ML22334A138
| ML22334A138 | |
| Person / Time | |
|---|---|
| Issue date: | 10/21/2022 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2137 | |
| Download: ML22334A138 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards SHINE Subcommittee Docket Number: (n/a)
Location: teleconference Date: Friday, October 21, 2022 Work Order No.: NRC-2137 Pages 1-73 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 SHINE SUBCOMMITTEE 8 + + + + +
9 FRIDAY 10 OCTOBER 21, 2022 11 + + + + +
12 The Subcommittee met via Video 13 Teleconference, at 9:30 a.m. EDT, Ronald Ballinger, 14 Chairman, presiding.
15 16 COMMITTEE MEMBERS:
17 RONALD G. BALLINGER, Chair 18 VICKI BIER, Member 19 CHARLES H. BROWN, JR., Member 20 VESNA DIMITRIJEVIC, Member 21 GREGORY HALNON, Member 22 JOSE MARCH-LEUBA, Member 23 JOY L. REMPE, Member 24 MATTHEW SUNSERI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1 ACRS CONSULTANT:
2 DENNIS BLEY 3 KEN CZERWINSKI 4 STEPHEN SCHULTZ 5
6 DESIGNATED FEDERAL OFFICIAL:
9 ALSO PRESENT:
10 MICHAEL BALAZIK, NRR 11 JOSH BORROMEO, NRR 12 NORBERT CARTE, NRR 13 CATHERINE KOLB, SHINE 14 SCOTT MOORE, ACRS 15 RYAN MYERS, SHINE 16 TRACY RADEL, SHINE 17 BILL WATSON, SHINE 18 DANIEL ARIZAGA, SHINE 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 TABLE OF CONTENTS 2 Page 3 Opening Remarks and Objectives . . . . . . . . . 4 4 Staff Opening Remarks . . . . . . . . . . . . . . 7 5 Section 7.4.3, "Process Integrated Instrument Control 6 System" 7 By Shine Medical Technologies LLC . . . . . 8 8 Section 7.4.3, "Process Integrated Instrument Control 9 System" 10 By NRC Staff . . . . . . . . . . . . . . . 24 11 Phased Startup Operations Supplement . . . . . . 35 12 Phased Startup Operations, SER, Appendix A . . . 51 13 Public Comment . . . . . . . . . . . . . . . . . 60 14 Committee Discussion . . . . . . . . . . . . . . 60 15 Adjournment . . . . . . . . . . . . . . . . . . . 73 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 9:30 a.m.
3 CHAIRMAN BALLINGER: All right. It's 4 9:30. Let's begin the meeting. This is a meeting of 5 the SHINE Subcommittee of the Advisory Committee on 6 Reactor Safeguards. I'm Ron Ballinger, Chairman of 7 today's subcommittee meeting.
8 ACRS members in attendance are Charlie 9 Brown, Greg Halnon, Jose March-Leuba, Joy Rempe, Matt 10 Sunseri, and I see Vesna somewhere here, Vesna 11 Dimitrijevic. And if I've missed somebody, I'm sure 12 I'll get reminded.
13 MEMBER BIER: Yes, Ron.
14 CHAIRMAN BALLINGER: Yes, yes.
15 MEMBER BIER: This is Vicki Bier. I just 16 joined, and I don't know if you saw my email. I will 17 have to duck out for a while at around 11 Eastern.
18 CHAIRMAN BALLINGER: Yes, got it. Thanks 19 again. We also have our consultants, Dennis Bley and 20 Steve Schultz present. Chris Brown of the ACRS staff 21 is the Designated Federal Official for this meeting.
22 During today's meeting, the subcommittee 23 will have a discussion with the NRC staff and SHINE 24 Medical Isotope, Incorporated, concerning process 25 integrated instrument control system (PICS). They NEAL 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 start up in any other remaining questions concerning 2 life cycle. I might add that this is the last 3 subcommittee meeting for this effort, so it's been a 4 long road but we're almost at the end.
5 The rules for participating, part of the 6 presentations by the applicant may be closed. We 7 don't think that will be the case, but, if it is, 8 we'll have to make arrangements to close the meeting.
9 The rules for participating in all ACRS, 10 including today's, were announced in the Federal 11 Register on June the 13th, 2019. The ACRS section of 12 the U.S. NRC public website provides our charter, 13 bylaws, agendas, letter reports, and full transcripts 14 of all full and subcommittee meetings, including 15 slides presented there. The meeting notice and agenda 16 for this meeting were posted there. We have received 17 no written statements or requests to make an oral 18 statement from the public.
19 The subcommittee will gather information, 20 analyze relevant issues and facts, and formulate 21 proposed positions and actions, as appropriate, for 22 deliberation by the full committee. The rules for 23 participation in today's meeting have been announced 24 as part of the notice for this meeting previously 25 published in the Federal Register.
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6 1 Today's meeting is being held virtually 2 over Microsoft Teams. A telephone bridgeline allowing 3 participating for the public using their computer 4 using Teams or by phone was made available.
5 Additionally, we have made an MS Teams link process 6 and password available on the published agenda.
7 A transcript of today's meeting is being 8 kept. Therefore, we request that meeting participants 9 on Teams and on the Teams call-in line identify 10 themselves when they speak and to speak with 11 sufficient clarity and volume so they can be readily 12 heard. Likewise, we request that meeting participants 13 keep their computer and/or telephone lines on mute 14 when not speaking to minimize disruptions. The chat 15 features on Teams should not be used for any technical 16 exchanges. Let's see. I can control -- most 17 everybody looks like they're muted.
18 Again, I'd like to note that this is our 19 final SHINE Subcommittee interaction with the staff 20 and SHINE. We do have a November 15th subcommittee 21 meeting from 8:30 to 5, it's a whole day, in which the 22 subcommittee will work on remaining memos and work on 23 the draft final letter report. That subcommittee will 24 be open to the public.
25 We'll now proceed, and Josh, I see you NEAL 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 there. So please give any opening remarks that you 2 would like.
3 MR. BORROMEO: Thank you, Professor 4 Ballinger. My name is Josh Borromeo. I'm Chief of 5 the Non-Power Production and Utilization Facility 6 Licensing Branch. Today you're going to hear 7 presentations from the staff and SHINE on PICS, the 8 process integrated control system, which is a non-9 safety related system for the facility. And you'll 10 also hear an overview of the phased construction 11 approach and also our associated license and controls 12 the staff is putting in place to ensure a safe 13 operation while SHINE moves from phase to phase of 14 construction.
15 Now, I do want to recognize it's been a 16 long road, right, and in our internal chat we were 17 saying, okay, we've started these in February. So I 18 wanted to recognize that we still have some work to do 19 to get this thing over the finish line, but I do want 20 to express my appreciation for all the hard work that 21 the staff and SHINE has done to get us to this point.
22 And I also want to highlight my appreciation for ACRS 23 and ACRS staff for being flexible and identifying ways 24 to efficiently work to get us through this review.
25 So with that, I'll turn it over to SHINE NEAL 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 for their PICS presentation.
2 CHAIRMAN BALLINGER: Okay. Before we add 3 again, we now have Ken Czerwinski, another one of our 4 consultants in the chemistry area, that's joined the 5 meeting.
6 Okay. Let's go.
7 MR. MYERS: Hello. My name is Ryan Myers.
8 I'm an I&C engineer here at SHINE. Welcome to the 9 process integrated control system, PICS, presentation.
10 Next slide, please. Here's a look at the 11 topics that will be covered. First will be an 12 overview of the PICS main functions, then PICS network 13 security features. After that, we'll look at PICS 14 interfaces with safety-related systems. Next, our 15 PICS communications with vendor-provided non-safety 16 related control systems. And, finally, we'll look at 17 operator access to the PICS network using PICS 18 workstations.
19 Next slide, please. Here's Figure 7.1-1 20 from the FSAR showing the instrumentation and control 21 system architecture. The upper right corner of the 22 figure shows the PICS external interfaces with safety 23 and non-safety related systems. Unidirectional and 24 bidirectional communications with PICS are captured 25 here. The safety-related systems in the center 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
9 1 this figure were covered in previous NRC audit 2 discussions. PICS communications with the supervisor 3 and operator workstations and indication displays in 4 the facility control room are shown at the bottom of 5 the figure, along with PICS production facility HMI 6 communications.
7 Next slide, please.
8 MEMBER BROWN: Could you go back to the 9 other slide for a minute? This is Charlie Brown.
10 MR. MYERS: Sure.
11 MEMBER BROWN: I noticed, it's just a 12 question and maybe you've got an overarching answer 13 for this. This is the -- you primarily show Figure 14 7.1-1, which is the excellent representation of the 15 safety systems that we addressed in the last meeting.
16 The process control, process integrated control system 17 has a big box with nothing in it, which not unexpected 18 since that's separate. And there is a figure in the, 19 I think it's 7.3-1, but that one is nowhere near what 20 I call the detail that the 7.1-1 is for the safety 21 systems. It's, fundamentally, some block diagrams 22 with one line going everywhere, which leaves a little 23 bit -- you talked about ethernet inside of your PICS 24 operations, and it would be nice to hear a little bit 25 about how integrated these overall PICS things is when NEAL 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 we get to that point in the slides.
2 I'm just giving you a heads-up, there's a 3 question I had relative to the detail and how 4 integrated the -- because you do call it an integrated 5 system and how diverse -- not diverse; that's the 6 wrong word. I'm not looking for diversity. I'm 7 looking for separation of functions because there's 8 two or three dozen process systems that are part of 9 this overall process integrated control system. And 10 my question really boils down to is it a giant 11 computer that's running all those giant set of servers 12 where all the software is on one or two servers, or 13 are they independent systems which feed independently 14 into the control functions for the operators?
15 You don't have to answer that now. It's 16 just when we get to the appropriate point. Did I get 17 that across very well?
18 MR. MYERS: Yes.
19 MEMBER BROWN: Okay.
20 MR. BROWN: Excuse me. This is Chris 21 Brown. It looks like you were trying to go to full 22 screen. Can you -- this diagram is very small. Can 23 you try to change the view?
24 MR. MYERS: Yes, I'm just having a 25 challenge doing that. There we go. Sorry. It's my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 1 first time driving.
2 MEMBER BROWN: We've got our magnifying 3 glass. A little humor to start the meeting.
4 MR. MYERS: So on to the next slide then.
5 PICS is a non-safety related control system used by 6 the plant operators to control and monitor facility 7 equipment throughout the radiation facility and 8 radioisotope production facility. PICS supports the 9 facility control room which contains the operator 10 workstations and the main control board.
11 The non-safety related instruments and 12 controls used throughout the plant are wired to the 13 local remote idle panels which then route back to the 14 PICS main distribution switch in the server room over 15 copper or fiberoptic cabling. The PICS HMI 16 workstations, including five system-specific remote 17 workstations, use thin clients connected to virtual 18 machines running on a server in the server room.
19 Next slide, please.
20 MEMBER BROWN: Did that just answer part 21 of my question?
22 MR. MYERS: I think so.
23 MEMBER BROWN: That these, all these 20 or 24 30, whatever it is, the large number -- and I'm not 25 arguing about the number. You obviously have a lot 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
12 1 things you have to control. So, fundamentally, 2 there's a giant server where all the software is 3 located for these systems. They're not separate PLCs 4 for every system. Is that a correct assumption, for 5 other than the ones shown up in the upper block of 6 Figure 7.3-1?
7 MR. MYERS: There are separate PLCs split 8 up by system. On the PICS side, there are five 9 separate, well, actually, seven PLCs and then three 10 for TPS. Those are split up, but they do communicate.
11 They're virtual machines, like HMI screens run 12 through, are on a stratus fault tolerant server that's 13 located in the server room.
14 MEMBER BROWN: Okay. So there is a -- so 15 this is stuff is, fundamentally, fed into -- if that 16 server fails, what happens? You lose all your 17 controls?
18 MR. ARIZAGA: Sorry. This is Dan Arizaga, 19 I&C engineer.
20 MEMBER BROWN: Yes.
21 MR. ARIZAGA: So, essentially, there is 22 redundancy in that with multiple thin clients, so, if 23 one of the servers goes down, you would have several 24 backup servers that would be able to pick up, so you 25 would have no interruption of the actual control PICS.
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13 1 MEMBER BROWN: Okay. So you've got 2 backups. So you've got parallel servers running, 3 which are all up to date for whatever is going on so 4 that the workstation operator can move from one to the 5 other server, as needed, to carry on operations; is 6 that correct?
7 MR. MYERS: Yes. It will switch to the 8 backup server automatically if the primary server were 9 to fail.
10 MEMBER BROWN: Okay, all right. Go ahead.
11 MR. MYERS: I can go into a little more 12 detail as we progress.
13 MEMBER BROWN: Okay. That's fine. Thank 14 you.
15 MR. MYERS: PICS network, architecture and 16 security, did I get through this one? Okay. The most 17 important PICS security feature is that there is no 18 connection to the internet, and the PICS devices are 19 not WiFi capable. PICS does have an outbound only 20 connection through a one-way data diode to the PICS 21 historian. The PICS manufacturing control network is 22 separated from the SHINE business network behind its 23 PLC, and its PLC communications are split into ten 24 virtual local area networks, or VLANs, one for each of 25 the ten PLCs.
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14 1 PICS has physical security implemented, 2 including the locking of control cabinets, the server 3 room, and physically blocking unused network ports.
4 The ethernet IP with CIP communication protocol used 5 for PICS is widely used to secure plants worldwide.
6 No remote access for monitoring or maintenance of the 7 plant is allowed either.
8 Next slide, please.
9 MEMBER BROWN: Stay there for a minute.
10 This is Charlie Brown again. You say the 11 manufacturing network is segregated from the SHINE 12 business network. Does that mean it's not connected?
13 MR. MYERS: It's not connected at all.
14 MEMBER BROWN: Okay. That's all I was 15 looking for. Segregation could mean you have 16 segregated software within your servers that allows 17 you to operate, but you're totally disconnected.
18 That's all I wanted to know. Thank you.
19 MR. MYERS: PICS interfaces with safety-20 related systems. The safety-related systems, the 21 target solution vessel reactivity protection system, 22 TRPS, and the engineered safety features actuation 23 system, ESFAS, communicate with PICS through a one-way 24 isolated rs485 Modbus gateway. While the information 25 exchange is unidirectional from TRPS/ESFAS to PICS, NEAL 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 PICS does send two cyclic redundancy checks, CRCs, per 2 Modbus message for error checking and verifying the 3 identity of the data.
4 Under normal operating conditions, PICS 5 allows operators to manually actuate TRPS/ESFAS 6 controlled components. The PICS controlled relays 7 have contacts in series with the TRPS/ESFAS controlled 8 relay contacts, so the safety and non-safety system 9 controls remain electrically isolated. TRPS/ESFAS can 10 remove component power, causing the components to fail 11 to their safe positions, regardless of PICS output 12 state.
13 After safety actuations, the enabled non-14 safety switch must be physically moved from the 15 disabled to the enabled position on the main control 16 board by the operator before a component reset request 17 can be sent from PICS. The actuation and priority 18 logic in TRPS/ESFAS must not be prevented by higher-19 priority inputs before TRPS/ESFAS will reset the 20 component, as requested by PICS.
21 The TRPS mode transition and component 22 reset request signals are sent from PICS to the safety 23 systems using a bit stream or binary pattern of 24 discrete relay outputs that are decoded by TRPS/ESFAS.
25 Unrecognized PICS output patterns will do nothing 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
16 1 TRPS or ESFAS. PICS is designed so that it cannot 2 fail or operate in a mode that could prevent the TRPS 3 or ESFAS from performing its designated functions.
4 CHAIRMAN BALLINGER: This is Ron 5 Ballinger. On bullet number one, two, three, four, 6 five, PICS provides signals to TRPS/ESFAS to 7 reposition components, da, da, da, da, da. Is this an 8 area where errors of commission or omission can impact 9 the safety side?
10 MR. MYERS: Can you --
11 MEMBER BROWN: Let me interpret his 12 question for you. If the operator doesn't do 13 something, does that affect the safety side --
14 CHAIRMAN BALLINGER: Yes, either 15 intentionally or not intentionally.
16 MEMBER BROWN: Right.
17 MS. RADEL: This is Tracy. So the -- no, 18 no operator action is needed to respond to an accident 19 condition, so they don't need to do anything. We have 20 assessed thoroughly to ensure that, if they do, 21 anything that they do cannot impact the safety systems 22 from performing their safety functions.
23 MS. KOLB: And this is Catherine Kolb. So 24 the purpose of this is for the reset, which I believe 25 we discussed at a previous meeting. So after 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
17 1 actuation from TRPS or ESFAS, you'd ensure that the 2 non-safety, enabled non-safety switch was in the 3 enabled position, and then you would be able to use 4 the PICS component, the PICS interface to reopen 5 components that had closed, for example to reset 6 things that had actuated.
7 There's no time requirements associated 8 with that in our design. There's no, you know, no 9 analogs, like power reactors sometimes have time 10 required actions in order for operators to do things.
11 This is just recovering from an accident at the 12 operator's discretion once the accident has been 13 mitigated or otherwise dispositioned to be safe.
14 CHAIRMAN BALLINGER: Thank you.
15 MR. MOORE: This is Scott Moore. I just 16 ask that each of the speakers identify themselves with 17 a full name before speaking, at least for the first 18 time. Thank you.
19 CHAIRMAN BALLINGER: Good point. Thank 20 you.
21 MR. MYERS: Next slide, please. PICS 22 vendor-provided non-safety related control system 23 interfaces. There are several vendor-provided control 24 system interfaces with PICS that provide the operators 25 in the facility control room with important process NEAL 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 monitoring information. Some of the vendor-supplied 2 control systems include the neutron driver assembly 3 system, NDAS; a super cell; and various auxiliary 4 control systems. Again, the most important thing is 5 that none of the PICS vendor-provided devices have 6 internet connections. Similarly, no remote access is 7 allowed. In unused communication, ports are blocked 8 or disabled. Many of the vendor-provided control 9 systems use ethernet, Modbus, or other industry 10 standard protocols to communicate with PICS. The 11 safety benefits of the object-oriented CIP protocol 12 over ethernet IP are employed by many of the vendor-13 supplied control systems.
14 Next slide, please. Vendor-provided non-15 safety related control system interfaces continued.
16 The Modbus connections tie into the PICS network via 17 Modbus interface modules or gateways, which provide 18 independently-configured communication ports specific 19 to their devices and systems. PICS Modbus networks 20 only communicate with read/write registers approved by 21 the vendors. Like the plant equipment using internet 22 IP with CIP, the building automation system, or BAS, 23 equipment uses BACnet/IP, another protocol commonly 24 used in plants for HVAC and system facility controls.
25 PICS monitors information from the non-NEAL 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 safety related vendor provided super cell and 2 radioactive liquid waste immobilization PLCs, along 3 with radiation monitors throughout the plant. PICS 4 communicates with the vendor-supplied NDAS control 5 system through providing permissive signals and 6 monitoring information.
7 Next slide, please.
8 MEMBER BROWN: Before you go on, this is 9 Charlie Brown again. The super cell, I'm trying to 10 think back to the facility figure. Are the super 11 cells within the irradiation units, or is that a big 12 separate -- I've forgotten.
13 MR. MYERS: That's on the RPF side.
14 MEMBER BROWN: Okay. So that's on the 15 production facility side. And there's how many super 16 cells, just one or I thought there were multiple super 17 cells.
18 MR. MYERS: Just the one.
19 MS. RADEL: This is Tracy Radel. Just to 20 clarify, there's one super cell that has ten 21 individual hot cells within it.
22 MEMBER BROWN: Okay. That's what, I was 23 trying to get to that. I was looking at your figures 24 from the text. I saw a number of workstations for 25 various super cells. Okay, I got it. Thank you.
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20 1 MR. MYERS: PICS workstations and network 2 access. Users who require access to the FactoryTalk 3 View Site Edition Supervisory Control and Data 4 Acquisition system will have independent accounts 5 created on the manufacturing domain. When logging in 6 to a PICS workstation, the operator's credentials are 7 authenticated against the valid accounts on the 8 manufacturing domain and workstation graphics are 9 view-only when no user is logged in.
10 Each PICS domain user will be assigned to 11 one of five domain groups, including maintenance, 12 operator, supervisor, administrator, or quality.
13 SCADA permissions are limited based on the assigned 14 domain group.
15 In addition to domain groups, users are 16 assigned to security areas which allow control of PICS 17 equipment. Control room operators and supervisors are 18 assigned to all security areas.
19 Next slide, please. And now for the final 20 slide, PICS workstations and network access continued.
21 A PICS workstation user can only take control of a 22 remote HMI after access is granted by the control room 23 supervisor. The control room supervisor can also take 24 back control of the PICS equipment at any time. Each 25 workstation and main control board thin client have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 1 their own ten-minute backup power supplies provided by 2 a local UPS. The standby generator system should be 3 providing backup power before the local UPS runs out 4 of battery. If power to a remote operator workstation 5 were lost, that thin client's virtual machine session 6 would continue to run on the stratus fault tolerant 7 server in the server room.
8 That concludes the PICS presentation.
9 Thank you.
10 MEMBER BROWN: Can I ask -- this is 11 Charlie Brown again. Can I ask another question or 12 maybe two, if I can figure it out here.
13 MR. MYERS: Sure.
14 MEMBER BROWN: I just wanted to confirm 15 something. I think you said this earlier, but I 16 wanted to connect it with words in the FSAR. In 17 Section 7.3.5, 7.3.3.5, that's the access control and 18 cybersecurity section, second paragraph reads, the 19 PICS and other vendor-provided non-safety related 20 control systems do not allow remote access. You 21 talked about that a minute ago. Let me finish the 22 next point.
23 Paragraph six says vendor-provided non-24 safety related control systems communicate with the 25 PICS via ethernet or other industry standard digital NEAL 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 communication protocols. I'm assuming that the 2 ethernet is, there is no connection of any ethernet.
3 You're running an ethernet bus through the PICS. I 4 think you told us that in the previous meeting. Is 5 that correct? Is my memory correct?
6 MR. MYERS: Yes, it's a local internet 7 hardwired connection within the plant itself.
8 MEMBER BROWN: Okay. But it's strictly a 9 local interior internet communication systems, so you 10 can control multiple systems.
11 MR. MYERS: Right.
12 MEMBER BROWN: There is no connection to 13 that particular network or internet network to any 14 remote networks.
15 MR. MYERS: Correct.
16 MEMBER BROWN: Outside the facility, 17 outside the facility. I think you've said that. I 18 just wanted to -- the words were a little bit dicey in 19 terms of how it's phrased; that's all.
20 MR. MYERS: Yes, you're correct. There 21 are no ethernet connections outside of the facility.
22 MEMBER BROWN: Okay, all right. Thank 23 you. Let me see if -- go ahead.
24 MR. WATSON: Charlie, this is Bill Watson, 25 interim I&C manager. I did want to correct the record NEAL 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 on one point. There is an outbound data stream from 2 PICS to the PICS historian for sending information, 3 outbound only.
4 MEMBER BROWN: Yes.
5 MR. WATSON: That communication occurs 6 through a data diode or what the NRC calls a 7 deterministic device, so it, in no physical way, can 8 even allow any kind of external communications to come 9 in to PICS. It's basically a one-way, you know, 10 hardware device. It only allows PICS to report, you 11 know, performance data out to the historian. So I 12 didn't want --
13 MEMBER BROWN: Go ahead, go ahead.
14 MR. WATSON: I just wanted to make sure we 15 were clear on that point, that there actually is a 16 connection but it is outbound only and it's a hardware 17 outbound only. It can't be defeated in any way.
18 MEMBER BROWN: Yes, mentioned that a few 19 minutes ago. I guess my question on that is -- how 20 can I phrase this properly? You've probably read 21 this, I've reiterated this many times. A hardware-22 based device can have bidirectional hardware-based 23 devices, but it's configured by software. A true data 24 diode is not configured by software. In other words, 25 it's hardwired and it can only have one unit NEAL 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 directional. Nothing from external can backfill 2 through it or be captured somewhere else and then 3 reverse that or turn it into a bidirectional.
4 So I presume the data diode interpretation 5 in this is strictly one way of passing data in and 6 only one thing to couple it and send it out, and 7 there's no software package that configures that.
8 It's hard configured.
9 MR. WATSON: That's absolutely correct in 10 the case of the data diode that's used for PICS.
11 MEMBER BROWN: Okay. That's all I wanted 12 to know. Thank you very much. And thank you all for 13 doing that so I didn't have to say anything.
14 CHAIRMAN BALLINGER: So that was your last 15 slide?
16 MR. MYERS: That's correct.
17 CHAIRMAN BALLINGER: Okay. If there 18 aren't any questions from the members or consultants 19 on this presentation, we can switch over. Here we 20 are. We're already there. I don't know who is the 21 presenter in this case.
22 MR. CARTE: Norbert Carte from I&C, NRR.
23 CHAIRMAN BALLINGER: I'm a slow reader.
24 Thanks.
25 MR. CARTE: Once again, this is Norbert NEAL 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 Carte from the Instrumentation & Control Branch.
2 We're assisting DANU in the review of the application.
3 Next slide, please. So, predominantly, 4 the review involves the same reviewers as you've seen 5 previously. However, the bulk of the review for PICS 6 was done by me, although there was some minor 7 involvement by others.
8 Next slide, please. We use the same set 9 of guidance, obviously different sections, for our 10 review of PICS. Next slide, please. I used red a 11 little bit to highlight what's new and different from 12 what you've seen before.
13 Next slide, please. So what we're looking 14 now is at PICS. What you've seen before was basically 15 HIPS, TRPS/ESFAS radiation monitoring systems.
16 Next slide, please. So the PICS 17 description is actually a little bit segmented in the 18 sense that there is some description in 7.3 and 19 obviously 7.2, and as well as 7.6, which is the 20 control console display instruments. Most of the 21 control console and display stuff is addressed by HFE, 22 but it is technically part of PICS, so it was covered 23 in the SER section on PICS.
24 And, again, the SHINE facility has two 25 distinct parts in a radiation facility and a refuel NEAL 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 radioisotope processing facility and one control room 2 and one PICS for everything. Well, yes, the TRPS is 3 for each irradiation unit.
4 So the safety of the facility is, in part, 5 defined by two things: the criteria on the PICS 6 systems and the criteria on the protection systems.
7 But the requirements that the protection system be 8 independent from the PICS system is not a requirement 9 placed on the PICS, it's a requirement placed on the 10 protection systems, and that was covered separately.
11 Now, there isn't necessarily a requirement that they 12 be diverse or different, but they are just by the 13 nature of the technologies used.
14 Next slide, please. So the following 15 three slides are three depictions from the FSAR of 16 what constitutes the PICS. I won't spend a lot of 17 time on this, but this is a little bit more detailed 18 and is a little bit what Charlie was asking about on 19 the other slides.
20 So next slide, please. This is the 21 gateway communication between the safety system and 22 the non-safety and basically what it's showing is that 23 there are two predominant communication paths; and, 24 within those communication paths, there are multiple 25 instances of one-way communication. So it's 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
27 1 possible to communicate effectively into the TRPS or 2 ESFAS, and that is one of the things that ensures 3 independence.
4 The other thing that ensures independence 5 is that, in general, the safety systems are failsafe 6 on loss of power and the safety actuation is to lose 7 power. Those two relays are in series, as described 8 in the previous presentation, so that's a little bit 9 how, another way that the systems are independent.
10 This is the digital communication independence that 11 the series power relays are the actuation 12 independence.
13 Next slide, please. So, in essence, the 14 control board has some static displays, as well as 15 some manual switches. What you see is a little bit 16 the ESF, which has, it's the middle display. It has 17 that little operate safe shutdown position for the 18 enable facility operation key switch.
19 Next slide, please. So, again, we need to 20 summarize a little bit the NRC's approach to safety 21 regulation. So it's a layered approach, and, in that 22 layer, we do certain types of review. So the 23 application identifies the principal safety concerns, 24 the design criteria effectively establish the 25 performance objectives that, if met, will ensure 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
28 1 the reasonable assurance of adequate safety against 2 the safety considerations. The design bases are, in 3 effect, the functions and values performed by the 4 system and used in the analysis to demonstrate that 5 normal operation, as well as anticipated events, will 6 not cause the performance criteria to be exceeded.
7 Then, finally, the last layer of the 8 review, and this is predominantly where I&C falls in, 9 is that the equipment performs the design basis 10 functions and values and misbehaviors of the equipment 11 do not exceed the assumptions in the safety analysis.
12 So predominantly -- next slide, please -- our review 13 is to ensure that the misbehaviors of the equipment do 14 not violate the safety analysis. So that, in essence, 15 required us to look at a subset of the design criteria 16 in the FSAR, and what you see in the safety evaluation 17 and summarized below is the subset of criteria that we 18 looked at to ensure safety.
19 Next slide, please. So the safety 20 analysis, and so, as we were summarizing before, in 21 effect, a system, our view of the world is that there 22 are two types of systems in a facility, ones that 23 generate events and ones that either prevent or 24 mitigate or alarm and notify about those events. So 25 the analysis demonstrates that the protection system NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 1 ensures that all events generated do not endanger the 2 health and safety of the public, and the PICS review, 3 the FSAR, includes an analysis of the HIPS equipment 4 or a summary of the analysis of the HIPS equipment, 5 which we did look at during the audit, and that 6 summary concluded that the failure modes of the HIPS 7 equipment were bounded by the safety analysis 8 documented in the FSAR or summarized in the FSAR.
9 There were two sort of exceptions to that 10 which impose additional requirements on the 11 architectural design so that those failures would not 12 exceed what was already analyzed. But that level of 13 detail is not really necessary in the FSAR and, 14 therefore, is not in the FSAR. It was looked at 15 during the audit.
16 So, again, the PICS is independent from 17 the TRPS and ESFAS by multiple ways, the digital 18 communication we saw earlier, the series, relays for 19 power to the controlled components. And the analysis 20 of the failure, the effects of failures is described 21 in the FSAR as summarized on this slide.
22 MEMBER BROWN: Norbert?
23 MR. CARTE: Yes.
24 MEMBER BROWN: You can correct me if I'm 25 wrong, but I hope I'm not. When we say the PICS 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
30 1 independent from the TRPS and ESFAS, there are 2 communications from the facility control room that go 3 through the PICS, but it comes up through the hardware 4 module or something like that, I've forgotten what 5 it's called, for specific, but it's unidirectional 6 type information. It's not stuff, it's control 7 functions is what I'm saying. It's nothing that could 8 interfere with the operation of the TRPS or ESFAS.
9 MR. CARTE: Right. Actually, maybe the 10 wording on that slide is slightly --
11 MEMBER BROWN: Yes, I'm looking at Figure 12 7.1-1, and you can very clearly see that there are 13 interactions from the workstations to the PICS and 14 then go out up to that, whatever it's called, I can't 15 read it. I don't have my magnifying glass right now.
16 MR. CARTE: Yes, technically, you're 17 correct. The wording on this slide, it's not a 18 bidirectional wording, and it's actually, I would say, 19 incorrect. The TRPS and ESFAS are independent from 20 PICS. The PICS is not necessarily independent from 21 the TRPS. But our view is that any failure of the 22 PICS would not inhibit the TRPS and ESFAS from 23 performing its function and, in that sense, they're 24 independent.
25 MEMBER BROWN: Yes, I got that.
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31 1 MR. CARTE: There is some information --
2 MEMBER BROWN: I just wanted to point out 3 the discrepancy; that's all.
4 MR. CARTE: Yes. So there is information 5 that goes from the TRPS and ESFAS to the PICS and 6 failures of that information would result in loss of 7 that information to PICS. But the TRPS and ESFAS is 8 failsafe, so if that information were missing, like 9 sensor failures, then the TRPS would failsafe to the 10 safe state. But, in essence, you're correct. That 11 statement is wrong. TRPS and ESFAS are independent 12 from PICS.
13 CHAIRMAN BALLINGER: Yes, this is Ron 14 again. It seems like we're, Charlie and I, are kind 15 of beating a dead horse on this, but this is the crux 16 of the analysis after all.
17 MR. CARTE: Yes. And so we talked about, 18 and I guess there was mention of the third. What I 19 initially talked about was the digital communications, 20 which is one way out from TRPS to PICS. I also 21 mentioned the relays interrupting power to the 22 controlled or protection devices, controlled and 23 protection devices, we would say the actuated devices.
24 What was mentioned in the PICS discussion 25 that was a third point was that there is a priority NEAL 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 module in effect that prioritizes the non-safety 2 inputs, and those non-safety inputs, if you examine 3 the logic in TRPS, can only work when there is no 4 manual or automatic safety actuation commanded by the 5 protection system. And in those instances, you can 6 then reset the protective action of the protection 7 system. In other words, basically, the condition 8 requiring the protective action needs to clear, for 9 the most part, before you can reset.
10 MEMBER BROWN: I got that out of the 11 reading of the FSAR and your SER.
12 MR. CARTE: Okay. Thank you. Next slide.
13 So, in essence, the design bases is essentially 14 included in Section 7.3.1, which describes the 15 variables monitored and alarmed, the control 16 functions, the interlocks and permissives that are 17 performed by the PICS system.
18 Next slide, please. And based on the 19 review of the independence aspects of the TRPS from 20 PICS, as well as the detailed analysis by SHINE 21 summarizing the FSAR, PICS equipment failures are all 22 bounded by the analysis summarized in the safety 23 analysis sections of the FSAR. We reached a 24 conclusion that PICS performs its role in providing 25 reasonable assurance of adequate safety.
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33 1 Next slide, please. Are there any 2 questions?
3 MEMBER BROWN: I'm trying to figure it 4 out. I lost track of one of my questions here. This 5 is Charlie again. Hold on for a second. Oh, okay.
6 There was one area, and I understand what the FSAR 7 said, it was in Section 7.3.1.3.11, and this is the 8 target solution vessel protection in ESFAS and its 9 relationship. There were words like safety-related 10 components that are capable of being actuated by the 11 TRPS or ESFAS but also have a non-safety related 12 function related to production achieve their safe 13 state by having power removed. And then the converse 14 of that is safety-related components that are capable 15 of being actuated but do not have a non-safety related 16 production are not controlled directly by PICS, but 17 there is -- the way I read this is, the TRPS does have 18 a non-safety related function and it feeds those 19 functions.
20 Can you explain -- it achieves a safe 21 state as a result of what? A malfunction so that it 22 can't affect the facility functions? You know what 23 I'm talking about?
24 MR. CARTE: A little bit. Let me, I think 25 the way to think about the scheme is a rod control NEAL 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 system. So, basically, in a power reactor, PWR, rod 2 control system, you have non-safety control of the 3 rods, but the safety system removes power and the rods 4 drop, and it goes to a safe state. And it's that same 5 configuration on the TRPS and ESFAS. All of the safe 6 states are achieved by loss of power, so, if you get 7 failures in the TRPS, you remove power, and that 8 includes sensor failures or self-diagnostic failures 9 of equipment, and that's how safety is assured.
10 So, in essence, the non-safety side 11 control is sort of irrelevant. All you're worried 12 about is that the failures are either detected and 13 protected against and/or do not exceed the assumptions 14 in the safety analysis.
15 MEMBER BROWN: Let me -- okay, I got that.
16 I'm looking at how it achieves it functionally. There 17 was another sentence where it said, in other words, it 18 has some connection to some production function, but 19 then it says -- so it's sending information to a 20 production function of some kind. Then it says should 21 a safety actuation be required, the TRPS or ESFAS 22 opens a contact in series with the power supply to 23 whatever component it was interacting with, causing it 24 to achieve its safe state also, regardless of the 25 control signals from the PICS. I read that positively NEAL 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 and that, if you have some production function going 2 on, you get a trip, the TRPS will terminate that 3 function by turning off its power supply via a relay 4 contact.
5 MR. CARTE: Correct.
6 MEMBER BROWN: That's the way I read that 7 sentence, and I don't have a problem with that, at 8 least as long as that reflects satisfaction with 9 whatever production is going on. I mean, SHINE 10 proposed it, so I presume they've looked at that.
11 MR. CARTE: Right. That is correct.
12 MEMBER BROWN: Okay. So I understand 13 what's going on correctly then.
14 MR. CARTE: Right. It's basically, 15 everything follows the pattern of a rod control 16 system.
17 MEMBER BROWN: Okay. I got it. I 18 understand the analogy. Thank you. That's all I had.
19 Ron, I'm done.
20 CHAIRMAN BALLINGER: Okay. Thank you.
21 Are there any other questions from members or 22 consultants on this presentation? Hearing none, now 23 we need to shift topics and go into the phased startup 24 presentation. So I guess SHINE needs to bring up 25 their slides. Who's the presenter?
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36 1 MS. RADEL: Hi, this is Tracy Radel. I'll 2 be presenting on the phased startup.
3 CHAIRMAN BALLINGER: Thanks.
4 MS. RADEL: So here's the outline of what 5 we'll go through today. I'm going to start out with 6 the philosophy around phased startup operations, move 7 into descriptions of each of the phases, and then more 8 specifically into the IF systems, RPF systems, I&C 9 systems, electrical aux, and then finally conclude 10 with the safety analysis aspects.
11 Next slide. So the overall philosophy is 12 to meet the national need for Moly-99 production as 13 soon as possible while also ensuring all requirements 14 related to public health and safety are met. We've 15 proposed phased startup operations to provide 16 flexibility for challenges that we expected to arise 17 during procurement, installation, and testing.
18 The key considerations we had for the way 19 the phases are structured were to ensure that all the 20 design criteria and safety functions were met during 21 all phases. Our goal was to simplify the process 22 boundary isolations, as well as the confinement 23 boundary isolations, and to minimize the impact on 24 operating portions of the facility.
25 I do want to note that our procurement and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 1 installation philosophy was not inherently impacted by 2 phased startup operations approach. SHINE is 3 procuring the equipment for all irradiation units at 4 the same time. No phasing on that. Fabrication for 5 most of the equipment is naturally being done and set 6 for batches because there are eight units' worth of 7 equipment, resulting in a staggered delivery. And as 8 challenges have been encountered in the fabrication 9 process, we have prioritized the phase one equipment.
10 Equipment will be installed as soon as 11 possible after it's received on site. So while the 12 primary focus is on getting phase one equipment 13 installed, we will not hold off installation of 14 equipment for later phases if it is ready to go in and 15 the construction team has bandwidth for installation.
16 Next slide. The phases are described 17 here. So for phase one, the facility structure and 18 nitrogen system structure fully installed, IUs one and 19 two are fully installed, and when I refer to an 20 irradiation unit, or IU, it includes the IU-specific 21 instances of the subcritical assembly systems, the 22 neutron flux detection systems, target solution 23 vessel, off-gas systems, primary cooling systems like 24 water pool system, and radiological ventilation Zone 25 1 equipment located in the cooling room. This NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
38 1 includes both RVZ1r and RVZ1e equipment.
2 For phase one, the tritium purification 3 system train A will be installed, and then the 4 auxiliary and support systems, with the exception of 5 the IU-specific instances of PCLS, LWPS, and RVZ1 6 equipment that were mentioned above. And then the 7 radioisotope production facility systems, with the 8 exception of the iodine and xenon purification and 9 packaging and the radioactive liquid waste 10 mobilization selective removal capabilities.
11 So Figure 1.1-1 of the phased startup 12 supplement provides a visual representation of the 13 phasing showing the physical areas for installation in 14 each phase can be helpful for understanding what's 15 installed for each phase of operation.
16 Next slide. Phase two brings in 17 irradiation units three, four, and five and TPS train 18 B. Phase three brings in irradiation units six, 19 seven, and eight and train C of the TPS equipment, 20 along with the RLWI selective removal capability and 21 the material staging building. Phase four is bringing 22 in the iodine and xenon purification and packaging 23 capability.
24 Next slide. On the irradiation units 25 specifically, they are designed and operated at a unit NEAL 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 level. Each IU has unit-specific instances of ESFAS, 2 NDAS, light water pool, irradiation biological shield; 3 and each IU is supported by a unit-specific instance 4 of PCLS.
5 The support system and process interfaces 6 with the IUs are isolated to support the phased 7 startup operation. Specifically, the auxiliary 8 systems, RPCS, facility nitrogen handling system, 9 facility chemical reagent system, nitrogen system, and 10 radiological ventilation zone include isolations to 11 support the phasing.
12 Next slide. In the tritium purification 13 system trains, the TPS as a whole consists of three 14 independent trains, and each TPS train supports 15 specific NDAS units. These train divisions are 16 supporting the phased operation, so each of these 17 trains includes independent thermal cycling absorption 18 process, or TCAP; the TPS NDAS interface lines; 19 secondary enclosure cleanup systems; vacuum impurity 20 treatment systems; connections to the NDAS secondary 21 enclosure cleanup; and TPS gloveboxes.
22 The tritium confinement boundary for each 23 TPS train is independent and isolated from the other 24 TPS trains, and no portion of the tritium confinement 25 boundary is shared between TPS trains. Isolations 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
40 1 provided at the TPS interface points to facility 2 systems to allow the trains to be connected and 3 commissioned without impacting other TPS train 4 operation.
5 Next slide. On the RPF side of the 6 facility, the RPF systems are installed to support 7 phase one operation, with the exception of the IXP 8 system and selective removal within the RLWI. Note 9 the capability to solidify liquid waste is installed 10 as part of phase one. During phase one through three 11 operations, the IXP system is not installed and the 12 IXP hot cell is exploited from the super cell 13 containment boundary. Connections to the IXP system 14 are isolated during phase one through three.
15 The capability of the RLWI system to 16 remove the classification driving isotopes is not 17 available during phase one and phase two operation.
18 During phase one and phase two, liquid waste is stored 19 in the subgrade. We do not anticipate having to 20 solidify liquid waste prior to phase three operation 21 due to the capacity of the storage within the RLWS.
22 Waste solidifying during phase one and phase two may 23 be higher dose and higher waste classification than 24 waste solidified during phase three or four.
25 Solidified liquid waste would be stored 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
41 1 portholes prior to shipment to disposal site.
2 Next slide. During phased startup 3 operations, the instrument and control systems are 4 installed to the extent practicable, given the extent 5 of equipment installation. IU-specific instances of 6 the TPS reactivity protection system are brought 7 online with the associated IUs and the applicable 8 phases.
9 There are nine TRPS cabinets installed in 10 the facility control room. All cabinets will be 11 installed prior to phase one operations. Those 12 cabinets are divided in the following way: So the 13 first three cabinets are the division A, B, and C for 14 IUs 1 and 2. The second set of three cabinets are 15 division A, B, and C for IUs 3, 4, and 5. And the 16 final set of three are the Division A, B, and C 17 cabinets for IUs 6, 7, and 8. So the division amongst 18 the TRPS cabinets does support phased startup 19 operations.
20 The engineering safety feature actuation 21 system is installed to support phase one operations.
22 We did implement a new capability to disable the 23 inputs that are not used during later phases. These 24 disabled inputs are restored and verified to be 25 operable prior to entering the technical NEAL 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 specifications mode of applicability associated with 2 the given input. Disabled inputs are listed in Table 3 7.5-1 of the supplement, and the safety functions not 4 utilized during particular phases are listed in Table 5 7.5-2 of the supplement.
6 MEMBER BROWN: This is Charlie Brown. Can 7 I ask you a question relative to the last bullet?
8 MS. RADEL: Yes.
9 MEMBER BROWN: I understand what you've 10 just gone through, but the ESFAS is an overall 11 facility piece of equipment, not like the TRPS which 12 is identified with each IU. And I'm only bringing 13 this up because of past experience of doing things 14 piecemeal in my Navy programs when we were building 15 submarines or aircraft carriers.
16 Your ESFAS is going to have all functions.
17 You talked about disabling outputs. It's not just 18 outputs, it's also inputs that you have to be careful 19 of, depending on how they're used in the software.
20 I've been there and done that and you've got to be --
21 all I'm doing is providing a little unneeded advice 22 probably. It's just very difficult to ensure you 23 don't have some stray piece of information come in and 24 all of a sudden gum up the works.
25 I'm not disagreeing with the approach NEAL 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 you're taking. I totally agree with the phased 2 approach. It's just a matter of, for an overall total 3 facility system, which has all that information 4 already built into the software, you're not going to 5 be piecemealing that software. It should be complete 6 when you start at the very beginning, and I've taken 7 that's correct based on what you've just said. I'm 8 just --
9 MS. RADEL: Just to clarify, the disable 10 function is for the inputs into the system and is done 11 through the maintenance workstation and verification 12 of those inputs being disabled for a particular phase 13 or enabled to support a particular phase.
14 MEMBER BROWN: I got that, but you've also 15 got outputs.
16 MS. RADEL: Yes, so that is the --
17 MEMBER BROWN: You can't ignore that.
18 MS. RADEL: So that's the safety function, 19 you know, the safety functions that wouldn't be 20 actuating during particular phases. Those are very 21 limited within the ESFAS.
22 MEMBER BROWN: Okay. I'm just, before you 23 start lighting off the first three, you've just got to 24 make sure those outputs are truly not going to affect 25 anything, that's all, so that you don't mess up 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
44 1 systems that you are actuating. I'm just a 2 grandfather offering advice.
3 MS. RADEL: I appreciate the advice.
4 Thank you.
5 MEMBER BROWN: Okay. Thank you.
6 MS. RADEL: Okay. The IU-specific 7 instances of the neutron flux detection system are 8 brought online with the associated IU. The safety-9 related process radiation monitors are installed, to 10 the extent practical, given the extent of equipment 11 installation. There are safety-related process 12 radiation monitors associated with the individual IUs, 13 as well as the TPS trains, and those are installed as 14 that equipment is brought online.
15 Safety-related process radiation monitors 16 associated with the IXP cell are installed prior to 17 phase four operations. Table 7.7-1 provides a 18 detailed listing of the radiation monitor phasing.
19 Process integrated control system hardware 20 is installed prior to phase one operations, with the 21 exception of hardware associated with TPS trains B and 22 C. PICS monitoring and controls associated with 23 equipment that's not yet installed or not yet operable 24 to support phase one are tested and placed into 25 operation as required for the given phase.
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45 1 Next slide.
2 MR. SCHULTZ: Tracy?
3 MS. RADEL: Yes.
4 MR. SCHULTZ: This is Steve Schultz.
5 There are non-safety related radiation monitors 6 associated with the PICS system. The PICS system 7 reads them. Are they going to be installed? What is 8 the schedule for --
9 MS. RADEL: All of the non-safety related 10 radiation monitors, yes, are installed as part of 11 phase one.
12 MR. SCHULTZ: I'm sorry. I didn't catch 13 the last part of the response.
14 MS. RADEL: Sorry. Yes, the non-safety 15 related radiation monitors are all installed as part 16 of phase one.
17 MR. SCHULTZ: Great. Thank you.
18 MS. RADEL: Next slide. The normal 19 electrical power supply system, or NPSS, and the 20 uninterruptible electrical power supply system, UPSS, 21 are installed in full to support phase one operations.
22 Loads on the NPSS and UPSS that are not yet installed 23 or not yet operable have the associated isolation 24 device removed or placed into an out-of-service 25 condition. Cabling associated with equipment not yet NEAL 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 installed is installed to the extent practical with 2 the power removed at the associated panel or load.
3 The non-safety related standby generator 4 system is also installed to support phase one 5 operations.
6 MR. BLEY: Tracy, Dennis Bley. Do you 7 anticipate -- well, I guess you've already told us 8 this. Never mind. I was wondering about the amount 9 of unconnected cable that's going to be there, but it 10 really doesn't matter. It will be from the source to 11 where the equipment will eventually be installed for 12 the most part?
13 MS. RADEL: The cabling and panels will be 14 installed out to the remote panels as part of phase 15 one and then --
16 MR. BLEY: And that includes the remote 17 panels?
18 MS. RADEL: Yes, it includes the remote 19 panels. And then the cabling beyond that will be 20 installed depending on equipment installed.
21 MEMBER BROWN: Okay. Along with the final 22 connection back to the power supply?
23 MS. RADEL: Yes. Auxiliary systems. The 24 RVZ1 recirculating subsystems. Our RVZ1r units 25 support individual IU cells and are installed 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
47 1 corresponding IU. A portion of the RVZ1e subsystem is 2 also installed with the corresponding IU that is the 3 portion of the system that is located within the 4 cooling rooms.
5 Supply lines from auxiliary systems that 6 are supplying each of the irradiation units have 7 manual isolation valves and blank flanges or caps to 8 support phased startup operations. And because of 9 normal variation and flexibility in facility 10 operations, the auxiliary systems are designed to 11 handle the variable loads without any modifications.
12 Next slide. For the accident analysis, a 13 hazard evaluation was performed to identify new or 14 different accident scenarios, including changes to 15 likelihood or consequence of existing accident 16 scenarios. The likelihood and consequence for these 17 new or different accident scenarios were then 18 evaluated and compared to the risk matrix and safety-19 related controls were applied to prevent or mitigate 20 the accident scenarios in the method that was 21 consistent with what's described in Chapter 13(a)(2) 22 of the FSAR.
23 No new accident categories were identified 24 as part of phased startup operations. And no 25 increases to the consequences of existing accident NEAL 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 scenarios covered in Chapter 13 of the FSAR were 2 identified.
3 There were five new accident sequences 4 within the existing accident categories that were 5 identified and five existing accident scenarios were 6 re-evaluated for increased likelihoods. Four new 7 credited entry controls and three new credited 8 administrative controls were added during phased 9 startup operations to prevent the new or different 10 accident scenarios.
11 And this is the final slide of my 12 presentation. Any questions?
13 MEMBER SUNSERI: Tracy, this is Matt 14 Sunseri. I've got a question for you. All these 15 physical analysis controls seem pretty thought out to 16 me. Can you speak a little bit towards the controls 17 that you will have in place for personnel access, 18 construction personnel access, operations personnel 19 access, such that, for a lack of better word, I'll use 20 the term unauthorized individuals aren't exposed to 21 radioactive material or radiation and that the 22 construction workers don't impede operators from 23 getting where they need to be to operate the plant?
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49 1 place such that they won't drift from their 2 construction activities and work on operational 3 equipment? That's a long one, but it's kind of the 4 administrative controls that you're going to have.
5 MS. KOLB: Yes, this is Catherine Kolb.
6 I'll respond to that question. So SHINE will 7 implement our physical security plan, our radiation 8 protection program, which includes access control to 9 the facility. So if workers, construction workers, 10 need to have regular access to the facility, they'll 11 be badged and trained as rad workers if they need to 12 to be able to access their normal work locations or 13 else, per the provisions of the plan, they will be 14 escorted by people who are trained and authorized, and 15 we intend to fully implement those two plans.
16 The other question about oversight of 17 construction activities, once the facility has its 18 operating license for phase one, we would expect and 19 have processes in place for people doing work for the 20 facility to check in with the control room as if we 21 were doing normal maintenance for the facility so that 22 the operators are cognizant of large activities that 23 are going on in the facility.
24 I know we don't have the general 25 arrangement drawing in the presentation, but it is 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
50 1 the phase supplements. And you will notice that most 2 of the activity is localized to the specific radiation 3 unit cells that would be worked on during the phased 4 approach, so we would not expect, you know, large 5 construction activities to be taking place, you know, 6 like throughout the facilities. So it should be, we 7 are expected to be able to coordinate that during the 8 phased approach installation activities.
9 MEMBER SUNSERI: Okay. That sounds 10 reasonable to me. I was just thinking about when we 11 talked through the plant a few weeks ago there was a 12 couple of places, and I just remember one and I 13 probably will get the equipment mixed, but I think the 14 irradiation units were on one side and the tritium 15 purification was on the other side of the hall in this 16 real long hall, so I can imagine that might get pretty 17 busy in there when you're operating half of it and 18 working on the other half. Thanks.
19 MS. KOLB: Yes. I understand your point 20 there, and your recollection is correct on the 21 arrangement of the facility. You know, we intend to 22 install everything that we can to the extent practical 23 to minimize that, but, yes, we're just intending to 24 implement the processes and procedures as we have 25 described them.
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51 1 MEMBER SUNSERI: Thank you.
2 MS. RADEL: Any other questions? Okay.
3 Thank you.
4 CHAIRMAN BALLINGER: Hearing none, thank 5 you very much. I think we would sort of be scheduled 6 for a break around now, say at 11, if we were to go 7 that far, but we only have one more presentation to go 8 and then discussion. So why don't we go with this 9 presentation, and then, if we think discussions are 10 going to take a longer time, we'll have a break before 11 that.
12 So unless I hear an objection from 13 members, let's go with the NRC presentation. Thank 14 you.
15 MR. BALAZIK: Can everybody hear me okay?
16 CHAIRMAN BALLINGER: I can hear you fine.
17 MR. BALAZIK: Perfect. Thank you. Good 18 morning. My name is Michael Balazik. I'm the NRC 19 project manager for SHINE in the Office of Nuclear 20 Reactor Regulation within the Division of Advanced 21 Reactors and Non-Power Production and Utilization 22 Facilities. And this morning, I'll be presenting the 23 staff's review of the phased approach to startup.
24 Next slide, please. Okay. So the 25 regulatory requirements that the staff applied to this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 1 portion of the review were 50.34, contents of 2 applications and technical information; 50.40, common 3 standards; and probably the most important one, 50.57, 4 the issuance of operating license.
5 Next slide, please. Guidance hasn't 6 changed. We pretty much use the standard guidance 7 we've been using for this entire review. NUREG-1537 8 and the final Interim Staff Guidance for licensing of 9 radioisotope production facilities.
10 Next slide, please. All right. So, 11 quickly, I'll just go over a summary of the 12 application. Tracy provided a lot more detail than I 13 would. Back in January of this year, SHINE did 14 supplement the SR-described four-phase approach to 15 startup operations. This phased approach is staggered 16 over a couple of years and planned to be completed in 17 the 2025 time frame.
18 So within the supplement, SHINE describes 19 the impacts, the technical impacts, along with 20 information differences for each chapter of what I'll 21 call the full design facility FSAR. Within the 22 supplement, SHINE identifies equipment isolation 23 points and the isolation methods for each phase for 24 the different equipment.
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53 1 impacted by this phased approach to startup were 2 Chapter 4, Chapter 7, Chapter 9, and 13.
3 Next slide, please. All right. Just 4 continuing on with a summary of the application. Back 5 in February of this year when we provided an overview 6 to ACRS full committee on the SHINE review, we did 7 talk about this phased approach to startup. And I 8 remember one member saying that, you know, this is 9 kind of analogous to plug and play. I can't remember 10 if he said that, but that's, you know, pretty much our 11 look on a majority of these items.
12 So the irradiation units, they're designed 13 and operated as independent units. The TPS, which 14 consists of three independent trains to support the IU 15 operation, so TPS train Alpha will support phase one, 16 and trains Bravo and Charlie, they'll support the 17 operation of the subsequent phases.
18 With the exception of the iodine and xenon 19 purification and packaging system and the radioactive 20 liquid waste isolation, all systems for the production 21 facility will be installed to support phase one 22 operations. And for instrument and control for TRPS, 23 it's IU-specific, and some of the inputs for the 24 ESFAS, which Member Brown was talking about, is an 25 entire facility system and, along with PICS, some 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
54 1 those inputs are disabled and brought on as the phases 2 come in.
3 And discussing Chapter 13, there were five 4 new accident sequences that were identified and five 5 existing sequences that had an increase in likelihood.
6 The new accident sequences were improper target 7 solution routing, damage to a TPS train, damage to the 8 process vessel vent system, Talk's interface, and back 9 flow of target solution to the IXP.
10 And the likelihood increase that was 11 evaluated by SHINE, there were heavy load drops on the 12 TPS, heavy load drops on an operating irradiation unit 13 or Talk cell, and a heavy load drop on the radioactive 14 liquid waste isolation enclosure super cell. And 15 then, of course, as the phases go in, as construction 16 is continued, you know, there's an increase in the 17 fire, the irradiation facility or the radioisotope 18 production facility.
19 Next slide, please. So how we started our 20 approach to this review is that we wanted the exact 21 same staff members to review the phased startup 22 approach that reviewed the full design. So for our 23 technical and safety review, the NRC staff reviewed 24 the information, the SHINE supplement, against 25 regulatory requirements, regulatory guidance 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
55 1 acceptance criteria, that I discussed earlier. Staff 2 evaluated the effect of the phased approach of startup 3 on the sufficiency of the facility descriptions, 4 design basis, facility operation, and SSCs, and as the 5 facility as a whole. And we also reviewed the kinds 6 and quantities of radioactive material expected to be 7 produced in the operation of the SHINE facility and 8 the means for controlling and limiting radioactive 9 exposures within 10 CFR Part 20.
10 We also reviewed the methods and 11 sufficiency of system level isolations for the 12 different phases just to ensure safe operation of 13 facility and health and safety of the workers and 14 public.
15 Next slide, please. Okay. We did perform 16 an audit. Right now, we're just finishing, just some 17 final touches on that is in draft form right now. We 18 can share that with members if requested. We're 19 hoping to have that issued here very soon.
20 I'll say that, early on in our review, we 21 had some areas of perceived risk significance in some 22 of those areas where the human system interfaces and 23 training of operators, because there will be a lot 24 going on in these different phases, that we wanted to 25 make sure, like the operators, you know, 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
56 1 minimal distractions to them while operating the 2 facility.
3 Tracy and Charlie discussed this earlier 4 on disabling and enabling instrumentation and control 5 inputs. Also, with construction, there will be 6 increased clean operations with heavy loads during 7 operation and also on radiological dose to workers on 8 completing construction. And what we looked at is if 9 there was a construction going on in an adjacent IU 10 cell, you know, what would those doses look like to 11 that individual in there.
12 Next slide, please. So 10 CFR 50.57, 13 which is issuance of operating license, it requires 14 that each license issued by the Commission to include 15 appropriate provisions with respect to uncompleted 16 items of constructions required to ensure that the 17 operation during the period of the completion of such 18 items will not endanger public health and safety. So 19 in their response to an RAI, SHINE did provide phased 20 specific listing of installation and functional 21 testing that was needed to support each phase of the 22 operation. And the staff is imposing a license 23 condition to ensure that the operation of these 24 subsequent phases will not commence until the 25 uncompleted items are completed and that NRC oversight NEAL 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 of completion of these uncompleted items is 2 maintained.
3 So next slide, please, is the actual 4 license condition that we're proposing. The first 5 part of this just points to the supplement submitted 6 by SHINE, and then the two conditions below talk 7 about, you know, 14 days prior to planned commencement 8 of operation of the next phase, that SHINE has to 9 notify the NRC in writing that all uncompleted items 10 of construction have been completed. And item B there 11 talks about SHINE providing updates to the NRC after 12 issuance of the operating license, which, you know, 13 would authorize phase one. Every six months, SHINE 14 needs to provide the NRC an update on the information 15 and the status of the schedule for completion of 16 uncompleted items of construction. And we could use 17 this information to inform our oversight inspection 18 activities for SHINE.
19 And last slide here, these are evaluations 20 and conclusions that SHINE did describe the design of 21 the systems and identified major features or 22 components affected by the proposed phase approach to 23 startup, also that the process is performed; operating 24 procedures and equipment; use of the facility; provide 25 reasonable assurance that they'll comply with Part 50 NEAL 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 Part 20 regulations and that the health and safety 2 of the public will be protected during the phased 3 approach to startup; and, 50.40, the issuance of the 4 operator license will not be inimical to the common 5 defense and security of health and safety of the 6 public and that the descriptions and discussions of 7 the SHINE systems affected by the approach are 8 sufficient to meet the applicable regulatory 9 requirements and acceptance criteria for issuance of 10 an operating license.
11 That's my last slide. Are there any 12 questions?
13 MEMBER HALNON: Yes, Michael. This is 14 Greg Halnon. Do you guys have a plan for how you're 15 going to do the oversight during this time frame?
16 There was some discussion whether Region III would be 17 doing it or Region II. Since you'll have operation 18 and construction going on at the same time, will there 19 be different oversight centers or --
20 MR. BALAZIK: Yes, Member Halnon. Right 21 now, Region II is the lead for the construction 22 activities at SHINE. Once we get into that pre-23 operational readiness, there's a combination of Region 24 II oversight activities and NRR oversight activities.
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59 1 readiness.
2 Now, for these parts of construction, we 3 haven't figured out exactly who would have the lead on 4 these inspection activities and what the inspection 5 activities look at this time. So I can't give you a 6 definite answer who is going to have the lead on this.
7 MEMBER HALNON: Okay. I think, as you go 8 forward and figure that out, we'd be interested in at 9 least seeing the documents or some kind of plan. I'm 10 not sure that the Operations Subcommittee wants a 11 full-blown meeting or anything, but let's stay in 12 touch and, when you get that set, communicate it with 13 me.
14 MR. BALAZIK: Yes, sir. I got it.
15 Appreciate it. Any other questions?
16 CHAIRMAN BALLINGER: This is Ron 17 Ballinger. With respect to that request, do you 18 anticipate the timing for that?
19 MR. BALAZIK: I think that would be based 20 on SHINE providing us the information when they would 21 be, you know, ready to move to the next phase. But --
22 CHAIRMAN BALLINGER: Okay. So that's long 23 after, long after we're done with the letter, right?
24 MR. BALAZIK: Long is a relative term. I 25 don't know if SHINE wants to chime in on their planned NEAL 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 schedule.
2 MS. RADEL: Yes, so this is Tracy Radel.
3 We're approximately a year or so out from substantial 4 completion, roughly, as far as receipt of the 5 operating license, you know, subsequent to that.
6 CHAIRMAN BALLINGER: I would consider that 7 long compared to December.
8 MR. BALAZIK: Yes, sir, I do agree with 9 that. Thank you, Tracy.
10 CHAIRMAN BALLINGER: Okay. So absent 11 further questions by members or consultants, we need 12 to now ask for public comment. If you are a member of 13 the public and you're listening and would like to make 14 a comment, please state your name and make your 15 comment, reminding, I think, that if you're on the 16 phone you have to use the star 6 procedure to get 17 access.
18 So are there members of the public out 19 there that would like to make a comment? Apparently 20 none.
21 Okay. So we are, more or less, at the end 22 of the presentations. I don't think we need a closed 23 session, so now I think we need to just open up the 24 discussion for any other comments or discussion points 25 that members would like to deal with. Deafening NEAL 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 silence. Okay.
2 MEMBER DIMITRIJEVIC: Ron, this is Vesna.
3 CHAIRMAN BALLINGER: Vesna, how are you?
4 MEMBER DIMITRIJEVIC: Good. How are you 5 doing?
6 CHAIRMAN BALLINGER: Your name is not on 7 this list for some reason.
8 MEMBER DIMITRIJEVIC: I don't know why.
9 I can see my name on the list.
10 CHAIRMAN BALLINGER: Okay, all right.
11 MEMBER DIMITRIJEVIC: I was thinking maybe 12 we can devote some short time on just discussing how 13 can we help you in writing this letter and do you have 14 some structure in mind, you know, so that we can get 15 ready for writing --
16 CHAIRMAN BALLINGER: Yes. I sent a note 17 out to the members probably late last night. The way 18 I see it, we now have, with the exception of two of 19 the memos, all of the memos may have ML numbers, and 20 so those are available. And my plan is to use those 21 memos as not only the starting point but the major 22 input for the letter and any other comments, which 23 I've asked people for -- from time to time, members 24 have sent paragraphs or such and such to me related to 25 what might be in the letter. Like I said last night, NEAL 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 there are various vintages. So if there are members 2 that have additional comments or issues related to 3 what might be in the letter, then I'd appreciate those 4 because, come next week or starting this weekend, I'll 5 be putting together the draft letter.
6 Now, the format will be, unless I hear 7 something different, there are no showstoppers, no 8 buts, that would be in the letter that would require 9 response from the staff, I don't think. And so the 10 front-end of the letter, we already have some of that, 11 some of the background that we've seen before. And so 12 then the conclusion will be quite simple in words we 13 approve and then some minimal discussion that hits the 14 high points and then a referral because all of the 15 memos will be attached to the final letter. So what 16 it amounts to is a summary up-front and then the 17 detailed references also included in the letter.
18 So that's the general format, and I'd 19 appreciate comments from members related to that 20 because I'm going to start doing it tomorrow.
21 MEMBER DIMITRIJEVIC: So this was one of 22 my, actually, curiosities. Every writer has, you 23 know, comments or suggestions or conclusions in the 24 front. You don't plan to put those in the final 25 letter, you're just going to reference other letters?
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63 1 CHAIRMAN BALLINGER: No, no, I'm sorry.
2 I guess I wasn't detailed enough. There will be a 3 section after the results and the conclusions and 4 recommendation for sort of, I guess I would call it 5 general comments, I'm not sure I'd want to use the 6 word suggestions, that would contain the kinds of 7 things that we've had discussions of at the various 8 subcommittee meetings, and that's where input, the 9 little paragraphs and the like that we've asked people 10 to provide, would be very important.
11 So, yes, there will be, you know, again, 12 since we don't anticipate, at least right now, any 13 what I call showstoppers, the buts, that's just a for 14 information section, in effect.
15 MEMBER DIMITRIJEVIC: Yes. You know, I 16 was just thinking that these comments we have provided 17 throughout the sessions, some of them are different 18 types, you know. Like, for example, some are 19 suggestions, something we would like to see later, you 20 know. For example, Charlie had the comments on the 21 electrical system, which he asked for the, you know, 22 the changes. So I was sort of wondering because we're 23 having these different type of comments --
24 CHAIRMAN BALLINGER: Yes, we'll have to 25 reconcile --
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64 1 MEMBER DIMITRIJEVIC: -- define the 2 categories. I wasn't sure what's the best way to 3 organize them, you know.
4 CHAIRMAN BALLINGER: I'm sure that, during 5 our discussions of the draft, we'll get that all 6 reconciled.
7 MEMBER DIMITRIJEVIC: All right, okay. So 8 then next --
9 CHAIRMAN BALLINGER: We got to have a 10 strawman to shoot at first.
11 MEMBER MARCH-LEUBA: This is Jose. The 12 way I envisioned it was we would have all the memos, 13 the full memos, in the appendices.
14 CHAIRMAN BALLINGER: Yes, yes.
15 MEMBER MARCH-LEUBA: Any comments, any 16 recommendations, any conclusions that you would like 17 to see on the main body of the letter, on the area 18 responsible for the memo, it would be convenient for 19 Ron if you write two or three paragraphs that you'd 20 ask him to say this is the summary of what the memo 21 says that I think merits inclusion in the body of the 22 letter.
23 CHAIRMAN BALLINGER: Yes, that's, you 24 know, we've asked that question quite a few times and 25 asked for input, and we've gotten some input. 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
65 1 we'll ask it again, yes. That would be very, very 2 helpful because, other than that, I will use the memos 3 themselves, which also contain these kinds of 4 comments. But it would be a lot easier if, now that 5 we've had the complete set of presentations, where, if 6 a member would like to provide a paragraph or so, that 7 would be very helpful. That's my story and I'm 8 sticking to it.
9 MEMBER BROWN: I had one question, Ron.
10 Is this meeting on the, whatever day it is, the 15th, 11 is that an in-person meeting, or are we going to be 12 trying to do this all day by virtual?
13 MEMBER REMPE: No, it's in person. We 14 decided that several months ago. Of course, if 15 someone wants to, they can still stay and do it 16 remotely, but there will be some folks in the room is 17 what we decided.
18 MEMBER BROWN: Okay. I was just trying to 19 confirm that that week was going to be an in-person 20 week. I wasn't at the meeting so --
21 CHAIRMAN BALLINGER: Yes, I think the 22 invitation was just sent out for anybody that wants to 23 do remote, but yes.
24 MEMBER BROWN: Yes, okay. That's all I 25 had.
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66 1 MEMBER HALNON: So, Ron, this is Greg.
2 Now I can kind of understand why you asked me to 3 revise one of the memos.
4 CHAIRMAN BALLINGER: Oh, wait a minute, 5 hold on a minute. Revising the memos, no, please.
6 MEMBER HALNON: Well, I mean, it's not the 7 actual issues, it's what we expected for the follow-8 up. If we don't, you know, sometimes time heals some 9 of these comments and then --
10 CHAIRMAN BALLINGER: Right, yes.
11 MEMBER HALNON: -- come up that don't 12 really warrant anymore time being spent on it.
13 CHAIRMAN BALLINGER: Yes, yes.
14 MEMBER HALNON: I assume you'd like to 15 make sure the memos are up to date from the standpoint 16 of what we want follow-up and what we don't, kind of 17 to Vesna's question, what --
18 CHAIRMAN BALLINGER: Well, I think now I'd 19 have to ask Larry or Chris about this. I think those 20 memos now have ML numbers, and so those are kind of in 21 violet unless something else, unless we can -- I don't 22 know what we would do if somebody wants to change a 23 memo.
24 MEMBER REMPE: This is Joy. I mean, Larry 25 and Chris can give you ultimate, but I would say 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
67 1 no, those were a snapshot in time, and perhaps the 2 letter can say these were a snapshot in time and 3 these, you know, this letter has our final comments 4 that we want to mention about this review.
5 CHAIRMAN BALLINGER: Yes, that's --
6 MEMBER REMPE: I think that's what we've 7 done in the past.
8 CHAIRMAN BALLINGER: -- you know, the sort 9 of one- or two-paragraph vehicle is a way to do that.
10 MEMBER HALNON: Okay. And that was where 11 I was going with it. So in a paragraph, that should 12 be the endpoint. I mean, that's finally where our 13 mind is at relative to any issues that we have, both 14 specific and general.
15 CHAIRMAN BALLINGER: Yes. A lot of these 16 chapters are sort of interwoven, if you will, and so 17 it's entirely appropriate to have a different outlook 18 once you've heard them all.
19 MEMBER HALNON: Okay. And --
20 MEMBER DIMITRIJEVIC: So, Ron, when you 21 said now, we definitely don't have showstoppers, but 22 if there's suggestions for the changes in the chapter, 23 like Charlie did on electrical, then what's happening 24 with those?
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68 1 suggestions, again, I need to make sure I'm not 2 violating a rule, if they're suggestions, the 3 applicant can either say, okay, we'll do that or, no, 4 we won't do that. That will be at the staff's or the 5 applicant's discretion. People can correct me if I'm 6 wrong.
7 MEMBER REMPE: Well, I would point out 8 that we only provide suggestions to the staff, right?
9 CHAIRMAN BALLINGER: Yes, yes.
10 MEMBER REMPE: I mean, we can make 11 comments to the applicant, but our charter is to help 12 the staff review.
13 CHAIRMAN BALLINGER: Yes, yes, yes.
14 MEMBER BROWN: If there's anything we want 15 a response from the staff for, we ought to say it in 16 your memo, not in one of the enclosures. It ought to 17 be brought up to the memo and we ask for a staff 18 response to our memo; that's all.
19 CHAIRMAN BALLINGER: And I think that 20 actually has happened for many of them.
21 MEMBER BROWN: Yes, that's the way we've 22 done all of our letters, so we sent a letter out, a 23 report, and we ask for a response or we don't. If we 24 want a response, then we get it. And if we've got 25 suggestions, we ask for a response.
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69 1 CHAIRMAN BALLINGER: Yes, yes.
2 MEMBER BROWN: This is not complicated.
3 CHAIRMAN BALLINGER: No, hopefully.
4 MEMBER HALNON: And the purpose of the 5 final memo is to give the Commission our overall 6 impression of the license application; is that 7 correct?
8 MEMBER REMPE: That's true, except it's a 9 letter, it's not a memo.
10 CHAIRMAN BALLINGER: It's a letter, it's 11 a letter.
12 MEMBER BROWN: It's a letter report.
13 MEMBER HALNON: Yes, that's words. But 14 the letter report.
15 MEMBER BROWN: It's a regular letter 16 report.
17 MEMBER HALNON: Yes, okay.
18 MEMBER REMPE: But I'm bean-counting 19 memos, Ron. You've said we've had all but a couple.
20 I know they're posted out there, but we're going go 21 actually go through how many? Isn't it like going to 22 be four or five, depending on what's happening with 23 this space --
24 CHAIRMAN BALLINGER: No, two or three.
25 MR. BROWN: Four. Four memos are left:
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70 1 cyber, life cycle, I&C, and help me, Jose. Oh, tech 2 specs, tech specs.
3 CHAIRMAN BALLINGER: Yes.
4 MEMBER REMPE: Isn't there a Chapter 7 5 also or something?
6 MR. BROWN: Yes, I&C. That's four.
7 CHAIRMAN BALLINGER: Yes. And there's 8 potentially a fifth, but I haven't decided, and that 9 is related to the phase approach. I waited until 10 after the presentations, and I'm going to think about 11 that a little bit, and it would be nice to hear from 12 the members on this. I'm leaning towards not having 13 a separate memo on the phased approach but including 14 discussion in what we would call the preamble and some 15 of the discussion in the letter because, in effect, 16 what the phased approach is is just a different method 17 of construction. Maybe I'm reading things wrong, but 18 it would be nice to hear from other members on what 19 their opinion would be.
20 MEMBER HALNON: It's not all that 21 different than what's going on in Vogtle or any other 22 multi-unit plant, so I don't see anything special 23 about it. It's just a matter of making sure that they 24 complied.
25 CHAIRMAN BALLINGER: Yes, yes, that's 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
71 1 I'm coming down to, but there are other opinions 2 probably. Oh, Scott Moore. Scott, you've raised your 3 hand.
4 MR. MOORE: Yes, Chairman Ballinger.
5 Previously, the staff had asked for the Committee's 6 final report on SHINE by the end of December. Are 7 they still looking for the report on that same time 8 line?
9 CHAIRMAN BALLINGER: I haven't heard 10 anything different, but we have an informal after this 11 meeting, and I'm sure we can confirm that. But I 12 think, Josh or Michael, can you confirm that?
13 MR. BORROMEO: That seems like a 14 reasonable time, but we can discuss if there's 15 resource issues at our informal afterwards.
16 MEMBER REMPE: This is Joy. And what 17 would be a reason for us to delay? We've gotten all 18 the information we need, and we have planned our 19 schedule, and so I wouldn't, even if the staff 20 decides, well, we can wait until, it would be February 21 if we don't do it in December because January we don't 22 have a full Committee meeting. So is there a reason 23 that we wouldn't want to try and meet that deadline, 24 Scott?
25 MR. MOORE: No, and I wasn't suggesting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
72 1 that. The only -- I just wanted to confirm that that 2 is when the staff needed the final report. And the 3 only reason I'd say that the Committee should delay 4 would be if there's new information or if the staff 5 hasn't responded to anything yet, and I'm not aware of 6 any of that.
7 CHAIRMAN BALLINGER: Right. So unless 8 death or plague occurs, December is it.
9 MEMBER REMPE: You know, with all the 10 pandemic stuff, don't say plague.
11 CHAIRMAN BALLINGER: I didn't say 12 pandemic. I said plague.
13 (Laughter.)
14 MEMBER REMPE: Never mind.
15 CHAIRMAN BALLINGER: Okay. So we've had 16 our discussion. Once again, I'd like to thank the 17 staff and the applicant and our staff actually for 18 seeing this through, and we're approaching the end, 19 and I'm looking forward with some fear and trepidation 20 to the November meeting where we have a discussion.
21 So if there aren't any further questions, 22 I think we need to close off this meeting. But, 23 Chris, should you and I and --
24 MR. BROWN: I have a separate invite.
25 Check 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
73 1 CHAIRMAN BALLINGER: Oh, it's a separate 2 invite. Okay.
3 MR. BROWN: Yes.
4 CHAIRMAN BALLINGER: All right. We're 5 good.
6 MR. BURKHART: Hey, Ron, this is Larry.
7 Do you want to have an opportunity for public comment?
8 CHAIRMAN BALLINGER: Did that.
9 MR. BURKHART: Okay, all right. Sorry.
10 CHAIRMAN BALLINGER: Did that and didn't 11 hear anything. Okay. So thanks again everybody, and 12 we'll see Josh and whoever in a few minutes.
13 (Whereupon, the above-entitled matter went 14 off the record at 11:16 a.m.)
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
Process Integrated Control System (PICS)
RYAN MYERS, I&C ENGINEER
© SHINE
© SHINE Technologies, Technologies, LLC LLC 1
Outline PICS Overview PICS Network Architecture and Security PICS Interfaces with Safety-Related Systems PICS Vendor-Provided Nonsafety-Related Control System Interfaces PICS Workstations and Network Access
© SHINE Technologies, LLC 2
PICS Overview
© SHINE Technologies, LLC 3
PICS Overview PICS is a nonsafety-related digital control system whose principal functions are to control and monitor facility systems and components within the irradiation facility (IF) and radioisotope production facility (RPF).
A portion of the PICS supports the main control board (MCB) and operator workstations in the facility control room (FCR) by receiving operator commands and collecting and transmitting facility information to the operators.
The PICS system network routes signals to the main distribution switch located in the server room.
Information from the FCR, remote input/output (RIO) cabinets, remote human machine interface (HMI) panels, programmable logic controllers (PLCs), vendor-provided control systems, and virtual machines communicate through the main distribution switch with a combination of copper and fiber optic cabling.
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PICS Network Architecture and Security PICS has no connection to the internet and no Wi-Fi capable devices.
The PICS manufacturing control network (MCN) is segregated from the SHINE business network.
The PICS PLC communications on the MCN is split into 10 separate virtual local area networks (VLANs), one for each of the 10 PICS PLCs.
PICS cabinets are locked requiring a key administratively controlled by Operations personnel.
PICS server room which houses the PICS ControlLogix PLCs and servers, has restricted access.
Unused ports (e.g., Ethernet, USB) are physically blocked or electronically disabled.
o The port keys are controlled by Operations personnel.
Ethernet/IP with CIP (common industrial protocol) is the communication protocol used for communication between the PICS PLCs, RIO racks, servers, workstations, and thin clients.
o CIP is widely used to secure plant networks.
Electronic access to PICS is not available from outside the site.
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PICS Interfaces with Safety-Related Systems The target solution vessel reactivity protection system (TRPS) and engineered safety features actuation system (ESFAS) provide signals to PICS via a one-way isolated nonsafety-related Modbus gateway.
PICS normally has manual electrically isolated control of TRPS/ESFAS controlled components.
PICS provides valve and damper position indication to TRPS/ESFAS for verification of completion of protective function through electrically isolated relay outputs.
PICS provides mode transition signals to TRPS, when manually initiated by the operator.
PICS provides signals to TRPS/ESFAS to reposition components, when manually initiated by the operator and the main control board enable nonsafety switch is in the enable position.
Both the mode transition and reposition request signals from PICS are encoded using a bitstream method with a pattern of discrete relay outputs that are then translated by TRPS/ESFAS.
PICS is designed so that its failures cannot directly or indirectly impact the ability of the TRPS or ESFAS to perform its safety functions.
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PICS Vendor-Provided Nonsafety-Related Control System Interfaces PICS interfaces with several vendor-provided nonsafety-related control systems which consist of the neutron driver assembly system (NDAS) controls, supercell controls, and various auxiliary control systems.
There are no internet connected or Wi-Fi enabled devices for the vendor-provided equipment.
Like PICS, the vendor-provided nonsafety-related control systems do not allow remote access and include the capability to disable unneeded networks, communication ports, and removable media drives, or provide engineered barriers.
Vendor-provided nonsafety-related control systems communicate with PICS via Ethernet, Modbus, or other industry standard digital communication protocols.
Many of the PICS vendor equipment interfaces communicate with CIP over Ethernet/IP, utilizing the protocols built in safety features.
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PICS Vendor-Provided Nonsafety-Related Control System Interfaces PICS Modbus connections to vendor-provided control systems use custom configured gateways to only read from or write to vendor-approved addresses.
o The plants power supply systems interface with PICS via Modbus.
The building automation system (BAS) provides control for many of the ventilation and facility systems.
o BAS provides information to PICS for monitoring only using BACnet/IP, a building automation and HVAC industry standard.
PICS communications with vendor-supplied supercell and radioactive liquid waste immobilization (RLWI) system PLCs are read-only communications used for monitoring purposes only.
The NDAS control system receives permissive signals from the PICS to allow or disable use of the system and provides information to PICS for monitoring.
PICS monitors vendor-supplied nonsafety-related radiation monitors throughout the plant.
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PICS Workstations and Network Access Users who require access to the FactoryTalk View (FTV) Site Edition (SE) Supervisory Control and Data Acquisition (SCADA) system will have individual accounts created on the manufacturing domain.
o Users are required to set a password for their manufacturing domain account.
When users log in to PICS with their unique credentials, their accounts authenticate against the manufacturing domain.
o When no user is logged in, graphics and alarms are view-only, with no control/interactive functions available.
o Domain users will only be assigned to one domain group.
The five domain groups are Maintenance, Operator, Supervisor, Administrator, or Quality.
In conjunction with domain groups, users will be assigned to security areas which will coincide with various equipment areas in the SHINE production facility.
o This will allow SHINE to give certain user accounts limited control of PICS equipment.
o Facility control room operators and supervisors will be assigned to all security areas.
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PICS Workstations and Network Access Users will not be able to log in or operate remote HMI locations without being granted access by the facility control room supervisor.
o The facility control room supervisor can take back control of the PICS equipment at any time.
In the event of a power outage, each operator workstation has a local uninterruptable power supply (UPS) capable of supplying 10 minutes of backup power, by which time, the standby generator system (SGS) will be fully engaged providing power o The operator workstation thin client sessions are not lost with a local loss of power, they continue to run on the Stratus fault tolerant server (ftServer) in the server room.
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Phased Approach to SHINE Facility Operations TRACY RADEL, VICE PRESIDENT OF ENGINEERING
© SHINE
© SHINE Technologies, Technologies, LLC LLC 1
Outline Philosophy Phase Descriptions Irradiation Facility Systems Radioisotope Production Facility Systems Instrumentation and Control Systems Electrical Power Systems Auxiliary Systems Accident Analysis
© SHINE Technologies, LLC 2
Overall Philosophy
Purpose:
Meet the national need for Mo-99 production as soon as possible while also ensuring all requirements related to public health and safety are met o Provide flexibility for challenges that may arise during procurement, installation, and testing Key considerations:
o Ensure that all design criteria and safety functions can be met o Simplify process boundary isolation strategy o Simplify confinement boundary isolation strategy o Minimize impact on operating portions of the facility
© SHINE Technologies, LLC 3
Procurement and Installation Philosophy The SHINE approach to phased startup operations does not inherently affect how SHINE is approaching procurement and installation o Equipment for all eight irradiation units (IUs) being procured at the same time o Fabrication for most equipment is naturally being done in sets or batches, resulting in staggered delivery o As challenges are encountered in the fabrication process, equipment for Phase 1 will be prioritized Equipment will be installed as soon as possible once it is received on site
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Phase Descriptions Phase 1:
o Facility structure (FSTR) and nitrogen purge system (N2PS) structure o IUs 1 and 2, including IU-specific instances of the subcritical assembly system (SCAS), neutron flux detection system (NFDS), target solution vessel (TSV) off-gas system (TOGS), primary closed loop cooling system (PCLS), light water pool system (LWPS), and radiological ventilation zone 1 (RVZ1) equipment located in the cooling room o Tritium purification system (TPS) train A o Auxiliary and support systems, with the exception of IU-specific instances of PCLS, LWPS, and RVZ1 equipment located in the cooling room o Radioisotope production facility (RPF) systems, with the exception of iodine and xenon purification and packaging (IXP) and radioactive liquid waste immobilization (RLWI) selective removal capabilities
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Phase Descriptions Phase 2:
o IUs 3, 4, and 5, including IU-specific instances of the SCAS, NFDS, TOGS, PCLS, LWPS, and RVZ1 equipment located in the cooling room o TPS train B Phase 3:
o IUs 6, 7, and 8, including IU-specific instances of the SCAS, NFDS, TOGS, PCLS, LWPS, and RVZ1 equipment located in the cooling room o TPS train C o RLWI selective removal capability o Material staging building Phase 4:
o IXP capability
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Irradiation Facility Systems IRRADIATION UNITS IUs are designed and operated at the unit level.
o Each IU has unit-specific instances of the SCAS, NDAS, light water pool, and irradiation cell biological shield (ICBS), and each IU is supported by unit-specific instances of the PCLS and TOGS.
o Support system and process line interfaces with the IUs are isolated to support phased startup operation (i.e., interfaces with IUs 3 through 8 are isolated during Phase 1 operation, interfaces with IUs 6 through 8 are isolated during Phase 2 operation).
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Irradiation Facility Systems TRITIUM PURIFICATION SYSTEM TRAINS The TPS consists of three independent trains and each TPS train supports specific NDAS units.
o Each TPS train includes independent train specific instances of the isotope separation system (Thermal Cycling Adsorption Process [TCAP]), TPS-NDAS interface lines, secondary enclosure cleanup (SEC),
vacuum/impurity treatment subsystem (Vac/ITS), NDAS SEC, and TPS glovebox.
o The tritium confinement boundary for each TPS train (including the TPS glovebox, SEC, isolation valves, TPS-NDAS interface lines, and tubing up to isolation valves) is independent and isolated from the other TPS trains; no portion of the tritium confinement boundary is shared between TPS trains.
o Isolation is provided at TPS interface points to facility systems to allow TPS trains to be connected and commissioned without impacting operating TPS trains.
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Radioisotope Production Facility Systems RPF systems are installed to support Phase 1 operations, with the exception of the IXP system and the RLWI selective removal capability.
During Phase 1 through Phase 3 operations, the IXP system is not installed within the IXP hot cell, and the IXP hot cell is isolated from the supercell confinement boundary.
o The interfacing process and supporting system connections to the IXP system are isolated during Phase 1 through Phase 3.
The capability of the RLWI system to remove classification-driving isotopes is not available during Phase 1 and Phase 2 operations.
o During Phase 1 and Phase 2, liquid waste is stored in the subgrade radioactive liquid waste storage (RLWS) system tanks prior to transfer to RLWI in order to maximize the decay time and limit the volume of solidified waste requiring disposal.
o Waste solidified during Phase 1 and Phase 2 may have higher dose rates and higher waste classifications than wastes solidified during Phase 3 and Phase 4.
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Instrumentation and Control Systems During phased startup operations, the instrumentation and control (I&C) systems are installed to the extent practicable given the extent of equipment installation.
IU-specific instances of the TSV reactivity protection system (TRPS) are brought online with the associated IU in the applicable phases.
o The nine TRPS cabinets are installed in the facility control room (FCR) prior to Phase 1 operations but are brought into operation with the corresponding IU phasing as described in Chapter 1.
The engineered safety features actuation system (ESFAS) is installed to support Phase 1 operations.
o During phased startup operations, inputs to the ESFAS for equipment that is not required to be operable are disabled using the maintenance workstation (MWS).
o These disabled inputs are restored and verified to be operable prior to entering the technical specification mode of applicability associated with the given input.
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Instrumentation and Control Systems IU-specific instances of the neutron flux detection system (NFDS) are brought online with the associated IU in the applicable phases.
The safety-related process radiation monitors are installed to the extent practicable given the extent of equipment installation.
o Safety-related process radiation monitors associated with individual IUs (inputs to TRPS) and TPS trains (inputs to ESFAS) are installed during the phase associated with that IU or TPS train.
o Safety-related process radiation monitors associated with the IXP cell (input to ESFAS) are installed prior to Phase 4 operations.
Process integrated control system (PICS) hardware (i.e., cabinets, power supplies, controllers, programmable logic controllers [PLCs]) is installed prior to Phase 1 operations, with the exception of hardware associated with TPS trains B and C.
o PICS monitoring and controls associated with equipment that is not yet installed or not yet operable to support Phase 1 operations are tested and placed in operation as required for a given phase.
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Electrical Power Systems The normal electrical power supply system (NPSS) and uninterruptible electrical power supply system (UPSS) are installed in full to support Phase 1 operations.
o Loads on the NPSS and UPSS that are not yet installed or not yet operable in Phases 1, 2, or 3 have the associated isolation device removed or placed in an out-of-service condition.
o Cabling associated with equipment that is not yet installed or not yet operable for a given phase is installed to the extent practicable with the power removed at the associated panel or load.
The nonsafety-related standby generator system (SGS) is installed in full to support Phase 1 operations.
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Auxiliary Systems RVZ1 recirculating subsystem (RVZ1r) units support individual IU and TOGS cells and are installed with the corresponding IU.
Portions of the RVZ1 exhaust subsystem (RVZ1e) located in the cooling rooms are installed with the corresponding IU.
Supply lines from auxiliary systems include manual isolation valves and blind flange or caps to support phased startup operations.
Auxiliary systems are designed to handle the variable loads without modifications.
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Accident Analysis A hazard evaluation was performed to identify new or different accident scenarios, including changes to likelihood or consequences of existing accident scenarios.
The likelihood and consequences for these new or different accident scenarios were then evaluated and compared to the risk matrix and safety-related controls were applied to prevent or mitigate the accident scenario, in a method consistent with that described in Chapter 13a2 of the FSAR.
Phased startup operations do not result in any new accident categories or increased consequences from existing accident scenarios.
Five new accident sequences were identified, and five existing accident scenarios were reevaluated with increased likelihoods.
Four new credited engineered controls and three new credited administrative controls are added during phased startup operations to prevent the new or different accident scenarios.
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Advisory Committee on Reactor Safeguards SHINE Medical Technologies Operating License Application Chapter 7 - Instrumentation and Controls PICS October 21, 2022 Norbert Carte Office of Nuclear Reactor Regulation
I&C Technical Review Team
- Dinesh Taneja - Senior Electronics Engineer (HIPS, ESFAS, RMS)
- Norbert Carte - Senior Electronics Engineer (TRPS, NFDS, PICS)
- Duane Hardesty - Sr. Project Manager (Technical Specifications)
- Rossnyev Alvarado - Electronics Engineer 2
Guidance and Acceptance Criteria
- NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content, issued February 1996;
- NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Standard Review Plan and Acceptance Criteria, issued February 1996;
- Final Interim Staff Guidance (ISG) Augmenting NUREG-1537, Part 1 and Part 2, for Licensing Radioisotope Production Facilities and Aqueous Homogeneous Reactors 3
SAFETY EVALUATION OVERVIEW 4
Chapter 7 Safety Evaluation
- Current Scope
- PICS
- Previous Briefings
- I&C Design Criteria
- Highly integrated Protection System (HIPS)
- Target solution vessel reactivity protection system (TRPS)
- neutron flux detection system (NFDS)
- Engineered safety features actuation system (ESFAS )
- radiation area monitoring system (RMS) 5
PICS Description
- FSAR Sections
- 7.3, Process Integrated Control System
- 7.6, Control Console and Display Instruments
- SER Section 7.4.3, Process Integrated Control System
- SHINE Facility
- Two Distinct Parts (IF & RPF)
- One Control Room & one PICS (with many parts)
- Protection Systems (i.e., TRPS & ESFAS) & Control Systems (i.e., PICS) are:
- Independent
- Diverse 6
PICS Systems 7
Gateway Communications Architecture 8
Background Information - Main Control Board 9
PICS REVIEW 10
Layered Approach to Safety
- Design Criteria - Performance Objectives
- Provide criterion for achieving reasonable assurance of adequate safety
- Some are more safety significant than others
- Design Bases - Functions and Values
- Events Described in other FSAR Chapters
- Analysis Demonstrates Misbehavior of DB is addressed
- Variables Monitored & Functions Performed
- Setpoints and Response Times (Analytic Values) 11
PICS -Design Criteria in Context
- FSAR Design Criteria for PICS
- SHINE facility design criteria: 3,6, & 13
- PICS Criteria: 1-26
- SHINE facility design criteria for independence of TRPS &
ESFAS from PICS are imposed on TRPS & ESFAS
- SHINE facility design criteria 14, 16, & 18
- Staff evaluated PICS against Design Criteria
- SHINE facility design criterion 3,6, & 13
- PICS Criterion 1-10 12
PICS -Design Criteria in Context
- NRC review focus(given preceding context):
- PICS equipment failures analyzed to ensure:
Effects are bounded by events analyzed in safety analysis, see FSAR Section 7.3.2.2.4, Effects of Control System Operation/Failures
- PICS Independent from TRPS/ESFAS
- Description in FSAR Section 7.3.1.3.11, Target Solution Vessel Reactivity Protection System and Engineered Safety Features Actuation System
- Description in FSAR Section 7.3.2.2.4, Effects of Control System Operation/Failures
- SHINE facility design criteria 14, 16, & 18 (imposed on TRPS & ESFAS) 13
PICS - Design Bases
- FSAR Section 7.3.1, System Description
- Has subsection for each: IU & RPF
- Each has subsections for each system controlled, which describes applicable PICS functionality:
- Variables Monitored and Alarmed
- Control Functions
- Interlocks and Permissives 14
Staff Evaluation of PICS
- Based on its review of the information provided, the NRC staff concludes the design of the PICS meets the applicable design acceptance criteria in Section 7.3 of NUREG-1537, Part 2.
- Based on the information reviewed, the NRC staff concludes that SHINE established the necessary design, fabrication, construction, testing, and performance requirements for the PICS to provide reasonable assurance that the facility be operated without undue risk to the health and safety of the public.
15
Questions 16
BACKGROUND 17
Acronyms APL actuation and priority logic (see HIPS TR)
ASAI application specific action item (see HIPS TR)
BF3 boron trifluoride BIST built-in self-test (see HIPS TR)
CAAS criticality accident alarm system CAMS continuous air monitoring system CCF common cause failure CDA critical digital asset CM communication modules (a HIPS module)
COTS commercial off-the-shelf CTB calibration and test bus (see HIPS TR)
EIM equipment interface module (a HIPS module)
EMI electromagnetic interference 18
Acronyms ESFAS engineered safety features actuation system FAT factory acceptance test FCR facility control room FDCS facility data and communications system FPGA field programmable gate array (see HIPS TR)
HIPS highly integrated protection system (see HIPS TR)
HVPS high voltage power supply HW-SM hardwired submodule (a HIPS module)
HWM hardwired module (a HIPS module)
I&C instrumentation and control IEEE Institute of Electrical and Electronic Engineers IF irradiation facility 19
Acronyms ISG interim staff guidance ISM input submodule (a HIPS module)
IU irradiation unit MI-CM monitoring and indication communication module (see HIPS TR)
MIB monitoring and indication bus (see HIPS TR)
MWS maintenance workstation (see HIPS TR)
NDAS neutron driver assembly system NFDS neutron flux detection system NPSS normal electrical power supply system NVM nonvolatile memory (see HIPS TR)
OOS out of service(see HIPS TR)
PDC Principal Design Criteria PICS process integrated control system 20
Acronyms PLDS programmable logic design specification PLRS programmable logic requirements specification QA quality assurance RAMS radiation area monitoring system RCA radiologically controlled area RDS radioactive drain system RFI radio-frequency interference RISM remote input submodule (a HIPS module)
RVZ1 radiological ventilation zone 1 RVZ1e radiological ventilation zone 1 exhaust subsystem RVZ1r radiological ventilation zone 1 recirculating subsystem RX receiver (Figure 7.1-x)
SASS subcritical assembly support structure SBM scheduling and bypass modules (a HIPS module) 21
Acronyms SBVM scheduling, bypass, and voting modules (a HIPS module)
SCAS subcritical assembly system SDB1 safety data bus 1 (see HIPS TR)
SDB2 safety data bus 2 (see HIPS TR)
SDB3 safety data bus 3 (see HIPS TR)
SDE secure development environment (see HIPS TR)
SFM safety function module (a HIPS module)
SOV solenoid operated valve SR safety-related SRM stack release monitor SRMS stack release monitoring system SVM scheduling and voting module (a HIPS module)
SyRS system requirements specification 22
Acronyms TMR triple modular redundant TOGS TSV off-gas system TPS tritium purification system TR topical report TRPS target solution vessel reactivity protection system TSPS target solution preparation system TSSS target solution storage system TSV target solution vessel TX transmitter (Figure 7.1-x)
UPSS uninterruptible electrical power supply system V&V verification & validation VTS vacuum transfer system 23
Advisory Committee on Reactor Safeguards SHINE Medical Technologies, LLC Operating License Application Appendix A - Phased Approach to Startup Michael Balazik Project Manager/Inspector Office of Nuclear Reactor Regulation October 21, 2022
Regulatory Basis
- Regulatory Requirements 10 CFR 50.34, Contents of applications; technical information 10 CFR 50.40, Common standards 10 CFR 50.57, Issuance of operating license 2
Guidance and Acceptance Criteria
- NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content, issued February 1996;
- NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Standard Review Plan and Acceptance Criteria, issued February 1996;
- Final Interim Staff Guidance (ISG) Augmenting NUREG-1537, Part 1 and Part 2, for Licensing Radioisotope Production Facilities and Aqueous Homogeneous Reactors 3
Summary of Application
- On January 27, 2022, SHINE supplemented the FSAR to describe a four-phase approach to startup operations.
- Phased completion is staggered over a few years and planned for completion in 2025.
- In the supplement, SHINE describes the technical impacts and information differences for each chapter of the full-design facility FSAR.
- SHINE identifies equipment isolation points and methods for each phase.
- SHINE FSAR Chapters 4, Irradiation Unit and Radioisotope Production Facility Description, 7, Instrumentation and Control Systems, 9, Auxiliary Systems, and 13, Accident Analysis, are most impacted.
4
Summary of Application (continued)
- Irradiation units (IU) are designed and operated independently (unit specific equipment).
- Tritium Purification System (TPS) consists of three independent trains to support IU operation.
- Except for the iodine and xenon purification/packaging (IXP) system and the radioactive liquid waste isolation (RWLI) selective removal capability, all systems for the Radioisotope Production Facility are installed to support Phase 1 operations.
- Instrumentation and Control Systems are IU specific (TRPS), or inputs are disabled (ESFAS and PICS) 5
Summary of Application (continued)
- Five new accident sequences were identified, and five existing accident sequences had an increase in likelihood
- New accident sequences Improper target solution routing (Uninstalled IU or IXP)
Damage to the TPS train Damage to the process vessel vent system(PVVS)/TOGS interface Backflow of target solution to the IXP
- Likelihood increase Heavy load drop on the TPS Heavy load drop on an operating IU or TOGS cell Heavy load drop on the RLWI enclosure or supercell Fire in the irradiation facility or radioisotope production facility 6
Staff Evaluation
- The same NRC staff that reviewed the full-design FSAR Chapter reviewed the same chapter in the SHINE Supplement (Phased Approach to Startup)
- Evaluated the effect on the sufficiency of the SHINE facility description and the design bases, the limits on facility operation, and the safety analysis of the structures, systems, and components (SSCs) and of the facility as a whole as presented in the SHINE FSAR.
- Reviewed the kinds and quantities of radioactive materials expected to be produced in the operation of the SHINE facility and the means for controlling and limiting radioactive effluents and radiation exposures.
- Reviewed the methods and sufficiency of system-level isolations for the different phases to ensure safe operation of the facility and to ensure health and safety of the workers and public.
7
Staff Evaluation (continued)
- The NRC staff audited information supporting the phased approach to startup.
- Initial areas of perceived risk significance for phased approach to startup Human system interfaces/training of operators Disabling/enabling instrumentation and control inputs Increase crane operation with heavy loads during operation Radiological dose to workers completing construction 8
Phased Startup Operation License Condition
- 10 CFR 50.57(b) requires each operating license issued by the Commission to include appropriate provisions with respect to uncompleted items of construction and such limitations or conditions as are required to ensure that operation during the period of the completion of such items will not endanger public health and safety.
- SHINE provided a phase-specific listing of installation and functional testing activities required to support operation of Phase 2, Phase 3, and Phase 4.
- NRC staff is imposing a license condition to ensure that the operation of the subsequent phases of the SHINE facility will not be commenced until the associated uncompleted items of construction have been completed and that appropriate NRC oversight of the completion of the uncompleted items of construction is maintained.
9
Phased Startup Operation License Condition (cont.)
License Condition is as follow:
The Licensee shall conduct activities for startup of facility operations in Phases, as described in SHINE Technologies, LLC Application for an Operating License Supplement No. 31, Enclosure 3, Phased Startup Operations Application Supplement, dated September 28, 2022 (ADAMS Accession Nos. ML22271A963 and ML22271A966), as amended. Operation of Phase 2 or of any subsequent Phase shall not commence prior to satisfaction of conditions (a) and (b) below:
a) No later than 14 days before the planned commencement of operation of Phase 2, and thereafter no later than 14 days before the planned commencement of operation of each subsequent phase, the Licensee shall notify the NRC in writing that all uncompleted items of construction related to that Phase have been completed.
b) Prior to the operation of Phase 4, the Licensee shall provide to the NRC in writing, six months after the issuance of this operating license and every six months thereafter, information on the status and schedule for completion of uncompleted items of construction.
10
Evaluation Findings and Conclusions
- SHINE described the design of the systems and identified the major features or components affected by the proposed phased approach to startup for the protection of the health and safety of the public.
- The processes to be performed, the operating procedures, the facility and equipment, the use of the facility, and other TSs, provide reasonable assurance that the applicant will comply with the regulations in 10 CFR Part 50 and 10 CFR Part 20 and that the health and safety of the public will be protected during the phased approach to startup.
- The issuance of an operating license for the facility would not be inimical to the common defense and security or to the health and safety of the public.
- The NRC staff finds that the descriptions and discussions of SHINEs systems as affected by the phased approach to startup are sufficient and meet the applicable regulatory requirements and guidance and acceptance criteria for the issuance of an operating license.
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