ML20207J455
| ML20207J455 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1999 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-3067, NUDOCS 9903160284 | |
| Download: ML20207J455 (177) | |
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J UNITED STATES NUCLEAR REGULATORY COMMISSION'S j ADVISORY COMMITTEE ON REACTOR SAFEGUARDS j MARCH 12, 1999 l
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The contents of this transcript of the proceeding 1 1
of the United States Nuclear Regulatory Commission Advisory j
/~s '
f A_/ Committee un Reactor Safeguards, taken on March 12, 1999, as !
i reported herein, is a record of the discussions recorded at the meeting held on the above date.
i l
This transcript had not been reviewed, corrected and edited and it may contain inaccuracies. l l
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g-483 l' UNITED STATES OF AMERICA-() 2 3
NUCLEAR REGULATORY COMMISSION 4 MEETING: '460TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5- (ACRS) ,
6 U.S. Nuclear Regulatory Commission )
l 7 Conference Room 2B3 I 8 Two White Flint North I L 9 Rockville, Maryland 10 Friday, March 12, 1999 l
-11 l
12
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I The committee met, pursuant to notice, at 8:30 !
13 a.m.
l i
I 14 MEMBERS PRESENT: i
() 15 DANA POWERS, Chairman, ACRS 16 GEORGE APOSTOLAKIS, Member, ACRS 17 JOHN J. BARTON, Member, ACRS 1 l
-18 -MARIO H. FONTANA, Member, ACRS l
19 THOMAS KRESS, Member, ACRS 20 DON W. MILLER, Member, ACRS
- 21 ROBERT L. SEALE, Member, ACRS 22 WILLIAM J. SHACK, Member, ACRS 23 GRAHAM B. WALLIS, Member, ACRS 24 ROBERT E. UHRIG, Member, ACRS i'
25 MARIO V. BONACA, Member, ACRS L
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484 1 -- - PARTICIPANTS:
2 MR. LIEBERMAN l.
3 .MR. BORCHARDT, ,
4' MS. GINSBERG-5 M1.-SOHINKI i
6 MR. ANKNEY 7 MR. CLAUSEN 8 MS. THORNHILL 9' DR. JOHN T. LARKINS '
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l 485 1: PROCEEDINGS
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( 2 [8:30 a.m.-]
3 CHAIRMAN POWERS: Let's come into session.
4 This'is the third meeting of.the third day of the 5 460th meeting of the Advisory Committee on Reactor i . .. l
- 6. Safeguards. l t
i 7 During today's meeting the committee will consider 1 8 the following: guidance for implementing the revised l 9 Lenforcement policy; safety evaluation report on the topical
-10 report regarding tritium production core; reconciliction of
'11 ACRS comments and recommendations; report of the Planning 12 and Procedures Subcommittee; future ACRS activities;
.13 proposed ACRS reports.
14- A portion of today's meeting may be closed to l
'Q
( ,/ '15 discuss organizational and personnel matters that relate 1 l
16 solely to the internal personnel rules and practices of this 17 advisory committee and matters the release of which would i
18 constitute a clearly unwarranted invasion of personal 19 privacy. ;
20 The meeting is being conducted in accordance with
- 21. the provisions of the. Federal Advisory Committee Act. Dr.
I 22 John T. Larkins is the Designated Federal Official for the
'23 initial portion of the. meeting. ,
24 We have received no written statements or requests 25- for time ~to make oral statements from members of the public 1
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486 1L regarding today's. session. .
[} 2 A transcript of portions of the meeting is being 3 kept, and it is requested that' speakers use one of the 4 microphones, identify themselves, and speak with sufficient 5 clarity and volume so they may~be readily heard.
t 6 I will remind members that today.at Noon we will I 7 have a showing of the PBS documentary on TMI and its ,
8 revisionist history --
9 [ Laughter.] '
10 CHAIRMAN POWERS: I also have a request from 11' Professor Uhrig to make comments at the beginning of the 12 meeting.
13 DR. UHRIG: You have a new version of the research j 14 report. I would ask -- l
/
(D) 15 CHAIRMAN. POWERS: Microphone, please.
16 DR. UHRIG: I would ask that you take a look at 17 the sections that pertain to you, get back to me with 18 whatever you want to do with it marked up, total I
'19 replacement, whatever you feel appropriate, the sooner =the 20 better but I would like to have something by next week. l 21 MR. BARTON: When next week? ,
22' DR. UHRIG: Let's say the end of next week but the 23' sooner the better.
~24 .DR. FONTANA: Is this the whole report?
25 DR. UHRIG: That's it.
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487 1 DR. FONTANA: Okay. '
l 2 DR. UHRIG: It's down to 120 pages.
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3 DR. SEALE: It's been on a diet. t 4 DR. UHRIG: It's been on a diet. Thank you. l 1
5 CHAIRMAN POWERS: Our opening session today deals !
6 with the. guidance on implementing the revised enforcement i 7 policy. :
8 Professor Seale, I believe that you are the 9 cognizant member on this issue. In fact, it looks like you
'l 10 are the cognizant member for the rest of the day. I l
11 DR. SEALE: Hardly. Okay, well, you'll remember j 1
12 that last November we had a presentation on the proposed l l
13 changes in the enforcement policy. Just to tickle your l 14 memory, it had to do.with the change in the level at which a
() 15 notice of violation would be~ issued and you will recall that 16 the estimate was at some 80 percent or so of the NOVs were 17 in fact in that category.
18 There has been a considerable amount of Staff
- 19. activity since then in interactions with the Commissioners
! 20 and also then in issuing a notice in the Federal Register !
21- about a month ago. I understand that the policy came into l 22 effect-in fact yesterday, the lith, and prior to that an l 23 implementation guide was issued that -- and you have a copy l l
24 .of a draft ofcthat or maybe it's the guide that is attached i l l 25' to the' Tab Number 12 in your bocklet. In general, we did
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er-I v 488 l 1 concur; f~ 2: .Today we are going to hear on an update of those l x_ - l 3 developments and also on some other things perhaps that have j
- 4 occurred as a result of discussions between the Staff and j
- 5. .the NEI,on various aspects of this whole policy. This whole j 6 issue is let's say still somewhat evolving, at least in i i
7 terms of the perspective that the Committee has, although I l, 8 understand that the Staff and NEI may have a set of j 9 recommendations that are at least gelled enough to be the.
10 basis for a.six months or so trial period, after which an ;
l 11 ' assessment of the effectiveness would be done and we have !
P 12 'ind'icated a desire to hear that, j i
13 I urge you to try to spot any pitfalls you may see ;
i
() 15- ol in the f e d, an h hat gu s I ur 16 over to Mr. Lieberman.
]
l 17 I should point out that we have until 10 o' clock i 18 including Committee discussion on this, and an,NEI has also 19 requested time to make a short presentation, so Mr.
20 Lieberman, if we could be through by about 9:40 we would 21 appreciate it -- with your presentation.
22 MR. LIEBERMAN: Okay. Have you framed your
- 23. questions? .My presentation is relatively brief.
24 DR. SENLE: Okay.
25 MR. LIEBERMAN: And then I look forward to ,
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489 1 questions.
[~
2 DR. SEALE: Okay. !
3 MR, LIEBERMAN: What I would like to do today -- I i 4 ' guess ~for the record I-am Jim Lieberman, Director of the i 5 Office of Enforcement. What I would lik' to do today is to 6 discuss three items that the Staff is working on. The whole !
7 Agency is changing various things and enforcement is clearly
'8 an~ area where a lot of changes are occurring.
9 The first change, as was mentioned, was changing ,
10 the Treatment Level IV violations, which we provided a {
11 briefing on last year. I will be discussing where we are on 12 that effort.
13 .Second, the Agency is relooking at the reactor 14 oversight process and that has four aspects'to it -- the
() 15' . inspection process, the assessment process, the enforcement 16 process, and reporting, and we want to have enforcement 17 integrated in that process and we developed a pilot ;
i la enforcement approach subject to Commission consideration l
19- 'that I would like to talk about, and then finally I would !
20 like to talk about our efforts on risk-informing the ,
22 The new interim enforcement policy dealing with 23' Level IV violations for power reactors went into effect '
24' yesterday, Under that approach most violations of Level IVs 25- will be described in inspection reports and treated as
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490 L 1 non-cited violations. A non-cited violation is a legal
-(} 2 violation but the licensee does-not have to respond to the l 3 violation. The licensee has to place it in the corrective 4 action program and take corrective action in a time period i
5 commensurate with safety.
6 We will close out the item noncompliance for 7 purposes ofl enforcement when the licensee places it into the 8 corrective action program. We will be focusing more of our 9 attention on the overall corrective action program and 10 efforta of the licensee and not on individual violations or 11 corrective actions for the individual violations because by 12 definition the Level IV violations are not that safety 13 significant.
14 With four exceptions we would continue having (G j 15 Level IV violations that result -- the slide says NCV but it 16 should be a Notice of Violation, an NOV, requiring a 17 response.
18 The purpose --
19 CHAIRMAN POWERS: I guess I didn't understand 12 0 that. With some exceptions Level IV violations will result 21 in notices of violation?
22 MR. LIEBERMAN: No. You're right -- the slide was 23 right in the first place. Appreciate the correction. I am 24 working with almost a double negative here.
25 Normally Level IV violations will result in l
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491 1 non-cited violations. There are four situations which I i '
, T 2 will discuss in a moment where we will have notices of l un Y 3' violation, so the exception is on the notices of violation, )
i 4 and we are doing this because to a large degree in the past
]
5 when the Agency issued a notice of violation it required the i 6 licensee to develop corrective action, implementing the :
7 program in a three-day time period established by 10 CFR 8 2.201 for responses to notice of violation. I
- 9. In some cases the violations that the licensee had !
l 10 identified through his own corrective action program -- and 11 their corrective action programs identify many more l L 12 violations'than we identify -- were more safety significant, 13 and thus we have the licensee focusing their attention on 14 violations of less significance than the ones that they may
() 15 have identified.
16 With this new policy, licensees will be able to j 17 focus their attention on noncompliances based on the safety !
, 18 significance.and not on what you might even call an l
l 19 artificial schedule based on the fact that NRT happened to )
I 20 describe the item on the NRC inspection report. )
l 21 The four exceptions are failure to restore 22 compliance in a timely manner -- and the issue here is the 23 licensee cannot let a violation continue. It's almost a 24 willful situation. Action must be taken to address the 25 circumstances for an ongoing violation. If the valves are I
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492 l 1 in the wrong position, the licensee has to put the valve in
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C 2 _the right position for the mode of operation. The licensee :
3 then has time to develop action to prevent recurrence ;
4 commensurate with the significance of the particular item.
- 5. The second item has to do with putting the 6 - violation in the corrective action program, because the 7 whole premise of the program is the licensee is dealing with 8 the issue as part of its corrective action program. Our f
9 inspectors will be seeking a reference from the licensee as !
10 to where the item is in the licensee's corrective action !
11 program, so if we follow up in the future on that particular l 12 item, we will know where to look for the item.
13 We recognize that there may be some violations due 14- to their significance in the circumstances that it doesn't J T
()
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15 need to be formally treated into a corrective action program 2
16 to prevent recurrence. It might have been an isolated 1" implementation issue. In those cases we expect the licensee !
l 18 to at least have analyzed that, kept a brief record of that 19 so that we can have that for any future inspection 20 activities.
21 The third exception is where the violation 22 reoccurred as a result of inaccurate corrective action for a 23 previous violation, and the violation was identified by the 24 NRC. Here we are focusing on the need to prevent recurrence 1
25 -and the effectiveness of the' licensee's corrective actions l
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493 1 including the ability'for the licensee to identify
(~'T 2 deficiencies and violations.
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3 We realize that the industry, NEI, does not like 4 this particular exception, primarily because it has an 5 assessment aspect to it. They would have us judge the 6 significance of the violation on the individual violation 7 and not consider the fact that it might have been 8 repetitious.
'9 MR. BARTON: You say this violation has to be 10 identified by the NRC? If it was identified by the licensee 11 and put in the corrective action system but the corrective 12 action was inadequate to preclude it from recurring, that 13 would not fall underneath this bullet?
14 MR. LIEBERMAN: In the second time the licensee e'
(N) 15 had identified it and put it back in the corrective action 16 program, so you have one aspect of the violation is that the 17 corrective action was inadequate. They identified that 18 corrective action and put it back in the program. l 19 If we had identified it, rather than the licensee, 20 then we would issue a notice of violation.
21 MR. BARTON: Is this who can document the failure 22 'of corrective action quicker?
23 MR. LIEBERMAN: We are aware of that issue and the 24 guidance we have placed on that is to give the licensee a l 25 reasonable opportunity to identify the issue, j
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l 494 1 For example, if at a morning meeting the licensee
[~-)\ -2 is describing its activities for the day and the events of, .
3 say, the previous evening and there was an issue that may be !
4 a noncompliance and the licensee said we are going to get 1 l
1 5 there later on this morning and the inspector immediately :
l 6 walks over to that particular area, does an inspection, l
7 finds a recurring violation, issues a citation -- that would 8 be inappropriate.
9 We want to give the licensee an opportunity to I
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10 have its system work. It is not a who can get there first
{
11 issue. I 12 MR. BARTON: And this will be made clear to the 13 resident inspectors?
14 MR. LIEBERMAN: We have done that through our l
() 15 training and in our guidance. In addition, any violation 16 that we do issue under this program has to be concurred in 17 by my office'for the first several months and theraafter a I
18 Division Director has to concur on it to provide the '
l 19 oversight to make sure that when we do issue a violation i 20 those are the violations that we want to issue.
21 DR. SEALE: John -- and I would ask all the l 22 members of the Committee -- to take a look at the guidance 23 that is included under "12" here. I read through it. It's 24 got that stultifying governmentese writing style with it, 25 but it does appear to be a good faith effort to present the t
ANN RILEY & ASSOCIATES, LTD. l Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i ,
i I 495 l
l 1 spirit that Mr. Lieberman has indicated here and in l
2 particular it includes the examples that we asked the Staff
[} ,
j 3 to include in their guidance.
4 I would be very interested to get your response to 5 those situations to see whether or not -- you know, it is a 6 good faith attempt but how good is it? -- and I am sure Mr.
l 7 Lieberman would like to know if you have any suggestions on 8 that. >
9 MR. LIEBERMAN: I would. You know, there's 10 hundreds and hundreds of different types of violations.
11- -There's many different circumstances. Nothing -- we can 12 never have a system that can be a cookbook that will avoid 13 the need to exercise judgment, and this is a particular 14 area -- how inadequate was the corrective action? How do
) 15 you decide when corrective action is inadequate? What is 16 the time period the licensee should have to develop the 17 corrective action since he can't develop corrective action 18 instantaneously? Those are judgment calls and we have tried i
19 to put out some guidance there.
20 As to this particular exception, this exception l
21 does have an assessment aspect and, as you will see in a few 22 moments, as part of the revisions to the policy to address 23 the'new assessment program we don't intend to continue with l 24 this particular-exception.
25 Now the fourth exception has to do with willful
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1 496 1 violations. Currently the policy'provides in Section 1
2 7 (b)' (1) (d) of the policy that if the licensee identifies a
(
3 willful violation by one of-its employees and if the 4 . employee involved is not a' supervisor, is not a " licensee .
5 official" -- that is the term we use in the policy, and the l l
6 matter has to do with a low safety significant issue, then !
7 we can issue a noncited violation. l 8 On the other hand, if a supervisor is involved and ;
9 a licensee official is involved in the violation, regardless i i
10 of the significance of the underlying violation then we ;
11 would issue a notice of violation and this is what this i 12 exception addresses.
13 Inspection reports that are issued after yesterday 14 will be implementing this policy. I think it's going to g-x3 l
i
( j :15 reduce unnecessary regulatory burden. At the same time it
)
16 is going to enhance our efficiency because we can be 17 focusing on the more significant of violations. It will 18 still focus on the need for corrective action and our agency 19 will focus more on the overall program and not on the 20 individual low level violations.
21 Now let me turn to the -- if you have any 22 questions on the Level IVs maybe this is a good time to 23 raise those.
24 [No response.]
25 MR. LIEBERMAN: Okay. Let me go to the new I
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1 approach. I have to say this is a proposed approach because !
(} 2 the Commission has not been briefed on this, nor have they 3 approved this approach.
4 In'looking at what we are doing, we feel the P
5 existing enforcement approach has been a good policy. It 6 has focused attention on issues of noncompliance and it has ;
7 served to~ provide regulatory messages to improve performance 8 and there's been a number of positive aspects about it.
9 At the same time, there have been cases where the 10 messages that were given through the escalated enforcement i 11 process has been inconsistent with the messages we have L 12 given though the SALP process in that there have been cases l 13 where licensees have received SALP is and we have had civil 14 penalties and at the same time there's been cases where we I
() 15 haven't had many civil penalties and licensees have been 16 SALP 3.
i l 17 The performance of licensees have substantially I 18 improved over the years. The enforcement program that we 19 have been using have essentially been unchanged since before 20 TMI in basic philosophy of using civil penalties to provide 21 deterrents.
22 So in developing the new assessment process there j 23 was an opportunity to relook at what we have been doing and R L 24' 'the first step of relooking at what we were doing was to 25- compare assessment and enforcement and see similarities and ;
i
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1 498 1 ' differences.
.2 Both of.these programs serve to formally -- the
'3 ~ first serves to determine what is the significance of.the 4' individual violation or the finding to serve as a basis of 5 , Agency. action. The enforcement process uses'four levels of '
6 severity -- severity levels 1, 2, 3, 4. The assessment uses 7 colors -- green, white, yellow, red. So both programs 8 assess the significance of violations.
j i
9 Both of these programs serve to develop Agency -)
10 action. In the' enforcement area we develop sanctions, )
11 notice of violations, civil penalties. The assessment i
12 action matrix under the new assessment process will be 1 13 developing, resulting in management meetirigs or regulatory 14- conferences, demands for information, 50.54 (f) letters, ,
15- orders--- and these are the same type of things we get 16 through the enforcement process.
17 Both provide incentives to improve performance and 18 emphasize the importance of compliance. Licensees will have 19 the desire to avoid being in white space and yellow space 20 and red space because of the increased inspection activity i
21 and the. increased Agency attention,.some of the deterrent !
2'2 effects we have with the enforcement program with civil 23 penalties. The licensees want to avoid civil penalties not i
24 .because of the huge monetary amount, because our penalties !
~
25 are relatively small compared to the size of reactors, but I
l i
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t 499
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'l because of the adverse publicity, the attention the Agency l l
() 2
-3 places on licensees'who have civil penalties.
Both processes provide public notice of what the J
1 4 Agency thinks of the licensee's performance, so given the
- 5 similarities of-both of these programs we thought we could 1
6 do a better job in integrating the enforcement and i
7 assessment and we think that rather than have the 8 enforcement program drive the assessment process the way it 9- may have occurred in the past, the assessment process should 10 be the driver of Agency action and enforcement should 11 complement it, not direct the result. ,
l
- 12 We want enforcement to be focused on safety. We 1 l 13 want it to be consistent with.the philosophy of the L 14 assessment process because the assessment process is going
() 15 to characterize the risk and safety significance of each l
1 16 finding to develop these crior bands and the agency j 17 response, which we are using the same system,-so we won't i 18 have a situation where enforcement thinks something is
-19 significant and assessment doesn't or vice versa.
20 So to achieve that we want to do the assessment ]
L l
l 21 once and use the assessment process to determine 1
22 significance.
- 23. We will still be considering compliance because I l 24 the Agency _ir a regulatory agency and so we need to continue
)
25 .to emphasize the-importance of compliance. The assessment i
4 i
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500 1 process will be considering compliance issues as well as
(} 2~ other issues that may have risk to safety that may not 3 necessarily be a specific requirement as we focus on !
'4 performance as well as root causes.
5 We want the enforcement process to be predictable, 6 to be more effective and more efficient to implement. We 7 want to design 'he' program in a way that doesn't create 8 unnecessary regulatory burdens but there is some regulatory 9 burden in any regulatory program but it is the appropriate 10 burden, and obviously'we want to have public confidence that
.11 - we think a clearer enforcement program that is more 12 systematic, more predictable, more integrated with the 13 assessment process should serve to go a long way in building l 14 public-confidence.
l
( 15 DR. SEALE: Let me make sure I understand or 16 clarify one point. Now you are talking about all aspects of -
17 enforcement not just Level IVs?
18 MR. L7,EBERMAN: That's right. That's a good 19 point. I'm talking about the totality of enforcement for 20 power. reactors -- the cases that may get civil penalties, 21 the cases that may get orders, and whatever.
22 DR. SEALE: But in general, these will go through 23 - .the assessment process rather than short-circuiting the 24 assessment process.
l - 25 MR. LIEBERMAN: Right. That gets to my next i
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501 1 point. Our planned approach is to divide violations into
/
i 2 two categories.
b 3 Category 1 or Group 1 are those violations that -
4 will be evaluated under the assessment process. Those are 5 the violations that go to the safety of the reactor, how the 6 reactor is designed and operated and maintained, emergency 7 planning, radiation protection and safeguards.
8 There are another group of violations which are ;
9 outside the assessment process. Those are the violations 10 associated with wi11 fulness, discrimination, things which 11 impact the Agency's ability to oversee licensees, things 12 like reporting, reports, inaccurate information, not giving 13 us -- providing amendments for us to review such as on the 14 50.59 or updates of quality assurance plane, things that fm t
) le affect the ability of the Agency to oversee the reactor. l 16 That doesn't go to direct safety, as to whether l l
17 there is risk at the facility but it goes to our ability to j 18 have reasonable assurance in carrying out our activities.
19 That is not covered by the assessment process. !
l 20 DR. SEALE: Let me try to draw a line. Maybe it 21 is inappropriate but I will try anyway.
22 If it is an NRC safety violation, it will go 23 through the assessment process -- is that what you are 24 saying?
25 MR. LIEBERMAN: Correct.
l
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i 502 l 1 'DR. SEALE: If it is an OSHA safety violation,
\ 2- personnel safety not. reactor safety, where does that go? !
[/
(_ !
3 MR. LIEBERMAN: Radiation protection for worker !
4 personal safety -- )
t 5 DR. SEALE: Yes. [
6 MR. LIEBERMAN: -- as to radiation, that's NRC '
, 7 jurisdiction and not OSHA. i 8 DR. SEALE: I understand but what about -- !
9 MR. LIEBERMAN: If it is trip and fall railing i 10 type issue, that is an OSHA issue, that would be covered by l
-11 the OSHA process. NRA -- the traditional enforcement 12- doesn't cover that either.
13 DR. SEALE: Okay, fine. Thank you.
14 MR. LIEBERMAN: As to the first group, we plan to {
/'S
( )g 15 utilize the assessment process to categorize the i
16 significance of violations covered by the assessment process i 17 so this way we will have a one-to-one relationship. The IB Agency will have one view on the significance of a 19 particular violation.
20 Then the assessment process will place that 21 individual violation into a color band, a green, white, l
22 yel. low, red. If it is a significant violation in safety, a j i
23 risk significant violation, that would be the white, yellow 24 and red, that will be going into the NRC response band where 25 we will have additional inspection and oversight. For those ANN RILEY & ASSOCIATES, LTD.
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i 1
503 ;
i 1- casca we would use notice of violation and the licensee
(}
(/
'2 would be required to provide a response to us and that l 3 response will help as as we do our oversight.
4 If the-licensee u& already given us a response, ;
5 because for example an LER was submitted, they wouldn't have !
6 to give'us the same information twice but assuming we didn't l
7 have.the information that we required in an NOV we would get l
~8 an NOV for that category.
9 For the ones which are considered licensee 10 response band, the green, we would have the noncited l l
11 violation and we would preserve the interim enforcement i 12 policy which I discussed earlier with three of the four 13 exceptions. We would continue the exception of not 14 restoring compliance, not putting it in the licensee's m
15 corrective action program and the willful issue, but 16 deleting the exception associated with the repetitive 17 ' corrective action issue because that should be part of the 18 assessment process and those type violations would be 19 evaluated for the risk significance and even if the 20 violation is repetitive, if it is still not a risk 21' .significant issue'then it would be considered the green type 22 of categorization and would result in a noncited violation.
23 We will be utilizing the Agency action matrix to 24 determine the Agency's response to the violation. We won't 25 need to have severity levels because there are basically
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I 504 l l
1 only two types of violation, the NCV and the notice of '
/ 2 violation.
O' We won't need to use civil penalties to provide 3 incentives for licensees to improve their program because 4 the color bands will provide that incentive by the process 5 in the Agency action matrix, and I presume you are familiar l 6 with the Agency action matrix from previous briefings. !
l 7 A red performance result in a shutdown, a yellow 8 performance I believe will result in meetings with the 1
9 Commission, probably a demand for information, possibly an 10 order, and the Agency response is a function of the number l
11 of hits in the various color bands based on performance 12 indicators and individual findings, and that process we feel j 13 should provide the incentives for licensees to maintain I 14 themselves in green space, which is a solid acceptable j
'yA) 15 performance, and thus we don't need the negative aspects of 16 s civil penalty to achieve a better performance.
17 Now we would --
l 18 DR. SEALE: Let me raise a question. What you are l 1
19 saying in essence is that everything goes into the 20 assessment process if it is white, yellow or red, but the 21 response to a yellow or red in particular is an accelerated 22 assessment response. That is, you don't wait until the next 23 assessment, normal, you know, calendar roll, you would !
l 24 actually ask someone to come in for a meeting with the j 25 Commissioners or whatever if that were a violation which was
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505 1 at that level of severity.
,m
/ j 2 MR. LIEBERMAN: I am not sure of that exactly.
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3 DR. SEALE: Do you see what I am driving at? e 4 MR. LIEBERMAN: Right. If we have a -- I also 5 misspoke when I said yellow -- meeting with the Commission.
6 There's five columns on the action matrix. The fourth 7 column is where the Commission would be informed and I guess 8 that is multiple yellow inputs, but if there is a violation 9 -which is considered red or yellow that is going to be a risk 10 significant violation and we would begin dialoging with the i
11 licensee with conferences. l j
12 I am not sure exactly when the Commission would l
13 meet or the EDO would meet with the licensee. Some of these l
14 details are still being developed and we are going to learn i (7_ ) 15 an awful lot with a pilot program. l 16 DR. SEALE: Our impression of the assessment ,
i 17 process is that there is a sort of calendar roll, and that l 18 seems at least in my personal opinion, a little cavalier if 19 you have a violation that would be a multiple yellow or a 20 red, and so while it is part of the assessment process it is 21 maybe not the assessment process as we quite know it right 22 now. It is some accelerated assessment response.
23 MR. LIEBERMAN: I think the answer to that has to 24 be yes.
25 DR. SEALE: Okay.
l l
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i 506 l i
1 MR. LIEBERMAN: And I can get back to you on that.
2 I'just don't know -- we don't have anyone from NRR here so I l)\
\. i 3 don't know the specific answer, but I can't imagine that we i i
4 are going to wait --
)
5 DR. SEALE: Well, I can't'either. j
(
6 MR. LIEBERMAN: --
so we have to deal with that as !
I 7 part of real-time. !
8 MR. BORCHARDT: This is Bill Borchardt from the !
9 Staff.
10 I think we need to make it clear also that no 11 enforcement actions are going to wait for the annual 12 assessment period.
13 DR. SEALE: Yes.
14 MR. BORCHARDT: That they are done in a more l
() 15 timely issue by issue manner, so when we talk about an 16 assessment of the safety or risk significance of a l
)
17 particular violation, that will be done in a timely manner 18 and not wait for an annual rollup --
19 DR. SEALE: Okay.
20 MR. BORCHARDT: --
and the enforcement actions j 21 whether there be a notice of violation or not will happen on 22 a schedule independent of the annual assessment.
23 MR. LIEBERMAN: Right, so we will be getting the 24 corrective action in the interim but your question was the 25 additional actions and some of those I think just have to i
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l l 1 occur in real-time -- ,
i l
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'2 DR. SEALE: Sure --'in a timely manner. -
l 3 .MR. LIEBERMAN: -- and not waiting for the annual !
l 4~ rollup of the action.
5 Okay. Now as to the violations not covered by the 6 assessment process, we would use traditional enforcement. ,
I . . :
7 We would also use traditional enforcement if we had actual 8 consequences, and by actual consequences I mean l 9 overexposures to workers or the public, substantial releases 10 of material, things which we call now Level I, II and III l 11.. under Supplement IV of the enforcement policy, because when 12 you have overexposures and releases of materials, the 13 barriers have failed. ;
14 We would also use traditional enforcement for the f~% ,
( 15 willful violations or the deliberate or careless disregard, j 16 for cases involving discrimination and for cases where the I 17 NRC's ability for oversight is impacted. In these type ]l 18 situations I think the traditional enforcement approach may 19 be a good vehicle for providing deterrence because it's not 20 going to be evaluated as part of the assessment process.
21 I am pretty excited about this process. Given
-22 that the changes of performance of the industry and given 23 resource issues that we face, and given an assessmeat 24 process that should be viable, that will patrol the Agency's I 25 response to issues, this new enforcement process -- I think 1
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l l
F- 1 l
508 I l' it makes a lot-of sense.
)
%-l
- 2 It will still maintain a focus on safety because
\
-3' compliance -- I mean on compliance because each issue will 4 be still addressed either through noncited violations or 5 through notices of violations and licensees won't be able to 6 disregard violations. If they do, that raises issues of- !
i 7~ willfulness and we can deal with that still. The type of- !
l
'8- enforcement will be based on risk and their performances 9 where the Agency wants to head more. )1 10 It will result in escalating our responses.again l
11 based on risk and' performance, using the Agency action 12 matrix.
13 I think it should still deter noncompliances by I 14 increasing the licensee's cost and direct their attention
]
() 15 for declining performance such that we don't really need 16- civil penalties with the negative aspects and the regulatory 17 burden associated with that. We might spend too much time )
18 arguing over whether a civil penalty is appropriate. Within i
19 the agency we spend a lot of time focusing on severity -
20 levels, at the right severity level, is the right amount in l l
21 the civil penalty, the potential litigative issues 22 associated with civil penalties and enforcement. We will be 23 able to avoid those and focus more attention on the 24 'particular safety significance and the corrective action for ;
1
'25 the particular_ issue, which I think is good. l l- )
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509 9
1 It will assure that we will have consistency 2 between the assessment process and enforcement. It will be v
3 a public process and I think it should improve public 4 confidence, but at the same time there will be those members -
5 of the public who will be concerned that the Agency may be 6 taking the wrong approach by doing away with civil 7- penalties.
8 We think that, as we explained, the rationale for 9 'this and the focus on safety and risk, and they're still 10 :getting corrective action, and we are still getting -- we'll 11 be able to monitor performance through the PIs and 12 inspections to determine if there's declining performance 13- and we have a relatively structured way to deal with 14 declining performance and if we follow that in a consistent
() 15 way I think that should build public confidence.
16 Enforcement will. complement assessment, which I
.17 think is important. I have already said I think it will 18 make it more efficient for NRC to implement and finally and 19 I think importantly I thin'k it is going to remove some of 20 the adversary relationship between the industry and the 21 Staff and we'll be able to focus on problems that we need to 22 focus on without this issue of litigation over our heads.
23 That's all I wanted to say about the new process.
24 MR. BARTON: I have a' question. Maybe I missed 25 it. On your Slide 7 you talk about violations which impact i
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510 L 1 NRC's ability to oversight. An example of that? !
( 2 MR. LIEBERMAN:
) That would be a 50.9 violation, 3 inaccurate information -- 50.59 issue where we should have l 4
had a license amendment to review and that we didn't reviewi 5 interference with an' inspection -- that doesn't happen very 6 often -- things _like that.
l f
7 MR. BARTON: Okay.
8 DR. SEALE: You mentioned that several of the 9 questions here are still not completely resolved or so on l 10 and you haven't taken this to the Commissioners as yet.
11 When do you plan to do that?
12 MR. LIEBERMAN: I believe the Commission paper is l
13 due to the EDO this Monday. We are going through drafts of l
! 14 this paper pretty rapidly. We have a briefing before the
() 15l Commission I believe on March 26th. I believe the 16- Commission paper is probably due at the end of next week. !
I 17 DR. SEALE: So if we want any input to the I i 18 Commissioners on this proposal we need to include it in the 19 letter we might write as a result of this briefing? ;
20 MR. LIEBERMAN: That's right. I am going to 21 emphasize that this is a pilot approach. I believe it is 22 being applied to nine plants and I expect to learn a lot, we j i
23 all expect to learn a lot during this pilot process to help 24 improve the assessment process and the enforcement process.
i l 25 MR. BARTON: For how long, the pilot program?
1
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j 1 MR. LIEBERMAN: It's a six month pilot program. ;
l /' 2 DR. UHRIG: Then the plants will continue on the i %} 3 normal, present program? '
4 MR. LIEBERMAN: Correct -- so we will have two'
{
5 different groups of enforcement actions, those with the l' l .
i 6 pilot and then the vast majority will be subject to 7 traditional enforcement.
8 DR. UHRIG: And we will still have the SALP l 9 evaluations? i 10 MR. LIEBERMAN: The SALP I think has been !
11 postponed indefinitely but I am not an expert on that. I am 12 not exactly sure of all the details there.
13 'DR. SEALE: I saw a list. I thought it was eight 14 but two plants in each region, is that --
15' MR. BARTON: These will be the same plants as in 16 the assessment process -- i 17 MR. LIEBERMAN: Oh, exactly, yes.
I 18 DR. SEALE: Two in each region.
19 MR. BORCHARDT: In fact, this effort is a subset 20 of that larger --
21 MR. BARTON: The assessment pilot?
22 MR. BORCHARDT: Yes.
23 DR. SEALE: Okay,
'24 MR. LIEBERMAN: That's right, because the first L 25- step of this is assessing the significance which the i
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512
- 1. assessment process is going to'be using. I j' } 2 Now we have another action item from the 3 Commission and,that is to clarify the policy to make it more 4- risk informed, specifically to change'the supplements of the ,
5- enforcement policy.to provide better examples of risk 6- significant violations and we have been working with I
7 .stakeholders in trying to develop different. approaches to do I that and we have considered things like tying the examples
~
8 9 to high-risk systems based on the maintenance rule, some of 10 che changes to 50.72 and what systems are more important ,
1 11 than others, and we are developing that approach. I 12 At the same time we are looking at the new '
13 enforcement approach for the. assessment process and we l 14 decided it is probably inappropriate from a resource point q
()_ 15 of view to go down both-tracks at the same time and if this
~
16 assessment process works, we-won't need to get into the 17 severity levels.
18 We will be using a risk-informed approach and thus 19 we won't need the examples and the supplements, so we intend 20 to propose to the Commission that we not continue with the 21 effort to risk-inform the supplements but'rather use the 22 concepts we have been using -- that is, looking at the 23 safety significance of the particular systems, using 24 guidance from the maintenance rule implementation and other 25 efforts the Agency has done to determine which items are I
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513 1 more risk significant than others as a short term until we-
- q)
['T ~2 make the final decision on where we are going with the l 3 assessment and~ enforcement process, and that would be 4 towards the end of 1999.
5 But we do think that we should clarify the policy l 6 to make it clear that we can both increase and decrease a '
7 . severity level example based on risk. We have been doing l
8 that. You can read the policy as suggesting we only use 9 risk to increase the severity level. We want to make it 10 clear that we can both dacrease and increase the severity 11 level.
12 CHAIRMAN POWERS: When you encounter violations of l 13 the fire protection, how do you go about assessing the ,
j 14 ~ severity of the risk?
() 15 MR. LIEBERMAN: With a lot of discussion. The l 16 guidance we have in the enforcement manual provides that 17 when we look at fire protection or Appendix R type
! 18. . violations, we look at the ability of the plant to reach a l.
19 hot shutdown. If the plant cannot reach hot shutdown with 20 the equipment described in the fire protection plan, and the 21 procedures people have been trained on the fire protection 22 plan, that would be considered Level III.
23 Now more recently as jna have been focusing more on l 24 risk, we started asking ourselves questions like, well, what 25' .other systems are available, what other procedures are ANN RILEY & ASSOCIATES, LTD.
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l 514 1 available people been trained on which may not be n
l ) 2 specifically described in the fire protection plan. If we
%)
3 feel that, notwithstanding the wording in the fire j 4
protection plan, the systems are there and the people 5 prepared to use those procedures and thus you can get to hot 6 shutdown notwithstanding the violation and then that would 7 be considered a Level IV and under the interim enforcement 8 policy a noncited violation.
9 Any other questions?
10 [No response.)
11 MR. LIEBERMAN: That concludes what I was going to 12 say.
13 DR. SEALE: Any burning questions at the moment?
14 [No response.] I
('~h)
- . 15 DR. SEALE: Well, what I am going to do then is, j 16 if you would, Mr. Lieberman, I would like to ask you to 17 stick around, and we are going to hear now from Ms. Ginsberg 18 from NEI, and after she has made her comments, then I would 19 like to ask both of you to be available not only to respond 20 to our questions but to comment, if appropriate, on each 21 other's comments, so Ms. Ginsberg?
22- MS. GINSBERG: Thank you very much for the 23 opportunity to provide you with some industry perspectives 24 on what Mr. Lieberman has just described. In the nature of 25 trying to make this as expedient a process as possible I am l
/ ANN RILEY & ASSOCIATES, LTD.
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l 515 l 1 not going to go though what Jim just did in terms of each
/T 2 and every feature of the proposed enforcement process that j
\_ / ;
3 has just been issued in terms of Level IV and also as part 4 of the pilot program.
5 What I would like to do is just give you our views l
6 about both the process generally as well as some of our 7 perspectives about specific features of what the NRC has 1
8 proposed and is about to propose to the Commission.
9 Jim described to you both the interim policy that 10 has been issued and became effective on March lith as well i
11 as the proposal for the new oversight program. We have ;
l 12 worked very closely in tne stakeholder process to both j 13 understand ano provide our views on these reforms to the l
14 enforcement process and basically are very encouraged by l
() 15 what the NRC has proposed.
16 We believe that most of the revisions will be very 17 effective in re&ching the goals the NRC and other 18 stakeholders had set out. In terms of reform, we think 19 there are very good public policy bases for developing the 20 kind of framework that Jim just described and I would add j 21 that licensees fully understand that these processes don't !
i 22 alleviate them from the requirements of the regulations, 23 that nothing in the changes to the enforcement process have l
24 changed any of the regulatory requirements. Ratller we view 25 this as a different way of handling violations that is more i
(' '
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516 lL : . appropriate based on the maturity of the industry and also
'2 with the' infusion or risk significance.
3' -With respect-to some of the remaining concerns, 4 there were'actually fewer remaining concerns as a result of 5 some of what Jim has told you this morning. In particular, 6 the elimination of the third exception on'the interim policy 7 '- we.believe is if very positive "tep. Obviously, never being j 8' happy with what is, we would encouraga you to eliminate it 9 entirely as opposed to just from the pilot program, but 10 nonetheless we think that is a considerable step forward and 11 appreciate the NRC's willingness to listen to our views.
12 CHAIRMAN POWERS: You'll have to excuse me. I I
13- don't remember the exceptions by number. l l
14 .MS. GINSBERG: Sure. The' third exception,related l
() '15 to repetitive violations found by.the NRC.
16 One of the things that I thcught was important to 17 highlight is the process that the NRC undertook to develop
> 18 . thele'nforcement policy reforms. We.think -- well' in my. ,
19 . experience and it's been more than a decade now,.I have not
- 20. 'seen the process work this well.in terms of' interaction with 21 the Agency, responses from the Agency and from stakeholders, 22 all'of whom have made a very' good _ faith effort to try and 23 develop a process that resulted in meeting the objectives 24'- that'everyone set out.
25 The~ objectives didn't always coincide, but for'the ANN RILEY & ASSOCIATES, LTD.
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yr 517 1- most part the. stakeholder objectives and the NRC objectives
() 2' 3
were coincident, and we think that is extremely -- that was an extremely. positive step forward. ,
^
4 Clearly this was an arms-length process. We did i 5 not always agree with the NRC and certainly the NRC did not 6 always agree with the industry-perspective, but'by airing 7 the varying views we think that they have reached some very :
8 strong bases for making some of the changes that they have.
9 In fact, I guess it is an opportunity to l
10 compliment the Staff's willingness to take criticism and act ,
11 on that criticism and we think that is both a very j 12 productive way to conduct Agency business even though at 13 moments perhaps not the most pleasant.
14 These processes have been implemented in a very
() 15 short period of time when you think about typical Agency 16 action. -The NRC's process -- the enforcement process has 17 more or less been in place for about 30 years and this is a 18 rather-fundamental change and we think that the fact that 19L the Agency is considering-these changes over the period of 20- just months, eight or so months, is a very positive 21 indication.
22 The interim policy -- let me spend a second or two 23' discussing our views about it. We believe it correctly I 24 recognizes the industry's sustained good performance. When 25 industry officials began complaining, their complaints ANN RILEY & ASSOCIATES, LTD. 1 Court Reporters )
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518 l
1 related to the numbers that were, statiutics for 1997 where
/ 2 V) 3 you had approximately 1400 or so Level IV violations out of i a total of about 1500 violations, all of which -- the 1400 4 of which were Level IVs, and we believe that the industry {
- 5. performance did not -- or actually the enforcement process 1
6 did not support the industry performance and we thought a ;
- l change needed to be made. !
l 8 In doing so the NRC has appropriately credited f 9 licensee corrective action programs with the capability to 10 assign priority to and to track the disposition of 11 violations and other issues. Again, we think this is very 12 appropriate and can be supported.
13 Finally, and Jim mentioned this, one of the 14 problems that we identified with the high number of Level rs i
) 15 IVs was the diversion of both NRC but primarily licensee 16 resources to items that were not safety significant, and by 17 doing so our concern was that it took away valuable 18 resources from items that were far more safety significant.
19 As I mentioned, the exception for repetitive 20 violations was an issue that we submitted in our comments I 21 believe that went in yesterday. Jim has already focused on 22 this and as I said before we would encourage the NRC to 23 consider deleting this in its entirety as opposed to just 24 for the pilot programs. ;
1 25 DR. KRESS: Do you have a reason for that? I mean l
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519 1 it seems to me like repetitive violations is an indication
(- 2 3
of something -- I don't know what.
significant or --
Is it not risk r
l t
4 MS. GINSBERG: Well, let's start with the fact !
5 that these are non-safety significant violations.
{
6 DR. KRESS: One at a time they na, slot be, but if ,
7 you have a lot of them -- l 8 MS. GINSBERG: That's right but --
9 CHAIRMAN POWERS: I guess I just don't understand
-10 that, because the definition is that if these are allowed to l 11 continue on, they will constitute a bigger hazard.
12 DR. KRESS: Yes.
13 ' CHAIRMAN POWERS: And repetitive violations would 14 suggest they are being allowed to continue on.
() 15 MS. GINSBERG: I think the industry's position is 16 that'the analysis.o'f the larger number of violations is an ,
1 17 assessment function and that in allowing the assessment 18 process to look at these if necessary, that is a more l l'
19 systematic approach. It is-a broader perspective and it 20 skews the process to just look at these violations even'if 21 there are several Level IVs.
22 CHAIRMAN POWERS: You just lost me totally. I
- 23 have got a violation. I committed it on October. I turned 24 around and did it in November and I did it in December.
I i 25 DR. SEALE: A non-cited violation.
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p 520 1 CHAIRMAN. POWERS: It is a non-cited violation.
(v ) 2 DR. SEALE: Right.
3 CHAIRMAN POWERS: Okay, now why shouldn't I get 4- cited at some point here?
5 MS. GINSBERG: You will be cited but for each 6 individual violation. An NCV will be issued for each 7 violation not for the culmination of three violations.
8 The issue of what is repetitive, what is 9 sufficient. corrective' action -- there are a whole host of 10 subjective issues that we think can be eliminated here, and 11 that are not left unreviewed by the Agency, but rather 12 should be reviewed through the different process of 13 assessment and further inspection if necessary.
14 On the issue of the PIM, one of the concerns that r^%
( ,) 15 the industry has identified is that by using the PIM as a 16 basis for further analysis what you are really doing is 17 using enforcement violations, enforcement actions as an 18 input to assessment, and we think that that is both 19 unnecessary anc contrary to the principles that have been 20 established for the assessment process.
21 The appeal process is not one to which we object.
22 In fact, by contrast we thoroughly support the opportunity 23 for further discussion if there is a dispute regarding a 24 NCV. The only concern that we have is what is that process, 25 how will it function, and that was not described in the l
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l 1 Federal Register notice, so we are encouraging the NRC to lO^%
.2' clarify its process.
3 MR. BARTON: Do you want to explain the second 4 bullet again?
.5 MS. GINSBERG: Sure. The proposal is to use the 6' PIM, the plant issues matrix, as the basis for tracking 7 ; Level IV NCV type violations and our position.is that there i l
8 is no need to do that, that by doing so what you are doing I 9 is eseentially using violations as an input to the 10 assessmentn process rather than letting the assessment j 11 process be driven as opposed allowing enforcement to drive 12 it.
13 CHAIRMAN POWERS: What input am I going to put 14 into the assessment process? It sounds like you would )
'15 restrict me from doing any input?
16 MS. GINSBERG: No. There are a whole host of 17 performance indicators that are going to be looked at --
18 CHAIRMAN POWERS: But you could have the same I 19 objection to those. I mean if I follow this logic, I would 20 have no input at all. You would'say I was double-counting 21- everything.
I 22 MS. GINSBERG: No, no, no, no, no. I think there I
.23 is a systematic approach.that the Agency together with some ;
- 24. of the stakeholders'is trying to establish that does take a !
25 broad look at a variety of~ things in the plants, and to the
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- l' . extent that these issues were part of the inspection process
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2 they would be processed through inspection as well as 3 enforcement if they involve a violation. I 4 DR. SEALE: But the inspection force is the NRC's ,
5 presence-in the plant on a day to day basis and save those j 6 . violations which do result in a notice of violation there ,
7 needs to be some -- or it would. appear appropriate that the ;
8- assessment process-have access to the knowledge, to the l
'9' integrated results.of that day to day presence when the 10 -assessment takes place and that is what I think we are I i
11 talking about here -- the input to the assessment process 12 from the day to day presence in the plant. :
13 MS. GINSBERG: I think we would return again to 14 -the' fact that these are non-safety significant and taht by I
() 15 accumulating them you don't necessarily get a safety 16 'significant' issue, and that if there is some safety l I
17 significant issue it will show up in other ways, not related !
l 18 to specifically necessarily to the combination of let's say l 1
19 these violations which may be described as repetitive 20 depending:on whose image of repetitive you use.
21 More questions?
22 CHAIRMAN POWERS: I'm thoroughly lost.
23 MR. BARTON: Let me try it. Maybe the concern l 24 goes something like this. I have got a component in the 25' plant that I've got a problem with and I end up with o
L ANN RILEY & ASSOCIATES, LTD.
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523 violations against it for some reason, repetitive becuase I
\ 2 can't correct it properly or timely, and that gets counted
! ~ -[d 3 as a hit against me and at the same time I can report this j 4 issue under maybe the maintenance rule reporting or -
5 something. I don't know. I am trying to figure out what j 6 the issue is here. That's the best I can come up with about '
7 whate the industry's concern may be here.
8 DR. MILLER: I don't understand the word ;
9 double-countint ss to what that really means. l 10 - MR. BARTON: You count it in the violation column 11 and you may count it somewheres else in the assessment 12 process. I i
13 MS. GINSBERG: That's exactly -- is it an input to 14 the assessntent process, and if so, for what purpose? If
~s !
7
( ) 15 they are non-safety significant -- we also are going back j l
16 and forth -- pardon me?
17 DR. MILLER: Seems like it's a bookkeeping ,
1 18 problem. .It either comes here or comes there and you are 19 worried about it is going to come both places.
20 MS. GINSBERG: That's one, and the other thing is 21 how is it analyzed. l 22 MR. BARTON: And how does it impact the 23 assessment, plant assessment I think is what they are l 24 worried about.
25 DR. FONTANA: I think you are going to have a real l l
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-1; :public percpetion. problem unless this is expliained very 5 2. clearely.
3 MS. GINSBERG: We think the whole process needs to 14 be explained very. clearly, so we agree with that.
5' Jim has described the proposed approach for the
'6 Reactor Oversight Program and basically'the industry 7- supports this as well. We think that it will effectively
'8- . complement but not duplicate the inspection and assessment
- 9 processes.
10 DR. MILLER: Is that assuming that the things you:
11 brought up on the previous overhead are changed, so'to
-12 speak?
- 13. MS. GINSBERG: No. It's' irrespective of that. We 14 think that further changr;.could be made to the interim
() 15 policy, which.is what we were talking about before, but we 16" think that this is a very solid framework irrespective of l l
.17 that. I 18 We endorse - .we encouraged the NRC to focus on )
I
- 19. the as-found condition and endorse the process that does I 20 that. We think that that is appropriate, not to take a 21 . retrospective look in the context of' enforcement but 22 evaluate the issue based on it is what it is.
23 This process even without civil penalties 24 continues to ensure that licensees will restore compliance 25 and'take the corrective action because with the notice of O ANN RILEY & ASSOCIATES, LTD.
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i 525 l
1 violation you are still required to do that.
-(} 2 3
Finally, we think that this appropriately takes credit for and allows'the enforcement process to work with 4 the'other Agency actions-that are going to be implemented f 5- .through the overall oversight process. l
)
6 In addition, as Jim also identified, we think that ,
l 7 this new process will avoid the diversion of resources that '
I 8 is typically associated with disputing enforcement actions i 9 -where there is a civil' penalty involved. You end up with a 10 situation where licensees feel compelled because of the )
i 11 attendant publicity and other features of the issuance of 12 enforcement aution with civil penalties to argue about that 13 and most of the time it draws the issue out, and what you 14 end up with is not much for all the dispute, so we are
() 15 encouraged to see that this will have the impact we believe 16 of avoiding a lot of that action and force licensees and the i
17 Agency to focus on fixing the item. I 18 Finally, with respect to this new approach we
'19 .think that the imposition Lf civil penalties will be focused 20 on those violations where the issuance of civil penalty is 21 most likely to have a deterrent effect. The industry has 22 had.a long-standing concern about issuing civil penalties 23 with the idea of deterrence for items that are based on a 24 mistake in judgment, for example, where someone would have 25_ no input or.the civil penalty would have no input into the L 10R7 RILEY & ASSOCIATES, LTD.
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It 526 1- decision in the future as it didn't at the time it occurred. ,
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2 DR. SEALE: Could I ask you or Lieberman, either
{
3 one --
4 MS, GINSBERG: Sure. !
5 DR. SEALE: -- has anyone gone through the record 6 of: civil penalties over the last 24 months, let's say, and 7- tried to decide.or assess whether or not or what the change 8 would-be if this policy had been in place at the time?
'9 We have already heard that we are talking.about 85 10 percent reduction in NOVs with the Level IV change. That is :
r 11 one burden reduction, 1
12 Clearly this is another. Has anyone looked at 13 that? ,
14 MR. LIEBERMAN: Yes. We have, and about -- only J
/
( 15 17 percent of the escalated cases, Levels I, II and III, in 16 the last two years would be covered under the traditional 17 approach. We didn't look at how many of those were civil 18 penalty cases and not civil penalty cases. So about 80 I i
19 percent of escalated cases would be covered by this new I 20 process and about, say, 20 percent would be covered by the j 21 ' traditional process based on the last two years.
22 DR. SEALE: I'm sorry. Go ahead.
23 MS. GINSBERG: Okay. Thank you. Overall, as I 24' said at the outset of this presentation, the industry does 25 strongly support the proposed changes to the enforcement I l
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1 policy, both the interim policy and that which will go to '
}-2 the. commission some time later this month.
3 We~are going to'be very interested in the policy's 4 implementation throughout the pilot program. We think that 5 will give us a tremendous amount of information upon which a t
6 firm judgment can be made with real data and so we will be 1
7 monitoring that very closely.
8 Finally, and this ia a point that has been made 9 more than once this morning, we think that it is extremely !
10 important and Jim Lieberman mentioned this in his 11 presentation, that the Agency communicate the bases for l 12 these changes in terms that the public will both understand 13 and that will support the changes that the Agency is making. l 14- We think there are very streng public policy bases j
() 15 for making these changes and that the Agency just has to 16 explain what it has done a'nd why, that this is not a 17 rollback of regulation. It is a fine-tuning or a honing of 18 the enforcement focus and that that does not alleviate I 19 licensees' responsibility from complying with the 20 regulations as they currently exist. j 21 I would be happy to take other questions if there 22 are any.
23 CRAIRMAN POWERS: Let me ask you a question about 24 this business of using risk to either increase or decrease .
l l
25 the severity of the violation. What do you think?
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528 1 MS. GINSBERG: Well, actually, that is already 2 built into the process that the assessment folks are
{
3 developing. Put aside for a moment the changes to the l 4' policy. We believeLthat risk must be considered, should be 5 and must be considered in the process of defining the !
l 6 -significance of an event, whether for enforcement purposes 7_ or for vcher assessment purposes. !
8 CHAIRMAN POWERS: My question really is I am a !
9 plant. You have caught me. It is my risk or is it some 10 generalized notion of risk that used against me?
l 11 MS. GINSBERG: Actually it is both. What the i 12 performance assessment folks have developed in the -- or the l l
13 oversight folks have developed in the context of the I l
14 inspection, what I believe are called inspection matrices, ;
1 f) 15 what is the formal name for IFC? IFC PZ?
16 MR. BORCHARDT: I think that is close enough.
l 17 MS. GINSBERG: Right. What they have developed is J 18 a process by which you take the event, look at its i
- 19. likelihood,-look at the item it is intended to mitigate or 1 20 the event it is intended to mitigate, look at the 21 redundancy, do a whole host of things and you come out with 22 what amounts to a generic risk significance. On top of
' 23 that --
24 CHAIRMAN POWERS: What I am asking is who does the 25_ .looking and with what tool?
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529 1 MS. GINSBERG: The NRC will do the looking in the
( 2 context of processing it through the matrix. My
)
3 understanding is that licensees will similarly be engaging 4 in that process to take a look at what the NRC is going to 5 come out with.
6 What is described as Phase 3 is an opportunity for 7 licensees to come in and if they have plant-specific 8 information, risk information, that would change the generic 9 result, if you will, licensees are going to be afforded that 10 opportunity to customize the risk analysis and we support 11 that.
12 DR. KRESS: Is this CDF core damage frequency you 13 are talking about or is it a set of attributes that relate 14 to that?
(~%
( ,) 15 MS. GINSBERG: Actually I don't know the answer to 16 that specifically. What you are going to end up with is, as 17 a result of the generic analysis, you'll end up with a 1
18 color, if you will, so it is roughly equated to CDF 6, 5, 4 l l
19 and 3, but it is not risk-based as much as :.t is 1 20 risk-informed is my understanding.
21 Jim, I don't know if you want to add to that?
22 MR. LIEBERMAN: Yes. We are focusing on the Delta 23 core damage frequency, whether risk-informed or risk-based.
24 We are going to try to put risk numbers to each finding. It 25 first begins with a relatively coarse screening as Phase I
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530 l:
L 1 and Phase II is a little more sophisticated, and then if we 2 feel comfortable that.it is a risk-significant violation, I
(}
3 believe 10 to the minus 6 or less, then we would dialogue 4' with the licensee to get into more specifics, and then use 5 that information to convert into the white, yellow, red i
6 bands.
7 MS. GINSBERG: Dr. Powers, it is important --
8 CHAIRMAN' POWERS: Let me.ask you more about this, 9 If this is all true except when it comes to fire, 10 and then it is a yes/no -- it's either white or red?
11 MR LIEBERMAN: I believe that in certain areas we 12 are not using all the PRA or using PRA. For those things 13 that PRA fits, we are using PRA but things like emergency 14 planning, safeguards, health physics, aspects of fire
() 15 protection, and I am sure there are some other areas too 16 where the analysis doesn't lend itself to it, there is going 17 to be a system closer to the severity levels, examples of i
18 the severity levels in'the enforcement policy to help guide l
'l 19 us to the color bands.
20 CHAIRMAN POWERS: I guess I don't understand when 21 you'say fire doesn't lend itself to risk assessment. I have l 22 had interminable hours of people discussing fire risk 23 assessment in front of me.
24 MR. LIEBERMAN: Okay. Appreciate that I am now 25 talking in an area that I don't have a lot of expertise ANN RILEY & ASSOCIATES, LTD.
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, 1 and --
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2 MR. BARTON: 'That is dangerous for a lawyer.
3 [ Laughter.] l i
4 MR. LIEBERMAN: Almost anything a lawyer talks 5 about may be dangerous, but seriously the existing PRAS that 6' 'the Agency has, I am not sure how well they model the fire 7 protection issues and probably I am saying more than I know 8 but I do know that there are challenges in the fire 9- protection area and I.am not exactly sure how the Agency has 10 worked that out in the assessment model.
11 DR. KRESS: I would like to return to Dana's '
12 earlier question. You say you will use the PRA where it is 13 applicable. What PRA is that? Plant-specific or just some 14 generic PRA you have or which PRA are we talking about? '
() 15 MR. LIEBERMAN: I think again I have exhausted the 16- knowledge I have in this area because I am relying on NRR to 17 get me the inputs as to the significance of the violations 18 and we-are not -- the Office of Enforcement is not 19 developing the significant levels.
20- MR. BONACA: I have a question on the repetitive 21 violations. It seems to me that if you have a violation, l 22 noncited, on a'given issue now and then you allow for this l
)
23- to go into the corrective action program and now you have a 24 -repetition of that violation, now-the second one -- that
)
25 would be changing the focus, right? That would be a l
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532 1 violation of the corrective action program. I mean you.have :
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2 ineffective corrective action program. Is it, or how will l
- j. 3 it be focused in that? '
4 MR. LIEBERMAN: Okay. Under the -- can I come to
- 5. .the table so I: don't talk to the back of people's heads? )
6~ DR. SEALE: Certainly. '
7 MR. BONACA: I am'trying to understand the --
8: DR. SEALE: 'Why don't you stay there too?.
9 MR. BONACA: Isn't it.true that at this point you ;
10 wouldn't worry anymore.about what the violation was. You
?
11 would worry about the fact that the corrective action 12 program didn't take care of it. j 13 MR. LIEBERMAN: You are correct. There's two 14 focuses -- the individual violation itself, whichever that n'
15 violation is,'and-then the lack of taking effective !
16 corrective action. !
l 17 The lack of taking effective corrective action on 18 a particular violation doesn't necessarily mean the I L19 corrective action program is broken. It may be, you know, 20- on that particular thing, you know, it is.an indication that 21 ~ there is an issue that needs to be addressed.
1 22 In the enforcement policy and how we have l 23 ' implemented it, as violations repeat, at some point the 24 ' significance of an ineffective corrective action becomes the 1
-25 issue and that can become escalated action and under the I l
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.1 existing program we would continue to do that. l
[
2 With this interim program we are focusing on not 3; just that the violation reoccurred. )
l 4 You.have to ask did it reoccur because of i 5' inadequate corrective action. That is a judgment call. The 6 violation occurredi say, November 1st and on November 10th
- 7. Lit repeated. !
8 Well,.was that.enough time to develop the program- )
9 and take the corrective action and.given the safety 10 significance should they have done it the next day or that 11 day or.did-they have more time to deal with that issue? You 12 have to make those judgments. !
1 13 Then if the licensee did identify that particular !
14 issue, that is the strength of the licensee. They are l
() 115 looking_for problems.
16 They found the issue and they put it'back in their 1
17' corrective action program. )
i 18f We are planning to beef up, strengthen-I think it-19 is Manual Chapter 4500, which'is the overview of.the 20- corrective. action program.to'do a greater sampling of not 21 only the licensee's identified issues but issues we have 22 identified which are NCVs and violations to look how the 23 licensee;is' treating those issues and through the assessment l 24- process then it becomes an issue. I
! 25 -
With the.new assessment procese, which is' focusing
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534 1 on a performance-based -- performance and risk-informed, we l'L. )J 2 will tolerate what I will call noise or low level violations 3 recurring. The issue is is there any potential risk 4 consequence to those violations.
5 Ellen mentioned the PIM. I think there is some 6 misunderstanding here. The question is how do we use the 7 PIM. What is the PIM? The PIM is a document that has a one 8 line description of inspection findings, who identified it, 9 and that we use as a tool to look at the inspection reports.
10 You know, we may have a stack of inspection reports several 11 feet high over the time period we are looking at, and this
- 12. PIM summarizes the issues and in the past we have used it to 13 see trends. Are the same type violations repeating over 14 time or is it a procedural violation in safeguards and a t'%
(
.%./
) 15 procedural violation here maybe in maintenance and someplace 16 in the control room. There's no connection there. That is 17 different than if there's seven violations in the control 18 room all dealing with failing to monitor the control boards 19 or whatever.
20 CHAIRMAN POWERS: Then you are double counting, 21 right?
22 MR. LIEBERMAN: No. The counting -- this is just 23 getting us information to help make an assessment. The PIM 24 doesn't drive the Agency action as a separate vehicle. It 25 is getting, it is analyzing information.
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I 535 !
1 Now the results of that information is used on the l
, 2 old system for SALP and in the new system -- of course, how 3 will we use it in the new system? !
4 The way we are going to use it in the new system l 5 is we are basically keeping score. The NCVs and NOVs and 6 other-inspection findings we placed in the PIM. Okay -- j 7 MR. BONACA: I really believe that this is good, j 8 the fact that you have' repeat violations I don't have a 9 problem in having them saying okay, then this should be an 10 NOV because -- okay. I am just concerned about the word l 11 "end" --
"end" was NRC-identified. You said the intent of 12 eliminating a penalty for Level IV was to allow for the 13 corrective action program.to take care of it. Well, this 14 will create a new category in all the licensees' corrective 15 action program, which are the one identified by the NRC
'16 because the end puts a specific weight on that and I am only 17 saying maybe it might be the right thing to do, but I am 18 saying that you are not really completely depending on the 19- corrective action program. There is a special category now, 20 these animals which come in and they are identified by the i 21 NRC --
)
i 22 MR. LIEBERMAN: Exactly, exactly.
23 MS GINSBERG: The industry made that comment. I 24 MR. LIEBERMAN: And the reason for that, and I i
25 think this is important, because we want the licensee's )
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- . +
h 536 1 corrective action program to not only fix problems but to
[~'l G'
2 identify problems, so we don't -- we have so few inspectors 3 compared to the number of employees licensees have that we 4 shouldn't be identifying issues, so this gives another 5 incentive for licensees to identify the issues themselves >
6 and if they do, they avoid the impact of enforcement, and if 7 they do identify it themselves that means their corrective f
8 action program is working, which is a plus, i 9 MR. BONACA: I agree. Just again, I think it is 10 absolutely appropriate that you are giving the corrective 11 action program the time to resolve an issue based on safety 12 significance. Now the point I am making is that so what is 13 the time the licensee has got to fix that problem? A month?
14 Two months?
r m.
() 15 The reason I am asking the question is that if ycu 16 don't put a reasonable time for the corrective action to 17 take place, then you are back to square one. Then they are 18 going to put.it as Level I and fix it in a day and take 19 priority over anything else. Do you see where I am going?
20 I know the verbiage here is very reasonable. The 21 question is how is it going to be --
22 DR. SEALE: -- implemented.
23 MR. BONACA: -- implemented.
24 MS. GINSBERG: And the question is what is 25 repetitive? Is it one -- is it one and the same functional
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537 1 area? Is it several of not following procedures in I 2 different areas?
N_.)T 3 MR. LIEBERMAN: That aspect, Ellen, I think is 4 pretty well covered. It is where -- it is where -- both the 5 corrective action that was developed for the first violation 6 should'have addressed the second violation. Now if the
- 7. first violation is in safeguards and there is a procedural 8 violation.in health. physics, that is apples and oranges and 9 . clearly that wouldn't be a repetitive, but it is a judgment 10 call because what is commensurate with safety for the 11 ~ particular issue is a function of a lot of things.
12 We know we have to monitor that very carefully 13 because they're subject to abuse --
14 MR. BONACA: Just the question I have is the time
() .15 that you will allow for the corrective action program to 16 take effect. That is the only question.
17 MR. LIEBERMAN: I don't have a specific number.
18 It's a rule of reason.
- 19. MR. BARTON: It is based on safety significance of 20 the item.
21 MR. BORCHARDT: What we expect is the licensee to 22 enter the deficiency into their action program and to 23 prioritize it based upon its significance.
24 MR. BARTON: ekay.
- 25. MR. BORCHARDT: That may warrant an immediate I
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F Y 538 1 ' correction-or it may be six' weeks or six months is
'(' k 2' appropriate. The inspection staff will look at that
\_/-
3 determination and have to make a judgment. I mean it is I
4 going to come down to some value judgments being made and i 5 ' accept that six months is okay.
6 ,
If that deficiency is repeated before that six 7 -month period is' completed and before the licensee had 8 completed the corrective actions for it, we would not cite 9 that, even if we identified it.
10 MR. BONACA: See, this discussion is totally l
11 reasonable, but I didn't see it -- I mean I saw a lot of l
- 12 words that implied that but I think that is the central l
13 . point.
14 MR.'BARTON: Provide the guidance to the C
( ,f 15 inspection --
16- MR. BONACA: Yes -- I think insofar as the 17 . guidance it would be appropriate to specify that you are 1
18 depending on the corrective action program and the judgment 119 you are making in the second violation is really on the 20- effectiveness of the corrective action program to act, 21 otherwise my concern is that it won't make any change. I 22 mean the licensees will just keep anything which the NRC 23 identifies as a Level I_and try to fix it in a day because i i
24 they are afraid that -- that kind of thing.
25 MR. BORCHARDT: I think it would be helpful if we ;
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I 539
.1 Lperhaps sent'Mr. Dudley a copy of the enforcement guidance 2 memorandum which discusses this is a lot more detail than a
(
3 one-line slide.
l ?4 DR. SEALE: I think we have it.
-5 -MR. BORCHARDT: And we have it --
l 6 .DR. SEALE: It is in the back of-your folder. I 7- take.it the industry _'does not have access to that?
8 MR. LIEBERMAN: It's (nl the web and we gave a copy
-9 to Ellen this morning.
~10 .DR. SEALE: Oh, okay, but you haven't had a 11 chance --
12 MS. GINSBERG: I haven't had a chance to digest
.13' it.
14 DR. SEALE: You commented with regard to the-15' l appeals. process.
16- MS. GINSBERG: Yes.
17 DR SEALE: And I think that is discussed in I 18_ rather great' detail in there, so that might' obviate your 19 earlier concern.
20 MR. LIEBERMAN: I think we have covered the basics :
i 21 on.the appeal.. process. ~
22' We are.using the same appeal process that we have 12 3 for notices of violations, with non-cited violations. Our 24 instructions to. inspectors that if at'the exit.the licensee j
- 25. disputes'the violation whether it is NCV or not, that is an 9
i 1
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540 1 issue that requires a Division Director to get involved s
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QJ
') 2 with, to provide that oversight, and the issue with the PIM, 3 I don't really see that as a negotiating issue with the new 4 process, with the pilot process.
5 Our action will be driven by the risk of the 6 violations and the PIMs and then if we get into white space 7 where we have to go back and increase our inspection effort 8 or get more diagnostic, then we will be looking at what we 9 found in the past in our inspection reports to help us focus 10 our effort, and the PIM is a tool we use to see what we have 11 found in the past and the concern about repetition we have 12 talked about.
13 DR. SEALE: Any further comments or questions?
14 [No response.)
O.
(,) 15 DR. SEALE: Well, gentlemen, we have managed to 16 fill the time that's been allocated.
17 Any other comments that either of our presenters 18 would like to make?
19 [:No response.]
20 DR. SEALE: I want to thank both of you. This era 21 of unanimity or near-unanimity and cooperation I think is 22 more real than apparent even in the sense that it does 23 appear that a product is coming forward and there is a 24 conscientious effort to evaluate it from both sides before 25 our irrevocable actions are taken and so on, and I want to I ANN RILEY & ASSOCIATES, LTD.
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541 I L
1 compliment:I think the good start.
2 We will probably have a letter.
[} I would like to 3 hear.from my colleaguesLat some point about whatLyou would i-4f like'to have appear.in that.
5' At this point I will turn it back to you, Mr.
6' Chairman. '
)
7- DGt. LIEBERMAN: I would just like to note.that we. !
8 have been. working with NEI as well as:UCS and it.really has 9 .beenLconstructive. .Our ideas'have changed through this 10L discussion process and both NEI as well as the UCS is i 11- ' generally; supportive.of where we are heading. .
l 12 HMS. GINSBERG: I would concur with that.
L 13 - CHAIRMAN POWERS: Thank you. I'think the Staff at 14 the NRC and with the help of the industry needs to be
( ), 15 complimented for the speed with which they have brought a 16 major revolution to'this enforcement process and I certainly 17l have enjoyed .their presentations. They are'always very.
18 educational and spirited.
19 I will recess until 10:15.
- 20 (Recess.) ,
21- CHAIRMAN POWERS: Let's'come back into session.
I 22 DR. SEALE: We dcn't have a quorum yet.
.23 . CHAIRMAN POWERS: Pe.have to sit here quietly --
24 (Laughter.]-
25 .
DR. SEALE: Oh, I don't know. We can' hear your i
Os ' '
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542 1 : teeth grinding.
g
- 2. DR. KRESS: We only need a quorum when we make
-(d).
3 decisions. We' don't need a quorum to start.
4~ CHAIRMAN POWERS: Yes, but we'll use the !
5- discussions as a basis for those decisions so I think I '
6' better have a quorum here.
7 DR. KRESS: That's at your discretion but we don't .
8 really have to.
9 CHAIRMAN POWERS: Because I am going to promptly 10' recuse myself from that and wound us slightly -- if we have 11 a quorum to start the meeting --
i 12 Our next subject is safety evaluation report on
- 13. the topical report regarding tritium production core. l i
14 My understanding is that some work on this has )
("%
q ,) 15 been done at the laboratory where I am employed. I have no .
16 idea what was done but nevertheless that forces me to recuse 17 myself and I am going to do so rather thoroughly and ask Dr.
18 Kress if he will take over chairing the session and pass it h i
19 on.
I 20 MR. SOHINKI: I thought it was Dr. Seale. ,
i 21 CHAIRMAN POWERS: Hang on. He'll do it in just a j 22 second.
23 DR. KRESS: I will promptly take that gavel that
- 24. just got handed to me and turn it over to Dr. Seale for this 25 ' session.
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543 1 DR. SEALE: Okay. This morning we have with us
() 2 3
some representatives of the Department of Energy and of the NRC Staff that's been evaluacing the prcposal on reactor !
I 4 production of tritium for Department of Energy requirementF. j 5 It is my understanding that this is an information {
6 only briefing and that a letter is not requested at this 7 time. The Staff I understand will be sending a letter to ;
8 the Commissioners essentially as I. understand it providing I 4 the status in the context of a safety evaluation report with 10 a negative consent flavor. -That is, if the Commissioners 1
11 have any concerns they are asked to intervene or to make l 12 them known but there is no action as such expected at this 13 time.
l 14 Eventually an application will be required to
() 15 modify any NRC license for a facility that would accept 16 burnable poison rods for tritium production, and it is my 17 understanding that that is exactly the contention under l 18 which most of this process is being done, namely that we l 19 have a kind of kind of burnable poison rod and that is 20 basically what it amounts to, l 21 I understand that all of the safety issues that !
l 22 are believed to be germane to the NRC's side of the process 23 are already being covered. The dividing lines as to where !
24 the fence is that you. throw the product over in order to 25 move it from NRC to DOE or other jurisdictions have already
[~'
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544 1 been defined and so we should be seeing in essence a m
j 2 con.plete picture of what the safety concerns are as far as 3 NRC is concerned.
4 With that, I will introduce our guests from DOE.
5 I will ask you to introduce yourselves and we expect to be 6 through by 11:45 and I guess you have about 40 minutes to 7 make your case.
8 MR. CLAUSEN: Good morning. I cm Max Clausen from 9 the Department of Energy and it is my pleasure to say thanks 10 again for the opportunity to come in and share with you the 11 work that we have been doing over the last few years in 12 preparing to satisfy a national security need for tritium 13 with the use of a burnable poison rod that makes tritium for 14 us in commercial lightwater reactors.
,, \
( ,) 15 The rod was developed over a period of years by 16 us -- by the Department with the support of some of the 17 contractors who you will be hearing from today, specifically 18 Pacific Northwest National Laboratory, Westinghouse, and a 19 little background from Savannah River in the old days but 20 they are sort of out of it today.
21 Today what we intend to so is to break the 22 presentation up as it's structured here. I am going to turn 23 this over in a second to my boss, who is the Program 24 director, Steve Schinki, and then we are going to -- I will 25 come back and talk just a moment more about the scope of the l
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545 1 report.after Steve those of you a quick overview of the 2
( total program and then we.will turn it over to the technical 3 folks to share with you the real contents of what you find 4 in a topical report of which an unclassified version has 5 been made available to you and access to a classified 6 version for those folks who just couldn't stand it without 7 going further into some of the details to find out.
8 I will acknowledge that we have some help in the 9 back -- a couple or three of our folks are classification 10 folks and if we start venturing into an area where we might 11 say'something that is classified, they are going to sort of 112 wave, shout and scream at us to prevent us from revealing 13 secrets here in the public domain, and so we will sort of.
14 once in awhile be looking over in that corner to see if our
() 15' classifiers will let us continue to talk.
16 I presume that the format here is wide open. You 17 can ask questions when you have them. We will try to cover 18 them. If we don't understand exactly what we need to tell 19 you at the time, we will take a note and get the answer back 20 to you.
21 CHAIRMAN POWERS: May I ask you in your outline 22 where-we would find the information on the comp -ibility of 23 the burnable poison rod under accident conditions?
24 MR. CLAUSEN; The discussions of the accidents are
- 25. here. We talk about it both in the core design --
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l 546 1 CHAIRMAN POWERS: You can't leave your microphone.
l
[ 2' When I look in that, for instance, ~ in the core
(-' .
. design and things like that, I don't see discussions of 3 l 4 compatibility of materials. }
- 5. MR. CLAUSEN: Okay, well, I am going to dLfer that ;
6 question to the folks who are actually going to actually do I t
-7 the discussion on the technical work. l 8 CHAIRMAN POWERS: I can be patient.
9 MR. CLAUSEN: In the end we are going to 6 . .4 this I 10 over to the NRC Staff to give you some closings on their !
l 11 safety evaluation report. '
12 Okay -- I am going to turn it over to Steve 13 Sohinki, who is the Program Director at the NRC for this 14 project.
() 15 MR. SOHINKI: Okay. I know you want to get to the 16 technical issues, but I thought it might be useful to spend 17 about five minutes or so just bringing you up to speed on 18 where we are as a programmatic matter.
19 After 10 years of looking at alternatives for 20 tritium production through a course of several Secretaries !
21 at the Department of Energy, Secretary Richardson finally 22 made a decision on December 22nd to use commercial reactors 23 for tritium production. The alternative was a linear 24 accelerator, which he designated as the backup technology.
25 He said in his announcement that TVA's existing ANN RILEY & ASSOCIATES, LTD.
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547 !
l -1 reactors at Watts.Bar and Sequoyah were the preferred l l
() 2 3
facilities for tritium production. The reason he used the term " preferred" at this point was that we are still j
L completing a National Environmental Policy Act process that 4
5 will be complete by April 12th, which is when we are 6 scheduling -- we are currently scheduling a record of 7 decision that we'll make a final decision on on reactors, l 8- but he designated the Watts Bar and Sequoyah reactors as the j i
9 preferred technology for the reasons that are on this '
10 slide -- commercial reactor technology for making tritium ;
11 has been demonstrated over the past several years in a )i 12- number of ways that I won't go into right now, unless you 13 have questions.
14 Obviously the use of existing reactors is going to l
() 15 be the least expensive way to produce tritium. It avoids l
16 the commitment to a major new weapons facility and that has 17 some benefits as was pointed out to us by a number of !
18 non-Governmental organizations with respect to arms 19 ~ reduction. goals because we need not commit to a major new l
20 facility at the same time as we are preaching that further 21 arms reductions are desirable.
22 DR. WALLIS: Is the price set in order to compete 23 with this facility that you are saving, or is it a much 24 lower price? I 25 MR. SOHINKI: The investment cost --
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548 l l' DR. WALLIS: The amount you pay the utilities.for !
i 2 this privil'ege.
3 .MR. SOHINKI: .W e have just completed a letter !
I
- 4 - agreement.with the TennesseeLValley Authority for the 5 irradiation services and what we have agreed.is -- part of i this depends on whether.we are talking about meeting START I equirements or START II requirements if we have a further 8
( trms reduction, but under current requirements it will-cost
-l 9- us in the neighborhood of about $20 million a year to
'10 irradiate these rods in TVA reactors.
11' DR. WALLIS: Which is a lot cheaper than building ,
- 12- your own facility, by orders of magnitude.
13 MR. SOHINKI: Oh, yes.
14- DR. FONTANA: I understand you are getting them at-15 (Qf- cost.
1 16 MR. SCHINKI: Yes. The arrangement with TVA is' '
17 .being'done under.the Economy Act of 1932 which is a statut'e l
18' which governa that the transfer of goods and services' 19 between Federal agencies, and you are right. Under the i 20 Economy Act the term," actual cost" is used, which is ;
21 sometimes misunderstood. It includes both direct and i
22 indirect. costs, 'so that -what we are paying TVA includes l
23 their out-of-pocket-costs plus indirect costs associated j
'24 . with our use of the capital asset.
l 2 5 '. Obviously the use of existing reactors has a great !
l.
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549 1 deal of flexibility with regard to meeting future tritium 2 needs. We pay only for the tritium we need and we don't pay 3 for it when we don't need it, unlike of course the
'4 commitment to a new facility.
5 The.other that the Secretary emphasized in his 6 statement was that TVA has a national security mission in 7 its charter-and has provided national security assistance 8 over the course of the past several decades in a number of 9 ways.
10 MR. SOHINKI: With respect to the need for
'll tritium, the president cigned the document called the 12 nuclear weapons stockpile plan each year, and in that 13 document tells both the Department of Defense and Department 14 of Energy how many weapons and what types of weapons will be 15 in the stockpile for the coming year and for a number of i
'16 years out.
17 The current requirements have not changed since i 18 the last time we spoke to you about a year and a half ago.
l 19 The latest stockpile plan tells the Department that we need ;
i 20 to have a supply of tritium by 2005.
]
21 Now, if the Russians should ratify the Start 2 22 agreement, that date would be pushed out to about 2011, but 23 - the Russians, who were reported to be close to ratifying 24 Start 2, it now appears are not going to be ratifying Start 25 2 any time soon. So for the time being, we're stuck with
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550 1 Start i requirements. If we have to irradiate in about --
) 2 or have tritium in about 2005, we need to start irradiating 3 rods in about 2003.
4 So that's what the first bullet says. We will
- 5 begin delivering-tritium -- actually, the current schedule 6 is slightly~1ater than 2005, and the reasons are somewhat 7 complex, but it comes down to the Congress restricting the 8 Department from implementing the tritium decision, and by 9 implementing, they meant conduct any construction-related 10 activities.
11 So we had a delay in the new extraction facility 12 that_we're designing down at Savannah River, and while we've 13 pulled back some of that lost time, that facility will not '
14 -be up and running, at least on the current schedule, until
() 15 February of 2006. i 16 This is just our -- and I think I may have shown 17 this the last time we appeared before this group, but just !
18 to refresh your recollection, this was our attempt at !
19 depicting the entire system for producing tritium in l
20 commercial reactors, starting at the upper left with the J 21 manufacture of the tritium producing burnable absorber rods.
22 We will be going out with a request for proposals 23' within about the next month or so for a commercial fuel 24 fabricator to fabricate -- assemble first and then later on 25 fabricate these rods for us. ;
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E 551 l 1
i 1 Once the rods are fabricated, they will be I
()
I 2 inserted into fuel assemblies in the same places as a 3 standard burnable absorber rod would be inserted. I think
- 4. .we've been through this and some more discussion will be had 5 about it, but they look the same as burnable absorber rods.
6 They are attached to the baseplate the same way as burnable
]
7 absorber rod, and they're -- they are placed in the same 8 locations.
9 They will be irradiated for the standard operating 10 cycle at Watts Bar and/or Sequoyah, and then, following the 11 irradiation cycle and after the utility. completes its 12 refueling outage, they will be consolidated from off the 13 --taken off the baseplates, consolidated, and then shipped 14 to Savannah River, where we're designing a new extraction
() 15 facility. We've been now through the preliminary design of 16 .that facility. The cost of that facility is about $400 I 17 million.
18 DR. POWERS: When you say consolidated, tell us i
19 exactly what you mean by that.
20 MR. SOHINKI: Yes. They'll be taken -- there's up 21 to 24 of these things cn1 the baseplate. They'll be either !
22 cut off the baseplate or the bolts will be tightened down l 23- and taken off that way. But we haven't come to a conclusion i 24 about exactly how we're going to take them off the baseplate l
25 yet. But there will be 300 of them placed in a container l
i-
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I 552 1 and then placed in the---
.hv:
2 'DR. POWERS: You're not anticipating crushing, 3 squeezing or otherwise damaging'these --
4 .MR. SOHINKI: No , no, no.
l 5 DR. PO.lERS: -- on site. ;
t 6 MR.-SOHINKI: No.
7 DR. POWERS: Okay.
8 MR. SOHINKI: No. And they'll be -- the, rods will ;
9 not be breached until they're in the extraction facility in i
10 the preparation module. ;
11 .After extraction, they will -- the tritium will be 12' sent to the adjacent tritium recycle facility or replacement l
13 tritium facility as we call it down at Savannah River, where I 14 the tritium will be bottled and sent out to the weapons. ;
15- DR. POWERS: Is that a new facility or is that the 16 existing --
17 MR. SOHINKI: That's an existing facility that's 18 been operating for about six years or five, six, years.
19 DR. POWERS: It's the one that's based on the 20 inter-metallic and things like that.
21 MR. SOHINKI: Correct.
22 DR. POWERS: Okay.
23 MR. SOHINKI: I won't spend any real time on the 24 next couple of slides. I just wanted to put it in your 25 packet. This is a project schedule based upon our work O ANN RILEY & ASSOCIATES, LTD.
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553
! 1 breakdown schedule for the project. The diamonds that are 2 on the schedule, numbered diamonds, are milestones for the 3 project which_we report against and which appear in a
-4 document called that stockpile stewardship and management 5 plan that goes to our customer, the Pentagon and the ?
6 Congress, each year. It's updated on an annual basis. I 7' just wanted'to have that_in your packet so you could refer '
?
8 to it. If you have any questions, I'll be glad to answer l 9 _them, but basically, all our major project milestones.
10- DR. SEALE: Ok " . As I see here, the preparation 11 of-the request for the license amendment I guess is t 12 beginning --
13 MR. SOHINKI: This year. -
l 14 DR. SEALE: Yes.
() 15 MR. SOHINKI: Right.
16 DR. SEALE: And about the middle of 2000 is when 17 you would be ready for that particular issue?
18 MR. SOHINKI: Yes. We're hoping that in the 12 to 19 14 month, at the outside, 16 months from now, we'll be 20 submitting or TVA will actually be submitting the license 21 amendment request. I 1
22 DR. POWERS: Are they going to use the Reg Guide 23 1.1744 formalism for doing a risk informed amendment 24 process? l 25 MR. CLAUSEN: The answer is that TVA hasn't made a l
(9
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554 l 1
1 commitment yet to that particular process, but they are !
s
( ) 2' evaluating the way they intend to do it.
\_/ i l
3 We will be working with them on building the )
4 l approach to the licensing, and I believe the risk informed i 5 approach will be considered for some significant portion of j 6 it.
7 MR. SOHINKI: Do you want to add anything?
8 FROM THE AUDIENCE: No. That's fine.
9 MR. SOHINKI: Okay.
10 In any case, that's the end of the remarks that I 11' had, and I'll turn it back over to Max to just tell you i
12 about the scope of the report that you're going to hear i
13 about in more detail. i 14 MR. CLAUSEN: When we came to the point where it j s
( ,)
4 15 was time to figure out what to do to get some sort of NRC 16 endorsement of where we were in a production core use of the 17 burnable absorber rods, we elected to go to the folks who 18 had done this before, i.e. Westinghouse, and ask them to 19 prepare a topical report in the same manner that they would 20 have prepared a topical report if this were a commercial )
21 product to replace another burnable absorber rod.
22 They used the same systematic approach to 23 preparing it and they've used the standard review plan as 24 the ladder against which they did the majority of the 25 evaluation. They've brought to the table a reasonable --
^
( ) ANN RILEY & ASSOCIATES, LTD.
\~/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
555 1 i well, we believe a very thorough review of the technical and l p 1 I
2 regulatory issues that are facing us in the use of this (gv}
3 burnable absorber as opposed to any other burnable absorber l l
4 in that place, recognizing that this absorber brings to the 5 party the fact that over tim, it produces tritium and the 6 tritium has some interesting characteristics to it, i.e., it 7 also decays to helium 3, which has got a cross section of 8 some interest. We've covered all of that kind of 9 information very thoroughly.
10 We did this using a representative plant which was 11 selected because it was probably the plant with the least 12 margin that we could find that Westinghouse was familiar 13 with, and therefore we felt it was safe to use this plant in 14 order to fully bound any other plant that might be used.
(3)
/
15 We wanted to do it in that way because at the time 16 that we started this process, we had not selected or entered 17 into any sort of an agreement whatsoever with any reactor 18 vendor, and so that's where we are.
l 19 The topical report that was provided will be used j 20 as a guide for the folks at TVA to move forward and prepare i
21 their license amendment on the -- and the plant-specific l 22 issues, and that's currently our plan in moving from where 23 we are now to the submittal in next fall. l 24 DR. SEALE: When you said least margin, --
25 =MR. CLAUSEN: Yes.
(3 ANN RILEY & ASSOCIATES, LTD.
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556 i 1 DR. SEALE: -- what were you measuring?
2- MR. CLAUSEN: We're measuring the fact that this '
l[v/')
m I
3 is the highest' power plant in the -- plant and was running i
4 with the -- I guess it's a containment issue that's a l
l 5 limiting issue. They're going to discuss that in detail as ;
6 we go'through the discussion.
1 7 DR. SEALE: Okay. So we're going to make it as 8 hard as we can. I 9 MR. CLAUSEN: Right. We want to show that this 10 thing's safe, and the plant that --
11 DR. SEALE: Okay.
12 MR. CLAUSEN: The technical report addresses 13 again, as I said, the applicable portions of the standard 14 review plan. We looked at all portions of the standard
() 15 review plan, did not -- went through and made a decision 16 about each and every item on the whole standard review plan )
17 list, and either told the staff that -- how it -- why it l
18 didn't apply or if it did apply, why it wasn't of concern.
19 We've used standard licensing criteria. The i i
20 issues from Juoking at the lead test assembly have been l 21 addressed i: this topical report. We looked at the 22 potential for FSAR and tech spec changes as they would have 1
23 to be addressed in this report, in a licensing amendment, I 24 and we also did a significant hazardous evaluation and have 25 come up with our impression that there is a no significant j l
i ANN RILEY & ASSOCIATES, LTD.
O' Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
w 557
<1 hazards response.
[~'l
\J 2 It does not address fabrication or i
3- post-irradiation handling in the spent fuel pool because at '
4 the time that we started it, we did not know which spent i
5 fuel pool. They're all plant specific. And it doesn't i 6 address the processes of consolidation and preparing them 7 for shipping. That'll have to be done in the license 8 amendment for the specific plants.
9 Having survived that discussion, I guess I'm going 10 to' introduce Rick Ankney, who is going to give us the 11 technical stuff, and he's gc.ag to actually demonstrate that 12 he's technically competent using --
13 MR. -)U1KNEY: Don't say that. Now'you put pressure 14 on me, p( ,) 15 DR. SEALE: There's a button you've got to --
16 MR. ANKNEY: There are multiple buttons.
17 DR. SEALE: Yes. Bring your own piano -player up 18 there to hit the keys for you.
19 MR. ANKNEY: Can you hear me now? Is it okay?
20 Okay. Can I have the pointer. 1 i
21 Ar Max mentioned, my name is Rick Ankney. I'm 22 from Westinghouse core engineering. I developed the core 2
.3 designs, .the two core designs that are documented in the 24 ' topical; report. i l
25- I think it was Max or maybe Steve who mentioned, l O ANN RILEY & ASSOCIATES, LTD.
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558 1 you know, one of the first choices that we had to make was f~'\
sJ
- 2 what reference plant are we going to choose for this work?
3 Our objective here was to really maximize tritium ;
4 production, to do a core design where we were producing the 5 maximum amount of tritium that we could. So it made sense 6 to pick a Westinghouse four-loop plant, four loop being the 7 biggest plant that we manufacture. And we picked the 8 17-by-17 fuel lattice because that give us the maximum 9 number of locations for TPBARs. In fact, in a four-loop 10 plant with 17 by 17 fuel, you'll have 33, 144 locations for 11 TPBARs. In fact, one of the core designs that is documented 12 in the report used that number of TPBARs in it.
13 Now, we also chose a high power level, high 14 temperature plant because that's going to be most limiting
/x
! ,) 15 from a safety analysis perspective. The highest power 16 level, four-loop 17 by 17 plant that we have is 35, 65 17 megawatts thermal, and that comes out to a 5.66 kilowatts 18 per foot linear heat rate.
19 These are the coolant temperatures that I've given 20 here, 593 T average and 625 T out. Again, these are at the 21 highest level of the plants of this type that we have.
22 So these factors combined represented a kind of 23 limiting bounding approach with respect to both tritium 24 production and evaluation of the core with respect to key 25 safety parameters.
l
(
()
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Court Reporters i 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 i
559 ,
i 1 Would you put up the next slide, please?
[}
%d 2 Now, we often use burnable absorber rods in our 3 cores. The conventional burnable absorber rod that 4 Westinghouse uses operates using Boron 10, okay. Boron 10 5 absorbs a neutron, you get an alpha particle off. !
6 TPBARs, of course, have a different set of 7 reactions. The primary reaction is this Lithium 6 reaction, 8 it absorbs the neutron and you get the tritium and the alpha {
9 particle.
10 DR. WALLIS: What's the energy of these neutrons?
11 MR. ANKNEY: Oh, all over the place.
12 DR. WALLIS: All over.
13 MR. ANKNEY: This is -- the primary reaction is 14 the thermal absorption.
! I
(Nj 15 DR. WALLIS: Thermal. Okay.
16 MR. ANKNEY: But you do get some fast absorptions '
l 17 too, and we account for that.
18 DR. MILLER: What's the cross section of Lithium 19 6?
20 MR. ANKNEY: It's on the order of a few hundred 21 bars, okay? It's lower than boron. Boron 10 is on the 1 22 order of a few thousand bars.
23' DR. KRESS: And what chemical form is lithium put 24 into burnable -- ;
25 MR. ANKNEY: Lithium illuminate.
[~
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L 560 N '
t j El DR. KRESS: Illuminate.
-I-~c') 2 MR. ANKNEY: Lithium illuminate '
\s,/ - l L 3 So this is the primary reaction, but the tritium, !
4 of course, has a half-life of 12.33-years, and so you get a' 5 decay of tritium into Helium 3. Helium 3 as it turns out is e 6- also a' pretty potent neutron absorber, again on the order of 7 Boron 10, so you need to account.for that, and this is the 8 important reaction there. It's -- you get an absorption 9 reaction where you get the tritium back, and you get a I 10' proton.
11 DR. MILLER: What's the cross section of Helium 3? '
i 12 MR. ANKNEY: It's on the order of a few thousand )
i 13 b a r s ,- t o o'. !
14 DR. MILLER: Oh, it's higher than lithium. l
-( ) 15 MR. ANKNEY: It's higher than lithium, and if I 16~ remember right, it's also a little higher than boron.
I 17 DR. SEALE: They're sort of jazzy detectors you 18- use.
19 MR. ANKNEY: So this -- while you don't make a lot 20 of helium because this half-life is 12 years, you do make 21- some, and it can become important.
22 Now, we've modified our codes, specifically the 23 Phoenix code and the ANC code >-- these are our two work l 1
24 horses for modelling the core -- we've modified these codes 25- to explicitly account for these reactions, so that I'm ,
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'(202) 842-0034 j
561
'l . keeping track of the lithium 6, the tritium, and the helium f)
V
.2 .3 number densities in every part of the core.
3 Next slide.
4- Now, at the beginning of life, if you look at a 5 TPBAR at a conventional Westinghouse burnable absorber, in 6 terms of their reactivity worth, they're fairly comparable.
7 TPBAR is maybe worth a little bit less, but roughly the 8 same.
9 But.there is a difference. Because the 10 conventional burnable absorber, what we call a wet annular 11 burnable absorber at Westinghouse, because it operates on 12 boron 10 and boron 10 has a pretty high cross section,.by 13 'the end of a cycle,'it's just about all gone, okay? It's 14 essentially gone.
() 15 The TPBARs on the other hand, because lithium 6 16 cross.section is a lot lower than boron 10, and also because I 17 the loading of lithium 6 in the TPBAR is pretty high, it 18 doesn't deplete nearly as completely. In fact, if you look
.19 by the end of the cycle, you still have, you know, roughly j 20 half of it there.
21 DR. KRESS: You don't have to enrich the core to 22 compensate for that difference?
23 MR. ANKNEY: That's my next slide.
24 DR. KRESS: Oh, okay. .Sorry.
.25 MR. ANKNEY: That difference in depletion is l
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Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 I
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i
i i
562 !
i i really_what drives the differences in the fuel management '
- - 2 between a conventional core and a tritium production core.
3 'Because_that lithium 6 is still there at the end of the {
]
4 cycle, that's a pretty big reactivity penalty, and so if you ;
1 5' . want to get the same energy out of the cycle, you have to do 6 something to compensate for this, and the way you compensate !
7- for it is you add more feed assemblies in or you use higher l 8 enrichments or both, and that's really what this slide talks 9 about.
10 If you look at a conventional core -- and these i
11 are actually numbers from an actual operating core design -- ,
12 the typical number of feed assemblies might be between like 1
13 84 and 92, something like that. This particular core had 89
)
14 feeds. In a tritium production core, in one of the designs
-( ) 15 that I documented, we used 140 feed assemblies in an 16 ' equilibrium cycle, okay? ,
17 So in a core, there's 193 fuel assemblies, so you 18 see this is a little less than half, and that's considerably 19 more than hc1f.
20 These are the feed fuel enrichments, 52 assemblies j 21 at 4.01, 37 assemblies at 4.2. We often split the 22 enrichments to help shape the power distribution. And you 23 can see the enrichments that we used for the tritium 24 production core. Again, they're higher.
25 The reason for this is that we need more excess l
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I
563
'l- ' reactivity in the core initially _because.at the end of the cycle, those TPBARs'are still going to be there to a large 2
3 extent, and that's a big reactivity. penalty. I 4 So using this kind of fuel management, we're
-5 loading enough reactivity into the core to get the cycle 6 energy out that we'normally want to get, i
7 We use two different kinds of burnable absorbers )
i 8 at Westinghouse. One'is called an integral burnable 1 9 absorber where we wrap boron on the fuel pellet itself. In 10 this particular core design, we used 800 -- 700 fuel rods 11 worth of integral burnable absorber. 'See, we used a lot 12 more in the tritium production core. That's to control the 13 excess reactivity at beginning of life.
14 Discrete burnable absorbers. In this particular
/
()f 15 core design, there.weren't any, but of course we had the 16 TPBARs in the tritium production core, 3344.
17 Cycle energy. This is in roughly an 18-month
-18 ' cycle. We get an 18-month cycle out of this particular core 19 design for the tritium production, and I put on this slide 20 also the number of grams of tritium that we produced, a
-21 little over 2800.
22' A TPBAR in the center of the core will produce 23 roughly one gram of tritium, but we also loaded TPBARs
}
24 around the edge of the core, and because they're in low i l
'25 neutron importance regions, they don't produce a gram. So
,O ANN RILEY & ASSOCIATES, LTD.
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i
-- .. .= .-. .. - . . -. _. . _ - . ~ . .. - - . . .---
13 l 564 1 that's why the average here is a little less than-one gram.
] 2 Next slide.
3 Now,.when we do safety assessments reloaded ~ cores t 4 at Westinghouse,'we use a bounding parameter approach where l 5 we calculate for.the core'really a long list of key safety 6 parameters-and compare those key safety parameters to the ;
7 parameters that were assumed in the reference safety (
I analysis, and if they're within the ranges that are normally 8
{
9 assumed in the reference safety analysis, then we can say 10 that the safety analysis is valid. l 11 We went through the same process with these 12 ' tritium production cores and found that despite the 13 differences in fuel management, that these cores really 14 operate within the ranges of.the key safety parameters that
() 15 we normally see. There's one exception that I'll talk ~about 16 in a minute, but it's really very minor. l 1
17 If you looked at the power distributions and the l 18 -power peaking factors between the conventional core and l
. l 19 these cores, you wouldn't really see much of a difference.
20 They look very much the same, same kinds of peaking factors, 1
21 same sorts of. radial power distributions. There's really 22 nothing remarkable that's different.
23 Reactivity coefficients, things like moderator ;
l 24 coefficients, boron worth, these sorts of things are all l
25 very, very comparable to what we normally see within the 1
t9
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565 l' ranges that we normally assume. !
1 T 2 We did see one exception to this particular 3 plant's key safety parameters, and that had to do with the i 4 Doppler. defect, and it was just slightly out of the range 5 that we normally assume, and it was accommodated within the !
6 safety analysis that we performed. I l
7 DR. MILLER: What kind of changes do you actually i
8 see in those, what percent or -- !
l
-9 MR. ANKNEY: In things like moderator l 1
10 coefficients? 1 1
11: DR. MILLER: Yes. I 12 MR. ANKNEY: It kind of depends on when you look 13 at the cycle. If you look at beginning of life, you might 14 see a fairly big change in the moderator coefficients. The
() 15 moderator coefficients is -- at beginning of life, it might 16 be at minus 9 PCM per degree F. For these cores, it might 17- be in the range of like minus 12, minus 15, something like 18 that, the reason being that the boron is worth less in these i l
19 cores because of the extra burnable absorber that you have,,
20 and the boron is really what drives the moderator 21 coefficient at beginning of life. So beginning of life, 22 you'll see a slightly more negative moderator coefficient.
l
~
- 23 At end of life, when all the boron is gone, you can't 24 distinguish between the moderator coefficient for these i 25l cores and a conventional core. They look very much alike.
I l
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566 i 1, Things'~like boron worths,: boron worths are little 2 2 .more negative -- a'little less negative for these cores
(}
3 =because there's so much other burnable absorber in these i 4 tritium production cores that the soluble boron has a 5_ tougher time competing for neutrons. So you see slightly I
.6_ lower boron worths, you know, maybe one or two PCM per PPM, 7 something like that'. !
8 If you look'at the topical report, there's very' !
9 long comparisons of various reactivity coefficients. ,
10 We looked at.other key. safety parameters, things (
11 like shutdown margins, ejected rod worths throughout peaking ,
12 factors. Again, these were all pretty much within the {
l 13 normally ranges that we see and we accommodate within the
~
14 safety analysis. I
() 15 So in the end, we were able to satisfy all of the 16 same nuclear design bases for these cores that we do for 17 conventional cores.
18 Next slide.
19 Now, these components are a little different, 20 though, than a regular burnable absorber. A regular ;
)
21 burnable absorber, the worth of it always goes down because 22 you're always depleting boron 10. For a TPBAR, though, l
23 because of decay of tritium, okay, you can actually have a j 24 burnable absorber whose reactivity worth goes up, okay, if l 25 you have a long shutdown, and we modelled that, and it's l
l
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i i
l
567 1- discussed in the report, i 2 We took one of'the designs that we did at near end f'/)..
\_ k 3 of life, went through a six-month shutdown, okay, that being ,
4 the longest conceivable shutdown that you would have ;
5 probably end of life without actually going into a 6 refueling. Actually, this is probably double what you would 7 normally see. But anyway, we modelled a six-month shutdown, ,
8 let the tritium decay into helium 3, and then looked to see
- 9. what effect it would have on the core.
i 10 What we noticed was that when we started'the core 11 back up and went to full power, we saw an 80 PPM decrease in 12 'the critical' boron concentration. So that's pretty ;
13 significant, okay, and this is the delta due to the -- now 14 the increase in the helium 3 that you have due to the
() 15 tritium decay. Very small changes in radial power 16 distribution, .though. I mean, these TPBARs are all over the 1 17 core, okay, so if you're raising up the helium 3, you're 18 basically doing it everywhere, so you don't see much of a 19 shift in the power distribution, a little bit of a tilt, but 20 not really very much.
21 The core peaking factors changed hardly at all, l 22 very little, less than about a percent. But you do see a 23' decrease in the cycle energy because you're adding absorber 24 to those TPBARs, and it doesn't burn up immediately, it 25: burns out gradually. So you wind up losing energy from the i
. /^ 4 ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036-(202) 842-0034
568 ,
1 cycle to1the: tune of about ten effective full power days.
2
(~}
\ _- .
So this is an effect that's certainly different !
than a' conventional burnable absorber and that really does
'3 need to be accounted for if you have a long shutdown. [
-Shutdowns of a few days or even a few weeks are probably 5
6 insignificant, but if you get into multiple months, when you l 7 start that core.up, you would see something. You would see 8 something that's different, f 9 DR. POWERS: The shutdown, I mean, when you're i 10 having an unanticipated shutdown and a restart for a brief 11 period of time, neutronically, they can be fairly 12 insignificant. Are.they also operationally insignificant?
13 MR ANKNEY: What do you mean?
- 14 DR. POWERS: I'll tell you a classic case. C
()
-15 reactor goes down, they start restart at the buildup of the 16 helium, changes all of the reactivity margins the operator ,
.17 has to work with.
- 18. MR. ANKNEY: I wouldn't -- for a short shutdown,-I )
i 19 don't think that's an issue, okay, because this is 80 PPM l
20 difference after six months. If you talk about a few days 21 or even a few weeks, this number is going to go down almost 22 proportionally. I mean, it's only going to be, you know, 23 .very, very small amount.
l 24 So it's something that if you had a lengthy 1,
25' shutdown, you'd certainly want to account for. A few days i l
' l l
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. . . . - =- _ - -- ..
1 1
569 l I
L 1 or even a few weeks,-I don't think it-would be necessary to l l
l( 2 do really much.
~3 Our core design codes do model this, though, so )
4 that when the reactor would go back up to power, those l, 5 models could be used to essentially estimate what's the 6 critical boron concentration going to be at restart that 7 would account for this?
i 8 There are other things, of course, that happen )
1 a:
9 when you shutdown, you have neptunium decay, you have other 1
10- things that are going on too that change the isotopics of l 11 the fuel, xenon, samarium, you know, all those things go on. )
12 So, .you know, these sorts of things can be calculated. I ,
1 13 don't think it's going to get significant, though, until you 14 get into the multiple weeks kind of scenario.
(r\.
,/ 15 DR. KRESS: You'd think the xenon would overwhelm 16 it.
17 MR. ANKNEY: Well, certainly-in the short term, 18 xenon -- xenon is a very big reactivity effect, on the order 19 of hundreds of PPM, okay? But xenon goes away after a few 20 days, 21 DR. KRESS: It goes away pretty fast, yes.
22 MR. ANKNEY: After a few days, it's gone. But 23 again, that's the kind of thing you have to account for.
24 DR. KRESS: I was-thinking about the operational
'25 --
I C';
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570 l 1 DR. POWERS: Well, I mean, the experience we've l 2 had is that they' calculate these reactivities versus control
(
3 rod so tightly that small errors cause them to be off, and 4 when they're off, they have to stop and start over again. I 5 mean, operationa) difficulties is what I was worried about.
6 MR. ANKNEY: Well, that's why you have to have a 7 good model that can predict it. You know, if you can !
8 predict it, then you can -- you know where to put your 9 control rods, you know where to put the critical boron )
10 concentration when you go back to power. j l
11 Next slide. J 12 You know, so I guess the bottom line is that we've 1
13 developed these core designs, we looked at the kinds of key j I
14 safety parameters that we normally look at for these reload j 15 cores. We didn't really find anything remarkable in terms 16 of how they would operate. We expect them to operate within )
l 17 the normal bounds that we see for conventional cores. '
18 We expect to meet all the typical nuclear design bases that 19 we normally meet.
20 The fuel management will necessarily change, 21 though, and higher enrichments will be needed and likely 22 more feed assemblies depending on how aggressive you want to 23 be with tritium production.
24 DR. MILLER: From an operational viewpoint, down 25 the line, when you get serious about putting these in, in 4
/~h ANN RILEY & ASSOCIATES, LTD.
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- - . .- - . ~ _ . - - .
. ~ . . - . . . . . - - . . - - . - . . - - . , - . _ . . - - - . . ~ .
571 1- 2003,lt guess, are you going to change the simulator so the 1{) operator is going to be operating the plant with the --
~
2 3' MR. ANKNEY: I think --
4 DR. MILLER: -At least_get operational experience 5 with a plant some of'the new dynamics?
6, MR. ANKNEY: I think probably what you would do is
-- 7
, you would dial:into the simulator the kinds of reactivity 8 coefficients --
9 DR MILLER: Right. That's what I mean.
10 MR. ANKNEY: -- and sorts of things that you would 11 expect to see in this kind of a core, and there are -- I 12 didn't mean to say there aren't any changes. I mean, there 13' are small. changes in the reactivity coefficients that could 14 be put into the simulator to, you know, reflect the kind of
()
'15 - plant behavior that you would expect to see. l 16 DP..-MILLER: Because I would think with that 17 change in moderator temperature feedback, that the operator 18 will see some differences.
19 MR. ANKNEY: And in fact, it kind of goes in-the 20- right direction. I'mean, operators --
21- DR. MILLER: It stabilizes --
22 MR. ANKNEY: -- tend to like negative --
23 DR. MILLER: Oh, yeah.
24 MR. ANKNEY: -- moderator coefficients, obviously.
25 And this tends to make the moderator coefficients at C ANN RILEY & ASSOCIATES, LTD.
Court ReporteIJ
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- s 1
, - . . . , . . n . . _ . . , - m, _e ., ,, .,- - , -, - - . . . -
p L
l 572 1 beginning of life more negat.ive. !
[ 1- 2 DR. MILLER: It stabilizes a number of --
' Kj -
3 MR. ANKNEY: It stabila.!je the core, right.
4 DR. POWERS: Did I understand that you've done the 5 rod injection accident?
i 6' .MP. ANKNEY: I didn't personally, but yes, we -- !
7 what I did was'I calculated the key safety parameters that '
8 go into the rod injection accident, that's right. ,
9 DR. POWERS: I looked and couldn't find it in the j 1
10 topical report. l 11 MR. ANKNEY: Well, it's probabl.y -- I don't I i
12 remenber if there was a discussion in the transient analysis )
13 section. If there wasn't, it was because the key safety I 14 parameters are within the bounds that we normally see. l
() 15 DR. POWERS: Right.
16 MR. ANKNEY: So there was no reason to redo it.
17' DR POWERS: Okay.
18- MR. ANKNEY: That's all I have. I think the next l i
19- speaker is Cheryl Thornhill from PNNL. ],
20 MS. THORNHILL: My name is Cheryl Thornhill, I'm with Pacific Northwest National Laboratory.
1 21 I'm going to l 22 give yuu a brief overview of our lead test assembly program !
23 and a refresher reminder about how the TPBAR itself works, 24 and summarize the design changes that we have made between 25 the lead test assembly design and the design described in l
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g_
i' 573 i
! 1 the production topical report.
l
N '2 PNNL designed'and fabricated 32 of these
!~
l 3 first-of-a-kind full-length tritium-producing burnable 4 absorber rods. We shipped them to the Westinghouse Columbia l 5 facility,.where they were installed on baseplate in groups 6 of eight and installed-in four fuel assemblies that were 7 then shipped with'the balance of the fuel assemblies that 8 Westinghouse was providing to Watts Bar for their fall of 9 1997 outage.
10 We received a license amendment for the lead test 11 assembly program in mid-September, and about a week later, 12 the assemblies with TPBAR actually went into the core, went l 13 critical in mid-October, and we achieved full power by the j 14 end of October of'that year.
() 15 The cycle. ended last month. We hau an exposure of 16 471.5 effective full power days, and this compares with a 17 design maximum of 550. We had a cycle burnup of 18,000, and 18 we took reactor coolant system samples for tritium routinely 19 throughout the. cycle.
l l
.20 Next view (; .aph, please.
,21 DR. KRESS: What are these clad with? Excuse me.
i
'22 MS. THORNHILL: I have a full description of that 23 in just a few minutes. And we will also be passing a figure 24 around.
l' 25 What we learned from our sampling of the coolant i.
h L( /
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574 1 chemistry -- and, by the:way, we began sampling in mid-February the spent fuel storage' pool water as well for
( ) 2 l
3, evidences of tritium -- is that actually the data was very ,
4 consistent with cycle one data. So our conclusions to date ;
5 are -- with the initial analysis is that our TPBARs i 6 essentially have performed just as expected.
7 DR. WALLIS: Excuse me. I think in your written .
8 material you supplied to us, it was mentioned it would have 9 ten system volumes of tritia'ed t effluent per year? Is that .
1 10 what you actually have in this case? '
11 MS. THORNHILL: Ten? I'm sorry? Oh , that's for 12 the production core.
13 DR. WALLIS: Yes, the production core. l 14 MS. THORNHILL: Right. No.
() 15 DR. WALLIS: So this is just a small sample.
16~ MS. THORNHILL: Yes.
17 DR. WALLIS: I'm way ahead of you.
18 MS. THORNHILL: Yes. Right.
19_ DR. WALLIS: I'm sorry.
20 MS. THORNHILL: And they will be talking about 21 those impacts in subsequent presentations.
- 22. DR'. WALLIS: We'll hear about that later.
23 MS. THORNHILL: But we didn't have to worry about 24 that.
25 DR. WALLIS: Right.
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1 1
1 575 l 1 MS. THORNHILL: And the LTAs haven't been removed -
l 2 from the core or the fuel assemblies have been removed from l [N 3 the core, and actually now it's next Saturday, they will be 4 removed from the host fuel assemblies. We'll have 5 representatives from the Department of Energy, Tennessee 6 Valley Authority and PNNL present to do what limited visual 7~ exams can be accomplished in that environment before the i i
8 LTAs are inserted in storage arrays to be shipped off-site. ]
9 Next slide.
10 DR. KRESS: Please, before you leave that, could 11 you go back and tell me what that first bullet means. I 12 MS. THORNHILL: What it means is that we didn't 13 see any unusual trends with the cycle 2 data compared with 14 cycle 1 data. Obviously there were differences because they I
( )- 15 had different chemistry that was going on, so there --
16 DR. KRESS: Cycle 2 was one with the --
17 MS. THORNHILL: With the TPBARs, yes. ,
18 DR. KRESS: Yes. And the cycle 1 had one.
19 MS. THORNHlL1- Had none, that's correct.
20 DR. KRESS: And you're saying trends were the same 21 in terms of the quantity of tritium in the coolant?
22 MS. THORNHILL: Right, in the fluctuations that 23 occurred throughout the cycle. But again, you know, the 24 chemistry isn't the same, so they're not a direct 25 one-for-one comparison.
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7, 576 l' DR. WALLIS: So you'didn't get a measure of the
( 2' effect;of using these' bars on the tritium in'the coolant 3 which--Nould.them be-extrapolated in order-to answer the question I was prematurely asking?
~
4 Didn't get-data on how
- 5. much extra. tritium you would get in the coolant water,:which 6 --
7 .MS. THORNHILL:
Right, but we never expected to 8 get.that with the lead test assembly program because -.
9 DR.'WALLIS: Because you didn't have enough.
101 MS. THORNHILL: Just not enough rods, and even 11 with our design maximum permeation rate, we would not have
.12 been able to make those conclusions. We would have only 13 been able to make a conclusion if we had something that 14 exceeded significantly the design permeation rates.
() 15 DR. WALLIS: So it didn't help you to verify a 16 prediction? I see.
17 MS. THORNHILL: Not to exact numbers, that is 18- true.
19- DR. KRESS: Do you have a model '. hat predicts the 20 : permeation rate?
21- MS. THORNHILL: Yes, we do. That is a very 22 important component of our TPBAR design model.
23 DR. KRESS: Does.that-come out of the old tritium 24 production data at. Savannah River? I mean the validation of 25 :that model.
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I 577 ,
1 MS. THORNHILL: We're venturing into that l
2- touchy-feely area here on -- those models are classified.
-3 DR. KRESS: Oh, I'm sorry.
4 MS. THORNHILL: -- and the data that supports the 5 models are classified.
i 6 This program obviously is based on the previous '
7 work. We're allowed to say that. But we also have work-8 going on in the current program that gives us the database 9 that we use.
10 DR. SEALE: Are there discussions of that in the t 11 classified report that's available?
12 MS. THORNHILL: I -- do we get into the permeation )
13 models in the classified part, the actual design models?
14 MR. CLAUSEN: Yes.
'15 MS. THORNHILL: Okay.
16 MR. CLAUSEN: Yes, we do.
17 MS. THORNHILL: Okay. Yes.
18 DR. SEALE: Tom, we may want to take a look at 19 that at your leisure.
20 MS. THORNHILL: Okay.
21 In early July, the first of the shipments will be ,
i 22- made from Watts Bar. We're going to put one array at a time l 23 in a cask for shipments to Idaho where we're going to --
24 ;we're planning to do'some. confirmatory tests. We want to do
-25 some non-destructive evaluations. As indicated here, we're ANN RILEY & ASSOCIATES, LTD. I C<\ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
I 1
578 1- going to ask the folks at Argonne to section a couple of I 2 rods and send some of those pieces back to PNNL for some
(}
- 3 confirmatory destructive examinations. I 4 Next slide, please, Max.
5 DR. NALLIS: I think you just sniffed for tritium.
6 Did you sniff for helium 3 or something like that, anything 7 else you could have --
8 MS. THORNHILL: No. We've only been monitoring 9 for tritium, and then, of course, whatever data they 10 routinely get.
11 TMt. POWERS: When you say visual and photography 12 on your PTA, are you going to do metallography?
13 MS. THORNHILL: We do metallography on the 14 destructive side. That is a capability that we have at
- (O). 15 PNNL.
16 Okay. While we're talking a little bit more 17 specific about the TPBAR, I want to pass around'our -- this 18 is actually an UCNE version of the rod. There are some 1
19 components within the rod that themselves are classified.
l 20 We didn't bring those today. But this is the 3-D model, l 21 then we have a photograph or a viewgraph presentation as 22 well.
23 But'our primary design principles, as you have 24 'already been told two or three times today, is to mimic to ;
25 the extent practicable the standard Westinghouse burnable L .
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579 1 absorber rods. We have the same. exterior dimensions as the fs
()
i I 2 standard burnable absorber rods. We have neutronic 3 characteristics that are similar. It's just that we use the 4 lithium illuminate for absorber instead of the boron 10. [
5 We also want to minimize the impact on reactor 1 6 operations. We used an upper end plug that had standard l
-7 Westinghouse threads, so that they made it readily to their l 8
- .tandard end plugs for insertion into the fuel assemblies.
i 9 Then obviously our goal is to prcduce and retain 10 tritium, and we accomp ' ish that through' the unique design 11 features of the TPBAR. The TPBAR is a series of concentric 11 2 circles, for lack of a better description, and our second 13 innermost circle is our lithium illuminate pellets. They're 14 solid -- they're annular pellets. And as the tritium is I) 15 production according to the reactions that Rick showed you a 16 few viewgraphs back, it diffuses out of the lithium 17 illuminate and as it is released in an oxide form, we have a 11 8 nice hot metal surface here with what we call our liners, 19 zircaloy liner, for cracking that form of the tritium so 20 that we have molecular tritium. And then the liner also 21' provides structural support and prevents shifting of 22 _ materials during radiation and handling.
23 The molecular tritium diffuses through the nickel 24 . plating. The nickel plating is on our getter-only to 25 prevent with surface from getting oxidized and inhibiting g)
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580
- 1- continued gettering -- 1
- .i I I '/ 2 DR. WALLIS: So the tritium oxidizes, it steals l b l
- 3. oxygen from the illuminate; is that --
4 MS. THORNHILL: That is the primary release ,
5 mechanism.
6 DR. WALLIS: .There's quite'a lot of potential 7 . chemistry.
8 DR. SEALE: Yes, sir.
. . i 9 MS. THORNHILL: The primary release that we've :
10 seen is either T20 or THO, okay? And so this surface gets 11 oxidized to give us the molecular tritium, diffuses through -
12 the nickel plating and then is captured as a solid metal 13 tritide on the zircaloy material that's under the nickel 14 plating.
()
15 Then in order to preclude any tritium leaking into 16 the. coolant, we use a 316 stainless steel cladding that has 17 a barrier on the inside diameter, an aluminide barrier, and ;
18 the combination of maintaining a very low tritium partial !
19 pressure by the very effective action of this getter and 1 20' this aluminide coating prevents permeation of the tritium 21 into the coolant. The barrier also performs the secondary 22 function of preventing hydrogen from diffusing, permeating 23 through the stainless steel and competing with the tritium 24 for the available gettering capacity of our getter.
25 DR. POWERS: When you say an aluminide coat, is
(
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581 1 that a nickel aluminide or --
f~'y 2 MS. THORNHILL: It's aluminide.
%/ ;
3 DR. POWERS: It's aluminide. Aluminide means 4 there's got to be something else there.
5 MS. THORNHILL: That's our classified component.
6 [ Laughter.] '
7 MS. THORNHILL: That is our classified component, 8 this is our class'ified' component. We can tell you a lot 9' about the pellets.
10 DR. POWERS: Unfortunately, that's not where the i 11 compatibility problem lies.
12 MS. THORNHILL: I know.
13 Final viewgraph next, please.
l 14 I know many of you were introduced to the TPBAR
\ p.
(, 15- during the LTA process. We did make a few design changes.
16 To facilitate core design with a full complement 17 of TPBARs, e'JU curront designer friends at Westinghouse 18 asked us to come up with a partial length absorber column.
19 We have -- our components, the getter, the pellet,.
20 the liner,-are fabricated as what we call pencils in 21 basically. twelve-inch lengths, and then they're stacked 22 'inside of the cladding.
- 23. For the LTA, we had. twelve of those pencils. For 24 the production design and the production topical report, we 25 took one of those pencils and made it essentially a spacer f'/
)
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l l 582 1 pencil sc that we could accommodate the partial length. But l
.() 2 3
our goals for tritium production didn't change.
had a design maximum goal.
We still And that, for several other 4 reasons, we' increased the lithium enrichment slightly to i
5 achieve production objectives.
6 Then finally, we modified the end plug weld merely 7 based on our lessons learned from fabricating the LTA to 8 facilitate future automated welding of TPBARs. j i 9 Now Mike Travis is going to. introduce us to some l
10 of the key safety evaluations. i 11 DR. POWERS: Can you tell me some about the 12- microstructure on the lithium illuminate? '
' 13 ' MS. THORNHILL: Microstructure on lithium 14 illuminate?
15 MR. TRAVIS: What are you looking for? It's a ]
16 ceramic -- my name is Michael Travis. I'm a manager of the )
I 17 program at Westinghouse Electric.
18 DR. POWERS: Grain size, inner-granular porosity, 19 things like that.
20 MR. TRAVIS: Bruce, why don't you --
21 MR. REED: Hello. My name is Bruce Reed, target 22.. design at the Laboratory.
23 We have a -- the theoretical density is greater 24 than_94 percent in the lithium illuminate, so there really 25- is very little open porosity in the pellet material. -It's
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1 583 l
1' closed porosity. i t 2 DR. KRESS: Is it centered?
[~'/
s_ - 1 3 MR. REED: .Yes. l 4 DR. POWERS: What kind of grain sizes .ck) you 5' -achieve? 1 6 MR. REED: I guess I'd have to get back to you -l 7 with'a response on that. I don't recall off the top of my- l
)
8 . head.
9 DR. POWERS: Thank you.
10 MR. TRAVIS: Okay. You asked about the -- before j i
11 I begin -- about the rod-injection accident, whether it was- )
)
12 analyzed. It is analyzed, it's in the report, section -- on l 13- page 2-330. In the unclassified version, there's a lengthy-l 14 --
q ) 15' DR. POWERS: I just didn't find it. That was not 16 to say it.wasn't there; I just -- I'm probably running out 17: .of gas,around --
18 MR. TRAVIS: Okay. As I mentioned before, I'm I 19- manager of the program at Westinghouse Electric to generate l 20' -the topical report, and I'm presenting work that wac done by l 21 others, so bear with me here.
22 The first discussion is the loss of coolant 23 accident analyses. It was performed with a code that was 24' called LOCTAJR. It was a modification of a code to add a l
25 one-dimensional model to analyze the heat transfer in and l
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l 584 1 out of the TPBAR which sit in the guide thimbles.
() 2 The assumptions that were made was that there were 3 negligible flow'during a LOCA accident through the thimble 4 -- guide thimble, too, that there was a zirc water reaction 5 on EOD-of the surface but none on the inside. And we were 6 looking for maximizing the temperatures of the TPBARs to see 7 what would happen there.
8 We used post-LOCA heat transfer, heat generation i 9 in the TPBARs, and we used the regular LOCA temperatures, 10 either the small-break LOCA or the large-break LOCA, as 11 input to LOCTAJR in order to get those temperatures.
12 Next slide.
13 The small break LOCA was our standard analysis of 14 record, is the input, and I think you will recognize some of
()
l 15 these codes, the NOTRUMP and SBLOCA codes. The large-break 16 LOCA was the same way. It uses the SATAN / BASH /LOCBART code 17 input. And the methodology could be adapted to our 18 Westinghouse best-estimate LOCA analysis methodology that we 19 have available.
20 Next slide.
21 We find that the TPBAR cladding tracked the 22 adjacent fuel. rod cladding. It lagged a little bit behind 23 the adjacent fuel. For the small-break LOCA, we did not 24 predict that cladding would burst in the TPBAR. The i 25 temperatures were sufficiently low.
l l
l 's/
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l 1
585 j t
1 We considered the effects of blockage and swelling l
- [
'( _')-
2 of the TPBARs, but we determined that the presence of the 3 TPBARs had no effect on adjacent fuel for the small-break I l
4 LOCA. )
5 DR. POWERS: Did you get an inner-metallic l 1
6 reaction between the nickel getter and the zirconium? )
7 MR. TRAVIS: The temperatures during the i
8 small-break LOCA were too low to get there, but the l 9 large-break LOCA temperatures were higher. i 10 Next slide.
11 We did get -- again, we found for the large-break 12 LOCA that TPBAR tracked the adjacent fuel rod cladding i 13 temperature. The potential burst effects were negligible 14 because we did predict the TPBAR would fail. But we also r-(3) ,
15 were predicting that the adjacent fuel would also have 16 failed during this event prior to the failure of the TPBARs.
17 You asked about inner-metallic reactions. We 18 generated a fairly significant report on that issue that is 19 classified and I can't talk about here. We summarized it in 20 the classified version of the topical report. It's on 21 section 3.7, 3.8. But basically, we found in summary that 22 the energetics from the inner-metallic reactions were 23 sufficiently small that they did not need to be considered 24 in the loss of ccslant accident.
25 A summary here was that the presence of the TPBARs I '
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586 1 had an insignificant effect on the adjacent fuel.
[~'l G'
2 I'm going to move on to the vessel integrity.
3 Again, this was done by others, analysis of the vessel 4 integrity was done at the Energy Center. We found a one 5 percent increase in the vessel fluence due to the fact that 6 we had a higher leakage core. Rick described the core 7 design, he was trying to maximize the tritium production.
8 Consequently to get those -- the power in the periphery of 9 the core to make some tritium out there, he had to increase 10 the fluence out there.
11 For the plant, the reference plant, we found all 12 to be well with the vessel fluence. There was no impact.
13 But the second bullet up here is cautionary, that there-may 14 be an impact if you pick a plant with a -- it's close to (g) 15 their screening criteria, the PTS screening criteria, if 16 it's operating.with little margin during heat up and cool 17 down, if the plant's on the border of upper shelf energy or 18 if there's high nickel cooper content in the beltline 19 materials.
20 DR , KRESS: Watts Bar has none of them.
21 MR. TRAVIS: Watts bar has cooper. Pardon me?
22 DR. KRESS: But it's not near the screening 23 criteria for upper shelf or -- it hasn't operated very long.
24 MR. TRAVIS: But you have to project out to its 25 design lifetime, and that's an issue that will need to be I)' ANN RILEY & ASSOCIATES, LTD.
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587 1 addressed in the license amendment for Watts Bar.
[~\-
.V
- 2. DR. KRESS: Oh, so you're projecting these.all the 3- :way to the end of life.
4 MR. TRAVIS: Right. Oh, yes. Yes. Currently, 5 today, there's not an. issue, but what we're saying is to get 6 .to'thei. you know, 40-year lifetime of the plants, you're 7 going to have to address these along the way.
8 MR. ANKNEY: There are ways to design the core to 9 reduce leakage so that this isn't an issue.
10 MR.'TRAVIS: Yes.
11 DR. MILLER: That would be the same way we've done ,
12 it in the past.
13 MR. ANKNEY: Low leakage loading patterns. .
14 MR. TRAVIS: Right.
() 15 .DR. UHRIG: You say there's cooper in the Watts 16 Bar vessel?
17 MR. TRAVIS: Yes, there is some concern with the 18 cooper in the welds, the beltline material in Watts Bar.
19 And.that will have to be addressed in the license amendment.
20 I'm going to -- the next presenter is Jim Sejvar.
21 MR. SEJVAR: Okay I was involved in the --
- 22. -looking at the radiol ogical consequences and impacts on the 23 reference plant with use of TPBARs. We looked at it from 2'4 - both the standpoint of normal plant operation as well as 25 accident scenarios.
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588 1 As was mentioned earlier, the purpose or the 2 things are designed to maintain -- retain the tritium, but
[w )/
l 3 to be prudent, we did assume this design permeation release 4 of one curie per year for average TPBAR.
5 DR. WALLIS: Now, is that -- that's an assumption.
6 It must be based on something.
7 MR. SEJVAR: It was provided to us by PNNL.
8 DR. WALLIS: It's based on some evidence, some 9 data or experiment?
10 DR. SEALE: I think that was the model I was 11 asking about and it's classified.
12 MR. SEJVAR: That's exactly right, and --
13 DR. WALLIS: So it was not just picked out of the 14 air.
(% 15 MR. SEJVAR:
( ) No , no. It was supplied to us by 16 people that know. I frankly don't know the permeation rate. ;
17 DR. WALLIS: So it's a best estimate rather than 18 an assumption, you're saying?
19 MR. TRAVIS: Excuse me. The model that predicts l
20 the tritium permeation leakage is classified and the number 21 is classified.
22 DR. WALLIS: I just want to know it's got a good 23 pedigree and it's not just picked out of the air.
l 24 MR. TRAVIS: No. No. It's been very, very well l
i 25 investigated in much depth.
l
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I I
589 1 DR. WALLIS: It's not classified because it's
() 2 wrong; it's classified for other reasons.
3 MR. TRAVIS: No. No.
4 [ Laughter.]
5 DR. KRESS: His other question was, this one curie i
6 per year, is that a best estimate or is it a conservative J 7 value that's well above the model prediction?
8 Mr TRAVIS: No comment. ,
1
- 9. [ Laughter.] )
10_ MR. SEJVAR: The other assumption that we made was 11 failure of two TPBARs with that inventory release fuel ;
12 coolant as sort of a bounding assumption.
13 DR. KRESS: Let me ask you about the first bullet.
14 The only change you calculate would be the effect on the
(( ) 15 inventory of the different enrichment. That's the only 16 effect'these bars have?
l 17 -MR. SEJVAR: Yes. We evaluated all the source
.18 . terms, our design basis source terms of fission products and 19 coolants, so it's a -- there are some changes in the 20 enrichments and burnups, so that affects the source terms 1
21 that we would normally design to, but the changes are small.
22 The other --
23 DR. KRESS: The title of this is normal plant :
24 operations. This doesn't count accidents; this is just 25 normal operations.
('( _'
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590 i
1 MR. SEJVAR: The last slide addresses accident (y
r v
j 2 scenarios.
3 So we did, in fact, calculate -- recalculate the 4 accident source terms through the fission products based on l
5 the differences in the core designs as well as the l
6 additional tritium load, and that's what we're talking about 7 here. As far as the additional tritium load, because there l
8 is tritium generated in the plants today, we took these two ;
9 sets of assumptions, this one as being sort of a design 10 basis, as we do with one percent defective fuel, and the 11 other is as an abnormal situation.
12 DR. FONTANA: You picked two bars as failure 13 because if you fail oae, you'll probably shut the plant 14 down?
/h
'( ) 15 MR. SEJVAR: No.
16 DR. FONTANA: No. You just picked it.
17 MR. SEJVAR: Again, that was an input to me, and I 18 think it was based on --
19 MR. TRAVIS: Excuse me, Jim. We picked two 20 failures and it's documented in the topical report in 23 section 2 --
I'm sorry -- 3.7. But we looked at the 22 statistics for failures of the Westinghouse burnable 23 absorber assemblies, burnable absorber pins, and we 24 concluded that the most likely prediction was one, but we 25 decided that wasn't fair, so we used 2 in the report in
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j
!. 591 i
l l 1 order to cover it. But the number of failures in burnable 1 !
() 2~
3
. absorber rods.is extremely low.
DR. KRESS: This is failures under-normal '
l-I 4 operation.
{
5 MR. TRAVIS: Any -- yes, mostly normal operation, ,
6 '
.but,.yes,lany plant operation.
7 DR. KRESS: When the tritium gets into the water, 8 it pretty much' stays there, doesn't it? !
9 MR. SEJVAR: Right.
l' 10- MR. TRAVIS: Well, yes, except Jim will tell you l
11 what he's going to do with"that here in a minute. i 12 DR. KRESS: Oh , okay, t
13 MR. SEJVAR: Okay. So based on these assumptions, '
1 14 we looked at various waste management aspects of this
() 15- additional load with the premise that we have tritium in our 16 current reactors to the tune of about 900 curies per year.
17' Experience has shown, especially with Maine Yankee, they had 18 stainless cladding,fthat this can build up and impact your 19 plant operation because of an increased exposure due to the '
'20
~
tritium to the plant workers, and the practice has been is 21 dilution and discharge. .You;have to dilute to reduce the 22' boron 'anyhow,-- so there is an enhanced discharge and 23 ~ dilution. .Sollong as you're well below the limiting 24 concentrations, that that's a reasonable and practical way 25 'of. managing the problem.
i .
l_ ,
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- _ .. - . -. _- .._. .-..-..-- ~. - ..
i 592 ,
i 1 In terms of.the impact, we'll talk about that in a !
[\_')l 2 minute. There's additional surveillance required. There is i
\
3 an additional solid waste inventory of about one resin bed l 4 that estimated could impact the plant'in that regard.
5 Next slide. f i
6 DR. KRESS: Did you evaluate a potential steam I 7 generator tube rupture accident with-that 20,000 curies?
8 MR. SEJVAR: That's addressed in chapter 15 or the !
i 9 accident analysis stuff, right. j 10 DR. POWERS: If we have two TPBAR failures per (
11 core, that represents, what, six times ten to the minus l l
12 four, the error probability? Am I right on that? Human l
I 13 error rates are -- it must be a very good quality control j 14 process associated with these.
( 15 MR. SEJVAR: Again, the error probability --
16 you're talking about basically a basis for the two --
17 DR. POWERS: Yes.
18 MR. SEJVAR: -- ruptured rods, and I think it's 19 based on --
j 20 DR. POWERS: I mean, you've used as a comparison 21 existing burnable rods, which presume there's a great deal 22 of experience in manufacturing. This is a new thing, and so 23 you're counting on an equivalent failure rate -- seems to me 24 that's not quite reasonable.
25 MR. TRAVIS: I would like to disagree. We went --
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i 593 !
1 the failure rate for our commercial burnable absorber rods i
() 2 3
is based on infant mortality from the very early days,.and we only saw two burnable absorber rods fail out of all the !
4! ones we built. So it's not --
it's consistent with the
- 5 Westinghouse experience.with burnable absorbers.
6 DR. POWERS: Yes, but what I'm asking is that you 7 have a brand new manufacturing process that we were told 8 just minutes ago was -- you're putting out a request for l 9 proposal. A new manufacturer is going to do this thing. l 10 You really think that his rate is going to be the same as
.f 11 the error rate that we have with something that we've built ,
12 literally thousands of? l 13 MR. TRAVIS: Well, I can't speak for other l 14 manufacturers. I can speak for Westinghouse. If we built !
y () 15 'them, we believe that they'll have that failure rate.
16 [ Laughter.) l 17 MR. CLAUSEN: At this point, our request for 1
18- proposal 1 process is still immature, but we are requiring l 19 that the folks who qualify to bid already have in place
- 20 experience lin fabricating similar components and a 10 CFR 21 -Appendix B program. So we're not anticipating that anybody 22 would be qualified for an award who would not already have 23- that kind of experience, and I suspect that in their 24 advertising, they would come along with the same story that 25 Mr. Travis just gave us.
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l-594 1 DR. POWERS: .I'm sure that they will be
[ 2_ enthusiastic about their capabilities. I'm a little more
(
3 interested in what the reality will turn out to be.
4' MR. SEJVARi Okay. So with dilution and discharge 5 -is a method of control for the' buildup of the tritium.
6 There's going to be some increased number of batch releases 7 because each release is monitored-before it's released, so 8 there's an increase sample frequency.
9 Those r"e basically the major impacts on the plant 10 operation. Thert s facilities in place and the labs have to 11~ monitor tritium -- for tritium currently, so this is --
12 there's more of an additional load on that operation, 13 operational aspect.
-14 Experience has shown, as I mentioned earlier, that
() .15 if you run around two to four microcuries per gram in the 16 . coolant, you generally get into controls of the 17 concentration just to avoid worker over-exposure or 18 additional exposure and reduce worker efficiency because of 19 additional protective measures that you must impose on the 20 workers, like plastics and respirators and SCBA gear.
21 So given that, we looked at the impact of reducing 22 or of discharging with additional tritium via the plant 23 effluent pathways, and even with this failure of two TPBAR, 24 which amounts to about 20,000 curies, we see that it's a j
25 relatively small increase in the off-site doses. In fact, i l
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595 1 less than ten percent of the off-site dose calculation 2 manual and plant tech spec limits, which are about three (f
3 millirem per year for liquid pathways. J 4 In fact, with the one curie per year design value, 5 this went from a nominal one percent of the total off-site i i
6 dose to about two percent, so it's a small contributor l l
7 basically to the off-site dose burden. ;
1 8 In terms of airborne limits, the tritium ties up j 9 with -- as tritiated water, so there's a relatively small i
10 impact or much, much less of an impact on the airborne 11 effluent pathway.
12 DR. POWERS: Explain that to me just a little bit.
13 The tritium ties up with water which makes it more 14 hazardous, and that reduces its airborne, or is it because j
()
-s 15 the tritium ties up with water, there's just less of it in I 16 the atmosphere?
17 MR. SEJVAR: Yes. What I was -- since tritium 18 exists primarily as tritiated water, the only airborne 19 effluence as opposed to a noble gas release would be --
20 DR. POWERS: So you're saying that it's just lower 21 concentration, so it contributes less.
22 MR. SEJVAR: That's right. And even though it's a 23 twelve-year half-life, it has a twelve-day biological 24 half-life, and so it's probably one of the more less l l
- 25. hazardous isotopes that we have in the plants.
I 1
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596 1 DR. FONTANA: Going back to your previous slide,
(} 2 would failure of one of the rods exceed that two to four 3 microcuries per gram tritium concentration? The second 4 bullet, first sub-bullet. Right there.
5 MR. SEJVAR: If you had a failure, instantaneous 6 failure -- if you had a failure of two rods, and we address ,
7 this in.the. report, if you had this burst or influx of 8, 20,000 curies into the reactor coolant system, yes, indeed, 9 it would go up to like 90 microcuries per gram.
10 On.the other hand, you could -- if you had the 11 capacity and the ability to dilute and discharge that, you 12 could dilute and discharge it in a couple of days without l 13 exceeding the limit.
I 14 DR. WALLIS: You would need quite a lot of water
[)
v 15 to dilute, wouldn't you?
16 .MR . SEJVAR: Well, the coolant volume is.about l 17 60 , 70,000 gallons, so -- and you need a feed process to do 18 that.
19 DR. WALLIS: And this would have to be treated 20 water and all that, so it wouldn't just.be any old water.
21 MR. SEJVAR: Just non-tritiated water, basically.
22 DR. WALLIS: It would also be treated so it could 23 go through the primary circuit. 1 24 MR. SEJVAR: Right.
25 In terms of accident scenarios that we're
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l l
597 1 analyzing, and this includes basically all the accidents in l
[}
V 2 chapter 15, the only accident having a substantial release 3 of tritium to the environment was a large-break LOCA. There 1 4 is no significant off-site thyroid or whole-body dose 5 impact. ,
i 6 The only major concern we came up with this 7 particular reference in this case that the discussion on i 8 bounding applies I guess because that particular plant had a 9 high leak rate of recirculating sump water going through our 10 auxiliary building to the tune of like one GMP versus -- or 11 actually it's two GPM versus most plants, which are about a 12 gallon per hour. So consequently, this gave us a high dose 13 in the control room from the tritium from a thyroid dose.
14 In terms of other impacts on accident situations, T) 15 the equipment qualification dose, in that case, it's mostly 16 a small impact because of the lower burnups. I 17 We looked at the hydrogen buildup inside of 18 containment after an accident and we took into account the 19 zirc water reaction from the zirc that's included in TPBAR 20 design, and as well as assuming that all of the inventory in 21 .all the TPBARs existed as hydrogen gas, which is very 22 . conservative, and that gave us about 600 standard cubic feet 23 of additional hydrogen inventory in the containment 24 atmosphere after an accident, and if you look at the Reg i
25 Guide 1.7 limit of four percent, four volume percent, that i
[\3
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% +
598 i 1 amounts to about. 6 percent of the total hydrogen volume
'that' equates to that concentration.
\ 2 1 LJ 3 .So I' guess my conclusions are that the increased.
i g4 discharges allow the exposure and ALARA goals to be met in 5 the: current; plants. The current plants currently discharge
.6- tritium'and maintain it at about one-or two microcuries per )
7 gram. Continuation of this practice can. exist without a ;
i 8- major impact .cn1 the operation, primarily in the sampling and I l'
9 discharge frequency, and the accident dose impact is
- 10 : primarily impact on the control room dose, and this is ---
11- this is primarily due to the assumption that this particular ;
- 12 reference . plant has in the .high number of -- the l'igh number j 113 ~ associated with the sump leakage into the primary --
14' LDR. WALLIS: It doesn't say anything about the
~
'15 'increase in~the spent-fuel pool temperature. Is someone 16 going to address that?
17 -MR. SEJVAR: I haven't addressed that myself, and 18 --
19 MR. TRAVIS: We hadn't planned to talk about that, 20 but if you want, if you have a specific question, we'll try i 21 to answer it.
22; IMt. WALLIS: It just seems to be fairly large, and 23 'so I made a note of it and-thoughtlE would ask the question 24 aboutfit.
'25 MR, TRAVIS: Yes. Well, the reason it went up was i-O~ ANN RILEY & ASSOCIATES, LTD.
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599 l 1 because there was -- we were .ischarging a lot of fuel
() 2 3.
during each cycle.
DR. WALLIS:
It wasn't the TPBARs because they're --
Right. It was just the cycle was 4 shorter.
5 MR. TRAVIS: Right. It wasn't a shorter cycle; it 6 was just so many more fuel assemblies.
7 MR. SEJVAR: We're feeding 140 assemblies, so --
8 every cycle, so you're discharging --
l 9 DR. WALLIS: Right.
10 MR. SEJVAR: -- that many.
11 DR. WALLIS: So you were putting a larger load on l 12 the fuel coolant system and so on and so forth, and 13 presumably the consequences of that were examined?
14 MR. TRAVIS: Right. Yes. And the temperatures
() 15 were whatever they worked out to be with the heat load.
16 MR. SEJVAR: Okay. I guess it's -- Sandra Andre 17 is going to talk about the conclusions here.
13 DR. SEALE: Ms. Andre, I'm not going to criticize 19 the speakers because I think we've all been very interested 20 and so on, but I will point out to everyone that we're 21 beginning to chew into our time and I think we should all 22 bear that in mind.
23 MS. ANDRE: Okay. Just a point on the spent fuel 24 pool, we're not really talking about it here because it's a 25 very plant-specific thing.
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1 600 l
1 Is this on? Okay.
2 The spent fuel pool is so very plant-specific that
[~
N. ]
l 3 it's really being left for the LAR and it'll have to be 4 addressed there, and in the interest of time, we're going to 5 kind of skip over the FMEA discussion. Suffice it to say l
6 that we did do a fairly detailed failure modes and effects 7 analysis to support our conclusions here, and Max, you can 8 just skip to the significant hazards.
9 Two major things in our conclusions section -- one 1
10 was our significant hazards consideration, and the second 11 was table 4.1, which was sort of a road map for the 12 plant-specific LARs.
13 The first question in the significant hazards was 14 the probability of a previously evaluated accident and in (f'N
,) 15 all the safety analysis and evaluations in the report 16 support our conclusion that there is nothing that is going 17 to increase the probability of any initiators to any of the 18 accidents.
19 DR. POWERS: I haven't looked at the particular 20 FSAR for this representative plant that you've selected or 21 bounding plant that you've selected, but FSARs typically 22 don't have elaborate analyses of the probability --
23 MS. ANDRE: That's right.
l 24 DR. POWERS: -- of accidents. And so now, you've L 25 gone through and evaluated the probabilities of those h)
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.1 accidents? j
/' N
'\_,l- 2 MS. ANDRE: We did not do a quantitative 3 probability analysis, no.
4 HDR . POWERS: And so how is it you know that it's no significant increase in the probability?
~
5 r
i 6 MS. ANDRE: We've looked at the various systems ]i 7 and components which could -- which are initiators for the l 8 accidents, and we -- the evaluations in the report show that !
9 there.-- none of these components and systems are really 10 impacted by the presence cf the TPBAR bars; therefore, we 11 made this qualitative conclusion on probability.
.1L2 DR. WALLIS: You have increased security? It !
13 would seem to me if there's publicity about this plant and 14 .its function, it might be more attractive to certain -- !
.A
'( ) 15 DR. POWERS: Or that would decrease the amount of [
16 maintenance because it's more difficult to do. I 17 DR. WALLIS: There are a few other consequences I
~18 besides the usual --
l 19 MS. ANDRE: Yes. We were --
20 DR. WALLIS: And presumably that's been looked as 21 well?
22 MS. ANDRE: We didn't address security in this 23 report. -I presume that will be done elsewhere on a 24 plant-specific' basis.
25 DR. WALLIS: It might involve greater cost or l
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(G 602 1 _ greater attention?
! D '2 MS.. ANDRE: Uh-huh.
3.
s f l 13 On the second part of that question, on the ;
t t
4 consequences, as Jim explained, we did look at the ;
5 radiological consequences of the accidents. We found no l
6 . adverse impact on the off-site thyroid, a slight increase on 7 .the off-site:whole body' doses.due to the core loading 8 patterns, and the control room dose increases,.which we 9 think can be maintained with a more typical recirculation I 10 leakage. ;
11 Okay. And does it create the possibility of a new 12 or different kind of accident? We looked at what are the !
13 differences from our normal burnable poison rods to the 14 TPBAR. The first is that the TPBAR obviously contain some O( ,j 15' materials which aren't in the burnable poisons.
I 16 We developed a matrix of materials and their i 17 potential interactions, which is in the classified topical 18 report and is supported, as Mike indicated, by a GRBE 19 report, which is also classified.
20- Another different is the helium 3 buildup during 21 shutdown, and as Rick discussed, we evaluated that scenario 22 !
and found it to be benign as far as safety analysis goes.
'23 Another different is the TPBAR have to be removed ,
i 24 from'the assembly, packaged and shipped, but that activity j
\
25 is'outside of the scope of this report, so it's not :
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P 603 l p 1 addressed here. !
l h 2' In those first few slides that we skipped over, we l N~s!'
3 did the failure modes and effects analysis and we did find !
i 4 five potential failure modes which could impact the ability j l 5 of the TPBAR to perform their safety function. All of those 6 basically' involve multiple failures of misloading acsemblies 7 or misloading pencils, and they're'all mitigated by 8 administrative controls and they are detectable by our '
l 9 normal tech spec surveillances.
l
- 10 We concluded that the TPBARs don't alter any of 11 the sequence of any of the accidents that we look at.
12 DR. SEALE: You made the comment earlier that you i
'13 don't consider the things associated with the disassembly of !
14 the --
l f3 .
() 15 MS. ANDRE: Right.
16 DR. SEALE: -- elements or something, but I would E17 have to say, until you get out of site, if you will, or 18 remote,'that at some point, you're going to have to talk 19 about the interaction of that process with the emergency l 20 planning process at least --
21 MS. ANDRE: Right.
~
22 DR. SEALE: -- for the plant site, and I recognize 1
- 23 that's probably down'the road. i 24 MS ANDRE
- Right.
25: MR. CLAUSEN: I believe that that's clearly in the l 'I ANN RILEY & ASSOCIATES, LTD. l L [hm/ Court Reporters j
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604 1 plan for what we intend to look at when we do the license J) 2' amendment preparation.
3 DR. SEALE: I understand.
4 MS. ANDRE: And finally, doesn't involve a 5 significant reduction in margin of safety. And based on 6 Rick's presentation that most of the key safety analysis 7 parameters are within the normal bounds with the exception 8 of the negative Doppler, which he. talked about, and the 9 safety analysis results in the report have shown that those 10 -- that they are virtually unaffected.
11 As I said, table 4.1 provides a road map for a 12 plant-specific license application, and we determined that
- 13. most of the items or many of the items can -- will only 14 require a confirming check to show that the input
() His assumptions haven't changed design -- or input parameters 16 haven't really changed.
17 There are some identified as requiring a 18 plant-specific analysis. Obviously the core design spent 19 fuel pool, some of those type things are identified in 20 there.
21 With that, we'll turn it over to Jim Wilson.
22 MR. WILSON: It's quite obvious from the 23 preparation -- the presentations we've had this morning that 24 our colleagues at DOE and National Lab have been very busy 25 over the past few years.. NRC staff has been looking at this
{
['-
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I 605 1 tritium production proposal since late 1995. We entered
[) 2' into a memorandum of understanding with the Department of i ~-
' 3' Energy in the spring of 1996, and we committed to provide 4 review and consultation with respect to DOE's program for l
5' the commercial lightwater production of tritium.
6 We acknowledged in the MOU that there were issues ;
7 associated with the civilian commercial reactors for 8 purposes associated with the weapons program, and we clearly 9 demarcated a line between our responsibilities to do a 10 safety' review to make sure that this could be done safely 11 and the policy issues were left to' DOE to pound through the 12 legislative wickets and to get approval for the program.
13~ In October of '96, staff laid out its proposed 14 process for reviewing DOE's program. We anticipated, indeed (I 15 they did submit-a topical report which we then reviewed, 16 avaluated, and issued as a NUREG, NUREG 1607, in May of '97. l l
17 DOE this last August submitted a production topical report )
18 as prepared by Westinghouse. Now the staff has been !
19 reviewing that submittal and has prepared a safety !
l 20 evaluation that we're going to be transmitting to the 21 3 Commission next week.
N 22 We provided an early copy. In fact, it was so i
23 preliminary it had not been sent through the technical j 24 editor,_ hadn't received OGC review. We stamped " draft" at L 25 the top and bottom of every page to make sure that you l
1 i
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i 606 L 1- realized this was not the staff's normal finished product.
l I( )
2 -So'that's.what you had before you.
. 3 Yesterday, I met with the subcommittee chairman 4 and provided him with a more up to date copy that was ;
5 current as of about noon yesterday, and we expect to have a !
6 final version ready early next week, and then it will go up 7 to the Commission as a negative consent, which means that we 8- expect to issue it by about the end of the month.
9 In the December 10th SRM, the staff received f
10 approval from the Commission to implement its proposed 11 . review program that I have just outlined. It additionally 12 provided for a series of public meetings to allow the public 13 to become informed and to provide comments.
14 We've had two of those series, a first one back in i
(\) 15 February of '97. It was a programmatic public meeting. The 16 second meeting was at Watts Bar in the summer of '97 17 immediately preceding the insertion of the LTAs into the 18 core at Watts Bar.
19 A third series of meetings is going to be held at '
20 any particular host facility -- in this case, Watts Bar and 21- Sequoyah -- prior to putting those -- the TPC into the core 22 and beginning irradiation. We expect that would happen 23' sometime in 2002, maybe early 2003.
24 Westinghouse has -- and the National Lab have 25 described the topical report to you in some detail. This
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1 briefly runs through the staff's interaction with the l UO 2 topical report. As.you can see, it was submitted last i
3 summer, we reviewed it this fall and submitted RAIs, which 4 DOE responded to.
5 Fairly recently, about a month ago, DOE submitted 6 Rev 1 to the topical report. It revised the topical report 7 to respond to the staff's RAIs and produce additional a information the staff needed in its review. Copies were j 9 provided to the ACRS in'mid February. And the staff has 10 been reviewing the topical report since you said the reactor 11 -- Advisory Committee on Reactor Safeguards a preliminary 12 draft which you've been reviewing.
13 As I said before, the SER is in final NRR and OGC 14 concurrence. We expect it to go to EDO later today and to q 15 the Commission next Monday.
16 We're not requesting that ACRS issue a letter on i
17 this. You all will get an opportunity to look at this, the 18 actual implementation of.the tritium program at the reactor 19 facilities when they come in for their license amendments.
20 We plan to issue the SER at the end of the month 21 as a NUREG, NUREG 1640. Section 5 of that NUREG summarizes ;
22 the staff's conclusions. The staff was able to conclude 23 that many technical issues related to the use of TPBARs and 24 ' commercial lightwater ree.ctors have been satisfactorily 25 addressed in the topical report, and it was a document that ANN RILEY & ASSOCIATES, LTD.
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l 1 was suitable for referencing by individual plant licensees. l
! ['/}
x-2 The staff identified several -- this is on the 1
1 3 order of about.16 -- plant-specific interface issues for l
l l l 1
4 which a licensee will have to provide additional information l 5 and analyses in support of a plant-specific amendment to the j 6 facility operating 1.icense for authorization to operate a 7 TPC.
B We also identified or confirmed the areas that i 9 Westinghouse identified where we would need a handful -- on 10 the order of four -- tech spec changes to support the 1
11 license amendment.
12 DR. MILLER: A question on your second bullet. If !
13 indeed this goes to either Sequoyah or Watts Bar, are those 14 issues virtually the same, then, the issues you point out O)
( 15 that are plant-specific?
16 MR. WILSON: The issues are very plant-specific. .
I 17 Some of them have to do with containment design, which is l 18 the same for both plants. They're small ice condenser 19 plants. Others are plant-specific with regard to EP l
20 procedures and the spent fuel handling area.
21 I'm not very familiar with the extent to which the 22 two plants would require different analyses for the 23 different auxiliary systems that were identified as 24 interface issues. Maybe one of the TVA representatives 25 could address that. We would expect to see it as part of C)
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1 the license. amendment package. It would have to be complete l (c,) 2 for each plant, and to the extent that the staff could take L) 3 advantage of the design similarities, I suppose they would 4 achieve some efficiency that way. But individual packages 5 will have to stand on their own outside of the topical 6 report.
7 The last two pages are just summarizing key dates, 8 and they've been alluded to before. I don't have any !
9 further -- anything further.
10 DR. SEALE: Any questicas?
1 11 (No response.]
12 DR. SEALE: I want to express our appreciation to 13 both the DOE and NRC and Westinghouse -- yes, sir?
14 MR. SOHINKI: Yes, Dr. Seale. There was one point !
C\
() 15 I thought might be worth making because I think we may have 26 left some people with a misimpression with respect to the 17 number of assemblies --
18 DR. SEALE: Yes. !
19 MR. SOHINK: -- in the core.
20 Obviously Westinghouse analyzed a conservative 21 case in which you would have a substantial --
22 DR. SEALE: Sure.
23 MR. SOHINK: -- number of additional assemblies in 24 a reload beyond what you would usually have. Our normal 25 mode of operation, tentative mode of operation given the
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t l
1 610 L 1 requirements for tritium at the current time, and even
'( ) 2 projected future requirements, would be that you would never 3 have to have additional fuel assemblies in a reload beyond 4 - what you would normally see. That's dictated by the number 5 of rods you use in a core, and if yca fully pack the core, ;
6 you would have a substantial amount of additional 7 assemblies. But we don't intend to ever have to do that. :
I 8 DR. SEALE: Those are questions certainly that I 9 we'll probably want to look into in more detail when we talk i 10 about a specific application.
l 11 The other comment I would make is that the l 12 Commission and its staff as a whole are in the midst of a l 13 migratory process toward risk-informed regulation, and we've i
14 never gone through an application for a license modification (G,) 15 of this magr'tude in the environment of a more risk-informed 16 regulatory process.
i 17 Whether or not that will require a difference in 18 approach is something we ought to be sensitive to. It may 19 be that the Commissioners may want to make some overall l
20 judgment on whether or not that's necessary. We don't know.
21 But I think it's important that the applicant -- there you 22 go -- and the staff continue to negotiate and to try to 23 flesh that issue out so that there are no unpleasant 24 surprises for anyone as we get closer to the time when an 25 actual application will be considered.
I
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1 l
i 611 1 Just a personal warning of where I might see a l
' [~i 2 bump'in the road or two. l
\ss/ -
.3 Does.any one of my colleagues have any further j 4 comments to make? l 5 [No response.] -
~6 DR. SEALE: Hearing none, Mr. Chairman, I'll turn 7 it back to you.
8 DR. POWERS: Thank you again. It's always very 9 informative presentations that both the staff and DOE have J 10 put together here, and documentation is voluminous. Now we i 1
11 learn we have to plow through the classified report as well, i 12 and we probably will.
13 With that, I will recess until one o' clock.
14 [Whereupon, the reported session of the meeting 15 was concluded.)
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REPORTER'S CERTIFICATE This is to certify that the attached proceedings fm i before the United States Nuclear Regulatory Commission in
%J the matter of:
NAME OF PROCEEDING: MEETING: 460TH ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) l I
1 CASE NUMBER:
1 PLACE OF PROCEEDING: Rockville, MD i
were held as herein appears, and that this is the original (O _,) transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to I I
typewriting by me or under the direction of the court l l
reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. !
O
\ /$] VW MJonHundley'r -
Official Reporter Ann Riley & Associates, Ltd.
l l
~
x_).
I l
I I
1 Tritium Production m
Commercial Light Water Reactors I )
Tritium Prod"ction Core Topical Report Prese2ation to the ACRS March 12,1999 i
O O O AGEXDA Tritium Production Core Topical Report i I
CLWR Tritium Program Status DOE Scope of the Topical Report DOE TPC Core Design W l
Summary of TPBAR Technology PNSL Results of Key Safety Evaluations W i
Conclusions of the Topical Report W Closing Remarks NRC 1 2 !
Tritium Production in Commercial Light Water Reactors Stephen M. Sohinki Director Commercial Light Water Reactor Project Office ;
L .S. Department of Energy i
O O O /
Commercial Light Water Reactors (CLWR)
Selected as Primary Tritium Source upf Defense (%grums Secretary of Energy Richardson announced his decision December 22,1998, selecting the use of existing reactors ;
to become the primary tritium source technology.
- Use of Tennessee Valley Authority's (TVA) Watts Bar and Sequoyah reactors preferred, pending completion of site-specific EIS.
- Secretary stated Watts Bar/Sequoyah is the best option for national security:
Proven technology Best deal for taxpayers Flexibility to meet present and future needs TVA has statutory national security mission 4
O O O h CLWR Project Overview Ofice offkfcnse 1%~ grams >
New tritium is needed by about FY 2005 to support current requirements for the nuclear weapons .
stockpile and 5-year reserve.
The Commercial Light Water Reactor (CLWR) ;
Tritium Project, selected as the primary tritium supply technology, will:
- Begin producing the first batch of tritium by placing tritium-producing burnable absorber rods (TPBARs) in the Watts Bar reactor during its scheduled outage in September 2003.
- Begin delivering tritium gas to the stockpile when the new Tritium Extraction Facility (TEF) becomes operational and processes the first batch of rods around, February 2006.
O O O System for Producing Tritium in 9 Commercial Light Water Reactors e
o r cc e cn ,,,c e, ,. .,,,
New Manufacture Facility Extract D! ! Transport W:
+ x L . .;;
L i . p -
i 54.
Recycle -
o lh s.
q ,,.,
4 t
.u i irradiate Assemble 6
Existing Facilities
O O O h CLWR Project Schedule FY 1996 1997 1998 1999 2000 2001 otnce nfnerac n.emms 2002 2003 2004 2005 2006 Target Technology E $7 Post-Irradiation Exam (PIE) of ATR Rods -
Laboratory Confirmatory Testing .
Lead Test Assembly Design y Lead Test Assembly irradiation 1 %M Lead Test Assembly FIE %hm Target Fabrication Lead Test Assembly Fabrication Production Rod Manufacturing E
Reactor Acquisition Prepare and Issue Draft & Final RFP Receive and Evaluate Proposals b IE Y
Conclude Interagency Agreement Prepare Request for License Amendment YY E Preparation for Irradiation b First Production Irradiation Cycle }bk Statutory and Regulatory NRC Review of Lead Test Assembly (LTA)
NRC Review License Amendment Requests y .
I NRC Approval of License Amendment (s) g
~nered EIS for Reactor Selection V i EIS for Tritium Extraction Facility 1 -
Tritium Extraction Facility (TEF)
TEF Conceptual / Preliminary Design TEF Detailed Design
%b TEF Site Preparation B TEF Construction N mm TEF Startup and Operations Img >
Initial Operational Capability - First Gas
O O O
$ CLWRProjectMilestones Milestone OJRcc ofDcfsme nngsams Date
- 1. Submit Lead Test Assembly Topical Report to NRC. / IQ/FY97
- 2. Issue draft request for proposals to nuclear utilities. / 2Q/FY97
- 3. Insert lead test assemblies in an operating reactor. / 4Q/FY97
- 4. Critical Decision-2a, approval of baseline and permission to begin design of Tritium Extraction Facility (TEF). / 4Q/FY97
- 5. Prepare Tritium-Producing Burnable Absorber Rod Topical Report. / 3Q/FY98
- 6. Submit report on the CLWR option to support the primary path decision. / 3Q/FY98
- 7. Award options contracts to purchase reactor or irradiation services 2Q/FY99 ;
- 8. Complete tiered environmental ir.: pact statement and record of decision for TEF 2Q/FY99
- 9. Complete tiered environmental impact statement and RODfor CLWR Option 2Q/FY99
- 10. Critical Decision-2b, permission to begin detailed design of the TEF 3Q/FY99
- 11. Document laboratory examinations of absorber rods irradiated in ATR 4Q/FY99
- 12. Irradiated lead test assemblies delivered to examination facility. 4Q/FY99
- 13. Critical Decision-3a, permission to begin construction of the TEF. IQ/FY00
- 14. Begin site preparation for the TEF. IQ/FYOO
- 15. Begin detailed design of the TEF structure and systems. IQ/FY00
- 16. Submit documents to initiate NRC license amendment process. 2Q/FY00
- 17. Award contract for commercial TPBAR manufacturing services. 2Q/FY00
- 18. Award contract for long-term transportation of TPBARs. 2Q/FY00
- 19. Begin assembly of production TPBAR components 2Q/FY02
- 20. Host reactor NRC operating license amended. IQ/FYO3
- 21. Begin irradiation of production TPBARs. 4Q/FY03
- 22. Completion ofirradiation of the first batch of TPBARs. 2Q/FY05
- 23. Critical Decision-4, begin operation of the TEF. 8 lQ/FYO6
- 24. Extraction of the first increment of tritium gas. 2Q/FYO6
O O O -
- h Tritium Production Core Topical Report Ofice ofDefense negrams Scope
- - Tritium Production Core (TPC) Topical Report ,
provides information for NRC review of:
- Technicalissues Regulatory issues
- Representative plant
- TPC to be used as reference for individual plant license amendment requests.
O O O Scope of the TPC Topical Report The topical report addresses
- Applicable sections of the SRP
- Licensing / design criteria for the TP. BARS
- Issues from the LTA licensing
- Potential FSAR and Tech Spec Changes -
- No Significant Hazards Consideration Evaluation The Topical Report does not address TPBAR fabrication, post-irradiation handling, consolidation, or shipping of TPBARs 10
- _ _ _ _ . _ - _ _ ._ __ __ _______ ________ ________ -_ -_______--___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - ___- I
o o o Tritium Production Core Design Richard D. Ankney Westinghouse Electric Co.
i
o o o .
g Choice of Reference Plant 01tice ofDefense negrams i Representative 4-Loop Westinghouse Plant with 17x17 Fuel Lattice
- Large core maximizes tritium production
- 3344 available TPBAR locations High power, high temperature operating conditions
- 3565 MWth core power,5.67 average kW/ft
- 593 F Tavg and 625 F Tout
O O O h TPBARNuclearReactions Office
- of Defn>nse 1% grams Primary nuclear reactions are:
3 Li' + n -+ ,T + 2He* + 4.84 Me7 ,
u 3 12.33 frr2 3 T He +
> 2 2 He + n -+ ,T'+,H' + C.761de V l.
Modified Westinghouse core design codes explicitly model these reactions throughout the core.
i
__f
O O O e
i Fractional Depletion of TPBAR and Wet Annular Bumable Absorber (WABA) ofrec oincreme rn>;: rams 1-9 0.9 0.8
, 0.7 5 '
50.6 a
E -+- TPBAR ;
- 0 .5
-m WABA
$ ~
Q o 0.4 E 0.3 0.2 0.1 0 ,
O 5000 10000 15000 20000 25000 Cycle Burnup (MWDfMTU) i
O O O I
h Tritium Production Core Fuel Management Ollice ofDefense Prcgrams C o n y en tio n a1 T ritiu m C o re P ro d u c tio n C o re '
N um ber of Feed 89 140 Fuel A ssem blies Feed Fuel 52 @ 4.01 112 @ 4.74 E n rich m en ts 37 @ 4.20 28 @ 4.30 (w /o U -2 3 5 ) i Integral Fuel 8704 11328 B u rn able A bsorbers !
D isc re te B- u rn ab le 0 3344 TPB A Rs A b so rb ers -
C ycle E nergy 476 494 :
__(E F P D )
T ritiu m N /A 2805 gram s P ro d u c tio n
0 0 0 Key Safety Parameter Assessment Office of Defensc 1% grants Power distributions and power peaking factors within limits and comparable to conventional cores.
R.eactivity coefficients and kinetics parameters within normal ranges (least negative Doppler defect single exception).
All other key safety parameters (e.g., shutdown margins) within normal ranges.
All nuclear design bases are satisfied.
O O O Helium-3 Considerations Ofice of Defense nngrams For long shutdowns, buildup of helium-3 can be an important reactivity effect.
l 6-month shutdown modeled near end-of-life Results:
- - ~80 ppm decrease in critical boron at restart
- only small changes in radial power distribution :
- core peaking factors not significantly affected (<1% .
change)
- decrease in cycle energy of 10 EFPD i
O O O 1 l
h Conclusions Offh'c ofD.-jdtse hvgrums Tritium Production Cores will operate within the key safety parameter ranges employed for conventional cores.
Nuclear Design Bases will be met.
! Higher fuel enrichments and/or more feed .
assemblies are required to achieve equivalent cycle energy.
.o o o l Summary of TPBAR Technology Cheryl Thornhill Pacific Northwest National Laboratory i
i
. .. - - . .~-.-. . .. . . . . . - . .
O O O h LTA STATL S Office ofDefbnsc Pmgmms
[
4 Lead Test Assemblies
- 8 TPBARs per assembly Inserted in Watts Bar September 1997
- Full power achieved 10/27/97
- Cycle ended 2/27/99 Exposure 471.5 EFPD ,
Total cycle burnup 18,066 mwd /MTU RCS samples taken throughout cycle 20
O O O ;
h LTA STATL S t)] fire ofDefertse Pmgrams Coolant tritium data were consistent with Cycle 1 trends Initial Analysis indicates TPBARs have performed as expected LTAs scheduled to be removed from host fuel assemblies 3/19/99
- Visual exam to be done when removed l - Place in storage arrays pending shipment to l
ANL-W l 21 l
a O O O h LTA STATUS 00 ice nfDefense Mgmms i
4 Shipments from WBN to ANL-W l ANL-W to perform NDE on all 32 TPBARs
- Visual and photography
- Rod puncture and gas analysis
- Neutron radiography and gamma scan
- Rod diameter and length Selected TPBARs to PXNL for destructive exams l
l 22- l
t D O O TRITILM PRODE CING BLRNABLE
- ABSORBER RODS Office of Defense hvgrams Underlying design principles
- Mimic, to the extent practicable, standard commercial Westinghouse burnable poison absorber rods
- Minimize the impact on reactor operations
- Produce and retain tritium l
I 23 i
O O O O Sketch of TPBAR Comprogramsonents Office of Defense w
r Liner Absorber Pellet Zircaloy-4 + ,
Lithium Alaminate i Getter .5 4 .
l Nickel I; Getter '
Plate / ZircaI6y:4%
Cindding w Cladding I.( $ 6 Stainte tee Aluminide N 9 l
Coating i k
l
, $l n .
l h-l l
Not to Scale 24 i i
I
O O O h DESIGN CHANGES SINCE LTA Office of[hfwsc Pmgrams Partiallength absorber column Lithium-6 enrichment (gm 6 Li/ inch)
Modified end plug weld 25
o o o l' I
Results of Key Safety Evaluations 1
l James Sejvar i Michael Travis !
Westinghouse Electric Company i
l
O O O
- h LOCA Analysis Assumptions LOCTAJR Assumptions D Radial Heat Transfer by Radiation and Conduction
- Negligible Steam Flow Between TPBAR and Guide Thimble
- Zirconium / Water Reaction Included on Outer Surface of Guide Thimble
- - Post-LOCA TPBAR Heat Generation Rates
- Hot Channel Fluid Conditions and Hot Rod Temperatures Input to LOCTAJR 29
-. --- - _ - - - _ _ - - - _ - - _ - - -- _-- ---- L
o o o t
h LOCA Analysis Assumptions an. ,,na- ~-
Small Break LzOCA Boundary Conditions from Analysis of Record, Appendix K Calculations, NOTRUMP/SBLOCTA Codes Large Break LOCA Boundary Conditions from Analysis of Record, Appendix K Calculation.s, SATAX/ BASH /LOCBART Codes ;
i Methodology Could Be Adapted to B.E. Large Break LOCA Analysis with WC/T Code 30
O O O 4
h Small Break LOCA Results
,,,,_ ~,_ ,
TPBAR Cladding Temperature Transient Tracks Adjacent Fuel Rod Cladding Temperature Cladding Burst Not Predicted for Reference Plant
. No Burst Effects (Particles) 4 Swelling and Blockage of TPBAR/ Thimble Channel Considered Presence of TPBARs Has Insignificant Effect on .
i Small Break LOCA Fuel Rod Behavior 31 i
I
..-.- -- . - . _ - - - .. - - - ..-- - .~ ~ . . _ - - . .- - . - . - ..=. . - ... - . .
O O O f h Large Break LOCA Results Ofice ofDejhtse ncgrams TPBAR Cladding Temperature Transient Tracks Adjacent Fuel Rod Cladding Temperature Cladding Burst Calculated Early in Transient Potential Burst Effects (Particles) Negligible due to Prior Fuel Rod P4urst Swelling and Blockage of TPBAR/ Thimble Channel Addressed in Analysis Assumptions Presence of TPBARs Has Insignificant Effect on Large Break LOCA Fuel Rod Behavior 32 i
O O O Tritium Production Core Reactor VesselIntegrity Officc ofDefertsc hognmus The 1.5 Percent Increase in Projected Vessel i Fluence Will Have Minimal Impact on Reactor Vessel / Plant Operation for the Reference Plant The Acceptance Criteria may not be met if:
A Plant is Close to the Pressurized Thermal Shock (PTS) Screening Criteria A Plant is Operating with Little Margin During Heatup/Cooldown The Vessel is on the Border of Upper Shelf Energy There is a High Copper / Nickel Content in the Beltline Materials 33
~
O O O Normal Plant Operation Office ofDcfense Progr.irns
- Source Tenns -
- Neglible Change in Source Terms other than tritium
- Design Permeation Release of I Ci/ year per Core Average TPBAR or Approximately 3300 Ci/ year Assumed in the Evaluations
- Failure of 2 TPBARs (~ 20,000 Ci) as a bounding assumption also Evaluated Waste Management
- Without Dilution, Retention of Tritium in Plant Water Volumes Would Result in Increased ORE to Plant Workers
- Additional Inventory Controlled by Continuation of Current Practice of Dilution and Discharge
- Operating Plants Currently Discharge about 900 Ci/ year
- Possible Increase of One Resin Bed (30 ft3) per year .
34
--_-----_____------_--,---___.----_____-__--__--,,---2 -
O O O Normal Plant Operation (cont.)
Ojnce qfDcforse Programs Monitoring and Sampling
- Increased No. of Batch Releases - Increased Sampling Frequency
- Do Not Anticipate Changes / Additions to PERMS Equipment Occupational Radiation Exposure
- Tritium Concentrations in Excess of 2-4 microcuries/ gram Require Management ofRCS Activity
- Reduced Worker Efficiency with Additional Protective Equipment (e.g.
plastics, respirators, SCBA, etc.)
Plant Effluents & Off-Site Radiation Dose
- Worst Case Release (Failure of 2 TPBARs) Would Result in Small Increase in Off-site Dose Less than 10% of ODCM Liquid Effluent Annual Limit Less than 0.1% of ODCM Airborne Effluent Annual Limit 35
O O O Accident Scenarios .
Offia ofDefense Progr.uns Radiation Dose Impacts
- Only Accident Having a Substantial Release of Tritium to the Environment is the LBLOCA
- No Significant Impact on Off-Site Thyroid or Whole Body Doses
- Committed Effective Dose from Tritium is of Concern Only for Control Room Dose with a High Leak Rate of Recirculating Sump Fluid (e.g. I gpm vs 1 gph)
Equipment Qualification Radiation Dose
- Lower TPC Burnups Generally Result in Lower Dose Hydrogen Buildup inside Containment
- Zirc-Water Reaction and TPBAR Inventory Results in ~600 scf or 0.6% of the Total hydrogen Volume at Regulatory Guide 1.7 Limit 36
- O O O l t
Conclusions Olik'c o/ Defense nnarams Increased Discharges allow Normal Operation ORE
/ALARA Goals to be met
. - Current Situation in Operating Plants Continuation of Current Discharge Practices can Accommodate Additional Tritium Inventory with TPC l
Major Impact on Normal Plant Operation is Increased-Sampling and Batch Discharge Frequency l Major Accident Dose Impact is Control Room Dose
- Impact is Small if Recirculation Sump Leakage is a Typical Plant Value (approximately 1 gph) 37
. o o o i
Conclusions of the Topical
. Report Sandra Andre' Westinghouse Electric Co.
t
O O O h Fcilure Modes and Effects Analysis (FMEA)
Officeof thfbtnel>ograms Only considered those failures which could be
^
safety significant or could affect occupational or off-site doses Only considered events which could occur
- between arrival of the new TPBAR/ fuel assemblies at the plant until irradiated
- TPBAR/ fuel assemblies placed in spent fuel pool t
- f i
39
- - _ _ _ - - = _ _ _ - _ _ _ _ - _ - _ - _ - - - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - - - - - - - - _ _ - _ - _ - - - - -
O O O ,
4 j
h Failure Modes and Effects Analysis (FMEA) '
pfIkfense Pmgrams Five potential failure modes identified which
- could result in inability of TPBARs to perform their safety function
- Misload of multiple fuel assemblies in core
- Multiple TPBARs not loaded
- Missing multiple pencils
- Lithium loading error affecting multiple TPBARs
- Inadvertent operation of TPBARs for second cycle 40
o o o h Failure Modes and Effects Analysis (FMEA) oz - ~ ~ ~ ,, -
All five potential modes are mitigated by administrative controls Errors large enough to cause fuel design limits to be exceeded are detectable by Tech Spec required surveillances 41
O O O
$ Significant Hazards Consideration OZWe ofDefense nograms -
No significant increase in the probability or consequences of an accident previously evaluated.
i
- Report shows that TPC does not impact any systems, components, or conditions that could lead to an increased probability of an accident.
i 42
O O O l
I h Significant Hazards Consideration
' Ofice qfDefense iW> grams No significant increase in the probability or consequences of an accident previously evaluatec .
- TPC has no adverse impact on offsite thyroid doses due to
- Offsite changeswhole bodygas in noble doses increase source slightly,in term, but rema well withm dose acceptance limits
- Control room whole body and thyroid doses increase, but can be maintained within acceptance limits for typical post-LBLOCA recirculation leakage
. 43
O O O i
! h Significant Hazards Consideration Office ofAfbnse nvgrams Does not create the possibility of a new or different kind of accident
- Differences from BPRAs for normal operation TPBARs contain materials not found in BPRAs.
Matrix of materials and potential interactions presented in Topical Report.
He 3 buildup during shutdown. Scenario was evaluated and found to be benign.
TPBARs removed from assembly, packaged, and shipped. This activity is outside the scope of the Topical Report.
44
i O O O l
h Significant Hazards Consideration
.. . tJffice ofEkfertse 1%gmms Does not create the possibility of a new or different kind of accident
- FMEA performed to evaluate potential consequences of failure of TPBAR and each TPBAR component Five potential failure modes identified which could impact the ability of TPBARs to perform their safety furiction. However, all are mitigated by administrative controls and are detectable during Tech Spec required surveillance
- TPBARs do not alter the nature of a LOCA or any other accident 45
O O O .
h .<
Significant Hazards Consideration Ollice ofTkfense Pmgmms t
Does not involve a significant reduction in margin ofsafety
- Most key safety analysis input parameters remain within the bounds of the current applicable reload s?fety analysis parameters
- Safety analyses results have been shown to be virtually unaffected 46
O O O i
h Plant Specific Evaluations for LAR Office afDefense Prograrns Table 4-1 of Topical Report provides a roadmap for preparation of the plant : '.ecific LAR Many items will require only a confirming check that input parameters / assumptions have not changed, e.g. design transients Some items are identified as requiring a plant specific analysis / evaluation, e.g. core design 47
o o o Closing Remarks James Wilson I
qA= p=uclear Regulatory Commission l
l l
[
. ._ -- - - - - -__-_