ML18233A206
| ML18233A206 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 08/22/2018 |
| From: | Manoharan A, Austin Young Tennessee Valley Authority |
| To: | Advisory Committee on Reactor Safeguards |
| Sutton M | |
| References | |
| Download: ML18233A206 (30) | |
Text
Clinch River Early Site Permit Part 2,SSAR Section 13.3, Part 5, & Part 6 Advisory Committee on Reactor Safeguards Committee Meeting Presented by Archie Manoharan, Licensing Alex Young, Engineering August 22, 2018
Acknowledgment: "This material is based upon work supported by the Department of Energy under Award Number DE-NE0008336."
Disclaimer: "This presentation was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof."
Acknowledgement and Disclaimer l 2 Advisory Committee on Reactor Safeguards
TVAs Mission Energy Economic Development Environment Serving the people of the Tennessee Valley to make life better.
Partner with 154 local power companies, to serve more than 9 million customers in parts of seven states. Directly serve 54 large industries and federal installations.
l 3 Advisory Committee on Reactor Safeguards
TVAs Nuclear Fleet Advisory Committee on Reactor Safeguards l 4 Browns Ferry Sequoyah Watts Bar Clinch River
NRC Issues ESP Environmental Review Hearing(s)
Safety Review Notice of Hearing, Opportunity 4/4 4 Contentions Filed 6/12 Audits & RAIs Comment Period DEIS 4/26 FEIS Scoping Meeting 5/15 PSER 8/4 ACRS Subcomm. Meetings FSER SER w/ no OIs 10/20 ASLB Hearing Audits & RAIs Notice of Intent 4/13 2 Contentions Admitted 10/10 2017 2018 2019 2020 ESPA Accepted 12-30-16 ESPA Rev. 1 Submitted 12-15-17 ESPA Rev. 2 Planned Submittal Dec 18 5/15 8/22 FEIS FSER NRC Review of ESPA Commission Ruling 5/3 ASLB Ruling 7/31 TVA Appeals 11/6 Full ACRS Contested Hearing Terminated Full ACRS 3/26 Advisory Committee on Reactor Safeguards l 5
ESPA - Emergency Preparedness Development l 6 Advisory Committee on Reactor Safeguards The ESPA considered information from four light water small modular reactor (SMR) designs:
NuScale (160 megawatts thermal (MWt), 50 megawatts electrical (MWe))
SMR-160 Holtec (525 MWt, 160 MWe)
mPower (530 MWt, 180 MWe)
Westinghouse (800 MWt, 225 MWe)
Combined nuclear generating capacity for the Clinch River Site not to exceed 2420 MWt (800 MWe)
Need for Scalable Emergency Planning Zone (EPZ):
NUREG-0396 introduced the concept of a 10-mile EPZ 40 years ago
NUREG-0396 considered large light water reactors (LWRs)
Based on SMR design information:
TVA developed a dose-based, consequence-oriented approach to determine an appropriate EPZ size for a SMR
approach has the same dose criteria as NUREG-0396
takes into consideration SMR design and safety advancements
Two emergency plans were proposed and developed
all four designs are expected to be able to meet the dose criteria for 2-mile EPZ
at least one design is expected to be able to meet the does criteria for Site Boundary EPZ
Exemption requests that allow for review of major features of emergency plans other than 10-mile EPZ
Presentation Outline Advisory Committee on Reactor Safeguards l 7 Part 2, Site Safety Analysis Report (SSAR), Section 13.3, Emergency Preparedness:
13.3.1 Physical Characteristics 13.3.2 Emergency Plan (Refers to Part 5 of the ESPA) 13.3.3 Emergency Planning Zones 13.3.4 Evacuation Time Estimates (Supports Part 5B) 13.3.5 Contacts and Agreements Part 5, Emergency Plan:
Part 5A Emergency Plan Site Boundary EPZ Part 5B Emergency Plan 2-Mile EPZ Part 6, Exemptions and Departures Exemption Requests for a Plume Exposure Pathway (PEP) EPZ at Site Boundary Exemption Requests for an approximate 2-mile PEP EPZ
Key NRC Interactions Related to Emergency Preparedness Advisory Committee on Reactor Safeguards l 8 Two audits were conducted to review the emergency preparedness information in the ESPA First audit - November 2017 through February 2018 Example analysis completed by TVA to demonstrate feasibility that dose criteria can be met at Clinch River Site Boundary (RAI-8885)
Second audit - April 2018 EPZ Plant Parameter Approach (RAI-9206)
Requests for Additional Information (RAIs)
RAI-8885 - demonstrate that dose criteria can be met at Site Boundary EPZ RAI-9206 - discuss how EPZ methodology was implemented in the example analysis and the EPZ plant parameter approach developed
Advisory Committee on Reactor Safeguards l 9 Part 2, SSAR, Chapter 13 - Section 13.3 Emergency Preparedness
Site Description DOE Oak Ridge Reservation borders the North-East sides 6.8 miles East of Kingston, TN 8.8 miles Northwest of Lenoir City, TN 9.2 miles East-Southeast of Harriman, TN (not shown) 25.6 miles West-Southwest of Knoxville, TN (not shown)
Advisory Committee on Reactor Safeguards l 10 Section 13.3.1 - Physical Characteristics Area Population U.S. Census 2010 data projected to 2015 856 permanent residents within 2-mile PEP EPZ 186,500 permanent residents within 15 miles
Advisory Committee on Reactor Safeguards l 11 The methodology uses a dose-based, consequence-oriented approach for determining the appropriate size of the PEP EPZ consistent with the NUREG-0396 approach with a dose criteria of the Environmental Protection Agency (EPA) early phase Protective Action Guides (PAGs).
The methodology is consistent with the NUREG-0396 approach:
a spectrum of accidents are addressed Dose criteria is the same PEP EPZ boundary ensures protection from dose levels above 1 rem total effective dose equivalent (TEDE) limit established in the EPA PAG Four light water SMR designs were considered which significantly differ from the large LWRs:
smaller cores lower source terms reduced accident consequences reduced likelihood of accidents slower accident progression allows more time for mitigating actions Section 13.3.3 - Emergency Planning Zones
Advisory Committee on Reactor Safeguards l 12 Section 13.3.3 - Emergency Planning Zones Consistent with the NUREG-0396 sizing rationale, the technical criteria for determining the PEP EPZ size:
A. Encompass those areas in which projected dose from design basis accidents (DBAs) could exceed the EPA early phase PAGs.
B. Encompass those areas in which consequences of less severe core melt accidents could exceed the EPA early phase PAGs.
C. Be of sufficient size to provide for substantial reduction in early severe health effects in the event of more severe core melt accidents.
Technical criteria for determining the PEP EPZ size uses the existing emergency preparedness regulatory framework and dose saving criteria established in NUREG-0396
Advisory Committee on Reactor Safeguards l 13 Section 13.3.3 - Emergency Planning Zones Areas outside the PEP EPZ would meet the EPA early phase PAG dose limit of less than 1 rem TEDE.
The methodology for verifying dose consequences beyond the PEP EPZ do not exceed the EPA early phase PAG levels includes:
Step 1 - Selecting appropriate accident scenarios (accident scenarios with mean core damage frequency (CDF) greater than 1E-6 per reactor-year (rx-yr))
Step 2 - Determining source terms for selected accident scenarios
Step 3 - Calculating the dose consequences for selected accident scenarios
Step 4 - Comparing the dose consequences for selected accident scenarios with the EPA early phase PAG Criteria A and B: PEP EPZ encompasses those areas in which the plume exposure doses from DBAs and less severe core melt accidents could exceed the EPA early phase PAG
Advisory Committee on Reactor Safeguards l 14 Section 13.3.3 - Emergency Planning Zones Methodology for verifying that areas outside the PEP EPZ meet the limits for substantial reduction in early health effects:
Step 1 - Selecting appropriate accident scenarios (accident scenarios with mean CDF greater than 1E-7 per rx-yr)
Step 2 - Determine source terms for selected accident scenarios
Step 3 - Calculate the dose consequences for selected accident scenarios at the PEP EPZ boundary
Step 4 - Calculate the distance at which the conditional probability to exceed 200 rem (whole body) exceeds 1E-3 per rx-yr
Step 5 - Compare that distance with the PEP EPZ Criteria C: PEP EPZ be of sufficient size to provide for substantial reduction in early severe health effects in the event of more severe core melt accidents
Design Specific Example Analysis - Site Boundary PEP EPZ Evaluates NuScale Power Plant at the Clinch River Site Implements the dose-based methodology described in SSAR Section 13.3 Demonstrates that Site Boundary EPZ is possible Doses at Site Boundary are much less than the EPA early phase PAG Advisory Committee on Reactor Safeguards l 15 Criteria Site Boundary Dose TEDE (rem)
EPA Early Phase PAG Limit TEDE (rem)
A: Design Basis Accidents 0.104 1
B: Less Severe Core Melt Accidents 0.158 1
C: Reduction in Early Severe Health Effects No accident scenarios with mean CDF greater than 1E-7 per rx-yr.
EPZ Plant Parameter Approach Advisory Committee on Reactor Safeguards l 16
Section 13.3.5 - Contacts and Agreements Advisory Committee on Reactor Safeguards l 17 Letters of Support Letters of support from the State of Tennessee, Anderson County, Roane County, and the City of Oak Ridge were submitted in support of the ESPA.
10 CFR 52.17(b)(4) requires that the applicant make good-faith efforts to obtain certifications from local, State, and Federal governmental agencies with EP responsibilities.
Letters of Agreements and Certification Letters Certification letters and letters of agreements will be pursued during the combined license application (COLA) process.
TVA will maintain agreements with surrounding emergency response organizations.
TVA would continue to work with State and local support organizations to establish an emergency preparedness at Clinch River commensurate with the potential consequences to public health and safety
Advisory Committee on Reactor Safeguards l 18 Part 5 - Emergency Plan
Part 5 - Emergency Plan l 19 Part 5 of the ESPA contains the major features of two distinct Emergency Plans for Clinch River Site in accordance with 10 CFR 52.17(b)(2)(i).
Part 5A Describes major features of an Emergency Plan for a PEP EPZ consisting of the area encompassed by the Site Boundary.
Part 5B Describes major features of an Emergency Plan for a PEP EPZ consisting of an area approximately two miles in radius surrounding the Clinch River Site.
Both plans address the 16 planning standards in NUREG-0654,Section II, which reflects the requirements in 10 CFR 50.47(b)(1) through 10 CFR 50.47(b)(16) and Appendix E to 10 CFR Part 50 considering the requested exemptions described in Part 6 of the ESPA Advisory Committee on Reactor Safeguards
Part 5A - Emergency Plan (Site Boundary EPZ)
Advisory Committee on Reactor Safeguards l 20 TVA Generic Emergency Plan as modified for Clinch River Site and an appendix with Site-Specific information Actions necessary to safeguard onsite personnel (within the site boundary) and minimize damage to property Information to ensure the compatibility of the proposed emergency plans (for onsite areas) with facility design features, site layout, and site location
Part 5B - Emergency Plan (2-Mile EPZ)
Advisory Committee on Reactor Safeguards l 21 TVA Generic Emergency Plan as modified for Clinch River Site and a Site-specific appendix Information to ensure the compatibility of the proposed emergency plans (for both onsite areas and the PEP EPZ) with facility design features, site layout, and site location.
Site Evacuation Time Estimate Report
Advisory Committee on Reactor Safeguards l 22 Part 5B - Evacuation Time Estimate Analysis of evacuation times is one method to identify any significant impediments to the development of emergency plans at the Site Provides TVA, State and local governments with site-specific information needed for protective action decision making Evacuation Time Estimates (ETE) analyses for Clinch River Site were completed in accordance with the guidance provided in NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies These analyses did not identify any physical characteristics unique to the Clinch River Site that could pose a significant impediment to the development of emergency plans
Advisory Committee on Reactor Safeguards l 23 Part 6 - Exemptions and Departures
Part 6 - Exemptions and Departures Advisory Committee on Reactor Safeguards l 24 Pursuant to 10 CFR 52.7, Specific Exemptions, which is governed by 10 CFR 50.12, Specific Exemptions, TVA requested exemptions from the following emergency preparedness requirements for the Clinch River Site:
Certain standards in 10 CFR 50.47(b) regarding onsite and offsite emergency response plans for nuclear power reactors
Certain requirements of 10 CFR 50.33(g) and 10 CFR 50.47(c)(2) to establish PEP EPZ for nuclear power plants
Certain requirements of 10 CFR Part 50, Appendix E, which establish the elements that make up the content of emergency plans Two Sets of Exemptions Based on the dose-based EPZ methodology described in Section 13.3 and taking light water SMR designs into consideration, two sets of exemptions were developed:
Exemptions for a PEP EPZ established at the Site Boundary (Part 5A)
Exemptions for an approximate 2-mile PEP EPZ (Part 5B)
Part 6 - Exemptions and Departures Advisory Committee on Reactor Safeguards l 25 Requested exemptions - Table 1-1 Exemptions Requested from 10 CFR 50.33(g),
50.47(b), and 50.47 (c)(2) for the Site Boundary PEP EPZ Emergency Plan Regulation Requirement Exemption Request 10 CFR 50.33(g) 10 CFR 50.47(c)(2) 10 mile PEP EPZ distance Deviate from 10 mile PEP EPZ 10 CFR 50.47(b), b(4),
b(5), b(6), b(9), b(10)
Various elements of a formal offsite emergency plan Deviate from formal offsite radiological emergency plan requirements on the basis that there are no offsite radiological consequences from any credible event in excess of the criteria described in Section 13.3.
Note: TVAs emergency plan will describe the capabilities to determine if a radiological release is occurring and promptly communicate that information to the offsite response organizations for their consideration.
Part 6 - Exemptions and Departures Advisory Committee on Reactor Safeguards l 26 Requested Exemptions - Table 1-2 Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary PEP EPZ Emergency Plan Regulation Requirement Exemption Request 10 CFR 50, Appendix E, Section IV.2 - IV.7 Evacuation time estimates (ETEs)
Deviate from ETE requirements as no offsite consequences from any credible event in excess of the criteria provided in Section 13.3, formal offsite radiological emergency response plans with preplanned evacuation details are not necessary.
Therefore, there is no need for ETEs.
10 CFR 50, Appendix E, Section IV.D.1, D.3, D. 4 Certain elements of offsite notifications Deviate from certain offsite notification requirements as members of public would not be within the Site Boundary PEP EPZ. (Note: TVA is not seeking an exemption from the requirement to notify responsible State and local government agencies within 15 minutes after declaring an emergency.)
10 CFR 50, Appendix E, Section IV.F.2, F.2.a, F. 2.a.(i) - 2.a.(iii),
F.2.b, F.2.c, F.2.d Certain elements of offsite exercises Deviate from certain offsite exercise requirements as no formal offsite radiological emergency response plans would be needed as no offsite consequences from any credible event in excess of the criteria provided in Section 13.3. (Note: TVA would continue to invite State and local support organizations to participate in the periodic drills and exercises conducted.)
Part 6 - Exemptions and Departures Advisory Committee on Reactor Safeguards l 27 Requested Exemptions - Table 1-3 Exemptions Requested from 10 CFR 50.33(g) and 50.47(c)(2) for the 2-Mile PEP EPZ Emergency Plan Regulation Requirement Exemption Request 10 CFR 50.33(g) 10 CFR 50.47(c)(2) 10 mile PEP EPZ distance Deviate from 10 mile PEP EPZ
Part 6 - Exemptions and Departures Advisory Committee on Reactor Safeguards l 28 Special Circumstances Exist - Underlying Purpose of the Regulations Being Met Exemptions are Authorized by Law Exemptions Will not Present Undue Risk to Public Health And Safety Exemptions Are Consistent with the Common Defense and Security Technical Justification The criteria established in the methodology described in Section 13.3, provides for adequate protection of public health and safety by providing a EPZ that encompasses the areas in which the plume exposure doses could exceed the EPA early phase PAG, and for where there is a substantial reduction in risk of significant early health effects.
Advisory Committee on Reactor Safeguards l 29 Summary ESPA COLA PEP EPZ Methodology (Part 2, SSAR, Section 13.3)
Approval of the dose-based, consequence oriented methodology for determining the PEP EPZ size Approval of design specific implementation of the methodology approved in the ESPA EPZ Size (Part 6)
Approval to deviate from the current 10-mile PEP EPZ requirements based on the methodology to determine PEP EPZ size Approval of design specific PEP EPZ size based on design specific implementation of the methodology Emergency Plan (Part 5)
Approval of the major features of the Site Boundary and 2-mile emergency plans presented in Part 5 Approval of the remaining elements of either the Site Boundary or 2-mile emergency plans OR a new plan based on design specific PEP EPZ size using methodology