ML19197A130

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NRC-2018-000831 - Resp 1 - Interim, Agency Records Subject to the Request Are Enclosed. Part 2 of 3
ML19197A130
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Issue date: 07/09/2019
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Text

SCHEDULING NOTE

Title:

BRIEFING ON THE STATUS OF SUBSEQUENT LICENSE RENEWAL PREPARATIONS (Public Meeting)

Purpose:

To provide the Commission with a discussion on the status of issues related to subsequent license renewal (SLR) applications and the staff prepar_edness to review an application .

Scheduled: April 26, 2017 9:00 a.m.

Duration: Approx. 3 ~10urs Location: Comm issioners' Conference Room , 1 st fl OWFN

Participants:

Presentation External Panel 60 mins.*

Richard Reister, Director, Light Water Reactor Sustainability Program , 10 mins.

  • U. S. Department of Energy Topic:
  • Results of ongoing DOE research related to the technical basis for operating beyond 60 years Sherry Bernhoft, Program Manager, Long Term Operations , 10 mins.
  • Electric Power Research Institute Topic:
  • Results of ongoing industry research related to the technical basis for operating beyond 60 years Jason Remer, Director, Plant Life Extension , Nuclear Energy Institute 10 mins.
  • Topic:
  • Industry perspectives on SLR preparedness Michael Gallagher, Vice President, License Renewal Projects , Exelon 10 mins.
  • Generation Co. , LLC, Peach Bottom Atomic Power Station ,

Units 2 and 3 Topic:

  • Peach Bottom SLR* application

.II ** *- -

Paul Aitken , Manager, Second License Renewal , Dominion Resources , 10 mins.

  • Surry Power Station , Units 1 and 2 Topic:
  • Surry SLR application David Lochbaum , Director, Nuclear Safety Project, Union of 10 mins.*

Concerned Scientists Topic:

Commission Q & A 30 mins.

Break 5 mins.

NRC Staff Panel 40 mins.*

Victor McCree, Executive Director for Operations Michele Evans, Deputy Director, Office of Nuclear Reactor Regulation (NRR)

George Wilson, Director, Division of License Renewal , NRR Brian Thomas, Director, Division of Engineering , Office of Nuclear Regulatory Research Allen Hiser, Senior Technical Advisor for License Renewal Aging Management, Division of License Renewal , NRR Topics:

  • Status of SLR guidance document development -

significant changes

  • Research related to SLR
  • SLR process optimization Commission Q & A 30 mins.

Discussion - Wrap-Up 5 mins.

  • For presentation only and does not include time for Commission .Q & A's 2

U.S. DEPARTMENT OF ENERGY Nuclear Energy NRC Commissioner Briefing DOE Light Water Reactor Sustainability (LWRS) Program April 26, 2017 Richard Reister, Program Manager Office of Nuclear Energy

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L WRS Program Nuclear Energy Objective:

  • Develop technologies and other solutions that can improve the reliability, sustain the safety, and extend the life of current reactors Four areas of research:
  • Materials Aging and Degradation
  • Advanced Instrumentation, Information, and Control Systems Technologies
  • Risk-Informed Safety Margin Characterization
  • Reactor Safety Technologies 3

LWRS Program Nuclear Energy DOE Role:

  • Support national strategic interests in energy security, reliability and grid stability
  • Address fundamental scientific questions to make progress on broadly applicable technology issues
  • Reduce technical uncertainties and risks such that industry is willing to make the necessary long-term investments Materials Research helps develop:
  • High quality materials degradation data
  • An understanding of the underlying mechanisms
  • Mechanistic models
  • Improved monitoring capabilities
  • Mitigation techniques 4

Materials Aging and Degradation Nuclear Energy

  • Expanded Materials Degradation Assessment {EMDA)

{NUREG/CR-7153), a joint DOE/NRC sponsored effort published October 2014, captured status and knowledge gaps in the following four areas:

  • Core internals and piping systems
  • Concrete civi I structures
  • Electrical power and instrumentation and control (l&C) cables
  • Much progress has been made to fill knowledge gaps
  • No generic technical show stoppers to long-term operation have been identified
  • Research continues to improve understanding and reduce uncertainties 5

Reactor Pressure Vessels Nuclear Energy Evaluation of risk for high fluence embrittlement and possible mitigation techniques through the mechanistic understanding the effects of..... .

  • Fluence, flux and influence of alloy chemistry on materials performance
  • Radiation-induced effects and mitigation techniques
  • Neutron attenuation and variation in through thickness properties Harvested Zion RPV:
  • Aging I irradiation behavior of weldments ----~ Currently machining samples, testing to continue to 2021.
  • Bias in toughness values derived from pre-cracked Charpy specimens 6

Core Internals Nuclear Energy Research involves analysis and testing of core Experiment [25]

80 internal materials of both commercial and

  • 500°C model alloys and includes service materials.
  • 400°C 60 The goal is to develop physics based predictive models bl)

~ RIME code 40

  • 2017 - Deliver Radiation Induce (!)

~

- 500°C Microstructural Evolution (RIME) model for lf1 - - - -

  • 400°C G= l o-6 dpa/s swelling 20 Res.gas= l appm
  • 2017 - Complete an integrated thermal and _... ...

radiation induced segregation model o~:..::..::&:J~~L-J---...::a.....-'--'--i........&.---1....~

0 20 40 60 80 100 120 140

  • 2019 - Complete a predictive model for Dose (dpa)

Irradiation-Assisted Stress Corrosion Cracking (IASCC) RIME code vs.

experimental data These models can be used by industry to better predict, manage, and mitigate the degradation of core internals.

7

  • Piping Nuclear Energy Environmentally Assisted Fatigue
  • Research has focused on experimental studies to develop a finite element based fatigue model that tracks key time-dependent properties for fatigue life based on LWR environmental conditions and plant operation history, rather than empirical methods using test data under non-relevant conditions.
  • 2017 - Complete thermal fatigue models for a 508 Low Alloy Steel RPV and 316L alloy surge line pipe.

Thermal Aging of Cast Austenitic Stainless Steel (CASS) and Austenitic Stainless Steel Welds (ASSW)

  • Research the effects of long-term thermal exposure on the service life of CASS and ASSW components.
  • 2019 - Complete a validated predictive model.
  • Future work - address synergistic effects of irradiation and thermal aged CASS materials.

8

U.S. DEPARTMENT OF ENERGY Concrete Civil Structures Nuclear Energy Conducting research on the fundamental behavior of the heavily reinforced co.n crete found in nuclear power plants under the influence of irradiation and Alkali-Silica Reaction (ASR)

  • Irradiation studies on mineral analogues, aggregates and concrete, with data retained in a developed database
  • Conducting experiments on ASRs influence on the structural significance to large reinforced structures
  • 2020 - Complete a model tool to predict the impact of both irradiation and ASR on concrete structural performance.

Based on research to date and initial evaluations, concrete structures appear to have significant safety margins during the 60-80 year time period.

Concrete NOE

  • Improved existing NOE techniques by using advanced signal processing techniques .

9

U.S. DEPARTMENT OF

  • ENERGY Power and l&C Cables Nuclear Energy Understanding cable degradation mechanisms and the ability to predict remaining useful life will help plants better manage the aging of their cables
  • Research is being conducted on the typical cable types found at plants
  • Accelerated aging under combined temperature and irradiation conditions
  • Electrical, chemical, and mechanical characterization is performed to establish aging trends and key factors for cable condition monitoring
  • . Also evaluating and_developing promising Non-Destructive Evaluation (NOE) methods and technologies through collaboration with vendors and industry Current model development
  • 2019 - complete a predictive models for cable aging under combined thermal and irradiation conditions We believe the aging of plant cable during the 60 to 80 year period of operation can be reasonably managed with appropriate monitoring programs.

10

Summary Nuclear Energy 11 No generic technical show stoppers to long-term operation have been identified 11 Supporting the development of improved monitoring techniques 11 Inform industry Aging Management Programs 11

~~121 1 ELECTRIC POWER

~*- RESEARCH INSTITUTE EPRI Long Term Operations Research & Development for Aging Management Sherry Bernhoft EPRI Senior Program Manager NRC Commissioner Briefing on SLR April 26, 2017

~ 2017 Electric Power Research Institute, Inc. All nghts reserved

Technical Basis for Aging Manageme.nt Inspection

  • How to inspect Assessment
  • What equipment and techniques are available
  • What to inspect and when
  • What are the associated
  • Inspection options uncertainties
  • How to dispose any observed
  • What techniques need to be degradation improved Mitigation and Testing Technical Support
  • Prevent or reduced degradation
  • Review of inspection results
  • Irradiated material testing *Guidelines review and maintenance

© 2017 Electric Power Research Institute, Inc. All rights reserved . E I-le;;;;

~~1 1 ELECTRIC POWER RESEARCH INSTITUTE

l EPRl's Approach

  • Issue Management Programs
  • Prioritized research plans
  • Collaboration with US DOE, NRC Operating Research and International partners Experience
  • NEI Initiative 03-08 Inspection Results
  • Lead plant support 3 ~~121 1 ELECTRIC POWER

© 2017 Electric Power Research Institute, Inc. All rights reserved ~*- RESEARCH INSTITUTE

Four Key Technical Areas

  • Concrete degradation
  • Electrical cable qualification and condition assessment 4 ('::=~121 1 ELECTRIC POWER

© 2017 Electric Power Research Institute. Inc. All rights reserved . ~*- RESEARCH INSTITUTE

Reactor Pressure Vessels (RPVs)

  • Surveillance capsule are used to monitor fracture toughness of the RPV and nozzles due to irradiation and other potential degradation mechanism
  • PWRs - Programs to collect surveillance capsule data at higher fluences

- Coordinated Surveillance Program

- Supplemental Surveillance Program

  • BWRs - Integrated Surveillance Program

- Extend for 80 years of operations An established embrittlement trend correlations exist to predict RPV mechanical properties 5

© 2017 Electric Power Research Institute, Inc. All rights reserved E ~121 1 ELECTRIC POWER RESEARCH INSTITUTE

Reactor Vessel Internals Former

  • Irradiation assisted stress corrosion cracking Core Barrel to Former Bolt (IASCC) of internals materials due to increased neutron fluence and the operating environment
  • EPRI BWR Vessel Internals Program and Materials Reliability Program (PWRs) Former Bolt Corner Edge (Long & Short) Bracket Baffle to Former Bolt
  • Extensive work has been completed on IASCC initiation and crack growth rate models
  • Harvested materials provide confirmation 6 ~p121 1 ELECTRIC POWER

© 2017 Electric Power Research Institute, Inc. All rights reserved t.= RESEARCH INSTITUTE

Concrete Degradation

  • Impacts on the structural integrity of concrete due to:

- Alkali-Silica Reactions (ASR)

- Irradiation and gamma heating

  • Leveraging the irradiated concrete work completed at ORNL, developed a PWR biological shield wall model and published results Modeling concrete structures exposed to high levels of radiation demonstrated safety margins exist Developing aging management and evaluation programs for reactive aggregates 7 r=~121 1 ELECTRIC POWER

© 2017 Electric Power Research Institute. Inc. All nghts reserved. ~*- RESEARCH INSTITUTE

Electrical Cable Qualification and Condition Assessment EPRI aging management - scoping methodology

  • Cable insulation materials age due to radiation, temperature and Entire Plant Cable Population submergence Cable Supporting Maintenance Rule
  • Research continues to support asset Conductors or Splices management Cables to Be Assessed by the Cable Aging Management Program

- Condition monitoring

- Determine remaining useful life (RUL)

  • Includes adverse environments , such as chemical and radiation environments.

8

© 2017 Electric Power Research Institute, Inc. All rights reserved E r.=!'!t~1 1 ELECTRIC 1-1~

POWER RESEARCH INSTITUTE

Summary

  • Continuous improvements for aging management are based on research, inspections and operating experience
  • Research results and technical reports are shared with the NRC staff
  • Technical support for the leads plants 9

© 2017 Electric Power Research Institute, Inc. All rights reserved. EI~121 1 ELECTRIC POWER RESEARCH INSTITUTE

Together ... Shaping the Future of Electricity 10 ~~~1 1 ELECTRIC POWER

© 2017 Electric Power Research Institute, Inc. All rights reserved ~*-*~ RESEARCH INSTITUTE

  • NRC Commissioner Briefing on Subsequent License Renewal NRC White Flint One Rockville, MD April 26, 2017 S. Jason Remer Director, Life Extension & New Technology Nuclear Energy Institute

Today's Briefing

  • Key Safety Principles Maintained
  • Process Optimization
  • Moving Forward

Nuclear Plants Are Critical Infrastructure

  • U.S. has the largest and best-run fleet of nuclear power plants in the world
  • Generate 20% of America's electricity overall; 62% of emissions-free electricity
  • Like other infrastructure, nuclear plants provide tremendous benefits for nearly a century
  • Nuclear energy needs to be included in any plan to rebuild America

~ - ~ -- --- - -- - -~ -~- ~~- -- ------- ~ - ~- --- -- -- -----'- -* --- .

Defining Our Future: A Logical Progression Advanced reactors Small modular reactors mnd license Renewal 2010 2020 2040 2060 2080 2100 All plants will

"'20% of reactors could reach 60 years.

retire due to economics "'Half of plants will reach 60 years.

Key Principles for License Renewal

  • Current regulatory process is adequate to ensure that the licensing basis of all operating plants provides and maintains an acceptable level of safety so that operation will not be detrimental to public health and safety or common defense and security
  • Each plant's licensing basis is required to be maintained during any renewal term in the same manner and to the same extent as during the original licensing term

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Regulation is Sound

  • Existing regulatory processes ensure safe operation

- 10 CFR 50, Appendix B

- Aging Management Programs

- Maintenance Rule

- Reactor Oversight Process

- Design basis is maintained

  • Process proven through experience, 86 with renewed license, 42 reactor units in PEO (approx. 128 reactor years in PEO)
  • Reliable, predictable process

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Regulatory Guidance is Sound

  • Significant Industry input to NRC as SLR GALL report was prepared over the last three years

- Comprehensive industry comments submitted on the draft GALL in February, 2016

- Industry participated in nine GALL-focused public meetings with NRC in 2016 to resolve industry comments

  • Final SLR GALL Report provided for stakeholder review Feb. 8
  • Part 54 Environmental Review

- Draft "Model SLR New and Significant Assessment Approach for SAIVIA"'

submitted to NRC to improve Environmental Review Process

SLR Research

  • Research and data being collected at EPRI, DOE and other facilities in U.S. conclude there are no technical "show stoppers" for operation beyond 60 years .
  • NRC has participated in seven NEI organized SLR site visits since 2015

- Salem/Hope Creek Station, Oak Ridge National Lab, EPRI, Pacific Northwest National Lab, AREVA, Westinghouse and University of Tennessee Site tours and presentation focused on aging management programs for concrete, cables and metal

SLR Application Optimization

  • Industry participated in three public meetings with NRC
  • Commitment to 18-month safety and environmental application review
  • Application of lessons learned from first round of License Renewal to improve application efficiency
  • Improved resource allocation and schedule coordination
  • Increased use of electronic communication tools
  • Elimination of redundancy - scoping meeting
  • Peer reviewed applications and RAI discipline
  • Final meeting to address SLR application optimization on May 11

SLR Lead Plant Update

  • Peach Bottom on track for BWR application submittal 3rd quarter 2018
  • Surry Station on track for PWR application submittal 1st quarter 2019
  • Industry aligned in commitment to dedicating resources needed for success of lead plant SLR applications
  • Industry survey conducted in May 2016 to determine how many plants may take advantage of SLR in the future

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Summary

  • NRC committed to optimizing application review process to accomplish an 18-month review
  • Lead plants on track for 2018 and 2019 application submittals
  • SLR applications must be of the highest quality to ensure 18-month NRC review goal can be met
  • Plant safety is and will be maintained throughout licensed period

___,. Exelon Generation Exelon is well positioned to be a lead applicant

./ Exelon has extensive aging management experience o 22 of 23 units have renewed operating licenses o 13 units are operating in PEO

./ Exelon has held leadership positions and participates in NEI and EPRI initiatives preparing the industry for Subsequent License Renewal and Long Term Operations

./ Exelon participated through NEI in providing comments to the staff on GALL-SLR

./ Exelon will submit a high quality application that can support an 18 month staff review

- Exelon Generation

Peach Bottom is BWR lead plant

./ First Renewal Application submitted July 02, 2001 o Approved May 7, 2003 o Entered PEO 2013 Unit 2 & 2014 Unit 3

~ Well run and maintained o 11 years without an automatic scram o Over $1.3 Billion in capital improvements 2012-2016 o Achieved Extended Power Uprate on Both Units in 2015 o Received 5th consecutive INPO Excellence Award o Named a "Top Plant" by POWER Magazine

~Community Commitment o Donated more than $416,000 to local non-profits and charities in our community in 2016 2 - Exelon Generation

Approach to Subsequent License Renewal

./ Part 51 Environmental Review: utilize guidance in NUREG 1437 (GEIS), NUREG 1555 (SRP) and Reg Guide Supplement 1 *

./ Part 54 Safety Review: utilize guidance in NUREG 2191 (GALL-SLR) and NUREG 2192 (SRP) o 54.21 (a) Integrated Plant Assessment o 54.21(c) TLAA Evaluation o Aging Management Programs

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Aging Management Programs are implemented to ensure that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the Current Licensing Basis for the period of extended operation.

3 ~ Exelon Generation

Part 54 Application Integrated Plant Assessment Scope Screen Aging Management Review Systems.

components and structures within the Passiw scope of Passive IOCFR54: Or Active?

  • Safety Related No Active
  • Non-Safety Related that anaged by could prevent Aging Existing Management No a safety Activities?

function Review Moclif) existing

  • Regulated or add new Events- SBO, programs EQ, Fire. Yes PTS,ATWS Structures & Components not subject to Additional Aging Management Review Demonstration that the effects of Aging are adequately managed 4 ~ Exelon Generation

48 Anticipated Aging Management Programs Mechanical I Structural Xl.M1 ASME Section XI lnservice Inspection, Subsections Xl.M27 Fire Water System Xl.S1 ASME Section XI , Subsection IWE IWB, IWC, and IWD Xl.M2 Water Chemistry Xl.M29 Outdoor and Large Atmospheric Metallic Tanks Xl.S3 ASME Section XI , Subsection IWF Xl.M3 Reactor Head Closure Stud Bolting Xl.M30 Fuel Oil Chemistry Xl.S4 10 CFR Part SO, Appendix J Xl.M4 BWR Vessel ID Attachment Welds Xl.M31 Reactor Vessel Material Surveillance XI.SS Masonry Walls Xl.M7 BWR Stress Corrosion Cracking Xl.M32 One-Time Inspection Xl.S6 Structures Monitoring XI.MS BWR Penetrations Xl.M33 Selective Leaching Xl.S7 Inspection of Water-Control Structures Associated with Nuclear Power Plants Xl.M9 BWR Vessel Internals Xl.M3S ASME Code Class 1 Small-Bore Piping XI.SS Protective Coating Monitoring and Maintenance Xl.M .12 Thermal Aging Embrittlement of Cast Austenitic Xl.M36 External Surfaces Monitoring of Mechanical Stainless Steel (CASS) Components Electrical Xl.M17 Flow-Accelerated Corrosion Xl.M3S Inspection of Internal Surfaces in Miscellaneous Xl.E1 Electrical Insulation for Electrical Cables and Piping and Ducting Components Connections Not Subject to 10 CFR S0.49 Environmental Qualification Requirements Xl.M1S Bolting Integrity Xl.M39 Lubricating Oil Analysis Xl.E2 Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR S0.49 Environmental Qualification Requirements Used in Instrumentation Circuits Xl.M20 Open-Cycle Cooling Water System Xl.M40 Monitoring of Neutron-Absorbing Materials Other Xl.E3A Electrical Insulation for Inaccessible Medium than Boraflex Voltage Power Cables Not Subject to 10 CFR S0.49 Environmental Qualification Requirements Xl.M21A Closed Treated Water Systems Xl.M41 Buried and Underground Piping and Tanks Xl.E3B Electrical Insulation for Inaccessible Instrumentation and Control Cables Not Subject to 10 CFR S0.49 Environmental Qualification Requirements Xl.M23 Inspection of Overhead Heavy Load and Light Load Xl.M42 Internal Coatings/Linings for in scope Piping, Piping Xl.E3C Electrical Insulation for Inaccessible Low Voltage (Related to Refueling) Handling Systems Components, Heat Exchangers, and Tanks Power Cables Not Subject to 10 CFR S0.49 Environmental Qualification Requirements Xl.M24 Compressed Air Monitoring X.M1 Fatigue Monitoring Xl.E4 Metal Enclosed Bus Xl.M2S BWR Reactor Water Cleanup System X.M2 Neutron Fluence Monitoring XI.ES Fuse Holders Xl.M26 Fire Protection Xl.E6 Electrical Cable Connections Not Subject to 10 CFR

, Plant Specific S0.49 Environmental Qualification Requirements Wooden Pole Program X.E1 Environmental Qualification of Electric Components 5

Summary

~The GALL-SLR and GEIS guidance is comprehensive, clear and has been developed based on learnings from first license renewal, research and operating experience

~The Peach Bottom SLR application will be consistent to GALL-SLR and GEIS to the greatest extent possible

~Exelon will submit a high quality application that can support an 18 month staff review

~The Peach Bottom SLR application development is on track for submittal in 3rd quarter 2018 6 - Exelon Generation

Subsequent License Renewal Surry Power Station

urry Power tation - Lead Plant Two Westinghouse 3-loop PW Rs Net Capacity: Each unit is 838 MW (net) => 1676 MW Capital Improvements rv $1B since previous LRA 40 60 80 Unit 1 1972 Years 2012 Years 2032 Years 2052 Unit 2 1973 2013 2033 2053 Lifetime Generation over 460,000,000 MWhrs

Dominion Assessment

  • Surry Power Station First station in fleet to reach 60 years (2032/2033)

Makes sense for Dominion, employees, stakeholders and customers Political landscape is supportive NRC notified of intent to apply for SLR (Nov-15)

Dominion Experience Highly experienced team involved in previous Dominion and industry LR applications Team members engaged in various SLR industry groups Extensive experience with the evolution of GALL/SRP (NUREG-1800/1801) for first renewals Direct involvement in GALL SLR review and SLR

  • industry guidance development Coordinated GALL-SLR issue resolution

LR- Circles of Support

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LR - Circles of upport

\odustry Support

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LR - Circles of Support

\f endor Support

\odustry Support

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Dominion SLR Application Will be a continuum from the first industry LR applications Will meet the expected standards established with the most recent industry LR applications Expected to be high degree of consistency with GALL-SLR AMPs will effectively manage the effects of aging to provide reasonable assurance for SLR period Quality will support an 18 month NRC review schedule

Dominion SLR -47 AMPs Mechanical Structural X I .M 1 A S ME Section X I I nservice Ins pec tion , S ubsecti o ns X I .1\1 3 0 Fue O il C h"mistry X I .S I A S ME So.ctl o n X I . S ubsec tion IWE

!'.NB , IWC . and 1\/1/D X I . fA 2W<::1 l E:t r G I 1 ~ 11 ib ll y X l .3 2AS IAE, :=.iat. liu 1X I , S ulJ ~t::teli<.: 11 I WL X I .M 3 R ea c tor Head :: 1osure S tud B *)ltino X l.1\1 32 C n e-T m;i l >sp ec ti on X l. S3AS ME Secti o n X I . S ubsection IWF X I .M 10 Boric l\cid ::: orr c*slon X I .M 33 Sel ect vc Looch i ng X l.S 4 10 C F R Pa -t 60, Ap p endix J

>,1. t.111 I b c r ackin g :)r 'i l c ke1 - a11 oy comi:o nerl( s 3nj Lo ss or X I .1\1 35 AS ME Cod e C la5S I S mall- B :)r e P 1p1ng X l. S5 Masonry W a lls M:::tt Ar;;:tln11A to Ro-ir.:Ad rt -ln11Ji": Ac1 Cnr-o c:;inn In R A ~ r:: t *l r CoolEnt r>res sure Boundery Co'Tip o r e nt s X I . t11 .* 4 I h erm a Aging ::mbrittle m e nt or <; a s t A u s t enitlc X I . M ~ b t:.xt erna l ::Hrr eces M o*itor i ng 0 1 M ec na nlcal X l. ::Jti c tru c tures M c nito nng S t ai nl ~ <;; ~ St~91 (CASS) Com pon e? n t:>

X I .M 16A PWR V e: s el lnte-nal s X I .M :J? rlu )( Thimbl e - ube In s pe c t o n X I .0 7 I nspec t lon *) f 'Nat e--C ontrol C: truc ture s .~ss o::. ic:ted v dtt-Nuc lea- f-'O\l\'e r f-'lan:s

>:I . M 17 Fl ovv-Ac:-e la rat Gd Co-r osion X I .f\..1 38 I n s pac tion of Interna l S urfaces ir Mi !:celta-ie *) US X I .SS Protec ti \.e C oatin g Monito ring a -. d Maintena nce P lp i ,g a nd Du.:. tin g Cv 111 po , e nt ~

X l .M1 8 B o ltin;i l

  • t eorty X I .1\1 39 L~brl c atlno O il Ana y: i s Electrical X I . t/119 Steam Gene r3t ors X I .1\1 4 ' Buri ed a nd Underoro unc Plpi>o a nd Tanks X I. E l El e *~ tr ca l Ins ulati o n f or E l ectri c al C abl e5 end Connoc ti on c N o t S ubj oot to 1 0 C F R 5J. L0 =.n v iro nm o nt:JI Q ua 11n c at1 o n Req u lrem e n:s
1. t11 20 O p en *CYcl e Cooliro 'Nat e- Sy st e m X I .1\142 I nce-nal C oatinos/ linl nos f or in scc;p P p i no. P ipino X l.E2 EleGtr cEI Ins ulati o n for Electri c al C able5 end Component3. Heet E ><c t-engers . end Tenk s C onne c ti on s N o t S ubj ect to 1 0 C Fn. 6J.L9 =: n v lronment =>I Q ua11ri c ati o n R 3 quir'3me rt s U sed In I nstrum e nta1 on C 1rcu1ts X I F 'lA FI Ar. -ri ~;;t l I n c; 1Jl :::\ti o n fnr I r:::t r.r.~i:; hi A MArl l 11m \In t i=t !)A P O\IV'3 r C abl es 'lot C utj e ct to . 0 C rR 50. 4 9 Cn virc nm e ntal

(..l uallil cat1 o n Ra qwrnme n:s Y I r.11 23 1-,s:i 9ction of 0 \.i?r-,P.3d H~a vy l oa d a rY.1 Light Load '><' .M1 F a tiguP. Mcnitoring .I . E 3 B EIP.c: ri r. at I nsL1l 3tion for I ra r..ces s b l ~ I n s trum1fltatlon (R ~ l atedt o REift...e ling) ..-ai- dling 3 ,'st e m s and Control Ceble s Net 3 ubj ec t to I 0 C FR !30. 4 8 Envi -onme n : al Q ual fi c atio n R ;iquiremerl(s

>:t.M 2 4 Co m p ress9 d ..O..ir M o nit o~l n;i X. M 2 l'J e utron Fluence l'vl onit orlng X I .E JC Electri ca l I nsula ti on f o r I na ccessib l ~ Lo...v Vo l:a ge P l.M"~ 1 G C:iJl tl::t 'JU C uLjt;t<;l LU

  • 0 C F R 50.4 9 E11 v il t..: 11111 tt11LC:tl Q ualifi c ation R 3quirnme nts "I . r.11 26 Fire Prot ecti on X. E I Envirc nmental Q ualifio ati o -, cf Ele , tr o Comi:; o nant s 1 X l .E ~ ll.1<>1al E ncl os,;d Bu~

X I . t/1 2 7 F ire Wate r Syst em l. E6 El ec t r cc;I Cabl e Cc nrecti ons N ot S ubj ect t o 1 0 C FR 5 0 . 4*) En vi r onri o ntc: I Q uolif cation R o qui -om ont c X I . t/1 29 O utdcor ard Laroe Atm osPh ar i;; M e ta l I c Tanks X I.E l Hio* Vol:a oe n s ulat cr s

NEI Roadmap -SLR imeline Subsequent License Renewal Timeline First license Begin licen se First SLR First SLR license 5 Year First plant renewal.

Plants enter the t"-

0 N

renewal submittal preparation application submitted 0

C\I approved byNRC minimum to submit SLR for to reach 60 years of operation period of continued extended operation operation per timely renewal

Summary NRC Staff has encouraged stakeholder review and input during GALL SLR/SRP development Dominion is engaged and integrated with the development of GALL-SLR and industry guidance Dominion team is experienced with LR/SLR and requirements Dominion will submit a high quality application to support an 18 month NRC review Surry Project Team is on schedule for a 1st quarter 2019 submittal

Subsequent -License Renewal David Lochbaum Director, Nuclear Safety Project www.ucsusa.org April 26, 2017 1

Issues

1) One-time SAMA evaluations
2) Safety by queue position
3) Public engagement
4) Knowledge management 2

Preface Neither license renewal nor subsequent license renewal is inherently unsafe.

Improperly maintained and operated reactors can get into trouble in less than 40 years.

Properly maintained and operated reactors can avoid trouble beyond 40 years.

3

One-time SAMA evaluations Severe accident mitigating alternative (SAMA) evaluations are required with initial license renewal application, unless already done for another reason, and are not required to be re-done for subsequent license renewal.

4

One-time SAMA evaluations SAMA evaluations are good ideas for ALL license renewals:

  • safety innovations may have emerged during the past two decades
  • populations may have changed during the past two decades
  • costs just may have changed during the past two decades 5

One-time SAMA evaluations 07-13-1999: NEI submits PRM seeking to delete the requirement for SAMA with license renewal applications 02-13-2001: NRC denied the PRM (ML010450132) citing its need to consider new and significant information

6

One-time SAMA evaluations

In the case of license renewal, it is the Commission's responsibility under NEPA to consider all environmental impacts stemming from its decision to allo~ the continued operation of the entire plant for an additional 20 years.

66 FR 10836 February 20, 2001 7

Safety by queue position 05-19-2004 NRC relicensed Ginna 09-30-2005 GALL/SRP Rev. 1 issued 12-23-2005 NRC relicensed Point Beach Point Beach had to develop an Alloy 600 aging management program (AMP) before NRC relicensed it.

Ginna was relicensed without an Alloy 600 AMP being required.

8

-~

§50.100 is black and white:

A license, permit, or standard design approval under parts 50 or 52 of this chapter may be revoked, suspended, or modified, in whole or in part, *** because of conditions revealed by the application or statement of fact of any report, record, inspection, or other means which would warrant the Commission to refuse to grant a license, permit, or approval on an original application ***

9

I NRC is cheating somebody If the increased safety measures in GALL/SRP Rev. 1 are truly needed to assure safety (as

§50.109 requires), then the people living around Ginna got cheated.

If the increased safety measures are NOT needed, then the shareholders and ratepayers of Point Beach got cheated.

So, whom did you all cheat?

10

NRC is cheating many 05-08-1995 10 CFR 50.54 issued 6 operating licenses renewed 07-31-2001 GALL/SRP Rev. 0 issued 29 operating licenses renewed 09-30-2005 GALL/SRP Rev. 1 issued 26 operating licenses renewed 12-31-2010 GALL/SRP Rev. 2 issued 27 operating licenses rene\Ned 11

Safety by queue position Position in line must not continue to determine which reactor has what safety measures and what owner pays which costs.

50.100 and 50.109 collectively must result in owners paying the same for renewed licenses and in communities receiving the same protections.

12

Public engagement By memo dated 09-12-2016, the NRC staff addressed public comments about subsequent license renewal during meetings it conducted May 9, November 1, November 13, and November 14, 2012 (ML16194A222).

I attended the May 5th 2012 meeting. My issues are addressed in Enclosure 3 to the 2016 memo.

13

Public engagement The NRC staff responded to my

safety by queue position

concern thusly:

"Reactors that *** wish to renew their licenses for 60-80 years of operation will most likely follow the guidance in the updated GALL and SRP when they prepare their applications but are not required to do so. Any applicant has the option to address the requirements through other means. In such cases, the staff will review the information and make a safety determination. In the end, all licensees must meet NRC regulations and demonstrate the ability to operate their plants safely during the SLR period."

14

Public engagement If raising license renewal standards was justified, NRC met 50.109 for Point Beach *but violated 5.100 for Ginna.

If raising standards was unjustified, NRC violated 50.109 for Point Beach but met 50.100 for Ginna.

Atomic Abe might have said you can't meet all the regulations all the time this way. 15

Public engagement?

05-09-2012 SLR public meeting 11-01-2012 SLR public meeting 11-13-2012 SLR public meeting 11-14-2012 SLR public meeting 01-31-2014 SLR SECY-04-0016 05-08-2014 SLR Briefing .  ?

08-29-2014 SRM SECY-04-0016

  • 09-12-2016 Staff memo resolving comments made during 2012 meetings 16

Knowledge management 17

Knowledge management The NRC and Nuclear CHAPTER4 Povver Plant Safety in 2014 .52 Positive Outcomes from NRC Oversight Tarnished Gold Standard 32 Fixing It Before It Break 33 Plugging the Brain Drain 35 Ob er ation on Effecti e RC ver ight UCS applauded NRC for undertaking knowledge management efforts a decade earlier.

18

Knowledge management Newer reactors have voluminous UFSARs and associated design and licensing bases information.

Older reactors have skimpier UFSARs and associated design and licensing bases information.

And regulations and regulatory bases today are different from the AEC and early NRC days.

19

Knowledge management Byron/Braidwood EDO appeal and numerous TIAs in recent years testify to the difficulties in trying to make safety decisions today using decades-old, often detail-lite design and licensing documents.

20

Knowledge management Will a 50.59 reviewer in 2060 really be able to ensure a proposed modification doesn't undermine safety margins established in the 1970s?

Will NRC inspectors accept that scantily explained 1970s methods conform with 2060 expectations?

21

U.S.NRC U nited States N uclear Regul ato ry Co mmission Protecting People and the Environment Briefing on the Status of Subsequent License Renewal Preparations Commission Meeting with NRC and Industry April 26, 2017

Agenda

  • Introduction and Key Messages
  • Status of SLR Guidance Documents
  • Overview of SLR Process Optimization
  • Summary of Changes in SLR Guidance
  • Status of Confirmatory Research Activities

Existing Regulatory Processes Are the Framework of License Renewal Regulations and Additional Guidance Aging Management Operating Support for Licensing Experience Decisions Oversight

Regulations and Processes Ensure Safe Operation

  • License renewal regulations ensure passive, long-lived structures and components perform intended functions
  • Continuous verification of safety through

.reviews and Reactor Oversight Process

License Renewal Framework Adequate for SLR

  • Additional focus on the adequacy of aging management programs (AMPs) and activities for the subsequent period of extended operation

Staff is Finalizing Regulatory Guidance for SLR

  • In December 2015, draft SLR guidance documents issued for public comment
  • In 20161 staff held nine public meetings and addressed public comments
  • Final SLR guidance to be issued July 2017

SLR Applications Expected in the Near Future

  • Peach Bottom Atomic Power Station

-SLR application expected mid-2018

  • Surry Power Station

-SLR application expected early 2019

  • Letters of intent useful in helping NRC prepare for anticipated submittals

Staff is Optimizing SLR Application Reviews

  • Identified modifications to optimize review of SLR application. New approach includes:

- Increasing the use of portals, telecommunications

- Early development of safety evaluation report and environmental impact statement

- Streamlining on-site audits

- Eliminating redundant inspections

  • Optimized review of high quality SLR application with no contentions could be completed in 18 months

Four Key Technical Issues for Operation Beyond 60 Years

  • Concrete and containment degradation
  • Electrical cable qualification and condition assessment

SLR Guidance Documents Enable Consistent Reviews of Applications

  • Generic Aging Lessons Learned for SLR (GALL-SLR) Report (NUREG-2191)

- Contains generic aging effects to be managed and appropriate AMPs

  • Standard Review Plan for the Review of SLR Applications for Nuclear Power Plants (SRP-SLR) (NUREG-2192)

- Contains guidance to NRC safety reviewers of the SLR application

Development of SLR Guidance Involved Rigorous Staff Review

  • Technical sources used for SLR guidance

- Expanded Materials Degradation Assessment

-AMP effectiveness audits at plants in the period of extended operation

- Relevant domestic and international operating experience

- External stakeholderl staff comments

Refinements to Current Guidance to Support 80 Years of Operation

  • New GALL-SLR Report AMPs

- Fluence Monitoring

-High Voltage Insulators

  • Modifications to Reactor Vessel Material Surveillance AMP

Changes Include Revisions to Electrical and Structural AMPs

  • Expanded Electrical Insulation of Cables AMP from one AMP to three AMPs to address aging of submerged cables at different voltages

- Updated for alkali-silica reaction (ASR)

-Added further evaluation for irradiation of concrete

NRC is Prepared to Review SLR Applications

  • GALL-SLR Report AMPs address technical issues
  • Plant-specific approaches for a few technical issues
  • Applicant's responsibility to evaluate technical issues, develop acceptable aging management methods

Staff is Ensuring Reactor Pressure Vessel Integrity BWRs

  • Confirming predictive methods using operating GO years experience (surveillance SO years

~

data) Z?

~u 150 . . . . - - - - - - - - - r - - - - - . - - - . .

e USA Surveillance Data QI 0

~ ...... 100 E ~

  • Assessing ~

c: w 0 c:

g 50 embrittlement at ',tj 0

  • v; c: u t'O :;::;

~ ....

0 *

~

  • ... * * ... * * ..,..._'WetliE higher fluence ~ ~

N'O. -50 c: .....

levels m*-

....~ ~

-100

[Source: ASTM E900, 2015]

c:

1£+17 1E+18 1£+19 1£+20 2

Fluence [n/cm ], E > 1 MeV

Staff is Assessing Effects of Irradiation-Assisted Degradation of Internals

  • Evaluating impacts of IASCC, loss of fracture toughness, and void swelling
  • Testing materials at higher irradiation levels Cracking in a PWR baffle bolt

Staff is Assessing Concrete Degradation

  • Evaluating effects of 0:i~* 0 ( G.* o' ** c
  • 1 * ';. $ *~ ~ .

0 0

ASR on structural 0 0

performance of ". * ~* / ~~ <4", '

concrete

  • Confirming structural integrity Reactive Aggregate Cracking through Aggregate

Staff is Confirming Structural Concrete Integrity

  • Evaluating effects of irradiation on concrete structures /*:***- * .,,,,

- Confirming DOE concrete r I .

irradiation damage and EPRI i I* ~ 1'.

concrete structural 1'

  • performance results

- Assessing EPRl's evaluation of . , .* _

susceptible plant configurations{  :!

- Assessing neutron fluence and '. .. , :

gamma dose on structural bio- ~~~. ~*>**

    • .i<

shield concrete ~=:;;;;;;;;l.J

Staff is Confirming Adequacy of Cable Condition Assessment Techniques

  • Evaluating synergistic effects of gamma radiation and thermal ~~

exposure in low voltage cables Thermal aging of jacketed cables

  • Confirming assessment of medium voltage coble submergence qualification

NRC Demonstrating Readiness to Accept and Review SLR Applications

  • Extensive stakeholder engagement continues
  • Confirmatory research ongoing for technical issues
  • NRC ready to accept and review SLR applications

Acronyms

  • ASR: Alkali-Silica Reaction
  • DOE: Department of Energy
  • EPRI: Electric Power Research Institute
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