ML19282A379
| ML19282A379 | |
| Person / Time | |
|---|---|
| Issue date: | 09/04/2019 |
| From: | Kent Howard Advisory Committee on Reactor Safeguards |
| To: | |
| Howard, K, ACRS | |
| References | |
| NRC-0552 | |
| Download: ML19282A379 (140) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number:
(n/a)
Location:
Rockville, Maryland Date:
Wednesday, September 4, 2019 Work Order No.:
NRC-0552 Pages 1-112 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 666TH MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 WEDNESDAY 8
SEPTEMBER 4, 2019 9
+ + + + +
10 ROCKVILLE, MARYLAND 11
+ + + + +
12 The Advisory Committee met at the Nuclear 13 Regulatory Commission, Two White Flint
- North, 14 Room T2B3, 11545 Rockville Pike, at 1:00 p.m., Peter 15 Riccardella, Chairman, presiding.
16 COMMITTEE MEMBERS:
17 PETER RICCARDELLA, Chairman 18 MATTHEW W. SUNSERI, Vice Chairman 19 JOY L. REMPE, Member-at-Large 20 RONALD G. BALLINGER, Member 21 DENNIS C. BLEY, Member 22 CHARLES H. BROWN, JR., Member 23 MICHAEL L. CORRADINI, Member 24 VESNA B. DIMITRIJEVIC, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 WALTER L. KIRCHNER, Member 1
JOSE MARCH-LEUBA, Member*
2 DAVID PETTI, Member 3
HAROLD B. RAY, Member 4
5 6
DESIGNATED FEDERAL OFFICIAL:
7 WEIDONG WANG 8
10
- Present via telephone 11 12 13 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 CONTENTS 1
Opening Remarks by the ACRS Chairman 4
2 Advanced Reactor SECY Policy Paper on Siting 6
3 Turkey Point Subsequent License Renewal..... 48 4
Adjourn....................
112 5
6 7
8 9
10 11 12 13 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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4 P R O C E E D I N G S 1
(1:00 p.m.)
2 CHAIRMAN RICCARDELLA: The meeting will 3
come to order. Today is the first day of the 666th 4
meeting of the Advisory Committee on Reactor 5
Safeguards.
6 I'm Pete Riccardella, ACRS Chairman.
7 The ACRS was established by the Atomic 8
Energy Act and is governed by the Federal Advisory 9
Committee Act, FACA.
10 The ACRS section of U.S. NRC public 11 website provides information about the history of the 12 ACRS and provides FACA-related documents, such as 13
- chapter, bylaws, Federal Register Notices for 14 meetings, letter reports, and transcripts of all full 15 and subcommittee meetings, including all slides 16 presented at the meetings.
17 The committee provides its advice on 18 safety matters to the Commission through its publicly 19 available letter reports. The Federal Register Notice 20 announcing this meeting was published on August 6th 21 and provides an agenda and instructions for interested 22 parties to provide written documents or request 23 opportunities to address the committee, as required by 24 FACA.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 In accordance with FACA, there is a 1
Designated Federal Official for today's meeting. The 2
DFO for this meeting is Mr. Weidong Wang.
3 During today's meeting, the committee will 4
consider the following: Advanced Reactor SECY Policy 5
Paper on Siting, Turkey Point Subsequent License 6
Renewal, and Preparation of ACRS Reports.
7 There is a phone bridge line. To preclude 8
interruption of the meeting, the phone will be placed 9
in a listen-in mode during presentations and committee 10 discussion.
11 We have received no written comments or 12 requests to make oral statements from members of the 13 public regarding today's session. There will be an 14 opportunity for public comment, as we have set aside 15 10 minutes in the agenda for comments from members of 16 the public attending or listening to our meeting.
17 Written communications may be forwarded to 18 Mr. Weidong Wang, the Designated Federal Official.
19 A transcript of the open portions of the 20 meeting is being kept, and it is requested that 21 speakers use one of the microphones, identify 22 themselves, and speak with sufficient clarity and 23 volume, so that they can be readily heard.
24 I would like to request that everybody 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 silence their cell phones or other devices that might 1
make noise in the meeting.
2 And I also believe we have Member Jose 3
March-Leuba on a private line calling in. He is 4
hurricane-bound in Florida, but he will attend 5
remotely.
6 Jose, are you there?
7 MEMBER MARCH-LEUBA: Yes, I'm here. Thank 8
you.
9 CHAIRMAN RICCARDELLA: Okay. Very good.
10 So the first topic, as I mentioned, is 11 Advanced Reactor SECY Policy Paper on Siting, and I 12 would like to ask the Subcommittee Chairman, Dennis 13 Bley, to introduce the subject.
14 MEMBER BLEY: Thank you, Mr. Chairman.
15 And thanks to everyone for having the phones working 16 today. It's great.
17 We had a subcommittee meeting a few weeks 18 ago, and most of the members were there. Some issues 19 were raised, and I hope our presenters from the staff 20 will address some of those issues if they can.
21 At this point, I will turn the session 22 over to John Segala, NRO.
23 MR. SEGALA: Thank you, Dr. Bley, and 24 thank you, Chairman Riccardella, and the other 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 committee members, for the opportunity to present 1
today on this important topic of population-related 2
siting considerations for advanced reactors.
3 As you know, this is a topic that has a 4
long history. And as Dr. Bley said, we briefed the 5
subcommittee meeting on August 23rd, and had a lot of 6
good discussions, and we're prepared today to answer 7
some of the committee/subcommittee's comments.
8 At the end of this meeting, we'll be 9
requesting a letter from the full committee on our 10 draft Commission paper.
11 And with that, I'll turn it over to Bill 12 Reckley, a senior project manager in my branch.
13 MR. RECKLEY: Thanks, John. As John 14 mentioned, this paper is related to population-related 15 siting consideration. I just kind of want to stress 16 that siting has a lot of different considerations, 17 both on the site as a potential hazard to the reactor, 18 and then of course the reactor as a potential hazard 19 to the environment. And this paper is limited to a 20 small slice of those issues, which is related to 21 population around a site.
22 So the purpose of the paper is to provide 23 the Commission with options and a recommendation on 24 possible change to the guidance documents. I will get 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 into some of this in a little more detail, but right 1
from the beginning emphasize that we don't see at this 2
time a need to change regulations, but we think the 3
situation would benefit from revision to the guidance 4
documents; in particular, Regulatory Guide 4.7.
5 So the paper is laid out with that 6
purpose, some background in terms of regulations and 7
guidance, a discussion, which is largely a description 8
of the options, and then a specific recommendation 9
from the staff to the Commission.
10 I have tried to collapse all of that in 11 terms of regulations and guidance onto this one graph.
12 And you can see up this -- up the left side are the 13 regulations that most of us are most familiar with, 14 and that is 10 CFR 100.21, as it relates to defining 15 exclusion areas, low population zones, and population 16 center distances.
17 And just to summarize those circles, the 18 exclusionary boundary is defined actually within 19 Part 50 and Part 52 as that distance at which an 20 individual would receive less than 25 rem in two 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br />, the worst two hours of an accident.
22 MEMBER BLEY: Bill?
23 MR. RECKLEY: Yes.
24 MEMBER BLEY: You said this only focuses 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 on population, which is the outcome. But it's deeply 1
involved with all of the other aspects that affect 2
what the doses are going to be, which you can't 3
ignore. And I'm going to express a little surprise, 4
and you may have this covered later, one has to decide 5
for which accidents they are going to calculate the 6
doses, which really has to do with a lot more, 7
including risk.
8 And I'm a little curious why you folks 9
didn't have an option, maybe I'd call it 3A, that 10 really tried to be risk-informed about the criteria 11 that we use. And I don't know if you can plan to get 12 to that later. If you do, that's just fine.
13 MR. RECKLEY: Yeah. I think in about two 14 slides I'll try to address that. And if I don't 15 succeed, you can continue with the question.
16 So, again, the standard definitions down 17 the left side there, for the low population zone, 18 which is the distance at which 25 rem would -- less 19 than 25 rem to an individual for the duration of the 20 accident, and then a low -- a population center 21 distance, which is defined in the rules as being one-22 and-a-third times the radius of the low population 23 zone. And that is the minimum distance to which a 24 reactor could be in relation to a population center of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 about 25,000 people.
1 Over on the right side, you have 10 CFR 2
100.21H, which is a vaguely worded rule.
3 MEMBER CORRADINI: Can I --
4 MR. RECKLEY: Go ahead.
5 MEMBER CORRADINI: I want to repeat 6
something that I wrote down, but I could have it 7
wrong, from the subcommittee meeting. The definition 8
of a population center is a tad fuzzy.
9 MR. RECKLEY: Yes.
10 MEMBER CORRADINI: It's not precise, as I 11 remember you stating at the time.
12 MR. RECKLEY: Right.
13 MEMBER CORRADINI: True?
14 MR. RECKLEY: Yes.
15 MEMBER CORRADINI: Okay.
16 MR. RECKLEY: Well, it is about 25,000.
17 MEMBER CORRADINI: Well, I guess the 18 boundary of where I draw -- where I count 25,000 19 people --
20 MR. RECKLEY: It's a population boundary, 21 not a political boundary.
22 MEMBER CORRADINI: Okay.
23 MR. RECKLEY: So you look for where the 24 actual population is. You map that out, and that's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 the distance to the population center, not necessarily 1
the political boundary of a -- you know, an 2
incorporated town or a city limit.
3 MEMBER CORRADINI: So the centroid of 4
where the population rises to or near 25,000.
5 MR. RECKLEY: Yes.
6 MEMBER CORRADINI: Okay.
7 MEMBER BLEY: I'm sorry. You said 8
"centroid," which implies the middle, and it's not.
9 MR. RECKLEY: The edge of the population 10 boundary.
11 MEMBER CORRADINI: But if it's not the 12 political boundary, then I could have a farm, a dairy, 13 since I'm that part of the country, a dairy entity.
14 And if I add up the 25,000, and the dairy farm is the 15 closest thing to 25,000, that's the boundary? I'm 16 still struggling as to how I get the 25,000 if it's 17 not the center of it.
18 MR. RECKLEY: Right. It did -- take a 19 case where you just draw where an actual population, 20 like a town where the residences start. So, in your 21 case, you would probably skip over the farm, right?
22 Skip over those couple hundred acres of the farm, even 23 if they're in the political boundary, and go to where 24 the actual residences, the suburban type, the actual 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12
-- with some density of that population, draw a circle 1
around it. This is very inexact.
2 MEMBER CORRADINI: Okay. So that's all I 3
was trying to get at. It's inexact, and it's a matter 4
of judgment and conversation, not a clear -- it's not 5
like a -- it's not like, you know, normal distribution 6
I take the 595 of the population and it adds up to 25.
7 MR. RECKLEY: For that population center.
8 Now, when we get to the next one, which is under 121H, 9
where we're looking at population density, and that 10 rule is also vaguely worded, it says located away from 11 population centers in low population densities are 12 preferred.
13 The way we meet that rule is through the 14 guidance in Reg Guide 4.7 that looks at population 15 density of 500 persons per square mile and ever-16 increasing radius. So the first mile you couldn't 17 have more than 1,571 people; in the second mile, 18 6,000; and it keeps going with those constraints until 19 you get to the limit of 20 miles. We look at 20 population density out to 20 miles, and the population 21 within that 20-mile circle would have to be less than 22 628,000 people.
23 And so those things in combination are how 24 you basically address some of the issues and some of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 the vagueness that you're referring to.
1 MEMBER RAY: To respond to Mike again a 2
little bit, I just want to draw attention to the fact 3
we're talking about densely populated. And the farm 4
example you gave isn't an example of densely 5
populated.
6 MEMBER CORRADINI: But I could have -- I 7
could have -- I won't use a particular town that I am 8
aware of, but a town in the Midwest which has a 9
population of suburban -- or of houses, but then as I 10 move out I could have farms that are closely packed 11 but that are within the political boundary, but may 12 not be in the population center.
13 MEMBER RAY: They are not in -- in my 14 judgment, they are not in a densely populated center.
15 They are outside the densely populated center.
16 MR. RECKLEY: Right. Even though they 17 might be in the political boundary. Right.
18 MEMBER RAY: Or in between you and the 19 densely populated center.
20 MR. RECKLEY: Yes.
21 MEMBER RAY: For example.
22 MR. RECKLEY: Right.
23 CHAIRMAN RICCARDELLA: Bill, I'm sorry.
24 I wasn't able to attend the subcommittee meeting, but 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 these -- the 25 rem for the two other zones, that 1
assumes what some accident under some design -- under 2
the design basis accident or something.
3 MR. RECKLEY: In the traditional sense, it 4
includes the Reg Guide 1465, the alternate source 5
term, or before that the TID 14484. Source term, into 6
the containment, and then with the conditions of the 7
allowable leakage out of the containment, in a 8
traditional sense.
9 In a second, I will get to an alternative 10 to that for advanced reactors.
11 CHAIRMAN RICCARDELLA: Okay. Thank you.
12 MR. SEGALA: And I'd just like to add for 13 the Reg Guide, it has you project out the population 14 five years from the initial siting, and it also says, 15 you know, reactors should not be located at a site 16 where the population density is well in excess of the 17 500. So even -- it's a guidance document, so it's not 18 a strict acceptance criteria, 500.
19 MR. RECKLEY: Keeping in mind that the 20 rule that we're enforcing says population -- low 21 population density preferred. It's an unusual rule, 22 and it dates back to the fact that this siting 23 guidance and siting as a policy for the Commission 24 goes back to the beginning, really. This guidance was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 first written in 1962.
1 So as we looked at it and interfaced with 2
stakeholders, there were two issues that we identified 3
with the planned uses of advanced reactors, and in 4
particular small modular reactors, and the guidance as 5
it was written, and called on us to assess whether we 6
could change the guidance while maintaining 7
appropriate public safety and conformance to the 8
rules.
9 The first was the limitation of 500 10 persons per square mile out to 20 miles, and the 11 second one -- policy issue was actually the same 12 population density, but close in to a reactor site.
13 So if you go back to the previous slide, you can see 14 a potential use for small modular reactors or advanced 15 reactors in general would be for remote areas.
16 And so take a remote area, a small town in 17 Alaska, this would say -- the current guidance would 18 say that population within the first mile couldn't 19 exceed 1,500 people. The desire would be to have that 20 reactor most likely closer to the town than a mile 21 away, because the reason you want it there is that it 22 currently has no grid.
23 The other area of concern was within DOE 24 and other stakeholder interest was the possible use of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 reactors to replace retiring fossil units. And they 1
might be closer to population centers than the 20-mile 2
criteria or the 15-mile criteria would allow in terms 3
of populations within that circle being limited to 4
350,000 in the case of 15 miles.
5 And so if a reactor can safely be put 6
somewhere, would it make sense to revise the siting 7
guidance to allow it? And that was the matter that we 8
were looking at.
9 MEMBER BLEY: Bill, one thing that bothers 10 me about the right-hand side of this figure is when 11 you put total populations in there, assuming a 12 population density, and rings around the reactor, the 13 population is going to be off somewhere away from the 14 reactor. And in one direction, the population density 15 could go quite high, where if you average it in rings 16 by miles away from the reactor, you could make it look 17 very low.
18 And is this kind of setting up per mile 19 rings? Is that specified in the reg guide?
20 MR. RECKLEY: I think there is actually 21 some look by sector in addition to rings, to totally 22 avoid what you're saying.
23 MEMBER BLEY: Because you would really be 24
-- it would really be smooshing out the population 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 where it isn't and saying I have a low population 1
density when --
2 MR. RECKLEY: It is looked at in a little 3
more than just the consent agreements.
4 MEMBER BLEY: Okay.
5 MR. RECKLEY: So with that as background, 6
some of the additional background and history relating 7
to siting is in an Oak Ridge report, and I gives the 8
ADAMS accession number there.
9 They also developed a possible approach, 10 and I'll be talking about that in a second. That's 11 Option 2.
12 So the staff developed four options. As 13 you can kind of get out of this conversation, there 14 are many ways that one could approach this. So we 15 could have had many more four options, but we did 16 narrow it down to try to give the Commission an idea 17 of different ways that this might be addressed.
18 So one of the things that we did do is 19 look at the paper and some of the comments and some of 20 the discussion we had on August 23rd during the 21 subcommittee meeting. And we're -- in the background 22 there are some proposed changes that would summarize 23 what would we -- what we would put in the paper.
24 But there were three main items that I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 took away anyway. One was to reinforce that this 1
guidance is related to unplanned releases and 2
accidents. There are rules in place for normal 3
effluents, normal operations. That is continued to be 4
controlled under those regulations such as 10 CFR Part 5
20.
6 Another question was on how Option 3 would 7
be implemented, and this goes to what Dr. Bley was 8
mentioning. What events do you look at? How are you 9
getting a source term in order to calculate the dose 10 for Option 3, which is the one that is based on an 11 assessment of the individual dose at a distance.
12 And there's two possible approaches that 13 we've talked about within the paper, and we tried to 14 clarify a little bit with the footnote in the backup 15 slides. The first is how we expect it to be pursued 16 for those that are using the methodology described in 17 draft Guide 1353 and NEI 18-04. That's the risk-18 informed approach that we brought before the committee 19 six months ago or more.
20 And in that -- if the reactor -- the 21 designer is using that methodology, they will develop 22 a mechanistic source term for the event sequences.
23 They will evaluate all of the event sequences in the 24 categories of design and beyond design basis events, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 and they will assess the offsite consequences.
1 And that would be the dose coming out of 2
those two event categories that they would compare to 3
the one rem in a month that we talk about under Option 4
- 3. And I'll get -- I know it's a little disjointed 5
here.
6 But another question that came up was the 7
-- how multi-unit events are handed. And so that same 8
footnote we were able -- a different footnote, we were 9
able to describe that 1353 or NEI 18-04 is done by 10 plant year. And so they are specifically looking at 11 multi-unit events or events that could affect more 12 than one radionuclide source in that event. So 13 whether it be reactors or off-gas systems or whatever 14 the source term might be.
15 MEMBER CORRADINI: So this is in the 16 current SECY that we saw?
17 MR. RECKLEY: It was hinted at in the 18 backup slide. The backup slide hopefully goes into a 19 little more detail now.
20 MEMBER CORRADINI: In the footnotes, right 21 under Option 3, it was discussed there; did I miss it?
22 MR. RECKLEY: Well, only vaguely, as 23 Dr. Bley mentioned. It says --
24 MEMBER CORRADINI: So let me now do -- my 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 hand calculation is if I have five of these, I have 1
five plant-years for every real year. That's what you 2
just said to me. That if I have five of these 3
collocated and there's a multi-module site, I would --
4 for every year passing I would take five plant-years 5
as the frequency effect? That's what I thought you 6
used by the term "plant-year" in the assessment.
7 MR. RECKLEY: Really, the way that this 8
methodology works, you're looking at the probability 9
of an event at the plant. That could be a single-unit 10 event or a multi-unit event.
11 MEMBER CORRADINI: Okay. So, in other 12 words, as some licensees might come in and calculate 13 what is with many on a site, many on a plant site, it 14 would not be a module, but it would be a module times 15 some multiplier by some definable review procedure.
16 MR. RECKLEY: Yes.
17 MEMBER CORRADINI: Okay. Very good. I 18 misunderstood. Thank you.
19 MEMBER REMPE: Since he interrupted you, 20 I'm looking at page 21 of the backup slides. And I 21 get the -- that you have -- again, right now, you have 22 beyond -- design and beyond design basis events if 23 they use 1353. But if they use a different approach, 24 it looks like they don't have to consider beyond 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 design basis events. They only look at possible plant 1
transients and accidents.
2 MR. RECKLEY: And what we're trying to 3
define there, and we got into this trouble in the 4
subcommittee meeting, and part of the problem is after 5
50 years no one agrees on the terminology, they would 6
do it the way they do it now.
7 So if you consider NUREG-1465 source term 8
as a design basis accident source term, then call it 9
a design basis accident source term. If you consider 10 it to be a beyond design basis accident source term, 11 then consider it to be a beyond design basis accident 12 source term.
13 MEMBER CORRADINI: But it's a source term 14 with containment performance specified in -- or some 15 sort of performance measures that are considered to be 16 conservative.
17 MR. RECKLEY: Yes. And a source term that 18 was considered to be conservative.
19 MEMBER CORRADINI: Correct. So it's 20 essentially a non-light water equivalent of 1465 with 21 Reg Guide 1.183 attributes.
22 MR. RECKLEY: Yes.
23 MEMBER CORRADINI: Okay.
24 MEMBER REMPE: So if I have a small micro 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 reactor and I don't want to try and do a PRA, I just 1
want to do a maximum hypothetical release. Does that 2
mean -- can they argue and say that that's not within 3
our design basis? That's never going to happen. Do 4
they have to do a maximum hypothetical release? What 5
will they do?
6 MR. RECKLEY: We're looking at that now.
7 So it's a little clearer under the 1353 that they 8
would categorize it. If they want to propose an 9
alternative, and we mention this in a section of the 10 draft guide, that if somebody wanted to use a maximum 11 hypothetical, they could do that, but that's really a 12 deviation from the guidance in NEI 18-04 and 1353.
13 So they are going to be coming in on their 14 own to justify that they have in that case identified 15 the actual maximum hypothetical accident to use in the 16 proposal.
17 So these aren't -- anyway, so they would 18 have to come in and justify that.
19 MEMBER REMPE: It doesn't fall under 20 Option 3, then. It's something different. I've 21 forgotten -- it's been a while since I've read the 22 draft, so --
23 MR. RECKLEY: It could, if they could 24 convince us that it was a maximum hypothetical. That 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 would, in effect, bound the beyond design basis event 1
in DG-1353. And so they could -- they could use this 2
guidance if they can convince us that they actually 3
have identified the maximum hypothetical.
4 MEMBER CORRADINI: Can I reverse this? If 5
I have a particular design with a particular set of 6
analyses that say nothing rises above five times 10-7, 7
one might have to infer some maximum credible accident 8
to at least decide what the distances are.
9 What if I have Joe's reactor, and Joe's 10 reactor is so safe that they buy their analysis, show 11 that nothing rises on a frequency basis above five 12 times 10-7, with uncertainty, therefore, I have to --
13 I have to define some maximum credible accident to 14 decide what the boundary is.
15 We were only talking the reverse 16 direction. I'm thinking that this other direction is 17
-- with inherent features of the design and the 18 passive design, I'm still going to have to identify 19 something as to decide what the boundary is.
20 MR. RECKLEY: Let me just pass on the 21 hypothetical. Basically, you're saying if I can -- if 22 I can design a reactor that has basically no chance of 23 releasing the radioactive materials, or at least --
24 MEMBER CORRADINI: Frequency under 1353.
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24 MR. RECKLEY: -- of below five times 10-7.
1 MEMBER CORRADINI: Yeah. Because we have 2
some already that --
3 MR. RECKLEY: I would hope that if 4
somebody is able to do that, we would say, "Great 5
job."
6 MS. CUBBAGE: So, Bill, what if you looked 7
at your Example 3 -- this is Amy Cubbage -- your 8
slide, it's less than one. Not Slide 3, it's Slide 9
- 12. I'm sorry.
10 MR. RECKLEY: Yeah. We'll get there under 11 that proposal, as to what the siting limitations would 12 be.
13 MEMBER CORRADINI: But back to Joy's 14 question, I want to make sure that we're clear. So 15 now at least in words in the revised SECY, there is a 16 path where the individual applicants could say we're 17 going to follow 1353 and those estimates for 18 mechanistic source term and frequency, et cetera, but 19 I can also take another path and write my own approach 20 to a new 1465 that has the appropriate attributes and 21 is conservative and bounds it.
22 MR. RECKLEY: Yes. We said we would 23 review that. But, again, that is going to be a 24 deviation, and we'll review it as a specific proposal.
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25 MEMBER REMPE: And in that deviation, do 1
they get to stop at accidents, or do they need to go 2
to beyond design basis? Because the footnote to me 3
implies they don't have to go to beyond design basis.
4 They get to stop at accidents.
5 MR. RECKLEY: Well, keep in mind that the 6
light water methodology, with the stylized events and 7
the use of 1465, is light water reactor.
8 MEMBER CORRADINI: But what generated the 9
1465 source term are severe accidents that are beyond 10 the design basis.
11 MEMBER REMPE: Right.
12 MEMBER CORRADINI: So I would assume in 13 light way they would have to come up with a class of 14 potential accidents that are beyond their design base, 15 and then basically encapsulate with conservative 16 calculations to be the equivalent of a 13 --
17 MEMBER REMPE: Put Slide 21 up, if you 18 would, just for a minute. This is the revised --
19 MEMBER BLEY: I'd remind all of the 20 members we have only allotted an hour for this follow 21 up to the subcommittee.
22 MEMBER CORRADINI: Sorry.
23 MEMBER REMPE: That's what is kind of 24 bothering me, the mark-out of including design basis.
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26 MR. RECKLEY: And the reason I marked that 1
out -- I can put it back in, to be honest. The reason 2
I put it out -- struck it out was because it causes so 3
much confusion in what we do now, not in what we would 4
propose to do under 1353.
5 The source term that we use, whether you 6
calculate it under 1465 or the old TID, is called 7
different things by different people. And so that's 8
the concern.
9 So what I tried to do was to strike out 10 the confusion and say, "Do it by NUREG-800, the 11 standard review plan, and do it by Reg Guide 1.183,"
12 that defines how that is done, and try to avoid the 13 confusion of the terminology, because sometimes it's 14 called maximum credible, sometimes it's called maximum 15 hypothetical, sometimes it's called design basis.
16 MS. CUBBAGE: And if you look at the 17 sentence in question, striking the beyond design 18 basis, the words prior to that are talking about a 19 wide range of potential accidents.
20 MR. RECKLEY: Right.
21 MS. CUBBAGE: And that's not limited to 22 DBA.
23 MEMBER REMPE: Okay.
24 MR. RECKLEY: And then the third bullet 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 there is the rationale for option three that was 1
discussed. We didn't change the paper.
2 We maintained the basis as the existing 3
criterion on population density, 500 people per square 4
mile, the compatibility with the methodology in DG-5 1353, and that's where we're getting the one rem over 6
a month for the analysis of the event sequences, and 7
engineering judgment for a multiplier that should take 8
that radius and multiply it by two. The --
9 MEMBER BLEY: Bill, right there, owing you 10 had the 30 days instead of --
11 MR. RECKLEY: Instead of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
12 MEMBER BLEY: -- 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, I get how 13 you're using 1353 to come up with the event sequences 14 to look at. What seems odd to me is, since we've 15 looked at 1353 and you guys have developed it, which 16 is looking for a risk informed --
17 MR. RECKLEY: Right.
18 MEMBER BLEY: -- approach, you could have 19 followed on with a risk informed approach to the 20 criteria, but you've put in what smelled like 21 arbitrary criteria once again, and why?
22 MR. RECKLEY: Again, as I said in the 23 beginning, we could have come up with a lot of 24 different alternatives.
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28 When we came up with option three, we were 1
trying to look at what, the limitations designers were 2
currently facing and whether we could come up with an 3
option that would maintain safety, but give them the 4
flexibility in siting, and after that, to stay as 5
simple as we could.
6 And really, as simple as we could was to 7
maintain the same criterion, 500 persons per square 8
mile, and then to introduce, as you mentioned, which 9
has got a risk informed element in it, the calculation 10 of the consequences, the one rem over a month.
11 And then the way we did the multiplier, to 12 be honest, I guess I can be honest, right, when we 13 first proposed this to stakeholders, our proposal was 14 two times the EPZ, and the reason it was two times the 15 EPZ is because that's roughly how it works out now.
16 The EPZ is 10 miles. We measure population density 17 out to 20 miles, so it's two times the EPZ.
18 As we interfaced with stakeholders, we 19 were convinced that linking it directly to the 20 emergency planning arena was probably not wise, and so 21 we withdrew the EPZ calculation and replaced it with 22 the LMP one rem over a month calculation.
23 I understand it's similar and they're not 24 unrelated, but it's a different parameter by a bit, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 but we kept the two. We kept the factor of two.
1 And footnote seven in the draft that you 2
have says the result of that will be that the area in 3
which we look at population density will be roughly 4
equivalent or slightly greater than two times the EPZ 5
and that's because the EPZ is two rem, I mean one rem 6
in the worst 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. The LMP criterion is one rem 7
over the month.
8 MEMBER CORRADINI: And the times two is 9
just a factor of safety?
10 MR. RECKLEY: Yes, and again, in the 11 beginning, it was tied to the current practice --
12 MEMBER CORRADINI: Okay.
13 MR. RECKLEY: -- and we just maintained 14 that.
15 MEMBER CORRADINI: So just to repeat the 16 subcommittee, so is the staff planning to do any 17 calculations to understand the technical basis of all 18 of these choices?
19 MR. RECKLEY: The difficulty is -- the 20 short answer is no, and the reason is there's too many 21 variables in play, and that's because a large part of 22 what we're trying to do is to introduce a sense of a 23 societal measure without defining a societal measure, 24 and if you wanted a calculation that would push us in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 the direction of having to define some things in order 1
to back out what the appropriate number would be.
2 And so we thought about it and really 3
thought that it would be wiser just to pick a number.
4 If it comes across as engineering judgment, which, I 5
guess, in many parlances would also be synonymous with 6
arbitrary, that's where we are.
7 MEMBER CORRADINI: Okay.
8 MEMBER BLEY: Well, it's not always 9
arbitrary.
10 MR. RECKLEY: No.
11 MEMBER BLEY: To help you finish --
12 MR. RECKLEY: Yes, we're going to go 13 through it.
14 MEMBER BLEY: -- when you get to option 15 two, since you don't favor option two --
16 MR. RECKLEY: Yeah.
17 MEMBER BLEY: -- and nobody on the 18 Committee favors it, going through the details is very 19 plodding and slow.
20 MR. RECKLEY: Right, okay.
21 MEMBER BLEY: Just give the overview of 22 what it was trying to do.
23 MR. RECKLEY: Okay, I'll go quickly then 24 through the options. Option one is just the status 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 quo. So we've talked about that already under what 1
the current requirements are, so I'll skip through 2
that one.
3 The option two description is the best in 4
this slide in which a rough equivalent societal risk 5
measure is defined as the area times the source term 6
factor times the people per square mile. Slide nine 7
gives the same example I used during the Subcommittee.
8 If you assume a proportional reduction in 9
the area of contamination with the dose factor, which 10 would be roughly proportional to power level, you can 11 work through an example, as is given on this slide, 12 where instead of 1,200 square miles for a small 13 reactor, you would be facing a contamination area of 14 more like 63 square miles.
15 MEMBER BLEY: The bottom line is you're 16 scaling on power.
17 MR. RECKLEY: Yes, in the paper, we 18 proposed to take the source term factor and equate it 19 to power level. Again, the whole thing is a rough --
20 it generally holds, but it's not an exact correlation 21 if you try to back it out.
22 So some of the advantages, it's relatively 23 simply. It does allow designs, attributes to 24 considered somewhat, primarily in the area of power.
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32 Disadvantage listed there, will face some negative 1
perceptions no matter what changes to siting criteria 2
we pursue.
3 So going onto the recommended approach, 4
option three, again, the rules stay the same, so you 5
maintain the exclusionary boundary and low population 6
zone.
7 The guidance would be changed in Reg Guide 8
4.7 to call out that for plant designs that could show 9
that the event sequence doses for plants that have 10 event sequence doses that exceed one rem TEDE over a 11 month beyond the site boundary, we would look at 12 population density and we would look at it somewhat 13 similar to what we do now, the population density of 14 500 persons per square mile, and we would look, as we 15 just talked, over the radial distance equal twice the 16 radius at which one rem was estimated.
17 MEMBER BLEY: Can I correct my earlier 18 comment? I went back and looked at 42 and 47, 4.7.
19 They only do the averages over the rings. They don't 20 do any sector thing in there, at least in the table I 21 was looking at.
22 MR. RECKLEY: I'll look in mine actually.
23 Is that what you look at, just the rings, or do you 24 look at sectors, Rao or Michelle?
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33 MR. TAMMARA: My name is Rao Tammara. I 1
do the chapter two. Yeah, it is the rings.
2 MR. RECKLEY: Okay, I stand corrected.
3 I'm sorry.
4 MR. TAMMARA: The definition is you can go 5
to the total population divided by the area.
6 MEMBER BLEY: And that kind of says we're 7
averaging --
8 MR. RECKLEY: Yes.
9 MEMBER BLEY: -- over all of these people 10 11 MR. RECKLEY: Right.
12 MEMBER BLEY: -- too, so.
13 MEMBER PETTI: So, Bill, that last bullet 14 says "for event sequences greater than one rem." What 15 if the reactor has no event sequences greater than 16 one?
17 MR. RECKLEY: We'll get there in a second.
18 MEMBER PETTI: Okay, great.
19 MR. RECKLEY: Next slide. So you can look 20 at this option, and during the Subcommittee and on 21 this slide, I tried to boil it down to one slide, at 22 three cases.
23 One, you have event sequences with 24 significant doses approaching 25 rem offsite, in which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 case you'll have traditional exclusionary boundaries, 1
low population zones, population center distances 2
calculated per the rule.
3 In addition to that, whatever distance you 4
calculate one rem over the month, you would look at 5
500 people per square mile out to twice that radius.
6 So you have both the rule and the guidance affecting 7
the total population and also the population center 8
distance.
9 In the second, you have no event sequences 10 with offsite doses approaching 25 rem, but you do have 11 event sequences that are exceeding one rem over the 12 month following an event. So with no doses of 25 rem, 13 you have the low population zone collapse to the site 14 boundary, but with event sequences that have doses 15 over one rem, you're still going to look at population 16 density and keep it less than 500 people per square 17 mile out to twice the radius at which you calculate 18 one rem.
19 Then in the third case under this option, 20 you have no event sequences that exceed one rem at the 21 site boundary, so the only thing that remains in play 22 is the rule that says keep reactors away from densely 23 populated centers of about 25,000 people.
24 So what we tried to show in the graph is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 if you have a population center of 25,000, the reactor 1
would be outside that population center. If it's less 2
than 25,000, you could be within, and the reason we 3
were looking at it like this is going back to the 4
first problem statement.
5 We don't currently know of reactors who 6
are looking at remote siting, I mean remote areas, 7
isolated communities that would be serving a 8
population center of greater than 25,000, so this 9
would allow a reactor, if it could otherwise make the 10 safety case, to be within a small town in a remote 11 area.
12 MEMBER BLEY:
You've dropped the 13 population density?
14 MR. RECKLEY: At that point, yes.
15 MEMBER BLEY: Because even though the 16 population center might be fewer than 25,000 people, 17 there could be a small area within it with really high 18 19 MR. RECKLEY: That's right.
20 MEMBER BLEY: -- population density?
21 MR. RECKLEY: Right, but again, this is 22 limited to those reactors that could show no event 23 sequences where you exceed one rem --
24 MEMBER BLEY: At the boundary.
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36 MR. RECKLEY: -- at the boundary.
1 MEMBER CORRADINI: So, can I -- so let's 2
go to NUREG 1537, non-power reactors. I can think of 3
some of the bigger ones of those that don't meet the 4
right-hand side of the lower one to the right, so am 5
I concerned?
6 In other words, the NIST reactor on the 7
Gaithersburg campus probably doesn't meet the bottom 8
one to the right unless I say that the campus itself 9
is a low population center. Is that what you said 10 over the phone? Did I --
11 MR. RECKLEY: Yes, that you could look at 12 the campus again, it's a huge campus, and look at it 13 in the context of how far are you actually away from 14 a population, a dense population?
15 MEMBER KIRCHNER: Bill, what Mike brought 16 up, it was in my mind and I didn't work through this 17 in advance. Would this be consistent with the rule 18 for non-power reactors, research reactors and such?
19 In other words, would they collapse to the same 20 answer?
21 MEMBER BLEY: I'm not sure. I mean, we 22 did the NIST reactor --
23 (Simultaneous speaking.)
24 MEMBER BLEY: We did the NIST reactor a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 few years ago and they really had almost a nil source 1
term. I don't remember the details. I doubt that --
2 MEMBER CORRADINI: But, except for the 3
Gaithersburg campus, they're in a population area that 4
would be greater than 25,000.
5 MEMBER BLEY: Yes.
6 MEMBER REMPE: But to meet it, Steve, 7
right --
8 MR. LYNCH: Yeah.
9 MEMBER REMPE: -- pointed out the very 10 restrictive criteria, but I have another question I 11 want to ask after that, but go ahead and repeat what 12 you said at the meeting.
13 MR. LYNCH: Sure, yeah, I can. Yeah, this 14 is Steve Lynch. I'm currently the Acting Chief of the 15 Advanced Reactor Licensing Branch and I'm also working 16 with the Research and Test Reactors Licensing Branch.
17 As far as the siting of a NIST reactor, 18 yes, it is in a population center that may be greater 19 than 25,000, but one of the differences, at least 20 under its current licensing basis, is the more 21 restrictive dose at the site boundary.
22 I believe that NIST is licensed such that 23 the maximum dose at the site boundary is limited to 24 100 millirem, so I think that is one of the different 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 considerations with that facility to address 1
consistency with the NPUF rule.
2 MEMBER CORRADINI: But if it were one rem 3
instead of 100, if it was a factor of 10 larger, would 4
I really change anything? I understand what you're 5
saying, but it still doesn't change anything from a 6
health hazard standpoint.
7 MR. LYNCH: Could you clarify what you're 8
asking with the --
9 MEMBER CORRADINI: What I'm saying is if 10 the NIST reactor were to have done a calculation --
11 I'm using them as a government example. I have other 12 examples that I could bring up. But if it were, 13 instead of 0.1 rem, it was one rem at the boundary, it 14 still is not a health hazard, so it wouldn't require 15 evacuation, so --
16 MR. LYNCH: Correct.
17 MEMBER CORRADINI: -- it's equivalent.
18 It's an equivalent question.
19 MR. LYNCH: Correct, and I think that's 20 where the NPUF rule comes in. So the 100 millirem was 21 a conservative number that, in the absence of accident 22 dose criteria for non-power reactors in the 23 regulations, facilities such as NIST had voluntarily 24 used as their accident dose criteria.
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39 With the NPUF rule, accident dose criteria 1
for research reactors will be set at one rem. And as 2
we were saying, if, at the site boundary, it's 3
demonstrated that, for the duration of an accident, 4
dose is at less than one rem, there would be no 5
offsite emergency planning needed.
6 MEMBER REMPE: So this ties into the 7
question I've been wanting to ask. During the 8
Subcommittee meeting, I believe the question was 9
raised on how do you do this calculation? Is it a 10 conservative calculation? Is it best estimate? And 11 I thought that some changes would be made to the draft 12 SECY to clarify what you wanted.
13 MR. RECKLEY: And again, that was what we 14 were trying to do with the change to the footnote, so 15 it you look at --
16 MEMBER REMPE: But show me how that's --
17 on page 21's footnote or which footnote? Maybe I 18 missed it.
19 MR. RECKLEY: Yes, basically on slide 21 20 that lays out two approaches as we had currently 21 identified.
22 MEMBER REMPE: Put the slide up there and 23 show me that it tells me to do conservative or best 24 estimate. I get the first part for 1353, but for a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 different approach --
1 MR. RECKLEY: For 1353, you're going to be 2
doing the design basis event or beyond design basis 3
event best estimate calculations.
4 MEMBER REMPE: What about the applicant 5
using a licensing approach different from that in 6
1353? How do I know that guy has to do a conservative 7
calculation or a best estimate one?
8 MR. RECKLEY: For the other set that we 9
can know how they do it, right, but there's a 10 hypothetical that we don't know what they'll be 11 proposing, so it's hard to address, but for the other 12 ones that we know, which would be light water, small 13 modular reactors, the option that they have is to use 14 the existing guidance for light water reactors, which 15 would be to use the source term out of NUREG 1465.
16 That's considered to be a conservative 17 source term, but, so it's not taken, for example, like 18 the advanced reactor approach in DG-1353, but it would 19 be best estimate calculations, using best estimate 20 calculations.
21 It would be the more traditional approach 22 that you would find in the siting calculation in a 23 current FSAR for a currently operating reactor. Those 24 are the two that we know because we've seen them 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 before.
1 People can propose alternatives. A light 2
water SMR could propose something similar to, but 3
deviations from the guidance that's in 1465, and we've 4
seen some of that where the guidance is used in some 5
respects, but it's tweaked to reflect specific design 6
details, specific release paths and filtering that 7
might occur, that might not be in a traditional light 8
water reactor containment.
9 In your case of the maximum hypothetical, 10 they could propose that and we'd have to review it on 11 its merits. I don't really have any specific guidance 12 on how somebody would do a maximum hypothetical except 13 for almost by definition, it's not best estimate 14 because they're making up something that's 15 intentionally conservative.
16 MEMBER BLEY: But your expected response 17 to that question would have been the second insert you 18 put up there, is that right?
19 MR. RECKLEY: Yes, well, only in that we 20 didn't want to repeat a lot of the stuff from 1353 21 that describes how that's done and from that SECY 22 paper. What we were adding, because that's where I 23 thought the question was, was more what would a light 24 water reactor, what would somebody that's not using 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1353 do?
1 And again, the easiest to describe is a 2
light water reactor approach, and then they always 3
have an option of proposing something on their own and 4
they would have to justify it on their own merits.
5 MEMBER REMPE: So I guess I was expecting 6
from the Subcommittee meeting that there would be 7
something about, that would say, "By the way, if you 8
have something that's not a light water reactor or not 9
the 1353 approach, we'd expect it to be darn 10 conservative," and I guess I don't see that here, but 11 maybe there's some other thing that gives them a clue.
12 MEMBER CORRADINI: What I'm hearing Bill 13 say is what's in blue is a conservative approach in 14 the light water world.
15 MR. RECKLEY: Right, they could propose 16 something.
17 MEMBER CORRADINI: And expecting an 18 equivalency in the non-light water world if something 19 comes up, and that's how they judge it.
20 MR. RECKLEY: Thank you, but it's going to 21 be a different source term than what's defined in 22 1465. You have different fuels, different --
23 MS. CUBBAGE: And I might add, this is Amy 24 Cubbage again, that we're going to need to figure that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 out to do the other part of siting, to figure out do 1
they meet the dose limits? Can they have a certain 2
EPZ? And then this is just going to leverage that 3
same number.
4 So the intent of this document wasn't to 5
define how every possible person is going to come up 6
with their source term, but given a certain source 7
term, how would we translate that into different 8
population density requirements?
9 I know that's not satisfying to you 10 because it's kind of like, well, but separately, we 11 have activities ongoing to look at source term and 12 other matters, and I think it's pretty clear from the 13 LMT guidance how you would do it. It's clear from the 14 light water world how you would do it. If someone 15 wants to come up with a different approach, we'll just 16 have to face that, and we'll need to figure that out 17 to give them a license regardless of this siting 18 issue.
19 MEMBER BLEY: As you folks described, this 20 is a high level SECY.
21 MR. RECKLEY: Yes.
22 MEMBER BLEY: There's a lot of details for 23 implementation.
24 MR. RECKLEY: That you'll see when we do 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 the Reg Guide.
1 MEMBER BLEY: That's what I wanted to get 2
to. Your intent is to do a Reg Guide to support this 3
to cover --
4 MR. RECKLEY: Yes.
5 MEMBER BLEY: -- these details.
6 MR. RECKLEY: This will be a change --
7 MEMBER BLEY: Because it's either going to 8
work well or not depending on that guidance.
9 MR. RECKLEY: Right, and so our plan and 10 what we call out in the paper is whatever option is 11 chosen, except for option one, which is status quo, it 12 would involve changing Regulatory Guide 4.7 to add 13 this as an alternative to the current approach of 500 14 persons per square mile out to 20 miles.
15 MEMBER BLEY: Okay.
16 MR. RECKLEY: Moving on then to the last 17 option, option four, I'll just briefly touch on it.
18 I don't believe there was a lot of support for this 19 one either. This was to develop broader societal risk 20 measures.
21 These are measures that would look at 22 potential doses to individuals and also population 23 doses. It would look at effects on economies, land 24 availability, displacement, decontamination costs, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 broader societal costs, and this kind of approach has 1
been talked about for decades, and usually avoided for 2
some of the disadvantages there. It talks a lot of 3
time to develop.
4 It would be a significant change from the 5
current siting, kind of treated as an independent 6
element because both the design and the site would be 7
looked at together, and so depending on how you did 8
it, you could have a design that would be acceptable 9
for one site and not acceptable at another site as a 10 result of the societal measures.
11 MEMBER BLEY: As a -- you know, you 12 introduced this in the SECY as this is a really good 13 idea if you could implement it.
14 MR. RECKLEY: Yes.
15 MEMBER BLEY:
The trouble is in 16 implementation.
17 MR. RECKLEY: Right.
18 MEMBER BLEY: We heard comments from 19 others that kind of focused on land contamination. We 20 had a meeting a couple of years ago on this issue of 21 societal risk, and especially because that was the big 22 thing that went --
23 MR. RECKLEY: Right.
24 MEMBER BLEY: -- they had over in Japan.
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46 We calculate, or we used to calculate land 1
contamination as part of the risk assessments. We 2
don't always report them, but we could.
3 You could have kind of a three prime 4
that's the way it is, but adds a land contamination 5
factor as a surrogate for possible societal risk 6
measures. I don't know how easy it would be to reach 7
agreement on what a criteria ought to be for that.
8 MEMBER KIRCHNER: I think, again, you'd 9
have to first resolve the low dose issue, which has 10 proven intractable for years and years despite 11 evidence to the contrary.
12 MR. RECKLEY: And we do use, when we do 13 our regulatory analysis --
14 MEMBER KIRCHNER: But with a criterion, a 15 cutoff somewhere.
16 MEMBER BLEY: Right.
17 MR. RECKLEY: And we point out --
18 MEMBER KIRCHNER:
And that would 19 difficult.
20 MR. RECKLEY: We point out in the paper 21 that in terms of regulatory analyses that we do for, 22 like, rule changes, you can identify a delta, but it's 23 an existing situation, a plant modification that we 24 may require or not require.
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47 You've got like a situation, then you can 1
assess, and we do consider these factors when we do 2
the regulatory analysis in the cost benefit 3
assessment. What gets difficult is when you don't 4
have a binary thing to compare.
5 Then as Walt was mentioning, you need to 6
come up with some other criteria and it's been very 7
elusive, and that is why we have not recommended this 8
option, although as Dr. Bley mentioned, if one could 9
do it, it would be the best measure of the actual 10 impact of a reactor on a particular community.
11 So it's just that we don't think it's 12 practical. So we recommend option three, and as John 13 mentioned, we would appreciate the insights of the 14 Committee on both the options and the recommendation.
15 MEMBER BLEY: Just as a matter of 16 discussion, a short one, I don't remember in the 17 environmental analysis that supports a license 18 application, they have at least an abbreviated form of 19 PRA. Do they do a land contamination calculation 20 there? Since nobody else knows either --
21 MR. RECKLEY: We would --
22 (Simultaneous speaking.)
23 MEMBER BLEY: -- we won't need to pursue 24 that one.
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48 MR. RECKLEY: Okay, I don't know. I'll 1
look at Marty. Is it included in the SAMA/SAMDA 2
evaluations? It's not? Okay, so, no.
3 MEMBER BLEY: Thank you, and that was your 4
last slide.
5 MR. RECKLEY: Yes.
6 MEMBER BLEY: Anything from members of the 7
Committee? Mr. Chairman, back to you on time.
8 CHAIRMAN RICCARDELLA: Thank you, very 9
good. We have a very busy agenda this week, and so 10 I'm happy that people are staying on schedule. I 11 think we should continue with the second item, which 12 is the Turkey Point subsequent license renewal, and I 13 will turn the floor over to our Vice Chairman Matt 14 Sunseri.
15 VICE CHAIRMAN SUNSERI: Thank you, Pete.
16 Maybe we'll just give it a second for the tables to 17 rearrange here.
18 CHAIRMAN RICCARDELLA: That's fine.
19 VICE CHAIRMAN SUNSERI: Okay. While you 20 all are getting your presentation up out, I'll go 21 ahead with some of the administrative stuff here.
22 All right. Thank you Mr. Chairman. This 23 is the -- the purpose of this part of the meeting 24 today is for Florida Power & Light Corporation, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 the NRC to brief the full Committee on subsequent 1
license renewal activities for the Turkey Point 2
Nuclear Generating Stations Three and Four.
3 A panel license review subcommittee 4
previously met on June 21, 2019 to discuss this 5
application. The subcommittee's objective was to 6
focus on the safety aspects of this application and to 7
formulate a
proposed position and action for 8
deliberation by the full Committee, which we will do 9
following the presentations today.
10 Due to separate and independent external 11 relationships with structural integrity associates, 12 Peter Riccardella and I are recusing ourselves from 13 the deliberations on the topic of metal fatigue, class 14 one components, environmentally assisted fatigue, and 15 the leak before break analysis for Class One auxiliary 16 piping as these topics relate to the Turkey Point 17 subsequent license renewal application.
18 At this point I'd ask Meena Khanna of the 19 Division of Materials and License Renewal if you have 20 any remarks before we start?
21 MS. KHANNA: Okay, thank you. Thank you 22 Chairman Riccardella, Mr. Sunseri and members of the 23 ACRS. I am Meena Khanna, Acting Deputy Director of 24 the Division of Materials License Renewal.
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50 We sincerely appreciate the opportunity to 1
today to present to the ACRS full committee, the 2
results of the staff's safety review of the first 3
application for subsequent license renewal, also known 4
as Operation Beyond Sixty Years.
5 This application was submitted by Florida 6
Power & Light Company for the Turkey Point Nuclear 7
Generating Station, Units Three and Four, located near 8
Homestead, Florida.
9 I'd like to note that we did have the 10 opportunity to present the results of the staff's 11 safety review of the Turkey Point SLRA to the ACRS 12 subcommittee back on June 21.
13 Before I proceed any further, we would 14 like to acknowledge the very challenging circumstances 15 that the employees of Florida Power & Light and their 16 families, as well as the residents of Florida and the 17 Bahamas are experiencing as a result of Hurricane 18 Dorian.
19 We understand that FPL is implementing its 20 hurricane preparedness procedures to ensure the safety 21 of their nuclear power plants, their personnel, and 22 the public. As a result, some of the FPL members of 23 the Turkey Point team are unable to attend this 24 meeting in person today, but will be with us by phone.
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51 We really appreciate those that have 1
actually joined us under these circumstances. Our 2
thoughts and prayers are with those that have been 3
impacted by the storm.
4 By way of background, Turkey Point's Three 5
and Four received approval for their initial renewed 6
licenses from the NRC on June 6, 2002. The NRC review 7
at that time was performed using guidance developed 8
prior to the issuance of the Generic Aging Lessons 9
Learned Report, or the GALL Report.
10 The NRC guidance for license renewal over 11 the years has evolved through enhancements and 12 improvements based on lessons learned from NRC license 13 renewal reviews and from both domestic and 14 international industry operating experience.
15 The GALL Report went through two revisions 16 and additional interim staff guidance was issued 17 following revision two. The guidance for subsequent 18 license renewals contained in the GALL SLR Report 19 built upon the previous guidance, and included 20 additional focus and enhancements where necessary on 21 aging management and time limited aging analysis for 22 operation in the 60 to 80 year period.
23 In the staff's presentation today, you 24 will hear about some of these specific SLR issues as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 applied to the Turkey Point review.
1 The NRC Project Manager for Turkey Point 2
subsequent license renewal application safety review 3
is Ms. Lois James, here behind me. Mr. Billy Rogers, 4
also a Senior PM on the Turkey Point project, will 5
present an overview of the staff's safety review 6
today.
7 Part of the management team that are here 8
with me today include Mr. Eric Oesterle, Chief of the 9
License Renewal Project Branch seated next to me. And 10 in the audience are other DMLR and NRR technical 11 branch chiefs as well as our staff.
12 In addition, we have several staff on the 13 phone in case there are specific questions about the 14 technical review. We also have on the phone Paula 15 Cooper from Region II, who oversaw the facility 16 inspections associated with the effectiveness of the 17 Aging Management Programs implemented for initial 18 license renewal, as well as other NRR staff who 19 supported the review.
20 We look forward to a productive discussion 21 today with the ACRS. And as always, look forward to 22 addressing any questions that you may have.
23 At this time, I'd like to turn the 24 presentation over to Mr. Bill Maher, FPL Senior 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 Licensing Director to introduce his team and commence 1
their presentation. Thank you.
2 MR. MAHER: My name is Bill Maher, I'm 3
Senior Licensing Director for Subsequent License 4
Renewal. Again, I'd like to echo the remarks of the 5
NRC as far as being able to accommodate us, and the 6
flexibility of the Committee to actually have people 7
on the phone who are not able to make it as a result 8
of Hurricane Dorian.
9 It was an interesting flight up this 10 morning. There were some bumps, but we got along.
11 And we actually made it. So, go to slide two.
12 So, what I'd like to do is to briefly 13 introduce, I already introduced myself. To my right 14 is Brian Stamp. He's the Site Director for Turkey 15 Point Three and Four.
16 And to my left I have Steve Hale from 17 ENERCON who is our technical lead on one of the 18 contractors that we have working on the project, 19 ENERCON. And Steve Franzone is on my staff, who is a 20 Licensing Manager associated with subsequent license 21 renewal.
22 I did want to at least preface this 23 particular presentation to show how we have satisfied 24 the NRC requirements for subsequent license renewal.
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54 How the aging affects associated for subsequent 1
license renewal are being effectively managed such 2
that the intended functions are being maintained.
3 And like Brian will point out, how our 4
gains are being -- how we're being able to maintain 5
those as we go through a period of subsequent, period 6
of observation. And I'll turn it over to Brian.
7 MR. STAMP: Hi, good afternoon. Like Bill 8
stated, my name is Brian Stamp. I am the site -- like 9
Bill said, I am Brian Stamp, Site Director at Turkey 10 Point. That means that I own the performance at 11 Turkey Point specifically, as well as a shared 12 oversight of the entire nuclear fleet.
13 Today on the slide we're looking at, I 14 want to talk briefly about our performance philosophy, 15 and specifically how it entails the sustainability.
16 The model that you're seeing is a model 17 that our C&O put together to really describe what that 18 sustainability looks like. And before this, all of 19 this comes from the philosophy that is governed by our 20 nuclear excellence model.
21 That nuclear excellence model has been 22 with us since 2008. And it has stayed the same for 23 all these years.
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55 core principals. The primary core value is around 1
deep respect for nuclear safety.
2 It also has a value of self improving 3
culture, learning organization, as well as a PDC. In 4
the PDC model, prevention, detection, and correction 5
which really describes how we want to spend 80 percent 6
of our time in that prevention and detection, and only 7
20 percent of our time in the actual correction.
8 That goes on down to a core principal that 9
really goes back to the sustainability and the 10 subsequent license renewal, which really is around the 11 effective long range planning of all the site 12 activities.
13 Now interestingly, the INPO organization 14 recently took our model with our C&O at the time, Mano 15 Nazar, and created their own document called the INPO 16 19-3. And it's staying on the COB.
17 While the words are a little different, 18 the output really is the same. It's really all about, 19 how do we make sure that we retain the gains that 20 we've already got at the performance level we're at, 21 plus rigorously and aggressively build additional 22 margin?
23 You know, one of the big criteria that we 24 use to make sure that we are doing both retaining and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 building a margin, it comes out at 10 CFR 50, Appendix 1
B, the quality assurance program.
2 You know, in that program there's two or 3
three key activities. One being the design control.
4 You know, that design control really ensures that we 5
make sure that the regulatory requirements as well as 6
our design basis requirements are rigorously reviewed.
7 They are tested and monitored.
8 And then all the reviews and the testing 9
then get in turn put into our control documents.
10 Whether that's a procedure or a document, that's used 11 in the field, like a drawing or a work order.
12 That's how that ensures that that design 13 basis is maintained. The regulatory basis is 14 maintained.
15 The other big part of that is the 16 corrective action program. That corrective action 17 program, the implementation of that ensures that any 18 adverse conditions in quality are quickly identified, 19 plus evaluated quickly, and/or the corrective actions 20 to prevent recurrence, put back into those same 21 documents, again, the procedures that we use or the 22 design documents that we use to improve those.
23 The last part of that really is the 24 configuration control that comes out of the procedure 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 process. That configuration control is what we use to 1
make sure that the site is always in the same 2
configuration as again, the design basis document as 3
well as the regulatory requirements say they should.
4 Now, all this goes back to, you know, this 5
retaining the gains, the aggressively building the 6
margin. That is really built into our core business 7
so that all of the, all of my direct reports have this 8
built into their daily work life, as well as all the 9
people below them.
10 And then taking this back to the 11 subsequent license renewal, it really goes back to the 12 way that we are implementing the aging management 13 process and program to ensure that again, we have that 14 sustainability long term.
15 With that, I'd like to turn it over to 16 Steve Franzone.
17 18 MR. FRANZONE: Thank you Brian. Good 19 afternoon. My name is Steve Franzone. I am the 20 Licensing Manager for the subsequent license renewal 21 project for Turkey Points Three and Four.
22 Slide four gives you an overview of the 23 location of Turkey Point Units Three and Four, which 24 is at the location -- which is at the very southern 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 tip of the Florida mainland.
1 The star in the center of the circle marks 2
the location of the site. It is located approximately 3
25 miles south of Miami.
4 The black dash circle represents the 50-5 mile radius of the plant. The closest cities are 6
Homestead and Florida City, which are approximately 7
nine miles west of the site.
8 The site is sandwiched between the 9
Everglades National Park and the Biscayne National 10 Park. The site has approximately 680 full time 11 employees. Go to slide five.
12 This slide provides a view of the entire 13 site looking north. Biscayne Bay is on the right-hand 14 side of the photo.
15 A little history about the site, site 16 construction started in 1965 by the Bechtel Power 17 Corporation with two 400 megawatt coil plants, which 18 are Units One and Two.
19 The construction permit for Turkey Point 20 was granted in 1967 for Units Three and Four. The 21 Nuclear Unit stated commercial operation in 1972 and 22 1973 respectively.
23 The cooling canal serves as our closed 24 circulating water system as it is -- and as the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 plant's ultimate heat sink. The intake is on the 1
right and the discharge is on the left. And you'll 2
see a better view in a few slides.
3 The licensed thermal power is 2,644 4
megawatts thermal. At the top of the photo is Unit 5
Five, which is an 1150 megawatt electric combined 6
cycle gas fired plant which went into commercial 7
operation in 2007.
8 Unit One and Two have since -- have been 9
retired since this photo was taken. And the stacks of 10 the units have been dismantled.
11 This slide presents the major events that 12 have occurred at the Turkey Point site. You can see 13 the dates for the initial operating license.
14 In 1983 and 1984, the original steam 15 generators for both units were replaced. In fact, it 16 was only the U-tube section which was actually 17 replaced.
18 In 1991, the onsite electrical systems for 19 both units were upgraded. And this included going 20 from two emergency diesel generators to four emergency 21 diesel generators, adding a spare battery, new digital 22 sequencers, redistribution and separation of loads.
23 And upgrading the RCS RCDs.
24 Other notable events in the plant history 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 include surviving Hurricane Andrew in 1992, and the 5 1
percent uprate in 1995. We were not only a pre-GALL 2
plant, but we're also the first Westinghouse units to 3
receive a renewed license in 2002.
4 We replaced the reactor vessels in 2004 5
and '05. Finally, we received approval for an 6
extended power uprate, which included a 1.7 percent 7
measurement on certain recapture in 2012, and entered 8
into the period of extended operation for Unit Three, 9
and of course Unit Four was 2013. At that point, the 10 fuel enrichment was increased to 5 percent.
11 CHAIRMAN RICCARDELLA: Excuse me, just a 12 correction for the record. They replaced the reactor 13 vessel heads, not the reactor vessels.
14 MR. FRANZONE: Yes. Sorry. Good catch.
15 MEMBER BLEY: Not that it's -- well, it 16 might be relevant to this.
17 MR. FRANZONE: It would be real hard.
18 MEMBER BLEY: How did you do during 19 Andrew? Was there flooding there?
20 MR. FRANZONE: Do you want to take that 21 one?
22 MR. STAMP: No, actually there was no 23 flooding. I was actually onsite during Hurricane 24 Andrews. There was actually no flooding.
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61 Andrew didn't have a lot of heavy rains 1
like the storm that just went through, Dorian.
2 MEMBER BLEY: Um-hum.
3 MR. STAMP: The -- I was in the control 4
room, and it was actually just like a simulator 5
scenario. The plant actually operated exactly like it 6
was designed.
7 Probably the best ever.
8 MEMBER BLEY: Interesting. And it didn't 9
-- I mean, it looks like it would have pumped water 10 into your intake area and flooded that.
11 But it didn't?
12 MR. STAMP: No. No, Andrew --
13 MR. FRANZONE: I think it was closed.
14 MR. STAMP: I was just going to say, 15 Andrew was moving at a pretty good clip. If I 16 remember right, it was 10 or 12 miles an hour. So, 17 and it was a very small, condensed storm.
18 So, it actually passed over the site in 19 roughly three to four hours, the main part of that 20 storm.
21 MEMBER DIMITRIJEVIC: And did you lose 22 power?
23 MR. STAMP: Yeah. We lost all offsite 24 power. But again --
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62 MEMBER DIMITRIJEVIC: For how long?
1 MR. STAMP: Well, you're now you're --
2 MR. HALE: About a week.
3 MR. STAMP: You're testing me.
4 MR. HALE: Yeah. We lost all the -- oh, 5
I'm sorry. Steve Hale, ENERCON. We lost all the 6
transmission lines going into the site.
7 They were restored within about a week.
8 MEMBER DIMITRIJEVIC: So, did you operate 9
on the diesel generator for a week?
10 MR. HALE: Yes. Yes, we did.
11 MEMBER DIMITRIJEVIC: That's what I know.
12 MR. HALE: It also highlighted some 13 challenges with regard to communications. Because a 14 lot of the communications were relying on cell towers 15 and things of this sort.
16 So, actually working with the NRC in the 17 region, we addressed some of the issues that fell out 18 of Hurricane Andrew with regards to communications.
19 You know, satellite phones, things like that, to 20 improve that response in case something like that 21 happened again.
22 MEMBER DIMITRIJEVIC: Well, interesting 23 that you just added to do the generator the year 24 before that happened.
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63 MR. HALE: Yes. Very convenient. Yes.
1 (Laughter) 2 MR. FRANZONE: Yes. And the flood level 3
for the site is 20 foot minimum protection. And it 4
goes higher. And the surges were not that high.
5 And in fact they were very much in line 6
with what they had predicted back in the '70s, so.
7 All right. Are we ready to go on? Okay.
8 MEMBER KIRCHNER: Do you --
9 MR. FRANZONE: Yes, sir?
10 MEMBER KIRCHNER: What's the current 11 operating status of the plant today?
12 MR. FRANZONE: Both units are at 100 13 percent power.
14 MEMBER KIRCHNER: They're still at 100 15 percent, okay.
16 MR. FRANZONE: Yes. We did not shut down 17 for this storm.
18 MEMBER KIRCHNER: Okay. Thank you.
19 MR. FRANZONE: As you can see, the main 20 features here are the closed loop cooling canals.
21 This feature is unique to Turkey Point, and is 22 approximately 168 miles of cooling canal.
23 It is basically a giant radiator that you 24 can actually see from space. It not only provides the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 normal cooling flow, so acts as the ultimate heat 1
sink.
2 The red solid line is the site boundary.
3 Where the bright yellow solid line is, the exclusion 4
area boundary.
5 To maintain the efficiency of this giant 6
radiator, the measures that we take include selective 7
dredging and clearing of the vegetation from the 8
9 This insert, the insert provides location 10 of the major structures. And we'll discuss it on the 11 next slide in more detail.
12 As you can see here, it's an expanded view 13 of the insert from slide eight. To orient you, north 14 is at the top of the slide. And just out of view is 15 the Unit Five, the combined site for natural gas unit.
16 We'll start from the left and go to the 17 right and just point out the major structures. Then 18 if you have more questions.
19 So first you'll see the switch yard. Next 20 will be the discharge structure. And then the turbine 21 building.
22 And then we have the containments, which 23 are post-tension containments. Sandwiched in between 24 the containments is the control building. It's the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 comm and control building for both Units.
1 And then next again, is the OX building.
2 Again, it's common for both Units. Then next we'll 3
have the intake structure.
4 And finally, on the very right-hand side 5
of the photo, you can see the independent spent fuel 6
storage facility. Any questions? I'll just go on.
7 Okay. Slide nine.
8 FPL's made -- has made and continues to 9
make significant investments in the plant. This slide 10 provides a listing of recent major modifications and 11 upgrades for the plant.
12 The timing of the submittal is important, 13 because when you take into account the ten-year window 14 for the pre-SPEO inspections, we are in the five-year 15 planning window for major projects.
16 Also, the submittal is important in 17 achieving our goals of retaining gain and building 18 margin for Turkey Point, as we discussed on slide 19 three.
20 Turkey Point has been an integral part of 21 the south Florida community for over 45 years.
22 Operation at Turkey Point, there are estimated to 23 generate nearly 1.7 billion dollars of total economic 24 output annually.
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66 The plant staff has a long history of safe 1
operation, and are valued members of the community, 2
having volunteered over six thousand hours in support 3
of charitable organizations.
4 The continued operation of Turkey Point 5
into a subsequent period of extended operation will 6
allow the plant workers and FPL to continue supporting 7
the local community.
8 MEMBER BLEY: Before you go.
9 MR. FRANZONE: Yes?
10 MEMBER BLEY: Can you tell me about two of 11 those items? The obsolescence projects and what 12 happened to your containment spray piping? How come 13 you had to replace that?
14 MR. FRANZONE: You want to start with the 15 containment spray piping?
16 MR. STAMP: Yeah. The containment spray 17 piping, we actually have --
18 MR. FRANZONE: There we go, Brian.
19 MR. STAMP: So, the containment spray 20 piping, we've actually started to replace some of that 21 piping. We started the last outage on one Unit where 22 we replaced the piping on the penetration into the 23 area that was susceptible to the corrosion.
24 We're preparing for the upcoming outage in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 the spring, and to do the similar on the second Unit.
1 And then the following fall, we're going to come back 2
and replace all the piping on the first Unit that we 3
did.
4 MEMBER BLEY: You did have extensive 5
corrosion then?
6 MR. STAMP: No. We did -- we did evaluate 7
the internals of the piping. The corrosion, I 8
wouldn't say it was extensive, but it was corrosion 9
there.
10 But, you know, preemptively we did replace 11 the piping. There was a, you know, it did have the 12 corrosion on it. And we're going to do it.
13 We're assuming that the same condition 14 belongs on the other Unit. So we're going to replace 15 the same piping on that.
16 MEMBER BLEY: Okay.
17 MR. HALE: We just need to explain the 18 piping is carbon steel. Okay.
19 MEMBER BLEY: Yes. Okay.
20 MR. HALE: And by design, I don't think it 21 was originally thought that it would be exposed to the 22 boric acid on a regular basis. But, so the corrosion 23 was really had to do with carbon steel and boric acid 24 really.
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68 MR. FRANZONE: Okay. And that second, 1
your first question you had was on the obsolescence 2
project?
3 MEMBER BLEY: Um-hum.
4 MR. FRANZONE: Right. So, as you know, 5
Turkey Point, and a lot of nuclear plants get older, 6
and so some of the components that we originally had 7
become obsolete.
8 So, what we've done is, is there's 9
basically a structured program. And we went through 10 a whole laundry list of items that we ended up 11 replacing.
12 I'll give you an example, would be the OX 13 transformers were replaced as part of that. Control 14 Board, enunciation system was replaced. We replaced 15 the instrument air system.
16 We've replaced the vital MCC buckets.
17 Because they needed that. ERDADS was replaced. Let 18 me see, some of the other ones. A significant portion 19 of the fire protection system.
20 We replaced ICW, which are intake cooling 21 water and component cooling water, which is our 22 service water strainers. And we recoded simple, 23 recoded some of the internals of the tanks.
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69 system was also upgraded. And so, it's just an 1
ongoing effort that we have to make because these 2
plants are just getting older, and the parts are not 3
available.
4 MEMBER REMPE: So, on this slide, I don't 5
see anything about the steam generator replacements.
6 And they were done thoroughly --
7 MR. FRANZONE: In 1983 and 1984. So, this 8
slide mainly is after the renewed license was issued 9
in 2002.
10 MEMBER REMPE: Okay.
11 MR. FRANZONE: Just trying to capture the 12 major ones.
13 MEMBER REMPE: How are the tubes behaving 14 with the replacement steam generators?
15 MR. FRANZONE: Very good. Unit Three is 16 only 2 percent plugged. And Unit Four is three-17 quarters of a percent plugged.
18 So they're doing really good. We've taken 19 the lessons we had in the early '70s to heart. And 20 after that when we did replace the generators, we had 21 very tight chemistry controls, so.
22 MR. HALE: In fact, for extended power 23 uprate, the Committee here asked some questions about 24 the steam generators and performance after the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 extended power uprate.
1 And they performed very well. We haven't 2
seen any degradation associated specifically for the 3
increase in power level.
4 MEMBER REMPE: Okay. Thank you.
5 CHAIRMAN RICCARDELLA: What about your 6
instrument and control system? Did you do any 7
upgrades with that?
8 MR. FRANZONE: Instrument air?
9 CHAIRMAN RICCARDELLA: No. I&C? Just 10 have you gone with a digital system more recently?
11 MR. STAMP: Yeah. For a lot of things.
12 For example, on all the feedwater controls, they have 13 all been transferred over to digital.
14 All of the modules that were originally in 15 place for all of the control systems, you know, that 16 inputted into the direct protection system, safeguard 17 system, have all been upgraded to newer models.
18 In fact, we're getting ready to go to a 19 third round of that, and to further upgrade those 20 again.
21 MR. HALE: And for the extended power 22 uprate for the turbine controls, we actually moved the 23 DEH system and digital controls on the turbine.
24 CHAIRMAN RICCARDELLA: Thank you.
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71 MR. FRANZONE: Okay. If we go to slide 1
ten. And as I've mentioned before, both Units are at 2
100 percent power. Average station capacity factor 3
for the last two years was 91.9 percent.
4 And unless there's no other questions, 5
we'll go to the next slide. Okay. The project team 6
-- we're on slide 11.
7 The project team has many years of both 8
Turkey Point experience and license renewal 9
experience. The multi-disciplined team consists of 10 ENERCON as the lead preparer for the schedule, as well 11 as Westinghouse, Framatone, and Structural Integrity 12 Associates in supporting roles.
13 Also, the project team was supported by 14 the next era FPL fleet and site program owners as well 15 as various subject matter experts such as Chuck 16 Ramdeen, who is civil, and he's here today. And Scott 17 Boggs who is on the phone with us. And Maribel 18 Valdez, who is also here today.
19 Every aging management program for SLR was 20 actually assigned a program owner to support a portion 21 of the application preparation and the NRC review.
22 The project team generated over 130 reports, which 23 supported the application in its review.
24 These reports will provide a way to ensure 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 that knowledge will be passed onto the personnel who 1
need it in the future.
2 The technical leads for our project 3
partner, ENERCON are both former FPL employees with 4
almost 80 years of combined experience with FPL. Both 5
developed the original license renewal application for 6
Turkey Point.
7 We have established an SLR/LR liaison 8
position now in order that we will be successful in 9
the transition to the subsequent period of extended 10 operation.
11 Mr. Bob Tomonto, who could not be here 12 with us today, but he has almost 30 years of licensing 13 and engineering experience at Turkey Point.
14 Specifically, his last two jobs have been as the 15 Turkey Point licensing manager, and as one of the 16 onsite design engineering managers.
17 I will now turn the presentation over to 18 Steve Hale who is one of the ENERCON technical leads 19 I just talked about. Again, thanks for giving us the 20 opportunity to present today.
21 MR. HALE: Thanks Steve. Good afternoon.
22 Sorry about that. Thanks Steve. Good afternoon, my 23 name is Steve Hale. And I work for ENERCON as one of 24 the technical leads for the Turkey Point subsequent 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 license renewal project.
1 Previous to that, I worked for Florida 2
Power & Light for over 46 years. And held many 3
positions, including the engineering director at the 4
site.
5 I was directly involved with original 6
license development for Turkey Point and St. Lucie, as 7
well as the extended power uprates for Point Beach, 8
St. Lucie, and Turkey Point. In fact, I actually made 9
all the ACRS presentations for all those major 10 licensing actions.
11 Just as a point of interest for original 12 licenses for Turkey Point, the ACRS subcommittee was 13 actually conducted at the site of Turkey Point. And 14 we walked the committee, primarily because it was the 15 first Westinghouse unit to go through license renewal.
16 For the subsequent license renewal 17 application, we followed the guidance of NEI 17-01, 18 which was developed specifically for subsequent 19 license renewal. To ensure a quality application, we 20 also reviewed REIs, REI responses for the last eight 21 applications that went through, and incorporated those 22 lessons learned.
23 We also conducted peer reviews with other 24 SLRA participants, and as well NEI, and other industry 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 folks. One of the other activities we implemented was 1
to have pre-meetings with the NRC on -- discussing 2
various technical topics.
3 And we also had a punchlist from the staff 4
on specific technical issues we needed to address in 5
the application. Which we did.
6 Our approach going in was to comply with 7
NUREGS 2191 and 2192 to the greatest extent practical.
8 And I think we've been able to accomplish that.
9 We alone with the NRC have worked 10 diligently to hold to the 18-month review schedule.
11 And with issue of the SER, with no open items or 12 confirmatory items in July, we were able to beat the 13 target schedule of 18 months.
14 MEMBER BLEY: Steve?
15 MR. HALE: Yes?
16 MEMBER BLEY: I'm not sure if I've heard 17 other people say they've reviewed other REIs from 18 other applications. Did that help you very much?
19 MR. HALE: Yes, very much so. Especially 20 the later ones. You know, some of the older ones, but 21 since River Bend and Waterford were fresh, --
22 MEMBER BLEY: Um-hum.
23 MR. HALE: To say the least. And actually 24 River Bend, they were trying to test the overall 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 process for subsequent licensing, --
1 MEMBER BLEY: Yeah.
2 MR. HALE: As well as part of the River 3
Bend review. We thought it was important to look at 4
those.
5 MEMBER BLEY: So you think you avoided 6
some --
7 MR. HALE: Yes. We did.
8 MEMBER BLEY: Okay.
9 MR. HALE: Next slide, Steve. Having been 10 involved with both original license renewal and 11 subsequent license renewal, I have an excellent 12 perspective as to what was involved in the integrated 13 plan assessment for both efforts.
14 And since the ACRS has reviewed every 15 license renewal application that has proceeded us, and 16 Turkey Point is the first application for subsequent 17 license renewal, we thought the best way to present 18 the methodology was talk about the differences between 19 what we saw for license renewal and subsequent license 20 renewal.
21 For scoping and screening, there were 22 minimal changes, because the criteria really hasn't 23 changed. You have to address modes that have been 24 implemented or current licensing basis changes which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 may have occurred.
1 And we did have to update our evaluation 2
for (a)(2), which is the scoping criteria of non-3 safety, which can affect safety. And that's primarily 4
due to the fact that guidance documents have been 5
developed since we submitted originally. And we had 6
to address that specific guidance.
7 As we moved into aging management reviews 8
and aging management programs, you start to see the 9
differences between subsequent license renewal and 10 original license renewal.
11 Turkey Point, as has been mentioned 12 previously, was a pre-GALL plant. And as a result our 13 aging management reviews were based on available 14 industry tools at the time.
15 With the issue of GALL Rev. 00, Rev. 01, 16 Rev. 02, and the interim staff guidance documents as 17 well as GALL SLR, the number of aging affects we had 18 to address has expanded somewhat.
19 The most significant differences we saw in 20 going to subsequent license renewal, was in the number 21 of aging management programs.
22 Turkey Point currently has 28 aging 23 management programs for original license renewal. And 24 moving into SLR, we're going to have 50 aging 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 management programs.
1 I'd like to give you some specifics on 2
those AMPs. So of the 50 AMPs, 14 are new, and 36 are 3
existing. And when I say existing, that's just lining 4
up what we do at the site with the GALL requirements.
5 For the 14 new AMPs, it's not as if we're 6
not doing things under those aging management 7
programs, they're just not under the umbrella of 8
license renewal or specifically identifying that this 9
is credited for our renewed license.
10 As noted, there were 11 aging management 11 programs with exceptions to GALL. All of which had 12 been reviewed by the NRC and accepted. Most have to 13 do with specific design features or characteristics at 14 Turkey Point that require taking the exception.
15 For plant specific AMPs, the new AMP has 16 to do with the polymer high voltage insulators 17 associated with the recovery path for the switch yard 18 to station blackout.
19 It's plant specific because there 20 currently is no GALL program for polymer insulators, 21 high voltage insulators.
22 The other plant specific AMP is an 23 existing AMP, which has been approved by the NRC, 24 having to do with management of fatigue of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 pressurizer surge lines. Next slide.
1 With regard to commitments, there are 57 2
mostly on an AMP by AMP basis. And include the 3
required pre-SPEO inspections.
4 These will be maintained separately for 5
clarity and to avoid confusion with commitments for 6
current license renewal.
7 There are three license conditions as 8
noted here. One of which is replace the carbon steel 9
piping inside containment, which we've already talked 10 about.
11 There will be a new chapter of the USFAR 12 specifically dedicated to subsequent license renewal.
13 This chapter will include a complete list of the 14 subsequent license renewal commitments.
15 Both Next Era, FPL, and ENERCON have 16 extensive experience with license renewal commitment 17 management and implementation. And this will ensure 18 all actions will be completed per the schedule.
19 Additionally as Steve mentioned, a new 20 SLRA liaison position has been created at Turkey 21 Point, which will be filled by a senior level, highly 22 qualified and experienced person.
23 Finally, moving onto time limited aging 24 analysis. The effort for SLR involved the same 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 detailed search of current licensing basis documents.
1 When compared to original license renewal, 2
some of the dispositions have changed from disposition 3
I and double II to triple III. And that's because 4
there are now GALL AMPs for certain TLAs like fatigue 5
that didn't exist previously.
6 We also updated the environmentally 7
assisted fatigue calculations because of some changes 8
to the guidance documents like NUREG 6909.
9 We did identify two new TLAs for 10 subsequent license renewal. One is for adopting leak 11 before break for non-primary loop RCS piping. And the 12 other involved the update of the reactor coolant pump 13 integrity analysis supporting Code Case N-481.
14 And that's really all I had to say. Any 15 questions?
16 MEMBER BLEY: Yeah, the new Chapter 17 SAR 17 is -- is that required? Or you just decided it was a 18 good idea?
19 MR. HALE: You're required to have an FS 20
-- UFSAR updated as part of the regulations with your 21 submittal.
22 MEMBER BLEY: Right. But the idea of 23 having a separate chapter on this was --
24 MR. HALE: We thought it would be best.
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80 You know, certainly when you think about the future 1
and the overall transition between the two, you know, 2
you can -- we're already making those plans.
3 But initially we felt it best to maintain 4
a separate UFSAR chapter.
5 MEMBER BLEY: You have any hints of others 6
in the industry that are likely to do that?
7 MR. HALE: We did have some dialog with 8
Exelon and Dominion. And I think they're pretty much 9
following a similar path.
10 MEMBER BLEY: Similar to you. Okay.
11 CHAIRMAN RICCARDELLA: And what's the 12 status of your reactor vessel with regard to radiation 13 embrittlement? Anything interesting?
14 MR. HALE: The reactor vessel, we redid 15 all of the calculations for subsequent license 16 renewal. TTS is at about 264. Something like that.
17 We did have some components that fell 18 below the 50 foot pounds for upper shelf energy. That 19 actually occurred for Turkey Point in the '90s.
20 And so we had to have a specific EMA 21 analysis --
22 CHAIRMAN RICCARDELLA: Okay.
23 MR. HALE: Addressing upper shelf energy.
24 But we updated that evaluation for original license 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 renewal. We updated it for extended power uprate.
1 And now we've updated it again for, when 2
I say we, it was Framatome actually did the analysis 3
for the -- the EMA analysis.
4 CHAIRMAN RICCARDELLA: And what is your 5
total end of life fluence at the end of the -- of 6
renewal fee? The section renewal fee again?
7 MR. HALE: I will have to pull that value 8
up. I can get it to you.
9 CHAIRMAN RICCARDELLA: Okay. I'd like 10 that.
11 MR. HALE: We -- it's in the application 12 in Chapter 4.2. But, we can give you that.
13 MR. BOGGS: This is Scott Boggs. I'd be 14 happy to answer that for you.
15 CHAIRMAN RICCARDELLA: Okay. Yeah.
16 MR. BOGGS: The end of life fluence on the 17 vessel is 1.08 D to the 20th. And on the limiting 18 weld it's 9.86 D to the 19th.
19 CHAIRMAN RICCARDELLA: Thank you.
20 MR. BOGGS: And that includes significant 21 margins that we've included for fuel loading.
22 CHAIRMAN RICCARDELLA: Okay. Thank you.
23 MR. HALE: And that was also based on 72 24 EFPY.
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82 CHAIRMAN RICCARDELLA: Um-hum.
1 MR. HALE: Which basically assumes the 2
plant runs at like 100 percent capacity factor from 3
here until the end of the plant life.
4 CHAIRMAN RICCARDELLA: Okay.
5 MR. HALE: So, there's margins inherently 6
built into the EFPY that was assumed for the fluence 7
calculations.
8 CHAIRMAN RICCARDELLA: Thank you.
9 VICE CHAIRMAN SUNSERI: So any other --
10 this isn't the end of your presentation is it?
11 MR. MAHER: No. It's not. So, we're on 12 slide 17. So, again, I would like to thank the 13 Committee.
14 Even though Turkey Point is a predone 15 plant for the first round of license renewal, we've 16 adopted the SLR goal with minimal exceptions as Steve 17 was talking about.
18 In keeping with the sustainability that 19 Brian talked about earlier, the goal now is to focus 20 on building and maintaining margin to be able to get 21 to 80 years worth of operation.
22 We have a dedicated individual with 23 engineering and license experience that has a direct 24 report to Brian. And he'll oversee the remediation 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 that's taking place now, and the transition through 1
the subsequent period of operation.
2 Again, I'd like to thank the ACRS 3
Committee for the opportunity to present to you. And 4
we'd like to thank the NRC staff associated with our 5
work in getting -- working through the areas that 6
needed to be reviewed so that we could be in this 7
position right now.
8 And I'll turn it over to Brian for any 9
closing remarks.
10 MR. STAMP: Yes. So on behalf of Florida 11 Power & Light and Turkey Point, I would like to thank 12 the NRC for the thorough review our subsequent license 13 renewal application.
14 The many hours spent in this review will 15 give the public confidence in the continued operation 16 at Turkey Point.
17 The process was very thoughtful. It was 18 predictable. Which gave us, as well as the rest of 19 the industry, a clear path forward.
20 And again, we appreciate and recognize the 21 importance of this first of a kind licensing effort, 22 both for the industry as well as for ourselves, as it 23 establishes, you know, lessons learned and processes 24 going forward.
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84 Thank you very much.
1 VICE CHAIRMAN SUNSERI: Thank you.
2 MEMBER KIRCHNER: May I ask a question?
3 VICE CHAIRMAN SUNSERI: Sure. I was just 4
going to ask if there were any other questions.
5 MEMBER KIRCHNER: So, often margin is used 6
for increasing power. Is there a plan to do another 7
EPU for this plant? For Three or Four?
8 MR. MAHER: No. Not currently there is 9
not.
10 MEMBER KIRCHNER: Okay. Thank you.
11 VICE CHAIRMAN SUNSERI: Members, any other 12 questions? And Jose, are you still out there? Do you 13 have a question for the group?
14 MEMBER MARCH-LEUBA: I'm here. The 15 weather is improving a lot. But I don't have any 16 questions.
17 (Laughter) 18 VICE CHAIRMAN SUNSERI: Okay. Well, 19 that's good to hear. Thank you.
20 All right. Well, I'll just close this 21 part and say I think this team did a fair 22 representation of what we heard during the 23 subcommittee week.
24 There was a little slightly different 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 group of people I would characterize as closer to the 1
day to day operations, which really inspired us that 2
the programs are being implemented in the way that Mr.
3 Stamp indicated here.
4 So, we appreciate your -- enduring the 5
hardship to be here during the week. And I know it's 6
a big commitment to be here when your plant is, you 7
know, just being missed by a hurricane. So, we thank 8
you for that.
9 We will now transition to the staff for 10 the staff presentation. So, Meena, if you could get 11 your team ready.
12 (Off mic comments) 13 VICE CHAIRMAN SUNSERI: Whenever you're 14 ready, yes.
15 MR. ROGERS: Good morning Chairman 16 Riccardella, Mr. Sunseri and Members of the ACRS. My 17 name is 18 VICE CHAIRMAN SUNSERI: Hold on. Can you 19
-- is your mic on?
20 MR. ROBERTS: Thank you. I'll start 21 again. Good morning Chairman Riccardella, Mr. Sunseri 22 and Members of the ACRS.
23 My name is Bill Rogers. I'm one of the 24 Project Managers for the safety review of the Turkey 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 Point Nuclear Generating Units Numbers Three and Four, 1
or Turkey Point subsequent license renewal application 2
3 As previously stated, we are here today to 4
discuss the NRC staff's safety review of the Turkey 5
Point SLRA that is documented in the safety evaluation 6
report or SER, which was issued on July 19, 2019.
7 And joining me here at the table today is 8
Angela Wu, a Safety Project Manager in the Division of 9
Materials and License Renewal, or DMLR, who will be 10 assisting with the slides.
11 And the Turkey Point Lead Safety Project 12 Manager, Lois James. And she's a Senior Project 13 Manager also in DMLR.
14 We have some in the audience, and joining 15 by phone are additional members of the technical staff 16 who participated in the review of the SLRA and 17 conducted the audits. Next slide please.
18 We will begin the presentation with a 19 general overview of the time line of the staff's 20 review.
21 The presentation will provide information 22 on the closure of the open items related to the buried 23 and underground piping and tanks program, which was 24 previously discussed in the meeting with the plant 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 license renewal subcommittee.
1 We will also discuss the disposition of 2
the aging management programs, AMPs, relative to the 3
guidance contained in the generic aging lessons 4
learned subsequent license renewal report, the GALL 5
SLR report.
6 And the staff's review of the SLRA and 7
audit activities. We will also highlight several of 8
the technical areas reviewed, which were unique to the 9
subsequent license renewal review relative to the 10 initial license renewal reviews.
11 And discuss the site specific license 12 condition. And then I will close with the staff's 13 safety conclusion. Okay. Next slide.
14 Turkey Point Units Three and Four were 15 granted the original licenses in 1972 and 1973, which 16 were set to expire in 2012 and 2013 respectively.
17 Prior to the license expirations, the licensee, 18 Florida Power & Light Company, or FPL, submitted the 19 initial license renewal application for 40 to 60 years 20 on September 11, 2000.
21 The staff met with the ACRS subcommittee 22 on plant license renewal and full committee on both 23 the safety evaluation report or SER with open items, 24 and the safety evaluation report and issued the Units 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 Three and Four initial renewed licenses in 2002 with 1
expiration dates of 2032 and 2033 respectively.
2 In January 2018, FPL submitted an SLRA for 3
Turkey Point Units Three and Four. The staff 4
performed its review of the SLRA, issued the SER of 5
open items, and presented the results of our review to 6
the ACRS subcommittee on plant license renewal on June 7
21, 2019.
8 Subsequently, the staff closed the open 9
item associated with the buried piping and issued the 10 SER on July 19, 2019. Next slide, please.
11 As I mentioned, the staff previously 12 identified one open item in the SER of open items 13 associated with the buried and underground piping and 14 tanks, an aging management program.
15 Specifically, the staff determined the 16 need for additional information regarding why 17 additional inspections beyond those recommended in the 18 GALL SLR report were not included in for buried steel 19 piping during the ten-year period prior to the 20 subsequent period of extended operation.
21 FPL provided additional information to 22 address the staff's concerns. Including one, FPL 23 committed to install cathodic protection at least nine 24 years prior to the subsequent period of extended 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 operation consistent with the GALL SLR report.
1 FPL clarified that there was only one pipe 2
break. And it was due to excavation activities and 3
not age related degradation.
4 And third, FPL committed to perform the 5
additional inspections beyond those recommended in the 6
GALL SLR report during the ten years period prior to 7
the subsequent period of extended operation.
8 So prior to the ARCS subcommittee meeting 9
on plant life renewal, the meeting was on July 21, FPL 10 provided additional information to address the staff's 11 concerns. And that was documented in the SER of open 12 items.
13 On the basis of this information, the 14 staff determined that its concerns related to the open 15 items were resolved. And as a result, the staff was 16 able to present the open items as a resolved issued 17 during the ACRS subcommittee meeting. Okay. Next 18 slide, please.
19 The SLR described a total of 49 AMPs. The 20 SLRA described a total of 49 AMPs. Twelve new and 37 21 existing.
22 This slide identifies the Applicant's 23 original SLRA disposition. You have the AMPs in the 24 left column. And the final disposition documented in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 the SER in the right column.
1 All of the AMPs were evaluated by the 2
staff for consistency of the GALL SLR report, and to 3
ensure compliance with 10 CFR, Part 54.
4 As a result of the staff's review, the 5
Applicant made several changes to the AMPs. One new 6
plant specific AMP was addressed to -- was added to 7
address polymer high voltage insulators.
8 As an example of another change the SME 9
Section 11, Subsection IWL AMP was changed from 10 existing with enhancements to existing with 11 enhancements and exceptions. Next slide, please.
12 Okay. On this slide I'd just like to 13 discuss a little of the staff's review and audit 14 activities which occurred to support the staff's 15 evaluation.
16 The Turkey Point review is the first 17 safety review performed by the staff using the GALL 18 SRP, or excuse me, GALL SLR, I mean, SRP/SLR guidance 19 issued in 2017.
20 In developing the process for reviewing 21 and SLRA, the staff identified several process 22 efficiencies as compared to the safety review of 23 initial license renewal applications.
24 For example, one efficiency dealt with the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 conduct of audits. Instead of one large and lengthy 1
onsite audit, the staff conducts two standard audits, 2
an operator experience audit, and an in-office audit.
3 This allows us to streamline the number of 4
staff traveling to the site. The majority of the 5
audit activities and breakout discussions were 6
conducted in our office through the use of portals and 7
telecommunications.
8 Also, onsite activities are performed on 9
an as needed basis. The necessity for an onsite audit 10 might be identified in the following manner:
11 During the performance of the operating 12 experience audit and the in-office audit, when it's 13 determined that onsite observations of material 14 conditions related to aging or -- excuse me, related 15 to aging, or component locations and configurations 16 are required to complete the staff's review.
17 Or, when a complex technical issue is 18 identified such that communications and information 19 gathering would be more efficiently performed by an 20 onsite audit.
21 For Turkey Point, during the two-week 22 experiencing audit, the staff performed an independent 23 review of plant specific operating experience to 24 identify pertinent examples of age related 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 degradation.
1 And it was documented in the Applicant's 2
corrective action program database. And to provide 3
insight into AMP effectiveness.
4 During the four-week in-office audit, the 5
audit team focused on two areas, the scope and the 6
screen review, and the review of AMPs, aging 7
management review items or AMRs, and time limited 8
aging analysis, or TLAAs and those reviews.
9 Based on the operating experience audit 10 and the in-office audit, the staff determined that it 11 was necessary to perform an onsite audit and also a 12 separate complex and technical issue audit.
13 The onsite audit reviewed documentation of 14 aging management programs and directly observed 15 material conditions of various structures and 16 equipment.
17 The onsite complex technical issue audit 18 reviewed appli -- the Applicant's proposed methods to 19 manage the effects of aging of concrete and steel 20 structural supports to irradiation, as well as the 21 analysis results. The issue will -- this issue will 22 be discussed further with the next slide.
23 Another efficiency that the staff 24 implemented as part of its review of the SLRAs was to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 no longer require the performance of inspection 1
procedure IP 71002, the license renewal inspection.
2 This inspection primarily focused on the adequacy of 3
pre-implementation activities for AMPs.
4 However, for subsequent license renewal, 5
the majority of aging management programs have already 6
been implemented and in effect since the beginning of 7
the 40 to 60 year period of extended operation. And 8
therefore, are no longer in a pre-implementation 9
phase.
10 Additionally, the 71002 include a scoping 11 and screening evaluation that focused on the 12 Applicant's activities relative to initially 13 identifying non-safety related SOCs with a potential 14 to affect safety-related SOCs, for inclusion of these 15 non-safety related SOCs within scope.
16 For SLR required observations of non-17 safety related components with a potential to affect 18 safety-related components, are performed by the 19 technical review staff as part of the SLRA review, or 20 during an onsite audit.
21 For Turkey Point, the staff's review was 22 also informed by the results of the Region II initial 23 license renewal inspection, IP 71003, phase four, 24 which coincided with the SLRA review time line.
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94 It should be noted that the phase four 1
inspection is related to the issuance of the initial 2
renewed license. And is independent of the SLRA 3
review.
4 MEMBER BLEY: Bill, can I interrupt you a 5
second?
6 MR. ROGERS: Yes, sure.
7 MEMBER BLEY:
I was not at the 8
Subcommittee meeting and haven't discussed with you.
9 The -- on first license renewal, many of us always 10 found those inspection reports extremely informative.
11 And, I haven't thought about this before 12 right now. Your argument why you didn't need them 13 now, you know, makes sense on the one hand. On the 14 other hand, things would show up in those reports that 15 you didn't really see any other way.
16 I assume there are continuing inspections 17 and on the AMPs and you had access to those reports, 18 is that right?
19 MR. ROGERS: Yes, that's correct. And, I 20 was going to discuss this, I'll just go off the script 21 here for a second and just explain what occurred 22 during our review process.
23 So, as you mentioned, the next inspection 24 procedures, IP71-003, that has one to four phases.
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95 And, the first two are post-licensing prior to PEO, to 1
initial PEO. And, the fourth one would occur during 2
the period of extended operation.
3 So, the Turkey Point IP71-003 Phase 4 4
coincided with our review. It was during the time 5
line.
6 MEMBER BLEY: Okay.
7 MR. ROGERS: So, the -- actually, the 8
inspector that performed the -- led the inspection, 9
Paula Cooper, Region II is on the telephone today.
10 But what we found is there are ongoing sets of 11 inspections that, for a period of time overlap the 12 initial review and the subsequent renewal.
13 So, while we found while the Phase 4 14 inspection is not -- does not have like a regulatory 15 tie to this licensing action, the information's still 16 very useful to us. And, we had discussions during 17 both our audit of our onsite audit that we were 18 reviewing plant conditions, which are open issues 19 figurations. We discussed that with the Regional 20 Inspector, Paula Cooper, during that time.
21 And, there has been some, you know, 22 there's been back and forth on that.
23 I will say that when our auditors were 24 onsite, well, actually, both. When they were 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 reviewing operating experience from the plant 1
database, and when they were onsite, we had similar 2
observations.
3 Now, the actions taken by the two parties 4
are somewhat different. Paula issued an inspection 5
procedure that had some findings associated with it.
6 MEMBER BLEY: Okay.
7 MR. ROGERS: We're in a licensing action, 8
and what we did is we used that information to 9
determine whether the aging management programs need 10 to be augmented or enhanced in some fashion.
11 So, we both reacted to the same set of 12 information that was shared back and forth.
13 Relative to the firs points you made about 14 the 71-002 inspection --
15 MEMBER BLEY: Yes?
16 MR. ROGERS: -- in pre-implementation, 17 that inspection is more of a paper review for when you 18 review the AMPs. They're not implemented; there's not 19 as much material to review.
20 So, for example, for this review, the new 21 programs reviewed by Headquarters
- staff, and 22 essentially, it's the same manner that the inspectors 23 would have done it during the pre-implementation 24 review.
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97 The one difference that I think is also 1
notable, is when the inspectors were doing the (a)(2) 2 review, that (a)(2) portion of that 71-002 inspection 3
back in the first renewal, so there were three bodies 4
that looked at that. The inspectors would do an 5
inspection. We had one division in NRR that would do 6
a review of that. And then, we had the License 7
Renewal Division look at it. So, all three parties 8
looked at it.
9 And, as the Applicant indicated, there's 10 not been an extensive change in the results or 11 approach to then identify items in scope for non-12 safety effective safety.
13 However, I will note that when we did our 14 onsite audit, one of the things that was looked at 15 during the onsite audit was (a)(2) related questions.
16 And, they were done by the Headquarters staff at that 17 time. So, we did take someone onsite to look at that.
18 MEMBER BLEY: Matt, did the Subcommittee 19 have an opportunity to review with the Inspector any 20 of the things? The only reason I'm bringing it up is, 21 if not, we might want to go -- push on that for the 22 next one.
23 VICE CHAIRMAN SUNSERI: Yes, no, Paula was 24 here --
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98 MEMBER BLEY: Oh, okay.
1 VICE CHAIRMAN SUNSERI: -- in person and 2
3 MEMBER BLEY: Very good.
4 VICE CHAIRMAN SUNSERI: -- made a 5
presentation.
6 MEMBER BLEY: I don't want to get her to 7
repeat what she said to the Subcommittee. I just 8
wanted to make sure we were involved in that. That's 9
great. Thank you.
10 And, thank you for that.
11 MR. ROGERS: Certainly.
12 MEMBER BLEY: Wonderful explanation.
13 MR. ROGERS: I will note, she's on the 14 telephone right now if you'd like to follow up with 15 any additional questions. She's on standby for that 16 purpose.
17 MEMBER BLEY: I haven't been through that 18 in the detail that would make that make sense to me 19 right now, so thank you.
20 MR. ROGERS: Okay, fine.
21 MEMBER BLEY: And, thanks to Paula.
22 MR. OESTERLE: So, this is Eric Oesterle.
23 I was just going to add that one of the 24 things that the staff committed to the ACRS was that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 for the Subcommittee meetings and the Full Committee 1
meetings, that we would always bring a site 2
representative or a Regional Inspector to the meeting 3
to share their observations on the inspections they've 4
done for license renewal including observations on 5
material conditions of the plant.
6 And so, like Mr. Sunseri identified Paula 7
who did the inspection down at Turkey Point, she was 8
at the Subcommittee meeting and is available today.
9 And so, we will continue to do that for future ACRS 10 meetings on SLR.
11 MEMBER BLEY: Thanks, Eric. I think 12 that's really important.
13 MR. ROGERS: Sure, and thank you. Next 14 slide, please?
15 So, this slide just addresses two examples 16 of plant specific issues unique to subsequent license 17 renewal.
18 The staff performed a first of a kind 19 review of irradiated structural concrete and steel 20 located in containment. In this case, it was the 21 reactor pressure vessel support system.
22 The issue of impacts of high fluence 23 levels was identified as an area of interest and the 24 Commission staff's requirement memo on the performance 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 of subsequent license renewal reviews.
1 Currently, there is no generic resolution 2
for addressing high fluence level impacts on 3
structural systems and components.
4 The staff guidance developed for 5
subsequent license renewal indicates all SLR 6
applicants should perform a plant-specific review of 7
fluence levels within containment, identify any 8
potential impacts on structural components, and 9
develop aging management program activities as 10 necessary.
11 In this case, the Applicant's evaluation 12 of the impact of high fluence levels on the concrete 13 portion of the RPV structural support system conclude 14 that the effects of radiation would not impact the 15 ability of the support system to perform its intended 16 function.
17 In addition, the concrete components would 18 continue to be periodically inspected during the 19 performance of the structure's monitoring program.
20 The Applicant's evaluation of the steel 21 portions of the RPV structural support system 22 determined that the enhancements to the ASME Section 23 11 in service inspection of nuclear power plant 24 components Subsection IWF AMP would be required.
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101 The Applicant enhanced the Section 11 IWF 1
AMP to require the inspection of all of the accessible 2
surfaces of all six reactor vessel supports of each 3
unit on a frequency of once every five years.
4 The Applicant had determined that these 5
inspections would demonstrate to the effects of aging 6
and the steel supports will be adequately managed so 7
that the intended functions will be maintained during 8
the subsequent period of extended operation.
9 The staff audited the Applicant's analyses 10 and evaluations over a period of several weeks both at 11 Turkey Point site and the additional facilities. The 12 staff's review was a multi disciplined effort that 13 included a team with expertise in fluence, materials, 14 and structures.
15 The staff concluded with reasonable 16 assurance that the Applicant had identified the 17 potential aging effects and developed aging management 18 programs that monitor the components conditions to 19 identify the effects of aging prior to the loss of 20 intended function.
21 Next, I'll discuss the staff's review of 22 the newly identified material component combination, 23 the polymer high voltage insulators, and as previously 24 mentioned, this was not addressed in the GAL SLR 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 report and the material component combination had been 1
first identified during the River Bend initial license 2
renewal application reviewed in 2018.
3 MEMBER BLEY: Are you planning that this 4
will make it into the GAL report in the next revision 5
or how do we track this?
6 MR. ROGERS: So, what we're -- yes, what 7
we're doing at the moment in the part of our process 8
is we gather this type of information in the package 9
and internally to the division in addition with 10 lessons learned. And, then, there is an ongoing 11 discussion of whether or not revisions are necessary.
12 And, they either will take the form of Interim Staff 13 Guidance or revisions to the document.
14 MEMBER BLEY: Okay. I didn't ask the 15 Applicant the same question but I'll just ask you.
16 How did you and the Applicant, together, come up with 17 what the right process is for inspecting these or 18 foreseeing them in the future?
19 MR. ROGERS: Sure. The -- well, the 20 Applicant determined what the process was. They took 21 their operating experience, they did an analysis and 22 evaluated these polymers. And, let me go back to my 23 notes for one moment.
24 They performed evaluation of the polymer 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 high voltage insulators and the evaluation considered 1
a loss of material, reduced insulation resistance to 2
the many mechanisms including wear, surface buildup of 3
contamination, and polymer degradation. Those were 4
the three primary things.
5 They put that into an aging management 6
program, had an evaluation of how they would address 7
these aging mechanisms. At that point, the staff 8
evaluates that and concluded that it met the 9
requirements of managing the effects of aging.
10 MEMBER BLEY: Okay, thanks. And, is there 11 Interim Staff Guidance now on this for the next time 12 it comes up?
13 MR. ROGERS: Not at this point. I might 14 ask Eric to address that thought.
15 MR. OESTERLE: Thanks, Bill. This is Eric 16 Oesterle.
17 So, back in March we did have a -- we 18 conducted a public meeting on SLR lessons learned 19 based on where we were with the NRC staff's review of 20 the three SLR application at that time.
21 And, one of the major focuses of that 22 meeting was looking at technical issues that were 23 identified as a result of these reviews that maybe 24 ripe for development of new guidance.
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104 And so, those both remain on the table.
1 We committed to periodic engagements with industry on 2
these technical issues and others that come up. But 3
we haven't determined yet what's the right format, if 4
it's going to be an ISG on one or more issues combined 5
or are we going to do a revision to the GAL SLR report 6
and the SRP SLR documents wholesale.
7 But there is a commitment to have these 8
ongoing discussions on lessons learned and technical 9
issues that would rise to that level.
10 MEMBER BLEY: I'm not personally familiar 11 with these insulators. Is there enough experience 12 with them so far that we really have a good idea of 13 what kind of problems they might incur with aging?
14 And, that the proposed AMP, well, the accepted AMP is 15 the right thing to do?
16 MR. HALE: Hi, this is Steve Hale.
17 In development of the aging management 18 program of the polymers, we did have some historical 19 information regarding how these have performed.
20 Although they're relatively new.
21 We spent quite a bit of time with our 22 information and distribution department which is the 23 ones that are primarily involved with this.
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105 is they're very resistant to, you know, collecting 1
salt spray and things like that.
2 MEMBER BLEY: That was a good thing.
3 MR. HALE: Yes, yes, exactly. So, you 4
know, in our discussions with D&B, you know, they were 5
able to give us the feedback on the types of aging 6
management we needed to perform on those insulators.
7 But they do find that they perform much better from 8
the, you know, collection of debris and things of that 9
sort.
10 MEMBER BLEY: thank you.
11 MR. HALE: Yes.
12 MR. ROGERS: There is one site specific 13 safety license condition that addresses FPL's one time 14 inspection AMP. The staff determined that the one 15 time inspection AMP did not address carbon steel 16 containment spray system piping as would be expected.
17 The Applicant indicated it plans to 18 replace the carbon steel piping in the containment 19 spray system inside containment with stainless steel 20 piping.
21 In addition, the Applicant had already 22 included this pipe replacement in site approved plant 23 improvement plan and has begun replacement.
24 MEMBER BLEY: And, again, I didn't ask 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 them, but how did they get boric acid in there? Did 1
they actually start the spray accidently some time or 2
3 MR. OESTERLE: Leaky valves.
4 MEMBER BLEY: They -- okay.
5 MR. ROGERS: So, rather than requiring the 6
Applicant to address the material environment and 7
aging effect, it wouldn't remain in the subsequent 8
period of extended operations.
9 The staff developed this license condition 10 to ensure that the pipe would be replaced prior to 11 SPEL.
12 In conclusion, the staff finds that the 13 requirements of 10 CFR 54.29(a) have been met for the 14 subsequent license renewal of Turkey Point Units 3 and 15 4, that there is reasonable assurance of safe 16 operation of Turkey Point Units 3 and 4 during the 17 subsequent period of extended operation.
18 That ends our presentation and we're 19 available for additional questions.
20 VICE CHAIRMAN SUNSERI: Well, once, again, 21 I think I would add that you did a good job of 22 representing what went on the Subcommittee meeting.
23 I know it's hard to replicate, you know, a five hour 24 meeting in a short period of time like this. But we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 do appreciate the high level review.
1 I do want to offer the opportunity for 2
your Region II representative to provide any remarks 3
if she cares to. I think she was very impressive 4
during the Subcommittee meetings, so I'd just offer 5
that comment if Paula's out there.
6 MS. JAMES: Paula? Paula? Paula Cooper?
7 MEMBER REMPE: Is the line open so she can 8
9 MS. JAMES: We have a separate line.
10 MEMBER BLEY: It still might not be open.
11 He's checking on it now.
12 MS. JAMES: This is Lois James. I'm -- I 13 will go give her a quick call.
14 VICE CHAIRMAN SUNSERI: Well, that's okay.
15 It was just a courtesy.
16 MS. JAMES: I'll see which line she's on.
17 VICE CHAIRMAN SUNSERI: Yes, if there was 18 something, it's not -- I think we have all our 19 questions answered.
20 MS. JAMES: Okay.
21 VICE CHAIRMAN SUNSERI: All right. So, at 22 that point, we are done. Are there any other 23 questions from the members?
24 MEMBER BROWN: I have one. I had 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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108 forgotten something on the buried piping. I'll look 1
back at the old slides from the Subcommittee meeting.
2 In this one, your slide four identified 3
the second item was there had been breaks in the 4
piping that was a result, there was only, and that was 5
due to an evacuation construction excavation activity.
6 But then, you noted several leaks, leaks 7
I take are not breaks, I presume there's a difference.
8 I mean, I think there's a difference. Okay.
9 MS. JAMES: Yes, sir. This is Lois James.
10 MEMBER BROWN:
And
- then, in the 11 Subcommittee meeting, you indicated that there was a 12 set of inspections, of the methodic protection systems 13 be installed within nine years prior to the additional 14 twenty-year extended operation.
15 And, but then, you were going to monitor 16 the -- with inspections during that ten-year period 17 prior to the end period also.
18 But then, you had two caveats in there.
19 If the CP system looks like it's effective you do one 20 thing, if it's not, you do something else. That -- I 21 don't -- that was in the Subcommittee you. You didn't 22 bring that out so there's really a kind of a two sets 23 of operations that you're going to be doing inspection 24 wise, that's the way I read the Subcommittee.
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109 I presume that's still in place? That 1
didn't disappear between the Subcommittee and Full 2
Committee meeting?
3 MS. JAMES: This is Lois James.
4 No, sir, that did not disappear. We were 5
trying to give a high level overview of it, not get 6
into that level of detail. But we do have Brian Allik 7
on the phone.
8 MEMBER BROWN: I just wanted to make sure 9
there --
10 MS. JAMES: Yes.
11 MEMBER BROWN: -- no -- that we didn't 12 lose some --
13 MS. JAMES: That has not changed.
14 MEMBER BROWN: -- consistency. That's all 15 I was --
16 MS. JAMES: That has not changed.
17 MEMBER BROWN: -- trying to make sure 18 something hadn't changed.
19 MS. JAMES: No, sir.
20 MEMBER BROWN: Okay, that's all I had.
21 Thank you.
22 VICE CHAIRMAN SUNSERI: Was there a 23 question over here?
24 MEMBER BROWN: No, nothing.
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110 VICE CHAIRMAN SUNSERI: Anybody else?
1 Jose, you have any comments you want to 2
add or questions you want to ask?
3 MEMBER MARCH-LEUBA: Nothing here.
4 VICE CHAIRMAN SUNSERI: All right. So, 5
now we will open the phone line for any public 6
comments. And, while we're getting the phone lines 7
open, we'll turn to the audience here. Is there 8
anybody in the audience who would like to make a 9
public comment, come to the microphone, state your 10 name, and provide your comment.
11 (NO RESPONSE) 12 VICE CHAIRMAN SUNSERI: Okay. So, there 13 is no comments from the room. I'll turn to the phone 14 line. If there's any members of the public listening 15 in that would like to make a comment, now is the 16 opportunity. State your name and provide your 17 comment, please.
18 MS. COOPER: This is Paula Cooper at 19 Region II. Can anybody hear me?
20 VICE CHAIRMAN SUNSERI: Yes, Paula, we can 21 hear you now.
22 MS. COOPER: Awesome, because the staff 23 line was busy and I couldn't get on, so I'm on the 24 public line.
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111 VICE CHAIRMAN SUNSERI: Oh, okay, all 1
right.
2 MS. COOPER: However, I don't have any 3
comments to add other than if you have any questions 4
for me, I am here. But I will say that Turkey Point 5
staff, and I don't want to make it seem like I am pro-6 licensee, but they were very receptive to every 7
comment and observation that we gave them on the 8
inspection. And, I'm pretty confident that they're 9
going to implement them appropriately.
10 VICE CHAIRMAN SUNSERI: All right, well, 11 thank you for that comment.
12 Are there any other members of the public 13 that would like to make a comment?
14 (NO RESPONSE) 15 VICE CHAIRMAN SUNSERI: All right. So, we 16 know the line is open because Paula used it. So, if 17 there's no other comments, we'll close the public 18 line. And, Mr. Chairman, we turn the floor back to 19 you.
20 CHAIRMAN RICCARDELLA: Okay.
21 VICE CHAIRMAN SUNSERI: Well, let me --
22 I'm sorry, just one other point.
23 We do have a draft letter report prepared 24 with our recommendations from the Subcommittee that we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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112 will review in deliberation at your choice. Thank 1
you.
CHAIRMAN RICCARDELLA: Yes, I think we'll 2
-- we have a lot to cover. And so, we'll take about 3
a 15 minute break, reconvene at 3:30 by that clock.
4 And, we have, by my count, five letters. There's one 5
I'd like to cover fairly rapidly. It's a revision to 6
a letter that we approved last meeting on a NuScale 7
report, on a NuScale topical report that I had some --
8 we had some comments while we were at NuScale and we 9
concluded that those were substantive, not editorial.
10 And so, we're going to reconsider that.
11 And then, we have the two letters that 12 were from the topics that were today. And, I'd like 13 to at least go through -- at least have a read through 14 of both of those before we conclude today.
15 So, with that, we will adjourn and I guess 16 for the day or -- recess.
17 (Whereupon, the above-entitled matter went 18 off the record at 3:17 p.m.)
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Turkey Point Units 3 and 4 Subsequent License Renewal ACRS Full Committee Meeting September 04, 2019
2 Agenda
- Introductions (Bill Maher - FPL Senior Licensing Director)
- Performance Philosophy and Sustainability - (Brian Stamp
- FPL Turkey Point Site Director)
- Turkey Point Site Information (Steve Franzone - FPL Licensing Manager)
- Subsequent License Renewal (SLR) Project (Steve Hale -
ENERCON Technical Lead)
- Closing Remarks - (Bill Maher - FPL Senior Licensing Director)
3 Performance Philosophy and Sustainability
4 Turkey Point Site Information
5 Turkey Point Site Information
6 Turkey Point Site Information Plant History
- Initial operating licenses issued Unit 3 - July 19, 1972 Unit 4 - April 10, 1973
- 1983-1984, replaced original steam generators
- 1991, upgraded on-site electrical system going from two emergency diesel generators (EDGs) to four EDGs
- 1992, Hurricane Andrew
- 1995, 5% power uprate, 2200 MWt to 2300 MWt
- June 6, 2002, received renewed operating licenses (first Westinghouse units)
- 2004-2005, replaced reactor vessel heads
- 2010, implemented alternate source term (AST) methodology
- 2012, 2013 implemented ~ 15% extended power uprate (EPU +
MUR) 2300 MWt to 2644 MWt
- 2012, 2013, Unit 3 and 4 entered the period of extended operation (PEO)
7 Turkey Point Site Information
8 Turkey Point Site Information
9 Turkey Point Site Information Significant Plant Modifications Since Initial License Renewal
- Replaced reactor vessel heads
- Replaced main and auxiliary transformers
- Cooling canals rehabilitation
- Replaced cask crane structure and crane
- Obsolescence Projects
- Extended Power Uprate (EPU) related modifications
- In progress Low pressure turbine rotor replacements U3 & U4 Containment Spray piping replacement Modifications and improvements to structures
10 Turkey Point Site Information Current Plant Status
- Plant Status
- 18 month fuel cycle
- Reactor oversight process (ROP) action matrix Column 1
- Last refueling outage Unit 3, Fall 2018 Unit 4, Spring 2019
- Next refueling outage Unit 3, Spring 2020 Unit 4, Fall 2020
11 SLR Project Multi-year effort starting in 2015
- Completed Feasibility study in early 2016
- Application submitted and accepted in early 2018 FPL/ENERCON Team
- Multi-discipline team with significant nuclear experience, both on site and corporate
- Extensive license renewal experience, both licensing and implementation, including original License Renewal (LR) effort for Turkey Point (PTN)
- Extensive PTN specific engineering and licensing experience
- SLRA Liaison position staffed at site by senior, experienced person
12 SLR Project Regulatory and Industry Guidance
- Used NEI 17-01 guidance
- Incorporated lessons learned from previous LRAs
- Conducted industry peer reviews
- Followed NUREG-2191 (GALL-SLR) and NUREG-2192 (SRP-SLR) to the greatest extent possible
- 18 month NRC review schedule (from April 2018)
Current Status
- Final SER issued July 22nd, 2019, no open or confirmatory items
13 SLR Project Integrated Plant Assessment - Overall approach similar to that of original LR
- Differences between LR and SLR
- Scoping and screening Minimal differences Some updates required to address 10 CFR 54.4(a)(2)
- Aging management reviews PTN initial LR pre-GALL, additional aging effects required disposition based on NUREG-2191 (GALL-SLR)
- Aging management programs (AMPs)
Significant differences PTN initial LR pre-GALL, 28 AMPs PTN SLR, 50 AMPs
- 14 new AMPs 12 consistent without exception 1 consistent with enhancement 1 plant-specific
- 36 existing AMPs (35 based on GALL) 1 consistent with exception 24 consistent with enhancements 10 consistent with exceptions and enhancements 1 plant-specific
15 SLR Project Commitments
- 57 total
- Will be maintained separate from commitments for current LR
- 3 license conditions in SER:
Incorporate supplement into the UFSAR Implement programs and complete activities described in the supplement prior to the subsequent period of extended operation (SPEO)
Replace containment spray piping inside containment UFSAR
- New Chapter 17, maintained separate from current LR
- SLR commitments included in table in Chapter 17 Project Team has extensive experience with LR commitment management and implementation
16 SLR Project Time-Limited Aging Analyses (TLAAs)
- Based on GALL AMPs for TLAAs, some TLAA dispositions shifted from (i) or (ii) to (iii)
- Updates required to environmentally assisted fatigue calculations due to changes in guidance documents
- Two new TLAAs for SLR Leak-Before-Break analysis for non-primary loop reactor coolant piping
- Pressurizer surge, residual heat removal and accumulator lines Reactor coolant pump integrity analysis used to address Code Case N-481
17 Closing Remarks
- Manage aging effects to ensure intended functions are maintained
- Evaluated TLAAs with acceptable results
- Satisfied requirements for subsequent license renewal
- Retain gains and build margin for the future
Advisory Committee on Reactor Safeguards Full Committee Meeting Turkey Point Nuclear Generating Unit Nos. 3 & 4 Subsequent License Renewal Safety Evaluation Report (SER)
September 4, 2019 Bill Rogers, Senior Reactor Engineer Office of Nuclear Reactor Regulation
Presentation Outline
- Overview of Safety Review of Turkey Point SLRA
- Closure of Open Item 3.0.3.1.7-1, Buried and Underground Piping and Tanks Program
- Aging Management Programs (AMPs)
- Staff Review and Audit Activities
- Examples of Plant-Specific Issues Unique to Subsequent License Renewal
- Site-Specific Safety License Condition
- Conclusion 2
Overview of Safety Review of Turkey Point SLRA 3
Application Submitted - January 31, 2018 Acceptance Determination - April 26, 2018 Safety Evaluation Report with Open Items - May 21, 2019 ACRS Subcommitee Meeting - June 21, 2019 Safety Evaluation Report - July 19, 2019 Unit Initial License Initial License Renewal Application Renewed License Expiration Date Subsequent License Renewal Application 3
07/19/1972 09/11/2000 06/06/2002 07/19/2032 01/31/2018 4
04/10/1973 09/11/2000 06/06/2002 04/10/2033 01/31/2018
Open Item 3.0.3.1.7-1, Buried and Underground Piping and Tanks Program 4
Issue: Basis for why additional inspections, beyond those recommended in GALL-SLR AMP XI.M41, are appropriate for buried steel piping during the 10-year period prior to the subsequent period of extended operation (SPEO).
Issue Resolution 1
Cathodic protection (CP) not operational during the 10-year period prior to the SPEO.
AMP XI.M41: CP is installed at least 5 years prior to the SPEO.
CP will be installed at least 9 years prior to the SPEO.
2 FPL stated in the SLRA that there have been breaks in buried piping at Turkey Point.
Only one pipe break - due to construction excavation activities; not age-related.
3 Staff noted that several leaks have occurred in buried steel piping.
FPL will conduct additional inspections in the 10-year period prior to the SPEO.
Applicants Original Disposition of AMPs 12 new programs 12 consistent 37 existing programs 3 consistent 27 consistent with enhancements 6 consistent with enhancements and exceptions 1 plant specific Final Disposition of AMPs in SER 14 new programs 12 consistent 1 consistent with enhancement 1 plant specific 36 existing programs 24 consistent with enhancements 1 consistent with exceptions 10 consistent with enhancements and exceptions 1 plant specific 5
Aging Management Programs (AMPs)
Staff Review and Audit Activities 6
Audit / Inspection Dates Location Operating Experience Audit May 7 - 18, 2018 Rockville, MD ML18183A445 In-office Audit June 18 - July 23, 2018 Rockville, MD ML18230B482 On-site Audits
- Complex Technical July 17 - October 17, 2018 Homestead, FL /
Rockville, MD ML19032A536
- On-Site August 27 - 31, 2018 Homestead, FL ML18341A024
Examples of Plant Specific Issues Unique to Subsequent License Renewal 7
- Staff performed a first-of-a-kind review of irradiated structural concrete and steel located in containment
- Staff performed a review of polymers used in high voltage insulators not discussed in GALL-SLR Report
SER Section 3.0.3.1.4, One-Time Inspection 8
- Site-Specific Safety License Condition
- Replace the portions of the carbon steel containment spray system piping inside containment that are exposed to treated borated water with stainless steel piping, which is not susceptible to loss of material in a treated borated water environment
- On the basis of its review of the SLRA, the staff finds that the requirements of 10 CFR 54.29(a) have been met for the subsequent license renewal of Turkey Point Nuclear Generating Unit Nos. 3 and 4.
9 Conclusion