ML22192A198
| ML22192A198 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/2022 |
| From: | Derek Widmayer Advisory Committee on Reactor Safeguards |
| To: | |
| Widmayer D | |
| References | |
| NRC-2019 | |
| Download: ML22192A198 (352) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Radiological Rulemaking Policies and Procedures Part 53 Subcommittee Docket Number: (n/a)
Location: teleconference Date: Friday, June 24, 2022 Work Order No.: NRC-2019 Pages 1-290 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 REGULATORY RULEMAKING, POLICIES AND PRACTICES:
8 PART 53 SUBCOMMITTEE 9 + + + + +
10 FRIDAY 11 JUNE 24, 2022 12 + + + + +
13 The Subcommittee met via Teleconference, 14 at 8:30 a.m. EDT, David A. Petti, Chairman, 15 presiding.
16 17 COMMITTEE MEMBERS:
18 DAVID A. PETTI, Chairman 19 RONALD G. BALLINGER, Member 20 VICKI M. BIER, Member 21 CHARLES H. BROWN, JR. Member 22 VESNA B. DIMITRIJEVIC, Member 23 GREGORY H. HALNON, Member 24 WALTER L. KIRCHNER, Member 25 JOSE MARCH-LEUBA, Chairman NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1 JOY L. REMPE, Member 2 MATTHEW W. SUNSERI, Member 3
4 ACRS CONSULTANTS:
5 DENNIS BLEY 6 STEPHEN SCHULTZ 7
8 DESIGNATED FEDERAL OFFICIAL:
9 DEREK WIDMAYER 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 1 C O N T E N T S 2 Opening Remarks . . . . . . . . . . . . . . . . . 4 3 Staff Introduction . . . . . . . . . . . . . . . 4 4 10 CFR Part 53 - Framework B, AERI Guidance 5 Documents . . . . . . . . . . . . . . . . . . . . 4 6 DG-XXX1, "Technology-Inclusive 7 Identification of Licensing Events 8 for Commercial Nuclear Plants . . . . . . . 8 9 DG-XXX2, "Alternative Evaluation for 10 Risk Insights (AERI) Framework" . . . . . . 84 11 10 CFR Part 53 - Framework A, Subpart F, 12 Requirements for Operations 13 Revised Proposed Language for Staffing 14 and Role of STA . . . . . . . . . . . . . . 86 15 Subcommittee Discussion 16 Adjourn 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 1 P R O C E E D I N G S 2 8:31 a.m.
3 CHAIRMAN PETTI: Thank you, Matt. Okay, 4 we'll start again. Welcome. This is day two of our 5 discussions on 10 CFR Part 53.
6 Just for the Court Reporter, I will go 7 through the roll and who is here. Members of the 8 Committee present in the room are Ron Ballinger, Joy 9 Rempe, myself, and Vicki Bier.
10 Online we have Vesna Dimitrijevic, Greg 11 Halnon, Walt Kirchner, Jose March-Leuba, and Matt 12 Sunseri. We do expect Charlie Brown, but probably 13 traffic is holding him up a little bit.
14 Also, the Federal Designated Officer of 15 the meeting is Derek Widmayer. With that, we will 16 continue with the Part 53 discussions, where we left 17 off yesterday.
18 So, please go ahead. Katie?
19 MS. WAGNER: Okay. So, good morning and 20 welcome to this meeting on Part 53 Framework B, 21 Subpart R, the Alternative Evaluation for Risk 22 Insights or AERI continued today.
23 My name is Katie Wagner, and I am a 24 Project Manager in the Division of Advanced Reactors 25 and Non-power Production Facilities, Non-power NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 1 Production Utilization Facilities in the Office of 2 Nuclear Reactor Regulations. Next slide, please.
3 Actually slide 39 I mean. Okay. So, 4 our agenda is slightly different than what is on 5 this slide, because Marty says he presented a bit 6 early yesterday.
7 And today where we'll pick up is 8 introducing the Graded PRA Working Group. And that 9 will be followed by the Technology-Inclusive 10 Identification of Licensing Events for Commercial 11 Nuclear Plants, followed by the AERI Framework. And 12 then I will finish with next steps. Next slide.
13 So, to briefly introduce everyone since 14 they are continuing on. Marty Stutzke is the 15 technical lead of the Graded PRA Working Group. He 16 is also the Senior Technical Advisor for PRA in the 17 Division of Advanced Reactors and Non-power 18 Production and Utilization Facilities, or DANU in 19 the Office of Nuclear Reactor Regulation, or NRR.
20 And we also have with us here today 21 Mihaela Biro, who is the principal author of Pre-22 decisional Draft Regulatory Guide DG-1413, 23 Technology-Inclusive Identification of Licensing 24 Events for Commercial Nuclear Plants. He is a 25 Senior Reliability and Risk Analyst in the Division NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 1 of Risk Assessment in NRR.
2 And our other presenter is Alissa 3 Neuhausen, who is the principal author of Pre-4 Decisional Draft Regulatory Guide DG-1414, 5 Alternative Evaluation for Risk Insights, or AERI 6 Framework. She is a Reliability and Risk Analyst 7 also in DRA in the office of NRR. Next slide, 8 please.
9 So, moving on. This slide shows the 10 membership of the Graded PRA Working Group. And as 11 you can see here, the working group is composed of 12 nine technical NRC staff from several divisions of 13 NRR.
14 And it also receives support from the 15 Office of Research and Dr. Robert Budnitz, who is a 16 consultant. And with the membership of the working 17 group, that ensures that the technical questions 18 receive feedback from multiple viewpoints, which is 19 important for, you know, these complex matters.
20 And also, the working group has 21 benefitted from several legal staff sitting in on 22 multiple meetings. So, I think, you know, we have a 23 well-rounded group. And next slide.
24 And just to briefly recap from 25 yesterday, Marty covered this slide. But, just to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 1 refresh everyone's memory. So, this initiative 2 evolved from the NRC staff's graded PRA initiative, 3 which started in spring of 2021.
4 And based on feedback during the 5 Advanced Reactor Stakeholders public meeting on May 6 27, 2021, the staff learned that industry concerns 7 were largely directed at grading how the PRA was 8 used in the licensing process, rather than grading 9 the technical content of the PRA itself.
10 Also, there was general recognition from 11 industry that the ASME/ANS non-LWR PRA standard 12 already offered opportunities to grade the technical 13 content of the PRA.
14 And as we discussed yesterday, there 15 have been various names since the spring of 2021, 16 which has been used to describe the concept that we 17 now call AERI, including the dose/consequence-based 18 approach, the technical, technology-inclusive, risk-19 informed maximum accident or TIRIMA approach, and 20 53, Part 53-BE or bounding event approach. And now 21 of course, we are using the term AERI or 22 Alternative Evaluation for Risk Insight.
23 And that, I will pass the microphone 24 onto my colleague, Mihaela Biro, to discuss 25 Technology-Inclusive Identification of Licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 1 Events for Commercial Nuclear Plants.
2 MS. BIRO: Good morning. Can we go to 3 slide 56, please? Thank you.
4 So, today I will talk to you about the 5 first guide that we developed, the PDG-1413 Pre-6 decisional Draft Regulatory Guide for plans of 7 Technology-Inclusive Guidance for Identification of 8 Licensing Events used to and from the licensing 9 basis, design basis and content of application.
10 This guide was initiated by the efforts 11 in AERI, for developing AERI. However, we realized 12 that this guidance can apply to any licensing 13 framework.
14 So, this guide, this generic guidance 15 applies to all light water and non-light water 16 reactors licensed under Part 50, Part 52, and Part 17 53 both Framework A, and Framework B.
18 So, before we continue, I really need to 19 explain what licensing events are. So, as I said, 20 this guide applies to all licensing frameworks as I 21 mentioned.
22 And each licensing framework uses its 23 own terminology, such as the design basis, 24 accidents, events, anticipated operational 25 occurrences, et cetera.
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9 1 We had to come up with a generic term, 2 so we used the term licensing event, a generic term 3 in the context of this pre-decisional guide to refer 4 to all those collections of designated event 5 categories that are identified in Part 50, 52, and 6 Part 53.
7 This slide provides an overview of the 8 contents of this pre-decisional regulatory guide.
9 And then I'll provide more details in the following 10 slides.
11 So, as any regulatory guide, Section A -
12 - so this has three sections. Section A is 13 dedicated to introduction and review of applicable 14 regulations.
15 Section B provides a discussion and an 16 overview of the ACRS recommendations, which were 17 covered by Marty earlier yesterday.
18 And finally, Section C provides the 19 staff guidance, which outlines an integrated 20 approach for identification of licensing events.
21 And this comes in three main parts.
22 One, the init -- identification of the 23 initiating events. Meaning identifying all possible 24 prohibition to the plant that can challenge the 25 control and the safety systems, and whose failure NEAL 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 could lead to radioactive release.
2 After the identification of initiating 3 events, part two would be the delineation of event 4 sequences. Which is the analysis of plant response 5 to the initiating event.
6 And finally, in part three, grouping and 7 mapping those initiating events and event sequences 8 into licensing event categories.
9 Lastly, this guide also contains an 10 appendix that reviews the techniques for searching 11 for initiating events, and provides a list of useful 12 references. But, it does not recommend any 13 particular technique. Slide 57, please? Next 14 slide.
15 So again, licensing events is a generic 16 term we use in this regulatory guide to refer to 17 designated event categories in the respective parts.
18 And those event categories and terminology vary for 19 the various licensing frameworks, and are summarized 20 in this table.
21 In Part 50 and Part 52, have not 22 necessarily clear cut definitions for all of these 23 terms. We searched through the regulations and the 24 associated regulatory guides, and identify all the 25 licensing event categories that are listed on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 1 first row.
2 Looking at these, we noticed that some 3 are purely initiating events. But, others are event 4 sequences, which encompass initiating events and 5 some embedded plant response. Examples being, 6 station blackout or ATWS.
7 On the second row, the licensing 8 modernization project, also known as LMP. It uses 9 PRA to align licensing events and has its own 10 defined event categories, which I believe were 11 defined by the industry, and are based on initiating 12 event frequency.
13 On the third row, Part 53, Framework A, 14 is also based on LMP with its own designated event 15 categories, which are frequency based.
16 And lastly, in Framework B, uses the 17 terms that are listed here, and we created to match 18 more with the traditional use of Parts 50 and 52.
19 Next slide, please.
20 So, the choice of the licensing 21 framework influences the process to be followed by 22 the applicant for the licensing event 23 identification. So, this table tries to summarize 24 the licensing frameworks and their implications.
25 Mainly, the choice of the framework NEAL 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 influences the process in that one, it establishes 2 what licensing event categories will be used, as 3 I've shown in the previous slide, but also whether a 4 PRA will be used, and how the risk inside from the 5 PRA will be used.
6 So, we have two terms here under a 7 second column. I want to refresh those real quick.
8 So, traditionally so PRA, this is enhanced use of 9 PRA.
10 So, traditional use, we think of 11 traditional use of PRA as the PRA in a supporting 12 role that complements the deterministic approach, 13 such as has been used in the operating fleet in the 14 U.S.
15 This includes, for example, searching 16 for severe accident vulnerabilities as expected by 17 similar accident policy statement, or demonstrate 18 the quantitative health objectives are met as 19 required by safety goal policy statement.
20 The enhanced use of PRA is basically 21 anything beyond its traditional role, such as in the 22 licensing modernization project. And also in the 23 preliminary role for Part 53, Framework A, the PRA 24 is used to identify the licensing basis events and 25 classify system structure and components 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
13 1 evaluate defense in depth.
2 In the fourth column, we summarize 3 whether exceptions from the regulations are 4 expected to be necessary. And there are two cases 5 that we'd expect some exemption would be needed.
6 In the first case, for non-light water 7 reactor applicants, because the regula -- the 8 regulations in Part 50 and 52 are oriented towards 9 light water reactors, and in many aspects are 10 prescriptive in nature.
11 Those non-light water reactor applicants 12 under Part 50 and 52 may need to request and justify 13 exemptions from regulatory requirements that don't 14 need to be satisfied for the chosen technology.
15 Secondly, the designer and applicants, 16 both light water and non-light water who seek the 17 enhanced user risk insights through LMP should also 18 request and justify exemptions from certain 19 requirements in Part 50 and 52.
20 One example that we're aware of, is the 21 definition safety related? Which in LMP is 22 different than in Parts 50 and 52.
23 In contrast, Part 53 Framework is 24 entirely technology inclusive, and can be used for 25 both light water and non-light water applicants NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 1 without the need for exemptions.
2 And lastly, on the last column, I want 3 to point out that the licensing event identification 4 is mostly under the umbrella of this preliminary 5 draft regulatory guide, with the exception of those 6 applicants who seek enhanced use of risk insight 7 through LMP.
8 So, for those, we expect that we'll use 9 Regulatory Guide 1.233 to identify licensing events.
10 I also want to point out that there are parts of 11 this preliminary draft guide that applies 12 generically to all frameworks.
13 So, before getting to licensing event 14 identification, the parts about initiating events 15 and identification and event sequences, that is 16 general guidance that would apply to all frameworks.
17 Next slide, please.
18 DR. BLEY: Before you leave that slide, 19 and maybe this is what you were hinting at, but 20 Appendix A of this guide, in my opinion, ought to 21 apply to all of these, including the enhanced ones.
22 And I know there isn't that kind of 23 guidance in 1.233, I don't believe. Why wouldn't it 24 apply to the enhanced use of risk insights cases?
25 MS. BIRO: Yes. So, actually maybe, let NEAL 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 me try to clarify. Appendix A applies to initiating 2 events and identification, right?
3 And so, that part would apply across.
4 It's not just for 1.233. We do have three parts in 5 this guide, initiating events, event sequences, and 6 licensing events.
7 And I'll show you on, we have a 8 flowchart that's coming next. And I hope that's 9 going to clarify. But, the first two --
10 DR. BLEY: Well, maybe that will take 11 care of it. But this, not just this viewgraph, this 12 figure from the Reg Guide might tell someone they 13 don't have to look at that if they're doing the 14 enhanced approach.
15 MEMBER KIRCHNER: Dennis, that was my 16 comment as well.
17 DR. BLEY: That troubles me. I would 18 think you would like a footnote or something here 19 saying -- or add it, add it right in this table, 20 because people tend to use the tables when they're 21 available, more than the words.
22 And this could cause that to get lost.
23 MS. BIRO: Okay. Okay, I appreciate 24 that comment, if it didn't come clearly when you 25 read it. It definitely, certainly can be clarified.
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16 1 MEMBER REMPE: So, this is Joy. And I 2 was wondering, why not also use this Reg Guide, or 3 Draft Guide for manufacturing license applications.
4 MS. BIRO: I can't speak for that.
5 Marty, can you help?
6 MR. STUTZKE: Yeah. This is Marty 7 Stutzke from the staff. This Guide applies to all 8 the licensing processes.
9 MEMBER REMPE: Well, the paragraph at 10 the beginning of it says it's for reactors. And 11 that's the title of it. It says Commercial Nuclear 12 Power plants. It doesn't say manufacturing 13 facilities.
14 MR. STUTZKE: We'll take that under 15 advisement. It's intended to apply to design certs 16 and manufacturing licenses.
17 MEMBER REMPE: Right. And so, I think 18 it could be broadened, is what I'm trying to say.
19 MR. STUTZKE: Yeah.
20 MEMBER REMPE: But, it looks like Mo has 21 a comment about this to counter my comment.
22 MR. SHAMS: No. Thank you. Mo Shams 23 with the staff. I was just wondering, for a 24 manufacturing facility that's not turning the 25 reactor critical, what kind of events are we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 1 concerned with at that point?
2 MEMBER REMPE: Chemical hazards, 3 radiation release.
4 MR. SHAMS: That hasn't been turned 5 critical, it's not loaded with fuel?
6 MEMBER REMPE: You can have radiation 7 from nuclear duranium, right? You can have a 8 radiative material release from it, right?
9 MR. SHAMS: I appreciate the thought.
10 By the way, we're in the manufacturing license.
11 We're looking to add fueling. We're looking to add 12 potential criticality.
13 MEMBER REMPE: Um-hum.
14 MR. SHAMS: So, I'm just mapping, you 15 know, this load design --
16 MEMBER REMPE: Yeah. I'm just saying, 17 you would have to make some changes. And I have a 18 comment about that later.
19 MR. SHAMS: Right.
20 MEMBER REMPE: But, I think it should be 21 broadened, because Part 53 applies to manufacturing 22 licenses. And so, you may fuel it, and things like 23 that.
24 But, there's other facilities too. So, 25 anyway, just a thought.
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18 1 MR. SHAMS: Make sure, thank you.
2 MS. BIRO: Thank you. Okay. So, moving 3 onto the next slide, please. So, our staff 4 perspective in this pre-decisional draft regulatory 5 guide, our consistence with the ACRS 6 recommendations.
7 The need to examine new and novel 8 designs with a clean sheet of paper, without relying 9 on any preconceived lists of design basis accidents 10 or scenarios, such as those that have been 11 historically established for pressurized water 12 reactors and boiler water reactors.
13 Because this, we believe this predefined 14 list can significantly meet the identification 15 process. So, they are approaching this guide 16 starting with a blank sheet of paper, through an 17 analysis have conducted objectively without 18 preconception.
19 Supports producing a comprehensive and 20 exhaustive list of licensing events. And the 21 maintenance that it's capable to identify unique 22 situations that can be introduced by new and novel 23 technologies and designs.
24 This is to ensure that the plant is, 25 design is appropriately analyzed and demonstrated to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 1 be safe based on the comprehensive list of licensing 2 events. Next slide, please.
3 So, to find techniques that can support 4 this needed objective and systematic search for 5 initiating events, we had a good many documents, 6 including our own NRC NUREGs, such as NUREG 1513.
7 It's a good example of an integrated 8 system analysis document. It provides guidance to 9 fuel cycle licenses and applicants, on how to 10 preform integrated safety analysis and document the 11 results.
12 Another NUREG that we looked at, of 13 course, is NUREG 0492, Fault Tree Handbook, which is 14 a fundamental NUREG for the P -- well-known to the 15 PRA practitioners. And discusses the basic concepts 16 of inductive and inductive techniques, and 17 specifically the fault tree method.
18 We also looked at recent work with 19 identifying initiating events for new advanced 20 technology. Molten Salt Reactor was one that had 21 benefitted from that work and initiating vent 22 identification from EPRI. There was an EPRI report 23 on that.
24 And also, the NRC has an MOU with the 25 Canadian Nuclear Safety Commission for an integral NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 1 Molten Salt Reactor.
2 But, we also looked at other non-nuclear 3 engineering and industrial organizations, such as 4 the American Institute of Chemical Engineers, and an 5 open internet search.
6 We did identify many techniques which we 7 discussed and reviewed in Appendix A to this guide.
8 But, I need to point out that we're not intending to 9 write a textbook on how to do this.
10 Rather, this pre-decisional guide 11 provides guidance that contains pointers to various 12 references. And that's where it is that could be 13 used. Next slide, please.
14 So, Appendix of the guide summarizes the 15 known and well-established techniques we identified 16 for conducting the search for initiating event and 17 illuminating sequences.
18 This is not an exhaustive list. Other 19 techniques could be used for this effort. But, we 20 put the techniques into general categories, they are 21 the inductive techniques and deductive techniques.
22 So, inductive techniques provide answers 23 to the generic question of what happens if, and 24 analyze some specific to general.
25 It assumes sudden state of component 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
21 1 examines its effect on the system. The most 2 familiar example perhaps is the failure mode and 3 affects analysis, also known as FMEA.
4 In contrast, the deductive techniques 5 are those declarations of how it can happen.
6 Deductions constitute reasoning from the general to 7 the specific.
8 So, in this approach you want to 9 postulate how the system has failed, and attempt to 10 find out what mode of system and components behavior 11 can lead to that failure.
12 So, the most familiar one is the fault 13 tree analysis, which is a common technique used 14 currently in the PRA.
15 Other well-known techniques are the 16 hazard and operability analysis, which is an 17 inductive technique. It's also known as HAZOP, 18 which is widely used outside the nuclear industry in 19 the process and engineering and chemical engineering 20 community.
21 But, I'd like to point out that it's 22 used in our own NUREG 1513 of Integrated Safety 23 Analysis guidance document for fuel cycle licenses 24 and applicants.
25 Master Logic Diagram is another known, NEAL 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 also known as MLD, is another well-known technique.
2 It is similar to fault tree analysis, but it's a 3 logic diagram. It resembles a fault tree, but 4 without the mathematical properties.
5 Lastly, I want to point out this guide 6 recommends using a combination of different methods, 7 combining inductive techniques, which analyze from 8 the generic to the specific. Combine that with the 9 deductive techniques, which analyze from generic to 10 the specific.
11 And show that the list if initiating 12 events is as comprehensive and exhaustive as 13 possible. And especially for new novel designs with 14 little or no operating experience.
15 DR. BLEY: I'd like to make a few 16 comments, if I might, at this point.
17 MS. BIRO: Yes, please.
18 DR. BLEY: One, you earlier said you've 19 provided a catalog of events that are not complete.
20 Well, it's pretty complete, but yeah, it's not fully 21 complete.
22 But, no recommendations. And my first 23 question would be, why not? But, I'm going to give 24 you some examples of what I mean by why not.
25 A few comments on specific things 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
23 1 here. The master logic diagram, as you said, 2 doesn't have the same logic properties as a fault 3 tree.
4 But, what you didn't point out is the 5 fault tree is if and only if logic, and the master 6 logic diagram is only if logic. So, there is a 7 logic structure to it.
8 Failure modes and effects analysis, the 9 way it's generally done is looking at single 10 failures with respect to components. And it 11 generates massively long lists that tend, in my 12 opinion and many others, tend not to be useful.
13 If you've done a halfway decent job of a 14 design, you don't get many of those. And they only 15 affect the system they're in.
16 A technique, and I think Mr. Fleming 17 included this in his paper, but I'm not positive, a 18 specific type of failure mode and effect analysis 19 has proved very helpful. And it's been dubbed a 20 system level failure mode and effect analysis.
21 So, you look at the effect of train 22 failures rather than independent component failures.
23 And that's been shown to be quite helpful at times.
24 There's one that's missing on here. And 25 I would expect the reason it's missing, is it NEAL 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 doesn't sound very scientific. It doesn't sound 2 very much like a method. But, it's really helpful 3 at breaking mindset.
4 Now, people who do a lot of PRA and raw 5 ability analysis, tend to think in terms of failure.
6 The engineers who design things tend to think in 7 terms of success. And it's real hard to look for 8 failures and find them.
9 Two approaches, maybe three, tend to 10 break that mindset and help people do better. The 11 one that's not on your list, and doesn't sound like 12 a method, I call a reframing. I think Ron Ballinger 13 might chip in and tell you what some aerospace and 14 defense people call it.
15 But, it's reframing how you think about 16 this. And instead of thinking about how can this 17 thing fail, and you're thinking random failures, or 18 maybe some systematic ones. You turn it around and 19 say, how can I make the system fail? How can I 20 sabotage it?
21 And that little flip in mindset often 22 helps you find weak spots in the design that you 23 wouldn't have found otherwise.
24 So, it doesn't sound like much. But, I 25 tell you, it's very effective. And I think 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
25 1 ought to add it to your list.
2 That tries, not tries, that really does 3 help people get around the mindset that this system 4 can't fail. That's a property too, of HAZOP, hazard 5 and operability analysis, because when you look at 6 the pieces of the system there, you're forced to use 7 a set of guide words.
8 Rather than saying how can this fail, 9 you can say, how can it get faster, slower, all of 10 those sorts of things. And that really does break 11 that mindset.
12 And there are aspects of hazard 13 analysis, especially looking for the sources of 14 hazard, before you start looking for how that hazard 15 can be released, that are helpful at breaking the 16 mindset.
17 So, you know, if this were mine, I would 18 really try HAZOP. And probably system hazard 19 analysis, and reframing, as things everybody ought 20 to use, because it really helps them break through 21 those mindset issues.
22 So, that was a long bit of chatter.
23 But, I think it's useful. And I compliment you on 24 putting together a pretty good list.
25 Some of these maybe aren't going to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 1 used very often. Some will be used by some analysts 2 almost all the time.
3 I'm not quite sure how Markov analysis 4 fits in here, because you have to build the model, 5 so you have to think of how things fail first. But, 6 I expect there are cases where Markov can help you 7 find things you wouldn't have found otherwise.
8 But, if you can say anything more about 9 the Markov, I'd be interested.
10 MS. BIRO: Okay. Well, thank you for 11 your comment. We did do a list. But, we were 12 looking forward for more comments.
13 And certainly this Appendix can be 14 improved. And we can add other examples, and make a 15 couple of points that you mentioned.
16 So, we are definitely open to enhance 17 this further, because it was a start. But, we could 18 use more references. And if there are any 19 suggestions, we definitely are open to it.
20 MEMBER BIER: One other minor comment.
21 Which is, I'm not sure I would put FMEA as 22 inductive. It tends to start with a list of events.
23 And then for each event look downstream at what are 24 the consequences or effects.
25 And that part of the process, in 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
27 1 mind, a little more deductive. I don't know how I 2 would have put that in the category and keep that.
3 Just a thought.
4 MS. BIRO: Okay. Thank you. Any other 5 comments?
6 (No response) 7 MS. BIRO: Okay If not, we're going to 8 proceed to the next slide. So, then in Section C of 9 this guide, we provide the guidance for an 10 integrated approach for identification of licensing 11 events.
12 So, before we get into it, we identify 13 five overarching principles, which we color coded in 14 a flowchart. And they are all covered in the next 15 three slides.
16 So, in the yellow, the need to identify 17 application-specific factors which include things 18 like licensing frameworks, any plant-specific design 19 features and site features.
20 In orange, the need to conduct a 21 systematic and comprehensive search for initiating 22 events. In blue, use a systematic process to 23 delineate a comprehensive set of event sequences.
24 In group, initiate all those initiating 25 events and event sequences into designated licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 1 event categories according to a selected framework.
2 And lastly, in red, provide assurance 3 that the set of licensing events is sufficient.
4 Next slide, please.
5 So now I'm going to walk you through the 6 flowchart that we included in Section C. So, we 7 start at the top, first and foremost in box one, 8 before one proceeds through the process, one would 9 have to identify which licensing framework is a 10 plant to be licensed under.
11 Because as I previously explained, the 12 choice of licensing framework influences the 13 process, because it influences the -- it establishes 14 what licensing event categories to be used, and 15 whether a PRA will be used, and how the results from 16 the PRA will be used.
17 This is a choice made by the applicants.
18 So, this guide does not provide any associated guide 19 in how to choose your licensing framework.
20 And next moving down, box two, assembles 21 the team. Of course, to conduct this effort for 22 identification of licensing events, we believe it is 23 necessary and fundamental to assemble a multi-24 disciplinary team with the right expertise, a team 25 that has familiarity with all the elements necessary NEAL 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 to support its work.
2 The experts that we thought of would 3 encompass the obvious ones, licensing, plant design, 4 operation, thermal hydraulics, reactor physics, PRA.
5 But, also any expertise in the selected 6 method of analysis and those initiating events, 7 methods that we discussed two slides ago. And if 8 there is any need for any expertise specific to the 9 chosen technology, things like molten salt, et 10 cetera.
11 Then, in the yellow boxes that you see, 12 we move to, into collecting application-specific 13 information, such as in box three, collect all the 14 plant specific information and site characteristics.
15 In box four, identify all radiological 16 sources. This will obviously include the reactor 17 core that exists, but also non-reactor core sources.
18 And these can include spent fuel, and 19 the spent fuel storage system. In the case of the 20 molten salt reactor, any fuel or salt processing 21 systems, any radioactive waste systems, and other 22 process systems with radioactive material.
23 And then this should cover all the 24 operating modes. And it also involves 25 identification of barriers, from the source to 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
30 1 environment. Those barriers that can prevent a 2 release of radioactive material.
3 In box five, in response to ACRS, we 4 recommend an exclusive search for chemical hazards.
5 Which can be done similarly to searching for the 6 radiological sources.
7 We are thinking of those chemical 8 hazards that are combined with the radiological 9 hazard, or which can impact the plant response to an 10 initiating event or may affect the properties of the 11 radiological release. But, pure chemical sources 12 will be outside the scope.
13 DR. BLEY: I'm -- I like seeing that 14 here. And I'm glad it's here. And I think this is 15 inclusive.
16 But, I -- as someone talked about 17 yesterday, we don't know what's coming in 18 technologies. We know some of them. But, there 19 might be something really new.
20 I'm not sure if there are any other 21 sources of hazards. But, it might be worth leaving 22 a placeholder for it.
23 You know, most of the things I think of, 24 can either be brought back to radiological or 25 chemical hazards, either from the poisonous aspects NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 1 of chemicals, or the energetic aspect of chemical 2 hazards.
3 But, I don't know, have you -- have you 4 really delved into that and though hard about it?
5 Are there other things that might present hazards 6 that we haven't really put on the list here?
7 MS. BIRO: Probably not, as much as --
8 yeah. We have thought a lot about that. But, we 9 can definitely take that comment and then consider 10 some more.
11 I would envision it would be hard to 12 imagine what could be possible without, -- yeah, 13 that's a challenge too, you know, not knowing what 14 kind of technology, you know, writing technology 15 inclusive.
16 Try to think of all possible other 17 hazards. So, definitely we'll take that comment and 18 think about it.
19 But, if you have anything, I would be 20 happy to consider.
21 MEMBER HALNON: Yeah, this is Greg.
22 Dennis, to your point it could be other industrial 23 or process hazards that -- not knowing what's going 24 to be connected to some of these plants.
25 DR. BLEY: Yeah. That's true. Now, NEAL 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 probably anything energetic coming out of them, or 2 poisonous really falls back under chemical hazards.
3 That's why I'm thinking this might be a pretty solid 4 list.
5 So, I haven't thought of anything 6 specifically. I'd tell you, just go ahead. But, 7 keep that in mind. You know, putting in another, 8 doesn't really help a whole bunch.
9 But, it doesn't ensure people will find 10 it. But, it might be a good reminder to the staff 11 and potential applicants to think beyond this list.
12 Is there anything else here that could lead to harm 13 to communities or people?
14 Okay. Go ahead.
15 MS. BIRO: Thank you. I appreciate it.
16 MR. STUTZKE: Yeah Dennis, this is Marty 17 Stutzke from the staff. To that point, are you 18 thinking about things like explosions?
19 DR. BLEY: Well, I thought of 20 explosions. I thought of some thermal things. And 21 then I could always back them up to chemical.
22 MR. STUTZKE: Right. Right.
23 DR. BLEY: And I -- so, I haven't 24 thought of anything yet that doesn't fit.
25 MR. STUTZKE: But, perhaps we can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 1 elaborate on the types of chemical hazards. You 2 know, into poison and energetic explosions and all 3 that.
4 MEMBER HALNON: Marty, this is Greg.
5 What I meant by other industrial processes, such as 6 if you're using a process heat or steam, or 7 something else that may not immediately think about 8 a chemical hazard, but it could be process energy 9 that you're using for an adjacent plant or 10 community.
11 MR. STUTZKE: Yes. So, I mean, the one 12 that came to mind while you all were speaking, was 13 the NGPN design to generate hydrogen for fuel 14 purposes.
15 DR. BLEY: Yeah.
16 MR. BUDNITZ: Well, what about high 17 voltage electricity?
18 DR. BLEY: Hey Bob, one at a time.
19 MR. BUDNITZ: Hi Dennis.
20 DR. BLEY: Yeah, I was just thinking of 21 electricity. That's right. I was thinking about a 22 giant Tesla effect.
23 But yeah, that's a possibility. And 24 well, radio frequency emissions. Now, that would be 25 coming from the rest of the plant, probably not from NEAL 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 the reactor itself. But, yeah.
2 CHAIRMAN PETTI: If there were 3 accelerated type systems somehow attached. You 4 know, those RF issues there that have to be 5 considered.
6 DR. BLEY: Yeah. If you generate RF 7 noise, given the cars we have now and other things, 8 you could be creating significant hazards outside.
9 So, RF and high voltage stuff maybe prongs, you 10 know, this with chemical hazards.
11 And we haven't seen a plant that really 12 introduces that significantly yet. But, we well 13 might.
14 MEMBER BROWN: How does this list, these 15 are very generalized statements. How does this list 16 take into account or identify stuff we've used in 17 some of the other design certs we've done?
18 Like a set of train tracks that's a half 19 a mile away from the plant, you know, just as in, as 20 the crow flies, which could be transporting all 21 types of chemicals. Does that get wrapped up in one 22 of these categories here?
23 Or is that irrespective of chemical 24 plants.
25 (Simultaneous speaking)
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35 1 DR. BLEY: I would think it's under the 2 chemical hazards, yeah.
3 MEMBER BROWN: Or irrespective of the, 4 both type of plant it is.
5 MR. STUTZKE: Yeah.
6 MEMBER BROWN: But, those apply. And 7 those seem to be, this is more a gen -- looks to me 8 more like a generic thing within the plant.
9 These are the things that can cause a 10 problem with the external events. Not necessarily 11 hurricanes or whatever, but transportation of, 12 within proximity, or a pipeline of some type that --
13 in proximity.
14 DR. BLEY: We've looked at those in the 15 past. I mean, --
16 MEMBER BROWN: I know. We've had a lot 17 of them.
18 DR. BLEY: Within the terms and the 19 like. But, I don't see that it has a place here.
20 So, you know, transportation or 21 something like that, would probably be on somehow, 22 on the list. Maybe this number five could be for 23 non-nuclear things. And you can have chemical, and 24 the electrical, and the transportation effects.
25 Just to make sure people look at them carefully.
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36 1 MR. STUTZKE: Yeah. This is Marty 2 Stutzke from the staff. I'd point you back to box 3 three about site characteristics. So, things like 4 pipelines.
5 Remember a number of years ago about 6 barge transportation down the Mississippi River, 7 containing liquefied natural gas and such.
8 DR. BLEY: I won't mention the plant.
9 But, we looked at one that had a fireworks factory 10 right next door.
11 (Laughter) 12 DR. BLEY: In a way that covers it too, 13 yeah.
14 MR. STUTZKE: But what I'm hearing is, 15 you think the guidance would benefit by adding some 16 specific examples.
17 DR. BLEY: I think so.
18 MR. STUTZKE: Yeah.
19 DR. BLEY: I mean, we don't want it to 20 be --
21 MR. STUTZKE: It can be overly generic 22 to the point that it's not helpful.
23 DR. BLEY: Yeah.
24 MEMBER BROWN: A characteristic is very 25 generic. And when I think of a sight, I don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 1 necessarily extend myself --
2 MR. STUTZKE: Yes.
3 MEMBER BROWN: external to the site.
4 And that's why -- that's why --
5 DR. BLEY: That's why the transportation 6 things have been identified in the past. But, I 7 would lean toward making five a little more general.
8 But, think about it. You don't want to 9 lose the chemical, because a lot of these systems 10 have chemical as major, major part of it.
11 MEMBER BROWN: Where are you now?
12 MS. BIRO: Well, I was finished with box 13 five.
14 MEMBER BROWN: Okay.
15 MS. BIRO: Do I have any more comments?
16 (No response) 17 MS. BIRO: No? Okay. Thank you. So, 18 I'll proceed through. So, in box six, one would 19 also need to consider the scope of the analysis, 20 whether the PRA is targeted as opposed to using 21 AERI, which would define the depth of the analysis.
22 In box seven we proceed to the 23 identification of plant specific safety functions.
24 And Identification of the systems needed to perform 25 safety functions with the associated success NEAL 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 criteria.
2 And then in box eight, --
3 MEMBER REMPE: So, I guess I'd like to 4 interrupt you on box seven. I'm looking at the text 5 of -- I basically was saying it a different way, my 6 comment from yesterday about critical safety 7 functions.
8 And the text in the report says safety 9 functions can be defined in many ways depending on 10 the plant type. And then it goes on about, they can 11 do it within a certain priority framework.
12 Reactivity control is the foremost 13 function, because the amounts of heat must be 14 removed from the core, it depends on how well this 15 function is accomplished.
16 And I'm thinking back when we talked to 17 the folks in Framework A, how they had put radiation 18 release as the primary safety function.
19 MS. BIRO: Yeah.
20 MEMBER REMPE: And in fact, I had to 21 argue to get control reactivity included, because 22 we'd had some issues with some plants might come 23 back to power. Because I -- this facility each 24 iteration, and why do you do this?
25 And I had -- and it wasn't just 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
39 1 staff. It was some other members. And it's like 2 well, we've had this issue with people returning to 3 power.
4 And I was really happy that they had 5 modified the text in Framework A to say such as, and 6 they included that. And they left it open for other 7 things too.
8 So again, I'm pleading with the staff, 9 why don't you put the same kind of text that's in 10 Framework A in Framework B, because if you look at 11 other places in the regulatory stuff that exists, 12 we've got a mishmash of stuff.
13 And I know Dennis has said, you may have 14 someone else write it. And their opinion comes into 15 a draft guide instead of a consistent story.
16 And so, for regulatory consistency, 17 efficiency, et cetera, let's use the same text here, 18 please.
19 MS. BIRO: Yes.
20 MEMBER REMPE: And so again, I hate to 21 pick on you, but this was a good example to 22 illustrate the point. And thank you.
23 MS. BIRO: No, and thank you for 24 pointing that out. It certainly can improve the 25 text. And you know, proceed and try to change that.
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40 1 MEMBER REMPE: Yeah. I just think it's 2 -- I like what they did with Framework A. And so 3 again, this is not even just the reg guide, this is 4 in the draft of the language. So, thanks.
5 MS. BIRO: Okay. Great. Thank you.
6 Okay. So, in box eight then, we identify the end 7 states for, define the end states for event 8 sequences. It's going to be used to support the 9 event sequence elimination selection.
10 So, then moving down to the bottom of 11 the slide, we also align a part where the selection 12 of the analysis methods to be done. This can be 13 done parallel and in sequence. It doesn't really 14 matter.
15 So, in box nine, selecting methods for 16 the identification of initiating events. As 17 attached on those earlier on the other slides.
18 In box ten, identify strategies for 19 grouping initiating events. And in box 11, consider 20 any analytical methods for event sequence 21 delineation.
22 So, things like event trees that are 23 very well-known in the PRA community. Even sequence 24 backgrounds are somewhat similar to those event 25 trees, et cetera. Next slide, please.
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41 1 MEMBER BROWN: Before you go to the next 2 slide.
3 MS. BIRO: Yes?
4 MEMBER BROWN: Back to 63 again.
5 MS. BIRO: Slide 63, please.
6 MEMBER BROWN: The previous slide.
7 Okay. I hope I don't forget the second one I want 8 to ask, after I ask the first one. I'm so old I 9 might not remember all those.
10 You say the first step in this is 11 selecting the licensing framework. And it just 12 figured in my thought is, a plant is a plant is a 13 plant.
14 You've got a plant design you've 15 envisioned, why does selecting the licensing 16 framework frame what you do?
17 I mean, I've got to consider --
18 regardless of the framework, I will end up with 19 events to apply, whether I license it under A, B, 20 non-A or non-B, whatever the case maybe.
21 MS. BIRO: Um-hum.
22 MEMBER BROWN: So, because you've got to 23 cover those, you've got to protect yourself for 24 those regardless of the framework. The framework 25 doesn't say you don't have to meet certain NEAL 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 standards.
2 All it does is say how you have to 3 present it and identify what it can do. But, the 4 framework problem is still there.
5 So, I have a little bit of a problem 6 with worrying about whether I've got a framework 7 selected or not.
8 You can design a plant with a new 9 concept, particularly with the advanced plants we're 10 seeing, and have no idea how you're going to try to 11 license it, other than you know the NRC is going to 12 ask you to follow some guideline.
13 But, those are the hazards and the 14 events that you have to deal with, are subject to 15 the plant, not the framework. That didn't come out 16 to me as a lot of that's really important or even 17 relevant.
18 So, I would have terminated block one.
19 MS. BIRO: Yeah.
20 MEMBER BROWN: That's my personal 21 thought. Of just one member by the way.
22 MS. BIRO: Yeah.
23 MEMBER BROWN: Just -- go ahead.
24 MS. BIRO: No, go ahead. You're right.
25 I think maybe it's a little, because you put it on a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 1 slide, and you only see what's in here.
2 I agree that most of the stuff is 3 generic. That you might not utilize the framework.
4 But, if that's become an important role later on the 5 graph when you make the licensing events, that's 6 when that delay it becoming.
7 MEMBER BROWN: But, a licensing event is 8 -- that, a hazard to the plant is a hazard to the 9 plant regardless of how you license it. It doesn't 10 go away because I decided to a Part 50 as opposed to 11 a Framework A, Part 53.
12 DR. BLEY: So Charlie, I'm trying to --
13 I'm trying to get my head around what you're saying.
14 What you're kind of saying is, before you branch to 15 sheet two, is where we ought to be selecting the 16 licensing framework?
17 MEMBER BROWN: That might -- yeah, I 18 didn't look at, I'd have to look at sheet two again.
19 That's probably the point.
20 I mean, at some point you get through 21 all this looking at your plant. Then the applicant 22 has to decide what framework they're going to use in 23 order to bring it through, and hope they don't miss 24 something.
25 DR. BLEY: That helps me a little with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 1 my comment earlier about that table, that in five 2 you didn't need anything from this reg guide if you 3 were following one of those enhanced approaches.
4 And yeah, you need to do this no matter 5 what approach you're doing.
6 MEMBER BROWN: Well, that's --
7 DR. BLEY: Well, let's think about that.
8 Maybe it's --
9 (Simultaneous speaking) 10 MEMBER BROWN: Well, I'm just throwing 11 that on the table. I don't --
12 DR. BLEY: Maybe it belongs somewhere 13 else in the chart.
14 MEMBER BROWN: I don't like the idea 15 that somebody comes into their plant design and 16 says, I'm going to select a licensing approach. Now 17 I'm going to go design a plant.
18 That's bass ackwards. Okay. So, in 19 polite terminology.
20 MS. BIRO: No, I agree. I envision the 21 designers will design their plans for us then figure 22 out which licensing framework works best for them.
23 MEMBER BROWN: They're doing that now.
24 MS. BIRO: Yes, yes.
25 MEMBER BROWN: Okay. The second, 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
45 1 second thing is, and this is subtle. The fact is, I 2 encountered this four or five years ago, and I just 3 now thought of something that I didn't think of 4 then, just because we're in this process, and one 5 other thing started with the other day.
6 We talk about in technology inclusive.
7 I'm the electric reactor innovation control. So, 8 I've got stuff that's going to shut down the plant, 9 operate it, monitor it, control it, et cetera, et 10 cetera.
11 In the trip and safeguard systems, 12 whatever the configuration they may take, is this 13 technology you use to influence how those systems 14 respond. You can change, like for analog systems 15 you can have the power go on and off. The stuff 16 comes back. Things happen.
17 In the computer-based systems, if you've 18 got microprocessors, and memory, that memory is 19 working typically in what's call RAM, random access 20 memory. It's nonvolatile, it's there all the time.
21 You lose power then you'll wait just like your 22 laptops and other stuff.
23 But, there are other types of digital 24 devices, such as FPGA, some which are called 25 volatile, where if the power goes away, what you've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 1 programed into them disappears.
2 And if nonvolatile, where they're 3 permanently programmed and they don't change. In 4 other words, power goes away, power comes back, all 5 the soft -- everything stays the same.
6 It's almost like an analog computer. And 7 you don't have to worry about software being 8 changed, because it's a hardware you've programmed 9 little logic gates, and they're fixed.
10 But, you could establish if you've got a 11 combination of a volatile memory and a nonvolatile 12 memory for diversity purposes. That volatile memory 13 when power goes away has to be reprogrammed as it's 14 booting back up.
15 But, if the power cycles, you could be 16 partway through your reboot, and all of a sudden 17 you've lost it. And how many times can you cycle.
18 How many times have you been in your house, and oops 19 the lights go out for microseconds, or three 20 seconds, or a minute later, bang it comes back.
21 So, you get these cycles going on and 22 off. You go, oh my God, what's happening with my 23 computer, with my television, they're toast or what 24 have you. You don't even think about, how do you 25 test for that?
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47 1 How do you envision what that would 2 happen? I don't know how to include those types of 3 things in this process, because it's new.
4 Like I say, I just thought of this the 5 other day when we were going through something. And 6 as we, actually as we were talking yesterday with 7 Marty, when he did some of the introductions.
8 MEMBER KIRCHNER: Well Charlie, this is 9 Walt. To your point, when you look at this flow 10 sheet, my sense is you have a fairly mature, robust 11 design going into deciding your licensing strategy 12 or selecting a framework, whether it's 50, or 52, or 13 53.
14 And you've done much of this already as 15 part of your design process. So, my sense is, to 16 your first comment, that when I look at this, maybe 17 if you want to call this the design process, not the 18 licensing process, you've probably gone through this 19 loop that's on this sheet.
20 MEMBER BROWN: Well, we didn't.
21 MEMBER KIRCHNER: Right. If you try, in 22 terms of testing your own design before you then 23 enter into the licensing process.
24 You see what I'm saying?
25 MEMBER BROWN: If you would like to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 1 think that's the occurrence as to what goes on. I 2 actually had an experience where that was not 3 thought about in the proposal.
4 If it would have adapted to the new 5 technology to the plants, that would be fine. I was 6 in the Naval nuclear program for 30 years.
7 MEMBER KIRCHNER: Right, right.
8 MEMBER BROWN: And I'm just telling them 9 so they'll know where I came from. And the decision 10 to do something or not do something was simply based 11 on, it did not recover.
12 I mean, it took eight minutes for the 13 stuff to come back. And the power went off and just 14 one time it came back, regardless of a repetitive 15 one.
16 And that was where we had the 17 microprocessors involved. We've got other 18 circumstances with other electronic technologies 19 where a rapid reboot and then loss, reboot, then 20 loss, what does that do?
21 Does that mean your diversity part never 22 comes back the way it should? How do you factor 23 that in in your overall long term failure modes and 24 effectiveness?
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49 1 addressed any. I'm just throwing that out, I'm a 2 little bit nervous about cat -- about just talking 3 about licensing events when they can be compromised 4 by even some technologies or apply to the plant that 5 you don't easily think of.
6 But, your electric plant, if you've got 7 a 1E electric system, or you've got DC backup, so 8 you don't have that cycle going on, that's a 9 correction.
10 But, some of them are saying now we 11 don't need 1E, or DC power backup.
12 MS. BIRO: Um-hum.
13 MEMBER BROWN: So, you don't know, it's 14 a struggle. I'm having, I'm struggling with that 15 now. So, I'm just bringing this up hoping somebody 16 else can tell me how wacko I am.
17 And this is nothing. But, you can go 18 on. It's just, I don't know how to throw that into 19 you all's thought process.
20 What are the extreme circumstances with 21 any of the technologies that we're using that may 22 not be covered under these. We try to do it with 23 the external events like, you know, pipelines and 24 all that.
25 MS. BIRO: Yeah.
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50 1 MEMBER BROWN: I think there's some 2 potential for some other things that you may not 3 think about during the design phase, or laying out 4 your overall architecture for both your controls 5 monitoring protection and the rest of the plant.
6 Tough stuff. I know, I'm just a crazy 7 guy there.
8 MS. BIRO: Yeah. No, you're not. I 9 mean, we are using those devices. And I have my 10 brand-new car go crazy on me. It's all driven by 11 wire. So, you know, you have to reset it and start 12 over. But, you know.
13 MEMBER BROWN: Blocking the middle of 14 the Interstate after you've been doing 60 miles an 15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />, right?
16 MS. BIRO: Yeah, right.
17 DR. BLEY: You know, Charlie's comments 18 got me to look at this in a new way. And this is 19 aimed at Marty as much as anybody else.
20 This is set up the way we've always done 21 PRA for light water reactors. In that there's a 22 plant there and now we come in to do the PRA.
23 And we collect all the information about 24 the design and everything that's there. In these 25 new processes, we're hoping people do the PRA 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
51 1 parallel with developing the design. Which means 2 you aren't quite following the same process. You're 3 kind of turning your way.
4 And my wonder is along Charlie's lines, 5 how would you draw this differently if you were 6 telling people how to do this as part of the design 7 process, and then later on, you kind of polish it up 8 by doing those things in here that will already be 9 in place?
10 So, it's drawn from the mindset of the 11 plant already being there. And now we're going to 12 start thinking about this stuff.
13 And that's not the way we hope it goes 14 in the future. So, but that's kind of a hand 15 grenade over the wall after all the work you've done 16 here.
17 CHAIRMAN PETTI: So Dennis, I can just 18 tell you that we -- this was done for the Itto 19 Project in a design setting.
20 And it was done in stages. So, there 21 were initial FMEAs done. You know, interactions 22 with the designers.
23 And you looked back and you did them 24 again. So, there was an iteration as the design 25 matured, or if there were options out there.
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52 1 And there's some really odd technologies 2 compared to fission, when you start talking about 3 some of the fusion systems, there's earlier systems 4 that use plasma.
5 And it was just a strong coupling and 6 iteration. So, it's kind of like a third dimension, 7 if you will, of these flowcharts where it's in the 8 design.
9 And so yeah, it's not linear, it goes 10 back and you do it again as you go on. So, it is 11 more complex. But, --
12 DR. BLEY: Your design spiral form 13 shipbuilding kind of thing. And at least it needs a 14 discussion of that.
15 This is -- this is drawn from the 16 standpoint of the plant already being there. And 17 now we're going to patch this onto it.
18 And that's not the way we expect this to 19 be done. And I think, you know, you can't lay out 20 all of that spiraling reiteration in a sensible 21 flowchart.
22 But, you could have an introductory 23 chart that describes that process, and then modify 24 this a little bit to imply how it, how it works as 25 you move through the development of the design and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 1 to the point where you're going to get a license, by 2 the time you're actually going in for selecting the 3 licensing framework and for the license.
4 Yeah, all this stuff is here, but a lot 5 of the analysis has already been done too. So, I 6 think you really need to address that.
7 And you could all sit around and pull 8 something together to help that work better. But, I 9 think you got to address that somehow in this 10 document, I believe.
11 MS. BIRO: And thank you. Yes, we were 12 like thinking how to draw arrows for iteration, for 13 the iterated process. And it was getting the 14 flowchart so busy we just kind of left it out.
15 But, it was implied. And maybe we can 16 enhance the other paths to highlight that that, you 17 know, everything here is iterated.
18 It's not on one straight shot. You 19 know, because you know, as you go advance in your 20 design to even site, you know, new information comes 21 in all the time.
22 So, they do have to keep them going back 23 to make sure everything is covered.
24 DR. BLEY: Yeah. There's some nice 25 examples that are more than 50 years old, back from NEAL 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 shipbuilding.
2 And they do this design spiral, which 3 implies you go around this design process and then 4 you reiterate. But, it gets more complete as you 5 spin out through the spiral and pieces are fitting 6 in.
7 Now, something like that as an 8 introduction, and then say you apply the pieces of 9 this that are appropriate as you go through that 10 evolution, might give you a way to make that 11 clearer.
12 But, otherwise you run into the problem 13 that hit Charlie, that this isn't in the right 14 order.
15 MEMBER BROWN: The thing that triggered 16 me was the loss of offsite power type circumstance.
17 But, what about the loss and then reapplying, loss 18 and reapplying, which occurs commonly in the 19 commercial systems?
20 And I completely lost track of that when 21 in this other design, based on the nature of the 22 memory they were using and the diversity approach.
23 Which is a fine diversity. Not a problem with that.
24 It was, how does it respond?
25 I actually rejected an application for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 1 technology in my program because when they turned 2 off the power, the displays didn't come back for 3 eight minutes and the operators were blind.
4 MS. BIRO: Um-hum.
5 MEMBER BROWN: Whereas analog stuff 6 comes back within about the blink of an eye. It's 7 like 200 to 300 milliseconds.
8 This might not be in spec. But, you 9 know about where the plant is. And that's the 10 important thing for the operators to know.
11 And it was because of proprietary 12 software. It could have been done otherwise, the 13 vendor decided after fully we weren't going to use 14 his -- the technology.
15 We spent six months redesigning it such 16 that it came back and when we turned the power off 17 it was back within the blink of an eye, 250 18 milliseconds the graft displayed.
19 And they were told this was the way this 20 stuff always works. But, what do you expect? Well, 21 can't be applied in an operating plant.
22 And I'm afraid we're losing, we've got 23 these big picture type stuff, like this, which is 24 good. But then I'm down in the weeds a little bit 25 of how the memory units and the processors are used.
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56 1 As they can influence what goes on with 2 these big ticket events. That's my concern.
3 MS. BIRO: Yeah.
4 MEMBER BROWN: That I've lost that. And 5 I don't know how. Don't ask me to explain it. You 6 know, I'm not a designer. I'm just and old guy 7 thinking about stuff out of the box.
8 MEMBER REMPE: Well, in fairness to the 9 draft guide, you do mention that the design process 10 is iterative in the introduction about incentive use 11 of this reg guide.
12 And you talk about that you, it's 13 expected you'd go through the process several times.
14 And you may want to expand it.
15 MS. BIRO: Yeah. I like it.
16 MEMBER REMPE: But, it's not like you're 17 getting acknowledged.
18 DR. BLEY: I come back to, yeah, but 19 when you have figures and tables, people really 20 focus on them and lose some of the text, no matter 21 how hard you try to tell them not to do that.
22 MEMBER BROWN: No, I agree. Dennis, 23 you're 100 percent right. The figures and tables 24 are, give you clear, a clear path that you think you 25 can go through and get to the end of the whole game.
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57 1 And we do lose sight of the words 2 sometimes. It looks like word salad when you read 3 them alone.
4 MS. BIRO: Yeah. It takes a lot more 5 patience.
6 MEMBER BROWN: Sorry to interrupt.
7 MS. BIRO: Oh, no, no, no. You didn't.
8 MEMBER BROWN: Sorry to drag us through 9 this potpourri of oddball thought process.
10 MS. BIRO: Yeah, not at all. No, I --
11 the one thought I had while you were talking, I 12 wonder if some of those things will be covered under 13 the testing program for electrical components?
14 And I'm not an electrical engineer, so I 15 don't know what kind of requirements we have on 16 digital systems.
17 MEMBER BROWN: Never been -- never been 18 mentioned, okay. And I didn't have a problem in 19 that program because we didn't use nonvolatile 20 memory. It was always fixed memory.
21 So, you never lost your basic program.
22 And we tested it for loss of power and non-loss of 23 power. As a matter of fact, you couldn't modify it 24 with UV programmable read-only memory.
25 MS. BIRO: Okay.
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58 1 MEMBER BROWN: Such that once you used 2 the ultraviolet light on it, you had to use new 3 software. Take the chip out and put a new chip in.
4 That was then. Now you use a case work 5 plan where you electronically change it, which 6 introduces other issues that you have to.
7 MS. BIRO: Yeah.
8 MEMBER BROWN: Anyway, it's just 9 sometimes we lose sight of what's inside when we're 10 trying to look at the big picture stuff. And the 11 little stuff can screw this stuff up.
12 That's basically the point I'm trying to 13 -- I don't know how to address that.
14 MS. BIRO: Yeah. It sounds like a new 15 initiating event. A multi -- repeat the loss of 16 outside power or something.
17 MEMBER BROWN: Well, most of the outside 18 power is not necessarily --
19 MS. BIRO: Yeah. Yeah.
20 MEMBER BROWN: It's a fixed thing. You 21 lose it, now how do you survive? Well, we've got 22 diesel, or we've got this.
23 MS. BIRO: Yeah.
24 MEMBER BROWN: You've got battery back 25 ups. Everybody's happy as a clam.
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59 1 Well, what if you now design a plant you 2 think is totally safe because it's got all these 3 nifty advanced characteristics. So, you don't have 4 the backup power, you have the same integrity or 5 pedigree because it's quote, not required.
6 MS. BIRO: Um-hum.
7 MEMBER BROWN: And then you miss this 8 little thing inside. And now the power comes back 9 and all of a sudden half of your stuff is not 10 working properly, and you don't know it.
11 Anyways --
12 MS. BIRO: Yeah. No, I think that would 13 be a challenge to like addressing the PRA. And I 14 think you'll have to address it before the PRA 15 influence.
16 MEMBER BROWN: No, you're 100 percent 17 right. That's why I don't -- I'm not, I haven't 18 figured it out yet.
19 MS. BIRO: Yeah.
20 MEMBER BROWN: I'm not a big PRA person.
21 I believe in using them. I just don't believe in 22 that they are the all to end all.
23 I think you have to use regimented 24 engineering skills if you go through the whole 25 process. Don't get wrapped up just because the PRA NEAL 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 says it's okay, it's okay.
2 MS. BIRO: Um-hum.
3 MEMBER BROWN: I think you have to have 4 a lot of other input into that at the same time.
5 MS. BIRO: Absolutely.
6 MEMBER BROWN: So, all right. I'm 7 through now. I've had enough to say.
8 MS. BIRO: Well, thank you. So, let's 9 proceed to the next slide.
10 So, next the outline process obviously 11 proceeds to identifying the list of initiating 12 events by applying the selected methods and grouping 13 strategy.
14 We also included in box 14, a step for 15 reviewing any relevant operating experience, if 16 there is any. As well as any prior relevant 17 initiating event analyses that are relevant.
18 Another to ensure that the list of 19 initiating events is comprehensive. Similarly in 20 box 16, apply for the event sequences in box 16, 21 apply the selected methods and analyze the plant 22 response to initiating events to delineate event 23 sequences.
24 I wanted to pause on boxes 15 and 18, 25 regarding the independent review and QA for issuing NEAL 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 events and event sequences. So, for those 2 applicants that are developing a PRA, the typical 3 PRA processes include a peer review of initiating 4 event, selection event, sequence delineation.
5 So, we expect those PRA processes will 6 continue to be used for this. However, they are 7 also a part of not having the PRA through use of 8 AERI.
9 And we expect that for those, an 10 analysis will be QA controlled under the relevant QA 11 program for the selected licensing framework.
12 DR. SCHULTZ: Just one comment there.
13 And a recommendation. It's not unusual to see it 14 presented this way.
15 But, my concern is that when you have 16 boxes that are either intermediate, or at the end of 17 a program, and you say this is where quality 18 assurance is going to be applied, it's not the 19 proper way to perform quality assurance.
20 MS. BIRO: Um-hum.
21 DR. SCHULTZ: What I would recommend is 22 that early in the program, probably in box two, 23 where you're picking the team to do the work, you 24 would also make sure and identify what the quality 25 assurance pro -- that there is a quality assurance NEAL 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 program in place in order to conduct all of the 2 boxes that follow.
3 And what you could include in these 4 boxes, is to assure that internal and independent 5 reviews are done. The internal reviews would be 6 part of the QA program. The independent reviews 7 would also be part of that program, but separate 8 from quality assurance.
9 What I'm concerned and it happens many 10 times that someone does a PRA and then tries to 11 apply quality assurance after a lot of the work is 12 done, it's not what quality assurance is about.
13 MS. BIRO: Yeah. Thank you. That's a 14 very good point. Certainly we can put that earlier 15 in the process for establishing the right program 16 for quality assurance.
17 MEMBER HALNON: Yeah, this is Greg.
18 I've just got a quick question on independent 19 review. I'm sorry, did I talk over somebody? I'm 20 sorry.
21 MEMBER KIRCHNER: Oh, Greg, go ahead.
22 This is Walt.
23 MEMBER HALNON: Okay. Well, a lot of 24 the new technologies that we'll see, and my 25 experience with the peer reviews is that you get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 1 people that are familiar with the plant design and 2 plant technologies such as BWRs or PWRs, or 3 something to that effect.
4 But, the new technology that maybe first 5 of a kind, very proprietary, how do you envision an 6 independent review being done on something like 7 that?
8 MS. BIRO: Well, independent means 9 somebody who is not involved in the process. So, I 10 would guess they'll have to build their own 11 proprietary and have some contract design to make 12 sure they do not disclose what they're reviewing.
13 I don't know if there's anything more 14 than that.
15 MEMBER HALNON: Okay. But, certainly a 16 peer review would not be plausible, since there's no 17 real peers in the industry.
18 I guess I'm just kind of thinking 19 through using terms that we're familiar with. With 20 new technology may not comport, may not equate to 21 the traditional way of doing things.
22 MS. BIRO: Okay.
23 DR. BLEY: Well, you know Greg, I'm 24 thinking back to the documents we've seen from the 25 staff. And the computer code development work we've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 1 seen from the staff.
2 And the standards work that was done for 3 these new kinds of reactors. And that had to bring 4 together combinations of people who understood 5 engineering and physics, and maybe no experience on 6 this particular design, but kind of a broad 7 knowledge of the different kinds of designs we've 8 looked at since the '50s, or '40s on some of it.
9 So, I think there's expertise around.
10 It's just we don't have operating experience on 11 these things.
12 So, I don't think it's impossible to 13 assemble teams to do it. And we've been doing parts 14 of it now for quite a few years, getting ready for 15 potential licenses.
16 It's an issue. And if you had a lot of 17 these going on at once, the pool of people who might 18 be able to participate and help, might be fairly 19 small.
20 So, we might get into some problems 21 there. I don't think it's the fact that since we've 22 never operated one, we don't have anybody who can 23 think about the issues that are involved here.
24 MEMBER HALNON: Yeah. I get that 25 Dennis. I appreciate it. I guess I'm, in thinking NEAL 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 my own experience with a peer review, I did a very 2 intense search for folks that one, first were 3 independent, and second had the expertise in the 4 specific design.
5 But, I get the more generalist approach.
6 I understand that.
7 MEMBER BALLINGER: This is Ron 8 Ballinger. Dennis and I have gone back on this a 9 few times. I'm just trying to find another way, 10 another title for independent review.
11 I think I would probably prefer the 12 words independent assault.
13 (Laughter) 14 MEMBER BALLINGER: And I'm not really 15 saying that tongue and cheek. DOE and other 16 organizations have what are called murder boards, 17 which go after something and ask the question, how 18 can I make it fail?
19 How can I mess it up? Rather than a 20 bunch of check boxes, it says all -- this event 21 sequence looks good and that, and other things. And 22 so you get yourself into a habit of sort of 23 confirmation bias.
24 So, I think the devil is in the details 25 for box 18. Am I saying it right, Dennis?
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66 1 DR. BLEY: Well, yeah.
2 MEMBER KIRCHNER: Well, I would offer a 3 different view, Ron. I would hope that this murder 4 board so to speak, as you say, was part of the 5 design process. Not wait until you're assembling 6 something for the NRC.
7 I'd like to remind everyone we're in the 8 licensing boxes right now.
9 MEMBER BALLINGER: Yeah. It's just a --
10 MEMBER KIRCHNER: And one hopes that 11 this was done and going back to, you know, in my own 12 humble opinion, the best use of PRA would be to 13 integrate with the PRA during the design process.
14 Not wait until now, we've decided okay, 15 we're going to go in front of the NRC, and here's 16 our licensing strategy, and so on.
17 I -- so, -- I would --
18 MEMBER BALLINGER: And I would say 19 there's two murder boards.
20 MEMBER KIRCHNER: I wanted to say two 21 things. One, Steve, I wanted to reflect on Steve's 22 comment. The QA has to be in the beginning.
23 You can't back fit it or apply it at the 24 end of the processes. So, to me the QA program is 25 fundamental throughout the licensing process for 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
67 1 applicant.
2 If you go back to the previous sheet, 3 all those methods to be accepted by the NRC, usually 4 are QA'ed qualified methods that have been 5 addressed in topical reports and so on.
6 So, QA's got to be up at the front.
7 Not, you know, all of a sudden applied here. And 8 then, I'm not sure what independent review this is.
9 This is an applicant's licensing 10 process. You're giving guidance to an applicant, 11 this is a way for you to pick initiating events.
12 Let's just stick with the top box.
13 So, that independent review, I mean, 14 that's up to the applicant to really scrub. So, 15 what you're recommending to the applicant, is 16 assemble a group of quote/unquote, independent 17 experts, and go through this process.
18 That's fine. I think a lot of the more 19 experienced companies do this as a part of their 20 design process and as part of assembling their 21 application and their -- and developing their 22 licensing strategy.
23 So, I think this is a good 24 recommendation. The independent review really comes 25 when the NRC does its review of what the applicant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 1 submits.
2 I mean, this hopefully here, doing it 3 here as the applicant goes through identifying 4 initiating events and the event sequence selection, 5 just strengthens their -- their licensing case if 6 you will, the safety case for presentation to the 7 NRC.
8 But, the real independent review is 9 coming later when you actually put the application 10 in. That's just an observation.
11 MEMBER DIMITRIJEVIC: Well, both. Is we 12 have discussed this multiple times in some of our 13 reviews. This is where the PRA differences from, 14 you know, Chapter 15.
15 There is the PRA is not a part of, you 16 know, of the applicant's program. And what they 17 mean independent review, they mean assembling the 18 experts from the different plants.
19 And you know, the totally, not connected 20 with the facility they're reviewing. And experts in 21 certain areas reviewing with cold peer review.
22 And that peer review is usually done 23 late in the process when the PRA is complete. The 24 experience today is that -- that the -- and that 25 peer review, in my opinion, it doesn't really, can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 1 ensure the quality, because it just ensures that 2 certain things are done.
3 So, that's why the Greg point is very 4 well taken. Because usually, these peer reviews 5 take two weeks to review all aspects of the PRA.
6 And therefore, like was happening if 7 they're reviewing initiating events, they would base 8 that on their experience. They will not redo or go 9 through the process that will -- that makes this the 10 experience of the events they have been seeing, they 11 have seen, and expect to see.
12 And that's where the new technologies 13 could be challenging, because you know, when we 14 start talking about these chemical events and things 15 like that, there's going to be all the new 16 challenges. So, the things which they have not been 17 seen before.
18 So therefore, they cannot be reviewed in 19 a day. Which I think is, probably, you know, the 20 shortness of those peer reviews in the general.
21 So, it's very good that we're 22 discussing, because there obviously the challenge is 23 to the, what does a QA mean here, when it should be 24 done?
25 That should be considered. And they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
70 1 not a part of the QA program section. So, I'm not 2 sure where that should be put.
3 But, obviously there will be a lot of 4 challenges to this. Especially for the things that 5 should be done up front.
6 You know, in addition to these peer 7 reviews with independent teams of people from 8 different facilities, there is also self assessment.
9 But, can that cover this? I'm not sure.
10 So, I just want to say that this is 11 opening a lot of, you know, points that should be 12 considered.
13 DR. BLEY: This is Dennis again. I'm 14 want to come back to, and Walt was hitting on it a 15 little bit.
16 Back to this idea that what we've got 17 here in the flowcharts, and not just the flowcharts, 18 in Section Charlie of the reg guide, which tells you 19 how to do this stuff, is it looks like applying all 20 of this to a plant that was already designed and is 21 sitting there.
22 So, at least in Section Charlie, you 23 need a pretty thorough discussion of how this works 24 from the beginning design through the whole process.
25 And maybe just having that laid out in a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 1 new first section, perhaps with a graphic, would 2 help. And then explaining that, you know, not all 3 the parts of the flowchart apply at all those 4 different stages, would make it work.
5 On QA, I just chime in on this.
6 Probably been discredited by now. But, I've always 7 liked the old Crosby book about quality is free.
8 You know, and you can't put quality in 9 by doing, taking a look after everything is done.
10 It's got to be built in from the beginning.
11 So, I agree with Walt on that part. And 12 I don't know where you show that in here. Vesna's 13 right that -- I think Vesna's right in that the ones 14 you've drawn in this, at least number 18, is that 15 final outside look to really have an independent 16 look.
17 But, somewhere in here you need to talk 18 about checking quality all the way from the 19 beginning.
20 MS. BIRO: Absolutely. All right. So, 21 I have one more slide to talk about. Next slide, 22 please.
23 So, now finally, the last slide for 24 proceeding to the licensing event definition. So, 25 what we showed on the previous slide applied to old NEAL 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 frameworks, the licensing -- with the identification 2 issue and events, and event sequences.
3 And now we see where our chart is 4 splitting up a little. So, on box 19 we check, is 5 this PRA? And if PRA is developed, of course, those 6 initiating events and event sequences will have to 7 end in the PRA.
8 And then if the licensing one is a 9 project, LMP is being used for enhanced use of the 10 PRA, would direct to Reg Guide 1.233 for -- as the 11 relevant guidance for licensing event 12 identification.
13 Otherwise, if LMP is not used, and we 14 move to box 22, that big box in green, so this was -
15 - would be either traditional use of the PRA or no 16 PRA at all through the use of AERI, which now we 17 still are and that remains in the scope of PDG 1413.
18 So, in box 22, the designers and 19 applicants are expected to define the strategy for 20 grouping event sequences to come up with the 21 licensing events.
22 So, the event sequences can be grouped 23 by frequency, which can be estimated qualitatively 24 or quantitatively.
25 They can also be grouped by type of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 1 event, which can consider specs such as plant 2 response following initiating events, similarity of 3 challenges and safety function, or similarity in 4 pathways that relate to the release of radioactive 5 material.
6 In box 23, apply the licensing event 7 grouping strategy. We say that all identified event 8 sequences should be mapped or licensing event 9 categories, so no event sequences should be 10 eliminated.
11 In box 24, identify the limited cases 12 for each group of licensing event. And then in box 13 25, we have a comparison to a predefined list.
14 We added this because comparison with 15 the SOP is legally required currently in Parts 50 16 and 52. It seems like there is an effort to 17 eliminate that in Part 50 and 52, but we just want 18 to be consistent with the current regulations.
19 And then again, our favorite, box 26, 20 independent review of QA. Our favorite is for 21 licensing event identification.
22 So, as I mentioned, now we are not under 23 the umbrella of the PRA, so everything in here, we 24 believe, will fit under the QA program for the 25 applicable -- applicability of the program for 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
74 1 selected framework.
2 Lastly, so then the end of the guide is 3 where we come up with the list of licensing events.
4 So, that's the end of PDG 1413.
5 Once this is done, one will be expected 6 to proceed with transient and accident analysis.
7 And perform design basis accident and radiological 8 consequence analysis before entering into the 9 guidance in the next guide that we produce, PDG 10 1414, which my colleague, Alissa, will be covering 11 next.
12 CHAIRMAN PETTI: So question. First of 13 all, this will be a good time for a break --
14 MS. BIRO: Absolutely.
15 CHAIRMAN PETTI: Before we move on. You 16 know, when I think about this, and I think about the 17 words traditional and enhanced, we're using a 18 shorthand, I understand that.
19 I think though in either case, we're 20 arguing that the PRA needs to be done in parallel 21 with the design, not later. Which is frankly what 22 happened with the existing fleet, because we built 23 them and then PRA came along later.
24 MS. BIRO: Um-hum.
25 CHAIRMAN PETTI: So, the word NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 1 traditional doesn't mean we want to do it the way it 2 was done with the traditional fleet. Right?
3 And so I think emphasizing that point in 4 the text up front, I think is important. That could 5 be done in either path.
6 MS. BIRO: Yeah. That's a good point.
7 CHAIRMAN PETTI: That's good.
8 MEMBER KIRCHNER: Mihaela, this is Walt 9 Kirchner. Just a minor observation. Probably you 10 want to connect that box in the upper right to the 11 bottom.
12 I mean, the end result is a list of 13 licensing events in either case. Isn't that the 14 case?
15 It says, follow NEI 18-04 as endorsed in 16 Reg Guide 1.233.
17 MS. BIRO: Okay. Good point. Yes.
18 MEMBER KIRCHNER: But the end point is 19 your lower right box. You know, that's just the 20 optics.
21 MS. BIRO: Yes. Yes, I agree with you.
22 Yeah, that would be a good arrow to draw there to 23 kind of illustrate that. Yeah.
24 MEMBER KIRCHNER: And to Dave's point, I 25 -- on this traditional use of PRA, I've always felt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 1 the best use of PRA would be to iterate with the PRA 2 during the design process.
3 CHAIRMAN PETTI: Yeah. I agree.
4 MEMBER KIRCHNER: And that's -- that's 5 the opportunity space that's there going forward for 6 advanced designs, in my opinion.
7 MS. BIRO: Yeah. Yes, and I believe 8 that's the case for newer reactors like the NuScale.
9 They've been using the PRA with their design.
10 But, they're not using LMP, right.
11 DR. BLEY: That's right.
12 MS. BIRO: Yeah.
13 DR. BLEY: I just want to get something 14 straight. I was trying to lay these three charts, 15 and they're in the, in your guide.
16 We're looking at things, and early on, 17 we're picking methods to apply in the various cases.
18 And then I'm a little confused, because we come into 19 initiating events analysis and in sequence selection 20 where we identify initiating events and the event 21 sequences.
22 And then we come to the last chart, and 23 we're ending up with the same output. So, there's a 24 little confusion for me of what's different, 25 especially between Chart Two and Chart Three.
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77 1 MS. BIRO: Okay. Well, Chart Two is, it 2 just showed the main parts of the analysis, right.
3 Well, in Chart One we just tried to show the 4 preparatory work before you start, you know.
5 DR. BLEY: Yeah, I got that.
6 MS. BIRO: So, those slides. And then 7 Three would be licensing events. So, here we tried 8 to show where you start splitting up the guide.
9 Like the fact that Reg Guide 1.233 is being used.
10 But other than that, I think they might 11 be pretty similar.
12 DR. BLEY: So, Chart Two is identifying 13 the initiating events and the sequences that come 14 from them.
15 MS. BIRO: Um-hum.
16 DR. BLEY: And Chart Three is sorting 17 through those and picking the ones that we want to 18 call licensing events.
19 MS. BIRO: Right.
20 DR. BLEY: Or -- including groups of 21 those. Okay. I think I kind of get it. And then 22 we have this overlay of iteration throughout the 23 design process until we get up to the regulatory 24 process.
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78 1 -- I'd do a first section that talks about that and 2 gives it some detail.
3 And then indicating that the Charts kind 4 of go from the standpoint of everything being there.
5 But, that's not how it really evolves.
6 So, but anyway, it's a -- I'm really 7 glad you've got this guidance coming out. And I 8 think you've done a great job on it.
9 I think it just needs some polish.
10 MS. BIRO: Well, thank you.
11 MEMBER DIMITRIJEVIC: Yeah, I have a 12 simple question that's connected to the guidance 13 necessary. But, with the Subparts, we have 14 disclosed the issuance with maybe Subpart K and 15 Subpart U.
16 That doesn't cover PRA quality 17 assurance, right? As much as I remember looking at 18 that, the Subpart K for --
19 CHAIRMAN PETTI: I think you're right.
20 I think you're right, Vesna.
21 MEMBER DIMITRIJEVIC: And if it doesn't, 22 should it?
23 CHAIRMAN PETTI: Well, again --
24 MEMBER DIMITRIJEVIC: And this is like a 25 green area, so it's not really different between NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 1 Framework A, and B. And in the PRA is the -- in 2 the leading category Framework A maybe that should 3 be different, so.
4 CHAIRMAN PETTI: Yeah. I always --
5 DR. BLEY: I thought --
6 CHAIRMAN PETTI: I always thought it set 7 the PRA standard.
8 DR. BLEY: I think it ought to -- I 9 think those sections ought to point to the fact for 10 PRA it's covered in the standards.
11 MEMBER DIMITRIJEVIC: Yeah but, this is 12 covering the standards. But, things we just 13 discussed are not covered in the standards.
14 Standards just tell you how different 15 areas are assembled teams and things like that.
16 But, it will not tell you to do it in the beginning 17 of the process and that.
18 DR. BLEY: No, that's right. That's why 19 they need an introductory section to talk about how 20 all of that works. Is you iterate your way through 21 the design process. Yeah, I agree with you.
22 MS. BIRO: Yeah. So, we tried to 23 capture it there. But maybe again, it's not 24 highlighted. But, yes, this slide, like what's in 25 green, that you're totally out of the PRA.
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80 1 But, before initiating events, all that, 2 it would be covered under the PRA umbrella. But, 3 once you move on this slide with the green parts, 4 you are in the, in establishing the licensing 5 events.
6 And that's nev -- that's not in the PRA.
7 So, that's very specific to, with this guide.
8 MEMBER DIMITRIJEVIC: Right. But that's 9 -- this may cover most of the connected to this 10 draft. I mean, it was connected in general to 11 Subpart K, and you -- you know, which is quality 12 assurance.
13 MS. BIRO: Right. So, we tried to say 14 that if you have a PRA, follow the PRA processes.
15 If you don't have a PRA, then you'll have to do some 16 QA for this effort.
17 And I don't remember what Subpart K is.
18 Is that QA?
19 MEMBER DIMITRIJEVIC: That's the QA.
20 MS. BIRO: Thank you.
21 MEMBER DIMITRIJEVIC: Subpart K is QA 22 for Framework A, and Subpart is QA for the Framework 23 B.
24 Okay, just a thought and let's have a 25 break.
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81 1 MS. BIRO: All right. Thank you. We 2 have one more comment in the room.
3 MEMBER BROWN: Yeah. I'm going to ask a 4 contrarian, both of my colleagues will probably 5 hammer me in their normal manner for my question.
6 If I was an applicant and had a plant 7 design that I wanted to build, we've got about 100 8 plants that were designed and built with post PRAs.
9 They didn't -- they were fundamentally 10 put in place without PRAs. Regardless of what they 11 did post, you know, later when people wanted to do 12 something. They're all operating safely.
13 If I was an applicant, and I looked at 14 this process, and I would be listening to the cash 15 register as I went through this, these three pages 16 of stuff.
17 If I wanted to be contrary and wanted to 18 go back and just do a straight Part 50, just like 19 the old days, can you do that?
20 CHAIRMAN PETTI: No.
21 MEMBER BROWN: Is that right? Where is 22 that in the rule?
23 CHAIRMAN PETTI: The alignment -- the 24 alignment of --
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82 1 there yet. But where is the --
2 CHAIRMAN PETTI: Oh, okay. It depends.
3 Today you could.
4 MEMBER BROWN: You could.
5 CHAIRMAN PETTI: But, as soon as the 6 Commission approves the alignment of 50.52, the PRA 7 will be required--
8 MEMBER BROWN: Yeah, I got that.
9 CHAIRMAN PETTI: If we go forward.
10 MEMBER BROWN: I'm just saying so, but 11 right now --
12 CHAIRMAN PETTI: That door is closing.
13 MEMBER BROWN: That's what we said.
14 But, I just -- I really worry about how expensive 15 some of this is. And how much it delays the 16 process.
17 And all I do is I look back and look at 18 AP1000 was a Part 52 plant.
19 CHAIRMAN PETTI: Yeah.
20 MEMBER BROWN: And it was, we did the 21 review of that in 2003? '04? I mean, in 2011, 22 something like that. Eleven or 12 years ago.
23 And I think the first plant is, is it 24 running now? Or is it in physical --
25 DR. BLEY: No. It's not quite there.
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83 1 CHAIRMAN PETTI: Charlie, the only thing 2 I will tell you is that having been involved in some 3 micro-reactor projects, they look by the LMP 4 approach. It is not onerous.
5 The systems are simpler. And so the PRA 6 should be fundamentally simpler. Which means less 7 time and effort.
8 In fact, almost every advanced reactor 9 design, not all, but I mean, you're seeing that 10 most. All the people are applying these rules, and 11 they see the value to them.
12 That's why I'm surprised frankly. Some 13 of -- we have heard some don't want to use it. But, 14 they just don't want to use it in the licensing.
15 MEMBER BROWN: Yeah.
16 CHAIRMAN PETTI: I still think they see 17 the value of it, even in the design basis.
18 MEMBER BROWN: I'm not arguing about --
19 I'm not arguing about voluntary use to it, to 20 enhance your ability to do it. But, now you're in 21 control of the process, not the process being 22 controlled via the licensing operation.
23 And the light water reactors are all 24 1,000 megawatt electrical plus. And all these 25 micro-reactors running around at 30 or 40 or 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
84 1 megawatts, I can provide power for one half of 2 McLean, Virginia.
3 So, I generally --
4 DR. BLEY: Charlie, not one --
5 MEMBER BROWN: All I'm trying to say is, 6 I just think we need to be careful in terms of 7 ensuring we can get plants designed and brought in.
8 And ensure the licensing process doesn't really tamp 9 down the ability to do that.
10 That's all I'm looking for is, to try to 11 provide some common sense as we go through this. I 12 don't know how to do that. I'm just a little bit 13 worried.
14 I'm obviously --
15 DR. BLEY: I understand your concern, 16 Charlie. But, two things, one is you know, all of 17 the operating plants now have some kind of PRA that 18 was done.
19 Many of them made changes because of 20 that, and improved their operations and their safety 21 because of that. And one averted accident pays for 22 a lot of PRAs.
23 And if you compare the cost of a major 24 piece of equipment in a plant to the analysis cost 25 for this, it looks pretty good.
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85 1 So, I think you're seeing more in terms 2 of money then there probably is with respect to the 3 whole design process. And not so much of the 4 benefit that occurs from it.
5 MEMBER BROWN: Well, I --
6 DR. BLEY: That's something we've all 7 talked about. And I think we all understand your 8 concern.
9 MEMBER BROWN: I'm just a little bit 10 nervous about it. I mean, when I retired, we were 11 looking in the Navy, I was actually -- I did the 12 protection analysis.
13 So, my group had to do -- we read all 14 the reports, what happened with TMI. And we adopted 15 the Level One type approach to try to make sure we 16 had a better feel for potential problems that could 17 occur that maybe we would have missed otherwise.
18 But, we never went to the larger scheme 19 of the Level Two, Three process, which are more 20 complex. That's -- I think there are some benefits.
21 I'm not against them.
22 I want to make that clear. It's just 23 I'm very concerned about how in this whole licensing 24 event and the interaction of the NRC back with the 25 applicants trying to get through this design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 1 process, that we don't penalize.
2 That's all I -- so, I quit. I told you, 3 my colleagues would rake all over my body.
4 CHAIRMAN PETTI: Thank you. So, let's 5 at this point --
6 MEMBER BROWN: Take a break.
7 CHAIRMAN PETTI: Take a break for 15 8 minutes. We will be back at 10:30. Thank you.
9 MEMBER BROWN: Thank you, Dennis.
10 DR. BLEY: Any time, Charles.
11 (Whereupon, the above-entitled matter 12 went off the record at 10:15 a.m. and 13 resumed at 10:30 a.m.)
14 CHAIRMAN PETTI: It's 10:30, let's 15 reconvene and move on. Is, Alissa, is it your turn?
16 MS. NEUHAUSEN: Yes.
17 CHAIRMAN PETTI: Okay. Thank you.
18 Please continue.
19 MS. NEUHAUSEN: So, good morning. This 20 is Alissa Neuhausen of the staff. If we could go to 21 slide 66, please.
22 So, we just finished talking about the 23 PDG-1413. Now, we're moving onto discussing PDG-24 1414, the Alternative Evaluation for Risk Insights 25 Framework.
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87 1 And as Mihaela mentioned, the work that 2 was done for her technology inclusive identification 3 licensing events is incomplete by the time you start 4 getting into the AERI Framework.
5 So, similar to the previous one, this 6 draft guide is formatted like a regulatory guide.
7 Not -- sorry, unlike PDG-1413, this Framework only 8 applies to LWRs and non-LWRs licensed under Part 53.
9 It's not applicable to both Frameworks.
10 And the rest of this related to the 11 regulatory guide is formatted, or PDG is formatted, 12 Sections Bravo and Charlie provide the discussion 13 for staff guidance.
14 And it's outlined with six components to 15 the AERI approach. And these are the six steps 16 here. And we'll talk about each of them. They each 17 have their own individual slides.
18 So, they are the first step is the 19 identification and characterization of the bounding 20 event or events. The determination of a consequence 21 estimate for the bounding event to confirm that the 22 reactor design meets the AERI entry conditions.
23 The determination of a demonstrably 24 conservative risk estimate for the bounding event to 25 demonstrate that the QHOs are met. The search for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 1 severe accident vulnerabilities using the entire set 2 of licensing events.
3 And the identification of risk insights 4 for the entire set of licensing events. And then 5 there's assessment of defense-in-depth adequacy, 6 which is not going to be listed on the flowchart, 7 but is also a part of the AERI Framework. Slide 67.
8 Okay. So, this is the same flowchart 9 that Marty presented yesterday. There are no 10 changes except for it's just highlighting which part 11 of the flowchart applies to the AERI approach 12 specifically.
13 That this is under Part 53, Framework 14 Bravo. There's a little yellow box highlighted with 15 a red dotted line that points you to where in the 16 flowchart that makes it clear.
17 And so you can see that it relies on the 18 steps from the previous draft guide. Next slide, 19 please, slide 68.
20 MEMBER BROWN: Can I?
21 MS. NEUHAUSEN: Yeah.
22 MEMBER BROWN: Dave, to get back to our 23 earlier discussion, to go back to your previous 24 draft of the little red dots. At least we mentioned 25 this yesterday.
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89 1 But, it says no, when we elect not to --
2 elect to adopt, develop PRA, the use is no for 3 Framework B. Yeah?
4 CHAIRMAN PETTI: No. Inside Framework 5 B. If you elect not to do a PRA.
6 MEMBER BROWN: Go to this AERI thing.
7 CHAIRMAN PETTI: Right. Then you have 8 to meet the entry conditions. If not, you're told 9 to go back out and do a PRA.
10 MS. NEUHAUSEN: There's two options.
11 You can go back out to the -- to what the green box 12 would be. To the enhanced area.
13 You can also do -- you know, there are 14 different options. You could redesign such as using 15 AERI would be the other one that I was getting at.
16 MEMBER BROWN: But, there is an option.
17 There is a path if you meet certain entry 18 conditions. I remember looking at that.
19 CHAIRMAN PETTI: But, this is really for 20 like micro-reactors. There's just no way that, I 21 think, any other --
22 MEMBER BROWN: You couldn't apply this 23 to a major power reactor?
24 CHAIRMAN PETTI: I just don't -- the 25 entry conditions are all based on dose at --
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90 1 MEMBER BROWN: At the EPZ?
2 CHAIRMAN PETTI: At 100 meters.
3 MEMBER BROWN: Oh, that's the 100 4 meters. All right.
5 CHAIRMAN PETTI: Or that's from 6 yesterday. There's just no way.
7 MEMBER BROWN: Okay. I didn't -- I 8 didn't really connect the dots on the 100 meter 9 thing that was the major impediment of taking this 10 approach.
11 Okay. All right, thanks. You answered 12 -- my question has been answered, I think.
13 MS. NEUHAUSEN: Okay. Slide 68. So, 14 here's the first step in the area approach, the 15 identification and characterization of the bounding 16 event or events.
17 So, in order to characterize the 18 bounding event, the applicant should conduct an 19 analysis capable of estimating the doses and 20 consequences used in the demonstrably conservative 21 risk estimate that result from evaluating the 22 limiting initiating event for the design, 23 considering credit only for inherent safety 24 features.
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91 1 inherent features are those which are characteristic 2 of the system, and do not require any actuation or 3 operator action to function.
4 Another important note on the bounding 5 event is the, what Katie discussed this morning, and 6 Marty discussed yesterday, the history of 7 terminology that's been used to how we ended up with 8 TIRIMA and then Part 53 BE.
9 And bounding events, so the bounding 10 event, your bounding is not used consistent with the 11 definition in NUREG 18.55. This is kind of a 12 different definition of how the word bounding event 13 is used.
14 So, the process of identifying and 15 characterizing a bounding event should use a full 16 set of licensing event. And should consider both 17 core and non-core radiological sources associated 18 with the reactor unit or multiple units. So, it 19 includes multiple units, multiple reactors in the 20 licensing events.
21 The bounding event should be defined by 22 parameters that may include source term meteorology, 23 atmospheric transport, protective action, dosimetry, 24 health effects, economic factors, and consequence 25 quantification.
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92 1 And this list comes from Reg Guide 2 1.247, which can be use as the guide for determining 3 the appropriate parameters and performing the 4 consequence analysis. It's the best guidance that's 5 available through non-LWRs right now.
6 CHAIRMAN PETTI: Just a question on the 7 thought process here. This looks an awful lot like 8 how an NPUF would come to their maximum access.
9 Is that fair to say in terms of the 10 steps?
11 MR. STUTZKE: Yeah, this is Marty 12 Stutzke from the staff. And it's -- it's true what 13 you say, this is the way NPUFs come up with it.
14 But, we didn't start with that in mind.
15 This process has evolved.
16 CHAIRMAN PETTI: Well, I think it's 17 good. I -- good to see some consistency.
18 MR. STUTZKE: Yeah.
19 CHAIRMAN PETTI: Because I think from a 20 hazard perspective, --
21 MR. STUTZKE: Yeah.
22 CHAIRMAN PETTI: This type of facility 23 probably has parallels in those.
24 MR. STUTZKE: Right. And that was kind 25 of the going in situation for AERI to begin with.
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93 1 CHAIRMAN PETTI: Right. Right. So, no 2 we are reviewing an NPUF currently. All of this and 3 you've done a very good job on it. So, it's doable.
4 Thank you.
5 MS. NEUHAUSEN: Okay. So, in order to 6 consider a bounding event, so a bounding event may 7 combine features of several individual licensing 8 events.
9 You may, an applicant may also want to 10 consider multiple bounding events when for example, 11 a design has more than one event with approximately 12 similar annual likelihoods of occurrence and with 13 similar overall radiological impacts, but with 14 different radiological characteristics of the 15 analyzed release.
16 DR. BLEY: Can I interrupt you there?
17 MS. NEUHAUSEN: Yes.
18 DR. BLEY: Reflecting back on our 19 conversation of the last hour, no, you got the right 20 words in. I'm sorry, I thought we were missing the 21 possibility for chemical, but that's in there.
22 MS. NEUHAUSEN: Yeah, but it should be 23 in here. And if it's not, it should still carry the 24 work that was done from the previous PDG.
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94 1 considered a side of licensing events.
2 MEMBER KIRCHNER: May I ask a clarifying 3 question? And this is Walt Kirchner. The going in 4 assumption is that -- wait a minute, I can't see the 5 slide. Now I can.
6 The limiting initiating event for the 7 design considering credit only for inherent safety 8 features, so I get that.
9 What I'm a little bit curious about is 10 the under the bounding event you've got two sub-11 bullets. And in that first bullet, are protective 12 actions and such.
13 I'm trying -- I'm trying to sort out 14 here. My sense is that you want the consequences of 15 essentially this maximum hypothetical accident, if I 16 can use that terminology.
17 The implication is that it's an 18 unmitigated release. Or it's only -- it's only 19 limited by what design features are there, 20 quote/unquote inherent safety features.
21 So, what does protective actions mean 22 there? What are you talking about there?
23 It seems to me that you're trying to 24 come up with an event that has maximum consequences.
25 How does protective actions play in this?
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95 1 I get the -- do you see where I'm going?
2 It's a -- I'm not sure, should --
3 MS. NEUHAUSEN: No, I understand the 4 comment. I'll have to take a look at Reg Guide 5 1.247 and the PRA standard to see if this needs to 6 be refined.
7 MEMBER KIRCHNER: Thank you.
8 MS. NEUHAUSEN: Slide 69. Okay. Slide 9 69 is not actually a step in the process. But, it 10 clarifies that there really are two sorts of 11 parallel processes going on at the same time in the 12 PDG.
13 The first is to confirm that the AERI 14 condition is met. And that's what Marty went into 15 extensive detail on yesterday in terms of the seven 16 slide calculations.
17 And that's listed in 10 CFR 18 53.4730(a)(34)(ii), and uses dose estimates based on 19 those bounding event or events. And is the risk of 20 acute and long-term radiation exposures.
21 The second part of the PDG covers the 22 actual conduct of the AERI Framework. Which already 23 is for the lists that I've already listed. So, I 24 won't repeat them. But, each has an associated 25 section in the PDG. Slide 70.
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96 1 On electing to use the AERI Framework, 2 an applicant may not have the available analysis to 3 know whether the entry condition is met for the 4 design.
5 So, we talked about this for PDG-1413, 6 but this is an iterative approach. You may get 7 kicked out. You may come back in as your design 8 evolves, especially for the construction permit 9 stage of an application.
10 It's just the recognition that an 11 applicant might have to select a different Framework 12 or conduct significant redesign to use AERI, is 13 acknowledged in this, in this step.
14 And the confirmation that the AERI 15 condition as met should use a realistic dose 16 estimate and realistic description of uncertainties.
17 This is because the AERI approach is meant to 18 provide a similar role as a PRA.
19 And so it should be similarly realistic 20 in contrast to using the traditional deterministic 21 approach where conservatisms are intentionally 22 introduced in the analysis. And any conservatives 23 that are introduced, should be identified and 24 addressed.
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97 1 condition should be met for each of the bounding 2 events. Slide 71.
3 So, the next step in the AERI Framework, 4 really the first step in the main portion of the 5 AERI Framework discussed in the guide is the 6 development of the demonstrably conservative risk 7 estimate.
8 This risk estimate can be used to 9 demonstrate that a reactor design meets the QHOs and 10 relies on the estimation of risks of prompt 11 radiation-caused fatalities and latent cancer 12 fatalities to offsite populations.
13 So, to develop the demonstratively 14 conservative risk estimate, really the foundation of 15 the AERI, a realistic estimate of the annual 16 frequency is an expected. This is the main 17 difference between the AERI approach and the PRA.
18 We're not expecting for frequencies to be delineated 19 for event sequences.
20 So, one approach that allows the AERI 21 Framework to develop this demonstratively 22 conservative risk estimate is for an assumed 23 frequency of once per year to be chosen to represent 24 the sum of event sequence frequencies. And that 25 selection of once a year is based on statistics from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 1 LWRs.
2 And an applicant may use a different 3 frequency to represent the sum of event sequence 4 frequencies with adequate justification.
5 MEMBER KIRCHNER: I would like to ask 6 another question. We've talked about chemical 7 hazards quite a bit throughout the 53 process.
8 What if a bounding event results in 9 toxicity fatalities? Then it could lead to cancer.
10 But, that -- that's a much more complicated thing.
11 Then the immediate threat from some 12 toxic chemicals could result in fatalities.
13 MS. NEUHAUSEN: My immediate thought 14 based on the way that the guides are written is if 15 that's the bounding event identified in the 16 licensing event, or one of multiple, and that maybe, 17 in my opinion, the way to, the reason to use 18 multiple bounding events instead of one, would be a 19 case like that.
20 But, that would be the bounding event 21 that would be carried through this analysis. But, 22 I'll let Marty weigh in, so.
23 MR. STUTZKE: Hi. This is Marty Stutzke 24 from the staff. The question relates on regulatory 25 authority in my mind. If chemicals are mixed up NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
99 1 with radioactive materials, then we, the NRC, 2 regulates it. If it's a pure chemical release that 3 goes offsite, then it's EPA's regulatory authority.
4 And if it affects workers, then it's OSHA's 5 regulatory authority. So if you read the way that 6 we do material licensing, you know it's clear that 7 chemical hazards are considered, but only to the 8 extent it involves radioactive material.
9 DR. BLEY: Marty.
10 MEMBER KIRCHNER: There's potential that 11 a system could have mixed radiological and chemical 12 hazards in its release and yes, it's a complication, 13 but the slide says radiation cause.
14 MR. STUTZKE: We'll take that one back.
15 We'll have to work on it some I think.
16 DR. BLEY: Marty.
17 MR. STUTZKE: Clearly, the Commission's 18 safety goals and corresponding qualitative and 19 quantitative health objectives, the purpose of the 20 safety culture is defining acceptable radiological 21 risks.
22 MEMBER KIRCHNER: Correct, yes.
23 MR. STUTZKE: Let me take that one back.
24 DR. BLEY: Marty, on this regulatory 25 situation with respect to OSHA and EPA, I don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 1 really know how deeply involved in looking at the 2 accident analysis those organizations are. They 3 have regulations that have to be met, but do they in 4 any way review? And in a case where we now have a 5 facility that perhaps could have a substantial 6 chemical hazard, how do they get factored in both to 7 protect workers and the public?
8 MR. STUTZKE: I'll try to answer, but 9 it's not really -- you're bordering on my -- the 10 edge of what I really know. I know that EPA does, 11 in fact, perform risk analyses for off-site 12 releases. So for example, some industrial facility 13 has a tank of chlorine and they would be obliged to 14 look at the risk if there were an accident that way.
15 That's about the limit of what I know, Dennis.
16 DR. BLEY: They don't actually need a 17 license from those organizations, do they?
18 MR. STUTZKE: They need approval.
19 DR. BLEY: They need approval.
20 MR. STUTZKE: I don't think it's called a 21 license as we know a license.
22 DR. BLEY: Okay. I'm really unfamiliar 23 with what happens when we get into those situations.
24 And now if we have a plant that seems to have more 25 worker risk and very low public risk, how we make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
101 1 sure that gets examined properly is kind of outside 2 my knowledge base, too.
3 MEMBER HALNON: Dennis, we start with 4 control room habitability. I mean that certainly is 5 a portion of it regardless of the radiological 6 piece. It's still a habitability issue for the 7 operators.
8 And I would assume that there's a 9 habitability issue offsite that onsite is probably a 10 more serious issue most likely.
11 MEMBER BIER: A couple of comments, 12 first in response to Dennis' question. I think it's 13 worth -- I don't know whether it's for the staff or 14 the DCRS to take a closer look at those regulatory 15 issues because my kind of informal sense is that 16 both EPA and OSHA are more reactive than NRC and 17 less proactive. And you know, EPA may get involved 18 after you have a release or OSHA in inspection after 19 you're operational, but I don't know how much they 20 would do beforehand. I think that's worth looking 21 into.
22 The other comment that I had just 23 generally on this slide, I don't really object to 24 how this slide is dealing with the QHO issue as kind 25 of a pragmatic matter, but in the longer term I 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
102 1 real questions about whether the QHOs are even 2 really appropriate for micro reactors because if you 3 look back at the history for how the QHOs were 4 developed, the original intent was to keep the risk 5 low relative to whatever other technology would be 6 used which at that time was assumed to be a baseload 7 coal plant. And if you're talking about a micro 8 reactor, the alternative technology is not, you 9 know, a mini megawatt baseload coal plant. It might 10 be battery power. It might be diesel generators.
11 It might be all kinds of other things, but it's not 12 a coal plant.
13 And you know, my own thinking on this is 14 risk has to be kind of commensurate with benefit.
15 And if you're talking about a large baseload plant 16 that serves hundreds of thousands of people, the 17 allowable risk might be legitimately greater than if 18 you're talking about a tiny micro reactor that 19 serves maybe one industrial facility or a very tiny 20 town some place.
21 And so I don't want to kind of derail 22 the efforts on Part 53 because I realize you guys 23 are on a clock and there's a limit how much 24 rethinking of major NRC policy is going to happen in 25 that process, but I think in the longer term kind 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
103 1 beyond issuance of Part 53, the prospect of micro 2 reactors may justify some rethinking of what safety 3 goals should apply in that context and how would we 4 develop them. Do we want them to be quantitative or 5 qualitative, et cetera, et cetera. So that's just 6 kind of a forewarning of an issue that's on my radar 7 that I don't expect you guys to solve in Part 53, 8 but we'll probably be coming back at some point.
9 DR. BLEY: I guess some of this stuff 10 that we consider outside the purview of NRC makes me 11 think back 60 years ago. I forget the name of the 12 case, but NRC never covered environmental issues 13 until there was an application that got challenged 14 and the federal courts told NRC, effectively ACRS 15 and the staff, no, NRC really has to protect against 16 these kinds of problems. So that could show up here 17 on some of these worker and chemical kind of things 18 that we normally think of as outside our area of 19 jurisdiction.
20 MEMBER DIMITRIJEVIC: This is Vesna. I 21 just wanted to -- the leak says something very 22 interesting and I just want to remind you that if 23 you go back to the Commission's safety goals and the 24 QHOs, the second round would cover what she talks 25 about because it says that there is a risk compared NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
104 1 to the risk of generating electricity reliable 2 competing technologies could cover what she was 3 talking about, so if we are back to the safety goals 4 instead of QHOs.
5 And I just want to make this, just to 6 remind you because I saw in some other parts of this 7 document, you know the frequency of -- is not 8 constant. We are talking frequency not probability 9 and initiating event frequencies could be 10 significantly higher for the new technologies than 11 once per year and even for existing technologies 12 some of the initiating event frequencies is usually 13 higher than once per year. Just a reminder. Don't 14 forget that.
15 MS. NEUHAUSEN: Can I keep going? Slide 16 72, please.
17 The next step in the area framework is 18 the search for severe accident vulnerabilities. And 19 this came from our review of the severe accident 20 policy statement and some of the language in the 21 Part 53 framework bravo.
22 So the search for severe accident 23 vulnerabilities that encompass the entire set of 24 licensing events, not just looking at the bounding 25 events, and any additional severe accidents. 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
105 1 severe accident vulnerabilities should be eliminated 2 through modifications to the design, operations, or 3 maintenance or justification may be provided for a 4 severe accident vulnerability is acceptable for the 5 design.
6 And the next slide is designed to 7 discuss the -- provide the severe accident 8 definition and severe accident vulnerability 9 definition.
10 Slide 73. Severe accidents are defined 11 in 10 CFR Part 53 and those events that progress 12 beyond the design basis accidents in which 13 substantial damage is done to the reactor core, 14 whether or not there are severe offsite 15 consequences. And that's consistent with how we're 16 using it in the area framework. There's no changes 17 there.
18 We're proposing in the area framework in 19 the PDG severe accident vulnerabilities are those 20 aspects of a facility design that represent an over 21 reliance on a single design feature, whether for 22 accident prevention or mitigation, and that could 23 lead to a severe accident after accounting for SSC 24 reliability, human actions, and defense-in-depth.
25 Slide 74. The next step 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
106 1 framework is the identification of risk insights.
2 The identification of risk insights relies on 3 understanding the entire set of licensing events.
4 Qualitative descriptions should be provided and 5 should be supplemented with quantitative 6 descriptions when available.
7 The qualitative descriptions may be the 8 most useful when framed as comparisons, so for 9 example, X is more important than Y or A is less 10 likely than B. They should also provide an 11 understanding of a hierarchy of event sequences 12 ranked by frequency. And these risk insights may be 13 used to support other licensing decisions.
14 MEMBER KIRCHNER: May we go back one 15 slide -- this is Walt Kirchner -- to 73?
16 This definition in 10 CFR 53, it started 17 me thinking. It probably needs to be more 18 technology expansive or inclusive. There's distinct 19 possibility that will have molten salt reactors with 20 liquid fuel in which case I'm not sure how you'd 21 define damage to the core. Core typically refers to 22 thick steel kind of configurations. Should that be 23 something like the reactor system and of course, a 24 severe accident, if you're stripping fission 25 products in any of those subsidiary systems, I think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
107 1 Marty pointed this out yesterday, you might have a 2 higher source term available for release in a 3 fission product storage subsystem than you may have 4 in the core, at least in terms of the volatiles.
5 Does this definition need to be expanded 6 in some way so that certainly you would worry about 7 substantial damage to one of those Chapter 9 systems 8 so to speak that are support systems to the actual 9 reactor primary system. Do you see where I'm going 10 with this?
11 MS. NEUHAUSEN: Yes, we see where you're 12 going with it and we didn't want to deviate from the 13 language for Reg. Guide -- or the PDG. I keep 14 messing that one up.
15 CHAIRMAN PETTI: So it may be more of a 16 comment than a 53 itself.
17 MEMBER KIRCHNER: Yes.
18 CHAIRMAN PETTI: And this is a 19 conformance change.
20 MEMBER KIRCHNER: Yes.
21 CHAIRMAN PETTI: I like to think of the 22 term as a substantial upset in the reactor facility 23 and then you can, you know, that can be damage.
24 MEMBER KIRCHNER: Yes, or reactor 25 systems, rather than just the core.
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108 1 CHAIRMAN PETTI: I've -- at our 2 facilities. You've got to think about the words a 3 little.
4 MR. JESSUP: This is Bill Jessup, NRC 5 staff. We appreciate the feedback on what this is 6 referring to, the rule language and what's drafted 7 in Part 53 framework bravo. We'll take back.
8 MR. STUTZKE: And to follow up on that 9 we had originally written that substantial damage is 10 done to the commercial nuclear plant. The problem 11 with that is it's too expansive. It would include 12 secondary systems where perhaps there's no 13 challenge. So we'll -- this is Bill Stutzke. We'll 14 take it back and try to work on the words.
15 MEMBER KIRCHNER: Yes. It's not our 16 business to rewrite your definitions, but I would --
17 it might be more expansive, Marty, if you just said 18 reactor systems or -- because as you point out, if 19 you make it the whole facility, then you're missing 20 what you're really concerned about.
21 MR. STUTZKE: Right. We'll noodle on 22 it.
23 MS. NEUHAUSEN: If we can go to Slide 24 75. So again, this is not listed in the flow chart, 25 but it's an important component to the area NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
109 1 framework, the assessment of defense-in-depth should 2 encompass the entire set of licensing events and 3 should complement the search for severe accident 4 vulnerabilities and the search for risk insights.
5 So for example, the search for severe 6 accident and vulnerability should consider relevant 7 defense-in-depth attributes including success 8 criteria and implement functionality, reliability, 9 and availability. So PDG-1414 adapts the regulatory 10 guidance position in Reg. Guide 1.174, the latest 11 revision of which provided additional guidance on 12 defense-in-depth per the Commission's direction.
13 Additional guidance that may be considered for the 14 AERI approach is in NEI 18-04 which was adapted from 15 IAEA SSR 2/1.
16 DR. BLEY: This Dennis again. Your 17 statement that NEI-1804 may provide guidance bothers 18 me because I think it provides some pretty solid 19 guidance maybe the most complete in this area for 20 how you lay out the issues and evaluate them that 21 I've seen. So I would lean on that a little 22 stronger. Also wonder -- and I forgot to look for 23 it earlier, do you refer to the knowledge-based 24 document on defense-in-depth? If not, I'm curious 25 why not.
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110 1 MS. NEUHAUSEN: Are you referring to the 2 NUREG AM?
3 DR. BLEY: Yes.
4 MS. NEUHAUSEN: We have considered 5 including that document, but we ran into some 6 challenges with the level of review that may be 7 required of that document in order to use it as a 8 resource in what will eventually become a regulatory 9 guide.
10 DR. BLEY: Well, it's got stuff in it --
11 well, it points you to the sources for everything 12 that's in it, but that's interesting.
13 MS. NEUHAUSEN: We understand.
14 DR. BLEY: At least in my opinion from 15 its value as a document, I think NRC should go 16 through that process and update it if necessary, but 17 validate it because it goes into things that are 18 pretty much spread throughout the literature in this 19 area and some of that literature is not always easy 20 to find.
21 MS. NEUHAUSEN: Thank you.
22 DR. BLEY: Even in the regulatory 23 document, it's a pretty thorough source of 24 information.
25 DR. SCHULTZ: This is Steve Schultz. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
111 1 mentioned yesterday that the IAEA is doing 2 relatively substantial work to examine SSR 2/1 to 3 apply to advanced designs. This is an activity that 4 started a few years ago and they're at the point in 5 their reviews that they're reducing revised guidance 6 in this area.
7 It may be a worthwhile summer activity 8 for someone, and I know the NRC is involved in this, 9 to consider the changes that are being made there 10 and assure that 1804, that document, reflects what 11 has gone on in the international community in the 12 last few years. Draft information started to come 13 out earlier this year in February/March time frame.
14 MS. NEUHAUSEN: Okay, if there are no 15 more questions, I'll hand the presentation back over 16 to Katy.
17 MS. WAGNER: All right. Let's go to 18 Slide 76, please.
19 CHAIRMAN PETTI: Turn your mic on.
20 MS. WAGNER: Okay, so --
21 CHAIRMAN PETTI: While you're doing 22 that, I'd like to go back to the NEI document and 23 that statement about it may be useful. That 24 document has been used by the staff and approved for 25 use for the staff with no exceptions for defense-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
112 1 depth. So I think there's a pretty good link there 2 to --
3 MS. NEUHAUSEN: We can take that back.
4 DR. BLEY: -- to be more positive about 5 that. Okay.
6 MR. STUTZKE: Dennis, this is Marty.
7 The concern is we can't write guidance that says you 8 have to use NEI 18-04. And we're just trying to 9 indicate it's a good source, good way to think about 10 how to evaluate defense-in-depth, but it's a little 11 confusing because depending on what licensing 12 framework you're in, it may not even be relevant to 13 the whole process.
14 DR. BLEY: Well, that part is true, but 15 I guess the way you just said it would be more 16 palatable than may provide guidance if they did 17 source -- rations. You know something like that.
18 It sounds almost dismissing to me when I read it the 19 way it's stated.
20 MR. STUTZKE: We'll work on the words.
21 But I agree, it's a very useful and almost 22 authoritative source.
23 DR. BLEY: Go ahead, I'm done.
24 MS. WAGNER: All right, so I think now 25 we can move back to Slide 76. That's it.
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113 1 All right, so first off, I would like to 2 sincerely thank the ACRS for the very thoughtful 3 comments. We really appreciate your feedback and the 4 graded PRA will be making revisions to both of the 5 predecisional draft reg guides as needed in response 6 to ACRS and other stakeholder feedback. And so 7 therefore, we are hoping to receive ACRS feedback as 8 soon as possible, for a side note, and also the 9 working group will be closely tracking any changes 10 to the preliminary proposed rule text that may 11 impact either of the predecisional draft guides.
12 And finally for predecisional draft 13 guide 1414, we will be developing guidance for AERI 14 maintenance and upgrades.
15 Next slide, please.
16 So as far as upcoming public meetings at 17 this time, the following interactions are planned.
18 We have an advanced reactor stakeholder meeting on 19 June 30th and then that will be followed by an ACRS 20 full committee meeting on July 6th. And then we 21 have a Commission meeting giving an update on Part 22 53 licensing and regulation of advanced reactors on 23 July 21st. And so with that, I believe that 24 concludes our presentation.
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114 1 about the full committee meeting. Since we spent 2 two full days here with basically the entire 3 committee, I think we should keep it very high 4 level, you know, summary.
5 And Scott, I have a question. We 6 haven't heard yet about Subpart F. Subpart F was a 7 response to the reconciliation letter they sent. So 8 do they have to talk about that in full committee or 9 can we just accept what we hear and not have to have 10 that topic in the full committee?
11 MR. WIDMAYER: Hey, this is Derek. Yes, 12 Dave, I think it would depend on whether you feel 13 like you need to write another letter. If you think 14 the issues are resolved, you don't have to have full 15 committee session on it. If you believe that there's 16 still something you want to say, I would say discuss 17 it during full committee.
18 CHAIRMAN PETTI: Okay. We'll have to 19 see what we get this afternoon.
20 MR. MOORE: I agree with Derek's 21 response. Yes, I agree with Derek's response.
22 CHAIRMAN PETTI: So again, based on what 23 we feel, that may or may not need to come forward, 24 the full committee.
25 Okay. Let's then keep going. Do any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
115 1 members have any final comment before we transition 2 to Subpart F?
3 MEMBER DIMITRIJEVIC: I would like 4 actually something which came up yesterday and I am 5 not really clear on it today is about the difference 6 in the classification of licensees between the 7 Subpart A and Subpart B. And I understand the 8 Subpart B because it's based on 50.69, but I have a 9 really -- I'm not sure how this three tier 10 classification means Subpart A was devised. We had 11 some discussion about this yesterday and I was 12 wondering, is there somebody who can respond to that 13 and tell us how is this specification devised? Why 14 is it different from the Subpart B and what was 15 assumed that happened? Would that be difference in 16 the safety, non-safety classification? I just would 17 like to hear this because that's one of the issues 18 I'm considering before we write the letter.
19 CHAIRMAN PETTI: And Vesna and I had 20 some discussion. 50.69 and please correct me if I'm 21 wrong, I thought was there to risk inform safety 22 classification of the existing plants to basically 23 change classifications before we had PRA, you know, 24 were overly conservative, if you will.
25 And so why is that the touchstone 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
116 1 Framework B, given you're going to have the PRA at 2 the time you're doing the design, not after the 3 fact. I just don't understand the thought process 4 for why you would necessarily align to 50.69 and why 5 you wouldn't just do something that is more risk 6 informed on the outset?
7 MS. DE MESSIERES: Yes, thank you for 8 the question. This is Candace De Messieres, member 9 --
10 CHAIRMAN PETTI: Oh, great. You're on 11 line. Perfect. Thanks.
12 MS. DE MESSIERES: Yes, thank you for 13 the question and for the clarification. So you're 14 correct that in an ideal scenario, the outcome of 15 the more traditional approach would align with the 16 50.69-like classification scheme for SSCs. However, 17 we do know in Framework B, you still are following 18 the traditional approach that you see in Part 50 and 19 52 so there is a possibility that some SSCs 20 categorized as safety related as an outcome of the 21 traditional safety analysis would then be non-safety 22 significant from a PRA standpoint.
23 I agree that the delta between the 24 outcome of the PRA since you have a PRA and you're 25 using it as part of the process should be quite NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
117 1 small and in fact, we would hope that you know, 2 again, you may not even need to use the 50.69 3 approach in Framework B. However, we did want to 4 leave that opportunity in in case that an applicant 5 would like that flexibility again, taking an 6 approach that's more traditional in nature and then 7 perhaps develops a PRA with the proper acceptability 8 to be able to implement that risk-informed 9 classification later on.
10 I will also note that we do have a 11 provision within the Part 53 Framework B section on 12 this that if they do -- if they would like to adopt 13 it at the time of application, that is permitted in 14 Framework B. So unlike the current framework where 15 50.69 kind of occurred after the fact and it was 16 adopted as a license amendment request in most cases 17 and I guess still is for the current fleet in some 18 plants, we can do that up front for Framework B. So 19 there's an option to do it at time of application or 20 as a license amendment later on down the road, 21 again, assuming maybe that someone has a more fully 22 developed PRA to take advantage of that operational 23 flexibility.
24 On the Framework A question, I would 25 probably defer to someone from the Framework A team.
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118 1 I can tell you that that safety classification 2 paradigm is described in guidance that we do have 3 for Framework A. But I think that's 1804, the LMP 4 process. However, I would probably want to defer to 5 a member of the Framework A team for that.
6 CHAIRMAN PETTI: Dennis, any thoughts?
7 MEMBER DIMITRIJEVIC: So there's nobody 8 from Framework A?
9 CHAIRMAN PETTI: No, there's nobody from 10 Framework A here.
11 MR. RECKLEY: We're listening if we want 12 to delve into it. This is Bill Reckley.
13 CHAIRMAN PETTI: Okay, Bill, yes. Go 14 ahead.
15 MR. RECKLEY: So it's probably a more 16 complicated question than it would first appear.
17 The basic difference is that from the Framework A 18 you basically use the PRA as the first step. And 19 you identify and categorize the event sequences into 20 the three categories, anticipated, unlikely, and 21 very unlikely using the Framework A language or as 22 Marty pointed out under the LMP language. Same 23 categories, but different names.
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119 1 particular safety function could cause you to cross 2 the frequency consequence target which in this area 3 is going to be around the 25 rem reference values 4 that we use from Part 50 and Part 52.
5 And then from those functions, the 6 applicant designer is going to pick which SSCs they 7 are going to rely upon to ensure a success path to 8 prevent it from going across the frequency 9 consequence target and that becomes your safety-10 related equipment.
11 So if you apply that -- the odd part is 12 if you apply that logic to a lightwater reactor, you 13 end up in the same place in terms of what kind of 14 systems are going to be needed to keep you from 15 crossing that 25 rem number. You're going to need a 16 reactor protection system. You're going to need an 17 Emergency Core Cooling System, and you're going to 18 need a containment. You need them all.
19 But as we look forward in a technology-20 inclusive way, and Dr. Rempe was mentioning this 21 earlier, we start under Framework A with the dose 22 criteria because it's a technology inclusive 23 approach. And then the applicants will need to 24 address what other safety functions are needed to 25 keep the dose below.
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120 1 And again, if you're a middle-sized 2 plant and hundreds of megawatts, you end up with the 3 same kind of systems. You're going to need a 4 reactivity control system, a protection system.
5 You're going to need a cooling system, and you're 6 going to need most likely a confinement barrier, be 7 it within the fuel or a separate structure.
8 So you approach it slightly differently 9 under the traditional approach. The design basis 10 accidents were defined. ANS standards 51.1 and 52.1 11 laid out the list of DBAs, again, predominantly the 12 large break LOCA and from that, you picked your 13 safety-related equipment, that in addition to the 14 anticipated operational occurrences.
15 So it's a slightly different approach.
16 It will largely end up, again, for medium-sized 17 plants, it will end up with the same systems, same 18 types of systems being safety related.
19 To the discussion that came yesterday 20 about a category of events were safety related, but 21 not safety significant. Again, within Framework A 22 that doesn't come up because you're going from the 23 other direction. You are first picking the 24 equipment that is safety or risk significant and 25 from that subset or from that set of events -- 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
121 1 SSEs, you're picking which ones you want to be 2 safety related, so you kind of by definition don't 3 have safety related but not safety significant or 4 risk significant events, so it's kind of -- and 5 again, even within Framework B a designer would not 6 be expected to take an approach where they had 7 safety-related equipment that was not otherwise risk 8 significant.
9 But anyway, does that help?
10 MEMBER DIMITRIJEVIC: Yes, I mean I see 11 your thinking. I just want to say according to the 12 industry as we know from like I said, South Texas 13 which completely applies these, there is a ten times 14 smaller SSCs in safety related not safety 15 significant, a very small group in the non-safety-16 related, safety-significance like a thousand versus 17 a couple hundred.
18 So I was wondering if we applied this 19 same approach you just described to the current 20 fleet, would see totally different safety 21 classification between safety and non-safety 22 systems?
23 MR. RECKLEY: It's hard to look back. I 24 think it you approach the design of the current 25 fleet using this kind of methodology, they would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
122 1 have been more selective in how they addressed 2 events. And for example, with the more modern 3 approach, if you have two transients, you're going 4 to look at them and try to address them both with 5 the same safety-related system. To some degree, I 6 don't want to exaggerate, but to some degree that 7 was not optimized for the current fleet. I'll just 8 say I think it's safe to say that. And so you ended 9 up having safety-related equipment to address 10 particular event -- initiating events within 11 sequences and there probably could have been a 12 better job done to optimize the designs to minimize 13 what was safety related. That wasn't a primary 14 focus in the '70s and so that exercise wasn't done.
15 In retrospect, the cost of having much more safety-16 related equipment became apparent, and then that led 17 to 50.69 type approaches to try to address and 18 better optimize the designs.
19 MEMBER DIMITRIJEVIC: Okay. All right.
20 I will think about that. And now since you 21 mentioned something, I have a totally independent 22 question, so don't connect it to this.
23 Is every applicant who comes under the 24 Framework A, you're doing his confirmations through 25 the FC curve. That is now a way that somebody can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
123 1 come, you know, with the way -- do the CDF and LERF 2 like a NuScale and use just safety goals without 3 ever going to FC curve. Is FC curve going to be in 4 every applicant's -- that's my question.
5 MR. RECKLEY: It's not written to 6 require the use of the FC curve. It's written to 7 require that the applicants address what safety --
8 what is the evaluation criteria that they'll use for 9 every licensing basis event. So the easiest way to 10 think about that would be the frequency consequence 11 target figure under LMP, but we don't require it.
12 And so, for example, and we've said this, if they 13 wanted to use a different curve than is in NEI 1004, 14 something that would, for example, be based on the 15 cumulative distribution function which has been a 16 proposal, that could be developed. If they wanted 17 to use a surrogate measure, they could likewise use 18 surrogate measures and be more barrier based. And 19 for example, in the anticipated region, they could 20 say our acceptance criteria is we won't fail a 21 particular barrier. And if the barrier remains 22 intact, you will control the release and therefore, 23 you wouldn't need to use a frequency consequence 24 target based on off-site dose if there's no release.
25 So yes, we give them that flexibility.
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124 1 Admittedly, we are writing this with the LMP in mind 2 and want to make sure it is one acceptable way to do 3 it, but leaving enough room such that it's not the 4 only way to do it.
5 MEMBER DIMITRIJEVIC: Okay, I mean I was 6 just wondering because then this safety 7 classification can go a different way. You know, I 8 can see that your provision of this third category 9 which is the non-safety system, but its significant.
10 It's sort of like you know just in case. Something 11 was missed in the classification, you want to make 12 sure that all the significant things are covered, 13 but in the classical word of the -- they will not 14 work exactly like that.
15 MR. RECKLEY: Yes, and within Framework 16 A, Dave, you're going to regret asking if I was 17 online I guess, but within Framework A and that's 18 not the primary discussion point today, but within 19 Framework A, the historically -- the way you 20 characterize it is probably right. The non-safety 21 related with special treatment were things that were 22 added to pick up identified gaps and we've talked 23 many times about ATWS and station blackout and under 24 Part 52, the regulatory treatment of non-safety 25 systems. To some degree you can look at that as a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
125 1 measure to pick up what was missed by the safety-2 related equipment and the Chapter 15 accident 3 analysis.
4 Within Framework A, it's a different 5 construct. The inclusion of non-safety related, but 6 safety significant equipment is built in and the 7 regulatory controls that are added for those systems 8 are not kind of just there to pick up what's missed.
9 As I mentioned earlier, the safety-related equipment 10 is derived out of that -- out of that set of event 11 sequences, and so it's a more integrated approach 12 and so the treatment of the non-safety related, but 13 safety significant SSCs is a more fundamental 14 integrated approach. It's not just to pick up 15 what's missed.
16 MEMBER DIMITRIJEVIC: Okay, I'm now 17 confused on a much higher level. I'm going to have 18 to think about it.
19 CHAIRMAN PETTI: Let me just -- I have 20 more a Framework B question that -- it's kind of 21 broader than this, but this is one that just raises 22 this issue. I understand this idea of trying to 23 make it consistent, at least not inconsistent with 24 50.52 options. But I would have thought that this 25 Framework B gave an opportunity to develop a rule NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
126 1 that made it consistent with those, but was the best 2 part of those. There's a lot of idiosyncrasy in 50 3 because of the historical legacy. And sometimes --
4 the argument is almost too much slavish compliance.
5 It's done in 50.52 whereas if you step back and 6 think about it, maybe there's a better idea on how 7 to do it that meets say the intent without the 8 letter of the law sort of thing. That's the one 9 thing that I don't see and I worry it's because of 10 the schedule that there just really hasn't been that 11 time to step back and say, you know, is this really, 12 you know, if you think about this, if 53 is as 13 technology neutral and performance based, why do we 14 need 52? Fifteen years from now will everybody be 15 using 53? And if you think about it that way, how 16 would B be different? I just worry that it's not as 17 optimized as it could be because of a schedule.
18 MR. JESSUP: Yes, this is Bill Jessup 19 from the NRC staff. I'm glad to respond. It's a 20 challenge to strike the right balance. I will say 21 that we were very thoughtful as we went through and 22 trying to look at the things that we know have 23 baggage and translate them over in a way that you 24 don't lose something, but also improve things. It's 25 a challenge to strike the right balance. I think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
127 1 we've got a good start with the first iteration. If 2 we identify specific areas where there's too much 3 baggage, you shouldn't have translated this so 4 directly. We'd be interested in hearing that, but 5 we -- in what was translated over, but we know 6 there's areas for improvement.
7 CHAIRMAN PETTI: Well, I think the 8 stakeholders probably could write a lot of comments 9 because they've lived 50.52. So -- it would also 10 just be interesting to keep a punch list of stuff 11 you didn't include, so that when you step back and 12 you go yes, we didn't bring this package, that would 13 be helpful. Thanks.
14 DR. BLEY: Dave?
15 CHAIRMAN PETTI: Yes.
16 DR. BLEY: You asked my thoughts on this 17 and we haven't had much time to ponder it in only 18 this one meeting so far. My biggest worry about an 19 approach such as this one is pretty well covered and 20 my biggest worry was that we would let people pick a 21 worse case accident and analyze it without being 22 convinced it was the best we could do at identifying 23 that bounding event. I think with the other Reg.
24 Guide and its appendix, we've done -- we're well on 25 our way to making that not be the main issue, so we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
128 1 get a bounding event and that includes the 2 initiating event in the scenario, it's pretty 3 reasonable.
4 Now beyond that, I have some things and 5 I'm going to ramble a bit because I haven't really 6 worked this all out yet. Yesterday, Marty provided 7 our justification for the dose at 100 meters. And I 8 got to think about that some more. In principle, 9 the approach kind of makes sense to me. Ed Lyman 10 brought up, well, re-emphasized things that were 11 already brought by Marty about the assumptions, the 12 LNT, the uncertainty with respect to individual 13 cancer fatality risk, the assumption of uniform 14 population, but I think Marty covered that pretty 15 well, but I got to think about it some more, the 16 uncertainty and the lambda risk coefficient. I kind 17 of think the uncertainty is all on the -- mostly on 18 one side there, on the conservative side. So I want 19 to give that some more thought.
20 Now the other place I've got to read 21 some more and think about is what we do beyond the 22 bounding case and how we make sure through our 23 definition of special treatment for SSCs that we 24 don't have a situation developed that would elevate 25 something that was not a bounding scenario into 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
129 1 bounding case by relaxation of reliability or some 2 other situation on things that weren't part of the 3 bounding case, but were part of alternative accident 4 sequences that could be important. And I've got to 5 look through here in some more detail on how that's 6 suggested because I really haven't worked that out.
7 And the last thing is what I brought up 8 I think some of the information on defense-in-depth 9 and that's related to this this same issue, 10 uncertainty and what might happen to other 11 parameters that were not tracking real well, how it 12 refers to the NEI document and why it leaves out the 13 knowledge management NUREG because even if it's not 14 approved for regulatory use, it's really a rich 15 source of information of things ought to be 16 considered. So those are things I need to think 17 about, but the worst one I think is covered pretty 18 well, the potentially worst one. All these others 19 could be important and I need to give it a little 20 more thought having just seen it long enough and we 21 haven't talked about it very much. So that's about 22 it.
23 MR. MOORE: Thank you, Chairman Petti.
24 This is Scott Moore, the Executive Director of the 25 ACRS. Everybody that's in the room here or on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
130 1 ACRS staff knows that there was an odor in the room 2 off and on this morning. I just want to report back 3 to you that the Fire Department came in. They 4 measured the levels in this room. It is safe to be 5 in this room. They think that it's from cleaning of 6 a chiller that's up on the roof.
7 There's a high turnover of the air in 8 the room, but if anybody is uncomfortable remaining 9 in the room and wants to leave, please feel free to 10 leave the room and go to a different floor, but it 11 is safe to remain in the room and the Fire 12 Department has checked it out. Thank you very much.
13 CHAIRMAN PETTI: With that, if there's 14 no more comments from members, I think maybe we take 15 an early lunch and come back. Jesse will be back at 16 one, I guess, to talk about Subpart F, so why don't 17 we do that?
18 MEMBER KIRCHNER: Dave, this is Walt.
19 CHAIRMAN PETTI: Yes.
20 MEMBER KIRCHNER: May I make one 21 comment?
22 CHAIRMAN PETTI: Sure.
23 MEMBER KIRCHNER: Maybe it's not on the 24 margin, but I am still bothered, Dennis covered some 25 of the issues. I just would like to ask the staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
131 1 how well you've tested this criterion for this 2 alternate approach?
3 I, too, am pondering this 100-meter 4 criterion. The people who will -- what happens when 5 the exclusionary or boundary is less than 100 meters 6 or more? How does that factor into this where it 7 doesn't matter, it's just a kind of a set criterion 8 as a screening criterion, then you still have to do 9 the dose calculations in any event as part of the 10 licensing --
11 CHAIRMAN PETTI: Right, right.
12 MEMBER KIRCHNER: So how well tested, 13 Marty and staff, how well have you tested that?
14 Have you just kind of on tabletop have you played 15 with a few concepts that are under consideration and 16 seen, tried to guesstimate where they might fall 17 vis-a-vis this criterion?
18 MR. STUTZKE: Walt, this is Marty 19 Stutzke from the staff. We're just now starting to 20 test it out. And I would emphasize the intent is to 21 only decide which plants need to do PRA versus those 22 that would be allowed to do the alternative 23 evaluation to risk insights.
24 So it's not that the reference point in 25 the rule text for that is not related to 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
132 1 location of the EAD or the EPZ. We would leave that 2 as separate.
3 The reality is that EAD were smaller 4 than 100 meters and an applicant wanted to collapse 5 its EPZ down to the exclusionary of boundary, that 6 would become controlling and the area criteria would 7 automatically be met.
8 MEMBER KIRCHNER: Okay. All right.
9 MR. STUTZKE: It's a little complicated 10 how they interface.
11 MEMBER KIRCHNER: Yes, okay. And then 12 the other observation, Dave, would be I'm still 13 troubled by definitions and since we know Bill 14 Reckley and his team is on the line listening, Bill, 15 since you've chosen unlikely and very unlikely, why 16 not call AOOs likely? That's meant in a light-17 hearted way.
18 (Laughter.)
19 MR. RECKLEY: Actually, along these 20 lines we are -- part of merging as Bill Jessup 21 mentioned yesterday is to try to minimize any places 22 where there's two terms with different definitions 23 and so we are looking to change under Framework A 24 anticipated operational occurrences to simply 25 anticipated event sequences. And then that way we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
133 1 have different terminology and avoid same term with 2 two definitions.
3 Actually, it's anticipated and likely, Walt.
4 We're probably pretty close.
5 MEMBER KIRCHNER: Yes, thanks, Bill, 6 yes. And then you avoid the baggage that goes with 7 the AOO from the other -- from the past, yes. Thank 8 you.
9 DR. BLEY: I had one other thing I 10 forgot to mention. One, I don't have a clue myself 11 as to what kind of dose versus distance we might get 12 out of some of these very small reactors. A hundred 13 meters seems very restrictive and I wonder if 14 there's a way to adapt that and maybe there's an 15 existing way already. I'm not sure. Anyway, I need 16 to think about that some more, too.
17 CHAIRMAN PETTI: I've seen some of the 18 microreactor source term. A 100 meters is okay.
19 Again, it depends on the technology that's used 20 obviously.
21 DR. BLEY: That helps. Thanks.
22 CHAIRMAN PETTI: Okay, I just want to 23 thank the staff because it's kind of a gear shift 24 when we go back to Subpart F. This has been a 25 really helpful day and a half on Subpart B to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
134 1 complement what we've heard in great detail on 2 Subpart A.
3 Members, I just ask if you have 4 comments, just send them to me by email. I think 5 I've captured most of the big things I heard from 6 people during the discussion. But we're on a tight 7 timeframe to have a letter basically. I've got to 8 finish the letter next week, so I'm shooting to have 9 a draft out, we'll put on SharePoint so members can 10 look at.
11 DR. BLEY: Quick question for Derek, I 12 guess, any chance we can get this transcript by mid 13 next week so we can look it over and pick things we 14 want out of it?
15 MR. WIDMAYER: I will try. I think it's 16 kind of late to make that ask.
17 DR. BLEY: Well, if it's possible 18 because this is a big deal and this is our only 19 meeting.
20 MR. WIDMAYER: Yes.
21 DR. BLEY: We've had on it and the 22 transcript has an awful lot of thoughts that would 23 be great to be able to sniff through.
24 MR. WIDMAYER: I will try.
25 MEMBER BROWN: I will echo Dennis' NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
135 1 comments. Some of this stuff I didn't figure out 2 until we were down here talking about them and the 3 transcript is the only place that -- I couldn't have 4 captured in my ramblings in ink and paper from the 5 meeting here, so that would be very helpful, unless 6 you happen to hit a key note on some of it.
7 CHAIRMAN PETTI: I've taken pretty good 8 notes, but I haven't incorporated obviously today's 9 stuff, but the letter is already at line 300.
10 (Laughter.)
11 And you know, if I add more, it's a long 12 letter. It's the only letter we have to deal with 13 in full committee.
14 MEMBER BROWN: Oh, okay.
15 CHAIRMAN PETTI: It's because of the 16 scope more than anything else.
17 DR. BLEY: I think Charlie will find the 18 transcript very interesting reading.
19 MEMBER BROWN: Yes.
20 CHAIRMAN PETTI: If we can get it then.
21 MR. WIDMAYER: Okay, Dave, do you want 22 to ask for public comments for this particular part?
23 CHAIRMAN PETTI: Oh, sure. Why don't we 24 do that.
25 Any member of the public, unmute NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
136 1 yourself, identify who you are, and your comments.
2 CHAIRMAN PETTI: Thank you. At this 3 point, I'm going to turn over Subpart F discussions 4 to Member Halnon. He's going to start and take it 5 from there.
6 Greg?
7 MEMBER HALNON: Yeah. Thanks, Dave.
8 Just a short interlude here. I mean, I 9 wanted to first thank Jesse and all you guys that 10 worked on this. This presentation is well laid out.
11 I want to appeal to our members to look 12 at this presentation in really three parts. The 13 first part will be the individual issues of 14 engineering expertise, load following and some 15 simulator discussion. At that point, if we let 16 Jesse get through that portion and then we ask 17 questions throughout that slide, that would be 18 excellent.
19 I think the main point is to allow Jesse 20 and team to get through the entire generally 21 licensed operator program discussion and hold our 22 questions till the end of that because I think there 23 will be a lot of clarifying questions and maybe some 24 what-if questions that will come out. But rather 25 than derail his thought process, I thought best to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
137 1 let him get through that, and then we'll ask 2 questions.
3 And then the third part is a summary of 4 what he talked about, and that'll be another 5 opportunity to bring in the odds-and-ends questions 6 at the end. So, again, the first portion, ask 7 questions as necessary, but the main issue is to let 8 then get through the GLRO discussion completely 9 because I think a lot of questions will get answered 10 in their commentary.
11 So, with that, I'll turn it back over to 12 the staff.
13 MR. SEYMOUR: Okay. Thank you. So, 14 again, I'm Jesse Seymour from the NRR Operator 15 Licensing Human Factors Branch. I spoke yesterday 16 on Framework B, and in the course of doing that, I 17 alluded to a number of things we talked about today 18 during Subpart F. We have had a slight change in 19 speaker alignments. So, again, I apologize for the 20 last-minute switch on who would be talking today.
21 So, to begin with, as discussed, I'll be 22 presenting today on the second iteration of the real 23 thing, which was Subpart F of preliminary Part 53.
24 And this is the subpart that covers staffing, 25 personnel qualifications, operator licensing and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
138 1 training.
2 If we can move on to the next slide, 3 please.
4 Okay. So here we have an overview of 5 the items that we'll be discussing today. So, 6 again, as Member Halnon discussed, the presentation 7 will take us through an overview of key changes to 8 Subpart F that are made under the second iteration, 9 and this will include a rather high-level synopsis 10 of items that we spoke about in more detail 11 yesterday. So things that haven't changed from the 12 Framework B discussion, I'll note that and won't go 13 into more detail unless the Committee wants to.
14 Then we'll discuss the new generally 15 licensed reactor operator framework, which replaces 16 the former non-licensed certified operator framework 17 in its entirety. And then, additionally, I will 18 provide a synopsis of how we feel that we've 19 addressed the items from the Committee's letter that 20 was issued to us several months back, and then leave 21 some time for any further questions or discussion at 22 the end.
23 Move on to the next slide, please.
24 So this slide -- again, I want to 25 recognize the whole group of folks who have been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
139 1 working on this. Again, I've had the privilege of 2 being able to work with a very talented team of 3 people, so again, I just wanted to call out that 4 expertise here.
5 And I just wanted to begin by saying 6 that recently, we presented preliminary rule 7 language for Part 53 that was related to various 8 human factors and operator licensing topics for 9 advanced reactors. This preliminary language is 10 intended to address the mandate described in the 11 Nuclear Energy Innovation and Modernization Act to 12 provide a risk-informed, performance-based approach 13 to licensing advanced reactors that is technology 14 inclusive while still ensuring safety.
15 Following that meeting, ACRS issued a 16 letter that acknowledged the staff's methodical 17 approach to developing the preliminary rule 18 language. The letter also recognized the delicate 19 balance that staff is trying to find between the 20 flexibility that is desired by the industry and the 21 predictability that's needed for effective 22 regulations to ensure safety.
23 The letter also provided recommendations 24 about how the Committee thought the rule language 25 should be adapted. I'd like to acknowledge 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
140 1 thank the Committee for their thoughtful suggestions 2 in that letter. Preliminary rule language has many 3 moving pieces, and the staff understand the 4 significant effort that the Committee put into 5 studying the material and considering the potential 6 impact on safety.
7 The staff carefully considered the 8 recommendations as well as continuing to consider 9 feedback from designers and licensees. As a result, 10 we have made several changes to the preliminary 11 rule. Today we will share with you the changes made 12 since the Committee issued its letter. It is my 13 opinion that these changes provide a significant 14 improvement to the rule while maintaining the 15 flexibility needed to support unique designs and 16 operating concepts as well as ensuring safety 17 through a predictable regulatory framework.
18 And as mentioned, I'd also like to again 19 just reiterate my point that we've had a very 20 talented team of folks working on this, and I just 21 want to acknowledge them. This has included 22 individuals from both the Office of NRR as well as 23 the Office of Research. And experience within NRR, 24 I want to recognize the incredible support that we 25 received from the staff and DANU as well.
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141 1 We can move to the next slide, please.
2 Okay. So I'll start out the main part 3 of today's presentation by providing an overview of 4 changes that were made in the second iteration of 5 Subpart F. In general, the second iteration of 6 Subpart F retains the majority of requirements 7 developed for the first iteration, although some 8 requirements have been relocated to more appropriate 9 spots, such as in grouping technical requirements.
10 It should be noted that most of the 11 changes made for the second iteration of Subpart F 12 were mirrored in the content of Subpart P that we 13 discussed yesterday. Because of that, most of the 14 items that are significantly different from the 15 first iteration of Subpart F were also discussed in 16 detail during the Framework B presentation 17 yesterday. For those items already discussed, as I 18 mentioned, I will only summarize those changes here 19 for the sake of time.
20 We can move to the next slide, please.
21 MEMBER HALNON: So, Jesse, real quick, 22 is it your intent to incorporate this into Subpart P 23 as well?
24 MR. SEYMOUR: Yes. So, when we went 25 through Subpart P yesterday, as we decided to make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
142 1 these changes, some of which were responsive to 2 concerns that the Committee had expressed, we 3 carried forward those same items within the second 4 iteration of Subpart F and also within the main body 5 of Subpart P.
6 And what we'll see is that the primary 7 difference is that right now, when you look at 8 Subpart P, it does not contain a generally licensed 9 reactor operator framework. Aside from that, these 10 items that we went through yesterday map to Subpart 11 F.
12 MEMBER HALNON: Yeah. I realize that.
13 I guess it was the GLRO -- is it your intent to try 14 to tailor that to be able to use in some form in 15 Subpart P?
16 MR. SEYMOUR: Exactly. And that's a 17 work in progress. And really, we got into this a 18 little bit yesterday, but part of it is the 19 iterative nature of what we're doing and the fact 20 that we're working on different pieces of this and 21 revising different pieces at different times.
22 Really, for the sake of keeping a good schedule, we 23 had to have Subpart B drafted by a certain time 24 frame.
25 At the same time, too, we were working NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
143 1 through the second iteration of Subpart F. And 2 really, I think what it boils down to is the fact 3 that now that we have a fairly well solidified 4 picture of what Framework B looks like, about 5 features like AERI and so forth, and we also have a 6 revised generally licensed reactor operator 7 framework that differs considerably in some regards 8 from what we had previously proposed; we can now 9 take those two things and look at them and identify 10 how the generally licensed reactor operator 11 framework would best fit into Framework B.
12 And a point that I would just make is 13 when you look at the Subpart B rule language, you 14 can see right within that structure some reserved 15 blocks of the rule language that are there so that 16 we can incorporate that at a later --
17 MEMBER HALNON: That's what I was kind 18 of alluding to. There's probably going to have to 19 be some tailoring because of the AERI approach.
20 MR. SEYMOUR: That's correct, and that's 21 something we're actively working on right now.
22 MEMBER HALNON: Okay. Very good. Makes 23 sense. Thanks.
24 DR. BLEY: Yesterday, someone on the 25 staff expressed the idea that it wasn't over 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
144 1 Framework B yet because there were regulatory 2 reasons it might not be able to be there. And is 3 that a concern still? And if it is, I'd like to 4 understand that better.
5 MR. SEYMOUR: So what I can say is that 6 we have to take a very deliberate approach with the 7 generally licensed reactor operator concept simply 8 because we do have statutory requirements that are 9 associated with operator licensing. So, again, we 10 do have to do everything in a very controlled, 11 deliberate manner. When we talk through the 12 criteria today, you'll see that we define a reactor 13 class for which this reactor operator licensing 14 framework applies.
15 So, again, there are things that we need 16 to do in a very deliberate way as we move through 17 this. But really, this stage of the game -- our 18 preliminary assessment at the moment is that there's 19 no impediment to us working towards an incorporation 20 of this concept in Framework B. Really, I think the 21 bigger hurdle was from a technical standpoint, 22 looking at the technical end of things and 23 determining what is sound and being very careful 24 about that.
25 And if we run into larger issues of any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
145 1 type of a regulatory hurdle or some other issue, 2 we'll navigate that in conjunction with the rest of 3 the team as we move through that.
4 MEMBER HALNON: So, Dennis, when we get 5 to the -- after the GLRO discussion, let's revisit 6 that question just to see how it comports with the 7 discussion we just had on the AERI approach.
8 DR. BLEY: Sure. I agree with that.
9 I'm assuming at this point that OGC has been in on 10 reviewing Subpart F and has not raised any 11 objections to this. Is that correct?
12 MR. SEYMOUR: So, with regards to that 13 question, that's something that we'll need to circle 14 back around with the Committee on. So that's not 15 something that I'm prepared to speak to at the 16 moment.
17 DR. BLEY: So they have not reviewed it 18 and signed off on it yet is what I --
19 MR. MOORE: Chairman --
20 (Simultaneous speaking.)
21 MR. MOORE: Chairman Petti, this is 22 Executive Director Moore. OGC and also NRR have 23 advised me that the Office of the General Counsel 24 would prefer that their advice to the staff not be 25 discussed. It gets into litigative areas that 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
146 1 don't want to discuss in an open area, not just on 2 this but on all issues.
3 DR. BLEY: Wow.
4 MR. MOORE: It gets to attorney-client 5 privilege areas between the staff and OGC.
6 MR. SEYMOUR: Okay. So, if it's okay, 7 I'll go ahead and move on. But again, as Member 8 Halnon said, I think that we'll talk through some of 9 these points, and hopefully the material that we 10 have here will be able to answer some of these as we 11 go. And certainly, we can circle back around with 12 the Committee if needed.
13 So, moving on, I'll begin with an 14 overview of the changes. We've added a staffing 15 plan requirement for engineering expertise that is 16 identical to that incorporated into Framework B.
17 Within the context of Subpart F, it should be noted 18 that this requirement would apply to all types of 19 facilities irrespective of any other staffing 20 considerations.
21 Though later on in this presentation 22 we'll start talking about the generally licensed 23 reactor operator framework, and we talk about that 24 in comparison with plants that would have the 25 traditional reactor operator and senior reactor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
147 1 operator staffing, the engineering expertise 2 requirement is one that would apply to all of those 3 facilities. So, again, just so everyone is aware, 4 this is something that we envision being applied to 5 Framework A and Framework B facilities as well as to 6 all types of licensed operator staffing 7 requirements.
8 We've also expanded upon the provision 9 for load following allowances as discussed 10 yesterday, to include process heat usage.
11 Additionally, we've similarly removed the regulation 12 addressing the use of a simulator as a human factors 13 engineering test bed. And again, our perspective, we 14 had gone back and forth a bit on the best way to 15 approach that, and we've determined that it's most 16 appropriate to leave that as something that's 17 covered by guidance, which is the current status 18 quo.
19 Also, we've taken a comparable approach 20 to change management requirements for approved 21 programs as what was discussed yesterday with 22 Framework B. Most notably, however, certified 23 operator provisions of the first iteration of 24 Subpart F have been completely replaced with an all-25 new generally licensed reactor operator framework.
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148 1 As mentioned yesterday, this is a feature that is 2 not presently incorporated into Framework B.
3 Move on to the next slide, please.
4 MEMBER HALNON: Hey, Jesse, before you 5 move on, the engineering expertise -- I think I 6 mentioned it yesterday -- is it fair to assume that 7 the guidance that comes off of this will look at the 8 details of communications and interactions with the 9 on-shift crew as well as the communications and 10 abilities to get into the monitoring systems, 11 potentially cybersecurity issues, using the internet 12 and those sort of details? Will the guidance deal 13 with that?
14 MR. SEYMOUR: That's exactly our current 15 intent. And as I mentioned yesterday, we've 16 identified some key issues that the guidance will 17 need to address at a minimum. Communications is an 18 important one of those. So, if you want the 19 engineering expertise to be available to the 20 operators when they need it and you want to provide 21 that in a flexible way, then the outgrowth of that 22 is that you may permit those to be located in a 23 remote setting. Perhaps it's going to be located 24 back at corporate headquarters or whatnot.
25 But the key thing is that in order to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
149 1 provide that when it's needed, there has to be a 2 reliable means of communicating back and forth. And 3 it's a two-way dialog, if you will. The engineering 4 expertise has to be able to receive germane plant 5 data and status as well as communications from the 6 operators. And in return, they have to be able to 7 reliably provide any required advice or assessment 8 back to them. So what we'll need to look at is, 9 from a communications standpoint, what is necessary 10 in the guidance space to be able to do that.
11 Now, another layer to things is the 12 responsiveness of that position. So, again, this 13 can't be a tech support in a conventional sense 14 where you call and it goes to a voicemail. You need 15 to actually be able to get somebody. And as I 16 pointed to yesterday, I was a Shift Technical 17 Advisor at a plant, both non-licensed and licensed 18 at different points. And one of the things that I 19 recall about that is that I would have a pager, 20 which kind of dates me a little bit, but I would go 21 out and sometimes go out to inspect a piece of 22 equipment, but I had a ten-minute response time.
23 So, in the event that the plant got into 24 an off-normal type of situation, I had ten minutes 25 to respond to the control room. And again, 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
150 1 understanding is that I think that's the current 2 standard that's out there for that. So we would 3 have to look at timeliness criteria, 4 responsiveness, and then, again, the reliability of 5 that two-way communication.
6 And one example of this would be, as you 7 go through our rule language, you can see that we've 8 updated certain post-TMI requirements that deal with 9 important indications that operators need to be able 10 to receive. So, as you go through those -- and 11 these are things that are indicative of core damage 12 states, leakage, safety parameters. One thing that 13 we've considered is, is that the type of information 14 that would at a minimum need to be what's reliably 15 transmitted and available to whoever's fulfilling 16 this role?
17 And again, that's just one way to meet 18 this. And I think that's part of the beauty of the 19 approach, that there's flexibility inherent in it, 20 because at the same time, you could just elect to 21 have a traditional STA. And again, whether that's a 22 dual role qualifying person or whether it's a stand-23 alone individual, again, just going with the 24 traditional route and having STA that's part of the 25 shift or located on the site there with the crew NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
151 1 would be another way to meet this.
2 DR. BLEY: Jesse, I want to back you up 3 to the middle of your soliloquy there. This idea of 4 having people off-site running the plant implies 5 you're going through, as you said, some kind of 6 communication link, and essentially all of those 7 these days are digital. And that brings up issues 8 of cybersecurity, of radio frequency interference, 9 of -- not right at the plant, but airplane crashes 10 and other accidents along the route of travel of 11 signals, and a whole host of areas.
12 Those, I don't think, are flagged 13 anywhere in Part 53 at this time. But maybe Bill or 14 somebody can tell me yeah, it is.
15 MR. SEYMOUR: One thing I want to point 16 out -- and I want to give Bill a chance to speak to 17 this if he wants to chime in, but one thing I want 18 to point out is right now we're talking about the 19 engineering expertise role. And this is not an 20 operator per se, right? So this is not someone who 21 is remotely located who is providing operational 22 inputs and controls and so forth to the facility 23 itself.
24 Again, this is a support and advice 25 engineering expertise role. So, when we talk about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
152 1 this remote potential nature of this individual and 2 we talk about communications back and forth, we're 3 talking about data. We're talking about voice and 4 that type of thing versus control inputs going back 5 and forth. And again, the cybersecurity aspects and 6 the remote operations aspects are beyond the scope 7 of what I'm really here to talk about today. I'd 8 have to defer that back to Bill.
9 But I think it's important just to 10 recognize that we're talking about the ability to 11 send data out from there. And I can say that when I 12 was an operator, there were certain means by which I 13 could view plant data in a secure way when I wasn't 14 on site. So there are capabilities that are like 15 that. That's very distinct from having the ability 16 to send any kind of control input and so forth.
17 So, again, I don't want to go too far 18 outside of my regime of work here in commenting on 19 that.
20 DR. BLEY: Okay. That's fair enough.
21 But the same issues would apply for that data link.
22 But more broadly, and not for you to answer, as you 23 just pointed out, others have raised this idea of 24 remote operations as well, and those things would 25 all factor into that area. So I don't know if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
153 1 anybody wants to talk about that now or some other 2 time, but at some point, we ought to talk about 3 that.
4 MEMBER HALNON: It's also important to 5 remember that these provisions get defined in a 6 staffing plan that gets submitted for approval. So 7 whatever scheme is developed by the licensee or 8 applicants gets another level of scrutiny by the 9 staff when they're approving the staffing plan. I 10 assume that's correct. Is it?
11 MR. SEYMOUR: That is. And when we look 12 at the structure of the language -- and again, I 13 appreciate you pointing that out. Section -- again, 14 we're talking about Framework A, so this would be 15 Section 53-730 foxtrot. If we go to that set of 16 requirements, that's the requirement for the 17 facility staffing plan, and this is something that 18 linked into the content of application requirements 19 for operating licenses and combined operating 20 licenses.
21 So, as you follow through, what you end 22 up with is a pointer that says submit the staffing 23 plan. One of the items added in there is how this 24 engineering expertise requirement will be met. So 25 that will be reviewed. Later on, when we look at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
154 1 conditions of the facility and license, the facility 2 is required to maintain the complement that's 3 described in the approved staffing plan.
4 So not only is there the opportunity to 5 review and approve it on the front end, but also at 6 the same time, there's a regulatory book to ensure 7 that's complied with thereafter.
8 MEMBER HALNON: And that puts a real 9 emphasis on both the standard review plans and the 10 guidance that you put out. So that's why we keep on 11 asking about those details. And I think you've got 12 the right experience to drive those details into 13 that guidance that needs to be done.
14 MR. SEYMOUR: I appreciate that. And 15 again, as we work through the development of our 16 staffing guidance, we do plan to have interactions 17 with the Committee as those guidance documents 18 become available. And again, if there's specific 19 sets of guidance, if there's specific items that the 20 Committee wishes to discuss, we can certainly bring 21 those in an appropriate draft form before the 22 Committee.
23 Okay. And then I guess I do want to 24 close the loop on just one point as well, too, 25 because something had been brought up about if 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
155 1 end up in some type of situation -- the aircraft 2 impact was a good example, something that denies 3 access to the site and perhaps interrupts 4 communications through it.
5 I want to point out that -- again, 6 without going outside of my area -- emergency 7 preparedness is its own set of requirements. And 8 the nature of those requirements is such that 9 there's requirements that are associated with 10 emergency response organizations and the type of 11 support that has to be provided in the event of a 12 clear emergency, albeit under the Part 53 framework, 13 there's different ways to go about doing that.
14 But if a plant gets into a declared 15 emergency, I think it's worth noting that you're 16 most likely talking about other avenues for 17 engineering expertise and support to be provided.
18 The nice thing about this engineering expertise 19 requirement is it's something that's ready to go and 20 waiting in the wing. So when that event happens, you 21 have it kind of right out of the gate. You don't 22 have to wait till you've declared an alert or site 23 emergency. And your ERO folks are starting to 24 respond in their 30-minute or one-hour time frame 25 depending on what role they're fulfilling.
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156 1 And again, also given that we can see 2 differences and what that looks like as we get 3 advanced reactor -- and the specifics of that I 4 would have to defer to the folks that worked on the 5 emergency preparedness side of Part 53. But I think 6 it's also worth noting that in terms of what support 7 provided to the organization, that this engineering 8 expertise individual by themself may not necessarily 9 be the end all/be all.
10 MEMBER HALNON: Jesse, moving to load 11 following, in the last discussion we had, there was 12 some talk around explaining in a little bit more 13 detail what you meant by an operator being able to 14 refuse a request or a demand or whatever the case 15 may be. How has your thinking evolved on that?
16 Because we were talking about -- as someone who's 17 going to have to be standing at the controls all the 18 time watching for it, and when a demand came in, 19 make a decision yes or no, I'm going to allow that -
20 - have you guys talked through that portion of that 21 in a little more detail?
22 MR. SEYMOUR: Yes. And again, it's an 23 area where we recognize that ultimately (Audio 24 interference.) to flesh things out a bit more. But 25 when you look --
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157 1 DR. BLEY: Jesse, you're drifting away 2 from the microphone.
3 MR. SEYMOUR: Sorry. Let me get a 4 little closer to the mic. Okay. Thank you. It's a 5 scenario that we realize we need to flesh out a 6 little bit more. But at the same time, too, I think 7 the rule language as it stands provides some insight 8 into where the backstop is, really.
9 And so, if we look at the revised rule 10 language, the second iteration, as we go through and 11 we look at Section 53-740(e), which deals with 12 activities that affect reactivity that aren't 13 associated with the controls themselves, keeping in 14 mind that a true control manipulation that affects 15 power reactivity would require a licensed operator -
16 - so these are things that would be on, 17 conventionally, the secondary side of a -- in 18 traditional plants, affecting terminal load, 19 secondary heat output, that type of thing.
20 If we look at how that's structured, 21 the requirement of E is modified by the requirement 22 of F. And F addresses load following. And when we 23 look at F, what we see is that there's three items 24 that are nested under that. And at least one of 25 them needs to be used to provide that assurance 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
158 1 an inappropriate load maneuver, inappropriate 2 demand, could be interrupted appropriately.
3 And those consist of the function of an 4 autonomous control -- not autonomous, but the 5 function of an automated control system, again. So 6 you could have automation that's going to truncate 7 that demand at a certain point or not allow it in 8 the first place. You could have a protection system.
9 And again, when we get to the actual -- bringing the 10 rule package before the Committee, we'll be able to 11 get into the statements of consideration and so 12 forth -- preamble I think we're calling it now.
13 And one of the things that we've -- even 14 at the level of that preamble that we currently have 15 that we're considering working in there is that this 16 protection system, if that's the option that's used, 17 that can't be synonymous with your reactor 18 protection system. It has to be something that's 19 more conservative and kind of dedicated to that 20 purpose, so again, something that's there to keep 21 you from butting up against that reactor protection 22 box in the first place.
23 And then the third option would be --
24 DR. BLEY: I'm not sure I fully 25 understood that one. Can you kind of say it again?
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159 1 MR. SEYMOUR: Yeah.
2 DR. BLEY: You said 753-740 E and F. In 3 my copy, it looks like that's all under 735, general 4 exemptions, unless I dropped a page in my looking.
5 But go ahead. Really, I'm more interested in the 6 technical question.
7 MR. SEYMOUR: Yeah. And actually, I've 8 got a copy of 740(f). And what I can do is I can 9 just read what those requirements are, just for the 10 sake of providing the information here. So what we 11 currently have is that load following may be 12 permitted in the provisions of paragraph E, which, 13 again, address those indirect reactivity 14 manipulations -- do not apply during load following 15 operations -- and again, load following is a defined 16 term -- provided that one of the following is 17 immediately capable of refusing demands when they 18 could challenge the safe operation of the plant or 19 when precluded by the plant conditions.
20 And those things would be the actuation 21 of an automatic protection system, or an automated 22 control system, or an operator or senior operator, 23 or a generally licensed operator, as appropriate.
24 So, when we talk about how this is 25 affected, one of the possible outcomes is that 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
160 1 could have that licensed individual that has to be 2 there and that continuous ability to interrupt the 3 transient role, but then we also provide two 4 technological ways that you can have the machine 5 take care of that, too, if it's appropriate.
6 Again, and important qualifiers, though, 7 when we talk about an automatic protection system, 8 that is not synonymous with reactor protection, 9 right? We want something that's more conservative 10 and, again, would keep you from getting into the 11 area in the first place.
12 DR. BLEY: I guess that word always gets 13 me, too. What do you mean by non-conservative in 14 this case -- more conservative, I mean, in this 15 case?
16 MR. SEYMOUR: A good way to think about 17 it is -- a great image is concentric boxes. If we 18 were to imagine that the plant safety limits would 19 be the outermost box, again, just thinking about a 20 traditional large light-water, and then if we go 21 within that box, we can imagine where the limiting 22 system settings would be. And then we could draw a 23 box within that and see where the actual reactor 24 protection system supplements were.
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161 1 about is a box inside that box, right? The idea is 2 that you've got some kind of a control. You're load 3 following for economic purposes. And again, for 4 that and for the economic considerations of 5 protecting your secondary equipment and so forth, 6 you're staying within this inner box, and you're 7 going to hit some type of a truncation, some type of 8 a limit that will put the brakes on how far the 9 plant's going to maneuver --
10 DR. BLEY: So more conservative really 11 means it happens sooner.
12 MR. SEYMOUR: That's right. That's 13 right.
14 (Simultaneous speaking.)
15 DR. BLEY: -- challenge the existing 16 safety system. Okay. That makes sense to me. I 17 think I got it now. But I will say my copy doesn't 18 have a 740. This text was under 735 in mine. So I 19 don't know what happened.
20 MR. SEYMOUR: Wow. Okay. Yeah, I'm 21 not sure on that. Again, that may be a typo that 22 somehow got in there.
23 MEMBER HALNON: So, Dennis, it's kind of 24 synonymous with -- the way I think of it is the BMW 25 integrated control system versus the reactor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
162 1 protection system.
2 DR. BLEY: Yeah. No, I think I got it 3 now.
4 MEMBER HALNON: Various limiters. Yeah.
5 MR. SEYMOUR: That's actually a great 6 analogy for that. That's a system that I'm familiar 7 with. And granted it's taking kind of an analog 8 approach to doing that, but -- exactly. You're 9 talking about a system that is at a very high degree 10 of automation controlling the plan's response and 11 output. Yet at the same time, it's still bracketed 12 by a reactor protection system that's outside of 13 that. So, again, a very good point of comparison.
14 MEMBER KIRCHNER: Well, the way I would 15 think of it is -- this is Walt Kirchner. It's, as 16 you said, the box within a box so that that 17 automatic control system, whatever system that is, 18 keeps you, like for an LWR, within your safety 19 limits on tech specs. So, obviously, as Dennis 20 said, this would have set points that would actuate 21 sooner so that you didn't challenge -- if it was 22 unattended, for example -- that that load didn't 23 challenge the safety envelope and actuate the 24 reactor protection system.
25 DR. BLEY: You know, the rule doesn't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
163 1 actually say that, except it's got the word 2 immediate in there. Maybe that's the thing that 3 gives you the implication that this ought to happen 4 first. But -- at least I don't think the rule says 5 what you just said about the conservative nature of 6 this compared to the reactor protection system.
7 That's paragraph F, again.
8 MR. SEYMOUR: That's good feedback, and 9 that's something that I'll definitely capture and 10 keep in mind as we work through further refinement 11 of the rule language. At this point, what I can say 12 is that what we've been looking to draft into the 13 preamble -- you know, those statements of 14 consideration that discuss that more information 15 about these preliminary regulations -- that is 16 currently the level that we had in mind to locate 17 that type of clarification.
18 But again, we can look at further 19 refining the rule language, particularly as we start 20 to look at the finishing touches on things and 21 moving things out to get those proposed rule 22 comments.
23 Okay. So --
24 MEMBER KIRCHNER: Could you write 25 guidance on this as well?
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164 1 MR. SEYMOUR: That's the current intent.
2 So there are a number of areas that we've identified 3 that we need to create guidance on. Some of them 4 are what we consider to be key regulatory guidance, 5 and other items, we're targeting at the latest you 6 have available at the time the proposed rule is 7 available.
8 And within that universe of stuff that 9 we're having to write, the guidance that would 10 address load following and what we see to be an 11 acceptable way to do that that would be in 12 compliance with regulation is an area that we've 13 identified. Yes. So we are looking to develop 14 guidance that would go through and provide 15 clarification on these areas.
16 MEMBER KIRCHNER: Well, the operating, 17 that automatic control system -- whatever you choose 18 to call it -- I don't know that BMW's name is a 19 proprietary name. But whatever that system is 20 called, then from a pragmatic standpoint, you would 21 have to ensure that that control system stays within 22 the lower bounds of the set points for the reactor 23 protection system. Maybe that's too much in the 24 weeds, but I mean that's the practical implication.
25 MR. SEYMOUR: It is. And I think in one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
165 1 of our earlier discussions, I had gone a bit more 2 into detail about where you really have to run that 3 logic out to. And the thing is we don't want 4 initiating events to be generated for the sake of an 5 economic nice-to-have. So the ability to plant a 6 load following is good for economics, and if it 7 could be done safely, then we want to try to write 8 regulations that are conducive to it.
9 Yet at the same time, too, what we don't 10 want is an automated control system blindly driving 11 the plant into some regime where it's unstable. And 12 that doesn't necessarily only happen at the top end 13 of the band. It can happen at the bottom end of the 14 band as well. And a classic example is if you think 15 about the large light-water reactors, you may have 16 two or three trains of feedwater. And within that, 17 you'll have feedwater pumps, condensate pumps, 18 sometimes a condensate booster pump as well.
19 And what you'll find is as you reduce 20 plant power, a lot of times around 50 percent power, 21 60 percent power area on the way down, you have to 22 start securing trains of feedwater; otherwise, 23 you'll end up with instabilities on the secondary 24 side of the plant. Depending --
25 MEMBER KIRCHNER: Yeah. You'll have 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
166 1 over-cooling event. If you just let the load drag 2 down to PWR, you'll go to the bottom end of your 3 tech specs. So I meant that in a sense -- just not 4 the higher end. That whole operating window defined 5 by tech specs has to be respected in this particular 6 case.
7 MR. SEYMOUR: Yes. And so a key thing -
8 - and this is really kind of a neat discussion 9 because when we think about what the technology is 10 able to do now with control systems -- I'll give an 11 example. And this is something where the guidance 12 just has to be appropriately written.
13 So let's say that the transient were to 14 drive you down to that lower end where you would 15 have to do some kind of a secondary realignment in 16 order to keep from that instability happening. At 17 that point, the control system could say, well, I'm 18 not going to let power drop any more. I'm just 19 going to go ahead and start putting output through 20 steam dumps and dumping steam to the turbine to 21 maintain some type of a minimal level that keeps you 22 from that.
23 And again, that's something that digital 24 control systems are able to manage, something that 25 20 or 30 years ago maybe we wouldn't have looked at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
167 1 the systems and said that they could do that in a 2 reliable way. But again, these are the types of 3 ways that an automated control system may be able to 4 truncate that. And I think the key for writing the 5 guidance is going to be to write it in such a way 6 that the designer can figure that out, and it'll be 7 on them to make the case to how that can be done 8 safely.
9 The guidance has to be written broadly 10 enough to be able to take varying solutions like the 11 one I just kind of made up as an example there and 12 to look at that and say, is this reasonable, and 13 will this accomplish the objective of the 14 regulation?
15 MEMBER HALNON: One thing to keep in 16 mind also is that load following capabilities is not 17 -- it's not enabled by this. This is just the plant 18 operation's response to it. It's a design issue, 19 design in both control system and in the physical 20 mechanical properties of the plant, mechanical 21 thermal properties.
22 So you kind of enter into this 23 regulation with the assumption that the boundaries 24 of how you can load follow, how far you can load 25 follow, and how the plant responds is already NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
168 1 established in the design aspects of it.
2 MEMBER KIRCHNER: There's a lot that 3 goes into it, too.
4 MEMBER HALNON: Yeah. This is simply 5 the operation's response to it.
6 MR. SEYMOUR: Yeah. One point -- and 7 not to belabor the conversation, but it's such an 8 interesting conversation. I always enjoy talking 9 about this. If we talk about the fuel qualification 10 and the ramp rates that the fuel is able to accept -
11 - so that's another thing depending on the design 12 that may have to be taken into consideration. And 13 that could vary depending on what part.
14 And perhaps for new fuel, fresh core 15 load, you're going into something that's more 16 restricted. So it's not even just how high or low 17 you can go. It's, how fast can you go? There may 18 be implications there as well.
19 MR. SEYMOUR: Okay. If we could go 20 ahead and move on to the next slide, please. It 21 should be slide number 84. Okay.
22 So now I'm going to begin the discussion 23 on generally licensed reactor operators. And --
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169 1 until Jesse gets through the next couple slides and 2 talks through this and their thinking, I think it 3 would be more efficient. But obviously, I can't 4 obviously help myself sometimes as well.
5 So continue on, Jesse.
6 MR. SEYMOUR: Okay. I'll be discussing 7 the generally licensed reactor operator rule 8 language which replaces the rule language that 9 previously discussed a certified operator option 10 within Subpart F. And before getting into the rule 11 language, first we should be clear on what a general 12 license is in the context of our current rule 13 language.
14 Current Part 55 process and the 15 previously released Part 53 rule language on the 16 licensing of operators is built on the premise of a 17 specific license that is issued in the name of a 18 single individual in response to an application that 19 is filed with the NRC or regulatory requirements.
20 These licenses are issued as either a 21 reactor operator or a senior reactor operator 22 license. The key aspect here is that this license -
23 - and again, we're talking about a specific license 24 -- is only issued after a request is received and is 25 only issued to a single person. In contrast -- 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
170 1 this is something that's a new concept here within 2 operator licensing. So this is why we have the 3 slide to explain what the difference is here.
4 In contrast, with the specific lessons 5 that we've traditionally used for reactor operators 6 and senior reactor operators, a general operator 7 license does not require the filing of an 8 application, as the license is embedded in the rule 9 language itself. This general license applies to a 10 class of operators who meet certain conditions. And 11 as I'll be discussing later, it automatically comes 12 into effect once those conditions are met.
13 So there is no application filed to the 14 NRC for a general license, nor does the NRC issue 15 the license in the name of a specific individual.
16 If the conditions that are articulated in the 17 regulation -- the license -- are no longer met, then 18 the license no longer applies. And I will be 19 further discussing the similarities and differences 20 between an individual that receives a specific 21 license under Part 53 and one who is generally 22 licensed under Part 53 in a later slide.
23 Move on to the next slide, please.
24 Okay. So, at this point, what I want to 25 do is kind of take a step back to where we began NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
171 1 this conversation on this alternative to traditional 2 ROs and SROs. And really, this harkens back to some 3 of the discussions that myself and my counterparts 4 had with this Committee around May of last year on a 5 white paper that we'd written that discussed this 6 underlying philosophy.
7 One key difference from the previous 8 version of the rule language that was written for 9 certified operators is that the use of generally 10 licensed reactor operators is not optional. So, in 11 the previous version of the rule, if the facility 12 met the stringent safety criteria required to have 13 certified operators, then they could choose or opt 14 in, so to speak, for using certified operators.
15 But they could also choose to go with 16 the alternative of having traditionally specifically 17 licensed reactor operators and senior reactor 18 operators. So that is no longer the case. In order 19 to meet the requirements of the Atomic Energy Act, a 20 new class of facility has been defined using the 21 same stringent safety criteria that was previously 22 used as the threshold for certified operators.
23 And this class facility requires the use 24 of generally licensed reactor operators in lieu of 25 specifically licensed reactor operators and senior NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
172 1 reactor operators. So, again, the key takeaway here 2 is that if you meet the criteria for the use of 3 these generally licensed reactor operators, there 4 isn't the alternative of going with a different 5 operator licensing track. This is the operator 6 license track that you follow.
7 So, again, that is a change. That 8 criteria is summarized here --
9 DR. BLEY: You anchored that to 10 something, and I didn't quite -- you said there's 11 already regulation that would require that?
12 MR. SEYMOUR: No, no. The preliminary 13 proposed rule language that --
14 (Simultaneous speaking.)
15 DR. BLEY: Okay. Fair enough.
16 MR. SEYMOUR: Yep. That's right.
17 MEMBER BROWN: Is the new Part 53 stuff 18 that we discussed as part of the white paper?
19 MR. SEYMOUR: That's correct.
20 MEMBER BROWN: Sorry to interrupt the 21 thread, but I was losing the thread like Dennis. So 22 --
23 MR. SEYMOUR: That's right. And --
24 MEMBER BROWN: It's the new rule (Audio 25 interference.) Am I not on? I'm on. Can you hear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
173 1 me?
2 MEMBER KIRCHNER: Charlie, speak more 3 directly into it. We, on the virtual side, can't 4 hear you.
5 MEMBER BROWN: Oh, okay, okay, that's I 6 got it.
7 I guess when we went through the white 8 paper, I didn't realize that the prescribed type of 9 operator was a general, as opposed to an RO, certain 10 senior reactor operator.
11 I didn't gather out of the white paper 12 that was the directive, so thanks.
13 DR. BLEY: I don't think it was that way 14 the last time around, but maybe it was.
15 MEMBER BROWN: That's what I didn't. I, 16 yes, I'm a little bit confused.
17 MR. SEYMOUR: And, I can clarify at this 18 point.
19 So, what we did in the original white 20 paper, and you know, things have moved in iterative 21 manner since then.
22 But, the original white paper asked a 23 question. And, what the question was, what would it 24 take to have an autonomous reactor where, you know, 25 you could just we don't need to have those licensed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
174 1 operators even here anymore?
2 And, by extension, what that thought 3 process leads to is, you know, the fact that from a 4 regulatory standpoint, that we just want to be as 5 concerned about who was there, right?
6 So, what we did is we started asking 7 those questions about what type of criteria would be 8 needed for this hypothetical autonomous reactor, 9 that would not use licensed operators.
10 And as we worked through that, you know, 11 we, we came up criteria that, you know, generally 12 translates to what you see in the upper part of the 13 slide there.
14 Now, what we found as we went through 15 that work, is that, you know, again, you know, we 16 said okay, let's say hypothetical, we just delete 17 these senior reactor operators and reactor 18 operators, you know, out of the equation and you're 19 just left with this autonomous reactor that runs 20 itself.
21 MEMBER BROWN: Where is autonomous 22 relative to? Is that stated somewhere in the new 23 writing, new stuff you've written up?
24 MR. SEYMOUR: Well, it's --
25 (Simultaneous speaking.)
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175 1 MEMBER BROWN: It makes it sound like all 2 Part 53 plants are autonomous, and therefore, we 3 don't need a licensed operator.
4 MR. SEYMOUR: I think I can clarify that 5 here, you know, momentarily.
6 So, the thing about autonomous operation 7 is, you know, it factored into our thought process 8 here. And something that ends up being kind of 9 implicit in what we're doing here.
10 Because what we found is that as we 11 worked through that problem, we found that if you 12 just got rid of all the SROs and ROs, especially the 13 SROs, you were still left with a group of 14 administrative tasks that are very important, that 15 you needed a suitably qualified person to do. And, 16 these were important things.
17 So, what we found is that even if you 18 had a reactor that from a safety standpoint would be 19 autonomous, because no one needed to do anything for 20 safety, you still needed someone who could fill this 21 role of performing important administrative actions.
22 And, these administrative actions tended 23 to be at the level of what a senior reactor operator 24 would do.
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176 1 keep the plant within an analyzed state within the 2 licensing basis.
3 So, what we did is we worked through 4 that problem because we said, you know, besides 5 that, there's also the fact that a lot of these 6 designs may be able to perhaps run autonomously, but 7 most of them will still need someone to start them 8 up.
9 They may still need someone to conduct 10 physics testing. There will have to be someone that 11 is appropriately qualified and will go as far as to 12 say licensed, to conduct those reactivity 13 manipulations.
14 So as we answered this question about an 15 autonomous reactor, what we found is that no matter 16 how low the staffing got, no matter how high 17 inherently safe the facility got, you always had to 18 have somebody that was there who could fill this 19 support administrative role.
20 And, when the situation requires it, who 21 could go in there and do things like reactivity 22 manipulations.
23 So, out of that original articulation 24 of, you know, considerations and so forth, the 25 certified operator comes up when we originally NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
177 1 presented in the fall.
2 What we did is we looked at the paradigm 3 of the certified fuel handler, and how that 4 individual is used to fill important administrative 5 functions, and so forth.
6 And, we used that as a template to begin 7 to try to address that.
8 Now again being responsive to, you know, 9 very important points that the ACRS raised, and 10 working through different aspects of this, what 11 we've done is we've now evolved that into this 12 general licensed reactor operator concept.
13 Again, someone who could perform these 14 important administrative tasks that need to be done, 15 even if the reactor itself is otherwise autonomous.
16 So again, you know, you can't get rid of 17 that administrator. It's kind of funny. You can 18 get rid of the operator but not the administrator 19 sometimes.
20 And, at the same, too, because they are 21 licensed, they meet the requirements to perform a 22 reactivity manipulation if you have need of physics 23 testing, and that type of thing.
24 MEMBER BROWN: You just said they're not 25 licensed though.
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178 1 MR. SEYMOUR: Well, that's what we've 2 transitioned to here. That's the change.
3 MEMBER BROWN: I am really losing it.
4 MEMBER HALNON: So, hey, Charlie, before 5 we get too wrapped up on autonomous operation, let's 6 just look at that in this case as a bounding case, 7 as opposed to worrying how a staffing plan could be 8 approved that would not require any operators to run 9 it, at this point.
10 MEMBER BROWN: Greg, the only reason I'm 11 somewhat confused as we lead into this, is that it's 12 almost as if Framework A, Subpart F, is now, that 13 the use of Framework A, and the licensing of a 14 reactor, basically defines operators as though the 15 plant is autonomous by definition.
16 And that licensed operators with a 17 greater level of qualification, are an exception, as 18 opposed to --
19 (Simultaneous speaking.)
20 CHAIRMAN PETTI: That's not how I read.
21 MEMBER BROWN: That's the way I, that's 22 the way I've got it.
23 CHAIRMAN PETTI: There are quote, entry 24 conditions if you will, like this morning to get 25 here. They're extremely restrictive.
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179 1 MEMBER HALNON: Right.
2 MEMBER BROWN: Well, that's not the way 3 this conversation is going. It sounds like 4 everything has been assumed in Part 53 when you go 5 license as an autonomous plant, because obviously 6 that's what all these plants will be, and therefore, 7 we'll go with this.
8 And, if you have some exception maybe go 9 down the other path at having --
10 (Simultaneous speaking.)
11 CHAIRMAN PETTI: No, I think what they, I 12 don't mean to put words in Jesse's mouth, is they 13 used autonomous operation as kind of a limit in 14 their thinking. And, then backed off that.
15 But it's helped, it helped them make 16 sure they thought across the spectrum.
17 MR. SEYMOUR: And, that's a great way to 18 put that.
19 It's important to remember that we're 20 not talking about the reactor operator and senior 21 reactor operator traditional framework here, because 22 we haven't really changed that from what was 23 originally proposed the first time we came in front.
24 So, that's there. And, that is really 25 the default, right. What changes is --
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180 1 (Simultaneous speaking.)
2 MEMBER BROWN: What the default again?
3 MR. SEYMOUR: Normal reactor operators 4 and senior reactor operators.
5 MEMBER BROWN: And, that's just not what 6 I got out of this transition. To me it, and I'm 7 looking at the last two slides in terms of the way 8 it.
9 A general license sounded like it was 10 once you get a license for your plant, then 11 therefore, the only thing you really need is 12 generally licensed operators, because they're kind 13 of they seem to be autonomous.
14 I would have thought about it the other 15 way. The plant is licensed under our current rules 16 would have operators, but the current rules.
17 But if somehow the plant was, met these 18 other specific criteria, you could plea bargain with 19 the NRC, sorry to use those terminology, to say we 20 don't need to go through NRC approval of our 21 license, of operators 22 We can do this ourselves with this 23 generally licensed reactor operator that, that the 24 applicant takes care of.
25 DR. BLEY: Charlie?
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181 1 MEMBER BROWN: Yes?
2 DR. BLEY: Can I give you a specific 3 reference? If you will look through Subpart F to 4 53.8-0-0, eight hundred.
5 MEMBER BROWN: Yes, I've got it open so 6 tell me where again?
7 DR. BLEY: 53.800. And, not the first 8 paragraph but just at the end of it, it says, under 9 the following conditions, and that's when all of 10 this comes up.
11 And, I don't think it says autonomous 12 anywhere but I, yes, that was helpful to the 13 thinking that led them to come up with this.
14 But there's five criteria listed, one, 15 two, three, four, five, that you have to meet all of 16 those.
17 And, I guess if you meet all of those, 18 you don't have a choice, you will have a general 19 license for operations.
20 MEMBER BROWN: Well, my computer just 21 crapped out on me. Tell me what the --
22 (Laughter.)
23 DR. BLEY: Write it down, 53.800.
24 MEMBER BROWN: I got it back, no, I got 25 it back now. Which, 53. what?
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182 1 MEMBER HALNON: 800.
2 MEMBER BROWN: 800. Okay, all right, go 3 ahead. I'll --
4 (Simultaneous speaking.)
5 MEMBER BROWN: No, no, I've got it open.
6 It's just that I went to do something and all of a 7 sudden, I've now closed the file.
8 MEMBER HALNON It's on page 37 of the 9 pre-read stuff.
10 MEMBER BROWN: Yes.
11 MEMBER BIER: Jesse, I have another 12 question.
13 I think in general from what I 14 understand of it, I like this idea that there will 15 be some license conditions under any circumstances, 16 and it's just a matter of what the conditions are.
17 The question that I have, and I realize 18 administrative doesn't necessarily mean just filling 19 out paperwork or whatever.
20 But your comment that well, normally 21 this person would be there just to perform 22 administrative functions and if need be, they could 23 do things like manual reactivity control, or physics 24 testing or whatever.
25 I guess one question I have, which may NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
183 1 go beyond, you know, the regulatory verbiage is, how 2 similar or different would those actions be from 3 their ordinary, daily responsibilities, and would 4 they become kind of deconditioned and out of 5 practice, at doing the things they need to do in an 6 emergency?
7 MR. SEYMOUR: This is a great point, and 8 you know, something that's in human factors 9 engineering that we look at, is that degradation of 10 proficiency.
11 And, the original white paper even 12 addressed that high automation. That there can be a 13 tendency to, to lose that manual operating skill.
14 Actually, we've got a good Brookhaven 15 National Lab technical report, I think on that, from 16 I think even the '90s. I think it was already being 17 called out there.
18 And, so a key thing that we build into 19 this, because one of the required components for 20 this general licensed reactor operator program, is 21 that there has to be a proficiency program.
22 All right, so --
23 (Simultaneous speaking.)
24 MR. SEYMOUR: That's right, that's right.
25 So, that's an aspect of it.
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184 1 And, again, that's an area where as we 2 work through developing the guidance, you know, we 3 have the regulatory book that we want to build in 4 and require it, but we'll have to look through, you 5 know, what's really going to be necessary there.
6 DR. BLEY: Jesse, I don't know if you 7 call out that paper, but that was a paper by John 8 O'Hara & Jim Higgins, as I recall.
9 And, if you don't call it out as a 10 reference, some members might like to see a copy of 11 it. I've probably got one but you probably do, too.
12 MR. SEYMOUR: I think it's cited as a 13 reference on the white paper from May, but I'll make 14 a note, you know, manual proficiency.
15 That's definitely something that I can 16 circle back around with on the ACRS staff and, you 17 know, provide back to you.
18 MEMBER BROWN: A little below over on the 19 side of that 53.0 was what, what threw me because 20 this said, can't scroll, 53 defines a new class of 21 reactors which require GLROs, in lieu of ROs.
22 And, I didn't see where the transition 23 was or it made to me, it made it sound like all Part 24 53s were these particular class of reactors.
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185 1 Part 53 only needs GLROs, period. And, is that, 2 you're shaking your head yes.
3 MR. SEYMOUR: No, I was just saying that 4 was the key wording, the in lieu of. You know, that 5 was the missing piece there.
6 Okay --
7 (Simultaneous speaking.)
8 DR. BLEY: One last question from me at 9 this point, Jesse.
10 Are you going to talk in any detail 11 about section 810, which talks about what the 12 operators can do, and what the NRC can and must do, 13 if there are violations of certain criteria?
14 MR. SEYMOUR: Yes.
15 DR. BLEY: Okay.
16 MR. SEYMOUR: I'll go through the 17 various, you know, sections, but again, section 810 18 covers the general license itself.
19 And, you know, I helped to craft those 20 words, and we made sure that we incorporated what we 21 felt to be necessary regulatory tools in that blurb, 22 so, okay.
23 So --
24 (Simultaneous speaking.)
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186 1 might. This is Walt.
2 I'm just looking at your bullets for the 3 criteria, and thinking through the implications.
4 What you're really saying is that this 5 plant, if you combine number two with one, and just 6 take the operators off the table for the moment, 7 what you're basically saying is that this plant 8 should be able to come to a safe, stable shutdown 9 condition on its own, without any operator 10 intervention.
11 MR. SEYMOUR: That's right. And what we 12 do for the sake of it being conservative, is we do 13 mandate that this, you know, general licensed 14 reactor operator has to have the capability to 15 initiate a shutdown. Again, as a conservative 16 measure. So, we do require that that be maintained.
17 But that's the idea here is that, and 18 this is why we feel that, you know, it's technically 19 prudent in this case to be able to, you know, kind 20 of take a step back and to relax the requirements, 21 while still maintaining the licensing.
22 Is that this human role in facility 23 safety is markedly different at this type of 24 facility. And again, this would just be a subset of 25 the facilities in that Part.
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187 1 MEMBER KIRCHNER: I'm just thinking back.
2 I --
3 (Audio interference.)
4 MR. SEYMOUR: -- the application would be 5 processed.
6 MEMBER BROWN: So they would be, the 7 application would specify that we meet these things, 8 and therefore, only GLROs are needed?
9 MR. SEYMOUR: That's correct. And, the 10 burden of proof for that would be on --
11 (Simultaneous speaking.)
12 CHAIRMAN PETTI: So guys, I think we have 13 to wait, but I think we lost the court reporter.
14 Your slides aren't up anymore, whoever does your 15 slides.
16 MEMBER KIRCHNER: Yes, we were tripped 17 off the meeting.
18 CHAIRMAN PETTI: Okay, yes, we all did.
19 (Chorus of agreement.)
20 CHAIRMAN PETTI: Okay, and, the court 21 reporter's back and the slides are up, so okay, 22 let's continue.
23 MR. SEYMOUR: Yes, and the point that I 24 was just making, just so that the court reporter 25 gets it, is one of the key attributes here is that, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
188 1 you know, a facility licensee applicants, as part of 2 getting their operating license and refined 3 operating license, would have to demonstrate that 4 they meet these criteria for the use of general 5 licensed reactor operators.
6 And, you know, in demonstrating that, 7 again, the burden of proof would be on them. They 8 would have to show how their design meets these 9 stringent requirements.
10 But by meeting that, they would then be 11 permitted to, you know, to use this mechanism. In 12 fact, they would have stop by the way things are 13 structured.
14 MEMBER BROWN: So that's how it becomes 15 part of the licensing basis of the plant?
16 MR. SEYMOUR: That's correct.
17 MEMBER BROWN: Okay, that's, I got the 18 connect now.
19 Thank you.
20 MR. SEYMOUR: Okay, so again, you know, 21 just, I guess to wrap up this slide, so at the top 22 of the slide again, the things that we point out 23 here is just at a very high level, if we were to 24 take those criteria for, for having these operators 25 and distill it down to its most fundamental ideas, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
189 1 that's really what we had is a synopsis up there.
2 So again, you know, it's a idea that 3 you've got a facility where no operator action is 4 needed to mitigate plant events, and achieve 5 acceptable accident performance.
6 And going beyond that, again to account 7 for, you know, uncertainties and unknown unknowns, 8 we go further and say that even defense in depth, 9 you know, has to be able to be accomplished in a 10 satisfactory way, independent of operator action.
11 So, now what that tells us --
12 (Simultaneous speaking.)
13 MEMBER HALNON: So, Jesse --
14 MR. SEYMOUR: Yes?
15 MEMBER HALNON: -- when you say, I'm 16 sorry, just I wanted to just make a point with that, 17 the language you used. Defense in depth must be 18 able to, but does it have to be?
19 MR. SEYMOUR: That's a good point. I see 20 the, you know, the subtlety of the wording there.
21 MEMBER HALNON: Several places there's a, 22 in the criteria it says where it can be. And, 23 there's always that aspect of if they're able to get 24 in the way, they might.
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190 1 operator action when they shouldn't have been, could 2 be for asset protection, or it could be someone 3 thinking that they know more than the control 4 systems, and so they take manual action instead of 5 letting it play out.
6 That's the nuance I wanted to just 7 explore when you talk through this stuff.
8 MR. SEYMOUR: That's a good point. I did 9 capture that, you know, subtlety of the wording 10 there so we can take another look at that.
11 Item 5, and again, you know, what I have 12 here is a high level, is a very high level synopsis 13 because the criteria themselves haven't evolved 14 since the last time, you know, I talked to the 15 committee.
16 Again, they were just located in a 17 different spot and again, they were facilitating 18 certified operators.
19 But the fifth criteria, right, this is 20 one that I think speaks to that point and it's this.
21 And, I have a copy here so I'll just read it.
22 So, the plant response to licensing 23 basis events does not rely on human actions to 24 ensure performance of systems, structures, or 25 components.
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191 1 Compliance with this paragraph may be 2 achieved through the use of systems, structures, and 3 components, that function through inherent 4 characteristics, or if engineered protections 5 against human failures.
6 That last part of it, and again this, 7 you know, this is a high bar. But that last piece 8 of it, right, this notion that, you know, you have 9 to show that you're either relying on things that 10 are inherent, or, you know, another alternative 11 would be to have engineered protections against 12 human failures.
13 This gets into the idea that you have to 14 guard against inappropriate human action putting you 15 into a state that would, you know, render this, you 16 know, render this ineffective.
17 And, again, you know, there may be 18 different ways to do that. So we have to, you know, 19 try to juggle crafting the wording in a way that 20 allows for different solutions to that.
21 But at the end of the day, what we're 22 getting at with that fifth criteria, is this idea 23 that you either have to build the plants, you know, 24 using things that are inherent or perhaps even of a 25 robust passive nature, to where those types of human NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
192 1 errors credibly aren't going to, you know, render 2 those systems, structures or components unable to 3 perform their job.
4 Or alternatively, you know, you have to 5 put, you know, those engineered protections there.
6 And, I think an example of this, you 7 know, when you review fuel cycle facilities, and you 8 get into the types of controls that fuel cycle 9 facilities use, you know, you have, you know, 10 certain engineered controls that those facilities 11 will use.
12 And, you have certain IROFS, items 13 relied on for safety that are administrative in 14 nature.
15 But you can have certain IROFS that are 16 administrative in nature, and considered to be 17 enhanced.
18 And, you know, the point that I would 19 make there is, conceptually what's happening is 20 you're putting an engineered feature that's there, 21 to work in conjunction with something that's 22 administrative. Like a task that you have to do, 23 just to provide added insurance that it's done in a 24 way that's appropriate.
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193 1 we interact with over on the fuel cycle facility 2 side of things, a bit more.
3 So again, when we look at that, that's 4 the important thing to keep in mind, right. We're 5 trying to provide, you know, some flexibility in how 6 a designer chooses to meet that, but the underlying 7 idea is exactly that.
8 There has to be a reasonable safeguard 9 that's there against not only the errors of 10 omission, you know, the person doesn't do an action 11 they're supposed to, right?
12 But also those errors of commission, 13 right. Somebody does something with the system that 14 puts it in some undesired state, and so the rest of 15 the safety scheme can't do its job.
16 DR. BLEY: Jesse?
17 MR. SEYMOUR: Yes?
18 DR. BLEY: I know what you're trying to 19 do. I would make you a little side bet that any 20 design you bring in, some of us could figure out 21 something an operator could do.
22 Now when you go to the fuel cycle 23 facilities, they say gee, if you have double 24 contingency, that takes care of it.
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194 1 people violate double contingency, or other actions.
2 So, people get around those, and other people can 3 figure out ways they could do it.
4 And, if you're really anchoring to that 5 saying it can't happen, I don't think it's going to 6 work.
7 I think you need something that's less 8 than that but precise, or you're just going to be 9 stuck.
10 You bring that design that everything 11 passed on to ACRS and somebody says what if he does 12 that? Well, that's dumb, he won't do that.
13 But what if he does? And, those things 14 happen. People pop a breaker, or pull a fuse or 15 something, and surprise. What can't happen, 16 happens.
17 So, the fuel cycle people get around it 18 by saying if you do this much, that's good enough.
19 And, we still have accidents but still, that's, 20 that's the way they live with it.
21 You're not quite giving them that out 22 here. You're saying the engineered protections have 23 to keep you from doing it, and I really don't think 24 that's going to be possible when you get into 25 specifics.
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195 1 MR. SEYMOUR: It's good feedback.
2 Something that we've thought through in terms of 3 guidance, and as this becomes more refined, what 4 this would look like is, you know, the possibility 5 for, you know, human reliability analysis used as a 6 tool, to go through and you know, by taking those 7 human factors, engineering and, you know, PRA types 8 of insights that come to play.
9 And, you know, human reliability 10 analysis, you know, helping to work through figuring 11 out what needs to be done to reduce those 12 likelihoods of failure down to some, some acceptable 13 level.
14 And again, you know, this is an active 15 problem that we're still, still working on.
16 (Simultaneous speaking.)
17 DR. BLEY: That's good enough, but I 18 think you need to pay attention to that, some 19 acceptable level, because right now it says it can't 20 happen.
21 MEMBER HALNON: Yes, and just to further 22 that and we can move, but, you know, the Reg Guide 23 1.174 talks about defense in depth, and then part of 24 that is the inclusion of programmatic activities, 25 which inherently are done by people.
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196 1 I think you're, you could probably get 2 through the safety functions and response to 3 licensing basis events, but when you start getting 4 into defense in depth, how deep do you go, and how 5 many, how long does the operator put his hands in 6 his pocket.
7 You're going to have a really difficult 8 time, defending the questions that could come out on 9 the what if side.
10 So, you got it, you understand our 11 position and questions on that. I think, I think 12 you're right. The guidance is going to be very 13 crucial.
14 And, I would encourage you to go back 15 and look at the language, where it says just for 16 example, requirements associated with defense in 17 depth, that's described in 53.250, can be met 18 without reliance on human actions.
19 But it doesn't say must be, or shall be, 20 or anything like that. It just says yes, if you can 21 do that, then you can do that.
22 But that doesn't guard against the other 23 part of it where they can be met, but we might have 24 put some operator actions in place just in case.
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197 1 depth?
2 So, I think that that's the general 3 thought process that at least most of us are going 4 through.
5 MR. SEYMOUR: I appreciate the feedback, 6 and these criteria are something that we've 7 recognize kind of from the get go, that, you know, 8 that there is going to be significant feedback and 9 comment on.
10 And, we're receptive to that, you know, 11 both as we receive that from the industry, and from 12 this body as well.
13 And, it's a particular area, you know, 14 as we move into the development of the proposed Rule 15 package. One of the things that we'll have an 16 opportunity to do is just, you know, solicit 17 specific comments on key areas.
18 And, this is an area that we have 19 discussed, you know, actually pointing to 20 specifically as being an area where we'd like to get 21 that.
22 So, again, I appreciate the feedback and 23 we will take that into consideration as we, we move 24 through this.
25 Again, you know, it's a very, it's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
198 1 very challenging thing to work through trying to 2 find, you know, the right balance of requirements 3 here.
4 MR. GREEN: Jesse, this is Brian Green, 5 Human Factors team lead. If I could, I'd just like 6 to follow up on something that, that Dr. Bley had 7 said.
8 You had pointed towards the double 9 contingency with the fuel cycle facilities. Was 10 that a suggestion that you thought that may be 11 something that we might consider adding, or was that 12 more just a comparison?
13 I guess my question is, you know, errors 14 of commission area always possible, and we probably 15 can never eliminate those. There's probably never 16 been a system ever designed that has no errors, no 17 possible errors of commission.
18 But is that your suggestion is that may 19 be a reasonable way to modify this to continue to 20 move forward?
21 DR. BLEY: I think you need some kind of 22 criteria that for you, is good enough. That one 23 works on the fuel cycle. I haven't thought about 24 applying it in the nuclear plant. But maybe it 25 does.
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199 1 And, there are some double activities 2 that are probably more likely to fail, than some 3 single activities.
4 So, you have to be careful how you do 5 this thing. No, I was using it as a comparison to 6 say that's how they defined it, and we still have 7 accidents. Not so many, but we have them.
8 MR. SEYMOUR: Fair enough, thank you.
9 We'll take a look at it and think on that to see if 10 there's a, you know, a reasonable way to, to use 11 that or something like it, to get a similar factor.
12 Thanks.
13 MEMBER KIRCHNER: Jesse, this is Walt.
14 Have you tested these criteria against 15 some of the new designs? Because from a designer's 16 standpoint, and, you know, just if you were 17 implementing in design space the advance reactor 18 policy statement, you would design a system such 19 that no operator action was needed. Especially for 20 the licensing basis events. Not the plant events.
21 So I'm curious about the choice of words 22 here. When you get to a larger system with more 23 complexity, especially in the balance of plant, or 24 the auxiliary systems for the reactor itself, I'm 25 just going through the exercise that if I'm 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
200 1 designing an advance reactor, I'm going to try as 2 much as possible to achieve passive safety, or 3 inherent safety by design.
4 I'm going to do if you go back to the 5 knowledge report that you put out on defense in 6 depth, you've got the operator usually at the end of 7 the chain.
8 You want the defense in depth primarily 9 to be by design, by redundancy, by independence, by 10 Charlie's fundamental principles, whether it's an 11 I&C system, or it's a mechanical system so that the 12 outcome is a safe landing. And, hopefully a safe 13 and stable shutdown.
14 So I'm just, I'm asking mitigate plant 15 events, or mitigate licensing events? If it's all-16 encompassing, then short of the simple nuclear 17 battery design, you're going to have an operator in 18 the loop with plant events.
19 I mean that can be all automated, but 20 typically that would be the part of the plant where 21 the operator would, would be an important variable.
22 MEMBER BROWN: If I was looking at this 23 based on our earlier conversation, just to spin you 24 off of Walt's comment.
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201 1 I guess a couple of them or whatever the thought 2 process is, it would still seem to me the last thing 3 to do, there would always be a fully licensed person 4 somewhere in the overall, whether even if he's 5 sitting back in the admin building.
6 Somebody on site, that is fully 7 licensed, that could be called on to provide 8 assistance if you got outside the bounds of what you 9 thought you met, but all of a sudden something.
10 I'm just kind of nervous with people 11 know how to ride the bicycle, but they don't know 12 how to put the chain on, okay?
13 MEMBER BIER: Charlie, I guess it's 14 personally a matter of semantics. Because if I'm 15 understanding right, you have gone from certified 16 operator a while ago, to licensed operator now. Is 17 that correct?
18 MR. SEYMOUR: That's correct.
19 MEMBER BIER: So, the person would be 20 licensed but with a different set of capabilities, 21 but with the same like legal authority and 22 responsibilities as a license.
23 MEMBER BROWN: But are the certified 24 stuff you talked about, the same as what you were 25 talking about now in the GLRO? Is that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
202 1 certification concept the same?
2 MR. SEYMOUR: A lot of the elements of it 3 do carry forward in terms of, you know, the 4 training, the examination. A lot of those 5 flexibilities.
6 We still envision a great deal of that 7 being similar, to what we had discussed for the 8 certified operator.
9 Again, certain things have changed 10 dramatically, right. Again the fact that there is 11 this license involved. There's things that are 12 embedded in that.
13 And, there are different authorities and 14 so forth, that a licensed operator.
15 MEMBER BROWN: Is the GLRO licensed by 16 NRC, or by the applicant?
17 MR. SEYMOUR: Licensed by the NRC. It's 18 a different licensing.
19 MEMBER BROWN: Oh, so this is different 20 than this certified?
21 MR. SEYMOUR: Yes, that's right.
22 MEMBER BROWN: Oh, okay, I lost that 23 bubble. So but it's not the same as a licensing NRC 24 would put on for a quote licensed reactor operator, 25 senior reactor operator? Is that?
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203 1 MR. SEYMOUR: It's a different 2 administrative mechanism that's used to do it. So -
3 -
4 (Simultaneous speaking.)
5 MEMBER BROWN: Well, administrative is 6 one thing, but what about technical?
7 MR. SEYMOUR: At the end of the day, all 8 of those operators are licensed by the Nuclear 9 Regulatory Commission.
10 MEMBER BROWN: So it's not the certified 11 guy that we talked about?
12 MR. SEYMOUR: That's right.
13 MEMBER BROWN: In the last meeting? This 14 is another.
15 MEMBER HALNON: Well, we're getting a 16 little ahead of ourselves.
17 MEMBER BROWN: Okay, I'm sorry, Greg. I 18 just, I kind of trashed your approach. I'll --
19 (Simultaneous speaking.)
20 MEMBER HALNON: No, I --
21 CHAIRMAN PETTI: Let's let Jesse move 22 forward here.
23 MEMBER BROWN: Yes, I quit.
24 CHAIRMAN PETTI: It's Friday afternoon.
25 Let's try to get through this.
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204 1 DR. BLEY: Well, okay before we go 2 forward, I wanted to go back to the issue Brian 3 raised, about would double contingency be a good 4 thing here.
5 And, I thought about it a little more 6 and remembered some work we had done a while back.
7 And, you know, with the LWR, we have to have, we 8 have a single failure criterion that we use.
9 So no single failure can get you in 10 great trouble.
11 With an operator, we thought about that 12 some years ago, and single failures by operators can 13 affect multiple things.
14 And, I don't think you would come up 15 with a real single failure criteria and to apply to 16 operators.
17 You guys can give it a bunch of thought, 18 but we've done it once before and could never get 19 there, because of the operator can bypass things 20 that normally keep systems and components separated 21 from each other.
22 So, that's a point to think about. And, 23 I guess I have one last question on the stuff 24 everybody else was asking you about.
25 I thought we read and you told us, 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
205 1 facility gets a general license. But that's not 2 true? Each individual operator gets a general 3 license?
4 MR. SEYMOUR: So, the general license 5 mechanism is a little bit different. What I want to 6 do is just touch upon the first point first though.
7 With regards to the operator, right, and 8 the ability that the operator may do the wrong 9 thing, I think it's important to note we're still 10 putting a licensed operator into this position.
11 So again, there's that licensing, 12 there's a presumption that there is, you know, some 13 minimally required degree of training and 14 examination proficiency, continuing training, 15 reexamination that happens.
16 And, you know, there's requirements for 17 simulation facilities and so on and so forth. And, 18 all that builds towards the idea that, you know, we 19 don't want this person to be going and making those 20 types of errors and so forth.
21 So we're going to require some 22 reasonable measures to make sure that their 23 training, and their qualification meets a certain 24 pedigree, and that they are licensed.
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206 1 that we don't anticipate that this person is going 2 to have to be, you know, taking actions to mitigate 3 events at these, at these types of facilities.
4 That's the difference.
5 So again, I just want to say that, you 6 know, irrespective of, you know, kind of the 7 underlying philosophy of how we got here, at the end 8 of the day we're still saying that this is a 9 licensed individual with some, you know, baseline 10 level of training qualification.
11 MEMBER BROWN: By NRC?
12 MR. SEYMOUR: Licensed by the NRC, yes, 13 that's right.
14 MEMBER BROWN: When I asked the question 15 earlier, I thought it came back out that the 16 applicant would be taking care of that. But that's 17 not the case now.
18 This is the NRC would be, might be a 19 lower level than they would apply to a quote, the 20 current standard of ROs, but that would be licensed 21 to a consideration that NRC considers satisfactory 22 downstream, from those two higher qualifications.
23 MR. SEYMOUR: That's correct.
24 MEMBER BROWN: Whenever that happens to 25 be.
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207 1 MR. SEYMOUR: And we'll get into the 2 mechanism that.
3 MEMBER HALNON: Yes, Charlie, you're 4 three slides ahead of us.
5 MEMBER BROWN: I'm sorry.
6 MR. SEYMOUR: Okay, so if we could 7 continue on to the next slide, please.
8 So what I want to talk about in this 9 slide here are some of the, you know, details about 10 this program.
11 And, again, some of this is just high-12 level just kind of, you know, establishing some 13 baseline pieces and parts of what's coming into play 14 here.
15 So as stated on the slide, there's only 16 one license level for the general license. So 17 there's no differentiation, such as reactor operator 18 and senior reactor operator.
19 And conceptually, if you think about 20 like a certified fuel handler, there is no senior 21 certified fuel handler. There's no, you know, 22 junior fuel handler. There's just one level that's 23 there.
24 So again, and that's not a licensed 25 role, but it's a useful kind of analogue to thinking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
208 1 about this here.
2 Again, there's just one level of license 3 within that particular framework, and it's the 4 general license reactor operator.
5 Because of the types of functions 6 fulfilled by this operator, it is similar although 7 not the same, as a specifically licensed SRO in 8 terms of the types of duties, and administrative 9 functions the person is fulfilling.
10 So again, we call it a general licensed 11 reactor operator, but a good way to think about this 12 is if you, you know, stripped away those 13 administrative responsibilities from a senior 14 reactor operator, and really thought about what they 15 are, compliance with technical specifications, 16 making notifications.
17 You know, maintain the plant within its 18 licensing basis, authorizing departures from the 19 licensing basis in an emergency, those are the types 20 of responsibilities that this general licensed 21 reactor operator would have.
22 So in some ways, it is, you know, 23 comparable to a senior reactor operator level of 24 role. But again, there's no distinction between, 25 you know, this and a lower level licensing.
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209 1 And as previously stated, if the 2 facility meets the criteria for this class of 3 license, then they will be required to use this 4 process, as opposed to the specifically licensed 5 reactor operator and senior reactor operator 6 process.
7 This is done to ensure that uniform 8 conditions for each class of license, is maintained 9 as required by the Atomic Energy Act.
10 The training program used for general 11 license reactor operators, will be based upon a 12 systematic approach to training, and will still be 13 reviewed and approved by the NRC.
14 So as we go through and we talk about 15 this process, we'll see that there's flexibilities 16 involved, and because of the nature of the general 17 licensed reactor operator process, and the nature of 18 general licensing, an NRC examiner would not be 19 going out and administering this examination.
20 We would not be writing out a license 21 with this person's name on it at the end of that.
22 But the training program and the examination program 23 used, to have this person meet the general licensing 24 requirements, would be commission approved programs.
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210 1 programs that would be used to implement that 2 process.
3 So again, this is still true for both 4 specific and general licensed operators. So again, 5 within Part 53, no difference there that, you know, 6 these programs have to be reviewed and approved by 7 the commission.
8 There is a later slide that will provide 9 a table showing the similarities and differences, 10 between the two types of licenses.
11 So I will focus primarily on the general 12 license for this presentation, but at the end we'll 13 see, you know, in a tabular format, what those 14 differences are.
15 For the general license reactor 16 operators, facilities are responsible to ensure that 17 sufficient staffing is present, such that there is a 18 continuous monitoring of the plant by folks who are 19 general licensed under this Part, to ensure a 20 continuity of responsibility.
21 So, what that means is this. When we're 22 talking about plants that don't meet these stringent 23 criteria and have this type of operator, a human 24 factors engineering based analysis, will need to be 25 conducted to determine what the appropriate staffing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
211 1 level is to maintain plant safety functions.
2 So for the plants that have the 3 specifically licensed ROs and SROs, there's a much 4 more involved process that goes through, because 5 there's an assumption that human action is going to 6 be necessary to maintain plant safety.
7 So there will need to be a body of work 8 that is assembled as part of the, you know, design 9 and application process and show that the staffing 10 model is apt to handle that.
11 In this case, by meeting these criteria, 12 what we establish is that there is not a human role 13 in the maintenance and safety functions.
14 So what we do is we adopt a more 15 proscriptive, you know, more relaxed baseline, you 16 know, kind of ground floor if you will, for what 17 monitoring needs to be done.
18 And again, what that consists of is 19 essentially two elements. One that there has to be 20 continuous monitoring of the fueled reactors; and, 21 also that there has to be a continuity of 22 responsibility for facility operations over the 23 operating phase.
24 The responsibilities for these general 25 licensed reactor operators include, and I touched NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
212 1 upon some of these before, monitoring plant 2 parameters, evaluating any emergency conditions, 3 shutting down the reactor, if required.
4 Dispatching and directing operations and 5 maintenance personnel; and, also implementing the 6 emergency plan per the site's specific requirements.
7 Move on to the next slide, please.
8 Okay, so now I'm going to go through and 9 step through the language that is new, that 10 addresses the general licensed reactor operators.
11 So as previously discussed, section 12 53.800 finds a new class of plants using design 13 criteria that were previously developed for use, you 14 know, in determining whether or not certified 15 operators can use, could be used.
16 So again, previously those requirements 17 were located in a different spot, used in a slightly 18 different manner.
19 Now what they do is they define a 20 separate class and facility. So in effect, a subset 21 of the Part 53 facilities are defined as this class.
22 And, that's something that we have to do 23 to conform with the Atomic Energy Act, in order to 24 use the specific form of operator licensing in that 25 context.
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213 1 Section 53.805, which is the next 2 section, provides the requirements for the facility 3 to meet, if that facility falls into this particular 4 class.
5 So, in brief, the facility must maintain 6 the generally licensed reactor operator 7 qualifications, and maintain their responsibility 8 for the administrative tasks ,that I talked about 9 earlier.
10 As well as ensuring that those operators 11 are qualified to implement the capabilities we 12 talked about. And, those capabilities were things 13 like initiating the reactor shutdown, you know, 14 dispatching operations and maintenance personnel, 15 and so forth.
16 So additionally, the facility needs to 17 develop, implement, and maintain NRC approved 18 programs for training, exams, and proficiency for 19 these operators.
20 And, the facility needs to make sure 21 that the relevant Part 26 and Part 73 requirements, 22 for fitness for duty, work hour restrictions, and 23 other examples would be physical protections such as 24 access authorization are met, as they pertain and 25 apply to the facility in question.
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214 1 The individual --
2 (Simultaneous speaking.)
3 MEMBER HALNON: These would be in Part 26 4 and 73, supervisors that are management?
5 MR. SEYMOUR: So what we do at the level 6 of the language that we have here, is we point to 7 Part 26 and Part 73. We don't attempt to go through 8 and, you know, articulate all the discrete 9 requirements.
10 MEMBER HALNON: Right, Part 26 has some 11 just differentiations between supervisors and non-12 supervisory people. I just wanted to know which 13 ones these would fall into.
14 MR. SEYMOUR: It's a good question. That 15 is one that I'll have to get back to you, the 16 committee on, so.
17 MR. HARRIS: Yes, hey, Jesse, this is 18 Paul Harris. I'm a Senior Program Manager for Part 19 26, drug and alcohol testing provisions.
20 And, in Part 26, what we're proposing is 21 that the generally licensed reactor operator, what 22 we do is we point to Jesse's requirements in Part 23 53, and we treat these individuals as we would an RO 24 and SRO.
25 MEMBER HALNON: Okay. Thanks, Paul.
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215 1 MR. HARRIS: Yes.
2 MR. SEYMOUR: Thanks, Paul, I appreciate 3 that.
4 MR. HARRIS: Yes.
5 MR. SEYMOUR: And additionally, there's a 6 key report that's here. Now if you'll notice that 7 last, you know, small bullet, report the names of 8 all general licensed reactor operators to the NRC 9 annually.
10 But as we go through this general 11 licensing process, which is different in some 12 regards to what we're used to, one of the things 13 that we, we have embedded in that, is the need for 14 the facility to report to us on an annual basis, the 15 names of all individuals who are covered under this 16 general license.
17 So again, a new reporting requirement.
18 And, this is a function of general licensing.
19 MEMBER BROWN: I presume the local 20 resident would always have a complete list of all 21 GLROs that are --
22 (Simultaneous speaking.)
23 MR. SEYMOUR: So with regards to a --
24 MEMBER BROWN: -- that's an onsite 25 resident.
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216 1 MR. SEYMOUR: With regards to a resident 2 inspector program, or the absence thereof, I'd have 3 to defer to probably Bill Reckley, if he's on the 4 line.
5 Because one thing that I'm not prepared 6 to speak to, is where we're at with regards to 7 whether all or some of these facilities, would 8 necessarily have resident inspectors. Particularly 9 if we're talking about micro reactors.
10 But Bill, I'm not sure if you're on the 11 line?
12 MR. RECKLEY: Yes.
13 MR. SEYMOUR: Okay.
14 MR. RECKLEY: Yes, Jesse, this is Bill 15 Reckley.
16 Charlie, whether we have resident 17 inspectors or not, the facility would always have 18 the names of the individuals, and the NRC would 19 always have access to that list.
20 MEMBER BROWN: So a region person could 21 come in and inspect and always have the --
22 (Simultaneous speaking.)
23 MR. RECKLEY: We always would have 24 unfettered access to the list.
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217 1 for.
2 MR. RECKLEY: Right.
3 MR. SEYMOUR: Okay, and sorry about that, 4 I thought the question was specific to, you know, 5 resident inspectors themselves.
6 MEMBER BROWN: I didn't go into micro 7 reactors but we can think about those and dream all 8 we want to, but never mind, I'll stop talking.
9 MR. SEYMOUR: Our, you know, our 10 perspective on the record keeping requirements that 11 we have here, and our intent is that if needed, at 12 any given point in time, we could go and, you know, 13 get the list and look at the records. That we could 14 verify status.
15 And something that we're working on and 16 thinking through as we do this, and you can see at 17 various places in the language where we leave record 18 keeping requirements, what we're doing is 19 essentially leaving the breadcrumb trail that we 20 need for an inspection program, when the appropriate 21 time arrives to go ahead and craft the inspection 22 program there.
23 MEMBER BROWN: I just didn't want to see 24 it every year we'll find out who is really there, 25 really the resident, the local, somebody ought to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
218 1 able to go into the plant at any time. That list 2 ought to be current.
3 MR. SEYMOUR: That's our intention here.
4 And, as we continue working through this 5 problem, you know, one of the things that, you know, 6 I think provides a really good frame of reference, 7 is if you look at how we currently do 8 requalification training of inspections, every other 9 year, so on a biannual basis, we send two examiners 10 out to each commercial plant, and they'll actually 11 be out there for a week, looking through the 12 requalification training program.
13 There's the records review that we do.
14 We look at, you know, performance and so forth.
15 And, that's, it's a useful benchmark for the types 16 of thinking that we have right now, for what may be 17 necessary with this type of a program.
18 Again, we just haven't reached a stage 19 where we're really putting pen to paper on it yet.
20 Okay, so --
21 (Simultaneous speaking.)
22 MEMBER KIRCHNER: Jesse?
23 MR. SEYMOUR: Yes?
24 MEMBER KIRCHNER: This is Walt again.
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219 1 whether it's this GLRO or the traditional approach, 2 that simulators or plant referenced simulator, or on 3 plant training, would much like in 10 CFR 55, that 4 would still adhere, right?
5 MR. SEYMOUR: What we have in the 6 requirements right now establishes, you know, a 7 requirement to have SAT-based training.
8 Again, that's, you know, par for the 9 course. It establishes, you know, requirements for 10 the use of simulation facilities.
11 So as you go through, a lot of this 12 aligns I think with the framework that, you know, 13 you're thinking of there. Those pieces of parts 14 are, are there. In some cases, there's relaxations 15 just based on the nature of the licensing.
16 But again, you know, having a training 17 program, having an exam program, you know, what we, 18 what we have is, you know, a requirement to use a 19 SAT-based process to train these operators.
20 To have, you know, an NRC approved 21 examination on the tests on their required knowledge 22 and abilities, that's used to examine them.
23 That there is a requalification training 24 program that's in effect so that they're, you know, 25 trained on a continual basis, that there is 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
220 1 know, requalification exams.
2 Now again, we do provide some 3 flexibility in what the periodicity is for those 4 requalification exams.
5 For the existing plants out there, it's 6 currently a two-year periodicity. That's something 7 where we do provide added flexibility here, for 8 these kind of general licensed reactor operators.
9 And, then you get to the simulator 10 requirement. And the way that the simulator 11 requirements are structured, again there is, you 12 know, a set of requirements that, you know, need to 13 be met if a simulation facility is used for specific 14 purposes.
15 So again, for training, for the conduct 16 of exams, or for experience requirements which, you 17 know, when we talk about those, that generally 18 points to reactivity manipulations that are being 19 done, you know, as part of proficiency or what not.
20 So, what we, what we have as we go 21 through those requirements is, you know, this 22 possibility that if you have a small micro reactor 23 facility, I use this as an example, you know, 24 perhaps you're going to be able to look at that and 25 make the case that you could develop some type of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
221 1 examination, that just uses the plant itself using 2 walkthroughs and so forth, to administer your exam.
3 Perhaps you could, you know, use some 4 type of a partial scope simulator, to go through and 5 conduct the required training, or perhaps a portion 6 of your exam that you need.
7 And, you know, just get the required 8 reactivity and relations on the plant itself.
9 So, the potential does exist with the 10 simulator requirements, that, you know, you may see 11 outcomes from that where an applicant is able to 12 make an adequate case to use something (audio 13 interference) full scope plant reference and 14 simulator.
15 Again, that flexibility is built into 16 the regulation, but the key point is just that the 17 burden of proof will be on the applicant, to go 18 through and make the case of how they're able to do 19 those required elements, using something other than 20 that full scope plant reference simulator.
21 MEMBER BROWN: And, that would be part of 22 the licensing, or is that after the license is 23 granted and NRC will figure that out later?
24 MR. SEYMOUR: For plants that have 25 specifically licensed ROs and SROs, we have built NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
222 1 into the regulation, the requirement for that 2 simulator to get approval.
3 For the general licensed reactor 4 operators, we do not have a requirement for that 5 simulator to be approved of.
6 Now, they'll have to submit to us the 7 training plan and the training program, and the 8 examination program, that they're going to use.
9 We'll review that, and we would get 10 insights into how they're going to accomplish those 11 things.
12 But the simulator itself would not 13 require our approval, you know, the actual initial 14 approvals of everything.
15 What would happen is that there would be 16 regulations that would have to be complied with. So 17 again, if we conduct inspections and so forth, we 18 could certainly go in and verify compliance with 19 those simulator requirements.
20 And, they're predicated upon the use of 21 the simulator. If they're not crediting the use of 22 the simulator to meet a certain area, then, you 23 know, obviously there may be a different way that 24 they're accomplishing that.
25 But the key thing I think here, is just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
223 1 to keep in mind that we're still reviewing and 2 approving the training program, and the exam 3 program.
4 And, embedded within those, especially 5 in the exam program, they have to go through, and 6 they have to show what the individual components of 7 their exam will be.
8 And, they'll have to show that they're 9 able to construct an exam program in some, you know, 10 form that we find to be acceptable.
11 One of the things you'll have to do 12 there is say, am I going to use a simulator to meet 13 this. And, if that's the case, again, we'll get 14 some insight into, you know, the intended usage of 15 that simulator.
16 But in terms of the initial simulation 17 facility needing to be a condition approved 18 simulator or something to that effect, when you 19 initially get the, get the plant --
20 (Simultaneous speaking.)
21 DR. BLEY: Microphone, please.
22 MR. SEYMOUR: -- licensed.
23 Sorry? Oh, sorry about that, yes, it 24 drifted away a little bit, yes.
25 DR. BLEY: I had a quick question.
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224 1 MEMBER BROWN: I think the short answer 2 is it may or may not be --
3 (Simultaneous speaking.)
4 DR. BLEY: -- anybody seen this --
5 (Simultaneous speaking.)
6 DR. BLEY: -- or have you had public 7 meetings on it?
8 MR. SEYMOUR: With regards to the 9 simulation aspect of, or --
10 (Simultaneous speaking.)
11 DR. BLEY: No, the whole general licensed 12 reactor operator concept.
13 MR. SEYMOUR: Well, this is actually the 14 first public presentation where we --
15 (Simultaneous speaking.)
16 DR. BLEY: Okay, that's --
17 MR. SEYMOUR: -- discussed this.
18 We just rolled out this rule language 19 about, I think about two weeks ago, if I remember 20 correctly.
21 And, what we do have is we have slated 22 next week on the 30th, a stakeholder meeting where I 23 will be presenting, you know, a lot of the same 24 material, you know, to our stakeholders to go 25 through it.
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225 1 DR. BLEY: Okay, that might be an 2 interesting one to sit in on.
3 Thank you.
4 MR. SEYMOUR: Okay.
5 So, Section 53.810 as we go through 6 these sections, is the general license itself.
7 Again, so this is, you know, something that's 8 considerably different.
9 So, the license and its conditions 10 itself, are actually articulated within a section of 11 the Regulation.
12 Now, again when we're talking about a 13 specifically licensed SRO or RO, you know, and 14 that's a process I've been through. I was a 15 licensed SRO.
16 When you complete the process, you get a 17 license back in the mail signed by the regional 18 branch chief.
19 And, it has conditions that are 20 articulated on the license itself, written there 21 that you have to comply with.
22 Here, those conditions are articulated 23 in the Regulations. So, they're there, they have to 24 be met by people that are covered under this general 25 license.
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226 1 They are binding, they are enforceable.
2 It just so happens that they're located in the 3 Regulation itself.
4 So, again key aspects for this are that 5 the facility must meet the safety criteria to be a 6 part of this class.
7 The operator must be employed in a 8 position that involves, you know, potentially 9 conducting control manipulations.
10 The person's qualifications need to be 11 established and maintained.
12 So these are all things that go into 13 this, you know, general license.
14 Again, to be covered by this general 15 license, you know, there's certain things that need 16 to be met.
17 The facility has to be the right type of 18 facility. The person has to be employed in the 19 right type of role. And again, they have to 20 maintain their qualifications.
21 So, when we went back to those items 22 that were covered under 53.805, if you fall out of 23 compliance with those items, you know, or if the 24 facility fails to maintain them in some type of 25 adequate manner, then again, the coverage by 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
227 1 general license goes away.
2 MEMBER HALNON: So --
3 (Simultaneous speaking.)
4 MR. SEYMOUR: Yes.
5 MEMBER HALNON: That's a good question, 6 Jesse. On the 810, and I'm sure some of this 7 language will get fleshed out as you get more public 8 comments.
9 But it's confusing to me when like in 10 delta it says the commission will suspend the 11 general license for violations, and you move on down 12 to say somebody sells drugs onsite.
13 Will one operator violating a commission 14 regulation disqualify all the operators, because you 15 take the general license away?
16 MR. SEYMOUR: So again, I'll provide my, 17 my explanation of this point. And again, as we go 18 through further development and the characterization 19 of that changes, then I will, you know, make sure 20 that we circle back around to this commission.
21 My understanding of the implications of 22 D is this. The general license is by its nature, a 23 general license that applies to a class of 24 individuals.
25 With the way that these regulations 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
228 1 conditions are constructed within it, we, as the 2 NRC, retain the capability to go in and either, you 3 know, suspend or to revoke the ability of any given 4 individual, to be covered under that general license 5 MEMBER HALNON: Okay, so it's like a line 6 item veto, then. That's what I wanted to get to.
7 Do you just strike the name of that person and 8 everybody else continues to comply.
9 That makes sense, it's just the language 10 is difficult to get through when you get to that 11 point.
12 MR. SEYMOUR: Okay.
13 DR. BLEY: I had that same, same question 14 and was wondering if it was individual, or facility.
15 The language seems more specific than I 16 remember in other regulations. This doesn't say the 17 commission may, it says the commission will suspend 18 the general license.
19 Now, I think what you just said to Greg 20 is, will suspend the general license for the person 21 involved. And, there's no hint of how he gets it 22 back.
23 But I had thought it was for the whole 24 facility and was wondering how that happens, and how 25 they get back in good graces.
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229 1 MR. SEYMOUR: A good, a good kind of 2 allegory, you know, to this concept because in a lot 3 of ways, it's different from what we're used to.
4 We're used to thinking of this, you 5 know, person that holds the piece of paper themself.
6 And, you know, if they have a issue that causes us 7 to suspend or revoke, then we, we go take that, you 8 know, piece of paper away from them.
9 You know, an allegory that I've used 10 before for this is if you imagine a pool with people 11 swimming in the pool, that pool would represent the 12 general license.
13 The lifeguard can blow his whistle and 14 tell any given person to get out of the pool. So 15 again, that's, you know, kind of a, you know, a 16 parable if you will, on how this, how this 17 functions.
18 But that's the underlying, that's the 19 underlying mechanism that's here. The license is 20 general in nature.
21 But again, you know, any given person 22 under the, you know, commission's authority, can be, 23 you know, prohibited from, from being covered by 24 that general license.
25 DR. BLEY: Okay.
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230 1 The wording here I think you really got 2 to be careful about, because this does say the 3 general license will be suspended. Which sounds 4 like the one that covers everybody.
5 MEMBER BROWN: Everybody get out of the 6 pool. If the plant shuts down, and nobody goes back 7 into it.
8 MEMBER HALNON: Yes, go ahead and move 9 on, Jesse.
10 MR. SEYMOUR: Okay, got it, and I 11 appreciate that. I did capture a note on that so 12 I'll make sure to circle around for us, the group, 13 to see if we needed to make some adjustments there.
14 Okay, so again, so the license is 15 limited, oh, sorry, general licensed operators must 16 observe facility procedures, and facility license 17 conditions.
18 Again, so that is built into this. The 19 license is limited to the facility or facilities, 20 where that person is employed.
21 The license can be suspended and 22 examples of items that may result in suspension, 23 including things like willful violations, conduct 24 that is a hazard to safe operations, the sale, use, 25 and possession of illegal drugs, would be another NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
231 1 one as well, too.
2 So beyond this, the NRC also reserves 3 the ability to require additional information from 4 an operator, to determine if the license should be 5 revoked or suspended.
6 So again, that ability to, you know, 7 demand that the information be provided to, to show 8 whether that licensing should remain in effect 9 there.
10 The operator is prohibited from 11 consuming alcoholic beverages within the protected 12 areas, or performing any activities that require the 13 license while under the influence.
14 And lastly, the operator must still 15 notify the NRC of a felony conviction.
16 And again, a lot of this is, you know, 17 kind of bread and butter to what we see for the 18 existing licensing.
19 Here, the key difference is just that 20 it's embedded in the Regulation.
21 Okay, if we can move on to the next 22 slide, please.
23 So again, Section 810 covered the 24 general license. Section 815 covers the general 25 licensed reactor operator training, retraining, 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
232 1 proficiency provisions.
2 So again, with Section 805, we saw that 3 the facility licensee has a responsibility to 4 implement and maintain certain programs.
5 Here, we're getting to the detail of 6 what the training, retraining, and proficiency 7 provisions actually look like.
8 MEMBER HALNON: Jesse, is any of this 9 different than the CO program that we have already 10 looked at?
11 MR. SEYMOUR: There's a great deal of 12 similarity with that program. A key difference, if 13 we want to call it a key difference here, is that 14 there is no specific medical requirement for general 15 licensed reactor operators.
16 And, that is a key difference.
17 MEMBER HALNON: Yes, I think if you just 18 work on the key differences, rather than go through 19 stuff that we've already listened to previously, it 20 might expedite this a little bit more.
21 MR. SEYMOUR: Okay.
22 Let's take a look here. So the key 23 thing I want to focus on then, is the difference for 24 the medical requirements.
25 When we came before the committee with a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
233 1 certified operator program, again in a lot of ways, 2 we were, you know, running things on a parallel way 3 to the licensed operator program at that point.
4 And, what we did is we looked at medical 5 requirements. We had a requirement to meet, you 6 know, certain medical fitness standards insofar as, 7 you know, not presenting a hazard to public health 8 and safety.
9 And, you know, generally speaking, it 10 was the same wording used for, you know, plants at 11 present.
12 But the key difference was this. For 13 the certified operators, there was no medical 14 reporting requirement.
15 So, for the certified operators they 16 were required by Regulation, to meet that medical 17 standard. But there was no specific, you know, back 18 and forth of reporting using NRC form 396 like we 19 would have with reactor operators, and senior 20 reactor operators.
21 So what we have here with general 22 licensed reactor operators, is that we've dropped 23 that requirement.
24 And again, we looked at this, we looked 25 at this carefully. In some regards, we had to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
234 1 consider, you know, well first of all, the biggest 2 single factor was looking at the, you know, the 3 safety considerations that were involved here.
4 And, what we did is we took a careful 5 look at, you know, why do we care about medical 6 fitness convention?
7 We care about it because of the risk of 8 incapacitation. That's one very important aspect.
9 There's others.
10 But incapacitation because, you know, 11 the operators have actions they may have to take in 12 response to an emergency. And, there's a nexus to 13 public health and safety there.
14 So again, we want to make sure that the 15 operator isn't, you know, incapacitated and unable 16 to fulfill those responsibilities.
17 And, if you look at the actual medical 18 standards that are imposed, you know, ANSI 3.5 and 19 its various iterations, provides that you'll go 20 through and you'll see things like high blood 21 pressure, and other conditions that we worry about, 22 because of the risk of kind of a prompt 23 incapacitation.
24 And, what we, what we did is we looked 25 at that and we looked at other, you know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
235 1 considerations, and we said here, because of the 2 strict safety criteria that these facilities had to 3 meet to be treated like this in the first place, 4 right, to have these general licensed reactor 5 operators, that we don't have that same degree of 6 concern about those medical implications that we 7 would have for plants that didn't meet those 8 criteria.
9 And, the other thing we did too, is we 10 also took that same reasoning, and we applied it to 11 some other known cases that we have, of instances 12 where people performed some relatively important 13 jobs, and yet we don't impose specific medical 14 requirements for them.
15 And in light of that, and then also the 16 complexities of individual medical conditioning, and 17 what that would look like within a general license 18 framework, which would be challenging.
19 Ultimately, the conclusion that we came 20 to is that, you know, to achieve that reasonable 21 assurance of safety, big picture here that a 22 specific medical requirement was not necessarily 23 needed.
24 And, something to keep in mind, too, is, 25 you know, I pointed to the requirements in Part 26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
236 1 and Part 73 earlier.
2 This, you know, absence of specific 3 medical requirements, right, the need to meet, you 4 know, an ANSI 3.5 medical standard and report to the 5 NRC on whether or not it's met.
6 You know, that's not necessarily the end 7 all, be all of the touch points that we get on 8 someone's fitness.
9 So, case in point, when we talk about 10 behavioral observation for example, right, you know, 11 that's a feature of other regulatory requirements 12 that are outside of what we're talking about here.
13 So again, you know, a person, you know, 14 would still be subject to behavioral observation.
15 They may still be subject to, you know, to drug 16 testing, fitness for duty requirements.
17 They may still be subject to work hour 18 restrictions. Things of this nature, right.
19 So, there's other types of touch points 20 that we have there on whether or not someone is able 21 to, and in a physical way, you know, do their job, 22 that aren't necessarily synonymous with going in and 23 getting a comprehensive work up by a physician and, 24 you know, making some type of report to the NRC.
25 So again, I can answer questions to that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
237 1 effect, but that, that's the key difference that's 2 here.
3 MEMBER HALNON: I think the only thing 4 that struck me was that it was, the general 5 operator, general licensed operator, will undergo a 6 certain amount of stress when you said earlier that 7 they have to respond, like activating the emergency 8 plan, and make communications and other things.
9 And, there's probably some baseline 10 medical requirements that would be required that 11 you'd want to, especially if they're minimum shift, 12 standards. You know, you have a staffing plan that 13 says you have so many operators on, and whatnot.
14 And, so I guess, I guess the impetus to 15 remove it, or just did not have some base level of 16 medical requirements, is interesting and having 17 taking them all off.
18 I understand behavioral observation, but 19 that's typically on midnight shift being observed by 20 somebody who doesn't have any medical requirements, 21 as well.
22 And I understand that work hours, and 23 other Part 26 type issues, but I don't quite 24 understand why you would just remove them all 25 completely from the, from the mix.
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238 1 MR. SEYMOUR: So really, you know, as I 2 was talking about earlier, from our perspective what 3 we had to do is, is look at this and consider 4 whether the safety implications warranted, you know, 5 the imposition of that, of that requirement.
6 MEMBER HALNON: Yes, I get that. But you 7 got monitoring, you know, you have the eyesight.
8 You have other things. You have the smell 9 requirement. Prescription medication monitoring.
10 Quite a bit of stuff that goes into 11 that. I understand the burden on the operating 12 shift is, is 13 pretty high sometimes, especially when you're have 14 to go get medical physician examinations and what 15 not.
16 But I'll have to think about it. I 17 still think that there's a level of stress, even in 18 the GLRO world that might warrant something. I'm 19 not convinced that no, no medical requirement is the 20 place to be.
21 MR. SEYMOUR: It's good feedback and 22 again, we welcome the, you know, the committee's 23 feedback in that area.
24 You know, it's definitely something that 25 we're receptive to, you know, taking another look at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
239 1 that.
2 What I would offer is this, right. If 3 we look at the regulatory requirements that we 4 impose upon fuel cycle facilities, again where there 5 are, you know, well, think of perhaps a fuel 6 enrichment facility if we want to have like a mental 7 model of something.
8 There are operators again, a different 9 regulatory framework and so forth. There are 10 hazards that are there. There are emergency plan 11 considerations, right? There's emergency action 12 levels.
13 If memory serves me, I think that 14 they're limited to alert and site area emergency for 15 those types of facilities.
16 But there's things that, you know, are 17 hazardous and there's things that need to be done 18 for, for safety.
19 Again, so these operators, you know, 20 will have to do important things in response under 21 certain conditions, right.
22 And there's things that they're credited 23 to do under the, you know, the integrated safety 24 analysis, right.
25 So, you know, administrative IROFS 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
240 1 so forth. And yet we don't at the level of 2 regulation, impose a specific medical requirement 3 upon them. Again, if memory serves me.
4 So, you know, it's an example of where 5 we can look at what we're doing on you know, one 6 side of the fence and compare it to the other side, 7 and see that there's a difference.
8 And, it just causes us to re-evaluate 9 and say, you know, if there's a reason why and it 10 doesn't raise to this level over here, then why are 11 we doing it over here?
12 MEMBER HALNON: Okay, well that's good 13 feedback. I didn't realize that there was nothing 14 on that side either.
15 But what about research and test 16 reactors? I mean we still RO and SRO those folks.
17 Do we have medical requirements on those licenses?
18 MR. SEYMOUR: So again, I'm not a 19 research and test reactor examiner, so I've always 20 worked on power reactor side of things.
21 So, I will answer this and again, if we 22 have any folks from, you know, from the NPUF branch 23 on the phone that want to chime in, you know, 24 please, by all means, do.
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241 1 side of things, what we generally see is a 2 commitment to ANSI 15.4, which articulates, you 3 know, the qualification requirements for licensed 4 operators. And, embedded in that standard, is a 5 medical component.
6 So, again, you know, for the power 7 reactor facilities, you know, I think fairly 8 universally, they're committed to ANSI 3.4. Again, 9 a fairly long standard; there's a lot in there.
10 Now the ANSI 15.4 standard is fairly 11 compressed by comparison, right. But again, you 12 know, from a medical standpoint, I should say.
13 There's more than --
14 (Simultaneous speaking.)
15 MEMBER HALNON: Okay, I'll come back and 16 look at that. I'll look at that and if, we'll 17 probably have a discussion about that later on.
18 But that's good feedback. I have no 19 specific concern other than what I stated, so it's 20 not really deep, a deep basis for you.
21 DR. SCHULTZ: Jesse, Steve Schultz.
22 Just thinking of the stakeholders 23 meeting next week, the fourth bullet that you have 24 here, the wording on the bullet seems to suggest 25 that simulators are going to be required.
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242 1 And, you may get some feedback there 2 that's different than the way you explained how 3 simulators would be integrated, and reviewed, as 4 part of the training program.
5 MR. SEYMOUR: I appreciate that feedback.
6 I wrote that bullet, and I didn't do a very good job 7 it.
8 The way that it's worded, you know, the 9 implication is that if simulator facilities are 10 going to be used in certain, you know, roles that 11 are credited for certain regulatory requirements, 12 then again, they're subject to requirements.
13 DR. SCHULTZ: Of course.
14 MR. SEYMOUR: Again, if there's a way 15 around that and you can justify doing something 16 other than those requirements, wouldn't necessary 17 apply.
18 But you're right, just the way that --
19 (Simultaneous speaking.)
20 DR. SCHULTZ: Got it.
21 MR. SEYMOUR: -- I worded that, yes.
22 DR. SCHULTZ: It's the way you would come 23 across in a short order presentation, that may get a 24 lot of questions.
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243 1 you.
2 Okay, so again moving on with these 3 points that are here, again that was the major 4 difference there were the medical requirements.
5 The last section of the new general 6 licensed reactor operator language, is 53.830, which 7 simply covers expiration.
8 And, the expiration requirement for the 9 license is that when someone leaves a position, that 10 would involve the potential operation of the 11 controls of the facility, that they are no longer 12 covered by that general license.
13 So that is the expiration requirement.
14 And, can we move on to the next slide, 15 please?
16 MEMBER HALNON: Is there an expiration 17 for the general license, or, you know, a re-approval 18 of the program? Or is it just done by inspection?
19 MR. SEYMOUR: The programs that enable 20 and support the general license, they would be, you 21 know, undergo initial approval and again, our intent 22 is that there would be an ongoing inspection 23 component, of making sure that they remain in 24 compliance with the Regulation.
25 But in terms of what we think of, 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
244 1 know, for license renewal, and just for those who 2 aren't familiar with this, reactor operator and 3 senior reactor operator licenses expire every six 4 years, for the power reactors.
5 So every six years, you know, they need 6 to go through a fresh application that comes in, and 7 go through a renewal process.
8 There wouldn't be anything of the sort 9 for this, this type of, you know, general licensing 10 process.
11 MEMBER HALNON: Okay.
12 Programs tend to drift quite 13 extensively, so there would have to be some 14 touchpoint in there, I assume?
15 MR. SEYMOUR: And, that's our intent is 16 to have, you know, and again we just haven't gotten 17 to the stage of developing an inspection program for 18 this --
19 (Simultaneous speaking.)
20 MEMBER HALNON: Okay.
21 MR. SEYMOUR: As you go through and you 22 can see the record keeping requirements, you can see 23 where we've kind of left the foundation for, you 24 know, areas that we have an interest in looking at, 25 to make sure that the records are there when we come NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
245 1 to look at that.
2 MEMBER HALNON: Okay.
3 MR. SEYMOUR: So, and it's --
4 MEMBER HALNON: Okay, when you have an 5 operator come in in year three, say, the original 6 program after three years of experience, may be 7 quite different.
8 Because you don't have a re-approval of 9 their program. You don't approve the requal 10 training.
11 MR. SEYMOUR: Well, we would, we would 12 approve the requal training. So the initial 13 training program and the continuing training 14 program, along with the attendant examination 15 programs, would all be subject to initial commission 16 review and approval.
17 So, those would be commission approved 18 programs.
19 Again, in terms of a formal re-approval, 20 no, but we would, you know, intend to inspect it on 21 an ongoing basis.
22 MEMBER HALNON: You approve it at T =
23 zero during the license process, but after three, 24 four years of operating experience, how, other than 25 inspection, I guess I don't understand how somebody, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
246 1 how you assure that the person going through that 2 initial program, is still getting all the necessary 3 requirements.
4 When you come up with your license, your 5 inspection program, I think that will be a key 6 discussion that we should have.
7 MR. SEYMOUR: Yes. There's some 8 complexity to that, and there's a lot of layers 9 that, that go into it.
10 MEMBER HALNON: Right, yes.
11 MR. SEYMOUR: When you talk about, you 12 know, what keeps that process current, part of the 13 nature of SAT-based training, and the reason, one of 14 the things we did with the original white paper is 15 we went all the way back to square one.
16 We said it's SAT, you know, the thing 17 that we want to stick with. And, we looked back at 18 the basis and we said, you know, SAT is still really 19 the gold standard for how to approach training.
20 One of the duties of the SAT process is 21 that it adapts. And by design, it's always looking 22 for, you know, things that are changing. And, 23 adapting the training, and looking for deficiencies 24 and correcting that.
25 So, you know, one of the fundamental NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
247 1 things about that training program maintaining its 2 efficacy over the course of the facility line, is a 3 robust and well-functioning SAT process, to 4 continually be, you know, adapting, right, updating, 5 you know, any changes to what the operators need to 6 know to perform their jobs, right.
7 Maintaining that focus on job task 8 analysis, right. And, then through its evaluation 9 phase, and more specifically, implementation and 10 evaluation phases.
11 That process of examination and also, 12 taking that last step and looking back to where 13 there's performance, you know, any type of 14 performance deficiencies that are emergent.
15 Any types of operational issues, and 16 then plugging that back into the beginning process.
17 So something that we're looking at, and 18 we've talked about this before too, is, you know, 19 the fact that some of these facilities may intend to 20 go through an accreditation process, to address that 21 need to have a SAT-based program. Other facilities 22 may opt not to.
23 And, one of the things that we've been 24 doing, and we're actively working a lot on this, you 25 know, got a lot of resources invested in this right NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
248 1 now, is developing our own updated guidance to be 2 able to look at those SAT-based training programs, 3 and to assess their adequacy directly.
4 And, that falls under two, there's two 5 very specific contexts that that comes up in. One 6 is if a plant isn't going to be accrediting that 7 training program in the first place, we need to make 8 that assessment directly.
9 But also if we have concerns about the 10 efficacy of that program, and again this is very 11 similar to what we currently have in place under 12 inspection procedure 41.500 and under NUREG 1220, 13 granted they're older documents that they're there.
14 But we have the ability, you know, 15 should there be cause, right, should there be 16 issues, that justify it, to go in and to essentially 17 take a, take a direct and, you know, a somewhat 18 very, very deep look at the individual attributes of 19 that SAT-based training program.
20 And, to, you know, so to speak, if it 21 was a vehicle, to pop the hood and look at the 22 engine.
23 So again, that's the other thing that, 24 you know, we want to have the ability to do. And 25 again, we haven't developed the inspection program NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
249 1 yet, but we are working on that guidance. And 2 that's one of the intended uses of that guidance.
3 MEMBER HALNON: Yes, and I think we're 4 going to be touching on a lot of places where 5 guidance is, you know, sort of still in play.
6 And, then that's going to be very 7 important next layer of this, to make it, to make it 8 palatable.
9 MEMBER BROWN: Another question.
10 SAT-based program, is that not mentioned 11 anywhere in this? I don't even know what SAT means, 12 and it's not, I just key worded it.
13 MALE SPEAKER: Systems approachable 14 training.
15 MR. SEYMOUR: Yes, so systems approach --
16 (Simultaneous speaking.)
17 MEMBER BROWN: I'm assuming it's not 18 referenced in the, in the Rule, that's all. You say 19 it's going to be done, derived from SAT, but there's 20 nothing in the, in the Rule language that says it 21 must be derived from SAT.
22 That's all I'm saying.
23 MR. SEYMOUR: Yes.
24 MEMBER BROWN: It's not rocket science.
25 MR. SEYMOUR: Under 53.815 it's mentioned NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
250 1 for the initial examination program, and for the 2 requal training program.
3 So if you go under 53.815 and you just 4 go under, it will be on page 43. You should see 5 some references to it.
6 But what it is, systems approach to 7 training, and in the industry's parlance sometimes 8 you'll hear it referred to as a systematic approach 9 to training.
10 It is a training approach that's much 11 broader than --
12 MEMBER BROWN: I'll take your word for 13 it. I just didn't see, I keyworded SAT.
14 MR. SEYMOUR: Okay.
15 MEMBER BROWN: Not systems what?
16 MR. SEYMOUR: Approach.
17 MEMBER BROWN: Approach training.
18 MR. SEYMOUR: Yes.
19 MEMBER BROWN: I did not do the whole 20 alphabet soup.
21 MR. SEYMOUR: If you go back, if you have 22 it opened up electronically, just scroll back to 23 53.725b, which is the definitions section at the 24 beginning.
25 It will actually show you --
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251 1 (Simultaneous speaking.)
2 MEMBER BROWN: Oh, okay.
3 MR. SEYMOUR: -- it broken down in the -
4 -
5 (Simultaneous speaking) 6 MEMBER BROWN: All right. I lose, thank 7 you.
8 MEMBER BIER: While we're interrupted, a 9 quick question, which is probably something I missed 10 going past earlier.
11 Is the testing and proficiency 12 examination of the GLROs, is that done by the 13 agency, or by the license holder?
14 MR. SEYMOUR: So the testing for GLROs 15 would be administered by the license holder, using a 16 commission approved program.
17 MEMBER BIER: Okay, so is that different 18 than what would be done currently for reactor 19 operators, and SROs?
20 MR. SEYMOUR: Under Part 53, or out there 21 in the existing fleet?
22 MEMBER BIER: Okay.
23 Well, both, I guess.
24 MR. SEYMOUR: Okay.
25 So out there in the existing fleet, 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
252 1 current framework is that, you know, for power 2 reactors and for the research and test reactors, 3 when the time comes for individual licensing and RO 4 or SRO, the NRC examiner goes out, they administer 5 an exam that we approve in advance.
6 In some cases, we'll even write them 7 ourselves. I've had that, that pleasure a couple of 8 times, for writing those.
9 And, what we'll do is they'll administer 10 that, and then based on, you know, the assessment, 11 about that person's performance, we'll issue a 12 license.
13 Under Part 53, what we do with the 14 specifically the licensed ROs and SROs, right, so 15 everybody who's not in this category, is we say, you 16 know, we give more flexibility for the facility to 17 develop their own examination program.
18 But we maintain the touch point of that 19 exam that's actually given, being reviewed and 20 approved by us before it's given.
21 What we do is we open up the opportunity 22 for the facility to physically administer that exam 23 to the applicants themselves, but the way that we 24 have Rule crafted, and our intention is for us to be 25 present in some degree, when that happens.
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253 1 And, that's a difference from the 2 general licensed reactor operator. A general 3 licensed reactor operator, we would take a step back 4 from that piece of it.
5 It would still be an approved program, 6 but we wouldn't be out there actually administering 7 the examination.
8 MEMBER BIER: Okay.
9 I think, you know, I'm less concerned 10 about whether you guys administer the exam, and more 11 about whether there is somebody there observing it 12 being administered.
13 Because in the aviation industry, there 14 were problems once companies were allowed to have 15 their own pilots give check rides to other pilots.
16 They would just sign off that it was given, and 17 there was no check ride.
18 And, so there has to be some way of 19 closing the loop. I don't mind, you know, who 20 writes the exam, or who, you know, if we just make 21 sure that its being done in good faith, so.
22 MR. SEYMOUR: What we're trying to do 23 here, that point you just brought up is something 24 that, you know, if you could be there in the cubicle 25 when we're talking about, you know, what we need to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
254 1 have here, that's something that weighs heavily on 2 us is this, you know, the neighborhood cop has to 3 stick their nose in there once in a while to make 4 sure things are being done right.
5 And, what we, what we do is we try to 6 take a graded approach in some ways. So when you 7 think about the plants that have specifically 8 licensed ROs and SROs, as I mentioned, the intention 9 is that we will be there when that exam is 10 administered.
11 Now, you know, to watch it, to audit it, 12 to inspect that process.
13 When we talk about these general 14 licensed reactor operators, you know, we may elect 15 to be there, but we won't necessarily be there.
16 And, the key difference is this. What 17 is the difference from a safety standpoint, in how 18 we perceive the human role between those two 19 facilities, right?
20 MEMBER BIER: Yes.
21 MR. SEYMOUR: You know, with this 22 specifically licensed reactor operator and senior 23 operator plants, there's a presumption that they 24 have that type of treatment because there's some 25 direct human role in maintaining safety functions.
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255 1 So, for us to just not even look at that 2 would be unacceptable to us, right? We have to go 3 in there and independently provide that, that layer 4 of assurance.
5 For these general licensed reactor 6 operator plants, and again, we're still working 7 through I think some of the fine detail about how 8 often do we want to go out and get those touch 9 points.
10 DR. BLEY: Jesse --
11 (Simultaneous speaking.)
12 MEMBER BIER: Go ahead.
13 DR. BLEY: I start worrying about things 14 that don't work the way we expect. So, supposing 15 there's a violation of some sort under 810 delta, 16 and a license is suspended for an individual.
17 I would assume the existing inspection 18 guidance on say a special inspection team, or 19 augmented inspection team, depending on the 20 severity, an SIT or AIT might be put together to go 21 out and look at what happened, and maybe re-look at 22 the training program, that sort of thing.
23 Have you worked through any of that yet?
24 MR. SEYMOUR: No. And, you know, again, 25 I'll defer to, you know, my counterparts and Dan, if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
256 1 there's been any, any work that's been done towards 2 those types of reactive inspections. And, what that 3 might look like under Part 53.
4 You know, again, I can say that 5 conceptually, you know, from our perspective, we've 6 tried to leave the tools in place.
7 And also as we develop guidance, do it 8 with an eye towards maintaining our capability to go 9 in there in a reactive sense.
10 And, I gave the example of the, you 11 know, SAT-based training program guidance that we're 12 developing.
13 One of the things we want to have is 14 even if the plant has an accredited training program 15 to where we say okay, you're accredited and, you 16 know, we found that that's an acceptable way to, you 17 know, meet this chunk of the regulation here.
18 If there's a significant plant event, 19 and it seems that there is a nexus to operator 20 performance that's there, you know, and if it seems 21 that this was derived from some deficiency in 22 training, then irrespective of that, of that 23 accreditation of the program, we want to have the 24 ability to go in there and look at that directly.
25 Now again, is this being done under NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
257 1 some, you know, fully developed, you know, reactive 2 inspection program? No.
3 What I say is that I, you know, on our 4 end, we anticipate that we will have that type of 5 mechanism that's there.
6 So again, we're trying to cater our, you 7 know, within our own kind of sphere of what we're 8 working on, cater our guidance and requirements such 9 that the records are maintained, such that the 10 guidance is there to implement that.
11 But in terms of what will that reactor 12 inspection program look like, that's a higher level, 13 you know, item that it's partly beyond the scope of, 14 you know, our narrow piece of it.
15 And then also, I think to an extent it's 16 something that we just haven't, you know, begun the, 17 begun the work on.
18 But yes, Bill Reckley, or, you know, 19 Nan, I'm not sure if you wanted to touch upon that.
20 MR. RECKLEY: No, I thought I'd, yes, 21 this is Bill Reckley. I think, Jesse, you answered 22 it correctly.
23 And, Dennis to your point, it would 24 somewhat depend on, on the finding, right. If it 25 was an individual behavior, we could suspend 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
258 1 general license to that individual, and feel 2 comfortable that it was an isolated case.
3 If there's any indication that it's more 4 cross-cutting, safety culture, associated with the 5 facility or, or the facility licensee, then that 6 might trigger where you're mentioning.
7 A broader based inspection of that 8 licensee, their programs, and so forth.
9 So we have that option, and we'd have to 10 decide on a case-by-case basis whether there was a 11 reason to, to question the overall program, the 12 overall behavior of the facility licensee.
13 DR. BLEY: So you don't need anything 14 specific in the Rules to cover that? Just your 15 ability to go in and examine things covers it, so --
16 (Simultaneous speaking.)
17 MR. RECKLEY: Yes.
18 DR. BLEY: -- we don't need anything 19 here.
20 MR. RECKLEY: Yes, we don't need it in 21 the Rule. As Jesse has mentioned a couple times, we 22 might need to look at guidance and, and maybe even 23 internal guidance in terms of our inspection 24 programs and so forth.
25 But no, we --
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259 1 (Simultaneous speaking.)
2 DR. BLEY: There's inspection guidance -
3 -
4 MR. RECKLEY: -- generally have the 5 right to do that anytime we want, so.
6 DR. BLEY: Does inspection guidance fall 7 under the need to have it in place before the Rule 8 is issued?
9 MR. RECKLEY: No.
10 DR. BLEY: Okay.
11 MR. SEYMOUR: Okay, if we can move on to 12 the next slide, please.
13 Okay, I discussed this slide a little 14 bit earlier, and I think, I think this should be 15 helpful for clarifying some of the differences 16 between the reactor operator and, you know, 17 specifically licensed senior reactor operator tracks 18 that are here, and this new generally licensed 19 reactor operator track.
20 And, so the slide provides a visual of 21 how they compare and contrast. And again, if we 22 follow the columns down here, the items in red are 23 really just a highlight where there's, you know, a 24 significant difference that exists between the two.
25 And, also at the same time it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
260 1 important to note where things are the same, right?
2 So again, you know, I would ask you to just to be 3 mindful of the things that are, you know, say yes, 4 and the things that say no, just kind of globally in 5 that, in that last column that's there.
6 In both cases, the operators who have 7 responsibility for administrative requirements and 8 control manipulations, will be licensed, right.
9 Again, a very important point.
10 And, I'll go even further and even 11 though it's not specifically mentioned here, when it 12 comes time for core alterations, provided that's a 13 plant that's not actually refueling online, you 14 know, the person that oversees those core 15 alterations, would have to be licensed as well, too.
16 So again, that's an item even beyond that.
17 However, due to the safety criteria that 18 must be met by the class definition, for facilities 19 that use generally licensed reactor operators, those 20 operators would not have a role in the mitigation of 21 events at that type of facility.
22 So again, as we look at that second row, 23 you know, this is where we start to see that 24 difference, right.
25 And, we'll see how that --
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261 1 (Simultaneous speaking.)
2 DR. BLEY: That's what I wanted to ask 3 you about.
4 MR. SEYMOUR: Yes.
5 DR. BLEY: That's the only one of these 6 when I look at it, that's in my opinion, based on 7 our assumptions that all our analysis is right.
8 There shouldn't be any need for 9 mitigation if they've met all their criteria, to be 10 in the spot where we can use a general licensed 11 operator.
12 But what if we were wrong and something 13 happens, and you actually do need to look at 14 mitigation?
15 MR. SEYMOUR: So what we're striving for 16 here, you know, I think in a lot of ways this gets 17 back to the underlying regulatory philosophy that it 18 is the nature of what we do.
19 And, you know, at the risk of kind of 20 getting in, you know, sounding philosophical, you 21 know, we can't regulate our way to zero risk.
22 We can shoot for a reasonable assurance.
23 We provide layers of analysis, and hurdles that have 24 to be met to get to this type of treatment.
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262 1 know, we have this reasonable assurance that, you 2 know, this type of operator shouldn't be in that 3 situation.
4 At the end of the day, this is still an 5 individual who is licensed by the Nuclear Regulatory 6 Commission, and has a certain required level of 7 training and examination, and competence associated 8 with them.
9 And, if you'll notice like in our 10 requirements we talked about earlier, we still 11 mandate for example, we have the ability to shut the 12 reactor down different from what the emergency plan 13 as required, to make notifications and so forth.
14 So, our thought process here is that 15 even if we go through and we say reasonably, you 16 know, we shouldn't ever have this operator needing 17 to take actions to mitigate events, we still, we 18 still backstop things, right?
19 We still leave a licensed individual 20 that's there with certain, you know, mandatory 21 capabilities.
22 And again, part of that is with an eye 23 towards what if you're wrong, right? What if there 24 is some, some item that's out there that wasn't 25 swept up by this.
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263 1 DR. BLEY: I'm glad you answered it the 2 way you did. You know, I could envision an answer 3 that says oh, the NRC will come in and take over 4 under this situation and that's just wrong. You 5 know? We don't want to do that.
6 MEMBER KIRCHNER: But Dennis, this is 7 Walt. Dennis, I was going to ask the same, the same 8 question in a different way.
9 I'm going back to the criteria. So and 10 as I asserted earlier, you know, a good design 11 team's going to try and make this new advance 12 passive reactor shut itself down, take care of 13 itself, and so on.
14 But in the event one of those systems 15 fails, does the operator and the GLRO intervene, or 16 not?
17 We had a different take on that question 18 of an operator doing something that might be a 19 mistake, or when we talked about defense in depth.
20 But should the system not perform as it 21 should, then does the operator defeat the system and 22 take over?
23 It's a rhetorical question, but I think 24 --
25 (Simultaneous speaking.)
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264 1 MEMBER KIRCHNER: Yes.
2 MEMBER HALNON: You're getting into the -
3 -
4 (Simultaneous speaking.)
5 MEMBER KIRCHNER: Sounds like an 6 important one.
7 MEMBER HALNON: -- into the defense in 8 depth is where we're headed, I think on that 9 question.
10 When the primary layer of defense fails, 11 or doesn't do its job, then you have multiple layers 12 below that.
13 And at what point do, or can operators 14 be on one of those defense in depth layers?
15 And I think we talked about that earlier 16 but I'm still not sure that we understand how --
17 (Simultaneous speaking.)
18 MEMBER KIRCHNER: Yes, and what I was 19 thinking of, Greg, was it may not be just reactivity 20 controlled. I mean that's what the regulations here 21 seem to be focused on.
22 But there are other things. And some of 23 these systems will have for example, tanks that are 24 storing fission products, or whatever. I mean I 25 don't want to speculate what they're doing.
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265 1 But it could be that you have a reactor 2 systems that's fairly safe, but you have auxiliary 3 systems that maybe aren't quite up to that level.
4 And, operator intervention may be very 5 important in event mitigation.
6 It's just something to think about, 7 Jesse. If you just limit it to reactivity 8 manipulations, there may be a lot of other things --
9 (Simultaneous speaking.)
10 MEMBER HALNON: Well, the criteria is 11 either safety criteria, safety functions, and 12 defense in depth for event mitigations.
13 So, I think it covers beyond reactivity 14 in itself. It's cooling, it's --
15 (Simultaneous speaking.)
16 MEMBER KIRCHNER: Beyond that, yes.
17 MEMBER HALNON: Yes.
18 MR. SEYMOUR: I want to I think clear the 19 air on a point here. There's a difference between 20 us, you know, saying in regulation that someone is 21 specifically authorized to do something, and us 22 precluding them from doing anything else, right.
23 In the regulation because of the legal 24 considerations, we have to go in there and say 25 specifically, that a given licensed person can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
266 1 operate the controls of the facility.
2 And again, we can trace that all the way 3 back to the Atomic Energy Act.
4 So that's why we call out the specific 5 authority of this, that individual to be able to 6 operate controls.
7 There's nothing that precludes them from 8 operating everything else. It's just we have to 9 give them the specific authority that's there.
10 And the other thing is, there's a 11 difference between what we credit this person to be 12 able to do, for the sake of figuring out if we're 13 going to let a plant use this type of operator 14 versus, you know, what they may do, right.
15 There's nothing that precludes this 16 person from operating, you know, any given, any 17 given system that's there. That's fine.
18 Again, you know, to get this treatment 19 of only having the general licensed reactor 20 operators from an analytical standpoint, we would 21 require this analysis that takes you through how 22 safety functions are met.
23 How defense in depth is achieved, and so 24 forth, to show that yes, reasonably, this person 25 should not have to mitigate events.
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267 1 But again, you know, if you want to get 2 into, you know, extreme situations and things like 3 that where things that weren't supposed to happen 4 ultimately did happen, there would be nothing wrong 5 with this individual operating, you know, systems 6 beyond just, you know, the facility controls, and so 7 forth.
8 So again, you know, just because we 9 specifically call out, you know, the ability of this 10 person and authorize them to operate facility 11 controls, in no way restricts their ability to 12 operate everything else.
13 MEMBER HALNON: Jesse, I don't think 14 there's any argument there. I think the concern is 15 the threshold between being a general licensed 16 class, and a class of operators, or reactors that 17 need SROs and ROs.
18 It's not necessarily a capability 19 issue, it's a licensing issue.
20 So, you know, it goes back to our 21 earlier discussion about if the operator is capable 22 of doing something that could actually disable that 23 credited automatic safety function, then that's 24 something that we need to understand, relative to 25 the class of operators that you're dealing with.
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268 1 DR. SCHULTZ: You don't want the 2 operator, this is Steve. You don't want the 3 operator to be confused either.
4 The earlier slide, and the indication in 5 the document says it could evaluate emergency 6 conditions, implement the emergency plan, and this 7 bullet happens to say you can't mitigate the 8 accident.
9 I don't want anybody to be confused that 10 they --
11 (Simultaneous speaking.)
12 MEMBER KIRCHNER: Yes, Steve, that was my 13 reaction to the visual.
14 DR. SCHULTZ: Yes.
15 MEMBER KIRCHNER: Not so much the 16 language.
17 DR. SCHULTZ: Exactly.
18 MR. SEYMOUR: Again, I think -- oh, 19 sorry.
20 DR. SCHULTZ: Go ahead.
21 MR. SEYMOUR: This gets back to the 22 approach that's taken here. So again, getting back 23 to the, you know, the analytic end of things.
24 You know, the objective here is you go 25 through and you say, and I know the word credible 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
269 1 kind of a loaded, loaded word.
2 But, you know, you look through and you 3 say credibly, this person shouldn't be in a 4 situation where they have to mitigate anything, 5 right.
6 And, that's the reasonable conclusion 7 that you come to, looking at the design of the 8 facility and so forth.
9 But then there's what do we do to be 10 conservative and still backstop that, in some type 11 of reasonable way.
12 And, so what we do is we layer on that 13 and we say even though it shouldn't end up that way, 14 we still want the person to have these indications 15 that they can look at, that will let them assess 16 things like safety function, performance, core 17 damage states, and so forth.
18 The ability to implement the emergency 19 plan, the ability to shut the reactor down and make 20 notifications, right.
21 If all of this analysis is correct, if 22 you met all these conditions to get, you know, to 23 have this type of operator, you know, theoretically 24 you should never be there, right.
25 We added all this on to (audio NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
270 1 interference) mandated and layered in here.
2 Again --
3 (Simultaneous speaking.)
4 MEMBER KIRCHNER: Yes, but theoretically 5 is good, but in actuality, stuff happens.
6 MR. SEYMOUR: Yes, which is why we put --
7 MEMBER KIRCHNER: And so I, what bothered 8 me, Jesse, was just kind of the implication that 9 it's hands off, walk away safe, and all I have to 10 do, well, if it actually isn't walk away safe, then 11 I actuate the emergency planning.
12 It's, that's a mis-impression on my 13 part, I'm sure, and not your intention. But it 14 just, just, that's why I reacted to this no in red.
15 (Simultaneous speaking.)
16 Maybe not so, maybe just have no in 17 black I wouldn't have noticed because my eyesight's 18 so bad.
19 CHAIRMAN PETTI: So if it just said 20 credited role as opposed to yes, they can still have 21 a role, it's just that it wasn't credited in, in the 22 analytical part of the, you know, the process.
23 MR. SEYMOUR: That's a great observation, 24 and that captures, that captures what the intent 25 there was.
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271 1 CHAIRMAN PETTI: Right.
2 MEMBER HALNON: Until you get to the 3 defense in depth portion. I mean that, you're going 4 to have to put a boundaries around the defense in 5 depth.
6 Because when you're trying to determine 7 class of operators, and you say that the operator 8 has no role in defense in depth, that's going to be 9 a, a bar that I don't think anybody can get on 10 except for that reactor on the moon that we're 11 talking about.
12 MR. RECKLEY: Yes, Jesse, this is Bill 13 Reckley.
14 I think maybe what Dave suggested, could 15 even be used there in terms of we're requiring an 16 assessment of defense in depth, and so they will 17 know what they have quote, credited.
18 Does that mean there's not a, an 19 additional possible role, an additional level of 20 defense in depth that might be provided by the 21 operators? Certainly not. We would encourage that.
22 But as far as they've analyzed it and 23 assessed defense in depth, they've been able to 24 successfully do it to a minimum without crediting 25 the operator.
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272 1 And, then any role that the operator, 2 the engineering expertise Jesse mentioned earlier, 3 all of that can contribute to even providing an 4 additional layer.
5 MEMBER HALNON: As long as it doesn't 6 hinder a previous layer.
7 MR. RECKLEY: Right.
8 MR. SEYMOUR: Well, that's dead on. You 9 know, I wish I had characterized, you know, things 10 in my slides.
11 I know with presentations, you always 12 get the most thorough proofread of stuff imaginable 13 when you actually put it up on the board. So, but 14 yes, definitely.
15 And more so even just, you know, the 16 presentation of this. I'm going to take that and 17 take a look back at the Rule language as we work 18 through making further refinements here in July, and 19 look at how we can adjust that.
20 Because again, that's a key point, and I 21 think we can capture it better with the language.
22 CHAIRMAN PETTI: The other question I had 23 was, this just made me think you know, if it's truly 24 a first of a kind technology, and that of course, 25 has some wiggle room because these systems, these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
273 1 advanced systems, they have cousins and brothers, 2 and sisters.
3 None of them have ever been identical to 4 one another. Because there just haven't been enough 5 of them built.
6 Would we be so bold to say that you 7 can't come in as an RO for the very first one?
8 MR. SEYMOUR: That's a very good 9 discussion point. I can say that what we've done at 10 this stage, is we imposed the engineering expertise 11 requirement on all facilities, even these.
12 So that pilot build would now have this 13 engineering expertise role that we have to satisfy.
14 So again, in terms of how you address 15 these uncertainties, unknown unknowns. So, you 16 know, at a minimum, it wouldn't just be your general 17 licensed reactor operator in isolation.
18 They would have this engineering 19 expertise support that would have to be accounted 20 for.
21 CHAIRMAN PETTI: And again, this, this 22 just really falls on the owner/operator. A designer 23 can come in and do all the analysis and use it as a 24 marketing, if you will.
25 Yes, we can have this but in the end, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
274 1 the ultimate decision is the owner/operator, and 2 that's kind of a different, they'd look at things a 3 little bit differently, I think, right?
4 Yes, okay.
5 MR. SEYMOUR: Within our staffing 6 guidance, you know, one thing that we've taken into 7 consideration, on the very last slide we'll circle 8 around about how we've, and how we either have or 9 how we're continually working to address the 10 committee's past concerns that were articulated in 11 the letter.
12 And, one of the things is within the 13 course of our staffing plan review guidance, you 14 know, working in a consideration about first of a 15 kind, and pilot builds facility.
16 And, you know, potential considerations 17 there. Now that's something we're looking to 18 address via guidance, and that is a work in 19 progress.
20 But again and I'll touch upon that in 21 the end, it's something, it's a problem. We haven't 22 lost sight of that and we really appreciate the 23 committee's feedback on that. You know, it's 24 something we're still working on.
25 Okay, so again just moving through the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
275 1 balance of the chart here.
2 So in both cases, the NRC, so again in 3 both cases I mean both specifically licensed SROs 4 and ROs and general licensed GLROs that are there, 5 the NRC has the legal authority to suspend or revoke 6 the license for violations.
7 And, additionally, require NRC approval 8 of the training and examination programs, as 9 required. So again, you know, those are things that 10 are consistent across there.
11 Because of the structure of the general 12 operator license, the NRC does not provide approval 13 for a specific exam prior to administration.
14 And again, this gets into the program 15 itself is approved, but we're not approving the 16 individual exams necessarily, as they happen.
17 Nor would there be, you know, the 18 aforementioned medical status update requirement 19 there.
20 And, we also talked about the 21 implications for a simulator facilities, and the 22 differences in initial approval that are there. So 23 there are some differences.
24 But again, a key point to take away is 25 that the training programs and exam programs for all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
276 1 licensed operators, would be initially reviewed and 2 approved by the NRC.
3 There are regulations that apply to 4 ensure that simulators have sufficient scope and 5 fidelity, but there's no requirement in the case of 6 the general licensed reactor operators, that those 7 simulators be approved in advance.
8 So again, I think that rounds out those 9 points that we had discussed earlier with regards to 10 the medical, and simulator differences that are 11 there.
12 The general license does not have a 13 renewal period, as we discussed. And, it expires 14 when the operator no longer holds a position that 15 would manipulate the controls.
16 So again, the NRC does not approve those 17 items.
18 So again as well look at that second to 19 last row that's there, what we start to see, and 20 where this really starts to build in is this, right.
21 When the designer goes through this 22 process of, you know, doing that, you know, very 23 involved design work analysis and so forth, to build 24 a plant that qualifies for this general licensed 25 reactor operators, where, where's the return on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
277 1 that? Where do you start seeing this?
2 Well, you see it in reduced staffing 3 requirements, right. You know, you see it in a 4 simplified requirements, right.
5 And, you see it in less regulatory 6 interface, especially when you start looking at that 7 second to last row that's there, right.
8 So you see that there's certain things 9 that don't go away. Like the initial review and 10 approval of certain programs.
11 But then you can go through an entire 12 litany of things that either no longer need 13 approval, or don't require continual back and forth 14 with the NRC, to go through those processes.
15 And, then as a last point, something 16 that we do, and I touched upon this earlier, is when 17 you talk about your continuing training and 18 requalificaiton training of these operators, what we 19 do is we provide more latitude for the general 20 licensed reactor operator plants, to go though and 21 identify. And, they'll have to justify why they're 22 using the periodicity that they are.
23 And, I know from, you know, some of the 24 conferences I've attended lately, there is, there is 25 work that I'm aware of out there in the industry, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
278 1 to, you know, apply methodologies to determine what 2 training and retraining periodicities need to be.
3 So, you know, there is work that's 4 floating around out there to support that type of 5 thing.
6 But again, they'll have to provide a 7 sound justification for it, if they want it to be 8 two years, if they want it to be three years.
9 Whatever that periodicity may be. But again, more 10 flexibility.
11 We can move on to the next slide, 12 please.
13 Okay, so on this slide what I want to do 14 is step through the individual concerns that were 15 articulated in the committee's letter.
16 And, now that we've talked through what 17 we have in Framework B, and what we have in 18 Framework A, and these various changes, just to roll 19 up, you know, how we feel that, you know, we're 20 addressing those concerns.
21 And, for the first item, after further 22 discussion and consideration of the concerns that 23 were raised by the committee, we decided to add a 24 requirement that engineering expertise be available 25 to support the facility operators at all times.
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279 1 This ensures that such expertise is 2 available when needed, but provides flexibility to 3 the facility in how to meet this.
4 And again, as I discussed earlier, this 5 flexibility, it could be a standalone position. It 6 could be a traditional STA. It could potentially be 7 a combined role. It could be provided remotely.
8 There's different ways to potentially 9 meet it.
10 For item two, so the second item on the 11 list, I have discussed the generally licensed 12 reactor operator framework.
13 So again, we received feedback from the 14 committee about concerns with the certified 15 operator, that non-licensed role.
16 We've completely overhauled that and 17 replaced it with a new licensed role.
18 In creation of the general licensed, 19 generally licensed reactor operator framework was 20 the result of taking both stakeholder input, you 21 know, input from this body and our own internal 22 discussions.
23 We're trying to balance concerns related 24 to operator responsibility and accountability, 25 against still being flexible and providing a reduced NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
280 1 burden on facilities where operators have lower 2 safety impact. Especially as it pertains to event 3 mitigation.
4 For the third item, there was a 5 discussion in the letter about the use of partial 6 scope simulators.
7 And, what I want to point out is that we 8 intend to address the use of partial scope 9 simulators via guidance.
10 And, we do have some ongoing work that 11 is helping us in that regard. Both with regards to, 12 you know, different uses for simulators, and also up 13 to and including circumstances where there's no 14 simulator at all. And what context that that might 15 be appropriate.
16 And one piece of our ongoing work that I 17 would point out, is that as part of our ongoing 18 human factors engineering work that we're doing to 19 develop scalable human factors engineering program 20 guidance, we have a contract with the Brookhaven 21 National Lab.
22 And, in the course of our ongoing work 23 with that, one of the recent products that we 24 received, and that we're actively working with, is, 25 you know, essentially a technical report 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
281 1 identifies considerations should, you know, an 2 alternative to using a simulator be desired.
3 And, you know, where the boundaries are, 4 and what types of alternative analyses could be 5 used.
6 So again, you know, keeping in mind that 7 research and test reactors, you know, don't, don't 8 use simulators by and large, to go through and 9 effect their programs.
10 Again, what we're trying to do is take a 11 good hard look, and know for all those possible 12 outcomes, no simulator, partial scope simulator, 13 full scope plant reference simulator, how to best, 14 how best to address that via guidance.
15 And that is an ongoing area of 16 development.
17 For the fourth item, the training 18 program review guidance that we discussed with the 19 committee is again, continues to be developed.
20 The specific feedback I believe that we 21 received, was that there were concerns with the age 22 of, for lack of a better way to put it, that, you 23 know, the age of our existing guidance, specifically 24 inspection procedure 41.500, and also NUREG 1220.
25 And, you know, the identified need to go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
282 1 through and update that, particularly since we could 2 be getting into circumstances where training 3 programs aren't accredited, and we have to do more 4 of a deep dive on those programs and a directed 5 look.
6 And we are actively working through 7 that. And, so that guidance is under development 8 and we're aiming to get a draft paper out for 9 comment later this year, that will address training 10 program reviews for advanced reactors.
11 Both under Part 53 and also as well, to 12 support advanced reactors coming in under Parts 50 13 and 52.
14 And then for the fifth item, and again I 15 touched upon this earlier. We intend to address the 16 first of a kind pilot builds and new designs, and 17 specifically, their staffing considerations, as part 18 of our flexibility staffing plan review guidance.
19 And, similarly, we intend to address 20 within the scope of that guidance, consideration of 21 the senior license holder role for facilities.
22 And, you know, that's a role Member 23 Halnon, I believe you had, you know, kind of led the 24 discussion on that when we spoke in one of the 25 earlier meetings.
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283 1 But again, you know, it's something that 2 we see in the existing fleets that are out there.
3 We see it enshrined in textbooks that, you know, you 4 identify this senior licensed holder, and typically 5 an operations manager or assistant operations 6 manager. They're required to hold a senior reactor 7 operators license.
8 But positionally, they hold a, you know, 9 special place in the organization hierarchy within 10 that senior license holder role.
11 So again, both that and also, you know, 12 staffing considerations for the pilot build of the 13 facility. Those are areas that we're currently, you 14 know, working on how to best address via the 15 staffing program review guidance.
16 MEMBER HALNON: Thanks, Jesse.
17 I think that even with the GLRO, that 18 might even be more important as we go forward.
19 But the only thing that I think that I 20 wanted to touch on before we take up final comments, 21 is that one of the issues that we had not talked 22 about but we had in our letter, was the potential 23 commercial conflict of interest.
24 One of the items that we said is the 25 senior reactor license, or licensed operators 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
284 1 beholden more to the independent review of the NRC, 2 or independent oversight of the NRC versus their 3 management when it comes to safety decisions.
4 And we sort of partially addressed that 5 with the general license. It may be more in optics 6 and how you present somebody's name on a list, if 7 you, somebody passes a test and says okay, I'll go 8 put your name on the list and that's all there is to 9 it.
10 That may be a little bit less than the 11 regional administrator at least making a phone call 12 saying okay, we understand you're now a general 13 licensed operator, congratulations.
14 So, you know, again, in the guidance, in 15 the practices, it may be addressed. I don' think 16 you necessarily have to address it by individual 17 license like we had sort of alluded to in our first 18 letter.
19 But something to think about as you go 20 forward. That's one thing that we had not talked 21 about today.
22 MR. SEYMOUR: I appreciate that. That's 23 something that's come up to, you know, in the course 24 of our discussions.
25 You know, the mechanism is, 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
285 1 different. I know, I know when I licensed and this 2 was status quo again. The plant had a banquet, you 3 know, and the regional administrator came up, and, 4 you know, stood up there and handed everybody not 5 just the actual license itself was kind of a 6 nondescript piece of paper that just has license 7 typed at the top.
8 But they hand you this fancy 9 certificate, all matted and framed. Signed, you 10 know, right up to the chairman of the commission, 11 right.
12 And, I know they even made the point 13 saying that it was the only document I think, that's 14 signed by the head of NRR, the EDO, and the 15 chairman.
16 So, you know, a big deal. So, you know, 17 there's a lot of pomp and circumstance with getting 18 that license.
19 And, you know, do you still impart the 20 same type of, you know, respect for the role when 21 you're just going through this mechanism.
22 It's a good point. Definitely, I'll 23 take that back to the group and we'll definitely 24 take that under advisement as we work through this.
25 MR. HALNON: Yes, like I said, it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
286 1 optics and, and a charge maybe, but not necessarily 2 Rule language issues.
3 MR. SEYMOUR: Okay.
4 Could we move on to the next slide, 5 please?
6 And, this should be the final slide just 7 to, you know, open the floor for any, any discussion 8 questions.
9 MEMBER HALNON: Well, we've gone through 10 quite a bit. Our discipline showed that we will 11 jump in whenever we have a question, which I think 12 is, is fine. We got through it.
13 I would ask the members if as you think 14 through your notes and whatnot, and if you have 15 other concerns or some things that weren't quite 16 where you need them to be, email me, and I'm going 17 to put together a paragraph, provide it to Dave for 18 consideration in our next full committee meeting.
19 But if we need to have a discussion 20 further of any of the topics, then we need to let 21 Dave know so that we can make sure it gets in the 22 full committee meeting.
23 So Dave, with that I'll hand everything 24 back to you, and let you wrap things up and get 25 whatever other comments you might need to get.
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287 1 CHAIRMAN PETTI: Okay, so at this point, 2 then I guess it's fair to say that, that we do need 3 to have a Subpart F discussion at the full 4 committee, if we're going to say something besides 5 just a summary of what we heard.
6 MEMBER BROWN: I had a loose end until 7 towards the end. It's that I thought a qualified 8 operator type should be available kind of whenever 9 the plant's operating, even if it's not within the 10 plant.
11 And, then the 53.73 talks about having 12 that engineering expertise. So I went back and re-13 read that and that, I think, kind of, it says for 14 all plant operations, okay.
15 And, I think it even says for all time.
16 I've got to go back and read that part. But that 17 resolved --
18 (Simultaneous speaking.)
19 CHAIRMAN PETTI: Right. So I think there 20 were a lot of things here that just resolved things 21 in our minds.
22 Because Greg, is there anything that, 23 that rises to a level that you want a finding in the 24 letter?
25 MEMBER HALNON: No, I was going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
288 1 mention that.
2 I don't see anything that I would say 3 rises to that. I think because much of the issues 4 that we're talking about are lower level that will 5 be in the guidance, and there's probably you know, 6 five or six topics in the guidance that we'll want 7 to look at in the future.
8 But from the standpoint of our previous 9 concerns in the letter, I think that everything's 10 been addressed to some extent --
11 (Simultaneous speaking.)
12 CHAIRMAN PETTI: Right.
13 MEMBER HALNON: -- to the point where we 14 really don't have any, any major issue.
15 I think it's just now seeing where the 16 details come out, and where they end up with their 17 language.
18 It's too much in flux right now to say 19 that this is a finding.
20 But as to your point, Dave, until we get 21 to the guidance portion of it, I don't see any extra 22 time needed in any kind of meetings.
23 CHAIRMAN PETTI: That's fine because I'm, 24 they're going to have a lot to talk about in full 25 committee.
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289 1 So taking this --
2 (Simultaneous speaking.)
3 MEMBER HALNON: Right.
4 CHAIRMAN PETTI: -- off the table, I 5 think, would be helpful.
6 MEMBER HALNON: No, I --
7 (Simultaneous speaking.)
8 MEMBER BROWN: The rule, the rule kind of 9 covers the stuff you have to have.
10 CHAIRMAN PETTI: Yes, yes.
11 MEMBER BROWN: Whether it's, so the 12 guidance is may or may not be. You know, that's a 13 discussion between applicants and staff, and us, 14 eventually.
15 CHAIRMAN PETTI: Right, down the road.
16 MEMBER BROWN: And it, they don't, may 17 not have to comply with that because it's just 18 guidance depending on how the staff wants the rule.
19 So anyway, if that helps, shut up.
20 CHAIRMAN PETTI: Okay.
21 Any other comments?
22 (No audible response.)
23 CHAIRMAN PETTI: Yes, I guess public 24 comment.
25 Anyone from the public have a comment?
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290 1 Unmute, identify yourself and your comment.
2 (No audible response.)
3 CHAIRMAN PETTI: Okay, not hearing any, 4 then at this point I want to, I want to thank Jesse 5 and the rest of the staff. It's been a good two 6 days, as I said earlier.
7 And, we'll see everybody in another week 8 for the live full committee.
9 I adjourn the meeting. Thank you.
10 (Whereupon, the above-entitled matter 11 went off the record at 3:44 p.m.)
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A d v i s o r y C om m i tte e on Re ac to r Safe guards (ACRS ) Re gulator y Rulemaking , Policies and Practices:
Part 53 Subcommittee 10 CFR Part 53 Licensing and Regula on of A dvanced Nuclear Reactors June 23-24, 2022
Part 53, Framework B, Subpart R:
Alternative Evaluation fo r Risk Insights (AERI)
ACRS Subcommittee Meeting 6/24/22
Agenda
- Evolution of Graded PRA Tasking - Katie Wagner
- Proposed AERI Entry Condition - Marty Stutzke
- Technology-Inclusive Identification of Licensing Events for Commercial Nuclear Plants - Mihaela Biro
- AERI Framework - Alissa Neuhausen
- Next Steps - Katie Wagner 39
Introductions
- Marty Stutzke - Technical Lead of the Graded PRA Working Group, Senior Technical Advisor for Probabilistic Risk Assessment, Division of Advanced Reactors and Non-power Production and Utilization Facilities (DANU), Office of Nuclear Reactor Regulation (NRR)
- Mihaela Biro - Principal Author of Pre-decisional Draft Regulatory Guide DG-1413, Technology-Inclusive Identification of Licensing Events for Commercial Nuclear Plants, Senior Reliability and Risk Analyst, Division of Risk Assessment (DRA), NRR
- Alissa Neuhausen - Principal Author of Pre-decisional Draft Regulatory Guide DG-1414, Alternative Evaluation for Risk Insights (AERI) Framework, Reliability and Risk Analyst, DRA, NRR
- Katie Wagner - Project Manager of the Graded PRA Working Group, Project Manager, DANU, NRR 40
The Graded PRA Working Group Membership Project Manager
- Alissa Neuhausen, NRR/DRA - Principal Author of PDG-1414
- Katie Wagner, NRR/DANU
- Hanh Phan, NRR/DANU
- Sunil Weerakkody, NRR/DRA Technical Lead
- Marty Stutzke, NRR/DANU
- Robert Budnitz, consultant Working Group Members Management/Coordination
- Hosung Ahn, on rotation from NRR/Division of Engineering and External Hazard
- Candace de Messieres, NRR/DANU
- Mihaela Biro, NRR/DRA - Principal Author of
- Steve Lynch, NRR/DANU PDG-1413
- Nathan Sanfilippo*
- Anne-Marie Grady, NRR/DRA
- John Segala, NRR/DANU
- Matt Humberstone, Office of Nuclear Regulatory Research (RES)/DRA
- Ian Jung, NRR/DANU *Former NRC employee 41
Alternative Evaluation for Risk Insights (AERI)
- Evolved from the staffs graded PRA initiative starting in Spring 2021 o Began with intent to grade the technical content of the PRA o Moved to grading the uses of the PRA in the design and licensing process PRA in an enhanced/leading role PRA in a supporting/confirmatory/traditional role
- Various names have been used to describe the concept:
o Dose/consequence-based approach o Technology-inclusive, risk-informed maximum accident (TIRIMA) approach o Part 53-BE (bounding event) o AERI 42
Uses of Probabilistic Risk Assessment
- The Policy Statement on the Regulation of Advanced Reactors (73 FR 60612; October 14, 2008) references three PRA-related policy statements:
- Safety Goals for the Operation of Nuclear Power Plants (51 FR 28044; August 4, 1986, as corrected and republished at 51 FR 30028; August 21, 1986)
Meet the QHOs
- Severe Reactor Accidents Regarding Future Designs and Existing Plants (50 FR 32138; August 8, 1985)
Search for severe accident vulnerabilities
- Use of Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities (60 FR 42622; August 16, 1995)
Identify risk insights
- The AERI approach and two pre-decisional draft regulatory guides (PDGs) have been developed to:
- Clarify for potential applicants the logic and the expectations of the NRC staff
- Provide sufficient risk information to inform licensing decisions
- Address related ACRS recommendations 43
ACRS Recommendations
- October 7, 2019 - Letter concerning review of draft SECY paper, "Population - Related Siting Considerations for Advanced Reactors," ML19277H071:
- Need to examine new designs with a clean sheet of paper.
- Think carefully about the failures and combinations of failures that could occur.
- Must remain vigilant and remember that nature provides surprises.
- Creative thinking will be required to identify such unique situations, to thoroughly identify the scenarios that will be the basis of the safety analysis and the source of releases, and to evaluate the suitability of sites.
- October 20, 2020 - Letter concerning 10 CFR Part 53, ML20091L698:
- Compensate for novel designs with uncertainties due to incompleteness in the knowledge base by performing systematic searches for hazards, initiating events, and accident scenarios with no preconceptions that could limit the creative process.
- May 5, 2021 - Letter concerning Part 53, ML21140A354:
- Compensate for novel designs with uncertainties due to incompleteness in the knowledge base by performing systematic searches for hazards, initiating events, and accident scenarios with no preconceptions that could limit the creative process.
- October 26, 2021 - Letter concerning Regulatory Guide (RG) 1.247, ML21288A018:
- Include guidance that the initial search for initiating events and scenarios should be done without preconceptions or using existing lists. 44
The Original Approach to Identifying Licensing Events To avoid the very real and very great danger of an accidental release of radioactivity from a reactor, our committee established a simple procedure: We asked the planner of each reactor to imagine the worst possible accident and to design safety apparatus guaranteeing that it could not happen. The committee reviewed each reactor plan, trying to imagine an accident even greater than that conceived by the planner. If we could think of a plausible mishap worse than any discussed by the planner, his analysis of the potential dangers was considered inadequate.
Edward Teller*
First chair of the Atomic Energy Commission (AEC)
Reactor Safeguards Committee (1947-1949)
- Teller, Edward with Allen Brown, The Legacy of Hiroshima, Double Day & Company, Garden City, NY, 1964.
45
Recognized Problems with the Original Approach to Identifying Licensing Events It is inherently impossible to give an objective definition or specification for "credible accidents" and thus the attempt to identify these for a given reactor entails some sense of futility and frustration, and, further, it is never entirely assured that all potential accidents have been examinedIt should be noted parenthetically, however, that this systematic search for credible accidents often contributes substantially to the safety of a facilityIn the plants finally approved for operation, there are no really credible potential accidents against which safeguards have not been provided to such extent that the calculated consequences to the public would be unacceptable.
Clifford K. Beck, AEC, 1959*
- Beck, Clifford K., TID-7579, Safety Factors to be Considered in Reactor Siting, Sixth International Congress and Exhibition of Electronics and Atomic Energy, Rome, Italy, 1959. Available at https://www.osti.gov/biblio/4200786-sixth-international-congress-exhibition-electronics-atomic-energy-rome-italy-june-papers.
46
Licensing Frameworks - Risk Evaluation Perspective H I Parts 50 and 52 with LMP Perform Perform design basis Continue design transient and accident radiological and licensing Part 53 Framework A accident analyses consequences analyses activities C D E F Finish PRA Select LBEs Select DBAs Classify SSCs development G
A Evaluate Comprehensive defense-in-and systematic depth initiator search and event B Select Notes:
sequence 1) Each step builds on all of the preceding steps (considers all information available at that point) licensing delineation framework 2) Feedback loops (e.g., the impact of design revisions) are not shown without preconceptions J K L M N or reliance on Select Perform Perform design basis yes Continue design Elect to Finish PRA predefined lists licensing transient and accident radiological and licensing develop PRA development events accident analyses consequences analyses activities Q
Parts 50 and 52 without LMP no AERI Part 53 Framework B ONLY for Part 53 Q1 - Develop demonstrably Framework B no conservative risk estimate Applicant decision using the bounding event O P Identify and yes Continue design AERI entry Q2 - Search all event PDG-1413, Technology-Inclusive Identification of Licensing Events for analyze the and licensing condition met? sequences for severe Commercial Nuclear Plants bounding event activities accident vulnerabilities PDG-1414, Alternative Evaluation for Risk Insights (AERI) Framework Q3 - Develop risk insights by AERI reviewing all event sequences Licensing Modernization Project (LMP) guidance - NEI 18-04, Rev. 1, as 47 endorsed in RG 1.233 47
Proposed AERI Entry Condition
§ 53.4730(a)(34) Description of risk evaluation.
A description of the risk evaluation developed for the commercial nuclear plant and its results. The risk evaluation must be based on:
(i) A PRA, or (ii) An AERI, provided that the dose from a postulated bounding event to an individual located 100 meters (328 feet) away from the commercial nuclear plant does not exceed 1 rem total effective dose equivalent (TEDE) over the first four days following a release, an additional 2 rem TEDE in the first year, and 0.5 rem TEDE per year in the second and subsequent years.
- Provides plants with flexibility in establishing their exclusion area boundaries (EABs) if the bounding events source term is small.
- The 100-meter criterion was back-calculated from a scoping consequence model:
o 50-year dose at 100 meters = 27.5 rem TEDE o Conditional individual latent cancer fatality risk (CILCFR) = 2 x 10-6 per event o Meet the QHO without developing a PRA to credit accident frequency in the risk estimate
- The AERI entry condition is not a safety or siting criterion.
48
Derivation of AERI Entry Condition (1 of 7) 1 Risk, R, is the sum of the products of frequency, , and consequence, ,
over the set of delineated event sequences.
2 Suppose we can identify a bounding event. max , ,,
3 Then we can bound the risk.
4 This demonstrably conservative approach
= sum of the initiating event frequencies eliminates the need to estimate the individual 1/plant-year, based on large LWR history event sequence frequencies by developing a PRA.
49
Derivation of AERI Entry Condition (2 of 7) 5
- There are two QHOs:
o Individual early fatality risk (IEFR) within 1 mile of the site 5 10 /
o Individual latent cancer fatality risk (ILCFR) within 10 miles of the site 2 10 /
- The Safety Goal Policy Statement specifies the distances to be used.
- Justification for these values is provided in NUREG-0880, Rev. 1, pp. 30-31.
6 Focus on ILCFR: = conditional latent cancer fatality risk,
- Part 53, Framework B has been developed to provide , of the bounding event the same level of safety as currently operating plants.
- The State-of-the-Art Reactor Consequence Analysis 1 2 10 /
studies indicate that IEFR is essentially zero for large LWRs.
7
= expected number of latent cancer fatalities within 10 miles of the site over 50 years following CILCFR occurrence of the bounding event
= total population within 10 miles of the site 50
Derivation of AERI Entry Condition (3 of 7) 8 Assume that the plume is confined to one of sixteen 22.5-degree sectors.
22.5° 8
= expected number of latent cancer fatalities in the 10-mile, 22.5° sector over 50 years following occurrence 1 1 10 of the bounding event 9
This assumption eliminates the Assume a uniform population density, .
need to consider the wind direction 51
Derivation of AERI Entry Condition (4 of 7) 10 On a differential basis, the number of latent cancer fatalities is a random variable that is characterized by a binomial probability distribution:
= probability that an individual located
~ ,
at distance r dies within 50 years Accordingly, the expected (mean) value is: = differential number of individuals in the 22.5° sector that are located
- between r and r + dr 11 Apply the linear no-threshold (LNT) model, which = risk coefficient (per rem) relates cumulative radiation exposure to latent 6 10 according to BEIR-VII*
cancer fatality risk.
- = 50-year dose at distance r (rem)
- National Research Council. 2006. Health Risks from Exposure The Commission affirmed the NRCs use of the to Low Levels of Ionizing Radiation: BEIR VII Phase 2.
Washington, DC: The National Academies Press.
LNT model in SRM-SECY-19-0008, July 16, 2021. https://doi.org/10.17226/11340.
52
Derivation of AERI Entry Condition (5 of 7) 12 Assume a power-law dose vs. distance model:
Consistent with NUREG-0396, Planning Basis for the Development of State and Local Government The subscript 0 refers to an arbitrary Radiological Emergency Response Plans in Support of reference location and dose. Light Water Nuclear Power Plants, November 1978.
13
- Integrate over the 10-mile area surrounding the site.
. 1 Apply the uniform population density, LNT, and power-
- * *2 law dose vs. distance assumptions.
16
. = expected number of latent cancer fatalities in 10 the 10-mile, 22.5° sector over 50 years following 4 occurrence of the bounding event 53
Derivation of AERI Entry Condition (6 of 7) 14 The total population in the 10-mile area is: Apply the uniform population density assumption.
- 10 20 5 15 Scoping consequence model.
10 80 5 Note: decreases as increases.
16 10 Upper bound of the scoping consequence model 400 400
- 0.422 Criterion for the reference point 10 54
Derivation of AERI Entry Condition (7 of 7) 17 Dose (rem TEDE) Condition 1 First 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> Additional dose 2
during the 1st year Additional dose 0.5 x 49 = 24.5 during the second and subsequent years 27.5 TOTAL Note: The reference location is not necessarily the same as the EAB 55
Technology-Inclusive Identification of Licensing Events for Commercial Nuclear Plants (PDG-1413)
- Formatted like a regulatory guide; currently a pre-decisional draft regulatory guide
- Section A: Applies to LWRs and non-LWRs licensed under Parts 50, 52, and 53 (Frameworks A and B)
- Section B (Discussion):
o Identifies licensing events for each licensing framework o Provides historical perspectives (early licensing, development of the standard review plan (SRP))
o Addresses ACRS recommendations to start with a blank sheet of paper (10/7/2019, 10/21/2020, 5/30/2021, and 10/26/2021)
- Section C (Staff Guidance) provides an integrated approach for:
o Conducting a systematic and comprehensive search for initiating events o Delineating a systematic and comprehensive sets of event sequences o Grouping the lists of initiating events and event sequences into licensing events
- Appendix A (Comprehensive Search for Initiating Events):
o Reviews techniques for searching for initiating events and points the user to helpful references o Does not endorse or recommend any specific technique 56
Licensing Event Refers to the Designated Event Categories in 10 CFR Parts 50, 52, and 53 Licensing Basis Designated Licensing Event Categories 10 CFR Parts 50 and 52 Based on a search of the regulations and associated regulatory guidance:
Mix of initiating events and event sequences
- Design basis events (DBEs) (§ 50.49):
- Non-DBA (§ 50.2, alternate ac source) o AOOs
- ATWS o External events
- SBO o Natural phenomena LMP as presented in NEI 18-04, Rev. 1 Licensing events are collectively referred to as licensing basis events (LBEs), which include the following categories:
and endorsed in RG 1.233
- AOOs Event sequences
- DBAs 10 CFR Part 53, Framework A Licensing events are collectively referred to as LBEs, which include the following categories:
Event sequences
- Unlikely event sequences
- Very unlikely event sequences
- DBAs 10 CFR Part 53, Framework B
- AOOs Mix of initiating events and
- DBEs partial event sequences
- DBAs 57
Implications of Applicant Decisions on Licensing Event Identification Applicant Decisions Implications Reactor Exemptions Licensing Event Licensing Basis Use of Risk Insights Design Required Risk Evaluation Identificationa LWR no PRA PDG-1413 traditional 10 CFR Parts 50 or 52 non-LWR yes PRA PDG-1413 LWR or enhanced yes PRA RG 1.233 non-LWR Preliminary proposed LWR or 10 CFR Part 53 enhancedb no PRA RG 1.233 non-LWR Framework A Preliminary proposed LWR or 10 CFR Part 53 traditionalb no PRA or AERIc PDG-1413 non-LWR Framework B aLWRs must compare the plant design to the SRP regardless of how the licensing events are identified.
bDictated by the choice of licensing framework.
cVoluntary risk-informed applications require development of a PRA.
58
Staff Perspective The use of a blank sheet of paper approach helps to avoid pitfalls such as, but not limited to:
- The unwitting or unquestioning carryover of assumptions about plant design or behavior,
- The tendency to focus on which predefined events apply (or do not apply) rather than which events are missing from the list,
- The use of predefined lists that are dated and do not reflect contemporary commercial nuclear plant design or operating experience.
The identification of licensing events, conducted objectively and without preconceptions or over-reliance on predefined lists, helps to ensure that the final list of licensing events is comprehensive and, hence, that the plant design is appropriately analyzed and demonstrated to be safe based on the comprehensive set of licensing events.
59
Techniques for Identifying Initiating Events
- The staff has reviewed many sources for identifying initiating events:
o NRC NUREGs o NRC and Canadian Nuclear Safety Commission, Joint Report on Terrestrial Energys Methodology for Developing a Postulated Initiating Events List for the Integral Molten Salt Reactor o IAEA-TECDOC-719 and IAEA SSG-3 o International Electrotechnical Commission, International Standard IEC 31010 o American Society of Mechanical Engineers and American Nuclear Society PRA standards o Center for Chemical Process Safety, American Institute of Chemical Engineers o Electric Power Research Institute technical reports o Open literature internet search
- PDG-1413 does not endorse any specific standard or reference
- PDG-1413 provides a guide to useful references; it is not intended to be a textbook 60
Examples of Techniques for Identifying Initiating Events Inductive Techniques Deductive Techniques
- Double Failure Matrix
- Cause Consequence Analysis
- Failure Mode and Effects Analysis*
- Common Cause Failure Analysis
- Failure Mode Effects and Criticality
- Fault Tree Analysis*
Analysis
- Markov Analysis
- Fault Hazard Analysis
- Master Logic Diagram*
- Functional Hazard Analysis
- Operating and Support Hazard Analysis
- Hazard and Operability Analysis*
- System Hazard Analysis
- Preliminary Hazard Analysis*
- Most common and well-developed techniques PDG-1413 recommends the use of an inductive and a deductive technique when searching for initiating events to ensure the list of initiating events is comprehensive. 61
Overarching Principles Identify application-specific factors (licensing framework, plant-specific design features, and site characteristics).
Conduct a systematic and comprehensive search for initiating events.
Use a systematic process to delineate a comprehensive set of event sequences.
Group initiating events and event sequences into designated licensing event categories according to the selected licensing framework.
Provide assurance that the set of licensing events is sufficient.
62
1 Select the Technology-Inclusive Identification Licensing Framework Collect Application-Specific Information of Licensing Events (Sheet 1 of 3) 2 3 4 5 6 Assemble Collect information on plant Identify Radiological Sources Define Analysis Scope Multi-disciplinary design, plant operating states, and Transport Barriers from Identify Chemical Hazards and Level of Detail Team and site characteristics The Source To The Environment (PRA vs. AERI) 7 Identify Plant-specific Safety Functions
- Systems needed to achieve safety functions
- Operator actions needed to achieve safety functions
- Success criteria Select Analysis Methods 8
9 Define Plant-specific End States for Event Sequences Select Initiating Event 11 Identification Methods 10 Select Analytical Methods
- Inductive methods Define Initiating Event for Event Sequences
- Deductive methods Grouping Strategy and X (e.g., Event Trees, Event
- Human-induced events Characteristics to Sequence Diagrams)
(Appendix provides Sheet 2 discussion and references) 63
Technology-Inclusive Identification of Licensing Events (Sheet 2 of 3)
Initiating Event Analysis 12 13 14 15 Account for Relevant Apply Initiating Event Apply Initiating Independent X Operating Experience and List of Identification Event Grouping Review and Quality for Insights from Earlier Initiating Events from Methods Strategy Assurance (QA)
Relevant Analyses Sheet 1 Event Sequence Selection 16 17 Apply Selected Analytical Methods 18
- Identify initiating event impact on safety functions Account for Relevant
- Identify the impact of front-line and support Operating Experience and Independent Review List of Y system dependencies on safety functions for Insights from Earlier and QA Event Sequences
- Identify the impact of operator actions on safety Analyses of Relevant Designs to functions Sheet 3 64
19 Is a PRA being developed to 20 Provide initiating Y support events and event Technology-Inclusive Identification yes (PRA) from the application? sequences to the PRA of Licensing Events (Sheet 3 of 3)
Sheet 2 no (AERI) 21 Identify Required Categories Follow NEI 18-04, of Licensing Events for Rev. 1 as endorsed Licensing Framework Enhanced use of PRA in RG 1.233
- Part 50 or 52 with LMP AERI or traditional use of PRA
- Part 53 Framework A
- Part 50 or 52 without LMP
- Part 53 Framework B 22 Define Licensing Event Grouping Strategy and Characteristics
- Group by frequency o Qualitative o Quantitative
- Group by type o Plant response following the initiating event (sequence of events, timing) o Similar challenge to safety functions o End state 25 24 Compare to Predefined Lists 26 (e.g., SRP Chapter 15, 23 Identify Limiting Cases Apply Licensing Event previous CP, OL, DC, SDA, ML, Independent List of (bounding or enveloping Grouping Strategy or COL applications) and Review and QA Licensing Events scenarios) for each group identify differences from SRP (only for LWRs) 65
Alternative Evaluation for Risk Insights (AERI) Framework (PDG-1414)
- Formatted like a regulatory guide; currently a pre-decisional draft regulatory guide
- Section A (Introduction): Only applies to LWRs and non-LWRs licensed under Part 53 Framework B
- Sections B (Discussion) & C (Staff Guidance): Components of the AERI approach:
o Identification and characterization of the bounding event Definition of a bounding event Multiple events may need to be considered as bounding events o Determination of a consequence estimate for the bounding event to confirm that the reactor design meets the AERI entry condition o Determination of a demonstrably conservative risk estimate for the bounding event to demonstrate that the QHOs are met Assumed frequency of 1/yr consistent with frequency of all event sequences for LWRs Applicant may use a lower frequency with justification o Search for severe accident vulnerabilities for the entire set of licensing events Definitions of severe accident and severe accident vulnerability o Identification of risk insights for the entire set of licensing events o Assessment of defense-in-depth adequacy for the entire set of licensing events 66
Licensing Frameworks - Risk Evaluation Perspective H I Parts 50 and 52 with LMP Perform Perform design basis Continue design transient and accident radiological and licensing Part 53 Framework A accident analyses consequences analyses activities C D E F Finish PRA Select LBEs Select DBAs Classify SSCs development G
A Evaluate Comprehensive defense-in-and systematic depth initiator search and event B Select Notes:
sequence 1) Each step builds on all of the preceding steps (considers all information available at that point) licensing delineation framework 2) Feedback loops (e.g., the impact of design revisions) are not shown without preconceptions J K L M N or reliance on Select Perform Perform design basis yes Continue design Elect to Finish PRA predefined lists licensing transient and accident radiological and licensing develop PRA development events accident analyses consequences analyses activities Q
Parts 50 and 52 without LMP no (AERI)
Part 53 Framework B ONLY for Part 53 Q1 - Develop demonstrably Framework B no conservative risk estimate using the bounding event Applicant decision O P Identify and yes Continue design AERI entry Q2 - Search all event PDG-1413, Technology-Inclusive Identification of Licensing Events for analyze the and licensing condition met? sequences for severe Commercial Nuclear Plants bounding event activities accident vulnerabilities PDG-1414, Alternative Evaluation for Risk Insights (AERI) Framework Q3 - Develop risk insights by AERI reviewing all event sequences LMP guidance - NEI 18-04, Rev. 1, as endorsed in RG 1.233 67 67
Q AERI Identification and no no yes Q1 - Demonstrably O P conservative risk estimate Identify and Characterization of the AERI entry Continue design and analyze the condition met? Q2 - Severe licensing activities bounding event accident vulnerabilities Bounding Event(s) Q3 - Risk Insights
- The analysis of the bounding event should be capable of estimating the doses and consequences used in the demonstrably conservative risk estimate that result from evaluating the limiting initiating event for the design, considering credit only for inherent safety features.
- The process should:
o use the full set of licensing events o consider both core and non-core radiological sources associated with the reactor unit or multiple units
- The bounding event:
o should be defined by parameters that include source term, meteorology, atmospheric transport, protective actions, dosimetry, health effects, economic factors, and consequence quantification o may combine features of several individual licensing events
- Multiple bounding events should be considered when, for example, a design has more than one event with approximately similar annual likelihoods of occurrence and with similar overall radiological impacts, but with different radiological characteristics of the analyzed release (isotopic composition, chemistry, timing) 68
Q AERI no no The bounding event(s) O Identify and P
AERI entry yes Q1 - Demonstrably conservative risk estimate Continue design and is used to both:
analyze the condition met? Q2 - Severe licensing activities bounding event accident vulnerabilities Q3 - Risk Insights
- Confirm that the AERI entry condition is met o 10 CFR 53.4730(a)(34)(ii) o Uses dose estimate based on the bounding event(s)
Risks of acute and long-term radiation exposures
- Conduct the AERI o Develop a demonstrably conservative risk estimate Uses a consequence estimate based on the bounding event(s) for risks of prompt and latent cancer fatalities) o Search for severe accident vulnerabilities (all licensing events) o Identification of risk insights (all licensing events) o Assessment of defense-in-depth 69
Q AERI no no yes Confirmation that the AERI O Identify and analyze the P
AERI entry condition met?
Q1 - Demonstrably conservative risk estimate Q2 - Severe Continue design and licensing activities Entry Condition is Met bounding event accident vulnerabilities Q3 - Risk Insights
- When electing to use the AERI approach, it may not be known at first whether the entry condition is met
- Confirmation is based on a realistic dose estimate and realistic description of uncertainties (preferred)
- Conservatisms are identified and addressed
- For multiple bounding events, the entry condition should be met for each bounding event 70
Q AERI no no yes Development of a O Identify and analyze the P
AERI entry condition met?
Q1 - Demonstrably conservative risk estimate Continue design and licensing activities Demonstrably Conservative bounding event Q2 - Severe accident vulnerabilities Q3 - Risk Insights Risk Estimate 71
- Demonstration that a reactor design meets the QHOs
- Risks of prompt radiation-caused fatalities and latent cancer fatalities to offsite populations
- No realistic estimate of annual frequency expected
- Assumed frequency of 1/yr, represents the sum of event sequence frequencies and equal to the sum of initiating event frequencies; based on LWR statistics
- Applicant may use a different frequency with justification and NRC staff will review on a case-by-case basis 71
Q AERI no no yes Search for Severe Accident O Identify and analyze the P
AERI entry condition met?
Q1 - Demonstrably conservative risk estimate Q2 - Severe Continue design and licensing activities Vulnerabilities bounding event accident vulnerabilities Q3 - Risk Insights
- Encompass entire set of licensing events and any additional severe accidents
- Severe accident vulnerabilities should be eliminated through modifications to the design, operations, or maintenance
- Justification may be provided for why a severe accident vulnerability is acceptable for the design 72
Q AERI no no yes Definition of Severe Accidents O Identify and P
AERI entry Q1 - Demonstrably conservative risk estimate Continue design and and Severe Accident analyze the bounding event condition met? Q2 - Severe accident vulnerabilities licensing activities Vulnerabilities Q3 - Risk Insights
- Severe accidents defined in 10 CFR 53.4730(a)(5)(v)(B) are those events that progress beyond the DBAs, in which substantial damage is done to the reactor core whether or not there are serious offsite consequences
- In PDG-1414, severe accident vulnerabilities are those aspects of a facility design that represent an overreliance on a single design feature, whether for accident prevention or mitigation, and that could lead to a severe accident after accounting for SSC reliability, human actions, and defense-in-depth 73
Q AERI no no Identification of Risk O Identify and P
yes Q1 - Demonstrably conservative risk estimate Insights analyze the bounding event AERI entry condition met? Q2 - Severe accident vulnerabilities Continue design and licensing activities Q3 - Risk Insights
- Based on entire set of licensing events
- Qualitative descriptions should be provided
- Quantitative descriptions should be provided when available
- Risk insights should provide an understanding of the hierarchy of event sequences ranked by frequency
- Risk insights identified using AERI may be used to support other licensing decisions 74
Assessment of Defense-in-Depth
- Encompasses entire set of licensing events
- Regulatory guidance position is adapted from RG 1.174
- NEI 18-04 may also provide guidance for the AERI framework related to assessing defense-in-depth (adapted from IAEA SSR 2/1)
- Assessment of defense-in-depth complements the search for severe accident vulnerabilities and search for risk insights 75
Path Forward PDG-1413 & PDG-1414
- Make revisions in response to ACRS and stakeholder feedback
- Monitor changes to preliminary proposed rule text PDG-1414
- Develop guidance for AERI maintenance and upgrades 76
Upcoming Meetings Periodic Advanced Reactor Stakeholder Public Meeting:
June 30, 2022 Advisory Committee on Reactor Safeguards Full Committee Meeting:
July 6, 2022 Commission Meeting - Update on 10 CFR Part 53 Licensing and Regulation of Advanced Nuclear Reactors:
July 21, 2022 77
Discussion 78
10 CFR Part 53 Subpart F Staffing , Pe rsonnel Qualifications, Training , and Human Factors (2nd Iteration)
ACRS Subcommittee Meeting 6/24/22
Agenda
- Overview of Key Changes to Subpart F under the 2nd Iteration o Addition of Engineering Expertise Requirement o Expansion of Load Following Allowances o Removal of Simulator HFE Testbed Requirement o Replacement of Certified Operator Framework
- Generally Licensed Reactor Operators
- Questions 80
Overview of Primary Staff Contributors (NRR & RES)
- Theresa Buchanan, Senior Reactor Engineer (Examiner)
- Dr. David Desaulniers, Senior Technical Advisor for Human Factors and Human Performance Evaluation
- Dr. Brian Green, Senior Human Factors Engineer -Team Lead
- Dr. Niav Hughes Green, Human Factors Psychologist
- Dr. Stephanie Morrow, Human Factors Psychologist
- Lauren Nist, Branch Chief, Operator Licensing and Human Factors Branch
- Maurin Scheetz, Reactor Engineer (Examiner)
- Jesse Seymour, Reactor Operations Engineer (Human Factors) 81
Key Changes to Subpart F under the 2nd Iteration
- 2nd iteration of Subpart F retains majority of requirements developed for the 1st iteration
- Some requirements have been relocated to more appropriate spots (e.g., grouping technical requirements)
- Most changes made for the second iteration of Subpart F were mirrored in the contents of Subpart P; for that reason, most significant differences from the first iteration of Subpart F were discussed in detail during the Framework B presentation
- A summary of those major changes will be provided here 82
Overview of Key Changes (continued)
- Addition of engineering expertise requirement o Staffing plan requirements of § 53.730(f) modified to include providing engineering expertise to operators
- Expansion of load following allowances o §§ 53.725(b) and 53.740(e) - (f) requirements modified to expand load following to include process heat usage
- Removal of simulator HFE testbed requirement
- Specific change management for approved programs
- Certified operator provisions completely replaced with an all new generally licensed reactor operator framework 83
Generally Licensed Reactor Operators (GLROs)
Under 2nd iteration of subpart F operator licenses now consist of general licenses and specific licenses.
- A specific license is issued to a named person and is effective upon approval by the Commission of an application filed pursuant to the regulations in this part and issuance of licensing documents to the applicant. Specific licenses are issued to ROs and SROs.
- A general license is effective without the filing of an application with the Commission or the issuance of licensing documents to a particular person. The general licensing of GLROs is addressed by the requirements of §§ 53.800 through 53.830.
84
Generally Licensed Reactor Operators (continued)
- What types of facilities would have GLROs?
o No operator action is needed to mitigate plant events and achieve acceptable accident performance o Defense-in-depth independent of operator action o Operators not significant factor in safety outcomes
- What role would GLROs fulfil?
o Administrative functions historically done by an SRO; keeps facility in analyzed state within licensing basis o Conduct manual reactivity manipulations if needed o Supervise core alterations and refueling operations 85
Generally Licensed Reactor Operators (continued)
- Only a single operator license level exists within the GLRO framework (analogous to the SRO level)
- Plants meeting the criteria for using GLROs would have to use GLROs in lieu of ROs and SROs for staffing
- Like ROs and SROs, the GLRO training program must also be derived from a systems approach to training (SAT)
- Prescriptive staffing and capabilities for GLROs:
o Continuous monitoring with continuity of responsibility o Monitor plant parameters, evaluate emergency conditions, initiate reactor shutdown, dispatch/direct ops & maintenance personnel, and implement emergency plan 86
Generally Licensed Reactor Operators (continued)
- § 53.800 defines new class of plants using the design criteria previously developed for certified operator use o Establishing new class done to conform with Atomic Energy Act
- § 53.805 establishes the responsibilities of facility licensees that use GLROs:
o Maintain GLROs qualifications for responsibilities o Only GLROs may manipulate facility controls o Develop/implement/maintain Commission approved programs for GLRO training, exams, & proficiency o Ensure GLROs meet Part 26 & 73 requirements o Report names of all GLROs to the NRC annually
- § 53.810 is the general license; it is granted provided that qualifications are established and maintained subject to restrictions. GLROs are subject to enforcement action.
87
Generally Licensed Reactor Operators (continued)
- § 53.815 covers GLRO training, retraining, and proficiency provisions.
o Training programs must be derived from SAT Includes performing reactivity manipulations o Initial examination on knowledge and abilities o Continuing training and requalification exams o Requirements for use of simulation facilities o Records must be available for NRC inspection o Must establish a GLRO proficiency program o No specific medical requirements for GLROs
- § 53.830 covers expiration of the license for GLROs 88
Specific Licensing (RO/SRO) versus General Licensing (GLRO)
Comparison of key aspects of the SRO/RO and GLRO frameworks:
Framework Aspect RO / SRO GLRO Licensed operators with responsibility for Yes Yes administrative requirements Licensed operators with role in event mitigation Yes No NRC has legal authority to suspend or revoke Yes Yes license for violations NRC approval of training & exam programs Yes Yes required?
NRC approval needed for exams, medical, simulator, Yes No renewals, terminations, and waivers?
Flexibility for requalification training & exam No Yes periodicity?
89
Summary of how ACRS letter concerns were addressed
- 1. STA Elimination - addressed via the new engineering expertise requirement
- 2. Use of non-licensed, certified operators - entirely replaced by a new licensed operator framework (GLRO)
- 3. Limited scope simulators - to be addressed via guidance and usage of existing standards
- 4. Training program reviews - new SAT program review guidance under development
- 5. Staffing plan provisions for first-of-a-kind builds, senior license holders, and organizational interfaces - to be addressed via guidance 90
Discussion 91
Final Discussion and Questions 92
Additional Information Additional information on the 10 CFR Part 53 rulemaking is available at https://www.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/part-53.html For information on how to submit comments go to https://www.regulations.gov and search for Docket ID NRC-2019-0062 For further information, contact Robert Beall, Office of Nuclear Material Safety and Safeguards, telephone: 301-415-3874; email:
Robert.Beall@nrc.gov 93
Acronyms Advisory Committee on Reactor EAB Exclusion area boundary ACRS Safeguards DBA Design basis accident AEC Atomic Energy Commission DBE Design basis event AERI Alternative evaluation for risk insights DC Design certification AOO Anticipated operational occurrence DG Draft regulatory guide ATWS Anticipated transient without scram DRA Division of Risk Assessment BDBE Beyond design basis event ESP Early site permit BE Bounding event FR Federal Register CFR Code of Federal Regulations GLRO Generally licensed reactor operator Conditional individual latent cancer fatality HFE Human factors engineering CILCFR risk IAEA International Atomic Energy Agency COL Combined license IEFR Individual early fatality risk CP Construction permit ILCFR Individual latent cancer fatality risk Division of Advanced Reactors and Non-DANU LBE Licensing basis event Power Production and Utilization Facilities 94
Acronyms LCO Limiting condition for operation RO Reactor operator LMP Licensing Modernization Project QHO Quantitative health objective LNT Linear no-threshold RES Office of Nuclear Regulatory Research LWR Light water reactor RG Regulatory guide ML Manufacturing license SAT Systems approach to training NEI Nuclear Energy Institute SBO Station black out NFPA National Fire Protection Association SDA Standard design approval NRC U.S. Nuclear Regulatory Commission SRO Senior reactor operator NRR Office of Nuclear Reactor Regulation SRP Standard review plan U.S. Nuclear Regulatory Commission SSCs Structures, systems, and components NUREG technical report designation STA Shift technical advisor OL Operating license TEDE Total effective dose equivalent PDG Pre-decisional draft regulatory guide Technology-inclusive, risk-informed TIRIMA PRA Probabilistic risk assessment maximum accident QA Quality assurance 95