ML18254A312
| ML18254A312 | |
| Person / Time | |
|---|---|
| Issue date: | 08/22/2018 |
| From: | Quynh Nguyen Advisory Committee on Reactor Safeguards |
| To: | |
| Nguyen Q | |
| References | |
| NRC-3860 | |
| Download: ML18254A312 (184) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
ACRS Regulatory Policies and Practices Subcommittee Docket Number:
N/A Location:
Rockville, Maryland Date:
August 22, 2018 Work Order No.:
NRC-3860 Pages 1-184 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 REGULATORY POLICIES AND PRACTICES SUBCOMMITTEE 7
+ + + + +
8 WEDNESDAY 9
AUGUST 22, 2018 10
+ + + + +
11 ROCKVILLE, MARYLAND 12
+ + + + +
13 The Subcommittee met at the Nuclear 14 Regulatory Commission, Two White Flint North, Room 15 T2B1, 11545 Rockville Pike, at 1:00 p.m., Walter L.
16 Kirchner, Chairman, presiding.
17 COMMITTEE MEMBERS:
18 WALTER L. KIRCHNER, Chairman 19 RONALD G. BALLINGER, Member 20 DENNIS C. BLEY, Member 21 MICHAEL L. CORRADINI, Member 22 JOSE A. MARCH-LEUBA, Member 23 JOY L. REMPE, Member 24 MATTHEW W. SUNSERI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 DESIGNATED FEDERAL OFFICIAL:
1 QUYNH NGUYEN 2
ALSO PRESENT:
3 ANNA BRADFORD, NRO 4
MICHELLE HART, NRO 5
ARCHIE MANOHARAN, TVA 6
BRUCE MUSICO, NSIR 7
RAYMOND SCHIELE, TVA 8
DANIEL STOUT, TVA 9
MALLECIA SUTTON, NRO 10 KENNETH THOMAS, NSIR 11 SCOTT WEBBER, NuScale 12 ALEX YOUNG, TVA 13
- Present via telephone 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 TABLE OF CONTENTS 1
Page 2
Opening Remarks 3
Walter Kirchner..............
4 4
Introductions and Overview 5
Anna Bradford...............
7 6
Chapter 13, Section 13.3:
7 Emergency Planning 8
Daniel Stout, Raymond Schiele, 9
Archie Manoharan, and Alex Young 9
10 Safety Evaluation Chapter 13, 11 Section 13.3: Emergency Planning 12 Mallecia Sutton, Bruce Musico, 13 and Michelle Hart............. 67 14 Public Comment 15 Walter Kirchner.............
124 16 Committee Discussion 17 Walter Kirchner.............
124 18 Adjourn 19 Walter Kirchner.............
125 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 P R O C E E D I N G S 1
(12:59 p.m.)
2 CHAIRMAN KIRCHNER: The meeting will now 3
come to order.
4 This is a meeting of the Regulatory 5
Policies and Practices Subcommittee of the Advisory 6
Committee on Reactor Safeguards.
7 I am Walt Kirchner, the Chairman of this 8
subcommittee meeting. ACRS members in the room are 9
Ron Ballinger, Dennis Bley, Matt Sunseri, Joy Rempe, 10 and Jose March-Leuba. Quynh Nguyen, who is of the 11 ACRS staff, is the designated federal official for 12 this hearing.
13 The subcommittee will hear from 14 representatives of TVA and the staff regarding a 15 Section 13.3, Emergency Planning, of TVA's Clinch 16 River early site permit application and the 17 corresponding safety evaluation.
18 The subcommittee will gather information, 19 analyze relevant issues and facts, and formulate 20 proposed positions and actions, as appropriate for 21 full deliberation by the full committee.
22 The ACRS was established by statute and is 23 governed by the Federal Advisory Committee Act. This 24 means that the committee can only speak through its 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 published letter reports. We hold meetings to gather 1
information to support our deliberations.
2 Interested parties who wish to provide 3
comments can contact our offices requesting time after 4
the meeting announcement is published in the Federal 5
Register. That said, we also set aside some time for 6
spur of the moment comments from members of the public 7
attending or listening to our meetings. Written 8
comments are also welcome.
9 In regard to early site permits, 10 CFR 10 52.23 provides that the Commission shall refer a copy 11 of the application to the ACRS and the committee shall 12 report on those portions which concern safety.
13 The ACRS section of the U.S. NRC public 14 website provides our charter, bylaws, letter reports, 15 and full transcripts of all full and subcommittee 16 meetings, including slides presented at the meetings.
17 The rules for participation in today's 18 meeting were previously announced in the Federal 19 Register. We have received no written comments or 20 requests for time to make oral statements from members 21 of the public regarding today's meeting. Is that 22 still true? Yes, okay.
23 We have a bridge line established -- you 24 can hear the static -- for interested members of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 public to listen in. To preclude interruption of the 1
meeting, the phone bridge will be placed in a listen-2 in mode during the presentations and maybe 3
discussions. We will unmute the bridge line at a 4
designated time to afford the public an opportunity to 5
make a statement or provide comments.
6 At this time, I request that meeting 7
attendees and participants silence their cell phones 8
and any other electronic devices that are audible.
9 A transcript of the meeting is being kept 10 and will be made available as stated in the Federal 11 Register notice. Therefore, we request that 12 participants in this meeting use the microphones 13 located throughout the meeting room when addressing 14 the subcommittee. The participants should first 15 identify themselves and speak with sufficient clarity 16 and volume so that they may be readily heard. Make 17 sure the little green light of the microphone is on 18 before speaking and off when not in use.
19 Before we proceed with the meeting, we 20 have been joined by our chairman, Mike Corradini.
21 Do we have Pete on the line?
22 MEMBER CORRADINI: He was. I do not think 23 he is.
24 CHAIRMAN KIRCHNER: Okay. So at this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 point, I think I can turn to Anna Bradford, who is the 1
Deputy Director over in NRO.
2 MS. BRADFORD: Thank you. Again, my name 3
is Anna Bradford. I am the Deputy Director of the 4
Division of Licensing, Siting, and Environmental 5
Analysis in the Office of New Reactors.
6 This morning, you heard from the staff on 7
a proposed rule for emergency planning for small 8
modular reactors and other new technologies. In the 9
SRM for SECY-15-0077, the Commission directed the 10 staff to use its existing exemption processes with 11 changes to emergency planning zone sizes, where 12 requested by an applicant prior to the rule being 13 completed.
14 This afternoon, we will discuss an 15 exemption request from the TVA Clinch River Nuclear 16 Site that was reviewed against the current regulations 17 and guidance.
18 The TVA early site permit application 19 includes a proposed methodology that, if approved, 20 could be used by a future combined license applicant 21 to establish a plume exposure pathway emergency 22 planning zone at the site boundary or a plume exposure 23 pathway emergency planning zone with a two-mile radius 24 if certain conditions are met. If these exemptions 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 are approved as part of the ESP, they will be 1
accompanied by permit conditions specifying the 2
circumstances under which they can be used by the 3
combined license applicant.
4 As you will hear, the NRC staff evaluated 5
TVA's proposed methodology for determining a plume 6
exposure pathway emergency planning zone, the proposed 7
major feature's emergency plans, and the associated 8
exemption request to determine whether they would be 9
protective of public health and safety.
10 It is important to note that the plume 11 exposure pathway emergency planning zone size itself 12 for the site will not be finalized in the early site 13 permit, if approved. The appropriate plume exposure 14 pathway emergency planning zone size for the site will 15 not be determined until a combined license application 16 that references a specific small modular reactor 17 design is submitted and reviewed for the Clinch River 18 Nuclear Site.
19 Separately, other subcommittee meetings on 20 the other chapters of the safety evaluation report for 21 the early site permit application are currently 22 planned for October 2018 and our goal is to have the 23 ACRS full committee in November or December of 2018.
24 I will now turn the presentation over to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 TVA. Thank you.
1 MR. STOUT: Thank you, Anna.
2 So on behalf of TVA, I want to thank you 3
for the opportunity to come and present. I'm Dan 4
Stout, Senior Manager, Small Modular Reactors for TVA.
5 I've been working in the nuclear business for about 33 6
years at TVA, managing SMRs for about six years.
7 I also have Archie Manoharan and Alex 8
- Young, who are going to cover part of the 9
presentation. Ray Schiele, to my left here, is our 10 Licensing Manager. And we have a number of TVA 11 employees and contractors able to support.
12 I do want to make the point that 13 protecting public health and safety is our highest 14 priority and we take our responsibility with respect 15 to emergency preparedness very seriously.
16 Here on slide 2 I want to acknowledge the 17 Department of Energy is a partner in the work that we 18 do. They not only support us in terms of programs and 19 resources, but they have been reimbursing roughly 50 20 percent of our costs in the work that we're doing.
21 Nevertheless, the views that are expressed are TVA's 22 alone.
23 Slide 3: The work that TVA is doing on 24 small modular reactors and on emergency preparedness 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 is consistent with TVA's mission to make life better 1
for the people in the Tennessee Valley by providing 2
safe, clean, affordable, and reliable electricity.
3 Nuclear energy, in general, is important to our 4
environmental stewardship and economic development 5
missions.
6 TVA provides electricity to 154 local 7
power companies who serve the 900 -- I'm sorry -- nine 8
million customers of the Tennessee Valley throughout 9
about seven states. We also directly serve 54 10 industrial customers and that includes the Department 11 of Energy.
12 Slide 4: TVA's nuclear fleet generates 13 roughly 40 percent of our electricity. We have seven 14 nuclear units at three sites: Browns Ferry, a three-15 unit plant in Alabama; Sequoyah and Watts Bar, both 16 two-unit plants in Tennessee.
17 The blue star in this figure is located on 18 the Watts Bar Reservoir and the nearest large city is 19 Knoxville. It is actually within the city limits of 20 Oak Ridge in Roan County, Tennessee.
21 On slide 5 I have a high-level overview of 22 the NRC review schedule. I wanted to provide this to 23 give you the frame of reference of where we are. We 24 submitted the application in May of 2016. It was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 accepted at the end of 2016 and in March 2017, the NRC 1
issued its review schedule. One of those milestones 2
is the ACRS review March 26, 2019.
3 We have completed one subcommittee 4
meeting. This is the second. We anticipate one or 5
two more and then hoping that the full committee 6
meeting is in advance of that milestone date.
7 The second line down shows environmental 8
review. The NRC's published schedule calls for the 9
final EIS in June of 2019. The NRC did issue the 10 draft environmental impact statement about five weeks 11 early. We're hoping that that trend continues there 12 as well.
13 Moving down to the last row is the 14 hearings. And a point of note on July 31st, the 15 Atomic Safety and Licensing Board dismissed the last 16 contention, denied two others that were proposed, and 17 terminated the contested hearing.
18 Slide 6.
19 MEMBER CORRADINI: So the hearings are 20 concluded?
21 MR. STOUT: The ASLB has terminated the 22 contested hearing. There will be a mandatory hearing 23 after the NRC concludes the final safety evaluation 24 report.
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12 MEMBER CORRADINI: Okay, thank you.
1 MR. STOUT: So now I turn to the 2
development of the early sit permit application and 3
emergency preparedness content, in particular.
4 TVA used a plant parameter envelope in 5
formulating the early site permit application, 6
consistent with 10 CFR Part 52 and it's based on the 7
design information that was supplied to us from the 8
four light water small modular reactor designs under 9
development at that time. Those include NuScale, 10 Holtec, mPower, and Westinghouse.
11 Now TVA has not selected a design for the 12 Clinch River Site yet. That is something that is 13 necessary for future licensing action in the COLA.
14 These new designs do include significant advances in 15 safety, such as smaller source terms from postulated 16 accidents, slower accident progression, and more 17 reliance on passive safety features. With this in 18 mind, TVA developed a dose-based consequence-oriented 19 approach to determine the EPZ size, which considers 20 the unique design and safety features of the SMRs.
21 NUREG-0396, which introduced the concept 22 of emergency planning zones is about 40 years old.
23 TVA's approach to determining the EPZ size uses the 24 same dose criteria as the NUREG. The approach that we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 have proposed does not ask for a change or an 1
exemption from this dose criteria. The dose criteria 2
is based on the EPA protective action guidelines: one 3
rem.
4 TVA's approach is also consistent with 5
SECY-15-0077, where the staff proposed a consequence-6 based approach. TVA analyzes a spectrum of accidents, 7
both design basis and beyond design basis, and 8
considers defense-in-depth to ensure public health and 9
safety protection at the EPZ boundary.
10 We're applying more precise analysis to 11 ensure that public dose is below the dose limits at 12 the EPZ boundary. The establishment of a site 13 boundary or two-mile zone remains the same basis for 14 level of protection as an existing ten-mile zone 15 provides for operating plants.
16 So as TVA evaluated the design information 17 from the four SMR designs, we concluded that it was 18 likely that all four would be able to meet the dose 19 criteria at a two-mile radius and at least one would 20 be able to meet site boundary, which is roughly 1,100 21 feet.
22 So TVA developed two distinct major 23 features emergency plans and included them in the 24 early site permit application and sought NRC's review 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 and approval of both. There remains this additional 1
licensing step at COLA phase, where a specific design 2
must be selected and analyzed. In that potential 3
future licensing step, TVA could include one of these 4
two major features emergency plans if the detailed 5
analysis confirms their applicability that the public 6
dose is below the dose limits.
7 MEMBER CORRADINI: So if I might just 8
clarify, you used information from the four candidates 9
to help define the two miles, or you had defined the 10 two miles and you did some sample calculations, or are 11 we going to get into that?
12 MR. STOUT: It's more the former. We 13 looked at the information that we got, made a 14 determination that two miles ought to be sufficient.
15 MEMBER CORRADINI: Okay.
16 MR. STOUT: Two miles is essentially a 17 surrogate for scalable. That's kind of how we viewed 18 it. We think that so by having approval of it, let's 19 suppose in the COLA phase we end up determining, 20 through analysis, that we reach the PAG at one mile.
21 Well, we can't use site boundary. We have to use two-22 mile. So that's how it would work.
23 Last --
24 MEMBER BLEY: And that's all based on a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 single module.
1 MR. STOUT: No, we considered both design 2
basis and beyond design basis. Multi-module would be 3
in the design basis phase.
4 MEMBER BLEY: Okay and you still come up 5
-- okay.
6 MEMBER CORRADINI: Well I guess that leads 7
me to the non-bulleted sub thing, which is combined 8
nuclear generating capacity for Clinch River Site is 9
not to exceed 800 megawatts or 24 --
10 So you took combinations that would look 11 as large of a thermal output and an associated source 12 term as that limit? That's I think where --
13 MR. STOUT: So we have a number of 14 detailed slides and we're going to walk through the 15 methodology --
16 MEMBER CORRADINI: Okay.
17 MR. STOUT: -- and we'll provide an 18 example calculation for information.
19 MEMBER CORRADINI: Okay, thank you.
20 MR. STOUT: All right. So with that, 21 consider this as all background. Now, let's jump into 22 the details of TVA's emergency preparedness content in 23 the ESPA. And I'm going to turn it over to Archie.
24 MS. MANOHARAN: Thank you, Dan.
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16 Good afternoon. My name is Archie 1
Manoharan. I have been part of the licensing team at 2
TVA's Clinch River as the mod project for over a year.
3 Prior to that, I've been in licensing for over ten 4
years. And thank you for having us and giving us this 5
opportunity to present today.
6 As Dan said, we would like to present 7
details of the emergency preparedness information in 8
the application in the early sit permit 9
application. I would first like to begin with an 10 outline of the presentation we have for you today.
11 To fully understand the emergency 12 preparedness approach for a small modular reactor at 13 the Clinch River Site, information in three parts of 14 the application needs to be considered. Today we are 15 going to discuss and present information from Part 2, 16 the Site Safety Analysis Report, and Part 5, Emergency 17 Plan, Part 6, Exemptions and Departures.
18 Specifically in Part 2, in Section 13.3, 19 Emergency Preparedness Information and Section 13.3.3, 20 which discusses the dose-based consequence of 21 methodology that Dan had alluded to in the slide 22 before.
23 This methodology and the small modular 24 reactor design features are the basis for the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 emergency preparedness approach that we are proposing 1
in the application. Based on this methodology, two 2
distinct emergency plans have been put together in 3
Part 5. In Part 5A, major features of an emergency 4
plan that would support a site boundary EPZ are 5
discussed. In Part 5B, major features of an emergency 6
plan for a two-mile EPZ are discussed.
7 As Dan already mentioned, an SMR design 8
for the Clinch River Site has not been selected yet.
9 So in Part 2, we are seeking review and approval of 10 the methodology and in Part 5, we are seeking review 11 and approval by the staff of the major features of 12 these emergency plans.
13 In a future COLA, once the reactor design 14
-- once a small modular reactor design has been 15
- selected, the dose-based methodology will be 16 implemented to show that the dose criteria is either 17 met at site boundary or two-mile. If it's met at site 18 boundary, then the Part 5A emergency plan, major 19 features emergency plan, will be utilized to create a 20 complete and integrated emergency plan and COLA. If 21 the dose criteria is met at two-mile EPZ, then the 22 Part 5B major features emergency plan will be utilized 23 to create a complete and integrated emergency plan in 24 COLA.
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18 To support the information in Part 5, a 1
set of exemption requests have been described and 2
submitted in Part 6 of the ESPA. We will go over 3
these in detail in the next slides. But just to avoid 4
any potential confusion, unless stated otherwise, the 5
terms emergency planning zone, EPZ, refers to plume 6
exposure pathway emergency planning zone. We will try 7
our best to use the entire term but when we say EPZ, 8
we are referring to plume exposure pathway.
9 Next slide, please.
10 MEMBER SUNSERI: Archie, could I ask you 11 to move your microphone a little closer?
12 MEMBER CORRADINI: Yes, can you repeat 13 what you just said at the end? I didn't catch it.
14 MS. MANOHARAN: Oh.
15 MEMBER CORRADINI: And closer still for 16 your mike.
17 CHAIRMAN KIRCHNER: Thank you.
18 MS. MANOHARAN: To avoid any potential 19 confusion, we are going to -- the terms emergency 20 planning zone or EPZ, when we use those terms, we are 21 referring to plume exposure pathway emergency planning 22 zone.
23 MEMBER BLEY: Not ingestion.
24 MS. MANOHARAN: Not ingestion and my next 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 slide explains why.
1 MEMBER BLEY: Okay.
2 MS. MANOHARAN: So in the course of the 3
staff's review of the emergency preparedness 4
information in our application, several requests for 5
additional information were issued. You see a few 6
listed here. In addition to the two that are listed, 7
RAI-9227 was also issued earlier this year, which is 8
not listed on this slide. But as a response to that 9
additional RAI, we withdrew our request for ingestion 10 exposure pathway exemption requests. And, therefore, 11 EPZ refers to plume exposure pathway.
12 Two audits were held to review the dose-13 based methodology described in Section 13.3 and also 14 focused on reviewing the example analysis that was 15 conducted by TVA to show that the dose criteria can be 16 met at Clinch River Site boundary. Alex Young is 17 going to walk through the example analysis in a few 18 slides.
19 Starting with our information in Part 2, 20 Section 13.3.1, Physical Characteristics, this section 21 describes information concerning site description and 22 area population. As the figure here illustrates the 23 site vicinity, you can see the Clinch River Site in 24 the central of the figure there north of Interstate I-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20
- 40. The Interstate I-40 is located about a mile away 1
from the site. The gray shaded area to the northeast 2
of the site is the DOE Oakridge Reservation. And two 3
towns are visible in this figure, Kingston to the west 4
about 6.8 miles away, and Lenoir City to the southeast 5
about 8.8. miles away.
6 Next slide.
7 MEMBER CORRADINI: So is there where 8
Clinch River Breeder Reactor, is that the same site 9
we're talking about?
10 MS. MANOHARAN: That's it.
11 MEMBER CORRADINI: Okay. So this is 12 irrelevant but curiosity. So when CRBR was being 13 considered, what was their emergency planning zone?
14 It was only 40 years ago. I don't see what's the 15 problem.
16 MR. STOUT: I don't know.
17 MEMBER CORRADINI: Yes? Oh, they 18 submitted to the NRC. Okay.
19 And then the second part of it is, if 20 you're within the EPZ -- if your EPZ is within -- I 21 can't remember the distance -- 1200 feet, it's all 22 within the red.
23 MR. STOUT: Yes, sir.
24 MS. MANOHARAN: That's correct.
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21 MEMBER CORRADINI: And just for the sake 1
of thinking it through, what is two miles from the red 2
dot -- the red star?
3 MS. MANOHARAN: I have a slide that is 4
coming up that actually shows the exact size.
5 MEMBER CORRADINI: Okay, fine. All right, 6
sorry.
7 MS. MANOHARAN: So that will answer that 8
question.
9 MEMBER CORRADINI: Okay, thank you.
10 MS. MANOHARAN: Okay. Section 13.3.3 in 11 Part 2 describes a dose-based consequence or entered 12 methodology for determining an appropriate EPZ size 13 for a small modular reactor at the Clinch River Site.
14 This approach, this methodology uses the same approach 15 and is consistent with the NUREG-0396 approach.
16 NUREG-0396 provided a basis for federal, 17 state, and local government agencies preparedness 18 organizations to determine the appropriate degree of 19 emergency response planning efforts in the area 20 surrounding a nuclear power plant. The report 21 introduced the concept of a generic EPZ as the basis 22 for planning of response actions which would result in 23 a dose savings in areas surrounding a nuclear plant in 24 case of a serious reactor accident.
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22 The NUREG concluded that the objective of 1
an emergency plan -- emergency response plan should be 2
to provide dose savings for a spectrum of accidents 3
that could produce offsite doses in excess of 4
protective action guides, PAGs.
5 Consistent with this recommendation, the 6
dose-based methodology that is described in the ESPA 7
analyzes a spectrum of accidents and uses the same 8
dose criteria that is used in NUREG-0396, which is the 9
one rem total effective dose equivalent limit 10 established in the EPA PAGs.
11 What the dose-based methodology does is 12 take into consideration the unique SMR design features 13 which vary significantly from large light water 14 reactors. For example, SMRs have smaller cores.
15 Their source terms are expected to be several 16 magnitudes lower than large light water reactors, 17 which results in reduced accident consequences, as 18 demonstrated in the example analysis that we'll go 19 over in a minute, and also are expected to have 20 reduced likelihood of accidents. Their core damage 21 frequency is expected to be several magnitudes 22 reduced, compared to large light water reactors and 23 also are expected to have slower accident progression, 24 which allows for more time to take mitigative actions.
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23 Next slide.
1 CHAIRMAN KIRCHNER: This may be, on my 2
part, maybe just quibbling with the words in the 3
previous field graph that rigorously, it doesn't 4
ensure protection for doses above one rem. The one 5
rem is the trigger point to start your emergency 6
planning. And that's no guarantee that it's less than 7
one rem exposure. That's the intent.
8 So it's more trigger than it is -- and 9
it's a measure to protect the public against dose 10 aversion but it's not a guarantee that a member of the 11 public wouldn't get 1.5 rem or whatever total dose, 12 right?
13 MS. MANOHARAN: Yes.
14 CHAIRMAN KIRCHNER: Okay.
15 MS. MANOHARAN: The intent of that 16 supplement was to show that we are using one rem TEDE.
17 But I do -- your point is noted. Thank you.
18 Next slide, please.
19 The technical criteria for determining a 20 plume exposure path for the EPZ has three criteria, A, 21 B, and C.
22 Criterion A encompasses those areas in 23 which projected dose from design basis accidents could 24 exceed EPA PAGs. Criterion B encompasses those areas 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 in consequences -- for which consequences of less 1
severe core melt accidents with intact containment 2
could exceed the EPA PAGs. For C, it ensures that 3
this EPZ is of sufficient size to provide substantial 4
reduction in early severe health effects in the event 5
of severe core melt -- in more severe core melt 6
accidents with containment by this failure.
7 Next slide, please.
8 MEMBER MARCH-LEUBA: Tell me what a less 9
severe core melt is. I mean on B, you said the 10 consequences of a less severe core melt accident.
11 MS. MANOHARAN: Yes.
12 MEMBER MARCH-LEUBA: What is that?
13 MS. MANOHARAN: So the less severe core --
14 just one second here. Yes, so the accident scenarios 15 would include core melt accidents with intact 16 containment beyond design basis scenarios and accident 17 scenarios with core damage frequencies greater than 10 18 to the negative six, which I will explain in the next 19 20 MEMBER MARCH-LEUBA: You'll explain later?
21 MS. MANOHARAN: Yes.
22 MEMBER MARCH-LEUBA: I'll wait.
23 MS. MANOHARAN: And there is a distinction 24 between each of them, which we will go over.
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25 MEMBER BLEY: So there is both a frequency 1
component to this and it is a contained melt.
2 MS. MANOHARAN: That is correct.
3 MEMBER CORRADINI: Did you really want to 4
say yes to that? In other words, you're assuming at 5
all times the containment is intact? Because I got 6
the impression you're looking for the collection, I 7
thought the collection of sequences that are both for 8
intact containments, which might have an unphysically 9
-- I'll use the word unphysical -- a prescribed source 10 term with an intact containment as well as PRA 11 sequences that would have a variety of source terms 12 but the containment could be bypassed.
13 MEMBER BLEY: It has the frequency element 14 on it, right?
15 MR. YOUNG: So I'd just like to clarify.
16 The criterion B portion, the less severe core melt 17 accidents is only looking at the intact containment.
18 MEMBER CORRADINI: Okay.
19 MR. YOUNG: The containment failure bypass 20 is handled in criterion C, which is the early severe 21
-- or the more severe core melt accident.
22 MEMBER CORRADINI: Okay, that's fine. And 23 then I thought you had said, I want to make sure, that 24 you have a frequency cut-off.
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26 MS. MANOHARAN: Yes, which is coming up in 1
the next slides.
2 MEMBER CORRADINI: Okay, fine. Thank you.
3 Okay, so we are at the frequency cutoff 4
slide, so the criterion A and B methodology 5
implementation. To verify that the dose consequences 6
beyond the EPZ do not exceed the EPA early phase PAGs, 7
the methodology starts with selecting appropriate 8
accident scenarios. The accident scenarios would mean 9
core damage frequency of 1E to the negative 6 per 10 reactor year is being selected.
11 Based on the accident scenarios that I've 12 selected, the source terms I calculated and the dose 13 consequence for the selected accident scenarios are 14 evaluated.
15 MEMBER BLEY: Now you're in category C, 16 right?
17 MS. MANOHARAN: This is still 1E to the 18 negative 6 per reactor year and then intact 19 containment. So we are in --
20 MEMBER BLEY: Oh, so you're still in B.
21 MR. YOUNG: Yes, so the blue box is 22 important.
23 MS. MANOHARAN: Yes, so we group A and B 24 together and this slide discusses how criterion A and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 B are evaluated. The next slide talks about how 1
criteria C is evaluated.
2 MEMBER CORRADINI: And then -- okay. I'm 3
not sure how to ask the question so let me ask it this 4
way.
5 So you're assuming that the containment is 6
intact during these -- in criterion A and B, 7
regardless of the accident sequence or is it 8
interwoven with the sequence itself tells you whether 9
the containment is in or out?
10 MR. YOUNG: The latter.
11 MEMBER CORRADINI: The latter.
12 MR. YOUNG: So if it meets the cutoff 13 frequency we've established here, we're only looking 14 at those accidents that are intact containment that 15 meet this cutoff frequency.
16 MEMBER CORRADINI: Okay. So my second 17 part of the question is where did you get 10 to the 18 minus 6 mean? Because as you get to these -- I'm 19 waiting for Dr. Kirchner to say this but I'll steal 20 his thunder. The uncertainty is such that is mean the 21 right value? Is 10 to the minus 6 with the mean the 22 right? Why? Why 10 to the minus six? Why mean?
23 MR. YOUNG: Sure. So the main core damage 24 frequency cutoff criteria we've established for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 criterion B and C is established by a significant 1
amount of industry documentation. A lot of that 2
industry documentation identifies E to the minus 6 as 3
a point that most accidents are encompassed by that.
4 An example of that would include the SOARCA analysis.
5 MEMBER CORRADINI: Yes, well, don't point 6
to them. I'm looking at our resident PRA expert 7
because that surprised me.
8 MEMBER BLEY: I don't quite get this. If 9
you've done a PRA, if you had a plant, there are a 10 great many accidents at lower frequency and, 11 depending, some or a lot above this. I don't quite 12 understand it.
13 MEMBER CORRADINI: But you put everything 14
-- I guess what I'm trying to understand is you put 15 everything into two baskets. First, regardless of the 16 basket, you're only looking at things that pop at 10 17 to the minus 6 or larger. And then, depending upon 18 the sequence, if the containment fails or not fails, 19 you have it in two bins.
20 MR. YOUNG: And so if the containment 21 fails, it would not be considered in the criterion B 22 greater than 1E-6. We have a cutoff frequency that is 23 further down line for criterion C. So if you did have 24 a cutoff frequency, you would have to evaluate that in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 criterion C.
1 MEMBER CORRADINI: Okay, I think I got it.
2 MS. MANOHARAN: So the very last step in 3
the methodology, implementation for criteria A and B 4
is to take the dose consequences calculated and 5
compare them to the EPA early phase PAG to ensure that 6
they are not exceeding.
7 So next slide, Criterion C. So EPZ should 8
be of sufficient size to provide substantial reduction 9
in early severe health effects in the event of a more 10 severe more melt accidents with intact containment.
11 So the first three steps are similar to 12 criteria A and B in that appropriate accident 13 scenarios, as selected, the cutoff here is mean core 14 damage frequency greater than 1E to the negative 7 per 15 reactor year. And source terms are calculated for the 16 selected accident scenarios and dose consequences from 17 those were evaluated.
18 There are two additional steps in 19 criterion C, which is to calculate the distance at 20 which the conditional probability to exceed 200 rem 21 whole body exceeds 1E to the negative 3 per reactor 22 year, consistent with the basis provided in NUREG-0396 23 and, finally, to compare the distance to the EPZ to 24 ensure that it is of sufficient size.
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30 Next slide, please. I would like to turn 1
it over to Alex Young, who is going to walk through 2
the example analysis that was conducted as a result of 3
an RAI request.
4 MR. YOUNG: Thanks, Archie. My name is 5
Alex Young. I'm part of the engineering team working 6
design engineering for the Clinch River project for 7
TVA. I've been working on this project for about four 8
years now.
9 Over the course of the review, one of the 10 things that was requested of TVA was for us to provide 11 some additional information that demonstrates that the 12 methodology we've just described can be implemented 13 and that the criteria for both the EPA early phase PAG 14 limits and the substantial reduction early health 15 effects can be met by an SMR design considered in an 16 OSI permit application.
17 To demonstrate this methodology, Clinch 18 River Site-specific example calculation was performed.
19 At the COLA, the applicant will still need to perform 20 an evaluation of whichever design is chosen for COLA.
21 This is just an example to demonstrate the 22 methodology.
23 This example calculation utilizes a 24 NuScale design that is assumed to be sited at the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 Clinch River Site. So we used NuScale-specific design 1
information like PRA and source terms and applied it 2
to Clinch River Site's specific information like 3
meteorological data and conservative assumptions like 4
the 1,100 foot distance from release boundary to site 5
boundary.
6 To summarize the evaluation, we start with 7
criterion A, looking at design basis accidents. We 8
utilized the design basis source term determined in 9
NuScale's Chapter 15 of their design cert to calculate 10 a dose of 0.104 rem and that leaves a significant 11 amount of margin compared to the one rem limit that 12 was established.
13 And we after we evaluated the design basis 14 accidents, we considered the less severe core melt 15 accidents, which are those of the criterion B 16 evaluation. For this criterion, we look at accident 17 scenarios with the main core damage frequency greater 18 than the 1E minus 6 and they have intact containments.
19 But for the NuScale design, there are no accident 20 scenarios that meet this cutoff frequency.
21
- However, there is a
note in our 22 methodology that if no accidents meet that cutoff 23 frequency, we will develop a surrogate source term and 24 analyze that source term to the limits.
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32 MEMBER BLEY: What kind of -- sorry, go 1
ahead.
2 What kind of guidance have you given 3
yourself on how you define a scenario? A clever 4
analyst can break up the scenario into many sub-5 scenarios, each one of which has a lower frequency.
6 So what kind of rules do you have to make sure these 7
10 to the minus 6 and 10 to the minus 7s are 8
meaningful?
9 MR. YOUNG: Sure so I'll start by making 10 a statement and then I'll hand it over to help from 11 Scott Webber, who can give some more detail about how 12 we did that in our example analysis.
13 But we look at various timing aspects and 14 equipment availability aspects.
15 MEMBER BLEY: So you may be grouping 16 things from a PRA --
17 MR. YOUNG: Yes.
18 MEMBER BLEY: -- or from higher level set 19 that have to meet these criteria?
20 MR. YOUNG: Yes. And it would be design-21 specific. Scott can speak to how we handled this in 22 the example.
23 MEMBER BLEY: Okay.
24 MR. WEBBER: I'm Scott Webber, PRA Group 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 at NuScale responsible for severe accidents and 1
emergency planning zone.
2 So towards what Alex was saying, in the 3
example work that was done here, there was no need to 4
distinguish between accident scenarios and accident 5
sequences because the as-submitted NuScale PRA has a 6
total CDF that is below the screening limits. And so 7
the question of --
8 MEMBER BLEY: Does that include external 9
events --
10 MR. WEBBER: That's correct.
11 MEMBER BLEY: -- and fires?
12 MR. WEBBER: All PRA that was part of 13 NuScale's design certification is included and that's 14 everything -- external events, internal, except for 15 seismic, which was not required at that time.
16 So the total core damage frequency is 17 greater -- sorry -- less than the screening limits 18 and, therefore, the grouping of accidents is 19 redundant.
20 MEMBER REMPE: Okay, I got confused in 21 your response. You said you did include external 22 events but then you said excluding seismic. Is that 23 what you said? So how could you do that?
24 MR. WEBBER: Right so the seismic PRA is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 not required for design certification PRA.
1 MEMBER REMPE: Okay.
2 MR. WEBBER: And so there is no seismic 3
here available at this time.
4 MEMBER REMPE: Okay.
5 MEMBER CORRADINI: So I'm waiting for 6
other people to ask the question but I'm the least 7
competent.
8 So what did you pick to get 0.158?
9 MR. YOUNG: Sure so as we will continue on 10 in the slides, we will get to that point.
11 MEMBER CORRADINI: Okay. And then let me 12 make sure I understand. So bin A is design basis 13 accidents that are Chapter 15 related and with 14 containment intact. And based on that collection, you 15 got a number. And then B, there was an empty set. So 16 you assumed something and got a number.
17 And C was an empty set?
18 MR. YOUNG: Sure, so --
19 MEMBER CORRADINI: They never broke 20 containment?
21 MR. YOUNG: So there are -- well, we'll 22 cover C here in just a second about how we exclude 23 that one. I would first like to cover the what 24 accident was selected for B.
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35 MEMBER CORRADINI: Okay.
1 MR. YOUNG: So as we mentioned for 2
criterion B, there were no accidents that SCRAMed in, 3
based on the cutoff frequency we said but we are going 4
to evaluate a surrogate source term. The source term 5
we evaluated is the most frequent accident that is 6
used to develop the Chapter 15 design basis source 7
term for the NuScale design.
8 Utilizing that source term from that 9
accident, that event, we determined the 0.158 rem.
10 MEMBER CORRADINI: What was that sequence?
11 What was the event?
12 MR. YOUNG: Sure. So the sequence is a 13 loss of DC power with an ECCS failure. To give you --
14 it is several orders of magnitude below what the 15 cutoff frequency is.
16 MEMBER MARCH-LEUBA: And it results in 17 core melt?
18 MR. YOUNG: I'm sorry?
19 MEMBER MARCH-LEUBA: You end up having a 20 core melt?
21 MR. YOUNG: It does result in core damage.
22 MEMBER MARCH-LEUBA: Core damage? How 23 severe?
24 MR. YOUNG: Scott, can you speak to how 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 severe the core damage is on that accident?
1 MR. WEBBER: The severity of the accident 2
is somewhat of a vague definition. There is a core 3
damage threshold that the PRA Group uses, which is a 4
peak cladding temperature of 2200 Fahrenheit that is 5
reached in all portions of the core.
6 MEMBER MARCH-LEUBA: A hundred percent of 7
the core --
8 MR. WEBBER: Exceeds --
9 MEMBER MARCH-LEUBA: -- exceeds the 2200 10 11 MR. WEBBER: -- the peak cladding 12 temperature.
13 MEMBER MARCH-LEUBA: So this is a complete 14 meltdown.
15 MR. WEBBER: Well based on the NuScale 16 design, it is not -- it does not necessarily melt.
17 MEMBER MARCH-LEUBA: But your initial do 18 cladding.
19 MR. WEBBER: There is definitely fuel 20 failure and relocation of fuel. Melting is a sort of 21 variable, depending on the amount of cooling in the 22 scenario.
23 MEMBER MARCH-LEUBA: So the oxide doesn't 24 melt but all of the cladding disappears.
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37 MR.
WEBBER:
There is significant 1
oxidation in the fuel relocation, yes.
2 MEMBER CORRADINI: So now let me ask the 3
question that I've bene waiting for.
4 If I put the alternative source term up 5
with categories in terms of the seven radiological 6
groups and then I have the timing, there is a conical 7
graph of that, and I put your source term up and 8
mapped it into that, what would it look like? Because 9
I assume this is much smaller than the alternative 10 source term on the percentage basis of the core.
11 MR. YOUNG: Which -- what are you asking 12 is smaller?
13 MEMBER CORRADINI: If I take NUREG-1465, 14 which is the alternative source term, it has 15 categories in terms of halogens, alkaline metals, 16 blah, blah, blah, and then it has timing -- when to 17 release gap release in-vessel, ex-vessel, et cetera.
18 I'm kind of curious if you've mapped in 19 the source term you used based on the discussion we 20 just heard, that comparison.
21 MR. YOUNG: I'll point to Scott to talk 22 about the specific source term and how that compares.
23 MEMBER CORRADINI: Do you have a slide 24 somewhere that we could look at or something we can 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 read later?
1 MR. YOUNG: We don't provide -- in this 2
presentation, we don't provide the specific source 3
term for this. That would be NuScale proprietary.
4 MEMBER CORRADINI: Ah.
5 MEMBER BLEY: We might see it in our 6
review.
7 MEMBER CORRADINI: Okay. Okay, that's 8
fine. That's good enough for the moment.
9 MS. MANOHARAN: I wouldn't say that there 10 is an RAI response that has the source term 11 information. It is NuScale proprietary, so it was 12 treated appropriately.
13 MEMBER CORRADINI: Okay so then we'll turn 14 to the staff and ask them. Thank you.
15 CHAIRMAN KIRCHNER: Now just to clarify 16 for the record, A on this slide and B both assume that 17 the containment leaks at the design leakage rate. Is 18 that correct?
19 MR. YOUNG: Yes, so the leakage rate for 20 A would be based on the assumptions in the NuScale 21 Chapter 15 analysis.
22 CHAIRMAN KIRCHNER: Sure. Right. Right.
23 MR. YOUNG: And the way NuScale has 24 specifically analyzed those accidents, those will be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 reviewed in more detail at the COLA stage or during 1
the design certification.
2 CHAIRMAN KIRCHNER: Sure. An B, the same 3
assumption for containment performance?
4 MR. YOUNG: Scott, can you speak to 5
containment performance for criterion B in the leakage 6
rate?
7 MR. WEBBER: You were right, Alex, the 8
tech spec leakage is assumed for both.
9 CHAIRMAN KIRCHNER: For both. That's what 10 I assumed.
11 Then -- well, this is not a review of 12 NuScale. So perhaps going into it in detail is not 13 appropriate. But I'm just looking at the ratio of the 14 numbers from A to B.
15 A suggests and I'll just guess it's some 16 kind of LOCA kind of event or equivalent. I wouldn't 17 expect complete core failure. And that number is 50 18 percent higher for B. So it doesn't suggest that 19 you've lost the entire core. I just was a little 20 concerned, for the record, and I don't have enough 21 information to back up my intuition.
22 MR. YOUNG: So I'd like to clarify that 23 the criterion A design basis accidents is based on 24 NuScale's Chapter 15 --
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40 CHAIRMAN KIRCHNER: Right.
1 MR. YOUNG: -- which is based on a 2
spectrum of accidents and not just a single LOCA 3
event.
4 CHAIRMAN KIRCHNER: Okay.
5 MEMBER MARCH-LEUBA: Now is the related 6
Chapter 15 accident analyzed in the results in core 7
failure?
8 MR. YOUNG: I'm sorry.
9 MEMBER MARCH-LEUBA: In any Chapter 15 10 event results in cladding damage?
11 MR. YOUNG: Not for NuScale.
12 MEMBER MARCH-LEUBA: Then why is it not 13 zero?
14 MR. YOUNG: I'll let Scott answer the 15 question on NuScale's Chapter 15 analysis.
16 CHAIRMAN KIRCHNER: Okay, sure.
17 MR. WEBBER: Yes, so as has been stated, 18 the NuScale analysis is an example based on best 19 available. But as of the design that has been 20 submitted, there is no fuel failure in any design 21 basis events for the NuScale design. So, therefore, 22 for the purposes of design basis source term to be 23 used for siting and other purposes, it was necessary 24 to already go beyond the design basis. So NuScale has 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 come up with what is called a design basis source 1
term, which is based on a set of five beyond design 2
basis accidents that include both LOCAs and losses of 3
power.
4 And so the design basis source term, which 5
is used for criterion A as a surrogate of all those 6
sequences that incorporates worst timing and new 7
releases.
8 MEMBER MARCH-LEUBA: I understand what it 9
is. I don't know why you did it. I mean it should be 10 sealed.
11 CHAIRMAN KIRCHNER: Okay, you may proceed.
12 MR. YOUNG: Okay, moving on to the 13 criterion C portion --
14 MEMBER MARCH-LEUBA: Sorry. Is this for 15 one NuScale module or 800 megawatts electric worth of 16 emollients, which of the two?
17 MR. YOUNG: This is for a single NuScale 18 module.
19 MEMBER MARCH-LEUBA: So no need to put 20 failures.
21 MR. YOUNG: No, not for this analysis.
22 MEMBER MARCH-LEUBA: But see if you have 23 a full plant, you will have two of those and then you 24 will be over one.
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42 MR. YOUNG: Well the multi-module question 1
will be addressed in the specific PRA results of the 2
design that is chosen at COLA.
3 For this analysis, using the NuScale plant 4
at this time, multi-module events were not -- were 5
below the threshold for consideration in the analysis.
6 MEMBER MARCH-LEUBA: So was this one.
7 MR. YOUNG: But criterion A is based on a 8
Chapter 15 analysis. So and NuScale considered the 9
design basis source term in their Chapter 15 analysis.
10 We used that for the example calculation.
11 MS. MANOHARAN: Maybe I didn't provide a 12 little bit of context. We did the example analysis as 13 the result of an RAI that asked us to demonstrate that 14 the methodology can be implemented and dose criteria 15 can be met. NuScale being the only SMR design 16 available to us with the design certification 17 application that is in review with the staff and the 18 design maturity enough for us to go and use them for 19 this example. That was the intent of this example 20 analysis, to show that those criteria can be met.
21 MEMBER MARCH-LEUBA: Okay, so we assume 22 that there was 100 percent fuel failure of all the 23 cladding in which 2200 Fahrenheit. And it is robbing 24 oxidation of everything and the whole things goes to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 the bottom of the core.
1 The containment remains closed. How did 2
you get any releases?
3 CHAIRMAN KIRCHNER: In design basis leak 4
rate -- tech spec leak rate of containment would give 5
you --
6 MEMBER MARCH-LEUBA: For NuScale?
7 CHAIRMAN KIRCHNER: Sure.
8 MEMBER MARCH-LEUBA: Well the first thing 9
to do is depressurize. There is no leakage. I guess 10 this is another possibility approximation.
11 MR. YOUNG: So moving on to criterion C, 12 this is the evaluation of the substantial reduction in 13 early health effects. When we performed the accident 14 screening, there were no accident scenarios for the 15 NuScale design with the main core damage frequency 16 greater than 1E minus 7.
17 MEMBER BALLINGER: Let me pull the string 18 a little bit more from Jose's. If you have 100 19 percent of the fuel -- of the cladding oxidized, what 20 is the pressure inside that vessel?
21 MS. BRADFORD: Can I -- this is Anna 22 Bradford from NRO. We're in a little bit of a gray 23 area here because we are not talking about the NuScale 24 design today. We will be coming to you with the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 NuScale design certification SE in the future, where 1
we can get into these details. But TVA is not the 2
designer of NuScale. They used some of NuScale's 3
design information because we asked for details to 4
show that this was even possible, given possible 5
designs. You know show us that such a thing could 6
even occur.
7 So I just don't want TVA or maybe even 8
NuScale, who is I guess accommodating here today, to 9
have to get into the details of what was assumed in 10 the design by the designer because they are not the 11 designer.
12 You will be seeing that in the future when 13 we come to ACRS with those details and with our 14 analysis of those details.
15 MR. YOUNG: So criterion C, no accident 16 scenario screened in based on the cored damage 17 frequency of 1E minus 7 and, therefore, there is no 18 dose evaluation for criterion C.
19 All this is to say that we met the 20 criterion A and B EPA early phase PAG dose limits and 21 did not screen any accidents for consideration in 22 criterion C. All this evaluation concludes that a 23 site boundary EPZ is possible at the Clinch River 24 Site.
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45 Next slide.
1 CHAIRMAN KIRCHNER: Okay, mindful of Anna 2
Bradford's comments that this is not a NuScale review, 3
but let me just -- so let's neutralize that.
4 Say you put the source of this number 5
aside. Multiply this number by the number of modules 6
that you might have and then, as was pointed out by 7
one of my colleagues, then you're above the one rem 8
trigger point.
9 So how do you plan going forward to deal 10 with the multi-module issue or you believe that you 11 can convince the staff that in PRA space, common mode, 12 common cause failure wouldn't require you to take all 13 X modules into consideration?
14 MR. YOUNG: So I'll say that our 15 methodology would consider multi-module events. The 16 inclusion of multi-module events is a design-specific 17 consideration that at COLA will be evaluated for the 18 particular design chosen.
19 So if we choose a particular design where 20 multi-module events need to be considered, those will 21 be considered in the methodology.
22 MEMBER REMPE: That's your hope is that it 23 will fall below the frequency is what I would guess.
24 MS. MANOHARAN: Yes, if the dose -- if I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 could just add to that point, if the dose criteria is 1
not met at site boundary, then we would not be able to 2
use site boundary. That's why there is a two-mile 3
emergency path. We definitely wanted to move that 4
boundary and have some confidence that at least one 5
reactor design would meet it.
6 MEMBER REMPE: And again, I am kind of 7
coming to this without the background because I'm not 8
inside the subcommittee but this A and B is a little 9
misleading because the staff asked you to do it. But 10 I'm guessing that if you really had picked the NuScale 11 design, you'd say hey, no, I'm not going to do this 12 because it all falls below, right?
13 MR. YOUNG: Well, just to clarify that 14 point, criterion B, whether anything screens in or 15 not, requires us to evaluate a surrogate source term 16 and come up with a perspective dose.
17 For criterion A, that would be very 18 technology-specific because our methodology requires 19 us to consider the same evaluation that the design 20 would consider in their Chapter 15 of their design 21 cert or equivalent.
22 MEMBER REMPE: If they can't get a dose in 23 any other design basis accidents, then you'll put a 24 big zero there.
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47 MR. YOUNG: Yes. If the --
1 MEMBER REMPE: Which means no circulating 2
release or whatever but, yes.
3 MR. YOUNG: If the design could prove that 4
the accident did not have to consider those design 5
basis accidents and the equivalent, those would be 6
zero and we would put a zero there.
7 Moving on to the next slide, so we just 8
discussed the example analysis that we performed. In 9
addition to this, we established an EPZ plant 10 parameter. This is separate from the plant parameter 11 envelope described in Chapter 2 of the site safety 12 analysis report. It is specific to the EPZ exemption 13 request. It does not apply to the rest of the site 14 safety analysis.
15 This is used to demonstrate or to ensure 16 that the exemption request would be applied 17 appropriately in the future at COLA. Even though this 18 is not an EPZ plant parameter envelope, as in Chapter 19 2, it would be applied very similarly in that at COLA 20 we will have to evaluate to ensure that the selected 21 design is bounded by the source terms established in 22 this plant parameter.
23 MEMBER REMPE: Well I have questions about 24 this, too. First of all, from this morning I asked a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 lot of questions about this four-day thing. And I was 1
told after the meeting this morning it's a rolling 2
four-days. It shouldn't be at t equals zero, which 3
wasn't conveyed this morning.
4 Is your thing going to be a rolling four-5 day, as long as there is a release?
6 MR. YOUNG: So the way we look at the 96-7 hour period is we look at from the start of release, 8
not the start of accident. So different accidents may 9
have different release timings.
10 So we start at the release time, not at 11 the accident start time. So we consider the initial 12 part of the release.
13 MEMBER REMPE: If I had a plant that had 14 a circulating release and they vented, and then they 15 managed to keep the core damage going for another 95 16 or 97 hours0.00112 days <br />0.0269 hours <br />1.603836e-4 weeks <br />3.69085e-5 months <br />, and then they had core damage and, 17 kaboom, a lot of stuff came out, that's you know, 18 again, at the worst four hours would be start after 19 the event and do it later. So that's something.
20 And I would think, Ken Thomas, if he's 21 still here, can elaborate on this because if it is the 22 worst four days, then that won't work if you do it at 23 t equals zero. You should pick the most severe four 24 days is what you said is in the regulation and it was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 just what was in the draft rule was incorrect.
1 MR. THOMAS: So this is Kenny Thomas from 2
NSIR DPR, technical aid for this morning's discussion.
3 It's not in the current rule. That is part of the 4
confusion that we had this morning is what is the 5
necessary intent of the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
6 So the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> is an homage to the four-7 day integrated dose and that's ongoing from the point 8
of when you start doing your dose projections you 9
start looking at what is the consequence impact to the 10 public and do you exceed one rem forecast over the 11 next 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> for the release and so forth.
12 So that is not in the current rule. It is 13 not in the guidance and it's one of the points of 14 confusion that we had this morning.
15 MEMBER REMPE: What is the legal 16 requirement for what they are doing? Do they have to 17 pick the most severe four days of a release so that 18 you can let the circulating release go on and then 19 start timing when you have the most severe? What is 20 the current requirement?
21 MR. THOMAS: Well, with respect to my 22 rule, it is not in it.
23 MEMBER REMPE: Not in your rule. That's 24 the current --
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50 MR. THOMAS: Not yet.
1 MEMBER REMPE: I thought at the end of 2
this morning's -- or this afternoon when you got me 3
before this meeting and said this, I thought you said 4
the intent was to have the most severe and that's what 5
in the regulation. What's in the regulation?
6 MR. THOMAS: It's not in the regulation.
7 MEMBER REMPE: Oh, the guidance.
8 MR. THOMAS: Right or it's not even in the 9
guidance yet.
10 We don't have the proper people. I don't 11 see the research individuals who do -- or Michelle 12 Hart -- who do the consequence analysis.
13 So I
would have to approach the 14 consequence analysis folks for that.
15 MS. BRADFORD: This is Anna Bradford, NRO.
16 We can go over this during the staff part of this 17 presentation, if that would be helpful.
18 MEMBER REMPE: Yes, again, because I don't 19 know about your four plans you've picked but to me it 20 seems like you might be able to have something more 21 severe if you --
22 CHAIRMAN KIRCHNER: Well, for the record, 23 they are not considering that technology.
24 MEMBER REMPE: Well I don't know the four 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 that they've picked if they've picked the most severe 1
for all four days.
2 CHAIRMAN KIRCHNER: But let's ask them how 3
they define your four days.
4 MEMBER REMPE: They've already told me 5
they start --
6 CHAIRMAN KIRCHNER: From the start of 7
release.
8 MEMBER REMPE: Yes, that's what they've 9
said. So did you look beyond?
10 MR.
YOUNG:
I'll make a
quick 11 clarification of that. This is for a plan parameter 12 that we've established based on certain accidents. We 13 considered that we did use the first four days from 14 the start of release. For established -- for 15 implementation of the methodology, we will evaluate 16 the most appropriate source term based on the accident 17 scenario that needs to be considered.
18 So the way our methodology worked, it does 19 not preclude us from having to consider the worst four 20 days or the early four days. That will revolve around 21 the accident selection and source term selection for 22 implementation of methodology but this is separate 23 from the example and separate from actual 24 implementation of the methodology.
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52 MEMBER REMPE: Okay, that helps, as long 1
as I know somebody is going to think about the most 2
severe four days. Thank you.
3 MR. YOUNG: Continuing on with this slide, 4
this is the plant parameter. We'll have to evaluate 5
it at COLA to ensure that the selected design meets 6
the source term we've developed.
7 To establish this EPZ plant parameter, we 8
developed the four-day atmospheric release source 9
term. This allowed us to account for various SMR 10 designs, and accident types, and the total four-day 11 release that was required for the EPA early phase PAG 12 dose limits.
13 The four-day atmospheric release source 14 term is a composite of three different source terms, 15 which includes the ESPA PPE Chapter 15 source terms 16 and the two source terms evaluated in the example 17 calculation. This accounts for various SMR designs 18 and various accident types to be considered.
19 The worst activity from each isotope 20 considered for each major time period, which we 21 considered to be the zero to 8, 8 to 24, and 24 to 96-22 hour time period is then accumulated into a composite.
23 We summed those up over four days and come up with a 24 total four-day atmospheric release source term.
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53 We then applied 25 percent of 1
discretionary margin to that total. From the four-day 2
total composite source term with the 25 percent 3
discretionary
- margin, we evaluate the dose 4
consequences. We determined that with this source 5
term, the four-day total composite plus 25 percent we 6
would be in compliance with the EPA PAG dose limit of 7
one rem.
8 At COLA, we will compare this source term 9
to the criterion A and B source terms for the accident 10 selected to this four-day atmospheric release source 11 term for EPZ exemption request applicability.
12 MEMBER REMPE: So you only considered the 13 species or the isotope. Did you consider like the 14 form, whether it is a particulate, whether it's a --
15 I mean what did you do with respect to the form of the 16 isotopic release?
17 MR. YOUNG: So we utilized the atmospheric 18
-- the gaseous release source terms that were 19 determined from the two example analyses source terms 20 and the PPE source term. Specific percentages or 21 breakdown of particulate versus aerosol, et cetera, is 22 specific to those source terms for the reactor 23 designs.
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54 information but the vendors consider that proprietary.
1 So we're just evaluating a known isotope with a known 2
activity.
3 MEMBER REMPE: Thank you.
4 MR. YOUNG: For the rest of the 5
presentation, I'll turn that back over to Archie.
6 MS. MANOHARAN: Thank you, Alex.
7 The last topic we have for Section 13.3 in 8
Part 2, we are on slide number 17, is information 9
concerning contacts and agreements.
10 In support of the ESPA, letters of support 11 from State of Tennessee, Anderson County, Roane 12 County, and City of Oak Ridge were submitted to the 13 staff. If a future combined license application is 14 pursued, TVA will pursue the appropriate certification 15 letters and letters of agreement with the local 16 emergency medical and law enforcement agencies to 17 ensure that there is enough emergency response 18 organization support available.
19 Most important before we leave Part 2 20 information is TVA would continue to work with state 21 and local support organizations to establish an 22 emergency preparedness at Clinch River that is 23 commensurate to the reactor design but selected at 24 COLA and the potential consequences resulting from 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 that reactor design to the public health and safety.
1 Next slide. Moving on to information in 2
Part 5 Emergency Plans, as I had mentioned at the 3
beginning of this presentation, in Part 5 the ESP 4
contains two major features -- two emergency plans 5
major features for a site boundary EPZ and major 6
features of an emergency plan for two-mile EPZ.
7 Both of these plans consider and address 8
the 16 planning standards of NUREG-0654. They contain 9
the amount of information available to us during the 10 ESP development. So design-specific information such 11 as that would be required to develop accident 12 analyses, or staffing levels, or EALs are not 13 addressed in Part 5.
14 You also need to consider the information 15 in Part 5 with the exemptions request in Part 6, which 16 I will summarize later in the presentation. Next 17 slide.
18 There was a question earlier about what 19 does the site boundary EPZ look like. This figure 20 here in red shows the EPZ site boundary for Clinch 21 River. The layout of the information in Part 5A for 22 site boundary EPZ has two parts. One is the main 23 plan, which builds on the generic emergency plan used 24 by TVA for the current nuclear operating plants 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 already approved by the staff and an appendix that has 1
site-specific information concerning the site location 2
and other site-specific features.
3 In addition to providing information 4
concerning the necessary actions to safeguard on-site 5
personnel and minimize damage, it proposes how the 6
emergency plan is compatible with the site.
7 Next slide. Another question was what 8
does the two-mile EPZ look like. The figure here, the 9
blue circle is the two-mile radius from approximately 10 the center of the site. The red is the exact size and 11 configuration of the two-mile EPZ. As you can see, in 12 most areas, it is actually larger than two-mile EPZ 13 and never less than two.
14 The exact size and configuration of the 15 two-mile EPZ was developed in relation to local 16 emergency response needs and capabilities, as they are 17 affected by conditions such as demography, topography, 18 land characteristics, and access routes.
19 MEMBER MARCH-LEUBA: In that, what is the 20 funny red line?
21 MS. MANOHARAN: The red line is the actual 22 two-mile EPZ. So --
23 MEMBER MARCH-LEUBA: No, the two-mile is 24 the circle.
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57 MS. MANOHARAN: The blue line, which is a 1
circle, is to show you the circle with the two-mile 2
radius from the center of the site. But when you 3
actually create your exact EPZ size, you take into 4
account population, land characteristics, ease of 5
access --
6 MEMBER MARCH-LEUBA:
This is your 7
imaginary line to two-miles, which is not two miles?
8 This is something larger.
9 MEMBER BLEY: The actual EPZ is a little 10 bigger. So it is probably roads and things it looks 11 like.
12 MS. MANOHARAN: Yes, some rivers and 13 roads.
14 MEMBER MARCH-LEUBA: You were following 15 some existing roads and things like that?
16 MS. MANOHARAN: Yes, that's correct. Yes.
17 MEMBER MARCH-LEUBA: So basically, ORNL is 18 outside the line, the extant plant?
19 MR. YOUNG: Yes.
20 MS. MANOHARAN: A site evacuation --
21 evacuation time estimate analysis was conducted to 22 show -- to support information, in part, which I will 23 go over in the next slide. Next slide, please.
24 So as I said, an evacuation time estimate 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 analysis was conducted to show that there are no 1
physical characteristics unique to the Clinch River 2
Site that would pose a significant impediment to 3
development of emergency planning -- emergency plans 4
at the site.
5 In addition to providing -- acting as a 6
tool to TVA and state and local governments for 7
specific -- site-specific information needed for 8
protective action decisions, it also serves as a tool 9
to show that there are no physical characteristics 10 that would hinder emergency plans.
11 It was conducted in accordance with 12 NUREG/CR-7002 and just to provide a clarification, 13 there is no site evacuation time estimate for Part 5A 14 because it is in the site boundary EPZ.
15 Next slide.
That concludes our 16 information that we had for Part 5.
17 Moving on to Part 6 of the presentation, 18 to support the information in Part 5 of which has a 19 two-mile EPZ and a site boundary EPZ emergency plans, 20 a set of exemption requests were developed after 21 reviewing the current emergency preparedness 22 requirements and each set supports either Part 5A or 23 Part 5B. I will go over the exemption requests in a 24 summary in the next couple of slides. Next slide, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 please.
1 In Table 1-1 of Part 6, exemption requests 2
are described that support site boundary EPZ emergency 3
plan. In addition to deviating from the current ten-4 mile plume exposure pathway EPZ size, certain elements 5
of a formal offsite emergency plan are being asked to 6
be exempt from, the logic being, at a COLA, after 7
reactor design has been selected, the dose-based 8
methodology that was described in 13.3 is implemented 9
to show that the dose criteria is adequately met at 10 site boundary. If that is the case, then these 11 exemptions would be warranted.
12 But it is also important to note that 13 TVA's emergency plans will describe the capabilities 14 to determine if a radiological release is occurring, 15 promptly communicate it to offsite organizations for 16 their consideration.
17 Next slide. Table 1-2 of Part 6 describes 18 certain exemption requests that support, again, site 19 boundary EPZ emergency plan, specifically from 20 evacuation time estimates, certain elements of offsite 21 notification, and offsite exercises.
22 Following the same logic, the SMR design 23 would have to show that it meets the dose criteria at 24 COLA, it goes with the dose-based methodology review 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 and then these exemptions will be granted.
1 It is also important to note before we 2
move on from here is that TVA is not seeking an 3
exemption from the requirements to notify responsible 4
state and local government agencies and, also, will 5
continue to invite state and local support 6
organizations to participate in periodic drills and 7
exercises.
8 Next slide. The last table, Table 1-3 in 9
Part 6, describes the exemption request that we put 10 forth for the two-mile EPZ emergency plan. The only 11 request or the only exemption request in place for a 12 two-mile EPZ is to deviate from the current ten-mile 13 EPZ size, which goes back to Dan's point at the 14 beginning of the presentation that it is the surrogate 15 to a ten-mile.
16 Next slide. Just to summarize the 17 technical basis in TVA's opinion for the exemptions is 18 the dose-based methodology consequence oriented 19 methodology that is described in Section 13.3, which 20 as we elaborated earlier, has the consistent approach 21 to NUREG-0396, evaluates a spectrum of accidents, has 22 the same dose criteria as EPA PAG and also ensures 23 that the EPZ is of sufficient size to provide 24 significant reduction in the case of severe health 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 effects.
1 Combined with this technical criteria and 2
the dose-based methodology, and the SMR design 3
- features, we believe that there are special 4
circumstances that exist that warrant granting the 5
exemption and that if a selected SMR design at COLA is 6
able to show that the dose criterias are met at either 7
site boundary or two-mile, exempting from these 8
requirements would still allow us to meet the 9
underlying purpose of the regulations.
10 Next slide, please. In summary, I think 11 it would be beneficial to go over what TVA is asking 12 for review in the ESPA and how that might be used in 13 a future combined license application.
14 So in Part 2 of the ESPA, we are seeking 15 approval of the dose-based consequence oriented 16 methodology for determining the plume exposure pathway 17 EPZ size. In a COLA, that methodology will be 18 implemented to develop a
design-specific 19 implementation of the methodology, if approved in 20 ESPA.
21 In the ESPA in Part 6, we are asking to 22 deviate from the current ten-mile EPZ requirements 23 based on the dose-based methodology described in 24 Section 13.3. In COLA, design-specific EPZ size will 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 be determined, based on the dose-based methodology.
1 In Part 5 of the ESPA, major features of 2
two emergency plans are described and approval for 3
these is being sought for site boundary and two-mile.
4 In COLA, once the SMR reactor design has been 5
selected, dose-based methodology implemented, and the 6
design-specific EPZ sizes established, it could be 7
site boundary, in which case Part 5A emergency plan --
8 major features of the Part 5 emergency plan will be 9
used to create a complete and integrated plan. The 10 same if the dose criteria is met at two-mile.
11 If the selected SMR design does not meet 12 the dose criteria, a new EPZ size will be developed 13 and a supporting emergency plan.
14 Okay, that concludes our presentation.
15 Thank you for your time. If there are any questions, 16 we will be happy to answer them.
17 CHAIRMAN KIRCHNER: Thank you.
18 Members, are there other questions?
19 Well, I should remind you that when you 20 have questions or comments from us individually that 21 doesn't necessarily represent the full committee.
22 And so with that, I will make a personal 23 observation. It seems to me that your plan B, if you 24 will, of the two-mile radius is prudent and a logical 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 backup to not being able to fit into your exclusion 1
area boundary -- or your site boundary. Sorry, I 2
misspoke.
3 How, given some of the examples that you 4
have worked, how confident are you on your local 5
weather patterns and other things such that you can, 6
with some margin, and this would be an interesting 7
thing to also ask the staff, to squeeze in your site 8
boundary these up to your multi-unit -- what's your 9
limit, 2,400 megawatts thermal?
10 MR. YOUNG: 2,420.
11 CHAIRMAN KIRCHNER: Yes. Do you have any 12 feeling for that or is that the purpose for the two-13 mile backup?
14 MR. YOUNG: So I believe the question --
15 CHAIRMAN KIRCHNER: Because it begs some 16 really detailed analysis over time of weather patterns 17 and such.
18 MR. YOUNG: Sure, the question revolves 19 around meteorology. We used Clinch River-specific 20 meteorological data that we collected in accordance 21 with the guidance, such as we did for the remainder of 22 the application, the end-dose analysis.
23 We have a lot of confidence in that data 24 because of some of the conservatisms we embedded into 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 our analysis, such as the 1,100 foot distance from 1
release boundary to site boundary that's been 2
mentioned and some of our other conservatisms in that 3
analysis.
4 CHAIRMAN KIRCHNER: So the weather is 5
going to accommodate your rather irregular shape, by 6
and large?
7 MR. YOUNG: Right. We --
8 CHAIRMAN KIRCHNER: Do you see where -- I 9
mean given, say it were one-mile instead of 1,100 feet 10 and it was a circle, not your boundary, then 11 variations in weather patterns and such are not as 12 crucial as trying to make sure it shoehorns into that 13 irregular shape of your actual site.
14 MR. STOUT: So we're pretty confident in 15 1,100 feet. The site is big enough that you have a 16 lot of flexibility on exactly where you put the 17 footprint within that, so that you have more than 18 1,100 feet.
19 And then we have the meteorology data in 20 all directions, and all conditions, all seasons. So 21 you know our analysis was built in the conservatisms 22 to give us confidence that 1,100 feet is adequate.
23 CHAIRMAN KIRCHNER: Okay. All right, 24 thank you.
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65 MEMBER REMPE: I'm sure I didn't -- if I 1
had done all my homework, I would know but did you do 2
like 30 years of site data or how many years of site 3
data did you consider?
4 MR. YOUNG: So we collected I believe 5
three years of on-site data that was utilized and we 6
did have data from the Clinch River Breeder Project 7
that we did use.
8 Scott, can you tell us how much data we 9
actually considered in the example analysis?
10 MR. WEBBER: Yes, so in the example 11 analysis, we used about representative years' worth of 12 data. It was I believe 2012 and '13, which was 13 considered to be well-representative of the 14 information that TVA had available for a larger 15 spread.
16 And the analysis also did dose assessment 17 for essentially every hour of that year so that there 18 was a release going in every direction and every 19 weather condition.
20 So what TVA was saying we have high 21 confidence that the analysis captured the most severe 22 meteorological conditions.
23 MEMBER MARCH-LEUBA: And the MA report is 24 the evidence for that year or is it 95 percent? Which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 is it?
1 MR. WEBBER: The numbers that were in the 2
slide are 50th percentile.
3 MEMBER MARCH-LEUBA: You said 80th 4
percentile?
5 MR. WEBBER: 50th percentile.
6 MEMBER MARCH-LEUBA: 50th.
7 MR. WEBBER: Yes. Mean and 95th were also 8
provided but he 50th percentile was shown.
9 MEMBER MARCH-LEUBA: For future already in 10 Knoxville you only get east wind when there is a 11 hurricane. And I'm sure you have even considered it 12 but there are hurricanes, I can assure you. So I 13 don't see how -- I mean for a real analysis, you need 14 to consider a hurricane. And you only get east wind 15 with a hurricane, which didn't happen in your three 16 years' of data.
17 MR. YOUNG: Sure. So we're many, many 18 miles inland, compared from where we see the really 19 high winds of met data. So from the averages of the 20 met data we collect, you know there are significant 21 meteorological events that get embedded into that.
22 MEMBER MARCH-LEUBA: But once every three, 23 four, or five years, you get 50 mile an hour coming 24 from the east. I know. I live there. And I know you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 didn't consider that.
1 MR. YOUNG: Well you know --
2 MR. WEBBER: I'd just like to make a point 3
that for perspectives of dose to site boundary, faster 4
winds are not necessarily more conservative. The wind 5
speed is too high. You can push the plume out so fast 6
that you have almost no exposure.
7 So I think in this instance, actually, a 8
hurricane would not be limiting.
9 CHAIRMAN KIRCHNER: Yes, it may be that an 10 inversion is more limiting for them.
11 MEMBER MARCH-LEUBA: I just wanted to 12 analyze. I think the worst and they entirely say I 13 don't want to do it.
14 CHAIRMAN KIRCHNER: Okay. At this point, 15 if there are no further questions of the applicant, 16 let us take a quick break and we can reset and start 17 at 2:30 on this clock. We are recessed.
18 (Whereupon, the above-entitled matter went 19 off the record at 2:19 p.m. and resumed at 2:31 p.m.)
20 MS. SUTTON: Good afternoon. My name is 21 Mallecia Sutton. I am one of the safety project 22 managers for the Clinch River Nuclear Site early site 23 permit application. With me today is Mr. Allen 24 Fetter, the other safety project manager. Also with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 me are the technical reviewers who will be presenting 1
the topic area, Bruce Musico, from the Division of 2
Preparedness and Response for Nuclear Security and 3
Incident Response, also known as NSIR, and Michelle 4
Hart from the Division of Licensing Site and 5
Environmental Analysis in the Office of New Reactors, 6
also known as NRO.
7 In the audience and on the conference 8
bridge are representatives from the Federal Emergency 9
Management Agency, FEMA, Technological Hazardous 10 Division. Also, representatives from Tennessee 11 Emergency Management Agency, TEMA, are on the 12 conference bridge, including TEMA Director Patrick 13 Sheehan.
14 TVA is asking approval for an early site 15 permit for the Clinch River Nuclear Site. As part of 16 the application, TVA described emergency planning 17 topics for approval. You have heard from TVA what 18 they submitted. The staff will be describing the 19 review of the emergency planning information.
20 Although the staff will be presenting its findings, 21 the licensing action will not be complete until the 22 Commission makes the decision whether to grant the 23 early site permit and the exemptions.
24 The appropriate plume exposure pathway 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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69 emergency planning zone size for this site will not be 1
determined until a combined license application that 2
references a specific small modular reactor design is 3
submitted for the Clinch River Nuclear Site. The 4
staff will be using several acronyms and abbreviations 5
in this presentation today. The presentation has a 6
list of definitions on the last two slides for your 7
reference.
8 Earlier today you heard the staff give a 9
detailed presentation of the rulemaking for emergency 10 planning for small modular reactors and other new 11 technologies currently in process. The ACRS should 12 recognize that TVA's Clinch River early site permit 13 application was submitted in May 2016. This was 14 before the staff started work on the small modular 15 reactor and other technologies rulemaking.
16 Accordingly, the application and review of the 17 application by the staff is based on current 18 regulations and guidance. The staff cannot review to 19 regulations or guidance that is not yet approved.
20 I will now briefly describe the early site 21 permit and the plan parameter envelope. An early site 22 permit is an approval of safety and environmental 23 suitability of a proposed site to support future 24 construction operation of the nuclear plant. In an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 early site permit application, the applicant doesn't 1
have to commit to building the reactor or specify 2
reactor design that would be built there. The early 3
site permit reserves both site safety and 4
environmental issues that are independent of the type 5
of reactor design. An early site permit does not 6
allow for construction and operation of a nuclear 7
plant.
8 Before a nuclear plant can be constructed 9
and operated at a site with an early site permit under 10 Part 52, a combined licensed application referencing 11 a specific reactor technology for this site must be 12 reviewed and approved by NRC. It is possible to 13 approve an early site permit site without a selected 14 reactor technology.
15 An early site permit plant parameter 16 envelope or PPE values are intended to bound a variety 17 of reactor technologies, rather than one specific 18 technology. The PPE values represent a surrogate 19 nuclear plant for the purpose of siting determination.
20 The PPE values are bound in criteria used by the staff 21 to determine the suitability of an early site permit 22 site for construction and operation of a nuclear 23 plant. The safety evaluation report evaluates the 24 site characteristics to include design basics, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 tornado, flood, and groundwater moisture, just to give 1
a few examples.
2 In the combined license application, when 3
a specific technology is identified, the PPE values 4
are compared to those of the selected technology. If 5
design parameters of the selected technology exceed 6
bounding early site permit PPE values, additional 7
reviews are conducted to ensure that the site remains 8
suitable from a safety and environmental standpoint 9
for construction and operation of its selected nuclear 10 plant technology. In addition, the site parameters 11 for the referenced certified design must be bounded by 12 the site characteristics in the early site permit.
13 In the development of a plant parameter 14 envelope, an applicant typically draws data from a 15 number of plant technologies under consideration to 16 construct a bounding envelope. It is important to 17 note that when issuing a permit, the NRC approves the 18 PPE rather than the specific technologies that a PPE 19 was drawn from. As such, any plant technology that 20 can demonstrate to be bounded by the plant parameter 21 envelope is suitable for use in a combined license 22 application.
23 The safety evaluation report for Chapter 24 13, Section 13.3 for the TVA Clinch River Nuclear Site 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 application addresses the plant's design features, 1
facilities, functions, and equipment necessary to a 2
logical emergency planning that must be considered in 3
an early site permit application that includes 4
proposed major features of the emergency plans.
5 TVA early site permit application includes 6
a methodology that, if approved in an early site 7
permit, could be used in future combined license 8
application referencing a specific small modular 9
reactor design and early site permit to determine the 10 appropriate site-specific plume exposure pathway 11 emergency planning zone size for the TVA Clinch River 12 Nuclear Site.
13 The submitted early site permit 14 application requests two sets of exemptions from the 15 current ten-mile plume exposure pathway emergency 16 planning zone requirements if certain conditions are 17 met: one set of 25 exemptions to support major 18 features emergency planning based on the plume 19 exposure pathway emergency planning zone at site 20 boundary and one set of two exemptions plume exposure 21 pathway emergency planning zone with a two-mile 22 radius.
23 If these sets of exemptions are approved 24 as part of the early site permit, it will be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 accompanied by permit conditions specifying the 1
circumstances under which these plans can be used in 2
the combined license application. The combined 3
licensed applicant would apply the methodology 4
approved in the early site permit to the design 5
selected for the combined license application in order 6
to determine whether the conditions for either of the 7
two sets of exemptions have been met.
8 Now, I turn the presentation over to Bruce 9
and Michelle to discuss the technical review.
10 Bruce.
11 MR. MUSICO: Thank you. Good afternoon.
12 My name is Bruce Musico. I am a Senior Emergency 13 Preparedness Specialist. I and Michelle Hart reviewed 14 the emergency planning information that TVA provide 15 din its ESP application. Slide 2, please.
16 You're going to see somewhat of an overlap 17 from our slides with TVAs because we cover common 18 areas.
19 The ESP application requested a review of 20 three key areas. First of all, the plume exposure 21 pathway emergency planning zone, or EPZ, sizing 22 methodology. And Michelle is going to address that 23 shortly.
24 Secondly, TVA requested approval of two 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 major features on-site emergency plans. The first 1
emergency plan assumed a site boundary plume exposure 2
pathway EPZ. The second emergency plan reflected an 3
approximately two-mile plume exposure pathway EPZ and 4
this particular major feature of emergency plan 5
included an evacuation time estimate.
6 And third, TVA requested approval of 25 7
exemption requests. And these are broken down into 8
two sets. One set was associated with the site 9
boundary emergency plan, major features emergency plan 10 and the second set was associated with the two-mile 11 plume exposure pathway EPZ.
12 The ESP proposes an exemption from the 13 current ten-mile plume exposure pathway EPZ, which is 14 currently in our regulations. The exemptions address 15 portions of our regulations, including 10 CFR 50.33, 16
.47, and Appendix E to 10 CFR Part 50. This is for 17 both on-site and off-site emergency planning. Next 18 slide, please.
19 This slide addresses the 10 CFR Part 52 20 licensing process in general. Upon issuance of an 21 early site permit, the applicant acquires approval 22 with conditions on: the plume exposure pathway EPZ 23 sizing methodology, the 25 requested exemptions, and 24 the two major features emergency plans, site boundary 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 and two-mile EPZs.
1 In the
- future, a
combined license 2
application that incorporates by reference the early 3
site permit will identify a chosen small modular 4
reactor or SMR technology for the Clinch River Nuclear 5
Site. At that time, the applicant must demonstrate 6
that the EPZ sizing methodology supports either the 7
site boundary or two-miles plume exposure pathway 8
emergency planning zone.
9 At that time, the COL applicant must also 10 provide a complete and integrated emergency plan. For 11 the two-mile plume exposure pathway EPZ, the COLA 12 applicant must provide an on-site emergency plan --
13 I'm sorry -- provide an on-site and off-site emergency 14 plan. For the site boundary plume exposure pathway 15 EPZ, the applicant must provide an on-site emergency 16 plan, which assumes that the site boundary, as defined 17 for EP purposes in the COLA, will be within the 18 applicant's owner-controlled area.
19 And in addition, the COL applicant must 20 address the identified COL action items, of which we 21 have identified 16, and the four permit conditions 22 that we've identified in the application.
23 MEMBER MARCH-LEUBA: So Bruce, could I 24 talk for a minute?
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76 MR. MUSICO: Yes.
1 MEMBER MARCH-LEUBA: The ESP -- you will 2
issue an SER or sign an ESP for them which has two 3
options, the two-mile or the site boundary.
4 MR. MUSICO: Site boundary, yes, that's 5
correct.
6 MEMBER MARCH-LEUBA: Is that correct? I 7
mean you approved both of them?
8 MR. MUSICO: We are approving both major 9
features emergency plan.
10 MEMBER CORRADINI: And they have to come 11 back with a chosen technology and show that they fit 12 into one of them.
13 MR. MUSICO: According to the methodology 14 that what we've also reviewed we'll have approved.
15 That's correct.
16 MEMBER CORRADINI: Okay.
17 MR. MUSICO: That's correct. This was a 18 first of a kind application in which we received two 19 emergency plans, rather than one with the application.
20 So it is kind of interesting in that respect.
21 MEMBER MARCH-LEUBA: And on that ESP, will 22 you have limitations about the methodology? Because 23 on their methodology, on their example, they have this 24 criteria for the frequency of 10 to the minus 6 and 10 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 to the minus 7, which are proposed. Will those become 1
part of the approval?
2 MR. MUSICO: The short answer is yes and 3
Michelle Hart is going to address that later.
4 The specific methodology is, however, 5
defined in Section 13.3 of the site safety analysis 6
report, which is Part 2 of the application, the ESP 7
application. So they have identified specifically 8
what the methodology is.
9 Next slide, please.
10 MEMBER BLEY: Quick question. They have 11 given you two on-site emergency plans. Are they 12 essentially identical?
13 MR. MUSICO: No.
14 MEMBER BLEY: Okay.
15 MR. MUSICO: They are very close. They 16 are very close.
17 MEMBER BLEY: Some will have connections 18 to off-site, I assume.
19 MR. MUSICO: Well, they're limited. First 20 of all, since they are major features emergency plan, 21 they are limited with respect to the extent that they 22 address our current emergency planning regulations and 23 guidance and they are permitted to do that. They can 24 pick and choose the limited aspects that they want to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 address at the ESP stage.
1 And they've provided us with two separate 2
plans. We've reviewed them separately but we also 3
compared them and, to a great extent, both plans are 4
virtually identical, except to the extent that one 5
plan reflects the site boundary of EPZ that they're 6
proposing. The other one reflects the approximate 7
two-mile EPZ that they're proposing and they also 8
reflect the exemptions that are specifically requested 9
for them.
10 For example, the site boundary major 11 features emergency plan reflects the 25 exemption 12 requests for that particular plant. For the two-mile 13 major features emergency plan, there's not that much 14 different than a ten-mile as far as the off-site 15 requirements. So they only have two exemption 16 requests that they are requesting for the two-mile 17 major features emergency plant.
18 So the fact that they were, to a great 19 extent, identical, made our job a little easier with 20 respect to approving them or reviewing them and 21 approving them, even though they are limited because 22 they are major features, but we also distinguished the 23 two plans, and you'll see that in the safety 24 evaluation, between language in one versus the other 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 in that one would address various aspects of say the 1
site boundary EPZ, where the other one would reflect 2
and describe various aspects of the two-mile plume 3
exposure pathway EPZ.
4 So there were differences and we called 5
those out specifically in the safety evaluation.
6 MEMBER BLEY: Thank you.
7 MR. MUSICO: All right, slide 4, please.
8 This slide reviews the staff's review of the specific 9
exemptions. The NRC reviewed the requested exemptions 10 pursuant to 10 CFR 50.12, which is entitled Specific 11 Exemptions.
12 Specifically, 50.12(a)(2) states that the 13 Commission will not consider granting an exemption 14 unless special circumstances are present. And then in 15 (ii), it states that special circumstances are present 16 whenever application of the regulation in the 17 particular circumstances would not serve the 18 underlying purpose of the rule or is not necessary to 19 achieve the underlying purpose of the rule.
20 Now for exemption requests there are a 21 number of special circumstances that are available to 22 them. This was one that they identified as applicable 23 to the application and the staff agree with that.
24 This is appropriate.
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80 Next slide, please. The underlying 1
purpose of 10 CFR 50.33, 50.47, and Appendix E to Part 2
50 is to, first of all, ensure that licensee maintain 3
effective on-site and off-site radiological emergency 4
response plans; secondly, to ensure that there is 5
reasonable assurance that adequate protective measures 6
can and will be taken in the event of a radiological 7
emergency; and third, establish a plume exposure and 8
ingestion pathway EPZ as appropriate.
9 And then the second bullet is the ESP 10 application serves to provide a basis for the 11 establishment in the COL application of either a site 12 boundary or two-mile plume exposure EPZ, and they can 13 pick which one, which maintains the same level of 14 protection, that is dose savings in the event of a 15 radiological emergency, in the environs of the Clinch 16 River Nuclear Site as that which exists in the basis 17 for the ten-mile plume exposure pathway EPZ.
18 So the safety level is maintained. It's 19 the same.
20 Next slide, please. Now, I'll turn it 21 over to Michelle.
22 MS. HART: Hi. I'm Michelle Hart. I'm in 23 the Office of New Reactors and I do look at siting 24 analysis as well as I looked at the analysis that they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 provided for the EPZ sizing methodology and criteria.
1 So TVA had stated that their plume 2
exposure pathway EPZ size methodology is based on 3
these following technical criteria. And I think they 4
described them before but, to remind you, they are the 5
plume exposure pathway EPZ should encompass those 6
areas in which project dose from design-basis 7
accidents could the EPA early phase protective action 8
guides; that the plume exposure pathway EPZ should 9
encompass those areas in which consequences of less 10 severe core melt accidents could exceed the EPA early 11 phase protective action guides; and plume exposure 12 pathway EPZ should be of sufficient size to provide 13 for substantial reduction in early health effects in 14 the event of more severe core melt accidents.
15 Next slide, please. This is slide 7. So 16 the features or the outline of the methodology that 17 they provided in their site safety analysis report, 18 the first step that you go through is the accident 19 scenario selection. So you would use the bounding 20 design-basis accident from the combined operating 21 license final safety analysis report Chapter 15. And 22 that is the analyses that you would use to look at the 23 safety of the plant and also to look at siting. And 24 so in addition to those accidents which do not have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 core failure, you would have an accident used to 1
assess your siting in the regulation and that, 2
generally in the past, for the large light water 3
reactors has been the LOCA with an intact containment 4
and using the tech spec release rate from the 5
containment. So you would use that same accident 6
that's used for the siting analysis.
7 And then you would go to use the combined 8
operating license application site-and design-9 specific probabilistic risk assessment to categorize 10 the severe accident scenarios.
11 So this PRA and the assessment of severe 12 accident scenarios should be all modes, include 13 internal and external events, would also include 14 applicable fuel handling and spent fuel pool 15 accidents, and would have multi-module considerations, 16 if those are applicable to the specific SMR design 17 that they choose.
18 You would start with all sequences with a 19 mean core damage frequency about 10 to the minus 8 per 20 reactor year and then you would further categorize 21 those scenarios, once you look at those, and determine 22 the scenarios from that.
23 So the first category, which when TVA was 24 talking that was the criterion B that they were 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 talking about, would be the more probable, less severe 1
core melt scenarios. And those are with a mean CDF 2
greater than 10 to the minus 6 per reactor year and 3
include intact containment.
4 And the third category, or what they would 5
call criterion C, is the less probable, more severe 6
core melt scenarios. And those are with a mean CDF 7
greater than 10 to the minus 7 per reactor year with 8
containment bypass or failure.
9 CHAIRMAN KIRCHNER: Michelle, now let me 10 ask a question. You specify a mean CDF. How much 11 uncertainty do you consider beyond just a mean CDF?
12 I mean where I'm going with this, I've 13 raised this point before, is that for the less mature 14 concepts, let me say it that way, more still on paper, 15 not any real operating experience, how do you assess 16 the PRA and the uncertainties with that? Because I 17 suspect that most design teams will come in with very 18 low mean CDF numbers and then say well, I meet your 19 criteria on this slide and we don't have to consider 20 severe accidents.
21 MS. HART: Right.
22 CHAIRMAN KIRCHNER: How prudent is that 23 and how are you going to interject some, how should I 24 say it, regulatory certainty? Because that's one of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 the things you're trying to do in all of your 1
processes.
2 How do you see the staff approaching this?
3 MS. HART: Well how -- I mean certainly, 4
it remains to be seen what will actually go through 5
when we do the implementation, when the applicant goes 6
through the implementation and when we review the 7
implementation of it.
8 And so it does, as you are rightly saying, 9
it does depend on the maturity of the specific design 10 that they've chosen and the quality of their PRA, the 11 acceptability of their PRA for this purpose. And we 12 would review that in conjunction with the PRA 13 reviewers in the Office of New Reactors to determine 14 the usability of the information that they gave us.
15 So there's no specific -- I don't think --
16 I think there is room for us to make that 17 determination at the time of implementation. We're 18 trying to cut off, trying to make the appropriate 19 decisions at that time.
20 Right now, we're saying that this looks 21 reasonable to categorize your events using your PRA 22 and mean seems to be a reasonable bound to use for 23 that purpose, for the emergency planning purposes.
24 MEMBER BLEY: Well there are some things 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 you might want to consider and that is, at the time of 1
COLA, at least from what we've seen on other designs 2
that have come through, they typically have no 3
operating experience. They might not -- they don't 4
have to have all their emergency procedures in place.
5 Those have to be in place before startup. They don't 6
have real operators yet and they haven't had operators 7
through training. So there is a lot of things not 8
there.
9 On the site-specific side of it, by COLA, 10 you should have a specific site but they typically 11 don't upgrade their PRA to account for that, except 12 with some purely loose bounding calculations that say 13 yes, we meet the envelope of what was assumed in the 14 design cert PRA. So those kind of things you need to 15 give some kind of weight to along the lines of Walt 16 talking, account for them as possibly giving you 17 higher results than the existing work.
18 MS. HART: Right. I think it's we do 19 recognize that the PRA for the design and the PRA use 20 for the combined operating license, in general, may 21 not include all the information or may not be the 22 exact same quality that you would need to do this 23 assessment. And so there may be some portions of it 24 that they have to describe to us why that's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 appropriate. And I think that that's -- it's a 1
discussion that we've been having with the licensing 2
modernization project also about the applicability of 3
the PRA and how you show that that's appropriate to 4
use for the purposes --
5 MEMBER BLEY: Well, I'm glad they're 6
talking to you.
7 MS. HART: Yes. So there is some 8
discussion along those lines that what you -- what we 9
have said in some of our guidance about what is 10 required for a PRA, for the design certification 11 especially, is that it's appropriate so that we don't 12 have to do a detailed analysis of -- or a detailed 13 review of their PRA. And so there may be some further 14 step that has to come here, depending on the design 15 and what they say in the PRA.
16 So a lot of this, unfortunately at this 17 stage, we have to kind of rely on how we would 18 implement it later. And I know it may not seem like 19 it gives enough information or enough detailed 20 information but I think you know this is a first of a 21 kind thing and if TVA does choose to go forward, if 22 they get their early site permit and then just decide 23 to go forward with the COL, we've been discussing this 24 with them -- not maybe necessarily this specific topic 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 but the idea of this analysis. And they helped 1
develop this analysis. They based it off of the 2
information in NUREG-0396. And so, generally, they're 3
trying to recreate what was done in NUREG-0396 for 4
their specific site at some future point, when they 5
specific design.
6 MEMBER BLEY: Yes, I don't have any real 7
qualms with the general approach but you will be the 8
first specific one looking at this, it appears to me.
9 So some kind of compensation for the things that 10 aren't there and can't be there yet ought to be on the 11 table.
12 MS. HART: Right and I think uncertainty 13 analysis is very important and it's something that we 14 will review carefully, the uncertainty, when we get to 15 the implementation stage.
16 MEMBER BLEY: Yes, it's not just 17 parametric uncertainty here. It's uncertainty in 18 things that aren't there that you can actually see 19 that aren't there yet.
20 MS. HART: That's correct.
21 Okay. So then of course, after you 22 categorize your events and select your scenarios, you 23 may group them, as you sometimes do in PRA but you 24 would determine source releases to the atmosphere for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 each of the categories, the design-basis accident, 1
more severe, less severe, you know if there are more 2
severe accidents. You would calculate the dose 3
consequences at distance from the plant and then you 4
would determine the plume exposure pathway, EPZ size 5
that would meet the dose-based criteria to be used in 6
further determination of the actual emergency planning 7
zone.
8 Next slide, please. So slide 8, so the 9
dose-based EPZ size criteria is a dose to an 10 individual from exposure to the airborne plume during 11 its passage and also to groundshine, using average 12 atmospheric dispersion characteristics for the site.
13 This is very similar to the way that it was done in 14 NUREG-0396 using average atmospheric dispersion 15 characteristics was one of the features that they 16 used.
17 And for the design-basis accident and for 18 the more severe less -- more probable, less severe 19 accidents, the dose criterions is one rem total 20 effective dose equivalent from a 96-hour exposure.
21 And that one rem over 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> is at the lower end of 22 the dose range for the EPA PAG for early phase 23 protective actions, for example, evacuation and 24 sheltering. And this is to verify that dose 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 consequences do not exceed the EPA PAG beyond the site 1
boundary, which is within the owner-controlled area, 2
for the two-mile plume exposure pathway EPZ.
3 For that last category, the less probable, 4
more severe accidents, you would calculate the 5
distance at which the conditional probability to 6
exceed 200 rem whole body from a 24-hour exposure 7
would exceed 10 to the minus 3 per reactor year. And 8
the 200 rem whole body is an acute dose at which 9
radiation-induced early health effects may begin to be 10 noted. For example, one of those effects is nausea.
11 And this is to verify that the plume exposure pathway 12 EPZ supports substantial reduction in early health 13 effects.
14 Next slide, please. So for the staff to 15 review the plume exposure pathway EPZ size methodology 16 that TVA provided, we did compare TVA's methodology 17 and the dose criteria to the study used as the 18 technical basis for the current 10-mile plume exposure 19 pathway EPZ requirement. And that study was NUREG-20 0396.
21 And the features of TVA's methodology are 22 consistent with NUREG-0396, in that it considered a 23 range of accidents. It performed accident consequence 24 analyses, and it determined an area outside of which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 early protective actions are not likely to be 1
necessary to protect the public from radiological 2
releases.
3 And, therefore, the staff concludes that 4
the applicant's proposed methodology is reasonable and 5
consistent with the analyses that form the technical 6
basis for the current regulatory requirement of a 7
plume exposure pathway EPZ of about ten miles in 8
radius.
9 MEMBER BLEY: If these are based on PRA, 10 do you have a sense for what not likely means, 11 quantitatively?
12 MS. HART: Quantitatively, there is 13 nothing in NUREG-0396 that would give you a clue to 14 that. I mean it did use NUREG -- I mean it used WASH-15 1400 as its basis.
16 MEMBER BLEY: WASH-1400, which you could 17 look at.
18 MS. HART: Yes. Yes, and so in general, 19 I think in general we talk a lot about the cutoff. I 20 know that that was a discussion this morning, the 21 cutoff for what the frequency of the events or the 22 sequences should be that you should evaluate. And 10 23 to the minus 8, 10 to the minus 7, 10 to the minus 6, 24 those all have been numbers that have been floating 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 around. And as TVA had stated, the specifics for like 1
the 10 to the minus 6 per reactor year for the more 2
probable accidents in that category has been discussed 3
in several different areas. In industry, they have 4
used that number a lot.
5 Ten to the minus seven, maybe not quite as 6
often, has been discussed but it seems reasonable, at 7
this point. I think it's when we get to the 8
implementation phase, if there is some special case or 9
there is something like we were talking about 10 NuScale's PRA, their design PRA doesn't have anything 11 in that category of 10 to the minus 6 or higher but do 12 they have a backstop that they would provide some 13 other analysis to bound any potential severe 14 accidents.
15 So I think it's a reasonable good bounding 16 assessment.
17 MEMBER MARCH-LEUBA: When in slide 7 when 18 you say 10 to the minus 7 per reactor year, you mean 19 module or multi-module year?
20 MS. HART: Well that is actually the quote 21 from TVA's methodology. It does depend on the design 22 that is used. And so I think we will definitely look 23 at that. I think in general, though, we would say it 24 is equivalent to a module year, unless there is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 something in the design that would show that there 1
would be multi-module events that would occur.
2 MEMBER REMPE: So when you reviewed their 3
analyses, what made you decide it was acceptable to 4
use one year of site-specific meteorological data from 5
TVA and use a 50 percent value?
6 MS. HART: I will be discussing the 7
example calculation and it's just an example to 8
evaluate the usability of the methodology. I did not 9
use their analysis to approve anything, per se. You 10 know I am not approving an EPZ size at this time.
11 MEMBER REMPE: Okay.
12 MS. HART: So it's just to say you know 13 how they used the methodology.
14 But the methodology does include the 15 feature that they would use average meteorological 16 conditions for the site and that was something that 17 was also done in NUREG-0396. So I think when you're 18 looking -- when you're doing projected analyses for 19 licensing purposes, in general, you want to use -- for 20 these purposes you want it to be a little bit more 21 representative than bounding in this case.
22 MEMBER REMPE: And is one year enough to 23 decide that something is representative?
24 MS. HART: That I can't say for sure.
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93 We'll look at the implementation. I think we will 1
look at multiple years of data because they are 2
required to provide multiple years of data. And so 3
we'll determine if the information they are using in 4
their analyses is representative of the site, whether 5
it is that specific year or not.
6 MEMBER REMPE: Okay, thank you.
7 MS. HART: Okay, next slide, please, so 8
slide 10. In their request for the exemptions -- so 9
now we've moved on from the methodology to the 10 exemption requests -- they did describe that there are 11 features of small modular reactors that support the 12 exemption requests. And TVA stated that special 13 circumstances exist at the Clinch River Nuclear Site, 14 due to the anticipated enhanced safety features of the 15 SMR designs under consideration. And those things are 16 such as: smaller radionuclide inventories and source 17 terms; projected accident progression rates are 18 anticipated to be slower; that various design features 19 are expected to eliminate several historically-20 considered design-basis events, for example, you 21 wouldn't have a lock rotor accident if you don't have 22 reactor coolant pumps; and advanced design features 23 would minimize accident consequences.
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94 be confirmed when they come in for a specific design 1
or just the results of the calculation?
2 MS. HART: Well that is -- I think the 3
results of the calculation are what tell you the 4
emergency planning zone size. That would be the 5
actual proof of that.
6 I think for the purposes of requesting the 7
exemptions, they had to make general statements about 8
SMR designs and why they thought they were special.
9 MEMBER MARCH-LEUBA: For the record, I 10 don't agree with the point number one, a smaller 11 inventory. Per megawatt, because their refueling is 12 longer, it is not accumulating only two years of 13 inventory. It will accumulate ten years of inventory.
14 So the inventory is larger per megawatt.
15 MS. HART: Yes, some designs, that's true.
16 MEMBER MARCH-LEUBA: But it has to be 17 plant-specific.
18 MS. HART: I think in general that idea is 19 just that they are at smaller power in the first 20 place.
21 MEMBER MARCH-LEUBA: Right.
22 MS. HART: So the stuff in the core is 23 less --
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95 my module, then you take advantage of the lower power.
1 MS. HART: Yes.
2 MEMBER MARCH-LEUBA: But specifically 3
NuScale, if you are going to have an accident that 4
melts the core, it is going to be an external event 5
with a high probability of killing all 12 of them.
6 So the multi-module thing has to be 7
addressed properly.
8 MS. HART: Multi-module accidents do need 9
to be considered and that would be in your source 10 terms, if that is something that is appropriate to the 11 design that's been chosen.
12 MEMBER MARCH-LEUBA: If you look at those 13 sequences, to damage the core, it has to be an 14 external event and it will hit all of it.
15 MS. HART: I don't know if that is true.
16 That is something to discuss with NuScale.
17 MEMBER BLEY: And we don't know what they 18 are going to plan.
19 MS. HART: For the TVA Site, we do not 20 know which design they are going to choose. It may 21 not be NuScale. You never know.
22 Next slide, please. So, as you expressed 23 some concern about the statements that were made, I 24 also had some questions about them. So I asked them 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 to provide some information about what they mean by 1
these things.
2 And so in my request for additional 3
information, I did ask for specific technical support 4
related to those statements and a comparison to large 5
light water reactors. And in their response, TVA did 6
provide tables with several parameters, comparing the 7
smallest and largest SMRs, by that I mean based on 8
unit-rated thermal power, in the Clinch River Nuclear 9
early site permit application plant parameter envelope 10 to the large and medium currently operating 11 pressurized water reactors, one example of each one of 12 those, and the AP1000, as well.
13 And some examples of the parameters that 14 they had comparisons was the internal events CDF and 15 large release frequency for the designs or for the 16 operating plants; the source term total activity -- so 17 that was just a total curie amount within the core of 18 each of those designs; the primary coolant liquid mass 19 to power ratio; and some severe accident progression 20 information, you know the length of the releases, the 21 timing of the releases, things like that. And there 22 were some additional parameters and I didn't describe 23 them all here but they are in the response to the 24 first RAI.
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97 And in general, they showed that the SMRs 1
do have better characteristics, if you look at these 2
specific parameters.
3 Next slide, please. So I also asked them 4
to give -- them being TVA -- to give me a 5
demonstration that the proposed plume exposure pathway 6
size criteria could be met at a given EPZ boundary 7
distance for potential reactor facilities that would 8
be represented by the surrogate design in the plant 9
parameter envelope.
10 And as you know, the plant parameter 11 envelope had several different designs that were used 12 to develop this envelope for the plant, surrogate 13 plant.
14 So in response to this request for 15 additional information, TVA provided an example 16 analysis using design information for a specific SMR 17 design -- as they described earlier, it was NuScale --
18 as input to their plume exposure pathway EPZ size 19 methodology.
20 And the example analysis did show that the 21 design could support a site boundary plume exposure 22 pathway EPZ, however, it was not intended, either by 23 TVA nor interpreted that way by the staff, to prove 24 the case for the early site permit application to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 justify a specific plume exposure pathway EPZ size.
1 And that is because it was based on preliminary design 2
information for an SMR at the lower end of the rate of 3
power that is part of the basis for the Clinch River 4
Nuclear Site ESP plant parameter envelope.
5 It used internal events design PRA only.
6 It did not include external events. And it did not do 7
a detailed uncertainly analysis. And the most 8
important reason, which of course I didn't put on the 9
slide, is that they are not asking for a specific EPZ 10 size at this time.
11 Next slide, please. So as TVA had 12 described, for use of the exemptions themselves in the 13 combined operating license, they did develop a non-14 design-specific accident release source term that 15 would meet the plume exposure pathway EPZ size 16 criteria to be used as plant parameters. And those 17 are listed in our safety evaluation report Table 13.3-18
- 1. It's the same idea as a plant parameter envelope 19 design-basis accident source term and it's used to 20 envelope an unknown design.
21 And this non-design-specific accident 22 release source term is reference in Permit Condition 23 1 for adoption of the EP exemptions by a COL that 24 references the ESP.
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99 This non-design-specific accident release 1
source term is an isotopic total release activity over 2
96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, which results in a total effective dose 3
equivalent of around 0.9 rem at the site boundary.
4 And as TVA had described earlier, it was based on 5
three core melt intact containment accidents, two were 6
design-basis accidents and one was a severe accidents, 7
from two different SMRs from the NuScale design and 8
also from the design that they used as the basis for 9
their early site permit siting analysis.
10 And they used the maximum activity release 11 for a specific nuclide from any of the three accidents 12 over a specific dose averaging period. They assumed 13 that would be the maximum release activity. And they 14 lined up the start of the release. Each time equals 15 zero at the same time of the release. So there was no 16
-- like if one started releasing at five hours and the 17 other one started releasing at ten hours, they moved 18 those both to the same starting period. And by dose 19 averaging period I mean those dose averaging periods 20 that we used in meteorological analysis, the zero to 21 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, 8 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and 24 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
22 Once they determined the maximum release 23 for each radionuclide and the different 24 radionuclides may have a release from a different 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 plant or a different accident; they were all a 1
composite together -- they added a 25 percent margin.
2 And then they did a back calculation to ensure that 3
they fit within the dose criteria at the site 4
boundary. And there was an additional adjustment to 5
some of those values. So there was at least a 25 6
percent margin over top of the maximum release for any 7
of those three accidents that was included in this 8
non-design-specific accident release source term.
9 Next slide, please. So as I said, this 10 was referenced in Permit Condition 1. And in Permit 11 Condition 1, COL applicant referencing the ESP, if 12 approved, would perform an analysis using the plume 13 exposure pathway EPZ size methodology with site-and 14 design-specific input to justify the plume exposure 15 EPZ size for the combined operating license 16 application.
17 In addition to the output of the EPZ size 18 basis, it would also include the source term releases 19 to the atmosphere. So an outcome of that analysis 20 would give you what was released to the atmosphere, 21 isotopic activity over time.
22 You would compare that release 23 characteristics to the environment to the SER Table 24 13.3-1 non-design-specific plant parameter source 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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101 term. And then you fit within -- if all of their 1
releases were less than what's in that table that was 2
developed in the ESP, then the COL applicant can adopt 3
the emergency planning exemptions.
4 And so that table, if you've looked at it 5
is a four-day total activity release to the atmosphere 6
for 71 separate isotopes.
7 So do you have any questions about that?
8 CHAIRMAN KIRCHNER: Yes, please. I was 9
just going back to the inventory is based on the 10 largest thermal unit that they were --
11 MS. HART: It included the largest thermal 12 unit as one of the accidents.
13 CHAIRMAN KIRCHNER: One of the accidents.
14 MS. HART: Yes, and the other one was the 15 NuScale examples that they provided in the RAI 16 response.
17 MEMBER REMPE: So just to make sure about 18 this four-day question that I keep harping about, if 19 they finally come in, you will be -- there is some 20 clue to tell people hey, I'm not just going to look at 21 from the first of the release, I'm going to look at 22 the most severe time.
23 MS.
HART:
We'll look at the 24 characteristics of the entire scenario to determine if 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 they've evaluated the appropriate release 1
characteristics.
2 MEMBER REMPE: Thank you.
3 MS. HART: Okay, next slide, please.
4 So as a reminder, we've been talking about 5
the plant parameter envelope. It does include the 6
four different SMR designs, preliminary designs, the 7
mPower and NuScale, Holtec SMR, and Westinghouse SMR.
8 And the plant parameter envelope, itself, you could 9
include a different reactor design in the COLA that 10 falls within the following PPE information range and 11 that's two or more SMRs with a maximum 800 megawatts 12 thermal for a single unit and a combined site capacity 13 not to exceed 2,420 megawatts thermal or 800 megawatts 14 electric.
15 So next slide, please and I will turn it 16 back over to Bruce.
17 CHAIRMAN KIRCHNER: Michelle?
18 MS. HART: Oh, I'm sorry.
19 CHAIRMAN KIRCHNER: I was just thinking 20 about Table 13.3-1 and the condition, permit 21 condition. Different reactor vendors might have 22 different accident sequences and might get their 23 release from different isotopes. Do you see where I'm 24 going?
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103 MS. HART: Yes.
1 CHAIRMAN KIRCHNER: So how does this fit 2
back to making that a condition that they live within 3
all of these four-day activity curie limits? Does 4
that always equate to still being below one rem at the 5
6 MS. HART: Right. So --
7 CHAIRMAN KIRCHNER: Do you see what I'm 8
going with?
9 MS. HART: Right, I see what you're 10 saying. So one of the reasons that this is a four-day 11 total integrated dose, so if there were different 12 characteristics to the rate of release, that's not 13 going to be a problem for them. But if there are 14 different isotopes that are included in this envelope 15 or if there is one isotope that is just really 16 different for a new design, it may not fit within this 17 table.
18 So, therefore, they don't automatically 19 get to use the exemptions but that doesn't mean that 20 they can't have a site boundary, a plume exposure 21 pathway EPZ because their analysis would prove that.
22 CHAIRMAN KIRCHNER: Okay.
23 MS. HART: This table is really only to 24 tell you that this is the information that we had in-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 house at the time that we evaluated their exemption 1
requests. And so these are the conditions on the 2
exemption, as we understand it now. So we're not 3
trying to bound everything.
4 CHAIRMAN KIRCHNER: But when it really 5
came to an actual COLA with an actual plant, and if 6
something --
7 MS. HART: They could take a variance.
8 CHAIRMAN KIRCHNER: -- say that -- I'll 9
pick something like xenon-133, which is a biggie here.
10 MS. HART: Right.
11 CHAIRMAN KIRCHNER: We're a little higher, 12 a little lower. Lower is okay but I mean say it were 13 higher, you would just analyze that as a variance.
14 I'm assuming it's not off the charts 15 different but it would be --
16 MS. HART: Right. Right and I think the 17 implementation is still to be seen as well. I mean a 18 permit condition should be, as the lawyers have told 19 us, it should be ministerial. So you don't assess the 20 information. You just verify that the information has 21 been met --
22 CHAIRMAN KIRCHNER: Okay, all right.
23 MS. HART: -- if that makes sense. But 24 they still may be able to justify a site boundary EPZ.
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105 It's just they may have to take a variance or --
1 CHAIRMAN KIRCHNER: Yes, they may, for 2
whatever reason, fuel choices or something, have a 3
different mix come out of their accident scenarios.
4 MS. HART: Right.
5 CHAIRMAN KIRCHNER: Okay.
6 MS. HART: Right.
7 Any additional questions on that?
8 Okay, so I will turn the presentation back 9
over to Bruce.
10 MR. MUSICO: Thank you. Slide 16, please.
11 This slide merely identifies some of the 12 key standards and guidance that the staff used to 13 perform its evaluation. There are additional 14 requirements and guidance documents that the staff 15 also used and those are identified within the safety 16 evaluation but these are the key ones.
17 Next slide, please. This slide deals with 18 the Federal Emergency Management Agency, FEMA, and our 19 consultation with them.
20 The NRC performed its review in 21 consultation with FEMA, pursuant to the FEMA-NRC 22 Memorandum of Understanding. FEMA's review was 23 limited in this case because, first of all, the ESP 24 application did not include any off-site emergency 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 plans and, in addition, the major features plans only 1
addressed a limited aspect of the on-site emergency 2
planning features.
3 In FEMA's January 24, 2018 letter, FEMA 4
stated that, working with TEMA, and that's the 5
Tennessee Emergency Management Agency, FEMA did not 6
identify physical characteristics of the proposed site 7
that could pose a significant impediment to the 8
development of emergency plans, including evacuation 9
from the two-mile emergency planning zone.
10 In addition, the boundary established for 11 the proposed two-mile plume exposure pathway EPZ was 12 established relative to local emergency response needs 13 and capabilities, as they are affected by conditions 14 as demography, topography, land characteristics, 15 access routes, and jurisdictional boundaries.
16 And at this time, FEMA's finding does not 17 endorse or determine the adequacy of a proposed two-18 mile plume exposure pathway EPZ for the site if 19 proposed during the licensing process. And these are 20 statements directly out of their letter.
21 In FEMA's June 12, 2017 letter, FEMA 22 further stated that it did not review or analyze the 23 feasibility and assumptions for the site boundary 24 emergency planning zone but, if requested in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 future, would provide comments and recommendations to 1
the NRC.
2 CHAIRMAN KIRCHNER: May I make an 3
observation here, Bruce?
4 If I remember correctly the rules under 5
Part 50 and Part 52, the applicant is not required to 6
have this at this ESP juncture. Is that correct?
7 MR. MUSICO: Not required to have what?
8 CHAIRMAN KIRCHNER: The way -- the fully-9 developed emergency plans.
10 MR. MUSICO: No. No, they are permitted 11 to come in with a major features emergency plan with 12 limitations.
13 CHAIRMAN KIRCHNER: Right.
14 MR. MUSICO: However, they are required to 15 come in and show that there are no physical 16 characteristics that could pose a
significant 17 impediment to development of an emergency plan.
18 CHAIRMAN KIRCHNER: Yes.
19 MR. MUSICO: And also with respect to --
20 let me see -- the boundary established for the 21 proposed two-mile plume exposure pathway EPZ, they 22 looked at that as well. And that was defined in the 23 evacuation time estimate.
24 CHAIRMAN KIRCHNER: Right.
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108 MR. MUSICO: Now, if the applicant chose 1
not to submit an evacuation time estimate at this 2
time, it would be very limited with respect to what we 3
could evaluate and what finality they would get at 4
this time. So again, that is one of the advantages of 5
the major features emergency plan that they could come 6
in with and that they could pick and choose what 7
aspects of emergency planning they choose to address.
8 And it was limited, in this case, but it included 9
various aspects that they reflected and we reviewed.
10 CHAIRMAN KIRCHNER: The reason I brought 11 it up is I'm not an expert from alpha to omega on all 12 the details. But the implication from the slide, it 13 just it's like negative you know but actually I think 14 the applicant has met all of your requirements --
15 MR. MUSICO: Well I -- I'm sorry.
16 CHAIRMAN KIRCHNER: -- or in Part 52 for 17 the ESP.
18 MR. MUSICO: I would characterize the 19 slide as positive in that --
20 CHAIRMAN KIRCHNER: Okay. All right.
21 MR. MUSICO: It doesn't say no.
22 CHAIRMAN KIRCHNER: It only addressed 23 limited features and so on but --
24 MR. MUSICO: An unbiased opinion here but 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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109 what the slide represents is that there were two key 1
aspects that we are required to consult with FEMA. If 2
you look at the regulations from 10 CFR Part 52, there 3
are two areas where it specifically directs the staff 4
to make determinations in consultation with FEMA.
5 CHAIRMAN KIRCHNER: Right.
6 MR. MUSICO: And that's reflected in their 7
letter.
8 CHAIRMAN KIRCHNER: Yes.
9 MR. MUSICO: What the letter does reflect, 10 also, is that there are limitations that FEMA has 11 identified that they would still look at in a further 12 licensing process and they are not approving an 13 emergency planning zone at this time.
14 So I think it's an appropriate balance in 15 the response, where they did respond to the two in 16 consultation with requirements that are required for 17 us to work with them on in an early site permit but, 18 also, in addition, reflected an area of concern that 19 they had going forward in the licensing process.
20 CHAIRMAN KIRCHNER: Yes, that's fine.
21 It's just that when you went through the list, as you 22 did -- I'm sure this is quite accurate -- I just come 23 away with a feeling like they maybe they didn't do 24 something correctly. But as far as I can tell, the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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110 read from this slide is that they've done everything 1
that's needed at this point.
2 MR. MUSICO: That's correct. That's 3
correct, they did.
4 CHAIRMAN KIRCHNER: Okay, thank you.
5 MR. MUSICO: So we satisfied the two in 6
consultation with requirements in the regulations --
7 CHAIRMAN KIRCHNER: Right, that's what I 8
thought. Okay, thank you.
9 MR. MUSICO: -- as well as identifying the 10 path going forward and their concerns going forward.
11 MEMBER BLEY: So you weren't approving an 12 EPZ at this time. You're approving an approach to 13 define.
14 MR. MUSICO: We are not approving an EPZ 15 at this time, a plume exposure pathway EPZ at this 16 time. We are approving a methodology for determining 17 dose that would be used to determine which of the two 18 major features emergency plans they can utilize in the 19 COLA application.
20 We are approving the two major features 21 emergency plans, which are reflected by the site 22 boundary EPZ and the two-mile EPZ.
23 MEMBER BLEY: Right.
24 MR. MUSICO: But in approving those, as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 they relate and are reflected in the respective major 1
features emergency plan, does not approve those for 2
the site because that choice will be made at the COL 3
application stage.
4 MEMBER BLEY: Right.
5 MR. MUSICO: And at that stage, let's say 6
they picked the two-mile plume exposure pathway EPZ in 7
the COLA, while they get the benefit of finality and 8
the approval of the two-mile major features plan that 9
we approved, it is a major feature plan. It is 10 limited aspects of emergency planning. At that time, 11 they do have to come in with a complete and integrated 12 emergency plan.
13 So there is a delta between the limited 14 aspect of EP that we approved now, versus what the 15 final, all the EP requirements that they have to show 16 in the COLA.
17 CHAIRMAN KIRCHNER: Right.
18 MEMBER BLEY: When we get to the COLA 19 stage, before you approve the COLA, does FEMA have to 20 agree? Do they have to approve it or do they just 21 have to not -- you just have to consult with them and 22 they shouldn't have any major objections.
23 MR. MUSICO: Well, it depends. It depends 24 on which -- naturally, we would consult with them on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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112 the application, whatever came in. But as far as the 1
requirement for any approval from them, it depends on 2
which major features emergency plan is chosen by TVA.
3 And I'll discuss that in the upcoming slide.
4 MEMBER BLEY: Okay.
5 MR. MUSICO: Next slide, please, it would 6
be slide 18.
7 In the safety evaluation, the staff 8
identified 16 COL action items and we identified four 9
permit conditions. This merely distinguishes between 10 what a COL action item is and what a permit condition 11 is.
12 For the COL action items, what they do is 13 they track information that is needed before granting 14 a COL but is not required in the early site permit 15 application. They reflect the SMR design that may be 16 identified in the COLA and they require NRC 17 evaluation, further analysis, as part of the COL 18 application review.
19 What these primarily come from is the fact 20
-- this is similar to the PSEG site application that 21 we reviewed, which came in with a plant parameter 22 envelope, where they didn't identify specific reactor 23 technology. So there are certain areas that deal with 24 emergency planning that are reactor-specific. And so 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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113 for those particular areas, that information just 1
isn't available yet because they haven't identified 2
the reactor.
3 So the TVA identified a number of areas 4
where this information is not available now. It will 5
be identified and addressed at the COL application 6
and, at that stage, we will review it in detail. And 7
we captured that as COL action items.
8 In short, COL action items request 9
information that they choose not to provide or is not 10 available at this time but will require a subsequent 11 analysis in the COL application. So we will be doing 12 a detailed analysis on that information at that time.
13 In contrast, we identified four permit 14 conditions and Michelle mentioned for Permit Condition 15 1 ministerial aspect of confirmation of whether they 16 met the permit conditions. We identified four, one of 17 which was Permit Condition 1 that Michelle addressed, 18 and these all have that characteristic.
19 An ESP is granted subject to permit 20 conditions, which address required detailed 21 information that is not yet known but will be 22 available in the COLA and subject to NRC confirmation.
23 Next slide, please. The next two slides, 24 19 and 20, merely list the 16 COL action items. And 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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114 I won't read through those. You can read through them 1
yourself. But the details associated with why these 2
were identified and how the staff recommended that 3
there be COL action items, this is detailed within the 4
safety evaluation. You can look for detail in the SE.
5 Slide 21. Slide 21 lists the four permit 6
conditions that the staff identified and also we 7
identified one confirmatory item, which reflected 8
TVA's withdrawal of one of their exemption requests.
9 And this will be closed out when we receive the ESP 10 Application Revision 2. So this is just a minor 11 issue, as far as a confirmation in Rev. 2 that they 12 actually withdrew it in Rev. 2.
13 Next slide, please. This deals with the 14 COL application, the combined license application. n 15 the COL application, the COL applicant will identify 16 an SMR technology which must meet the plume exposure 17 pathway EPZ sizing methodology approved in the early 18 site permit for either the site boundary or two-mile 19 plume exposure pathway EPZ, or if they choose, they 20 may proposed a new emergency plan.
21 In other words, if they come in and they 22 show that one of the technologies they've chosen does 23 not -- using the methodology that we've approved in 24 the ESP does not meet either the site boundary or two-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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115 mile plume exposure pathway EPZ, then they would lose 1
the benefit of the finality associated with the 2
approved two major features emergency plan. And they 3
would have to come in at the COL time with a complete 4
and integrated emergency plan, a completely new 5
complete and integrated emergency plan with no benefit 6
from the preapproval and finality for the site 7
boundary or two-mile plan that we've reviewed.
8 If the two-mile plume exposure pathway EPZ 9
is selected and justified, the NRC will request that 10 FEMA review the off-site emergency plans -- and I 11 think that addresses your earlier question -- because 12 at that time, there would be a requirement for a 13 complete and integrated emergency plan to have to 14 submit off-site emergency plans. And that's where 15 FEMA would come in, where they would review and 16 approve, as part of our consultation, the off-site 17 emergency plans.
18 If, however, the site boundary plume 19 exposure pathway EPZ is selected and justified using 20 the methodology, no formal FEMA approval of the off-21 site radiological plans are required because there 22 would not be any off-site radiological emergency plans 23 submitted in the COLA.
24 The COL applicant will still need, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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116 however, to address requirements to communicate and 1
coordinate with off-site support organizations and 2
agencies.
3 Yes?
4 CHAIRMAN KIRCHNER: Let me throw a 5
hypothetical case out there. So invariably, we've 6
seen this with the existing fleet. They always want 7
to uprate the power, get more out of their investment.
8 So what happens now if TVA -- you grant 9
these exemptions, et
- cetera, and with these 10 limitations, permit conditions, et cetera -- but they 11 think this over for a bit and they say well, you know, 12 we really ought to get a few more hundred megawatts 13 electric out of this and they'll push up the thermal 14 rating? Are you still then in a position, 15 notwithstanding what we heard this morning -- I don't 16 know if you were there on the rulemaking --
17 MR. MUSICO: I was there.
18 CHAIRMAN KIRCHNER: -- and the future of 19 that rulemaking, if they came in and said well, gee, 20 I think we can't quite shoehorn it into our current 21 site boundary and maybe we need a little cushion, so 22 we want to do it at three miles, what would happen 23 then? Would you -- notwithstanding the rulemaking 24 that should allow that flexibility, would you then 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 just reopen the case for that contingency?
1 MR. MUSICO: Well, yes. Yes, we would.
2 CHAIRMAN KIRCHNER: And I guess exemption 3
would be the means to handle it.
4 MR. MUSICO: They would -- pardon?
5 CHAIRMAN KIRCHNER: An exemption, then, 6
would be the means to handle it.
7 MR. MUSICO: No, not necessarily. If they 8
came in and they determined, through whatever means --
9 the power itself, the power levels are really not 10 particularly relevant to the analysis that we did, 11 except to the extent that using the methodology, 12 subsequently they can meet the dose -- using the 13 methodology they've defined and we've approved, they 14 can meet the site boundary of two miles.
15 If they decide to come in with the reactor 16 technology that has a higher power level then that 17 could not meet either the site boundary or two-mile 18 plume exposure pathway EPZ, they would lose the 19 finality, the benefit associated with the two major 20 features emergency plan that we approved. They would 21 be required to come in with a totally new complete and 22 integrated emergency plan which reflected that.
23 With respect to the methodology, they have 24 the benefit of the methodology and if they could show 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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118 that, using that methodology, they don't meet the two-1 mile or the site boundary but they meet three miles, 2
conceivably, they could come in and use the 3
methodology with a new complete and integrated 4
5 CHAIRMAN KIRCHNER: That's what I was 6
testing.
7 MR. MUSICO: -- and we would review that.
8 CHAIRMAN KIRCHNER: And you would review 9
that.
10 MR. MUSICO: Well, we wouldn't be 11 reviewing the methodology again.
12 CHAIRMAN KIRCHNER: Right, no.
13 MR. MUSICO: We would be reviewing the 14 complete and integrated emergency plan.
15 CHAIRMAN KIRCHNER: Right but you wouldn't 16 throw them out and say no, that's ten miles, folks.
17 MR. MUSICO: No. No --
18 CHAIRMAN KIRCHNER: Okay. That's what I'm 19 testing.
20 MR. MUSICO: -- because the methodology --
21 CHAIRMAN KIRCHNER: I'm testing how 22 flexible your approach is.
23 MR. MUSICO: -- is not site boundary, two 24 miles, or ten miles. The methodology is the dose at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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119 whatever distance it turns out to be.
1 CHAIRMAN KIRCHNER: Exactly.
2 MR. MUSICO: So we did think about that.
3 CHAIRMAN KIRCHNER: Okay, good.
4 MR. MUSICO: So yes, that's an interesting 5
approach that they could possibly take.
6 MS. BRADFORD: This is Anna Bradford from 7
NRO. Just one nuance is we wouldn't necessarily have 8
to -- I mean the methodology would be approved. So 9
someone said we wouldn't review the methodology. We 10 would review the application of that methodology --
11 CHAIRMAN KIRCHNER: Of course. Yes, of 12 course.
13 MS. BRADFORD: -- to make sure we agree 14 with where they came out.
15 CHAIRMAN KIRCHNER: Yes, all right.
16 MEMBER MARCH-LEUBA: Yes, but make sure 17 when you write the SP that you box yourself with the 18 two-mile because you call it two-mile everywhere. I'm 19 looking at a map and I would love to have a one and a 20 half mile.
21 MR. MUSICO: Well, I wouldn't say they 22 boxed themselves. I would say they provide themselves 23 with a high amount of flexibility.
24 CHAIRMAN KIRCHNER: Yes.
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120 MEMBER MARCH-LEUBA: Well tell me again, 1
if it was only one and a half mile, you could make the 2
lower, the south boundary I-40 and don't have to have 3
any migration plans.
4 MR. MUSICO: They would have to choose the 5
two-mile emergency planning zone if they wanted to use 6
that major feature as a risk plan.
7 MEMBER MARCH-LEUBA: They cannot take one 8
and a half?
9 MR. MUSICO: They can take one and a half 10 but they still have to use the two-mile emergency 11 planning major features plan.
12 MEMBER MARCH-LEUBA: Why?
13 MR. MUSICO: If the methodology determined 14 that the desired dose was at one and a half miles, 15 they couldn't have the benefit of the site boundary 16 major features emergency plan. They would have to 17 utilize the two-mile major features emergency plan.
18 Now, if they didn't want to utilize that 19 and let's say they wanted to have a new one and a half 20 mile emergency planning zone, they would also lose the 21 benefit of the evacuation time estimate and they would 22 still have to off-site emergency plans. So, it would 23 be -- it wouldn't be advantageous to them to do that 24 because they've already gotten a lot of finality for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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121 that two-mile emergency planning zone. They've got 1
the finality associated with the evacuation time 2
estimate, as far as our review of the major features 3
emergency plan. And they just have to supplement 4
that, provide the delta for the complete and 5
integrated emergency at the COL application --
6 MEMBER MARCH-LEUBA: Most of the plan is 7
on I-40 and the Oak Ridge Turnpike because everything 8
else is a desert. There is nothing there.
9 MR. MUSICO: Well you know they could move 10 the road. Who knows.
11 MEMBER MARCH-LEUBA: Okay.
12 MR. MUSICO: All right, slide 23. Thank 13 you.
14 All right, slide 23 -- let's see -- this 15 summarizes the five key findings that the staff made 16 in the safety evaluation report and these reflect the 17 findings that are required by our regulation.
18 First of all, the staff found that there 19 are no significant impediments to the development of 20 emergency plans. Secondly, there was an adequate --
21 TVA provided an adequate description of contacts and 22 arrangements with federal, state, and local support 23 agencies. The staff found that the proposed 24 exemptions are acceptable. The staff found that the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 proposed major features emergency plans are 1
acceptable. And finally, that the proposed dose-based 2
consequence-oriented EPZ sizing methodology is 3
reasonable.
4 Next slide, please, and I'll turn it back 5
over to Michelle or to Mallecia. Sorry.
6 MS. SUTTON: The staff's conclusion. The 7
staff presented its review and findings on emergency 8
planning for the TVA Clinch River early site permit 9
application. The staff concludes that the plume 10 exposure pathway emergency planning zone size and 11 methodology is acceptable for determining the 12 appropriate size of the plume exposure pathway 13 emergency planning zone for the Clinch River Nuclear 14 Site because it is consistent with the analyses that 15 form the technical basis for the current ten-mile 16 plume exposure pathway emergency planning zone.
17 The two major features emergency plans are 18 acceptable because they meet the applicable standards 19 of 10 CFR 50.47 and requirements of Appendix E to 10 20 CFR Part 50.
21 The exemption requests are acceptable 22 because they are authorized by law, will not present 23 an undue risk to the public health and safety, are 24 consistent with the common defense and security, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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123 special circumstances are present.
1 Therefore, the staff finds the TVA early 2
site permit application acceptable with respect to 3
emergency planning and related exemption requests.
4 Because we are discussing an early site 5
permit, the staff wanted to clarify the relationship 6
of the early site permit exemptions to a future 7
combined license application that references the 8
permit. The staff's presentation provided details on 9
the evaluation of TVA's methodology, exemption 10 requests, and emergency plans. This table provides 11 the breakdown of TVA's request for approval in these 12 three topic areas in their early site permit 13 application and the final products of the staff's 14 evaluation.
15 In addition, it provides how the early 16 site permit and exemptions can be implemented in a 17 combined license application if the early site permit 18 conditions are met.
19 The last is an action that will not be 20 completed until the Commission makes a decision 21 whether to grant an early site permit and the 22 exemptions. The appropriate plume exposure pathway 23 emergency planning zone size for this site will not be 24 determined until a combined license application that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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124 references a specific small modular reactor design is 1
submitted for the Clinch River Nuclear Site.
2 If there are no additional questions on 3
this table or for the staff, this will conclude the 4
staff's presentation.
5 Any questions?
6 CHAIRMAN KIRCHNER: Thank you. Let me go 7
around first -- or take public comments first. Excuse 8
me.
9 So let me look around and see if anyone is 10 in the room. Is there anyone in the room from the 11 public who wishes to make a comment?
12 Seeing no one stepping forward, can we 13 open -- it is open.
14 To those on our bridge line, is there 15 anyone from the public who would wish to make a 16 comment?
17 Hearing none, we can close the bridge line 18
-- or mute the bridge line. Thank you.
19 And I will go around the table, starting 20 with Ron.
21 MEMBER BALLINGER: No comments.
22 CHAIRMAN KIRCHNER: Dennis.
23 MEMBER BLEY: No comments.
24 CHAIRMAN KIRCHNER: Matt.
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125 MEMBER SUNSERI:
I appreciate the 1
presentations. I have no comments.
2 CHAIRMAN KIRCHNER: Joy.
3 MEMBER REMPE: I also appreciate the 4
presentations but have no comment.
5 CHAIRMAN KIRCHNER: Jose.
6 MEMBER MARCH-LEUBA: Why break a perfect 7
record? No comment.
8 CHAIRMAN KIRCHNER: Well, again, with the 9
caveat that this is just one member's opinion and not 10 that speaking for the ACRS, I think what we've heard 11 from the applicant and what the staff has presented --
12 thank you for your presentations -- sounds reasonable 13 and prudent. And I expect that the devil will be in 14 the details when we actually see an actual technology 15 selection and the COLA.
16 So if there are no further comments, thank 17 you again, and we are adjourned.
18 (Whereupon, the above-entitled matter went 19 off the record at 3:42 p.m.)
20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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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
+25%
TVA ESPA PPE Ch. 15 Source Term Example Analysis Criteria A Source Term Example Analysis Criteria B Source Term 4-Day Total Composite Source Term 4-Day Total Composite Source Term
+25%
Dose Calculation Non-Design-Specific 4-Day Total Atmospheric Release Source Term
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
Advisory Committee on Reactor Safeguards l 30
1 ACRS Subcommittee August 22, 2018 Tennessee Valley Authority (TVA)
Early Site Permit Application (ESPA)
ESPA Site Safety Analysis Report (SSAR) Section 13.3 Emergency Planning Advanced Safety Evaluation Report (SER) with no Open Items Project Managers Mallecia Sutton (NRO)
Technical Reviewers Bruce Musico (NSIR)
Michelle Hart (NRO)
2 13.3 Emergency Planning -
TVA Early Site Permit Application The ESPA requested review of 3 key areas, which consist of:
Plume exposure pathway (PEP) emergency planning zone (EPZ) sizing methodology (ESPA SSAR, Sec. 13.3)
2 Major Features (onsite) Emergency Plans (ESPA Part 5)
ESPA Part 5A reflects a Site Boundary PEP EPZ ESPA Part 5B reflects a 2-Mile PEP EPZ (includes an evacuation time estimate)
25 Exemption Requests (ESPA Part 6)
ESPA proposes 2 sets of exemptions (for the site boundary/2-mile PEP EPZs)
ESPA proposes an exemption from the current 10-mile PEP EPZ Exemptions address portions of 10 CFR 50.33(g), 50.47(b) & (c)(2),
and Appendix E to 10 CFR Part 50, for onsite and offsite emergency planning (EP)
3 Part 52 Licensing Process
Upon issuance of the early site permit (ESP), the applicant acquires approval, with conditions, on:
The PEP EPZ sizing methodology
The 25 requested exemptions
The 2 major features E-plans (site boundary & 2-mi PEP EPZ)
In the future, a combined license application (COLA) that incorporates by reference the ESP will:
Identify a chosen small modular reactor (SMR) technology for the Clinch River Nuclear Site The applicant must demonstrate that the EPZ sizing methodology supports either the site boundary or 2-mile PEP EPZ
Provide a complete & integrated emergency plan For the 2-mile PEP EPZ, must provide onsite & offsite emergency plans For the site boundary PEP EPZ, must provide onsite emergency plan (assumes that site boundary, as defined for EP purposes in the COLA, will be within the applicants owner controlled area)
Address identified COL action items and permit conditions
4 Review of Exemptions (Special Circumstances)
The NRC reviewed the requested exemptions pursuant to 10 CFR 50.12 (Specific Exemptions) 50.12(a)(2) - The Commission will not consider granting an exemption unless special circumstances are present.
Special circumstances are present whenever -
(ii) - Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule, or is not necessary to achieve the underlying purpose of the rule.
5 Special Circumstances (Underlying Purpose of Rule)
The underlying purpose of 10 CFR 50.33, 50.47, and Appendix E to 10 CFR Part 50, is to:
Ensure that licensees maintain effective onsite and offsite radiological emergency response plans,
Ensure that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, and
Establish plume exposure and ingestion pathway EPZs.
The ESPA serves to provide a basis for the establishment (in the COLA) of either a Site Boundary or 2-mi PEP EPZ, which maintains the same level of protection (i.e., dose savings in the event of a radiological emergency) in the environs of the Clinch River Nuclear Site, as that which exists in the basis for a 10-mi PEP EPZ.
6 TVA PEP EPZ Size Methodology Technical Criteria
PEP EPZ should encompass those areas in which projected dose from design basis accidents (DBAs) could exceed the U.S. Environmental Protection Agency (EPA) early phase protective action guide (PAG)
PEP EPZ should encompass those areas in which consequences of less severe core melt accidents could exceed the EPA early phase PAG
PEP EPZ should be of sufficient size to provide for substantial reduction in early health effects in the event of more severe core melt accidents
7 TVA PEP EPZ Size Methodology SSAR Section 13.3.3.1
Accident scenario selection Use bounding DBA from COLA Final Safety Analysis Report Chapter 15 Use COLA site-and design-specific probabilistic risk assessment (PRA) to categorize severe accident scenarios All modes, internal and external events, applicable fuel handling and spent fuel pool accidents, multi-module considerations Assess all sequences with mean core damage frequency (CDF) > 10-8 per rx-yr More probable, less severe core melt scenarios Mean CDF > 10-6 per rx-yr, intact containment Less probable, more severe core melt scenarios Mean CDF > 10-7 per rx-yr, containment bypass or failure
Determine source term releases to atmosphere
Calculate dose consequences at distance from plant
Determine PEP EPZ size that meets the dose-based criteria
8 TVA Dose-Based PEP EPZ Size Criteria
Dose to individual from exposure to the airborne plume during its passage and to groundshine, using average atmospheric dispersion characteristics for site
DBA and more probable, less severe accidents
1 rem total effective dose equivalent (TEDE) from 96-hr exposure
Lower end of dose range EPA PAG for early phase protective actions (e.g.,
evacuation and sheltering)
Verify that dose consequences do not exceed the EPA PAG beyond the site boundary (within owner controlled area) and 2-mile PEP EPZs
Less probable, more severe accidents
Calculate the distance at which the conditional probability to exceed 200 rem whole body from 24-hr exposure exceeds 10-3 per rx-yr
Acute dose at which radiation-induced early health effects may begin to be noted (e.g., nausea)
Verify that the PEP EPZ supports substantial reduction in early health effects
9 Review of PEP EPZ Size Methodology
Staff compared TVAs methodology and dose criteria to the study used as technical basis for current 10-mile PEP EPZ requirement (NUREG-0396)
The features of TVAs methodology are consistent with NUREG-0396 Considered a range of accidents Performed accident consequence analyses Determined an area outside of which early protective actions are not likely to be necessary to protect the public from radiological releases
The staff concludes that the applicants proposed methodology is reasonable, and consistent with the analyses that form the technical basis for the current regulatory requirement of a PEP EPZ of about 10 miles in radius.
10 SMR Features that Support the Exemption Requests
TVA stated that special circumstances exist at the Clinch River Nuclear Site due to the anticipated enhanced safety features of the SMR designs under consideration
Smaller radionuclide inventory and source terms
Projected accident progression rate is anticipated to be slower
Various design features are expected to eliminate several historically considered design basis events
Severe accidents are projected to be less likely to occur
Advanced design features that would minimize accident consequences
11 Request for Additional Information Question 1
Specific technical support related to the statements on SMR features and comparison to large light water reactors (LLWRs)
TVA provided tables with several parameters comparing the smallest and largest SMRs (based on unit rated thermal power) in the Clinch River Nuclear ESPA plant parameter envelope (PPE) to large and medium currently operating pressurized water reactors and the AP1000 For example:
Internal events CDF and large release frequency Source term total activity Primary coolant liquid mass to power ratio Severe accident progression information
12 Request for Additional Information Question 2
Demonstration that the proposed PEP EPZ size criteria could be met at a given EPZ boundary distance for potential reactor facilities that would be represented by the surrogate design in the PPE
TVA provided an example analysis using design information for a specific SMR design as input to the SSAR 13.3 PEP EPZ size methodology
Example analysis showed that design could support a site boundary PEP EPZ
Not intended to prove case for ESPA to justify a specific PEP EPZ size Based on preliminary design information for an SMR at the lower end of the rated power (160 MWt) that is part of the basis for the Clinch River Nuclear ESPA PPE Used internal events design PRA only Did not do detailed uncertainty analysis
13 EP Exemption Plant Parameters
TVA developed a non-design-specific accident release source term that would meet the PEP EPZ size criteria to be used as plant parameters (SER Table 13.3-1)
Same idea as PPE DBA source term to envelope an unknown design
Referenced in Permit Condition 1 for adoption of EP exemptions
Isotopic total release activity over 96 hrs results in TEDE of about 0.9 rem at site boundary
3 core melt, intact containment accidents (2 DBAs and 1 severe accident)
From 2 SMRs (160 MWt and 800 MWt)
Maximum activity release for a specific radionuclide from any of the 3 accidents over a specific dose averaging period was assumed to be the release activity of that radionuclide for that period 0-8 hrs, 8-24 hrs, 24-96 hrs
Added 25% margin
Additional adjustment to values for backcalculation
14 Permit Condition 1
COL applicant referencing the ESP (if approved) would perform an analysis using the SSAR 13.3 PEP EPZ size methodology, with site-and design-specific input, to justify the PEP EPZ size for the COLA
The COLA PEP EPZ size analysis output includes the source term releases to the atmosphere
Isotopic activity release over time
If the COLA PEP EPZ size analysis source term releases to the atmosphere are bounded by the non-design-specific plant parameter source term information in SER Table 13.3-1, then the COL applicant can adopt the EP exemptions
4-day total activity release to the atmosphere for 71 isotopes
COLA values should be shown to be less than ESP (Table 13.3-1) values to adopt the EP exemptions
15 Plant Parameter Envelope
TVA identified 4 SMR designs to develop the PPE
BWXT mPower (Generation mPower)
NuScale (NuScale Power)
SMR-160 (Holtec SMR)
Westinghouse SMR (Westinghouse Electric Co.)
A different reactor design that falls within the following PPE information range may be selected in the COLA
2 or more SMRs with a maximum 800 MWt for a single unit
Combined site capacity not to exceed 2420 MWt (800 MWe)
16 Review Standards/Guidance 10 CFR Part 52, Subpart A, Early Site Permits 10 CFR 50.47 & Appendix E to Part 50 10 CFR 50.12 & 52.7, Specific Exemptions NUREG-0800, Standard Review Plan, Sec. 13.3, Emergency Planning NUREG-0654/FEMA-REP-1 (Rev. 1), Suppl. 2, NSIR/DPR-ISG-01 NUREG-0696, Functional Criteria for Emergency Response Facilities NUREG/CR-7002, Criteria for Development of ETE Studies NUREG-0396, Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants EPA PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents
17 Federal Emergency Management Agency (FEMA) Consultation
NRC performed its review in consultation with FEMA, pursuant to the FEMA-NRC Memorandum of Understanding (MOU) (12/7/15, ML15344A371)
FEMA review was limited because:
The ESPA did not include offsite emergency plans, and
The major features plans only addressed limited onsite EP features.
FEMAs January 24, 2018, letter (ML18031B055) stated that:
Working with TEMA, FEMA did not identify physical characteristic of the proposed site that could pose a significant impediment to the development of emergency plans, including evacuation from the 2-mi EPZ.
The boundary established for the proposed 2-mi PEP EPZ was established relative to local emergency response needs and capabilities, as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries.
At this time, FEMAs finding does not endorse or determine the adequacy of a proposed 2-mi PEP EPZ for the site if proposed during the licensing process.
In its June 12, 2017, letter (ML17164A206) FEMA further stated that it did not review or analyze the feasibility and assumptions for the site boundary EPZ, but if requested in the future, would provide comments and recommendations.
18 COL Action Items vs. Permit Conditions
The 16 COL Action Items:
Track information that is needed before granting a COL, but is not required in the ESPA
Reflect the SMR design that may be identified in the COLA
Require NRC evaluation as part of the COLA review
The 4 Permit Conditions:
An ESP is granted subject to permit conditions, which address required detailed information that is not yet known, but will be available in the COLA and subject to NRC confirmation
19 16 COL Action Items 13.3-1, Select SMR (EPA PAGs)/PEP EPZ/E-plan 13.3-2, Update Letters of Agreement/MOUs 13.3-3, SMR facilities & staffing 13.3-4, Emergency action level scheme 13.3-5, Alert and notification system 13.3-6, SMR communications/data links 13.3-7, Joint Information Center location/capabilities 13.3-8, Onsite monitoring systems/equipment
20 COL Action Items (cont.)
13.3-9, Technical Support Center 13.3-10, Operations Support Center 13.3-11, Local Recovery Center 13.3-12, Central Emergency Control Center 13.3-13, Radiation monitoring systems 13.3-14, Meteorological tower & monitoring program 13.3-15, On-site personnel decontamination facility 13.3-16, Communications testing & hostile action exercises
21 4 Permit Conditions, 1 Confirmatory Item
Permit Conditions (PC)
SMR PPE Accident Consequence Analyses PC 1, Calculation of EPZ Size
Fukushima Dai-ichi (near term task force 9.3, Tier 1)
PC 2, Multi-Unit Staffing Assessment PC 3, Communications Assessment
2011 Emergency Preparedness Rulemaking PC 4, On-Shift Staffing Analysis
Confirmatory Item 13.3-1
Withdrawal of exemption request Item No. 19 (re: the requirement for remedial exercises)
Section IV.F.2.f of App. E to 10 CFR Part 50
Can be closed out when ESPA Rev. 2 is submitted
22 Combined License Application (COLA)
In the COL Application:
The COL applicant will identify an SMR technology, which must meet the PEP EPZ sizing methodology approved in the ESP for either the site boundary or 2-mile PEP EPZ, or may propose a new emergency plan.
If the 2-mile PEP EPZ is selected and justified, the NRC will request that FEMA review the offsite emergency plans.
If the site boundary PEP EPZ is selected and justified, no formal FEMA-approved offsite radiological plans are required.
The COL applicant will still need to address requirements to communicate and coordinate with offsite support organizations and agencies
23 Staff Review Findings
No significant impediments to the development of emergency plans (10 CFR 52.17(b)(1))
Adequate description of contacts and arrangements with Federal/State/local support agencies (10 CFR 52.17(b)(4))
Proposed exemptions are acceptable (10 CFR 50.12, 52.7)
Proposed major features emergency plans are acceptable (10 CFR 52.17(b)(2)(i))
Proposed dose-based, consequence-oriented EPZ sizing methodology is reasonable
24 Conclusions
The staff concludes that:
The PEP EPZ sizing methodology is acceptable for determining the appropriate size of the PEP EPZ for the Clinch River Nuclear Site because it is consistent with the analyses that form the technical basis for the current 10-mile PEP EPZ.
The 2 major features emergency plans are acceptable because they meet the applicable standards of 10 CFR 50.47 and requirements of Appendix E to 10 CFR Part 50.
The exemption requests are acceptable because they are authorized by law, will not present an undue risk to the public health and safety, are consistent with the common defense and security, and special circumstances are present.
Therefore, the staff finds the TVA ESPA acceptable with respect to emergency planning and related exemption requests.
TVAs Request in ESP Application and Method of Implementation (if ESP Application Approved) in COLA Final Products and Approval Mechanism ESP COLA ESP COLA Methodology (SSAR 13.3)
Approval of a dose-based methodology for determining the EPZ size, as described in SSAR Section 13.3.
Approval of site-specific implementation of the previously approved methodology in ESP SSAR Section 13.3 to justify EPZ size. EPZ size calculation provided using site-and design-specific information.
Approval of final EPZ size.
Final Product: SER and permit Staff relies on NUREG-0396 and EPA PAG Manual.
SECY-15-0077: Staff initiated rulemaking for SMRs and ONTs.
Prior to establishment of rule, staff should be prepared to adapt approach to EPZs for SMRs under existing exemption processes, in parallel with its rulemaking efforts (case-by-case).
Final Product: SER, license with EPZ size Using the methodology in ESP SSAR Section 13.3, the COL applicant must demonstrate that the selected SMR design meets EPA PAGs for the selected EPZ size.
Exemption Request (Part 6)
Approval for exemptions from the current 10-mile EPZ requirement if certain conditions are met. Approval to use the methodology in ESP SSAR Section 13.3 to determine EPZ size in the COLA. The ESPA requests 2 sets of exemptions, one for a site boundary EPZ and one for a 2 mile EPZ, and proposed major features of emergency plans for each.
The COLA can rely on EP exemptions granted in the ESP, provided site-and design-specific information justify use of one of the sets of exemptions evaluated in the ESPA.
Final Product: SER and permit with exemptions (if approved) and related conditions Staff relies on exemption guidance, NUREG-0396 and EPA PAG Manual Final Product: SER, license to reflect EPZ size supported in the COLA.
Emergency Plans (Part 5A and Part 5B)
Approval of the major features of the site boundary and 2-mile emergency plans in Part 5.
Approval of complete and integrated emergency plans, including offsite emergency plans if a PEP EPZ other than site boundary is selected. Includes the remaining features of the emergency plan (either site boundary or 2-mile) from the ESP or new emergency plan based on the final dose-based EPZ size.
Final Product: SER and permit Staff relies on existing rules and guidance, except to the extent that they are not applicable because of the requested exemptions.
Final Product: SER, license to reflect EPZ size supported in the COLA.
26 Abbreviations
CDF - core damage frequency
CFR - Code of Federal Regulations
COL - combined license
COLA - combined license application
DBA - design basis accident
EP - emergency planning
EPA - U.S. Environmental Protection Agency
EPZ - emergency planning zone
ESP - early site permit
ESPA - early site permit application
ETE - evacuation time estimate
FEMA - Federal Emergency Management Agency
FSAR - Final Safety Analysis Report
LLWR - large light water reactor
MOU - memorandum of understanding
MWe - megawatts electric
MWt - megawatts thermal
NTTF - Near-Term Task Force
27 Abbreviations (cont.)
PAG - (EPA) protective action guide
PC - permit condition
PEP - plume exposure pathway
PPE - plant parameter envelope
PRA - probabilistic risk assessment
RG - Regulatory Guide
rem - roentgen equivalent man (1 rem = 0.01 Sv)
rx-yr - reactor-year
SER - safety evaluation report
SMR - small modular reactor
SSAR - site safety analysis report
TEDE - total effective dose equivalent