Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards
582nd Meeting
Docket Number:
(n/a)
Location:
Rockville, Maryland
Date:
Thursday, April 7, 2011
Work Order No.:
NRC-821
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers
1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005
(202) 234-4433
Pages 1-289
DISCLAIMER
UNITED STATES NUCLEAR REGULATORY COMMISSION’S
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
The contents of this transcript of the proceeding of the United States Nuclear
Regulatory Commission Advisory Committee on Reactor Safeguards, as reported
herein, is a record of the discussions recorded at the meeting.
This transcript has not been reviewed, corrected, and edited, and it may contain
inaccuracies.
1
1
UNITED STATES OF AMERICA
2
NUCLEAR REGULATORY COMMISSION
3
+ + + + +
4
582nd MEETING
5
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
6
(ACRS)
7
OPEN SESSION
8
+ + + + +
9
THURSDAY
10
APRIL 7, 2011
11
+ + + + +
12
ROCKVILLE, MARYLAND
13
+ + + + +
14
The Advisory Committee met at the
15
Nuclear Regulatory Commission, Two White Flint
16
North, Room T2B3, 11545 Rockville Pike, at
17
8:30 a.m., Said Abdel-Khalik, Chairman, presiding.
18
COMMITTEE MEMBERS:
SAID ABDEL-KHALIK, Chairman
19
J. SAM ARMIJO, Vice Chairman
20
JOHN W. STETKAR, Member-at-Large
21
SANJOY BANERJEE, Member
22
DENNIS C. BLEY, Member
23
CHARLES H. BROWN, Member
24
MICHAEL L. CORRADINI, Member
25
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COMMITTEE MEMBERS:
(cont'd)
2
DANA A. POWERS, Member
3
HAROLD B. RAY, Member
4
JOY REMPE, Member
5
MICHAEL T. RYAN, Member
6
WILLIAM J. SHACK, Member
7
JOHN D. SIEBER, Member
8
9
NRC STAFF PRESENT:
SYED ALI, RES/SL
10
STEVEN ARNDT, NRR/DE
11
SURINDER ARORA, NRO/DNRL/NARP
12
ERIC BOWMAN
13
CRAIG ERLANGER, NSIR/DSP
14
PETER KANG, NRO/Electrical Engineering Branch
15
TIM KOBETZ, Reactor Inspection Branch
16
MICHAEL LAYTON, NSIR
17
ERIC LEE, NSIR
18
BRIAN McDERMOTT, NSIR/Division of Preparedness
19
and Response
20
TIMOTHY MOSSMAN, NRR/DE/EICB
21
WILLIAM RULAND, NRR/DSS
22
DANIEL J. SANTOS, NRO/DE
23
RANDY SULLIVAN, NSIR
24
JOHN THORP
25
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NRC STAFF PRESENT:
(cont'd)
2
BARRY WESTREICH
3
GEORGE WILSON, NRR/Digital I&C Branch
4
DEREK WIDMAYER, Designated Federal Official
5
6
ALSO PRESENT:
7
JEAN-LUC BEGON, UniStar
8
MARK FINLEY, UniStar
9
GREG GIBSON, UniStar
10
GENE HUGHES, UniStar
11
TED MESSIER, AREVA NP
12
JOSH REINERT, AREVA NP
13
RICHARD SZOCH, UniStar
14
15
16
17
18
19
20
21
22
23
24
25
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1
TABLE OF CONTENTS
2
PAGE
3
Opening Remarks by the ACRS Chairman
4
Selected Chapters of the Safety Evaluation
5
Report (SER) with Open Items Associated
6
with the Calvert Cliffs, Unit 3
7
Combined License Application Referencing
8
the U.S. Evolutionary Power Reactor (EPR) . . .
9
10
. . . . . .
6
Events at the Fukushima
Reactor Site in Japan . . . . . . . . . . . 95
11
Draft Final Regulatory Guide 1.152,
12
"Criteria for Use of Computers in
13
Safety Systems of Nuclear Power Plants,"
14
and Cyber Security Related Activities . . . .
15
5
193
Adjourn
16
17
18
19
20
21
22
23
24
25
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1
P-R-O-C-E-E-D-I-N-G-S
2
(8:30 a.m.)
3
4
CHAIRMAN ABDEL-KHALIK:
The meeting will
now come to order.
5
This is the first day of the 582nd meeting
6
of
the
Advisory
Committee
7
During today's meeting, the Committee will consider
8
the following:
9
Evaluation Report with Open Items Associated with the
10
Calvert Cliffs, Unit 3 Combined License Application
11
Referencing the U.S. EPR; 2) Events at the Fukushima
12
Reactor Site in Japan; 3) Draft Final Regulatory
13
Guide 1.152, "Criteria for Use of Computers in Safety
14
Systems of Nuclear Power Plants and Cyber Security
15
Related
Reactor
Safeguards.
16
Reports.
1) Selected Chapters of the Safety
Activities";
17
on
This
and
4)
Preparation
meeting
is
being
of
ACRS
conducted
in
18
accordance with the provisions of the Federal Advisory
19
Committee Act.
20
Federal
21
meeting.
Mr. Derek Widmayer is the Designated
Official
22
for
the initial portion of the
Portions of the session dealing with the
23
selected
chapters
24
associated
25
application referencing the U.S. EPR may be closed to
with
of
the
the
SER
Calvert
with
Cliffs
open
Unit
items
3
COL
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1
protect
2
AREVA.
information
3
designated
as
proprietary
by
We have received written comments from Mr.
4
Bob
Leyse
regarding the events at the Fukushima
5
reactor site in Japan.
6
for time to make oral statements from members of the
7
public regarding today's sessions.
8
9
We have received no requests
There will be a phone bridge line.
To
preclude interruption of the meeting, the phone will
10
be
placed
in
a
listen-only mode during the
11
presentations and Committee discussions.
12
A transcript of portions of the meeting is
13
being kept, and it is requested that the speakers use
14
one of the microphones, identify themselves, and speak
15
with sufficient clarity and volume, so that they can
16
be readily heard.
17
At this time, we will go to the first item
18
on
the
agenda, Selected Chapters of the Safety
19
Evaluation Report with Open Items Associated with the
20
Calvert Cliffs Unit 3 Combined License Application
21
Referencing the U.S. EPR.
22
through that discussion.
23
Dr. Powers.
24
MEMBER POWERS:
25
are
in
the
And Dr. Powers will lead us
Members are aware that we
process of reviewing the design
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1
certification, safety analysis report of the design
2
certification of the EPR reactor.
3
in all of the certifications, there is a reference
4
COLA
5
evaluation report going on.
for
that,
6
and
Staff's
there
is
strategy
As is the process
a
for
parallel
safety
handling
these
7
parallel endeavors will be outlined in some detail,
8
but
9
evaluation report with open items.
in
essence
it
is
to
bring
to
us
a
safety
When the staff
10
feels that a pathway has been established to resolve
11
those open items, we examine the reference material
12
and
13
identify.
14
what is called Phase 4 of the safety evaluation
15
report.
see
if
there
are
other
issues
that we can
And, if not, then the material moves on to
16
What we're going to do today is bring to
17
the Committee -- and I think it's 10 chapters -- of
18
the reference COLA SER where the Subcommittee has
19
examined
20
identified by the staff, and found no additional
21
items, and want to move it on into the Phase 4 of
22
their review.
23
that
material,
examined
the
open
items
The strategy we are going to adopt is
24
staff is going to give us a bit of an introduction to
25
this reference COLA material.
Then, the applicant
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1
will review the material relatively briefly.
2
covering a lot of material in a short period of time,
3
so it will be a fairly high-level review.
4
We're
And then, the staff will go over some of
5
the elements of their SER.
6
major issues, the Subcommittee and the staff have not
7
identified such things.
8
will turn the meeting over to Surinder, who will give
9
you some background on their review and some overview
10
If you are looking for
So with that introduction, I
of the process.
11
Surinder?
12
MR. ARORA:
Thank you, Dr. Powers.
My
13
name is Surinder Arora, and I am the lead project
14
manager for Calvert Cliffs Unit 3 combined license
15
application project.
16
presentation will be a two-part presentation.
17
Dr. Powers said, UniStar will go first, and then I
18
will give a brief overview of all the 10 chapters that
19
we are going to be presenting today to the Committee.
20
I will start my presentation with a brief
21
description and status of the Calvert Cliffs Unit 3
22
combined license application project review.
What I will do is today's
23
Can we go to the first slide?
24
Calvert
25
received
in
two
Cliff
parts,
COLA
and
application
several
Like
was
supplements,
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1
starting with the initial submission on July -- in
2
July
3
docketed in June of 2008.
4
submitted after Part 2, and the latest revision, which
5
is Rev 7, which is currently being followed further
6
with reviews.
2007.
7
Part 2 was accepted for review and
The
COLA
with
Several updates were
reviews
the
are
reviews
being
8
concurrent
on
9
certification, which is AREVA's FSAR.
performed
the
design
The staff has
10
completed Phase 2 reviews on nine full chapters of
11
Calvert Cliff's application and one partial chapter,
12
which we are going to be presenting to the Committee
13
today.
14
I will show in the next slide the Phase 2
15
reviews and status.
This slide here depicts the six
16
visits of the review process, and, as I said, we are
17
currently at the end of Phase 2 for this -- for these
18
10 chapters.
19
Phase 4 where we are trying to close the open items
20
which were identified at the end of Phase 2.
And some of the work is being done in
21
Next slide.
22
Review strategy -- we start with pre-
23
application activities.
This is generic information
24
that I thought will be useful to present.
25
application activities involve a public meeting near
The pre-
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1
the proposed site to make the public aware of the
2
applicant's intent to build a new nuclear powerplant
3
and to discuss the NRC's review process for the
4
application.
5
In such public meetings, we also provide
6
the contact information at NRC, so that the public can
7
obtain any further information they need.
8
receiving the application from the applicant, the
9
staff performs an acceptance review of the content of
10
the application to make sure that it is complete, and
11
staff can start the review of the application.
12
that decision is sent to the applicant in a letter --
13
official letter that gives the docket date for the
14
application.
15
As
several
chapters
of
the
After
And
combined
16
license application incorporate by reference the U.S.
17
EPR
18
concurrently being reviewed under a different docket
19
number, the staff's review of COL FSAR for chapters or
20
sections which incorporate U.S. EPR FSAR by reference,
21
ensures
22
incorporated by reference from DC FSAR and the site-
23
specific information included in the COL FSAR more
24
together represent the complete scope of the COLA
25
chapters.
design
certification, which is, as I said,
that
the
combination
of
the
information
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1
And to track the revisions of the DC,
2
which are coming also at the same time, we have
3
created an open generic RAI to track the open items,
4
so that all the revisions of the DC are reviewed for
5
the purpose of the COLA revision.
6
That's
my
brief
introduction
7
project and our review strategy.
8
that?
9
start the UniStar presentation.
of
the
And any questions on
Otherwise, I will pass it on to Mr. Gibson to
10
MEMBER POWERS:
I might just interject
11
here that at the outset of this endeavor I was very
12
suspicious of the piecemeal review process rather than
13
having a complete application.
14
encountered any difficulty doing things this way.
15
So far, we have not
It seems -- in fact, all the project
16
managers involved have promised me the most boring
17
review that they can possibly deliver, and so far we
18
have succeeded admirably, because things move very
19
smoothly and they are not bringing things to us until
20
some pathway to their resolution is evident to both
21
parties involved.
22
23
If there are no other questions, we will
turn now to --
24
MR. ARORA:
Mr. Gibson and his team?
25
MEMBER POWERS:
These gentlemen have a
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major challenge of covering 10 chapters in about,
2
what, 50 minutes?
3
to do it, and I said, "That's what you get the big
4
bucks for."
5
6
So -MEMBER CORRADINI:
So you're just going to
keep us in line.
7
8
And they asked me for advice on how
MEMBER POWERS:
Mike, I can't keep you in
line on the best day I have ever had in my life.
9
MR. GIBSON:
my
name
is
Mr. Chairman, members of the
10
ACRS,
11
President
12
appreciate the opportunity to come before you.
13
have been to the individual Subcommittee meetings, but
14
this is our first full Committee meeting.
with
Greg
UniStar
Gibson.
Nuclear
I'm Senior Vice
Energy,
and
I
We
15
So with that I'd like to briefly just say
16
that I graduated from Georgia Tech in Physics and
17
Nuclear
18
Bachelor's and an MBA in International Business from
19
National University.
20
the industry, 25 years of experience with Southern
21
California Edison.
Engineering.
I have a Master's and a
I have 35 years of experience in
Thank you, Harold.
22
And I also worked for eight years with the
23
Nuclear Regulatory Commission out of Regions II and
24
III.
25
Manager of Regulatory Affairs for the South Texas
After I left San Onofre, I was the initial
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1
Project, Units 3 and 4.
2
three years with UniStar Nuclear.
3
And I joined for the last
Also, I may have met many of you through
4
the American Nuclear Society.
5
the Operations and Power Division, and I also was the
6
President of the San Diego chapter of the ANS.
7
I was the Chairman of
Our presentation that we have today is
8
going to be joined by Mark Finley.
9
here,
I
apologize.
His title is wrong
He is Vice President of
10
Engineering.
11
and we are supported by our teammates from AREVA, Ted
12
Messier and Josh Reinert.
13
table, but our major speakers who will be here to
14
address what we are anticipating would be the types of
15
questions that you would want to focus on today.
16
Rick Szoch, Jean-Luc Begon, Gene Hughes,
We couldn't all fit at the
So with that, I would like to give just a
17
quick,
18
Surinder presented.
19
one partial chapter that we provided, you can see the
20
number of departures, exemptions, and SER open items
21
that we have in these chapters as we have moved
22
forward.
23
you
know, summary to dovetail into what
With the nine total chapters and
In terms of our SER open items, we have 39
24
for these sections and chapters.
And of those we have
25
responded to all of the 39, so we are very hopeful
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1
that this will move very expeditiously through to
2
Phase 4 and into Phase 5, as the staff reviews the
3
closure packages that we have for our SER open items.
4
For
our
presentation
today,
we
have
5
identified items of interest that we wanted to bring
6
to you dealing with Chapter 2, which is the site
7
characteristics, also Chapter 8, 17, and 18 -- or 17
8
and 19.
9
power, and 17, quality and reliability assurance, and
the
These -- again, Chapter 8 is the electrical
10
then
PRA.
We figured those were topics of
11
particular interest to the Committee.
12
As Surinder mentioned, we have used the
13
incorporate by reference methodologies that many of
14
the other RCOLAs have for referencing the U.S. EPR
15
design certification that is being provided by AREVA.
16
And so today what we will be doing is just talking
17
about the departures, exemptions, SER open items, and
18
anything of particular site-specific interest.
19
As many of you know, the Calvert Cliffs
20
Unit 3 site is located adjacent to the Calvert 1 and
21
2 sites.
22
any of the ACRS members would like to visit the site,
23
we would be more than happy to work with Derek to
24
provide a tour of that property.
25
Again, we have made an open invitation.
If
But as you can see here from the artist's
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1
rendering, it is in the upper right-hand side, and the
2
plant is approximately 84 feet, 83 feet above sea
3
level above the Chesapeake Bay behind the cliffs.
4
Okay.
Here is our 50-mile radius to show
5
Washington, D.C., Annapolis, and Fredericksburg being
6
the areas -- Baltimore is just outside where we have
7
our corporate offices, but that is the vicinity of the
8
facility.
9
in the presentation about transmission lines, and we
10
will be going back to a very similar figure to this.
11
On the chapters that we had, the vast
12
majority of these have been incorporated by reference,
13
and so that was one of the reasons why we have so few
14
SER open items and so few departures.
15
And we will be talking a little bit later
Okay.
So with this, I will start by
16
turning over the first part, which is Chapter 2, and
17
we will be focusing on meteorology.
18
interest in Chapters 2.4, which is hydrology, and 2.5,
19
which is soils.
20
in Part 2 of our ACRS presentations, and we are only
21
going to be covering Chapters 2.1 through 2.3 in this
22
presentation.
There may be
But those are going to be addressed
23
So with that, I would like to turn it over
24
to Mark Finley, who is our Engineering Vice President.
25
Mark?
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1
MR. FINLEY:
Thank you, Greg.
As Greg
2
said, my name is Mark Finley.
3
Manager, actually Vice President of Engineering now.
4
MEMBER
I'm UniStar Engineering
CORRADINI:
If I might just
5
interrupt you, I wanted to ask Dana -- and probably
6
you guys aren't the right one -- just from a timing
7
standpoint, Dana, we have written a letter on the
8
certification for some chapters.
9
Are they the same chapters that we are now
10
looking at for the -- I'm a little confused.
11
unravel this for me?
12
letter to the Commission about some set of chapters,
13
but are they the same set that we're looking at here?
14
15
MEMBER CORRADINI:
Okay.
But not a one to
one.
MEMBER POWERS:
Not -- the two are going
along fairly independently.
20
21
There's a substantial
overlap.
18
19
Because I remember we did a
MEMBER POWERS:
16
17
Can you
MEMBER
Thank you.
22
CORRADINI:
Okay.
Thank you.
Sorry.
MR.
FINLEY:
A little bit about my
23
background, I have been with UniStar for four years,
24
and before that with Constellation at the Ginna plant
25
and Calvert Cliffs plant, before that the U.S. Nuclear
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1
Navy, and graduate of the Naval Academy, a B.S. from
2
the Naval Academy, professional engineer from the
3
State of Maryland.
4
As Greg said, there is three topical areas
5
that were of interest in the Subcommittee that we
6
thought we would talk about here today, and the first
7
is meteorological data, and specifically what margin
8
we have in the design parameters for meteorology for
9
the future.
10
And so Slide 11 here speaks to the fact --
11
I'm going to talk a little bit about the significant
12
design parameters for meteorology and what values we
13
have assumed from a generic standpoint consistent with
14
the design certification, and what values we have
15
assumed from a site-specific standpoint for the site-
16
specific structures.
17
I'm
sure
the
Committee
is
aware,
but
18
essentially the Calvert Cliffs project follows the
19
design certification document for all of the generic
20
structures onsite.
21
specific safety structure, which is the UHS makeup on
22
the Chesapeake Bay.
23
generic, and they follow the design as described in
24
the design certification.
25
We
In fact, there is only one site-
All of the other structures are
have
used
a
conservative
approach
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1
meeting
regulatory
2
parameters that I am about to describe.
3
requirements
for
all
of
the
Next, Slide 12, so first maximum rainfall
4
rate.
Generally, for the Calvert Cliffs site, this
5
maximum rainfall rate is associated with tropical
6
storms.
7
is no clear trends regarding the number or severity of
8
tropical storms for the region.
9
locale, based on a 100-year annual recurrence data
10
from the National Weather Service, we have 3.28 inches
11
per hour as a maximum rate.
In terms of predictions for the future, there
12
However,
in
the
For the site-specific
design
certification
13
document, an assumed value of 19.4 inches per hour is
14
used for design of the generic structures.
15
again, that is what we're using for the generic
16
structures.
And,
17
We have chosen a site-specific rate of
18
18.5 inches per hour, and that will be used for the
19
one site-specific structure and for the -- essentially
20
the grading of the site at Calvert Cliffs.
21
see, a lot of margin here between what is calculated
22
as the 100-year return value for the Calvert Cliffs
23
locale and what is actually assumed in the design.
As you can
24
Next slide.
25
In terms of loading on the roof during the
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1
winter, in terms of predictions for the future, snow
2
volumes are actually projected to decrease, whereas
3
precipitation amounts potentially increase.
4
load during the winter is actually a combination of
5
these two, because it takes not only the snow but also
6
rainfall on top of the snow as -- in developing the
7
worst loading.
8
Again,
based
on
data
for
The snow
the
site
9
specifically, we have -- it's 113 years of historical
10
data, and, in addition, a calculation statistically
11
for a 100-year return value.
12
per square foot.
13
pounds per square foot, which is the generic value
14
that is used in the design certification.
15
site-specific structure, we will use 65 pounds per
16
square foot.
17
bounding in terms of what is expected for the Calvert
18
site.
Okay?
And that compares to the 100
Next?
20
MEMBER CORRADINI:
that again?
22
And for the
So not as high as generic, but certainly
19
21
The number is 38 pounds
I'm sorry.
MR. FINLEY:
Can you just repeat
I'm just listening to the -Certainly.
So what we expect
23
-- and using the regulatory process that applies for
24
calculating the worst snow and rain load at the
25
Calvert Cliffs site, we calculate 38 pounds per square
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1
foot.
2
MEMBER CORRADINI:
3
MR. FINLEY:
Okay.
And this compares to what is
4
used in the design for the generic structures, 100
5
pounds per square foot, and for the one site-specific
6
structure 65 pounds per square foot.
7
MEMBER ARMIJO:
I don't know your acronyms
8
for that building, the UHS M/U building.
9
building?
10
MR. FINLEY:
Okay.
What is that
It's the makeup --
11
ultimate heat sink makeup structure.
12
structure that is located on the bay, basically.
13
it's not needed except 72 hours after the event,
14
design
15
makeup to the basins of the UHS cooling towers for the
16
plant.
17
generic structures are located, as Greg said, up above
18
the cliffs, essentially 84 foot above grade.
basis
accident.
It's the one
And
Essentially, it provides
19
The towers themselves and the rest of the
CHAIRMAN ABDEL-KHALIK:
Clearly, the site-
20
specific maximum rainfall rate and the snow and ice
21
load site-specific value that you have selected are
22
conservative compared to historical data.
23
are within the specified generic maximums for the DCD.
24
I'm curious as to how these values were selected,
25
however.
And they
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1
MR. FINLEY:
Okay.
I understand the
2
question, how they're selected.
3
meteorological expert, I would like to defer to AREVA,
4
at
5
determining these values.
least
Given I'm not a
regarding the generic process used for
6
Ted, can I ask you to help?
7
MR. MESSIER:
Is this microphone on?
Hi,
8
I'm Ted Messier from AREVA.
I'm a meteorologist.
9
I've been working in the commercial nuclear industry
10
for over 20 years now.
I have a Bachelor of Science
11
and Master of Science degree in Meteorology.
12
my background in a nutshell.
That is
13
How that 100 pounds per square foot value
14
was determined, sir, we followed the relatively recent
15
interim staff guidance that was put out around 2007 on
16
determining snow loads for the roofs of safety-related
17
structures.
18
snowfall events, historical maximum snowpacks, which
19
-- type of statistics are stored by National Oceanic
20
and Atmospheric Administration.
21
there is a website, whose address I can give you, and
22
you can see for yourself.
It involved looking at historical maximum
If you're interested,
23
We also looked at a couple of statistical
24
parameters -- the 100-year return period snowpack and
25
100-year return period snowfall event.
And using the
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1
guidance provided by NRC staff, we came up with this
2
value of 100 pounds per square feet.
3
4
CHAIRMAN
ABDEL-KHALIK:
No, no.
I'm
interested in the 18.5 inches per hour --
5
MR. MESSIER:
Ah.
6
CHAIRMAN ABDEL-KHALIK:
-- and the 64
7
inches per square foot that you have selected for the
8
site-specific values.
9
MR. MESSIER:
Ah.
For the site-specific
10
values, I am going to pass it back to Mark, then, as
11
those were not part of AREVA's provenance.
12
(Laughter.)
13
MR. FINLEY:
So Ted described the process
14
for the generic method.
15
essentially what you see here -- let's go back to
16
Slide 12 first for maximum rainfall rate.
17
we
18
recurrence
19
Service data for the region, established the site-
20
specific value of 3.28 inches per hour.
used
is
described
calculation
21
In terms of site-specific,
in
terms
based
on
of
The process
the
100-year
National
Weather
In terms of how we selected 18.5, it was
22
just
margin
that
23
parameter
24
involved in designing to a higher value.
25
was established, but impacts on the design were also
with
was
added
consideration
to
of
the
site-specific
costs
that
were
So margin
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1
considered.
2
MEMBER
BROWN:
That sounds like you
3
evaluated a larger number and then said, "Okay, the
4
incremental cost difference between 18.5 and 3.28 is
5
relatively small.
6
bite the bullet and use the higher number."
7
why you used 18.5 vice 19.4 --
8
9
Therefore, we will go ahead and
MR. FINLEY:
Although
I don't know exactly the
history of how this number was developed.
I don't
10
have a reason for why 18.5 is different than 19.4,
11
frankly.
12
development we stayed with a generic value, and then
13
at one point we stuck with 18.5.
14
15
MEMBER SHACK:
Did you use 18.5 for the
existing plants?
16
17
It might have been just in the history of
MEMBER
CORRADINI:
You expected this
question, I assume.
18
MR. FINLEY:
Frankly, I'm not -- I didn't,
19
so I'm not sure the value that is used for Calvert
20
Cliffs Unit 1 -- I suspect it is much lower than 18.5.
21
With regard to -- and back to Slide 13.
22
With regard to the snow load, again, similar process.
23
We used actual data for the Calvert Cliffs site and
24
the regulatory requirements that applied to calculate
25
the 38 pounds per square foot, and then a value with
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1
margin was chosen for the site-specific structure,
2
even though less than the generic design value taken.
3
MEMBER BLEY:
It looks like there was
4
nothing systematic about the way you went after margin
5
or how you --
6
MR. FINLEY:
That's correct.
I can't say
7
that there is any established methodology that was
8
used
9
increased costs against having some margin for the
10
to
determine
it.
Just a balance between
parameter.
11
MEMBER CORRADINI:
So let me ask the
12
question differently, just so -- because, as you can
13
see, after the light is on we start looking at it.
14
if you went back to the -- maybe the rainfall one --
15
and the meteorologist that just stepped down, if you
16
could step up.
So
17
So given what it is historically -- and I
18
think I understood how you got to that number -- and
19
given what you guys have chosen, forget about how
20
you've justified it, so how do I interpret that
21
enormous range that the 100-year recurrence value was
22
lower, and now you have chosen this.
23
will never occur, this will never -- I mean, how do I
24
interpret something --
25
MEMBER POWERS:
That means this
This is a real good way to
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1
shut me up when I asked them, "What are you going to
2
do about global weather change?"
3
4
MEMBER CORRADINI:
MEMBER POWERS:
I don't think they did it
for me, but they can certainly shut me up --
7
MEMBER CORRADINI:
8
MEMBER POWERS:
9
MEMBER CORRADINI:
MR. MESSIER:
11
(Laughter.)
12
-- for Mr. Powers.
13
MEMBER CORRADINI:
Okay.
We will not --
It is big enough so
that nobody is going to ask anymore.
15
16
Okay.
-- when they say that.
10
14
So this is the
powers -- the powers --
5
6
Okay.
MEMBER POWERS:
It effectively kept me
quiet for a while.
17
MR. FINLEY:
One thing just to be clear --
18
and I'm sure you probably understand this -- but the
19
19.4 that Ted would speak of is chosen to bound the
20
whole country.
21
22
MEMBER SHACK:
It might not be so bad in
Florida.
23
MR. FINLEY:
Right.
Right, right.
24
should be bounding for Calvert Cliffs.
25
have margin to the number.
It is.
So it
We
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1
MEMBER CORRADINI:
2
fine.
Thank you.
3
understood.
That's fine.
That's
I just wanted to make sure I
Thank you.
4
MR. FINLEY:
Okay.
If I can move to
5
Slide 14.
6
non-tornado
7
predictions for the future, no specific projections
8
regarding changes in wind speed.
9
American
10
With regard to wind speed -- and this is
wind
Society
speed
for
--
Civil
again,
in
terms
of
We have followed the
Engineers
guidance
on
calculating a maximum wind speed.
11
The 50-year return value is 95 miles per
12
hour, the 100-year return value is 102 miles per hour.
13
And
14
hurricane/tropical storm frequency in the region.
this
15
data
that
was
used
does
include
the
So there is margin to the generic wind
16
speed value of 145 miles per hour using the design
17
certification.
18
value of 102 miles per hour in the one site-specific
19
structure, the UHS makeup building.
20
21
We have used the calculated 100-year
MEMBER BANERJEE:
gust?
22
MR. FINLEY:
23
MEMBER SIEBER:
24
Is that the three-second
Yes, that's correct.
Now, how do you justify
that lower wind speed for that one building?
25
MR. FINLEY:
Well, again, the process
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1
used, as stated here, meets regulatory requirements,
2
follows
3
guidance for establishing maximum wind speed at the
4
location.
5
is how the 102 mile per hour value was taken.
the
American
Society
for
Civil
Engineers
We used a 100-year return value, and that
6
MEMBER SIEBER:
My experience is that when
7
you have a number of structures, some of which are
8
designed very strongly to withstand heavy rainfall,
9
snowfalls, and high winds, including tornados, and you
10
have an adjacent commercial building that is not
11
designed to that, and you suffer one of those kinds of
12
events, pieces of the commercial building end up going
13
into your switchyard and transformers can cause a lot
14
of problems.
15
So my questions would be, first, can you
16
justify 102 miles an hour for a commercial building?
17
How far away from the plant is it?
18
to the plant where it can damage vital equipment?
19
you perhaps address that?
20
MR. FINLEY:
Is it close enough
Yes, yes, yes.
Can
So we'll talk
21
a little bit more when we talk about tornado, but the
22
UHS makeup structure -- again, this is the one safety
23
structure down on the bay -- is also designed for
24
tornado wind speeds, and also designed for tornado-
25
borne missiles.
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1
Okay.
So in terms of protection of safety
2
equipment in that safety structure, the structure is
3
designed to protect all of the safety equipment.
4
Now, your question regarding the non-
5
safety structures, they are not typically designed for
6
tornadoes.
7
terms of wind speed and other loading.
8
expect that, say, for the Turbine Building, which is
9
close to other safety structures on the site, that the
10
But as you say, there is siding on the
structure that would probably --
13
14
We would
structure itself would not fall down.
11
12
They are designed to meet regional code in
MEMBER SIEBER:
I can testify that it does
come off.
15
MR. FINLEY:
in
such
an
Right.
event.
The siding would come
16
off
17
structures are designed for tornado-borne missiles, so
18
they
19
structure and other non-safety structures that are in
20
the proximity of the safety structures would not fall
21
down.
would be protected.
But, again, the safety
The turbine building
22
So in that sense the structure itself
23
wouldn't impact on the safety structures, but you're
24
right, we could have problems, say, in the switchyard
25
and other non-safety areas resulting from debris in
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1
such an event, yes.
2
3
MEMBER SIEBER:
Yes, offsite of offsite
power is --
4
MR. FINLEY:
Yes.
5
MEMBER SIEBER:
-- can be a serious event.
6
I noticed from this artist's drawing it looks like
7
there are some sheet metal buildings that lie between
8
Units 1 and 2 and your proposed Unit 3.
9
correct?
10
There is probably a lot of construction
trailers around there, too.
11
MR. FINLEY:
12
buildings.
13
photo of the site --
14
15
Is that
Yes, so those are office
If you go back to the picture, the aerial
MEMBER SIEBER:
Well, that's the artist's
photo.
16
MR. FINLEY:
Yes, so the new unit up on
17
the -- sort of the top right of the picture, that's a
18
computer graphics rendition.
19
real, essentially the existing Unit 1 and 2 site, and
20
there is office buildings you see essentially to the
21
west and southwest of the existing site.
22
office buildings for the existing site.
23
MEMBER SIEBER:
24
MR.
FINLEY:
not
sheet
25
buildings,
The rest of the site is
Those are
So --
They are commercial.
They are commercial
metal
type
buildings
but
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1
substantial commercial buildings, yes.
2
MEMBER SIEBER:
I notice as you go through
3
this, will you get to probable maximum floods, site
4
elevation,
5
interest to --
6
bay
elevation?
MR. FINLEY:
That seems to be of
We'll touch on that, but,
7
again, that is in Chapter 2.4, hydrology.
8
the standpoint of --
9
MEMBER SIEBER:
10
11
MR.
FINLEY:
But from
That's not --
-- meteorology, we can
certainly tantalize you with some early information.
12
MEMBER SIEBER:
13
picked out to talk about specifically.
14
MR. FINLEY:
It's not one that you
That's correct.
So we can
15
talk in general about it.
It's actually in terms of
16
technically it's part of the scope for future -- a
17
future meeting.
18
safety structures, except for the UHS makeup safety
19
structure, are at the --
As Greg said, though, all of the
20
MEMBER SIEBER:
21
MR. FINLEY:
22
MEMBER SIEBER:
23
MR. FINLEY:
That's on there.
-- 84-foot -On the bay.
That's correct.
The makeup
24
structure is on the bay, and it will be designed for
25
the maximum flood, i.e. tsunami, etcetera.
It will be
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1
designed to accommodate that.
2
MEMBER SIEBER:
3
will hear about at some later meeting.
4
MR. FINLEY:
5
MEMBER SIEBER:
6
Okay.
And the details we
Yes, sir.
Thank you.
I'll make a
note of that.
7
MR. FINLEY:
So Slide 15 I think now, with
8
respect to tornado.
I spoke a little bit about this.
9
Again, in terms of predictions, not a lot of evidence
10
to try to predict how the strength or frequency of
11
tornadoes will change in the future.
12
The process that we use to establish the
13
site-specific value met this Regulatory Guide 1.76,
14
and the number established was 200 miles per hour, and
15
there is also additional data in terms of the size of
16
the tornado, and so forth.
17
lower than what is assumed for the generic design
18
structures and the design certification.
19
thirty miles per hour is used there.
20
And, of course, this is
Two hundred
For our one site-specific structure, we
21
will use 200 miles per hour as a tornado wind.
22
I said before, this also includes debris that would be
23
borne with that tornado.
24
25
MEMBER BANERJEE:
And as
How did you arrive at
the 230 miles per hour?
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1
MR. FINLEY:
2
generic number.
3
back and --
4
So that's -- the 230 is a
Let me ask Ted from AREVA to come
MEMBER POWERS:
we
Maybe in the interest of
5
time,
should leave the generic values to
6
discussions of generic things --
7
MR. FINLEY:
8
MEMBER POWERS:
9
Okay.
Let's move --
-- and focus just on the
specific things, because we will run out of time here.
10
MR. FINLEY:
Understand.
And then, my
11
last parameter would be temperature for the site,
12
maybe of most interest in terms of the future, but
13
there
14
temperature could change for the site, the predictions
15
of roughly a three-degree increase over the next 50
16
years essentially for the site.
are
17
predictions
We
have
available in terms of how
established
a
zero
percent
18
exceedance value for the Calvert Cliffs site using
19
data over the last 30 years of 102 degrees.
20
zero percent exceedance means a value that is not
21
exceeded for two consecutive hours, so 102 degrees is
22
essentially a maximum dry bulb value found looking at
23
the last 30 years of data.
Now, a
24
If you look at the generic maximum value
25
for dry bulb temperature in the U.S. EPR FSAR, that is
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1
115 degrees, so a significant amount of margin to that
2
value.
3
the design of HVAC systems for the safety structures
4
that
5
structure we are using a 102-degree maximum zero
6
percent exceedance dry bulb temperature, which is
7
applicable to the Calvert Cliffs site.
And, again, this temperature will be used in
are
generic.
8
9
For the site-specific safety
MEMBER STETKAR:
Mark, on your snow load
and precipitation slides, you mentioned that you would
10
113 years of historical data.
11
years for temperature?
12
MR. FINLEY:
Why did you only use 30
The question is:
why only 30
13
years for temperature?
14
availability of data from a site that was close to
15
Calvert Cliffs.
16
It has to do with the
MEMBER STETKAR:
Well, you had 113 years
17
of precipitation data for a site that was close to
18
Calvert Cliffs?
19
MR. FINLEY:
For temperatures, we wanted
20
to use a site that was local, very close, and we used
21
the Patuxent River Naval Air Station site, and we had
22
30 years of data for that.
Again, in terms of the
23
regulatory
apply,
24
acceptable.
25
criteria
that
MEMBER STETKAR:
30
years
was
Thirty years worth of
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1
data to predict 100-year exceedance frequencies is not
2
a lot of data.
3
4
MEMBER SIEBER:
That makes me feel very
old.
5
(Laughter.)
6
MEMBER STETKAR:
7
precipitation?
8
MR. FINLEY:
9
MEMBER STETKAR:
I think --
10
MR. FINLEY:
11
MEMBER SIEBER:
12
MR. FINLEY:
13
What data site?
It talks about -Richmond's close by.
-- Solomons Island it looks
like was used, Solomons, Maryland.
14
MEMBER SIEBER:
15
MEMBER BLEY:
16
What did you use for the
there.
Okay.
That's essentially right
It's right next door.
17
MEMBER STETKAR:
Well, but my curiosity is
18
if they had precipitation records for 113 years at
19
that site, they probably have temperature records at
20
that site.
21
22
MEMBER BLEY:
you don't.
23
I believe I heard you say
That comes from further away.
MR. FINLEY:
Yes, and I can confirm, but
24
I don't believe we had the hourly data that was
25
required with dry bulb and wet bulb.
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1
2
MEMBER STETKAR:
Hourly gets to be a
problem going back.
3
MR. FINLEY:
Yes.
Yes, this is hourly
4
data, and it includes needing some information about
5
humidity.
6
7
MEMBER STETKAR:
problem at some sites.
8
9
10
Hourly data gets to be a
That's right.
MEMBER SIEBER:
Thank you.
That shouldn't say, "I'm
not going to pay attention to any data older than 30
years, because it's not hourly"?
11
MR. FINLEY:
12
MEMBER BLEY:
Yes, that's correct.
Is there some, you know,
13
statistical estimate that tries to take care of these
14
different
15
distributions or something?
time
periods,
16
MR. FINLEY:
17
MEMBER BLEY:
18
extreme
value
What do you do?
Again, not -Or is this just a maximum in
30 years?
19
20
use
MR. FINLEY:
For this particular value,
this is a maximum --
21
MEMBER SIEBER:
22
MR. FINLEY:
Observed.
-- the 30-year data.
For the
23
other values we talked about where we speak of the
24
100-year recurrence or 50-year recurrence, that's a
25
calculated value based on statistical analysis of the
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1
data.
But for this temperature value it's a -- it's
2
going back looking at actual hourly data, finding what
3
the maximum is that was not exceeded by more than one
4
hour consecutively.
5
process.
6
So this was a deterministic
So last slide, I'm sure you're -- the
7
basic question is, in terms of margin, I think what
8
we've demonstrated here is we have significant margin
9
to the generic values for all the generic safety
10
structures.
We don't have as much margin for the
11
site-specific structure.
12
However, we do have monitoring programs,
13
and we do have technical specifications that will
14
require us to monitor these temperatures.
15
future, if we do see trends that affects these design
16
parameters, we will take approach action.
17
either
18
accommodate a higher value, or make modifications to
19
the plant to accommodate the higher value.
establish
20
that
And in the
We will
we have the margin to
I have experience, for example, at Calvert
21
Cliffs Unit 1 and 2.
I know we used originally a
22
design bay water temperature for Unit 1 and Unit 2 of
23
85 degrees.
24
2, we ultimately exceeded that bay temperature of 85
25
degrees as many sites across the country have done.
And in my history at Calvert Cliffs 1 and
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1
We took appropriate action.
2
our service water system, which is the ultimate heat
3
sink for the plant.
4
water temperature, we, you know, increased the design
5
temperature essentially for the plant.
6
of a process could be followed for us, if necessary,
7
in the future.
8
9
We modified
To accommodate the higher bay
MEMBER ARMIJO:
about your site map.
So that kind
I had a quick question
You just give a picture.
But
10
are the elevations for the unit and the existing units
11
about the same?
12
MR. FINLEY:
No.
So the question is about
13
the elevation for the two units.
14
site grade is 45 feet, 45 feet above mean seawater
15
level, essentially for Chesapeake Bay there.
16
new site is I think 84, 85 feet, so it's about 40 feet
17
higher.
18
The existing unit
And the
And, essentially, it's not a once-through
19
type plant, for one.
For two, the plant has to be set
20
back 1,000 feet from the Chesapeake Bay based on
21
Maryland requirements now.
22
existing units.
23
MEMBER ARMIJO:
24
MR.
So it's up higher than the
25
FINLEY:
meteorology discussion.
Thank you.
Okay.
So that's the
Our next topic of interest is
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1
electrical power, and I'd like to introduce Jean-Luc
2
Begon, who is our Electrical and I&C Manager for
3
UniStar, to discuss that topic.
4
MR. BEGON:
Yes.
Thanks, Mark.
Yes,
5
hello.
6
UniStar and for Mark Finley for three years now.
7
Previously, I was working for EDF, both in operations
8
and engineering of pressurized water reactor.
9
I'm Jean-Luc Begon.
Jean-Luc?
I have been working for
Next slide, please.
10
I am going to give you an overview of the
11
line connecting the site to the grid.
There are three
12
500 kV lines connecting the site to the grid.
13
them on your right side are coming from the Waugh
14
Chapel Substation, which is located at the north of
15
Anne Arundel County, which is 48 miles from the site.
16
These two lines are routed on different towers but
17
share the same right-of-way.
Two of
18
And there is a third line coming from the
19
Chalk Point Substation, and this line is 18 miles away
20
from the site.
21
right-of-way this line will share the same right-of-
22
way of the Waugh Chapel lines.
23
24
And for nine miles at the end of the
MEMBER SIEBER:
So for nine miles all
three lines are on the same right-of-way.
25
MR. BEGON:
Yes.
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1
2
MEMBER SIEBER:
How far apart are they
roughly?
3
MR. BEGON:
4
MR. FINLEY:
Roughly -Certainly beyond the physical
5
-- there is physical separations from the existing
6
Waugh Chapel lines.
7
8
MEMBER SIEBER:
feet, 100 feet, one span length.
9
10
MR. FINLEY:
Yes, roughly.
In terms of,
let's say, 50 yards, something -- 50 feet?
11
MR. BEGON:
12
MEMBER SIEBER:
13
Yes, I was thinking 50
Yes, 90 feet.
I'm sure Google will tell
me.
14
MR. BEGON:
Yes.
15
MEMBER BROWN:
Let me just ask, on Jack's
16
question, the -- this is -- you are just talking about
17
towers being blown over and then hitting the other --
18
and
19
second --
taking
the
other
line
20
MEMBER SIEBER:
21
MEMBER BROWN:
out
and
losing
your
Well, or whipped -Well, I'm just trying to
22
get a handle on it, or does it consider a tower being
23
actually -- or some of the towers being -- actually
24
coming loose and then being thrown -- it seems like 50
25
yards is not a particularly large distance.
I mean,
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1
I can throw a football -- well, I can't anymore,
2
but --
3
MR. FINLEY:
I think -- Jean-Luc can
4
correct me -- but basically we consider a crumpling of
5
one set of towers and assure that we don't affect an
6
adjacent line with that crumpling.
7
there were some debris, again, as was asked before,
8
from one tower it could affect the other line.
9
for the expected way these towers would fail, we
10
shouldn't -- one line should not interact with the
11
other.
12
MEMBER BROWN:
Okay.
Certainly, if
But
So a transmission
13
line coming apart from one, there is not enough length
14
at the -- if it separates right at the tower, it won't
15
-- it can't be blown over the wires on the other
16
transmission 50 yards away?
17
are more than 50 yards apart.
18
MR. BEGON:
Gas
&
I'm presuming the towers
Yes.
Electric
In fact, we asked
19
Baltimore
about,
you
know, tower
20
failure and was it considered? Was distance made in
21
such a way when one tower collapses, it won't affect
22
the other ones.
23
tower falling on -- or its length across, you know,
24
and normally your tower will collapse and will not
25
affect the other one.
You don't have any experience of a
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1
MEMBER BROWN:
2
MR. BEGON:
All right.
But of course, as Mark said,
3
there might be some cases of a tornado or things like
4
that where it could affect more than one line, yes.
5
MEMBER BROWN:
I was just thinking of the
6
lines itself, the cables themselves, being whipped
7
over.
8
long enough to be picked up and blown over.
And depending on the distance, they would be
9
MR. FINLEY:
I can't say that in terms of
10
the design we could say if a cable part -- a conductor
11
parted
12
wouldn't affect the other lines.
13
mode of failure.
that
14
it
wouldn't
affect
MEMBER SIEBER:
the
other
--
it
That's not a normal
The chances are very low
15
that you are going to get a conductor that will, you
16
know, probabilistically speaking, contact the other
17
line some way to cause it to short out.
18
19
MR.
FINLEY:
Right.
There's a long
distance, as you know, between towers, and so --
20
MEMBER SIEBER:
21
MR. FINLEY:
-- the long distance of
22
conductor
23
separation between these lines to accommodate that
24
sort of --
25
between
The issue is the towers.
towers.
MEMBER SIEBER:
We don't have the
Right.
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1
MEMBER STETKAR:
Jean-Luc, before you
2
change this, we had quite some discussion in the
3
Subcommittee meeting about the offsite power system.
4
And just for the record, these three transmission
5
lines are the only three transmission lines that
6
supply all three units at the site, is that correct?
7
MR. BEGON:
That's correct.
8
MEMBER STETKAR:
This is the only offsite
9
power connection for all three units, not just Unit 3.
10
I asked the question at the Subcommittee meeting, and
11
you said you were going to get back to us.
12
happens if you have a catastrophic loss of power at
13
the Waugh Chapel Substation, since it is a common
14
connection point for two of the three lines to all
15
three units?
16
site?
17
What
What happens to all three units at the
MR. BEGON:
I don't have the research yet
18
we have requested following the Subcommittee -- the
19
analysis on what would be the -- what will happen to
20
the grid.
21
which is performed as part of the requirement, but I
22
don't have the result from --
23
24
And, anyway, it is part of the analysis
MEMBER STETKAR:
You still don't have
that.
25
MR. BEGON:
-- at this date.
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1
2
MEMBER
STETKAR:
question, by the way, a year ago.
3
MR. BEGON:
4
MEMBER STETKAR:
5
But we asked that
Hmm?
We asked that question a
year ago.
6
MR. FINLEY:
Yes.
But I will say that,
7
certainly the one line that would remain, separate
8
from the Waugh Chapel lines, is not designed to carry
9
the full load from the three sites.
10
a transient, as Jean-Luc said.
11
reduce power.
So we would have
We would have to
12
In fact, the EPR, the new unit is designed
13
to reduce power quickly in a load rejection like this
14
and go into what we call an island mode type of
15
operation where essentially you don't trip the reactor
16
but you reduce power, partial insertion of rods, and
17
so forth, so you rapidly reduce power, the reactor
18
would stay online, and the site would get power from
19
the turbine generator, which would be operating, you
20
know, continuously through the transient.
21
22
So that is the type of transient that we
would expect on the site.
23
MEMBER STETKAR:
24
MR. FINLEY:
25
MEMBER STETKAR:
On Unit 3.
On Unit 3, that's correct.
You would probably trip
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1
the other two units.
2
MR. FINLEY:
That's correct.
3
MEMBER SIEBER:
Is your turbine generator
4
designed to quickly run back to house load, or will it
5
trip?
6
MR. FINLEY:
7
to explain.
8
operation, which is --
9
No, that's what I attempted
So we have what we call an island mode
MEMBER SIEBER:
10
MR.
FINLEY:
Right.
-- a rapid runback on
11
reaction power, so that you don't trip the reactor.
12
The
13
essentially becomes isolated from the grid, okay?
14
you maintain power to your auxiliary loads through the
15
turbine generator, the main turbine generator, for
16
Unit 3.
turbine
17
stays
online,
MEMBER BLEY:
and
the
switchyard
So
Do you have any knowledge of
18
operational experience with plants that are designed
19
to go to the island mode when they actually have a
20
full load rejection?
21
staying online after that?
22
What is the likelihood of them
MR. FINLEY:
I personally don't.
Jean-
23
Luc, maybe you can speak of -- I know they use it in
24
France.
25
MR. BEGON:
Yes, we have experience of --
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1
operational experience.
2
tell us what has been considered in the PRA as the
3
value for the success of island mode success.
4
5
So maybe I will ask AREVA to
MEMBER BLEY:
Okay.
And the operating
base -- operating history basis for that, please.
6
MR. BEGON:
Yes.
7
MR. REINERT:
I'm Joshua Reinert from
8
AREVA.
Quick background -- I started off in the
9
Nuclear Navy on submarines as a reactor operator and
10
engineering
watch
11
University
12
engineering, and then I got a Master's Degree from
13
MIT.
14
a company called information Systems Laboratories,
15
which is based just down the street, and now I work at
16
AREVA for the last four years predominantly on the EPR
17
and the COLA PRAs.
of
supervisor.
Connecticut
I went to the
and
studied
electrical
I studied under George Apostolakis.
I worked at
18
And for this island mode, the credit that
19
we took was we reduced the grid-related failures by 68
20
percent
21
frequency, and that was based on the advanced light
22
water reactor utility requirements document.
23
to
recalculate
MEMBER BLEY:
LOOP
probability
or
LOOP
So you didn't base it on
24
operating experience.
Do you know the operating
25
experience in Europe with plants that are designed to
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1
go to the island mode when they lose offsite power
2
connection?
3
MR. FINLEY:
I don't.
We don't hear --
4
unless AREVA knows.
5
experience data do we have essentially to base that
6
number on?
7
He is asking, what operating
MR. REINERT:
Well, the number out of the
8
document that I mentioned I believe was based on
9
operating plant experience.
10
MEMBER CORRADINI:
But where?
I think
11
Dennis is asking, can you give him more information?
12
I'm sure he'll want to look at it.
13
MR. GIBSON:
14
to get that information back to you.
15
to.
16
to provide that back to the Committee.
MEMBER RAY:
We'd be pleased
We'll take an action
Is there a startup acceptance
test to do this?
19
MEMBER SIEBER:
20
MEMBER RAY:
21
MEMBER SIEBER:
22
MEMBER RAY:
23
MR. BEGON:
24
MR. FINLEY:
25
We can take an action
We believe it's in France.
17
18
Yes.
initial
test
program
What, the runback?
A full load rejection -Yes.
-- keep the unit online.
Yes, it is there.
Yes.
a
We have as part of the
plan to do a full load
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1
rejection.
2
MEMBER RAY:
3
MEMBER SIEBER:
4
MEMBER
5
Thank you.
From full load.
RAY:
About what level of
confidence did you --
6
MEMBER BLEY:
Well, it has been about
7
50/50 from what I have experienced.
8
MEMBER RAY:
9
MEMBER BLEY:
10
I understand, trust me I do.
And he's saying it's about
40/60, so -- 30/70.
11
MEMBER RAY:
We tried it at Palo Verde.
12
MEMBER BLEY:
13
MEMBER RAY:
14
(Laughter.)
15
MEMBER SIEBER:
How did that work out?
Never mind.
16
coping time is for Unit 3?
17
hours?
18
19
Is it going to be four
Eight hours?
MR. BEGON:
hours.
Do you know what the LOOP
It's going to be less than six
Less than six hours.
20
MEMBER SIEBER:
21
MR. BEGON:
22
MEMBER SIEBER:
Less than six?
Yes.
I'm interested more in,
23
what is it going to be greater than, rather than --
24
you know, 10 minutes is less than six hours.
25
MR. BEGON:
We will have to --
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1
2
MEMBER SIEBER:
plant, I take it.
3
MR. BEGON:
4
MR. FINLEY:
5
It will be a four-hour
Yes.
I think what he means is we
can cope for at least six hours.
6
MEMBER SIEBER:
7
MR. BEGON:
8
MEMBER CORRADINI:
9
to
ask,
because
I
Oh, okay.
Yes.
didn't
Just one thing I wanted
understand
--
I
don't
10
understand -- I haven't been in on the details of
11
this.
12
emergency diesel generators come online?
So when you do this island mode, do the
13
MR. FINLEY:
14
MEMBER CORRADINI:
15
No.
Just in case?
they still not called upon?
16
MR. FINLEY:
The question is:
17
diesel start?
18
a shaking of a head over there I guess.
19
20
will the
And I think, well, I don't -- there is
MEMBER BLEY:
Yes, but he shouldn't be
answering this.
21
22
Or are
MEMBER STETKAR:
I shouldn't be answering
the question, and I'm not, but --
23
(Laughter.)
24
MEMBER CORRADINI:
25
(Laughter.)
Okay, John.
Thank you.
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1
MEMBER ARMIJO:
2
MR. BEGON:
3
Yes.
Although you'd like to.
Okay.
Next slide?
The design criteria for the offsite
4
power is based on Appendix A, Part 50, and it's
5
requirement
6
transmission
7
distribution system by two physically independent
8
circuits.
is
about
network
electric
and
the
power
onsite
from
the
electric
9
And it is mentioned that its purpose is to
10
offset that, and so we consider that the proposed
11
design meets the regulatory design basis.
12
Next slide, please.
13
Yes.
There is a loss of offsite
14
frequency, which is considered in the site-specific
15
PRAs 1.7 ten powers minus two.
16
used by AREVA in the design certification model is
17
1.9.
18
bounded by the value which is considered in the U.S.
19
EPR PRA model.
And the one which is
So what we say -- the conductive Unit 3 value is
20
MEMBER STETKAR:
Jean-Luc?
Before you go
21
from that, I think we just heard that the grid-related
22
contribution to the loss of offsite power in the PRA
23
has been numerically reduced to take credit for this
24
island mode operation.
25
that account for any type of reduction, numerical
Your site-specific value, does
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1
reduction?
And, if so, what is it?
2
the 1.7E-2 per year based on?
3
MR. BEGON:
If not, what is
Yes, it does, but the loss of
4
offsite power is -- and maybe you will correct me if
5
I'm wrong, but it's combined of three things which are
6
catastrophic
7
value, and which are grid.
8
considered because of island mode is on the calculate
9
it to a grid loss.
10
conditions,
which
are
site-specific
And the value which was
So it doesn't take into account for waiver
11
condition
loss
and
for
site-specific.
12
difference mainly is related to the waiver condition
13
at Calvert, and because based on NUREG the value of
14
the site is lower than the average in the U.S. based
15
on waiver condition.
16
MR. FINLEY:
17
MEMBER STETKAR:
18
MR.
And the
And just to clarify --
HUGHES:
Based on a NUREG
I think I -- let me
19
contribute to this.
20
the next speaker.
21
of PRA for UniStar.
22
assessment since the '70s.
23
full ACRS was in 1973, so I have had many great
24
opportunities
25
predecessors and some of you.
to
If I could introduce myself, I'm
I'm Gene Hughes.
I'm the Director
I have been engaged in risk
My first meeting with the
interact
with
some
of
your
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1
And I am probably best known for founding
2
and operating ERIN Engineering for over 20 years.
3
then left and established a company called ETRANCO to
4
build on or to support the new build plants, and to be
5
more engaged in international activities, and I am
6
very proud to represent UniStar.
7
I
The value of 1.7 minus two represents the
8
total,
and
that
total
9
switchyard-centered,
comes
from
plant-centered,
grid-related,
and
weather-
10
related.
And we went through each of these and
11
compared the NUREG/CR-6890 value, looked at what had
12
been used for Calvert Cliffs, looked at the generic
13
value, and we came up with what we thought would be
14
the appropriate thing to use in the PRA for Calvert
15
Cliffs Unit 3.
16
In
the
.32
factor
a
case
of
the
grid-related,
we
17
applied
18
rejection capability.
19
analysis and is credited in it, and it's that total
20
that comes up to 1.68 minus two.
21
22
as a result of this load
So that is included in the
If you'd like, I could talk about each one
of them.
23
MEMBER BLEY:
But, Gene, just a quick
24
question.
Since Calvert has been there, there has not
25
been a loss of offsite power.
Is that true?
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1
MR. FINLEY:
We actually have a slide
2
here.
At least since 1985, which I think was the date
3
the NUREG was based on, there has not been.
4
MEMBER SIEBER:
Right.
5
MEMBER STETKAR:
Okay.
It's TJM.
That's the date of
6
the NUREG, but the plant has been there, so the plant
7
should know.
8
9
MR. FINLEY:
any.
Understand.
I'm not aware of
We haven't confirmed that prior -- the plant has
10
been operating since '73 or '74 timeframe.
11
confirmed, and we can take the action to confirm that
12
there wasn't anything prior to --
13
MEMBER STETKAR:
I have not
I always get curious
14
about plant-specific people who have plant-specific
15
operating experience relying on numbers out of a
16
NUREG.
17
MR. FINLEY:
Well, I can tell you, I went
18
to the site in '84, and since '84 we have not had loss
19
of a grid.
20
21
MEMBER STETKAR:
MEMBER BLEY:
I would have hoped that
would have been factored in.
24
25
Well, somebody there
knows, though.
22
23
Prior to that, I --
MR. HUGHES:
Go ahead.
Well, let me comment.
You
know, you have to think carefully about whether or not
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1
to use the plant-specific data.
2
by.
3
MEMBER BLEY:
4
justify it if you don't.
5
MR. HUGHES:
switchyard,
The plant is close
Yes, but you ought to
Well, the switchyard is a
6
separate
7
offsite connections are certainly the same.
8
understand your point.
9
10
and
the
MEMBER STETKAR:
connections
and
the
But I
The grid is the same, the
weather is the same, the switchyard is different.
11
MR. BEGON:
Yes.
Before we leave this
12
slide, I would just like to mention that especially
13
for event we have discussed previously, like, you
14
know, waiver condition that will blow away, you know,
15
the
16
conservative matter, we have not considered, you know,
17
any benefit.
18
are grid loss also.
19
considering, you know, the PRA value.
three
20
lines,
but
the
--
in
the
PRA,
as
a
We only considered for the ones which
So that's a conservative way of
MR. HUGHES:
If I may clarify one more
21
time -- I apologize -- the grid-related value that we
22
use for that contribution, the grid-related was taken
23
from Calvert 1 and 2, and that particular part of the
24
grid, and it was modified for this load rejection
25
capability.
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MEMBER STETKAR:
2
MR. HUGHES:
But from the NUREG.
Yes.
No, the value was
3
actually taken from Calvert 1 and 2 for that one
4
contribution.
5
MEMBER STETKAR:
6
MEMBER SHACK:
7
get their data?
Okay.
Where did Calvert 1 and 2
From the NUREG.
8
MR. HUGHES:
Probably.
9
(Laughter.)
10
MR. BEGON:
11
PRA on -- as Mark mentioned, 1985.
12
looked at Calvert Cliffs 1 and 2, and which followup
13
the PRA value compared to what has been considered.
14
And we have checked, and these values are conservative
15
compared to the update of Calvert Cliffs site since
16
1985.
Since 1985, the followup of
Since 1985, they
17
Next slide, please.
18
So what does the design criteria which has
19
been considered for the lines -- the existing lines
20
for Waugh Chapel and Chalk Point?
21
for the lines is 100 miles per hour, and for the
22
towers is 125 miles per hour.
23
So the wind speed
The ice loading, which is considered is
24
1-1/2 inch radial, and as I said before, of course,
25
there is a physical separation between the tower in
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1
such a way that when the tower collapses it won't
2
affect
3
switchyards are designed in such a way with breakers
4
that one electrical fault on the line will not affect
5
the other line.
the
6
other
About
lines.
tornadoes
And, of course, the
on
the
site,
so
the
7
tornadoes which have been reported from January 1950
8
to December 2006, there have been 12 of them, and they
9
have been in the range of F0 to F2 magnitude.
So that
10
is to say that F0 is less than 73 miles per hour, F1
11
is up to 112, and F2 is 157.
12
of these tornadoes has been estimated between 72 to
13
200 yards.
And the estimated range
14
So since 1985, we have not -- because it
15
is what we have in the report under PRA update of
16
Calvert Cliffs 1 and 2 is there have not been any loss
17
of power in the kV line event on Calvert Cliffs 1 and
18
2.
19
since 1985 for Calvert Cliffs Unit 1 and 2.
So there was no grid-related loss of offsite power
20
21
Okay.
This value for 1985 is based on a
document from Calvert Cliffs 1 and 2 for the FBI.
22
Next slide, please.
23
Summary -- so the proposed design meets
24
10
CFR
Part
50,
Appendix
A,
design
25
physical independence on the lines.
criteria
of
Calvert Cliffs
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1
Unit 3 LOOP event frequency is by the U.S. EPR PRA
2
model.
3
cope with extreme weather conditions.
4
So lines are designed with requirements to
No grid-related loss of offsite power at
5
Calvert Cliffs Unit 1 and 2 since 1985.
And as we
6
have discussed before, should a loss of offsite power
7
occur to the -- as the U.S. EPR design full load
8
rejection, but to say the plant will go back to an
9
island mode, or to say it will supply its own load,
10
and, therefore, we won't need to rely on the emergency
11
diesel generator.
12
If the island mode was to fail, we can
13
then rely on four emergency diesel generators, in
14
addition to which there are two alternate current
15
sources
16
classified emergency diesel generator.
17
18
diversified
compared
to
MEMBER SIEBER:
Okay.
You've done -- or TJM has
done all of the stability tests.
MR. FINLEY:
the
Any questions for Jean-Luc or
the rest of us regarding transmission systems?
21
22
are
MR. FINLEY:
19
20
which
Yes?
That's correct.
We've done
the stability analysis for the worst single --
23
MEMBER SIEBER:
Well, you have to run a
24
variety of them, and that's typically what system
25
operators do.
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1
2
MR. FINLEY:
Yes, yes, that has been done.
Yes.
3
MEMBER SIEBER:
And I will correct a
4
question that I made.
5
-- that whips from one transmission line to another,
6
if it contacts one conductor, it won't trip the other
7
line, because the first line will have tripped on
8
differential at the time of the break.
9
two.
10
It has to hit
The odds of it doing that and causing a short
between two phases is very small.
11
12
A single line failure between
So the only real concern in my mind, it
becomes a collapsed tower.
13
MR. FINLEY:
Understand.
And, again, as
14
we said, in terms of a collapsed tower, we have the
15
separation to accommodate that without --
16
MEMBER SIEBER:
17
MR. FINLEY:
18
MEMBER SIEBER:
19
MR. FINLEY:
I read that.
Yes.
Okay.
Okay.
Thank you.
And the third and
20
final topical area for the presentation is regarding
21
reliability
assurance,
22
Chapter 19.
And Gene Hughes, who just introduced
23
himself, will follow that topic.
24
25
MR.
confirm
the
HUGHES:
schedule.
Chapter
17,
and
PRA,
Before I start, let me
We need to conclude our
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presentation by 10, is that correct?
2
MEMBER POWERS:
3
MR. HUGHES:
I think that's fine.
Okay.
Then, I'm going to
4
pick the high points of the presentation and try to
5
communicate
6
heavily when we were together before, because for
7
those of you who were not there, I think they are
8
interesting.
some
things
that
we
discussed
pretty
9
And in the PRA area, we have incorporated
10
by reference the Calvert Cliffs or, excuse me, the EPR
11
PRA.
12
specific factors and how we address that.
So I'll go through that and look at the site-
13
In reliability assurance, I would like you
14
to just understand how the program works.
15
got a series of slides here that I will go through
16
rather rapidly to do that and to try to demonstrate
17
it.
18
And I've
This first slide points out that there is
19
an expert panel.
To date, the expert panel that we
20
have used has been AREVA.
21
support to UniStar.
22
meetings.
23
little less formal than the other two, and in the
24
future, in about a year, the meetings will continue.
25
And as they go forward, we will be using it and moving
They have provided that
They have had two and a half
The reason I called it a half is one was a
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1
it
under
2
Engineering who will be overseeing that from UniStar.
3
The expert panel is intended to bring
4
together not different organizations but different
5
capabilities and knowledge related to maintenance,
6
equipment, licensing, PRA, safety, deterministic.
7
is to get disciplines together.
8
the
9
10
auspices
of
the
MEMBER CORRADINI:
Vice
President
of
It
So when you say a
panel, you are going to have -- you have a resource
base which you will pull upon depending on topic?
11
MR. HUGHES:
12
consistent
panel
13
organizations --
of
The panel itself will be a
people
14
MEMBER CORRADINI:
15
MR. HUGHES:
representing
those
Okay.
-- operating under procedures
16
that are put in place to control how they operate with
17
minutes,
18
organization --
with
everything
19
MEMBER CORRADINI:
20
MR. HUGHES:
maintained
Okay.
as
an
Thank you.
-- that is doing this.
The
21
expert panel meeting frequency will be adjusted.
To
22
date, the effort of the expert panel has looked at
23
systems.
24
using
25
people, conclude whether the systems are in scope or
So we start off at the system level, and
deterministic
and
PRA
knowledge
from
these
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1
not.
And I will discuss how that decision is made
2
briefly.
3
But this expert panel meets, makes that
4
decision.
5
we will proceed as design is more detail, into the
6
component level to the function level.
7
separate out the things that are important to us.
8
From the system level we have done today,
There
is
interim
staff
And we will
guidance
that
9
applies to this -- ISG-18 -- and we are in accordance
10
with ISG-18, the way I have read it, and it meets all
11
of those expectations.
12
panel
13
ultimately,
14
components are important to safety as perceived in the
15
PRA, and that includes looking at risk achievement
16
worth, looking at parameters from the PRA, but it also
17
includes the knowledge of the PRA person.
and
we
when
What that means is we take the
evaluate
we
go
whether
beyond
the
the
components
system,
the
18
So having a PRA representative means that
19
we can have comments and information on more than the
20
3,000
21
represent the 50,000 or so that are in a plant.
22
take the PRA knowledge and extend it from a PRA person
23
for those things that were not modeled in detail.
components
24
25
that
are
roughly
in
a
PRA
to
So we
On the deterministic side, we look at a
series of criteria, and those criteria I have on a
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1
slide that will come up in a second.
2
show with this series of slides is how this progresses
3
from the expert panel that has the risk-significant
4
list that we are trying to develop with the criteria
5
that are shown during the course of this.
6
So if I can go to the next --
7
MEMBER STETKAR:
8
What I wanted to
Gene, in the interest of
time here, let me get a couple of questions in.
9
MR. HUGHES:
10
Yes.
MEMBER STETKAR:
Because you are not going
11
to get through all of your slides.
12
reliability assurance process to identify systems,
13
trains
14
individual failure modes in the final reliability
15
assurance list?
of
systems,
individual
16
MR. HUGHES:
17
MEMBER STETKAR:
Is the goal of the
components,
or
All of the above.
Okay.
That means -- when
18
you say "all of the above," do you mean at a level of
19
detail that I care about -- excuse me.
20
operated valve fails to open, but I don't care about
21
this motor-operated valve closes spuriously.
22
MR. HUGHES:
23
MEMBER
This motor-
That's correct.
STETKAR:
Okay.
How do you
24
reconcile that extremely fine level of detail with the
25
fact that the supporting PRA does not have adequate
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1
detail to support those conclusions, the generic PRA
2
that you have adopted?
3
MR. HUGHES:
Let me jump ahead --
4
MEMBER STETKAR:
5
MR. HUGHES:
6
MEMBER STETKAR:
Because I --
-- very quickly --- challenge you that no
7
expert panel understands risk to that level of detail
8
to differentiate between failure of a motor -- that
9
motor-operated valve to open on demand as included
10
versus spurious closure of that motor-operated valve.
11
Human beings don't think that well.
12
MR. HUGHES:
13
You've asked two questions,
I think.
14
MEMBER STETKAR:
I have asked a -- no.
If
15
you had told me that the level of your reliability
16
assurance program was going to be limited at the
17
system level or the train level, I wouldn't have asked
18
any more questions.
19
MR. HUGHES:
Okay.
Our job -- can I --
20
let me get to the right slide.
21
one.
This shows the design process.
22
one.
Go to the next one, please.
23
Okay.
Just leave it right there.
24
25
Let's go to the next
Go to the next
One more, one more.
You are absolutely correct the design
process is going forward.
You are absolutely correct
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1
procurement will be going forward.
2
program is to identify to procurement the information
3
they can use to procure the equipment, so that under
4
this program those components that are not safety-
5
related but are important to safety, as determined by
6
this
7
requirements, with special things applied to them as
8
appropriate.
panel,
are
procured
with
Our job in this
the
appropriate
9
So we have to give information from the
10
panel to procurement that they can deal with, and
11
that's at a very specific level.
12
the design goes forward is we apply the PRA that we
13
have right now -- and this PRA is fairly broad, it has
14
much less detail than we would like, but it has the
15
detail that is available in the design.
16
And so what we do as
As we go forward, that PRA will be
17
refined, and we will continue to work to make an ever-
18
increasingly plant-specific PRA.
19
shows that at the time we load fuel we are required by
20
regulation to have -- and we will have -- a plant-
21
specific PRA that is the as-to-be-operated, because we
22
have
23
consistent with as-built at the time of fuel load, and
24
also meets all of the standards in effect one year
25
prior.
no
operating
experience,
This bottom line
but
is
certainly
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So that is a much more detailed PRA than
2
we have today.
As the PRA goes forward and we get
3
increasing information, we will also be reflecting
4
increasing design detail.
5
relationship between the PRA and design.
6
exchange information, make sure we meet with system
7
engineers, we meet with the appropriate people on
8
design to have the PRA reflected.
So we have to have a
We have to
9
The PRA person has to take that knowledge
10
to the expert panel, and the expert panel really has
11
an obligation to go as far toward the function level
12
as you describe -- close, open -- as we can.
13
honesty, we won't get every component out of 50,000,
14
but we will do the best we can.
Now, in
15
And we will take systems, and we will have
16
meetings on a regular schedule and break them down
17
into the components, we will evaluate each component,
18
have an open discussion, make a decision, and document
19
the basis for it, using these questions that we have.
20
Did I answer your question?
21
MEMBER STETKAR:
Somewhat.
At the time,
22
you noted that the reliability assurance program will
23
be a basis for quality requirements when you start to
24
procure equipment, and I think that's a bit of my
25
concern.
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1
Again,
if
the
reliability
assurance
2
program at that time, which is obviously well before
3
fuel load, was developed to the level of system or
4
system
5
components
6
confidence in terms of being able to use the PRA and
7
the expert panel.
train, you know, encompassing all of the
in
that
train,
that
is
one
level
of
8
If the intent is to indeed exclude my
9
specific motor-operated valve because you haven't
10
identified all of the failure modes that might be
11
possible, but the ones that you have identified aren't
12
safety-significant, so therefore I can procure that
13
without extra quality equipment, at that point I start
14
to get a bit concerned, because that -- if you are
15
trying to be that fine and detailed in determining
16
whether certain quality attributes be applied to that
17
specific valve based on failure modes of that valve,
18
and the important -- the numerical risk importance of
19
specific failure modes, that is difficult to do.
20
MR. HUGHES:
It is.
Let me give you two
21
factors that work in our favor.
22
procurement tends to be the more significant larger
23
items that tend to be non-controversial.
24
really fall in this category.
25
One is the early
They don't
The later procurement -- I'll give you an
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1
example of something that might cut across systems --
2
a locked open valve.
A locked open valve in a system
3
could
important function to retain
4
pressure,
5
significant.
6
can provide information that locked open or locked
7
closed valves can be procured in a certain way with
8
confidence.
have
9
a
very
but
the
movement
of
the
valve
is
not
So if that affects the procurement, we
MEMBER STETKAR:
Now, that's an excellent
10
example, because how do you know that movement of that
11
valve?
12
apart is not risk-significant if the risk assessment
13
does not include that valve and that failure mode.
14
And I will guarantee you that it doesn't.
In the sense of spurious closure, falling
15
MR. HUGHES:
I guarantee you that it
16
doesn't, and I agree with you.
17
doesn't include it in the PRA is the judgment that has
18
gone
19
unlikely, and that that translates into confidence
20
that the PRA insights would be consistent with that.
into
21
the
fact
that
But the reason it
these
things
are
very
The thing about this program that is I
22
think enriching is that we not only have that PRA
23
perception brought to the meeting, but we have a
24
representative of maintenance who has experience who
25
can tell us, has this happened?
Is this something we
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1
should
be
2
correct?
worried
Or is our perception
So it's an integrated decision.
3
4
about?
MEMBER STETKAR:
your slides.
5
I'll let you go on with
We have talked enough about this.
MR. HUGHES:
Okay.
The objective of this
6
slide I think is to demonstrate again that the design
7
is evolving.
8
with the designers and get the information and try to
9
feed that into the PRA, and then feed both PRA and
10
design
11
program.
As the design evolves, we will interact
knowledge
into
the
reliability
assurance
12
The one other thing to bear in mind is, as
13
this program approaches fuel load, what we deliver out
14
of this is a package of the components, functions, the
15
information, and the requirements we have placed on
16
it, and provide it to the Maintenance Rule that is
17
then used to maintain that information and track it
18
and implement it throughout the life of the plant.
19
So the panel doesn't stop when fuel load
20
occurs.
If there are design changes, is there are
21
enhancements, if there is a revised PRA, if there are
22
new things that come to bear, the panel will continue
23
to evaluate, and components won't be taken out and
24
replaced, but information to the Maintenance Rule
25
people who can monitor will be provided.
So they have
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1
the latest and best information we can develop.
2
Let's see where we are in the slides.
Can
3
we advance?
This just shows the information -- let's
4
just roll through this series, if you would, and the
5
feedback.
And it's several slides long.
6
Okay.
7
members and the organization.
8
more slide.
9
10
This just summarizes the panel
MEMBER CORRADINI:
If we can go to -- one
Just so I understand
the panel members.
11
MR. HUGHES:
Yes.
12
MEMBER CORRADINI:
So there is going to be
13
an individual representing each of the functional
14
areas or there will be rotating individuals.
15
what I'm not clear about.
16
MR. HUGHES:
That's
I'm sorry.
Generally, we will have an
17
individual who will be trained and who will be the
18
person representing operations in these decisions.
19
MEMBER CORRADINI:
20
MR. HUGHES:
21
It will change from time to
MEMBER CORRADINI:
Yes, yes.
They're
allowed to do other things once in a while.
24
25
Thank you.
time.
22
23
Okay.
MR. HUGHES:
Yes.
This shows six people.
It will be a procedure that will be put together that
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will specify the exact makeup.
2
MEMBER CORRADINI:
3
MR. HUGHES:
4
The next slide?
5
Just
for
Okay.
And it may deviate a little.
information,
these
are
the
6
criteria for the deterministic ranking, and it's the
7
impact of the failure or the impact of what the thing
8
does.
9
that.
So let's go to the next one.
That completes
10
The thing I want to communicate with just
11
a few more minutes is that the PRA we have for Calvert
12
Cliffs is incorporated by reference from the EPR PRA.
13
It is in fact one and the same.
14
several pie charts that reflect the EPR PRA.
15
the core damage frequency, the at-power portion versus
16
in this case fire and flood, and those values we
17
looked
18
appropriate to be used for Calvert Cliffs.
at
to
determine
whether
This is one of
or
not
It shows
they
are
19
So we looked at departures, we looked at
20
plant-unique features, we looked at the site, and we
21
determined case by case that we were in fact bounded
22
by and could incorporate by reference the existing
23
PRA.
24
knew I wouldn't have time to get through them, but
25
it's all there.
There is a whole series of pie charts, but I
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1
2
MEMBER RAY: Loss of offsite power, Gene,
includes station blackout, SBO?
3
4
MR.
HUGHES:
Loss of offsite power
includes station blackout.
5
MEMBER RAY:
Yes, okay.
6
MEMBER BLEY:
And so what you did for
7
things that are in fact going to be plant-specific,
8
like the ultimate heat sink connection, is you just
9
showed that from what you know of the design that is
10
bounded by what is in --
11
MR. HUGHES:
That's correct.
12
MEMBER BLEY:
13
MR. HUGHES:
14
think coming up that says just that.
15
MEMBER BLEY:
16
MR. HUGHES:
-- the design -In fact, there is a slide I
I'll wait for that.
Let's go to the next one.
17
Here are the features.
18
power, and we compared the different contributors and
19
evaluated them.
20
capacity -- it says adequate capacity for 72 hours,
21
but what we really have is six days if we use a PRA
22
realistic basis.
23
We looked at loss of offsite
The ultimate heat sink makeup water
This is the design basis.
The circulating
24
water system was evaluated.
The raw water system
25
includes the essential service water makeup.
We
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looked at what the assumptions were in the PRA and
2
concluded that we were okay.
3
The sewage water system, security, central
4
gas distribution, they were either not in the PRA, or
5
I'll cover the gas distribution in a second, and
6
potable water is not.
7
Can we go to the next one?
Which I think
8
-- let me switch, because of my glasses, to my copy
9
which I can see better than that.
10
I thought there would be some interest in
11
what the external event risk was.
So we made sure
12
that we included a summary of that, and this slide
13
shows the external contributors and how we viewed
14
them.
15
cover a lot, so let me just cover one thing.
And you'll notice that in -- I guess I can't
16
We were asked because of the metrics issue
17
that has been around to evaluate the risk in terms of
18
as a comparison to our baseline risk that I showed in
19
the pie chart for screening, and we chose not to adopt
20
a numerical relationship.
21
But as we evaluated the ones that we
22
screened, we did compare them to both the criteria for
23
screening, 10-7 or six, and we also compared to the
24
baseline CDF.
25
was low or exceedingly low, and so we felt very
And in all cases we found that the risk
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1
comfortable screening them.
2
In most cases, if I can just broadly
3
summarize, we have a good site.
4
is
5
flooding and those sorts of things, the dominant flood
6
contributor really comes from -- or the closest that
7
we
8
inundation, the rain, and we still have several feet
9
of margin in that case.
high,
can
it's
get
10
got
to
good
the
We have a site that
elevations.
elevation
is
Looking at
from
just
an
Looking at the other cases, the offsite
11
hazards, they are not close by.
12
distance
13
pipeline.
to
rail,
the
distance
They are not close.
14
MEMBER BLEY:
15
MR. HUGHES:
We evaluated the
to
natural
gas
And so --
Naval Air Station.
The Naval Air Station was not
16
specifically evaluated, but AREVA did look at air
17
travel
18
aircraft going near the station and used that to
19
determine what the value was.
in
20
21
the
area
and
looked
Josh Reinert is here.
at
the
number
of
Do you want to add
to that, or is that -- is that good enough?
22
MEMBER BLEY:
are
activities
I was specifically asking if
23
there
from
the Naval Air Station
24
flights -- and I don't know if they are even still
25
operating down there -- that might be different than
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the commercial air.
2
MR. REINERT:
Naval
3
the
4
expansive analysis of airplane crash.
5
remember if the take off and landing frequency from
6
that Naval Air Station was specifically included.
7
the presence of that Air Station required us to do a
8
lot more analysis.
9
Air
Station
I believe the presence of
MEMBER BLEY:
required
us
to
do
a
more
I just don't
But
Flight tests and things like
10
that that might be very different than we think about
11
for normal aircraft?
12
And did you think about that?
MR. REINERT:
We didn't look at -- we
13
didn't look at specifically what kind of operations
14
they would be doing at that specific air station.
15
MEMBER BLEY:
Okay.
16
MR. REINERT:
But we have to -- we have to
17
include a frequency based on the type of aircraft.
18
And I believe that aircraft from there would fall
19
under military craft, and then we used a generic crash
20
frequency based on military aircraft.
21
MEMBER BLEY:
I think by the time you get
22
to the end of the picture Gene showed you ought to
23
think pretty hard about what is going on over there
24
and how it affects you.
25
MEMBER STETKAR:
Two quick things.
And I
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agree,
looking
at
military
2
interesting, if you actually look at them.
3
did a seismic margins analysis.
4
seismic risk, is that correct?
5
MR. HUGHES:
6
MEMBER
activities
is
pretty
You only
You didn't quantify
That's correct.
STETKAR:
Okay.
One of the
7
interesting things is, on this slide, the third item
8
down is tornadoes, and it says that it is screened at
9
a core damage frequency of 5.4 times 10-8 per year.
10
I notice from your Slide Number 43 that that is a
11
little more than 10 percent -- 10 percent -- of the
12
total core damage frequency from everything else that
13
you did quantify.
14
Very few of the other contributors are
15
nearly as large as 10 percent, so it's curious that
16
you screen out something that could be as large as 10
17
percent of the total when you do quantify things that
18
are as small as one percent of the total.
19
explain why that is done?
20
MR. HUGHES:
Can you
There are two pieces to that.
21
One is quantification, and one is how you characterize
22
it.
23
you do?
24
look at the return interval of a tornado sufficient to
25
cause damage to the stuff and the equipment onsite
Do you screen it, or do you add it, or what do
The quantification process for tornado was to
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1
that is not designed to meet the highest requirements
2
of safety-related structures and those items.
3
We took the ultimate heat sink and other
4
things and destroyed them or assumed they were not
5
available.
6
was above 95 miles per hour, or a wind speed that
7
high, and we then calculated this value of 5.4 minus
8
8.
We used the frequency of the tornado that
9
It was our judgment that if we were to do
10
something more rigorous we might get a lower value,
11
and that was sort of a crude -- if you'll forgive me
12
for saying that -- way of getting a conservative
13
estimate of where it might be, and it led us to
14
conclude
15
significant contributor.
that
16
we
did
not
think
that it was a
We did not -- but I want to emphasize, we
17
did not apply a 10 percent criterion.
18
the value and said, "Is it low relative to it?"
19
in this case something on the order of 10 percent.
20
MEMBER
STETKAR:
We looked at
And
Well, but you've
21
explicitly, in your nice pie chart here, you have
22
explicitly
23
depending on however I understand this, at 5.3 times
24
10-9.
25
you spent -- somebody spent resources to do that, and
quantified
things
that
contribute,
You have explicitly quantified that.
I mean,
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1
you have made judgments that something that could be
2
a couple of orders -- one order of magnitude higher
3
than that is probably not significant.
4
MR.
HUGHES:
Well, the pie chart
5
represents the solution of the internal events PRA,
6
which includes many events at even lower frequency
7
than shown on the chart.
8
MEMBER STETKAR:
My question is:
does it
9
make sense to just summarily exclude something without
10
actually quantifying it through the model when there
11
is
12
consequences could be measurable?
13
We're running out of time.
14
discussion here, but I think we've made the point for
15
the record.
evidence
16
that
the
MR. HUGHES:
impact
frequency
We can get into a long
That completes the items I
think, in the light of time.
18
if you would like, but I'm past my point.
20
the
That's enough.
17
19
and
MEMBER STETKAR:
I'd be happy to continue
Any other questions to
pose of this --
21
MEMBER BLEY:
Well, just one quick one
22
from me, Gene.
23
continue and start refining the PRA?
24
that begin?
25
Have you got a plan for how you
MR. HUGHES:
And when does
We have a plan, and the plan
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1
involves significant interaction with EDF, interaction
2
with AREVA.
3
Vincent Sorel is here, who is my boss at UniStar, and
4
he previously was at EDF, and we have access to and
5
information exchange with them.
6
We've got the work that has been done.
We plan to proceed with a much more
7
detailed PRA, plant-specific.
8
answer is when we will begin that in earnest, and I
9
would
10
refer
to
The question I cannot
Mr. Gibson if -- how would you
characterize it?
11
MR. GIBSON:
That is a budget question,
12
and it was originally our plan in the fourth quarter
13
to start toward an 18-month to two-year effort to
14
develop a full scope internal/external Level 2 PRA.
15
Again, we are leveraging EDF, which by the way does
16
have the largest equipment reliability database in the
17
world, it's my understanding.
18
a Level 1 EDF PRA.
19
And that we also have
They also have a fire PRA which is
20
extremely interesting to us, and we have had several
21
meetings with them.
22
Nuclear Build, NNB, the EDF subsidiary, and British
23
Energy.
24
help me, Gene.
25
EDF I believe is the only one who has a --
And we are also working with New
And we will also be working with the -- now
It's the spent fuel pool PRA, which
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MR. HUGHES:
Yes.
2
MR. GIBSON:
-- spent fuel pool PRA -- to
3
leverage all of these opportunities to make an EDF EPR
4
generic PRA that will then also be used with site-
5
specific information for Calvert, so that we have a
6
state-of-the-art 1.200, peer reviewed, full compliant,
7
within about two to three years.
8
MEMBER BLEY:
9
MEMBER POWERS:
10
Okay.
Thanks.
Any other questions you
would like to pose to the applicant in this case?
11
(No response.)
12
Well, thank you very much.
13
The
staff
will
now
summarize
the
14
evaluations they have done and where they stand on the
15
continued
16
particularly the open items that remain.
examination
of
these
chapters,
and
17
Surinder, the floor is yours.
18
MR. ARORA:
19
Just continuing the review strategy that
Yes, sir.
Thank you.
20
I was discussing before I handed it over to Mr.
21
Gibson, I would like to add just a couple of things to
22
that.
23
When we bring the Chapter 2 SER -- when we
24
say that it's ready for review, we make sure that all
25
of the issues that were identified during the review
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1
are either closed out or we have a path forward, we
2
have identified an open item, and we have a path
3
forward to resolve that.
4
to add.
5
So that is one item I wanted
And during the review, staff uses our
6
electronic
RAI system to send questions to the
7
applicant, and also uses teleconferences or public
8
meetings to request the information or discuss the
9
information that has been provided by the applicant.
10
And we also go for audits sometimes to
11
review
the supporting information.
12
included
13
referenced.
14
of documentation, so that's another effort by staff to
15
make
16
application.
in
sure
17
the
application.
That is not
However, it is
So we go for audits and look at that kind
that
we
perform
good
review
on
the
With that, I will quickly go over --
18
provide an overview, chapter by chapter, where we are
19
in the review phase, and I have a team of technical
20
experts here with me.
21
specific question where I need help, I will refer it
22
to them at that time.
23
In case the Committee has a
So let's start with Chapter 2 first.
And
24
as indicated on the slide, most of the questions in
25
this case were in the meteorological area.
The number
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1
of questions looks large, but at the end all of them
2
were resolved to the satisfaction of the technical
3
staff.
Only two items were identified as open items.
4
And one open item was to do with the
5
effect of nearby tree line on the meteorological
6
monitoring program, and the second was to get a
7
description of the departure from the site temperature
8
parameter for the ultimate heat sink.
9
only two open items which are identified.
Those were the
10
And also, to give some idea of the staff's
11
initiatives during this review, I would give a couple
12
of examples where staff used verifications on the
13
information that was provided by the applicant in the
14
application.
15
weather phenomena described by the applicant, the
16
staff used the severe weather database published by
17
NOAA and the Southeast Regional Climate Center.
18
To verify the descriptions of the severe
The
applicant
provided
short-term
19
atmospheric dispersion parameters' values using the
20
proprietary
21
independently verified by staff by using the NRC code
22
FALON.
23
we performed the independent reviews on this chapter.
24
And right now, the chapter, even though it
25
is partial, we are working on closing the open items,
computer
code
AEOLUS3,
which
were
So that was just to give you examples of where
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1
and we are in Phase 4 at this time.
2
Chapter
4
is
totally
IBR
chapter
3
incorporated by reference.
4
of the EPR sections which were referenced in the COLA
5
application.
6
7
So this involved a review
MEMBER ARMIJO:
Is the fuel open item --
is that the M5 cladding exemption issue?
8
MR. ARORA:
9
was going to say that.
Yes.
10
MEMBER ARMIJO:
11
MR. ARORA:
That's what it is.
I
Okay.
There were two RAIs, and there
12
are two open items.
The first open item tracks the
13
status of exemption requests in COLA Part 7 for use of
14
M5 material for the fuel rod cladding.
15
MEMBER ARMIJO:
16
MR. ARORA:
Okay.
The exemption request was not
17
referenced in the FSAR, and the RAI requested that the
18
exemption request be added to that FSAR.
19
the exemption section but not described in the FSAR.
20
So the RAI was issued to make sure that there is
21
consistency between the two.
22
It was in
The second open item, Section 4.3, tracks
23
the
need
for
COL
applicant
to
address
the
COL
24
information item, which was yet to be added by AREVA.
25
So there was an RAI for AREVA to add a COL action item
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1
at that time, and applicant committed to incorporating
2
that when that gets into the AREVA FSAR.
3
the only two open items on Chapter 4.
Those are
4
Chapter 5 review was performed by several
5
technical reviewers in the Component Integrity Branch
6
and
7
Plant.
8
the technical branches to review this section.
Engineering
Mechanics
Branch,
Balance
of
the
So there was a lot of coordination in between
9
There are several sections which are IBR
10
with
no
departures.
There are sections where
11
supplemental information has been provided.
12
supplemental information was reviewed by the technical
13
reviewers in their areas of expertise.
14
28 total questions which were issued to the applicant
15
requesting additional information.
So the
And there were
16
And, finally, 25 of 28 were resolved,
17
closed, and there were only three open items left.
18
One of the open items in 5.2 Section, the staff
19
requested that COL applicant address the procedures
20
for alarm setpoints to the COL FSAR.
21
Another open item in 5.2 Section, staff
22
requested
COL
applicant
23
alarmed low level leakage.
to
provide
procedure
for
24
The third and the last open item in this
25
chapter is in 5.3 Section, and the COL applicant was
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1
to modify FSAR Table 13.4-1 to include Section 5.4.2
2
under the pre-service inspection program.
3
didn't have this item listed, so the RAI requested
4
that they will be revised.
5
the three items have been responded to, and are ready
6
to be closed.
7
8
MEMBER BLEY:
And as of today, all of
That means you have been
through them, your --
9
MR. ARORA:
10
11
That table
MEMBER
Pardon?
BLEY:
You have reviewed them
already?
12
MR. ARORA:
13
MEMBER BLEY:
14
MR. ARORA:
15
Chapter
8,
Yes, sir.
Okay.
Staff has reviewed them.
when
we
brought
to
the
16
Subcommittee last time, there was no open item on it.
17
There was one departure, however, which was identified
18
from the EPR design certification application.
19
departure has been later on been -- it has been
20
removed, and it does not apply to the COL application.
21
And the departure pertained to the number
22
of cooling fans that Calvert Cliffs application had
23
versus the number of cooling fans for the cooling
24
tower
25
AREVA's application had a higher number, and Calvert
actually,
that
AREVA's
application
That
had
--
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had 48 fans.
2
fans was the same, if you add up, multiply it by the
3
horsepower of each fan.
4
Cliffs was using were of larger capacity.
5
However, the total horsepower for these
So the fans which Calvert
However, this particular item in the later
6
revision of BC application has become a conceptual
7
design item in which case Calvert Cliffs can have
8
their own design.
9
which was previously identified.
10
And it is no longer a departure,
So the chapter is
all clear.
11
MEMBER STETKAR:
Surinder, we had some
12
discussion that -- and I asked the applicant this
13
previously to you.
14
Subcommittee meeting about this notion that Units 1
15
and 2 are licensed with a total of three offsite power
16
transmission lines connecting --
We had some discussion at the
17
MR. ARORA:
Right.
18
MEMBER STETKAR:
-- to the site that share
19
the same right-of-way for at least 12 miles.
And now
20
they have added a third unit to the site with the same
21
three transmission lines.
22
staff become concerned regarding the number of offsite
23
transmission lines?
At what point does the
24
Suppose I add a fourth unit to the site or
25
a fifth unit or a sixth unit, at what point does three
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become not enough, considering that each unit is
2
supposed to have two --
3
MR. ARORA:
Okay.
4
MEMBER STETKAR:
-- supplies?
So already
5
I'm not sure how three supply three with each having
6
two, but --
7
8
MR.
Not being the technical
reviewer, I will refer the question to Mr. Kang.
9
10
ARORA:
Peter Kang, could you please address the
question?
11
MR. KANG:
My name is Peter Kang, and I am
12
from Electrical Engineering Branch.
And that is a --
13
that question is hard to answer.
To begin with,
14
originally, one unit, you've got to have two offsite
15
lines.
16
Calvert Cliffs.
17
know.
18
capacity.
Two units, we have three offsite lines for
Okay?
And the fourth unit, I don't
To begin with, we have to see the line
19
The reason for Calvert Cliffs, they use
20
three units with three offsite lines is justified
21
because Unit 1 and 2, as they are considered as --
22
even
23
considered as -- can be considered as offsite lines
24
now.
25
It's -- and the 1 and 2 are going to have three
though
they
are
one
mile
apart,
they
are
So Unit 3 is going to have four offsite lines.
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1
offsite lines help form Unit 3.
2
So it's hard to answer the question, and
3
we have to see the overall, like some other plants
4
like six units or seven units onsite probably we might
5
need a lot more than three offsite lines or six
6
offsite lines or 12 offsite lines.
7
MEMBER CORRADINI:
8
(Laughter.)
9
MR. KANG:
I don't know.
Let me ask --
That is Dr. Stetkar's question.
10
So we've got to look at each line's capacity, and what
11
is the requirements for the plant, and you have to
12
postulate a combination of which unit is on, which
13
unit is off, and all of these combinations.
14
MEMBER BLEY:
Let me ask John's question
15
in a little different way.
16
offsite lines has to do with the availability of power
17
and independence of supplies.
18
running on the same right-of-way begin not to be
19
considered independent sources?
20
21
MR. KANG:
The need for multiple
At what point do lines
I don't know.
I'm -- this is
a very plant -- very site-specific and --
22
MEMBER BLEY:
But right now we are happy
23
with all three running nine miles on the same right-
24
of-way.
25
MR. KANG:
Three nine miles?
Three --
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1
yes, from Chalk Point it's going on first three nine
2
miles.
3
same right-of-way.
So we have three offsite lines running in the
4
MEMBER BLEY:
5
MR. KANG:
6
MEMBER BLEY:
7
MR. KANG:
8
weather-related
9
offsite lines.
So vulnerable to some --
It is.
-- local event.
It is.
impact,
it
Like if you have some
might
lose
all
three
And we have all this -- number one, we
10
have island mode operations, and number two we have
11
emergency diesel generators.
12
of the emergency diesel generators.
13
the emergency diesel generators, then we have diesels
14
on a site.
15
MEMBER STETKAR:
16
MR. KANG:
17
MEMBER
That's what is for all
And if we lose
Let me ask you --
Yes.
STETKAR:
-- suppose I had a
18
single-unit site -- four trains, four emergency diesel
19
generators.
20
site require two offsite power transmission lines,
21
despite the fact that it's got four independent diesel
22
generators, and maybe it can also go to island mode.
Would the licensing requirements for that
23
MR. KANG:
24
MEMBER STETKAR:
25
Yes.
So if I was to take the
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1
MR. KANG:
2
MEMBER STETKAR:
3
Nowhere, yes.
-- wherever, by itself as
a single unit, you would still require two --
4
MR. KANG:
Offsite lines.
5
MEMBER STETKAR:
-- independent offsite
6
power lines for that single unit.
7
MR. KANG:
8
MEMBER STETKAR:
9
MR. KANG:
10
Yes, sir.
Okay.
Okay.
MEMBER CORRADINI:
So the island mode is
11
what is giving you confidence you can live with what's
12
there?
13
MR. KANG:
Well, that is --
14
MEMBER CORRADINI:
I'm looking for an
15
answer that, if it weren't the rest of us, that
16
somebody
17
because so far I don't understand anything.
in
the
general
public
18
MR. KANG:
Okay.
19
MEMBER CORRADINI:
20
MR. KANG:
would
understand,
We just -We couldn't be blunt.
Yes, and we do -- well, that is
21
considered as another offsite line and a power source.
22
It could be used for emergencies or a planned plant
23
shutdown.
24
25
MEMBER CORRADINI:
So it's the unique
features of this third unit that gives you confidence
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1
that
you can live with the current transmission
2
capability.
3
MR. KANG:
Well, that's what I have been
4
saying -- seeing.
5
was just -- when the new unit is added in there, what
6
they do is existing transmission lines, then they LOOP
7
into new plants, which connect older units and the new
8
units together, and they treat it as another offsite
9
lines.
10
11
All the plants so far I've seen it
MEMBER CORRADINI:
I understand.
12
Okay.
Fine.
I think
Thank you.
MEMBER
SIEBER:
Maybe I could add
13
additional confusion.
I worked at a site that had six
14
units, three nuclear units, three supercritical coal-
15
fired units.
16
was considered adequate by the NRC.
17
the adequacy by running stability studies with a lot
18
of combinations of unit outages, unit trips, system
19
trips, line trips, and right-of-way conflicts.
It had five transmission lines, which
And you improve
20
And it becomes very complicated, but what
21
really counts is the probability that you will enter
22
into a LOOP, which is an abnormal operating condition,
23
as opposed to a design basis accident.
24
get complicated with multiple units.
25
MEMBER POWERS:
And so it can
Please continue.
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1
MR. ARORA:
Thanks, Peter.
2
Next, we move on to Chapter 10.
There
3
were two technical branches who were involved in the
4
review -- the Balance of the Plant Branch and the
5
Component Integrity Branch.
6
RAIs issued to request additional information, and all
7
responses were adequate, and only one open item was
8
identified.
There were a total of 11
9
The open item related to flood analysis of
10
the turbine building resulting from a failure of the
11
circ water piping inside the turbine building.
12
applicant's response is currently being reviewed.
13
Applicant has already answered the RAI, and staff is
14
currently
15
response was adequate.
16
closed or a supplementary RAI will be issued to get
17
more information, if needed.
reviewing
18
Next,
the
The
response to see if the
And either the item will be
Chapter
11,
radioactive
waste
19
management.
20
Branch, Siting and Accident Consequences Branch.
21
part
22
independently confirmed whether the applicant complied
23
with the dose limits to the members of the public
24
under Part 20.1301 and 20.1302.
25
confirmed liquid and gaseous effluents concentration
of
the
The branches involved were Health Physics
review
of
this
chapter,
the
As
staff
And then, it also
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1
limits
of
Part
20,
Appendix
B,
and
Part
50,
2
Appendix I, the design objectives and ALARA provisions
3
were met.
4
A total of 11 questions were sent to the
5
applicant requesting additional information, and there
6
were two supplementary questions which were issued
7
during the Phase 4 review, which were riding on the
8
previous questions actually.
9
been received, and the staff is in the process of
10
reviewing those responses, either to close the items
11
or see if we need to have more information from the
12
applicant.
13
All the responses have
Chapter 12, radiation protection, the lead
14
review branch for this Chapter is Health Physics
15
Branch, and a total of 16 questions in this case
16
requesting additional information were issued to the
17
applicant.
18
And there were four open items that were
19
identified at the end, and some of the open items were
20
very
21
correctly stated, and a couple of typos.
minor
22
in
One
nature,
item
like
asked
the
to
units
correct
were
not
conversion
23
between the units, identify the piping that could
24
potentially become contaminated.
25
open item.
That was another RAI
And the third open item was describe
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1
design
features
and/or
monitoring
of
the
vacuum
2
breakers to demonstrate compliance to 10 CFR 20.1406.
3
All responses have been received, and
4
staff has reviewed most of them.
5
open items are in the process of being closed.
6
Chapter
16
pertains
And right now the
to
the
technical
7
specifications, and there were 22 questions which were
8
initially asked.
9
on the review of AREVA design and the Part 4 of the
10
application,
11
specification.
12
Actually, these questions are based
which
pertains
to
the
technical
And all of the questions were resolved,
13
closed, except for one, which is to do with the
14
details of the setpoint program, setpoint control
15
program.
16
right now staff is working with the applicant to
17
finalize the details that they would like to see in
18
the setpoint control program.
And that is the only question remaining, and
19
Chapter
17,
assurance
and
20
reliability
21
Branch was the lead reviewer, and QA Branch was in the
22
supporting role to review the application.
23
assurance.
quality
PRA and Severe Accidents
In all, there were about -- there were 18
24
questions initially, and one was issued during the
25
Phase 4 in the closure process, so a total of 19
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1
questions asked, and there are 10 questions which are
2
showing currently open on the slide.
3
are four items which staff is ready to be closing
4
them.
5
provided
6
questions.
However, there
They will be closed because the applicant has
adequate
information
in
response
to
the
7
And there is a supplementary RAI, which is
8
being drafted to address the other three questions on
9
Section 17.4.
Four will be closed; three will be
10
addressed in the supplementary RAI which is being
11
drafted currently.
12
The QA program under 17.5 Section, which
13
was reviewed by the applicant and resubmitted, is in
14
review under a topical report.
15
staff is reviewing that section to close that last one
16
item.
17
Chapter
--
had
of
25
information from the applicant.
20
open items which are currently being reviewed.
21
the responses are in, and staff is reviewing those
22
seven items to see if we can close those items.
24
the
for
total
19
was
issued
a
questions,
That
were
we
18
23
which
19
And currently the
additional
And there are seven
last
chapter
All of
for
my
presentation.
25
MEMBER
POWERS:
Any questions to the
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1
speaker?
2
(No response.)
3
Well, this concludes the presentation of
4
these particular subset of chapters.
We are roughly
5
halfway through this process, I believe now.
6
Again, the Subcommittee will come back to
7
look at the chapters where items -- to look at the
8
resolution
9
intention is we are moving on a pathway to complete
of
final
process
both
the
and
what
COLA
not.
and
The
10
this
11
certification in roughly July of 2012.
12
say is that it is progressing very well, and we are
13
getting high quality presentations across the board
14
from both staff and the applicants throughout this.
15
for
items,
the
EPR
And all I can
One of the effective mechanisms we have
16
been
able
17
particularly
18
certification, has gone and looked at details when we
19
needed to look at details on particular items, and
20
continually we are offered that opportunity at every
21
turn in the process.
22
horizon right now for this process.
23
24
to
take
advantage of is actually
John is -- in connection with the
So I have no clouds on the
With that, I will turn it back to you, Mr.
Chairman.
25
CHAIRMAN ABDEL-KHALIK:
Thank you.
At
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1
this time, we are scheduled to take a 15-minute break,
2
following which we will have a briefing on the events
3
at the Fukushima reactor site in Japan.
4
take a 15-minute break.
5
10 minutes to 10.
So we will
We will reconvene at exactly
6
(Whereupon,
7
foregoing matter went off the record at
8
10:35 a.m. and went back on the record at
9
10:49 a.m.)
10
11
the
proceedings
CHAIRMAN ABDEL-KHALIK:
in
the
We're back in
session.
12
We will now move to the next item on the
13
agenda, a briefing from the NRC staff on the status of
14
the response to the events at the Fukushima Daiichi
15
Nuclear Power Plant following the tragic earthquake
16
and tsunami in Japan.
17
This briefing will serve as the initiation
18
of
significant
19
activities and lessons learned from the Fukushima
20
event in order to maintain public health and safety in
21
the
22
Subcommittee of the whole devoted to these activities,
23
and plans to have regular engagement with the NRC task
24
force evaluating the agency's response, as well as
25
other stakeholders, as appropriate, to gain additional
United
ACRS
States.
engagement
on
the
followup
The ACRS will have a new
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1
perspectives.
2
In accordance with the recently issued
3
Commission
Tasking
Memorandum,
the
ACRS
has
been
4
formally tasked by the Commission to review the report
5
developed by the staff as part of the staff's longer
6
term review.
7
effort in a separate ACRS letter report later this
8
year.
We will provide our evaluation of that
9
The Commission tasking for ACRS on the
10
subject of Fukushima is thus far specific to the
11
evaluation
12
However, the ACRS, consistent with its charter, will
13
self-initiate activities to be appropriately informed
14
and properly prepared to provide the best possible
15
advice to the Commission on an ongoing basis.
of
the
staff's
longer
term
review.
16
Before we begin the briefing, I would like
17
to call for a moment of silence to honor victims of
18
the Japanese tragedy and to serve as a reminder to all
19
of us that nuclear technology is unique, requiring our
20
total, absolute, and unwavering commitment to nuclear
21
safety,
22
integrity.
public
transparency,
a
and
23
(Whereupon,
moment
24
observed.)
25
CHAIRMAN ABDEL-KHALIK:
of
professional
silence
Thank you.
was
At
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1
this time, I would like to call on Mr. Ruland to begin
2
the NRC presentation.
3
MR. RULAND:
Thank you, and good morning,
4
Mr. Chairman, and members of the Advisory Committee on
5
Reactor Safeguards.
6
The staff has prepared a briefing on the
7
Fukushima events and some of the early implications of
8
those events.
9
which led to the core and -- which led to core and
10
spent fuel damage, is a significant tragedy for the
11
people of Japan.
12
those affected by this event.
The earthquake and subsequent tsunami,
Our sympathy goes out to all of
13
While somewhat removed from the suffering
14
of the Japanese themselves, nevertheless, the NRC
15
staff, as nuclear safety professionals, feel the loss
16
personally.
17
learning the right lessons from this event.
18
end, we will briefly outline the event only to the
19
extent that it points to areas we will need to examine
20
for
21
regulations.
22
highlights of some of the regulatory areas to be
23
reviewed.
possible
24
25
What we can do, however, is to focus on
enhancements
or
improvements
To that
in
our
We will follow that discussion with
We will try to answer any questions you
may have.
However, since the event is still ongoing,
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1
and much of the detailed information is not available,
2
or not easily confirmed, the implications for U.S.
3
plants will unfold in the weeks and months ahead.
4
Still, based on the information already available, and
5
as directed by the Commission, the staff has launched
6
the task force that you have already mentioned that we
7
will touch on briefly.
8
At a high level, we will be sure to pass
9
along to the task force issues that may be raised at
10
this meeting, or we will get back to you with an
11
answer if we can.
So let us begin.
12
Let me just briefly go over the agenda.
13
As you can see, there is a number of staff that are
14
going to be presenting their topics.
15
try to keep it -- make it quick, kind of march through
16
this promptly, because we know we have only two hours.
17
Again, the notion here is for us to just
18
touch on the areas that the staff is going to consider
19
or that has implications for our regulations.
20
by no means a comprehensive list, particularly given,
21
you know, the timing of this briefing.
22
23
This is
So with that, I would ask John Thorp to
start us off with the sequence of events.
24
25
We are going to
MR.
morning.
THORP:
Thank you, Bill.
Good
On March 11, 2011, at 2:46 p.m. Japan
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1
Standard Time, a magnitude 9.0 earthquake struck off
2
the coast -- the eastern coast of Japan.
3
the U.S. Geological Survey, this earthquake was the
4
fourth largest in the world since 1900 and was the
5
largest ever recorded in Japan.
6
According to
The earthquake resulted in a tsunami that
7
reportedly
exceeded
8
locations,
as
9
Industrial
and
32
feet
reported
by
Safety
in
the
height
Japanese
Agency,
our
in
Nuclear
counterpart
10
regulatory agency in Japan.
11
report on the height of the tsunami.
12
a range of wave heights reported in this event.
13
Next slide.
14
MEMBER POWERS:
some
And note, this is one
There have been
Do we know anything about
15
the seismicity of this particular area of Japan, so
16
that we -- I mean, it says it's the fourth largest
17
since 1900.
18
this part of the plant comparable to what we use for
19
the eastern United States?
20
But do we have a seismic hazard curve for
MR. THORP:
I don't have an answer for you
21
on that, but I believe that some of our staff will be
22
addressing seismic issues a little bit later in the
23
presentation, and they should be able to touch on
24
that.
25
MR. RULAND:
Dana, I couldn't hear the
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1
question.
2
3
I'm sorry.
MR. THORP:
History of seismicity in that
area.
4
MEMBER POWERS:
Do we have an equivalent
5
of a seismic hazard curve of the types that we have
6
generated for central and eastern United States?
7
8
MR. RULAND:
I think we will be able to at
least touch on the answer to that question.
9
MEMBER CORRADINI:
But just to follow up
10
Dana's question, though, but if you can't touch on it
11
today, I assume within the task force report that
12
would be something that we expect to see there.
13
MEMBER POWERS:
Well, one of the things
14
that I found remarkable in the 2006 earthquake was the
15
understanding of the details of seismicity in a more
16
northerly part of Japan was not as detailed as I would
17
have expected.
18
here.
19
I wonder if it's a similar situation
MR. RULAND:
If we could -- we will have
20
a presentation on seismicity, so if we could kind of
21
move on.
22
so we can kind of go through this.
23
MR. THORP:
And if you don't mind, hold those questions,
Okay.
Thank you.
Four nuclear power
24
stations were actually affected by this earthquake.
25
At Onagawa, the northernmost affected site, all three
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1
units scrammed and are currently in cold shutdown.
2
The single unit at Tokai, the southernmost affected
3
site, also scrammed, and it is in cold shutdown.
4
The
operating
Fukushima
Daiichi
and
5
Fukushima Daini plants successfully scrammed after the
6
earthquake.
7
in a loss of heat sink at the Fukushima Daini, ichi
8
being one, ni being two, so this is the number two
9
station that I'm referring to now.
10
However, the subsequent tsunami resulted
This was categorized as an INES Level 3 or
11
serious incident.
12
eventually
13
pumps, but not before suppression pool temperatures
14
reached
15
declaration of an emergency action level and Japanese
16
officials ordering an evacuation of residents within
17
10 kilometers of the site.
18
reactors are currently in cold shutdown and stable.
able
The Fukushima Daini operator was
to
saturation
restore
operation
conditions,
of
seawater
necessitating
the
The Fukushima Daini
19
Now, the information that I will present
20
in the following slides is taken from various publicly
21
available press releases, primarily from our Japanese
22
counterpart, the nuclear regulator, NISA, and the
23
utility, the Tokyo Electric Power Company or TEPCO.
24
25
While assessment is a natural and ongoing
part
of
the
agency's
response
to
this
event,
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1
conclusions based on our assessments will not be
2
presented as part of my slides, because events are
3
still unfolding and the information that is available
4
to us, as Bill pointed out, is incomplete or, in some
5
instances, unconfirmed.
6
The agency task force assignment that will
7
be discussed later during this presentation includes
8
establishing a framework for the agency's review and
9
assessment of this event.
10
Next slide, please.
11
Extended station blackout at Fukushima
12
Daiichi.
Immediately following the earthquake, the
13
reactors at Fukushima Daiichi, Units 1, 2, and 3,
14
scrammed.
15
offsite power, resulting in the plants having to use
16
their emergency diesel generators.
The earthquake also caused a loss of
17
About an hour after the earthquake, the
18
tsunami hit and inundated the underground emergency
19
diesel
20
generators non-functional and initiating the extended
21
station blackout condition.
22
extent
23
mitigating the station blackout with DC power.
generator
the
rooms,
station's
rendering
the
diesel
It is not clear to what
batteries
24
Next slide.
25
Accident sequence.
contributed
to
After the tsunami and
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1
station blackout, core cooling was provided by an
2
isolation condenser system for Unit 1, and reactor
3
core isolation cooling, or RCIC, systems for Units 2
4
and 3.
5
is dependent on the ability to refill the condenser
6
shell side with makeup water to serve as a heat sink.
7
During a station blackout, RCIC operation
8
is dependent on batteries to provide DC power to
9
energize valve motors and control circuits.
Continued operation of an isolation condenser
The
10
Japanese utility reported that they lost all cooling,
11
presumably after the isolation condenser boiled dry
12
for Unit 1, and the batteries providing power to RCIC
13
were exhausted for Units 2 and 3.
14
CHAIRMAN ABDEL-KHALIK:
15
take manual control of RCIC.
16
that happen at Fukushima?
17
MR. THORP:
Now, operators can
Has that happened?
Did
We don't have specific facts
18
that indicate exactly what the operator actions were
19
in
20
something we will certainly look into as part of our
21
evaluations.
response
22
to
manually
CHAIRMAN
23
station
manual
24
prolonged
25
cooling to the plants?
operate
ABDEL-KHALIK:
control
of
RCIC.
That is
The operator
RCIC, would that have
the time available to them to provide
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1
MR. RULAND:
At this stage, we -- I mean,
2
clearly, if a RCIC system continued to operate, of
3
course it would provide cooling.
4
information about what happened.
5
MR. THORP:
But we have no
The regulator reported --
6
excuse me.
7
exactly when or how long core cooling was lost for
8
each unit.
9
in
this
We don't have definitive information on
The regulator reported that at some point
sequence
of events, Units 1, 2, and 3
10
commenced seawater injection.
11
MEMBER CORRADINI:
Just to -- you said it,
12
but I want to make sure.
So in terms of the timing of
13
what you just said, it's fuzzy.
14
MR. THORP:
15
MEMBER CORRADINI:
16
fuzzy?
17
know that at least?
18
19
Yes, it is.
What's the range of
Not earlier than, and not later than.
MR. THORP:
Do you
I don't have specific details
for you this morning --
20
MEMBER CORRADINI:
21
MR. THORP:
22
MEMBER ARMIJO:
Okay.
-- on that.
Were the batteries used
23
for spent fuel cooling in Unit 4?
Since they didn't
24
have a core inside the reactor, did they try and keep
25
the pools cool using battery power on Unit 4?
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1
2
MR. THORP:
We don't have information
on --
3
MEMBER ARMIJO:
4
MR.
5
THORP:
We don't know that?
-- the answer to your
question.
6
MEMBER ARMIJO:
Just one other top-level
7
question.
8
Japanese on why Units 5 and 6 survived in a better
9
state with --
10
Is there any information provided by the
MR. THORP:
I have a couple of comments on
11
Units 5 and 6 as we move through that hopefully will
12
answer your question there.
13
Moving
along,
the
loss
of
flow,
and
14
presumably the inventory, some inventory in Units 1,
15
2, and 3, resulted in at least partial core uncovery.
16
Primary containment pressure increased, potentially
17
threatening the integrity of these structures, as
18
evidenced by the utility taking measures to reduce
19
pressure through venting.
20
The regulator reported that on 12 March,
21
as water level in Unit 1 reactor pressure vessel
22
lowered, fuel cladding interacted with the water and
23
generated hydrogen.
24
of
25
explosion in the reactor building.
the
This hydrogen accumulated outside
primary containment vessel and caused an
A similar --
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1
2
MEMBER BANERJEE:
How long was this period
from the initiation of the accident?
3
MR. THORP:
Well, the accident started on
4
11 March, and this report from the regulator was that
5
on 12 March the gas buildup occurred, and then the
6
explosion
7
timeframe of the explosion.
8
9
occurred.
I don't know exactly the
MEMBER BANERJEE:
So the timeframe -- you
know when the explosion occurred, though, right?
10
MR. THORP:
Yes.
11
MEMBER BANERJEE:
You don't know when the
12
core started to produce hydrogen.
13
saying.
14
MR. THORP:
15
MEMBER SIEBER:
That's what you're
That's correct.
How certain are we that
16
the hydrogen came from zirc water as opposed to a
17
couple of other --
18
MR. THORP:
What we have is the report
19
from the regulator and their assessment that it was
20
generation based on zirc water reaction.
21
MEMBER SIEBER:
22
MR.
THORP:
Okay.
A similar explosion was
23
reported by the regulator as having occurred in Unit 3
24
on 14 March.
25
Unit 2 and Unit 4 on 15 March.
Two more explosions were reported in
However, the exact
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1
cause of these explosions is as of yet unconfirmed.
2
Open source imaging shows significant damage to the
3
Units 1, 3, and 4 reactor buildings.
4
recorded the explosion in one or more of the units.
5
The
utility
reports
that
News videos
the
Unit
2
6
explosion may have occurred within the suppression
7
chamber or torus, potentially damaging that unit's
8
primary containment.
9
10
MEMBER CORRADINI:
MR. THORP:
MEMBER CORRADINI:
was -- where did it occur?
15
16
It's a report from the
utility.
13
14
MR. THORP:
And, again, the report
Excuse me.
That the Unit 2 explosion may
have occurred within the suppression chamber.
17
MEMBER CORRADINI:
18
MR. THORP:
19
MEMBER CORRADINI:
20
MEMBER SHACK:
21
Within.
Yes.
Okay.
Do we know how they tried
to do the venting?
22
MR. THORP:
23
on the venting process they took.
24
25
So the last
statement you just made is confirmed or speculation?
11
12
I'm sorry.
We don't have specific details
MEMBER SHACK:
So we don't know whether
they have hardened vents, sort of akin to what we
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1
would expect.
2
MEMBER SIEBER:
3
MR. THORP:
4
told they don't.
5
we have to find out.
6
They apparently do not.
It's not clear.
We have been
We have been told maybe they do, so
MEMBER CORRADINI:
So I'm going to ask you
7
something that is probably unfair, but -- so yesterday
8
in
9
Congressman Markey claims he has an NRC report that
the
had
House
Energy
and
Committee,
10
they
11
understand where he got that and if it's true.
12
what I'm hearing today is unclear.
13
14
hardened vents.
Commerce
MR.
THORP:
And I am trying to
So
That's a totally unfair
question, right.
15
(Laughter.)
16
I really don't know.
17
MEMBER CORRADINI:
Because Marty Virgilio
18
looked awful surprised when it was asked of him, and
19
I --
20
MR. THORP:
Yes.
21
MEMBER CORRADINI:
22
what the facts are.
23
then we don't know the answer.
24
25
-- I want to get clear
And if we don't know the answer,
MR. THORP:
We don't know the answer, but
that's certainly one of the questions that we will be
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1
pursuing as part of our followup.
2
MEMBER SIEBER:
3
MR. RULAND:
Yes.
Yes.
The photos I saw --
We take, obviously,
4
what we say very seriously, and we want it to be
5
absolutely credible.
6
So --
MEMBER CORRADINI:
The reason I -- no, the
7
reason I ask that is because Marty's response was, "We
8
don't know."
9
thought -- and the source of that was NRC, and I
10
thought that didn't make sense to me, and I wanted to
11
make sure at least I think -- at least somebody ought
12
to followup as to why these incorrect facts are
13
getting out.
14
And he was told he was wrong, and I
MR. RULAND:
You might have read some
15
press information about a document, a New York Times
16
article yesterday, you know, quoting a document from
17
the NRC.
18
quoting that document don't understand the context
19
that that document --
And I would submit that the people that are
20
MEMBER CORRADINI:
21
MR. RULAND:
22
MEMBER CORRADINI:
23
MEMBER SIEBER:
Fine, okay.
-- was produced.
Thank you.
Fine.
I have a quick question.
24
You had a torus explosion, presumably in Unit 2.
25
was from the inside of the torus?
That
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1
MR. THORP:
It's not clear whether it was
2
just outside the torus or whether it was inside the
3
torus.
4
MEMBER SIEBER:
Okay.
But the inside of
5
the torus ordinarily would be under a nitrogen blanket
6
in that type of reactor, right?
7
MEMBER ARMIJO:
Until it's vented, yes.
8
MEMBER SIEBER:
And so --
9
MEMBER CORRADINI:
I was going to followup
10
my question.
11
can understand it near, but not in.
12
13
You're thinking the same thing I am.
MEMBER SIEBER:
I
Yes, I guess we don't know
the answer to that right now.
14
MR. THORP:
15
MR. RULAND:
16
MR. THORP:
Units
and
Okay.
3
Next slide.
The status
on
18
handouts, the hard copies that you have, may look a
19
little bit different than what is displayed on the
20
screen.
21
to obtain the latest status as of this morning, so I
22
have got a couple of pieces of information that are
23
later than April 5th.
25
2,
Correct.
17
24
1,
No, we don't.
-- note, your particular
I deleted the date 5 April, because I tried
The
regulator
had
reported
that
the
Units 1, 2, and 3 reactor cores are likely damaged, as
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1
evidenced by the presence of iodine and cesium in the
2
environmental monitoring samples they have taken.
3
Additionally, TEPCO, Tokyo Electric Power Company, has
4
announced publicly that they estimate the core damage
5
in Unit 1 as 70 percent; Unit 2, 30 percent; and
6
Unit 3, 25 percent.
7
statement on radiation levels that they measured in
8
the units on March 14th and 15th.
9
10
These figures were based in their
MEMBER BLEY:
We don't know what that
means, right?
11
(Laughter.)
12
I certainly don't know what that means.
13
MEMBER CORRADINI:
So just to give you a
14
historical connection, if I remember correctly, the
15
few days following TMI, a number of laboratories were
16
asked to do analyses, and all came in with a damage
17
based on zirc water reaction of something on the order
18
of 50 to 70 percent.
19
understand what that means.
20
reaction analysis?
21
What is it?
22
Is that -- I'm trying to
Is it a zirc water
Is it a radioisotope analysis?
MR. THORP:
We don't really know.
They
23
indicated it was based on radiation levels that they
24
had --
25
MEMBER SIEBER:
So you can't prove that.
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1
MR. THORP:
That's right.
Now, the use of
2
seawater for core cooling was taken for several days,
3
and resulted in some degree, we believe, of salt
4
buildup within the reactor pressure vessels for these
5
units.
They have switched to fresh water cooling.
6
We learned from a Japanese television news
7
report on Tuesday, 5 April, that a safety relief valve
8
on Unit 1 was believed to be stuck open.
9
not obtained other or subsequent reports on the status
10
of this valve on Unit 1.
11
12
But we have
We do --
MEMBER REMPE:
Excuse me.
What date would
they claim it had started to be stuck open?
13
MR. THORP:
April 5th.
14
MEMBER REMPE:
15
MR. THORP:
Okay.
Nitrogen inerting of Unit 1
16
primary containment, those operations were conducted
17
on
18
10:30 p.m. Japan Standard Time.
Wednesday,
19
6
April,
yesterday,
MEMBER CORRADINI:
--
I
apologize
--
at
I'm getting ahead of
20
you
21
instrumentation that they can actually see a pressure
22
change with this injection?
23
MR.
24
instrumentation
25
instrumentation they have is.
THORP:
they
but
commencing
--
so
do
they
have
It's not clear what
have
and
how
reliable
the
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1
MEMBER CORRADINI:
2
public reason given for this injection is?
3
MR. THORP:
And so the reason --
Well, their containments are
4
supposed to be inerted anyway.
5
inert the containment, so that if they have to vent
6
they
7
explosion.
will
8
9
minimize
the
MR. RULAND:
possibility
of
hydrogen
And the inerting is happening
in Unit 1, correct?
10
MR. THORP:
11
MEMBER BANERJEE:
12
me?
13
nitrogen --
Unit 1.
MR. THORP:
want to dwell on it.
That's correct.
Can you explain that to
I was also puzzled by that.
14
15
So their concern is to
How does injecting
It's not clear to me.
I don't
It was --
16
MR. RULAND:
17
MR. THORP:
What was the question?
It was a discussion of partial
18
pressures.
19
nitrogen would necessarily be a mitigating factor for
20
the potential for explosion.
21
He doesn't understand why injection of
MEMBER
POWERS:
It's a well-known
22
phenomenon that injection with nitrogen, getting it up
23
over 70 percent, interferes in the propagation of a
24
deflagration front, because -- simply because of heat
25
capacity.
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1
MEMBER BANERJEE:
So is that -- the
2
containment is supposed to be inerted, at least the
3
primary containment.
4
Dana, is if it issues as a mixed stream of nitrogen
5
and hydrogen, that changes the deflagration of --
6
So the point you are making,
MEMBER POWERS:
the
7
that
8
accompanied by oxygen that exolved from the seawater
9
that has been pumped in, subsequently leaked through
--
hydrogen
I believe the concern is
into
the
within the drywell may be
10
the
drywell, and so they want any
11
hydrogen/oxygen mixture to be inerted.
12
MEMBER BANERJEE:
13
MEMBER POWERS:
Okay.
Right now it is probably
14
steam-inerted.
But if you start putting cold water
15
in, you are going to eliminate the steam-inerting, so
16
they replace it with nitrogen-inerting and get it back
17
to the condition that it was designed to be in -- that
18
is, inerted.
19
MEMBER BANERJEE:
20
MEMBER
SIEBER:
Okay.
Thanks.
In order to re-inert
21
Unit 1 containment, did they actually have to vent the
22
containment?
23
24
MR. THORP:
I don't know the specific
sequence of steps taken.
25
MEMBER SIEBER:
To replace whatever is in
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1
there with fresh nitrogen.
2
drop and --
3
MR. THORP:
4
MEMBER SIEBER:
Otherwise, pressures will
Right.
-- I would have seen that
5
on the charts I read, and I didn't.
6
MR. THORP:
7
I don't know the
specific sequence of steps they took.
8
9
Right.
MEMBER CORRADINI:
If I might just --
again, I think you're going to say you're not sure,
10
but they are -- the procedures of venting are not --
11
I know that they occurred over the first few days.
12
there still venting going on, or is that unclear also?
13
MR.
THORP:
Is
That's also unclear, and
14
certainly the report that the safety relief valve was
15
stuck open is one indicator that perhaps they are
16
having to deal with that, but --
17
MEMBER CORRADINI:
18
MR. THORP:
19
MEMBER CORRADINI:
On Unit 1.
-- it's unclear.
On Unit 1.
The only reason I ask
20
the question is, from the same public sources I think
21
we are all looking at, Unit 1 is the only one that is
22
showing pressurized.
23
MR. RULAND:
That's correct.
24
MEMBER CORRADINI:
25
MR. RULAND:
Okay, fine.
It's about seven pounds I
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1
think, the last time I saw the number.
2
MEMBER ARMIJO:
John, just a real basic
3
question.
4
of the Japanese plants and -- so that we can compare
5
them with the U.S. plants?
6
BWR3's.
7
Do we have reasonably up-to-date drawings
MR. THORP:
You know, BWR4, Mark 1's,
I think we have been working
8
to obtain materials that -- from our staff that are
9
stationed in Japan.
10
Japan detachment.
11
12
We call them the site team or the
Bill, I don't know if you have other
comments on that.
13
MR. RULAND:
Everybody knows this plant
14
was built by General Electric, so I would imagine
15
General Electric has the drawings and --
16
17
MEMBER ARMIJO:
I've been there, you know,
and I --
18
MR. RULAND:
19
MEMBER
ARMIJO:
were
-- from a hazy
20
recollection,
21
identical, to the U.S. plants.
22
sorts of stories that they were different, and I had
23
wondered -- I would like to know if the NRC has
24
drawings of the plants as they currently exist.
25
they
Right.
very
similar,
if
not
But I have heard all
The other thing I know about the Japanese,
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1
they were very careful to follow the safety upgrades
2
that the NRC required in the U.S. plants, but I have
3
heard otherwise.
4
you may be, and I'm not sure what I can rely on.
5
So I'm probably in the same state as
MR. RULAND:
Yes.
One of the things the
6
staff is sensitive for -- is sensitive about is when
7
we -- we don't want to divert the Japanese attention
8
on their primary responsibilities to get the plant
9
under control.
Basically, you know, stop working on
10
what you're doing and, you know, come brief us.
11
That's not where we're at.
12
MEMBER ARMIJO:
13
Send us your drawings,
while you're busy --
14
MR. RULAND:
And so that has been, you
15
know, some of the reason, you know, the data stream we
16
have is slow.
17
ahead, you know, we will be, you know, trying to get
18
that information.
But I'm sure in the weeks and months
19
MEMBER ARMIJO:
Okay.
20
MEMBER SIEBER:
When I looked at aerial
21
photographs, the vents did not appear to be hardened.
22
You can actually see them.
23
conclusion that the explosion probably occurred in the
24
outer shell of the containment building out in the
25
primary containment, but the concrete structure --
And that leads to the
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1
concrete and sheet metal structure above that, and
2
vent pipes -- it's hard to tell which unit you were
3
looking at that the vent pipes appeared to be broken,
4
and the building -- most of the building outside
5
covering is missing.
6
And with a hardened vent -- the vent,
7
prior to the venting operation, still filled with
8
oxygen, so the chance of a deflagration inside the
9
vent is real, if you vent hydrogen through that.
10
11
MR. THORP:
Let's see, to continue, I
don't -- I took that as a statement, not a question.
12
MEMBER SIEBER:
13
MR. THORP:
It's a statement.
Okay.
Thank you.
All the
14
units are using cooling pumps that are powered by
15
offsite power sources as of April 3rd.
16
I am repeating myself.
17
Freshwater
means,
is
being
including
injected
various
19
pressure coolant injection systems.
20
of high radiation levels, in the thousands of r,
21
inside the primary containments, as I had noted above.
22
While the radiation levels are high, they
have trended downward.
24
dose
25
higher than normal doses.
rates
onsite,
feedwater
through
18
23
the
I apologize if
and
low
There are reports
As a result of the significant
several
workers
have
received
However, there have been no
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1
reports of workers exceeding regulatory dose limits
2
for response to emergencies.
3
4
MEMBER SIEBER:
That's 10 for equipment,
25 for rem.
5
MR. THORP:
I have seen a 25 rem limit for
6
a response to emergencies, and there are lower limits,
7
their
8
occupational exposure.
normal
9
10
regulatory
limits,
MEMBER SIEBER:
for
Well, there's two -- 10
and 25 -- is the three.
11
MEMBER
REMPE:
They increased it
12
periodically.
13
higher levels as this accident progressed.
14
15
exposure,
It's my understanding that they went to
MEMBER SIEBER:
I'd rather two instances
over ten.
16
MEMBER RYAN:
There's probably a little
17
bit of detail there in terms of the folks who get --
18
their feet have been exposed, and that's a local skin
19
dose as opposed to a whole body --
20
MR. THORP:
21
MEMBER RYAN:
Extremities dose, yes.
So I think it's -- you've
22
got to lay out all of the details to really understand
23
what the number means and in what context.
24
25
CHAIRMAN
ABDEL-KHALIK:
John, please
continue.
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1
2
MR. THORP:
Okay.
Thank you.
I'll try
and move along.
3
The Unit 4 reactor core was offloaded into
4
the spent fuel pool about three months prior to the
5
earthquake.
6
15 March caused significant damage to the reactor
7
building.
8
not functional, cooling and makeup water is being
9
provided by injection of fresh water from a concrete
10
The Unit 4 explosion that occurred on
Since the spent fuel pool cooling system is
pumper truck.
11
Units 5 and 6 did not experience an
12
extended station blackout condition following the
13
earthquake and tsunami, although Unit 5 may have
14
experienced loss of all AC power for a period of time.
15
These two units are in cold shutdown, and shutdown
16
cooling systems are operating normally for Units 5 and
17
6.
18
MEMBER CORRADINI:
Can we go back to Sam's
19
question about -- I'm sorry, but Sam asked something,
20
and you were going to defer him.
21
MEMBER ARMIJO:
Yes.
So this is -Do you have any kind
22
of a -- call it speculation for now -- from the
23
Japanese or from internally of why Units 5 and 6 fared
24
better?
25
Are they -MR. THORP:
I have a photo --
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1
MEMBER ARMIJO:
2
MR. THORP:
-- at the same elevation?
-- that will come after this
3
that will I hope show you -- well, you won't see
4
Units 5 and 6 on this photo.
5
enough, are located to the north of Units 1, 2, 3, and
6
4, okay?
7
ground than those four units.
8
9
And they appear to be on somewhat higher
MEMBER SIEBER:
Do we know how much higher
that is?
10
11
But Units 5 and 6, oddly
MR. THORP:
We don't know how much higher
that is.
12
MEMBER ARMIJO:
Well, John, many of us --
13
as you must realize, we have been working on this
14
thing from various sources of information.
15
go on Google Maps, they have an elevation feature.
16
And I did, in fact, look to see if there was any
17
elevation differences in parking lots next to Units 1
18
through 4, and 5 and 6.
19
about another 10 feet higher up on the Units 5 and 6.
20
I don't know if that's actually fact or --
21
but I'm looking for some reason that tells us why 5
22
and 6 made it past this, didn't get into the same
23
state.
24
25
And my unverified numbers was
MEMBER SIEBER:
numbers.
And if you
Yes.
I reviewed your
I don't fully agree.
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1
MEMBER ARMIJO:
I wouldn't be surprised.
2
MEMBER SIEBER:
I think it's a figurative
4
MEMBER ARMIJO:
Well, that's good.
5
MEMBER SIEBER:
But that's probably the
3
6
distance.
reason why that occurred right there.
7
MEMBER ARMIJO:
Well, that's sort of the
8
things that are on a list of questions that the ACRS
9
is probably going to be putting together, a list of
10
kind of key questions that --
11
MEMBER SIEBER:
12
MR. THORP:
We could all --
One of my colleagues that will
13
speak to the station blackout topic, and will be able
14
to address a slight difference between Units 5 and 6,
15
emergency diesel generators and how they respond to a
16
blackout --
17
MR. RULAND:
18
MR. THORP:
19
MR. RULAND:
20
MR. THORP:
21
-- or loss of power versus -John?
-- the other units, so I would
like to defer to --
22
23
John?
MR. RULAND:
George, why don't you mention
that briefly.
24
MR. WILSON:
Yes.
The --
25
MR. RULAND:
This is George Wilson.
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1
MR. WILSON:
One of the units has a HPCS,
2
and Unit 5 has HPCS diesel -- or it might be Unit 6 --
3
has HPCS diesel, has a HPCS system.
4
HPCS diesel, that is the power supply.
5
that it has a HPCS diesel, that -- and at that
6
elevation, nothing happened to that HPCS diesel.
7
So if it has a
So the fact
Therefore, power was there, and they were
8
able to -- what we think is that they were able to
9
cross-connect the Unit 5 and Unit 6 spent fuel pools,
10
because they didn't have the power from the HPCS
11
diesel on the other unit.
12
happening to that.
13
MEMBER
14
ARMIJO:
somewhat higher elevation?
15
MR. WILSON:
16
MEMBER ARMIJO:
17
fact,
that
18
difference?
19
you
know
MR. WILSON:
So there was nothing
And you mentioned a
Do you have a --
Well, it --
that
-- for that, or is that a
there
is
an
elevation
As John said, I don't know if
20
there is an elevation difference.
But as you do know,
21
HPCS is a safety-related system.
And it's used -- I
22
mean, it should be in an environment that it would be
23
protected from that, because that would be the safety-
24
related diesel.
25
So, and that's all we know.
MEMBER ARMIJO:
Okay.
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1
CHAIRMAN ABDEL-KHALIK:
Now, with regard
2
to the spent fuel pools, it is my understanding that
3
the
4
Japanese are similar to those used at U.S. plants.
5
And for both BWRs and PWRs, the emergency operating
6
procedures focus on maintaining the critical safety
7
functions of the reactor.
emergency
operating
procedures
used
by
the
8
Nowhere in the EOPs are the operators
9
asked to check the status of the spent fuel pools.
10
Given what happened at Fukushima with regard to the
11
spent fuel pools, should the licensees be asked to
12
evaluate the adequacies of their EOP?
13
MR. RULAND:
EOPs and the SAMGs are going
14
to be one of the things that the task force is going
15
to look at.
16
CHAIRMAN ABDEL-KHALIK:
17
MEMBER CORRADINI:
Okay.
Can I get back just to
18
-- so we asked about the schematics, and you said
19
they're busy and you don't have them.
20
capacities and the loadings on the spent fuel pools,
21
including the common ones?
22
or --
23
MR. THORP:
24
with
me
on
25
information
that.
from
What about the
Do you know what that is,
I don't have specific details
We have worked to get some
GE-Hitachi
on
the
fuel
assembly
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1
loadout in the various spent fuel pools, and the
2
normal core loading number of assemblies, etcetera, in
3
each of the reactor pressure vessels.
4
answer the question for you right now.
5
MEMBER CORRADINI:
But I couldn't
That's fine.
6
fine.
7
you're going to defer, and that's fine.
8
list.
That's
I figure a lot of the things we're asking
We'll make a
9
But the reason I'm asking the question is,
10
particularly for Unit 4, since it was offloaded, I was
11
curious about what was in Unit 4 besides the core.
12
And given the fact there is like three or four NUREGs
13
that NRC has done on spent fuel pools relative to
14
accident situations and essentially boildowns, what
15
would be -- has the NRC done a calculation on if -- if
16
unattended, how many days would this pool have been
17
able to -- do you know what I'm asking?
18
MR. THORP:
Yes.
19
MEMBER CORRADINI:
20
MR. THORP:
Yes.
And has that been done?
We have been working to obtain
21
information in that regard and to conduct some
22
calculations,
23
finalized or not.
24
25
but
I
don't
know
MEMBER CORRADINI:
fine.
whether
they are
That's fine, that's
But you have already thought in that regard.
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1
MR. THORP:
2
MEMBER CORRADINI:
3
MR. RULAND:
4
We did.
When we talk about emergency
planning, we have -- that's one of the topics.
5
MEMBER CORRADINI:
6
MR. RULAND:
7
MEMBER CORRADINI:
8
MEMBER SIEBER:
9
Thank you.
Okay.
Thank you.
We'll bring that up then.
Thank you very much.
One thing I would point
out is the fuel pool content is going to be typical of
10
plants that are regularly in service.
11
hand, I think it makes, from a thermal hydraulic
12
standpoint, a difference to know how they -- where
13
they place fuel assemblies in the pool.
14
On the other
You can build a chimney effect by having
15
a whole core discharge in one place in the pool,
16
which, you know, mixing is natural circulation, and
17
fuel damage will occur earlier if it's that way as
18
opposed to spread around to cool it.
19
something that we need to learn what the pattern was.
20
21
MR. RULAND:
Randy?
So that would be
If you don't --
Randy, could you talk about this a little bit, please?
22
MR. SULLIVAN:
Yes, Randy Sullivan.
I'm
23
not the spent fuel pool expert, but much of what you
24
are asking was known in the Operations Center.
25
these spent fuel pools very much do not look like your
And
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1
typical American spent fuel pool.
2
racked densely.
They are not re-
3
In Unit -- let's see, let me get this
4
straight -- 1, 2, 3, there is like one core offload.
5
There was some calculations -- this was a surprise to
6
us early on.
7
the event, but we do have some calculations in the Ops
8
Center on time to boil off.
We were unaware of this until later in
9
You know, we would assume in a typical
10
U.S. spent fuel pool you've got, I don't know, six
11
days, eight days, something.
12
days.
These are more like 30
I have even heard 100 days.
13
Now, Unit 4 was the exception.
There was
14
a 105-day-old full core offload, and of course Unit 4
15
is where the problem was.
16
17
I don't have the actual numbers at my
fingertips, and I would encourage you to wait.
18
MEMBER CORRADINI:
19
MEMBER
REMPE:
That's fine.
Would you elaborate a
20
little more about the geometry being different?
21
in particular, in Unit 4?
22
MR. SULLIVAN:
Yes.
23
MEMBER REMPE:
Tell me what, you know --
24
MR. SULLIVAN:
In a typical U.S. spent
25
fuel pool, you will find several cores, right?
And,
And
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1
we're -- I'm sorry?
2
MR. RULAND:
Just to kind of put this in
3
perspective, the spent fuel pools -- we don't know
4
what the condition of the spent fuel pools were after
5
the seismic event.
6
7
MEMBER REMPE:
I'm talking about just
the --
8
MR. RULAND:
9
MEMBER REMPE:
10
MR. RULAND:
We don't know --- structure, John.
We don't know structurally
11
what their condition was.
We don't know how much
12
water was in the spent fuel pools after the seismic
13
event.
14
the explosion.
15
you know, trying to -- you know, truly it is a rough
16
estimate.
17
rough estimate about time to boil.
18
CHAIRMAN ABDEL-KHALIK:
And we don't know how much water was in after
So there is lots of uncertainty to --
Anything that we could have done was a
But in terms of
19
geometry, there were indications that there is a
20
shallow part of the pool.
21
was the full core offload for Unit 4 placed in the
22
shallow part of the pool?
23
MR. RULAND:
24
MR. SULLIVAN:
25
And if that is the case,
I have no idea.
No idea.
The only thing I wanted to
relate that we were sure of is that there was fewer
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1
elements in the pool than perhaps you were expecting,
2
given your U.S. experiments.
3
4
MEMBER CORRADINI:
MR. SULLIVAN:
6
MEMBER CORRADINI:
7
MEMBER REMPE:
That's what I am sure of.
Thank you.
But building geometry,
anything different that you know about?
9
10
Thank
you.
5
8
That's fine.
MR. SULLIVAN:
No, sorry.
Can't help you
with building geometry.
11
MEMBER REMPE:
12
MEMBER BLEY:
Okay.
Bill, quickly, you mentioned
13
the SAMGs.
14
years.
15
the SAMGs in any way, or audit them?
16
outside the design basis, are they really outside of
17
the normal scope?
18
I've heard different things over the
Up to this point in time, does staff review
MR. RULAND:
Or because it's
The SAMGs are something that
19
we worked with industry to establish, right, at a high
20
generic level.
So that's what we did.
21
MEMBER BLEY:
22
MR. RULAND:
Okay.
You know, I'll be sure that
23
we're -- the whole issue of SAMGs and what -- what is
24
appropriate there is going to come out.
25
Chairman here has opined that the -- you know, they
I know the
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1
have similar procedures that we do.
2
that.
3
4
CHAIRMAN ABDEL-KHALIK:
We have heard
Not with regard to
SAMGs, though.
5
MR. RULAND:
With SAMGs or EOPs.
You
6
know, we -- that has not been verified.
7
-- you know, that could be a presumption, but we don't
8
know for certain.
9
weeks and the months ahead.
10
That might be
You know, this will come out in the
MEMBER SIEBER:
One of the things I think
11
would help in an analysis of all of this is to know
12
what happened in that first hour of operation between
13
the earthquake and whatever seismic damage occurred in
14
the tsunami, because it appears to me is the tsunami
15
caused the bulk of the problems, as opposed to the
16
seismic event.
17
And from a regulatory standpoint, that
18
makes a big difference as to how you treat various
19
phenomena, natural phenomena at various sites.
20
perhaps you can reach into that area and see what you
21
can pull out.
22
MR. RULAND:
23
MR. THORP:
24
MR. RULAND:
25
MR. THORP:
So
How much more time, John?
We're just about done.
Okay.
But I think that's going to be
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1
another
one
2
Committee.
of
the
focuses
of
the
task
force's
3
There are a number of photographs -- you
4
can see one of them here -- of the Fukushima Daiichi
5
site that have been released through the media.
6
is one such photograph with the units labeled as
7
shown.
8
containment buildings is evident from the photographs
9
as you look at them.
The degree of destruction of the secondary
10
Units 5 and 6 are not --
11
MEMBER RAY:
12
This
You are now calling these
"secondary containments" consistently.
13
MR. THORP:
That's what I am calling them.
14
You know, I'm a PWR guy, so here I am trying to relate
15
BWR stuff.
16
17
MEMBER
SIEBER:
buildings.
18
MR. THORP:
19
MEMBER RAY:
20
have been calling them.
21
22
MR. THORP:
Reactor building, yes.
Reactor building is what I
Yes.
I'm good with reactor
building.
23
MEMBER RAY:
24
MR. THORP:
25
Call them reactor
All right.
Units 5 and 6 are not show in
this picture, but they are located, as you're looking
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1
at this picture, to the left or to the north end of
2
the site.
3
4
And
concludes
the
slides
that
I
intended to present.
5
6
that
MEMBER ARMIJO:
Where is the common fuel
pool for the discharge?
7
MR. THORP:
The common fuel pool -- I
8
can't point it out exactly, but it's kind of south of
9
Unit 4.
10
MEMBER ARMIJO:
11
MR. THORP:
12
In one of the structures
there, but I don't know specifically.
13
MEMBER ARMIJO:
14
MEMBER
15
All right.
SIEBER:
Those tower-like
structures are the vent towers, right?
16
MR. THORP:
That would have been my guess,
17
but I don't know for sure.
18
MEMBER SIEBER:
19
Okay.
That's what I assume from
the photographs that I saw.
20
MR. RULAND:
Eric?
21
MR. BOWMAN:
Good morning.
On March 18th,
22
we issued the first generic communication on the
23
subject.
24
issued so far, Information Notice 2011-05.
25
It is the only generic communication we have
The purpose of that Information Notice was
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1
to provide a summary, a high-level summary of the
2
events as they happened, as we knew them at the time,
3
to the industry and to allow the recipients to review
4
the information and consider what actions would be
5
appropriate on their parts to avoid having similar
6
problems at their sites.
7
In addition to the description of the
8
circumstances as we knew it to have occurred, we
9
provided a discussion of the regulatory background
10
that we felt was pertinent to the events that took
11
place.
12
In particular, we discussed General Design
13
Criteria 2, or whatever the similar design criteria
14
requirements were for appropriate licensees, the B.5.b
15
requirements for mitigating strategies for beyond
16
design basis events that came out after the terrorist
17
events of September 11, 2001, and the station blackout
18
rule.
19
We also provided a look ahead to what was
20
-- what we knew of the industry initiatives following
21
on to the event to verify their capabilities.
22
Kobetz will be covering that.
23
discussion of the upcoming Temporary Instruction to
24
conduct
25
discussing the task force action that came out after
inspections,
and
Tim
And we provided a
Barry
Westreich
will
be
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1
the follow-on Commission meeting.
2
CHAIRMAN
that
ABDEL-KHALIK:
3
understanding
4
licensees in response to Section B.5.b are based on an
5
event at a specific unit, at a single unit.
6
licensees of multiple-unit sites, are they being asked
7
to also evaluate the adequacy of the staged equipment,
8
if more than one unit is involved?
9
MR. THORP:
10
MR. RULAND:
11
a second.
12
is
13
question, Barry?
on
equipment
staged
by
the
So for
This was an information -Barry, could you -- hold on
Barry was associated with -- you know, he
rotation
14
the
It's my
from
NSIR.
MR. WESTREICH:
Can you answer that
Yes, the B.5.b equipment
15
was there for an event.
16
So the licensees evaluated an event -- large explosion
17
-- to see the location of the various units.
18
be designed for multiple units.
19
I mean, I can't give you an answer specifically for
20
the fleet.
21
multiple units; some may not.
22
It wasn't for a single unit.
They may
We don't really know.
So some sites have capabilities for
MEMBER ARMIJO:
This was a mind-boggling
23
event, you know, which may be much different than what
24
we have traditionally thought of as an event.
25
MR. THORP:
Barry, if I could address the
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1
question, this was an Information Notice.
We did not
2
ask them to evaluate anything.
3
information so they could do their own evaluations.
4
The Temporary Instruction inspection will follow-on to
5
take a look at those things.
We provided the
6
And also, the details of the mitigating
7
strategies requirements are typically Official Use
8
Only security-related information that we have not
9
released to the public, and we aren't really prepared
10
at this point to --
11
CHAIRMAN ABDEL-KHALIK:
its
12
on
13
evaluations, and the question is whether the staged
14
equipment would be adequate if you have an event that
15
involves more than one unit on a multi-unit site.
16
17
own,
is
asking
But the industry,
MR. RULAND:
licensees
these
of the questions the task force will address.
CHAIRMAN ABDEL-KHALIK:
19
MR. RULAND:
That what --
The task force will address
that question.
21
CHAIRMAN ABDEL-KHALIK:
22
right?
23
asked?
24
25
do
I'm certain that that is one
18
20
to
The task force,
Is that a question that has already been
MR. RULAND:
The task force has not only
long term, which is -- has the short-term actions,
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1
which is within 90 days, and those are the issues that
2
are adequate protection issues.
3
task force has on their plate near term.
4
after the three months, it turns out the three-month
5
to nine-month timeframe is the longer term actions.
6
So that's what the
And then,
So the task force is asking the adequate
7
protection issue virtually as we speak.
8
anything
9
protection issue, that needs to be addressed now?
10
that
needs
to
be
done,
as
Is there
an
adequate
And
that's the question that is on the task force's plate.
11
CHAIRMAN ABDEL-KHALIK:
12
MEMBER CORRADINI:
I
don't
understand
the
Thank you.
Just a clarification.
13
So
14
Information Notice went out within the first week?
15
MR. BOWMAN:
16
MEMBER CORRADINI:
sequence.
So the
Yes.
Okay.
And then, this
17
in some sense -- I don't want to say call it an
18
inventory, but this is a -- shall I say, an inventory
19
of what from various rules historically are onsite for
20
the various units.
21
that that I wanted to connect to it.
22
there will now be a temporary order or a temporary --
23
I
24
inspection, an onsite inspection, by the NRC staff.
don't
25
remember
And then, you said something after
what
MR. BOWMAN:
you
called
You said that
it,
but
an
Tim will be addressing that.
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1
2
MEMBER CORRADINI:
okay.
Oh, I'm sorry.
Okay,
Thank you.
3
MR. BOWMAN:
Any other questions for me?
4
(No response.)
5
MR. KOBETZ:
All right.
I'm Tim Kobetz.
6
I'm the Chief of the Reactor Inspection Branch, and,
7
as we have just discussed, I am going to be talking
8
about
9
initiatives, because we only know about them at a high
10
--
at
a
high
level
about
some
industry
level.
11
But I am going to be talking about our
12
Temporary Instruction and what that is, and how that
13
is going to be looking at some of what they're doing,
14
and then also performing somewhat of an independent
15
assessment.
16
I'll talk about that.
But it's a quick high-level look, and
17
So within a few days of the event, the
18
industry -- an industry-wide initiative was launched
19
to assess the plant's readiness to manage some of
20
these extreme events.
21
to be completed within 30 days, so that would be mid
22
-- probably late April.
The assessments are scheduled
23
There is really four areas that they were
24
looking at, and, again, I'm going to talk about them
25
at a high level, because we don't know specifics as
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to, you know, the question that you just brought up
2
about,
3
multiple sites.
4
part of what our Temporary Instruction would be doing.
are
5
they
looking
at
the
50.54(hh)(2) for
We don't know that yet, but that's
So the first area that they would be
6
looking at is verifying each plant's capability to
7
manage major challenges, such as aircraft impacts, as
8
we just talked, and other losses of large areas of the
9
plant due to natural events and fires.
10
You know, this
is somewhat from the 50.54(hh)(2).
11
Specific actions would include testing and
12
inspecting
13
events,
14
operators and support staff are in place, and, you
15
know, up to date to deal with what they have put in
16
place.
and
equipment
verifying
required
that
to
mitigate
qualifications
these
of
the
17
The second one would be verifying the
18
plant's capability to manage a total loss of offsite
19
power.
20
as we said, George Wilson will go into a little bit
21
more on our requirements for a station blackout.
22
this is going to require verification that all of the
23
required materials are adequately -- are adequate and
24
properly staged, and that the procedures are in place,
25
and that operator training is, again, up to date.
You know, you're at station blackout, which,
But
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1
The third one is verifying capability to
2
mitigate flooding and impact of floods on systems
3
inside
4
include verifying required materials and equipment are
5
properly located again.
and
outside
the
plant.
Specific actions
6
One of the things I would like to point
7
out is these are things that we do look at during, you
8
know, the inspections.
9
looking at them here from a slightly different angle
10
But they are going to be
now as to what could go beyond.
11
And
then,
the
last
one,
they
are
12
performing walkdowns and inspections of important
13
equipment needed to respond successfully to extreme
14
events like fires and floods.
15
analysis identifying any potential equipment functions
16
that could be lost during a seismic event, and then
17
developing
18
vulnerabilities.
strategies
to
This will include an
mitigate
any
potential
19
Walkdowns and inspections will include
20
important equipment, permanent and temporary, such as
21
storage tanks, plant water to intake structures, and
22
fire and flood response equipment.
23
So the NRC obviously wants to -- may have
24
a good understanding of what the licensees are looking
25
at, and then perform somewhat of an independent look
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1
as to what else we think should be addressed going
2
into the future.
3
So that takes us --
4
MEMBER CORRADINI:
I'm sorry.
I just
5
wanted to make sure -- this is everything onsite, and
6
particularly in your fourth bullet relative to natural
7
disasters.
8
necessarily independent, is that what I understood
9
that to mean?
So spent fuel, other things that are not
10
So, for example, what I was looking for is
11
some sort of discussion about natural events that may
12
affect spent fuel cooling.
13
14
MR. KOBETZ:
Would they be looking at
this?
15
MEMBER CORRADINI:
16
MR. KOBETZ:
17
MEMBER CORRADINI:
18
MR. KOBETZ:
19
Yes.
That's our understanding.
Okay.
Again, we're going to have to
follow up during the TI, but --
20
MEMBER CORRADINI:
21
MR. KOBETZ:
Thank you.
So we decided to perform a
22
Temporary -- issue a Temporary Instruction to perform
23
an inspection.
24
what a Temporary Instruction is, you know, we have our
25
normal baseline inspection program and other special
Just to give you an understanding of
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1
inspections.
2
Instruction is used for a one-time inspection to focus
3
on a current safety issue.
4
But when things come up, a Temporary
Now,
where
we
usually
use
Temporary
5
Instructions are going to be maybe to follow up on
6
licensee actions in response to a Generic Letter or
7
something like that, something that we are going to do
8
one time, or when an event like this happens and we
9
want to gather some information and see what else
10
maybe we should be doing, or the industry should be
11
doing.
12
would gather from this would feed into the teamwork
13
that Barry is going to be talking about.
And then, this -- the information that we
14
So on March 23rd, the NRC issued a
15
Temporary Instruction, which was very quick for doing
16
one of these, to focus on these things.
17
of the TI is to independently assess the adequacy of
18
the actions taken by the licensee in response to the
19
Fukushima event.
20
will be used to evaluate the industry's readiness for
21
a
22
additional
23
warranted.
The inspection results from this TI
similar event, and aid in determining whether
24
25
The objective
regulatory
actions
by
the
NRC
are
The intent of this TI is to be a highlevel look at the industry's preparedness for events
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1
that in some aspects could exceed a design basis for
2
the plant -- in some instances.
3
specific followup inspection will be performed.
4
If necessary, more
The inspection assessment area is similar
5
to the industry initiative.
6
independence, as I was noting, from the industry
7
inspection, we are going to use a combination of
8
looking at what the industry is doing, what they are
9
finding, and then doing some independent looks at
10
However, to maintain our
those areas.
11
Our
by
inspections
12
completed
13
documented by May 13th.
14
April
29th,
MEMBER POWERS:
are
scheduled
to
and
then
report
I'm a little unclear.
15
What is it that you are looking for?
16
respond to beyond design basis events?
17
MR. KOBETZ:
the
be
Their ability to
Well, it's to look to make
18
sure that the things that they've put into place for
19
some of these other things, such as 50.54(hh)(2),
20
station
21
maintaining them and that.
blackout,
22
they
are
still
--
they
are
But the fourth one is to look at, okay,
23
let's say we do have the fire and the flood and the
24
earthquake
25
vulnerabilities?
at
the
same
time.
What are the
Are there things that they need to
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1
put in place?
Are they putting things in place into
2
their corrective action program?
3
But, again, it's a high-level look to see,
4
are there some vulnerabilities that we haven't noted
5
before?
6
what should we maybe do about it down the road?
7
And what is the industry doing about it?
MEMBER CORRADINI:
And
I'm kind of with Dana.
8
I want to understand the logic.
9
was the -- what's called the Information Notice, to
10
kind of list the stuff.
11
That's the wrong word.
12
So the first logic
I'll call it an inventory.
Now, you are going out with staff to look
13
at the list and say, "Okay.
14
status of these items relative to their originally
15
intended function?"
16
or you are going to look at the same things and their
17
maintenance and upkeep for what exactly?
18
What is the current
And then, you are going to ask --
I understand Step 1, which is you were
19
supposed to do this, what's the list, now I am going
20
to go out and make sure that the list is there and
21
it's being maintained per the original objective.
22
Now, the second part of that I'm still --
23
24
MR. KOBETZ:
Well, actually, it's the
fourth part --
25
MEMBER CORRADINI:
Okay.
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1
MR. KOBETZ:
-- is the licensee would be
2
going out and performing walkdowns of other equipment
3
-- tanks, things that could be lost that maybe weren't
4
considered in the original design basis of the plant
5
but need to be looked -- or they think could cause a
6
vulnerability, maybe not.
7
at those types of things.
8
9
But it's to look, you know,
MEMBER CORRADINI:
All right.
sorry I can't get a hold on this one.
I mean, I'm
So do they know
10
what they are looking for?
11
struggling
12
objectives and what they have installed it for, and I
13
understand that you want to make sure that what is
14
installed is there and being properly maintained.
here.
That's what I'm -- I'm
I understand their original
15
But the fourth thing I'm -- it seems a bit
16
fuzzy, so I'm trying to understand what -- what is an
17
applicant going to do there, and what is the staff
18
going to do versus the applicant's stuff onsite?
19
MR. RULAND:
regional
staff
Right now, what the staff --
20
the
and the inspectors have been
21
assigned to do is not only to kind of look at what
22
licensees are doing, but to independently examine the
23
site, think about potential flooding, dam failures,
24
whatever external events that site could affect, write
25
that down and provide it to us.
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And what that is going to do is inform the
2
task force, oh, here is what so-and-so inspector at
3
such-and-such
4
vulnerability, and that will -- that information --
5
because we're not going to do anything about it at
6
this stage, that information then would go to the task
7
force, be examined by not only the task force but NRR
8
management, and, okay, what do we need to do about
9
this?
a
plant
identified
as
a
potential
It's basically going to feed into our overall
10
picture of, what do we need to do to respond to this
11
event?
12
MEMBER CORRADINI:
But let me just push
13
back a little bit.
14
the staff -- your staff, I mean, inspection staff
15
that's going out, to put it crudely, do they have a
16
menu or a thinking process they are going to use as
17
they go doing this looking?
18
could get soup to nuts.
19
MR. RULAND:
20
MEMBER CORRADINI:
21
So I understand the objective, but
If the answer is no, you
And that's -That's what I'm worried
about.
22
MR. RULAND:
That's -- well, I would argue
23
that that's not a worry; that's an advantage.
We've
24
got 104 sites out there.
25
They know what their FSAR says, and they have a decent
Inspectors know the plants.
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1
idea of what are those potential events.
2
something that the staff got out very quickly.
3
just our initial look at what is going on out there.
4
It is not the -- in any shape or form the final
5
statement about what licensees need to do or do not
6
need to do.
7
8
MEMBER CORRADINI:
This is
It is
That part I get.
I
understand.
9
MR. KOBETZ:
that
we
are
And to help focus, one of the
10
things
doing
--
because,
you
know,
11
obviously we do have 104 sites, 65 reports.
12
weekly calls.
13
different regions to talk about things that they are
14
finding, so they can exchange information.
15
there is something at a plant that one inspector
16
identified that another inspector didn't think to look
17
at, and so we are trying to do that.
18
said, this is the first of -- just to feed in.
We have
We start having weekly calls with the
19
MEMBER CORRADINI:
20
MEMBER SIEBER:
Maybe
But, as Bill
Okay.
You're actually inspecting
21
for the current requirements of the plant as opposed
22
to tasking inspectors to figure out what happened at
23
Fukushima, and how should you change the plant.
24
me, that's two different things.
25
treating it as two different things, which is the
To
I think that you are
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1
appropriate way to do it.
2
Until your task force is done analyzing
3
what happened in Japan, that's the only way you can
4
decide what new requirements you need to put on plants
5
here to protect against that same thing.
6
So
you
are
deciding
conditions,
8
changing the rules to make that happen, and sometime
9
in the future there will be an inspection to make sure
it.
needs
to
be
existing
7
did
what
determining
changed,
10
everybody
And that's what -- how I
11
understand, in simplistic terms, what it is you're
12
doing now.
Is that correct?
13
MR. RULAND:
Yes.
14
MR. KOBETZ:
That was all of the -- my
15
presentation, if there's no other questions.
16
CHAIRMAN ABDEL-KHALIK:
17
MR.
WESTREICH:
Thank you.
My name is Barry
18
Westreich.
I'm going to talk about the task force.
19
We have talked about it quite a bit already, so that
20
there is a lot of the details we have already gone
21
over.
22
force, so -- I have spoken to them.
23
started their efforts, and we are providing input to
24
them as they begin to understand what their efforts
25
are going to be.
And just to clarify, I am not on the task
I know they have
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1
But on March 23rd, the Commission directed
2
the staff to establish this task force.
3
methodical review and will recommend near-term actions
4
to improve our regulatory system.
5
from
6
independent review.
7
staff and others a variety of our current status and
8
the areas where we need to go in the future.
the
industry
9
efforts,
so
It is a
It is independent
it
is
our
own
And they will be discussing with
As on the slide, they have a number of
10
milestones.
11
Commission meeting, which the date is May 12th.
12
then, the 60-day meeting on April 16th, and the 90-day
13
meeting corresponds with the issuance of their final
14
near-term report, which is on July 19th.
15
The first milestone is a 30-day
And
And then, they are also looking at a
16
longer term.
17
start no later than the issuance of the 90-day report,
18
and it will extend for six months.
19
And as Bill indicated, that effort is to
They are looking at specific information
20
on sequence of events.
21
talked about today they will be looking at in greater
22
detail -- potential interagency issues and policy
23
issues, as well as lessons learned for non-operating
24
reactors, non-power reactors.
25
A lot of this stuff we have
They intend to have extensive interaction
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1
with the key stakeholders, and they will issue a
2
report at the end of that six-month period for the
3
longer term effort.
4
ACRS has been asked to review that and report back to
5
the Commission on their findings.
6
And then, as you indicated, the
MEMBER CORRADINI:
Is there -- I'm sure
7
there is.
8
a to-do list and a schedule that goes along with three
9
months, and then the further meeting, that is out
10
Is there a -- for want of a better word --
there?
11
MR. WESTREICH:
Well, my understanding,
12
they do have a charter that has been developed, but I
13
think they are still reviewing kind of the world, the
14
universe of issues they might want to consider in --
15
16
MEMBER CORRADINI:
But they are still
developing this.
17
MR. WESTREICH:
They are.
18
MEMBER CORRADINI:
19
MR. WESTREICH:
20
CHAIRMAN ABDEL-KHALIK:
Okay.
As far as I know.
Now, most of our
21
plants are located on multi-unit sites.
And yet many
22
of our safety-significant decisions are made on an
23
individual unit basis.
24
that.
25
unit basis rather than site-wide basis.
There are many examples of
The estimated risks are done on an individual
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1
Our operator training programs, simulator
2
training scenarios, design of full-scale simulators,
3
the role in training of shift technical advisors,
4
given what happened, should we change our paradigm and
5
address issues based on site-specific evaluations,
6
general site evaluations rather than unit-specific
7
evaluations?
8
9
10
MR. WESTREICH:
Well, I think those are
all good issues that the task force I'm sure will be
wrestling with.
11
CHAIRMAN ABDEL-KHALIK:
12
MR. RULAND:
13
MR. WESTREICH:
14
Okay.
That's it, right, Barry?
Yes, that's it.
So now we
tag-team to the next group.
15
MR. RULAND:
16
(Pause.)
17
MR. RULAND:
Yes, right.
Next group?
I've just advised the NRC
18
staff that we have like 51 minutes left, so kind of
19
march -- you know, let's try to -- because I know the
20
ACRS members want to address each one of these issues.
21
MR. ALI:
Yes.
I'm Syed Ali from the
22
Office of Research SL, Structural Issues, and I'm
23
going to give you a brief overview of the seismic
24
environment or seismic background.
25
So this earthquake was magnitude 9 on the
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1
Richter scale.
2
the Fukushima site.
3
about 80 miles from the epicenter was in the range of
4
1 to 2.75 g.
5
The epicenter was about 109 miles from
The peak ground acceleration at
A couple of slides down I will give you a
6
little bit more on the Fukushima site itself.
7
question that came up in the beginning about the
8
hazard, we don't have probabilistic data, but we do
9
have some comparisons of the design versus the
10
The
observed.
11
MEMBER SHACK:
How about their procedure
12
for developing a design earthquake?
13
go through a seismic hazard analysis somewhat akin to
14
what we do, or do they go strictly on historical
15
record?
16
MR. ALI:
kind
a
Well, I think they are in the
17
same
18
previously, they were more deterministic, and now they
19
are trying to do more of hazard assessments.
20
this particular plant, from what we know it was, you
21
know, deterministic basis.
22
of
Does it sort of
phase
MR. RULAND:
that
we
are.
You know,
But for
But we have been working very
23
closely with the Japanese in this particular seismic
24
area.
25
happened on Friday, the 11th of March.
As a matter of fact, the event, if you recall,
Their seismic
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1
experts were here in country for the RIC, and our
2
seismic experts were meeting with them during that
3
time.
4
MR. ALI:
That's right.
I was actually in
5
that meeting all day long with them and their Director
6
of the Seismic Division.
7
and forth to the Ops Center to, you know, find out the
8
status of what is happening and kind of updating us.
9
So, yes, we do have a cooperative research program
10
That was JNES was going back
with JNES.
11
The tsunami data -- we say peak amplitude
12
reports vary, because looking at different reports we
13
get different numbers.
14
they
15
interpreted differently, but we have numbers anywhere
16
varying from 14 meters to 23 meters from the wave
17
height.
were
observed
Now, that could be because
at
different
locations
or
18
The design basis number -- again, we don't
19
have the exact numbers right now, but that also varies
20
anywhere from five to 10 meters.
21
some reports stating that the reactors and the backup
22
power sources were located 10 to 13 meters above the
23
sea level.
24
will be getting more details on and firm up the
25
numbers as we move along.
And we have seen
But, you know, this is something that we
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1
MEMBER STETKAR:
2
MR. ALI:
3
MEMBER
Syed?
Yes.
STETKAR:
That's the diesels.
4
Where are -- the switchgear was located relatively low
5
in the plant, though, wasn't it?
6
MR. ALI:
7
MEMBER STETKAR:
That I don't know.
Okay.
But, I mean, you
8
can have survivable diesels but no -- they seem to be
9
having problems connecting electric power to things.
10
MR. RULAND:
11
MEMBER
12
Right.
STETKAR:
Because of flooded
switchgear.
13
MR. RULAND:
Right.
It's the whole suite
14
of what, you know, you need the diesel for -- the
15
tanks, the diesels, and the switchgear, all of them,
16
right, is what could have been affected.
17
MR. ALI:
Actually, I was in Japan.
I
18
went there as a part of the second team and just came
19
back a couple of days ago.
20
emphasis right now is to deal with the current crisis
21
and not -- not deal so much with the -- you know, how
22
it happened, but, you know, deal with the crisis as it
23
unfolds.
24
25
And, you know, their
The next -- this slide gives a little bit
of
a
flavor
of
the
design
basis
peak
ground
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1
acceleration versus the observed.
2
here for -- you know, this is kind of a representative
3
number for Unit 2.
4
observed.
5
And what you see
The design was less than the
The observed was more.
We do have numbers for the other units
6
also, so from the records that we have seen, or from
7
the reports we have seen, for Daiichi, three of the
8
six units had observed accelerations greater than the
9
design.
10
design or a little bit less than the design.
11
12
And the other three were either close to the
MEMBER ARMIJO:
What was Unit 4?
it --
13
MR. ALI:
14
maximum was less than the design.
Unit 4 was -- actually, the
15
MEMBER ARMIJO:
16
MR. ALI:
17
observed as more than the design, Units 2, 3, and 5.
MEMBER ARMIJO:
19
MR. ALI:
And the other three units were
MEMBER SIEBER:
Now, your observed numbers
come from seismic instrumentation?
23
MR. ALI:
24
MEMBER SIEBER:
25
Okay.
less than the design.
21
22
So it was --
Yes, 2, 3, and 5 -- 2, 3, and 5
18
20
Was
Right.
Okay.
It's unusual to see
such a variation over a short distance, unless there
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1
is soil --
2
MR. ALI:
Right.
3
MEMBER SIEBER:
4
MR. ALI:
It could be part --- or something like --
-- partly because of the soil,
5
partly, you know, as was discussed here, that the
6
level of the different buildings is different also.
7
8
MEMBER SIEBER:
I can picture how it would
happen, but it's sort of unusual anyway.
9
MR. ALI:
Yes.
So from the numbers that
10
I have here, the observed varies from 319 gal to 550
11
gal, like 300 -- .3 g to about .55 or .56 g.
12
13
MEMBER STETKAR:
One centimeter per second
squared.
14
MEMBER REMPE:
15
MR. ALI:
Dennis has the answer.
You have to divide by 90 D1 to
16
get gs.
So g would be a little bit more.
17
.55 -- or 500 gal, that might be .56 or .57 g's.
18
19
MEMBER STETKAR:
Thank you.
Thank
you.
20
21
Okay.
So if it's
MR. ALI:
But that's all I have, you know,
as far as the overall background.
22
MEMBER SIEBER:
23
MR. WILSON:
Thank you.
My name is George Wilson.
24
I'm the Electrical I&C Branch Chief right now in NRR.
25
I'm
going
to
be
basically
going
over
how
we
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1
implemented a station blackout rule here for the
2
plants in the United States.
3
In 1988, we -- NRC issued a station
4
blackout rule that required every plant in the United
5
States to be able to take a station blackout and
6
recover from it for that -- for a specified duration.
7
We issued Regulatory Guide 1.155, which endorsed the
8
NUMARC 87-00 standard, that is the standard the
9
industry used to implement the station blackout rule.
10
We also performed evaluations and issued
11
safety evaluations for all 104 plants, and performed
12
eight pilot inspections, two in each region, to get a
13
feel for what we -- make sure they had implemented the
14
rule correctly, and no major issues were identified
15
during those inspections.
16
17
First, I want to go over what we classify
to be the --
18
MEMBER BROWN:
What was the specified
19
duration that you listed in the second -- I just don't
20
remember --
21
MR. WILSON:
Four hours.
22
MEMBER BROWN:
23
MR. WILSON:
24
MEMBER BROWN:
25
MR. WILSON:
Four hours?
Right.
Thank you.
It will be for batteries, and
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1
I'll explain that in a little bit.
2
MEMBER BROWN:
3
MR. WILSON:
Okay.
First, I want to explain what
4
coping is.
The coping duration is actually the time
5
that you get a station blackout event until you either
6
restore
7
generator, so you get the power back.
8
durations were evaluated on the design of the plant
9
for both onsite and offsite power systems.
offsite
10
power
or
you
restore
a
diesel
And the coping
The offsite power systems would be the
11
redundancy of the different lines coming into the
12
switchyard, and also the chances that they would have
13
a loss of offsite power.
14
were located by the severe weather.
15
onsite would be the redundancy of the diesel
16
generators
17
generators.
18
and
the
That could be where they
reliability
of
the factors
the
diesel
We allowed two different types of coping
19
mechanisms.
20
battery only.
21
-- they could only cope with a station blackout for
22
four hours on the batteries.
23
four hours, they had to make modifications to the
24
plant or they had to have an alternate AC source.
25
One was AC-independent, and that means a
We only allowed each nuclear powerplant
So,
and
the
If it was longer than
alternate -- and on the
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1
alternate AC source, they analyzed how long it would
2
take them to get back the power, and they use that for
3
two to 16 hours.
4
has a 16-hour coping, and that means they have to have
5
all of the fuel oil and everything to run that plant
6
for -- those diesel, that other supply, for 16 hours.
7
Forty-plants are battery coping plants; 60 plants are
8
alternate AC plants.
9
There is one three-unit site that
The big key on the station blackout is
10
that it required every plant to have procedures to be
11
able to recover from the station blackout, and those
12
procedures specifically recovered the restoration of
13
AC power.
14
generator troubleshooting plans that were made.
15
also addressed to be able to hook up temporary power.
16
That means that they enhanced the diesel
And
they
also
have
--
during
They
Generic
17
Letter 2006-02 that we issued with the grid interface,
18
we ensured that every nuclear powerplant have an
19
interface agreement with their local grid operator to
20
ensure that they would be the primary source to
21
restore power first, if offsite power was lost.
22
They also evaluated non-essential DC loads
23
for
stripping
to
increase
the
capacity
of
the
24
batteries.
25
lighting in the control room, they could break that
And some examples of that would be
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1
down,
or if the diesel generator start circuits
2
actually come from the battery, they could open that
3
up, so that at least it wouldn't continue to try to
4
start.
So they would strip some of the loads down.
5
They also took actions for a loss of
6
ventilation
7
cooled, or looked at potentially bypassing some of the
8
isolation circuits that would cause an isolation for
9
HPSI and RCIC.
10
to
ensure
that
the rooms were being
And, like I said, you know, they had
grid interfaces.
11
MEMBER STETKAR:
George, I suspect I know
12
the answer to this -- or at least your answer -- do we
13
know whether the Japanese had similar station blackout
14
coping procedures?
15
MR. WILSON:
I do not know.
16
MEMBER SIEBER:
I think the more important
17
question is -- Fukushima had the event.
At the time
18
of the flooding, that was the start of the station
19
blackout.
20
damage?
21
Ten minutes?
22
you the validity of the four-hour, eight-hour, what
23
have you, stipulation in our rules.
24
the answer to that timing question?
25
MR. RULAND:
How long did they last until they got core
Was it four hours?
Eight hours?
Two hours?
If you could answer that, that will tell
Does anybody know
We don't know specifically
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1
what the answer is.
2
that the NRC has done some analysis as part of the
3
SOARCA program to estimate -- if you remember, the
4
Peach Bottom sequence in there is very similar to what
5
was done, right?
6
power, no recovery, right?
7
we did.
8
9
10
So
But, you know, of course you know
It's basically loss of offsite
that
could
And that was the analysis
help
inform
us
about
approximately, you know, when core damage could have
started.
11
MEMBER SIEBER:
But I think it would be
12
important to look at this event to see -- as another
13
way to validate what we believe station blackout or
14
duration time really is.
15
MR. RULAND:
16
MEMBER SIEBER:
17
Yes, correct.
And I would like to know
the answer, if I could find out somehow.
18
MR. RULAND:
Yes, sir.
19
MEMBER SIEBER:
20
MR. RULAND:
21
MR. McDERMOTT:
Okay.
Thank you.
That will be on our plate.
Good morning.
My name is
22
Brian McDermott.
I'm the Director for the Division of
23
Preparedness and Response in NSIR, and I'm going to be
24
speaking about NRC's incident response relative to
25
this incident.
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1
Shortly
after
4:40
a.m.
on
Friday,
2
March 11, the NRC headquarters operations officers
3
made the first calls to inform NRC management of the
4
earthquake
5
significant threat to NRC licensed facilities, it
6
quickly became evident that the Fukushima Daiichi site
7
had multiple units in a station blackout condition,
8
and that we would need to engage our stakeholders.
9
in
Japan.
Although there was no
In order to coordinate interactions with
10
federal partners, NRC elected to staff the NRC
11
Operations Center with a liaison team.
12
requests for technical and radiological assessment
13
began coming in, staffing was expanded to include a
14
reactor safety team and a protective measures team.
However, as
15
Later that day, in response to a request
16
from the U.S. Ambassador in Japan, the NRC discharged
17
two senior staff to provide technical assistance at
18
the U.S. Embassy in Tokyo under the umbrella of the
19
USAID disaster assistance response team.
20
days, seven additional staff were dispatched to assist
21
the Embassy and serve as technical liaisons with
22
Japanese counterparts.
23
Within a few
Since March 11, we have continued around-
24
the-clock
staffing
in
the
Operations
Center,
25
maintained the multi-discipline team in Japan.
and
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1
Actions to stabilize the situation at
2
Fukushima are ongoing, and so is NRC's response.
3
NRC's role in the events at Fukushima has really been
4
primarily
5
coordination assistance.
6
Embassy
7
situation and make recommendations relative to the
8
protection of U.S. citizens.
to
in
9
provide
Japan
In
in
technical
and
We are supporting the U.S.
its
addition,
assessment
efforts
we
are
to
assess
supporting
the
the
10
Japanese government by responding to their technical
11
questions and coordinating efforts in the U.S. to
12
address other requests for assistance.
13
also been working domestically with federal partners
14
on the issue of trace radionuclides detected here in
15
the United States.
The NRC has
16
Under the national response framework, the
17
Environmental Protection Agency has the lead role for
18
such events.
19
provided peer reviews for technical papers and worked
20
with
21
monitoring data.
However, in a support role, the NRC has
licensees
on
the
sharing
of
radiological
22
In terms of our coordination, support, and
23
outreach, we utilized our knowledge regarding the
24
basic boiling water reactor designs at Fukushima.
25
has been able to provide significant support to other
NRC
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1
agencies
as
they
assess
the
event and evaluate
2
potential impacts on their missions and personnel.
3
In order to develop the best possible
4
technical responses to questions received from Japan,
5
the NRC's reactor safety team has been working closely
6
with nuclear experts from other civilian agencies, the
7
Department
8
Institute for Nuclear Power Operations.
of
Defense,
General
Electric,
and
the
9
Relative to our dose assessments and plume
10
modeling, the protective measures team has worked
11
closely with the Department of Energy counterparts,
12
and the National Atmospheric Release Advisory Center,
13
also known as NARAC.
14
liaison team has been working to ensure a timely
15
exchange
16
congressional
17
partners, and international organizations such as
18
IAEA.
of
19
Throughout the event, the NRC's
information
with
stakeholders,
the
federal
White
House,
and
state
Regarding our continued support for the
20
response, as I noted earlier, the Operations Center
21
remains staffed, and we continue to have the team in
22
Japan.
23
in learning lessons from the events at Fukushima, this
24
remains an ongoing event.
25
today
And while there are many of us very interested
is
often
The information available
incomplete
and
difficult
to
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1
corroborate.
2
As the situation on the ground improves,
3
and
our
Japanese
4
additional details, I fully expect and support a
5
thorough examination of the facts by the NRC's newly
6
formed task force, as the lessons learned will help
7
strengthen our domestic preparedness.
8
9
counterparts are able to share
I am prepared to answer any questions you
might have.
10
MEMBER POWERS:
11
You
said
12
radiation.
you
were
Question on the dispersal.
working
on
the
dispersal
of
13
MR. McDERMOTT:
Yes, sir.
14
MEMBER POWERS:
What computational tool
15
are you using to estimate the amount of dispersal that
16
you get?
17
MR. McDERMOTT:
We are going to have a
18
presentation by Randy Sullivan next, and we are going
19
to talk about our dose assessment in particular.
20
MEMBER
POWERS:
Well, I was more
21
interested in the -- it's a substantial distance from
22
Japan to our --
23
MR. McDERMOTT:
Yes.
The short answer is
24
that NRC has the RASCAL code, which we use to generate
25
source terms.
However, dose projections in terms of
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1
plume for RASCAL only go out 50 miles.
2
quick-look tool in the Operations Center.
3
official U.S. Government position on plume modeling,
4
we coordinate with NARAC, and we do that -- practice
5
that
6
capability to model over a greater distance.
during
7
our
exercises.
MEMBER CORRADINI:
That is our
For the
And they have the
So was -- is this the
8
appropriate to ask a question on that?
9
release on the 16th of March and an appendix, which
10
looked like it was from the RASCAL code.
11
12
MR. McDERMOTT:
We're going to speak to
that.
13
14
So I saw a
MEMBER CORRADINI:
You're going to speak
to that.
15
MR. McDERMOTT:
I guess, yes.
16
MEMBER CORRADINI:
So can I ask the -- I
17
will save that part of the question.
My second part
18
of the question is:
19
simultaneously so there is more refined analysis that
20
is available to you?
are NARAC calculations being done
21
MR. SULLIVAN:
Simultaneously?
22
MEMBER CORRADINI:
I --
Well, I mean, you are
23
doing the RASCAL calculations very quick.
But the
24
NARAC calculations I thought were also being -- I
25
thought were available.
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1
MR. SULLIVAN:
They are not simultaneous.
2
They take many hours to do, and it's not simultaneous,
3
as you're saying.
4
but that's more for follow-on than happened on the
5
16th.
6
We are working on some comparisons,
MEMBER
CORRADINI:
7
calculations by the 16th?
8
MR. SULLIVAN:
9
MEMBER POWERS:
There were NARAC
On the 15th, that's right.
Let me ask you one other
10
question.
11
learn sorts of things about licensees and accidents
12
and what not.
13
you have within the Operations Center to see if there
14
are tools that could be refined, improved, created,
15
gotten rid of, whatever it is that should be done with
16
that, to -- I mean, this is a wonderful exercise for
17
you in the sense that you can have a certain
18
detachment from it, but it gives you some hint, if you
19
weren't so detached.
20
with a set of -- maybe it's in the longer term, but --
21
We have this team that has been set up to
Will you be looking at the tools that
And will you be coming forth
MR. McDERMOTT:
It will be.
We are going
22
to do the lessons learned relative to the functions
23
within
24
valuable learning experience for us on how we work as
25
a team in response to emergencies.
the
Operations
Center.
This was a very
You know, you
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1
learn a lot of things just from the fact that we were
2
running around-the-clock operations now for the last
3
several weeks.
4
So there is a lot of logistical and
5
integration type things we can learn, but the tools
6
are certainly on the list of things we need to take a
7
hard look at.
8
9
MEMBER POWERS:
think
the
chore
don't
managing
around
want
underestimate
to
the
clock
10
operations,
11
difficulty there.
12
expertise in that, but the tools we might be very
13
interested in.
14
around the clock, but it doesn't involve managing lots
15
of people.
16
I
of
I think the -- I mean, I
the
The Committee here has very little
Sometimes our Committee may seem to go
MR. SULLIVAN:
I had the privilege of
17
staffing several shifts around the clock, and I don't
18
know that detached would be the right word.
We are
19
heartsick
we
20
everything we could to support them with our technical
21
expertise.
22
23
the
events
MEMBER BANERJEE:
in
Japan,
and
did
Are you going to talk in
-- about these RASCAL --
24
25
over
MR. SULLIVAN:
I'll talk about them, yes.
Let's go to the next slide.
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1
MR. RULAND:
Before we move on, just -- I
2
want to emphasize for the support for the Ambassador
3
and the U.S. Government as a whole, there was -- you
4
know, the NRC is just one part of the overall federal
5
family, right?
6
Defense,
7
integrated well with all of those organizations.
There's the Department of State,
Energy,
right?
And I think we have
8
Go ahead, Randy.
9
MR. SULLIVAN:
Well, I was going to start
10
by talking about EPZs, but I think you all already
11
know this.
12
MEMBER SIEBER:
13
MR. SULLIVAN:
14
If
15
So go to the next slide.
want
to
talk
about
the
recommendation, I'm prepared to do that.
16
17
you
Yes, we know that.
MEMBER
BANERJEE:
This is of great
interest.
18
MR. SULLIVAN:
So I thought.
I wasn't
19
sure we would have time for it, but apparently we do,
20
so --
21
22
MEMBER
announcement.
23
24
SIEBER:
It's a yellow
I think we all read it.
MR. SULLIVAN:
Okay.
Do you want a
presentation, or do you want to ask questions?
25
MEMBER CORRADINI:
Yes.
Well, I guess my
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1
first question -- I just wanted to know that the
2
release -- I don't know if it was on the 16th or 17th
3
-- there a click point on the PDF that had an output.
4
MR. SULLIVAN:
5
MEMBER CORRADINI:
6
But there was no input.
So I'm asking a simple engineering question --
7
MR. SULLIVAN:
8
MEMBER
9
Yes.
Sure.
CORRADINI:
-- where is the
complete calculation?
10
MR. SULLIVAN:
I'm sorry.
11
MEMBER CORRADINI:
Ask that again?
Where is the complete
12
calculation, so I can see the source, the assumed
13
source, and the assumptions?
14
15
MR. SULLIVAN:
MEMBER CORRADINI:
Okay.
But it wasn't
released?
18
MR. SULLIVAN:
19
MEMBER CORRADINI:
20
MR. SULLIVAN:
No, it was not.
you, if that's what you want.
22
off our assumptions.
23
Okay.
But I can rattle it off for
21
24
We
have a book of RASCAL stuff.
16
17
Well, that's available.
MEMBER CORRADINI:
I mean, I can rattle
That's what I guess I
was --
25
MEMBER BANERJEE:
Do we have this written
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1
down somewhere?
2
MR. SULLIVAN:
3
MEMBER SIEBER:
4
I think so, yes.
That would be a better way
to give it to us.
5
MR. SULLIVAN:
6
MEMBER BANERJEE:
7
Okay.
But weather conditions,
wind velocity, everything.
8
MR. SULLIVAN:
9
MEMBER SIEBER:
Sure.
Well, and the other factor
10
that I think is important is, do you have more than
11
one reactor?
12
MR. SULLIVAN:
13
MEMBER SIEBER:
14
So you had a bunch of
different source terms.
15
16
Yes.
MR.
SULLIVAN:
Unfortunately, RASCAL
doesn't handle a bunch of different source terms.
17
MEMBER SIEBER:
18
works.
19
there someplace.
I understand how RASCAL
That's -- so there has to be a compromise in
20
MR. SULLIVAN:
21
MEMBER SIEBER:
Exactly.
Source term -- you can't
22
really tell what it is because it's multiple sources
23
that came at different times?
24
MR. SULLIVAN:
25
MEMBER SIEBER:
That's right.
And as far as I could
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1
tell, neither the licensee nor the officials in Japan
2
knew exactly what the source term strength was and
3
what
4
difficult to make an evacuation recommendation under
5
those circumstances.
its
composition
6
was.
So it becomes very
CHAIRMAN ABDEL-KHALIK:
I understand that
7
a request has been made to provide that information in
8
written form.
9
MEMBER SIEBER:
10
Yes.
CHAIRMAN ABDEL-KHALIK:
But I think it
11
would be very informative to us if you just go ahead
12
and
13
calculation was based.
talk
about
14
the
assumptions
MR. SULLIVAN:
on
which
this
I'm assuming that the task
15
force will be looking at this in some depth.
I'll
16
provide what I know from a response person's point of
17
view.
I wasn't there for the calculation.
18
But I have to set the stage for you a
19
little bit.
20
and of course this record is known.
21
explosion at Unit 1 on the 12th.
22
explosion at Unit 2 -- I'm sorry, Unit 3 on the 14th,
23
and an explosion at Unit 2 on the 15th.
24
25
I'm not sure about these times, but -There was an
There was an
Before that time, the NRC's position was
that
we
were
advising
the
Ambassador to advise
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1
citizens
to
2
Recommendation.
3
well, the morning of the 16th, we were very much
4
worried about the status of the spent fuel pools, in
5
addition to the reactors.
6
obey
Our
the
Japanese
Protective
Action
We performed a calculation that --
vision
was
what
you
might
have
7
expected in a spent fuel pool in America, and that
8
would be a lot more fuel in them than turns out to be
9
the case, which we learned several days later.
10
were very worried about the spent fuel pools.
11
So we
We were not getting succinct information,
12
as
you
might
imagine.
We did talk to a NISA
13
representative on the morning of the 16th, and we
14
didn't get much information that would tell us things
15
were going in the right direction.
16
his best to inform us of what he knew, but that wasn't
17
at all what we would have expected in a nuclear event
18
in the U.S.
The gentleman did
19
That being the case, my staff -- I'm the
20
protective measure team's director, developed a source
21
term that they thought would represent the potential
22
situation using the tools we had -- that's RASCAL.
23
NARAC takes a couple of days to perform -- well,
24
several
25
calculation.
hours, and perhaps longer, to perform a
So we needed to use the tool that we had
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1
-- that was RASCAL.
2
We did a calculation that would give you
3
-- the details do exist, and whether the task force
4
looks into that deeper or they can be provided, we
5
will have to get back to you on that.
6
source term was 100 percent fuel damage in Unit 2, and
7
literally no -- it was assumed to be ex-vessel and an
8
unfiltered, totally failed containment.
9
failed," that is typically 100 percent a day.
10
MEMBER CORRADINI:
But the first
By "totally
So it was 100 percent
11
release bypass.
12
whether or not you have containment bypass.
13
assume containment bypass.
14
As you use RASCAL, it asks you
MR. SULLIVAN:
I think we did not.
You
I
15
think we assumed failed containment.
But I could be
16
wrong on that, so we'll have to get back to you on
17
that.
18
are embedded in RASCAL, and I just don't know which --
The difference is some plate-out factors that
19
MEMBER CORRADINI:
20
But approximately what you're saying is --
21
22
MR. SULLIVAN:
That's fine.
Okay.
Yes, it's a big release is
what I'm approximately saying.
23
MEMBER SIEBER:
You have scrubbing and
24
plate-out, but otherwise it looks like a Chernobyl
25
source term.
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1
MR. RULAND:
Randy?
2
MR. SULLIVAN:
3
MR. RULAND:
I wouldn't say that.
Yes?
I understand you are trying
4
to be responsive to the Committee here, but I'm
5
getting the sense that we need to have some more
6
refined numbers and answers to the Committee.
7
would ask some forbearance on the Committee, and let's
8
get something in writing and provide that to the
9
Committee.
10
MEMBER ARMIJO:
So I
Well, Bill, I want to make
11
sure that we get the analysis and the numbers that
12
were actually used in coming up with this decision,
13
because, clearly, there were -- a number of
14
conservatisms were made, and as time goes on we will
15
find out how conservative they were, and we can look
16
back and -- on this decision.
17
the actual analysis as it was done at the time.
18
MR. RULAND:
But I would like to see
We understand, and we will --
19
you know, we will be responsive to the Committee.
But
20
as you can imagine, as Randy has already alluded to,
21
right, this -- typically in an emergency event, right,
22
we are going with the best available information that
23
we have at the time, which was based on essentially
24
press reports and our inferences that we were drawing
25
based on what we knew.
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While the individual that Randy had talked
2
to about, you know, the individual we had talked to,
3
it's not clear to us that that was the right person.
4
We
5
information internally for them.
6
their hands full, and, you know, so they were not, you
7
know, providing us detailed source term information
8
they were using.
suspect
9
that
the
Japanese
MEMBER CORRADINI:
what
just said?
fact
had
that
They clearly had
Can I just follow up
10
with
11
completely understand.
12
was a lack of data, or you're saying that there was
13
data and you weren't getting it?
14
you
in
MR. RULAND:
I'm sorry, I don't
So you're saying that there
We -- what we -- the data --
15
the only thing that we were doing is trying to make a
16
recommendation -- trying to help the United States
17
Government provide whatever information the Ambassador
18
needed relative to a recommendation for U.S. citizens.
19
20
MEMBER CORRADINI:
are we talking about?
21
22
MR. RULAND:
We're talking probably in --
where, in the --
23
MEMBER CORRADINI:
24
MR. RULAND:
25
How many U.S. citizens
that
question.
In that zone.
I don't know the answer to
You know, approximately 320,000
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1
Americans in Japan total, but I don't know in that
2
particular area.
3
to that question.
4
5
Don't know.
MEMBER ARMIJO:
Don't know the answer
There's a military base
in --
6
MEMBER CORRADINI:
I guess I'm -- this is
7
out of the realm of technical, but in some sense it's
8
in the realm of --
9
MEMBER ARMIJO:
10
Public confidence, really.
MEMBER CORRADINI:
one
way
of
11
be
12
reasonableness.
13
whether it was a lack of data or there was data there
14
and you were concerned that it was not being shared.
15
And if it was a lack of data, then I can understand
16
that,
17
blackout condition and go poking around in areas that
18
would be a bit hazardous.
19
to understand.
because
20
putting
it,
Public confidence would
but
in
the
realm
of
I guess I'm trying to understand
you'd
have
to
go
in
in
a
station
So that's what I'm trying
The other part of this technically is is
21
that if you look at the two calculations, the four-
22
unit calculation in our smaller doses -- are smaller
23
doses than the one unit calculation, which confused
24
me.
25
MR. SULLIVAN:
Okay.
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1
MEMBER
are
As a function of
2
distance,
3
assuming something on some refinement on four units
4
that you're not assuming on the one unit calculation.
5
So that also confuses me.
6
MR. SULLIVAN:
7
MEMBER CORRADINI:
8
they
CORRADINI:
different,
which
means
you're
Okay.
So I was left confused
on the 17th.
9
MR. SULLIVAN:
Okay.
10
MEMBER CORRADINI:
11
MEMBER BANERJEE:
Not informed.
Mike, maybe -- you were
12
just starting to tell us what your assumptions were.
13
Let's get through this, and then we will get back to
14
you.
15
16
MEMBER SIEBER:
down first.
17
18
I would like to write them
MR. SULLIVAN:
I thought we agreed that
some sort of written summary --
19
MR. RULAND:
20
MEMBER BANERJEE:
21
Yes.
if you would just do it qualitatively right now.
22
MR. SULLIVAN:
23
MEMBER SIEBER:
24
MR. SULLIVAN:
25
Yes, that's great, but
Sure.
Unit 2, 100 percent.
First off, I think we are
leaving you with the wrong impression about data and
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RASCAL.
We did not have any effluent monitoring data.
2
We did not have any spectral analysis from a plume.
3
All this is is an assumption given what we knew was
4
potentially the status of the reactors in the spent
5
fuel pool.
6
involved in this, "data" as in measurements.
There is no data from the site that's
7
MEMBER CORRADINI:
Well, I guess what --
8
I'm sorry that I'm picking on you, but you just happen
9
to be there.
It's just if you have a calculation that
10
is very quick to do, I would think I would have the
11
monitoring data that -- the airborne monitors that a
12
lot of us were looking at every day --
13
MEMBER SIEBER:
14
MEMBER CORRADINI:
Right.
-- every hour of every
15
day and asking, "How can I get a calculation that maps
16
up with what I see there to at least benchmark what
17
I'm calculating?"
18
MEMBER SIEBER:
19
MEMBER BANERJEE:
20
You can't do it.
You can do that in
RASCAL.
21
MR. SULLIVAN:
The wind was not blowing in
22
the direction of those monitors for the most part.
23
mean,
24
potential future dose rate, we are not looking at the
25
way the wind blew yesterday or the deposition on the
if
I
we're going to do an assessment of a
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1
ground.
We're using what we know to frame a potential
2
accident at the site, and then going forward with what
3
that hypothetically could result in.
4
MEMBER CORRADINI:
So to better understand
5
what you're saying is is that you were doing a what-if
6
calculation.
7
MR. SULLIVAN:
8
MEMBER CORRADINI:
9
That's right.
Not a benchmarking of
what you saw.
10
MR. SULLIVAN:
That's right.
I think we
11
got through the first calculation.
12
fuel damage.
13
containment bypass or failed containment.
That's a
14
piece
from
15
calculation record.
16
stable air, light precipitation, and a 16-hour release
17
duration.
of
It's 100 percent
I'm sorry, I don't know whether it's
information
that
we
can
know
the
And relatively low wind speed,
18
The second calculation assumed --
19
MR. RULAND:
20
MR. SULLIVAN:
21
MR. RULAND:
Randy?
Yes.
I think I had previously
22
stated that we were going to provide them -- the
23
Committee something --
24
MR. SULLIVAN:
25
MR. RULAND:
I'm happy to do that.
-- in writing.
And my -- I'm
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1
reluctant for you to provide this, so I'd ask the
2
Committee's forbearance, that we are going to -- we
3
will
4
matter.
provide
something
to the Committee on this
5
CHAIRMAN ABDEL-KHALIK:
6
MEMBER ARMIJO:
That's fine.
Well, can you tell us
7
something at least qualitatively on statements that we
8
read in the media that we knew that the spent fuel
9
pool in Unit 4 was dry?
10
That was the Chairman's
testimony on this.
11
And so, you know, was that in your
12
assumption, that the spent fuel pools were empty?
13
like to know as much as -- whatever you can tell us
14
about that.
15
16
MR. SULLIVAN:
MEMBER ARMIJO:
MR. SULLIVAN:
I know that.
-- or not, I don't know,
but certainly in bad shape you could know.
21
22
I know that.
I'm not disputing that, but --
19
20
Well, Unit 4 had -- reactor
building had experienced an explosion event.
17
18
I'd
MEMBER ARMIJO:
So your assessment was
that the Unit 4 fuel was the source of that explosion?
23
MR.
SULLIVAN:
There was limited and
24
uncertain data, and although our assumptions here
25
don't necessarily track, we, the staff, were worried
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about all the spent fuel pools.
2
unaware of the low heat loading in Units 1, 2, and 3,
3
and we were aware that mitigative actions were not
4
being taken.
5
You know, we were
Well, we thought -- we didn't know that
6
mitigative actions were being taken.
7
great pause.
8
pools in trouble, it was part of the limited and
9
uncertain
10
So that gave us
Although we didn't model four spent fuel
data
that
forced
this
conservative
and
prudent recommendation.
11
MEMBER ARMIJO:
The reason I'm pressing on
12
this is this was a very, very important decision.
13
I would have expected there would have been high-level
14
conversations between our regulatory bodies and our
15
government with equivalent people in the Japanese
16
government on the worst-case analysis that we were
17
doing.
18
Was there anything like that going on?
MR. SULLIVAN:
You know, I'm not aware of
19
what took place at a high level.
20
guy.
21
22
MEMBER BANERJEE:
I'm more of a staff
So these calculations
were done, and they went where after that?
23
MR. SULLIVAN:
24
MR. McDERMOTT:
25
And
To the Chairman, right?
They were assessed by the
executive team and discussed with the Chairman.
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1
2
MEMBER BANERJEE:
So it went to who in the
executive team?
3
MR. RULAND:
Typically, the executive team
4
is deputy office directors and office directors.
5
not recall who specifically was the executive -- the
6
ET director at the time that this recommendation was
7
made.
8
9
10
MEMBER CORRADINI:
But I guess Sanjoy
asked the question I think you wanted to get an answer
to.
11
12
I d
MEMBER BANERJEE:
Yes, I want an answer on
this.
13
MEMBER CORRADINI:
14
MEMBER BANERJEE:
15
MEMBER CORRADINI:
Who reviewed it?
Who reviewed it?
Because at least from
16
my standpoint, I think Sam kind of expressed it for a
17
number of us.
18
clearly
19
assuming
20
Before you started publicizing our what-if, I'd like
21
to have done some sort of comparison, because it
22
creates a -- it potentially can create a
23
misimpression.
24
25
We're a bit concerned about the fact
you did a what-if calculation, but I'm
the
Japanese
MR. RULAND:
did
a
what-if
calculation.
As everybody here I know is
well aware, under normal circumstances in the United
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1
States -- in the United States, there is no such thing
2
as
3
emergency planning.
4
what the recommendation is, right?
5
kind of our operating -- that's kind of the operating
6
presumption.
conservative
7
or
non-conservative
in
EP,
in
It's you try to get it right,
MEMBER CORRADINI:
I mean, that's
But let me reverse
8
this.
Thirty-two years ago, if Japan would have done
9
a what-if calculation about Three Mile Island, and
10
said all the Japanese within 50 miles of Harrisburg
11
should get out, what would be our response to that,
12
from a policy standpoint?
13
MR. RULAND:
14
MEMBER CORRADINI:
15
I can't answer that question.
Well, that's the sort
of thing that I think Sam --
16
MEMBER ARMIJO:
Well, it's just as we talk
17
to many people, they come up to us and ask us,
18
friends, associates, they say, you know, what was your
19
assumption,
20
Japanese regulators?
21
and
how
did
you
coordinate with the
And this is a very high-level decision, I
22
would think, and it would have -- you know, the
23
Chairman of the NRC called up his counterpart or the
24
Embassy and they say, "Hey, look, we're getting some
25
very, very different numbers, and what do you think?
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And we're thinking of getting our people out, and what
2
do you guys think?"
3
MR. RULAND:
As Brian McDermott said, one
4
of the things that we have to do for the incident
5
response program is do a hotwash.
6
our incident response to this event.
7
included, as well as all of the actions we have taken.
8
9
Basically, examine
And this will be
So we are going to examine how this
recommendation was made and/or whatever.
You know,
10
this will be part of our overall review of our agency
11
response to this matter.
12
CHAIRMAN ABDEL-KHALIK:
13
has
been
made,
14
detailed --
and
you
promised
15
MR. RULAND:
16
CHAIRMAN ABDEL-KHALIK:
17
I think the point
to
give
us
the
Yes, sir.
-- information to
support that calculation.
18
MEMBER SIEBER:
I don't want to prolong
19
the questioning in this area, and I would like to
20
leave aside whatever diplomatic issues are there.
21
But
States,
had
the
would
accident
your
occurred
calculation
in
and
the
22
United
your
23
recommendation, which would differ from state, local,
24
and utility recommendations be similar, or would you
25
have -- would you say, "This is the -- I think the
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1
whole reactor went, and I got all of these spent fuel
2
pools, and this reactor went, and that reactor went,
3
so we'll take 100 percent of all of it."
4
And I didn't have -- I didn't model the
5
topography, and I think the wind is going to blow it
6
over the mountain.
7
8
MR. SULLIVAN:
Because that goes to --
9
MEMBER SIEBER:
10
important thing right now.
11
12
Could we back up one slide?
MR. SULLIVAN:
That to me is the most
I mean, our expectation is
that if it were our licensee --
13
MEMBER SIEBER:
14
MR. SULLIVAN:
Right.
-- and our response in the
15
U.S. we would have better data, a very different
16
response,
17
measurements.
18
that, but we didn't.
and
we
would
have
much
better
plume
And maybe the Japanese had some of
19
MEMBER SIEBER:
20
MR. SULLIVAN:
Yes.
All right?
I want to point
21
out that the 10-mile EPZ is designed, tested, and
22
inspected to be able to perform response actions,
23
protective actions, within hours.
24
evacuation time estimates -- in the U.S. are 10 to 14
25
hours.
Our longest ETEs --
So that is the initial phase.
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1
We have always said that should it be
2
necessary, the EPZ -- the 10-mile EPZ provides a
3
substantial basis for expansion should that ever be
4
necessary.
5
We have studied some 250, some 50 or 60 in detail.
6
They are ad hoc evacuations for the most part.
7
are all successful.
8
authorities know how to evacuate people should there
9
be a threat.
10
We have studied evacuations in the U.S.
They all saved lives.
They
so local
So getting back to your question, we would
11
have
expected
12
measurements, better effluent monitoring, on and on.
13
14
different
data,
MEMBER SIEBER:
MR. SULLIVAN:
16
MEMBER SIEBER:
plume
Provided the licensee
We have people onsite.
You don't have NRC people
or any federal people out there with monitoring.
18
19
data,
provided that, because you don't have access --
15
17
more
MR. SULLIVAN:
We have state people out
there with monitoring.
20
MR. RULAND:
NRC
does
not
In addition, if I could add,
21
the
make
protective
action
22
recommendations.
23
understand, to do our own independent calculations, so
24
when the state or when the licensee makes protective
25
action recommendations to the local, county, or state
Our role in a U.S. event is to
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1
officials, who actually make the decision, we can
2
verify whether those recommendations -- you know, we
3
can do an independent check.
4
a U.S. event.
That is our role during
5
And so it is -- in this case, it was a
6
different role that the NRC was playing, it was
7
fulfilling.
8
9
MEMBER SIEBER:
It's exactly how that role
is portrayed in the United States that I would be
10
concerned about, you know.
11
needs more examination.
12
thank you.
And I think this area
I'll leave it at that, and
13
MR. SULLIVAN:
14
CHAIRMAN ABDEL-KHALIK:
15
MR. SULLIVAN:
16
Thank you.
Please proceed.
Well, I'm pretty much done.
I'm the last speaker.
17
CHAIRMAN ABDEL-KHALIK:
Let me just ask a
18
question about a topic that didn't come up in the
19
discussions, and that pertains to dry cask storage.
20
My understanding is that Fukushima had many dry casks,
21
and assisted with a lot of dry storage casks, is that
22
correct?
23
MR. SULLIVAN:
24
somebody?
25
I'm not --
Sorry.
Don't know.
Does
I heard not so many dry cask storage, but
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1
MEMBER ARMIJO:
2
CHAIRMAN ABDEL-KHALIK:
3
Nine.
Nine.
Okay.
And
that none of them was damaged, is that correct?
4
MR. McDERMOTT:
According to the TEPCO
5
reports, they performed walkdowns and did not identify
6
anything on their initial inspections.
7
they would be doing subsequent detailed examinations,
8
and they never reported out on that.
9
CHAIRMAN ABDEL-KHALIK:
They indicated
Was that due to
10
their inherent robustness, or was it because the pad
11
was located at a much higher elevator?
12
MR. McDERMOTT:
13
information at this time.
14
15
I don't think we have that
CHAIRMAN ABDEL-KHALIK:
Okay.
any additional questions to the staff?
16
MEMBER
CORRADINI:
Are there
Mike?
Just I wanted to
17
compliment the staff.
18
So I appreciate them coming on such short notice to
19
inform us.
20
away our aggressive questioning to imply anything
21
different.
22
talk to us.
23
This is kind of a tough area.
I guess I don't want to -- them to take
I really do appreciate the staff coming to
MEMBER ARMIJO:
I would like to provide
24
some feedback, if it's okay.
The thing that I think
25
I'm missing -- it's probably there -- is in the 30-day
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1
review, and then the 90-day review, I think it's very
2
important to get down to the root cause of the things
3
that failed, because before we start saying, "This is
4
what we've got to do to improve our plants here in the
5
United States," and not limit ourselves to a tsunami,
6
because
7
tsunami, but we may be subject to other things that
8
are worse than what we thought we had to deal with.
most
9
of
our
plants
aren't
subject
to
a
But I think it's very important to get to
10
the root cause of why some units survived well, and
11
why others didn't.
12
well, even at a working level, working hypothesis, I
13
think
14
recommendations on what to do about something that we
15
haven't really sorted out.
16
MR. McDERMOTT:
And until we know that fairly
it's kind of premature to be making
So -I would agree with you 100
17
percent.
18
very important for NRC, but, as I mentioned earlier,
19
this is an ongoing event.
20
some actions at this point in time that appear to have
21
brought some stability to the situation.
22
don't have enough information to verify that at this
23
time.
You know, they have taken
However, we
So --
24
25
I think understanding this event will be
CHAIRMAN ABDEL-KHALIK:
As I indicated
earlier, this briefing serves as the initiation of
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1
significant ACRS engagement on the followup activities
2
and lessons learned from the Fukushima event in order
3
to maintain public health and safety in the United
4
States.
5
While the Commission tasking for ACRS on
6
the subject of Fukushima is thus far specific to the
7
evaluation of the staff's longer term review, however,
8
the ACRS, consistent with its charter, will self-
9
initiate activities to be appropriately informed and
10
properly prepared to provide the best possible advice
11
to the Commission on an ongoing basis.
12
13
At this point, again, let me express my
thanks and appreciation to the staff.
14
MR. RULAND:
15
CHAIRMAN ABDEL-KHALIK:
16
MR. RULAND:
17
Thank you.
Mr. Ruland?
Mr. Chairman, I have some
closing remarks that I --
18
CHAIRMAN ABDEL-KHALIK:
19
MR. RULAND:
Thank you.
Yes, please.
I just wanted to
20
say thank you to the Committee for their forbearance
21
in our frequent saying, "The task force is going to
22
handle that."
23
you
24
presentation early this week.
25
we get to do lots of dry runs, because we take
know,
we
But, you know, it is -- as you know,
probably
started
working
on
this
So, you know, normally
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1
Committee meetings extremely seriously.
2
But two areas I would like to address is,
3
first, the actions of our Japanese colleagues.
4
know, what we are -- what you heard here, you might
5
have assumed that the Japanese, you know, were not --
6
may or may not have been doing what was appropriate.
7
We don't know that, right?
8
right, the Japanese took the actions that they needed
9
to to protect their citizens, and attempting to try to
10
You
As far as we can tell,
recover the plant.
11
We have -- you know, we were trying to, in
12
the United States, to protect our citizens or to make
13
recommendations, as appropriate, based on the limited
14
information we had.
15
you have to basically make a decision on the spot that
16
-- you know, based on limited data.
17
have to make a decision, and sometimes that's better
18
than no decision.
19
that.
And sometimes during emergencies
And sometimes you
So I just kind of wanted to say
20
And the other thing has to do with the
21
timing of root cause evaluations and the timing of our
22
recommendations.
23
to -- you know, how long do you wait before you start
24
acting
25
regulatory
on
This is a balance that we are trying
making
recommendations
framework?
to
change
our
It's -- you know, do we
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1
continue to wait for root cause evaluations, or do we
2
start the process now of examining what we should do?
3
And so similar to what I have just said
4
about, you know, making decisions with limited data,
5
you know, the staff -- we need to make some decisions
6
and make some recommendations to the Commission with
7
the data we have today, and the data we might have in
8
the next 60 to 90 days.
9
So
I
would
just
ask,
basically,
a
10
collective understanding from everybody of, you know,
11
the situation we're in, and we're trying to do our
12
best.
So --
13
14
CHAIRMAN ABDEL-KHALIK:
much.
15
16
Thank you very
MR. RULAND:
And thank you for allowing me
to say that.
17
CHAIRMAN ABDEL-KHALIK:
18
At this time, we are scheduled for a one-
19
hour lunch break, and we will reconvene at quarter to
20
two.
at
Thanks.
21
(Whereupon,
12:44
p.m.,
the
22
proceedings in the foregoing matter went
23
off the record.)
24
25
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1
A F T E R N O O N
S E S S I O N
2
1:46 p.m.
3
CHAIRMAN ABDEL-KHALIK:
At this time we
4
are back in session.
5
the agenda, Draft Final Reg Guide 1.152, Criteria For
6
Use of Computers in Safety Systems of Nuclear Power
7
Plants and Cyber Security Related Activities.
8
Charlie Brown will lead us through this discussion.
9
We will move to the next item on
And
Charlie.
10
MEMBER BROWN:
Okay.
Just by providing a
11
little bit of background so you'll know where this
12
thing fits in, first of all, we did review the during
13
a subcommittee meeting about a month ago.
14
has been around for a long time.
15
2001 and 2006 to include cyber security type positions
16
aside
17
Subsequently, I think 10 CFR 73.54 was issued with
18
more
19
Commission thought should be taken care of relative to
20
cyber security.
from
the
extensive
21
positions
information
And 1.152
It was revised post
2.1
relative
through
to
what
2.9.
the
And then Reg. Guide 5.71 which is cyber
22
security was issued about a year ago.
Correct me if
23
I'm wrong.
24
is from what is their view point is -- to now revise
25
1.152 to take the things they think were covered in
And the object now is -- of course, this
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1
5.71, move them out of 1.152 and focused these only on
2
the design points.
3
the first five were covered design-type items relative
4
to the New Reactors or NRR or whoever, the design
5
centers.
6
There were nine positions of which
And then 5.71 is a programmatic document.
7
And so they say, "Okay, we've got all those over
8
here."
9
they want to do it, and then we'll have whatever
10
They're going to explain that evolution, why
discussions we'll have.
So that's kind of --
11
Bill.
12
MEMBER SHACK:
13
guidance.
14
document to the other.
15
16
So there's no real new
We're just moving guidance from one
MEMBER BROWN:
That's the theory.
Correct
me if I'm wrong, Steve.
17
MR. ARNDT:
18
MEMBER
There's some revisions.
BROWN:
They expanded some
19
paragraphs in 1.152 and a few things like that.
20
fundamentally if you read their write-up, it would
21
have said, "Hey, we're taking 2.629 as covered in the
22
other guidance now and we're removing that."
23
spiffed up 1.152 to give it a little bit more meat on
24
the design side.
25
But
And they
So, with that, I'll turn it over to Steve
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1
and Tim who are going to provide the discussion
2
process.
3
MR. ARNDT:
Okay.
Well, good afternoon.
4
As most of you know, my name is Steven Arndt.
5
in the Division of Engineering in NRR, previously in
6
Research as most of you probably know.
7
I work
With me today is Mr. Timothy Mossman who
8
will help me make the presentation.
9
today are staff and managers from the Office of
Reactor
Regulations,
and
10
Nuclear
11
Reactors,
Office
12
Incident Response that owns the Cyber program.
13
we get into any gory detailed type of discussions
14
associated with that, we can turn to them.
the
of
the
Also with us
Office
Nuclear
of
New
Safety and
So if
15
As Mr. Brown articulated, we supported a
16
subcommittee meeting on February 23rd to discuss the
17
details of the revision of Reg. Guide 1.152, Criteria
18
for Use of Computers in Safety Systems of Nuclear
19
Power Plants."
20
which continues to endorse IEEE 7432 Rev 2003 with
21
revisions associated with the cyber security area.
This is a discussion of Revision 3
22
One of the major revisions was to take the
23
malicious action part of security out of this document
24
and put it where it belongs in the security area.
25
the non-malicious area has been retitled
And
"Security
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1
Development and Operational Environment" which is
2
basically all those things that would occur that might
3
also have the same impact as a malicious attack but
4
was not a malicious intent.
5
some length.
6
We'll talk about that at
The purpose of our presentation today is
7
to
overview
the
digital safety system and cyber
8
security licensing and oversight.
9
licensing
activities
in
this
We have both
area
and
inspection
10
activities that are involved with the region, to
11
present to you the modifications that we've discussed
12
and to answer questions regarding how this all fits
13
together, how did it come to be the way it is, how
14
we're trying to close the loop on this particular
15
phase of this development and also address some
16
questions
17
particularly how the various players are interfacing
18
and coordinating in this area.
that
were
raised
in
the
subcommittee,
19
Our desired outcome is to achieve a common
20
understanding of what we're doing, how we're doing it,
21
make sure you guys all understand the evolution and
22
how we've come to this point and where we're going in
23
the forward direction and, of course, to receive a
24
positive recommendation on publishing the revision of
25
the guide.
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1
To do this, what we're going to do is I'm
2
going to give a short history of the development of
3
the documents.
4
than what Charlie just gave you; how did we get here,
5
what are the rules, how do we support the rules with
6
our guidance and where are we going in the future.
7
It's basically a little more detailed
Tim is then going to talk about the
8
details of the modification of Reg. Guide 1.152.
At
9
the end, I'll come back, talk a little bit about
10
future developments, what we're going to do to
11
complete this evolution and look at future activities
12
associated with this: when are the inspections going
13
to happen, how are they going to occur, what are the
14
procedures, these kinds of things.
15
As Charlie mentioned, Reg. Guide 1.152 is
16
an old document.
17
basically put it in place, the first version, in 1985
18
to talk to computer-specific work or digital, if you
19
will, aspects of the licensing of instrumentation and
20
control systems.
21
It's been around for a while.
We
The governing document for instrumentation
22
and control systems is 10 CFR 50.55(a)(h) which is the
23
place where we codify IEEE 603 as the guidance.
24
That's for all kinds of I&C systems, analog, hybrid
25
systems, digital systems.
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1
MEMBER BROWN:
The 1991 version.
Correct?
2
MEMBER BROWN:
Yes, 1991 version.
Back in
3
the '80s when we were starting to see digital systems
4
we wanted to provide additional guidance on this
5
digital-specific aspects of those requirements.
6
1985 we endorsed IEEE 7432, 1982 version which talks
7
about specific aspects of design of digital systems in
8
that review.
9
So in
In 1996, we updated that basically with
10
all
the
11
between those two documents.
12
version of 7432 which was the 1993 version.
13
experience
associated with the 11 years
We endorsed a new
Then we had our infamous attacks in 2001.
14
As a result of that, the Agency looked at a lot of
15
things including and especially security requirements.
16
And they issued a number of orders. The first order
17
associated with cyber was the February 2002 order
18
which contained in part the requirement to evaluate
19
potential consequences to the facility associated with
20
a
21
including cyber.
number
of
different
potential
attack
vectors
22
It followed up that with the 2002 order
23
which included a revision to the design basis threat
24
to
25
development of a cyber security program at each
specifically
established
requirements
for
the
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1
nuclear power plant.
That was until the publication
2
of the Cyber Rule, the governing regulatory structure.
3
To support that regulatory structure, NEI
4
developed 04-04 and NRC developed a revision to Rev.
5
Guide 1.152 to address on a temporary basis the
6
security requirements associated with the orders.
7
When we started the digital I&C research -- I'm sorry
8
-- digital I&C program plan that resulted in the
9
interim staff guidance that you reviewed over the last
10
year and a half, one of the issues that was raised --
11
and the industry and the NRC with input from the
12
public decided to take on as a particular item of
13
interest -- was how the guidance in 1.152 Rev. 2 and
14
guidance in 04-04 fit together.
15
We looked at it and decided there was no conflict
16
associated with that guidance.
17
complimentary to the other.
We went through that.
But one program was
18
The guidance in 04-04 was programmatic.
19
The guidance in 1.152 Revision 2, the nine specific
20
regulatory positions associated with the different
21
life cycle development processes was more specific.
22
So, taken as a whole, 04-04 and Rev. Guide 1.152 Rev.
23
2 and ISG-01 were the regulatory guidance documents
24
for the regulation associated with the orders.
25
While we were doing all that and the
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1
industry was trying to get on top of this issue which
2
they did a good job of, the NRC was engaged in
3
rulemaking.
4
which was the rule for cyber security.
5
and codified by rulemaking the requirements in the
6
orders but also expanded the program to provide more
7
details.
8
In March 2009, the NRC issued 10 CFR 7354
That updated
That rulemaking established cyber security
9
as a separate requirement under the Security Program.
10
It requires a cyber security plan be provided for each
11
facility and then implementation of that plan in a
12
program-based, performance-based rule.
13
As a result of that, we developed 5.71
14
which is the cyber security guidance.
15
in the process of revising 1.1.52 to be in line with
16
the rule and to augment for safety systems the non-
17
malicious security development environment issues for
18
the safety system.
19
And now we are
I wasn't reading my notes.
One of the
20
things we did as part of that as since we're not going
21
to talk about malicious attacks under Part 50 anymore
22
-- malicious attacks have been moved to the Rule 73.54
23
and
24
systems remain under the Part 50 rules -- is we needed
25
a new terminology to talk about it.
issues
associated
with
reliability
of
safety
So we now have
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1
the terminology "secure development and operational
2
environment."
3
One of the feedbacks we got from the
4
subcommittee meeting was that's not defined anywhere
5
in the Revision 3 of Reg. Guide 1.152.
6
back and defined it.
7
ways, secured development environment and secured
8
operational environment because what you're trying to
9
accomplish is slightly different.
So we've gone
And we've defined it in two
10
Secured development environment is the
11
condition of having appropriate physical, logical and
12
programmatic controls during the system development
13
phases
14
undocumented code is not introduced into the digital
15
system.
16
and policies in place to keep that stuff out of the
17
code.
to
ensure
that
unwanted,
unneeded
and
During the development, you've got programs
18
Secured operational environment is the
19
condition of having appropriate physical, logical and
20
administrative controls within the facility to ensure
21
undesired behavior of the connected system and events
22
initiated by inadvertent access to the system doesn't
23
occur.
24
the concept of keeping the bad stuff out either in the
25
development process or in the operational phase.
So it's a slightly different concept, but it's
And
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those will be added to the reg. guide to make sure
2
everybody's on the same page and knows exactly what
3
we're talking about.
4
MEMBER BROWN:
Can I just make sure
5
everybody understands the specific points right here.
6
We've
7
equipment within the -- by the vendor as the result of
8
actions after licensing, what have you, 1.152, only
9
those items associated with the designing and building
10
effectively
separated
the
design
of
the
of the hardware for the safety system.
11
And it involves internal controls for the
12
control of that design as well as how you get into.
13
It can involve how do you design the equipment to make
14
sure you can meet this other operational environment
15
as well in the long term.
16
All the malicious stuff, in other words,
17
how does somebody getting access and what can they do
18
external, has been taken out and is now under the
19
programmatic umbrella of Reg. Guide 5.71 which comes
20
after the license is granted and may not even be
21
looked at -- I don't say this too pejoratively --
22
until the equipment gets delivered to the site because
23
it's a site application fundamentally of how do you
24
secure these equipments from external access once they
25
are delivered and installed or being installed and
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1
managed while they're on site.
2
You can fuzz that up a little bit if you
3
want to.
4
nasty stuff from just taking care of the design
5
business.
6
7
MR. ARNDT:
Okay.
I'd like to clarify
that a little bit.
8
9
But that's fundamentally -- We've separated
MEMBER BROWN:
I would have expected you
to.
10
MR. ARNDT:
From a regulatory standpoint,
11
we have separated the malicious event, the malicious
12
intent actions, be it in the design or the operation
13
from design aspects associated with unintended actions
14
that may have similar consequences associated with the
15
reliability and safety of the system.
16
Safety is a Part 50 issue.
Security is a
17
Part 73 issue which I think is what Charlie said.
The
18
one issue I do take some concern with the way you
19
articulated it is although we review at a programmatic
20
level the malicious issues we don't wait until the
21
very end.
22
through all phases of the development process and we
23
review their implementation and inspection through all
24
the phases of the development.
25
in Part 73 doesn't mean we're not looking at design
We review their plan associated with that
So simply because it's
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1
phase of the system to account for cyber security
2
issues.
3
MEMBER BROWN:
But am I not right in that
4
the cyber security plan as required to be presented by
5
the licensee is not required to be provided until a
6
year before fuel load or something like that?
7
a period of time where there's nothing going on.
8
MR. ARNDT:
9
MEMBER BROWN:
There's
Kinda --
10
here for a minute.
11
locator just disappeared.
Let me finish my thought
Now I just lost it.
12
MR. ARNDT:
13
MEMBER BROWN:
14
MR. ARNDT:
15
MEMBER BROWN:
The old
I'm going to let -Let me.
All right.
I just -- The problem --
16
One of the issues that we discussed in detail was the
17
separation
18
architecture -- Can you get an architecture hardware
19
and software designed without the knowledge of what it
20
has to do when it start getting to be evaluated for
21
site application, installation and cyber security
22
protection.
of
the
design from how does that
23
And if you look at Reg. Guide 1.152 the
24
way it's written there are specific words that say we
25
will not look.
There are very explicit words that say
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1
we
will
not
2
incorporate cyber protection, cyber security features,
3
into your design.
4
in how they potentially affect safety operation, but
5
not from the cyber security standpoint.
6
look
at
this.
But you could can
We will review those only in that
So that was one of the major discussion
7
points.
And I'll let them elaborate, argue for and
8
against it, which I'm sure they're prepared to do.
9
But it's a matter of integrating a large amount of
10
information which gives pretty good stuff in 5.71 in
11
terms of things that need to be taken care of.
12
a good document.
It's
13
But if the vendor doesn't know he's going
14
to have to meet all those, now you deliver equipment.
15
What good is it?
16
major bones of contention in the overall discussions.
So that's been kinda one of the
17
Jack.
18
MEMBER SIEBER:
19
MR. ARNDT:
Can I hold that question for
one second?
22
Craig.
23
MR. ERLANGER:
24
Do you deal with the
insider threat at the facility?
20
21
I'm sorry.
Good afternoon, everyone.
My name is Craig Erlanger and I'm the Branch Chief.
25
(Off the record discussion.)
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1
Good
afternoon.
My name is Craig
2
Erlanger.
I'm a Branch Chief up at NSIR.
Just to add
3
a little bit to what Steve had to say is that the
4
cyber security plans are actually a condition or will
5
become a condition of their license.
6
So to what Charlie is speaking about one
7
thing that we do and are still working on is there's
8
multiple license conditions related to the applicants.
9
The final one has I believe it's a couple months
10
before fuel load.
11
submit a proposed implementation schedule.
12
But it also requires applicants to
And that's one thing that we didn't talk
13
to the ACRS about last time.
And Digital I&C
14
Subcommittee gave us a lot of good things to think
15
about.
16
do and when can we do it.
17
until the last eight months before fuel load and that
18
long down the road.
19
them in their license that they will meet all the
20
security controls.
21
methodology and approach.
And one thing we're exploring is what can we
So it's not that we wait
We're getting things committed to
They will follow a certain
22
One of the concerns we've been hearing
23
again and again is when are you going to look at it.
24
Are you going to wait until the last part to do it?
25
And what I'll tell you today is we're working real
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hard to make sure we do stuff at the appropriate time
2
in the program.
3
Regarding
the
insider
threat
and
the
4
totality, yes.
They're required to look at all that.
5
When a licensee chooses a vendor the burden is put on
6
the licensee to ensure that the vendor is meeting
7
those
8
buying.
requirements
in
the
equipment
that
they're
I'm being very general.
9
But Jay Amin here, he spoke here last time
10
at the Digital I&C Subcommittee that they have to meet
11
the totality of the requirements.
12
look at in licensing is programmatic in nature.
13
the application of the cyber security program does get
14
down to the system level for the assets that are
15
identified as a result of the program.
16
So, yes, what we
So it's also greater than safety.
But
It's
17
security and emergency preparedness is important.
18
It's not just a safety-related rulemaking.
19
covers a lot more things.
20
I know we want to talk about Reg. Guide 1.152.
21
we're around.
22
they come up this afternoon.
23
a bit greater.
24
25
So it
And I'll stop there because
But
I mean we'll answer any questions as
MEMBER BLEY:
But the scope of it is
Let me just -- While you're
still there, let me slip something in.
I missed the
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1
subcommittee meeting.
I'm very sorry for that.
2
another requirement to be elsewhere.
I had
3
I think the concern I think other members
4
have had and I know I do is when you, at least, in the
5
guidance separate these two issues that are really
6
heavily interrelated.
7
you end up doing the same thing twice which is an
8
awful lot of work or you end up not doing it as
9
thoroughly on the one that comes last.
There's a concern that either
10
And you're saying words that make it sound
11
like you're trying to figure out how that won't
12
happen.
13
that it makes it more likely to happen.
14
kind of the gist of the problem as we see it that when
15
you're doing your really detailed review is when these
16
issues are most obvious to deal with and identify.
17
That's the concern.
And pulling the pieces apart makes us worry
18
And that's
So how you integrate them -- Because I
19
assume you're going to have the same people involved
20
in doing this, how you make that work with these two
21
separate lists is the part I'm worried about.
22
MEMBER STETKAR:
23
we asked.
24
this.
25
Can I?
Steve, I thought
The same people are not involved doing
MR. ARNDT:
I was going to talk to that on
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1
this slide.
2
MEMBER BLEY:
I've heard different things.
3
Obviously, I heard from somebody that made it sound
4
like it would be the same people.
5
MEMBER BROWN:
When you're finished I
6
wanted to make one observation relative to your point
7
in terms of separating them out.
8
is how are they going to do what they say they're
9
going to do when the reg. guide says we are not going
10
to look at it.
11
reference 5.71.
And, number two, 1.152 doesn't even
Am I correct?
12
MR. ARNDT:
13
MEMBER BROWN:
14
One of the concerns
In the background section.
The background section.
Yes, but only in the standpoint of the malicious.
15
MR. ARNDT:
Correct.
16
MEMBER BROWN:
In other words, there's no
17
reference in terms of -- There's information there
18
that you've got to pay attention to.
19
integrate, first, you say you're not going to look at.
20
And the other one you don't even reference where 90
21
percent of the really good information is that the
22
vendors may have to deal with.
23
24
So how you
Now you can go ahead and struggle along
with this and we'll proceed on.
25
MR. ARNDT:
Thank you for your words of
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encouragement.
2
(Laughter.)
3
MEMBER BROWN:
Well, I mean some of this
4
could have been solved easily by not being so explicit
5
about what you're going to look at.
6
mushed it a lot better.
7
could have waved your hand and say, "Oh no.
8
in there.
9
together."
You could have
If you refer to 5.71 you
It's all
We'll be going and we'll be doing it
10
But right now it looks like everybody is
11
walking down a separate -- You know you're all riding
12
separate horses.
13
MR. ARNDT:
Okay.
What I'm going to do
14
now is talk about the current regulatory structure and
15
how
16
presentation I'll talk about things we're doing in the
17
future specifically for this particular issue and
18
others associated with guidance development.
we're
doing
the
work.
At the end of the
19
Right now, we have safety systems, digital
20
safety systems, being reviewed in licensing reviews by
21
NRR and NRO.
22
with this reg. guide.
23
them
24
positions that are in the new regulatory guide which
25
is basically all the design phases.
And we'll use the guidance associated
specifically
That is to say we'll look at
associated
with
the
regulatory
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1
And, as Mr. Brown mentioned, we will not
2
explicitly look at the effectiveness and capabilities
3
of cyber controls.
4
included in the safety systems for their high quality
5
development process, their reliability and those kinds
6
of things that might affect safety.
7
But we will look at cyber controls
Their effectiveness for cyber controls is
8
part
of
the
Cyber Rule 5.71.
9
Inspection Program, we have an inspection guide for
10
digital system reviews that deals with inspection of
11
the
12
testing, the operations and maintenance associated
13
with digital safety upgrades.
14
look at those aspects under the inspection program and
15
the ROP and other programs.
installation,
16
the
In the Regional
checkout,
the
acceptance
Those inspectors will
As part of the NSIR cyber plan review
17
which
is
18
undergoing right now, they will look at the
19
effectiveness
20
inspections will look at the implementation of those
21
programs.
22
NRO staff do the licensing work for digital safety
23
systems.
24
25
their
of
licensing
the
cyber
phase
which
program
they're
and
their
Right now, as Charlie mentioned, NRR and
NSIR staff looks at the licensing that is
the review of the plans.
The inspection for both
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1
programs is done by the same set of inspectors out of
2
the same branch in the four regions.
3
procedures,
4
procedure for digital safety installation, checkout,
5
testing and cyber security implementation, but they
6
will reference each other directly.
7
process of doing that.
8
about that at the end of the presentation.
there
will
be
a
The inspection
separate
inspection
And we're in the
I'll talk a little bit more
9
The program associated with the licensing
10
is developed in Chapter 7 of the Standard Review Plan
11
and
12
Currently, Chapter 7 and I think it's Appendix 7(1)(d)
13
points to cyber security plan and basically says,
14
"That's where all the good stuff is."
Chapter
15
13
of
the
Standard
Review
Plan.
Is it as strong as we'd like it to be?
16
it as connected as we'd like it to be?
17
one of the things we're going to do when we address
18
revisions to Chapter 7 and Chapter 13.
19
No.
Is
That's
We also need to get a pointer back from
20
Chapter 13 to Chapter 7.
21
but it's not as strong as we would like.
22
one of our actions moving forward.
23
There is some of that tie,
And that's
The people, it's a small group.
It's
24
maybe 40 people in the NRC Headquarters and NSIR and
25
NRR and NRO all work together on a very regular basis.
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So informally it's the same bunch of guys.
2
it's a program being dealt with by a specific group
3
within a specific organization.
4
between the various things that basically say, "Go
5
find the good cyber stuff in 5.71.
6
digital system safety reliability safety, independence
7
type stuff in the digital safety stuff under 1.52."
8
9
And we have pointers
Again, can we do better?
better?
Go find the good
Do we need to do
Are we planning on doing better?
10
MEMBER BROWN:
Formally,
Yes.
Before you leave that one
11
question, I wanted to make sure I understood the
12
previous
13
hardware is going to be go out to multiple regions.
14
Is it -- And I thought you said only one region --
15
correct me if I'm wrong -- that there would be a set
16
of people that did these inspections for the cyber
17
stuff.
18
slide.
The regional inspection, this
MR. ARNDT:
Region II has a lead right now
19
both for digital safety system reviews (1) because
20
Oconee is in Region II and (2) it's the lead plant for
21
safety
22
inspection group which is the lead for the new plant
23
reviews.
24
25
reviews and it also has the construction
We anticipate that there will be reviews
done in all four regions for both cyber.
But there
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will be a lead region, probably Region II, for cyber.
2
I don't know.
3
out yet.
4
because that's already been established.
5
be a small cadre of inspectors in each of the regions.
6
That's our -- That's what we've --
7
8
The inspection plan hasn't been worked
It will be for digital safety systems
MEMBER BROWN:
There will
But they'll be looking at
the plan.
9
MR. ARNDT:
Yes.
They'll be looking for
10
digital safety systems.
11
implementation of the systems on site.
12
they'll be looking at the implementation of the plan.
13
They'll be looking at the
MEMBER STETKAR:
to
differentiate
For security,
But I think, Steve, it's
14
important
15
confirm that what is installed and implemented in the
16
plant is consistent with the fundamental design or if
17
it's a plan, the security plan.
18
the same type of review if you step back that NRR --
19
MR. ARNDT:
20
MEMBER STETKAR:
21
MR. ARNDT:
simply
So they don't perform
Their function --
-- or NRO staff or NSIR
Absolutely.
They serve a
different function.
24
25
Right.
inspectors
staff would be performing from Headquarters.
22
23
the
MEMBER STETKAR:
So discussions about how
well integrated the inspection process might be I
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1
don't think necessarily addresses our concerns at the
2
integrated review of the system design itself.
3
MR. ARNDT:
4
MEMBER STETKAR:
5
MR.
6
ARNDT:
Correct.
And I think --
They serve different
functions.
7
MEMBER STETKAR:
I understand how the
8
inspection process especially if it's focused in one
9
region.
10
Those folks obviously will talk to each other
or themselves probably a lot.
11
MR. ARNDT:
Right.
12
MEMBER STETKAR:
But their role in this
13
process in terms of a design review if you will is
14
zero.
They don't do design.
15
16
MR. ARNDT:
They don't do design review by
definition.
17
MEMBER STETKAR:
18
MR. ARNDT:
19
That's right.
They don't do licensing.
But
it is an important function nevertheless.
20
MEMBER STETKAR:
It's important function.
21
But I think in terms of some of the feedback you're
22
hearing from us we're focusing more at the design
23
level of review and the integration of the review
24
activities at that level before it ever evolves into
25
the hands of the inspectors.
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MR. ARNDT:
2
MEMBER BROWN:
3
MEMBER STETKAR:
No, an integrated design
review.
6
7
From a cyber perspective in
this case.
4
5
Okay.
MEMBER BROWN:
I understand that.
But we
felt cyber should be included as part of the overall.
8
MEMBER STETKAR:
9
MEMBER BROWN:
10
MR. LAYTON:
Integrated design review.
Yes.
If I may.
I'm Michael
11
Layton.
I'm the Deputy Director for the Security
12
Policy in NSIR.
13
a little bit with the concern of the timing of the
14
cyber security program reviews.
And I think I might be able to help
15
We are very appreciative of the feedback
16
that we've been getting from the subcommittee and the
17
full committee over the past several months.
18
want to point out that we really want to try to
19
address the insights that you've given us within the
20
constraints that the Commission has laid out for us in
21
considerations with the SRM.
But I
22
One of the things that we're working at
23
and I may be leaning a little bit forward with this is
24
that we're really in consultation with the program
25
offices with NRR and NRO and also OGC to see if there
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is an opportunity for, as Craig was saying, to have
2
licensees commit in a license condition to, for lack
3
of a better term, do more of a phased submittal of
4
their
5
waiting until right at the end to submit everything in
6
one large lump.
cyber security programs to us rather than
7
And if that occurs we can then start
8
looking at things as they come in earlier on the cyber
9
security program as licensees are completing them
10
rather than waiting until the end.
11
really something that's in our thoughts right now that
12
we really haven't gelled with OGC or the Program
13
Office to see how that exactly would work.
14
15
MEMBER
BROWN:
But yet that's
Well, that depends on
licensee cooperation to actually submit --
16
MR. LAYTON:
17
MEMBER BROWN:
18
MR. LAYTON:
19
grayness in there.
20
MEMBER
Well, and -- Yeah.
Go ahead, John.
It does.
STETKAR:
I'm sorry.
There's a bit of
There's a bit of
21
grayness.
But the reality of it is and we think
22
licensees would see, too, that it would really be in
23
their best benefit from a business model standpoint to
24
engage us early rather than to wait until the end.
25
Because if they -- You know this has occurred with
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other licensing actions.
2
the
3
reviewed
4
There's a lot more resource scrutiny that has to be
5
applied to it.
6
the applicant is trying to conduct their business.
last
date
by
of
the
If everything waits until
submittal
NRC
it
before something is
typically takes longer.
And those have impacts on really how
7
And once we have our thoughts together
8
internally within NRC staff we would engage applicants
9
and licensees and really communicate that to them that
10
it's something we see would be really to their benefit
11
to do that.
12
13
MR.
LAYTON:
That's a pragmatic
consideration.
14
MEMBER STETKAR:
15
MR. LAYTON:
Yes.
On the other hand, it still
16
doesn't necessarily address -- It gets the cyber
17
security plan review off the ground earlier.
18
MEMBER STETKAR:
19
MR. LAYTON:
perhaps
It doesn't necessarily still
20
ensure
21
features into the fundamental design of the hardware,
22
for example, are implemented in that timely manner.
23
And so that's -- It would help.
24
earlier in the process.
25
that
Yes.
feedback
MEMBER STETKAR:
of
cyber
security
It might raise issues
Yes, and that's really
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the applicant's responsibility.
2
MR. ARNDT:
And one of the things you have
3
to realize is many of the cyber security controls will
4
not be actually in the safety system.
5
majority of them probably won't be because either they
6
will be programmatic controls or they'll be hardware
7
controls outside the safety system boundary which we
8
wouldn't look at from a design standpoint anyway.
9
we do look at cyber security rule because the scope is
10
But
so much broader.
11
12
Actually a vast
MEMBER STETKAR:
Yes.
Well, you need to
keep going.
13
MEMBER
BROWN:
Well, before he keeps
14
going, I did read 73.54 and there was I think at least
15
one SRM.
16
Commission's goals we're separating these and saying
17
one guy does one.
18
And you commented in order to meet the
I
didn't
read those to say that you
19
couldn't integrate your designs.
I mean it did not
20
say one guy goes down this path.
All it did was
21
separate design requirements from cyber requirements
22
that say "Hey, here's a specific rule which covers the
23
gamut of what we're concerned about."
24
25
But it didn't say you couldn't talk to
people.
It didn't say you couldn't review that as
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1
part of the design.
2
heard that one one other time or a couple times back
3
in our subcommittee meeting and I couldn't go find a
4
specific cite that said, "No, no.
5
your review of what you do hardware wise during the
6
design process.
7
integrate."
8
9
So I didn't view that.
I've
You can't integrate
There's nothing that says you can't
MEMBER STETKAR:
This is also -- I'm very
poor at citing specific numbers of things.
So let me
10
just -- There's also a Commission guidance saying that
11
there should be a more integrated assessment of both
12
safety and security from both perspectives.
13
cases, that's been addressed in terms of physical
14
security elements.
15
MEMBER BROWN:
16
MEMBER STETKAR:
In some
Right.
Protection of barriers,
17
abilities of operations personnel and visa versa.
18
that same general thought process should extend out
19
into the cyber security world also.
20
guidance from the Commission saying that the security
21
and safety ought not to be considered separately as,
22
in some cases, they have been in the past.
23
24
MEMBER BROWN:
Okay.
But
So there is
You can go on to the
next slide.
25
MEMBER STETKAR:
He has books with numbers
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1
and paragraphs that he can cite.
2
3
MR. ARNDT:
We can discuss that more later
after we finish the formal presentation.
4
So as articulated in the previous slide
5
and we've just discussed at some length the revision
6
of 1.152 will bring the guidance in line with the
7
revision of the regulation associated with 10 CFR Part
8
53 and provide some level of consistent guidance to
9
the industry.
As you know, there is guidance that has
10
been established and that provides us a parallel path
11
similar to the parallel path we had with 04-04 earlier
12
on.
13
The safety framework for Part 50 reviews
14
as
I
articulated
15
basically
16
requirements for I&C systems.
17
which endorses IEEE Standard 7-4.3.2 which says for a
18
computer system or a digital system this is how you
19
interpret 603.
20
603 for a computer system.
codifies
earlier
603,
was
50.55(a)(h)
specifically
which
articulating
In Reg. Guide 1.152
These are ways in which you can meet
21
And because the 2003 version did not deal
22
with either a secure developmental and operational
23
environment or cyber security for that matter we
24
provided additional regulatory positions associated
25
with that.
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MEMBER BROWN:
2
MR. ARNDT:
3
And that was in Rev. 2.
It's in Rev. 2 and in Rev. 3.
Different regulatory positions in Rev. 3.
4
With
that,
I'm
going
to
turn
the
5
presentation over to Mr. Mossman.
He's going to give
6
you the gory details of the revision and then I'll
7
come back at the end to talk about future activities
8
and some of the other open issues that people want to
9
throw spears at.
10
Tim.
11
MR. MOSSMAN:
Good afternoon.
As Steve
12
mentioned, my name is Tim Mossman.
13
before the full committee before.
14
the NRC for about two and a half years.
I work for
15
George
NRR.
16
educational background is Nuclear and Reliability
17
Engineering.
18
Wilson
in
the
I&C
I've never been
I've worked with
branch
of
My
And for the previous decade before coming
19
here I worked on command and control systems in the
20
missile defense arena which was a lot of fun.
21
there you actually want things to blow up.
But
22
(Laughter.)
23
Anyway to kick off my discussion one of
24
the things I wanted to re-emphasize is something Steve
25
had mentioned.
One of the key things about 1.152 is
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we've not changed one of the very core things that
2
1.152 does which is endorse IEEE 7-4.3.2.
3
from Rev. 2 to Rev. 3 are endorsing 7-4.3 2003 which
4
is something that standard has done since Rev. 0.
We still
5
However, we are making changing to the
6
document, specifically, making changes that address
7
the regulatory positions that were adopted in Revision
8
2 of the reg. guide.
9
presentation I'm going to discussing the NRC treatment
digital
10
of
11
referred to as establishment of a secured development
12
and operational environment which were introduced a
13
few slides back.
14
talking
15
predictable,
16
system development and operation.
17
--
18
I&C
So in this section of the
about
safety
system
security,
hereafter
Specifically, I'm going to be
Modifications
non-malicious
MEMBER ARMIJO:
1.152
to
challenges
focus
to
on
digital
I'm going to talk
Could you give a couple of
19
examples of predictable, non-malicious challenges? I'm
20
not a cyber security --
21
MR. MOSSMAN:
Okay.
About ten slides in
22
I've got some examples of events.
I can either wait
23
then or I can skip ahead a little bit.
24
MEMBER ARMIJO:
25
MR. MOSSMAN:
Just go ahead.
Okay.
I'll wait.
So we're focusing the
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1
reg. guides, some of the regulatory positions, on Part
2
50 and Part 52 reliability requirements and those
3
positions will now reflect the migration of cyber
4
security provisions over to Part 73.
5
We did a very high level mapping of where
6
regulatory positions migrated to.
Section 2.1 and 2.2
7
in
the
8
requirements phase.
9
in Revision 3.
Rev.
2
of
1.152
covered
concepts
and
We still maintain those sections
However, the malicious and cyber
10
aspects of the concepts and requirements phase move to
11
Appendix C Section 12.2 of Reg. Guide 5.71.
12
Sections 2.3 to 2.5 in 1.152 cover design
13
implementation and test.
14
sections in Rev. 3 again for non-malicious events.
15
The malicious aspects of those have migrated over to
16
Appendix C of 5.71 Sections 12.3 to 12.5.
17
MEMBER BROWN:
We've also maintained those
Before you leave that since
18
you're on one through five which is what you've
19
covered positions 2.1 through 2.5.
20
MR. MOSSMAN:
21
MEMBER BROWN:
Yes.
I did in part of anal
22
approach to doing business do a position-by-position
23
comparison to Rev. 2 and you expanded some and you did
24
exactly what you said.
25
have the benefit of that.
You removed -- Okay.
Okay.
I didn't
I had to do it by
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1
eyeball.
2
MEMBER CORRADINI:
3
MEMBER BROWN:
4
Okay.
Got it.
5
You
6
malicious things.
did
What's that?
And you did those.
remove
anything
Oh yeah.
It's very notable.
referring
to
potential
You removed -- Those were gone.
7
MR. MOSSMAN:
8
MEMBER BROWN:
9
OUO.
Yes.
All right.
What I didn't
find was -- And this applies to 2.6.
I had a
10
difficult time finding where in 2.7.1.
11
and looked at section 12. whatever you all referenced
12
these things should have gone.
13
MR. MOSSMAN:
14
MEMBER BROWN:
15
I mean I went
Okay.
But I don't want you to
walk me through that right now.
16
MR. MOSSMAN:
17
MEMBER BROWN:
Okay.
It's just if you -- After
18
the fact if you could give me the listing, I would
19
like to at least see it particularly for 2.6.
20
not
21
actually expanded a couple of those and I thought they
22
were better than what they were from the design than
23
they were in the first Rev. 2.
unsatisfied
24
25
with
the
MR. MOSSMAN:
2.1
Yes.
through
2.5.
I was
You
Based upon applying
the Rev. 2 positions, we knew there were a couple.
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1
There is some language that wasn't great.
2
spruced it up.
3
MEMBER BROWN:
4
the malicious or unwanted type stuff.
5
MR. MOSSMAN:
6
MEMBER BROWN:
7
And you did delete
Yes.
All right.
Just wanted to
make sure I understood that that was intentional.
8
MR. MOSSMAN:
9
MEMBER BROWN:
10
Yes.
So we
Okay.
You made those and I just
never really --
11
MR. MOSSMAN:
Yes.
I think I can answer
12
the 2.6, the installation checkout and acceptance
13
testing.
14
cover that on the next slide.
That went to -- And actually I think we
15
MEMBER BROWN:
16
MR. MOSSMAN:
17
MEMBER BROWN:
Yes.
I had to struggle
trying to find the same words.
20
MR. MOSSMAN:
21
MEMBER BROWN:
22
Yes, that went to Appendix
C, Section 12.6 which is Licensee Applicant Testing.
18
19
Yes, you cover it.
Okay.
Maybe you rewrote all the
stuff so I couldn't understand it anymore.
23
MR. MOSSMAN:
Okay.
Go ahead.
As we kind of ghosted
24
there, the sections regulatory positions 2.6 to 2.9
25
which covered post factory acceptance testing, digital
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1
systems, we've migrated completely over to Reg. Guide
2
5.71.
3
Part 52 licensing as they occur after installation
4
occurs and we need to make our determination before
5
installation occurs.
6
those aspects more completely and thoroughly.
We have not used those sections in Part 50 and
7
And the feeling was 5.71 covered
MEMBER BROWN:
8
to-paragraph comparison.
9
MR. MOSSMAN:
10
MEMBER BROWN:
11
MR. MOSSMAN:
12
MEMBER BROWN:
13
MR. MOSSMAN:
I'll look for a paragraph-
Okay.
I couldn't find it.
Okay.
But let's go on.
All right.
So at this time
14
we believe Revision 3, Reg. Guide 1.152 is ready for
15
release.
16
we've
17
intentional malicious acts or actions.
18
enhanced the focus of 1.152 to be more focused on
19
integrity and reliability per Part 50 requirements.
20
In addition, the post factory acceptance test life
21
cycle phases have been taken out of 1.152.
22
what was taken out.
And to kind of summarize what you've heard
removed
all
references
to
cyber
security,
We've kinda
So that's
23
Very specifically, we've tried to enhance
24
our focus of the document on -- and I'll be talking
25
about these at length in the next few slides -- is
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1
first
and
foremost
2
environment
3
unwanted and unneeded code.
4
challenge the reliability or integrity of the safety
5
system should it be inadvertently activated during
6
operations.
7
10 CFR Part 50 Appendix B, Design Control.
from
protection
the
of
inclusion
the
of
development
undocumented,
Such extra software can
We derive that focus from Criterion 3 of
8
Our second big objective we try to cover
9
in Rev. 3 is to establish controls in the system to
10
prevent
11
operations.
12
IEEE 603.91 which is Access Control.
13
inadvertent
access
to
the
system
during
This criteria comes from clause 59 of
And
the
last
objective
is
to
ensure
14
protection of the safety systems against undesirable
15
behavior of connected systems.
16
little more about what we mean by undesirable behavior
17
and give some examples a little later in the briefing.
18
And this criteria comes from Clause 563 of IEEE 603,
19
Independence from Other Systems.
And I'll be talking a
20
And as Steve addressed earlier we adopted
21
terminology -- Because we were having security versus
22
security debates, we changed our terminology from
23
security
24
environment to differentiate what we're talking about
25
in Part 50 versus what Part 73 addresses.
to
secure
development
and
operational
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1
Secure development environment as Steve
2
covered earlier, we've crafted a definition, something
3
that the subcommittee asked for.
4
and looked we found we did about everything we could
5
except actually explicitly define what we meant.
6
MEMBER BROWN:
When we went back
The copy we reviewed for
7
the meeting did not -- I don't remember seeing this in
8
there.
9
10
MR. MOSSMAN:
up.
11
12
And we haven't done a mark-
MEMBER
BROWN:
You've marked it up
subsequently.
13
MR. MOSSMAN:
Yes.
I've got it marked.
14
I'm doing the mark-up and I figure I would take
15
comments from the full committee before they go
16
anywhere.
17
The philosophy here is that applicants
18
should protect their development environments from the
19
inclusion of unwanted, unneeded, undocumented code.
20
For high reliable software systems simpler designs and
21
implementations are generally preferred.
22
complex a system is the less things that could go
23
wrong.
24
25
MEMBER
ARMIJO:
The less
I'd like to ask a
question.
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1
MR. MOSSMAN:
2
MEMBER ARMIJO:
Sure.
We just reviewed something
3
the other day, this commercial software, Common Q or
4
whatever it is.
5
MR. MOSSMAN:
6
MEMBER ARMIJO:
Right.
And it had a whole bunch
7
of features that they said, "Well, we're not going to
8
use that.
9
presumably was okay.
10
We're going to turn those off." And that
Is that consistent with what
we're seeing here?
11
MEMBER BROWN:
Yes and no.
The reality is
12
if you get a -- It depends on how you design the
13
system.
Can I speak on this?
14
15
MEMBER ARMIJO:
Yes.
I'm just trying to
understand.
16
MEMBER BROWN:
It depends on how you
17
design.
18
platform, then you just put in the functions, the
19
algorithms, the coding that you want.
20
commercially available platform which is in use by a
21
wealth of different people in different types of plant
22
applications and you've got to make a decision as to
23
how you're going to use the stuff they have in there,
24
the functionality.
25
If you do a custom design with a custom
You take a
And if you don't like some of it, you then
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1
have to do management wise or administratively to
2
restrict the use to those to not use the ones you
3
don't want.
4
development environment" so that everyone --
5
6
That requires you to maintain "a secure
MEMBER ARMIJO:
What's turned off stays
turned off.
7
MEMBER BROWN:
Exactly.
So when somebody
8
does make a software change that they know what the
9
rules are and what functions they can use and what
10
functions they can't use as well as operations, I
11
mean.
12
And I'll use the word although I couldn't
13
define it, boolean operations, that do certain things.
14
It's like divide by zero.
15
zero in places.
16
no.
17
You don't want divide by
So anyway that's the answer.
MEMBER SIEBER:
Yes and
But there is a point to
18
keep in mind that if you buy commercial systems with
19
commercial software and you need only these pieces of
20
it, there's no obligation to remove all the other
21
pieces.
22
23
They're still there.
MEMBER BROWN:
Absolutely.
They're still
there.
24
MEMBER SIEBER:
This superfluous code.
25
MEMBER BROWN:
And it gets processed.
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It's in the process.
2
stuff.
3
If you've got other adjunct
MEMBER SIEBER:
If it's superfluous code
4
it has to be evaluated as to whether it takes process
5
and time, uses unnecessary resources, interferes with
6
the operation of other parts of the program.
7
not a simple thing.
8
MEMBER BROWN:
9
MEMBER SIEBER:
10
MEMBER BROWN:
This is
That's what I was thinking.
In my opinion.
For reference back I guess
11
in the late '80s, one of my guys convinced me in my
12
Naval Nuclear program to try to use a Windows-based
13
set of operating system for a system that we didn't,
14
you know, that was a control system but not a safety
15
system.
16
MEMBER SIEBER:
17
MEMBER BROWN:
Wow.
And I was just aghast that
18
they would even propose it.
So I said, "Fine.
Show
19
me how you're going to strip all the code out that we
20
don't need."
21
hard to strip out, all the code out of the two million
22
lines of code and whatever it was of the particular
23
Windows version, then they decided that the custom
24
design was a better approach.
25
can refer to me however you want to, but just by being
And after they ferreted out it was too
So just by being -- You
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obnoxious --
2
MEMBER CORRADINI:
3
the record or off the record?
Do you want to do it on
4
MEMBER BROWN:
5
So you're exactly right.
6
which is extremely laborious and you don't know what
7
you're going to do to the code when you do that.
8
9
I'll keep it on the record.
You would have cut it out
MEMBER SIEBER:
real
requirement
that
The issue is there's no
tells
you
what
to
do
and
10
depending on the attitude of the person who is in
11
charge of constructing the code you could go one of
12
two paths.
13
in there and say, "I'll never use it" and so forth.
14
But it's there.
15
probably spend more money to develop custom software.
16
There is sort of a struggle there.
You could leave a lot of superfluous stuff
17
Or you could custom design and
MR. MOSSMAN:
It's good discussion and
18
actually it was a good question because it's something
19
we've wrestled with internally and it's something I
20
know
21
discussions
22
ourselves.
my
NRO
counterpart,
on
this.
we've
had
a
lot
of
And it's an area amongst
23
1.152 actually contains some very high
24
level language that says if you come in with a COTS
25
system you need to make a case in not so many words as
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1
to how you're going to manage the functionality that
2
that system brings.
3
MEMBER SIEBER:
4
MR. MOSSMAN:
Right.
It's an area we'd like to
5
see more guidance developed and I'm kinda ghosting a
6
few slides back in my presentation.
7
area -- And we heard that when we sent Rev. 3 out for
8
public comment.
9
got back from the industry is they'd like -- as
But that's an
That was one of the other comments we
10
opposed to a few high level statements to make a case,
11
they'd like some more guidance.
12
MR. ARNDT:
13
MR. MOSSMAN:
14
And we agree.
For the transcript, COTS is.
Commercial Off-The-Shelf
software.
15
MEMBER BLEY:
And just for Sam you sat in
16
on that meeting and the thing we saw there was there
17
wasn't a restriction from here.
18
a detailed set of rules and apparently the base code
19
was structured such that it didn't all run.
20
control that.
21
22
MEMBER ARMIJO:
But the vendor wrote
You could
You had to activate it
some way.
23
MEMBER BLEY:
You had to actuate it and
24
there are detailed rules that never use this call and
25
never go here.
Set these parameters this way and it
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will never exercise that part of the code.
2
all administrative, but that's the way they did it.
3
MEMBER ARMIJO:
4
MEMBER BLEY:
5
the vendor.
6
Now that's
Yes.
And those rules came from
They set it up.
MEMBER ARMIJO:
So it still potentially
7
could get activated and somehow cause problems unless
8
you follow those administrative rules very carefully.
9
MEMBER
10
surprised
11
happened?
12
if
BLEY:
sometime
Would you be horribly
in
MEMBER BROWN:
the
future
something
Just think about it from a
13
hacking standpoint.
14
wrench and they know what the code is and may know
15
what that platform looks like, they hack in.
16
a call in.
17
hacked all the time and they've got sophisticated
18
stuff, this is not going to be as sophisticated.
19
20
If somebody wanted to throw a
They put
If the DoD can get hacked the way they get
MEMBER
BLEY:
And the restriction
document, the set of rules, is --
21
MEMBER STETKAR:
In that particular case,
22
the vendor because of other commercial arrangements
23
had claimed they had complete control over all changes
24
to the software because it was a commercial licensing
25
issue.
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1
MEMBER BROWN:
Yes.
Except that same
2
platform is used by other folks who could though then
3
reverse it, engineer it, figure out what it is.
4
MEMBER STETKAR:
Right.
They didn't have
5
control over the universal knowledge.
6
MEMBER BROWN:
Exactly.
That's one of the
7
points when you have communication devices from level
8
to
9
communications
10
level
to
level
from
from
the
outside
you
want
no
and you want an
isolated device that transmits one way only.
11
MEMBER STETKAR:
12
MEMBER BROWN:
13
where
that.
Yes.
There's a couple ways to do
You could do that with hardware.
14
MEMBER SIEBER:
15
MEMBER BROWN:
16
devices that are software-controlled.
17
it can be bidirectional or unidirectional.
18
not design a system from level four to three and three
19
to two which is 5.71.
20
Yes.
Or you could do that with
In other words,
You should
You should not use communication devices
21
that are software controlled.
In other words, they
22
can be made uni- or bidirectional based on code.
23
There's no restriction on any of that.
24
even a basic guidance relative to that.
25
words, there's a preference that it be unidirectional
There's not
In other
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and that's in Section C-3.3.2 or 5.71 or something
2
like that.
3
It doesn't say a word.
So you could get
4
something and you don't have -- Somebody's got to
5
justify why it's going to be -- software is going to
6
be protect that software from keeping something from
7
happening.
8
wrinkles in this stuff.
9
It's just how you do it.
MEMBER SIEBER:
To do all that logic by
10
hardware you end up with a massive --
11
MEMBER BROWN:
No, there's communication
12
hardware that doesn't.
13
now than it was a few years ago.
It's far more sophisticated
14
MEMBER SIEBER:
15
MEMBER BROWN:
16
There's a lot of
I admit to my age.
Well, I admit to mine also.
We're not that far apart, Jack, like five months.
17
Go ahead.
18
MR. LEE:
Eric Lee from NSIR.
I'm one of
19
the cyber security specialists participating in Reg.
20
Guide 5.71.
21
the boundary device.
22
specifically have put in some wording such that the
23
boundary
24
secure and --
25
I agree with you, sir, 100 percent about
device
must
That is the reason why we
be
physically
and
logically
And in addition to that we also require
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1
that the boundary device be achieved one way data
2
flow, at least, be achieved through the hardware-based
3
systems.
4
the industry and that is why if you look at the NEI
5
08-09 instead of explaining all the detail about what
6
they need to do what they said in the NEI 08-09 is
7
that
8
incorporate the deterministic data value or if you do
9
not then you must meet this type of criteria to have
10
they
MR. LEE:
either
you
Okay.
That's in 5.71 or
5.71 specifically what I just
talked about.
MEMBER BROWN:
I didn't find that.
I'd
like to.
17
MR. LEE:
18
MEMBER BROWN:
19
that
08-09?
15
16
stated
MEMBER BROWN:
13
14
specifically
a similar kind of assurance.
11
12
And we have discussed this very lengthy with
I could show that to you.
That's fine.
You can show
me after the fact.
20
MR. LEE:
21
MEMBER BROWN:
22
words you said didn't sound absolute.
23
Sure.
MEMBER STETKAR:
Thank you.
Because the
Well, but for example,
24
there's nothing in Reg. Guide 1.1.52 that contains
25
those types of statements.
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2
MEMBER BROWN:
MEMBER STETKAR:
Because that's apparently
an irrelevant issue for --
5
MEMBER BROWN:
6
MEMBER STETKAR:
7
The design.
-- design for a safety
purpose.
8
9
It's only
in 5.71.
3
4
Oh, absolutely.
MEMBER BROWN:
Right.
Thank you for
pointing that out.
10
MEMBER STETKAR:
11
MEMBER BROWN:
I lost the bubble on that
MR.
Okay.
12
You're welcome.
one.
13
MOSSMAN:
Now to sum up
14
security development environment basically the NRR/NRO
15
staff has part of licensing evaluations are looking to
16
conclude
17
measures to ensure the superfluous code has not been
18
introduced into a deployed system.
19
that
an
applicant
Security
has
taken
development
reasonable
guidance,
we
20
recognize that each development may be unique as such.
21
The way 1.152 approaches this is it directs applicants
22
to perform a concepts phase assessment.
23
this
24
identify opportunities in the development process
25
where unwanted, unneeded, undocumented requirements,
concepts
phase
assessment,
As part of
applicant
should
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design
features
or
implemented
2
introduced into your system.
3
these measures, the measures taken to protect the
4
development
environment
5
superfluous
code
6
challenges identified.
and
code
could
be
The NRC's evaluation of
from
the
functions
introduction
depend
on
of
those
7
To date, we have seen applicants come in.
8
Some of the things that applicants have identified,
9
they've identified opportunities to inject unreviewed
10
requirements
in
the
requirements
11
documentation
and/or
12
documentation or databases that are not driven by
13
requirements,
14
implementation and coding environment, physical and
15
logical access --
design
physical
and
16
MEMBER BROWN:
17
MR.
databases
features
logical
into
access
design
to
MOSSMAN:
Opportunities where
somebody's got an opportunity to get into your
19
development.
20
MEMBER BROWN:
21
MEMBER STETKAR:
22
MR. MOSSMAN:
Okay.
All right.
Not features.
Yes.
These aren't features.
Yes.
24
25
the
These are negative things?
18
23
or
MEMBER BROWN:
These all sounded very
negative.
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MR. MOSSMAN:
2
MEMBER BROWN:
3
Right. Yes.
I wanted to make sure I
hadn't lost a little.
4
MR. MOSSMAN:
No.
I used to do risk
5
management and sometimes it's backwards.
And you have
6
somebody -- I want to know what your risks are before
7
I know what your fixes are and people always want to
8
jump ahead and tell you how they fixed the problem
9
before telling you what they were fixing.
So many of
10
our RAIs have kinda -- We want to backtrack people to
11
"Okay.
12
trying to fix?"
You told me what the fix was.
What were you
13
But some of the fixes people have come up
14
with are we've seen people take credit for very strict
15
controls
16
documentation,
17
backward,
18
documentation, design documentation to implement a
19
code and back and forth, strict controls on the
20
implemented code including physical access to develop
21
facility, logical access to the development platforms
22
as well as the development network including isolation
23
of those networks, use of software librarian tools
24
that track and maintain history of all changes.
25
seen controls on the test environment to include
on
the
requirements
processes
traceability
of
to
and
perform
their
design
forward
requirements
to
and
design
We've
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1
isolation of the test environment and the control of
2
test data and products as well as test tools.
3
MEMBER BROWN:
4
MR. MOSSMAN:
5
We also recognize one of the special notes
6
with digital system development is there often is a
7
difference
8
development.
9
cases, we've seen platforms come in with applications
10
where the platform may have been developed many, many
11
years ago, sometimes in a different country where the
12
application was developed more recently.
13
kinds of systems, we're going to want to evaluate both
14
development environments to make sure that both the
15
operating
16
protected from the introduction of unwanted, unneeded,
17
undocumented code.
between
Those are positive ones.
Those are good ones.
platform
and
application
And we're interested in both.
platform
and
the
Yes.
application
In many
For these
has
been
18
It's a little bit of a challenge, but the
19
recent Oconee RPS/ESPS platform that was approved with
20
such a system the original platform was developed
21
overseas
22
developed domestically within the last few years.
23
we had to evaluate both of those development
24
environments.
25
many
years
ago.
The application was
Secure operational environment.
And
Again,
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this is a definition we did not have the last time.
2
Steve
3
operational environment and I kinda touched on these
4
earlier we want to protect systems in the operational
5
environment from undesirable behavior of connected
6
system and inadvertent access to the safety system.
read
it
earlier.
Part of your secure
7
When we talk about independence from other
8
systems, we specifically use the term "undesirable
9
behavior"
when
we
describe
a
secure
operational
10
environment such that it will encompass events that
11
aren't just failures of connected systems.
12
when you're talking about digital systems it can be
13
abnormal, unusual, low probability behaviors that are
14
not strictly considered failures of a connected system
15
but may not have been routinely expected or may not
16
have -- unanticipated by your safety system nominal
17
operation.
18
But also
These kinds of behaviors includes things
19
like
excessive
20
transmission, missing or out-of-sequence messages,
21
transmission
22
messages that are not designed for the safety system,
23
transmission of standard message formats that have
24
out-of-range data and transmission of a message when
25
a safety system is not in a correct mode to process
of
data
transmission,
nonstandard
corrupted
message
formats
data
or
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it.
2
When I used to do missile defense they
3
always used to worry that somebody -- We'd be in
4
operation and someone would get a test message to
5
launch.
We had to design for that.
6
(Laughter.)
7
And
today
we've
seen
Don't do this.
applicants
take
8
credit for -- The first one I'll emphasize because
9
it's my personal favorite is device isolation.
not
10
you're
11
wonderful solution.
12
and it makes your submission a lot simpler to write.
13
connected
If
to other systems, that's a
It makes my review a lot easier
And as Charlie alluded to, any kind of
14
devices that physically prevent transmission of data
15
into the safety system.
16
with those.
17
listing of messages such that only approved documented
18
messages will actually pass through the safety system.
19
We've seen applicants come in
Use of message filters, essentially white
MEMBER
BROWN:
That sounds good, but
20
you're using software to make sure your directionality
21
is satisfactory which is -- So you're using software
22
which is accessible and changeable to protect software
23
which is vulnerable which is really a crumby idea.
24
I'm sorry to be so blunt.
25
MR. MOSSMAN:
Yes.
For the one we saw it
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wasn't the only part of their case.
2
range checks on data fields to make sure information
3
too large, too small doesn't get through.
4
of CRC checks to filter out corrupted messages.
5
MEMBER BROWN:
Use of out-of-
And the use
That's all well and good
6
when you do those things within a particular division.
7
When you depend upon it, again software protecting
8
software for division to division or from safety
9
system to a monitoring system where people have to
10
have to reliable data, that's not necessarily a nifty
11
way to do that.
12
they're not unfoolable.
13
word.
So they're not overwhelming -- I mean
And I'm not sure that's a
14
MR. MOSSMAN:
15
MEMBER BROWN:
16
MR. MOSSMAN:
Yes.
Nothing is perfect.
Yes.
The other aspect of secure
17
operational environment is access control.
Again, the
18
applicant's concept phase assessment should identify
19
physical and logical points of access to the system
20
that may present an opportunity for personnel to
21
inadvertently access the system.
22
Physical points of access include open
23
communications ports on the system which is a USB or
24
serial port that just unused that someone made a
25
mistake when we try to connect into.
Logical points
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1
of access include any points of human interface on
2
systems that are connected to the same network as the
3
digital safety system.
4
To date we've seen applicants take credit
5
for locked and alarmed rooms and/or cabinets in which
6
the safety systems reside such that an alarm would go
7
if anybody attempted to access that area or that
8
cabinet.
9
Systems that have disabled unused external
10
communication
11
potential user interfaces to systems that are on the
12
same network.
13
enable the system that would be required to allow the
14
system to enter certain modes or perform certain
15
functions.
16
ports.
Password protection on any
And use of controlled key switches that
Some example events of what we mean by
17
non-malicious activity.
18
systems, but they provide -- they illustrate the kind
19
of events that we would hope to preclude.
20
Ferry Unit 3 in August of 2006, they had a failure of
21
a condensate demineralizer controller.
22
be on the same network with the variable frequency
23
drive controller that were used to run the plant
24
recirc pumps.
25
These were all non-safety
Browns
It happened to
This is a BWR.
When
the
condensate
demineralizer
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controller failed it generated an excessive amount of
2
network traffic.
3
of those variable frequency drive controllers and
4
ultimately
5
operation of the recirc pumps.
6
had to scram.
7
frequency drive controllers were not protected from
8
another system on that network.
That traffic inhibited the operation
become
nonresponsive,
affected
the
Eventually the plant
Not a malicious act.
But the variable
9
Oconee Unit 3 in November of '08, they had
10
a standard time logging system installed throughout
11
their plant.
12
received a standard time signal for logging purposes
13
to make sure if anything goofed up everybody would
14
have the same time in the logs.
15
Their digital control rod drive system
Somehow they got a noisy message and a
16
correctly formatted message came to the control rod
17
drive system correctly formatted but populated all
18
with
19
appropriate data field for everything except day of
20
year.
21
of year zero meant and it froze that system and caused
22
a plant trip.
zeros.
Interestingly enough, zero was an
The operating system did not recognize what day
23
MEMBER
BROWN:
I want to use this
24
opportunity to relate to some earlier discussions
25
we've
had
relative
to
division-to-division
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1
communication in a couple of different plants where we
2
were assured that the CRCs, the other stuff, it was
3
only a simple field of a one or a zero buried in a
4
long message and it's so simple that this is not a
5
problem.
6
the impetus for trying to find a way in that
7
protection system that there was a downstream check
8
that if all the processors locked up it would still
9
scram within the required amount of time if they all
10
Segue into this discussion and so that was
did that.
11
So I love your example because it is the
12
first one I've been able to get my meaty little hand
13
on -- it's hard enough to come up with this stuff --
14
to use as an example of some of the prior comments
15
I've made and why I've been as insistent on this cyber
16
stuff as I have relative -- An example here would be
17
on one of the projects that we've discussed where the
18
data going to the technical support center and the
19
Emergency Operations Facility, EOF, was going to be
20
done via the corporate network.
21
"Oh, this is just fine."
22
And everybody was
I've got -- I'm not talking about now
23
who's in control.
This is strictly what kind of data
24
do the operators have relative to the main control
25
room relative to what the folks in the other place who
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may be providing some technical support.
2
words, how do we deal with those?
3
gotten to that question yet because this is outside
4
the safety system world.
5
In other
I haven't even
But anyway it's an example.
His example
6
could have the same thing getting data that gives and
7
misleads them in terms of the thought process or
8
decision process or going through.
9
simple.
10
a scram.
11
12
Just kinda scramble things up although caused
Anyway, go on.
Just wanted to make sure
we used this opportunity to provide some --
13
14
This is fairly
MR. MOSSMAN:
No problem.
Any time you
need a straight man let me know.
15
MEMBER BROWN:
Good information.
16
going to run you down to my meetings.
17
MR. MOSSMAN:
18
MEMBER BROWN:
19
MR. MOSSMAN:
I'm
Okay.
We'll pay you later.
Okay.
And the last event which
20
might be considered both inadvertent access and an
21
undesirable behavior event, but the event was at Hatch
22
in March of '08.
23
on an upgrade to a condensate demineralizer system.
24
The work he was doing to test that system on a system
25
that was logically connected to a plant system caused
Initiated when somebody was
working
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an unfortunate interaction between the work he was
2
doing in the actual plant system and eventually caused
3
a bunch of valves to close and also involved an
4
internet plant scram.
5
the part plant personnel to actually be affecting
6
plant operation.
7
was a standalone.
8
But there was no intention on
He was working on what he thought
MEMBER BROWN:
Yes, but the example you
9
use is useful from this standpoint that if you don't
10
have the proper boundary devices to the safety systems
11
and/or their adjunct connected systems you could get
12
the -- somebody can hack in and do something of that
13
nature and possibly end up shutting valves when you
14
don't want to when you're powering and generating
15
electricity.
16
Just trying to highlight the importance
17
that this unless you have literally an armor belt
18
you're
19
superhighway for guys that like to play games, think
20
it's cute to try to challenge the system.
setting
up
what
21
Yes, Jack.
22
MEMBER SIEBER:
I
would
Go ahead.
call
a
cyber
Thank you.
Have you run into any
23
circumstances where the timing of messages makes a
24
difference?
25
company and talked to the transmission department for
For example, I did recently visit a power
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protective relaying people where they have begun using
2
digital relaying for transmission lines and so forth
3
and found that because the signals transmitted so
4
rapidly the sequences of protective actions were not
5
in the orders that they expected which caused faults
6
on their system.
7
8
Have you run into that in power plant
digital systems?
9
MR.
And is that an issue there?
MOSSMAN:
It was something I
10
mentioned.
11
worked on DoD systems that was a big issues getting
12
messages out of sequence.
13
I personally have not.
MEMBER
SIEBER:
Yes.
But I know when I
And does your
14
regulation and your standards cover situations like
15
that?
16
MR. MOSSMAN:
That would be something we
17
would want to look at when you talk about undesirable
18
behavior of connected systems.
19
gets caught in the loop and gets hung up and comes in
20
out of order from something else --
21
MEMBER SIEBER:
22
MR.
23
Asynchronous.
Yes.
That would be
something we would be interested in looking at.
24
25
MOSSMAN:
Because if a message
MEMBER SIEBER:
Yes.
I just thought I'd
bring it up because that's something that has occurred
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not too far from here as a matter of fact and it's
2
happened more than once.
3
in power plant situations, but it does apply in
4
transmission system situations.
5
switchyard and the operation of the safety systems
6
there may be situations where you may digitize bus
7
transfers and so forth that could interfere with the
8
operation of safety systems.
9
And maybe it doesn't apply
And if I look at the
Just something you might want to look at.
10
MEMBER STETKAR:
Tim, I was going to wait.
11
But your next slide, I've been waiting for the slide
12
after your next slide.
13
bit out of order.
But the next slide is a little
14
MR. MOSSMAN:
Okay.
15
MEMBER STETKAR:
So if we can hold on this
16
one or come to this only because you kinda addressed
17
the standard.
18
MR. MOSSMAN:
Okay.
19
MEMBER STETKAR:
In the reg. guide some of
20
the stuff that we're been talking about here and the
21
reason I wanted to bring it up now is it's kinda --
22
Jack's a good straight man.
23
awful
24
statement
25
guidance for designing digital systems such that they
lot
about
says
The reg. guide talks an
vulnerability
"This
assessment.
regulatory
guide
Your
provides
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1
are free from vulnerabilities that could affect the
2
reliability of the system."
3
discussion of what types of vulnerabilities that feeds
4
back into your secure environment.
5
I mean that's good guidance.
And then there's a
And that's good.
6
Then you go on to say that, for example,
7
Annex D in particular of IEEE Standard 7-4.3.2 2003 is
8
not endorsed by this regulatory guide.
9
guide also does not endorse several other annexes of
The regulatory
10
the same guidance.
11
annexes that are not endorsed by this particular
12
regulatory guide, there are examples provided of other
13
documents or other guidance that provide surrogates.
14
However, in all of the other
Annex D there is no guide.
There are no
15
surrogates identified.
And Annex D in particular is
16
the identification and resolution of hazards which
17
provides information about the use of qualitative or
18
quantitative methods like fault tree analysis, failure
19
modes and effects analysis which tend to get you into
20
that
21
vulnerabilities
22
example, if you're vulnerable to timing issues.
identification
so
that
of
you
23
MEMBER SIEBER:
24
MEMBER STETKAR:
25
both
hazards
and
might
determine,
for
Yes.
There's a statement in
there that says that the staff agrees that fault tree
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1
analysis
and
2
analyzing potential hazards.
3
endorsed this annex because it provides inadequate
4
guidance concerning the use of fault tree analysis and
5
FMEA techniques.
6
FMEA
are
well-known
techniques
for
However, the NRC has not
And you're just left hanging.
So the guidance says you ought to do this
7
stuff.
It's a good thing to do.
8
But here's something that you should not use.
9
doesn't say anything that you could use in lieu of
10
this.
11
That
12
anything.
13
Guide 1.152.
You need to do this.
It just leaves you hanging.
has
nothing
to
do
about
It
So that's one.
cyber
security
or
This is strictly within the purview of Reg.
14
MEMBER SIEBER:
15
MEMBER STETKAR:
Yes.
How do you overcome that?
16
And the reason I wanted to get to this because I knew
17
where you were headed.
18
comments later.
19
MR. ARNDT:
But we'll talk about public
Yes.
And point of fact, it
20
doesn't say you can't use it.
21
endorse its use."
22
23
And there's --
MEMBER STETKAR:
Oh, oh okay.
So if I use
this I'm using something that's not endorsed.
24
25
It says, "We do not
MR. ARNDT:
words.
I'm really not trying to mince
But it does matter because for a bunch of
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1
reason the first of which is the NRC usually does not
2
endorse non-normative standards.
3
this
4
normative which means the Committee didn't agree on
5
it.
6
consider.
standard
and
most
MEMBER SIEBER:
8
MR. ARNDT:
10
IEEE standards are non-
It was put in as something you might want to
7
9
And the appendix to
Right.
Information.
And when we endorse a standard
you say "If you do this, it's acceptable to us in its
entirety."
11
MEMBER STETKAR:
Let me interrupt you in
12
a moment.
I understand that and I understand that
13
rationale holds for all of the other non-endorsements
14
of all of other annexes or appendices, whatever you
15
want to call them.
16
MR. ARNDT:
Correct.
17
MEMBER STETKAR:
However, in all of the
18
other cases, you say "We don't endorse this, but
19
here's something else that we're pointing you to."
20
MR. ARNDT:
We understand that.
21
MEMBER STETKAR:
22
MR. ARNDT:
Yes.
There's nothing here.
And we recognize that as
23
a weakness.
And in point of fact the primary reason
24
we do that in this particular case is hazard analysis
25
be it HAZOP, be it fault tree, be it failure modes and
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1
effects analysis or others, is an open issue in
2
digital systems.
3
the standard for 2010 has taken that out of the
4
standard.
5
people can't agree on the right way to do it.
In point of fact, the revision of
That entire annex has been removed because
6
Now I understand that that doesn't help.
7
MEMBER STETKAR:
8
I mean that even muddies the issue furthermore.
9
10
That doesn't help at all.
MR.
ARNDT:
It makes it even more
challenging.
11
MEMBER STETKAR:
12
MR. ARNDT:
Right.
But the point is that what we
13
expect to see is the licensees to attempt to develop
14
a hazard analysis that looks at potential ways in
15
which
16
appropriate
17
methodology is is left open because we can't find
18
anything that we consider an acceptable standalone
19
document to support that, be it a standard, be it a
20
reference, etc.
the
system
might
reference
fail.
is
and
Exactly what the
the
appropriate
21
There are references out there and many
22
licensees either reference this or reference other
23
standards or reference documents including some of our
24
own NUREGs.
25
standard that then becomes endorsed we have to say
The point is to make it a reference in a
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1
that's what we think is the right way of doing it.
2
just don't know the right way of doing it.
3
MEMBER STETKAR:
I understand that.
We
There
4
are however -- I've read that section of the standard.
5
This is my own personal opinion.
6
good stuff in there.
7
of everybody's going to agree that it's a holistic
8
methodology if you will.
9
stuff that if I were going to be doing a hazards and
10
vulnerability assessment it would be good to think
11
about.
12
There's a lot of
It's not complete in the sense
But there's a lot of good
Now given the fact that the regulatory
13
guidance for whatever reason ought not to formally
14
endorse that entire appendix, is there nothing wrong
15
with the regulatory guidance excerpting information
16
from that appendix, summarizing it and saying "Well,
17
in the context of this regulatory guide, here's some
18
good things to think about."
19
than just leaving it as it is which is -- As it is,
20
it's completely open and you're saying that moving
21
forward it's going to become even less clear.
22
23
MR.
ARNDT:
You know, that's better
With respect to this
particular IEEE standard.
24
MEMBER STETKAR:
25
MR. ARNDT:
This issue, yes.
And this particular guidance.
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1
What we hope to do in the next revision which Tim was
2
about ready to talk about.
3
MEMBER STETKAR:
That's why I wanted to
4
get this part of the discussion out of the way before
5
you got forward.
6
MR. ARNDT:
7
finish talking.
8
different standard which is very unlikely because --
9
Yes.
You can fill him in after I
Is to either reference a
MEMBER STETKAR:
10
MR. ARNDT:
You can't find one.
Well, and even if we did find
11
one referencing just one piece of one standard is
12
challenging or putting a regulatory position in that
13
talks specifically to this issue.
14
an ongoing research program in the Office of Research
15
on failure modes and effects analysis and other
16
failure
17
Commission at the recommendation of the Committee
18
asked us to do I guess a year ago or so.
19
ongoing research program.
20
modes
assessment
Exactly
how
We currently have
methodologies
we
do
as
the
So that's an
that in our next
21
revision which we plan on doing soon we'll try and
22
attempt to deal with that.
23
Tim.
24
25
MEMBER BROWN:
And I'll turn it back to
Wait a minute.
I want to
-- Go ahead, John.
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1
2
MEMBER STETKAR:
Sorry.
I just wanted to
get that in.
3
MR. ARNDT:
4
MEMBER
That's all right.
BROWN:
That's good because I
5
wanted to emphasized -- I figured you'd bring that up.
6
So I was going to wait until you finished.
7
while I understand all the discussion you went through
8
and the basis and all that type of stuff you don't
9
have to endorse something in order to -- I mean you
10
all state very clearly in the thing that you evaluate
11
things on a case-by-case basis.
12
MR. ARNDT:
13
MEMBER BROWN:
Because
Yes.
Which means you effectively
14
look at whatever somebody does.
15
evaluate it independently and individually to see that
16
they used a rationale thoughtful process.
17
used this or knew that there were methods that had
18
come usefulness in terms of those evaluations -- you
19
don't have to endorse them but they get evaluated on
20
a case-by-case basis -- they don't get thrown out.
21
MR. ARNDT:
22
MEMBER
You're going to
And if they
Right.
BROWN:
So you still have to
23
justify it.
So I'm not totally enamored with the idea
24
of just throwing it all way and just letting everybody
25
come in with this own individualistic when there are
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1
some things that everybody acknowledges are fairly
2
reasonable approaches to doing things.
3
going to have to justify it if you utilize those.
But you're
4
I just throw that out because that was
5
just a thought process I went through based on the
6
conversation we had the last time.
7
MR. ARNDT:
Yes.
It's certainly something
8
that the licensees can choose to do.
9
why
10
we
generally
don't
MEMBER BROWN:
12
MR. ARNDT:
15
MR. ARNDT:
16
MEMBER
17
something.
18
the board.
Is that
That's okay also.
Yes.
BROWN:
You don't endorse
You don't have to have agreement across
19
MR. ARNDT:
20
MEMBER BROWN:
Correct.
It doesn't mean it has to
be the big red X on it.
22
Anyway, all right.
I just want to throw
my two cents worth in on John's thought process.
24
25
I didn't say endorse.
not everyone does agree which is -MEMBER BROWN:
23
non-normative
Well, let me finish.
14
21
endorse
appendices --
11
13
The whole reason
MEMBER STETKAR:
We got out of order, but
it seemed -NEAL R. GROSS
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1
MR. MOSSMAN:
No, that's all right.
2
MEMBER STETKAR:
You know, the way the
3
discussion was going it seemed to flow a little bit
4
better.
5
MR. MOSSMAN:
Okay.
We're good.
6
Public comments, we did let this out for
7
public comments primarily over the last summer.
We
8
got 38 public comments.
9
Most of it dealt with the language, editorial changes
10
to both the background position and the regulatory
11
positions.
12
the language in certain sections as well as clarifying
13
scope of Part 50 versus Part 73.
A handful were incorporated.
14
We adopted several that really cleaned up
We
had a handful that we did not
15
incorporate.
Some wanted us to make stronger
16
statements about 5.71 and 08-09 and how we can delete
17
a bunch of our positions because they'll all be
18
covered there.
19
5.71 or 08-09 doesn't absolve you from meeting IEEE
20
603.
And we decided just because you do
So we didn't delete our guidance.
21
We had a lot of requests to reference ISG-
22
04 which we at one point wanted to do.
But we were
23
told that was not referencing interim staff guidance
24
and final reg. guides was not good practice.
25
had a handful of out-of-scope.
And we
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1
2
MEMBER BROWN:
that one.
3
MR. MOSSMAN:
4
MEMBER
5
Yes.
BROWN:
Because that's the
communications one.
6
MR. MOSSMAN:
7
MEMBER BROWN:
8
I wanted to ask you about
Yes.
It's got a lot of decent
stuff in it.
9
MR. MOSSMAN:
10
MEMBER BROWN:
It does.
It's not -- The information
11
is in 1.152 explicitly.
So right now it just kinda
12
resides out in the amorphous ether of the universe
13
which seems to be incongruous with all -- I think
14
there's 20.
15
communications type through processes which are pretty
16
good.
I seem to remember 20 or something
17
MR. MOSSMAN:
18
MEMBER BROWN:
Yes.
I mean when I first read
19
this two and a half years ago I said, "Oh, somebody is
20
thinking about this stuff."
21
MEMBER
BLEY:
Well, Charlie just hit
22
something.
Before you respond, two and a half years
23
ago and from what we heard in other areas some of the
24
interim staff guidance may hang around for five years
25
or even more.
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1
MEMBER BROWN:
Yes.
2
MEMBER BLEY:
If that's the case not
3
referencing it just doesn't seem a reasonable thing.
4
MEMBER BROWN:
5
MEMBER BLEY:
Or incorporating it.
Yes.
Ideally incorporating
6
it it won't be out there as an ISG anymore.
7
might not happen for a while.
8
MEMBER BROWN:
9
MEMBER BLEY:
But that
Referencing it, yes.
We're seeing a lot of that.
10
MR. ARNDT:
11
that goes directly to your issue.
12
all the ISGs including ISG-04 to become either part of
13
the standard review plan the next time it's updated or
14
a reg. guide the next time it's updated or an IEEE
15
standard the next time it's updated.
16
fact, most of the stuff that's in ISG-04 is going to
17
work its way into 7-4.3.2 in the next revision which
18
will then be endorsed by --
19
Well, there's two points, one
MEMBER BLEY:
just kinda hanging there.
21
MEMBER BROWN:
There's nothing there in
the interim.
23
24
In point of
But in the interim, it's
20
22
The intent is for
MR. ARNDT:
2010.
The one that we're
currently working which will be 2012 or 2013.
25
MEMBER BROWN:
When will that be issued?
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Four years from now?
2
MR. ARNDT:
2012 or 2013.
3
MEMBER BROWN:
4
MR. ARNDT:
Yes.
Okay.
I mean it's --
The other primary issue is the
5
ISG is specifically intended to provide additional
6
guidance, not new positions.
7
guidance flows from regulation to reg. guides to
8
either the standard review plan or an ISG that exists
9
at the same level.
10
MEMBER BROWN:
So the point is the
The standard review plan is
11
what you guys look at and while I know that the
12
licensees I guess have access to that so that they'll
13
know what -- That's really not guidance per se.
14
just says this is how we're going to review it.
15
MEMBER BLEY:
It
And, in principle, what you
16
say makes sense.
17
that sure look like some new positions to me.
18
where is the lack of good practice in referencing an
19
ISG or in letting one sit around for a few months
20
before it becomes something more formal?
21
know.
22
In practice we've seen some ISGs
MEMBER BROWN:
And
I don't
I mean, it was approved or
23
at least it was reviewed by the Committee I guess
24
before I got there three or four years ago.
25
already been -- had a letter written or something.
It had
So
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1
I mean that was another point.
2
other stuff, the public comments, and all the other
3
stuff that's being ratcheted around in this thing.
4
MR. ARNDT:
Yes.
But based on all the
And one of the reasons
5
that we generally do not endorse an interim guidance
6
with a permanent guidance or visa versa is the interim
7
guidance at least for these did not go through the
8
full regulatory development process.
9
MEMBER BROWN:
10
Steve, supposedly.
11
12
People are there using it,
MR.
ARNDT:
And they will until the
permanent guidance is put in place.
13
MR. MOSSMAN:
At this point in time, the
14
best statement we have is other NRC staff positions
15
and guidance govern unidirectional and bidirectional
16
data communications between safety and non-safety
17
digital systems.
18
ISG-04 reference.
19
20
That's where we previously had the
It's in the 2.1 Concepts section.
MEMBER BROWN:
this thing out of the air.
21
MR. MOSSMAN:
22
MEMBER BROWN:
23
Yes.
Take a deep breath and we
can go on.
24
25
Yes, they've got to pull
Dennis, do you have anything else?
Or
John, on that?
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1
2
MEMBER STETKAR:
well taken.
3
4
CHAIRMAN
ABDEL-KHALIK:
Only a
dissatisfaction.
5
6
I think Dennis's point is
MEMBER BROWN:
am.
You're in the same boat I
But this has given me food for thought here.
7
MEMBER STETKAR:
I understand and I guess
8
I personally agree with the motion that regulatory
9
guides
10
guidance.
11
12
should
not
formally
endorse
interim
staff
That's not -- If you get into that role -MEMBER
BROWN:
You can reference it
without endorsing it.
13
MEMBER STETKAR:
-- we're walking down a
14
path that I don't think the Agency wants to walk down.
15
On the other hands, ISGs that take a life of their own
16
and exists for several years with numerous revisions
17
and things like that is coming close to that same
18
path.
19
MR. ARNDT:
a
Commission
As you may or may not know, we
20
had
meeting
on
February
1st
that
21
discussed I&C issues in general and the Steering
22
Committee and ISGs and specific and our intentions
23
associated with them.
24
plan to phase out the Steering Committee to stop
25
revising the ISGs and some of them have one revision.
And the Commission endorsed our
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1
And to move all of the ISGs into permanent guidance on
2
a relatively expedited plan.
3
4
So that's our plan.
more of them.
5
6
MEMBER STETKAR:
MEMBER BROWN:
Why not just make it an
attachment to the reg. guide?
9
PARTICIPANT:
10
MEMBER BROWN:
11
MR. ARNDT:
12
MEMBER BROWN:
13
Historical rather than
geologic.
7
8
And I can talk to
Appendix.
Appendix.
Thank you.
Normative or non-normative?
I have no idea.
It's an
academic word.
14
MR. ARNDT:
Tim, why don't you go on.
15
MR. MOSSMAN:
16
Future activities for 1.152, Revision 3 by
Okay.
All right.
17
direction was a very limited scope revision.
18
only
19
malicious provisions, out.
20
activities coming up that will affect Reg. Guide 1.152
21
not the least of which is the release of the 2010
22
version of IEEE 7-4.3.2.
23
we're done with Rev. 3 we'll get about formally
24
evaluating 2010 version.
geared
25
at
separately
MEMBER BROWN:
the
cyber
We're
provisions,
However, there are other
That will be as soon as
The 2010 version of what?
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MR. MOSSMAN:
2
MEMBER BROWN:
3
it.
Of IEEE 7-4.3.2.
Okay.
But then what do you do?
4
MR. MOSSMAN:
5
MEMBER BROWN:
6
MR. MOSSMAN:
You'll be evaluating
Yes.
You revise 1.152?
That would go into --
Is that Rev. 4?
That would be Rev. 4 which
7
we hope to start on as soon as we get Rev. 3 out the
8
door.
9
MEMBER BROWN:
10
That's a future activity.
11
MR. MOSSMAN:
12
MEMBER
How much do you have to do?
Yes.
BROWN:
And the usefulness of
13
issuing Rev. 3 in its current form or with whatever
14
recommendations we may have for you which you may have
15
to evaluate if we have any, how long does it take to
16
do the Rev. 4?
17
18
Another two years?
MR. MOSSMAN:
Three years?
It's taken us -- We're 15
months into Rev. 3 at this point.
19
MEMBER STETKAR:
Can I ask Tim or Steve as
20
long as we're talking about future activities?
21
going to wait on this one also.
I was
22
Given the discussion that we've had about
23
plans to revise 1.152 itself, you know, the subject of
24
this slide, plans to perhaps more formally integrate
25
guidance of 5.71 and 1.152, plans to do other things
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perhaps, in the -- I'll call for lack of a better term
2
-- near future, in the next year to year and a half
3
kind of time frame.
4
What exactly is the impetus or the driving
5
force to issue Rev. 3 of this reg. guide now?
6
other words, what do we accomplish by doing that
7
recognizing all of these other issues?
8
MR. ARNDT:
In
The primary reason for doing
9
it and doing it in an expeditious manner is since the
10
finalization of the rulemaking for Part 73, 73.54,
11
we're basically doing that part of the reviews.
12
is to say 2.6 through 2.9 in security.
13
a regulatory guide out on the street that is basically
14
in conflict with our current practices.
15
MEMBER STETKAR:
16
MEMBER BROWN:
The question is is it in
You just said all the stuff
from 2.6 to 2.9 has been rolled into 5.71.
19
MR. ARNDT:
20
MEMBER STETKAR:
21
MR. ARNDT:
22
MEMBER
23
We don't want
conflict or is it just simply duplicative?
17
18
That
It has.
In conflict is a problem.
Yes.
STETKAR:
Duplicative is not
necessarily a functional problem.
24
MR. ARNDT:
Correct.
25
MEMBER SIEBER:
Right.
Provided it's --
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MR. ARNDT:
But the current version of
2
1.1.52 says we're reviewing for cyber security aspects
3
of the digital safety system which is in point of fact
4
not correct.
5
aspects because Part 73 specifically says how we're
6
going to review for cyber security aspects and that
7
ain't what's in 1.152 Rev. 2.
We're not reviewing for cyber security
8
MEMBER STETKAR:
9
MR. ARNDT:
10
Thanks.
MR. MOSSMAN:
Okay.
All right.
Also hopefully
11
our expectation for Rev. 4 and this is -- we kinda
12
already ghosted this discussion -- something that both
13
us and staff and we received the industry comments.
14
Both would like to see more guidance on the format and
15
content of the concepts phase assessment as well as
16
failure analyses.
17
discussion on treatment of predeveloped systems which
18
we talked about a little earlier.
19
we'd like to see more guidance.
20
need.
In addition, we had a little
Those are all areas
And it is an area of
21
One of the challenges we have in writing
22
these sections is a lot of times the things that have
23
security overtones when they come in they're protected
24
under 2.390.
25
that looks like a good precedent, it's not publicly
So even when we -- If we get something
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1
available because it has security overtones.
2
really like to get better guidance that people can
3
work from.
4
All right.
So we'd
Now I'm going to transition a
5
little bit.
There was a -- Provide a little overview
6
of the cyber security framework.
7
from many, many different directions already.
8
73.54 is officially titled "Protection of Digital
9
Computer and Communication Systems and Networks."
We've kinda hit this
10 CFR
It
10
requires licensees to provide high assurance, not
11
absolute
12
communication systems and networks are adequately
13
protected against cyber attacks.
14
assurance,
that
digital
computer
and
Now the scope of the rule includes digital
15
computer
and
communication
systems
and
networks
16
associated with safety-related and important safety
17
systems, security functions, emergency preparedness
18
functions and support systems and equipment which if
19
compromised would adversely impact safety, security or
20
emergency preparedness functions.
21
Important to note, 73.54 is an operational
22
program that applies to licensees and applicants.
23
Additionally, it focuses cyber security rule as the
24
prevention of radiological sabotage.
25
sabotage means any deliberate act directed against a
Radiological
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1
plant.
Cyber security is the process by which
2
critical digital assets -- and critical digital assets
3
are any of those systems that listed in the scope of
4
the rule -- are protected on a continual basis from
5
compromise.
6
That being said, there are certain aspects
7
of cyber security rule and regulatory guidance that
8
can
9
applicants during the design of systems.
and
should
be
considered
by
licensees
and
These are
10
principally covered in the security controls found in
11
Reg. Guide 5.71.
12
Security is a process.
The challenge with
13
cyber security features and the design phase is that
14
adversity changes and evolves.
15
today may be obsolete tomorrow.
16
constantly reevaluate your cyber security plan, your
17
program and your controls.
What may be adequate
So it's important to
18
73.54 is a performance based regulation.
19
It focuses on measurable outcomes and defines results
20
rather
21
procedures or specific direction regarding how these
22
results are to be obtained.
than
23
prescriptive
processes,
techniques,
Reg. Guide 5.71 contains the security
24
controls.
25
Reg.
Guide
There are 148 security controls covered in
5.71.
They address currently known
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vulnerabilities -- They were designed to address known
2
vulnerabilities that adversaries can use to compromise
3
the system or equipment.
4
A little over 40 of those controls are
5
technical controls, an example of which is in Appendix
6
B.4.2, User Identification and Authentication, where
7
systems are required to essentially authenticate who
8
is accessing them.
9
There
are
also
a
large
number
of
10
operational and management controls.
Section C.11.4
11
covers configuration change control which governs
12
changes to your critical digital assets.
13
We recognize cyber security features may
14
be included in digital safety systems as Steve alluded
15
to earlier.
16
elect not to for a lot of very good reasons.
17
build the defenses around the parameter as opposed to
18
build them in the system.
They also may not be.
Licensees may
They may
19
However, if cyber security controls are
20
included in digital safety system we would anticipate
21
those features would have been developed under the
22
same quality processes as the digital safety system
23
gets developed.
24
both a Part 50 reliability purpose and 73 cyber
25
security purpose, we under the Part 50 would evaluate
If that cyber security feature serves
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1
that feature for its ability to maintain the reliable
2
operation of the system.
3
a conclusion that it meets its Part 73 cyber security
4
intended function.
We would not try to come to
5
And similarly if a system is exclusively
6
a cyber security feature we would still want to look
7
at it.
8
ensuring that that cyber feature does not negatively
9
impact
10
But our primary focus under Part 50 would be
or
degrade
the
reliable
operation
or
performance of the safety system.
11
And, with that, I'm going to turn the
12
presentation back over to Steve to finish up.
13
you.
Thank
14
MR. ARNDT:
Thank you, Tim.
15
The next two slides I'm going to talk
16
about specific efforts that are underway to deal with
17
the whole issue of coordination among the various
18
players and our future broader things beyond just
19
1.152.
20
By
21
recognize you.
22
the
way,
Charlie,
you
wouldn't
Don't be shy.
One of the issues that we've always known
23
was an issue but was brought to a very appropriate
24
head at the subcommittee was the coordination between
25
the
reviews
with
the
licensing reviews and the
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1
inspections.
2
New reactors and current reactor backfits
3
do the safety reviews and the licensing and, of
4
course, NSIR does the cyber security plan licensing.
5
These are all ongoing activities.
6
make sure there's some kind of formal requirement,
7
formal process, by which we talk to each other.
8
reviewing in some cases the same systems, not in all
9
cases, because the cyber rule is much broader than
There is a need to
We're
10
Part 50.
11
security systems, emergency preparedness systems that
12
we don't look at.
13
at together there needs to be a formal process.
14
They look at important safety systems,
To
But for the systems that we do look
do
that, we're doing a number of
15
different things, one of which is an interoffice
16
office instruction.
For those of you who are not
17
familiar
an
18
instruction to staff in a particular office and an
19
interoffice office instruction to staff in a number of
20
offices to specifically talk to when you do a review
21
that involves digital systems make sure the safety
22
people are looking at it and the security people are
23
looking at it.
24
25
with
it,
office
instruction
is
The instruction talks about schedule.
talks about timing.
an
It
It talks about who needs to talk
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1
to who, what the responsibilities are.
2
procedure is ongoing.
3
and we're going to work on that probably issuing it
4
later this year, probably late summer.
5
And that
We've got a very rough draft
In addition to that, as I alluded to
6
earlier, the inspection part of this will have a piece
7
of that.
8
either in the safety review or in the security plan
9
review licensing activities, there will be a pointer
10
So if a particular issue is identified
to something in the inspection program.
11
As Dr. Stetkar talked about earlier, those
12
programs deal with different parts of the life cycle,
13
the installation, the test, the operations, things
14
like
15
procedure
16
installation and post installation testing.
17
the procedure that they're using in Oconee for the
18
inspection that starts actually next week.
that.
Currently we've got an inspection
for
looking
digital
to
modified
system
This is
That's
20
pointers to the cyber program.
21
implementation inspection procedure which is being
22
developed now and will probably be done next year will
23
have pointers specifically back to both the safety
24
system
25
systems.
procedure
be
safety
19
inspection
going
at
to
have
The cyber
for
these
kinds
of
When you do the review, make sure you're
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1
talking to them about these kinds of things and back
2
to the original plan reviews and safety analysis.
3
Right
to
the
safety
analysis
inspection procedure.
has
4
pointers
5
inspection procedure has pointers back to the safety
6
analysis.
7
with those.
8
but it does solve the coordination issue or it will
9
solve the coordination issue.
10
the
now,
And the
We're going to do a cross toss associated
So that doesn't solve the review issue,
MEMBER BROWN:
That was -- You just talked
11
about design stuff.
So that's how you meet the safety
12
functions that are supposed to be done.
13
MR. ARNDT:
Correct.
14
MEMBER BROWN:
15
MR. ARNDT:
16
MEMBER BROWN:
17
MR. ARNDT:
Not the cyber functions.
I believe I talked about both.
Oh, I missed it if you did.
Okay.
Timing is part of the
18
issue.
19
the licensing review for all the current operating
20
plants for their cyber plant.
21
is ongoing.
22
depending
23
schedule it will be done in a sequence-based process
24
over a number of years.
25
Snapshot today, we're in the process of doing
That licensing review
It's going to be done for all of them and
upon
the
plan
and
the
implementation
Once that's complete, the licensees will
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1
be required to update their plan and update their
2
implementation as new threats arise.
3
MEMBER BROWN:
4
MR. ARNDT:
Put aside the new --
Let me finish please.
For the
5
digital safety systems, that is done when the licensee
6
wants to do a change.
7
request and we do our review.
8
of the safety systems, our procedures will say, "Go
9
and talk to the cyber people and see what their plan
They send a license amendment
When we do our review
10
is.
See how they're integrating this cyber security
11
issue for this new system into an update into an
12
update to their cyber plan."
13
cyber plan when they put in a new system should say is
14
this being reviewed by the NRR people as part of the
15
license amendment.
16
17
MEMBER BROWN:
And the opposite, their
So you're going to do what
you said you weren't going to do in 1.152.
18
MR. ARNDT:
No.
We're going to do what we
19
said we were going to do in terms of talking to each
20
other and making sure the two different people know
21
what's going on and know what the particular systems
22
are supposed to do.
23
MEMBER BROWN:
24
MR. ARNDT:
25
You just lost me, Steve.
What we said we're not going
to do in 1.152 is review the safety system for its
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1
effectiveness to mitigate cyber.
2
3
MEMBER BROWN:
During the safety system
review.
4
MR. ARNDT:
Safety system review.
But we
5
will look at what the cyber controls are to make sure
6
they're not degrading a safety function.
7
MEMBER BLEY:
8
MEMBER BROWN:
9
To mitigate I guess.
I'm trying to -- You're
wordsmithing too much on me here.
10
MR. ARNDT:
I'm not trying to.
11
MEMBER BROWN:
It just sounds like nuances
12
and carefully selected words.
13
somebody like Oconee who is putting in a new digital
14
protection system.
It's down there now.
15
MR. ARNDT:
16
MEMBER BROWN:
17
Right.
MR. ARNDT:
19
MEMBER BROWN:
So that's water over
Right.
So you're doing it on a
backwards basis.
21
MR. ARNDT:
22
MEMBER BROWN:
23
Okay.
the dam or under the bridge whichever the case may be.
18
20
I mean I understand if
Correct.
They're now required to put
together a cyber plan per 73.54.
24
MR. ARNDT:
Right.
25
MEMBER BROWN:
And submit it.
Whether the
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design
actually
has
features
2
implement the cyber plan is questionable.
3
know until you look at it.
4
something to look at.
5
say, "Gee, you can't do these things."
MR. ARNDT:
7
MEMBER BROWN:
So somebody now has
Right.
That means somebody is
going to have to make modifications somewhere.
9
MR. ARNDT:
10
11
You don't
The cyber people will look and
6
8
that allow you to
If they choose --
MEMBER BROWN:
Either that or they put
bandaids on which are administrative or whatever.
12
MR. ARNDT:
They can choose as part of
13
their cyber program to have technical controls or
14
administrative controls or management controls.
15
they choose to do technical controls, they could
16
either be part of the safety system or not part of the
17
safety system.
If
18
If it's part of the safety system, they
19
can credit things that are already part of the safety
20
system or add new things to the safety system.
21
they add new things to the safety system, they have to
22
come back to us and do a license amendment for the
23
safety.
24
25
If
All of the security program is a license
amendment.
When they do that, they bring it in.
We
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1
look at it from the safety perspective.
NSIR looks at
2
it from the cyber perspective.
3
and we decide whether or not it's acceptable.
We talk to each other
4
1.1.52 simply says as part of our 1.152
5
review we're not going to look at the cyber part.
6
That's NSIR's job.
7
aspects of that particular solution.
8
9
We're going to look at the safety
MEMBER BROWN:
Once a system's already
designed, you have no choice but to do that.
If it
10
hasn't been designed and they're coming in and they're
11
going to put in a new design it seems incongruous to
12
wait for two or three years while you review this
13
process and review the design approach that they want
14
in their LAR, their License Application Request, for
15
the new system or License Amendment Request for the
16
new system to put in.
17
There you don't have to wait.
I understand.
That's the
18
point.
Plants that are already
19
existing it's obvious.
20
can do them in parallel or one or the other.
21
makes sense because you don't have any choice but to
22
wait.
You have to do things.
It's already done.
23
You
And that
The plant is already there.
But for the new plants coming along or
24
backfit a new system into the plant, you don't have to
25
wait until the whole thing is done.
You can integrate
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it before during the design phase.
2
says "No, we're not going to bother with that.
3
just make sure anything they put in there that they is
4
going to mitigate the stuff is not going to impact the
5
safety system.
6
later."
7
All that 1.152
We'll
And we'll worry about the other stuff
That's what you've got written down.
8
understand
your
thought
process
on
9
You're going to develop a coordinating process.
I
coordination.
But
10
you've got to separate the systems you're dealing with
11
from the stuff that's going to be designed and applied
12
for as opposed to those that they're already in place.
13
If they're already in place, you have no choice but to
14
do certain -- They're just there.
15
And that's kinda fundamentally what we've
16
been talking about in this other point about if you're
17
going out into one of these new plants, whatever, and
18
you're doing the design you ought to make sure that
19
you do an integrated design at that point to make sure
20
that you have a system that can be satisfactorily
21
implement
22
necessary for that particular application and its
23
configuration.
24
25
the
cyber
security
features
that
are
That's the point.
MR. ARNDT:
Yes.
And I think we're doing
that in the new plant applications.
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MEMBER BROWN:
We were told that nobody --
2
I tried to look at cyber in any of the new plants
3
today and you can't find anything.
4
that's going to come if you go look in whatever, the
5
Tier 1, whatever it is, chapters.
6
7
MR. ARNDT:
It's downstream.
I think my colleagues from
NSIR would like to address that.
8
9
There's a plan
MEMBER BROWN:
Sorry.
I didn't hear.
You have to talk louder when I'm talking anyway.
10
MR. LAYTON:
As I'm understanding the
11
dialogue, in licensing we may not be looking at the
12
cyber security design aspects.
13
forward and submit their plans, that we would be
14
looking at it as they submit them.
15
mentioned before if we're able to get them to submit
16
them in more of a phased approach we would be looking
17
at them earlier than just right at the end of the
18
process.
19
MEMBER BROWN:
But as they move
And like I
I understand that.
20
that's not required.
21
could encourage them to do that.
But
They don't have to do that.
22
MR. LAYTON:
23
MEMBER BROWN:
24
MR. LAYTON:
25
(Off the record comments.)
You
Correct.
But they don't have to.
Correct.
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MEMBER BROWN:
2
MR. LAYTON:
I'm sorry.
No, your point is correct.
3
On the phase approach it is voluntarily for them to do
4
that.
5
that plan reviewed and approved before we --
But before they operate they still have to have
6
MEMBER BROWN:
7
MR. ARNDT:
discussions
I understand that.
Okay.
on
I'm sure we will have
8
additional
this.
Other future
9
activities, the subcommittee requested that we give a
10
broader discussion on other future activities that
11
relate to these matters.
12
rulemaking is in progress now to codify the updated
13
version of 603 as the rule for the safety systems.
14
And that's ongoing and should be done late next year.
15
We talked about at some length Revision 4
16
to 1.152 to address the new version of 7.43 and other
17
needed guidance.
As you probably know,
18
Starting next fiscal year which will be
19
September, I'm sorry, October, we're going to start a
20
major revision of Chapter 7 to do a number of things,
21
one of which is incorporated interim staff guidance,
22
update a number of things associated with lessons
23
learned from the last basically ten years since we've
24
done a major upgrade.
25
three years ago.
We did a minor upgrade about
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1
We're also on the NSIR going to do a
2
revision of 5.71 based on what we've learned as well
3
as hopefully including a formal endorsement of the
4
industry guidance and update Chapter 13 which is where
5
the cyber security lies in the standard review plan.
6
That should be done spring of 2012 or thereabouts.
7
There's also work associated with support
8
documents both on the NEI side and the NRC side to
9
provide
10
additional
guidance
at
a
lower tier for
implementation of 5.71.
11
And, of course, there's the inspection
12
procedure guidance that needs to be done for the
13
security program.
14
procedure for the safety program.
It's going to
15
probably get tweaked after Diablo.
That will be a
16
pilot for both the new ISG-06 process, but also we
17
expect to revise our inspection procedure after the
18
Oconee program which Unit 1 is ongoing right now.
19
Unit 2 and Unit 3 will be a year or two years later
20
based on their shutdown schedule.
21
which is hopefully going to start the licensing review
22
in the summer.
We currently have an inspection
23
MEMBER BROWN:
24
MR. ARNDT:
25
And also Diablo
This summer?
This summer.
After that is
done, we'll probably update and revise our inspection
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procedure
2
procedure in the program associated with it for cyber
3
is being developed now and will be updated or should
4
be completed sometime next year.
5
for
safety
systems.
The inspection
So those are the major piece parts.
As
6
some of you probably know -- I know Charlie does --
7
there is also a number of other regulatory guides that
8
are currently in the process of being revised and will
9
come to the Committee probably this summer or fall
10
which have to do with the software development process
11
artifacts, the software development plan.
12
13
MEMBER BROWN:
Yes.
I just -- There are
five or six of them if I remember in that package.
14
MR. ARNDT:
Six, yes.
15
MEMBER BROWN:
And I think we'd like to do
16
-- At least personally we ought not do those one at a
17
time.
18
We ought to try to do them all at once because I think
19
at least at quick look they were all tied together.
We ought to try to do -- I hate to say this.
20
MR.
ARNDT:
They're all basically
21
associated with the software development process, be
22
it the planning, the implementation, the verification
23
validation, all the different issues that parallel on
24
the staff side with Branch Technical Position 14.
25
probably makes sense to do them at once, although that
It
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will be a fairly large --
2
MEMBER BROWN:
3
each of these is.
4
I don't remember how long
I knew there were six of them.
MR. ARNDT:
They're about 20 pages each.
5
And then most of them reference IEEE standards, some
6
of which are fairly small.
7
encyclopedic.
8
9
MEMBER BROWN:
If I read them, I wouldn't
remember them anyway.
10
11
Some of which are
MR. ARNDT:
So that's the basic program
plan for the next two to three years.
12
In
summary,
we'll
close
our
formal
13
presentation there.
14
overview of how the digital system safety and cyber
15
security licensing and oversight process is currently
16
and our plans for modifications in the near term.
17
We believe we've provided a good
We provided at some level of detail the
18
changes that we are proposing to Reg. Guide 1.152
19
regarding the security development and operational
20
environment and other issues.
21
address all the questions raised at the subcommittee
22
meeting and throughout the presentation.
23
realize
24
questions that you have for us.
25
there
will
probably
And we've tried to
be
some
Although we
additional
So, with that, I'll stop talking for a
NEAL R. GROSS
(202) 234-4433
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.
WASHINGTON, D.C. 20005-3701
(202) 234-4433
288
1
second at least.
2
3
MEMBER BROWN:
else to say?
4
5
Tim, do you have anything
MR. MOSSMAN:
No.
Thank you.
6
MR. ARNDT:
7
MEMBER BROWN:
8
Appreciate the time.
Turn it back to you, Charlie.
Other comments?
John?
Anybody else?
9
(No verbal response.)
10
Thank you very much for your presentation.
11
Thank you very much for the eloquence with which you
12
parried the thrusts of the discussion.
13
MEMBER CORRADINI:
14
MR. ARNDT:
They're getting expert.
With respect to one of the
15
earlier comments, I would direct you to 73.54(f).
16
might find the words enlightening.
17
18
MEMBER BROWN:
On what?
You
Just tell me what
they are.
19
MR.
ARNDT:
20
procedures,
21
supporting technical information used by the licensee
22
need
23
approval as part of the cyber security plan but are
24
subject to inspection by the staff on a periodic
25
basis."
not
be
site
"Policies implementing
specific
submitted
for
analysis
Commission
and
other
review and
NEAL R. GROSS
(202) 234-4433
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.
WASHINGTON, D.C. 20005-3701
(202) 234-4433
289
1
MEMBER BROWN:
That's disturbing.
2
MEMBER CORRADINI:
3
MEMBER BROWN:
It's a rule.
What did I hear in one of
4
the meetings yesterday?
I'm not going to repeat it
5
because I don't want anybody to think I think that
6
way.
7
need rules.
But if you didn't have exceptions, you wouldn't
One way of thinking about things.
8
MR. ARNDT:
Correct.
9
MEMBER BROWN:
Other than that, thank you
10
very much.
We appreciate it.
I think you covered the
11
waterfront as far as I'm concerned.
12
I turn it back to you, Mr. Chairman.
13
CHAIRMAN ABDEL-KHALIK:
14
MEMBER BROWN:
15
CHAIRMAN ABDEL-KHALIK:
Thank you.
On time.
At this time we
16
are off the record and we are scheduled for a 15
17
minute break.
18
reading some of the two draft letters that we have.
19
4:10 p.m. please.
20
We will come back at 4:10 p.m. to start
Off the record.
(Whereupon, a short recess was taken.)
21
22
23
24
25
NEAL R. GROSS
(202) 234-4433
COURT REPORTERS AND TRANSCRIBERS
1323 RHODE ISLAND AVE., N.W.
WASHINGTON, D.C. 20005-3701
(202) 234-4433
UNISTAR NUCLEAR ENERGY
Presentation to ACRS Full Committee
U.S. EPRTM
Calvert Cliffs Nuclear Power Plant Unit 3
FSAR Chapters 2 (Part-1), 4, 5, 8, 10, 11, 12, 16, 17,19
SER with Open Items
April 7, 2011
Introduction
•
Greg Gibson, Senior Vice President, Regulatory Affairs, will lead the Calvert
Cliffs Unit 3 presentation.
•
Presentation was prepared by UniStar and is supported by AREVA (U.S.
EPR Supplier).
− Mark Finley (UniStar - Engineering Manager)
− Richard Szoch (UniStar - Director of Testing & Programs Development)
− Jean-Luc Begon (UniStar - Manager of Electrical/I&C Engineering)
− Gene Hughes (UniStar - Director of PRA)
− Ted Messier (AREVA - Meteorologist/Principal Scientist)
− Josh Reinert (AREVA - COLA PRA Lead)
2
Calvert Cliffs Unit 3
Overview
3
Items Of Interest
 The below listed site specific information is discussed in detail in today’s
presentation:
 Chapter 2, (Part 1), Site Characteristics
 Chapter 8, Electrical Power
 Chapter 17, Quality & Reliability Assurance/ Chapter 19 PRA
4
Calvert Cliffs Unit 3
ACRS Full Committee Meeting
Introduction
•
UNE is responsible for the design of Calvert Cliffs Unit 3 and develops the
design primarily through contracts with Bechtel and AREVA who have
joined in a Consortium to develop the detailed design of the US EPR.
•
RCOLA authored using ‘Incorporate by Reference’ (IBR) methodology.
•
To simplify document presentation and review, only supplemental
information, or site-specific information, departures or exemptions from the
U.S. EPR FSAR are contained in the COLA.
•
The focus of today’s presentation will be a summary of the first 9½ FSAR
Chapters that have been presented to the U.S. EPR ACRS Subcommittee.
5
6
7
List of Chapters










Chapter 2, Sections 2.1, 2.1, 2.2 & 2.3, Site Characteristics
Chapter 4, Reactor
Chapter 5, Reactor Coolant System
Chapter 8, Electric Power
Chapter 10, Steam and Power Conversion System
Chapter 11, Radioactive Waste Management
Chapter 12, Radiation Protection
Chapter 16, Technical Specifications
Chapter 17, Quality Assurance and Reliability Assurance
Chapter 19, Probabilistic Risk Assessment /Severe Accident Evaluation
8
ACRS Full Committee Meeting
Agenda
Based on Presentations to Subcommittee

•

•

•

Chapter 2 (Part 1)
Meteorology
Chapter 8
Off-site Transmission System
Chapter 17 & Chapter 19
Reliability Assurance /PRA
Conclusions
9
Chapter 2, (Part 1), Site Characteristics
Meteorology
Presented by Mark Finley
UniStar Engineering Manager
10
Meteorological Design Parameters
 Discussion at the ACRS Subcommittee for Calvert Cliffs Unit 3 Chapter 2
(Part 1) related to meteorological design parameters and the margin
associated to these parameters.
 Next is a brief review of the significant meteorological design parameters
and their associated site specific (Calvert Cliffs Unit 3) and generic (US
EPR) values.
 A conservative approach has been used to set the design parameters in
accordance with the associated regulatory requirements.
11
Maximum Rainfall Rate
 The maximum rainfall rate is generally associated with tropical storms.
 There is no clear trend in the annual number of tropical storms.
 The National Weather Service calculated 100-year annual recurrence
interval for rainfall in the site region (Solomons, MD), using as much as 126
years of historical data, is 3.28 inches/hr.
 Thus, there is reasonable assurance that the generic maximum rainfall rate
of 19.4 inches/hr will not be exceeded.
 A site specific maximum rainfall rate of 18.5 inches/hr will be used for
design of the one site specific safety structure (UHS M/U Building).
12
Roof Snow Load
 Winter snow volumes are projected to decrease while winter precipitation
amounts are projected to increase.
 The site-specific characteristic value was determined to be 38 psf (pounds
per square foot) using ISG-07 and as much as 113 years of historical data:
• (1) the 100-year return period snowpack,
• (2) the historical maximum snowpack,
• (3) the 100-year return period snowfall event, and
• (4) the historical maximum snowfall event in the site region.
 Thus, there is reasonable assurance that the roof snow load generic design
value of 100 psf will not be exceeded.
 A snow and ice load of 65 psf will be used for design of the one site
specific safety structure (UHS M/U Building).
13
Maximum Non-Tornado Wind Speed
 There are no specific projections regarding wind speed.
 Thus, there is no basis to assess the possible impact on the ASCE 7-05
Basic Wind Speed (3-second gust).
 The site-specific characteristic value was determined to be 95 mph (miles
per hour) (50-year return period value) using ASCE 7-05, which included
the results of an analysis of hurricane wind speeds.
 The 100-year return period value was determined to be 102 mph.
 Thus, there is reasonable assurance that the maximum non-tornado wind
speed generic design value of 145 mph will not be exceeded.
 The 100-year return period value of 102 mph will be used for design of the
one site specific safety structure (UHS M/U Building).
14
Tornado
 There is insufficient evidence to determine whether trends exist in smallscale phenomena such as tornadoes.
 Thus, there is no basis to assess the possible impact on the tornado
maximum wind speed.
 The site-specific characteristic value was determined to be 200 mph using
Regulatory Guide 1.76.
 Thus, there is reasonable assurance that the maximum tornado wind speed
design value of 230 mph will not be exceeded.
 The site-specific characteristic value of 200 mph will be used for design of
the one site specific safety structure (UHS M/U Building).
15
Maximum Temperature Values
 The amount of warming later in the century depends on the mitigation of
greenhouse gas emissions.
 The 0% exceedance maximum dry bulb temperature is 102°F.
 If the projected mid century annual average temperature increase of 3°F
(1.7°C) is added to the 0% exceedance maximum dry bulb temperature of
102°F, the result is 102°F + 3°F = 105°F.
 Thus, there is reasonable assurance that the site extreme temperature
value of 115°F will not be exceeded.
 The 0% exceedance maximum dry bulb temperature of 102°F will be used
for the ventilation design of the one site specific safety structure (UHS M/U
Building).
16
Meteorological Design Parameters
Conclusions
 Significant margin is available to generic meteorological design values to
accommodate future changes in climate for Calvert Cliffs Unit 3.
 Although not as much margin is available for site specific design values,
these values are also conservative and monitoring programs at site will be
used to assure design margins are assessed in the future should climate
change.
17
ACRS Full Committee Meeting
Agenda
Based on Presentations to Subcommittee

•

•

•

Chapter 2 (Part 1)
Meteorology
Chapter 8
Off-site Transmission System
Chapter 17 & Chapter 19
Reliability Assurance /PRA
Conclusions
18
Chapter 8, Electrical Power
Off-site Transmission System
Presented by Jean-Luc Begon
UniStar Supervisor of Electrical/I&C Engineering
19
Off-site Transmission System
Calvert Cliffs Unit 3
One three phase 500 kV transmission line from the CCNPP site to the Chalk Point Substation in Anne Arundel County (18 Miles)
Two separate three phase 500 kV transmission lines (single right‐of‐way) from the CCNPP site to the Waugh Chapel Substation in Anne Arundel County (48 Miles)
20
Off-site Transmission System
Regulatory Design Bases
Appendix A to part 50
General Design Criteria for Nuclear Power Plants
Criterion 17--Electric power systems:
… Electric power from the transmission network to the onsite electric
distribution system shall be supplied by two physically independent circuits (not
necessarily on separate rights of way) designed and located so as to minimize
to the extent practical the likelihood of their simultaneous failure under
operating and postulated accident and environmental conditions. …
Calvert Cliffs Unit 3 design meets the Regulatory Design Bases
21
Off-site Transmission System
Loss Of Offsite Power - PRA
 Loss of Offsite Power (LOOP) event frequency is approximately 1.7E-02/yr
for the Calvert Cliffs Unit 3 site.
 This LOOP event frequency value used in the U.S. EPR FSAR PRA model
is 1.9E-02/yr.
LOOP event frequency for Calvert Cliffs Unit 3 site is bounded by
the value in the U.S. EPR PRA model.
22
Off-site Transmission System
Specific Design Parameters
 500 kV line design criteria
• Wind Speed: 100 mph for wires
125 mph for towers
• Ice Loading: 1½ inch radial
• Physical Separation: one tower collapse does not affect other lines.
• Electrical Fault: one electrical fault does not affect other line.
.
23
Off-site Transmission System
Tornadoes in Calvert County
 In the period from January 1, 1950 through December 31, 2006, twelve (12)
tornadoes were reported in Calvert County. This corresponds to an annual
average of 0.2 tornadoes per year.
 The magnitude of the tornadoes ranged from F0 to F2, as designated by the
National Weather Service.
• An F0 tornado has estimated wind speeds less than 73 mph.
• An F1 tornado has estimated wind speeds between 73 and 112 mph.
• An F2 tornado has estimated wind speeds between 113 and 157 mph.
 The widths of the paths of the 12 tornadoes in Calvert Count were
estimated to range from 17 to 200 yards.
24
Off-site Transmission System
Loss of 500KV lines in Calvert County
 Historical Data for Grid at Calvert Cliffs Unit 1 & 2
• No grid related loss of offsite power since 1985.
25
Off-site Transmission System
Summary
 Proposed design meets 10 CFR Part 50 Appendix A design criterion 17
(Physical independence).
 Calvert Cliffs Unit 3 LOOP event frequency is bounded by the U.S. EPR
PRA model.
 Lines are designed with requirements to cope with extreme weather
conditions.
 No grid related loss of offsite power at Calvert Cliffs Unit 1 & 2 since 1985.
 Should a loss of offsite power occur the U.S. EPR can rely on:
 Full load rejection (Island mode – Plant supplying itself)
 Four Emergency Diesel Generators
 Two Alternate Current sources
26
ACRS Full Committee Meeting
Agenda
Based on Presentations to Subcommittee

•

•

•

Chapter 2 (Part 1)
Meteorology
Chapter 8
Off-site Transmission System
Chapter 17 & Chapter 19
Reliability Assurance /PRA
Conclusions
27
Chapter 17 Quality and Reliability Assurance
Chapter 19 PRA/Severe Accident Evaluation
Reliability Assurance /PRA
Presented by Gene Hughes
UniStar Supervisor of PRA
and
Richard Szoch
UniStar Supervisor of Testing &
Programs Development
28
Reliability Assurance
.
RAP
DESIGN
EXPERT PANEL REVIEW
RISK SIGN’T SSC LIST
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
M‐RULE
NEI 07‐02A
Program
•CAP
• Q/A
• Procurement
• Maintenance
• ISI/IST
• Surveillance Test
PRA
29
Reliability Assurance
.
RAP
EXPERT PANEL REVIEW
RISK SIGN’T SSC LIST
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
DESIGN
D – RAP
(Stage 1)
PRA
F
U
E
L
M‐RULE
NEI 07‐02A
Program
L
O
A
D
•CAP
• Q/A
• Procurement
• Maintenance
• ISI/IST
• Surveillance Test
S Operational C RAP (Stage 2)
H
E
D
U
L
E
30
Reliability Assurance
.
RAP
DESIGN
PRA
EXPERT PANEL REVIEW
INITIAL DESIGN AT DC / COL Stage
RISK SIGN’T SSC LIST
DETAILED DESIGN &
DESIGN CHANGE PROCESS
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
FINALIZED DESIGN DETAIL
F
U
E
L
L
O
A
D
M‐RULE
NEI 07‐02A
Program
DESIGN CHANGE PROCESS
S
C
H
E
D
U
L
E
31
Reliability Assurance
.
RAP
EXPERT PANEL REVIEW
RISK SIGN’T SSC LIST
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
Function of the Panel
Decision Criteria
Documentation
Etc.
•
•
•
•
•
•
PRA Insights (CDF, LRF, Other)
Maintenance Considerations
Defense in Depth
Safety Margins Preserved
Technical Specifications
Etc.
F
U
E
L
M‐RULE
NEI 07‐02A
Program
L
O
A
D
S
C
H
E
D
U
L
E
32
Reliability Assurance
SSC Disposition, Functional Significance, Basis, Etc.
.
RAP
EXPERT PANEL REVIEW
RISK SIGN’T SSC LIST
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
Function of the Panel
Decision Criteria
Documentation
Etc.
•
•
•
•
•
•
PRA Insights (CDF, LRF, Other)
Maintenance Considerations
Defense in Depth
Safety Margins Preserved
Technical Specifications
Etc.
F
U
E
L
L
O
A
D
S
C
H
E
D
U
L
E
M‐RULE
NEI 07‐02A
Program
TEXT TO
EXPLAIN
•Scoping,
GOES
•Monitoring
HEE
•Corrective
Action
•Preventative
Maintenance
•Periodic
Evaluation
•Risk
Assessment
•Training and
Qualification
•Operating
Experience
33
Reliability Assurance
./
RAP
DESIGN
PRA
EXPERT PANEL REVIEW
INITIAL DESIGN AT DC / COL Stage
RISK SIGN’T SSC LIST
DETAILED DESIGN &
DESIGN CHANGE PROCESS
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
FINALIZED DESIGN DETAIL
F
U
E
L
L
O
A
D
M‐RULE
NEI 07‐02A
Program
DESIGN CHANGE PROCESS
S
C
H
E
D
U
L
E
34
Reliability Assurance
.
RAP
DESIGN
PRA
EXPERT PANEL REVIEW
INITIAL DESIGN AT DC / COL Stage
DC Stage PRA Bounds COLA
RISK SIGN’T SSC LIST
DETAILED DESIGN &
DESIGN CHANGE PROCESS
Enhanced COL PRA Plant Details
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
FINALIZED DESIGN DETAIL
PRA As‐Built, As to be Operated Meets Stds. F
U
E
L
L
O
A
D
S
C
H
E
D
U
L
E
M‐RULE
NEI 07‐02A
Program
DESIGN CHANGE PROCESS
Periodic PRA Updates for Data, Design, Etc.
35
Reliability Assurance
.
RAP
DESIGN
PRA
EXPERT PANEL REVIEW
INITIAL DESIGN AT DC / COL Stage
DC Stage PRA Bounds COLA
RISK SIGN’T SSC LIST
DETAILED DESIGN &
DESIGN CHANGE PROCESS
Enhanced COL PRA Plant Details
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
FINALIZED DESIGN DETAIL
PRA As‐Built, As to be Operated Meets Stds. F
U
E
L
L
O
A
D
S
C
H
E
D
U
L
E
M‐RULE
NEI 07‐02A
Program
DESIGN CHANGE PROCESS
Periodic PRA Updates for Data, Design, Etc.
36
Reliability Assurance
.
RAP
DESIGN
PRA
EXPERT PANEL REVIEW
INITIAL DESIGN AT DC / COL Stage
DC Stage PRA Bounds COLA
RISK SIGN’T SSC LIST
DETAILED DESIGN &
DESIGN CHANGE PROCESS
Enhanced COL PRA Plant Details
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
FINALIZED DESIGN DETAIL
PRA As‐Built, As to be Operated Meets Stds. F
U
E
L
L
O
A
D
S
C
H
E
D
U
L
E
M‐RULE
NEI 07‐02A
Program
DESIGN CHANGE PROCESS
Periodic PRA Updates for Data, Design, Etc.
37
Reliability Assurance
./
RAP
DESIGN
PRA
EXPERT PANEL REVIEW
INITIAL DESIGN AT DC / COL Stage
DC Stage PRA Bounds COLA
RISK SIGN’T SSC LIST
DETAILED DESIGN &
DESIGN CHANGE PROCESS
Enhanced COL PRA Plant Details
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
FINALIZED DESIGN DETAIL
PRA As‐Built, As to be Operated Meets Stds. F
U
E
L
L
O
A
D
S
C
H
E
D
U
L
E
M‐RULE
NEI 07‐02A
Program
DESIGN CHANGE PROCESS
Periodic PRA Updates for Data, Design, Etc.
38
Reliability Assurance
./
RAP
DESIGN
PRA
EXPERT PANEL REVIEW
INITIAL DESIGN AT DC / COL Stage
DC Stage PRA Bounds COLA
RISK SIGN’T SSC LIST
DETAILED DESIGN &
DESIGN CHANGE PROCESS
Enhanced COL PRA Plant Details
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
FINALIZED DESIGN DETAIL
PRA As‐Built, As to be Operated Meets Stds. F
U
E
L
L
O
A
D
S
C
H
E
D
U
L
E
M‐RULE
NEI 07‐02A
Program
DESIGN CHANGE PROCESS
Periodic PRA Updates for Data, Design, Etc.
39
Reliability Assurance
./Design
RAP
DESIGN
PRA
EXPERT PANEL REVIEW
INITIAL DESIGN AT DC / COL Stage
DC Stage PRA Bounds COLA
RISK SIGN’T SSC LIST
DETAILED DESIGN &
DESIGN CHANGE PROCESS
Enhanced COL PRA Plant Details
• CAP/QA
• Procurement
• Fabrication
• Construction
• Installation
• Testing
FINALIZED DESIGN DETAIL
PRA As‐Built, As to be Operated Meets Stds. F
U
E
L
L
O
A
D
S
C
H
E
D
U
L
E
M‐RULE
NEI 07‐02A
Program
DESIGN CHANGE PROCESS
Periodic PRA Updates for Data, Design, Etc.
40
Reliability Assurance
• RAP Expert Panel – Membership
 Designated individuals having expertise in the areas of:
 Risk Assessment
▪ Operations
▪ Maintenance
 Engineering
▪ Quality Assurance ▪ Licensing
• RAP Expert Panel – Categorization
 Identify a risk categorization of the component based on PRA insights
(where the component is modeled)
 Develop a risk categorization of the component based on deterministic
insights
 Designate the overall categorization of the component
41
Reliability Assurance
• RAP Expert Panel – Risk Ranking
 PRA Ranking: based upon its Fussell-Vesely (FV) importance and its risk
achievement worth (RAW)
 Deterministic Ranking regardless of whether they are also subject to the
PRA risk categorization process
 Is the function used to mitigate accidents or transients?
 Is the function specifically called out in the
Emergency Operating Procedures (EOPs)?
 Does the loss of the function directly fail another risk-significant system?
 Is the loss of the function safety significant for shutdown or mode changes?
 Does the loss of the function, in and of itself, directly cause an initiating event?
42
Probabilistic Risk Assessment
and Severe Accident Evaluation
Calvert Cliffs 3 COLA PRA
Summary of U.S. EPR FSAR and Calvert Cliffs 3 PRA Results
At-Power Events
F L D -A N N A L L , 6 %
F L D -S A B 1 4 F B , 4 %
F L D -E F W , 1 %
F IR E -S A B -M E C H , 3 %
F IR E -S W G R , 4 %
LO OP , 27%
FIR E - M C R , 5 %
F IR E -M S -V R , 6 %
S LO C A, 9 %
F IR E -S A B 1 4 -A C , 1 4 %
MF W , 1%
A TW S , 2%
C C W S/E SW S, 3%
B a la n c e o f P la n t , 1 %
SG T R , 2%
G T, 5%
S LB , 3%
T o ta l A t P o w e r C D F = 5 .3 E -0 7 / y r
43
Probabilistic Risk Assessment
and Severe Accident Evaluation
Update During Design and Construction
RISK INFORMED .
DESIGN EVALUATION OF ALTERNATIVES
PROCEDURE EVALUATION
TECHNICAL SPECIFICATION INPUTS
D‐RAP plus PROCUREMENT
DESIGN
PRA
INITIAL DESIGN AT DC / COL Stage
DC Stage PRA Bounds COLA
DETAILED DESIGN / CHANGE PROCESS
Enhanced COL PRA Plant Details
FINALIZED DESIGN DETAIL
PRA As‐Built, As to be Operated Meets Stds. F
U
E
L
L
O
A
D
S
C
H
E
D
U
L
E
M‐RULE
MSPI ISI
NEI 07‐02A
SDP M‐Rule
Program
NOED IST
Tech. Specs.
DESIGN CHANGE PROCESS
Periodic PRA Updates for Data, Design, Etc.
44
Probabilistic Risk Assessment
and Severe Accident Evaluation
Site Specific Features
 LOOP Frequency Bounded by U.S EPR Design Certification
 UHS Makeup Water System – Adequate capacity 72 hour plus makeup
 Circulating Water System – Evaluated and treatment confirmed
 Raw Water System, includes Essential Service Water Normal Makeup
Supply – Not in PRA (no recovery action to credit Raw Water System)
 Sewage Water Treatment System – Not in PRA
 Security Access Facility, including warehouse – Not in PRA
 Central Gas Distribution System – Discussed under External Events
 Potable and Sanitary Water Systems – Not in PRA
45
Probabilistic Risk Assessment
External Events
46
ACRS Full Committee Meeting
Agenda
Based on Presentations to Subcommittee

•

•

•

Chapter 2 (Part 1)
Meteorology
Chapter 8
Off-site Transmission System
Chapter 17 & Chapter 19
Reliability Assurance /PRA
Conclusions
47
Conclusions
 No ASLB Contentions.
 There are three (3) departures and three (3) exemptions.
 Responses have been submitted to all thirty-nine (39) SER Open Items.
 As of April 7, 2011, 60% of the Calvert Cliffs Unit 3 COLA has completed
Phase 3 and these Chapters are ready to move to Phase 4.
48
Acronyms
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
ACRS – Advisory Committee on Reactor
Safeguards
ASLB – Atomic Safety & Licensing Board
ASCE – American Society of Civil Engineers
CAP – Corrective Action Program
CCWS Component Cooling Water System
CDF – Core Damage Frequency
CFR – Code of Federal Regulations
COL – Combined License
COLA – Combined License Application
CWS – Circulating Water System
DC – Design Certification
DOE – Department of Energy
DRAP – Design Reliability Assurance Program
EDF – Électricité de France
EFWS – Emergency Feedwater System
EPGB – Emergency Power Generating Building
• ESW(S) – Essential Service Water (System)
• ESWB – Essential Service Water Building
(Consisting of ESWCT & ESWPB)
•
ESWCT(S) – Essential Service Water Cooling
Tower (Structure)
•
•
EOP – Emergency Operating Procedures
FIRE-SAB-MECH – Fire in Safeguard
Buildings, Mechanical Areas
FIRE-SWGR – Fire in Switchgear Building
FIRE-SAB14-AC – Fire in Safeguard Buildings
1 or 4 Switchgear Room
FIRE-MS-VR – Fire in MFWS (Main Feedwater)
/ MSS (Main Steam) Valve Room
FLD-ANN ALL – Flooding in containment
annulus that disables all 4 safety trains.
•
•
•
•
•
•
•
•
•
•
•
•
FSAR – Final Safety Analysis Report
ESWPB – Essential Service Water Pump
Building
Fire-MCR – Fire in the Main Control Room
FLD-EFW – Flooding from the EFW system
FLD-SAB14 FB – Flooding in a Safeguard
Building
FSER – Final Safety Evaluation Report
GMRS – Ground Motion Response Spectra
GT – General Transient
49
Acronyms
• HCLPF – High Confidence, Low Probability
of Failure
•
•
•
•
•
•
•
•
•
•
•
IBR – Incorporate by Reference
ISI – Inservice Inspection
ISLOCA – Interfacing System Loss of Coolant
Accident
ISRS – In-Structure Response Spectra
IST – Inservice Testing
LOCA – Loss of Coolant Accident
LOOP – Loss of Offsite Power
LRF – Large Release Frequency
MAAP – Modular Accident Analysis Program
MCR – Main Control Room
MFW(S) Main Feedwater (System)
• MSPI - Mitigating System Performance Index
•
•
•
•
•
•
NEI – Nuclear Energy Institute
NOED – Notice of Enforcement Discretion
NRC – Nuclear Regulatory Commission
M-Rule – Maintenance Rule
M/U – Makeup
OSP – Offsite Power
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
PRA – Probabilistic Risk Assessment
QA – Quality Assurance
RCOLA – Reference COL Application
RCP – Reactor Coolant Pump
RHR(S) – Residual Heat Removal (System)
SAMDA – Severe Accident Mitigation Design
Alternatives
SD – Shutdown
SDP – Significance Determination Process
SER – Safety Evaluation Report
SGTR Steam Generator Tube Rupture
SLBI – Steam Line Break Inside Containment
SLBO – Steam Line Break Outside
Containment
SLOCA – Small Loss of Coolant Accident
SMA – Seismic Margins Assessment
SRP – Standard Review Plan
SSC – Structures, Systems, and Components
SSE – Safe Shutdown Earthquake
UHS – Ultimate Heat Sink
ULD – Uncontrolled Level Drop
50
Presentation to the ACRS Full
Committee - 582nd Meeting
Briefing on EPR Design Certification Application Safety Evaluation
Report with Open Item for Chapters 2, 4, 5, 8, 10, 11, 12, 16, 17, and 19
Surinder Arora
Project Manager
April 7, 2011
Major Milestones Chronology
07/13/2007
Part 1 of the COL Application (Partial) submitted
12/14/2007
Part 1, Rev. 1, submitted
03/14/2008
Part 1, Rev. 2, & Part 2 of the Application submitted
06/03/2008
Part 2 of the Application accepted for review (Docketed)
08/01/2008
Revision 3 submitted
03/09/2009
Revision 4 submitted
06/30/2009
Revision 5 submitted
07/14/2009
Review schedule published
09/30/2009
Revision 6 submitted
04/12/2010
Phase 1 review completion milestone
12/20/2010
Revision 7 submitted
01/12/2011
ACRS reviews complete for Chapters 2 (Group I), 4, 5, 8, 10,
11, 12, 16, 17 & 19
2 of 14
April 7, 2011, ACRS 582nd Meeting
Review Schedule
Phase - Activity
Target Date
Phase 1 - Preliminary Safety Evaluation Report (SER) and Request
for Additional Information (RAI)
April 2010 (Actual)
Phase 2 - SER with Open Items
November 2011
Phase 3 – Advisory Committee on Reactor Safeguards (ACRS)
Review of SER with Open Items
February 2012
Phase 4 - Advanced SER with No Open Items
June 2012
Phase 5 - ACRS Review of Advanced SER with No Open Items
October 2012
Phase 6 – Final SER with No Open Items
January 2013
NOTE: The target dates are current as of March 4, 2011. The target dates are
reviewed periodically and are subject to change.
3 of 14
April 7, 2011, ACRS 582nd Meeting
Review Strategy
•
•
•
•
Pre-application activities
Acceptance Review of the application
COLA has chapters and sections incorporated by Reference
Review of COLA site specific information in conjunction with
the DC review. Same technical reviewers in most cases.
• Frequent interaction with the applicant
 Teleconferences
 Audits
 Public meetings
• Use of Electronic RAI System (eRAI)
• Phase discipline
4 of 14
April 7, 2011, ACRS 582nd Meeting
Summary of SER with OI: Chapter 2
Site Characteristics
SRP Section/Application Section
Number of RAI
Questions
Number of SE
Open Items
2.0
Site Characteristics
0
0
2.1
Geography and Demography
0
0
2.2
Nearby Industrial, Transportation,
and Military Facilities
10
0
2.3
Meteorology
70
2
Totals
80
2
5 of 14
April 7, 2011, ACRS 582nd Meeting
Summary of SER with OI: Chapter 4
Reactor
SRP Section/Application Section
Number of RAI
Questions
Number of SE
Open Items
4.1
Summary Description (IBR)
0
0
4.2
Fuel System Design (IBR
w/supplement)
1
1
4.3
Nuclear Design (IBR)
1
1
4.4
Thermal-Hydraulic Design (IBR)
0
0
4.5
Reactor Materials (IBR)
0
0
4.6
Functional Design of Reactivity
Control Systems (IBR)
0
0
Totals
2
2
6 of 14
April 7, 2011, ACRS 582nd Meeting
Summary of SER with OI: Chapter 5
Reactor Coolant System and Connected
Systems
SRP Section/Application Section
Number of RAI
Questions
Number of SE
Open Items
5.1
Summary Description (IBR)
0
0
5.2
Integrity of the Reactor Coolant
Pressure Boundary
10
2
5.3
Reactor Vessel
5
0
5.4
Component and Subsystem
Design
13
1
Totals
28
3
7 of 14
April 7, 2011, ACRS 582nd Meeting
Summary of SER with OI: Chapter 8
Electric Power
SRP Section/Application Section
Number of RAI
Questions
Number of SE
Open Items
8.1
Introduction
1
0
8.2
Offsite Power System
10
0
8.3
Onsite Power System
14
0
8.4
Station Blackout
2
0
Totals
27
0
8 of 14
April 7, 2011, ACRS 582nd Meeting
Summary of SER with OI: Chapter 10
Steam and Power Conversion System
SRP Section/Application Section
Number of RAI
Questions
Number of SE
Open Items
10.1
Summary Description (IBR)
0
0
10.2
Turbine-Generator
2
0
10.3
Main Steam Supply System
4
0
10.4
Other Features of Steam and
Power Conversion System
5
1
Totals
11
1
9 of 14
April 7, 2011, ACRS 582nd Meeting
Summary of SER with OI: Chapter 11
Radioactive Waste Management
SRP Section/Application Section
Number of RAI
Questions
Number of SE
Open Items
0
0
11.1
Source Terms (IBR)
11.2
Liquid Waste Management
System
4+1*
2
11.3
Gaseous Waste Management
Systems
2+1*
1
11.4
Solid Waste Management
Systems
1
0
11.5
Process and Effluent Radiological
Monitoring and Sampling Systems
2
0
9+2*
3
Totals
10 of 14
April 7, 2011, ACRS 582nd Meeting
Summary of SER with OI: Chapter 12
Radiation Protection
SRP Section/Application Section
Number of RAI
Questions
Number of SE
Open Items
12.1
Ensuring that Occupational
Radiation Exposures are ALARA
5
0
12.2
Radiation Sources
2
0
12.3
Radiation Protection Design
Features
8
4
12.4
Dose Assessment (IBR)
0
0
12.5
Operational Radiation Protection
Program
1
0
Totals
16
4
11 of 14
April 7, 2011, ACRS 582nd Meeting
11
Summary of SER with OI: Chapter 16
Technical Specifications
SRP Section/Application Section
16.1
Introduction
16.2
Summary of Application
16.3
Regulatory Basis
16.4
Technical; Evaluation
16.5
Post Combined License Activities
16.6
Conclusions
Number of RAI
Questions
Totals
12 of 14
Number of SE
Open Items
22
1
22
1
April 7, 2011, ACRS 582nd Meeting
Summary of SER with OI: Chapter 17
Quality Assurance and Reliability Assurance
SRP Section/Application Section
Number of RAI
Questions
Number of SE
Open Items
17.1
Quality Assurance During Design (IBR)
0
0
17.2
Quality Assurance During the Operations
Phase
0
0
17.3
Quality Assurance Program Description
(IBR)
0
0
17.4
Reliability Assurance Program
9
7
17.5
Quality Assurance Program Description
6+1*
1
17.6
Description of Applicant’s Program for
Implementation of 10 CFR 50.65, the
Maintenance Rule
3
2
17.7
Maintenance Rule Program
18+1*
10
Totals
13 of 14
April 7, 2011, ACRS 582nd Meeting
Summary of SER with OI: Chapter 19
Probabilistic Risk Assessment and
Severe Accident Evaluation
SRP Section/Application Section
Number of RAI
Questions
Number of SE
Open Items
19.1
Probabilistic Risk Assessment
24
6
19.2
Severe Accident Evaluations
1
1
19.3
Open, Confirmatory, and COL Action
Items Identified as Unresolved (IBR)
0
0
Totals
25
7
14 of 14
April 7, 2011, ACRS 582nd Meeting
Advisory Committee
on Reactor Safeguards
Fukushima Event and Issues
April 7, 2011
Agenda
•
•
•
•
•
•
•
•
•
Introduction – Bill Ruland (5 min)
Sequence of Events – John Thorp (10 min)
Information Notice – Eric Bowman (5 min)
Industry Actions and Temporary Instruction – Tim
Kobetz (5 min)
Near Term Task Force – Barry Westreich (10 min)
Seismic Attributes – Syed Ali (5 min)
Station Blackout – George Wilson (10 min)
NRC Incident Response – Brian McDermott (10 min)
Emergency Preparedness – Randy Sullivan (10 min)
2
Tohoku Pacific Earthquake
• 14:46 (Local) March 11,
2011
• Magnitude 9.0 Earthquake
– 4th largest in the world since
1900 (USGS)
– Largest in Japan since
modern instrument
recordings began 130 years
ago (USGS)
• Resulted in a Tsunami that
is estimated to have
exceeded 32 feet in height
(NISA)
3
Affected Nuclear Power Stations
– Onagawa NPS
• All 3 units scrammed
– Fukushima Dai-ichi (I) NPS
• Units 1, 2, 3 scrammed
• Units 4, 5, 6 already
shutdown
– Fukushima Dai-ni (II) NPS
• All 4 units scrammed
– Tokai
• Scrammed (single unit
site)
Source: NISA
4
Extended SBO at Fukushima Dai-ichi
• Earthquake
– Reactor Units 1, 2,
and 3 scram
– Loss of offsite power
to all 6 units
• Tsunami
– Loss of emergency AC
power
• Extended Station
Blackout
5
Accident Sequence
• Reactor coolant flow after SBO
– Reactor isolation makeup water system
• Loss of coolant flow
– Utility established seawater injection
• Elevated primary containment pressure
• Explosions
– Damaged reactor buildings for Units 1, 3 and 4
– Unit 2 explosion in primary Containment- reactor
building not damaged, possible torus damage
6
5 April Status: Units 1,2 and 3
• Cores reported to be damaged
• Extent unknown
• Salt buildup from seawater injection
• All units have offsite AC power available
• Equipment verification in progress
• Freshwater injection via:
• Feedwater line
• Low pressure coolant injection
• High radiation levels in containment and
site
7
Status: Units 4, 5, and 6
• Unit 4
– Core offloaded to spent fuel pool (SFP)
– An explosion caused significant damage to Unit 4
reactor building
– SFP cooling system not functional
– SFP being cooled periodically by injection of fresh
water from a concrete truck pump
• Units 5 and 6
– On external AC power with core cooling functional
– SFP cooling is functional on both units
8
Unit 1
Unit 2
Unit 3
Unit 4
Fukushima Dai’ichi Nuclear Power Station
Information Notice 2011-05
• Purpose: to provide high level discussion of earthquake
effects at Fukushima Daiichi and allow licensee review
and consideration of actions to avoid similar problems.
• Background discussion of pertinent regulatory
requirements
– General Design Criteria 2 (or similar)
– “B.5.b Requirements” for beyond design basis events
• Interim Compensatory Measures Order EA-02-026, Section B.5.b
• License Conditions
• 10 CFR 50.54(hh)(2)
– Station Blackout Rule, 10 CFR 50.63
10
Industry Initiatives
• An industry-wide assessment to verify and validate
each plant site's readiness to manage extreme events
• Initiatives include licensee verification of:
– Each plant's capability to manage major challenges, and losses of
large areas of the plant due to natural events, fires or explosions
– Each plant's capability to manage a total loss of off-site power
– Verifying the capability to mitigate flooding and the impact of floods
– Performing walk-downs and inspection of important equipment needed
to respond successfully to extreme events like fires and flood including
identification of any potential that equipment functions could be lost
during seismic events appropriate for the site, and development of
strategies to mitigate any potential vulnerabilities.
11
NRC Inspection Activities
• Temporary Instruction 2515/183, “Followup to the
Fukushima Daiichi Nuclear Station Fuel Damage Event
• Inspection uses a combination of assessment of
licensee actions and independent inspections
• The inspection is for fact/data gathering to help
evaluate whether future regulatory actions may be
necessary.
12
Near-Term Task Force
• Commission Direction for Near-Term Review
– Conduct a methodical and systematic review of relevant NRC
regulatory requirements, programs, and processes, and their
implementation, to recommend whether the agency should
make near-term improvements to our regulatory system
– Recommendations for the content, structure, and estimated
resource impact for the longer-term review
– Independent from industry efforts
– Milestones
• 30-day Commission meeting (5/12/11)
• 60-day Commission meeting (6/16/11)
• 90-day final report, SECY, and Commission meeting
(7/19/11)
13
Longer-Term Review
• Commission Direction for Longer-Term Review
– Specific information on sequence of events and equipment
status
– Evaluate policy issues
– Potential interagency issues
– Lessons learned for facilities other than operating reactors
– Receive input and interact with all key stakeholders
– Report within six months after beginning of long-term effort
– ACRS to review final long-term report (as issued in its final
form), and provide letter report to the Commission
14
Tōhoku Earthquake and Tsunami
• Earthquake Data*
– Magnitude 9.0
– Epicenter: ~109 miles from Fukushima
site
– Peak Ground Acceleration
• 1.0g up to 2.75g at 80 miles from epicenter
• ~0.30g to 0.58g in Fukushima Prefecture
*California Coastal Commission. “The Tōhoku Earthquake of March 11, 2011: A preliminary Report on
Implications for Coastal California “
Tōhoku Earthquake and Tsunami
• Tsunami Data*
– Peak amplitude reports vary
– Reached shore within ~ one hour after the
earthquake
– Up to six miles of run-up in flat regions
*California Coastal Commission. “The Tōhoku Earthquake of March 11, 2011: A preliminary Report on
Implications for Coastal California “
Tōhoku Earthquake and Tsunami
• NPP Foundation Accelerations*
Location
Design
Japanese
Regulatory
Guide
g
Observed
g
Daiichi Unit 2
.45
.56
Daiichi Unit 6
.46
.45
Daini Unit 1
.44
.23
Daini Unit 2
.44
.20
*TEPCO Press Release April 01, 2011: The record of the earthquake intensity observed at Fukushima
Daiichi Nuclear Power Station and the Fukushima Daini Nuclear Power Station (Interim Report).
Station Blackout– Background
• NRC issued SBO Rule (10 CFR 50.63) in 1988
• Each plant must be able to withstand for a specified
duration and recover from a SBO
• Regulatory Guide (RG) 1.155, “Station Blackout,” endorsed NUMARC 87-00 industry guidance for
SBO rule
• All 104 plants met the SBO rule requirements at the
time of the staff’s review
– Safety Evaluations
– Pilot Inspections
18
Station Blackout - Implementation
• Coping Duration
– Factors affecting Offsite power design
– Factors affecting Onsite power system
• Coping Methods
– AC independent
– Alternate AC
• Procedures
–
–
–
–
Restoration of AC power
Non essential DC loads for stripping
Actions for loss of ventilation
Grid Interface
19
NRC Incident Response
•
•
•
•
•
Response Decisions
NRC Roles
Areas of Focus
Coordination, Support and Outreach
Current Status of Response
20
Emergency Planning Zones
• Two emergency planning zones (EPZ) around each
nuclear power plant
– 10 mile EPZ – plume exposure planning zone
• Response within hours
– 50 mile EPZ – ingestion exposure planning zone
• Response within days
• EPZ size established:
– Encompasses most accident sequences
• WASH 1400 Reactor Safety Study
• Conservative Assumptions
– Provides a substantial basis for expansion of response beyond
the EPZ should it be needed
21
PAR for U.S. Citizens in
Japan
• Recommendation for 50 mile evacuation
– Limited and uncertain data available
– Significant challenges to 3 units and 4 spent fuel
pools
– Potential for large offsite release existed
– Rapidly modeled aggregate cores to simulate
potential release
– Decision to expand evacuation was prudent given
the uncertain conditions
22
Questions?
23
Le ys e Co m m e n t to ACRS Me e tin g Nu m b e r 582: : P RM-50-93
Of course, nuclear power plants in the USA should operate at reduced
power levels pending the resolution of PRM-50-93.
I have told ACRS subcommittees and the full committee that 2200 is too
high and I have cited the thoroughly researched PRM-50-93. About one
year ago the NRC assigned a high priority to review of PRM-50-93 with a
deadline of September 30, 2010. Next, NRC dropped that deadline, using
the excuse that a further petition submitted by Mark Edward Leyse called
for a merger of review activities and an indefinite schedule. So, now we
have Fukushima, a slow-moving event that among other consequences led
to the production of a lot of hydrogen. The NRC and the NEI still tell
everybody that 2200 is based on sound science and many media reports
cite 2200 as the starting point for hydrogen production at Fukushima.
That events at Fukushima jolted the Commissioners and led to all kinds of
excitement at NRC including this from a press release, “The Nuclear
Regulatory Commission has voted to launch a two-pronged review of U.S.
nuclear power plant safety in the aftermath of the March 11 earthquake and
tsunami and the resulting crisis at a Japanese nuclear power plant. The
Commission supported the establishment of an agency task force, made up
of current senior managers and former NRC experts with relevant
experience. The task force will conduct both short- and long-term analysis
of the lessons that can be learned from the situation in Japan, and the
results of their work will be made public.”
This morning, April 6, 2010, I witnessed the congressional proceedings that
were induced by Fukushima with participation by NRC, NEI, UCS and ANS.
Fukushima is characterized by a relatively slow moving set of events.
Nevertheless, the NRC has placed reactions to those events as a far higher
priority than reacting to the far more significant implications of PRM-50-93.
PRM-50-93 addresses events that move fast, in addition to the slowmoving scenes at Fukushima.
Indeed, if the NRC had responded in a timely manner to the earlier PRM50-76 and then with its second chance had responded to the far more
thoroughly documented PRM-50-93, it would have tools in place for
evaluating the course of hydrogen production at Fukushima. Today, the
NRC does not have those tools.
Training tools at the NRC should be corrected by reducing the incorrect
2200 that is too high. Of course, nuclear power plants in the USA should
operate at reduced power levels pending the resolution of PRM-50-93.
Regulatory Guide 1.152, Revision 3
Steven Arndt, NRR / DE
Tim Mossman, NRR / DE / EICB
April 7, 2011
1
Purpose
• Provide an overview of digital system safety and
cyber security licensing and oversight
• Present the modifications to Regulatory Guide
1.152 regarding a Secure Development and
Operational Environment (SDOE)
• Address ACRS questions regarding
coordination between NRR, NRO and NSIR and
future work associated with regulatory guidance
development in this area
2
Desired Outcomes
• Achieve common understanding of the
NRC’s licensing and oversight for digital
system safety and cyber security
• Address all ACRS questions
• Receive ACRS recommendation to issue
Regulatory Guide 1.152, Revision 3
3
Contents
• History of digital system safety and cyber
security
• Overview of the current regulatory
structure relative to digital system safety
and cyber security
– Overview of planned activities regarding
safety and cyber security
• Modifications to Regulatory Guide 1.152
4
Timeline (1 of 2)
•
•
•
•
•
NRC Issues RG 1.152 (Nov. 1985)
NRC Issues RG 1.152, Rev 1 (Jan. 1996)
Terrorist Attacks (Sept. 2001)
NRC Issues Order EA-02-026 (Feb. 2002)
NRC Issues Order EA-03-086 (April 2003)
5
Timeline (2 of 2)
•
•
•
•
•
•
NEI Issues NEI 04-04, Rev. 1 (Nov. 2005)
NRC issues RG 1.152, Rev. 2 (Jan. 2006)
NRC issues ISG-01 (Dec. 2007)
NRC Issues 10 CFR73.54 (Mar. 2009)
NRC Issues RG 5.71 (Jan. 2010)
NRC Issues RG1.152, Rev.3 (June 2011)
6
Regulatory Overview
• NRR / NRO licensing reviews
– Digital Safety Systems
• Regional Inspection
– Digital Safety System instillation, operations
• NSIR cyber plan review
– Digital Safety, Important to Safety, Security and
Emergency Preparedness Systems
• NSIR / Regional Implementation Inspection
– Major plant upgrades or Digital Safety Systems
7
Safety and Security Framework
• RG 1.152, Revision 3 will bring NRC guidance
in line with revisions to regulation (Parts 50 and
73) and provide consistent guidance to industry
• NRC will continue to assure digital system
safety and cyber security under this framework
8
Safety Framework
• 10 CFR 50.55(a)(h) codifies IEEE Std.
603-1991
• Regulatory Guide 1.152 endorses IEEE
Std. 7-4.3.2
– IEEE Std. 7-4.3.2 – 2003 did not address
security
9
REGULATORY GUIDE 1.152,
REVISION 3 CHANGES
10
RG 1.152 Changes
• Modification to address predictable, nonmalicious challenges to digital safety
system development and operation
• Enhanced focus on Part 50/52 reliability
requirements
• Reflection of migration of cyber security
provisions to 10 CFR 73
11
Mapping of Security /
Reliability Guidance (1 of 3)
• Cyber-specific provisions for Concepts
and Requirements phases migrated to
RG 5.71, Appendix C 12.2
RG 1.152
Rev. 2
Sections 2.1 -2.2
Concept &
Requirements
RG 5.71
Security Controls
Section C 12.2
RG 1.152
Rev. 3
Sections 2.1 -2.2
Concept &
Requirements
12
Mapping of Security /
Reliability Guidance (2 of 3)
• Cyber-specific provisions for Design,
Implementation & Test phases migrated
to RG 5.71, Appendix C 12.3 – 12.5
RG 1.152
Rev. 2
Sections 2.3-2.5
Design,
Implementation &
Test
RG 5.71
Sections C12.3 12.5
RG 1.152
Rev. 3
Sections 2.3-2.5
Design,
Implementation &
Test
13
Mapping of Security /
Reliability Guidance (3 of 3)
• Post-Factory Acceptance Phases are not
used in Part 50 licensing determinations
• Guidance is more thoroughly covered
under 73.54 as elaborated in RG 5.71
RG 1.152
Rev. 2
Section 2.6-2.9
Site Acceptance
Operations
Maintenance
Retirement
RG 5.71
Section C12.6 & Cyber Security Program
Operation & Maintenance
14
RG 1.152, Revision 3
• Revision 3 is ready for release
• Since 10 CFR 73.54 and RG 5.71 have been
issued, RG 1.152 is being revised to:
– Remove references to the term “cyber-security”
– Remove direction to evaluate systems against
malicious actions or attacks under Part 50
– Remove guidance pertaining to life-cycle phases
beyond what is credited in Part 50 / 52 licensing
reviews
15
RG 1.152, Revision 3
• RG 1.152, Revision 3 is clarifying its focus on:
– Protection of the development environment from inclusion of
undocumented, unneeded, and unwanted code (Criterion III,
“Design Control,” of 10 CFR Part 50, Appendix B)
– Controls to prevent inadvertent access to systems (IEEE Std.
603-1991, Clause 5.9)
– Protection against undesirable behavior of connected system
(IEEE Std. 603-1991, Clause 5.6.3)
• To avoid confusion between Part 50 / 52 and
Part 73 “security,” Regulatory Guide 1.152,
Revision 3 adopted the use of the term “secure
development and operational environment” in its
place
16
“Secure Development Environment”
• Definition: The condition of having appropriate
physical, logical and programmatic controls during the
system development phases (i.e., concepts,
requirements, design, implementation, testing) to
ensure that unwanted, unneeded and undocumented
functionality (e.g., superfluous code) is not introduced
into digital safety systems
• Applicants should protect their development
environments such that unwanted, unneeded and
undocumented code is not included in safety systems
– These types of code increase the potential for a system to exhibit
unpredictable and undesirable behavior
17
Secure Development Guidance
• Each phase of the development process has
unique characteristics
• As part of their Concepts phase assessment,
applicants should identify opportunities where
superfluous requirements, features or code
could be introduced into the system
• The adequacy of appropriate development
phase controls adopted will be dependant on
the results of the assessment
18
Platform versus Application
• An applicant should be prepared to describe the
secure environment controls that will be applied
to both the platform software and the application
software
– It is anticipated that these two software products may
be developed at different times
– These software products could also be developed at
different locations by different personnel under
different development processes
19
“Secure Operational Environment”
• Definition: The condition of having appropriate
physical, logical and administrative controls within a
facility to ensure that the reliable operation of digital
safety systems are not degraded by undesirable
behavior of connected systems and events initiated
by inadvertent access to the system
• Applicants should provide design features and/or
protective measures to ensure that the reliability of the
digital safety system is not compromised by:
– Undesirable behavior by connected systems (per Clause 5.6.3 of
IEEE Std. 603-1991)
– Inadvertent access to the safety system (per Clause 5.9 of IEEE
Std. 603-1991)
20
Independence from Other Systems
• Undesirable behavior of connected digital systems
includes consideration of failures, as well as other offnominal behaviors, such as:
–
–
–
–
Excessive data transmission
Corrupted data transmission
“Missing” or out-of-sequence messages
Transmission of out-of-range data
• Applicants should consider these types of occurrences
for digital safety systems and have features provided to
ensure that the safety function will be unaffected
21
Access Control
• For digital systems, access controls must
consider physical, as well as logical, points of
access
– Digital systems often feature points of access (e.g.,
USB ports) in their design
– Systems residing on networks may be accessed from
other connected systems on the same network
– Applicants should provide, via plant controls enabled
by system and facility design features, reasonable
assurance that only authorized personnel will be able
to access the system
22
Example SDOE Events
• Examples of non-malicious, undesirable
behavior of connected systems impacting other
plant (non-safety) systems
– Browns Ferry, Unit 3 – August 2006 event
– Oconee, Unit 3 – November 2008 event
• Example of non-malicious, inadvertent access
event that impacted a (non-safety) digital plant
system
– Hatch, Unit 2 - March 2008 event
23
Public Comments Summary
•
•
38 comments received
Incorporated:
– Several language / editorial changes to the document that improved the
RG’s background and regulatory positions
– Clarifying scope of Part 50 versus Part 73
•
Not incorporated:
– Requests to delete secure operational environment provisions in favor
of programmatic coverage per RG 5.71 and NEI 08-09
– Requests to reference ISG-04
– Several out-of-scope requests
•
Deferred
– Requests for additional guidance pertaining to Concept phase
assessments and use of pre-developed systems
24
Future RG 1.152 Activities
• IEEE 7-4.3.2 – 2010
– IEEE 7-4.3.2-2010 was very recently issued by
IEEE and will be evaluated for NRC endorsement
– RG 1.152 will be updated, as applicable
• Both staff and industry (per public comments
received) would like to see more guidance
published regarding:
– Format and content of Concept phase assessments
& Failure analysis
– Treatment of pre-developed systems
25
Cyber Security Framework
• 10 CFR 73.54 / Regulatory Guide 5.71
published
– Performance-Based, Program focused
– FOCUS: Prevention of Radiological Sabotage
– Consistent with regulatory approach for physical
security
• Security is a process not a state
26
RG 5.71 Security Controls
• 148 Cyber Security Controls safeguard against
currently known vulnerabilities that an adversary
can use to compromise a system or equipment
– Technical Security Controls
• Example: B.4.2 User Identification and Authentication - A username
and password
– Operational & Management Security Controls
• Example: C.11.4 Configuration Change Control - Authorizing and
documenting changes to CDAs
27
Cyber Security Features
• Digital safety systems may include features that serve
a cyber security purpose
•
Cyber security features included in a Digital Safety System
should have been developed under safety-quality processes
• Those features should be described in a Part 50 / 52
application such that:
– NRC staff will evaluate whether the cyber feature will degrade
reliable system function
• The cyber function adequacy will be addressed under
Part 73
28
NRR / NRO / NSIR Coordination
• Inter-Office Instruction is being developed
– NRR / NRO / NSIR / Regional Office activities
• New Reactor Licensing
• Digital Safety System Licensing
• Cyber Security Oversight & Inspections
– Information from Digital Safety System
reviews can inform cyber inspections
• Schedules, timing, scope
• Inspection procedures
29
Future Regulatory Activities
• 10 CFR 50.55(a)(h) rulemaking in process to
codify IEEE Std. 603-2009
• RG 1.152, Revision 4 to address IEEE Std. 74.3.2-2010 and other needed guidance
• SRP Chapter 7 update
• RG 5.71 & SRP Chapter 13 updates
– NRC Endorsement of NEI 08-09
• Development of Cyber Security Inspection
Program
30
Summary
• Provided an overview of digital system safety
and cyber security licensing and oversight
• Presented the modifications to Regulatory
Guide 1.152 regarding a Secure Development
and Operational Environment (SDOE)
• Addressed ACRS questions regarding
coordination between NRR, NRO and NSIR and
future work associated with regulatory guidance
development in this area
31