | 03/20/2025 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-0269 | |
| Download: ML25106A296 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards, Digital I&C and Electrical Systems Open Session Location:
teleconference Date:
Thursday, March 20, 2025 Work Order No.:
NRC-0269 Pages 1-73 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 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 DIGITAL INSTRUMENTATION & CONTROLS AND ELECTRICAL 7
SYSTEMS (DIGITAL I&C) SUBCOMMITTEE 8
OPEN SESSION 9
THURSDAY 10 MARCH 20, 2025 11 The Subcommittee met via Video-12 Teleconference, at 1:00 p.m. EDT, Thomas E. Roberts, 13 Chair, presiding.
14 COMMITTEE MEMBERS:
15 THOMAS E. ROBERTS, Chair 16 RONALD G. BALLINGER, Member 17 VICKI M. BIER, Member 18 VESNA B. DIMITRIJEVIC, Member 19 CRAIG A. HARRINGTON, Member 20 GREGORY H. HALNON, Member 21 ROBERT P. MARTIN, Member 22 SCOTT P. PALMTAG, Member 23 DAVID A. PETTI, Member 24 MATTHEW W. SUNSERI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 ACRS CONSULTANTS:
1 DENNIS BLEY 2
CHARLES BROWN, JR.
3 4
DESIGNATED FEDERAL OFFICIAL:
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 P-R-O-C-E-E-D-I-N-G-S 1
1:00 p.m.
2 CHAIR ROBERTS: Okay. This meeting will 3
now come to order. This is a meeting of the Digital 4
I&C and Electrical Systems Subcommittee. I am Tom 5
Roberts, chairman of today's subcommittee meeting.
6 ACRS members in attendance in person are Ron 7
Ballinger, Craig Harrington, Greg Halnon, Bob Martin, 8
Scott Palmtag, Matt Sunseri, and myself. ACRS 9
consultant present in person is Charlie Brown. ACRS 10 members in attendance virtually via Teams are Vicki 11 Bier, David Petti, and is Vesna on?
12 MS. ANTONESCU: She's supposed to be.
13 CHAIR ROBERTS: And Vesna Dimitrijevic.
14 Thank you. And Dennis Bley, our consultant, is also 15 online via Teams. If there's any other ACRS members 16 or consultants that I've left out, please speak up 17 now.
18 So Christina Antonescu of the ACRS staff 19 is the Designated Federal Officer for today's meeting.
20 No member conflicts of interests have been identified 21 for today's meeting, and we have a quorum.
22 During today's meeting, the subcommittee 23 will receive information on the staff's electrical 24 power and environmental qualification activities.
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 It's worth noting that this subcommittee, which is 1
commonly referred to as the Digital I&C subcommittee, 2
also has to review electrical systems issues. While 3
we periodically hold meetings to review the status of 4
digital I&C issues, we have not retained or been asked 5
to review electrical systems issues. With that, we 6
could not find a record of any such previous meetings.
7 Given the importance of electrical systems and 8
reliability and safety, now is a good time to start 9
such briefings, and we greatly appreciate the staff's 10 efforts to put together today's briefing.
11 The staff will brief us on several current 12 issues, including revised guidelines for environmental 13 qualification of electrical equipment, alignment with 14 the Commission's probabilistic risk assessment, or 15 PRA, policy, and several draft new and updated 16 regulatory guides. Also, the staff will address 17 ongoing coordination with the Federal Energy 18 Regulatory Commission (FERC) and North American 19 Electric Reliability Corporation (NERC) on the state 20 of the grid and international activities.
21 The ACRS was established by statute and is 22 governed by the Federal Advisory Committee Act, or 23 FACA. The NRC implements FACA in accordance with its 24 regulations found in Title 10, Part 7, of the Federal 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 Code of Regulations. Per these regulations and under 1
the Committee's bylaws, the ACRS speaks only through 2
its published letter reports. All member comments 3
will be regarded as only the individual opinion of 4
that member, not a committee position.
5 All relevant information related to ACRS 6
activities, such as letters, rules of meeting 7
participation, and transcripts are located on the NRC 8
public website and can be easily found by typing about 9
us ACRS in the search field on NRC's homepage. The 10
- ACRS, consistent with the agency's value of 11 transparency in regulation of nuclear facilities 12 provides opportunities for public input and comment 13 during our proceedings. We have received no written 14 statements, or requests to make an oral statement, 15 from the public. We have set aside time at the end of 16 this meeting for any public comments.
17 The subcommittee will gather information, 18 analyze relevant issues and facts, and formulate 19 proposed conclusions and recommendations, as 20 appropriate, for deliberation by the full committee.
21 I expect today's meeting will be informational only, 22 and there won't be any further deliberations, but 23 we'll decide that at the end of the meeting.
24 A transcript of the meeting is being kept 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 and will be posted on our website. When addressing 1
the committee, the participants should first identify 2
themselves and speak with sufficient clarity and 3
volume so that they can be readily heard. If you are 4
not speaking, please mute your microphone on Teams or 5
by pressing *6 on your phone.
6 Please do not use the Teams chat function 7
to conduct sidebar discussions related to 8
presentations. Rather, limit use of the meeting chat 9
function to report IT problems. For everyone in the 10 room, please put all your electronic devices in silent 11 mode and mute your laptop microphone and speakers. In 12 addition, please keep sidebar discussions in the room 13 to a minimum since the ceiling microphones are live.
14 For the presenters, your microphones are 15 unidirectional and you'll need to speak into the front 16 of the microphone and pull them closer to you to be 17 heard. If you have any feedback for the ACRS about 18 today's meeting, we encourage you to fill out the 19 public meeting feedback form on the NRC's website.
20 With that, we'll now proceed with the 21 meeting and I'll ask Mr. Wendell Morton of the NRR 22 staff to begin opening statements. Wendell.
23 MR. MORTON: We very much appreciate that.
24 So my name is Wendell Morton. I'm the branch chief 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
7 Electrical Engineering Discipline in the Division of 1
Engineering and External Hands and also Nuclear 2
Reactor Regulation. I want to say we appreciate the 3
ACRS invitation for this meeting. It's been a first-4 of-a-kind for us, and we're looking definitely forward 5
to the conversation and giving you an update on the 6
wonderful things the staff is doing in the electrical 7
discipline.
8 Obviously, we deal with a
lot of 9
challenging topics and issues, as well, (Audio 10 Interference.) participating in past meetings and had 11 a lot of successes, and this presentation will go a 12 long way to just give you an update on all those great 13 things we're working on to kind of, you know, further 14 the NRC's mission of being a modern risk-informed 15 regulatory. Along with my staff, I want to definitely 16 thank them all for contributing to this presentation 17 and also for the wonderful work that they do to 18 support us and also our management here, as well. Our 19 division director, Tania Martinez Navedo, is right 20 here next to me.
21 So with that being said, we thank you for 22 this invitation and look forward to this conversation 23 and may more come in the future. And after that, I'll 24 kick it to my staff who will be giving this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 presentation, Sheila Ray and Liliana Ramadan.
1 MS. RAMADAN: Good afternoon. My name is 2
Liliana Ramadan, and, as Wendell stated, we are here 3
to present an overview of our electrical engineering 4
activities. And if we can go to the slide for the 5
overview of pertinent regulations. It pretty much 6
gives a depiction of what regulations our activities 7
fall under.
8 Next slide. This slide specifically 9
focuses on how we review complex electrical 10 engineering safety and regulatory issues within the 11 licensing purview. Some of our evaluations include 12 designs that propose electrical tower system 13 modifications to operating reactors, such as license 14 amendments, notice of enforcement discretion 15 allegations and power uprates. We also provide 16 specialized technical assistance and advice to other 17 divisions, regions, and offices. We participate in 18 audits and inspections as technical specialists and 19 team members.
20 Next slide. In the next couple of slides, 21 I will be going over the open-faced condition. And 22 with that, what is open-faced condition, also known as 23 OPC? It's the loss of two of three phases of the off-24 site power circuit on the high-voltage side of a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 transformer connecting an off-site power circuit to 1
the transmission system. The operating experience and 2
the Byron event demonstrated that OPC may be difficult 3
to detect by the existing plant instrumentation and 4
electrical protection schemes under all operational 5
conditions, and there is a potential for severe 6
voltage unbalance resulting in the degradation or the 7
failure of electrical equipment. In some cases, the 8
inability to detect and disconnect the degraded power 9
source from the safety bus prevents the transfer to a 10 standby off-site power supply and the standby 11 alternating source. OPC is considered not a common 12 event. Next slide.
13 CHAIR ROBERTS: If I could pause you just 14 for a little bit. I had asked for this to be in the 15 presentation because this was a major electrical power 16 issue back in the 2012 to probably 2015 time frame, 17 and there was a lot of activity that took place 18 through the entire fleet to address these issues. And 19 it was almost closed out until the Palisades plant 20 decided to restart. They listed this as one of their 21 major open issues in the presentation they gave us 22 several months ago.
23 So given the time that's passed and the 24 fact that many of us were not involved with the ACRS 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 or NRC activities back 10 - 12 years ago, I thought it 1
worth a little bit of time for the staff to review the 2
issue and bring us up to speed on what the concerns 3
were and what they still are.
4 MR. BROWN: Just one observation on the 5
open phase. AC circuits, basically, are either three-6 phase Y connected, like the Y, or they're delta. If 7
you have a Y connection and you lose a phase, you go 8
from three to one, which is very difficult to detect.
9 The delta can actually keep operating because you 10 still have two out of three phases, and it presents 11 another set of problems in terms of the currents 12 issue, the size of your tables. So I just want to try 13 to give a little, call it a lecture or an observation 14 on what it really means when they talk about open-15 phase circuits because it's not necessarily obvious to 16 all those who don't deal with this garbage all the 17 time.
18 Anyway, that was just trying to give 19 people a calibration.
20 MS. RAY: This is Sheila Ray, senior 21 electrical engineer in NRR. I just wanted to mention 22 the bulletin is already closed out, and we'll be 23 discussing a little bit further on that. I just 24 wanted to clarify.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 MS. RAMADAN: Next slide, please. The NRC 1
addressed OPC through NRC'sBulletin 2012-01 which 2
focused on the design vulnerabilities that require the 3
licensee's response to mitigate potential impacts on 4
safety. To address OPC, the licensee had two options:
5 the auto-detection option and the risk-informed 6
option. As the bulletin noted, approximately 65 7
percent of the operating reactors adopted the risk-8 informed option. And what the risk-informed option 9
basically allowed the licensees and applicants to 10 demonstrate that operator manual would be sufficient 11 to mitigate the impact in lieu of automatic 12 protection.
13 Next slide. And this slide depicts some 14 of the past actions taken by the staff. As stated 15 earlier, the NRC issued Bulletin 2012-01 to request 16 information about the facility's electrical power 17 system designs in the light of the OPC design 18 vulnerability. In response to the Bulletin 2012-01, 19 the licensee stated that the OPC design vulnerability 20 existed at all operating reactors.
21 In 2013, the industry-wide initiative was 22 submitted of the proposed resolution to the OPC issue.
23 A summary report documented the NRC staff's review of 24 the licensee's response.
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12 In 2015, BTP 89 was issued to provide the 1
OPC-related guidance to conduct license amendment 2
reviews. In 2016, the Temporary Instruction 2515/192 3
was developed to provide NRC inspectors guidance to 4
verify interim compensatory measures to the OPC issue.
5 In 2017, the SRM to the SECY-16-0068 established a 6
basis for the OPC evaluations and direction to the 7
staff.
8 Next slide. In 2020, the NRC developed 9
the TI 2515/194 that provided to the inspectors 10 guidance to verify that the licensees appropriately 11 implemented the NEI voluntary industry initiative.
12 Using the TI 2515/194, inspectors conducted 13 inspections at all operating reactors. In 2023, the 14 OPC issue was closed by the bulletin through the FRN 15 with the exceptions for Palisades and the Vogtle new 16 units.
17 MEMBER HALNON: To give you all a little 18 perspective from the licensee perspective or side of 19 the things, a voluntary industry initiative is bubbled 20 up to the CNOs and the committee called in SIAC. It's 21 the Nuclear Strategic Initiatives Advisory Committee 22 of NEI, and they all vote to kind of ratchet each 23 other to do it and to make sure their responses back 24 to the NRC is a commitment basically. And what 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
13 does is puts a little bit more control in licensees' 1
hands about whether it's safety-related and non-safety 2
related or whether it's a detection or auto-trip, like 3
the two options that you gave with the different ways 4
that people could do it and also the timing of it 5
because it would usually require some kind of outage 6
to be able to install it. Obviously, locals put that 7
aside. Palisades was shutting down, so they just let 8
it expire basically. They said, we don't need to do 9
it because we're not going to have any power going out 10 on that. So this gave the industry a lot of 11 flexibility.
12 I was going to ask you how did that 13 voluntary initiative go through the bulletin? This is 14 a high-visibility voluntary initiative. There's other 15 ones, like the MRP, another thing we do through the 16 materials folks. Could this go pretty well from your 17 perspective, the standpoint of allowing the industry 18 to kind of design and set the requirements themselves 19 and be able to verify through temporary instruction?
20 MS. RAMADAN: Yes, it did. And there's a 21 subject matter expert online that can speak to that, 22 and I would revert to Vijay to kind of go over a 23 little bit more on the specifics. Vijay, if you don't 24 mind.
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14 MR. GOEL: Yes. This is Vijay Goel from 1
electrical engineering branch. Yes, I was very much 2
involved with this. So it went very well actually.
3 Initially, NEI came with their validity initiatives, 4
and we definitely appreciated that. And, initially, 5
they had, like, stripping that came with the risk-6 informed option, and NRC independently evaluated that.
7 That is optional, legally good. So, basically, all 8
the plants have implemented very satisfactory the open 9
phase, and the NRC is satisfied with their responses 10 and we closed the issues at all the operating plants.
11 Thank you.
12 MEMBER HALNON: Thank you, Vijay. And the 13 other option would have been the backfit plants.
14 That's a very expensive and manpower-intensive on both 15 sides of the table in that respect, so this saved a 16 lot of money and a lot of flexibility on both sides.
17 I'm not going to say they collaborated really well, 18 but the industry offered up an acceptable solution and 19 regulatory structure for that.
20 MR. GOEL: Yes, definitely. Yes, that's 21 good. Thank you.
22 MR. MORTON: This is Wendell Morton, if I 23 could jump in to make an additional point on top of 24 Vijay's. I do think, coming in from a different 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 discipline, I&C, where I spent most of my bread and 1
butter, I think this represents a really good example 2
of a really good collaborative effort between industry 3
and the staff in developing acceptable solutions --
4 MS. ANTONESCU: Can you speak up, please?
5 MR. MORTON: Can you hear me now? Sorry.
6 I thought this really represented an excellent example 7
of collaborative effort between industry and the staff 8
to develop a technically-sufficient solution to 9
address a problem that was identified that we all got 10 mutual benefit from. So I want to point that out, 11 too, and kind of re-emphasize that for the electrical 12 discipline. Thank you.
13 CHAIR ROBERTS: This is a case where an 14 event, and Charlie talked about it, Y versus delta, 15 and the people that work in three-phase powers since, 16 I don't know, a couple hundred years, at least a 17 hundred years. But this is one where operating 18 experience revealed a vulnerability where you had what 19 was essentially an undetectable or undetected failure 20 that could impede the operation of safety -- the 21 cooler is important to safety, so it's important to 22 come up with an approach to, you know, mitigate it.
23 And I guess, before we go back to you, 24 Charlie, I was wondering if Dennis, who is very deeply 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 involved with the issues back when they were working 1
in the, you know, 10 to 12-year time frame, Dennis, I 2
wondered if you would make any more observations.
3 DR. BLEY: No. I think the staff is doing 4
great. There were so many people jumping in. EPRI 5
came and gave us a presentation on a solution that 6
they developed, and some of the vendors were upset 7
that they were competing with EPRI members to some 8
extent. Anyway, they were good solutions.
9 MR. BROWN: One other observation, piece 10 of information rather. If you lose it in a Y, 11 everything goes to a stop. If you're in a delta 12 configuration was the phase, if the transformer is 13 rated properly, you can supply about, I think it's, 14 like, 63 percent -- I haven't got the exact number; 15 it's in the ballpark -- of the rated load. So if your 16 rated load is actually on that transformer or whatever 17 the gear you're coming out of is less than 63 percent, 18 you keep on running. If it's greater than that, you 19 may not see it, but all of your currents, everything 20 is out of balance by then.
21 So you don't detect that by just listening 22 to the plant. It's not particularly obvious. My Navy 23 experience, I never ran into one of these in 35 years, 24 so it's not like they happen all the time. And 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
17 Navy is fundamentally Y-connected circuits, so, if you 1
lose something, you're going to lose it in a plant 2
pretty quickly just based on plant parameters. Just 3
a calibration thought process on this issue.
4 PARTICIPANT: So there's no protection 5
mechanisms in response --
6 MR. BROWN: It's not readily obvious, 7
depending on the loads and the size. These are big 8
transformers in many cases, so those single-phasing 9
auto Y is more obvious because you rapidly start 10 losing other things because it's feeding a number of 11 different systems.
12 PARTICIPANT: And you would expect this to 13 be something that could occur in lifetime of plant.
14 MR. BROWN: It turns out transformers are 15 pretty darn robust, but, like I say, 35 years working 16 on all the stuff I worked with over because Rickover 17 expected us to be aware of all the electrical stuff, 18 even though we were a downstream user of the power in 19 the submarines, not solely responsible, although I 20 hate to say it, anytime something broke, he told us to 21 make sure it got fixed.
22 MEMBER HALNON: That's pretty good, 23 Charlie. It took you only 20 minutes to get through 24 the right -- other one.
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18 (Laughter.)
1 PARTICIPANT: It's an honest question, 2
though, if he was you'd think that, because the phase 3
became disconnected at an operating plant, and they 4
initially had trouble detecting it, but they detected 5
all the ancillary effects of the voltage.
6 MEMBER HALNON: I was going to mention, 7
that's the safety issue, especially with the deltas 8
issue. This is the power going back into the plant, 9
the essential services power, not necessarily power 10 going out, although that's a problem, too. But you 11 could be running your equipment and it degraded, and 12 not know it and be messing up the motors in addition 13 so they're not operability. So you lose your ACCS 14 operability pretty quickly.
15 MR. BROWN: An unbalanced day's operation 16 can overheat motors, all types of other items that 17 you've got that are fed by three phase.
18 DR. BLEY: As Charlie says, the unbalanced 19 condition can lead to really high currents, and they 20 go high fast enough that the protective circuits won't 21 protect the equipment. It's possible.
22 MR. BROWN: They can also stay under the 23
-- depending the load on that particular transformer's 24 configuration. They just sit there and sizzle for a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 while.
1 PARTICIPANT: So, Tom, what was the fix?
2 What would that be? Just a detect --
3 CHAIR ROBERTS: I'll have to turn that 4
back to Liliana, but the two-phase would always have 5
some sort of detection circuit, and the other was to 6
do a risk-informed evaluation that you could basically 7
deal with the delay in finding the problem when it 8
happens. I hope I read that right.
9 MR. BROWN: And that's what the Navy did.
10 We never put anything in, at least to my knowledge.
11 MEMBER HALNON: At some points but some 12 phase-to-phase monitoring in with alarms that may have 13 complemented the risk-informed way. Some put 14 automatic systems in. They tried to stay from the 15 automatic systems just because of the maintenance and 16 all the stuff around it, but there was some hardware 17 usually on the --
18 (Simultaneous speaking.)
19 MEMBER HALNON: Detection protection, yes.
20 MEMBER HARRINGTON: The challenge is if it 21 happens on a standby transformer that's extremely 22 lightly loaded, you just can't detect it because 23 there's no --
24 MS. ANTONESCU: Can you please identify 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 yourselves when you speak --
1 MEMBER HALNON: Yes. This is Greg. Part 2
of the problem is the plants would go on their 3
auxiliary power and running off their output of their 4
transformer generator to get the fast transfer to the 5
-- essentially, even when you're getting fast 6
transfer, if you have a lost split one phase out, then 7
you're done because this usually happens out in the 8
switch yard or beyond where you lose that problem, or 9
you lose that phase.
10 MS. RAMADAN: Next slide. As stated in 11 the previous slides, we reviewed complex electrical 12 engineering safety and regulatory issues in the 13 licensee's review, primarily of the combined operating 14 license applications research test reactor amendments 15 and certification reviews for advanced reactors under 16 10 CFR Part 50 and 52. And, currently, we are engaged 17 in pre-decisional application review activities for 18 the Natrium reactor, and we also continue to engage in 19 the review activities for the NuScale US460 standard 20 design approval for the light water technology small 21 modular reactor. On November the 5th, 2024, we 22 presented to the ACRS subcommittee the staff's review 23 of the US460 Design Approval Application Final Safety 24 Analysis Report, revision 1, for Chapter 8, Electrical 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 Power.
1 Next slide. And for this one, we're just 2
currently evaluating electrical systems in support of 3
decommissioning activities.
4 MEMBER HALNON: The Crane Energy Center is 5
working on repowering their -- they sold one of their 6
big transformers to TMI 2 for decommissioning. Are 7
you or will you be involved in making sure, when they 8
repower Unit 1, that they haven't dismantled 9
electrical systems such that they weren't keeping 10 their cable -- a lot of things go down, go away when 11 you're decommissioning and go to cold and dark 12 condition. Will you be doing any kind of interaction 13 with them to make sure that their electrical systems 14 are back up to snuff?
15 MS. RAMADAN: For the decommissioning 16 aspect of the electrical reviews?
17 MEMBER HALNON: No, the repowering of Unit 18 1.
19 MS. RAMADAN: I would refer to Wendell on 20 the specific question.
21 MS. MARTINEZ NAVEDO: This is Tania 22 Martinez Navedo. With respect to that particular 23 restart project, it's very early in the project to 24 have advanced technical discussions, but I do say 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 that, for Palisades, there has been some touchpoints 1
with the electrical staff. So that might be a 2
potential conversation we're going to have with them.
3 MEMBER HALNON: Okay. Yes. It seems 4
like, somehow, you're going to have to be involved, 5
especially when you start looking at the submerged 6
cables in units that have been shut down. You don't 7
worry about the cable balls getting filled with water 8
if you don't have any power going through them back.
9 So it seems like there would be some that we (Audio 10 Interference.)
11 MS. MARTINEZ NAVEDO: Yes. That and, for 12 example, if somebody needs to provide some information 13 on the equipment that held qualification during the 14 time the plant was shut down. So there are 15 conversations of that sort happening at this moment 16 for Palisades, but we will certainly have those 17 further projects.
18 MEMBER HALNON: They have to come in and 19 start talking. Thanks.
20 MS. RAMADAN: Next slide, please. We also 21 review electrical engineering safety and regulatory 22 issues in license renewal and subsequent license 23 renewal reviews under 10 CFR Part 54 where we focus on 24 the license renewal review to ensure that the effects 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 of aging will be adequately managed throughout the 1
period of extended operation. As a background, 2
license renewal is the renewal from 40 to 60 years.
3 A subsequent license renewal is from 60 to 80 years.
4 Our electrical reviews are limited to 5
long-lived passive in-scope components, including SVO 6
recovery path. They're mostly limited to cables, fuse 7
holders, metal and closed bus, connections, switch 8
yard insulators, transmission conductors.
9 The aging management programs are 10 primarily condition monitoring with limited actions.
11 The electrical time-limiting aging analysis is usually 12 covered under the EQ program. High voltage insulators 13 and transmission conductors are covered at site-14 specific further evaluation.
15 Currently, in-house, we are reviewing 16 Perry, Diablo Canyon, Browns Ferry, Clinton, and 17 Dresden applications.
The remainder of the 18 application safety evaluations have been completed.
19 Also in-house, we are currently adjusting to new 20 metrics where we continue to apply process 21 improvements, lessons learned, and engagement with 22 industry to ensure that appropriate credit for 23 operational programs occurs.
24 Next slide. We also collaborate with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 research on these projects. For the valve-regulated 1
lead-acid battery project, it's basically we are doing 2
a feasibility study to determine how the operational 3
and environmental conditions and failure modes could 4
affect the service life for VRLA batteries, and this 5
project currently has a direct correlation to what we 6
are currently working in-house.
7 The second project, the islanding, is 8
basically a research that would determine the --
9 CHAIR ROBERTS: Liliana, what would be the 10 end result for the VRLA study? Would you rather have 11 a reg guide or add to a reg guide some endorsement of, 12 you know, approaches to refine a VRLA battery?
13 MS. RAMADAN: Yes. And, currently, once 14 that's completed, our intentions are to do a new 15 regulatory guidance on this particular technology.
16 CHAIR ROBERTS: So what are you seeing so 17 far? Are there any hard spots or things that are 18 challenging?
19 MS. RAMADAN: Right now, we're currently 20 in the draft stages of the regulatory guidance, and we 21 have taken some exceptions to it. But we also, for 22 the IEEE standards that we're endorsing, they are 23 currently getting updated and the final publication 24 should be occurring and we will follow pursuit with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 our guidance.
1 CHAIR ROBERTS: Okay. So no technical 2
issues that you know of, just trying to get 3
synchronized with the paper?
4 MS. RAMADAN: Correct. None that we are 5
aware at this point.
6 CHAIR ROBERTS: My understanding is the 7
reason why NuScale EDAS system is not safety related 8
is because there's no, you know, technical bases for 9
the VRLA battery; is that right?
10 MS. RAMADAN: Correct.
11 CHAIR ROBERTS: Okay. Thank you.
12 MS. RAY: We also are involved in the 13 assessment of the NUREG/CR-7153, and we also are 14 involved in the future-focused research, which is a 15 study on novel and innovative cable condition 16 monitoring techniques.
17 CHAIR ROBERTS: Can you talk a little bit 18 more on islanding? I might have missed it. What is 19 islanding and what's the focus of the research there?
20 MS. RAMADAN: Islanding is, basically, 21 we're trying to determine the possible challenges for 22 the nuclear power plants and advanced reactors during 23 the transition, operation, and recovery from islanding 24 mode operation. Just trying to get an understanding 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 of what the mode rejection events would be, what would 1
be the electrical power system responses, and what 2
those challenges would be.
3 MEMBER HALNON: Okay. Islanding would be, 4
like, a microreactor that supplies its own grid, and 5
there's nothing else to support?
6 MS. RAMADAN: Correct.
7 CHAIR ROBERTS: Okay.
8 MS. RAMADAN: Next slide. We provide 9
evaluation for design applications for new reactors, 10 advanced and small modular reactors regarding the EQ 11 program. For the license renewal and subsequent 12 license renewal activities, we engage in the review of 13 electrical components within the EQ program of 14 electrical equipment for managing the effects of aging 15 for applicable components during the period of 16 extended operation.
17 With the proposed rule on increased 18 enrichment of conventional and accident tolerant fuel 19 design for light water reactors, there's a potential 20 request by the licensees to increase the power output 21 of reactors, and we are currently involved in the EQ 22 review to ensure that the structure systems and 23 components are able to accommodate the conditions that 24 would exist at these higher power levels and 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
27 extension of the refueling frequencies.
1 Some of these conditions can have 2
potential impacts to the EQ design input, such as the 3
radiological dose, pressure, and temperature. So 4
that's currently what we are working on during this 5
program. Next slide.
6 CHAIR ROBERTS: Are you going to talk 7
later about design basis versus beyond design basis 8
environments? Okay. I'll wait until you get there.
9 MS. RAY: Thanks, Lily. I'm going to take 10 over. My name is Sheila Ray. I'm a senior electrical 11 engineer in the Electrical Engineering branch. I've 12 been here 20 years. Also, I'm a licensed professional 13 engineer in the state of Maryland.
14 We're actually going to switch topics to 15 infrastructure, and I'm really excited to share the 16 immense work we do in this area. So both electrical 17 and PRA staff participate in several IEEE groups, 18 provide technical expertise, and to present agency 19 positions for potential inclusion in standards.
20 Specifically, we participate in the IEEE Power and 21 Energy Society in the committees listed on this slide.
22 We developed a successful and cohesive 23 vision and strategy to endorse IEEE standards and 24 regulatory guides. Our strategy is multifaceted 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
28 results in efficiency and regulatory processes and 1
reduced time frames to complete reg guides. In line 2
with the ADVANCE Act, we endorse standards for future 3
reactors. We focus on the mission and regulatory 4
requirements when determining if a standard should be 5
endorsed in a new reg guide or to revise an existing 6
reg guide. This approach for staff and constituents 7
allows them to navigate and use reg guides, and it 8
prevents an ad hoc approach.
9 Also, as the group gathers and analyzes 10 operating experience, it informs the reg guide 11 process. For example, the timing of a reg guide 12 update may change if there's numerous operating 13 experience events on a particular component.
14 Our strategy includes creating and 15 revising reg guides such that they're applicable to 16 licensees and applicants subject to 50 and 52.
17 Thereby, the reg guides are applicable to operating 18 reactors, new reactors, advanced reactors, SMRs, as 19 well as nuclear facilities in some cases.
20 Slide 21. Oh, sorry. Slide 20. In our 21 strategy, we ensure reg guides are fully aligned with 22 Commission PRA policy and provide risk-informed and 23 performance-based metrics. We particularly focus on 24 combining standards on one technical topic in a reg 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 guide. For example, in Reg Guide 1.9, we focus on 1
emergency on-site power sources, including diesel 2
generators and combustion gas turbines. Another 3
example is Reg Guide 1.204, where we endorse multiple 4
standards on lightning protection.
5 This strategy is beneficial in several 6
ways. It reduces staff hours, reduces costs, creates 7
a one-stop shop for agency policy on the technical 8
topic, and allows for greater efficiency.
9 Slide 21. Given the numerous IEEE 10 standards, a variety of staff working on reg guides, 11 and applicability to 10 CFR Parts 50 and 52, a tool 12 was developed for staff to understand the reg guide 13 process and also increase process efficiency. While 14 research owns the reg guide process, electrical staff 15 are the technical leads and develop the content of the 16 reg guide. The checklist is a living document that 17 outlines actions for staff and incorporates lessons 18 learned.
19 Another example of our commitment to 20 process efficiency is the development of a briefing 21 sheet that highlights risk principles when presenting 22 to management.
23 MEMBER HALNON: Where it says your 24 electrical staff has technical leads, can you 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
30 explain how research, since they kind of control the 1
reg guides, how they work with you on that? Plus, I 2
assume that there's committee intendants and 3
membership, as well.
4 MS. RAY: Sure. So many electrical staff 5
attend the IEEE working groups to develop a standard, 6
so we are including the NRC position in the standards 7
for consideration. So many of those staff will write 8
the actual reg guide to endorse the standard, and 9
then, usually, when we write the reg guide, we'll hand 10 it over to research and they take it through the 11 process, meaning through the concurrence process, 12 providing it to ACRS for comment, issuing it for 13 public comment. And then, once the public comments 14 are in, they gather the public comments, and then the 15 technical lead will address the public comments and 16 revise the reg guide. And then research will then 17 finally issue the reg guide. So it's a very much 18 joint hand-in-hand collaboration.
19 DR. BLEY: Sheila, this is Dennis Bley.
20 Kind of how has that been working when the nuclear is 21 not the main actor in all this electrical stuff but 22 we're a significant actor? You get the standards the 23 way you want them pretty well, or do you have to do 24 quite a few exceptions and clarifications?
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31 MS. RAY: It depends on the regulatory 1
guide. As you mentioned, there are some IEEE groups 2
that are specific to nuclear and others where the 3
equipment is not specific to nuclear. For example, 4
batteries, vented lead-acid batteries are used in many 5
industries: telecom, military. It's not specific to 6
nuclear. So in those cases, sometimes, we may have to 7
add some clarifications or supplements.
8 For reg guides or standards particular for 9
nuclear, I think it's an easier process to endorse 10 them.
11 DR. BLEY: That makes sense. Thanks.
12 MS. RAY: Sure. Other questions? Moving 13 on to slide 22 regarding Draft Guide 1427. This is 14 Qualification of Fiber-Optic Cables, Connections, and 15 Optical Fiber Splices. The DG was issued in October 16 of 2024. We received public comments, and the staff 17 has addressed them. Final reg guide is in concurrence 18 and expected to be issued in spring 2025.
19 Slide 23. We have seen some --
20 DR. BLEY: Dennis again. On the 21 fiberoptic stuff, is there much of it in the plants 22 now? I'm not aware. I haven't been out there a lot 23 in the last few years. What have we been doing before 24 we get this guidance?
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32 MS. RAY: There were two questions in 1
there. What fiberoptic cables are in there, my 2
understanding, it's more for instrumentation than 3
power. It's control systems.
4 CHAIR ROBERTS: They use it for isolation 5
quite often to prevent crosstalk between channels.
6 MS. RAY: I'll also defer to my colleague, 7
Matt McConnell. I think he's on the line.
8 MR. McCONNELL: Yes. Good afternoon.
9 This is Matthew McConnell, senior electrical engineer 10 in the Long-Term Operations and Modernization branch 11 in NRR, and also the agency's EQ SME.
12 So with regard to the question on 13 fiberoptics, we've been seeing that more often in the 14 digital I&C upgrades.
- And, generally, these 15 fiberoptic cables are installed in locations that 16 would be considered a mild environment, so it would be 17 covered under more the 50.55(a)(h) or the GDC-4 18 criterion for qualification versus 50.49, hopefully, 19 to answer your question.
20 DR. BLEY: Yes, that's good. Thanks.
21 MS. RAY: Member Bley, did that answer 22 your second question, as well?
23 DR. BLEY: It's good enough. Thanks.
24 MS. RAY: Okay. We'll continue. Slide 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 23.
1 CHAIR ROBERTS: Just to clarify, on the 2
previous slide, the plan to issue the final reg guide 3
in spring 2025, the process would have you run it 4
through the ACRS staff first, so when do you expect 5
that to happen?
6 MS. RAY: In the next coming weeks.
7 CHAIR ROBERTS: Great. Thank you.
8 MS. RAY: It's in concurrence. Once we 9
get to a certain point in concurrence, it will be 10 shipped over to you promptly.
11 CHAIR ROBERTS: Great.
12 MS. RAY: So one of the comments from ACRS 13 member -- we really appreciate those comments -- was 14 regarding the qualification of equipment for beyond 15 design basis accidents. Staff added a clarification 16 in the background section related to the 5155 17 equipment relied on for beyond design basis must have 18 sufficient capacity and capability.
And to 19 demonstrate that capacity and capability, type testing 20 was used to --
21 CHAIR ROBERTS: Yes. Probably should 22 interrupt you to give a little background, people may 23 not remember from six months ago, but we had a 24 discussion on this draft guide and one of the concerns 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 I had was that the draft guide had several exceptions 1
listed, I think there were six total, all would have 2
said that anything in the IEEE standard that had to 3
deal with beyond design basis conditions. They called 4
it design extension conditions, I think, is the 5
international terminology used, but it's really for 6
severe accident conditions where, basically there's an 7
exception to not meet them, that they weren't invoked 8
as requirements or what do you call it? They weren't 9
invoked as operative guidance. And I was wondering 10 why that would be the case because there are certain 11 requirements in the regulations for beyond design 12 basis conditions, you know, things like -- the 13 complementary design criteria I think they're called 14 in LMP, for example, requires you to have equipment 15 operability in those environments and there was some 16 discussion of non-safety with special treatments for 17 advanced light water reactors.
18 So it wasn't clear to me why those would 19 be excepted, you know, take an exception to in the 20 draft guidance. SO I think Sheila, your -- intent was 21 to answer that question.
22 MS. RAY: Sure. So our regulatory guide 23 focuses more on design basis accidents. So in that 24 case, we are taking an exception that you don't have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 to use all of the type testing for design basis. You 1
can use type testing to demonstrate the capacity and 2
capability for design basis -- I'm sorry -- severe 3
accident. You do not have to use type testing or 4
severe accident, but it's one method to demonstrate --
5 CHAIR ROBERTS: I think they're agreement 6
is setting to use the term as applicable or some 7
buzzword, so it wasn't a requirement implied in the 8
IEEE standard that you had to meet all the severe 9
accident environmental conditions. It just said you 10 had to look at whether or not it was appropriate.
11 So, again, it wasn't clear to me why there 12 was an exception taken to those types of statements, 13 and it also seemed like the reg guide was, at one 14 point -- was it 89? I probably don't get the numbers 15 right but the one on, overall, the environmental 16 qualification, not specific to fiberoptics, did not 17 take exception to some of the guidelines that were in 18 that IEEE standard.
19 So I was just trying to understand what is 20 the overall theme? You know, what is it you're trying 21 to communicate with these exceptions?
22 MS. RAY: It's more of that, for design 23 basis, we wanted to make it very clear and then 24 separate out beyond design basis. Go ahead.
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36 MR. BROWN: This is for fiberoptic cable.
1 MS. RAY: Fiberoptics and --
2 MR. BROWN: That's what we're talking 3
about. I just want to make sure I'm on the right page 4
here.
5 MS. RAY: Yes.
6 MR. BROWN: I don't know about commercial 7
experience, and we haven't had a naval nuclear reactor 8
beyond design basis accidents occur. But in testing 9
of normal cables that you find, electrical cables, and 10 the advances in materials that they've used for 11 insulations and other type stuff, there's some pretty 12 severe steam and other temperature conditions that 13 were beyond what you would design for, and they worked 14 okay.
15 Fiberoptic cable is a totally different 16 material and it sounds like you're using kind of a, 17 well, they ought to maybe perform okay in the beyond 18 design basis world and we're just going to kind of 19 take a chance that they will. That's what I got. I'm 20 not trying to be negative --
21 MS. RAY: Right. We're commenting that 22 type testing is one way to demonstrate --
23 MR. BROWN: But I'm just saying that the 24 type testing is one thing, but real world experience 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
37 of normal standard cables in environmental conditions 1
that exceed what they are type tested for has 2
generally been that they work. They might not work 3
for three months, but they will work for three weeks 4
or whatever it is, whereas fiberoptic cables are not 5
-- that material that's internal to the cables is far 6
less robust than copper and normal insulation 7
materials.
8 So how do you translate that thought 9
process into the beyond design basis world saying that 10 we're not really worried about -- it sounds like we 11 don't have any basis for making that extension; that's 12 a better way for me to phrase it. So I don't quite 13 understand that.
14 MS. RAY: I will also ask my colleague, 15 Mr. Matt McConnell, to jump in.
16 MR. McCONNELL: Yes. This is Matthew 17 McConnell again, senior electrical engineer with the 18 NRR. It's interesting, speaking specifically to 19 fiberoptics, that my experience with them and in 20 talking with various vendors that have put them 21 through significant testing with radiation, 22 temperature, and whatnot, that, initially, there was 23 concerns about potentially discoloration causing 24 problems with the reflection/refraction properties 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
38 be able to transmit signals, but they actually found 1
in the end that, when they subjected them to the 2
extremes, that the actual glass material itself had a 3
healing property that would actually improve the 4
actual signal strength. That's something that 5
happened over time. It's almost like scarring where 6
you or even a weld where you maybe are damaging, 7
purposely damaging something, but then it gets 8
improved over time.
9 So I just wanted to throw that in there as 10 far as they are actually been demonstrated, they have 11 been demonstrated to be rather robust, even though, 12 currently, what we've seen is that they're being put 13 into mild environments that would, under pretty much 14 no circumstance, be exposed to what would be 15 considered a severe accident or beyond design basis.
16 Thank you.
17 MR. BROWN: Just one observation on the 18 healing. That implies there's an initial degradation 19 but that the radiation exposure over a longer term 20 heals itself to some extent, and that's what I get out 21 of it. But that sort of says the stuff doesn't work 22 for a while, and then, several weeks later, it maybe 23 works a little bit better after a while. But that 24 doesn't help you again until in the initial parts.
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39 I'm just trying to get the points across 1
to make sure I understand where you're going with 2
this. I'm not against fiberoptic cables; don't get me 3
wrong. They have to be used in certain circumstances.
4 We definitely don't want to use co-ax if we can use 5
fiber from the normal digital controls and other type 6
stuff because you get some that are performance on 7
their operational capability.
8 But we have to be very careful on how we 9
extrapolate and say everything is okay and then also 10 while it heals later, but is that a month later, is 11 that two weeks? If somebody had something that could 12 tell us is this a matter of a few hours or is it a 13 matter of a few weeks for this healing so that they 14 come back and they work again. We haven't seen 15 anything, we haven't heard anything, at least I 16 haven't seen anything in the stuff provided, that 17 would give us a flavor to what you're talking about in 18 terms of this healing capability. I don't know if 19 you've seen that, Tom, but I haven't, so that's my 20 concern. I don't know whether Tom agrees with that or 21 not totally.
22 CHAIR ROBERTS: I think it's a matter of 23 having equipment that will work in the environment 24 that's it's accredited to work in, which is what that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 next-to-last sub-bullet, third sub-bullet on that 1
list, says. Where it leaves me is that you're going 2
to send us the latest, you know, graph from prior and 3
the 1427 ready for issue, and we'll take a look at it.
4 You know, certainly, that last major sub-bullet would 5
resolve which it certainly could've had six months ago 6
which is that your draft seemed to preclude using type 7
testing if it says NRC doesn't endorse the position on 8
the beyond design basis conditions, design extension 9
conditions. And so if you're not endorsing, if that's 10 the terminology, then I'm probably fine with it. I 11 just want to make sure I understand where we end up.
12 MS. RAY: Yes. Our reg guide is focused 13 on design basis, and so, in that case, you don't have 14 to do type testing for design extension severe 15 accident. However, you could do type testing to 16 demonstrate the functionality in severe accident 17 situations.
18 CHAIR ROBERTS: Okay.
19 MS. RAY: And the last thing is --
20 CHAIR ROBERTS: I had a comment just on a 21 related topic, you know, the EQ environment is defined 22 in Reg Guide 1.183, it's almost a severe accident 23 environment because it assumes, you know a design 24 release or a beyond design release into containment 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 and then, if the equipment was within a containment, 1
you have to go qualify it in that environment. It's 2
just getting you closer to a severe environment 3
anyway.
4 At least with NuScale, they've gotten, I 5
was calling it an exception, but a different approach 6
to the reg guide. They do not assume a release in the 7
containment for EQ, which kind of leads to another 8
question of, okay, so for equipment that does need to 9
survive that environment, you've lost the margin that 10 you would have by using the more severe environment.
11 I don't know if you're seeing more 12 applicants wanting to go the way of NuScale or whether 13 there was any, you know, generic change you're 14 thinking of making to more explicitly account for the 15 loss of margin in some other guidelines?
16 MS. RAY: I'm going to defer to my 17 colleague, Mr. McConnell.
18 MR. McCONNELL: Yes. Matt McConnell 19 again. Yes, your comment is taken, understood. I 20 wasn't involved with the NuScale review, but I 21 understand what you're saying with regard to the 22 assumed maximum hypothetical accident that need to be 23 considered. And I think, going forward, we apply 24 50.49 as it's written, and we take that to heart as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
42 far as what accidents need to be considered. We 1
clarified the guidance in Reg Guide 1.89 to what needs 2
to be met and what needs to establish the framework 3
for which needs to be established.
4 If you see 50.49(b)(1)(c), I believe it 5
is, basically, it discusses and says you must assume 6
the maximum hypothetical accident. So under those 7
circumstances, yes, the conditions could be quite 8
severe and, you know, those would need to be 9
considered. Hopefully, that answered your question.
10 CHAIR ROBERTS: Yes. I think that applied 11 design with that maximum hypothetical accident isn't 12 so bad, you know, compared to what's currently defined 13 in the Reg Guide 1.183, then that's justified for that 14 plant design, but that still now leaves, if you did 15 have a beyond design basis kind of event, then you 16 would have to meet the kind of requirements that are 17 on the slide that's displayed right now, the 18 50.155(b)(1) requirements, the requirements for 19 complementary design criteria in LMP, those types of 20 things.
21 It's just something to keep an eye on.
22 You kind of get that margin for free pretty much, but 23 you use a reg guide environment because it's so 24 severe. When folks get not necessarily exceptions 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
43 the rule but exceptions to the reg guide, obviously, 1
you don't have reg guides and regulations, so you have 2
to, you know, except the approaches that would stay 3
within the regulations.
4 So, again, I was wondering whether you're 5
looking at more globally more than just NuScale used 6
the less severe environment for the EQ environment, 7
whether there was something you would think about 8
putting out to mitigate that or whether what's already 9
there are sufficient.
10 MR. MORTON: This is Wendell Morton. This 11 is a matter of context for your question. Similar to 12 the VRLA reg guide we are going to be producing, as we 13 get more data points, we will be looking if we need to 14 make some adjustments to our guidance, as well. But 15 we do, on each of these designs, on a case-by-case 16 basis, we see a consistent theme as we've been going 17 through and we will adjust course or adjust our paths 18 accordingly, as a general position to follow through, 19 so thank you.
20 CHAIR ROBERTS: Okay. Thank you, Wendell.
21 MS. RAY: Lastly, on this DG, we removed 22 the word exceptions and referred to items as 23 regulatory positions.
24 So we're proud to share some of our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 upcoming work, and this first one is IEEE 1819 on 1
risk-informed categorization. The standard is being 2
revised, and the standard is expected to be published 3
in late 2026. The staff, including both electrical 4
and PRA, would consider endorsing the new revision of 5
IEEE 1819 in a new regulatory guide.
6 Additionally, on this similar topic, Reg 7
Guide 1.201 is under revision by DRA.
8 MR. BROWN: Can I ask a question? As you 9
said electrical and electric equipment. Is that now 10 springboarding into the reactor instrumentation 11 control and projection system world, or are you 12 talking about -- or is this IEEE standard dealing with 13 other stuff?
14 MS. RAY: I'm going to defer to my 15 colleague, Khoi Nguyen, who is actually on the working 16 group to revise 1819.
17 MR. BROWN: Well, it's really developing 18 the new reg guide, right?
19 MS. RAY: Understand. We have not started 20 the work on the reg guide because --
21 (Simultaneous speaking.)
22 MR. BROWN: Oh, the IEEE standard --
23 MS. RAY: Yes.
24 MR. BROWN: Oh, okay.
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45 MS. RAY: Khoi.
1 MR. NGUYEN: This is Khoi Nguyen, 2
Electrical branch in NRR. I'm the member of the 3
working group three program in the 1819. The working 4
group is currently working on the revision of the 1819 5
to include the guidance for electromag equipment 6
beside electrical equipment. There's not much 7
guidance on alternates beside how to characterize the 8
equipment to implement 10 CFR 50.69.
9 Does that answer the question?
10 MR. BROWN: Does it apply to electronic 11 equipment, like the reactor protection systems, or 12 not?
13 MR. NGUYEN: Yes, it does.
14 MR. BROWN: So we're going to risk inform 15 the design of reactor protection equipment, so it 16 doesn't necessarily have to work based on a PRA. I'm 17 being sarcastic a little bit there because when I turn 18 and twist, I expect something to start, stop, or 19 change state. When I tell a reactor to scram, I 20 expect it to scram, not maybe scram. I'm having a 21 little trouble, a little problem with the thought --
22 I'll wait until I guess I get to see the reg guide but 23 24 CHAIR ROBERTS: Let's back up with this a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 little bit. This is a process which already exists in 1
Reg Guide 1.201. There's a process for determining 2
what the risk significance is of various SSCs. A 3
reactor protection system, I think, would be a hard 4
sell, and we had a similar discussion this morning.
5 It will be a hard sell to come to a conclusion 6
anything but, you know, safety related, but you could 7
get there. But the goal with this discussion was 8
there is a Reg Guide 1.201 and I asked this here too, 9
because there was a meeting three years ago where the 10 IEEE spent the effort to kind of tailor the guidance 11 in 1.201 to electrical and electronic equipment, and 12 then industry came back and said we don't want it.
13 And so that's the last I saw when I pulled the thread, 14 so I was kind of curious where that currently is 15 because the IEEE obviously, you know, didn't agree 16 with that and said there was more discussion required 17 as to whether or not there was value added by 18 incorporating some of the thoughts that the IEEE 19 committee came up with into Reg Guide 1.201 or had Reg 20 Guide 1.201 reference it or whatever the right linkage 21 was. But at least at that time, industry didn't want 22 it.
23 And so the question, I want to understand 24 where that was, what the story was.
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47 MR. BROWN: I don't recall that the 16 1
years I was on the committee that we ever referenced 2
1.201 when you're designing the safety systems. It 3
was making sure they would work. So if you risk-4 informed it completely and you say I only need one 5
channel of scram protection and if it fails, that's 6
okay. That's even a little bit extensive. I'm being 7
sarcastic on --
8 CHAIR ROBERTS: So we had some hands up.
9 I think I saw Dennis. I can't see the hands right 10 now, but I think --
11 (Simultaneous speaking.)
12 CHAIR ROBERTS: Dennis, why don't you go 13 first, and then we'll go to the staff.
14 DR. BLEY: Yes. Dennis Bley. Charlie 15 always challenges me to say something. Whether you do 16 a risk analysis or not, your system may or may not 17 work, and there's plenty of history to tell us that, 18 Charlie. But I don't remember 1819 in any detail. Is 19 it consistent with the categorization and treatment 20 discussions in NEI 1804, the LMP? Because if it's 21 not, you're going to put somebody who is designing a 22 plant in a bind. What do they use?
23 MS. RAY: I think I might defer to Mr.
24 McConnell. He has his hand up.
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48 MR. McCONNELL: Yes. This is Matt 1
McConnell again. I don't know if I can answer 2
Dennis's question, but the intent, I believe, was to 3
avoid or minimize any potential conflict in guidance 4
that's out there. That's part of the reason why we've 5
kind of delayed the issuance of a reg guide in support 6
of 1819, but that's maybe a topic of another 7
conversation another day.
8 But I just wanted to kind of lay out and 9
build on the concept that 50.69 doesn't have 10 restrictions on what
- systems, structures, and 11 components could be applicable for the categorization 12 of treatment of equipment. So while it's highly 13 unlikely that a reactor protection system would fall 14 out of scope and allow you to take certain exceptions 15 to be categorized as Risk 3 and 4, I can't say without 16 a doubt that they would be. But that would be on a 17 plant-by-plant PRA basis and based on the 50.69 18 requirements on how the equipment is categorized under 19 their risk. Thank you.
20 DR. BLEY: Okay. Thanks. And I just 21 would, because people can now use 1804, which does 22 give guidance in this area, I hope the revision to the 23 standard and to your reg guide are at least consistent 24 with the guidance from the other document. Thanks.
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49 MR. McCONNELL: Yes. If I could follow 1
up. This is Matt McConnell again. I would say that, 2
yes, we are going to strive or consistency, and we 3
understand that there's existing guidance out there.
4 I think some of the challenges have been with some of 5
the equipment that's been allowed, say the Risk 3 and 6
4 equipment that is allowed exemption to the 50.49 7
environmental qualification requirements, but with the 8
understanding that the equipment, even though it no 9
longer needs to satisfy 50.49, that it still is 10 expected to perform its design function and that you 11 have to be careful to be able to satisfy common cause 12 in the PRA and ensure that the system structures and 13 components can still perform their function. Thank 14 you.
15 MR. MORTON: This is Wendell Morton. So 16 just to add some additional context to what Matt just 17 said, we will be working on this particular reg guide 18 in conjunction with our PRA experts themselves. We 19 have a few that were actually on the committee that is 20 overseeing this standard, and we will be working with 21 them or developing this reg guide to make sure the 22 relevance guidance is all consistent, to Matt's point.
23 So I'd like to give some additional context, as well, 24 that we're not developing this strictly in terms 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
50 electrical. We'll be considering alternate plans as 1
well.
2 DR. BLEY: That's really good. I 3
appreciate hearing that because, at times, electrical 4
has been a little in your own world compared to what 5
everybody else is doing.
6 MR. MORTON: Understood. We're in a new 7
world now. We appreciate that perspective. Thank 8
you.
9 CHAIR ROBERTS: Dennis, this question 10 started because one of the draft guides, I don't 11 remember which one, but I think it was IEEE 338, if I 12 remember right, has -- this IEEE 1819 is a required 13 reference that you have to use, and when I pulled the 14 string on that I found this, you know, three years ago 15 whereas I just stated, we wanted to use 1819. So, 16 again, I guess there's more discussion you have to 17 come with that draft guidance to whether the reference 18 is appropriate, and I think Dennis raises a great 19 question, which is, when you look at harmonizing 1819 20 and 1.201, is 1.201 harmonized with NEI 1804 and there 21 would be a discrepancy with what LMP would have you do 22 and what the reg guide would have you do. And that's 23 another thing that you might really look to get 24 standardized if there is a inverse. I don't know that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 there is. Certainly one's oriented towards 50.69 and 1
one is oriented towards new plants, so is there a 2
difference? I don't know that there needs to be, but 3
while we're thinking about --
4 MR. MORTON: A lot of those issues we're 5
going to be looking to actually develop the reg guide.
6 CHAIR ROBERTS: Okay. I think Khoi Nguyen 7
from the staff has his hand up.
8 MR. NGUYEN: Yes, this is Khoi Nguyen 9
again. So I would like to provide some history of the 10 development of the 1819. So the Reg Guide 1.201 11 endorsing NEI 0004 for our prioritization of the SSC 12 of the plant. However, NEI 0004 is lacking guidance 13 for categorization of the electrical and electronic 14 components. And IEEE 1819 provides details here.
15 However, in the last few years, the industry pushed 16 back on 1819 endorsement because of the concern of 17 conflict with NEI 0004. Since then, the IEEE has been 18 working with industry to address the industry concern, 19 mostly on the special treatment. And that we'll be 20 looking at in the next revision of the 1819.
21 For the question why Reg Guide 1.201 does 22 not endorse 1819 because the schedule for Reg Guide 23 1.201 is to the Reg Guide within the next year does 24 not support the new revision of 1819, so the staff 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 with the revision, or 1819 current within the schedule 1
or by the end of 2026 the staff may endorse and stand 2
that under a new reg guide. That's the reason why we 3
have two reg guides and the two different standards.
4 MR. BROWN: I know I'm kind of the outlier 5
in this, but so I will -- Tom knows very well that, as 6
long as they allow me to be a consultant on this 7
committee before formerly a member, I am particularly 8
sensitive to this. For 22 years, I was responsible 9
for, roughly, 140 nuclear power plants and all the 10 submarines. I was very concerned about not having 11 something work when you have 50 to 55,000 sailors in 12 submarines depending on your equipment to operate 13 continuously and still provide safe operation.
14 So I hate to be a thorn in the side of PRA 15 and risk informing, I know we're going to do it in 16 some areas. I don't disagree with it in some areas.
17 But to me, there's always certain specific reactor 18 protection safeguards and reactivity control systems 19 that have to be very, very carefully guarded so that 20 we don't make the wrong decisions when we're doing it.
21 So I'm not trying to be a thorn in the 22 side of progress, but, at some point, we have to look 23 at the safety systems and really be very careful how 24 you deal with them, regardless of your sensitivity 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
53 1.201, which I don't disagree with. I've seen it and 1
looked at it. There are places where it's useful, and 2
there are places where I won't say it won't be useful 3
because we always use engineering judgment in some 4
places. If I'm allowed to speak, you will always have 5
somebody else willing to talk about an alternate 6
thought process. And some of the members here 7
remember that.
8 MS. RAY: We appreciate the comment. The 9
staff is fully committed to safety and --
10 MR. BROWN: I'm not questioning your 11 commitment to safety.
12 MS. RAY: I understand.
13 MR. BROWN: I have great respect for all 14 the staff members I've worked with over the last 17 -
15 18 years, so I have no problem with that.
16 MS. RAY: We look forward to your comments 17 on the reg guide when we finish it.
18 MR. BROWN: All right. Thank you.
19 MEMBER DIMITRIJEVIC: This is Vesna. I 20 just want to summarize something which was already 21 said here but just for Charlie, you know. Reg Guide 22 1.201 supports the 10 CFR 50.69, which gives the same 23 risk-informed categorization. So 121 supports the 10 24 CFR 50.69, and there is also difference between those 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 two guidance in the scope because IEEE Standard 1819 1
is just for the electrical equipment, you know, the 2
201 is for all SSCs.
3 I just was summarizing something because, 4
you know, it's not just the Reg Guide 1.200. I mean, 5
that's a priority of the 10 CFR 50. Okay.
6 CHAIR ROBERTS: Okay. Thanks, Vesna.
7 MS. RAY: So on more upcoming work, Lily 8
had alluded to a new reg guide on valve-regulated 9
lead-acid batteries. Given several applications 10 utilizing this technology, as well as industry 11 comments to provide guidance on other battery 12 technologies, we're working on this new reg guide.
13 And this new reg guide would endorse with 14 clarifications IEEE 1187 and 1188.
15 So these IEEE standards, as Lily 16 mentioned, are under revision right now and are 17 expected to be issued shortly. And, therefore, the 18 staff's draft guide is expected by the end of 2025.
19 Consistent with our vision and strategy, this reg 20 guide endorses new technologies in line with the 21 ADVANCE Act.
22 Also on batteries, staff is developing a 23 revision to Reg Guide 1.158 on the qualification of 24 safety-related vented lead-acid batteries. This reg 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
55 guide revision would endorse the latest IEEE 535 1
published in 2022. And the DG is expected in the 2
summer of 2025. This is an example of the staff 3
updating guidance in a timely manner to ensure the 4
latest guidance is available to licensees and 5
applicants.
6 Also of committee interest, Reg Guide 1.9, 7
we worked on this a number of years ago, and work has 8
now resumed. The diesel standard was revised late 9
last year and is now a joint logo standard, meaning 10 IEEE and IEC. Therefore, the staff has resumed work 11 on Reg Guide 1.9 to endorse clarifications to 12 standards on diesel generators and combustion gas 13 turbines. This is an example of implementing our 14 vision and strategy of combining related standards on 15 a technical topic into one reg guide on standby power 16 supplies. Yes.
17 MR. BROWN: We reviewed this back in 2021 18 or so, and we wrote a letter which you all responded 19 to and then a second respond which said you were 20 deferring for catchup, whatever, you know, because of 21 other work. And I noted the difference here. The Reg 22 Guide 1.9 that you presented to us covered three 23 areas. One was diesels, one was safety combustion.
24 The first item, C1, was other anticipated power 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
56 sources which was the source of most of our, was the 1
most critical comment we made. You don't even mention 2
that. Does that mean you're deleting C1 out of the 3
reg guide or you're going to do something additional 4
with it or not?
5 MS. RAY: I am going to defer to my 6
management, Tania.
7 MS. MARTINEZ NAVEDO: Tania Martinez 8
- Navedo, acting Director for the Division of 9
Engineering and External Hazards. Right now, are 10 discussing how to reinsert that piece in the reg 11 guide.
12 MR. BROWN: C1?
13 MS. MARTINEZ NAVEDO: Yes.
14 MR. BROWN: You're taking it out right 15 now?
16 MS. MARTINEZ NAVEDO: No. We are actually 17 keeping it because we are evaluating if we're going to 18 keep it because it would be consistent with the new 19 mission of the NRC as we're working on enabling new 20 technologies. So based on some of the conversations 21 with folks in the industry, this might be appropriate 22 to lay out clear criteria they can follow if they want 23 to use any other type of equipment outside of the EDG 24 and the GGG equipment.
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57 MR. BROWN: I didn't want you to think 1
because we made that comment that we disagree with 2
that. The problem was that, when you looked at the 3
diesels and the combustion turbine generators, the 4
performance requirements were laid out for each of 5
those components in terms of what they had to deal 6
with in the electric plants and how those plants 7
responded in, like, load demands, harmonics, when 8
you're going to alternate -- the vision here is 9
windmills, okay, or solar because if you're going for 10 the 145 acres of solar on your plant, in addition to 11 the 17 in a nuclear power plant, including the 12 diesels, you've got to be mindless if you want to do 13 that, including the battery you'd have to deal with 14 it. It would take a lot of real estate.
15 But if you did, developing all your plant 16 loads, diesel generators become combustion turbine 17 generators. The generators, they look like what they 18 have to supply in the plants. They have harmonic 19 performance. They have load demand, which you can put 20 on them immediately. There will be covering time.
21 When they put on a high load, it has to be within a 22 time frame where everything doesn't drop off. Doing 23 that with electronics, solar power, batteries, is 24 very, very difficult, and my problem with it when we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 wrote the letter was there was, basically, no 1
identification of what the alternate power sources' 2
performance would have to be. So that was the 3
concern.
4 I just wanted to make it clear that, at 5
least in my opinion -- I can't speak to the committee 6
now but what the committee accepted at that time was 7
the lack of definition of what those alternate systems 8
would have to be designed to meet. And I don't mean 9
the detailed design. We're not trying to tell them 10 how to design the systems but the basic functional 11 performance so that they'd be compatible with existing 12 plants, or even the new plants, the advanced plants, 13 are all going to have conventional electrical 14 components and systems in them. They may have 15 different coolants, they may have different other 16 stuff, but the plants themselves are electrical stuff.
17 And it was totally wiped out. And the other two 18 components, there were very clear definitions of what 19 their performance requirements were in order to meet 20 this, the normal schedule.
21 So I'm just trying to clarify that don't 22 take my comments negatively. It's just a matter of 23 ensuring we make them compatible with what we required 24 for the other components, as well, and to let you know 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
59 that I've done a lot of heavy-duty electronic stuff, 1
and it is very difficult to get the harmonic 2
performance that you want. It's just going to have to 3
be addressed. I'm not asking for an answer. It's 4
just we have to know how to address it before we go 5
forward; that's all.
6 MS. MARTINEZ NAVEDO: And I appreciate it.
7 This is Tania Martinez Navedo again. I appreciate 8
that feedback and that clarification. Basically, what 9
we were trying to do is to align the criteria with 10 what is in GDC 17 capacity, availability, reliability 11 and so forth, not centered on a particular technical, 12 you know, particular component.
13 The reason why we are trying to propose 14 this is that when we worked on the gas turbine 15 generators as the emergency power source for a newer 16 reactor design in the past, like US-APWR, it took the 17 staff a sizable amount of hours to try to come up with 18 an ISG and guidance that could support the review of 19 that particular, you know, piece of equipment. At 20 that point, there was no IEEE standard for gas 21 turbines.
22 There was some operating experience out 23 there, not in nuclear, but there was some that we 24 could leverage. But what we want to do is pave 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
60 way to the staff to do a review with at least some set 1
of criteria they can use to review but, at the same 2
time, tell potential applicants this is how you can 3
write a footprint for your Chapter 8, even if you 4
assigned something different than EDGs and GGGs.
5 That's the real reason why we were trying to draft a 6
new reg.
7 MR. BROWN: I was here when did the US-8 APWR, and the CTG was an issue we had to deal with.
9 But the difference is the inertia in diesels is 10 totally different from the rotating inertia of a 11 combustion turbine generator; and, therefore, could 12 they be relied on. One of the issues was could they 13 be relied on to respond appropriately for what the 14 plant needed, and you all struggled with that.
15 MS. MARTINEZ NAVEDO: We did, but we were 16 able to --
17 MR. BROWN: You got through it.
18 MS. MARTINEZ NAVEDO: -- put together an 19 ISG, and we have some guardrails that help both the 20 reviewers, as well as the applicant, in continuing to 21 provide the necessary information for a reasonable 22 assurance finding.
23 MR. BROWN: All right. I'm just trying to 24 clarify the nature of what the context of our comments 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 was when we wrote the letter three years ago, four 1
years ago now, I think. Thank you. Sorry to take up 2
your time. I'm not sorry.
3 (Laughter.)
4 CHAIR ROBERTS: Okay. It sounds like 5
staff understands what the letter was getting at and 6
they're still working through what the appropriate 7
level of specificity is for the reg guide to cover 8
things that, clearly, are not going to be covered in 9
detail, just to give the applicant as to what they 10 need to cover. So we look forward to seeing that in 11 the fall.
12 MS. RAY: Okay. So in addition to 13 regulatory guide activities, staff continues to align 14 with the Commission PRA policy. Specifically, with 15 the NuScale review, we applied a risk-informed graded 16 approach to evaluate DC systems. Other examples 17 include the potential endorsement of 1819, which we 18 discussed and also open-phase the risk-informed 19 option. And we'll be talking about BTP 8-9 in a later 20 slide.
21 Slide 29. Other examples where we are 22 fully aligned with Commission PRA policy is license 23 amendment requests on tech spec task force travelers, 24 10 CFR 50.69, and tech spec completion times. In all 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 of these reviews, the staff uses PRA methods and data 1
to complement the NRC's deterministic approach and 2
support traditional defense-in-depth philosophy.
3 Slide 30. Staff is working on a revision 4
to Reg Guide 1.118 on periodic testing to endorse IEEE 5
338. We received ACRS comments noting the paragraph 6
in the background section on 50.155 was useful, so we 7
have added it to other reg guides. In addition, the 8
comment of IEEE 338 references risk-informed 9
categorization; and, thereby, that will also inform 10 our new reg guide to endorse 1819.
11 Slide 31. Based on lessons learned with 12 license amendment requests and closing out the 13 bulletin on open phase, staff is revising the guidance 14 in two branch technical positions, as listed here.
15 This is part of our effort to update guidance 16 documents and incorporate risk-informed performance-17 based methods.
18 We routinely review operating experience 19 on electrical and environmental qualification. We 20 work with the Operating Experience branch to identify 21 trends, and the review of operating experience informs 22 the reg guide process such that revision should be 23 initiated based on significant operating experience 24 where the priority could be modified. Lastly, during 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 our participation with IEEE, NRC staff shared public 1
information on operating experience to inform the 2
development of standards.
3 We also work with other federal agencies 4
and entities regarding the grid and grid events. For 5
example, we restarted quarterly meetings with FERC 6
and, most recently, in January, discussed Blackstart, 7
Texas winter storms, and the quantified risk of LOOPs 8
and station blackout. During severe weather events, 9
such as hurricanes and flooding, we expertly work with 10 NERC to understand the grid condition and any expected 11 impacts to nuclear facilities. We lead and support 12 biannual joint commission meetings with FERC where 13 NERC also participates. This coordination with FERC 14 and NERC strengthens our knowledge on the grid status 15 and any potential impacts to nuclear.
16 We also are very active in the 17 international arena. First, we participate in the IEC 18 and assist in the development of international 19 standards. Some successes include the joint logo 20 standard on environmental qualification as endorsed in 21 Reg Guide 1.189, the joint logo standard on diesel 22 generators, and the joint logo standards on the 23 condition monitoring of cables.
24 Other standards on grid coordination are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 valuable as NPP designers may use them in U.S.
1 licensing. Some applicants are adopting international 2
standards in their design, and NRC's participation 3
ensures U.S. perspectives in operating experience are 4
considered.
5 Slide 35. We also participate in the 6
Nuclear Energy Agency's WGELEC, the Working Group on 7
Electrical Power Systems. This critical exchange of 8
information and experience assists in our shared 9
understanding and recommended solutions. This 10 information supports our licensing work, as well as 11 reg guide development.
12 Regarding IAEA activities, we're currently 13 participating in two projects: one on the revision of 14 a report on electric grid reliability and the 15 interface with NPPs to specifically address SMRs. In 16 addition, we participate in the updated IGALL for 17 license renewal activities.
18 This past summer, we proudly hosted seven 19 Polish experts over four weeks to exchange information 20 on AP1000 electrical
- systems, environmental 21 qualification, and inspections. The highly-successful 22 collaboration was significant for Poland for the 23 construction, licensing, and inspection of their 24 future NPPs.
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65 As part of the Romania bilateral 1
cooperation, electrical staff supported in-depth 2
discussions on environmental qualification and DC 3
systems. In addition, we routinely respond to 4
information requests from other countries on 5
electrical topics.
6 CHAIR ROBERTS: In general, are you 7
learning, you know, from the international community?
8 And I guess the opposite of that is are they learning 9
from you?
10 MS. RAY: Yes. It is definitely mutual 11 understanding and shared information. Poland does 12 things a little bit differently. They separate out 13 the technical and the inspection, and some of their 14 questions were very insightful for us, as well.
15 CHAIR ROBERTS: Do you have any examples?
16 MS. RAY: It's interesting how they review 17 the electrical systems. They're very much looking at 18 very specific design details that, as of right now, we 19 don't have access to. For example, very specific 20 calculations that maybe, like, Westinghouse would have 21 done, they're going to the depth of that level, 22 whereas we would
- more, we would audit some 23 calculations, we may look at summaries of calculations 24 where it seems -- since they're new, they're applying 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
66 their licensing experience to other technologies to 1
nuclear, and it seems they're looking a little bit 2
more pointedly at the calculations. And I think 3
that's just their regulatory structure.
4 MR. MORTON: This is Wendell Morton. I 5
can contribute a little more to that, as well, Sheila.
6 So one of the big things during their visit was, 7
obviously, comparing different regulatory models that 8
they observed trying to develop their own and coming 9
here to the NRC and learning how we do our business.
10 So a lot of their questions were along the lines of 11 how we do certain things in terms of audits, 12 inspections and licensing; the level of depth that we 13 are able to go to in the system meets all the 14 requirements. There were a lot of exchanges and 15 conversations along those lines: how do you guys do 16 this, how does the NRC do this, how do we approach an 17 inspection in a granular way or how do you approach 18 your licensing for this particular housing.
19 So there were a lot of questions about, 20 like, trying to understand how we do our business, as 21 well as the framework itself. So part of that, a lot 22 of part of it is just educate them on how we do our 23 business and then giving them samples of what we do 24 during our business in terms of licensing, inspection, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 and even support, things of that -- to Sheila's point, 1
they are differently structured than we are, so there 2
are some questions that are just apples and oranges.
3 We just do things differently.
4 CHAIR ROBERTS: Okay. Thank you.
5 MEMBER HALNON: One question before you 6
get into your summary. I just, I know we love our 7
SMRs and discussions we're having, one of the 8
strategies --
9 (Audio interference.)
10 MEMBER HALNON: -- are you doing any 11 studies or working with research on the impacts of the 12 following on your quick plants?
13 MS. RAY: Something that's been discussed 14 a number of times. We don't have any ongoing items on 15 load following.
16 MEMBER HALNON: I mean, it does have 17 impact all the way through the system. You know, it 18 can be done on an application-by-application specific 19 case, but that operating strategy may not be thought 20 of, much like our light water reactors were thought of 21 when we first built them and then they discounted it 22 because of wear and tear, if you will, and make it 23 simple. Now they're talking about doing it again, and 24 there is some studies going on I know NuScale was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 looking at for a while, as well.
1 So it would be interesting to see if 2
there's any more that we might be able to gain from 3
that, again, especially with --
4 (Audio interference.)
5 MS. RAY: In our international activities, 6
we are gathering information on islanding and, 7
therefore, we're gathering some information on load 8
following. I believe my colleague, Matt, had his hand 9
up.
10 MR. McCONNELL: Yes. This is Matthew 11 McConnell, senior electrical engineer. Just to 12 follow-up with that, yes, we're aware of the potential 13 need and desire to become and operate more in a load-14 following manner. Actually, a few years ago, I was 15 aware that there were several plants in the Midwest 16 that were actually operating in that manner, and I do 17 understand the potential impacts on not only just 18 equipment in general but also in the qualification 19 equipment when you talk about increased cycling and 20 also how we structure our technical specifications.
21 So our ear is firmly to the ground to hear what path 22 and what route the industry is going to follow with 23 that, and we will definitely pursue that as necessary.
24 MEMBER HALNON: Thank you, Matt.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 MS. RAY: So as you can see, we're very 1
busy. So of note, electrical staff work on all 2
electrical and environmental qualification aspects of 3
licensing projects for operating reactors, new 4
reactors, as well as other nuclear facilities. We 5
continue to align with the ADVANCE Act and the 6
Commission PRA policies.
7 Our reg guide strategy is timely such that 8
we make efforts to endorse the latest standard and 9
include risk-informed performance-based methods. Our 10 cooperation with FERC and NERC is instrumental in 11 understanding grid status and any impacts to nuclear.
12 And, lastly, we continue to engage our international 13 counterparts to inform NRC's mission objectives.
14 We really appreciate your time and 15 attention. Any questions?
16 MR. BROWN: I guess I can't stop. And 17 this is tackling Reg Guide 1.9 again. One of those 18 things we didn't talk about in our letter, if you look 19 at the potential alternate sources, you mention two of 20 them: wind and/or solar. And, obviously, you could 21 put a giant battery at the plant which you keep 22 charged all the time and it would last for some amount 23 of time before you bought something else in, although 24 that would be a risk-informed design decision if you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
70 couldn't recharge it from the plant itself concurrent 1
to the 110. But these other alternatives, other than 2
diesels or combustion turbine generators, some of them 3
involve weather conditions external to the plant.
4 Whatever we do with the reg guide has to somehow 5
communicate that external plant conditions, such as 6
weather or weather impact, and how they could either 7
impact negatively, permanently negatively depending on 8
how long they lasted, so I think weather enters in, 9
whereas with the diesels and combustion turbine 10 generators, you just got to keep the gas tank full.
11 MS. RAY: Actually, I agree with you. We 12 do include those aspects in both gas turbine and 13 diesel standard. Let me finish.
14 MR. BROWN: Go ahead. I'm sorry. I was 15 biting my tongue.
16 MS. RAY: Oh, sorry. On tornado 17 depressurization.
18 MR. BROWN: Right.
19 MS. RAY: So that aspect on what's going 20 on outside has to be considered, and my personal 21 opinion is, yes, that has to be included in the 22 generic section, as well.
23 MR. BROWN: Okay. But as well as in the 24 C1 --
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 MS. RAY: Yes, absolutely, yes, yes.
1 MR. BROWN: -- if that's what you call a 2
generic. There's a large discussion, which is very 3
good, in the beginning of the whole thing which just 4
talks about the application, et cetera. That's a very 5
complete, comprehensive discussion. It was when we 6
got to the other pieces that I had the difficulty.
7 But I did not mention weather type 8
situations in our letter. We were complex enough as 9
it was, and I think the committee probably helped me 10 lighten it up a little bit so it wasn't quite as 11 complex.
12 MS. RAY: We appreciated the comment. We 13 also appreciate the comment that the beginning section 14 was comprehensive. That's very appreciated to know 15 that it's helpful.
16 MR. BROWN: Yes. This wasn't all 17 negative.
18 CHAIR ROBERTS: Okay. Any other comments 19 or questions for the staff? I just want to offer that 20 I really appreciated this integrated presentation 21 because what we see from you all is a lot of reg 22 guides, and it's kind of hard sometimes to see how 23 they all fit together, and I wanted to bring up a 24 couple of big points I got out of this session. One 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
72 is you are looking at environmental qualification 1
globally and what that means in terms of more 2
applicants; and if NuScale were to come up with a 3
different approach, you've got your eye on that.
4 Looking at how to account or cover the beyond design 5
basis experience or concerns, so you are looking at 6
that. New technologies you're looking towards.
7 You're looking at how to more risk inform, you know, 8
what you've got in terms of your guidance out there.
9 So you have those reg guides and your successful 10 interface with both domestic and international 11 agencies.
12 So it was very good to get an integrated 13 picture in what you all are doing. I just wanted to 14 thank you for putting it together, and I'm sure we'll 15 have more discussions on those reg guides as they come 16 through, but we got a good global understanding of 17 what you're working on.
18 So with that, there's no comments from the 19 public. Oh, sure. It's time for public comments. If 20 there's anybody, a member of the public, would like to 21 make a comment, please go ahead and raise your hand in 22 Teams. I don't if there's any public in the room but 23 if you'd like to make a comment, go ahead and raise 24 your hand, and then, you know, unmute yourself 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
73 state your comment. So I'll wait about ten seconds.
1 (Pause.)
2 CHAIR ROBERTS: Okay. Since there are no 3
apparent issues in making a public comment, I'll go 4
ahead and close the meeting if there are no other 5
last-minute observations.
6 Okay.
With
- that, the meeting is 7
adjourned.
8 (Whereupon, the above-entitled matter went 9
off the record at 2:36 p.m.)
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
ACRS: Electrical Engineering Briefing March 20, 2025 Wendell Morton Liliana Ramadan Sheila Ray
Opening Remarks Wendell Morton
Acronyms BL - Bulletin BTP - Branch Technical Position CFR - Code of Federal Regulations DG - Draft Guide EDG - Emergency Diesel Generator EE - Electrical Engineering EQ - Environmental Qualification FERC - Federal Energy Regulatory Commission GDC - General Design Criteria IAEA - International Atomic Energy Agency IEC - International Electrotechnical Commission IEEE - Institute of Electrical and Electronics Engineers NEA - Nuclear Energy Agency NERC - North American Electric Reliability Corporation PRA - Probabilistic Risk Assessment RG - Regulatory Guide SRP - Standard Review Plan Std - Standard TSTF - Technical Specification Task Force 3
Agenda Opening Remarks Overview of Electrical Engineering (EE) & Environmental Qualification (EQ) regulations Licensing EE & EQ activities in operating reactors, new and advanced reactors, small modular reactors, license renewal, & research projects Open Phase Regional Coordination Infrastructure
- DG-1427 public comment resolution/status
- RG 1.9 Status 4
Agenda, cont.
Infrastructure, cont.
- Continued Alignment with Commission Probabilistic Risk Assessment (PRA) Policy
- Risk-informed graded approach - NuScale review
- Technical Specification Task Force (TSTF) 505 license amendment requests
- Open Phase Condition (risk-informed option)
- Potential endorsement of IEEE Std. 1819
- DG-1438 questions
- Standard Review Plan Status
- Operating Experience Federal Energy Regulatory Commission (FERC) and North American Electric Reliability Corporation (NERC) Coordination International Activities 5
Staff & Contributors Electrical Engineering Branch (NRR/DEX/EEEB)
- Wendell Morton, Branch Chief
- Lauren Bryson, Adakou Foli, Vijay Goel, Kayleh James, Nadim Khan, Edmund Kleeh, Khoi Nguyen, Liliana Ramadan, Sheila Ray Long Term Operations and Modernization Branch (NRR/DEX/ELTB)
- Patrick Koch, acting Branch Chief
- Jorge Cintron, Brian Correll, Matthew McConnell, Kenneth Miller Instrumentation, Controls, and Electrical Engineering Branch (RES/DE/ICEEB)
- Calvin Cheung, acting Branch Chief
Overview of Pertinent Regulations Electrical Engineering 10 CFR 50, Appendix A, General Design Criteria (GDC)
- GDC 17, Electric Power Systems
- GDC 18, Inspection and Testing of Electric Power Systems Environmental Qualification 10 CFR 50, Appendix A, GDC 4, Environmental and Dynamic Effects Design Bases 10 CFR 50.49, Environmental qualification of electric equipment important to safety for nuclear power plants License Renewal 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants 7
REGULATIONS 10 CFR Part 50:
50.34, 50.49, 50.55(a)(h), 50.63, 50.65, 50.69, 50.71, GDC 2, GDC 4, GDC 5, GDC 17, GDC 18, GDC 50, App. B 10 CFR Part 52 (New Reactors)
Proposed 10 CFR Part 53 (Advanced Reactors) 10 CFR Part 54 (License Renewal)
Licensing: Operating Reactors
- Operating Reactors
- License Amendments, Notice of Enforcement Discretion, Allegations, etc.
- Regional Coordination EE Counterpart Meeting with NRR, RES, Regions for technical discussions and dialogue Inspection support 8
Licensing: Open Phase Condition What is an open phase condition (OPC)?
- OPC is defined as the open circuit of one or two of the three phases of any offsite power circuit required for normal operation of electrical systems.
What are the consequences?
- The 2012 operating event at Byron Station (ML12272A358) revealed a significant design vulnerability issue
- OPC in the plants offsite power supply will cause a common cause failure of AC electric power system
- Loss of safety functions of Engineered Safety Features
- Both offsite and onsite electric power systems were not able to perform their intended safety functions due to the design vulnerability 9
Licensing: Open Phase Condition Past operating experience involved offsite power supply circuits that were rendered inoperable by an open-circuited phase, and the condition went undetected for several weeks because offsite power was not aligned during normal operation and the surveillance procedures, which recorded phase-to-phase voltage, did not identify the loss of the single phase.
How was OPC addressed?
- Detection, automatic trip response, and alarm in main control room
- Risk-informed option - perform a risk evaluation under certain boundary conditions to support an alarm and manual response to an OPC 10
Licensing: Open Phase Condition NRC Actions Following the Byron event
- July 2012 - Issued Bulletin 2012-01: Design Vulnerability in Electric Power System
- February 2013 - Summary Report - Documented the review of licensee responses and staff recommendations
- March 2017 - SRM-SECY-16-0068 directed staff to verify licensees implementation and update the Reactor Oversight Process to provide periodic oversight of industrys implementation of OPC initiative
- November 2016 - Issued Temporary Instruction (TI) 2515/192, Inspection of the Licensees Interim Compensatory Measures Associated with the Open Phase Condition (OPC) Design Vulnerabilities In Electric Power Systems.
11
Licensing: Open Phase Condition
- NRC Actions Following the Byron event, cont.
- August 2020 - Issued Revision 2 of the TI 2515/194, Inspection of the Licensees Implementation of Industry Initiatives Associated with the Open Phase Condition Design Vulnerabilities in Electric Power Systems to verify that licensees have appropriately implemented the voluntary industry initiative
- March 2023 - Completion of issuance of closure letters to licensees and Bulletin 2012-01 closure
- Current activities - Revision of BTP 8-9 (will be upcoming Revision 1) 12
Licensing: Advanced and Small Modular Reactors
- Advanced Reactors
- Terrapower Construction Permit Application
- Small Modular Reactors
- NuScale US460 Standard Design Approval 13
Licensing: Decommissioning &
Nuclear Facilities
- Decommissioning
- Peach Bottom Unit 1
- Request for Alternative Schedule to complete decommissioning activities
- Nonpower Production and Utilization Facilities 14
Licensing: License Renewal Initial License Renewal Clinton Comanche Peak Diablo Canyon Perry Subsequent License Renewal Browns Ferry Dresden Monticello North Anna Oconee Peach Bottom Point Beach Surry St. Lucie Turkey Point VC Summer 15
Licensing: Research
- Research Projects
- Valve-Regulated Lead-Acid battery technology
- Islanding
- Assessment of research efforts after the issuance of Expanded Materials Degradation Assessment (EMDA): Aging of Cables andCable Systems (NUREG/CR-7153, Volume 5)
- Future Focused Research on novel and innovative cable condition monitoring techniques 16
Licensing: Environmental Qualification (EQ)
- Licensing of new reactors, advanced reactors and small modular reactors
- Increased Enrichment of Conventional and Accident Tolerant Fuel Extended power uprates and refueling frequency (PWRs).
Potential impacts to EQ design inputs such as radiological dose, pressure, temperature, etc.
17
Infrastructure: IEEE participation NRC staff provide technical expertise and offer technical insights to present agency positions for potential inclusion in standards and development of high-quality standards Under the IEEE Power and Energy Society, NRC staff participate in:
- Nuclear Power Engineering Committee
- Energy Storage and Stationary Battery Committee
- Power System Relaying and Control Committee
- Power System Communications and Cybersecurity Committee
- Insulated Conductors Committee
- Transformers Committee 18
Infrastructure: Vision & Strategy of EE Regulatory Guidance Inline with ADVANCE Act, Leverage Action Plan for Enhancing NRCs Codes and Standards Program for Future Reactors Focus on the agency mission and regulatory requirements when determining if an RG is needed or requires updating Represent a technically acceptable approach for allowing licensees, manufacturers, vendors, and NRC staff to effectively navigate and use regulatory guidance Prevent the ad hoc approach of generating additional regulatory guidance documents Gather and analyze operating experience Applicable to licensees and applicants subject to 10 CFR Parts 50 & 52 19
Infrastructure: Vision & Strategy of EE Regulatory Guidance Ensuring new RGs or revisions of RGs are aligned Commission PRA Policy and providing risk informed and performance-based methods Combine related standards on a technical topic into one RG Reduced staff hours as compared to updating and maintaining several RGs Reduced costs as compared to updating and maintaining several RGs Technical Efficacy - Generates efficiencies such that industry/users have a one-stop shop on NRC positions on a particular topic Process Efficiency - review process is streamlined for one RG on a technical topic (i.e., one public comment period on a technical topic)
Updates to a combined RG endorsing several standards would only be considered when there are significant changes that impact the staffs position or provide additional clarifications 20
Infrastructure: EE RG Checklist
- The EE RG Checklist was developed to improve and increase process efficiency
- Regulatory Guide and Programs Management Branch (RES/DE/RGPMB) owns the RG process
- EE RG Checklist provides an overview of the process and outlines actions to prepare a DG and publish the final RG
- Incorporates insights from staff and management, share the lessons learned to help improve the development process 21
Infrastructure: DG-1427
- DG-1427, Qualification of Fiber-Optic Cables, Connections, and Optical Fiber Splices for Use in Safety Systems for Production and Utilization Facilities. ML24201A068
- Issued Oct 2024 to endorse, with clarifications, IEEE Std. 1682-2023, IEEE Standard for Qualifying Fiber Optic Cables, Connections, and Optical Fiber Splices for Use in Safety Systems in Nuclear Power Generating Stations.
- Public comments received and staff is addressing them to issue the final RG in Spring 2025.
22
Infrastructure: DG-1427 ACRS comments in ACRS Planning & Procedures Portion of the October 2024 Full Committee Meeting
- Related to the qualification for severe accident
- Added paragraph in Background on 10 CFR 50.155(c)
- Equipment relied on for the mitigation strategies and guidelines required by 10 CFR 50.155(b)(1) must have sufficient capacity and capability to perform the necessary functions.
- Type testing could be used to demonstrate the capability of equipment to perform credited functions under extreme natural events or severe accident/design extension conditions.
- Identification of regulatory positions as exceptions was deleted.
23
Infrastructure: Upcoming RG Work
- Risk-Informed Categorization of Electrical and Electronic Equipment
- Staff is considering endorsement of the next revision of IEEE Std. 1819, IEEE Standard for Risk-Informed Categorization and Treatment of Electrical and Electronic Equipment at Nuclear Power Generating Stations and Other Nuclear Facilities in a new RG.
- The next revision of the standard is expected in 2026
- NRR/DRA is in the process of revising RG 1.201, Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to Their Safety Significance 24
Infrastructure: Upcoming RG Work
- Valve-Regulated Lead-Acid Batteries
- New RG to endorse the following standards, with clarifications:
- IEEE Std. 1187, IEEE Recommended Practice for Installation Design and Installation of Valve-Regulated Lead-Acid Batteries for Stationary Applications
- IEEE Std. 1188, IEEE Recommended Practice for Maintenance, Testing, and Replacement of Valve-Regulated Lead-Acid Batteries for Stationary Applications
- Expect to complete draft by end of 2025 25
Infrastructure: Upcoming RG Work
- Qualification of Vented Lead-Acid Batteries
- Revision of RG 1.158 Qualification of Safety-Related Lead Storage Batteries for Nuclear Power Plants
- To endorse, with clarifications, IEEE Std. 535-2022, IEEE Standard for Qualification of Class 1E Vented Lead Acid Storage Batteries for Nuclear Power Generating Stations
- Expect to complete draft by Summer 2025 26
Infrastructure: Upcoming RG Work
- Standby Power Supply Revision of RG 1.9 to include both emergency diesel generators and combustion gas turbines To endorse, with clarifications:
IEC/IEEE 63332-387:2024, Nuclear facilities --
Electrical power systems -- Diesel generator units applied as standby power sources IEEE Std. 2420-2019, IEEE Standard Criteria for Combustion Turbine-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations Expect to complete draft by Fall 2025 27
Infrastructure: Commission PRA Policy Alignment
- NuScale
- Risk-informed graded approach to evaluate the DC systems
- Potential Endorsement of IEEE 1819
- Open Phase, as previously discussed
- Risk-Informed Option
- Revision of BTP 8-9 28
Infrastructure: Commission PRA Policy Alignment License Amendment Requests
- TSTF-505, Provide Risk-Informed Extended Completion Times - Risk Informed TSTF Initiative 4b ML18183A493
- TSTF-585, Provide an Alternative to the LCO 3.0.3 One-Hour Preparation Time ML23065A085
- TSTF-439, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO ML051860296
- 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors
- Technical Specification completion time extension 29
Infrastructure: Continued Alignment with the Commission PRA Policy
- DG-1438, Periodic Testing of Electric Power and Protection Systems (Proposed Revision 4 to RG 1.118)
- ACRS comments noting the paragraph on 10 CFR 50.155
- Expect publication of DG-1438 in Spring 2025 30
Infrastructure: Standard Review Plan Status
- Branch Technical Position (BTP) 8-8, Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions
- BTP 8-9, Open Phase Conditions in Electric Power System 31
Infrastructure: Operating Experience
- Review electrical operating experience
- Participate in Technical Review Groups to identify trends
- Informs EE RG strategy
- Potential for generic communications
- Assist in standards development process 32
FERC/NERC Coordination
- FERC quarterly meetings
- Restart of information exchange on technical topics of mutual interest
- Met in January 2025 to discuss Blackstart, Texas Winter Storms, Quantified Risk of Loss of Offsite Power and Station Blackout
- NERC cooperation
International Activities
- International Electrotechnical Commission (IEC)
- Participate in development of international standards on EDG, battery, grid coordination, condition monitoring of cables, etc.
- As NPP designers participate in the world market, international standards have been used for design, operation and maintenance in US licensing
- Provide technical expertise, share operating experience, and offer technical insights to present agency positions for potential inclusion in standards 34
International Activities
- Nuclear Energy Agency (NEA)
- Participate in Working Group on Electrical Power Systems.
- Exchange of information and experience on the safety of electrical systems.
- Facilitate international convergence on safety issues related to the safety of electrical systems and, where practicable, seek to develop a shared understanding and recommend solutions on important issues.
- Allow prompt attention to evolving electrical plant events to share the lessons learned.
35
International Activities
- International Atomic Energy Agency (IAEA)
- Participate and author sections for the revision to Nuclear Energy Series NG-T-3.8, Electric Grid Reliability and Interface with Nuclear Power Plants to include information on the development, deployment, and oversight of small modular reactors
- Participate in the update of Safety Report Series No. 82, Revision 2, Ageing Management for Nuclear Power Plants: International Generic Ageing Lessons Learned (IGALL) 36
International Activities
- Poland
- The NRC and Polands nuclear regulator, the National Atomic Energy Agency (known as PAA), have a cooperation agreement.
- The cooperation included an exchange information on Westinghouses AP1000 electrical systems, offsite power, inspections, & EQ in Summer 2024.
37
International Activities
- Romania
- Bilateral cooperation for technical exchange &
regulatory information sharing
- Other countries
- Routinely respond to information requests on EDG, grid, and other technical topics 38
Summary
- Advance licensing projects on operating reactors, advanced reactors, small modular reactors and production and utilization facilities.
- Continued alignment with ADVANCE Act &
Commission PRA Policy.
- Initiate new and revised RGs based on up-to-date standards, operating experience, and risk informed and performance-based methods.
- Coordinate with FERC/NERC on the state of the grid and impact on nuclear.
- Engage international counterparts to inform NRCs mission objectives.
39
Thank you for your time and attention.
Questions?