ML22095A108
| ML22095A108 | |
| Person / Time | |
|---|---|
| Issue date: | 03/03/2022 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Burkhart, L, ACRS | |
| References | |
| NRC-1869 | |
| Download: ML22095A108 (161) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number:
(n/a)
Location:
teleconference Date:
Thursday, March 3, 2022 Work Order No.:
NRC-1869 Pages 1-115 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 693RD MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 THURSDAY 8
MARCH 3, 2022 9
+ + + + +
10 The Advisory Committee met via 11 teleconference at 8:30 a.m., Joy L. Rempe, Chairman, 12 presiding.
13 14 COMMITTEE MEMBERS:
15 JOY L. REMPE, Chairman 16 WALTER L. KIRCHNER, Vice Chairman 17 DAVID A. PETTI, Member-at-Large 18 RONALD G. BALLINGER, Member 19 VICKI M. BIER, Member 20 CHARLES H. BROWN, JR., Member 21 VESNA B. DIMITRIJEVIC, Member 22 GREGORY H. HALNON, Member 23 JOSE A. MARCH-LEUBA, Member 24 MATTHEW W. SUNSERI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 ACRS CONSULTANTS:
1 DENNIS BLEY 2
4 DESIGNATED FEDERAL OFFICIAL:
5 KENT HOWARD 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 CONTENTS 1
Page 2
NIST Event Briefing (Open) 3 7.1) Remarks from Subcommittee Chairman.....
4 4
7.2) Presentations from the NIST and NRC staff 5
Joshua Borromeo..............
8 6
Thomas Newton, NIST............ 11 7
Patrick Boyle, NRC
............ 73 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 P-R-O-C-E-E-D-I-N-G-S 1
8:30 a.m.
2 CHAIRMAN REMPE: So good morning, this 3
meeting will now come to order. This is the second 4
day of the 693rd meeting of the Advisory Committee on 5
reactor Safeguards.
6 Because of the COVID-19 outbreak and 7
current health precautions, this Committee meeting is 8
being conducted remotely.
9 I'm Joy Rempe, the Chairman of the ACRS.
10 I'm now going to call roll to verify a quorum. And 11 that clear communications exist.
12 Members in attendance are Ron Ballinger?
13 MEMBER BALLINGER: Yes.
14 CHAIRMAN REMPE: Vicki Bier?
15 MEMBER BIER: Yes.
16 CHAIRMAN REMPE: Charles Brown?
17 MEMBER BROWN: Yes.
18 CHAIRMAN REMPE: Vesna Dimitrijevic?
19 MEMBER DIMITRIJEVIC: Yes.
20 CHAIRMAN REMPE: Great.
21 MEMBER DIMITRIJEVIC: Sorry. I forget how 22 to use my microphone.
23 CHAIRMAN REMPE: Charlie, I think we need 24 you to mute yourself now because I'm hearing a little 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 bit of an echo. Greg Halnon?
1 MEMBER HALNON: Yes, I'm here.
2 CHAIRMAN REMPE: Walt Kirchner?
3 VICE CHAIRMAN KIRCHNER: Here.
4 CHAIRMAN REMPE: Jose March-Leuba? We'll 5
come back to Jose. Dave Petti? Dave, I can't hear 6
you although you --
7 MEMBER PETTI: Oh. Here.
8 CHAIRMAN REMPE: Oh now I hear you. Okay.
9 Thank you. Okay, Jose, are you there because, since 10 we had a little bit of trouble with Dave?
11 MEMBER MARCH-LEUBA: Yes. I had to change 12 speakers. My headphones are still working.
13 CHAIRMAN REMPE: Okay. Okay, thanks. And 14 then Matthew Sunseri, are you here?
15 MEMBER SUNSERI: Here.
16 CHAIRMAN REMPE: Great. So we have a 17 quorum. The ACRS was established by the Atomic Energy 18 Act and is govern by the Federal Advisory Committee 19 Act.
20 The federal notice announcing this meeting 21 was published on February 14th, 2022. This 22 announcement, as well as an agenda and instructions 23 for interested parties to submit written documents or 24 to request opportunities -- this announcement included 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 an agenda and instructions for interested parties to 1
submit written documents or request opportunities to 2
address the Committee.
3 The designated federal officer for this 4
meeting is Kent Howard.
5 A communications channel has been open to 6
allow members of the public to monitor the open 7
portions of this meeting.
8 The ACRS has just started inviting members 9
of the public to use the MS Teams link to view slides 10 and other discussion materials during these open 11 sessions.
12 If you're a member of the public who does 13 not yet have this link, please email Lawrence Burkhart 14 at lawrence.burkhart@nrc.gov. And I'll say it again 15 just so you can write it down.
16 lawrence.burkhart@nrc.gov.
17 In the future, the MS Teams link 18 information will be placed in the federal notice, 19 register notice. And agendas on the ACRS public 20 website.
21 We've received no written comments or 22 requests to make oral statements from members of the 23 public regarding today's session. Periodically the 24 meeting will be opened to accept comments from 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 participants listening to our meetings.
1 Written comments may be forward to Mr.
2 Kent Howard, the designated federal officer.
3 During today's meeting the Committee will 4
an information briefing on the National Institute of 5
Standards and Technology, or NIST, reactor event.
6 A transcript of the open portions of the 7
meeting is being kept. And it's requested that the 8
speakers identify themselves and speak with sufficient 9
clarity and volumes so that they can be readily heard.
10 Additionally, participants should mute themselves when 11 not speaking.
12 At this time I'd like to ask other members 13 if they have any opening remarks. Hearing none, I'd 14 then like to ask Member Sunseri to lead us through the 15 information briefing for today. Matt.
16 MEMBER SUNSERI: Thank you, Chair Rempe.
17 Good morning, Members. Members, this is the much 18 awaited briefing by NIST and NRC Staff on the event 19 that occurred at the NIST Reactor a little over one 20 year ago.
21 Our plant operations subcommittee has been 22 following the review and have provided the committee 23 earlier reports from Staff to help you keep updated.
24 We have been waiting for NIST and Staff to complete 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 their reviews so that we can get a complete 1
understanding of what happened and what NIST is doing 2
about it.
3 We reached that point in time. And I look 4
forward to today's briefings and interactions. And 5
I'd also like to thank the folks at NIST and Staff for 6
meeting with us today.
7 Josh Borromeo, branch chief of the NPUF 8
licensing branch will introduce NIST and the Staff.
9 And before we get started I want to let everyone know 10 that we do have a hard stop at 11:30 due to another 11 activity that requires the attention of several 12 members.
13 So, are there any questions from Members 14 before we get started? All right. I will now turn to 15 Joshua for the introductions and presentations.
16 Joshua?
17 MR. BORROMEO: Thank you, Member Sunseri.
18 Like said, I'm Josh Borromeo and I'm chief of the Non-19 power Production and Utilization Facility, or NPUF, 20 licensing branch. My branch is responsible for the 21 licensing of NPUFs, including the National Institute 22 of Standards and Technology, NIST, center for neutron 23 research.
24 We are happy to have the opportunity to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 provide the ACRS with an overview of the fuel failure 1
event that occurred on February 3rd, 2021 at the test 2
reactor at NIST. Today you'll hear from both the 3
licensee and the staff with a primary focus on the 4
event sequence and the technical analysis of the 5
event.
6 Now, there are two areas that I want to 7
highlight before I turn over to NIST. First, while 8
this was a fuel failure event and there was a release 9
of radioactive material to the environment, the 10 reactor safety systems functioned properly and the 11 offsite dose to the public was near background levels 12 and well below the NRC's regulatory limits.
13 The NRC remains satisfied that public 14 health and safety was protected. And that the 15 surrounding community remains safe. The reactor 16 remains safely shut down and is being continuously 17 monitored for fission product release.
18 The second is that this event exceeded a 19 safety limit. And exceeding a safety limit requires 20 the reactor to be shut down and cannot be restarted 21 without NRC authorization. The NRC is actively 22 reviewing the NIST request to restart the reactor and 23 perform an inspection and enforcement activities.
24 Given that the NRC has not completed all 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 of these reviews there may be areas that we cannot 1
discuss with you today. And while the NRC is 2
prioritizing the review, the Agency will not authorize 3
restart of the facility until it is determined that 4
the restart will be protected of public health and 5
safety.
6 Presenting today for the staff will be 7
Patrick Boyle, who is the project manager for NIST.
8 And Tom Newton will be presenting for the Licensee.
9 I look forward to the discussion today and 10 hope that we can provide you with valuable insights on 11 this event. Thank you again. And I'll turn it over 12 to NIST if there aren't any questions.
13 MR. NEWTON: Thank you, Joshua. I would 14 first of all like to introduce my colleagues from 15 NIST. So I'm Tom Newton, a deputy director of NCNR 16 and the chief of reactor operations and engineering.
17 And I'd like to have my colleagues introduce 18 themselves as well.
19 MR. DIMEO: My name is Rob Dimeo. I'm the 20 director for the NIST Center for neutron research.
21 MR. DEWEY: I am Steve Dewey. I'm the 22 chief of health physics at the NCNR.
23 MR. BRAND: I'm Paul Brand. I'm the chief 24 of reactor engineering.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 MR. STRADER: And I'm Randy Strader. I'm 1
chief reactor operations.
2 MR. NEWTON: Thank you, gentlemen. I will 3
now start the sharing of the slides here. I trust you 4
can all see that.
5 So what we're going to talk about today 6
is, first of all, we're going to talk about the 7
reactor and describe the reactor and the fuel. Then 8
talk about the February event in some detail.
9 Followed by corrective actions and, well, root causes 10 and corrective actions.
11 So first of all, the NCNR, the NIST Center 12 for Neutron Research, is one of three major neutron 13 science centers in the United States. The other two 14 are at Oak Ridge National Laboratory, the spallation 15 neutron source and the high flux isotope reactor.
16 We have a total of 30 neutron instruments 17 that are supplied neutrons from the reactor. The ones 18 over here on the right are all in our guide hall that 19 are supplied, that are focused on our liquid hydrogen 20 cold source. Our large liquid hydrogen cold source.
21 So these are all cold neutron instruments.
22 The ones that are sort of the center here 23 are mostly thermal neutron instruments, with the 24 exception of the BT9 instrument, which it has its own 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 liquid hydrogen cold source.
1 So all of these beams are oversubscribed 2
by a factor of at least two. So there is a high 3
demand for our neutrons. And we support greater than 4
3,000 research participants at the NCNR every year.
5 As I mentioned though, the neutrons are 6
supplied by the 20 megawatt reactor, the NBSR. And 7
the reactor operates on a 38 day fuel cycle.
8 This is a view of the reactor. A cutaway 9
view of the reactor. We have 30 fuel elements in the 10 reactor. Each of these elements have a hat on top 11 that we use for moving.
12 These elements are inserted into the lower 13 grid plate, which is where the nozzle meets up with 14 the flow of heavy water through the reactor. And then 15 they're latched in the upper grid plate here.
16 We have a split core with a flux trap in 17 the middle. So there are upper and lower fuel 18 sections with a gap in the middle for a peak of 19 thermal neutrons and to lower the amount of gamma rays 20 that go out to the beam tubes and the liquid hydrogen 21 cold source.
22 The reactor is controlled by four shim 23 safety arms, which are made of cadmium. They are 24 rotated by the shaft outside the reactor so it's a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 shim a four motion that the elements, the shim arms 1
are moved. Total travel is about 40 degrees from full 2
in to full out. Criticality is roughly half way or so 3
when we startup a fuel cycle. There is also a small 4
regulating rod here we use for fine tune control.
5 As I mentioned, it's a heavy water 6
reactor. So it's heavy water cooled, moderated and 7
reflected. We have two plenum of inlet from the 8
primary pumps. So the heavy water flows through the 9
reactor at a flow rate of about 9,000 gallons a 10 minute. And during full power operation that results 11 in about a 15 degree Fahrenheit temperature change 12 across the reactor.
13 The fuel itself is HEU fuel. Uranium 14 oxide U308. It's a dispersion fuel with aluminum 15 dispersant. And it's clad and aluminum.
16 We have an interior of the reactor, there 17 are 17 fuel plates. There are actually 34 since there 18 are upper and lower sections. The outer plates here 19 are just aluminum, there is no fuel there. So all the 20 fuel, of course, is in the center. We have a total 21 loading of about 350 grams of uranium-235 per fuel 22 element.
23 The way we do our refueling. We have four 24 new elements that we added at the outside of the core.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 And every other fuel element is moved during the 1
refueling to a different position wherein that the 2
more burnt elements are in the center and the less 3
burnt elements are on the outside. And that runs for 4
38 days until we run out of reactivity and start the 5
process over again.
6 Each element is in for either seven or 7
eight cycles. So when we put those four new elements 8
in we discharge four. Two of which have been in for 9
eight cycles and two of which have been in for seven 10 cycles.
11 And because it's heavy water coolant, the 12 refueling is done by feel and by hand. We can't mix 13 the heavy water with the air because it could, first 14 of all, degrade the heavy water. And second of all, 15 you could expose the personnel to triuranium from the 16 heavy water. So everything is done by feel.
17 This is a picture over here on the right 18 of a refueling we done a number of years ago. This is 19 a new element that's getting ready to be put into the 20 core. They're going to hook it up to this extension 21 rod, lower it into this hole here, and then use these 22 transfer arms to transfer the element across the core 23 to the position it needs to go into.
24 We have a refueling tool that's dedicated 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 to each position. So once the element is in position, 1
the refueling is hooked up to that element and then 2
lowered down into the core. And then lastly, the 3
position into the upper grid plate.
4 And to make that a little clearer, I've 5
got a little video here that I'll show you. This is 6
the refueling tool that's hooked up to the top element 7
head. The element right here suspended above the 8
upper and lower grid plates. And you'll seen in the 9
video, it's going to get lowered into the section.
10 And then we'll zoom in a little bit and you'll see how 11 the latching mechanism works.
12 (Whereupon, the video was played.)
13 MR. NEWTON: So here is the element 14 lowering into position. Now it's in the lower grid 15 plate. And now the tool will be pushing the element 16 against the spring. The hat against the spring.
17 You can see this is the latching mechanism 18 that runs underneath the reactor and then it's then 19 rotated over and then brought into a notch underneath 20 the upper grid plate. And then it's latched into 21 place and the tool is removed.
22 So, moving now to the event. On January 23 4th, about a month before, we did a refueling in 24 preparation for a re-startup. It was a relative 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 routine refueling. Latching and latch checks were 1
done after the refueling was completed.
2 After the event was done, and we used 3
video surveillance to find out what the heck happened 4
here, we found that the latch checks were not done 5
correctly. As a result of that, an element that had 6
been in for one cycle, a second cycle element was not 7
latched into position.
8 And I want to emphasize this diagram we 9
see here. It's the way we found it after the event.
10 So there is a little speculation as to what it looked 11 like before all that happened.
12 One other factor is that we delayed 13 startup about a month because of COVID concerns. And 14 so we decided to start the reactor on February the 3rd 15 instead.
16 As part of that procedure, since it was 17 January, we needed to keep the primary system cool and 18 the secondary system warm so about every day we would 19 start and stop the primary pumps. And the speculation 20 here is that the starting and stopping of the pumps 21 pushed this element out of position away from the 22 flow. So then it became resting on the lower grid 23 plate without any flow to it.
24 Even though this out of position flow and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 pressure instruments didn't show any anomalies so 1
there was no detection that this was out of position.
2 MEMBER SUNSERI: Hey, Tom, this is Matt.
3 MR. NEWTON: Yes.
4 MEMBER SUNSERI: Just a quick question 5
here. How much do those fuel elements weigh?
6 And have you thought about, is the reactor 7
coolant pumps, is there sufficient flow to cause a 8
lift, enough lift force to move it?
9 MR. NEWTON: Yes, there is. There's 10 definitely, we've actually seen this before. The 11 elements weigh, I think about 1 kilogram. Randy, is 12 that right? Twenty pounds maybe.
13 MR. STRADER: Yes. It's about 40 pounds.
14 MR. NEWTON: Forty pounds, okay.
15 MR. STRADER: Yes.
16 MR. NEWTON: Yes, so 20 kilograms. So 17 yes, there is definitely sufficient force to move the 18 element out. And that's one of the reasons we have it 19 latched in the grid.
20 MEMBER SUNSERI: Yes. No, I understand.
21 Okay, great. And just so it will help out the members 22 a little bit, if you can pause every now and then and 23 let members interject questions or comments as they 24 go.
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18 MR. NEWTON: Okay.
1 MEMBER SUNSERI: Thank you.
2 MR. NEWTON: Feel free to interrupt also.
3 MEMBER SUNSERI: Yes, no problem.
4 MEMBER HALNON: Hey, Tom, this is Greg 5
Halnon.
6 MEMBER PETTI: Hey, Tom?
7 MEMBER HALNON: Dave, you want to go 8
ahead? I can wait.
9 MEMBER PETTI: I just wondered, the last 10 bullet. Do you guess have flex source range monitors 11 and --
12 MR. NEWTON: Yes.
13 MEMBER PETTI: And they didn't see 14 anything?
15 MR. NEWTON: Well, we didn't start up the 16 reactor until February 3rd so we didn't, the neutron 17 instruments are not seeing anything --
18 MEMBER PETTI: Ah.
19 MR. NEWTON: -- up until the startup. And 20 I'll kind of go over that --
21 MEMBER PETTI: Okay, thanks.
22 MEMBER HALNON: Okay. Yes, this is Greg.
23 Just a couple of questions from a dimensions 24 perspective.
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19 The bottom pin that was supposed to be in 1
the hole, it's moved over how far? What is that 2
dimension?
3 MR. NEWTON: I would guess maybe about 4
four or five inches.
5 MEMBER HALNON: Four or five inches.
6 Okay. I was just trying to get some context.
7 MR. NEWTON: Okay.
8 MEMBER HALNON: And then in the upper 9
portion, where the fuel plate sticks through the upper 10 tube sheet, or upper plate, is there clearance there 11 that you have in your mind or is there, how big is the 12 square hole and how big is the plate going in?
13 MR. NEWTON: It's about four-by-four or 14 something. Randy, maybe you could, do you know the 15 dimensions of that?
16 MR. STRADER: I don't know the dimensions 17 exactly --
18 MEMBER HALNON: Okay.
19 MR. STRADER: -- but there is about a half 20 inch to three quarter inch gap total around.
21 MEMBER HALNON: Okay. So there is not a 22 tight clearance there?
23 MR. STRADER: No. It's not a tight 24 clearance, no.
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20 MEMBER HALNON: Okay. All right, thanks.
1 MEMBER SUNSERI: And Ron Ballinger has his 2
hand up. Ron?
3 MEMBER BALLINGER: Yes, thanks. With 4
respect to the 1, 2, 3, third bullet, the second 5
element was not latched. Is there a checklist similar 6
to, for lack of a better word, a pilot's checklist 7
where you have a procedure where more than one person 8
has to sign off or verify that something is done?
9 MR. NEWTON: Yes.
10 MEMBER BALLINGER: Or was there?
11 MR. NEWTON: Yes, there was a checklist.
12 The folks that did the check actually thought they did 13 it correctly and signed off on it. And then we found 14 out later they didn't do it correctly. So all the 15 paperwork was in order but it was not correct.
16 MEMBER BALLINGER: Thanks.
17 MR. NEWTON: Sure. Other questions?
18 Okay, I'll proceed then.
19 So the event on February 3rd. We did a, 20 what we thought was a routine startup. We began the 21 startup at 8:16 in the morning. We leveled off at ten 22 megawatts, as we do per procedure, at 9 o'clock. At 23 9:06 we begin at essentially full power. And at 9:07, 24 before we reached full power, there was a sudden drop 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 to about seven megawatts or so followed very shortly 1
thereafter by a release of fission products in our, 2
that was detected in our fission product monitor with 3
the cover gas that leaves the reactor.
4 Right after that the fission products 5
reached the stack radiation monitor which reached the 6
set point of 50,000 counts per minute, which resulted 7
in what we call a major scram. A major scram not only 8
scrams the reactor but also seals the confinement 9
building to limit any releases.
10 At 9:16 we declared an alert. At 9:21 we 11 had to evacuate the control room. Got a high 12 radiation levels. And the control room is located 13 just outside the reactor top area, which is fairly 14 typical in research reactors. And at 9:29 we notified 15 the NRC.
16 I've got a graph here of the event. This 17 is from a program that we call the reactor to a 18 desktop, which take a takes a sampling of data. So 19 it's good for trending but it's not necessarily great 20 for seeing all the peak numbers and stuff.
21 So just to orient you here. The green 22 line here is the shim arm position. The black line is 23 reactor power. The red line is the stack radiation 24 monitor. And the blue line is the fission product 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 monitor. This is the monitor that is the first to see 1
the fission products leave the reactor.
2 So we leveled off the reactor power level 3
at about a megawatt early on in the morning. And then 4
we --
5 MEMBER BROWN: Excuse me, what was the 6
green line again?
7 MR. NEWTON: The green line is the shim 8
arm position. This is basically control --
9 MEMBER BROWN: Oh, okay. I got it. All 10 right. Then I missed it. Thank you.
11 MR. NEWTON: Okay. And then we raised 12 power, as I said, about 9 o'clock and leveled off at 13 ten megawatts. And you can see there is some 14 oscillations here. We believe these oscillations are 15 due to departure from nuclear boiling in that element.
16 This was found in the nuclear instrument 17 somewhat, but it didn't reach a threshold by which the 18 operator thought it was sufficiently abnormal to take 19 action.
20 Then we raised power up to, close to full 21 power. Here is the sudden drop at seven megawatts 22 down to seven megawatts or so. We calculated this 23 later to be about 35 stents of negative reactivity.
24 You can see right as it drops. And then 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 we have sharp increase in the fission product monitor.
1 And once the fission products reached the stack, the 2
stack monitor went up precipitously as well causing 3
the major scram. You can see the scram happening 4
here.
5 And once the confinement building is 6
sealed then the stack monitor drops off due to lack of 7
airflow.
8 VICE CHAIRMAN KIRCHNER: Tom?
9 MR. NEWTON: Yes.
10 VICE CHAIRMAN KIRCHNER: This is Walt 11 Kirchner. The primary coolant system, it's the heavy 12 water cooled system. Did the pressure boundary leak?
13 Why did you see things in the stack?
14 MR. NEWTON: Oh, no. This is not pressure 15 boundary leak this is a normal, the helium above the 16 reactor is not a sealed system, it is part of our 17 ventilation system that, that we would normally expect 18 to see that.
19 Randy, do you want to comment --
20 VICE CHAIRMAN KIRCHNER: So the primary 21 coolant system is not a fission product barrier?
22 MR. NEWTON: It is. Maybe I've --
23 (Pause.)
24 MR. NEWTON: I guess that's a good 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 question. Well it's not sealed but it is a fission 1
product barrier.
2 MR. STRADER: It still contains --
3 (Simultaneous speaking.)
4 MR. STRADER: It still contains most of 5
the fission products in an event like this. Some of 6
the fission products, like the noble gases, come out 7
in the helium.
8 And there are, it's not a sealed system on 9
top. So they --
10 VICE CHAIRMAN KIRCHNER: So it's a cover 11 gas --
12 MR. STRADER: Yes.
13 VICE CHAIRMAN KIRCHNER: -- like system --
14 MR. STRADER: Yes.
15 VICE CHAIRMAN KIRCHNER: -- and that's the 16 path of escape for the gaseous fission products?
17 MR. STRADER: That's correct.
18 VICE CHAIRMAN KIRCHNER: Thank you.
19 MEMBER HALNON: Tom, this is Greg Halnon.
20 Can you just briefly tell me what the operators were 21 seeing real-time during this oscillation of the power?
22 I mean, did they notice it?
23 MR. NEWTON: Yes. Well actually, I've got 24 a backup slide here. I guess I could stop sharing and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 go down to, maybe just scroll down to that and it will 1
probably help you a little bit better.
2 Let me see, how do I do this. So there it 3
is. Okay.
4 This is what the reactor operator saw.
5 And of course we have the benefit of not only 20/20 6
hindsight but comparing a normal startup with the 7
startup on February 3rd. So you can see normally we 8
level off at ten megawatts. And there is a little bit 9
of oscillation used in a normal nuclear instrument 10 noise.
11 And then you can see ten megawatt is 12 significantly higher. One of the things we looked at 13 when we started looking at this event in detail is the 14 training on folks as to what is abnormal was a little 15 informal I guess I should say.
16 We had a couple of earlier events back in 17 the '80s and '90s where we started up the reactor with 18 a loose fuel element, and they saw significantly 19 higher oscillations due to what we think is attributed 20 to elements kind of bumping around in the flow with 21 probably some boiling going on at the same time.
22 And that was informally told to the 23 operators it's five to seven percent of oscillations.
24 And if you really crunch the numbers here you see 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 these oscillations are about four percent or 1
something.
2 Clearly it's not normal, but it didn't 3
really reach the threshold to alert the operator. And 4
this was an experienced operator.
5 MEMBER HALNON: Okay. So the previous 6
issue from back when you said you had the 7
oscillations, the fatter lines just didn't peak their 8
interest about what was going on in there, they just 9
assumed something was normal with it?
10 MR. NEWTON: Yes. There was a couple of 11 other contributing factors there, that we just 12 replaced the controller, the cycle four. And there 13 was some uncertainty there.
14 MEMBER HALNON: Okay. All right, thanks.
15 MR. NEWTON: All right. Let me run back 16 to where I was before. Let's see, where was I. Okay.
17 Any other questions on the graph? Okay.
18 In that response. As Joshua mentioned, 19 all systems operated like they were designed to do, as 20 expected. We of course test these before startup.
21 The operators and health physics staff did 22 effective response. They did what they were supposed 23 to do and what they were trained to do.
24 As I mentioned, the radiation levels in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 the control room necessitated evacuation. The 1
emergency instruction criterion is that we evacuate if 2
projected exposure to anybody in the control room is 3
going to exceed 300 millirem.
4 The two operators stayed briefly behind to 5
start some shutdown activities. And then we had a 6
reentry later that day into the building to complete 7
those shutdown activities.
8 And as a result of all this we had about 9
ten staff members that were contaminated due to the 10 event. They were successfully decontaminated and then 11 sent home later that day.
12 MEMBER HALNON: Tom, real quick, Greg.
13 MR. NEWTON: Yes.
14 MEMBER HALNON: This is Greg again. When 15 we talk operators, are we talking licensed operators, 16 senior or reactor operators?
17 MR. NEWTON: Yes. I believe there was 18 some trainees there as well, but most of them are 19 licensed operators.
20 MEMBER HALNON: Okay.
21 MR. NEWTON: Is that correct, Randy?
22 MR. STRADER: Yes, that's correct.
23 MR. NEWTON: Okay.
24 MEMBER BROWN: Can I ask a, this is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 Charlie Brown, can I ask a question also?
1 MR. NEWTON: Sure.
2 MEMBER BROWN: You noted that two 3
operators briefly stayed behind to start shutdown 4
actions. There is no, obviously they were still in 5
the radiation area, in the control room, to do that.
6 Is that the assumption that's correct?
7 MR. NEWTON: Yes.
8 MEMBER BROWN: Okay. So there is no 9
remote station where these similar actions can be 10 taken?
11 MR. NEWTON: We have a remote monitoring 12 station that we can monitor things. There is some 13 ventilation controls there but they don't have enough 14 controls to do things like start and stop pumps and 15 things like that.
16 MEMBER BROWN: Okay.
17 MR. NEWTON: But we do have a remote 18 station but it's not a complete remote --
19 MEMBER BROWN: It can't shut down and 20 control stuff after the event is, once you've got a 21 radiation problem in the control room.
22 MR. NEWTON: Yes. And keep in mind that 23 once the reactor scram we don't have decay heat 24 problems. As long as the pumps stay on we're good to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 go there.
1 So they stayed behind, first of all, 2
because they're projected exposure was really probably 3
not going to exceed 300 millirem if they're there for 4
a couple more minutes. Just to take care of a few 5
actions that they thought were necessary.
6 MEMBER BROWN: Well, if those actions 7
weren't taken, even though it's scram, is that a 8
problem?
9 MR. NEWTON: No.
10 MEMBER BROWN: So if they hadn't stayed, 11 my question is, if they hadn't stayed behind, the 12 plant scrammed --
13 MR. NEWTON: Yes.
14 MEMBER BROWN: -- would there have been a 15 problem if they hadn't been able to take those 16 subsequent shutdown actions?
17 MR. NEWTON: No. Randy, you want to 18 comment on that further?
19 MR. STRADER: No. Because we still have 20 forced flow. The shutdown pumps come on. And so that 21 would take care of all that. There were some actions 22 if we wanted to take the plant, a better situation so 23 when we're in our emergency control station we're able 24 to monitor things more accurately.
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30 MEMBER BROWN: Okay, thank you.
1 MR. NEWTON: Okay. Personnel doses. We 2
had a recorded total maximum dose of the maximum 3
personnel of about, a little over a rem.
4 And you can see the table here, all this 5
is a deep dose from the dosimeter. Of course the 6
annual limit from NRC is five rem, so it's well below 7
that.
8 We believe the doses are overestimated 9
because the dosimeters, as part of the event, got 10 contaminated. And it was a while before they were 11 decontaminated. And so we think the contamination of 12 the dosimeters itself contributed to that dose.
13 But to be conservative, we assign that 14 dose anyway. The EPD actually only shows 182 15 milligrams to the maximum exposed person.
16 We also did internal monitoring to see if 17 there were any uptake of fission products. The only 18 thing we saw was tritium, which is what we typically 19 see in reactor operators as they do get some internal 20 tritium dose. But there was no internal dose due to 21 the event itself we believe.
22 MEMBER SUNSERI: So that was my question 23 on that slide. So it is retained for operators to 24 receive internal dose from tritium?
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31 MR. NEWTON: Somewhat, yes. As part of 1
the refueling process you do get a little tritium 2
exposure just from moving things in and out of the 3
heavy water.
4 MEMBER BROWN: You noted that the 5
dosimeters were contaminated. Is that a normal 6
circumstance?
7 MR. NEWTON: Well no. I mean this was a 8
lesson learn we have that we collected their 9
dosimeters as folks existed the control room as part 10 of the decontamination, the personnel decontamination 11 process. And they were collected and put in a bag.
12 And it was a while before we got the bags sorted out 13 and decontaminated.
14 Steve, do you want to say anything else 15 about that?
16 MR. DEWEY: You got it exactly right. It 17 is abnormal for dosimeters to get contaminated. We do 18 on occasion, when work is going on in high 19 contamination
- areas, we usually try to take 20 precautions in that case. But in this case this was 21 an unusual event, obviously. And the dosimeters 22 getting contaminated was not anything routine.
23 MEMBER BROWN: So that was --
24 MR. DEWEY: And -- okay.
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32 MEMBER BROWN: That was due to being in 1
the control room then?
2 MR. DEWEY: Correct. Correct. So when 3
the event occurred from the reactor vessel, the top of 4
the reactor vessel is not complete sealed. So when 5
the noble gases came out of the top of the reactor 6
into the area of above the reactor, they also entered 7
the control room.
8 So the short, the decay product from the 9
noble gases deposited on the dosimeters and on the 10 personnel as well too. So that's where the source of 11 that dose came from.
12 MEMBER BROWN: And also the control 13 systems, right? I mean, the panels and everything 14 else --
15 MR. DEWEY: Correct.
16 MEMBER BROWN: -- you stated. Okay, thank 17 you.
18 MR. NEWTON: Now we'll kind of shift into 19 why we declared an alert. This is from the emergency 20 classification criteria for the environmental 21 emergency instructions.
22 Initial criteria for an alert is RD-401, 23 which is a stack monitor, reaching set point of 50,000 24 counts per minute. Then you drop down the action 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 level criteria as to whether or not you declare it.
1 And on 2.2.2 here, evidence of fuel cladding failure 2
by the high helium sweep activity, and that was the 3
blue line I showed you on the graph, reaches 50,000 4
counts per minute.
5 So clearly we had a fuel cladding failure 6
which lead us into the alert situation. So that's 7
when we declared it.
8 Now the kind of hard part is now 9
determining what the effluent doses and levels are at 10 the site boundary, which is what I'll discuss next.
11 On the boundary we have a 400 meter radius boundary 12 around the reactor as our emergency planning zone.
13 This is all within the NIST campus so there was no 14 overlap of offsite properties.
15 During the event, right after the event we 16 took multiple air and particulate samples. Both at 17 the site boundary and at the stack. The level that 18 the site boundary were either low or none detectable 19 and so it led to a lot of uncertainty as to what, 20 taking those measurements as to how that, how we can 21 quantify that.
22 So we eventually used the stack samples, 23 which there was a lot more data from. And dilution 24 factors, which is allowed in the emergency plan, to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 determine what the offsite, the 400 meter site 1
boundary doses are.
2 So as a result of those determinations we 3
downgraded to a notification of unusual event at 1532.
4 And then terminated the emergency at 1935. These were 5
the points at which we had made definite determination 6
that those samples were indicated at the levels were, 7
that level or below.
8 MEMBER HALNON: Tom, this is Greg. What 9
was the weather that day?
10 MR. NEWTON: It was fairly clear I think.
11 And it was a bit windy out. Steve, do you know? Did 12 you do a determination on atmospheric conditions?
13 MR. DEWEY: I'm not sure off the top of my 14 head. I certainly can get that but I don't remember.
15 MR. NEWTON: Okay.
16 MEMBER HALNON: Okay. Do your sampling 17 procedures take that into consideration, that site and 18 boundary depending on air, wind direction --
19 MR. NEWTON: Yes.
20 MEMBER HALNON:
time of
- day, 21 inversions, other things that may be occurring?
22 MR. NEWTON: Correct. Yes, everything was 23 taken down wind and at the appropriate locations as 24 best we can determine.
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35 MEMBER HALNON: Okay, thanks.
1 MR. NEWTON: We'll now talk about isotopes 2
a little bit. As you can see, the majority of the 3
release activities were as expected for fission 4
product noble gases, xenons and kryptons.
5 We had a total release during the event 6
was of about 30 curies of those noble gases. Again, 7
these are based on the stack samples. The boundary 8
samples show many isotopes of xenon and they were 9
very, very low so it was hard to quantify.
10 Initially we estimated the dose to the 11 public to be less than.5 millirem. NRC and DOE 12 independently confirmed that. And DOE later on did a 13 full dose estimate and turned out to be about eight 14 microrem at the boundary level.
15 You can also after the event we returned 16 to normal ventilation on February 6th. And over the 17 next six three months released about another 15 curies 18 or so. Resulting in about six microrem or something 19 of activity.
20 And you can see the differences in 21 activity levels between the event and three months 22 afterwards.
23 We didn't see any iodine at all in the 24 release initially for two reasons. One, it stayed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 mostly in the primary coolant system. And secondly, 1
our emergency ventilation has charcoal filters which 2
would absorb any remaining iodine.
3 Once we restarted normal ventilation those 4
charcoal filters are no longer in service and so we 5
saw just a smidgen of iodine-131 over the next few 6
days.
7 We had a little bit of cobalt-60 also in 8
one of the samples that we think was cross 9
contamination.
10 Effective, the 10 CFR 20, annual release 11 limits, is 10 millirem a year for a facility.
12 Typically we run about quite a bit less than that.
13 Our normal releases are argon-41 and tritium with an 14 annual boundary of about.8 millirem. Something like 15 that.
16 As I mentioned before, the event total 17 boundary dose was about 14 microrem, which is two 18 percent of what we normally release.
19 Now we have in our safety analysis report 20 the maximum hypothetical accident, which is a complete 21 melting of maximum activity fuel element. Which 22 results in a calculated dose of 6.4 millirem. And we 23 were orders of magnitude below that. So we're well 24 bounded by the MHA.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 Okay, shifting a little bit. On the 23rd 1
of February we were able to get a video camera and 2
start video surveillance of the core itself.
3 One of the first things we saw out of 4
normal was this element out of position. You can see 5
a normal element next to it, H-6, is in position.
6 This one is clearly up.
7 The other thing to look at is this latch.
8 This is the latch you saw in the video. This latch is 9
not over where it should be. Obviously it's in the 10 element window. And so this is clearly out of 11 position and clearly unlatched.
12 Then once we were able to get down to the 13 lower grid plate we took a look at this nozzle of the 14 element that was out of position. And you can see we 15 also have evidence of previously molten material 16 that's sitting on the lower grid plate.
17 CHAIRMAN REMPE: So do you know, or have 18 any idea or suspect what that material is?
19 MR. NEWTON: Well, it's at least aluminum.
20 CHAIRMAN REMPE: Yes.
21 MR. NEWTON: And we're sure --
22 CHAIRMAN REMPE: Do they think that it's 23 got anything else besides aluminum in it?
24 MR. NEWTON: We --
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38 (Simultaneous speaking.)
1 MR. NEWTON: We haven't done a complete 2
PIE of all this material yet. We were speculating 3
it's mixed fuel and aluminum.
4 CHAIRMAN REMPE: Thanks.
5 MR. NEWTON: And of course there is also 6
fission products in the system that we have seen. So 7
clearly those fuel, or at least fission products, have 8
escaped.
9 As a result --
10 MEMBER SUNSERI: Excuse me, I think Ron 11 has a --
12 MR. NEWTON: Oh, he does. Okay.
13 MEMBER SUNSERI: Ron has another question.
14 MEMBER BALLINGER: Yes. I'm looking at 15 this picture and then I'm looking back, I'm remember 16 back at the cartoon of the latching thing. And I'm 17 also remembering the statement that the operators 18 believe that they had done the procedure right.
19 And that's awful hard for me to reconcile 20 given what I'm seeing. So I'm assuming that we'll 21 hear a bit later about corrective actions related to 22 this.
23 It's just hard to see how this could be 24 signed off on.
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39 MEMBER HALNON: Well this is not visible, 1
right?
2 MEMBER BALLINGER: Well, it may not be 3
visible but you're turning a wrench at the top 4
effectively. And that wrench isn't going to move, 5
that thing is not going to latch and you're not going 6
to be able to move that.
7 But again, I'm looking at a cartoon plus 8
a video so I could be completely wrong.
9 MEMBER SUNSERI: This is Matt. Ron, I 10 think you're getting ahead of them a little bit. They 11 will talk, I'm sure they'll talk about this. I looked 12 ahead in the presentation.
13 MR. NEWTON: Well, just to kind of put a 14 little bit of emphasis on that, the latch check that 15 was done after the fact, one of the things we found is 16 they turned it in the wrong direction. And so that 17 was a lot of confusion. Clearly some training issues 18 and procedural compliance issues that I will talk 19 about in a bit.
20 MEMBER BALLINGER: Thanks.
21 MR. NEWTON: Sure. So as a result of the 22 video surveillance, and other things, we made a 23 conclusion on March 5th that we exceeded the 450 24 degree fuel safety limit and reported that to NRC in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 accordance with our tech specs. And as was mentioned 1
earlier, that the reactor was shut down, obviously, 2
and operations are not going to be resumed until NRC 3
authorizes restart.
4 (Telephonic interference) on the failed 5
fuel element and identified it was element number 6
1175. It was originally introduced into the core on 7
October. The previous October. It ran a full cycle 8
no issues, no problems there.
9 We also looked at, took a good hard look 10 at the QA records and manufacturing and inspection and 11 all that sort of stuff and identified there was no 12 anomalies. So this was a normal element that was 13 clearly out of position.
14 Sometime last summer we began procedures 15 to remove the failed fuel element. Here is another 16 picture of this element sort of from the side. You 17 can see the nozzle and previously molten material on 18 the lower grid plate. The nozzle, the hole here where 19 it would normally go is over here. You can't really 20 see it that well.
21 And then once we pulled the element up you 22 can see all of the molten, the previously molten 23 material stayed with the element. Which is good news 24 there. It didn't abnormally effect the lower grid 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 plate in any way.
1 Then we moved the element. We had a 2
debris cap here sitting on where the element would 3
normally go to catch any debris that might come off 4
the element. And we eventually removed these pieces 5
here prior to removal. Removal.
6 And then over here on the right here you 7
see, looking up at the bottom of the fuel element you 8
can see all of this previously molten material pretty 9
much accumulated all in the nozzle area. Again, we 10 haven't done any PIE to know the exact amount of fuel 11 that as melted, but clearly significant.
12 CHAIRMAN REMPE: So just to make sure I 13 understand, the nozzle itself is probably stainless or 14 something else?
16 CHAIRMAN REMPE: The nozzle itself that 17 looks pretty nice and undamaged at the bottom is 18 aluminum. So this is stuff coming from above that's 19 dribbled down is what you're thinking?
20 MR. NEWTON: Correct.
21 CHAIRMAN REMPE: Okay.
22 MR. NEWTON: Paul, Randy, do you want to 23 comment on this at all?
24 MR. STRADER: Yes.
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42 MR. BRAND: The nozzle was, I'm sorry, 1
this is Paul Brand. You want to answer, Randy, that's 2
fine.
3 MR. STRADER: All I was going to say is 4
that the fuel is located well above the nozzle. So 5
it's traveling through the moderator after it melts.
6 And the fuel is about, it's about, I'm doing the math 7
in my head, it's about five inches away.
8 CHAIRMAN REMPE: So I get the fact that 9
it's hotter up in the middle of the core than down at 10 the bottom, but it's interesting it didn't freeze and 11 it got all the way down there and accumulated. Any, 12 it will be interesting to see the photos as they come 13 out.
14 MR. BRAND: Yes. I would, let me add, 15 which is partly speculation. But let's assume that 16 the inside of the fuel element was sort of evacuated 17 by steam so the melt was capable of moving down.
18 And this nozzle that you're looking at was 19 constantly being cooled by the water that's standing 20 around it. So it becomes a cooled form over the 21 aluminum for the fuel melt to solidify in.
22 CHAIRMAN REMPE: Yes. And just, again, I 23 look at lots of pictures of other fuel that has 24 degraded in melt and usually it dribbles and candles 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 down. And even, anyway, it will be interesting to see 1
how this behaves in a different way.
2 VICE CHAIRMAN KIRCHNER: Well, with the, 3
Joy, with the nozzle not in the correct position the 4
force flow is not there. There is probably 5
substantial, if not complete voiding, inside the fuel 6
element because it's canned.
7 CHAIRMAN REMPE: Yes. Well, you've seen 8
the curved plates and so yes, I get it that there is 9
a gap between the plates. But it's just interesting 10 that it made it down in such a mass.
11 But it would be interesting to see if 12 there is any sort of hold up or it just always falls 13 straight down. But anyway, it will be interesting is 14 all. Thank you.
15 VICE CHAIRMAN KIRCHNER: But this picture 16 on the right shows clearly though that the nozzle is 17 all clogged up, right?
18 MR. BRAND: Yes.
19 VICE CHAIRMAN KIRCHNER: All the melted 20 material sealed off the bottom, you know, it pooled 21 right there. Right?
22 CHAIRMAN REMPE: Yes.
23 MR. BRAND: Yes. Right above the, the 24 inside of that nozzle is cylindrical up to the point 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 where you see on the outside this conical structure 1
that leads with a bar like structure. The inside is 2
the same. There is no conical structure.
3 The presumption is, the assumption is that 4
the amount of liquid that is in there exceeds the 5
height of the cylindrical structure and actually plugs 6
into the conical structure on the inside. That's why 7
it's trapped in there. It can't get out.
8 MEMBER PETTI: Just a question. The grid 9
plate, is that aluminum as well or is it steel?
11 MEMBER PETTI: Aluminum.
12 MR. BRAND: Right, Randy? Is that 13 correct?
14 MR. STRADER: Yes, it's aluminum.
15 MR. BRAND: Okay.
16 MEMBER PETTI: Okay, thanks.
17 MR. STRADER: It's about, I think about 18 three inches. Three to four inches. I can't remember 19 exactly the dimensions.
20 MR. NEWTON: Okay. I'm going to kind of 21 shift now to root causes and corrective actions if 22 there is no more questions about the event or the fuel 23 or anything. Okay.
24 MEMBER SUNSERI: Please go ahead. Thank 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 you.
1 MR. NEWTON: All right. Okay, so shortly 2
after the event we formed a technical working group to 3
look at root causes of the event. It took us a couple 4
of months to talk to everybody and get everything 5
together.
6 And we found there were inadequacies, 7
clearly inadequacies in training and procedures of 8
fuel action. The procedures were not written well 9
enough and the training clearly was inadequate.
10 Procedure compliance was also inadequate.
11 And management oversight of the process was also 12 inadequate. So we reported that to NRC in May.
13 June we of course completed, continued to 14 investigate. We found that there was a possibility 15 that by lowering the element that the fuel handling 16 tool onto the element with sufficient force you could 17 actually inadvertently unlatch the element without 18 meaning to.
19 And the reason this is important is, part 20 of the thing we did was the height check. The height 21 latch check, which we don't do anymore, but we did do.
22 You could, in the process of doing that height check, 23 inadvertently unlatch the element. And there is some 24 speculation that this is actually what happened.
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46 Our reactor oversight committee, the 1
safety evaluation committee formed an investigation 2
after the first one was done to verify root causes, to 3
look at the response. And to review all of that and 4
look at corrective, possible corrective actions. This 5
was both internal and external folks that formed this 6
committee.
7 They completed the report in August. They 8
agreed with all of the root causes that were 9
originally found and they added two additional root 10 causes. A lack of change management program and a 11 culture of complacency and the reactor operations 12 group. They also recommended 24 corrective actions 13 and program improvements, all of which we have agreed 14 to do.
15 And amongst --
16 MEMBER SUNSERI: And I think that, excuse 17 me, Ron, I think this points to some of your questions 18 or concerns.
19 MEMBER BALLINGER: Yes, it does. I'm glad 20 that they tagged what they called a culture of 21 complacency because that's a very hard thing to deal 22 with if you have, or to understand the impact on that 23 because if nothing has happened at a plant for a very, 24 very long time, it's just natural human nature.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 And that trends, that kind of cascades 1
down to a situation where you have difficulty in 2
determining what's not normal. And generally 3
speaking, for one of these plants, at any of these 4
plants, I was operating a plant, and a wrench turner 5
for a long time, if something is not normal, it isn't 6
normal.
7 And the problem has always been, what 8
isn't normal. If you're in the plant and you know 9
something is odd, at what point do you say that it's 10 too odd. And this complacency, which is human nature, 11 I mean, goodness, really hurts in that respect.
12 MR. NEWTON: Couldn't agree more.
13 MEMBER BALLINGER: I mean, by the way, 14 it's complacency on the term of, on the point of, on 15 the part of management as well as the technical staff.
16 MR. NEWTON: That is correct.
17 CHAIRMAN REMPE: So out of curiosity, were 18 the persons involved in installing the fuel, you 19 mentioned you had some interns or trainees as well as 20 licensed staff or something. Were they experienced 21 employees or young learning employees?
22 MR. NEWTON: Well that was one of the 23 issues we had with this event is the folks that did 24 the latch checks were very junior. A couple of them 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 had never done it before. And the one that had done 1
it before had only done it a couple of times. And so 2
clearly we had some training issues that we didn't 3
foresee.
4 CHAIRMAN REMPE: Thank you.
5 MEMBER BALLINGER: This is Ron again. You 6
know as well as I do that I don't believe that this 7
kind of misplacement could happen at the MITR, am I 8
right?
9 MR. NEWTON: Well, it's a different 10 latching mechanism.
11 MEMBER BALLINGER: That's what I mean.
12 The latching mechanism. The ring that has to be 13 rotated --
14 MR. NEWTON: Yes.
15 MEMBER BALLINGER: -- simply, this simply 16 can't happen.
17 MR. NEWTON: Correct.
18 MEMBER HALNON: Tom, this is Greg. Are 19 you going to go through the corrective actions in more 20 detail or is this --
21 MR. NEWTON: No, I've got several slides 22 on corrective action.
23 MEMBER HALNON: Okay. Because I got some 24 questions that I want to kind of run through on the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 complacency relative to the actual fuel latching and 1
fuel changing process versus backing up into the 2
management culture, into the industry culture.
3 MR. NEWTON: Yes.
4 MEMBER HALNON: So I'll wait and see.
5 MR. NEWTON: Okay.
6 MEMBER HALNON: All right.
7 MR. NEWTON: Yes, I should be able to 8
address those I think. Okay.
9 First of all, management corrective 10 actions. We are doing a top to bottom change 11 management program of improvements. We have elevated 12 the aging reactor management program to include 13 tracking of overall big tracking of things that could 14 not only effective nuclear safety but other things 15 that they could, they put in their purview.
16 Organizational realignment, including 17 requiring all operators to go through a training 18 shift. This will be about a, roughly once a month 19 rotation. And all they'll be doing in that rotation 20 is training.
21 We are overhauling every single one of our 22 procedures. More than 500 procedures. And doing 23 audits of compliance to make sure folks are following 24 those new procedures. And we're vastly expanding our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 corrective action program to manage all these changes.
1 We are also establishing continuous 2
improvement program. We have required all staff, this 3
is all staff from reactor operations, reactor 4
engineering, health physics and safety to participate 5
in detailed corrective action implementation and 6
recovery tasks. They've been doing that now for a 7
year. Almost a year.
8 And it's not going to stop when we start 9
the reactor back up. Every time we identify a 10 corrective actions as part of this change management 11 program these folks will be involved in that.
12 We are instituting safety culture changes 13 throughout the organization. And that's got to be 14 integrated in our training and our procedures and 15 everything else. And we talk about that on at least 16 a weekly basis about the safety culture practices and 17 things.
18 And finally, we're benchmarking ourselves 19 with other facilities. Not only in the U.S. but also 20 around the world.
21 MEMBER PETTI: Tom?
22 MR. NEWTON: Yes.
23 MEMBER PETTI: How often was training?
24 You said you're now implementing additional shift of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 training. What was the baseline before?
1 MR. NEWTON: Well we had, of course a 2
biennial re-qualification training which was clearly 3
inadequate. And most of the other training was on the 4
job. I'll talk about that here in a little bit about 5
how we're going to fix out training program.
6 But it was a bit, say, call it an 7
apprentice program maybe that clearly didn't cover all 8
the details that were needed to cover in training.
9 And so with that, maybe I'll move on to the next 10 slide.
11 But we are now --
12 MEMBER BROWN: Before you do that?
13 MR. NEWTON: Yes.
14 MEMBER BROWN: This is Charlie Brown 15 again.
16 MR. NEWTON: Okay.
17 MEMBER BROWN: You said the training is 18 biennial. Is that every two years you're talking 19 about?
20 MR. NEWTON: Yes. That's the NRC 21 requirement.
22 MEMBER BROWN: Okay.
23 MR. NEWTON: That's the minimum.
24 MEMBER BROWN: But in that interval, new 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 people come in and out so --
1 MR. NEWTON: So that's a different 2
program.
3 MEMBER BROWN: -- training maybe for a 4
year before, I mean, how do new people get introduced 5
without going through a training program?
6 MR. NEWTON: We have a training, have and 7
have had a training program for new individuals that's 8
parts of, and we've implemented qualification cards 9
and stuff recently. And that will be implemented 10 further in our new training program.
11 But yes, it's a different program training 12 versus folks that are already licensed. And it was a 13 mix of both of those during the event.
14 MEMBER BROWN: Okay, thank you.
15 DR. SCHULTZ: Tom --
16 (Simultaneous speaking.)
17 MEMBER HALNON: Tom, this is Greg again.
18 MEMBER SUNSERI: Wait. Hold on, Greg, 19 Steve Schultz has got his hand up first.
20 MEMBER HALNON: Oh, sorry.
21 MEMBER SUNSERI: Then we'll go to you.
22 Steve?
23 DR. SCHULTZ: Tom, this is Steve Schultz.
24 The presentation here, associated with continuous 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 improvement, it mentions safety culture and 1
benchmarking with other facilities. These types of 2
programmatic features have been in the nuclear 3
industry now for over 20 years and are continuously 4
practiced at nuclear facilities.
5 Why is this coming out as an improvement 6
that needs to be done at the facility? In other 7
words, it seems like this is a new thing for the 8
facility and would suggest that you have not been, or 9
the facility, not you particularly, but the facility 10 has not been up to speed with what has been happening 11 in reactor safety practices.
12 MR. NEWTON: Well, right. Well, as Ron 13 mentioned, we have a culture, we identified a culture 14 of complacency. And you really have to step it up a 15 notch, or more than a notch, to implement all these 16 programs.
17 We did have some safety culture training 18 but it clearly was not adequate. And we weren't 19 practicing what we preached. And so we're going to 20 make sure that that is taken care of in everything we 21 do.
22 DR. SCHULTZ: Thank you.
23 MEMBER SUNSERI: Okay. Go ahead, Greg.
24 MEMBER HALNON: Yes, kind of along the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 same lines. In the commercial industry, where I came 1
from, we have a gold standard that we go to get our 2
baseline safety culture requirements, safety culture 3
stuff. And we use the INPO, Institute of Nuclear 4
Power Operators.
5 What do you guys go to? What is your 6
standard that you go to when you say, okay, I got to 7
rewrite this procedure or I got to change this 8
culture, I got to do this, where do you go to get what 9
the A+ looks like?
10 MR. NEWTON: Well we're now implementing 11 INPO 11-003, I think, in our procedures. And so we're 12 looking in the INPO guidance for safety culture and 13 procedures and things.
14 MEMBER HALNON: Okay. And you probably 15 got that through the NRC I assume.
16 MR. NEWTON: Yes.
17 MEMBER HALNON: Are you members of INPO?
18 MR. NEWTON: No, but we've gotten the, we 19 have --
20 MEMBER HALNON: Okay.
21 MR. NEWTON: -- all the documentation.
22 MEMBER HALNON: Yes. Well that's a public 23 document, that's not a problem. But I was just 24 curious.
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55 So from that perspective, the industry 1
itself has plenty of corrective action program 2
improvements and other things. And along the same 3
line that Steve was talking about, it seems like there 4
is plenty of information out there that would have, I 5
guess already been established in many nuclear 6
programs. I'm just not as familiar with these types 7
of reactors from the standpoint of that interaction.
8 And I guess just for the, when you say 9
benchmarking other facilities, what, can you give me 10 an example of what other facilities you'll be 11 benchmarking?
12 MR. NEWTON: Well, we talked to several 13 research reactors, including Dow Chemical, which has 14 a, of course, an overall safety program. We've talked 15 to ANSTO in Australia, which is also a 20 megawatt 16 reactor, about how they do things.
17 And we've reached out to a few people here 18 in there to look, and Oak Ridge National Laboratory, 19 to see how they do DOE versus DOC versus all the other 20 programs that are out there. And we're trying to do 21 what, find out what is good and strive to get there.
22 MEMBER HALNON: Okay. Have you reached 23 out to the commercial industry?
24 MR. NEWTON: Not yet. But that's also on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
56 our to-do list.
1 MEMBER HALNON: Okay. Thanks.
2 MEMBER SUNSERI: Ron has his hand up 3
again.
4 MEMBER BALLINGER: Yes, thanks. Have you 5
folks taken a look at the two reports that were 6
produced as a result of the Davis-Besse vessel head 7
incident?
8 Most people look at the Davis-Besse 9
technical root cause report with horror. But the 10 management at Davis-Besse, at the time, also did a 11 management root cause document. And it exists. You 12 got to go find it.
13 But that document might be very 14 instructive in issues of, dealing with issues of 15 complacency and operational, what do you want to call 16 it, feedback between management and the technical 17 staff. It probably is worth a read.
18 MR. NEWTON: Okay, we'll take a look at 19 that.
20 MEMBER SUNSERI: Go ahead, Tom.
21 MR. NEWTON: Okay. All right, now moving 22 on to training. We are requiring proficiency training 23 for all folks that move fuel. And that includes full 24 qualification with a qualification card. Basically 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
57 what they have to know, what they have to demonstrate.
1 And then it has to be documented before they're 2
allowed to move fuel.
3 We are rewriting all of our training 4
program for better knowledge transfers. I mentioned 5
it was previously an apprentice program which is not 6
really very effective. And so this is going to be 7
detailed training program to put in to place to 8
capture everything that people need to know.
9 Also we are, our supervisors were a bit 10 inconsistent in how they trained folks. We are now 11 developing standards for those to qualify them for 12 supervision. And also how to oversee folks.
13 And in addition to that, we're now 14 implementing periodic management reviews of the 15 effectiveness of this training program.
16 As I mentioned --
17 DR. SCHULTZ: Tom? Tom, excuse me. This 18 is Steve Schultz.
19 In reviewing the root cause report, it 20 seemed clear from the evaluations that there was a 21 substantial, or the management that was in place was 22 changing often before this event occurred. And also, 23 there were several interim positions as it was named.
24 Has that been stabilized as a part of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 this? Is there, it seems from your introductions that 1
there has been a focus on stabilizing the management 2
systems within the organization.
3 MR. NEWTON: Absolutely. Randy Strader 4
here is now permanently our chief of reactor 5
operations. And hopefully he'll be there for some 6
time.
7 DR. SCHULTZ: Thank you.
8 MR. NEWTON: Okay. Procedures. As I 9
mentioned, we are revamping all of our procedures to 10 integrate safety into them. We're revising them to 11 the INPO standard for procedures.
12 In particular we are rewriting our 13 refueling procedures. Of course we're doing all of 14 them. But the refueling procedures are much more 15 detailed now. It used to be, move fuel from A to B.
16 And now it is each detailed movement of what you have 17 to do in order to move, latch and latch check the 18 element.
19 And other part of that procedure, we're 20 rewriting the tab on reader/worker program where it is 21 a picture of the reader who is sitting outside, or 22 standing outside the reactor top area with folks 23 inside doing the refueling. So he reads the step, 24 they repeat back the step what they're going to do, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
59 they do the step and verify they've done that step.
1 And then they go back and forth and he checks off the 2
things that are all captured and done and documented.
3 MEMBER HALNON: So, Tom, this is Greg.
4 This is where I think a benchmark with the commercial 5
industry may be useful.
6 When we move fuel and latch it to pick it 7
up, there are many different measurements that are 8
taken. Weight checks, spring depression checks, 9
height checks, location. Everything that's done. And 10 if something, one little thing doesn't agree, then 11 it's all stopped.
12 And I think that the cross verification of 13 things, it looks like you're trying to build that into 14 it. You might get some really good ideas on how they 15 do that and how the communication goes with refueling 16 SROs and other people who are there for self-purpose 17 of making sure that everything agrees before anything 18 is done.
19 MR. NEWTON: That's great. Great idea.
20 We're also changing the refueling procedures to 21 require latch checks not done until the final pump 22 restart. And in addition to rotation check with a 23 verification of fiduciary art. We're also having a 24 redundant person make sure the rotation check is done 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 properly.
1 And the new thing we're doing is we're 2
requiring a visual check after all the refueling is 3
done and the latches are in place. We're going to be 4
rolling the camera into the reactor vessel, moving it 5
around to every single fuel element position. So we 6
document that on the video.
7 We then download the video and do an 8
analysis on the video to verify that each element is 9
in the latch position. That's redundantly checked by 10 another person.
11 And then after that they, during and after 12 that a video check is done there is no contact allowed 13 to the element. So we have clearly made a 14 verification that the elements are properly latched 15 prior to getting the reactor started up.
16 And equipment. This is a picture of the 17 visual checks here. This is the camera that goes into 18 the reactor.
We have tested this quite 19 satisfactorily. And we're in the process of finishing 20 up the procedures that are going to put this in place 21 for the analysis and such that we're going to be 22 implementing in the next few weeks or so.
23 We're also assessing the refueling tools.
24 One of the things that, if you read the report one of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 the refueling tools that we would replace with were 1
just a little bit different than the old tools. Which 2
created some uncertainty on the height check, the 3
height latch check.
4 We're also not going to be doing the 5
height checks anymore. So we're going to only do 6
things that completely verify the element is in a 7
latch position.
8 And one other thing we're going to be 9
implementing is the noise getting in the nuclear 10 instrument channels to take all the subjectivity about 11 whether or not a signal is normal or abnormal. This 12 is going to do a signal analysis to make sure, that 13 alerts the operator if it detects something that's 14 abnormal.
15 So now I'm going to move on to finish up 16 with our interactions with the NRC. And you're going 17 to --
18 MEMBER SUNSERI: Tom?
19 MR. NEWTON: Yes, sir.
20 VICE CHAIRMAN KIRCHNER: This is Walt 21 Kirchner. May I ask a question about, have you 22 considered any other changes to the actual reactor 23 core systems or design?
24 The first one that comes to me is that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 you're using d, heavy water for moderator. Have you 1
thought of going to light water, so to speak? You 2
give up some neutron production but you wouldn't have 3
all the tritium exposure.
4 MR. NEWTON: We can't maintain criticality 5
with light water in our current core configuration so 6
it would be a complete reactor --
7 VICE CHAIRMAN KIRCHNER: I see. Okay.
8 Thank you.
9 MR. NEWTON: Yes.
10 MEMBER SUNSERI: Steve?
11 DR. SCHULTZ: Yes. With regard to the 12 noise gate that you're developing, what do you feel 13 you can achieve with that?
14 In other words, what capability is 15 feasible that you didn't have before?
16 MR. NEWTON: Well before, as I showed what 17 the operator saw, the theory, and hopefully in 18 practice this noise gate would detect that and detect 19 that this is not a normal signal coming off of a 20 nuclear instrument. I mean, there is kind of 21 statistical noise you see on the nuclear instruments 22 but there is also things that force a different signal 23 coming out.
24 And I probably don't have, given the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 details here about how that all works. That's beyond 1
my expertise. But the folks that are doing this are 2
designing it to where it analyses the signal to detect 3
that something is not right.
4 Paul, do you want to try to help me out on 5
that one at all?
6 MR. BRAND: Sure, Tom. Paul Brand here.
7 One of the things that happens when you get a nuclear 8
signal there is just a normal proscenium statistics 9
when everything is fine.
10 If there is noise above and beyond that it 11 can do two things. First you can see that the 12 statistics is not proscenium. But there is more to 13 it. You can also do an entire Fourier analysis of 14 that signal. And look for things that are not 15 supposed to be there.
16 And you can put a trip level on that and 17 say, hey, you know right there is information of noise 18 that is not supposed to be there, give a warning to 19 the operator and force them to run down. By 20 procedure.
21 DR. SCHULTZ: Thank you. Another 22 question, Tom. Have you gone into, as a result of 23 this event, what if exercises to evaluate other types 24 of events that could happen to make sure that the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 systems instrumentation and the draining that you got 1
ongoing part of a safety culture program, but to 2
examine, so this event happened, what else could 3
happen and what are we not well protected for?
4 MR. NEWTON: Yes. We've been thinking 5
pretty hard about that for, well, the better part of 6
the year, about extent of conditions. Not just unless 7
the elements but whatever else. So yes, we're taking 8
a pretty hard look at that.
9 And not only that we're, I didn't really 10 mention this, but you're going to implement a lot more 11 drills and things for our operators to respond to.
12 Events that we didn't think we possible before.
13 DR. SCHULTZ: And that look is involving 14 the organization?
15 In other words, in safety culture training 16 it is really good to have everyone involved in these 17 investigations in the what if evaluations.
18 MR. NEWTON: Agreed.
19 DR. SCHULTZ: Thank you.
20 MR. NEWTON: Yes.
21 MEMBER SUNSERI: Tom, I have one question 22 and then we'll go to Walk next. So just to comment on 23 the noise gate. I don't know how this system works, 24 but just be cautious that any attenuation of the NI 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
65 signal doesn't affect its safety function.
1 MR. NEWTON: Yes, absolutely. It's going 2
to be completely independent.
3 MEMBER SUNSERI: Okay. Walk?
4 VICE CHAIRMAN KIRCHNER: Yes, thank you, 5
Matt. I was thinking the same thing. I was also, I 6
presume, Tom, you have like a loose parts procedures 7
or, when you do your refueling and everything else 8
you've got procedures in place that, I'm just thinking 9
of other things that like your, the event that you 10 had, anything that would lead to a flow block that 11 obviously would be the kind of thing that could result 12 in the same consequences in terms of a fuel melt and 13 such.
14 Though I would presume that there are 15 programs in place, and you're looking at your reactor 16 systems, your coolant systems to ensure that there is 17 no possibility of loose parts and other blockage.
18 Anything that could lead to a potential blockage, that 19 would be of concern.
20 MR. NEWTON: Yes. I assume you're talking 21 to me about FME, foreign material exclusion? We have, 22 yes, we have a program for that whenever we're doing 23 things on the reactor top.
24 And of course, the primary system is, for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
66 the most part, a closed system. Unless we have some 1
sort of gasket or something that gets loose.
2 And we do have a filter in the system that 3
takes up any big debris before it can actually get to 4
the core.
5 MEMBER SUNSERI: That FME becomes an 6
important question. Especially when you decide to 7
intentionally start sticking things into the reactor 8
vessel. Like cameras and stuff.
9 MR. NEWTON: Yes. We have, matter of 10 fact, I'll talk about the cleanup effort we have in a 11 minute, but we had a big FME documentation program 12 that we make sure that we're not getting things too 13 close to the reactor. Yes.
14 Okay, Greg, your hand is up?
15 MEMBER HALNON: Yes, just a couple of 16 questions. You mentioned extended condition. Did you 17 guys look back at previous corrective action program 18 items to see if there are any low events that could 19 have been an indicator that this cultural issue, 20 complacency, even equipment issues, may be something 21 that manifested itself in the past in a low level 22 event that you just didn't quite catch too because of 23 the complacency issue?
24 MR. NEWTON: Well, I guess I could say 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 there are a couple of events that we had an unlatched 1
element way back in the day. And again, we had this 2
sort of apprenticeship program to where the folks that 3
were in charge there were, it seems the folks that 4
were the experts on this system and so things were not 5
really put into place for the more junior folks. And 6
that's what we're trying to fix now. So clearly it's 7
an issue and we need to address it.
8 MEMBER HALNON: Okay. The second is on a 9
concept called extent of cause. Have you looked at 10 this root cause and the contributing causes and 11 applied it across your other programmatic aspects of 12 nuclear operations to see if there is anything else 13 that you may need to dive into to ensure that the 14 problems don't exist there?
15 MR. NEWTON: Yes. I mean, this is 16 continually, we continually look at the extent of 17 conditions of everything we have going on. And as I 18 mentioned, it's not, we're not just focused on 19 refueling we're focused on everything we do here to 20 make sure we're capturing any complacency issues and 21 things that we might identify later on as a problem.
22 MEMBER HALNON: Okay, thanks.
23 MEMBER SUNSERI: Okay, I see no questions 24 so go ahead, Tom.
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68 MR. NEWTON: All right. So again, you'll 1
hear more about this in a little bit, but the NRC 2
started their special inspection team on the 8th of 3
February last year. And they've been pretty much 4
present here daily.
5 At least we have daily stand up meetings 6
and they're either physically or virtually present for 7
that. And they're also here of course for special 8
evolutions. And so they've been a continuous presence 9
here.
10 In February through May we had several 11 written reports, which you probably have all seen 12 about exceeding the safety limit and the adequacies we 13 found.
14 In July we have started weekly phone calls 15 with the NRC management to help and exchange 16 information back and forth between what they need for 17 their programs and what we need.
18 October 1st we submitted a report of root 19 causes, plant corrective actions. And we also 20 submitted a request for permission to restart.
21 Contingent on having our corrective actions done.
22 And since then we have been working with 23 NRC with supplemental reports and furnishing 24 information for their audit process. Which they'll 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 talk about.
1 And on December 23rd we submitted our 2
license amendment request, which will codify and put 3
in concrete that we're requiring not only rotation but 4
also visual latch checks. And also the requirements 5
you don't touch anything after the visual checks are 6
done. That's going to be in the tech spec so it will 7
be a requirement from here on out.
8 Any questions on that? You'll get more 9
information for that from the NRC.
10 Just to finish up on the reactor status.
11 Currently right now 27 of the 30 fuel elements have 12 been removed from the core, including 1175, the 13 damaged element. We left three in there, two of which 14 we left in there to make sure that no debris fell down 15 to below the lower grid plate. So we're going to be, 16 probably in the next couple of weeks, removing the 17 final three as we now have finished the vessel 18 cleanup.
19 This was done late last month. There are 20 some contractors here in the picture here that are 21 using their tools to remove debris from the core. And 22 so we were able to complete that and verify the vessel 23 is clean. Which will then now start us to start the 24 primary system cleanup.
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70 And the way we're going to be doing that 1
is taking 30 out, three filter elements. Instead of 2
fuel they're going to be filters. And then we're 3
going to put them in the core into position and start 4
the primary pumps and see how that works in terms of 5
getting all the primary system, all the fission 6
product material and such in the primary system 7
cleaned out.
8 MEMBER HALNON: Tom, this is Greg. This 9
picture intrigues me. Are those lead aprons they have 10 on?
11 MR. NEWTON: I think they're just 12 containment issue aprons. I don't think they're lead.
13 I think they're, but since you're moving tools up and 14 down that have heavy water in them, you got to be 15 really careful you don't get anything on your anti-16 seize.
17 MEMBER HALNON: Okay. I don't see any 18 shielding under their feet. That was what I was 19 curious about. Is there not a very high dose rate 20 right there?
21 MR. NEWTON: Well one thing I want to 22 point out here, there is heavy water above the reactor 23 here. And since we're concerned about tritium 24 exposure and degradation of heavy water, Paul Brand 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 had a great idea to put some balls in here, some 1
plastic balls, that serve as a layer to prevent 2
interaction between the two. And they work extremely 3
well.
4 MEMBER HALNON: Okay.
5 MR. NEWTON: So I have to kudos to him for 6
that idea.
7 MEMBER HALNON: Okay, thanks.
8 MR. NEWTON: And one thing we're doing in 9
parallel is, the elements that were in the reactor at 10 the time, the undamaged elements we need to evaluate 11 for possible reuse. And the way we're going to do 12 that is we're going to reverse the flow through the 13 element and basically fill from the top to the bottom 14 to flush out any material that might be in there. And 15 then do a visual inspection and re-certification 16 before we are able to reuse the elements.
17 And then my last slide, conclusion.
18 February 3rd, as we know, was an unprecedented event 19 in U.S. research reactor history. NIST is committed 20 to get the reactor restarted when all necessary 21 corrective actions are done and the NRC agrees with 22 that and allows us to restate.
23 NIST public affairs folks have been real 24 great in terms of communication all across the board.
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72 External reviews found that the response on the day of 1
the event was appropriate, so folks did what they were 2
supposed to do.
3 And the last bullet I want to leave with 4
is, frequent open communication with NRC we believe is 5
the key to recovery and restart. So any other 6
questions for us?
7 MEMBER SUNSERI: Ron has his hand up.
8 MR. NEWTON: Okay.
9 MEMBER BALLINGER: Yes. With respect to 10 the visual inspection I guess are you assuming that 11 you can look down the element and see any blockage 12 that might be between elements, is that correct?
13 MR. NEWTON: Oh, for the reuse, yes.
14 MEMBER BALLINGER: Yes.
15 MR. NEWTON: They would actually, they've 16 got a video system set up in our spent fuel pool where 17 they can actually see all the way through the element, 18 or the channel.
19 MEMBER BALLINGER: Okay. Yes, good.
20 Thank you.
21 MEMBER SUNSERI: Members, any other 22 questions?
23 (No audible response.)
24 MEMBER SUNSERI: Well that was an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 excellent presentation. Thank you so much. And I 1
think you see that we had great interest and then a 2
lot of good questions and a lot of good answers, too.
3 Thank you.
4 Okay. At this point, Joshua, I guess we 5
transition over to the Staff.
6 MR. BORROMEO: Yes. And presenting for 7
the Staff will be Patrick Boyle, who is the Project 8
Manager for NIST.
9 MEMBER SUNSERI: Morning, Patrick.
10 MR. BOYLE: Good morning. Yes, I am going 11 to start sharing my screen here. Okay. So as Joshua 12 said I am Patrick Boyle and I am the Project Manager 13 for the NIST Facility.
14 I am in the Non-Power Production and 15 Utilization Facility Licensing Branch. My slides this 16 morning are going to cover the NRC response to an 17 event.
18 Once again it is going to be caveated by 19 the fact that the NRC response is still ongoing and we 20 don't have final statements for a number of the areas, 21 but I will cover as much as we have at this point.
22 So key messages, focusing on the safety of 23 the event. The NIST reactor is currently at safe 24 shutdown condition. As mentioned earlier, it will not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
74 restart until authorized by the Commission.
1 Also, as Tom mentioned, most of the fuel 2
has been removed from the reactor. Three elements 3
remain in place. During the event the offsite dose to 4
the public was near background levels. The radiation 5
dose to the workers during the event was also well 6
below regulatory limits.
7 The NRC did an independent evaluation of 8
the consequence event and reached the same conclusions 9
and the NRC is currently reviewing the license request 10 to restart the reactor. In addition, inspection and 11 follow-up activities are continuing.
12 So initial reaction to the NRC response 13 event, a special inspection team was assembled and 14 dispatched to the site. Shortly thereafter a 15 technical review team was assembled, and I will go 16 into more details of the functions of each one of 17 these teams in the following slides.
18 The results from the technical review will 19 inform the restart decision. So the current status, 20 the special inspection team has completed its 21 inspection activities. They are finalizing the 22 report, which is going through the concurrence 23 process.
24 The technical team has looked at the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 corrective actions, cleanup activities, and is 1
currently working to obtain additional information as 2
to inform the restart review decision and then 3
additional inspection activities will continue, 4
including onsite inspections prior to and following 5
any authorized restart.
6 So the event itself, NIST reported to the 7
NRC partial melting of one element. The safety limit 8
in the technical specifications at NIST indicates the 9
fuel cladding temperature not exceed 842 degrees and 10 since the melting occurred that fuel temperature was 11 clearly exceeded.
12 The NIST reported very limited 13 radiological release during the event. The NRC 14 compared the event to the radiological dose 15 consequence to the accident analysis in a safety 16 analysis report and specifically we looked at the 17 maximum hypothetical accident.
18 So I'll take a minute and explain what 19 that is for research reactors, because this is not 20 something that you would experience in the power 21 reactor environment.
22 So NUREG-1537, Part 2, which provides the 23 Standard Review Plan and acceptance criteria for 24 licensing non-power reactors, within that we have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 Chapter 13 which discusses the different accident 1
scenarios included with the maximum hypothetical 2
accident.
3 That is done as a bonding worst case 4
scenario. And so you look at what can possibly go 5
wrong. You don't necessarily find any credible 6
initiating event so that's why we call it maximum 7
hypothetical accident.
8 So for NIST the maximum hypothetical 9
accident within their safety analysis report is 10 complete blockage of flow to one fuel element by 11 unspecified means and then certain assumptions are 12 made related to what the potential dose consequence 13 could be, including that all the noble gas fission 14 products are assumed to be released in primary coolant 15 and quickly go into that helium space that we talked 16 about earlier.
17 So that's that cover gas but then that 18 transmits into the exhaust system and then the exhaust 19 system itself will isolate, which Tom had mentioned 20 earlier.
21 Looking at that performing analysis for 22 the license of the facility, the maximum expected dose 23 to the public with all the limiting assumptions in 24 place would be 6.4 millirem.
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77 So what actually happened? There was flow 1
blocked to one element. There was at least some 2
partial melting of the fuel as evidenced by the visual 3
inspections that Tom showed earlier.
4 Also identified in the fission product 5
stack monitor was noble gases, specifically the 6
presence of krypton, and there was also the dose 7
calculation performed by NIST and confirmed by the NRC 8
Staff that they were well below the potential release 9
limits for the maximum hypothetical accident.
10 So the maximum hypothetical accident in 11 the license and the safety analysis report bounds the 12 actual event that occurred. So we also --
13 (Simultaneous speaking.)
14 MEMBER SUNSERI: Patrick, we have a 15 comment or a question from Ron Ballinger.
16 MR. BOYLE: Okay. Sorry. Yes, I'm sorry 17 I can't see --
18 (Simultaneous speaking.)
19 MEMBER BALLINGER: Yes, sorry.
20 MEMBER SUNSERI: Yes, no, that's okay. I 21 am the air traffic controller for this so I'll keep 22 you on.
23 MR. BOYLE: Thank you. Okay.
24 MEMBER BALLINGER: It appears to me that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 you now have a benchmark where you can compare the 1
dose rate from the actual maximum hypothetical 2
accident to what actually happened.
3 Have you thought about doing that scaling 4
to see what the dose would actually be for a complete 5
melting to see how close you would have been to the 6
artificial limit?
7 MR. BOYLE: Yes, that's a good question, 8
and there are a number of aspects to consider for that 9
while looking at theoretical versus an actual 10 measurement.
11 First of all, we don't know how much of 12 the fuel actually melted. That may not be determined 13 for a number of years because we have to find a way to 14 transport and then basically do some type of PIE on 15 that to determine how much actually melted and then we 16 could ratio from there.
17 The other assumptions, and the reason why 18 the dose consequence is actually much lower than the 19 theoretical is we take all the limiting conditions, we 20 assume full power operation for extended time, we 21 assume a maximum burned element, we assumed the 22 highest power location.
23 So all of those factors do create a 24 bounding condition versus an actual and if we were 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 trying to make this an accident that is, you would 1
have an initiating event and make it a maximum 2
credible accident then we would be trying to do some 3
kind of closer alignment to the actual consequence 4
from this event versus what is analyzed.
5 But the fact that it's a hypothetical 6
accident there is a lot of margin and the intention is 7
to maintain that because that's kind of the licensing 8
philosophy for further research reactors.
9 MEMBER BALLINGER: Yes, it just seems like 10 you've dodged a bullet and you've got a data point 11 which you don't often get.
12 MR. BOYLE: That's correct, yes. Really, 13 personally, I'd rather not have this data point.
14 MEMBER BALLINGER: Some days chickens, 15 some days feathers.
16 MR. BOYLE: Yes, there we go.
17 MEMBER SUNSERI: Okay. We have Walt has 18 a question. Go ahead, Walt.
19 VICE CHAIRMAN KIRCHNER: Yes. Patrick, as 20 a result of this, obviously, the offsite dose was kept 21 quite low because the ventilation system isolated it.
22 Have you looked at that system and to what 23 extent is that as in a power reactor system and 24 accident sequences where you make an assumption of a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 single failure, what if that ventilation system didn't 1
isolate, what would the dose have been offsite?
2 MR. BOYLE: Yes. And that's -- You're 3
right. That's one of the other assumptions within the 4
safety analysis for the facility.
5 We only take credit for the systems that 6
are required to be operational at the facility. So 7
once again you have the items you put in place to 8
reduce the release during the event, but you only take 9
credit for the items that you require in technical 10 specification.
11 So the intention is to really build a lot 12 of margin into the non-credited systems so that you 13 are not challenging your release limits.
14 MEMBER SUNSERI: Okay. You okay, Walt?
15 VICE CHAIRMAN KIRCHNER: Yes. Thank you.
16 I will think further about that aspect of the system, 17 you know.
18 MR. BOYLE: Yes. Right. Right. Right, 19 and that's part of the non-power licensing approach.
20 MEMBER SUNSERI: All right, I don't see 21 other hands. Go ahead.
22 MR. BOYLE: Are we good with questions 23 here? I'm sorry, I'm going to have to keep pausing.
24 MEMBER SUNSERI: Yes.
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81 MR. BOYLE: When you present you don't 1
really see the rest of the Teams stuff, so --
2 MEMBER SUNSERI: Yes, yes. No, no, that's 3
fine. Just when you go from slide to slide just 4
briefly pause between slides and that will help.
5 MR. BOYLE: Okay. No problem. So it was 6
mentioned earlier NIST cannot restart until authorized 7
by the Commission.
8 So these are the regulations that are in 9
place that relate to that. So we have 10 CFR 50.36 10 which identifies the technical specifications and the 11 requirement to have a safety limit, and then within 12 50.36 if the safety limit is exceeded the reactor must 13 be shut down, licensee shall notify the Commission, 14 review the event, including the causing condition, 15 root cause, you know, extent of corrective actions, 16 take the precluding recurrence, and then operation 17 must not resume until authorized by the Commission.
18 So that is right in the regulations.
19 So to review, the request that came in by 20 NIST, actually even before that, we put a team in 21 place to look at the event in great detail and then 22 this team has continued to work with looking at the 23 event itself, the cleanup evolution, the corrective 24 actions, and proposed restart activities.
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82 And we have pulled from a number of 1
divisions, including the non-power division, the 2
safety system. These are all within the Office of 3
Nuclear Reactor Regulation.
4 The additional review in the areas we were 5
kind of primarily focused on is like the reactor 6
vessel internals. We are taking a good look at what 7
that cleanup means.
8 We are looking at, you know, things 9
potentially involved with, you know, what happens when 10 the hot aluminum hit the lower grid and is there any 11 other potential damages, so things of that nature.
12 We are looking at the potential impacts to 13 the coolant system. We are looking at, you know, what 14 about the fuel that was in the reactor that is going 15 to be re-used.
16 So we are looking at NIST has to evaluate 17 this, provide their review and their acceptance of the 18 results, and then the NRC Staff will review that.
19 Questions?
20 MEMBER SUNSERI: Yes. Jose March-Leuba 21 has a question.
22 MR. BOYLE: Okay, go ahead.
23 MEMBER MARCH-LEUBA: Thank you. Yes, I 24 agree that it's really good that, one, the public was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 never at risk, I mean the dose outside, the boundary 1
was really low, but the control room had to be 2
evacuated.
3 Is there anything in the regulations or 4
anything that you can see there to improve the 5
ventilation of the control room? Because I mean all 6
of the reactors we have seen are designed to have 7
input for the ventilation system from the outside and 8
they have two, one in the north and one in the south, 9
and they pick the one that is cleaner. So can you 10 talk about that?
11 MR. BOYLE: Yes, I can actually talk about 12 that, just about non-power reactors in general. It is 13 very common for the control room to be in a common 14 environment with the reactor itself.
15 I can speak specifically, I worked at the 16 Penn State Research Reactor for a number of years as 17 a senior operator there and the entry to the control 18 room was through the reactor bay.
19 So if you got a high radiation alarm and 20 you needed to exit the facility you did have a short 21 pathway through that and you would have access to a 22 remote readout looking at the radiation and nuclear 23 instrumentations at a remote panel.
24 But that's a common design for the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
84 research reactors and the potential exposure to the 1
operator is included in the safety analysis and you 2
have to demonstrate that you make assumptions related 3
to the amount of time it takes to exit the facility 4
and what the personnel exposure looks like.
5 So I agree if you are used a power plant 6
where you have an isolated control room with 7
habitability requirements. Those do not exist for 8
research reactors and the reason is the very low 9
source term and the ability to properly exit without 10 consequence to the safety and recovery of the event.
11 MEMBER SUNSERI: And Greg has his hand up.
12 MR. BOYLE: Okay, go on.
13 MEMBER HALNON: Yes.
14 MEMBER SUNSERI: One more question. Greg.
15 MEMBER HALNON: Yes, a couple. I wanted 16 to talk a little bit about, and I think it might be 17 more appropriate down the road here, but I'll ask this 18 question first.
19 You know, the corresponding, if you had a 20 corresponding event in the commercial reactor world we 21 would be in a huge, huge programmatic aspect to get 22 that solved throughout the industry, to take a look at 23 it. IMPO would be going crazy with their industry 24 documents and inspections or assessments and whatnot.
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85 And I understand that this has got a very 1
low consequence to the public and relatively 2
straightforward, but does the NRC feel that the 3
industry response, the research reactor industry, is 4
taking this serious enough to look at their own 5
programs throughout the country to make sure that they 6
don't have the same types of problems going on?
7 MR. BOYLE: I think the bigger picture 8
related to the cultures that can develop at a small 9
facility and the problems associated with turnover of 10 facilities who have, you know, not a large number of 11 personnel and they are there for a long period of time 12 and then they transition away and you have new people 13 coming in that don't necessarily have that depth of 14 experience.
15 So that is definitely a good area for the 16 remaining of the research reactor community to focus 17 upon. I do believe we do have some information we are 18 going to share with that coming out of this event, but 19 just in general looking at trend within the other 20 research reactors and looking at the challenges to 21 maintaining staff.
22 I mean I know this discussion is primarily 23 focused on NIST, but we do have a couple other 24 facilities that are going through personnel changes 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 where they actually don't have any current license 1
reactor operators and they have their cold license.
2 And if the facility has been in place for 3
30 years but they had a transition of the two or three 4
people that were responsible for operating the reactor 5
and ended up getting in a situation where they don't 6
have anybody currently licensed for that facility it 7
is -- So that is a unique aspect to the community and 8
that is definitely an area of focus going forward.
9 MEMBER HALNON: Okay. Have you guys put 10 any generic communications out on this at all?
11 MR. BOYLE: Not at this point.
12 MEMBER HALNON: All right. Do you have 13 any plans to?
14 MR. BOYLE: Josh? Lifeline.
15 MR. BORROMEO: This is Josh Borromeo, 16 Chief of the NPUF Licensing Branch. So taking a look 17 at a generic communication is something that we have 18 built into our project, our restart action plan 19 project plan, right.
20 But at this time we are still completing 21 our SIT inspection and out of that, right, I think the 22 community, the research test reactor community, is 23 going to become more aware of the issues that happened 24 at NIST, right, but we haven't yet released that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
87 report.
1 It's coming soon, but we haven't released 2
that publicly yet. So a short answer is we are still 3
evaluating whether or not a generic communication is 4
appropriate for this type of event.
5 MEMBER HALNON: Okay. Thanks, Josh.
6 MEMBER SUNSERI: We have a couple of 7
questions that have prompted up. We will go with 8
Charles Brown first.
9 MR. BOYLE: Okay.
10 MEMBER BROWN: I went back and looked at 11 the backup slide from NIST, the number, I think it was 12 the last slide on the operator experience.
13 MR. BOYLE: Yes, I have seen that.
14 MEMBER BROWN: It looks to me like there 15 was a lot of clues five years ago of significance, you 16 had a significant start of reduction of experienced 17 SROs and fairly less than half have maybe experience 18 as of the last, when this occurred.
19 I mean there was a significant falloff.
20 If you look at the other graph on the left-hand side 21
-- I don't know whether you can put that one back up 22 or not so that the other --
23 MR. BOYLE: Yes. If I stop sharing I can 24 let Tom put that one up. So we can go ahead and do 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 that.
1 MEMBER BROWN: Their 32nd slide, Number 2
32.
3 MR. NEWTON: I'm on it. I'll get it right 4
in a minute.
5 MR. BOYLE: Okay. Thanks, Tom.
6 MR. NEWTON: Okay. Oh, of course, it went 7
to the wrong spot. Oh, crap. All right, I'll try 8
this again. Okay. Do you see -- Maybe I forgot to 9
share it. Can you see that or not?
10 MEMBER BROWN: No, not yet.
11 MR. NEWTON: Okay. Let me try this again.
12 MEMBER SUNSERI: I think Patrick may have 13 to un-share his screen to allow you to share.
14 MEMBER BROWN: Oh, there it is.
15 MR. BOYLE: Yes, I think I already did.
16 MR. NEWTON: Yes. You got it now?
17 MEMBER BROWN: I don't know. Maybe, you 18 know, I am not Greg, I am not Matt, I don't have their 19 commercial experience, but just looking at the trend 20 in the right-hand slide and then you compare that also 21 with the data that you have, does NRC ever look at or 22 evaluate periodically how these plants and test 23 reactors are being staffed?
24 That's terrible when you look at what 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
89 happened on the 4th, that the level of experience, 1
supervisor's experience, number of -- I mean it seems 2
to me that there was a precursor somewhere along here 3
and that indicates something and it's before COVID 4
even had started.
5 MR. NEWTON: Well that's not true, but --
6 MEMBER BROWN: Well that's what it looks 7
like. Tell me why it's not true.
8 MR. NEWTON: Well, I mean COVID started 9
actually in Fiscal '20, but the point here and on the 10 4th of February, this is the crew that actually did 11 the last checks. This isn't the entire crew, so it's 12 a little bit misleading here.
13 But, yes, we clearly had a drop off of 14 experience starting about 2018/2019 that we didn't --
15 We had a lot of people that retired so the experience 16 level went quite a bit down.
17 MEMBER BROWN: You all actively recruit 18 Navy experience people? I kind of gathered that if 19 you look over from FY, for Fiscal Year '09 through 20 about '15 and then you started looking, seeing a 21 gradual decreasing of people that actually ran real 22 power reactors.
23 MR. NEWTON: Yes, we do active recruitment 24 of Navy folks. Unfortunately, they can earn more 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
90 money elsewhere and so that's a big factor. We 1
struggle to get qualified folks.
2 (Simultaneous speaking.)
3 MEMBER SUNSERI: I think, Charlie, your 4
point here is is that, you know, this is the part of 5
the management complacency, right, looking at all this 6
stuff and making sure that you take mitigation actions 7
in shrinking your safety culture and procedures and to 8
-- There is all kinds of tools that offset various 9
experience levels, but this was like the perfect 10 storm, everything converged together on these guys, so 11 12 MEMBER BROWN: Yes.
13 DR. BLEY: Yes, this is Dennis. You know, 14 Charlie, well you guys didn't tell us, but the number 15 of people who are part of the operating crew for small 16 research reactors is pretty small and they tend to 17 stay there a very long time. I think that's what you 18 see here, they drop off.
19 But even in an organization as big as the 20 nuclear Navy was, I remember back in the '70s the Navy 21 prevented, which the research folks can't do, 22 prevented a significant number of senior lieutenant 23 commanders from leaving their program in the Navy for 24 several years because the same thing kind of was going 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 to happen there.
1 But when you have a very small number of 2
people and they all kind of started at the same time 3
and stayed around this sort of thing can happen. I'm 4
not sure it's complacency. I think it's probably just 5
aging of the crews probably, and supervisors.
6 MEMBER SUNSERI: Yes. I mean the -- My 7
point was that the attrition is not due to 8
complacency, but the response to the attrition could 9
be. That's all I was suggesting.
10 MEMBER BROWN: Can I make one observation, 11 Matt, and I'll be quiet?
12 MEMBER SUNSERI: Yes.
13 MEMBER BROWN: I got in the naval nuclear 14 program in 1965 and back in those days we had fewer 15 plants operationally and the headquarters actually 16 conducted crew examinations periodically.
17 And in that timeframe as the plants 18 increased we had to change that, that's why we 19 implemented, I have forgotten what they are called 20 now, but it's a Navy-run examination crew that comes 21 through periodically and examines all the crews, 22 because we just couldn't handle it from headquarters.
23 The only time we were able to do it after 24 that was before an initial startup after a refueling.
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92 So the operator attention and people checking their 1
status and qualifications and their knowledge is a 2
pretty important item to me.
3 So, Dennis, I don't know whether that --
4 You were on the Enterprise, what, in the '70s?
5 DR. BLEY: I went in in '69 and I was 6
there in the early '70s.
7 MEMBER BROWN: Do you remember when the 8
Propulsion Plan Examining Board started?
9 DR. BLEY: No, that was after me. We 10 still had you guys coming out.
11 MEMBER BROWN: Yes, that's -- Exactly.
12 And we recognized that. I am just wondering if NRC --
13 I don't know how many test reactors are out there. I 14 am just -- Operator experience is very important.
15 We recognized it at -- Rickover went non-16 linear when we had to start giving that up somewhat.
17 I won't -- When I say "non-linear," he was very 18 attentive, let's put it that way. I got that from 19 personal experience, but much later.
20 So, anyway, it's just a clue. That's all 21 I am looking -- I am just trying to give NRC an idea 22 that maybe there is something else that people need to 23 look at for these plants to see if there is a trend 24 that we may be able to try to catch some of this stuff 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
93 in advance, that's all, from a training qualification 1
complacency.
2 It's just another factor when you look at 3
something like this happening on those two graphs 4
relative to experience and the number, put aside the 5
1-4 thing, but the numbers back in FY '20 and '21.
6 That's a pretty significant degradation of 7
experience. So, anyway, I'll stop now. It's just 8
something to think about.
9 MEMBER SUNSERI: Ron, you have a question?
10 MEMBER BALLINGER: Yes. Charlie will 11 probably remember what happened when the Admiral 12 instituted what he called verbatim compliance, but 13 that's another story.
14 My comment is that has this incident been 15 discussed at the other facilities? Because a plant 16 like HFIR, if they lose cooling for even a second they 17 are in big trouble with their fuel.
18 It seemed to me like this fuel got into 19 trouble in a pretty short period of time. Like Walt 20 was concerned about flow restrictions and things like 21 that are probably doubly or triply important for 22 something like HFIR.
23 MEMBER SUNSERI: Is that a question or 24 just a comment?
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94 MEMBER BALLINGER: Well, I guess it's just 1
a comment.
2 MEMBER SUNSERI: Okay.
3 DR. BLEY: We did some work with HFIR, 4
Ron. I don't know if you know it, but the designers 5
expected a core melt every three or four years so they 6
designed for that.
7 MEMBER BALLINGER:
That's what I
8 understand.
9 MEMBER SUNSERI: Okay.
10 MR. BORROMEO: So this is Josh Borromeo 11 again. Maybe Tom can correct me if I am wrong, but we 12 did present this event, or at least some aspects of 13 it, at the Research and Test Reactor Annual Conference 14 back in October of this year.
15 I believe there was an ANS conference as 16 well where we discussed this. Actually, next week at 17 the RIC we have another presentation on the NIST event 18 where NIST will be presenting as well as the NRC 19 Staff.
20 So there are upcoming engagements where we 21 are going to be discussing this event. Also, once we 22 release the SIT report we will have a public meeting 23 regarding that.
24 So there is going to be opportunities to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
95 socialize this external to the Agency that the RTR 1
community can participate in.
2 MEMBER BROWN: Is the Agency going to do 3
-- This is Charlie again. I guess in my old job years 4
and years ago if we had had like Ron talked about the 5
one plant, do you anticipate now going back to all the 6
other research reactors that are run by all the 7
universities and checking to see, doing kind of a 8
retrench or are just only focused on this and 9
everybody else keeps on operating?
10 MR. BORROMEO: Yes, so I think this kind 11 of gets back to the other question before, right. So 12 right now we are focused on NIST, right, what 13 happened, understanding the root causes, understanding 14 the corrective actions.
15 But as part of our plan we are going to 16 take a look and see if there is any sort of generic 17 implications that need to be shared with the community 18 to ensure, right, that any sort of similarities 19 between the event, you know, between the facilities, 20 are repeated at other reactors.
21 MR. BOYLE: Yes. And this is Patrick 22 again. I do want to focus on two aspects of this 23 potential impact for other non-power facilities.
24 You did mention the DOE facilities, which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
96 the NRC doesn't license, but we do share information 1
with them related to safety and operation of the 2
facilities.
3 The other thing to bear in mind is this is 4
the highest power research reactor currently 5
operating, well, I'm sorry, test reactor technically, 6
the highest power non-power facility operating in the 7
United States at this time.
8 The bulk of the other facilities don't 9
even have coolant pumps, they run on natural 10 circulation. We have about, I can't remember off the 11 top of my head, I think four that use force flow and 12 only RMIT, NIST are the high power reactors, meaning 13 greater than one megawatt.
14 Most facilities are one megawatt or less 15 and they run on natural convection and cooling can 16 occur in air with the fuel at equilibrium conditions.
17 So that is -- It does create some perspective for the 18 other facilities, but also recognize the questions 19 being asked are related to management and that applies 20 to all facilities. Greg, I see you have a question.
21 MEMBER HALNON: Yes. Since we're just 22 kind of freewheeling it here, I'm not sure exactly 23 where this was going to fit, but from an NRC routine 24 inspection perspective what in the inspection program 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
97 allowed this facility to establish a culture of 1
complacency, inadequate safety culture, inadequate 2
training, inadequate procedures.
3 Did you look back at your own inspection 4
program to see how this -- And I go back to earlier 5
Ron mentioned Davis-Besse and since I worked there 6
after the accident there I was very intimately 7
involved with the management aspect of the root cause 8
and whatnot and the NRC also did a root cause looking 9
at their own programs to figure out what they missed.
10 Did you do that here as well?
11 MR. BOYLE: I'm going to ask Travis to 12 speak to that. He is the Branch Chief for the 13 Oversight Branch of non-power facilities.
14 MR. TATE: Yes. So this is, as Patrick 15 said, this is Travis Tate. I am the Branch Chief that 16 has the inspections for the RTR facilities.
17 To answer your question, we are focused 18 currently on NIST but we are taking a look and plan to 19 take a look at our programs and, you know, after the 20 end and after we get through the NIST evaluation.
21 We want to make sure that we have a 22 holistic look at everything before we engage in that.
23 I say that, but we are, you know, starting to collect 24 things that we need to look at as part of our program 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 to evaluate if there are any changes that we need to 1
make.
2 MEMBER HALNON: Okay. Do you even --
3 Travis, do you -- And I appreciate that. I think 4
that's the right thing to do. It's been a year since 5
the event. Have you guys looked back to see what you 6
missed?
7 I mean these are pretty significant 8
cultural management issues that just didn't happen 9
overnight. Did you look back at your previous 10 inspection results from a
routine inspection 11 perspective and see if there was something that was 12 indicating it that you missed or that maybe the 13 program was clearly inadequate to inspect or anything 14 around those types of questions?
15 MR. TATE: Yes, you're right on, and 16 that's what I was kind of alluding to in my response 17 is one of the things that I have asked the Staff to do 18 is to pull, look at prior inspections to see if there 19 was anything there.
20 MEMBER HALNON:
Okay.
So that 21 introspective look is still to be done then?
22 MR. TATE: That's correct.
23 MEMBER HALNON: Okay.
24 MEMBER SUNSERI: Please continue, Patrick.
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99 Thank you.
1 MR. BOYLE: Okay. I'm going to show our 2
slides again here. Okay. So I was up to the 3
identifying of the different, just the breadth of the 4
restart review team looking at aspects associated with 5
the restart request, the corrective actions.
6 So at this point, you know, as Tom 7
indicated earlier back in back in October NIST 8
submitted a restart request to the NRC but they had a 9
big IOU with that.
10 So it's actually very helpful in the fact 11 that the NRC Staff is able to see what NIST plans to 12 inspect and confirm and evaluate and it provides us, 13 meaning the NRC Staff, the time to look at those 14 results in real time and determine if there will be 15 enough information to help us support a restart 16 decision.
17 So if there are any areas where we need 18 additional information we have an audit process that 19 is open, it allows us to ask questions, and then the 20 NIST can share detailed responses to us and when we 21 determine information that is necessary for the 22 restart decision we will ask NIST to place that 23 specifically on the docket so it's publicly available 24 to everyone to understand what the NRC Staff reviewed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 and how that information was used to make the restart 1
decision.
2 So the next steps, we are continuing with 3
looking at the inspection results that NIST is 4
performing, all of the fuel and components and the 5
analyses and looking at the results that NIST is 6
receiving and seeing if it is consistent with our 7
understanding of the materials involved.
8 And, also, the oversight process is 9
continuing, so we are wrapping up the SIT currently, 10 but we are going to continue with additional 11 inspections and have follow-up inspections and 12 potentially a restart inspection team.
13 So in summary, NIST and event recovery 14 still proceeding with the cleanup activities, 15 inspection activities are planned, and they are 16 inspecting the materials that they have.
17 NRC approval is required for restart.
18 Once again, as we discussed several times, the actual 19 event release was a small fraction of regulatory 20 limits and well within the safety analysis performed 21 for the facility.
22 The NRC will continue its inspection 23 activities prior to and following the restart, and, 24 once again, the authorization to restart will not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
101 occur until the NRC has determined that it will remain 1
protective of the public health and safety, basically 2
the reactor is restored to its design basis.
3 So that's my formal presentation. You've 4
been pretty good about questions so far. Anymore at 5
this point?
6 MEMBER REMPE: This is Joy. I apologize 7
because I got distracted with another activity on 8
ACRS, but I noticed in your presentation that you 9
said, hey, there is visual evidence of what is molten 10 material and I recall hearing during this presentation 11 from either your or NIST about the fuel assemblies 12 being reviewed.
13 Is there a document somewhere that shows 14 some of the images that have been obtained of the 15 assemblies that were damaged that way we can get some 16 more idea of how the melt progression went?
17 MR. BOYLE: I'm trying to think how much 18 of that has been released to date. We are still 19 putting together the special inspection report and I 20 think that might be a place where some of that could 21 be included.
22 Also, we are developing the technical 23 evaluation reports supporting the restart decision and 24 if a visual item is useful for conveying the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
102 information we would probably include it in that 1
location.
2 But I don't know if there is any plan at 3
this point to release the image it captures so far.
4 So does anybody else on the team know that?
5 MEMBER REMPE: Or even from the NIST 6
folks. Again, I just am wondering if some of that 7
information could be sent to Kent Howard because of my 8
personal interest and your inspection report, too, 9
that includes any of these images I would like a copy.
10 MR. NEWTON: We can certainly share them.
11 We have not put them on the docket from NRC. There 12 may be some images from the ANS meeting or something, 13 but we could certainly share them with the ACRS folks.
14 MEMBER REMPE: I would appreciate it. And 15 just send it to Kent and he will forward it to us.
16 Thank you.
17 MEMBER SUNSERI: All right. We have 18 Stephen Schultz then Greg then Walt, in that order.
19 DR. SCHULTZ: Patrick, I didn't quite 20 catch, have you established the restart inspection 21 team? It seems like continuity would be important to 22 have a team available that has been following, the 23 whole team who has been following this carefully.
24 You definitely have a large organizational 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
103 setup to examine this in not much detail but in terms 1
of the evaluation of corrective actions and the 2
evaluation of what needs to be done before and during 3
and after restart would be important to have a 4
dedicated team associated with that.
5 (Simultaneous speaking.)
6 MR. BOYLE: Yes, I'll let Travis speak to 7
that.
8 MR. TATE: Yes, this is Travis. You are 9
absolutely correct. We are working at this moment 10 trying to, looking at the corrective actions, looking 11 at our inspection findings, and the various other 12 sources of information to identify, you know, what are 13 the corrective actions that we need to look at to 14 inform the restart decision as well as any ongoing 15 inspections that we maybe, you know, need to look at, 16 you know, even after, you know, if we were to 17 authorize restart, you know, what we would we need to 18 look at from an inspection standpoint going forward.
19 Because I think you guys have kind of 20 honed in on some of the issues that was raised by NIST 21 are some issues that are long-term kind of fixes that 22 need to be done with the management and the operations 23 of the facility, and so we are putting that together 24 now. We are putting together a team.
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104 Our special inspection lead for NIST is 1
the assigned NIST regular inspector of the facility so 2
he will provide a lot of continuity between the 3
special inspection and any future inspections.
4 DR. SCHULTZ: Thank you, Travis. I 5
appreciate that evaluation. Also, I just wanted to 6
comment I am pleased to see that this is going to be 7
presented by both organizations at the Regulatory 8
Information Conference.
9 I think that's an ideal way to communicate 10 with industry on this issue/event and its recovery.
11 Thank you.
12 MR. TATE: Yes. And I would add to that, 13 as was mentioned, we also participated in an ANS 14 conference where NIST spoke and I did a presentation 15 on our activities as well.
16 That panel also included the DOE folks 17 that were involved with the HFIR facility event that 18 happened. So it was a good panel to share information 19 for events like this.
20 DR. SCHULTZ: Very good. Thank you.
21 MEMBER SUNSERI: Okay. We'll go to Greg 22 next.
23 MEMBER HALNON: Yes. This is sort of a 24 tossup. First, Tom, if you would address it and then 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
105 maybe the NRC folks, either Joshua or Patrick.
1 How was the reaction from the public? Now 2
understanding that it was somewhat squashed because of 3
the pandemic, but what kind of feedback did you get 4
from the public from the initiation of the alert 5
through the next couple months after that?
6 MR. NEWTON: Well the NIST public affairs 7
folks kind of handled all that. We had a town hall 8
meeting I think a couple of weeks later, which was 9
well attended by, at least for the neighbors, that the 10 NIST director spoke at and an NRC representative was 11 there as well to talk about the event.
12 So we have had a pretty good relationship 13 with the public and we have been doing everything we 14 can to put things out there for public dissemination.
15 MEMBER HALNON: Did you get a lot of 16 reaction? I mean was there a concern of dose rates 17 and issues, maybe things that didn't get communicated 18 real well previous, prior to the event or anything 19 like that?
20 MR. NEWTON: We had some early inquiries 21 and stuff, which we answered kind of, you know, if 22 we'd get an email or something we would answer through 23 the Public Affairs Office, so there was some concern 24 but it wasn't anything we couldn't handle.
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106 MEMBER HALNON: Okay.
1 MR. NEWTON: Rob, was there anything else 2
you would like to discuss on that?
3 MR. DIMEO: Obviously when this happened 4
there was a NIST announcement that went public 5
describing the event as all the facts were known on 6
the day of it, on February 3rd, and that was followed 7
up by subsequent public announcements.
8 There was quite a bit of public interest, 9
especially by the surrounding communities. As Tom 10 mentioned, we scheduled a town hall with the public.
11 I think it was the following week.
12 The NIST acting director was present, 13 myself, and the radiation safety officer from NIST was 14 present as well, along with representatives from the 15 NRC.
16 There were a lot of questions that came in 17 and I believe we were able to effectively answer them.
18 It was a huge help to have the NRC there from the 19 regulatory perspective to provide their feedback as 20 well.
21 And we have been tracking the public 22 interest from the perspective of inquiries that have 23 come in to NIST over time and when there has been a 24 release, for example when we had notified the NRC of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
107 exceeding the safety limit on the fuel element, when 1
the interim NRC report was released, and other 2
subsequent public announcements, when we made those 3
there was renewed interest but not nearly the same 4
that there was on the first, at the initial incident 5
time. It has gradually -- It has subsided over time.
6 There don't seem to be any remaining 7
questions other than there remains a public interest 8
once we would get that authorization to restart the 9
reactor to hold another public meeting with them, 10 likely with the senior NIST leadership as well, to 11 have a conversation with the public to address any 12 concerns that they might have.
13 MEMBER HALNON: Good. Appreciate that.
14 Anything from the NRC side that you guys have received 15 from the public or otherwise relative to the public 16 response?
17 MR. TATE: Yes, this is Travis.
18 (Simultaneous speaking.)
19 MR. TATE: Oh, Josh. Yes, I would say 20 that what Rob said has been consistent with what we 21 saw, a lot of initial public interest immediately 22 after the event and a lot of communications.
23 We work closely with our Office of Public 24 Affairs and, you know, issued, there were social media 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
108 tweets and things like that that we issued working 1
with Public Affairs and Congressional Affairs.
2 There was a lot of interest, you know, 3
throughout this past year. We have had a few 4
briefings of congressional staff members as well.
5 But, yes, there was a lot of initial -- And, you know, 6
considering where NIST is located, as you can imagine, 7
there was a lot of interest inside the NRC from 8
employees as well.
9 MEMBER HALNON: Yes, I can imagine. Local 10 government, did you get any interaction or any 11 inquiries from the local government? Did they 12 exercise their emergency plan annex for radiological 13 emergencies or do you know of any details there?
14 MR. TATE: So most of that coordination 15 with the local governments is done through our Region 16 I office and I don't think, I'm not sure if anyone is 17 on the call from our Region I.
18 The State Liaison Office in Region I does 19 that coordination. I know that they were in contact 20 with the State, but I am not aware if the State 21 exercised in anything other than awareness of what was 22 going on with the event.
23 MEMBER HALNON: Okay. I would appreciate 24 any feedback that you might get, if you could check 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
109 with the Region I office.
1 I am interested if any portions of either 2
the local or State plans were implemented in their 3
radiological annex of their all hazards plans.
4 MR. TATE: Will do.
5 MEMBER HALNON: Thank you.
6 MEMBER SUNSERI: So we'll just ask Kent 7
Howard, our BFO, to follow up with you on that, okay.
8 MR. TATE: Okay, great. Thanks.
9 MEMBER SUNSERI: And, Walt Kirchner.
10 VICE CHAIRMAN KIRCHNER: Yes. I have one 11 question and then two observations if I might, Matt.
12 The first, the question is given that the confinement 13 system functioned and prevented a more serious event 14 in terms of consequence and release, have you looked 15 at, are there any design improvements in terms of 16 resiliency, redundancy, or safety-related functions 17 for the confinement system and the vent, such as 18 hardening the vent or redundant measures to ensure the 19 functionality of that in an event like this?
20 Is there anything along those lines in 21 terms of design changes envisioned for the confinement 22 system?
23 MR. NEWTON: Well not at this time. As I 24 mentioned, as had been mentioned, everything 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
110 functioned like it was supposed to. We do have some 1
redundancy built in to the confinement system and it 2
all functioned quite well.
3 So we're not looking at any changes right 4
now because we haven't identified any weaknesses.
5 VICE CHAIRMAN KIRCHNER: I am not familiar 6
with the balance of plant and the layout and such.
7 Does that confinement system have redundancy in the 8
isolation valves?
9 MR. NEWTON: Randy, do you want to help me 10 out here?
11 MR. STRADER: There is not a redundancy in 12 the valves themselves, but there is, we test the 13 confinement system, the leakage rate, so if anything 14 were to fail we would understand what the system can 15 handle, and so we test that annually and we also test 16 all the --
17 MR. NEWTON: It looks like we lost you, 18 Randy.
19 VICE CHAIRMAN KIRCHNER: Yes.
20 MR. NEWTON: I'm not sure what happened.
21 He must have dropped off.
22 VICE CHAIRMAN KIRCHNER: Well, my concern 23 is just --
24 MR. STRADER: Yes, I'm sorry. Yes, I'm 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
111 sorry, I dropped off. We also test all the valves and 1
the motors that operate the fans.
2 So we have both DC and AC motors that 3
operate each fan, and there is two fans, quarterly to 4
ensure that they operate as intended.
5 VICE CHAIRMAN KIRCHNER: I am just 6
thinking because you have an open-vented primary 7
system is there -- Well, maybe this is too much 8
detail, but it just seems to me you have only one line 9
of defense, and so is that equipment designed like 10 safety-related equipment for a power reactor?
11 MR. STRADER: I can't speak for a power 12 reactor, but it's been analyzed through our safety 13 analysis to be able to handle at RMHA.
14 VICE CHAIRMAN KIRCHNER: Okay. Okay, 15 thank you. Matt, may I make two observations?
16 MEMBER SUNSERI: Yes, sir, go ahead.
17 VICE CHAIRMAN KIRCHNER: Well the first 18 one is relevant to the Committee's deliberations 19 during this meeting on another topic it seems to me 20 that the approach that the NIST people took in 21 defining their NHA is a good example that might be 22 used by small reactors going forward in the licensing 23 arena. Now I am talking about power reactors.
24 Then the other cautionary observation I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
112 would make is we continue to hear that smaller 1
reactors, the expectation is that somehow smaller 2
reactors are safer and because the source term is 3
smaller the consequences are less in the case of an 4
accident.
5 That may be true, but it may not, and I 6
just throw out that cautionary note that there is 7
something also called frequency. So when you look at 8
risk it's not just the source term, but the potential 9
probability for an accident and advanced designs that 10 haven't been proven.
11 And there are good examples of this, Fermi 12 was one, it was a much smaller reactor, it wasn't 13 necessarily more beautiful. So I am just a little 14 concerned going forward when we look at small and 15 advanced modular reactors that we just don't go in 16 with the presumption that they are safer until 17 demonstrated. That's just a personal note.
18 MEMBER SUNSERI: Yes. No, that's a good 19 point, Walt, and that is exactly why I think we wanted 20 to have this presentation so that we could glean any 21 of those insights for our future work. We will go to 22 Dave Petti next.
23 MEMBER PETTI: Yes. I just wanted to 24 follow on from what Walt said. I looked at it from a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
113 perspective of reactor training and our recent 1
discussions and vis-a-vis a Part 53 licensed versus 2
certified operators.
3 I think this is also a cautionary tale and 4
I think supports our position in the letter we took, 5
so --
6 MEMBER SUNSERI: Yes. No, very good 7
without a doubt. Any other Members?
8 (No audible response.)
9 MEMBER SUNSERI: All right. Well those 10 were great comments, great questions. So now we will 11 open up the line for the public comments. If you are 12 a member of the public listening in on the phone line 13 you can unmute yourself using star six.
14 If you are a member of the public on the 15 Teams just open your, unmute yourself and make your 16 comment, state your name and make your comment. So 17 the line is now open.
18 (No audible response.)
19 MEMBER SUNSERI: Okay. I am not hearing 20 anything. We will close off those comments. Any 21 other members or anyone in the Staff or NIST would 22 like to make any comment before we close up?
23 (No audible response.)
24 MEMBER SUNSERI: All right. Well then I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
114 will close this up. I really want to thank Patrick 1
and Thomas and all of the folks on your teams that 2
supported the presentations today.
3 They were excellent and informed us. I 4
think I would say it met or maybe even exceeded my 5
expectations on the level of detail and the comments 6
here.
7 As Walt and Dave were saying, I think some 8
of the important insights, at least I heard from the 9
drawing out of this, is not necessarily around the 10 technology because safety culture tends to be, I'll 11 use a buzz word here, technology-inclusive, right, you 12 know, safety culture crosses all venues.
13 I think we saw here clearly what could 14 happen when complacency at either levels of management 15 or workforce sets in, the importance of procedure use 16 and adherence, the importance of training, being 17 mindful of the level of experience of your staff and 18 making sure that they procedures and training is 19 sufficient to support the level of experience that you 20 have, which is a management activity, and last but not 21 least I will say respect for all things that could 22 affect the integrity of nuclear feel, like the 23 latching procedures, et cetera.
24 So I think those are all important 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
115 concepts that we could think about as we look forward 1
to our future work. And as Walt was saying, it really 2
doesn't matter what size the reactors are, these 3
things all apply and you can have undesirable 4
consequences if you don't take care of the safety 5
culture.
6 So with that, Chair Rempe, I will turn the 7
presentation back to you.
8 MEMBER REMPE: Thanks, Matt, and thanks to 9
-- I would also like to thank on behalf of the 10 Committee for the presentations we received from the 11 staff at NIST as well as the NRC Staff.
12 At this time -- Oh, I also want to thank 13 you, Matt, for your leadership in getting this 14 arranged for us. At this time I would like to ask the 15 court reporter to note that we are going to go off the 16 record and then I would like to discuss with the 17 Committee what they want to do for the next 45 18 minutes.
19 (Whereupon, the above-entitled matter went 20 off the record at 10:43 a.m.)
21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
February 3, 2021, Fuel Failure Event at the NIST Center for Neutron Research (NCNR)
Rob Dimeo, Director Tom Newton, Deputy Director/Chief of Reactor Operations and Engineering Paul Brand, Chief of Reactor Engineering Randy Strader, Chief of Reactor Operations Steve Dewey, Chief of Health Physics Andrew Gahan, Chief of Aging Reactor Management
2 NCNR
- One of Three Major Neutron Science Centers in the US
- Supports > 3000 research participants annually
- Neutrons supplied by 20 MW reactor, the NBSR
- Reactor operates on a 38 day fuel cycle
Cut-away View of the NBSR Core Top Grid Plate Fuel Elements (30)
Fuel Plates Liquid Hydrogen Cold Neutron Source Bottom Grid Plate D2O Primary Inlet Plenums Cd Shim Safety Arms (4)
Reactor Vessel Radial Beam Tubes (9)
Split Core:
18-cm Unfueled Gap - Flux Trap Primary Outlet (2)
Thermal Shield
Highly enriched, U3O8 with Al dispersant, Aluminum clad 34 (17x2) fueled plates Total loading: ~350g U/element Upper and lower fuel sections -- unfueled 18 cm gap to minimize high energy neutrons and gammas in cold neutron sources and beam tubes Four new fuel elements added after each 38-day cycle Elements in for 7 or 8 cycles Fuel 4
D2O coolant: refueling is done blind All 30 elements are moved each refueling Each core position has its own transfer tool Elements are moved via transfer arms, lowered into core, then latched into position Refueling 5
Refueling the NBSR (2010)
Latching video 6
Refueling January 4, 2021
- Routine refueling performed, with latching and latch checks
- After-the-event review showed these checks were done incorrectly.
- 2nd cycle element was not latched.
- Startup was delayed ~1 month because of COVID concerns.
- Routine (daily) starting and stopping of primary pumps pushed the element into an area outside of flow.
- Not detected by any instruments prior to startup.
8:16 startup 9:00 approach to 10 MW 9:06 begin ascension to full power 9:07 sudden drop to about 7 MW 9:08 release of fission products 9:09 major scram via stack monitor reaching 50,000 cpm 9:16 alert declared 9:21 evacuation of control room due to high radiation levels 9:29 NRC notified February 3 event 8
All systems operated as designed Good response by operators and health physics staff Radiation levels in control room necessitated evacuation shortly after event (Emergency Instruction: evacuate if projected exposure > 300 mrem)
Two operators briefly stayed behind to start shutdown actions Three operators and one HP re-entered later that day to complete shutdown actions Total of 10 staff members were contaminated Successfully decontaminated that day.
Event response 10
Maximum total dose 1172 mrem NRC annual limit: 5000 mrem Doses were likely lower as dosimeters were contaminated.
Maximum Electronic Personal Dosimeter 182 mrem.
Internal doses all from tritium Likely not event related Personnel Doses 11
12
13 NBSR Emergency Planning Zone Boundary dose estimates
- Multiple air and particulate samples taken at stack and 400 m site boundary.
- Large uncertainties in site boundary measurements delayed downgrading of emergency. Eventually used stack samples and dilution factors.
- Feb. 3:
- 1532: Downgraded to NOUE
- 1935: Terminated emergency
Primary isotopes Xe-133, Xe-133m, Kr-83m Feb 3 - 6, 2021
Emergency ventilation
Total of 29.6 Ci released Results based upon stack samples
400 m boundary samples had very low levels of Xe-138 (Cs-138), Xe-133, Xe-135 Initial estimated dose to the public <0.5 mrem
Confirmed by NRC and DOE (CMHT)
DOE Dose Estimate 0.008 mrem (Feb 3-6)
Feb 6 return to normal ventilation
Total of 15.4 Ci released Feb 7 thru April 30
Dose Estimate 0.006 mrem (NIST)
Co-60 likely a result of cross contamination of sample equipment Release Estimate 14 Nuclide Release Activity Feb 3-6, 2021 (Curies)
Release Activity Feb 7-April 30 (Curies)
Kr-83m 1.53E+00 Kr-85m 5.16E-02 Kr-87 9.03E-02 Kr-88 1.14E-01 Rb-88 9.35E-02 Xe-137 4.91E-01 Xe-138 5.10E-01 Xe-131m 4.88E+00 3.04E+00 Xe-133 1.80E+01 1.05E+01 Xe-133m 9.70E-02 6.19E-02 Xe-135 1.30E+00 9.72E-02 Kr-85 2.49E+00 1.77E+00 Co-60 9.01E-13 Cs-138 1.32E-12 I-131 1.33E-4
Annual release limit 10 mrem / year 10 CFR 20.1101(d)
Annual Release (2020 Typical) 1120 Ci Ar-41 1273 Ci H-3 Annual Boundary Dose 0.8 mrem Event Total Boundary Dose 0.014 mrem 2% of normal annual release in terms of dose Maximum Hypothetical Accident (MHA) 6.4 mrem offsite dose Release Estimate (continued) 15
16 Video Surveillance of Core Began 2/23/21 Upper grid plate, positions H-6 and J-7 Lower grid plate, near position J-7
February 23: Video surveillance showed single element out of position with apparent fuel damage.
March 5: Concluded that 450oC fuel safety limit had been exceeded, report to NRC in accordance with TS 6.6.1 Safety Limit 17
18 Failed fuel element
- Element was identified as Element no. 1175, originally introduced into the core in October, 2020.
- Ran one cycle (38 days) with no issues.
- Review of QA records identified no anomalies in manufacturing or acceptance.
19 Video Surveillance of Core Failed fuel element prior to moving from lower grid plate Video still shot of failed fuel element as it was released from the lower grid plate
20 Video Surveillance of Core Bottom of failed fuel element prior to removal from the core on August 5 Failed element resting on top of installed debris cap
March 10: Internal Technical Working Group (TWG) formed to investigate root cause May 13: TWG report complete; letter to NRC reporting inadequacies in:
Training and procedures in fuel latching Procedural compliance Management oversight June 3 follow-up: finding that element could inadvertently be unlatched by use of refueling tool without rotational force Root Cause Investigation 21
May 14: SEC Subcommittee formed to investigate response, root cause review and corrective actions 5 people, NIST and external August 12: report complete Two additional root causes:
Lack of change management program Culture of complacency 24 recommended corrective actions and program improvements Safety Evaluation Committee (SEC) Investigation 22
Change management:
New Aging Reactor Management program Organizational realignment, including additional training shift Procedure overhaul with compliance audits Managing changes via Corrective Action Program Continuous improvement Extensive staff participation -- 19 teams of 56 NCNR staff formed to formulate detailed corrective actions implementation and recovery tasks.
Safety culture Benchmarking with other facilities Corrective Actions -- Management 23
Proficiency training Qualification for fuel movements Programs rewritten for better knowledge transfer Development of standards for supervisors Qualification and oversight training Periodic management reviews of program Corrective Actions -- Training 24
Personnel adherence Safety more integrated into procedures Revision to INPO 11-003 Rewrite fueling procedures Capture details Latch checks done prior to final pump restart Redundant rotation check New procedures Visual checks No contact with fuel head after visual check Corrective Actions -- Procedures 25
Visual Checks Testing completed Tools assessment Discontinue use of height checks NI noise gate To alert operator of abnormal signal Corrective Actions -- Equipment 26
NRC Special Inspection Team began 2/8/21 Physical or virtual presence at daily meetings, special evolutions February - May: Written reports on event, exceeding safety limit, and findings of inadequacies July: Start weekly calls with NRC management October 1: Root causes, planned corrective actions and request for permission to restart October-present:
Supplemental reports Information furnished for NRC audit process December 23: LAR submitted to require both rotation and visual latch checks in technical specifications NCNR interactions with NRC 27
27 Fuel elements removed from core, including damaged element Final three removal in progress Vessel cleanup complete Primary system cleanup using filter elements started late March Evaluation of remaining fuel elements for possible reuse:
backflow and inspection Reactor Status 28 Vessel cleanup February 2022
Feb. 3, 2021 event was unprecedented in recent U.S. research reactor history.
NIST is committed to restart reactor when all necessary corrective actions are complete, and NRC allows.
NIST Public Affairs has been invaluable in facilitating communications.
External reviews found that response on the day of the event was appropriate.
Frequent and open communications with NRC is key to recovery and restart.
Conclusion 29
Backup slides 30
Nuclear Instrument response during event 31 Normal Startup Startup February 3, 2021
Operator Experience 32 Average Experience of SROs and Supervisors Experience of Reactor Operators
NIST Event NRC Event Brief to ACRS March 3, 2022
Key Messages
- The NIST reactor is in a safe shutdown condition and may not restart until authorized by the Commission
- Most of the fuel removed from the reactor vessel (3 of 30 elements remain) and recovery actions are underway
- Offsite dose to the public from the event was near background levels
- Radiation dose to the workers from the event was well below regulatory limits
- NRC independently evaluated the consequences of the event and is reviewing the licensee's request to restart the reactor
- NRC review and inspection activities are still ongoing
NRC Response - Executive Summary
- Special Inspection Team (SIT) Dispatched to Site
- Team chartered to review the event and licensee response
- Technical Review Team Assembled
- NRC technical experts to review NIST root cause results, corrective actions, and recovery activities
- Results of technical review will inform restart decision
- Status of Teams
- SIT report is going through concurrence
- NRC technical review team initiated an audit to more closely review information from licensee
- Additional inspection activities will continue prior to and following any authorized restart
NRC Review of Event
- NIST reported to the NRC that partial melting of one fuel element occurred providing indication that the safety limit was exceeded
- The safety limit as stated in the technical specifications is:
- The reactor fuel cladding temperature shall not exceed 842°F (450°C) for any operating conditions of power and flow
- NIST reported very limited radiological release during and following the event
- NRC staff compared the event and radiological dose consequence to the accident analysis in the NIST safety analysis report
- NRC staff determined that the event was within the radiological release amount identified in the maximum hypothetical accident safety analysis
Maximum Hypothetical Accident
- NUREG-1537, Part 2 provides the standard review plan and acceptance criteria for licensing non-power reactors
- Chapter 13 discusses the maximum hypothetical accident (MHA) as a postulated accident scenario whose potential consequences are shown to exceed all credible accidents
- Complete blockage of flow to one fuel element by unspecified means
- All the noble gas fission products are assumed to be released into the primary coolant and quickly collect in the helium space at the top of the reactor vessel
- Maximum dose to the public, at the exclusion boundary, is calculated to be 7 mrem
- Flow blocked to one element
- Partial fuel melting released fission products
- Krypton was observed in the stack monitor
- Visual evidence of once molten material that appears to be previously melted fuel that has since resolidified
- NIST (as confirmed by the NRC staff) calculated the total dose to the public during the event as ranging from 0.00035 mrem to 0.0008 mrem, which is a small fraction of the theoretical dose consequence
Restart Requires Commission Authorization
- 10 CFR 50.36(c) requires technical specifications to include safety limits, which are defined as limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain physical barriers that guard against the uncontrolled release of radioactivity
- 10 CFR 50.36(c) states that in the event of a safety limit exceedance:
- The reactor must be shut down
- The licensee shall notify the Commission
- The licensee shall review the matter and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence
- Operation must not be resumed until authorized by the Commission
Restart Request Review Team
- Primary Technical support from multiple divisions including:
- Division of Advanced Reactors and Non-Power Production and Utilization Facilities (Project Manager and Inspectors)
- Division of Safety Systems
- Division of Engineering and External Hazards
- Division of New and Renewed Licenses
- Division of Radiation Protection and Accident Dose
- Main Review areas
- Reactor Vessel Internals
- Mechanical Engineering and Inservice Testing
- Plant Systems
- Nuclear Methods, Fuels, and Systems
NRC Restart Request Review
- NIST submitted a restart request to the NRC
- NRC staff has initiated an audit to perform a more detailed review of the following items:
- Root cause corrective actions
- Actions to prevent recurrence
- Cleanup activities
- Evaluation of structures, systems, and components potentially affected by the event
NRC Staff Next Actions
- NRC staff continue review of NIST inspection results, tests, and analyses to determine if a sound technical basis exists to authorize restart
- NRC oversight and inspection processes will continue as the SIT closes out and the restart/enhanced inspection process begins
Summary
- NIST reactor is in event recovery with cleanup activities proceeding and inspection activities planned
- NRC approval is required for restart
- The NRC will continue its inspection activities prior to and following any authorized reactor restart
- The NRC will not authorize restart until it has determined that restart will be protective of public health and safety.