ML22060A129
| ML22060A129 | |
| Person / Time | |
|---|---|
| Issue date: | 02/02/2022 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Burkhart, L, ACRS | |
| References | |
| NRC-1833 | |
| Download: ML22060A129 (289) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number: (n/a)
Location: teleconference Date: Wednesday, February 2, 2022 Work Order No.: NRC-1833 Pages 1-195 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 692ND MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +
8 WEDNESDAY 9 FEBRUARY 2, 2022 10 + + + + +
11 The Advisory Committee met at the Nuclear 12 Regulatory Commission, Two White Flint North, Room 13 T2B1, 11545 Rockville Pike, at 8:30 a.m., Joy L.
14 Rempe, Chairman, presiding.
15 COMMITTEE MEMBERS:
16 JOY L. REMPE, Chairman 17 WALTER L. KIRCHNER, Vice Chairman 18 DAVID A. PETTI, Member-at-Large 19 RONALD G. BALLINGER, Member 20 VICKI M. BIER, Member 21 CHARLES H. BROWN, JR., Member 22 VESNA B. DIMITRIJEVIC, Member*
23 GREGORY H. HALNON, Member 24 JOSE A. MARCH-LEUBA, Member 25 MATTHEW W. SUNSERI, Chairman 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 CONSULTANT:
2 STEPHEN SCHULTZ 3
4 DESIGNATED FEDERAL OFFICIAL:
5 QUYNH NGUYEN 6 MIKE SNODDERLY 7
8 9
10 11 12 13 14 15 16 17 *Present via teleconference 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 CONTENTS 2 Opening Remarks by the ACRS Chairman . . . . . . 4 3 North Anna Subsequent License Renewal 4 Application . . . . . . . . . . . . . . . . . . . 6 5 Lunch . . . . . . . . . . . . . . . . . . . . . . 60 6 Integration of Source Term Activities in 7 Support of Advanced Reactor Initiatives . . . . . 60 8 Committee Deliberation on Integration of 9 Source Term Activities in Support of Advanced 10 Reactor Initiatives . . . . . . . . . . . . . . 110 11 Adjourn . . . . . . . . . . . . . . . . . . . . 195 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 1 P-R-O-C-E-E-D-I-N-G-S 2 8:37 a.m.
3 CHAIRMAN REMPE: Good morning. This 4 meeting will now come to order. This is the first day 5 of the 692nd meeting of the Advisory Committee on 6 Reactor Safeguards.
7 I'm Joy Rempe, Chair of the ACRS. Member 8 in attendance are Ron Ballinger, Vicki Bier, Greg 9 Halnon, Walt Kirchner, Jose March-Leuba. We've got an 10 echo, hold on.
11 (Off record comments.)
12 CHAIRMAN REMPE: Okay. Jose March-Leuba, 13 Dave Petti and Matt Sunseri. Member Charles Brown 14 will be joining us shortly, he had some traffic issues 15 coming in.
16 And we expect, also, that Member Vesna 17 Dimitrijevic will be joining us shortly. However, I 18 note we do have a quorum.
19 Today the Committee is primarily meeting 20 in person with some ACRS Staff, NRC Staff and 21 participants attending virtually.
22 The ACRS was established by the Atomic 23 Energy Act and is governed by the Federal Advisory 24 Committee Act. The ACRS section of the U.S. NRC 25 public website provides information about the history 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 of this committee and documents, such as our charter, 2 bylaws, federal register notices for meetings, letter 3 reports and transcripts of open portions of our full 4 and subcommittee meetings. Including slides presented 5 at these meetings.
6 The Committee provides its advise on 7 safety matters to the Commission through its publicly 8 available letter reports.
9 The federal register notice announced this 10 meeting was published on December 28th, 2021. This 11 announcement provided a meeting agenda, as well as 12 instructions for interested parties to provide written 13 documents or request opportunities to address the 14 Committee. We have received no written comments or 15 requests to make oral statements from members of the 16 public regarding today's session.
17 A communications channel has been open to 18 allow members of the public to listen. Periodically, 19 the meeting will be open to accept comments from 20 participants listing to our meetings.
21 Written comments, if not provided 22 previously, may still be forwarded to Mr. Kent Howard, 23 the designated federal officer, for today's meeting.
24 During today's meeting, the Committee will consider 25 the following topics.
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6 1 North Anna subsequent license renewal 2 application, the NuScale topical report on the 3 building design and analysis methodology for safety 4 related structures. And the proposed rule language 5 for 10 CFR Part 53 Subpart F, related to Staffing, 6 personnel qualifications, training and human factors.
7 With respect to the NuScale topic, some 8 portions of the session may be closed to discuss 9 information that's proprietary to the licensee and its 10 contractors pursuant to 5 U.S.C. 552b(c)(4).
11 A transcript of the meeting is being kept.
12 And I request that speakers identify themselves and 13 speak with sufficient clarity and volume so that they 14 can be readily heard. Additionally, participants 15 should mute themselves when not speaking.
16 At this time I'd like to ask other Members 17 if they have any opening remarks? Seeing none, I'd 18 like to ask Member Sunseri to lead us through our 19 first topic for today.
20 MEMBER SUNSERI: Thank you, Chair Rempe.
21 Good morning. During this session we will hear from 22 Members of the NRC Staff and Dominion Energy on the 23 subsequent license renewal application for the North 24 Anna Power Station.
25 Our plant license renewal subcommittee met NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 1 with these folks on December 15th, 2021 and conducted 2 a thorough review of the topic. It's been our 3 intention to apply an internal ACRS lessons learned 4 for subsequent license renewal applications to shift 5 the Subcommittee review to the full committee when the 6 application doesn't have any outstanding items or open 7 issues.
8 This action would have the benefit of 9 reducing Staff, Applicant and ACRS resources on some 10 redundant aspects of the review. This was not the 11 case for this review as we had two unresolved 12 different views at the time of this subcommittee.
13 These different views have subsequently 14 been dispositioned, and I anticipate that we will hear 15 from Staff on this today. I look forward to the 16 future subsequent license renewal applications that we 17 can apply our lessons learned.
18 At this time, I'd like to invite Mr. Brian 19 Smith, director of division of new reactor licensing 20 for any comment. Brian, are you there?
21 MR. SMITH: Yes, sir, I'm here. Thank 22 you, Member Sunseri. And also, thank you, Chairman 23 Rempe and Members of the ACRS.
24 As you said, my name is I'm Brian Smith, 25 I'm the director of the division of new and renewed 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 licenses here in NRR.
2 We sincerely appreciate the opportunity 3 today to present to the ACRS the results of the 4 Staff's review on the fourth application for 5 subsequence license renewal. This application was 6 submitted by Virginia Power & Electric, or Dominion, 7 for the North Anna Power Station, Units 1 and 2 8 located in Louisa, Virginia.
9 By way of background. North Anna Units 1 10 and 2 received approval for their initial license 11 review from the NRC on March 20th, 2003. The NRC 12 review at that time was performed using guidance prior 13 to the issuance of the generic aging lessons learned 14 report, or the GALL report.
15 The NRC guidance for license renewal over 16 the years has evolved through enhancements and 17 improvements based on the lessons learned from NRC 18 reviews from both domestic and international industry 19 operating experience as well.
20 The GALL report has gone through two 21 revisions. An additional interim Staff guidance was 22 issued following Revision 2.
23 The guidance for subsequent license 24 renewal is contained in the GALL SLR report. This was 25 built from previous guidance and included additional 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 focus and enhancements were necessary on aging 2 management and time limiting aging analyses for the 3 operation in the 60 to 80 year period.
4 In the Staff's presentation today, you 5 will hear about some of the specific SLR issues as 6 applied to the North Anna review, and those requested 7 by the Subcommittee. Including the two differing 8 professional reviews.
9 The NRC project manager for the North Anna 10 subsequent license renewal application review is Lois 11 James. Lois will introduce the Staff who will be 12 presenting or addressing the questions regarding the 13 Staff's review.
14 Part of the management team here with me 15 today is Lauren Gibson, the chief of the license 16 renewal project branch, and branch chiefs for Staff 17 involved in the technical review, including Joe 18 Colaccino and Steve Bloom.
19 We also have with us representatives from 20 Region II, Stewart Bailey, chief of the reactor 21 project Branch IV, and the division of reactor 22 projects Region II. And Jen England, senior resident 23 inspector at North Anna.
24 I'd like to note that the Staff completed 25 its review with no confirmatory or open items in 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
10 1 safety evaluation report. The Staff will provide an 2 overview of its safety review and highlight a few 3 technical areas that may be of interest to the ACRS.
4 Finally, we will address any questions you 5 may have on the Staff's presentation. We look forward 6 to a productive discussion today with the ACRS.
7 At this time I'd like to turn the 8 presentation over to Mr. Paul Phelps, Dominion 9 engineering director for SLR to introduce his team and 10 commence the presentation.
11 MR. PHELPS: Thank you, Brian. Good 12 morning. My name is Paul Phelps and I am the 13 engineering director responsible for the North Anna 14 Power Station subsequent license renewal, or SLR 15 project.
16 We appreciate the opportunity to speak 17 with the ACRS full committee today on Dominion 18 Energy's application for subsequent license renewal.
19 This is a very important day and we appreciate the 20 support and look forward to presenting the SLR 21 application highlights to the committee.
22 By way of my background, I have been in 23 the nuclear industry for 30 years. I am responsible 24 for various SLR related projects that are currently 25 under development in Virginia.
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11 1 We have stood up an organization, not only 2 to perform the requisite work for the re-licensing, 3 for re-licensing the station, but we also have a 4 larger organization that is currently working on 5 projects to improve the safety, reliability and aging 6 management for North Anna Power Station through 7 various modifications.
8 I want to take the time to introduce the 9 team assembled to present the North Anna SLR 10 application. Paul Aitken is the engineering manager 11 responsible for the development of the North Anna SLR 12 application. Paul also led the team for the Surry 13 subsequent license renewal project.
14 Keith Miller is one of the team's project 15 managers. He has served in different roles within the 16 SLR team and is currently the project manager for 17 aging management programs.
18 Along with the team I introduced we have 19 senior station leaders on the virtual call as well.
20 I would like to recognize Lisa Hilbert, who is the new 21 site vice president at North Anna Power Station.
22 In addition, we also have technical Staff 23 available in the virtual audience, or in the room with 24 me, should we need some assistance on any questions 25 you may have during our portion of the presentation.
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12 1 If needed, they will identify themselves and address 2 your questions.
3 Next slide. I want to cover the agenda 4 for today's meeting. We will discuss the station 5 overview performance, SLR application development, SLR 6 aging management programs, technical topics and 7 closing remarks.
8 Next slide please. Here is an overview of 9 the station and the 50 mile radius. North Anna Power 10 Station is located in Louisa County Virginia adjacent 11 to Lake Anna. Lake Anna was constructed to serve the 12 needs of the station by damming the North Anna River.
13 The area includes both populated and 14 industrialized areas, as well as expansive rural 15 areas. And spans from Northern Virginia to the 16 suburbs south of our State Capitol, Richmond, and from 17 the upper Chesapeake Bay to the area west of 18 Charlottesville.
19 Included in this area are many military 20 installations and airports providing international 21 travel.
22 Next slide please. North Anna is a 23 Westinghouse three-loop pressurized water reactor 24 within an output net capacity of over 1,900 megawatts.
25 Together these two units are capable of producing 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 approximately 15 percent of Virginia's electricity 2 needs.
3 Unit 1 started commercial operational in 4 1978 and Unit 2 started commercial operation in 1980.
5 The independent spent fuel storage installation 6 facility recently had the site-specific licensed 7 renewed in 2018.
8 A 4.3 percent power uprate was implemented 9 in 1986, prior to the initial license renewal. The 10 renewed licenses for both Surry North Anna Power 11 Stations were issued in March of 2003. Lastly, North 12 Anna entered the period of extended operation in 2018 13 and 2020 for Units 1 and 2 respectively.
14 Next slide please. Here is some high 15 level information on the performance of North Anna.
16 To note, North Anna operates on a 18-month refueling 17 frequency. The plant capacity factor has been good, 18 as reflected in the bullets above.
19 As far as the regulatory oversight 20 process, North Anna is in column one and has been 21 there since 2013. Additionally, ROP indicator status 22 has been all green since 2000 for both Unit 1, in 2010 23 for Unit 2.
24 Next slide please. There has been 25 significant capital investments made to North Anna 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 since the first renewed license was issued in 2003.
2 As I mentioned in my opening remarks, Dominion Energy 3 will continue to invest in North Anna to maintain 4 safety and plant reliability for the current and 5 subsequent period of extended operation.
6 Here is the partial list of some of the 7 major projects that have been completed at North Anna.
8 I would like to highlight a few.
9 North Anna has performed a reactor vessel 10 head replacement on both units, replaced the reserved 11 station service transformers, which supply power to 12 the emergency buses, replace the main transformers on 13 both units, replace the main generators on both units, 14 and perform reactor vessel upflow conversion on both 15 units.
16 At this time I will transition the 17 presentation to Paul Aitken to provide an overview of 18 the SLR application development process.
19 MR. AITKEN: Next slide. Thanks, Paul.
20 And good morning to everyone. We're on Slide 7 now.
21 I'll be providing a quick overview of the 22 SLR application development process and other 23 considerations for the ACRS Committee today.
24 Surry and North Anna are considered sister 25 plants, based on the similarities and design 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
15 1 operation. I believe that the similarities between 2 North Anna and Surry allowed for a more efficient 3 review by the NRC Staff since many of the aging 4 management programs and supporting materials were 5 either the same or very similar.
6 For those three programs we are proactive 7 and implemented as many enhancements as we could for 8 North Anna that were identified during the Surry 9 application preparation and review. For every 10 procedure enhancement that we are able to implement 11 during North Anna application submittal, we increased 12 our alignment with the GALL, SLR and decreased the 13 number of enhancements the station would need to 14 implement upon issuance of the subsequent licenses.
15 In addition, the same Dominion project 16 team identified and examined any lessons learned from 17 the Surry review. Including audit questions and REIs 18 and incorporated those improvements into the North 19 Anna application as appropriate. Together this 20 resulted in reducing the overall number of REIs.
21 And lastly, through the issuance of the 22 four interim Staff guidance documents prior to the 23 North Anna submittal, the number of aging management 24 programs, with exceptions, were reduced by nearly half 25 in North Anna. Keith Miller will be providing 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
16 1 additional context for the Committee following my 2 presentation.
3 Next slide please. I'll provide a brief 4 summary on the differences between the first license 5 renewal and subsequent license renewal for the 6 Committee. For scoping and screening there are 7 minimal changes in the overall process approach. This 8 is primarily because of the established industry 9 criteria hasn't changed very much from first license 10 renewal.
11 One area that we expect it to have 12 adjustments was related to scoping and screening for 13 Alpha 2. That's non-safety, which can affect safety 14 related equipment.
15 This was due to the criterion guidance 16 evolving since first license renewal, as Brian 17 mentioned in his opening comments. North Anna, as 18 well as Surry, were pre-GALL plants so we were in the 19 same situation of updating the methodology and scoping 20 of plant additional equipment.
21 In the area of aging management reviews, 22 the expansion and the number of aging effects we had 23 to address significantly increased due to the vintage 24 of the previous application and the evolution of the 25 GALL over the years. During the aging management 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 review, our alignment with the GALL was 99.7 percent 2 with the use of industry footnotes alpha through echo 3 for the aging management reviews.
4 The biggest difference with an aging 5 management programs. Currently for first license 6 renewal we have 25 aging management programs. Moving 7 into subsequent license renewal there will be 48 aging 8 management programs.
9 In terms of aging management program 10 enhancements, these will be tracked within the 11 Dominion Energy commitment tracking system following 12 issuance of the renewed licenses.
13 Some commitment items have already been 14 addressed and Dominion Energy will ensure their proper 15 resources are in place to implement the commitments on 16 or ahead of schedule.
17 At this time, I'll hand the next portion 18 of the presentation over to Keith Miller to discuss 19 aging management programs and technical topics.
20 MR. MILLER: Thank you, Paul. Operating 21 experience was reviewed for a ten year period to 22 inform the aging management programs.
23 In addition to operating experience, 24 recent license REIs associated with the Surry, Turkey 25 Point and Peach Bottom SLR projects, as well as recent 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 first license renewal projects, were reviewed for 2 insights. Our project team also participated in the 3 Turkey Point, Peach Bottom and Oconee industry peer 4 reviews to provide AMP insights and share constructive 5 comments.
6 Prior to submittal of application 7 effectiveness of aging management activities was 8 assessed using evaluation elements identified in NEI 9 14-12, which provides industry guidance on AMP 10 effective missed reviews.
11 All first license renewal aging management 12 activities were continued and incorporated into SLR 13 AMPs. None were discontinued.
14 Next slide please. This slide gives you 15 a picture of the AMPs consistency with the GALL SLR.
16 Looking at the lefthand column there are 41 existing 17 AMPs that resulted from combination subdivision 18 process of the first license renewals AMPs.
19 The SLR existing AMPs are augmented by 20 seven new AMPs. The remainder of the column is to 21 provide some perspectives on our consistency with the 22 GALL SLR.
23 You can see there that approximately half 24 of the 48 SLR AMPs are consistent with GALL about 25 enhancement. About a third of the AMPs are consistent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 1 with enhancement. Three AMPs are consistent with 2 exception and four are consistent with exceptions and 3 enhancements.
4 So this in particular was a major 5 improvement from Surry. We went from 12 AMPs with 6 exceptions for Surry down to seven AMPs with 7 exceptions for North Anna.
8 On the next slide I'll provide some 9 context on the effectiveness of the first license 10 renewal AMPs. First license renewals AMPs have been, 11 and will continue to be, assessed for AMP 12 effectiveness.
13 AMP reviews, including in NEI 14-12, an 14 AMP effectiveness review confirmed implementation of 15 the first license renewal commitments and performed 16 assessments of inspection schedules, inspection 17 results and trending data. Any identified gaps were 18 addressed, were included in the corrective action 19 program.
20 Program owners receive periodic training 21 and are required to complete AMP effectiveness reviews 22 every five years, as well as perform systematic 23 operating experience reviews on an ongoing basis to 24 inform the aging management programs and augment AMP 25 effectiveness.
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20 1 And just as an indication of regulatory 2 acceptability of the Dominion Energy aging management 3 programs, the IP 71003 Phase two inspection identified 4 no findings or concerns in the fourth quarter of 2017.
5 Next slide please. In the subcommittee 6 meeting, we presented in some detail how Dominion 7 addressed four technical topics reflected on this 8 slide related to concrete and containment degradation, 9 reactor vessel internals, reactor vessel support steel 10 and reactor vessel embrittlement.
11 To summarize, we have developed our 12 various aging management programs to be consistent 13 with the GALL SLR guidance for each of these technical 14 topics. There has been no loss of license renewal 15 intended functions due to concrete aging since 16 entering the period of extended operation.
17 Dominion Energy has proactively addressed 18 alkaloid sulfur reaction aging by implementing the 19 EPRI alkali silica reaction inspection guidance. As 20 we discussed in the subcommittee meeting, ASR has not 21 been identified at North Anna based on inspections to 22 date. With the exception of precast concrete poles 23 that support overhead electrical circuits from the 24 reserve station service transformers to the turbine 25 building.
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21 1 There is a design change currently being 2 implemented that either replaces or refurbishes the 3 precast concrete poles. These poles were fabricated 4 offsite and their concrete is not representative of 5 the concrete used in other structures.
6 Next, the concrete, the containment 7 concrete biological shield wall, gamma and neutron 8 irradiation remains conservatively below GALL SLR 9 radiation exposure levels throughout the subsequent 10 period of extended operation. Also, recent 11 examinations of the concrete, of the containment liner 12 to concrete slab interface in 2016 did not identify 13 any degradation.
14 North Anna will manage the reactor vessel 15 internals consistent with MRP 227, Rev 1 Alpha 16 inspection and evaluation guidance that was issued in 17 December 2019 with its NRC safety evaluation for the 18 first period of extended operation. The reactor 19 vessel internals program also incorporates recent NRC 20 interim Staff guidance for updated aging management 21 criteria for reactor vessel internal components in 22 PWRs.
23 In addition, examinations for ten SLR 24 reactor vessel internal components are also 25 incorporated into the PWR vessel internals program, 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 consistent with MRP 2018-22 interim guidance, MRP 2 2019-9 interim guidance and WCAP 17451, Rev 2 3 guidance.
4 For reactor vessel support steel, Dominion 5 Energy determined that peak stresses for design basis 6 loads associated with the Units 1 and 2 reactor vessel 7 support assemblies are below the critical stress 8 limits for calculated through wall and/or surface 9 flaws based on projected fracture toughness through 10 the subsequent period of extended operation.
11 And lastly, we have developed fluence 12 projections for 80 years. Satisfactorily evaluated 13 reactor vessel material properties for 80 years. And 14 will perform surveillance capsule testing for each 15 unit prior to, and during, the subsequent period of 16 operation.
17 The applicability of existing heat up and 18 cool down curves can be extended to 72 effective full 19 power years based upon using updated material property 20 data and application of the K1c methodology is 21 currently included in the ASME code.
22 I will now turn the presentation back over 23 to Paul Aitken for closing remarks.
24 MR. AITKEN: Okay, thanks, Keith. I first 25 want to commend the NRC Staff on their efforts over NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 1 the last couple of years. The Staff has worked very 2 hard in reviewing the North Anna SLR application in 3 conducting the various public meetings with provided 4 the appropriate forum for stakeholder involvement.
5 I want to emphasize that Dominion Energy 6 has been engaged in integrative of the work leading up 7 to the GALL SLR issuance through our highly 8 experienced team. We have been heavily invested, 9 along with others in the industry, over the last 10 couple of years, to ensure we have the appropriate 11 guidance and have explored areas for optimization with 12 the NRC Staff.
13 Dominion Energy has developed a high 14 quality application for North Anna that benefit from 15 the insights and lessons learned gained from the Surry 16 application that I mentioned earlier.
17 As Paul Phelps mentioned in the opening, 18 Dominion Energy will continue to invest in North Anna 19 now and into the future to ensure the continued safe 20 and reliable operation for 80 years. This ends our 21 prepared remarks and I would like to express our 22 appreciation to the ACRS Committee for this 23 opportunity.
24 MEMBER SUNSERI: Thank you, Paul. I would 25 just comment, it's pretty remarkable that 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
24 1 entered the first extended period of operation and had 2 several inspections with no findings. How do you 3 attribute that success?
4 What are you doing, at least in your 5 opinion, that's maintaining the plant so well and 6 establishing such a high record with the inspection?
7 MR. AITKEN: I would say that starts at 8 the top. With Lisa and Fred Mladen, her predecessor, 9 setting the expectations and the tone on 10 implementation and execution.
11 And then through the involvement of the 12 SLR team coming in and looking at the work that was 13 done for first license, because we turn over a lot of 14 stones, as you know.
15 MEMBER SUNSERI: Right.
16 MR. AITKEN: So, we didn't have a lot of, 17 you know, we found some things, but when identified we 18 brought it to the attention of the station and things 19 were addressed. So the station is highly reactive and 20 was willing to listen and act. And I think that was, 21 really set the tone for a successful project.
22 MEMBER SUNSERI: Now that's good. At 23 least in my mind it goes beyond just this subsequent 24 license renewal. It's the care in which you take care 25 of the facility asset. And it's probably every NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 1 employee's engagement in some way so. I mean, it's a 2 real confidence builder from my perspective.
3 Let me turn to the other members. Any 4 members have any comments or other questions for 5 Dominion?
6 MEMBER HALNON: I have a couple of 7 questions.
8 MEMBER SUNSERI: Go ahead, Greg.
9 MEMBER HALNON: On Slide 8, this is Greg 10 Halnon by the way. On Slide 8 you said that the first 11 license renewal only had 25 AMPs and the second 12 license renewal 48.
13 And on Slide 10 you said that there is 41 14 existing programs. Could you just explain the 15 difference between those numbers for me?
16 MR. MILLER: Yes. This is Keith Miller 17 from Dominion again. So, there were 25 programs 18 associated with first license renewal.
19 Some of those programs were subdivided 20 into other programs and subsequent license renewal 21 space. So an example, I can give a couple examples.
22 There were, the chemistry aging management 23 activity in first license renewal space was subdivided 24 into water chemistry and subsequent license renewal, 25 as well as lube oil and one other AMP as well. 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
26 1 while there were 25 programs on paper for first 2 license renewal, many of those same activities are 3 being continued in subsequent license renewal space.
4 Now, there were seven new programs in 5 subsequent license renewal space that we really didn't 6 have a corollary for in first license renewal. Four 7 of those were related to electrical programs and three 8 were mechanical.
9 MEMBER HALNON: Okay. So it's only seven 10 new programs were written, the other, say 25 or 41, 11 whatever you want to call it, they were existing 12 programs that you're already tracking --
13 MR. MILLER: Correct.
14 MEMBER HALNON: -- information. Okay. So 15 you'll have that much data already in an established 16 database.
17 The second question, since subsequent 18 license renewal period of operation is down the road 19 a ways, what are your top concerns relative to 20 equipment issues that you might be looking at 20 years 21 down the road here?
22 MR. MILLER: Looking into the future, 23 based on the inspections and condition monitoring that 24 we're doing, I can't say anything jumps out. I think 25 selective leaching in the industry is something 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
27 1 we're dealing with. In particular, in buried pipes.
2 So I would say that would be in the area that's 3 probably the one that jumps to the top.
4 And as far as the internals, I think 5 that's working its way through EPRI and the NRC. I 6 think even Rev 2 has been provided to the NRC with 7 additional guidance for 80 years of operations. And 8 that will be reviewed. So we feel good about that.
9 We've had good inspection results at both Surry and 10 North Anna.
11 So, I guess to answer your question simply 12 would be the selective leaching and buried pipe.
13 MEMBER HALNON: Okay. So how, you 14 probably could, well, you got a cathodic protection 15 program, how is that, how is the data in the cathodic 16 protection looking?
17 MR. MILLER: So we --
18 (Simultaneous speaking.)
19 MR. MILLER: Yes, I'm sorry, I didn't mean 20 to cut you off.
21 MEMBER HALNON: No, go ahead. Go ahead.
22 You got it.
23 MR. MILLER: Yes, we do have a cathodic 24 protection system. We do have a couple of subsystems 25 that have been not meeting expectations, and there 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
28 1 enhancements in the application to get those restored 2 to working condition.
3 MEMBER HALNON: Okay. And then I assume 4 those obviously will be in the corrective action 5 program?
6 MR. MILLER: That's correct.
7 MEMBER HALNON: On the radars of the NRC.
8 MR. MILLER: It is definitely on the 9 radar. Right.
10 MEMBER HALNON: Thank you.
11 MEMBER SUNSERI: Any other Members? Yes, 12 Dr. Steve Schultz, our consultant, has a question. Go 13 ahead, Steve.
14 DR. SCHULTZ: This is Steve Schultz.
15 Paul, I think the question is for you. You mentioned 16 that the program managers have a responsibility to 17 assess their programs and report on a five year 18 interval. Is that done altogether or is each program 19 responsible for their own schedule associated with 20 that?
21 And if it's the latter, how is that 22 reporting coordinated within the plant?
23 I know there's a lot of crosstalk between 24 the program managers, but can you describe that in 25 more detail?
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29 1 My second question is, you mentioned in 2 the presentation that the major inspection associated 3 with the original license renewal was done in 2017.
4 How are you coordinating with the NRC on what you 5 would expect to be, this may be a question for the 6 Staff, but how you would coordinate your program 7 manager's assessments and reports with the NRC 8 inspections, what you would anticipate in the near 9 future associated with the current license renewal?
10 MR. MILLER: This is Keith Miller again.
11 On the first question related to AMP effectiveness 12 reviews, historically the station has done those all 13 at once for all the programs. So it would be one 14 concerted effort to do those, to do those reviews at 15 once rather than kind of staggering them on a program 16 basis.
17 Administratively it's a lot easier to do 18 it that way. I think typically they actually track it 19 through the corrective action program so the initiated 20 condition report, and then individual actions for each 21 of the program owners to do the reviews.
22 And then as far as future NRC interaction 23 inspection I would probably turn to the NRC Staff on 24 that. All those, the NRC inspections are coordinated 25 through the licensing group at the station.
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30 1 But I think that would be really, I guess, 2 spearheaded by the NRC Staff as opposed to the station 3 initiating it. But maybe you could, maybe I'm not 4 understanding the question.
5 DR. SCHULTZ: That's a fine answer to the 6 question. I'll wait for the Staff to respond to that.
7 When was your last report published, 8 associated with the current license review? Or is 9 this a new program, the five year commitment that you 10 have within the station?
11 MR. MILLER: The five year commitment has 12 been existing. It's procedurally driven. It's, as 13 stated in the plant procedure, these reviews are done 14 every five years.
15 Looking back, I think that the last one 16 was done in 2019 time frame. Or 2020. It's been 17 relatively recent. But I would have to go back to get 18 the exact year for you on that.
19 DR. SCHULTZ: That's fine. Thank you.
20 MR. AITKEN: Can I --
21 DR. SCHULTZ: And as you, go ahead.
22 MR. AITKEN: Yes, this is Paul. Just to 23 add on to what Keith was saying.
24 So yes, we were cut off so I couldn't 25 answer your question, Keith jumped in. So yes, what 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 we try to do is all of these at one time. And we use 2 the guidance, you heard us reference the NEI document 3 14-12.
4 And that was an industry initiative that 5 was put forward back as we were starting subsequent 6 license renewal to address the elements of an 7 effectiveness review. What should be some of the 8 objectives that should be considered.
9 So as we start off, we setup the 10 objectives for all the aging management programs, for 11 everybody to looking for the same types of things.
12 And that's all correlated at the end and assessed.
13 So as Keith said, I think there was, yes, 14 maybe 2019. Our last one was done. And you find 15 administrative things in a procedure that doesn't have 16 this or that. And we put that in a corrective action 17 program and get that tidied up.
18 But there was nothing significant that 19 came out of it. And I think that was just reinforced 20 by the region inspection.
21 Because Unit 2 entered the period of 22 extended operation in August of 2020 and ironically we 23 submitted just a couple of days later. So we went 24 ahead and did that work, just to give us the 25 confidence that as we proceeded through 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
32 1 application submittal and the review that we had 2 confidence in the aging management program 3 implementation from first license renewal.
4 DR. SCHULTZ: So you've had your 5 corrective action program associated with the last 6 review. If you take a look at what was proposed as 7 corrective action from that review, I presume at this 8 point they're relatively all completed?
9 What's your record on --
10 MR. AITKEN: Yes, generally --
11 DR. SCHULTZ: -- resolving those comments?
12 Those corrective actions?
13 MR. AITKEN: Yes. I don't, I can't speak 14 with hundred percent confidence, but just through the 15 track record at North Anna they're quick to resolve.
16 Because a lot of the things were just 17 administrative, as I mentioned. So they report in, 18 they're tracked by management and things are driven to 19 closure. So I have a high degree of confidence. If 20 not all, most are actually completed by this time.
21 DR. SCHULTZ: Thank you.
22 MR. AITKEN: Yes, sir.
23 MEMBER SUNSERI: Thank you. Now at this 24 time we will transition to the NRC Staff. Brian, I'll 25 ask you to queue up your team.
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33 1 MR. SMITH: All right.
2 MS. JAMES: Good morning.
3 MR. SMITH: Lois, go ahead.
4 MS. JAMES: Good morning, Chairman Rempe, 5 and Members of the ACRS. My name is Lois James and I 6 am one of the senior licensed renewal project managers 7 in the office of nuclear reactor regulations, or NRR.
8 We are here today to discuss the Staff 9 safety review of the North Anna Power Station, or 10 North Anna, subsequent license renewal review 11 application, or SLRA, and documented in the safety 12 evaluation report, or SER.
13 Joining me today are On Yee, technical 14 reviewer for the license renewal review, Steve Bloom, 15 chief of the corrosion and steam generator branch in 16 NRR, and Jen England, North Anna senior resident 17 inspector. Also joining us today are members of the 18 technical and regional Staff, including Lauren Gibson, 19 chief of the license renewal projects branch, Angie 20 Buford, chief of the vessels and internals branch, and 21 Joe Colaccino, chief of the structural civil and 22 geotech engineering branch.
23 I went one too far. We will begin today's 24 presentation with an overview of the North Anna 25 licensing history before moving on to the North Anna NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 1 aging management programs. We will then discuss a few 2 technical areas that we believe are of interest to the 3 ACRS, and hear from Region II on the inspections and 4 plant material conditions before sharing the Staff's 5 conclusion of the safety review.
6 The North Anna SLRA, oops. North Anna 7 Units 1 and 2 were initially licensed in April 1978 8 and August 1980, respectively. In May 2001 the 9 Applicant, Virginia Electric Power Company, or 10 Dominion, submitted the initial license renewal 11 application.
12 The initial license, renewed licenses were 13 issued on March 2003 extending the expiration date to 14 April 2038 and August 2040 for Units 1 and 2, 15 respectively.
16 On August 24th, 2020 Dominion submitted an 17 SLRA for North Anna Units 1 and 2. The application 18 was accepted for review on October 15th, 2020. And 19 the final safety evaluation report was issued on 20 January 3rd, 2022 with no open or confirmatory items.
21 The North Anna SLRA described a total of 22 48 AMPs. Seven new and 41 existing. This slide 23 describes the Applicant's original disposition of 24 these AMPs, as stated in the SLRA in the left column.
25 The final disposition, as documented in the SER, 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
35 1 the right column.
2 All of the AMPs were evaluated for 3 consistency with a generic aging lessons learned 4 subsequent license renewal review, or GALL SLR report.
5 As a result of its review, the Staff documented one 6 Staff identified exception in the neutron fluence 7 monitoring program in the SER. This accounts for the 8 difference in the existing programs. One program 9 moved from consistent to consistent with enhancements 10 and/or exceptions.
11 Based on the review, the results of the 12 audit, and additional information provided by the 13 Applicant, the Staff concluded that the Applicant's 14 aging management program activities, and results, were 15 consistent with the criteria of the standard review 16 plan and requirements of 10 CFR Part 54.
17 Since the final SRA was issued, or SER was 18 issued with no open or confirmatory items, we will 19 highlight some specific areas of the review we thought 20 would be of interest to the ACRS. The first two 21 topics are technical areas of general interests. The 22 last topic is a plant-specific item that was 23 identified during the Staff's review and received two 24 nonconcurrences.
25 I will turn the presentation over to On NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 1 Yee to discuss the first two topics, then Steve Bloom 2 will discuss the last. On.
3 MR. YEE: Good morning. My name is On 4 Yee. This next topic on RPV embrittlement has two 5 aspects.
6 The first is related to the adequacy of 7 the Applicant's reactor vessel material surveillance 8 program, which is addressed on this slide, and the 9 second is related to the disposition of the vessel 10 embrittlement time limited aging analyses for the 80 11 year operating period. Which will be addressed on the 12 next slide.
13 This slide identifies the peak reactor 14 vessel fluence levels for each unit on the left, which 15 are in access of seven times ten to the 19th neutrons 16 per centimeter squared on the vessel inter-diameter 17 surface.
18 The Applicant has identified the 19 withdrawal and testing of one capsule at each unit to 20 assess vessel embrittlement at the 80 year fluence 21 levels. As indicated, testing of these capsules will 22 occur within the next five years.
23 On the right side of the slide we plotted 24 the completed surveillance testing and the plant 25 testing for North Anna Unit 1. The graph for Unit 2 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 is nearly identical to this.
2 The axes on these graphs are calendar 3 years on the x-axis and neutron fluence on the y-axis.
4 The blue dash lines represent the 60 year vessel 5 fluence and the end of the current 60 year license.
6 The solid green lines represent the same quantities 7 for 80 years. The solid black data points provide the 8 neutron fluence and the test date for the prior tested 9 capsules.
10 The orange symbols represent the 11 Applicant's change in testing of a capsule to obtain 12 the 80 year fluence. In this case, the Applicant will 13 test the capsule located at a higher neutron flux 14 location and will acquire data for a 80 year fluence 15 level earlier than originally planned.
16 Next slide please. For the TLAs, time 17 limiting aging analyses, certain RPV materials at Unit 18 2 were projected to exhibited upper shelf energies at 19 or below the 50 foot pound limit required in Appendix 20 G, to 10 CFR Part 50.
21 As a result, the Applicant performed 22 equivalent margin analyses for these RPV materials, as 23 well as additional RPV materials, out of conservatism 24 for both units. Regarding pressurized thermal shock, 25 the Applicant projected its PTS evaluations to the end 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 of the subsequent period of extended operation and 2 demonstrated all of the RPV materials meet the 3 screening criteria in 10 CFR 50.61.
4 The Applicant has demonstrated upper shelf 5 energy and pressurized thermal shock TLAs have been 6 projected to the end of the subsequent period of 7 extended operation in accordance with 10 CFR 8 54.21(c)(1)(ii).
9 Next slide please. This topic is related 10 to radiation of reactor vessel internals. There is no 11 Staff approved topical report or generic methodology 12 for aging management of PWR vessel internals for 80 13 years of operation.
14 The GALL SLR report, as updated by recent 15 interim Staff guidance in 2021, finds it acceptable 16 for the Applicants to use the Staff approved guidance 17 for six years, and MRP 227 Revision 1-A in combination 18 with the plant specific gap analysis to identify 19 appropriate changes to the inspection program for 80 20 years.
21 For the assessment of neutron fluence 22 projections for the vessel internal components at 72 23 effective full power years, the Staff reviewed the 24 fluence projection methodology and exposures to the 25 internals as part of its review of the aging NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 1 management program and the Applicant's gap analysis.
2 From its audited information, the Staff 3 verified that the neutron fluence methodology and the 4 calculated fluence values for the PWR vessel internals 5 are acceptable. The Staff also verified that 6 component specific fluence exposures for 72-EFPY were 7 adequately addressed in the Applicant's gap analysis 8 and aging management program.
9 The Staff determined the PWR vessel 10 internals programs is consistent with the GALL SLR 11 report, as modified by the recent interim Staff 12 guidance and adequately addresses inspection of PWR 13 internals during the subsequent period of extended 14 operation.
15 I will now turn the presentation over to 16 Steve Bloom. Next slide please.
17 MR. BLOOM: Good morning. My name is 18 Steven Bloom. The plant-specific buried and 19 underground piping and tanks aging management program 20 addresses the buried gray cast iron piping in the fire 21 protection system. This piping had six ruptures prior 22 to 2003, with the root caused identified as cracking 23 initiated due to manufacturing defects due to cyclic 24 loading that occurred during pump start testing.
25 The plant changed the test procedures 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
40 1 limit the pressure transient in the downstream piping, 2 and no ruptures have occurred since 2003. Multiple 3 inadvertent pipe starts have occurred since 2003 4 within out any additional ruptures occurring.
5 The 14-12 iron piping material is also 6 subject to loss of material due to selective leaching.
7 And the material was identified in Dominion documents 8 as brittle from impact testing.
9 Next slide please. The Applicant provided 10 two enhancements to the buried and underground piping 11 and tanks program directed towards management of 12 selective leaching in Enhancement 5, and also cracking 13 due to cyclic loading in Enhancement 6.
14 For these enhancements, the Applicant 15 committed to excavate six gray cast iron locations of 16 each unit, in each ten year operating period prior to 17 entering the subsequent period of extended operation.
18 So, a total of three periods under which they would be 19 excavated.
20 Five of these excavations will be ten foot 21 blanks of piping. The remaining excavation will be 22 either a pipe or component location, for example, a 23 hydrant location, with a focus on identification of 24 selective leaching in that fifth location.
25 For the piping locations, the Applicant 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 will use visual and magnetic particle testing to 2 inspect for cracking on both the inside diameter and 3 outside diameter of the piping. If cracks are 4 identified, the Applicant will perform a radiographic 5 non-destructive examination on these areas.
6 In addition, if no pipings are identified, 7 a one foot axial piece will be removed and de-8 structurally examined for loss of material due to 9 selective leaching. If cracking is identified, then 10 a one foot section will be selected and destructively 11 tested to identify cracking due to cyclic loading, and 12 also inspected for loss of material due to cyclic 13 loading.
14 If the cause is from manufacturing flaws 15 and not age related degradation mechanism, then the 16 results from these inspections will be documented. If 17 the cyclic loading cracking is identified as due to 18 aging, then the Applicant will perform additional 19 evaluations that will cover through the end of 20 subsequent period of operation.
21 If these evaluations project a loss of 22 function prior to the end of subsequent license, a 23 period of extended operation, this finding will be 24 entered in the Applicant's corrective action program 25 for an evaluation of extent of condition and extent of 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 cause and to identify any needed follow-on actions.
2 The Staff found these enhancements to be 3 adequate to find reasonable assurance that the piping 4 will perform its intended function during the period 5 of extended operation.
6 Next slide please. At this point I would 7 like to note that we did receive two nonconcurrences 8 during the review. Management has addressed both 9 nonconcurrences and the resolution of the issues are 10 identified in the final safety evaluation package in 11 ADAMS.
12 In addressing the first nonconcurrence, 13 additional justification was added to the Staff's 14 findings in this section of the SER. These changes 15 were included in the draft SER.
16 In evaluating the second nonconcurrence, 17 management agreed that the FSAR supplement did not 18 provide, did not sufficiently match the program 19 description that Dominion provided in the supplements 20 and previous REI responses. The Staff issued an REI 21 to Dominion to update the FSAR supplement. Dominion 22 provided its response and the Staff updated the 23 discussion in the final SER.
24 I will now turn over the presentation to 25 Jen England, who will discuss the regional inspection 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 activities and plant material conditions. Next slide 2 please.
3 MS. ENGLAND: Good morning. As mentioned, 4 my name is Jennifer England. I am the Acting Senior 5 Resident Inspector at North Anna. With me is Kenya 6 Carrington, the North Anna Resident Inspector, and 7 Stewart Bailey, our Branch Chief.
8 We are here to provide Region II's review 9 and assessment of the implementation of the Aging 10 Management Programs, Material Condition, and Overall 11 Regulatory Assessment of North Anna Units 1 and 2.
12 The License Renewal Inspection Program and 13 the Reactor Oversight Baseline Inspection Program are 14 both used to inspect aging management activities at 15 North Anna.
16 I will start with the activities performed 17 under the License Renewal Inspection Program, then 18 discuss the ROP inspections, and follow up with the 19 material condition of the plant.
20 In order to assess the adequacy of the 21 license renewal program for the initial period of 22 extended operation Inspection Procedure 71003 23 recommends using a four-phase approach to license 24 renewal inspections.
25 This slide lists the specific license 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 renewal inspections that have been performed at North 2 Anna. The Phase 1 and 2 inspections were performed 3 for both units on the dates listed with no findings 4 identified.
5 Phase 3 inspections were not required 6 because no findings were identified in Phase 1 or 2.
7 Finally, the Phase 4 inspections, which typically 8 occur five to ten years into the period of extended 9 operation, have not yet been performed at North Anna 10 as the period of extended operation began in 2018 for 11 Unit 1 and 2020 for Unit 2.
12 Next slide, please. In addition to the 13 inspections mandated by the License Renewal Inspection 14 Program, inspectors use several ROP baseline 15 inspection procedures to evaluate the implementation 16 of aging management activities.
17 One example is the baseline inspection of 18 the In-Service Inspection Program. This inspection is 19 performed each refueling outage and provides the 20 inspectors the opportunity to review and assess 21 inspections credited for aging management.
22 The second example is the heat sink 23 inspection, which provides the inspectors an 24 opportunity to review the service water system, 25 including heat exchangers, the service water intake 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 structure, and both above ground and buried or 2 inaccessible piping and components.
3 All of these activities are within the 4 scope of license renewal. Additionally, the Design 5 Basis Assurance Inspection, or DBAI, includes a review 6 of the aging management activities for the safety 7 structure systems and components selected.
8 At North Anna the regional inspectors have 9 found no violations or findings of greater than green 10 significance as a result of the inspections performed 11 using these procedures.
12 Also of note, the triennial fire 13 protection procedure has recently updated to review 14 aging management of this equipment.
15 Next slide, please. Currently, North Anna 16 Units 1 and 2 are in the licensee response column and 17 have all green findings and performance indicators.
18 This indicates that the licensee has been 19 able to effectively identify conditions adverse to 20 quality and correct them in a timely manner.
21 We reviewed all inspection findings and 22 trends over the last ten years to gain insight related 23 to aging components. We have identified two findings 24 with an aging management aspect.
25 In 2013 the NRC issued a finding for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 1 failure to replace capacitors in the turbine control 2 system. Specifically, Capacitor C in the speed 3 amplifier card failed leading to a reactor trip.
4 The cause of the failure was due to aged 5 degradation of the capacitor. Since the time of this 6 failure this control system has been replaced with a 7 digital system for both units.
8 In 2021 the NRC identified a green finding 9 in a non-cited violation for inadequate instructions 10 for handling of aged cables. The procedure did not 11 identify the allowable bend radius for battery 12 cabling.
13 If a cable is bent with a small radius the 14 cable insulation can crack over time. The licensee 15 has corrective actions to address the radius of 16 cables.
17 Next slide, please. I will now speak to 18 the material condition of North Anna from the resident 19 inspector viewpoint. We have no concerns with the 20 overall material condition of the plant that need to 21 be addressed outside the baseline ROP.
22 The license has been successful at 23 completing large capital improvement projects that 24 maintain or improve the material condition of its 25 structure systems and components.
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47 1 The License Renewal Program inspections 2 did not identify any substantial weaknesses in the 3 station's performance in managing the effects of aging 4 at the site.
5 The inspectors will continue to inspect 6 and assess the licensee's ability to manage the aging 7 through the baseline inspections. Are there any 8 questions?
9 MEMBER SUNSERI: This is Matt. I have one 10 for you, Jen. You know, this is I guess directly 11 related to your experience being on the site and being 12 the person that gets to see the equipment performance 13 and how it's being maintained and everything through 14 direct observation, which a lot of us don't get that 15 opportunity, right, we just see it remotely or read 16 about it in reports.
17 So regarding the fire protection system 18 piping and, you know, there were different views on 19 how to address that, from your observation of how that 20 equipment is being maintained and what is expected to 21 be done with it going forward do you see those as 22 effective measures for managing the aging of that fire 23 protection piping?
24 MS. ENGLAND: Yes, I believe it is 25 effective. Our technical experts from the regional 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 office have also looked into this issue and we will 2 continue to monitor it.
3 I don't know if anyone else would like to 4 add anything from our side.
5 MEMBER SUNSERI: It's been a number of 6 years since there has actually been a failure, I think 7 2003, something like that.
8 MS. ENGLAND: That's correct. And there 9 has been several inadvertent starts which have not 10 resulted in any additional failures.
11 MEMBER SUNSERI: Okay. All right. Thank 12 you.
13 VICE CHAIRMAN KIRCHNER: Matt?
14 MEMBER SUNSERI: Yes, Walt?
15 VICE CHAIRMAN KIRCHNER: Yes, this is Walt 16 Kirchner. Just following on, looking ahead, not North 17 Anna per se, but is the Staff seeing this as a common 18 problem throughout the license renewals and subsequent 19 license renewals for the plants?
20 It seems to me, if I memory is correct, we 21 saw this on Surry. I am returning to the buried gray 22 cast iron piping. Does that suggest that some kind of 23 guidance going forward for new plants or reworking 24 existing plant fire mains and such should be looking 25 at different materials?
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49 1 MR. BAILEY: So this is Stewart Bailey.
2 I was wondering if I could ask NRR to chime in on 3 that. There is a broader industry experience related 4 to failure of these systems, but I don't know exactly 5 what the Agency is doing about it at this time.
6 MEMBER BALLINGER: This is Ron Ballinger.
7 I'll just make a comment. Gray cast iron pipe, buried 8 piping, is not just a problem in the nuclear industry, 9 it's a problem everywhere.
10 If you go to the American Water Works 11 website you'll discover that. Piping, gray cast iron 12 piping with selective leaching, which is hard to 13 determine where it is, 80 to 100 years before you 14 start getting failures.
15 And so what has happened here is they have 16 just accelerated the problem by pump starts, and so I 17 think the inspection program that they have identified 18 is as good as it's going to get.
19 Will there be random failures going 20 forward? Yes. Well, you can't 100 percent inspect 21 everything and sooner or later they're going to have 22 a failure but it's not for lack of them trying to get 23 a handle on it.
24 But what Walt's saying is people are 25 replacing the pipe. But replacing pipes at plants 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 where they are buried in concrete in some cases is a 2 really tough problem to do. It's as good as they're 3 going to get.
4 MR. SMITH: Hi. This is Brian Smith.
5 Thanks for asking the question and raising the issue.
6 We recently decided to start an update to the GALL SOR 7 report, a revision to that similar to what we did for 8 just the regular GALL report some years back.
9 As part of that we had planned to do a 10 lessons learned. So this can be one of the items that 11 we'll focus on as we go forward and in developing the 12 updated guidance. So, thank you.
13 MEMBER BALLINGER: Yes. There are EPRI 14 programs that are ongoing right now to develop 15 techniques for detecting selective leaching as a 16 function of chemistry and the like.
17 It's a tough -- You know, you see it, you 18 know it's there, but to decide whether a material will 19 be susceptible is a little bit trickier. So there are 20 EPRI programs that are ongoing in this area as well.
21 MEMBER SUNSERI: Okay. Very good. Do we 22 have any other questions for the Resident Inspector 23 before we move on?
24 MEMBER HALNON: Yes, I have a couple.
25 MEMBER SUNSERI: Okay. Go ahead, Greg.
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51 1 MEMBER HALNON: So, Jen, we talked earlier 2 with the Staff, the North Anna Staff, about the 3 protection program. Is it on your radar screen? Have 4 you been looking at that since they've said they felt 5 themselves that they had not met expectations?
6 MS. ENGLAND: Yes. We are always focused 7 on service water piping and any time we can get access 8 into a manhole, this is just something that all 9 residents spend their time on. Yes, so we are 10 definitely focused on that.
11 MEMBER HALNON: Okay. Many plants have 12 cable vaults outside in the yard that often get 13 flooded and have to be pumped out.
14 Is there any concern there with the, I 15 hesitate to say climate change, but with the increased 16 weather activity that we are having on the east coast 17 relative to their program and how they make sure that 18 there is not a wetted cable issue that's out in the 19 yard?
20 MS. ENGLAND: Yes. Like I said, every 21 time you have the ability to access a manhole, this is 22 very typical for us to go in there and look at it for 23 things such as wetted cables.
24 We also do look at it annually as part of 25 our external flooding procedures. I do not -- I can't 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 speak to climate change, but from all the things that 2 I have looked at, so their last two inspections of 3 manholes and things of that nature, I don't see a 4 significant negative trend, but, obviously, we are 5 always looking at it and we are always asking 6 questions.
7 We're inspectors so we're never actually 8 satisfied.
9 MEMBER HALNON: Okay. So I guess I'll 10 ask, you can just make a judgment, do they have a 11 robust program to make sure that those manholes are 12 pumped out and dried out after weather?
13 MS. ENGLAND: Yes. So it looks like any 14 manhole that -- Every manhole is inspected on a 3-year 15 basis. Any manhole that any water is found in, more 16 than 12 inches, they will install a sump pump from 17 what I can tell, which appears to be pretty robust in 18 my opinion.
19 MEMBER HALNON: Okay. Thank you.
20 MEMBER BROWN: Hi. This is Charlie Brown.
21 I had one question I guess, and maybe I should have 22 brought it up at the Subcommittee but I didn't.
23 As a result of the earthquake some years 24 ago, obviously buried piping is susceptible to damage, 25 possibly even damage that's not evident immediately 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
53 1 even a few years later, was there any effort to try to 2 assess whether an enhanced inspection program should 3 be applied to this buried cast iron piping as opposed 4 to just the routine?
5 I don't know if that's the Staff or 6 Dominion to answer that, but that was the only 7 question I had.
8 MS. ENGLAND: I do not have the answer to 9 that. I don't know if someone else would like to 10 comment.
11 MEMBER BROWN: Is there a reason that 12 there wouldn't be any need to do that? I'm not a 13 stressed, you know, piping expert, but it was pretty 14 -- I felt it all the way up at my house. My house was 15 rattling and shaking.
16 MEMBER SUNSERI: Yes. I don't know where 17 I've heard this, but I know that North Anna went 18 through a very extensive review, like a top to bottom 19 review.
20 MEMBER BROWN: Well I remember that, yes, 21 for the, I mean after the earthquake.
22 MEMBER SUNSERI: But I don't know 23 specifically about the pipes.
24 MEMBER BROWN: I was just looking at 25 downstream.
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54 1 MEMBER SUNSERI: Yes.
2 MEMBER BROWN: You know, you might not 3 find anything today but is there something incipient 4 in --
5 (Simultaneous speaking.)
6 MEMBER SUNSERI: Maybe we could ask 7 Dominion Energy if they have a response to that 8 question. Paul, if you're still on?
9 MEMBER BROWN: You're still there, 10 Dominion?
11 MR. PHELPS: Sorry. We have to come off 12 mute here. So, yes, we had, you know, we're going 13 back in time here so it's difficult, but there was 14 obviously a confirmatory action whether it was a 15 series of activities and actions and I just don't 16 recall.
17 All I can maybe state is the fact that 18 since the earthquake, ten years, 11 years now we're 19 at, we haven't had any issues. So I think if there 20 was something that may have caused some disturbance to 21 the buried pipe, as Jen said, in some of the 22 autostarts that we've had and the normal testing that 23 we would have done, we probably would have seen 24 something by now.
25 So that might not be the best answer, but 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 that's probably all I can offer at this point.
2 MEMBER BROWN: Okay. I just wondered if 3 somebody assessed any. We're looking at another 20 4 years, and so that's why I asked the question. If 5 that's what we got, that's what we got. Thank you.
6 MR. PHELPS: Yes, sir.
7 MEMBER SUNSERI: I would imagine that the 8 inspection program that they have if it would see, you 9 know, other things from that if it existed.
10 MEMBER BROWN: Yes, I would hope so. I 11 just -- It just dinged my brain when I was looking 12 through it again, do we need to do any, do we need to 13 think about it a little harder going out for another 14 20 years recognizing we didn't see anything in the 15 past ten.
16 MEMBER SUNSERI: Yes. But that --
17 (Simultaneous speaking.)
18 MR. PHELPS: So, Charlie, this is Paul.
19 Yes, I'm sorry. Yes, one of my tech staff said that 20 we've done six or seven fire protection buried pipe 21 inspections in the teen years and we have not seen any 22 issues, so I just want to offer that up to the 23 Committee.
24 MEMBER BROWN: All right. No, that's a 25 reasonable approach to seeing if you had anything 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
56 1 the near future with whatever is coming up, so thank 2 you.
3 MEMBER SUNSERI: Any other questions for 4 the Resident before we move on?
5 (No audible response.)
6 MEMBER SUNSERI: All right. Steve 7 Schultz?
8 DR. SCHULTZ: This is Steve Schultz. Jen, 9 a question for you, or a comment first. When you 10 present the slides about the results of inspections 11 stating no findings, no findings, no findings, I think 12 it's important to understand how detailed your 13 inspections, in fact, have been and how well the 14 documentation of those inspections has been completed.
15 Very thorough reports of very intense 16 inspections, so that result is a good one to see here.
17 The other is a question, and following on to my 18 comments to Dominion, you've focused on the fact that 19 the ROP baseline inspections and your other resident 20 activities really do focus continuously on the aging 21 management programs.
22 But would it be worthwhile to coordinate 23 a particular license renewal related inspection 24 following the licensee's approach to do their five 25 year evaluation and reporting and then evaluate 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 corrective action program that would result from that 2 and its effectiveness?
3 MS. ENGLAND: We get to select the samples 4 that we look at on a periodic basis and, yes, I agree 5 that would probably be a very good sample to take.
6 Does that answer your question?
7 DR. SCHULTZ: Yes. Thank you.
8 MS. JAMES: This is Lois James. If I 9 could add, Jen, if I am not mistaken when we do our 10 Phase 4 that is going to look at effectiveness which 11 will particularly prompt us to look at how they have 12 looked at their effectiveness.
13 So I think that, you know, it will 14 definitely caught, more than likely get caught in the 15 resident review, but also get caught when we do the 16 Phase 4.
17 DR. SCHULTZ: Thank you for the additional 18 comment, Lois.
19 MS. CARRINGTON: This is Kenya Carrington, 20 the Resident. I will also add that as the licensee 21 has been going through their subsequent license 22 renewal we have engaged with the Staff and 23 Headquarters just to try to gain a better 24 understanding on our part and additional insights as 25 we go out into the field and perform our inspection NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 1 and vice versa.
2 DR. SCHULTZ: I am glad to hear that. The 3 licensee talked a lot about their training program.
4 Well not a lot, but they mentioned, and I know they do 5 a lot of work associated with the training of the 6 program managers for the aging management program, so 7 I am glad to hear that is happening on the Staff's 8 side also. Thank you.
9 MEMBER SUNSERI: Thank you all. Jen and 10 Kenya, we appreciate the fact that you are there 11 onsite and obviously we have a lot of interest in your 12 perspectives on things, so thank you for your comments 13 today.
14 I will turn it back to you to either 15 continue with your part or pass it on to the next 16 person.
17 MS. ENGLAND: All right. Thank you. I 18 would like to hand the presentation back over to Lois 19 James.
20 MS. JAMES: Thank you, Jen. In 21 conclusion, for the SLRA safety review the Staff finds 22 that the requirements of 10 CFR 54.29(a) have been met 23 for the subsequent license renewal of the North Anna 24 Power Station's Units 1 and 2.
25 We will now be happy to answer any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
59 1 additional questions you may have. Thank you.
2 MEMBER SUNSERI: Thank you, Lois.
3 Members, any other questions for Staff, I guess or 4 Applicant at this point since we're wrapping it up?
5 (No audible response.)
6 MEMBER SUNSERI: All right. So no 7 questions for this. We'll go the public line I guess 8 for comments at this point in time. So, members of 9 the public, this is your opportunity to provide a 10 comment.
11 Unmute your line by star 6 and provide 12 your name and comment. So the line now is open.
13 Let's see if -- Well, any -- We'll give it one more or 14 a few more seconds.
15 (No audible response.)
16 MEMBER SUNSERI: All right. Then I guess, 17 Chair Rempe, this concludes our part of the 18 presentation here, so we can head back to you.
19 CHAIRMAN REMPE: Thank you. I appreciate 20 you for doing this. I know we had a late start 21 getting it done on time.
22 It's my understanding you have a letter 23 that you are ready to read in?
24 MEMBER SUNSERI: Yes. Based on the review 25 and the fact that (audio interference) information 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 since that time and by the presentation today we do 2 have a letter report that, draft letter report, that 3 was prepared to send to the Board.
4 CHAIRMAN REMPE: Great.
5 MEMBER SUNSERI: It's ready to go.
6 CHAIRMAN REMPE: Okay. So at this point 7 I think we can go off the record and ask the court 8 reporter to please come back at 1:00 p.m. eastern time 9 and we'll go back on the record.
10 (Whereupon, the above-entitled matter went 11 off the record at 9:50 a.m. and resumed at 1:00 p.m.)
12 CHAIRMAN REMPE: Okay, my computer tells me 13 it's 1 o'clock, so we're going to come back into 14 session.
15 And at this point, I would like to invite 16 Member Sunseri, to make a statement.
17 MEMBER SUNSERI: Thank you, Chair Rempe.
18 I had previously announced during the 19 subcommittee review of the North Ana subsequent 20 license renewal, that I was recusing myself from metal 21 environmental fatigue, and reactor vessel 22 embrittlement issues, due to professional affiliation 23 outside of the ACRS.
24 I intended to make that same statement 25 prior to the start of full committee. I just 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 overlooked it in my notes. But I have been abiding by 2 the recusal.
3 In addition to that, for the same 4 professional affiliation reason, I will be recusing 5 myself from the complete review of the NuScale topical 6 report on buildings design analysis methodology for 7 safety related structures.
8 Thank you.
9 CHAIRMAN REMPE: And, I'm going to do a 10 sound check because of some concerns about certain 11 members not being audible.
12 Could you hear that, court reporter, what 13 Member Sunseri said?
14 (No audible response.)
15 CHAIRMAN REMPE: Great.
16 So, at this time, I'd like to ask Member 17 Kirchner to lead us through the discussion on NuScale 18 topical report on the building design and analysis 19 methodology for safety related structures.
20 Walt?
21 VICE CHAIRMAN KIRCHNER: Thank you, Madam 22 Chairman. Good afternoon everyone.
23 This afternoon we will hear from 24 representatives of NuScale, and the NRC staff, on the 25 NuScale topical report, the building design 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
62 1 analysis for safety related structures.
2 We had the benefit of detailed 3 presentations by both parties, at our NuScale 4 subcommittee meeting on January 19.
5 Today, we will hear summary presentations 6 on the matter, and I have a draft letter report to 7 read into the record, for the Committee's 8 consideration and deliberation, after the 9 presentations.
10 With that, I am going to turn to Fehmida 11 Mesania from NuScale, to start us off this afternoon.
12 Fehmida, go ahead.
13 DR. MESANIA: Thank you. Good morning, 14 good afternoon. Can everyone hear me okay?
15 CHAIRMAN REMPE: Yes, we can.
16 DR. MESANIA: Thank you.
17 So, please, would you mind going to the 18 next slide, please, number two?
19 Thank you.
20 So, again, my name is Fehmida Mesania.
21 I'm a licensing engineer with NuScale. We thank you 22 for the opportunity to present NuScale topical report 23 on the building design and analysis methodology for 24 safety related structures.
25 For today's meeting, my colleagues Rim 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 Nayal and Giulio Flores, will support all 2 presentations.
3 Slide three, please.
4 Thanks.
5 So, the proposed agenda for today's 6 presentation includes a purpose, the brief 7 introduction, followed by a technical discussion on 8 the following subjects.
9 The building design of steel composite 10 walls in reinforced concrete members; and, design 11 methodology, as it's related to in-structure response 12 spectra and effective stiffness.
13 Slide four, please.
14 Thanks.
15 The purpose of this meeting is present the 16 ACRS scope committee, the technical content of the 17 topical report as outlined by the agenda.
18 And, also provide the public a general 19 understanding of the NuScale methodology.
20 There are several considerations that are 21 unique to the steel composite walls, and our focus is 22 to highlight the methodology for building design for 23 SC1 and SC2 safety related structures, related to RC 24 and SC walls that are applicable to the NuScale SMR 25 design.
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64 1 It is worth mentioning that the design 2 applicability and constructability (audio 3 interference) are not part of the scope of this 4 topical report, but are being considered and 5 investigated as part of our SDA submittal.
6 Slide five, please.
7 Thanks.
8 So, plate reduction. So, this topical 9 report presents a design methodology implementing new 10 industry standards for nuclear facilities.
11 The methodologies presented in our topical 12 report are in compliance with the requirement of 13 several standards and codes, including NC918, 360-16, 14 both recently endorsed by R.G. 1.2043. But we are 15 also using 349.13, and 360-16.
16 For the NuScale methodology, is consistent 17 with the structure acceptance criteria presented in 18 the Nuclear Scale Design specifically deal with 19 standards, the EDSRS, sections 384 and 372.
20 By meeting this requirement and criteria, 21 the methodologies provided an added assurance that the 22 SSEs will perform their safety function.
23 In addition, the topical report clarifies 24 methodologies for the interaction of SC walls, with 25 traditionally constructed, reinforced concrete members NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
65 1 such as facemasks, slabs and rules.
2 This methodology is intended, but is not 3 required, to be used in conjunction with another 4 NuScale topical report related to improvements in 5 frequency domain soil structure fluid interaction 6 analysis.
7 The NuScale plans to apply the methodology 8 described here, to our SCA submittal where design 9 details will be provided.
10 Are there any questions or comments so 11 far?
12 (No audible response.)
13 So, hearing none, I would like to thank 14 you for your attention, and I will hand it over to Rim 15 Nayal, to continue our technical presentation.
16 DR. NAYAL: Good morning, and good 17 afternoon.
18 This is Rim Nayal, I'm structural engineer 19 with NuScale.
20 In the next few slides, I'll present 21 building design methodology for steel plates composite 22 walls.
23 Next slide, please.
24 So, this slide presents, provides a 25 general description of SC walls. SC walls 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
66 1 fabricated from steel plates, referred to as face 2 plates, with a concrete core between the plates.
3 As shown in the sketch here, stud anchors 4 are welded to the faceplate at certain spacing in both 5 directions, to develop composite actions between the 6 steel and concrete.
7 The steel plates are also connected to 8 each other with ties at specific spacing, to resist 9 the out-of-plane sheer loading.
10 Next slide, please.
11 This slide presents a discussion and 12 advantages associated with using SC walls. And, it 13 highlights some of the areas requiring special 14 attention when utilizing them in construction.
15 SC walls are known to offer higher loading 16 capacity and ultimate strength, compared to other 17 types of construction.
18 And, SC walls also provide higher 19 resistance to blast and earthquake.
20 Major advantages of SC walls is 21 modularity, where SC walls are fabricated offsite, and 22 transported to the field for installation. Which 23 helps save time and reduce cost.
24 These modules are sized taking into 25 account multi aspect of the design, including 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 limitation on dimensions and weight for 2 transportation.
3 Another advantage of modular construction 4 is that the design can be optimized to have limited 5 number of conflagrations, in terms of layout that are 6 repeated throughout the building.
7 Some areas requiring special design or 8 treatment in SC walls construction are discussed here.
9 First one is SC wall connection to other structural 10 members.
11 Design and specifically, construction of 12 these connections, can become challenging given 13 potential steel congestion and exclusivity (phonetic) 14 issues.
15 The second item is corrosion of face 16 plates for below grade walls. These two areas will be 17 discussed later in this presentation.
18 Next slide, please.
19 So, as far as construction material, 20 carbon steel is mainly used everywhere in the design, 21 except for face plates in contact with borated water.
22 For these modules, stainless steel face plates are 23 utilized.
24 For modules used in the full area 25 connecting the stainless steel face plates to other 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 carbon steel components, involves performing the 2 similar metal welds.
3 Welding requirements associated with the 4 use of the similar welds are outside the scope of this 5 topical report, and will be addressed in the future.
6 However, as in general, here are some 7 actions that help with the concern with the similar 8 metal welds.
9 Like utilizing industry experience on 10 welding parameters and techniques that are appropriate 11 for the welded metals. In addition, controlling the 12 environment of these welds can help alleviate this 13 issue.
14 Controlling the environment may be like 15 controlling concrete chemistry to avoid corrosion of 16 these similar welds, and also the use of leak chases, 17 and the module splices to prevent borated water leaks 18 from reaching to these dissimilar welds, metal welds.
19 Next slide, please.
20 As far as design of ASC walls, the walls 21 are designed to the rules of NAEIC N690, 2018 edition, 22 and AIC 360-16.
23 Design is based on load and resistance 24 force design. Loading combinations are based on AIC's 25 N690, and the dimensionals and material properties NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 1 limits from N690 are applied, which applies to wall 2 thickness for interior and exterior walls, limits on 3 minimum and maximum faceplate thickness, stud and ties 4 minimum and maximum spacings, and et cetera.
5 The required strength is calculated by 6 dividing walls into panels, based on code panel size 7 limits for interior and for connection regions.
8 Five element responses are then averaged 9 over these panels, to obtain demand.
10 Available strength for each type of 11 response and load interaction, are calculated based on 12 code equations.
13 And, based on that, demand to capacity 14 ratio is for governing load cases, are calculated to 15 ensure acceptable design.
16 As a result of the global design, 17 faceplate thicknesses are determined along with anchor 18 and tie, tie dimensions, and spacings.
19 Next slide, please.
20 So, back to the subject of corrosion of 21 face plates for below grade walls.
22 The topical report discusses NuScale's 23 defense in depth approach for corrosion mitigation, of 24 the carbon steel face plates based on environments.
25 This can vary from applying coating as 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
70 1 minimum on the face plates below grades, to applying 2 controlled load strength material, or shotcrete, for 3 environments with high chloride, or hydrogen sulfide.
4 Or even using backfill with controlled pH 5 and chloride limits to reduce impact from corrosion, 6 corrosive soil.
7 Specific corrosion and aging management 8 plans for NuScale design, are outside the scope of 9 this topical report, and will be addressed in the 10 future.
11 Next slide, please.
12 This slide provides a brief discussion on 13 design of connections between SC walls, and other 14 structural components like basement, reinforced 15 concrete slabs, and other SC walls.
16 The connections are designed to the rules 17 of AIC N690. The code's philosophy is to ensure that 18 these connections are stronger than the weaker of the 19 connected members.
20 This ensures ductile behavior of the 21 structure.
22 For calculating the connection required 23 strength, full-strength connection design is used for 24 most connections. That is, the connection is designed 25 to 125 percent of the nominal strength of the weaker 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 of the connected members.
2 Use of over strength connection is limited 3 to cases where the connected members have low demand-4 to-capacity ratio.
5 Calculation of the available strength of 6 the connection is in compliance with the requirements 7 of N690, AIC 360-16, and ACI 349.13.
8 Connection detailing can be achieved using 9 different types of connectors and mechanisms, to 10 transfer forces and moments between the connected 11 members. Like using studs, anchor rods, continuity 12 plates, et cetera.
13 Detailing of the connections for the 14 NuScale design is also outside the scope of the 15 topical, this topical report, and it will be addressed 16 in the future.
17 In general, examples from the design guide 18 32 shows some connection configuration, that can give 19 some idea about the design.
20 This concludes my presentation about SC 21 walls, and we can take any question right now, or 22 otherwise, we can continue to the next section of this 23 presentation, which is about reinforced concrete.
24 MEMBER HALNON: Yes, I had one question, 25 this is Greg Halnon.
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72 1 When you say that these are corrosion 2 management and details are outside the scope, how will 3 the, I mean will this topical report provide 4 acceptance criteria, or some kind of criteria, so that 5 when we do see those other topical reports, we will 6 know the connection back to this topical report?
7 I guess my question is more, how are we 8 going to know if you address it in future ones, or 9 just letting it go now?
10 DR. NAYAL: So, I mean first of all, the 11 design of these connections is still under 12 development. And, course it's going to be presented 13 in the future when it's needed, before the final 14 design is you know, is completed.
15 VICE CHAIRMAN KIRCHNER: I was actually 16 more interested in corrosion management. I mean I'm 17 assuming you're assuming there's no corrosion? In 18 your account.
19 DR. NAYAL: Could you repeat the question?
20 VICE CHAIRMAN KIRCHNER: I'm more 21 interested in the corrosion management, the previous 22 slide, where you had said that that was outside the 23 scope and it will be in future application.
24 DR. NAYAL: Right.
25 So, right now, I mean there are so many 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 options that can be done for that, to mitigate the 2 corrosion, or to take some actions to alleviate that 3 concern.
4 Right now in the, like the detailed, this 5 is mainly design and design methodology topical 6 report. So, we think that dealing with the corrosion 7 and, you know, and aging management, that will be 8 addressed somewhere else.
9 VICE CHAIRMAN KIRCHNER: I guess it's that 10 somewhere else --
11 (Simultaneous speaking.)
12 DR. NAYAL: Yes --
13 VICE CHAIRMAN KIRCHNER: -- will be some 14 --
15 DR. NAYAL: -- it will be site specific.
16 And, it will be communicated at the time an 17 application is submitted.
18 VICE CHAIRMAN KIRCHNER: Okay, so I guess 19 we'll just have to remember that it's a hanging topic.
20 Thanks.
21 DR. NAYAL: Thank you.
22 Okay, so next slide, please.
23 Next section of this presentation is to 24 discuss the methodology for reinforced concrete 25 members in building design.
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74 1 Next slide, please.
2 Basement, all other slabs, and roof slabs 3 in the NuScale design, are constructed of reinforced 4 concrete. The design methodology for reinforced 5 concrete is based on the requirements of ACI 349.13, 6 and ACI 318.08, for each structural element, as 7 applicable.
8 Design is based also on load and 9 resistance for design. Loading combinations are based 10 on ACI 349 load combinations, and core dimensional 11 limits as applicable, are applied. Like thickness, 12 spacings between reinforcements, and many other 13 details.
14 The required strength is based on section 15 cuts at different locations of the member, and 16 available strength for each type of loading and 17 interaction are calculated based on code equations.
18 Demand-to-capacity ratio governing failure 19 modes are then calculated to reflect design margins.
20 The next few slides will go in a little 21 bit more detail over the design.
22 Next slide, please.
23 So, on this slide we're focusing on major 24 actions that we look at when designing slabs in 25 basement.
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75 1 This includes designing for in-plane 2 shear, and evaluating interactions between axial force 3 with out-of-plane moment, axial force with in-plane 4 moment, and axial force with out-of-plane shear.
5 The table shows what checks are typically 6 looked at for different numbers. For example, while 7 in-plane moment is not important for basement, it has 8 to be looked at for the slabs.
9 Next slide, please.
10 So, for each member, the demand is 11 calculated from section cuts taken at different 12 locations of the slab.
13 The topical report provides guidance on 14 where to take these section cuts for different types 15 of structural elements, and in addition to that, we 16 look at the contour plot of the stresses, to confirm 17 the critical locations of these section cuts.
18 And if needed, additional section cuts are 19 considered to obtain the demand.
20 So, for example, on the left side, the 21 sketch shows the vertical deformation of the slab.
22 This deformation generates out-of-plane moment, and 23 out-of-plane shear forces in the slab.
24 So, the section cuts recommended are at 25 the locations where these actions are expected to 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
76 1 critical.
2 Similarly, the sketch on the right showed 3 the diaphragm action deformation where the slab 4 transferred loads, horizontal loads, to the adjacent 5 supporting walls.
6 And, based on that, section cuts critical 7 locations are recommended where the design to be 8 checked.
9 And, as I said, these sketch confirm later 10 when we look at the contour plots of the stresses.
11 Next slide, please.
12 So, the capacities of the members are for 13 different design actions, are then calculated based on 14 code equations.
15 Where it comes to the design, demand of 16 the members is calculated for different loading 17 combinations, and for all time points of the seismic 18 events.
19 For example, the sketch to the top, here, 20 shows an example of demand for interaction equations.
21 Each one of these blue dots represents member of 22 demand at certain time points of the seismic event.
23 To perform the design, we envelope that 24 demand of the member and for all of these points, and 25 then we compare it with the capacity curve that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
77 1 shown in the bottom of the slides, to decide whether 2 the member has enough capacity or not.
3 And, then based on that, we calculated the 4 maximum demand-to-capacity ratio and to assess the 5 safety margins, and whether the design is sufficient, 6 or whether it, change is needed.
7 And, we repeat that for different types of 8 checks, and for different members.
9 Next slide, please.
10 Finally, the reinforcement of the member 11 is determined after calculating the needed demand for 12 each action.
13 The demand is added based on what type of 14 reinforcement is needed to resist that demand. For 15 shear enforcement, the maximum demand of the two 16 directions is used for both, for both of these 17 directions.
18 This summarizes the slides on reinforced 19 concrete design, and if there are any comments or 20 questions, I'll be happy to take them now.
21 (No audible response.)
22 DR. NAYAL: And if not, I'll hand over to 23 Guilio, to go over the next part of the presentation.
24 (No audible response.)
25 VICE CHAIRMAN KIRCHNER: Go ahead, Guilio.
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78 1 (No audible response.)
2 CHAIRMAN REMPE: So, we're not hearing 3 anyone speaking. So, perhaps your microphone is on 4 mute, Guilio?
5 MR. SNODDERLY: We did a sound check --
6 (Simultaneous speaking.)
7 CHAIRMAN REMPE: Is anyone one from --
8 MR. SNODDERLY: Yes, we did a sound check 9 with Guilio and it worked. So, maybe he lost his 10 connection.
11 Liz English or Mark Chitty, could someone 12 give Guilio a call, or see what, what the problem is?
13 MR. CHITTY: We can.
14 PARTICIPANT: Yes, we're communicating with 15 him now. Thanks, if you just give us a minute?
16 MR. SNODDERLY: Very good.
17 (Pause.)
18 MR. FLORES: Hello?
19 PARTICIPANT: We hear you.
20 (Audio interference.)
21 CHAIRMAN REMPE: We can hear you but it's 22 not very clear.
23 MR. FLORES: Okay, so let me call the 24 number.
25 (Pause.)
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79 1 CHAIRMAN REMPE: So, I assume the folks 2 from NuScale know that we aren't hearing anything in 3 the room. If someone could confirm that and let us 4 know.
5 PARTICIPANT: Yes, thank you, we're aware.
6 We're working on it. Appreciate it.
7 CHAIRMAN REMPE: Thanks, we'll be patient.
8 PARTICIPANT: Thank you.
9 MR. NGUYEN: So, the fastest way in 10 troubleshooting is to log off, and then log back in.
11 MR. FLORES: Hello, can you hear me now?
12 (Audio interference.)
13 CHAIRMAN REMPE: Yes, but we have an echo.
14 MR. SNODDERLY: Can you mute your computer?
15 If you're using your phone and your computer, you need 16 to mute one or the other. And, I suggest your 17 computer.
18 Guilio, are you there?
19 (No audible response.)
20 MR. FLORES: Okay, can you hear me?
21 MR. SNODDERLY: Yes, you're good now.
22 MR. FLORES: Okay, yes. Now let me open my 23 computer. I had to close it because it was sounding 24 like echo.
25 (Pause.)
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80 1 MR. FLORES: Okay, yes, sorry for the 2 inconvenience.
3 So, I am Guilio Leon Flores, I am a 4 structural engineer by NuScale Power, and I'm going to 5 present a summary of the topical report sections 4 and 6 5.
7 Section 4 describes the methodology to 8 obtain in the structure response spectra for equipment 9 design, and member forces for design of seismic 10 category 1 and 2 structures.
11 If we go to the next slide, please.
12 I'm going to start by summarizing some 13 important seismic design concepts used in our design 14 methodology.
15 Buildings are designed for a specific 16 target performance, or a specific level of deformation 17 and damage, designed by a limit state category.
18 For nuclear plants, the criteria to 19 achieve a specific target performance come from ASC 20 43.
21 Four limit states are defined A, B, C, and 22 D, which range from significant to negligible damage.
23 NuScale buildings are designed for limit 24 state D. In other words, structures are designed to 25 remain essentially elastic, with negligible damage.
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81 1 Next slide, please.
2 (Audio interference.)
3 MR. FLORES: Sorry.
4 CHAIRMAN REMPE: There's still an echo.
5 MR. FLORES: Oh, it's starting, okay.
6 Okay, how about now?
7 MEMBER SUNSERI: That's better, Guilio.
8 MR. FLORES: Okay, sorry.
9 Okay, yes, this slide.
10 In agreement with the reinforced concrete 11 design philosophy, concrete is designed to take 12 compression loads, and it is considered to retract 13 under tension loads. Reinforcing the steel on the 14 other hand, is designed to take all tension loads.
15 For this reason, it is expected that some 16 structure members will experience cracking under the 17 safe shut down, earthquake, or SSE. But this cracking 18 should be minimal since structure design, according to 19 (audio interference), is expected to result in 20 essentially elastic behavior.
21 And, this is accomplished following design 22 code requirements, such as the use of lower material 23 and member strength, use of load factors to increase 24 the magnitude of design loads.
25 Due to all of these reasons, concrete 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 cracking under the SSE, if any, should not impair the 2 member safety function.
3 Next slide, please.
4 Under the SSE, the stiffness of cracked 5 members is reduced. On the other hand, the structure 6 damping increases, because the energy dissipated by 7 the structure increases.
8 The figure shows an example of a 9 cantilever wall subject to a seismic force at the top.
10 The wall stiffness is that slope of the force 11 displacement curve.
12 So, when the force is small, the member is 13 uncracked, and if the stiffness is uncracked or the 14 gross stiffness.
15 Above a certain threshold, the member 16 cracked, and the stiffness decreases with increasing 17 force.
18 The safety of the stiffness, which is a 19 red line in the figure, is an intermediate stiffness 20 that's up by the code, to represent the cracked state 21 for seismic analysis using linear elastic models.
22 (Audio interference) damping is also taken 23 from the codes, and the standard.
24 If we go to the next slide.
25 So, as I explained, damping ratios 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
83 1 effective stiffness used in linear elastic analysis, 2 are co-related to the level of cracking expected 3 during the SSE.
4 ASCE 4 introduces a concept of response 5 level to help make this correlation. The response 6 level is determined on a member-by-member basis, based 7 on the member stresses.
8 So, if the member stress is smaller than 9 the stress associated with cracking, response level 1 10 is assigned. Otherwise, response level 2 is assigned 11 to the member, and the member is considered cracked.
12 Next slide, please.
13 This and the following slides, show our 14 design process. We start with two models, one for 15 seismic analysis, and another one for static analysis 16 considering known seismic loads.
17 The first step is the determination of the 18 member response level. To this end, seismic models 19 are set to uncracked damping and uncracked stiffness, 20 corresponding to a response level 1 for all members.
21 Stresses are then evaluated in all the 22 members, considering the most critical seismic load 23 combination. Stiffness and damping of the members 24 that are cracked, are abated to the ones corresponding 25 to a response level 2.
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84 1 Next slide, please.
2 Seismic models with abated stiffness and 3 damping are used for, in-structure response spectra 4 calculation.
5 ISRS are calculated for 535 seismic design 6 respond spectrum ground motion, and then they are 7 averaged.
8 ISRS are also calculated for one CSDRS 9 high frequency ground motion. Blast manual 15 10 percent, peak broadening is then applied.
11 ISRS for notes on specific flow regions 12 are then enveloped. The process is repeated for all 13 selected 4 to 5. And, the final ISRS are the envelope 14 considering all soil profiles.
15 MR. SNODDERLY: Excuse me, NuScale, I need 16 you to hold for a second.
17 I just was notified by our executive 18 director in the room, that we lost communications with 19 the room.
20 So, now they can't hear you, so they're 21 trying to reconnect. So, now we waited for you, now 22 you'll have to wait for us.
23 But --
24 (Simultaneous speaking.)
25 MR. FLORES: Sure.
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85 1 MR. SNODDERLY: -- so, please be patient.
2 MR. FLORES: That's fine.
3 MR. NGUYEN: Thanks, Mike, I'll physically 4 check.
5 MR. SNODDERLY: Okay, thanks.
6 (Pause.)
7 MR. SNODDERLY: Hello, Member Halnon?
8 (No audible response.)
9 MR. SNODDERLY: Member Halnon?
10 (No audible response.)
11 MR. SNODDERLY: Court reporter, are you 12 there?
13 (No audible response.)
14 MR. SNODDERLY: All right, some people, 15 okay, great.
16 So, we've lost the room so we're, I'm 17 letting some people back in.
18 Can I ask who just joined us?
19 (No audible response.)
20 MR. SNODDERLY: Okay, the ACRS has lost 21 connection. Hang on, they're getting it back.
22 All right. So, Greg just notified me that 23 they've, okay.
24 MEMBER HALNON: Yes, we're trying to get it 25 back.
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86 1 MR. SNODDERLY: Okay.
2 MEMBER HALNON: Quynh's working on it, so 3 just give us a couple seconds.
4 MR. SNODDERLY: Okay. Now --
5 (Simultaneous speaking.)
6 MEMBER HALNON: You know that patience we 7 had a few minutes ago?
8 MR. SNODDERLY: Yes.
9 MEMBER HALNON: We need it the other way 10 now.
11 MR. SNODDERLY: I already used that line, 12 Greg.
13 MEMBER HALNON: Yes, right.
14 MR. SNODDERLY: We're on standby.
15 (Pause.)
16 MEMBER HALNON: Should see us any second, 17 Mike.
18 MR. SNODDERLY: So, I just saw Dave Petty 19 came in. I'm seeing the individual members coming in, 20 but hopefully people in the room can hear us.
21 CHAIRMAN REMPE: Okay, somebody who's got 22 their mic on, turn it off.
23 MR. SNODDERLY: That's, well, I have mine 24 on. Do you want me to turn my mic?
25 CHAIRMAN REMPE: No, I think you're fine.
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87 1 We had members in the room who were on their mics.
2 MR. SNODDERLY: Okay.
3 CHAIRMAN REMPE: Okay, I want to apologize 4 for internet interruptions, and I hope that you can, 5 didn't go too far before we lost the connection.
6 MR. SNODDERLY: Yes, so right now I believe 7 we're on slide 25, and I'll ask NuScale to start 8 there.
9 And, then why don't you let us know if 10 that's something you haven't heard before, or that 11 said something.
12 VICE CHAIRMAN KIRCHNER: We were on 21.
13 MR. SNODDERLY: 21?
14 PARTICIPANT: Yes, Mike, we were on 21.
15 MR. SNODDERLY: Okay, please, NuScale, can 16 you please go to slide 21?
17 MR. FLORES: Okay, sure.
18 MR. SNODDERLY: Okay.
19 MR. FLORES: Yes, this is part of the 20 enforced concrete design philosophy. So, I was saying 21 the concrete is designed to take compression loads, 22 and it is considered to be cracked under tension 23 loads. Reinforcing the steel on the other hand, is 24 designed to take all tension loads.
25 For this reasons, it is expected that 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
88 1 structural members will experience cracking under the 2 phase shutdown earthquake.
3 But this cracking should be minimal since 4 the structural design is according to limit the (audio 5 interference). And, it is expected to result in 6 essentially elastic behavior.
7 And, this is accomplished following design 8 code requirements, such as the use of lower material 9 and member strengths, use of (audio interference) 10 factors to increase the magnitude of design loads.
11 Due to all these reasons, concrete 12 cracking under the SSE if any, should not impair the 13 member's safety function.
14 Next slide, please.
15 Okay, so the stiffness of cracked members 16 is reduced. On the other hand, structural damping 17 increases because the energy dissipated by the 18 structure increases.
19 The figure shows an example of a 20 cantilever wall that is subject to a force at the top, 21 and to the right, there is a force displacement incur 22 where the effective stiffness is shown as the red line 23 in the figure, and is an intermediate stiffness set up 24 by the codes to represent the crack states for seismic 25 analysis using linear elastic models.
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89 1 Structural damping is also set up by the 2 codes, and the standard.
3 Next slide, please.
4 As explained before, damping ranges and 5 effective stiffness in linear elastic analysis, are 6 correlated to the level of cracking expected during 7 the SSE.
8 ASC 4 introduces the concept of response 9 levels to help make this correlation. The response 10 level is determined on a member-by-member basis, based 11 on the member's stress.
12 So, if the member stress is smaller than 13 the stress associated with cracking, response level 1 14 is assigned. Otherwise, response level 2 is assigned, 15 and the member is considered cracked.
16 Next slide, please.
17 This and the following slides, show our 18 design process. We start with two models, one for 19 seismic analysis, and another one for static analysis 20 considering known seismic loads.
21 The first step is the determination of the 22 member response level. To this end, seismic models 23 are set to uncracked damping, and uncracked stiffness 24 corresponding to response level 1 for all members.
25 Stresses are then elevated in all 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
90 1 members, considering the most critical seismic load 2 combinations.
3 Stiffness and damping of the members that 4 are cracked, are updated to the ones corresponding to 5 response level 2.
6 The next slide shows the process for the 7 ISRS calculation, that seismic models with updated 8 stiffness and damping, are used for the ISRS in the 9 structural respondent specter calculation.
10 ISRS are calculated for 535 seismic design 11 respondent specter ground motions, and then they are 12 averaged.
13 ISRS are also calculate for one CSDRS high 14 frequency ground motion. Plus/minus 15 percent peak 15 broadening is then applied.
16 ISRS from notes on the specific flow 17 ratios are then enveloped and the process is repeated 18 for all selected soil profiles.
19 Final ISRS are the envelopes considering 20 all soil profiles.
21 The next slide shows the process for the 22 member design in seismic models with updated 23 stiffness.
24 And, response level 2 damping are used to 25 obtain seismic forces for five CSDRS ground motions, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 1 and one CSDRS high frequency ground motion.
2 No seismic forces accompanying the seismic 3 loads are obtained from the static model, with the 4 stiffness matching the stiffness of the seismic model.
5 Demand-to-capacity ratios for the five 6 CSDRS ground motions are averaged, and then enveloped 7 considering all those combinations.
8 Demand-to-capacity ratios have to be lower 9 than one, otherwise, the member section is increased 10 or additional reinforcement is considered.
11 And, the process is repeated for all 12 selected soil profiles.
13 Final demonstration of ratios are the 14 envelopes considering all soil profiles.
15 Are there any questions?
16 VICE CHAIRMAN KIRCHNER: Guilio, this is 17 Walt Kirchner. I have one question.
18 On the ASCE guidance, it's like how much 19 cracking is acceptable? Where I'm going with this is 20 there's cracking, and then there's just complete 21 failure of concrete.
22 I'm presuming that ASCE set of 23 adjustments, the R1 and the R2, obviously the concrete 24 hasn't turned to rubble inside the steel composite 25 wall. So, how much cracking is acceptable in 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
92 1 codes?
2 MR. FLORES: Yes, so can we go to slide 3 number 22, please?
4 Yes, so the figure, the force displacement 5 code, may help explain this.
6 So, we are talking about the, really the 7 elastic range, which is the first portion of the 8 curve.
9 Now, the profile that you see there is a 10 global capacity curve that defines the global capacity 11 of the member.
12 So, the cracking of course, of the force 13 in the first portion of the curve, which means the 14 crack that may appear on the member, are very tiny.
15 Maybe you may not see it.
16 And, in order to see the crack but maybe 17 you're worried, you need to go to the curve towards 18 the end. Then you start seeing the big cracks, and 19 then you reach the capacity. But we are far from it.
20 We're just in the beginning of the curve.
21 And, the concrete, I mean it cracks 22 because it has a very low capacity for tension loads.
23 But those cracks are very minor at this stage. It's 24 not the end of the capacity, it's just the beginning.
25 I don't know if that's clear?
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93 1 VICE CHAIRMAN KIRCHNER: Yes, okay. The 2 presumption is that it's relatively small cracking, 3 it's not gross failure of the concrete?
4 MR. FLORES: Yes, it's not failure at all, 5 no. Failure as I mentioned, you need to go to the end 6 of the curve, and we are not there because the end of 7 the curve is to limit to state A, near collapse.
8 We are at the beginning, which is limit to 9 state D, essentially elastic.
10 VICE CHAIRMAN KIRCHNER: Okay, thank you.
11 MR. FLORES: It shows with minor cracking 12 there.
13 MEMBER BALLINGER: Remember, this is 14 reinforced also.
15 VICE CHAIRMAN KIRCHNER: No, of course.
16 MEMBER BALLINGER: So.
17 MEMBER HALNON: I've got one quick 18 question.
19 MR. FLORES: Yes.
20 MR. HALNON: This is Greg Halnon.
21 In the next, when you did your iterations, 22 you said selected soil types. And, how broad is that 23 relative to the potential soils that might be, a site 24 might be built on?
25 MR. FLORES: Yes, it's very broad.
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94 1 So, we have three soil profiles. One is 2 very soft soil, and the other one is rigid soil, and 3 the third soil is more rigid. It's like crack. It's 4 like rock, sorry, rock.
5 So, we try to cover the different 6 scenarios now from soft to very rigid soil profiles.
7 MEMBER HALNON: Okay, so essentially, 8 you've covered pretty much most of the soil types that 9 would be considered for an adequate site for one of 10 these plants?
11 MR. FLORES: Yes.
12 MEMBER HALNON: I'm not, I don't want to 13 put words in your mouth, but it sounds like you're 14 confident that you're pretty well bounded.
15 MR. FLORES: Yes.
16 So, for the selective soil profiles we 17 evaluated, the soil, different soil profiles across 18 the U.S. And, that was, were used for in previous 19 plant applications, as well.
20 And, because based on that, we selected 21 those three soil profiles, try to cover the entire 22 spectrum of soil conditions.
23 MEMBER HALNON: Okay, thanks.
24 MR. FLORES: You're welcome 25 If there are no more questions, we can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
95 1 move to the last section of the topical report.
2 (No audible response.)
3 MR. FLORES: This last section describes 4 the modeling approach, to represent effective 5 stiffness in our building models.
6 Next slide, please.
7 For the NuScale design, finite element 8 models are developed using ANSI phototropic material 9 model. Steel plate composite walls and reinforced 10 concrete members, are modeled using ANSI's traditional 11 shell elements, and also 3-D solid shell element.
12 For shell elements, effective stiffness is 13 implemented by adjusting material properties and 14 model, in the model thickness to match the code 15 specified values.
16 And, this is the same procedure outlined 17 in AIST design guide 32.
18 For solid shells, since the model 19 thickness cannot be changed without changing the 20 geometry, two alternative methods are implemented.
21 Both methods are consistent with design 22 guide 32 approach. And, I'll explain in the next 23 slide.
24 In both methods, the solid shell element 25 is subdivided into three layers. In method one, 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
96 1 middle layer has thickness and properties to match 2 code specified stiffness. And, the outside layers are 3 dormant layers having negligible stiffness.
4 This method is more suitable for 5 reinforced concrete members.
6 In method two, each layer thickness is 7 equal to the actual steel plate, or concrete 8 thickness. Material properties for each layer are 9 chosen to match again, the code specified thickness.
10 This method is more suitable for SC walls.
11 Both methods, method one and method two, 12 can be used in the same model. As I explained, they 13 generate a Q and effective stiffness values matching 14 the code.
15 This summarize our presentation, is the 16 topical report. I don't know if there are more 17 questions?
18 VICE CHAIRMAN KIRCHNER: Members, any 19 further questions of NuScale?
20 (No audible response.)
21 VICE CHAIRMAN KIRCHNER: Okay, thank you 22 very much. I think then we can turn to the NRC staff, 23 and.
24 MR. FLORES: Oh, there was one slide but 25 it's just a summary. We can go just one minute, yes.
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97 1 VICE CHAIRMAN KIRCHNER: Okay.
2 MR. FLORES: So, in summary, the topical 3 report includes the building design and analysis 4 methodology implementing new industry standards, and 5 novel structural systems such as the use of SC walls.
6 It is applicable to new generation of a 7 small model reactor design, and a portion of this 8 report will be used as part of the standard design 9 approval application.
10 Thank you.
11 VICE CHAIRMAN KIRCHNER: Thank you.
12 I think we can turn to the NRC staff 13 presentation at this point.
14 MR. SNODDERLY: Yes, Member Kirchner, it 15 will be Demetrius Murray from the staff, to kick 16 things off.
17 Thank you.
18 MR. MURRAY: Thank you --
19 (Simultaneous speaking.)
20 VICE CHAIRMAN KIRCHNER: Go ahead, 21 Demetrius.
22 MR. SNODDERLY: NuScale, if I could, yes, 23 thank you, relinquish the slides. Thank you.
24 MR. MURRAY: Can you see my slides?
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98 1 you.
2 MR. MURRAY: Thank you.
3 Okay, good afternoon. I would like to 4 thank the ACRS, NuScale, and the general public, for 5 entertaining the NRC for the presentation of our 6 safety evaluation of NuScale's building design and 7 analysis methodologies for safety related structures 8 topical report.
9 In December of 2020, NuScale submitted 10 Rev. 0 of their building design topical report, to the 11 NRC. After acceptance of the topical report, the NRC 12 issued multiple requests for additional information, 13 RAIs, to NuScale in May and August 2021.
14 NuScale provided answers to the NRC's RAIs 15 in June and September of the same year.
16 NuScale issued Rev. 1 of their topical 17 report to the NRC on October 6 of 2021.
18 We are here today to further discuss the 19 staff's advanced safety evaluation of the topical 20 report.
21 The staff reviewers are Ata Istar, Dr.
22 Amit Ghosh, and now retired Robert Pettis. I am the 23 topical report project manager, Demetrius Murray, 24 supported by senior project manager Getachew Tesfaye.
25 Before we transition to Ata to discuss 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
99 1 safety evaluation, I would like to open, or give an 2 opportunity for NRC management Michael Dudek, and 3 Joseph Colaccino.
4 MR. DUDEK: So, just once again, thanks to 5 the Committee for hearing us on this very unique 6 topic.
7 I think we had a very good and 8 collaborative subcommittee meeting, in which we got a 9 lot of good feedback from the Committee.
10 We've taken a lot of those comments and 11 concerns into account today, and we've added that as 12 some of our specific talking points in going forward 13 today.
14 And, I would welcome the Committee if they 15 have any additional questions with what we're 16 presenting. We are open books and we have the 17 appropriate staff members on hand today, to address 18 those concerns.
19 That's all for me. Joe, would you like to 20 say something before we proceed?
21 MR. COLACCINO: Thanks, Mike.
22 All of what Mike said, plus in addition I 23 just want to again, recognize the uniqueness of this 24 review, and how we coordinated with the Office of 25 Research's development and approval of Reg. Guide NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 1 1.243.
2 I believe we have staff members from 3 Research here today, if there are any questions about 4 that Reg. Guide.
5 Thank you.
6 MR. ISTAR: Good afternoon, or good 7 morning. Can you guys hear me?
8 (No audible response.)
9 MR. ISTAR: Can you hear me?
10 VICE CHAIRMAN KIRCHNER: Yes, we hear you 11 very well. Go ahead.
12 MR. ISTAR: Thank you. This is Ata Istar, 13 structural engineer, NRC.
14 Before I start my presentation, I would 15 like to recognize Bob Pettis, who retired last month 16 and, or I should say two months from now, in December, 17 end of December.
18 And, he was the lead for the review of 19 this topical report, and he provided immense 20 information, and for that, that he needs to be 21 recognized for.
22 Based on the review of the TR, the staff 23 concluded that the methodology presented in the 24 NuScale TR, are acceptable to perform the building 25 design and analysis for seismic category 1 and 2 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
101 1 nuclear safety related reinforced concrete, and steel 2 plate composite structures, other than containment.
3 The methodology follows the implementation 4 of the requirements of ACI 349.13, AIC and 690.18, 5 appendix 9, which is endorsed by Reg. Guide 1.243.
6 The methodologies are also consistent with 7 the applicable regulatory requirements of acceptance 8 criteria, sections 372 and 384, in NRC NuScale design 9 specific review standard.
10 Next slide, please.
11 I would like to provide information on the 12 following items that are questioned during the ACRS 13 subcommittee meeting.
14 The first one is the effects of corrosion 15 on the ASC wall below grade. The second one is 16 welding attachments to the ASC walls after concrete is 17 placed. The third one is industry experience on the 18 SC wall construction.
19 Next slide, please.
20 Based on the review of the TR, the staff 21 requested the information related to corrosion effect 22 on SC walls, as required in section B3.13, of AIC 360-23 -16, which states the structure components shall be 24 designed to tolerate corrosion, or shall be protected 25 against corrosion.
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102 1 Since the small modular rafter design may 2 also consider the possibility of plant license 3 extensions of up to 80 years, and the in-service 4 inspection and repairs of below grade exterior SC 5 walls base plates would be impractical for the 6 duration of extended licensing period.
7 NuScale response included the following 8 graded approach, and is described in revision 1 of the 9 topical report.
10 First, the application of tar epoxy 11 coating on the exterior below grade face plates. The 12 second one, using control low strength material, or 13 employing shotcrete cementitious material on the 14 exterior low grade face plates.
15 Further, using backfill material with 16 control pH and chloride limits.
17 Based on the reviews, staff conclude that 18 the NuScale response is consist with section b3.13 of 19 AISC 360-16.
20 Next slide, please.
21 VICE CHAIRMAN KIRCHNER: Ata, before you go 22 on, this is Walt Kirchner.
23 MR. ISTAR: Yes, sir.
24 VICE CHAIRMAN KIRCHNER: This is an almost 25 the application for the reactor building 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
103 1 particular, that we saw in the NuScale DCA.
2 It's almost like a ship at sea, only the 3 water now is inside the ship, not outside.
4 And, is this a place where cathodic 5 protection could be used to mitigate issues with 6 corrosion below grade?
7 MR. ISTAR: It could be, but at this point, 8 the applicant is just picked up, picked up the 9 cathodic protection mitigation, you know, mitigation 10 application.
11 But pick up providing epoxy coating, 12 external on the below grade face plates and the 13 shotcrete using a cementitious material. And, also 14 using a backfill material with control pH, and with 15 chloride limits.
16 And, again, anything can be used. Once it 17 goes into a site specific, issues are determined. I 18 think numerous protection measures can be used, you 19 know.
20 It's when --
21 (Simultaneous speaking.)
22 MEMBER BALLINGER: As a practical --
23 MR. ISTAR: Yes?
24 MEMBER BALLINGER: As a practical matter, 25 cathodic protection really can't be used.
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104 1 MR. ISTAR: Well.
2 MEMBER BALLINGER: As a practical matter, 3 cathodic protection is not going to be. Because 4 you've got this pool that's got a stainless steel wall 5 on the inside, carbon steel plate on the outside.
6 The stainless steel will be a giant 7 cathode. It's air saturated water. And, the outside 8 will be steel, and if it's exposed to any kind of 9 water or anything like that, that's just, you'd have 10 to use the power plant itself to provide enough 11 current to do cathodic protection.
12 MR. ISTAR: Okay. Sir, let me explain.
13 I think the pool wall stainless steel part 14 of it, it should be stainless steel on both sides.
15 And, that's the outside surface, so that faceplate I 16 don't think, is exposed to the ground level.
17 So, there is another wall --
18 (Simultaneous speaking.)
19 MEMBER BALLINGER: No, what I meant was the 20 --
21 MR. ISTAR: there is another wall --
22 MEMBER BALLINGER: -- the tie rods that go.
23 MR. ISTAR: There is another wall outside, 24 which is a carbon steel.
25 MEMBER BALLINGER: Right, but they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
105 1 connected with tie rods.
2 MR. ISTAR: Correct, they are connected 3 with tie rods, correct.
4 But the pool area, and that is the outside 5 of the SC wall for that location, is, doesn't, outside 6 faceplate is not exposed to the soil.
7 The applicant can confirm that, but based 8 on my understanding, the outside wall of the reactor 9 building is carbon steel on both sides. And, the 10 outside face of, faceplate, is exposed to the soil.
11 And, it's very difficult to inspect for 12 the duration of the license, and also repair.
13 But the cathodic protections could be used 14 on the outside. But not on the stainless steel part 15 of it. I agree with you on that.
16 Any other questions?
17 MEMBER BALLINGER: No, that's, okay. Just 18 since we've wagged this issue, when, where would we 19 normally see this taken up? When we get to an actual 20 COL application where you have site specific 21 information, and then these mitigating measures would 22 be implemented?
23 And, that would be somewhere in the FSAR 24 --
25 (Simultaneous speaking.)
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106 1 MR. ISTAR: Correct.
2 MEMBER BALLINGER: -- or the submittal.
3 Somewhere in the licensing application submittal?
4 MR. ISTAR: Yes.
5 MEMBER BALLINGER: Okay.
6 MR. ISTAR: Correct.
7 MEMBER BALLINGER: Thank you.
8 MR. ISTAR: Correct.
9 Next slide, please.
10 Based on the review of the TR, the staff 11 also requested information related to the attachment 12 to SC walls, and the effects of elevated temperatures 13 in the concrete due to welding.
14 NuScale response was the attachment to SC 15 walls are to be installed in the shop during the 16 fabrication, or at the field prior to the concrete 17 placement.
18 However, when the attachments are needed 19 after the concrete is placed, the effects of elevated 20 temperatures from weldings are minimized by the 21 following generic industry guidelines.
22 The minimum faceplate thickness is limited 23 to half-inch. The minimum concrete curing prior, 24 period is 21 days. This requirement assures that the 25 concrete has enough strength.
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107 1 And, heat input to the concrete is 2 controlled by setting a maximum base plate temperature 3 to 25 degree Fahrenheit, above the minimum pre-4 temperature.
5 Or the calculations performed provide 6 specific allowance.
7 Based on the review, the staff concluded 8 that the NuScale's response is consistent with Reg.
9 Guide 1.243.
10 Next slide, please.
11 During the ACR subcommittee meeting, there 12 was a question related to industry experience on SC 13 wall construction.
14 Similar SC wall application was reviewed 15 and approved for AP 1000 shield building. Integrated 16 design approach was implemented on the AP 1000 shield 17 building design by performing the design detailed 18 structural analysis of the SC walls and connections, 19 performing testing of SC walls and connections, and 20 performing inspections.
21 Finally, AICN 690-18 was recently endorsed 22 by Reg. Guide 1.243, and this specification is 23 acceptable for the design of SC walls and connections, 24 for seismic category 1 and 2 nuclear safety related 25 structures.
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108 1 This will conclude my presentation. I can 2 take any question you may have.
3 Thank you.
4 VICE CHAIRMAN KIRCHNER: Members, any 5 questions at this juncture?
6 (No audible response.)
7 VICE CHAIRMAN KIRCHNER: Okay.
8 So, Ata, does that complete the NRC 9 presentations?
10 MR. ISTAR: Yes, sir.
11 VICE CHAIRMAN KIRCHNER: Thank you. Thank 12 you very much for responding to our questions during 13 the subcommittee.
14 MR. ISTAR: I thank you, too.
15 VICE CHAIRMAN KIRCHNER: So, Madam 16 Chairman, I think we're at a juncture where we should 17 open the public line for comment.
18 (No audible response.)
19 VICE CHAIRMAN KIRCHNER: If there are any 20 members of the public who wish to make a comment, 21 please identify yourself and make your comment.
22 Press *6 to unmute your phone.
23 (No audible response.)
24 VICE CHAIRMAN KIRCHNER: Hearing none, any 25 further comments from NuScale, or the staff?
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109 1 (No audible response.)
2 VICE CHAIRMAN KIRCHNER: Hearing none, 3 okay, thank you very much all, and Madam Chairman, I 4 think we're ready to move on to read the letter into 5 the record.
6 CHAIRMAN REMPE: Okay. Do we want to take 7 a, first of all Tammy, are you out there?
8 MS. SKOV: I'm right here.
9 CHAIRMAN REMPE: Great. As always, we can 10 depend on you.
11 Do we want to take two minutes to take a 12 break and we'll come back -- oh, first of all, we do 13 need to ask for public comments.
14 VICE CHAIRMAN KIRCHNER: I just did.
15 CHAIRMAN REMPE: Okay, okay, sorry.
16 Okay, then let's take a 10 minute break, 17 and we will reconvene at how about we'll give 2020, 18 give you 13 minutes, and we'll read the letter in.
19 VICE CHAIRMAN KIRCHNER: Thank you.
20 (Whereupon, the above-entitled matter went 21 off the record at 2:07 p.m. and resumed at 3:45 p.m.)
22 CHAIRMAN REMPE: Okay, it's 3:45 on the 23 east coast and we are going to reconvene. And at this 24 time I'd like to ask Member Halnon to lead us through 25 our discussion on the proposed rule language for 10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
110 1 CFR 53 Subpart F relating to staffing, personnel 2 qualifications, training and human factors. Member 3 Halnon.
4 MEMBER HALNON: Thank you, Chairman Rempe.
5 The purpose of this session at the full committee is 6 to review and discuss the proposed rule language as 7 she mentioned, Subpart F of Part 53. We've had a 8 couple of meaningful subcommittee discussions on the 9 topic and it's been very beneficial and has enabled us 10 to focus this discussion to a few topics that we can 11 dive deeper into. We will also get into the review of 12 the rule language as well.
13 But I wanted to make sure everybody knew 14 it didn't preclude asking questions on different 15 topics even though we're going to limit the discussion 16 here to -- for different focus topics.
17 So, staff has been ready. They've got a 18 good presentation coming up. I'm looking forward to 19 it so I'm going to turn it over to Lauren Nist, and 20 you can introduce your team and get started.
21 MS. NIST: Thank you, sir. Can you hear 22 me okay?
23 MEMBER HALNON: Yes, we can.
24 MS. NIST: Okay, so good afternoon. I'm 25 Lauren Nist, the chief of the operator licensing 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
111 1 human factors branch and my staff's presenting today 2 on the preliminary rule language for Part 53 Subpart 3 F, staffing, personnel qualifications and training.
4 Let's see.
5 So the presenters today are Jesse Seymour, 6 Maurin Scheetz, and Theresa Buchanan, and they are all 7 in operator licensing and human factors branch in NRR>
8 all the slides are publicly available and in ADAMS at 9 the ML number shown here. Next slide, please.
10 Although you -- the subcommittee and I 11 think previously the full committee perhaps, you 12 primarily heard from Jesse Seymour on all things 13 related to Part 53 Subpart F before today. And I 14 think he's done a wonderful job presenting the 15 committee with information on our efforts in this area 16 to date.
17 Jesse is one of the members and leaders of 18 a team of staff who have been working on developing 19 this subpart. And that team consists of the staff 20 members listed here which you can see includes staff 21 from both NRR and the Office of Research.
22 Collectively these staff members have expertise in 23 human factors engineering, nuclear power plant 24 personnel qualification and training processes and 25 methods, and experience in commercial nuclear power 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
112 1 plant operations and training. Next slide, please.
2 For today's meeting as Member Halnon said 3 we prepared to focus on a couple of different areas 4 based on discussion topics at the earlier 5 subcommittees which are listed here. In addition to 6 an overview of the preliminary rule language we'll 7 also plan to talk about staffing considerations 8 including treatment of the role that has been filled 9 by the shift technical advisor at operating plants and 10 its inclusion as it may be relevant for Part 53 11 plants. Also the concept of certified versus licensed 12 operators, considerations for simulators, and plans 13 for updating NRC regulatory guidance documents 14 associated with Part 53.
15 So without further delay I will now turn 16 the presentation over to Jesse. There was one key 17 thing I wanted to say actually which was that we had 18 planned on talking for 30 minutes or less, at least 19 the staff had planned to do that to allow the rest of 20 the time for questions and answers. And we do plan on 21 stopping after talking about the key topics to allow 22 the committee to ask questions and discuss with the 23 staff.
24 So, now without further delay, Jesse, if 25 you'd please take over. Thank you.
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113 1 MR. SEYMOUR: Thanks, Lauren. I 2 appreciate it. Liz, if we can move on to the next 3 slide, please. Thank you. Okay. I'm Jesse Seymour 4 and I'll start out the main part of our presentation 5 by providing an overview of the structure and content 6 of the preliminary proposed rule language that our 7 team has developed within Part 53 Subpart F for 8 application during the operating phase facility-wide.
9 Specifically, we'll be talking about 10 requirements that currently span the 53.750 to .789 11 sections. And these requirements address the general 12 areas of staffing, personnel qualifications, training, 13 and human factors engineering, and they're divided up 14 into four subsections at present. As we go through 15 this I'll provide an overview of those subsections.
16 In light of having covered the full scope 17 of these requirements in detail during previous 18 meetings of the subcommittee today I'll be keeping 19 things at a higher level and focusing on highlighting 20 some of the more significant provisions of these 21 preliminary requirements.
22 To begin with, the 53.750 through .759 23 section covers general requirements that apply to all 24 operating license and combined operating license 25 applicants and holders under Part 53. Within 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
114 1 subsection two key sets of requirements are located at 2 53.753 and at 53.755.
3 First, 53.753 addresses technical 4 requirements for operating license and combined 5 operating license applicants. These includes human 6 factors engineering design requirements, human-system 7 interface design requirements, concept of operations, 8 functional requirements analyses, and function 9 allocation requirements, staffing plan requirements, 10 and licensed and certified operator programmatic 11 requirements.
12 Second, 53.755 section addresses certain 13 conditions of licenses for operating license and 14 combined operating license holders, and some key 15 provisions -- and again, we're just highlighting some 16 major areas -- some key provisions that are embedded 17 in that section include provisions for not using 18 licensed operators, and also provisions for load 19 following.
20 Next, 53.760 through .769 section covers 21 operator licensing requirements including those 22 associated with training, examination, 23 requalification, and simulator requirements.
24 Separately, the 53.770 through .779 section covers 25 operator certification programmatic requirements.
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115 1 And lastly, 53.780 through .789 section covers general 2 training and qualification requirements for other 3 facility personnel.
4 We can move on to the next slide, please.
5 So we begin by focusing on some of the key aspects of 6 the first section, the 53.750 through .759 section.
7 This section fulfills a role that's similar to certain 8 aspects of the existing 50.34(f) post-TMI 9 requirements, 50.54 conditions of facility licenses 10 requirements, and the Part 55 operator licensing 11 requirements.
12 However, a major difference from the 13 current regulatory framework is that the requirements 14 established in areas of human factors engineering, 15 staffing and operator qualification within this 16 preliminary rule language are now linked to design-17 specific safety functions and their fulfillment.
18 I'll explain what is meant at a high level 19 here. First, human factors engineering is required or 20 needed to support safety functions versus being 21 generically applied and limited to a control room.
22 Secondly, operator staffing is required to 23 the extent necessary to support design-specific means 24 for safety function fulfillment versus relying upon a 25 prescribed number of reactor operators and senior NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
116 1 reactor operators. This is an area that Maurin will 2 expand upon shortly.
3 Third, the fundamental role of the 4 licensed operator now centers around the management 5 and fulfillment of safety functions in addition to 6 manipulation of facility controls. Also included are 7 requirements that must be met in order to justify not 8 using any licensed operators as part of facility 9 staffing. And again, I want to make the distinction 10 that these criteria that we're about to talk about 11 that simply establish whether licensed operators are 12 required for a facility. Meeting these requirements 13 doesn't imply (audio interference) staff. It simply 14 means different requirements change, and we'll talk 15 about how they change.
16 Facilities meeting these requirements 17 would have the option to instead use non-licensed 18 certified operators in lieu of licensed operators.
19 And we'll delve further into the specifics of 20 certified operators in the upcoming slides. At 21 present, there's two different staff proposals for 22 what these criteria would consist of.
23 The first proposal is a PRA-centered 24 approach that would require that several criteria 25 could be met in order to meet the overall criteria.
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117 1 And these criteria include, first, not requiring any 2 human actions for event mitigation as part of meeting 3 safety criteria, achieving safety functions, or 4 providing adequate defense-in-depth.
5 The second criteria would be that the PRA 6 for the facility would need to demonstrate that the 7 evaluation criteria for each event sequence could be 8 met without human action for mitigation.
9 And third, the plant response to licensing 10 basis events would need to not be reliant upon human 11 actions to guarantee the performance of safety-related 12 system structures and components. And examples of 13 what we mean by that third criteria are that you would 14 need to be relying upon either things like inherent 15 safety characteristics, or robust passive 16 characteristics, or other safety features that have 17 provisions made to guard against human failures 18 rendering those systems unable to fulfill their 19 function. An example of that would be safeguards 20 against system misalignments and so forth.
21 The second alternate proposal -- so this 22 would be the second bullet. The second alternate 23 proposal is derived from an integrated safety analysis 24 based set of principles. And that would instead 25 require that the design basis accident safety criteria 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
118 1 of Part 53 be met without mitigation by human actions, 2 active engineering features, or by passive engineering 3 features except for those passive features that have 4 the capability to both survive the licensing basis 5 events while also not being defeated by credible human 6 errors. And again I use the term "passive" there, but 7 built into that is that reliance upon inherent safety 8 factors would also be an acceptable means of meeting 9 that second criteria as well.
10 So that's a synopsis of key parts of the 11 53.750 to .759 section. With that being said I'll 12 move into an overview of the other portions. We can 13 go ahead and move on to the next slide.
14 So, sections 53.760 through .769 address 15 operator licensing requirements for those Part 53 16 facilities that require licensed operators. I'd like 17 to note that these sections propose a framework that 18 includes an operator licensing pathway that is 19 independent of, or borrows in part from that of Part 20 55.
21 Key aspects of the operator licensing 22 requirements include, first, requiring training 23 programs to be based on a systems approach to 24 training, and to ensure that licensed operators 25 possess the knowledge and abilities needed to protect 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
119 1 public health and maintain plant safety functions.
2 And secondly, incorporating facility 3 developed and NRC approved examination programs that 4 are tailored to the design-specific operator roles.
5 Section 53.770 through .779 cover the 6 (audio interference) requirements for operator 7 certification programs. At those facilities that are 8 around to use certified operators in lieu of licensed 9 operators. Certified operators are defined under Part 10 53 as being individuals certified to manipulate 11 facility controls without being licensed by the 12 Commission.
13 It is important to note that certified 14 operators are not intended to be credited for 15 fulfilling plant safety functions. But contrary, the 16 designs of the facility to qualify to use certified 17 operators would not have a human role in the 18 mitigation of plant events. This is a topic that 19 Theresa will be addressing in detail later on in this 20 presentation. For now though, key aspects of the 21 operator certification requirements include requiring 22 training programs to be based on a systems approach to 23 training, and to ensure that non-licensed certified 24 operators possess the knowledge and abilities needed 25 to protect the public health and perform job duties, 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
120 1 and also using facility developed and NRC approved 2 tailored examination programs for the qualification of 3 those operators.
4 Lastly, sections 53.780 through .789 cover 5 training and qualification requirements for commercial 6 nuclear plant personnel under Part 53. Section 53.781 7 in particular covers specific training and 8 qualification requirements, and these -- key aspects 9 of these include requiring training programs to be 10 established with sufficient time to provide trained 11 and qualified personnel to operate the facility prior 12 to fuel load. And this is a flexibility beyond the 13 existing 51.20 requirements.
14 Requiring the use of a systems approach to 15 training which is consistent with our system 16 requirements, and also requiring the training and 17 qualification of supervisors, technicians, and other 18 appropriate operating personnel to be accounted for.
19 And importantly it should be noted that the categories 20 of personnel described in the preliminary language are 21 in general more generic than those of 51.20 in order 22 to accommodate for greater flexibilities in roles and 23 responsibilities.
24 So with that being said I'd like to go 25 ahead and hand off to Maurin who will continue on 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
121 1 the staffing part of the discussion.
2 MR. SNODDERLY: Thanks, Jesse. Can you 3 hear me?
4 MR. SEYMOUR: Yes, I can hear you.
5 MR. SNODDERLY: Great. So, this is Maurin 6 and I'm going to talk about our Part 53 staffing 7 approach, and then the rule language. And then I'll 8 talk a little bit about the shift technical advisor, 9 and we'll have some time for discussion there.
10 So first as the next slide -- there we go, 11 staffing approach. So, we wanted a staffing rule that 12 works for new and novel concepts of operations, those 13 that we expect to see for the wide variety of advanced 14 reactor technologies, and we want something that 15 allows more flexibility based on design-specific 16 needs.
17 A key assumption we have is that 18 prescriptive staffing requirements like those that we 19 use for large light water reactors which assign a 20 specific number of operators and senior operators to 21 be onsite in the control room and at the controls.
22 That doesn't make sense for Part 53.
23 We do not believe that rule-based 24 prescriptive staffing levels would provide reasonable 25 assurance of safe plant operation across different 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
122 1 designs and facility sites. Furthermore, the use of 2 prescriptive staffing would likely force applicants to 3 rely on the exemption process when those staffing 4 levels didn't fit their design's needs. So we don't 5 think that would be an efficient or practical approach 6 to rely on exemptions.
7 We think that flexible staffing 8 requirements, ones that are risk-informed, 9 performance-based, and technology-inclusive are 10 needed.
11 We anticipate that there will be designs 12 where operators do not significantly influence safety 13 outcomes. And because of this we thought about 14 staffing needs for two groups of advanced reactor 15 facilities. One group where operators have a safety 16 role, and one group where operators do not have a 17 safety role.
18 You'll notice that this staffing approach 19 is consistent with our Part 53 approach for human 20 factors as well as licensing or certifying operators, 21 and that's because these areas are interrelated. In 22 fact, the Part 53 requirements in these areas are 23 integrated and supported by requirements for 24 applicants to submit new types of information as part 25 of their application.
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123 1 Those new types of information that we're 2 going to require are things like a concept of 3 operations document, and a function requirements 4 analysis, and information about function allocation.
5 So for a given facility design this type of 6 information gives the staff a broad understanding of 7 the operator's role in facility safety, thus informing 8 staffing plan needs.
9 Finally, we relied heavily on our 10 experience that we gained in recent years from 11 evaluating staffing plans as well as looking at how to 12 eliminate the shift technical advisor position for the 13 NuScale small modular reactor design. Next slide, 14 please.
15 So that was our approach. Now I'm just 16 going to summarize the Part 53 staffing plan 17 requirements.
18 MEMBER BROWN: Can you go back a slide?
19 MR. SNODDERLY: Go back a slide.
20 MEMBER BROWN: This is Charlie Brown.
21 Yes, back to slide 9. What is a novel concept?
22 MR. SNODDERLY: I think we just mean new.
23 So different -- new and different conduct of 24 operations. The end concept. Sorry, novel -- new or 25 novel. Basically we're saying different than what 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
124 1 we're used to --
2 (Simultaneous speaking) 3 MEMBER BROWN: -- is fundamentally what 4 you're saying. Is that right?
5 MR. SNODDERLY: Say it again? I talked 6 over you.
7 MEMBER BROWN: No operators would be okay.
8 MR. SNODDERLY: That would be novel. I 9 think we're just saying we expect different ones.
10 There are so many different designs out there, their 11 concept of operations are going to be varied. We're 12 trying to come up with a way to require staffing for 13 different types of ways to operate the plant.
14 MEMBER BROWN: Have you given any 15 consideration that there ought to be some, how do I 16 phrase this. Do you have a basis? That's not what 17 I'm trying to say. Just saying novel concept without 18 some idea of where you think a cutoff may be. You 19 don't have any floor the way this is phrased.
20 MR. SNODDERLY: Well, I mean this is -- I 21 think Part 53 has some broad requirements to come in 22 the door so we're going to look at whatever the 23 concept of operations are for those plants. I think 24 Lauren has her hand up if she wants to try a stab at 25 Charlie's question.
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125 1 MS. NIST: Thanks, Maurin. I just wanted 2 to say that this is talking about -- this bullet here 3 is the staff's approach to coming up with a 4 performance-based technology-inclusive staffing 5 requirement.
6 MEMBER BROWN: I don't need the buzzwords.
7 I'm not trying to be critical, but those buzzwords are 8 used for everything. Performance-based, technology 9 neutral, blah, blah, blah. And I'm not criticizing, 10 that's just what's being used for everything as if 11 that's the magic elixir that's going to give us --
12 MS. NIST: So (audio interference) just in 13 the interest of proceeding on and clarity we're 14 talking about what the staff's effort is and our work 15 product is attempting to accommodate reviews that we 16 might -- approach of how we might review concepts of 17 operation for facilities that basically aren't large 18 light waters. That's the point we're trying to get 19 across with the bullet.
20 MEMBER BROWN: I understand that, but it 21 seems to me you ought to have some idea of what would 22 be acceptable -- the least acceptable thing you would 23 accept I guess. The minimum thing you may accept. I 24 mean, this is open-ended and to me there ought to be 25 a game plan or some thought process to say what -- do 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
126 1 we really think you can sit these out with having 2 nobody around for 500 miles. And if the answer to 3 that is no then you try to put something into the 4 staffing approach that gets that point across. I 5 mean, should there be a minimum staff as opposed to 6 zero. That's the only point I'm trying to make and 7 this doesn't give the communication to whoever comes 8 in to do a Part 53 that zero is not ever going to be 9 the right answer. That's all I'm saying. This is --
10 it's totally open-ended.
11 MEMBER HALNON: Jesse, you wanted to weigh 12 in?
13 MR. SEYMOUR: Yes, yes, I appreciate that.
14 So, I just want to make a point, a clarifying point 15 here that under the preliminary proposed structure 16 that we're talking about here there is no outcome that 17 ends with zero operations personnel being associated 18 with an operating power reactor. There's always going 19 to be some variation of licensed or certified 20 personnel overseeing the plant operations. So zero is 21 not an acceptable outcome with what we're doing here.
22 MEMBER BROWN: Is that clear from the 23 writeup? The comment, I like the comment that zero is 24 not the right outcome. Somehow that thought crossed 25 -- this is my personal opinion obviously.
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127 1 CHAIRMAN REMPE: Excuse me, we're getting 2 a lot of background noise. So if you're not speaking 3 please mute your computers or whatever.
4 MEMBER BROWN: I'm sorry, Joy.
5 CHAIRMAN REMPE: I just was going to tell 6 you to go ahead.
7 MEMBER BROWN: My only reason for making 8 the comment is that somehow this zero is not an 9 acceptable outcome is -- should be communicated 10 somehow as part of the Part 53 language. That's all 11 I'm saying. There's -- that's the reason I made the 12 comment. I've just never done anything without having 13 an idea of where -- what the minimum I would accept in 14 terms of -- it's like looking at the I&C system. I 15 would never accept a system that allows total 16 communication between all four independent, non-17 independent channels. That's insane. So to me 18 staffing is --
19 MR. SEYMOUR: So I'm not hearing anything 20 on my end. I'm not sure --
21 MEMBER HALNON: This is Greg online. We 22 just lost our stuff again here. So if you all would 23 just hang in and let us get our internet back here at 24 the ACRS room we'll be back with you in a minute.
25 MR. SEYMOUR: Okay, thank you.
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128 1 MEMBER HALNON: We're still working on it 2 so everybody just stand by. Okay, we're coming back 3 now. I take it back, we're not coming back now. Hold 4 on.
5 (Simultaneous speaking) 6 PARTICIPANT: This is one of the things 7 that happens where I don't think I'd ever be able to 8 sit in a driverless car.
9 CHAIRMAN REMPE: You have no faith in the 10 future, Derek. I think we're back.
11 MEMBER BROWN: You just made my point 12 Derek.
13 (Simultaneous speaking) 14 MEMBER HALNON: Okay, this is Greg. We're 15 going to continue on. Member Bier has a comment to 16 make and then I'll summarize the theme of what we're 17 listening to, and we'll let you guys go on from there.
18 MEMBER BIER: This is in a way a different 19 version of Charlie's question which is what is the 20 basis for evaluating proposals. So for instance, 21 let's say we decide that X number of operators is 22 acceptable for Y number of reactors of a certain type, 23 right. One operator can handle however many.
24 So then five years from now they come back 25 and say well, everything has gone really smoothly 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
129 1 now we want twice that many reactors. And five years 2 later they may come back and say well, everything is 3 going super smoothly so now we want three or four 4 times what you approved initially, and that could keep 5 going until something doesn't work anymore. And is 6 there a process by which there would be a way to say 7 no, we approve this based on these assumptions and 8 that's no longer valid as you increase. You need to 9 up your operators.
10 MEMBER HALNON: Thanks.
11 MEMBER BROWN: Can I amplify what she said 12 a little bit Jesse?
13 MR. SEYMOUR: Go ahead.
14 MEMBER BROWN: What just occurred --
15 what's been brought up in the past is that we'll have 16 these reactors sitting out there, a small modular 17 reactor with somebody in the middle of Wyoming with 18 somebody back in New York controlling it via the 19 internet. And we just lost control. I mean, somehow 20 it's got to be communicated that you've got to be in 21 a manner to always have control on demand. And I 22 don't know what the right way to phrase it is, but 23 that's the thought process that I think you ought to 24 be trying to incorporate into the Part 53 language.
25 Did I reflect your thought?
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130 1 MEMBER HALNON: Yes. For the staff don't 2 answer that now.
3 MEMBER BROWN: No reason to answer.
4 MEMBER HALNON: But what I wanted to say 5 is that the theme that you're going to be hearing I 6 believe, and we talked about it. I had to sit back 7 and think about what the themes were at the 8 subcommittee meetings was the -- and I don't know if 9 I'm going to use the right word. It's sort of the 10 permissive structure, the lack of a minimum, the lack 11 of an expectation or whatever the case may be. We 12 talked about with the STA. We'll talk about it some 13 more.
14 So we'll work through that and try to 15 clarify that comment for you so that you'll understand 16 where we're coming from as we go through this. So I 17 didn't want to bog it down right now.
18 MEMBER BROWN: That's fine. I just wanted 19 to get that thought process.
20 MEMBER HALNON: You popped the bubble on 21 where we wanted to go on some of these things. Go 22 ahead.
23 MS. CUBBAGE: This is Amy Cubbage, NRC 24 staff. I just wanted to interject if I may.
25 MEMBER HALNON: Go ahead, Amy.
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131 1 MS. CUBBAGE: I wanted to reiterate what 2 Jesse was saying, that under Part 53 we're currently 3 not considering fully remote and autonomous operations 4 which I think is what Charlie was alluding to.
5 MEMBER HALNON: Thanks, Amy. And it's not 6 just the autonomous.
7 MEMBER BROWN: It wasn't just -- I'm 8 sorry, Greg, go ahead.
9 MEMBER HALNON: No, it just wasn't 10 autonomous. It was the minimum requirements.
11 MS. CUBBAGE: Understood, understood. I 12 just wanted to clarify the idea of remote and fully 13 autonomous is not being contemplated right now under 14 the rule. And as Jesse indicated all of these 15 scenarios would have some operations presence onsite.
16 It's a matter of how many and what their 17 certifications or licensing would be. And Jesse, 18 please correct me if I'm wrong.
19 MR. SEYMOUR: No, that is the case. And 20 I just, you know, while I have the floor here just for 21 a second I just want to reinforce the fact that when 22 determining the number of operators. And again, we're 23 talking about licensed operator staffing and the 24 general approach that Maurin is outlining here. This 25 is a performance-based requirement. And Maurin will 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
132 1 talk about this. But an applicant is going to have to 2 use human factors engineering based analyses and 3 assessments to show the proof, to show the data for 4 why that number of people is going to be capable of 5 fulfilling the safety functions for that facility.
6 So not only do we not go to zero, but we 7 also have essentially the state of the art of human 8 factors engineering that has to be backing up the 9 number that they're using.
10 MEMBER BALLINGER: This is Ron Ballinger.
11 I've got to go look at the transcript for one of the 12 previous Part 53 meetings, but I seem to recall the 13 statement that Part 53 will not preclude autonomous 14 and remote operation.
15 MEMBER BROWN: That's correct. I vaguely 16 remember that, but I would not swear to it.
17 MEMBER BALLINGER: So what I'm hearing now 18 is that's not the case.
19 MEMBER HALNON: And I think -- this is 20 Greg. We're talking two different areas. We were 21 talking in the technology world about how you would 22 license the technology as opposed now we're talking 23 how you staff the operators. So there is a disconnect 24 between those two areas. If the expectation from this 25 group is that you will not have autonomous reactor 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
133 1 operations that's not the expectation of the group 2 writing the language for the earlier parts of the Part 3 53. We did have that discussion at least once if not 4 twice during other subcommittee meetings, but not for 5 the Subpart F. So that's a question.
6 The other piece of it is, again, it's not 7 so much the autonomous operations, it's the lack of 8 that expectation being very explicit in the rule 9 language which is what you just said, Jesse, was there 10 will not -- there's no expectation of zero operators, 11 no expectation of autonomous or remote operation.
12 Well, that's not in the rule language. That's your 13 expectation, but that's not in the rule language. So 14 that's the point, again, as we try to cut through all 15 the examples. But that's the point.
16 CHAIRMAN REMPE: Greg, I'm going to 17 interrupt here for a minute. Someone tried to respond 18 with a technical response in the chat. That doesn't 19 appear in the transcript and so it doesn't -- in fact, 20 it just flashes on the screen and it's gone. So if 21 the staff wants to make the comment they need to make 22 it verbally so it's on the record.
23 MR. SNODDERLY: Right, Chairman, and I can 24 do that. This is Maurin. I'm ready to keep going and 25 I talk to what's in the chat. And what's in the chat 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
134 1 is this implication that the staffing plan, there's 2 got to be somebody there. So if you look in the 3 Subpart F discussion table from October 2021 when we 4 put this proposed rule language out, or preliminary 5 rule language out it discusses how the staffing 6 requirements work.
7 And the implication of staffing 8 requirements specified here for certified operators 9 are that there must be a minimum of one individual 10 fulfilling these requirements at all times with as 11 many additional certified operators as needed above 12 that minimum in order to implement these requirements.
13 An applicant will need to demonstrate how 14 their proposed approach to certified operator staffing 15 accomplishes this. It must also be recognized that 16 even a fully autonomous reactor would still need to be 17 under the cognizance of a certified operator. So in 18 staffing land where the rule works is that there's at 19 least one person there. We don't say that in the rule 20 because that would be prescriptive, but there is an 21 assumption. And we're going to look at that.
22 And that's where I was trying to get --
23 these areas are all interrelated. So you know, who 24 are these people. Well, they're certified operators 25 or they're licensed operators. And there's human 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
135 1 factors requirements to determine those needs and what 2 kind of HSI they operate with, or just watch, monitor 3 with, et cetera. So it's all interrelated.
4 I agree it doesn't really work with zero.
5 I can't review a staffing plan that says zero.
6 There's not going to be much to do. So it's kind of 7 set up for this. And this does establish a minimum.
8 So we're letting the design kind of lead that, what is 9 the minimum for this design and prove it is kind of 10 what -- that is our approach.
11 MEMBER BALLINGER: To me the word 12 "cognizance" is important. That doesn't mean the 13 operator has to be there.
14 MEMBER BROWN: There's another thought 15 process with that. One of the things that needs to be 16 considered in terms of operating any plant, and I can 17 use only one example. I will just use one example, is 18 when you have multiple plants and you've got a large 19 amount of computer-based operations where they're 20 monitoring and they're controlling and you've got one 21 operator there ought to be -- this is me, not the 22 committee talking. For any critical operation 23 something has to start, or be stopped, or initiated, 24 or what have you. There ought to be a manual backup 25 somehow, and that's part of the human factors 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
136 1 engineering assessment is can that be done if the 2 automation fails.
3 We do that with reactor trips. There's a 4 manual backup, manual scram switch that goes directly 5 to the scram breaker. You can directly go start a 6 pump if you need to manually. It doesn't go through 7 the computer system. So I don't know how that --
8 that's got to be factored in when you're looking at 9 human factors engineering and the displays a person 10 has even if it's only one. That doesn't mean -- it's 11 just a thought process that you've got to consider as 12 part of this whole staffing and operations setup.
13 I'll stop right there. It's just a thought process.
14 MR. SNODDERLY: Okay, thank you.
15 MEMBER BROWN: Thank you.
16 MR. SNODDERLY: Thank you for that. Okay, 17 so I think we were on the slide with the rule. I was 18 stepping through the staffing rule. And first, the 19 applicant needs to provide a staffing plan that 20 describes the numbers, positions, and qualifications 21 of reactor operators and senior reactor operators or 22 certified operators across all modes of operation.
23 That staffing plan needs to describe 24 personnel providing support in areas such as plant 25 operations, equipment surveillance and maintenance, 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
137 1 radiological protection chemistry, et cetera. The 2 list is on the slide, I'm not going to read it all.
3 And this type of information, they support areas --
4 this information supports the staff's understanding of 5 any non-traditional roles or collateral duties that 6 those licensed operators or certified operators might 7 have, and any associated workload with that.
8 And then finally facilities that are 9 required to have licensed operators must provide a 10 description of how the proposed licensed operator 11 staffing would be sufficient to provide assurance that 12 plant safety functions can be maintained. And this is 13 performance-based. It needs to be supported by HFE, 14 human factors engineering analyses and assessments.
15 MEMBER HALNON: This staffing plan is 16 absolutely key obviously, and it's going to be -- I 17 assume it's submitted and approved by you guys during 18 the licensing process. Is there going to be a 19 guidance document that puts out there what are the 20 minimum requirements for a staffing plan to submit? Or 21 are you going to let it be a free flow of whatever the 22 licensee or the applicant wants to put in there?
23 That's not the right way to put it. Are you going to 24 have a guidance document that's going to give what one 25 should look like, what should it contain, what level 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
138 1 of detail in that respect?
2 MR. SNODDERLY: We have a staff review 3 guidance document under way for this to look at these 4 staffing plans, how to -- what we're going to be 5 looking for, how we're going to verify that they work, 6 what kind of validation did the applicant do. So yes, 7 that exists in the form of guidance.
8 But the requirement itself is right here.
9 That has to describe numbers, positions, and 10 qualifications across all modes. So this is what's 11 required. It's pretty clear, but how the staff is 12 going to look at it, yes, that will be available and 13 it's -- like I said it's under way currently as an 14 interim staff guidance white paper that we'll be 15 putting out for comment sometime this spring I think.
16 MEMBER HALNON: Okay. I think we'd like 17 to see that when you get it to a point where you want 18 it to be. I think that will help alleviate any fears 19 that we're not going to have operators onsite, or 20 anything like that. Let's go ahead and move on unless 21 there's other comments. Okay, go ahead.
22 MR. SNODDERLY: Okay. Next slide, please.
23 So now I'm going to talk about the shift technical 24 advisor, or the STA for Part 53. Initially the staff 25 did not include a requirement for staffing the shift 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
139 1 technical advisor position in rule language. We 2 arrived at this position in part because of commission 3 policy that made the STA position an interim measure 4 after the accident at Three Mile Island unit upgrades 5 could be made to the control room human-system 6 interfaces and operator training.
7 We also left the STA out of the rule 8 because of the combination of other requirements for 9 operator training, human factors engineering, human-10 system interface design, staffing analysis, and 11 defense-in-depth provisions for Part 53 facilities 12 that in essence take over from the STA.
13 We understand that the committee has the 14 following concerns about the no STA approach. And 15 they are reservation about blanket STA elimination 16 under the rule, the value of having an independent 17 individual for event assessment, a desire to maintain 18 engineering expertise available, and the relevance of 19 the role of the STA in light of uncertainties with new 20 designs. So we understand those concerns and I'll say 21 in light of these concerns and after additional 22 discussion that we've had on this very challenging 23 topic we are currently considering three different 24 options for the next iteration of the rule language.
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140 1 requirement for staff. The second is STA is required 2 with provisions for omitting it with justification.
3 And that would be at plants with licensed operators.
4 So the STA would still be required as part of that 5 staffing. And then the third one is at all plants 6 regardless of whether they have licensed or certified 7 operators all plants must provide independent and 8 readily available engineering expertise to the on-9 shift operators. So like I said we're still 10 considering them. I'm going to open up the floor now 11 for full committee discussion on this topic if I can.
12 CHAIRMAN REMPE: So before a member has a 13 comment, we discussed earlier that the court reporter 14 could identify which member is talking and they didn't 15 need to identify themselves. Apparently my light, I'm 16 the chairman, lights up anytime anyone in the room 17 talks. And so a participant has indicated that it 18 would be helpful for them if we could identify 19 ourselves. It's not absolute all the time, but just 20 to try and have them understand who's talking. Okay, 21 folks? Thank you. Go ahead.
22 MEMBER HALNON: Thank you, Chairman. So 23 we've arrived at this point after subcommittee 24 discussions and providing comments back to where we 25 have these three options. Again, this is Greg Halnon.
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141 1 That didn't work very quickly, did it. Isn't two and 2 three essentially the same? In other words, if you 3 can do number three then you can eliminate the STA 4 provision. I guess explain to me the difference 5 between two and three.
6 MR. SNODDERLY: Okay. So, two is like we 7 say today at our Part 50 plants, that's the STA body.
8 There's licensed operators in the control room. The 9 STA might be one of them, a licensed SRO or has other 10 qualifications. So that's going with what we 11 currently have for that position, that role, with the 12 option to justify why you don't need it such as we saw 13 for NuScale.
14 MEMBER HALNON: Wouldn't you use number 15 three to justify why you wouldn't need it?
16 MR. SNODDERLY: Could you use number three 17 to justify --
18 MEMBER HALNON: In other words, the way 19 that we justify omitting the STA now is by saying we 20 have engineering expertise within our licensed 21 operators, and we have them available that they can 22 jump into the STA role.
23 (Simultaneous speaking) 24 MR. SNODDERLY: I think in number two 25 we're looking at the traditional STA, and number 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
142 1 three, these are standalone. These aren't like you 2 can do any combination. If we went with number three 3 it's having some access to engineering expertise. So 4 you don't have to call that person the STA. They 5 don't have to be the licensed operator. So different 6 from two is that it could be somebody at a different 7 location that you can get a hold of, this is one way 8 I see it. To help you with an issue that you're 9 seeing on shift.
10 MEMBER HALNON: Okay, I get it. So number 11 three is just access to. I've got it. Okay.
12 MR. SNODDERLY: Yes.
13 MEMBER HALNON: So it doesn't have to 14 necessarily be onsite, but you have somebody who they 15 have on call that they can call at any time.
16 MR. SNODDERLY: Exactly.
17 MEMBER BROWN: I think the key is on call 18 for each shift of operation. Not that you find them 19 if they're there. They have to know they've got to be 20 available. That's the way I would read that.
21 MEMBER HALNON: Yes, and this is Greg 22 again. I assume that we would go further on the 23 engineering expertise that they would have access to 24 indications, display information that is independent 25 than just a phone call where somebody is relaying 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
143 1 information to them.
2 MR. SNODDERLY: Right. I imagine some 3 kind of awareness -- this is Maurin, sorry. Some kind 4 of awareness -- we haven't gotten into the details of 5 how this works or looks, but -- and I will point out 6 that number three is for certified and licensed 7 operator plants. So anything coming in.
8 And number two is those licensed operator 9 plants where there are things that the operators have 10 to do to maintain safety functions, keeping the 11 traditional STA role to advise them.
12 MEMBER HALNON: Okay, thanks. Jesse?
13 MR. SEYMOUR: Thank you. I just wanted to 14 add to the point. And again, with the understanding 15 that option three would have to be further developed 16 if we were to incorporate this.
17 We do have human-system interface design 18 requirements that we adapted from the existing 19 comparable post-TMI requirements. So when you go 20 through and you look at certain indications and so 21 forth that are required to be available to the 22 operators, we do have things that cover possible 23 indication of core damage states, establishes safety 24 functions, and those kinds of important parameters.
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144 1 whether it's a licensed operator plant or a certified 2 operator plant. So again, it wouldn't take too much 3 to extend those types of provisions to whoever is 4 fulfilling this engineering expertise type of 5 requirement.
6 MEMBER HALNON: Thank you, Jesse. Go 7 ahead on with your presentation.
8 MR. SNODDERLY: Okay, well that's all I 9 had prepared for my part on the STA. It looks like 10 we're ready to pass off to Theresa now. She's going 11 to talk about certified operators. Over to Theresa.
12 MS. BUCHANAN: Yes, Maurin. Can you give 13 me a sound check?
14 MR. SNODDERLY: Sound good.
15 MS. BUCHANAN: Thanks, Maurin. So I'm 16 Theresa Buchanan and I'm here this afternoon to talk 17 with you all about certified operators or 18 certification of operators which is of course a brand 19 new proposed process from how we're currently doing 20 it.
21 I would like to note that I have a hard 22 stop at 5 p.m. so hopefully I'll be able to get 23 through all of my section. If not Jesse is standing 24 by to step in and pinch hit for me. So I thank Jesse 25 for being willing to do that.
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145 1 So, certified operators. Giving you some 2 background. The staff has proposed an option that 3 allows for the use of non-licensed operating staff in 4 place of licensed operators at plants that can meet 5 stringent safety criteria. These individuals would 6 still be required to complete a commission approved 7 systems approach to training based training program 8 and to demonstrate competence through an examination 9 process that is approved by the Commission, but the 10 certification of that competence would be through a 11 facility program rather than through the Commission 12 licensing process. Therefore, the expectation is that 13 these operators would demonstrate a similar level of 14 competence at performing those required actions 15 determined from a job task analysis as would a 16 licensed operator, although the domain of those 17 actions may be different.
18 The stringent safety criteria that would 19 need to be met to allow use of this option would 20 ensure that the certified operator was not relied on 21 to perform actions necessary to safely mitigate 22 licensing basis events as opposed to a licensed 23 operator who would be.
24 The certified operator therefore would not 25 need to demonstrate competence in performing 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
146 1 actions because they would not exist at that site.
2 The certified operator would be responsible for 3 administrative functions similar to what a senior 4 reactor operator would be expected to perform as well 5 as being responsible for operation of the facility in 6 the following ways as applicable to the site design.
7 Monitoring plant data and parameters, shutting down 8 the reactor when required, dispatching maintenance or 9 other operations personnel, implementing the emergency 10 plan, and of course performing reactivity 11 manipulations when required. Next slide, please.
12 All right, so now I'm going to talk about 13 --
14 MEMBER BROWN: Can I ask you, can you go 15 backwards?
16 MS. BUCHANAN: Certainly. Can we please 17 go back one slide.
18 MEMBER BROWN: Slide 12. I just want to 19 make sure I understood you. You said the certified 20 operator would not be able to handle an accident 21 situation.
22 MS. BUCHANAN: I'm saying that --
23 (Simultaneous speaking) 24 MS. BUCHANAN: Are you finished with your 25 question?
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147 1 MEMBER BROWN: Yes, I'm trying to make 2 sure I understood what you said. I heard the words 3 accident or -- I can't remember exactly how you 4 phrased it. Safety function, that's what you used.
5 You wouldn't be certified to be -- to safety functions 6 like a licensed operator would be. If that's the case 7 who would?
8 MS. BUCHANAN: The terminology I used is 9 that the stringent safety criteria that Jesse was 10 discussing earlier would be in place to ensure that 11 certified operators were not relied upon to perform 12 actions necessary to safely mitigate licensing basis 13 events. The reasoning being was that other processes 14 that don't rely on human actions would be the ones 15 that would be relied upon to mitigate licensing basis 16 events in order to meet the other requirements of Part 17 53.
18 MEMBER BROWN: So it would be all 19 automatic in other words. It would not require human 20 intervention to perform those safety functions.
21 MS. BUCHANAN: It would not require human 22 intervention to perform those safety functions. I'm 23 not sure I would agree with the use of the term 24 "automatic" because as Jesse mentioned on the second 25 optional criteria it relies on things like inherent 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
148 1 safety characteristics. So the use of physics, or 2 gravity. So if you consider those to be automatic.
3 I consider those to be more inherent to the design.
4 Any other questions on this slide?
5 MEMBER BROWN: No, that's fine. Thank 6 you.
7 MS. BUCHANAN: All right. Next slide, 8 please then. All right. So now we're going to talk 9 a little bit about -- so I looked at some of the 10 background. Now here's some of the reasoning. We 11 sort of got into it a little bit on the last slide.
12 If an operator is not needed to ensure 13 safe mitigation of licensing basis events as I just 14 mentioned then they would not be required to be 15 licensed from a public health and safety standpoint.
16 Regulatory burden is also a consideration.
17 These facilities would be expected to have finite 18 resources. And if we're requiring additional burden 19 for licensing of operators when not necessary from a 20 safety standpoint then that could require the use of 21 resources that would be better applied elsewhere from 22 a safety standpoint. In other words, requiring 23 licensing of operators when not necessary from a 24 safety standpoint could actually have an adverse 25 impact on safety even though that's counter-intuitive.
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149 1 Note, the facility is still licensed and 2 must still have and follow a commission approved 3 training and examination program for these operators 4 which would be monitored for compliance by the 5 Commission through periodic inspection. Tasks 6 identified by the job task analysis for the certified 7 operator position would still be accomplished by 8 rigorously trained and qualified individuals.
9 So we have some past precedent. Certified 10 fuel handlers are an example of a similar process in 11 that the position requires these individuals be 12 trained and qualified to perform the tasks identified 13 by a job task analysis, in their case involving 14 movement of fuel in the spent fuel pool through to dry 15 storage. The certified fuel handler is responsible to 16 ensure reactivity is maintained, respond in the event 17 of an accident in their case, for example, a damaged 18 fuel rod or a drop in fuel in order to take actions to 19 mitigate the event. Their actions may not be complex 20 and the consequences of the accident may not be as 21 significant as for a currently operating facility.
22 When I talk currently I mean currently operating, 23 current power operators, not advanced reactors.
24 But they are still there and they have 25 been evaluated as being acceptably low to allow for 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
150 1 certified fuel handler program by a licensed operator.
2 These processes are not the same, but they are similar 3 in that the certified fuel handler like a certified 4 operator would be expected to monitor the progress of 5 work, perform administrative functions, direct work 6 activities, and oversee operations in the case of a 7 certified operator that may impact reactivity in the 8 spent fuel pool. Not on this --
9 MEMBER BROWN: I'm sorry, go ahead.
10 MS. BUCHANAN: Okay. Not on this slide, 11 but another example that I wanted to provide is with 12 fuel cycle facilities. Although the NRC does have the 13 authority under the Atomic Energy Act of 1954 as 14 amended to license operators at fuel cycle facilities 15 this has not been done in practice. Instead, 16 technicians and line operators at these facilities are 17 trained and qualified in the required aspects of their 18 job by the facility. This process is reviewed as part 19 of our standard review plan for fuel cycle facility 20 applications. Again, this is a similar process but 21 there are some differences as there are safety 22 consequences for these individual actions or inactions 23 in operation of the facility.
24 In fact, 10 CFR Part 70.61 discusses what 25 I refer to as safety tiers. An example would be 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
151 1 high-consequence event, or credible intermediate 2 consequence event. And they require engineering or 3 administrative controls to limit the likelihood of 4 these events. And these controls are applied to the 5 worker's responsibilities as applicable.
6 A high-consequence event could result in 7 an acute worker dose of 100 rem or more, a dose of 25 8 rem or more, or intake of 30mg or more of soluble 9 uranium to any individual outside the control area, or 10 certain acute chemical exposures to individuals.
11 A certified operator for a power facility 12 would not be expected to be required to manipulate 13 plant equipment in the event of an accident as we 14 discussed earlier, although they would have other 15 responsibilities such as notifications and 16 administrative actions.
17 For reactivity manipulations and whether 18 or not a non-licensed operator can safely perform 19 those the staff's perspective is that if the design 20 can meet the stringent safety criteria then the 21 consequences of any errors performed by the certified 22 operator during these reactivity manipulations would 23 be bounded by the design, and this plus the previously 24 discussed rigorous qualification requirements provides 25 an adequate assurance of protection.
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152 1 Finally, although it has been said that 2 some current advanced reactor designs may meet the 3 stringent safety criteria Jesse mentioned earlier, 4 even if they currently cannot the intent of this rule 5 is to make it robust enough to accommodate future 6 designs which may be able to meet this criteria.
7 MEMBER BROWN: Can I ask a question?
8 MEMBER HALNON: Go ahead, Charlie.
9 MEMBER BROWN: It says whether the 10 operators are licensed or not the facility would still 11 be licensed by NRC. Does that shift the liability to 12 make you responsible then if something went bad as 13 opposed to the operators? Not the operators but the 14 company or whoever, the licensee? Is that the same as 15 for fuel facilities, that NRC assumes the liability 16 because it's licensed by NRC even though the operators 17 aren't? It's a little bit different. It's not a 18 reactor plant, it's a fuel facility as opposed to 19 there's -- consequences are somewhat less than you 20 would from a power reactor.
21 MS. BUCHANAN: I agree that the 22 consequences at a fuel cycle facility are somewhat 23 less than that of currently operating power reactors, 24 yes. There are some differences, and I did 25 acknowledge the fact that these -- precedent are not 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
153 1 exact precedent. They are similar, they are not the 2 same. I do have some information on the next slide 3 that actually may address your question.
4 MEMBER BROWN: You answered my question.
5 NRC effectively absorbs the liability when we're in 6 this position for a power reactor. That's the way I 7 would read this. Greg?
8 MEMBER HALNON: She made a point -- this 9 is Greg -- made a point of saying that the facility is 10 still licensed. So you're still going to have a chief 11 nuclear officer, or somebody that is in charge of 12 nuclear that's going to -- the officer will ultimately 13 be held.
14 MEMBER BROWN: The owner --
15 MEMBER HALNON: The owners --
16 MEMBER BROWN: -- even though they're 17 licensed by the NRC without the "operator" licensing 18 certification.
19 MEMBER HALNON: I believe that would be 20 the case in this situation.
21 MEMBER BROWN: Okay. All right, well 22 thank you.
23 MEMBER HALNON: I mean, you'd have to 24 follow up with the enforcement policy, but it will go 25 after the officer of the company.
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154 1 MEMBER PETTI: I just had a question and 2 I don't know the answer. Does this new approach 3 impact the ability of facility owner and Price-4 Anderson insurance and all that, is there a connection 5 there that has to be thought of?
6 MS. BUCHANAN: Well, I will state that I 7 don't have the answer to that as I'm not really 8 involved in anything to do with the Price-Anderson Act 9 associated with insurance. What I will say is that I 10 actually have information on the next slide that's 11 really related to this topic so if everyone is okay 12 with it can I go to the next slide and then we can 13 revisit this?
14 MEMBER PETTI: Sure.
15 MS. BUCHANAN: Okay. So let's go to the 16 next slide, please. All right, so there are actually 17 some prior concerns raised by the ACRS subcommittee.
18 And some of these concerns include differences in 19 accountability as compared to licensed operators which 20 is kind of what was being alluded to earlier. Where 21 is the accountability, as well as a lessened ability 22 to resist coercion by inappropriate management action 23 or orders, a redundancy to a scalable operator 24 licensing provision, as well as lack of certification 25 by an independent entity, i.e., NRC.
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155 1 So we acknowledge that these concerns are 2 valid. We continue to have the perspective that if 3 the stringent safety criteria are met to allow the use 4 of this provision the safety consequences of an 5 inappropriate operator action or inaction are so low 6 that these concerns would not be expected to have a 7 significant impact on the safety of the facility.
8 Additionally, the framework allows for 9 appropriate staffing requirements when there's no 10 significant human role in safety. There's past 11 precedent for using non-licensed personnel in similar 12 roles although those roles have a different relation 13 to safety for those types of industries.
14 The ability to meet the criteria and the 15 desire of the industry for this provision has been 16 expressed. It is important to note, and here's the 17 piece I wanted to get to. It's important to note that 18 the administrative section of technical specifications 19 can assign and with the current operating reactor 20 fleet have assigned responsibilities to management to 21 allow for personal accountability so not just the 22 facility is accountable.
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156 1 for the facility, that certified operators have 2 certain responsibilities they must meet.
3 So before I finish the slide did that 4 answer the question that was raised earlier, at least 5 help answer the question that was raised earlier?
6 MEMBER HALNON: I would say it addresses 7 the question. I'm not sure it answers it.
8 MS. BUCHANAN: All right. I'll take 9 addressing it.
10 MEMBER BIER: I'd also like to ask a quick 11 follow-up. This is Vicki Bier. I just want to make 12 sure I understand a question that was going through my 13 mind while I was listening to you. Early on you said 14 that a certified operator would have no safety 15 responsibility essentially. And in my mind I was 16 running through but actions they take could have 17 adverse consequences for safety and who's going to be 18 there to fix it if they do.
19 And the second part of your presentation 20 kind of said well, those adverse consequences would 21 have to be bounded by the design of the facility. Is 22 that the answer to my nagging question, that there's 23 a limit to the damage somebody can do?
24 MS. BUCHANAN: I wouldn't call that a 25 nagging question. I would call that a very good 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
157 1 question and the answer is yes, that is part of it.
2 I believe when -- and Jesse, please correct me if I'm 3 wrong, but I believe when the stringent criteria that 4 he was mentioning, especially on the second option, 5 there's a statement there that has to do with the 6 ability to withstand not just the event, but basically 7 operator actions associated with the event. Jesse, 8 did you have anything you wanted to add on that?
9 MR. SEYMOUR: Yes, Theresa, that's a good 10 way to characterize it, and it's actually baked in to 11 both options. It just gets there via different means.
12 But the key thing is that whether it's through 13 pointing to reliance on the types of robust passive 14 features that would be resistant to incorrect human 15 actions rendering them unable to fulfill their safety 16 function, or things that are just inherent, or whether 17 it be requiring -- perhaps through a human reliability 18 analysis type assessment, going through and 19 determining what the credible human errors of omission 20 or commission could be. Installing engineered 21 features to reduce the likelihood of those occurrences 22 down to some acceptable level.
23 Again, those two options, they both 24 accomplish that and via different means. But it's 25 baked in to both of them for lack of a better way 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
158 1 put it. Again, it's a key consideration that if 2 you're assuming that people, they don't have a human 3 safety role, it's not only for the actions that they 4 need to take, it's for the things that they could do 5 that potentially could remove the things that are 6 credited for safe (audio interference).
7 MS. BUCHANAN: Thank you, Jesse. Does 8 that answer the question or address the question?
9 MEMBER BIER: Yes, I'm happy with that 10 answer for now. Thank you.
11 MEMBER BROWN: I'm going to calibrate that 12 in just a slightly different way. This is just from 13 past experience in that the guidance we used to give 14 to our operators, you were the final -- the operators 15 were the final step. They were the final safety step.
16 They were responsible for the safety of the reactor, 17 taking care of it. They were always there. We're 18 effectively abandoning that thought process. I'm not 19 saying it's not justified if it's bought off on, I'm 20 just saying we've walked away from saying that the 21 operator is the final protection against a major 22 accident.
23 MS. BUCHANAN: I would characterize --
24 finish, please.
25 MEMBER BROWN: No, that's -- there's no 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
159 1 way to -- you could characterize it.
2 MS. BUCHANAN: Well, I would like to 3 characterize it slightly differently. You can choose 4 not to agree with this characterization, but the way 5 I would characterize it is we would give the 6 facilities an opportunity to prove to us that they 7 don't need the operators as that last step to safety.
8 But they would have to prove to us that those 9 operators are not only not needed as last step to 10 safety, but they can't do a wrong action that would 11 put them into the line of safety.
12 And that's how I would characterize it.
13 So I wouldn't say that we're abandoning that as a 14 philosophy. I would say that we are modifying it to 15 acknowledge the possibilities of future technologies 16 that they could be designed in such a way as to 17 eliminate the need for it.
18 MEMBER BROWN: The plant is so safe that 19 it can't possibly hurt anybody.
20 MS. BUCHANAN: Well, that's why I said 21 it's a very high bar.
22 MEMBER BROWN: Okay, thank you.
23 MEMBER HALNON: This is Greg. Before 24 Theresa has to go I want a couple of questions. You 25 mentioned that the lesson, the ability to resist 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
160 1 coercion by inappropriate management. I got that 2 part. What would keep management from only certifying 3 operators who let's say toed the line as opposed to 4 operators that may not necessarily -- let's say 5 independent thinkers as opposed to just toeing the 6 line.
7 What would prevent them from only -- being 8 very selective on their certified operators to not 9 have to coerce them?
10 MS. BUCHANAN: Well, I would respond by 11 saying it's primarily the other aspects of the rule 12 language for certified operators. They're required to 13 propose a training program which would include 14 eligibility, experience requirements for entry into 15 the program as well as what the contents of the 16 program would be to output an operator. And they 17 would be required -- we would then approve, review and 18 approve it, the Commission would. They would be 19 required to follow that program, and then we would be 20 coming by in the -- behind them doing periodic 21 inspections to ensure compliance with the program.
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161 1 as well as the training program, a certification 2 program, and periodic inspection by the Commission.
3 So I don't think that that would be a significant 4 concern, that they would only have compliant 5 operators. Would that be a good term to use?
6 MEMBER HALNON: Yes, I understand what 7 you're saying. Okay, then carrying this out further 8 then, first of all I did want to make the statement 9 that we are assuming that these are qualified 10 proficient operators. They're not duds who get 11 through this training program. So I wanted to say 12 that. They're probably equivalent to the proficiency 13 and abilities of a licensed operator. So we're not 14 talking about people who are just going to go do bad 15 things all the time.
16 However, first question, and this is --
17 should be an easy one. Do you anticipate that there 18 would be full-time resident inspectors onsite at these 19 new smaller facilities?
20 MS. BUCHANAN: That's beyond my purview.
21 I wouldn't be able to answer that question.
22 MEMBER HALNON: My sense is no. If you're 23 not going to have any operators there you're probably 24 not going to have a full-time resident inspector. So 25 the second question is can the NRC de-certify an 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
162 1 operator if they see something that they don't like?
2 MS. BUCHANAN: And Jesse, I'm going to ask 3 for your assistance on this one, but the way that I am 4 envisioning this program is that the certification is 5 at the facility level, but it's covered by a 6 commission reviewed and approved program. And if the 7 facility were to fail to follow their program which 8 would include de-certifying operators when necessary 9 then they would of course be subject to enforcement 10 action. And if they continued to fail to de-certify 11 operators when necessary then of course the 12 enforcement would continue to be escalated per that 13 process. Jesse, did you have anything you wanted to 14 add?
15 MR. SEYMOUR: Theresa, you characterized 16 that well. Just very broadly, something that we for 17 the purposes of this presentation can't speak to to 18 any great extent is what the inspection program and 19 what the oversight process will ultimately look like 20 within this framework simply because it's beyond the 21 scope of the piece of it that we're working on. To my 22 understanding it really kind of goes a bit beyond 23 where the status of the work is.
24 So again, if we're asking questions about 25 will they have resident inspectors, and what type of 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
163 1 specific inspection activities will be there. We 2 can't speak to that, but what we can say is that we're 3 laying the groundwork here for what we anticipate the 4 inspection needs and the regulatory hooks to be. And 5 one of those which Theresa I thought put quite well is 6 that the facility will be on the hook for maintaining 7 the approved training program and also complying with 8 the regulations that govern the certified operator 9 process. So part of that would be removing people 10 that aren't performing from performing their duties 11 and remediating them. Again, that's casting a pretty 12 wide -- painting that with a pretty wide brush.
13 There's more specifics to it than that.
14 But if they're not doing that, again, our 15 intention right now and the way that we foresee this 16 is similar to how we do re-qualification program 17 inspections. There would be regulatory touch points 18 where we're looking at those programs. And again, if 19 we found efficiencies there, in a similar manner to 20 how, in the commercial world, we will issue findings 21 under the ROP for the re-qualification training 22 programs. We would have the regulatory hooks needed 23 to issue enforcement. Those actions would address to 24 that facility as licensee. And then from that point 25 again if there was continued non-compliance with 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
164 1 regulations, again we've seen how that works in 2 enforcement space. Things will ratchet up from there.
3 MS. BUCHANAN: Thank you, Jesse. I've 4 only got two sentences left on my spiel so can I 5 finish those and then we can get back to your 6 questions?
7 MEMBER HALNON: Yes, go ahead, Theresa.
8 MS. BUCHANAN: Thank you so much. As 9 Maurin just finished discussing we are continue to 10 evaluate the role of an STA or engineering expertise 11 availability. If the STA role or that engineering 12 expertise availability is included in the rule 13 language this can also add -- provide additional 14 assurance of safety for the plant.
15 Finally, a key requirement, this is kind 16 of like a summary. A key requirement is the 17 certification programs require the review and approval 18 of the Commission, and compliance with the programs 19 will be monitored by the Commission through periodic 20 inspections. So that's the end of my prepared remarks 21 for the certified operators section. So if we could 22 return. I'm sorry, I didn't catch the name, but if we 23 could return to the individual who said he had some 24 questions for me. He was only able to ask one.
25 MEMBER HALNON: This is Greg, Greg Halnon.
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165 1 You've answered most of them. I'm not going to press 2 it beyond. I brought up the inspection piece because 3 you relied on it in an earlier answer. That's one of 4 the reasons I brought that up. But with lack of 5 continuous oversight on the site like we have with our 6 large light water reactors operator proficiencies at 7 the request of and opinion of the management who may 8 not be onsite.
9 And the other piece of this, the basis for 10 the earlier question was the difference between the 11 licensed versus non-licensed operators and the level 12 of personal accountability they feel for that.
13 The last question I have for you is with 14 all the stuff and all the conversation that we've had 15 why are you doing this?
16 MS. BUCHANAN: Okay. So you threw me the 17 softball earlier to throw me a hardball later. I got 18 it. Why we're doing this. Well, we already got some 19 feedback about the use of all those buzzwords, but 20 unfortunately those buzzwords are actually very 21 applicable in this situation.
22 Part 55 as written right now works for 23 large light water reactors, but it's very 24 prescriptive, and it's very technology-specific for 25 large light water reactors. So we obviously have 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
166 1 do something about that because it won't fit with 2 advanced reactor designs. There are aspects of it 3 that just won't.
4 So, okay, that follows into the why are we 5 doing Part 53. Fine, now it's like why are we 6 splitting between licensed operators and these non-7 licensed certified operators. Why not just do 8 licensed operators.
9 We could do that. What we are looking at 10 trying to do was trying to balance a regulatory burden 11 versus a safety impact. So we're trying to reduce 12 regulatory burden. This would be a reduction of 13 regulatory burden because the facility would not need 14 to be going through the Commission for the licensing 15 of operators. They would still have some regulatory 16 burden because we're not just handing this over to 17 them and not ever looking at it again. That was a 18 very good point you had earlier. We need to make sure 19 that we have appropriate touch points to ensure that 20 they're following their programs appropriately.
21 But it would reduce regulatory burden in 22 this aspect, to allow them to focus their efforts 23 elsewhere, their resources and efforts elsewhere. So 24 really that's why we're doing this. We are attempting 25 to balance the burden of a processes against 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
167 1 safety. So if the safety case isn't there the burden 2 shouldn't be there, and that's it.
3 MEMBER HALNON: Okay. Well, thank you for 4 that. I wanted to just before you left give you the 5 sense that I think this is the sense of the committee.
6 I speak for myself and I'll look at the heads nodding 7 or throwing something at me around the table.
8 I think we're concerned with the continued 9 cumulative effect of this backing off of oversight 10 through requirements in the regulatory language.
11 Elimination of the STA. We made that comment and now 12 you're coming back with some appropriate options. Not 13 having a licensed operator. How about potentially not 14 having any operators onsite at all? Having lesser 15 scope simulators as we'll talk about in a minute.
16 Having less re-qualification requirements from the 17 standpoint of prescriptive two-year re-qualification 18 exams, written exams and that sort of thing.
19 So the cumulative effect of all these 20 feels like we're giving away the farm to the less 21 oversight and less NRC I guess hooks is what I'm 22 trying to say. So anyway, that's where the concern 23 is. We'll continue to talk about it. We'll talk more 24 about it probably with the reduced simulator scope 25 although I think we'll get through that pretty 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
168 1 quickly. So that's where we're coming from and that's 2 where you see some of the discussion coming from the 3 members.
4 MS. BUCHANAN: Understood. I thank you 5 for the insights, appreciate that. I'm going to --
6 Jesse, I'm going to go ahead and turn this over to you 7 because I've got to head out of here. So I want to 8 thank everyone for letting me come and present before 9 you all. I really do appreciate having the 10 opportunity to present the staff's perspective on 11 those controversial topic.
12 MEMBER HALNON: Thank you, Theresa.
13 Jesse, you're back up again.
14 MEMBER PETTI: So I had one comment sort 15 of on the opposite side. I keep hearing this is a 16 high bar. So, as I look at the advanced reactors I 17 see very few that will not rely on an operator in some 18 way once they do a full safety analysis, et cetera, et 19 cetera. So I worry that we're going through a 20 tremendous amount of effort for a null set. No one 21 can get through this gate. Now, there may be some 22 design out there, but at least all the ones that I 23 know of that are out there, there has to be an 24 operator involved.
25 It will be very different than the current 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
169 1 fleet in terms of the nature of the interaction like 2 we even see in NuScale. But I worry -- there's also 3 that. There's so much effort here and in the end the 4 bar is -- may be so high that why are we doing it.
5 MEMBER HALNON: That's kind of where my 6 question came in. I agree.
7 VICE CHAIRMAN KIRCHNER: I have the same 8 feeling, Dave. As any -- this is one member's opinion 9 so I have to be careful how I say this. If it's a 10 power reactor of scale, I'm talking 100 megawatts or 11 more, I don't -- like you say, I see the bar very 12 high, and also I see lots of reasons why you would 13 want and need an operator onsite full-time with such 14 a facility.
15 So, if we put aside these micro reactors 16 for a moment, I know the staff is to be commended for 17 trying to span a spectrum that is like a research 18 reactor to something that's, you know, on the other 19 end is an LWR. But I have the same feeling as Dave, 20 that the credible power production reactors, this is 21 going to be a very high bar to demonstrate no one is 22 needed and then we drop all of the requirements down 23 to a certified level. (Audio interference) that 24 person's only doing administrative functions. There's 25 some language that's being used here that I don't 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
170 1 think is appropriate either.
2 MEMBER HALNON: And this is Greg.
3 Remember we're talking about commercial reactors that 4 have the sole purpose besides being safe to earn money 5 for somebody. So.
6 MEMBER BIER: I have one other comment I 7 want to make which is at the kind of 10,000 foot 8 level. So when -- I guess it was Charlie who asked is 9 there a floor. Is the floor zero or non-zero. And 10 essentially Jesse's answer was no, the minimum is one, 11 but we cannot say that because that would be 12 prescriptive. And I'm like if the answer is the 13 minimum is one why can't you say that and what is 14 gained by obscuring that fact. And I realize -- it's 15 not a criticism of Jesse. I realize there may be some 16 administrative pressures being brought to bear, 17 industry pressures or whatever, but that just concerns 18 me if there is a plain English answer that we cannot 19 write down.
20 MS. CUBBAGE: This is Amy Cubbage, NRC 21 staff. I want to reiterate what the staff tried to 22 say earlier. The preliminary proposed rule language 23 does specify a minimum of one.
24 MEMBER BALLINGER: It specifies a minimum 25 of one cognizant person.
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171 1 MS. CUBBAGE: So maybe we need to take a 2 look at that language, but the intent was one.
3 MEMBER BALLINGER: This is Ron Ballinger.
4 To me cognizant doesn't mean onsite. And maybe that's 5 appropriate.
6 MEMBER BROWN: And it doesn't mean a 7 reactor operator either. It could be certified.
8 MEMBER HALNON: And this is Greg. It 9 doesn't conform with what we heard earlier on other 10 parts of Part 53 so you have to get together with --
11 and aligned with the rest of the Part 53 staff.
12 MS. CUBBAGE: Well, I'm communicating 13 information from the Part 53 team. If somebody else 14 would like to chime in. We're kind of talking amongst 15 ourselves here. I'm seeing language that the licensee 16 must provide for a certified operator to continually 17 monitor, et cetera, et cetera, at a minimum, et 18 cetera, et cetera. So I'm not seeing this cognizant 19 language in the rule text. So I think we need to kind 20 of take that back and make sure -- your comment is 21 well taken, and make sure that the language is 22 consistent. But that's what my awareness is of the 23 language.
24 MEMBER BALLINGER: I'm just reading, I 25 guess it's from the chat line from Lauren. It must 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
172 1 also be recognized that even a fully autonomous 2 reactor would still need to be under the cognizance of 3 a certified operator. This is Ron Ballinger.
4 CHAIRMAN REMPE: So Lauren, if you're 5 there please speak up.
6 MEMBER BALLINGER: That's what I recall.
7 Excuse me, I'm sorry.
8 CHAIRMAN REMPE: Yes, if you're there 9 please speak up.
10 MS. CUBBAGE: We need to clarify that 11 because that's not rule text. That was a table. So 12 please go ahead, Lauren.
13 MS. NIST: Yes. So like Amy said a moment 14 ago, the staff here in our caucus had been sharing 15 some information to help address that. And again I 16 had forgotten about the limitation on the use of the 17 chat in this meeting and I had shared that.
18 So, what I shared was from a discussion 19 table that was from October of last year on the 20 rationale for some language that was being put 21 forward. But it looks like in the preliminary, let's 22 see, 53.755(i)(3) the licensee must provide for a 23 certified operator utility to monitor the operation of 24 field units. At a minimum the certified operator must 25 have the following capabilities. Cognizant was not 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
173 1 the rule text.
2 So I think Mr. Brown and Amy had just said 3 that as well, so I don't think there's anything 4 additional there from that chat message that hasn't 5 been stated.
6 MEMBER BROWN: This is Charlie Brown. I 7 didn't say cognizant. I haven't gone to the -- I was 8 just looking at the certified word as opposed to 9 reactor operator, licensed.
10 MS. NIST: Yes, that's right. That's what 11 I -- my apologies. What I meant to say was that you 12 had basically just stated what I said about the 13 minimum operator could be licensed or certified I 14 believe.
15 MEMBER BROWN: Yes, that's all. I just 16 have difficulties with -- I just looked for a floor of 17 what I would call a licensed operator. By the time we 18 went through all the certified stuff. I understand 19 what you're trying to do, and I understand the basis 20 as you reiterated it very well. It's just I guess I 21 really don't agree that you have somebody that's, 22 quote, "certified" that can't take actions under an 23 accident condition. That does not make a whole lot of 24 sense to me. It may be where we end up, it just 25 doesn't make sense to me.
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174 1 MEMBER HALNON: This is Greg. Before this 2 horse is absolutely dead let's go ahead and move on to 3 the other topics, and then we can summarize some 4 discussions at the end. If the team wants to continue 5 on we'll be quiet for a minute. I can only guarantee 6 a minute.
7 MR. SEYMOUR: Okay. So with that being 8 said I'll continue on to the simulator scope 9 discussion and then we can come back to those points.
10 I think there's some clarification I can provide as 11 well if we want to circle back around later.
12 So again, just a discussion of simulator 13 scope. Specifically we'll be talking about that 14 aspect of our training and qualification requirements.
15 So now I'd like to discuss the topic of simulators and 16 how we are preliminarily approaching that area under 17 Part 53. So at present section 53.765(e) would 18 establish simulation facility requirements for those 19 plants that are required to have licensed operator 20 staffing, and separately the 773(e) section would 21 establish separate and somewhat less stringent 22 simulation facility requirements for plants with 23 certified operators.
24 Key aspects of both of those sections even 25 though they are separate include the following.
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175 1 First, full scope simulators are not mandated and 2 partial scope simulators may, key word may be 3 acceptable provided that the simulator scope is 4 adequate to meet the intended usage. Alternatives to 5 the use of simulators may be possible as well.
6 Simulation facilities for plants with 7 licensed operators must be approved by the Commission 8 if a facility licensee will rely upon them for 9 training, experience requirements, or for initial or 10 re-qualification examinations. Similar approval is 11 not required for certified operator facilities though.
12 Also, facilities must demonstrate that 13 adequate simulator scope is provided to support human 14 factors engineering analyses and assessments in order 15 to be able to use the simulation facility for 16 conducting those analyses and assessments. We can 17 move on to the next slide, please.
18 So in developing the preliminary rule 19 language we -- and by that I mean our working group, 20 we reviewed section 306 of the Nuclear Waste Policy 21 Act and the Federal Register notice that's listed here 22 on the side that was associated with the staff's 23 implementation of the Nuclear Waste Policy Act 24 simulator related provisions, and essentially the 25 considerations for when they were first incorporated 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
176 1 into regulation.
2 One key observation that we made was that 3 flexibilities were historically provided to allow for 4 potential use of the plant itself, and/or plant 5 referenced simulator, or some other type of simulation 6 device such as a part-task or basic principles 7 simulator for the conduct of the simulator portion of 8 the operator test.
9 Another key observation was that we found 10 that the NRC's stated intent during this time frame, 11 and again this was written back around the 1987 time 12 frame. The NRC's stated intent was not to permit the 13 initiation of transience on the plant itself if the 14 plant was going to be used as the quote unquote 15 "simulation facility."
16 Rather, the use of the plant was 17 envisioned as an option that might be used in 18 conjunction with another simulation device or devices 19 in lieu of a plant referenced simulator. Our current 20 perspective based on our work thus far is that the 21 Nuclear Waste Policy Act does not mandate that the NRC 22 require that plants have simulators, but instead 23 requires regulations to address the use of simulations 24 in training.
25 The implication of this is 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
177 1 flexibility exists to allow the use of the actual 2 plant to simulate tasks for training and operator test 3 purposes without necessarily having a separate 4 simulation facility. In this case, specifically a 5 simulator.
6 Prior concerns raised by the ACRS 7 subcommittee have included the potential for 8 reductions in training and evaluative efficacy, 9 impacts on procedure quality, reduced support of 10 analyses, and staff experience in approval of partial-11 scope simulators. If we can move on to the next 12 slide, please.
13 The philosophical basis behind the 14 preliminary rule language addressing simulators is 15 that overall we feel that plant referenced full-scope 16 simulators will remain the preferred approach and 17 would represent the best route for meeting Part 53 18 requirements. So again, I'll say that we discuss 19 these flexibilities but we still see that the most 20 straightforward and preferred path to navigate that is 21 with a full-scope plant referenced simulator.
22 Even with the flexibilities afforded we 23 expect that the majority of Part 53 applicants will 24 choose to go that route due to the regulatory 25 certainty consideration associated with it, 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
178 1 advances in technology lowering the associated cost.
2 I think it's important to keep in mind 3 that what we are conventionally used to are these 4 large simulation facilities that have analog controls.
5 There's a lot of hardware involved, a lot of switches, 6 gauges, things like that. And there's a substantial 7 amount of installation and maintenance and upkeep 8 costs associated with that.
9 As we look at modern designs we see the 10 use of a lot of soft controls. So in this case we 11 anticipate that with that progression we're going to 12 see the cost associated with building a plant 13 referenced full-scope simulator and maintaining it 14 over the life of the facility come down. So again, 15 these are the different things that shape our thinking 16 here.
17 So as a point of consideration and a point 18 of comparison I'd like to point out that the existing 19 regulations, and by this I point to what we currently 20 have in Parts 50 and 55. The existing regulations do 21 not strictly mandate plant referenced full-scope 22 simulators either because of how the Commission 23 approved alternative structure. So again, if we truly 24 look at how the Commission approved alternative 25 structure, and we look at the genesis of that, 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
179 1 there was the intent to -- I'll give an example. The 2 research in test reactors, there was not a desire to 3 change the status quo for them. So they were 4 essentially grandfathered and allowed to continue with 5 not having simulators.
6 But again, if we look at how the 7 Commission approved alternative structure we can see 8 that although there is another track that's built into 9 this simulator process right now, full-scope plant 10 referenced simulators were still adopted by all 11 current power reactors. So again, just because the 12 flexibility is there doesn't mean that it's 13 necessarily going to be the most effective path.
14 So Part 53 language leaves alternatives to 15 simulator usage, whether they be full-scope or 16 otherwise. But, and this is very important here. The 17 burden will still be on the applicant to demonstrate 18 how a number of areas are supported by whatever 19 approach they're proposing. And these areas would 20 include showing the following.
21 So, they would have to show how licensed 22 or certified operator training and examinations would 23 be supported. The simulators used in this context 24 would require sufficient scope and fidelity for 25 operators to acquire and demonstrate the knowledge 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
180 1 abilities needed for the job duties. They would also 2 have to be able to demonstrate how experience 3 requirements, and by that I mean specifically those 4 associated with reactivity manipulations would be 5 conducted. And also how human factors engineering 6 analyses, assessments, and human-system interface 7 design test bed needs would be met. So again, if an 8 applicant were to opt to pursue one of these 9 flexibilities, perhaps propose even to use the plant 10 itself as a simulation facility in conjunction with 11 maybe a part-scope simulator or something to that 12 effect, this is the hurdle they would have to get 13 over.
14 So again, it's not just a matter of I'm 15 not going to build a simulator. You have to make the 16 case for how you're able to do these things. And our 17 belief is that there may be a very small subset of 18 applicants for whom they do see a success path where 19 they see that they can show this using an alternative 20 to full-scope plant referenced simulator, that they 21 can provide the required evidence to justify that, and 22 that that will be a benefit to them as they go through 23 the process.
24 But our sense looking at this is that the 25 majority of facilities would look at this and 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
181 1 they would still see the plant referenced full-scope 2 simulator as being most advantageous to them over the 3 long run.
4 So, the next slide would take us over to 5 a discussion of guidance and our different guidance 6 projects. So I'll pause there to see if there's any 7 questions before we move on to that.
8 MEMBER HALNON: Okay, this is Greg.
9 Anyone have questions on the simulator scope issue?
10 I don't see any. Go ahead, Jesse, move on.
11 MR. SEYMOUR: Okay. So, this is the final 12 part of this presentation. What I'd like to do now 13 for the committee is I'd like to provide a summary of 14 the areas of regulatory guidance that our team is 15 currently working on. And I'll go through these. As 16 you can see there's a number of areas. We're working 17 on many fronts here.
18 So first, we are developing guidance to 19 facilitate human factors engineering reviews being 20 accomplished in a manner that is scalable. We have a 21 working group that is developing this guidance with 22 contract support from Brookhaven National Laboratory.
23 Our current goal is to complete our draft of this 24 guidance by the June time frame. So that would be 25 this June.
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182 1 Second, we are developing guidance for the 2 review of the staffing plans that would be associated 3 with the flexible operation staffing requirements that 4 were preliminarily proposed in Part 53. So earlier 5 when the committee was asking about this guidance and 6 where it will exist, and when it will be ready, and so 7 forth that's specifically what I'm talking about here.
8 So this guidance augments the existing 9 NUREG-1791. And again, just for clarity NUREG-1791 is 10 the human factors engineering based exemption review 11 process that we use when applicants want to do 12 something other than the staffing that's prescribed by 13 50.54(m). So again, if you want to propose a 14 different staffing model than what is mandated by that 15 regulation this is the human factors engineering based 16 process that you use to justify that. So again, a 17 different application of that. And this is guidance 18 that supplements NUREG-1791 and repurposes its 19 processes again just to a different end, in a very 20 high level accomplishing the same thing, looking at 21 what needs to be done and how many people and what 22 roles do you need to do it, going through a very 23 rigorous human factors engineering based structured 24 methodology.
25 But again in this case we're augmenting 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
183 1 existing guidance for that purpose, and adapting it 2 for use within the specific context of Part 53. Now, 3 that's a project that we're doing in-house, so we're 4 not relying on contractor support for that. We're 5 using our own experts used to work through that.
6 And again, we are targeting June of this 7 year. And again that's our current goal for having a 8 draft of that guidance prepared.
9 Third, we are currently working with Idaho 10 National Lab on the development of operator licensing 11 examination guidance that can support the tailorable 12 approach to operator licensing and certification 13 examinations that this rule would permit.
14 And as before, in conjunction with Idaho 15 National Lab we've got a pretty aggressive schedule 16 for developing that. But we're currently aiming to 17 have a draft completed by the June time frame for that 18 guidance as well.
19 And also, something I wanted to point out 20 as well too. On one of the first slides we showed the 21 working group that we have very broadly. Again, just 22 kind of the key individuals. There's more people even 23 than that working on this stuff. But I want to say 24 that we have quite a bit of interaction with the 25 Office of Research on those projects.
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184 1 So again, as I talk about the human 2 factors engineering guidance, the staffing guidance, 3 and the operator licensing guidance we have members of 4 the Office of Research that are participating, on some 5 cases even leading some of those efforts as we work 6 through that. So again, a lot of close coordination, 7 not only with contract national lab support, but also 8 with our own Office of Research.
9 Separately we're also working on 10 developing guidance for the review of a systems 11 approach to training based training programs. And 12 that guidance would support the review of non-13 accredited training programs and in general would 14 serve as an update to the existing set of review 15 guidance of NUREG-1220 and Inspection Procedure 41500.
16 And during previous meetings of the subcommittee it 17 was pointed out very accurately that those two 18 references are dated. So we recognize that and what 19 we're doing is working on updating and refreshing, and 20 taking a good look at that guidance and reassessing 21 what does it need to look like decades after it was 22 originally developed. So again we're doing a pretty 23 comprehensive overhaul of guidance for reviewing these 24 staff-based training programs.
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185 1 approximately one year. And that is so as to be able 2 to support any near term applicants as they may be 3 needed. So in case we get an applicant that comes in 4 under Parts 50 or 52 that chooses to forego that 5 accreditation, so as to be ready for that. But then 6 on a longer time frame also have it ready for use 7 within the context of Part 53.
8 So our current working group includes both 9 headquarters and regional operator licensing staff, 10 and also includes individuals with commercial 11 instructor and operating experience. So again, 12 commercial instructor experience very important here 13 because they're kind of the end user of that process 14 out in the field.
15 Lastly, it's important to note that ARCAP 16 ISG Chapter 11 which covers organizational and human-17 system considerations is planned to be supplemented 18 with guidance for Part 53 at an appropriate point in 19 the future. So at present myself and many of the 20 other members of the group that we talked about, 21 Theresa Buchanan, Maurin, and so forth have worked to 22 one degree or another on the current version of ARCAP 23 Chapter 11 which is intended to address Part 50 and 52 24 applicants, fast reactor applicants, and to navigate 25 some of the considerations associated with licensing 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
186 1 within that framework.
2 However, at a future date once Part 53 is 3 sufficiently developed our intent is to augment that 4 guidance. Now again, that document is broad in its 5 scope, and we anticipate including within it the new 6 guidance for other review areas beyond those key areas 7 that I've already outlined here. And I'll just give 8 some examples, but we foresee that eventually we would 9 be expanding that guidance out to cover areas such as 10 load following, the post-Three Mile Island human-11 system interface design requirements, and also 12 potentially aspects of simulation facilities should we 13 find that there's gaps with the existing guidance in 14 those areas.
15 But again, the key thing is that that is 16 an interim guidance document and over a very long time 17 frame we anticipate that that guidance will eventually 18 be translated into other review plans and documents as 19 their permanent home.
20 So with that being said if we could just 21 go ahead and move on to the final slide. This 22 completes the prepared part of our presentation, and 23 I'd just like to go ahead and open things up for 24 questions and general discussion at this point.
25 MEMBER HALNON: Thank you, Jesse. Any 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
187 1 other lingering questions from the committee?
2 Chairman Rempe.
3 CHAIRMAN REMPE: I'm sorry, I was just 4 going to remind you to get public comments.
5 MEMBER HALNON: Thanks, appreciate it. I 6 was going to forget. Okay, at this point then we'll 7 open up the -- I have a question. Oh Amy, did you 8 have something you wanted to say?
9 MS. CUBBAGE: Yes, I just wanted to follow 10 up on one point that was made earlier. I don't want 11 to leave anything incorrect on the record.
12 There was a statement about not wanting to 13 have a certified operator there that's not allowed to 14 take any actions. And I wanted to just state what the 15 current preliminary proposed rule language says with 16 regards to certified operators, that they must have 17 the following capabilities. Number one, the ability 18 to receive plant operating data including reactor 19 parameters and information needed for the evaluation 20 of emergent conditions, and importantly here, number 21 two, the ability to immediately initiate a reactor 22 shutdown from his or her location. So I wanted to 23 reassure that these certified operators are not -- are 24 going to be required to have the ability to take 25 action to shut the reactor down. Thank you.
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188 1 MEMBER HALNON: Thank you, Amy.
2 MR. SEYMOUR: If I could just clarify that 3 point. Amy, thanks for pointing that out. It's a 4 very good point. That's an area where we almost 5 became deterministic in our thinking. And I'll 6 clarify that.
7 You could go through analyses that show 8 that the facility through inherent characteristics and 9 so forth will find its way into a safe, stable state, 10 you know, subcritical or whatnot. But even though, 11 even though the analyses show that we still wanted 12 that extra layer of assurance. So we said one of the 13 requirements for the certified operator is that they 14 have that ability to have vital plant information 15 coming to them wherever they are located, and have 16 that ability to initiate that reactor shutdown. So 17 again, it's an area where we said for our own 18 assurance we still want that extra measure there as 19 well.
20 MEMBER PETTI: So Jesse, I'm a little 21 confused then because earlier one of the criteria for 22 a certified operator was not being involved in any 23 safety -- can't remember the exact words, but any 24 actions that would influence safety. Being able to 25 shut down the reactor, that sounds like a safety --
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189 1 MS. CUBBAGE: This is Amy Cubbage. Let me 2 explain it in my words, and that's that if you do the 3 analysis of the reactor and you have no operator 4 actions that are credited for safety functions that's 5 different than saying that the operator can't take an 6 action if something didn't go as planned.
7 MEMBER PETTI: Okay.
8 MS. CUBBAGE: Did I get that right, Jesse?
9 MR. SEYMOUR: Yes, Amy. Again, it's kind 10 of like how we think about having many layers to 11 defense-in-depth. There's a difference between the 12 operator being credited to do something and then 13 having almost a beyond design basis capability that's 14 built in there just for extra assurance. And that's 15 really what we're talking about here. It's a prudent 16 measure to have this. We think that's justified to 17 maintain that capability.
18 MEMBER PETTI: Thanks, that helps.
19 MEMBER BROWN: The words that were used 20 earlier, earlier said that the certified operator 21 would not be capable of taking actions in an accident 22 situation. Didn't say they couldn't shut down the 23 reactor. I understood that they can shut down the 24 reactor. My response, the reason I made the comment 25 was there's many times when shutting the reactor down 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
190 1 is not the only thing that has to be made sure 2 happens. So that was the reason for my earlier 3 comment. And they've made the statement in earlier 4 meetings that they could -- the certified operator 5 could scram the plant, but whatever that means in the 6 new plants. But what about auxiliary things that a 7 real reactor, an actual licensed operator could take.
8 Start this, do that, make sure such and such is 9 happening, and make it a safe shutdown as opposed to 10 just putting the rods on the bottom, or whatever the 11 reactivity mode is.
12 MEMBER BIER: So, I would like to raise 13 one other question which kind of comes back to a point 14 earlier. This is Vicki Bier. And you said that -- I 15 forget who, that the requirements for what level of 16 staffing are needed would be performance-based. And 17 I think within the NRC in general there's kind of a 18 vagueness about performance-based that doesn't exist 19 in some other fields because if you have performance-20 based pollution control you just go to the smokestack 21 and measure. You don't need an analysis to tell you 22 what the performance is.
23 But at NRC some performance is measured 24 like how long the maintenance backlog is at a plant, 25 and other performance is by analysis like how your 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
191 1 fire protection does you don't start a fire to test 2 it. So coming back to my question about what if 3 somebody had previously established a certain level of 4 staffing and came back in and said by performance we 5 can justify more reactors for the same staff because 6 we've never needed our staff to do anything in the 7 last five years. Would that count as performance-8 based or do they actually need to have an elaborate 9 human factors analysis to justify that they don't need 10 more operators or whatever?
11 MR. SEYMOUR: So in this case, the way 12 that I understand I think the setting for that 13 question is that this would be a facility that was 14 licensed and then at some future point perhaps they're 15 going to add additional modules or something like that 16 that they would then look to modify that staffing.
17 So a key aspect of this is that the 18 staffing plan that is submitted would be reviewed, and 19 if we find it to be acceptable and approve it it would 20 become part of the licensing basis for that plant. So 21 even though that number was developed and reviewed and 22 approved, and it didn't come out of a table in 23 50.54(m), what we would be doing is in the final stage 24 of licensing that would become -- it would be 25 combined.
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192 1 So if they wanted to modify that what they 2 would have to do is go through the license amendment 3 process, and as we envision it it would be very 4 similar to what they had to do prior to that. Again, 5 you would have to go through the human factors 6 engineering based analyses and assessments, do the 7 validation work and actually show the proof for why 8 the proposed revision to the staffing plan was going 9 to be acceptable. And you wouldn't be allowed to do 10 that until that licensing action had been approved by 11 the NRC.
12 MEMBER HALNON: Jesse, how would you 13 handle first of a kind technology then?
14 MR. SEYMOUR: So, with a first of a kind 15 technology the key thing is that as you go through the 16 staffing process what we're doing is we're borrowing 17 from the framework of NUREG-1791. And what that's 18 going to look for, again we'll see where -- there's 19 challenges associated with this. This isn't easy.
20 The NUREG-1791 process, it's structured. You begin 21 with things like an operating experience review. So 22 you look for existing operator experience which may be 23 limited in this case. So again, that's an area of 24 challenge.
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193 1 is that -- and again, I'll skip over -- I'm sorry?
2 Okay, sorry, I thought someone was speaking. So what 3 you'll see as you move through that is you'll see that 4 there's an identification of what the safety functions 5 are for that design. Again, achieved through analysis 6 and safety functions, that's dealt with more broadly 7 under the Part 53 framework.
8 There's an allocation where you determine 9 who or what is going to be doing that, what level of 10 feature and so forth. And then from there you develop 11 a task analysis to figure out, okay, what are the 12 tasks the operators need to be able to do.
13 Now, at that point you go through from 14 there. And there's other stages, but ultimately what 15 all that leads to is now that you've mapped out what 16 needs to be done ultimately you're working towards the 17 validation of that, and you're looking at really the 18 proof that as you've identified those things that need 19 to be done for that design, that the proposed number 20 of people is going to be sufficient to accommodate 21 that.
22 And typically that's going to take the 23 form of a validation that's done in a simulator with 24 scenarios, again, performance-based testing. Using 25 this can you show that it all works. And again, 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
194 1 recreating things like workload under challenging 2 conditions, making sure that under these emergency 3 situations that the safety functions. And again, key 4 wording that we use, that the safety functions needed 5 for that plant can be fulfilled by the proposed number 6 of people.
7 So again, what I don't want to do is gloss 8 over the fact that first of a kind doesn't present a 9 challenge. It does. What you're doing is you're 10 approaching that with really the state of the art for 11 how do you answer that question.
12 MEMBER HALNON: Okay. Dr. Desaulniers, 13 you wanted to weigh in?
14 DR. DESAULNIERS: Well, I think Jesse went 15 on to provide a little bit more clarity that I wanted 16 to add in response to Member Bier's question with 17 regard to what it meant to be performance-based. And 18 Jesse was going into that there, that we wouldn't just 19 be looking at past operating experience as a 20 justification to infer what might be possible for 21 performance in the future, but as Jesse was just 22 noting typically this would be done in -- performance-23 based testing in a simulator where operations for the 24 additional number of units if that was the question to 25 be addressed here in the revised staffing assessment, 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
195 1 it would need to be shown through performance-based 2 scenarios. So just wanted to be clear as I fully 3 recognize there is differences in how that term is 4 being used.
5 MEMBER BIER: Okay, thank you.
6 MEMBER HALNON: Yes, thanks. Any other 7 questions from the committee? Okay, I'll open it up 8 for the public comment. If you would please unmute, 9 state your name and if appropriate, affiliation.
10 Again, it's open for public comment. If you would 11 unmute your mike that I think you do by *6, and state 12 your name and if appropriate your affiliation.
13 Okay, hearing no public comments I wanted 14 to thank the staff. Jesse, you and your team, Lauren, 15 Maurin, all you guys. You did a great job of getting 16 through this. We appreciate it. The slides were 17 right on point. And we appreciate you addressing the 18 comments of the subcommittee. We appreciate that very 19 much. Chairman Rempe, how would you like to proceed 20 from here?
21 CHAIRMAN REMPE: First, I'd like to note 22 that we're going to go off the record, so the court 23 reporter may cease recording things.
24 (Whereupon, the above-entitled matter went 25 off the record at 5:36 p.m.)
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Staff Presentation to the ACRS Full-Committee NuScale Topical Report Building Design and Analysis Methodology for Safety-Related Structures (TR-0920-71621, Revision 1)
February 2, 2022
Topical Report Review Chronology
- NuScale submitted topical report TR-0920-71621, Revision 0, Building Design and Analysis Methodology for Safety-Related Structures, on December 18, 2020.
- NuScale provided responses to RAIs 9833 and 9834 on June 05, 2021, and RAI 9860 on September 05, 2021. The Staff found the responses acceptable.
- NuScale issued topical report Revision 1 of on October 06, 2021, that incorporated the RAI responses.
- NRC issued the advanced Safety Evaluation Report on November 30, 2021.
2
NRC Staff Reviewers:
- Ata Istar, Structural Engineer, NRR/DEX/ESEB
- Amitava Ghosh, Ph.D., Geotechnical Engineer, NRR/DEX/ESEB
- Robert Pettis, P.E. (Retired) Sr. Reactor Engineer, NRR/DEX/ESEB Project Managers:
- Demetrius Murray, TR Project Manager, NRR/DNRL/NRLB
- Getachew Tesfaye, Sr. Project Manager, NRR/DNRL/NRLB 3
Conclusions of Staffs TR Findings
- The methodologies presented in the NuScale TR are acceptable to perform building design and analysis for seismic Category I and II nuclear safety-related RC and SC structures other than containment.
- The methodologies follow implementation of the requirements of ACI 349-13 and AISC N690-18, Appendix N9, endorsed by RG 1.243.
- The methodologies are also consistent with the applicable regulatory requirements of acceptance criteria in NRC NuScale DSRS Sections 3.7.2 and 3.8.4.
4
Members Questions from ACRS Subcommittee Meeting
- Effects of corrosion on SC walls below-grade.
- Welding attachments to SC walls after concrete is placed.
- Industry experience on SC wall construction.
5
Effects of Corrosion on SC walls below-grade
- The staff requested information related to the corrosion effects on SC walls as required in provision B3.13 of ANSI/AISC 360-16.
- Section B3.13 of AISC 360-16 has a general requirement that states:
Structural components shall be designed to tolerate corrosion or shall be protected against corrosion.
- SMR designs may also consider the possibility of plant license extension of up to 80 years.
- In-service inspections and repairs of below-grade exterior SC wall faceplate would be impractical for the duration of the extended licensing period.
- NuScale Response: The following graded approach is described in the TR, Revision 1:
application of tar epoxy coating on exterior below grade faceplates.
using controlled low strength material or employing shotcrete cementitious material on exterior below grade faceplates.
Using backfill material with controlled pH and chloride limits.
- NuScales response is consistent with Section B3.13 of AISC 360-16.
6
Welding attachments to SC walls after concrete is placed
- The staff requested information related to the attachments to SC walls and the effects of elevated temperature in concrete due to welding.
- NuScale Response: The attachments to SC walls are planned to be installed in the shop during fabrication or in the field prior to concrete placement. Design will employ a defense-in-depth control, based on industry wide engineering practices and more recent design experience related to installation of SC walls.
When attachments are needed after concrete is placed, the effects of elevated temperature from welding are minimized by these generic industry guidelines:
- The minimum faceplate thickness is limited to half an inch.
- The minimum concrete age is 21 days. This requirement assures the concrete has enough strength.
- Heat input to the concrete is controlled by setting the maximum base metal temperature to 25°F above the minimum preheat temperature, or a calculation is performed to provide specific allowances.
- NuScales response is consistent with RG 1.243. 7
Industry experience on SC wall construction
- Similar SC wall application was reviewed and approved for AP1000 Shield Building.
- Integrated design process, which SC walls, were implemented on the AP1000 Shield Building design.
- For SC walls and connections, specification ANSI/AISC N690-18 was recently endorsed by RG 1.243.
8
Thank You for Your Attention Any Questions?
9
LO-112954 January 28, 2022 Docket No. 99902078 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
SUBJECT:
NuScale Power, LLC Submittal of Presentation Materials Entitled ACRS Full Committee Meeting: NuScale Building Design and Analysis Methodology for Safety-Related Structures, PM-112948, Revision 0 The purpose of this submittal is to provide presentation materials to the NRC for use during the upcoming Advisory Committee on Reactor Safeguards (ACRS) meeting on February 2, 2022. The materials support NuScales presentation of the topical report NuScale Building Design and Analysis Methodology for Safety-Related Structures, TR-0920-71621, Revision 1.
The enclosure is the nonproprietary version of the presentation entitled ACRS Full Committee Meeting: NuScale Building Design and Analysis Methodology for Safety-Related Structures, PM-112948, Revision 0.
This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.
If you have any questions, please contact Liz English at 541-452-7333 or at EEnglish@nuscalepower.com.
Sincerely, Mark W. Shaver Manager, Licensing NuScale Power, LLC Distribution: Michael Dudek, NRC Getachew Tesfaye, NRC Bruce Bavol, NRC
Enclosure:
ACRS Full Committee Meeting: NuScale Building Design and Analysis Methodology for Safety-Related Structures, PM-112948, Revision 0 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
LO-112954
Enclosure:
ACRS Full Committee Meeting: NuScale Building Design and Analysis Methodology for Safety-Related Structures, PM-112948, Revision 0 NuScale Power, LLC 1100 NE Circle Blvd., Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com
NuScale Nonproprietary ACRS Full Committee Meeting NuScale Building Design and Analysis Methodology for Safety-Related Structures February 2, 2022 1
PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Presenters Fehmida Mesania, Ph.D., P.E.
Engineer, Licensing Rim Nayal, Ph.D., P.E.
Engineer, Civil Structural Giulio Leon Flores, P.E., S.E.
Engineer, Civil Structural 2
PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Agenda
- Purpose
- Introduction
- Technical Discussion
- Steel-plate composite (SC) Walls
- Reinforced concrete (RC) members
- Effective stiffness modeling approach
- In-structure response spectra (ISRS) and structural design process 3
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Purpose
- Present technical content of topical report TR-0920-71621
- Provide the ACRS committee a general understanding of building design and analysis methodology for seismic Category I and II nuclear safety-related reinforced concrete (RC) and steel-plate composite (SC) structures applicable to NuScale design 4
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Introduction - Topical Report
- Topical report presents a design methodology implementing new industry standards for nuclear facilities
- Applicable to new generation Small Modular Reactor (SMR) designs
- Complies with reinforced concrete and SC walls requirements (i.e.
ANSI N690-18, ANSI/AISC 360-16, ACI 349-13, RG 1.243, RG 1.142, DSRS 3.7.2 and 3.8.4)
- Defines design methodologies to account for the interaction of SC walls with traditionally constructed RC members such as basemats, slabs, and roofs
- Implements the soil library methodology for complex structures as per NuScale topical report, Improvements in Frequency Domain Soil-Structure-Fluid Interaction Analysis, TR-0118-58005-P-A, Revision 2
- Topical report information will be used as part of Standard Design Approval Application (SDAA) submittal 5
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Building Design - SC Walls Rim Nayal, Ph.D., P.E.
Engineer, Civil Structural 6
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Steel-Composite Walls
- Steel-Plate Composite Walls
- Steel faceplates with concrete core
- Anchors to ensure composite behavior
- Ties to ensure integrity 7
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SC Walls - Insight
- Advantages Higher capacity and resistance to blast and earthquake Modular construction
- Fabrication and erection: time saving
- Transportable: smaller and lighter modules
- Design optimization: common module layouts repeated throughout the building
- Areas requiring special attention Connection with other structural members Corrosion of faceplates for below-grade walls 8
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SC Walls - Material
- Material
- Stainless steel (SS) faceplates for ultimate heat sink (UHS) pool (borated water)
- Utilize welding parameters and techniques based on industry experience appropriate for the welded metals
- Concrete chemistry is controlled to avoid corrosion in DMWs
- Leak chases at the module splices prevent borated water leakage inside the wall 9
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SC Walls - Design
- SC Design methodology
- Specification for Safety-Related Steel Structures for Nuclear Facilities, ANSI/AISC N690-18 & Specification for Structural Steel Buildings, ANSI/AISC 360-16
- Load and resistance factor design (LRFD), load combinations based on AISC N690
- Code limits on dimensional and material properties are applied
- Required strength: averaging finite element responses
- Available strength: for each type of loading and interaction
- Demand-Capacity ratio for governing failure modes
- SC modules design parameters
- Panel faceplate thickness
- Anchor diameter/ tie dimensions and spacing 10 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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SC Walls - Corrosion
- LTR discusses multiple corrosion mitigation of below-grade walls based on the soil environment:
- Minimum: Coating for below-grade protection of carbon steel
- High chloride or hydrogen sulfide: Controlled Low Strength Material (CLSM) or shotcrete employed as a cementitious material
- Controlled pH and chloride limits backfill placed and thoroughly compacted based on site-specific conditions
- Specific corrosion management plans are outside the scope of this LTR, subject of future applications 11 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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SC Walls - Connections
- Connection Design
- AISC N690-18: Connections are designed to be stronger than the weaker of the connected parts to ensure ductility
- Required strength: Full strength connection design, limited use of over-strength connection design
- Available strength: Per ANSI/AISC N690-18, ANSI/AISC 360-16 and ACI 349-13 as required
- Detailing: Connectors to transfer loads (e.g., studs, anchoring rebar, couplers, shear lugs, continuity plates)
- Detailing of connections is outside the scope of this LTR, will be presented in future applications
- Examples of connection configuration can be found in AISC DG-32 12 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Building Design - RC Members Rim Nayal, Ph.D., P.E.
Engineer, Civil Structural 13 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Reinforced Concrete - Design
- RC members: basemat, intermediate floors, and roof slab
- RC design methodology
- American Concrete Institute, ACI 349-13 Code Requirements for Nuclear Safety-Related Concrete Structures and ACI 318-08 Building Code Requirements for Structural Concrete
- Load and resistance factor design (LRFD) and load combinations based on ACI 349
- Code dimensional limits: spacing, thickness
- Required strength: section cuts
- Available strength: for each type of loading and interaction
- Demand-Capacity ratio for governing failure modes 14 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Reinforced Concrete - Design cont.
Design Conditions:
- Interaction of axial force - out-of-plane (OOP) moment
- Interaction of axial force - in-plane (IP) moment
- Interaction of axial force - out-of-plane shear
- In-plane shear IP IP OOP OOP Axial Moment1 Shear1 Moment Shear Load2 Slabs Basemat 1 Satisfies special seismic requirements of ACI 349 Chapter 21 2 Axial load is used together with the IP and OOP actions 15 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Reinforced Concrete - Demand
- Demand calculation:
- Out-of-plane moments - In-plane shear and axial loads - In-plane moment
- Out-of-plane shear y
x z
In-plane deformation of floor diaphragm Vertical deformation of a floor slab y
x 16 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Reinforced Concrete - Capacity
- Member capacities obtained from Envelope of Demand ACI 349
- In-plane shear capacity according Axial Force to Chapter 21 of ACI 349
- Interaction diagrams checks Moment
- Demand-capacity ratio is calculated to assess safety margin in the design Axial Force Moment P-M Design Evaluation 17 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Reinforced Concrete - Reinforcement Total Slab Reinforcement Plane Section Demand YZ Z
IP shear Y Plane X XZ OOP shear XZ plane and axial load ment Y reinforcement OOP moment use max and axial load
+
IP shear each way Plane YZ YZ plane OOP shear + Z and axial load Y Plane OOP moment X XZ and axial load X reinforcement 18 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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ISRS & Design Methodology Giulio Flores, P.E, S.E.
Engineer, Civil Structural 19 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Seismic Design Philosophy
- Buildings are designed for a specific target performance level of deformation and damage, defined according to the Limit State (LS) categories
- ASCE 43-19 provides criteria to achieve a specific target performance
- NuScale Seismic Design Basis meets LS-D criteria for Structures, Systems and Components (SSCs)
Limit Expected Deformation Expected Damage State A Large permanent distortion, short of collapse Significant B Moderate permanent distortion Generally repairable C Limited permanent distortion Minimal D Essentially elastic behavior Negligible 20 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Seismic Design Philosophy
- In RC design, concrete takes compression loads while it is considered cracked under tension loads
- Reinforcing steel is designed to take all tension loads
- Concrete cracking is expected under SSE. However, structural design according to LS-D criteria is expected to result in essentially elastic behavior with negligible damage. In design codes, this is achieved through:
- Use of lower material and member strengths
- Use of load factors to increase the magnitude of design loads
- Thus, concrete cracking under SSE, if any, should not impair the members safety function 21 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Effective Stiffness Concept
- Due to cracking under SSE loading, the stiffness of cracked RC/SC members is reduced compared to their gross stiffness. Conversely, structural damping increases
- Effective stiffness and damping ratios are taken from codes and standards Force Force Disp Force (uncracked)
Cracked (effective) Displacement uncracked 22 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Effective Stiffness & Damping
- Damping values and effective stiffness used in linear elastic analysis depend on the level of cracking expected during the SSE
- In accordance with ASCE 4, a response level (RL) is determined on a member-by-member basis, based on the member stress, S:
- If S < Scr, RL-1 (uncracked) is used
- If Scr S, RL-2 (cracked) is used
- For ISRS calculation, stiffness and damping are consistent with the expected RL
- For member design, stiffness is consistent with the expected RL and RL-2 damping values are used for all members as per ASCE 4 23 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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ISRS & Design Methodology
- Seismic and Static models are developed
- First step is determination of effective stiffness and damping for load combinations involving seismic loads,
- Seismic models are set to uncracked damping and uncracked stiffness for all members, i.e. RL-1 is assumed for all members
- Seismic shear and bending stresses are evaluated in all members considering the most critical seismic load combination
- Stiffness and damping of members that are cracked are updated to the ones corresponding to RL-2 24 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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ISRS Methodology ISRS Seismic models with updated stiffness and damping
- For five CSDRS ground motions and then averaged
- For one CSDRS-HF ground motion
- +/-15% peak broadening
- Envelope for all nodes on floor region Repeat for selected soil profiles and envelope 25 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Member Design Methodology Member Design Seismic models with updated stiffness and RL-2 damping
- Seismic Forces for five CSDRS ground motions
- Seismic Forces for one CSDRS-HF ground motion
- For seismic load combinations, non-seismic forces from Static Model with stiffness matching Seismic Model
- For non-seismic load combinations, forces from Static Model with uncracked stiffness
- Obtain demand-to-capacity ratios (DCR)
- DCR for CSDRS ground motions are averaged
- Envelope DCR for all load combinations
- DCR 1.0 Repeat for selected soil profiles and envelope 26 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Effective Stiffness Modeling Approach Giulio Flores, P.E, S.E.
Engineer, Civil Structural 27 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Modeling Approach
- Finite element (FE) models are developed using ANSYS orthotropic material model
- Modeling of SC and RC walls and slabs can be performed using ANSYS SHELL181 or SOLSH190
- For SHELL181, effective stiffness is implemented by adjusting material properties and member SHELL181 thickness to match code-specified values (AISC DG-32 approach)
- Two methods are used for implementing effective stiffness values for SOLSH190. Both methods apply to RC members and SC walls and are consistent with AISC DG-32 approach SOLSH190 28 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Modeling Approach Method 1 Method 2
- 3-layered SOLSH190
- 3-layered SOLSH190
- Middle layer properties match
- Middle layer thickness code stiffness matches concrete
- Outside layers are dummy
- Outside layer matches faceplate thickness
- More suitable to RC members
- More suitable to SC walls RC Wall SOLSH190 SC Wall SOLSH190 Outside Steel Outside Layers Faceplates ts Layers E ~ 0, Es,Gs Ems, Gms G~0 Concrete t Middle Concrete ts tc Middle Ec,Gc Layer Ec,Gc Layer c
Em, Gm Emc, Gmc ts Nodes Nodes 29 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Summary
- Building design modifications
- Use of SC wall panels
- Building design and analysis methodology
- Topical report presents a design methodology implementing new industry standards for nuclear facilities
- Applicable to new generation small modular reactor designs
- Implements the soil library methodology for complex structures as presented in the NuScale topical report, Improvements in Frequency Domain Soil-Structure-Fluid Interaction Analysis, TR-0118-58005-P-A, Revision 2
- Topical report information will be used as part of SDAA submittal 30 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Acronyms ACI American Concrete Institute IP In-Plane ACRS Advanced Committee on Reactor ISRS In-structure Response Spectra Safeguards LS Limit State AISC American Institute of Steel Construction LRFD Load and Resistance Factor Design ANSI American National Standards Institute LTR Licensing Topical Report ASCE American Society of Civil Engineers OOP Out-of-Plane CLSM Controlled Low Strength Material RC Reinforced Concrete CS Carbon Steel RL Response Level CSDRS Certified Seismic Design Response SC Steel-plate Composite Spectra SDAA Standard Design Approval Application CSDRS-HF Certified Seismic Design Response Spectra - high frequency SMR Small Modular Reactor DCR Demand-to-Capacity Ratio SS Stainless Steel DG Design Guide SSC Structures, Systems and Components DSRS Design Specific Review Standard SSE Safe Shutdown Earthquake DMW Dissimilar-Metal Welds UHS Ultimate Heat Sink FE Finite Element 31 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Portland Office Richland Office 6650 SW Redwood Lane, 1933 Jadwin Ave., Suite 130 Suite 210 Richland, WA 99354 Portland, OR 97224 541.360.0500 971.371.1592 Charlotte Office Corvallis Office 2815 Coliseum Centre Drive, 1100 NE Circle Blvd., Suite 200 Suite 230 Corvallis, OR 97330 Charlotte, NC 28217 541.360.0500 980.349.4804 Rockville Office 11333 Woodglen Ave., Suite 205 Rockville, MD 20852 301.770.0472 http://www.nuscalepower.com Twitter: @NuScale_Power 32 PM-112948 Revision:0 Copyright 2022 by NuScale Power, LLC.
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Advisory Committee on Reactor Safeguards (ACRS)
Full Committee 10 CFR Part 53 Subpart F Staffing, Personnel Qualifications, Training, and Human Factors February 2, 2022 1
Agenda 3:45pm - 3:55pm Opening Remarks & Staff Introductions 3:55pm - 5:00pm Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors 5:00pm - 5:15pm Discussion 2
Welcome / Introductions
- Welcome:
o Lauren Nist, Office of Nuclear Reactor Regulation (NRR)
- Presenters:
o Jesse Seymour, NRR o Maurin Scheetz, NRR o Theresa Buchanan, NRR
- Public Meeting Slides:
o ADAMS Accession No. ML22027A369 3
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Overview of Primary Staff Contributors (NRR & Office of Nuclear Regulatory Research)
- Theresa Buchanan, Senior Reactor Engineer (Examiner)
- Dr. David Desaulniers, Senior Technical Advisor for Human Factors and Human Performance Evaluation
- Dr. Brian Green, Human Factors Team Leader
- Dr. Niav Hughes Green, Human Factors Psychologist
- Dr. Stephanie Morrow, Human Factors Psychologist
- Lauren Nist, Branch Chief, Operator Licensing and Human Factors Branch
- Maurin Scheetz, Reactor Engineer (Examiner)
- Jesse Seymour, Reactor Operations Engineer (Human Factors) 4
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Presentation Topics
- Overview of Preliminary Rule Language
- Key Operations Staffing Considerations o Staffing Plans o Shift Technical Advisor o Certified Operators
- Simulator Considerations
- Regulatory Guidance Documents
- Questions 5
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Overview of §§ 53.750-789 Structure and Key Content o §§ 53.750-759: General Requirements
- § 53.753: Technical Requirements for operating license (OL) and combined license (COL) Applicants Human Factors Engineering (HFE) design requirements Human-System Interface (HSI) design requirements Concept of Operations, Functional Requirements Analysis, and Function Allocation requirements Staffing Plan requirements Licensed & Certified Operator program requirements
- § 53.755: Conditions of Licenses for OL and COL Holders Provisions for not using licensed operators and criteria Provisions for load-following o §§ 53.760-769: Operator Licensing Requirements
- Training, examination, requalification, and simulator requirements o §§ 53.770-779: Operator Certification Requirements o §§ 53.780-789: General Training and Qualification Requirements.
6
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements
§§ 53.750-759: Staffing, Training, Qualifications, and Human Factors
- Fulfills role similar to aspects of § 50.34(f) post-Three Mile Island (TMI) requirements, § 50.54 conditions of facility licenses, and Part 55 operator licensing requirements
- Key areas now linked to design safety functions and their fulfillment:
o HFE now required where needed to support safety function fulfillment o Operator staffing now required to the extent needed to support safety function fulfilment, versus reliance on prescribed numbers of operators o Licensed operator role centered on fulfilling/managing safety functions
- Includes criteria for when licensed operator staffing would not be required
- 1st proposal - no mitigative actions by operators needed to meet safety criteria, safety functions, or provide defense in depth (as supported by probabilistic risk assessment) and structures, systems, and components performance needed for licensing basis event (LBE) response not reliant on humans
- 2nd proposal - Design-basis accident safety criteria met without mitigative actions by operators, active engineered features, or passive design features (except those able to survive LBEs and resist credible human errors). 7
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements
§§ 53.760 through 53.789 - Overview of Key Aspects
- §§ 53.760-769, Operator Licensing Requirements o Requires training programs to be based on systems approach to training (SAT) and ensure licensed operators possess the knowledge/abilities needed to protect public health and maintain plant safety functions o Incorporates facility-developed and NRC-approved examination programs that are tailored to the design specific operator roles
- §§ 53.770-779, Operator Certification Requirements o Requires training programs to be based on SAT and ensure non-licensed, certified operators possess the knowledge and abilities needed to protect public health and perform job duties o Uses facility-developed/NRC-approved, tailored exam programs
- §§ 53.780-789, General Training & Qualification Requirements o Builds upon the § 50.120, Training Rule, but adjusts timeframe for program establishment and updates personnel categories 8
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Part 53 Staffing Approach
- Accommodate novel concepts of operations and diverse technologies
- Prescriptive staffing ratios (like those for large light water reactors) may not be needed/appropriate to support safe operation
- Consider differences in staffing needs when:
o Operators have a safety role o Operators do not have a safety role
- Conduct of Operations, Functional Requirements Analysis and Function allocation as input to staffing plan review
- Staff experience from recent review of NuScale small modular reactor staffing plans 9
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Part 53 Staffing Plan Requirements
- Describe numbers, positions, and qualifications of reactor operators (RO) and senior reactor operators (SRO) (or certified operators) across all modes
- Describe personnel in other support roles (e.g., operations, maintenance, radiological protection, chemistry, fire brigades, engineering, security, and emergency response)
- Facilities with licensed operators: describe how the proposed staffing level is sufficient to provide assurance that plant safety functions can be maintained (must provide support via HFE-analyses and assessments) 10
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Shift Technical Advisor (STA) Position in Part 53
- Prior concerns raised by the ACRS subcommittee have included:
o Reservation about blanket STA elimination under rule o Value of having an independent individual for event assessment o Desirability of maintaining engineering expertise available o Relevance of role in light of uncertainties with new designs
- Considering three different options as part of staffing plan requirements:
- 1. No requirement for STA
- 3. Requirement for engineering expertise that is independent from and readily available to the on-shift operators (for certified and licensed operators) 11
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Certified Operators - Background The staff proposed the option of non-licensed, certified operators for facilities meeting specific requirements as an alternative to SROs & ROs
- Certified operator would be responsible for important administrative functions that would otherwise be performed by SROs
- Certified operator staffing would need to provide a continuity of responsibility for facility operations during the operating phase, including monitoring of fueled units with the following capabilities:
o Receiving plant operating data and parameters o Ability to immediately initiate a reactor shutdown o Ability to promptly dispatch ops/maintenance personnel o The ability to implement any emergency plan responsibilities o Conducting reactivity manipulations that require human action 12
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Reasoning Behind the Certified Operator Alternative
- If a facility lacks an operator role in safety (e.g., an autonomous reactor design), then a key driver warranting federal licensing of individuals is removed (i.e., operator performance would not have a meaningful influence on public health and safety outcomes within that context) o Regardless of whether the operators were licensed, the facility itself would still be licensed by the NRC
- Important administrative job tasks that would remain still need to be accomplished by adequately qualified personnel.
o Precedent shows that similar administrative tasks have been fulfilled by non-licensed personnel, such as Certified Fuel Handlers
- Durable rule should account for future safety advancements 13
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Certified Operators versus Licensed Operators Considerations
- Prior concerns raised by the ACRS subcommittee have included:
o Differences in accountability compared to licensed operators o Lessened ability to resist coercion by inappropriate management o Redundancy to scalable operator licensing provisions o Lack of certification by an independent entity (i.e., the NRC)
- At present, the staff perspective remains that the certified operator alternative is appropriate based upon the following considerations:
o The framework should be able to efficiently account for staffing requirements when there is no significant human role in safety o Precedent for using non-licensed personnel in comparable roles o Designers have indicated that they may be able to meet criteria and have expressed potential demand for such an alternative o Ability to administratively assign responsibilities to management o Effects of a potential STA or engineering expertise requirement o Regulatory approval and oversight of certification programs 14
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Simulator Scope - Background
- Part 53 preliminary establishes simulation facility requirements for plants with licensed operators, along with less stringent simulation facility requirements for plants with certified operators; some key aspects include the following:
o Full-scope simulators are not mandated; partial scope simulators may be acceptable, provided that the scope is adequate to meet intended usage; alternatives to simulators are possible as well o Simulation facilities for plants with licensed operators must be approved by the Commission if the facility licensee will rely upon them for training, experience requirements, or for initial or requalification examinations
- Equivalent approval not required for certified operator facilities o Must demonstrate that adequate simulator scope is provided to support HFE analyses/assessments in order to use a simulation facility for conducting these analyses/assessments 15
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Simulator Scope
- In developing preliminary rule language, staff reviewed Section 306 of the Nuclear Waste Policy Act (NWPA) and 52 FR 9453 which discussed implementation of the Acts simulator-related provisions:
o Flexibilities historically provided to allow for potential use of the plant itself, and/or a plant-referenced simulator, and/or some other type of simulation device (such as a part-task or basic-principles simulator) for the conduct of the simulator portion of the operating test o The NRCs stated intent was not to permit the initiation of transients on the plant itself if used as a simulation facility; rather, the use of the plant was envisioned as an option that might be used in conjunction with another simulation device or devices, in lieu of a plant-referenced simulator
- Current perspective is that NWPA does not mandate NRC to require that plants have simulators, but instead requires regulations address the use of simulations in training; flexibility exists to allow the use of the actual plant to simulate tasks for training and operating test purposes without having a separate simulator
- Prior concerns raised by the ACRS subcommittee have included the potential for reductions in training and evaluative efficacy, impacts on procedure quality, reduced support of analyses, and staff experience in the approval of partial scope simulators 16
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Simulator Scope (contd)
- Philosophical basis behind preliminary rule language is:
o Plant-referenced, full-scope simulators remain the preferred approach and would represent the best route for meeting Part 53 requirements
- Staff expect majority of Part 53 applicants will have them due to regulatory certainty and technology lowering the associated costs o Existing regulations do not strictly mandate plant-referenced, full-scope simulators either, but still adopted by all current power reactors o Part 53 rule language leaves alternatives to simulator usage (full-scope or otherwise), but the burden will be on the applicant to demonstrate how the following are supported:
- Licensed or certified operator training and exams; simulators used require sufficient scope and fidelity for operators to acquire and demonstrate knowledge and abilities needed for job duties.
- Experience requirements (i.e., reactivity manipulations)
- HFE analyses/assessments and HSI design testbed needs o Additional staff review guidance may be needed, such as to support reviews of partial scope simulation facilities 17
Subpart F - Staffing, Personnel Qualifications, Training, and Human Factors Requirements Regulatory Guidance Development Overview
- HFE Review Guidance o Supports scalable reviews, developed with Brookhaven National Laboratory support, goal is draft by June
- Staffing Plan Review Guidance o Facilitates review of staffing plans using NUREG-1791, goal is draft by June
- Operator Licensing Examination Review Guidance o Supports review of tailored programs, developed with Idaho National Laboratory, goal is draft by June
- SAT-based Training Program Review Guidance o Supports the review of non-accredited training programs; developed by staff o Updates the existing, dated SAT review guidance of NUREG-1220 & IP 41500 o Current development goal is 1 year to support near-term applicants as needed o Team includes HQ and regional operator licensing staff (inc. former instructors)
- Advanced Reactor Content of Application Project, ISG Chapter 11, Organization and Human-System Considerations, as supplemented with guidance for Part 53 o Will support other review areas beyond those covered above or by existing guidance (e.g., load following, post-TMI items, simulation facilities, etc.)
18
Final Discussion and Questions 19
Acronyms and Abbreviations ACRS Advisory Committee for Reactor Safeguards NRR Office of Nuclear Reactor Regulation Agencywide Documents Access and NUREG U.S. NRC technical report designation ADAMS Management System NWPA Nuclear Waste Policy Act COL Combined license OL Operating license FR Federal Register RO Reactor operator HFE Human factors engineering SAT Systems approach to training HSI Human-system interface SRO Senior reactor operator ISG Interim staff guidance STA Shift technical advisor IP Inspection procedure TMI Three Mile Island LBE Licensing basis event 20
North Anna Power Station Units 1 and 2 Subsequent License Renewal Application ACRS Full-Committee Meeting February 2, 2022
Agenda Station Overview/Performance SLR Application Development SLR Aging Management Programs Technical Topics Closing Remarks 2
North Anna Power Station 3
Station Overview Unit 1 Unit 2 Full Power License - 2,775 MWt April 1, 1978 August 21, 1980 (Operating (Operating License Issued) License Issued)
Independent Spent Fuel Storage Loading Pad 1: 1998, Pad 2: 2008, (ISFSI) Pad 3: 2021 4.3% Power Uprate to 2,893 MWt 1986 First License Renewal Approval 2003 1.6% MUR to 2,940 MWt 2010 Entered Period of Extended Operation April 1, 2018 August 21, 2020 Current License Expiration April 1, 2038 August 21, 2040 4
North Anna Performance North Anna operates on an 18-month refueling frequency Plant Capacity Factor:
- 2019: U1 - 94.53% U2 - 90.38%
- 2020: U1 - 101.7% U2 - 88.41%
- 2021: U1 - 83.32% U2 - 102.21%
Regulatory Status
- ROP Actions Matrix Column 1
- All ROP Indicators are Green 5
Significant Plant Modifications North Anna Power Station Unit 1 Unit 2 A/B RSS Transformer Replacement 2021 2021 C RSS Transformer Replacement 2019 2019 Reactor Vessel Upflow Conversion 1996 2018 Reactor Vessel Head Replacement 2003 2003 Main Transformer Replacement 2006 2006 Station Service Transformers Replacement 2010 2010 Main Generator Replacement 2014 2008 Underground Fire Protection Piping Replacement 2012 2012 Fire Detection System Replacement 2021 2012 Service Water Spray Array Piping Replacement 2009 2009 AL-6XN Service Water Charging Piping Replacement 2001 N/A Service Water Instrument Air Compressor Dryer Replacement 2003 2003 Underground Security Diesel Generator Fuel Oil Supply Tank 2015 N/A Replacement Flux Thimble Tube Replacements 2016 N/A 6
SLR Application Improvement Implementation of Lessons Learned from Surry
- Fewer Than Half the Enhancements
- Led Industry/NRC Effort to Identify and Issue ISGs
- Reduced Number of AMPs with Exceptions 7
Integrated Plant Assessment First License Renewal (FLR) and Subsequent License Renewal (SLR) deltas Scoping & Screening
- Minimal Differences from FLR (pre-GALL)
- Some updates required to address 10 CFR 54.4(a)(2)
- Followed NUREG-2191 (GALL-SLR) and NUREG-2192 (GALL-SRP)
Aging Management Reviews
- NAPS FLR was pre-GALL, additional aging effects required disposition based on NUREG-2191 (GALL-SLR)
Aging Management Programs
- SLR - 48 AMPs License Renewal Commitments
- UFSAR Supplement (Appendix A)
- Implementation activities have begun and will continue following issuance of renewed license 8
North Anna SLR AMP Considerations Incorporation of operating experience (OE):
- Industry and plant specific OE reviewed for a 10-year period
- Participation in Industry Peer Reviews AMP Effectiveness Reviews performed on all first license renewal AMPs using elements of NEI 14-12 All First License Renewal (FLR) AMPs will be continued and incorporated into SLR AMPs 9
North Anna SLR - 48 GALL-AMPs Consistent With With Exception Plant with Enhancement Exception and Specific GALL-SLR Enhancement Existing 41 16 18 3 4 0 New 7 7 0 0 0 0 Total 48 10
FLR AMP Effectiveness FLR AMPs have been evaluated for AMP effectiveness
- Identified gaps have been included in the CAP system as described in Appendix B
- Periodic AMP effectiveness reviews are required to be completed by the program owners every 5 years OE is systematically reviewed on an on-going basis Training is conducted periodically for program owners IP 71003 Phase 2 inspection identified no findings or concerns in 4Q17 11
Technical Topics Concrete and RV Support RV Containment RV Internals Steel Embrittlement Degradation 12
Dominion Energy SLR Summary North Anna has a high degree of consistency with GALL-SLR, which resulted in a high quality SLR Application that includes lessons learned from Surrys SLRA North Anna SLRA was developed using the same highly experienced team used for Surry SLR Dominion Energy has committed future investments in people, program enhancements and equipment modifications for the SPEO 13
Advisory Committee on Reactor Safeguards North Anna Power Station, Units 1 and 2 Subsequent License Renewal Application (SLRA)
Safety Evaluation Report (SER)
February 2, 2022 Lois M. James, Senior Project Manager Office of Nuclear Reactor Regulation
Presentation Outline
- North Anna Licensing History
- North Anna Aging Management Programs
- Specific Technical Areas of Review
- Inspections and Plant Material Conditions
- Conclusion on North Anna SLRA Review
North Anna, Units 1 & 2:
Licensing History Initial License Renewal Initial Initial License Renewed Expiration Unit License Renewal Application License Date 1 4/1/1978 5/29/2001 3/20/2003 4/1/2038 2 8/21/1980 5/29/2001 3/20/2003 8/21/2040 Subsequent License Renewal Application Submitted 8/24/2020 Acceptance Determination 10/15/2020 Draft Safety Evaluation Report with 10/18/2021 No Open or Confirmatory Items Final Safety Evaluation Report 1/3/2022
North Anna Aging Management Programs SLRA - Original Disposition of AMPs SER - Final Disposition of AMPs o 7 new programs o 7 new programs
- 7 consistent
- 7 consistent o 41 existing programs o 41 existing programs
- 17 consistent
- 16 consistent
- 24 consistent with
- 25 consistent with enhancements and/or enhancements and/or exceptions exceptions
Specific Technical Areas of Review
- Reactor Pressure Vessel Neutron Fluence
- Irradiation Effects on Reactor Internals
- Buried Gray Cast Iron Piping
Reactor Pressure Vessel Neutron Embrittlement
- Unit 1 year projected peak neutron fluence of 7.20 x 1019 n/cm2 (E>1.0 MeV)
- Capsule X achieves 80-year projected peak neutron fluence at approximately 39.1 EFPY (~2025)
- Unit 2 year projected peak neutron fluence of 7.34 x 1019 n/cm2 (E>1.0 MeV)
- Capsule X achieves 80-year projected peak neutron fluence at approximately 39.3 EFPY (~2026)
Reactor Pressure Vessel Neutron Embrittlement
- Upper Shelf Energy (USE)
- Limiting USE value at 72 EFPY
- 50.0 ft-lbs for the Unit 1 Inlet Nozzle Forging 11
- 48.2 ft-lbs for the Unit 2 Intermediate Shell Forging 04
- Applicant conservatively performed equivalent margin analysis (EMA) for:
- Upper and Intermediate Shell Forgings
- Inlet and Outlet Nozzle Forgings and Welds
- Analyses have been projected to be no less than 50 ft-lbs or EMA demonstrated lower values of Charpy USE will provide margins of safety against fracture to the end of the SPEO
- Pressurized Thermal Shock (PTS)
- Limiting RTPTS value for base metal or longitudinal weld materials at 72 EFPY
- 212.2°F - Unit 2 Lower Shell Forging 03
- Limiting RTPTS value for circumferentially oriented welds at 72 EFPY
- 136.3°F - Unit 1 Intermediate to Lower Shell Circumferential Weld Heat # 25531
- PTS analyses have been projected to be below screening criteria in 10 CFR 50.61 at the end of the SPEO
Irradiation Effects on Reactor Internals
- Review Basis: The staff reviewed the 80-year neutron fluence values for the reactor vessel internals (RVI) components as part of the staff review of the RVI gap analysis that was included as part of SLRA AMP B2.1.7, PWR Vessel Internals.
- Staff Verification: The staff verified that the 72-EFPY neutron fluence values for the RVI components were adequately addressed in the applicant's gap analysis.
- Reasonable Assurance: The staff determined the applicants PWR Vessel Internals Program (including gap analysis) adequately addresses the inspection of RVI components during the SPEO
Buried Gray Cast Iron Piping in Fire Protection System
- 6 ruptures prior to 2003
- Identified as cracking due to cyclic loading -
during pump start testing
- Changed test procedure in 2003 to limit pressure in downstream piping - no ruptures since then
- Multiple inadvertent pump starts have occurred since 2003 without failures
- Material is also subject to selective leaching
- Material is brittle
Buried Gray Cast Iron Piping in Fire Protection System (cont)
- Enhancements 5 (for selective leaching) and 6 (for cracking) to the Buried and Underground Piping and Tanks Program
- 6 gray cast iron locations to be excavated each 10 years
- 5 piping 10-foot lengths and 1 piping or component for Selective Leaching program
- Visual and magnetic particle to inspect for cracking
- Combination of radiography and destructive testing on a 1-ft section if cracking is identified, to determine cause
- If defect is from manufacturing and not aging: document results
- Cracking due to aging will result in crack growth and flaw stability evaluations to end of subsequent PEO
- Projected loss of function will be entered into Corrective Action Program for extent of condition, extent of cause and further follow-on actions
Buried Gray Cast Iron Piping in Fire Protection System (cont)
Two nonconcurrences were received during the review and concurrence process regarding the buried gray cast iron piping in fire protection system.
Both nonconcurrences were resolved in the final SER.
Region II AMP Inspections License Renewal Inspection Program for Initial Period of Extended Operations Inspection Dates Results U1 & U2 IP 71003 September 19-22, 2016 No Findings Phase 1 ML16306A189 U1 IP 71003 Nov 27-Dec 15, 2017 No Findings Phase 2 ML18029A029 U2 IP 71003 March 11-15, 2019 No Findings Phase 2 ML19134A146 U1 & U2 IP71003 TBD Phase 4
Region II: AMP Inspections ROP Baseline Inspections Inspection Date Aging Management Program IP71111.08 ISI Annually Augmented Inspection Activities alternate units Boric Acid Corrosion Surveillance ISI Program - Component and Component Support Inspections ISI Program - Containment Inspections ISI Program - Reactor Vessel Reactor Vessel Internals Inspection Steam Generator Inspections IP71111.07T Heat Sink 2006, 2008, Service Water System Inspections 2011, 2014, 2017, 2020 IP71111.21M DBAI 4Q 2018 Ensure the selected SSCs that are subject (operating 4Q 2021 in the post-40-year licensing period) to aging management review pursuant to 10 CFR Part 54 are being managed for aging in accordance with appropriate aging management programs.
IP71152 PI&R Sample 2Q 2018 Preventive Maintenance Program Age-related capacitor degradation resulted in a reactor trip
Region II AMP Inspections Resident Inspector Insight and Inspection Results
- No findings from License Renewal Program inspections
- 2013: Green finding for the failure to failure to establish and implement appropriate periodic preventive maintenance for replacement frequency of the C4 capacitor on the Speed Error Amplifier card B (1A08D). The C4 capacitor failed due to age related degradation. (FIN 05000339/2013007-01)
- 2021: Green NCV for an inadequate procedure for handling age degraded safety related cable. (NCV 05000338,05000339/2021010-03)
Region II: Plant Material Condition + Conclusion
- Plant material condition is generally acceptable and meets regulatory requirements for systems, structures, and components.
- The inspectors found that the AMPs were being implemented in accordance with the license condition.
- The NRC will continue to monitor AMPs using the baseline Reactor Oversight Process.
SLRA Review Conclusion On the basis of its review of the SLRA, the staff determined that the requirements of 10 CFR 54.29(a) have been met for the subsequent license renewal of North Anna Power Station, Units 1 and 2.