ML23031A082
| ML23031A082 | |
| Person / Time | |
|---|---|
| Issue date: | 01/11/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2227 | |
| Download: ML23031A082 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Design-Centered BWRX-300 Subcommittee Open Session Docket Number: (n/a)
Location: teleconference Date: Wednesday, January 11, 2023 Work Order No.: NRC-2227 Pages 1-89 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 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 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 DESIGN-CENTERED BWRX-300 SUBCOMMITTEE 8 + + + + +
9 WEDNESDAY 10 JANUARY 11, 2023 11 + + + + +
12 The Subcommittee met via Teleconference, 13 at 2:00 p.m. EST, Joy L. Rempe, Chair, presiding.
14 15 COMMITTEE MEMBERS:
16 JOY L. REMPE, Chair 17 RONALD G. BALLINGER, Member 18 VICKI M. BIER, Member 19 CHARLES H. BROWN, JR., Member 20 VESNA B. DIMITRIJEVIC, Member 21 WALTER L. KIRCHNER, Member 22 GREGORY H. HALNON, Member 23 JOSE MARCH-LEUBA, Member 24 DAVID A. PETTI, Member 25 MATTHEW W. SUNSERI, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1 ACRS CONSULTANTS:
2 DENNIS BLEY 3 STEPHEN SCHULTZ 4
5 DESIGNATED FEDERAL OFFICIAL:
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 1 C-O-N-T-E-N-T-S 2 Opening Remarks 3 Joy Rempe . . . . . . . . . . . . . . . . . . . 4 4 Discussion of Memorandum of Understanding, 5 Memorandum of Cooperation, and Collaboration on 6 BWRX-300 (including major accomplishments, upcoming 7 activities, and joint reports) 8 Robert Taylor . . . . . . . . . . . . . . . . . 7 9 Donna Williams . . . . . . . . . . . . . . . . . 9 10 Michael Dudek . . . . . . . . . . . . . . . . . 36 11 Opportunity for Public Comment . . . . . . . . . 82 12 Discussion of Upcoming Activities, Including 13 Proprietary Schedules (Closed Session) 14 Member Discussion 15 Adjourn . . . . . . . . . . . . . . . . . . . . . 89 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 1 P-R-O-C-E-E-D-I-N-G-S 2 2:00 p.m.
3 CHAIR REMPE: Okay. My computer tells me 4 now it's 2:00 p.m. on the East Coast, so this meeting 5 will now come to order. This is a meeting of the 6 Advisory Committee on Reactor Safeguards' BWRX-300 7 Design-Centered Subcommittee.
8 I'm Joy Rempe, the chairman for this 9 meeting. Members in attendance are Ron Ballinger, 10 Vicki Bier, Charles Brown, Vesna Dimitrijevic, Jose 11 March-Leuba, Walt Kirchner, Dave Petti, Greg Halnon, 12 and Matt Sunseri. We're also being joined by our 13 consultants Dennis Bley and Stephen Schultz.
14 Mike Snodderly is the designated federal 15 official for this meeting.
16 Today the Subcommittee will discuss the 17 NRC staff's Memorandum of Understanding, Memorandum of 18 Cooperation, and Collaboration on BWRX-300 and other 19 activities with the Canadian Nuclear Safety 20 Commission.
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 the 24 regulations found in Title 10 of the Code of Federal 25 Regulations, Part 7. The Committee can only speak 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 1 through its published letter reports. We hold 2 meetings to gather information and perform preparatory 3 work for the support and deliberations at a Full 4 Committee meeting.
5 The rules for participation in all ACRS 6 meetings were announced through the Federal Register 7 on June 13th, 2019. The ACRS section of the U.S.
8 NRC's public website provides our charter, bylaws, 9 agenda, letter reports, and full transcripts of all 10 Full and Subcommittee meetings that are open including 11 the slides presented there.
12 The agenda for this meeting was posted there.
13 Portions of this meeting will be closed to 14 protect proprietary information and information 15 provided in confidence pursuant to 5 USC 552(b)(C)(4).
16 As stated in the Federal Register notice and in the 17 public meeting notes published -- posted to our 18 website members of the public who desire to provide 19 written or oral input to the Subcommittee may do so 20 and should contact the DFO five days prior to the 21 meeting if possible.
22 The communications channel has been opened 23 to allow members of the public to monitor the open 24 portions of this meeting and the ACRS now invites 25 members of the public to use the MS Teams link so that 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 1 it can also view slides and other discussion materials 2 during the open sessions. The MS Teams link 3 information was placed on the agenda on the ACRS 4 public web site and we did receive no written comments 5 or requests to make oral statements from members of 6 the public regarding today's session.
7 There will be an opportunity for public 8 comment during the meeting, however, and we have set 9 aside 10 minutes in the agenda for these comments from 10 members who are listening to the meeting if they 11 decide they would like to make a comment.
12 A transcript of the meeting is being kept 13 and it is requested that the speakers identify 14 themselves and speak with sufficient clarity and 15 volume so they can be readily heard. Additionally we 16 request that participants mute themselves when they 17 aren't speaking.
18 Before we begin with this meeting I want 19 to note that this topic came up during the review of 20 the BWRX-300 Topical Report, and during this meeting 21 we requested this briefing. And I want to thank the 22 staff for accommodating this request today.
23 So we'll now proceed with the meeting, and 24 I'd like to call on Rob Taylor of the Office of 25 Nuclear Reactor Regulations to begin his presentation.
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7 1 Rob?
2 MR. TAYLOR: Thank you, Joy. Good 3 afternoon, Chairman Rempe and Subcommittee members.
4 I'm Rob Taylor. I'm the Deputy Office Director for 5 New Reactors and have responsibility for the BWRX-300, 6 as well as other new and advanced reactor licensing 7 activities and our efforts in collaboration with the 8 Canadian Nuclear Safety Commission under the 9 Memorandum of Cooperation that you mentioned.
10 We're pleased to be here today to brief 11 you on an important effort related to our licensing of 12 SMRs and advanced reactors. The NRC has a bilateral 13 cooperation agreement with over 45 regulatory 14 counterparts that facilitate technical exchanges and 15 information sharing. We leverage these relationships 16 to enhance our ability to regulate the next generation 17 of reactors in the United States.
18 Today we will be discussing our 19 collaboration with our colleagues at the Canadian 20 Nuclear Safety Commission which provides a prime 21 example of the success of our international 22 cooperation on advanced reactors.
23 The NRC and CNSC have embarked on a first-24 of-a-kind effort to collaboratively perform safety 25 reviews of advanced reactor and SMR designs that are 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 1 expected to be constructed in both countries. The 2 goal of this effort is to gain efficiencies by making 3 joint observations on advanced technologies or by 4 identifying where different regulations -- or 5 differing regulations may result in different 6 regulatory decisions.
7 Since signing the Memorandum of 8 Cooperation in 2019 the NRC and CNSC have participated 9 in collaborative reviews of key technical and 10 regulatory topics and produced six joint products 11 related to SMR and advanced reactor designs. This 12 cooperation has enabled us to gain valuable insights 13 into the benefits as well as complexities associated 14 with joint reviews. These lessons learned will be 15 crucial in informing how these reviews could 16 potentially be completed with multiple parties 17 involved while also ensuring that national 18 responsibilities are preserved.
19 Today we'll discuss how the Memorandum of 20 Cooperation is implemented, the successes and 21 challenges we've encountered, and talk about the 22 current projects and future plans for collaboration.
23 In particular we'll discuss recently initiated 24 projects to collaborate on specific technical topics 25 for the BWRX-300 SMR, which is the focus of this 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 1 Subcommittee.
2 We see tremendous value in the 3 collaboration with CNSC and anticipate that the 4 groundwork that we're laying today in pre-application 5 cooperation will enable more effective license reviews 6 of the BWRX-300 and other designs in the future.
7 I'll now turn the presentation over to 8 Donna Williams who will walk us through the materials.
9 Thank you.
10 MR. SNODDERLY: You're muted, Donna.
11 MS. WILLIAMS: Apologize. I was muted 12 there.
13 I'm Donna Williams, Senior Project Manager 14 in the Office of Nuclear Reactor Regulation, with 15 responsibility for project management in the -- of the 16 CNSC-NRC MOC.
17 So the presentation today, I plan to 18 discuss how and why the cooperation with Canada was 19 initiated and how it's being implemented. We'll 20 discuss the products that have been developed, the 21 current work and how we identify projects for future 22 work.
23 Several advanced reactor and small modular 24 reactor designs are under consideration for licensing 25 in both the U.S. and Canada and the vendors are 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 1 actively involved in pre-application activities with 2 both regulators, however different regulations, 3 guidance and practices for licensing in Canada and the 4 U.S. can negatively impact the standardization of 5 these designs. It was anticipated that if the 6 regulators were able to jointly review aspects of the 7 design, it would maximize design standardization and 8 provide review efficiencies.
9 In 2019 the NRC and CNSC signed an 10 historic Memorandum of Cooperation to provide a 11 mechanism for joint reviews of these reactors. The 12 MOC represents an important step in both countries' 13 strong commitment to be more effective, efficient, and 14 timely in the reviews of next generation technologies 15 while continuing to achieve their individual safety 16 missions.
17 The benefits of this collaboration to the 18 NRC and CNSC are effective and efficient regulation 19 and enhanced risk-informed agile decision making. The 20 MOC allows for both regulators to retain sovereignty 21 in their licensing decisions while benefiting from the 22 other's expertise and experience.
23 CHAIR REMPE: Donna, this is Joy.
24 MS. WILLIAMS: Yes?
25 CHAIR REMPE: Before you go to the next 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 1 slide --
2 MS. WILLIAMS: Yes.
3 CHAIR REMPE: -- I have a couple of 4 questions. I think this is a great thing to be doing, 5 but I'm curious about how you will respond to 6 stakeholders if they give you a lot of questions about 7 how do you know that you've benefitted from this 8 collaboration? Do you have metrics that you're using 9 to try and demonstrate this was a good thing to do?
10 And if so, could you elaborate on what those metrics 11 are?
12 MS. WILLIAMS: We do have specific 13 metrics, but I see Mo is on here, so he may have some 14 thoughts on --
15 MR. SHAMS: Yes, I was going to assist 16 Donna. So this is Mo Shams. Chairman Rempe, thank 17 you. If I may I can support the response to that.
18 So 100 we're aligned with your thinking 19 and the stakeholders on that, to what degree this is 20 going to benefit what we're doing. And I think it's 21 not the easiest thing to particularly measure, but 22 it's not -- also it's not the hardest for us.
23 So we have particular attributes that we 24 can point to. I think the biggest one that we can 25 point to is the ability for one regulator to leverage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 1 what the other has done in the past and actually being 2 able to build on that and not particularly repeat and 3 produce duplication. And we're seeing that already as 4 we're going to tell you a little bit further down the 5 presentation on BWRX-300, particularly around the 6 fuel. So that's an area where we can point to an 7 efficiency right there.
8 Another element to it is it would probably 9 a little bit more tangible to the vendor than the 10 regulator, which is reaching more of a standardized 11 design that would work in both countries having 12 arrived to a common technical position on a certain 13 area and making the right adjustments to make that 14 design palatable for both sides. So that's an 15 intangible activity as well.
16 We try to hold ourselves very much to the 17 resources that we identify in a particular activity, 18 so we measure ourselves against that. Certainly we'll 19 try to make them as efficient as possible, but there's 20 certainly a degree of a learning curve and being able 21 to communicate on both sides the technical aspects or 22 share information.
23 So I would say it's a mixed bag of 24 specific numbers that we look at, which is resources 25 and whether or not we're meeting them and meeting our 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 1 schedules, as well as other intangibles that we see 2 that turn value, whether it's the standardization or 3 leveraging the other regulators' prior work.
4 MEMBER MARCH-LEUBA: Hey, Mohamed, this is 5 Jose March-Leuba. This is very interesting what you 6 said. Just so I can focus on the designs, can you 7 give me an example of a design that is not the 8 standard? I mean, what do you mean by a standardized 9 design in this particular case in U.S. and Canada?
10 MR. SHAMS: Sure. Sure. I would say 11 we're interacting now with the VA BWRX-300 design.
12 We're looking to interact with other designs as well.
13 I think the benefit that goes back to the 14 vendor is if they can get both regulators to say 15 perhaps the state of safety-related equipment are the 16 same for both sides, or the number of redundancies 17 that are needed for reactivity controls, or what have 18 you, satisfy both sets of requirements on both sides 19 of the border, that's what I meant by standardizing 20 the design, or at least keeping it consistent for that 21 vendor and for both countries. That's going to 22 facilitate construction, it's going to facilitate 23 manufacturing of equipment perhaps in one country 24 versus the other. And for them in my view it 25 facilitates deployment worldwide. So that was what I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 1 was pointing to when I said standardizing design.
2 MEMBER MARCH-LEUBA: Yes, but say for 3 example the U.S. requires three diesel generators and 4 Canada requires only two. If I was here this time I 5 would apply for three satisfies both regulators. But 6 are you thinking that through this collaboration we 7 can agree on a two-and-a-half solution at the 8 regulatory level? And obviously there are not two-9 and-a-half diesel generators, but see what I mean?
10 MR. SHAMS: I know. Something in between.
11 Yes. I want to say you could because there may be a 12 justification that the regulator that has three can be 13 satisfied with two-and-a-half with the right 14 justification because there are other attributes in 15 the design that compensate for the difference. But to 16 your point, clearly the obvious answer would be 17 provide the three and now we've covered both. But you 18 could ultimately get in a place where you can find 19 that two-and-a-half would satisfy, even two, but you 20 still would need potentially whatever legal instrument 21 that we would need to make the two work, which is an 22 exemption or some other sort of a legal instrument.
23 MEMBER MARCH-LEUBA: Yes, the point I was 24 -- that's not the point I was trying to make --
25 MR. SHAMS: Okay.
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15 1 MEMBER MARCH-LEUBA: -- but the point I'm 2 thinking of now is that if the solutions have been 3 design the plant with three so that you satisfy both 4 regulations, this particular MOU 21317/162122BU is 5 wasting our time, because GE can do that on their own.
6 So I do encourage that you guys try to find a two-and-7 a-half solution whenever possible. That should be a 8 goal of the MOU, right? Otherwise, if you want to 9 pick the three, they can do it without us.
10 MR. SHAMS: And it's a great point, and I 11 agree with you. And a good bit of the guidance that 12 we hold ourselves to as a group on both sides is look 13 at the differences between the two countries and the 14 regulations and guidance and determine if they're 15 particularly -- meaningful is -- may not be the right 16 word I'd like to use, but they're that critical or 17 that important or are they being addressed in a 18 different manner perhaps? On the surface like there 19 are differences, but there are other attributes within 20 the regulatory framework that captures the same ideas.
21 So to your point, searching for that two-and-a-half 22 solution. I agree with you.
23 CHAIR REMPE: So this is Joy and I 24 appreciate this discussion. And actually the last 25 comments were, Mo, where I was thinking this might be 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 1 a very useful exercise is understanding not only the 2 differences in the criteria and the methods to get to 3 those criteria, but the impact.
4 MR. SHAMS: Yes.
5 CHAIR REMPE: When I learned a different 6 language, I've actually learned more about my own 7 language. And I think the same thing would come from 8 this type of endeavor and it could be extrapolated to 9 other regulators in other countries. So it's not an 10 easy-to-quantify metric, but I think there's some 11 knowledge gained that should be emphasized. And 12 actually later in this -- your set of slides I wanted 13 to harp on that a bit -- point a bit more by one of 14 the other activities you've done where you looked at 15 the LMP versus the regulatory approach. Because I 16 think that that exercise could yield some more 17 benefits, and so I'm curious about that. But I think 18 knowledge gained is another important metric that 19 would help, you know, licensing future reactor sites.
20 MR. SHAMS: A hundred percent. And I 21 don't want to belabor this and take much more of your 22 time, but I couldn't express how much we're aligned in 23 the thinking on -- before we go into any comparison we 24 know it's going to be different. That's just probably 25 the more default answer than anything. It's probably 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 1 get out of it recognizing how the differences there 2 that are particularly critical, meaningful, and 3 practical? I like the word about that. And to what 4 degree that that impact can be mitigated to get to a 5 common solution. So we're in that -- and it's not the 6 easiest thing to get to, but certainly that's the line 7 of thinking that we're adopting here.
8 CHAIR REMPE: Thank you.
9 MR. SHAMS: Sure. Thank you.
10 Donna, back to you.
11 MS. WILLIAMS: All right. Thanks, Mo.
12 And thanks for the questions.
13 So this slide shows the structure and 14 responsibilities under the MOC. Prior to the MOC we 15 had an existing Memorandum of Understanding between 16 the NRC and CNSC that established a framework for the 17 exchange of many types of regulatory information.
18 Activities of the MOU are managed by a steering 19 committee composed of senior managers in both 20 agencies. The MOC specifically addresses advanced 21 technologies including small modular reactors.
22 A subcommittee was established consisting 23 of staff and management that are responsible for the 24 review of SMR and advanced reactor license 25 applications. Working groups of subject matter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 1 experts in each country are established to cooperate 2 on the specific aspects of a design or generic topic 3 and work plans are created to guide each of the 4 projects.
5 The MOC covers several types of projects 6 including pre-licensing engagement, licensing reviews, 7 and the sharing of science and research results.
8 Projects are established to cooperate on specific 9 aspects of the design or generic topic and work plans 10 are created to guide each project by identifying the 11 objective and scope of the project, the expected 12 outputs, the work process and schedule, points of 13 contact in each agency and external organizations that 14 would be involved. The work plans ensure that both 15 agencies are aligned in the expectations up front and 16 have committed the necessary resources to perform the 17 joint review.
18 In carrying out the collaborative reviews 19 NRC and CNSC staff can hold joint meetings with 20 vendors, participate certainly in audits, issue a 21 joint set of questions to the vendor applicant, and 22 provide training on licensing processes and technical 23 issues to each other. A working group of subject 24 matter experts carries out the plan and develops joint 25 products.
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19 1 We developed processes for collaboration 2 to administer this first-of-a-kind cooperation such as 3 protocols, checklists, templates, and desk guides.
4 For example, a communication protocol was developed to 5 ensure that communication activities are effectively 6 coordinated and managed. The protocol also provides 7 guidance on managing sensitive information including 8 appropriate security markings.
9 To date we've successfully testing the 10 process of collaborative reviews by issuing joint 11 products that meet all of the goals of the MOC. One 12 of the goals is to collaborate on pre-application 13 activities for designs under consideration in both 14 countries. Because NRC and CNSC are both in pre-15 application engagement with X-energy, GEH, and 16 Terrestrial, we focused on specific technical topics 17 for these designs for our first projects.
18 The first report that was issued concerns 19 the reactor vessel for X-energy's advanced reactor.
20 This report documents the collaborative review of X-21 energy's approach to code identification, assessment 22 selection, and the adequacy of the regulatory analysis 23 conclusions made in the code selection.
24 We also issued a report that documents the 25 results of the collaborative assessment of the method 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 1 for predicting the conditions inside the containment 2 vessel following a LOCA for the GEH BWRX-300 reactor.
3 Another product is the joint report 4 concerning Terrestrial Energy USA's white paper on 5 postulated initiated events for its integral molten 6 salt reactor.
7 The second goal of the MOC is the 8 development of shared review approaches to facilitate 9 regulatory reviews. In this area we issued a joint 10 report that documents the results of a broad overview 11 of NRC and CNSC regulatory frameworks and for the a 12 specific comparison of LMP-endorsed NRC Reg Guide 13 1.233 with the CNSC approach.
14 The findings in this report will support future 15 collaborative reviews by understanding the differences 16 in our approaches for licensing new reactors.
17 A third goal of the MOC is to collaborate 18 on research and development of regulatory positions to 19 address unique or novel technical considerations for 20 advanced reactors. In this area we've issued two 21 interim reports on TRISO fuel qualification. These 22 reports address the regulatory basis for advanced 23 reactor fuel qualification in Canada and the U.S., the 24 known degradation mechanisms and failure modes for 25 TRISO fuel, and transient behavior of TRISO fuel.
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21 1 The issuance of these products 2 demonstrates that we can successfully perform 3 collaborative reviews and positions the NRC and CNSC 4 for future success in licensing review cooperation.
5 CHAIR REMPE: Donna. Please go back to 6 the prior slide.
7 MS. WILLIAMS: Yes.
8 CHAIR REMPE: Okay. So in one or two 9 sentences can you tell us what the biggest benefit 10 was?
11 MS. WILLIAMS: In a specific product?
12 CHAIR REMPE: And in particular I'm 13 interested in the Terrestrial postulated initiating 14 events because this is something that's always been a 15 focus of ACRS, about starting with a clean sheet of 16 paper. What did you guys learn from this interaction 17 and why was it beneficial?
18 And then on the LMP comparison report with 19 the Canadian approach, I'm interested in, bottom line, 20 why was this a good thing do? And I actually had a 21 copy of this report and I saw a lot of good ideas for 22 future activities. And what's going on about that?
23 Are you guys going to do some of those activities, 24 because I hope the answer is yes.
25 MS. WILLIAMS: Yes, and I was going to say 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 1 I think one of the biggest benefits of that report is 2 identifying where there are areas that we need to look 3 at more closely. And one of them was the SSC 4 classification project that we're doing now, but there 5 are several others. And we're maintaining a list of 6 possible topics for future projects using some of the 7 outputs of that report.
8 But, Mo, did you have something to add, 9 too?
10 MR. SHAMS: Sure. I think I'll build on 11 what you said. So we'll start with the LMP project.
12 Donna is spot on. We did take a good bit of insights 13 from that comparison and it did suggest that looking 14 into structure system component classification would 15 be a valuable effort, and we actually are underway on 16 that. And I believe we're aiming for earlier -- early 17 this year to put together a report that looks at our 18 process for classifying structures and components as 19 well as the Canadian. So this is a great, great 20 project and insight for us.
21 Also imbedded in that report itself there 22 was the comparisons about -- that the LMP and the --
23 sort of the dose limits that we have imbedded in our 24 regulations and how they compare to those in the 25 Canadian framework. And we also can say arrived --
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23 1 that there were differences, getting back to that 2 discussion we just had a couple minutes ago. We 3 ultimately arrived that there are differences between 4 these limits, but ultimately both are leading to a 5 safe licensing of these facilities. So different 6 numerics that in particularly lend themselves to a 7 difference in the level of safety that the regulations 8 assure at the end of the day. So those were good 9 insights for us from LMP.
10 We had actually follow-on discussions with 11 our Canadian counterparts on safety goals and how they 12 were developed and constructed. So there was a number 13 of great benefits that came to us from this particular 14 project.
15 For the Terrestrial one, the postulated 16 initiating event, you're 100 percent right. This was 17 an opportunity for us to exercise or at least -- not 18 just us, for the vendor to exercise and us to be able 19 to review, if you will, a clean-sheet-of-paper 20 approach looking at a technology that certainly hasn't 21 been licensed before and be able to develop initiating 22 events.
23 They did do a -- we responded that it was 24 a viable job, great job. The approach wasn't 25 particularly complete and we left that note in there 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 1 that more would be developed as the design has matured 2 enough, but for the level of maturity that was offered 3 to us we felt that what was offered was -- represented 4 a viable approach for identifying initiating events.
5 CHAIR REMPE: Let me focus in a little bit 6 more. Did either the U.S. or the Canadians identify 7 a type of event that -- in one country that was not 8 detected in another, or did you come up with the 9 conclusion that we both captured the same type of 10 events?
11 MR. SHAMS: We were more the latter than 12 the former. We were more near -- our finding was more 13 towards -- the approach they're using to identify 14 initiating events was viable and the ones they 15 identify are a reasonable set of events that identify 16 -- given the maturity. We didn't close the door that 17 other events would be identified as the design matures 18 further.
19 CHAIR REMPE: Okay. So far it gives you 20 a warm fuzzy, but it's not a guarantee to a vendor or 21 either regulator that if you send to one country, it's 22 going to give you the same events in the other 23 country. Just so far you've not detected anything 24 different, I guess.
25 MR. SHAMS: Yes.
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25 1 CHAIR REMPE: Did I summarize what I'm 2 hearing?
3 MR. SHAMS: Yes, exactly. And also 4 perhaps you can say it this way: On one hand the 5 entire approach is intended to support de-risking the 6 reviews. So at this point Terrestrial has a great 7 insight into a -- how did we envision or how do we 8 envision created postulated events and what areas 9 we'll be looking at? So they have a good sense for 10 that.
11 On the flip side of that for us, we're 12 also looking at a new technology and we're not seeing 13 major gaps, which is the point you just made. We're 14 not seeing major gaps. Perhaps there are events in 15 there that needs to be further materialized or 16 crystallized. And reliability of equipment would come 17 in there and perhaps drive events one way or the 18 other, but we didn't see major gaps that sort of 19 concern us on both sides. So those sort of two high-20 level goals in my view were reasonably accomplished in 21 that exercise.
22 CHAIR REMPE: Okay. Again this was just 23 my reading and maybe I've missed something, but when 24 I looked at the LMP document the way that the LMP will 25 do a defense-in-depth assessment after they finish 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 1 their analyses was described like it was a well-2 established process. And I'm not sure that that's 3 quite the situation. And you can correct me if I'm 4 confused here, Mo, but I'm just kind of wondering if 5 maybe that some insights could be gained if there was 6 a little more -- well, at least if some of the --
7 we've not exercised this approach yet really with a 8 real design. And can we explore getting some insights 9 from the Canadians and how they do it, or you think 10 that both countries are in the same situation? I'm 11 kind of getting down into the weeds to see if there 12 are some things where we know --
13 (Simultaneous speaking.)
14 MR. SHAMS: You are. You're stressing --
15 you're definitely stressing my knowledge of that.
16 (Laughter.)
17 MR. SHAMS: I would say I believe there's 18 definitely learning on both sides, that the Canadian 19 approach in this -- certainly in this area is valuable 20 for us to understand how they consider defense-in-21 depth, but as -- our approach to the LMP has been in 22 a number of ways: And number one is the frequencies 23 of events that we look at, whether it's a likely 24 event, highly unlikely events, the bands -- as you 25 would recognize when we presented this approach to 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 1 you, the bands of events we're looking at. And then 2 also the sets of equipment and the sets of accidents 3 that we're looking at, what would be a design-basis 4 accident versus just a licensing event.
5 And then on top of that you probably have 6 seen it in the Part 53 proposed requirements is 7 specific requirements into defense-in-depth being 8 provided and describing what would that look like? So 9 no single -- particularly single system or action or 10 -- is the single sole item to be relied on.
11 So we're building through the events and 12 we're building it through the requirements for relying 13 on more than just one set of equipment or actions and 14 the like. And certainly there's room for us to learn 15 what the Canadians are doing to see how best we 16 approach that.
17 We are certainly aware that in your letter 18 to us in the past month or so there was discussion 19 about augmenting defense-in-depth. And we're looking 20 to respond in that -- in an appropriate way to 21 basically mention that what efforts we have to do 22 going forward in terms of guidance in that regard.
23 CHAIR REMPE: Yes, again I just am kind of 24 pulling the string. And I just think there's a lot of 25 good opportunities that we could learn from and 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 1 jointly solve this all together. But anyway, I think 2 I've made my point. Thank you.
3 MR. SHAMS: Thank you.
4 MS. WILLIAMS: Okay. Yes, in addition to 5 the specific technical benefits that we've learned in 6 each of these reports, I think these first products we 7 were really testing the system. We were figuring out 8 how to work together, how to jointly perform a review 9 and issue a joint product that will pay off with these 10 benefits when we get into the actual licensing 11 reviews. This is all in pre-app and very specific 12 topics. But there were a lot of lessons learned that 13 came out of this that really made us more efficient in 14 how we can do this.
15 So that brings us to the next slide on 16 lessons learned. So this first-of-a-kind 17 collaboration had a learning curve. In response to 18 lessons learned from early implementation of the MOC 19 we established processes and protocols to ensure that 20 the collaborative products benefit both agencies and 21 don't result in longer review times and increased 22 resources expended.
23 A challenge that we encountered was that 24 there are differences in the priority of licensing 25 projects and resources available for each regulator.
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29 1 To address this we identified criteria to 2 strategically select projects that will better 3 position us for success. That includes choosing 4 designs that are similar phases of submittal in each 5 agency. We also actively engaged with vendors to 6 ensure that the requests of both regulators are 7 similar enough to allow for joint review.
8 Another change to the process was to 9 expand the collaboration to include the U.K.'s Office 10 of Nuclear Regulation, who also have an interest in 11 specific projects. In September of 2021 the NRC and 12 CNSC mutually agreed to invite LNR to observe the 13 collaborative activities for TRISO fuel. We're 14 leveraging the existing bilateral arrangement that we 15 have with LNR to enable this initiative. And we plan 16 to expand on this and have LNR observe the 17 collaborative activities on BWRX-300.
18 When we began collaborative reviews we 19 anticipated that differences in licensing frameworks 20 and processes would be a challenge to developing joint 21 regulatory positions. To address this we held 22 training sessions on each other's regulatory processes 23 and we also compared the regulatory frameworks so we 24 can understand how a regulatory decision made in one 25 country can be applied in the other.
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30 1 One action taken to improve the 2 understanding of each other's processes was a staff 3 exchange. This formal staff exchange was included as 4 part of the collaborative review of the first GEH 5 Topical Report. This exchange was successful in 6 increasing communication and allowed CNSC and NRC to 7 better understand the different review approaches in 8 each country.
9 Because much of the work performed under 10 the MOC us withheld as proprietary or as foreign 11 government-controlled information, very little 12 information in the MOC project was made publicly 13 available initially. Recognizing that several 14 external stakeholders including other regulators are 15 interested in the collaborative activities, we made a 16 conscious effort to make reports publicly available if 17 possible. When we issue press releases, we issue 18 press releases when joint reports are issued and we've 19 create external web pages and made presentations in 20 public conferences on the activities under the MOC.
21 We also ensure that we coordinate any public 22 announcements and presentations with CNSC, and they do 23 the same with the NRC.
24 We also faced some logistical challenges 25 in sharing sensitive information, holding joint public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 1 meetings, and efficiently working together to develop 2 products. These challenges were addressed to the use 3 of IT tools and alignment on new processes and 4 protocols that we use during the reviews.
5 We have discussed how the designs are 6 chosen for collaborative review and improvising 7 details on the current projects. The decision to 8 propose collaborative licensing projects is that of 9 the vendors. It's made with consideration of their 10 commercial plans in each country.
11 This slide shows the four designs that 12 have been the subject of collaboration under the MOC 13 including NuScale's SMR, X-energy's Xe-100, GE 14 Hitachi's BWRX-300, and Terrestrial Energy's integral 15 molten salt reactor. When proposing projects vendors 16 consider the timelines for submittal in each country 17 as well as the scope and depth of interactions with 18 the regulators. In agreeing to cooperation the 19 regulators consider the outcomes of products desired 20 by the vendor in each country. For example, the 21 objectives of the CNSC's vendor design review process 22 are different than those of the NRC's certification 23 and pre-licensing engagement process. The 24 opportunities exist for leveraging information between 25 these two regulators.
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32 1 Even in areas where the licensing process 2 or outputs differ, cooperation can align on 3 fundamental scientific and engineering findings. In 4 general, a request by vendors to participate in this 5 bilateral cooperation is made because they've already 6 substantially engaged with at least one of the 7 regulators and have no plans to engage with the other 8 regulator on the same design.
9 We've established criteria to 10 strategically select licensing projects that are at 11 similar phases of submittal in each country and the 12 requests to both regulators are similar enough to 13 allow for a joint review. The decision to cooperate 14 on a licensing project is based on the following 15 factors: The extent to which the vendor is engaging 16 in meaningful pre-licensing activity with each 17 regulator, the similarity between a vendor's 18 engagement activities in each country, the timelines 19 for engaging with each regulator, and the ability of 20 the vendor to share information about their design 21 with both regulators. These factors will determine 22 whether cooperation can occur and the usefulness of 23 that cooperation.
24 The most benefit will be gained through 25 projects in which the similarities in each country are 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 1 well-aligned. Communication between the vendor 2 representatives in each country is also important.
3 The vendors in each country should be able to 4 collaborate effectively with each other and speak with 5 one voice.
6 Once a design is chosen for collaboration 7 the NRC and CNSC, in cooperation with the vendor, 8 identify specific technical topics for review.
9 Generally these areas are the subject of topical 10 reports or white papers that have been submitted.
11 Recognizing that the regulatory requirements will not 12 always align, collaboration will focus on the 13 technical content that ultimately satisfies both 14 countries' unique requirements.
15 The NRC and CNSC work with the vendors as 16 active participants in the collaborative process.
17 Vendors are strongly encouraged to have a point of 18 contact participating from both sides of the border to 19 represent the vendor in collaborative activities.
20 Communication protocols are established and 21 standardized at the beginning of the project. Vendors 22 must be enabled with a working understanding of how 23 both regulators conduct their pre-licensing activities 24 and what the outcomes of those processes are.
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34 1 alignment with the vendor on the scope of 2 collaboration and establish an understanding on how 3 this collaboration can result in both near-term and 4 long-term useful products. The regulators clearly 5 communicate the expectations with vendors that are 6 considered necessary to facilitate an efficient and 7 p r o d u c t i v e c o l l a b o r a t i o n .
8 The regulators also work to influence the 9 utilities to collaborate in the preparation of 10 licensing application. They get early alignment on 11 the scope and expected outcomes.
12 There are currently three active projects 13 under the MOC. Our collaborative work continues with 14 the TRISO fuel qualification project as the science 15 and regulatory experience evolves. As I mentioned 16 earlier we've already issued two interim reports and 17 plan to issue a final report early this year. The 18 goal of this collaboration was to establish a common 19 regulatory position on TRISO fuel qualification based 20 on existing public knowledge and to identify any 21 potential analytic or testing gaps that would need to 22 be addressed to enable TRISO use in advanced reactor 23 licensing applications.
24 It's expected that the final report will 25 enable efficiencies in the licensing process by 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 1 providing reactor vendors and regulators with a 2 reference-able report that documents the basis for 3 items related to fuel qualification and highlights the 4 areas where additional analysis or testing is needed 5 to support licensing.
6 We also engaged the U.K. regulator to 7 observe our activities, but there are developers in 8 all three countries proposing to use variations of 9 TRISO fuel. The benefit of a shared knowledge base on 10 TRISO goes beyond Canada, the U.S., and the U.K.
11 We're also collaborating on a project on 12 safety classification processes. The goal of this 13 project is to identify key similarities and 14 differences in a safety-significance determination 15 process, the scope of SSCs subject to the process, and 16 the outcomes, as well as the engineering design rules 17 applied to each safety class.
18 The joint report on technology inclusive 19 and risk-informed reviews for advanced reactors that 20 was developed under the MOC include a brief comparison 21 on safety classification SSCs and recommended more 22 detailed future work be done on both the safety 23 classification and application of safety 24 classification.
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36 1 between the regulators in these areas and confirming 2 this and identifying the differences will benefit 3 future cooperation in advanced reactor regulatory 4 activities, particularly for vendors seeking licenses 5 in other countries.
6 The working group performed reviews of two 7 pilot areas: pressure retaining components and 8 supports and reliability assurance programs. The 9 working group plans to issue an interim report and 10 results of the pilot reviews by the end of this month 11 and a final report in June.
12 Earlier this year we began collaborative 13 reviews of specific aspects of the GEH BWRX-300 small 14 modular reactor. Mike Dudek, the Branch Chief in the 15 Division of New Reactor Licensing, will present more 16 details on these projects. I'll turn it over to Mike 17 unless you have any questions.
18 MR. DUDEK: Any questions before I begin?
19 CHAIR REMPE: I'm not seeing any. Go 20 ahead.
21 MR. DUDEK: Okay. Hearing none, again my 22 name is Michael Dudek. I'm the Chief of New Reactor 23 Licensing in the Division of New and Renewed Licenses.
24 And this really where the rubber meets the road today, 25 so thanks, Donna, and thanks, Chairman Rempe and 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 1 esteemed members of the Committee for your opportunity 2 -- the opportunity to brief this today.
3 And this really goes to the rubber meeting 4 the road on what we're doing for the current work and 5 the next steps for what we're doing on these 6 collaborative efforts with GEH and CNSC.
7 Under the Memorandum of Cooperation 8 advanced reactors and small modular reactor 9 technologies are conducting collaborative reviews.
10 The process and guidelines for collaborating on the 11 BWRX-300 have been documented in a charter that was 12 signed by the EDO in late September 2022.
13 Additionally, the staff is providing knowledge 14 transfer training to CNSC staff and they're providing 15 knowledge transfer to us. This whole initiative 16 started off with a two-week training class between the 17 two entities to understand how each other operates.
18 We have some common guidelines on the 19 ESBWR and some of the other designs from the other 20 work that we've done, but this two-work -- two-week 21 training class really got down to the nitty-gritty on 22 how each other's regulators make their regulatory 23 findings, what their regulations entail, how they make 24 their technical judgments, and just how far they go in 25 some of their reviewing. So it was very enlightening 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 1 to our technical staff for how they analyze, and it 2 was quite eye-opening at the end of the day.
3 So with that training class and these 4 efforts underway what is the goal? Well, the goal is 5 to conduct efficient and coordinated technical reviews 6 resulting in a common technical position. So 7 regardless of regulatory outcomes or regardless of 8 processes and procedures we have been finding common 9 ground on technical positions. Technical to technical 10 discussions on pump valves, safety structures, safety 11 systems, fuel, design have been very fruitful and very 12 -- and there's been an understanding gained across 13 borders.
14 And that's really the golden goose at the 15 end of the day, harmonization on technical items, 16 technical positions where we can agree and can find 17 those efficiencies in the BWRX-300 design, to enhance 18 the standardization. Because that's the goal at the 19 end of the day, right? I mean, I've heard it -- we've 20 heard it over and over from GEH, what if at the end of 21 the day we could submit one application for both 22 countries? Well, we're making strides in that 23 direction. We are definitely making strides in that 24 direction. It's those technical reviews and those 25 technical items where we're making the best efforts.
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39 1 And as always we presented some additional 2 information. Every topical report, every item that we 3 review comes before the ACRS and we have the 4 opportunity to review it. And this isn't the last 5 time that we will be in front of you talking about 6 this item, but I hope this presentation today helps 7 enhance your knowledge about where we're at where 8 we're going. And the next --
9 DR. BLEY: Can I --
10 MR. DUDEK: -- slide is going to help me 11 do that even further. Yes?
12 DR. BLEY: This is Dennis Bley.
13 MR. DUDEK: Sure.
14 DR. BLEY: I kind of followed everything 15 up until now, but I've been worrying about one -- a 16 couple of areas. When you compared what they do at 17 NRC to -- it's more a philosophy of regulation I guess 18 -- to Canada -- we'll leave the U.K. out because 19 they're pretty different I think -- are you kind of 20 similar in when you think you need independent 21 confirmatory analysis by the regulator and in areas 22 where you need experiments to back up computer 23 modeling or is there more reliance by one party of the 24 other on some of these things?
25 MR. DUDEK: So I'm going to go out on a 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 1 limb and start the answer. Then I can turn it over to 2 Mo and Brian for perhaps additional insights.
3 But I think on the first topical report 4 that we reviewed between GEH -- it was very 5 enlightening that CNSC didn't appear to go as far with 6 the codes or utilize the codes in a similar manner as 7 the U.S. And what I mean by that is that they still 8 use the codes, they still did the calculations, but 9 they didn't -- I don't think that they went quite as 10 far as the in-depth analysis and the independence that 11 the NRC goes through with those codes and those 12 independent analysis.
13 Brian? Mo, you have any additional 14 insights on that?
15 MR. SHAMS: Yes, thank you, Mike.
16 So as we have discussed a little bit 17 earlier and we continue to point out, there is 18 differences. It's not a carbon copy approach at all, 19 but I think if we step back a little bit, we can see 20 the commonality. I think both regulators are 21 incredibly independent. They do have a commission 22 just like we do, reporting up to the commission in 23 their own way as far as their analyses and the like.
24 I probably would like to take it a little 25 bit higher than whether -- what they do specifically 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 1 on software validation versus not, even though it's a 2 convenient answer, but I'm seeing it across the board.
3 As we're interacting on things the independence comes 4 through, they're looking at our activities and then 5 taking that and assessing the -- in a risk-informed 6 approach what areas they wanted to look into further, 7 what areas they wanted to confirm, what reviews do 8 they want to do.
9 So I'm not particularly seeing a reduced 10 degree of independence per se or reliance on -- Dr.
11 Bley, you asked about safety features, testing for 12 safety features. I'm seeing a common theme between 13 both regulators about requiring the right data to 14 support the finding, relying on the industry and the 15 applicant to provide such information. So they have 16 a lot of language that one can map through our 17 regulations and our guidance.
18 DR. BLEY: Thanks. That's a pretty rosy 19 picture.
20 (Laughter.)
21 DR. BLEY: You're just painting a really 22 nice picture for us.
23 MR. SHAMS: Well, I think I was -- no, I'm 24 serious. No, I'm serious. I would say look at the 25 AP1000. I think that's a good example, perhaps a 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 1 complete -- more complete example than the activities 2 that we're working on now. And that offers a glaring 3 example of taking what we have done and just 4 particularly looking at certain areas and ultimately 5 arriving to the conclusion very similar to ours they 6 need particularly any massive changes per se or even 7 small changes to the design. So I feel reasonably 8 comfortable that their approach and ultimately where 9 they find themselves is relatively close to where the 10 U.S. is.
11 CHAIR REMPE: So since you brought up the 12 AP1000 --
13 (Simultaneous speaking.)
14 MR. SHAMS: So, I know, yes.
15 CHAIR REMPE: -- in the U.K. regulator did 16 identify an area where the U.S. missed with respect to 17 getting data to support the assumption. I'm looking 18 for some specific examples. Did the U.S. NRC see 19 something good that the regulator in Canada is doing 20 that said -- that made you think hey, maybe we should 21 change how we do something or other, or vice versa has 22 that happened with the Canadian regulator? I guess 23 I'm kind of getting back to what metrics -- give me 24 some examples.
25 MR. SHAMS: Sure. Sure. So I'll try to 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 1 give you examples now that we're talking AP1000, so we 2 might as well just get into that. So I think what --
3 back in the day when we were discussing it I think 4 that at the time we were having a lively debate around 5 a steel concrete composite and shield building, if 6 some of the members may recall, and the like. And 7 that was an area for them that they honed in on. They 8 looked into how that was approved by us. That was 9 another area -- a bit of a novel construction 10 approach.
11 And we went further in our own assessments 12 and they relied on that.
13 So an area where they found us have done 14 something and they leveraged, I would point to that 15 and say that was an area they definitely had some 16 concerns with early on and we helped move them through 17 that.
18 As far as where we've benefitted, I would 19 point to something perhaps not as technical as what I 20 just provided and I would point more to how we're 21 approaching advanced reactor reviews and the pre-22 application activities that we're taking on. I think 23 a good bit of that also came from seeing the VDR 24 process for Canada and their ability to provide 25 feedback on whether a design is on the right track or 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 1 meeting the regulations and what not.
2 So we've modeled something that ultimately 3 fits within our regulatory frames and our regulatory 4 boundaries, but it does achieve a similar goal of 5 providing input on whether a design or an idea that a 6 vendor is embracing is ultimately going to meet with 7 the regulations, with our regulations. So I'd point 8 to those activities and say there's definitely benefit 9 in our interactions over the past however many -- as 10 long as I can over the past decade-and-a-half or so.
11 CHAIR REMPE: Yeah, I know the VDR, the 12 vendor design -- whatever the R stands for -- I'm 13 drawing a blank here now.
14 MR. SHAMS: Review or something, I think 15 so.
16 CHAIR REMPE: Review. Yes.
17 MR. SHAMS: Yes.
18 CHAIR REMPE: A lot of the advanced 19 reactor components or design developers have said, 20 well, we really could use that to show we've made 21 progress. I don't know of anything we do that is 22 exactly like that other than you accept the 23 application. Are you planning to do something along 24 that lines or --
25 MR. SHAMS: So not in that format. We 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
45 1 believe what we have achieves the goal, perhaps 2 addresses the problem perhaps in a different way. So 3 we do have standard design reviews that ultimately can 4 look at any sort of -- any size, if you would, or any 5 part of a design, but we also have the -- what we're 6 sort of building truly now is the pre-application 7 review, which really could stand a small white paper 8 that's a couple of pages to just a dozen of topical 9 reports that cover broad areas.
10 So we feel like we have a flexible 11 approach that can actually achieve that. How does the 12 design meet our regulation at this point? So we have 13 a way to get there, but not -- perhaps not as 14 structured as what CNSC has.
15 CHAIR REMPE: Okay. Thanks.
16 MEMBER PETTI: Mo, I have a question. I 17 hope the internet is good. It's been going in and 18 out.
19 There was a time before I was on ACRS 20 where designers felt that it was easier to get through 21 the Canadian system than the U.S. system. And when I 22 was part of the MIT study we pushed on that and were 23 assured that that really wasn't the case, that these 24 were at very high levels in the regulatory 25 authorities.
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46 1 My sense was there were different 2 approaches that got you to the same place though. And 3 they asked the same questions, just maybe in a 4 different order. Is that your sense, that maybe this 5 was a misnomer that was out there about the Canadian 6 versus the U.S. regulatory approaches?
7 MR. SHAMS: Absolutely. I would align 8 myself with that thinking. They're different 9 approaches. They're asking questions in a different 10 order per se that they ultimately end up in the same 11 place. I kind of mentioned that a little bit earlier.
12 When we did the LMP comparisons we recognized that 13 there are differences in dose limits off site and the 14 like, but at the end of the day the philosophy, the 15 safety, the defense-in-depth and the like they're very 16 similar.
17 Now I think the ease versus not comes from 18 the degree of prescription in regulations, what Dr.
19 Rempe was pointing to, the VDR approach and its 20 ability to provide early feedback per se and perhaps 21 our guidance and our regs were not as structured and 22 perhaps not as well communicated to vendors as could 23 have been. So we've learned from that feedback.
24 So I agree with you, it's more a 25 perception than a reality, but we also had some role NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 1 to play to make sure that that perception is 2 addressed. And whatever we need to add in our 3 guidance we could, which we did facilitate that new 4 risking and a little easier start to the process 5 before you actually come and apply with a full.
6 MEMBER PETTI: Thanks.
7 MR. SHAMS: Thank you.
8 MR. DUDEK: Any additional questions?
9 (No audible response.)
10 MR. DUDEK: Hearing none --
11 DR. BLEY: I'm sorry. I got my buttons 12 confused on my computer.
13 MR. DUDEK: Yes?
14 DR. BLEY: I want to follow up on that 15 just a little bit. I was of the same mind as your and 16 Dave's discussion there. Our pre-licensing process 17 seems pretty thorough now and this -- we're seeing 18 more and more of vendors submitting topical reports 19 before their application comes in, which seems to give 20 them some of the benefits they were thinking they had 21 through the Canadian process. Can you say anything 22 more about that?
23 MR. SHAMS: Of course. Yes. I want to 24 say that over the past couple years we're seeing -- we 25 started -- it was an idea. We started it. I was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 1 talking with the staff about it not too long ago. The 2 road map. We were able to describing the road map for 3 non-light water reactor applicants, that there are a 4 number of ways to be able to get feedback and be able 5 to give perhaps staff formal positions. But it was a 6 concept and everybody sort of approached it in a timid 7 way.
8 I would say now we have dozens of --
9 whether it's white papers or topical reports and 10 they're being done in a systematic way. Your feedback 11 on it is incredibly valuable. We pass that along. We 12 address it as appropriate. And I think they're 13 definitely seeing that value. And I would also point 14 to the work that we're been doing on the Kairos design 15 and review. And that also presents a great example of 16 how successful it has been to use topical reports and 17 address certain areas early and how that feeds into 18 the application and stabilizes the review and supports 19 a schedule, an appropriate schedule and an aggressive 20 schedule, if you would.
21 So I think it's growing, Dr. Bley. It is 22 growing. And I can see more and more of the 23 applicants relying on that, figuring out ways. And 24 we're getting topical reports in areas that didn't 25 traditionally get topical reports. They were 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
49 1 envisioned in the past to be for approving a software 2 or what -- we're looking at other than that now with 3 other areas, whether it's source term, whether it's 4 fuel qualification, whether it's regulatory 5 applicability. So I think it's working, in my view.
6 I know it's another rosy pictures, but forgive me for 7 that.
8 DR. BLEY: Yes, I kind of like -- agree 9 with your rosy picture there. I think they're not 10 getting much credit for it, at least in things that 11 end up in the press. But I think that's been pretty 12 successful so far.
13 MR. SHAMS: Thank you.
14 CHAIR REMPE: I agree it's successful in 15 some ways, but then we're also seeing multiple 16 versions of topical reports coming in from some 17 vendors. And I think -- again, I've mentioned it in 18 other meetings, but maybe we need to think about are 19 we giving them so many SSCs and iterating that it's 20 going to make the process more expensive and maybe 21 they need to have some guidance on when enough is 22 enough. So I guess don't go too far is I guess I feel 23 obligated to say on that.
24 MR. SHAMS: I think it's a fair point. I 25 think I wouldn't paint every product we receive as 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 1 being an optimal product. I think just the line is 2 always a subjective one and different vendors approach 3 it differently. Some would go above the line to make 4 sure that they meet the line; others they want to inch 5 their way to get to that line. And that's exactly 6 what you described about multiple iteration.
7 We try to meet vendors where they are and 8 provide the feedback we can, but we're also going to 9 be honest that we're not here to grade homework, you 10 know. We're here to be able to provide the best 11 service possible to them and to the public. So 12 anyway, yes, it's definitely an evolution and I think 13 the vendor plays a role into getting their stuff here 14 on time and at quality.
15 DR. BLEY: And I'd throw in one practical 16 side. I do agree with Joy we have to be careful and 17 it probably will end up with less efficiency in some 18 areas, but then the people doing this development are 19 getting their funding in increments. They kind of 20 have to come at it in pieces, too.
21 MR. SHAMS: They certainly do. And their 22 accountability -- if we point to particular projects 23 that are funded by government per se or partially 24 funded by government, they have to meet certain 25 metrics and they have to see progress for the NRC. So 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 1 they do have -- they do have accountability that they 2 need to adhere to, too.
3 MR. DUDEK: Okay. If there's no 4 discussion --
5 MR. SHAMS: Mike, back to you.
6 MR. DUDEK: All right.
7 MEMBER BROWN: Yes, this is Charlie Brown.
8 I couldn't get my mic open. Apologize for that.
9 MR. SHAMS: No worries.
10 MEMBER BROWN: Yes, it is me, Charlie 11 Brown. I am on the line. Can people hear me okay?
12 MR. SHAMS: Yes, yes, we can hear you.
13 MEMBER BROWN: I'm trying to segue back to 14 a statement made in one of the earlier slides. Can't 15 remember which one. I guess I'm a little skeptical, 16 or maybe I'm the resident skeptic here as opposed to 17 all the smiling faces and shining sun that has been 18 thrown down on the discussion.
19 The object was if an applicant wants to 20 submit something, eh submits one design approach or 21 application. Does he go to both the NRC and the CNSC 22 and they both review it, or does just one review and 23 the other one accepts the review of the NRC? I'm 24 having a tough time figuring out how this becomes 25 somebody doesn't do something. If you've got two 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 1 people reviewing it, obviously the applicant is going 2 to have to review it with both commissions in order to 3 get it accepted.
4 So where is this commonality that -- I'll 5 use my area of I&C for an example. I mean, we get an 6 FSAR as part of an application that comes in and 7 there's a chapter that deals with the electric power 8 system as well as the I&C. And you all review that.
9 We review it. You provide an SE. We review it.
10 Whether -- if there's a topical report, we go through 11 that if necessary and we provide comments. And if you 12 note back in most of the design approvals we've done, 13 we have made comments particularly in our areas on the 14 power -- electric power and the I&C where changes have 15 been made during the application process to satisfy 16 the committee.
17 Now is there a similar committee on this; 18 I tried to figure that out from all the paperwork we 19 had, that provides a similar type approach with the 20 ACRS on the Canadian side?
21 MR. SHAMS: So that's a very specific 22 question. I don't understand the Canadian system that 23 well at that level of detail. But I know there is a 24 commission level review of their products, their 25 activities, their licensing actions. So that part is 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 similar.
2 Whether or not there is an intermediate 3 level in between, an independent body like yourselves, 4 I cannot comment on that. I don't know the answer to 5 that.
6 MEMBER BROWN: The reason I asked the 7 question, I'm trying to -- just looking at my area now 8 --
9 MR. SHAMS: Sure.
10 MEMBER BROWN: -- all of a sudden they, 11 the applicant submits something to you guys, and they 12 come in and say, well, CNSC has already accepted this 13 and approved the design, does that mean we turn into 14 a rubber stamp and say that, no, we don't have to 15 review it because it's already been accepted by the 16 Canadian's commission?
17 MR. SHAMS: That's a great question. So, 18 if you allow me, I'll elaborate on this a little bit.
19 So the short answer to that is no. I mean, just let 20 me start by saying that. The answer to that would be 21 no. That's not what we're going to do.
22 Now, how best we can leverage that review 23 by the Canadians is really the main exercise that 24 we're doing here.
25 So there are a number of examples where, 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 1 if a regulator has already done the review and the 2 other regulator could use it, and I pointed to AP1000 3 as a good example of that. It went through the review 4 on the U.S. side. The ACRS looked at it. Everything 5 was done.
6 So the Canadians had a great opportunity 7 to be able to leverage that and add to it what they 8 feel is appropriate to arrive to their independent 9 licensing decision. It's not a rubber stamp on their 10 end either, because they actually also have to prove 11 to their stakeholders that that design, being their 12 own independent way, that that design is safe.
13 But they have an incredible resource in 14 you as having done and looked at it. And I'll point 15 to the, you know, to I&C, the example you provided.
16 And the ACRS had approved already that I&C platform.
17 They didn't find any issues, or those have been 18 already addressed and what have you. So that presents 19 a great opportunity.
20 Now, if we are approaching issues today 21 that are -- we're at the same starting point. So, to 22 your point, there's a learning curve. Perhaps there's 23 a set of two eyes on it. Whether it's initiating 24 events, whether it's a code for a design of 25 containment or assessing containment performance, then 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 1 we're at a place where we're both looking at it.
2 What we aspire to in the future is having 3 the ability now to have done that work together and 4 looked at containment codes together, looked at --
5 maybe in the next round, we have the ability to be 6 able to rely on each other, construct, you know, 7 perhaps a broader team that part of it looks at 8 Chapter A versus another part is looking at Chapter B, 9 having the ability to rely on each other, review and 10 protect.
11 But, ultimately, the licensing decision is 12 independent. And that does not change. That is not 13 going to change. So, ultimately, we have to stand by 14 our decision, whether we've done the review entirely 15 independently by ourselves per se or relied on some of 16 these insights, technical insights, from our partners.
17 And the same is the other way around, whether they've 18 done an entire review on their own or relied partially 19 on some of our work. But the licensing decision is 20 independent.
21 MR. DUDEK: So let me dovetail into that 22 a little bit, Mo, in that licensing decisions and an 23 important key aspect is that -- I think a little bit 24 of your original question was, is common information 25 being submitted to both regulator. Yes. All 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 1 information that we have been reviewing and 2 collaborating on, GEH is submitting the same 3 information to CNSC as they're submitting us.
4 Now, we're lockstep in Canada in some 5 respects in that we're having monthly, if not weekly, 6 meetings on some of these items. So we know where 7 they're at in their review and their processes and 8 procedures, and they know where we're at associated 9 with these commonly submitted elements.
10 And that's beneficial at the end of the 11 day. So, if an interesting issue or a tough technical 12 item does come up, we're collaborating and 13 coordinating, and our technical reviewers are 14 discussing it across borders.
15 And to your point of that licensing 16 decision and whether we're able to accept something or 17 they are able to accept something from one regulator 18 to another, you know, that's the whole IAEA initiative 19 right now on harmonization, right, the NHSI 20 harmonization initiative where a mature regulator can 21 accept a licensing decision from another mature 22 regulator.
23 And I'm not sure we're quite there yet.
24 That's the golden goose at the end of day. And that's 25 the effort that we're talking about behind on the 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
57 1 international fronts for the last six months, and we 2 will continue throughout this next year. So that's an 3 important aspect, and that's a goal to get to.
4 Mo, anything else to add?
5 MR. SHAMS: Nothing, Mike. Thank you.
6 MEMBER BROWN: Yeah, let me elaborate on 7 your, or at least try to take your comments, your 8 discussion and point it somewhat. AP1000, we 9 actually, the Committee actually challenged part of 10 the I&C design in which the vendor had to go provide 11 some additional information.
12 For example, I think this was the one 13 where we were focusing on the deterministic, well, it 14 wasn't really deterministic, processing of the overall 15 I&C system in terms of straight through, on whether it 16 was an interrupt driven, blah, blah, blah, how did you 17 make sure you could always, the thing always went from 18 point A to point B in a required time.
19 They actually came back, and we had to put 20 program limits in terms of application code that was 21 installed into that system so that it would not 22 potentially just jam it up because it was trying to 23 execute so many routines. So the other part was a 24 couple of the design details that they actually 25 cranked in based on some of those comments as well.
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58 1 The other big issue that we, one of the 2 big issues was the passive valves. There was a big 3 back and forth between the Committee and the staff 4 relative to the --
5 (Simultaneous speaking.)
6 MEMBER BROWN: -- the triggering 7 mechanism. I won't call them one of the more 8 pejorative type of words.
9 (Simultaneous speaking.)
10 MEMBER BROWN: But there was a lot of back 11 and forth on that.
12 So it seems to me, I mean, once you all 13 have made a decision and we've adjudicated that 14 between, you know, we've made comments and if we 15 either accept it or not in the Commission rules, I'm 16 trying to figure out how you take that and you swing 17 that, how do the Canadians deal with some of the more 18 controversial type issues.
19 And bringing up AP1000 is a good point, 20 because a lot of issues came up during that review on 21 the design.
22 MR. SHAMS: Yep, yep.
23 MEMBER BROWN: And I'm not saying it was 24 on the staff, because we all agreed at the end we were 25 going forward with it.
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59 1 MR. SHAMS: Yep.
2 MEMBER BROWN: But that's, there was a --
3 how does the CNSC now take that and do an independent 4 review? I mean, if they, they kind of -- we're 5 building those right now. Okay.
6 MR. SHAMS: I think it's a great, great 7 great question, because it really talks to the 8 practicality of all this. None of this is static.
9 None of this is frozen in time.
10 You know, we make the best decision. You 11 give us the best feedback. We offer the Commission 12 the best recommendation we have at the time. And a 13 decision is made based on that. But there's processes 14 as we go forward to update and, you know, rectify 15 things depending on their safety significance and the 16 like. In terms of -- so that's how we maintain the 17 safety of the design if we end up finding something in 18 the end that we need to update.
19 As far as what, you know, how the 20 Canadians would benefit from that, I think it's going 21 to have to be dependent on the point of time in which 22 they're, you know, picking up our work per se and 23 relying on it. It would be -- if it's at the time 24 that we're still in dialogue with you, so there's 25 definitely a risk of, you know, you giving us some 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 1 feedback that leads to change things, if it's a time 2 further down on it, that's a more, you know, a reduced 3 risk if you would.
4 You know, we interact with them and others 5 as well. We interact on a periodic basis. And all 6 these issues come up.
7 You know, if we have a dialogue going on 8 AP1000, I envision such issues being brought up. If 9 we identify things clearly that's being done in 10 public, but it's more than just, you know, sort of 11 offering it in public and everybody can go read the 12 newspaper. But, no, there is our interaction with 13 them, whether it's, you know, biannually or any 14 discussion on all the different issues and topics that 15 we're, you know, interacting on.
16 We have also relationships with the 17 Canadians on oversight. You know, they had, we had 18 exchanges with the residents team or inspectors, 19 looked at AP1000 as well or other activities that 20 we're doing just for the oversight framework as a 21 whole but also for the specific technologies that they 22 had an interest in as well.
23 So these are all different mechanisms by 24 which we continue to interact and adapt through 25 changes and, you know, things that we identify along 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 1 the way. So I hope that gets to the point that it's 2 not frozen in time and forgotten from that point going 3 forward.
4 MEMBER BROWN: Okay. Well, thanks. Don't 5 take my queries as saying that -- you know, I'm not 6 trying to pour cold water. I think this is in the 7 positive --
8 MR. SHAMS: No.
9 MEMBER BROWN: -- area that it would be 10 useful for both countries to be able to simplify the 11 process somewhat so that we can build more of the 12 plants. I mean, it's -- the easier we can make it for 13 the applicants to be able to come up with a common, 14 common designs that satisfy both countries' 15 requirements and regulations, the better off we are in 16 the long run in terms of --
17 MR. SHAMS: Absolutely.
18 MEMBER BROWN: -- both countries. So --
19 MR. SHAMS: Absolutely, absolutely.
20 MEMBER BROWN: -- I'm just, I just don't 21 want us, the U.S., either the Commission or the 22 Committee, in my own mind to be brought up to the 23 point, well gee, it's already been accepted and go 24 forward. That's not a good end point for this 25 harmonization approach.
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62 1 MR. SHAMS: A hundred percent. We 2 couldn't agree more. And that is not the goal for 3 what we're doing.
4 I think there is a lot of efficiency to be 5 gained in technical, common technical positions, 6 reviews, data, software. But the licensing process 7 and the interactions with you all and the Commission, 8 that's intact. That's not being viewed as an area to, 9 you know, to change.
10 MEMBER BROWN: Okay. Thank you very much 11 for your patience with my --
12 (Laughter.)
13 MEMBER BROWN: -- my inquiries. Okay?
14 MR. SHAMS: We're grateful for the 15 questions, by the way, absolutely grateful. Thank 16 you.
17 MR. DUDEK: Absolutely. That's why we're 18 here.
19 MEMBER MARCH-LEUBA: This is Jose. Since 20 we have plenty of time, let me bring something related 21 to this. Mostly what we're doing on these 22 incorporations is not the licensing itself, but it's 23 the topical reports.
24 And it's not unusual for the NRC staff to 25 basically commission a review of a topical report 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 1 from, say, a national laboratory. So an expert or a 2 number of experts from a national laboratory do all 3 the technical review for a topical report. And then 4 the NRC staff does the final ten percent, comprise the 5 SER.
6 In that sense, it wouldn't be unheard of 7 if we were to commission the review of a topical 8 report to the Canadian regulators. And then we, the 9 NRC staff, do the final ten percent, of course, on 10 final SER.
11 So, since there is so much more emphasis 12 on topical reports for deciding new reactors, I think 13 there is some benefits to be gained by incorporating 14 more. If I am a regulator and I review a critical 15 heat flux correlation, why doesn't a greater number to 16 have to review from the scratch the same critical heat 17 flux correlation? I mean, if it's already been 18 reviewed, you have to reincorporate.
19 But, so there is a lot to be gained there.
20 I'm used to leaving intact the ACRS and the Commission 21 positions on roles. But 90 percent of the work is 22 done together.
23 MR. DUDEK: Well, Jose, let me take that.
24 And hopefully we can -- I'd like to parlay that into 25 the next slide just real quick, because that's where 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 1 I'm going to get into some of those details about how 2 we're delegating some of the work under those topical 3 reports. And we've actually expanded it to white 4 papers now as well. So, you know, the CNSC takes a 5 piece. We take a piece. And then we align on that 6 common position.
7 MR. SHAMS: Thanks, Mike. So, Jose, let 8 me answer your question. Absolutely, I think that is 9 the concept. The mechanics probably would be 10 something that we have to work out, you know, because 11 there are certainly deltas between a laboratory doing 12 it for us.
13 But your description of the concept is 14 spot on, to what degree can we use something that's 15 already been done. And that's actually, again, that 16 is what's being done today on the fuel side of things.
17 You know, we didn't quite tell you yet, and Mike is 18 going to walk through that, but when we show you what 19 we're doing for fuel, it's exactly the concept you 20 were describing.
21 We've already reviewed several topical 22 reports associated with the fuel for BWRX-300. And 23 the Canadians are having the ability now to look at 24 these reports and review them in a way that satisfies 25 their need for effect.
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65 1 And then ultimately after writing an SC, 2 which is in your description, would be that ten 3 percent, you know, the write-up now built on the 4 strength of what the NRC has already done in this 5 area.
6 And we're not just providing the reports 7 and the SCs that we bring. But we're actually making 8 ourselves available to meet and discuss and actually 9 provide, you know, human insights into these reviews 10 and how they were done and explanations. So I think 11 the model is quite close to what you've described.
12 And we're looking to see the same thing on 13 the other side as well. What we haven't mentioned yet 14 is BWRX is envisioned to be built in Canada ahead of 15 the U.S. by a year or so. So we can see a great deal 16 of value in seeing, you know, issues or inspections.
17 We can leverage what's being done in that regard and 18 see how we can benefit this side of the border with 19 this information.
20 MEMBER MARCH-LEUBA: Going back one step 21 further up --
22 MR. SHAMS: Sure.
23 MEMBER MARCH-LEUBA: -- for the philosophy 24 point, one thing we do, we, NRC staff. By that, I 25 mean you. I'm ACRS. One thing NRC does with 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 1 regulatory guides is they endorse and incorporate by 2 reference, say, for example, on NEI position.
3 MR. SHAMS: Sure.
4 MEMBER MARCH-LEUBA: I don't think we are 5 going that far. I think that to keep everybody happy 6 it would be best if we do the topical report 7 commissioning a national laboratory model in which 8 they do 90 percent and we do 10 percent. So I just 9 wanted to bring that to your attention. I mean, when 10 we say incorporating by reference, people start 11 getting cold feet, I think.
12 MR. SHAMS: It's a great idea. And we'll 13 definitely reflect on it and see. And as I say, we'll 14 find the right mechanics for it. But the idea, we 15 absolutely share the same vision on that.
16 DR. BLEY: This is Dennis again. Michael, 17 you tossed out white papers. And I guess if you're 18 not planning to say more about it, please say some 19 more now, because those aren't something that you 20 actually approve. What's the role of white papers in 21 all of these processes we're talking about?
22 MR. DUDEK: So I'll answer that in just a 23 minute. But I'd like to go back to the previous slide 24 first and answer your first question with some 25 additional information on it. Can you go back one 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 1 slide?
2 So, Member Bley, just to answer your 3 question on some of the codes and what we've done and 4 how they apply to the proposed regulators, I would 5 refer you to that first joint report on the 6 containment evaluation method. And I just sent the 7 joint report to Mike Snodderly and the ML number is 8 22031A279. And that ML number is for that joint 9 report. And it gives some additional details on that 10 code piece.
11 But colloquially, let's start -- and to 12 your white paper discussion, let's discuss what work 13 is actually being done right now. And this is 14 colloquially called our five-member or five-topic 15 discussions, CNSC, NRC, TVA, OPG, and SaskPower. So 16 essentially it's now six with the addition of 17 SaskPower.
18 And as Mo very graciously said, OPG is a 19 step ahead. And they will be building a year ahead of 20 us. We will be learning a lot about their processes 21 and procedures and how this is going to go forward.
22 And SaskPower is now a new member to our five-party 23 discussions, as they may be purchasing the GE Hitachi 24 as well. So next slide.
25 So what are we doing? And it goes to that 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 1 white paper and that topical report discussion. And 2 that's to say that we have three work plans that are 3 currently underway, you know, under the structure of, 4 you know, the MOC and the charter that was signed by 5 the EDO in 2022. We have an annex to that charter, 6 which is really the work plans themselves. What work 7 is actually going to be done? What are we actually 8 doing? And what are we actually collaborating on?
9 And we've decided to collaborate on three 10 items, three technical items, that we've been, that 11 the three entities, us, CNSC, and GEH, have aligned on 12 that would be of benefit to discuss. And it's really 13 those advanced construction techniques, the safety 14 strategy white paper, and a fuel verification and 15 validation report that we're, that both countries are 16 looking at.
17 So I'm going to describe a little bit more 18 about each one of them if that's okay.
19 First and foremost, the advanced 20 construction technique project, so NRC and CNSC are 21 currently reviewing, each reviewing the white paper 22 that was submitted to both SCs by GEH. And this is 23 really, you know, goes to the bottom line of steel 24 plate composite containment vessel construction for 25 the reactor building structural design.
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69 1 This white paper is, describes the use of 2 what they call steel bricks. Now, these steel bricks 3 will be used for the construction of most walls and 4 floor for the BWRX-300 integrated reactor building.
5 And these steel bricks will be filled with cement and 6 with steel tie rods and will be a structural element 7 for the containment and reactor building structures.
8 New and novel designs, something that the 9 U.S. at least hasn't seen before. I think it's been 10 used in a couple other entities. But, you know, this 11 is new to at least me. And I'm learning a lot about 12 it.
13 So they did submit this white paper to us.
14 We have been reviewing it since October 14, 2022. We 15 have had a public meeting on it. And that was in 16 November 12, 2022. We had a joint public meeting on 17 it between the NRC, CNSC, and GEH.
18 And now we're working to put that joint 19 report and put that meeting summary and those joint 20 efforts and those joint learnings of what we've done 21 over the last, you know, three to four or five months 22 together. And we should see something come together 23 on that by March, the end of March of 2023.
24 Any questions on steel bricks before we 25 move on?
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70 1 MEMBER KIRCHNER: Mike, this is Walt 2 Kirchner. Happy New Year first, and then, also Mo.
3 Just, Mike, you were, weren't you the 4 lead, your staff the lead on the NuScale steel plate 5 composite PR review?
6 MR. DUDEK: It's not, the steel plate 7 composite isn't quite what these steel bricks is. And 8 what I mean by that, this steel brick technology is 9 almost two steel plates put together with tie rods, 10 and then you fill it with concrete as part of the 11 structural element. So it's a little bit different 12 than what the NuScale design entailed.
13 (Simultaneous speaking.)
14 MEMBER KIRCHNER: Without getting into 15 proprietary details, the basic concept is the same.
16 MR. SHAMS: It is. And it's the same 17 concept that AP1000 used as well. So I'm --
18 MEMBER KIRCHNER: Right.
19 MR. SHAMS: -- I'm with you. And I know 20 you remember in those days, they came in and presented 21 to you on what AP1000 was and was not. So, yes, you 22 know, it's not particularly that different. But there 23 are proprietary elements that are somewhat different, 24 yes.
25 MEMBER KIRCHNER: Of course, but back in 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 1 that time, Mo, since you brought it up, this is Dennis 2 again --
3 MR. SHAMS: Yep.
4 MEMBER KIRCHNER: -- there were no 5 consensus standards on steel plate composite 6 constructions. There are now. So I assume that's 7 having, feed into --
8 MR. SHAMS: It is, yeah, it is definitely 9 helping quite a bit to have -- do you remember --
10 you're right. The dialogue back then was the data 11 that we've used and the testing that was assembled at 12 the time. I think we're in a better place now.
13 But there's also -- and Mike, you know, 14 I'm sure will have the ability to describe. There is 15 a testing program that's taking place for that 16 particular design that BWRX-300 is adopting. And 17 they're working with BUE and -- in particular to do 18 the sum validation of their data and their models.
19 So, yes, it's both. There's data as well as better 20 foundation in terms of codes.
21 MEMBER KIRCHNER: Okay. Thanks.
22 MR. DUDEK: Yeah, and some of those 23 initial tests are being done out at the University of 24 Purdue. And we're slated to go out and see some of 25 those additional steel brick tests later this year as 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 1 part of the -- project.
2 MEMBER KIRCHNER: Mike, this is Walt 3 again. That brings up an interesting thing.
4 I'm not familiar with how the Canadians 5 deal with ANSI and other American standards. Probably 6 in this topical area we're talking about civil and 7 also ASME.
8 You mentioned earlier your joint work on 9 the pressure vessel for the X-energy. You know, 10 nominally at least on the U.S. side, one would look to 11 ASME code case or such to cover a novel high 12 temperature design like that.
13 How does it work with the Canadians in 14 terms of standards? Do they rely a lot on the ASME 15 boiler and pressure vessel code? That would seem to 16 be, you know, the go-to place for that pressure vessel 17 work for X-energy.
18 MR. SHAMS: I can take that, Mike.
19 They do, Dr. Kirchner. Yeah, absolutely, 20 they do. We do have a common utility, if you would, 21 for the ASME code. I believe it's, you know, it's 22 integrated in their thinking and approach for building 23 nuclear plants.
24 And when we did do a joint effort on the 25 X-energy vessel construction code, we had a common 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 1 view that what was presented was viable. So that 2 gives you an example of them, you know, adopting an 3 ASME code revision or a section per se. So, yes, 4 they're definitely embracing that code.
5 MEMBER KIRCHNER: Does the same hold for 6 IEEE as well? Just excuse my unfamiliarity with the 7 Canadian licensing processes.
8 MR. SHAMS: Sure.
9 MEMBER KIRCHNER: Do they look generally 10 to IEEE for the electrical and digital standard base?
11 MR. SHAMS: That's a little bit deeper 12 than I know about their regulatory framework. So 13 don't know the answer to that.
14 But I would like to offer a more general 15 answer, as I think they have a lot of, they see a lot 16 of value in American codes and standards per se. But 17 they're also well integrated internationally. So 18 you'll see international products, you know, that 19 they're using as well. But I don't know the answer to 20 the IEEE specifically.
21 CHAIR REMPE: Let's go on to your second 22 bullet because of time. We're using up the allocated 23 time rapidly. Thank you.
24 MR. DUDEK: Absolutely. And this second 25 work plan is what we colloquially call the safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
74 1 strategy. And this is the NRC and CNSC are currently 2 reviewing a white paper entitled safety strategy. And 3 it's for that BWRX-300.
4 So the white paper was submitted to the 5 NRC in early December, December 6, 2022. And it 6 really looks to incorporate the selective guidance 7 from the IAEA's safety standards for specific safety 8 requirements in SSR2/1, Revision 1.
9 GEH is not requesting specific regulatory 10 endorsement of the IAEA standard by either the NRC or 11 CNSC. However, the objective of the safety strategy 12 is to establish the design and a high level strategy 13 of safety when using defense in depth concepts between 14 the two countries associated with the IAEA standards.
15 GEH believes that this is accomplished 16 through the incorporation of the design requirements 17 through selective guidance. And it also believes that 18 it's consistent with the current NRC and CNSC 19 regulatory requirements.
20 So we're really looking on how does the 21 NRC do business, how does CNSC do business, and can we 22 parlay our understanding for that associated with this 23 IAEA standard.
24 We've had an initial public, joint public 25 meeting in December 14th. We have been providing, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 1 meeting regularly with CNSC and providing that 2 preliminary feedback to GEH. We're working on a 3 meeting summary and a meeting feedback. And we're 4 taking a look at, a comprehensive look at this topic 5 --
6 (Audio interference.)
7 CHAIR REMPE: -- GEH. Yet the CNSC and 8 the NRC would say if you follow this IAEA standards 9 it's likely you're going to meet our regulatory 10 requirements. Is that what they'd like to have you 11 say and you're trying to evaluate it for something 12 that there would be a gap by just following the IAEA 13 safety standards?
14 MR. DUDEK: Yeah, I think very simply 15 we're looking at that gap.
16 CHAIR REMPE: Okay. And then could I have 17 you send a copy of this white paper to Mike so that it 18 could be provided to the ACRS members and slides from 19 that meeting?
20 MR. DUDEK: Sure. I think we can do that.
21 I'll take that as a note.
22 CHAIR REMPE: Okay. Thank you.
23 MR. DUDEK: Mo, anything to add?
24 MR. SHAMS: No, Mike, you covered it.
25 Thank you.
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76 1 DR. SCHULTZ: Mike, this is Steve Schultz.
2 Just a question on the IAEA standard and work here.
3 Over the past two years at least, the IAEA 4 has been looking at the revision of the, of the 5 Revision 1 standard going forward to apply to new 6 reactor designs. And has that been something that the 7 GEH folks have incorporated into their reviews here 8 and to this strategy?
9 MR. DUDEK: I think it's their proposal at 10 this time. I'm not sure that they've actually 11 incorporated it. They've submitted a white paper 12 floating this idea to us on how this would work and 13 whether we can get our arms around it. And then I 14 think they have a topical report or I believe they 15 have a topical report planned for later this year 16 that's going to flesh this out even further.
17 DR. SCHULTZ: Good. Thank you.
18 And I did note in looking at the 19 information we have been provided on the overall 20 licensing approach for CNSC and NRC that for the CNSC, 21 their defense in depth approach is almost readily 22 adapted from the IAEA approach, though I'd be 23 interested in seeing that work that you're going to 24 forward to Mike so --
25 MR. DUDEK: Sure.
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77 1 DR. SCHULTZ: -- we can review that.
2 Thank you.
3 MR. DUDEK: Sure. I will forward what I 4 can. And I'll round with Mo and Brian on what I can 5 find. Okay.
6 DR. SCHULTZ: Thank you.
7 MR. DUDEK: Absolutely. So, without any 8 further discussion on that, we'll move on to the third 9 topic of the, the third work plans. And that's really 10 the fuel verification and validation, you know, and 11 this GNF2 fuel that the BWRX-300 design is proposing 12 to utilize. But we've seen that same fuel as part of 13 the ESBWR. So the NRC is very familiar with this 14 design.
15 And we've had several public meetings with 16 CNSC over the last three months to try to bring 17 understanding and commonalities across, and 18 harmonization across borders of what we've seen and 19 what we've known and trying to brief and get CNSC 20 comfortable with reviewing that information that GEH 21 is going to send to both of us. So it's more of a 22 mentor-mentee of mature regulators at that point for 23 at least this topic.
24 Mo, anything to add on that?
25 MR. SHAMS: No, Mike. I would, you know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 1 the only item I point to is this is really again the 2 prime example of how are we leveraging this activity 3 to gain efficiency, to gain mileage, if you would.
4 It's by things like this, what we've done 5 versus what they have done and how we can share that 6 knowledge and help the other regulator move forward 7 quicker, faster and with a foundation of great work 8 that's done by the other regulator. So this is a 9 prime example of that.
10 DR. BLEY: A quick question from Dennis.
11 MR. SHAMS: Sure.
12 DR. BLEY: I've heard the phrase another 13 mature regulator many, many times --
14 MR. SHAMS: Yes.
15 DR. BLEY: -- which on the surface makes 16 sense. To get specifics, into specifics, it might be 17 hard to pin down. Is IAEA, are they declaring who are 18 mature regulators? Are you guys? Where is that -- is 19 that really a big deal here, or is that just language 20 that's floating through?
21 MR. SHAMS: So I wouldn't say it's a big 22 deal between us and the Canadian regulator, because 23 we're both, I would say fit the category of mature 24 regulators. I think it's -- in our vision, you know, 25 early on, it continues to be is we start with folks NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 1 that we have a great deal of commonalities to start 2 building a model that works and we can identify where 3 we can benefit from each other and when we cannot.
4 So I wouldn't characterize either of us as 5 an immature regulator. But does that exist? Yeah.
6 Certainly, you know, developing nations, those that 7 are early on in their journey with these reactors and 8 these technologies, we would probably say that they 9 still need a bit to gain to get to a mature regulator.
10 And that would be the group that would be looked at as 11 not particularly a mature regulator.
12 DR. BLEY: So, as this grows and goes 13 forward, with you and the Canadians and maybe other 14 countries coming in I guess it's this group of 15 regulators who decide who gets to come into the club 16 in the future.
17 (Simultaneous speaking.)
18 MR. DUDEK: I think it's more in depth 19 than that. I think the IAEA forum under the SMR 20 regulators forum, which we're discussing and defining 21 some of these terms, there's over 30-plus countries 22 that are in those discussions and aligning on, you 23 know, who is a developing country and who is a mature 24 regulator.
25 And it's pretty clear in those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 1 discussions. You know, if you license multiple 2 reactors, if you have a good operating fleet, and you 3 have well established processes and regulatory 4 procedures, then I think for all intents and purposes 5 you're a mature regulator in at least the IAEA's view 6 and how we're defining and how you'll see some of 7 these reports coming out for those --
8 DR. BLEY: Okay. Thanks, Michael. That's 9 --
10 MR. DUDEK: -- for those countries.
11 DR. BLEY: That's what I was looking for.
12 And I guess IAEA is kind of the lead on this, if there 13 is such a thing as a lead.
14 MR. DUDEK: Yes. Okay. Next slide, so 15 bringing up the tail end here on next steps if we can.
16 And the next steps are really, you know, 17 the U.S. and Canada are routinely exchanging 18 information. As I said, these are monthly, daily, and 19 weekly activities.
20 And it's anticipated that pre-application 21 engagement to identify additional potential projects 22 and technical areas are, you know, highly sought 23 after. And we're discussing them on a routine basis 24 between our senior managers and our staff to come up 25 with these collaborative reviews and these 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
81 1 collaborative ideas.
2 And really the thanks is to GEH for, you 3 know, really coming to the table and giving us this 4 opportunity on these topics and really sending some 5 challenging topics in front of us that we can both 6 align on and interact on. And we want to be 7 successful at the end of the day. And we want to 8 provide them some benefits. So, you know, all of this 9 is in the back of our minds.
10 So, while the focus of current projects is 11 on pre-application and interactions, you know, really 12 at the end of the day, you know, we're cooperating and 13 collaborating with an important entity to our north to 14 review on specific sections and topics. And 15 hopefully, you know, that golden goose at the end of 16 the day is harmonization and CNSC's and NRC's goal of 17 conducting joint reviews and these joint activities on 18 topics and activities jointly.
19 So, with that being said, I'll turn it 20 over to, back to either you, Chairman Rempe, or Mo and 21 Brian for any additional thoughts that you have.
22 CHAIR REMPE: Okay. So this is Joy. Mo 23 or others on the staff, do you have any final 24 comments?
25 MR. SHAMS: No, thank you. No, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
82 1 questions have been incredibly thoughtful. And I hope 2 that we were able to respond to your inquiries and 3 will provide the information you requested. But other 4 than that, no, back to you.
5 CHAIR REMPE: You've done a great job. I 6 found this presentation very helpful.
7 I want to remind members and consultants 8 that there is going to be a closed session. But if 9 there's any other questions you want to ask in the 10 open session, this is the time to do that. And then 11 we'll open up the line for public comments. I see 12 your hand up, Dennis.
13 DR. BLEY: Yeah, just a quick one in an 14 area that I guess I'm not too concerned about. But 15 Congress has passed the laws that establish NRC as the 16 nuclear regulator for the United States. Is there any 17 legal issues that are troublesome here with making 18 these kind of cooperations work?
19 MR. SHAMS: We haven't encountered any.
20 And as long as it remains in a place that doesn't 21 particularly impact our sovereignty and our ability to 22 make our licensing decisions independently, we see 23 this as another merging of our interactions that we 24 have been doing for a while, whether it's bilateral or 25 multilateral through IAEA, other organizations. So, 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
83 1 no, our legal advisers did not find issues with what 2 we've been doing.
3 DR. BLEY: Okay. Thanks a lot. And 4 thanks for the --
5 MR. SHAMS: Sure.
6 CHAIR REMPE: Charlie, I saw your hand up 7 next.
8 MEMBER BROWN: Yeah, thanks. I wanted to 9 -- the two white papers, which are pretty high level 10 type documents when you get right down to it, 11 strategies for doing various things, as well as the 12 details on the construction techniques item, the -- I 13 wanted to emphasize a little bit of Jose's comment 14 relative to the topical reports. That's where the 15 rubber hits the road in the details, the piece parts 16 that you put these plants together with in most 17 circumstances.
18 And I know in my area we've, there's been 19 a couple of topical reports that have been reviewed, 20 and then they have been used by other applicants. And 21 they've flown through the review process with barely 22 a wink and a nod. I mean, they were agreed to once.
23 And they were accepted by the next applicant, and away 24 we went. And they worked very, very well.
25 So the topical reports are, I just wanted NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
84 1 to emphasize what Jose said, that those are an 2 important linchpin when we're getting down to the 3 details about what the plants and what the applicants 4 are going to design the specific systems utilizing.
5 That was my only thought. So don't lose sight of 6 that.
7 MR. SHAMS: No, no, we're not. And I 8 thank you for the feedback on that. And we want to --
9 I don't know if we answered the question as crisply as 10 we could have been.
11 The white papers are not replacing topical 12 reports by no mean. They serve a different purpose.
13 They serve a purpose of are we on the right track per 14 se and what elements are missing versus not. So 15 that's, the purpose they kind of offer is an 16 opportunity to provide feedback.
17 A topical report is a topical report.
18 It's a licensing tool. It gets your review. It gets 19 our SC and a staff position is preserved and can be 20 incorporated by reference. So they serve different 21 purposes.
22 CHAIR REMPE: Okay. And then I saw Greg's 23 hand up.
24 MEMBER HALNON: Yeah, thanks, Joy. If 25 you've covered, I got two questions, and if you've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 1 covered them already, I apologize.
2 MR. SHAMS: Sure.
3 MEMBER HALNON: One of them is, do you 4 ever see a situation where you might endorse a 5 Canadian standard so that there's only one effort by 6 the licensee to, or the applicant to establish their 7 documents?
8 MR. SHAMS: I would probably say certainly 9 there's no reason for us not to. I'd say I would 10 point more to more international thing, like an ISO 11 9000 per se. So that's more of an example of what you 12 pointed to. That would be an opportunity for us to 13 endorse something that licensees can use on this side 14 of the border versus the other. But conceptually, 15 there's no reason not to. Yes, if we find something 16 in there that supports us and our reviews, we would do 17 it, yes.
18 MEMBER HALNON: Okay. Second question, do 19 you ever -- well, when is it not appropriate? Do you 20 foresee any circumstance or situation where you would, 21 if an applicant came in and said we want a joint 22 review, you would say no, thank you?
23 MR. SHAMS: That's a great question. I 24 didn't mean to -- but it's a tough question. I would 25 say that the characteristics and the aspects that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 1 Donna went through early on is to make this as 2 efficiently as possible.
3 You know, I'll start by saying we're open 4 for business. If anybody -- you know, it's a public 5 service operation. So, if anybody is submitting an 6 application to us, we certainly have a place for them.
7 Whether or not they did the right priorities or their 8 budget, of course, that plays a factor in, you know, 9 how quickly we can get to it.
10 Now, in terms of a joint collaborative 11 effort on a review, that would have to be impacted by 12 a number of factors, you know, how well is that 13 application oriented for the two regulators to 14 collaborate, is one far ahead of the other, you know, 15 do we have similar design or are there differences.
16 So those are the factors, what's on our 17 plate versus what's on their plate, is it going to be 18 built in both countries versus both in one but not in 19 the other. So those would be the criteria and the 20 attributes that we would use to decide, you know, the 21 priority of that application.
22 MEMBER HALNON: Okay. Thanks, Mo.
23 MR. SHAMS: Sure.
24 CHAIR REMPE: So I know you were going 25 from the phone to the computer, Greg. And I believe NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
87 1 it's slide 8. It's where Donna went through those 2 characteristics and criteria that emphasize which ones 3 might be viewed more favorably to use.
4 At this point, I'd like to open up the 5 line for public comments. If you are online, you 6 should raise your hand and, or do a star 6. I don't 7 see -- I saw a hand, but it disappeared. Is there 8 anyone who wants to make a public comment? Okay. I 9 think I've given us enough time.
10 And the phone lines, if you wanted to make 11 a comment, you I believe hit star 6. And that unmutes 12 you. And that would allow you to make a comment. So 13 I'll give you a couple of seconds longer.
14 And not hearing anything, then it's time 15 for us to switch and go to the non-public invitation.
16 And again, I want to thank the staff for the great 17 presentations and their willingness to brief us.
18 I believe, but, Mo, perhaps you or others 19 could confirm this, but I believe the CNSC folks would 20 be allowed to be in this closed session. Is that 21 true? I'm not hearing --
22 MR. SHAMS: No, I'm, yeah, I'm thinking 23 the answer through.
24 CHAIR REMPE: Okay.
25 MR. SHAMS: Yeah. I honestly don't know NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 1 the answer to that. I would have to confer with my 2 staff on that. I don't know the answer to that. I 3 know --
4 CHAIR REMPE: Okay.
5 MR. SHAMS: -- I forwarded them the link 6 this morning. I don't know if they have the link for 7 the closed session.
8 CHAIR REMPE: Okay.
9 MS. WILLIAMS: Yeah, the information I 10 think we were planning to discuss in the closed 11 session is the subjective meetings that we've had with 12 CNSC. So I don't see a reason why they couldn't.
13 MR. SHAMS: So there's your response.
14 Yeah, ordinarily, you know, we would have to be 15 careful with what's being discussed, whether it's 16 proprietary or not. But this is their information.
17 They are partners with us in this information. So it 18 would be appropriate for them to attend.
19 CHAIR REMPE: So I will trust you to 20 forward that to them.
21 And then let's take -- I know we're 22 running a little bit late. But why don't we take a 23 five-minute break, because it takes a while to confirm 24 everybody is really here that should be here? So 25 let's restart at 3:50 p.m. Does that sound good? And 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
89 1 thank you.
2 MR. SHAMS: Thank you.
3 CHAIR REMPE: Okay.
4 MR. SHAMS: Appreciate it.
5 CHAIR REMPE: Thanks again.
6 (Whereupon, the above-entitled matter went 7 off the record at 3:45 p.m.)
8 9
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CNSC - U.S. NRC Cooperation on Advanced Reactor Technologies and Small Modular Reactors January 11, 2023
Outline
- Introduction
- Memorandum of Cooperation process
- First products
- Current work
- Future projects
Introduction
- Memorandum of Cooperation signed in 2019 to collaborate on reviews of designs submitted for review in the U.S. and Canada
- Goal - Collaborate on ART-SMR design reviews and share experience
- Effective and efficient regulation
- Risk-informed agile decision-making 3
Implementation of the MOC MOU Steering Committee MOC ART-SMR Subcommittee Work plans Working groups/ subject matter experts
Scope of Memorandum of Cooperation (MOC)
Scope of projects
- Pre-licensing engagement
- Licensing reviews
- Science and research Development of work plans Processes for collaboration
Joint NRC/CNSC Products Pre-licensing Engagement
- X-energy - Xe100 reactor pressure vessel construction code assessment
- GEH- BWRX-300 Containment Evaluation Method
- Terrestrial - postulated initiating events Review Approaches
- Report Comparting the U.S. LMP with the Canadian Approach Unique Technical Considerations
- TRISO fuel qualification
Lessons Learned and Improvements to the Collaboration Process Expansion to include UK/ONR Staff exchanges Strengthened communication to external stakeholders Upgrades to collaboration tools
Project Selection
- Request by vendors
- Criteria
- The extent to which the vendor is engaging in meaningful pre-licensing activity with each regulator
- The similarity between the vendors engagement activities in each country
- The timelines for engaging with each regulator
- The ability of the vendor to share information about their design with both regulators
Current Work Collaborative work plans underway Safety Classification of Structures, TRISO Fuel Systems and Qualification GEH BWRX-300 Components
Joint Review of GE Hitachis BWRX-300
- Goal: Efficient and coordinated reviews resulting in common technical positions
- To date, NRC and CNSC have successfully collaborated and issued a joint report on BWRX-300 containment evaluation method.
CNSC-NRC MOC BWRX-300 Current Projects
- BWRX-300: Advanced construction techniques. The NRC and CNSC staff are reviewing a white paper on BWRX-300 Steel-Plate Composite (SC) Containment Vessel (SCCV) and Reactor Building Structural Design
- BWRX-300: Safety Strategy. The NRC and CNSC staff are reviewing a white paper on the Safety Strategy for BWRX-300.
The Safety Strategy incorporates selected guidance from the IAEA Safety Standards Specific Safety Requirements No. SSR-2/1, Revision 1, Safety of Nuclear Power Plants: Design.
- BWRX-300: fuel verification and validation. CNSC is leveraging previous USNRC reviews of the GNF2 fuel product in the CNSCs review of OPGs construction license application.
Next Steps
- Work with vendors and utilities to identify specific technical issues and perform joint reviews of topical reports and white papers in the pre-application phase
- Cooperate on the review of specific sections or topics in licensing applications.
12