ML23054A177
| ML23054A177 | |
| Person / Time | |
|---|---|
| Issue date: | 02/02/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2246 | |
| Download: ML23054A177 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number: (n/a)
Location: teleconference Date: Thursday, February 2, 2023 Work Order No.: NRC-2246 Pages 1-121 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 702ND MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +
8 THURSDAY 9 FEBRUARY 2, 2023 10 + + + + +
11 The Advisory Committee met via 12 teleconference at 8:30 a.m., Joy L. Rempe, Chairman, 13 presiding.
14 15 COMMITTEE MEMBERS:
16 JOY L. REMPE, Chairman 17 WALTER L. KIRCHNER, Vice Chairman 18 DAVID A. PETTI, Member-at-Large 19 RONALD G. BALLINGER, Member 20 VICKI M. BIER, Member 21 CHARLES H. BROWN, JR., Member 22 VESNA B. DIMITRIJEVIC, Member 23 GREGORY H. HALNON, Member 24 JOSE A. MARCH-LEUBA, Member 25 MATTHEW W. SUNSERI, Member 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 1 ACRS CONSULTANT:
2 DENNIS BLEY 3
4 DESIGNATED FEDERAL OFFICIAL:
5 WEIDONG WANG 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 1 P-R-O-C-E-E-D-I-N-G-S 2 8:30 a.m.
3 CHAIRMAN REMPE: Okay. Good morning 4 everyone. It's 8:30 on the East Coast, and this 5 meeting will now come to order. I hear an echo, so If 6 you're out there on the virtual area, please make sure 7 your microphones are muted. This is the second day of 8 the 702nd Meeting of the Advisory Committee on Reactor 9 Safeguards. I'm Joy Rempe, Chairman of the ACRS.
10 Other members in attendance are Ron 11 Ballinger, Vicki Bier, Charles Brown, Vesna 12 Dimitrijevic, Greg Halnon, Walt Kirchner, Jose March-13 Leuba, Dave Petti and Matt Sunseri, so we do have a 14 quorum.
15 Similar to yesterday, the Committee is 16 meeting in person and virtually. A communications 17 channel has ben opened to allow members of the public 18 to monitor the Committee discussion. Mr. Weidong Wang 19 is the Designated Federal Officer for today's meeting.
20 During today's meeting, the Committee will 21 consider the following topics: The Oconee subsequent 22 license renewal application review. A transcript of 23 the open portions of the meeting is being kept, and 24 it's requested the speakers identify themselves and 25 speak with sufficient clarity and volume so they can 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 1 be readily heard.
2 Additionally, participants should mute 3 themselves when they're not speaking. At this time 4 (audio interference) that even though Kent is the DFO 5 for this topic, that Weidong, the minutes were 6 provided or the opening remarks were provided to me, 7 that he is still the DFO, okay? But anyway, do any 8 other members have any opening remarks?
9 MEMBER HALNON: Joy, you didn't mention 10 the consultants that are here.
11 CHAIRMAN REMPE: We don't usually do that 12 in full Committee, okay?
13 MEMBER HALNON: That's right.
14 CHAIRMAN REMPE: Okay, anyway. Since 15 yeah, we do not. Although we do have our consultant, 16 Steve Schultz with us, we don't usually introduce 17 them. It's only subcommittees that we do that. Okay.
18 So then If not, I'd like to ask Matt Sunseri to lead 19 us through our first topic for today's meeting. Matt.
20 MEMBER SUNSERI: Good morning. Thank you, 21 Dr. Rempe. Today -- so I am Matt Sunseri. I'm the 22 lead member for the Subsequent License Renewal 23 Subcommittee. Today's review is for the Oconee 24 Nuclear Station, which is operated by Duke Energy 25 Carolinas, LLC. We handle the subsequent license 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 1 renewal review slightly different than other technical 2 reviews that we engage, and that is for applications 3 that have no open or confirmatory items.
4 We combine the subcommittee review with 5 the full committee presentation into one session, and 6 then bring that before the full Committee, and that's 7 what we're doing today. Then we schedule a subsequent 8 full Committee meeting to do the report preparation 9 and further deliberations. However, the ACRS is an 10 agile committee and we have found ourselves with some 11 windfall time available during this session.
12 The Chairman is asking to see If could 13 pull up the deliberations from the next meeting to 14 this meeting for the report preparation, so we intend 15 to do that. So after the presentations today, we will 16 need some time to collect our thoughts and get ready, 17 but we anticipate -- well no, we will start 18 deliberations at 2:00 p.m. Eastern Time this 19 afternoon, deliberation and report preparation for the 20 Oconee SLR report that we will prepare.
21 And I make that announcement for any 22 members of the public that are listening in and care 23 to oversee that deliberation this afternoon. So I 24 before I continue, are there any questions about that 25 change in the process?
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6 1 CHAIRMAN REMPE: I'd just add, although I 2 anticipate we will be done this afternoon with -- and 3 be able to pass out the letter report, if something 4 were to happen, because you never know at the ACRS, we 5 do also have time after our PMP tomorrow too to finish 6 it. So I really do suspect we'll be done with the 7 report this meeting.
8 MEMBER SUNSERI: Yeah, that's a good 9 point. So we have the rest of this session to 10 complete that report if we need to take that time.
11 Hopefully, we'll get through it this afternoon.
12 Okay, very good. So I'll continue on, and 13 like other members, because I do some work outside of 14 the ACRS and other clients that I support, I have a 15 potential conflict on one of the technical aspects of 16 this review. So I will be recusing myself from 17 deliberations on the portion of the review related to 18 metal environmental fatigue, or irradiation, 19 embrittlement and reactor --
20 Now I now turn to Brian Smith, Director of 21 the New and Renewal Licenses, for comments. Brian.
22 MR. SMITH: Good morning, Chairman Rempe 23 and Committee members. My name is Brian Smith. I'm 24 the Director of the Division of New and Renewed 25 Licenses.
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7 1 (Audio interference.)
2 CHAIRMAN REMPE: Yes. Thomas, do you know 3 why it did this? Okay, okay. We'll see If that keeps 4 up. The other thing I wanted to mention Brian, would 5 you put your microphone a little closer to where 6 you're talking so we can hear you better. Thank you.
7 MR. SMITH: Yes ma'am. Once again, good 8 morning everyone. Brian Smith, Director of the 9 Division of New and Renewed Licenses in NRR. Pleased 10 to be here today, and we appreciate the opportunity to 11 present the results of our review of the sixth 12 application for Subsequent License Renewal.
13 This application was submitted by Duke 14 Energy for the Oconee Nuclear Station, Units 1, 2 and 15 3, located in Seneca, South Carolina. The background:
16 Oconee Units 1, 2 and 3 received approval for their 17 initial license renewal from the NRC on May 23rd, 18 2000. The application at that time was submitted 19 prior to when NRC issued the initial generic Aging 20 Lessons Learned report or the GALL report.
21 The initial GALL report was issued in 22 2011. The NRC guidance for license renewal has 23 evolved over the years through enhancements and 24 improvements based on the lessons learned from NRC 25 application reviews and from consideration of both 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 1 domestic and international industry operating 2 experience.
3 This initial GALL report for license 4 renewal went through two revisions, with additional 5 interim staff guidance following Revision 2. GALL 6 Report Revision 2, along with these ISGs, were used to 7 develop the guidance for subsequent license renewal 8 that's contained in the GALL SLR report.
9 In addition to the previous license 10 renewal guidance, the GALL SLR report included 11 additional focus on aging management and time-limiting 12 aging analyses for operation in the 60 to 80 year time 13 period.
14 The NRC project manager for the Oconee 15 Subsequent License Renewal application review is Mark 16 Yoo. Mark will introduce the staff who will be 17 presenting and addressing the questions regarding the 18 safety review. Part of the management team here with 19 me today is Lauren Gibson, to my right, Chief of the 20 License Renewal Projects Branch, as well as branch 21 chiefs for the staff involved in the technical review.
22 Also with us today is our senior technical 23 advisor for Aging Management, Dr. Allen Hiser, who 24 will be able to answer questions from the Committee.
25 This will be Allen's last time for the ACRS before he 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 1 retires, we think for the last time, at the end of the 2 month. So we appreciate Allen coming back for an 3 additional year to help us with some knowledge 4 management activities.
5 Replacing Allen is Dr. John Wise, who's 6 here today as well. He comes to us from NMSS. He 7 does have prior experience in reactor license renewal 8 reuse. He left NRR to go to NMSS to help them develop 9 their license renewal program for storage casks. He's 10 presented in front of you several times in that role 11 at NMSS. So we're glad to have John on board with us.
12 Jared Nadel, senior resident inspector at 13 Oconee, will discuss the regional inspection 14 activities, and Paula Cooper, Region II, Senior 15 Reactor Inspector, is attending virtually and will 16 also support today's presentation. I'd like to note 17 that the staff completed its review with no 18 confirmatory or open items in the safety evaluations.
19 Finally, we will address any questions you 20 may have on the staff's presentation, and we look 21 forward to a production discussion today with the 22 ACRS. At this time, I would like to turn the 23 presentation over to Ms. Rounette Nader, Director of 24 License Renewal at Duke Energy, to introduce her team 25 and commence the presentation.
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10 1 MS. NADER: Thank you, Brian. Good 2 morning. Thank you Chairman Rempe and members of the 3 ACRS. My name is Rounette Nader. I am the Director 4 of License Renewal for Duke Energy, including the 5 Oconee Subsequent License Renewal Project. I'm going 6 to MC the Duke discussion today. We appreciate the 7 opportunity to speak with the ACRS Full Committee 8 today on Duke Energy's application for subsequent 9 license renewal.
10 This is an important milestone in the 11 process, and we look forward to presenting the 12 application highlights to the Committee.
13 Next slide, please. I want to take a 14 moment to introduce the team assembled to present the 15 application, the Oconee subsequent license renewal 16 application. I'll provide additional background on 17 each speaker throughout as I introduce them to speak, 18 but I will introduce them now. First we have Mr.
19 Steve Snider to my left. Steve is the Oconee Site 20 Vice President.
21 Next we have Greg Robison to my right.
22 Greg is the engineering manager responsible for the 23 development of Oconee subsequent license renewal 24 application, and finally we have Joe Terrell. Joe is 25 a lead engineer responsible for the Cost 1 portions of 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 1 the Oconee subsequent license renewal application, and 2 will be discussing some specific programs today.
3 In addition to the presenters at the 4 table, we have other members of the Duke subsequent 5 license renewal team throughout the room here today, 6 as well as a Duke team assembled in a conference room 7 in Charlotte. These teams are in a position to assist 8 with any questions the ACRS may have today.
9 So first a little about myself. As I 10 mentioned, I'm responsible for license renewal at Duke 11 Energy and the SLR application process, as well as the 12 project to implement the commitments from the initial 13 license renewal for the Duke Energy fleet. I began my 14 career at Oconee Nuclear Station in design 15 engineering, and from there I joined the initial 16 license renewal team in 1996, and was part of the team 17 that assembled the second license renewal application 18 in the country to be submitted to the NRC.
19 After finishing license renewal on Oconee, 20 McGuire and Catawba Nuclear Stations, I had various 21 roles in licensing, projects, business planning and 22 strategy before rejoining the license renewal efforts 23 at Duke.
24 Next slide, please. So I want to cover 25 the agenda for today's meeting. First, Steve Snider 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 1 will provide an overview of the Oconee Nuclear Station 2 and discuss recent station performance. Steve will 3 also discuss significant plant upgrades that 4 demonstrate Oconee's investment in the continued safe 5 and reliable operation of the plant.
6 Then Greg Robison will discuss the Oconee 7 subsequent license renewal application. Greg will 8 discuss the development of the application and the 9 advancements and changes between Oconee initial 10 licensure renewal, which was a pre-GALL plant, as 11 Brian mentioned, and subsequent license renewal.
12 Greg will discuss the integrated plant 13 assessment results and provide an overview of the 14 subsequent license renewal aging management program 15 alignment to the SLR GALL. Finally, Greg will discuss 16 initial licensure and aging management program 17 effectiveness reviews, and how Oconee is continuing to 18 ensure license renewal commitments are met and will 19 continue to be met for subsequent license renewal.
20 Joe Terrell will discuss our specific 21 technical topics. He will discuss the reactor vessel 22 internals, reactor vessels supports and irradiated 23 concrete. Finally, I will wrap up with some closing 24 remarks. So of course, the ACRS members, you are 25 welcome to ask questions as we go, but do note that 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 1 I'll pause at the end of each of these three major 2 topics that we plan to cover and open the floor for 3 any questions that you may have, and we can cover them 4 then as well. Next slide, please.
5 MEMBER SUNSERI: And so I'll just 6 interject now. So I just meant to say this during the 7 opening, but I think it's remarkable that you have so 8 many folks here to participate in this deliberation 9 in-person, and that we've done this a couple of times 10 and I think this truly shows the commitment on your 11 part to have a quality interaction with us today.
12 I think that is also reflected in the 13 quality of the application. So I just wanted -- I 14 know it's a hardship to bring this many people to 15 Washington, D.C., but I wanted to extend my 16 appreciation for it.
17 MS. NADER: Thank you, and we very much 18 appreciate being here in person. I'm glad that we 19 were able to do that. So next up is Steve Snider.
20 Steve Snider will give, as I mentioned, the Oconee 21 Nuclear Station plant overview.
22 Steve began his career, his energy career 23 as an electrical engineer in design engineering. He 24 held various positions of increasing responsibility in 25 engineering at Catawba Nuclear Station, receiving his 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 1 senior reactor operator license and continued with 2 management roles at Catawba and McGuire Nuclear 3 Stations in engineering, operations and maintenance.
4 In 2019, Steve was named the Vice 5 President of Corporate Nuclear Engineering, 6 responsible for functions such as nuclear fuel 7 management and procurement, core design and nuclear 8 safety analysis, and in April 2021, Steve was named 9 the Oconee Site Vice President.
10 MR. SNIDER: Good morning Chairman Rempe 11 and board members. So I'll start with -- go to the 12 next slide. I'll give a quick overview of Oconee.
13 You can see Oconee is a three unit Babcock and Wilcox 14 nuclear station processing design. We are a 15 pressurized water reactor with -- cooling. I'm 16 standing closer to the mic.
17 We produce nominally 2,554 megawatts.
18 That's enough to power more than 1.9 million homes.
19 We sit adjacent to Lake Keowee and Seneca in upstate 20 South Carolina. Our emergency AC power supply for 21 Oconee is supplied by Keowee Hydroelectric Station, 22 which is a bit unique for a nuclear power plant. Then 23 we also have a standby shutdown facility, which is a 24 backup to existing safety systems and provides 25 additional defense-in-depth.
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15 1 A couple of other comments. Duke Energy's 2 annual economic impact just in Oconee County each year 3 is roughly $1.8 billion, so a rather significant 4 impact, positive impact to the communities and 5 customers that we serve. Also, our -- and also --
6 (Audio interference.)
7 CHAIRMAN REMPE: That isn't coming from 8 your computer, right? Because they -- okay. There 9 seems to be a mic open. Can figure out who's line is 10 open?
11 (Pause.)
12 CHAIRMAN REMPE: So let's try again. We 13 are having the other noise. If that happens again, 14 we'll continue to try and figure out where it's coming 15 from, and I apologize.
16 MR. SNIDER: Okay.
17 CHAIRMAN REMPE: Go ahead.
18 MR. SNIDER: The last comment I was going 19 to make on this slide is that we are a carbon free 20 source of energy, so in the County alone it counts for 21 avoiding 15 million tons of CO2 annually.
22 We'll move to the next slide. Here's 23 another layout of the site. If you start in the lower 24 left-hand corner, north is pointing up. So like in 25 the southwest corner you can see the intake for the 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 1 site. Just above that, you can see the shutdown, 2 standby shutdown facility that each one of the three 3 units lined up there over Unit 1, the north-most unit.
4 Then Unit 2, then Unit 3 to the south.
5 There is an aux building adjacent to that, 6 and then a common turbine building that houses the 7 turbine generators and secondary systems. Unit 1 8 output to the 230 kV switch yard, which you see 9 relatively in the middle of the picture, and then Unit 10 3 outputs to the 525 kV switch yard.
11 And then further to the right, you can see 12 Keowee hydroelectric station, and then Lake Keowee to 13 the north. Any questions about the layout?
14 MEMBER HALNON: Yeah Steve, it's Greg.
15 The intake, is that -- is that the river that feeds 16 Lake Keowee or is it --
17 MR. SNIDER: It's hard to look at looking 18 at it from above, because of the elevation 19 differences. But the intake is part of Lake Keowee.
20 It just circles around that part of the plant.
21 MEMBER HALNON: Okay. In the switch 22 yards, you say 1 and 2 is out to 230. Is it a ring 23 bus, or is that a -- how is that? I'm looking at 24 shared systems. What are the shared, where's the 25 shared systems up there?
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17 1 MR. SNIDER: The 230 kV switch yard is the 2 emergency offsite power source. It all comes to this 3 230 kV switch yard. Unit 3 just generates through 4 the, to the 525 kV switch yard.
5 MEMBER HALNON: Okay. All the emergency 6 power is through 230, right Todd?
7 MR. GREEN: Yep, that's correct.
8 MEMBER HALNON: Okay, thank you.
9 MR. SNIDER: All right, next slide. Some 10 of this was previously covered, but you can see there 11 where we currently are with our licenses. We also 12 have a fuel storage facility, and the current license 13 expires for Unit 1 and Unit 2 in 2033, and for Unit 3 14 in 2034. We did submit our subsequent license renewal 15 application in June 2021. I don't have to say that.
16 That's why we're here today.
17 Okay, we'll go to the next slide. Overall 18 performance. I would rate Oconee's performance as 19 very good. Each unit operates on a 24 month refueling 20 cycle. We did have breaker to breaker runs for the 21 last full cycle that we completed for each one of the 22 units. You see the plant capacity factors listed 23 there for the last three years, and on average, the 24 three-year average for each of the units is greater 25 than 95 percent capacity factor.
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18 1 And then from a regulatory status, we are 2 in Action Column 1, and all of our ROP indicators are 3 currently green.
4 DR. SCHULTZ: Steve, this is Steve 5 Schultz. The power uprate that was approved in 2021, 6 that was the measurement uncertainty recapture. Is 7 that -- how much was achieved there?
8 MR. SNIDER: We are still implementing 9 that. We're anticipating about 14 megawatts per unit 10 between implementation and the leading edge flow 11 meters and the actual upgrade.
12 DR. SCHULTZ: So on this slide, you note 13 that each unit's on a 24-month refueling cycle. Are 14 there any other operational improvements or uprates 15 that are anticipated over the period of subsequent 16 operation?
17 MR. SNIDER: We do not currently have any 18 planned uprates beyond the measurement uprate.
19 DR. SCHULTZ: So Rowley's doing studies --
20 MR. SNIDER: Right, in the future. But 21 right now we don't have any actual projects to do.
22 DR. SCHULTZ: Nothing is planned, and If 23 anything did change in that regard, you'd need to come 24 back in and --
25 MR. SNIDER: Absolutely.
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19 1 DR. SCHULTZ: --make modifications, have 2 those approved?
3 MR. SNIDER: We are planning to do studies 4 along those, what would be required, whether or not 5 it's even feasible related to doing upgrades. But If 6 we did decide to move forward with any of those yes, 7 it would -- it would require licensing actions.
8 DR. SCHULTZ: But not part of this 9 application?
10 MR. SNIDER: No, certainly not part of 11 this application.
12 DR. SCHULTZ: Thank you.
13 MR. SNIDER: Okay, next slide. We have 14 done a significant number of plant modifications since 15 initial license renewal. I will highlight a couple.
16 The first two we have replaced the once-through steam 17 generators on all three units. We have replaced the 18 reactor vessel heads for all three units. We also 19 invest in modernizing Keowee as well. We've replaced 20 the rotors and the stators associated with both Keowee 21 units.
22 There's a number listed here and there's 23 a lot that aren't listed that we've just done, we've 24 done significant capital investments, both to improve 25 reliability and also to improve risk improvement 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
20 1 related to nuclear safety for the units as well.
2 MEMBER SUNSERI: Steve, I've got a couple 3 of -- oh, go ahead Greg.
4 MEMBER HALNON: Oh okay, I was going to 5 ask -- So a number of years ago you had from the 6 Keowee issues, some cables, cabling issues with the 7 NRC. Did that get modification to resolve that, or 8 was that a --
9 MR. SNIDER: That has been resolved.
10 There were some follow-up commitments that we made 11 associated with that, and those have all been 12 implemented.
13 MEMBER HALNON: So it's testing and 14 evaluation basically? Is that --
15 MR. SNIDER: I didn't fully hear the 16 question. The questions were related to the cable 17 separation issue and how that was resolved?
18 MEMBER HALNON: Yeah. The question was 19 how was that resolved? Did you -- Steve mentioned 20 some commitments. What were those? Are those ongoing 21 commitments, or are they all completed?
22 MR. GREEN: Well, the commitments are 23 complete.
24 MEMBER HALNON: Is there -- so I think you 25 need to come to the microphone.
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21 1 CHAIRMAN REMPE: And state your name.
2 MEMBER HALNON: State your name.
3 CHAIRMAN REMPE: All that stuff.
4 MR. GREEN: Okay. I'm Todd Green. I'm 5 the general manager at Oconee Engineering.
6 (Simultaneous speaking.)
7 CHAIRMAN REMPE: There's no mic up there.
8 So he's doing the right thing, but he just --
9 MR. GREEN: Talk to the green light.
10 CHAIRMAN REMPE: Yeah.
11 MR. GREEN: Any time. That issue has been 12 understood and has been resolved. There's no open 13 commitments associated with it. We did do 14 modifications to improve the separation for the cables 15 that were in question.
16 MEMBER HALNON: Okay. So that's behind 17 you and everyone's --
18 MR. GREEN: Yes sir.
19 MEMBER HALNON: Okay. Great, thanks.
20 MEMBER SUNSERI: I had a question about 21 Keowee also. The replacement of the rotor poles and 22 the stator, I guess that's for the electrical 23 generator part. What is the output of those 24 generators, and are there -- is there any, I guess, 25 why was that done and is there any life limiting 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 1 components on there?
2 MR. SNIDER: We are constantly maintaining 3 those units. I mean we very much have the long view 4 in line in terms of being able to maintain those 5 units. So it -- considering the -- a lot of that was 6 time-based in terms of just making the units reliable.
7 We consider all of Keowee in terms of what's needed to 8 maintain those generation assets, whether it's control 9 systems or the generating components. We are 10 continuing to make major upgrades to Keowee for the 11 life of the station.
12 MEMBER SUNSERI: Okay, and while we're on 13 this table, I don't want to get into a digital I&C 14 meeting here, but what was the scope of the safeguards 15 and reactor protection system upgrades?
16 MR. SNIDER: We completely replaced the 17 reactor protection and ES system with a digital 18 system.
19 MEMBER SUNSERI: The whole, everything?
20 MR. SNIDER: Complete upgrade.
21 MEMBER BROWN: That was actually reviewed 22 here. When I got here in 2008, that one was run past 23 us, although we did not have a specific meeting when 24 I was here. It might have occurred right before me.
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23 1 us a little bit about what a protected service water 2 system is?
3 MR. SNIDER: The protected service water 4 was a rather significant risk improvement action. It 5 installed an additional power supply, additional 6 cooling water pump, basically did a fairly significant 7 amount of work to -- a different way to get power into 8 Oconee.
9 As Rounette said before, I came to Oconee 10 in 2021. One of the things that really impressed me 11 about Oconee is the number of different ways we can 12 get power in to be able to support managing the units.
13 The protected service water project is largely another 14 way to get power to be able to support the safety 15 systems. It's additional power supply for the HPI 16 pumps, an additional cooling water pump.
17 MEMBER SUNSERI: I guess I'm losing the 18 connection there. Protected service water power on 19 it?
20 MR. SNIDER: The cooling water is a 21 secondary cooling water pump.
22 MEMBER SUNSERI: Right. So that doesn't 23 have anything to do with power supply though?
24 MR. SNIDER: There was additional power 25 supply as in a power line that came in as part of that 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 1 project.
2 MEMBER SUNSERI: Okay. That's not -- that 3 modification is not listed in this list, right?
4 MS. NADER: This is Rounette Nader. We 5 typically have just called this entire project a 6 protected service water project, but yeah, it was 7 bigger than just service water, as Steve mentioned.
8 MEMBER SUNSERI: Okay.
9 MS. NADER: So maybe a bit of a misnomer, 10 and that's because that's just typically what we've 11 called it. It was a very large multi-year project.
12 MEMBER SUNSERI: Okay, yeah. I'm just 13 trying sort out what protected and, you know, so I get 14 it. I understand what you're saying now. I think 15 that's all I have for now.
16 MEMBER HALNON: Yeah, and just one more 17 question. Back on the reactor vessel heads, the 2003-18 ish replacement, is that the proactive replacement 19 based on the MRP projects that said it's probably good 20 to get replacing, or are they reactive from the 21 standpoint that you actually had some cracking in the 22 CRDMs?
23 MR. SNIDER: It was, it was both. I mean 24 we were seeing indications and had to respond to 25 those, and it was obvious the best thing to do in 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 1 terms of nuclear safety was just to replace the heads.
2 I mean we continued to do inspections going forward 3 just --
4 (Simultaneous speaking.)
5 MEMBER HALNON: Any issues with the new 6 heads? No leakage, no indications or anything?
7 MR. SNIDER: No sir.
8 MEMBER HALNON: Thanks.
9 MEMBER BROWN: You know, this is Charlie 10 Brown. Just to turn this into a digital I&C meeting 11 again, I just wanted to refresh my memory that when 12 you say it was a digital system (audio interference),
13 my memory was that was a software-based, 14 microprocessor-based digital I&C replacement. I 15 remember some words like triple modular redundance and 16 a bunch of stuff like that --
17 MR. SNIDER: That's correct.
18 MEMBER BROWN: I just wanted to make sure 19 that was the one --
20 MR. SNIDER: That's it.
21 MEMBER BROWN: --I was informed was being 22 installed so --
23 MR. SNIDER: Correct.
24 MEMBER BROWN: And it had -- I presume 25 it's worked satisfactorily over the last 11-12 years?
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26 1 MR. SNIDER: Very much so. It was a 2 tremendous reliability and safety improvement related 3 to that situation.
4 MEMBER BROWN: Okay. Just wanted to 5 confirm that our expectations were met.
6 MR. SNIDER: It was one of the -- I want 7 to say it's one of the smarter decisions we made, to 8 launch off and do that and work through that.
9 MEMBER BROWN: A lot of analog stuff 10 doesn't have to vary. The software-based systems are 11 much more reliable for that kind of thing.
12 MR. SNIDER: That's correct.
13 MEMBER BROWN: All right, thank you.
14 MEMBER BALLINGER: This is Ron Ballinger.
15 To be clear, when you did the head replacement, you 16 went from 80 to 182 weld material and 600 to 52 and 17 152 and 690?
18 MR. SNIDER: I'm going to --
19 MR. TERRELL: This is Joe Terrell, and the 20 answer is that is correct.
21 MEMBER BALLINGER: Okay.
22 MR. TERRELL: They're all, those nickel-23 based materials are all stress corrosion crack-24 resistant materials.
25 MEMBER BALLINGER: That's what I thought.
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27 1 MR. SNIDER: All right. If there are no 2 other questions, I'll turn it back over to Rounette.
3 MS. NADER: Thank you Steve. Next slide.
4 Thank you. Before we move on, any other questions on 5 the plant and the upgrades? Okay, thank you. Next up 6 is Greg Robison. As I mentioned, Greg will mention 7 that -- Greg will discuss the Duke subsequent license 8 renewal process.
9 Greg has over 40 years' experience at Duke 10 Energy with work in nuclear design, construction, 11 programs and licensing. In the 1980's, Greg was 12 involved in the development of license renewal 13 concepts, and in the 90's the regulatory design, 14 including the development of the first rule and what 15 we then referred to as "the new rule," which is the 16 rule that governs our license renewal process today.
17 He went on to lead the successful Oconee, 18 McGuire and Catawba initial license renewal efforts, 19 and then spent the next almost 20 years leading a 20 number of high profile efforts for Duke, before 21 returning to his license renewal roots to lead the 22 Oconee subsequent license renewal project. We're 23 fortunate to have Greg's license renewal experience 24 and leadership on this project. Greg.
25 MR. ROBISON: Thank you, Rounette. Good 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 1 morning. Yes, Greg Robison here. Nice to be able to 2 share a few thoughts with you this morning. Next 3 slide, please. I thought I would start with an object 4 lesson this morning. We had taken this picture. I 5 guess this is the stack of paper representing the 6 application, 4,010 pages, 19 inches tall. Glad we 7 didn't have to bring 40 copies this time to 8 Washington.
9 MEMBER BALLINGER: Was it three-hole 10 punched?
11 MR. ROBISON: It had to be, yes, because 12 we put it in the Seneca public reading room, yes. So 13 I'm going to take a few minutes and talk about the, do 14 a little overview of the development of the 15 application, and then talk about final results, 16 programmatic results.
17 MEMBER HALNON: So how does that compare 18 to the first one you did?
19 MR. ROBISON: It's about another third 20 larger than the first one.
21 MEMBER HALNON: Not too bad.
22 MR. ROBISON: Simpler in there, and maybe 23 that fits into the discussion of the standards here.
24 So we did have an in-house development team pull this 25 together. We had about 20 people on the core team 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 1 pulling this together. The idea was -- you see many 2 of them here with us today. We had technical, project 3 management, legal and licensing support and expertise 4 there on the team, many of which had previous license 5 renewal experience, and a number of which had pervious 6 Oconee experience.
7 So we had a nice blend of historical 8 perspective as well as working on the new perspective, 9 as we worked part of the team. We had key vendor 10 support with Framatome, Structural Integrity and 11 Enercon. Enercon helped us put our environmental work 12 together. So we had, we reached out to the industry 13 strengths and added them to the Duke team. So I feel 14 like we had a really strong people side effort here.
15 Talk a little bit about contemporary 16 guidance. We did use all of the current guidance.
17 Yes, as Brian introduced, we were a pre-GALL plant.
18 I'm going to speak a little bit more about that in a 19 few minutes. I just was very impressed with the 20 guidance that we have available today, compared to 21 what we had back in the 90's. It's coming along very 22 mature. It worked. I came in as a skeptic and I'm 23 going out a believer, and that's probably the 24 strongest testimony I can give.
25 We used the contemporary guidance for 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
30 1 scoping and screening, aging management, time-limited 2 aging analysis work, as well as the programmatic aging 3 management program work.
4 Next slide, please. The other thing we 5 added to the recipe to build the application was 6 lessons learned and experience. We reached out to the 7 industry. I want to say a thank you to the lead 8 plants for guidance interpretation, SLR GALL guidance 9 and SRP interpretation.
10 Issue resolution, we followed them right 11 along, made sure we understand what they were working 12 on. They were more than gracious to provide that 13 guidance to us, so we could apply it to Oconee, and 14 then that ended up resulting in a license renewal 15 application that I believe was very readable and 16 structured in that way.
17 The License Renewal team at Duke 18 participated at the industry level. We were around in 19 the development of SRL, the GALL SLR. That helped 20 shape our perspectives there. We supported other 21 applicants during peer reviews and they supported us, 22 which built quality into our work.
23 From there, we actually reached out to our 24 current program owners at Oconee, to understand where 25 we are on the initial licensing programs. We knew 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
31 1 that was our starting line. So we wanted to go and 2 very much immerse ourselves in that and understand 3 that starting line, as we looked towards 80 years of 4 building programs that would work through the 5 subsequent period.
6 We also worked with them when they had 7 their -- and I believe we'll talk a little bit about 8 that. The NRC will talk about that later this 9 morning.
10 MEMBER HALNON: So Greg, you mentioned you 11 reached out to the program owners. Was the first 12 license renewal, commitments and program changes and 13 all those, were those just integrated into the normal 14 way of doing business, or did you have a separate 15 license renewal type person that's tracking these 16 commitments?
17 MR. ROBISON: When we left, we actually 18 had a separate person for a good long, and we do still 19 now. We have a fleet level person that's doing that 20 for us now, and that was something that we felt was 21 important at the end of initial license renewal, when 22 the team turned over the commitments to the site. We 23 wrote them down and we felt like we needed to leave 24 someone there that could help with the interpretation, 25 and as the implementation and procedures and things 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
32 1 were written.
2 We just didn't hand it to the site and let 3 them figure it out on their own, and that person 4 helped guide the development of the programs. That 5 trend has continued. So we've had a person there 6 helping do that interpretation and, you know, again 7 for subsequent renewal when we looked back, we have 8 many program owners who very much understand how the 9 programs work and what their responsibilities are. So 10 we've seen that grow as well.
11 MEMBER HALNON: Any intent to keep that 12 person in place in the subsequent part?
13 MR. ROBISON: Yes, yes. We will keep that 14 person in place for the fleet. We have that person 15 very actively involved. In fact, they were in there 16 leading the site efforts, the fleet person was leading 17 the site efforts for the Phase 4 inspection.
18 MEMBER HALNON: Okay.
19 MR. ROBISON: And we're cross-pollinating 20 our younger generation now.
21 MEMBER SUNSERI: Yeah, okay. I have 22 somewhat of a leading question, but I don't know to 23 how to ask it anyway, otherwise. But I imagine you 24 tracked some of these activities through your 25 corrective action program, and you must have some kind 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 1 of commitment tracking program, and then you take all 2 that and update your UFSAR as necessary. Is that 3 accurate or can you describe how that --
4 MR. ROBISON: Your description is very 5 accurate, and it's a dynamic process. It's not just 6 static, we leave the procedures and don't really look 7 at it. We're following the results.
8 The programs as we designed them were 9 learning programs, and they have that feedback 10 mechanism too, and we use the corrective action system 11 and we let that feedback, both from the industry 12 experience as well as plant experience and fleet 13 experience, grow those programs, and they continue to 14 mature over time.
15 MEMBER SUNSERI: Thank you.
16 DR. SCHULTZ: So Greg, the peer review for 17 Oconee. Could you expand on that a bit? Who 18 participated in that review and what were, what were 19 the findings that improved the application?
20 MR. ROBISON: I'm going to have to ask 21 Heather. Heather, do you recall who did the peer 22 reviews for Oconee application, the other utilities 23 that we had?
24 MS. GALLOWAY: I have to look.
25 CHAIRMAN REMPE: So your name, excuse me.
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34 1 You need to say your name and speak loudly.
2 MS. GALLOWAY: This is Heather Galloway 3 with Oconee License Renewal, and I can look it up 4 really quickly and let you know who our peer reviewers 5 were.
6 CHAIRMAN REMPE: Great, thank you.
7 MR. ROBISON: Yeah, thank you Heather.
8 Sorry Steve, I'm just drawing a blank.
9 DR. SCHULTZ: Any comments related -- I'm 10 just curious on how that process works. You 11 participated in the reviews and had this done for this 12 application, and what are the general findings that 13 come out of that review?
14 MR. ROBISON: Let us get that answer for 15 you. I can tell you that for the peer reviews more 16 recently that we've done across the industry, we've 17 been a little more selective about -- rather than 18 trying to do a broad 4,000-page review for someone, we 19 pick key areas that we had expertise in, so that we 20 could provide that quality feedback and not just give 21 them general editorials. Let us, let us get that 22 answer on Oconee specifically. Sorry, I'm drawing a 23 blank this morning.
24 DR. SCHULTZ: We have time. Thank you.
25 MR. ROBISON: Yeah.
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35 1 MEMBER KIRCHNER: Greg, this is Walt 2 Kirchner. I'm doing this virtually, so I'm sorry I'm 3 not there. My question is do any of these AMPs, did 4 they factor in that rather extensive list of plant 5 upgrades that you'd made over the years?
6 MR. ROBISON: Yes, very much so. The 7 programmatic oversight is of the plant as it exists.
8 So If we've added to the plant, to the extent that it 9 touched the program, we've applied that -- the new 10 population into that program. We don't just leave the 11 programs focused like they were 20-odd years ago.
12 They continue to be expanded as the scope needs to be 13 expanded.
14 DR. SCHULTZ: Thank you.
15 MR. ROBISON: Next slide, please. So that 16 was the development side. I'm going to talk a little 17 bit about process advancement, picking up on the 18 things Brian said this morning about the fact we were 19 pre-GALL, and I'm going to do a little compare and 20 contrast just to sort of give us a feel for what I 21 consider the evolution toward a very mature standard 22 that we have in the industry today.
23 The initial license renewal, we were the 24 second plant in the country to get licensed in May of 25 2000 as you said. GALL was still in the formative 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 1 stages. We actually were working with the NRC staff 2 to try to frame up, as part of the industry efforts, 3 what the big technical areas were and how we would go 4 about putting our arms around that.
5 The ten elements that we came up with for 6 programs was all vetted during that period of time, 7 and we applied those lessons at Oconee based on good 8 engineering, good science and the structure that we 9 thought best at the time, you know. We didn't have 10 any written guidance, so we did the best we could to 11 come up with a good engineered way to do things.
12 What I can see today is the maturity of 13 those programs. Even though you look back and say 14 well, they're not lining up perhaps with GALL over 15 time. We were the prototype, If you will, of those 16 early days. Ten elements, the way those -- the way 17 the programs were structured.
18 The implementation of those programs over 19 the last 20 years, it's the maturity of those that I 20 think has really advanced, giving us a good foundation 21 to build subsequent renewals on. The pieces of the 22 work that we have here for scoping and screening you 23 see on the slide did follow GALL SLR and the standard 24 review plan today. We had a couple of changes from 25 initial license renewal that was a reinterpretation of 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 1 10 C.F.R. 54(a)(2).
2 It's not wrong what we did before, but 3 we've enhanced it. We broadened that view and defined 4 it and understood it a little better as a good debate, 5 a good understanding would be. So we've actually 6 added scope to the subsequent renewal programs that 7 will manage the aging of a little broader population.
8 An example could be piping in the turbine building, 9 where we've had some pipelines that are safety-related 10 coming through that area.
11 We expanded the non-safety piping in the 12 area and equipment in the area that we're going to 13 manage the aging of, so that we don't impact. Should 14 a failure occur of the non-safety, there won't be any 15 impact on safety. We did that before. We just 16 broadened the scope today. It's -- and it really just 17 adds more population to an existing program.
18 It wasn't like we had a deficiency or 19 something new had to add. We just had to broaden the 20 population. Another area where we've made a change is 21 NFPA 805. We've moved from the old Appendix R 22 standards to a very structured NFPA 805. What that 23 did in the redefinition of fire protection, it ended 24 up adding a few new features to the plant to the fire 25 protection program, and we picked that up.
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38 1 That was a licensing change made since 20 2 years ago, and we were able to just flow that right 3 into the programmatic actions for subsequent renewal.
4 So there are two examples of the growth of things.
5 DR. SCHULTZ: Greg, on the 54 alpha 2 6 changes, does that affect all the AMPs or just the new 7 AMPs that are associated with subsequent --
8 MR. ROBISON: It affects all the AMPs.
9 DR. SCHULTZ: Okay.
10 MR. ROBISON: Yeah. For example If we had 11 an airline or non-safety potable water line that 12 happened to be somewhere and we judged very 13 conservatively let's worry about that. We added that 14 or made sure that was included, and even If a current 15 AMP covered it, we expanded the population --
16 DR. SCHULTZ: It's noted in your long 17 table of AMP reviews that a number have -- a number of 18 the current ones have been expanded. And so it's 19 pretty much due to this?
20 MR. ROBISON: It was somewhat -- well, it 21 was somewhat due to this, but a lot of it was to bring 22 those programs up to current standards. So there were 23 enhancements today, and I think this is a very 24 positive. There were enhancements to the today 25 programs as the GALL SLR gave us additional insights 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
39 1 and maturity on the way the programs could be 2 conducted for the future.
3 It just allowed us to make them better.
4 So that's what you'll see. I'm going to cover that in 5 a just a second.
6 DR. SCHULTZ: Thank you.
7 (Simultaneous speaking.)
8 MEMBER HALNON: Sorry, I'm going to turn 9 your words around. You had programs out there that 10 were not up to current standards?
11 DR. SCHULTZ: That was my next question.
12 MR. ROBISON: We do not have -- we have 13 programs in the plant that meet the program standards 14 of the plant, the licensing basis of the plant.
15 MEMBER HALNON: Okay, I think. So this 16 applied --
17 MEMBER SUNSERI: So I was going to ask the 18 question a little differently. I was just using his 19 words. I imagine, and I could get over my head real 20 quick on this because I'm not a PRA expert. I imagine 21 NFPA 805 is going. So you did a fire PRA or something 22 as a result of that, and that identified components 23 that are more important and maybe they were given 24 before.
25 So now those get looked at, they're 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 1 important to safety. So they get amplified to them 2 and you manage it that way, right? That's -- it's not 3 because there's an AMP that you do it. It's because 4 you identify important equipment that needs aging 5 management?
6 MR. ROBISON: That's right.
7 MEMBER SUNSERI: So there's other areas in 8 your performance improvement and oversight of 9 performance where you're going to identify, you know, 10 things that are important that may not have been in 11 the past, based on whatever lessons learned in the 12 industry or whatever, right?
13 MR. ROBISON: Yes. In the case of NFPA 14 805, when you go through the license renewal process, 15 they scoped in additional things that were not scoped 16 in in initial license renewal. So it was the 17 application of NFPA 805 that added these additional 18 important safety items that we picked up in the 19 programs.
20 And now that, you know, that -- we had 21 picked them up informally, you know. If it's a wetted 22 carbon steel system, we were looking at all the wetted 23 carbon steel systems for aging issues. But now for 24 subsequent renewal, they were very much more formally 25 involved in the programs, because they came with this 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 1 licensing change.
2 MEMBER SUNSERI: Thank you.
3 MR. ROBISON: So real quickly to get 4 through the rest of this, and then we'll go talk to 5 some programs. Scoping and screening was done to 6 contemporary standards. Aging management reviews, I 7 had some wow statistics for you. 93.3 percent, that 8 doesn't even tell the story. It's 13,676 AMR lines in 9 the application, aligned with GALL Notes A through E.
10 There are 72 lines that don't align with 11 A through E. So that'll give you a feel for how we 12 were able to meet the contemporary standards with the 13 design of the actions that are for subsequent renewal.
14 A pretty significant use of the guidance, the mature 15 guidance that's there.
16 Applying GALL gives us that enhanced feel, 17 that enhanced programmatic foundation to stand on for 18 subsequent renewal. We feel very good about that, how 19 it's helped us see how to mature the programs. We're 20 in good shape there. Next slide, please.
21 MEMBER SUNSERI: And just for continuity, 22 then a question. Those 70 whatever lines that didn't, 23 what would you say correspond or I forget what the 24 word is, are those the exceptions and enhancements 25 that you made?
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42 1 MR. ROBISON: Yes, they're the exceptions, 2 and I'll give you a couple of examples.
3 MEMBER SUNSERI: Okay, perfect.
4 MR. ROBISON: Where was it, where we are.
5 48 subsequent license renewal programs that I'll speak 6 to, we had 26 programs pre-GALL in initial license 7 renewal, plus a number of preventive maintenance 8 activities, proceduralized activities. We didn't know 9 in the mid-90's exactly how to capture the actions 10 that were already being taken in maintenance 11 procedures that were aging management techniques.
12 And we were still inventing the ten 13 elements of a program and all. So what we credited 14 initial license renewal was preventive maintenance 15 activities. It's hard to count all of that. So they 16 don't -- the numbers 26 and the 48 don't line up 17 exactly.
18 I'll give you a couple of examples. Same 19 action, different program. In today, in the license 20 renewal efforts today, we looked at external surfaces 21 of mechanical -- as part of our structural monitoring 22 program. For subsequent renewal, it's going to be its 23 own program. The same actions are being done. We're 24 just going to call it, bring it out, call it something 25 different today. So if you're doing tally marks, 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 1 you're going to do a tally mark today compared to what 2 we did in initial renewal.
3 Another area that's a little different is 4 our FERC/NRC jurisdictional boundary area at Keowee.
5 The GALL SLR and standard review plan did a very nice 6 job on water control structures of being very clear 7 where the FERC aging management responsibilities fit, 8 and the NRC aging management responsibilities.
9 Now what does this mean? It means that 10 the water control features at Keowee are part of the 11 component set for license renewal for Oconee. The 12 aging management program for those is the FERC 13 programs. We didn't have to re-review those. There 14 was an acceptance of the FERC five year inspection 15 work that is already going on. We're committed to 16 that.
17 We've just renewed the license of Keowee 18 with FERC, and all of that work will continue on into 19 the future. They just don't have to be fully 20 investigated as part of the aging management work like 21 we're looking at other parts of Keowee, that produce 22 the power Steve has mentioned. For those, we use the 23 structural monitoring program. We're actually in the 24 plant looking at the structures, looking at the 25 features of the plant that we can do as a part of the 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 1 Oconee Engineering team.
2 So that jurisdictional boundary definition 3 that didn't exist back in the 90's, is much clearer in 4 the standards today. We were able to take credit for 5 that in the tally, the tally mark on the number of 6 program changes for that.
7 So just a couple of examples of how things 8 have changed, and I hope you get a sense that they 9 didn't -- we didn't regress or go differently.
10 They're just advancements that we were able to explain 11 a little bit clearer today versus 1995-1996.
12 MEMBER SUNSERI: So you mentioned 13 something that I just wanted for clarity to follow up 14 on. Your first example for the Keowee was that you 15 had some maintenance activity you were doing for the 16 initial license renewal that in the subsequent you're 17 going to pull those activities out and do them as a 18 separate program?
19 MR. ROBISON: Yes.
20 MEMBER SUNSERI: So looking ahead, I mean 21 we've reviewed all the post-license renewal inspection 22 reports. I think there's four or five of them and 23 there was an integrated Phase 4 report also. You 24 demonstrate very -- you have demonstrated very good 25 compliance. No findings in any of that. That's good.
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45 1 How are you going to ensure that that shift in the way 2 you're doing that is going to -- you can keep 3 compliance there?
4 MR. ROBISON: We'll do it in a couple of 5 ways. One is we'll update the UFSAR based on the 6 results of subsequent renewal. Number two, as we were 7 discussing about having the fleet oversight person 8 there, they will make sure that those commitments get 9 addressed. If it means taking credit for a procedure 10 and transitioning it to a more structured program, 11 we'll have somebody there with the knowledge to make 12 sure that gets done.
13 We won't just turn it over and hope that 14 the plant can figure it out. We'll actually walk them 15 into it and then the plant will have the program and 16 the program owner name, and that person will continue 17 to carry forward the responsibilities. So we very 18 much have a transition plan.
19 MEMBER SUNSERI: Okay. Well, that's good.
20 I mean I would just -- this isn't a negative criticism 21 or anything. But I would just say sometimes the old 22 way of doing business has proven to be good and you 23 could enhance yourself in a more difficult way. I'll 24 leave it at that.
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46 1 were discussing, and I forget who I was discussing 2 with, the transition to a new generation, and part of 3 the value of doing this in a structured way, to 4 transition in a structured way, is the education 5 process for the next generation of owners. So we are 6 very keen on that as well, and so that's why I'm 7 emphasizing the transitions.
8 We're not, we're not going to leave a 25 9 year-old to go figure out what we wrote in a pile of 10 paper years before. We're going to work to make sure 11 that that gets done, and we did that with initial 12 license renewal. We wrote some post-renewal specs 13 that detailed procedural level changes that had to be 14 made in order to implement the commitments.
15 So we went to that level of detail, to 16 make sure we were ready to implement the commitments.
17 MEMBER HALNON: Yeah. Well, this is not 18 to put words in your mouth, but the way I'm looking at 19 in my head is that you're kind of -- you're weeding it 20 into the normal way of business, in addition to 21 supplementing it with the historical aspect of why 22 it's there and why it has to be important.
23 So that to me is a good, a really good 24 foundation for keeping that compliance in the future.
25 A new generation will come in and it's a combination 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 1 of here's the procedure, here's the established way of 2 doing things, and here's why it's very important. So 3 it's to me a very good mixture.
4 MR. ROBISON: It was important to me back 5 in the 90's that we wrote specifications, technical 6 documents as basis documents. Just like we had the 7 design basis program in the early 90's, late 80's-8 early 90's, we wrote license renewal basis documents 9 that capture that history, provided that foundation, 10 and then we were able to build forward from that.
11 So we had the person and a document, and 12 we're doing the same thing here. Technical basis 13 documents that will be a part of the record, that will 14 be readable and they're like study-able, and then 15 we'll have people involved with that transition.
16 HH Yeah. So the key question is do you 17 have an app yet that can --
18 MR. ROBISON: You're onto something, and 19 one of my pet peeves.
20 MS. NADER: Greg's favorite word, there's 21 an app for that. This is Rounette Nader. I was just 22 going to expand a little bit on that, because I do 23 lead the efforts for implementation, the 24 implementation for the commitments for license 25 renewal. So what we've -- the Duke model is when we 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 1 get a renewed license, initial or now subsequent 2 renewed license, as we get closer to the period of 3 extended operation or the subsequent period of 4 extended operation, we put a team together to 5 implement those specific commitments that are 6 necessary before entering into that PEO or SPEO.
7 So that project team is put together to 8 specifically work on implementation of those 9 commitments. What they do, in addition to ensure the 10 commitments get met, is they also write the AMP basis 11 documents and they work with the program owners at the 12 site, and they leave them with those AMP basis 13 documents.
14 So they manage that transition, so that 15 the site and the fleet program owners can own that 16 when they move to the next plant, to manage that, the 17 implementation of the next plant. So that's the Duke 18 model. As Greg said, when the application team, you 19 know, goes away, we actually bring in a second team to 20 implement the next commitments, and then that team 21 transitions.
22 MEMBER HALNON: So then to -- for context, 23 when is the SPEO for Units 1, 2 and 3? Do you have 24 that off the top of your head?
25 MS. NADER: 2033 for Units 1 and 2.
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49 1 MEMBER HALNON: Okay, so a decade from 2 now. So there's going to be some education needed, 3 self-education probably because many of us won't be 4 around to even talk about it.
5 MS. NADER: That's right, and that's --
6 and that's been the case even for initial license 7 renewal. You know, Oconee was an early initial 8 license renewal plant, so the PEO was even further 9 away than it is this time. So that's why we bring in 10 the project team, because some time has passed.
11 We leave, the application team leaves a 12 good legacy, but the implementation team, comes in, 13 picks up that information to make sure that it gets 14 disseminated out to the program owners.
15 DR. SCHULTZ: Thanks. You have some do 16 AMPs that will start, that the programmatic portion of 17 those are going to start before, well before SLR? In 18 other words, five years before you need to start 19 gathering data and monitoring overall performance, in 20 anticipation of moving into the subsequent operations?
21 MS. NADER: That's correct. We will put 22 the implementation team in place shortly. Even though 23 it's a decade away, yeah. That work takes several 24 years.
25 MR. ROBISON: We're actually already 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 1 discussing that, and I'll hit the last point and I'm 2 going to hurry on through my stuff. We're not doing 3 anything, we're not making any promises that we don't 4 give the program owners today at the site, to help 5 temper and understand. You know, we can't promise we 6 can do something and then can't help them out.
7 So we went to the experts, you know. We 8 made them part of the team, and that was part of the 9 maturity that we -- they gave us the quality, the 10 feedback on the programs. We walked the plant with 11 them. We talked about it. Before we wrote it in the 12 application, we had it checked and tempered by the 13 program owners.
14 I thought that was a nice addition, you 15 know. You can make promises. You can make all the 16 promises you want. But keeping the promises becomes 17 very difficult If you don't do that right. So we 18 wanted to make sure that we did that right, and that 19 involved our fleet and our plant program owners. Even 20 on the new programs, we would ask their opinion, we 21 would get their insights as we were proposing actions 22 so --
23 Next slide, please. Now let's talk some 24 numbers. I mentioned there were 48 programs. You see 25 they're in Column 1 to the left. There's 48 total 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 1 programs, 34 existing, 14 new. Let me walk across 2 pretty quickly here the existing line and the new 3 line, and I'll tell you how the -- I'll give you an 4 example of one or two of these as we go, If that's 5 okay.
6 I'm going to work across the existing 34 7 line there. The second box over is consistent with 8 GALL, absolutely consistent with GALL. There were six 9 of these. This is water chemistry, the Stalwart 10 program, things that are just there and we're going to 11 use forecasting corrosion, steam generator 12 inspections. They don't change. They're there. GALL 13 describes them very well. It's what we're doing 14 today, many of them industry-based.
15 Column 3, 20 programs with enhancements.
16 So this is almost half of the program, half of the 48 17 were existing programs that were good, but they could 18 be better and enhanced with insights from GALL SLR.
19 This is where my skepticism was. Are we going to 20 really get anything out of this? When I got there, we 21 got into it. Yes, we do.
22 The industry's in really good shape with 23 the guidance documents that we have today, because 24 it's captured. It's the basis document. It's 25 captured those lessons learned, and we were able to 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 1 apply those with the 20 existing AMPs here. We did 2 have a couple of exceptions here in Column 4. Just to 3 give you an example, the concrete containment pre-4 stress monitoring.
5 Early in plant life, we were collecting 6 data in a certain manner. We discovered somewhere in 7 the 90's that we weren't really getting the right 8 data. We were not using random tendons. We were 9 using sample tendons. This was something we made up 10 in the 70's and said we'll go and just go into the 11 test bite, kind of we'll see.
12 Well what we -- what it dawned on us was 13 because you -- it's just like any system where you --
14 If you put your hand in a system, you influence a 15 system and now you become part of the system. Well, 16 we were doing sample tendons and we were collecting 17 data on the same tendons over and over, and realizing 18 we weren't getting the health of the building. We 19 were getting the health of a modified sample tendon.
20 So somewhere in the 90's we changed that 21 technique. GALL comes along and GALL SLR says use the 22 total lifetime set of data. I don't want to use the 23 total lifetime set of data. I want to use the last 25 24 years' worth of really good data on the health of the 25 building. So I had to take exception to GALL to be 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 1 able to do that, but I'm -- the exception I'm taking 2 is because I don't, I can't use that early data.
3 But I do have a wonderful set of data for 4 the last 25 plus years, that tells me the health of 5 the building. We've applied it, we can draw it.
6 We've drawn graphs. I believe we had some of that 7 information in the application, to really have a good 8 feel for where the building is in its life, If you 9 will, based on this later data.
10 So it required us to take almost a 11 procedural kind of exception, but didn't impact the 12 program at all. So that's an example of where we had 13 to make a modification to the standard, but we did it 14 in a very thoughtful and mindful way to make sure 15 we're in good shape going forward.
16 Let's see, that's Column 4. Column 5 with 17 exception and enhancement. Here's a fire water 18 testing example. We have dry pipes with a deluge 19 valve. The GALL would ask us to go and do a pressure 20 test on dry pipe. We would do the pressure test on 21 wet pipe, the system, the system kind of pressure 22 test. We don't have water in the system. It's dry.
23 We took exception to the standard wording 24 there because of the system configuration. The 25 enhancement, however, is going to ask us to go do an 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 1 internal inspection. Find a way to get a camera or 2 something into the dry portion of the pipe, to take a 3 visual. So we had to modify the standard in GALL to 4 get the answer that we, you know, that we felt were 5 the proper aging steps. It made perfectly good sense 6 to do that.
7 So you see it showing up. There's five of 8 these, but we were again very mindful and thoughtful 9 about how we did that. We just didn't dismiss it out 10 of hand because we didn't want to do it. We found 11 other ways to do it that didn't match up to the 12 standards.
13 MEMBER HALNON: So Greg on that dry 14 pipe/wet pipe, is the program deep enough to If it's 15 called to duty and is used, that there's an inspection 16 post-actuation so you check it then, or is it just 17 this one inspection of the dry?
18 MR. ROBISON: It will do -- we will do the 19 inspection periodically. It will be over the 20 remaining life of the plant, you know.
21 (Simultaneous speaking.)
22 MEMBER HALNON: So there's no specific 23 thing that --
24 MR. ROBISON: It wouldn't be triggered by 25 -- no, it wouldn't be triggered by an action, because 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
55 1 what we would want to make sure is the system is ready 2 if called upon. And so we will have a periodicity to 3 those --
4 MEMBER HALNON: Right, and the point is is 5 that if it's called upon, it's been put through a 6 cycle, it's wet now, is that an opportunity to see did 7 our inspections reveal everything that we expected 8 them to reveal?
9 MR. ROBISON: Right.
10 MEMBER HALNON: So the question is would 11 the program trigger the system engineer or the owner 12 to go out and take a look at that?
13 MR. ROBISON: We had to flood that pipe 14 and use sprinklers. We had other things to inspect.
15 We would have to -- we would have to do a larger 16 inspection to put the plant back in condition, to go 17 back into operation specifically. We would -- we 18 probably would have had a fire and needed that system 19 to actuate.
20 MEMBER HALNON: It could have been 21 inadvertent. It could have been inadvertent.
22 MR. ROBISON: And then, you know, then you 23 would do -- you would re-inspect it as part of a 24 broader inspection.
25 MEMBER HALNON: Okay.
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56 1 MR. ROBISON: The last thing we had was 2 the plant-specific. We have a design feature inside 3 containment. We have a secondary shield wall and the 4 panels -- and the panels are connected by the tendons.
5 I don't know If other people in the industry have this 6 design, but the tendon needs -- we need to go inspect 7 these tendons periodically. I think there's 14 of 8 them or something like that that connect these panels.
9 So we have a plant-specific program. It's 10 not described in GALL. This is a part of initial 11 license renewal. The ten elements are all defined.
12 We've got data. We had a really interesting, good 13 discussion with the staff about the aspects of the 14 program as a part of subsequent renewal and that's 15 been captured in the SC as well. So that's the 16 existing programs, okay. We're good with that.
17 Quickly then, the new programs. We have 18 the -- 11 of the 14 are consistent with GALL. We just 19 use the aspects of GALL, walked through the plant, 20 looked at the features of the plant. They line up 21 perfectly with that. You obviously can't -- the next 22 column. In the third column, you can't enhance a new 23 program because it's new.
24 So we did have -- we did have three 25 programs that took exception to GALL that were new 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 1 programs. Example here was selective leaching.
2 Rather than doing it on a unit basis for a three unit 3 plant, we said we would have a bigger population. If 4 we did it on a site, we'd take exception to GALL. We 5 said let's do it on a site basis, have a bigger 6 population.
7 If there is a trend, If there is something 8 showing up, we want the program to be looking across 9 the site, all three units. So we said that made more 10 sense, and so we proposed that change and that's been 11 accepted. So a little, a little tweak, a little 12 maturity on a plant-specific aspect to make it make 13 sense to us.
14 And so they weren't significant 15 exceptions. They were just we hope wise exceptions.
16 That way we're going to leave it. We had no, no 17 exceptions, enhancements in the plant-specific new 18 programs, and that's the 48. Let me stop for a 19 second. Any questions on -- I had to go kind of 20 quickly on that.
21 MEMBER KIRCHNER: Greg, this is Walt 22 Kirchner again. As you did all this, did you find any 23 -- this makes for a very comprehensive examination of 24 the physical health of the plant. Did you find 25 anything that is not identified in the GALL SLR, the 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 1 NUREG reports, or did you find anything that surprised 2 you as you went through the plant to prepare for this, 3 that might not have been identified in, you know, the 4 GALL framework?
5 What I'm asking, I guess, is you know, 6 were there any surprises or things that in the course 7 of doing all this that might not have been identified 8 in a GALL program?
9 MR. ROBISON: Thinking about it no, I 10 don't know that anything came across as a real 11 surprise. When we put together license renewal back 12 in the late 80's and early 90's, we reverse-engineered 13 root cause studies back on those days. It turns out 14 there's five things that happen to mechanical systems, 15 thin, crack, deform and brittle or leak-altered 16 joints.
17 So that's the end point of all of the 18 work, and If you take that and go into the standards 19 and you look for that and make sure that we're hitting 20 one of those end points, and we are. So I didn't find 21 any surprises because I found the end point that we 22 were after, that we had thought about when we were 23 doing all the academic work many, many years ago.
24 And that's why I think the GALL standards 25 as they're written today are really a good compilation 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 1 of all of that experience over the last 30 plus years, 2 to pull that together.
3 MEMBER KIRCHNER: That's good, because 4 what I'm -- where I was going was, you know, just 5 having a different set of eyes on things and making 6 sure it's just not a compliance exercise. It's really 7 more than that, and it sounds like that's what you've 8 done. Thank you.
9 CHAIRMAN REMPE: So I have a question, if 10 that's okay Matt?
11 MEMBER SUNSERI: Yeah.
12 CHAIRMAN REMPE: I've really appreciated 13 this overview of the whole program and the perspective 14 you've provided today, and I'm just wondering, I keep 15 thinking about that picture of 19 inches of paper. Is 16 there something that could further improve, or do you 17 have any thoughts now on this process? Is there 18 something that you thought well this really wasn't 19 worth our effort?
20 MR. ROBISON: No, I can't think of 21 anything to improve it. I mean our -- again, I'm 22 thinking back many, many years when all this design.
23 The scoping makes sense, the screening -- aspects 24 makes sense. The aging management review makes sense.
25 The techniques and the way we documented in the big 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 1 tables now, the 13,000 plus items make sense.
2 I mean it's a little rote, hand over hand 3 kind of things, but it's necessary. We need to do 4 that.
5 CHAIRMAN REMPE: Thanks for the 6 perspective. Thank you.
7 MR. ROBISON: I'm going to stop here and 8 turn it back over to Rounette.
9 MEMBER SUNSERI: Yeah. I'm just going to 10 note we have about 20 minutes allocated for this 11 session and we've got the three technical topics, and 12 we probably will get more questions. It's not your 13 fault, but we're going long here since we're asking a 14 lot of questions, so it's a good interaction. If we 15 go a little longer, that's okay. I think we have time 16 to make it up. I just want to be mindful of the 17 staff's time and they have 45 minutes as well.
18 MS. NADER: Okay, and I think we're also 19 -- Heather Galloway is ready with the answer to the 20 question about the peer review.
21 MS. GALLOWAY: This is Heather Galloway 22 again, and the question asked earlier was who 23 participated in the Duke Energy industry peer reviews.
24 We had Excelon, Dominion, NextEra and Entergy 25 participating in those, as well as members of our own 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 1 License Renewal Implementation team, who are also very 2 knowledgeable on license renewal and the process, also 3 participated in our peer reviews.
4 As far as what did we -- what were our 5 learnings from the peer reviews? That was the follow-6 up question. We had about 375 comments from the peer 7 reviews, and we incorporated all but three comments.
8 So If we could bucket those findings, one of the 9 biggest areas was in electrical scoping methodology.
10 We took an all-in approach to electrical 11 scoping, and we had to go and refine that, because 12 that all-in approach would have included -- would have 13 had us including all buildings on site, all structures 14 on site. So by refining that methodology, we were 15 able to, you know, pull back the scope of license 16 renewal a little bit in that area.
17 We also did -- they did very focused 18 reviews on specific aspects of Chapters 2-3, and then 19 a very specific TLAAs in Chapter 4 that we asked them 20 to look at, mainly the Class 1 type, the thermal or 21 the metal fatigue, the reactor vessel type work, as 22 well as our tendons. So they provided us feedback in 23 those categories as well, as well as the AMPs.
24 And then separate from that industry peer 25 review, we also had Excelon go in and do I'll call it 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 1 a deep dive into each one of our AMPs, where they went 2 and looked at the ten elements and compared the ten 3 elements as we had identified them compared to GALL.
4 So they did that relationship for us, to see how 5 aligned we were. We took some learnings from that and 6 improved our programs, to be better aligned with GALL 7 as well.
8 DR. SCHULTZ: Great response. Thank you.
9 MEMBER BROWN: I want to ask -- can I ask 10 a question before on your 19 inch stack? I'm not 11 sure this got asked before, that so it was about a 12 third bigger than what you did for the initial SLR, 13 initial license renewal some years ago. Could you 14 pinpoint what drove the additional, 33 percent 15 additional paper?
16 MR. ROBISON: A lot of it was just the 17 inclusion of a lot of information this time the staff 18 felt they needed to review. As the example, I 19 mentioned the basis documents we wrote back in the 20 90's. Those documents received a lot of review at the 21 site. We did several site inspections, and some of 22 the materials that we had kept at home last time we 23 put in the application this time. So that ended up 24 adding materials to the document.
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63 1 of requirements that staff imposed? It was more your 2 inclusion of previous information, that then they 3 requested information to complete their review of it?
4 MR. ROBISON: It was, yeah.
5 MEMBER BROWN: Did I say that properly?
6 MR. ROBISON: That's a good 7 characterization, yes.
8 MEMBER BROWN: That's a lot of paper, 9 particularly after you completed one.
10 MR. ROBISON: So here's another wow 11 statistic. I think I did this. My wife got mad, 12 because I had it stacked in the corner of the dining 13 room. We produced about ten feet of technical paper 14 for the initial license renewal application of 14 or 15 15 inches or whatever it was.
16 So you know, just order of magnitude kind 17 of thing. This time, we probably produced on the 18 order of ten feet of paper, and a big chunk of that 19 went into the application, because electronically it's 20 easier than hauling it up here by van like we had to 21 do last time. We were able -- by that, and I think, 22 you know, the staff can corroborate, but they needed 23 that as part of their review.
24 Last time we had 400 and something RAIs 25 that pulled that information out of the technical 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 1 basis. We didn't have to have that many this time, 2 because we had provided it with the application 3 materials.
4 MEMBER SUNSERI: It's probably 5 insignificant compared to licensing a 2,300 megawatt 6 brand new plant though.
7 DR. SCHULTZ: These days.
8 MEMBER BROWN: I guess the other question 9 I had, the adjunct question that I think goes along 10 with -- this is Charlie Brown by the way, If nobody 11 doesn't know who I am -- is you got all the extra 12 paper. But on a time, on the initial license renewal 13 you had X amount of findings. I presume you had some 14 idea of how much manpower and stuff you expended on 15 that. Did that change significantly for the SLR?
16 MR. ROBISON: It did change because part 17 of what we had to do, we're training new staff. So we 18 had a level of experience this time and a level of new 19 this time that we didn't have last time. We were all 20 brand new last time and inventing the process. We had 21 probably twice as many people this time than our 22 initial License Renewal team.
23 But we were very much more focused this 24 time. Last time we were coming out of the research 25 world and writing basis documents and then extracting 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 1 from that, and trying to figure out a good way to 2 communicate our understanding of the aging basis of 3 the plant. This time with GALL and the structure that 4 was there, it was very easy to apply the people to the 5 tasks that were there, and go ahead and begin to train 6 the next generation.
7 MEMBER BROWN: So the refinement of the 8 GALL actually helped the process?
9 MR. ROBISON: Yes sir, it did.
10 MEMBER BROWN: That's what I'm taking away 11 from. We went through that years ago, so all right.
12 Thank you very much.
13 MEMBER BIER: Excuse me. I just want to 14 kind of try reinterpreting what you said about whether 15 the volume of the analysis and paperwork was 16 worthwhile. It sounds like you said yes, it was very 17 voluminous, but If the goal was to catch every 18 possible problem that was necessary. Is that a fair 19 description?
20 MR. ROBISON: It is, it is. Going in as 21 an engineer, you don't go in to kind of do two out of 22 three or five out of seven. You do all seven and you 23 document it. You might pull four out of the seven and 24 put in the application, but we're going to do seven 25 out of seven and have it in our records. So it was a 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 1 complete review and then we would work to meet the 2 standard review plan to present it.
3 MEMBER BIER: So it's not like the 80/20 4 rule, like ahh, good enough. We'll skip the rest 5 because it's low probability?
6 MR. ROBISON: No ma'am.
7 MEMBER BIER: Okay, perfect. Thank you.
8 MS. NADER: Thank you for those questions.
9 Next slide. Okay. We're going to move on to the 10 technical topics. Joe Terrell is going to discuss the 11 technical topics with the Committee today. These 12 topics have historically been of interest in the 13 licensure proceedings, and they were of interest in 14 the Oconee review as well.
15 Joe is a materials engineer with a 16 background in aluminum and powdered metal industry 17 before joining the energy sector almost 20 years ago.
18 In his time with Duke Energy, he has focused on 19 materials-related programs, and was also involved in 20 initial license renewal projects for the Crystal River 21 and Harris nuclear power plants. Next slide, please.
22 Joe?
23 MR. TERRELL: Okay. Thank you Rounette.
24 Thank you ACRS. We're going to cover three technical 25 topics here, the reactor vessel internals, the reactor 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 1 vessel supports and concrete embrittlement.
2 Next slide. So PWR vessel internals. The 3 scope of this program included reactor internals 4 component items that were identified within MRP-227-A, 5 and the gap analysis which uses MRP-227-Rev1A as the 6 starting point. The gap analysis we used incorporates 7 the screening, categorization and ranking results from 8 MRP-189-Rev3, which covers all of the B&W plant 9 designs, and the engineering evaluation and assessment 10 of age-related degradation from MRP-229.
11 So we performed an Oconee-specific fluence 12 TIG evaluations for SLR, to ensure that Oconee was 13 bounded by MRP-189 Rev 3, relative to the assessment 14 of time-dependent aging effects such as reduction of 15 fracture, toughness by radiation embrittlement and 16 cracking by fatigue.
17 The gap analysis identified new primary 18 and expansion items. New primary items include core 19 barrel cylinder, hot flange, circumferential weld and 20 the center circumferential weld in Unit 2, and this 21 would require inspection or analytical evaluation 22 prior to entering the SPEO.
23 New expansion items linked to these new 24 primary items include all of the remaining core barrel 25 cylinder welds for Units 1, 2 and 3, and the new 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
68 1 primary items included the lower grid rib section for 2 Units 1, 2 and 3, and the new expansion items linked 3 to this primary item includes the upper grid assembly 4 for Units 1, 2 and 3.
5 Duke will manage vessel internals fluence 6 projections for the reactor internals consistent with 7 the neutron fluence monitoring program, and will 8 manage vessel internals exams consistent with the PWR 9 vessel internals program, including recent NRC 10 guidance, changes noted in the recently-issued ISG and 11 the gap analysis. PWR vessel internals program will 12 be enhanced to provide guidance implementing changes 13 in primary and expansion items, and acceptance and 14 expansion criteria in MRP-227-Rev1A as modified by the 15 gap analysis.
16 MEMBER BALLINGER: Do you folks anticipate 17 changing the capsule removal schedule for the license 18 renewal?
19 MR. TERRELL: Yes. Oconee is part of the 20 integrated master reactor vessel surveillance program.
21 So this includes lots of capsules from the B&W design 22 vessels, and currently there are no capsules in the 23 vessel. But we use the integrated program to manage 24 the aging. And we have done our analysis and we, you 25 know, we meet the fluence requirements for --
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69 1 You're supposed to determine a post-fluent 2 capsule when the fluence is between one and two times 3 the SPEO life. We have -- we've already done that.
4 MEMBER BALLINGER: I don't remember that 5 any of the Oconee plants were at any kind of risk at 6 the end of 80 years.
7 MR. TERRELL: That is correct.
8 MEMBER BALLINGER: Thank you.
9 DR. SCHULTZ: Joe, you have monitoring 10 outside the reactor vessel? Do you have monitoring 11 outside the reactor vessel?
12 MR. TERRELL: We, yeah. We have X vessel 13 dosimetry that we utilize in Unit 2, and so we do 14 periodically, you know, examine that dosimetry to 15 ensure that our fluence projections are on track, and 16 to characterize the uncertainty in the fluence 17 projections.
18 DR. SCHULTZ: Given the similarity between 19 the units, you can apply that to all three units?
20 MR. TERRELL: That is correct.
21 DR. SCHULTZ: The fluence evaluation that 22 Framatome did for these programs, that includes the 23 power uprate?
24 MR. TERRELL: Yes. The power uprate 25 itself was 1.6 percent, and we conservatively assume 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
70 1 the two percent increase for the fluence evaluations, 2 to add a little additional conservatism into the 3 projections.
4 Okay, next slide. Next topic is reactor 5 vessel supports. As with all 177 fuel assembly lower 6 loop B&W designs, the Oconee reactor vessel utilizes 7 a welded steel support skirt assembly that consists of 8 a support skirt, support flange, anchor bolts and 9 associated embedment items such as side plate, 10 vertical-bearing plate and Nelson studs. You can see 11 those components in those two diagrams there.
12 So the upper portion of the support skirt 13 is welded to the reactor vessel lower transition 14 forging, and that is identified in the top figure over 15 there to the left. You can see where it says "weld."
16 The lower portion of the support skirt is welded to 17 the support flange, which is secured to the reactor 18 vessel pedestal concrete, with anchor bolts embedded 19 into the concrete.
20 That weld is not actually shown here, but 21 If you look at the lower figure, you see the item 22 "support flange," and then you could see the reactor 23 vessel support skirt vertically going down to the 24 horizontal flange, and that weld is right there.
25 The support skirts, support flange, --
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71 1 plate -- yes. Thank you. So the support skirt, 2 support flange, -- plate, vertical-bearing plate are 3 all made of carbon steel. The anchor bolts and 4 associated fasteners are made from high strength alloy 5 steel.
6 It is important to note here that, you 7 know, in comparison or in contrast to let's say a 8 Westinghouse type design, in the B&W design there is 9 no structural support provided by the reactor vessels 10 to the nozzles.
11 All of the support is through the support 12 skirt steel assembly and the concrete pedestal. So 13 the primary shield wall serves one function, that is 14 a biological shield and it does not support the 15 reactor coolant system in, for a B&W plant.
16 Okay, next slide. So the support skirt in 17 the embedment, carbon and low alloy steel items were 18 evaluated for susceptibility to irradiation 19 embrittlement using the process documented in NUREG 20 1509, Radiation Effects on Reactor Pressure Vessel 21 Supports.
22 For those items in which NUREG 1509 23 evaluation found potential susceptibility to 24 irradiation embrittlement, and that would include the 25 Units 1, 2 and 3 support flange and Nelson studs, and 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
72 1 the Units 1 and 2 support flange welds, further 2 evaluation was completed to demonstrated that intended 3 function will be maintained throughout the SPEO.
4 So based on that analysis, reactor vessel 5 support intended function will be maintained 6 consistent with the COB during the SPEO when 7 considering damage due to irradiation, and Duke will 8 manage the aging of the reactor vessel supports with 9 the ASV Section 11, subsection IWF program, the boric 10 acid corrosion program and the fatigue monitoring 11 program.
12 MEMBER PETTI: Why don't you want the 13 flange welds in Unit 3 on the list? Is there 14 something about the configuration that --
15 MR. TERRELL: Yes. The weld process that 16 happened to be used for Unit 3 was different, and that 17 resulted in different initial material properties. So 18 that's why the -- let's say the adjusted reference 19 temperature for that material was different than for 20 Units 1 and 2. So that resulted in -- there could be 21 potential embrittlement impacts to that weld. But not 22 for that weld. That weld actually was better than 23 Units 1 and 2, excuse me.
24 MEMBER SUNSERI: Those floor plates on the 25 floor, do you have any challenges with any water and 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 1 corrosion or anything on those?
2 MR. TERRELL: Those components get 3 inspected on a regular basis, and we so far all of the 4 inspection results have shown that there are no signs 5 of material degradation on those that's part of the 6 structure.
7 MEMBER SUNSERI: Are they coated?
8 MR. TERRELL: They do have a coating of 9 concrete on those.
10 MEMBER SUNSERI: Okay, thanks.
11 MEMBER BALLINGER: A Nelson stud is just 12 a giant thread of rock --
13 MR. TERRELL: It's probably, probably 14 correct.
15 CHAIRMAN REMPE: I don't know if I have to 16 remind you to turn your mic or not. Probably we'll 17 just let it go. Go ahead.
18 MR. TERRELL: Okay, next slide. The last 19 technical topic is going to be on the subject of 20 concrete embrittlement. The key topic of concrete 21 embrittlement focused on the primary shield in the 22 reactor vessel pedestal concrete, which supports the 23 reactor vessel support skirt as we have just 24 discussed.
25 The primary shield wall does not provide 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 1 a support function for the reactor coolant system, as 2 previously discussed. The projected maximum exposure 3 on the inner surface of the primary shield wall in the 4 80 years is less than the GALL SLR thresholds above 5 which radiation damage is a potential concern for 6 irradiation embrittlement.
7 Thermal embrittlement of the primary 8 shield wall concrete is also not a concern. We 9 confirm through thermal analysis that the primary 10 shield wall uses updated gamma heating rates generated 11 for SLR. The general area and localized area concrete 12 temperatures will be below 150 degrees Fahrenheit and 13 250 degrees Fahrenheit, respectively. So it's not an 14 issue.
15 Next slide. So for the reactor vessel 16 pedestal concrete, again the pedestal concrete 17 provides a support function for the reactor coolant 18 system. Maximum exposures for the reactor vessel 19 pedestal concrete are bounded by the maximum fluence 20 and gamma dose for the reactor vessel support skirt 21 weld, which is 71 centimeters above the reactor vessel 22 embedment pedestal concrete.
23 And so therefore they are less than 24 thresholds above which radiation damage is a potential 25 concern for concrete embrittlement. The general 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 1 concrete temperatures would be below 150 degrees 2 Fahrenheit, as confirmed through thermal analysis of 3 pedestal support and using the updated gamma heating 4 rates generated for SLR.
5 Now for local, localized concrete areas 6 directly below the reactor vessel support flange at 7 the shear pin locations, are conservatively predicted 8 to have localized temperatures slightly higher than 9 200 degrees Fahrenheit. However, considering the 10 large number of conservatisms used in this analysis, 11 the risk that actual temperatures would exceed 200 12 degrees Fahrenheit is minimal. Therefore, 13 concrete thermal embrittlement is not a concern for 14 the pedestal concrete.
15 DR. SCHULTZ: Joe, could you give us an 16 example of the conservatisms that make you feel 17 comfortable?
18 MR. TERRELL: Yes.
19 DR. SCHULTZ: Thank you.
20 (Pause.)
21 MR. TERRELL: There are several. Heat 22 transfer calculations were performed on the most 23 thermally stressed areas of the concrete.
24 Conservative gamma heating rates, fluence in gamma 25 dose projections were used.
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76 1 Gamma heat well, and we assumed a minimum 2 cavity air flow, which would assume our temperature.
3 Conservative air temperatures from the highest 4 measured summer measurements were used, and there was 5 no azimuthal heat transfer assumed in the thermal 6 analysis models that we used.
7 DR. SCHULTZ: Thank you.
8 MEMBER BALLINGER: The thing is, the 9 shield wall is like five feet thick, and so the 10 neutron dose through that wall is gone after the first 11 four inches, so you don't need to worry there. The 12 pedestal's in compression always, and so that 13 temperature drops off very quick as you go in there.
14 So I mean those are not factored in, but they make a 15 huge difference.
16 MEMBER PETTI: -- not being an expert on 17 concrete, is the fact that it's in compression, 18 reasonable stress affects the embrittlement, or are 19 they really independent?
20 MEMBER BALLINGER: It won't even map. I 21 mean it's not intentional.
22 MEMBER PETTI: Okay I know, yeah.
23 MEMBER BALLINGER: So if it's in 24 compression and when you talk about --
25 MEMBER PETTI: Stress corrosion cracking, 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
77 1 you have to have the stress depth that has --
2 (Simultaneous speaking.)
3 MEMBER BALLINGER: Right. There's not an 4 analogy there.
5 MEMBER PETTI: No.
6 MEMBER BALLINGER: Okay. That's all I 7 wanted to know.
8 MEMBER HALNON: So Joe, I assume that all 9 these assumptions are -- I assume that the insulation 10 is in good shape, your insulation around the vessel 11 and pipes and what-not. Is there a program to lock it 12 down after a shutdown for a refueling outage and then 13 lock it down prior to starting up, to make sure that 14 the assumptions in those thermal analyses stay stable?
15 MR. TERRELL: Yes, there is a program 16 where the -- there's three programs actually that we 17 use. So they, they will assure that the intended 18 function would be maintained in the condition. Yes, 19 we ensure that there's a program, or it's actually in 20 scope for SLR, the insulations surrounding the reactor 21 vessel.
22 MEMBER HALNON: Okay, and Steve, I assume 23 that your expectation is that if something is found on 24 a walkdown, that it goes in corrective action program, 25 and these thermal analyses would be revisited based 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 1 on, you know, bounding conditions that it could have 2 seen?
3 MR. SNIDER: That's correct, and at the 4 beginning of every refueling outage, we immediately do 5 walkdowns, review the results of those as a management 6 team, make sure condition reports -- are written to 7 address each one.
8 MEMBER HALNON: Thank you.
9 MEMBER SUNSERI: I have one last question.
10 But are the temperatures able to be monitored and 11 vented in these areas?
12 MR. TERRELL: We do have temperature 13 monitoring in the reactor air cavity, and so yes, 14 that's correct.
15 MEMBER SUNSERI: Anything else?
16 MR. TERRELL: That's all I have. Thank 17 you.
18 MEMBER SUNSERI: Anything else, Rounette?
19 MS. NADER: Next slide. I just had some 20 closing remarks on the next slide. Thank you. So I 21 hope that the remarks that we've provided today have 22 left you with a few sentiments, and first that Duke 23 utilizes a team of highly capable individuals, with 24 both license renewal experience and familiarity with 25 the Oconee systems and programs.
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79 1 Of the approximately 20-person team that 2 Greg mentioned, nearly every member of that team has 3 either previous license renewal experience or Oconee 4 experience or both. And so when I was provided the 5 opportunity to assemble a subsequent license renewal 6 team for Oconee, I was very fortunate to be able to 7 get just about anyone who had licensure on their 8 resume on the team.
9 So and secondly, hopefully that what you 10 saw from the numbers that Greg presented and the 11 greater than 95 percent alignment with GALL SLR and 12 the Oconee aging management reviews, and the fact that 13 we can incorporate many of the current license renewal 14 commitments across the subsequent license renewal 15 aging management programs, that that also is an 16 important factor in just the overall high quality 17 application that Duke was able to put together, and 18 the fact that we were able to benefit from the 19 insights of lessons learned from the early SLR 20 applicants.
21 Then as Steve mentioned earlier and with 22 the list he showed, Duke Energy will continue to 23 invest in Oconee now and in the future, to ensure the 24 continued safe and reliable operation for 80 years.
25 So in closing, I also want to commend the staff on 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 1 their efforts in reviewing the application over the 2 past year and a half. The staff conducted a thorough 3 and rigorous review that included a comprehensive 4 audit and several follow-up public meetings on various 5 technical topics.
6 They've engaged with the Duke staff 7 appropriately and we've addressed many of their 8 questions and comments through this process.
9 Next slide. That ends our remarks.
10 MEMBER SUNSERI: All right. Well thank 11 you all very much for a very good presentation, very 12 robust discussion. Members, thank you for your input.
13 We don't have it on the agenda, but we do take breaks 14 at the discretion of the Chairman. So I'm going to 15 turn it over to the Chairman for discussion please.
16 CHAIRMAN REMPE: The staff we have to be 17 considerate. I have checked with them and they said 18 that that would be fine, and again If I look at the 19 whole agenda for the subcommittee meeting, we'll --
20 I'm confident we'll make up some of the time later.
21 I'd like to give everyone a ten minute break and ask 22 them to come back at 10:20 on the east coast, and 23 we're recessed until 10:20.
24 (Whereupon at 10:10 a.m., the above-25 entitled matter went off the record, and resumed at 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
81 1 10:20 a.m.)
2 CHAIRMAN REMPE: Okay. It's 10:20, we're 3 back in session, and I will turn it back over to Matt.
4 MEMBER SUNSERI: Thank you Chairman.
5 We're ready to continue, so this is the staff 6 presentation, and I'll turn it over to Mark Yoo.
7 Thank you, Mark.
8 MR. YOO: Good morning and members of the 9 ACRS. My name is Mark Yoo. I'm one of the senior 10 license renewal project managers in NRR. And lead 11 project manager for the Oconee SLRC. We're here today 12 to discuss the staff safety review of the Oconee 13 Nuclear Station SLR application, as documented in the 14 safety evaluation or SE. Joining me today at the 15 table is Lauren Gibson, Chief of the License Renewal 16 Projects Branch.
17 (Pause.)
18 MR. YOO: Dr. Allen Hiser, senior 19 technical advisor for Aging Management; and Jared 20 Nadel, senior resident inspector at Oconee. We also 21 have joining us both in the audience and virtually 22 members of the Technical and Regional staff.
23 Next slide, please. We'll begin today's 24 presentation with an overview of the Oconee licensing 25 history before moving on to the Oconee aging 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
82 1 management programs. We will then discuss selected 2 technical areas that we believe are of interest to the 3 ACRS, and hear from Region 2 on inspections and plant 4 material conditions, before sharing the conclusions of 5 the staff's safety review.
6 Next slide, please. Oconee Units 1, 2 and 7 3 were initially licensed on February 6, 1973, October 8 6, 1973 and July 19th, 1974 respectively. In July 9 1998, the applicant submitted the initial license 10 renewal application. The initial renewed licenses 11 were issued in May of 2000, extending the expiration 12 dates by 20 years to the dates indicated on the slide.
13 On June 7th, 2021, Duke Energy submitted 14 an SLR application for Oconee Units 1, 2 and 3. The 15 application was accepted for review on July 28th, 16 2021, and the safety evaluation was issued on December 17 19th, 2022 with no open or confirmatory items.
18 Next slide, please. Slide 4. The Oconee 19 SLR application described a total of 48 aging 20 management programs or AMPs, consisting of 34 existing 21 programs and 14 new programs. This slide identifies 22 the applicant's original disposition of these AMPs as 23 initially submitted in the application in the left 24 column, and the final disposition as documented in the 25 staff's SE in the right column.
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83 1 All of the AMPs except one were evaluated 2 for consistency with the GALL SLR report, and 3 ultimately all of the AMPs were found to be consistent 4 with acceptable enhancements or exceptions. The 5 applicant included one plant-specific aging management 6 program, the secondary shield wall tendon surveillance 7 program, which was reviewed in accordance with our 8 standard review plan for subsequent license renewal, 9 and was also found to be acceptable.
10 I'd like to add a bit about the work we 11 did to review the aging management activities and the 12 other technical information in the application. As 13 part of our review, the staff conducted an aging 14 management audit to review operating experience, the 15 aging management programs and time-limited aging 16 analyses or TLAAs.
17 This audit spent 11 weeks, included both 18 on-site and virtual activities, and leveraged the 19 ePortal and breakout sessions between the staff and 20 the applicant. There was also an additional limited 21 scope audit for the PWR and vessel internals programs, 22 which was conducted virtually using the ePortal and 23 which I'll discuss a little further on the next slide.
24 We had 77 RAIs and 15 second line RAIs from this 25 review.
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84 1 The applicant submitted four SLR 2 application supplements, plus one annual update. We 3 had seven public meetings which were conducted to 4 discuss a variety of responses to RAIs that were 5 issued by the NRC staff, including topics related to 6 PWR vessel internals and irradiated concrete.
7 Based on our review of the SLR 8 application, the results of the audits and additional 9 information provided by the applicant, the staff 10 concluded that the applicant's aging management 11 program activities were consistent with the criteria 12 of the standard review plan for SLR and the 13 requirements of 10 C.F.R. Part 54.
14 Next slide, please. So this slide 15 represents certain specific areas of the SLR 16 application review. The first four bullets are those 17 referred to in our staff requirements manual for SECY 18 140016 titled "Ongoing Staff Activities to Assess 19 Regulatory Considerations for a Power Reactor 20 Subsequent License."
21 Those four items are reactor pressure 22 vessel neutron embrittlement, irradiated -- and 23 cracking of reactor vessel internals, irradiated 24 concrete -- containment, and electrical cable 25 qualification and condition assessment. For each of 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
85 1 these four areas, the applicant provided information 2 in the application and throughout the staff's review, 3 which the staff dispositioned using the guidance in 4 the GALL SLR report and the standard review plan for 5 SLR.
6 The staff's review of the reactor vessel 7 internals focused on the applicant's existing PWR and 8 vessel internals program, which was based upon MRP-9 227-A report and the applicant's gap analysis that 10 identifies the programmatic changes to address 80 11 years of operation. In the limited scope audit I 12 mentioned on the previous page, the staff reviewed the 13 applicant's bases as specific core barrel weld 14 components did not screen in for stress corroding 15 cracking or fatigue cracking mechanisms.
16 Ultimately, the applicant modified the 17 application to change relevant components from the new 18 additional measures inspection category to the 19 expansion inspection category. Based upon the staff's 20 review of the application and RAI responses, the staff 21 concluded that the applicant's PWR vessel internals 22 program will be adequate to manage the applicable 23 aging effects in the subsequent period of extended 24 operation.
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86 1 included the reactor pressure vessel primary shield 2 wall or PSW and the pedestal concretes. The staff 3 reviewed the applicant's fluence methodology and found 4 that the applicant demonstrated that the analyses were 5 based on conservative models that would produce 6 results higher than reflected in plant operation.
7 The staff also reviewed the integrity of 8 the RPV PSW and pedestal concretes. The staff 9 reviewed analyses and plant-specific operating 10 experience related to the effects of irradiation on 11 the mechanical properties of these structures and 12 components. Based on its review of the application 13 and the RAI responses, the staff concluded that there 14 is reasonable assurance that the concrete in these 15 areas will continue to fulfill its intended function 16 throughout the subsequent period of extended 17 operation.
18 The last bullet here, the Keowee Hydro 19 Station is included because this review involved a 20 unique situation for Oconee. The Keowee Hydro Station 21 serves as the emergency power source and is licensed 22 by the Federal Energy Regulatory Commission or FERC.
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87 1 by FERC instead of the NRC.
2 The NRC did conduct walkdowns of the 3 Keowee Hydro Station during its reviewing and found 4 that relying on the FERC inspections provides 5 reasonable assurance that the Keowee Hydro Station 6 will maintain its intended function throughout the 7 subsequent period of extended operation.
8 MEMBER HALNON: Real quick question. Does 9 the FERC inspections have the same level of public 10 transparency as the NRC inspections? In other words, 11 will the surrounding public understand the condition 12 of the hydro station going forward?
13 MR. NADEL: I do not know that. I don't 14 know the level of public release of their reports.
15 MEMBER HALNON: Okay.
16 CHAIRMAN REMPE: You still have to say 17 your name.
18 MR. NADEL: Sorry, Jared Nadel.
19 MR. YOO: Is there any staff on the 20 structural technical staff that could maybe speak to 21 those FERC inspections, at least the transparency 22 aspect of those inspections?
23 MEMBER HALNON: You've got some folks.
24 MR. STARR: Dave Starr, NRC, structural 25 engineer. FERC is under Title 18, I think Part 12 as 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 1 well as Subpart D, is an acceptable way of inspecting 2 the existing structures. So that's --
3 MEMBER HALNON: Yes, I get that 4 technically it's acceptable and probably regulatory-5 wise it's acceptable. But part of the equation of the 6 acceptance of the community is to have transparency of 7 inspections and to, especially with Keowee, it's being 8 unique. If the public doesn't have the information on 9 how often is that being inspected and is safe, there's 10 not an opportunity for engagement or anything else.
11 So the curiosity is beyond just, you know, 12 can I go to find it. Is it really available and as 13 transparent as the NRC inspections, which are very 14 transparent, very available.
15 MR. YOO: Yeah. I believe the member of 16 the licensee can respond to that question.
17 MR. ROBISON: There's a certified dam 18 inspection report written in -- written and PE stamped 19 by --
20 CHAIRMAN REMPE: Greg, you have to say 21 your name really loud.
22 MR. ROBISON: Greg Robison, Duke Energy.
23 There's a certified dam inspection report written and 24 PE stamped and submitted by FERC as a public document 25 after the dam inspections are done. So there is a 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 1 public record of the dam's safety, and that's all a 2 part of the hydro FERC rules. But it's a 3 comprehensive report and, you know, as the inspections 4 are done five years or every so often, that report is 5 written and it is submitted and it is public.
6 MEMBER HALNON: When you say "public," is 7 it easy to get to? Is it actually an inspection 8 report where you just are able to get on a website and 9 click it?
10 MR. ROBISON: I suppose you can Google it.
11 I haven't, you know, it's that kind of public. It's 12 there, you know, and really the issue with hydro and 13 dam safety is community, communication to community 14 and the confidence that the hydro facilities are safe, 15 because there's, you know, part of the FERC license is 16 recreation and aesthetics and those types of things 17 for the lake and the river.
18 And so the reports are the certification 19 that we're meeting the FERC rules.
20 MEMBER HALNON: Okay. Well, it sounds 21 like an interested party can find it. It may be as 22 easy as going to the NRC website. Thank you Greg.
23 MEMBER SUNSERI: I just Googled it, it 24 pulls up.
25 (Simultaneous speaking.)
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90 1 MEMBER HALNON: But anyway, so I had 2 another kind of question, following up on this. I had 3 not realized that there was a different entity 4 providing oversight of the Keowee. So are there 5 technical specifications involved? It's emergency AC 6 power, right? Are there other technical 7 specifications for its availability?
8 MR. NADEL: This is Jared Nadel. Yeah, 9 that's correct. The Keowee, the hydro generators are 10 in tech specs for --
11 MEMBER HALNON: So and you as an inspector 12 have authority to go there and look and --
13 MR. NADEL: That's correct. We go over 14 there periodically and as you'll see on a slide that's 15 coming up, I have also gone into the -- at Keowee with 16 a FERC inspector on that five year inspection.
17 MEMBER HALNON: Okay. Well, we may have 18 further questions when you get that point.
19 MR. NADEL: I imagine so.
20 MR. YOO: Are there any other questions 21 related to the safety review?
22 (No response.)
23 MR. YOO: Okay. At this time, I will turn 24 it over to Jared Nadel, the senior resident inspector 25 a Oconee, and he will discuss inspections and the 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 1 plant material condition.
2 MR. NADEL: Good morning everyone. I'm 3 Jared Nadel, senior resident inspector at Oconee 4 Nuclear Station. I've been a resident inspector for 5 the past 15 years at three different sites, and I've 6 transferred to Oconee in 2009. Also joining me 7 virtually on behalf of the region is Paula Cooper, 8 senior reactor inspector.
9 My role here today is to present the 10 inspector's perspective on the material condition of 11 the plant, and the adequacy of the site's performance 12 on managing the effects of aging. These insights are 13 gained from those region-based inspections and those 14 performed by me and my other two resident inspectors 15 on site.
16 This table represents the inspections that 17 were performed through the license renewal inspection 18 program, specifically by the 71003 inspection 19 procedure, which is a series of inspections that are 20 performed after the license is renewed, including both 21 before and after entering the period of extended 22 operation.
23 Each of the three units received a Phase 24 1 inspection. This phase occurs prior to the period 25 of extended operation during an outage, where the 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
92 1 inspectors can walk down normally inaccessible areas 2 such as containment to observe the implementation of 3 the aging management programs.
4 For Unit 1, the inspector observed the 5 inspections of the pressurizer internal cladding, 6 spray line and spray head. For Unit 2, the inspector 7 observed ultrasonic exams on the lower core barrel, 8 bolting and flow distributor bolting, while also 9 reviewing the reactor building coatings program.
10 (audio interference) and the eddy current testing of 11 the main condenser tubes.
12 The Phase 2 was a two-week inspection 13 performed by a team of six inspectors prior to 14 entering the period of extended operation, to verify 15 the license renewal activities were completed. The 16 inspectors reviewed a combination of 24 aging 17 management programs and commitments, and determined 18 that there were a couple of activities outstanding.
19 In this case, a Phase 3 would normally be 20 performed to finalize the review of the remaining 21 items, but as you can see the Unit 3 Phase 1 was 22 performed after the Phase 2. Thus, we were able to 23 close out those items during that inspection. The 24 Phase 4 was the most recent inspection performed last 25 year. Paula Cooper was the lead for this inspection 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 1 and its purpose was to verify that the licensee was 2 adequately managing the effects of aging.
3 This is a one week inspection that was 4 performed by a team of three inspectors and one 5 technical reviewer. The team reviewed over 50 6 systems, structures and components associated with 13 7 aging management programs. The inspections did not 8 identify any findings or concerns with how the 9 licensee implements their aging management programs.
10 Next slide.
11 DR. SCHULTZ: I'll just remark before you 12 leave that Jared that was a very comprehensive, both 13 inspection and report associated with that. Well done 14 and you briefly described the 50 elements of the 15 inspection. Well documented. Thank you.
16 MR. NADEL: In addition to the inspections 17 mandated by the license renewal inspection program, 18 inspectors used several ROP baseline inspection 19 procedures to evaluate the implementation of aging 20 management activities. One example is the baseline 21 inspection of the in-service inspection program.
22 This inspection is performed each 23 refueling outage and provides the inspectors the 24 opportunity to review and assess inspections credited 25 for aging management. The second example is the heat 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
94 1 sink inspection, which provides the inspectors an 2 opportunity to review the service water system, as 3 well as the ultimate heat sink. All of these 4 activities are within the scope of license renewal.
5 Also of note, the triennial fire 6 protection procedure has recently been updated to 7 review aging management of the fire protection 8 equipment.
9 Next slide. I will now speak to the 10 material condition of Oconee from a regional 11 viewpoint. As a senior resident inspector, we perform 12 routine walkdowns of the plant as an independent means 13 of verifying the structures, systems and components 14 are maintaining their intended function. This 15 includes systems that are normally accessible at 16 power, those accessible only during outages and those 17 that are even more infrequent, such as the photo in 18 this slide.
19 This photo is of me performing the 20 inspection with a FERC inspector and licensee civil 21 engineers of the penstock at the Keowee hydroelectric 22 plant. As you may have heard, Keowee serves as an 23 emergency backup source for power for the Oconee 24 Nuclear Station. In general, we have no concerns with 25 the overall material condition of the plant beyond the 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 1 baseline reactor oversight process.
2 The licensee has been successful at 3 completing large capital improvement projects that 4 maintain or improve the material condition of its 5 structures, systems and components. The inspectors 6 will continue to inspect and assess the licensee's 7 ability to manage the effects of aging through the 8 baseline inspections. Are there any questions?
9 DR. SCHULTZ: I have one question that --
10 but I'll ask it of either Mark or Laura. Duke had the 11 opportunity to describe their level of effort and the 12 number of personnel that were involved in their 13 application development and interactions with the NRC.
14 I know we've got some representatives of the NRC staff 15 here.
16 But could you describe the numbers of 17 folks and types of folks that have participated in the 18 review of the application?
19 MS. GIBSON: I'm Lauren Gibson. Lots and 20 varied. On a typical review, we have over 58 21 technical reviewers who look at the various different 22 aspects. We also have environmental reviewers who do 23 the other side. Altogether, we usually spend about 24 23,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> working on reviews like this, including 25 ACRS meetings, and we had a number of project managers 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 1 due to staff turnover.
2 So Mark, I believe you're number four in 3 the past three months? Yes. So it's a wide swath of 4 people in various different areas.
5 DR. SCHULTZ: I think I counted 64 when I 6 looked down the roster in the documentation, and the 7 pile of paper that you assembled, and I don't mean 8 that in any derogatory way. But it's quite extensive 9 as well in terms of your safety evaluation of the 10 application.
11 MS. GIBSON: Yes, thank you.
12 MEMBER SUNSERI: I have a question for 13 Jared. We don't obviously get to go to the stations 14 to see, so you're kind of our eyes and ears at the 15 station. We rely a lot on your perspectives and I 16 know sometimes our questions are challenging because 17 we go beyond what I would call the regulatory 18 threshold and it's used for things that, you know, 19 direct observations of things like this.
20 So with that introduction, sometimes you 21 go to nuclear stations and what I'll call the farther 22 away you get from the nuclear island of more degraded 23 standards, be it housekeeping, material condition, 24 etcetera, from the drawing that was put up there, it 25 looks like the Keowee station is pretty far away from 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 1 that. Can you just share with us your direct 2 observations of the material condition, corrosion, 3 coatings, housekeeping?
4 MR. NADEL: Yeah sure. I'll be glad to.
5 Yeah, you mentioned the Keowee station is a good 6 distance from the nuclear island, and you typically 7 would drive there from where we would normally park to 8 get there. But I would say that the material 9 condition at Keowee is good. Housekeeping is 10 excellent. There's just not that many areas or 11 significant amount, you know.
12 When work is going on, obviously it's a 13 different story. But after that, there's not any 14 stray material or anything like that hanging around, 15 you know. When I got to Oconee, as I imagine most 16 inspectors, I don't typically see a hydro facility 17 like Keowee in my normal duties. So everything there 18 was different.
19 As you go deeper into the facility at 20 Keowee and you get below the level where the turbines 21 are, there is continual water leakage that exists, and 22 that's not abnormal for this type of facility, and 23 it's managed and it is not, you know, gross by any 24 means. But that was a new thing for me when I got 25 there, to see that kind of, you know, that kind of 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 1 condition, and that's the reason why I was interested 2 in actually taking an opportunity like that to go 3 inside the penstock, which you know, most of the 4 people even on site don't get an opportunity to do.
5 MEMBER SUNSERI: And so the people that 6 maintain that station, are they the same craft that 7 maintain the Oconee station? I mean so say electrical 8 maintenance would do this maintenance on the switch 9 gears and the breakers and everything up there?
10 MR. NADEL: Oh. So it's a mixed bag.
11 From an operations standpoint, there are -- the 12 operators that are at Keowee are Oconee nuclear 13 operators, and they are part of that organization.
14 That wasn't always the case, but that's the way that 15 it is now. In terms of the electrical components that 16 are out there, when I've been out there most of those 17 I've seen there are fleet teams that have specialized 18 in some of those type of components that will come and 19 do the work.
20 But there is also people from the station 21 in electrical that go out there, depending on what 22 type of work it is. Engineers from the station have 23 a responsibility for Keowee and will always be out 24 there when there's significant electrical work going 25 on.
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99 1 MEMBER SUNSERI: So a lot of times -- so 2 it sounds similar to this. A lot of times at a 3 station you'll see the switch yard is the similar 4 example, right? So you'll have people from the parent 5 company doing some work out there, and then some from 6 the site doing some work out there, and there's a 7 clear, kind of a clear line of demarcation. Is that 8 -- they're pretty clear there?
9 So what I worry about is, you know, either 10 overlapping things and making mistakes that could 11 cause unavailability or missing something that could 12 cause unavailability.
13 MR. NADEL: Yeah, I understand. I think 14 it is very clear, and it's not as defined as in a 15 switch yard. It's all Duke, and even the hydro-16 specific groups which will go out to Keowee to do 17 things like this type of inspection, they do that at 18 every hydro facility, and Keowee is another one that 19 they do it at. But they all recognize the special 20 place that Keowee has compared to the other ones.
21 MEMBER SUNSERI: Okay, so just one more 22 question, and I hate to keep putting you on the spot, 23 because I didn't think about all this because I wasn't 24 realizing the situation. But so a lot of times in 25 that switch yard plant relationship there's, I'll call 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 1 it for lack of better words, a contract between the 2 switch yard company and the parent utility?
3 I mean they all work for the same place, 4 right, but you know, somewhat of a contract. This is 5 your responsibilities and obligations, this is our 6 responsibilities and obligations. Do they have 7 something similar to that with the Keowee station?
8 MR. NADEL: I don't know if I can speak to 9 that specifically, but I'll let, you know, I'll let 10 Steve talk if he wants.
11 MR. SNIDER: This is Steve Snider -- This 12 is Steve Snider for Oconee. Everything that Jared 13 said is accurate. For the Keowee Hydro Station, for 14 the switch yard, Oconee personnel provide oversight.
15 We are all one company. We work very closely 16 together.
17 We do rely very much on the expertise of 18 all areas of the company for the work we're doing, 19 whether it's associated with hydro station or the 20 distribution system on the switch yard. But the 21 Oconee site is responsible for the oversight and the 22 quality of the work.
23 MEMBER SUNSERI: Yeah. I don't, I'm not 24 challenging either. I'm just seeking to understand 25 because you, I know you're aware that industry 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 1 experience says that at least in the switch yards, 2 there's been some discoordination from time to time.
3 MR. SNIDER: Right, and we have service 4 level agreements that documents clearly what the 5 responsibilities are for each one of the business 6 units on how that responsibility and functionality 7 works.
8 MEMBER SUNSERI: Perfect, yeah. That's 9 the timed service level agreement. Thanks. I 10 appreciate that, thank you.
11 MEMBER HALNON: I have a quick question on 12 the managing interface with FERC. Clearly it looks 13 like, you know, you're the -- you're the interface 14 with the inspectors from FERC coming. I assume that, 15 you said you were with the inspectors and what-not.
16 If they found something that would rise to the level 17 of a concern for the NRC, would you open a parallel 18 finding to follow that, or would you just rely on 19 FERC through their processes to follow up on it?
20 MR. NADEL: So I think that in the case 21 that something like that happened, we would follow up 22 independently, because as has been mentioned, you 23 know, the inspection that I went on, it was only 24 because of FERC that it was happening, and there was 25 no hard requirement necessarily for me to participate.
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102 1 I just took advantage basically of that 2 access to do an independent walkdown of the material 3 condition of that part of Keowee, and If there were 4 any issues that FERC identified, you know, civilly and 5 structurally, or that I identified on that inspection, 6 we would follow up on that through our authority over 7 the emergency power source requirements at Keowee.
8 MEMBER HALNON: Okay. So they're 9 obligated to talk to you after their inspections or --
10 I mean you don't have to Google their report, right?
11 MR. NADEL: No, no. They're not obligated 12 to talk to us. I don't think, you know, there are 13 memorandums of understanding between the NRC and FERC.
14 But for this type of inspection, it was independent in 15 terms of my decision to participate. We weren't 16 notified and I requested the report, which is 17 generated after this inspection.
18 I'm not sure If it was the same as the 19 public report, because it included a lot of detailed 20 pictures of the inside of this penstock. But as part 21 of my review, I did request that the licensee 22 maintains that. So I got that from them.
23 MEMBER HALNON: Just my opinion. It feels 24 a little on the informal side from that perspective, 25 and not knowing all the details I would -- If I was in 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 1 the position of being an inspector at the site, I 2 would want to be a little bit more formally notified 3 If there is a finding of some type, whatever meets 4 their threshold, whatever they call it.
5 MR. NADEL: Yeah, I think it's -- your 6 assessment is accurate. It is a little bit more 7 informal, and but from the NRC side, there's probably 8 things we can do to make that more formalized, since 9 it is once in a five years type of --
10 MEMBER HALNON: Yeah, and you may not be 11 there next time, in five years.
12 MR. NADEL: Right.
13 CHAIRMAN REMPE: So can I pull the thread?
14 Let's talk about what could be done to make it more 15 formal? Is it something where there's some document 16 that's passed to the next inspector, that says hey, 17 beware of this and be sure you get the report?
18 MR. NADEL: Yeah. I think for the 19 turnover process, that would be the best opportunity 20 to make new inspectors aware of this as an inspection 21 that occurs, and it's an opportunity for us to go out 22 and assess an area of the plant that we can't 23 frequently access. But just to be clear, as part of 24 our baseline inspection process as residents, there is 25 no requirement to do this particular inspection. It's 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
104 1 at our option, and based on this.
2 MEMBER SUNSERI: Chairman, there's a Duke 3 employee.
4 MS. GALLOWAY: Yes, hi. This is Heather 5 Galloway, again with Duke. I just wanted to also 6 point out that the FERC inspections are not done in a 7 vacuum necessarily. Our engineers are tied in 8 directly with FERC. They actually participate in many 9 of these walkdowns too.
10 So any adverse findings that FERC were to 11 find, our engineers would take that and it would be 12 put into the corrective action program, and then we'd 13 follow up on it from there too. So that's another way 14 that the NRC would become aware of it, would be the 15 daily review of the corrective action program.
16 CHAIRMAN REMPE: So there's a requirement 17 that a FERC finding gets put in the ROP?
18 MS. GALLOWAY: I don't know that there's 19 a requirement, but if there's a degraded condition, we 20 will, we will put it in the corrective action. We'll 21 put it in our corrective action program.
22 CHAIRMAN REMPE: Okay. So I thought I 23 heard you say the ROP, but it's your corrective action 24 program?
25 MS. GALLOWAY: Our corrective action, 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 1 yeah. Our corrective action.
2 (Simultaneous speaking.)
3 CHAIRMAN REMPE: And do the inspectors 4 take your corrective action --
5 MS. GALLOWAY: The NRC inspectors?
6 CHAIRMAN REMPE: Yeah.
7 MS. GALLOWAY: They reviewed it daily, I 8 believe.
9 CHAIRMAN REMPE: Okay.
10 MEMBER SUNSERI: But it's emergency AC 11 power, right? So there's a ROP performance indicator 12 for that, isn't there?
13 MR. NADEL: Yes. This is Jared Nadel, 14 yeah. That's correct. So it's --
15 CHAIRMAN REMPE: It should be in that --
16 MR. NADEL: Right, it is. I mean it's 17 monitored and --
18 MEMBER BROWN: Yes, I wanted to -- off 19 this one, just a slightly different pitch, because I 20 was -- this is the first time I've not seen diesel 21 generator emergency backup systems and anything, you 22 know, anything I've participated in in the past. I 23 don't have you all's plant experience.
24 And yet the formalities seem to be a 25 little bit less than what we would expect on a normal 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
106 1 facility. You've been a resident and an inspector at 2 other facilities other than this one, where we've had 3 the standard backup diesel generator setups with 4 switch yard operations, etcetera. Do you get a 5 feeling that the maintenance and the care for this 6 Keowee setup is worse than or not as good as what you 7 see in the more formally monitored plants? I mean 8 you're -- interesting you said this is not a 9 requirement for you as a resident inspector to go out 10 there. Did I misinterpret that statement?
11 MR. NADEL: Yeah, this is Jared Nadel.
12 Yeah. Just to make sure I'm being clear --
13 MEMBER BROWN: I'm not criticizing you 14 about it.
15 MR. NADEL: No, no.
16 MEMBER BROWN: That's not the point.
17 MR. NADEL: So that I was talking 18 specifically about the FERC inspection aspect that 19 occurs out at Keowee. I would say in terms of 20 comparison to a diesel generator at a normal plant, 21 it's exactly the same level of oversight and 22 importance.
23 (Simultaneous speaking.)
24 MR. NADEL: That's correct, by us as well, 25 in terms of the inspections that we do. There are 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 1 inspections we do that are, you know, not associated 2 with the FERC oversight aspects, but wholly within the 3 NRC's regulatory purview associated with the 4 electrical capability of the units, the testing of 5 them. So that works very much like it would at any 6 plant with diesel generators. It's just a very 7 different system obviously that --
8 MEMBER BROWN: So you, you had no 9 dependence -- you don't depend on FERC doing your 10 validation that this emergency power source is 11 suitable for running a nuclear power plant If it loses 12 its, you know, general capability from the main switch 13 yards and everything else?
14 MR. NADEL: Yes. Yeah, that's correct, 15 and it's much more often that there will be issues 16 with the other aspects of the Keowee design and 17 control system, breakers, electrical aspects, things 18 like that that we would be getting involved in than 19 the stuff associated with the dam itself, the spillway 20 or the internal components like the penstock, which 21 really are more on the FERC side.
22 MEMBER BROWN: Okay. A separate question 23 based on experience out in the west, was dams and the 24 unavailability of water, to trap water through 25 hydroelectric systems. Is there any history of the 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 1 Keowee backup water system ever approaching levels 2 that would lead you to be apprehensive, or that 3 couldn't provide the power necessary?
4 MR. NADEL: So the level of the lake at 5 Keowee itself is also something specifically 6 controlled by the nuclear power plant. It's also in 7 technical specifications, and Duke manages the entire 8 watershed with Lake Joccasee above Lake Keowee, and 9 then Lake Hartwell below it, with that in mind. So 10 they would divert water from sources upstream and 11 starve sources downstream as needed in order to 12 maintain that level for nuclear safety and I'm not 13 aware of any times, certainly in the recent past, 14 where they've ever had a challenge with Lake Keowee in 15 terms of the availability of water or the level of the 16 lake.
17 MEMBER BROWN: I guess the point is that 18 there is a process to control that, such that you 19 don't have a problem based on controlling downstream 20 message that would deplete the water systems in 21 Keowee? Okay.
22 MR. NADEL: Yeah, that's exactly right.
23 MEMBER BROWN: I don't know whether I 24 missed anything --
25 MEMBER SUNSERI: Yeah, no. No, that's 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 1 good questions and we have -- mic.
2 MR. SNIDER: This is Steve Snider. I was 3 going to say I think Jared covered it well, but we do 4 manage the entire waterstream there. We are near the 5 top of the waterstream If you will, and all the 6 climate projections, If anything we're going to get 7 wetter, not drier, you know, in the future.
8 So and we manage that to make sure we have 9 ample water supply there for Oconee and Keowee proper.
10 Then back to the comments related to the emergency AC 11 piece so the -- of Keowee. I was licensed and grew up 12 with emergency diesels, so that's very familiar to me.
13 But as far as maintenance rule inspections, tech 14 specs, all that is what you would expect for emergency 15 power supply.
16 FERC comes in more of the structural, the 17 physical part of the dam, and that piece of it is more 18 what their focus is. That's the -- it's more of the 19 uniqueness part where they come into play. And just 20 to plug for that real quick, hydro stations are a lot 21 simpler. Gravity works, no sequencer. I don't know 22 why everybody doesn't have one.
23 MEMBER BROWN: No, I don't -- I understand 24 that point.
25 MR. SNIDER: Yeah, no.
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110 1 MEMBER BROWN: It's just after looking at 2 what's going on, you know, with the various lakes and 3 everybody screaming for water on the west coast, and 4 not having adequate reservoirs, it just triggered my 5 thought process.
6 (Simultaneous speaking.)
7 MEMBER BROWN: --asking that question.
8 I'm like you.
9 MEMBER SUNSERI: No. I think a lot of us 10 agree, it's probably more reliable. But you know, 11 since it is different and we're just seeking a lot of 12 questions to seek information.
13 (Simultaneous speaking.)
14 MEMBER SUNSERI: To me, it almost sounds 15 like, and maybe I'll get into trouble by saying this, 16 but you know, the transmission lines themselves are 17 governed by FERC, right, but the plant depends on 18 those for the offsite power, right.
19 So your first line of defense is having 20 offsite power by having so many transmission lines, 21 and it comes into the switch yard and there's a 22 demarcation and somebody's responsible for this and 23 somebody's responsible for that. But you know, my 24 experience is that the utilities that own that, you 25 know, maybe not physically but you know, make a lot of 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 1 ownership for overseeing that, to make sure those 2 relationships support the plant, and it sounds like 3 you all have all that in place. So I'm satisfied.
4 MEMBER HALNON: So just to close out my 5 thought process on the managing and interface with 6 FERC and NRC, and I mentioned it seems kind of 7 informal. I was trying to think well what would be, 8 in my mind, acceptable, and I would think that when 9 the inspection is done, that your procedures drives 10 you to summarize that into your quarterly inspection 11 report, such that it's transparent and all in one 12 place.
13 And no, there's no question that it has 14 been considered in the ROP perspective and it also 15 provides the references to get to, so you don't just 16 have to Google a report title. That would be, in my 17 mind, the right thing to do. So just maybe take that 18 and consider it, and go forward so that it's pretty 19 wrapped up, because it's very unique. There's not 20 many places, if any, that we take credit for another 21 organization's inspection.
22 I mean even from a OSHA perspective, even 23 the OSHA inspections, unless there's something that 24 happens and you bring the OSHA inspector in. But 25 this, it sounds like we're kind of handing it to FERC 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 1 and there's really no formal lines of communication.
2 Everyone's doing the right thing. It's just a matter 3 of --
4 MS. COOPER: This is Paula Cooper, senior 5 reactor inspector. Can I just add a comment to that 6 if I could?
7 MEMBER HALNON: Sure.
8 MS. COOPER: So I just wanted to kind of 9 communicate that. So FERC and NRC, the Dam Safety 10 Group, you have a I guess formal collaboration upward, 11 and I can't say that it's specific to Oconee because 12 a lot of the dams that we're dealing with on that 13 collaboration front is associated with dams that are 14 not under FERC authority and are solely under NRC 15 authority.
16 But there's a Congressional decision that 17 was made many decades ago, recognizing that FERC is 18 the authority for knowledge, experience, etcetera on 19 those dam safeties. So for that reason, FERC actually 20 does the inspections on our behalf for those specific 21 dams.
22 So in terms of is there an easy pathway to 23 connect this inspection report to the NRC, yes. I 24 mean that pathway exists. That collaboration already 25 exists between FERC, but I think it would be a really 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 1 easy value add for them to just request that they add 2 providing this documentation to NRC when it's 3 performed.
4 MEMBER SUNSERI: Okay, thank you. That 5 would be helpful. Thanks for the comments. Anybody 6 else? We don't get the resident inspectors here at 7 our desk very often.
8 MS. GIBSON: May I make one more comment 9 about the FERC inspections?
10 MEMBER SUNSERI: Sure.
11 MS. GIBSON: This is Lauren Gibson, branch 12 chief for License Renewal. I think we may have 13 started down this path because we said that we don't 14 do the FERC inspections and FERC does aging management 15 programs. I wanted to clarify from the perspective of 16 license renewal. What we mean is that FERC handles 17 the aging management part of the plant, like the 18 individuals from the plant said.
19 The structural things like that that are 20 not directly related to the operational issues that 21 maybe dealt with for the NRC with the emergency AC 22 power. So what we did is we went out to the site and 23 we did a walkdown there, and we clarified which parts 24 of -- which system as we moved from our system to 25 their system, would be under NRC aging management and 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 1 which would be under FERC management.
2 We didn't want to duplicate anything that 3 FERC was doing, because they are, you know, a valued 4 federal agency as well, and we ended up being good 5 with what we saw and what is happening there. So from 6 an aging management perspective, FERC handles parts of 7 the dam. But from an overall perspective, it seems 8 much complicated than that.
9 MEMBER HALNON: And my question would just 10 be If FERC said no, we're not going to do it, then 11 you'd be doing it; correct?
12 MS. GIBSON: I think If FERC said no, 13 we're not going to do it, we would have a broader 14 national problem. But yeah, at the site we would 15 probably pick up the slack.
16 MEMBER HALNON: That's sort of just a 17 technique to say If they weren't there, you would fill 18 that gap. So now you are crediting portion of your 19 responsibility to FERC, and that's the line of 20 questioning and how you manage that interface. It's 21 not a criticism of allowing FERC to do it. I'm 22 perfectly happy with that.
23 MEMBER SUNSERI: But I think the telling 24 part of all this discussion is that the end of the 25 day, there was not a plant-specific aging management 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 1 plan for this AC power. It all fit in the scope of 2 the generic stuff and whether -- I don't know If there 3 was an exception or not. I didn't remember seeing it, 4 but you know. So on a system level, this is just like 5 any other AC power at any other nuclear power plant as 6 far as aging management and license renewals go.
7 So you know, there is some nuance here 8 obviously, but it wasn't anything that they had to go 9 create some plant-specific -- plant-specific program, 10 I guess, for license renewals. I think that's -- keep 11 that in mind as kind of an overall conclusion here.
12 Anything else?
13 (No response.)
14 MEMBER SUNSERI: All right. Well, you can 15 continue.
16 MR. NADEL: I'll turn it back over to 17 Mark.
18 MR. YOO: Next slide, please. So in 19 conclusion for the SLR application safety review, the 20 staff finds the requirements of 10 C.F.R. 5429(a) have 21 been met for the subsequent license renewal for Oconee 22 Nuclear Station Units 1, 2 and 3, and we'll be happy 23 to answer any additional questions you might have.
24 Thank you.
25 MEMBER SUNSERI: Members, anything else?
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116 1 DR. SCHULTZ: I have one additional 2 process question. It seemed -- this is Steve Schultz.
3 It seemed like in this review, that the interaction 4 between the NRC and the applicant, as it was 5 associated with their request for additional 6 information and responses back, ran very smoothly.
7 Were there any particular changes for this review in 8 that regard? It seemed like you were bundling 9 together the requests for information in certain ways 10 that were making it more -- the process more 11 efficient?
12 MS. GIBSON: At one point in our review in 13 our back and forth with the RAIs, we determined that 14 it would be more efficient for us to have public 15 meetings during the RAI response development phase, to 16 minimize the paper work back and forth between the 17 licensee and us. Hence the seven public meetings we 18 had on that RAI process, and we found that to be a 19 faster way for issue resolution in this case.
20 DR. SCHULTZ: Those meeting were held over 21 a day period, two day period? I mean how did that 22 interaction go for each of the, each of those 23 interactions?
24 MS. GIBSON: It was staggered, based on 25 when information became available, to be able to 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
117 1 discuss. Some of them I believe were bundled, but 2 some were separate.
3 MEMBER HALNON: So you permitted some of 4 your technical questions to be answered in the public 5 meetings, which made them go -- either go away or --
6 MS. GIBSON: No, it wasn't that it --
7 MEMBER HALNON: I'd just say, how would it 8 make it faster to have a public meeting, because it 9 seems like that bogs things down?
10 MS. GIBSON: So the way the RAI process 11 normally goes, is the NRC creates the question, has a 12 clarification call with the licensee saying do you 13 understand what we need, everybody's okay with it, we 14 issue it, and then we get something back from the 15 licensee. If the licensee completely missed the mark, 16 you know, if we did not communicate clearly and 17 everyone thought we had communicated clearly, then 18 that means we need another round.
19 So if we have this intermediate public 20 meeting in the middle, where they can say here's what 21 we're thinking of responding; is this what you're 22 looking for, then we can have a more substantive 23 discussion and get to the final answer faster.
24 MEMBER HALNON: And I think we're kind of 25 saying the same thing, but I understand now.
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118 1 MEMBER BROWN: This is -- oh I'm sorry, 2 Steve. Go ahead.
3 DR. SCHULTZ: Go ahead --
4 MEMBER BROWN: If you found that 5 beneficial, let me backtrack, which I always do. It 6 means a problem. I like the idea of meetings, but in 7 my old program there was no such thing as a public 8 meeting at the Naval. You just couldn't put it out.
9 It was just too convoluted.
10 But when you're trying to ensure that the 11 applicant or a vendor understands your questions, face 12 to face back and forth as opposed to paper Q and A's 13 are far superior to ensuring you're going to get an 14 answer back with the question you really intended to 15 ask. So you say that was successful, and based on 16 looking at the time it has taken to do other 17 interactions with RAIs, is there some way you all are 18 trying to move this process that you used to improve 19 the NRC's process in other areas on RAIs?
20 MS. GIBSON: I can't speak beyond my 21 division. We have spoken about this with the New 22 Reactors Group, because we're in the Division of New 23 and Renewed Reactors. I will say this is -- this was 24 a good way to approach the issues that were not 25 resolved in the first round in RAIs and the second 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
119 1 round. It would have been inefficient to do it for 2 all 77 RAIs that went out at the beginning.
3 MEMBER BROWN: Some are simple and some 4 are not?
5 MS. GIBSON: Right. So there's a point at 6 which we're like okay, let's move into this process.
7 MEMBER BROWN: Okay. I just like face to 8 face, as you can obviously see.
9 MS. GIBSON: As do we. We're very happy 10 to see Oconee here today, yes.
11 MEMBER SUNSERI: Anything else?
12 MEMBER BROWN: Nope, that's it. Thank 13 you.
14 MEMBER SUNSERI: Any other members? Vice 15 Chair Kirchner, are you on the line? Do you have 16 anything?
17 MEMBER KIRCHNER: Thank you, Matt. No, 18 no. Thanks to all the presenters. Very useful.
19 MEMBER SUNSERI: Okay, all right. So I 20 guess then we are at the end of the formal 21 presentations here. The path forward will be we'll 22 take the information that we've received from both 23 these presentations. We'll put together a letter 24 report that will -- we will -- prior to deliberating 25 and reviewing with the full Committee at two o'clock 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
120 1 today in this room and --
2 CHAIRMAN REMPE: We need to open the line 3 for public comments.
4 MEMBER SUNSERI: Oh yeah, sure. I always 5 forget that part. That's not pushing the button.
6 There's two requirements that an ACRS member has, call 7 for public comments, push the button. I failed on one 8 of them. So at this point, we will turn to the public 9 line here and ask If there are any comments. If 10 you're on the phone, *6 on mute. If not, If you're on 11 the teams, just state your name and make your comment.
12 (Pause.)
13 MEMBER SUNSERI: All right. So we have 14 none, and thank you.
15 CHAIRMAN REMPE: Thank you.
16 MEMBER SUNSERI: And I will turn it back 17 to the Chair.
18 CHAIRMAN REMPE: Thank you very much. A 19 very good meeting. I appreciate the applicant's 20 presentations, our licensee's presentations as well as 21 the staff's presentation.
22 At this point, we are going to go off the 23 record for the entire meeting, and I think I'm correct 24 about that today. I was confused yesterday, but thank 25 you for your support and we'll all return here at 2:00 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
121 1 p.m. and hopefully have another fun letter-writing 2 session, right? Thank you.
3 (Whereupon at 11:07 a.m., the above-4 entitled matter went off the record.)
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Advisory Committee on Reactor Safeguards Oconee Nuclear Station, Units 1, 2, and 3 Subsequent License Renewal Application (SLRA)
Safety Evaluation (SE)
February 2, 2023 Mark Yoo, Senior Project Manager Jared Nadel, Senior Resident Inspector
Presentation Outline
- Oconee Nuclear Station (Oconee) Licensing History
- Oconee Aging Management Programs
- Specific Technical Areas of Review
- Inspections and Plant Material Conditions
- Conclusion on Oconee SLRA Review 2
Oconee, Units 1, 2, and 3:
Licensing History Initial License Renewal Initial Initial License Renewed Expiration Unit License Renewal Application License Date 1 2/6/1973 7/7/1998 5/23/2000 2/6/2033 2 10/6/1973 7/7/1998 5/23/2000 10/6/2033 3 7/19/1974 7/7/1998 5/23/2000 7/19/2034 Subsequent License Renewal Application Submitted 6/7/2021 Acceptance Determination 7/28/2021 Safety Evaluation 12/19/2022 3
Oconee Units 1, 2, and 3 Aging Management Programs SLRA - Original Disposition of AMPs SE - Final Disposition of AMPs o 48 AMPs in total o 48 AMPs in total o 34 existing programs o 34 existing programs
- 6 consistent with GALL-SLR
- 6 consistent with GALL-SLR
- 27 consistent with
- 27 consistent with enhancements and/or enhancements and/or exceptions exceptions
- 1 plant-specific
- 1 plant-specific o 14 new programs o 14 new programs
- 12 consistent
- 11 consistent
- 2 consistent with exceptions
- 3 consistent with exceptions 4
Specific Areas of SLRA Review
- Reactor Pressure Vessel Neutron Embrittlement
- Reactor Vessel Internals - Irradiation-Assisted Stress Corrosion Cracking
- Irradiated Concrete and Containment
- Electrical Cable Qualification and Condition Assessment
- Keowee Hydro Station 5
Region II: AMP Inspections License Renewal Inspection Program for Initial Period of Extended Operations Inspection Dates Results U1 IP 71003 April 11-14, 2011 No Findings Phase 1 ML111250604 U2 IP 71003 November 5-12, 2012 No Findings Phase 1 ML12335A243 U3 IP 71003 April 21-24, 2014 No Findings Phase 1 ML14153A244 U1, U2 & U3 IP 71003 August 6 - 23, 2012 No Findings Phase 2 ML12277A420 U1 & U2 IP 71003 June 6-10, 2022 No Findings Phase 4 ML22209A250 6
Region II: AMP Inspections ROP Baseline Inspections Inspection Date Aging Management Program IP71111.08 ISI Biennial per unit Augmented Inspection Activities 2022 U1 Boric Acid Corrosion Surveillance 2021 U2 ISI Program - Component and Component Support 2022 U3 Inspections ISI Program - Containment Inspections ISI Program - Reactor Vessel Reactor Vessel Internals Inspection Steam Generator Inspections IP71111.07T Heat Sink Triennial Service Water System and Inspection of Water 2021 Control Structures IP71111.21N Triennial Fire Protection 2022 IP71152 PI&R Biennial Ensure activities in the licensees aging management 2021 program are adequate to identify the aging effect prior to loss of SSC intended function, and whether the licensees corrective actions address the adequacy of the aging management program.
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Region II: Plant Material Condition and Conclusion
- Plant material condition meets regulatory requirements for systems, structures, and components.
- The inspectors found that the AMPs were being implemented in accordance with the license condition.
- The NRC will continue to monitor AMPs using the baseline Reactor Oversight Process.
8
SLRA Review Conclusion On the basis of its review of the SLRA, the staff determined that the requirements of 10 CFR 54.29(a) have been met for the subsequent license renewal of Oconee Nuclear Station, Units 1, 2, and 3.
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Oconee Nuclear Station Units 1, 2, and 3 Subsequent License Renewal Application Advisory Committee on Reactor Safeguards February 2, 2023
Introductions
Rounette Nader - Duke Energy License Renewal Director Steve Snider - Oconee Nuclear Station Vice President Greg Robison - Duke Energy Subsequent License Renewal Manager Joe Terrell - Duke Energy Subsequent License Renewal Technical Lead 2
Agenda
- Oconee Nuclear Station
- Station Overview
- Licensing Overview
- Performance
- Significant Plant Modifications
- Subsequent License Renewal Application
- Subsequent License Renewal Application Development
- Process Advancement for Subsequent License Renewal
- Oconee Subsequent License Renewal Aging Management Program Results
- Key Technical Topics
- Reactor Vessel Internals
- Reactor Vessel Supports
- Concrete Embrittlement
- Closing Remarks 3
Oconee Nuclear Station Steve Snider 4
Oconee Nuclear Station Overview
- Oconee Nuclear Station (Oconee) is a three-unit, Babcock & Wilcox (B&W) nuclear steam supply system, pressurized water reactor (PWR) plant, using once through cooling
- Oconee produces 2,554 megawatts, enough to power more than 1.9 million homes
- Oconee sits on 510 acres adjacent to Lake Keowee in Seneca, SC
- Emergency AC power for Oconee is supplied by Keowee Hydroelectric Station
- Standby Shutdown Facility is backup to existing safety systems (additional defense in depth) 5
Oconee Nuclear Station Overview Lake North Keowee Discharge Keowee Auxiliary Hydroelectric Building Station Unit 1 230 kV Turbine Switchyard Standby Building Shutdown Unit 2 Facility Unit 3 525 kV Switchyard Intake 6
Oconee Nuclear Station Licensing Overview Licensing Action Unit 1 Unit 2 Unit 3 Full Power Licenses February 6, 1973 October 6, 1973 July 19, 1974 Site-specific license issued - 1987 Independent Spent Fuel Storage Renewed site-specific license issued - 2009 Installations General license issued - 1997 Power uprate Approved February 2021 Initial License Renewal Issued May 23, 2000 Entered Period of Extended Operation February 6, 2013 October 6, 2013 July 19, 2014 Current License Expiration February 6, 2033 October 6, 2033 July 19, 2034 Subsequent License Renewal June 7, 2021 Application Submittal 7
Oconee Performance
- Each Oconee unit operates on a 24-month refueling frequency
- Breaker-to-breaker runs for each Oconee Unit during the last full cycle of operation
- Unit 1 - 710 days, Unit 2 - 701 days, Unit 3 - 727 days
- Plant Capacity Factors Year Unit 1 Unit 2 Unit 3 2020 92.2 103.0 92.9 2021 102.2 94.0 101.6 2022 94.2 95.9 93.2 3-year average 96.2 97.6 95.9
- Regulatory Status
- Reactor Oversight Process (ROP) Actions Matrix Column 1
- All ROP Indicators are Green 8
Significant Plant Modifications Modification Unit 1 Unit 2 Unit 3 Replaced Once-Through Steam Generators 2003 2004 2004 Replaced Reactor Vessel Heads 2003 2004 2003 Replaced Reactor Protection Systems/Engineered Safeguards 2011 2013 2012 Installed Borated Water Storage Tank Tornado Missile Protection 2012 2012 2012 Replaced Carbon Steel Low Pressure Service Water Inlet/Outlet 2014, 2016, 2011, 2013 2010 Piping to Reactor Coolant Pumps with Stainless Steel 2022 Replaced/Upgraded Main Step-up Transformer 2018 2015 2016 Replaced High Pressure Feedwater Heater 2016 2017 2020, 2022 Replaced Low Pressure Turbines Rotors 2020 2019 2020 Installed Protected Service Water 2016 Adopted NFPA 805 Licensing Basis 2016 Replaced Turbine Building Roof 2019 Keowee Unit 1: 2014 Replaced Keowee Rotor Poles Keowee Unit 2: 2014 Keowee Unit 1: 2019 Replaced Keowee Stators Keowee Unit 2: 2020 9
Subsequent License Renewal Application Greg Robison 10
Subsequent License Renewal Application Development
- Developed by
- In-house Duke Subsequent License Renewal (SLR) team
- Augmented with key vendor support
- Used Contemporary Guidance
- Comprehensive Scoping & Screening was performed based 19 on NUREG-2192, NEI 17-01, and Regulatory Guide 1.188
- Integrated Plant Assessment results presented consistent with contemporary style and detail
- Time-limited Aging Analysis results addressed for 80 years
- SLR aging management programs have been harmonized with NUREG-2191 Oconee SLR Application printed (4010 pages) 11
Subsequent License Renewal Application Development
- Applied Lessons Learned & Experience
- SLR Lead Plants - Lessons applied in Oconee application development
- Industry Participation - Duke participated with the industry during the development of the Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR)
Report (NUREG-2191)
- Application Peer Reviews - Participated in peer reviews and received a peer review of the Oconee SLR Application
- License Renewal Aging Management Program Effectiveness Reviews - Initial Oconee license renewal aging management program effectiveness reviews performed using elements of NEI 14-12
- NRC Staff Review - In June 2022, an IP-71003 Phase 4 inspection was conducted to assess aging management program effectiveness. No issues identified.
12
Process Advancement for Subsequent License Renewal
- License Renewal Process Advancement
- For SLR, process advancements like those captured in GALL-SLR mean even further refined programmatic actions for the subsequent period of extended operation (SPEO)
- For initial License Renewal, Oconee was a pre-GALL plant (LR Pre-GALL)
- Scoping & Screening
- SLR Scoping & Screening followed NUREG-2191 (GALL-SLR) and NUREG-2192 Standard Review Plan of SLR Applications (SRP-SLR)
- Minimal Differences from LR Pre-GALL
- Scope expansion required to address 10 CFR 54.4(a)(2)
- Scope expansion due to adoption of NFPA 805 for Fire Protection Program
- Aging Management Review
- SLR aging management review results had a high consistency (99.3% Notes A thru E) with GALL-SLR
- LR Pre-GALL used industry-derived aging effects identification tools
- Applying GALL-SLR allows for enhanced standardization of the Oconee aging management programs 13
Process Advancement for Subsequent License Renewal
- Aging Management Programs
- SLR - credited 48 aging management programs
- Industry and plant-specific operating experience reviewed for a 10-year period
- Effectiveness of existing aging management programs confirmed by operating experience & no new aging effects were identified
- LR Pre-GALL - credited 26 aging management programs and numerous preventive maintenance activities
- Site and Fleet Participation
- Current site and fleet program owners reviewed SLR aging management programs
- For new SLR aging management programs, these reviewers included their perspectives in the program design and ensured feasibility of the SLR commitments 14
Oconee Subsequent License Renewal Aging Management Program Results Oconee SLR Consistent Consistent With With Aging with GALL- with Exception Exception and Plant Specific Management SLR Enhancement Only Enhancement Programs Existing 6 20 2 5 1 34 New 11 0 3 0 0 14 Total 48 15
Key Technical Topics Joe Terrell 16
Key Technical Topics
- Reactor Vessel Internals
- Reactor Vessel Supports
- Concrete Embrittlement 17
Reactor Vessel Internals
- The MRP-227-A Gap Analysis used MRP-227, Revision 1-A as the starting point and identified several new primary and expansion inspection items
- New Primary Items with Expansion
- Oconee Unit 2 core barrel cylinder top flange circumferential weld and center circumferential weld. Expansion items include all remaining core barrel cylinder welds for Units 1, 2, and 3.
- Lower grid rib section for Units 1, 2, and 3. Expansion items include the upper grid assembly for Units 1, 2, and 3.
Aging Management Programs
- Neutron Fluence Monitoring Program (X.M2)
- PWR Vessel Internals Program (XI.M16A) 18
Reactor Vessel Supports
- As with all 177 fuel assembly (FA) lowered loop B&W designs, the Oconee reactor vessel utilizes a welded steel support skirt assembly that consists of a support skirt, support flange, anchor bolts, and associated embedment items (e.g., sole plate, vertical bearing plate, and nelson studs)
- Support skirt, support flange, sole plate, and vertical bearing plate are all made from carbon steel; anchor bolts and associated fasteners are made from low alloy steel
- No structural support is provided at the reactor vessel nozzles 19
Reactor Vessel Supports
- Support skirt and embedment carbon and low alloy steel items were evaluated for susceptibility to irradiation embrittlement using the process documented in NUREG-1509, Radiation Effects on Reactor Pressure Vessel Supports
- For those items (i.e., Units 1, 2, and 3 support flange and nelson studs, and Units 1 and 2 support flange welds) in which the NUREG-1509 evaluation found potentially susceptible to irradiation embrittlement, further evaluation was completed to demonstrate that intended function will be maintained throughout the SPEO
- Based on this evaluation of the effects of irradiation embrittlement on component intended function, the reactor vessel supports intended function will be maintained consistent with the current licensing basis throughout the SPEO Aging Management Programs
- Fatigue Monitoring Program (X.M1)
- Boric Acid Corrosion Program (XI.M10)
- ASME Section XI, Subsection IWF Program (XI.S3) 20
Concrete Embrittlement
- The key topic of concrete embrittlement focused on the primary shield wall and reactor vessel pedestal concrete which supports the reactor vessel support skirt
- Primary Shield Wall
- The primary shield wall does not provide a support function for the reactor coolant system
- Projected maximum radiation exposures on the inner surface of the primary shield wall at the end of the SPEO (72 EFPY) are less than GALL-SLR thresholds above which irradiation damage is a potential concern for concrete embrittlement
- Concrete thermal embrittlement is not a concern. Duke confirmed through thermal analyses of the primary shield wall, using updated gamma heating rates generated for SLR, that general area and localized area concrete temperatures will be below 150°F and 200°F, respectively.
21
Concrete Embrittlement
- Reactor Vessel Pedestal Concrete
- The reactor vessel pedestal provides a support function for the reactor coolant system
- Projected maximum radiation exposures on the reactor vessel pedestal concrete at the end of the SPEO (72 EFPY) are less than GALL-SLR thresholds above which irradiation damage is a potential concern for concrete embrittlement
- General concrete temperatures will be below 150°F as confirmed through thermal analyses of the pedestal support, using updated gamma heating rates generated for SLR
- Localized concrete areas directly below the reactor vessel support flange at the shear pin locations are conservatively predicted to have localized temperatures slightly higher than 200°F; considering the conservatisms used in the analysis, the risk that actual temperatures would exceed 200°F is minimal; therefore, concrete thermal embrittlement is not a concern Aging Management Programs
- ASME Section XI, Subsection IWF Program (XI.S3)
- Structures Monitoring Program (XI.S6) 22
Closing Remarks Rounette Nader 23
Closing Remarks
- Duke Energy submitted a high-quality Oconee SLR Application
- Duke Energy team is comprised of individuals experienced with license renewal and familiar with Oconee systems and programs
- Oconee aging management reviews have a high degree of consistency with GALL-SLR
- Duke Energy will continue to invest in people, program enhancements and equipment modifications, laying the foundation for the SPEO 24
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