ML22339A102

Pg_E Presentation for NRC Public Meeting

ML22339A102
Person / Time
Site:	Diablo Canyon
Issue date:	12/05/2022
From:	Soenen P Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation
References
Download: ML22339A102 (1)

Text

DCPP License Renewal Pre-Submittal Presentation Presented by:

Philippe Soenen Director, Strategic Initiatives December 8, 2022

Topics

• Background on DCPP License Renewal (LR)

• Specific License Renewal Topics Environmental Report Updates Operating Experience Timing of LR Application (LRA) Implementation Severe Accident Mitigation Alternatives (SAMA) Analysis Reactor Vessel Coupon Withdrawal Update License Renewal Duration 2

Background on DCPP LR 3

DCPP License Renewal History

• Multi-year update of LRA completed in 2014 (block 4) for NRC review:

Typical annual update items (e.g., review of component database for changes, review of operating experience)

Addressed new LR Interim Staff Guidance (LR-ISGs)

Updated Environmental Report (e.g., census data, threatened and endangered species, alternatives evaluation, and SAMA Analysis)

• Current license expiration dates for DCPP, Unit 1 and Unit 2, are November 2, 2024 and August 26, 2025, respectively 4

Withdrawal 1

2 3

4 5

6 7

(2007-2009):

Feasibility Study (2009-2011):

Submittal /

NRC Review (2011-2014):

LR On-Hold (2014-2016):

Update /

NRC Review (2016-2018):

LR On-Hold (Sept. 2022):

Senate Bill 846 (Oct. 2022):

PG&E Request Resumption of Review

DCPP License Renewal NRC Review Progress 5

Completed items Regional Inspection Scoping Audit Plant Condition & Programs Closeout Inspection (optional)

Safety/Technical Review NRC issues Suppl. SER SERs issued as NUREGs ACRS Review Sub-Committee Meeting 2nd Sub-Committee Meeting Full Committee Meeting Sub-Committee Meeting Region Recom mendation ACRS Recom mendation to the Comm ission Final SER Issued - Jun. 2011 Suppl. SER Issued - TBD Final SER Issued - Jun. 2011 Commission Action -

Issuance of Renewed License Application Submittal -

November 2009 Sufficiency Determination -

January 2010 Environmental Review NRC issues Draft SEIS for comment Draft SEIS Public Meeting NRC issues Final SEIS Scoping Notice Site Visit 1st Public Meeting EIS Scoping Period Ends RAIs to Plant RAIs answered by Plant Environmental LRA Update 2nd Site Visit 2nd Scoping Period and Public Meeting Update RAIs to Plant Update RAIs answered by Plant Final SEIS Issued Intervention and Hearings Hearing Notice Request Deadline ASLB Hearing ASLB Decision No Intervention or Resol ved Consistent with GALL Audits RAIs to Plant RAIs answered by Plant NRC issues draft SER Plant answers open items NRC issues final SER Annual Updates Safety/Technical LRA Update Update RAIs to Plant Update RAIs answered by Plant

State and Federal Updates Assembly Bill (AB) 180 Signed by the California Governor on June 30, 2022 Authorized $75 million for near-term fuel purchasing, fuel storage, licensing and project team to preserve option of extended DCPP operations Senate Bill (SB) 846 Signed by the California Governor on September 2, 2022 Directed PG&E to pursue continued operations for 5 years beyond 2025 Addresses both near-term and long-term funding needs Includes state policy "off ramps" that could terminate the path of renewing the operating licenses U.S. Department of Energy Civil Nuclear Credit (CNC)

Program

• DCPP has been certified to participate in the CNC programs first award period 6

Request to Resume Review of DCPP LRA PG&Es October 2022 Submittal

• PG&E requested the NRC resume review of the LRA as it existed when the review ceased in 2016 and confirm that the NRC will not deem the existing licenses to have expired until the LRA has been finally determined

- PG&E believes resumption is within NRC authority and is consistent with precedent

- PG&E would submit an update to the LRA by December 2023

• If the request to resume review of the DCPP LRA is not granted, PG&E requested an exemption from 10 CFR 2.109(b) to ensure DCPP Units 1 and 2 can continue to operate while the application is under review

- PG&E concluded the exemption (if needed) is permissible because it is authorized by law, will not present an undue risk to the public health and safety, is consistent with the common defense and security, and because special circumstances are present 7

Environmental Report Updates 8

Environmental Report Updates PG&E plans to submit an updated environmental report

• Update evaluations with current information related to potential environmental impacts associated with the renewed license

• Update format consistent with current NRC guidance

• Incorporate updated information from site-specific Decommissioning studies

• Recent, extensive environmental work was completed to support decommissioning activities 9

Operating Experience 10

Operating Experience Updates PG&E plans to consider operating experience in the LRA

• During the original LRA review, PG&E addressed NRC questions related to Generic Aging Lessons Learned (GALL),

Revision 2, and made updates to aging management programs (AMPs) through the request for additional information process

• PG&E plans to review all AMPs for potential updates from newer operating experience or NRC guidance

GALL, Revision 2

GALL - Subsequent License Renewal (SLR)

Initial LR and SLR - Interim Staff Guidance 11

Timing of License Renewal Implementation 12

Site LRA Submittal Date Initial SER Issued PEO Began Implementation Time*

Renewed License Issued Indian Point, Unit 2 Apr 2007 Nov 2009 Sep 2013

~4 years Sep 2018 Prairie Island, Unit 1 Apr 2008 Oct 2009 Aug 2013

~4 years Jun 2011 Vermont Yankee Jan 2006 Feb 2008 Mar 2012

~4 years Mar 2011 Oyster Creek Jul 2005 Dec 2006 Apr 2009

~2.75 years Apr 2009 Nine Mile Point, Unit 1 May 2004 Jun 2006 Aug 2009

~3 years Oct 2006 PG&Es implementation timeframe is unique compared to industry precedent

• The timeframe for DCPP is to address significant needs identified by the State of CA to protect public health and safety by having adequate energy supply

• Implementation timeframe considered from issuance of initial Safety Evaluation Report (SER) to period of extended operation (PEO)

Precedent - Sites with Shorter Implementation Timeframes 13

Implementation Timing Aging Management Program (AMPs)

• At the time the DCPP LRA was withdrawn, implementation of most AMPs was prior to the PEO

• Recent shift in state policy has compressed the schedule for implementation of DCPP AMPs

• Considering revising timeframe given remaining refueling outages prior to the PEO (see next slide)

- Renewed operating licenses do not change the existing robust requirements for safe operations, on-going maintenance, and recurring inspections; rather, license renewal adds more inspection requirements

- Risk and plant-specific operating experience will be used to inform implementation timing

- Will take advantage of opportunistic inspections 14

Sample Implementation Schedule for DCPP 15 N

PEO: period of extended operations LRA: License Renewal Application Oct 2022 Submit Request for LRA Resumption or Exemption 4Q 2023 Submit New/Updated LRA 1

Fall 2025 2R25 6

5 Nov 2024 Unit 1 PEO begins Aug 2025 Unit 2 PEO begins Spring 2025 1R25 7

Issue Renewed Licenses First Outage for Each Unit after Renewed Licenses 8

Finish Implementing AMPs tied to an outage 15 Spring 2024 2R24 Fall 2023 1R24 4

3 2

NRC will continue to have an onsite presence during the LRA review period and will retain its authority to conduct all regulatory activities associated with licensing, inspection and oversight. This includes taking whatever actions may be necessary to ensure adequate protection of public health and safety.

Severe Accident Mitigation Alternatives (SAMA) Analysis 16

DCPP SAMA Background

• In 2009, PG&E performed SAMA analysis for initial LRA

• NRC requests for additional information (RAIs) complete

• LR review put on-hold prior to NRC issuance of the Supplemental Environmental Impact Statement (SEIS)

• In 2015-2016, PG&E updated the initial SAMA analysis

• Incorporated updated information, including new plant Probabilistic Risk Assessment (PRA), census data, and seismic information

• NRC on-site audit and RAIs complete

• LR review put on-hold prior to NRC issuance of the SEIS 17

SAMA Update Approach

• PG&E plans to complete a new full SAMA with the current DCPP PRA model-of-record

• Changes to the DCPP PRA model-of-record during the NRC review will be addressed via the LRA amendment or RAI process

• PG&E currently does not plan to use the Nuclear Energy Institute (NEI) 17-04 new and significant information approach

• No previously approved DCPP SAMA as baseline for comparison 18

DCPP Reactor Vessel Coupon Updates 19

Reactor Vessel Coupon Updates

• Reactor vessel coupon withdrawal requirements for the current 40-yr operating period have been satisfied

• Unit 2 reactor vessel coupons have all been withdrawn

• Data was used in original LRA to demonstrate acceptability through the PEO (i.e., 60 years of operation)

• Unit 1 reactor vessel coupons

• Data was used in original LRA to demonstrate acceptability through the PEO (i.e., 60 years of operation)

• LRA credited withdrawing one final coupon to support the DCPP PEO and to benefit the industry PG&E plans to retrieve the Unit 1 coupon in the Fall 2023 refueling outage (~96 Effective Full Power Years) 20

License Renewal Duration 21

Balancing State Needs

• SB-846 directed continued DCPP operations for 5 years beyond 2025

• SB-846 requires ongoing assessment of need for DCPP to support state reliability needs

• As allowed by NRC regulations, original LRA sought NRC license renewal for 20 years

• NRC review for 20 years of extended operations is consistent with PG&E's current LRA restart plans

• Actual operating duration will be controlled by the State legislative and regulatory processes

Consistent with Indian Point precedent for NRCs bounding review of up to 20 years

• Allows for maximum flexibility by State of California to ensure electric resource adequacy 22

Questions?

23