ML23221A040
| ML23221A040 | |
| Person / Time | |
|---|---|
| Issue date: | 07/26/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2472 | |
| Download: ML23221A040 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Plant Operations and Fire Protection Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, July 26, 2023 Work Order No.:
NRC-2472 Pages 1-97 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 PLANT OPERATIONS, RADIATION PROTECTION, AND FIRE 7
PROTECTION SUBCOMMITTEE 8
+ + + + +
9 WEDNESDAY 10 JULY 26, 2023 11
+ + + + +
12 The Subcommittee met via Teleconference, 13 at 1:00 p.m. CDT, Gregory H. Halnon, Chair, presiding.
14 COMMITTEE MEMBERS:
15 GREGORY H. HALNON, Chair 16 RONALD G. BALLINGER, Member 17 VICKI M. BIER, Member 18 JOSE A. MARCH-LEUBA, Member 19 ROBERT MARTIN, Member 20 WALTER L. KIRCHNER, Member 21 DAVID A. PETTI, Member 22 JOY L. REMPE, Member 23 THOMAS ROBERTS, Member 24 MATTHEW W. SUNSERI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 ACRS CONSULTANT:
1 STEPHEN SCHULTZ 2
3 4
DESIGNATED FEDERAL OFFICIAL:
5 KENT HOWARD 6
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 TABLE OF CONTENTS 1
Opening Remarks and Objectives 2
By Gregory Halnon..............4 3
Opening Remarks 4
By John Monninger..............7 5
RIV Presentations 6
Reactor Oversight Process Status, Findings 7
& Crosscutting Issue Trends, Occupational 8
Dose Trends, and Effectiveness..........17 9
Specific topic - Perspectives on Diablo Canyon Nuclear 10 Power Plant License Renewal Venture....... 27 11 Specific topic - Texas Cold Weather Event in 12 2021, grid reliability, grid black start 13 capability, nuclear plant
........... 53 14 performance and vulnerabilities 15 Regional staffing, knowledge management, and 16 inspector pipeline discussion.......... 65 17 Opportunity for public comment
......... 95 18 Adjourn 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 P-R-O-C-E-E-D-I-N-G-S 1
1:00 p.m.
2 CHAIR HALNON: Good afternoon. This is a 3
meeting of the Plant Operations and Fire Protection 4
Subcommittee of the Advisory Committee on Reactor 5
Safeguards. I am Greg Halnon, Chairman of today's 6
subcommittee meeting. ACRS members in attendance are 7
Dave Petti, Jose March-Leuba, Joy Rempe, Matthew 8
Sunseri, Ron Ballinger, Walter Kirchner, Vicki Bier, 9
Bob Martin, Tom Roberts, and we have ACRS consultant 10 Steve Schultz with us. Did I miss anybody?
11 Kent Howard and Chris Brown of the ACRS 12 staff are the Designated Federal Officials for this 13 meeting. The ACRS reviews and advises the Commission 14 with regard to the licensing and operation of 15 production and utilization facilities on safety 16 issues. Also, the adequacy of proposed reactor safety 17 standards, technical, and policy issues relevant to 18 the licensing of evolutionary and passive plant 19 designs and other matters referred to it by the 20 Commission.
21 During today's meeting, the subcommittee 22 will hear presentations by and hold discussions with 23 the NRC staff at Region IV on operation experience in 24 the areas of the reactor oversight process, and you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 might hear this referred to as the ROP. The 1
applicant's license renewal (Audio interference.)
2 topics of interest. Although I do not anticipate the 3
need for the discussion of classified information that 4
is proprietary or security related pursuant to the 5
Freedom of Information Act. If attendants at those 6
meetings deal with such information, they'll be 7
limited to the NRC staff and its consultants and 8
organizations who have entered into the appropriate 9
confidentiality agreements with them. Consequently, 10 we will need to confirm eligible observers and 11 participants in the closed part of the meeting prior 12 to the start of today's meeting. And, again, I don't 13 anticipate the need for that with our agenda.
14 The ACRS was established by statute and is 15 governed by the Federal Advisory Committee Act (FACA).
16 The Committee only speaks through its published letter 17 reports. Because this is a subcommittee meeting, 18 participants should consider any remarks by the ACRS 19 members as their personal comments and not committee 20 positions. We hold subcommittee meetings to gather 21 information for preparatory work in the support of 22 deliberations at the full Committee meeting as 23 necessary.
24 The rules for participation in all ACRS 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 meetings, including today's, are announced in the 1
Federal Register on June 13, 2019, the ACRS section of 2
the U.S. NRC public website provides our charter, 3
bylaws, agendas, letter reports, and full transcripts 4
of all full and subcommittee meetings, including 5
slides presented there. This meeting -- the agenda 6
for this meeting will be posted there, as well. We 7
have received no written statements or requests to 8
make an oral statement from the public.
9 Today's meeting is a hybrid meeting of NRC 10 Region IV with Microsoft Teams, which includes a 11 telephone bridge line allowing participation of the 12 public over telephone or over the computer. There 13 will be an opportunity for public comment, and we have 14 set aside time at the conclusion of the prepared open 15 presentations and member discussions to have those 16 comments.
17 This meeting is being transcribed. A 18 transcript of the meeting is being kept (audio 19 interference), and it is requested that the speakers 20 identify themselves and speak with sufficient clarity 21 and volume so that they can be readily heard.
22 Additionally, participants should mute themselves when 23 not speaking. To mute on a phone bridge line, please 24 push *6. Teams will simply unmute their selected 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 microphone. Raising your hand virtually will be noted 1
as your cue to speak.
2 We will now proceed with the meeting, and 3
I'd like to start by calling on staff, specifically 4
the newly appointed Deputy Regional Administrator John 5
Monninger.
Congratulations on your recent 6
appointment, and he's gone. There he is.
7 MR. MONNINGER: Came up around the other 8
side.
9 CHAIR HALNON: I had to rehearse passing 10 the microphone back to you.
11 MR. MONNINGER: So I apologize for that.
12 Good afternoon. I'm John Monninger, the Deputy 13 Regional Administrator for NRC's Region IV office down 14 here in Arlington, Texas. I have the honor of 15 welcoming you, the ACRS Subcommittee on Plant 16 Operations and Fire Protection, to our Region IV. It 17 really is a rare and important opportunity for us 18 within the region to host the ACRS, and we do thank 19 you all for your interest in coming out here and the 20 time that you're going to spend with us.
21 You know, over the past 34 years, 22 predominantly within Headquarters, I have had many 23 opportunities to brief and interact with the ACRS, and 24 for the vast majority of the time I've found those 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 interactions enjoyable. You know, thinking about the 1
regional staff, you know, what I would probably 2
compare the interactions or the discussions with the 3
ACRS, it would be comparable to a qual board. We have 4
our inspectors that go through training and 5
development, et cetera. Prior to getting an official 6
certification, they have to go in front of a qual 7
board of their peers, management, et cetera. So to a 8
certain extent, I draw parallel between briefings in 9
front of the ACRS in terms of the NRC's technical work 10 to the qual boards that our inspectors in the field 11 do.
12 So how far back do I go? I guess, did you 13 hear the -- okay. So we're on slide two. I 14 mentioned, you know, NRC's staff are our greatest 15 assets, not just within Region IV but across the 16 agency, just in terms of their knowledge, skills, and 17 ability, and, above all, their commitment to our 18 public health and safety mission, in addition to that 19 their commitment to public service, public service for 20 the federal government, public service for our 21 country.
22 As you're aware, Region IV is one of the 23 four regional offices. To a large extent, the four 24 regional offices are identical. There are some slight 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 differences between regions. Region I, III, and IV 1
are essentially identical. Region II has a little bit 2
of differences in terms of their responsibility for 3
fuel cycle facilities, and they're the lead for the 4
NRC's construction oversight programs within Region 5
II.
6 While Headquarters back in Rockville is 7
responsible for development of the policies and the 8
procedures, it's the regional offices that execute 9
those programs and policies, you know, be it the 10 inspection
- programs, the oversight
- programs, 11 enforcement programs, the allegations programs, the 12 investigative programs, et cetera. Again, they're all 13 covered by the regional offices. In addition, our 14 interactions with the states, the agreement states, 15 that occurs through the regions.
16 Region IV, I believe or I think we 17 believe, is a little bit different. You know, just 18 some interesting facts and figures. We cover 22 and 19 a half states, so the question is what is the half 20 state. Missouri. We had the Callaway reactor versus 21 the materials program for the state of Missouri in 22 Region III. So we have the 22 states, plus the 23 Callaway reactor, within Missouri.
24 Those states, when you look at that land 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 mass area, it covers 75 percent of the land mass or 1
land area within the U.S. We cover 10 of the 24 time 2
zones across the country from, I guess, the Central 3
within Mississippi, taking us all the way across the 4
Pacific to Guam, the U.S. territory above Guam. Our 5
inspectors go up to the north slopes of Alaska to do 6
inspections, in addition to the territory of Guam, 7
and, occasionally, also will go out on oil rigs within 8
the Gulf of Mexico.
9 So there are some unique issues in terms 10 of that vast area and the travel time and the 11 resources and the time to support that. But other 12 than that, you know, Region IV operations are very 13 similar to the other three regions.
14 You know, I know we're going to focus on 15 the operating reactors, et cetera, but I did want to 16 mention, you know, briefly our materials program. Of 17 the 22 states within our Region IV area, 6 states are 18 under NRC jurisdiction and the 16 states are within 19 state jurisdiction, and then the state of Wyoming is 20 sort of split between NRC overseeing materials and the 21 state of Wyoming overseeing the uranium.
22 We have 500-plus materials licensees that 23 our Region IV interacts with and completes 24 approximately 300 materials licensing actions per year 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 and also oversees the Air Force Master Materials 1
License. Going back to operating reactors, which is 2
more the purview of this subcommittee, there are 18 3
units, 18 operating units within Region IV at 12 sites 4
across 10 states. Eight are Westinghouse large PWRs, 5
six are combustion engineering designs, one BMW design 6
up in Arkansas, and four General Electric BWRs.
7 As I think we mentioned earlier today, we 8
have a staffing level of approximately 160 or so FTE 9
or staff. We're at our staffing level. With that 10 said, there is pretty significant hiring and attrition 11 across the agency, and Region IV is in the midst of 12 the hiring, training, developing, and qualification of 13 our staff.
14 So we do have, we established the Region 15 IV staff, actually, prior to me arriving down here and 16 developed a vision. It was a ground-level effort to 17 establish a vision and then some parties associated 18 with that. So our vision within Region IV is together 19 we foster a culture of high trust that maximizes 20 professional growth and development and inspires 21 leadership at all levels. So, you know, that really 22 encompasses three aspects: trust with one another, 23 trust with our licensees, trust with the general 24 public, maximizing professional growth, the next 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 generation of individuals to come up through the NRC 1
and run the agency, and also focuses on leadership at 2
all levels. Leadership does depend upon the 3
supervisory level and managerial level. Leadership is 4
across all aspects of the agency. It's across all 5
aspects of the staff.
6 Our three parties are, of course, the 7
first one very much focused on our safety and security 8
mission, completing the materials and the reactors 9
inspection and licensing programs. We're on track for 10 that this year. The more recent, I guess, challenge 11 we've had post-COVID is working within the new hybrid 12 working environment. I guess we probably have a year, 13 year and a half under our belt since reentry and 14 currently we don't have any significant challenges in 15 terms of the hybrid work environment. The agency is 16 looking at changing that environment, and we'll 17 address that when it potentially comes around.
18 Probably, the biggest one I do think 19 across the agency and really for us in Region IV is 20 the management of human capital. You know, the 21 recruitment, training, development, qualification, and 22 even when an individual is qualified, you know, 23 they're essentially an apprentice or eventually a 24 journeyman. So, you know, it can be a year and a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 half, two years, until an individual is qualified, but 1
you really want those individuals to have three - four 2
years at the sites or three - four years doing 3
specialized inspections is what is really needed.
4 So we got a very, very strong focus on 5
staffing. The branch chiefs are, you know, really in 6
the lead for it, and they've been doing some pretty 7
significant accomplishments in terms of outreach and 8
in terms of really bringing in a fresh new set of eyes 9
to the agency and training and qualifying those.
10 And the last one up there was working 11 again towards our vision, and I mentioned, well, I 12 didn't mention our transformation action plan, but a 13 lot of activities underway in terms of what we're 14 doing to invest in ourselves within Region IV to make 15 us a better organization.
16 I think, with that, what we wanted to do 17 was to roll in to the presentations. As was mentioned 18 earlier, there are four presentations. I'd like to 19 just introduce the speakers for those four 20 presentations, and we'll go from there.
21 So the first presentation will be on the 22 trends and insights from the reactor oversight 23 process. Ami Agrawal and Dr. Natasha Greene will be 24 leading up those discussions. Ami is the team leader 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 for inspection program and assessment team, and she's 1
been with the NRC for approximately 20 years now.
2 She's worked in Regions I, Regions II, Headquarters, 3
and was previously a resident inspector up at the 4
Indian Point site. Natasha Greene also has worked in 5
Headquarters and Region IV. She was previously a 6
senior health physicist within Region IV. She has a 7
Ph.D. in atmospheric physics and is currently a team 8
leader in her particular branch. So those two will 9
lead up our first discussion and our presentation.
10 The next session will be on our 11 preparations for Diablo Canyon license renewal and the 12 various activities that Region IV does to support 13 that, and that will be led by Mr. Greg Pick. Greg is 14 currently a
senior reactor inspector in the 15 Engineering Branch. He has been an inspector for more 16 than 40 years. He's been involved in license renewal 17 inspections for the past 20 and, prior to that, 18 license renewal project management. So Greg brings a 19 lot of experience and run time in license renewal.
20 Following that, we'll have a discussion on 21 the Texas severe weather event from back in February 22 2021 led up by Mr. Sam Graves. Sam is also a senior 23 reactor inspector in the Engineering Branch, too.
24 He's had a lot of focus on fire protection and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 cybersecurity over the years, and he's been with the 1
NRC for, I guess, the past 18 years, has a strong 2
focus in electrical engineering and, prior to that, he 3
served in the U.S. Navy.
4 And then rounding us out in presentation 5
four is one of our branch chiefs from our Project 6
Branch, Mr. John Dixon. As Project Branch Chief, he 7
has oversight responsibilities for the Arkansas 8
Nuclear One site, the Palo Verde site, and the 9
Waterford site. He was previously a resident, a 10 senior resident inspector, and has been with the NRC 11 for more than 20 years.
12 So with that, we'll roll with the first --
13 we'll see if there's any questions, and then we'll --
14 MEMBER KIRCHNER: What I wanted to ask 15 John is how hybridized are you, so to speak? I would 16 just think that you, being, you know, a regional 17 office, you're working with the plants, so that's hard 18 to do virtually in many aspects.
19 MR. MONNINGER: So a lot goes into 20 definitions, you know, what is hybrid, what is 21 telework. If you think about the whole role of a 22 resident inspector, resident inspectors aren't within 23 this building, so the agency has had resident 24 inspectors since post-TMI. I'm not sure if it was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 before TMI; I think it was an action item -- they were 1
exploring it during TMI, the Three Mile Island 2
accident, and it was implemented afterwards.
3 So we've always had those remote staff out 4
there, you know. Prior to COVID, I would say the vast 5
majority of the staff throughout the agency was 6
probably, well, at least a CWS, you know, maybe a day 7
or two. So within our Region IV, the agency stance is 8
currently up to six days per pay period telework and 9
four days in the office. I think, in terms of our 10 staff, I think we've got about 60 percent or so that 11 take advantage of it.
12 I think one of the things you have to 13 recognize, though, you know, when you talk about 14 regional staff and inspectors, prior to that, you 15 know, 30 percent of their time was on the road. So, 16 yes, so the inspectors are still going out in the 17 fields. In terms of the hybrid environment, the vast 18 majority of that hybrid approach would have been more 19 time within the office, as opposed to time at the 20 sites. There are some, you know, some aspects of time 21 at the site that they're doing, but I would say the 22 vast majority of the on-site time is back to pre-COVID 23 levels. So, if anything, the major impact would have 24 been more staff that would have reported to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 regional office. Did that make sense?
1 And so, with that, we'll roll to Ami.
2 MEMBER REMPE: John, before you switch 3
off, I just wanted to say, on behalf of ACRS, we 4
really do appreciate that you and your staff have 5
welcomed us and prepared all these presentations 6
because it is important for us to hear from the 7
regional offices as part of our mission.
8 MR. MONNINGER: And we do very much enjoy 9
having you guys come down.
10 MS. AGRAWAL: So I didn't realize there's 11 already a laptop here. I'm just going to make some 12 space for mine.
13 All right. So my name is Ami Agrawal.
14 Like John said, I'm the team lead for the inspection 15 program assessment team to share some insights on the 16 ROP trends. Don't ask too many hard questions that I 17 can't answer. No, just kidding. And then, obviously, 18 Natasha is going to, you know, speak on certain, like 19 the Columbia event on the radiation effluent data.
20 So to get started, so for Region IV, 21 currently Columbia and River Bend are the two plants 22 that are in the column two of the action matrix.
23 However, as you can see, we did have Callaway and 24 Waterford in 2022 and '23 were also in the column two 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
18 of the action matrix. Callaway had a white PI for 1
unplanned scrams per 7,000 critical hours, and then 2
we'll talk about water for Columbia and River Bend in 3
a second, just to give you a background of, you know, 4
where they are. And those state plans had white 5
findings near the greenhouse.
6 Any questions on that one?
7 MEMBER KIRCHNER: Define what column one 8
and two mean and green versus blue and how to read 9
your chart in terms of, if I'm a member of the public, 10 what do I take away from that matrix you're showing 11 us.
12 MS. AGRAWAL: So column one is licensees 13 and the licensee response column, so they have all 14 green findings, all green PIs. And when a licensee 15 moves from column one to column two is one or two 16 white findings put them in column two of the action 17 matrix to a white finding; I just say white finding in 18 the column two. And the blue is the column two, green 19 is just indicating that all the indicators for that 20 licensee is in the green band for findings and PIs.
21 CHAIR HALNON: How many unplanned scrams 22 does it take to get a white PI?
23 MS. AGRAWAL: Maybe I could call a friend.
24 But 7,000 critical hours, yes.
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
19 CHAIR HALNON: Is it one or is it two?
1 It's five. So that's pretty unusual nowadays to see 2
that. They had a 95001 inspection?
3 MS. AGRAWAL: Yes, they've had their 4
supplemental inspection, and that's why they've moved 5
from -- so once we complete the 95001 or the 6
supplemental inspection, which are 95001 one, two, or 7
three, depending on, you know which column of the 8
action matrix they are, once that's complete and the 9
report is out, the licensee moves the columns. So 10 they have had their supplemental --
11 CHAIR HALNON: Can you speak to what their 12 root cause was and what they did to fix it?
13 MS. AGRAWAL: That's a great question.
14 I'll have to call a friend because I'm not 100 percent 15 have the background on --
16 CHAIR HALNON: I don't recall --
17 (Simultaneous speaking.)
18 MS. AGRAWAL: -- information.
19 CHAIR HALNON: That's fine. The 95-001, 20 it's a public thing. I'll look it up. I was just 21 curious because an unplanned scram is unusual nowadays 22 because of how reliable the plants are.
23 MR. HAY: This is Mike Hay. I'm the 24 Deputy Director in the Division of Operating Reactor 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
20 Safety. So the unplanned scrams PI, like we talked 1
about at Callaway, was due to a scatter failure they 2
had, and that was one of the scrams. And we did the 3
95-001, and the major cause of it was just improper 4
fabrication by the vendor. And, you know, it 5
basically catastrophically failed pretty shortly after 6
they were using it.
7 Is anybody else online that might have 8
more -- it was a while back that we did that so --
9 Sam, you might know more.
10 CHAIR HALNON: I'll look it up because 11 even that, when you have like a manufacturing defect, 12 it typically doesn't reflect back on the licensee's 13 performance to some extent. But I'll look it up. The 14 second quarter of '22? Third quarter of '22?
15 MR. HAY: Yes. So the licensee did have 16 some involvement in oversight of that scatter being 17 rewound.
18 CHAIR HALNON: Okay.
19 MR. HAY: And that wasn't the only scram 20 they had. There were other scrams, but that was the 21 last scram that crossed the threshold.
22 CHAIR HALNON: Okay. But it's plain 23 depths in ---
24 MR. HAY: Absolutely.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 CHAIR HALNON: Okay. Thank you.
1 MS. AGRAWAL: Thanks, Mike.
2 CHAIR HALNON: We won't ask any questions 3
now. Oh, wait a minute, I lied. Sorry.
4 MEMBER KIRCHNER: So you're talking in 5
your jargon. ACRS aren't out in the field frequently 6
enough. Could you just refresh our memories as what's 7
the implication of being at column two, and how do you 8
get back in column one? And you were just mentioning 9
the different levels of inspection. Could you just, 10 for the public record, just say what's the difference 11 and how does one of the licensees, you know, improve 12 their whatever corrective action, or what is necessary 13 to make the transition back into the green?
14 MS. AGRAWAL: Okay. Sure. So once a 15 licensee moves from column one to column two of the 16 action matrix, so if it's for a single or two white 17 findings, then we perform 95-001, which are the 18 supplemental inspections. There are three of them, 19 95-001, 2, and 3.
20
- Now, at the completion of those 21 inspections, the NRC will issue an inspection report, 22 and we perform those inspections, obviously, we have 23 to coordinate with the licensee when they're ready for 24 us to go and inspect. So once they've completed their 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 root cause or, you know, their causal analysis and 1
they're ready for us to go and inspect, that's when 2
the team goes on site to inspect and complete the 3
inspection.
4 So once the report is issued, that's when 5
the licensee can move from column two to column one 6
and similarly for other columns. Once those 7
inspections are completed, that's when the licensee 8
moves from the higher column of the action matrix to 9
the lower.
10 Does that answer your question?
11 MEMBER KIRCHNER: Thank you. Just to 12 expand on that then, so you mentioned the different 13 types of inspections. How comprehensive are the 14 license inspections when a licensee is in, say, column 15 two to get back to one? You mentioned three different 16 levels. Does it depend on the events that caused them 17 to move to, in this case, the blue, and how 18 comprehensive is that inspection then? At some point, 19 it would be a much broader inspection of things, like 20 the quality assurance program, the effectiveness, and 21 so on.
22 MS. AGRAWAL: Yes. That's a great 23 question. So 95-001, I mean, each procedure has, you 24 know, specific inspection hours that are dedicated for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 that inspection. And it's also going to vary on, you 1
know, how complicated their event is and how expensive 2
that's -- so there's a range for each of the 3
supplemental inspections for how many hours the 4
inspectors are allowed to perform the inspection, and, 5
obviously, if they're going to 95-003, then, yes, we 6
would definitely look at their QA program, we would 7
look at their safety culture.
8 Some portion of that is going to be 9
looking at their corrective action and also their 10 safety conscious work environment on the site.
11 There's some aspect of that in each of the 12 supplemental inspections. But, obviously, the higher 13 the inspection effort, right, or the higher the color 14 of the finding, the higher number of inspection hours 15 that we're going to be spending at the site.
16 MEMBER KIRCHNER: I'll just hold on for a 17 while. I'm just intentionally drawing you out so 18 that, if I'm a member of the public listening to this 19 20 MS. AGRAWAL: Yes, that's fine.
21 MEMBER KIRCHNER: Are you limited to a 22 fixed number of hours for your inspection, or is the 23 inspection based on the issues that you're really 24 looking at and then you tailor your hours to fit the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 problem that you're addressing?
1 MS. AGRAWAL: Each inspection procedure 2
does have a set number of hours, but it's going to be 3
a range and it's going to depend on the significance 4
of the event how many hours we spent for that 5
inspection.
6 Any more on this one? Yes.
7 DR. GREENE: But the random inspection 8
hours would also depend on how engaged the licensee is 9
with the inspectors. So if we are awaiting 10 information, it can draw out that time because we're 11 still trying to interact with them and get information 12 back. So it really is a communication level, as well.
13 This was Natasha Greene.
14 MS. AGRAWAL: So moving on, I'm going to 15 share some data on the red findings and green findings 16 and then crosscutting aspects.
17 So for Region IV, like I
already 18 mentioned, we had two whites for Waterford, Columbia, 19 and one white finding from Columbia, and then we just 20 issued a white finding last week on July 20th for 21 River Bend.
22 And so just to give a background on each 23 of the findings, for Waterford, for the first one, the 24 condenser exhaust wide-range gas monitor, the mid and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 high range detectors, had errors in its output that 1
could result in an over-classification up to a general 2
emergency resulting in unnecessary public protective 3
actions. Also, the licensee failed to use adequate 4
methods, systems, and equipment for assessing and 5
monitoring actual and potential off-site consequences 6
of a radiological emergency because those same errors 7
would result in inaccurate dose assessment for a 8
radiological release through the main condenser 9
exhaust. I know that was a lot, but just to, I guess, 10 wrap it up, for their wide-range gas monitor, there 11 was a potential for over-classification just the way 12 the monitors were calibrated up to a general 13 emergency, so it impacted their emergency action 14 level, and that's what the white findings were.
15 The second white finding --
16 CHAIR HALNON: Before you go on, can you 17 recall what type of inspection that was? Was it like 18 an engineering inspection or an EP inspection? Can 19 you recall what kind of inspection --
20 MS. AGRAWAL: Yes, our EP --
21 CHAIR HALNON: The EP did?
22 MS. AGRAWAL: Yes, EP inspection.
23 CHAIR HALNON: Thanks.
24 MS. AGRAWAL: The second white finding was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 for a calibration error in wide-range gas -- I know 1
they sound similar. The licensee failed to follow and 2
maintain the effectiveness of an emergency plan.
3 Specifically, they failed to use adequate methods, 4
systems, and equipment for assessing and monitoring 5
actual and potential off-site consequences of a 6
radiological emergency. The licensee had conversion 7
factor error that would result in inaccurate dose 8
assessments for a radiological release through the 9
plant vent stack exhaust path, and so that's the 10 difference. Any questions on that?
11 For the Columbia event, the licensee 12 failed to implement and follow written procedures for 13 radiation protection resulting in two uptake of 14 radioactive materials to work, resulting in doses 15 greater than 700 millirem committed effective dose.
16 And Dr. Greene is going to talk about it on the next 17 slide.
18 And River Bend white finding was just 19 issued on July 20th, and the background of that is, 20 during a routine surveillance test of the Division 3 21 HPCS, which stands for high-pressure core spray, 22 diesel generator transformer, the licensee identified 23 that the transformer feeder was damaged, resulting in 24 a fire alarm in the switch gear room. And there was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
27 a white finding and a notice of violation for failure 1
to adequately implement maintenance inspection 2
procedure for HPCS transformer.
3 Any questions? Okay. I'll turn it over 4
to Dr. Greene.
5 DR. GREENE: All right. So I'm going to 6
quickly give a (audio interference) of the Columbia 7
event and how they basically received their white 8
finding for this particular event. So this actually 9
occurred back on May 28th, 2021, so it's been about 10 two years coming on this particular issue. What 11 happened is, actually, they were performing some work 12 in the underwater clean-up heat exchanger room. There 13 were two pipefitters that were performing a task on a 14 platform in a locked high radiation area where they 15 were getting some oversight, not continuous as 16 required but some oversight. And as a result of all 17 of this, you basically had two pipefitters that 18 received what we call internal uptakes. So when we 19 look at those internal uptakes, we would say how much 20 dose was received and, as an assessment, each of those 21 individuals received over 700 millirem of what we call 22 committed effective dose equivalent.
23 So based on that, HP inspectors jumped 24 into action. We started to review all their 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 information, received a root cause analysis from the 1
licensee. And as a result of that, we determined that 2
there was a preliminary white finding which we issued 3
in a report 2021-090 in January 13th of 2022.
4 That particular report actually documented 5
three apparent violations. One was of 10 CFR 20.1701 6
for failure to use (audio interference) Okay. I'm 7
good? Okay. All right.
8 So they were actually implementing an 9
engineering control, which was a glove bag, and the 10 two pipefitters that were implementing the use of this 11 glove bag really did not have adequate instructions on 12 how to do it, so they ended up basically installing it 13 inadequately. And as a result, they were not 14 protected from the uptake, really a puff, of 15 radioactive contaminants that came out of the piping.
16 So as a result of that, that was the 17 20.1701 violation. We also issued a 10 CFR 20.1501(a) 18 violation, which was a failure to have adequate 19 surveys for the area that those engineers were working 20 in. And then we also issued, and this was 21 preliminarily, Tech Spec 572(b) which basically says 22 that for a locked high radiation area, which means 23 that the dose rates in that area have to be at least 24 one per hour at 30 centimeters from the source. The 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
29 controls there were not implemented continuously, so 1
that was documented.
2 As a result of receiving this preliminary 3
white finding, the licensee decided that they would 4
like to present their position in a regulatory 5
conference. So they came to the NRC on March 1st of 6
2022 and presented their position on these particular 7
apparent violations. During the public meeting 8
portion, comments were made which actually warranted 9
additional investigation by our Office of 10 Investigations into this uptake event, and that review 11 was completed on March 9th of 2023. So it went almost 12 an entire year to look into the issue.
13 As a result of that, NRC inspectors 14 continued their review. Once we received the results 15 of the Office of Investigation results and, once we 16 looked at that, we did identify at that time two 17 additional violations. One of those additional 18 violations was preliminarily determined again as 19 white, so this was a separate white from the first one 20 that we issued, for a violation of 10 CFR 20.1204(a),
21 and that particular regulation basically says that you 22 have to do an adequate internal dose assessment. So 23 we found deficiencies that they had within that 24 process.
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
30 This was actually documented in an 1
inspection report on June 1st of this year. The 2
licensee has elected to respond in writing to that, 3
which I believe we just received their response today, 4
so we'll be looking at that in its entirety.
5 So as a result of all of this, inspectors 6
did make a final determination on the first 7
preliminary white, and we did determine that the final 8
significance was, in fact, white, which is for low to 9
moderate safety significance. And that also was 10 associated with the three violations that we 11 previously discussed, and that was issued in 12 Inspection Report 2023-90 on June 1st of 2023.
13 Any questions about the Columbia uptake --
14 CHAIR HALNON: Just one.
15 DR. GREENE: Sure.
16 CHAIR HALNON: I mean, the thing that 17 sticks out, obviously, is the time line.
18 DR. GREENE: Yes.
19 CHAIR HALNON: Two years. Can you address 20 what the site did in the interim or anything to 21 potentially plug any holes in their program and 22 performance so that those two years was just 23 administrative only?
24 DR. GREENE: Absolutely. So what we know 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
31 that they've done to date, they've definitely taken a 1
look at their procedures, their ALARA plans, and also 2
their oversight process to see what enhancements can 3
be implemented to prevent this from happening again.
4 I would say that they did make some changes. I think 5
they're still working on some of those changes. We 6
actually had an opportunity to go out and visit just 7
a couple of months ago, and they offered some 8
additional insights. So I think the licensee is 9
actively still looking into this process and have made 10 changes, but we have not yet conducted the 95-001 that 11 Ami has had a lot of questions about. But in that 12 particular question, the inspectors will be looking at 13 all of the corrective actions that were implemented to 14 see if it basically would prevent recurrence of this 15 type of an issue.
16 CHAIR HALNON: Okay. And you're satisfied 17 that they're not having continuing uptakes problems at 18 this point? Because, you know, just from face value, 19 it looks like there's still vulnerability there for 20 personal safety.
21 DR. GREENE: I can't say we satisfied that 22 because we haven't conducted the 95-001, but what I 23 could say is we're actively monitoring their process.
24 MEMBER REMPE: I'm curious about that they 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
32 requested this regulatory conference and, after this, 1
there were additional findings. Was that a surprise 2
to them, or did they anticipate findings would be made 3
and this maybe lowered the severity of the findings?
4 DR. GREENE: I think the reason for the 5
conference was probably a surprise to everyone. It 6
was a public conference, so this portion was public 7
comment. An individual came in and basically said NRC 8
needs to reevaluate what was just told to you, and so 9
we did just that.
10 MEMBER REMPE: Thank you.
11 DR. GREENE: Any additional questions?
12 All right. Thank you. And I just want to make one 13 additional comment. You had asked Ami about the 14 Waterford issues on the workgroups that were done.
15 That was actually a collective with EP and ROP. When 16 we go out and do HP inspections, part of that is under 17 our baseline inspection process, and so what we 18 actively do when we have those types of issues, we'll 19 look at where it's the most significant at. And so 20 those particular issues, the significance fell on the 21 EP side, so ROP supported EP in those efforts.
22 Thank you.
23 MS. AGRAWAL: So next on the trend, I'm 24 going to tell a little story here. There's three 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 slides that go with this. So green findings, if you 1
look at, you know, from 2018 until 2022, it looks like 2
that we have an increasing trend under the green 3
finding, but this is only telling a story for those 4
years. There's an increase. But if we go a little 5
bit further out, so, taking a few more years back, you 6
can see where we were in 2015, right, we're back to 7
where we are in 2022 where we were previously.
8 CHAIR HALNON: How many fewer plants are 9
operating now, though? In 2015, did you have SONGS --
10 MS. AGRAWAL: And that is one of the 11 factors; you're right. And then if we look back 12 further, about 15 years of trend, it shows altogether 13 a
different story where a
clear statistical 14 significance decrease trend is apparent from 2006 to 15 2014 and then where we are today.
16 What could we say about that, right?
17 Well, there has been some improvements that the 18 industry has made in risk reduction due to new FLEX 19 equipment that have been incorporated. There are 20 certain applications that NRC has applied. For 21 example, the AV-8 flyer SDP. We have made 22 improvements to our LB evaluate performance 23 deficiency. Just a few years back, there was an 24 effort to revise the guidance for more than minor 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 performance -- so there's a number of efforts that 1
have led throughout the years that could tell why we 2
are where we are today. Any questions?
3 Now, breaking this down for the regions, 4
there doesn't really appear to be anything noteworthy.
5 It seems to be equally distributed. Each region has 6
had at least one red and green finding since 2014.
7 Every region has been represented in the years since 8
then. Every region has had at least one year in the 9
time frame without any red and green findings, as 10 well. This is consistent with the analysis going back 11 to 2013. There was a GAO audit of inspection 12 findings. Any questions?
13 CHAIR HALNON: Does that include the 14 security findings?
15 MS. AGRAWAL: So I excluded the security 16 findings because it's a public meeting and the slides 17 cannot be publicly available.
18 CHAIR HALNON: And do you see any trend in 19 certain cornerstones, or is it pretty distributed?
20 MS. AGRAWAL: It's pretty distributed.
21 But, yes, since we've done, you know, cybersecurity 22 inspections, there has been an increase in the 23 security area for green findings, yes. And there has 24 been red and green in security, but I just chose not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 to --
1 CHAIR HALNON: Got it.
2 MS. AGRAWAL: The trend in security is 3
pretty similar to what you see here.
4 MEMBER REMPE: So this maybe isn't fair to 5
ask, but sometimes you hear licensees complaining 6
about differences in regional inspectors' 7
interpretation of the requirements. Do you have any 8
insights about that?
9 MS. AGRAWAL: Yes, that is accurate. So 10 in a few slides, I'll show you the breakdown for green 11 findings per region. And this is historically that 12 Region IV has had a higher number of findings in 13 general when we look at green findings. However, for 14 greater than green findings, it's been pretty 15 consistent for the regions. But in green findings, 16 yes. Obviously, every region is a little bit 17 different. You know, some regions, like, for example, 18 I mean, I've worked in three different regions. Some 19 regions like to take three issues, right, three 20 performance deficiencies, write one violation. Region 21 IV probably doesn't have, you know, we tend not to do 22 that. We try to separate those issues and write three 23 findings maybe, you know, versus combining them.
24 So, yes, there is historically some 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 differences between the regions. However, I would 1
say, you know, was it three years, John, since we've 2
done the more than minor -- so we have updated our 3
guidance for how we evaluate the findings from minor, 4
more than minor, criteria. And that's going to bring 5
in more consistency amongst the regions, and I know in 6
certain inspections, for example, the engineering 7
inspections, there's some collaboration among the 8
regions when the findings are, you know, before the 9
findings are issued, you know, what kind of findings 10 are coming up. So there is some effort to kind of 11 bring all the regions together in more consistency, 12 but, yes, of course, there's going to be some 13 differences, yes.
14 Okay. So for green findings, there has 15 been a declining trend since 2017. And I think I've 16 already covered, you know, some of the reasonings, but 17 I'll just share and just kind of reiterate some of the 18 things I already said. So while we have kept most of 19 our analysis for green findings separate from any 20 consideration of more risk-significant
- events, 21 visually at least, there seems to be a relation to 22 what happened with red and green finding here. One 23 hypothesis in the 2018 time frame was that this was 24 just a reflection of several plants shut down, what 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 you just mentioned, including several that were 1
historically not the strongest performers.
2 There was also NEI's contention that it 3
was obviously just, you know, plants have just 4
performed better, drastically improved over the years, 5
and so that's why the findings are low. However, you 6
know, I shared some other insights, you know, from the 7
NRC's perspective, what we have improved as far as our 8
program for the trend.
9 There's also, you know, historically, 10 there has been push also from the licensee side more 11 criticism or more, I don't want to say criticism but 12 more scrutiny for the findings, particularly the green 13 findings, and that has also impacted the inspectors 14 issuing findings. So that does impact the decrease in 15 the findings, as well.
16 And from the operating experience and 17 analytics perspective, just as we were skeptical of 18 the idea that 75 percent of the drop in the findings 19 was a result of 300-percent improvement in the 20 licensee performance over five years, it's obviously 21 not, you know, there's obviously some improvements, 22 but I wouldn't say that much. We do not believe that 23 the increase in re-findings is necessarily an 24 indication of a sudden decline in performance.
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
38 However, a year ago, and what I mentioned, there's 1
been COVID obviously. There has been some move 2
because, you know, the outage work. So COVID is 3
definitely going to have some impact on all the work 4
that was pushed back that's the licensee cutting back 5
6 MEMBER MARCH-LEUBA: Yes, that was going to 7
be my question. Here they're -- they're in the 8
hundreds now. It's clearly a separation with COVID in 9
2020. There's two possibilities: that the work was 10 postponed or the inspections were less in person and 11 in less detail.
12 MS. AGRAWAL: I would say both. I would 13 say both.
14 MEMBER MARCH-LEUBA: When I look at this, 15 I don't see any reason 2022 wasn't it. And I usually 16 do this in 2020 for usual circumstances.
17 MS. AGRAWAL: So, I mean, I would say 18 about a year ago we actually started, as far as the 19 regional inspectors being present, right. And the 20 licensees were just starting to get all that deferred 21 work back into their outages so they're --
22 MEMBER MARCH-LEUBA: So, obviously, we can 23 table your previous conclusion that we keep going 24 down. We're not going down. When you go to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 doctor, he says any unexplained loss of weight. If 1
you've lost weight because you've been on a diet, 2
that's not bad.
3 MS. AGRAWAL: Right.
4 MEMBER MARCH-LEUBA: This is explained.
5 CHAIR HALNON: And there's so many 6
dynamics. It's not misleading; it's just not telling 7
the story. There's three different types of these 8
findings: self identified, self revealing, and 9
inspection --
10 MS. AGRAWAL: NRC identified and licensee 11 identified.
12 CHAIR HALNON: And licensee identified.
13 And that tells a much more story. The self-revealing 14 ones, when something happens and it reveals itself, 15 that, to me, is the most serious of the statistics we 16 should be looking at. A lot of the programmatic 17 aspects, if you look at this, that's the decade of 18 people reaching a period of extended operation at 19 license renewal, so that's another dynamic is that 20 they've raked through their programs, they've got 21 their license in place, and now they're doing their 22 just before period of extended operation inspections 23 themselves, assessments, and getting their programs in 24 place. That's another thing that happened during that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 time frame, the ROP enhancement pushed by the industry 1
which came up with about a dozen things that, 2
surprisingly, would try to reduce the number of 3
findings that came out.
4 There's so many dynamics going on during 5
this decade that this, like I said, it's just not as 6
telling as it could be if you start slicing and dicing 7
it more.
8 MS. AGRAWAL: Yes, there's multiple 9
factors.
10 MEMBER ROBERTS: And this is Tom Roberts.
11 I've got here a question I wanted to ask, which is 12 kind of saying input loss of flex data on operating 13 experience based on things you didn't find. Have you 14 reconciled the state of affairs to see if there's 15 similar trends or whether there's some gaps that they 16 could fill in with their data that you're not seeing?
17 MS. AGRAWAL: So I cannot speak to that 18 because this data does not include the INPOs, but I 19 know that our Headquarters operating experience group 20 in the Division of Reactor Oversight does look at 21 INPOs data and, you know, hey, where we are, what is 22 INPO finding, what is NRC finding, if there is any 23 commonality or differences. So they do monitor that, 24 but I would say that, you know, I guess I can't really 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 speak to that from this data.
1 And here's a breakdown by region and per 2
site. I know we already discussed some of the 3
differences. You know, you see Region IV has 4
historically been a little bit higher, not a whole 5
lot, but, yes, we have our differences in different 6
regions.
7 And for the crosscutting aspects --
8 CHAIR HALNON: Could you quickly just 9
define what crosscutting aspect is for the folks in 10 the public?
11 MS. AGRAWAL: Yes. So --
12 CHAIR HALNON: I asked that question 13 before Walt did.
14 MS. AGRAWAL: So each of the findings have 15 a crosscutting aspect. Well, if it's appropriate, we 16 assign a crosscutting aspect to the finding, and these 17 are the areas of the crosscutting aspects. So there's 18 three main areas, but these are the separate aspects 19 under each of the areas, and I don't want to go 20 through each one. And it just pretty much tells the 21 reasoning behind -- did you want to say something?
22 Oh, okay. Greg, it looked like you had something to 23 say. Okay.
24 So if it's appropriate for the findings, 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
42 we assign a crosscutting aspect that may be the cause 1
of why the licensee failed in these areas. And unless 2
somebody else has a better definition of that -- so 3
every year, once a year we do an annual, end-of-cycle 4
meeting. We talk about each of the plants, how 5
they've done in their assessment pretty much for each 6
of the plants. And as part of that assessment, this 7
is internal to the NRC, as part of that assessment, we 8
actually do look at these areas for crosscutting to 9
see if there's some commonalities. I don't want to 10 say themes but there's commonalities under each of 11 these aspects. And if there are, then we talk about 12 what additional inspection efforts may be required for 13 that area.
14 CHAIR HALNON: So this was a post Davis-15 Besse, I believe, corrective action. So we're trying 16 to get to be a leading indicator to focus inspection 17 resources and licensee assessment resources in areas 18 that are showing a decline, as opposed to a violation 19 or something to that effect.
20 MS. AGRAWAL: That's right. Okay. So 21 2018 - 2022 Region IV was approximately 33 percent of 22 all the ROP inspection findings. And the graphs, the 23 break line shows each of the crosscutting aspects, 24 what fraction of the total number of crosscutting 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 aspects were for Region IV. And just overall, I don't 1
have all the obvious breakdown by the region, but it's 2
pretty consistent amongst the regions how we've 3
applied crosscutting aspects to the findings.
4 And unless there's additional questions --
5 yes?
6 MEMBER KIRCHNER: On this previous slide, 7
so what do you do with this? You know, from the 8
statistics standpoint, nothing stands out really. So 9
you collected this information. Is there something 10 actionable based on this that you'll change your 11 inspection procedures, you'll change your frequency, 12 you'll be more aggressive, you'll be whatever? What 13 takeaway do you get from this? Because all I see is 14 comparable statistics for each of the categories you 15 16 MS. AGRAWAL: Yes. Okay. So each of the 17 aspects, actually, it has maximum number of assigned 18 aspects that are associated with it. So let's say, 19 for example, under problematic condition, so the P1 20 (audio interference). If P1 has 12 findings that have 21 P1 assigned to it, right, now that's the maximum, and 22 so then that would tell us that they actually have a 23 theme associated with that aspect. And so if that's 24 true, if we get to that point, we would add additional 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 oversight for that licensee.
1 MEMBER KIRCHNER: That does not leap out 2
to me from this view.
3 CHAIR HALNON:
From a
licensee 4
perspective, they're tracking it in a much lower 5
threshold than the NRC is tracking it. And this is a 6
per region, so you can pretend it's like a per site.
7 And if there's a trend or what they're calling a 8
theme, a current site will do a self assessment and 9
try to turn that trend around. The 12 is a backstop 10 that the NRC set, saying, if you don't fix it, we're 11 going to come in and help you. And they'll put some 12 resources into inspection. So it basically gives the 13 licensee time to chase their own problems, but the NRC 14 is in a monitoring zone, allowing the corrective 15 action program to work. And if it doesn't look like 16 it's working or it's in the PI&R area, then they're 17 going to put additional resources on inspection.
18 MS. AGRAWAL: So, for example, under PI&R, 19 so we have every two years we have an PI&R inspection 20 team that goes out. If the inspection is coming up, 21 then we would increase the oversight in that area. If 22 not, then we also have a number of samples in a year 23 that's allotted to PI&R. So we would, you know, we 24 would assign samples to look at, you know, that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 particular area, so that's how our oversight --
1 MEMBER SUNSERI: Thinking about Walt's 2
question, I mean, the takeaway for me is is that it 3
was brought up here earlier today that there's 4
potential consistency amongst the region
- and, 5
certainly, the assignment of a crosscutting aspect is 6
somewhat of a subjective call. This graph looks to me 7
like, within Region IV, there's good balance across 8
the country, which is the biggest takeaway for me. So 9
now that, you know, each licensee is treated fair, if 10 you will, but they still are exposed to oversight if 11 they get too many. Would you say that's a fair 12 assessment?
13 MS. AGRAWAL: That's fair. Anymore 14 questions? And back to Dr. Greene.
15 DR. GREENE: All right. Before I go into 16 this, I did want to mention, on the crosscutting 17 aspect, another perspective of this is that the 18 residents themselves closely monitor at the sites 19 specifically that they're at. So the licensee will 20 get a strong message from the residents if they're 21 seeing a build-up in one particular area of CCA, what 22 we call crosscutting aspects, and let them know, hey, 23 we're seeing that you're having a lot of these right 24 here, so what are you doing. So that communication is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 definitely given to the licensee.
1 So what I'm going to quickly discuss on 2
the ROP umbrella is one of the things that we look at 3
for HP or radiation protection, and that's called the 4
three-year rolling average. Basically, it's a three-5 year average dose for NRC sites per reactor per year, 6
and then it's ranked in four quartiles. So this 7
report is actually issued every year from NRC based on 8
data that they received from the licensees. And what 9
we do as HP inspectors or RP inspectors, however you 10 want to look at it, we look at the quartile rankings.
11 And so we used to, we used to have an inspection 12 procedure, which was 7112402, which was titled 13 Occupational ALARA Planning and Assessments. At this 14 time, that particular inspection procedure was retired 15 in 2020. However, aspects of that were still 16 incorporated to another inspection procedure.
17 And so whenever we have potential 18 violations or findings under the ALARA aspect, and for 19 those that do not know ALARA stands for as low as 20 reasonably achievable, which is particularly indicated 21 how much dose a licensee is allowing their workers to 22 receive, when we look at issues under the ALARA 23 aspect, we basically look at how much oversight or 24 inspection should be dedicated to this based on what 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 quartile that particular licensee is in.
1 So, for instance, this right here is 2
showing it for two different type of light water 3
reactors. For those that don't know, commercial 4
reactors in the United States are particularly, 5
they're boiling water reactors or pressurized water 6
reactors, so we have two different charts here.
7 Under the boiling water reactors, the 8
first quartile is the top performer. We only have 41 9
person rem between 2019 and 2021, and that's an 10 average per reactor per year, down to the fourth-11 quartile performers, which are the worst performers.
12 And the bottom of that was 230 person rem. Now, 13 what's important to note here is that we do have what 14 we call a threshold value for ALARA. That is found in 15 Inspection Manual Chapter 0609, Appendix C for 16 occupational radiation and safety. And what that 17 basically says is that, for boiling water reactors, 18 there's a threshold value of 240-person rem. So what 19 does that mean? That basically means that, if we have 20 a site that is exceeding 240-person rem, that 21 potential ALARA violation can potentially be white 22 versus green.
23 Fortunately, we haven't seen our licensees 24 exceed that 240 mark for BWRs or, in contrast, 135-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 person rem for PWRs in quite some time. So, 1
therefore, an ALARA violation wouldn't get them to a 2
white based on our Manual Chapter 0609 Appendix C.
3 So this is just a really quick overview of 4
how we look at licensees from the three-year rolling 5
average perspective. Any questions about that? All 6
right.
7 And just as a reference point, NRC Region 8
IV actually has four BWRs and eight PWRs that we're 9
actively operating, that we're actively monitoring.
10 All right. Next slide. Okay. There we 11 go. All right. So somewhat in contrast, the licensee 12 doesn't really look at three-year rolling averages.
13 They look at what is called collective radiation 14 exposure, and so this is sort of a chart to kind of 15 express what that looks like almost since the 16 inception of power plants. And so you'll see this is 17 ranging from about 1973 up until 2021, and you can 18 see, in general, it's a downward trend that we're 19 seeing. So what does that mean? That basically means 20 the licensees' source term is getting better. Over 21 time, we're seeing that their collective radiation 22 exposure is decreasing as we have gone over time.
23 So the first chart here is actually 24 showing the 2021 average collective dose, and, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 actually, that should be rem. But it's BWRs is about 1
108, PWRs is about 32. And then on the average 2
measurable dose per individual, so these are 3
individual average doses, you'll see that BWRs, their 4
individual staff is picking up an average of 206 5
millirem in a year and PWRs about 81 millirem in a 6
year.
7 So this is just another perspective that, 8
you know, you can look at it at a site and just kind 9
of see overall how licensees are doing in terms of 10 their dose. Any questions about that? Yes?
11 MEMBER BIER: This is Vicki Bier of ACRS.
12 This is not a question about this one slide, but kind 13 of overall the presentation so far. It sounds like 14 there is a lot of kind of procedural aspects to the 15 review. Like you compute all these things. You see 16 if any of the cross-cutting areas are way out of line 17 or you look at the dose relative to the reliable cut-18 off, et cetera.
19 How much of the inspection or findings is 20 qualitative? Like maybe they don't have a lot of, you 21 know, hits on the training, cross-cutting area, but 22 the inspectors just say, well, I don't have a really 23 good feeling about the quality of the training at this 24 plant or, you know, somebody where their dose may not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 be outside of the limit, but you've observed, well, 1
you know, they seem to have poor practices on dose 2
control and so I would expect sooner or later maybe 3
they will exceed a limit. And, you know, kind of the 4
situational awareness side of inspection, I guess, I 5
would describe it as.
6 DR. GREENE: Thank you for that question.
7 So I would say it's a mixture of both, right? So we 8
sort of use the numbers and the quantitative data to 9
sort of risk inform our approach.
10 So if you look at our licensee and our 11 licensee procedures, most of them are risk-informed 12 procedures. So we may look at this data as I 13 demonstrated and say, okay, we're going to allow these 14 many hours to look at this particular program.
15 However, when we get into the program a 16 lot of that information then becomes qualitative 17 because we're looking at how they're implementing 18 different aspects of the program. And so then we can 19 get into things like the cross-cutting aspects to sort 20 of give way to, you know, what is the underlying 21 causes of some of these issues?
22 And as you mentioned before, some of those 23 may be training, some of those may be, you know, 24 oversight or resources or things of that nature. So 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 it's not as much quantitative as that point, but it's 1
really how good is your program.
2 MEMBER BIER: Okay. Mm-hmm.
3 MR. DIXON: Just real quick, this is John 4
Dixon, the Project Experience Chief. To also answer 5
your question, the residents are frequently at the 6
site walking around the plants. So they will 7
frequently come across something that will change the 8
entire direction of their day.
9 Right, they may have planned to go do this 10 surveillance test because this is what was planned, 11 this is what was scheduled for last week. But because 12 of something they walked down, something they come 13 across, something that changes at the plant that day, 14 it will completely change their focus and their shift.
15 Training is a good piece that she had 16 mentioned. We specifically have an inspection 17 procedure where the residents will go spend time at 18 the control room and at the simulator observing, 19 monitoring, you know, paying attention to things of 20 that nature. But even that piece is more encompassing 21 than just doing those two types of activities.
22 It's looking at procedures. It's looking 23 at how they prepare to do the training for the 24 operators. So there is a lot of aspects that are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 quantitative and qualitative equally.
1 DR. GREENE: Any additional questions?
2 Thank you.
3 MEMBER MARTIN: This Bob Martin from ACRS.
4 I couldn't help but Google while we're listening here 5
and seeing that the budget trends for the NRC have 6
been downward, like as much as 15, 20 percent since 7
2014. Beside this data right here, you've shown 8
improving trends related to inspections and such.
9 And, you know, I won't use the word 10 statistics so, you know, there's, you know, lies, damn 11 lies and statistics. Is there anything you might say 12 that because of the budget reductions, you must feel 13 them everywhere, does it impact the inspections, the 14 amount of business and such like that, staffing?
15 Could that influence the trends that we've seen?
16 DR. GREENE: I'll give my opinion and then 17 I'm going to give you my personal opinion. This may 18 be a personal perspective, but I think we all feel it 19 as some point. Appearances by the scale of personal 20 reference, you know, we are probably one staff down.
21 So it makes us take on more inspections at times or, 22 you know, you have more FTE that is being lost because 23 you don't have inspectors out there. But it doesn't 24 really take away from the job in my opinion.
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53 You know, I think we work so well together 1
because we know what we need to pick up when we can't 2
get another inspector on board so we know how to 3
either do more inspection hours before we go onsite 4
or, you know, just better management and planning from 5
that perspective. But I think the crunch is felt in 6
some perspective from everyone.
7 MEMBER MARTIN: You walked that line 8
pretty well.
9 MS. AGRAWAL: So do I need to say more?
10 So, I mean, we haven't seen -- I mean, we haven't done 11
-- the inspection hours have been pretty consistent 12 actually so that's really what I would say. It's been 13 pretty consistent, you know, the hours and number of 14 inspections that we do.
15 Obviously, we've improved, right, under 16 the engineering inspections. But we focus on -- but 17 as far as how many inspection hours and what we 18 performed has been pretty consistent.
19 MR. PICK: Good afternoon, ladies and 20 gentlemen, and especially the members of the ops 21 subcommittee.
22 This is the plan to beat all plans. This 23 is the roadmap for discussing the plan. I'm using the 24 skills I've acquired over 22 years in Toastmasters is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 what I'm trying to do.
1 Aging progresses slowly. On a previous 2
slide was the Parthenon. It has been around for 3,000 3
years. If we look at the plant one month before they 4
cross that magical data four years into their period 5
of extended operation, which is just a term we use to 6
describe the original license period and the re-7 license period or one year into it, it won't matter 8
that much when you think about concrete lasting for 9
3,000 years over in Greece.
10 We are presuming that the application will 11 be received in December, and the NRC will accept it.
12 We won't send it back. That would affect the time 13 limit. Aging measurements apply to both units. If 14 there is something that happens during the review that 15 stops us from verifying Unit 1, then we can do it 16 during the year two inspection.
17 I expected them to read the slides, sir.
18 Don't people on Teams have the slides? This is the 19 plan for the license renewal review of Diablo Canyon.
20 I won't last 10 minutes at this rate.
21 We review in Region IV 100 percent of the 22 aging management programs in the appendix. We only 23 have to review about 70 percent because we are a 24 sampling organization.
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55 The re-licensing set goes back to 2013.
1 I became aware of that. The licensee has already been 2
informed that as an inspector, I know they already 3
were licensed. I led that inspection. We're going 4
back to 2010. I'm sure there wasn't too much 5
significant that happened in that three years, but 6
they're going to factor into their license renewal 7
application and our inspections.
8 We anticipate a small number of changes.
9 Because the original licensing occurred in 2010 and it 10 was withdrawn in 2018, interim staff guidelines for 11 license renewal had been issued. And the staff had 12 issued questions to the licensee and they had 13 responded.
14 So they have already incorporated the 15 post-GALL, Rev. 2 guidelines into their living license 16 renewal application. And that's their baseline for 17 the re-submittal. I don't anticipate a lot of 18 changes. They've been inspected once in this area.
19 What allows us to inspect -- yes, sir.
20 MEMBER BALLINGER: I have a question.
21 Okay. Why is this costing billions of dollars?
22 MR. PICK: Why is what costing billions of 23 dollars?
24 MEMBER BALLINGER: The re-licensing of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
56 Diablo Canyon. They are (simultaneous speaking) a 1
couple billion dollars.
2 MR. PICK: I'm sure this is OGC stuff.
3 I'm not speaking for OGC. They applied, and they 4
withdrew. They got to reapply. So the staff hours 5
will have to be reviewed for the new application.
6 MEMBER BALLINGER: I guess I never could 7
understand because I didn't turn the lights on we.
8 MR. PICK: I agree with you, sir. I 9
agree.
10 MEMBER HALNON: They would suspend capital 11 expenditures for certain things that were long-term.
12 They would suspend working on aging management 13 programs that were required for the initial period of 14 operation. So there is probably a lot of things they 15 had to gear back up that it's --
16 MR. PICK: As a matter of fact, we have an 17 inspection ongoing this week and last week for us to 18 assess what they had started winding down and what it 19 would take to gear it back up relative to plant 20 operations that we are going to tag onto that 21 inspection to see if any of it affected the license 22 renewal. When I get that bullet, I'll go right past 23 it.
24 (Simultaneous speaking.)
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57 MEMBER BALLINGER: I don't know. Somebody 1
said a billion there, a billion there, sooner or 2
later, we're spending a lot of money.
3 MR. PICK: That's beyond my pay grade.
4 That's beyond my pay grade. What authority gives us 5
the ability to conduct our inspections? That is the 6
licensing support inspection procedure.
7 If the aging management program audit from 8
headquarters or the scoping and screening audits in 9
headquarters has questions, then we will use that 10 procedure to follow-up on the questions because we 11 have already reviewed the first submittal. We don't 12 expect the full review because of this inspection. So 13 that's one answer to your question, Ronald.
14 Because they came in for timely renewal, 15 we issued a special inspection to accommodate for 16 timely renewal. What that really means is if we're 17 doing our review of their application and they cross 18 over that magic date where they should shut down, they 19 don't have to shut down because we're doing our 20 review.
21 But it has guidelines for us. That 22 inspection is to go out there during the outage and 23 look at the material condition. That was not done in 24 response to the original application under 71003 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 because it was withdrawn. So those will be first-time 1
inspections.
2 To verify they implemented their 3
commitments effectively and correctly, these 4
inspections weren't done either because they withdrew 5
their application. We will do it this time with a 6
highly qualified four person team with over 90 years 7
of inspection experience in civil, structural, 8
mechanical and electric.
9 My peer in the audience did a great job 10 creating this team of inspectors in the Phase 3. Flow 11 evaluations have to occur. Sometimes headquarters is 12 doing a review of a program, and it's not done. We 13 can't review what is not completed yet.
14 Phase 3 allows us to do the unfinished 15 evaluations after they cross into the period of 16 extended operation. And in their letter, dated March 17 something of this year, there are two programs, buried 18 piping and selective leaching, that require two 19 outages for each unit to implement the program. We 20 will follow-up after each outage when they've done 21 their activities to see how well they are implementing 22 their aging management activities.
23 I'm going to click through this real 24 quick. You have one outage, we're going to do an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
59 inspection. If you have two outages, we're going to 1
do an inspection. We're going to do a 71002 for 2
things we haven't looked at before and assist our 3
peers in headquarters.
4 The Phase 2 commitment, that's going to be 5
four people onsite for two weeks to look at -- do they 6
got solid programs? Did they implement solid 7
programs? And for those that exist, are they 8
effective?
9 In Unit 1 license renewal, we get another 10 shot at verifying the implementation of their 11 programs. In two licenses, then they were in two 12 Phase 3 inspections.
13 What are we going to look at? The 2010 14 inspection had 16 observations. We're doing an in-15 office review to see how well their corrective action 16 program corrected them back then. And for things that 17 were corrected back then that weren't just a change 18 out of a component, are they factoring it into the new 19 license renewal application?
20 We're evaluating the closed commitments in 21 that March letter. They have no commitments on the 22 docket yet because it's a new application. But they 23 did have 75. In their March letter, they had closed 24 25 of those original commitments.
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60 If it was an aging issue back then, then 1
it would be an aging issue now. We're going to check 2
on how well they closed those commitments and do we 3
agree? And by pre-application, I mean before we 4
receive the application in December.
5 Conduct an inspection during the Unit 1 6
outage, we may review programs that have little or no 7
changes. This goes to your question, Ron. A split 8
has existed for years. The GALL guidance hasn't 9
changed, and they already submitted it originally.
10 In talking to them before October if they 11 say, hey, we're going to come in with the same 12 program, I'm going to recommend, why don't we take a 13 look at it? Now would we close the (audio 14 interference) commitment in that report? Well, no, 15 because I'm going to wait until I verify in the new 16 application that it's what I expect. And we're going 17 to incorporate insights from the inspection ongoing 18 today, post-application.
19 So we've received their application.
20 We've accepted it. What kind of inspections are going 21 to occur? Headquarters has identified items if they 22 have any. If they have any questions they need eyes 23 on in the field instead of flying out of Washington, 24 we'll use our planned inspection to look at it.
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61 We're going to make sure they reflect the 1
current guidance in their programs. That the 2
commitments that they make in their application are 3
actually being implemented or can be implemented the 4
way they say. That they are effectively implemented.
5 That's what we do as inspectors. We talk to the 6
engineers onsite. We look at the programs. We look 7
at the completed work, and we conclude whether, yup, 8
it's working the way it should 9
MEMBER BALLINGER:
I have another 10 question.
11 MR. PICK: Yes, sir.
12 MEMBER BALLINGER: We've had a number of 13 SORs going forward. And so have you folks taken a 14 look at those applications and the amps and issues 15 that have come up in those applications and then 16 normalized it with respect to Diablo Canyon to 17 statistically -- you know, you say you don't review 18 everything, but can you use the information in the 19 past to pick areas that you think you should review 20 that may be the more critical ones?
21 MR. PICK: We have not. And I'm not sure 22 that there has been a regional inspection of a plant 23 in SLR yet. I don't know the answer to that.
24 MEMBER BALLINGER: Well, and I'm not --
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62 well, I guess I'm not saying that. What I'm saying is 1
clients come in for subsequent license renewal. And 2
they say, well, we've got this many amps, and these 3
are issues. And we know which plants have had varied 4
piping issues for example or whatever. And you can 5
see what the plants are doing.
6 Have you been able to factor that 7
knowledge into well, now you're going to be out in 8
Diablo Canyon and you do your review. You say to 9
yourself, well, these plans historically in the past 10 are plans that have had issues. We'll use that 11 knowledge to select a statistically significant set of 12 amps to look at normalized to the Diablo Canyon.
13 MR. PICK: We're going to review all of 14 the aging management programs at Diablo. But we will 15 focus on those that more likely have problems based on 16 our inspection experience. We always do that on every 17 inspection. As a matter of fact, if we can figure out 18 what's the most important thing, we'll go there first.
19 Yes, sir. That's how inspectors work.
20 In the future, I've alluded to it earlier.
21 We review the outstanding commitments, those that we 22 couldn't get to prior to entering the PEO and any 23 questions we raise. Or maybe we hit the licensee with 24 a stumper, and they need time to resolve it so they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
63 can't say we're done. We verify that it will be 1
implemented effectively and that's after they earn the 2
PEO or we looked at that flow evaluation or we wait 3
for that headquarters review.
4 The other one I mentioned earlier is there 5
are two programs that they need, the timely renewal 6
period that they asked for to implement selective 7
leaching and buried piping. We know those are future 8
inspections. Each inspection will have a standalone 9
inspection report. Now any other questions?
10 MEMBER REMPE: You bet. I'm not hearing 11 you mention anything about your take on what will be 12 needed for seismic evaluation. So do you anticipate 13 that Diablo Canyon will have some activities that are 14 going to be a little more challenging in a subsequent 15 license renewal?
16 MR. PICK: On the safety side, no, because 17 I was the lead during original licensing until it was 18 withdraw. There was never any seismic concerns of 2 19 over 1 on the safety side. Those were environmental 20 issues being raised by the State of California. I 21 can't speak for the State of California, but this time 22 California wants it. That's my answer as Greg Pick, 23 an individual.
24 MEMBER REMPE: What about flex, they will 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 have to make some of the improvements for flex which 1
I don't know if they started on that at all with --
2 MR. PICK: I don't know that either. But 3
my peer says yes.
4 MEMBER REMPE: It's already been -- okay.
5 Thank you.
6 MEMBER SUNSERI: Hey, Greg. Matt Sunseri.
7 I chair the license renewal subcommittee at ACRS. So 8
I'm not trying to pin you down with this, but just a 9
ballpark. When do you think you will be complete with 10 your evaluation because you lead us and then we follow 11 so any timeline?
12 MR. PICK: I suspect if it's accepted the 13 way the NRC says, I'm kind of speaking for DLR. But 14 they are probably going to follow the 22 month from 15 January of 2024 as close as they can. In preparation 16 for this, I reached out to Brian Harris, the DLR PM 17 and said, hey, when do you think you'll do your onsite 18 amp and scoping audit because that feeds into our 19 71002? He said we're planning it -- if everything 20 goes according to plan, March, 2024.
21 MEMBER SUNSERI: Okay. And from our 22 experience, the ACRS fits under that 22 month window 23 so somewhere in the order of about 20 -- okay, got it, 24 18 months. Thanks.
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65 MR. PICK: Any other questions. I'm going 1
to let my good buddy Sam come up to the lectern and 2
take over.
3 MEMBER HALNON: So just as a time check, 4
Sam, everyone has taken off your time so we thank you 5
for your time, and we appreciate it.
6 MR. GRAVES: Thanks very much. I 7
appreciate your time.
8 MEMBER HALNON: Yeah, we've got about 20 9
minutes. And I need five minutes to wrap up on the 10 staffing and then some public comments. So about 15, 11 20 minutes. And I'll give you a five minute warning.
12 MR. GRAVES: Okay. Well, thanks very 13 much. The clicker works. Yeah, I'm going to briefly, 14 now briefly, talk about the Texas interconnection and 15 some impacts from Winter Storm Uri on the Texas grid 16 and some reliability improvements.
17 But let me preface this with I'm an NRC 18 inspector. I am not an expert, not that there even is 19 such an animal that I've ever met. But anyway, I have 20 zero Toastmaster experience so mine will be a little 21 less than gray.
22 MEMBER HALNON: So notwithstanding that, 23 the reason we put this on the agenda was to discuss 24 really the impact on the nuclear units in Texas, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
66 specifically, towards that last topic was if, once you 1
describe the grid and how it's all isolated, weighing 2
-- when everything goes down, how do you get it back?
3 MR. GRAVES: Yeah, I have some of that in 4
here. It's called black start.
5 MEMBER HALNON: Right.
6 MR. GRAVES: And it is a significant 7
concern for us as well as ERCOT. Everything here, I 8
got from publicly available information and any 9
mistakes or anything else are obviously mine. And it 10 doesn't reflect the Commission or the regional 11 management or op.
12 I call this an agenda. Greg called it a 13 plan. But I'm going to talk a little bit about our 14 guide, something about a little review of the winter 15 event, the impacts of the Texas nuclear power plants 16 briefly on that. I'll talk a little bit about the 17 inquiry, the joint inquiry from FERC, NERC, and the 18 regional entities, especially ERCOT and then the black 19 start concerns and go over some recent improvements to 20 grid reliability.
21 So ERCOT is the Electric Reliability 22 Council of Texas. It is similar to NERC. But I'm 23 sure you probably know that there are three large 24 interconnects from the bulk power system in the United 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 States, Eastern, Western and ERCOT, Texas. Ninety 1
percent of Texas is covered by ERCOT.
2 The Texas legislature sets the rules, 3
gives them to the Public Utility Commission who in 4
turn oversees ERCOT. ERCOT is the reliability 5
coordinator for Texas.
6 Yeah, Texas has a political system which 7
is a -- it does have some strong ties with the fossil 8
fuel entities. And usually, it has the highest 9
install capacity of generation from renewable source, 10 more than 38,000 megawatts in wind and more than 11 20,000 megawatts in solar.
12 The interconnect has more than 1,000 units 13 and 53 plus thousand miles of high voltage 14 transmission lines.
15 So the winter event in February 2021, 16 extreme cold weather. It was minus 5 degrees at my 17 house. That was the coldest it's ever been, and I 18 live 30 miles south of Dallas.
19 A huge amount of electrical load shedding 20 went on, in fact the largest ever in the United 21 States. The cold brought precipitation and snow here 22 and even down in South Texas.
23 The 2021 event was similar to a 2011 event 24 and 2014 cold weather events in Texas in addition to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 others. So this was not the first time bad things 1
have happened to the Texas power grid due to cold 2
weather.
3 It contributed to more than 4.5 million 4
customers being without power for up to four days, and 5
more than 200 people lost their lives because of this.
6 And within our pot, more than 350 generators were 7
taken offline and lost 52,200 plus megawatts power out 8
of the roughly 107,000 megawatts total available 9
capacity. And of the nuclear power plants, one unit 10 in South Texas tripped because of the cold weather.
11 So here is a little graph that I borrowed 12 from an ERCOT report. And on February 15, this is 13 when things really started to go wrong. You could see 14 it started out around 1:23 in the morning. We were 15 around 59.9 hertz, which is reasonable.
16 They tripped about 1,000 megawatts or so 17 on the load shed and frequency restored it to around 18 60 hertz. But these are brackets of 10 minutes. So 19 around 1:33 in the morning, bridge frequency started 20 to decay away, and ERCOT, the operators, they began to 21 manually shed some load. And you can see also where 22 some of the generators began to fail as temperatures 23 started to fall.
24 It was well below freezing at 1:33 in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 morning on February 15. And it had been that way for 1
quite a period of time. The concern here is that red 2
shaded area down there at the bottom below this 59.4 3
hertz line.
4 There are various reasons for that, but 5
for the Texas plants, my understanding from a 6
mechanical perspective is that carbon blading begins 7
to overheat if the frequency drops down about that 8
far. So that was problematic for a lot of steam 9
turbine driven prime movers but also at 59.4 that's 10 when a 9 minute timer begins to engage with what we 11 call the underfrequency load shed relays, which is an 12 automatic protective function that all of the 13 interconnects have. And if it goes on for more than 14 nine minutes or so at that depressed frequency, 15 automatic tripping would start to take place, which 16 could be significant.
17 MEMBER BALLINGER: I'm not sure that it's 18 a steam turbine issue. I think it's a reactive power 19 issue, right?
20 MR. GRAVES: Oh, there are several reasons 21 why 59.4 hertz --
22 MEMBER BALLINGER: Once you get down below 23 that frequency, you get a lot of reactive power.
24 MR. GRAVES: The reactive power --
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70 MEMBER BALLINGER:
(Simultaneous 1
speaking.)
2 MR. GRAVES: Yeah, there are a lot of 3
reasons why 59.4 for hertz is where they set that set 4
point. But the reason why 59.4 hertz is important for 5
us is because Comanche Peak, they set a timer at that 6
value. So I will talk about that here in a second as 7
a matter of fact.
8 Impacts due to Texas plants, we have 9
obviously Comanche
- Peak, South Texas Project.
10 Comanche Peak is about 40 miles or so from here, not 11 too far. And the South Texas Project is about a six 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> drive south, almost to the Texas Coast so, you 13 know, two different areas.
14 But Comanche Peak, they were pretty smart.
15 They proactively implemented their cold weather 16 procedures, recognizing that, you know, watching the 17 weather, knowing that every weather person locally was 18 telling them this is going to get much, much worse.
19 So they were proactive in this.
20 You know they began their cold weather 21 preparation procedures starting on the 14th when it 22 really began to get cold. And they built some 23 temporary enclosures around susceptible equipment.
24 They provided, you know, heat tracing and internal 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 heating to these enclosures for some of these devices, 1
which was pretty smart.
2 They also, we talked about that was also 3
fairly smart, is they started one train of their 4
emergency diesel generators, both
- units, and 5
transferred one train of their vital loads to those 6
diesels in preparation for potential loss.
7 But they did have some problems with the 8
steam generator water level instrumentation line, you 9
know, the automatic level control of the steam 10 generator, but the operators were quickly able to 11 recover that. And it didn't cause a trip or anything 12 like that.
13 But here is where I understood they had 14 some restrictions at the 59.4 hertz involving the 15 turbine. And once they got to that, they started 16 their own timer. And they would have tripped the unit 17 off the line at that point, you know, nine minutes or 18 so into it.
19 Now it could have been associated with the 20 underfrequency load shed, but my understanding was it 21 had to do with the potential heating of blade problems 22 on their turbine. Now I'm definitely not a mechanical 23 guy so I could be wrong.
24 The South Texas Project, not quite so 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
72 good. They did enter their cold weather preparation 1
procedures, but I don't know if it was complacency or 2
what. They are quite a bit further south, and they 3
don't freeze very often. But they didn't go to the 4
same lengths.
5 But anyway, on February 15, due to 6
extremely cold weather, they did end up tripping them 7
offline because the main feedwater pump suction 8
pressure line has a net positive suction pressure 9
sensing line, it wasn't insulated, and it froze. And 10 that caused essentially two of the main feedwater 11 pumps, they thought that they had a loss of suction 12 signal, and it tripped them off. And the branch wrote 13 an offsite violation, which was a finding for them.
14 They actually had a mod that they were 15 supposed to go out and check those exact lines to 16 ensure that they were insulated and had heat tracing 17 and everything on them, but well they didn't do it.
18 And it lost, and it tripped them off line.
19 Steam generator water levels, yeah, 20 equivalent of megawatts or so from their channel 21 radius, and it took them until the 18th at about 7:54 22 p.m. to recover. They had other problems going on at 23 that time.
24 Let's see. All plant safety equipment, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 especially safety-related equipment, it performed as 1
expected. Both Comanche Peak and South Texas Project 2
have since been inspected by, I think it's called a 3
Texas Reliability Entity, who works for ERCOT.
4 But, anyway, NERC and ERCOT have protocols 5
which now requires them to be inspected for winter 6
weatherization. But we asked about this, and we got 7
no formal feedback from ERCOT or the licensee. You 8
know, it was just informal from the regulatory affairs 9
folks who said everything was fine. So that is a 10 concern to my branch now.
11 The joint inquiry, I'm sure you are 12 familiar with this. FERC and NERC and the regional 13 entities, they came up with a pretty well written 14 report that had 28 recommendations to improve the 15 performance for extreme cold weather.
16 So some of the issues that still stick out 17 to us was the Public Utility Commission, it oversees 18 ERCOT. But the natural gas group in Texas was 19 overseen by something called the Railroad Commission.
20 And they each have their own little kingdoms, their 21 fiefdoms.
22 And they didn't really talk and, you know, 23 that latent disconnect was a significant problem 24 because the gas production facilities, they were 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
74 supposed to be on a list of critical loads that were 1
not supposed to be tripped off, you know, under 2
weather-related events, but they were. So a lot of 3
them got divorced from power, you know, as things 4
started to go south on them.
5 But the Risk Reliability Report from NERC 6
in 2021 identified that natural gas delivery to 7
generate the units is one of their top four risks.
8 So recommendations, some of the ones that 9
are appropriate for NPPs that I thought were 10 important, require generator owners to identify 11 critical components to systems, SSEs, that could be 12 susceptible in, you know, freezing weather or adverse 13 weather. And not only do they have to identify it, 14 but, you know, they have to implement freeze 15 protection for those SSEs that they identified. And 16 these were all part of NERC project 202107, which is 17 like the first 10 pieces of Recommendation Number 1 18 out of that FERC report.
19 So it also required annual specific cold 20 weather preparedness plans and training, develop and 21 implement corrective action plans, which all of their 22 plants have anyway. So this was pretty simple for 23 them. But requiring the retrofit of any existing 24 units, and if you're going to have new ones, the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 design has got to integrate protections from, you 1
know, ambient chilled air weather events that they 2
have to analyze for now with this new data on how cold 3
it got. But these were all part of the same project, 4
202107, but these were particularly completed. The 5
Phase 1 is finished.
6 Of interest to us was the Study 7
Recommendation Number 26 and that has to do with the 8
black start capability in the ERCOT footprint.
9 Any questions so far? You can tell I'm 10 not a Toastmaster guru like my friend Greg. Oh, I 11 should have introduced myself earlier with a little 12 more color and said howdy y'all, but I didn't. But 13 here black start concerns. How are we doing? All 14 right.
15 So black start, essentially for anybody 16 that may not know is that if the grid collapses there 17 are certain little island units that can restart 18 without availability of offsite power, without the 19 grid being available, whether it's from batteries or 20 diesels or whatever.
21 They are designed, you know, to start and 22 then they will come up and power another unit that is 23 relatively too graphically close, which would have a 24 little more capacity. And then that would in turn 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 feed another generating unit, which has more capacity.
1 And that process would continue until all these little 2
islanded areas can actually connect together and 3
restore the grid slowly but surely.
4 So ERCOT had 28 black start units at the 5
time and most of them unfortunately were powered by 6
natural gas. Several of them had alternate fuels, but 7
that was problematic, too. So 9 of the 13 black start 8
units operated sporadically or not at all. And 6 of 9
the 15 secondary units ran out of fuel or experienced 10 other outages with freezing natural gas lines.
11 So the problem that got our attention was 12 82 percent of all of those black start resources were 13 either outage, de-rated or failed, so 82 percent.
14 This also got our attention. The ERCOT 15 CEO testified in front of the Texas Senate that the 16 grid was about four minutes away from total collapse.
17 And that was that little red area that you saw the 18 grid frequency was collapsing down to 59.302 hertz.
19 But he told them that it could last for weeks or maybe 20 months.
21 So we're thinking offsite power 22 restoration to nuclear power plants, the models don't 23 go for months. So anyway, we questioned that. We 24 were curious about that. So we had a conversation 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
1 And we brought that to -- of course, they 2
knew it. But we asked them about the interconnection 3
at the time, recognizing that Texas is not connected 4
to anything else. But, you know, some of the other 5
things that have since transpired, that the 6
recommendations of that report have been completed, 7
that's where that asterisk is, addressed by updated 8
reliability standards, the winterization protections.
9 But that doesn't say anything about the lack of 10 interconnect with the other large interconnections.
11 So NRC probabilistic models as you 12 probably know, they are sensitive to the restoration 13 of offsite power, typically, you know, in hours or 14 maybe a couple of days. It's not a long period of 15 time. And here is a graph that --
16 MR. MARCH-LEUBA: Can you back to that?
17 Will the flex equipment help on this long-term being 18 out of offsite power? The flex equipment is designed 19 to keep you going for longer than eight hours.
20 MR. GRAVES: Yeah. Loss of offsite power 21 is not the same thing as station black. Loss of 22 offsite power, they are diesel generators. Their 23 diesel generators are expected to function. That is 24 the power source that they would use, unless they ran 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 out of fuel, in which case if they had flex equipment 1
that would carry, you know, the vital loads necessary 2
to cool the coolant, I guarantee they would use that 3
too, so yeah. But I don't think that's gone into the 4
calculation of the models.
5 MEMBER MARCH-LEUBA: Yeah, but you are 6
saying there is more on the assumption side that is 7
correct.
8 MR. GRAVES: Well, before this event, the 9
graph I'm going to show you from the INL guys and our 10 ERA folks and SRAs, I can explain that.
11 MEMBER MARCH-LEUBA: Okay. I'll wait.
12 MR. GRAVES: Yeah. This graph, right, it 13 is dated -- I got one earlier today that I didn't have 14 a chance to put it in, but it goes to 2020. But the 15 shapes of graphs are the same. There is some -- the 16 concern is the weather-related term, that blue line, 17 this is one of those graphs that graphs the negative 18 thing, right?
19 So essentially as time goes on, the 20 probability of non-recovery is what this shows. The 21 probability of non-recovery on the blue line goes 22 down, down, down. The presumption is that offsite 23 power would be restored, you know, within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, 24 less than that, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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79 The probability that it wouldn't be 1
restored is about a.3. But if it would have really 2
lasted for weeks or months, that graph would not be 3
correct any longer for that weather-related event. So 4
that's what we were still questioning, if the data 5
that we use for this model is appropriate with the new 6
information that we have.
7 So some recent improvements. Some 8
research conducted by S&P Global Intelligence, Texas 9
is second only to California with battery storage 10 capacity and that's a very, very good thing.
11 The reason why we still have lights now is 12 just about every day this month, we've been setting 13 records for electricity usage, and it's well above 14 80,000 megawatts. So the margin is fairly small, but 15 they've put in almost 4 gigawatts of storage, battery 16 storage, since that 2021 event, which is very good.
17 It already had the largest wind fleet in 18 the United States and is expected to add 78 gigawatts 19 to the existing 12 gigawatts solar generation 20 capability. We expect to have 36 percent by the end 21 of this year for our needs and, you know, rising to 43 22 percent in 2035, yeah, maybe.
23 MEMBER PETTI: Just really based on 24 capacity not on megawatt hours.
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80 MR. GRAVES: No, it's capacity.
1 MEMBER PETTI: It's capacity, yeah, okay, 2
then multiply it by the capacity factor, yeah.
3 MR. GRAVES: And I think that's a stretch 4
because as I -- you may know this, but the political 5
system in Texas immediately during this cold weather 6
event, they blamed the renewables. They thought that 7
frozen turbines and all kinds of other things were the 8
real cause of why we were suffering. You know, it 9
took some time for them to recognize it was really 10 fossil fuel concerns.
11 But I'm hoping that trend -- this is me 12 personally. I hope that the trend in renewables 13 continues because it is helping out right now.
14 Anyway, one of the things that the Texas 15 political system did, they required the development of 16 a map of all the essentially -- all the critical 17 infrastructure associated with the supply chain for 18 electrical generation.
19 There was no map. They didn't know where 20 all of these things were. They weren't on the right 21 list to ensure they weren't divorced whenever tripping 22 started to take place. So anyway, they wisely came up 23 and said we're going to make a supply chain map. And 24 they did that.
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81 This map, which is not publicly available, 1
of course, so we take it on faith. But, you know, it 2
points out supposedly where all the generation is and 3
where all the gas power, the natural gas resources, 4
are that feed these generations and where they get 5
power from.
6 Well, in October 2022, they revised 7
emergency preparedness rules, implementing summer and 8
weather preparedness standards in alignment with 9
Senate Bill 3. The rule required the generation 10 entities and transmission providers to complete winter 11 weather emergency preparation measures. And then they 12 had to submit under oath and affirmation the 13 declaration that they are ready.
14 It also required the Texas Railroad 15 Commission to adopt preparedness standards, which was 16 new and help with the production of that supply chain 17 map. And essentially it mandated that the Texas 18 Railroad Commission designate what natural gas 19 infrastructure is now critical and natural gas 20 weatherization that that is in force via inspections.
21 So hopefully Texas will be prepared for a 22 cold weather event that could happen, you know, this 23 winter but any other time. They have made some 24 progress.
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82 MEMBER HALNON: Thank you, Sam. I'm going 1
to relieve you of your duties at this point.
2 Outstanding. I appreciate that.
3 MR. GRAVES: Thanks very much.
4 MEMBER HALNON: This topic was very 5
important.
6 MEMBER MARCH-LEUBA: I did have a 7
question. We don't have any bandwidth here.
8 MEMBER HALNON: You can talk to him 9
offline. The reason we wanted to do this was to 10 inform our weather-related discussions relative to the 11 advanced reactors we saw yesterday and the molten salt 12 reactor that is going to be built in. Could cold 13 weather affect that? Most certainly. So we want to 14 make sure we ask the right questions during use.
15 John?
16 MEMBER MARCH-LEUBA: That was where my 17 question was, which is more of a comment.
18 MEMBER HALNON: Okay. Go ahead.
19 MEMBER MARCH-LEUBA: We normally will --
20 it really is we are always fighting yesterday's war 21 when nobody was aware what the critical load 22 temperature is, what it is for high critical pipes.
23 Is there a high temperature threshold that 24 causes problems? I mean, are we going to have -- how 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 do we know we won't repeat the same event? You know, 1
when you have a heat seeking or re-band that really 2
gets too high, you have to downgrade. Is anybody 3
thinking if we have three days continuous of 115, we 4
get problems?
5 MEMBER GRAVES: All of the new plants, 6
they're all --
7 MEMBER MARCH-LEUBA: Yeah, but in the same 8
frame of catastrophic failure that can cause somebody 9
trying to figure out how to prevent.
10 MEMBER GRAVES: Yeah. That's a very good 11 question. I do know that as part of -- in addition to 12 winter weatherization concerns, there were summer 13 weatherization concerns that they had to accommodate.
14 They had to do an analysis and, you know, identify 15 what the expected high temperature would be and if 16 they are prepared for that type of weather and then, 17 you know, probably add some margin. I don't know for 18 sure what ERCOT made them do. But, you know, other 19 than the broad strokes, I know they made a plan for 20 both hot weather and cold weather.
21 MEMBER MARCH-LEUBA: It certainly affects 22 maintenance.
23 MEMBER GRAVES: Oh, no question.
24 MEMBER HALNON: And personnel safety as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
84 well, I mean, heat stress on the workers themselves it 1
causes a lot of extra, extra time. So let's move on.
2 MEMBER MARCH-LEUBA: We're also fighting 3
less guesswork, and you have to think of what's going 4
to happen 15, 20 years from now.
5 MEMBER HALNON: Yeah. Good point. Yeah, 6
introduce the topic and tell us your guys' 7
presentation and then we'll be done.
8 MR. DIXON: All right. So my name is John 9
Dixon again. I'm a project experience chief 10 responsible for calibrating water for Arkansas Nuclear 11 One. So in general, I'm going to talk about staffing 12 today, primarily specific with the resident inspector 13 developer program. However, it also really applies to 14 our engineering branches, health physics and really 15 all of our technical staff in the regions as well.
16 MEMBER HALNON: And take your time. We're 17 going to extend a little bit so don't short change 18 your presentation.
19 MR. DIXON: It's quick. It's people.
20 It's important, but it's quick. So the resident 21 program in general, there are at least two residents 22 that are at every site. Some sites, the larger sites, 23 Palo Verde, Oconee, Vogtle, they have three or more 24 residents depending upon what specific is for the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 site.
1 The residents also have a seven year time 2
limit that we have to adhere to. And that's just to 3
make sure that they don't get too close to the 4
licensee, make sure they don't lose their objectivity 5
to be able to fully inspect, to be able to point out 6
problems and concerns with them.
7 In each region, you have up to eight 8
resident inspector development program candidates that 9
we hire specifically for the program. They get 10 priority choice for any vacant resident positions 11 before it goes to postings for other people that are 12 in the region or at headquarters.
13 All the regions are also trying to 14 overhire if possible because of all the current 15 vacancies just in general that are happening in the 16 regions.
17 So just a little bit of insight into how 18 difficult this is becoming. So in just this fiscal 19 year alone, we've done a pre-screen of at least 100 20 different folks. Out of those 100 folks, we hired 9 21 currently, 3 more that have accepted offers. So 22 that's 12. So that's just over 10 percent. That was 23 kind of at the start of the year though.
24 As of right now, we're actually looking at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 less than 5 percent. So we're having to go through a 1
whole lot more applications to bring folks in. Right 2
now in this slide, I did this last week and this is 3
already out of date.
4 It says we're trying to hire four more 5
this year, but because of moves that have already 6
transpired because of other things that have been 7
going on, that number is actually higher now. So 8
that's how quickly things are changing. And it's not 9
just Region IV. It's all four regions that are 10 dealing with this right now.
11 MR. MARCH-LEUBA: Sorry. Just me this 12 afternoon, I may be napping but you say that you only 13 hire 5 percent of the people that apply? Typically, 14 what we've seen now is you cannot find people to 15 apply, and you hire everybody.
16 MR. DIXON: Right so that's -- I'll get to 17 there in just a minute. But effectively, that's the 18 position that we're starting to get into right now.
19 So I might review 100 applications. But 20 out of those 100 that I actually get to meet, right, 21 so this is after human resources has already done the 22 first screen. I will look at it then. So out of the 23 100, I may only pick six to try to go talk to to 24 interview. Out of those six, we may offer all six but 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
87 we may only get one or two that actually accept.
1 MEMBER MARCH-LEUBA: Because those 94 you 2
interview were not qualified?
3 MR. DIXON: A mixed bag. So remember the 4
resident inspector development program is very 5
specific. And I'll get to that in the very last 6
slide.
7 So we've had three individuals that have 8
actually left the agency and part of it is because of 9
the last slide that I'll get to in just a minute. But 10 the benefit is all three of those individuals got a 11 promotion. So the industry, just like you had talked 12 about before, really covets the experience of the 13 resident program. So we do have to be concerned with 14 that aspect.
15 These slides are also out of date already 16 in just the last couple of weeks that I put them 17 together. So residents that have moved to other 18 positions, so this is also part of the answer to your 19 question.
20 The agency is moving people around at a 21 really high rate right now. The expected number to 22 hire was 400 for this fiscal year. Well, that creates 23 all kinds of openings at all kinds of different 24 levels. The agency also covets the residents. So 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 we're losing residents to other positions within the 1
agency.
2 So continued challenges, the big thing 3
here in my opinion is the requirements in the 4
telework. That is causing a lot of problems when we 5
call individuals and we say, hey, we expect you to 6
move to the DFW region. And then within six months to 7
two years, you've got to move to a site.
8 Oh, you can only be on the site for four 9
to seven years then you've got to move to another 10 site. That's it, tap, I'm done. I don't want to be 11 considered for this position any longer.
12 And then if they are, the very next thing 13 we talk about it this position is really not telework.
14 You are expected to show up to the site every day.
15 Yes, we do have some flexibilities. Yes, there are 16 some hours that you can do that are telework, but by 17 and large you show up to the site every day. That 18 cuts a lot more people out.
19 MEMBER MARCH-LEUBA: Sorry. I'm slow this 20 afternoon. What you are telling me is of the majority 21 of people that apply, after you explain to them what 22 the job entails, they don't want it.
23 MR. DIXON: Correct.
24 MEMBER MARCH-LEUBA: It's not that you are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
89 rejecting them because they are not qualified. They 1
are really not applying after they find out.
2 MR. DIXON: Correct.
3 MEMBER MARCH-LEUBA: Okay. That's more in 4
line of what I thought.
5 MEMBER BALLINGER: This is Ron Ballinger.
6 Let me try to get an understanding. The initial cut 7
set, the people that you get to see, are the ones that 8
pass some form of a minimum threshold.
9 MR.
DIXON:
Minimum threshold of 10 experience and education.
11 MEMBER BALLINGER: Okay. What is the 12 minimum threshold?
13 MR.
DIXON:
So from an education 14 standpoint, we are only looking at primarily folks 15 that have a bachelor's or greater degree.
16 MEMBER BALLINGER: Okay.
17 MR. DIXON: And we've looked at both, 18 right out of college, and we've not had good 19 experience with those. We have primarily tried to 20 focus on what we call mid-career, which is three plus 21 years of experience.
22 MEMBER REMPE: You mentioned several were 23 waiting for their security clearance. Once you 24 finally get someone who says yeah, I'd like to apply, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
90 how long does it take to get through the onboarding 1
process?
2 MR. DIXON: It really depends upon the 3
background of the particular individual. We've had it 4
go literally in one month if they have an existing 5
security clearance to over a year if they were from 6
Abu Dhabi or were working for the Chinese 7
construction.
8 MEMBER BALLINGER: Okay. What about --
9 now this is personal. What about a system whereby you 10 take a junior college graduate. You hire them into 11 the system at the plants or they do or somebody does.
12 And as a result of the training that they get during 13 their tenure at the plant, they become qualified for 14 the resident inspection position. Can you grow your 15 own in other words?
16 MR. DIXON: So the sites definitely do 17 that at the junior college level. For us, they would 18 not meet the minimum requirements with human resources 19 because they don't have a bachelor's degree.
20 MEMBER BALLINGER: So that is the cut-set.
21 You've got to have a bachelor's degree, that's it. So 22 has anybody actually looked at that? Is that an 23 absolute requirement?
24 MR. DIXON: The way the positions are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 currently posted right now, what we're looking for, 1
yes. But that's after they graduate with a bachelor's 2
degree. Correct. A ranked program will be kind of 3
another similar program to that.
4 MEMBER BIER: Following up from what Joy 5
was asking this morning about are there requirements 6
that seem either nonsensical or overly burdensome, I 7
mean, some of these requirements seem pretty clearly 8
necessary. But to what extent is the seven year 9
rotation necessary and is that something that somebody 10 should be re-evaluating or do you think it's really 11 important to have that?
12 MR. DIXON: So that has been raised 13 multiple times. And that actually has been extended 14 once already. It used to be five years, and it's been 15 extended to seven years.
16 We do have a separate working group that's 17 called the resident retention working group that looks 18 at different things to propose to how to make it more 19 advantageous to get people to want to apply to the 20 resident program. And the seven year time limit is 21 one that continuously comes up.
22 However, like I mentioned, the concern 23 about losing your objectivity to the site really is a 24 pretty big concern we have.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
92 MEMBER PETTI: Just going back to the 1
degree requirement, it's a science or engineering 2
bachelor's? You won't be accepting someone with an 3
agricultural degree or even a liberal arts degree?
4 MR. DIXON: So liberal arts, I would say 5
no, not categorically. However, generic STEM, so 6
math, science, engineering, we do tend to heavily 7
focus on nuclear mechanical or electrical. But we've 8
had chemical engineers. We've had biomedical, you 9
know, bioengineering.
10 MEMBER PETTI: You know, you read stories 11 in the press about large corporations are reevaluating 12 these sorts of requirements. And they have moved from 13 college degrees to not even have college degrees for 14 many of their positions. I've never drilled down to 15 figure out what it was, but I've read a lot about that 16 so. It's worth probably re-looking at that again 17 although this is highly specialized.
18 MEMBER BALLINGER: Yeah, kind of a more 19 holistic approach to say, well, we really would like 20
-- our experience is that college degree people work 21 out best. However, there may be some cases where that 22 requirement is -- somebody comes in with so much 23 experience, doesn't have a college degree, well, 24 that's a more holistic approach to that first initial 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
93 cut-set. It might work in some cases.
1 MR. DIXON: I would agree.
2 MEMBER PETTI:
Experience can be 3
substituted by the need.
4 MR. DIXON: The postings do provide for 5
experience to a certain extent. But in my 6
conversations with human resources, for all the 7
applicants that we've been getting in, they all have 8
to have a bachelor's degree.
9 So like with the Navy nuke experience, 10 what a lot of them do is they will go get the -- I 11 know Thomas Edison is one of them, and I forget the 12 other university, that basically gives them credit for 13 their experience as a Navy nuke and gives them a 14 degree.
15 MR. MONNINGER: So, John, maybe I could 16 also add in. So I think this is actually an issue 17 across the entire federal government in the hiring 18 process. You know, it's probably a relic from the 19 50s, 60s, 70s, 80s, 90s, et cetera. The current 20 administration and the previous administration with --
21 I'm not sure if it's OPM or whatever, they've been 22 issuing guidance in terms of, you know, trying to get 23 away from the explicit degree requirements to 24 experiential learnings, et cetera.
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
94 However, it hasn't trickled down into all 1
of the federal agencies' hiring process. But it is 2
getting there, but we're not there yet. And I believe 3
many other agencies aren't there yet, but, you know, 4
that transition is occurring.
5 But, you know, in order to credit a 6
position being a 15, 14, 13, there is a scoring 7
system. And for jobs that require a degree, you get 8
more points. And that's one way that the NRC has be 9
it the 15, the 14, the 13s, et cetera. So the entire 10 system needs to change.
And the current 11 administration, there has been guidance out there, but 12 it hasn't filtered all the way through the process.
13 MEMBER BALLINGER: How does it work in 14 Europe?
15 MR. MONNINGER: They have a very different 16 two track system in their educational system, college 17 versus technical. And the technical side is very much 18 appreciated, much more appreciated than it is in the 19 U.S., I think.
20 MR. DIXON: If a U.S. citizen was to 21 apply, for example, OECD to the NEA or IAEA, I would 22 say the requirements are actually higher. You read 23 any of those vacancy announcements, the entry level is 24 a master's degree in the -- you know, so NEA, Nuclear 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
95 Energy Agency, and IAEA, but, yeah, they are pretty 1
explicit.
2 MEMBER BIER: I guess part of the reason 3
that I was questioning the seven year retention, I 4
certainly understand the idea captured by the locals.
5 But it seems like a career path that says, gee, you 6
can live in Dallas for five years whatever maybe or a 7
recent college grade, a newlywed, you get the 8
nightlife and the excitement of the big city, and then 9
you know that you will move out to some place with 10 affordable housing, and you know, et cetera. It seems 11 like it's kind of a typical life path to say, sure, I 12 get my five years in the big city and then I will move 13 to a small town and raise my kids or whatever.
14 And it seems like without the seven year 15 relocation, that might be a lot more attractive for 16 people who say, you know, I'm not ready to settle down 17 yet, but I know that's coming. It's a thought.
18 MR. DIXON: I appreciate that. Any final 19 questions?
20 MEMBER HALNON: Thank you, John. We're 21 going to go ahead and move along here. I want to open 22 up the line for public comment at this time. The way 23 the public can make a comment is to virtually raise 24 your hand. The facilitator will unmute your mic and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
96 then you can introduce yourself and make your comment.
1 So at this point, is there any public comments? And 2
I will call on you by name if I see a hand raised.
3 Okay. Leigh, Lee, Lloveras? Can you unmute?
4 MS. LLOVERAS: There you go. Can you hear 5
me?
6 MEMBER HALNON: Yes.
7 MS. LLOVERAS: Hi, there. My name is 8
Leigh Anne Lloveras. I'm with the Breakthrough 9
Institute. And we'd like to offer the following 10 comment for your consideration regarding the winter 11 storm section.
12 The NRC should consider how nuclear power 13 plants can help to provide more resilience through 14 black start capacity to the grid. Currently, they are 15 required to trip during a loss of offsite power. The 16 best way to avoid long offsite power recovery time is 17 to avoid the loss of power in the first place.
18 A delay in the requirement to trip in the 19 event of a loop event would increase grid reliability 20 instead of exacerbating the issue by removing the 21 nuclear power plant capacity and frequency inertia at 22 the very time it's needed most.
23 In the event of a blackout, nuclear power 24 plants have supplies to maintain safety for extended 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
97 periods of time. The site increase in risk as a 1
result of increased blackout probability pales in 2
comparison to the immediate danger and frequent loss 3
of life as a result of blackout events.
4 Thank you for the opportunity to comment.
5 MEMBER HALNON: Thank you for your 6
comment. Any other comments from the public? Leigh, 7
do you have another one or are you just -- okay.
8 Never mind. Okay. I don't see any additional hands.
9 I will ask the members if there are any final comments 10 or questions before we close.
11 Okay. First of all, thank you, John, and 12 your staff. Excellent presentations and information.
13 As you can see, the membership is about to pontificate 14 and explore, I guess, is the right word for it. We 15 certainly appreciate the facilities, the time that 16 you've put into it, the interactions we've had today 17 and we just wish you the best on your new assignment.
18 We have a lot of confidence in your staff 19 here. I appreciate it very much.
20 One last chance for members? I believe 21 that means I do this, the meeting is adjourned. Thank 22 you.
23 (Whereupon, the above-entitled matter went 24 off the record at 3:13 p.m. CDT.)
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
ACRS Subcommittee on Plant Operations and Fire Protection Public Meeting July 26, 2023 NRC Region IV Presentations
Our People are Our Greatest Asset!
Region IV Priorities
- Risk-informed completion of the materials and reactor inspection and licensing programs while adapting to a new hybrid work environment
- Proactive management of human capital for recruiting, hiring and professional development of staff that recognizes the value of diversity and inclusion
- Continued progress toward achieving the Region IV Vision using our Transformation Action Plan including well-defined Objectives and Key Results
Presentation Topics Region IV ROP Trends Ami Agrawal, Team Leader, Inspection Program and Assessment Team Natasha Greene, Senior Health Physicist Perspectives on Diablo Canyon License Renewal Greg Pick, Senior Reactor Inspector Impacts from Winter Storm Uri and Recent Grid-Related Reliability Improvements Sam Graves, Senior Reactor Inspector Residents and RIDP Staffing Challenges John Dixon, Chief, Reactor Projects Branch D
Region IV ROP Trends
Action Matrix Status Region IV 3Q2022 4Q2022 1Q2023 2Q2023 Current Callaway Column 2 Column 1 Waterford Column 2 Column 1 Columbia Column 2 Riverbend Column 1 Column 2 Columbia and Riverbend are the two plants in Column 2 (as of July 20, 2023).
Greater-than-Green Findings 2022/2023
- Waterford radiation monitor non-conservative calibration issues (White)
- Waterford calibration errors in WRGMs (White)
- Columbia contamination event (White)
- River Bend HPCS transformer (White)
Columbia Generating Stations White Finding Timeline/Details
Greater than Green ROP Findings Trend
- Noticeable increase in greater-than-Green ROP findings in 2022 compared to the previous few years 0
2 4
6 8
10 12 2018 2019 2020 2021 2022 Greater-than-Green Findings Greater-than-Green findings here are counted by site; the year is assigned based on the enforcement action case number.
- Noticeable increase in greater-than-Green ROP findings in 2022 compared to the previous few years
- Looking a few years further back though, this appears to be in line with previous levels of performance 0
2 4
6 8
10 12 2015 2016 2017 2018 2019 2020 2021 2022 Greater-than-Green Findings Greater than Green ROP Findings Trend
- Noticeable increase in greater-than-Green ROP findings in 2022 compared to the previous few years
- Looking a few years further back though, this appears to be in line with previous levels of performance
- Going back further yet shows a clear decreasing trend over a 15-year time frame 0
5 10 15 20 25 30 Greater-than-Green Findings
= y-axis maximum in previous two graphs Greater than Green ROP Findings Trend
Breakout of Greater-than-Green Findings
- Nothing particularly notable about regional distribution 0
5 10 15 20 25 30 GTG Findings by Region Region 1 Region 2 Region 3 Region 4
ROP Green Findings 0
200 400 600 800 1000 1200 Green Findings Declining Trend clear by 2017 2021 first year-over-year increase since 2011 Analysis determined trend driven by change in the application of the more-than-minor threshold
0 50 100 150 200 250 300 350 Findings by Region RI RII RIII RIV 0
5 10 15 20 25 30 Findings-per-Site by Region RI RII RIII RIV
Region 4 Cross-Cutting Aspect Assignment 0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
Region 4 Fraction of CCA Assignments 2018-2022
- - - R4 % of all findings
Three-Year Rolling Averages (TYRA)
The TYRA is the 3-year average dose for NRC sites per reactor per year, ranked in four quartiles for BWRs and PWRs.
Collective Radiation Exposure (CRE)
The sum of the individual doses received in a given time period by a specified population (i.e., reactor workers) from exposure to a specified source of radiation.
Questions?
Perspectives on Diablo Canyon License Renewal (Region IV Inspection Strategy - Greg Pick)
Agenda
- Premises
- Inspection Guidance
- Inspection Milestones
- Pre-application Inspections
- Post-application Inspections
- Phase 3 Inspections
Premises
- Aging processes progress slowly
- Received Application in December 2023 and accepted
- Aging management programs apply to both units
- Review 100 percent of AMPs and related commitments
- Review operating experience from 2010
- Anticipate small number of significant changes
Inspection Guidance
- 71002, License Renewal Inspection
- 71013, Site Inspection for Plants with a Timely Renewal Application Phase 1 - outage walk downs Phase 2 - commitments and aging management programs Phase 3 - unfinished evaluations
Inspection Milestones
- 10/23 71013 U1 Phase 1 Outage
- 04/24 71013 U2 Phase 1 Outage
- 06/24 71002 Licensing Inspection
- 08/24 71013 U1 Phase 2 Commitment
Inspection Milestones (contd)
- 11/2/24 U1 License End Date
- 02/25 71013 U2 Phase 2 Commitment
- 8/26/25 U2 License End Date
- TBD 71013 Phase 3 as needed
Pre-application Inspections
- Review corrective actions from 2010 inspection
- Evaluate closed commitments from 2009 application
- Conduct inspection during Unit 1 Outage
- Review programs with anticipated little or no changes
- Incorporate insights from focused baseline inspection that assessed potential gaps
Post-Application Inspections
- Review HQ identified items, if needed
- Verify programs reflect current guidance
- Verify commitments implemented
- Confirm programs effectively implemented
- Conduct inspection during Unit 2 Outage
Phase 3 Inspections
- Review outstanding commitments and programs during timely renewal period
- Review selective leaching and buried pipe programs
Sam Graves Engineering Branch 2 Division of Operating Reactor Safety Region IV Impacts from Winter Storm Uri and Recent Grid-Related Reliability Improvements Texas Interconnection -
Disclaimer The information presented here was gathered from numerous publicly available sources and is not the official position of the Commission nor Regional Management.
Any mistakes or omissions are mine alone.
ACRS Region IV Presentation - 7/23 30
Agenda
- 2021 Winter Event Review
- Joint Inquiry - Issues, Recommendations and Updates
- Black Start Concerns
- Recent Improvements to Grid Reliability 31 ACRS Region IV Presentation - 7/23
Texas Interconnect - ERCOT 32 ACRS Region IV Presentation - 7/23 The Electric Reliability Council of Texas (ERCOT) operates the Texas Interconnection under rules established by the Texas Legislature, with oversight from the Public Utility Commission of Texas (PUCT).
Texas Interconnect - ERCOT 33 ACRS Region IV Presentation - 7/23
- Texas currently has a political system with strong ties to fossil fuels, yet it has the highest installed capacity of generation from renewable energy resources in the U.S.
(>38,000 MW in wind, >20,000 MW in solar).
- The interconnect consists of more than 1,000 generating units and about 53,000 miles of high-voltage transmission lines.
- In February 2021, a period of extreme cold weather caused the largest controlled electrical load shedding event in US history.
- In addition to arctic air, the cold front brought freezing precipitation and snow to large parts of Texas and the South-Central U.S.
- The 2021 event was similar to a 2011 and 2014 cold weather event in Texas.
2021 Winter Event Review 34 ACRS Region IV Presentation - 7/23
- The adverse weather contributed to power outages affecting more than 4.5 million customers throughout the ERCOT region, with some outages lasting longer than four days.
More than 200 people lost their lives.
- Within ERCOT, more than 350 generators were taken offline resulting in a loss of >52200 MW out of 107514 MW total available capacity.
- One unit at South Texas Project tripped late in the event timeline due to weather impacts.
Event Review 35 ACRS Region IV Presentation - 7/23
Around 01:33 on 2/15 grid frequency was becoming problematic. Too little available generation capacity vs. loading was exacerbated by more generators going offline. Edging closer to 59.4 Hz (Red Shaded Area) and the UFLS timer.
10 minute Intervals 60-Hz Line 59.4-Hz Line 36 Event Review ACRS Region IV Presentation - 7/23
Impacts to Texas NPPs - Comanche Peak ACRS Region IV Presentation - 7/23 37 Comanche Peak (CP) implemented their procedures for cold weather preparation prior to the arrival of the cold front on February 14, 2021.
CP explained to us that they had expected the cold weather duration to be unusually long with temperatures lower than previously experienced.
CP had proactively built temporary enclosures around susceptible equipment and provided temporary heating to the enclosures.
Impacts to Texas NPPs - Comanche Peak ACRS Region IV Presentation - 7/23 38 In anticipation of potential grid frequency anomalies, CP started and transferred one train of vital loads to an emergency diesel generator (EDG) on each unit.
On the evening of 14 February, CP had a steam generator water level instrument line freeze, which briefly impacted automatic level control of the associated steam generator; Operators quickly took manual control of S/G level and successfully thawed the line recovering the instrument.
CP had a further restriction involving main turbine operation with grid frequency below 59.4 Hz and had a timer running that would have driven them to trip the generator.
Impacts to Texas NPPs - South Texas Project ACRS Region IV Presentation - 7/23 39 South Texas Project (STP) also implemented their procedures for cold weather preparation prior to the arrival of the cold front.
On February 15, 2021, Unit 1 was at 100 percent power with three main feedwater pumps feeding the steam generators.
Extremely low temperatures resulted in an uninsulated main feedwater pump suction pressure sensing line freezing (located outside on the turbine deck), causing two main feedwater pumps to trip on a false loss of suction source signal. This was the subject of a non-cited violation: FIN 05000498/2021002-01 Inadequate Cold Weather Procedures Leads to Plant Trip.
Reactor and main turbine automatically tripped due to low steam generator water levels, resulting in the loss of approximately 1200 MW to the grid. The unit returned to full power at 7:54 p.m.
on February 18.
Impacts to Texas NPPs ACRS Region IV Presentation - 7/23 40 For both CP and STP, resident inspectors tracked the weather and the impacts to the sites and kept regional management well informed of ongoing issues.
All plant safety equipment performed as expected.
Both Texas NPPs have since been inspected by the state reliability coordinator, as required by both NERC and ERCOT protocols, for winter weatherization. CP has recently been inspected for summer preparedness. No significant issues were shared with the Region. (In fact, we received no formal information at allonly informal feedback from the site)
NRC inspectors continue to review plant preparations for adverse weather (hot or cold) as part of the Baseline.
Joint Inquiry - Issues, Recommendations, and Updates ACRS Region IV Presentation - 7/23 41 FERC, along with NERC and regional entities including ERCOT, initiated a joint inquiry into Winter Storm Uri that resulted in a joint report in November of 2021.
The report included 28 recommendations aimed to improve extreme cold weather operations, preparedness, and coordination. Several apply to NPPs.
- While the PUCT oversees electricity services (and ERCOT),
the natural gas sector is regulated by the Texas Railroad Commission. This relationship (or lack thereof) was a latent disconnect in event communications.
Many gas production facilities were not identified as critical loads, and were not protected when manual load shedding became necessary. This information disconnect compounded the event with additional losses of generation capacity due to fuel issues.
NERCs 2021 Reliability Risk Priorities Report identified the ability to deliver natural gas to generating units supporting reliability as one of their top four risks.
Issues, Recommendations, and Updates 42 ACRS Region IV Presentation - 7/23
Issues, Recommendations, and Updates
- Require Generator Owners to identify cold-weather-critical components and systems which are susceptible to freezing or otherwise failing due to cold weather, and which could cause the unit to trip, derate, or fail to start.
(*NERC Project 2021-07 Phase 2, Due Winter 2023-2024) Applies to NPPs.
- Require Generator Owners to identify and implement freeze protection measures for the cold-weather-critical components and systems. (NERC Project 2021-07 Phase 2, Due Winter 2023-2024) Applies to NPPs.
43 ACRS Region IV Presentation - 7/23
- Project 2021-07 is a two-phase project to address the 10 sub-recommendations in Key Recommendation 1 of the Report for new or enhanced NERC Reliability Standards (EOP-11 and EOP-12).
Issues, Recommendations and Updates Require annual unit-specific cold weather preparedness plan training. (*Project 2021-07 SAR Phase 1) - Includes NPPs.
Develop and implement corrective action plan (CAP) for identified equipment outages, failures to start, or derate (Project 2021-07 SAR Phase 1) - Similar program exists at NPPs.
Require the retrofit of existing generating units, and for new generating units, to design them to operate to a specified ambient temperature and weather conditions (e.g., wind, freezing precipitation). (Project 2021-07 SAR Phase 1) Includes NPPs.
Study Recommendation 26: A joint FERC-NERC-Regional Entity team should study black start unit availability in the ERCOT footprint during cold weather conditions. (Winter 2023-2024) 44 ACRS Region IV Presentation - 7/23
- Project 2021-07 SAR Phase 1 has been implemented.
Black Start Concerns ERCOT had a total of 28 Black Start resources - all used natural gas as their primary fuel, while some had an alternate fuel.
Nine of the 13 primary Black Start-capable generators were operating sporadically, and six of the 15 secondary generators were experiencing outages or lack of fuel.
Over the course of the event, 82 percent of the Black Start resources, comprising 1,418 MW out of a total 1,711 MW experienced an outage, derate, or failure to start at some point.
45 ACRS Region IV Presentation - 7/23
Black Start Concerns ERCOT CEO testified in front of the Texas Senate that the grid was about 4 minutes from collapse and the condition could potentially last weeks.
The regional electrical branch questioned whether the potential failure of offsite power for an extended period (weeks or months) was appropriately captured in NRC risk models for Texas plants, given the additional concerns with the weather impacts to the dedicated Black Start units.
46 ACRS Region IV Presentation - 7/23
Black Start Concerns The branch voiced concerns with NRR and FERC staff that the lack of connection between ERCOT and the other Interconnects, combined with the lack of winterization protections for the Black Start units in the ERCOT system*, may challenge our risk model assumptions and substantially impact NRC regulatory activities.
NRC probabilistic risk models are sensitive to restoration from a loss of offsite power and include favorable estimates of recovery, usually within days, based on broad industry trends.
47 ACRS Region IV Presentation - 7/23
- Should be addressed by updated reliability standards
Black Start Concerns NRC models the recovery of offsite power based on historical data from industry, producing a family of curves where the non-recovery probability trends towards lower and lower values as the time after initiation of the LOOP increases.
48 ACRS Region IV Presentation - 7/23
Recent Improvements to Grid Reliability
- Based on research conducted in May 2023 by S&P Global Intelligence, Texas is second only to California in battery storage capacity, with 2.2 gigawatts of storage and 29.2 gigawatts in the planning pipeline by 2030.
- ERCOT already has the largest wind fleet in the U.S.
and is planning to add 78 gigawatts of capacity to its existing 12-gigawatt solar generation.
- In 2023, solar and wind power are expected to jointly account for 36 percent of the grid's needs, rising to >43 percent in 2035.
ACRS Region IV Presentation - 7/23 49
Recent Improvements to Grid Reliability In April 2022, The Texas Electricity Supply Chain Security and Mapping Committee adopted an Electricity Supply Chain Map of critical infrastructure.
The map identifies critical infrastructure facilities that make up the states electricity supply chain, including electric generation plants and the natural gas facilities that supply fuel to power the plants.
ACRS Region IV Presentation - 7/23 50
Recent Improvements to Grid Reliability In October 2022, the PUCT revised the Weather Emergency Preparedness rule (16 TAC § 25.55) implementing winter and summer weather preparedness standards in alignment with State Senate Bill 3.
The rule required generation entities and transmission service providers to complete winter weather emergency preparation measures and submit a declaration of winter weather preparedness.
ACRS Region IV Presentation - 7/23 51
Recent Improvements to Grid Reliability
- Texas State Senate Bill 3 (SB) also required the state Railroad Commission to adopt preparedness standards no later than 6 months following the production of the Texas Electricity Supply Chain Security and Map.
- Facilities subject to the rule were required to implement requirements including:
- Critical Designation of Natural Gas Infrastructure (§3.65)
- Natural Gas Weatherization (§3.66) - Enforced via Inspections ACRS Region IV Presentation - 7/23 52
Questions?
Residents and RIDP Staffing Challenges
Resident Program
Prescreened over 100 applicants in FY 2023
Residents that left the Agency
Residents to other Positions
Continued Challenges Other Issues:
Move requirements Telework Limits
Questions?